NEVADA. Smart Solar Focusing on Low-Conflict Zones to Promote Nevada s Economy, Protect Wildlands, and Build a Clean Energy Future.

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1 Focusing on Low-Conflict Zones to Promote the West s Economy, Protect Wildlands, and Build a Clean Energy Future NEVADA Southern boasts some of the best solar resources in the nation, with great potential for clean energy development in the flat expanses between the state s many mountain ranges. That potential is evident from the seven Solar Energy Zones (SEZs) proposed for in the BLM Solar Programmatic Environmental Impact Statement (PEIS), more than any other state. As detailed here, several of the proposed SEZs need significant refinements, but overall they are very good areas for solar development. The BLM has committed to a zone-based approach to solar development on public lands, and through extensive and ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power millions of homes and businesses across the West while minimizing environmental impacts. These zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in. Increase economic opportunities by generating tax revenue, creating green jobs during project construction and operations and developing a market for associated service industries; Help meet state renewable energy standard has a requirement that 25% of the state s electricity come from renewable energy sources by 2025; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies and communities across America and around the globe. Avoiding Conflicts, Controversy and Costly Delays A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach will simply not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands. For example, in, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: Sage grouse habitat: more than 1 million acres of core breeding habitat; Elk, pronghorn and mule deer migration corridors: more than 1 million acres; and Wilderness quality lands: 140,000 acres. Page 21 Smart Solar Focusing on Low-Conflict Zones to Promote s Economy, Protect Wildlands, and Build a Clean Energy Future Clint Bentley, Director of The Fraternity of the Desert Bighorn, says, With careful planning and coordination I strongly support solar energy development on s public lands. If properly located, solar projects can provide great benefits to our State. However, strong input on development areas from local residents and wildlife experts is critical to minimize damage to wildlife habitat and impacts to animal travel corridors. With this involvement, and a focus on low-conflict areas for development, I look forward to participating in sound planning and implementation of a responsible solar energy program for our public lands.

2 Smart Solar BLM Proposed Solar Energy Zones 1 6 ive r 2 W hit er Esmeralda Nye Lincoln Solar Energy Zone Name BLM Proposed Acreage Gold Point 4,810 Millers Clark 8,968 7 Lake Mead 16,787 Total Acres in r 76,874 East Mormon Mt. ve 15,649 Dry Lake Valley North 95 Ri Dry Lake 6 dy 16,552 ud 31,625 Delamar Valley M Amargosa Valley Las Vegas 171,265 Large Map Area Reno BLM Proposed Solar Energy Zone* Lake Mohave The Wilderness Society s Recommendation: Candidate for Designation Representative Special Status Species Habitat NDOW Greater Sage-Grouse Habitat** Desert Tortoise Critical Habitat*** Data Sources: NREL Solar Energy Potential**** Excellent Very Good Page 22 Virgin Riv 5 Las Vegas * Bureau of Land Management, 2010 ** Department of Wildlife, 2001 *** U.S Fish and Wildlife Service, 2010 **** National Renewable Energy Laboratory, Miles 40 er

3 Focusing on Low-Conflict Zones to Promote the West s Economy, Protect Wildlands, and Build a Clean Energy Future Millers Proposed Solar Energy Zone. Photo Credit: Jon Belak, The Wilderness Society 3 Gold Point Proposed Solar Energy Zone. Photo Credit: Alex Daue, The Wilderness Society 6 Amargosa Valley Proposed Solar Energy Zone. Photo Credit: Jon Belak, The Wilderness Society 2 4 Dry Lake Valley North Proposed Solar Energy Zone. Photo Credit: Jon Belak, The Wilderness Society Delamar Valley Proposed Solar Energy Zone. Photo Credit: Jon Belak, The Wilderness Society 7 5 East Mormon Mt. Proposed Solar Energy Zone. Photo Credit: Rob Mrowka, Center for Biological Diversity Dry Lake Proposed Solar Energy Zone. Photo Credit: Rob Mrowka, Center for Biological Diversity Page 23 1

4 Smart Solar Details on the Proposed SEZs The proposed SEZs in will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs, and protect the environment. The BLM will continue to refine the SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs through the process the BLM will lay out in the upcoming Supplement to the Solar PEIS. These efforts will ensure that the solar energy program for our public lands has room to grow for decades to come. Our key recommendations for needed improvements to the SEZs follow. With these improvements, based on what we know now, the proposed SEZs are good for solar and good for the environment. Good for Solar Great solar potential: all of the SEZs receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; Flat landscape: allows for cost effective construction; and Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces impacts. Good for the Environment No conflicts with protected areas, proposed wilderness, or critical wildlife habitat; Generally dominated by sparse, shrubby plants that are of low value to wildlife; Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change. Even the SEZs best suited for development need to address the natural and cultural resources that exist on-site. These places may be flat but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries as well as on strategies to address potential impacts at the project level. Key recommendations for each of the SEZs follow. We have also made general recommendations to im- prove projects by addressing key potential conflicts and issues wherever they occur, including: Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; Protecting water quality; Minimizing soil erosion and associated damage to vegetation; Minimizing spread of soil diseases and toxins; Safeguarding habitat connectivity and wildlife movement corridors; Avoiding impacts to sensitive species in playa wetlands; Avoiding desert tortoise critical habitat and using best practices for tortoise relocation; Protecting sensitive and important species, such as desert tortoise, pronghorn, desert horned lizard, Greater Sage- Grouse, and rare desert, riparian, and groundwater-dependent plants; and Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure. Amargosa Valley SEZ The proposed Amargosa Valley SEZ is 13 miles northwest of the town of Amargosa Valley in southwestern. The SEZ lies towards the northern end of the Amargosa Valley in Nye and is located along the ephemeral Amargosa River between the Bare and Funeral Mountain Ranges. US Hwy 95 runs along the northeastern edge of the proposed SEZ. Revise the boundary to remove the Amargosa River and 100-year flood channel as well as the associated wash to preserve wildlife, plant habitat and hydrological function, as well as provide flood control; The recommended boundary adjustment would also maintain a desert tortoise/wildlife movement corridor that is key to linking nearby populations; Application of low-water use solar technologies is particularly important for the area of the proposed Amargosa Valley SEZ because of potential impacts of groundwater pumping to the nearby Ash Meadows National Wildlife Refuge and Devil s Hole and the endangered, groundwater-dependent species that live there; Page 24

5 Focusing on Low-Conflict Zones to Promote the West s Economy, Protect Wildlands, and Build a Clean Energy Future Avoid indirect impacts to endemic dune beetle species; these species do not have suitable habitat within the SEZ, but could be affected by changes in sand transport to areas east of the SEZ; and Consider extending the SEZ north in low-conflict lands between the Amargosa River and US Hwy 95. Delamar Valley SEZ The proposed Delamar Valley SEZ is 21 miles southwest of the town of Caliente in Lincoln, southeastern. The SEZ lies between the South Pahroc Range to the west and the Delamar Mountains to the east and southeast. The proposed SEZ is nine miles east of US Hwy 93. Revise the boundary to remove the southern end of the SEZ, from where Jumbo Wash enters the playa and south of there to protect sensitive natural resources in the playa lake; Consider extending the SEZ to the northeast in lowconflict lands; Groundwater flows south through the Delamar Valley and continues into the Pahranagat National Wildlife Refuge, which provides habitat for special status, groundwater-dependent species; groundwater supply to these species must be maintained; and Proximity to existing transmission lines and US Hwy 93 will decrease disturbance and development costs by reducing associated infrastructure needs. The nearby segment of the 500 kv Southwest Intertie Project (SWIP) transmission line now under construction will also provide significant additional transmission capacity when it is complete. Dry Lake SEZ The proposed Dry Lake SEZ is located in southern in the Dry Lake Valley in Clark, and is bounded on the west by the Arrow Canyon Range and on the southeast by the Dry Lake Range. The proposed SEZ is 22 miles northeast of Las Vegas and I-15 and US Hwy 93 run along the southeast and southwest boundaries, respectively. Revise the boundary to exclude the Dry Lake playa, the series of rugged and jumbled washes flowing southwest to northeast into the playa near the SEZ s northern boundary, the heavily developed area in the southeast corner, and the portion southeast of I-15; Consider extending the SEZ to the northeast in lowconflict lands there; and Proximity to a large metropolitan area, existing transmission lines and roads will decrease disturbance and development costs by reducing materials transportation costs and associated infrastructure needs. The nearby segment of the 500 kv SWIP transmission line now under construction will also provide significant additional transmission capacity when it is complete. Dry Lake Valley North SEZ The proposed Dry Lake Valley North SEZ is located in Lincoln in southeastern. The SEZ is located in the Dry Lake Valley and is bounded by numerous mountain ranges on the east and west. The proposed SEZ is 15 miles west of the town of Panaca and is nine miles west of US Hwy 93. Revise the boundary to avoid important wildlife habitat and other sensitive natural resources, including habitat for Desert Valley Kangaroo mouse, desert horned lizard and burrowing owl, as well as Eastwood milkweed; and Proximity to existing transmission lines and roads will decrease disturbance and development costs by reducing associated infrastructure needs. The nearby segment of the 500 kv SWIP transmission line now under construction will provide significant additional transmission capacity when it is complete. East Mormon Mountain SEZ The proposed East Mormon Mountain SEZ is in Lincoln in southeastern and straddles Toquop Wash, just east of East Mormon Mountain. The proposed SEZ is 10 miles north of I-15 and 13 miles northwest of the town of Mesquite. Evaluate impacts of the 2005 fire on desert tortoise critical habitat to assess whether adjacent unburned areas may have increased value and whether burned areas may no longer provide habitat; and Avoid impacts to major washes to maintain surface hydrologic function and protect wildlife habitat. Page 25

6 Smart Solar Gold Point SEZ The proposed Gold Point SEZ is located in Esmeralda in southwestern. The SEZ is in the upper Lida Valley between MacGruder Mountain and Slate Ridge. The proposed SEZ is 21 miles southwest of the town of Goldfield, nine miles west of US Hwy 95 and two miles south of State Hwy 3. Avoid impacts to pronghorn herds in the Lida Valley by using project design that protects pronghorn access to forage and water and scheduling construction outside of dry periods when access is most critical; and New transmission to the SEZ could be run along highways 3, 266 and 95, limiting impacts by co-locating with existing infrastructure rather than routing through undisturbed areas. Millers SEZ The proposed Millers SEZ is located in Esmeralda in western. The SEZ is north of US Hwy 95/US Hwy 6, which runs east west along its southern border. The proposed SEZ is 13 miles northwest of the town of Tonopah. The SEZ is in the southeast end of the Big Smoky Valley, in an area known as Tonopah Flat, and is surrounded by Lone Mountain to the south, the Monte Cristo Range to the west, and the San Antonio Mountains to the east. Avoid important wildlife habitat in sand dunes; Avoid indirect impacts to endemic dune beetle species; these species do not have suitable habitat within the SEZ, but could be affected by changes in sand transport to areas northeast of the SEZ; and Since this site is adjacent to US Hwy 95/US Hwy 6, access to the site would require minimal ground disturbance. The proximity of existing transmission lines also raise the possibility of using existing capacity on those lines or upgrading them instead of building new lines. Page 26