Solar PV - Environmental Due Diligence


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Environmental Due Diligence for siting and permitting solar PV facilities at the utility scale

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Solar PV - Environmental Due Diligence

  1. 1. EUCIDue Diligence forSolar PV Projects Daniel Belin, AICPecology and environment, Inc.
  2. 2. Enhancing Due Diligenceand Streamlining Permitting June 14-15, 2011 Daniel Belin, AICP ecology and environment, Inc.
  3. 3.  Project Development Overview Due Diligence – Real Estate vs. Environmental GIS Demo The Permitting Process Streamlining Tips
  4. 4. Phase I & II ESA Legal standard - ASTM Real Estate document Contamination liabilities CERCLA Benefits – addresses legal liability for contamination Limitation – does not address other regulatory liability
  5. 5. Phase I & II ESA Not a green light to start design Don’t rush into development
  6. 6.  Did not invest in early issue identification Adjusting layout after design Wastes time and money
  7. 7.  Database searches GIS investigation Site reconnaissance Agency consultation Permitting matrix Critical Issues Analysis
  8. 8. Natural Environment Built Environment Wildlife and Habitat  Land use Special Status and State-  Flat-panel PV -- 2.5~12.5 Listed species acre/MW Habitat fragmentation or  Solar-thermal -- 5.0~12.5 removal acre/MW Microclimate/habitat  Aesthetics/Visual Resources, changes glare Water availability  Recreation Cultural resources  Public involvement
  9. 9. Must be compatible withother uses, immediateand adjacent Mining and Agriculture often compatible Recreation/Tourism requires consideration Federal land: recreation use classes may preclude large-scale solar developments:  Off-Highway Vehicles (OHV)  Near Designated Wilderness Areas and Wilderness Study Areas  Wild and Scenic Rivers  National Trails  Scenic Byways  National, state, and local parks Cumulative impacts
  10. 10.  Disruption of wildlife movement corridors Direct loss of or change in native species habitat Shading from solar arrays can create a microclimate Disturbance due to human activity, roads, fences, and light
  11. 11.  Includes archaeology, paleontology, and historic structures Consultation with State Historic Preservation Office Tribal and federal agency consultation Varying levels of assessment  Phase I survey where resources possible  Phase II survey where resources known  Monitoring during construction Historic buildings 50+ years old. Can include structures (cemeteries, bridges, dams)
  12. 12.  Often the most significant public concern Landscapes differ in their ability to accommodate change Technical approaches can quantify impacts. BLM and USFS have standard protocols. Strategies to minimize impacts and ease public controversy Determine visual sensitivity level Reduce impacts with careful array and road placement, vegetation screens
  13. 13.  Water for thermal-solar project cooling and mirror washing requirements can be significant Impacts to wetlands and streams (arroyos) must be avoided or mitigated Runoff / erosion from impervious surface
  14. 14. Water Use by Fuel Source and Generation Technology1 Wet Cooling Wet Cooling Water Other Water Water Other Water Consumtion Consumptionb Generation Consumtion Consumptionb Generation Technology (gal/MWh)a (gal/MWh) Technology (gal/MWh)a (gal/MWh) irrigation Solar Trough 760-920 8 Biomass2 300-480 dependentd Natural Gas Combined Solar Tower 750 8 Cycle 18-21 180 Photovoltaic Solar 0 5c Coal (IGCC)f 140 200 avg. 4,500 Wind 0 0 Hydroelectric (evap) Fossil 300-480 35-104 Nuclear 400-720e 75-1801 Data calculated from U.S. Department of Energy, Energy Demands on Water Resources: Report to Congress on the Interdependency of Energy and Water (Dec. 2006), available at Carter provided notes. See Carter & Campbell, supra note 8, at 8.a. Data is for cooling tower technology.b. Includes water consumed in producing or enhancing the fuel source and in generation; excluding cooling water consumption.c. National Renewable Energy Laboratory (NREL), Fuel from the Sky: Solar Power’s Potential for Western Energy Supply, NREL/SR-550-32160 (July 2002), at 99.d. CRS provided note.e. Cooling ponds which are commonly used at nuclear facilities consume roughly 720 gal/MWh.f. IGCC is Integrated Gasification Combined-Cycle.22 The biomass referenced in Table 2 does not include woody biomass.
  15. 15. » Case Study – Silver State Solar Predicted Water Consumption  400 MW PV  Ivanpah Valley, NV  600 Acre-Feet-Annually (AFA) / 4 years (construction)  21 AFA (operations)  Average industrial development in region – 4,717 AFA
  16. 16. 14: Easements, ROWs, Legal Issues 1: 4: Visual 5/6: 8: 15: Other 2: T & E Species 3: Open Space/ 7: Floodplain/ 9: Waterways 10: PrimeAcres Zoning Conservation Resources Hist./Cult. Wetlands Encumbrances, (c) Parks (d) Drainage (g) (i) Ag. Land (j) Areas (b) (e) (miles) (f) (h) 17: Other Significant Resources and Notes:  Swainsons hawk 0.8 miles Yes. Floodplain away borders northern Stream/River Site is located in an 8.15 miles 7.79 miles  Delta button- part of property and crosses the Enterprise Zone from from Prime 160 AG-40 No. celery 1.5 miles No stream through No property; Site has an Agricultural designated Historic canal/ditch along Farmland and property/ Preserve R-69-C1 scenic route House northern border  giant garter Moderately well designation snake approx 3 drained miles  California tiger salamander  Northern Hardpan Vernal Freshwater Pool Site is located in an 1.42miles 9.15 miles Emergent  vernal pool fairy Stream/River Enterprise Zone from from No/Moderately well Wetland on Grazing40.09 AG-40 Yes. shrimp No borders Site has an Agricultural designated Historic drained eastern northwest corner land  valley elderberry Preserve R-69-C1 scenic route Farm property longhorn beetle designation border.  western spadefoot are < 5 miles from the site but not on site One Swainsons hawk 22.96 from Yes. Floodplain Stream/River Site is located in an 4.89 miles crosses the Eastern 0.29 miles from the the covers southern Enterprise Zone Park 2.3 miles from property, one portion is106.62 AG-40 No site, burrowing owl intersection end of No stream/river Site has an Agricultural from the site Historic prime 0.6 miles from the of HWY property/somewhat borders the Preserve R-80-8 House farmland site 580/5. poorly drained south end of the site Swainsons hawk 0.8 miles 23.24 miles Farmland 4.22 miles Site is located in an Burrowing owl 2.6 from the of Park 1.7miles from No/Somewhat No streams or Enterprise Zone43.31 AG-40 No miles. California intersection No rivers Statewide from the site Historic poorly drained No Agricultural tiger salamander of HWY Importanc House Preserve designation within 5 miles. 580/5. e
  17. 17. GIS Online Siting Tool
  18. 18. 1. Define regulatory process and involved agencies2. Conduct initial surveys and studies to identify potential environmental impacts and required permits3. Hold agency consultations4. Complete detailed environmental surveys5. Develop permit applications6. Agency review7. Public hearings8. Final permits issued
  19. 19.  Bureau of Land Management ROW Application and Plan of Development National Environmental Policy Act State Siting Committee Conditional Use Permit Applications (County level)
  20. 20. Pre- application meeting Submit preliminary application 30 day public notice andCounty scheduled public hearing with P&Z comment Board and BOCC period 30 day public Submit final 1041 application notice and comment period Joint public hearing with Planning and Zoning Board and BOCC Total:P&Z Board hold meeting on same day and 3-4 Months issue recommendations to BOCC BOCC Meeting Final Approval issued within 7 days
  21. 21. Preliminary Discussions 0-2 Months Pre- Application Period 6-9 Months Application Submittal Period 3 MonthsHearing and Service of Decision 0-2 Months Appeal Window 1 Month Total: 18 Months
  22. 22. Application 30 days Notice of Intent Published 45 days Public Scoping Draft EIS 6-9 months 45 daysComment Period / Agency Review Final EIS 6-9 monthsComment Period / Agency Review 45 days Record of Decision (ROD) Total: Appeal Period 18-24 months
  23. 23.  What takes so long?  Seasonal field studies  NEPA/State equivalent applicability  Permit linkages and Agency communication  Agency expertise and workload  Statutory review times  Quality and completeness of applications  Agency and community relationships
  24. 24. “By putting these renewable energyprojects on a fast track, we are managingour public lands not just for conventionalenergy development but also forenvironmentally responsible renewableenergy production that will power our cleanenergy future.” Secretary of Interior, Ken Salazar November 5, 2009
  25. 25.  NEPA Fast Tracked Projects  2 Solar PV projects  Silver State – 400 MW PV  Start to Finish – 14 months  Agency schedule pre-set  RECO office  Statutory review times  Strong management on all sides  Project completely vetted before initiating NEPA
  26. 26.  Streamlining process Desert tortoise Identification of key issues for timely resolution - 9 months before filing the application Shaved 6 months by establishing pre-filing process Issues raised during pre-filing:  Quantitative cumulative impacts approach for desert tortoise  New alternatives  Dry lakes recreation  Visual resources  Mojave National Preserve Transmission lines in Ivanpah Valley
  27. 27.  Get your team talking details for a complete Project Description
  28. 28.  Dual state and federal lead agencies Cover needs for both agencies at once Added complexity can mean delays Plan ahead even more with two lead agencies
  29. 29. Frequent Data Gaps in Project Descriptions Complete land use tables GIS Data for access roads, tower locations Helicopter use plans Noxious weed plan Construction schedule – realistic? Work force requirements for O&M Decommissioning All project components covered? Construction equipment used – air emissions
  30. 30.  Expect a sophisticated public Document all outreach efforts Identify key public issues for your project Explain alternatives development process Take public recommendations for alternatives seriously
  31. 31.  Track all alternatives screened Address system alternatives (PV vs. CSP) Develop an adequate range of alternatives: BLM to require 3 to 4 alternatives for renewable projects Agencies expect public engagement to develop alternatives for contentious projects
  32. 32.  No longer business as usual The bar has been raised Early agency attention equals feedback for your developing project and most likely a quicker decision process
  33. 33. Questions? Dan Belin(703)