Ivanpah Solar Electric Generating System Final Environmental Impact Statement APPENDIX A-1 IVANPAH SOLAR ELECTRIC GENERATING SYSTEM SUMMARY OF PUBLIC AND AGENCY COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS) AND AGENCY RESPONSES JULY 2010 July 2010 Ivanpah Solar Electric Generating System Final Environmental Impact Statement Key to Commentors Commentor ID # Affiliation Kevin Emmerich 1 Basin and Range Watch Ileene Anderson, Lisa T. Belenky 2 Center for Biological Diversity Sierra Club San Gorgonio Chapter and Sidney Silliman 3 Desert Committee Scott Cashen 4 Sierra Club Gloria Smith 5 Senior Attorney, Sierra Club Kathleen M. Goforth 6 Environmental Protection Agency, Region IX Kim Delfino, Joshua Basofin 7 Defenders of Wildlife California District, Western Watershed Michael J. Connor, Ph.D. 8 Project Acting Regional Defense Council, National Rory D. Westberg 9 Park Service Joanna H. Walk, Alice Bond, Natural Resource Defense Council, The Alex Daue 10 Wilderness Society Greg Suba 11 California Native Plant Society Glenn R. Stewart 12 Desert Tortoise Council Steve Knight 13 Assemblyman, 36th Assembly District Anthony Adams 14 Assemblyman, 59th Assembly District Ann Vanino 15 Moving Forward Deleted 16 Comments not associated with the DEIS Richard Sierra, Jr. 17 Hod Carriers Local 783 Mike Vandeman, Ph.D 18 Pacbell Violette Roberst 19 Mojave Environmental Education Consortium J. Stephan Dolezalek 20 Vantage Point Venture Partners Brendan Hughes 21 Nancy Schultz 22 Rocco Davis 23 LiUNA! Pacific Southwest Regional Office Robin Kent 24 Sue Wainscott 25 Desert Conservation Program Laura Cunningham 26 Desert Ecologist, Basin and Range Watch County of San Bernardino, Land Use Carrie Hyke 27 Services Department Cindy MacDonald 28 CRM Deleted 29 Comments not associated with DEIS David Lamfrom 30 National Parks Conservation Association John L. Carrier 31 CH2MHill Mia P. Ratcliff 32 Clark County Department of Aviation Tom Budlong 33 Chris Clarke 34 Private Citizen Mass Mailing 35 A.1-1 July 2010 Ivanpah Solar Electric Generating System Final Environmental Impact Statement Dennis Nowicki 36 Eileen Hennessy 37 Connie Conway 38 Assemblywoman, District 34 Glenn R. Stewart 39 The Desert Tortoise Council A.1-2 July 2010 Ivanpah Solar Electric Generating System Final Environmental Impact Statement INTRODUCTION The Draft Environmental Impact Statement (DEIS) for the Ivanpah Solar Electric Generating System (Ivanpah SEGS) project was published in November, 2009, and the public comment period expired on February 11, 2010. The following sections have organized the comments into categories, in order to facilitate technical review, development of responses, and, where needed, revision to the text in the Final EIS. 1.0 GENERAL COMMENTS 1.1 General Sufficiency of DEIS Comment ISEGS-6-1: On January 16, 2008, EPA provided extensive formal scoping comments for the ISEGS Project which included a variety of detailed recommendations regarding purpose and need, range of alternatives, and resource areas of concern. Based on our review of the ISEGS DEIS, we have rated the document as Environmental Concerns - Insufficient Information (EC-2). Please see the enclosed "Summary of EPA Rating Definitions." In the enclosed detailed comments, EPA provides specific recommendations regarding analyses and documentation to assist in assessing potential significant impacts from the proposed ISEGS Project. Specifically, EPA is concerned with the: 1) current justification for the Project purpose, need, and independent utility; 2) range of alternatives; 3) impacts to biological and aquatic resources; 4) impacts to air quality; 5) impacts to endangered species and other species of concern; and, 6) cumulative impacts from reasonably foreseeable future actions. Comment ISEGS-6-2: While EPA is pleased with certain aspects of this Project including the use of dry cooling, the close proximity to current highway infrastructure, and a 5% maximum energy production cap on natural gas, EPA recommends that the forthcoming Supplemental DElS (SDElS) provide additional analyses (including any necessary supporting documentation) and identify specific minimization or mitigation measures, as appropriate, regarding the issue areas below. (Specific recommendations are included in the following detailed comments.) • Project Purpose, Need, and Independent Utility • Range of Alternatives • Biological and Aquatic Resources • Air Quality (including impacts from construction) • Endangered Species and Other Species of Concern • Cumulative Impacts (from reasonably foreseeable future actions) Response: BLM has reviewed and evaluated all public comments received on the Draft EIS (DEIS), and also evaluated information received through the California Energy Commission (CEC) hearing process. The Supplemental Draft EIS (SDEIS), published on April 16, was specifically developed to address many of the comments, including those associated with the Purpose and Need, the range of alternatives, and Biological Resources/endangered species. Other specific comments on cumulative impacts and A.1-3 July 2010 Ivanpah Solar Electric Generating System Final Environmental Impact Statement air quality were evaluated, and are addressed through text modifications in their respective sections in the Final EIS (FEIS). 1.2 General Objection to Project Comment ISEGS-22-1: I oppose the Ivanpah Solar Electric Generating System, it is a plan that does not fit the desert for three main reasons, the impacts to the fragile natural resources are too great, the amount of water needed is too great and a mitigation plan is not in place to address translocation, water depletion, and loss of public space. Comment ISEGS-11-1a: CNPS supports the development of alternative, green energy sources, as long as those projects do not unnecessarily degrade healthy, diverse ecosystems. The proposed ISEGS project will cause significant, avoidable, adverse impacts to native vegetation communities and significant impacts to rare plant populations on the site, and within the surrounding Ivanpah Valley area. These impacts will have permanent (i.e., effects will persist for thousands of years) effects on ecosystem functions that have been evolving within the Ivanpah Valley for millennia. The area within the proposed project footprint will be affected directly, and the areas surrounding the project footprint will be affected indirectly during project construction and operational phases. Response: The comments opposing the proposed project are appreciated. These comments were considered in the selection of the preferred alternative in the FEIS, and will be considered in the decision whether or not to issue a right-of-way grant in the Record of Decision. 1.3 General Support for Project Comment ISEGS-15-1: As a resident of the High Desert region, I am writing to express my support for Bright Source energy's Ivanpah project. The project represents a significant economic development opportunity for the High Desert region and a major step towards achieving our state's and nation's clean energy and economic goals. Comment ISEGS-14-4: California and the nation need BrightSource's Ivanpah SEGS project, and others like it, to launch a stronger, more independent and competitive economy that once again proudly leads the world. I ask that BLM and CEC undertake everything in their power to promptly approve and support the development of the Ivanpah SEGS project. Comment ISEGS-14-1: I am writing in support of Bright Source Energy's Ivanpah Solar Energy Generating System (ISEGS) project, and urge the California Energy Commission (CEC) and the U.S. Bureau of Land Management (BLM) to promptly and successfully complete its permitting process. This utility-scale solar project will bring needed economic development and jobs to California's High Desert, including to my own district. By itself, the Ivanpah project is a great opportunity for our region; A.1-4 July 2010 Ivanpah Solar Electric Generating System Final Environmental Impact Statement importantly, it also represents the first major step in building the new solar industry that will greatly benefit our region. Comment ISEGS-13-4: California and the nation need BrightSource's Ivanpah SEGS project, and others like it, to launch a stronger, more independent and competitive economy that once again proudly leads the world. I ask that BLM and CEC promptly approve and support the development of the Ivanpah SEGS project. Comment ISEGS-13-1: Brightsource Energy's Ivanpah Solar Energy Generating System (ISEGS) project will bring needed economic development and jobs to California's High Desert, including my district. The project represents a tremendous opportunity for our region by itself, but is also an important first step in building the new solar industry that will greatly benefit our region. I support the Ivanpah SEGS project, and ask that the California Energy Commission (CEC) and the U.S. Bureau of Land Management (BLM) issue permits for its prompt development. Comment ISEGS-23-2: We understand the environmental challenges that a project such as Ivanpah presents, particularly given its large footprint, but those are challenges that are being thoroughly and deliberately worked out. BrightSource has adopted environmentally friendly strategies such as dry cooling to minimize water usage, and a low impact design to minimize impacts to the desert topography and plants. No short cuts are being taken with a project as important as this! We are confident that BrightSource is taking environmental responsibility very seriously