Ivanpah SEGS - BLM ePlanning - Bureau of Land Management

Ivanpah SEGS - BLM ePlanning - Bureau of Land Management

Biological Assessment for the Ivanpah Solar Electric Generating System (Ivanpah SEGS) Project Prepared for Bureau of Land Management Prepared on beha...

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Biological Assessment for the Ivanpah Solar Electric Generating System (Ivanpah SEGS) Project Prepared for Bureau of Land Management

Prepared on behalf of

Solar Partners I, LLC; Solar Partners II, LLC; Solar Partners IV, LLC; and Solar Partners VIII, LLC

Prepared by 2485 Natomas Park Drive, Suite 600 Sacramento, CA 95833

December 2009

1

Contents Section ..................................................................................................................................... Page Contents........................................................................................................................................ iii Figures ................................................................................................................. iv Attachments ........................................................................................................ v Background ............................................................................................................................... 1-1 1.1 Introduction............................................................................................................. 1-1 Description of Proposed Action ........................................................................................... 2-1 2.1 Introduction............................................................................................................. 2-1 2.2 Project Features ....................................................................................................... 2-7 2.2.1 Solar Fields .............................................................................................. 2-7 2.2.2 Power Block ............................................................................................. 2-9 2.2.3 Stormwater Management .................................................................... 2-12 2.2.4 Power Lines and Substation................................................................ 2-13 2.2.5 Telecommunications ............................................................................ 2-14 2.2.6 Gas Line ................................................................................................. 2-14 2.2.7 Water Line ............................................................................................. 2-15 2.3 Construction .......................................................................................................... 2-15 2.3.1 Colosseum Road and Rerouted Trails ............................................... 2-18 2.3.2 Security and Desert Tortoise Fencing ................................................ 2-18 2.3.3 Vegetation Clearing and Cutting ....................................................... 2-19 2.3.4 Gas Pipeline ........................................................................................... 2-19 2.3.5 Water Line ............................................................................................. 2-20 2.3.6 Gen-tie Lines and Substation .............................................................. 2-20 2.3.7 Telecommunications Line ................................................................... 2-21 2.4 Operation ............................................................................................................... 2-23 2.4.1 Solar Fields ............................................................................................ 2-23 2.4.2 Water System ........................................................................................ 2-23 2.4.3 Concrete Holding Basins ..................................................................... 2-24 2.4.4 Waste Management .............................................................................. 2-24 2.5 Project Maintenance Activities ........................................................................... 2-24 2.5.1 Class I ..................................................................................................... 2-25 2.5.2 Class II .................................................................................................... 2-25 2.5.3 Class III .................................................................................................. 2-26 2.5.4 Class IV .................................................................................................. 2-26 2.5.5 Class V.................................................................................................... 2-26 2.6 Site Rehabilitation Plan ........................................................................................ 2-26 2.7 Facility Closure ..................................................................................................... 2-28 2.7.1 Temporary Closure .............................................................................. 2-28 2.7.2 Permanent Closure ............................................................................... 2-29 2.8 Minimization Measures ....................................................................................... 2-29

III

CONTENTS

2.8.1 Construction Minimization Measures ............................................... 2-30 2.8.2 Operation Minimization Measures .................................................... 2-36 2.9 Progress and Compliance Report ....................................................................... 2-39 Environmental Baseline .......................................................................................................... 3-1 3.1 Biological Setting ..................................................................................................... 3-1 3.1.1 Regional Overview ................................................................................. 3-1 3.1.2 Habitat and Vegetation .......................................................................... 3-1 3.1.3 Threatened and Endangered Plant Species ......................................... 3-3 3.1.4 Noxious Weeds ....................................................................................... 3-4 3.1.5 Wildlife Species ....................................................................................... 3-6 3.2 Environmental Baseline ......................................................................................... 3-7 3.2.1 Projects That Are Reasonably Foreseeable .......................................... 3-7 3.2.2 Projects That Are Not Reasonably Foreseeable ................................ 3-10 Status of Species and Habitat ................................................................................................ 4-1 4.1 Mojave Desert Tortoise (Gopherus agassizii) ......................................................... 4-1 4.1.1 Status......................................................................................................... 4-1 4.1.2 Natural History, Distribution, Abundance, and Habitat .................. 4-1 4.1.3 Survey Methodology .............................................................................. 4-4 4.1.4 Survey Results ......................................................................................... 4-4 Effects of Proposed Action ..................................................................................................... 5-1 5.1 Introduction ............................................................................................................. 5-1 5.2 Direct Effects ............................................................................................................ 5-1 5.3 Indirect Effects ......................................................................................................... 5-2 5.4 Cumulative Effects .................................................................................................. 5-3 References.................................................................................................................................. 6-5

Figures 1-1 2-1 2-2 2-3 2-4 2-5 2-6 2-7 3-1 3-2 4-1 4-2 4-3

IV

Vicinity Map Site Plan and Linear Facilities Construction Logistics Area Fiber Optic Route Trails Appearance of Site After Construction Proposed Gas Line Route Eldorado Ivanpah Transmission Project Access Roads Project Area Vegetation Map and Sensitive Geomorphic Features 2007 Desert Tortoise Survey Area Desert Tortoise Survey Results Translocation areas

CONTENTS

Attachments A B C D E F G H I

Draft Closure, Revegetation and Rehabilitation Plan Tortoise Fencing and Tortoise Guard Specifications No attachment Desert Tortoise Translocation/Relocation Plan Raven Management Plan No attachment Survey of translocation sites 2009 2008 Desert Tortoise Survey Report for Additional Ivanpah SEGS Action Area List of Observed Desert Tortoise Sign at Ivanpah SEGS in 2007

V

Background 1.1 Introduction Solar Partners I, LLC; Solar Partners II, LLC; Solar Partners VIII, LLC, the owners of the three separate solar plant sites, and Solar Partners IV, LLC, the owner of shared facilities required by the three solar plant sites, propose to develop a solar facility (together referred to as the Ivanpah Solar Electric Generating System, or Ivanpah SEGS) in the Ivanpah Valley about 4.5 miles southwest of Primm, Nevada. This Biological Assessment has been prepared in accordance with legal requirements set forth under Section 7 of the Endangered Species Act [ESA] (16 U.S.C. 1536(c)). The Mojave population of the desert tortoise (Gopherus agassizii) is a federally threatened species under the ESA. Solar Partners I, LLC; Solar Partners II, LLC; Solar Partners VIII, LLC, the owners of the three separate solar plant sites, and Solar Partners IV, LLC, the owner of shared facilities required by the three solar plant sites, are the proponent for the project. These four companies are Delaware limited liability companies. BrightSource Energy Inc. (BrightSource), a Delaware corporation, is a technology and development company, and the parent company of the Solar Partners entities. The Proposed Action is to develop three solar energy plant sites in the Ivanpah Valley located in San Bernardino County, California, 4.5 miles southwest of Primm, Nevada (Figure 1-1, all figures are located at the end of the section). The site is located in Township 17N, Range 14E, and Township 16N, Range 14E on land administered by the U.S. Bureau of Land Management (Bureau). Access to the site is via the Yates Well Road interchange on I-15 and Colosseum Road. The site is located 0.5 mile to the west of the Primm Valley Golf Club. BrightSource is seeking a separate right-of-way (ROW) grant from the Bureau for each of the three solar plant sites and for the shared infrastructure.

1-1

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Description of Proposed Action 2.1 Introduction The companies have filed SF 299 Right-Of-Way (ROW) grant applications for use of the land with the Bureau’s Needles Field Office. The Ivanpah SEGS will consist of three independent solar thermal electric generating facilities (or plants) that will be co-located approximately 1.6 miles west of the Ivanpah Dry Lake and 4.5 miles southwest of Primm, Nevada, in San Bernardino County, California (Figure 1-1). The project site will be located on federal property managed by BLM. The three Ivanpah SEGS facilities (see Figure 2-1) will have a combined net rating of approximately 400 megawatt (MW). The total Ivanpah SEGS project area consists of approximately 4,062 acres. Ivanpah 1 will require approximately 914 acres (1.4 square miles); Ivanpah 2 will require approximately 921 acres (1.4 square miles); and Ivanpah 3 is larger and will require approximately 1,834 acres (2.9 square miles). The developed areas for Ivanpah 1, 2, and 3 will cover a total of 3,671 acres (5.7 square miles). Following completion of low-impact design (LID) and issuance of permits, the proposed project will be constructed in three phases, and completed within 48 months (target completion by December 2013). Construction is planned in the following order: (1) Ivanpah 1 (the southernmost site; nominal 100 MW) and shared facilities; (2) Ivanpah 2 (the middle site; nominal 100 MW); and (3) Ivanpah 3 (the northern site, nominal 200 MW). Alternative sequencing of the facilities is a possibility, but in each case the shared facilities (administration/storage building, groundwater production wells, and portions of linear facilities) will be constructed in connection with the first plant’s construction. For purposes of this biological assessment, impacts have been placed into three categories. 1. Permanently disturbed areas: This includes those features that would remain after the project’s 50-year span1. They would include the Southern California Edison (SCE) substation and the paved portion of Colosseum Road from the Golf Club to the substation; the rerouted trails (i.e., the gravel road from the end of the paved portion of the rerouted Colosseum Road to where it connects with the Colosseum dirt road, the rerouted access tracks around the top of Ivanpah 3; and stabilized channel crossings. 2. Long-term disturbance areas: This includes facilities that will remain in place for the duration of the project. Examples include the solar plants, administration/warehouse building, water supply wells, monitoring well, and utility lines. Areas affected by these facilities will be revegetated following closure, which would be the same order as construction, with the exception that the shared facilities would be handled as part of the last phase that is closed. 3. Temporary disturbance areas: This includes areas that will be revegetated within 5 years from the time of disturbance. Facilities that fall into this category include the

1 The BLM right-of-way grant will be for 50 years, which includes construction and decommissioning/restoration. Therefore, the plant’s operating life will be between 40 and 45 years.

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2. DESCRIPTION OF PROPOSED ACTION

utility and roadway construction corridors and lightly graded areas within Ivanpah 2 and Ivanpah 3 (which will be revegetated within 1 year of completion of construction) and those areas within the Construction Logistics Area (CLA) that are used for construction (which will be revegetated once construction of all three solar plants is completed). A breakdown of the project’s permanent and long-term disturbance areas is presented in Tables 2.1-1 and 2.1-2. Most of the temporary disturbance will occur in the CLA between Ivanpah 1 and 2 (approximately 377 acres in size, see Figure 2-2) and the graded areas within Ivanpah 2 and Ivanpah 3. However, it will include the SCE substation (permanent disturbance), the administration/warehouse building, and shared utilities (long-term disturbances). Portions of the CLA will be used during construction for staging, laydown, heliostat fabrication, and temporary offices. Once construction has been completed, only the shared facilities will remain in this area. In addition to the CLA, temporary impacts would occur to approximately 8.6 acres that will be used for construction of the gas line tap station at the existing Kern River Gas Transmission (KRGT) pipeline, construction of the approximately 2,000-foot-long gas pipeline north of Ivanpah 3, and construction of the gas metering set for Ivanpah 1 and 2. A breakdown of the temporary disturbance areas is provided in Table 2.1-3. In addition, within the proposed site boundaries are about 7 miles of existing trails. Hence, the total impact area for the project site is about 4,055 acres (see Table 2.1-4). TABLE 2.1-1

Areas of Permanent Disturbance Components

Linear Feet

Acres

Ivanpah 3 12' dirt road from gas line to trail 699226 (east side of Ivanpah 3)

6,752

1.86

12' dirt road from trail 699198 to asphalt road between Units 2 & 3

1,572

0.43

12' rerouted trail 699226 from gas line west side

6,906

1.90

30' asphalt road between Ivanpah Units 2 & 3

4,751

3.93

12' dirt trail to mining claim

1,492

0.41

3,115

0.86

30' asphalt improved Colosseum Rd.

8,442

6.98

30' asphalt re-routed Colosseum Road

4,343

3.59

12' gravel road re-routed Colosseum Road to where it exits the CLA

2,452

0.68

24' access road to substation

1,761

1.21

Ivanpah 2 12’ rerouted trail 699198 (along west side of Ivanpah 2) CLA including improvements to Colosseum Road

Substation Diversion berms & channel around Substation TOTAL AREAS OF PERMANENT DISTURBANCE

2-2

16.10 8.30 46.25

2. DESCRIPTION OF PROPOSED ACTION

TABLE 2.1-2

Areas of Long-Term Disturbance Components

Linear Feet

Acres

Kern River Gas Transmission Line (KRGT) Tap Station 12' dirt service road from tap point to top of Ivanpah 3

0.34 2,011

0.55

7,103

1.96

Ivanpah 3 12' dirt road from trail 699226 to trail 699198 Ivanpah 3 Metering set 24' asphalt road to PB

0.01 3,872

Power block (PB)

2.67 14.96

Solar Power Towers

3.74

15' dirt road from PB to the four SPTs

10,300

3.55

12' dirt road from SPTs to corners

25,617

7.06

12' perimeter road around Ivanpah 3

40,778

11.23

Set back from property line

17.50

10' heliostat maintenance paths

210.98

Heliostat field

1150.18

Gen-tie towers from PB to top of Ivanpah 2

0.006

Ivanpah 3 fill stockpiles

3.98

Ivanpah 2 30' asphalt road from Ivanpah 3 to Colosseum Road

7,247

5.99

24' asphalt road to PB

2,229

1.54

Power block (PB) 12' dirt service road from PB to corners

13.17 15,176

4.18

Gen-tie towers along south side of Ivanpah 2

0.004

Ivanpah 3 gen-tie along west side of Ivanpah 2

0.007

Ivanpah 2 gen-tie from PB to end of Ivanpah 2 (4 tower footprints)

0.004

12' perimeter road around Ivanpah 2

24,167

Set back from property line 10' heliostat maintenance road

4.71 629,528

Heliostat field 12' dirt trail along southwest corner of Ivanpah 2 Ivanpah 2 channel crossings

6.66

144.52 606.16

4,148

1.14 0.31

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2. DESCRIPTION OF PROPOSED ACTION

TABLE 2.1-2 (CONT.)

Areas of Long-Term Disturbance Components

Linear Feet

Ivanpah 2 fill stockpiles

Acres 2.03

CLA including Improvements to Colosseum Road 12' dirt service road for double-circuit gen-tie line

1,898

0.52

Double-circuit gen-tie towers (area of 4 tower footprints)

0.004

Gas meter set for Ivanpah 1 & 2

0.02

24' asphalt road from re-routed Colosseum to Ivanpah 1

2,153

Admin Building (incl. entrance road) 12' dirt service road for monitoring well

8.90 866

Monitoring well 12' dirt service road for production wells

0.24 0.002

1,075

Production wells 12' dirt service road from Ivanpah 1 to Substation

1.48

0.30 0.005

2,867

Gen-tie towers from Ivanpah 1 to Substation

0.79 0.005

40-acre succulent storage & stockpile area

40.00

CLA fill stockpile

0.91

Ivanpah 1 24' asphalt road from edge of Ivanpah 1 to PB

3,361

2.31

Gas & water line corridor to PB

3,361

0.00

Power block (PB)

13.17

Gen-tie towers from PB to Ivanpah 1 (area of 6 tower footprints)

0.005

12' dirt service road from PB to corners

12,020

3.31

12' perimeter road around Ivanpah 1

23,857

6.57

Set back from property line 10' heliostat maintenance road Heliostat field Ivanpah 1 fill stockpiles TOTAL AREAS OF LONG-TERM DISTURBANCE

2-4

8.79 636,325

146.08 730.30 1.57 3,184.43

2. DESCRIPTION OF PROPOSED ACTION

TABLE 2.1-3

Areas of Temporary Disturbance Components

Linear Feet

Acres

Kern River Gas Transmission Line (KRGT) Tap Station Construction Area Gas Line from tap point to top of I-3

0.92 2,011

1.75

15,427

13.46

Construction corridor for 30' asphalt road between Units 2 & 3

4,751

1.53

Construction corridor for 24' asphalt road to PB

3,872

1.24

Gas line from metering set to PB

5,823

0.00b

Water line from metering set to PB

5,785

0.00b

Construction corridor for gas & water line

5,823

3.74

Gen-tie corridor from PB to top of Unit 2

4,065

0.36

Ivanpah 3 Gas Line Corridor 50' construction area (east side)

Ivanpah 3 graded areas

380.00

Ivanpah 2 Construction corridor for 30' asphalt road from Ivanpah 3 to Colosseum

7,247

2.33

Gas & water line corridor to PB

3,972

2.55

Construction corridor for 24' asphalt road to PB

2,229

0.72

Ivanpah 3 gen-tie along south side of Ivanpah 2

3,296

0.25

Ivanpah 3 gen-tie along west side of Ivanpah 2

5,371

0.38

Ivanpah 2 gen-tie from PB to end of Unit 2

2,322

0.20

Graded areas

123.00

CLA Including improvements to Colosseum Road Construction corridor for 30' asphalt improved Colosseum Rd.

8,442

Tire wash/concrete washout off Colosseum Road

2.71 1.04

Construction corridor for 30' asphalt re-routed Colosseum Road

4,343

1.40

Construction corridor for 24' access road to substation

1,761

0.57

Ivanpah 2 & 3 gen-tie to substation construction corridor

1,898

0.35

Construction of double-circuit gen-tie towers

0.20

Construction area for gas meter set for Ivanpah 1 & 2

0.92

Construction corridor for 24' asphalt road from re-routed Colosseum to Ivanpah 1

2,153

0.69

Construction corridor from wells to main line

1,075

0.69

Gen-tie line from Ivanpah 1 to Substation

2,867

0.53

Construction of gen-tie towers from Ivanpah 1 to Sub

0.32

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2. DESCRIPTION OF PROPOSED ACTION

TABLE 2.1-3

Areas of Temporary Disturbance Components

Linear Feet

Construction parking

Acres 1.53

Contractor Trailer area

18.57

Equipment Laydown

20.46

CLA area available for construction use

247.19

Ivanpah 1 Construction corridor for 24' asphalt road from edge to PB Construction of gen-tie towers from PB to end of Ivanpah 1 TOTAL AREAS OF TEMPORARY DISTURBANCE b

3,361

1.08 0.29 830.97

Located within the dirt access road. No additional impact.

TABLE 2 TABLE 2.1-4

Net Disturbed Area Acres Total Disturbed Area of the Solar Plant Less existing trails Net Disturbed Area of the Solar Plant

4,061.65 - 6.96 4,054.69

In addition to the project site, the action area includes the installation of a fiber optic line. This fiber optic route consists of two segments. The first segment is from Ivanpah substation to Mountain Pass substation using existing poles shown in Figure 2-3. The second segment is from Mountain Pass substation to an interface point to be designated by the local telecommunication carrier. In both segments the fiber optic cable would be installed on the existing distribution line poles. Therefore, the action area includes the project site plus the route for the fiber optic line. Concurrent with the Bureau’s ROW filing process, BrightSource also filed an Application For Certification (AFC) with the California Energy Commission (CEC). BrightSource has been informed by both the CEC and the Bureau of their intention to conduct a joint environmental review of the proposed project. The CEC has issued its Final Staff Assessment and the Bureau has issued a draft Environmental Impact Statement. The two agencies will coordinate their analysis but will issue separate decisions.

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2. DESCRIPTION OF PROPOSED ACTION

2.2 Project Features 2.2.1 Solar Fields The approximate size of the area for Ivanpah 1 (Phase 1) is 914 acres; for Ivanpah 2 (Phase 2) the area is 921 acres; and for Ivanpah 3 (Phase 3) the area is 1,834 acres (Figure 2-1). The following sections describe the major components of the solar fields.

2.2.1.1 Security and Desert Tortoise Fence Prior to clearing vegetation and site grading, for the construction logistics area and each project site, the boundary would be permanently fenced with an 8-foot-high chain-link for security purposes and permanent desert tortoise exclusionary fencing would either be attached to the base of the security fence or installed outside the security fence to allow construction of linear facilities. A permanent I-beam design desert tortoise guard would be installed to allow equipment access to the fenced sites and exclude desert tortoises. The specifications for the proposed desert tortoise guard are included in Attachment B. All tortoise exclusion fencing, tortoise guards and combined tortoise/security fence will be inspected on a regular basis (at least twice per year and after each storm event) sufficient to maintain an effective barrier to tortoise movements. Inspections would be documented in writing and include any observations of damaged fencing. All fence damage will be repaired in a timely manner to ensure that tortoises do not travel through damaged sections. Similarly, tortoise guards will be cleaned out of deposited material underneath them in a timely manner to ensure that any tortoise that falls underneath has a path of escape without crossing the intended barrier. Debris will be removed that accumulates along the fence line or under the tortoise guards.

2.2.1.2 Colosseum Road and Rerouted Trails Construction and permanent access would be from Colosseum Road to the project entrance road (Figure 2-1). Colosseum Road is an existing dirt road, which will be paved (30-feetwide, 3-foot-wide dirt shoulders on each side, 2 lanes) for a 1.6-mile length from the Primm Valley Golf Club to the project site2. The project would re-route a portion of Colosseum Road around the southern end of the Ivanpah 2 plant site for a distance of 0.8 miles, which will also be a 30-foot paved 2-lane road, then continue as an 8-foot-wide dirt road another 0.5 mile to connect to the point where the existing Colosseum dirt road would exit the Ivanpah 2 site boundary. In addition, paved access roads would be created to access the power blocks of the three Ivanpah plant sites within the fenced solar sites. Existing dirt trails that traverse the site will be re-routed either around the project site or to a proposed paved access road. Each re-routed dirt trail will be 8 to 12 feet wide (to match the existing trail) and will be reconnected to the original dirt trail on the other side of the project site (see Figure 2-4). Tortoise gates will be installed to prevent tortoise from entering internal roads. A list of trails in the area and the project’s impact upon them is presented in the following table.

2 A portion of this road has been recently paved from the golf club to their wells, but may lack sufficient road base to support construction vehicles.

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2. DESCRIPTION OF PROPOSED ACTION

TABLE 2.2-1

Modification Status for Bureau Trails in Proximity of Ivanpah Site Bureau Trail #

Proximity to Ivanpah SEGS Component

Status

699135

North of Project Site

Remains Open – no impact

699194

South of Project Site, runs between Trails 699238, 699244, and Power Line

Remains Open – no impact

699195

Southwest of Project Site, runs between Power Line and Colosseum Trails

Remains Open – no impact

699197

Southwest of Project Site

Remains Open – no impact

699198

Runs through southern portion of Ivanpah 3 and northern portion of Ivanpah 2

Modification required - on east side of Ivanpah 3, close trail and connect with dirt road to be constructed that connects to a road between Ivanpah 2 and 3. Follow new road to reconnection with 699198 on the west side of Ivanpah 2 as shown on Figure 2-4.

699199

South of Project Site

Remains Open – no impact

699221

South of Project Site, runs between Trails 699194 and 699199

Remains Open – no impact

699223

South of Ivanpah 2, runs between the Wash and Colosseum Road Trails.

Remains Open – no impact

699226

Runs through northern portion of Ivanpah 3

Modification required - relocate trail around the north side of Ivanpah 3, as shown on Figure 2-4.

699227

West of Project Site

Remains Open – no impact

699232

West of Project Site

Remains Open – no impact

699238

East of Project Site and goes around Primm Valley Golf Club and continues south

Remains Open – no impact

699239

East of Project Site

Remains Open – no impact

699244

Southeast of Project Site

Remains Open – no impact

699617

Goes around metamorphic hill and connects to Trail 699238.

Remains Open – no impact

Colosseum Road

Runs through the southern portion of Ivanpah 2

Modification required - realign and improve road as shown on Figure 2-4 to follow the existing power line corridor and then follow the southern boundary of Ivanpah 2 to the original Colosseum Road Trail southwest of Ivanpah 2.

2.2.1.3 Heliostats and Solar Receivers The solar fields would consist of one heliostat (mirror) array constructed within each 100-MW plant site and five heliostat arrays constructed within the 200-MW plant site. Each heliostat array would be arranged around a single centralized solar power tower (SPT). An

2-8

2. DESCRIPTION OF PROPOSED ACTION

artist rendering is provided as Figure 2-5. The heliostats would automatically track the sun throughout the day and reflect the solar energy to the SPT. It is estimated that the 100 and 200 MW plant sites would contain approximately 55,000 and 104,000 heliostats, respectively. Each heliostat consists of two mirrors. Each mirror is 7.22 feet wide by 10.5 feet high (2.20 meters by 3.20 meters) yielding a reflecting surface of 75.8 square feet (7.04 square meters).

2.2.1.4 Solar Power Tower Height The SPT height for all three solar plant sites would be 459 feet (140 meters). In addition, FAA-required lighting and a lightning pole would extend above the top of the towers approximately 5 to 10 feet (1.5 to 3 meters).

2.2.2 Power Block All three units (Ivanpah 1, 2, and 3) will have their own individual power block. The size of both Ivanpah 1 and 2 power blocks (including the diversion berms and stormwater channel) will be approximately 13.17 acres; whereas, Ivanpah 3 power block will be approximate 14.96 acres. Each power block will contain, but is not limited to, the following equipment: TABLE 2.2-2

Power Block Equipment List Steam Turbine

Power Tower

Generator

Generator Step-up Transformer

Auxiliary Boiler

Unit Auxiliary Transformer

Air Cooled Condenser

SUS Transformer

Feed Water Heaters

Raw Water/Fire Water Tank

Boiler Feed Pumps

Demineralized Water Tank

Plant Services Building

Raw Water Forwarding Pumps

Water Treatment Equipment Area

Demineralized Water Forwarding Pumps

Underground Gas Pipeline

Electrical Substation

Emergency Evaporation Ponds

115 kV Generation Tie Line

Condensate Tank/Pump

Waste Water Tank

Emergency Generator

Domestic Water System

Local Control Building

Concrete Holding Basins

Solar Superheater/Reheater Receiver

Access Roadway

2.2.2.1 Power Cycle The solar plant’s power cycle is based on a Rankine cycle turbine with three pressure stage casings. Primary thermal input is via solar receiver boilers, superheater and reheaters at the top of four distributed power towers. Live superheated steam enters a high pressure turbine

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2. DESCRIPTION OF PROPOSED ACTION

casing at 140 bar and 1,004°F (540°C). It leaves the high pressure casing via two extractions to high pressure preheaters, and is exhausted to a reheat circuit. In Ivanpah 3, the reheat steam is heated in a solar reheater (similar to the solar boiler), at the top of a power tower located in the power block adjacent to the turbogenerator. The reheated steam enters an intermediate pressure turbine casing at 3.5 bar and 896°F (480°C). It leaves the intermediate pressure casing via two extractions – one to a de-aerator and one to a preheater. The IP exhaust then enters the low pressure casing at 4.5 bar and 432°F (222°C). Exhaust steam at 0.1265 bar is condensed in an air-cooled condenser. Condensate is sent from the condenser well through three LP preheaters, to the de-aerator, which also serves for feedwater reserve storage and is the point of feedwater make-up injection. From the deaerator, high pressure feedwater pumps send feedwater through two high pressure preheaters out to the solar field boilers. The major components of the combined-cycle power block are described below.

2.2.2.2 Steam Generation Subsystems The steam generation subsystems consist of the receiver boiler and blowdown systems. The receiver boilers collect solar energy from the heliostat mirrors and transfer it to feedwater for steam production. This heat transfer produces steam at the pressures and temperatures required by the steam turbine. The blowdown system maintains feedwater quality. The system includes safety and auto relief valves and processing of continuous and intermittent blowdown streams.

2.2.2.3 Steam Turbine Generator Subsystems The steam turbine system consists of a condensing steam turbine generator with reheat, gland steam system, lubricating oil system, hydraulic control system, and steam admission/induction valving. High pressure and intermediate pressure steam from the superheater receiver enters the associated steam turbine sections through the inlet steam system. The steam expands through multiple stages of the turbine, driving the generator. On exiting the low pressure turbine, the steam is directed into the surface condenser.

2.2.2.4 Distributed Control System The Distributed Control System will be a redundant microprocessor-based system that will provide the following functions: •

Control the heliostat mirrors, steam turbine generator, and other systems in response to unit load demands (coordinated control)



Provide control room operator interface



Monitor plant equipment and process parameters and provide this information to the plant operators in a meaningful format



Provide visual and audible alarms for abnormal events based on field signals or software-generated signals from plant systems, processes, or equipment

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The Distributed Control System will have functionally distributed architecture comprising a group of similar redundant processing units linked to a group of operator consoles and an engineer workstation by redundant data highways. Each processor will be programmed to perform specific dedicated tasks for control information, data acquisition, annunciation, and historical purposes. Plant operation will be controlled from the operator panel located in the control room. The operator panel will consist of two individual video/keyboard consoles and one engineering workstation. Each video/keyboard console will be an independent electronic package so that failure of a single package does not disable more than one video/keyboard. The engineering workstation will allow the control system operator interface to be revised by authorized personnel.

2.2.2.5 Boiler Feedwater System The boiler feedwater system transfers feedwater from the low pressure steam turbine to the solar receiver boilers. The system will consist of two pumps, each pump sized for 100 percent capacity for supplying all boilers. The pump will be multistage, horizontal, motor-driven with intermediate bleed-off, and will include regulating control valves, minimum flow recirculation control, and other associated piping and valves. One 100 percent capacity spare pump will be available for all boilers.

2.2.2.6 Condensate System The condensate system will provide a flow path from the condenser hotwell to the boiler feed pumps. The condensate system will include three, 50-percent capacity multistage, vertical, motor-driven condensate pumps.

2.2.2.7 Demineralized Water System The demineralized water system will consist of a filter and demineralizer train from an onsite water treatment system consisting of activated carbon filters, de-ionization columns, and a mixed bed polisher. The unit will be a self-contained trailer-mounted unit. Demineralized water will be stored in a 25,000-gallon demineralized water storage tank; boiler feedwater make-up water will be stored in another 25,000-gallon tank.

2.2.2.8 Power Cycle Makeup and Storage The power cycle makeup and storage subsystem provides demineralized water storage and pumping capabilities to supply high-purity water for system cycle makeup and chemical cleaning operations. Major components of the system are the demineralized water storage tank, providing for more than a 14-hour supply of demineralized water at peak load, and two, 100-percent capacity, horizontal, centrifugal, cycle makeup water pumps.

2.2.2.9 Compressed Air The compressed air system provides instrument air and service air to points of use throughout the facility. The compressed air system will include two, 100-percent capacity motor-driven air compressors, two air dryers with prefilters and after filters, an air receiver, instrument air header, and service air header. All instrument air will be dried. A control

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valve will be provided in the service air header to prevent high consumption of service air from reducing the instrument air header pressure below critical levels.

2.2.2.10 Fuel Availability Natural gas will be delivered to the power block via pipeline as described below. Each solar plant will have a single 100 percent capacity fuel gas booster compressor to ensure that natural gas is delivered at the proper pressure.

2.2.2.11 Steam Boiler Each solar plant includes a partial-load steam boiler, which will be used for thermal input to the turbine during the morning start-up cycle to assist the plant in coming up to operating temperature more quickly. The boiler will also be operated during transient cloudy conditions, to maintain the turbine on-line and ready to resume production from solar thermal input, after the clouds pass. After the clouds pass and solar thermal input resumes, the turbine will be returned to full solar production and the boilers will be shut down.

2.2.2.12 Domestic Water Use and Wastewater Management A small filtration and purification system at the administration/warehouse building will be used to provide potable water for domestic, including sanitary, uses (sinks, showers, and toilets). Drinking water may also be trucked to the site. The power block sites will have porta-potties (i.e., portable toilets with self-contained hand wash stations), and use bottled water. Portable toilets will be serviced by a waste management firm on a regular basis, depending on the number of toilets and staff at each facility. A septic system and leach lines will be used at the administration and maintenance complex to treat domestic wastewater.

2.2.2.13 Concrete Holding Basins Two concrete-lined holding basins about 40 feet wide by 60 feet long by 6 feet deep would be included in the power block for each project site. They would be used during boiler commissioning and emergency outfalls from any of the processes.

2.2.3 Stormwater Management Stormwater runoff at the site is predominantly sheet flow from west to east, eventually discharging into Ivanpah Dry Lake. In support of a low-impact design (LID), with exception of the power block areas, solar field development will maintain sheet flow where possible, with water exiting the site in existing natural contours and flows. In addition, the majority of the project site will maintain the original grades and natural drainage features and, therefore, requires no added storm drainage control. Existing small to moderate ephemeral washes will remain intact at locations capable of being traversed by installation equipment. Large ephemeral washes will be graded to the extent necessary to provide equipment access. In limited areas such as the power blocks and administrative areas, a storm drainage system will be designed using diversion channels, by-pass channels, or swales to direct run-on flow from up-slope areas, and run-off flow through and around each facility. The design will be developed for sheet flow for all storm events less than or equal to a 100-year, 24-hour storm event. Diversion channels will be designed so that a minimum ground surface slope of 0.5 percent shall be provided to

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provide positive, puddle-free drainage. Storm drainage channels will be sized to convey floods at relatively low velocities that will not result in significant scour or particle transport, and may be lined with a non-erodible material such as compacted rip-rap, geosynthetic matting, or engineered vegetation. Stormwater will be allowed to sheet flow across roads. An “Irish Bridge” style crossing will be constructed where permanent asphalt paved access roads cross major ephemeral washes on the site. The Irish Bridges will be constructed of reinforced concrete or gabion baskets and are being designed to prevent the scour and washout of major asphalt access roads during storm events. Grading within the power block, switch yard and administrative building area are to be designed to provide positive drainage of rainfall runoff away from each structure. In general, grade shall be sloped away from the building walls and equipment at a minimum pitch of two percent to provide surface drainage. Slopes of excavated areas shall be protected from rutting and scouring by means of armoring with local stone. Surface water will not be permitted to flow uncontrolled down any embankment slope. Where grade surfaces are flat or rise from the edge of an excavation, the top of the excavated slope will be protected by a low berm that is to be continuous and extend to a point at each end where the grade has a positive slope away from the excavation. The discharge from such protective system will be led to the edge of the excavation in order to prevent edge and slope scour. All surface runoff during and after construction will be controlled in accordance with the requirements of the Construction Stormwater Pollution Prevention Plan (CH2M HILL, 2009b), National Pollutant Discharge Elimination System (NPDES) Construction Runoff Permit, the requirements of the San Bernardino Water Quality Management Plan manual, and all other applicable laws, ordinances, regulations and standards.

2.2.4 Power Lines and Substation Ivanpah 1, 2, and 3 would be interconnected to an existing Southern California Edison (SCE) grid through an upgraded El Dorado– Baker–Coolwater-Dunn Siding-Mountain Pass 115-kV line passing between Ivanpah 1 and 2 on a northeast-southwest utility corridor. A substation would be constructed between Ivanpah 1 and 2 that would be used to connect Ivanpah SEGS to the electrical grid. The approximate location of the substation is shown in Figure 2-1. The substation dimensions would be about 835 feet wide by 850 feet long— approximately 16.2 acres in size with another 8.3 acres being used for a stormwater diversion berm and channel. In addition, a 24 foot wide asphalt road (shown in Figure 2-2) about 1,760 feet long will be needed to connect the substation to the re-routed Colosseum Road (on the south side of Ivanpah 2). The 115-kV transmission generation tie line (gen-tie line) from the edge of the Ivanpah 1 solar field to the substation would be approximately 2,870 feet long. The Ivanpah 2 and 3 gen-tie lines extend approximately 2,320 feet and 9,440 feet, respectively, before coming together. The combined gen-tie line then extends approximately 1,900 feet to the substation. There would be a 12 foot wide dirt service road running alongside the gen-tie lines. Each circuit would be supported by single-pole structures at appropriate intervals (generally about 750 feet apart) with final heights as determined during detailed design. The shared gen-tie line for Ivanpah 2 and 3 would be carried on a double-circuit pole line. The

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lines would be insulated from the poles using porcelain insulators. The gen-tie lines would be constructed to be raptor safe, in conformance with Suggested Practices for Raptor Protection on Power Lines: the State of the Art in 1996 (APLIC 1996).

2.2.5 Telecommunications The proposed Ivanpah substation would also require new telecommunication infrastructure to be installed to provide protective relay circuit, Supervisory Control and Data Acquisition (SCADA) circuit, data, and telephone services. The telecommunication path from Ivanpah substation to a local carrier facility interface in the Mountain Pass area consists of approximately 8 miles of fiber optic cable to be installed overhead on existing poles and new underground conduits to be constructed in the substation and telecom carrier interface point. This fiber optic route consists of two segments. The first segment would be from Ivanpah substation to Mountain Pass substation using the existing Nipton 33-kV distribution line poles built along the transmission line corridor that crosses between Ivanpah 1 and 2. The second segment would be from Mountain Pass substation to the telecommunications facility approximately 1.5 miles away at an interface point to be designated by the local telecommunication carrier. The fiber optic cable along this portion of the route would be installed on the existing Earth 12 kV distribution line poles.

2.2.6 Gas Line Natural gas would be used as a supplementary fuel for project operation. Each phase of the project includes a small package natural gas-fired start-up boiler to provide heat for solar plant start-up and during temporary cloud cover. Natural gas would be obtained by the construction of a new 6 mile long, 4 to 6 inch distribution pipeline from the existing Kern River Gas Transmission (KRGT) pipeline located approximately 0.5 mile north of the Ivanpah 3 site (see Figure 2-6). A permanent gas metering station (100 feet x 150 feet) and a temporary construction area (200 feet x 200 feet) would be located at the point of connection. From the tap station, the natural gas line would head south along the western edge of Ivanpah 3 to a metering station (10 feet x 40 feet) near its southeast corner. Although the gas line and metering station would be within the area that was surveyed, they would be located outside the project’s fenced heliostat fields and a dirt access road would follow the pipeline so that the gas company has access to it for maintenance. From the metering station at Ivanpah 3, the gas line (and 12-foot-wide dirt access road) would continue along the eastern edge of Ivanpah 2 to another metering station (20 feet x 40 feet) on the southeast corner, below Colosseum Road that would service Ivanpah 1 and 2. Again, the gas line and metering station would be located within the project area, but outside the fenced heliostat field. From that metering station, the gas line to Ivanpah 1 would be located alongside or under the 30-foot-wide paved access road that goes from Colosseum Road past the Administration Building to the Ivanpah 1’s power block (see Figure 2-6). A gas-metering station would be required at the KRGT tap point to measure and record gas volumes. In addition, facilities would be installed to regulate the gas pressure and to remove any liquids or solid particles. Construction activities related to the metering station and metering sets would include grading a pad and installing aboveground- and underground gas piping, metering equipment, gas conditioning, pressure regulation, and pigging facilities. Either a distribution line or photovoltaic cells and batteries would be used

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2. DESCRIPTION OF PROPOSED ACTION

for metering station operation lighting and, communication equipment. Perimeter chain link fencing for security would also be installed. Gas line pigging facilities would be located at strategic locations along the gas pipe line. Periodic gas line pigging is required to remove liquids and debris within the pipeline, which improves gas flow. Also, inspection pigs would be used to monitor the pipeline integrity to ensure the pipeline is in proper working order. With routine maintenance, the gas lines will run more efficiently and will minimize product losses during launch and capture.

2.2.7 Water Line Two new groundwater production wells would be drilled and developed to provide raw water for the Ivanpah SEGS project. The water would be drawn from one of the two wells that would be located near the northwest corner of Ivanpah 1 (see Figure 2-1), with the other well serving as 100 percent redundant backup. To reduce impacts on the land and provide operating efficiencies, the wells would provide water to all three plant sites. The 400-MW capacity of the 3 plant sites would require up to 46 gallons per minute (gpm) of raw water make-up, which would be drawn from the wells and distributed to the plant sites via underground high density polyethylene (HDPE) or polyvinyl chloride (PVC) pipe. Each plant site would have a raw water tank with a capacity of 250,000 gallons. A portion of the raw water (100,000 gallons) is for plant site use while the majority would be reserved for fire water. There would be a 12-foot-wide dirt access road to the wells. The water supply line would go from the wells along the dirt access road to the paved road on the northwest corner of Ivanpah 1 and run north to Administration Building, Ivanpah 2 and Ivanpah 3 along the same corridor as the gas line; and south to Ivanpah 1 along the paved access road leading to the power block. This new water distribution line would be approximately 1,075 feet long from the wells to the main line going to each of the plant sites. In addition, a monitoring well would be installed southeast of the Administration Building near the northwest corner of Ivanpah 1 (see Figure 2-1). The permanent area required for the installation of the monitoring well and the approximately 870-foot-long, 12-foot-wide dirt access road to it is 0.24 acres.

2.3 Construction After the California Energy Commission (CEC) license and BLM right-of-way (ROW) grant have been issued, the proposed project will be constructed in three phases. Construction is anticipated to be performed in the following order: (1) the Construction Logistics Area; (2) Ivanpah 1 (the southernmost site) and other shared facilities; (3) Ivanpah 2 (the middle site); and (4) Ivanpah 3 (the 200-MW plant on the north). However, given that the three plants will receive separate, independent licensing approvals, it is possible that the order of construction may change. The shared facilities will be constructed in connection with the first plant construction, whether it is Ivanpah 1, 2, or 3.Construction is planned to take place over approximately 48 months, from the first quarter of 2010 to the fourth quarter 2013. Commercial operations are expected to commence in 2011 at Ivanpah 1, in 2012 at Ivanpah 2, and in 2013 at Ivanpah 3. Major milestones are listed in Table 2.3-1.

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TABLE 2.3-1

Project Schedule Major Milestones Activity

Date

Begin Construction

First Quarter 2010

Ivanpah 1 Commercial Operation

Fourth Quarter 2011

Ivanpah 2 Commercial Operation

Fourth Quarter 2012

Ivanpah 3 Commercial Operation

Fourth Quarter 2013

There would be an average workforce of approximately 474 construction craft people, supervisory, support, and construction management personnel onsite during construction. The peak construction site workforce level (959 workers) is expected to occur in Month 32. Typically, construction would be scheduled to occur between 5 a.m. and 7 p.m. on weekdays and Saturdays. Additional hours may be necessary to make up schedule deficiencies, or to complete critical construction activities (e.g., pouring concrete at night during hot weather and working around time-critical shutdowns and constraints). During some construction periods and during the startup phase of the project, some activities would continue 24 hours per day, 7 days per week. During summer, construction may start substantially earlier to avoid the heat of the day. Construction laydown and parking would occupy areas of the solar plant sites within the heliostat fields as well as the Construction Logistics Area between Ivanpah 1 and Ivanpah 2 (see Figure 2-2). For example, while constructing the power block, materials for the construction of the power block as well as vehicles for those workers would be parked near the power block. Similarly, steel pipes to be used for the heliostats would be laid out in the heliostat field near where they are to be placed. The Construction Logistics Area would also contain additional equipment laydown and worker parking and trailer areas. Temporary construction support facilities within the construction logistics area (primarily located in Area E on Figure 2-2) are expected to include: • • • • • • • •

10 single-wide full-length trailer offices or equivalent Chemical toilets/porta-potties Parking for 200 vehicles 5 tool sheds/containers Equipment parking for 20 pieces of construction equipment Construction material laydown area Solar field equipment laydown area Fabrication sheds

A construction equipment noxious weed wash station would be constructed within the project site (currently planned in Area E) or within an alternate area approved by the Bureau. Table 2.3-2 provides a construction sequence for the project.

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TABLE 2.3-2

Ivanpah SEGS Construction Sequence Preliminary Stage Site and construction logistic area (CLA) fence lines are staked by land surveyors Improved Colosseum Road location staked by land surveyors Approved biologists survey staked borders of internal perimeter road and area of Colosseum Road and translocate/relocate all desert tortoises found 10-foot-wide perimeter road (within the staked fence line) is cleared of all vegetation and graded Fencing company installs combined tortoise/security fence along staked fence line and installs tortoise gates at entrances Fencing company installs tortoise exclusion fence along Colosseum Road. Area within fenced perimeters is surveyed by biologists and desert tortoises translocated/relocated. Area is opened for public salvage of succulent plants, if required by the Bureau Site Development Stage Vegetation mowed to within 12 to 18 inches of ground surface Locations of roads, buildings and structures staked by land surveyors Pads, parking areas and construction laydown areas graded if needed, and construction trailers moved to locations within the CLA Rough Grading of site Grading of power block, building pads, internal roads and solar field (as necessary) Construction Stage Wells installed to provide construction water Wheel-washing stations established Power block excavated and foundations poured Colosseum Road graded and paved from golf course to plant Internal roads graded, graveled, or paved Fabrication shops erected Power equipment and materials brought onsite Installation of underground piping and wiring Heliostat materials brought onsite Construction of power block Construction of Administration/warehouse building Construction of heliostat field Ivanpah 2 and 3 Repeat process described above for Ivanpah 1 for Ivanpah 2 and Ivanpah 3 Removal/Restoration Phase Once construction has been completed, all construction equipment and temporary buildings will be removed. Areas used for construction that are no longer required for operation will be restored per the Closure, Revegetation and Rehabilitation Plan.

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2.3.1 Colosseum Road and Rerouted Trails Construction access would be from Colosseum Road to the plant site entrance road (Figure 2-1). Colosseum Road is an existing dirt road, which will be paved from the Primm Valley Golf Club to the project site as part of the project. This 30-foot wide (2-lane) section of roadway would be about 1.6 miles long. The project would also re-route a 0.95-mile-long segment of the existing Colosseum Road that passes through Ivanpah 2, around the southern end of the Ivanpah 2 plant site. That new section of asphalt road will be 0.8 miles long with an additional 10.5 mile of dirt road that will connect to the existing Colosseum dirt road where it exits the south end of Ivanpah 2 (see also Figure 2-2). In addition, paved access roads would be created to access the power blocks of the three Ivanpah plant sites. Trails passing through the project site would be re-routed, as described in Section 2.2.1.2, when that section of the project is built (see Figure 2-4).

2.3.2 Security and Desert Tortoise Fencing Prior to clearing vegetation and site grading at the start of the development of each solar plant, the boundary of the site being developed would be permanently fenced with an 8-foot-high chain-link for security purposes and permanent desert tortoise exclusion fencing would either be attached to the base of the security fence or installed outside the security fence to allow construction of linear facilities. Desert tortoise guards would be installed at the gates to allow equipment access to the fenced sites and exclude desert tortoises. The first step would include clearing an approximately 10-foot-wide linear swath along the entire outer edge of each facility boundary to create an internal perimeter road and install the fencing. The perimeter road would be within the fence line of the site boundary. Once the fence is installed and prior to vegetation clearing and site grading, a desert tortoise clearance survey according to USFWS protocol and the project-specific translocation plan3 would be performed. If required by the Bureau, upon completion of the desert tortoise clearance survey and translocation, and prior to mowing, the barrel cactus and Mojave yucca that would otherwise be mowed or impacted during construction would be offered up for public salvage. Otherwise, the succulent plants will be salvaged according to the Closure, Revegetation and Rehabilitation Plan. The combined security and tortoise exclusion fence would be constructed with durable materials (i.e., 11 gauge or heavier) suitable to resist desert environments, alkaline and acidic soils, wind, and erosion. Fence material will consist of 1-inch horizontal by 2-inch vertical, galvanized welded wire, 36 inches in width. A trench will be dug to allow 12 inches of fence to be buried below the natural level of the ground, leaving 22 to 24 inches aboveground. The top end of the tortoise fence is to be secured to the security fence with hog rings at 12- to 18-inch intervals. Distance between posts is not to exceed 10 feet. The fence will be perpendicular to the ground surface, or slightly angled away from the road toward the side encountered by tortoises. After the tortoise fence has been installed and secured to the security fence and posts, excavated soil will be replaced and compacted to minimize soil erosion.

3 See Desert Tortoise Translocation/Relocation Plan for the Ivanpah Solar Electric Generating System, Attachment D.

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As part of its mitigation, the Applicant (or Caltrans, if required as part of Caltrans’ mitigation requirements for construction of the Joint Point of Entry) will fence the north side of I-15 with desert tortoise exclusion fencing from Nipton Road exit to the Yates Well Road exit. If fencing is to be performed by the Applicant, it will work with Caltrans regarding the appropriate location for this fencing along I-15. The Applicant will also consider the location of the proposed Joint Port of Entry in locating this fencing.

2.3.3 Vegetation Clearing and Cutting To construct the heliostat array fields located within these sites, some vegetation clearing will occur but only where necessary to allow for equipment access and stormwater management. In areas where general site grading is not required, vegetation clearing will not occur. Although vegetation removal will be minimized, the entire area covered by the solar plant sites and related facilities would no longer be available to desert tortoises. The related facilities such as the substation and administration building outside the fenced solar sites would be permanently fenced and desert tortoises excluded during construction and operation. Inclusive of these solar plant sites and the area used for access roads, transmission poles, and the substation and administration building, the total area that would be permanently disturbed by development activities consists of approximately 4,062 acres or approximately 6.35 square miles. As practicable, existing root systems would remain in place to anchor the soil. Occasional cutting of the vegetation may be required to control plant re-growth that could affect mirror movement. All cut vegetation would be handled as described in the Draft Closure, Revegetation and Rehabilitation Plan (Attachment A of this document; CH2M HILL, 2009c). Regarding stormwater runoff and hydrologic connectivity, the solar field development would maintain unobstructed sheet flow, to the degree possible. The power block footprint will be graded to create level pad elevations with approximately balanced cut and fill earthwork for each power block. The size of both Ivanpah 1 and 2 power blocks will be about 13.2 acres; the Ivanpah 3 power block will be approximately 15 acres. Acreage estimates include the power block perimeter road, stormwater diversion channel and berm, and concrete holding basins.

2.3.4 Gas Pipeline The construction contractor will determine which method to use to install the natural gas pipeline—a trench or trenchless method. The most common method of pipeline construction includes excavation of an open trench approximately 36 inches wide and 3 to 10 feet deep, depending on the site-specific soil type. With loose soil, a trench up to 8 feet wide at the top and 3 feet wide at the bottom may be required. The pipeline would be buried to provide a minimum cover of 36 inches. During construction, a 50-foot-wide construction corridor may be disturbed. This temporary construction corridor would be used to store the excavated soil, provide access for equipment and vehicles, and space for fitting the pipeline prior to installation and backfill via backhoe. If metal piping is used, a cathodic protection system would be designed to control the electrochemical corrosion of metal piping buried in the soil. Depending upon the corrosion potential and the site soils, either passive or impressed

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current cathodic protection would be provided. Once completed, a 12-foot-wide dirt service road or paved road access will be maintained. Construction would require temporary disturbance of the ROW (e.g., vegetation clearing, trench excavation, soil compaction, dust generation, and restoration). The temporary construction disturbance area for the natural gas pipeline tap point would be a 200-foot by 200-foot area required by KRGT. Construction of the Ivanpah 3 metering set would use a temporary laydown area within the Ivanpah 3 site; whereas, construction of the Ivanpah 1 and 2 metering set would use a portion of the Construction Logistics Area just south of the metering set (Area F on Figure 2-2).

2.3.5 Water Line The construction contractor will determine which method to use to install the water supply pipeline—a trench or trenchless method. The most common method of construction of the water supply line includes excavation of an open trench approximately 3 feet wide and 5 to 10 feet deep, depending on the site-specific soil type. With loose soil, a trench up to 8 feet wide at the top and 3 feet wide at the bottom may be required. The pipeline would be buried to provide a minimum cover of 36 inches. During construction, a 50-foot wide construction corridor may be disturbed. This temporary construction corridor would be used to store the excavated soil, provide access for equipment and vehicles, and space for fitting the pipeline prior to installation and backfill via backhoe. Construction would require temporary disturbance to the approximate 11,075-foot-long corridor (e.g., vegetation clearing, trench excavation, soil compaction, dust generation, and restoration). The temporary construction disturbance area for the water supply line located just north of Ivanpah 1 encompasses 0.99 acres, with permanent disturbance of 0.3 acres (assuming a 12-foot wide dirt access road).

2.3.6 Gen-tie Lines and Substation 2.3.6.1 Construction of Proposed Ivanpah Substation Substation construction would be performed by SCE (or its contractor) and would consist of grading and site preparation, foundation excavation and pouring, equipment delivery and installation, and wiring and testing. In addition, a permanent berm and stormwater diversion channel (about 8.3 acres in size) will be constructed around the substation to protect it from stormwater runoff. Grading of the approximate 16.1-acre site and construction of the stormwater berm/diversion channel would require an estimated 3 to 5 weeks. In addition, a 5-foot-wide graded apron will extend outside the boundary fence around the substation’s perimeter. Once graded, the area will be graveled and dunnage will be used for equipment and material storage during construction of the substation. The substation site is large enough to provide for laydown of substation construction materials and equipment as well as construction parking within it. Temporary berms may be placed around the construction site to prevent stormwater from flowing across the site during construction. Equipment and materials for substation construction would be delivered and stored in the 16.1-acre site. Hazardous materials such as paints, epoxies, grease, and compounds would be

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stored in lockers or covered containers within these areas. Transformer oil and caustic electrolyte (battery fluid) would be delivered after the electrical equipment is in place.

2.3.6.2 Construction of Proposed Generation Tie Lines The 115-kV generation tie line (gen-tie) structures, insulators, conductors, and other equipment will be delivered to a construction laydown area or marshalling yard located either within the Construction Logistics Area, near the switchyard at the power block of the unit under construction, or within the laydown area adjacent to the Ivanpah Substation. Construction crews would deliver the poles and other equipment from the laydown area to the individual pole locations. In most locations, the poles could be placed on the side of the 8- to 12-foot-wide dirt access roads. Construction vehicles would follow a route between the substation and the heliostat field. At most, 4 or 5 vehicles would need to use this access route to erect the poles. Construction activity is usually confined within the electrical easement with little or no disturbance to the adjacent lands. An area approximately 100 feet by 20 feet may be temporarily disturbed at each pole site during pole setting activities. Where poles with concrete foundations are located (angle locations), the maximum area of temporary construction disturbance would be approximately 100 feet by 30 feet. For each embedded pole location, the crews would auger a hole approximately 10 feet deep. The soil would be backfilled and compacted around the pole. Setting the poles would require 1 or 2 days at each pole location. Augering, the noisiest activity, would last 15 to 30 minutes at each location. Soil that is excavated and is determined to be surplus would be used as fill elsewhere on the Ivanpah SEGS site. Poles with a concrete foundation would require an excavation 20 to 30 feet deep and less than 7 feet in diameter. Where the soils are sandy, approved soil stabilizers may be needed to prevent the soil from sloughing back into the pits. A circular cage of rebar, up to 6 feet in diameter, would be assembled and lowered into the pit, and a concrete foundation would be poured and allowed to cure for 7 days or longer. The steel pole would then be mounted and bolted to the foundation. To string the conductors onto the poles, the construction crew would first pull a rope through travelers or pulleys, which would be attached to the insulators on the structures. Three ropes would be used—one for each conductor phase. Each rope will then be attached to its respective conductor. Reel trucks and tensioners would be used to pull the conductors and set the proper sag. Temporary disturbance at each pulling location will be approximately 100 feet by 40 feet for tensioner and reel truck positioning.

2.3.7 Telecommunications Line 2.3.7.1 Poles Accessible by Service Road The overhead cable would be installed by attaching cross arms on existing distribution poles. This would require the use of a bucket truck. Four people and two trucks would be used. A crew can install up to 2,000 feet of cable in one day. A crew can complete three splices in one day. Overhead fiber optic cable stringing includes all activities associated with the installation of cables onto cross-arms on existing wood pole structures. This includes the installation of vibration dampeners and suspension and dead-end hardware assemblies. Stringing sheaves (rollers or travelers) are attached during the framing process. A standard wire stringing plan

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includes a sequenced program of events starting with determination of cable pulls and cable pulling equipment set-up positions. Advanced planning determines pulling locations, times, and safety protocols needed for ensuring that safe and quick installation of cable is accomplished. Fiber optic cable pulls typically occur every 10,000 to 20,000 feet over flat or mountainous terrain. Fiber optic cable splices are required at the ends of each cable pull. “Fiber optic cable pulls” are the lengths of any given continuous cable installation process between two selected points along the existing overhead or underground structure line. Fiber optic cable pulls are selected, where possible, based on availability of pulling equipment and designated dead-end structures at the ends of each pull, geometry of the line as affected by points of inflection, terrain, and suitability of fiber optic cable stringing and splicing equipment set ups. The dimensions of the area needed for stringing set ups varies depending upon the terrain; however, a typical stringing set up is 40 feet by 60 feet. Where necessary due to space limitations, crews can work from within a substantially smaller area. For the installation of the fiber optic cable in existing and new underground conduit, a high density polyethylene smoothwall innerduct would be used. Innerduct facilitates the installation of the fiber optic cable, provides protection, and helps identify the cable. The innerduct is installed first inside the conduit. The fiber optic cable is then installed inside the innerduct.

2.3.7.2 Poles to be Constructed on Foot SCE estimates that approximately 20 poles are not accessible from the existing dirt service roads. Poles with potential access issues are located between Pole 4045066E/67E (the last H-frame structure accessible from the dirt service road east of Mountain Pass Substation) and Pole 4045099E—the single corner pole before the end of the existing access road southwest of the proposed Ivanpah Substation site (see Figure 2-7). Construction of the fiber optic line on these poles would be done by workers on foot. A summary of the poles with potential access issues are provided below:

2.3.7.2.1 Poles 4045068E/69E to Pole 4045078E/79E (corner structure) Six H-frame structures in canyon east of the last structures accessible from the Mountain Pass access roads. These poles are located on a steep east-facing slope and along the wash in the canyon. No access roads are visible in aerial photos.

2.3.7.2.2 Poles 4045080E to 4045083E (single wood poles) Approximately 2 or 3 poles between H-frame corner pole and access road to the east may not have access roads to the poles. Due to the presence of small washes in the area it is not clear whether there are access roads based on aerial photos; however, there appears to be a two-track road to these poles or near these poles.

2.3.7.2.3 Poles 4045084E to 4045099E (single wood poles) Approximately 10 poles located in the area between the two existing access roads do not appear to have access roads to the poles.

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2.4 Operation Ivanpah SEGS would be designed for an operating life of up to 45 years4.

2.4.1 Solar Fields Management, engineering, administrative staff, skilled workers, and operators would serve the three Ivanpah SEGS plant sites. Ivanpah SEGS is expected to employ up to 90 full-time employees. The plant sites are expected to operate 7 days a week, up to 14 hours per day. Ivanpah SEGS is expected to have an annual power plant performance availability of 92 to 98 percent.

2.4.2 Water System Water consumption is considered minimal (estimated at less than 100 acre-feet/year for all three solar plant sites) and would mainly be used to provide water for washing heliostats and to replace boiler feedwater blowdown. Operation requirements necessitate the washing of some portion of the project’s solar heliostats on a nightly basis. Individual heliostats are washed about once every 2 weeks. The application rate per heliostat would be 2.5 gallons once every 2 weeks. Heliostat wash water requirements for Ivanpah 1 and 2 will be 3,575,000 gallons per year or 10.97 acre-feet per year (afy) and 6,760,000 gallons or about 20.75 afy for Ivanpah 3, for total deionized water consumption of 42.7 afy after project buildout. Because of dust created during site grading, it is possible that this washing cycle may need to be more frequent during the first 5 months of construction of Ivanpah 3, when Ivanpah 1 is operating. The amount of additional water needed for mirror washing during this 5-month period depends on several factors such as the frequency, speed, and direction of wind and the amount of dust created by the grading activities. Additionally, during construction of Ivanpah 3 (as with the other units), dust suppression (water or soil binders) will be used to minimize wind erosion. Also considering that the closest points between Ivanpah 1 and Ivanpah 3 exceed 1.5 miles, it is not likely that any additional mirror washing will be needed. However, it was conservatively estimated that the frequency of mirror washing would, at most, double (i.e., weekly washing). If washing frequency is doubled, the amount of water required would be: 55,000 heliostats x 2.5 gallons per heliostat x 22 weeks or 3,025,000 gallons (or about 9.3 acre-feet). Therefore, the amount of additional water required is estimated not to exceed 4.65 acre-feet. High quality deionized water containing only minimal iron and copper from the water piping will be used for heliostat mirror washing. Assuming uniform dispersion of the 1.25 gallons of water across the mirror surface and no evaporation, runoff onto the ground will be about 0.17 gal, or about 22 fluid ounces per linear foot per washing episode. Given such small amounts, no water will run offsite as a result of heliostat washing. Due to the high evaporation rates in the area, and the minimal amount of runoff water used, it is likely that wash water will evaporate at or just below the ground surface in most seasons.5 The 4 The BLM right-of-way lease will be for 50 years, which includes construction and decommissioning/restoration. Therefore, the plant’s operating life will be between 40 and 45 years. 5 At an estimated 1.8 oz of water per inch every other week, the potential for the wash water to stimulate weed growth is minimal.

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area underneath the mirrors will be inspected for weeds and addressed per the requirements of the Weed Management Plan (Attachment DR13-1A, Data Response Set 1F; CH2M HILL, 2008b). Stormwater discharge during operations would adhere to the Industrial Stormwater Pollution Prevention Plan (CH2M HILL, 2009d ) and the Preliminary Draft Drainage, Erosion, and Sediment Control Plan (CH2M HILL, 2009a) and state water quality standards. Make-up water for the steam system will be treated by means of a mixed-bed ion-exchange system to produce feedwater-quality water for use in the boiler system. The ion exchange resigns will be sent offsite for regeneration. Drinking water will either be brought onsite or a small filter/purification system would be used to provide potable water for sanitary uses (sinks, showers, and toilets) within the plants.

2.4.3 Concrete Holding Basins Two concrete-lined holding basins of about 40 feet by 60 feet by 6 feet deep are included in the power block area. They can serve for boiler commissioning and emergency outfalls from any of the processes. No waste streams will be discharged to the concrete holding basins.

2.4.4 Waste Management Waste management is the process whereby all operational wastes produced at Ivanpah SEGS are properly collected, treated (if necessary), and disposed of. Wastes may include process waste, nonhazardous waste, and hazardous waste, both liquid and solid. The primary wastewater collection system would collect process wastewater from all equipment, including the boilers and water treatment equipment. Each power block would include portable facilities that will be serviced regularly by an outside vendor. All wastewater would be recycled in the system. Drinking water will either be brought onsite or a small filter/purification system would be used to provide potable water at the administration/warehouse building.

2.5 Project Maintenance Activities Project components that are expected to require routine or infrequent maintenance are the natural gas pipeline, monitoring well, water supply wells, water pipeline, access roads, and the general project perimeter fence. Since the security fences around each of the three solar plant sites and the shared facilities area would be designed to exclude desert tortoises, the potential for direct effects to desert tortoises from maintenance activities would only be expected to occur outside the fenced areas. Structures and machinery may be repaired, upgraded or retrofitted to ensure peak performance. The anticipated maintenance activities that could occur outside the fenced solar plant sites are grouped into the following five categories: •

Class I: Maintenance activities that do not result in new surface disturbance;



Class II: Maintenance activities that result in minimal surface disturbance;



Class III: Maintenance activities that result in major surface disturbance;

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Class IV: Maintenance activities that may extend outside the project ROW; and



Class V: Emergency repairs.

The activities associated with the maintenance classes are further discussed as follows.

2.5.1 Class I Class I are those maintenance activities outside the fenced area that do not result in new surface disturbance. These activities include tasks that would be performed by hand or with the use of tools, equipment, and/or vehicles. Class I activities would take place on existing structures or would be staged from existing roads or likewise disturbed areas (excluding those areas subjected to restoration). They would not include off-road travel. Vehicles used for such tasks would likely include those primarily used for transportation or lifting purposes. Low-boy tractor and trailer, flat bed, utility trucks, forklifts, scissor lifts, cherry pickers, and mechanical hoists may be used to transport equipment and materials and to lift heavy objects. Labor may involve several workers confined to the area in need of maintenance. These activities may need to be performed on a routine daily, or as needed, basis.

2.5.2 Class II Class II activities would result in minimal surface disturbance. These activities would likely be performed with heavy earth moving equipment including motor grader, bulldozer, front-end loader, backhoe, water truck, asphalt paver, and/or dump truck. Labor may involve several workers confined to the area in need of maintenance. Class II activities may involve the following: a)

Underground utility (e.g.; water, gas, sewage, electrical, communication, etc.) repairs, upgrades and tie-ins to structures;

b)

Motor grading and repairs of existing dirt roads, shoulders, and berms;

c)

Cut or fill of soil surface to re-establish appropriate cover due to soil erosion after rainfall events;

d) Maintenance of drainages, fords and culverts for proper flow of water runoff, including the removal of debris along the outside of the security fences and remedy for areas of undercut fence; e)

Re-surfacing and other maintenance of the asphalt roads, shoulders and parking lots;

f)

Major security and desert tortoise exclusion fence repairs;

g)

Pipeline segment replacement should a below grade inspection reveal severe damage, then excavation and replacement of a portion of the pipeline would be necessary;

h) Installation of anodes should routine cathodic protection surveys reveal an isolated gas pipeline segment with low pipe-to-soil electrical potentials;

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i)

Below grade gas pipe and coating inspections indicating low pipe-to-soil electrical potentials where a portion of the pipe would be excavated for visual inspection; and

j)

Installation of anode flex for cathodic protection should a below grade inspection reveal failed gas pipeline coating where excavation and recoating of the pipeline segment could be necessary.

2.5.3 Class III Class III includes maintenance activities that result in major surface disturbance. Class III activities may involve the following: a) Installation of a new underground pipeline a distance of 1,000 feet or more; and b) Disturbance of 1 acre or more for construction of any new stormwater drainage features.

2.5.4 Class IV Class IV includes maintenance activities that would extend outside the action area described in this BA. This class of activities may include any of the previously mentioned actions that would extend beyond these limits including the creation of staging or laydown areas and equipment stockpile and spoil pile deposition areas. The extent of disturbance may vary with the project and depend upon the ROW width, topography, layout, and other factors. Class IV activities may require additional consultation with the USFWS prior to implementation.

2.5.5 Class V Class V includes emergency situations to ensure public safety, service reliability, and to protect the environment. Emergency repairs may include temporary closure and bringing the solar plant site back online, utility outages, pipeline leaks or breaks, fire control, human medical emergency, and reestablishment of access roads severely damaged by storms. These activities may involve a backhoe and/or cat-loader, motor grader, and possibly other heavy earth moving equipment. It is anticipated that most emergency situations would affect less than 0.5 acre, although the amount of habitat disturbance would vary depending upon the nature of the emergency. BrightSource may need to consult with the USFWS following the emergency action if those activities extend beyond the action area described in this BA.

2.6 Site Rehabilitation Plan The Draft Closure, Revegetation and Rehabilitation Plan (Rehabilitation Plan) is included as Attachment A. The Rehabilitation Plan follows the Technical Basis Document (CH2M HILL, 2008a), the Weed Management Plan (CH2M HILL, 2008b), and other component plans approved by the Bureau, CDFG and other appropriate resource agencies. The plan will be implemented to rehabilitate habitat including accelerating revegetation following construction and closure of the facility. One of the objectives is the acceleration of secondary succession and consequent improvement of desert tortoise habitat characteristics over time following last disturbance. A brief description of the rehabilitation and revegetation plan is provided below. The Rehabilitation Plan for construction impacts would be incorporated

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into the BRMIMP and submitted to the Bureau and CEC for review and approval at least 30 days prior to the start of construction. Temporarily disturbed areas such as the pipeline corridors would be treated within one year following completion of the construction activities. The Draft Closure, Revegetation and Rehabilitation Plan includes the following sections and details: 1)

Goals and objectives of rehabilitation and revegetation

2)

A description of methods employed to achieve them

3)

Criteria to determine the progress of revegetation

4)

Operations phase procedures and guidelines for addressing occasional disturbance such as may be caused by flood waters

5)

Integration of measures provided in the accepted weed control plan

6)

Reporting procedures and schedule objectives

The scope of the plan would be proportionate to the magnitude of the expected impact from construction, and to the size of the area to be rehabilitated at the end of Ivanpah SEGS operational life. As noted in the Rehabilitation Plan, arid region soils can have accumulated substantial amounts of nutrients as well as a dormant seed bank, despite having little organic matter compared to humid zone soils. Soil mycorrhizal fungi are also usually present, and all these characteristics can aid in rehabilitation and revegetation. Therefore, the top 2 to 3 inches of topsoil in trenched areas for pipeline installation would be salvaged and stockpiled until it can be re-spread following construction. Decompacting surface areas compressed by passing vehicles, and compacting areas where the density of the soil has been affected by excavation is planned, followed by re-spreading the stockpiled topsoil area prior to seeding. The disturbed construction corridor would then be seeded with native species identified in the plan, emphasizing those species adapted to disturbed habitat such as cheesebush (Hymenoclea salsola), saltbush (Atriplex canescens), and black-banded rabbitbrush (Chysothamnus paniculatus). The Rehabilitation Plan and, in particular, the Technical Basis Document prepared as part of that effort, detail the ecological basis for this project’s approach to revegetation. Of particular importance is the conclusion based on ecological studies as well as revegetation monitoring that successful revegetation occurs in stages beginning with those species best adapted to disturbed soils. Achieving vegetation comparable in density and composition to the surrounding landscape is not a near-term goal of revegetation, since it would be physically impossible in the absence of mature soil conditions, as well as other microenvironmental factors achieved through vegetation succession. Seeding and other revegetation measures are specifically intended to accelerate that successional process. Because rainfall is not only sparse but also intermittent, seeding would be timed as far as practicable to avoid drought periods. Volunteers, weedy species that would naturally disperse to the area and become established, are also anticipated and would be used to accelerate revegetation, provided they are not noxious weeds identified for eradication if encountered. Over the long-term, once the Ivanpah SEGS facilities are decommissioned (anticipated to be approximately 40 to 45 years after commencement of commercial operation of the unit) the

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structures would be removed and the project area would be rehabilitated to approximate preconstruction surface conditions in terms of slope and surface roughness. Because rehabilitation and revegetation of the site would not occur for at least 40 years, the Rehabilitation Plan has provisions to allow for updating to accommodate changing environmental conditions as well as provide increased specificity when needed. Because the conditions that would affect the decommissioning decision and overall goals for rehabilitation are uncertain, the Rehabilitation Plan will be reviewed at least 5 years prior to planned permanent closure and a Final Closure Plan will be prepared. Completed no later than 1 year prior to closure, these updates would also reflect the current technology and regulatory requirements at the time of facility closure, and document any deviations from the original plan. The Final Closure Plan would be submitted to the agencies involved (assumed to be CEC and BLM) prior to facility closure.

2.7 Facility Closure Facility closure can be temporary or permanent. Temporary closure is a shutdown for a period exceeding the time required for normal maintenance, including closure for overhaul or replacement of the steam turbine. Causes for temporary closure include a disruption in the supply of natural gas or damage to an integral component from natural events such as earthquake or flood, or a radical change in the market for electrical energy. Permanent closure is defined as a cessation in operations with no intent to restart operations owing to facility age, damage to the plant beyond repair, economic conditions, or other reasons.

2.7.1 Temporary Closure For a temporary facility closure, where there is no release of hazardous materials, security would be maintained on a 24-hour basis. The CEC, Bureau and other responsible agencies would be notified of a temporary closure as necessary and appropriate. Depending on the length of the shutdown, a contingency plan for the temporary cessation of operations would be implemented. The contingency plan would be conducted to ensure conformance with all applicable LORS and the protection of public health, safety, and the environment. The plan, depending on the expected duration of the shutdown, may include the draining of all chemicals from storage tanks and other equipment and the safe shutdown of all equipment. All wastes would be properly disposed of according to applicable LORS. Where the temporary closure includes damage to the facility, and there is a release or threatened release of regulated substances or other hazardous materials into the environment, procedures would be followed as set forth in a Risk Management Plan (RMP) and a Hazardous Materials Business Plan (HMBP). (The RMP and HMBP are available on request.) Procedures would include methods to control releases, notification of applicable authorities and public, emergency response, and training for facility personnel in responding to and controlling releases of hazardous materials. Once the immediate problem is solved, and the regulated substance/hazardous material release is contained and cleaned up, temporary closure would proceed as described above for a closure where there is no release of hazardous materials. It is possible for a temporary closure to become a permanent closure. Although there may be every intention of resuming operations, if a temporary closure continues for longer than

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3 years, then unless the project owner can present reasonable evidence of its plan to resume operations, the Bureau can assume permanent closure and ask the project owner to begin the decommissioning and restoration process, or access the performance bond funds and begin the process itself.

2.7.2 Permanent Closure Because the conditions that would affect the planned decommissioning decision are largely unknown at this time, these conditions would be presented to the CEC and Bureau when more information is available and the timing for decommissioning is imminent (at least 5 years prior to the planned start of decommissioning activities). It is also assumed that decommissioning would take place in the same sequence as project construction, with Ivanpah 1 being the first to be decommissioned, followed by Ivanpah 2, then the Ivanpah 3 along with the shared facilities being part of the final phase. Because the BLM ROW grant is anticipated to be for a 50-year duration, decommissioning of each phase would begin sometime after 40 years of operation so that construction, operation, decommissioning and restoration do not exceed the term of the 50-year grant. To ensure that public health, safety and the environment are protected during this period, a decommissioning plan would be submitted to the CEC and Bureau for approval prior to decommissioning. The plan would include the following: •

Proposed decommissioning activities



Conformance of the proposed decommissioning activities to all applicable LORS and local/regional plans



Activities necessary to restore the site if the plan requires removal of all equipment and appurtenant facilities



Decommissioning alternatives



Associated costs of the decommissioning activities

In general, the decommissioning plan for the facility would attempt to maximize the recycling of all facility components. Unused chemicals would be sold back to the suppliers or other purchasers or users. Equipment containing chemicals would be drained and shut down to ensure public health, safety and to protect the environment. All non-hazardous wastes would be collected and disposed of in appropriate landfills or waste collection facilities. Hazardous wastes would be disposed of according to all applicable laws, ordinances, regulations, and standards. The site would be secured 24 hours per day during the decommissioning activities. More detailed closure activities are described in the Draft Closure, Revegetation and Rehabilitation Plan, included as Attachment A of this document; CH2M HILL, 2009c.

2.8 Minimization Measures The following subsection describes the measures proposed by the Applicant to avoid and minimize the potential adverse effects to the desert tortoise resulting from the Ivanpah

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SEGS construction and operation. Site-specific measures, such as exclusionary fencing, preconstruction surveys, monitoring, etc., would be mapped and identified as environmental specifications in the construction drawings.

2.8.1 Construction Minimization Measures This section lists measures intended to minimize take of the desert tortoise that would be implemented during construction of each solar plant site. Each solar plant site would be developed independently and work would not be started until financing for that phase had been secured. Hence, these mitigation measures will apply to each power plant site. The following desert tortoise protection measures will be incorporated into the project owner’s Biological Resources Mitigation, Implementation and Monitoring Plan (BRMIMP) which also addresses other biological resource concerns. 1. Authorized biologists6 will conduct all activities described in the previous section for desert tortoise monitors, including locating desert tortoises and their sign (i.e., conduct presence/absence and clearance surveys) and attempting to ensure that the effects of the project on the desert tortoise and its habitat are minimized in accordance with the measures stated in this BA and the terms and conditions of the biological opinion. Authorized Biologists will keep current with the latest information on USFWS protocols and guidelines. An authorized biologist will have thorough and current knowledge of desert tortoise behavior, natural history, and ecology, physiology, and will have demonstrated substantial field experience and training to safely and successfully: - handle and temporarily hold desert tortoises - excavate burrows to locate desert tortoise or eggs - relocate/translocate desert tortoises - reconstruct desert tortoise burrows - unearth and relocate desert tortoise eggs - locate, identify, and record all forms of desert tortoise sign The project owner will from time-to-time be seeking authorized biologist approval from the CEC for individuals who have the appropriate qualifications. Desert tortoise monitors will oversee all project construction activities with the potential to affect the desert tortoise. The desert tortoise monitors will ensure proper implementation of protective measures, record and report desert tortoise and tortoise sign observations in accordance with approved protocol, report incidents of noncompliance in accordance with the biological opinion and other relevant permits, and move desert tortoises from harm’s way and place these animals in “safe areas” pre-selected by authorized biologists or maintain the desert tortoises in their immediate possession until an authorized biologist assumes care of the animal. 6 USFWS designates biologists who are approved to handle tortoises as “Authorized Biologists.” Such biologists have demonstrated to USFWS that they possess sufficient desert tortoise knowledge and experience to handle and move tortoises appropriately, and have received USFWS approval. Authorized Biologists are permitted to then approve specific monitors to handle tortoises, at their discretion. The California Department of Fish and Game (CDFG) must also approve such biologists, potentially including individual approvals for monitors approved by the Authorized Biologist. Designated Biologists are the equivalent of Authorized Biologists. Only Designated Biologists and certain Biological Monitors who have been approved by the Designated Biologist would be allowed to handle desert tortoises.

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The desert tortoise monitors will assist the authorized biologists during surveys and often serve as "apprentices" to acquire experience. Desert tortoise monitors would not be authorized to conduct desert tortoise presence/absence or clearance surveys unless directly supervised by an authorized biologist. “Directly supervised” means the authorized biologist is in direct voice and sight contact with the desert tortoise monitor. BrightSource will be seeking, from time-to-time, desert tortoise monitor approval for individuals who have appropriate qualifications. 2. The BRMIMP will include a Worker Environmental Awareness Program (WEAP) that will address the types of construction activities that may affect the desert tortoise. The WEAP will also describe the protective measures listed in the BA and in the terms and conditions of the biological opinion. Special emphasis will be placed on explaining the protective measures developed for the desert tortoise and the consequences of noncompliance. At a minimum, the program will contain information on physical characteristics, distribution, behavior, ecology, sensitivity to human activities, legal protection, penalties for violations, reporting requirements, and protective measures associated with the desert tortoise. The WEAP will be administered to all onsite personnel including employees, contractors, contractors’ employees, supervisors, inspectors, subcontractors, and delivery personnel. A pamphlet that outlines basic critical information on dealing with desert tortoises encountered on the project will be provided to all personnel attending the program. The program will be administered onsite by the authorized biologist. It may include an oral presentation, video/PowerPoint, and written materials. 3. The project owner would designate a Field Contact Representative (FCR) who would be responsible for overseeing compliance with the protective measures. The FCR would be onsite during all activities that may result in the take of the desert tortoise. The FCR would have the authority to halt all activities that are in violation of the desert tortoise protective measures identified in the Biological Opinion and the BRMIMP. If the FCR or authorized biologist/desert tortoise monitor identifies a violation of the desert tortoise protective measures, work will proceed only after the violation has been corrected. The FCR will have a copy of the biological opinion during all construction activities. The FCR may be an authorized biologist, construction supervisor, or any other employee with the authority to halt construction activity. 4. During construction, the project owner will comply with the Guidelines for Handling Desert Tortoises During Construction Projects (Desert Tortoise Council, 1994). 5. The boundaries of all areas to be disturbed (project sites and linear corridors) will be flagged before beginning any activities, and all disturbances would be confined to the flagged areas. All project vehicles and equipment would be confined to the flagged areas. Survey crew vehicles would remain on existing roads. Disturbance beyond the construction zone would be prohibited except to complete a specific task within designated areas or emergency situations.

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6. The project owner will implement a desert tortoise translocation/relocation plan—a copy of which is provided in Attachment D to this document. The plan will be incorporated into the BRMIMP. The plan is an essential feature and conservation measure of this biological assessment, and will outline the following procedures. The authorized biologist will maintain a record of all desert tortoises encountered and relocated during project surveys and monitoring. This information would include for each individual: the locations (narrative, vegetation type, and maps) and dates of observations; general conditions and health; any apparent injuries and state of healing; if moved, the location from which it was captured and the location in which it was released; and diagnostic markings (i.e., identification numbers). All potential desert tortoise burrows within the fenced area will be searched for presence. In some cases, a fiber optic scope may be used to determine presence or absence within a deep burrow. Burrows inhabited by tortoises will be excavated by authorized biologists or desert tortoise monitors supervised by an authorized biologist using hand tools. To prevent reentry by a tortoise or other wildlife, all burrows would be collapsed once absence has been determined. Tortoises excavated from burrows would be relocated to unoccupied natural or artificial burrows outside the fenced area immediately following excavation. The animals would be transported in clean cardboard boxes. A new box would be used for each individual tortoise and would be properly discarded after a single use. The new burrow would be located at least 300 feet from the outside of the permanently fenced area and would be of similar size, shape and orientation to the original burrow. The new burrow locations would be determined by the authorized biologist. Relocated tortoises would not be placed in existing occupied burrows. The authorized biologist would wear disposable surgical gloves when handling desert tortoises. A new pair would be donned for each tortoise handled to avoid the transmission of upper respiratory tract disease (URTD). Shell notching would not be performed. Any equipment used on the tortoises would be sterilized between each use. Desert tortoises would be treated in a manner to ensure that they do not overheat, exhibit signs of overheating (e.g., gaping, foaming at the mouth, etc.), or are placed in a situation where they cannot maintain surface and core temperatures necessary to their well-being. Desert tortoises would be kept shaded at all times until it is safe to release them. No desert tortoise would be captured, moved, transported, released, or purposefully caused to leave its burrow for whatever reason when the ambient air temperature is above 95ºF (35ºC). Ambient air temperature would be measured in the shade, protected from wind, at a height of 2 inches (5 centimeters) above the ground surface. No desert tortoise would be captured if the ambient air temperature is anticipated to exceed 95ºF (35ºC) before handling and relocation can be completed. If the ambient air temperature exceeds 95ºF (35ºC) during handling or processing, desert tortoises would be kept shaded in an environment that does not exceed 95ºF (35ºC), and the animals would not be released until ambient air temperature declines to below 95ºF (35ºC).

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To monitor for survivorship and health, for a period of 1 year following their translocation/relocation, the desert tortoises will be located at least monthly by the authorized biologist during the periods of activity (spring: March – May and fall: August – October) and once during the two non-active periods (summer: June - July and winter: November –February). For the following 2-years, they will be located at least once in the spring and once in the fall. In order to locate all translocated/ relocated tortoises, it will be necessary that they be marked and fitted with radio transmitters. All pertinent information would be recorded, such as behavior, physical characteristics, health characteristics and any visible signs of URTD, as well as any potential anomalies the individual desert tortoise might display. 7. Tortoise handling, artificial burrow construction, egg handling and other procedures would follow those described in the Guidelines for Handling Desert Tortoise During Construction Projects (Desert Tortoise Council, 1994). 8. Prior to the initiation of construction activities for each solar plant site, the project owner will enclose the boundary of the site with permanent chain-link fencing for security purposes and permanent desert tortoise exclusion fencing would be attached to the bottom of the chain link fencing in areas where appropriate. The permanent desert tortoise exclusion fencing would be consistent with the guidance of the Desert Tortoise Recovery Office (DTRO)7 and the specifications would be included in the BRMIMP. Desert tortoise guards would be installed at the gated entries to prevent desert tortoises from gaining entry (Attachment B). 9. The project owner would implement the same protective measures for the preparation, fencing, and use of the construction logistics area as described in protective measure 8. 10. The utility ROWs would be temporarily fenced on each side of the ROW. The temporary exclusionary fencing would consist of either galvanized hard wire cloth or silt fencing. The fencing would be buried approximately 6 inches below ground or bent at a right angle towards the outside of the ROW and covered with dirt, rocks or gravel to discourage the desert tortoise from digging under the fence. The temporary exclusionary fencing would be installed prior to the onset of clearing and mowing. The fence installation would be supervised and monitored under the direction of authorized biologists and desert tortoise monitors. 11. Within 24 hours prior to the initiation of construction of the desert tortoise-exclusion fence, a desert tortoise survey would be conducted using techniques providing 100 percent coverage of the construction area and an additional transect along both sides of the fence line transect to provide coverage of an area approximately 90 feet wide centered on the fence alignment. Transects would be no greater than 30 feet apart. The fence alignment would be flagged prior to the biological survey. Two complete passes of complete coverage would be conducted. All desert tortoise burrows, and burrows constructed by other species that might be used by desert tortoises, would be examined to determine occupancy. Any burrow within the fence line would be

7 Found at: http://www.fws.gov/ventura/speciesinfo/protocols_guidelines/docs/dt/DT_Exclusion-Fence_2005.pdf

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2. DESCRIPTION OF PROPOSED ACTION

collapsed after confirmation that it is not occupied by a desert tortoise, or if occupied, the desert tortoise has been removed. 12. Following construction of the security and attached desert tortoise exclusion fence, the fenced area would be cleared of desert tortoises. Two complete passes with complete coverage would be conducted as described above. If no desert tortoises are observed during the second survey, a third survey would not be conducted. Transects would be no wider than 30 feet. Each separate survey would be walked in a different direction to allow opposing angles of observation. If a desert tortoise is located on the second survey, a third survey would be conducted. The authorized biologists would be primarily responsible for the clearance surveys. Some authorized biologists may be substituted with desert tortoise monitors and would be placed between authorized biologists during the surveys. Once the area surveyed is deemed free of desert tortoises the areas may be open to a vegetation salvage program, if the Bureau desires. All potential desert tortoise burrows located would be excavated by hand by an authorized biologist, desert tortoises removed, and collapsed or blocked to prevent occupation by desert tortoises. If excavated during May through July, the authorized biologist would search for desert tortoise nests/eggs, which are typically located near the entrance to burrows. All desert tortoise handling and removal, and burrow excavations, including nests, would be conducted by an authorized biologist in accordance with the Service-approved protocol (Desert Tortoise Council, 1994 ). If the Desert Tortoise Council releases a revised protocol for handling of desert tortoises before initiation of project activities, the revised protocol would be implemented for the project. 13. Following the desert tortoise clearance and translocation and vegetation salvage, heavy equipment would enter the fenced solar plant sites to clear, grub (where necessary), mow, level, and trench the sites. A desert tortoise monitor would be onsite during initial clearing and grading and, if necessary, to translocate tortoises missed during the clearance survey. Should a desert tortoise be discovered, an authorized biologist will remove the tortoise as outlined in the translocation plan. 14. Access by project-related personnel to Ivanpah SEGS will be restricted to established access roads (Figure 2-1). Cross country vehicle and equipment use outside designated work areas would be prohibited. 15. The project owner would require personnel to exercise caution when traveling to and from the site. To minimize the likelihood of vehicle strikes of desert tortoises outside the fenced areas, a 20 mile per hour speed limit would be enforced on Colosseum Road and other authorized access routes to the work site. Speed limit signs will be posted on both sides of these roads. 16. Trash receptacles at the work site will have self-locking lids to prevent entry by opportunistic predators such as common ravens and coyotes. Trash receptacles will be emptied daily. 17. Other than law enforcement or security personnel, project personnel would be prohibited from bringing pets and firearms to the project site.

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2. DESCRIPTION OF PROPOSED ACTION

18. The project owner would implement a comprehensive raven management and control plan (Attachment E). This plan is an essential feature and conservation measure of this biological assessment. 19. Project employees working outside the fenced areas would be required to check under a vehicle or equipment before it is moved. If a desert tortoise is encountered the vehicle would not be moved until such animals have voluntarily moved within a safe distance from the parked vehicle. Desert tortoises may be moved by an authorized biologist for this task. 20. All activities would be restricted to pre-approved ROW locations. If unforeseen circumstances require expansion of activities, the potential expanded work areas would be approved by the Bureau and the CEC. The expanded work areas will be surveyed by an authorized biologist for desert tortoises prior to requesting approval by the Bureau and CEC. Use of protection measures would be implemented within the expanded work areas based on the judgment of the Bureau and an authorized biologist. Any work involving areas outside the action area described in this BA would require re-initiation or amendment of consultation with USFWS and CDFG. 21. At the end of each work day, the project owner will ensure that trenches, bores and other excavations outside the permanently fenced area that constitute wildlife pitfalls would either be immediately backfilled, sloped at a 3:1 ratio at the ends to provide wildlife escape ramps, covered, or fully enclosed with fencing to prevent any entrapment. All excavations outside the permanently fenced area would be inspected periodically throughout and at the end of each workday by an authorized biologist, desert tortoise monitor, or the FCR. Should a tortoise become entrapped, an authorized biologist will remove and relocate the tortoise to a safe location. 22. Any construction pipe, culvert, or similar structure with a diameter greater than 3 inches, stored less than 8 inches aboveground and within desert tortoise habitat (i.e., outside the permanently fenced area) for one or more nights, would be inspected for tortoises before the material is moved, buried or capped. As an alternative, all such structures may be capped before being stored outside the fenced area, or placed on pipe racks. These materials would not need to be inspected or capped if they are stored within the permanently fenced area after the clearance surveys have been completed. 23. All vehicles and equipment would be maintained in proper working condition to minimize the potential for fugitive emissions of motor oil, antifreeze, hydraulic fluid, grease, or other hazardous materials. An authorized biologist, desert tortoise monitor, CEC, and the Bureau would be informed of any hazardous spills immediately. Hazardous spills would be immediately cleaned up and the contaminated soil would be properly disposed of at a licensed facility. 24. All fuel, transmission or brake fluid leaks, or other hazardous waste leaks, spills or releases would be reported immediately. The project proponent would be responsible for spill material removal and disposal to an approved offsite landfill. Servicing of construction equipment would take place only at a designated area. All fuel or hazardous waste leaks, spills, or releases would be stopped or repaired

2-35

2. DESCRIPTION OF PROPOSED ACTION

immediately and cleaned up at the time of occurrence. Service/maintenance vehicles would carry a bucket and pads to absorb leaks or spills. 25. All unused material and equipment, including soil and rock piles, would be removed upon completion of any maintenance activities located outside the permanently fenced area. 26. To minimize dust emissions and topsoil erosion, water would be applied to the construction area, dirt roads, trenches, spoil piles and other areas where ground disturbance has taken place. The minimal amount of water would be applied to meet safety and air quality standards in an effort to prevent puddling, which would attract desert tortoises and common ravens to the construction site. 27. The Bureau would require the project owner to compensate for the loss of desert tortoise habitat according to the NEMO Plan amendment to the CDCA Plan. The Bureau compensation ratio of 1 to 1 will be applied. In lieu fees may substitute for proof of land acquisition. The Bureau may fund desert tortoise habitat enhancement and recovery actions instead of or in addition to land acquisition. 28. An authorized biologist or FCR would notify the Bureau, USFWS, and CDFG within 24 hours upon locating a dead or injured desert tortoise. The notification would be made by telephone and in writing to the Bureau, USFWS Ventura Field Office, CDFG Bishop Office and CEC. The report would include the date and time of the finding or incident (if known), location of the carcass, a photograph, cause of death (if known), and other pertinent information. Tortoises fatally injured due to projectrelated activities would be submitted for necropsy, at the expense of the project owner, as outlined in Salvaging Injured, Recently Dead, Ill, and Dying Wild, FreeRoaming Desert Tortoises (Gopherus agassizii) (Berry 2001). Tortoises with minor injuries would be transported to a nearby qualified veterinarian for treatment at the expense of the project owner. If an injured animal recovers, the Bureau, USFWS, CDFG, and CEC would be contacted by the project owner for final disposition of the animal.

2.8.2 Operation Minimization Measures The following protection measures would be common to all classes of maintenance activities performed during operation of the solar plant site: 1. The authorized biologist or FCR would make initial notification to the Bureau, USFWS, CDFG and CEC within 24 hours upon locating a dead or injured desert tortoise during the Ivanpah SEGS operation phase. The notification must be made by telephone and in writing to the Bureau, USFWS Ventura Field Office, CDFG Bishop Field Office and CEC Sacramento Office. The report would include the date and time of the finding or incident (if known), location of the carcass, a photograph, cause of death (if known), and other pertinent information. Tortoises fatally injured or killed from project-related activities would be submitted for necropsy, at the expense of the project owner, as outlined in Salvaging Injured, Recently Dead, Ill, and Dying Wild, Free-Roaming Desert Tortoises (Gopherus agassizii) (Berry, 2001). Tortoises with minor injuries would be transported to a nearby qualified veterinarian for treatment at the expense of the project owner. If an injured animal recovers, the Bureau,

2-36

2. DESCRIPTION OF PROPOSED ACTION

USFWS, CDFG and CEC would be contacted by the project owner for final disposition of the animal. 2. The project owner would designate a FCR who would be responsible for overseeing compliance with the desert tortoise protection measures during operation. The FCR would have a copy of all measures when work is being conducted on the site. The FCR must be onsite during any activities located outside established tortoise exclusion areas or which otherwise have the potential to result in the take of tortoise. The FCR would have the authority to halt all activities that are in violation of the measures. Work would proceed only after hazards to the desert tortoise are removed, the species is no longer at risk, or the individual has been moved from harm’s way by the authorized biologist. The FCR may be a project manager, the project owner’s representative, or a biologist. 3. Vehicle parking, material stockpiles, and construction-related materials used for maintenance or repair activities would be located within the permanently fenced area. 4. WEAP training would continue for all Ivanpah SEGS personnel during the Ivanpah SEGS operation phase. All employees and their contractors involved with operation and maintenance would attend the agency-approved WEAP. These employees would participate in the education program prior to initiation of work activities. New employees would receive formal, approved training prior to working onsite. During the WEAP training, employees would be instructed to exercise caution when commuting to the project area. To minimize the likelihood for vehicle strikes of desert tortoises, the posted speed limit on the access roads would be 20 miles per hour. Speed limit signs would be posted on both sides of access roads to remind drivers of the speed limit when entering and exiting. 5. The Bureau would attempt to ensure activities are confined to the authorized work areas by conducting periodic project assessments. The assessments may be conducted by an authorized biologist under the direction of the Bureau. Should the assessment find that operations and maintenance activities extend beyond the approved work area, the Bureau would require that the project owner use appropriate measures to restore disturbed areas. Work areas would be clearly marked to prevent vehicles or personnel from exiting the authorized work area(s) on an unapproved path. 6. Existing routes of travel to and from the solar array fields would be used outside the cleared and fenced areas. Colosseum Road would be the only means of accessing Ivanpah SEGS. Cross-country use of vehicles and equipment outside the cleared and fenced areas would be strictly prohibited. 7. The authorized biologist and desert tortoise monitors would be present during maintenance outside the established tortoise exclusion areas and off established roads (such as cleaning the gen-tie line conductors) to assist in the implementation of protection measures for the desert tortoise and to monitor compliance. The appropriate number of authorized biologists and desert tortoise monitors would be dependent upon the nature and extent of the work.

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2. DESCRIPTION OF PROPOSED ACTION

8. The removal of desert tortoises from harm’s way would be conducted according to the Guidelines for Handling Desert Tortoises During Construction Projects (Desert Tortoise Council, 1994). 9. All encounters with desert tortoise would be reported to an authorized biologist, desert tortoise monitor, or FCR. These designees would maintain records of all desert tortoises encountered during the operation phase. This information would include for each individual: the locations (narrative, vegetation type, and maps) and dates of observations; general conditions and health; any apparent injuries and state of healing; if moved, the location from which it was captured and the location where it was released (and whether animals voided their bladders); and diagnostic markings (i.e., identification numbers). 10. Only authorized biologists would handle desert tortoises during Ivanpah SEGS operations activities and only if necessary. When a desert tortoise is moved, an authorized biologist would be responsible for taking appropriate measures to ensure that the animal is not exposed to temperature extremes that could be harmful. When handing desert tortoises or excavating their burrows, the authorized biologist would follow the appropriate protocols outlined in Guidelines for Handling Desert Tortoises During Construction Projects (Desert Tortoise Council, 1994). 11. An authorized biologist would perform desert tortoise clearance surveys and an authorized biologist or desert tortoise monitor would perform monitoring of maintenance activities outside the permanently fenced area. The biologist or monitor would be responsible for assisting crews in compliance with protection measures, performing surveys in front of the crew as needed to locate and avoid desert tortoises and other sensitive species. 12. Pre-activity surveys for maintenance activities outside the permanently fenced area would be conducted by a desert tortoise monitor no more than 72 hours prior to the onset of activities. Desert tortoise burrows (including pallets) outside of, but near, the work area would be prominently flagged so they may be avoided. Proposed actions would avoid disturbing such sites to the extent possible. In the event an occupied burrow is found within the proposed maintenance area, the authorized biologist would be onsite during maintenance activities to monitor the burrow and move the desert tortoise from harm’s way, if necessary. 13. Burrow excavation would be performed using hand tools either by or under the direct supervision of an authorized biologist. Excavation of desert tortoise burrows would occur no more than 7 days before the onset of maintenance activities. All desert tortoises removed from burrows would be placed in an unoccupied burrow of approximately the same size as the one from which it was removed. If an existing burrow is unavailable, an authorized biologist would construct or direct the construction of a burrow of similar shape, size, depth, and orientation as the original burrow. To ensure their safety, desert tortoises moved during their least active periods would be monitored by an authorized biologist for 2 days after placement in the new burrows or until the end of the job. An authorized biologist would be allowed some judgment and discretion to ensure the survival of the desert tortoise.

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2. DESCRIPTION OF PROPOSED ACTION

14. The area of disturbance from maintenance activities outside the permanently fenced areas would be confined to the smallest practical area, considering topography, placement of facilities, location of burrows, public health and safety, and other limiting factors. As needed, work area boundaries would be delineated with flagging or other marking to minimize surface disturbance associated with vehicle straying. Special habitat features, such as burrows identified outside the permanently fenced area by an authorized biologist or a desert tortoise monitor would be avoided to the extent possible. Previously disturbed areas within the permanently fenced area would, to the extent possible, be used for the stockpiling, storage, parking, and any other surface-disturbing activity. 15. All activities outside the permanently fenced area would be restricted to the described action area. If unforeseen circumstances require expansion of the corridor width, the potential expanded work areas would be surveyed by an authorized biologist for desert tortoise prior to use of the area. All appropriate protection measures would be implemented within the expanded work areas based on the judgment of the regulatory agencies and an authorized biologist. Work outside of the original ROW would proceed only after receiving written approval from the Bureau, USFWS, CDFG, and CEC describing the exact location of the expansion. 16. The authorized biologist or FCR would immediately notify the Bureau of an emergency situation. As a part of this response, the Bureau may require additional measures to protect the desert tortoise. During any responses related to human health, fire, hazardous waste, or repairs requiring off-road vehicle and equipment use, the Bureau may also require measures to recover damaged habitat. 17. Any damage to the permanent fencing would be repaired immediately. Following installation, the permanent fencing would be inspected annually and after major rainfall events.

2.9 Progress and Compliance Report The project owner would submit an annual report to the Bureau, USFWS, CDFG and CEC documenting the completed construction activities and the effectiveness and practicality of the avoidance and minimization measures for the desert tortoise, the number of desert tortoises excavated from their burrows, the number of desert tortoises removed from the site, the number of desert tortoises killed or injured, and the specific information for each species required under Construction Minimization Measure 2 by January 31 of the following year or within 30 calendar days following any break in construction activity lasting more than 30 calendar days. The report would also make recommendations as appropriate for modifying the measures to enhance species protection or improve the utility of the permit. The annual report would provide information on the actual acreage disturbed by various aspects of the construction and maintenance activities. The final report would be submitted within 60 calendar days following the completion of construction for all three solar plant sites and the associated utilities and facilities. BrightSource would report to the Bureau, USFWS, CDFG and CEC any direct mortality or suspected mortality of desert tortoises as a result of the proposed project. BrightSource

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2. DESCRIPTION OF PROPOSED ACTION

would also report to the Bureau, USFWS, CDFG and CEC immediately any information about any unauthorized take or suspected take of federally listed species, and would notify the Bureau, USFWS, CDFG and CEC within 24 hours of receiving such information. Notification would include the date, time, and location of the incident, or of the finding of a dead or injured animal. In the case of a dead animal, the individual animal should be preserved, as appropriate, and held in a secure location until instructions are received from the USFWS regarding the disposition of the specimen, or the USFWS takes custody of the specimen. Any contractor or employee who, during routine operations and maintenance activities, inadvertently kills or injures a listed wildlife species would immediately report the incident to their supervisor. This supervisor must contact the Bureau, USFWS, and CDFG immediately in the case of a dead or injured listed species.

2-40

TAP STATION

IVANPAH 3

METERING SET

IVANPAH 2

METERING SET

os ol C se

Colos

seum

ad Ro

ADMINISTRATION AND STORAGE

SUBSTATION

Road

d oa R

s lo Co

um se

um

REROUTED COLOSSEUM ROAD

PROPOSED MONITORING WELL

WELLS

IVANPAH 1

LEGEND WELLS DIRT ROAD PAVED ROAD UTILITIES CORRIDOR NATURAL GAS LINE GEN-TIE LINE KERN RIVER GAS LINE 4WD TOURING/TRAILS SECTION LINES PROJECT SITE 0

3,000 Feet

³

\\ZION\SACGIS\PROJ\352897_IVANPAH\MAPFILES\2008FIELDMAPS\IVANPAH_TOWNSHIPRANGE.MXD SSCOPES 3/10/2009 14:16:37

FIGURE 2-1 SITE PLAN AND LINEAR FACILITIES IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

E

E

F Asphalt Access Rd

Dirt Access Rd

Asphalt Access Rd

A

A

B

A

D C A

LEGEND

Dirt Access Road (1.9 acres) Asphalt Access Road (6.2 acres) Project Site Construction Logistics Area A: General Construction Parking and Equipment Laydown (265.7 acres) B: Administration/ Warehouse and Parking (8.4 acres) C: Substation (16.1 acres) D: Existing Transmission Line Corridor (58.1 acres) E: Equipment Laydown and Wash Areas (15.1 acres) F: Gas Metering Station Construction Laydown Area (7.5 acres)

0

$

600 Feet

1,200

FIGURE 2-2 CONSTRUCTION LOGISTICS AREA IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

SAC \\ZION\SACGIS\PROJ\352897_IVANPAH\MAPFILES\2009_UPDATED_FIGURES\CONSTRUCTIONLOGISTICSAREA.MXD SSCOPES 8/28/2009 09:45:50

Project route Name

Primm Valley Golf Club Distribution_comm_line CA Eldorado to Ivanpah CA Ivanpah to Wheaton NV Eldorado to Ivanpah

Ivanpah Sub

Access_road_08Mar25

G / "

Ivanpah Sub Area Substations

15

N

ip to n

33 k

V

/ "

# 0

MT. PASS SUB

/ "

# 0

AT&T Mt Pass

0

±

15

kV 12 rth Ea

Mountain Pass (MW Site)

# 0

15 15 NIPT

1

2

3

4 Miles

ON R D

FIGURE 2-2 FIBER OPTIC ROUTE IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

Source: Southern California Edison ES062007009SAC Figure_2-3_v2.ai 09/09/08 afint

5 69913

TAP STATION

2 699

26

98 91 69

IVANPAH 3 17

po w

er

lin e

6 699

METERING SET

699617

IVANPAH 2

METERING SET wash

C um se os ol R d oa

REROUTED COLOSSEUM ROAD 69 91 98

699238

um se os l Co

PROPOSED MONITORING WELL

SUBSTATION

69 91 98

ad

ADMINISTRATION AND STORAGE

ad

98 91 69

Colo sseu m Ro

Ro

69 91 97

WELLS

po w

95 01 69

er

lin e

IVANPAH 1

699238

69 91 94

LEGEND WELLS DIRT ROAD PAVED ROAD UTILITIES CORRIDOR NATURAL GAS LINE GEN-TIE LINE KERN RIVER GAS LINE 4WD TOURING/TRAILS 6

PROJECT SITE99199 0

3,000 Feet

³

1 69922

\\ZION\SACGIS\PROJ\352897_IVANPAH\MAPFILES\2008FIELDMAPS\FIGURE_2-3_TRAILS.MXD SSCOPES MCLAY1 3/27/2009 13:33:42

FIGURE 2-3 TRAILS

IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

FIGURE 2-4 APPEARANCE OF SITE AFTER CONSTRUCTION IVANPAH SOLAR ELECTRIC GENERATING SYSTEM ES062007009SAC Figure_2-4.ai 03.10.09 tdaus

TAP STATION

IVANPAH 3

METERING SET

IVANPAH 2

METERING SET

os ol C se um d oa R

s lo Co

Colos

seum

um se

ad Ro

ADMINISTRATION AND STORAGE SUBSTATION

Road

IVANPAH 1

LEGEND NATURAL GAS LINE KERN RIVER GAS LINE 4WD TOURING/TRAILS PROJECT SITE 0

3,000 Feet

³

\\ZION\SACGIS\PROJ\352897_IVANPAH\MAPFILES\FIGURE2-6_PROPOSEDGASLINEROUTE.MXD SSCOPES 3/10/2009 14:26:24

FIGURE 2-6 PROPOSED GAS LINE ROUTE IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

Eldorado Ivanpah Transmission Project 744-2724-2

Access Roads

744-2742-2

LEGEND

EITP_bio_access_roads_20090119 EITP_bio_dist_poles_20090120

EITP_bio_telecom_20090109 Telecom: Nipton 33kV Telecom: Eldorado-Lugo 500kV Telecom: New fiber optic line Eldorado_Mt_Pass_TL FIM Overhead Grid

740-2724-2

740-2730-2

6 (H-frame) poles in canyon (including the corner pole) with no access road.

740-2736-2

740-2742-2

Approximately 10 poles (single) with no access between access roads.

Pole 4045078E/79E Corner pole (H-Frame)

FIGURE 2-7

0

500

0 50 100

Approximately 2-3 poles (single) with questionable access between corner pole and access road.

Pole 4045099E Corner pole (single)

1,000 200

300

400 Meters

1:12,000

CLARK COUNTY

736-2724-2

736-2730-2

736-2736-2

Pole 4045066E/67E (H-frame) Last poles with access from Mt Pass side

SAN BERNARDINO COUNTY

Roger Overstreet SCE Corp Env Health & Safety Eldorado Ivanpah Transmission Project Projection: NAD 83 UTM Zone 11

Notes: The Nipton 33kV line in this area is located on FIM maps 736-2730-2 and 736-2736-2.

732-2724-2

732-2730-2

Access roads on the right side of the map were mapped using aerials and have not been field checked. Access roads on the left (near Mt Pass Sub) were mapped using GPS and are accurate.

Southern California Edison (SCE) has no reason to believe that there are any inaccuracies or defects with information incorporated in this work and make no representations of any kind, including, but not limited to, the warranties of merchantability or fitness for a particular use, nor are any such warranties to be implied, with respect to the information or data, furnished herein. No part of this map may be reproduced or transmitted in any form or by any means electronic or mechanical, including phototcopying and recording system, except as expressly permitted in writing by SCE. Features depicted herein are planning level accuracy, and intended for informational purposes only. Distances and locations may be distorted at this scale. Always consult with the proper legal documents or agencies regarding such features. This map is copyrighted and reproduced with permission granted by THOMAS BROS. MAPS (R). Contains Transmission Inf ormat ion Dis tribution limit ed to FERC S tandards of Conduct CONFIDENTIAL: Cont ains Crit ical E lectric I nf rastruct ure Information If any questions contact Corporat e Securit y (27875) for handling/storage requirements.

°

2,000 Feet

Environmental Baseline 3.1 Biological Setting 3.1.1 Regional Overview The Ivanpah Valley is bounded by the Lucy Grey Range and McCullough Mountains to the east, the New York Mountains and the Mid-Hills to the south, the Ivanpah Mountains, Mescal Range, and Clark Mountain to the west, and the Clark Mountain and southernmost Spring Range to the north. The valley-facing slopes of these mountain ranges empty into Ivanpah and Roach dry lakes. From the rugged mountains to the dry lake basins, Ivanpah Valley encompasses a diverse assemblage of landscape features and vegetation communities. The Primm Valley Golf Club is a golf course located 0.5 mile east of the project area. There are no residential units associated with the golf course. However, the golf course has several water features. The closest community is the town of Primm, Nevada, a retail and casino center along the I-15 corridor, located about 4.5 miles northeast of the project area. The town of Jean, Nevada is located approximately 15 miles north of Primm along I-15. The southern outskirts of greater Las Vegas are about 32 linear miles north-northeast of the project area. The proposed 4,060-acre (6.3 square miles) area affected by the solar site is located on an alluvial fan, or bajada, that extends eastward from the Clark Mountains to Ivanpah Dry Lake (Figure 3-1). The alluvial fan topography slopes gradually (3 to 5 percent grade) to the east and southeast from an elevation of approximately 3,150 feet in the northwest corner to about 2,850 feet in the southeast corner. The alluvial fan is dissected by numerous ephemeral washes. Most are small active channels 1 to 3 feet wide, but a few are larger, with bank-to-bank widths of more than 50 feet and active channels 5 to15 feet (or more) wide. In some areas the topography flattens, and many of the drainages become weakly expressed assemblages of braided erosional channels. In these areas, flows dissipate across the site into broad sheet flows. The general direction of drainage within Ivanpah SEGS flows eastward, ultimately reaching Ivanpah Dry Lake. The site is on land administered by the Bureau’s Needles Field Office. As an amendment to the California Desert Conservation Area (CDCA) Plan, the Bureau produced the Northern and Eastern Mojave (NEMO) Coordinated Management Plan (Bureau, 2002). This document consists of proposed management actions for public lands in the NEMO Planning Area. The Ivanpah SEGS site is located in the southeastern portion of the NEMO Planning Area Boundary (CH2M HILL, 2007). The Ivanpah SEGS project is not located within or adjacent to a Bureau-designated Desert Wildlife Management Area (DWMA), area of critical environmental concern (ACEC) or Wildlife Habitat Management Area (WHMA).

3.1.2 Habitat and Vegetation Mojave Creosote Bush Scrub is the predominant vegetation type observed within the Ivanpah SEGS site. This type corresponds to the Holland type of the same name (Holland,

3-1

3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE

1986) and may correspond to one or more of the Creosote Bush, Creosote Bush-White Bursage, or Black Bush series of A Manual of California Vegetation (Sawyer and Keeler-Wolf, 1995). According to Holland, Mojave Creosote Bush Scrub is composed of widely spaced evergreen and drought-deciduous shrubs, cacti and yucca, from 1 to 9 feet in height. Creosote bush (Larrea tridentata) is the dominant shrub species and the indicator species for this vegetation type. Burrobush or white bursage (Ambrosia dumosa), cheesebush (Hymenoclea salsola), Nevada tea (Ephedra nevadensis) and Mojave yucca (Yucca schidigera) are common associates throughout the range of this type (Holland, 1986) and are found at the Ivanpah SEGS site. Four subtypes of Mojave Creosote Bush Scrub were also identified in the Ivanpah SEGS site. These subtypes intergrade and transitions between these subtypes are subtle. These Mojave Creosote Bush Scrub Subtypes are: 1) Larrea-Ambrosia Scrub; 2) Larrea mixed Scrub; 3) Larrea Scrub; and 4) Limestone-Associated Type of Larrea Scrub. The predominant subtype of Mojave Creosote Bush Scrub vegetation is the Larrea-Ambrosia subtype of Creosote Bush Scrub. Limestone features within the one-mile buffer on the northwest are vegetated by the limestone-associated Larrea scrub subtype. Two other vegetation types, Mojave Yucca – Nevada Ephedra Scrub and Mojave Wash Scrub also occur. The Mojave Yucca – Nevada Ephedra Scrub vegetation type is restricted to a small area of limestone pavement plain at the base of the limestone hills of the eastern extension of the Clark Mountain Range, in the north-central area of the one-mile buffer. It also extends into the very northern end of the utility corridor. Many small to medium ephemeral washes are associated with increased densities of cheesebush, and the larger ephemeral wash drainage features are vegetated with Mojave Wash Scrub. Figure 3-2 shows the general location of vegetation types present within the Ivanpah SEGS site, by project feature. Vegetation types observed during rare plant surveys of the Ivanpah Substation to Mountain Pass Substation area are described in the Biological Survey Report prepared by EPG (EPG 2008). In general, the area at lower elevations in the vicinity of the Ivanpah substation features rolling topography draining south toward I-15. The transmission line tops out at the Mountain Pass Substation (in San Bernardino County, California) at an elevation of approximately 5,320 feet (EPG, 2008). The dominant vegetation type at the lower elevations is a Blackbush series with Joshua trees (Yucca brevifolia). Blackbush is the dominant shrub, providing extensive groundcover. More conspicuous but less dominant, Joshua trees (Yucca brevifolia) are also present. Other plants include Mojave yucca (Yucca schidigera), broom snakeweed (Gutierrezia sarothrae), green ephedra (Ephedra viridis), desert almond (Prunus fasciculata), cheesebush (Hymenoclea salsola), and Utah juniper (Juniperus osteosperma). Near Mountain Pass, the plant community at this elevation is typical of mid-elevation desert mountains, and features Utah juniper, singleleaf pinyon (Pinus monophylla), Mormon tea (Ephedra sp.), and numerous shrubs, annuals, and perennial plants, including turpentine brush (Thamnosma montana), goldenbush (Ericameria sp.), bladder sage (Salazaria mexicana), desert lupine (Lupinus shockleyii), freckled milkvetch (Astragalus lentiginosus), and desert paintbrush (Castilleja angustifolia). Additional information on the vegetation types and plant species observed in the action area is included in the Botanical Resources Report (GANDA, 2008) and the Draft Biological Survey Report prepared by EPG (EPG, 2008).

3-2

3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE

3.1.3 Threatened and Endangered Plant Species Federally listed plant species were not identified during surveys of the action area conducted in 2007 and 2008. The following sources describe the results of the three botanical surveys conducted within the action area: 1)

2007 rare plant surveys of the Ivanpah SEGS site, including the one-mile site buffer, are included in the AFC (CH2M HILL, 2007)

2)

Results of the 2008 botanical surveys of the Ivanpah SEGS site are provided in the Technical Botanical Resources Report (Attachment BR3-1A)

3)

Results of rare plant surveys conducted for the transmission corridor extending southwest from the Ivanpah substation to the Mountain Pass area are presented in the El Dorado-Ivanpah Transmission Project Biological Resources Summary Report prepared by EPG (2008)

A summary of the key findings from these three rare plant surveys is provided below. Additional details on these surveys can be found in the survey reports.

3.1.3.1 Results of Surveys Conducted for the Ivanpah SEGS Project Eight special status plants were identified within the Ivanpah SEGS site (excluding the onemile buffer) during 2007 and 2008. None of these eight special status species are federally or state-listed. The eight special status plant species are: small-flowered androstephium (Androstephium breviflorum), Mojave milkweed (Asclepias nyctaginifolia), desert pincushion (Coryphantha chlorantha), Utah vine milkweed (Cynanchum utahense), nine-awned pappus grass (Enneapogon desvauxii), Parish’s club-cholla (Grusonia (=Opuntia) parishii), Utah mortonia (Mortonia utahensis) and Rusby’s desert mallow (Sphaeralcea rusbyi var. eremicola). Four of these special status plants (Mojave milkweed, desert pincushion, Utah vine milkweed and Parish’s club cholla) were also identified within the Ivanpah SEGS site in 2007. In addition to the eight special-status plant species identified during protocol-level surveys, desert portulaca (Portulaca halimoides), an ephemeral summer annual, was observed within the Ivanpah SEGS site in October 2007 by Jim Andre during independent visits that were not a part of the protocol-level survey effort for this project. A list of plant species observed during these surveys is provided in the AFC (CH2M HILL, 2007) and in the 2008 Botanical Resources report prepared by GANDA (2008).

3.1.3.2 Results of Surveys Conducted for the Proposed Telecommunications Line EPG, Inc. conducted reconnaissance-level biological surveys of the proposed approximately 8-mile-long telecommunications line on April 7 to 10, 2008 and April 14 to 15, 2008. Seven special status plant species, Mojave milkweed (Asclepias nyctaginifolia), nine-awned pappus grass (Enneapogon desvauxii), Parish’s club-cholla (Grusonia (=Opuntia) parishii), Aven Nelson’s phacelia (Phacelia anelsonii), sky-blue phacelia (Phacelia coerulea), black grama (Bouteloua eriopoda) and Utah vine milkweed (Cynanchum utahense) were identified within the proposed fiber optic line alignment. None of these special status plant species are federally listed. Additionally, one cactus in the genus Coryphantha [Escobaria], was identified in the Mountain Pass Area. This plant could not be positively identified to species, and it is

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3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE

uncertain if these plants are the desert pincushion, a special status plant. More detail on the rare plants identified during the surveys of the corridor between the Ivanpah Substation and the Mountain Pass Area are included in the biological resources summary report prepared by EPG (EPG, 2008).

3.1.4 Noxious Weeds Noxious weeds (also sometimes called invasive weeds) are defined for this document as species of non-native plants that are included on the weed lists of the California Department of Food and Agriculture (CDFA, 2007), the California Invasive Plant Council (Cal-IPC, 2006), or those weeds of special concern identified by the Bureau. The Mojave Weed Management Plan website (http://www.mojavewma.org/) was also consulted to assemble a list of target noxious weeds to include in surveys. A list of invasive species that occur, or potentially could occur in the action area is provided in the Table 1 of the Weed Management Plan (Attachment DR13-1A, Data Response Set 1F; CH2M HILL, 2008b). Weeds were searched for during all phases of the biological field surveys, when special attention was given to identifying non-native invasive plant species. During protocol surveys, all surveyors noted any plant species with which they were not familiar, and took samples that were identified by the project’s lead botanists, in part, to determine if these species were noxious weeds. The same procedure was used during reconnaissance surveys of the 1-mile buffer. Several noxious weeds are known to occur in the project vicinity. The weeds of highest concern in the general area include Sahara mustard (Brassica tournefortii) and saltcedar (Tamarix ramosissima) (pers. comm., C. Grant and C. Sullivan, 2007). Red brome (Bromus madritensis ssp. rubens), filaree (Erodium cicutarium), and other ubiquitous weeds are also present; however, because of the widespread nature of these weeds, control is considered impracticable.

3.1.4.1 Species Descriptions and Management Strategy Descriptions of the more common or troublesome noxious weeds occurring or potentially occurring at Ivanpah SEGS are provided in this section, along with the basic weed management strategy applicable to each. The Weed Management Plan (CH2M HILL, 2008b) provides additional information on management strategy and control methods for all observed and potentially occurring noxious weed species. Management strategies must encompass not only eradication, but also identify those weed species that are widely established and ubiquitous. Certain ubiquitous exotic species (e.g. Bromus madritensis ssp. rubens, Schismus spp., Erodium cicutarium) would be monitored and not immediately subject to control because control of these aggressive colonizers is impractical, and it would also likely slow site revegetation and rehabilitation by retarding the rate of secondary succession and surface stabilization. In addition, these species can play a beneficial role in accelerating surface stabilization and, therefore, reduce soil erosion caused by sheet flow or high winds. Complete eradication of large areas where infestations are already established would adversely affect other pioneer species, and is likely to be impractical because the area would likely be re-invaded from adjacent lands in the absence of physical barriers that isolate the area.

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The following list provides brief descriptions of the weed species of particular concern at the Ivanpah SEGS. Additional weed species are listed in Table 1 of the Weed Management Plan: •

Sahara mustard, or African mustard, (Brassica tournefortii) was not observed on the project site, but is known from the area and is of high concern. Cal-IPC has declared this plant highly invasive (Cal-IPC, 2006). This species would be eradicated whenever encountered.



Red brome (Bromus madritensis ssp. rubens) is an introduced Eurasian grass adapted to microhabitats that can be frequently found at the base of desert shrubs. It can also form carpet cover in pockets of fine-grained soils in rough terrain off the bajada. It is widespread and abundant in the Mojave Desert and has been found on the Ivanpah SEGS site. Seeds from this species can disperse readily and across large distances. CalIPC has declared this plant highly invasive (Cal-IPC, 2006). Stands of red brome have played an important role in accelerating wildfires in desert scrub communities (Brooks, 1999); a deleterious effect partly because warm-desert plant communities are ill-adapted to fire (Brown and Minnich, 1986). Because of its widespread distribution, red brome is not considered feasible for general control, and weed abatement measures for this species would not be required.



Cheat grass (Bromus tectorum) is among the most widely distributed invasive plant species in the western U.S. Closely related to red brome, it is adapted to colder steppe and woodland habitats. It is known to occur in the vicinity, but has not been observed on the project site and is likely to occur only at higher elevations. Cal-IPC has declared this plant highly invasive (Cal-IPC, 2006). Because of its widespread distribution, cheat grass is not considered feasible for general control and weed abatement measures would not be required.



Mediterranean grass (Schismus spp.) was observed patchily distributed throughout the project site. Cal-IPC has determined that this plant has a limited invasiveness rating in California (Cal-IPC, 2006). The Bureau and other agencies recognize that because of the widespread distribution of Mediterranean grass, this species is not considered feasible to control; therefore, weed abatement efforts for Mediterranean grass would not be required.



Although all invasive plants share the trait of being adapted to disturbed habitat, Russian thistle or tumbleweed (Salsola tragus) particularly tends to be restricted to roadway shoulders and other sites where the soil has been recently disturbed. This species was not observed at the project site, but is a common invader on disturbed sites. After summer rains in 2008, widespread areas on the northern margin of Ivanpah Playa were covered with a thick growth of tumbleweed. Cal-IPC has determined that this plant has a limited invasiveness rating in California (Cal-IPC, 2006). There is a high potential that Russian thistle could become established in the construction area and this species would be eradicated if observed.



London rocket (Sisymbrium irio) is widespread throughout the warm deserts of North America. It was identified near the project site along Colosseum Road. Cal-IPC has declared this plant moderately invasive (Cal-IPC, 2006). London rocket would be eradicated at Ivanpah SEGS wherever it is observed.

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3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE



Mediterranean tamarisk or saltcedar (Tamarix ramosissima) has been observed near the project site; however, it is a riparian plant and is therefore restricted to habitats where there is perennial saturation such as springs and seeps, or runoff from poorly maintained water pipelines or well pumps. Cal-IPC has declared this plant highly invasive (Cal-IPC, 2006). This species would be eradicated wherever observed on the project site.



Filaree or storksbill (Erodium cicutarium) is a widespread annual species common in disturbed habitats. It can form dense, transient populations when conditions are suitable. It has a limited overall rating by Cal-IPC, generally because the ecological impacts of the species are minor. Because of its widespread distribution, filaree is not considered feasible for general control and weed abatement measures would not be required onsite.

3.1.4.2 New Weeds Weeds not identified in the descriptions above, or previously reported for the area or anticipated, could colonize the site or invade site facilities, both during construction as well during operation. During construction, the project environmental compliance manager (ECM) would regularly update the list of potential noxious weeds, and identify any new potential threats. This would include developing a management strategy and management methods appropriate to the plant species and the nature of any potential invasion. Similarly, the facility plant site manager or appropriate designee during operations would be required to continually update the potential noxious weed list and provide monitoring and management appropriate to any new species.

3.1.5 Wildlife Species The diversity of vegetation and landscape features in and around the proposed Ivanpah SEGS provides habitat for a rich variety of Mojave Desert and non-native wildlife. These includes the desert tortoise and other reptiles such as side-blotched lizard (Uta stansburiana), desert iguana (Dipsosaurus dorsalis), long-nosed leopard lizard (Gambelia wislizenii), western whiptail (Cnemidophorus tigris), zebra-tailed lizard (Callisaurus draconoides), common collared lizard (Crotaphytus collaris), sidewinder (Crotalus cerastes), and gopher snake (Pituophis melanoleucus). Developing knowledge of the banded Gila monster (Heloderma suspectum cinctum) distribution in California suggests that this large but seldom seen lizard may occur in the project vicinity. The Ivanpah SEGS project area provides forage, cover, roosting, and nesting habitat for a variety of bird species. Resident and migratory birds use the resources during the winter, migratory, and breeding seasons. This includes birds such as Say’s phoebe (Sayornis saya), black-throated sparrow (Amphispiza bilineata), white-crowned sparrow (Zonotrichia leucophrys), sage sparrow (Amphispiza belli), blue-gray gnatcatcher (Polioptila caerulea), cactus wren (Campylorhynchus brunneicapillus), Verdin (Auriparus flaviceps), western kingbird (Tyrannus verticalis), sage thrasher (Oreoscoptes montanus), house finch (Carpodacus mexicanus), lesser nighthawk (Chordeiles acutipennis), common ground-dove (Columbina passerina), mourning dove (Zenaida macroura), Gambel’s quail (Callipepla gambelii), American kestrel (Falco sparverius), and red-tailed hawk (Buteo jamaicensis).

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3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE

A diverse collection of landscape features, vegetation diversity, forage, and prey availability in the Ivanpah SEGS project area is likely to attract a variety of mammal species such as Audubon’s cottontail (Sylvilagus audubonii), black-tailed jackrabbit (Lepus californicus), whitetail antelope squirrel (Ammospermophilus leucurus), desert kit fox (Vulpes macrotis), and coyote (Canis latrans). The regional mule deer (Odocoileus hemionus hemionus) population is considered low despite efforts in 1948 to reintroduce the species to the New York and Providence mountains, installation of guzzlers, and efforts to control the introduced feral burro (Equus asinus) (NPS, 2006). Given the proximity of the Clark Mountains, it is likely that deer and desert bighorn sheep (Ovis canadensis nelsoni) move down into the upper elevations of the valley, including the Ivanpah SEGS project area, to forage. It is also likely that areas of Ivanpah Valley provide important movement corridors for mule deer and bighorn sheep.

3.2 Environmental Baseline The environmental baseline includes the past and present affects of all Federal, State, or private actions and other human activities in the action area, the anticipated effects of all proposed Federal projects in the action area that have already undergone formal or early section 7 or section 10 consultation, and the effect of State or private actions which are contemporaneous with the consultation process (50 CFR 402.02). The Ivanpah Valley has been affected by a variety of activities ranging from the construction and continued use of major highways such as I-15 and secondary roads, unimproved roads and trails, pipelines, Union Pacific Railroad, casinos and retail businesses, recreational opportunities (such as the Primm Golf Club and land sailing/racing on the Ivanpah Dry Lakebed), electrical transmission lines and substations, and other facilities developed around the Nevada communities of Jean and Primm as well as the California community of Nipton, and the ranchette development along Nipton Road. Development and human intrusion within the area has resulted in desert tortoise habitat loss and degradation, habitat fragmentation, harm and harassment of individual tortoises, and the introduction of nonnative species. The Boulder Corridor, a utility corridor containing such utilities as the Los Angeles Department of Water and Power (LADWP) electrical transmission line, KRGT line, and Level 3 fiber optic line is located directly north of the proposed site. Additionally, the SCE and LADWP electrical transmission lines cross the southern extent of the project site. Several water wells also exist in the immediate area.

3.2.1 Projects That Are Reasonably Foreseeable There are five other projects that have been studied in the Ivanpah Valley and in the vicinity of the proposed Ivanpah SEGS project including: • • • • • • •

Desert Xpress Rail Line Improvements to I-15. This project is under construction. Las Vegas Valley Water District Pipeline Southern Nevada Supplemental Airport (Ivanpah Valley Airport) Table Mountain Wind Generating Facility AT&T Fiber Optic Line. This project is completed. OptiSolar

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3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE

3.2.1.1 Desert Xpress Rail Line The Desert Xpress Rail Line project is a privately funded proposed high-speed rail passenger train from Victorville, California, to Las Vegas, Nevada. The proposal was initiated to provide an alternative to automobile travel between the Los Angeles area and Las Vegas along I-15. This highway, the most direct automobile route between the Los Angeles area and Las Vegas, experiences heavy traffic congestion, especially on weekends. Currently, there is no passenger train service to Las Vegas. The city of Victorville was selected as the location for the western-most terminal since it is within a one-hour drive of 12 million people. The train would travel up to 125 miles per hour and would make the 190-mile trip from Victorville to Las Vegas in approximately 1 hour and 45 minutes, taking more than 2 hours off the typical automobile travel time. According to the Federal Railroad Administration (FRA), the project would involve construction of a fully grade separated, dedicated double track passenger-only railroad along an approximately 200-mile corridor, from Victorville to Las Vegas. Segment 4 of the proposed route (from Mountain Pass to Primm, NV) has two alternatives. It appears that Alternatives A and B would diverge north or south of I-15 west of the I-15/Nipton Road (Highway 164) interchange. Alternative A would leave the I-15 freeway corridor in the vicinity of Halloran Springs between Kelbaker Road and Cima Road and head south for approximately 4 miles before returning to the I-15 freeway corridor south of Primm. A portion of this alignment may encroach on the MNP, approximately one half mile south of the I-15 freeway. This alternative of the proposed rail line would be within 0.8 miles south of the Ivanpah SEGS project as it parallels I-15. Alternative B would leave the I-15 freeway ROW in the same vicinity and head north, crossing the Ivanpah valley through the middle of Ivanpah 2 before returning to the I-15 freeway ROW south of Primm. A 4,000-foot long tunnel would be necessary for Alternative B (FRA, 2006). Preparation of an environmental impact statement (EIS) for the project was initiated during FRA public scoping meetings on July 25 and 26, 2006. The Draft Environmental Impact Statement on this project was released for public comment in March 2009. The comment period on the EIS ended May22, 2009. More information on the project can be found at: http://www.fra.dot.gov/us/content/1703.

3.2.1.2 Interstate 15 Improvements Interstate 15 is the major highway between Southern California and Las Vegas. As an international connection between the Canadian border and Montana, and the Mexican border south of San Diego, the freeway carries high volumes of interstate traffic, particularly semi-trucks. Near the California-Nevada border, traffic volumes on I-15 in San Bernardino County average 40,000 vehicles per day. These volumes include both long-distance and tourist traffic to and from the Las Vegas and Colorado River destinations. Traffic growth in the project area has been moderate (two to three percent per year), although traffic volumes have increased much faster further south. The California Department of Transportation (Caltrans) has an ongoing plan for improvements to I-15 (DOT, 2004). Highway construction planned between Barstow and the Nevada state line includes: 1) a proposed point-of-entry inspection station near the Nevada border with construction likely to start in late 2010 and continue for 2 years; 2) a 12-milelong northbound truck descending lane and pavement rehabilitation (expected to be

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3. BIOLOGICAL SETTING AND ENVIRONMENTAL BASELINE

completed in the summer of 2010); and 3) regrading of median slopes, (completed, Pers. Comm., Bory, 2008). The increasing traffic volumes, as well as the spot widening to the freeway, would serve to increase the highway’s role in acting as a barrier to the natural movements of terrestrial wildlife species, specifically the desert tortoise, as well as to potentially increased mortality resulting from vehicle strikes. There is no permanent tortoise fencing along this stretch of I-15.

3.2.1.3 Las Vegas Valley Water District Pipeline The Las Vegas Valley Water District has proposed construction and operation of a water supply pipeline from the existing 2420 Zone Bermuda Reservoir (located in southern Las Vegas) to Jean, Primm, the Southern Nevada Correctional Center, and the proposed Ivanpah Valley Airport. The pipeline also would provide water to other users along the I-15 corridor and within the Ivanpah Valley in general. The project would include more than 30 miles of large-diameter pipeline, 3 pump stations, 2 reservoirs, and associated access roads, electric power distribution lines, and telemetry control structures (Bureau, 2002). The availability of a reliable water source in Ivanpah Valley would likely result in increased development and a variety of direct and indirect effects as a result of the development.

3.2.1.4 Southern Nevada Supplemental Airport (Ivanpah Valley Airport) The Clark County Department of Aviation (CCDOA) is proposing to construct a new supplemental commercial service airport in the Ivanpah Valley (Ivanpah Valley Airport). The new airport would provide additional capacity to serve residents of southern Nevada and visitors to the Las Vegas area. Ivanpah Valley Airport is the planned relief airport for McCarran International Airport. Since there is only limited space left for expansion at McCarran, a new airport is an alternative to increase capacity. Clark County, Nevada purchased 6,500 acres of land along I-15 in the Ivanpah Valley from the Bureau about 30 miles southwest of McCarran International Airport. The proposed airport would be located between Jean and Primm, Nevada. The Ivanpah Valley Airport project is planned on 9.4 square miles along I-15. The project site is bordered by I-15 on the west and the Union Pacific Rail Road (UPRR) tracks on the east. Primm, Nevada, an existing commercial development including hotel casino and shopping plaza, is located approximately one mile south of the south end of the airport project. Jean, Nevada is located approximately 17 miles north of the Ivanpah SEGS site. The proposed airport site is located on part of the Roach Lake Playa (Clark County Department of Aviation 2004). The analysis of the project effects has not been completed. On August 4, 2008, the FAA and the Bureau released a Draft Alternatives Working Paper for public comment. All dates for construction and availability are fluid at this time. However, the official CCDOA statements suggest a goal of starting construction in 2010 and beginning operation in 2017 (Stutz, 2007). The proposed airport project is within tortoise habitat.

3.2.1.5 Table Mountain Wind Energy Facility The Table Mountain Wind Company (TMWC) is proposing to develop a nominal 150 to 205 MW wind-powered electric generation facility and ancillary facilities located at the south end of the Spring Mountain Range between the communities of Goodsprings, Sandy

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Valley, Jean, and Primm, Nevada. TMWC has applied for a 25-year term ROW grant from the Bureau’s Las Vegas Field Office to construct, operate, and maintain a wind generating and ancillary facilities on approximately 325 acres of public land. The purpose of the proposed project is to provide wind-generated electricity to meet existing and future electricity needs and demonstrate the ability of wind energy to provide a reliable, economical, and environmentally acceptable energy resource in southern Nevada. It was concluded in the EIS that implementation of the proposed project or alternatives would result in significant impacts on visual resources and potentially significant impacts on wildlife resources. The project is located within occupied desert tortoise habitat and would therefore adversely affect the tortoise. Positive benefit to air quality and socioeconomic resources would result from the development and operation of the wind generating facility (PBS&J, 2002). The project location is approximately 13 miles north of the Ivanpah SEGS site. Project workforce requirements and proposed construction schedules are not available. Construction workers in Las Vegas would use I-15 to Jean, NV to access the site.

3.2.1.6 AT&T Fiber-optic Cable Replacement Project AT&T Corporation (AT&T) recently replaced deteriorating portions of its approximately 190-mile fiber optic cable extending from Las Vegas, Nevada, to Victorville, California. The activities required to ensure the function and capacity of the overall system included replacement of portions of the direct bury cable, as well as replacement of portions of the cable within existing conduit. Constructed in 1988–89, this cable route contains a 0.5-inch diameter fiber optic cable that is either “directly buried” in the ground or otherwise enclosed within existing buried conduit. Segment 1, of the 3-segment project, parallels the west side of I-15 from Nipton Road to Primm, NV. The California State Lands Commission (CSLC) and the Bureau prepared a draft Environmental Assessment/Mitigated Negative Declaration (EA/MND) to assess the environmental impacts associated with the replacement of the three segments of AT&T’s existing fiber optic cable (Bureau and CSLC, 2008).

3.2.1.7 OptiSolar (First Solar) OptiSolar, a Hayward solar manufacturer of thin film amorphous silicon solar panels and developer for wholesale applications, or its subsidiary Gen3 Solar, submitted a ROW application to the Bureau for land immediately east of the Ivanpah SEGS project area. This application is now managed by First Solar, who purchased the assets of OptiSolar. According to the Bureau’s Needles Field Office, a plan of development (POD) has been submitted for the proposed 300 MW project. The POD is currently being updated. The Bureau’s review of the potential impacts associated with the POD is not yet available for public review, and there has been no Notice of Intent (NOI) issued yet for this project. No construction schedule is available.

3.2.2 Projects That Are Not Reasonably Foreseeable There is some information about several other projects within the Ivanpah basin; however at this time, these projects have not proceeded in the normal course to the point that there is enough publicly available information to determine their potential effects and have some

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comfort level that they would proceed to construction. Accordingly, these potential projects are considered speculative and thus not reasonably foreseeable. They are: • • • • •

Amtrak Rail Line California-Nevada Interstate Maglev train Solar Investments I, LLC PPM Energy 63 MW Wind Project Reliant Energy 500 kV Power Line

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Status of Species and Habitat 4.1 Mojave Desert Tortoise (Gopherus agassizii) This section describes the status, natural history, distribution, abundance and habitat of the Mojave desert tortoise relative to the proposed action area. The section includes the results of USFWS-protocol surveys conducted for the action area in 2007 and 2008.

4.1.1 Status On August 4, 1989, the USFWS published an emergency rule listing the Mojave Desert population of the desert tortoise as endangered (USFWS, 1989). The USFWS final rule, dated April 2, 1990, determined the Mojave population of the desert tortoise to be threatened under the Federal Endangered Species Act (USFWS, 1990a). The tortoise was listed in response to loss and degradation of habitat caused by numerous human activities including urbanization, agricultural development, military training, recreational use, mining, and livestock grazing. The loss of individual desert tortoises to increased predation by common ravens, collection by humans for pets or consumption, collisions with vehicles on paved and unpaved roads, and mortality resulting from diseases also contributed to the listing. The tortoise was statelisted in California as threatened in 1989, and is classified as State Protected and Threatened by the neighboring state of Nevada. Prior to state and federal listing, Bureau initiated efforts to protect the tortoise in 1988 with a range-wide management plan (Bureau, 2001). The USFWS desert tortoise recovery plan is the key strategy for recovery and delisting of this species (USFWS, 1994b). As part of the recovery strategy, the USFWS designated critical habitat for the desert tortoise in portions of California, Nevada, Arizona, and Utah (USFWS, 1994b). Further, the plan recommends implementation of reserve level protection of desert tortoise populations and habitat within DWMAs, while maintaining and protecting other sensitive species and ecosystem functions. DWMAs were developed to provide “reserve level” protection for the tortoise (USFWS, 1994b). Critical habitat was designated to identify areas containing key biological and physical attributes that are essential to the desert tortoise’s survival and conservation, such as space, food, water, nutrition, cover, shelter, and reproductive sites. As part of the actions needed to accomplish the recovery of this species, land management goals within all DWMAs include restriction of human activities that adversely affect desert tortoises (USFWS, 1994b).

4.1.2 Natural History, Distribution, Abundance, and Habitat The desert tortoise is a long-lived reptile with a high domed shell, stocky, elephant-like limbs and a short tail. Gopherus agassizii is one of four tortoise species found in North America. The desert tortoise’s range includes the Mojave Desert region of Nevada, southern California, and the southwest corner of Utah and the Sonoran Desert region of Arizona and northern Mexico. The desert tortoise is divided into two primary populations, the Mojave and the Sonoran. The Mojave population is located north and west of the Colorado River and the Sonoran includes all tortoises south and east of the river in Arizona and Mexico (in

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4. STATUS OF SPECIES AND HABITAT

Averill-Murray and Swann 2002). The Mojave population is primarily found in creosote bush (Larrea tridentata) dominated valleys with adequate annual forbs for forage. Adult desert tortoises typically weigh 10 pounds or more and reach lengths of 11 to 16 inches (in USFWS, 1994). Desert tortoises have been known to live up to 70 years or more but the typical adult likely lives 25 to 35 years (in USFWS, 1994). Like many long-lived species, the tortoise has a relatively slow rate of reproduction. Sexual maturity is primarily size dependent (≥ 180 to 208 millimeters) with tortoises typically achieving breeding status at 15 to 20 years of age. Mating generally occurs in the spring (mid-March to late-May), with nesting and egg-laying occurring from April to July (Rostral et al., 1994; USFWS, 1994b). Desert tortoises have also been known to lay eggs in the fall (in USFWS, 1994b). The female tortoise typically lays her eggs in an earthen chamber approximately 2.7 to 3.9 inches deep, excavated near the mouth of a burrow or under a bush (Woodbury and Hardy, 1948; USFWS, 1994b). Following egg-laying, the female covers the eggs with soil. Clutch size ranges from 2 to 14 eggs, with an average of 5 to 6 eggs (Luckenbach, 1982). Females can produce as much as three clutches in a season. Eggs are subject to predation from a variety of predators, and female tortoises have been observed apparently defending their clutches from Gila monsters (Gienger and Tracy, 2008). The eggs typically hatch 90 to 120 days later, between August and October. Hatchlings are born with a yolk sac that protrudes through the plastron. Eggs incubated above 89.3 degrees Fahrenheit (°F) develop into females and males are the result of cooler incubation (in USFWS, 1994b). This yolk sac typically sustains the animal for up to 6 months. Hatchling desert tortoises often go into hibernation in the late fall but often emerge for short active periods on warm sunny or rainy days (Luckenbach, 1982). Desert tortoise activity is seasonally variable. Peak adult and juvenile desert tortoise-activity in California typically coincides with the greatest annual forage availability during the early spring and summer. However, tortoises will emerge from their burrows at any time of year when the weather is suitable. Hatchling desert tortoises typically become active earlier than adults and their greatest activity period can be expected between late winter and spring. During active periods, tortoises feed on a wide variety of herbaceous plants, including cactus, grasses, and annual flowers (USFWS, 1994b). Annual home ranges have been estimated between 10 and 450 acres and are age, sex, seasonal, and resource density dependent (USFWS, 1994b). Although adult males can be aggressive toward each other during the breeding season, there can be a great deal of overlap in individual home ranges (USFWS, 1994b). More than 1.5 square miles of habitat may be required to meet the life history needs of a tortoise and individuals have been known to travel as much or more than 7 miles at a time (Bureau, 2001). In drought years, tortoises can be expected to wander farther in search of forage. During their active period, desert tortoises retreat to shallow burrows and aboveground shade to escape the heat of the day. They will also retire to burrows at nighttime. Desert tortoises are primarily dormant in winter in underground burrows and sometimes congregate in communal dens. Tortoise population densities have changed over time, resulting in their federal and state listing. Estimated densities of the total desert tortoise population in the 1980s ranged from 10 to 84 individuals per 0.5 hectare (in Boarman, 2002). The same estimate for tortoises less

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4. STATUS OF SPECIES AND HABITAT

than 140 millimeters in length ranged from 2 to 63 individuals for every 0.5 hectares, with the realization that juvenile tortoises are more difficult to find and likely underrepresented in population estimates based solely on survey data. As presented in Boarman 2002, juvenile survivorship of 75 percent per year may be necessary to maintain population stability and survivorship of upwards to 97 percent may be required for the recovery of a declining population, making raven predation a major cause for concern. The proposed Ivanpah SEGS is located in the southeastern portion of the NEMO Planning Area Boundary. The NEMO addresses threatened and endangered species conservation and recovery (Bureau, 2001). This includes alternatives to address mortality caused by raven predation (Bureau, 2001). The NEMO defines five geographical areas of tortoise habitat in the planning area that include an Ivanpah Valley and a North Ivanpah Valley area, the Ivanpah SEGS being located with the Ivanpah Valley habitat area. The Bureau has designated both Ivanpah areas as Category III desert tortoise habitat with a management goal to maintain a viable tortoise population (Bureau, 2001). According to the NEMO, the non-lakebed portion of Ivanpah Valley area is excellent quality tortoise habitat with some of the highest population densities in the East Mojave while the North Ivanpah Valley area is quantified as good quality tortoise habitat (Bureau, 2001). The proposed Ivanpah SEGS project area is within the Northeastern Mohave Recovery Unit, one of six designated evolutionarily significant units within the range of the tortoise (USFWS, 1994b). When determining the size and location of DWMAs, the Service estimated that stable tortoise populations are likely to have densities of at least 10 adults per square mile (USFWS, 1994b). When the 1994 Recovery Plan was being issued some of the highest known tortoise densities were in southern Ivanpah Valley, with 200 to 250 adults per square mile (USFWS, 1994b). These 1990s densities were less than estimates for the southern Ivanpah Valley in the 1970s. That 20-year decline has been heavily attributed to raven predation (USFWS, 1994). Densities for the northern Ivanpah Valley in the 1990s were typically less than 50 adults per square mile (USFWS, 1994b). According to the 1994 recovery plan, tortoise densities in the Ivanpah Valley DWMA were estimated between 5 and 250 adult tortoises per square mile and the area was given a threat level of 3 out of 5 (5 = extremely high) (USFWS, 1994b). The Desert Tortoise Recovery Planning Assessment Committee (DTRPAC) recommended revising the threat level for the Ivanpah Valley DWMA to a 4 to reflect 2003 conditions (DTRPAC, 2004). As a result of 2002 line distance sampling surveys in the Ivanpah Valley plots within the Mojave National Preserve, live tortoises were found on 16 percent of the transects while carcasses were found on 46 percent, but there was not enough statistical data to suggest a recent decline in the adult population (DTRPAC, 2004). It is well established that the desert tortoise is distributed throughout Ivanpah Valley with the exception of the dry lakes and developed areas. Twenty-five live tortoises, 97 carcasses, 214 burrows, and 50 other tortoise sign were encountered during the 2007 and 2008 USFWS protocol tortoise survey of the Ivanpah SEGS

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4. STATUS OF SPECIES AND HABITAT

4.1.3 Survey Methodology USFWS protocol desert tortoise surveys (USFWS, 1990b, 1992), including zone-of-influence transects (see Figure 4-1) were conducted for the project site from April 9 to June 5, 2007, and additional surveys were conducted from May 20 to May 25, 2008. The 2008 survey report is provided in Attachment H. As part of SCE’s transmission line upgrade and fiber optic line, EPG, Inc. performed surveys of the proposed approximately 8-mile telecommunications alignment on April 7 to 10, 2008 and April 14 to 15, 2008. The telecommunication line surveys were not protocol-level; however, their results are summarized in this section.

4.1.4 Survey Results The action area and vicinity provides good quality desert tortoise habitat. Desert tortoises are likely to be encountered throughout the area from the edges of the Ivanpah Dry Lake north to the base of the Clark Mountains. The CNDDB contains records of the desert tortoise within the Ivanpah SEGS action area and tortoises were found during the local installation of the Kern River Gas Pipeline and the LADWP transmission line (John Cleckler, personal observation). No desert tortoises were reported within the action area during the development of the adjacent Primm Valley Golf Club (personal communication with Ray Bransfield/USFWS May 15, 2008). Tortoises were found in close proximity to the golf club perimeter fence during the 2007 Ivanpah SEGS protocol surveys. Changes to the Ivanpah SEGS design increased the size of the action area and, therefore, additional protocol surveys were conducted for the additional areas in 2008. As a result of the 2007 and 2008 protocol surveys, a total of 386 tortoise sign including 25 live tortoises, 97 carcasses, 214 burrows, and 50 other sign were encountered. Tortoise sign and density was greatest in Ivanpah 1 at the southern boundary of the project site and was less dense as the survey moved towards the Clark Mountains and Ivanpah 3. The desert tortoise sign discovered during the 2007 surveys and their physical relation to the action area are illustrated in Figure 4-2. The figure displays all detected 2007 desert tortoise sign that has been identified by a color coded number. These numbers are linked to the specific characteristics for each sign that are summarized in several tables included in Appendix I. Specific characteristics tortoise sign were assigned a number in the Appendix I table that can be linked to Figure 4-2. Surveys of the fiber optic route by EPG, Inc. (2008) confirmed that the entire route is within desert tortoise habitat. Protocol level surveys were not conducted. However, in surveying the fiber optic route EPG found 3 tortoise burrows and a tortoise shell. The 2008 desert tortoise survey report for the additional action area around the project site is included in Attachment H.

4.1.5 Proposed Translocation Area At the suggestion of the USFWS, the Applicant contemplated potential translocation sites near I-15. However, in response to comments received from the resource agencies, the Applicant refined the potential relocation sites to include four sites located to the west of the three Ivanpah solar plants. These areas were chosen for further analysis due to their

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4. STATUS OF SPECIES AND HABITAT

proximity to the Ivanpah solar plants; thus, reducing the distance required for relocation. Vegetation surveys were performed in these areas to determine their suitability for use as relocation sites. Population surveys were also performed to get a sense of how dense the tortoise population was in those areas. Both studies are summarized below.

4.1.5.1 Vegetation Survey of Proposed Translocation Area Site vegetation surveys and analyses of vegetation data were conducted at Ivanpah SEGS and surrounding areas in the northwestern Ivanpah Valley during April and July 2009. These data were first gathered to characterize existing vegetation baseline conditions, and then for the evaluation of desert tortoise habitat. The latter is to be used to determine the suitability of proposed relocation and translocation areas for desert tortoise that may need to be moved during implementation of the Ivanpah SEGS project. Due to the fact that most of the data was collected during summer and well after the flowering period of most winter and spring annuals, the focus of this study was on perennial shrubs and succulents alone.

4.1.5.1.1 Survey Protocol Sampling for shrub and succulent abundance, diversity (Smith, 1992), and richness were conducted using 12-meter radius relevés (a term used in vegetation ecology for an arbitrarily assigned vegetation sampling plot) (CNPS, 2000). The number of individuals of each species was tallied within each relevé. Data was collected within the three Ivanpah units, within potential relocation and translocation areas in the vicinity, and in other surrounding areas (Figure 4-3). A more detailed summary of this analysis is provided in the Desert Tortoise Translocation Plan.

4.1.5.1.2 Survey Findings Due to their higher elevation, the relocation areas to the west of the Ivanpah SEGS units generally have higher shrub and succulent diversity and richness than the Ivanpah SEGS units themselves. Based on the stipulations provided by CDFG and CEC, the area to the west of the site appears to be suitable for the relocation or translocation of desert tortoise, in terms of vegetation. It is important to note that the western half of the relocation area to the west of Ivanpah 3 has a different plant species composition than the Ivanpah SEGS units and the remainder of the relocation area. This northwestern portion of the relocation area is in a transition zone, where blackbrush is present and creosote bush and burrobush are less common. In RI3-R3, out of 18 species, blackbrush is the most abundant species and creosote bush is 8th most abundant. Tortoises typically do not occupy these areas as commonly as creosote-dominated areas (Nussear et al. 2009); however, one live tortoise and four tortoise carcasses were found in translocation area N1 during recent tortoise surveys (complete results discussed in a separate memorandum). Based upon the results of this study, the translocation areas (N1 through N4) are expected to have suitable tortoise habitat for translocation of tortoises. Although vegetation sampling was not conducted within these translocation areas, greater shrub and succulent diversity and richness is expected because the elevation is higher than the Ivanpah SEGS units.

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4. STATUS OF SPECIES AND HABITAT

4.1.5.2 Desert Tortoise Presence/Absence Survey of Proposed Translocation Area Desert tortoise surveys were performed by SNEI (2009) to determine the presence/absence and abundance of desert tortoises within the proposed translocation sites (Attachment G). More information on these surveys is contained in the Desert Tortoise Translocation Plan. A summary of the results is presented here.

4.1.5.2.1 Survey Protocol The proposed translocation areas were surveyed for desert tortoise sign in July and August 2009. Biologists used 100 percent coverage of the translocation areas using 10 meter transects. The survey focused on visual signs of desert tortoise (e.g., burrows, shells bones, scutes, scat, tracks, etc.).

4.1.5.2.2 Survey Findings All four translocation sites had habitat that showed at least some sign of desert tortoise. Coyote scat was also observed in all four sites. Site N1 contained 77 burrows (none of which were class 1), 4 carcasses and 1 large male tortoise. It also contained one set of coyote tracks and 3 to 4 pieces of coyote scat. The biologists also found one tortoise carcass that appeared to have been bitten by a large predator and another where the carapace had been popped off the plastron. Site N2 contained 50 burrows, 3 tortoises (all inside burrows) and 2 carcasses. It had two sets of coyote tracks and 3 to 4 pieces of coyote scat. No other predator sign was found. Site N3 had the most predator sign with 5 to 6 pieces of coyote scat and 3 separate sets of coyote tracks. The biologists also found 34 burrows and 4 carcasses. Two tortoise carcasses had bite marks on them and one was found next to coyote scat. Site N4, the northernmost site, had the least predator sign with only 2 to 3 pieces of coyote scat and no coyote tracks. In addition, 31 tortoise burrows, 1 carcass and 1 drinking circle was found. It is also worth noting that during the fieldwork the biologists did not see any feral dogs, ravens, nests, or potential perches at any of the four translocation sites. Based on the data found, it was determined that the density of tortoise in the four areas was low. Moving tortoises from the Ivanpah solar sites to the proposed translocation sites would not overburden the existing population.

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FIGURE 4-1 2007 DESERT TORTOISE SURVEY AREA IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

ES062007009SAC Figure_4-1.ai 03/27/09 tdaus

CLARK MOUNTAIN RANGE

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FIGURE 4-2 2007 DESERT TORTOISE SURVEY RESULTS IVANPAH SOLAR ELECTRIC GENERATING SYSTEM

7.5N13E ction: 36

17N 14E Section: 12

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KEY

I1-R1 through I1-R3: Ivanpah 1, relevés 1 - 3 I2-R1 through I2-R3: Ivanpah 2, relevés 1 - 3 I3-R1 through I3-R5: Ivanpah 3, relevés 1 - 5 RI1-R1 and RI1-R2: Relocation Area for Ivanpah 1, relevés 1 and 2 RI2-R1: Relocation Area for Ivanpah 2, relevé 1 RIST-R1 and RIST-R2: Relocation 16Nrelevés 14E 1 and 2 16N 14EArea for Ivanpah Substation, 16N 14ERI3-R1 through RI3-R3: Relocation Area for Ivanpah 3, relevés 1 - 3 33 Section: Section: 32 Section: 31 TS1-R1 through TS1-R3: Southern Translocation Area 1, relevés 1 - 3 TS2-R1 through TS2-R3: Southern Translocation Area 2, relevés 1 - 3 TS3-R1 through TS3-R3: Southern Translocation Area 3, relevés 1 - 3 KRGT1 and KRGT2: Kern River Gas Transmission Line Undisturbed Relevés 1 and 2 BP: Borrow Pit Undisturbed Relevé

Shrub & Succulent Sampling Sites

16N 13E ) Corral Location " Section: 13 Train Line Option 4B Train Line Option 4C Trails Project Site Relocation Area Translocation Area

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Section: 19

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15.5N14E 15.5N14E Feet Section: 21Section: 20

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FIGURE 4-3 VEGETATION SAMPLING FOR PROPOSED DESERT TORTOISE RELOCATION AND TRANSLOCATION AREAS 15.5N14E 15.5N15E

15.5N14E 15.5N14E IVANPAH SOLAR ELECTRIC GENERATING SYSTEM Section: 24 Section: 23 Section: 22

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Section: 19

Effects of Proposed Action 5.1 Introduction This section includes a summary of the analysis of the potential direct, indirect and cumulative effects to the desert tortoise resulting from the proposed construction and operation of Ivanpah SEGS.

5.2 Direct Effects Direct effects are those that are caused by the proposed action and occur at the same time and place. As described in Section 3, no federally listed plants occur within the action area; therefore, no direct effects to federally listed plants are expected to occur as a result of project implementation. The proposed action area is not located within designated critical habitat for the desert tortoise but is located approximately 5 miles north of the Ivanpah critical habitat unit, just north of the I-15 and Route 164 interchange. The action area is within suitable habitat for the desert tortoise and 25 live tortoises were found as a result of a combined 2007 and 2008 protocol level surveys of the action area. Based on the protocol surveys, the proposed action would likely result in the translocation of 25 tortoises and the destruction of 214 tortoise burrows. During the life of the Project, Ivanpah SEGS project would permanently remove about 3,750 acres of desert tortoise habitat. An additional 310 acres would be used for temporary laydown and temporary work space for utility installation. It would take many years to restore the temporary work space to baseline habitat value. Impacts from the construction of the fiber optic line are expected to be minimal because modifications to the existing distribution lines would be done using a bucket truck that would remain in the dirt service road, or on foot for areas not accessible by truck. Stringing the fiber optic cable would require a 40-foot by 60-foot area every 10,000 to 20,000 feet. The work that could not be done from the existing dirt service road would be handled by vehicles driving over the existing vegetation. Desert tortoise monitors will be present during these construction activities. Desert tortoises may be harmed during clearing, grubbing, mowing, grading and trenching activities or may become entrapped within open trenches and pipes. Project actions could result in direct mortality, injury, or harassment of individuals as a result of encounters with vehicles or heavy equipment, whether in the action area or from vehicles straying from designated access or designated areas into adjacent habitat. Other direct effects could include individual tortoises being crushed or entombed in their burrows, collection or vandalism, disruption of tortoise behavior during construction or operation of facilities, disturbance by noise or vibrations from the heavy equipment, injury or mortality from encounters with workers’ or visitors' pets, and trash that may attract predators such as

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6. REFERENCES

ravens and coyotes. Desert tortoises may also be attracted to the construction area by application of water to control dust, placing them at higher risk of injury or mortality. Increased human activity and vehicle travel would occur from the construction and improvement of access roads, which could disturb, injure, or kill individual tortoises. Also, tortoises may take shelter under parked vehicles and be killed, injured, or harassed when the vehicle is moved. Installation of the security and exclusionary fencing could result in direct effects such as mortality, injury, or harassment of desert tortoises due to equipment operation, installation activities, removal of tortoise burrows, and tortoise translocation. The fencing would preclude desert tortoises from re-entering. This would result in fragmentation of habitat and individual home ranges. Capturing, handling, and relocating desert tortoises from the proposed site after the installation of the fencing would result in harassment and may also result in death or injury. Blythe et al. (2003) found that translocated Sonoran desert tortoises moved less than 0.5 mile returned to their home ranges within a few days. Tortoises moved outside their home ranges would likely attempt to return to the area from which they were moved, making it difficult to remove them from the potential adverse effects associated with project construction. Removal of habitat within a tortoise’s home range or segregating individuals from their home range with a fence would likely result in displacement stress that could result in loss of health, exposure, increased risk of predation, increased intraspecific competition, and death. Tortoises may die or become injured by capture and relocation if these methods are performed improperly, particularly during extreme temperatures, or if they void their bladders. Averill-Murray (2001) determined that tortoises that voided their bladders during handling had significantly lower overall survival rates (0.81-0.88) than those that did not void (0.96). If multiple desert tortoises are handled by biologists without the use of appropriate protective measures and procedures, such as reused latex gloves, pathogens may be spread among the tortoises.

5.3 Indirect Effects Indirect effects are those that are caused by, or result from, the proposed action and are later in time, but reasonably certain to occur. In contrast to direct effects, indirect effects are more subtle, and may affect individuals and populations and habitat quality over an extended period of time, long after construction activities have been completed. Indirect effects are of particular concern for long-lived species such as the desert tortoise because project-related effects may not become evident in individuals or populations until years later. The loss of desert tortoise habitat during the project life that would occur from permanent use of about 3,750 acres and removing as much as 310 acres of shrubs and herbaceous vegetation during the construction period, would indirectly affect the species through the loss of burrowing, breeding, and foraging habitat. Habitat quality would be reduced with the potential introduction of invasive plant species and compaction of soils. Additionally, the introduction of noxious weeds may lead to increased wildfire frequency (Brooks et al., 2003). Other potential indirect effects include the permanently fenced area acting as barriers that would impede any long-term natural movements of desert tortoises attempting to return to their original home ranges and burrows.

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6. REFERENCES

The potential for severe long-term effects include collisions and collections along the paved access roads where vehicle frequency and speed is generally greatest. Census data indicate that desert tortoise numbers decline as vehicle use increases (Bury et al., 1977) and that tortoise sign increases with increased distance from roads (Nicholson, 1978). Additional effects that may occur from casual use of the access roads in the vicinity of the action area include unauthorized trail creation and off-highway vehicle use. The proposed Ivanpah SEGS would be the largest solar facility of its kind at this time and could attract public curiosity that would result in greater disturbance of the surrounding habitat and potential collection and other take of desert tortoise. Human activities may provide food in the form of trash and litter or water that attracts tortoise predators such as the common raven, desert kit fox, feral dogs, and coyote (Berry, 1985; Bureau, 1990). Facility infrastructure such as power poles could provide perching and nesting opportunities for ravens. Natural predation rates may be altered or increased when natural habitats are disturbed or modified. Common raven populations in some areas of the Mojave Desert have increased 1,500 percent from 1968 to 1988 in response to expanding human use of the desert (Boarman, 2002). Since ravens were scarce in the Mojave Desert prior to 1940, the current level of raven predation on juvenile desert tortoises is considered to be an unnatural occurrence (Bureau, 1990). In addition to ravens, feral dogs have emerged as significant predators of the tortoise. Dogs may range several miles into the desert and have been found digging up and killing desert tortoises (USFWS, 1994a; Evans, 2001). Dogs brought to the project site with visitors may harass, injure, or kill desert tortoises, particularly if allowed off leash to roam freely in occupied desert tortoise habitat. During construction, breaches in the desert tortoise exclusionary fencing may occur; thus allowing tortoises to pass through the barrier and be affected by project-related activities. If breaches occur, materials and equipment left behind following construction and maintenance activities may entrap or entangle tortoises, attract desert tortoise predators such as common ravens and coyotes, or provide shelter for tortoises, which when removed may result in displacement or injury of the tortoise. During operation, surface water flows could also undercut and compromise the exclusion of the tortoise fences and, therefore, allow short-term access to desert tortoise and their predators until such time as repairs are made.

5.4 Cumulative Effects Cumulative effects are of those future state and private activities, excluding federal activities that are reasonably foreseeable. Because the Bureau and NPS administer much of the land surrounding Ivanpah SEGS, nearly all of the actions that are reasonably expected to occur would be subject to the requirements of section 7 consultations. The California Energy Commission lists 12 existing projects and about 18 proposed projects for the Ivanpah Valley in California and Nevada. Those projects in direct proximity to the Ivanpah SEGS are the improvements to Interstate 15, which are under construction, the proposed Caltrans Joint Port of Entry, the proposed Southern California Edison upgrade of the existing 115 kV transmission line to a 220 kV double circuit line, and the proposed First Solar photovoltaic power plant on federal land adjacent to the Ivanpah SEGS project. All of these projects will undergo separate Section 7 consultations.

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If the First Solar site has the same density of desert tortoises as Ivanpah SEGS, they may also translocate them to the west of the Ivanpah units. That would add about 50 more desert tortoises (25 from each project) to the 14 sections of land (about 36 sq. kilometers) available to the west of Ivanpah SEGS. That averages 1.4 desert tortoises per sq.km. BrightSource found 23 desert tortoises on 4,060 acres (= 23 desert tortoises on 16.4 sq.km or 1.4/sq.km. The 1994 Desert Tortoise Recovery Plan estimated between 2 and 97 adult desert tortoises/sq.km in the Ivanpah Valley. Hence, the cumulative effect would increase the average density about 1.4 desert tortoises per sq.km. The resulting density in this part of the Ivanpah Valley would average 2.8 desert tortoises/sq.km. This is still much lower than the reported historical densities. The First Solar plans have not been submitted. Their Plan of Development has recently shifted its footprint to the south and west. Another potential translocation site for that project would be north of their development site. The Ivanpah SEGS site and associated linear features are located entirely on federal land under the Bureau’s jurisdiction, and are therefore subject to the provisions of the Bureau’s California Desert Conservation Area (CDCA) Plan (Revised 1999). Additionally, the Ivanpah SEGS project area, as well as much of the Ivanpah Valley, lies within the NEMO Planning Area Boundary. The NEMO Plan (July 2002) addresses threatened and endangered species conservation and recovery within the Ivanpah Valley through the proposed establishment of large, well-distributed DWMAs. However, while construction of the Ivanpah SEGS would contribute to the loss of desert tortoise habitat within the Ivanpah Valley, this land is located outside of critical habitat, and within an area that is designated Class L Limited Use and Class M Moderate Use according to the CDCA Map 1, Land-Use Plan 1999 (Bureau, 1999). Allowable uses for these land use designations include electrical generation facilities, and specifically solar electrical generation facilities. Other permitted land uses on Bureau-managed land include: utility transmission and distribution facilities, communication sites, grazing, mineral exploration and development, motorized vehicle access/transportation, and recreation.

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