The drafters of a plan to regulate renewable energy development on 22 million acres of the California desert got feedback this week from their panel of independent scientists -- and it had to have stung. The Desert Renewable Energy Conservation Plan (DRECP)'s Independent Science Panel, convened to provide "science-based input" to the DRECP, has issued that feedback for 2012, and that feedback is that the plan is not scientifically sound.
Which is a more polite paraphrase of the actual language in the Independent Science Panel's 2012 Recommendations (ISP 2012). From the beginning of the document:
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.
The DRECP, mandated by the same law as California's Renewable Portfolio Standard, is a multi-agency effort to plan renewable energy development on between 1.2 and 2.2 million acres of the desert in Imperial, Inyo, Kern, Los Angeles, Riverside, San Bernardino and San Diego counties. It is being prepared by the "Renewable Energy Action Team (REAT)," a consortium of state and federal agencies including the California Energy Commission, California Department of Fish and Game, the Bureau of Land Management, and the U.S. Fish and Wildlife Service.
The ISP, made up of scientists from state and federal scientific agencies and a range of universities, has provided feedback to the DRECP in the past. Their 2010 recommendations were exhaustive, but can essentially be boiled down to "don't develop renewable energy in places where you'll regret doing so later." The California desert is one of the least-disturbed, biotically intact landscapes left in North America, with unstable geology and crucial wildlife migration linkages: the ISP's 2010 call for a "no regrets" policy advocated a thorough assessment of ecologically important areas in the desert and a resolve to steer development away from those areas.
According to ISP 2012, the REAT has mainly ignored the 2010 recommendations. Among the flaws in the DRECP which ISP 2012 mentions:
- Some of the mapped alternatives for the DRECP would focus industrial development in long-established conservation areas, such as the Desert Tortoise Natural Area
- The plan lumps wildly different habitats with different ecological characteristics (for instance, desert shrublands and coastal chaparral) into the same categories and proposes to manage them identically
- The process for creating the DRECP seems fragmented, with no clear sense of how its various sub-projects will be reconciled
- REAT's planners are using the wrong ecological models to predict species sustainability and abundance, leading to optimistic analyses of development's effects on wildlife
- The plan fails to mention a number of species of concern that will likely be affected by desert renewable energy development
- The document is poorly edited and difficult to decipher, and its poorly designed maps hard to interpret
... and it goes on. Overall, the ISP's criticism runs along the lines of the document being too vague, too disorganized, and too slapdash.
It's a rather devastating criticism, and it remains to be seen how REAT will respond to it or incorporate its criticisms into the final product. If the 2010 ISP recommendations are any guide, that answer may well be "not all that much."
As ReWire's friend Molly Peterson points out on the KPCC website, much of the environmentalist support for desert renewables development was based, at least outwardly, on the assumption that the process would be informed by the best available science.
This month, some of the best available scientists have weighed in to say that hasn't been happening. That may not come as news to those who've been following the news about wildlife impacts from desert renewable energy development, but it's still sobering.