Educational Bulletin #10-3
A publication of the Desert Protective Council www.dpcinc.org
Farewell to Ivanpah?
by Laura Cunningham and Kevin Emmerich
Old-growth creosote habitat on the site of the proposed
Ivanpah Solar Electric Generating Station. Chazz Layne photo
We stood in the quiet fan sloping gradually down from snow-
covered Clark Mountain on the border of the Mojave National
Preserve. The winter day was brisk and breezy, the air fresh, and
the creosote bushes were green from recent rains. I noticed many
animal tracks in the sandy washes winding through the cactus
and bursage: coyotes, bobcats, kangaroo rats, kit foxes. Small
green rosettes of annual wildflowers poked their leaves upwards,
a harbinger of the coming spring when their blooms would add
color to this desert.
Meanwhile in the distant city, other folks had designs on this
land. Plans were being made, investments sought, deals struck.
On February 11, 2009, Southern California Edison agreed to
purchase 13,000 megawatts of electricity from solar projects to
be built by Oakland-based BrightSource Energy. It was the larg-
est solar electricity deal in the world. BrightSource had been busy
during the previous two years applying for permission to use
nearly 4,000 acres (about 6.4 square miles) of public land in order
to build a 400 megawatt (MW) solar thermal “power tower” plant,
the first stage of the deal.
Here would be the so-called Ivanpah Solar Electric Generating
System (ISEGS).
The proposed project represents part of the efforts by some to
sacrifice over a million acres of public lands and arid land ecosys-
tems in California alone to questionable “green” energy projects.
The scope of impacts and environmental devastation that will re-
sult from these projects are not worth the amount of energy, that
could instead be generated from rooftop photovoltaic panels.
BrightSource raised more than $160 million from equity inves-
tors including Google, VantagePoint Venture Partners, and Drap-
er Fisher Jurvetson, but they will need billions of dollars more to
develop the full 13,000 MW worth of power plants. Edison will
not say how much it is paying for the solar-generated power, but
did admit that the electricity from the first Ivanpah plant would
be priced below the state benchmark known as the Market Price
Referent, 12.5 cents a kilowatt-hour. We guess that the cost to gen-
erate the electricity from the solar thermal plant would be just
under this figure. It costs 4.7 cents per kilowatt-hour to generate
electricity by burning natural gas.
BrightSource probably chose the Ivanpah site in California,
uphill from Interstate 15 near the Nevada border, partly because
it is right across the Ivanpah Valley from the Bighorn Generating
Station, a 598-megawatt natural gas-fired, combined-cycle power
plant approximately 35 miles south of Las Vegas. The ISEGS will
burn natural gas in order to keep the start-up boiler warm during
cloudy days and cold mornings. Natural gas for the project would
be obtained by a new 5.3-mile-long natural gas pipeline connect-
ing to the Kern River Gas Transmission Line, less than a half a
mile north of the project site.
Yielding to reality
The Preliminary Staff Assessment (PSA) describing the project,
prepared by the California Energy Commission (CEC) in 2008,
dryly noted: “The ISEGS site would be located in an undeveloped
area. Brush would be cleared prior to grading.”
 The proposal has been modified since then, as BrightSource
has attempted to undercut criticism by tweaking the design of
the site, reducing from 318,000 to about 175,000 the number of
heliostat mirrors. The mirrors would be placed in curving rows
to concentrate sunlight on boilers atop three 459-foot-tall power
towers, down from five in the earlier plan. Each mirror would
track the sun throughout the day and reflect the solar energy to
the receiver boiler. In each of the three plants, a Rankine-cycle
reheat steam turbine would then receive the steam from the so-
lar boilers to turn turbine generators. Herbicides would then be
regularly sprayed, according to the PSA, to keep weeds down and
prevent fire-fuel build-up.
Perhaps realizing the massive amount of landscape degrada-
tion that would take place, BrightSource changed its plans for
grading and drainage at the Ivanpah site as well.
The initial plan submitted to the CEC and Bureau of Land
Management (BLM), which manages Ivanpah Valley, would have
required grading almost 4,000 acres of pristine desert to place
heliostats. The desert would have been scraped bare in a huge
swath.
But this scheme ignored some complications: flash floods com-
ing off Clark Mountain, the Federally protected desert tortoise,
and dense vegetation — all the cacti, yuccas, creosote, wildflow-
ers, and other plants that store carbon and help buffer the effects
of global warming. Plowing all this up would release stored car-
bon in the vegetation, and in the soil microfauna and flora. This is
rather a paradox; renewable energy projects like that at Ivanpah are
supposed to help reduce carbon emissions into the atmosphere.
So the planners rethought some of their macro-manipulation
of the landscape.
In the most recent revisions to the plan, BrightSource claims it
will leave more desert vegetation intact, scraping only part of the
area and merely “trimming brush” elsewhere — vegetation that
could “interfere with mirror movement to a height of 12–18 inch-
Barrel cactus and pencil chollas on the site are unlikely to
survive transplanting.
es” would be clipped and pulped. The new plan would also build
around the numerous washes that flow through the project area,
instead of building berms and drainage channels to shunt flash
floods away from the large mirrors. Given the Ivanpah Valley’s
strong desert winds and the consequent erosion of strips of “pre-
served” vegetation, it is questionable whether such partial disrup-
tion of the desert soil will be any less destructive in the long term.
And in August 2010, the CEC’s Presiding Member’s Proposed De-
cision on ISEGS contained a shocking estimate of potential flood
damage to the project: “While neighboring properties will not be
substantially affected by increased peak or sediment flows, the
data suggests that a significant number of heliostats may fail due
to erosion removing the soil support for their mounting poles, as
many as 32,000 during a 100-year flood event.”
There will be an estimated 173,500 heliostats on the site, each
with two mirrors 10 feet wide on 12-foot pedestals. Amazingly,
the CEC will only require study and testing later, after approval,
to determine the optimum depth for the mounting poles so as to
avoid erosion caused failure of the heliostats.
The solar heat used in the boiler process would be supplement-
ed by burning natural gas to heat a partial load steam boiler when
solar conditions are insufficient. Each power plant within the
project would include a small natural gas-fired start-up boiler to
provide additional heat for plant start-up and during temporary
cloud cover. Natural gas would be supplied to the site through a
new, proposed six-mile long distribution pipeline — ranging from
four to six inches in diameter — from the existing Kern River Gas
Transmission pipeline located a half-mile north of the Ivanpah 3
site. The primary method of construction includes excavation of
an open trench about 36 inches wide and 3 to 10 feet deep. With
loose soil, a trench up to 8 feet wide at the top and 3 feet wide
at the bottom may be required. The temporary construction dis-
turbance area for the natural gas pipeline would be a 200-foot by
200-foot area required for the KRGT tap point. Again; how much
carbon are we offsetting?
Access and Maintenance Roads
Colosseum Road, currently a dirt road used by recreationists,
would be paved to a 30-foot wide, two lane road for a distance of
1.9 miles from the Primm Valley Golf Club to the facility entrance.
The road would be re-routed around the southern end of Ivanpah
2 before re-joining the current road to the west of the proposed
facility. But two other dirt roads used by recreational users would
be blocked and re-located outside of the project boundary fence.
Within the heliostat fields, 10-foot wide maintenance roads
would be established concentrically around the power blocks to
provide access for heliostat washing and maintenance. The roads
would be established between every other row of heliostats. The
applicant estimates that 100 heliostats can be washed per hour
with four trucks working 10 hours per night at about 0.4 mile per
hour. Many miles of new heliostat maintenance road would be
graded into the desert. An additional maintenance road would be
established on the inside perimeter of the boundary fence. Within
each unit, a diagonal dirt road would be established to provide
access to the concentric maintenance paths and the power blocks.
Some of these would be gravel.
According to supporting documents for the project’s Draft
Biological Assessment, “To construct the heliostat array fields lo-
cated within these sites, some vegetation clearing and site grading
would occur. In areas where general site grading is not required
for stormwater management, vegetation clearing
and grading would be performed only between
every other row of the heliostat arrays that radiate
outward in concentric arcs from their associated
receiving towers. The cleared rows would serve as
access routes from which the heliostat mirrors can
be reached from both sides of the road for service
and cleaning, thus minimizing soil disturbance
within the heliostat array fields. It should be not-
ed that a minimum amount of cutting and filling
within these access routes is anticipated. Some re-
grading for maintenance would most likely be re-
quired due to soil erosion and regular use.”
An “Irish Bridge” or low-water crossing would
be constructed where permanent asphalt paved
access roads cross major ephemeral washes on the
site. These bridges would be constructed of rein-
forced concrete or gabion baskets, would gener-
ally conform to the cross-sectional dimensions of
the channel, and are being designed to prevent the
scour and washout of major asphalt access roads
during storm events. When necessary, offsite
stormwater drainage would be collected using a
system of swales, berms, and existing ephemeral
washes to control and direct stormwater through
and around the ISEGS site. Those who complain
against off-road users on the desert need to consid-
er this huge increase in roads built by solar thermal
companies.

Fencing
The project area would be surrounded by security
fence, which would be constructed of eight-foot
tall galvanized steel chain-link, with barbed wire
at the top as required. The security fence would
surround the outer perimeter of each power plant,
the substation, and the administrative complex.
Tortoise barrier fence would also be installed. The
tortoise fence would consist of one-inch horizontal
by two-inch vertical galvanized welded wire. The
fence would be installed to a depth of 12 inches,
and would extend 22 to 24 inches above the ground
surface and integrated with the security fence.
So much for BLM’s main mission, the manage-
ment of public lands for multiple use. That is a lot of trash to leave in our desert.
Another question is how these fine-mesh tortoise fences will Supposedly, cacti and yuccas would be salvaged prior to con-
act as barriers to flood debris allowed to flow in washes through struction, transplanted into windrows, and maintained for later
the project. Will tortoise fences act as dams, collecting gravel, transplanting following decommissioning. Unless they are wa-
cobbles, and branches, eventually changing the flows of these tered vigilantly, these plants often die in our experience. ­Yuccas
washes? Will floodwaters overbank their channels, causing dam- are especially difficult to transplant.
age to fences and other structures? Those of us who live in the des-
ert know that the infrequent yet strong flash floods in the desert Rare Plants and Desert Animals
easily take down ill-conceived fences. The project will have a significant impact on the overall diversity
of life in the Mojave Desert. The applicant admits there is really
Decommissioning no way to compensate for the loss of most of the rare plants that
After the (highly theoretical and optimistic) 50-year lifespan of are listed. Most of the mitigation plans would merely “protect and
the project, the owner would close the plant. Facilities would be enhance offsite populations or some other form of compensatory
removed to a depth of three feet and the ground graded to “origi- mitigation.” At least 12 rare plants have been found on the project
nal contours.” But concrete, piping, and other materials existing site, some with significant portions of their range facing destruc-
below three feet in depth would be left in place. tion from the solar facility. The Rusby’s desert mallow, for exam-
ple, has been described by the California Native Plant Society as
“rare, threatened, or endangered in CA and elsewhere.” Their map
lists only 35 locations where the plant has been found, all in Cali-
fornia, and clustering around the Clark Mountain area.
A diverse range of insects, reptiles, birds, and mammals also
dwell on this desert fan.
The project site is excellent habitat for the Federally Threat-
ened desert tortoise. The Ivanpah PSA said “the 2007/2008 proto-
col desert tortoise surveys found 25 live desert tortoises, 97 desert
tortoise carcasses, 214 burrows, and 50 other tortoise sign.”
Since tortoises cannot co-exist with solar thermal mirror ar-
rays, what usually has to happen is that the tortoises are “cleared.”
This involves removing and translocating all tortoises from the
entire 4,000 acres. All burrows are dug up to try to find animals
underground. Many are missed, so several “clearances” must be
carried out. The applicant company has been required to “miti-
gate” this damage by acquiring desert land somewhere else and
translocating all the tortoises found and dug up to the new site.
Even with this plan, mortality for translocated desert tortoises
has been high. The PSA states that an estimated 15 percent is “nor-
mal.” But recent experiences with the Fort Irwin translocation
operation suggest that even higher mortality rates are probable.
Drought only exacerbates the stress of moving tortoises from their
home ranges to unfamiliar new areas, where they have to compete
for food and burrows with already present tortoises. Many of the
tortoises translocated in the disastrous Ft. Irwin plan were killed
by coyotes. Walking around the translocation site near Primm,
Nevada, where thousands of tortoises were translocated from the
Las Vegas Valley boom developments, we see many shells lying on
the ground.
The ISEGS lies within the Northeastern Recovery Unit for the
desert tortoise, one of six units designated in the 1994 Desert Tor-
toise (Mojave Population) Recovery Plan. Studies done indicate
these populations have distinct genetic, morphological, ecologi-
cal, and behavioral characteristics, making them distinct “Evolu-
tionary Significant Units.”
CDFG has not yet issued BrightSource an Incidental Take Per-
mit, under the California Endangered Species Act, requiring the
“take” (an allowable death of a certain number of tortoises) to
be minimized and fully mitigated. Unfortunately, land manag-
ers had earlier left the Ivanpah project site out of critical habitat
designation for the desert tortoise, even though density was his-
torically high. BLM had designated portions of Ivanpah Valley as
Category 1 desert tortoise habitat in their Northern and Eastern
Mojave Desert Management Plan (NEMO), but the northern part
of Ivanpah Valley was excluded for some reason.
Ravens sometimes kill and eat juvenile tortoises, especially
when human activity attracts the birds with trash and food scraps.
What kind of reduction measures will be taken to minimize raven
predation on tortoises? If native predators are to be exterminated,
the applicant needs to explain how this will take place. Will the
same measures apply to coyotes on the translocation site? The
applicant should be able to describe and admit the unattractive
details that will need to be implemented for predator reduction.
These details should not be green-washed.
Staking out territory
In Summer 2010, before the project was even approved by BLM
and the CEC, surveyors were busy on this desert fan. Thousands
of stakes marked out Phase 1 of the outline of the first solar field
planned of three. A Construction Laydown Area along Colosseum
Mine Road is also marked out, with some stakes labeled “gate.”
Stakes line the proposed entrance road to the vast construction
site that are indicators of the tortoise exclusion fence that will be
the first item to go up, as a horde of contract biologists come to
clear tortoises out of the construction areas and keep them off
roads that will be full of truck traffic. We contacted BLM to ask
about this, and received this answer:
“This is to confirm the explanation you heard from ­BrightSource
to your survey stake question... There have been multiple surveys
conducted at different times since the ROW [Right Of Way] appli-
cations were filed on BLM. In my conversations with ­BrightSource,
they were informed that when they did any survey work or data col-
lections on public land associated with their ROW applications, all
vehicle access was limited to designated open OHV routes or other-
wise had to be done on foot. Most recently, BrightSource has been
finalizing legal land descriptions to submit as part of their final plan
of development for the project. BLM requires applicants to complete
a metes and bounds survey showing project perimeters, facilities, and
exact acreages. The surveys also have to be tied to existing rectangu-
lar survey monuments in and around the project. I am sure there are
many stakes on the ground in support of this surveying effort.”
Conclusion
In June 2009 we visited the site of the proposed ISEGS on the
night of a full moon. Life was abundant there; showers had passed
through days before. On Yates Well Road in the broad creosote
flats in the lower basin, 20 or 30 lesser nighthawks flew about in
the dusk light after insects. Some sat on the small road, flying up as
we came by. A single poorwill also flew up from the desert floor.
Black-tailed jackrabbits dashed about in the evening darkness
as stars came out.
As if to show the incredible diversity of life here, a spotted
leaf-nosed snake was out basking in the residual heat of the little
crumbling roadway that will be BrightSource’s main entrance
road to their project.
We took a close look at the snake’s enlarged rostral scale which
the snake uses to burrow into the sandy, gravelly creosote plains
that it lives on. They often hunt geckoes.
We put the snake back on the ground and hoped its habitat
would not succumb to the perils of poorly planned renewable en-
ergy developments.
The evidence is clear that none of these projects is necessary to
meet renewable energy goals. We can generate more renewables
that are truly clean on our rooftops without killing one plant or
animal, without scraping one square foot of soil. Ivanpah is a peak
power proposal, not base load. Not one coal plant will be replaced
by ISEGS. Why not put 2.5 kilowatts of photovoltaic panels on
each of the 160,000 homes the project applicant claims it will
serve?
Kevin Emmerich spent 17 years working as a Park Ranger and
biological resources technician, mostly in Death Valley National
Park. Laura Cunningham has worked as a tortoise biologist in the
Mojave Desert, and is an artist and writer on ecological subjects.
They co-founded the Beatty, NV-based group Basin and Range
Watch to track ill-sited large-scale renewable energy projects.
The Ivanpah Solar Electric Generating Station was approved by the
Department of the Interior on October 7.