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Renewable Portfolio Standards (RPS) in many states, including the six states analyzed for solarresources in the PEIS, reflects this old energy paradigm.But by mandating a market “add-on,” rather than a substitution, RPSs may be ineffective inreducing emissions or climate change. With no requirement to reduce fossil-fuel-generatedpower by an equivalent mega-wattage, RPS mandates are being used by Investor OwnedUtilities to create an artificial market above existing generation, even as efficiency andconservation reduce overall demand. In addition, utilities are playing the green card to justifylucrative new transmission infrastructure. If left unchecked, RPS policies could undermineefforts to reduce CO2 emissions, unnecessarily increase the cost of renewable energy, and delayby decades our transition to a new energy economy.By converting public lands to industrial energy factories in fragile, remote areas with massiverequirements for transmission at great cost to ratepayers and the environment, our renewableenergy policy is taking the least enlightened path possible, while attempting to create theillusion of innovation and progress.As of July 2012, eleven solar projects on over 36,000 acres had been approved on public lands.The projects range from 618 to 7,025 acres, with the average power plant exceeding 3,300acres. As of July, pending proposals numbered 76, and would cover a total of 695,387 acres of public land (email communication, July 10, 2012, from Jayme Lopez, Renewable EnergyCoordination Office, BLM). The scale, intensity, and pace of development on public lands areunprecedented. Massive solar power plants pose irreversible, long-term, cumulative ecosystem-and species-level threats to fragile desert and grassland biomes.In addition, allowing applications for and approving so many projects at once has renderedpublic review of environmental impact studies, let alone understanding of the cumulativeimpacts, nearly impossible.
Net GHG Reduction Unproven
No scientific evidence has been presented to support the claim that these projects reducegreenhouse emissions. Indeed, recent evidence suggests that the opposite may be true. Recentwork at the Center for Conservation Biology, University of California, Riverside, suggests that soildisturbance from large-scale solar development may disrupt Pleistocene-era caliche depositsthat release carbon to the atmosphere when exposed to the elements, thus “negat[ing] thesolar development C gains.” Researchers call for more studies on groundwater depletion,landscape fragmentation, vegetation type conversion and regional carbon budgets. Theresearchers warn that “moving forward with industrial-scale solar developments in undevelopeddesert habitats without quantifying the array of impacts…may unknowingly compromisebiodiversity and soil disturbance from large-scale solar ecosystem functioning.” (Allen,McHughen, Barrows. Impacts of Large-Scale Solar Development on Regional EcosystemDynamics: Critical Research Gaps. Desert Tortoise Council, 36
Annual Meeting and Symposium,February 18-20, 2011, Las Vegas, NV).In addition, sulfur hexafluoride (SF6), used primarily as an electrical insulator in high voltagetransmission of electricity, is the most potent of the six greenhouse gases regulated by the EPA,with a global warming potential 23,900 times that of CO2. One pound of SF6 is equivalent to