Compensatory Mitigation SUMMER2015
17
Compensatory Mitigation For Utility-Scale Solar Energy Projects
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Transcript of Compensatory Mitigation SUMMER2015
Compensatory MitigationFor Utility-Scale Solar Energy
Projects
2
STEPS Background on Compensatory Mitigation
alleviate loss that cannot be addressed on-site, by restoring anticipated loss off-site.
acquired, restored, and/or preserved offsite to offset the unavoidable impacts
“in-kind” mitigationAvoid
Minimize
Rectify
Reduce
Compensatory Mitigation
(CEQ, 1979)
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Different Solar Technologies and Impacts
Power towers
Parabolic trough
Solar photovoltaic
Crescent Dunes Solar Energy Project
Ivanpah Solar Electric Generating System
Silver State North
Genesis Solar Power Project
Silver State SouthStatus: Initial Construction
Harry AllenStatus: Approved Comment and Review Period
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The United States 2000-2010
(DOE, 2012)
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Mandatory Growth
National Environmental Policy Act of 1969 (NEPA) Congressional mandates Executive Orders 13212 Executive Orders 13514 DOI Secretarial Order 3285SA1
“take appropriate actions, tothe extent consistent with applicable law, to expedite projects that will increase the production, transmission, or conservation of energy.”
“Encourage … development of renewable energy …while protecting and enhancing the nation’s water, wildlife, and other natural resources; to identify appropriate areas for generation …on public lands to ensure the most environmentally responsible development…”
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BLM SEZ’s
Programmatic Environmental Impact Statement for Solar Energy Development in Six Southwestern States2012
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Methods and Materials The Bureau of Land Management (BLM)
www.blm.gov/wo/st/en.html The California Energy Commission (CEC)
www.energy.ca.gov/ Biological opinion is the document that states the opinion of the Service as to whether or not the Federal action is likely to jeopardize the continued existence of listed species or result in the destruction or adverse modification of critical habitat.
Environmental Impact Statement (EIS), a document that describes the consequences of the proposed project on the environment.
Record of Decision(ROD) document with the final decision on the project specifications, required avoidance and minimization measures, and required compensatory mitigation
Right-of- Way Lease/Grant (ROW) specifies final stipulations on project design, and mitigation requirements.
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How Data Was Kept 30 documents were reviewed for
the 6 projects.
An Excel file was kept with all document titles and webpages that were reviewed.
Which documents contained the accurate information?
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Need for Utility-Scale Solar Development and Data on Compensatory Mitigation Costs
Main goal of solar energy program for utility-scale solar energy development on BLM-administered lands :
– is to create a standardized and streamlined authorization process (BLM and DOE 2012).
“…to ensure consistent application of measures to mitigate the potential adverse impacts of such development.” (BLM and DOE 2012)
“CONSISTENT APPLICATION”
GOAL=
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ResultsProject Total
AcresTotal MW
Total Compensatory Mitigation Costs¹
Approx. Cost Per Acre
Approx. Cost Per MW
Crescent Dunes Nevada 2010
1620 110 $200,000 $123 $1,818
Silver State North Nevada 2010
600 50 $509,400² $849 $10,188
Silver State South Nevada 2014
2427 250 $7,277,600 $2,998 $29,110
Harry AllenNevada 2015
594 112 $2,234,708 $3,762 $19,952
GenesisCalifornia 2010
4640 250 $5,329,106 - $5,352,306 $1,148 - $1,153
$21,316 - $21,409
IvanpahCalifornia 2010
3471 370 $29,547,635 $8,512 $79,858
Average Approx. Cost
$2,898 $27,040
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How do the numbers compare?
Findings suggest: Unrelated to the amount of acres acquired for the project footprint
Harry Allen Solar594 acres
$3,762/acre
$19,952/MW
Only of
Only of
Silver State North600 acres
$10,188/MW
$849/acre 19%
51%
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How do the numbers compare?
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Findings suggest: Compensatory mitigation costs are un-related to the type of solar technology used.
Ivanpah
$8,512/acre
$79,858/MW
Only of
Crescent Dunes
$1,818/MW
$123/acre 1.45%
2.28%
Power Tower in 2010
Only of
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How do the numbers compare?
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The findings from this study suggest that compensatory mitigation costs are inconsistent within states and from state to state. The findings suggest that compensatory mitigation costs are inconsistent no matter if the same animal/ plant species is effected.
Ivanpah
$8,512/acre
$79,858/MW
Only of
Only of
Genesis
$21,409/MW
$1,153/acre 13%
26%
California in 2010
Dessert Tortoise fees $910/acre
300% of land
Only of
Only of 40% of land
$500/acre 55%
13%1750 of 4640
10,413 of 3,471
How do the numbers compare?
This finding from the combined six projects suggests that compensatory mitigation prices go up as the MW output goes up (with exception to Crescent Dunes).
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Ivanpah Solar Electric Generating System370 MW $19,858
Silver State South 250 MW $29,110/MW
Genesis Solar Power Project250 MW $21,409/MW
Harry Allen Solar112 MW $19,952/MW
Crescent Dunes 110 MW $1,818/MW
Silver State North 50 MW $10,188/MW
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Missing data.What’s next? Any real rules set in place for the actual costs of compensatory mitigation? Where do the numbers come from? Many projects were approved in the same year, so why are the variations so
large? Is the government properly managing our land?
More research needs to be done.
The BLM has approved 33 projects since 2010, so there is a chance that some of those facilities can fill in gaps in price.
A standard put in place for compensatory mitigation costs. The research needs to be complete to be sure the compensatory mitigation
process is fair.
Any
?
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References
CEQ (Council on Environmental Quality), 1979. CEQ Regulation 1508-- Terminology and Index. Available at: https://ceq.doe.gov/nepa/regs/ceq/1508.htm
BLM, 2011. Crescent Dunes Final Environmental Impact Statement FES-10-57, N-86292, DOI-BLM-NVB020-2009-0104-EIS, Appendix E: BLM Wildlife Mitigation and Monitoring Plan. BLM Battle Mountain District, Tonanah, Nevada. Available at: http://www.blm.gov/style/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/nepa/crescent_dunes_solar.Par.86958.File.dat/Appendix%20E.pdf.
NFWS (National Fish and Wildlife), 2010. Biological Opinion for the Silver State Solar Project File No. 84320-2010-F-0208,Fish and Wildlife Office, Las Vegas, Nevada. Available at: http://www.blm.gov/style/medialib/blm/nv/field_offices/las_vegas_field_office/energy/nextlight_-_other/NextLight_BO.Par.54027.File.dat/NextLight_Silver_State_Solar_BO%20.pdf
