Conflicts and questions remain three years after California launched an ambitious plan to streamline development of renewable energy on millions of acres of desert land.

The Desert Renewable Energy Conservation Plan, which sprang from a 2009 order from former Gov. Arnold Schwarzenegger, was designed to balance conservation with high-priority renewable-energy development over a 40-year time frame, way beyond the 33-percent RPS. The plan, which will coincide with a state target to reduce greenhouse-gas emissions 80 percent by 2050, aims to lay out conservation goals and determine the best areas in the Mojave and Colorado deserts for renewables. An overarching theme is to smooth project permitting by minimizing conflict between developers and environmentalists and forging cooperation among state agencies from the start.

The plan, expected to be complete early next year, is a collaborative effort of the Renewable Energy Action Team (REAT), which is comprised of representatives from the California Energy Commission, California Department of Fish and Game, U.S. Bureau of Land Management, and U.S. Fish and Wildlife Service.

The entire DRECP area includes 22 million acres in the counties of Imperial, Kern, Los Angeles, Riverside, San Bernardino and San Diego. It takes off the map several million acres that are legally protected -- such as national parks, military installations, tribal lands, and areas that have been proposed for protection in a bill by Sen. Dianne Feinstein (D-Calif.). After that, approximately 1.1 million to 2.3 million acres are left for "development focus areas," or DFAs.

Instead of setting environmental goals, the draft plan simply precludes some areas from development based on assumed conflict, said Nancy Rader, executive director of the California Wind Energy Association. "They are wiping a bunch of areas off the map with a huge brush," she told Energy Prospects West.

A July draft plan listed five DFA scenarios or alternatives: disturbed lands; balanced (transmission aligned, geographically dispersed); West Mojave emphasis; Southeast emphasis; and a flexible scenario that would increase the area of development and include different types of technology. Total acres in DFAs range from 1.1 million in the "disturbed" alternative to 2.3 million under the "flexible" alternative.

Under all five alternatives, approximately 20,000 MW of power would be developed. Large-scale utility solar is the big winner, with approximately 14,000 MW of development in scenarios 1-4 and 8,446 MW in the fifth, "flexible" alternative. Wind development ranges from 971 MW in the "disturbed" alternative to 6,600 MW in the flexible scenario. In all five alternatives, geothermal kicks in approximately 2,800 MW and distributed generation around 1,700 MW.

Rader, however, said that even the 6,600 MW number in the flexible alternative was high for wind, since it captures only 16 percent of high-priority wind-resource areas, those that have wind speeds greater than 6.5 meters/second and are commercially viable.

"They don't have a clue what goes into development," she said, adding that the draft plan "is disastrous for California's clean-energy goals" and that wind is currently the lowest-cost renewable power on the market. "If this thing goes through, you will not see wind be a contender in the long-term renewables market," she said.

Rader said a better approach would have been to determine the biological goals of the plan, such as species protection, "and then you design your zones around that."

The Center for Energy Efficiency and Renewable Technologies, in July 31 comments, said it preferred Alternative 2, the "balanced" approach, which would entail 13,103 MW of solar and 2,000 MW of wind, because it is "both geographically balanced," which is necessary for system reliability, "and aligned with existing and proposed transmission, and there appear to be moderate resource conflicts that can be mitigated."

However, CEERT stated that it believes there needs to be more development in high-quality areas -- such as on BLM land in the West Mojave, which "will have access to transmission and is close to the communities that need the energy." Just because land is clear of conflicts does not mean it is suitable, CEERT stressed. In a phone call, CERRT officials noted that one development area was divided into five-acre parcels, all with different owners.

CEERT recommended including other areas with access to transmission -- such as areas with high commercial interest and insolation, as well as areas where projects are now being developed.

"We are concerned that some of these areas have been put off limits for biological resources reasons based on modeled data rather than on-the-ground surveys and on-the-ground data," CEERT stated.

In July 20 comments, the Sierra Club and the Center for Biological Diversity complained that the amount of land designated for development focus areas is "already unduly high" and "allows for significant flexibility in siting projects to avoid sensitive resources." Also, "the amount of megawatts required from the DRECP area is based on high projections around future demand, and a lack of acknowledgement of the vast amount of potential renewable energy development outside of the DRECP area."

The groups also argued that the draft plan has downplayed the contributions of distributed solar photovoltaics, energy efficiency, demand response and energy storage.

At the same time, the plan lacks clarity on species conservation, said Ileene Anderson with the Center for Biological Diversity. There are only some ideas on conservation based on project-specific mitigations in the past.

The DRECP lead agencies "have not identified the biological goals/objectives for covered species and communities -- key issues in identifying what needs to be saved where," she said.

According to the DRECP website, the plan will cover dozens of different protected plants and animals for which "take" will be authorized. But usually with broad conservation plans such as DRECP, there are specific criteria for why, where and how protected and endangered species are going to conserved -- "that usually drives the process, so permits can be given for projects that basically follow the rules of the conservation plan," Anderson said. With DRECP, "it's looking a lot more like a plain development plan" and it is "unclear what conservation is actually going to occur and how they are going to meet the requirements under the law to conserve the species."

Anderson noted that two of the DFA alternatives include an area of critical environmental concern -- the Desert Tortoise Research Natural Area, which is a private land reserve assembled by the Desert Tortoise Preserve Committee through private donations and mitigation for projects that impacted tortoise habitat. "This makes no sense to me," Anderson said.

The U.S. Fish and Wildlife Service has issued some possible guidelines for golden eagles, which prior to recent legislation could not be given a "take" permit. The guidelines envision establishing project exclusion buffers within certain radii of nesting sites, though Anderson has noted that eagles rarely use the same nest site each year and "floater" eagles, which travel widely, have been killed at California wind farms.

The Renewable Energy Action Team, in a late-July presentation on the DRECP, stated that specific conservation actions along with reserve design -- areas reserved for species protection -- for each alternative are still to come.

"Nowadays, there isn't really enough privately owned 'habitat' out there to be acquired to mitigate the impacts, so other actions are being considered," said Anderson, such as fencing of roads.

"The California Endangered Species Act requires 'full mitigation' of impacts, and it has to date been impossible to evaluate how much these 'other' types of mitigation actually benefit the species," she said.

The REAT presentation also gave rough estimates for "mitigation" contribution -- 200,000 acres to 672,000 acres, depending on the development alternative pursued. REAT stated that "this does not suggest that all impacts are mitigable," nor does it include any mitigation for aerial disturbances, such as those affecting birds, bats, and aircraft.

The presentation also noted that, even in the 1.1 million to 2 million acres of DFAs, conflicts may arise between development, areas of critical environmental concern, and use of land for cattle grazing, herd management and off-road recreation. The Center for Biological Diversity has noted that BLM is proposing three "Special Recreation Management Areas" under the DRECP, but "it is unclear how these areas were identified ... [or] what kinds of activities would be allowed in them," and whether they would conflict with critical environmental areas.

- Chris Raphael

© 2012 Energy NewsData   http://www.energyprospects.com