Some of the huge impacts of this proposed energy sprawl project include:

• The rare catus Sand cholla (Grusonia [or Opuntia] pulchella), a BLM sensitive species and Nevada fully protected species, was observed on the project area.

• 279 miles of new chainlink fencing would be constructed in the proposed alternative. This will fragment habitat and block large areas of connectivity for bighorn sheep, which regularly travel and disperse between mountain ranges.

• BLM’s Preferred Alternative would grade flat 35% of the desert, vegetation, and rangelands. 

• BLM estimates that 10,607 acre-feet per year of water will be needed for the solar field and battery storage areas for dust suppression during construction. Water would be purchased from a public or private entity and trucked in, or new wells within the solar project area would be drilled. 

• Greenlink West Transmission Project (approved) is needed to connect these massive utiluty-scale solar projects to load centers (read: data rcenters); the transmission projects should have been analyzed with the numerous remote desert solar applications waiting for interconnection to the grid but it was not. These solar applications are useless unless a large high-voltage transmission project is built in the future to connect them with the grid. Greenlink West was recently approved but will take years to construct, yet BLM is reviewing these solar projects as if they already have the ability to connect to load centers. These segmented environmental reviews hide the significant impacts of this massive build-out of Nevada’s Outback and public resources.

• The proposed action would allow solar projects to remove vegetation across 48,351 acres in the project area, which is unacceptable. This would include grading or disk and roll “to work existing vegetation into the underlying surface soils," or mowing in other places.

• Vegetation could be mulched and spread over the disturbed soil surface in order to try to control dust. This will not be enough to control dust, and will this mulched plant material include rare plants and cacti? This is not an ecologically responsible development method. Why is BLM not requiring vegetation to be left in place?

• 292 acres are proposed to be used as temporary laydown areas and would be bladed flat to remove all vegetation and level contours. Gravel may be placed on top of the surfaces to try to control dust and mud. This will fragment intact landscapes and vegetation communities, and restoration will not be possible for centuries. An Alternative should be analyzed that only allows 25 acres of laydown areas.

• The proposed on-site substation alone would cover 252 acres in an otherwise undeveloped basin, and create a large industrial metal structure with tall gen-tie lines, transformers, and other equipment. 

• The proposed action is estimated to have 393 acres of industrial Lithium battery energy storage systems. This could present a huge fire safety issue, as well as hazardous materials clean-up strain to the local communities. This could put a tremendous strain on local fire and hazmat crews, as well as fire water resources. 

The BLM, Battle Mountain District Office, is reviewing a programmatic-level Environmental Impact Statement and Resource Management Plan amendment to construct seven utility-scale photovoltaic solar facilities with battery energy storage systems on BLM-administered lands in Esmeralda County, Nevada. The seven proposed facilities would be geographically contiguous and encompass approximately 62,300 acres or 100 square miles of BLM-administered lands approximately 30 miles west of Tonopah, Nevada. The BLM is attempting to streamline the review of 7 massive solar facilities in one weakly written Environmental Impact Statement. The BLM is proposing to change their regional Resource Management Plan and allow the solar developers to build their solar panels on 10 percent slopes. At this point, they are only allowed to build on 5 percent slopes. This will impact viewsheds, wildlife and surface hydrology. 

The BLM will also need to "downgrade" the visual resources. How does BLM manage scenery? In this case, they would apply an industrial visual class called VRM Class IV to the entire region which would encourage major visual modifications to the landscape.

The projects would need to connect to the pending Greenlink West Transmission Line Esmeralda Substation which could transmit one gigawatt of energy, but there are far more projects proposed than there is capacity for. 

The project site contains 12,000-year-old Clovis points and cultural sites, several plant communities and over 20 rare plants, one of the most important linkage areas for desert bighorn sheep, outstanding visual resources, pronghorn antelope, and the area contains Lands with Wilderness Characteristics. 

In 2023, the Friends of Nevada Wilderness submitted a proposal to protect this part of the Big Smoky Valley as an Area of Critical Environmental Concern (ACEC) instead of sacrificing it for large-scale energy sprawl. The Esmeralda/Fish Lake ACEC would protect 849,170 acres of public lands in the region and if designated, would prevent the solar construction from taking place. We are supporting this as an alternative to the projects. OR we are supporting a pause on the review of the project until the ACEC can be fully evaluated in a seperate public review. The BLM has said the ACEC proposal is not needed. We don't agree.

But instead of completing thorough surveys over this gigantic area, BLM streamlines the EIS by only surveying some of the projects in a piecemeal fashion and admits that “results of the individual existing surveys are not necessarily representative of the conditions in the wider planning area”. Significant populations of these species could remain in the unsurveyed areas, and may be destroyed by solar development. This is another reason that we disagree with this programmatic approach—each solar application needs a separate EIS.

More surveys are warranted since these biological soil crusts, when ripped up and destroyed by grading, driving, crushing and soil disturbance halt Carbon sequestration, and other ecological values are lost.

In October, 2024, we found several species of lichens in the Monte Cristo Range just to the north of the planning area, which could also be found in the project footprints given more fieldwork.

Antelope and Bighorn Populations

The Draft EIS contains very little information about the significant bighorn sheep population located in the planning area. The Final EIS needs to analyze this better. Basins are important dispersal habitat for bighorn sheep movement between mountain range core areas.

279 miles of new chainlink fencing would be constructed in the proposed alternative (DEIS, page 2-4). This will fragment habitat and block large areas of connectivity for bighorn sheep, which regularly travel and disperse between mountain ranges.

The project area is a critical habitat linkage for desert bighorn core populations in Lone Mountain, the Silver Peak Range, and the Monte Cristo Range. Emigrant Peak and the Volcanic Hills are an important lambing ground. A guzzler was constructed in the Volcanic Hills to support wintering populations of desert bighorn. The projects will cut off linkages, movement corridors, and destroy winter foraging ground. 

The DEIS at 3-38 says that Lands with Wilderness Characteristics are generally roadless BLM-administered lands greater than 5,000 acres (or less if they meet size exception criteria, such as being adjacent to a designated wilderness area or a wilderness study area) that have maintained their natural character and are primarily undeveloped. Additionally, they provide outstanding opportunities for solitude or for primitive and unconfined recreation, and they may possess supplemental values, including those that are ecological, geological, or other features of scientific, educational, scenic, or historical value.

Then BLM says that these lands have not been evaluated through a land use planning effort. BLM needs to delay the review and possible approval of the E7 projects until the very outdated 1997 Tonopah Resource Management Plan is revised, and the pending Nevada Resource Management Plan Modernization Project is reviewed with full public participation for all the new information currently available.

BLM’s Preferred Alternative would grade flat, remove vegetation, drive and crush, mow, and disturb thousands of acres of the rangelands on allotments which overlap the solar project areas. 279 miles of new chainlink fencing would be constructed in the proposed alternative (DEIS on page 2-4), apparently excluding livestock on overlapping allotments. This is unacceptable. BLM discusses its multiple use mandate under the Federal Land and Policy Management Act (FLPMA) yet these massive solar project applications would convert multiple use lands to a single, virtually privatized, fenced-off, single use—that of solar energy production that would not even benefit local communities.

The DEIS described how three grazing allotments overlap the planning area: Monte Cristo, Sheep Mountain, and Silver Peak. Combined, these three allotments cover 49,210 acres (79 percent) of the planning area. Yet BLM will allow a solar developer to come in and disturb, grade, mow, and drive over sensitive grasslands in the area, without consequence? This needs to be explained and analyzed in the Final EIS. BLM needs to include all Land Health Assessments for these rangelands overlapping the planning area included in the Final EIS. How will this impact the economics of the county?

Under the Federal Lands and Policy Management Act (FLPMA), BLM has the responsibility to manage lands in a manner that will protect the quality of scenic values. The BLM meets statutory requirements with the Visual Resource Management (VRM) program described in BLM Manual 8400, Visual Resource Management; Handbook 8410-1, Visual Resource Inventory (BLM 1986a); and Handbook 8431, Visual Resource Contrast Rating (BLM 1986b). The VRM program establishes national consistency for inventorying, planning, and managing the qualities of BLM-administered lands’ visual resources.

Approving 100 square miles of solar projects leaves the BLM with no choice but to downgrade the VRM Class to VRM Class IV which is the major development class. This is not consistent FLPMA requirements to manage the land in a way that would protect the scenery.

Downgrading the VRM Class on 100 square miles of public land is inconsistent with the BLM’s Multiple Use mission. BLM lands are managed for Multiple Use and Renewable Energy has been written into FLPMA, but taking away the entire basin for solar energy is Single Use Management. Developing 62,000 acres for one use does not allow for other uses in the area. 

FLPMA sets forth the BLM's multiple-use and sustained yield mission, directing that public lands be managed for a variety of uses, ranging from conventional and renewable energy development, livestock grazing, conservation, mining, watershed protection, and recreation.

The area is considered an important, visually sensitive area. In fact. Parts of the Silver Peak Range are managed as VRM Class I with a goal of preserving the existing character of the landscape. Allowed Level of Change: This class provides for natural ecological changes; however, it does not preclude very limited management activity. The level of change to the characteristic landscape should be very low and must not attract attention.

The Visual Resources in the area have not been evaluated since 1997 – 26 years ago.  That is when the last update of the Tonopah Resource Management Plan happened. Since the last update of the RMP, several acres of Lands with Wilderness Characteristics (LWC) were identified and established, but because the RMP is so outdated, the VRM Class was never updated to recognize these LWC. 

Because there will be plan amendments in this review, the BLM has an opportunity to upgrade the VRM Class IV lands to VRM Class II.

The area is mostly undeveloped and the viewshed is intact on a landscape level. Because so much of the region qualifies for LWC, that means the Visual Resources were also evaluated when the LWC were established. Lands with Wilderness Characteristics should not be managed as VRM Class IV. The objective of VRM Class IV is to provide for management activities which require major modification of the existing character of the landscape. Allowed Level of Change: The level of change to the characteristic landscape can be high. Management activities may dominate the view and may be the major focus of viewer attention. Through careful siting, minimal disturbance, and repeating the basic elements of form, line, color, and texture within the existing setting.

If the Esmeralda/Fish Lake ACEC were evaluated properly, BLM would have an opportunity to upgrade the VRM Class in the region to VRM Class II with the objective of: retaining the existing character of the landscape. Allowed Level of Change: The level of change to the characteristic landscape should be low. Management activities may be seen, but should not attract the attention of the casual observer. 

There need to be more Key Observation Point (KOP) simulations with this review. Because the projects span 100 square miles, 10 KOP simulations is simply not enough. For an area this large, there should be at least 50 KOP simulations including one that shows construction night lighting and one that shows fugitive dust plumes. 

The KOP simulations that show the solar panels are very weak, faded and do not represent what a solar project actually looks like. 

There is no good KOP that shows what a solar project would look like on a slope. Below is an actual photo of the Silver State South Solar Project, Nevada which shows the slop visual impacts very well. 

If the BLM were to review a reduced footprint alternative, the visual impacts would not be as severe.  It is sad that an area with so many outstanding resources is being targeted for so much development.   

The proposed on-site substation alone would cover 252 acres (DEIS page 2-3) in an otherwise undeveloped basin, and create a large industrial metal structure with tall gen-tie lines, transformers, and other equipment. Is this in addition to the proposed Esmeralda substation which would be built with the approved Greenlink West Transmission Project? The cumulative impacts of so many new tall artificial structures needs to be analyzed.

Cultural Resources

The DEIS on page 3-23 says that portions of Big Smoky Valley in the planning areas includes Pleistocene Lake Tonopah. Archaeological evidence suggests that people have occupied the area beginning in the Paleoarchaic period (circa 13,000 to 7,700 years ago) through the Late Archaic period (up to circa 650 years ago), and into precontact times and the ethnohistoric period. Dozens of new archaeological sites were found during surveys throughout the solar application areas.

The proposed action is estimated to have 393 acres of industrial Lithium battery storage systems (DEIS at 2-3). This could present a huge fire safety issue, as well as hazardous materials clean-up strain to the local communities. This could put a tremendous strain on local fire and hazmat crews, as well as fire water resources. 

On September 17, 2024, a truck crash with one truck carrying Lithium batteries resulted in a fire and released of toxic materials on US 95, which necessitated the complete closure of the highway for many hours.[1] The truck melted from the intense and prolonged Lithium battery fire. 87,000 gallpages of water in tanker trucks needed to put out lithium truck fire (pers. Communication from Pahrump, NV personnel).

Congresswoman Dina Titus released the following statement following the crash:

“Today’s accident and fire on U.S. 95 involving a truck carrying lithium-ion batteries underscores the urgency for Congress to act on the ‘Thermal Runaway Reduction Act’, legislation I introduced last week in response to a similar accident on Interstate 15 in July. Without better regulation of the transport of these batteries, it is only a matter of time before these accidents and resulting fires take human lives. Furthermore, the resulting road closures and the amount of water needed to extinguish these fires have significant impacts on resources in our region. Congress needs to act quickly to enact live-saving regulations.”[2] 

BLM defers important emergency response plans to a later time after approval. These plans need to be developed now for public comment and included in the Final EIS:

"The applicants would develop an emergency response plan that presents the results of a    comprehensive facility hazard analysis and, for each identified hazard, a response plan.         The emergency response plan would assign roles and actions for on-site personnel and     responders; it would also designate assembly areas and response actions." DEIS age 2-7.

[1] https://www.8newsnow.com/news/local-news/fiery-semi-truck-crash-involving-lithum-batteries-closes-us-95-northwest-of-las-vegas/

[2] Id.

BLM to Review 7 solar projects on 158 Square Miles in one Small Environmental Impact Statement  

November 10th, 2023 - Tonopah NV

In an unprecedented move, the Bureau of Land Management is streamlining the environmental review for seven solar projects located on 118,631 acres (158 square miles) in one programmatic environmental impact statement.   

The 118,631 acres of public lands have been withdrawn from mineral entry for a period of two years in Esmeralda County’s Big Smoky Valley, near Tonopah, Nevada while the projects are being considered.  

“The BLM is now asking the public to think of every possible land-use impact on over 150 square miles of public land in just 30 days!” said Kevin Emmerich, Co-founder of Basin and Range Watch. 

All 7 project developers seek to connect to the Esmeralda Substation associated with the proposed Greenlink West Transmission Project. While the BLM is saying all projects will produce 5.3 GW of solar energy, the Esmeralda Substation would only be able to connect 1 GW of energy to the grid. 

The projects would require so much land to build, impacts to biological, groundwater, cultural, visual resources would be simply unavoidable. 

The seven projects are called: 

· Esmeralda Energy Center Project, proposed by Boulevard Associates LLC; 

· Gold Dust Solar Project, proposed by Gold Dust Solar LLC; 

· Lone Mountain Solar Project, proposed by Lone Mountain Solar LLC; 

· Nivloc Energy Project, proposed by Nivloc Solar LLC; 

· Red Ridge 1 Project, proposed by 335ES 8me LLC; 

· Red Ridge 2 Project, proposed by 336SP 8me LLC; and 

· Smoky Valley Solar Project, proposed by CG Western Renewables III LLC. 

“It appears that the Interior Department is seeking to approve Right of Ways for projects that will have no way to connect to the grid” Emmerich also said. “It still remains disturbing that the BLM would sacrifice entire basins that provide migration corridors for species like pronghorn”.

Nevada smokebush (Psorothamnus polydenius) blooming in November. Dunes and alkaline meadows in Big Smoky Valley next to Lone Mountain--all on the site of the proposed Gold Dust Solar Project.

Currently under the Western Solar Plan of 2012, developers are not permitted to build solar projects on slopes of 5 percent or more. This plan seeks to change that rule. In September 2023, Hurricane Hillery caused extensive flooding on the Silver State South Solar project located near Primm, Nevada. The project was built on an alluvial fan with a nearly 5 percent slope. Floodwater caused sheet flow to move the posts and foundations of the panels. If the BLM allows solar developers to continue to build on steeper slopes, there will be more damage like this in the future. 

 “Basin and Range Watch continues to be disappointed that the Biden Administration is aggressively targeting public lands for energy sprawl when so many viable alternatives exist for solar energy on rooftops, and in the built environment in general” said Emmerich.