Regional Mitigation Strategy for the Dry Lake Solar Energy Zone - Technical Note 444
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Regional Mitigation Strategy for the Dry Lake Solar Energy Zone Technical Note 444 Produced by: Bureau of Land Management March 2014
Suggested citation: Bureau of Land Management. 2014. Solar Regional Mitigation Strategy for the Dry Lake Solar Energy Zone. Tech Note 444. Bureau of Land Management, Southern Nevada District Office, Las Vegas, NV. Production services provided by: Bureau of Land Management National Operations Center Information and Publishing Services Section P.O. Box 25047 Denver, CO 80225 BLM/OC/ST-14/002+1794
Regional Mitigation Strategy for the Dry Lake Solar Energy Zone Produced by: Bureau of Land Management March 2014
ACKNOWLEDGMENTS T his technical note is the product of a collaborative effort. Many people representing many National Laboratory project support team: Heidi Hartmann (Lead), Laura Fox, David Murphy, Karen Smith, Shannon Stewart, Members of the Information and Publishing Services Section at the BLM National Operations Center assisted by providing editorial and different entities had a hand in its Konstance Wescott, and Lee design and layout services. Many development. The project occurred Walston. Special thanks also go to others contributed by attending under the leadership of Ray Brady, John McCarty (BLM Washington or helping conduct one or more of Bureau of Land Management Office), Rochelle Francisco the workshops conducted to obtain (BLM) Washington Office. The final (BLM Nevada State Office), Fred input from interested parties, by content was approved by the BLM Edwards, Mark Slaughter, Kathleen providing comments on draft Regional Mitigation Project Team: Sprowl, Boris Poff, and the other versions of this document, and by Joe Vieira (Lead), Michael Dwyer, members of the BLM Southern providing management oversight Wendy Seley, and Gordon Toevs. Nevada District, Pahrump Field and/or technical support. Thanks to Special thanks go to the Argonne Office Interdisciplinary Team. all who contributed! ii • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
TABLE OF CONTENTS ABSTRACT____________________________________________________________________________________ 1 1. INTRODUCTION AND PURPOSE_______________________________________________________________ 2 1.1 Purpose of the Strategy_______________________________________________________________________ 2 1.2 Background______________________________________________________________________________ 3 1.3 Solar Regional Mitigation Strategy Process___________________________________________________________ 4 1.4 Stakeholder Involvement in the Solar Regional Mitigation Strategy Process________________________________________ 5 2. MITIGATION STRATEGY – DRY LAKE SOLAR ENERGY ZONE__________________________________________ 6 2.1 Description of the Dry Lake Solar Energy Zone and Surrounding Region__________________________________________ 6 2.1.1 General Description of the Solar Energy Zone______________________________________________________ 6 2.1.2 Landscape Conditions of the Solar Energy Zone and the Region___________________________________________ 6 2.1.3 Regional Setting_______________________________________________________________________ 8 2.1.3.1 General Description________________________________________________________________ 8 2.1.3.2 Problematic Regional Trends___________________________________________________________ 8 2.2 General Description of Solar Development in the Dry Lake Solar Energy Zone______________________________________ 18 2.2.1 Description of Existing Rights-of-Way and Impact on Developable Area_____________________________________ 18 2.2.2 Description of Potential Development_________________________________________________________ 18 2.3 Summary of Solar Development Impacts on the Dry Lake Solar Energy Zone______________________________________ 19 2.4 Mitigation Strategy (Hierarchy) of the Dry Lake Solar Energy Zone_____________________________________________ 20 2.4.1 Avoidance__________________________________________________________________________ 20 2.4.1.1 Dry Wash/Riparian Areas____________________________________________________________ 20 2.4.1.2 Existing Rights-of-Way, Mining Claims, etc._________________________________________________ 20 2.4.2 Minimization________________________________________________________________________ 21 2.4.2.1 Summary of Programmatic Design Features to be Applied________________________________________ 21 2.4.2.2 Other Required Impact Minimization Measures and/or Stipulations___________________________________ 21 2.4.3 Regional Mitigation____________________________________________________________________ 21 2.4.3.1 Identification of Unavoidable Impacts____________________________________________________ 22 2.4.3.2 Unavoidable Impacts that May Warrant Regional Mitigation_______________________________________ 23 2.4.3.2.1 Conceptual Models__________________________________________________________ 23 2.4.3.2.2 Unavoidable Impacts that May Warrant Regional Mitigation_________________________________ 23 2.5 Regional Mitigation Goals____________________________________________________________________ 24 2.5.1 Background on Regional Goals______________________________________________________________ 24 2.5.2 Las Vegas Resource Management Plan Goals and Objectives____________________________________________ 24 2.5.3 Dry Lake Solar Energy Zone Mitigation Goals and Objectives____________________________________________ 25 2.6 Calculating the Recommended Mitigation Fee for the Dry Lake Solar Energy Zone___________________________________ 26 2.7 Management of Solar Regional Mitigation Fees________________________________________________________ 28 2.8 Evaluation of Mitigation Locations, Objectives, and Actions_________________________________________________ 29 2.9 Mitigation Effectiveness Monitoring and Adaptive Management Plan__________________________________________ 35 2.10 Implementation Strategy_____________________________________________________________________ 43 REFERENCES_________________________________________________________________________________ 45 APPENDIX A: Impact Assessment Summary Table___________________________________________________________ 46 APPENDIX B: Regional and Dry Lake Solar Energy Zone Conceptual Models____________________________________________ 51 APPENDIX C: Summary Table: Impacts that May Warrant Regional Mitigation for the Dry Lake Solar Energy Zone_____________________ 54 APPENDIX D: BLM Screening of Candidate Regional Mitigation Sites for the Dry Lake Solar Energy Zone__________________________ 57 APPENDIX E: Mitigation of Visual Resource Impacts in the Dry Lake Solar Energy Zone_____________________________________ 63 REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • iii
Figures 2-1 Dry Lake Solar Energy Zone and surrounding area______________________________________________ 7 2-2 Landscape condition in the Mojave Basin and Range ecoregion___________________________________ 9 2-3 Landscape condition in the Dry Lake Solar Energy Zone_________________________________________ 10 2-4 Dry Lake Solar Energy Zone and surrounding land designations__________________________________ 11 2-5 Land cover types in the Mojave Basin and Range ecoregion______________________________________ 12 2-6 Land cover types in the vicinity of the Dry Lake Solar Energy Zone________________________________ 13 2-7 Conceptual diagram for estimating condition and trends of conservation elements in the Mojave Basin and Range ecoregion for the Dry Lake Solar Energy Zone Solar Regional Mitigation Strategy_____________________________ 15 2-8 Dry Lake Solar Energy Zone revised developable area___________________________________________ 20 2-9 Steps for calculating per-acre regional mitigation fees__________________________________________ 26 2-10 Gold Butte Area of Critical Environmental Concern_____________________________________________ 31 2-11 Example of a stratified, nonbiased sampling schema for the Dry Lake Solar Energy Zone______________ 40 2-12 Example of a stratified, nonbiased sampling schema for the Gold Butte Area of Critical Environmental Concern___________________________________________________________ 41 Tables 2-1 Ecological stressor source, site-impact scores, and distance decay scores implemented for the landscape condition model for the Mojave Basin and Range________________________________ 8 2-2 Land cover types and amounts in the vicinity of the Dry Lake Solar Energy Zone_____________________ 14 2-3 Condition and trends assessment for coarse and fine filter conservation elements in the Mojave Basin and Range relevant to the Dry Lake Solar Energy Zone_________________________ 16 2-4 Estimate of funding needed for management activities to ensure effectiveness and durability__________ 27 2-5 Dry Lake Solar Energy Zone goals and objectives associated with mitigation in the Gold Butte Area of Critical Environmental Concern________________________________________ 32 2-6 Priority/order of Gold Butte Area of Critical Environmental Concern mitigation goals and objectives____________________________________________________________ 34 2-7 Recommended methods and measurements for core and contingent indicators.____________________ 37 2-8 Quantitative indicators and measurements relevant to each of the three rangeland health attributes______________________________________________________ 38 iv • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
ABSTRACT T he “Regional Mitigation Strategy for the Dry Lake Solar Energy Zone” presents a strategy for Impact Statement (PEIS) for Solar Energy Development in Six Southwestern States.” The strategy consists of preliminary mitigation fee could be calculated; and (4) how the impacts and mitigation actions could be monitored. While this pilot strategy compensating for the unavoidable findings and recommendations for the Dry Lake SEZ is not a Bureau impacts that are expected from for conducting each element of of Land Management decision, the development of the Dry Lake a process that identifies: (1) the it will inform future decision Solar Energy Zone (SEZ) in southern unavoidable impacts of utility- documents for: configuration of Nevada. This strategy responds to scale solar development in the lease parcels within the Dry Lake a call for the development of solar Dry Lake SEZ that may warrant SEZ; lease stipulations; impacts to regional mitigation strategies for regional mitigation; (2) mitigation be mitigated in the region; where each of the SEZs, as committed to actions that can be implemented and how regional mitigation will in the record of decision for the in the region to compensate for occur; and how monitoring and “Final Programmatic Environmental those impacts; (3) how a regional adaptive management will occur. REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 1
1. INTRODUCTION AND PURPOSE 1.1 Purpose of the Strategy T he “Regional Mitigation Strategy for the Dry Lake Solar Energy Zone” recommends a strategy between resources, ecosystem functions, ecosystem services, and change agents (including development, climate change, what will happen if the actions are not achieving the desired results. for compensating for certain wildfire, etc.). This pilot strategy will guide unavoidable impacts that are future decisions for: expected from the development 4. The unavoidable impacts that, of the Dry Lake Solar Energy Zone in consideration of regional • The configuration of lease (SEZ) in southern Nevada. The trends and roles the impacted parcels within the Dry Lake SEZ. Bureau of Land Management (BLM) resources play, may warrant • The lease stipulations to achieve is required to manage the public regional mitigation. avoidance and minimization of lands in a manner that will protect impacts. the quality of ecological and 5. The regional mitigation goals • The impacts to be mitigated in environmental values and provide and objectives recommended the immediate region. for wildlife habitat in a way that for the Dry Lake SEZ. • Where and how regional does not result in the permanent mitigation will occur. impairment of the productivity of 6. The regional mitigation • Monitoring and adaptive the land. While the BLM places a locations and action(s) management. priority on mitigating impacts to recommended for achieving the • Developing BLM policy to guide an acceptable level onsite, there mitigation goals and objectives regional mitigation. are times when onsite mitigation for the Dry Lake SEZ. alone may not be sufficient. In these The BLM authorized officer cases, which are likely to occur with 7. The estimated cost of the will make these decisions prior utility-scale solar development, mitigation action(s), including to leasing and will also take into which often involves a long-term a breakout of acquisition, consideration: commitment of resources over restoration, and/or ongoing a relatively large area, the BLM management costs to ensure • The National Environmental is considering requirements for effectiveness and durability. Policy Act (NEPA) analysis regional mitigation for those done for the proposed action, unavoidable impacts that could 8. A recommended method for including comments submitted exacerbate problematic regional calculating a mitigation fee that by the public and other trends. Accordingly, this pilot could be assessed to developers stakeholders. strategy articulates: and an explanation of how it • Any changes to the applicable was calculated for the Dry Lake resource management plan 1. The unavoidable impacts SEZ. (RMP) or other plans that affect expected as a result of management of the SEZ or development of the Dry Lake 9. A recommendation for how the possible mitigation sites. SEZ. BLM fee revenue derived from • The input received from 2. The problematic trends in the development of the Dry Lake consultation with tribes. Mojave Desert, where the Dry SEZ could be managed. • Any other information that Lake SEZ is located. would update, correct, or 10. A recommendation for how otherwise supplement the 3. A conceptual model that the outcomes of the mitigation information contained in this depicts the relationships actions could be monitored and strategy. 2 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
1.2 Background I n 2012, the BLM and the U.S. Department of Energy published the “Final Programmatic Environmental publication of the Supplement to the Draft Solar PEIS and the Final Solar PEIS to foster stakeholder engagement. A framework for to avoid as many conflicts as possible. Avoidance is also used within the boundaries of SEZs by designating nondevelopable Impact Statement (PEIS) for regional mitigation planning was areas. Minimization involves the Solar Energy Development in Six included in the Final Solar PEIS and implementation of design features Southwestern States” (Final Solar the Solar PEIS ROD. Concurrent with (which are required mitigation PEIS). The Final Solar PEIS assessed the development of this strategy, measures) and management the impact of utility-scale solar the BLM has developed a technical practices meant to reduce the energy development on public reference, titled “Procedural impacts onsite. As a part of the lands in the six southwestern Guidance for Developing Solar analysis, the Final Solar PEIS states of Arizona, California, Regional Mitigation Strategies,” to included a robust suite of design Colorado, Nevada, New Mexico, provide guidance on the process features in the BLM’s solar energy and Utah. The “Approved Resource and a refined framework to aid in program that will be employed to Management Plan Amendments/ the preparation of solar regional minimize some of the expected Record of Decision (ROD) for mitigation strategies (SRMSs) for impacts of development onsite. Solar Energy Development other SEZs (BLM forthcoming). The Final Solar PEIS analyzed, in Six Southwestern States” The BLM’s policy is to mitigate and the Solar PEIS ROD adopted, (Solar PEIS ROD) implemented impacts to an acceptable level both programmatic and SEZ- a comprehensive solar energy onsite whenever possible specific design features. These program for public lands in those through avoidance, minimization, design features will be included as states and incorporated land use remediation, or reduction of stipulations in right-of-way leases allocations and programmatic impacts over time. The use of for SEZs. and SEZ-specific design features regional mitigation is evaluated This SRMS addresses the final into land use plans in the six-state by the BLM on a case-by-case tier of the mitigation hierarchy, study area (BLM 2012). The Solar basis and is based on the need specifically compensatory PEIS ROD identified 17 priority to address resource issues that mitigation, hereafter referred areas for utility-scale solar energy cannot be acceptably mitigated to as regional mitigation. development, or SEZs. The Final onsite. Furthermore, not all This pilot strategy consists of Solar PEIS presents a detailed adverse impacts can or must be recommendations to mitigate analysis of the expected impacts of fully mitigated either onsite or in some of the unavoidable impacts solar development on each SEZ. the immediate region. A certain that remain after avoidance Comments on both the Draft level of adverse or unavoidable and minimization measures are Solar PEIS and the Supplement to impact may be acceptable: (1) taken. This strategy differs from the Draft Solar PEIS encouraged when an appropriate level of project-level compensatory the BLM to incorporate a mitigation will be conducted and mitigation planning that has been robust mitigation framework remaining impacts do not result in conducted in the past. In this into the proposed solar energy unnecessary or undue degradation; pilot, compensatory mitigation is program to address unavoidable or (2) when impacts to BLM considered in a landscape context impacts expected in SEZs. In the sensitive species or Endangered and includes identification of Supplement to the Draft Solar PEIS, Species Act-listed species do not mitigation goals and objectives, as the BLM presented, as part of its exceed established resource and well as the selection of mitigation incentives for SEZs, the concept value objectives. actions based on the degree of of regional mitigation planning1. In order to minimize the impact and regional conditions A draft framework for regional impacts of solar development, and trends. This procedure for mitigation planning was posted on the BLM applies a mitigation conducting mitigation is also the project web page between the hierarchy, consisting of avoid, reflected in the BLM’s interim 1 minimize, and compensate. policy, Draft Manual Section 1794, In the Final Solar Energy PEIS (BLM and DOE 2012), Appendix A, Section A.2.5, the BLM refers to solar regional mitigation plans Implementation of this hierarchy “Regional Mitigation,” issued on (SRMPs). To be consistent with guidance issued in BLM Instruction begins with the location and June 13, 2013. Memorandum 2013-142 (BLM 2013b), the BLM adopts the termi- configuration of the SEZs, so as nology of solar regional mitigation strategies (SRMSs). REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 3
1.3 Solar Regional Mitigation Strategy Process I n August 2012, the BLM initiated the pilot Dry Lake SEZ Solar Regional Mitigation Planning Project, comments was also extended to the public. The content and methods used in this process incorporate many of the ideas and comments of Critical Environmental Concern (ACEC), but for which sufficient resources have been unavailable. The Gold Butte ACEC is in the same which constitutes the first SRMS received from the public. ecological zone (ecoregion) and developed for an SEZ. The Dry The mitigation actions subzone as the Dry Lake SEZ and is Lake SEZ SRMS originated identified in this strategy are of the same vegetation community. simultaneously with, and served designed to compensate for The Gold Butte ACEC provides as a pilot test case for, the the loss of some of the habitat, habitat for all of the wildlife, establishment of BLM guidance visual resources, and ecological including the special status species, for developing SRMSs for other services that are expected from found in the Dry Lake SEZ. SEZs (BLM forthcoming). The effort the development of the Dry Under the terms of this strategy, was conducted with a significant Lake SEZ. For the purpose of this funding derived from mitigation amount of public involvement, analysis, it is assumed that all of fees for the Dry Lake SEZ will not including four workshops, the developable land within the be sufficient to fund all of the several web-based meetings, and Dry Lake SEZ will be impacted. The potential restoration and protection opportunities to comment on degree of compensation will take needs in the Gold Butte ACEC, but preliminary and draft versions of into consideration the condition they will allow significant progress methodologies and strategies. of the resource values present in toward achieving the management The Dry Lake SEZ is located the Dry Lake SEZ and also consider objectives for the ACEC: to preserve about 15 mi (24 km) northeast of the relative costs and benefits of the extraordinary resource values Las Vegas in Nevada. The process the use of public lands for solar found there while providing for for developing the Dry Lake SEZ energy development, including the human use and enjoyment. As SRMS largely followed the outline amount of time and effort required part of the proposed solar energy for regional mitigation planning to restore the disturbed area program, the solar long-term outlined in the Final Solar PEIS. In upon expiration of the lease. The monitoring program will be used general, a team of specialists from recommended mitigation actions to evaluate the effectiveness of the BLM Southern Nevada District are drawn from the “Proposed Las mitigation strategies employed Office, with the support of Argonne Vegas Resource Management Plan through regional mitigation plans. National Laboratory, produced a and Final Environmental Impact Regional mitigation strategies will preliminary product at each step Statement” (Las Vegas RMP) (BLM be subject to continued review in the process, which was then 1998). They consist of restoration and adjustment by the BLM and presented and discussed in a public and preservation measures its partners to ensure conservation forum. The opportunity for written prescribed for the Gold Butte Area goals and objectives are being met. 4 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
1.4 Stakeholder Involvement in the Solar Regional Mitigation Strategy Process T he pilot process for including stakeholder input in developing the Dry Lake SEZ SRMS included October 24-25, 2012. This workshop included a field visit to the Dry Lake SEZ in order to give the participants a firsthand look at the SEZ. BLM (December 6, 2012); methods to identify impacts that may warrant mitigation (January 1, 2013); and a proposed mitigation fee four workshops in Las Vegas and staff experts were present and setting method and method to several web-based meetings. spoke about the range of resources evaluate candidate mitigation sites Representatives from federal, state, present in the SEZ and possible (March 21, 2013). and local government agencies; opportunities available to avoid, All presentations from the four nongovernmental organizations minimize, and mitigate potential workshops and three webinars are concerned with issues such as impacts related to solar energy posted on the project documents environmental or recreational development. web page on the Dry Lake SEZ impacts; representatives from The third workshop was SRMS Project website at: http:// the solar development industry, held January 30-31, 2013. This www.blm.gov/nv/st/en/fo/lvfo/ mining industry, and utilities; tribal workshop focused on regional blm_programs/energy/dry_lake_ representatives; and individual trends and conditions, unavoidable solar_energy.html. Reports from members of the public who had impacts that may warrant regional the workshops are also available. been involved in the Solar PEIS mitigation, the establishment of Additional materials that were process were invited to attend regional mitigation objectives, the provided for stakeholder review these activities. Approximately 70 use of mapping tools and data in are posted on the project website individuals and representatives choosing locations for mitigation, documents page as well. from the previously mentioned prioritization of mitigation projects, Throughout the pilot project, organizations attended the kickoff mitigation costing, and long-term stakeholders were invited to workshop held August 29-30, monitoring. comment on interim draft 2012. During the first workshop, The fourth workshop, held materials, including the summary background on regional mitigation on February 27, 2013, focused of unavoidable impacts at the planning and the Solar PEIS impact on three topics: (1) methods for Dry Lake SEZ that may warrant assessment for the Dry Lake SEZ establishing mitigation fees in SEZs, mitigation, the proposed method were provided to the attendees. and specifically in the Dry Lake SEZ; for deriving the mitigation fees, the The subsequent three workshops all (2) establishing solar mitigation method of evaluating candidate had about 35 attendees, including objectives and priority setting; sites for mitigation, and the specific individuals and representatives and (3) structures for holding and mitigation sites and activities from agencies, nongovernmental applying mitigation funds. proposed for the Dry Lake SEZ. organizations, the solar industry Additionally, several webinars Many of these comments were and consultants to the industry, were held to provide information discussed during workshops and utilities, and tribes. on: mitigation valuation methods used to guide development of this The second workshop was held and mitigation structure options strategy. REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 5
2. MITIGATION STRATEGY – DRY LAKE SOLAR ENERGY ZONE 2.1 Description of the Dry Lake Solar Energy Zone and Surrounding Region 2.1.1 General Description facilities. Three designated transmission corridors pass spatial datasets in a meaningful timeframe. The REAs serve multiple of the Solar Energy Zone through the area, including a purposes in an ecoregional Section 368 energy corridor (of context, including identifying and The Dry Lake SEZ is located in the Energy Policy Act of 2005), answering important management Clark County in southern Nevada. which contains numerous electric questions; understanding key The total area of the Dry Lake SEZ, transmission lines, natural gas and resource values; understanding as shown in Figure 2-1, is 6,187 refined petroleum product lines, the influence of various change acres (25 km2) (BLM and DOE 2012). and water lines (see Figure 2-1 for agents; understanding projected In the Final Solar PEIS and the Solar the designated corridor). A power ecological trends; identifying and PEIS ROD, 469 acres (1.9 km2) of generating station is also located mapping key opportunities for floodplain and wetland within the within the area of the SEZ, and two resource conservation, restoration, SEZ boundaries were identified existing natural gas power plants and development; and providing as nondevelopment areas. The are located just southwest of the a baseline to evaluate and guide developable area of the SEZ SEZ on private land. A minerals future actions. given in the Final Solar PEIS was processing plant is located in the One useful product of the 5,717 acres (23 km2). southeastern corner of the SEZ. REAs is the development of The towns of Moapa and The Final Solar PEIS indicated that landscape condition models. Overton are located 18 mi (29 km) in 2012 there were three pending These geospatial models have northeast and 23 mi (37 km) east solar applications within or adjacent been created to represent the of the SEZ, respectively. Nellis Air to the SEZ and an additional large condition or level of intactness Force Base is located approximately application area located about 2 mi throughout the ecoregion at the 13 mi (21 km) southwest of the SEZ. (3 km) to the east of the SEZ across time in which the assessments were The nearest major roads accessing Interstate 15. initiated (approximately 2010). the proposed Dry Lake SEZ are The landscape condition model Interstate 15, which passes along is a combination of two primary the southeastern boundary of the 2.1.2 Landscape factors—land use and a distance SEZ, and U.S. Route 93, which runs Conditions of the decay function from land uses. from north to south along part of Different land use categories were the southwest border of the SEZ. Solar Energy Zone assigned a relative value between 0 and 1, representing very high The Union Pacific Railroad runs north to south along a portion of and the Region landscape alteration to very little the eastern SEZ boundary, with landscape alteration. For example, In 2012, the BLM completed the nearest stop in Las Vegas. The high-density urban areas received the “Mojave Basin and Range Rapid area around the SEZ is not highly values closer to 0, whereas intact Ecoregional Assessment” for the populated, although Clark County, undisturbed areas received values Mojave Basin and Range ecoregion with a 2008 population close to closer to 1. The distance decay in which the Dry Lake SEZ is located 2 million individuals, has a large function considered the proximity (NatureServe 2013). The Mojave number of residents. of each location to human land Basin and Range REA examines The SEZ already contains uses. Table 2-1 lists a number of broad-scale ecological values, rights-of-way and developed examples of land use and distance conditions, and trends within the areas, including energy, water, decay scores for various stressor ecoregion by synthesizing existing and transportation infrastructure categories in the Mojave Basin and 6 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
Range. A full description of the The model illustrates landscape to this landscape condition model, landscape condition model and condition values throughout the most of the impacts occur near how it was developed can be found ecoregion (Figure 2-2). The resulting urban areas (e.g., Las Vegas) and in the “Mojave Basin and Range map provides a composite view of along roadways. However, most Rapid Ecoregional Assessments the relative impacts of land uses of the Mojave Basin and Range is Final Memorandum I-3-C.” across the entire ecoregion. Darker still relatively intact. The landscape The landscape condition green areas indicate apparently condition within the Dry Lake SEZ is model developed for the Mojave least impacted areas (most intact) shown in Figure 2-3. Basin and Range was developed and orange-red areas are the most as a raster dataset of 100-m cells. impacted (least intact). According Figure 2-1. Dry Lake Solar Energy Zone and surrounding area (Source: BLM and DOE 2012). REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 7
2.1.3 Regional Setting Mixed Salt Desert Scrub (0.8% of the developable area), and North the nondevelopable area of the SEZ include Developed, Medium – High American Warm Desert Wash (0.4% Intensity and North American Warm 2.1.3.1 General Description of the developable area). Other land Desert Pavement (Table 2-2). cover types expected to occur in The Dry Lake SEZ is situated within 5 mi (8 km) of several other Table 2-1. Ecological stressor source, site-impact scores, and distance decay scores implemented for federally owned or administered the landscape condition model for the Mojave Basin and Range. lands. The Moapa River Indian Reservation is approximately 4 mi Site Presumed Distance Impact (6.4 km) northeast of the revised Ecological Stressor Source Impact Relative Decay Approaches SEZ boundary. The Coyote Springs Score Stress Score Negligible ACEC, which is also designated critical habitat for the federally Transportation threatened desert tortoise, is Dirt roads, 4-wheel drive 0.7 Low 0.5 200 m located within 0.5 mi (0.8 km) west Local, neighborhood and connecting roads 0.5 Medium 0.5 200 m of the SEZ. Farther west of the Coyote Springs ACEC is the U.S. Secondary and connecting roads 0.2 High 0.2 500 m Fish and Wildlife Service Desert Primary highways with limited access 0.05 Very High 0.1 1,000 m National Wildlife Refuge, which is Primary highways without limited access 0.05 Very High 0.05 2,000 m approximately 3 mi (4.8 km) west of the SEZ. The Muddy Mountains Urban and Industrial Development Wilderness Area is approximately Low-density development 0.6 Medium 0.5 200 m 8 mi (12.9 km) southeast of the SEZ Medium-density development 0.5 Medium 0.5 200 m (Figure 2-4). The Dry Lake SEZ is located Powerline/transmission lines 0.5 Medium 0.9 100 m in a relatively undeveloped rural Oil/gas wells 0.5 Medium 0.2 500 m area, bounded on the west by the Arrow Canyon Range and on the High-density development 0.05 Very High 0.05 2,000 m southeast by the Dry Lake Range. Mines 0.05 Very High 0.2 500 m The topography of the land within Managed and Modified Land Cover the SEZ is arid basin dominated by creosote and white bursage Ruderal forest and upland 0.9 Very Low 1 0m vegetation communities. Land Native vegetation with introduced species 0.9 Very Low 1 0m cover types2 within the ecoregion Pasture 0.9 Very Low 0.9 100 m are presented in Figure 2-5. At a more local scale, land cover types in Recently logged 0.9 Very Low 0.5 200 m the vicinity of the Dry Lake SEZ are Managed tree plantations 0.8 Low 0.5 200 m shown in Figure 2-6. In total, there Introduced tree and shrub 0.5 Medium 0.5 200 m are 10 natural land cover types and 2 disturbance land cover types Introduced upland grass and forb 0.5 Medium 0.5 200 m predicted to occur in the vicinity Introduced wetland 0.3 High 0.8 125 m (i.e., within 5 mi, or 8 km) of the Dry Lake SEZ (Table 2-2). There are Cultivated agriculture 0.3 High 0.5 200 m three land cover types that occur in the developable portion of the SEZ (Table 2-2). Listed in order of 2.1.3.2 Problematic Regional Trends Range REA defines conservation dominance, these land cover types elements as resources of are: Sonora-Mojave Creosote-White The Mojave Basin and Range conservation concern within an Bursage Desert Scrub (98.8% of the REA presents a framework for ecoregion. These elements could developable area), Sonora-Mojave determining the condition and include habitat or populations 2 trend of various resource values for plant and animal taxa, such Geospatial data for land cover types were obtained from the Southwest Regional Gap Analysis Project (http://earth.gis.usu.edu/ and conservation elements in the as threatened and endangered swgap/) and the California Gap land cover mapping project (http:// ecoregion. The Mojave Basin and species, or ecological systems and gap.uidaho.edu/index.php/california-land-cover/). 8 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
plant communities of regional types of conservation elements in functions and services in the importance. A list of conservation the Mojave Basin and Range: ecoregion. elements could also include other resource values, such as highly • Coarse filter conservation • Fine filter conservation elements, erodible soils; populations of elements, which typically include which complement the first wild horses and burros; scenic all of the major ecosystem types set of elements by including a viewsheds; or designated sites within the assessment landscape limited subset of focal species of natural, historical, or cultural and represent all of the assemblages and individual significance. There are two basic predominant natural ecosystem species. Figure 2-2. Landscape condition in the Mojave Basin and Range ecoregion. Darker green areas indicate least impacted areas (most intact), whereas orange-red areas are the most impacted (least intact). Also shown is the 5-mile buffer around the Dry Lake Solar Energy Zone. REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 9
Figure 2-3. Landscape condition in the Dry Lake Solar Energy Zone. Approximately 3,471 acres of the solar energy zone are considered eligible for utility-scale solar energy development. 10 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
Figure 2-4. Dry Lake Solar Energy Zone and surrounding land designations. REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 11
Figure 2-5. Land cover types in the Mojave Basin and Range ecoregion. 12 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
Figure 2-6. Land cover types in the vicinity of the Dry Lake Solar Energy Zone. REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 13
Table 2-2. Land cover types and amounts in the vicinity of the Dry Lake Solar Energy Zone. are the easiest to predict in a meaningful timeframe for SRMSs Acres Within Entire SEZ Acres Within because solar energy development Acres Within SEZ Description (Developable and 5-Mile Buffer Developable Area1 Nondevelopable)2 Around SEZ3 represents an anthropogenic disturbance, and the impacts of Natural Land Cover Types human development are likely to Sonora-Mojave Creosotebush-White affect all conservation elements 3,427 (98.8%) 5,879 (95.0%) 83,300 (84.1%) Bursage Desert Scrub similarly. Understanding the problematic Sonora-Mojave Mixed Salt Desert Scrub 30 (0.8%) 38 (0.6%) 645 (0.7%) conservation element trends relevant to the Dry Lake SEZ North American Warm Desert Wash 14 (0.4%) 141 (2.3%) 2,618 (2.6%) was accomplished through (1) a geospatial analysis of North American Warm Desert available ecoregional data and 21 (0.3%) 1,694 (1.7%) Pavement (2) expert opinion by the BLM North American Warm Desert Bedrock interdisciplinary team. Figure 2-7 5,144 (5.2%) Cliff and Outcrop presents a conceptual illustration of the geospatial framework for Mojave Mid-Elevation Mixed Desert Scrub 4,651 (4.7%) determining the condition and trends of conservation elements North American Warm Desert Playa 287 (0.3%) in the ecoregion. The geospatial data used in this assessment are Inter-Mountain Basins Semi-Desert 147 (0.1%) available publicly from open Shrub Steppe sources. These data include the BLM’s landscape condition model Open Water 1 (
Geospatial Data 1. Landscape Condition Model1 2. Habitat Suitablity Models2 3. Land Cover Types3 Characterize Distribution: 1. In the ecoregion 2. Within vicinity of the SEZ (5-mi buffer) CONDITION 3. Within SEZ developable area Geospatial Overlay Analysis4: TRENDS/ 1. Current Development Footprint5 2. 2025 Development Footprint6 FORECAST 1 The landscape condition model is available from and described in the BLM Mojave Basin and Range Rapid Ecoregional Assessment. 2 Habitat suitability models are available from the Southwest Regional Gap Analysis Project. 3 Land cover types are available from the Southwest Regional Gap Analysis Project. 4 The overlay change agent/conservation element analysis was conducted to determine geospatial trends. Geospatial data for the change agent were overlayed with the distribution of conservation elements to determine current and future distributions of the conservation elements. 5 Geospatial data for the current human development footprint model are available from and described in the BLM Mojave Basin and Range Rapid Ecoregional Assessment. 6 Geospatial data for the future (approximately 2025) human development footprint model are available from and described in the BLM Mojave Basin and Range Rapid Ecoregional Assessment. Figure 2-7. Conceptual diagram for estimating condition and trends of conservation elements in the Mojave Basin and Range ecoregion for the Dry Lake Solar Energy Zone Solar Regional Mitigation Strategy. human development footprints3 for geospatial trends of fine scale expected to experience a declining and forecast trends. Trends are conservation elements (individual trend in the Mojave Basin and understood by using the current species). In Table 2-3, coarse filter Range, as all conservation elements and future human development conservation elements evaluated are expected to experience some footprints to evaluate the include the Mojave Basin and level of range contraction due to expected future distribution of the Range landscape condition model human development in the future. conservation element relative to its and the Southwest Regional Gap Landscape condition within the current distribution. Analysis Project modeled land cover Mojave Basin and Range is also An example table showing the types. expected to decline in the future. condition and trends of various The only fine filter conservation Because the Sonora-Mojave coarse and fine filter conservation element presented in Table 2-3 Creosotebush-White Bursage elements in the Mojave Basin and is the Mojave population of the Desert Scrub comprised the largest Range is shown in Table 2-3. Due desert tortoise (Gopherus agassizii), portion of the Dry Lake SEZ (98.8%), to the large number of fine scale which is listed in the table due the cumulative expected future conservation elements that could to its threatened status under loss of this conservation element potentially be evaluated, the BLM the Endangered Species Act and of 10.26% was considered to be determined that a trends analysis of known presence in potentially a problematic trend among all coarse filter land cover types would suitable habitat on the Dry Lake conservation elements relative to be a suitable habitat-based proxy SEZ. Based on the results presented the Dry Lake SEZ. 3 in Table 2-3, it was concluded that Geospatial data for current and future human development footprints are described in more detail in the Mojave Basin and all conservation elements are Range REA (NatureServe 2013). REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 15
Table 2-3. Condition and trends assessment for coarse and fine filter conservation elements in the Mojave Basin and Range relevant to the Dry Lake Solar Energy Zone. Solar Energy Zone (SEZ) Condition in the Landscape-Ecoregional Site-Specific Condition Vicinity of SEZ Ecoregional Trendsa Condition (SEZ Developable Area) (Local-Regional Status) Coarse Filter Conservation Element: Land Cover Types Percent Percent Percent Percent Potential Potential Current Future Within 5 Percent Current Future Potential Within SEZ Distribu- Distribu- Conversion Conversion mi Area Total Conversion Conversion Distribu- Relative to tion (Acres) tion (Acres) to Human to Human Description Relative to Distribu- Relative to Relative to tion (Acres) Distribu- Within 5 Within Devel- Devel- Distribu- tion Within Distribu- Distribu- Within SEZ tion in mi of SEZ Mojave opment opment tion in Ecoregion tion in tion in Ecoregion Boundary Ecoregion (Acres) (Acres) Ecoregion Ecoregion Ecoregion Natural Land Cover Types Sonora-Mojave Creosotebush-White 3,428 0.02% 83,300 0.59% 14,085,230 34.73% 1,229,275 8.73% 1,444,510 10.26% Bursage Desert Scrub North American Warm 14
Table 2-3 (continued). Solar Energy Zone (SEZ) Condition in the Vicinity Landscape-Ecoregional Site-Specific Condition of SEZ (Local-Regional Ecoregional Trendsa Condition (SEZ Developable Area) Status) Coarse Filter Conservation Element: Landscape Condition Model Average Current Average Future Condition Average Ecoregional Average Current Condition Average Current Condition Condition Value Within Value Within Mojave Difference in Current and Value Within 5 mi of SEZ Value Within the SEZ (SD*) Mojave Basin and Range Basin and Range Future Condition Boundary (SD*) Ecoregion (SD*) Ecoregion (SD*) Values (%) Landscape Condition 57.4 (5.0) 66.0 (9.4) 76.6 (13.8) 72.3 (17.3) -4.3 (5.6%) Value Fine Filter Conservation Element: Mojave Desert Tortoise Distribution Potential Distribution Potential Distribution Future Conversion to Potential Distribution (Acres) Within 5 mi of SEZ (Acres) Within Mojave Human Development Percent Future Conversion (Acres) Within SEZ Boundary Ecoregion (Acres) Mojave Desert Tortoise Potentially 3,471 92,168 16,772,653 1,059,811 6.3% Suitable Habitat Model (SWReGAP) *SD = standard deviation REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 17
2.2 General Description of Solar Development in the Dry Lake Solar Energy Zone 2.2.1 Description of element in common—they all have a large solar field with reflectors or Availability of transmission from SEZs to load centers is an Existing Rights-of- photovoltaic surfaces designed to important consideration for capture the sun’s energy. The solar future development in SEZs. Way and Impact on fields generally require a relatively For the proposed Dry Lake SEZ, Developable Area flat land surface; only locations with several existing transmission lines, less than 5% slope were included including a 500-kilovolt line, run As stated in Section 2.1, the Dry as SEZs in the Final Solar PEIS. As through the SEZ. It is possible that Lake SEZ contains many previously constructed to date, vegetation is an existing line could be used to developed areas, including a generally cleared and solar fields provide access from the SEZ to natural gas power plant (the Harry are fenced to prevent damage to or the transmission grid, but since Allen Generating Station), pipelines, from wildlife and trespassers. existing lines may already be at a gypsum mining processing In the Final Solar PEIS, full capacity, it is possible that plant, several known mining maximum solar development of the at full build-out capacity, new claims, and three designated Dry Lake SEZ was assumed to be transmission and/or upgrades of transmission corridors and rights- 80% of the developable SEZ area existing transmission lines may be of-way (including a 500-kilovolt over a period of 20 years. Although required to bring electricity from transmission line) (Figure 2-4). the developable area has been the proposed Dry Lake SEZ to load Subsequent to the signing refined to 3,471 acres (14 km2) (see centers. An assessment of the most of the Solar PEIS ROD, BLM Section 2.2.1), for the purposes of likely load center destinations for Southern Nevada District Office this assessment, it is assumed that power generated at the Dry Lake staff revised the developable and more nondevelopment areas will SEZ and a general assessment nondevelopable portions of the be identified in the future and that of the impacts of constructing SEZ to take into account current only approximately 3,000 acres and operating new transmission existing land uses on the SEZ. (12 km2) will be developed (see facilities on those load centers was Known locations of rights-of-way, Section 2.5). In the Final Solar PEIS, provided in Section 11.3.23 of the pipelines, and existing leases data from various existing solar Final Solar PEIS. Project-specific and mining claims, including facilities were used to estimate analyses would also be required to the natural gas power plant and that solar trough facilities will identify the specific impacts of new gypsum processing plant, have require about 5 acres/megawatt transmission construction and line been identified as nondevelopment (0.02 km2/megawatt), and other upgrades for any projects proposed areas within the SEZ. Although types of solar facilities (e.g., within the SEZ. the total SEZ size is the same as power tower, dish engine, and Since Interstate 15 and that reported in the Final Solar photovoltaic technologies) will U.S. Route 93 are adjacent to the PEIS (6,187 acres, or 25 km2), the require about 9 acres/megawatt SEZ, existing road access should be developable area of the SEZ has (0.04 km2/megawatt). Using these adequate to support construction been reduced from 5,717 acres land requirement assumptions, full and operation of solar facilities. (23 km2) to 3,471 acres (14 km2) development of the Dry Lake SEZ, It is likely that no additional road (Figure 2-8). assuming the revised developable construction outside of the SEZ area, would allow development of would be needed. solar facilities with an estimated 2.2.2 Description of total of between 386 megawatts (for power tower, dish engine, or Potential Development photovoltaic technologies) and 694 megawatts (for solar trough Utility-scale solar facilities of technologies) of electrical power all technology types have a key capacity. 18 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
2.3 Summary of Solar Development Impacts on the Dry Lake Solar Energy Zone A comprehensive assessment of the potential impacts of solar development at the Dry Lake SEZ was provided of the SEZ lands, military use of the SEZ lands, soils, water resources, vegetation, wildlife, special status species (both vegetation Some potential positive impacts of development were identified for local socioeconomics, as well as positive impacts in terms of in the Final Solar PEIS (BLM and and wildlife), air quality, visual potential to reduce greenhouse gas DOE 2012). Potential adverse resources, paleontological and emissions if solar energy produced impacts included effects on nearby cultural resources, Native American at the SEZ would displace use of wilderness areas, recreational use concerns, and transportation. fossil fuels. REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 19
2.4 Mitigation Strategy (Hierarchy) of the Dry Lake Solar Energy Zone 2.4.1 Avoidance 2.4.1.2 Existing Rights-of-Way, areas within the SEZ. The remaining developable area of the SEZ has Mining Claims, etc. been reduced to 3,471 acres 2.4.1.1 Dry Wash/Riparian Areas (14 km2) (Figure 2-8). This reduction As stated in Section 2.2.1, the in developable area of the SEZ In the Final Solar PEIS and BLM has revised the developable also will reduce potential impacts the Solar PEIS ROD, 469 acres and nondevelopable portions identified in the Final Solar PEIS (1.9 km2) of floodplain and wetland of the SEZ to take into account (e.g., far fewer acres of habitat within the SEZ boundaries were current existing land uses on the reduction will occur for vegetation identified as nondevelopment SEZ. Known locations of rights- and wildlife species, including areas. Avoidance of these areas will of-way, pipelines, and existing special status species). In addition, eliminate or largely reduce adverse leases and mining claims, including an eligible archaeological site impacts to them. the natural gas power plant and (i.e., Old Spanish Trail/Mormon gypsum processing plant, have Road) within a right-of-way will be been identified as nondevelopment avoided. Figure 2-8. Dry Lake Solar Energy Zone revised developable area. 20 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
2.4.2 Minimization identifying potential mitigation strategies for avoiding or Historic Places, onsite mitigation or avoidance strategies will be minimizing potential impacts on considered during consultation 2.4.2.1 Summary of Programmatic the congressionally designated with the BLM-Nevada state historic Design Features to be Applied Old Spanish National Historic Trail preservation officer and affected and also on any remnants of the tribes to minimize impacts on The Final Solar PEIS identified National Register of Historic Places- significant cultural resources. a comprehensive suite of required listed sites associated with the programmatic design features Old Spanish Trail/Mormon Road that would avoid and/or minimize that may be located within the 2.4.3 Regional Mitigation adverse impacts to resources, either SEZ. Avoidance of the Old Spanish onsite or through consultation/ Trail site within the southeastern Identifying the impacts of coordination with potentially portion of the proposed SEZ is utility-scale solar development affected entities. The programmatic recommended. that may warrant regional design features are extensive Native American concerns: mitigation involves three steps: and are listed in their entirety in The Moapa Band of Paiute Indians (1) identifying all the potential Appendix A of the Solar PEIS ROD have specifically requested formal impacts; (2) identifying which (BLM 2012). These programmatic government-to-government of the potential impacts are design features include required contact when construction or likely to be unavoidable (i.e., the actions to avoid or minimize land management projects are impacts that cannot be mitigated impacts to all of the potentially being proposed on and/or near onsite by avoidance and/or the impacted resources listed in the Muddy River, Virgin River, implementation of design features Section 2.3. Colorado River, Arrow Canyon meant to minimize the impact); Range, Potato Woman, and Apex and (3) identifying which of the Pleistocene Lake. Compensatory unavoidable impacts may warrant 2.4.2.2 Other Required Impact programs of mitigation could be regional mitigation by taking into Minimization Measures and/or implemented to provide access consideration the condition and Stipulations to and/or deliberately cultivate trend of the impacted resources patches of culturally significant in the region and how they could The Final Solar PEIS also plants within the Dry Lake SEZ be affected by the unavoidable includes SEZ-specific design or on other public lands nearby impacts. features for all of the SEZs. The SEZ- where tribes have ready access. As part of the Dry Lake SRMS specific design features identified The BLM should consider assisting process, a team of specialists from for the Dry Lake SEZ were the the Moapa Band of Paiute Indians the BLM Southern Nevada District following: with the preparation of forms to Office (called the interdisciplinary Water resources: Groundwater nominate identified sacred places team) reevaluated the potential analyses suggest that full build- as traditional cultural properties, impacts of solar development that out of dry-cooled and wet-cooled if it is found that all the proper were described in the Final Solar technologies is not feasible; for eligibility requirements are met. PEIS (see Section 2.3) in the light mixed-technology development Some additional minimization of available data specific to the scenarios, any proposed dry- or measures would likely be identified SEZ area. This team, along with wet-cooled projects should use during preparation of a NEPA other BLM subject matter experts water conservation practices. analysis to support a competitive and Argonne National Laboratory Wildlife (mammals): The lease offering within the SEZ. subject matter experts, followed fencing around the solar energy These measures would also be the methodology presented in development should not block incorporated into the lease offering Sections 2.4.3.1 and 2.4.3.2 for first the free movement of mammals, as stipulations. For example, if identifying unavoidable impacts particularly big game species. any archaeological sites are found from solar development in the Cultural resources: during the cultural resource SEZ, and then for identifying the Coordination with the trail inventory (see text box titled Dry unavoidable impacts that may administration for the Old Lake Cultural Resources) and are warrant regional mitigation. Spanish Trail and Old Spanish Trail determined to be eligible for Association is recommended for listing in the National Register of REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444 • 21
Dry Lake Cultural Resources Following the process for evaluating cultural resources outlined in Appendix E of the BLM technical reference, titled “Procedural Guidance for Developing Solar Regional Mitigation Strategies” the BLM interdisciplinary team determined cultural resources at the Dry Lake SEZ could most likely be mitigated onsite and would not require regional mitigation. At the time of the pilot Dry Lake SEZ Solar Regional Mitigation Planning Project, a relatively high percentage of the Dry Lake SEZ (well over 20%) had been previously surveyed and/or had been previously disturbed during other industrial activities (e.g., power generation, transmission, mining/milling) with few known sites recorded. A segment of the Old Spanish Trail/Mormon Road (not identified as part of the congressionally designated national historic trail) was previously evaluated and determined significant; it is listed as part of a National Register historic district. Because of its proximity to two washes already established as avoidance areas and a set of existing transmission line rights-of-way, it was determined by the interdisciplinary team that any potential impacts on the cultural site (road) are “avoidable,” and no development with the potential to impact the site would be approved in that portion of the SEZ (see Section 2.4.1.2). No other National Register-eligible sites were known within the SEZ at the time of the pilot. An archaeological inventory of the unsurveyed portions of the SEZ is scheduled to be completed prior to offering the SEZ for competitive lease. In the case of the pilot, it was determined by the interdisciplinary team that a regional approach to mitigation planning did not make sense for the Dry Lake SEZ because other SEZs would not likely benefit (not in same region) and because little cost savings and efficiency could be gained with so little survey needed. It was also assumed that the few significant sites that might be found in the SEZ during the future inventory could be mitigated most effectively onsite (i.e., within the SEZ) using traditional methods and in consultation with the state historic preservation officer and tribes. The cultural resource mitigation planning for the Dry Lake SEZ was able to be stopped at this point, and it was concluded that standard procedures for addressing cultural resource impacts made the most sense; the standard procedures would complete the inventory and evaluation and mitigate for any significant sites within the SEZ. In addition, consultation with the Moapa Band of Paiute Indians and other tribes had not identified archaeological/cultural resources significant to them in the SEZ, although resources in the surrounding areas had been identified through an ethnographic study (SWCA and University of Arizona 2011). At the time of the pilot, the BLM was still seeking clarifications from the Moapa on whether portions of the Salt Song Trail or other traditional trails crossed the SEZ and whether cultural resource impacts of interest to the tribe were possible. This issue has not yet been resolved. Based on feedback during the pilot Dry Lake SEZ Solar Regional Mitigation Planning Project workshops, the Moapa were most concerned about impacts on habitat, wildlife, and water use. 2.4.3.1 Identification of impacts for each resource • The team verified/augmented value presented in the Final the programmatic and SEZ- Unavoidable Impacts Solar PEIS. specific design features The following methodology - Evaluated whether the presented in Appendix A of the was used to identify unavoidable description of the affected Final Solar PEIS. impacts: environment and impacts - Reviewed the programmatic was comprehensive and and SEZ-specific design • The interdisciplinary team accurate and whether features presented in the verified/augmented the affected more detailed information Final Solar PEIS, determined environment and impacts was available that could which design features presented in the Final Solar PEIS influence the description of are applicable to the Dry (for completeness, reviewed impacts as provided in the Lake SEZ, and determined analysis in both the Draft and PEIS. Where applicable, new if there are additional Final Solar PEIS). information was documented measures that could be - Reviewed the affected (see Appendix A, Impact implemented to avoid and/ environment and the direct, Assessment Summary Table). or minimize impacts onsite. indirect, and cumulative Where applicable, this was 22 • REGIONAL MITIGATION STRATEGY FOR THE DRY LAKE SOLAR ENERGY ZONE • TECHNICAL NOTE 444
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