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P.O.

Box 24, Joshua Tree, California 92252


www.mbconservation.org

March 22, 2018

BLM-California State Director


2800 Cottage Way, Room W-1623
Sacramento, CA 95828 Submitted by email to: BLM_CA_DRECP@blm.gov

Re: DRECP LUPA Plan Amendments and Scoping Comments

Dear Director Perez,


We oppose amending the Desert Renewable Energy Conservation Plan and
stand by the protections gained in the DRECP for millions of acres of California
Desert conservation and recreation lands.

The MBCA actively pursues its mission to preserve the economic and environmental welfare of
the Morongo Basin, our neighboring desert communities, and, by extension, the California
Deserts. To this end we were actively involved throughout the 8 years of the DRECP
development and will continue to critically evaluate proposed projects. MBCA advocates for
and educates citizens and decisions makers on the benefits of personal choices, roof-top solar
located at the point of use, and CCAs as pathways toward zero net energy. 1

We are one among many organizations, communities and individuals2 alarmed by the notice to
amend the CDCA (DRECP LUPA) after only 18 months. We do not support the re-opening of the
DRECP at this time. We are not sympathetic to Executive Orders to promote energy
independence and reduce barriers to capital investment on even more of our public lands in
the California Desert. The BLM’s request for comments on how land designations identified in
the plan might affect development of solar, wind, and other renewable energy resources is an
obvious open door for RE developers and local governments seeking to avoid the restrictions
and conservation actions attached to development on federal lands under NEPA.

1
http://www.mbconservation.org/zero_net_energy_event_content
2
Reference the DRECP scoping comment letter from several High Desert community groups and residents,
including Lucerne Valley Economic Development Association, Homestead Valley Community Council and Newberry
Springs Economic Development Association, dated March 22, 2018.
2
MBCA DRECP Comments
March 22, 2018

We are aware that California has passed its mandated AB32 greenhouse gas production goals
for 2020 and suffers from an oversupply of solar energy.3 Opening conservation lands to more
utility scale renewable energy (RE) will only benefit the bottom line for developers and burden
rate payers without advancing California’s climate change goals.4 Any addition to the 20,000
MW utility scale RE production that the DRECP already provides for would industrialize the
desert with no possibility of restoration to the original functioning ecosystems rich with a
diversity of life not recognized in the environmental reports supporting this plan.

MBCA Board members attended three of the eight scoping sessions and, in this letter, answer
the request to highlight issues and concerns with new science and experience.

Issue and concern: The increase in regional PM10 with each utility solar installation on the
sand transport paths (STP) that trace the low valleys between the desert mountain ranges.

1. The BLM DRECP acreage allocated for RE in relation to the total acreage of
BLM land designated for other uses in the planning area is deceiving in its
presentation.
What are the acreage allocations and what do they signify?
• BLM’s DRECP Planning Area = 10.8 million acres;
• BLM’s DRECP makes 800,000 acres (7%) of that total acreage potentially available for
renewable energy development, of which 388,000 (4%) are designated as
Development Focus Areas. DFAs are considered to have low resource conflict and are
fast tracked;
• The ROD allocated 6.5 million acres (60%) as conservation areas including CD National
Conservation Lands, ACECs, wildlife allocations, and National Scenic and Historic Trail
Corridors, which limit or are closed to renewable energy;
• The ROD designated 3.5 million acres (33%) as Special or Extensive Recreational
Management Areas (SRMA, ERMA), which are also generally closed to renewable
energy. (Bold added)

Based on these figures the allocations appear to favor conservation leaving RE developers with
the short straw. The conservationists get a whopping 60% while the developers get only 4%. No
wonder they are upset. But, could this be an equivalency problem - are the 10.8 million acres
flat and uniform like a billiard table? Or something else? They are something else.

A USGS study of 10 million acres in the Mojave Desert from Lancaster and Mojave on the west
to Jean, NV, and Goffs, CA on the east evaluated the potential lands for solar energy
installation. “Solar installations require low-gradient smooth topography…About 48% of the
entire area is less than 5% slope (4.8 million acres), and 8.3% is less than 1% slope (830,000
acres), the favored slope category. For this lowest-slope category, deposits underlying about

3
http://www.caiso.com/informed/Pages/ManagingOversupply.aspx
4
http://www.latimes.com/projects/la-fi-electricity-solar/
3
MBCA DRECP Comments
March 22, 2018

98% (813,000 acres) of the area are either mixed eolian-alluvial origin or are fine-grained
alluvial deposits, and thus susceptible to eolian dust and sand transport, especially after
disturbance. In addition, in this low-slope category, 89% (738,700 acres) of the area is
susceptible to flooding, based on the age and geomorphology of alluvial deposits. These maps
are examples of several we present for decision-making with respect to hazards and ecological
attributes in the face of climate change.” 5 (Bold added and acreage calculated by commenter)

Based on the topography and surficial


geology used in mapping the area,
BLM’s DRECP allocation of 800,000
acres potentially available for RE
represents the favored 1% slope.
However, we know that 98% or
784,000 acres of that favored slope
category is susceptible to eolian dust
and sand transport, especially after
disturbance. The DFA allocation of
388,000 acres is only 50% of the Figure 1 Mojave Desert topography - Google Earth
favored 1% slope but most, if not
essentially all, is on fine grained alluvial deposits, the very stuff of Particulate Matter 10, better
known as DUST.

Going back to the headline: are the acreages allocated for conservation, recreation, and energy
development deceiving as presented in the DRECP? Yes, because the percentages are provided
without topographic context. Context informs us that the DFAs are allocated on acreage that is
1% slope or less. The landscape has no more to give.

2. The soil characteristics underlying the acreage allocated for renewable


energy development are not fully described in the DRECP as to the high
danger of eolian dust, especially after disturbance.

The DRECP LUPA and EIS air quality chapters are equivalent to the CA.Gov Driver Handbook,
you get all the rules and regulations as well as some driving tips but then you have to learn by
doing. It is true that each renewable energy project comes with its particular challenges to
solve, but we know, based on USGS mapping, soil studies, and now extensive experience, that
virtually all of the 1% and less slope areas, 388,000 acres, within the DFAs will blow dust when
disturbed. That information should be front and center along with warnings about the health
effects of eolian dust now and as it worsens with climate change. Currently, with the exception

5
D.R. Bedford and D.M. Miller, Assessing the Geology and Geography of Large-Footprint Energy Installations in the
Mojave Desert, California and Nevada, in Natural Resources Needs Related to Climate Change in the Great Basin &
Mojave Desert: Research, Adaptation, Mitigation, U.S. Geological Survey Workshop, April 20-22, 2010, Las Vegas,
Nevada, Poster,
4
MBCA DRECP Comments
March 22, 2018

of the Owens Dry Lake Project,6 we apparently lack usable data to guide monitoring and
mitigation standards and practices. The Mojave Desert Air Quality Management District
(MDAQMD) is using a fugitive dust rule,7 adopted in1996, that applies to construction and
demolition activity, heavily traveled publicly maintained unpaved roads, weed suppression
activity, limestone processing activity in the Lucerne Valley area, and dust emitting activities on
BLM dirt roads. This was long before the time of RE projects covering hundreds to thousands of
acres in size, denuded and leveled with little or no chance of recovery following
decommissioning.

3. Sand Transport Paths (STP) described and visualized.

This DRECP Gateway


map illustrates the
sand and dune
systems of the
Mojave Desert.
These systems, as
described by the
USGS, are either of
mixed eolian-alluvial
origin or are fine-
grained alluvial
deposits, and thus
susceptible to eolian
Figure 2 Data Basin Gateway Map used in DRECP to illustrate Sand and Dune Systems dust and sand
transport, especially
after disturbance. What the map above does not visualize is the contiguous linear dunes
stabilized by vegetation. The stabilizing vegetation is usually either a Big Galleta Grass-Creosote
Bush community or salt bush scrub. The green circle shows the origin of the Clark’s Pass STP in
the Joshua Tree basin. With
the construction of 3 solar
energy facilities in 2014
(Cascade Solar 150 acres,
Leer Avenue Solar 120
acres, and Indian Trail Solar
80 acres) residents
downwind discovered they
were living on a newly
disturbed STP. The STP
continues toward Blyth and
Figure 3: Sand Transport Path from Joshua Tree toward the Colorado River the Colorado River.

6
https://www.arb.ca.gov/DRDB/GBU/CURHTML/R433.PDF
7
MDAQMD Rule 403.2 Fugitive Dust Control for the Mojave Desert Planning Area is on the Master Rule
Development Calendar 2018.
5
MBCA DRECP Comments
March 22, 2018

The map 8 in Figure 4 is of the same area but includes stabilized as well as active dunes. The
source playas are the gridded pattern with name in parenthesis. The active and relatively
unvegetated dunes, such as the Kelso Dunes (KD) are outlined with an open dotted pattern. The
inactive, vegetated dunes have the dense pattern.

Figure 4: Map of Sand Transport in the Mojave Desert from Zimbelman

Solar Projects

1.Indian Trail
80 acres

2. Lear Ave
120 acres
1
2 3. Cascade Solar
150 acres
3

Figure 5: Area within Green circle in Figure 4- Sand Transport Path in the Morongo Basins

8
Sand Transport Paths in the Mojave Desert, Southwestern United States. J.R. Zimbelman, S.H. Williams, V.P.
Tchakerian. In Desert Aeolian Processes. Edited by J.R. Tchakerian. 1995.
https://pdfs.semanticscholar.org/8659/019534c2b1a2192e83458381b86a43b443b3.pdf
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MBCA DRECP Comments
March 22, 2018

Figure 5 is the area within the Green Circle in Figure 4. The 3 red stars by Copper Mountain are the solar
fields described under Figure 2. Before being scraped and graded sand was stabilized by the roots of the
Big Galleta grass. The figure below demonstrates the fine work done by the roots of the grass. This grass
is not threatened or endangered on any federal or state list and receives little notice. It is the function of
this grass growing with the neighboring creosote and other species that must be protected – not only
for the air breathing humans but also for the desert tortoise and fringe-toed lizards that may inhabit this
environment.

Figure 6 Linear dune stabilized by Big Galleta Grass in the Joshua Tree basin.

The prevailing winds in the Mojave Desert Air Basin (MDAB) are out of the west and southwest.
The MDAQMD covers the majority of the MDAB. The MDAB is an assemblage of mountain
ranges interspersed with long broad valleys that often contain dry lakes. Many of the lower
mountains which dot the vast terrain rise from 1,000 to 4,000 feet above the valley floor. The
mountains edge the valleys forming wind channels. One of the lesser wind channels lies
between the San Bernardino Mountains (Lucerne Valley) and the Little San Bernardino
Mountains (the Morongo Valley). 9

Figure 7 below shows the dust rising on March 28, 2016 from Cascade Solar, the 150-acre PV
solar facility in the Joshua Tree basin within the Morongo Valley. This solar facility was
completed in 2014 so the soils have not stabilized as predicted in planning documents. Note, in
the foreground, where the soil is undisturbed and stabilized there is no dust rising.

9
MDAQMD CEQA and Federal Conformity Guidelines August 2016 Planning, Rule Making and Grants Section. Air
Monitoring Section http://mdaqmd.ca.gov/home/showdocument?id=538
7
MBCA DRECP Comments
March 22, 2018

Figure 7: Dust rising off Cascade Solar on 3/28/26

Lucerne Valley is
aligned with the
Morongo Basin as
stated above. Winds
out of the NW
connect us. The
Figure 4 map shows
Lucerne Dry Lake as
a source area for the
Morongo Basin.
Existing solar
developments in that
area are on soils that
continue to blow
dust in high winds
even after several
years
Figure 8: Pile up on Hwy 247
in Lucerne Valley during
The purpose of this
March 28, 2016 dust event
slide show is to
demonstrate life on
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MBCA DRECP Comments
March 22, 2018

The purpose of this slide show is to demonstrate life on an STP and what can happen when
the areas are destabilized and the wind blows. This is not a problem just for the BLM, it also
includes projects on land under county jurisdiction. In other words, this is a desert wide
problem and if not confronted could result in the creation of another Owens Valley, which
was the largest dust source in the United States until serious and costly efforts were made
to stabilize the dry lake following extensive litigation.10
4. Suggestions to protect the DRECP Plan Area from becoming another Owens
Lake.
Background
The Owens Dry Lake has produced some of the worst Particulate Matter (PM) in the
country.
• The area of the Owens Dry Lake currently subject to dry land controls is 30,000
acres.11
• Based on the presented USGS analyses, the assumed area of DRECP DFAs are on
slopes 1% or less with soils susceptible to eolian dust and sand transport, especially
after disturbance is 388,000 acres
• If the DFAs are completely built out it is highly likely that the PM10 emissions in the
Plan Area and downwind air quality for hundreds to thousands of miles could be
increased by greater than that experienced at Owens Lake two decades ago.
This map shows currently proposed RE projects, county, state, and federal, within the USDA Soil
Survey Boundary. Red areas are analyzed with a high potential for eolian dust. The yellow areas
have a moderate potentai for blowing dust. All projects are on high dust potential soils.

The red circle


is a project
on BLM land
within a DFA.
It is also
completely
covered by a
Landscape
Wildlife
Linkage
(DRECP LUPA
Figure D-1)

Figure 9: Map of Lucerne


Valley and Newberry
Springs/Daggett area
showing soils, proposed
projects & MDAQMD
monitoring stations.

10
https://www.inyowater.org/documents/reports/owens-valley-water-history-chronology/
11
Personal communication with Earl Withycombe, Air Resources Engineer, CARB.
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MBCA DRECP Comments
March 22, 2018

The DRECP LUPA and EIS do not provide sufficient caution for project planning and
implementation of RE on STPs. We suggest that BLM consult Volume 1 of the BLM PEIS
(finalized in 2012) and add the following guidance into the current plan.12

· (p. 4-5, (Wind Erosion of Soils), text should have been included to indicate that wind
erosion and deposition are important processes in alluvial valleys where many of the
SEZs are located, especially for the formation of eolian landforms such as yardangs and
sand dunes.
· (p. 4-27) As the effects of global climate change continue to affect the six-state
region, it is very likely that, associated with northward migration of storm tracks
(USGCRP 2009), desertification will intensify; thus, it will be more likely that more dust
will be produced as vegetative cover decreases and as soils dry (Morman 2010). USGS
scientists have been studying the sources and compositions of dust across the southwest
deserts, from both natural and anthropogenic sources, including the dust in terminal
lake valleys in southern California and Nevada in which solar developments are being
contemplated in this PEIS (Reheis et al. 2009). The studies are finding that dust from
terminal lake basins could be transported hundreds of miles and could be a global source
of metal-bearing and potentially toxic dust. Not only are the dusts readily available, but
they are also easily respired and highly bioaccessible (Morman 2010; Reheis et al. 2003).
While there is some variability among dust sources, all include a mixture of arsenic,
cadmium, chromium, copper, lead, nickel, and zinc, all of which are potentially toxic to
humans (Morman 2010; Reheis et al. 2003, 2009).
· (p. 5-16) Once disturbed, areas with biological soil crusts and desert pavement can
become long-term dust sources and thus may require special consideration during the
ROW application process or during the air permit application process.

1. We suggest commencing and continuing consultation with California Air Resources Board
and U.S. EPA to be certain that the analysis and modeling of soils for each of the DFAs and
Variance lands is adequate to ensure compliance with state and federal standards.

2. We suggest that, in the absence of NRCS analysis for soil types within a plan area, that there
be topographic and surficial geologic analyses to inform the BLM and the public of the
fugitive dust possibilities resulting from site disturbance.

3. The MDAQMD does not currently have meteorological or PM10 monitoring stations east of
Barstow and Victorville. SCAQMD lacks these stations east of the Coachella Valley. We
suggest that all applicants locate meteorological and PM10 monitors on site, guided by
AQMD, for a period of at least one year prior to development, and that they remain in place
during the life of the project and beyond. The data generated must be publicly available.

12
http://solareis.anl.gov/documents/fpeis/index.cfm
10
MBCA DRECP Comments
March 22, 2018

4. In lieu of any meaningful dust control mitigation measures for the landscape level
disturbance of RE sites, we suggest that the proven windblown dust mitigations in the Great
Basin Rule 433.13 Control of Particulate Emissions at Owens Lake (Adopted: 4/13/2016) be
adopted for use in the Mojave Desert Plan Area. Example:

“The Best Available Control Measure (BACM)


2. “BACM PM10 Control Measures” are best available control measures designed to
reduce PM10 emissions to Control Efficiency (“CE”) levels specified below through
compliance with performance standards specified in Attachment A or in specific control
measure definitions below.

e. “BACM Gravel Blanket” means the application of a layer of gravel sufficient to meet
the CE level of 100% by covering the control area with
• a layer of gravel at least four inches thick with gravel screened to a size greater
than ½ inch in diameter, or
• a layer of gravel at least two inches thick with gravel screened to ½ inch in
diameter underlain with a permanent permeable geotextile fabric.”

5. We suggest that Great Basin Rule 433 as applicable be a supplement to the Best
Management Practices and Guidance Manual: Desert Renewable Energy Projects, and that
it be a living document updated as new research results are available.

We appreciate this opportunity to comment and thank you for your considerable time to
evaluate them.

Sincerely,

Pat Flanagan,
Board Member
Morongo Basin Conservation Association

13
https://www.arb.ca.gov/DRDB/GBU/CURHTML/R433.PDF
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MBCA DRECP Comments
March 22, 2018