2. STEPS
Background on
Compensatory Mitigation
alleviate loss that cannot
be addressed on-site, by
restoring anticipated loss
off-site.
acquired, restored,
and/or preserved offsite
to offset the unavoidable
impacts
“in-kind” mitigation
2
Avoid
Minimize
Rectify
Reduce
Compensatory Mitigation
(CEQ, 1979)
3. Different Solar Technologies and Impacts
Power towers
Parabolic trough
Solar photovoltaic
3
Crescent Dunes Solar Energy
Project
Ivanpah Solar Electric
Generating System
Silver State North
Genesis Solar Power Project
Silver State
South
Status: Initial
Construction
Harry Allen
Status:
Approved
Comment and
Review Period
5. Mandatory Growth
National Environmental Policy Act of 1969 (NEPA)
Congressional mandates
Executive Orders 13212
Executive Orders 13514
DOI Secretarial Order 3285SA1
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“take appropriate actions, to
the extent consistent with
applicable law, to expedite
projects that will increase the
production, transmission, or
conservation of energy.”
“Encourage … development of
renewable energy …while protecting
and enhancing the nation’s water,
wildlife, and other natural resources;
to identify appropriate areas for
generation …on public lands to
ensure the most environmentally
responsible development…”
7. Methods and Materials
The Bureau of Land Management (BLM)
www.blm.gov/wo/st/en.html
The California Energy Commission (CEC)
www.energy.ca.gov/
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Biological opinion is the document that
states the opinion of the Service as to
whether or not the Federal action is
likely to jeopardize the continued
existence of listed species or result in the
destruction or adverse modification of
critical habitat.
Environmental Impact
Statement (EIS), a
document that describes
the consequences of the
proposed project on the
environment.
Record of Decision
(ROD) document with the
final decision on the
project specifications,
required avoidance and
minimization measures,
and required
compensatory mitigation
Right-of- Way
Lease/Grant
(ROW) specifies
final stipulations
on project design,
and mitigation
requirements.
8. How Data Was Kept
30 documents were reviewed for
the 6 projects.
An Excel file was kept with all
document titles and webpages
that were reviewed.
Which documents contained the
accurate information?
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9. Need for Utility-Scale Solar Development and Data
on Compensatory Mitigation Costs
Main goal of solar energy program for
utility-scale solar energy development on
BLM-administered lands :
– is to create a standardized and
streamlined authorization process
(BLM and DOE 2012).
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“…to ensure consistent application
of measures to mitigate the
potential adverse impacts of such
development.” (BLM and DOE 2012)
10. Results
Project Total
Acres
Total
MW
Total Compensatory
Mitigation Costs¹
Approx. Cost
Per Acre
Approx. Cost
Per MW
Crescent Dunes
Nevada 2010
1620 110 $200,000 $123 $1,818
Silver State North
Nevada 2010
600 50 $509,400² $849 $10,188
Silver State South
Nevada 2014
2427 250 $7,277,600 $2,998 $29,110
Harry Allen
Nevada 2015
594 112 $2,234,708 $3,762 $19,952
Genesis
California 2010
4640 250 $5,329,106 - $5,352,306 $1,148 -
$1,153
$21,316 -
$21,409
Ivanpah
California 2010
3471 370 $29,547,635 $8,512 $79,858
Average Approx.
Cost
$2,898 $27,040
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11. How do the numbers
compare?
11
Findings suggest: Unrelated to the
amount of acres acquired for the
project footprint
Harry Allen Solar
594 acres
$3,762/acre
$19,952/MW
Only of
Only of
Silver State North
600 acres
$10,188/MW
$849/acre 19%
51%
12. 12
How do the numbers
compare?
12
Findings suggest: Compensatory mitigation costs are un-related to
the type of solar technology used.
Ivanpah
$8,512/acre
$79,858/MW
Only of
Crescent Dunes
$1,818/MW
$123/acre
1.45%
2.28%
Power Tower in 2010
Only of
13. 13
How do the numbers compare?
13
The findings from this study suggest that compensatory mitigation costs are inconsistent
within states and from state to state. The findings suggest that compensatory mitigation
costs are inconsistent no matter if the same animal/ plant species is effected.
Ivanpah
$8,512/acre
$79,858/MW
Only of
Only of
Genesis
$21,409/MW
$1,153/acre 13%
26%
California in 2010
Dessert
Tortoise
fees
$910/acre
300% of land
Only of
Only of
40% of land
$500/acre 55%
13%1750 of
4640
10,413 of
3,471
14. How do the numbers compare?
This finding
from the
combined six
projects
suggests that
compensatory
mitigation
prices go up as
the MW output
goes up (with
exception to
Crescent
Dunes).
14
Ivanpah Solar Electric Generating System
370 MW $19,858
Silver State South
250 MW $29,110/MW
Genesis Solar Power Project
250 MW $21,409/MW
Harry Allen Solar
112 MW $19,952/MW
Crescent Dunes
110 MW $1,818/MW
Silver State North
50 MW $10,188/MW
15. Missing data.
What’s next?
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Any real rules set in place for the actual costs of compensatory mitigation?
Where do the numbers come from?
Many projects were approved in the same year, so why are the variations so
large?
Is the government properly managing our land?
More research needs to be done.
The BLM has approved 33 projects since 2010, so there is a chance that some of
those facilities can fill in gaps in price.
A standard put in place for compensatory mitigation costs.
The research needs to be complete to be sure the compensatory mitigation
process is fair.
16. References
CEQ (Council on Environmental Quality), 1979. CEQ Regulation 1508-- Terminology
and Index. Available at: https://ceq.doe.gov/nepa/regs/ceq/1508.htm
BLM, 2011. Crescent Dunes Final Environmental Impact Statement FES-10-57, N-
86292, DOI-BLM-NVB020-2009-0104-EIS, Appendix E: BLM Wildlife Mitigation and
Monitoring Plan. BLM Battle Mountain District, Tonanah, Nevada. Available at:
http://www.blm.gov/style/medialib/blm/nv/field_offices/battle_mountain_field/
blm_information/nepa/crescent_dunes_solar.Par.86958.File.dat/Appendix%20E.p
df.
NFWS (National Fish and Wildlife), 2010. Biological Opinion for the Silver State
Solar Project File No. 84320-2010-F-0208,Fish and Wildlife Office, Las Vegas,
Nevada. Available at:
http://www.blm.gov/style/medialib/blm/nv/field_offices/las_vegas_field_office/e
nergy/nextlight_-
_other/NextLight_BO.Par.54027.File.dat/NextLight_Silver_State_Solar_BO%20.pdf
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