September 18, 2024 - Riverside County, CA - The Bureau of Land Management (BLM) has prepared this Environmental Assessment (EA) for IP Easley, a subsidiary of Intersect Power LLC, which proposes to construct and operate the Easley Renewable Energy Project on approximately 2,700 acres of BLM-managed public lands and 990 acres of private lands north of Desert Center on I-10. The project would be built within a quarter mile of the community of Lake Tamarisk (the community is asking for a larger buffer), and destroy more desert dry wash woodlands full of desert ironwood trees. The entire area is a ground zero area for solar energy sprawl and BLM has already approved nearly 20,000 acres of solar projects in the area. This project is within the Desert Renewable Energy Conservation Plan (DRECP) area, but represents another failure of this plan amendment to protect people, communities, and important biological resources such as old growth desert ironwood wash habitats.

old growth 

The Chuckwalla Basin aquifer is only 100 Acre Feet (AF) above overdraft. Exorbitant groundwater use for Utility Scale Solar construction is in large part responsible for this reduction from 12,000 AF over the last decade.

Intersect Power alone would extract an additional 1,000 Acre Feet of groundwater for the Easley Solar Project thus causing a 900 Acre Feet Overdraft of the Chuckwalla Valley Groundwater Basin and continuous degradation of water quality as freshwater mixes with high salinity ancient water layers.

The project would develop 500 acres of valuable desert dry wash woodlands and desert pavement.

The project will impact habitat for desert tortoise, desert ironwood trees, burro deer, kit fox, American badger and a host of other species.

The project will create dangerous fugitive dust for the residents of Desert Center and Lake Tamarisk, rural towns in Riverside County, California. 

The project will increase the threat of collisions for avian species. This has been a big documented problem for both the Desert Sunlight and Palen Solar Projects. 

The project will continue to lower the property values and quality of life for the local residents.

The BLM is required to consider a No Action Alternative and has developed an Alternative 4 that would reduce the size of the project, move it further back from the Lake Tamarisk community and preserve hundreds of acrea of desert dry wash woodlands.

Tell BLM to select a No Action Alterative and to use Alternative D as a last resort to protect the habitat and community. 

Sample Letter

Easley Solar Environmental Assessment

To: Bureau of Land Management 

Palm Springs Field Office

1201 Bird Center Dr. 

Palm Springs, CA 92262

Email sent to BLM_CA_CDD_Easley_Solar@blm.gov

If the BLM were to select a No Action Alternative or even the Community setback Alternative D, Intersect Power still has made a substantial amount of money off of this region with the Oberon Solar Project. The BLM should not be proud of Oberon, it is setting negative precedents by violating the DRECP Conservation and Management Actions and setbacks, BLM also allowed Intersect to destroy 600 acres of Mojave desert tortoise Critical Habitat. This cannot happen again.

The most heartbreaking impact is the utter disregard the company has had for the community and how the BLM has allowed it to go this far.

Please pick an alternative that helps the community and natural resources of the area. Enough is enough.

The proposed Easley Solar Project will have significant impacts to federally threatened Mojave desert tortoise, desert wash old growth trees such as ironwoods, burro deer, bighorn sheep, and cause fugitive dust.

Groundwater impacts are a huge concern in this overdrafted valley.

A wildlife connectivity corridor will be partly blocked and developed in some of these alternatives, which is unacceptable. Furthermore, this disturbance will cause a spike of invasive weed proliferation such as Sahara mustard.  This will cause a weed invasion to adjacent microphyll woodlands and the Chuckwalla Critical Habitat for desert tortoise. 

BLM should consider the No Action Alternative as a Reasonable Alternative in order to protect people in these communities, and natural resources of Chuckwalla Valley. BLM should at least choose Alternative 4, which would set the project back from Lake Tamarisk more and protect desert dry wash woodlands. 

Thank you, [your name]

Further information from our comment letter:

Purpose and Need:

From the EA: 1.3.1 BLM’s Purpose and Need The BLM’s purpose is to respond to the IP Easley, LLC, a subsidiary of Intersect Power, LLC, request under Title V of the Federal Land Policy and Management Act of 1976 (FLPMA) (43 U.S.C. Section 1761(a)(4)) for a right-of-way (ROW) grant to construct, operate, maintain, and decommission a solar PV electric generating and energy storage facility and appurtenant facilities on public lands. In responding to the application, BLM must consider BLM’s multiple-use mandate, and comply with FLPMA, the BLM ROW regulations, the Energy Act of 2020 [Consolidated Appropriations Act of 2021, Division Z, TITLE III, Subtitle B, Section 3104, 116 P.L. 260, 134 Stat. 1182 (December 27, 2020), now codified at 43 U.S.C. § 3001 et seq.], and other applicable federal laws, as well as the need to promote certain policy objectives, including Executive Order 14008, described below.

 Executive Order 14008 dated January 27, 2021, “Tackling the Climate Crisis at Home and Abroad” directs the Secretary of the Interior to identify steps that can be taken to increase renewable energy production on public lands and manage federal lands to support robust climate action while ensuring protection for our lands, waters, and biodiversity (see sections 204 and 207). Furthermore, this Project would contribute to California State Senate Bill 100 that requires a 60 percent renewable energy portfolio standard by 2030 and sets a 100% clean, zero carbon, and renewable energy policy for California's electricity system by 2045. The need for this action is established by the BLM’s responsibility under Section 501(a)(4) of FLPMA, which authorizes the BLM to issue ROW grants on public lands for systems for generation, transmission, and distribution of electric energy. PALM SPRINGS–SOUTH COAST FIELD OFFICE.

The Purpose and Need Statement is overly narrow and fails to include language that safeguards the community of Lake Tamarisk, water resources, dry desert wash woodlands, desert tortoise, and the viewshed. Because this part of Riverside County is a ground zero for large-scale solar development, it is even more vulnerable to direct and cumulative impacts. 

Our organizations seek to conserve public lands and biodiversity, and we support renewable energy placed on degraded lands, and in the built environment. We have never supported utilizing pristine desert on public lands for largescale utility solar development. Instead of massive bulldozing of desert ecosystems and fragmentation of rural communities, we proposed an alternative that would have utilized the California Energy Efficiency Strategic Plan, which is already state law. Enough rooftop and parking lot sites exist to more than fulfill the California electricity need combined with more energy efficiency. However, the BLM did not adopt our proposal. The BLM’s Desert Renewable Energy Conservation Plan Land Use Plan (DRECP LUP), which was developed in collaboration with other federal, state, and local agencies, tribal governments and the public, was approved by the BLM in 2016. The DRECP LUP is supposed to provide a process for utility scale renewable energy while providing for the long-term conservation and management of special-status species and desert vegetation communities, as well as other physical, cultural, scenic, and social resources within the DRECP LUP Area through the use of “durable regulatory mechanisms” (DRECP LUP Executive Summary for the Record of Decision (ROD), page ES-2). 

Even if the project is located in a DRECP Development Focus Area, there are a series of setbacks and avoidance measures that could and should be utilized to protect the community and the environmental from the unavoidable impacts associated with large-scale solar development. 

An obvious flaw of the DRECP was a general failure to recognize how communities are impacted by large-scale solar projects. While the plan is one of the more detailed programmatic plans, it fails to protect communities in the front line of these projects from fugitive dust, property value decline, overuse of water, quality of life decline, and viewshed issues.

The Easley Solar Project should be reviewed with a full Environmental Impact Statement (EIS) because the DRECP was flawed in this region. The BLM made a mapping error and assumed that 965 acres of BLM lands were actually private land.  As it turned out, these lands are under BLM ownership and were considered “unallocated”. As a result, any public lands that were unallocated under the DRECP are placed into a “General Public Lands” management. This is new important information, and requires a Supplemental EA or full EIS in order to fully analyze these significant impacts.

General Public Lands are public lands in the Desert Renewable Energy Conservation Plan planning area that are managed by the Bureau of Land Management and are not covered by other designations. These lands are potentially available for renewable energy development, but BLM must use a Land Use Plan Amendment to the DRECP and California Desert Conservation Area Pan to release them for development. A plan amendment could potentially be used to create a community buffer for Lake Tamarisk so no future solar developments can be approved on those lands. The two sections in question contain over 500 acres of important desert dry wash woodlands and these lands should be excluded from solar development. 

In 2022, the BLM used “plan maintenance” to add the unallocated lands to the Development Focus Area that Intersect Power is seeking to develop for their project. 

The BLM can use Plan Maintenance for “minor changes in data”.  But in the case of the Easley location, the BLM just added 1.5 square miles (950 acres) of public land to a Development Focus Area without any National Environmental Policy Act (NEPA) analysis and the DRECP coverage of that location is vague and has little information on water resources, cultural resources and biological resources. Nor was there an analysis on how allowing the 960 acres to be moved into “Development Focus” would have impacted the community of Lake Tamarisk. “Maintenance shall not result in expansion in the scope of resource uses or restrictions, or change the terms, conditions, and decisions of the approved plan.” [1]

There are several resources on the 960 acres such as biological, socioeconomic, water, and cultural resources that would be impacted by industrial solar development and this really should have been reviewed in a NEPA analysis, but without NEPA, this appears to favor Intersect Power. 

Because of this, the BLM should select the No Action Alternative for the Easley Solar Project or at least select Alternative 4 for the project which would avoid these two areas. 

While Intersect Power states that Alternative 4 would not be enough to produce 400 megawatts (MW), they would still be able to generate 300 MW. Intersect has already had their Oberon Solar Project approved and built, and it now has a full power purchase agreement. 

It would seem more than unreasonable if BLM selected anything but Alternative 4 but the No Action would be the best for both the community and the environment. 

The direct and cumulative impacts from the Oberon Solar Project justify a full Environmental Impact Statement review. According to BLM’s NEPA Handbook:

7.2 ACTIONS REQUIRING AN EIS Actions whose effects are expected to be significant and are           not fully covered in an existing EIS must be analyzed in a new or supplemental EIS (516 DM 11.8(A)). You must also prepare an EIS if, after preparation of an EA, you determine that the effects of the proposed action would be significant and cannot be mitigated to a level of nonsignificance (see section 7.1, Actions Requiring an EA). If you determine during preparation of an EA that the proposed action would have significant effects and cannot be mitigated to a level of nonsignificance, you do not need to complete preparation of the EA before beginning preparation of an EIS (516 DM 11.7(E)) (See section 8.4.1, Significant Impacts – Transitioning from an EA to an EIS)

Significance is defined as effects of sufficient context and intensity that an environmental impact statement is required. The CEQ regulations refer to both significant effects and significant issues (for example, 40 CFR 1502.2(b)).

Intensity. This refers to the severity of effect. Responsible officials must bear in mind that more than one agency may make decisions about partial aspects of a major action….” (40 CFR 1508.27). The Oberon Solar Project meets some of the ten considerations defining “Intensity” and justifying an EIS. These include:

• Public health and safety (40 CFR 1508.27(b)(2)):  Fugitive dust from the project could compromise the public health of the community of Desert Center. Dust can cause respiratory problems, Valley Fever and complicate health issues associated with Covid 19. 

• Unique characteristics of the geographic area (40 CFR 1508.27(b)(3)). “Unique characteristics” are generally limited to those that have been identified through the land use planning process or other legislative, regulatory, or planning process; The preferred alternative for the site has old growth microphyll woodlands containing desert ironwood trees over 1,000 years old. 

• Degree to which effects are likely to be highly controversial (40 CFR 1508.27(b)(4)): Destroying microphyll woodlands is controversial. Developing desert tortoise habitat is controversial. Using up groundwater is controversial.

• Degree to which effects are highly uncertain or involve unique or unknown risks (40 CFR 1508.27(b)(5)): Big risks are associated with fugitive dust and public health. There is also a risk of extirpating local populations of plant and animal species. 

• Consideration of whether the action may establish a precedent for future actions with significant impacts (40 CFR 1508.27(b)(6)):  Developing an area that was originally not intended to be developed with weak plan maintenance will set precedents for future actions that could e[-weaken the DRECP. 

• Consideration of whether the action is related to other actions with cumulatively significant impacts (40 CFR 1508.27(b)(7)): Development and removal of wildlife connectivity corridors could impact the desert tortoise, burro deer, bighorn sheep and other wildlife. Furthermore, this disturbance will cause a spike of invasive weed proliferation such as Sahara mustard.  This will cause a weed invasion to adjacent microphyll woodlands and the Chuckwalla Critical Habitat. 

• Scientific, cultural, or historical resources, including those listed in or eligible for listing in the National Register of Historic Places (40 CFR 1508.27(b)(8)): This entire region is considered a “Cultural Landscape for all of the Native American Tribes in the area. 

• Threatened or endangered species and their critical habitat (40 CFR 1508.27(b)(9)): The proposed action would develop 565 acres of desert dry wash woodland and part of the wildlife connectivity corridor 

• Any effects that threaten a violation of Federal, State, or local law or requirements imposed for the protection of the environment (40 CFR 1508.27(b)(10)): Surface hydrology altercations would violate the Clean Water Act. Fugitive dust would violate the Clean Air Act and developing suitable habitat for the Desert Tortoise could violate the Endangered Species Act. 

[1] eCFR :: 43 CFR 1610.5-4 -- Maintenance.

Alternatives:

A No Action Alternative is a Reasonable Alternative

Because a “reasonable alternative” can be carried out based on environmental factors, BLM should consider the No Action Alternative as a Reasonable Alternative. Traditionally, the BLM does a very minimal job of analyzing the No Action Alternative, but if the goals of conservation are carried through, a No Action would benefit the community of Lake Tamarisk and allow more that 500 acres of desert dry wash microphyll woodland habitat to remain intact.

For example, the Need for remote energy projects can be examined by considering the potential energy output of Distributed Energy. In 2020, the nation of Vietnam installed 9 GW of rooftop solar onto their local grid. [1]   

In comparison, the expected output for Easley Solar would only be 300 to 400 MW. BLM must review the No Action Alternative in greater detail. 

Alternative 4:

The best Action Alternative being reviewed in the EA would be Alternative 4.  The alternative should also cut off more of the project on the northeast to preserve wildlife connectivity corridors. This alternative would set the project back from Lake Tamarisk more and protect desert dry wash woodlands. The project should be set back even further from the community. Building a dirt berm is an admission by both BLM and the applicant that this project will be a major visual problem. 

A Plan Amendment Alternative with a Supplemental Environmental Assessment Should be Reviewed

Because the BLM failed to consider a Plan Amendment to the DRECP in 2022 when BLM conducted Plan Maintenance to move two parcels from General lands to Development Focus Lands, nobody was aware of it but Intersect Power. This constitutes new information. This happened over 2 years ago but any Statute of Limitations should be waived because the public was not informed that this happened. We believe this triggers a need for a Supplemental EA or EIS. 

According to the NEPA Handbook, “Supplementation” has a particular meaning in the NEPA context. The Supreme Court has explained that supplementation of an EIS is necessary only if there remains major Federal action to occur. (See Norton v. Southern Utah Wilderness Alliance, 542 U.S. 55 (2004)) . In the case of a land use plan, implementation of the Federal action is the signing of a Record of Decision. You must prepare a supplement to a draft or final EIS if, after circulation of a draft or final EIS but prior to implementation of the Federal action:

 • you make substantial changes to the proposed action that are relevant to environmental concerns (40 CFR 1502.9(c)(1)(i)) ; 

• you add a new alternative that is outside the spectrum of alternatives already analyzed (see Question 29b,CEQ, Forty Most Asked Questions Concerning CEQ's NEPA Regulations, March 23, 1981) ; or 

• there are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its effects (40 CFR 1502.9(c)(1)(ii)) .

We believe that when the 960 acres was moved from General Public Lands to a Development Focus Area it was a major change that will end up resulting in environmental and socioeconomic impacts if Easley Solar is built. 

Under a Plan Amendment, the BLM could establish a permanent buffer to the community and provide a long-term protection to the desert dry wash woodlands. 

[1] Scaling up Rooftop Solar in Vietnam – More than 9GW installed in 2020 – pv magazine International (pv-magazine.com)

Environmental Impacts of the Proposed Action

Vegetation:

Grading, drive and crush construction methods, or any use of heavy vehicles on the site will destroy vegetation, crush biological soil crust and desert pavement and encourage invasive weeds such as Sahara mustard to move in. Herbicides would be used to control invasive weeds and could result in killing any native plants as well. 

Herbicides could also enter the watershed and impact the health of the community of Lake Tamarisk.

Mojave Desert Tortoise:

Mojave desert tortoise sign (class 4 and 5 carcasses) have been observed primarily in the eastern portion of the project site in desert dry wash woodland, with carcasses observed in the western portion, as presented in Section 3.5.2 (Affected Environment). Mojave desert tortoises continue to decline range wide, despite attempts to fence roads, close illegal routes, put of signs warning drivers of tortoises crossing roads, and other mitigation measures which are not efficacious in recovering the tortoise. This project will add to the decline. The desert tortoise has lost over 80,000 acres of habitat range-wide to solar energy. The Oberon Solar Project destroyed about 600 acres of desert tortoise critical habitat. Preserving desert dry wash in a No Action Alternative or Alternative D would be the better choice for conserving habitat. 

^The area of each Recovery Unit and Tortoise Conservation Area (TCA), percent of total habitat, density (number of breeding adults/km2 and standard errors = SE), and the percent change in population density between 2004 and 2014. Populations below the viable level of 3.9 breeding individuals/km2 (10 breeding individuals per mi2) (assumes a 1:1 sex ratio) and showing a decline from 2004 to 2014 are in red (after Desert Tortoise Council).

Note that the adjacent Chuckwalla Critical Habitat Unit has declined 37.43% from 2004 to 2014, when the last population monitoring surveys were completed. The Oberon Solar Project removed 600 acres of this habitat. 

In addition, the application of herbicides along will significantly impact tortoise habitat, reducing and elimination important food plants such as annual forbs and grasses. The disturbance of heavy machinery, solar panel installation, construction and operation activities will significantly impact soil surfaces, burrows, and vegetation important to tortoises.

The EA Fails to Adequately Analyze and Mitigate Avian-Solar Impacts

As other large-scale solar projects in the DFA have resulted in the mortality due to “lake-effect” impacts, resulting in collisions, this important concern should be fully analyzed and mitigation measures enumerated, including those not tiered to in the DRECP. This is a growing concern with waterbirds that fly across the desert from the Salton Sea and Gulf of California, to Colorado River water bodies. 

The EA briefly discusses bird collision and monitoring studies of mortality done elsewhere in California. Yet Argonne National Laboratory (2016) summarized multiple agency findings of widespread impacts to birds from utility-scale solar projects. Mortality monitoring and reporting is required by lead agencies on many projects. Data from 7 projects in Southern California (4 Photovoltaic, 2 Solar Trough, 1 Power Tower), reported from 2012-April 2016 showed that significant bat and insect mortality, including Monarch butterflies was occurring on solar projects. A total of 3,545 mortalities from 183 species (2012-April 2016) were recorded, from a mix of reports from incidental finds and systematic surveys. Many mortalities occur due to dehydration/heat stress after initial injury/stranding.  

Mortality to birds of Conservation Concern and Federal Endangered/Threatened species (including California Desert solar projects) impacted Yuma Ridgeway’s (Clapper) Rail, Willow Flycatcher, Yellow-billed Cuckoo, Peregrine Falcon, Bank Swallow, Western Grebe, Horned and Eared Grebes, American White Pelican, Burrowing Owl, and Calliope Hummingbird. The environmental assessment admits that more of the common species could die from collision or Lake Effect. This is obvious. While the numbers of more sensitive species would be lower, they are recognized as sensitive for a reason. It is obvious that more common species will have greater numbers, but because Endangered and Species if Special Concern have traditionally lower numbers, the mortality of fewer individuals is significant.  The EA should include required mitigation measures such as requiring the applicant to create a bigger space between solar panels, create an uneven, wavy surface for the panels to break up the lake effect and finally, surround each panel with a white rim to break up this lake effect. 

An Endangered Yuma Ridgeway rail was found dead on the Desert Sunlight Solar Project in 2013 and this may be the only one found while others were removed by scavengers. 

Mojave fringe-toed lizards have been observed crossing desert pavements in this area. The project will destroy linkage habitat for the species. Kevin Emmerich, who has experience surveying for the species, observed a Mojave fringe-toed lizard crossing desert pavement on the Oberon Solar site before construction in 2021. 

Couch’s spadefoot toad was not observed during surveys, but eight areas were identified as potential breeding habitat where water may accumulate after rainfall.

The cumulative buildout of large-scale solar in this region has led to habitat and linkage loss for larger mammals such as burro deer, desert bighorn sheep.

Water: 

The Chuckwalla basin aquifer is only 100 Acre Feet (AF) above overdraft. Exorbitant groundwater use for Utility Scale Solar construction is in large part responsible for this reduction from 12,000 AF over the last decade. 

Intersect Power apparently caused several wells to go dry when over pumping for construction of their Oberon Project caused a Cone of Depression. Other wells began pumping brackish water. 

Intersect Power alone would extract an additional 1000 Acre Feet of groundwater for the Easley Solar Project thus causing a 900 Acre Feet Overdraft of the Chuckwalla Valley Groundwater Basin and continuous degradation of water quality as freshwater mixes with high salinity ancient water layers. 

The recent Roux Associates analysis of the Easly Solar Hydrology studies states: 

“According to the water supply assessment/impact analysis prepared by GSI Water Solutions (2024), as part of that analysis, groundwater impacts due to pumping were evaluated based on groundwater modeling, largely based on previous modeling results (e.g., Fang, et.al., 2021). Although the GSI Water report uses the tools that are recommended in the Best Management Practices associated with the Desert Renewable Energy Conservation Plan, the report fails to provide a robust discussion of model development, calibration, sensitivity analyses, and limitations. Due to the absence of key foundational information in the prior modeling documentation which serves as a basis for the Project impact analysis, there are substantial information/data gaps that must be addressed for the drawdown and water budget estimations to be considered reliable. Additionally, aspects of the basin conceptual model (e.g.,groundwater recharge) are unrealistic as noted below and affect the reliability of the impact analysis.”

And concludes:

“Given the absence of foundational information related to the water supply assessment and the excessive estimation of groundwater recharge for Chuckwalla (and the corresponding implications of these deficiencies on the reliability of the Project impact analysis) we are unable to provide further substantive review to assess the proposed water-supply for the Project. Similarly, county decision-makers cannot make a fully informed decision as to whether the Project would substantially decrease groundwater supplies such that the Project (or cumulative projects) may impede sustainable groundwater management of the basin (Impact HWQ-2).

We recommend that the water supply assessment be revisited to address these issues. Further, we believe that a review of the underlying modeling (Fang, et.al., 2021) be performed by an independent research group such as the U.S. Geological Survey. If these modeling tools are going to be relied upon for land management decision-making, the high-degree of uncertainty, and potential unreliability leads to substantial risk in decision-making that would not only affect Chuckwalla Valley, but downgradient basins as well.”

Fugitive Dust:

Even with attempted mitigation, Intersect Power created a big fugitive dust problem from their Oberon Solar Project construction. When vegetation, biological soil crust and desert pavement are removed, there is nothing to hold airborne dust when the wind blows. This creates bad health problems for anybody living near the project.

Lithium Battery Fires:

What is the emergency response going to be if the Lithium battery banks go up in flames? How much water would be needed to control the fire? How many days or weeks would take to control? What are the health impacts of breathing the smoke? There have already been inverter fires on adjacent sites from the EDF Renewables projects. Who is responsible for paying the bill for the fire suppression? 

Noise:

Will the batteries be air cooled and how many fans will be needed to do this? The Yellow Pine Solar Project near Pahrump, Nevada cools its lithium batteries with automatic fans running all day. The noise lever is substantial and can be heard a half mile or more away. The location of Easley Solar is even hotter. How noisy will this be? 

Property Values:

It is disappointing to see that the Environmental Assessment for Easley Solar has no Environmental Justice or Socioeconomics category.

At the public meeting for Easley Solar in Riverside County in August 2024, residents of Lake Tamarisk made comments that stated that some residents are having considerable difficulty selling their properties due to the onslaught of large-scale solar projects and future applications surrounding the community. Even dropping the price by 30 percent has not worked and these people can’t sell their homes. It is hard to imagine anybody wanting to move to the Desert Center/Lake Tamarisk area after the large-scale solar industry ruined the entire area. It is very clear that Intersect Power does not care about these people. 

There should be a supplemental EA created to address the socio-economic impacts, environmental justice impacts and bad effects this project will have on the community

Conclusion: 

If the BLM were to select a No Action Alternative or even the Community setback Alternative D, Intersect Power still has made a substantial amount of money off of this region with the Oberon Solar Project. The BLM should not be proud of Oberon, it is setting negative precedents by violating the DRECP Conservation and Management Actions and setbacks, BLM also allowed Intersect to destroy 600 acres of Mojave desert tortoise Critical Habitat. This cannot happen again.

The most heartbreaking impact is the utter disregard the company has had for the community and how the BLM has allowed it to go this far.

Please pick an alternative that helps the community and natural resources of the area. Enough is enough.