Compensatory Mitigation for Utility-Scale Solar Energy Projects
1. Barbara Neal -July 2015 1
Compensatory Mitigation for Utility-Scale_
Solar Energy Projects__________________
_______________Barbara Neal_______________
Prepared for Argonne National Laboratory
Environmental Science division
July 2015
2. Barbara Neal -July 2015 2
Table of contents____________________________________
Section Page
I. Abstract 3
II. Introduction
A. Background on Mitigation and Costs
B. Different Solar Technologies and Impacts
C. Data Sources
5
5
6
8
III. Methods and Materials
A. Places to Find Information/Government Sites
Table 1: Documents and Location URL
B. Types of Information
C. Projects Reviewed
D. Types of Costs Included
8
8
10
11
11
12
IV. Results
Table 2: Project Information & Compensatory Mitigation Costs
13
13
V. Discussion/Conclusion
A. Need for Utility-Scale Solar Development
and Data on Compensatory Mitigation Costs
B. How do the numbers compare?
C. Missing data.
D. Questions.
E. What’s next?
16
16
16
19
19
20
VI. References 20
3. Barbara Neal -July 2015 3
I. Abstract_______________________________________
The purpose of this research is to compile and analyze available data on compensatory
mitigation costs for utility-scale solar facilities. The aim was to allow comparison of these costs
across projects, to identify the types of compensatory mitigation costs incurred to date and allow
better understanding of the effectiveness of the mitigation actions and consistency of
requirements across projects. In this paper the hypothesis is examined that compensatory
mitigation costs are related across projects. Steps are being taken in many companies across the
United States to meet the projected demand for solar energy.
There is a lack of Information on the costs of compensatory mitigation. This evaluation
of costs, done for six utility-scale solar energy projects, was meant to help with that process.
From this research it was found that due to the lack of established pricing of compensatory
mitigation costs, the costs are very dissimilar. In reviewing the results of this research it can be
seen that compensatory mitigation costs are unrelated to amount of acres acquired for the project
footprint, or to the power generating capacity of the facility. No two facilities show similar per
acre or per MW costs. The findings from this study suggest that compensatory mitigation costs
are inconsistent within states and from state to state. The findings also suggest that compensatory
mitigation costs are inconsistent no matter what plant/animal species are affected. The required
ratios for compensation were dissimilar. The prices for desert tortoise compensation lands were
also dissimilar within the same state. The data also suggest that compensatory mitigation costs
are unrelated to the type of solar technology used.
This research shows that a better area (avoiding endangered species) will lower cost. One
project in this study was able to avoid any endangered species and therefore avoid any mitigation
4. Barbara Neal -July 2015 4
fees associated with endangered species. These findings from the combined six projects do
suggest that compensatory mitigation prices go up as the MW output goes up. With the exception
of the Crescent Dunes project, the price per megawatt increases as the number of megawatts
increases.
Information was not located to explain the inconsistency in cost data. This research did
not identify clear reasons for the differences in price or land compensation ratio requirements.
We don’t know if the government is properly managing our land. In reviewing these documents I
am led to ask whether there are any real rules set in place for the actual costs of compensatory
mitigation. The BLM has approved and began construction of 14 projects since 2010, so there is
a chance that as more documentation for development of those facilities becomes available, it
can fill in some of the gaps in compensatory mitigation cost data. Continued research on
mitigation costs is needed to be sure the compensatory mitigation process is fair.
5. Barbara Neal -July 2015 5
II. Introduction__________________________________
A. Background on Mitigation and Costs___________________________
In the United States, the National Environmental Policy Act of 1969(NEPA) has been put
in place to protect the environment. Compensatory mitigation costs, as they relate to this project,
are the costs associated with off-site1 measures taken to prevent impacts to the environment and
biosphere on public land. Many effects have to be taken into consideration. Utility-scale solar
facilities (that is, larger facilities generally over 20 MW that will send electricity to the
transmission grid) will reduce greenhouse gas emissions and reduce air pollutant emissions, but
they still have ecological impacts on the environment. The purpose of this project is to find what
off-site costs are associated with trying to avoid unsought effects to the environment while
building solar facilities.
Avoiding damage is the first priority of mitigation. (CEQ, 1979) When an initial plan is
written for a project, the plan is intensively reviewed by the government, the shareholders, and
the public. To avoid the occurrence of unforeseen adverse impacts, some actions are immediately
eliminated in whole or in part. After avoidance, minimization efforts are taken to lessen impacts.
For example, visual impacts from a 90 foot wall can be reduced by limiting that wall to 45 feet.
In general, even after avoidance and minimization, there will still be impacts. According
to the Council of Environmental Quality’s (CEQ) hierarchy, the next two steps are rectifying and
reducing. (CEQ, 1979) The area within the project footprint disturbed from construction can be
rectified by reclamation and restoration. Then overtime, reduction of impacts happens by
preserving and maintaining what was rectified (CEQ, 1979). Each of these actions are done on-
site, and each idea is developed before any off-site measures are considered.
1Off-site- Locations outside of the proposed project footprint.
6. Barbara Neal -July 2015 6
Compensatory mitigation is essentially the last element in mitigation. The goal of
compensatory mitigation is to alleviate loss that cannot be addressed on-site, by restoring
anticipated loss off-site. In compensatory mitigation, substitute resources or environments will
be acquired, restored, and/or preserved offsite to offset the unavoidable impacts. Ideally the
project can provide “in-kind” mitigation, which would replace the lost resource with a similar or
equivalent resource. A lake could be replaced by a similarly-sized nearby lake. In a less ideal
scenario, compensatory mitigation funds could be provided for some alternative action that the
public agrees upon. The alternative action would provide positive effects to a resource to
counteract the negative impacts to a different resource.
More compensatory mitigation information is available for wetlands. The National
Wetlands Mitigation Action Plan has been in place since 2002, while the Final Programmatic
Environmental Impact Statement (PEIS) for Solar Energy Development in Six Southwestern
States has only been in place since 2012.
This report will focus on the costs of compensatory mitigation for existing operational
utility-scale solar facilities. The data is mainly from the public records from Bureau of Land
Management (BLM) and the California Energy Commission. The purpose of this research is to
allow comparison of these costs across projects, to identify the types of compensatory mitigation
costs incurred to date and allow better understanding of their effectiveness and consistency
across projects.
B. Different Solar Technologies and Impacts_______________________
There are different types of solar energy generating technologies, which may warrant
different types of compensatory mitigation. The main technologies in use currently include
power towers, power towers with thermal storage, parabolic trough, and solar photovoltaic.
7. Barbara Neal -July 2015 7
Power tower collection happens when energy produced by the sun beaming onto reflectors
(called heliostats) is directed to a collection tower. One example impact of concern with respect
to power towers is avian population impacts. Birds can fly into the light beams and be killed by
this type of solar power generation.
Parabolic troughs create energy by concentrating the solar heat with a parabola shaped
mirror to a tube containing oil (called a heat transfer fluid).The oil heats up and turns water into
steam, which turns a wind turbine to create energy.
Solar photovoltaic (PV) technology has a complex chemical process discovered by a
French physicist in 1839. “Edmund Becquerel discovered the photovoltaic effect during
experiments with electrolytic cells; he noticed that certain materials were capable of generating
small amounts of electric current when exposed to sunlight” (BLM and DOE, 2010). When the
sun hits semi conductive materials atoms are ionized and a chemical imbalance takes place
which directly translates to electricity.
PV and trough facilities raise a different avian concern. The collectors are not very far
apart and reflect light, so they look like lakes. Birds may be attracted to this and collide with the
panels; the extent of this occurrence is currently under study. “Indirect impacts may extend
beyond the solar project footprint as the result of factors such as runoff, water depletion, dust
deposition, noise, or visual impacts (Walston, 2015).”
Some solar energy technologies incorporate mechanisms that can equip them with energy
storage, or sensors that follow the sun to receive the best available sunlight concentration. In this
paper we will examine the hypothesis that compensatory mitigation costs are related to the type
of solar technology used.
8. Barbara Neal -July 2015 8
C. Data Sources ______________________________________________
NEPA requires companies to submit an Environmental Impact Statement (EIS), a
document that describes the consequences of the proposed project on the environment. Action
plans and some costs to offset the impacts are also included. The draft EIS is evaluated by the
federal agency overseeing the project, and given a public review period to assess alternatives to
decrease those impacts. The final EIS is then published, with public comments and responses
included.
Additional information on projected costs may be found in the Record of Decision
(ROD) for the EIS, a document submitted from the governmental agency to the public with the
final decision on the project specifications, required avoidance and minimization measures, and
required compensatory mitigation. A project may cause significant impacts as long as those
impacts were identified in the EIS and revealed to the public. An agency may decide that the
benefits of a project outweigh the significant adverse impacts. Often when significant impacts
will occur, compensatory mitigation for those impacts is required. For projects on public lands
(that is, lands administered by the BLM, compensatory mitigation costs may also be found in the
right-of-way (ROW) document, this document specifies final stipulations on project design and
mitigation requirements.
III. Methods and Materials___________________________
A. Places to Find Information/GovernmentSites____________________
For this project, available NEPA documents for utility-scale solar facilities that have been
approved by the BLM since 2010 were reviewed to gather data on compensatory mitigation
requirements and costs. An Excel file was kept with all document titles and webpages that were
reviewed. All compensatory mitigation costs were placed in this file. Only the most recent
9. Barbara Neal -July 2015 9
information for each project was used for the final information recorded in this report. A total of
30 documents were reviewed for the 6 projects. All documents reviewed were not necessary to
include, but review of these documents was important in the research process to understand
which documents contained the accurate information. A Microsoft word file was also kept with
copies of important compensatory mitigation tables provided in the reviewed documents.
NEPA process asks companies to reference other documents, instead of repeating
information, in order to reduce paper work, therefore many documents that were reviewed
referenced data from other documents. The ROW Lease/Grant document is the final document
produced in the BLM leasing process; it specifies final stipulations on project design and
mitigation requirements. In some cases the information in the ROW document will differ from
that presented in earlier documents like the draft and final EIS. In other cases the information
will stay the same, and the ROW will reference the earlier document that has the final
information. For some of the projects reviewed information was missing or incomplete. Table 1
below provides the location URLs for the mandatory documents and the home websites of the
six utility-scale solar energy projects reviewed in this study. The data recorded in Table 2 (see
Section V) reflects information directly from, or referred to in the ROW document (or ROD
when the ROW was not available).
11. Barbara Neal -July 2015 11
B. Types of Information________________________________________
The Bureau of Land Management’s (BLM) website contains a webpage for each project
being developed with access to most or all of the required NEPA documents on developing
projects on public lands. In addition to the above documents the BLM website also contains
conservation plans, some stop work orders, and biological opinions. The Biological opinion is
typically provided by the U.S Fish and Wildlife Service and contains information as to whether
or not the building of the facility is expected to risk the continual survival of listed species or
have an outcome in the devastation or adverse alteration of critical habitat. (USFWS, 2013)
www.blm.gov/wo/st/en.html
The California Energy Commission (CEC) is also responsible for permitting of utility-
scale power tower and parabolic trough solar facilities (but not photovoltaic facilities).
Therefore, this website also includes extensive documentation for these facilities, which was also
referenced for the two California projects reviewed for this report (i.e., the Ivanpah and Genesis
solar projects).
Individual project websites listed above are good for public information and quick
references to project specifications. These websites include beneficial information and
background on the technology used.
C. Projects Reviewed__________________________________________
This work was limited to six utility-scale solar facilities on public lands. There are many
projects currently in the development stages, under construction, and in operation. The
information on some solar facilities is unavailable because facilities located on private lands are
not required to release information for public review, although they are required to meet county
12. Barbara Neal -July 2015 12
and state regulations, and are permitted by these agencies. Any facility that uses public land has
to be reviewed under NEPA and receive a BLM right-of-way grant prior to beginning
construction; this is a process that requires two or more years to complete. Projects on public
land were included in this report because information is publically available. The six projects
reviewed range from 50-370 MW, and from 594-4,640 acres. “BLM manages more than 19
million acres of public lands with excellent solar energy potential in 6 states: California, Nevada,
Arizona, New Mexico, Colorado and Utah. Since 2010, the BLM has approved 33 utility-scale
solar energy projects, with a total approved capacity of 9,278 megawatts.” (BLM, 2015) Of the
33 approved facilities approved, 4 have been terminated, 11 are not on BLM public lands, but
have a transmission line that runs across public lands. There are 14 facilities that are either under
construction or in operation, totaling a potential of 3,864 MW. If data from more facilities could
be obtained, the compensatory mitigation cost information would be strengthened. If data from
more facilities could be obtained, the compensatory mitigation cost information would be
strengthened.
D. Types of Costs Included_____________________________________
Mitigation costs summarized in this report are limited to compensatory (off-site) costs.
Some actions, for example driveway sweeping to reduce visible dust from construction,, are done
off-site, but are not considered compensatory mitigation because driveway sweeping is
considered a part of good construction practices. Compensatory mitigation is restoration,
creation, enhancement, and/or preservation (for example, through acquiring new lands,
conservation easements) of lands outside of the project area (BLM 2013). Therefore, only costs
associated with these actions are considered compensatory mitigation costs in this document.
13. Barbara Neal -July 2015 13
IV. Results____________________________________________________________
For this project, compensatory mitigation costs for six utility-scale solar energy projects were evaluated (four located in
Nevada and two in California). Table 2 gives an overview of what the costs were for and an evaluation of approximate costs per
acre and approximate costs per Megawatt.
Crescent
Dunes
Status:
Construction
completed;
running tests
ROW
granted
2010
Nye County,
Nevada
Acres: 1620
Technology:
Concentrated
Solar Thermal
Power Tower
110 MW
Study of kangaroo mouse habitat - $200,000 (BLM 2011) $200,000 $123 $1,818
Silver
State
North
Status: In
operation
ROD 2010
Clark
County,
Nevada
Acres: 600
Technology:
Thin film PV
50 MW
Desert tortoise:
a) Remuneration fees; paid to BLM $774/acre *600 acres - $464,400
b) Housing, care, treatment, other fees; paid to recovery center - $9000 per
tortoise (project no more than 5 tortoises) – $45,000
Common Ravens: Reduce potential for increased predation (costs not
available)
Non-native plant species: Reduce spread (costs not available)All above (NFWS, 2010)
$509,4003
$849 $10,188
2 Documents have incomplete information; actual costs may have been different than these estimated costs.
3 Data on actual compensatory mitigation costs for the Silver State North project were limited as project documentation was not available through the project
website at: http://www.blm.gov/nv/st/en/fo/lvfo/blm_programs/energy/nextlight_renewable0.html
14. Barbara Neal -July 2015 14
Silver
State
South
Status:
Initial
Construction
ROW
granted
2014
Clark
County,
Nevada
Acres : 2,427
Technology:
PV
250 MW
Crypto biotic soil mitigation - $50,000 (BLM, 2014, ROW)
Monitor and Enforce Disturbance Buffers for nests of raptors and MBTA-
protected species (costs not available) (BLM, 2014, ROW)
Desert tortoises (BLM, 2014, ROD):
a) Monitoring - $3,500,000
b) Dust palliatives - $100,000
c) Restoration 400 acres of roads within the proposed ACEC4 - $400,000
d) Law enforcement: within the proposed ACEC- $350,000
e) Health and genetics - $200,000
f) Remuneration fee $824 per acre x 2400 acres - $1,977,600
g) Remove perimeter fence/ fence highway 93 - $700,000
$7,277,600 $2,998 $29,110
Harry
Allen
Solar
Energy
Center
Project
(Dry Lake SEZ
Parcel 1)
Status:
Approved
Decision
Record 2015
Clark
County,
Nevada
Acres : 594
Technology:
PV
112 MW
Comment
and Review
Period
Desert tortoise remuneration: $843/acre x 594 acres - $500,742 (BLM, 2015)
Dust palliatives’ movement during rain study - $23,000 (BLM, 2015)
Solar Regional Mitigation: $1,836/acre x 594 acres -$1,090,584 (BLM, 2015)
Long-term Monitoring of Mitigation projects - $620,382 (BLM, 2015)
$2,234,708 $3,762 $19,952
Genesis
Solar
Power
Project
Status: In
operation
ROW
Riverside
County,
California
Acres :
4,640
Technology:
Desert tortoise compensatory mitigation (BIO-12)5 -$4,263,500
1:1 & 5:1 ratio for impacts to 24 acres = 1870 acres; Acquisition: $500/acre; Initial habitat
improvement: $330/acre, Long-term management: $1,450/acre)
State waters(BIO-22)6: 111 acres needed -$342,768
(Microphyllous Riparian Vegetation (16 acres) 3:1;Un-vegetated Ephemeral Dry Wash (53
acres) 1:1; Indirect Impacts to Un-vegetated Ephemeral Dry Wash (21 acres) 0.5:1)
Mojave fringe-toed lizard: -$422,668
$5,329,106 -
$5,352,306
$1,148 -
$1,153
$21,316 -
$21,409
4 “Amendments to the 1998 Las Vegas Resource Management Plan designate a 31,859-acre Area of Critical Environmental Concern (ACEC) adjacent to the
ROW grant area.
5 Genesis BIO-12- Desert tortoise compensatory mitigation, calls for the most land compared to other needed mitigation. Project was allowed to use the dessert
tortoise land to mitigate loss of land for other species/resources as long as it met the requirements for the said species/re source.
6 Genesis BIO-22- Is the water replacement plan and many species/resources can use the same land as all requirements are met.
15. Barbara Neal -July 2015 15
granted
2010
Parabolic
Trough
250 MW
(Stabilized/partially stabilized sand dunes (7.5 acres) 3:1; Playa and Sand Drifts (38 acres) 3:1.)
Burrowing Owls: BIO-12. 19.5 acres per owl (two owl estimate) -$120,432 7
Special-Status Plants: BIO-12. 3:1 ratio (Rank 1 plants)& 2:1 ratio (Rank 2 plants)
Protection, habitat improvement, long-term management -$2,280/acre.
Regional Raven Management Program: 1754 acres at $105/acre - $184,170
DTCCL and NRHP: $25/acre + up to 20% -$116,000 to $139,200
Sonoran Creosote Bush Scrub & Associated Wildlife: 1774 acres; BIO-12. (costs not
available) Golden Eagle: BIO-12. (costs not available) Special-Status Birds &
Migratory Birds: BIO-12. (costs not available) Desert Kit Fox & American Badger:
1,811 acres; BIO-22; BIO-12. (costs not available) Bats: BIO-22; BIO-12 (costs not
available) All Above (CEC, 2010)
Ivanpah
Solar
Electric
Generatin
g System
Status: In
operation
ROW granted
2010
San
Bernardino
County,
California
Acres :
3,471
Technology:
Power tower
370 MW
School impact fees -$3,195 ALL (BLM,2010)
Desert tortoises: killed/dead have necropsied (costs not available)
Raven Management Plan(costs not available)
Acquire land (3:1 ratio) 10,414 acres
2/3rds: Maintenance of fencing & habitat enhancements - $17,426,627
Land Acquisition: $910/acre -$6,519,240; Initial habitat improvements: $250/acre –
$1,791,000; Long-Term management of lands: $1,350/acre- $9,671,400
1/3rd: Desert tortoise habitat enhancement - $12,117,813
(50 miles of fencing- $7,084,341; Long-Term Maintenance of Fencing $1,450/acre –
$5,193,500; Administrative -$276,469)
Burrowing owls: Relocate all occupied burrows from site. (costs not available)
Mojave milkweed: 30 acres (costs not available)
Nelson’s bighorn sheep: construct & manage artificial water source (costs not available)
Ephemeral drainages: BIO-178. 175 acres of state jurisdictional waters (costs not available)
$29,547,635 $8,512 $79,848
Acronyms: ACEC – Area of Critical Environmental Concern; DTCCL– World War II Desert Training Center California-Arizona
Maneuver Area Cultural Landscape (Historic District) Documentation; MBTA– Migratory Bird Treaty Act; MW– Megawatt;
NRHP– National Register of Historic Places Nomination contribution; PV– Photovoltaic.
7 Not included in total, because it can be covered underBIO-12
8 Ivanpah BIO-17: Desert tortoise compensatory mitigation, calls for the most land compared to other needed mitigation. Pro ject was allowed to use the dessert
tortoise land to mitigate loss of land for other species/resources as long as it met the requirements for the said species/re source
16. Barbara Neal -July 2015 16
V. Discussion/Conclusion___________________________
A. Need for Utility-ScaleSolar Development and Data on Compensatory
Mitigation Costs ___________________________________________
In order to reserve non-renewable resources, reduce greenhouse gas to prevent climate
change, live in harmony with our environment, and explore the capacities of science, companies
produce solar energy. According to the BLM and DOE the main goal of creating their solar
energy program for utility-scale solar energy development on BLM-administered lands is to meet
the demands of Congressional mandates, Executive Orders 13212 & 13514, and DOI Secretarial
Order 3285SA1, to generate renewable energy on public lands (BLM and DOE 2012).
“The BLM has identified a need to respond in a more efficient and effective manner to
the high interest in siting utility-scale solar energy development on public lands and to ensure
consistent application of measures to mitigate the potential adverse impacts of such
development.” (BLM and DOE 2012) There is a demand for solar energy development all over
the world. According to the Sun Shot vision study of February 2012, the United States has fallen
behind China/ Taiwan, Europe, and Japan in solar development within the previous 10
years.(DOE, 2012) Steps are being taken in many companies across the United States to meet the
projected demand for solar energy. There is a lack of information on the costs of compensatory
mitigation. This evaluation of costs, done for some of the utility-scale solar energy projects
currently approved on public lands, was meant to help with that process.
How Do the Numbers Compare? ______________________________
The findings suggest that compensatory mitigation costs are unrelated to amount of acres
acquired for the project footprint, or to the power generating capacity of the facility. For example
the Harry Allen Solar Energy project footprint and the Silver State North project foot print were
17. Barbara Neal -July 2015 17
essentially the same (594 and 600 acres, respectively). The Silver State North compensatory
mitigation costs were approximately $849/acre and $10,188/MW. The Harry Allen Solar Energy
project compensatory mitigation costs were approximately $3,762/acre and $19,952/MW. Silver
State only paid 19% of what Harry Allen paid per acre. MW payment was closer, but still far
away, only 51% paid by Silver State North compared to Harry Allen. No two facilities show
similar per acre or per MW costs.
The findings from this study suggest that compensatory mitigation costs are inconsistent
within states and from state to state. The findings also suggest that compensatory mitigation
costs are inconsistent no matter what plant/animal species are affected. For example, in 2010 in
California, rights-of -way grants were issued by the BLM for both the Ivanpah Solar Electric
Generating System and the Genesis Solar Power projects. The compensatory mitigation cost per
acre of project area was estimated to be $8,512 for the Ivanpah project, but only $1,153 for the
Genesis project. Some reasons for these different costs are the amount of land that was required
to be compensated for, the ratio of lands required, and the costs of those lands. For the Ivanpah
project each acre of the project foot print required compensation, whereas for the Genesis project
compensation for only a portion of the lands occupied was required.
The required ratios for compensation were also dissimilar. The Ivanpah project required
compensation land in a 3:1 ratio9, while the Genesis Project compensated for lands with ratios
ranging from 0.5:1 to 5:1. The differing compensation ratios occurred for the two projects
located in the same state and approved in the same year. There was a 3:1 desert tortoise land
compensation requirement for each of Ivanpah’s 3,471 acres, for a total of 10,413 compensation
9 3:1 ratio: For every 1 acre of land used the project must acquire and preserve 3 acres of land outside the project
area. For example if the project must compensate for 1000 acres of land on a 3:1 ratio, 3000 acres must be
purchased.If the project must compensate on a 1:1 ratio for 1000 acres of land, then only 1000 acres would need to
be purchased.
18. Barbara Neal -July 2015 18
acres (300% of the project footprint). Only a 1:1 ratio for 1,750 acres and 5:1 ratio for 24 acres
were used for the Genesis Project, totaling 1,870 acres or only 40% of Genesis’s 4,640 acre
project footprint.
The prices for the desert tortoise compensation lands were also dissimilar. Desert tortoise
compensation land was $910/acre for the Ivanpah project, but only $500/acre for the Genesis
Project. This cost difference is surprising, the facilities are only 20 min apart.
The Ivanpah and Genesis projects were similar in the way that they both required desert
tortoise compensation lands and they both allowed those desert tortoise lands to be counted as
compensation land for other endangered species that compensation was also required for, as long
as the lands met both of the species’ requirements (see Genesis BIO-12 (CEC, 2010) & Ivanpah
BIO-17 (CEC, 2010) compensation exceptions).
The comparative data presented in Table 2 also suggest that compensatory mitigation
costs are unrelated to the type of solar technology used. For example, the Crescent Dunes project
and the Ivanpah project both use power tower technology and were both approved in 2010. As
seen in Table 2 Crescent Dunes’ approximate compensatory mitigation price per acre was $123,
while Ivanpah’s approximate price per acre was $8512. Crescent Dunes paid only 1% of what
Ivanpah paid per acre. Crescent Dunes’ approximate price per MW was $1,818, while Ivanpah’s
approximate price per MW was $79,858. Crescent Dunes’ approximate price per MW is only 2%
of Ivanpah’s price. The compensatory mitigation costs for the Crescent Dunes and Ivanpah
projects showed the largest variation among the six projects reviewed. The Cresent Dunes
project did not mitigate for desert tortoise. This research shows that a better area (avoiding
endangered species) will lower cost. The Crescent dunes project was able to avoid any desert
tortoise habitat, therefore avoiding the mitigation fees associated with desert tortoise.
19. Barbara Neal -July 2015 19
These findings from the combined six projects do suggest that compensatory mitigation
prices go up as the MW output goes up. With the exception of the Crescent Dunes project, the
price per megawatt increases as the number of megawatts increases. The larger the megawatt
capacity of a project, the more customers it will be able to service, and the project should
therefore be more profitable. If this hypothesis is correct it should not take these projects long to
make back the cost of compensatory mitigation fees through profits.
A. Missing data.______________________________________________
Information was not located to explain the inconsistency in cost data. For example, in the
Ivanpah and Genesis comparison, the two sites are in the same state and approved in the same
year. Yet, the tortoise land acquisition prices and acquisition ratios are different. If there is some
information that explains why that is so, that needs to be included with the mandatory paper
work. In the Ivanpah and the Genesis Solar Project comparisons many costs were unavailable,
but most costs that were not listed fell under the category of species that fell into the Genesis
BIO-12 & Ivanpah BIO-17 compensation exceptions. This research did not identify clear reasons
for the differences in price or land compensation ratio requirements. We don’t know if the
government is properly managing our land. When important information on price inconsistencies
is left out, we only know the prices are different, while the year of ROW and the states that the
projects were built in are the same.
B. Questions.______________________________________________
In reviewing these documents I am led to ask whether there are any real rules set in place
for the actual costs of compensatory mitigation. Where do the numbers come from? Many
projects were approved in the same year, so why are the variations so large? Is the government
properly managing our land?
20. Barbara Neal -July 2015 20
C. What’s next? _____________________________________________
More research needs to be done. The BLM has approved and began construction of 14
projects since 2010, so there is a chance that as more documentation for development of those
facilities becomes available, it can fill in some of the gaps in compensatory mitigation cost data.
In general, guidelines or standards should be put in place for compensatory mitigation
requirements. Continued research on mitigation costs is needed to be sure the compensatory
mitigation process is fair.
VI. References_____________________________________
BLM (Bureau of Land Management), 2010. Ivanpah Solar Electric Generating System
Final Environmental Impact Statement. Bureau of Land Management
Needles Field Office, Needles, California. Available at:
http://www.blm.gov/style/medialib/blm/ca/pdf/needles/lands_solar.Par.20589.File.dat/2-
4_0_Affected_Environment_and_Environmental_Consequences.pdf
BLM, 2011. Crescent Dunes Final Environmental Impact Statement FES-10-57, N-86292, DOI-
BLM-NVB020-2009-0104-EIS, Appendix E: BLM Wildlife Mitigation and Monitoring Plan.
BLM Battle Mountain District, Tonanah, Nevada. Available at:
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