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Bechtel Signs Contracts with Unions

Ivanpah Valley, California and southern Nevada area -- From the February issue of the local Operating Engineers Union newsletter: Bechtel was awarded the Ivanpah Solar Electric Generating System on the California-Nevada border, in San Bernardino County, California. The first phase 110-MW project is scheduled to begin construction "early this year" (if BrightSource can weave its way through the permit maze and opposition by environmental groups). The second phase is scheduled six months after the start of the first phase. The third phase would complete construction.

According to the Union newsletter: "Business manager William C. Waggoner, Vice President Ron Sikorski and myself [Mickey J. Adams, President] concluded negotiations with with Bechtel's Labor Relations Director Regi Phelps on construction of the project and also on the Assembly Fabricator Agreement -- called the Heliostat Agreement -- which operating engineers, carpenters and electricians will assemble. The total cost of construction and assembly is approximately $2 billion. Bechtel has also signed with the Riverside and San Bernardino Building Trades."

BrightSource Interviewed on FOX Business

March 4, 2010, Bacara Resort and Spa, Santa Barbara, California -- In an interview with Fox Business reporter Brian Sullivan at the Wall Street Journal ECO:nomics conference, John M. Woolard (president and CEO of BrightSource Energy) discussed the Ivanpah Solar Generating System in the Mojave Desert of southeastern California. Mentioning the contract with Bechtel to construct the now three power tower solar thermal plants, the DOE loan guarantee (see below), and some of the technology, Woolard was asked, "But is it going to happen?" He replied, "It's going to happen."

The three power towers would be the largest solar thermal power plants in the world, he stated, all together on one site.

We would like to point out that BrightSource still has an upward climb to resolve numerous environmental impact and mitigation issues, including threats to desert tortoises and rare plants. They also have not made public their plan on how they will secure heliostat foundations to withstand floodwaters that will be allowed to flow through the solar field. The company experienced problems when trying to drive in poles into the bouldery substrate.

The conference convened "top chief executives, policy-makers and thought leaders to assess the urgent risks and new opportunities in markets impacted by the environment."

Mr. Woolard gave a talk on "Renewables in the Recession" along with Gabriel Alonso, CEO of Horizon Wind Energy. Woolard is a lifetime member of the Sierra Club.

Patricia Mulroy, General Manager of Southern Nevada Water Authority, gave a talk called "Water Works". We wonder whether she is scheming water deals for "water battery" proposals that would supposedly store energy produced from wind farms Perhaps BrightSource, too, wants in on Nevada groundwater for their proposed Coyote Springs power tower plant (the failed new city by Harvey Whitemore).

Dr. Steven Chu, Secretary of the U.S. Department of Energy was a featured participant, whose talked was titled "Where Will the Administration Place Its Bets?"

Al Gore, chairman of Alliance for Climate Protection, and T. Boone Pickens, chairman, BP Capital Management were in attendance. James E. Rogers, CEO of Duke Energy, Lewis Hay, III, Chairman and CEO of FPL Group, and Eric Schmidt, CEO of Google, were also there.

Big investor Vinod Khosla, of Khosla Ventures Managing Partners and founding member of Sun Microsystems, told Sullivan that he would not invest in any company that needs long-term subsidies. If it takes 5 to 7 years to get it on its feet, "no problem." But Khosla said he wants a company to be competitive in the real-world market. He does not want an industry propped up by government funds (as much of the solar thermal industry will be, we add).

The sponsors of the conference includes Chevron, Shell Oil Company, FedEx, Intel and Vestas (a wind company).

"ECO:nomics is a highly collaborative event that explores some of the leading ideas linking energy and the environment, and Chevron is delighted to help support this innovative conference," said Russ Yarrow, general manager of California corporate affairs, Chevron (>>here).

See Wall Street Journal Executive Conference - ECO:nomics, Creating Environmental Capital.

$1.37 Billion DOE Loan Guarantee Given for ISEGS

February 22, 2010, Washington D.C. -- Department of Energy Secretary Steven Chu announced conditional commitments for more than $1.37 billion in loan guarantees under the American Recovery and Reinvestment Act to BrightSource Energy, Inc. to support the construction and start-up of the 400 MW Ivanpah Solar Electric Generating System.

“This is an investment in American jobs and the clean, renewable energy our economy needs,” said Secretary Chu. “We’re not going to sit on the sidelines while other countries capture the jobs of the future – we’re committed to becoming the global leader in the clean energy economy,” he said.

BrightSource estimates that the construction of this complex will employ approximately 1,000 people, and its operation will create 86 permanent jobs. BrightSource’s construction contractor has entered into project labor agreements with various trade unions for the construction of the project.

The loan guarantee is conditioned on financial and environmental requirements BrightSource must meet before closing on the loan, including local, state and federal regulatory approvals. The Bureau of Land Management will continue leading a National Environmental Policy Act (NEPA) review with support from the Department of Energy. Today's announcement does not affect that process.

The first plant is expected to begin construction in the second half of 2010 and come on line in 2012. Commercial operation for the second plant is slated for mid-2013 and the third later in 2013. Electricity from the project will be sold under long-term power purchase agreements with Pacific Gas & Electric and Southern California Edison Company (SCE).

The conditional commitments contemplate that the Federal Financing Bank will provide the financing for the project. Before offering a conditional commitment, DOE takes significant steps to ensure risks are properly mitigated for each project prior to approval for closing of a loan guarantee. The Department performs due diligence on all projects, including a thorough investigation and analysis of each project’s financial, technical and legal strengths and weaknesses. In addition to the underwriting and due diligence process, each project is reviewed in consultation with independent consultants.

This is the sixth conditional commitment for a loan guarantee for clean and renewable energy projects entered into by the Department’s Loan Programs Office, which manages the nation's green energy loan portfolio. This conditional commitment is another step toward making the United States a worldwide leader in the manufacture and deployment of green-energy technology. For more information, please visit the Loan Guarantee Program website.

From U.S. Department of Energy News.

The Washington Post observes: "The solar plant is on federally owned land. So, while the Energy Department is seeking to promote the project, the Interior Department's Bureau of Land Management is supposed to be protecting the area."

Basin and Range Watch reader Joe Orawczyk comments: "Once we (taxpayers) provide the 'loan guarantees' to these remote solar developers, they will have effectively externalized their financial risk for their proposed projects. Because if they or their projects go belly up, their investors are protected from paying for the failure by our government underwriting it with our taxes. Hence, financially speaking, it will serve in the best interest of the taxpayer to see the project to fruition, lest we absorb the cost.

"We pay for part of the project with government subsidies called grants, we provide the public land, we sacrifice the water, we pay utilities for new power lines which would not be needed if solar panels were on our roof tops instead of mirrors in some remote site, we pay a higher price for the end product along with increased taxes on it, and with government loan guarantees we get stuck holding the check if the band stops playing. What a sweet deal for these foreign developers and their investors. -- Local PV is the better answer."

Blog Activity

February 11, 2010 - Letter to Bureau of Land Management on the beauty of Ivanpah Valley, on the Desert Blog by Chris Clarke >>here.

February 10, 2020 - Ivanpah Hearings Underscore Brightsource's Poor Site Choice; Reluctance to Fund Mitigation, on the Mojave Desert Blog by Shaun >>here.

BrightSource Changes Design - Reduced

February 11, 2020 - "BrightSource Energy on Thursday plans to submit a new design to regulators that shrinks the size of the 4,000-acre Ivanpah Solar Energy Generating Station by 12 percent, reducing the number of desert tortoises that must be relocated and avoiding an area of rare plants" writes Green Inc. blog (New York Times).

The power plant’s electricity generation would fall from 440 megawatts to 392 megawatts. The Ivanpah 3 power plant in the northern part of the project site would be reduced from a complex 5-tower design down to a one-tower plant.

On urging from California Energy Commission biologists, BrightSource agreed to re-design their solar thermal project because of the high number of rare plants clustered in that part of the valley.

Energy Commission staff consider impacts to five rare plants: Mojave milkweed (Asclepias nyctaginifolia), Desert pincushion (Coryphantha chlorantha), Nine-awned pappus grass (Enneapogon desvauxii), Parish’s club-cholla (Grusonia parishii), and Rusby’s desert-mallow (Sphaeralcea rusbyi var. eremicola) to be significant according to California Environmental Quality Act (CEQA) guidelines because the project would eliminate a substantial portion of their documented occurrences in the state. Other rare plants also occur in the project site: Small-Flowered Androstephium (Androstephium breviflorum), Utah Vine Milkweed (Cynanchum utahense), and Desert portulaca (Portulaca halimoides).

The original plan would have BrightSource biologists try to collect seed from these species as well as try to transplant live plants into an on-site nursery. But the California Native Plant Society considers translocation of wild plants to be risky and usually not effective. Especially rare species that could suffer sever hits by the project, would be fenced off within the heliostat field, in what CEC biologists called "plant corrals," and idea met with much skepticism by both staff and environmental groups.

Botanist Dr. Bruce Pavlik, Professor of Biology at Mills College in Oakland, California (author of the recommended book "The California Deserts: An Ecological Rediscovery") gave a public comment by phone concerning this during the January evidentiary hearing on ISEGS at the California Energy Commission in Sacramento.

He said transplanting rare plants is a great challenge in the desert, from his experience. At the huge open-pit Viceroy Mine in the Castle Mountains (an inholding within Mojave National Preserve), results of extensive salvage and translocation efforts were poor.

BrightSource did good survey work at the site, he noted, but he had concerns with the mitigation. The science of plant conservation and restoration relies on trying to conserve populations, not individuals. A population is defined by seeds in the soil seedbank, lying dormant waiting for the right weather conditions. Surveys will only uncover the existing above-ground population, not the total population. He also mentioned that the surveys for ISEGS were done in two years of below-average rainfall.

Putting up fences around plants is not conserving the population, he urged. "This would be a bad precedent."

After a big rain event, the annual six-awned pappus grass "miraculously" arose out of the ground, where it had not been noted in these numbers previously. But perennial plants can also do this. Pavlik explained that populations exist in some places that we do not know -- we should not define the population by existing plants. Milkweeds are known to have long dispersal distances.

Genetic diversity should be a main concern for plant species. This is key to maintaining resilience in response to climate change, and a lot of genetic diversity could reside in the seedbank. Populations are not static, he concluded, and open habitat should be maintained to allow populations to respond to environmental fluctuations.

Because of these concerns, BrightSource tried to reduce the impact to rare plants which are densest in the northern area, by moving out of these places. But this does not take into account the seedbank.

As for tortoises, they are more evenly distributed across the entire site, and they move all over. This re-design does nothing to truly conserve this threatened population in Ivanpah Valley. A large chunk of habitat for tortoises will still be removed and degraded, fragmenting the basin.

From our own notes at the hearing, and the New York Times >>here.

BLM Open House in Needles

January 21, 2010 - The Bureau of Land Management (BLM) announces an open house to facilitate
understanding of the proposed Ivanpah Solar Electric Generation Project on public lands in San
Bernardino County, California. The open house will be held Thursday, Feb. 4, 2010, from 2 to 4 p.m.
at the BLM Needles Field Office, 1303 South Highway 95, in Needles, Calif. Copies of the Draft
Environmental Impact Statement (DEIS) and California Energy Commission (CEC) Final Staff
Assessment (FSA) for the project will be available for inspection and staff will be available to
answer questions. An opportunity will be provided at the open house to submit written comments.
The official comment period for the DEIS/FSA ends on February 11, 2010.

Evidentiary Hearings in Sacramento

January 11-14, 2010 - Basin and Range Watch members participated in four long days of hearings before the California Energy Commission in the state capitol, California. Six to seven weeks after the close of the hearings, the commissioners will issue their Presiding Member’s Proposed Decision on whether to certify ISEGS, for a 30-day comment period. We will have many stories concerning these hearings at a later date. See the transcript of the first day on this page >>here.

Final Staff Assessment/Draft Environmental Impact Statement Out!

November 4, 2009 -

Ivanpah Solar Electric Generating System is the first utility-scale solar energy project in line to be permitted in California on public land during the current push for renewables. It is the precedent-setter.

The Bureau of Land Management (BLM) and Energy Commission staff announced the release of their roughly 1,200-page Final Staff Assessment (FSA), that combines Bureau of Land Management's Draft Environmental Impact Statement (DEIS). The enormous document may be downloaded at: http://www.energy.ca.gov/2008publications/CEC-700-2008-013/FSA/

BLM still must release its Final EIS. While this accelerates the review process, we have yet to see how BLM will handle its side of the decision to permit the Ivanpah Solar Electric Generating System on public land.

Two Different Comment Periods

1. The California Energy Commission encourages public participation in the review of the
ISEGS Application for Certification and the FSA/DEIS. Written comments on the FSA/DEIS which a member of the public or interested party would like to have entered into the record before the Energy Commission’s Evidentiary Hearing, should be provided to John Kessler, Energy Commission Project Manager, no later than 5:00 p.m., December 7, 2009 at this address:

John Kessler
Project Manager
Siting, Transmission and Environmental Protection Division
California Energy Commission
1516 Ninth Street, MS-15
Sacramento, CA 95814
Phone: 916-654-4679

or by email to jkessler@energy.state.ca.us.

It is crucial that comments be entered into the record.

2. BLM will also be conducting a 90-day comment period in association with BLM’s EIS process, which will be noticed separately. Following completion of BLM’s comment period scheduled to end February 11, 2010, Energy Commission staff and BLM will prepare a Final Environmental Impact Statement (FEIS). The FEIS will respond to public comments and will incorporate any changes deemed necessary to update the analysis of project impacts. Address comments on this Bureau of Land Management EIS to both of the following: Needles Field Office, Attention: George R. Meckfessel, Planning and Environmental Coordinator, 1303 South U.S. Highway 95, Needles, CA 92363. Or email: CA690@ca.blm.gov

(From http://www.energy.ca.gov/sitingcases/ivanpah/notices/2009-11-04_Notice_of_Availability_of_FSA_DEIS_TN-53970.pdf)

This has a "record-breaking" fast deadline. Prehearing conferences will occur in Sacramento on November 18, 2009 and December 10, 2009. The evidentiary hearing would take place on December 15, 2009. Apparently fast-tracking means compressing the timeline of release of the FSA/DEIS and hearings into an unreasonably short space.

We will be reviewing this document and posting our comments shortly.

San Bernardino County Against Ivanpah Project

County Supervisor Brad Mitzelfelt say the massive solar energy project that would cover 4,000 acres should be built elsewhere to protect pristine desert habitat that is home to several endangered species. Mitzelfelt's chief concern, said spokesman Andy Silva, is that the project would monopolize too much desert tortoise habitat. When a project affects desert tortoise habitat other land has to be set aside for tortoises. That means either buying private land or putting more restrictions - such as banning off-roading - on existing public land. If the project were built elsewhere - not in a tortoise habitat - the Ivanpah Valley land could be set aside to make up for land lost to other projects, explained the county.

"When you chew up this much ... land, it makes it that much harder for the next project," Silva said.

In a statement, Mitzelfelt said the project would use San Bernardino County resources but likely wouldn't provide jobs or power for the county.

"This project would create jobs for mostly Las Vegas and electricity for mostly San Francisco at the expense of Southern California's Mojave Desert," Mitzelfelt said.

"It's habitat for a lot of critters," added Eldon Hughes of the San Gorgonio Chapter of the Sierra Club. "There are better places to put solar energy."

Story in the San Bernardino Sun >>here.

Distributed Generation Eliminated as an Alternative

November 14, 2009 -

See the Final Staff Assessment text by the California Energy Commission and where to send comments >>here.

Draft Environmental Impact Statement Due Out, but Tortoise an Obstacle

October 3, 2009

The California Energy Commission (CEC) and Bureau of Land Management (BLM) announced on September 24 that they had completed the Administrative Draft of the Final Staff Assessment (the CEC's review) and Draft Environmental Impact Statement (the BLM's parallel review) of BrightSource's proposal to place a giant solar thermal energy complex on 4,000 acres of BLM land adjacent to Mojave National Preserve, in Ivanpah Valley. The FSA/DEIS would circulate for about three weeks for approval from Washington BLM and Sacramento CEC offices before its public release.

A sticking issue, however, was the Desert tortoise, a federally threatened reptile inhabiting the fan where the utility-scale solar power tower would be built. "Significant outstanding information" regarding mitigation for the tortoise was described by the CEC in a memorandum (60 mb pdf file >>here), especially "analyses and permit requirements" from the California Department of Fish and Game.

Therefore, CEC decided to bypass Fish and Game and develop its own "desert tortoise mitigation measures" in accordance with the California Environmental Quality Act. "Staff considers the mitigation approach described in the Administrative Draft to be adequate to satisfy state and federal requirements for mitigating impacts to desert tortoise," the CEC proclaimed. We are not so sure.

^Ivanpah Valley tortoise.

Tortoise Relocation Plan

August 12, 2009

A Draft Desert Tortoise Translocation/Relocation Plan was developed by BrightSource in summer 2009, to move all tortoises from the project site onto approximately 4,065 acres of adjacent Bureau of Land Management (BLM) land - a 1:1 land mitigation scheme. The California Department of Fish and Game (CDFG) commented that no information was provided that describes the density of resident desert tortoise at the proposed relocation/translocation sites. In response BrightSource sent out a subcontractor, Southern Nevada Environmental, Inc., to conduct surveys of the scattered translocation areas in Ivanpah Valley (giving no dates or times in their results >>here, a 27 page, 4.2 mb pdf). They claimed to have completed "100 percent coverage surveys" for desert tortoise, interpreting their data to indicate that density of desert tortoise in the area is low and that "translocation into sites N1 through N4 would not overburden the existing population."

We doubt that an accurate idea of tortoise population density can be obtained except by undertaking more detailed and intensive survey methods, such as line-distance sampling, during spring when tortoise are above-ground more.

<Desert tortoise found by contract biologists for BrightSource on their proposed N2 translocation site in Ivanpah Valley. (Source: http://www.energy.ca.gov/sitingcases/ivanpah/documents/applicant/2009-08-13_Supplemental_Data_Response_Set_2J_TN-52847.pdf)

The proposed Ivanpah Solar Electric Generating System would lie within the Northeastern Recovery Unit for the desert tortoise, one of six units designated in the 1994 Desert Tortoise (Mojave Population) Recovery Plan. Studies done indicate these populations have distinct genetic, morphological, ecological, behavioral characters, making them distinct "Evolutionary Significant Units" (US Fish and Wildlife Service, 1994, Desert Tortoise [Mojave Population] Recovery Plan. US Fish and Wildlife Service, Portland, Oregon, 73 pp plus appendices).

CDFG has not yet issued BrightSource an Incidental Take Permit, under the California Endangered Species Act, requiring the "take" (an allowable death of a certain number of tortoises) to be minimized and fully mitigated.

Unfortunately, land managers had earlier left the Ivanpah project site out of critical habitat designation for the Federal and State Threatened desert tortoise, even though density was historically high. BLM had designated portions of Ivanpah Valley as Category 1 desert tortoise habitat in their Northern and Eastern Mojave Desert Management Plan (NEMO), but the northern part of Ivanpah Valley was excluded for some reason.

Environmental groups had many comments. Western Watersheds Project and the Sierra Club recommended that the California Energy Commission ensure that the Clark Mountain cattle grazing allotment be retired, and that the existing Desert Wildlife Management Areas (DWMA) boundary be expanded or the area made into an Area of Critical Environmental Concern (ACEC).

Basin and Range Watch supports the stand of having no renewable energy projects in Ivanpah Valley desert habitat.

^August 2009 version of the tortoise translocation area map in Ivanpah Valley. Dashed rectangles along Interstate 15, and to the west of the project are the proposed tortoise translocation areas. California Department of Fish and Game, as of October 4, 2009, has not signed off on the plan yet. (Source: http://www.energy.ca.gov/sitingcases/ivanpah/documents/applicant/2009-08 13_Supplemental_Data_Response_Set_2J_TN-52847.pdf)

^Summer sunset in Ivanpah Valley, looking west toward Clark Mountain in Mojave National Preserve.

Spring Nights at Ivanpah

June 6, 2009

We visited the site of the proposed Ivanpah Solar Electric Generating System in late spring on the night of a full Moon. Life was abundant here as showers passed through days before. On Yates Well Road in the broad creosote flats in the lower basin, 20 to 30 Lesser nighthawks flew about in the dusk light after insects. Some sat on the small road, flying up as we came by. A single Poorwill also flew up from the desert floor.

Black-tailed jackrabbits (Lepus californicus) dashed about in the evening darkness as stars came out.

As if to show the incredible diversity of life here, a Spotted leaf-nosed snake (Phyllorhynchus decurtatus) was out basking in the residual heat of the little crumbling roadway that will be BrightSource's main entrance road to their project.

^Spotted leaf-nosed snake in Ivanpah Valley.

<We took a close look at the snake's enlarged rostral scale which the snake used to burrow into the sandy, gravelly creosote plains that it lives on. They often hunt geckoes.

>We put the snake back on the ground and hoped its habitat would not succumb to the perils of poorly planned renewable energy developments.

^Night at Ivanpah Valley, with the Clark Mountain Range in the background and Stateline Wilderness. The glow of Las Vegas is to the far right.

^June full Moon at Ivanpah.

Major Changes to Plan

April 16, 2009

From: California Energy Commission - April 15, 2009

Perhaps realizing the massive amount of landscape degradation that would take place to construct this large-scale solar thermal energy plant in the Mojave Desert, BrightSource of Oakland, California, has changed its plans for grading and drainage at the Ivanpah Valley site in San Bernardino County.

The former plan of development submitted to the California Energy Commission (CEC) and Bureau of Land Management (BLM), which manages Ivanpah Valley, would have required grading almost 4,000 acres of pristine desert to place heliostats: mirrors on posts reflecting sunlight towards central "power towers" that heat fluids to generate steam at adjacent steam engine power plants. The desert would have been scraped bare in a huge swath. (See >>here)

But this neat industrial scheme must deal with some complications: flash floods coming off Clark Mountain, the Federally protected Desert tortoise, and dense vegetation -- all the cacti, yuccas, creosote, wildflowers, and other plants that store carbon and help buffer the effects of Global Warming. Ploughing all this up would release stored carbon in the vegetation and soil microfauna and flora. This is rather a paradox since renewable energy projects like that at Ivanpah are supposed to help reduce carbon emissions into the atmosphere.

So the planners are rethinking some of their macro-manipulation of the landscape.

The California Energy Commission memo says: "The complexity of this large project on a sloping alluvial fan below a mountain range has required several rounds of BLM/Energy Commission
data requests and interaction with the applicant. The grading and drainage plans currently under development are necessary to define the physical layout of the project and the extent of ground disturbance with respect to site grading and drainage features. These plans will enable BLM and Energy Commission staff to assess project impacts and to identify impact avoidance and mitigation measures. Similarly, development of a comprehensive Biological Resources mitigation plan for protecting wildlife and rare plants is critical to BLM and Energy Commission staff’s preparation of the Final Staff Assessment/Draft Environmental Impact Statement (FSA/DEIS). The information developed under the grading and drainage plans is pivotal to the applicant’s ability to progress to preparation of subsequent plans and permit applications, many of which can be developed
concurrently."

"Because the draft plan primarily listed options for rehabilitating the site after project closure, and did not address what the applicant actually proposed in a manner sufficient to protect and restore soil and vegetation resources, it needs to be revised ..."

BrightSource filed its draft Desert Tortoise Translocation and Relocation Plan on March 19, 2009. Staff representatives of BLM, US Fish and Wildlife Service, California Department of Fish and Game, and the Energy Commission "are currently preparing comments to the draft plan and expect to provide comments to the applicant in late April."

We eagerly await the release of the new plan, as it appears that BrightSource is trying to leave desert shrubs and other vegetation more intact. Are they proposing to place the heliostat mirrors among the cacti, creosote, and yuccas? The new plan also seems to seek to build around the numerous washes that flow through the project area down the fan, instead of building berms and drainage channels to alter the flash floodwater flow away from the large mirror areas.

The memo says: "The applicant has developed an alternate approach to its grading and drainage plans differing from those submitted previously, by applying low-impact development principles for its revised plans. The approach seeks to minimize grading and disturbance to existing vegetation, and to have stormwater move through the site according to its natural drainage patterns within the ephemeral washes. The applicant plans to design the pylons supporting the heliostats so as to resist damage from stormwater flows by driving them deeper underground. This is intended to ensure that changes in the course and depth of the washes over time will not significantly affect the integrity of the heliostats. The use of this revised low-impact development plan eliminates previously contemplated drainage control structures and allows applicant to fill in additional space with heliostats, increasing the total number from approximately 240,000 previously to 280,000 as currently proposed."

The Sacramento energy folks and BLM seem somewhat skeptical.

The memo says: "The applicant is also exploring equipment and site access options that would be used during construction that minimize site disturbance. While staff is encouraged by the revised site preparation approach overall, it is necessary for staff to evaluate and for the applicant to demonstrate that multiple assumptions in the low impact design are reasonably achievable. These include assumptions that vegetation changes will not significantly alter stormwater runoff, and that the heliostat field construction can be accomplished without significantly removing or damaging vegetation."

The Energy Commission and BLM are also asking BrightSource to do a groundwater study to evaluate the potential for migration of brackish groundwater westward towards the existing and proposed project wells due to pumping by the Ivanpah project for its water needs.

Other problems have come up with how to mitigate Desert tortoise habitat destruction, and how land for translocated tortoises would be found and preserved. BLM and California Department of Fish and Game have differing criteria "for biological resources mitigation so that habitat
compensation lands for desert tortoise can meet the requirements of both agencies..."

See the memo update >>here.

<Catclaw acacias in winter.

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