Basin and Range Watch
To:
John Ruhs
Nevada State Director
Bureau of Land Management
Sent by email to: jruhs@blm.gov
Gayle Marrs-Smith
Las Vegas Field Office Manager
Bureau of Land Management
Sent by email to: gmarrssm@blm.gov
Tim Smith
Las Vegas Field Office
Bureau of Land Management
Sent by email to: tsmith@blm.gov
February 20, 2016
Subject: Reactivated Crescent Peak Wind Application Lease #NVN----090068 and Request for Wind Energy Free Designation for the Southern Nevada Resource Management Plan
Dear Mr. Ruhs,
As you may be aware, a wind application has been reactivated in the BLM Southern Nevada Resource Area. In 2009, Oak Creek Wind Energy filed an application with the BLM for the Crescent Peak Renewables LLC, Lease #NVN----090068. This would be in close proximity to the recently set back Searchlight Wind Project which had its Record of Decision voided last October by a Federal Judge. As you remember, we have a request for a wind energy free designation for this project site for the Southern Nevada Resource Management Plan.
The wind application was recently purchased by Elous Wind, a Swedish LLC, which plans on building a project in this location by 2021.
According the Bureau of Land Management Southern Nevada Office, this project has the potential to move forward before the Southern Nevada Resource Management Plan is made final. We have been told that this company would like to file a Notice of Intent for the Federal Register soon. They tell us the company still needs to submit a Plan of Development. They also tell us the company may consider constructing concrete based, 750 foot turbines.
As you are aware, there is a brand new Castle Mountains National Monument adjacent to this site in California. This was not and could not be evaluated in the RMP due to its very recent nature.
Any wind project located next to this new monument would have direct and cumulative impacts to the local region and now that a new National Park Service unit has been established. The entire region has been a popular recreation area long before this new monument was created. Any wind project would be directly visible from the Mojave National Preserve (MNP) in California. A wind energy facility would forever degrade the visual landscape from the Castle Peaks portion of the MNP. As it stands now, the Crescent Peak Wind application spans close to 40,000 acres and would be visible from a great portion of the east side of the MNP. Please consider that the development of both the Searchlight Wind Project and the Crescent Peak Wind Project would cumulatively change the view to industrial and be a death knell for tourism in the region.
From Nevada, the project would be visible for many miles. It would be quite obvious from Spirit Mountain, the Place of Creation for many Colorado River Indian Tribes. The Ft. Mojave Tribe has told us that several burial sites are located throughout this region. The project would also be visible from private lands and a great deal of the community of Searchlight, Nevada. The wind application literally surrounds the historic Walking Box Ranch, a historic cattle ranch purchased by Hollywood actors Rex and Clara Bow in 1931. In 2005, the BLM purchased the Walking Box Ranch with a grant from the Southern Nevada Public Lands Management Act. The Nature Conservancy owns two conservation easements on the Ranch property, preserving habitat for the desert tortoise. The TNC has preserved 439,000 acres in the Piute Valley. Furthermore, the BLM has agreed to provide 6 million dollars of mitigation money from the Dry Lake South Solar Energy Zone to be used as mitigation money for environmental protection and enhancement of the El Dorado/Piute Area of Critical Environmental Concern (ACEC) which would be directly impacted by any large wind energy facility. We have taken photos both from the proposed project site and the new Castle Mountains National Monument to illustrate the visual impacts. They are at the end of this letter.
The Map below shows the entire region:
On October 30th, 2015, Federal Judge Miranda Du vacated the Record of Decision for the nearby Searchlight Wind Project. This decision was based on the inadequate golden eagle and desert tortoise surveys for the project. In particular, 28 golden eagle nests were found within ten miles of the project. This number is greater than the three listed in the Final Environmental Impact Statement for the project. The map below comes from a study conducted in a collaborative effort by the Nevada Division of Wildlife and the Great Basin Bird Observatory. The map shows several more nests in the region, many of which are located within the application of the Crescent Peak Wind Project. From the map they produced, there can be up to 100 nests in the region. Golden eagles can fly as fast as 150 miles per hour and have a home range of up to 60 square miles, so any wind project built in this region is likely to impact the population. Several other species of birds would be impacted as well and locals refer the area as a “hawk flyway”.
The area also supports one of the highest density desert tortoise populations in Nevada.
The Southern Nevada Resource Management Plan (SNRMP) is now under review by the BLM and is the management blueprint for the region. In our personal communications with the BLM, there will be no final decision on this plan until fall, 2016. Under the Federal Lands Policy Management Act (FLPMA), land use designations can be updated through Resource Management Plans. The 2015 SNRMP is now incomplete for this region due to the recent designation of the Castle Mountains National Monument in California. The Draft Environmental Impact Statement does not discuss the new national monument and fails to examine the potential impacts that an industrial wind facility would have on it.
We would like to ask you to consider the following requests concerning the recent news about the Crescent Peak Wind application:
Do not allow any Notice of Intent to be submitted for this project until the Southern Nevada Resource Management Plan is made final.
Add a new alternative to the SNRMP designating a wind energy free zone for the Federal Lands of the entire Piute Valley and El Dorado Valley and extend it south to the California Border.
Upgrade all Visual Resource Classifications in the SNRMP to VRM I which would acknowledge the scenic quality of the area as well as the creation of the new adjacent National Monument to the management area.
Hold public meetings for the region. Ask the public how appropriate both of these projects would be.
Do not allow industrial wind facilities to be built anywhere within the view-scape of the Piute Valley and the surrounding region.
The map below shows the boundaries that we are requesting to be considered in the Southern Nevada Resource Management Plan for an off limits Wind Energy Development Zone:
Above: Wind Energy Free Zone in red.
The National Renewable Energy Laboratory has produced a map of wind energy resources in the United States. The following map shows only marginal wind energy potential for the entire Piute Valley including the sites of both the Searchlight and Crescent Peak Wind Applications. The average optimal wind speed for wind energy production is 13 miles an hour, while the averages for the Piute Valley are about 6 to 6.5 miles per hour. The map is included below:
In conclusion, the Southern Nevada Resource Management Plan provides the BLM with a good opportunity to manage this area prioritizing conservation of the biological, cultural, and visual resources of the region. Protecting the region with a wind free designation would maintain the integrity of the area which will keep local tourism alive and well.
Thank you for considering our comments.
Sincerely,
Kevin Emmerich
Laura Cunningham
Basin and Range Watch
Visual Impacts in photographs:
Above: Looking across Piute Valley towards Spirit Mountain from the Crescent Peak proposed project site. Not only would turbines be directly visible in the foreground, they would be highly visible in the distance for the Searchlight Wind Project.
Above: This is the Castle Peaks in the Mojave National Preserve, California taken from the site of the proposed Crescent Peak Wind Project site.
Above: View of the Crescent Peak Wind Project site in Nevada from the new Castle Mountains National Monument in California.
Above: Castle Mountains National Monument, California seen from just over the Nevada border from the proposed Crescent Peak Wind Project site.
