Please Cancel the Environmental Impact Statement review of the Rough Hat Clark County Solar Project
Petition to Interior Secretary Deb Haaland, BLM Director Tracy Stone Manning, BLM Nevada State Director Jon Raby and Fish and Wildlife Director Paul Souza
Dear Secretary Haaland, Director Stone-Manning, State Director Raby and Director Souza,
Due to the irreversible impacts that would occur to the water resources of the Pahrump Valley the quality of life for residents and wildlife the undersigned request that that Secretary Haaland, and the Interior Department cancel the Environmental Impact Statement and further review of the proposed Rough Hat Clark County Solar Project located on Bureau of Land Management (BLM) lands south of Pahrump, Nevada.
The Rough Hat Clark County Solar Project is a proposed 400-megawatt solar photovoltaic facility on 2,400 acres of public land that would replace nearly 4 square miles of public land in the Mojave Desert habitat with solar panels, battery storage banks, and new transmission lines. The project is only one of 6 large-scale solar projects and transmission upgrades either built or proposed for Mojave Desert habitat on public lands south of Pahrump, Nevada.
The following resource conflicts will occur out of this project moves forward:
Water Resources:
· The project proponent must use 800 acre-feet of water just for the construction phase of this project and 16-acre feet each year for operation.
· The Pahrump Valley is situated in Nevada State regulated Basin 162 and is over-appropriated by 42,000-acre feet. The perennial yield is 20,000-acre feet, but there are nearly 62,000 acre-feet of water rights issued for this basin.
· The 3,000-acre Yellow Pine Solar Project has already used 1,800 acre-feet and there are 9 other solar applications in the region so far including the Rough Hat Clark County Solar Project that could collectively require an additional 5,000 acre-feet or more. That would use up about one quarter of the annual recharge of Basin 162.
· The project proponent, Candela Renewables, has stated they are uncertain where they would obtain the water rights for this project but have indicated they would buy it from existing water right holders in the basin.
· This will impact the wells of local landowners in the basin, potentially take part in impacting natural springs like Stump Spring and impact water resources that are part of the watershed in the Amargosa Basin.
Desert Tortoise:
The project site is beautiful Mojave Desert over 3,000 feet in elevation, receives 5 to 10 inches of rain annually and supports a healthy, reproducing desert tortoise population.
The Environmental Impact Statement for the Rough Hat Clark County Solar Project estimates that there are 114 adult desert tortoises on the site. Usually, the number of juvenile tortoises is about 3 to 4 times greater than the number of adults. It should also be noted that nearly 3 times more tortoises were found on the adjacent 3,000-acre Yellow Pine Solar Project site than predicted by project biologists. The US Fish and Wildlife Service only requires that adult tortoises be moved and not juveniles due to the difficulty of finding quarter-sized juvenile tortoises, but this means that hundreds of desert tortoise juveniles and hatchlings will be crushed and killed by large earth-moving equipment.
The desert tortoise was listed as Threatened under the Endangered Species Act in 1990 and has seen sharp declines in several of its Recovery Units. Starting in 2009, large-scale solar energy applications have been accepted on thousands of acres of tortoise habitat and over 75,000 acres of this tortoise habitat has been developed so far for solar energy. In the Pahrump Valley in 2021, 139 tortoises were moved off the adjacent Yellow Pine Solar Project during a record-breaking drought and 33 were killed by badgers. The habitat on the Rough Hat Clark site is even more suitable for desert tortoises due to its higher elevation.
The desert tortoise density predicted for the Rough Hat Clark County Solar Project was originally estimated to be 3.4 tortoises per kilometer. In 2022, the BLM admitted that the project site predicted density is actually 5.6 per square kilometer. It needs to be noted that the tortoise density of the project site now rivals 17 of the established Fish and Wildlife Service designated Critical Habitat units for the desert tortoise.
In total, the Fish and Wildlife Service has determined that the desert tortoise has seen a 37 percent range-wide decline from 2004 to 2014 during counts, and is not seeing any improvement.
Approval of the Rough Hat Clark County Solar Project will likely contribute to this on-going extinction trend by having to dig up and move over 100 adult desert tortoises. Associated with desert tortoises are dozens of other species of plants and animals that will be destroyed by this project.
Changing Management Objectives in Resource Management Planning Will Hurt the Community and Environment
To approve the Rough Hat Clark County Solar Project, the Bureau of Land Management must downgrade the Visual Resource Management objectives of the entire region to allow for unsightly development. The current level of management allows for a moderate level of change that may attract attention but should not dominate the view of a casual observer. This is called BLM Visual Resource Management Class III. The BLM seeks to allow management activities that require major modifications of the existing character of the landscape. The level of change may be high and may dominate the view and be the major focus of viewer attention. This is called Visual Resource Management Class IV. The BLM intends to change the entire South Pahrump Valley to this lower visual class to accommodate nearly 20,000 acres of solar energy projects.
This is part of the 1997 Las Vegas Resource Management Plan – a large BLM land use plan that covers 3 million acres in Southern Nevada which includes much of the South Pahrump Valley. The plan struck a balance with projected growth of the region and protecting valuable view-sheds.
This downgrade would literally pave the way for this industrialization of so much public land, the view-shed would be committed to a single use with future of solar panels, transmission lines and Lithium-ion battery banks. Downgrading visual resources will impact the quality of life for local landowners and impair the recreational opportunities these beautiful lands provide to the public. This will likely lower property values in the region and degrade the recreational experience for tourists traveling along Tecopa Road which is also referred to as the Old Spanish Trail Highway.
Please Cancel This Project
The Interior Department has the authority to cancel a National Environmental Policy Act review and has done so in the past. In 2018, Interior Secretary Ryan Zinke and the Energy and Infrastructure Team canceled the Environmental Impact Statement for the Crescent Peak Wind Project near Searchlight, Nevada which would have developed over 200 wind turbines on 38,000 acres of wildlife habitat, visual and cultural resources in what is now the Avi Kwa Ame National Monument.
In 2021, Interior Secretary Deb Haaland canceled the Environmental Impact Statement that would have weakened many of the conservation actions approved under the California Desert Renewable Energy Conservation Plan.
Solar energy can be sited in many different locations including rooftops, over parking lots, on previously disturbed lands and other brownfields.
For the sake of the future of local water resources, the desert tortoise and other species, and the communities threatened, please cancel the Environmental Impact Statement review for the Rough Hat Clark County Solar Project.
