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Basin and Range Watch
Defending the Desert

Action Alert
Oppose the Gemini Solar Project
Sample Letter to Send Below
The Draft Environmental Impact Statement for the Gemini Solar Project on Bureau of Land Management (BLM) lands in southern Nevada was released in June. Comments are due on September 5th. The project will develop 11 square miles (7,100 acres) and over 200 Federally Threatened desert tortoises will need to be excavated and moved. The project will be built on the Valley of Fire Entrance Road by the Muddy Mountains Wilderness Area . It will remove one quarter of the entire habitat of Threecorner milkvetch, one of the rarest plants Nevada, and cover part of the Old Spanish Trail. 

The BLM has only offered 4 alternatives to choose from and the only one we can support is the No Action Alternative. All other three alternatives would allow industrial development on the full 11 square miles. The BLM will not review a reduced footprint alternative or an alternate location alternative. The BLM will not consider the potential to use solar energy on the rooftops and other infrastructure in booming and already developed Las Vegas, Nevada.

The Proposed Action would involve solar development utilizing traditional development methods, which include disk and roll to remove vegetation in the solar array areas.

The Hybrid Alternative would involve solar development utilizing traditional development methods in solar array areas on approximately 2,500 acres, and mowing that leaves vegetation stumps and natural land contours in place on the remaining solar array areas on approximately 4,600 acres.

The All Mowing Alternative would involve development of the facility utilizing only mowing in solar array areas. Where mowing is utilized under each alternative, desert tortoises would be reintroduced into the remaining habitat in the solar array areas after the completion of construction. After so much disturbance to the Mojave Desert habitat we doubt this will help tortoises.

Here is the official  Federal Register notice  for the Draft Environmental Impact Statement for the Gemini Solar Project. We will be following closely.

The Draft Environmental Impact Statement for the Gemini Solar Project can be downloaded  >>here .

^ Before and After? The photo on the left is part of the 7,100 acre Gemini Solar proposed project site. The photo on the right is the construction phase of the 1,700 acre Stateline Solar Project near Primm, Nevada in 2014.
Degrading Desert Tortoise Habitat on Public Lands
T he proposed Gemini Solar Project is located in the Northeastern Mojave Recovery Unit for the federally threatened Desert tortoise (Gopherus agassizii) . Even with adequate monitoring and vegetation mowing, the development and operation will likely kill, injure and displace individual desert tortoises.

The BLM estimates that 215 adult tortoises and over 900 juveniles will be killed or displaced by this project. Even the most experienced desert tortoise biologists end up missing a significant amount of hatchlings and juveniles. Basin and Range Watch expects Gemini Solar to cause significant desert tortoise mortality if fully approved.
All tortoises would be excavated from their burrows and relocated out of the way of development or translocated to locations up to 5 miles away. Not all desert tortoise translocation projects go well. Problems that result from translocation of desert tortoises include:
  • 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.
  • 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 former burrows and water sources. Tortoises are ectothermic (cold-blooded) and do not internally regulate their body temperature that well.
  • Lack of Reproductive Success - A recent Smithsonian study found that translocated male desert tortoises are not reproducing.
Two examples of desert tortoise translocations that didn't go well are the 2008 Ft. Irwin National Training Center project and the 2013 Moapa Solar Project

Unlike in the West Mojave Desert, this population segment of the desert tortoise is doing quite well when left alone, but the desert tortoise is seeing a big decline throughout its range.

The desert tortoise is now included in the global list of the top 50 turtle and tortoise species at greatest risk of extinction.

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.)

In Nevada alone, three major solar projects have been built in the region and Clark Country is asking Congress to turn over 40,000 acres of public lands, all tortoise habitat, to developers.

Vegetation Mowing - The Lesser of Two Evils is Still Evil

The BLM is attempting to create a new precedent where tortoises and solar panels can supposedly co-exist. This would include mowing vegetation down, but allowing it to regrow and than allowing tortoises to re-enter the site. But the BLM is attempting this largely experimental plan on 11 square miles with no peer-reviewed scientific evidence that mowing vegetation works for the long-term for the desert tortoise populations. The BLM is basing this plan on the recenty constructed 80 acre Pahrump Solar Project where only 4 desert tortoises were found. That project allows tortoises to re-enter the project site though small doorways in the fence. All vegetation was mowed down, but shrubs have started to regrow. But none of the returning annual vegetation is native. The Pahrump Solar Project has proliferated the growth of brome grass, split grass and Russin thistle all over the site. All of these species are known to be less nutritional for the tortoise. Plus Gemini Solar would be almost 100 times larger than the Pahrump Solar Project and hundreds more desert tortoises would be impacted. Shade from solar panels would keep temperatures cooler for tortoises coming out of hibernation in late winter and spring, when tortoises are seeking warm ground to thermoregulate.

Crushing Desert Ecosystems

All mowed desert vegetation on the entire 11 square miles would be shredded by 20,000 pound GT-25XP Heavy Duty Mulchers . No vegetation would be allowed to regrow over 24 inches. While the BLM has said this would not be much of an impact, it is essentially allowing vehicles far more heavy than any recreational off highway vehicle to crush this habitat. All life left on this site, from biological soil crusts to kangaroo rats to microphyll woodlands, will be crushed and shredded. Any animals not crushed will most likely be deafened by the noise. Vehicles would need to re-enter the site on a regular basis to conduct maintenance. While maintenace would be monitoired, It is not clear how tortoises would be protected from all of this on site traffic.
*The GT-25XP Heavey Duty Mulcher
^Desert tortoise biologist moving and checking a desert tortoise
^Invasive annual grass revegetating the Pahrump Solar Project
^Desert Tortoise (Gopherus agassizii)
^Map of live tortoises found on the Gemini project site
Loss of Wildlife and Rare Plants
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, California kingsnake, threecorner milkvetch, Nye milkvetch, American badger, western banded gecko, and beavertail cactus to name just a few. 
^Threecorner milkvetch   (Astragalus geyeri var. triquetrus) (photo by Jim Andre)
^Biological soil crusts are undisturbed on the project site
^Mojave aster ( Xylorhiza tortifolia)
^Desert tarantula ( Aphonopelma chalcodes)
^Mojave Desert Sidewinder ( Crotalus cerastes )
American Badger ( Taxidea taxus)
^American kestral (Falco sparverius)
^Desert Iguana (Dipsosaurus dorsalus)
^ Desert bighorn sheep ( Ovis canadensis nelson ) Signs of sheep have been found on the project site. This would be a winter foraging area.
Threecornor Milkvetch and Moapa Dace
The threecorner milkvetch is a rare, slender annual forb with bi‑pinnate leaves in the pea family that grows in sandy soils in a limited region of the Mojave Desert of southeastern Nevada and adjacent Arizona. Threecorner milkvetch is one of the rarest plants in Nevada. It is endemic to specific soils found only within a localized area of southeastern Nevada and adjacent northwestern Arizona. It is very rare due to its limited distribution and low population numbers. It depends on sandy substrates and the solar project devlopment could block the cooridor of windblown sand that creates habitat for Threecorner milkvetch.

The Gemini Solar Project would remove over 700 acres or about one quarter of the known habitat for Threecorner milkvetch. The BLM will not even consider an alternative that removes this small portion of the project site. The BLM plans to control invasive weeds on the milkvetch habitat by using herbicides. But this of course, will impact rare plants as well.

Basin and Range Watch submitted a petition with the Fish and Wildlife Service to list Threecorner milkvetch as Endangered under the Endangered Species Act.
The Gemini Solar Project will need to use 2,200 acre feet of water for construction and 20 acre feet per year for maintenance. The water would be extracted though wells from California Wash. The project site falls within the California Wash Hydrologic area. The water originates from carbonate rocks under Coyote Springs Valley. The California Wash basin feeds Muddy Spring in the Muddy River which is habitat for the Moapa Dace . These rare desert fish inhabit the Warm Springs area which encompasses 25 springs in the upper Moapa River including Muddy Spring. While water use would be monitored, this is a frivolous use of water that should be reserved for habitats for rare species --not solar panels that can go on rooftops.
Avian Lake Effect
^Copper Mountain Solar Project near Boulder City, Nevada
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 Gemini Solar Project would be built within 15 miles of the Muddy River, within 25 miles of Lake Mead and the Colorado River, and 40 miles from the Pahranagat National Wildlife Refuge, and has the potential to attract waterbirds.
Cultural Resources
The Old Spanish Trail was in use between 1829 and 1848. Spain searched for a trade route between New Mexico and California in the 1700s. Traders with mule caravans stopped here as early as 1829, using the area as a link from the abundantly watered flowing springs of Las Vegas -- "The Meadows."

Congress designated the area as part of the Old Spanish Trail in 2002. Several segments in Nevada are listed in the National Register of Historic Places.

The California Crossing of the Old Spanish Trail represents one of the places where the trail split into two alternate routes. The trail segment through the Project area along the east fork in the California Wash is considered

The Trail was based on a prior Native American route.

The National Historic Trails Project identified a 1,781-meter segment of the Old Spanish Trail within the area of predictive modeling that placed the trail roughly along the California Wash in the project area.

Developing a massive solar industrial project will destroy the historic character of the region.


Impacts to Visual Resources

An 11-square-mile development would be visible for great distances. The visual contrasts would be visible from over 25 miles away. Covering that much land with solar panels would completely change the entire landscape. The project would be visible from the Muddy Mountains Wilderness Area (on the right), the Bitter Springs Backcountry Byway, the Old Spanish Trail, the Valley of Fire Road, the Desert National Wildlife Refuge, California Wash, and the White Domes Road Scenic Byway.

The Proposed Action is within Visual Resource Management (VRM) Class III area and would require an amendment to the 1998 Las Vegas Resource Management Plan to downgrade to Class IV objective. The VRM Class IV objective allows for management activities that require major modifications of the existing landscape character, such as the transmission facilities associated with the project.
^The area of analysis for visual resources is the Project’s visual sphere of influence (VSOI), which is the extent to which the Project could visually degrade the visible landscape. The threshold for VSOI is the viewshed within approximately 15 miles (24 kilometers) from the Project area; however, potential adverse impacts were considered 25 miles away.

The BLM has made visual simulations called Key Obervation Point (KOP's). But these simulations in the EIS fail to completely capture the full impacts in the KOPs.
^One of the many Key Observation Point simulations from BLM. They have undermined the actual impacts, and minimized the visual impacts in this simulation.
^Above is the Silver State South Solar Project near Primm, Nevada. This is what a solar project actually looks like. Our photo, not a simulation.





>To the right is the view from the project site looking northwest from the Valley of Fire Road.



<Left: Natural limestone arch along the Bitter Springs Backcountry Byway



>Right: Sandstone bluffs along the Bitter Springs Backcountry Byway
A Reasonable Alternative








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. ” Building the remote Gemini Solar Project will require cooling of the batteries on site and they may use air conditioning to do so. How efficient is this?
Gemini Solar will have an on-site battery storage facility which will have to be cooled with air conditioning in the summer. The batteries will most likely need to be cooled during hot summer nights when the sun is not shining. This will require a "parasitic load" off the existing power grid to run these air-conditioning units, to cool the battery banks in the hot desert. Is this the most efficient way to store energy - in batteries?
Sample Letter to Send to BLM
The BLM will be accepting comments on the Draft Environmental Impact Statement until September 5th, 2019.










Comments can be sent to: blm_nv_sndo_geminisolar@blm.gov , faxed to (702) 515-5023 or mailed to: Gemini Solar Project, Attn: Herman Pinales, BLM Las Vegas Field Office, 4701 N Torrey Pines Drive, Las Vegas, NV 89130.

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 select a No Action Alternative for the Gemini Solar Project and designate the region a large-scale solar energy-free zone with a Plan Amendment to the 1998 Las Vegas Resource Management Plan.

Approval of the project would result in the removal of over 7,100 acres or 11 square miles of good quality desert tortoise habitat. The desert tortoise is Federally Threatened and is losing habitat throughout its range. It may need to be up-listed to Endangered status with the cumulative developments happening on its habitat.

There are no peer reviewed studies that show that vegetation mowing and allowing desert tortoises to re-enter a site with solar panels has long-term success. There has never been a vegetation mowing project that is this large.

Vegetation mowing will have very big impacts. All vegetation will be cut. Burrowing animals would be killed and deafened. Many of the estimated 900 juvenile desert tortoises would be missed and killed. Biological soil crusts would be destroyed. Invasive annual weeds would move in on the mowed site.

Tortoises would be allowed to re-enter the site. Tortoises could be killed by operation and maintenance activities because vehicles will enter the habitat for maintenance. Shade from solar panels could inhibit tortoises coming out of hibernation in late winter and spring.

The project would remove 700 acres or one quarter of the habitat for Threecorner milkvetch, one of Nevada's rarest plants.

A supplemental EIS is needed because the BLM has not fully reviewed the full range of alternatives. The BLM should review off-site alternatives. The BLM will only review three action alternatives, all which would be 11 square miles or over 7,000 acres. Eighteen Solar Energy Zones were designated on BLM lands in the west in 2012. The Zones were created to site energy in areas that have lesser conflicts than the Gemini Solar site. The BLM should review a reduced footprint alternative which minimizes the impacts to the desert tortoise. The BLM should review an alternative that cuts out the 700 acres of Threecorner milkvetch habitat. This is one of the rarest plants in Nevada. The BLM should review a distributed generation alternative.

The project site lies on one of the most undisturbed habitats in the Mojave Desert. It contains biological soil crusts and a large list of native Mojave Desert species. It is home to sensitive species like the burrowing owl, kit fox, several rare milkvetches, the American badger and the Gila monster.

Rare microphyll woodland with catclaw acacia and desert willow will be destroyed. These groves of deep-rooted desert trees harbor numerous bird species, and should be conserved, not shredded.

The project would be built on part of the historic Old Spanish Trail. The massive build-out of solar panels, new roads and transmission lines will permanently destroy the historic and wild character of the area.

The BLM should not downgrade the region's Visual Class to VRM Class IV. The project would destroy the view and experience from several popular locations including the Muddy Mountains Wilderness Area, the Valley of Fire Road, and the Bitter Springs Backcountry Byway. The project would be on a popular scenic route that tourists take to the Valley of Fire State Park and Muddy Mountains Wilderness Area. Compromising the visual resources of the region has the potential to impact tourism in Nevada. A large-scale solar project of this size only creates about 15-20 full time jobs.

Several thousand acres of land are being developed in the Las Vegas Valley for new housing. The amount of space located on the rooftops and over parking lots provides a more efficient alternative for solar panels, and eliminates the need for costly transmission lines. This easily justifies a No Action Alternative for the Gemini Solar Project."
Basin & Range Watch
PO Box 70, Beatty 
NV 89003