Consideration of Spatial and Temporal Scale

It is important to consider not only the immediate, predicted impacts at the site itself, but also the impacts that will extend beyond the immediate site, the cumulative impacts of multiple facilities on the landscape, and impacts over time to the siting of one or more facilities.

1. Project Scale vs. Desert Scale
Currently, the right-of-way process is designed to analyze each application separately at the site specified. The EIS process conducts an assessment of impacts of the individual project on the ecosystem. The process cannot be used to determine the optimum placement of projects throughout the entire desert and it lacks full consideration of the spatial scale of likely impacts beyond the project boundary. The process does not take a holistic look at the desert biology and ecosystem across California, Nevada, and Arizona. It only takes a snapshot of each project area and cannot cross state boundaries. The Solar PEIS may address this issue, but at this time it is unclear how it will incorporate spatial and temporal impacts. BLM staff at the state and district office as well as a citizen’s group mentioned this as a weakness.

2. Lack of Cumulative Impact Analysis
Due to the large number of applications currently being processed by the BLM it is difficult, if not impossible, to address the concerns of cumulative impacts of multiple facilities across the desert landscape and over time. Each project is reviewed individually and the process does not consider the possibility of one project located in the same area as another potential project. As a BLM Staff Member stated, “When you're looking at an application, you can easily look at what's already gone on and do a cumulative impact analysis on that, but what's difficult is predicting the future.”¹ Tribes and environmental groups have voiced concerns over the BLM’s inability to address cumulative impacts due to the many solar applications submitted within a narrow time frame, with, each being assessed only for individual impacts. If development proposals occurred singly and over a longer period of time, the impacts of adding each new facility could be analyzed. The Solar PEIS may be looking at cumulative impacts inside the designated SESAs; however, this will not apply to previously proposed projects not in SESAs.

1 U.S. Bureau of Land Management Staff Member 3, Personal Communication, July 30, 2009.