Basin and Range Watch
Defending the Desert

Action Alert
April, 2020
Yellow Pine Solar Project will Shred 92,930 Mojave Yuccas
The Yellow Pine Solar Project will develop 3,000 acres (4.5 square miles) of old growth Mojave Desert in the South Pahrump Valley. The project is so large, the the BLM has estimated that 92,930 Mojave yuccas will need to be shredded for the project. That is about 30 Mojave yuccas per acre. The Draft Environmental Impact Statement for the Yellow Pine Solar Project on Bureau of Land Management (BLM) lands in southern Nevada was released in March. Comments are due on May 4th, 2020. Several biological and cultural resources will be impacted by this project.

The Mojave yucca (Yucca schidigera) also known as the Spanish dagger is an evergreen shrub with bayonet shaped leaves and a central woody trunk. It is one of the iconic plants found from mid to high elevations in the Mojave Desert. Mojave yuccas have several stems and can form extensive clonal rings. Mojave yuccas can live to be 600 or more years old and there are several very old growth yuccas on the proposed Yellow Pine Solar site. They grow an average of 2 centimeters to one inch per year and can grow to be over 20 feet tall. They grow at elevations between 2,000 and 5,000 feet and depend on rainfall averages of 6 inches or more per year.

Mojave yuccas flower every spring and usually produce fruit by June. The Mojave yucca is pollinated exclusively by the Yucca moth ( Tegeticula yuccasella ) which lay their eggs on flowers after pollination. The developing seeds in turn, p rovide food for the moth larvae.

The Mojave yucca plays an important ecological role in the desert ecosystem. Several wildlife species brows on the leaves and flowers. Ground squirrels, woodrats and several species of birds eat the seeds and woodrats disperse the seeds extensively. The plants themselves provide nesting opportunities for birds like cactus wrens and the bases provide shade, shelter and burrowing options for desert tortoises. The Mojave yucca is also a great habitat for the desert night lizard (Xantusia vigilis ) .

Traditional uses by Native Americans include making soap from the roots, making baskets, rope, sandals and hats from the fibers and eating fresh and dried fruits.
^Flowering Mojave yucca
^Yucca moth
Desert tortoise ( ( Gopherus agassizii)
^Desert night lizard
^Loggerhead shrike ( Lanius ludovicianus)
^Desert tortoise burrow on project site

From Page 3-86 of the Draft Environmental Impact Statement : "Construction impacts to cactus- yucca would be the direct removal of approximately 106,771 total cactus and yucca, which is 67% of the yucca and cactus within the project area. This percentage is based on cactus and yucca density surveys performed for the project. Most of the species removed would be Mojave yucca, totaling approximately 92,930 individuals. " 
This is how all Mojave yuccas will be destroyed on the Yellow Pine Solar site. The video is from the Ivanpah Solar Project in 2010. While yuccas and cactus are considered "Forest Products" worth preserving, there are too many to economically salvage, so a mass elimination is planned.
^ Before
^ After
The Yellow Pine Solar Project would be located on approximately 3,000 acres of BLM managed public lands. Nextera Energy proposes to construct and operate a 500 megawatt solar energy project with battery storage and GridLiance West, LLC has applied for a right-of-way on public land to construct, and operate a 230-kilovolt Trout Canyon Substation and associated 230-kV transmission line. The Bureau of Land Management is reviewing two action alternatives - the traditional disc and roll clearing methods and the all mowing alternative. The mowing alternative is supposed to lessen the impact, but would grind all plants to the roots and only allow them to grow back between 18 and 24 inches. Both alternatives will result in a major loss of Mojave Desert biological diversity.
The top left photo shows the Sunshine Valley Solar Project located in Amargosa Valley, Nevada. All vegetation has been "mowed" or ground down to the roots. The top right photo shows the Desert Sunlight Solar Project in Riverside County, California using traditional clearing methods.
^Desert tortoise
^Large-scale solar development in Dry Lake Valley, Nevada
^Biological soil crust
^Mojave aster ( Xylorhiza tortifolia)
Desert Ecosystems Store C02 . Removing them Makes Climate Change Worse
The journal Nature Geoscience found that closed basins in deserts store carbon. Areas that have no external hydrologic drainage in arid regions store carbon.

The Desert Underground is a recent publication by Robin Kobaly. It is a wonderful book that illustrates the critical importance of biological soil crusts and their role in sequestering C02.

"Research around the world is showing that the biggest contributors to soil stability in deserts are the smallest of microorganisms. Tiny microbes hold our desert landscape together. The valuable role of hidden microorganisms in keeping our air cleaner, preventing dust storms, controlling erosion, and helping us reduce carbon dioxide levels in our atmosphere is enormous, but that role is mostly overlooked when we make land-use decisions in our desert."
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/yellow Pine Solar Project will require cooling of the batteries on site and they may use air conditioning to do so. How efficient is this?
Sample Letter to Send to BLM

The BLM will be accepting comments on the Draft Environmental Impact Statement until May 4th, 2020.

Comments can be sent to:
Fax: 702-515-5023
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 Yellow Pine 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 3,000 acres or 4.6 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.

Based on population estimates, approximately 53 adult desert tortoises, 276 subadults or juveniles, and 69 hatchlings are anticipated to be displaced or killed by project-related construction activities via translocation.

Vegetation mowing will have very big impacts. All vegetation will be cut. Burrowing animals would be killed and deafened. Many of the estimated 398 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 destroy 92,930 Mojave yuccas, many hundreds of years old.

A supplemental EIS is needed because the BLM has not fully reviewed the full range of alternatives. The BLM should review off-site alternatives. 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 Yellow Pine Solar site. The BLM should review a reduced footprint alternative which minimizes the impacts to the desert tortoise. 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, the American badger and the Gila monster.

The project would be near 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 region's Visual Class is VRM Class III. The management objective of VRM Class III is to partially retain the   character of the landscape. This should require a Land Use Plan Amendment for the 1998 Las Vegas Resource Management plan and give the public a full 90 day comment period.

A large-scale solar project of this size only creates about 5-15 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 Yellow Pine Solar Project."
Basin & Range Watch
PO Box 70, Beatty 
NV 89003