The massive, 6,000-plus-page draft Desert Renewable Energy Conservation Plan started its journey through the public comment period this week with at least one contentious public meeting.
The plan, commonly referred to as the DRECP, would shape both renewable energy development and some conservation across 22 million acres of the California desert in six counties. Criticism of the document is mounting, over its complexity and the relatively short period in which the public will be allowed to comment on the Plan. As we reported earlier this month, the sheer size of the document inevitably excludes most members of the public from having meaningful input into the process.
But a closer look at the DRECP reveals that behind the arcane language and the bureaucratic jargon lies a document that is woefully out of date, planning for development of renewable energy in the California desert as though the last six years never happened.
Over the last two years, we at ReWire have chronicled the steady decline of the utility-scale solar industry, whose power plants once envisioned as covering many thousands of acres in the California desert succumbed to severe competition from ever-cheaper photovoltaic panels. Though large solar power plants are still being designed, approved and built using photovoltaic technology, remote power plants in the desert often need new, expensive, ratepayer-funded transmission lines to pipe those electrons from the desert to the usually coastal cities that seek to consume the energy.
In fact, the last three or four years have seen a devastating shakeout in the utility-scale solar industry, with several favored companies going bankrupt and one former rock star among solar companies -- Oakland-based BrightSource energy -- pulling the plug on one project after another in the last two years.
In the meantime, small local installations on rooftops, above parking lots, and in other urban and suburban settings are burgeoning in California. Getting power from your roof has become so cost-competitive in the state that since 2013, more than half of all rooftop solar projects installed in the state have been brought online without state subsidies.
But you'd never know this reading the Desert Renewable Energy Conservation Plan. The document is written as if none of the massive changes in the solar industry over the last five years ever took place. Instead, a combination of circular logic and bureaucratic inertia has proposed a renewable energy plan for the California desert that is already obsolete.
And in offering this obsolete document for public consumption and discussion, the DRECP's authors are wasting valuable time and energy that could be devoted to taking concrete steps to battle climate change by solarizing our cities and towns.
In order to understand the largest problem with the DRECP's approach we'll need to refresh our memories about a couple features of Environmental Impact Statements, casually referred to as EISs in policy speak, under the federal National Environmental Policy Act, or NEPA. Those features are the legally required description of Project Alternatives, and the project's "Purpose and Need."
In order to assess the environmental impact of a proposal, an EIS must compare and contrast a number of feasible alternative ways of making that proposal happen, describing the different projected impacts of each of those alternatives.
Under the California Environmental Quality Act, or CEQA, the state's version of NEPA, an Environmental Impact Report, or EIR, must also describe a number of Alternatives for each proposed project. (Unlike NEPA, which merely requires that the Alternatives' impact be described, CEQA actually requires that a project proponent choose from among the least-damaging Alternatives.)
Both state and federal law require that one of the Alternatives considered in an EIS or EIR be doing nothing, or conducting business as usual. This so-called "No Action Alternative" usually acts as a baseline against which to gauge the amount of environmental damage a project would do, though in some cases, such as in environmental restoration projects, the No Action Alternative might actually result in greater damage to the environment.
Alternatives in either an EIS or an EIR must be "reasonable" to be included for consideration. Under NEPA, an Alternative can be judged "not reasonable" if it's either technologically infeasible or too expensive, or if it doesn't show "elements of common sense" (to use the wording of the Council on Environmental Quality's "Regulations for Implementing NEPA," which we cited in our last DRECP commentary).
An Alternative can also be judged "unreasonable" if it doesn't meet a project's "Purpose and Need." The "Purpose and Need" of a project is the reason the project is being proposed: It can be anything from providing more effective flood control on a stretch of river to providing local health care to underserved communities to exploring outer space.
What's the DRECP's Purpose and Need? "Complex" would be an easy, glib answer. The section of the DRECP that describes the project's Purpose and Need is 14 pages long, amounting to 5,991 words including footnotes, and covers the differing objectives of five state and federal agencies: the Bureau of Land Management, the U.S. Fish and Wildlife Service, the California Energy Commission, the California Department of Fish and Wildlife, and the California State Lands Commission.
You'd think the Purpose and Need section of a document like the DRECP would focus on our society's need to fight climate change, or else why build all these proposed renewable energy facilities in the desert? But climate change is mentioned only once in the section, in passing and in a different context. The phrase "greenhouse gas" appears once, in a mention of the fact that California has plans to reduce its emissions of same.
Instead, to oversimplify for our purposes, the renewable energy development portion of DRECP's Purpose and Need centers around the BLM's goal of, to lift the description straight from the document,
Promote renewable energy and transmission development, consistent with federal renewable energy and transmission goals and policies, in consideration of state renewable energy targets.
Those "federal renewable energy and transmission goals and targets" include meeting White House goals of building 20,000 megawatts' worth of renewable energy generating facilities on public lands by the year 2020. (For comparison's sake, that'd be about 54 additional solar power plants the size of California's Ivanpah Solar Electric Generating System, or 8,000 single 2.5-megawatt wind turbines.)
The BLM's portion of the DRECP's Purpose and Need also includes this revealing statement:
to identify and prioritize specific locations best suited for large-scale production of solar energy on public lands; encourage the production, development, and delivery of renewable energy as one of [the Department of the Interior's] highest priorities; and work collaboratively with others to encourage the timely and responsible development of renewable energy and associated transmission while protecting the nation's water, wildlife, and other natural resources.
Translated: BLM's objective in promoting the DRECP is to make energy development in the California desert a top priority of the agency in order to help the state of California meet its renewable energy goals.
Meanwhile, state agencies actually up the ante on the Federal government in their Purpose and Need section by increasing the amount of development they want in the desert. The Feds' target of 20,000 megawatts of renewable development on public lands applies to all public lands nationwide; the state of California wants to build that much entirely within the DRECP Plan Area.
The state agencies' Purpose and Need also includes this somewhat disturbingly worded objective:
Reduce the biological and other environmental impacts of future utility-scale renewable energy developments in the Plan Area by designating appropriate areas for renewable energy development within the context of a landscape-scale conservation plan that are sufficient to accommodate the foreseeable demand for renewable energy in the DRECP through 2040.
Why is that disturbing? It's double-talk. If your intent really were to reduce ecological effects of energy development in the desert, your approach would be to designate areas sufficient to maintain the desert's ecological integrity and biological diversity in a warming world, and then talk about putting renewable energy development on the land that remained. Reducing ecological impact by making sure the energy development areas are big enough to meet future demand is a little like saving money by making sure you buy enough tequila for all your friends. The tequila may not be a bad idea on its own, but you really have to choose one or the other.
So we have both state and federal agencies whose point in the DRECP is to make rapid deployment of renewables in the California desert a high priority, apparently for its own sake rather than to fight climate change. That, in a nutshell, is the Purpose and Need of the renewable energy section of the document.
The problem is, as we've written extensively here at ReWire, that big remote renewable energy development in the desert isn't necessarily the most efficient, benign, or economically democratic way of addressing California's pressing need to get off fossil fuels. Look at the UCLA Luskin Center's work over the last few years: This summer they announced that single-family houses within the Los Angeles city limits could be generating about three quarters of the DRECP's target megawattage. Larger roofs could easily make up the rest. And that's just in the city limits. An earlier Luskin Center report found that rooftops throughout Los Angeles County, properly outfitted with solar panels, could meet about half the peak demand of the entire state.
And those rooftop solar panels could all be installed within a fraction of the time it takes to assess, permit, finance, and construct even a modest 250-megawatt solar facility on public lands in the desert. It's the difference between enduring the NEPA process and pulling a local building permit.
If you search the DRECP's entire set of 92 documents making up more than 6,030 pages, the phrase "Luskin Center" appears precisely nowhere. In fact, the entire document is based on the only partly expressed assumption that there is no better, more efficient, more expedient, more economical way of getting the state off fossil fuels than by building utility-scale renewables in the desert.
Back to the discussion of Alternatives.
The DRECP includes six of them, including a No Action Alternative that would basically preserve the status quo in the desert. The Preferred Alternative, which we've described here in the past, would open up 2.2 million acres of so-called "Development Focus Areas" to possible fast-tracked renewable energy development. The other four Alternatives vary in the acreage to be signed over to Development Focus Areas, ranging from just over a million acres at a minimum to almost 2.5 million acres on the high end.
The acreage each alternative would devote to theoretically protected "reserve lands" doesn't vary nearly as much among the Alternatives, with all five other than the No Action Alternative granting some sort of provisional protected status, whose precise nature is yet to be determined, to around 15 million acres.
Nor do any of the formal Alternatives differ much in their overall assumptions. The desert is for developing for renewable energy. The only question is how much and where. The only decision worth making is where to set the threshold between -- on the one hand -- preserving the desert as it is for the benefit of the wildlife that lives there and the people who value it, and -- on the other -- ramping up those megawatts of renewable capacity.
This isn't speculation or interpretation on our part. The Desert Renewable Energy Conservation Plan comes right out and says so.
Along with the six Alternatives included in the draft DRECP, the document lists eight proposed Alternatives its authors decided not to include for consideration in the draft. Two were proposed by the renewable energy industry and would have opened up very large areas to wind and solar development, including most of the Owens Valley and some of the lands slated for protection under Senator Dianne Feinstein's proposed California Desert Protection Act.
One rejected Alternative would have limited energy development to BLM lands only, while another would have kept those Development Focus Areas on privately owned and disturbed lands.
A so-called "Dispersed Lands Alternative" would have opened up more than 4.6 million acres of the desert to development, more than twice as much as in the Preferred Alternative.
The rejected "Avian Avoidance" Alternative would have kept both wind and solar development out of the areas most critical to eagles, condors, and other migratory or ecologically important birds: it was rejected in part, according to the DRECP, because "The Avian Avoidance Alternative... would only partially meet the purpose and need and objectives to streamline renewable energy."
Another alternative would mainly have restricted Development Focus Areas to eastern Imperial and Riverside counties, essentially declaring Imperial east of the Salton Sea and the Riverside East Solar Energy Zone area as sacrifice areas for renewable energy.
But likely the most telling Alternative to be excluded from consideration was the "Distributed Generation Alternative." Distributed Generation, as longtime ReWire readers will recall, essentially uses rooftop or carport solar, combined heat and power, and other currently available technologies to generate power at or near the point where that power is used.
The DRECP pays lip service to the importance of distributed generation. It says that it assumes a certain number of megawatts of power will be generated by rooftop solar and other distributed generation techniques within the DRECP Plan Area, and agrees that rooftop solar and other technologies will be important parts of California's energy future.
But the Distributed Generation Alternative didn't make it into the draft DRECP. Why? That old Purpose and Need which emphasizes renewable energy development over actually fighting climate change.
The Distributed Generation Alternative would not respond to the BLM's purpose and need for agency action in the EIR/EIS because it would not advance the federal orders and mandates that compel the BLM to evaluate renewable energy projects on federally administered lands.
In other words, considering the thought of putting solar on rooftops in cities rather than out in the desert wouldn't meet the BLM's purpose and need of putting renewable energy in the desert.
And then there's this:
Under the Distributed Generation Alternative, the DRECP would not plan for the development of utility-scale renewable energy facilities larger than 20 MW, but instead assume that future greenhouse gas and emission reduction goals will be achieved exclusively through distributed generation. This would not meet the interagency goal because it does not provide a streamlined process for the development of utility-scale renewable energy and does not provide for the long-term conservation and management of Covered Species and other physical, cultural, scenic and social values within the Plan Area.
In other words, changing our focus to generate renewable power in cities wouldn't accomplish our goal of streamlining the renewable power plants we wouldn't be building in the desert, nor would it allow us to protect sensitive wildlife species from the renewable power plants we wouldn't be building.
With this kind of baseless circular logic, the DRECP omits from consideration the one potential Alternative that actually makes sense in light of economic, technological, and social trends over the last decade, and which offers a much more adaptable tool in the fight against climate change -- all due to bureaucratic inertia.
And by doing so, it's artificially limiting the terms of discussion of the future of the California desert to lock in an increasingly obsolete scenario, in which 2.2 million acres of our open desert lands could be converted to industrial facilities that advances in technology make increasingly unnecessary.