The National Park Service has made its opinion known on a proposed solar power tower project just outside the boundaries of Joshua Tree National Park, and the agency says the project would have "unavoidable and unmitigatable significant adverse impacts" to the park.
The summation by the Park Service came in the form of the agency's comments on the Draft Supplemental environmental Impact Statement (SEIS) on BrightSource Energy and Abengoa Solar's proposed Palen Solar Electric Generating System (PSEGS), which would place 160,000 billboard-sized mirrors surrounding two 750-foot solar power towers about ten miles from the park's eastern boundary.
Foremost among the National Park Service's requests: scrap the power tower design and go back to the drawing board to create a solar power plant with less visual impact than the two power towers, which at 750 feet would tie for sixth place among the tallest structures in California.
The mere presence of the towers, with the requisite safety lightings and navigation beacons, poses concern to the park agency, which holds among its many missions protecting the dark desert night skies over Joshua Tree. In the words of the comment letter:
National Parks include some of the last remaining harbors of natural darkness and provide an excellent opportunity for the public to experience this endangered resource. NPS is dedicated to protecting and sharing this resource for the enjoyment of current and future generations.... [D]ata taken from Pinto Wells in the Pinto Basin of Joshua Tree NP indicates that this area is the darkest measured in the park and is representative of the darkest skies found in the Mojave Desert. Construction and operation of the PSEGS project has a high potential to degrade the natural darkness of the Pinto Basin and the eastern portions of Joshua Tree NP....
During the preparation of the Draft SEIS, according to the document, the NPS provided five viewpoints within and near the park that National Park Service staff felt were of critical importance in gauging the project's effect on Joshua Tree National Park. None of the five are mentioned in the Draft SEIS.
The comments also question assumptions about the scope of the project's visibility that go unmentioned in the Draft SEIS:
The DSEIS assessment was limited to an approximately 30-mile radius. During scoping and public review, assessments conducted by non-government organizations and media outlets indicate that the proposed PSEGS project may be visible from more distant locations, including other national park units such as the Mojave National Preserve. The impact of visibility cannot be adequately assessed without additional analysis to confirm whether or not the project will have a broader impact that what was analyzed in the DSEIS.
ReWire was one of those media outlets that reported on the possible visibility issues.
The National Park Service also commented on a facet of PSEGS and other BrightSource-designed projects that often escapes notice, namely that the plant would use natural gas to pre-heat the plant's boiler fluid in the mornings, and to maintain the fluid's temperature on cold or cloudy days. "The applicant has not clearly defined the amount of natural gas that will be used on any given day or during extended periods of inclement weather," notes the NPS document, pointing out that the project will generate more than 100,000 tons of carbon dioxide per year. The agency suggests that applicants BrightSource and Abengoa -- doing business as Palen Solar Holdings (PSH) -- should be made to follow EPA air pollution rules for large emitters of both CO2 and large particulate matter pollution, a.k.a PM10.
Predictably, the agency also has concerns over PSEGS' likely impact on wildlife ranging from solar flux injuries and collisions to disorientation for migrating birds from the towers' lights. National Park Service staff say that the Draft SEIS omits mention of recent discoveries of eagle nests within ten miles of the PSEGS site, and express concerns that insufficient study might mean that the project will pose far more threat to eagles than the Draft SEIS considers likely. The nearby Lake Tamarisk attracts more than 200 bird species, according to a local checklist, hinting at the region's importance for wildlife.
The comment letter contains a number of pragmatic management suggestions intended to alleviate some of the National Park Service's concerns should the project be approved, but it states in remarkably strong terms that it wants the power tower design jettisoned.
"NPS strongly recommends that BLM consider whether solar power tower technology, as proposed by the applicant, is appropriate for this location. NPS preference would be for BLM to limit development in this location to different technologies that have a lower profile and less potential to negatively impact the resource of Joshua Tree NP, such as a photovoltaic solar system."
That suggestion is not going to make the project proponents happy: BrightSource is only in the business of building solar power towers, and changing the project's design essentially means halting the last project the company has on the drawing board for the California desert. That fact seems not to be lost on the National Park Service, which is supporting the Draft SEIS's "No Action Alternative A" -- which consists of denying the project, refusing to grant a right of way on the 3,896 acres of public land it would occupy, and sending those who'd like to put solar generating capacity on the parcel all the way back to square one.