Authors of a gigantic, multi-year plan to develop as much as two million acres of the California Desert for renewable energy seem to be unaware that the Environmental Protection Agency (EPA) has gotten there first. The EPA has spent the last four years inventorying two million acres of polluted land in California that might be suitable for renewable energy development, but their work doesn't even rate a mention in the upcoming desert energy plan.
A preliminary guide to the content of the mammoth Desert Renewable Energy Conservation Plan (DRECP), includes thousands of pages of description of what we'll see in the DRECP when it's finally published. But one thing it seems not to include is any mention of the EPA's RePowering America's Lands initiative, a multi-year, multi-million-dollar project that has already identified millions of acres of contaminated lands suitable for renewable energy development, including sites in the California desert.
The DRECP's recently released Description and Comparative Evaluation of Draft DRECP Alternatives is a huge document intended only as a preliminary guide to DRECP's eventual Draft Environmental Impact Statement, and ReWire may have missed a stray paragraph or footnote referencing the EPA's project.
But a detailed look at the Description's sections most likely to benefit from including the work EPA has already done shows no apparent reference to the EPA's several-year cataloguing effort in those sections -- and in fact almost no references to the EPA itself.
For instance, description of the first of seven Alternatives presented in the Description, the "Disturbed Lands/Low Conflict" Alternative intended to steer development of renewable energy facilities away from biologically valuable lands, makes no reference whatsoever to the RePowering America's Lands initiative. This despite the EPA's identification of landfills, abandoned mines, Superfund sites and brownfields, and other lands too altered to bear much ecological value in the California desert that may well be suitable for utility-scale solar, biomass and other renewable energy.
One reason for this may be that the bulk of the EPA's 20 million acres identified as potential renewable energy development sites are smaller parcels in more urbanized areas. The DRECP's framers were encouraged to include a distributed generation Alternative in their document, and declined to do so. According to the Description, the framers' reasons for excluding a distributed generation alternative were:
- Unavailability of many California rooftops for solar energy due to building orientation, structural integrity, or other reasons
- The need for distribution system upgrades to integrate small scale power
- An interconnection process historically designed for large, central power plants
- Difficulty for large rooftop projects to secure financing
Based on these (increasingly outdated) objections, the Description concludes that distributed generation alone is therefore insufficient if California is going to meet its Renewable Portfolio Standard goals. Each of the DRECP's Alternatives includes at least 1,700 megawatts of utility-scale power, the Description says, and without that lump of utility-scale generation California won't be able to achieve its renewable goals.
Since 2008, though, the RePowering America's Lands initiative has identified parcels throughout the United States that could generate about 919,600 megawatts of solar power alone. That's the total for the whole country, of course, and California's percentage of that total is hard to extract from the data. But the EPA 's lands identified in California add up to 1,971,798 acres, about a tenth of the national total, and about as much acreage as all but the most expansive DRECP alternative would open up to development. Some of those lands, for instance the acreage on Military bases in the desert, may turn out to be unsuitable for energy development. But even assuming that only a tenth of those lands are appropriate for development, and ignoring California's better solar resources, that would still account for 9,200 megawatts of solar possible on the California lands the EPA identifies -- five times what the DRECP Description says it has to assume would be built in utility-scale solar on lands outside the EPA's database.
In other words, it may be that there's no mention of the EPA project in the DRECP Description because the existence of the EPA's project undermines the DRECP's underlying rationale.
This isn't the first time the DRECP has come under scrutiny for ignoring relevant data. ReWire readers may recall a particularly devastating piece of criticism offered by a panel of independent scientists asked to provide feedback on the plan. As we reported in August, the DRECP's Independent Science Panel's 2012 (ISP 2012) offered a serious slam at the plan's scientific underpinnings:
ISP 2012 is deeply concerned with the scientific quality of DRECP products and processes we reviewed, a lack of adherence to recommendations from ISA 2010, and inadequate answers by plan participants to questions we raised about methods, documentation, and other plan elements. The panel unanimously concluded that DRECP is unlikely to produce a scientifically defensible plan without making immediate and significant course corrections.... ISP 2012 recommends that the DRECP add scientific expertise from outside institutions to help achieve these improvements.
We can only hope the actual DRECP Environmental Impact Statement is better researched than its Description.