Basin and Range Watch
Defending the Desert
September 19th, 2022
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Oppose the Bonanza Solar Project!
Sample Letter to Send Below
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The Bureau of Land Management (BLM) is asking for public input on the Bonanza Solar Project proposed for approximately 5,100 acres of BLM-managed public land located in Clark County, Nevada, approximately 30 miles northwest of Las Vegas, Nevada and 4 miles west of Indian Springs, Nevada. The public input period will close September 22nd, 2022. We have a sample letter at the end of this alert.
EDF Renewables Development, Inc (Bonanza Solar LLC), has applied for a right-of-way grant for the construction and operation of a 300 megawatt (MW) solar energy project, including battery energy storage and interconnection to the regional transmission system. It is a photovoltaic solar power project with battery storage on BLM-land designated as a solar variance area in Clark County. About 2,500 acres would be developed for solar energy within this footprint
If fully built out, the project would impact 4 square miles of Mojave Desert public lands and habitat.
The project would be built in a region identified as "the most critical desert tortoise connectivity corridor in Nevada". It is located in an area identified as critical for the desert tortoise. This high value contiguous habitat maintains genetic and demographic connectivity between wilderness areas, national park lands, wildlife refuges and critical habitats.
Heavy construction equipment would crush millions of living organisms. Over 150,000 cacti and Mojave yuccas would be impacted. Insects, reptiles and mammals would all be threatened by heavy machinery. The project would create fugitive dust issues for the communities of Cactus Springs and Indian Springs. The project would be visible from the Spring Mountains National Recreation Area, the Mt. Stirling Wilderness Area, Cold Creek, the community of Cactus Springs, and the Desert National Wildlife Refuge.
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^ Before and After? Left, habitat example for about 50 percent of the Bonanza Solar Project. Right, industrial clearing for the Yellow Pine Solar Project in Clark County, Nevada (photo by Shannon Salter).
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Degrading Desert Tortoise Habitat on Public Lands |
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The U.S. Fish and Wildlife Service’s (USFWS) Desert Tortoise Recovery Office performed a landscape-scale modeling exercise to identify priority habitat linkages between and among desert tortoise conservation areas and define other large blocks of habitat with important value to recovery of the desert tortoise.
The project is proposed in relatively undisturbed desert tortoise habitat. It is located in the modeled Least Cost Corridor and represents high value contiguous habitat that connects desert tortoise conservation areas. It has been determined to be important to maintain genetic and demographic connectivity across the landscape to connect conservation areas such as National Wildlife Refuges, Wilderness Areas, Areas of Critical Environmental Concern and Critical Habitats. All wildlife connectivity has been cut off to the east in the Las Vegas Valley by explosive urban growth, so this region "connects" the Indian Springs Valley to both the Amargosa Valley and Pahrump Valley.
All tortoises would be excavated from their burrows and translocated off site to a location to be decided. Last year, the translocation that moved tortoises off the Yellow Pine Solar Project on the west side of the Spring Range resulted in the predation of 33 of the moved tortoises by badgers which are not common desert tortoise predators. This could very well be because they moved the tortoises during a record-breaking drought year and the badgers were desperate for food. Common problems that result from translocation of desert tortoises include:
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Predation - Savvy predators like coyotes will often keep track of recently moved, disoriented desert tortoises, and they have reduced tortoise numbers on certain translocation projects. This is a bigger problem on drought years. Ravens also search out newly-moved tortoises.
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Overheating (Hyperthermia) - Translocated tortoises often become disoriented and will seek out their former homes. In many cases, tortoises overheat doing this. They have been observed pacing recently built fences searching for home burrows and water sources. Tortoises are ectothermic (cold-blooded) and do not internally regulate their body temperature that well.
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Lack of Reproductive Success - A recent Smithsonian study found that translocated male desert tortoises are not reproducing.
According to tortoise biologists: "Prevailing declines in the abundance of adults overall and in four of the five recovery units indicate the need for more aggressive implementation of recovery actions and more critical evaluation of the suite of future activities and projects in tortoise habitat that may exacerbate ongoing population declines. G. agassizii is now included in the list of the top 50 turtle and tortoise species at greatest risk." (from Allison, L. J. and A. M. Mcluckie. 2018. Population Trends in Mojave Desert Tortoises (Gopherus agassizii). Herpetological Conservation and Biology 13(2):433–452.)
The region was hit hard by drought in the last 2 years. Surveyors located 167 tortoise carcasses in the 12,000 acre survey area. But the area has seen an abundant amount of precipitation in 2022 and tortoise eggshells have been found.
The Nevada Department of Transportation recently installed 9 culverts under the Highway 95 adjacent to the project site as mitigation for highway improvements. Remote cameras have been set up and desert tortoises have been recorded walking through the culverts. Desert tortoise connectivity is maintained by these culverts to a point. Building a 4 square mile solar project in the same area could defeat the purpose of maintaining connectivity with culverts.
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Above: Two maps showing the Priority One Desert Tortoise Connectivity Habitat in the Indian Springs Valley with the project proposal outlined in the first map.
Left: One of the 33 desert tortoises killed by badgers after being moved off the Yellow Pine Solar Project.
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^Desert tortoise burrow map from the survey report for tortoises on the Bonanza Solar site.
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^One of the 9 culverts built under Hwy 95 by NDOT as mitigatioon for desert tortoise impacts by highway improvements. |
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Crushing Desert Ecosystems
The project site would most likely be cleared through what is being called "vegetation mowing". The idea being that some vegetation could regrow under the solar panels. But the vehicles that clear the vegetation can weigh over 25,000 pounds. Even when some vegetation eventually grows back, it is still initially crushed and anything burrowing under the ground would also be crushed.
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^Clearing for Yellow Pine Solar Project, NV (photo by Shannon Salter) |
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^Clearing for Sunshine Valley Solar Project, NV |
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Vegetation mowing for the Inavpah Solar Project in 2010 |
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Cacti and Yucca
From the project proponent's own calculations, there are 63 cacti and yuccas per acre on the project site that would be developed. That means there are 157,500 cacti and Mojave yuccas on the site. While some would be relocated, most would be destroyed. Salvaging 150,000 cacti and yuccas would be very expensive for the proponent so many would be sacrificed.
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Fugitive Dust
Dust control in hot, arid climates is very problematic. The removal of established vegetation, biological soil crusts and centuries old desert pavement creates opportunities for dust to be airborne every time the wind blows. Not only does fugitive dust create problems for visual and biological resources, it creates issues for public health as well.
Some of the topography of the project site is composed of clay-based badlands which will create big dust issues when run over by earth movers.
In 2013, 28 workers were sent home with valley fever during the construction of the Topaz Solar Project in California. The above photo shows out of control dust from the Sunshine Valley Solar Project, Amargosa Valley, Nevada construction - 2019.
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Above: Badlands topography on east side of the Bonanza Site. |
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Loss of Wildlife and Native Plants |
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The proposed project would be developed on a diverse and undisturbed Mojave Desert habitat. The vegetation is characterized by creosote and white bursage mixed with mid-elevation Mojave Desert plants. The site supports a host of species such as burrowing owls, kit foxes, kangaroo rats, big galletta grass, fluff grass, desert iguana, Parish club cholla, Mojave yucca, honey mesquite, glossy snake, cottontop cactus, American badger, western banded gecko, and beavertail cactus to name just a few. |
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^Parish's club-cholla (Grusonia parishii)
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^ Calico Cactus - (Echinocereus Engelmanni)
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^Big Galleta Grass (Hilaria rigida) High value food for desert tortoise
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^Loggerhead shrike (Lanius ludovicianus)
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^Mojave yuccas (Yucca schidigera) can live to be 200 to 500 years old and provide habitat, shelter and food for multiple species. Thousands would be destroyed for the Bonanza Solar Project.
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^Mojave Desert Sidewinder (Crotalus cerastes)
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^American Badger (Taxidea taxus)
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^Great Basin collared lizard (Crotaphytus bicinctores)
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^Phainopepla (Phainopepla nitens)
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^Long nosed leopard lizard ( Gambelia wislizenii)
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Large numbers of bird mortalities have been detected on utility-scale solar projects, and many scientists believe that they are creating a polarized glare or lake effect that causes birds and insects to be deceived and collide with solar panels or simply dehydrate after landing. The avian impacts are not fully understood, but everyone seems to agree that this problem was underestimated during the initial boom to fast-track big solar on both public and private lands in the Southwestern US.
Data gathered from seven solar projects in the southern California desert and arid grassland habitats from 2012 through April 2016 show that 183 bird species have been killed at solar projects, a number that rises with new information. 3,545 individual birds were reported dead at solar projects.
The Bonanza Solar Project would be located about 1 1/2 miles from Cactus Springs - a small wetlands that attracts water birds and other migrating birds.
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The region is homeland to the Western Shoshone, Southern Paiute, and Chemehuevi peoples and is significant because of the spring mounds and springs scattered on the valley floor: Cactus Spring and Indian Spring. These springs were crucial stopping points in travels across the desert.
Archaeological resources most commonly consist of small lithic scatters, although rock art, rock shelters, and larger archaeological districts are also noted.
Temple of Goddess Spirituality Cultural Landscape
A cultural landscape exists around the Temple of Goddess Spirituality (https://www.sekhmettemple.org), composed of intact Mojave Desert ecosystems and viewscapes that are important in providing a peaceful, natural setting for the temple and its artwork, theaters, trails, and buildings. The desert is a sacred landscape that is part of the temple experience
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Impacts to Visual Resources
A 4-square-mile development (right) would be visible for great distances. The visual contrasts would be visible from up to 20 miles away. Covering that much land with solar panels would completely change the entire landscape. The project would be visible from the Spring Mountains Recreation Area, Mt Charleston Wilderness Area, Mt. Stirling Wilderness Area, Desert National Wildlife Refuge, Cactus Springs and Cold Creek. It would create a very unnatural change to the landscape.
The BLM may convert the area into an industrial zone.
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Top: Scenic landscape on the Bonanza Solar Project site
Bottom: Silver State South Solar Project near Primm, Nevada.
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With all of the new construction projects happening in the Las Vegas region, renewable energy can be utilized on rooftops and above parking lots. The US Department of Energy says, “The number of U.S. households with rooftop solar is rapidly growing. The amount of grid-connected solar is expected to double in just two years. With this large number of PV homes in the U.S. and a continuing robust market for additional PV installations, an ever-increasing number of PV homes will likely be sold or refinanced.”
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Water
The project proponent has not said where they would get the water required to build the project. The close proximity to Cactus Springs (right) and presense of mesquite and cottonwood indicates that any water use for construction could draw down the aquifer. A solar project of this size will need about 300 to 400 acre feet of water during construction to mitigate fugitive dust emissions. Under the Clark County Multi-Species Habitat Conservation Plan, mesquite habitats on public lands are required to be protected.
The project would be located in the Indian Springs Basin which has recently been identified as being situated right on top of a "Mega-channel" that is directly connected to Devil's Hole and Ash Meadows National Wildlife Refuge. Water recharge from the high Spring Range is a reason for the mega-channel. The Devil's Hole pupfish is one of the most endangered species on the planet. Other endangered species could be threatened in Ash Meadows National Wildlife Refuge.
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^Interpretive pupfish sign at the site of Devil's Hole. |
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Cumulative Impacts
The main transmission line Bonanza would hook into is called Gridliance and to the west is the Innovation Substation. This has attracted two other solar energy developers to the region. Aside from the Bonanza Solar Project proposal, there is also the proposed South Ridge Solar, a 2,200 acre project located to the west of the Bonanza Site and the proposed Kawich Solar, a 4,300 acre project located just south of Bonanza. The entire transmission infrastructure is set up to export the energy to California.
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Area of Critical Environmental Concern
Basin and Range Watch and Western Watersheds Project are requesting that the BLM designate the region as a 58,000 acre Cactus Springs Area of Critical Environmental Concern (ACEC) as an alternative to the solar project proposals. Areas of Critical Environmental Concern or ACEC designations highlight areas where special management attention is needed to protect important historical, cultural, and scenic values, or fish and wildlife or other natural resources. The proposal for the ACEC can be viewed here.
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Sample Letter to Send to BLM
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The BLM will be accepting comments on the Bonanza Solar Project application until September 22nd, 2022. Now is a good time to tell the BLM to reject this project.
Written input can be submitted via email to: BonanzaSolar@blm.gov.
Additionally, public input can be mailed to Greg Helseth, BLM Nevada State Office, 1340 Financial Boulevard, Reno, Nevada 89502
Below is a sample letter you can copy and send to BLM. Please personalize the message to give them a diverse selection of comments. Your own ideas will make a difference to them when considering comments.
"Please reject the application for the Bonanza Solar Project.
The proposed project site is located in a part of the Mojave
Desert that the Fish and Wildlife Service has called 'the most critical
desert tortoise connectivity corridor in Southern Nevada'. This high value contiguous habitat maintains genetic and demographic connectivity between wilderness areas, national park lands, wildlife refuges and critical habitats. All desert tortoise connectivity in the Las Vegas Valley has been cut off by explosive urban growth.
The project would destroy an undisturbed site and remove habitat for multiple Mojave Desert species including desert kit fox, Parish's Club Cholla, Utah vine milkweed, kangaroo rat, long-nose leopard lizard, burrowing owl, western banded gecko, loggerhead shrike and a host of other species.
There are 63 cacti and yuccas per acre on the project site that would be developed. That means there are 157,500 cacti and Mojave yuccas on the site. Most would be removed and/or destroyed
The project would create visual impacts for the Mt. Charleston Wilderness Area, the Mount Stirling Wilderness Area, the Desert National Wildlife Refuge, Cactus Springs and Cold Creek.
Construction of the project would destroy biological soil crusts and desert pavement. This will create fugitive dust issues for the communities of Cactus Springs and Indian Springs, Nevada,
Construction of the project would require 300 to 400 acre feet of water to control fugitive dust. If the project proponent uses local water, it could dry up the riparian springs at Cactus Springs. The region also sits on top of a Mega-channel that is part of the watershed that supplies Ash Meadows National Wildlife Refuge and Devil's Hole, home to the Devil's Hole Pupfish, one of the most endangered species in the world.
To preserve diverse Mojave Desert habitat on public lands, BLM should reject the application for the Bonanza Solar Project and establish the 58,000 acre Area of Critical Environmental Concern as the alternative proposed by two organizations."
(Your name and address here)
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Basin & Range Watch
PO Box 70, Beatty
NV 89003
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