Basin and Range Watch
Defending the Desert

July 19th, 2022
Oppose the Golden Currant Solar Project!
Sample Letter to Send Below
The Bureau of Land Management is asking for public input on the Golden Currant Solar Project proposed for approximately 4,364 acres of BLM-managed public land located in Clark County, Nevada, approximately five miles southeast of Pahrump and 26 miles west of Las Vegas. State Route 160 is less than two miles northeast of the site. The public input period will close August 5, 2022. The BLM will host two virtual information forums – July 19 and 20. You can register here.

Nobel Solar, LLC has applied to the BLM Las Vegas Field Office for a right-of-way grant for the construction of a proposed solar facility and interconnection to the transmission system. Nobel Solar is proposing the construction and operation of the Golden Currant Solar Project, a photovoltaic solar power project with battery storage on BLM-land designated as a solar variance area in Clark County. The project was formerly called Sagittarius Solar.

If fully built out, the project would impact nearly 7 square miles of Mojave Desert public lands and habitat.

The project will be built less than 2 miles from the Old Spanish National Historic Trial. Nearly 50 percent of the project would be built on rugged badlands topography cut by deep canyons. Industrial construction will pulverize badlands into bad fugitive dust. The project would be built adjacent to the Stump Spring Area of Critical Environmental Concern - set aside to protect wetlands and cultural sites. There are mesquite woodlands on the project site and associated wildlife. The project would impair access to the Front Site Road and Cathedral Canyon. The project would create unmitigable impacts to the viewshed and is being reviewed through an outdated BLM Resource Management Plan that provides no protection to visual resources. 

The BLM has already approved the Yellow Pine Solar Project with grave impacts to the desert tortoise and has plans to sacrifice a total of 18,000 acres (nearly 30 square miles) for 5 solar projects in this part of the Mojave Desert.

^ Before and After? Left, habitat example for about 50 percent of the Golden Currant Solar Project. Right, industrial clearing for the Blythe Solar Project in Riverside County, California
Degrading Desert Tortoise Habitat on Public Lands
All tortoises would be excavated from their burrows and translocated to the Stump Spring Translocation Area across the Tecopa Road, and the Trout Canyon Translocation Area. Recently, the translocation for the adjacent, approved Yellow Pine Solar Project resulted in the predation of 30 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:
  • 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.
  • 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 other examples of desert tortoise translocations that didn't go well are the 2005 Ft. Irwin National Training Center project and the 2013 Moapa Solar Project.

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.)

^One of nearly 30 tortoises killed by badgers for the Yellow Pine Solar Project
^Desert tortoise"
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.
^Clearing for Yellow Pine Solar Project, NV (photo by Shannon Salter)
^Clearing for Sunshine Valley Solar Project, NV
Vegetation mowing for the Inavpah Solar Project in 2010
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.

Much 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.
Left and Right: Badlands topography on Golden Currant 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, Parish club cholla, Mojave yucca, mesquite, California kingsnake, Pahrump buckwheat, American badger, western banded gecko, and beavertail cactus to name just a few. 
^Parish's club-cholla (Grusonia parishii)
^Biological soil crusts are undisturbed on the project site
^Desert Dandelion (Malacothrix glabrata)
^Praying mantis on mesquite
Mojave yuccas (Yucca schidigera) can live to be 200 to 500 years old and provide habitat, shelter and food for multiple species. Over 90,000 are being destroyed for the Yellow Pine Solar Project.
^Mojave Desert Sidewinder (Crotalus cerastes)
American Badger (Taxidea taxus)
^Desert tortoise burrow on project site
^Phainopepla (Phainopepla nitens)
^Long nosed leopard lizard ( Gambelia wislizenii)
Avian Lake Effect
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 Golden Currant Solar Project would be built within 1 mile of Stump Spring and 30 miles from the Amargosa River and has the potential to attract birds.
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 Trail was based on a prior Indigenous route. The valley has been home to the Paiute and Shoshone peoples for thousands of years, and the valley still holds cultural importance.

The trail goes through the Pahrump Valley and developing 5 massive solar industrial projects in the area will destroy the historic character of the region. Golden Currant Solar would be under 2 miles from the Old Spanish Trail.
Impacts to Visual Resources - Outdated Resource Plan

A 7-square-mile development (right) 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 Mt Charleston, Highway 160, California wilderness areas such as the Kingston Range and the Nopah Range and will create a very unnatural change to the landscape.

The BLM mostly manages the Viewshed on the site as a resource to be developed based on an outdated Resource Management Plan from 1997 that is scheduled to be updated next year. Much has changed since 1997 including public land visitor use numbers. The updated plan could "upgrade" the viewshed management to discourage developments this massive. The BLM is planning a Nevada-Wide revision of all Resource Management Plans in 2023 and should stop all review for Golden Currant until that happens.

Much of the project site has also been declared a High Conflict Area due to its long distance visibility from parts of Death Valley National Park (circled in red below).
Top: Scenic landscape on Golden Currant Solar Project site

Bottom: Silver State South Solar Project near Primm, Nevada.
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.

The close proximity to Stump Spring and presense of mesquite shows there is a high water table on much of the project site. The BLM has determined that the project has a certain amount of high conflicts and will ask the developer to avoid much on the mesquite on the site, but as you can see from their map, they will surround delicate washes and canyons with thousands of industrial solar panels. The BLM appears to believe that these conflicts can be resolved with mitigation. The only way to avoid these conflicts is to reject this application. Under the Clark County Multi-Species Habitat Conservation Plan, mesquite habitats on public lands are required to be avoided.
^Map of the project created by the developer showing washes that would be avoided. The project site is fragile and thus it will still be a disaster.
Sample Letter to Send to BLM
The BLM will be accepting comments on the Golden Currant Solar Project application until August 5th, 2022.

Written input can be submitted via email to: [email protected]; please include “Golden Currant Solar Project Variance” in the subject line of the email.

Additionally, public input can be mailed to BLM Southern Nevada District Office, Attn: Golden Currant Solar Project Variance, 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 reject the application for the Golden Currant Solar Project.

Approval of the project would result in the removal of tens of thousands of Mojave yuccas and cacti. Many of the plants are hundreds of years old and provide habitat and food to the wildlife of the area.

The project site is located in important desert tortoise habitat. When desert tortoises were moved off the Yellow Pine Site in May, 2021, just to the east of the proposed Golden Currant project site, nearly 3 times more tortoises than predicted were found and 30 of the 139 moved were killed by hungry badgers in drought conditions . Please do not allow a repeat of the recent desert tortoise disaster that took place on the Yellow Pine Solar site. Desert tortoises are protected under the Endangered Species Act and are seeing sharp declines throughout their range.

Nearly 50 percent of the project site is made up of badlands eroded by canyons and over a 5 percent slope. This topography would need to be leveled to accommodate solar panels.

The project site contains old biological soil crusts and desert pavement that is about 100,000 years old. Removal of the desert surface and clay-based badlands topography will result in uncontrollable fugitive dust. This will impact public health in nearby Pahrump, Nevada and Charleston View, California.

The project site contains hundreds of rare Parish Club Cholla, mesquite, kit fox, desert iguana, burrowing owl, coyote and several other species. Millions of living organisms would be killed in the construction of the project.

The project will probably require up to 1,200 acre-feet of water for construction and additional acre-feet each year for operation. The Pahrump Valley Basin is over-drafted by 12,000 acre-feet.

The project will destroy habitat for mesquite and associated species, a unique groundwater dependent habitat.

Solar projects can mimic lakes and will often kill a number of bird species. The project would be in the vicinity of Stump Spring and the Amargosa River which attract several birds.

The project would be located less than 2 miles from the Old Spanish National Historic Trail. Developing an industrial eyesore so close to the trail will destroy the historic character of the region.

The project will cut off access to over 7 square miles of public land and be visible from recreation trails, Highway 160, Mt. Charleston, the Kingston Range Wilderness in California and the South Nopah Range Wilderness also in California. Public access would be impacted on the Front Site Road and to Cathedral Canyon.

The Bureau of Land Management should not even consider reviewing this application until the Southern Nevada Resource Management Plan can be updated. The plan is outdated by 25 years. Visitor use to the Tecopa Road has increased in this time and the visual resources along with other resources need to have better protection.

To preserve diverse Mojave Desert habitat on public lands and the quality of life in Pahrump, Nevada, BLM should reject the application for the Solar Project."

(Your name and address here)
Basin & Range Watch
PO Box 70, Beatty 
NV 89003