DES 10-47 N- 86292

DOI-BLM-NVB020-2009-0104-EIS

Draft 

Environmental Impact Statement

Battle Mountain District Office

Battle Mountain Nevada

Tonopah Field Office

Tonopah, Nevada

United States Department of the Interior

Bureau of Land Management

Tonopah Solar Energy, LLC

Crescent Dunes Solar Energy Project

September 3, 2010
BLM Mission Statement

It is the mission of the Bureau of Land Management to sustain the health, diversity, and productivity of 

the public lands for the use and enjoyment of present and future generations. 

BLM/NV/BM/EIS/10/30+1793

DOI No. DES 10-47
p

g

In Reply Refer To:

N-86292

DOI-BLM-NVBO2O-2009-0 1 04-EIS2800 (NVBO200)

Dear Reader:Enclosed for your review and comment is the Tonopah Solar Energy, LLC, Crescent Dunes Solar Energy

Project Draft Environmental Impact Statement (DEIS), prepared by the Bureau of Land Management

(BLM), Tonopah Field Office. The DEIS analyzes the direct, indirect, and cumulative impacts associated

with the proposed construction and operation of the Crescent Dunes Solar Energy Project.

The public comment period begins September 3, 2010. Before including your address, phone number,

e-mail address, or other personal identifying information in your comment, you should be aware that your

entire comment, including your personal identifying information, may be made publicly available at any

time. While you can ask us in your comment to withhold your personal identifying information from

public review, we cannot guarantee that we will be able to. In addition, information will be posted online

at the BLM website: http://www.blm.gov/nv/st/en.html.

Comments on the DEIS can be mailed to the above address, Attn: Tim Coward, Renewable Energy

Project Manager, faxed to (775) 482-7810, or c-mailed to crescent dunes@blm.gov.

Comments should be postmarked or otherwise delivered to the Tonopah Field Office by close of business,

October 18, 2010 to ensure full consideration. Comments may also be submitted at public meetings to be

held:

• September 22, 2010 (6 pm 8pm), Southern Nevada District Office, 4701 N. Torrey Pines

Drive, Las Vegas, NV

• September 23, 2010 (6 pm 8 pm), Tonopah Convention Center, 301 Brougher Ave.,

Tonopah, NV

A Final Environmental Impact Statement (FEIS) will be prepared that will consider the commentsreceived during the public review and comment period. If you would like any additional information,

please contact Tim Coward, Renewable Energy Project Manager, at (775) 482-7800.

Sincerely,

Thomas J. Seley

Field Manager
DRAFT

ENVIRONMENTAL IMPACT STATEMENT

TONOPAH SOLAR ENERGY, LLC 

CRESCENT DUNES SOLAR ENERGY PROJECT

Lead Agency: U. S. Department of the Interior

Bureau of Land Management

Battle Mountain District Office

Cooperating Agencies: Department of Defense, Department of Energy,

Nevada Department of Wildlife, Esmeralda 

County, Nye County, Town of Tonopah

Project Location: Nye County, Nevada

Correspondence on This EIS Tim Coward, Renewable Energy Project Manager

Should be Directed to: Bureau of Land Management 

P.O. Box 911 

Tonopah, NV 89049

(775) 482-7800

ABSTRACT

Tonopah Solar Energy, LLC applied to the BLM for a 7,680-acre right-of-way (ROW) on public lands to 

construct a concentrated solar thermal power plant facility approximately 13 miles northwest of 

Tonopah, Nye County, Nevada. The proposed project is not expected to use the total acres applied for 

in the ROW application. The facility is expected to operate for approximately 30 years. The proposed 

solar power project would use concentrated solar power technology, using heliostats or mirrors to focus 

sunlight on a receiver erected in the center of the solar field (the power tower or central receiver). A 

heat transfer fluid is heated as it passes through the receiver and is then circulated through a series of 

heat exchangers to generate high-pressure steam. The steam is used to power a conventional Rankine 

cycle steam turbine, which produces electricity. The exhaust steam from the turbine is condensed and 

returned via feedwater pumps to the heat exchangers where steam is regenerated. Hybrid cooling 

processes would be used for this project to minimize water use while continuing to maintain efficient 

power generation. The plant design would generate a nominal capacity of 110 megawatts.

The project’s proposed facility design includes the heliostat fields, a 653-foot central receiver tower, a 

power block, buildings, a parking area, a laydown area, evaporating ponds, and an access road. A single 

overhead 230-kilovolt transmission line would connect the plant to the nearby Anaconda Moly 

substation. 

This Draft Environmental Impact Statement analyzes the environmental effects of the Proposed Action, 

two action alternatives, and the No Action Alternative.

Responsible Official for EIS: Thomas J. Seley

Field Manager

Tonopah Field Office 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| i 

Contents

Acronyms, Abbreviations, and Glossary .....................................................................................................xiv

Executive Summary......................................................................................................................................xx

1.0 Introduction and Purpose and Need.............................................................................................. 1-1

1.1 Authority and Jurisdiction.......................................................................................................... 1-1

1.1.1 DOE Authority and Jurisdiction.............................................................................................. 1-2

1.2 Project Overview........................................................................................................................ 1-2

1.3 Project Location ......................................................................................................................... 1-3

1.4 Purpose and Need for the Proposed Project............................................................................. 1-6

1.4.1 Purpose .................................................................................................................................. 1-6

1.4.2 Need....................................................................................................................................... 1-6

1.4.3 DOE Purpose and Need.......................................................................................................... 1-6

1.4.4 Proponent Purpose and Need................................................................................................ 1-6

1.5 Relationship to Bureau of Land Management and Non-Bureau of Land Management Policies, 

Plans, and Programs............................................................................................................................... 1-7

1.6 Authorizing Actions and Permits.............................................................................................. 1-10

1.7 Agency Coordination................................................................................................................ 1-12

1.7.1 Agency Communication ....................................................................................................... 1-12

1.7.2 Cooperating Agencies.......................................................................................................... 1-13

1.8 Summary of Public Scoping and Issue Identification............................................................... 1-14

1.8.1 Federal Register ................................................................................................................... 1-14

1.8.2 Announcements, and Media Releases................................................................................. 1-14

1.8.3 Public Meetings.................................................................................................................... 1-15

1.8.4 Summary of Public and Agency Comments......................................................................... 1-16

1.9 Organization of the Environmental Impact Statement............................................................ 1-21

2.0 Alternatives Including the Proposed Action .................................................................................. 2-1

2.1 Introduction ............................................................................................................................... 2-1

2.2 Project Background.................................................................................................................... 2-1

2.3 Regulatory Framework of Alternatives...................................................................................... 2-5

2.4 Existing Facilities........................................................................................................................ 2-5

2.5 Proposed Action......................................................................................................................... 2-5
Proposed Crescent Dunes Solar Energy Project: Draft EIS| ii

2.5.1 Project Overview.................................................................................................................... 2-5

2.5.2 Project Component Summary................................................................................................ 2-7

2.5.3 Project Component Additional Detail.................................................................................. 2-22

2.5.4 Construction Activities......................................................................................................... 2-33

2.5.5 Operations and Maintenance .............................................................................................. 2-36

2.5.6 Water Demand and Sources................................................................................................ 2-37

2.5.7 Land Ownership and Mining Claims..................................................................................... 2-40

2.5.8 Hazardous Materials Management...................................................................................... 2-40

2.5.9 Security, Fire Protection and Intentional Destructive Acts.................................................. 2-45

2.5.10 Applicant-Committed Environmental Protection Measures ........................................... 2-47

2.5.11 Decommissioning and Reclamation................................................................................. 2-56

2.6 Alternatives to the Proposed Action........................................................................................ 2-58

2.6.1 Alternatives Considered in Detail (Including No Action) ..................................................... 2-58

2.6.2 Alternatives Considered but Eliminated from Detailed Analysis......................................... 2-62

2.7 Comparative Analysis of Alternatives...................................................................................... 2-65

2.8 BLM-Preferred Alternative........................................................................................................2-71

3.0 Affected Environment.................................................................................................................... 3-1

3.1 Introduction ............................................................................................................................... 3-1

3.2 Vegetation.................................................................................................................................. 3-6

3.2.1 Area of Analysis and Methodology ........................................................................................ 3-6

3.2.2 Regulatory Framework........................................................................................................... 3-6

3.2.3 Affected Environment............................................................................................................ 3-7

3.3 Wildlife Resources.................................................................................................................... 3-20

3.3.1 Area of Analysis and Methodology ...................................................................................... 3-20

3.3.2 Regulatory Framework.........................................................................................................3-20

3.3.3 Affected Environment.......................................................................................................... 3-20

3.4 Special Status Species (Plants and Wildlife)............................................................................. 3-22

3.4.1 Special Status Plant Species................................................................................................. 3-22

3.4.2 Special Status Wildlife Species............................................................................................. 3-27

3.5 Water Quality and Quantity..................................................................................................... 3-37

3.5.1 Area of Analysis and Methodology ...................................................................................... 3-37

3.5.2 Regulatory Framework......................................................................................................... 3-37
Proposed Crescent Dunes Solar Energy Project: Draft EIS| iii

3.5.3 Affected Environment.......................................................................................................... 3-37

3.6 Air Quality ................................................................................................................................ 3-45

3.6.1 Area of Analysis.................................................................................................................... 3-45

3.6.2 Regulatory Framework......................................................................................................... 3-45

3.6.3 Climate Change .................................................................................................................... 3-48

3.6.4 Affected Environment.......................................................................................................... 3-49

3.7 Cultural Resources................................................................................................................... 3-52

3.7.1 Area of Analysis and Methodology ...................................................................................... 3-52

3.7.2 Definition of the Resource ................................................................................................... 3-53

3.7.3 Regulatory Framework......................................................................................................... 3-53

3.7.4 Affected Environment.......................................................................................................... 3-55

3.8 Native American Religious Concerns....................................................................................... 3-58

3.8.1 Area of Analysis and Methodology ...................................................................................... 3-58

3.8.2 Definition of the Resource ................................................................................................... 3-58

3.8.3 Regulatory Framework......................................................................................................... 3-58

3.8.4 Affected Environment.......................................................................................................... 3-59

3.9 Land Use and Access................................................................................................................ 3-60

3.9.1 Area of Analysis and Methodology ...................................................................................... 3-60

3.9.2 Regulatory Framework......................................................................................................... 3-61

3.9.3 Affected Environment.......................................................................................................... 3-63

3.10 Soils.......................................................................................................................................... 3-68

3.10.1 Area of Analysis and Methodology .................................................................................. 3-68

3.10.2 Regulatory Framework..................................................................................................... 3-68

3.10.3 Affected Environment...................................................................................................... 3-69

3.11 Social and Economics............................................................................................................... 3-79

3.11.1 Area of Analysis and Methodology .................................................................................. 3-79

3.11.2 Regulatory Framework..................................................................................................... 3-79

3.11.3 Affected Environment...................................................................................................... 3-79

3.12 Visual........................................................................................................................................ 3-89

3.12.1 Area of Analysis and Methodology .................................................................................. 3-89

3.12.2 Regulatory Framework..................................................................................................... 3-90

3.12.3 Affected Environment...................................................................................................... 3-91
Proposed Crescent Dunes Solar Energy Project: Draft EIS| iv

3.13 Hazardous Materials.............................................................................................................. 3-100

3.13.1 Area of Analysis and Methodology ................................................................................ 3-100

3.13.2 Regulatory Framework................................................................................................... 3-100

3.13.3 Affected Environment.................................................................................................... 3-100

3.13.4 CESA ............................................................................................................................... 3-102

3.14 Range Resources.................................................................................................................... 3-102

3.14.1 Area of Analysis and Methodology ................................................................................ 3-102

3.14.2 Regulatory Framework................................................................................................... 3-103

3.14.3 Affected Environment.................................................................................................... 3-103

3.15 Recreation and Wilderness.................................................................................................... 3-105

3.15.1 Area of Analysis and Methodology ................................................................................ 3-105

3.15.2 Regulatory Framework................................................................................................... 3-108

3.15.3 Affected Environment.................................................................................................... 3-108

4.0 Environmental Consequences ....................................................................................................... 4-1

4.1 Vegetation.................................................................................................................................. 4-2

4.1.1 Methods................................................................................................................................. 4-2

4.1.2 Proposed Action..................................................................................................................... 4-2

4.1.3 Alternative 1........................................................................................................................... 4-5

4.1.4 Alternative 2........................................................................................................................... 4-7

4.1.5 Borrow Pit .............................................................................................................................. 4-8

4.1.6 TL and Anaconda-Moly Substation ........................................................................................ 4-9

4.1.7 No Action Alternative........................................................................................................... 4-10

4.1.8 Summary of Impacts............................................................................................................ 4-10

4.1.9 Mitigation............................................................................................................................. 4-10

4.2 Wildlife..................................................................................................................................... 4-11

4.2.1 Methods............................................................................................................................... 4-11

4.2.2 Proposed Action................................................................................................................... 4-11

4.2.3 Alternative 1......................................................................................................................... 4-12

4.2.4 Alternative 2......................................................................................................................... 4-13

4.2.5 Borrow Pit ............................................................................................................................ 4-13

4.2.6 TL and Anaconda-Moly Substation Corridor........................................................................ 4-14

4.2.7 No Action Alternative........................................................................................................... 4-14
Proposed Crescent Dunes Solar Energy Project: Draft EIS| v 

4.2.8 Summary of Impacts............................................................................................................ 4-14

4.2.9 Mitigation............................................................................................................................. 4-15

4.3 Special Status Plant Species..................................................................................................... 4-15

4.3.1 Methods............................................................................................................................... 4-15

4.3.2 Proposed Action Alternative................................................................................................ 4-15

4.3.3 Alternative 1......................................................................................................................... 4-17

4.3.4 Alternative 2......................................................................................................................... 4-18

4.3.5 Borrow Pit ............................................................................................................................ 4-18

4.3.6 TL and Anaconda-Moly Substation Corridor........................................................................ 4-19

4.3.7 No Action Alternative........................................................................................................... 4-19

4.3.8 Summary of Impacts............................................................................................................ 4-19

4.3.9 Mitigation............................................................................................................................. 4-20

4.4 Special Status Wildlife Species................................................................................................. 4-20

4.4.1 Methods............................................................................................................................... 4-20

4.4.2 Proposed Action................................................................................................................... 4-20

4.4.3 Alternative 1......................................................................................................................... 4-24

4.4.4 Alternative 2......................................................................................................................... 4-27

4.4.5 Borrow Pit ............................................................................................................................ 4-29

4.4.6 TL and Anaconda-Moly Substation Corridor........................................................................ 4-30

4.4.7 No Action Alternative........................................................................................................... 4-32

4.4.8 Summary of Impacts............................................................................................................ 4-32

4.4.9 Mitigation............................................................................................................................. 4-33

4.5 Water Quality and Quantity..................................................................................................... 4-33

4.5.1 Methods............................................................................................................................... 4-33

4.5.2 Proposed Action................................................................................................................... 4-35

4.5.3 Alternative 1......................................................................................................................... 4-43

4.5.4 Alternative 2......................................................................................................................... 4-46

4.5.5 TL and Anaconda-Moly Substation Corridor........................................................................ 4-48

4.5.6 Borrow Pit ............................................................................................................................ 4-49

4.5.7 Point of Diversion................................................................................................................. 4-50

4.5.8 PWR 107............................................................................................................................... 4-50

4.5.9 No Action Alternative........................................................................................................... 4-51
Proposed Crescent Dunes Solar Energy Project: Draft EIS| vi

4.5.10 Summary of Impacts........................................................................................................ 4-51

4.5.11 Mitigation......................................................................................................................... 4-52

4.6 Air Quality ................................................................................................................................ 4-54

4.6.1 Methodology........................................................................................................................ 4-54

4.6.2 Proposed Project Emission Estimates.................................................................................. 4-55

4.6.3 Air Quality Conformity Assessment..................................................................................... 4-61

4.6.4 Alternatives and Cumulative Effects Analysis...................................................................... 4-64

4.6.5 Summary of Impact Analysis................................................................................................ 4-64

4.7 Cultural Resources................................................................................................................... 4-65

4.7.1 Methods............................................................................................................................... 4-65

4.7.2 Proposed Action................................................................................................................... 4-65

4.7.3 Alternative 1......................................................................................................................... 4-66

4.7.4 Alternative 2......................................................................................................................... 4-66

4.7.5 TL and Anaconda-Moly Substation Corridor........................................................................ 4-67

4.7.6 Borrow Pit ............................................................................................................................ 4-67

4.7.7 No Action Alternative........................................................................................................... 4-67

4.7.8 Summary of Impacts............................................................................................................ 4-68

4.7.9 Mitigation............................................................................................................................. 4-68

4.8 Native American Religious Concerns....................................................................................... 4-68

4.8.1 Methods............................................................................................................................... 4-69

4.8.2 No Action Alternative........................................................................................................... 4-69

4.8.3 Summary of Impacts............................................................................................................ 4-69

4.9 Land Use and Access................................................................................................................ 4-69

4.9.1 Methods............................................................................................................................... 4-69

4.9.2 Proposed Action................................................................................................................... 4-70

4.9.3 Alternative 1......................................................................................................................... 4-71

4.9.4 Alternative 2......................................................................................................................... 4-73

4.9.5 TL and Anaconda-Moly Substation Corridor........................................................................ 4-74

4.9.6 Borrow Pit ............................................................................................................................ 4-75

4.9.7 No Action Alternative........................................................................................................... 4-76

4.9.8 Summary of Impacts............................................................................................................ 4-76

4.9.9 Mitigation............................................................................................................................. 4-76
Proposed Crescent Dunes Solar Energy Project: Draft EIS| vii

4.10 Soils.......................................................................................................................................... 4-76

4.10.1 Methods........................................................................................................................... 4-76

4.10.2 Proposed Action............................................................................................................... 4-78

4.10.3 Alternative 1..................................................................................................................... 4-79

4.10.4 Alternative 2..................................................................................................................... 4-79

4.10.5 TL and Anaconda-Moly Substation Corridor.................................................................... 4-80

4.10.6 Borrow Pit ........................................................................................................................ 4-80

4.10.7 No Action Alternative....................................................................................................... 4-81

4.10.8 Summary of Impacts........................................................................................................ 4-81

4.10.9 Mitigation......................................................................................................................... 4-81

4.11 Social and Economics............................................................................................................... 4-83

4.11.1 Methods........................................................................................................................... 4-83

4.11.2 Proposed Action............................................................................................................... 4-83

4.11.3 No Action Alternative....................................................................................................... 4-86

4.11.4 Summary of Impacts........................................................................................................ 4-87

4.11.5 Mitigation......................................................................................................................... 4-87

4.12 Visual Resources ...................................................................................................................... 4-87

4.12.1 Methods........................................................................................................................... 4-87

4.12.2 Proposed Action............................................................................................................... 4-91

4.12.3 Alternative 1..................................................................................................................... 4-97

4.12.4 Alternative 2................................................................................................................... 4-100

4.12.5 TL and Anaconda-Moly Substation Corridor.................................................................. 4-103

4.12.6 Borrow Pit ...................................................................................................................... 4-105

4.12.7 No Action Alternative..................................................................................................... 4-105

4.12.8 Summary of Effects........................................................................................................ 4-105

4.12.9 Mitigation....................................................................................................................... 4-106

4.13 Hazardous Materials.............................................................................................................. 4-107

4.13.1 Methods......................................................................................................................... 4-107

4.13.2 Proposed Action............................................................................................................. 4-107

4.13.3 Alternative 1................................................................................................................... 4-111

4.13.4 Alternative 2................................................................................................................... 4-111

4.13.5 TL and Anaconda-Moly Substation Corridor.................................................................. 4-111
Proposed Crescent Dunes Solar Energy Project: Draft EIS| viii

4.13.6 Borrow Pit ...................................................................................................................... 4-112

4.13.7 No Action Alternative..................................................................................................... 4-112

4.13.8 Summary of Impacts...................................................................................................... 4-112

4.13.9 Mitigation....................................................................................................................... 4-112

4.14 Range Resources.................................................................................................................... 4-115

4.14.1 Methods......................................................................................................................... 4-115

4.14.2 Proposed Action............................................................................................................. 4-115

4.14.3 Alternative 1................................................................................................................... 4-117

4.14.4 Alternative 2................................................................................................................... 4-117

4.14.5 TL and Anaconda-Moly Substation Corridor.................................................................. 4-118

4.14.6 Borrow Pit ...................................................................................................................... 4-119

4.14.7 No Action Alternative..................................................................................................... 4-119

4.14.8 Summary of Impacts...................................................................................................... 4-119

4.14.9 Mitigation....................................................................................................................... 4-120

4.15 Recreation and Wilderness.................................................................................................... 4-120

4.15.1 Methods......................................................................................................................... 4-120

4.15.2 Proposed Action............................................................................................................. 4-121

4.15.3 Alternative 1................................................................................................................... 4-122

4.15.4 Alternative 2................................................................................................................... 4-124

4.15.5 TL and Anaconda-Moly Substation Corridor.................................................................. 4-125

4.15.6 Borrow Pit ...................................................................................................................... 4-125

4.15.7 No Action Alternative..................................................................................................... 4-126

4.15.8 Summary of Impacts...................................................................................................... 4-126

4.16 Unavoidable Adverse Environmental Impacts....................................................................... 4-126

4.17 Irreversible and Irretrievable Commitment of Resources..................................................... 4-127

4.18 Relationship between Short-Term Uses and Long-Term Productivity of the Environment.. 4-129

4.18.1 Short-Term Uses ............................................................................................................ 4-129

4.18.2 Long-Term Productivity of the Environment ................................................................. 4-129

4.19 Cumulative Impacts ............................................................................................................... 4-129

4.19.1 Actions Considered for Cumulative Analysis ................................................................. 4-129

4.19.2 Regulations and Guidance ............................................................................................. 4-130

4.19.3 Methodology for Assessing Cumulative Impacts........................................................... 4-130
Proposed Crescent Dunes Solar Energy Project: Draft EIS| ix

4.19.4 Past and Present Actions ............................................................................................... 4-131

4.19.5 Reasonable Foreseeable Future Actions........................................................................ 4-131

4.19.6 Cumulative Impacts, by Resource.................................................................................. 4-133

5.0 Consultation and Coordination...................................................................................................... 5-1

5.1 Public Involvement Process....................................................................................................... 5-1

5.1.1 Scoping................................................................................................................................... 5-1

5.1.2 Final Environmental Impact Statement................................................................................. 5-2

5.2 Formal Consultation with Interested Agencies and Tribal Government................................... 5-2

5.3 List of Agencies, Organizations, and Persons to Whom Copies of the Environmental Impact 

Statement Were Sent ............................................................................................................................ 5-2

5.3.1 Federal Government.............................................................................................................. 5-2

5.3.2 State Government.................................................................................................................. 5-3

5.3.3 Local Government.................................................................................................................. 5-3

5.3.4 Tribal Government................................................................................................................. 5-3

5.3.5 Other Organizations............................................................................................................... 5-3

5.3.6 Elected Government Officials ................................................................................................ 5-4

5.3.7 Availability.............................................................................................................................. 5-4

6.0 List of Preparers and Reviewers..................................................................................................... 6-1

7.0 References ..................................................................................................................................... 7-1

8.0 Glossary .......................................................................................................................................... 8-1

Figures

Figure 1-1. Solar map ................................................................................................................................ 1-4

Figure 1-2. Site vicinity map...................................................................................................................... 1-5

Figure 2-1. Alternative locations............................................................................................................... 2-2

Figure 2-2. Test well location.................................................................................................................... 2-3

Figure 2-3. Conceptual process diagram................................................................................................... 2-6

Figure 2-4. Diagram of tower.................................................................................................................... 2-8

Figure 2-5. Heliostat.................................................................................................................................. 2-9

Figure 2-6. Power block layout ............................................................................................................... 2-10

Figure 2-7. Transmission route ............................................................................................................... 2-13

Figure 2-8. Substation layout.................................................................................................................. 2-14

Figure 2-9. Pole elevation ....................................................................................................................... 2-15

Figure 2-10. Transmission line profile..................................................................................................... 2-16

Figure 2-11. Road sections...................................................................................................................... 2-17
Proposed Crescent Dunes Solar Energy Project: Draft EIS| x 

Figure 2-12. Construction lay down areas.............................................................................................. 2-18

Figure 2-13. Preliminary grading and drainage design ........................................................................... 2-19

Figure 2-14. Power block grading and drainage ..................................................................................... 2-20

Figure 2-15. Big Smoky Valley groundwater basin (with Tonopah Flat subarea)................................... 2-39

Figure 2-16. Proposed septic systems..................................................................................................... 2-44

Figure 2-17. Alternative sites considered but not evaluated further..................................................... 2-64

Figure 3-1. Proposed Area and Alternative Area ...................................................................................... 3-5

Figure 3-2. Vegetation and land cover types within the Proposed and Alternative Areas..................... 3-12

Figure 3-3. Vegetation and land cover types within the borrow pit and the TL and Anaconda Moly 

Substation corridor.................................................................................................................................. 3-16

Figure 3-4. Vegetation associations and land cover types within the CESA........................................... 3-18

Figure 3-5. Nevada oryctes habitat within the proposed and alternative areas.................................... 3-24

Figure 3-6. Nevada oryctes habitat within the CESA .............................................................................. 3-26

Figure 3-7. Pale kangaroo mouse habitat in the detailed study area...................................................... 3-32

Alternative Area....................................................................................................................................... 3-34

Figure 3-8. Pale kangaroo mouse habitat throughout the CESA ............................................................. 3-35

Figure 3-9. Potential golden eagle habitat throughout the CESA........................................................... 3-36

Figure 3-10. Surface Water Resources.................................................................................................... 3-38

Figure 3-11. Generalized depth to groundwater (Source: WorleyParsons 2010) .................................. 3-40

Figure 3-12. Well locations (Source: WorleyParsons 2010).................................................................... 3-42

Figure 3-13. Land use area of analysis and CESA.................................................................................... 3-62

Figure 3-14. Land use area and ownership status.................................................................................. 3-66

Figure 3-15. Soils within the Proposed Area........................................................................................... 3-72

Figure 3-16. Soils within the Alternative Area ........................................................................................3-74

Figure 3-17. Soils within the borrow pit area ......................................................................................... 3-76

Figure 3-18. Soils within the TL and Anaconda Moly Substation corridor.............................................. 3-78

Figure 3-19. KOPs used in the analysis of potential impacts to visual resources.................................... 3-92

Figure 3-20. Grazing allotments within the Big Smoky Valley .............................................................. 3-104

Figure 3-21. Recreation management areas within the project area................................................... 3-106

Figure 3-22. Recreation management area within the CESA................................................................ 3-107

Figure 4-1. Vegetation and land cover types within the alternatives....................................................... 4-3

Figure 4-2. Nevada oryctes habitat affected by the Proposed Action, Alternative 1, and Alternative 24-16

Figure 4-3. Project components and pale kangaroo mouse habitat....................................................... 4-21

Figure 4-4. The 1-foot drawdown contour for construction activities................................................... 4-36

Figure 4-5. The 1-foot drawdown contour for the 53-year scenario for the Proposed Action .............. 4-42

Figure 4-6. The 1-foot drawdown contour for the 53-year scenario for Alternative 1 .......................... 4-45

Figure 4-7. The 1-foot drawdown contour for the 53-year scenario for Alternative 2 .......................... 4-47

Figure 4-8. SRMA (rights-of-way avoidance area) and Alternatives..................................................... 4-123
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xi

Tables

Table 1-1. Federal, state, and local laws, statutes, and EOs applicable to the Proposed Project and 

Alternatives................................................................................................................................................ 1-9

Table 1-2. Potential authorizations and permits .................................................................................... 1-10

Table 1-3. Publications for the proposed Crescent Dunes Solar Energy Project.................................... 1-15

Table 1-4. Public meeting information ................................................................................................... 1-15

Table 1-5. Summary of public and agency comments received ............................................................. 1-16

Table 1-6. Description of EIS chapters.................................................................................................... 1-21

Table 2-1. Conceptual project schedule, with activities representative of typical TSE projects............ 2-35

Table 2-2. Conceptual construction process........................................................................................... 2-36

Table 2-3. Hazardous waste laws, ordinances, and regulations............................................................. 2-41

Table 2-4. Potential Project Hazardous Materials ................................................................................. 2-43

Table 2-5. Comparative analysis of alternatives considered in detail ....................................................2- 66

Table 3-1. CESAs........................................................................................................................................ 3-2

Table 3-2. Supplemental authorities/elements that must be addressed................................................. 3-3

Table 3-3. Other resources considered for analysis in the EIS.................................................................. 3-4

Table 3-4. Approximate area of each vegetation community and land cover type within the Proposed 

Area.......................................................................................................................................................... 3-13

Table 3-5. MLRA ecological areas and project plant cover estimates within the Proposed Area.......... 3-13

Table 3-6. Approximate area of each vegetation community and land cover type within the Alternative 

Area.......................................................................................................................................................... 3-14

Table 3-7. MLRA ecological areas and project plant cover estimates within the Alternative Area ....... 3-14

Table 3-8. Approximate area of each vegetation community and land cover type within the borrow pit...

................................................................................................................................................................. 3-15

Table 3-9. MLRA ecological areas and project plant cover estimates within the borrow pit................. 3-15

Table 3-10. Approximate area of each vegetation community and land cover type within the TL and 

Anaconda Moly Substation corridor........................................................................................................ 3-17

Table 3-11. MLRA ecological areas and project plant cover estimates within the TL and Anaconda Moly 

Substation corridor.................................................................................................................................. 3-17

Table 3-12. Summary of area of each vegetation community or land cover type and their proportion 

within the CESA........................................................................................................................................ 3-19

Table 3-13. Special status mammal species potentially found in the project area ................................ 3-30

Table 3-14. Birds considered special status species observed in or that may occur in the project area3-33

Reptiles .................................................................................................................................................... 3-33

Table 3-15. Current groundwater consumption in the Tonopah Flat subarea....................................... 3-39

Table 3-16. Summary of wells within the project CESA.......................................................................... 3-41

Table 3-17. National Ambient Air Quality Standards.............................................................................. 3-46

Table 3-18. Climate data for Tonopah Airport, Nevada (1971–2000).................................................... 3-50

Table 3-19. 2008 air quality monitoring data ......................................................................................... 3-51

Table 3-20. Summary of cultural resource site types, by area ............................................................... 3-57

Table 3-21. Authorized and pending BLM ROWs within the Proposed Area, Borrow Pit, and TL Corridor ..

................................................................................................................................................................. 3-64
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xii

Table 3-22. Authorized and pending BLM ROWS within the Alternative Area....................................... 3-64

Table 3-23. Authorized and pending BLM ROWs and mining claims within the borrow pit area .......... 3-65

Table 3-24. NRCS soil types and evaluation criteria for the Proposed Area........................................... 3-71

Table 3-25. NRCS soil types and evaluation criteria for the Alternative Area ........................................ 3-73

Table 3-26. NRCS soil types and evaluation criteria for the borrow pit ................................................. 3-75

Table 3-27. NRCS soil types and evaluation criteria for the TL and Anaconda Moly Substation corridor.....

................................................................................................................................................................. 3-77

Table 3-28. Population estimates for Nye and Esmeralda counties and Nevada, 2000–2009............... 3-80

Table 3-29. Population estimates for Nye and Esmeralda counties and Nevada, 2008–2009............... 3-80

Table 3-30. Population projections for Nye and Esmeralda counties and Nevada ................................ 3-81

Table 3-31. Federal agencies managing lands in Nye County................................................................. 3-81

Table 3-32. Housing characteristics........................................................................................................ 3-82

Table 3-33. Housing conditions and costs............................................................................................... 3-83

Table 3-34. Labor force characteristics of Esmeralda and Nye counties and Nevada, 1990–2010........ 3-84

Table 3-35. Employment by industry for Nye and Esmeralda counties and Nevada, 2007.................... 3-85

Table 3-36. Largest employers in Nye County ........................................................................................ 3-86

Table 3-37. Largest employers in Esmeralda County.............................................................................. 3-86

Table 3-38. Summary of schools in the Nye County School District....................................................... 3-87

Table 3-39. Nye County revenues, 2008–2009....................................................................................... 3-88

Table 3-40. Nye County expenditures for fiscal year 2008–2009........................................................... 3-89

Table 3-43. Summary of applicable regulations for the use, storage, and disposal of hazardous materials

............................................................................................................................................................... 3-101

Table 3-44. Summary of regulations applicable to hazardous and non-hazardous wastes................. 3-102

Table 4-1. Estimated area (in acres) for each project component used in the assessment of impacts... 4-1

Table 4-2. Summary of effects to vegetation communities or land cover types for the Proposed Action in 

the project footprint and the CESA............................................................................................................ 4-4

Table 4-3. BLM Noxious Weed Risk Assessment Factors and Rating Risk Assessment Factors worksheet 

(BLM 1992)................................................................................................................................................. 4-4

Table 4-4. Summary of effects to vegetation communities or land cover type for Alternative 1 in the 

project footprint and the CESA.................................................................................................................. 4-6

Table 4-5. Summary of effects to vegetation communities or land cover type for Alternative 2 in the 

project footprint and the CESA.................................................................................................................. 4-7

Table 4-6. Summary of effects to vegetation communities or land cover type for the borrow pit ......... 4-8

Table 4-7. Predicted chemical makeup of the pond sludge.................................................................... 4-40

Table 4-8. Estimated drawdown on existing wells within the CESA....................................................... 4-52

Table 4-9. Maximum annual criteria pollutant emission estimates from construction activities.......... 4-56

Table 4-10. Nonrecurring greenhouse gas emissions estimates for construction activities.................. 4-57

Table 4-11. Nonrecurring criteria pollutant emission estimates for salt system commissioning activities..

................................................................................................................................................................. 4-58

Table 4-12. Nonrecurring greenhouse gas emission estimates for salt commissioning activities......... 4-58

Table 4-13. Annual criteria pollutant emissions from on-site stationary sources during the operation 

phase........................................................................................................................................................ 4-60
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xiii

Table 4-14. Annual criteria pollutant emissions from worker commute, heliostat washing, and deliveries 

during operation ...................................................................................................................................... 4-60

Table 4-15. Annual greenhouse gas emissions from on-site stationary sources.................................... 4-61

Table 4-16. Annual greenhouse gas emissions from worker commute, heliostat washing, and deliveries 

during operation ...................................................................................................................................... 4-61

Table 4-17. Air quality conformity determination for project construction phase ................................ 4-62

Table 4-18. Air quality conformity determination for project operation phase..................................... 4-63

Table 4-18. County and State Construction Industry Workforce............................................................ 4-83

Table 4-19. Communities, Population, and Travel Distance from Project Site....................................... 4-84

Table 4-20. Sensitivity Ratings for Viewer Types.................................................................................... 4-88

Table 4-21. Impact Levels Defined.......................................................................................................... 4-90

Table 4-22. Distance Zones (BLM 1986a)................................................................................................. 4-91

Table 4-23. Visual Effects Summary for KOPs for each proposed Build Alternative............................. 4-106

Table 4-24. Hazardous materials that will be used during project operation. ..................................... 4-109

Table 4-25. Grazing Acreage and AUM Reductions due to Project Components and Alternatives...... 4-120

Table 4-26. Irreversible and Irretrievable Commitment of Resources by the Proposed Action .......... 4-128

Table 4-27. Reasonable and Foreseeable Future Projects.................................................................... 4-133

Table 5-1. Public meeting information ...................................................................................................... 5-1

Table 6-1. List of BLM Reviewers. ............................................................................................................. 6-1

Table 6-2. Environmental Impact Statement Contractor and Subcontractors......................................... 6-3

Table 6-3. Technical Studies and Design Contractor(s)............................................................................. 6-4

Table 6-4. Project Proponent(s)................................................................................................................ 6-4
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xiv

1 Acronyms, Abbreviations, and Glossary

AC alternating current

ACC air cooled condenser

ACEC Area of Critical Environmental Concern

ACHP Advisory Council on Historic Preservation

AF acre-feet

AFY acre-feet per year

ALR action leakage rate

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

Amsl above mean sea level

ANSI American National Standards Institute

APE area of potential effects

ASTM American Society of Testing and Materials

AUM animal unit months

BACP Nevada Bureau of Air Quality Planning

bgs below ground surface

BLM U.S. Bureau of Land Management

BMPs best management practices

CAS Chemical Abstract Service number

CCAR California Climate Action Registry

CERCLA (or superfund) Comprehensive Environmental Response, Compensation and Liability Act

CESA cumulative effects study area

CFR Code of Federal Regulations

CEQ Council on Environmental Quality

CH4 methane

CMPs corrugated metal pipes

CO carbon monoxide
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xv

CO2 carbon dioxide

CSP concentrating solar power technology

CVSA Commercial Vehicle Safety Alliance

CWMA Cooperative Weed Management Areas

dB decibel 

dBA A-weighted decibel

DC direct current

DCS Distributed Control System

DEIS Draft Environmental Impact Statement

DHS U.S. Department of Homeland Security

DOD U.S. Department of Defense

DOI U.S. Department of the Interior

EAI Ecological Area Inventory

EIS Environmental Impact Statement

EO Executive Order

EPCRA Emergency Planning and Community Right to Know Act

EPA ID Environmental Protection Agency Identification number

EPA U.S. Environmental Protection Agency

EPAct Energy Policy Act of 2005

ESA Endangered Species Act

FAA Federal Aviation Administration

FEMA Federal Emergency Management Act

FHWA Federal Highway Administration

FLPMA Federal Land Policy and Management Act

ft2 square feet

gal gallon

GAP Southwest Regional Gap Analysis Project

GBBO Great Basin Bird Observatory
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xvi

GIS Geographic Information Systems

GLO General Land Office

GPS Global Positioning System

GSU Generator Step-Up 

HAP hazardous air pollutant

HDR HDR Engineering, Inc.

HFC hydrofluorocarbon

HMA Herd Management Area

HMBP Hazardous Materials Business Plans

HPMP Historic Property Management Plan

HTF heat transfer fluid

HUD U.S. Housing and Urban Development

IEEE Institute of Electrical and Electronics Engineers Standards

IMACS Intermountain Archeological Computer System

I/O Input/Output

JBR JBR Environmental Consultants, Inc.

KEC Kautz Environmental Consultants, Inc.

KNO3 potassium nitrate

KOP key observation points

kV kilovolt

Ldn Day-night noise level

Leq equivalent noise level or average noise level

m2 square meters

MBTA Migratory Bird Treaty Act

MLRA Major Land Resource Areas

MSDS Material Safety Data Sheets

MW megawatt

N2O nitrous oxide
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xvii

NAAQS National Ambient Air Quality Standards

NAC Nevada Administrative Code

NaNO3 sodium nitrate

NBMG Nevada Bureau of Mines and Geology

NDA Nevada Department of Agriculture

NDEP Nevada Division of Environmental Protection 

NDOT Nevada Department of Transportation

NDOW Nevada Department of Wildlife

NDWR Nevada Division of Water Resources

NEPA National Environmental Policy Act

NFPA National Fire Protection Agency

NHPA National Historic Preservation Act

NPDES National Pollutant Discharge Elimination System

NOx oxides of nitrogen

NO2 nitrogen dioxide

NOI Notice of Intent

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NRS Nevada Revised Statute

NVCRIS Nevada Cultural Resource Information System

NWAC Nevada Weed Action Committee

O3 ozone

OSHA Occupational Safety and Health Administration

Pb lead 

PFC perfluorocarbon

PGA peak ground acceleration

PL Public Law

PLC Programmable Logic Controllers
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xviii

PM10 particulate matter

PM2.5 fine particulate matter

POI point of interconnection

PSD prevention of significant deterioration

psia pressure per square inch

PUC Public Utilities Commission

PWR Public Water Reserves

PCRA Resources Conservation and Recovery Act

RMP Resource Management Plan

ROD Record of Decision

ROW right-of-way

RPS renewable portfolio standard

SCADA Supervisory Control and Data Acquisition 

SCORP Statewide Comprehensive Outdoor Recreation Plan

SCS Soil Conservation Service

SF6 sulfur hexafluoride

SH State Highway

SHPO State Historic Preservation Office

SOx oxides of sulfur

SO2 sulfur dioxide

SPCC Spill Prevention Control and Countermeasure

SRMA Special Recreation Management Area

STG steam turbine generator

SWPPP Stormwater Pollution Prevention Plan

TCLP Toxicity Characteristic Leaching Procedure

TCP traditional cultural property

TDS total dissolved solids

TFO Tonopah Field Office
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xix

TL transmission line

TSE Tonopah Solar Energy, LLC

UAT unit auxiliary transformer

UPS uninterruptible power supply

USC United States Code

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

V volt

VOC volatile organic compound

Wh Watt-hours

Wig interagency working group on environmental justice

WMP Weed Management Plan

WSS web soil survey
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xx

Executive Summary

The U.S. Bureau of Land Management (BLM) has prepared this Environmental Impact Statement (EIS) to 

analyze potential environmental impacts associated with approval of development of the Crescent 

Dunes Solar Energy Project. Tonopah Solar Energy, LLC (TSE), the Proponent, has proposed construction 

of this solar power generation facility in Nye County, Nevada. Nevada Department of Wildlife, Nye 

County, Esmeralda County, U.S. Department of Defense-Air Force, and the Department of Energy (DOE)

accepted invitations to be cooperating agencies in the development of this document. The DOE is a 

cooperating agency on this EIS pursuant to an MOU between DOE and BLM signed in April 2010.

Project Purpose and Need

The BLM Tonopah Field Office (TFO) has received a ROW application from TSE (Proponent) and must 

consider permitting the solar facility. The Proponent proposes to construct, operate, and decommission 

a solar power electric generation facility and associated infrastructure on lands managed by the TFO. 

The TFO’s purpose is to respond to the Proponent’s ROW grant application under Title V of the Federal 

Land Policy and Management Act (FLPMA) (43 USC 1761) for completeness and in compliance with the 

FLPMA, BLM ROW regulations, and other applicable federal and state laws. 

The TFO’s need is to consider permitting TSE’s application under the BLM’s CFR 2800 while, based on 

the BLM’s EIS, limiting undue or unnecessary degradation of public lands.

Proponent’s Intended Use of the Project

The proposed project would contribute much needed on-peak power to the electrical grid that serves 

the western United States as demand for power continues to grow in these states. The thermal storage 

capability of this technology allows renewable electricity to be produced even when the peak demand 

period extends into the late evening hours. As older technology fossil-fuel plants reach the end of their 

useful lives, replacing them with clean, reliable energy sources is a net benefit. The Proponent has 

executed a Power Purchase Agreement with NV Energy for sale of the electricity produced from the 

facility. The facility is expected to produce approximately 110 MW of power.

Project Description

The proposed solar facility will use Concentrating Solar Power (CSP) technology to generate electricity. 

This specific technology uses heliostat/reflecting mirrors to redirect sunlight on a receiver erected in the 

center of the solar field (called the central receiver). The central receiver consists of a series of tubes

through which a liquid salt passes and is heated by the concentrated solar energy. The heated salt is 

then routed to a large insulated tank where it can be stored with minimal energy loss. When electricity 

is to be generated, the heated salt is circulated through a series of heat exchangers to generate highpressure, superheated steam that is used to power a conventional Rankine cycle steam 

turbine/generator to produce electricity. Energy produced from the facility would interconnect to the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xxi

electrical grid through a new transmission line extending to the existing NV Energy Anaconda Moly 

Substation, approximately 6 miles north of the site. 

Major project components include:

• a solar field consisting of a large area of heliostats 

• a central receiving tower

• a conventional steam turbine to generate electricity

• thermal storage tanks to store the hot and cold liquid salt

• a hybrid cooling system (i.e., an air-cooled condenser with a wet cooling augmentation system 

designed to minimize water consumption by use only during times of high electricity demand)

• a water treatment system and evaporation ponds to remove impurities from the groundwater, 

thereby protecting the turbine

• associated equipment such as pumps, transformers, heat exchangers, and buildings

• associated linear facilities, including a TL and access road, and 

• a borrow pit for aggregate.

This EIS analyzes the environmental effects of the Proposed Action, the No Action Alternative, and two 

alternatives. The Proposed Action would: 

• Approve a right-of-way (ROW) application submitted by TSE to construct and operate a 

110-megawatt (MW) solar power generating facility based on concentrating solar power 

technology (CSP), an approximately 9.5-mile 230 kilovolt (kV) TL, and the temporary use of a 

40-acre borrow pit to extract aggregate for construction. The technology uses heliostats 

(reflecting mirrors) to redirect sunlight onto a receiver erected in the center of a solar field. The 

solar power facility is proposed to be located on BLM-managed lands in Nye County, Nevada. 

Project Location

The proposed project site is located in south-central Nevada, approximately 13.5 miles northwest of 

Tonopah, in Nye County. The project is located within the southern portion of the Big Smoky Valley, 

north of US Highway 95/6 along Poleline Road (State Highway 89). The proposed project would be built

on lands administered by BLM. BLM’s general solar policy is to facilitate environmentally responsible 

commercial development of solar energy projects on public lands and to use solar energy systems on 

BLM facilities where feasible (BLM 2007). Given BLM’s solar policy and the advantage of the BLM 

controlling large areas of land in the southwestern United States, the Proponent is proposing this 

project on BLM-administered lands as opposed to private lands.

Summary of Potential Impacts

Vegetation

Construction activities associated with the Proposed Action Alternative would result in direct effects, 

including the removal of topsoil and vegetation within the project areas during grading activities. 

Approximately 1,628-1,673 acres will be graded in order to construct the project facilities (i.e., 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xxii

heliostats, administrative buildings, access road, borrow pit and transmission line poles), and an 

additional 167-213 acres will be temporarily disturbed during construction. Revegetation and 

reclamation activities would be implemented on the temporarily disturbed sites at the end of 

construction. Following decommissioning and removal of the project, revegetation and reclamation of 

the site would result in eventual reestablishment of the vegetative cover. 

Noxious weeds and Invasive Species

No federal or state listed noxious weeds were observed in the study area. However, invasive species 

such as Russian thistle and halogeton were present in the study area and may further proliferate in 

localized areas. Implementation of the reclamation plan and BMPs would reduce the potential for 

noxious weeds and introductions into and invasive species proliferation throughout the area. The 

Proponent developed a Preliminary Weed Risk Assessment and will develop Weed Management Plan 

(WMP) for the project. The WMP will prescribe management actions for monitoring and eradicating 

specified species by BLM-approved methods. The WMP also will describe applicable processes for the 

use of herbicides on federally managed lands in Nevada, and provide the basis for proper management 

and use of herbicides in the project area. 

Wildlife Resources

Impacts to wildlife are anticipated to include the loss of habitat due to construction of the facility, 

excavation of aggregate in the borrow pit, and construction of the transmission line, and access road. 

During these activities, wildlife that is unable to flee the area may be injured or killed by heavy 

equipment. Additional injuries or deaths may occur because of vehicle collisions by construction and 

operation vehicles, as well as employees commuting to and from their residences and the project site. 

Evaporation ponds will be covered by a porous screen so wildlife will not be affected by the brine 

solution being generated during operation. 

Special Status Species (Plants)

Construction activities associated with the proposed project would directly affect Nevada oryctes, a BLM 

Sensitive Species, by removing plants and suitable habitat within the project areas during grading 

activities to construct the project facilities (i.e., heliostats, power block, evaporation ponds, and 

administrative buildings), and a paved access road. 

Special Status Species (Wildlife)

Mammals: Pale Kangaroo Mice and Bats: Impacts to pale kangaroo mice would include direct mortality 

during grading and the removal of suitable habitat. Direct effects to pale kangaroo mice and bats may 

result from the operation of the facility’s evaporation ponds. The water in the evaporation ponds would 

be saturated with salt (making a brine solution). If mice or bats ingest water from the pond, they may 

become ill or die from sodium toxicity. A porous screen will cover the ponds so that mice or bats are 

excluded from the pond. Additionally, the proposed project would introduce transmission lines into the 

area providing opportunities for avian predators such as owls and other raptors. The potential presence 

of these predators may increase predation pressure on the pale kangaroo mouse and sensitive bat 

species. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xxiii

Golden eagles and Migratory Birds

Water Quality and Quantity

: Impacts to Golden eagles and other migratory birds would include 

potential injury or mortality due to the operation of the facility and transmission line and the removal of 

approximately 1,628-1,673 acres of potential foraging habit. Also, birds may be injured or killed because

of collisions with vehicles, colliding with the mirrors and other structures, and flying through the 

concentrated solar rays near the receiver. Reflections from the heliostat arrays may mimic water 

potentially attracting migratory birds to the site.

Groundwater: Drawdown in excess of 10 feet will not extend beyond the proposed project site; some of 

the existing wells in the area will experience a drawdown of between 1-foot to 1.5-feet. Potential direct 

impacts to groundwater include possible contamination entering the groundwater around the wellhead 

(due to hazardous materials on-site), proposed well pumping causing drawdown affecting wells, and 

restrictions to existing well access or use.

Surface Water

Wetlands, Riparian Zones, and Waters of the U.S.

: Potential direct impacts to surface water associated with the project include increased 

runoff flows, increased sediment transport, increased discharge and transport of contaminants, or 

possible affects to drainage paths or altered flow.

No impacts to jurisdictional wetlands or other special aquatic or riparian sites will occur, as these 

resources were not present in the project area. 

Air Quality

Emissions associated with construction activities and the operational phases of the plant are within 

established federal, state, and regional thresholds. Furthermore, the proposed project is located in a 

region that EPA has categorized as an attainment area for all regulated pollutants. As such, the 

proposed project with all its proposed emission control strategies is not expected to cause a violation of 

established air quality standards and will conform to federal air quality goals and objectives. Through 

the permit application process with the Nevada Department of Environmental Protection, Bureau of Air 

Pollution Control, the proposed project will also have conformed to regional air quality requirements 

and objectives. 

Cultural

Development of the Proposed Action Alternative would impact four historic properties. A total of eight 

historic properties would be impacted by Alternative 2. Only one known historic property would be 

impacted by Alternative 1. No impacts are anticipated for the Transmission Line and Substation or the 

borrow pit. Unanticipated discoveries during project construction could result in impacts to yet

unidentified historic properties for any of the alternatives as well as the Transmission Line and 

Substation or borrow pit. 

Native American Religious Concerns

At this time, given the known and provided information, there exists some potential (not definitive) to 

impact project area specific archaeological sites and associated artifacts of concern. Potential impacts 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xxiv

could occur because of cultural resources treatment plan implementation and the lack of avoidance of 

pre-historic and/or ethno-historic archaeological sites. Based on previous consultations, historic sites 

appear to be of little concern, unless they are associated with specific family histories and ancestral 

habitations (i.e. homesteads located on turn of the century allotment lands).

Considering some impacts may not be known until after (or during) project development (i.e. 

inadvertent discovery of previously unidentifiable subsurface deposits) and the fact that consultation is 

ongoing, specific resource identification and subsequent determinations of impact are not conclusive.

Land Use and Access

Potential impacts on Land Use and Access from the proposed project and its various components are 

relatively limited. The proposed project and the associated alternatives would not create hazards to air 

traffic according to determinations reached by the FAA. Alternative 1 encroaches on a right-of-way 

avoidance area for recreation and a no surface occupancy area for mining, both associated with the 

Crescent Dunes. Existing rights-of-way, mining claims, and other leases have been identified near or 

within the proposed project, but none of these has been identified as potentially conflicting with the 

project.

Soils

The potential for direct impacts, indirect impacts, and cumulative impacts associated with construction 

of the project are present. These impacts may include increased erosion, increased soil compaction, and 

diminished potential for revegetation. Direct impacts, indirect impacts, and cumulative impacts 

associated with operation of the project are not expected. Top soil removed during clear and grub 

activity and grading and excavation required for construction will be collected and stockpiled on-site. 

Stockpiles will be protected from wind and water erosion through establishment of native vegetation 

and temporary or permanent erosion control BMPs including weed-free straw bales or wattles for the 

duration of facility construction, operation, and decommission. Following decommissioning, the 

stockpiled topsoil will be replaced across the site where topsoil was previously removed to provide a 

proper soil substrate for seeding or planting and enhance re-establishment of native vegetation to preconstruction conditions.

Social and Economics

Social and economic impacts may occur as a result of construction and of operation of the proposed 

project. While some construction workforce is available locally, the majority will be relocating to the 

surrounding communities temporarily. This could increase local population by 20 percent or more 

during the peak of construction, resulting in the need for temporary workforce housing, thereby 

impacting the local infrastructure. Through direct and indirect impact, approximately 1,500 jobs would 

be created, $140 million of personal income would be added to the State of Nevada annually, and $160 

million would be added to the gross state product annually during the peak of construction.

While some operations and maintenance workforce is available locally, the majority will be relocating to 

the surrounding communities. This could increase local population by 2 percent or more during 

operation of the facility. However, enough existing residential property exists to accommodate the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| xxv

relocating workforce. Through direct, indirect, and induced impact, during operations and maintenance 

of the facility, approximately 200 jobs would be created, $30 million of personal income would be added 

to the State of Nevada annually, and $22.7 million would be added to the gross state product annually.

Noise

Temporary noise impacts may be experienced during the construction of any part of the proposed 

facility. However, no sensitive receptors were identified in the project area; therefore, no impacts to 

sensitive receivers are likely to occur.

Visual

The proposed solar energy generating facility and associated components would have an estimated 

footprint of approximately 1,600 acres that would house the solar field, administration buildings, 

evaporation pond, generation transmission tie line, substation, and ancillary facilities. Based on 

evaluations of key observation points and the lack of sensitive receptors in the area, impacts to the 

visual context of the project is moderate, except for the Crescent Dunes recreational area where the 

impact is expected to be major.

Hazardous Materials and Other Waste

The construction activities associated with the proposed project will result in an increase risk of 

accidental hazardous material spills from vehicles and heavy equipment. These risks will be mitigated 

with the implementation of operational plans and best management practices. Start-up and operation 

of the facility will involve large volumes of heated molten salt, which if released, could be harmful to the 

local natural resources within the project footprint. In addition, the water treatment facility will 

generate effluent that is placed in ponds to allow the water to evaporate, producing a brine material. 

Spills of these materials are unlikely given the design and management practices to be in place 

throughout construction and operation of the facility. 

Range Resources and Wild Horses

The proposed project will result in the removal of approximately 1,628-1,673 acres of the San Antone 

allotment from forage production and the associated reduction in grazing potential. The loss of this 

amount of forage production equates to approximately 52 AUMs of grazing potential. To maintain 

current ecological condition of the range, the current preference of 13,505 AUMs for the grazing permit 

in this allotment would be reduced to 13,453 AUMs, a reduction of 0.4%. No Wild Horse Management 

Areas are near the proposed project, therefore wild horses and burros would not be affected. 

Recreation / Wilderness

The proposed project would result in the loss of approximately 1,628-1,673 acres of BLM land that is 

currently used for recreational activities such as hunting. Alternative 1 will affect approximately 130 

acres of the Special Recreation Management Area associated with the Crescent Dunes, which is used 

primarily as an off-road vehicle use area. No wilderness areas or wilderness study areas are within 25 

miles of the project area. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-1 

1.0Introduction and Purpose and Need

The U.S. Bureau of Land Management (BLM) has prepared this Environmental Impact Statement (EIS) to 

analyze potential environmental impacts associated with the Crescent Dunes Solar Energy Project. 

Tonopah Solar Energy, LLC (TSE), the Proponent, has proposed construction of this solar power 

generation facility in Nye County, Nevada. The solar facility would have the following features: 

• a large field of heliostats or mirrors to reflect the sun’s energy onto a central receiver or tower

• a conventional steam turbine to generate electricity

• thermal storage tanks to store the hot and cold liquid salt

• a hybrid cooling system (i.e., an air cooled condenser [ACC] with a wet cooling augmentation 

system designed to minimize water consumption by use only during times of high electricity 

demand)

• associated equipment such as pumps, transformers, heat exchangers, and buildings

• associated linear facilities including a transmission line (TL) and access road

This EIS analyzes the environmental effects of the Proposed Action, the No Action Alternative, and two 

alternatives. The Proposed Action would: 

• Approve a right-of-way (ROW) application submitted by TSE to construct and operate a 

100-megawatt (MW) solar power generating facility based on concentrating solar power 

technology (CSP), an approximately 9.5-mile 230 kilovolt (kV) TL, and the temporary use of a 

40-acre borrow pit to extract aggregate for construction. The technology uses heliostats 

(reflecting mirrors) to redirect sunlight onto a receiver erected in the center of a solar field. The 

solar power facility is proposed to be located on BLM-managed lands in Nye County, Nevada. 

1.1 Authority and Jurisdiction

This EIS addresses project-related impacts pursuant to the requirements of the National Environmental 

Policy Act of 1969 (NEPA), 42 United States Code (USC) §§ 4321 et seq., and subsequent implementing 

regulations issued by the Council on Environmental Quality (CEQ) (40 Code of Federal Regulations 

[CFR] 1500–1508). This EIS was also prepared in conformance with the BLM’s NEPA Handbook H-1790-1 

(BLM 2008a). The BLM Handbook provides instructions for compliance with the CEQ regulations for 

implementing the procedural provisions of NEPA and the U.S. Department of the Interior’s (DOI) Manual 

on NEPA (516 DM 1-7).

BLM is the lead federal agency responsible for reviewing TSE’s application. The Proposed Action would 

occur on public lands managed by BLM in the Tonopah Resource Management Plan (RMP) planning 

area. BLM has prepared a RMP to manage resources on these lands. The Proposed Action would 

conform to the current land use plan; no amendment of the plan would be needed in connection with 

implementation of the Proposed Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-2 

1.1.1 DOE Authority and Jurisdiction 

Title XVII of Energy Policy Act (EPAct) authorizes the Secretary of Energy to make loan guarantees for 

eligible projects, including those that “avoid, reduce, or sequester air pollutants or anthropogenic 

emissions of greenhouse gases, and employ new or significantly improved technologies as compared to 

commercial technologies in service in the United States at the time the guarantee is issued.” Tonopah 

Solar Energy, LLC has applied to the U.S. Department of Energy (DOE) for a loan guarantee pursuant to 

Title XVII of the EPAct. DOE is participating in the review of this NEPA document as a cooperating 

agency (40 CFR §1508.5) to ensure that analyses needed to support its decision making on whether to 

provide a loan guarantee to Tonopah Solar Energy, LLC are provided in the EIS.

1.2 Project Overview

The proposed solar facility will use CSP. This specific technology uses heliostat/reflecting mirrors to 

redirect sunlight on a receiver erected in the center of the solar field (called the central receiver). The 

facility is expected to produce approximately 110 MW of power.

The central receiver consists of a series of tubes. Liquid salt—which has the viscosity and appearance of 

water when heated—is routed to the receiver when solar energy is to be collected. The liquid salt passes 

through the receiver, where it is heated by the concentrated solar energy, and then is routed to a large 

insulated tank, where it can be stored with minimal energy loss. When electricity is to be generated, the 

heated salt is circulated through a series of heat exchangers to generate high-pressure superheated 

steam. The steam is then used to power a conventional Rankine cycle steam turbine/generator, which 

produces electricity. The exhaust steam from the turbine is condensed and returned via feedwater 

pumps to the heat exchangers, where the high-pressure superheated steam is generated again. The 

energy in the heated salt is depleted after generating steam and routed to the cold salt tank for reuse 

the next day.

Energy produced from the facility would interconnect through a new TL to the existing NV Energy 

Anaconda Moly Substation (ROW 033242), approximately 6 miles north of the site. The length of the 

proposed new TL would be approximately 9.5 miles.

Major project components include:

• a solar field consisting of a large area of heliostats (reflective mirrors that reflect the sun’s 

energy into a central receiver or tower)

• a conventional steam turbine to generate electricity

• thermal storage tanks to store the hot and cold liquid salt

• a hybrid cooling system (i.e., an air-cooled condenser with a wet cooling augmentation system 

designed to minimize water consumption by use only during times of high electricity demand)

• a water treatment system and evaporation ponds to remove impurities from the groundwater, 

thereby protecting the turbine

• associated equipment such as pumps, transformers, heat exchangers, and buildings

• associated linear facilities, including a TL and access road 

• a borrow pit for aggregate
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-3 

1.3 Project Location

The proposed project would be built on lands administered by BLM. According to the National 

Renewable Energy Laboratory United States Solar Atlas, the proposed project site maintains high 

insolation levels on a year-round basis, creating ideal conditions for solar energy generation (Figure 1-1). 

While many undeveloped parcels of land exist in Nevada, it can be difficult to acquire parcels from 

private parties and assemble the acreage needed for a CSP plant. If enough private land were acquired, 

permitting issues at a local level within a jurisdiction with no policy on solar development can be 

difficult. BLM’s general solar policy is to facilitate environmentally responsible commercial development 

of solar energy projects on public lands and to use solar energy systems on BLM facilities where feasible 

(BLM 2007). Given BLM’s solar policy and the advantage of the BLM controlling large areas of land in the 

southwestern United States, the Proponent is proposing this project on BLM-administered lands as 

opposed to private lands.

The proposed project site, transmission line (TL), and borrow pit (temporary during construction) are 

located in south-central Nevada, west of Tonopah, in Nye County. The proposed project encompasses 

approximately 2,950 acres (Figure 1-2), as located in the following lands when described by aliquot 

parts:

Proposed Project Site (N-86292)

• in Township 4 North, Range 41 East: 

• western half of Sections 12 and 13

• Sections 11 and 14

• northwestern, northeastern, and southeastern quarters of Section 15

• southwestern, northeastern, and southeastern quarters of Section 10

• southern half of the northwestern quarter of Section 10

• eastern half of the southwestern quarter of Section 15

TL and Substation (N-87933)

• in Township 4 North, Range 41 East: 

• eastern half of Section 9

• northwestern, southwestern, and southeastern quarters of Section 4

• in Township 5 North, Range 41 East:

• northwestern, southwestern, and northeastern quarters of Section 33

• eastern half of Section 28

• Section 22

• southeastern quarter of Section 15

• western half of Section 14

• southwestern, southeastern, and northeastern quarters of Section 11

• eastern half of Section 2

• northwestern quarter of Section 27
Tonopah, NV

Crescent Dunes Solar Energy Project

Source: National Renewable Energy Laboratory, May 2004

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Solar_resources.mxd

Figure 1-1 Solar Resources Map
Nevada Test and Training Range 

Nellis AFB

Anaconda Substation

To Las Vegas

Borrow Pit

0 510

Miles

Legend

Transmission line

Borrow Pit

Proposed Site

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Site_Vicinity_Map.mxd

Tonopah

Figure 1-2 Site Vicinity Map

Project Site Crescent Dunes Solar Energy Project

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-6 

Potential Borrow/Gravel Pit

• in Township 5 North, Range 41 East: 

• northeastern quarter of Section 19

• western half of the northwestern quarter of Section 20

• southern half of the southeastern quarter of Section 18

The areas for the project site, TL, and substation are shown in more detail in Chapter 2.0, Alternatives

Including the Proposed Action. The solar field, administration building areas, evaporation pond areas, 

TL, substation, and other ancillary facilities would be located within the approximately 2,950 acres 

identified above; temporary and permanent construction impacts would not affect this entire area. The 

estimated area of permanent disturbance and temporary disturbance within the proposed final ROW

boundary is approximately 1,673 acres (permanent) and 213 acres (temporary), the remainder of the 

2,950 acres would remain undisturbed. 

During the scoping phase for this EIS, two alternative site locations were identified (see Figure 2-1). 

Alternative 1 is located approximately 1.85 miles north of the proposed project site, and Alternative 2 is 

located approximately 2.4 miles northwest of the proposed project site. The two alternatives would use 

the same technology as described in Section 1.2, Project Overview, and occupy approximately the same 

acreage on lands administered by BLM. 

1.4 Purpose and Need for the Proposed Project

1.4.1 Purpose

The BLM Tonopah Field Office (TFO) has received a ROW application from TSE (Proponent) and must 

consider permitting the solar facility. The Proponent proposes to construct, operate, and decommission 

a solar power electric generation facility and associated infrastructure on lands managed by the TFO. 

The TFO’s purpose is to respond to the Proponent’s ROW grant application under Title V of the Federal 

Land Policy and Management Act (FLPMA) (43 USC 1761) for completeness and in compliance with the 

FLPMA, BLM ROW regulations, and other applicable federal and state laws. 

1.4.2 Need

The TFO’s need is to consider permitting TSE’s application under the BLM’s CFR 2800 while, based on 

the BLM’s EIS, limiting undue or unnecessary degradation of public lands.

1.4.3 DOE Purpose and Need 

The purpose and need for DOE action is to comply with DOE’s mandate under EPAct 2005 by selecting 

eligible projects that meet the goals of the Act. DOE is using the NEPA process to assist in determining 

whether to issue a loan guarantee to Tonopah Solar Energy, LLC to support the proposed project.

1.4.4 Proponent Purpose and Need 

The Proponent has filed a ROW application for consideration to construct, operate, and decommission a 

solar power generation facility and associated infrastructure.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-7 

The State of Nevada has enacted a renewable portfolio standard (RPS) as part of its 1997 restructuring 

legislation. Under the standard, the state’s investor-owned utilities must use eligible renewable energy 

resources to supply a minimum percentage of the total electricity they sell. Nevada’s RPS increased 

July 1, 2009, to 25 percent of retail sales in 2025. In its most recent Integrated Resource Plan filed with 

and approved by the Public Utilities Commission (PUC) of Nevada, NV Energy will spend approximately 

$2 billion to purchase and invest in new renewable energy by 2015. The Proponent’s construction and 

operation of the proposed project would contribute to achieving Nevada’s RPS goals. 

The proposed project would contribute much needed on-peak power to the electrical grid that serves 

the western United States as demand for power continues to grow in these states. The thermal storage 

capability of this technology allows renewable electricity to be produced even when the peak demand 

period extends into the late evening hours. As older technology fossil-fuel plants reach the end of their 

useful lives, replacing them with clean, reliable energy sources is a net benefit. The proposed project 

would respond to this need, as the Proponent has executed a Power Purchase Agreement with NV 

Energy as of November 4, 2009, for sale of the electricity produced from the facility.

The purpose of the facility is to:

• provide solar-generated electricity to the national electric grid

• help reduce both Nevada’s and the nation’s reliance on fossil-fuel generated electricity

• expand Nevada’s and the nation’s use of non-fossil, renewable energy

• expand Nevada’s renewable energy portfolio

The Proponent’s need for the project is to: 

• deliver approximately 485,000 MW hour (MWh) of cost-effective renewable energy annually to 

the Nevada electricity grid

• develop a solar energy project that provides a stable source of renewable energy to the grid 

through the use of thermal storage

• develop a renewable energy project that can produce renewable energy during Nevada’s peak 

electricity demand periods, including evenings in summer, when solar projects without storage 

can no longer generate solar energy 

1.5 Relationship to Bureau of Land Management and Non-Bureau of Land 

Management Policies, Plans, and Programs

This EIS addresses project-related impacts pursuant to the requirements of NEPA, 42 USC §§ 4321 et 

seq., and subsequent implementing regulations issued by the CEQ (40 CFR 1500–1508). The EIS was also 

prepared in conformance with the BLM’s NEPA Handbook (BLM 2008a). The BLM Handbook provides 

instructions for compliance with the CEQ regulations for implementing the procedural provisions of 

NEPA and the DOI Manual on NEPA (516 DM 1-7). 

The BLM NEPA Handbook also provides guidance on monitoring. Three distinct types of monitoring are 

identified and, if the Proposed Action were approved, would be applicable:
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-8 

• Compliance Monitoring: As part of the Record of Decision (ROD) on the proposed project, 

committed mitigation measures and related monitoring and enforcement activities, if any, for 

the selected alternative will be identified. Stipulations that will become part of BLM’s 

authorization will be attached to the ROD or incorporated by reference from this EIS or other 

applicable requirements. Any measures to avoid or reduce environmental harm identified in this 

EIS that are not adopted will also be identified with an explanation of why the measures were 

not adopted. NEPA requires that decisions on a project be implemented in accordance with the 

ROD. BLM will perform compliance monitoring to ensure that actions taken comply with the 

terms, conditions, and mitigation measures identified in the ROD.

• Effectiveness or Success Monitoring: Determining whether decisions made in the ROD are 

achieving intended environmental objectives may require monitoring the effectiveness or 

success of the actions or decisions. Effectiveness monitoring is not required by NEPA unless 

specified in the ROD. However, monitoring requirements specified in this EIS will be 

incorporated into the ROD. Effectiveness monitoring will typically be required to determine the 

effectiveness or success of identified mitigation measures.

• Evaluation of Validity Monitoring: Determining if a decision continues to be correct or 

appropriate over time is another purpose of monitoring. Evaluation of decision validity 

monitoring is not required by NEPA, and it is usually not routinely needed for all decisions 

covered by an EIS. Evaluation monitoring goes beyond effectiveness monitoring and focuses on 

examining the validity of the environmental objectives. Evaluation monitoring would be used to 

determine whether the terms, conditions, and mitigation measures prescribed by the ROD are 

still needed to achieve environmental objectives or if they are greater or less than necessary to 

achieve environmental objectives.

In Executive Order (EO) 13212 of May 18, 2001 (Actions to Expedite Energy-related Projects), President 

George W. Bush ordered that executive departments and agencies take appropriate actions “to expedite 

projects that will increase the production, transmission, or conservation of energy.” Section 211, of the 

Energy Policy Act of 2005 (EPAct), (Public Law [PL] 109-58) states “...that the Secretary of the Interior 

should, before the end of the 10-year period beginning on enactment of this Act, seek to have approved 

non-hydropower renewable energy projects located on public land with a generation capacity of at least 

10,000 MW of electricity.”

DOI manages approximately 520 million acres of land, one-fifth of the land mass of the United States. 

On March 11, 2009, Secretary of the Interior Ken Salazar issued a Secretarial Order that made facilitating 

the production, development, and delivery of renewable energy on public land a top priority for DOI. 

Within DOI, BLM administers approximately 253 million surface acres of public land in the United States. 

BLM has identified approximately 23 million acres in the Southwest as containing high solar energy 

potential.

The BLM Solar Energy Development Policy establishes a framework to process applications for rights-ofway, and directs BLM to be responsive to solar energy project applicants, while maintaining its 

commitment to resource protection. In 2007, BLM issued Instructional Memorandum Number 

2007-097, which established policy for processing of ROW applications for solar energy development 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-9 

projects on public land administered by BLM. BLM would strive to balance the financial and social 

benefits from this Proposed Action while minimizing impacts to other resources.

Table 1-1 provides a representative list of federal, state, and local laws, statutes, and EOs that may apply 

to the Proposed Action. 

Table 1-1. Federal, state, and local laws, statutes, and EOs applicable to the Proposed Project and 

Alternatives

Federal Laws and Statutes

Archaeological and Historic Data Preservation Act of 1974 (Public Law [PL] 86-253, as amended by PL 93291; 

16 United States Code [USC] 469)

Bald and Golden Eagle Protection Act of 1940 (16 USC 668-668d, 54 Stat. 250) as amended (PL 95-616 

[92 Stat. 3114]) November 8, 1978

Archaeological Resources Protection Act of 1979 (PL 96-95; 16 USC 470aa-mm)

Clean Air Act of 1990 (as amended by PL 92-574; 42 USC 4901)

Department of Transportation Act of 1966 (PL 89-670; 49 USC Section 303)

Endangered Species Act of 1973 (PL 85-624; 16 USC 661, 664 1008)

Energy Policy Act of 2005 (PL 109-58)

Federal Land Policy and Management Act of 1976, Section 201(a) (PL 94-579; 43 USC 1701 et seq.)

Federal Water Pollution Control Act of 1972, Section 404 (PL 92-500; 33 USC 1344, as amended)

Historic Sites Act of 1935 (PL 292-74; 16 USC 461-467)

Land and Water Conservation Fund Act of 1965 (PL 88-578)

Migratory Bird Treaty Act of 1918 (16 USC 703-712, as amended)

National Environmental Policy Act of 1969 (PL 91-190; 42 USC 4321)

National Historic Preservation Act of 1966, Section 106 [PL 89-665; 16 USC 407(f)] 

Paleontological Resources Preservation Act 2009

Executive Orders

Executive Order (EO) 11296 Flood Hazard Evaluation Guidelines

EO 11514 Protection and Enhancement of Environmental Quality

EO 11593 Protection and Enhancement of the Cultural Environment

EO 11988 Floodplain Management (43 Code of Federal Regulations [CFR] 6030)

EO 11990 Protection of Wetlands

EO 12898 Federal Actions to Address Environmental Justice in Minority Populations and Low-income Populations

EO 13007 Indian Sacred Sites

EO 13186 Responsibilities of Federal Agencies to Protect Migratory Birds

EO 13212 Actions to Expedite Energy-related Projects

EO 13287 Preserve America

EO 123772 Intergovernmental Review of Federal Programs

Federal Regulations

10 CFR Parts 1022-1022, Department of Energy NEPA Implementing Procedures

40 CFR Parts 1500-1508, Council on Environmental Quality implementation of NEPA

33 CFR 320-331 and 40 CFR Part 230, Section 404 of the Clean Water Act and its Implementing Regulations

36 CFR Part 800, as amended, Protection of Historic Properties

43 CFR Part 2800, as amended, Right-of-Way Principles and Procedures
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-10

Table 1-1. Federal, state, and local laws, statutes, and EOs applicable to the Proposed Project and 

Alternatives

State Laws and Statutes

Nevada Revised Statue (NRS) 502.390 Permit required to develop or maintain certain bodies of water, fees and 

assessments; penalties.

NRS 527.060-120 Protection and Preservation of Timbered Lands, Trees, and Flora – Definitions Cactus and Yucca

NRS 527.270 List of species declared to be threatened with extinction; special permit required for removal or

destruction

NRS 533.030 Adjudication of Vested Water Rights; Appropriation of Public Waters – Appropriation for beneficial

use; use for recreational purpose declared beneficial; limitations and exceptions

NRS 533.035 Adjudication of Vested Water Rights; Appropriation of Public Waters – Beneficial use: Basis, measure 

and limit of right to use

NRS 534.020 Underground waters that belong to the public and are subject to appropriation for beneficial use;

declaration of legislative intent

NRS 555.005 Agriculture – Control of Insects, Pests, and Noxious Weeds

1.6 Authorizing Actions and Permits

In addition to the EIS, implementing the Proposed Action would require authorizing actions from other 

federal, state, and local agencies with jurisdiction over certain aspects of the proposed project. Table 1-2 

lists potential permits or approvals that may be required before and during construction, and during 

operations. The Proponent or contractor would be responsible for amending existing permits, applying 

for, and acquiring additional permits, as needed. 

Table 1-2. Potential authorizations and permits

Agency Permit or Approval Regulated Activity

Federal Permits and Approvals

U.S. Bureau of Land 

Management 

(BLM) 

National Environmental Policy Act

Record of Decision 

Major federal action significantly affecting the quality 

of the human environment 

BLM

Right of Way Permit and/or

Temporary Use Permit 

(BLM SF 299 application)

Required for permanent and temporary (example 

construction) use of BLM administered lands (facilities, 

water pipelines, transmission, access roads, gas 

pipeline, and other ancillary items) 

U.S. Fish and 

Wildlife Service

Endangered Species Act Section 7 

Consultation and Biological 

Opinion

Required for potential direct or indirect impacts to 

federally listed species and/or associated habitats 

U.S. Environmental 

Protection Agency 

(EPA)

Section 402 National Pollutant 

Discharge Elimination System

(NPDES) Notification

Required for stormwater management during 

construction

Tribal Authorities

Nevada Tribal 

Councils

Section 106 Review and Native 

American Consultation

Required to address impacts on Native American or 

cultural resources
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-11

Table 1-2. Potential authorizations and permits

Agency Permit or Approval Regulated Activity

Nevada State Permits and Approvals

Nevada State 

Historic 

Preservation Office

Section 106 Review and 

Concurrence

Federally funded projects are to take into account 

potential impacts on cultural and historical resources

Nevada 

Department of 

Wildlife (NDOW)

Southern Region Project Review Wildlife and habitat consultation for disturbance on 

BLM-managed land

NDOW

Implementation of terms and 

conditions of the Biological 

Opinion

Potential impacts on common and special-status 

wildlife species (document compliance with the terms 

and conditions of the Biological Opinion)

NDOW Industrial Artificial Pond Permit Potential injuries and mortalities to wildlife caused by

ponds 

NDOW Consent for Alteration of 

Protected Species

Required for taking any wildlife classified as protected

Nevada Division of 

Environmental 

Protection (NDEP) 

Prevention of Significant 

Deterioration Program Major 

Source Permit

Required to consolidate potential air quality impacts of 

a proposed major project

NDEP

General Stormwater Permit for 

Construction Activities (Notice of 

Intent and General Permit)

Construction activities disturbing more than 1 acre

NDEP Bureau of Air 

Pollution Control 

Operating Permit to Construct Nevada Administrative Code 445B.22037 requires 

fugitive dust to be controlled

NDEP Bureau of Air 

Pollution Control

Surface Area Disturbance/Dust 

Mitigation Control Plan

Required for a surface area disturbance is greater then 

20 acres

NDEP Bureau of Air 

Pollution Control

Sand and Gravel Processing Plant Required for construction/operation of new asphaltic 

concrete plants, concrete batch plants, and sand and

gravel processing plants (Nevada Revised Statute 

[NRS] 445B.155) 

NDEP Bureau of 

Safe Drinking 

Water

Concurrence Letter or Letter of 

Approval to Construct

Need permit to operate the water system upon 

satisfaction of the requirements set forth in 

NRS 445A.885 to 445A.915, inclusive, and the 

requirements set forth in the regulations adopted by 

the Commission

NDEP Bureau of 

Water Pollution 

Control

Temporary Discharge Permit Required for discharge to surface waters, for all 

purposes except working in waterways, maximum of 

180 days

NDEP Bureau of 

Water Quality 

Pollution Control

Section 401 Water Quality 

Certification

Required for impacts on water quality caused by 

discharges to a water body by construction activities

NDEP Bureau of 

Water Pollution 

Control

General Stormwater Discharge 

Permit

Required for stormwater discharge associated with 

construction activities disturbing at least 1 acre

Nevada 

Department of 

Water Resources

Water Right Permit Required for the issuance of water rights

Nevada Public 

Utilities 

Commission

Utility Environmental Protection 

Act

Required for the construction of a utility facility
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-12

Table 1-2. Potential authorizations and permits

Agency Permit or Approval Regulated Activity

Nevada Division of 

Forestry

Native Cacti and Yucca 

Commercial Salvaging and 

Transportation Permit

Required for the salvage and removal, transport or 

sale of five or more native cacti or yucca from private 

or federal land 

Nevada Division of 

Forestry

Permit for the Take of Critically 

Endangered Flora

Required for the disturbance of plant species listed as 

Critically Endangered (NRS 527.260 to 527.300) 

Nevada 

Department of 

Motor Vehicles and 

Public Safety

Nevada State Hazardous Materials 

Permit or Roving Permit

Required for storage of flammable and combustible 

liquids (includes fuel storage areas and fuel depot used 

more than 30 days)

Nye County Permits and Approvals

Nye County Bureau 

of Fire Prevention

Fire Safety Compliance

Certification

Building and operation fire safety

Nye County 

Planning

Department

Flood Damage Prevention Permit Certification of flood zone location

Building Permit County Building Division Construction of facilities

Other Permits and Approvals

NV Energy 

Interconnection

Approval for Interconnection Proposed project connection to an existing NV Energy 

transmission line

1.7 Agency Coordination

1.7.1 Agency Communication

After the publication of the Notice of Intent (NOI) for the Proposed Action, BLM contacted relevant 

federal, state, and local government agencies to initiate coordination. Because of this coordination 

effort, the following agencies and officials were identified as having an interest in the project and were 

asked to submit comments: 

Federal

• U.S. Bureau of Reclamation

• U.S. Army Corps of Engineers

• U.S. Air Force

• U.S. Fish and Wildlife Service (USFWS)

• U.S. Environmental Protection Agency (EPA)

• National Park Service

• U.S. Senator Harry Reid 

• U.S. Senator John Ensign

• U.S. Congressman Dean Heller

State

• Nevada Department of Transportation

• NV Energy Lands Service Department

• Nevada State Office Planning and Environmental 

• Nevada Department of Wildlife (NDOW) – Southern Region Office
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-13

Local

• Southern Nevada Water Authority

• Esmeralda County Commissioners

• Nye County Commissioners

• Town of Tonopah

1.7.2 Cooperating Agencies

A cooperating agency is any federal, state, or local government agency that has jurisdiction either by law 

or special expertise regarding environmental impacts of a proposed action or a reasonable alternative 

for a federal action. The benefits of cooperating agency participation in the analysis for and preparation 

of an EIS include: 

• disclosure of relevant information early in the analytical process

• application of available technological expertise and staff support

• avoidance of duplication of other federal, state, local, or tribal procedures

• establishment of a formal process for addressing intergovernmental issues 

The following is the list of federal, state, and local agencies that were invited to be a cooperating agency 

for the project. Please see Appendix E in the Scoping Report for copies of the invitation letters.

Federal

• U.S. Department of Transportation 

• USFWS

• U.S. Forrest Service

• National Park Service

• National Park Service: Death Valley National Park

• U.S. Department of Defense (DOD)

• U.S. Department of Energy (DOE)

• U.S. Department of Transportation Federal Aviation Administration

• EPA 

State

• State of Nevada

• Nevada Department of Transportation

• NDOW

• Nevada Division of Environmental Protection (NDEP)

• State of Nevada Department of Conservation and Natural Resources

• PUC of Nevada

• Nevada State Historic Preservation Office (SHPO)

• State of Nevada Commission on Mineral Resources
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-14

Local

• Nye County Board of Commissioners

• Esmeralda County Board of Commissioners

• Town of Tonopah

Upon receipt of the invitation letter, each agency had 45 days to accept or decline the opportunity to 

become a cooperating agency. Cooperating agencies may contribute baseline information and/or 

provide input into the environmental document, as well as review the draft and final versions of the EIS.

The following agencies accepted the invitation to become a cooperating agency:

• NDOW

• National Park Service – Death Valley National Park

• Nye County, Esmeralda County, Town of Tonopah

• DOD, U.S. Air Force

On September 14, 2009, the Proponent submitted a Part I application to the DOE Loan Guarantee 

Program seeking a guarantee for the Proposed Project in response to the Loan Guarantee Solicitation 

Announcement (DE-FOA-0000140) issued on July 29, 2009. The Proponent then submitted a Part II 

application in December 2009. The DOE invited the Proponent to enter into the due diligence process 

on June 25, 2010 and initiated NEPA review for the Proposed Project. In July 2010, The DOE requested 

to participate as a cooperating agency pursuant to an MOU between DOE and BLM signed in April 2010. 

In July 2010 the National Park Service – Death Valley National Park opted out of being a cooperating 

agency.

1.8 Summary of Public Scoping and Issue Identification

Scoping is an integral part of the NEPA process and provides “an early and open process for determining 

the scope of issues to be addressed and for identifying the significant issues related to a proposed 

action” (40 CFR 1501.7). During this scoping process, BLM solicited comments from pertinent agencies 

and the public. These comments will be organized and analyzed so that the relevant issues can be 

addressed during the environmental analysis and the preparation of the EIS. Comments will help BLM 

define the scope of analysis for the EIS.

1.8.1 Federal Register

The Federal Register NOI was published on November 24, 2009, marking the beginning of the scoping 

period for the project. The scoping period ended on December 24, 2009. This period fulfills the BLM 

minimum requirement of a 30-day scoping period.

1.8.2 Announcements, and Media Releases

Announcements for the public scoping meetings were published in a variety of local and regional 

newspapers (see Table 1-3). Additionally, scoping meeting dates, times, and locations were posted on 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-15

the BLM TFO Web site (www.BLM.gov/nc/st/en/fo/Battle_Mountain_Field.html). A public service 

announcement was also made on News 88.9 KNPR Nevada Public Radio on November 24, 2009.

Table 1-3. Publications for the proposed Crescent Dunes Solar Energy Project 

Newspaper Dates Published

Pahrump Mirror December 2, 9, and 16, 2009

Pahrump Valley Times December 3, 10 and 17, 2010

Las Vegas Review-Journal December 2, 9, and 16, 2010

Reno Gazette-Journal December 2, 9, and 16, 2010

Copies of these announcements can be found in the Scoping Report in the Administrative Record. 

1.8.3 Public Meetings

Public meetings are required where “there may be substantial environmental controversy concerning 

the environmental effects of the proposed action, a substantial interested in holding the meeting, or a 

request for a meeting by another agency with jurisdiction over the action” (40 CFR 1506.6). Public 

scoping meetings locations, dates, and number of attendees are provided in Table 1-4. In accordance 

with BLM requirements, sign-in sheets were provided and attendees were encouraged to sign in. Copies 

of the sign-in sheets are provided in the Administrative Records. 

Table 1-4. Public meeting information

Meeting Location Date Number 

of Attendees

Tonopah Convention Center

301 Brougher Ave, Tonopah, Nevada Thursday, December 17, 2009 42

BLM Southern Nevada District Office

4701 N. Torrey Pines Drive, Las Vegas, Nevada Friday, December 18, 2009 6 

Note: All meetings were held from 6 to 8 p.m. 

Both meetings began with a brief presentation of the project and an overview of the NEPA process. 

Additionally, posters summarizing the proposed project location, proposed technology, and an overview 

of the NEPA process were displayed for public review (Appendix D). BLM, TSE, and HDR Engineering, Inc. 

(HDR, the EIS consultant), representatives were available to answer questions. Project fact sheets and 

comment cards were provided at each meeting. Comment cards were provided so members of the 

public could submit comments regarding issues or concerns, reasonable changes or additions to the 

proposed project, or any other comments or questions. Comment cards could be submitted at the 

meeting, mailed, or faxed to the BLM TFO. Additionally, any written comments could be submitted by 

fax, mail, or e-mail to the BLM TFO.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-16

1.8.4 Summary of Public and Agency Comments

Twenty-four comments on the proposed project were submitted (Table 1-5). Comments included 

concerns and questions regarding public lands, threatened and endangered species, water resources, 

cultural resources, dark skies, socioeconomic impacts, and cumulative impacts and connected actions.

Table 1-5. Summary of public and agency comments received

Organization/Name Comment Comment Type

U.S. Environmental 

Protection Agency

Tom Plenys

DEIS should clearly identify the underlying purpose and need 

to which BLM is responding in proposing the alternatives. 

The DEIS should describe how each alternative was 

developed, how it addresses each project objective, and how 

it would be implemented. The DEIS should estimate the 

quantity of water the project will require and describe the 

source of this water and potential effects on other water 

users and natural resources in the project’s area of influence. 

The DEIS should identify all petitioned and listed threatened 

and endangered species and critical habitat that might occur 

within the project area. EO 13112, mandates that federal 

agencies take actions to prevent the introduction of invasive 

species, provide for their control, and minimize the 

economic, ecological, and human health impacts that 

invasive species cause. The cumulative impacts analysis 

should provide context for understanding the magnitude of 

the impacts of the alternatives by analyzing the impacts of 

other past, present, and reasonably foreseeable projects or 

actions and then considering those cumulative impacts in 

their entirety. The DEIS should consider how climate change 

could potentially influence the proposed project, specifically 

within sensitive areas, and assess how the projected impacts 

could be exacerbated by climate change. The DEIS should 

provide a detailed discussion of ambient air conditions 

(baseline or existing conditions), NAAQS, criteria pollutant 

nonattainment areas, and potential air quality impacts of the 

proposed project. Consultation for tribal cultural resources is 

required under Section 106 of the NHPA. EO 12898 directs 

federal agencies to identify and address disproportionately 

high and adverse human health or environmental effects on 

minority and low-income populations. The DEIS should 

address potential direct, indirect, and cumulative impacts of 

hazardous waste from construction and operation of the 

proposed project. The DEIS should discuss how the proposed 

action would support or conflict with the objectives of 

federal, state, tribal or local land use plans, policies and 

controls in the project area.

General

Water resources

Land use

Threatened and 

endangered species

Cumulative impacts

Climate change

Air quality

Hazardous materials
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-17

Table 1-5. Summary of public and agency comments received

Organization/Name Comment Comment Type

U.S. Fish and Wildlife 

Service

Nevada Fish and 

Wildlife Office

Kathleen Erwin

The Nevada Fish and Wildlife Office has received your 

November 24, 2009 scoping notice for this project. Based on 

our workload we are unable to provide you with comments 

at this time. However, we would appreciate remaining on 

your mailing list to review the draft EIS when complete. 

Please contact our office if you have any questions regarding 

listed or proposed species or migratory birds.

General

U.S. Geological Survey

Brenda Johnson

Has reviewed plan and has no comment. General

Duckwater Shoshone 

Tribe

Virginia M. Sanche

At the present time, Duckwater Shoshone Tribe has no 

concerns with the project. However, the Tribe recommends 

that the Tonopah Field Office contact the Yomba Shoshone 

Tribe, as the project is closer to their traditional homelands. 

Native American 

concerns

Timbisha Shoshone 

Tribe

Barbara Durha

Concern that their tribe has not seen cultural reports, have 

not had opportunity to provide input and would like 

extension of deadline for comment. 

Cultural resources

Nevada State 

Clearinghouse

Robert K. Martinez, 

P.E.

All waters of the State belong to the public and may be 

appropriated for beneficial use pursuant to the provisions of 

Chapters 533 and 534 of the Nevada Revised Statutes (NRS) 

and not otherwise. No use of surface water or groundwater 

is to occur unless a permit is issued.

Water resources

Nevada State 

Clearinghouse

Skip Canfield

Regarding dark sky attributes, solar facilities should have 

shields placed on all lights; a comprehensive look at visual 

impacts should be considered when the BLM reviews any 

development plans on public lands in Nevada and nationally.

Dark skies

Nevada Department of 

Wildlife

D. Bradford 

Hardenbrook

Concern for wildlife and birds under the migratory bird 

treaty act, desert kangaroo rat, pale kangaroo mouse, kit fox, 

pronghorn antelope, scarab beetle, etc.

Wildlife
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-18

Table 1-5. Summary of public and agency comments received

Organization/Name Comment Comment Type

Nevada Division of 

Mines 

Alan Coye

The EIS should consider the following: 1. The proposed 

project will apparently withdraw 1,600 acres of land from 

the operation of the mining law and the staking of mining 

claims. 2. The proposed project is located in an area of 

pediment adjacent to two highly mineralized mountain 

ranges, the Royston Hills to the west and the San Antonio 

Mountains to the east. Many new mineral deposits in 

Nevada are being discovered beneath the pediment adjacent 

to mineralized mountain ranges. 3. The San Antonio Mining 

District which contains the significant molybdenum deposit 

(Liberty Deposit) controlled by General Moly occurs 

approximately six miles from the proposed location. 4. The 

proposed project may occur in an area prospective for 

lithium-bearing brines, which are being actively explored for 

in nearby areas. 5. The area of the proposed project may be 

prospective for geothermal energy. The EIS needs to analyze 

and carefully consider the impacts from the proposed 

project to the development of other possible natural 

resources in the area.

Land use

Cumulative effects

Mineral rights

Nye County Nuclear 

Waste

Repository Office

Lewis Darrell Lacy, Jr. 

One of the main issues is the availability of water for current 

and future use, given that the local basins have limited 

recharge and existing water supplies are over allocated 

based on the current amount of water rights issued, any 

transfers of water rights for this project will be adjudicated 

by the Nevada State Engineer; however, the cumulative 

impact of water use technologies should be comprehensively 

addressed during the EIS process. Nye County requests that 

the BLM and Solar Reserve cooperate with our staff and local 

communities during the EIS process to identify all 

impacts-direct, indirect, and cumulative-from the 

construction and operation of this facility. Once the impacts 

from the plant are identified, we desire to consult within the 

EIS process to help develop appropriate mitigation measures 

as well as ensure that appropriate buffers and equipment 

designs are incorporated to minimize disturbance to the 

area.

Water resources

Cumulative impacts
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-19

Table 1-5. Summary of public and agency comments received

Organization/Name Comment Comment Type

Town of Tonopah

Terry Rivero, Chairman

Any comments or concerns that the Town of Tonopah staff 

had in regard to the site location for this project were 

addressed directly with Solar Reserve or are being addressed 

by Nye County’s renewable energy team. Resource or service 

deficiencies are being identified in the areas of: housing, 

schools, water, waste water, and emergency services. Solar 

Reserve also seriously considered our area’s most precious 

and finite resource, water, by deciding to implement a dry, 

rather than wet, cooling process. 

Community resources

Water resources

Tonopah Town Board

Horace Carlyle

Strong supporter with attached letter! Would like to be 

added to mailing list.

General

Tonopah Astronomical 

Society

Thomas W. Cohen

Concern for the Dark Sky – please conform to lighting 

recommendations.

Dark skies

Nevada Wilderness 

Project

John C. Tull

Concerns for wildlife – scarab beetle, milkvetch, pale 

kangaroo mouse.

Wildlife

Center for Biological 

Diversity

Rob Mrowka

Concern for impact on rare species and habitats, off-road 

vehicle use impacts, cumulative and connected actions

(consider other projects and cumulative impact of this 

project in conjunction), conflicting land uses (area is an ORV 

park, which could lead to dirty solar panels and a lot of extra 

water to clean them!), privatization of site, decommissioning 

and restoration. Also, want to be an active stakeholder.

Threatened and 

endangered species

Off-highway vehicle 

impacts

Cumulative effects

Water resources

Tonopah Sand and 

Gravel

Carl Wright

We would like to be permitted to become a preferred 

vendor and participate in the initial bidding process so that 

we may be allotted the opportunity to provide our local 

services to this well-founded energy project

General

Western Lithium 

Corporation

Dennis P. Bryan

Could a geothermal well fit on the property too? What about 

underground metal deposits? Would like to see multiple uses 

for property. 

Land use

Individual

John Mudge

My sense is that we should not ”break our pick” on this one. 

1,600 acres is pretty small and, of course, we don't want to 

be seen as opposing renewables. I do endorse keeping our 

eyes and ears open to land use proposals as they come along 

so that we can comment appropriately. The updated RMPs 

that are going on in Winnemucca and that are scheduled for 

Battle Mountain and then Elko are key examples.

Land use

Individual

Richard Delong

I think it is good to make sure that the BLM continues to 

consider all resources when making discretionary decisions. 

General
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-20

Table 1-5. Summary of public and agency comments received

Organization/Name Comment Comment Type

Individual

Brad Mamer

How do I obtain specific information on the government 

lease of these public lands?

Public lands

Individual

David Haig

I attended the public forum in Tonopah for the Crescent 

Dunes project and was quite impressed by the presentation. 

Being in a desert region, there were concerns about water 

supply and they seem to have that planned for. There were 

also concerns about night-time lighting affecting Tonopah’s 

dark sky environment and they have planned for that with 

minimal lighting needed and with the use of shielded light 

fixtures. I think this is an excellent project to help diversify 

Nevada’s energy supply with minimal impact to the 

environment. This project will also bring much needed jobs 

to the area and will also help diversify the local tax base and 

may even be a boost to local tourism.

General

Water resources

Dark skies

Socioeconomic 

conditions

Individual

Dan Lingelbach

I am in favor of this project as it is large enough to produce 

some realistic data regarding the feasibility of concentrating 

solar thermal electric power production. Hopefully, they will 

account for the energy that must be used to produce such a 

facility including the site preparation, faulting all the 

equipment to the site, installation, man-hours, checkout 

costs, etc. I assume that those costs will be available soon 

after completion and then later on the total power 

production for at least a year of operation. I would 

appreciate being kept informed.

General

Individual

John E. Hiatt

Lack of ground water, rare plants, drainage plan, concern 

about size of tower and whether this is going to be 

successful or experimental, mitigation for impact to lost 

resources, wildlife migration routes, bird attraction to panels 

and the results of this cumulative impact to the dunes, 

socioeconomic impact of influx of construction workers, 

reclamation bonding.

Water resources

Wildlife

Cumulative effects

Socioeconomic 

conditions

Individual

John Snow

Would the current pre-existing mineral rights policies cover 

the mining and geothermal concerns if the withdrawal is 

apparent and not prescribed in the EIS?

Mineral rights

Note: Full versions of comments are included in Appendix F of the Public Scoping Report.

Because reasonably foreseeable future actions contribute to the cumulative effects of the proposed 

project, these actions are discussed in Chapter 4.0. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 1-21

1.9 Organization of the Environmental Impact Statement

This EIS follows the CEQ recommended organization, in accordance with 40 CFR 1502.10, and BLM 

guidelines described in the BLM Handbook H-1790-1. The Chapters and their content are described in 

Table 1-6. 

Table 1-6. Description of EIS chapters

Chapter Description

Chapter 1 – Introduction

and Purpose and Need

This chapter provides a description of the purpose of, and need for, the Proposed 

Action, the role of the U.S. Bureau of Land Management in the Environmental 

Impact Statement (EIS) process, required regulatory actions for the proposed 

project, and the public and agency scoping summary.

Chapter 2 – Alternatives

Including the Proposed 

Action

This chapter describes the Proposed Action and alternatives analyzed in the EIS, 

including the No Action Alternative. Alternatives that were considered but 

eliminated from further analysis are described, with a discussion of why they were 

not considered further.

Chapter 3 – Affected 

Environment

This chapter describes the existing environment that could be affected by granting 

the rights-of-way requested by the Proponent. 

Chapter 4 – Environmental 

Consequences

This chapter describes possible environmental consequences of the Proposed Action 

and alternatives analyzed in the EIS. Direct, indirect, and cumulative effects of the 

Proposed Action and alternatives are assessed and described in order to allow for 

comparative impact evaluation. Impacts are compared to the social and natural 

environment that would be expected to exist if no action were taken (the No Action 

Alternative).

Chapter 5 – Consultation 

and Coordination

This chapter describes public participation undertaken to date. It also lists agencies 

and organizations that will receive copies of the Draft EIS for review and lists the 

preparers of the document.

Chapter 6 – References This chapter includes a list of references used in the preparation of the EIS.

Chapter 7 – Glossary This chapter includes a glossary of technical terms used in the EIS.

Chapter 8 – Index This chapter includes an index listing of key words used in the EIS.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-1 

2.0Alternatives Including the Proposed Action

2.1 Introduction

The Proposed Action for BLM is to evaluate a ROW application submitted by TSE to construct and 

operate a 110 MW solar power generating facility (proposed project) based on CSP. This technology 

uses heliostats (reflecting mirrors) to redirect sunlight on a receiver erected in the center of a solar field. 

The solar power facility is proposed to be located on BLM property located in Nye County, Nevada. The 

BLM ROW grant would be for a term of 30 years and would be renewable. Additionally, two alternative 

sites are being considered as possible locations for the proposed solar power facility, and these are 

shown in Figure 2-1 and described in detail in Section 2.6, Alternatives to the Proposed Action. This 

chapter provides a description of the alternatives analyzed in this EIS and includes the Proposed Action, 

the No Action Alternative, and the two alternative sites. This chapter also includes a comparative 

analysis of alternatives studied in detail; other alternatives considered but eliminated from further 

evaluation; and the identification of the BLM-preferred alternative. Under the No Action Alternative, no 

solar facility would be constructed, and the environmental and social setting would continue to be 

consistent with the current conditions. 

2.2 Project Background

SolarReserve, doing business as TSE, is a Santa Monica, California, based energy company formed by 

US Renewables Group, a private equity firm focused exclusively on renewable energy. SolarReserve now 

holds the exclusive worldwide license to build solar plants that use equipment manufactured by United 

Technology Corporation’s subsidiary, Pratt & Whitney, through its Rocketdyne division.

As illustrated in Figure 1-2, the nearest community to the proposed project site is the town of Tonopah, 

Nevada, which is located approximately 13 miles to the southeast of the site (from the proposed project 

site, 8.5 miles south along Pole Line Road [State Route 89] to State Highway [SH] 95/6, and then 

4.5 miles east along SH 95/6 to Tonopah). The project overlaps or bisects several existing mining claims 

in the region (Figure 2-1) The land necessary for construction of the proposed solar power plant, 

including the heliostat array, power block, and associated facilities, consists of 1,673 acres located 

within the land boundaries described in Section 1.3, Project Location, and shown on Figure 2-2. The 

proposed boundaries as filed in the SF-299 application are currently in excess of the minimum needed to 

site the physical equipment. The project is in the preliminary project design stage, and the additional 

land will allow the Proponent the flexibility to (1) adjust the location of the central tower based on the 

results of soils/geotechnical, cultural, and biological baseline studies and (2) determine an adequate 

buffer between plant facilities and any adjacent uses before finalizing the equipment location within the 

ROW and finalizing the plant boundaries.

TSE performed preliminary screening on additional BLM land near NV Energy’s Anaconda Moly 

Substation. TSE’s technology has specific siting requirements, including a large open space of 

approximately 4 square miles, minimal slope, transmission access, water availability, road access, and 

high solar incidence. TSE is also limited to sites not already claimed by other developers.
Crescent Dunes Road

Borrow Pit

Anaconda-Moly Substation

Pole Line Road

¬«89

¬«89 0 1 2

Miles

Legend

Transmission line

Existing

Planned

Borrow Pit

Alternative Area

Proposed Area

Alternative 1

Alternative 2

Proposed Alternative

Mining Claims

±

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Alt_Locations.mxd

2-1 Alternative Locations

 and Mining Claims

Crescent Dunes

Solar Energy Project

!

Project Site

NEVADA

Substation
!H

Crescent Dunes Road

Test well ¬«89

Pole Line Road

Limit of Heliostats

Limit of ROW

Power Block

Admin Parking

Evaportation

Ponds

Proposed

Alternate 1

Alternate 2

0 0.25 0.5

Miles

Legend

!H Test well

Roads

Transmission line

Existing

Planned

Alternative Area

Proposed Area

Existing Mining Claims

Alternative 1

Alternative 2

Proposed Action Alternative

±

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Exst_grnd_wtr_testwell.mxd

Figure 2-2 Alternatives Site Layout

Crescent Dunes

! Solar Energy Project Project Site

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-4 

The site selection process for the proposed project involved screening sites based on the following 

parameters:

• siting area with minimum area of 4 square miles, contiguous in configuration

• solar resource

• distance from TLs and substations

• land ownership

• water data

• topography

• wind data

• airport locations

• highways/roads

• faults

• population centers

• military bases

• BLM SF-299 applications pending

• various environmental constraints

Based on these criteria and BLM land available, the proposed project site was identified. The proposed 

project site is situated on a relatively flat piece of BLM-managed land covering approximately 

2,950 acres. The annual average direct normal solar resource for this site averages 7.4 Watt-hours (Wh) 

per square meter (m2

) per day. NV Energy’s Anaconda Moly Substation is located to the north of the 

proposed project site. Additionally, the proposed project site is not located in Areas of Critical 

Environmental Concern (ACECs) or areas of potential impact to military operations based on the DOD 

online screening tool. Other regional sites had the requisite minimum 4 square miles of contiguous BLM 

lands but were farther away from transmission substations of interest compared to the proposed 

project site. These other regional sites are discussed in more detail in Section 2.6.2, Alternatives 

Considered but Eliminated from Detailed Analysis. 

The project is proposed on lands administered by BLM for several reasons. According to the National 

Renewable Energy Laboratory United States Solar Atlas, the proposed project site maintains high 

insolation levels on a year-round basis, creating ideal conditions for solar energy generation. While 

undeveloped parcels of land exist in Nevada, it can be difficult to acquire parcels from private parties 

and assemble the acreage needed for a CSP plant. If enough private land were acquired, permitting 

issues at a local level within a jurisdiction with no policy on solar development can be difficult. The 

BLM’s general solar policy is to facilitate environmentally responsible commercial development of solar 

energy projects on public lands and to use solar energy systems on BLM facilities where feasible (BLM 

2007). Given the BLM’s solar policy and the advantage of the BLM controlling large areas of land in the 

Southwest, the Proponent is proposing this project on BLM-administered lands as opposed to on private 

lands.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-5 

2.3 Regulatory Framework of Alternatives

BLM is required by NEPA to evaluate not only the Proposed Action, but reasonable alternatives including 

the No Action Alternative (40 CFR § 1502.14). Section 1502.14(a) requires federal agencies to explore a 

reasonable range of alternatives, “and for alternatives that were eliminated from detailed study, briefly 

discuss the reasons for their having been eliminated.” The CEQ guidance concerning NEPA regulations 

adds that reasonable alternatives include those that are “practical or feasible from the technical and 

economic standpoint and using common sense, rather than simply desirable from the standpoint of the 

applicant” (CEQ 1981).

When granting a ROW, FLPMA Title V requires BLM to include in the ROW terms and conditions that 

minimize environmental impacts. Specifically, such terms shall “minimize damage to scenic and esthetic 

values and fish and wildlife habitat and otherwise protect the environment... require compliance with 

applicable air and water quality standards established by or pursuant to applicable federal or state law; 

and ... require compliance with State standards for public health and safety, environmental protection, 

and siting, construction, operation and maintenance of” the ROW (43 U.S.C. § 176(a)) Consideration of 

such terms and conditions will be part of the alternatives analyzed in this Draft EIS.

2.4 Existing Facilities

The only existing facility in the area associated with this proposed project is a groundwater well (BLM 

No. 88177, expires 12/31/2013) that was established in 2010 to substantiate the presence and quantity 

of groundwater in the area in support of permit requests for use of the water and to support evaluating 

environmental impacts (Figure 2-2). The well is approximately 500 feet deep and 6 inches in diameter. 

The well would be used as a water source during construction of the facility. Development of the project 

would include establishing a pump house and associated infrastructure as described later in this 

chapter. Upon completion of construction the well will be plugged and abandoned in accordance with 

provisions contained in Nevada Administrative Code (NAC) 534.4365 (WorleyParsons 2010a). The 

project proposes to construct a new well closer to the center of the project (the power block) as the 

source of water for the proposed operation of the facility. 

2.5 Proposed Action

2.5.1 Project Overview 

The proposed solar power project uses CSP technology, which uses heliostats/reflecting mirrors to 

redirect sunlight on a receiver erected in the center of the solar field (the power tower or central 

receiver). A heat transfer fluid (HTF) is heated as it passes through the receiver and then is circulated 

through a series of heat exchangers to generate high-pressure superheated steam. The steam is then 

used to power a conventional Rankine cycle steam turbine/generator, which produces electricity. The 

exhaust steam from the turbine is condensed and returned via feedwater pumps to the heat 

exchangers, where the high-pressure superheated steam is generated again. Hybrid cooling processes 

are to be used for this project to minimize water use while continuing to maintain efficient power 

generation. Figure 2-3 presents a conceptual diagram of the process.
Source: Solar Reserve

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Concptl_proc_dia.mxd

Figure 2-3 Conceptual Process Diagram

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-7 

Both the central receiver and type of HTF used in the cycle distinguish TSE technology from other CSP 

technologies. The salt is a combination of sodium and potassium nitrate (NaNO3 and KNO3) (similar to 

commercial fertilizer), with a melting temperature of approximately 460°F. It is melted to a liquid form 

and circulated through the tubes in the central receiver, collecting the energy gathered from the sun. 

The heated salt is then routed to an insulated storage tank (hot thermal storage tank) where the energy 

can be stored with minimal energy loss. When electricity is to be generated, the hot salt is routed to the 

heat exchanger (or steam generator) and used to produce steam at high temperature. After exiting the 

steam generator, the salt is sent to a “cold” salt thermal storage tank and the cycle is repeated. 

The other key characteristic of the TSE’s technology is a central tower. The approximately 653-foot-tall 

tower and the size of the solar array or heliostat field have been optimized by TSE in conjunction with 

Rocketdyne to operate at a commercial scale and produce renewable energy at a competitive price. 

A brief summary of the various components and aspects of the proposed project is provided below in 

Section 2.5.2, Project Component Summary, and additional detail on each is provided in Section 2.5.3, 

Project Component Additional Detail. 

2.5.2 Project Component Summary

Generating Facility Components

• Solar Collecting Tower (Figure 2-4) – The concrete tower would be approximately 538 feet tall 

and would house a 100-foot-tall cylindrical solar receiver and a 15-foot maintenance crane. The 

total height would be approximately 653 feet, and would have appropriate lighting for aviation 

safety and lightning protection. 

• Solar Array (Figure 2-5) – The array would consist of a circular field encompassing an area with a 

radius of 4,300 feet (approximately 330 acres) where the heliostats (or mirrors) would be 

located. 

• Power Block (Figure 2-6) - The power block, in a circular area with a radius of about 400 feet, 

would house the central receiver tower, storage tanks, steam turbine, ACC, transformers, heat 

exchangers, power block buildings, and other ancillary equipment.

• Osmosis Water Treatment System and Evaporation Ponds – These facilities would purify the 

groundwater to be used in the production of electricity. 

• Hybrid Cooling System – The system would include an evaporative cooling tower and ACC. 

• Thermal Storage System – The storage system would include two large, insulated storage tanks 

and associated piping for the liquefied salt, one “hot” tank for the storage of the materials prior 

to use in generating the steam, and a “cool” tank for storing salt prior to resending it to the

central tower for heating. 
20’ 95’ 538’

653’

Front Side

Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Diagram_of_tower.mxd

Crescent Dunes Solar Energy Project

Figure 2-4 Central Receiving Tower
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Heliostat.mxd

Crescent Dunes

Solar Energy Project

Figure 2-5 Heliostat
Crescent Dunes

Solar Energy Project

Figure 2-6 Power Block Layout

Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Power_Blk_Layout.mxd

Project Site

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-11

Major Electrical Systems and Equipment

• Generator Step-Up (GSU) Transformer – A GSU Transformer would be designed and installed in 

accordance with current standards and guidelines for a project of this size. The GSU steps up the 

voltage to 230 kV for delivery to the electrical grid.

• Unit Auxiliary Transformers (UATs) – UATs would be used to convert electricity to a lower 

voltage for use in the plant auxiliary systems. 

• Electrical Building – A small building would be constructed in the power block to house 

switchgears, motor controllers, control panels, power and lighting panels, control equipment, a 

battery back-up system, and other similar items. 

• Emergency Power Generator(s) – Diesel-powered generator(s) would be used to provide 

emergency power in addition to the battery back-up system. 

• Lighting Systems – The lighting system for the facility would be limited to those areas required 

for safe operation of the facility. Where lighting is required, it would be designed and installed 

to minimize visual impacts in the region. 

• Communication Systems – The Supervisory Control and Data Acquisition (SCADA) system, which 

controls power generation and transmission processes, would use fiber-optic or copper lines in 

the facility. Other communications during construction and operation would occur through new 

fiber-optic or copper lines installed in the TL corridors, or through a satellite (dish) system.

Transmission Systems and Interconnections

• Transmission Route (Figure 2-7) – The outgoing TL would follow the proposed project site access 

road to Pole Line Road, head north along Pole Line Road to where the Millers to Anaconda TL is 

located, and then parallel the Millers to Anaconda TL to the Anaconda Moly Substation, for a 

distance of approximately 9.5 miles. 

• Interconnections (Figures 2-8, 2-9, and 2-10) – The project would interconnect to the Anaconda 

Moly Substation located approximately 6 miles due north of the generating facility location.

• A temporary 60 kV transmission line for construction power, to be located within the permanent 

ROW. 

Civil/Structural Features

• Access Roads (Figures 2-11 and 2-12) – A paved, two-lane access road would extend 

approximately 1,500 feet from Pole Line Road to the facility. An existing access road that follows 

the Millers to Anaconda TL, would be used for access during construction and for maintenance 

of the TL. Pole Line Road would also be used for access to the TL where the TL would follow Pole 

Line Road.

• Building and Enclosures – A control building, a warehouse, and other buildings would be 

developed within the project area to support operations of the facility.

• Storage Tanks – Tanks would be constructed to store demineralized water, non-demineralized 

water, salt or HTF, lube oil, and other materials for the power block. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-12

• Site Drainage (Figures 2-13 and 2-14) – The heliostat array would be graded such that existing 

drainage patterns will be maintained, but the area in the power block will graded to divert 

stormwater to ditches.
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Transmsn_rte.mxd

Project Site

NEVADA Figure 2-7 Transmission Route

Crescent Dunes Solar Energy Project
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Substn_Layout.mxd

Project Site

NEVADA Figure 2-8 Substation Layout

Crescent Dunes Solar Energy Project
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Pole_elevation.mxd

Figure 2-9 Pole Elevation

Crescent Dunes Solar Energy Project
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Trans_ln_profile.mxd

Figure 2-10 Transmission Line Profile

Crescent Dunes Solar Energy Project
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Road_sections.mxd

Figure 2-11 Road Sections

Crescent Dunes Solar Energy Project
Power 

Block/Receiver

Project

Fenceline

Boundary

Heliostat Field

Temporary

Laydown/Construction

Area

Evaporation Pond

Temporary

Heliostat 

Assemly 

Building

Construction

Parking

Administration/Shop

Building

Crescent Dunes

Solar Energy Project

Figure 2-12 Example Temporary Constuction Areas

Source: Solar Reserve

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Const_Laydown_Areas.mxd

Legend

Administration/Shop Building

Construction Parking

Evaporation Pond

Heliostat Field

Power Block/Receiver

Project Fenceline Boundary

Temporary Heliostat Assembly Building

Temporary Laydown/Construction Area

Project Site

NEVADA
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Prelim_Gradng_drng_des.mxd

Figure 2-13 Preliminary Grading & Drainage Design

for Proposed Project

Crescent Dunes Solar Energy Project

Project Site

NEVADA
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Pwr_blk_grading.mxd

Figure 2-14 Power Block Grading and Drainage

Crescent Dunes Solar Energy Project Project Site

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-21

Construction Activities

• Construction Facilities – Facilities would include an office trailer, material lay down areas

(Figure 2-12), rock processing equipment, portable concrete batch plant, temporary 

aboveground storage tank for diesel fuel, portable sanitary toilets, and a temporary septic 

system. 

• Borrow Site – A material borrow site would be required for extracting aggregate for the 

construction of the access road and the base of the proposed facility. This material would come 

from a borrow site located next to an existing pit used by Nye County Public Works. 

• Construction Process and Conceptual Schedule – Construction is scheduled to last 30 months, 

with teams expected to work 10 hours per day, 5 days per week. Work activities may be up to 

24 hours per day and up to 7 days per week to make up on schedule, perform certain tasks at 

night, and to prepare for specific activities for the next day.

• Construction Work Force and Equipment – The work force would vary throughout the 

construction process, with a maximum expected to reach 400–500 workers. 

Operations and Maintenance

• Operation – The plant would be operated 7 days per week for 10 or more hours per day using a 

workforce of 40–45 full-time employees. The plant would be staffed 24 hours per day.

• Maintenance – Routine inspection and maintenance would be implemented on all components 

of the project.

Water Sources and Water Demand

• Water Demand – During construction, water requirements are estimated at 500 acre-feet per 

year (AFY) for the first year and 150 AFY in the remaining construction years. During operation, 

water demand is not expected to exceed more than 600 AFY. 

• Water Sources – Approximately 854 AFY of existing water rights in the basin would be acquired 

and used for this project, subject to approval from the Nevada Division of Water Resources 

(NDWR). 

Other Components

• Hazardous Materials/Waste Management – Various hazardous materials that are relatively 

standard for industrial facilities would be used during construction and operation of the facility. 

All materials and the resulting wastes (hazardous and non-hazardous) would be stored, used, 

and managed in accordance with local, state, and federal regulations, guidelines, and Best 

Management Practices. 

• Wastewater – Two types of wastewater will be generated, industrial and domestic. The 

industrial wastewater will be generated from the cooling tower blow down and from the first 

pass reverse osmosis system. The wastewater from this process will be piped to three 10-acre 

lined evaporation ponds. Domestic wastewater will be generated from toilets, showers, kitchens 

and sinks, and will be directed to an onsite sanitary septic system and onsite leach field. 

• Fire Protection and Security – A Fire Protection and Prevention Plan will be prepared for 

construction and operation of the facility. The plans will include measures relating to 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-22

safeguarding human life, preventing personnel injury, preservation of property and minimizing 

downtime due to fire or explosion. Fire protection measures will include fire prevention 

methods to prevent the inception of fires. Of concern are adequate exits, fire-safe construction, 

reduction of ignition sources, control of fuel sources, and proper maintenance of fire water 

supply and sprinkler systems.

Decommissioning and Reclamation

• Decommissioning – The project would likely operate for 30 to 50 years, after which time the 

facilities and materials would be removed from the site using Best Management Practices and 

be made available for reuse elsewhere or disposed of in accordance with appropriate 

regulations.

• Reclamation – The area would be recontoured to reflect the preconstruction condition, topsoils 

would be redistributed, and disturbed areas would be revegetated according to a reclamation 

plan established in coordination with BLM (being developed by the proponent). 

2.5.3 Project Component Additional Detail 

The overall site layout for the proposed facility is shown on Figure 2-2. Additional details on the project 

components may be found in the project Plan of Development (TSE 2009). 

2.5.3.1 Generating Facility Components

2.5.3.1.1 Solar Collecting Tower

The solar power tower would be a concrete or steel structure, approximately 538 feet high, which would 

support a cylindrical receiver, approximately 100 feet tall, mounted on the top of the tower (Figure 2-4). 

The receiver would consist of tube panels through which the liquid salt or HTF would flow. Therefore, 

the top of the receiver would be at a height of approximately 638 feet. A maintenance crane would also 

be mounted on top of the receiver, which is expected to be 15 feet tall. Structures in excess of 200 feet 

would require a filing with the Federal Aviation Administration (FAA) to obtain a determination of no 

hazard prior to construction. 

2.5.3.1.2 Heliostat (Mirror) Array

The solar collecting tower/central receiver system would generate electric power from sunlight by 

focusing concentrated solar radiation on a tower-mounted receiver. The system would use thousands of 

sun-tracking mirrors called heliostats, which would be arranged concentrically around the central 

receiver tower and reflect the incident sunlight onto the receiver.

The proposed facility would consist of up to approximately 17,500 heliostats occupying approximately 

1,400 acres. Each heliostat would be approximately 670 square feet (ft2

) in size, yielding a total 

reflecting surface of about 12,000,000 ft2 (1,100,000 m2

). The size and shape of the heliostats are shown 

in Figure 2-5.

The arrangement of the heliostats within the array would be optimized to maximize the amount of solar 

energy that could be collected by the field, and would be arranged to avoid interference among 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-23

heliostats as they track the sun during the day. The heliostats would be arranged in arcs around the 

solar receiver asymmetrically: 

• The first row or line of heliostats would have a radius of approximately 420 feet.

• The longest arc/line of heliostats, with a radius of approximately 5,100 feet, would be in the 

northern section of the heliostat array. This is due to the greater collection efficiency of 

heliostats located north of the receiver tower for sites in the northern hemisphere of the world. 

With the sun predominantly in the southern sky, the cosine effect of incidence and reflection 

angles would be less in the northern heliostats than in the southern ones. The converse—lower 

collection efficiency in the southern section—is also true; therefore, the maximum southern arc 

radius would be the shortest (3,580 feet), and the southern heliostat field would be the 

smallest.

• The eastern sector of the heliostat would be more valuable than the western sector for energy 

collection because afternoon energy collection, during on-peak utility hours, is more valuable 

than morning energy collection, during part-peak or off-peak hours. Therefore, the maximum 

eastern row arc radius may be greater than the maximum western row arc radius.

2.5.3.1.3 Power Block

The power block would include a steam turbine generator (STG), multiple feedwater heaters, steam 

superheaters, lubricating oil system, hydraulic control system, valving, and feedwater pumps. Steam 

would be generated at a temperature of 1,050°F and a pressure of 1,685 absolute pounds per square 

inch (psia) before entering the high-pressure section of the turbine. Steam exiting the high-pressure 

section of the turbine would be reheated to increase its temperature before entering the immediatepressure section of the turbine. Exhaust steam from the turbine would be directed to the cooling 

system. The turbine would drive a generator, which would deliver electrical power via a main step-up 

transformer in the on-site substation to the utility grid. Extraction steam from the steam turbine would 

be used to preheat the feedwater and for deaerating the feedwater.

This high-efficiency turbine would be designed for reliable operation under conditions of daily start up 

and shutdown over the life of the plant. The solar field and power generation equipment may be started 

each morning after sunrise and insolation build-up. The solar field would be shut down in the evening as 

the sun sets, although the integral thermal energy storage system would allow the steam turbine to 

continue operating if there is demand for electricity.

The primary components of the power block include (see Figure 2-6): 

• Solar Steam Generator System – The steam generator would be the core of the steam supply 

system for the power block. The steam generator system would include a preheater, 

evaporator, superheater, reheater, and steam drum. High-pressure feedwater would enter the 

steam generator from the preheaters and would leave as saturated steam that subsequently 

flows to the superheaters.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-24

• Solar Preheater – The solar preheaters would have a shell and tube design. High-pressure 

feedwater would enter the preheaters from the low-pressure feedwater heaters and would 

leave as high-pressure feedwater.

• Evaporator – The evaporator would receive heated, high-pressure water from the preheater and 

would evaporate the water into saturated steam. The evaporator would have a shell and tube 

design.

• Solar Superheaters/Reheaters – The saturated steam would flow to a shell and tube superheater 

to reach the desired steam-turbine temperature and pressure-operating conditions. The 

reheater would receive “cold” outlet steam from the high-pressure turbine stage and reheat the 

steam before being reintroduced into the intermediate-pressure stage of the turbine.

• Steam Turbine – Once the pressurized steam had reached the optimum temperature in the 

superheater, it would flow to the steam turbine, which would extract thermal energy from the 

steam.

• Feedwater Heaters – The feedwater would be heated to the required conditions using 

conventional turbine extraction steam in low-pressure feedwater heaters.

• Deaerator – A direct contact steam deaerator would be included to eliminate dissolved oxygen 

in the condensate and steam.

2.5.3.1.4 Cooling System (Hybrid) 

Heat rejection in the facility would use a hybrid cooling system (wet cooling combined with dry cooling). 

The cooling system would consist of a steam turbine, exhaust transfer duct exiting the steam turbine, 

air-cooled condenser, small evaporative cooler, condensate tank, and condensate pump. The system 

would receive saturated turbine exhaust from the steam turbine, where it would be piped through a 

transfer duct to a finned-tube air-cooled condenser. The air-cooled condenser would blow ambient air 

across a heat-transfer surface area, which cools and condenses steam. The finned tubes are usually 

arranged in the form of an “A-frame” over forced draft fans to reduce land area requirements. The 

evaporative cooling system would take the form of a small cooling tower to augment the heat rejection 

system of the air-cooled condenser. The evaporative cooling system would operate only during periods 

of high electrical demand and would increase the electricity generated and cycle efficiency during 

periods. The condensed steam would be gathered in a condensate tank and be provided to the 

feedwater circuit through a condensate pump. A typical air-cooled condenser can condense steam 

within 30°F to 50°F of the ambient dry-bulb temperature. 

2.5.3.1.5 Thermal Storage System

The thermal storage system would use hot and cold liquid salt tanks to store solar heat energy for later 

steam generation as well as associated pumps and piping. Thermal storage would provide the facility 

with several enhancements. The solar field would be nominally sized to provide excess solar energy to 

the system during summer months, and such sizing would intentionally result in collection of excess 

heat that could not be used instantly by the power block. The thermal storage capability would allow the 

excess heat to be stored until used for power generation. Thermal storage can also extend the 

generation day of TSE power plants. The heated salt can be stored in insulated tanks to provide a steam 

heating source after the sun sets, allowing the facility to more closely satisfy the load demands of the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-25

electricity grid system, which typically peak in the late afternoon and evening hours. The thermal 

storage system would include an auxiliary electric heat source to keep the salt in a molten state through 

protracted maintenance outages.

The thermal storage system would contain two storage tanks—one “cold” tank storing liquid salt at 

550°F and one “hot” tank storing liquid salt at 1,050°F. As the sun rose, cold liquid salt (or HTF) would be 

pumped from the cold liquid salt tank through the tubes inside the receiver. After absorbing energy 

from the concentrated sunlight, the temperature of the HTF would be increased to the design outlet 

temperature of 1,050°F. Part of the heated HTF would then be pumped to a hot liquid salt tank for 

storage and part to a steam generating system that would produce superheated steam for use in the 

conventional Rankine cycle turbine/generator system. After exiting the steam generator, the HTF would 

be returned to the cold tank where it would be stored and eventually reheated in the receiver. This 

arrangement would allow excess heat to be stored for power generation outside of the direct solarheating period of the day. The system would also include piping, valves, pumps, expansion tanks, and

heaters.

The HTF would consist of NaNO3 and KNO3 in a “eutectic” mixture designed to remain liquid or molten 

over a wide temperature range. The HTF mixture has a melting point of 460°F and must be preheated 

and maintained above this minimum temperature in order to remain in liquid form.

2.5.3.2 Major Electrical Systems and Equipment

The bulk of the electric power produced by the facility would be transmitted to the electric grid under 

the control of Sierra Pacific Power Company, doing business as NV Energy. During operation, a small 

amount of electric power would be used to power station auxiliary loads such as pumps and fans, 

control systems, and general facility loads including lighting, heating, air conditioning, heliostat 

movement, and other uses. Additionally, electric power would be used for heat tracing, which would 

provide energy to maintain the salt in a fluid state during protracted maintenance outages. Some power 

would be converted from alternating current (AC) to direct current (DC), which would be used as backup 

power for control systems. 

2.5.3.2.1 Electrical Components

Power would be generated by the STG and stepped up through the GSU transformer to the utility high 

voltage system. The generator would be connected to the step-up transformer by isolated phase bus

duct. A low-side generator breaker would be provided between the generator and the GSU transformer.

2.5.3.2.2 Generator Step-Up Transformers

A two winding, delta-wye GSU transformer would be designed according to the Institute of Electrical and 

Electronics Engineers Standards (IEEE) C57.12.00-2000 and supplied for the STG. The neutral point of 

each high voltage winding would be solidly grounded. The GSU transformer would have metal oxide 

surge arresters adjacent to the high-voltage terminals. 

Accessories would include a local visual annunciator, magnetic liquid-level gauge, pressure-relief device, 

sudden pressure relay, oil preservation device, valves for top and bottom filter press connections, 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-26

drain/sampling valves, grounding pads, bushing-mounted current transformers, combustible gas 

detector, on-line dissolved gas/water monitor with 4–20 milliamp signal out to the controller, and hot 

spot winding temperature elements.

The GSU would include manual de-energized tap changers located in the high-voltage windings with 

taps ranging from 5 percent above normal to 5 percent below normal in 2.5 percent increments. GSU 

transformer auxiliaries would be powered from two 480-volt (V), three-phase, three-wire sources for 

each transformer. Each power supply would be fed from separate sources and routed in separate 

conduits.

2.5.3.2.3 Unit Auxiliary Transformers

One or more two winding, delta-wye UATs would be designed according to the IEEE Standards 

C57.12.00-2000 and supplied for 4,160 V service. The UAT would be rated to supply facility startup and 

maximum operating power requirements. A system calculation showing all connected equipment loads 

for the UAT would be used to determine the requirements prior to procurement of the UAT. The neutral 

point of the UAT low voltage winding would be 1,000-amp, low-resistance grounded.

2.5.3.2.4 Electrical Building 

A plant electrical building would house the 4,160 V switchgear, 4,160 V motor controllers, low voltage 

switchgear, low voltage motor control centers, control panels, power and lighting panels, 

uninterruptible power supply (UPS), DC station batteries, DC switchboard, other miscellaneous 

equipment, steam turbine control equipment, and the control Input/Output (I/O) cabinets. The 

electrical building would be a single-story facility, approximately 4,000 ft2 in size, 94 feet long and 

34 feet wide. 

2.5.3.2.5 Medium Voltage Switchgear

The medium voltage switchgear would be single-ended, rated 4,160 V nominal, three-phase, three-wire 

with ratings not to exceed 3,000 amps, continuous, and the calculated fault current duty. The medium 

voltage switchgear would receive power from the UAT through non-segregated phase bus duct. 

The medium voltage switchgear lineups would be located indoors, would use vacuum interrupters, and 

would be rated to allow continuous distribution of the full auxiliary load. Each lineup would contain 

auxiliary power metering and voltage transformers, a main incoming breaker, and feeder breakers as 

necessary to distribute the load. All medium voltage breakers would be electrically operated from the 

control system and equipped with a stored energy mechanism. Breakers would be provided with remote 

racking mechanisms.

2.5.3.2.6 Emergency Power Systems

The emergency power for the facility switchyard and many other plant critical loads would be supplied 

by the 125-V DC station battery system. Additionally, emergency generator(s) (diesel) would be 

employed to provide emergency power to the facility.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-27

2.5.3.2.7 Lighting Systems

The facility’s lighting system would provide operation and maintenance personnel with illumination for 

both normal and emergency conditions. Lighting would be designed to minimize light pollution by using 

sensor lights and directional lighting in cases where this would not compromise safety or security. 

Although the proposed project site is in a remote area, lighting on-site would be limited to areas 

required for safety and would be shielded from public view to the extent possible. Outdoor lighting 

would be photocell controlled through contacts that control the outdoor lighting. 

Lighting will not be provided for the solar field, but is expected to be provided in the following areas:

• building interior equipment, office, control, maintenance, and warehouse

• tower

• building exterior entrances

• outdoor equipment within the power block and tank area

• power transformers

• power block roadway

• parking areas within the power block area

• tank area

• entrance gate

• water treatment area

• ACC

2.5.3.2.8 Communication Systems

Mirror tracking and plant process control would be accomplished by a Distributed Control System (DCS), 

which would interface Programmable Logic Controllers (PLC), field instrumentation, a meteorological 

station, and communications devices designed for site monitoring, control, and historical trending of the 

solar power plant.

All data collected from the field would be transmitted to the site control room via a fiber or copper 

communications infrastructure. The control room would also contain a router for the point of 

connection to a T1 line or equivalent as well as phone lines for communication to the outside.

During construction, communication systems would be either hard wire or satellite communication 

system (dish). For the plant operations, it is expected that a hardwired communication source would be 

designed and installed to support the project. The hardwired communication line would be routed along 

the existing TL near the plant, and the new transmission corridor along Pole Line Road. This line would 

be designed and installed in cooperation with the applicable communications provider.

Communications would be provided by satellite if a hardwired communication line cannot be brought to 

the site along existing overhead power line structures. Additionally, a communication line would be 

constructed on the generation-tie line transmission poles between the proposed project site and the 

Anaconda Moly Substation. The purpose of this fiber optics line would be to provide NV Energy the 

ability to “communicate” between the Anaconda Moly Substation and the facilities on-site. Additionally, 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-28

it is anticipated that a new communications dish would need to be installed on an existing tower at the 

Millers Substation, located southwest of the proposed project site. The purpose of this new dish would 

be to provide a second means of communication between the Anaconda Moly Substation and the 

proposed project site.

2.5.3.3 Construction Power Supply

A 60 kV power line is located adjacent to and west of the existing Millers to Anaconda TL. This power 

line is owned and operated by NV Energy and would be used to provide a source of temporary power for 

construction and for a backup to auxiliary plant/house power load requirements. A separate overhead 

power line would be installed adjacent to the project TL to deliver power from this 60 kV line to the 

plant site. Transformers would be installed to step down the power to the voltage necessary for use. 

2.5.3.4 Transmission Systems and Interconnection

2.5.3.4.1 Interconnection

The proposed project is planned to interconnect to the existing NV Energy Anaconda Moly Substation 

(ROW 033242) that is located north of the proposed project site. In this case, a new TL would be 

constructed between the proposed project site and the substation. The proposed route for the new TL

would follow the site access road to Pole Line Road, head north along Pole Line Road to where the 

existing Millers to Anaconda TL is located, and then parallel the Millers to Anaconda TL to the Anaconda 

Moly Substation, to interconnect with the electricity grid (see Figures 2-7 and 2-8).

Therefore, for a majority of the distance between the proposed project site and the Anaconda Moly 

Substation, the new TL would parallel the existing TL (ROW 033242) (see Figure 2-7). 

The facility switchyard and the TL between the facility switchyard and electrical system interconnection 

would be engineered, procured, and constructed as part of this project. The high voltage interconnect 

from the facility to the electric utility would be made via an SF6-insulated, high-voltage breaker with a 

single-circuit, overhead line from the facility switchyard to the utility substation.

The anticipated pole configuration used for the new TL would be a steel “mono” pole or H-frame; a 

monopole structure is shown on Figure 2-9. The point of interconnection (POI) is at a “termination pole 

structure” located approximately 500 feet south of the existing Anaconda Moly Substation at N38o 19' 

20.281" and W117o 20' 10.143". A preliminary layout representing the location and components 

involved in the interconnection is shown in Figure 2-8. 

The Proponent is in discussions with NV Energy regarding construction and ownership of the new TL. At 

this time, it is expected that the new TL would be owned by the Proponent up to the POI, and NV Energy 

would own interconnection facilities between the POI and the substation. 

2.5.3.4.2 Potential Transmission Route

The TL route to the NV Energy Anaconda Moly Substation is shown in Figure 2-7. The interconnection 

line would exit the power block and follow the access road to Pole Line Road. At this location, it would

parallel Pole Line Road to the point where the existing Millers to Anaconda TL is located. The line would
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-29

then turn northeast and follow the existing TL to the existing Anaconda Moly Substation. A typical TL 

profile is illustrated on Figure 2-10. 

2.5.3.5 Civil/Structural Features

2.5.3.5.1 Access Roads

Access to the proposed project site would be provided from Pole Line Road. Pole Line Road is a Nye 

County owned and maintained road and is asphalt surfaced from its intersection with SH 6/95 to north 

of the proposed project site. A short section of Pole Line Road from its intersection with SH 95 to a 

location south of the site is in Esmeralda County. This section of Pole Line Road, although located in 

Esmeralda County, is maintained by Nye County through the terms of a formal agreement. Pole Line 

Road is anticipated to continue to be maintained by Nye County. 

The access road to the proposed project site would be connected directly to Pole Line Road near the 

southwestern corner of the site (see Figure 2-2). The paved surface of this road would be a two-lane 

road, constructed with adequate width for two directions of travel with a minimum of 2-foot shoulders 

on each side of the road. This paved road would be extended to provide access to the power block. All 

roads within the power block would be surfaced with asphalt. The entry gate location would be located 

a short distance east of Pole Line Road in order to eliminate a backup queue on Pole Line Road. The 

proposed minimum road width is 24 feet for the main access road and 20 feet for the internal (within 

fenced area) perimeter road—see Figure 2-11. 

The predominant traffic to/from the proposed project site would occur during construction and would 

primarily be construction crew commuter traffic. Vehicle trips to and from the site would use SH 95 to 

access the site from the north (Reno) and south (Las Vegas), and SH 6 to SH 95 may be used for traffic 

coming from east of the town of Tonopah. The traffic associated with the project is not expected to 

produce permanent traffic impacts to SH 95 because the peak traffic is expected to be approximately 

90 trucks per day and 400 cars per day and would be temporary. The proposed project site would 

receive deliveries of materials from local, regional, and possibly international points of origin including 

bulk commodity materials, engineered equipment and machinery, and general materials of 

construction. The proposed project site is not currently served by rail, so materials would be transported 

to the site by truck, including those materials brought in to the region by rail or ship. These materials 

would be loaded onto trucks at various ports and depots for delivery to site.

Heavy and oversize loads would be delivered using trucks and trailers equipped to handle specialized 

loads. Oversized loads would be individually permitted to transport each such load to the site. Heavy 

and oversized loads for the project are typical of a common power plant or process facility and may 

include items such as the step-up transformer, the solar receiver panels, steam turbine, generator, and 

tanks. 

Additionally, unpaved roads would be constructed from the power block to the eastern and southern 

edges of the solar field. The unpaved solar field perimeter road would be constructed around the solar 

field, and would be surfaced with rock or treated native soil. A typical section of this road is shown on 

Figure 2-11.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-30

2.5.3.5.2 Building and Enclosures

The following buildings and enclosures are planned as part of the project, and their locations are 

described below:

• Steam Generator Area Building (approximately 30,000 ft2

). This structure would be located 

between the HTF storage tanks within the power block. The building would provide structural 

support and protection for the equipment associated with the heat exchange process.

• Steam Turbine Area/Enclosure (not considered a building). This structure would house the STG 

and associated equipment, and would be located within the power block. The STG may be 

enclosed in a building for protection, or it may be located outdoors.

• Electrical Building (approximately 2,500 ft2

). This structure would be located within the power 

block area and would house the switchgear, motor control centers, battery power supply, and 

other primary plant electrical components.

• Administration/Maintenance Building (approximately 10,000 ft2). This building would serve as 

the center for support staff for the project during operations. This facility is planned to be 

located outside the heliostat field, near the access road.

• Heliostat Assembly Building (approximately 80,000 ft2

). This building would be used as a 

protected environment for the assembly/construction of heliostats during construction of the 

plant. It would be converted to other uses upon completion of project construction.

• Permanent Warehouse (approximately 6,000 ft2). This building would provide permanent 

warehouse space for the facility and would be located near the administrative/maintenance 

building. 

• Control Room Building (approximately 6,000 ft2). This building would be located within the 

power block and would provide the control room functions for the project. It would be located 

west of the Steam Turbine Area.

• Building Sanitation Facilities. The administrative/maintenance building located on the perimeter 

of the heliostat field and the control building located within the power block would each be 

served by a permanent septic system (tank and leach field).

• Water Treatment Building (approximately 12,000 ft2). The building would house the water 

treatment facilities.

2.5.3.5.3 Material Storage

On-site storage for spare field and power block components would be required for maintenance uses. In 

addition, on-site storage facilities for water pretreatment chemicals, cooling water treatment chemicals, 

and boiler water treatment chemicals would be necessary. The HTF material (salt) would be delivered to 

the project as dry, solid pellets. The material would be delivered in 1-ton “super sacks,” which can be 

stored on-site until melted for use in the plant process. The salt must be heated until fluid for use in the 

system, and would be stored within the lay down area of the site until it were heated, liquefied, and 

sent to the storage tanks. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-31

Potentially polluting substances would be managed in accordance with all applicable laws, ordinances, 

regulations, and standards to protect worker health, prevent leaks and spills, and protect stormwater 

quality as discussed further in Section 2.5.8, Hazardous Materials Management. 

Construction lay down and storage would occur throughout the permanently disturbed areas. The 

power block and the heliostat field immediately adjacent to the power block would be used for lay down 

and storage of the power block components. Equipment would be stored within the power block, and 

would include cranes, loaders, fork lifts, generators, boom trucks, water trucks, etc. The earthmoving 

equipment would be stored in a central location each night near the area where the work is being 

undertaken, or near the western side of the heliostat field, where all the equipment can be most easily

fueled. All these locations would be within the perimeter of the permanent project facilities. 

Additionally, a small temporary lay down area, worker parking area, and construction trailer area would 

be used during facility construction. The areas are shown in Figure 2-12. The features shown may be 

relocated during final project planning but would remain within the total area identified. The heliostat 

assembly building may be constructed permanently to be used during the life of the project, or may be 

removed after construction. Areas along the TL corridor and near the substation (less than 5 acres) may 

be used for storage of power poles during construction. These areas would remain within the area 

identified for temporary disturbance.

2.5.3.5.4 Storage Tanks

The following storage tanks would be located on-site: 

• Demineralized Water Storage Tank: One demineralized water storage tank would be 

constructed to store demineralized water for use as mirror wash water, steam cycle make up, 

and for use in the hybrid cooling system.

• Fire/Service Water Storage Tank: One fire/service water tank would be constructed to store 

water for fire protection, service water needs, and for raw water storage prior to treatment.

• HTF Storage Tanks: Two tanks would be constructed to contain the HTF. One would house the 

hot HTF (1,050°F), and the other would house the cold HTF (550°F).

• Lube oil and hydraulic oil storage tanks would be associated with the STG.

• Additional ancillary tanks, including aboveground diesel tanks, would be on-site for a variety of 

liquids within the power block area.

2.5.3.5.5 Pipelines

Project operational water would be obtained from on-site wells; therefore, an off-site pipeline would 

not be required. The CSP technology proposed for the project would not require a natural gas source.

During construction of the project, there would be a high water demand for soil moisture conditioning 

and dust control, and on-site wells would provide construction water. Water demand and sources are 

further discussed in Section 2.5.6, Water Demand and Source. 

2.5.3.5.6 Site Drainage

The proposed project site is located on a portion of the Smoky Valley that slopes to the west at 

approximately 2 percent. The stormwater drainage system would be designed to allow the storm flow to 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-32

follow its preexisting drainage paths. Currently, storm flows drain from the San Antonio Mountains to 

the east and infiltrate across the nearly flat site on their way to Peavine Creek. Within the proposed 

project site, the storm flows broaden out and do not follow individual drainage courses. This allows 

increased infiltration as the flows move to the west toward Peavine Creek. Near the eastern end of the 

facility, two gentle drainage paths are visible in the topographic survey of the site. These would be 

maintained, and the flows would be allowed to continue to fan out across the heliostat field or may be 

routed around the exterior of the heliostat field.

The grading plan within the heliostat field would be such that storm flows follow preexisting paths. The 

majority of the proposed project site, within the perimeter fence, would not be graded but would be 

smoothed to allow truck access throughout heliostat field.

Preliminary storm drainage for the overall facility can be seen on the grading plan included as 

Figure 2-13. More details of the power block are shown in Figure 2-14. Small ditches would be 

constructed along roadways, as necessary, to provide a path of travel for water and to allow infiltration 

of rainfall.

Grading near the power block, to the east side or uphill side of the power block, would include a small 

berm and ditch to divert upstream flows around the power block. Additionally, the finished floor 

elevations of buildings and other structures subject to damage from stormwater would be built a 

minimum of 12 inches above anticipated 100-year storm levels in accordance with all applicable laws, 

ordinances, regulations, and standards. 

Preliminary hydrology calculations were performed using the TR-55 (SCS Method). It is proposed that 

the stormwater drainage system be designed using the Natural Resource Conservation Service (NRCS) 

method (TR-55) to determine the amount of rainfall during a specific rainfall event, and in accordance 

with the Nye County stormwater design requirements. A detailed technical drainage study may have to 

be submitted for approval to Nye County’s Tonopah Public Works Office for construction of the facility.

All surface water runoff during and after construction would be controlled in accordance with the 

requirements of the National Pollutant Discharge Elimination System (NPDES) stormwater runoff permit 

and all other applicable laws, ordinances, regulations, and standards.

The power island would be graded such that all rainfall within the power island would be directed to the 

containment ponds adjacent to the on-site salt tanks or to the western heliostat field and would be 

allowed to infiltrate. Pipe culverts would be used, as required, where storm channels cross roads.

2.5.3.5.7 Evaporation Ponds

There are two types of wastewater generated at the Project; industrial and domestic. In the industrial 

process, wastewater is generated from the cooling tower blow down, and occasionally from the first 

pass reverse osmosis system (pre-treatment of groundwater) and the steam cycle blow down (in 

summer months, these streams are diverted into the cooling tower and evaporated). Wastewater from 

these industrial processes will be piped to three 10-acre evaporation ponds (total combined pond top 

area of up to 30 acres) for disposal. Evaporations ponds would be adaptively managed to minimize risks 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-33

to wildlife near the site. When ponds are filled with water, a porous screen would cover the entire pond 

so that wildlife would not be attracted to the water surface. Additional information on the design and 

operation of the evaporation ponds is provided in the Wastewater Plan (WorleyParsons 2010b).

The expected chemistry of the wastewater discharge is provided in Chapter 4. The concentrations of 

chemical constituents in the wastewater discharge are compared to Toxicity Characteristic Leaching 

Procedure (TCLP) values as reported in the Code of Federal Regulations 40 CFR 261 (Title 40, Part 261). 

None of the predicted chemical constituents in the wastewater has TCLP limits, and therefore the 

wastewater is not considered a hazardous waste under Federal regulations.

In the domestic process, all wastewater generated from toilets, showers, kitchens and sinks will be 

directed into an onsite sanitary septic system and on-site leach field.

2.5.4 Construction Activities

2.5.4.1 Temporary Construction Facilities

The project construction contractor would mobilize and develop temporary construction facilities and

lay down areas adjacent to the power block and outside the heliostat field (see Figure 2-12). Once a final 

design has been established, the contractor would prepare site maps showing the construction project 

in detail. Temporary construction facilities would include construction staging areas; employee parking 

areas; temporary shop buildings; an office trailer with electrical, telephone, and Internet service; 

temporary sanitary facilities; a temporary guard shack; and on-site dumpsters. Additionally, rock 

processing equipment and a portable batch plant would be mobilized for site development. A temporary 

concrete batch plant would be mobilized for use during project execution. The temporary batch plant 

would include cement storage and a batching operation where the cement, water, and aggregate could 

be proportioned and mixed. This facility would be located in the temporary lay down area or in the 

heliostat field, just east of the temporary lay down area. The majority of these temporary facilities 

would be located within the construction logistics/lay down/parking areas and/or within the heliostat 

field (see Figure 2-12). 

Construction equipment would be staged near the location of active work, primarily within the power 

block near the center of the heliostat field. Additionally, temporary sanitary facilities would be located 

throughout the proposed project site for use by construction personnel; they would be sized and 

located in accordance with Occupational Safety and Health Administration (OSHA) requirements. 

Several areas internal to the solar field would also be set up to temporarily store materials for 

construction of the power block facilities, for construction of the heliostats, and for temporary storage 

and heat conditioning of solid HTF. This would locate material closer to the point of installation.

A geotechnical investigation was performed in April 2010 of an area located next to an existing borrow 

site located along Pole Line Road, near Peavine Creek. The existing pit is used by Nye County Public 

Works. The investigation found that the aggregate is suitable for use for project construction. The total 

area needed to supply an adequate amount of material is 40 acres. A Mineral Materials Negotiated Sale 

(BLM Form 3600-9) has been submitted to BLM for the 40-acre site, located immediately north of the 

Nye County pit. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-34

All on-site construction operations can be completed within the limits of the SF-299 filed for the 

proposed project, and within the two additional SF-299 applications previously discussed (one for 

transmission and one for gravel/aggregate). 

A temporary 10,000 gallon (gal) aboveground storage tank would be used to supply diesel fuel during 

facility construction. This would be located in the temporary lay down area and would be double walled, 

or located within a containment area in accordance with applicable regulations.

The sanitary needs of the construction work force within the heliostats and power block area would be 

met with the use of portable toilets. The temporary construction trailers would use a temporary septic 

system that would be abandoned upon completion of construction.

2.5.4.2 Construction Process and Conceptual Schedule

Construction of the generating facility, from site preparation and grading to commercial operation, 

would be expected to take approximately 30 months. Typically, construction would be scheduled to 

occur between 5 a.m. and 7 p.m. on weekdays and Saturdays (approximately 14 hours per day, 6 days 

per week). Additional hours may be necessary to make up schedule deficiencies or to complete critical 

construction activities (e.g., pouring of concrete at night during hot weather, working around timecritical 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. The items of work that 

may occur 24 hours per day would include, but are not limited to, placing and finishing concrete 

(because of cooler nighttime temperatures), welding on critical pipe systems (these may be critical path 

items and need to be expedited), radiation testing of the welds on certain pipes (completed when staff 

is vacated from the area), electrical terminations, DCS wiring and programming, heliostat assembly (if 

this seems to be falling behind schedule), and preparation for start-up testing. Because this is a solar 

plant, testing of the facility requires adequate energy supply (i.e., the sun). Therefore, preparations may 

take place overnight to ready the facility for start-up tests the following day, when the sun would 

provide the energy to power the start-up testing.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-35

Table 2-1. Conceptual project schedule, with activities representative of typical TSE projects

Activity Time Frame

Start construction. Month 1

Begin mobilization. Month 1

Delineate and mark the boundaries of the construction zone. Month 1

Stabilize construction entrance/exit and roadway. Install tire wash. Month 1

Establish parking and staging areas for vehicle and equipment storage and maintenance. Month 1

Establish lay down area(s) for materials storage and staging. Month 1

Establish concrete washout area. Month 1

Clear and grub, strip topsoil. Months 1–2 

Install certified weed-free fiber rolls or silt fence at the base of slopes adjacent to 

delineated sensitive areas (e.g., wetlands), if any. Months 1–2 

Construct stormwater infiltration/evaporation area. Months 3–6 

Assemble and erect heliostats. Months 10–20

Power block construction. Months 6–24

Construct reinforced concrete foundations. Months 6–24

Construction administrative/warehouse building. Months 20–22

Final stabilization of site. Month 27

Commission and testing. Months 27–30

2.5.4.3 Construction Work Force and Equipment

The construction work force would consist of approximately 400 to 500 personnel at peak for 

construction, including supervisors and management personnel, with an average of approximately 

250 crewmembers on-site at any given time. Project construction would require additional support staff, 

including construction inspectors, surveyors, project managers, and environmental inspectors.

Prior to commencing construction, crews would mobilize to the site. During this time, equipment and 

construction materials would be transported to the designated construction staging areas, and trailers 

and temporary shop buildings would be established. In addition, personnel would receive appropriate 

safety and environmental training. Also, signs may be erected at this time to designate approved access, 

fueling, smoking, concrete washout, and exclusion areas. Table 2-2 outlines the construction process.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-36

Table 2-2. Conceptual construction process

Construction 

Phase Description Approximate Number and Type of Construction Equipment and Vehicles

Rough Grading

Grubbing, clearing, and bulk grading, 

including approximately 500,000 cubic 

yards of cut and compacted fill

Approximately five scrapers, two compactors, three 

graders, two loaders, four dozers, five water trucks, 

and three water pulls

Finish Grading

Final grading to finish grade at a rate of 

approximately 960,000 square feet per 

day (22 acres)

Approximately two scrapers, three graders, one 

dozer, four water trucks

Roads, 

Foundations, 

Flatwork, and 

Site Utilities

Construction of roads, excavation and 

construction of foundations for heliostats 

and utilities

Approximately 20 to 40 pieces of equipment would 

be present at any one time, including concrete 

trucks, concrete pumps, backhoes, excavators, 

loaders, graders, foundation drills, paving 

machines, drum rollers, fork lifts, tractors, dump 

trucks, small cranes, and additional support 

vehicles

Heliostat 

Assembly and 

Deployment

Field assembly of heliostats in temporary 

shop buildings constructed at the site, 

installation of assemblies on cast-in-place 

piers or other foundations

Approximately eight to ten crews, each with one or 

two pieces of equipment including small cranes, 

forklifts, welding machines, trucks, and tractors

Power Block 

Construction 

Construction of foundations, structural 

frames and buildings, installation of 

utilities and equipment including the 

steam turbine generator, condenser, 

pumps, buildings, air cooled condenser

cooling structure, TES tanks, and central

receiver tower

An average of 12 to 18 pieces of equipment would 

be used for power block construction over the 

duration of the project, with more equipment being 

used during the early stages of foundation 

construction and frame erection. Equipment would

include backhoes, excavators, foundation drills, 

concrete trucks, concrete pumps, forklifts, boom 

trucks, lifts, cranes, welders, trucks, and other 

support vehicles

Liquid Salt 

Preparation Melting of the delivered dry salt product Temporary propane, electric, or gas (propane) fired 

auxiliary boiler, forklifts, loaders, and trucks

2.5.5 Operations and Maintenance 

2.5.5.1 Overview

Management, engineering, administrative, skilled workers, and operators would serve the solar plant. 

The plant is expected to employ up to 40–50 full-time employees during operation. The facility may be 

operated up to 7 days per week, and 10 or more hours per day. The facility would be staffed 24 hours 

per day.

The facility would be expected to have an annual operational availability of up to 92 to 95 percent (of no 

cloudy, daylight hours). The facility may be operated in one of the following modes:

• The facility could be operated up to its maximum output as dictated by the available solar 

insolation and the available thermal storage, for as many hours per year as possible.

• The facility would be placed in standby mode every night when the solar insolation or thermal 

energy storage level drops to a point that results in the STG dropping below its minimum design 

low-load.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-37

• A full shutdown would occur if required by equipment malfunction, TL disconnect, or scheduled 

maintenance.

2.5.5.2 Maintenance

Long-term operation of the facility would include periodic maintenance and overhaul of all balance-ofplant and solar facility equipment such as the STG, pumps, piping, etc., in accordance with manufacturer 

recommended schedules. Periodic cleaning of the heliostats with demineralized water would be 

necessary to maintain the desired mirror reflectivity.

Routine inspections of the substation and electric TL would be conducted by certified site personnel on 

a monthly basis or as needed under emergency conditions. All of the substation structures would be 

inspected from the ground on an annual basis for corrosion, misalignment, and foundation condition. 

Ground inspection would include the inspection of hardware, insulator keys, and conductors.

Regular inspection of electric lines, support systems, and instrumentation and controls is critical for the 

safe, efficient, and economical operation of the project. Various inspection processes, including aerial 

inspection, ground inspection, and climbing may be conducted. Ground inspection includes checking of 

the hardware, insulators, and conductors for corrosion, breaks, broken insulators, and failing splices. 

The frequency of inspection may vary depending on factors such as the age of the system, structure 

type, and vegetation conditions.

2.5.5.3 Work Force and Equipment

It is planned that plant personnel would be on-site in two 12-hour shifts or three 8-hour shifts, 7 days 

per week to ensure that the facility is staffed at all times. A full-time staff would be required for 

operations and maintenance of the facility, anticipated to include one operator for every 12-hour 

rotating shift, four relief operators, four maintenance technicians, four mirror washers, one to two 

process/performance engineers, one maintenance manager, and five to seven administrative staff 

members per day. An additional part-time staff of 5 to 15 subcontractor personnel would be on-site 

daily to conduct occasional maintenance of the facility, including cleaning or repairing equipment; 

system testing; removing, repairing, and/or installing insulation before and after maintenance; scaffold 

installation and removal; and personnel facility-related activities.

2.5.6 Water Demand and Sources 

2.5.6.1 Water Sources

The proposed source of water would be groundwater, extracted through one of two on-site wells. Two 

wells, one for primary and one for back-up, would be drilled within the project area. Well data from the 

NDWR well log database and the U.S. Geological Survey National Water Information System indicate the 

depth to water in the vicinity of the proposed project site ranges from approximately 55 to 104 feet 

below ground surface (bgs) and well depths range from approximately 100 to 200 feet bgs. This 

information was confirmed by a test well drilled adjacent to the proposed project area to substantiate 

water availability. Wells in the vicinity of the proposed project site were installed in unconsolidated 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-38

alluvial materials, and similar materials were observed in the test well on-site. Only the test well is 

within the proposed project site.

The proposed project site is located within the southeastern portion of the Tonopah Flat subarea of the 

Big Smoky Valley groundwater basin, which is within the Central Hydrologic Region of Nevada 

(Figure 2-15). The Tonopah Flat subarea is a designated basin, and the southern half of the proposed 

project site (Township 4 North, Range 41 East, Sections 2, 3, and 10–15) is located in a preferred use 

area.

Limited data are available on groundwater quality in the basin. The general quality of groundwater in 

Nye County is suitable to marginally suitable, with total dissolved solids concentrations exceeding the 

state or federal general drinking water standards in portions of the Big Smoky Valley groundwater basin 

(Buqo 2004). Testing of water collected from the test wells drilled on-site are consistent with the 

previous data.

For operational use, water would be pumped into a raw water storage tank. Raw water would be 

treated through a reverse osmosis water treatment facility and converted to demineralized water for 

use in the steam cycle, for mirror washing, and for use in the hybrid cooling system. The need for 

additional pretreatment such as water softening or ion exchange, if any, would be determined based on 

analytical data obtained during the groundwater investigation. 

2.5.6.2 Water Demand

Water would be necessary for both construction and operation of the project. During construction, 

water would be required for soil moisture conditioning during the earthmoving activities and for dust 

control. Based on the expected soil conditions (existing moisture content and the optimal moisture of 

the soil necessary to achieve proper compaction), approximately 500 AF of water likely would be 

needed the first year of construction, when the major earthwork occurs. Approximately 150 AF of water 

would be needed each subsequent year of construction for ongoing dust control during construction 

and moisture conditioning of soils for ongoing backfilling operations.
Nevada Test and Training Range 

Nellis AFB

To Las Vegas

Proposed Site/ To Ely

Alternatives

Anaconda Substation

Borrow Pit

Gabbs Valley

Big Smoky Valley

Big Smoky Valley

Ralston Valley

Hot Creek

Stone Cabin Valley

Smith Creek

Ione Valley

Dixie Valley Kobeh Valley

Monitor Valley

Monitor Valley

Fish Lake Valley

Cactus Flat

Fairview Valley

Edwards Creek Valley

Clayton Valley

Alkali Spring Valley

Columbus Salt Marsh Valley

Soda Spring Valley

Grass Valley

Big Smoky Valley

Gold Flat

Upper Reese River Valley

Little Fish Lake Valley

Antelope Valley

Monte Cristo Valley

Eastgate Valley Area

Teels Marsh Valley

Carson Desert

Rhodes Salt Marsh Valley

Cowkick Valley

Antelope Valley

Garfield Flat

Soda Spring Valley

Stonewall Flat

Stingaree Valley

Ralston Valley

Queen Valley

Walker Lake Valley

Rawhide Flats

Little Smoky Valley

0 10 20

Miles

Legend

Borrow Pit

Alternative Area

Proposed Site

Big Smoky Valley

Tonopah Flat sub area

Alternate 1

Alternate 2

Proposed Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Big_smky_vlly_gwBasin.mxd

Tonopah

Project Site

NEVADA Figure 2-15 Big Smoky Valley

Groundwater Basin

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-40

Water needs of the operating plant would include three primary uses:

• steam cycle makeup water – estimated at 100 AFY

• mirror wash water – estimated at 70 AFY

• hybrid cooling system augmentation – estimated at 430 AFY

Incidental use that would be included in the 600 AF:

• potable water – estimated at less than 3 AFY

Although the steam cycle is a “closed system,” some water would be lost during operational steam blow 

down. The addition of “makeup water” would be required throughout the operating time frame to 

compensate for this loss. 

The heliostat mirrors’ reflectivity would decrease in efficiency and, therefore, the ability to generate 

electricity would decrease as the mirrors collect dust and other particles. A mirror wash program would 

be implemented to wash the mirrors on a continual basis. This program may run up to 7 days or nights 

per week.

During periods of high temperatures or electrical demand, the cooling system would be operated in 

“hybrid” mode. The “hybrid” mode of operation would include heat rejection through the ACC as well as 

heat rejection through the small evaporative cooler (cooling tower). The hybrid mode of operation 

would increase the efficiency of the plant and allow for the production of additional electricity during 

these times when electricity is in highest demand. 

Potable water would be used for sanitary purposes in the facilities, as well as drinking water. Water 

would be stored on-site and used for fire protection. 

2.5.7 Land Ownership and Mining Claims

The proposed project site is located on unincorporated lands administered by BLM within Nye County, 

Nevada, and guided by the Tonopah RMP (BLM 1997). Based on a review of the 1997 RMP and other 

BLM records, the proposed project site is not within wild horse and burro herd management area 

boundaries, ROW avoidance areas, land withdrawals, ACECs, fluid mineral potential area, mineral 

leasing restriction areas, or fire management zones. The area is within the relatively large San Antone 

Grazing Allotment. During the analysis, three mining claims had been filed (April 2010) in Section 34 of

the TSE ROW application area. Several other existing mining exist along the transmission route (Figure 2-

1)

2.5.8 Hazardous Materials Management

A variety of chemicals and hazardous substances would be stored and used during construction and 

operation of the project. The storage, handling, and use of all chemicals would be conducted in 

accordance with applicable laws, ordinances, and regulations (see Table 2-3).
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-41

Table 2-3. Hazardous waste laws, ordinances, and regulations

Laws, Ordinances, and Regulations Applicability

Federal

Comprehensive Environmental Response, 

Compensation, and Liability Act, 42 United States Code 

(USC) § 9601 et seq., 40 Code of Federal Regulations 

(CFR) Part 302, as amended by the Superfund 

Amendments and Reauthorization Act of 1986 

Requires notification to various agencies when there is 

a release of hazardous substances from a facility

Emergency Planning and Community Right to Know Act, 

42 USC § 11001 et seq., 40 CFR Parts 350, 355, and 370

Requires inventory reporting, planning, and reporting 

for hazardous and acutely hazardous materials

Occupational Safety and Health Standards, 

29 USC Section 65129; 29 CFR 1910 et seq., 

and Safety and Health Regulations for Construction, 

29 CFR 1926 et seq. 

Specifies standards for hazardous materials storage, 

handling, and worker protection in emergencies

Oil Pollution Prevention, 40 CFR 112 Requires the preparation of a Spill Prevention Control 

and Countermeasures Plan

Chemical Facility Anti-Terrorism Standard, 6 CFR Part 27 Requires facilities that use or store certain hazardous

materials to submit information to the Department of

Homeland Security so that a vulnerability assessment 

can be conducted to determine what security measures 

should be implemented

State

Stormwater Pollution Prevention, General 

Permit NVR100000

Requires the preparation of a Stormwater Pollution

Prevention Plan for construction and industrial activities

Local

International Fire Code, Nye County Code 

Section 15.16.010

Adopts the International Fire Code, 2003 Edition, into 

Nye County regulations

Industry Codes and Standards

American Society of Mechanical Engineers,

American National Standards Institute, and

American Society of Testing Materials 

Sets forth standards for power plant design, including 

mechanical systems, electrical, and piping

Uniform Fire Code, Articles 79, 80, and others Sets forth requirements for the storage and handling of 

hazardous materials

National Fire Protection Agency Establishes fire prevention standards and guidelines

The following project planning documents would specify procedures for the proper storage and 

management of these substances at the proposed project site.

Health and Safety Requirements – To comply with regulations set forth by OSHA and the Nevada 

Division of Industrial Relations, health and safety programs would be established for construction and 

operations at the proposed project site that would document potential hazards and requirements for 

establishing and maintaining a safe working environment during construction and operation. The 

programs would include identification of all hazardous substances and chemicals used at the site, 

including Material Safety Data Sheets (MSDS), a communication and training program, labeling, and 

identification of hazards and safe work practices. In addition, safety showers and eyewashes would be 

provided adjacent to, or in the vicinity of, chemical storage and use areas. Plant personnel would use 

approved personal protective equipment during chemical spill containment and cleanup activities. 

Personnel would be properly trained in the handling of these chemicals and instructed in the procedures 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-42

to follow in case of a chemical spill or accidental release. Adequate supplies of absorbent material would 

be stored on-site for spill cleanup.

Construction and Operation Stormwater Pollution Prevention Plan (SWPPP) – The project would comply 

with the requirements of the NPDES through preparation and implementation of a SWPPP and filing of 

an NOI to comply with the General Construction and General Industrial Stormwater NPDES permit. The 

plans would include procedures to be followed during construction to prevent erosion and 

sedimentation, non-stormwater discharges, and contact between stormwater and potentially polluting 

substances.

Hazardous Materials Business Plan (HMBP) – HMBPs would be filed with Nye County for the 

construction and operation of the facility. The HMBPs would inventory the hazardous materials and 

waste properties, quantities, storage containers and locations, and contingency planning and emergency 

response procedures.

Spill Prevention Control and Countermeasure (SPCC) Plans – SPCC Plans would be prepared for 

construction and operation of the facility. The plans would include spill prevention and 

countermeasures procedures to be implemented, including (but not limited to) a spill record (if 

applicable), analysis of potential spills, description of containment facilities, fill and overfill prevention 

facilities, spill response procedures, personnel training, and spill prevention. In addition, all spills would 

be reported to the BLM Hazardous Materials Coordinator.

The chemicals and hazardous substances that would be used at the site and their storage locations are

provided in Table 2-4. This list identifies each chemical by type, intended use, hazardous characteristics, 

and estimated quantity to be stored on-site.

The solar facility would require the use of large amounts of nitrate salt (NaNO3, CAS 7631-99-4; and 

KNO3, CAS 7757-79-1) at the proposed project site as the HTF. The salt would be melted once during 

project construction and would be used throughout the project life at temperatures between 550°F and 

1050°F. To ensure worker safety and environmental protection, the hot and cold HTF tank areas would 

be designed such that any release would be contained in a basin. The construction SWPPP would specify 

procedures to prevent contact between HTF and stormwater during processing of this material prior to 

plant startup. In addition, the processing area would be cleaned to ensure residual HTF is removed from 

surface soil after processing.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-43

Table 2-4. Potential Project Hazardous Materials

Material 

Chemical Abstract 

Service Number 

(CAS No.)

Use Hazardous 

Characteristics

Estimated Quantity 

On-Site

Carbon dioxide (gas) 124-38-9 Generator pumping Asphyxiant, 

compressed gas

20,000 standard 

cubic feet (scf)

Carbon dioxide 

(liquid) 124-38-9 Fire suppression

Asphyxiant, 

compressed liquid, 

cryogen

25,000 pounds (lb) 

Diesel fuel (No. 2) 68476-34-6 

Fuel for emergency 

generator, fire water 

pump, and diesel 

storage for vehicle 

use

Toxic, combustible 21,500 gallons (gal) 

Ferric chloride 

solution 7705-08-0 Possible use for 

water pretreatment

Toxic 3,000 gal

Hydrogen 1333-74-0 Generator cooling Toxic, flammable, 

explosive 24,000 scf

Hydrated lime 1305-62-0 Possible use for 

water pretreatment Toxic, corrosive 2,000 cubic feet (cf) 

Lubricating oil Various

Mechanical 

equipment, 

lubrication

Toxic, combustible 25,000 gal

Hydraulic oil Various Steam valve 

actuation Toxic, combustible 1,000 gal

Mineral oil Various Transformer oil Toxic, combustible 100,000 gal

Nitrogen 7727-37-9 Blanketing Asphyxiant, 

compressed gas 400 lb

Sodium carbonate 497-19-8 Water pretreatment Toxic 2,000 cf

Sulfur hexafluoride TBD Contained in 

switchgear devices Toxic 200 lb

Sodium hydroxide 

(50% by weight) 1310-73-2 

Possible water 

demineralizer media 

regeneration

Toxic, corrosive 3,000 gal

Sulfuric acid 

(29% by weight) 7664-93-9 Batteries Toxic, corrosive 2,000 gal

Sulfuric acid 

(93% by weight) 7664-93-9 

Reverse Osmosis 

(RO) feed pH 

control, possible 

water demineralizer 

media regeneration 

Toxic, corrosive 5,000 gal

Domestic wastewater would be treated and disposed of at the proposed project site using a septic 

disposal system consisting of septic tanks and a leach field permitted by NDEP and Nye County. It is 

anticipated that separate septic and leach field systems would be constructed for each of the power 

block and administrative buildings. These would be designed in accordance with local and state 

regulations by a licensed engineer. A typical/proposed schematic is shown in Figure 2-16.
Source: TSE Plan of Development

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Propsed_septic.mxd

Figure 2-16 Proposed Septic Systems

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-45

The project would produce maintenance and plant wastes typical of a power generation plant. These 

wastes would be managed in accordance with a Waste Management Plan to be developed before 

construction and operation of the facility. Wastes may include oily rags, broken and rusted metal and 

machine parts, defective or broken solar mirrors and electrical materials, empty containers, and other 

miscellaneous solid wastes including the typical refuse generated by workers. These materials would be 

collected by a local waste disposal company and disposed of at a landfill permitted to receive these 

wastes. Waste collection and disposal would be in accordance with applicable regulatory requirements 

to minimize health and safety effects, prevent leaks and spills, and prevent potential contact with 

stormwater.

Several methods would be used to properly manage and dispose of hazardous wastes generated by the 

project. Waste lubricating oil would be recovered and recycled by a waste oil recycling contractor. Spent 

lubrication oil filters would be disposed of in a Class I landfill. Workers would be trained to handle 

hazardous wastes generated at the proposed project site.

Chemical cleaning wastes would consist of alkaline and acid cleaning solutions used during preoperational chemical cleaning of heat exchangers after the units are installed. These wastes, which can 

contain elevated metal concentrations, would be temporarily stored on-site in portable tanks and would 

be disposed of off-site by a chemical cleaning contractor in accordance with applicable regulatory 

requirements.

2.5.9 Security, Fire Protection and Intentional Destructive Acts

2.5.9.1 Security

Chain link security fencing would be installed around the site perimeter, switchyard, and other areas 

requiring controlled access prior to beginning construction. The site perimeter fence would be up to 

8 feet high and have an overall height of no more than 10 feet from the bottom of the wire mesh to the 

top barbed wire. The fence would have top rail, bottom tension wire, and three strands of barbed wire 

mounted on 45-degree extension arms. Posts would be set in concrete.

Controlled access gates would be located at the entrances to the facility. Access through the main gate 

would require an electronic swipe card, preventing unaccompanied visitors from accessing the facility. 

All visitors would be logged in and out of the facility during normal business hours. Visitors and nonemployees would be allowed entry only with approval from a staff member at the facility. Visitors would 

be issued visitor passes to be worn during their visit and returned at the main office when leaving.

Personnel would staff the facility 24 hours per day, 7 days per week. Even when the solar power plant is 

not operating, personnel would be present as necessary for maintenance, to prepare the plant for 

startup, and/or for site security.

2.5.9.2 Fire Protection

The project would rely on both on-site fire protection systems and off-site fire protection services during 

both construction and operation of the facility. The on-site fire protection system would be designed to 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-46

protect personnel and limit property loss and plant downtime in the event of a fire. The primary source 

of fire protection water would be the service/fire water storage tank.

A Fire Protection and Prevention Plan would be prepared for construction and operation of the facility. 

The plan would include measures relating to safeguarding human life, preventing personnel injury, 

preserving property, and minimizing downtime attributable to fire or explosion. Fire protection 

measures would include the following:

• prevention of the inception of fires

• adequate exits

• fire-safe construction

• reduction of ignition sources

• control of fuel sources

• proper maintenance of fire water supply and sprinkler systems 

During construction, the permanent facility fire suppression system would be placed in service as early 

as practicable. Prior to installation of the facility’s permanent fire suppression system, fire extinguishers 

and other portable fire fighting equipment would be available on-site. These fire extinguishers would be 

maintained for the full construction duration, in accordance with local and federal OSHA requirements. 

During construction, water trucks would be first in and last out of the site for fire control purposes. 

Installation of a construction water source would be one of the first activities in order to provide an onsite source for construction and fire prevention water.

Locations of portable fire extinguishers would include, but not necessarily be limited to, portable office 

spaces, hot work areas, flammable chemical storage areas, and mobile equipment (e.g., passenger 

vehicles and earthmoving equipment). Fire-fighting equipment would be located to allow for 

unobstructed access to the equipment and would be conspicuously marked. Portable fire fighting 

equipment would be routinely inspected in accordance with regulatory requirements and replaced 

immediately if defective or in need of recharge.

The facilities operating fire protection water system would be supplied from a dedicated portion of the 

water storage tank located on the plant site. One electric and one diesel-fueled backup firewater pump, 

each with a capacity of approximately 3,000 gal per minute, would deliver water to the fire protection 

piping network. A smaller electric, motor-driven jockey pump would maintain pressure in the piping 

network. If the jockey pump were unable to maintain a set operating pressure in the piping network, the 

diesel fire pump would start automatically.

A piping network would be configured in a loop so that a piping failure could be isolated with shutoff 

valves without interrupting the supply of water to a majority of the loop. The piping network would 

supply fire hydrants located at intervals throughout the power plant site, possibly a sprinkler deluge 

system at each unit transformer, and sprinkler systems at the STG lube oil equipment. Sprinkler systems 

would also be installed in the administrative/control/warehouse/maintenance building and fire pump 

enclosure as required by National Fire Protection Association (NFPA) and local code requirements. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-47

Handheld fire extinguishers of the appropriate size and rating would be located in accordance with 

NFPA 10 throughout the facility.

2.5.9.3 Intentional Destructive Acts

Solar generation projects can be the subject of intentional destructive acts ranging from random 

vandalism and theft to sabotage and acts of terrorism intended to disable the facility. Acts of vandalism 

and theft are far more likely to occur than sabotage or terrorism. Theft usually involves equipment at 

substations and switchyards that contain salvageable metal when metal prices are high. Vandalism 

usually occurs in remote areas and is more likely to involve spontaneous acts such as shooting at 

equipment. 

As indicated above, in order to keep the project infrastructure secure from threats from intentional 

destructive acts, the project site would be surrounded by an eight foot perimeter fence, and would be 

staffed 24 hours a day, 7 days a week. Furthermore, to ensure that the facility is not the target of 

unauthorized access, electronic controlled-access gates would be utilized.

Pursuant to DOE’s policy set out in a December 1, 2006, memorandum, “Need to Consider Intentional 

Destructive Acts in NEPA Documents,” DOE has considered the potential environmental consequences 

of intentional destructive acts at the Crescent Dunes site. DOE concludes that the risk of damage to the 

proposed Project from intentional destructive acts would be considered very low, in line with or less 

than the risk to similar generation facilities in the U.S. Theft or opportunistic vandalism is more likely 

than sabotage or terrorist acts, which are considered to be a negligible risk. 

Protection of widely dispersed electrical generation equipment, substations, and thousands of miles of 

transmission lines from destructive acts is not practical. Damaged equipment and transmission lines may 

be quickly repaired or replaced in the same manner that storm damaged equipment are returned to 

service. The results of any such acts could be expensive to repair, but no substantial impacts to 

continued electrical service would be anticipated. No significant environmental impacts would be 

expected from physical damage to the proposed Project or from loss of power delivery.

2.5.10 Applicant-Committed Environmental Protection Measures 

Vegetation

Between 1,628 and 1,673 acres of natural vegetation would be removed because of the various 

components of this project. Cactus and yucca would be salvaged in coordination with BLM. In 

coordination with BLM, the Proponent is developing a reclamation plan to be implemented at the 

termination of the lease. 

The Proponent has developed a Preliminary Weed Risk Assessment and will develop Weed Management 

Plan (WMP) for the project. The WMP will prescribe management actions for monitoring and eradicating 

specified species by BLM-approved methods. The WMP also will describe applicable regulations for the 

use of herbicides on federally managed lands in Nevada, and provide the basis for proper management 

and use of herbicides in the project area. A preemergent herbicide would be applied in the spring, and 

spot foliar applications would be used throughout the year to maintain the area free of vegetation. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-48

Typically, operations and maintenance requirements for native landscapes are low once established. 

The WMP will include weeding, annual pruning, and soil monitoring, if necessary. Weeding should occur 

frequently, typically weekly, during the initial growth period to ensure that invasive plants do not 

mature and set seed. Weeding activities would follow the approved WMP. Once the native plant species 

are established, weeding frequency would drop to less frequent intervals.

Wildlife Resources

Some wildlife such as small mammals and reptiles may still access the ponds, so ponds will be equipped 

with materials in each corner that would provide trapped wildlife with sufficient traction to be able to

exit the ponds. Additional mitigation is described in Section 4.5.11. Mitigation would be further 

developed in coordination with NDOW as part of the Industrial Artificial Pond Permit.

Special Status Plant Species

A mitigation plan is being developed between BLM, NDOW, and TSE.

Special Status Wildlife Species

Mammals: Pale Kangaroo Mice and Bats

A mitigation plan is being developed between TSE, BLM, and NDOW. Mitigation would include raptor 

deterrent mechanisms on TLs and any vertical structures that could promote raptor predation. In 

addition, the proponent may undertake additional studies of the Pale Kangaroo mouse during 

construction, in coordination with NDOW.

Golden Eagles and Migratory Birds

In order to minimize impacts to migratory birds during initial grading activities, the Proponent would 

avoid land clearing activities such as vegetation removal during the avian breeding season (April 1 to 

August 31). These dates may be modified by BLM based on specific site and weather conditions. If land 

clearing activities take place during the avian breeding season, a qualified biologist would conduct 

preconstruction surveys in the affected area to identify nests and breeding birds. If active nests were 

located, then a protective buffer zone would be delineated around the area (approximately 100 feet) 

and land-clearing activities would be restricted within this buffer zone. A golden eagle monitoring plan 

for known nest locations would be developed between BLM, NDOW, and USFWS.

In order to mitigate potential effects of TLs on birds, all static TLs would be marked with wire marks. This 

should make the static lines easier to see and reduce bird/wire collisions. In order to minimize potential 

bird electrocutions, TL wires would be spaced to accommodate the wingspan of the largest bird in the 

project area. 

Reptiles

No sensitive reptile species were identified in the proposed project area; therefore, no mitigation 

measures would be required.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No mitigation is proposed.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-49

Water Quality and Quantity

Mitigation measures to avoid or eliminate the potential impacts to hydrological resources associated 

with various tasks of construction and operation of the proposed project are discussed below. 

General water quality is protected under the Clean Water Act. All surface water runoff that would occur 

during and after construction as a result of the project would be controlled in accordance with the 

requirements of the construction and operational (post-construction) NPDES Stormwater Permit and 

other applicable laws, ordinances, regulations, and standards.

SPCC plans would be prepared for project construction and operation, to include spill prevention and 

countermeasure procedures to be implemented. To the extent practicable, SPCC would minimize the 

use of and need for disposal of hazardous and toxic wastes. The implementation of BMPs would prevent 

transport of contamination to the environment. 

The preparation and implementation of a construction SWPPP (a requirement of NPDES) that includes 

site-specific BMPs would mitigate and reduce erosion and water pollution.

BMPs may include: 

• silt barriers installed during construction to filter or contain sediment transport

• frequent inspection and cleaning of construction equipment to reduce or prevent 

contamination

• equipment fueling and service at designated locations away from drainage paths and 

wells to minimize contamination transport

As discussed in Section 2.5.2, grading of the site would allow storm flows to follow preexisting paths. 

The power island would be graded to direct rainfall within the power island to detention/retention 

basins adjacent to the on-site salt tanks to infiltrate into the ground instead of flowing off-site. Small 

ditches would be constructed along roadways and culverts as needed where washes cross roads. 

Transmission towers to be located along the proposed TL corridor would be positioned to avoid existing 

drainage paths of ephemeral washes to mitigate the potential for altered flow paths.

The construction plan would designate construction staging areas and approved access and exclusion 

areas. Wells identified for potential access or use impacts during the construction process would be 

appropriately included in the exclusion areas to maintain access at all times. 

Facility water needs are estimated to be less than the anticipated maximum water right quantity to be 

acquired and would not negatively affect or alter the appropriation of groundwater. 

The Proponent has filed for an approved jurisdictional determination requesting that the ephemeral 

Peavine Creek and its tributaries not be subject to jurisdiction under the Clean Water Act because they 

have been determined to be isolated intrastate waters (JBR 2010a).
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-50

Evaporation Ponds Avian and Wildlife Monitoring and Protection

A detailed monitoring and mitigation plan would be developed in coordination with NDOW as part of 

the Artificial Industrial Pond Permit application process. Initial mitigation and monitoring measures are 

described below.

Evaporation ponds would be covered with a porous screen, that would allow for evaporation, but also 

act as an avian deterrent. Avian monitoring at the evaporation ponds would be conducted twice 

monthly for the first 2 years of project operation and would continue at least monthly over the life of 

the project. The monitor (an appointed biologist or Environment Compliance Manager) would identify 

bird species and/or functional groups (e.g., waterfowl, waders, shorebirds, upland shorebirds) and 

wildlife observed utilizing the ponds, record the behavior of the birds and wildlife (e.g., feeding, 

swimming, wading, nesting), and note any mortalities or physical infirmities (e.g., birth defects or 

reduced growth) associated with any animals observed on or adjacent to the evaporation ponds. This 

information would be compiled and submitted to NDOW on a quarterly basis in accordance with the 

AIPP guidelines and permit requirements. Any dead bird or wildlife that could be safely retrieved from 

the evaporation ponds would be collected by a biologist or Environment Compliance Manager and sent 

to a qualified laboratory to determine whether the mortality was directly related to salt toxicity or 

encrustation. In accordance with the AIPP guidelines and permit requirements, all mortalities or injuries 

would be reported to NDOW within 24 hours of the observation. Documented mortality resulting from 

salt toxicity or encrustation would result in corrective measures or additional mitigation actions 

implemented in coordination with NDOW, BLM, and any other appropriate agencies. 

Air Quality

The proponent will implement the most current air emission technologies to maintain air emissions in 

accordance with state and federal regulations.

Cultural Resources

Further archaeological data collection will be needed to mitigate the adverse impacts to historic 

properties. A Historic Property Treatment Plan (HPTP) is being developed by TSE. The HPTP will list all 

historic properties to be adversely affected by the project and specify and describe in detail the 

mitigation measures—site avoidance, testing, data recovery, or monitoring—to be implemented prior to 

and/or during construction.

Native American Religious Concerns

During initial consultation, no Native American values were identified being impacted. 

Land Use and Access

No mitigation has been identified as being needed to address impacts on Land Use or Access. Access will 

be maintained throughout the construction and operation of the project.

Soils

Erosion

The objectives of erosion mitigation are to reduce short-term erosion and sedimentation, as well as 

quickly restore topography and vegetation to pre-construction conditions in all areas required and 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-51

approved by the BLM. Measures to be implemented by the project Proponent during project 

construction and reclamation are listed below.

Implementation of the following measures and practices would minimize the effects of grading, 

excavation, and other surface disturbances in all project areas. Schedules and specifications on the use 

of these features would be included in the COM plan.

• Confine all vehicular and equipment traffic associated with construction to the construction 

footprint, material yards, and access roads designated in the COM Plan.

• Limit soils and vegetation disturbance and removal to the minimum areas necessary for access 

and construction.

• Where vegetation removal is necessary, use cutting/mowing methods instead of blading, 

wherever possible.

• Adhere to a construction methodology that mitigates impacts in sensitive areas during severe 

weather events.

• Prior to work on the project, inform all construction personnel of environmental concerns, 

pertinent laws and regulations, and elements of the erosion control plan.

• Minimize grading to the greatest extent possible. Where required, grading should be conducted 

away from drainages and watercourses to reduce the risk of material entering these features.

• Graded material should be sloped and bermed to reduce surface water flows across the graded 

area.

• Replace excavated materials and minimize the time between excavation and backfilling.

• Direct dewatering operations to stable surfaces to avoid soil erosion.

• Use detention basins, certified weed-free straw bales or wattles, or silt fences where 

appropriate to reduce soil loss via erosion.

• Use drainage control structures including culverts, ditches, water bars (berms and cross ditches), 

and sediment traps, as necessary, to direct surface drainage away from disturbed areas and 

minimize runoff and sedimentation down-slope from all disturbed areas.

• Implement other appropriate BMPs to minimize erosion-related impacts during site preparation 

and construction, and subsequent reclamation.

• Re-establish native vegetation and, if necessary, non-persistent, non-invasive, non-native 

vegetation in highly erodible areas as soon as possible following construction.

In areas of highly erodible soils, construction equipment and techniques that minimize surface 

disturbance, soil compaction, and loss of topsoil would be used, such as vehicles with low ground 

pressure tires. Erosion control measures, in accordance with the Soil Conservation and Erosion Control 

Plan, will be installed prior to construction in potential soil erosion areas. Erodible slopes that do not 

require grading should be cleared using equipment that results in little to no soil disturbance.

Compaction

Construction, operation, and maintenance activities will be restricted when the soil is too wet to support 

construction or maintenance equipment (i.e., when heavy equipment creates ruts in excess of 4 inches 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-52

deep over a distance of 100 feet or more in wet or saturated soils). If soil is too wet, one or more of the 

following measures would apply:

• Where feasible, route all construction or maintenance activities to avoid wet areas as long as 

the route does not enter sensitive resource areas.

• If wet areas cannot be avoided, implement BMPs for use in these areas during construction and 

improvement of access roads, and during subsequent reclamation. Appropriate BMPs include 

use of wide-track or balloon-tire vehicles and equipment, or other approved weight dispersing 

systems, geotextile cushions, pre-fabricated equipment pads, and other materials to minimize 

damage to soil. If BMPs cannot be successfully applied, construction or routine maintenance 

activities would not be allowed in these areas until the project conditions improve and 

construction activity can proceed without damage to soils.

• Limit construction equipment access to the minimum amount feasible, remove and separate 

topsoil in wet or saturated areas, and stabilize subsurface soils with a combination of one or 

more of the following: grading to dewater problem areas, use of weight dispersion mats, and 

erosion control measures such as surface rilling and back-dragging. Following construction, regrade and re-contour the area, replace topsoil, and reseed to achieve pre-construction native 

plant densities.

Diminished Reclamation/Re-vegetation

Vegetation removal and soil disturbances (including temporary road improvements) will be minimized. 

Where vegetation removal is required, mowing or cutting methods will be utilized to the greatest extent 

possible. Top soil removed during clear and grub activity and grading and excavation required for 

construction will be collected and stockpiled on-site. Stockpiles will be protected from wind and water 

erosion through establishment of native vegetation and temporary or permanent erosion control BMPs 

including weed-free straw bales or wattles for the duration of facility construction, operation, and 

decommission. Following decommission, the stockpiled topsoil will be replaced across the site where 

topsoil was previously removed to provide a proper soil substrate for seeding or planting and enhance 

re-establishment of native vegetation to pre-construction conditions.

Social and Economics

Following is the proposed mitigation for the socioeconomic impacts associated with the construction 

and operations/maintenance phases of the proposed Project:

• In coordination with the Tonopah Town Board, develop a housing and rental plan to coordinate 

available rental property in and around Tonopah. 

• If available rental properties do not meet needs, work with the Town Board to develop 

temporary trailer park for relocating workforce in town or at the site. 

Visual 

To the extent possible, the project location will be integrated with the surrounding landscape to avoid 

conflict with significant aesthetic conditions. Subsequent to construction, restoration efforts will be 

made in areas that were temporarily disturbed. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-53

Given the importance of maintaining dark sky conditions, conscious efforts will be made to protect the 

current dark skies from light pollution. The Federal Aviation Administration (FAA) requires lighting on 

any temporary or permanent structure that exceeds an overall height of 200-feet above ground level. In 

order to maintain dark sky conditions and minimize visual disturbance, it is recommended that the 

central receiver tower be illuminated with white lighting during daytime hours and red strobe lights 

during the night. Additionally, perimeter lighting, including lighting used to illuminate walkways, 

roadways, equipment yards, and parking lots, should be fully shielded, low-pressure sodium lighting to 

reduce or eliminate detrimental lighting impact and prevent unnecessary light pollution. 

The TL poles will be constructed of wood which tends to blend into the landscape with distance. Given 

the flat, expansive nature of the landscape, the wood poles will provide less structural contrast as they 

blend into the horizon and skyline. The appearance of the wood poles will be similar to the existing 

power line poles in the corridor.

Hazardous Materials

During facility construction, various hazardous materials and one regulated substance will be stored 

onsite. Construction service personnel will follow general industry health, safety, and environmental 

Best Management Practices (BMP) for filling and servicing construction equipment and vehicles. The 

BMPs are designed to reduce the potential for incidents involving hazardous materials. They include the 

following:

• Refueling and maintenance of vehicles and equipment will occur only in designated areas that 

are either bermed or covered with concrete, asphalt, or other impervious surfaces to control 

potential spills. Employees will be present during refueling activities. 

• Vehicle and equipment service and maintenance will be conducted only by authorized 

personnel. 

• Refueling will be conducted only with approved pumps, hoses, and nozzles. 

• Catch-pans will be placed under equipment to catch potential spills during servicing. 

• All disconnected hoses will be placed in containers to collect residual fuel from the hoses. 

• Vehicle engines will be shut down during refueling. 

• No smoking, open flames, or welding will be allowed in refueling or service areas. 

• Refueling will be performed away from bodies of water to prevent contamination of water in 

the event of a leak or spill. 

• When refueling is completed, the service truck will leave the project site. 

• Service trucks will be provided with fire extinguishers and spill containment equipment, such as 

absorbents. 

• Should a spill contaminate soil, the soil will be put in containers and disposed of as appropriate. 

All containers used to store hazardous materials will be inspected at least once per week for 

signs of leaking or failure. All maintenance and refueling areas will be inspected monthly. 

Results of inspections will be recorded in a logbook that will be maintained onsite. 

In the unlikely event of a spill, the spill may need to be reported to the appropriate regulatory agencies 

and cleanup of contaminated soil could be required. Small spills will be contained and cleaned up 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-54

immediately by trained, onsite personnel. Larger spills will be reported via emergency phone numbers 

to obtain help from offsite containment and cleanup crews. All personnel working on the project during 

the construction phase will be trained in handling hazardous materials and the dangers associated with 

hazardous materials. An onsite health and safety person will be designated to implement health and If

there is a large spill from a service or refueling truck, contaminated soil will be placed into barrels or 

trucks by service personnel for offsite disposal at an appropriate facility in accordance with law. If a spill 

involves hazardous materials quantities equal to or greater than the specific RQ (42 gallons for 

petroleum products), all federal, state, and local reporting requirements will be followed. In the event of 

a fire or injury, the local fire department will be called. 

In addition to these BMPs to address accidental hazardous materials releases, a construction site 

security plan will be prepared to address hazardous materials security and will include the following 

elements: 

• Descriptions of the site perimeter fencing and access security 

• Evacuation procedures 

• A protocol for contacting law enforcement in the event of conduct endangering the facility, its 

employees, its contractors, or the public 

• A site access protocol for contractors and vendors, including applicable personnel background 

checks consistent with state and federal law regarding security and privacy 

• A protocol for hazardous materials vendors to prepare and implement security plans as per 49 

CFR 172.800 and to ensure that all hazardous materials drivers are in compliance with personnel 

background security checks as per 49 CFR Part 172, Subpart I 

• A protocol for security of nitrate salts in accordance with Department of Homeland Security 

(DHS) measures to protect listed Chemicals of Interest (risk: theft) as per 6 CFR Part 27 

During facility operation, various hazardous materials and one regulated substance will be stored onsite 

as shown in Table 4-23. Material Safety Data Sheets (MSDS) for the chemicals likely to occur on site 

during operation of the proposed Project can be found in the POD (Tonopah Solar Energy 2009). 

During operation of the facility, all hazardous materials will be handled and stored in accordance with 

applicable codes and regulations specified in Section 3.13 Affected Environment. Some general 

measures that will be implemented includes:

• Provision of an automatic sprinkler system for indoor hazardous material storage areas 

• Provision of an exhaust system for indoor hazardous material storage areas 

• Separation of incompatible materials by isolating them from each other with a noncombustible 

partition 

• Spill control in all storage, handling, and dispensing areas 

• Separate secondary containment for each chemical storage system; secondary containment is 

required to hold the entire contents of the tank plus the volume of water for the fire 

suppression system that could be used for fire protection for a period of 20 minutes in the event 

of a catastrophic spill 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-55

The above mitigation measures will be outlined in the following plans:

Health and Safety Requirements - To comply with regulations set forth by the Occupational Health and 

Safety Administration (OSHA) and the Nevada Division of Industrial Relations, health and safety 

programs will be established for construction and operations at the Site that will document potential 

hazards and requirements for establishing and maintaining a safe working environment during 

construction and operation. The programs will include identification of all hazardous substances and 

chemicals used at the site, including Material Safety Data Sheets (MSDS), a communication and training 

program, labeling, and identification of hazards and safe work practices. In addition, safety showers and 

eyewashes would be provided adjacent to, or in the vicinity of, chemical storage and use areas. Plant 

personnel would use approved personal protective equipment during chemical spill containment and 

cleanup activities. Personnel would be properly trained in the handling of these chemicals and 

instructed in the procedures to follow in case of a chemical spill or accidental release. Adequate supplies 

of absorbent material would be stored onsite for spill cleanup.

Construction and Operating Stormwater Pollution Prevention Plans (SWPPP) – The project will comply 

with the requirements of the National Pollutant Discharge Elimination System (NPDES) through 

preparation and implementation of a SWPPP and filing of a Notice of Intent (NOI) to comply with the 

General Construction and General Industrial Stormwater NPDES Permit. The plans will include 

procedures to be followed during construction to prevent erosion and sedimentation, non-stormwater 

discharges, and contact between stormwater and potentially polluting substances.

Hazardous Materials Management Plans (HMMP) – Hazardous Materials Management Plans will be 

filed with Nye County for the construction and operation of the facility. The plans will inventory the 

hazardous materials and waste properties, quantities, storage containers and locations, and contingency 

planning and emergency response procedures. 

Spill Prevention Control and Countermeasure Plans (SPCC) - SPCC Plans will be prepared for 

construction and operation of the Site. The plans will include spill prevention and countermeasures 

procedures to be implemented including (but not limited to) a spill record (if applicable), analysis of 

potential spills, description of containment facilities, fill and overfill prevention facilities, spill response 

procedures, personnel training and spill prevention. In addition, all spills will be reported to the BLM 

Hazardous Materials Coordinator.

Range Resources 

The project will be designed to minimize impacts where possible and construction measures will be 

taken to reduce long-term impacts during construction of the facility and the TLs, such as blading only 

areas that are needed for long-term access. Mitigation of these impacts will include recontouring and 

revegetating the area after removal and decommissioning of the facility at the end of the lease period. 

Goals of the revegetation plan are to return the site to a condition of production of comparable type 

and volume of forage and sustainable ecological condition. 

Mitigation for temporary impacts will vary by the type and severity of the impact. Impacts requiring 

removal of vegetation will be mitigated through revegetation efforts as described in the Revegetation 
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Plan. These efforts may include salvage and subsequent redistribution of topsoil, distribution of seeds to 

promote reestablishment of native plants, and control of noxious and invasive weed species. Where 

possible, vegetation would be crushed to allow the necessary construction access, minimizing impacts to 

the vegetation and the soils. In other cases, plants may be cut to allow construction access, retaining a 

root stock to provide a base for resprouting and more rapid plant reestablishment. 

Recreation and Wilderness

Access to recreation areas will be maintained throughout the construction and operation of the facility. 

No wilderness areas were identified as impacted by the proposed project.

2.5.11 Decommissioning and Reclamation 

The procedures described for decommissioning are designed to ensure public health and safety, 

environmental protection, and compliance with applicable regulations. It is assumed that 

decommissioning of the permanent plant facilities would begin 30–50 years after the commercial 

operation date of the solar plant. Decommissioning of temporary facilities, including but not limited to 

temporary septic systems, temporary underground conduit, temporary power poles, temporary 

concrete pads, and similar items would be completed during the plant commissioning time frame or 

within the first 6 months of facility operation following completion. The project goals for site 

decommissioning are as follows:

• Remove aboveground structures unless converted to other uses. 

• Restore the lines and grades in the disturbed area of the site to match the natural gradients of 

the site. 

• Reestablish native vegetation in the disturbed areas. 

The proposed implementation strategy to achieve the goals for site decommissioning would include the 

following:

• Use industry standard demolition means and methods to decrease personnel and 

environmental safety exposures by minimizing time and keeping personnel from close proximity 

to actual demolition activities to the extent practical. 

• Plan each component of the decommissioning project such that personnel and environmental 

safety are maintained while efficiently executing the work. 

• Conduct pre-decommissioning activities such as final decommissioning and restoration planning 

that address the “as-found” site conditions at the start of the project. 

• Remove all residual materials and chemicals from the site prior to demolition for reuse at other 

facilities or for proper disposal at licensed facilities. 

• Demolish aboveground structures (dismantling and removal of improvements and materials) in 

a phased approach while still using some items until close to the end of the project. For 

instance, the water supply, administrative building, and some electrical power components 

would be modified to be used until very late in the decommissioning project. 

• Demolish and remove belowground facilities (floor slabs, footings, and underground utilities) as 

needed to meet the decommissioning goals. 
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• Clean up soils, if needed, with special attention given to retention pond and hazardous materials 

use/storage areas to ensure that clean closure is achieved. 

• Dispose of materials in appropriate facilities for treatment/disposal or recycling. 

• Recontour lines and grades to match the natural gradient and function of the site. 

• Revegetate with native plants.

Although various types of decommissioning and demolition equipment would be used to dismantle each 

type of structure or equipment, dismantling would proceed according to the following general staging 

process. The first stage would consist of dismantling and demolishing aboveground structures to be 

removed. The second stage would consist of concrete removal as needed to ensure that no concrete 

structure remained within 3 feet of final grade (i.e., floor slabs, belowground walls, and footings) as 

appropriate, and removal/dismantling of underground utilities within 3 feet of final grade. The third 

stage would be excavation and removal of contaminated soils. The final stage would include contouring 

to return the disturbed area of the site to near original conditions while disturbing as little of the other 

site areas as possible, revegetating the site, and conducting associated monitoring. 

Stage 1. Aboveground demolition entails breakdown and removal of aboveground structures and 

facilities. Residual materials from these activities would be transported by heavy haul dump truck to a 

central recycling/staging area where the debris would be processed for transport to an off-site recycler. 

A project recycle center (at each power unit either as the work progresses or at the central 

administrative area) would be established to:

• Size-reduce and stage metals and mirrors for transport to an off-site recycler. 

• Crush concrete and remove rebar. 

• Stockpile concrete for later use at the site. 

• Stage rebar for transport to an off-site recycler. 

• Temporarily store and act as a shipping point for any hazardous materials to an approved 

Treatment, Storage, and Disposal (TSD) facility. 

The strategy for demolition consists of using mechanized equipment and trained personnel for the safe 

dismantling and removal of the following aboveground structures: 

• Remove heliostats and related equipment using low environmental impact equipment. 

• Dismantle towers using explosives to put the towers on the ground, then use conventional 

heavy equipment to size reduce and transport for recycling (this is the industry standard for safe 

demolition of large towers and massive concrete structures). 

• Remove the turbine generators, condensers and related equipment, TLs and towers, and 

aboveground pipelines using conventional demolition equipment and techniques. 

• Near the very end of the project, remove site-related fencing.

Stage 2. The belowground facilities to be removed include concrete slabs and footings that would 

remain within 3 feet of final grade at the end of the project. It is anticipated that any and all site-related 

piping and utilities, including water lines, belowground electric/control/communication lines, and gas 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-58

lines would be completely removed, regardless of the depth below final grade. These materials would 

be excavated and transported to the recycling area(s) for processing and ultimate recycling. The 

resulting trenches would be backfilled with suitable material of similar consistency and permeability as 

the surrounding native materials and compacted to 85 percent relative compaction.

Stage 3. The need for, depth, and extent of contaminated soil excavation would be based on 

observation of conditions and analysis of soil samples after removal of the evaporation pond and 

hazardous materials storage areas, and upon closure of the recycling center(s) and waste storage areas 

using during decommissioning. At this time, removal of contaminated soil is assumed to be unnecessary. 

If required, removal would be conducted to the extent feasible and as required to meet regulatory 

cleanup criteria for the protection of groundwater and the environment. If contaminated soil removal 

were required, the resulting excavations would be backfilled with native soil of similar permeability and 

consistency as the surrounding materials and compacted to 85 percent relative compaction. 

Stage 4. Recontouring of the site would be conducted using standard grading equipment to return the 

land to match, within reason, the previously existing surface and surrounding grade and function. 

Grading activities would be limited to previously disturbed areas that require recontouring. Efforts 

would be made to disturb as little of the natural drainage and vegetation as possible. Concrete rubble, 

crushed to approximately 2-inch minus size, would be placed in the lower portions of fills, at depths at 

least 3 feet below final grade. Fills would be compacted to approximately 85 percent relative 

compaction by wheel or track rolling to avoid over-compaction of the soils. To the extent feasible, 

efforts would be made to place a layer of coarser materials at the ground surface to add stability. After 

recontouring, the site would be revegetated where appropriate using native plants in accordance with a 

restoration plan developed in coordination with BLM.

2.6 Alternatives to the Proposed Action

Numerous alternative locations were considered for the Proposed Action using the siting criteria 

discussed in Section 2.2, Project Background. 

2.6.1 Alternatives Considered in Detail (Including No Action)

Three alternatives to the Proposed Action were evaluated for potential impacts, including two 

alternative locations for the project and the No Action Alternative.

2.6.1.1 Alternative 1 

The center of Alternative 1 would be located approximately 1.85 miles north of the center of the 

Proposed Action (see Figure 2-1). Alternative 1 was proposed during the scoping process by the U.S. Air 

Force to minimize impacts on instrumentation use to support the training mission on the Nevada Test 

and Training Range to the southeast of the Proposed Action. Many components of this alternative are 

similar to the Proposed Action. The sections below identify those items that differ from the Proposed 

Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-59

2.6.1.1.1 Project Components

The overall site layout for the alternative facility is very similar to the Proposed Action, as shown in 

Figure 2-2, and would include an array of components that are described in this section of the 

document. Additional details on the project components may be found in the project Plan of 

Development (TSE 2009). 

Generating Facility Components

The generating facility components required for Alternative 1 would be the same as for the Proposed 

Action. However, the location of the central receiving tower would be farther north, and the 

configuration of the mirror array would be slightly different, as depicted in Figure 2-2. 

Major Electrical Systems and Equipment

The major electrical systems and associated equipment for Alternative 1 would be the same as

described for the Proposed Action. 

Transmission Systems and Interconnection

The transmission system and interconnection components for Alternative 1 would have only minor 

differences from those described for the Proposed Action. 

Interconnection 

The interconnection at the Anaconda Moly Substation would be the same as for the Proposed Action. 

Potential Transmission Route

The transmission route would be similar to the route for the Proposed Action. The route would begin at 

the transformers on the facility and follow a path west to the existing transmission alignment 

(Figure 2-1). The total length of the new TL would be 7.5 miles.

Civil/Structural Features

The specifications and descriptions of the access roads, buildings and enclosures, material storage, 

storage tanks, and pipelines for Alternative 1 would be the same as for the Proposed Action. Details of 

the stormwater drainage plan for Alternative 1 would be designed specific to this site to accomplish the 

same objectives as the Proposed Action, and would be similar to the plan developed for the Proposed 

Action, which is shown in Figures 2-13 and 2-14. 

Construction Activities

Temporary construction facilities, construction process and schedule, and construction work force and 

equipment for Alternative 1 would be the same as for the Proposed Action.

Operations and Maintenance 

Operations and maintenance associated with Alternative 1 would be the same as for the Proposed 

Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-60

2.6.1.1.2 Water Demand and Sources

Water Sources

The water source for Alternative 1 would come from a well located approximately at the center of the 

power block. 

Water Demand

Water use for Alternative 1 would be the same as for the Proposed Action. 

2.6.1.1.3 Hazardous Materials Management

Hazardous materials used and hazardous wastes generated for Alternative 1 would be the same as for 

the Proposed Action. 

2.6.1.1.4 Security and Fire Protection

Security and fire protection for Alternative 1 would be the same as for the Proposed Action.

2.6.1.1.5 Applicant-Committed Environmental Protection Measures

Environmental protection measures would be the same as those for the proposed action. 

2.6.1.1.6 Decommissioning and Reclamation

The general concepts and requirements of the decommissioning and reclamation for Alternative 1 

would be the same as for the Proposed Action. 

2.6.1.2 Alternative 2

The center of Alternative 2 would be located approximately 2.4 miles northwest of the center of the 

Proposed Action (see Figure 2-1). Alternative 2 was proposed to minimize potential impacts of 

Alternative 1 on the soils and associated resources near the Crescent Dunes. Many components of this 

alternative are similar to the Proposed Action and Alternative 1. The sections below identify those items 

that differ from the Proposed Action.

2.6.1.2.1 Project Components

The overall site layout for the Alternative 2 facility would be very similar to the Proposed Action, as 

shown in Figure 2-2, and would include an array of components described in this section of the 

document. Additional details on the project components may be found in the project Plan of 

Development (TSE 2009). 

Generating Facility Components

The generating facility components required for Alternative 2 would be the same as for Proposed 

Action. However, the location of the central receiving tower would be northwest of the proposed 

project, and the configuration of the mirror array would be slightly different, as depicted in Figure 2-2. 

Major Electrical Systems and Equipment

The major electrical systems and associated equipment for Alternative 2 would be the same as 

described for the Proposed Action. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-61

Transmission Systems and Interconnection

The transmission system and interconnection components for Alternative 2 would have only minor 

differences from those for the Proposed Action. 

Interconnection

The interconnection at the Anaconda Moly Substation would be the same as for the Proposed Action. 

Potential Transmission Route

The transmission route would be similar to the route for the Proposed Action. The route would begin at 

the transformers on the facility and follows a path west to the existing transmission alignment 

(Figure 2-1). The total length of the new TL would be 6.9 miles.

Civil/Structural Features

The specifications and descriptions of the access roads, buildings and enclosures, material storage, 

storage tanks, and pipelines for Alternative 2 would be the same as for the Proposed Action. Details of 

the stormwater drainage plan for Alternative 2 would be designed specific to this site to accomplish the 

same objectives as the Proposed Action, and would be similar to the plan developed for the proposed 

project, which is shown on Figures 2-13 and 2-14.

Construction Activities

Temporary construction facilities, construction process and schedule, and construction work force and 

equipment for Alternative 2 would be the same as for the Proposed Action.

Operations and Maintenance 

Operations and maintenance associated with Alternative 2 would be the same as for the Proposed 

Action.

2.6.1.2.2 Water Demand and Sources

Water Sources

The water source for Alternative 2 would come from a well located approximately at the center of the 

power block. 

Water Demand

Water use for Alternative 2 would be the same as for the Proposed Action. 

2.6.1.2.3 Hazardous Materials Management

Hazardous materials used and hazardous wastes generated for Alternative 2 would be the same as for 

the Proposed Action. 

2.6.1.2.4 Security and Fire Protection

Security and fire protection for Alternative 2 would be the same as for the Proposed Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-62

2.6.1.2.5 Applicant-Committed Environmental Protection Measures

Environmental protection measures would be the same as those for the proposed action. 

2.6.1.2.6 Decommissioning and Reclamation

The general concepts and requirements of the decommissioning and reclamation for Alternative 2 

would be the same as for the Proposed Action. 

2.6.1.3 No Action Alternative

In accordance with CEQ [40 CFR 1502.14(d) and 1508.25(b)] and BLM guidelines (BLM 2008a), this EIS 

evaluates the No Action Alternative. The No Action Alternative describes the environmental 

consequences that would result if the Proposed Action were not implemented. The No Action 

Alternative forms the baseline from which the impacts of all other alternatives can be measured.

Under the No Action Alternative, BLM would not approve the SF-299 ROW grant, and the proposed solar 

facility would not be constructed. Not constructing the facility would require the state utilities to rely on 

other facilities to achieve the goals of the RPS. 

2.6.2 Alternatives Considered but Eliminated from Detailed Analysis 

In accordance with BLM’s NEPA Handbook and associated guidelines, alternatives that do not meet the 

purpose and need of the project, are not technically or economically feasible, or are substantially similar

to or have similar impacts as other alternatives being evaluated may be eliminated from detailed 

analysis. For this project, two additional alternative locations were initially considered and a different 

cooling technology was considered. 

2.6.2.1 Alternative Locations

TSE performed preliminary screening of areas in the regional vicinity of Tonopah, Nevada, for 

consideration as potential locations for the Proposed Action. TSE’s technology has specific siting 

requirements, including a large open space of approximately 4 square miles, minimal slope, transmission 

access, water availability, road access, and high solar incidence. TSE is also limited to sites not already 

claimed by other developers. The site selection process for the Proposed Action screened sites based on 

the following parameters:

• siting area with minimum area of 4 square miles and contiguous in configuration

• solar resource

• distance from TLs and substations

• environmental considerations

• stormwater drainage channels/waters of the United States

• land ownership

• water resources

• topography

• airport locations

• highways/roads
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-63

• faults

• population centers

• military interference issues

As a result of the effort, three sites were identified that met the screening criteria, and SF-299 

applications were submitted on the three BLM-administered areas, including the proposed project site 

(Figure 2-17). The two additional sites were the Mud Lake Site, east of Tonopah, and the Peavine Creek 

Site, west of the proposed project site. 

Each of these three sites met the criteria for solar resource, topography, proximity to interconnection, 

potential for water resources, and minimal interference with other land uses. After further review, the 

Mud Lake and Peavine Creek sites were ultimately eliminated from further consideration for one or 

more of the following reasons: a high potential for military and/or radar operations interference, 

potential for cultural resource occurrence and sensitivity, potential for substantial upgrades required for 

road access, potential for affecting areas with significant stormwater drainage channels, and the need 

for substantial interconnection capacity upgrades. In addition, interconnection studies showed that 

transmission would require extensive upgrades for the Mud Lake Site, including a new substation. 

Finally, given that the Mud Lake Site was being proposed in a dry lakebed, the area had a high potential 

for the presence of and impacts to sensitive cultural resources and values. 

Based on discussions with personnel at Nellis Air Force Base and the DOD Preliminary Screening Tool 

(FAA 2010a), it was discovered that both the Mud Lake and Peavine Creek sites were located in areas 

where impacts on military training were highly probable.
Borrow Pit

Anaconda Substation

Peavine Creek Alternative Site

Mud Lake Alternative Site

Tonopah

Project site and 

current alternatives

376

01234

Miles

Legend

Planned

Alternative sites considered

Borrow Pit

Alternative Area

Proposed Site

Alternate 1

Alternate 2

Proposed Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Alt_sites_considered.mxd

Figure 2-17 Alternative Sites Considered

but not Further Evaluated

Crescent Dunes Solar Energy Project

Project Site

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-65

2.6.2.1 Alternative Cooling Technology 

The Proposed Action would include a hybrid wet-dry system for cooling. This system would optimize the 

efficiency of the power generation compared with water use. The following is a short description of the 

different cooling technologies; however, the hybrid cooling is the system carried forward in this EIS.

Wet Cooling

A wet cooling system consists primarily of a cooling tower, water recirculation pumps, and a wet surface 

condenser. Steam is condensed in the wet surface condenser with cooling water being pumped from 

the cold water basin. The warm water leaving the wet surface condenser returns to the cooling tower, 

where it is chilled by evaporative cooling. The cooling tower maintains a cold water basin temperature 

by turning fans on and off.

Cooling towers are typically the lowest cost system while providing the highest steam turbine efficiency. 

Higher turbine efficiencies are achieved because the cooling tower uses the wet bulb temperature 

instead of ambient temperature, thereby enabling cooler steam condensate. The downside to cooling 

towers is the high water use caused by the evaporative cooling. 

By using wet cooling technology for the Proposed Action, it was estimated that approximately 1,000–

1,200 AF of water would be needed per year. Because of this high water use and the option of using a 

hybrid technology using less water, this alternative was not carried forward in the analysis. 

Dry Cooling

A dry cooling system consists primarily of an ACC. Steam is passed through a tube structure in the ACC 

and is cooled by air flowing over the tubes, similar to a car radiator.

ACC systems typically have higher costs than that of a cooling tower. The ACC itself is significantly more 

expensive than a cooling tower for the same power plant but removes the need for circulating pumps 

and a wet surface condenser. The most significant advantage of a dry cooled system is the lower water 

use than wet and hybrid cooling systems. The downside to an ACC is low turbine efficiency, which will 

relate to higher power costs because of lower power production for the same capital cost. 

It is estimated that a dry cooled technology for this project would use 150–200 AF of water per year. 

However, because of the decrease in efficiency and, thereby, a higher power cost, the fully dry-cooled 

technology was not carried forward in the analysis.

2.7 Comparative Analysis of Alternatives

Table 2-5 provides a comparative analysis of the alternatives considered in detail in this EIS. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-66

Table 2-5. Comparative analysis of alternatives considered in detail

Resource/Issue Proposed Action Alternative 1 Alternative 2 No Action Alternative

Land disturbance 

(acres)

Permanent: 1,704 acres

Temporary: 102 acres

Total: 1,806 acres

Permanent: 1,665 acres

Temporary: 110 acres

Total: 1,775 acres

Permanent: 1,652 acres

Temporary: 110 acres

Total: 1,762 acres 

No land would be 

disturbed. 

Vegetation 

(including noxious 

weeds)

Construction: Removal of 

1,673 acres of common desert 

vegetation during construction of 

project facilities

Operation: No effects

Construction: Removal of 

1,640 acres of common desert 

vegetation during construction of 

project facilities, and removal of a 

large proportion (16 percent) of 

unique habitat (active and 

stabilized dunes) within the 

Cumulative Effect Study Area

Operation: No effects

Construction: Removal of 

1,628 acres of common desert 

vegetation during construction of 

project facilities

Operation: Since vegetation would 

be removed during construction, 

no effects to vegetation

No vegetation would 

be affected.

Wildlife resources

Construction: Injury or mortality 

to wildlife during grading and 

construction activities, and 

removal of 1,673 acres of habitat

Operation: Potential for wildlife 

injury or mortality related to 

operation of evaporation ponds

Construction: Injury or mortality to 

wildlife during grading and 

construction activities, and removal 

of 1,640 acres of habitat including 7 

acres of unique dune habitat

Operation: Potential for wildlife 

injury or mortality related to 

operation of evaporation ponds 

Construction: Injury or mortality 

to wildlife during grading and 

construction activities, and 

removal of 1,628 acres of habitat

Operation: Potential for wildlife 

injury or mortality related to 

operation of evaporation ponds

No wildlife would be 

affected.

Special status 

species (plants) 

Construction: Removal of Nevada 

oryctes plants and 1,374 acres of 

suitable habitat

Operation: No effects

Construction: Removal of Nevada 

oryctes plants and 803 acres of 

suitable habitat

Operation: No effects

Construction: Removal of Nevada 

oryctes plants and 434 acres of 

suitable habitat

Operation: No effects

No special status 

species would be 

affected.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-67

Table 2-5. Comparative analysis of alternatives considered in detail

Resource/Issue Proposed Action Alternative 1 Alternative 2 No Action Alternative

Special status 

species (wildlife)

Construction: Injury or mortality 

to pale kangaroo mice during 

construction and grading 

activities, and removal of 1,466 

acres of suitable habitat

Operation: Pale kangaroo mice 

may suffer injury or mortality 

related to operation of the 

evaporation ponds

Construction: Injury or mortality to 

pale kangaroo mice and special 

status beetle species during 

construction and grading activities, 

removal of 1,191 acres of suitable 

habitat for pale kangaroo mouse, 

and removal of 7 acres of beetle 

habitat

Operation: Pale kangaroo mice 

may suffer injury or mortality 

related to operation of the 

evaporation ponds

Construction: Injury or mortality 

to pale kangaroo mice during 

construction and grading activities, 

removal of 434 acres of suitable 

habitat

Operation: Pale kangaroo mice 

may suffer injury or mortality 

related to operation of the 

evaporation ponds

No special status 

species would be 

affected.

Golden eagles and 

migratory birds

Construction: Removal of 

1,673 acres of golden eagle

foraging habitat and migratory 

bird nesting habitat

Operation: Injury or mortality due 

to bird collisions with project 

structures and transmission line

Construction: Removal of 

1,640 acres of golden eagle

foraging habitat and migratory bird 

nesting habitat

Operation: Injury or mortality due 

to bird collisions with project 

structures and transmission line

Construction: Removal of 

1,628 acres of golden eagle

foraging habitat and migratory bird 

nesting habitat

Operation: Injury or mortality due 

to bird collisions with project 

structures and transmission line

Migratory birds or 

Golden eagles would 

no be affected. 

Surface water 

quality and 

quantity 

Construction: Increased potential

for surface water contamination 

due to accidental hazardous 

material spills, and increased 

potential for sediment transport 

during storms

Operation: Increased potential for 

sediment transport during storms

Construction: Increased potential 

for surface water contamination 

due to accidental hazardous 

material spills, and increased 

potential for sediment transport 

during storms

Operation: Increased potential for 

sediment transport during storms

Construction: Increased potential 

for surface water contamination 

due to accidental hazardous 

material spills, and increased 

potential for sediment transport 

during storms

Operation: Increased potential for 

sediment transport during storms

Surface water would 

not be affected.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-68

Table 2-5. Comparative analysis of alternatives considered in detail

Resource/Issue Proposed Action Alternative 1 Alternative 2 No Action Alternative

Groundwater 

quality and 

quantity 

Construction: Increased potential 

for groundwater quality effects 

due to naturally occurring total 

dissolved solids (TDS) in the area

Operation: Increased potential for 

groundwater contamination due 

to accidental hazardous material 

spills

Construction: Increased potential 

for groundwater quality effects due 

to naturally occurring TDS in the 

area

Operation: Increased potential for 

groundwater contamination due to 

accidental hazardous material spills

Construction: Increased potential 

for groundwater quality effects 

due to naturally occurring TDS in 

the area

Operation: Increased potential for 

groundwater contamination due to 

accidental hazardous material spills

Groundwater would 

not be affected.

Waters of the 

United States

Not present Not present Not present No waters of the 

United States would 

be affected.

Air quality

Construction: Temporary effects 

on air quality due to construction 

equipment exhaust, fugitive dust 

generated by vehicles and 

construction equipment, and wind 

driven fugitive dust; also, 

temporary effects on air quality 

due to initial heating of salt

Operation: Emissions from 

operation of the plant not 

expected to exceed federal or 

state air quality standards

Construction: Temporary effects 

on air quality due to construction 

equipment exhaust, fugitive dust 

generated by vehicles and 

construction equipment, and wind 

driven fugitive dust; also, 

temporary effects on air quality due 

to initial heating of salt

Operation: Emissions from 

operation of the plant not expected 

to exceed federal or state air 

quality standards

Construction: Temporary effects 

on air quality due to construction 

equipment exhaust, fugitive dust 

generated by vehicles and 

construction equipment, and wind 

driven fugitive dust; also, 

temporary effects on air quality 

due to initial heating of salt

Operation: Emissions from 

operation of the plant not 

expected to exceed federal or state 

air quality standards

Air quality would not 

be affected.

Cultural resources

Construction: Effects include 

disturbance and removal of four

existing properties eligible for 

listing on the National Register of 

Historic Places due to grading and 

construction activities

Operation: No effects

Construction: Effects include 

disturbance and removal of one 

existing property eligible for listing 

on the National Register of Historic 

Places due to grading and 

construction activities

Operation: No effects

Construction: Effects include 

disturbance and removal of eight 

existing properties eligible for 

listing on the National Register of 

Historic Places due to grading and 

construction activities

Operation: No effects

Cultural resources 

would not be affected

Native American 

religious concerns

No Native American concerns 

were identified during 

consultations

No Native American concerns were 

identified during consultations

No Native American concerns were 

identified during consultations

No Native American 

concerns were 

identified during 

consultations
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-69

Table 2-5. Comparative analysis of alternatives considered in detail

Resource/Issue Proposed Action Alternative 1 Alternative 2 No Action Alternative

Land use and 

access (including 

special 

designations)

Construction: Consistent with U.S. 

Bureau of Land Management 

(BLM) policies, goals, objectives, 

and land use descriptions; removal 

of 1,673 acres of BLM land from 

potential public use or disposal; 

potential impacts to military 

flights and airspace

Operation: Same as construction 

Construction: Not consistent with 

BLM policies, goals, objectives, and 

land use descriptions; removal of 

1,640 acres of BLM land from 

potential public use or disposal; 

removal of 130 acres of a right-ofway avoidance area (Special 

Recreation Management Area); 

effects on a designated mineral 

leasing area; potential impacts to 

military flights and airspace

Operation: Same as construction

Construction: Consistent with BLM 

policies, goals, objectives, and land 

use descriptions; removal of 

1,628 acres of BLM land from 

potential public use; potential 

impacts to military flights and 

airspace

Operation: Same as construction

Land use and access 

would not be 

affected.

Soils

Construction: Potential increase 

in soil erosion and compaction

Operation: No effects

Construction: Potential increase in 

soil erosion and compaction

Operation: No effects

Construction: Potential increase in 

soil erosion and compaction

Operation: No effects

Soils would not be 

affected.

Social and 

economic values

Construction: Temporary increase 

in local population during peak 

construction, and temporary 

increase in local jobs

Operation: Increase in local 

population, and approximately 

200 direct and indirect jobs 

created, with $30 million in 

revenues added to the State of 

Nevada annually

Construction: Temporary increase 

in local population during peak 

construction, and temporary 

increase in local jobs

Operation: Increase in local 

population, and approximately 

200 direct and indirect jobs 

created, with $30 million in 

revenues added to the State of 

Nevada annually

Construction: Temporary increase 

in local population during peak 

construction, and temporary 

increase in local jobs

Operation: Increase in local 

population, and approximately 200

direct and indirect jobs created, 

with $30 million in revenues added 

to the State of Nevada annually

No new jobs would be 

created and no 

revenue would be 

added to the State of 

Nevada annually as a 

result of the proposed 

project.

Visual resources

Construction: Major viewshed 

effects for recreationalists using 

dunes; Moderate viewshed effects

for travelers along Pole Line Road

Operation: Same as construction

Construction: Major viewshed 

effects for recreationalists using 

dunes; Moderate viewshed effects 

for travelers along Pole Line Road

Operation: Same as construction

Construction: Major viewshed 

effects for recreationalists using 

dunes; Moderate viewshed effects 

for travelers along Pole Line Road

Operation: Same as construction

Visual resources 

would not be 

affected.

Hazardous 

materials and solid 

waste

Construction: Potential for 

hazardous spills would increase 

and may affect groundwater

Operation: Same as construction

Construction: Potential for 

hazardous spills would increase and 

may affect groundwater

Operation: Same as construction

Construction: Potential for 

hazardous spills would increase 

and may affect groundwater

Operation: Same as construction

No impacts from 

hazardous materials 

would occur.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 2-70

Table 2-5. Comparative analysis of alternatives considered in detail

Resource/Issue Proposed Action Alternative 1 Alternative 2 No Action Alternative

Rangeland 

resources and 

livestock grazing

Construction: Removal of 

1,673 acres of forage production 

and livestock grazing area, which 

amounts to 52 Animal Unit 

Months (AUM) 

Operation: Increased activity and 

human presence in the area may 

cause livestock to avoid the area 

adjacent to the facility

Construction: Removal of 1,640

acres of forage production and 

livestock grazing area, which 

amounts to 50 AUMs.

Operation: Increased activity and 

human presence in the area may 

cause livestock to avoid the area 

adjacent to the facility

Construction: Removal of 1,628 

acres of forage production and

livestock grazing area, which 

amounts to 50 AUMs

Operation: Increased activity and 

human presence in the area may 

cause livestock to avoid the area 

adjacent to the facility

Rangeland resources 

and livestock grazing 

would not be 

affected.

Recreation, 

wilderness

No effects to recreation and 

wilderness are likely to occur.

Construction: Conversion of 

approximately 130 acres of the 

rights-of-way avoidance area (e.g., 

Crescent Dunes SRMA) into project 

facilities

Operation: Same as construction

No effects to recreation and 

wilderness are likely to occur.

Recreation and 

wilderness would not 

be affected.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 2-71

2.8 BLM-Preferred Alternative

In accordance with NEPA, Federal agencies are required by the CEQ (40 CFR 1502.14) to identify their 

preferred alternative for a project in the Draft EIS, if a preference has been identified, and in the Final 

EIS prepared for the proposed project. The preferred alternative is not a final agency decision; rather, it 

is an indication of the agency’s preference. 

The BLM has selected a preferred alternative based on the analysis in this DEIS; this preferred 

alternative is the alternative that best fulfills the agency’s statutory mission and responsibilities, 

considering economic, environmental, technical, and other factors.

The BLM has determined that the preferred alternative is Alternative 2 as described in Section 2.6, 

Alternatives to the Proposed Action. This alternative was chosen because this alternative: 

• has the least impacts to special status plants and wildlife species; 

• stays within the existing transmission corridor and reduces the length of the transmission line;

• does not impact the Crescent Dunes SRMA; 

• has the least impact to recreationalists utilizing Crescent Dunes; and 

• best complies with the TFO Resource Management Plan.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-1 

3.0Affected Environment

3.1 Introduction

This chapter describes the affected environment associated with the construction and operation of the 

Proposed Action, Alternative 1, or Alternative 2. The affected environment is analyzed in the physical 

project area, including all ancillary facilities [i.e., TL(s), borrow pit, access road(s)]. 

During the scoping process, additional alternatives were identified for the location of the generation 

facilities. In order to assess the Proposed Action and these alternatives, two areas were identified for 

describing the affected environment for this EIS: the Proposed Area, which contains the Proposed 

Action, and the Alternative Area, which contains the overlapping Alternatives 1 and 2 (see Figure 3-1). 

The TL route and borrow pit were assessed individually in each resource section, but would be 

components of any of the three build alternatives, if selected. This section documents the baseline 

(existing conditions) to identify and evaluate the environmental changes resulting from construction and 

operation of the proposed project. 

The following acreage applies to the above-described areas:

• Proposed Area = 2,762 acres

• Alternative Area = 3,821 acres

• TL and Substation = 180 acres

• Borrow Pit = 40 acres

In addition, a Cumulative Effects Study Area (CESA) was defined for each resource, as described in 

Table 3-1, and the existing environment for these areas is described in each resource section.

Best available information is used to describe the existing environment and the proposed project, and 

the discussion is based on consideration of issues raised during the public scoping meetings and 

guidance from NEPA and other related statutes.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-2 

Table 3-1. CESAs

Resource Analysis Area CESA

Water quality and quantity 

(groundwater and surface 

water)

Project area and associated facilities

Surface water: Tonopah Flat (137A) hydrographic 

basin of the Big Smoky Valley watershed (see 

Figure 2-15) 

Groundwater: 53-year, 1-foot draw down contour

(See Figure 3-7) 

Waters of the United States Project area and associated facilities 53-year, 1-foot drawdown contour (See Figure 3-

7) 

Geology and minerals 

(aggregate) Project area and associated facilities 5-mile radius of project area and associated facilities

Air quality San Antone allotment San Antone allotment

Soils Project area and associated facilities 5-mile radius of project area and associated 

facilities

Wildlife Project area and associated facilities

The southern end of Big Smoky Valley and 

relevant Nevada Department of Wildlife hunt 

areas 

Special status species Project area and associated facilities

Tonopah Flats Area for special status wildlife and 

plants. 

 10-mile buffer from boundaries of detailed study 

area for migratory birds and golden eagles

Range resources Project area and associated facilities San Antone allotment

Land use authorizations

and access Project area and associated facilities 1-mile buffer around the project area and 

associated facilities

Recreation and wilderness 25-mile radius of project area and 

associated facilities

25-mile radius of project area and associated 

facilities

Visual resources Viewshed of the project area and 

associated facilities

Viewshed of the project area and associated 

facilities

Auditory resources 1-mile buffer around the project area 1-mile buffer around the project area

Social and economic

values 50-mile radius of the town of Tonopah 50-mile radius of the town of Tonopah

Hazardous materials 1-mile buffer around project area and 

associated facilities

1-mile buffer around project area and associated 

facilities

Cultural resources Project area and associated facilities Project area and associated facilities

Native American

traditional values Project area and associated facilities 53-year, 1-foot draw down contour

Paleontology Project area and associated facilities Project area and associated facilities

Environmental justice Same as social and economic values Same as social and economic values

Invasive, nonnative

species Project area and associated facilities 5-mile radius of project area and associated 

facilities

Wetlands/riparian zones Project area and associated facilities 53-year, 1-foot drawdown contour

Migratory birds Project area and associated facilities 10-mile buffer around the boundaries of the 

detailed study area

To comply with NEPA, BLM is required to address specific elements of the environments that are subject 

to requirements specified in statute or regulations or by executive order. Table 3-2 includes the resource 

areas that must be addressed in all environmental analysis (BLM 2008a).
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-3 

Table 3-2. Supplemental authorities/elements that must be addressed

Supplemental Authoritya Not 

Presentb

Present/

Not

Affected

Present/

May Be 

Affectedc 

Rationale

Noxious weeds X 

No noxious weeds are documented in the Proposed or 

Alternative Areas; however, noxious weeds may be in 

the region. 

Migratory birds X The proposed project may affect migratory birds. 

Threatened and endangered 

species X No threatened or endangered species are within or near the project area. 

Areas of Critical 

Environmental Concern

(ACECs) 

X No ACECs are found within or near the project area. 

Water quantity and water 

quality X 

The 10-foot drawdown contour for groundwater 

withdrawal is within the project site and is approximately 

150 feet below ground surface; it does not affect any 

external wells, and the groundwater table is not 

connected to surface water features.

Wetlands, riparian zones, 

and waters of the United 

States

X No wetlands, riparian zones, or waters of the United 

States are in or near the project area. 

Floodplains X No floodplains are in or near the project area. 

Wild and scenic rivers X No wild and scenic rivers are in or near the project area. 

Air quality X 

Emissions from construction and operation of the 

proposed project would be within established federal, 

state, and regional thresholds.

Cultural/Historic properties X Historical properties are present within the Proposed 

and Alternative Areas.

Native American religious 

concerns X 

The U.S. Bureau of Land Management is actively 

coordinating with three tribes in the region and one 

descendancy group in the region. To date, no special 

concerns have been identified.

Environmental justice X 

The proposed project would not disproportionately 

affect environmental justice populations, and may bring 

economic development and jobs to the areas that would 

benefit all populations.

Waste – hazardous 

materials X 

Hazardous materials would be used on site; mitigation 

measures and Best Management Practices would reduce 

potential for spills and contamination. 

Wilderness X No designated wilderness exists within or near the 

project area.

Forest and rangelands 

(Healthy Forest Restoration 

Act [HFRA] only)

X No forests or rangelands defined by HFRA are in or near 

the project area. 

Prime or unique farmlands X No prime or unique farmlands are present in or near the 

project area.

Heath and human safety X 

The proposed project would have no effect on public 

heath or safety by implementing the regulatory safety 

and health plans. a See H-1790-1 (BLM 2008a) Appendix 1: Supplemental Authorities to be considered. b Supplemental Authorities determined to be “Not Present” were not carried forward for further analysis.

c Supplemental Authorities determined to be “Present/May be Affected” must be carried forward for analysis. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-4 

In addition to the critical elements of the human environment, other biological, physical and human 

resources are considered in the NEPA process. Table 3-3 lists resources considered by BLM for analysis 

in this document.

Table 3-3. Other resources considered for analysis in the EIS

Other Resourcesa Not 

Present

Present/

Not 

Affected

Present/

May Be 

Affected

Rationale

Vegetation X Approximately 1,600 acres of vegetation would be 

removed due to construction of project components.

Wildlife resources X Wildlife may be injured or killed during construction and 

operation of the project. 

Special status species 

(plants) X Removal of special status plant species and habitatwould occur.

Special status species 

(wildlife) X Pale kangaroo mouse may be killed or injured during 

construction and operation of the facility.

Land use and access X 

Land use and access associated with the proposed 

project is consistent with the U.S. Bureau of Land 

Management’s Tonopah Resources Management Plan

(Tonopah RMP). Some impact to access of Crescent 

Dunes was identified

Geology X 

Construction and operation of the proposed project 

would not affect geologic resources within or near the 

project area because such resources would not be 

removed from the area. 

Soils X 

Construction of the proposed project may increase 

erosion and soil compaction as well as diminish the 

potential for revegetation.

Minerals X 

The Tonopah RMP has indentified the area as low 

mineral potential. No areas of high, moderate, or low 

fluid mineral potential were identified within or near the 

project area.

Socioeconomics X 

Construction and operation of the project would create 

jobs for the local population, and add jobs to the 

community.

Noise X 

Project construction and operation activity would 

increase noise in and near the project area. There are no 

sensitive receptors within the project area.

Grazing X 

The proposed project would remove approximately 

1,600 acres that could be used for grazing, resulting in a 

reduction in animal unit months in the project area.

Visual X 

The project would be visible to travelers and 

recreationalists at Crescent Dunes Special Recreation 

Management Area (SRMA).

Recreation X The project would be near the SRMA for Crescent Dunes.

Transportation 

and traffic X 

Traffic is expected to increase during construction 

activities because of the influx of construction and 

project materials. However, the analysis showed that it 

would not impact the overall traffic scenario of the area.

Wild horses and burros X The project area does not occur within a Horse 

Management Area. a Other resources determined to be “Not Present” or “Present/Not Affected need to be carried forward for analysis or discussed further in the 

document based on the rationale provided.
Crescent Dunes Road

Borrow Pit

Anaconda-Moly Substation

Pole Line Road

¬«89

¬«89

0 1 2

Miles

Legend

Transmission line

Existing

Planned

Borrow Pit

Alternative Area

Proposed Area

± Roads

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3.mxd

Figure 3-1 Alternative Locations

Crescent Dunes

! Solar Energy Project Project Site

NEVADA

Substation
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-6 

3.2 Vegetation

This section addresses vegetation resources in the proposed project area. Vegetation resources covered 

in this section include plant communities and noxious and invasive plant species. Special status plant 

species are addressed in Section 3.4.1, Special Status Plant Species. 

3.2.1 Area of Analysis and Methodology 

The detailed study area for vegetation resources includes the Proposed Area, the Alternative Area, the 

borrow pit, and the TL and Anaconda Moly Substation corridor. An assessment of cumulative impacts 

includes the areas within a 5-mile radius from the boundary of the detailed study area, which includes 

the southern end of the Big Smoky Valley and San Antonio Mountains. 

Data on the vegetation resources were obtained from the Natural Resources Conservation Service 

(NRCS) Ecological Area Inventory, the Southwest Regional Gap Analysis Project (GAP), NRCS custom soil 

survey reports, Nevada Department of Agriculture (NDA), and 2006-color aerial photography. GAP data 

provide geographic information system (GIS) land cover type information developed from satellite 

imagery (U.S. Geological Survey [USGS] 2004). Major Land Resource Area (MLRA) Ecological Area 

Descriptions provide data on soils and reclamation potential.

Prior to the field surveys, GAP data were used to identify vegetation communities and land cover types 

within the detailed study area and CESA. During field surveys, delineations and descriptions of 

vegetation communities and land cover types in the GAP data were verified, and adjustments to those 

delineations or descriptions were documented. Field surveys within the Proposed Area, TL corridor, and 

the proposed borrow pit were conducted by botanists from JBR Environmental Consultants, Inc. (JBR), 

on May 18–23, 2009. Because of the subsequent identification of the Alternative Area during the 

scoping process, field surveys for the Alternative Area were conducted on May 3–6, 2010. Botanists 

walked the detailed study area to confirm and delineate Gap Land Cover types, identify the distribution 

of noxious weeds and invasive plant species, and inventory special status plant species (see Section

3.4.2, Special Status Plant Species). GAP data for the CESA were not verified outside the detailed study 

area. 

Establishment of reclamation goals requires an evaluation of the area’s plant cover prior to 

construction. To support development of reclamation goals, information on projected plant cover within 

the Proposed Area, Alternative Area, borrow pit, and TL and Anaconda Moly Substation corridor has 

been summarized from the descriptions of the ecological areas within the detailed study area.

3.2.2 Regulatory Framework 

3.2.2.1 BLM Policy

In addition to adhering to Nevada policies regarding noxious weeds, BLM also recognizes the problem of 

invasive annual grasses and actively seeks to control the spread of these species on BLM land in part by 

forming Cooperative Weed Management Areas and Integrated Weed Management Plans. BLM requires 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-7 

that leasers of BLM land conduct a risk assessment for noxious weeds and invasive species and develop 

measures for prevention, control, and monitoring of such species in their project areas (BLM 2008b). 

3.2.2.2 Nevada Regulations

Under NRS 555-005-201, NDA categorizes and maintains a list of noxious weeds that are determined to 

be a threat throughout the state. These statutes give NDA the power to investigate noxious weeds and 

require the landowners or occupants to control such weeds. 

3.2.3 Affected Environment 

The majority of Nevada is characterized as a basin and range setting, which is generally defined as 

parallel mountain ranges separated by valleys or intermontane basins. Valleys are generally drier and 

vegetated with shrubs and grasses (Griffith 2009). Mountain ranges have enough available moisture to 

support woody vegetation, including stands of pinyon pine and juniper trees (Griffith 2009). Winters are 

cold, with temperatures ranging from 20°F to 40°F. Temperatures in the summer are more variable, with 

the daytime highs ranging from 75°F to 90°F and nighttime lows ranging from 50°F to 60°F (Western 

Regional Climate Center 2010a). Annual rainfall in the region is approximately 5–10 inches per year, with 

slightly more precipitation in the winter and spring (January–May) (Western Regional Climate 

Center 2010a) (see Section 3.6, Air Quality). 

3.2.3.1 Vegetation and Land Cover Types

The proposed project area is located at the southern end of the Big Smoky Valley east of the Crescent 

Dunes and the San Antonio Mountains. According to the Southwest Regional GAP, vegetation 

communities and land cover types identified within the southern end of the Big Smoky Valley and the 

San Antonio Mountains include:

• Inter-Mountain Basins Cliff and Canyon

• Inter-Mountain Basins Active and Stabilized Dunes

• Inter-Mountain Basins Playa

• Great Basin Pinyon-Juniper Woodland

• Inter-Mountain Basin Big Sagebrush

• Great Basin Xeric Mixed Sagebrush Shrubland

• Mojave Mid-Elevation Mixed Salt Desert Scrub

• Inter-Mountain Basins Mixed Salt Desert Scrub

• Inter-Mountain Basins Semi-Desert Shrub Steppe

• Inter-Mountain Basin Montane Sagebrush Steppe

• Inter-Mountain Basin Semi-Desert Grassland

• Inter-Mountain Basin Greasewood Flat

• Barren Lands

• Recently Mined or Quarried

• Invasive Annual Grasses
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-8 

Below are the GAP land cover type descriptions abbreviated from USGS (2005) for all vegetation 

communities or land cover types found within the detailed study area and the CESA. Subsequent 

sections detail vegetation or land cover type specific to the Proposed Area, Alternative Area, borrow pit, 

TL and Anaconda Moly Substation, and CESA.

Inter-Mountain Basins Cliff and Canyon

This ecological system is found from foothills to subalpine elevations and includes barren and sparsely 

vegetated landscapes (generally less than 10 percent plant cover) of steep cliff faces, narrow canyons, 

and smaller rock outcrops of various igneous, sedimentary, and metamorphic bedrock types. Also 

included is vegetation of unstable scree and talus slopes that typically occurs below cliff faces. Widely 

scattered tress and shrubs may include white fir (Abies concolor), common pinyon (Pinus edulis), limber 

pine (Pinus flexilis), singleleaf pinyon (Pinus monophylla), juniper (Juniperus spp.), sagebrush (Artemisia 

tridentata), antelope bitterbrush (Purshia tridentata), curlleaf mountain mahogany (Cercocarpus 

ledifolius), ephedra (Ephedra spp.), creambush (Holodiscus discolor), and other species.

Inter-Mountain Basins Active and Stabilized Dunes 

This ecological system occurs in Intermountain West basins and consists of unvegetated to moderately 

vegetated (less than 10–30 percent plant cover) active and stabilized dunes and sandsheets. Species 

occupying these environments are often adapted to shifting, coarse-textured substrates (usually quartz 

sand) and form patchy or open grasslands, shrublands, or steppe composed of Indian ricegrass, sand 

sagebrush (Artemisia filifolia), sagebrush, fourwing saltbush, ephedra, blackbrush (Coleogyne 

ramosissima), rubber rabbitbrush (Chrysothamnus nauseosus), yellow wildrye (Leymus flavescens), 

chokecherry (Prunus virginiana), purch (Psoralidium lanceolatum), antelope bitterbrush (Purshia

tridentata), alkali sacaton, fourpart horsebrush (Tetradymia tetramers), or crinklemat (Tiquilia spp). 

Inter-Mountain Basins Playa 

This ecological system is composed of barren and sparsely vegetated playas (generally less than 

10 percent plant cover) found in the shrubs around the margins. These systems are intermittently 

flooded. The water is prevented from percolating through the soil by an impermeable soil subhorizon 

and is left to evaporate. Soil salinity varies greatly with soil moisture and greatly affects species 

composition. Characteristic species may include iodinebush (Allenrolfea occidentalis), greasewood 

(Sarcobatus vermiculatus), spiny hopsage (Grayia spinosa), Lemmon’s alkaligrass (Puccinellia lemmonii), 

basin wildrye (Leymus cinereus), saltgrass (Distichlis spicata), and/or Atriplex spp.

Great Basin Pinyon-Juniper Woodland

This ecological system occurs on dry mountain ranges of the Great Basin region and eastern foothills of 

the Sierra Nevada. These woodlands occur on warm, dry areas on mountain slopes, mesas, plateaus, 

and ridges. Severe climatic events occurring during the growing season, such as frosts and drought, are 

thought to limit the distribution of pinyon-juniper woodlands to relatively narrow altitudinal belts on 

mountainsides. Woodlands dominated by a mix of singleleaf pinyon and Utah juniper (Juniperus 

osteosperma), pure or nearly pure occurrences of singleleaf pinyon, or woodlands dominated solely by 

Utah juniper comprise this system. Curlleaf mountain mahogany is a common associate. Understory 

layers are variable and may include shrubs such as sagebrush (Artemisia spp.) and bunch grasses.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-9 

Inter-Mountain Basins Big Sagebrush Shrubland

This ecological system occurs throughout much of the western United States, typically in broad basins 

between mountain ranges, plains, and foothills between 1,500 and 2,300 meters (m) in elevation. Soils 

are typically deep, well-drained, and non-saline. These shrublands are dominated by sagebrush 

(Artemisia tridentata spp.). Scattered juniper species, greasewood, and Atriplex spp. may be present in 

some stands. Perennial herbaceous components typically contribute less than 25 percent vegetative 

cover. Common graminoid species include Indian ricegrass (Achnatherum hymenoides) and blue gramma 

(Bouteloua gracilis), as well as others.

Great Basin Xeric Mixed Sagebrush Shrubland

This ecological system occurs in the Great Basin on dry flats and plains, alluvial fans, rolling hillslopes, 

saddles and ridges at elevations between 1,000 and 2,600 m (3,281 and 8,530 feet). Areas are dry, often 

exposed to desiccating winds, with typically shallow, rock, non-saline soils. Shrublands are dominated by 

black sagebrush (Artemisia nova) (middle and low elevations) or little sagebrush (Artemisia arbuscula) 

(higher elevation), and may be codominated by sagebrush (Artemisia tridentata ssp. Wyomingensis) or 

rabbitbrush (Chrysothamnus viscidiflorus). The herbaceous layer is likely sparse and composed of 

perennial bunch grasses such as Indian ricegrass, desert needlegrass (Achnatherum speciosum), 

squirreltail (Elymus elymoides), or Sandberg bluegrass (Poa secunda).

Mojave Mid-Elevation Mixed Salt Desert Scrub

This ecological system represents the extensive desert scrub in the transition zone above creosote bush 

(Larrea tridentata) – burro bush (Ambrosia dumosa) desert scrub and below the lower montane 

woodlands (700–1,800 m [2,297–5,906 feet] in elevation) that occurs in the eastern and central Mojave 

Desert. It is also common on lower piedmont slopes in the transition zone into the southern Great Basin. 

The vegetation in this ecological system is quite variable. Codominants and diagnostic species include 

blackbrush (Coleogyne ramosissima), California buckwheat (Eriogonum fasciculatum), Nevada ephedra 

(Ephedra nevadensis), spiny hopsage (Grayia spinosa), and either Joshua tree (Yucca brevifolia) or 

Spanish dagger (Yucca schidigera). Desert grasses such as Indian ricegrass and desert needlegrass may 

be present. Scattered juniper species or desert scrub species may also be present.

Inter-Mountain Basins Mixed Salt Desert Scrub

This extensive ecological system includes open-canopied shrublands of typically saline basins, alluvial 

slopes, and plains across the intermountain western United States. Substrates are often saline and 

calcareous, medium- to fine-textured, alkaline soils, but include some coarser-textured soils. The 

vegetation is characterized by a typically open to moderately dense shrubland composed of one or more 

Atriplex species such as shadscale (Atriplex confertifolia), cattle saltbush (Atriplex polycarpa), or

spinescale saltbush (Atriplex spinifera). Other shrubs present to codominant may include sagebrush, 

rabbitbrush, rubber rabbitbrush (Ericameria nauseosa), ephedra (Ephedra nevadensis), spiny hopsage

(Grayia spinosa), and winterfat (Krascheninnikovia lanata), as well as others. Greasewood (Sarcobatus 

vermiculatus) is generally absent, but if present does not codominate. The herbaceous layer varies from 

sparse to moderately dense and is dominated by perennial graminoids such as Indian ricegrass, blue 

grama, thickspike wheatgrass (Elymus lanceolatus ssp. lanceolatus), western wheatgrass (Pascopyrum 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-10

smithii), James’ galleta (Pleuraphis jamesii), big galleta (Pleuraphis rigida), Sandberg bluegrass, or alkali 

sacaton (Sporobolus airoides). Various forbs are also present.

The Inter-Mountain Basins Mixed Desert Scrub was the most extensive vegetation association 

throughout the detailed study area. In subsequent sections (Sections 3.4.1, Special Status Plant Species,

and 3.4.2, Special Status Wildlife Species), this vegetation association is further delineated and refined 

to reflect dominant plant species and specific habitat for the pale kangaroo mouse and Nevada oryctes.

Inter-Mountain Montane Sagebrush Steppe

This system primarily occurs on deep-soiled to stony flats, ridges, nearly flat ridgetops, and mountain 

slopes. In general, this system shows an affinity for mild topography, fine soils, and some source of 

subsurface moisture. It is composed primarily of mountain sagebrush (Artemisia tridentata ssp. 

Vaseyana) and other sagebrush species. Antelope bitterbrush (Purshia tridentata) may codominate or 

even dominate some stands. Other common shrubs include snowberry (Symphoricarpos spp.), 

serviceberry (Amelanchier spp.), rabbitbrush, and wax currant (Ribes cereum). Most stands have an 

abundant perennial herbaceous layer (over 25 percent cover). Common graminoids include Arizona 

fescue (Festuca arizonica), Idaho fescue (Festuca idahoensis), needle and thread grass (Hesperostipa 

comata), as well as others. In many areas, frequent wildfires maintain an open herbaceous-rich steppe 

condition, although at most areas, shrub cover can be unusually high for a steppe system (greater than 

40 percent), with the moisture providing equally high grass and forb cover.

Inter-Mountain Basins Semi-Desert Shrub-Steppe

This ecological system occurs throughout the intermountain western United States, typically at lower 

elevations on alluvial fans and flats with moderate to deep soils. This semiarid shrub-steppe is typically 

dominated by graminoids (greater than 25 percent cover) with an open shrub layer. Characteristic 

grasses include Indian ricegrass, blue grama, saltgrass (Distichlis spicata), needle and thread 

(Hesperostipa comata), James’ galleta, Sandberg’s bluegrass, and alkali sacaton. The woody layer is 

often a mixture of shrubs and dwarf-shrubs. Characteristic species include fourwing saltbush (Atriplex 

canescens), sagebrush (Artemisia tridentata), rabbitbrush (Chrysothamnus spp.), Ephedra species, 

broom snakeweed (Gutierrezia sarothrae), and winterfat. Sagebrush species may be present but do not 

dominate. The general aspect of occurrences may be either open shrubland with patchy grasses or 

patchy open herbaceous layer. Disturbance may be important in maintaining the woody component. 

Microphytic crust is very important in some stands.

Inter-Mountain Basins Semi-Desert Grassland

This widespread ecological system occurs throughout the intermountain western United States on dry 

plains and mesas at approximately 1,450 to 2,320 m (4,757 to 7,612 feet) elevation. These grasslands 

occur in lowland and upland areas and may occupy swales, playas, mesatops, plateau parks, alluvial 

flats, and plains, but areas are typically xeric. The dominant perennial bunch grasses and shrubs within 

this system are all very drought-resistant plants. These grasslands are typically dominated or 

codominated by Indian ricegrass, three awn grass (Aristida spp.), blue grama, deer grass (Muhlenbergia

sp.), or James’ galleta (Pleuraphis jamesii) and others. This community may include scattered shrubs and 

dwarf shrubs of species of sagebrush, Atriplex sp., or winterfat.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-11

Inter-Mountain Basins Greasewood Flat

This ecological system occurs throughout much of the western United States in intermountain basins 

and extends onto the western Great Plains. It typically occurs near drainages on stream terraces and 

flats or may form rings around more sparsely vegetated playas. Areas typically have saline soils, a 

shallow water table, and flood intermittently, but remain dry for most of the growing season. The water 

table remains high enough to maintain vegetation, despite salt accumulations. This system usually 

occurs as a mosaic of multiple communities, with open to moderately dense shrublands dominated or 

codominated by greasewood, fourwing saltbush, shadscale, or winterfat that may be present to 

codominant. Occurrences are often surrounded by mixed salt desert scrub. The herbaceous layer, if 

present, is usually dominated by graminoids. There may be inclusions of alkali sacaton, salt grass (where 

water remains ponded the longest), or common spikerush (Eleocharis palustris) herbaceous types.

Barren Lands, Non-specific

Barren areas consist of bedrock, desert pavement, scarps, talus, slides, volcanic material, glacial debris, 

sand dunes, strip mines, gravel pits, and other accumulation of earthen material. Generally, vegetation 

accounts for less than 15 percent of total cover.

Recently Mined or Quarried

Areas where open pit mining or quarries are visible in the imagery (images acquired between 1999 

and 2001), and are 2 hectares or greater in size.

Invasive Annual Grasses

Areas that are dominated by introduced annual grass species such as Avena spp., Bromus spp., and 

Schismus spp.

3.2.3.1.1 Proposed Area

The topography of the Proposed Area is generally flat with elevations ranging from approximately 

5,000–5,060 feet. Six vegetation communities or land cover types were mapped and observed in the 

Proposed Area (see Table 3-4). Since GAP land cover type data are derived from satellite imagery, the 

vegetation community or land cover type observed during field surveys may deviate slightly from the 

USGS descriptions. During field surveys, biologists noted deviations in the land cover type description 

and distributions. Table 3-4 provides the number of acres of each vegetation community/land cover 

type mapped with GAP data, and the deviations in GAP data as observed during field surveys. Figure 3-2 

illustrates the distribution of each vegetation community or land cover type in the Proposed and 

Alternative Areas. Projected plant cover percentages for soil units/ecological areas within the Proposed 

Area are presented in Table 3-5. Reclamation potential associated with soil units is addressed in Section

3.9, Soils. 
Crescent Dunes Road

89

Pole Line Road

0 0.5 1

Miles

Legend

Alternative Area

Proposed Area

Road Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Veg_Proposed_AlternativeArea.mxd

Figure 3-2 Vegetation / Land Cover Types

within the Proposed and Alternative Areas

Crescent Dunes Solar Energy Project

Project Site

NEVADA

Inter-Mountain Basins Active and Stabilized Dunes

Inter-Mountain Basins Playa

Inter-Mountain Basins Mixed Salt Desert Scrub

Inter-Mountain Basins Semi-Desert Shrub Steppe

Inter-Mountain Basins Greasewood Flat

Barren Lands
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-13

Table 3-4. Approximate area of each vegetation community and land cover type within the Proposed 

Area

Southwest Regional Gap 

Analysis Project (GAP)

Vegetation Community 

or Land Cover Type

Area 

(acres) Field Observations

Inter-Mountain Basins Mixed Salt 

Desert Scrub 2,408 Field surveys generally confirmed the GAP vegetation associationdescription and distribution.

Inter-Mountain Basins Semi-Desert 

Shrub-Steppe 176 

Field surveys generally confirmed distribution of the GAP vegetation 

association description. However, during field surveys biologists 

observed that greasewood was not always a component of this 

community.

Inter-Mountain Basins Active and 

Stabilized Dune 6 

Field surveys generally confirmed the GAP vegetation association

description; however, the northern portion of Proposed Area is 

classified as active and stabilized dunes, and although the soils are 

sandy, no active or stabilized dunes are present.

Inter-Mountain Basins Greasewood 

Flat 120 Field surveys generally confirmed the GAP vegetation association 

description and distribution.

Intermountain Basins Playa 3 Field surveys generally confirmed the GAP vegetation association

description and distribution.

Barren Lands 74 Field surveys generally confirmed the GAP vegetation association

description and distribution.

Table 3-5. MLRA ecological areas and project plant cover estimates within the Proposed Area

Soil Units within the 

Proposed Area

Corresponding Major Land Resource Area 

(MLRA) Ecological Area Estimated Plant Cover

Belcher (BEB) R029XY046NV – Sandy Loam 5-8 P.Z. 15–25 percent

Broyes (BrB) R028BY017NV – Loamy 5-8 P.Z. 5–15 percent

Dune Land (DU) No corresponding MLRA Ecological Area Not applicable

Playas (PN) No corresponding MLRA Ecological Area Not applicable

Stumble (STC) R029XY012NV Sandy 5-8 P.Z. 15–25 percent

Tipperary (TGE) R027XY016NV Loamy Upland 5-8” P.Z. 20–30 percent

3.2.3.1.2 Alternative Area

The topography of the Alternative Area is generally flat with an elevation of approximately 5,000–

5,060 feet. Five vegetation communities or land cover types were mapped and observed in the 

proposed area (see Table 3-6). Since GAP land cover type data are derived from satellite imagery, the

vegetation community or land cover type observed during field surveys may deviate slightly from the 

USGS descriptions. During field surveys, biologists noted deviations in the land cover type description 

and distributions. Table 3-6 provides the number of acres of each vegetation community or land cover 

type mapped with GAP data, and the deviations in GAP data as observed during field surveys. Figure 3-2 

illustrates the distribution of each vegetation community or land cover type. Project plant cover 

percentages for soil units/ecological areas within the Alternative Area are presented in Table 3-7. 

Reclamation potential associated with soil units is addressed in Section 3.9, Soils. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-14

Table 3-6. Approximate area of each vegetation community and land cover type within the 

Alternative Area

Southwest Regional Gap 

Analysis Project (GAP)

Vegetation Community 

or Land Cover Type

Area

(acres) Field Observations

Inter-Mountain Basins 

Mixed Salt Desert Scrub 3,721 

Field surveys generally confirmed the GAP vegetation association description 

and distribution. However, it was noted that Lemon scurfpea and Indian 

ricegrass were more dominant in the eastern portion of the site. Nevada dalea 

was predominant in the central portion of the alternative area, and Bailey’s 

greasewood was predominant in the western portion of the site.

Inter-Mountain Basins 

Semi-Desert Shrub-Steppe 38 Field surveys generally confirmed the GAP vegetation association description 

and distribution.

Intermountain Active 

and Stabilized Dunes 26 Field surveys generally confirmed the GAP vegetation association description 

and distribution.

Inter-Mountain Basins 

Greasewood Flat 3 Field surveys generally confirmed the GAP vegetation association description 

and distribution. 

Barren Lands 39 Field surveys generally confirmed the GAP land cover type description and 

distribution.

Intermountain 

Basins Playa 2 Field surveys generally confirmed the GAP land cover type description and 

distribution.

Table 3-7. MLRA ecological areas and project plant cover estimates within the Alternative Area

Soil Units within the 

Proposed Area

Corresponding Major Land Resource Area 

(MLRA) Ecological Area

Estimated Plant Cover

Belcher (BEB) R029XY046NV – Sandy Loam 5-8 P.Z. 15–25 percent

Dune Land (DU) No corresponding MLRA Ecological Area Not applicable

Stumble (STC) R029XY012NV Sandy 5-8 P.Z. 15–25 percent

Timper (TEB) R029XY017NV Loamy 5-8” P.Z. 15–25 percent

Tipperary (TGE) R027XY016NV Loamy Upland 5-8” P.Z. 20–30 percent

Yomba (Ym) R029XY017NV Loamy 5-8” P.Z. 15–25 percent

3.2.3.1.3 Borrow Pit

The topography in the borrow pit area is generally flat, with an elevation of approximately 4,881–

4,972 feet. Three land cover types were observed in the proposed project area (Table 3-8). Since GAP 

land cover type data are derived from satellite imagery, the vegetation community or land cover type 

observed during field surveys may deviate slightly from the USGS descriptions. During field surveys, 

biologists noted deviations in the land cover type description and distributions. Table 3-8 provides the 

number of acres of each vegetation community or land cover type mapped with GAP data, and the 

deviations in GAP data as observed during field surveys. Figure 3-3 illustrates the distribution of each 

vegetation community or land cover type. Project plant cover percentages for soil units/ecological areas 

within the borrow pit area are presented in Table 3-9. Reclamation potential associated with soil units is 

addressed in Section 3-9, Soils. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-15

Table 3-8. Approximate area of each vegetation community and land cover type within the borrow pit

Southwest Regional Gap 

Analysis Project (GAP) 

Vegetation Community 

or Land Cover Type

Area

(acres)

Field Observations

Inter-Mountain Basins 

Mixed Salt Desert Scrub

40 Field surveys generally confirmed the GAP vegetation association description 

and distribution. The dominant shrubs were Bailey’s greasewood and littleleaf 

horsebrush.

Table 3-9. MLRA ecological areas and project plant cover estimates within the borrow pit

Soil Units within the 

Proposed Area

Corresponding Major Land Resource Area 

(MLRA) Ecological Area Estimated Plant Cover

Yomba (Ym) R029XY017 – Loamy 5-8 P.Z. 15–25 percent

Yomba (including Playas) R029XY017 – Loamy 5-8 P.Z. 15–25 percent

3.2.3.1.4 TL and Anaconda Moly Substation

The topography along the TL and Anaconda Moly Substation corridor rises slightly from the valley floor 

to the location of the substation, with an elevation of approximately 4,880–5,200 feet. Three vegetation 

communities or land cover types were observed within the TL and Anaconda Moly Substation corridor. 

Table 3-10 lists the land cover types/vegetation communities within the TL and Anaconda Moly 

Substation corridor. Since GAP land cover type data are derived from satellite imagery, the vegetation 

community/land cover type observed during field surveys may deviate slightly from the USGS 

descriptions. During field surveys, biologist noted deviations in the land cover type description and 

distributions. Table 3-10 provides the number of acres of each vegetation community or land cover type, 

and the deviations in GAP data observed during field surveys. Figure 3-3 illustrates distribution of each 

vegetation community or land cover type. Plant cover percentages for soil units/ecological areas within 

the TL and Anaconda Moly Substation corridor are presented in Table 3-11. Reclamation potential 

associated with soil units is addressed in Section 3.9, Soils. 
Crescent Dunes Road

Anaconda Substation

89

Pole Line Road

Pole Line Road

89

0 0.5 1

Miles

Legend

Borrow Pit (40 acres)

Transmission Line Buffer

Road

Alternative Area

Proposed Area

Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Veg_Transline.mxd

Figure 3-3 Vegetation / Land Cover Types

within Borrow Pit, Transmission Line and 

Anaconda Substation Corridor

Crescent Dunes Solar Energy Project

Project Site

NEVADA

Inter-Mountain Basins Playa

Inter-Mountain Basins Mixed Salt Desert Scrub

Inter-Mountain Basins Semi-Desert Shrub Steppe

Inter-Mountain Basins Greasewood Flat

Recently Mined or Quarried

Anaconda Substation
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-17

Table 3-10. Approximate area of each vegetation community and land cover type within the TL and 

Anaconda Moly Substation corridor

Southwest Regional Gap 

Analysis Project (GAP)

Vegetation Community 

or Land Cover Type

Area 

(acres) Field Observations

Inter-Mountain Basins 

Mixed Salt Desert Scrub 113 

The southern part of the transmission line (TL) corridor next to Pole Line Road 

was dominated by Bailey’s greasewood (Sarcobatus baileyi). At the northern 

end of the TL, fourwing saltbush and Bailey’s greasewood were dominant.

Inter-Mountain Basins 

Semi-Desert Shrub-Steppe 1 Field surveys generally confirmed the GAP vegetation association description and distribution.

Inter-Mountain Basins 

Greasewood Flat 1 Field surveys generally confirmed the GAP vegetation association description 

and distribution.

Table 3-11. MLRA ecological areas and project plant cover estimates within the TL and Anaconda 

Moly Substation corridor

Soil Units within the 

Proposed Area

Corresponding Major Land Resource Area 

(MLRA) Ecological Area

Estimated Plant Cover 

(basal and crown)

Stumble (STC) R029XY012NV – Sandy 5-8 P.Z. 15–25 percent

Timper (TEB) R029XY017NV – Loamy 5-8” P.Z. 15–25 percent

Yomba (Ym) R029XY017NV – Loamy 5-8” P.Z. 15–25 percent

3.2.3.1.5 CESA

All fifteen GAP vegetation communities/land cover types described previously were identified in the 

CESA. Differences between land cover types generally follow elevation changes from the valley floor to 

mountain slopes. For example, in the San Antonio Mountains, land cover types include Great Basin 

Pinyon-Juniper Woodland and Intermountain Basins Cliff and Canyon (see Figure 3-4). These are typical 

land cover types throughout the mountain ranges of the Great Basin. 

Generally, within the CESA, the valley floor has a higher percentage of the Mixed Salt Desert Scrub and 

Inter-Mountain Basin Desert Scrub Steppe. As the elevation increases between the valley floor and the 

mountain slopes, sagebrush becomes increasingly more predominant on the landscape until reaching an 

elevation where sufficient moisture exists to support pinyon-juniper woodlands. The steep slopes of the 

San Antonio Mountains have exposed cliffs with minimal vegetation where limited soil and moisture are 

unable to support it. The exception to this generality is the presence of the Crescent Dunes between the 

valley floor and the San Antonio Mountains. The Crescent Dunes are unvegetated sand dunes. 

Table 3-12 illustrates the area vegetation community or land cover type and the proportion of each 

within the CESA.
012

Miles

Legend

Borrow Pit (40 acres)

Planned

Transmission Line Buffer

CESA (5-mile buffer)

Alternative Area

Proposed Area

Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Veg_CESA_5mile.mxd

Figure 3-4 Vegetation / Land Cover Types

within the CESA

Crescent Dunes Solar Energy Project

Project Site

NEVADA

Inter-Mountain Basins Cliff and Canyon

Inter-Mountain Basins Arctive and Stabilized Dunes

Inter-Mountain Basins Playa

Great Basin Pinyon-Juniper Woodland

Inter-Mountain Basins Big Sagebrush Shrubland

Great Basin Xeric Mixed Sagebrush Shrubland

Inter-Mountain Basins Mixed Salt Desert Scrub

Inter-Mountain Basins Montane Sagebrush Steppe

Inter-Mountain Basins Big Sagebrush Steppe

Inter-Mountain Basins Semi-Desert Shrub Steppe

Inter-Mountain Basins Greasewood Flat

Barren Lands

Agriculture

Recently mined or quarried
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-19

Table 3-12. Summary of area of each vegetation community or land cover type and their proportion 

within the CESA

Vegetation Community or Land Cover Type Area 

(acres)

Proportion of Area 

in the CESA

Inter-Mountain Basins Cliff and Canyon 109.59 0.11% 

Inter-Mountain Basins Active and Stabilized Dunes 43.12 0.04% 

Inter-Mountain Basins Playa 100.52 0.10% 

Great Basin Pinyon-Juniper Woodland 41.35 0.04% 

Inter-Mountain Basins Big Sagebrush Shrubland 2061.5 2.08% 

Great Basin Xeric Mixed Sagebrush Shrubland 6,936.94 7.00% 

Mojave Mid-Elevation Mixed Desert Shrub 31.56 0.03% 

Inter-Mountain Basins Mixed Salt Desert Scrub 81,992.96 82.71% 

Inter-Mountain Basins Montane Sagebrush Steppe 1.78 0.00% 

Inter-Mountain Basins Semi-Desert Shrub Steppe 2,821.95 2.85% 

Inter-Mountain Basins Semi-Desert Grassland 1.78 0.00% 

Inter-Mountain Basins Greasewood Flat 3,094.47 3.12% 

Barren Lands 532.38 0.54% 

Recently Mined or Quarried 1,349.51 1.36% 

Invasive Annual Grassland 11.11 0.01% 

Total 99,130.52 100.00% 

3.2.3.2 Noxious Weeds and Invasive Species

The NDA list of noxious and invasive weeds includes 43 species identified as noxious in the State of 

Nevada. Weeds from this list that have been identified previously in Nye County include hoary cress 

(Cardaria draba) and Russian knapweed (Acroptilon repens) (Nevada Weed Action Committee 2001), but 

others may be present in the Big Smoky Valley. 

Invasive species such as cheatgrass (Bromus tectorum) are also a concern in the area because it has been 

identified throughout the Great Basin. Because cheatgrass disturbs native ecosystems, the key to 

controlling this invasive species is understanding the current distribution and minimizing the dispersal 

and establishment of the species (Peterson 2003).

3.2.3.2.1 Proposed Area

No noxious weeds were found in the Proposed Area; however, two invasive nonnative species were 

observed in the Proposed Area: halogeton (Halogeton gomeratus) and Russian thistle (Salsola sp.). 

Halogeton was observed infrequently throughout the proposed project area. However, Russian thistle 

was prevalent, especially in sandier soils throughout the proposed project area. Cheatgrass was not 

observed in the detailed study area. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-20

3.2.3.2.2 Alternative Area

No noxious weeds were found in the Alternative Area; however, two invasive nonnative species were 

observed in the Alternative Area: halogeton and Russian thistle.

3.2.3.2.3 Borrow Pit

Three tamarisk (Tamarisk sp.) plants were observed in the proposed borrow pit area along an 

ephemeral channel. Tall whitetop (Lepidium latifolium) was observed in a wash outside the southwest 

boundary of the proposed borrow pit area. 

3.2.3.2.4 TL and Anaconda Moly Substation

No noxious weeds were found in the TL and Anaconda Moly Substation corridor; however, two invasive 

nonnative species were observed in the TL and Anaconda Moly Substation corridor: halogeton and 

Russian thistle.

3.2.3.2.5 CESA

It is likely that many of the noxious and invasive species are present throughout the CESA. Cheatgrass 

may be the greatest concern because it is now widely spread throughout the Great Basin. Other noxious 

weeds may be present within the CESA, including but not limited to tall whitetop, hoary cress, tamarisk, 

and Russian knapweed.

3.3 Wildlife Resources

This section covers general wildlife resources. It describes wildlife species, including game, that are 

relatively abundant and are not classified as “special status species” under statute, regulations, or 

agency guidelines. Special status species are covered in Section 3.4.2, Special Status Wildlife Species. 

3.3.1 Area of Analysis and Methodology 

The area of analysis for wildlife resources includes the Proposed Area, the Alternative Area, the borrow 

pit, and the TL and Anaconda Moly Substation corridor. A cumulative effects assessment will include the 

southern end of the Big Smoky Valley and relevant NDOW hunt areas. 

3.3.2 Regulatory Framework 

The BLM RMPs provide management standards for wildlife and wildlife habitat. BLM field offices, in 

cooperation with NDOW, monitor wildlife and habitat conditions and maintain crucial wildlife habitat. 

NDOW and BLM jointly manage habitat for mule deer, pronghorn antelope, and other game species.

3.3.3 Affected Environment 

The detailed study area is completely within the southern end of the Big Smoky Valley. Although the 

specific land cover types may vary, the area is dominated by low growing shrubs and grasses that mostly 

provide 10–25 percent vegetative cover (see Section 3.2, Vegetation). East of the Proposed Area are the 

Crescent Dunes, which are mainly barren and consist only of exposed sand. Directly east of the dunes 

are the San Antonio Mountains, which rise to an elevation of approximately 6,300 feet within the CESA. 

These mountains provide rocky cliffs, sagebrush steppe, and some pinyon-juniper woodland. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-21

3.3.3.1 Proposed Area

3.3.3.1.1 Mammals

According to the ecological area descriptions and GAP data, the main components of vegetation in this 

area include greasewood, blackbrush, four-wing saltbush, and Indian ricegrass. This vegetation provides 

food, water, and cover for many small mammals such as Jackrabbits (Lepus californicus), kit foxes 

(Vulpes macrotis), ground squirrels (Spermophilus spp.), desert woodrats (Neotoma lepida), pocket mice 

(Perognathus spp.), deer mice (Peromyscus maniculatus), grasshopper mice (Onychomys spp.), and 

kangaroo rats (Dipodomys spp.). Additionally, many bat species may forage within the project area.

3.3.3.1.2 Game

Many big game species are common throughout the Great Basin Desert, including American pronghorn 

(Antilocapra americana), mule deer (Odocoileus hemionus), bighorn sheep (Ovis canadensis), and elk 

(Cervus elaphus). According to NDOW, the project area falls within designated pronghorn habitat. 

Pronghorn tracks were observed in the project area during field surveys and it is likely that they utilize 

this area. Mule deer likely use this area for foraging; however, the area has not been designated as 

important or unique habitat for this species by NDOW. It is unlikely that bighorn sheep utilize the area 

because they prefer the steep cliffs of the surrounding mountain ranges; however, bighorn sheep may 

migrate through the area.

3.3.3.1.3 Birds 

Most birds that utilize the project area are protected by the Migratory Bird Treaty Act (MBTA) (see 

Section 3.4.2, Special Status Wildlife Species); however, some birds may utilize the project area year 

round. For example, ravens (Corvus corax) may prey on reptiles, insects, and small mammals that are 

present throughout the project area. Horned larks (Eremophila alpestris) may forage on seeds and 

insects in the project area. Both common ravens and horned larks were observed during field surveys 

within the proposed area (in May 2009).

3.3.3.1.4 Reptiles

A wide variety of reptiles may be present in the project area, including western whiptail (Cnemidophorus 

tigris), leopard lizard (Gambelia wislizenii), gopher snake (Pituophis melanoleucus), and desert horned 

lizard (Phrynosoma platyrhinos) as well as others. These species as well as others are present in a wide 

variety of valley habitats and most likely utilize the project area.

3.3.3.2 Alternative Area

The wildlife found in the Alternative Area is consistent with the wildlife described in the Proposed Area.

3.3.3.3 Borrow Pit

The wildlife found in the borrow pit area is consistent with the wildlife described in the Proposed Area.

3.3.3.4 TL and Anaconda Moly Substation

The wildlife found in the TL and substation area is consistent with the wildlife described in the Proposed 

Area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-22

3.3.3.5 CESA

Species composition of wildlife throughout most of the valley portion of the CESA is similar to that 

described for the Proposed Area because most of the habitat is the same (see Section 3.2, Vegetation). 

However, the San Antonio Mountain Range is within the CESA and provides different habitat than the 

proposed area, including sagebrush, rock outcrops (including cliffs), and pinyon and juniper woodlands 

(see Section 3.2, Vegetation). These mountains may provide suitable habitat for species not found 

within the detailed study area. Common game species that may utilize this habitat include bighorn

sheep, mountain lion (Puma concolor), and mule deer. A variety of additional mammals might utilize 

these higher mountainous habitats, including bobcat (Lynx rufus), ground squirrels (Spermophilus spp.), 

and voles (Microtus spp.). Steep slopes with exposed cliffs may provide good roosting habitat for a 

variety of bat species, golden eagles, and other raptors (see Section 3.4.2, Special Status Wildlife 

Species). 

3.4 Special Status Species (Plants and Wildlife)

In this EIS, the term “special status species” encompasses species that are listed as threatened or 

endangered or species proposed or candidates for listing under the Endangered Species Act of 1973 as 

amended (50 CFR 17.11 [listed animals], 50 CFR 1712 [listed plants], and subsequent notices published 

in the Federal Register). It also encompasses species listed as protected by the State of Nevada under 

NRS 501.100–503.104, NRS 527.050, and NRS 527.60–527.300, and species listed as BLM sensitive 

species. 

3.4.1 Special Status Plant Species 

3.4.1.1 Area of Analysis and Methodology

The detailed study area for special status plant species includes the Proposed Area, the Alternative Area, 

the borrow pit, and the TL and Anaconda Moly Substation corridor. The CESA for special status plant 

species was determined to be the Tonopah Flats area. 

According to the Nevada Natural Heritage Program (NNHP) data, no special status plant species have 

previously been recorded within 2 kilometers (1.24 miles) of the project area. Field surveys for special 

status plant species and cacti were conducted on May 18–23, 2009, for the Proposed Area, the TL 

corridor, and the borrow pit area. Field surveys for special status plants and cacti in the Alternative Area 

were conducted on May 3–6, 2010. Biologists completed pedestrian surveys for special status plant 

species by walking transects spaced 15 meters (49 feet) apart over a portion of the project area. As the 

biologist became more familiar with the particular habitats and soils associated with special status plant 

species, these habitats were searched thoroughly and special status plant species locations were 

recorded. Information on habitat and soil preferences for BLM sensitive species gathered during field 

surveys were used to identify the amount of potential habitat for special status plant species throughout 

the CESA. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-23

3.4.1.2 Regulatory Framework

3.4.1.2.1 BLM Policy

BLM has implemented policies for special status species found on BLM-managed lands. BLM’s list of 

special status species includes species that are listed or proposed for listing under the Endangered 

Species Act (ESA) and species requiring special management consideration to promote their 

conservation and reduce the likelihood and need for future listing under the ESA. Additionally, all federal 

candidate species, proposed species, and delisted species (for 5 years after delisting) will be conserved 

as BLM sensitive species (BLM 2008b).

3.4.1.2.2 Nevada Protected Species Regulations

The State of Nevada has identified plant species that are declining in their range throughout Nevada or 

are otherwise rare and at risk of extinction. Plants warranting such protection are listed as Critically 

Endangered under NRS 503.104. Taking of these plants is prohibited without a permit obtained from the 

Nevada Division of Forestry (Nevada Administrative Code [NAC] 527.250). 

3.4.1.2.3 Nevada State Protection of Christmas Trees, Cacti, and Yucca 

Under NRS 527.060–527.120, it is illegal for any individual or company to cut, destroy, remove, or 

posses any Christmas tree, cactus, yucca, or portions of such plants. This statute is applicable to any 

cacti or yucca on BLM-managed lands.

3.4.1.3 Affected Environment

3.4.1.3.1 Proposed Area

The field surveys did not identify any BLM sensitive plant in the Proposed Area during the May 2009 

field surveys. However, in the 2010 surveys of the Alternative Area, Nevada oryctes (Oryctes 

nevadensis), a BLM sensitive species, was found to be widespread throughout the Inter-Mountain Basins 

Mixed Salt Desert Scrub vegetation association, where the dominant shrub cover was Nevada dalea 

(Psorothamnus polydenius) and the soils were Stumble Loamy fine sand 0-8 percent slopes (STC) (Figure 

3-5 and Figure 3-14 in Section 3.8, Soils). Because this species appears only in years with optimal rainfall 

and temperature patterns (NNHP 2001), it is likely that Nevada oryctes is present throughout similar 

habitat in the Proposed Area even though it was not detected during the 2009 surveys. Anecdotal 

observations of four Nevada oryctes plants made during the 2010 small mammal trapping surveys in the 

Proposed Area support this conclusion. Based on this information, it can be assumed that Nevada 

oryctes is present within the same Nevada dalea-dominated Mixed Salt Desert Scrub vegetation 

association in the Proposed Area, which is approximately 2017 acres (Figure 3-5). Additionally, three 

cactus species were observed throughout the project area, including Wiggins’ cholla (Cylindropuntia 

echinocarpa), sand cholla (Grusonia pulchella), and pricklypear (Opuntia polyacantha var. erinacae). 
Crescent Dunes Road

¬«89

Pole Line Road

0 0.5 1

Miles

 Legend

Alternative Area

Proposed Area

Road

±

Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Nev_Oryc_Habit.mxd

Figure 3-5 Nevada Oryctes Habitat within

Proposed and Alternative areas

Crescent Dunes

Solar Energy Project

!

Project Site

NEVADA

Suitable Habitat

Potential Habitat

Vegetation Type

Barren Land

Greasewood

Lemon Scurfpea

Nevada Dalea
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-25

3.4.1.3.2 Alternative Area

As discussed above, during 2010 field surveys biologists observed the Nevada oryctes (a BLM sensitive 

species) throughout approximately 1119 acres of the Alternative Area where the Mixed Salt Desert 

Scrub vegetation association is dominated by Nevada dalea and the soil is sandy. Because of the number 

of plants observed in the area, a detailed count of the plants was not obtained, but the boundary of the 

area within which the plants were observed was mapped (Figure 3-5, and Figure 3.15 in Section 3.8, 

Soils). 

Additionally, one cactus species, sand cholla, was observed throughout the Alternative Area.

3.4.1.3.3 Borrow Pit

One cactus was found in proposed borrow pit. No other BLM sensitive species or associated habitat or 

soils were found throughout the borrow pit area (Figure 3.16 in Section 3.8, Soils). 

3.4.1.3.4 TL and Anaconda Moly Substation

In 2009, one Nevada oryctes plant was found within the TL and Anaconda Moly Substation corridor 

(Figure 3-5). However, botanists observed that the Nevada dalea dominated the Mixed Salt Desert Scrub 

vegetation association throughout the TL corridor. As mentioned above, this is the vegetation 

association in which the Nevada oryctes was found to be common during the 2010 surveys. Although 

only one plant was found in 2009, the presence of this species is probably more widespread during years 

with optimal rainfall and temperatures, and may be more abundant within the TL corridor than 

previously documented.

3.4.1.3.5 CESA

Detailed surveys for special status plant species were not conducted throughout the CESA for this 

project. However, after overlaying the distribution of Nevada oryctes plants over the NRCS soils data it 

was determined that oryctes distribution is closely associated with the STC soil type (Figure 3-6). The 

STC soil type (i.e. oryctes habitat) occupies approximately 25,880 acres within the CESA. Additionally, 

information on observations of the species is available from the NNHP. Previous observations of the 

Nevada oryctes have been documented in Churchill, Esmeralda, Humboldt, Mineral, Pershing, Storey, 

and Washoe counties in Nevada, as well as Inyo County of California (NNHP 2001). Nevada oryctes may 

be found in similar soil types in these counties.
0 5 10

Miles

±

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Big_smky_vlly_gwBasin.mxd

!

Project Site

NEVADA 3-6 Nevada Oryctes Plant Habitat

throughout the CESA

Crescent Dunes

Solar Energy Project

 Legend

Tonopah Flat sub area

Potential

Suitable

Planned Transmission Line

Alternative Area

Proposed Area
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-27

3.4.2 Special Status Wildlife Species

3.4.2.1 Area of Analysis and Methodology

The area of analysis for special status species includes the Proposed Area, Alternative Area; borrow pit, 

and TL and Anaconda Moly Substation corridor. The CESA for sensitive wildlife varied depending on the 

species. For pale kangaroo mice, the CESA was determined to be the Tonopah Flats Area (Figure 3-8). 

For golden eagles, the CESA was determined to be 10-mile radius around the perimeter of the detailed 

study area (Figure 3-9). 

To develop a concise list of special status wildlife species potentially occurring in the detailed study area, 

data were compiled from USFWS (2009), the Nevada BLM Sensitive Species list, the Nevada State 

Protected Species list (NAC 503.030 for mammals, NAC 503.050 for birds, NAC 503.075 for amphibians, 

NAC 503.080 for reptiles), and the NHHP database. Agency biologists (USFWS, NDOW, and BLM) were 

consulted on several occasions to provide additional input. This information was used to develop a list of 

special status wildlife species that could occur within the project area. Species with no potential to occur 

because of documented range or distribution or a lack of preferred habitat (i.e., pinyon jays that only 

occur in pinyon-juniper habitat) were not included in this analysis. Based on an evaluation of listed 

species and habitats, and with concurrence from USFWS, no federally listed threatened, endangered, 

candidate, or proposed species occur in the project area (USFWS 2009a). 

To assess the existing conditions of golden eagles in the project area and the CESA, BLM biologists, in 

coordination with USFWS biologists, developed a general approach to evaluate potential impacts on this 

species. The initial step was to evaluate data on previously documented and currently known nesting 

sites, and identify potential nesting habitat by reviewing topographic maps and other data. Multiple 

data sources were used to conduct this analysis including data from: NDOW, BLM, NRCS Soil Survey, 

MLRA, GAP, aerial photographs, current literature, Great Basin Bird Observatory, topographic maps, and 

National Climatic Data Center. BLM biologists conducted field surveys and aerial surveys of historic or 

known nesting sites and as well as potential habitat throughout the CESA. Field surveys for golden 

eagles were conducted June 4, 2010 in the southern portion of the San Antonio Mountains. Surveys 

focused on determining golden eagle occupancy and condition of two previously documented nests and 

potential nesting habitat in the area. Aerial surveys were on June 24, 2010 throughout the CESA. 

Transects were flown from southeast to northwest in a zigzag manner. All areas with rocky outcrops, 

mountains, and cliffs (i.e. potential golden eagle nesting habitat) were examined for golden eagles or 

sign (i.e. white wash or nests). Transects throughout portions of the CESA that were considered less 

suitable golden eagle habitat were approximately 2-3 miles apart. All potential golden eagles and nests 

locations were recorded with a GPS unit. Additionally, GAP data within the CESA was used to identify the 

extent of potential golden eagle habitat. The intermountain basin cliff and canyon land cover type was 

considered as potential nesting habitat.

According to NDOW, two Nevada State Protected Species could occur within the project area: the pale 

kangaroo mouse (Microdipodops pallidus) and the dark kangaroo mouse (Microdipodops megacephalus) 

(NDOW 2009). Field surveys were conducted in April 17–19 and May 5–19, 2010, to determine the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-28

presence or absence of these species in the Proposed Area and Alternative Area. Evaluating potential 

habitat it was found that there would not be suitable habitat in and around the borrow pit and 

transmission line, therefore surveys were not recommended for these components. Surveys for 

kangaroo mice consisted of a live-trapping effort within different habitats (soil units) of the Proposed 

Area and Alternative Area. Ten trap lines were established in the Proposed Area and Alternative Area 

(five trap lines in each) (Figure 3-7). Additionally, two trap lines were established outside the Proposed 

and Alternative Areas. Trapping efforts were conducted for up to four nights at each trapping location. 

Trapping did not occur within the borrow pit or TL areas (JBR 2010a). Information on habitat and soil 

preferences for the pale kangaroo mouse gathered during field surveys were used to identify the 

amount of potential habitat for kangaroo mice throughout the CESA.

3.4.2.2 Regulatory Framework

3.4.2.2.1 Endangered Species Act of 1973

The Endangered Species Act protects plants and animals that are listed by the federal government as 

“endangered” or “threatened.” The law requires federal agencies, in consultation with USFWS to ensure 

that actions they authorize, fund, or carry out are not likely to jeopardize the continued existence of any 

listed species or result in the destruction or adverse modification of designated critical habitat of such 

species. The law also prohibits any action that causes a “taking” of any listed species of endangered fish 

or wildlife. Likewise, the import, export, interstate, and foreign commerce of listed species are all 

generally prohibited.

3.4.2.2.2 Migratory Bird Treaty Act

The MBTA (16 USC 703) makes it unlawful to pursue, hunt, take, capture, kill, or possess any migratory 

bird, or part, nest, or egg of such bird listed in wildlife protection treaties among the United States and 

Great Britain (on behalf of Canada), Mexico, Japan, and the former Union of Soviet Socialist Republics. In 

addition, this act also contains a clause that prohibits baiting or poisoning of these bird species. The

current list of species covered by MBTA can be found in 50 CFR 10.13. Because several migratory bird 

species may occur within the study corridor, the MBTA applies to those bird species that may be 

affected during implementation of the proposed project. The MBTA (16 USC 701–718h) prohibits the 

“taking” of any migratory birds, including hunting, pursuing, wounding, killing, possessing, or 

transporting any migratory bird, nest, egg, or part thereof. 

3.4.2.2.3 Bald and Golden Eagle Protection Act

The Bald and golden eagle Protection Act (16 USC 668–668c) prohibits anyone, without a permit issued 

by the Secretary of the Interior, from “taking” bald eagles or golden eagles, including pursing, shooting, 

poisoning, wounding, killing, capturing, trapping, collecting, molesting, or disturbing bald eagles or 

golden eagles. The Act provides criminal penalties for persons who “take, possess, sell, purchase, barter, 

offer to sell, purchase or barter, transport, export or import, at any time or any manner any bald or 

golden eagle, alive or dead, or any part, nest, or egg thereof.”
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-29

3.4.2.2.4 BLM Policy

BLM has implemented policies for special status species found on BLM-managed lands. BLM’s list of 

special status species includes species that are listed or proposed for listing under the Endangered 

Species Act (ESA) and species requiring special management consideration to promote their 

conservation and reduce the likelihood and need for future listing under the ESA. Additionally, all federal 

candidate species, proposed species, and delisted species (for 5 years after delisting) will be conserved 

as BLM sensitive species (BLM 2008b).

3.4.2.2.5 Nevada Regulations

The State of Nevada has identified wildlife species that are declining in their range throughout Nevada 

or are otherwise rare and at risk of extinction. Sensitive and protected animal species are protected in 

Title 45 of NRS (NRS 501.100 through 503.104). Classification of wildlife species and related regulations

are detailed in Chapter 503 of NAC. Taking of these species is allowed only after obtaining necessary 

permits or authorizations from NDOW.

3.4.2.2.6 Nevada State Protection and Propagation of Native Fauna

NRS 503.584 through 503.589 provide for the protection and propagation of native fauna, including 

migratory birds. The Board of Wildlife Commissioners determines which species will be fully protected 

under this statute (i.e., State of Nevada Protected Species). 

3.4.2.2.7 South Central Nevada Sage Grouse Conservation Plan

This plan covers the south central portions of Nevada, including the project area, and was prepared by 

the South Central Planning Team, which consists of concerned citizens, property owners, land managers, 

land users, local governments, and other interested parties (South Central Planning Team 2004). The 

conservation strategy in this document reflects ideas consistent with the Management Guidelines for 

Sage Grouse and Sagebrush Ecosystems in Nevada (BLM 2000), and the Western Association of Fish and 

Wildlife Agencies (Connelly et al. 2000). The conservation plan includes an initial analysis of sage-grouse

populations and habitat within the south central Nevada sage-grouse planning area and indentifies 

management recommendations for these populations and habitats. 

3.4.2.3 Affected Environment

3.4.2.3.1 Proposed Area

Mammals

Four sensitive mammal species could potentially occur in the Proposed Area. The listing status, a 

description of suitable habitat, and an assessment of the potential for the species to occur and the 

potential for impacts to the species are included in Table 3-13.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-30

Table 3-13. Special status mammal species potentially found in the project area

Species Statusa Habitat Presence in Project Area

Pygmy Rabbit 

Brachylagus idahoensis BLM Dense sagebrush with friable soils

Unlikely, no evidence found in 

sagebrush habitats in borrow pit

area

Dark Kangaroo Mouse

Microdipodops megacephalus

NV 

Protected Gravelly to sandy habitats Potential 

Pale Kangaroo Mouse

Microdipodops pallidus

NV 

Protected Sandy habitats Potential

Desert Bighorn Sheep

Ovis canadensis nelsoni BLM Mountains Highly unlikely, other than crossing 

between mountain ranges

California Myotis

Myotis Californicus BLM

Lower Sonoran desert scrub to forests

Roosts in cliff crevices Potential forager in the area

Western Small-footed Myotis

Myotis ciliolabrum BLM

Desert scrub, grasslands, sagebrush 

steppe, pinyon-juniper woodlands

Roosts in caves, mines, and trees

Potential forager in the area

Long-eared Myotis

Myotis evotis

BLM

Found throughout the state primarily 

associated with forests.

Roosts in hollow trees, mines, caves 

and buildings

Unlikely except during migration

Little Brown Bat

Myotis lucifugus BLM

Primarily found at higher elevations 

and higher latitudes

Roosts in hollow trees, rock outcrops, 

buildings, and occasionally mines and 

caves

Unlikely except during migration

Fringed Myotis

Myotis thysanodes BLM

Found throughout central and 

southern Nevada in a wide variety of 

habitats from low desert scrub to high 

elevation forests

Roosts in mines, caves, trees and 

buildings

Potential forager in the area

Western Pipistrelle

Pipistrellus hesperus BLM

Lower and upper Sonoran desert 

habitats

Roosts in rock crevices, mines, caves, 

or occasionally buildings and 

vegetation

Potential forager in the area

Brazilian free-tailed bat

Tadarida brasiliensis BLM

Found in a wide variety of habitats 

throughout Nevada

Roosts in cliff faces, mines, caves, 

buildings, bridges and hollow trees

Potential forager in the area

a BLM = Nevada BLM Sensitive Species, NV Protected = protected under Nevada Revised Statutes 501.105 and listed under 

Nevada Administrative Code 503.030 

The pale kangaroo mouse relies on the sandy soils and the open salt desert scrub vegetation like the 

habitat that occurs near the dunes in the project area (Wilson and Ruff 1999). Although, the GAP 

vegetation data illustrate only a small area of the Active and Stabilized Dunes vegetation association 

(see Section 3.2, Vegetation) within the Proposed Area. Biologists noted that within the northeastern 

portion of the Proposed Area, the soils were sandier and contained more dune or “mini” dune features. 

Mini dune features are small sandy mounds that are vegetated with shrubs and little understory. This 

Mixed Salt Desert Scrub vegetation association was dominated by lemon scurfpea. Farther west of the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-31

dunes, the Mixed Salt Desert Scrub vegetation association was dominated by Nevada dalea and also 

contained sandy soil or inclusions of mini dune features. It is within these two habitats where the most 

pale kangaroo mice were captured (JBR 2010a); therefore, these areas were delineated as suitable 

habitat (Figure 3-7). A small area of barren land was identified as potential habitat because it was close 

to the dune and lemon scurf pea community, and even though it did not have any vegetation, sandy 

soils were present. Generally, pale kangaroo mice were not trapped at sites that lacked sandy soils, 

dune, or mini dune features. This included the southeastern portion of the proposed project site where 

Bailey’s greasewood was the dominant component of the Mixed Salt Desert Scrub vegetation 

association. Based on results of the field surveys, it was determined that kangaroo mouse suitable 

habitat was closely associated with two soil types including Dune Land (DU), and Tipperary fine sand 

(TGE). The Stumble Loamy Fine Sand soil type was identified both as suitable habitat and potential 

habitat. Within the proposed area, approximately 2,448 acres were identified as suitable habitat and 

287 acres were identified as potential habitat.

Although historical literature identifies stabilized dunes as habitat for the dark kangaroo mouse (Hall 

and Linsdale 1929), more recent research shows that dark kangaroo mice prefer gravelly soils in valley 

bottoms dominated by sagebrush, rabbitbrush, and horsebrush (Ghiselin 1970; Wilson and Ruff 1999). 

During surveys, no dark kangaroo mice were captured in the Proposed or Alternative Areas, or off-site. 

Additionally, no dark kangaroo mouse habitat was observed in the Proposed or Alternative Areas.

As illustrated in Table 3-13, a wide variety of special status bats have the potential to occur in the area. 

Generally, bats are unlikely to roost in the area as most bat species roost in trees, cliff faces, mines, and 

buildings (Bradley et al. 2006), which are not present in the project area. However, bats may potentially 

forage throughout the project area or migrate through the Lower Big Smoky Valley. 

Migratory Birds

Eleven bird species that are considered to have special status were observed or could potentially occur 

in the project area (Table 3-14). The listing status and a description of suitable habitat are included in 

Table 3-14.

In addition to the birds identified in Table 3-14, a wide variety of birds protected under the MBTA could 

utilize the Proposed Area for nesting, foraging, or as a migratory corridor. Field surveys were conducted 

during the avian spring migration period (May 2009, April/May 2010). Species observed included blackthroated sparrows (Amphispiza bilineata) and loggerhead shrike (Lanius ludovicianus). Like most valleys 

in Nevada, the Big Smoky Valley contains playas that may be seasonally inundated and wetlands that 

could provide temporary habitat for migrating birds such as American avocets, vesper sparrows, and 

Northern Harriers, as well as others (Great Basin Bird Observatory 2010). 
Crescent Dunes Road

¬«89

Pole Line Road

0 0.5 1

Miles

 Legend

Alternative Area

Proposed Area

Road

±

Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Pale_Kang_Mouse.mxd

Figure 3-7 Pale Kangaroo Mouse Habitat within

Proposed and Alternative areas

Crescent Dunes

Solar Energy Project

!

Project Site

NEVADA

Habitat Suitability

Not Suitable

Potential

Suitable

Vegetation Type

Barren Land

Greasewood

Lemon Scurfpea

Nevada Dalea
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-33

Golden Eagles

Golden eagles were observed in the region of the proposed project during 2010 field surveys and from 

anecdotal observations of field staff. Like much of the Big Smoky Valley, the project area is potential 

foraging habitat for golden eagles, though it provides no unique resources compared with the remaining 

area, and does not contain roosting or nesting habitat. Field surveys by BLM biologists confirmed that a 

golden eagle nest in the San Antonio Mountains, approximately 8 miles southeast from the project area, 

was active and contained young birds (BLM 2010a). One inactive nest was found approximately 4 miles 

east of the proposed project area. This nest was determined to be inactive and not occupied this season 

based on the lack of fresh whitewash and the sloughing of the nest material. Overall, the condition of 

the nest was considered fair to good.

Table 3-14. Birds considered special status species observed in or that may occur in the project area

Species Statusa Habitat Presence in Project Area

Sage Sparrow

Amphispiza belli BLM Sagebrush, saltbush, coastal 

scrub Potential, not observed

Golden Eagle

Aquila chrysaetos BLM Mountains, deserts, plains Potential forager, nests have been documented 

within 5 miles of the Proposed Area

Short-eared Owl

Asio flammeus BLM Open country, ground nester Potential, no evidence of nesting found

Burrowing Owl

Athene cunicularia BLM Open country, nest areas 

usually include elevated perch

Potential, very sandy nature of soils in majority 

of area may makes nesting unlikely

Swainson’s Hawk

Buteo swainsoni

BLM Open country, plains, prairie, 

agricultural areas Potential forager

Greater Sage-grouse

Centrocercus urophasianus

BLM

C Sagebrush habitats Unlikely, sagebrush in gravel pit area, but no 

evidence of sage-grouse found

Prairie Falcon

Falco mexicanus BLM Open country, nests on cliffs 

and outcrops Potential forager

Loggerhead Shrike

Lanius ludovicianus BLM Open country in greasewood, 

sagebrush, agricultural areas Observed in borrow pit area

Long-billed Curlew

Numenius americanus

BLM Wet and dry uplands, 

wetlands, agricultural fields Potential migrant

Vesper Sparrow

Pooecetes gramineus

BLM Grasslands, farmlands, forest 

clearings, sagebrush Potential migrant

Brewer’s Sparrow

Spizella breweri

NV 

Sensitive Sagebrush habitat Recorded in sagebrush in borrow pit area

a BLM = Nevada BLM Sensitive Species; NV Sensitive = protected under Nevada Revised Statutes (NRS) 501.105, NRS 501.110, 

NRS 501.181 and listed under Nevada Administrative Code 503.050; C = U.S. Fish and Wildlife Service candidate species

Reptiles

No special status reptiles were observed in or have the potential to occur within the Proposed Area.

Insects

Three BLM sensitive species of insects are endemic to the Crescent Dunes: Crescent Dunes Aegialia 

Scarab (Aegialia crescent), Crescent Dunes Aphodious Scarab (Aphodius sp.), and Crescent Dunes Sirican 

Scarab (Serica ammomenisco). According to NNHP, these species have been documented on Crescent 

Dunes. It is unlikely that these three species would be present in the Proposed Area because they are 

associated with the sand dunes and the dunes do not extend into the proposed project area. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-34

Alternative Area

Since the Alternative Area is directly adjacent to the Proposed Area, the existing environment for 

wildlife special status species is very similar. Also, since the Alternative Area overlaps the Crescent 

Dunes, it is likely that endemic beetle species are present within the Alternative Area. 

During 2010 trapping efforts, the presence of pale kangaroo mice was confirmed within the Alternative 

Area. Similar to the Proposed Area, more mice were caught in the eastern portion of the Alternative 

Area near the dunes where the Mixed Salt Desert Scrub Community was dominated by lemon scurfpea 

and Nevada dalea (Figure 3-7). Some pale kangaroo mice were caught in the Mixed Salt Desert Scrub 

vegetation association dominated by greasewood where sandier soils or mini dune features were 

present. However, no pale kangaroo mice were captured in the westernmost portion of the Alternative 

Area that was dominated by greasewood, where sandy soils or mini dune features were not present. 

Within the alternative area, approximately 1,936 acres were identified as suitable habitat and 1,227 

acres were identified as potential habitat.

3.4.2.3.2 Borrow Pit

Special status wildlife species composition is similar to that of the Proposed Area. Species that are 

dependent on habitat near or endemic to the Crescent Dunes such as kangaroo mice and beetle species 

are not likely to be found in the borrow pit area because of the lack of appropriate habitat.

3.4.2.3.3 TL and Anaconda Moly Substation

Special status wildlife species composition is similar to the Proposed Area. Species that are dependent 

on habitat near or endemic to the Crescent Sand Dunes such as kangaroo mice and various beetle 

species area not likely to be found within the TL and Anaconda Moly Substation corridor because of the 

lack of appropriate habitat.

3.4.2.3.4 CESA

Special status wildlife species composition is similar to the Proposed Area. Pale kangaroo mice likely are 

found throughout the CESA. Approximately 29,343 acres of potential or suitable pale kangaroo mouse 

habitat were identified throughout the CESA (Figure 3-8).

Golden eagles are likely to nest within the CESA. During field surveys, biologists observed that one 

previously identified nest was occupied approximately 8 miles southeast of the proposed project area as 

well as an abandoned nest approximately 4 miles east of the proposed project area. Additionally, 

biologists recorded two incidental sightings of golden eagles. Biologist observed that the potential 

habitat within the CESA is limited. Rocky cliffs in the San Antonio Mountains and utility poles throughout 

the valley may provide roosting opportunities. Potential nesting habitat within the CESA is limited to the 

cliff and rocky outcrops (i.e. inter-mountain basins cliff and canyon GAP land cover type). Approximately 

691 acres of potential nesting habitat exists within the San Antonio Mountains (Figure 3-9). 
0 5 10

Miles

±

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Big_smky_vlly_gwBasin.mxd

!

Project Site

NEVADA Figure 3-8 Pale Kangaroo Mouse Habitat

throughout the CESA

Crescent Dunes

Solar Energy Project

 Legend

Tonopah Flat sub area

Potential

Suitable

Planned Transmission Line

Alternative Area

Proposed Area
Tonopah

0 2.5 5

Miles

Legend

Alternative Area

Proposed Site

Planned

Inter-Mountain Basins Cliff and Canyon

±

Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Veg_CESA_10mile.mxd

Figure 3-9. Potential Golden Eagle 

Nesting Habitat Throughout the CESA.

Crescent Dunes Solar Energy Project !

Project Site

NEVADA

(i.e. potential golden eagle habitat)
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-37

3.5 Water Quality and Quantity

3.5.1 Area of Analysis and Methodology 

The area of analysis for water quality and quantity includes the Project Area, Alternative Area, borrow 

pit, and the TL and Anaconda Moly Substation corridor. In addition, there are two CESAs:

• Groundwater CESA – The 1-foot, 53-year draw down contour for the proposed groundwater well 

(Figure 3-10). The CESA for groundwater resources was developed using a numerical model 

developed by WorleyParsons (WorleyParsons 2010c) in cooperation with the BLM Nevada State 

Office. The full report is available at the BLM TFO for review. 

• Surface water and stormwater drainage CESA – The subbasin within the Tonopah Flat (137A) 

hydrographic basin of the Big Smoky Valley watershed (see Figure 2-15). A subbasin has been 

delineated to define the CESA. The subbasin encompasses the northeastern quarter within 

hydrologic basin 137A. This subbasin accounts for the drainage area upstream of the project 

location bound by the San Antonio Range to the east, the Toiyabe Range to the north, and the 

valley downstream to the southwest where Peavine Creek drains. Aerial photography and USGS 

10-foot interval topographic mapping was used to determine the hydrologic limits of the 

subbasin. This subbasin is considered the CESA for water quality and quantity. 

3.5.2 Regulatory Framework 

BLM is authorized by Section 313 of the Clean Water Act as amended (33 U.S.C. 1323), Section 1447 of 

the Public Health Service Act, as amended by the Safe Drinking Water Act (42 U.S.C. 300j-6), Section 

6001 of the Solid Waste Disposal Act, as amended (42 U.S.C. 6961) and Section 22 of the Toxic 

Substances Control Act and Section 301 of Title Three of the United States Code to insure Federal 

compliance with the applicable pollution control requirements.

Nevada water law is based on prior appropriation and beneficial use. All water within the boundaries of 

the state, whether above or beneath the surface of the ground, belongs to the public and is subject to 

appropriation for beneficial use under the laws of the state (WorleyParsons 2010a). 

An application with the State of Nevada has been filed by TSE for permission to retire active irrigation 

groundwater rights near the project area and to divert the rights approximately 10.6 miles southeast to 

the project area for industrial water use. The anticipated groundwater right quantity (consumptive use) 

to be granted to TSE and available for transfer is 854 AFY. It is estimated that only 600 AFY would be 

needed for facility operations. 

3.5.3 Affected Environment 

3.5.3.1 Groundwater

The project area is located in the Central Hydrographic Region and overlies the basin fill aquifer system 

that is composed primarily of alluvial, colluvial, and lacustrine deposits. Groundwater in the Tonopah 

Flat subarea flows horizontally from the mountains surrounding the subarea to the valley floor, reaching 

the water table through watercourse infiltration or percolation into rock fractures. 
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^`^`^`

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^`

^`^`^`^` ^`

^`

^`^`^`^`

^` ^`

^`^`

^`^`^`

^`

^`

Nevada 

To Las Vegas

Proposed Area/

Alternative Area

Anaconda-Moly Substation

Borrow Pit

Big Smoky Valley

Transmission Line

Ralston Valley

Gabbs Valley Ione Valley

Clayton Valley

Monte Cristo Valley

Alkali Spring Valley

Fish Lake Valley

Big Smoky Valley

Columbus Salt Marsh Valley

Soda Spring Valley

Upper Reese River Valley

Rhodes Salt Marsh Valley

Stonewall Flat

Ralston Valley

Monitor Valley

Ione Wash

Peavine Creek

Big Wash

Slime Wash

Mud Spring

Red Spring

Mud Spring

Alum Spring

Rojo Spring Warm Spring

Gale Spring

Pipe Spring

Troy Spring

Cook SpringCook Spring

Lobo Spring

Cave SpringCave Spring

Deep SpringDeep Spring

Hunts Spring

Black Spring

Davis Spring

Betty Spring

Prody Spring

North SpringNorth Spring Twin Springs

Mamie SpringMamie Spring

Milton Spring

Willow Spring

Golden Spring Keough Spring

Seyler Spring

Yellow Spring Barrel Spring

Keller Spring

Barrel Spring

Indian Spring

Willow Spring

Baxter Spring

Graham Spring

Yellow Spring

Summit Spring

Barrel Spring

Coyote Spring

B and C Spring

Soldier Spring

Stevens Spring

Mustang Spring Stewart Spring

Indian Springs Spanish Spring

Warlock Spring

Mustang Spring Outlaw Springs

Paradise Spring

Rat Trap Spring

Ryecroft Spring

Antelope Spring

Fourmile Spring

Humphrey Spring Mitchell Spring Snowbird Spring

Roadside Spring

Millsite Spring

Cinnabar Spring

Antelope Spring

Macaroni Spring

Valcalda Spring

Valcalda Spring

Woodchuck Spring

Ledbetter Spring

Ink House Spring

Palo Alto Spring

Cornelius Spring

Blue Link Spring

Minnesota Spring

Peppercorn Spring

Wild Horse Spring

Pipe Organ Spring

Black Jack Spring

Alkali Hot Spring

Boyd Canyon Spring

West Willow Spring

Coyote Hole Spring

Fitzpatrick Spring

Brush Rabbit Spring

Mississippi Springs

Upper Summit Spring

Cedar Corral Spring

Bettles Ranch Spring

Barney Meadows Spring

East Manhattan Spring

Cottonwood Basin Spring

0 5 10

Miles

Legend

!. Spring/Seep

Ephemeral Stream

Transmission Line

^` PWR

Borrow Pit (40 acre)

Basin Boundaries

Alternative Area

Proposed Area

53 Year 1' Drawdown

(CESA)

±

Source: ESRI 2010, USGS Seamless GIS Data Web Server

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Surface_wtr_res.mxd

Tonopah

!

Project Site

NEVADA Figure 3-10 Surface Water Resources

Crescent Dunes

Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-39

There are many springs and seeps within the Tonopah Flat (137A) hydrographic basin (Figure 3-11). 

Most springs are located in bedrock areas, and the closest springs to the project area are more than 10 

miles away (WorleyParsons 2010a). A BLM database and a USGS National Hydrography Dataset both 

identify seeps, springs, and wells. An assessment of these databases indicates that no springs or seeps 

exist within the groundwater CESA.

The general depth to water in the Tonopah Flat subarea is typically greater than 100 feet bgs, and some 

central locations of the subarea have depths to groundwater ranging from 0–100 feet bgs (Figure 3-11). 

The test well drilled by TSE indicates that the depth to groundwater at the project area is approximately 

172 feet bgs. 

Historical groundwater consumption in the undeveloped Tonopah Flat subarea is attributed to 

agriculture water use. This includes irrigation of crop and pasture land and stock watering. Current 

groundwater consumption is summarized in Table 3-15. 

Table 3-15. Current groundwater consumption in the Tonopah Flat subarea

Manner of Use

Nevada Division of Water Resources 

(2010)

Nye County Water Resources Plan 

(Buqo 2004)

acre-feet per year acre-feet per year

Irrigation 10,204.69 11,797.00 

Mining and Milling 8,330.76 12,683 

Municipal 58.95 1,507 

Quasi-Municipal 20.84 14 

Stockwater 916.31 864 

Total 19,531.55 26,865.00 

Source: WorleyParsons 2010

The Tonopah subarea reportedly has 12,000 acre-feet (AF) of annual recharge, 2,000 AF of annual 

inflow, 6,000 AF of annual evapotranspiration, and 8,000 AF of annual outflow (Buqo 2004). The 

perennial yield (safe yield) is estimated at 6,000 AF per year (Buqo 2004). The total water rights demand 

through March 1999 was reportedly at 26,724 AF per year (AFY). However, these are the estimated 

committed water rights in the subarea and do not represent the actual groundwater withdrawal and 

consumption, which are significantly less (Buqo 2004). The majority of the water rights are committed to 

irrigation, mining, and milling. 

Total dissolved solids (TDS) are very low in surface water as precipitation enters the Tonopah Flat 

subarea hydrologic system. TDS increases as surface water flows from the mountains to the valley. 

Similarly, groundwater TDS is lowest in the mountains and highest in the valley where water is 

evaporated or vegetation is present. In general, the groundwater quality in the subarea is suitable to 

marginally suitable, but groundwater in portions of the subarea where groundwater is shallow exceeds 

state and/or federal drinking water standards for TDS (WorleyParsons 2010a).
Source: Worley Parsons, 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Gen_Depth2_Grndwtr.mxd

± Figure 3-11 Generalized

Depth to Groundwater

Crescent Dunes Solar Energy Project

!

Project Site

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-41

According to the Nevada State Engineer well log database, there are 173 logged wells within the 

Tonopah Flat subarea, and they are shown on Figure 3-12 (State of Nevada Department of Conservation 

and Natural Resources Division of Water Resources 2010). Several of the wells closest to the project 

location are summarized in Table 3-16, based on data (WorleyParsons 2010a) tabulated from the 

Nevada State Engineers well log. 

Table 3-16. Summary of wells within the project CESA

Well 

Number

Well Depth 

(feet below 

ground surface) 

Water Level 

(feet below 

ground surface) 

Water Quality Use/Notes

11 280 50 Good Municipal

12 350 36 Not available Quasi-municipal

13 100 40 Not available Mining

16 312 9 Not available Domestic

21 30 15 Not available Unknown

22 30 No water Not available Unknown

23 400 Dry Not available Abandoned stock

24 179 20 Not available Domestic

43 200 Not available Not available Abandoned, cemented

44 220 104 Good Stock, replacement well

45 255 68 Not available Stock

3.5.3.1.1 Proposed Area

The Proposed Area is located in the region where the depth to groundwater is greater than 100 feet bgs. 

A TSE test well has been drilled and installed near the northern boundary of the area. Groundwater 

wells numbers 43 and 44 are located outside of the southeastern corner of the Proposed Area boundary

(State of Nevada Department of conservation and Natural Resources Division of Water Resources 2010). 

Rogers Well (USGS 2010) is located within 1 mile of the western boundary of the Proposed Area. No 

seeps or springs are located within the Proposed Area boundary. 

3.5.3.1.2 Alternative Area

The Alternative Area is located in the region where the depth to groundwater is greater than 100 feet 

bgs. There are no existing wells located within the boundary of the Alternative Area, but the TSE test 

well will be drilled and installed near the southern boundary of the area. No seeps or springs are located 

within the Alternative Area boundary. 

3.5.3.1.3 Borrow Pit

The borrow pit is located in the region where the depth to groundwater ranges from 50–100 feet bgs. 

No seeps, springs, or existing wells are located in the vicinity of the borrow pit. 
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Proposed Area/

Alternatives

Anaconda-Moly Substation

Borrow Pit

Big Smoky Valley

Transmission Line

Ralston Valley

Clayton Valley

Alkali Spring Valley

Ralston Valley

45

12

11

13

16

23 24

21/22

43/44

Mikes Well

Rays Wells

Blair Well

Desert Well

Davids Well

Henrys Well

Chance Well

Bridge Well

Big 10 Well

Peavine Well

Fraziers Well

San Antonio Well

Spanish Pipeline Well

0 2.5 5

Miles

Legend

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!( Water Wells

!( Oil and Gas Wells

Transmission Line

Alternative Area

Proposed Area

Basin Boundaries

53 Year 1' Drawdown (CESA)

±

Source: ESRI 2010, USGS Seamless GIS Data Web Server

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Well_locations.mxd

Tonopah

!

Project Site

NEVADA Figure 3-12 Well Locations

Crescent Dunes

Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-43

3.5.3.1.4 TL and Anaconda Moly Substation

The TL corridor and the Anaconda Moly Substation are located in the region where the depth to 

groundwater is greater than 100 feet bgs. No seeps, springs, or existing wells are located within the TL

corridor or at the Anaconda Moly Substation. Seven sink/rise locations have been identified within a 

1-mile buffer of the TL corridor (USGS 2010). 

3.5.3.1.5 CESA

Nine existing groundwater wells are located within the CESA. Well numbers 11, 12, 13, 16, 21, 22, 

and 23 are located between the 1- and 1.5-foot draw down contours. Well numbers 43 and 44 are 

located at the 2-foot draw down contour, see Figure 3-12 (WorleyParsons 2010a).

3.5.3.2 Surface Water

Hydrographic basin 137A of the Big Smoky Valley (Tonopah Flat subarea) is a semiarid to arid desert 

climate that has a season of winter cold fronts and a season of summer monsoons. Most precipitation 

falls in the winter, with an annual average precipitation of 4–8 inches per year over the basin 

(WorleyParsons 2010a). Because most of the precipitation in the area falls in the mountains, the primary 

source of surface water is generated from runoff in short watercourses in the surrounding mountain 

ranges. These watercourses drain steeply to the adjacent valleys, where they seep into the sediments 

and evaporate.

Within the Tonopah Flat subarea, the majority of the basin alluvial valley is undeveloped desert 

rangeland, with patches of agriculture, surrounded by rocky mountain ranges. The basin’s primary 

source of surface water is stormwater runoff in intermittent streams originating in the Toiyabe Range 

and stormwater flowing southeast into Tonopah Flat from Ione Valley, including Knickerbocker, 

Cloverdale, Cottonwood, and Peavine creeks (WorleyParsons 2010a). Peavine Creek, the largest 

drainage from Toiyabe Range to Tonopah Flat, passes approximately 2 miles west and downgrade of the 

project location, terminating as it loses flow on the alluvial apron of the valley floor. Figure 3-10 shows 

the surface water resources in the basin.

Approximately 30 springs and seeps were identified around the boundary of the Tonopah Flat subarea. 

Most springs identified by WorleyParsons are located in bedrock areas, with the closest springs and 

seeps located more than 10 miles from the project area (WorleyParsons 2010a). 

Within this subbasin, one watercourse has a mapped floodplain. Peavine Creek is a Federal Emergency 

Management Agency (FEMA) mapped effective Zone A floodplain (FEMA FIRM 32023C4450E,

February 17, 2010). A Zone A floodplain has a 1 percent annual chance of flooding. It should be noted 

that a detailed analysis has not been performed for the area, so no depth or base flood elevation is 

given. 

Aerial photographs and USGS maps of the area show several ephemeral drainage paths that drain west 

from the San Antonio Range and pass through the CESA. JBR conducted a field visit in the area and 

concluded that these ephemeral drainage paths lose definition and do not reach Peavine Creek 

(JBR 2009). Based on preliminary field surveys, JBR recommended to the USACE that Peavine Creek and 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-44

its tributaries are isolated intrastate waters with no apparent interstate or foreign commerce 

connection and would, therefore, not be considered subject to jurisdiction under the Clean Water Act 

(JBR 2009). 

Federal reserved water rights are primarily limited to Public Water Reserves (PWRs) for the BLM in 

Nevada. In 1926, an EO created “Public Water Reserves No. 107,” which ended the site-specific system 

of reserving springs and water holes. Prior to PWR 107, federal agencies identified springs and public 

water holes to be reserved as chronologically numbered PWRs. PWR 107 was created to reserve public 

water holes and natural springs yielding amounts in excess of homesteading requirements. This order 

states that “legal subdivision(s) of public land surveys which is vacant, unappropriated, unreserved 

public land and contains a spring or water hole, and all land within one quarter of a mile of every spring 

or water be reserved for public use” (BLM 2010b). PWR 107 was not intended to reserve the entire yield 

of each public spring or water hole. All waters from these sources in excess of the minimum amount 

necessary for domestic human consumption and stock watering purposes are available for appropriation 

through state water law. 

3.5.3.2.1 Proposed Area

The Proposed Area is located primarily in undeveloped desert rangeland and is set at the foothills of the 

San Antonio Range. There are a few existing ephemeral surface water drainage paths that meander 

across the Proposed Area boundary, draining to the west from the San Antonio Mountains and Crescent 

Dunes (Figure 3-10). Ephemeral washes show the path that surface water runoff typically takes during 

intense storms. The Proposed Area has very low vegetation density, which is common with ephemeral 

wash conditions. 

There is a culvert crossing under SH 89, but a field visit conducted by JBR revealed that the ephemeral 

drainage paths that cross the Proposed Area lose definition before reaching the culvert at the highway 

(JBR 2009). 

Off-area stormwater sheet flow may be allowed to follow its present drainage paths and continue to 

flow through the project area where the solar field would be constructed. If it is decided that the offarea storm flows will be routed around the area (after detailed design and consultation with Nye 

County), flows would discharge to historic flow paths downstream of the area. If detention basins are 

required for storm flows from the solar field, they will be sized to meet current stormwater 

requirements. 

No PWR 107 waters are located within the limits of the Proposed Area.

3.5.3.2.2 Alternative Area

Located directly north of the Proposed Area, the Alternative Area is also located at the foothills of the 

San Antonio Range where the land is primarily undeveloped desert rangeland. There is one potential 

existing ephemeral drainage path crossing into the Alternative Area at the eastern boundary.

No PWR 107 waters are located within the limits of the Alternative Area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-45

3.5.3.2.3 Borrow Pit

The borrow pit is located northwest of the project area location and just southeast of the intersection of 

Peavine Creek and SH 89. A culvert crossing under SH 89 conveys Peavine Creek’s intermittent flow. An 

ephemeral reach branches from Peavine Creek upstream of SH 89 and passes through the borrow pit

area. 

No PWR 107 waters are located within the limits of the proposed borrow pit.

3.5.3.2.4 TL and Anaconda Moly Substation

Several existing ephemeral drainage paths from the San Antonio Range cross the proposed TL corridor. 

The ephemeral drainages cross in various locations starting at a point where the corridor turns east from 

SH 89 and continues along the existing TL to the Anaconda Moly Substation. None of these ephemeral 

washes reach Peavine Creek. 

No PWR 107 waters are located within the limits of the proposed TL and substation corridor.

3.5.3.2.5 CESA

The ephemeral washes discussed above continue through the CESA, ending at the ephemeral Peavine 

Creek. No seeps and springs are located within the defined CESA.

Several PWR 107 waters are located within the surface water CESA. The closest PWR 107 is located 

approximately 4.5 miles northeast of the northeastern corner of the Alternative Area. Three are located 

just outside of the surface water CESA limits, approximately 6 miles southeast from the southeastern

corner of the proposed site. 

3.6 Air Quality

3.6.1 Area of Analysis 

The area of analysis for air quality includes hydrographic subbasins 53, 139, and 153, which 

encompasses all of the Proposed Area, Alternative Area, borrow pit, and TL and Anaconda Moly 

Substation corridor. The CESA includes the same area. 

3.6.2 Regulatory Framework 

3.6.2.1 Federal Air Quality Regulations

The federal Clean Air Act of 1970 was the first comprehensive legislation aimed at reducing levels of air 

pollution throughout the country. The 1970 law required the EPA to establish National Ambient Air 

Quality Standards (NAAQS), which set maximum allowable concentrations for six criteria pollutants: 

carbon monoxide, nitrogen dioxide, ozone, particulate matter, sulfur dioxide, and lead, as shown in 

Table 3-17 and briefly described below.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-46

Table 3-17. National Ambient Air Quality Standards

Pollutant Averaging Time Primary Standard Secondary Standard

Carbon monoxide (CO)

1-hour 35 ppma NSb

8-hour 9 ppm NS

Nitrogen dioxide (NO2) 

1-hour 0.100 ppmc NS

Annual 0.053 ppm 0.053 ppm

Ozone (O3) 

8-hour

(1997 standard) 0.08 ppmd 0.08 ppm

8-hour

(2008 standard) 0.075 ppmd 0.075 ppm

Particulate matter (PM10) 24-hour 150 μg/m3 e 150 μg/m3

Fine particulate matter (PM2.5) 

24-hour 35 μg/m3 35 μg/m3

Annual 15 μg/m3 15 μg/m3

Sulfur dioxide (SO2) 

3-hour NS 0.5 ppm

24-hour 0.14 ppm NS

Annual 0.03 ppm NS

Lead Rolling 3-month average 0.15 μg/m3 0.15 μg/m3

Quarterly 1.5 μg/m3 1.5 μg/m3

Source: 40 Code of Federal Regulations § 50 a parts per million

b no standard

c based on a 3-year average of the 98th percentile of the daily maximum 1-hour average d based on a 3-year average of the 4th highest concentration e micrograms per cubic meter

Carbon monoxide (CO) is a colorless, odorless gas resulting from the incomplete combustion of carbonbased fuels, including petroleum products. In most areas, vehicle emissions are the primary source of 

CO. 

Nitrogen dioxide (NO2) is a yellowish-orange to reddish-brown gas resulting from high temperature 

combustion. Diesel vehicles and power plants are major sources of NO2. 

Ozone (O3) is produced through a complex chemical reaction in which precursor compounds, such as 

hydrocarbons and nitrogen oxides, are transformed by sunlight into O3 molecules, which consist of three 

oxygen atoms. The primary sources for O3 precursors are vehicle and industrial emissions.

Particulate matter (PM10 and PM2.5) consists of suspended dust, fibers, combustion ash, and other fine 

particles. The major source is industrial emissions, but it also results from diesel vehicle emissions, 

unpaved roadways, agricultural activity, and mechanical resuspension on paved roads from vehicle 

activity.

Sulfur dioxide (SO2) is a colorless gas with a rotten egg odor that results from the combustion of fuels 

containing sulfur. Primary sources are coal-fired power plants, industrial plants, and metals smelters, 

with some emissions from diesel vehicles burning low-grade fuels.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-47

Lead in the atmosphere results primarily from the burning of leaded fuels; this type of pollution has 

been drastically reduced in the United States in recent years with the ban on leaded automobile fuels.

Amendments to the Clean Air Act were passed in 1977 and 1990. Among many revisions included in the 

amendments are requirements for nonattainment areas and State Implementation Plans for areas that 

do not meet the standards.

For most of the criteria pollutants, two standards have been established: a primary standard and a 

secondary standard. The primary standard was established with the goal of protecting public health, 

while the secondary standard is intended for the protection of the public welfare.

3.6.2.1.1 Class I Federal Lands

Class I federal lands consist of 156 national parks and wilderness areas across the country for which 

pristine air quality and visibility are protected. Regulations pertaining to Class I areas affect major 

projects within 100 kilometers (about 60 miles) of designated lands.

The nearest Class I areas to the project area are a series of national parks and wilderness areas in the 

Sierra Nevada of California, including Yosemite National Park, Kings Canyon National Park, John Muir 

Wilderness, and Ansel Adams Wilderness. The closest of these areas is approximately 90 miles 

(150 kilometers) from the project area, which is outside of the 100-kilometer regulatory threshold.

3.6.2.2 State Air Quality Regulations

Nevada has established state-specific ambient air quality standards, which are maintained by the NDEP. 

With a few exceptions, the Nevada standards mirror the NAAQS (NDEP 2010a). Notable differences in 

the two sets of standards, with the Nevada standard being more stringent than the NAAQS, are:

• hydrogen sulfide (0.08 parts per million [ppm], 1-hour average)

• a separate CO standard for elevations at or above 5,000 feet above sea level (6 ppm, 8-hour 

average)

• an 03 standard specific to the Lake Tahoe Basin (0.10 ppm, 1-hour average)

Recent changes in the NAAQS have made them more stringent than the state standards for several of 

the pollutants, specifically NO2, O3, lead, and PM2.5. 

3.6.2.3 Local Air Quality Regulations

The project area is located in the northwestern portion of Nye County, which regulates air quality in 

terms of dust control for construction areas; however, those regulations apply only in the Pahrump 

Regional Planning District in the southern portion of the county. There are no local air quality 

regulations applicable to the project area.

3.6.2.4 Potential Permits

The NDEP Bureau of Air Pollution Control issues several types of permits for construction and operation 

of projects (NDEP 2010a). The type of permit required depends on the project size and quantity of 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-48

pollutant emissions expected from the project. Major sources—those generating more than 100 tons 

per year of any one regulated pollutant—require a Class 1 permit, while minor sources—those 

generating less than 100 tons per year of any one regulated pollutant—require a Class 2 permit. A third 

classification, a Class 3 permit, is available for small sources generating less than 5 tons per year in total 

regulated air pollutants. For construction activities, a Surface Area Disturbance permit is required if the 

total surface area disturbance is greater than 5 acres.

For the proposed project, a Surface Area Disturbance permit would be required for construction and 

either a Class 2 or Class 3 permit would be required for facility operation. The actual class of permit 

needed would be determined through modeling and dispersion of project-generated emissions.

3.6.3 Climate Change 

Ongoing scientific research as identified the potential impacts of anthropogenic (i.e., man-made) 

greenhouse gas (GHG) emissions and changes in biological carbon dequestration due to land 

management activities on global climate. Through complex interactions on a regional and global scale, 

these GHG emissions and net losses of biological carbon sinks cause a net warming effect of the 

atmosphere, primarily by decreasing the amount of heat energy radiated by the earth back into spacel 

Although GHG levels have varied for millennia, recent industrialization and burning of fossil carbon 

sources have caused CO2 concentrations to increase dramatically, and are likely to contribute to overall 

global climatic changes. The Intergovernmental Panel on Climate Change (IPCC) recently concluded that 

“warming of the climate system in unequivocal” and “most of the observed increase in globally average 

temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic 

greenhouse gas concentrations.” 

Global mean surface temperatures have increased nearly 1.8°F from 1890 to 2006. Models indicate that 

average temperature changes are likely to be greater in the Northern Hemisphere. Northern latitudes 

(above 24°N) have exhibited temperature increases of nearly 2.1°F since 1900, with nearly a 1.8°F 

increase since 1970 alone. Without additional meteorological monitoring systems, it is difficult to 

determine the spatial and temporal variability and change of climatic conditions, but increasing 

concentrations of GHGs are likely to accelerate the rate of climate change.

In 2001, the IPCC indicated that by the year 2100, global average surface temperatures would increase 

2.5 to 10.4°F above 1990 levels. The National Academy of Sciences has confirmed these findings, but 

also has indicated thare are uncertainties regarding how climate changes may affect different regions. 

Computer model predictions indicate that increases in temperature would not be equally distributed, 

but are likely to be accentuated at higher latitudes. Warming during the winter months is expected to be 

greater than during the summer, and increases in daily minimum temperatures is more likely than 

increases in daily maximum temperatures. Increases in temperatures would increase water vapor in the 

atmosphere, and reduce soil moisture, increasing generalized drought conditions, while at the same 

time enhancing heavy storm events. Although large-scale spatial shifes in precipitation distribution may 

occur, these changes are more uncertain and difficult to predict.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-49

As with any field of scientific study, there are uncertainties associated with the science of climate 

change. This does not imply that scientists do not have confidence in many aspects of climate change 

science. Some aspects of the science are known with virtual certainty, because they are based on wellknown physical laws and documents trends (USEPA 2008).

Several activities contribute to the phenomena of climate change, including emissions of GHGs 

(especially CO2 and methane) from fossil fuel development, large wildfires, and activities using 

combustion engines; changes to the natural carbon cycle; and changes to radiative forces and 

reflectivity (albedo). It is important to note that GHGs would have a sustained climatic impact over 

different temporal scales. For example, recent emissions of CO2 can influence climate for 100 years.

It may be difficult to discern whether glocal climate change is already affecting resources in the 

proposed project area. In most cases, there is more information about potential or projected effects of 

global blimate change on resources. It is important to note that projected changes are likely to occur 

over several decades to a century. Therefore, many of the projected changes associated with climate 

change may not be measurably discernible within the reasonably foreseeable future.

3.6.4 Affected Environment 

3.6.4.1 Regional Climate

The project area is located in the northwestern portion of Nye County in southwestern Nevada. The 

project area is situated at an elevation of approximately 5,000 feet above sea level and lies within a 

portion of the Great Basin Desert. Climate in the Great Basin Desert is characterized by hot summers, 

cold winters, and very low precipitation. 

The nearest weather station to the project area is at the Tonopah Airport, approximately 15 miles 

southeast of the project area. Average daily maximum temperatures recorded at this station during the 

summer months range between 84°F and 91°F. Average minimum daily temperatures in the winter 

months range between 19°F and 24°F. Annual precipitation averages just less than 6 inches and is 

distributed throughout the year. Total annual snowfall averages about 13 inches, but accumulation is 

uncommon, as monthly snow depth averages 0 inches. A summary of average temperature and 

precipitation is presented in Table 3-18. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-50

Table 3-18. Climate data for Tonopah Airport, Nevada (1971–2000)

Month Average Daily

Temperature (°F)a

Average Daily

Maximum

Temperature (°F)

Average Daily

Minimum

Temperature (°F)

Average

Precipitation

(inches)

January 32.1 44.4 19.8 0.47 

February 37.1 49.8 24.3 0.56 

March 42.4 56.1 28.7 0.62 

April 49.0 63.8 34.1 0.46 

May 57.8 73.3 42.3 0.62 

June 67.4 84.2 50.5 0.33 

July 73.6 91.0 56.2 0.47 

August 71.5 88.5 54.5 0.68 

September 63.8 80.1 47.4 0.51 

October 52.5 68.0 37.0 0.40 

November 38.5 51.7 25.3 0.43 

December 32.2 44.9 19.5 0.35 

Annual 51.6 66.5 36.7 5.90 

Source: Western Regional Climate Center 2010b a in degrees Fahrenheit

3.6.4.2 Proposed Area

The NDEP Bureau of Air Quality Planning maintains a network of air monitoring sites throughout most of 

Nevada, although Washoe and Clark counties conduct their own air quality monitoring. Monitoring sites

vary in the extent and number of pollutants monitored, with some sites monitoring one pollutant and 

others monitoring several pollutants. Some of the monitoring sites operate for the entire year, while 

others operate for the peak pollutant season only.

There are no monitoring sites near the project area. The nearest monitoring sites to the project area are 

the Fallon Site, located at West End Elementary School in Fallon, approximately 110 miles northwest of 

the project area, and four sites located around Pahrump, approximately 155 miles southeast of the 

project area. The Fallon monitoring site collects data on O3 only, while the Pahrump monitoring sites

collect data on PM10 only. The Fallon site recorded 1 day above the 8-hour O3 standard, and the 

Pahrump-Wilson Road site recorded 2 days above the 24-hour PM10 standard. Exceedances, however, 

are based on longer-term trends. For O3, the standard is based on a 3-year average of the fourth-highest 

daily maximum 8-hour average concentration. For PM10, the standard is not to be exceeded more than 

once per year on average over a 3-year period. There were no exceedances of either the 8-hour O3 or 

the 24-hour PM10 standard at the Fallon or Pahrump monitoring sites. A summary of the concentrations 

monitored at these locations is presented in Table 3-19. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-51

Table 3-19. 2008 air quality monitoring data 

Monitoring

Site Pollutant AveragingTime

Concentration Number of 

Days Above

Standarda

Number of 

Exceedancesa

Maximum Fourth

Highest

Fallonb O3 8-hour 0.078 ppmc 0.068 ppm 1 0 

Pahrump –

Linda Streetd PM10 24-hour 63 μg/m3 e 57 μg/m3 0 0 

Pahrump – 

Red Buttef PM10 24-hour 126 μg/m3 75 μg/m3 0 0 

Pahrump - 

Gamebirdg PM10 24-hour 94 μg/m3 74 μg/m3 0 0 

Pahrump – 

Wilson Roadh PM10 24-hour 223 μg/m3 119 μg/m3 2 0 

Source: U.S. Environmental Protection Agency 2010 a The National Ambient Air Quality Standards for ozone (O3) and particulate matter (PM10) are based on 3-year averages. The 

number of days above the standard column is for information only, because these data alone do not result in a violation. The 

number of exceedances column show violations of the standard.

b West End Elementary School, 280 South Russell Street, EPA Area ID 32-001-0002 c parts per million

d 8825 North Linda Street, EPA Area ID 32-023-0011 e micrograms per cubic meter

f

1500 Red Butte, EPA Area ID 32-023-0012 g 781 East Gamebird, EPA Area ID 32-023-0013 h 1020 East Wilson Road, EPA Area ID 32-023-0014 

The Clean Air Act amendments of 1977 and 1990 authorized the EPA to designate areas that have not 

met the NAAQS as being in nonattainment and to classify the severity of the nonattainment. Each 

nonattainment area requires a State Implementation Plan that outlines the actions that will be taken to 

reduce air pollution to levels that achieve compliance with the NAAQS. This proposed project lies within 

an area that is designated as being in attainment for all of the NAAQS.

3.6.4.3 Alternative Area

Conditions for the Alternative Area are the same as for the Proposed Area.

3.6.4.4 Borrow Pit

Conditions for the borrow pit are the same as for the Proposed Area.

3.6.4.5 TL and Anaconda Moly Substation

Conditions for the TL and Anaconda Moly Substation are the same as for the Proposed Area.

3.6.4.6 CESA

Conditions for the CESA are the same as for the Proposed Area.
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3.7 Cultural Resources

3.7.1 Area of Analysis and Methodology 

The area of analysis, hereafter referred to as the area of potential effect (APE), includes the Proposed 

Area, Alternative Area, borrow pit, the TL, the Anaconda Moly Substation, and a 1-mile radius. Figure 3-1 

shows the project area. A Class I cultural resource inventory was performed for the APE; a Class III 

survey was performed within the project area (proposed area, alternative area, TL, substation, and 

borrow pit). 

The APE for Native American values includes the proposed project area, as well as the CESA, defined as 

the project viewshed. Steward (1938) documented that the Wiyumahunovi (buffalo berry water valley; 

Big Smoky Valley) was home to a Western Shoshone band called the Wiymbitükanü (buffalo berry 

eaters). The valley was a favored gathering area of the Wiymbitükanü and other Western Shoshone 

bands for seeds from the hukümbi and töpoi roots (both plants were unidentified by Steward). Big 

Smoky Valley is still home to descendents of the Wiymbitükanü, who are organized into a group called 

the Western Shoshone Descendents of the Big Smoky Valley.

The following is a brief description of the methods used to conduct the literature review and Class III 

cultural resources survey. 

3.7.1.1 Literature Review

Information regarding previously documented cultural resources was obtained from the BLM TFO in 

Tonopah, Nevada; the online Nevada Cultural Resources Information System; BLM General Land Office 

plat maps and historic topographic and other maps accessed at the University of Nevada, Reno; Mary B. 

Ansari Map Library; and on the Nevada Bureau of Mining and Geology Web site. Data included previous 

cultural resource investigations and documented cultural resources. The literature review covered the 

area of analysis.

3.7.1.2 Survey

Intensive Class III cultural resource surveys were conducted within the project area , the results of which 

are reported in A Cultural Resources Inventory for a Solar Development near Crescent Dunes, Nye 

County, Nevada (Malinky and Harmon 2009) and Crescent Dunes Extensions, Nye County, Nevada

(Risse 2010). The Malinky and Harmon (2009) survey encompassed the Proposed Area, borrow pit, TL, 

and Anaconda Moly Substation corridor; the Risse (2010) survey covered the Alternative Area. The 

purpose of fieldwork was to identify historic properties that might be adversely affected by this project. 

The surveys were conducted with 100 percent ground surface coverage within the area of analysis 

because of sparse vegetation. Survey crews employed parallel pedestrian transects spaced no more than 

30 meters (100 feet) apart, except when expectations of finding cultural resources were high or ground 

surface visibility was compromised, in which case transects were spaced 15 meters (50 feet) apart. The 

cultural resource surveys were undertaken in June 2009 and February 2010.
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Sites were documented using Intermountain Antiquities Computer System site forms and Nevada Short 

Forms, drawings, 35 mm photographs, and a portable Thales global positioning system receiver. Areas of 

cultural activity were intensively surveyed in transects spaced no more than 2 meters (6 feet) apart. 

Sites recorded over 10 years prior were revisited and the site forms updated.

3.7.1.3 Consultation

A Class III Cultural Survey Report was submitted to the Nevada State Historic Preservation Office (SHPO) 

in April 2010. On May 17, 2010, the SHPO concurred with the BLM determination regarding the 

eligibility of the historic properties within the proposed project area (Nevada SHPO 2010).

3.7.2 Definition of the Resource

A cultural resource is any definable location of past human activity identifiable through field survey, 

historical documentation, or oral evidence. Cultural resources include archaeological or architectural 

sites, structures, or places, and places of traditional cultural or religious importance to specified groups 

whether or not represented by physical remains. 

For management purposes, cultural resources can be subdivided into prehistoric archaeological 

resources, historic resources, and traditional cultural properties (TCPs). Prehistoric archaeological 

resources are material remains of human activity that predate the written record, and are generally 

identified as artifacts, features, loci, sites, and districts. Historic resources consist of objects, artifacts, 

structures, buildings, and/or districts that can be associated with some aspect of history. A TCP is 

defined as: 

“a property eligible for inclusion in the National Register of Historic Places (National Register) for 

its association with cultural practices or beliefs of a living community that (a) are rooted in that 

community’s history and (b) are important in maintaining the continuing cultural identity of the 

community.” (Parker and King 1998) 

A historic property is any prehistoric or historic district, site, building, structure, or object, included in, or 

eligible for inclusion in, the National Register maintained by the Secretary of the Interior. The term can 

also apply to TCPs.

3.7.3 Regulatory Framework 

Because the proposed undertaking would involve public lands administered by BLM, it is subject to 

compliance with federal regulatory guidelines. Environmental laws applicable to this undertaking and 

involving cultural resources include NEPA, the National Historic Preservation Act, the American Indian 

Religious Freedom Act, and Executive Order 13007. The following is a brief overview of each legal 

authority. 
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3.7.3.1 NEPA

NEPA, as amended (42 USC 4371 et seq.), requires agencies to analyze the impacts of any federal 

undertaking on the environment, including both natural and cultural resources. With regard to cultural 

resources, NEPA stipulates that:

1) federal agencies must work to preserve important historical and cultural aspects of our national 

heritage [Section 101(b)(4)]

2) compliance studies involving historic properties require coordination with other preservation 

laws such as the National Historic Preservation Act 

3.7.3.2 National Historic Preservation Act

The National Historic Preservation Act of 1966, most recently amended in 2006, specifically addresses 

the need to protect cultural resources. In particular, Section 106 requires that federal undertakings, 

defined as projects on federal land, receiving federal funding, or requiring federal approval, license, or 

permit, must identify, manage, and take into consideration the potential effects an undertaking may 

have on historic properties. Federal agencies also must allow the Advisory Council on Historic 

Preservation an opportunity to comment on such actions. 

To be eligible for inclusion in the National Register, properties must be important in American history, 

architecture, archaeology, engineering, or culture. They also must possess integrity of location, design, 

setting, materials, workmanship, feeling, and association, and meet at least one of the following four 

criteria:

• Criterion A – are associated with events that have made a significant contribution to the broad 

patterns of our history

• Criterion B – are associated with the lives of persons significant in our past

• Criterion C – embody the distinctive characteristics of a type, period, or method of construction; 

or represent the work of a master; or possess high artistic values; or represent a significant 

distinguishable entity whose components may lack individual distinction

• Criterion D – have yielded, or may be likely to yield, information important in prehistory or 

history

Properties may be of local, state, or national importance. Typically, historic properties are at least 

50 years old, but younger properties may be considered for listing if they are of exceptional importance.

In accordance with Section 106 regulations, the lead federal agency is required to initiate the 

Section 106 review process and consult with all interested parties, such as the SHPO, the Advisory 

Council on Historic Preservation, and Native American tribes. Because the Nevada BLM has been 

designated the lead agency, it is responsible for identification, evaluation, and provision of management 

recommendations for historic resources within the project area of potential effects; determination of 

the project’s effect(s) on those historic resources; and determination and subsequent implementation of 

mitigation measures, if applicable.
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3.7.3.3 American Indian Religious Freedom Act

The American Indian Religious Freedom Act of 1978 is a joint resolution passed by Congress (Public 

Law 95-341) to protect and preserve Native Americans’ inherent right of freedom to believe, express, 

and exercise their traditional religions, including but not limited to access to sites, use and possession of 

sacred objects, and the freedom to worship through ceremonies and traditional rites. The American 

Indian Religious Freedom Act requires that agencies consider impacts on Native American religious 

places and practices through consultation with tribes see Chapter 3.8 Native American Religious 

Concerns for consultation information and results. 

3.7.3.4 Executive Order 13007

Alternately referred to as “Indian Sacred Sites,” this EO requires that federal agencies: (1) accommodate 

access to and ceremonial use of Indian sacred sites (as long as access does not compromise federal law 

or essential agency functions); (2) avoid adverse effects to the physical integrity of sacred sites; (3) as 

appropriate, maintain confidentiality of the location of such sites; and (4) implement procedures to 

execute the order (such as consultation).

3.7.4 Affected Environment 

3.7.4.1 Environmental Setting 

The project is in Big Smoky Valley in south central Nevada. This region is part of the Great Basin, which 

falls within the larger basin and range physiographic province that extends from southeastern California 

through Nevada, into western Utah, southern Arizona, and northwestern Mexico. Elevations within the 

project area range from 4,760 to 5,380 feet above mean sea level. Average annual precipitation in Big 

Smoky Valley is less than 10 inches. 

Geological formations within the APE can be characterized as Quaternary and Tertiary alluvial, colluvial, 

and talus deposits predominantly consisting of fluviate gravels in the bajada areas grading into fluviate 

and lacustrine sand and silt in the valleys, and including eolian (wind-blown) and playa deposits 

(Kleinhampl 1985). Soils generally consist of coarse-textured loamy fine sand, fine sandy loam, and 

gravelly sand.

The APE flora mostly consists of a mixed desert salt shrub vegetation community dominated by 

shadscale and other Atriplex spp. Other vegetation in the area may include Bailey’s greasewood, winter 

fat, bud sage, Nevada joint-fir, Indian rice grass, bottlebrush squirreltail, and galleta (see Section 3.2, 

Vegetation). Fauna include waterfowl such as grebes, cormorants, herons, and egrets, which exploit the 

wetlands of Mud Lake; falconiform birds such as vultures, hawks, falcons, and eagles; and game birds 

like the Gambel’s quail, which occupy the uplands. Mammals include the coyote, kit fox, gray fox, ringtailed cats, badger, striped skunk, bobcat, deer, pronghorn, bighorn sheep, and lagomorphs and rodents 

(rabbits, mice, gophers) (see Sections 3.3, Wildlife, and 3.4.2, Special Status Wildlife Species). 
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3.7.4.2 Cultural Setting

Past occupation in this region can be subdivided into four distinct periods: Pre-Archaic (9000–6000 BC), 

Early Archaic (6000–2500 BC), Middle Archaic (2500 BC–AD 700), and Late Archaic (AD 700–1850). 

Following are brief descriptions of each period.

3.7.4.2.1 Pre-Archaic

Two lithic traditions developed during the late Pleistocene/Early Holocene period: the Fluted Point 

Tradition (Clovis and Folsom) and the Stemmed Point or Western Pluvial Lakes Tradition. The Fluted 

Point Tradition consists of lanceolate projectile points with longitudinal flake scars, termed “fluting.” In 

the Great Basin, these sites are often located around extinct Pluvial lakes (Faught and Freeman 1998). 

These types of points are most commonly found in isolated contexts or in surficial scatters consisting of 

multiple temporal components. Fluted points have been documented in the southern end of Big Smoky 

Valley, as well as Lake Tonopah, Mud Lake, and in Long and Jake’s Valleys. The ephemeral contexts of 

these sites suggest that the Fluted Point Tradition represented a more nomadic lifestyle.

Stemmed Point artifact assemblages consist of edge-ground, stemmed, and non-notched lanceolate 

projectile points, lanceolate knives, and scrapers, crescents, and possibly core-blades and burins. 

Stemmed points have been recorded in the Sunshine Locality in Long Valley and Lake Tonopah at the 

southern end of Big Smoky Valley (Beck and Jones 1997; Grayson 1993). Unlike the Fluted Point 

Tradition, Stemmed Point Tradition sites indicate more long-term occupation of the region.

3.7.4.2.2 Early Archaic

This period is characterized by large side-notched projectile points, large concave-based Triple-T and 

Humboldt Series points, and Pinto Series points. During the Early Archaic, ground stone tools are more 

commonplace, suggesting an increase in reliance on wild plant foods. Changes in the Middle Holocene 

paleoclimate, which experienced a warming trend accompanied by drier conditions, likely influenced a 

migration of populations to areas outside the region. 

3.7.4.2.3 Middle Archaic

During the Late Holocene, however, sites increased significantly, as did the general population in the 

Great Basin region (Mabry 1998). Site types representing more varied activities are found, such as 

assaying stations, kill and butchering sites, plant gathering, food processing, and rock art sites. Point 

types that date to this period include Gatecliff, Humboldt, Pinto, and Elko Series. A more diversified 

ground stone tool assemblage, including manos, metates, mortars, and pestles, is found during the 

Middle Archaic. By AD 500, the appearance of pit houses, surface masonry structures, and ceramics 

indicates regional occupation in southern and far eastern Nevada by the Fremont culture.

3.7.4.2.4 Late Archaic

Prehistoric occupation dating to the early part of the Late Archaic is most widely identified by the 

presence of Rosegate Series projectile points, including the Rose Springs and Eastgate varieties. This 

point type signifies the evolution of the hunting strategy from atlatl and dart to bow and arrow. 

Quarrying, butchering, shelter, and habitation sites are most common during the first half of this period. 
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From AD 1300 to 1850, pre-contact sites are characterized by Desert Series points and Intermountain 

Brownware pottery. Following European contact, sites generally contain Euroamerican or aboriginal 

artifacts, and often a combination of the two. Mining-related sites are probably most common in the Big 

Smoky Valley, although wagon trails, stage lines, farms or ranches, and homesteads are other site types 

found in the region.

3.7.4.3 Summary of Findings

The cultural resource inventories conducted by Malinky and Harmon (2009) and Risse (2010) resulted in 

the documentation of 142 sites (Table 3-20). The majority of the sites (78) are prehistoric, 59 are 

historic, and 5 are multicomponent (evidencing both prehistoric and historic use). The prehistoric sites 

generally can be characterized as small (less than 50 artifacts), surficial lithic scatters with no associated 

features. Historic sites consist of mining features—a prospecting pit and a claim post, small trash 

scatters, and one road segment. Only 13 sites—all prehistoric lithic scatters—qualify as historic 

properties. All are recommended National Register eligible under Criterion D for their potential to 

provide information regarding lithic technology and chronology in the Big Smoky Valley region. The 

prevailing site types suggest that both prehistoric and historic activity in this region can be characterized 

as short term, involving lithic reduction in the case of prehistoric peoples, and during the historic period, 

prospecting for mineral deposits.

Table 3-20. Summary of cultural resource site types, by area

Area

Site Types

Total

Sites

Prehistoric Historic Multicomponent

Eligiblea Not 

Eligiblea Eligible Not Eligible Eligible Not Eligible

Proposed Area 4 35 0 10 0 1 50 

Alternative Area 9 30 0 49 0 4 92 

Borrow pit 0 0 0 0 0 0 0 

Transmission line and 

Anaconda Moly Substation

0 0 0 0 0 0 0 

Total 78 59 5 149 a describes National Register of Historic Places status

3.7.4.4 Proposed Area

Refer to Table 3-20 for a summary of cultural resources in this area.

3.7.4.5 Alternative Area

Refer to Table 3-20 for a summary of cultural resources in this area.

3.7.4.6 Borrow Pit

Refer to Table 3-20 for a summary of cultural resources in this area.

3.7.4.7 TL and Anaconda Moly Substation

Refer to Table 3-20 for a summary of cultural resources in this area.
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3.7.4.8 CESA

During the tribal consultations, no traditional cultural properties were identified in the CESA (Section 

3.8). 

3.8 Native American Religious Concerns

3.8.1 Area of Analysis and Methodology 

The area of analysis, hereafter referred to as the project area, includes the Proposed Area, Alternative 

Area, borrow pit, and the TL and Anaconda-Moly Substation corridor as shown in Figure 3-1. 

Considering BLM has limited knowledge of any past or contemporary traditional or cultural uses, 

resources, or activities within the immediate and surrounding area, and considering that consultation is 

ongoing, a BLM-proposed CESA is defined as the Tonopah Flat (137A) Hydrographic Basin of the Big 

Smoky Valley watershed (see Figure 2-15). Given the limited water sources in the region, 

traditional/cultural activities most likely would have been concentrated around such locations.

Approximately 30 springs and seeps were identified around the boundary of the Tonopah Flat subarea. 

Most springs identified by WorleyParsons are located in bedrock areas, with the closest springs and 

seeps located more than 10 miles from the Project (WorleyParsons 2010a). 

This BLM-proposed CESA boundary may be altered by participating tribal entities throughout the course 

of Native American consultation and as further input is received.

3.8.2 Definition of the Resource 

Given past and present tribal participation in various projects and proposals throughout lands 

administered by BLM in Nevada, the following are examples of traditional or cultural resources, 

activities, and sites of concern considered sacred or detrimental to the continuation of family and 

community traditions, beliefs, and lifeways: prehistoric and historic habitation sites, sources of water 

(hot and cold springs), pine nut gathering locations, firewood harvesting locations, sites of ceremony 

and prayer, certain prehistoric and ethno-historic archaeological sites, gravesites, “rock art” sites, 

medicinal/edible plant gathering locations, areas and features associated with creation stories, tribally 

designated traditional cultural properties (TCPs), and tribal land acquisition efforts involving 

Congressional delegations.

3.8.3 Regulatory Framework 

In accordance with the National Historic Preservation Act (P.L. 89-665), NEPA (P.L. 91-190), FLPMA 

(P.L. 94-579), the American Indian Religious Freedom Act (P.L. 95-341), the Native American Graves 

Protection and Repatriation Act (P.L. 101-601), and EO 13007, BLM must provide affected tribal 

governments, traditional leaders, and lineal descendants an opportunity to comment and consult on the 

proposed project. 

These laws and other mandates and directives, such as BLM’s Manual Handbook H-8120-1, need to be 

considered when identifying and evaluating the significance of, considering impacts to, and developing 
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treatment plans for specific sites, activities, or resources of traditional or cultural importance within the 

Native American Religious Concerns area of analysis and CESA boundary.

3.8.4 Affected Environment 

3.8.4.1 Environmental Setting 

Although a significant distance from the project area, known locations (to BLM) of cultural or traditional 

significance within the general region are: Darrough’s Hotspring, Blue Spring, and other spring 

complexes in central Big Smoky Valley; Peavine Canyon in the Southern Toiyabe Range; Indian Allotment 

lands throughout central and northern Big Smoky Valley; cemeteries; Toiyabe and Toquima Range pine 

nut harvesting sites; “Wiam” or “Buffalo Berry Trees” of central Big Smoky Valley; and Toquima Cave.

Steward (1938) documented that the Wiyumahunovi (buffalo berry water valley; Big Smoky Valley) was 

home to a Western Shoshone band called the Wiymbitükanü (buffalo berry eaters). The valley was a 

favored gathering area of the Wiymbitükanü and other Western Shoshone bands for seeds from the 

hukümbi and töpoi roots (both plants were unidentified by Steward). Big Smoky Valley is still home to 

descendents of the Wiymbitükanü, with many having organized into a group called the Western 

Shoshone Descendents of the Big Smoky Valley.

3.8.4.2 Summary of Findings

BLM’s TFO initiated consultation by providing the project proposal description and location (with 

attached maps) by mail on March 8, 2010, to the Timbisha Shoshone Tribe, Duckwater Shoshone Tribe, 

Yomba Shoshone Tribe, Descendants of Big Smoky Valley, and various other family members known to 

have interests in the Tonopah and/or Big Smoky Valley areas. Following the initial mailing, multiple 

communications or coordination occurred (e-mails, telephone calls, meetings, and site visits), with BLM 

requesting input and extending field visit and meeting invitations. Of the tribal entities contacted, the 

Timbisha Shoshone Tribe, Descendants of Big Smoky Valley, and, more recently, the Yomba Shoshone 

Tribe have expressed the most interest and have requested further participation. 

On April 7, 2010, the TFO and Timbisha Shoshone Tribe participated in a field visit to the project site. On 

June 8, 2010, the TFO conducted a status update meeting with the Timbisha Shoshone Tribe in Beatty, 

Nevada. In addition the BLM conducted a field tour and meeting with representatives of the Yomba 

Shoshone Tribe, no special concerns were raised by the tribe. BLM continues to provide opportunities 

for tribal participation through the EIS analysis. 

As a result of recent communications and coordination, the following are issues and concerns given to 

date by participating tribal entities: potential impacts to water sources and avoidance of identified 

cultural resources, further tribal participation (monitor or observer opportunities) during 

implementation of a cultural resources treatment plan (data recovery) and/or during new surface 

disturbance associated with construction activities, general concerns about possible impacts to older 

sites along the “old lakeshore” or sites that might exist within the dunes (Crescent Dunes), maintenance 

of existing access routes, possibly damage to solar panels from vandalism, and cultural resource site 

inspections to ensure construction employees avoid known sites.
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3.8.4.3 CESA

It is believed that cultural resources—including tribal resources and sites of cultural, traditional, and 

spiritual use and associated activities—are increasingly in danger of losing their physical and spiritual 

integrity. As populations grow and technology advances, public interest in using lands administered by 

BLM increases and, thus, the potential for the decline of culturally sensitive areas also increases. 

Different world views and social and spiritual practices and beliefs often conflict with each other. 

As told by previous tribal participants, perhaps the leading contributors affecting cultural properties and 

traditional resources have been historic and modern mining, livestock grazing, cheat grass invasion, 

catastrophic wildfires, impacts to water sources, drought, and the general growth of populations and 

public use or interest in areas once considered remote.

Considering BLM has limited knowledge of any past or contemporary traditional or cultural uses, 

resources, or activities within and adjacent to the project boundary, a CESA has been defined as the 

Tonopah Flat (137A) Hydrographic Basin of the Big Smoky Valley watershed (see Figure 2-15). Given the 

limited water sources in the Tonopah area, traditional or cultural activities most likely would have been 

concentrated near water sources. This tentative BLM determination has been presented to tribal 

participants for concurrence, further analysis, and identification of any specific inclusions.

As stated earlier, known locations (to BLM) of any cultural or traditional significance within the general 

region are: Darrough’s Hotspring, Blue Spring, and other spring complexes in central Big Smoky Valley; 

Peavine Canyon; cemeteries; Indian Allotment lands throughout central and northern Big Smoky Valley; 

Toiyabe and Toquima Range pine nut harvesting locations; “Wiam” or “Buffalo Berry Trees” of central 

Big Smoky Valley; and Toquima Cave. Because of significant distances, project activities are not expected 

to affect the properties noted above.

In addition to all the existing, growing, and developing uses of the public lands, renewable energy 

development (geothermal, wind, and solar) may contribute to the regional decline of cultural or 

traditional use sites, resources, and associated activities. However, contributions of this specific 

Proposed Action are expected to be minimal because most of the proposed activities currently appear 

to be located within an area of little past or contemporary use or significant usable resources.

3.9 Land Use and Access

This section provides an overview of the existing and future land use and public access in the project 

area. It includes a description of the area of analysis and methodology and analyzes the project in 

relation to property ownership, land use plans, policies, authorizations, and access issues.

3.9.1 Area of Analysis and Methodology 

The area of analysis for land use and access of the proposed project includes the Proposed Area, 

Alternative Area, borrow pit, and TL and Anaconda Moly Substation corridor (Figure 3-1). The CESA

varies by resource area within this EIS. For land use and access, it includes a 1-mile buffer surrounding 

each of these four identified areas (also see Figure 3-13). The land use and access evaluation 

methodology involved a review of related data of county, state, and federal land use plans, as well as 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-61

master title plats, geothermal plats, oil and gas plats, land use plats, and other land records available at 

BLM’s Nevada State Office in Reno and the Carson City Field Office. Data were also collected through 

analysis of aerial photography, field verification, and coordination with County staff. Individuals from 

BLM were contacted, and the BLM Legacy Rehost (LR2000) database was used to verify land use and 

ROW resources on BLM land within the area of analysis. The data were compiled to assess potential land 

use impacts from the construction, operation, and maintenance of the proposed project.

3.9.2 Regulatory Framework 

The primary legal basis for granting a land-use authorization for this proposed project on BLM land is 

Section 501 of the FLPMA. Under the FLPMA, the Secretary of the Interior is authorized to grant, issue, 

or renew ROWs over, upon, or through such land for utility corridors, roads, trails, highways, railroads, 

canals, etc (43 CFR 2800). The FLPMA provides BLM with authority to issue leases and permits for the 

use, occupancy, and development of public land. The regulations establishing procedures for processing 

these leases and permits are found in 43 CFR 2920. Relevant federal, state, regional, and local land use 

plans, goals, policies, and objectives are discussed below.

3.9.2.1 BLM Tonopah RMP and ROD (1997)

The BLM Tonopah RMP provides a comprehensive framework for managing approximately 6.1 million 

acres of public lands administered by the Tonopah Field Station of the BLM Battle Mountain District 

(BLM 1997). The RMP lands and ROWs objective is to make lands available for community expansion 

and private economic development and to increase the potential for economic diversity. Lands within 

the Tonopah Planning Area will be open to consideration for linear or areal ROWs, leases, and land use 

permits where there are no unresolvable conflicts with other resource values. Any such grants, leases, 

or permits will include appropriate stipulations to protect the area’s special values. Land use lease or 

permit applications are addressed on a case-by-case basis, where consistent with other resource 

management objectives and local land uses.
Crescent Dunes Road

Anaconda Substation

Pole Line Road

Unnamed Access Road

¬«89

¬«89

T6N R40E

T5N R40E

T6N R41E

T5N R41E T6N R41E T6N R42E

T5N R41E T5N R42E

T5N R40E

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T5N R41E

T4N R41E

T5N R41E

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CESA One Mile Buffer

Alternative Area

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Local Road

State Highway

Proposed Transmission Line (138kV)

Existing Transmission Line (120kV)

Borrow Pit (40 acres)

Rights-of-way avoidance areas (Crescent Dunes SRMA)

±

Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Area_of_Analysis.mxd

Figure 3-13 Land-Use Area

of Analysis and CESA

Crescent Dunes

Solar Energy Project

Substation

!

Project Site

NEVADA

!

Project Site

NEVADA
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-63

3.9.2.2 Nye County Comprehensive Plan

Use of privately owned lands in the project area is planned and regulated by Nye County. The Nye 

County Comprehensive Plan (Nye County Board of Commissioners 1994, amended 2010) was developed 

to act as a guide to the Nye County Board of Commissioners on all matters of growth and development. 

This guidance is accomplished by establishing goals and objectives that address countywide issues and 

concerns and implementing policies and programs to accomplish the objectives. The plan also serves as 

a framework for local land use plans and other growth management mechanisms. The federal 

government owns and manages certain parcels of land within Nye County and has the ability to acquire 

additional lands pursuant to Article I, Section 8, Clause 17 of the U.S. Constitution and Chapter 328 of 

the NRS. Nye County is in the process of creating a Federal Lands Element of the Comprehensive Plan to 

develop goals, objectives, and policies for federal lands within Nye County.

It is Nye County’s objective to:

• protect the health, safety, and welfare of its residents

• enhance their economic opportunities

• preserve their quality of life

3.9.3 Affected Environment 

3.9.3.1 Land Ownership Status and Existing Land Use

Two major categories of land ownership were identified: federal lands administered by BLM and 

privately held land (Figure 3-13). 

Existing land use conditions in the area of analysis are characterized primarily by open desert, utility 

corridors and facilities, grazing allotment, recreation, and transportation and access. BLM administers 

the vast majority of land in the proposed project area through the TFO. BLM grants land use 

authorizations that allow private entities to use public lands for specific purposes. According to the 

Tonopah RMP (BLM 1997), the area of analysis for the proposed project is subject to the following 

authorizations or restrictions (Figure 3-13): 

• San Antone grazing allotment (covers entire area of analysis) (for additional information see 

Section 3.14, Range Resources) 

• a ROW avoidance area (Classification 2—other),

• off-highway vehicle restriction (limited to existing roads and trails and closed to competitive 

events)

• visual resource management (Class 4) (covers entire area of analysis)

• a utility corridor

• mineral leasing restrictions (no surface occupancy)

• avoidance of Crescent Sand Dunes (Special Resource Management Area [SRMA]) 

In addition, based on a data search within BLM’s GeoCommunicator (BLM 2010b), the area of analysis

and the CESA are all contained within a DOD Airspace Consultation Area. This is an important BLM 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-64

coordination requirement for wind, solar, and communication development projects. Since the 

proposed project is within this area, consultation with the DOD would be required. The U.S. Air Force is 

a Cooperating Agency on the EIS, and consultation with DOD has occurred throughout the process (see 

Chapter 5). 

Based on a data search within BLM’s LR2000 (BLM 2010c) and Mining Claim Geographic Report (BLM 

2010d), a variety of leases, easements, and ROWs have been granted by BLM within the area of analysis 

(Table 3-21).

3.9.3.1.1 Proposed Area

This area consists entirely of lands administered by BLM. In addition to the universal land use 

authorizations mentioned previously that cover this entire area, Table 3-21 lists specific land uses 

authorized by BLM.

Table 3-21. Authorized and pending BLM ROWs within the Proposed Area, Borrow Pit, and TL Corridor

Area of Analysis

U.S. Bureau of 

Land 

Management

Serial Number

Status Description

Proposed Area N-086292 Pending Crescent Dunes Solar Energy Project, by Tonopah Solar 

Energy, LLC 

Proposed Area N-88207 Authorized Section 302 FLPMA permit, by Tonopah Solar Energy, LLC 

(meteorological tower)

TL Corridor N-87933 Pending Crescent Dunes Solar Energy Project, by Tonopah Solar 

Energy, LLC, 230 kV TL

TL Corridor N-33242 Authorized Sierra Pacific Power Company, 120 kV TL, Expires 

12/29/2011 

TL Corridor N-043264 Authorized Sierra Pacific Power Company, 55 kV TL, in perpetuity 

Borrow Pit N-88525 Authorized Crescent Dunes Solar Energy Project, by Tonopah Solar 

Energy, LLC, Temporary Geotechnical Studies Permit

3.9.3.1.2 Alternative Area

This area consists entirely of lands administered by BLM. In addition to the universal land use 

authorizations mentioned previously that cover this entire area, Table 3-22 lists specific land uses 

authorized by BLM.

Table 3-22. Authorized and pending BLM ROWS within the Alternative Area

Area of Analysis

U.S. Bureau of 

Land Management 

Serial Number

Status Description

Alternative Area N-086292 Pending Crescent Dunes Solar Energy Project, by Tonopah 

Solar Energy, LLC 

Alternative Area N-033242 Authorized Right-of-way (ROW) – power transmission, by Sierra 

Pacific Power Company (now NV Energy)

Alternative Area N-040052 Authorized ROW – water facility, by federal government

Alternative Area N-88177 Authorized ROW – test well for Crescent Dunes Solar Energy 

Project, by Tonopah Solar Energy, LLC
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-65

3.9.3.1.3 Borrow Pit

This area consists of lands administered by BLM. In addition to the universal land use authorizations 

mentioned previously that cover this entire area, Table 3-23 lists specific land uses authorized by BLM.

Table 3-23. Authorized and pending BLM ROWs and mining claims within the borrow pit area

Area of Analysis

U.S. Bureau of 

Land Management 

Serial Number

Status Description

Borrow pit NVN 059045 Expired Mineral materials (negotiated all), by 

Larson Construction

Borrow pit NVN 077836 Authorized Government free use mineral (all), by Nye 

County Road Department

Borrow pit NMC1010435 (MW13) Active

Mining claim – Chris Gibson, Fredrick 

Gibson, Jan Lamb, Sue Latta, John Rud, Rod 

Sipes, Lorin Stieff, and Jeff Summerer

Borrow pit NMC1010433 (MW11) Active

Mining claim – Chris Gibson, Fredrick 

Gibson, Jan Lamb, Sue Latta, John Rud, Rod 

Sipes, Lorin Stieff, and Jeff Summerer

3.9.3.1.4 TL and Anaconda Moly Substation

The area proposed as a TL corridor is located on lands administered by BLM (Figure 3-13). However, this 

area is immediately adjacent to an authorized power/transmission ROW grant to NV Energy by BLM 

(ROW number NVN 033242). 

The area proposed for the Anaconda Moly Substation area is located on lands owned by Sierra Pacific 

Power Company (now doing business as NV Energy) and is classified as Nye County Planning Department 

land use code 700, Centrally Assessed Public Utility (Nye County Board of Commissioners 1994). This 

area is currently used for a power conversion facility.

3.9.3.1.5 CESA

This area includes a 1-mile buffer surrounding the area of analysis (each of the four previously identified 

areas). Therefore, it includes both public (BLM-administered) and private (NV Energy) lands 

(Figure 3-14).

In addition, a 3,000-acre natural dune area (Crescent Sand Dunes) is located just east of the Proposed

and Alternative Area boundaries. These dunes have been designated by BLM as an SRMA, and any new 

or amended ROW within this area would have to be compatible with the special values of this area. This 

area is also closed to competitive recreational events to protect sensitive resources such as threatened 

and endangered species and cultural resources.
Crescent Dunes Road

Anaconda-Moly Substation

Pole Line Road

Unnamed Access Road

¬«89

¬«89

T6N R40E

T5N R40E

T6N R41E

T5N R41E T6N R41E T6N R42E

T5N R41E T5N R42E

T5N R40E

T4N R40E

T5N R41E

T4N R41E

T5N R41ET5N R42E

T4N R42E

T4N R41E

06 05 04

28

31

11

11

04

11

22

09

33

09

11

16

25

36

10

21

14

16

29

14

17

21

01

02

18

07

23

01

24

23

12

26

20

10

30

14

34

30

13

32

35

15

02

13

23

31

35

26

24

05

20

02

35

08

08

21

15

09

33

03

18 13

32

09

27

05

16

01

20

12

18

25

17

08

35

22

28

02

19

33

36

08

21

07

17

12

12

24

14

36

23

18

04

19

16

32

06

31

32

05

29

17

04

07

13

19

07

03

24

19

34

06

20

01

31

06

36 33

26 25 30 29 28

29

27

30

34

26 25 29 28

22

15

28

30

26

10

27

03

03

25

34

22

28

27

10

15

30 29 26 25

27

27

15

22

10

03

27

34

34

03

10

15

22

27

27

0 1 2

Miles

Legend

CESA One Mile Buffer

Township/Range

Alternative Area

Proposed Area

Bureau of Land Management

Private

Proposed Transmission Line (138kV)

Existing Transmission Line (120kV)

Borrow Pit (40 acres)

Utility Corridors

Local Road

State Highway Aerial Source: ESRI 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Area_of_Analysis.mxd

Figure 3-14 Land-Use

and Ownership Status

Crescent Dunes

Solar Energy Project

Substation

!

Project Site

NEVADA

±

OHV Restrictions (Limited to Existing Roads and Trails and CLosed to Competitive Use

Rights-of-way avoidance areas (Crescent Dunes SRMA)

Mineral Leasing Restrictions (No Surface Occupancy
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-67

3.9.3.2 Access

Access to the proposed project would be provided from SH 89 (Pole Line Road) (Figure 3-14). Pole Line 

Road is a Nye County owned and maintained road near the proposed project and is asphalt surfaced 

from its intersection with US 6/95 and continues north of the proposed project area. A short section of 

Pole Line Road from its intersection with US 6/95 to a location south of the proposed project area is in 

Esmeralda County. This section of Pole Line Road, although located in Esmeralda County, is maintained 

by Nye County through the terms of a formal agreement. According to Nye County representatives, the 

existing paved surface of Pole Line Road is between 24 and 28 feet wide.

3.9.3.2.1 Proposed Area

Access to the project site would be along a new access road that would be created from Pole Line Road. 

It would be a paved, two-lane road constructed with adequate width for two directions of travel and 

shoulders. Access to the new road would be restricted to authorized project personnel during 

construction and operation. Additionally, unpaved roads would be constructed from the power block to 

the edges of the solar field. 

The main access road to Crescent Dunes is Crescent Dunes Road. This road currently exists along the 

northern border of the Proposed Area. This unpaved road provides vehicle and recreational access to 

the Crescent Sand Dunes SRMA. No other trails or roads are present within the Proposed Area.

3.9.3.2.2 Alternative Area

Access to each of the project sites would be along new access roads that would be created from Pole 

Line Road. The roads would be paved, two-lane roads constructed with adequate width for two 

directions of travel and shoulders. Access to the new road would be restricted to authorized project 

personnel during construction and operation. Additionally, unpaved roads would be constructed from 

the power block to the edges of the solar field. 

Crescent Dunes Road currently exists along the southern border of the Alternative Area. This unpaved 

road provides vehicle and recreational access to the Crescent Sand Dunes SRMA. No other trails or roads 

are present within the Alternative Area.

3.9.3.2.3 Borrow Pit

Access to the borrow pit is directly provided from Pole Line Road, and no changes to this access are 

anticipated.

3.9.3.2.4 TL and Anaconda Moly Substation

Primary access to the TL would be from Pole Line Road and from an existing maintenance road along an 

existing TL corridor. Direct access to TL towers would occur along short spurs off of the main road. 

Access to the Anaconda Moly Substation would originate from Pole Line Road and head north-northeast

on an unnamed paved TL access road as indicated in Figure 3-14. Public access to these roads would not 

change.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-68

3.10 Soils

3.10.1 Area of Analysis and Methodology 

The areas of analysis for soils are the Proposed Area, Alternative Area, borrow pit, and TL and Anaconda 

Moly Substation corridor (Figure 3-1). Soils were identified and mapped for the areas of analysis as 

stipulated by the data adequacy standards. The CESA for soils consists of the area within a 5-mile radius 

of the project areas and proposed facilities. Identification and mapping of soils for the CESA was not 

stipulated by the data adequacy standards and was not performed.

The primary source of information for soils was obtained from the NRCS online Web Soil Survey, which 

was accessed to obtain the soils data presented herein (NRCS 2009). The specific soil survey represented 

by the soil data obtained through the Web Soil Survey is the Soil Survey of the Big Smoky Valley Area, 

Nevada, Part of Nye County. Information related to the principal soil orders and dominant suborders as 

provided by BLM in the data adequacy standards is also used.

As used in this section of the EIS document, the term “soil” refers to the naturally weathered geologic 

sediments existing in layers or horizons of minerals and/or organic constituents of variable thickness, 

which differ from the geologic parent material (rock) in their morphological, physical, chemical, and 

mineralogical properties as well as their biological characteristics. 

NRCS identifies and delineates soils into units with the objective of separating the landscape into 

segments with similar use and management requirements. This provides information sufficient for the 

development of resource plans. On-site investigations are required to precisely define and locate soils 

and evaluate their various physical, chemical, and engineering characteristics. Soils within the areas of 

analysis are described based on ten factors stipulated by the data adequacy standards, including soil 

series name, texture, permeability, pH, available water capacity, hydrologic group, wind and water 

erosion hazard, landscape position, depth to bedrock, and suitability as topsoil for reclamation. This 

information is presented separately for each detailed study area below.

3.10.2 Regulatory Framework 

3.10.2.1 NPDES

NDEP administers EPA regulations (55 CFR 47990) that require permitting of stormwater-generated 

pollution under the NPDES. Pursuant to these EPA regulations, a General Permit under the NPDES 

Stormwater Program must be obtained for all construction activities affecting areas of 5 acres or 

greater. The General Permit requires implementation of Best Management Practices (BMPs) to reduce 

pollutant loads into the waters of the state.

3.10.2.2 Nevada BMPs

Use of BMPs in Nevada is addressed in the Handbook of Best Management Practices published by the 

State of Nevada Environmental Commission (1994), which references two definitions of BMPs—the EPA 

definition and the NAC definition. EPA defines BMPs as “methods, measures, or practices to prevent or 

reduce water pollution, including but not limited to, structural and non-structural controls, operation 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-69

and maintenance procedures and scheduling and distribution of activities.” NAC 445.200 defines “Best 

Practices” as “measures, methods, or operation or practice that are reasonably designed to prevent, 

eliminate, or reduce water pollution from diffuse sources and that are consistent with the best practices 

in the particular field under the conditions applicable” and states that this term is intended to be 

equivalent to the term “best management practices” as used in federal laws and regulations.

Usually BMPs are applied as a system of practices rather than a single practice. BMPs are selected on the 

basis of site-specific conditions that reflect natural background conditions and political, social, 

economic, and technical feasibility.

3.10.3 Affected Environment 

3.10.3.1 Geologic Overview

A brief summary of geologic information is provided here. 

The areas of analysis are located in the southern portion of Big Smoky Valley known as the Tonopah Flat 

Subarea in northern Nye County, Nevada. This area is located near the center of the Great Basin Section 

of the basin and range physiographic province. The valley is surrounded to the north by the Toiyabe and 

Shoshone ranges, to the south by Lone Mountain and the Silver Peak Range, to the east by the San 

Antonio Range, and to the west by the Royston Hills and Monte Cristo Range. Uplift exhibited by the 

present-day mountain ranges was caused by Cenozoic Era basin-and-range faulting that reached great 

magnitude during the middle to late Tertiary Period and continues to the present. The floor of Big 

Smoky Valley consists of alluvial sediments derived from the surrounding mountains and is internally 

drained. Margins of the valley include alluvial fans, talus slopes, and pediments. Wind action has 

affected the intermontane valleys and resulted in deflation basins (blowouts) and sand accumulations in 

the form of solitary dunes and dune fields. 

Geologic materials present in the project region vary greatly and include Paleozoic to Tertiary rocks and 

Tertiary to Quaternary sediments. These geologic materials are briefly summarized below.

• Paleozoic Sedimentary and Metamorphic Rocks

• Cretaceous Granitic Rocks

• Tertiary Intrusive and Extrusive Rocks

• Tertiary Sedimentary Rocks

• Quaternary and Tertiary Sediments

Based on the geologic map covering the project area and surrounding areas, geologic material exposed 

at the surface of all four areas of analysis consists of Alluvium, Colluvium, and Talus described as 

Quaternary and Tertiary deposits predominantly consisting of fluviate gravels flanking mountains, 

grading into fluviate and lacustrine sand and silt in valleys, and including eolian (wind-blown) and playa 

deposits. The estimated thickness of alluvium is about 1,500 to 3,000 feet beneath western portions of 

the areas of analysis (WorleyParsons 2010a). The thickness of alluvium is expected to thin to the east 

where the areas of analysis approach the foothills and flanks of the San Antonio Mountains.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-70

3.10.3.2 Soil Characteristics

Entisols are the principal soil order and psamments are the dominant soil suborder at the proposed 

project area. Soils are dominated by relatively coarse-textured soils including loamy fine sand, fine sandy 

loam, fine sand, and gravelly sand, which support important vegetation communities adapted to the arid 

climate. The potential for soil displacement by water is low, but by wind action is high. These soils are 

easily displaced by wind if vegetative cover is removed. If there is an increase in soil movement because 

of a loss of vegetation, resultant cumulative impacts on adjoining vegetation communities and 

modification in the structure and productivity of the soils can occur, including short- and long-term, 

direct and indirect effects.

Specific NRCS soil types present at each area of analysis and their respective characteristics, including 

soil series name, texture, permeability, pH, available water capacity, hydrologic group, wind and water 

erosion hazard, landscape position, depth to bedrock, and suitability as topsoil for reclamation, are 

presented in Tables 3-24 through 3-27 and illustrated in Figures 3-15 through 3-18, by area of analysis. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-71

Table 3-24. NRCS soil types and evaluation criteria for the Proposed Area

NRCS Soil 

Series 

(NRCS Symbol)

Approx. 

Percentage 

of Study 

Area

Natural Resources Conservation Service (NRCS) Evaluation Criteria

USDA 

Surface 

Texture 

Rating

Permeability 

Standard Class 

Rating

(Ksat in μm/sec)

and Class Limita

pH

Available

Water 

Capacity 

(in/in)

Hydrologic

Group

Wind Erosion 

Hazard 

(Erodibility

Group/Index)b

Water 

Erosion 

Hazard 

(K Factor 

Rating)

(Kw/Kf)

c

Landscape 

Positiond 

Depth to 

Bedrock

Suitability as 

Topsoil for

Reclamation

Broyles fine 

sandy loam, 

2 to 4 percent 

slopes (BrB)

8.1% 

Fine 

sandy 

loam

28.0000 

High 7.9–9.6 0.09–0.15 B 3/86 .32/.32 VSAF

>60 inches Poor

Dune land (DU) 0.3% Fine 

sand

92.0000 

High 7.4–8.4 0.03–0.05 A 1/250 .15/.20 DUVS >60 inches Poor

Playas (PN) 0.6% Silty 

clay

0.2150 

Moderately Low 8.5–9.6 0.02–0.04 D 4/86 .37/.37 

PL

VF

BZ

>60 inches Poor

Stumble loamy 

fine sand, 

0 to 8 percent 

slopes (STC)

81.5% 

Loamy 

fine 

sand

92.0000 

High 6.6–8.4 0.06–0.08 A 2/134 .17/.20 

VS

VF

AF

>60 inches Poor

Tipperary 

fine sand, 

4 to 30 percent 

slopes (TGE)

9.5% Fine 

sand

423.0000 

Very High 8.5–9.6 0.05–0.07 A 1/250 .15/.15 VSAF

>60 inches Poor

a Permeability is expressed as the representative saturated hydraulic conductivity (Ksat) rating in micrometers per second (μm/sec), which corresponds to various NRCS classes based on Ksat range 

as follows: Very Low (0.00–0.01), Low (0.01–0.1), Moderately Low (0.01–1.0), Moderately High (1–10), High (10–100), and Very High (100–705). b Wind erodibility groups (Groups 1 through 8) are made up of soils with similar properties affecting their susceptibility to wind erosion; Group 1 soils are most susceptible, Group 8 soils are least 

susceptible. Wind erodibility index is a numerical value indicating the soil susceptibility to wind erosion in tons per year per acre that can be expected to be lost to wind erosion. c K Factor Rating indicates the susceptibility of a soil to sheet and rill erosion by water and is one of the factors used in the Universal Soil Loss Equation. Values of K can range from 0.02 to 0.69 and 

other factors being equal, the higher the value the more susceptible the soil is to sheet and rill erosion by water. Kw is the value for the whole soil; Kf is the value for the fine fraction of the soil 

(material less than 2.0 millimeters in size).

d NRCS Geomorphic Description System Category (Landscape) Symbols: AF = alluvial fan, BZ = braided stream, DU = dune, PL = playa, VF = valley floor, VS = valley side (NRCS 2009) 
¬«89

Crescent Dunes Road

STC

BrB

TGE

PN

DU

BEB

Crescent Dunes

Solar Energy Project

Figure 3-15 Soils Within Proposed Area

Sources: National Resources Conservation Service; Photo: ESRI 2010

!

Project Site

NEVADA ±

0 0.1 0.2 0.3 0.4 0.5

Miles

Legend

Proposed Area BEB (Belcher gravelly sand, 0 to 4 percent slopes)

BrB (Broyles fine sandy loam, 2 to 4 percent slopes)

DU (Dune land)

PN (Playas)

STC (Stumble loamy fine sand, 0 to 8 percent slopes)

TGE (Tipperary fine sand, 4 to 30 percent slopes)

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Soils_Proposed_Area.mxd
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-73

Table 3-25. NRCS soil types and evaluation criteria for the Alternative Area

NRCS 

Soil Series 

(NRCS Symbol)

Approx. 

Percentage 

of Study 

Area

Natural Resources Conservation Service (NRCS) Evaluation Criteria

USDA 

Surface 

Texture 

Rating

Permeability 

Standard Class 

Rating

(Ksat in μm/sec)

and Class Limita

pH

Available

Water 

Capacity 

(in/in)

Hydrologic 

Group

Wind Erosion 

Hazard 

(Erodibility

Group/Index)b

Water 

Erosion 

Hazard 

(K Factor 

Rating)

(Kw/Kf)

c

Landscape 

Positiond 

Depth to 

Bedrock

Suitability as 

Topsoil for 

Reclamation

Timber gravelly 

sandy loam,

0 to 4 percent 

slopes (TEB)

3.0% 

Gravelly 

sandy 

loam

74.5376 

High 7.9–9.6 0.04–0.15 D 4/86 .17/.28 VFPL

>60 inches Fair

Dune land (DU) 8.9% Fine 

sand

92.0000 

High 7.4–8.4 0.03–0.05 A 1/250 .15/.20 DUVS

>60 inches Poor

Playas (PN) 0.4% Silty 

clay

0.2150 

Moderately Low 8.5–9.6 0.02–0.04 D 4/86 .37/.37 

PL

VF

BZ

>60 inches Poor

Stumble loamy 

fine sand, 

0 to 8 percent 

slopes (STC)

75.1% 

Loamy 

fine 

sand

92.0000 

High 6.6–8.4 0.06–0.08 A 2/134 .17/.20 

VS

VF

AF

>60 inches Poor

Belcher 

gravelly sand, 

0 to 4 percent 

slopes (BEB)

12.1% Gravelly 

sand

14.9240 

High 7.9–9.6 0.04–0.15 D 2/134 .32/.20 VFPL

19 inches Poor

Tipperary 

fine sand, 

4 to 30 percent 

slopes (TGE)

0.5 Fine 

sand

423.0000 

Very High 8.5–9.6 0.05–0.07 A 1/250 .15/.15 VSAF

>60 inches Poor

a Permeability is expressed as the representative saturated hydraulic conductivity (Ksat) rating in micrometers per second (μm/sec), which corresponds to various NRCS classes based on Ksat range as follows: Very Low 

(0.00–0.01), Low (0.01–0.1), Moderately Low (0.01–1.0), Moderately High (1–10), High (10–100), and Very High (100–705). b Wind erodibility groups (Groups 1 through 8) are made up of soils with similar properties affecting their susceptibility to wind erosion; Group 1 soils are most susceptible, Group 8 soils are least susceptible. Wind 

erodibility index is a numerical value indicating the soil susceptibility to wind erosion in tons per year per acre that can be expected to be lost to wind erosion. c K Factor Rating indicates the susceptibility of a soil to sheet and rill erosion by water and is one of the factors used in the Universal Soil Loss Equation. Values of K can range from 0.02 to 0.69 and other factors being 

equal, the higher the value the more susceptible the soil is to sheet and rill erosion by water. Kw is the value for the whole soil; Kf is the value for the fine fraction of the soil (material less than 2.0 millimeters in size). d NRCS Geomorphic Description System Category (Landscape) Symbols: AF = alluvial fan, BZ = braided stream, DU = dune, PL = playa, VF = valley floor, VS = valley side (NRCS 2008)
89 Crescent Dunes Road

STC

DU

BEB

TEB

TGE

PN

Crescent Dunes

Solar Energy Project

Figure 3-16 Soils Within the Alternative Area

Sources: National Resources Conservation Service; Photo: ESRI 2010

Project Site

NEVADA

0 0.1 0.2 0.3 0.4 0.5

Miles

Legend

Alternative Area

BEB (Belcher gravelly sand, 0 to 4 percent slopes)

DU (Dune land)

PN (Playas)

STC (Stumble loamy fine sand, 0 to 8 percent slopes)

TEB (Timper gravelly sand loam, 0 to 4 percent slopes)

TGE (Tipperary fine sand, 4 to 30 percent slopes)

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Soils_Alternative_Area.mxd
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-75

Table 3-26. NRCS soil types and evaluation criteria for the borrow pit

NRCS 

Soil Series 

(NRCS Symbol)

Approx. 

Percentage 

of Study 

Area

Natural Resources Conservation Service (NRCS) Evaluation Criteria

USDA 

Surface 

Texture

Rating

Permeability 

Standard Class 

Rating

(Ksat in μm/sec)

and Class Limita

pH

Available

Water 

Capacity 

(in/in)

Hydrologic 

Group

Wind Erosion 

Hazard 

(Erodibility

Group/Index)b

Water 

Erosion 

Hazard 

(K Factor 

Rating)

(Kw/Kf)

c

Landscape 

Positiond 

Depth to 

Bedrock

Suitability as 

Topsoil for 

Reclamation

Yomba gravelly 

sand (Ym) 55.9% Gravelly sand

71.4868 

High 7.4–9.0 0.04–0.18 B 2/134 .20/.37 

BZ

VF

PL

>60 inches Poor

Yomba-Playas 

complex (YO) 44.1% Gravelly sand

71.4868 

High 7.4–9.6 0.03–0.18 B 2/134 .20/.37 

BZ

VF

PL

>60 inches Poor

a Permeability is expressed as the representative saturated hydraulic conductivity (Ksat) rating in micrometers per second (μm/sec), which corresponds to various NRCS classes based on Ksat range 

as follows: Very Low (0.00–0.01), Low (0.01–0.1), Moderately Low (0.01–1.0), Moderately High (1–10), High (10–100), and Very High (100–705). b Wind erodibility groups (Groups 1 through 8) are made up of soils with similar properties affecting their susceptibility to wind erosion; Group 1 soils are most susceptible, Group 8 soils are least 

susceptible. Wind erodibility index is a numerical value indicating the soil susceptibility to wind erosion in tons per year per acre that can be expected to be lost to wind erosion. c K Factor Rating indicates the susceptibility of a soil to sheet and rill erosion by water and is one of the factors used in the Universal Soil Loss Equation. Values of K can range from 0.02 to 0.69 and 

other factors being equal, the higher the value the more susceptible the soil is to sheet and rill erosion by water. Kw is the value for the whole soil; Kf is the value for the fine fraction of the soil 

(material less than 2.0 millimeters in size).

d NRCS Geomorphic Description System Category (Landscape) Symbols: AF = alluvial fan, BZ = braided stream, DU = dune, PL = playa, VF = valley floor, VS = valley side (NRCS 2008)
YO

89

Ym

YO

Crescent Dunes

Solar Energy Project

Figure 3-17 Soils Within the Borrow Pit Area

Sources: National Resources Conservation Service; Photo: ESRI 2010

Project Site

NEVADA

0 100 200 300 400 500

Feet

Legend

Borrow Pit (40 acre) YO (Yomba-Playas complex)

Ym (Yomba gravelly sand)

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Soils_Borrow_Pit.mxd
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Table 3-27. NRCS soil types and evaluation criteria for the TL and Anaconda Moly Substation corridor 

NRCS 

Soil Series 

(NRCS Symbol)

Approx. 

Percentage 

of Study 

Area

Natural Resources Conservation Service (NRCS) Evaluation Criteria

USDA 

Surface 

Texture 

Rating

Permeability 

Standard Class 

Rating

(Ksat in μm/sec)

and Class Limita

pH

Available

Water 

Capacity 

(in/in)

Hydrologic 

Group

Wind Erosion 

Hazard 

(Erodibility

Group/Index)b

Water 

Erosion 

Hazard 

(K Factor 

Rating)

(Kw/Kf)

c

Landscape 

Positiond 

Depth to 

Bedrock

Suitability as 

Topsoil for 

Reclamation

Timber gravelly 

sandy loam, 

0 to 4 percent 

slopes (TEB)

14.2% 

Gravelly 

sandy 

loam

74.5376 

High 7.9–9.6 0.04–0.15 D 4/86 .17/.28 VFPL

>60 inches Fair

Playas (PN) 0.4% Silty 

clay

0.2150 

Moderately Low 8.5–9.6 0.02–0.04 D 4/86 .37/.37 

PL

VF

BZ

>60 inches Poor

Stumble loamy 

fine sand, 

0 to 8 percent 

slopes (STC)

68.9% 

Loamy 

fine 

sand

92.0000 

High 6.6–8.4 0.06–0.08 A 2/134 .17/.20 

VS

VF

AF

>60 inches Poor

Belcher 

gravelly sand, 

0 to 4 percent 

slopes (BEB)

16.5% Gravelly 

sand

14.9240 

High 7.9–9.6 0.04–0.15 D 2/134 .32/.20 VFPL

19 inches Poor

a Permeability is expressed as the representative saturated hydraulic conductivity (Ksat) rating in micrometers per second (μm/sec), which corresponds to various NRCS classes based on Ksat range 

as follows: Very Low (0.00–0.01), Low (0.01–0.1), Moderately Low (0.01–1.0), Moderately High (1–10), High (10–100), and Very High (100–705). b Wind erodibility groups (Groups 1 through 8) are made up of soils with similar properties affecting their susceptibility to wind erosion; Group 1 soils are most susceptible, Group 8 soils are least 

susceptible. Wind erodibility index is a numerical value indicating the soil susceptibility to wind erosion in tons per year per acre that can be expected to be lost to wind erosion. c K Factor Rating indicates the susceptibility of a soil to sheet and rill erosion by water and is one of the factors used in the Universal Soil Loss Equation. Values of K can range from 0.02 to 0.69 and 

other factors being equal, the higher the value the more susceptible the soil is to sheet and rill erosion by water. Kw is the value for the whole soil; Kf is the value for the fine fraction of the soil 

(material less than 2.0 millimeters in size).

d NRCS Geomorphic Description System Category (Landscape) Symbols: AF = alluvial fan, BZ = braided stream, DU = dune, PL = playa, VF = valley floor, VS = valley side (NRCS 2008)
Anaconda-Moly Substation

¬«89

Crescent Dunes Road

STC

TEB

BEB

BEB

Crescent Dunes

Solar Energy Project

Figure 3-18 Soils Within the Transmission

Line Corridor

Sources: National Resources Conservation Service; Photo: ESRI 2010

!

Project Site

NEVADA ±

0 0.5 1 1.5 2

Miles

Legend

Transmission line 500' BEB (Belcher gravelly sand, 0 to 4 percent slopes)

PN (Playas)

STC (Stumble loamy fine sand, 0 to 8 percent slopes)

TEB (Timper gravelly sand loam, 0 to 4 percent slopes)

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3.11 Social and Economics

3.11.1 Area of Analysis and Methodology 

The proposed project area is located approximately 13 miles northwest of Tonopah in Nye 

County, Nevada. The area of analysis for social and economic conditions includes the Proposed

Area, Alternative Area, borrow pit, and TL and Anaconda Moly Substation corridor. The CESA

includes Nye and Esmeralda counties, with emphasis on communities closest to the project 

area, such as Tonopah, Round Mountain, Silver Peak, and Goldfield. In many cases there are 

limited or no comparative data for these towns because of their small populations (i.e., less than 

20,000). State- and county-level data were used to set the proposed project in a regional 

context. 

3.11.2 Regulatory Framework 

Under NEPA, social and economic effects by themselves are not required in the preparation of 

an EIS. However, an EIS must include discussion of a proposed action’s social and economic 

effects when they relate to the effects on the natural or physical environment. These effects 

were examined to determine the impacts of the Proposed Action, alternatives, and the No

Action Alternative on local and regional social and economic conditions.

3.11.3 Affected Environment 

3.11.3.1 Proposed Area

3.11.3.1.1 Social Conditions

Social conditions result from interactions of humans with one another, over time, and from 

observable patterns and characteristics that they create in their surroundings. Social conditions 

include demographic characteristics, community character, and pubic facilities related to 

societal activities.

Key demographic characteristics of the project area include race, income, employment, housing, 

and population growth. Population growth is an important socioeconomic factor because of its 

direct influence on housing and employment growth and on existing and planned infrastructure. 

Population growth influences the demand for energy and catalyzes construction of energygenerating facilities. 

Populations

The project area is located in Nye County, approximately 13 miles northwest of the 

unincorporated town of Tonopah. In 2000, the population of Nye County was 32,978 (Table 3-

28). In 2008, the Nevada State Demographer’s Office projected that the 2009 population of Nye 

County would be 46,360, an increase of approximately 40.6 percent. Tonopah is the Nye County 

seat. In 2000, Tonopah’s population was 2,833. The 2009 projections anticipated an 8.9 percent 

decline in population. The unincorporated community of Round Mountain, approximately 70 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-80

miles northeast of the project area, was also projected to experience a decline in population (19 

percent). 

The Esmeralda County line is located approximately 2 miles west of the project area. The current 

population of Esmeralda County is 1,187, an 11.9 percent increase from the 2000 population of 

1,061. The county seat is Goldfield, located approximately 35 miles south of the project area. It 

has experienced a 4 percent increase in population between 2000 and 2009, from 424 to 441. 

Silver Peak, located approximately 35 miles southwest of the project area, was projected to 

experience a 12 percent decline in population during the same period, from 161 to 141. 

Table 3-28. Population estimates for Nye and Esmeralda counties and Nevada, 2000–2009

Geographic Area Population (2000) Population (2009a) Percentage Change

Nevada 1,998,257 2,711,206 34.0 

Nye County 32,485 46,360 40.6

 Tonopah 2,721 2,580 –8.9 

 Round Mountain 1,039 837 –19.4 

Esmeralda County 971 1,187 11.9 

 Silver Peak 161 141 –12.4 

 Goldfield 424 441 4.0 

Source: Nevada State Demographer’s Office 2008

a 2009 population as projected in 2008

For the last 23 years, Nevada has been among the four fastest-growing states in the country. In 

2008 and 2009, Nevada dropped to eighth place and lost population across the majority of 

towns in the project area (Table 3-29). This decline is attributable to a slowdown in the 

construction industry and the slowing of migration across the nation as current economic 

conditions make it more difficult for people to change jobs, sell their homes, and move to 

Nevada. 

Furthermore, Nye County’s economy has historically revolved around the mining sector and 

activities at the U.S. Department of Energy’s Nevada Test Area, resulting in unstable population 

growth rates from 1970 to 2002, indicating the need for economic diversification in the county 

(EDEN 2009). 

Table 3-29. Population estimates for Nye and Esmeralda counties and Nevada, 2008–2009

Geographic area Population (2008) Population (2009a) Percentage change

Nevada 2,738,733 2,711,206 –1.0 

Nye County 47,370 46,360 –2.1 

 Tonopah 2,628 2,580 –1.8

 Round Mountain 850 837 –1.5 

Esmeralda County 1,240 1,187 –4.3 

 Silver Peak 182 141 –2.2 

 Goldfield 415 441 6.4 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-81

Source: Nevada State Demographer’s Office 2008

a 2009 population as projected in 2008

According to the Nevada State Demographer’s Office, the population of Nevada is projected to 

increase by 31 percent over the next 15 years (2010–2025). Additionally, both Nye and 

Esmeralda counties are anticipated to experience steady growth through 2025 (Table 3-30). 

Population projections derive from historical population trends and have not been modified to 

account for future probable and foreseeable developments and events such as the current 

economic downturn.

Table 3-30. Population projections for Nye and Esmeralda counties and Nevada

Year

State of Nevada Nye County Esmeralda County

Projected 

Population

Percentage 

Change

Projected 

Population

Percentage 

Change

Projected 

Population

Percentage 

Change

2010 2,963,812 — 55,028 — 1,280 — 

2015 3,321,189 12.0 66,292 20.5 1,321 3.2 

2020 3,619,563 9.0 75,240 13.5 1,373 3.9 

2025 3,872,937 7.0 81,852 8.8 1,457 6.1 

Source: Nevada State Demographer’s Office 2008. 

Nye County is approximately 18,159 square miles (11.6 million acres). For a county of this size, it 

has a sparse population, partially attributable to the lack of available private land for 

development. Over 97 percent of the county’s land area is managed by federal agencies (Table 

3-31) as compared with 87 percent in the state of Nevada. Additionally, 19,000 acres are under 

state management, leaving only approximately 249,000 acres of private land in the county.

Table 3-31. Federal agencies managing lands in Nye County

Agency Acreage

U.S. Bureau of Land Management (BLM) 6,500,000 

U.S. Forest Service 1,900,000 

U.S. Department of Defense 1,800,000 

U.S. Department of Energy 863,000

National Park Service 107,000

U.S. Fish and Wildlife Service (USFWS) 13,700 

BLM/USFWS jointly managed 8,400 

U.S. Bureau of Indian Affairs 8,000 

Total 11,200,100 

Housing

Tables 3-32 and 3-33 summarize the housing characteristics of the population centers in the 

area of analysis. Housing data were obtained from the U.S. Census Bureau. Because of the small 

population in most towns in the project area, data gaps were present. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-82

Between 2000 and 2008, the U.S. Census Bureau estimated that Nye County would have a 4.1 

percent increase in available housing. In 2000, the towns near the project area in both 

Esmeralda and Nye counties had vacancy rates greater than 29 percent. Although more recent 

data are unavailable, with the current state of the economy and the decline in population (Table 

3-30), it is likely that vacancy rates will continue to maintain this high rate.

Table 3-32. Housing characteristics

Area

2000 

Number 

of Units

2000 

Vacant 

Units

2000 

Percentage 

Vacant 

2006–2008 

Number

of Units

2006–2008 

Vacant 

Units

2006–2008 

Percentage 

Vacant 

Nevada 827,457 76,292 9.2 1,098,307 151,160 13.8 

Nye County 15,934 2,625 16.5 16,592 3,202 19.3 

 Tonopah 1,589 463 29.1 Not available Not available Not available

 Round Mountain 872 203 23.3 Not available Not available Not available

Esmeralda County 833 378 45.4 Not available Not available Not available

 Silver Peak 399 165 41.4 Not available Not available Not available

 Goldfield 434 213 49.1 Not available Not available Not available

Source: U.S. Census Bureau 2009

Additional housing in the form of hotels and motels is also available near the project area. 

According to TravelNevada.com, in 2009 Tonopah had eight hotels/motels and Goldfield had 

one. Based on information from the Web site, the two towns had approximately 351 guest 

rooms among the nine hotels and motels. Additional accommodation is available in the form of 

recreational vehicle facilities, mobile home sites, and campgrounds. 

The most recent data on housing conditions and mortgage costs indicate that median housing 

conditions in Nye County are generally about 60 percent less than for the state of Nevada as a 

whole (Table 3-34). Housing conditions in Tonopah and other communities near the project area 

are also lower than those for the state and for Nye County. Many areas of the country report 

today’s housing values have declined to near 2000 housing values.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-83

Table 3-33. Housing conditions and costs

Area

2000 

Median 

Housing 

Conditions

2006–2008 

Median 

Housing

Conditions

2000

Average 

Monthly 

Mortgage 

Costs

2006–2008 

Average 

Monthly 

Mortgage 

Costs

2000

Median 

Monthly 

Gross

Rental Costs

2006–2008 

Median 

Monthly 

Gross

Rental Costs

Nevada 142,000a 296,200 1,190a 1,796 699 999 

Nye County 122,100 187,100 866 1,239 541 848 

 Tonopah 78,200 Not available 869 Not available 478 Not available

 Round 

Mountain

66,300 Not available 806 Not available 476 Not available

Esmeralda 

County

75,600 Not available 825 Not available 381 Not available

 Silver Peak 87,000 Not available 550 Not available 336 Not available

 Goldfield 71,300 Not available 950 Not available 389 Not available

Source: U.S. Census Bureau 2009

a figures are in nominal dollars

3.11.3.1.2 Economic Conditions

Historically, Nye County’s economy revolved around mining, agriculture, federal defense 

research and development, and the railroad. Mining and agriculture have been the primary 

activities; however, the importance of these sectors has decreased over time. Nye County has 

also been subject to the “boom-and-bust” economy long associated with the cyclical mining 

industry; mirroring this are both high and low population growth rates. The nearest town to the 

project area, Tonopah, has seen its historic dependence on mining shift to tourist traffic through 

the community and traffic serving the nearby Tonopah Test Range. 

In nearby Esmeralda County, the major employer is the government, primarily state 

government. Mining, trade, transportation, and utilities play a role. Like Nye County, Esmeralda 

County is restoring its mining ghost towns to attract more tourism.

Over a 20-year period, Nevada and Nye County showed an increase in employment, but also an 

increase in the unemployment rate. These rates include the current recession. Esmeralda 

County appears to show a decrease in jobs and a decrease in the unemployment rate (Table 3-

34). The small size of Esmeralda County magnifies even small changes to the economy. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-84

Table 3-34. Labor force characteristics of Esmeralda and Nye counties and Nevada, 1990–2010

Characteristic

Nevada Esmeralda County Nye County

1990 2010 1990 2010 1990 2010

Labor force 655,896 1,373,387 613 481 8,945 17,411 

Employment 622,516 1,185,677 575 457 8,616 15,714 

Unemployment 33,380 187,710 38 24 329 1,697 

Unemployment rate 5.1% 13.7% 6.2% 5.0% 3.7% 9.7% 

Source: Nevada Department of Employment, Training, and Rehabilitation – Research and Analysis Bureau 2010

Table 3-35 summarizes the number of people employed by all economic sectors in Nevada and 

in Nye and Esmeralda counties. Nye and Esmeralda counties have 89 percent and 68 percent, 

respectively, of their labor force employed by the private sector. Government is an important 

sector statewide and in each of the counties. This is particularly true in Esmeralda County, 

where 30 percent of the labor force holds government jobs. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-85

Table 3-35. Employment by industry for Nye and Esmeralda counties and Nevada, 2007 

Industry State of Nevada Esmeralda County Nye County

Farm 4,835 53 255 

Total Private 1,492,783 320 16,425 

 Forestry, fishing, etc. 1,886 (D)a 74 

 Mining 14,512 (D) 1,044 

 Utilities 4,680 0 131 

 Construction 156,837 (D) 1,571 

 Manufacturing 54,528 (D) 229 

 Wholesale trade 44,853 (D) 193 

 Retail trade 171,545 (D) 2,142 

 Transportation and warehousing 57,709 (D) 291 

 Information 20,518 (D) 137 

 Finance and insurance 75,034 11 478 

 Real estate 121,332 27 1,736 

 Professional, scientific, technical services 88,541 (D) 2,532 

 Management 19,447 (D) 34 

 Administrative and waste services 109,530 12 1,268 

 Educational services 11,393 0 (D) 

 Health care and social assistance 102,592 (L)b (D) 

 Arts, entertainment, recreation 52,576 (L) 962 

 Accommodation and food services 318,494 (D) 1,614 

 Other services, except public administration 66,776 (D) 953 

Total government 168,913 98 2,068 

 Federal, civilian 17,119 (L) 157 

 Military 14,672 (L) 115 

 State, local 137,122 91 1,796 

 State 33,329 (D) 167 

 Local 103,793 (D) 1,629 

Total 1,666,531 471 18,748 

Source: U.S. Department of Commerce, Bureau of Economic Analysis 2009

a (D) = not reported, confidential but included in total

b (L) = less than 10 jobs, but estimates for this item are included in the totals

Retail, professional, scientific, and technical services, along with government, are the largest 

employment sectors in Nye County. The largest sectors in Esmeralda County are farm, real 

estate, and government. Professional, scientific, and technical services, the largest sector in Nye 

County, accounts for 13.5 percent of employment, compared with only approximately 5 percent 

statewide. 

Rural counties have a tendency to lose population in the 20–34 year age group because many 

members of this cohort move to more urban areas where there is greater opportunity to realize 

educational and career opportunities. Additionally, increased rates of retirees moving to rural 

areas raise concerns that more public services will be required, which would tax an economy 

with a shrinking revenue base. In Nye County, government payments to individuals for 

retirement and disability insurance benefits (primarily Medicare and Medicaid), income 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-86

maintenance benefits, and veteran’s benefits accounted for 22.7 percent of the total personal 

income compared with 10.7 percent in the state of Nevada; an indicator of a relatively large 

retirement population in the county (U.S. Department of Commerce 2009).

Tables 3-36 and 3-37 list the largest employers in Nye and Esmeralda counties. It is unknown 

whether these employees reside in the county where they work or whether they commute. For 

instance, an employee may reside in Esmeralda County but commute to Nye County to work.

Table 3-36. Largest employers in Nye County

Employer City Industry Number 

of Employees

Bechtel Nevada 

Corporation — Research and development 1,000–1,499 

Nye County School District Tonopah Elementary and secondary schools 900–999 

Smoky Valley Mining 

Division — Gold ore mining 700–799 

Nye County Tonopah Tonopah executive and legislative offices 

combined 600–699 

Source: NV Energy 2010

Table 3-37. Largest employers in Esmeralda County

Employera City Industry Number of 

employees

Esmeralda County Goldfield — 60–69 

Chemetall Foote Corporation Silver Peak Lithium mining 50–59 

Esmeralda County School 

district

Goldfield Elementary school 30–39 

Source: Esmeralda County 2010

a

 all other, greater than 20 employees

Income

Median household income and per capita income data were obtained from the U.S. Census 

Bureau’s American Community Survey. The most recent data, 2008, indicate the median 

household income in the state was $56,432, Nye County’s was $43,463, and Esmeralda County’s 

was $40,299. U.S. Census Bureau data were not available for towns with less than 20,000 

residents. 

Law Enforcement and Emergency Services

Law enforcement in the project area is provided by the Nye County Sherriff’s Department and 

the Nevada Highway Patrol. The Nye County Sheriff’s Office North Area Command has 

headquarters in Tonopah. Emergency services, including fire and ambulance, in the surrounding 

area are provided by the town of Tonopah. The Nye Regional Medical Center is located in 

Tonopah. BLM is responsible for fire protection for wildland fires on public land. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-87

Electricity and Natural Gas

The project area is served by NV Energy (formerly Sierra Pacific Power Company). NV Energy 

service covers 54,500 square miles, providing electricity to 2.4 million customers throughout 

Nevada and northeastern California (NV Energy 2010). 

Public Water Supply and Wastewater

There are few public water supply systems in the project area. The majority of water users rely 

on individual wells. Tonopah Public Utilities manages public water supply systems near the 

project area (Economic Development Authority of Nye County 2010).

Solid Waste

NDEP, Bureau of Waste Management, oversees permitting of solid waste landfills and other 

waste management facilities within the state of Nevada. Tonopah has an operating Class II 

landfill. 

Schools

The project area is located within the Nye County School District. Of the district’s five public 

schools, none are within the project area. A summary of school information and enrollment is 

provided in Table 3-38. 

Table 3-38. Summary of schools in the Nye County School District

Schools Grade Levels Number of Students 

for 2009–2010 School Year

Silver Rim Elementary (Tonopah) K–2 87 

Tonopah Elementary /Middle (Tonopah) 3–8 191 

Tonopah High (Tonopah) 9–12 161 

Round Mountain Elementary (Round Mountain) K–5 145 

Round Mountain Middle/High (Round Mountain) 6–12 177 

Source: Nye County School District 2010

Fiscal Resources

The Nye County Finance Department describes County governmental revenues and 

expenditures within 5 major funds and approximately 67 nonmajor funds. The General Fund is 

the primary operating fund for Nye County (Nye County 2010). Tables 3-39 and 3-40 summarize

the Nye County revenues and expenditures, respectively. Any tax (direct revenue) benefit of the 

proposed facility would go to Nye County; however, indirect revenue such as employment 

would benefit the region.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-88

Table 3-39. Nye County revenues, 2008–2009

Revenue General 

Fund

Education 

Endowmen

t Fund

Special 

Project 

Fund

Endowmen

t Capital 

Projects 

Fund

Repositor

y 

Oversight 

Fund

Other 

Government

al Funds

Totals 

Taxes $16,049,40

2 $—a $— $— $— $6,118,385 $22,167,787 

Licenses 128,395 — — — — 1,233,861 1,362,256 

Intergovernment

al resources 14,756,343 — 8,651,700 — 4,467,271 9,448,981 37,324,295 

Charges for 

services 2,370,025 — — — — 2,111,922 4,481,947 

Fines for 

forfeitures 354,485 — — — — 1,133,408 1,487,893 

Other 1,714,752 479,252 914,422 645,209 — 2,188,873 5,942,508 

Total Revenues 35,373,402 479,252 9,566,12

2 645,209 4,467,271 22,235,430 72,766,686 

Source: Information was taken directly from Nye County 2010; inconsistencies have been noted. a Dashes indicate that the relevant revenue source did not contribute to the County fund or that the fund did not pay for the 

relevant expense in fiscal year 2008–2009. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-89

Table 3-40. Nye County expenditures for fiscal year 2008–2009

Expenditure General 

Fund

Education 

Endowment 

Fund

Special 

Project 

Fund

Endowment 

Capital 

Projects 

Fund

Repositor

y 

Oversight 

Fund

Other 

Government

al Funds

Totals 

General 

government

$12,520,44

3 $— $321,648 $— $4,467,271 $4,028,094 $21,337,456 

Judicial 6,613,059 — 10,906 — — 349,108 6,973,073 

Public safety 16,358,654 — 50,071 — — 3,585,514 19,994,239 

Public works 99,432 — 108,100 — — 6,472,230 6,679,762 

Health and 

sanitation 315,963 — — — — 983,838 1,299,801 

Welfare — — — — — 1,935,744 1,935,744 

Culture and 

recreation — — 26,745 — — 522,554 549,299 

Community 

support 410,070 — 76,539 — — 459,967 946,576 

Intergovernmental — 479,252 124,590 — — 709,416 1,313,258 

Capital 

projects — — 2,154,10

0 — — 936,710 3,090,810 

Debt service — — — — — 

 Principal — — — — — 2,262,887 2,262,887 

 Interest — — — — — 356,958 356,958 

Total 

expenditures 36,317,621 479,252 2,872,699 — 4,467,271 22,603,020 66,739,863 

Excess 

(deficiency) of 

revenues over 

expenditures

(944,219) — 6,693,42

3 645,209 — (367,590) 6,026,823 

Source: Information was taken directly from Nye County 2010; inconsistencies have been noted. a Blank cells indicate that the relevant revenue source did not contribute to the County fund or that the fund did not pay for the 

relevant expense in fiscal year 2008–2009.

3.11.3.2 Alternative Area

Existing conditions are the same as described previously for the Proposed Area.

3.11.3.3 Borrow Pit

Existing conditions are the same as described previously for the Proposed Area.

3.11.3.4 TL and Anaconda Moly Substation

Existing conditions are the same as described previously for the Proposed Area.

3.12 Visual

3.12.1 Area of Analysis and Methodology 

The visual resources study area for the proposed project was defined as the area wherein 

potential undesirable visual effects from construction and maintenance of the proposed project 

may be observed. The methodology used for this visual analysis is based on the BLM Visual 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-90

Resource Inventory and Visual Resource Contrast Rating handbook (BLM 1986a,b). This BLM 

methodology establishes a baseline for visual characteristics. A viewshed delineation was 

prepared for the proposed and alternative areas using a digital elevation model (DEM) (HDR 

2010). This delineation illustrates areas from which viewers would have a clear line-of-sight to 

the project area within 10 miles of the proposed and alternative areas (HDR 2010). Output from 

this DEM indicates areas in which the project would be “visible” and “not visible” to observers in 

the study area. The model takes into account topography, viewer height, and the height of 

project components mainly the central receiver tower (as this would be the most visible feature 

throughout the viewshed). This is important because changes in topography can block or expose 

views. During the field reconnaissance, six critical viewpoints or Key Observation Points (KOPs)

were established within the visible portion of the viewshed delineation using BLM Visual 

Resource Management (VRM) guidance (Figure 3-19). KOPs were selected in populated or 

commonly utilized areas where people could possible have a view of the proposed project. 

These areas included the Crescent Dunes Special Recreation Management Area, commonly 

traveled roads, and residential communities. 

According to the Tonopah RMP and Final EIS, the proposed and alternative areas as well as the 

surrounding land in the Big Smoky Valley are classified as Class C and managed according to 

VRM Class IV standards (BLM 1997). However, since the RMP and EIS were published in 1997, 

visual resource specialists completed a Scenic Quality Evaluation worksheet at each KOP. 

Additionally, Visual Contrast Rating worksheets were completed for each KOP and discussed in 

Chapter 4(HDR 2010). 

Since the Proposed Area and the Alternative Area are adjacent to each other, the KOPs 

presented in this chapter illustrate the view from the KOP to the proposed project area. KOPs 

and visual simulations for the proposed action and alternatives are included in Chapter 4.

3.12.2 Regulatory Framework 

The following section outlines all federal, state, and local laws, policies, and regulations that

apply to the area of analysis and were considered in the development of this visual resources 

analysis. 

3.12.2.1 Federal

The FLPMA requires BLM to protect the quality of scenic values on public lands (43 USC 1701). 

BLM has developed an analytical process that identifies, sets, and meets objectives for 

maintaining scenic values and visual quality. The VRM system functions in two ways: first, BLM 

conducts an inventory that evaluates visual resources on all lands under its jurisdiction; once 

inventoried and analyzed, lands are given relative visual ratings (i.e., VRM classifications). VRM 

classes describe the different degrees of modification allowable within the landscape. The BLM 

VRM classes are as follows:
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-91

• Class I. To preserve the existing character of the landscape. The level of change to the 

characteristic landscape should be very low and must not attract attention.

• Class II. To retain the existing character of the landscape. The level of change to the 

characteristic landscape should be low.

• Class III. To partially retain the existing character of the landscape. The level of change 

to the characteristic landscape should be moderate.

• Class IV. To provide for management activities that require major modification of the 

existing character of the landscape. The level of change to the characteristic landscape 

can be high. The area of analysis for the proposed project is located on Class IV land. 

The Tonopah RMP and ROD assign VRM classes ranging from Class I to IV to all BLM lands in the 

planning area. All future projects and actions must adhere to the objectives of the applicable 

VRM classes. The original VRM inventory was completed by BLM in 1997 and is included in the 

Tonopah RMP and ROD. 

3.12.3 Affected Environment 

This section provides a detailed inventory of the existing visual landscape. The area of analysis

for this visual resources assessment is defined as the area wherein potential undesirable visual 

effects from construction, operation, and decommissioning of the Proposed Action may be

discerned. 

3.12.3.1 Regional Setting

The proposed solar energy project is located in Nye County, Nevada, approximately 13 miles 

from the town of Tonopah, Nevada. The project area is located on unincorporated land 

administered by BLM. The project area is located in the basin and range physiographic province 

in the Great Basin Desert sub-province characterized by expansive flat desert valleys surrounded 

by high fault-block mountains. The region generally consists of wide valleys or basins bounded 

by alluvial slopes and mountain ranges. Views from travel routes (e.g., US 95) tend to be of 

broad, sweeping desert in a semiarid landscape. 

Other nearby mountains include Lone Mountain to the south, Pilot Peak to the east, and the 

Shoshone and Toiyabe Ranges to the north. 

Within the regional setting, the visual resources study area was defined by viewpoints from 

which the proposed facilities would be seen. The viewshed is extensive given the openness of 

the landscape and the availability of viewpoints from travel routes, recreational areas, and the 

nearby community of Tonopah. 
Smoky Valley

!(2

!(3

!(4

!(1

!(6

!(5

0 0.8 1.6

Miles

Legend

Borrow Pit Alternative Area

Proposed Area

±

Source: ESRI 2010, USGS Seamless GIS Data Web Server

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Key_observation.mxd

Tonopah

!

Project Site

NEVADA Figure 3-19 Key Observation Points for

Visual Resource Analysis

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-93

3.12.3.2 Project Setting

The project area is located in northeastern Esmeralda County and southwestern Nye County and 

lies in Gabb’s Valley Range north of SR 95 and south of the Humboldt-Toiyabe National Forest. 

The topography of the area is flat, with steeply sloping elevations ranging between 9,100 and 

11,000 feet in the background distances. The project area is accessible via SR 95 and Pole Line 

Road. Access into the landscape is open due to the flat expanses of land. 

The majority of land in the study area is administered by BLM and has been classified as a VRM 

Class IV landscape. BLM has defined the objectives for development on Class IV landscapes as 

having “to provide for management activities which require major modifications of the existing 

character of the landscape. The level of change to the characteristic landscape can be high. 

These management activities may dominate the view and be the major focus of viewer 

attention. However, every attempt should be made to minimize the impact of these activities 

through careful location, minimal disturbance, and repeating the basic elements.”

Development within the area of analysis is minimal and is limited to utility development such as 

“H” frame and monopole power lines, a power substation, and paved roads. Vegetation within 

the area of analysis is xeric shrub-steppe or sagebrush, which is typical of the region. No visible 

flowing water features are located within the project area, although ephemeral drainages may 

be present seasonally or during precipitation. 

Tonopah has been designated as a premier stargazing destination. Dark sky conditions are a 

valuable asset to the town, and efforts to encourage the proper use of lighting and light 

shielding is included in the mitigation section of this assessment. 

3.12.3.3 Proposed Area

The landscape in the Proposed Area is generally characterized by flat desert with low-lying 

desert scrub vegetation bounded by high-relief fault-block mountains in the seldom seen 

distance zone (over 15 miles away). Landscape in the region appears desolate, that is, devoid of 

any major cultural modification aside from a paved two-lane rural highway and a power line 

corridor (oriented northeast and southwest) that bisects the landscape approximately 3 miles 

north of the Proposed Area. The colors within the landscape are limited to bands of earth tone 

browns and tans, with few other distinguishing colors, creating a relatively homogenous 

appearance. 

The most distinctive natural feature in the area is the Crescent Dunes SRMA. The Crescent 

Dunes are relatively unique as they are smooth, undulating sand dunes that are visible from

over 5 miles away. According to the BLM, approximately 1,200 people/year visit the site (BLM 

2010f) 

The closest residences to the Proposed Area are approximately 10 miles away to the south. The 

residential area is on the outskirts of the town of Tonopah located off Radar Road. Most of the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-94

residences in this area are single-family detached homes. Approximately 10 houses (located at a 

slightly higher elevation) currently have views of Crescent Dunes in the distance and, as such, 

would have views of the Proposed Area. Views from this area may be slightly obstructed by 

vegetation, topography, and distance. 

The Proposed Area is located immediately adjacent to Pole Line Road, which is a paved two-lane

highway. This road provides access to residences and farmland, as well as the existing Anaconda 

Moly Substation from SR 95. Pole Line Road has a very low level of daily traffic. 

Given the special recreation designation of Crescent Dunes, the area supports some recreational 

activity, although no signs indicating recreational areas are apparent. Crescent Dunes and the 

surrounding landscape are used by off-highway vehicle recreationists, as evidenced by an 

extensive network of 4-wheel drive trails and staging areas located sporadically throughout the 

area.

3.12.3.3.1 KOP 1 – Crescent Dunes SRMA

KOP 1 is within the SRMA (the view faces north toward the Anaconda Moly Substation). From 

this vantage point, high-relief mountains are visible for nearly 180 degrees from north to south

(Photograph 1). The landscape in the foreground and middleground is flat and sparsely 

vegetated. Background distances reveal high-relief fault-block mountains that form a distinct 

line along the horizon. The landscape in the area is very desolate and undeveloped. The area is 

unique to the region in that the series of smooth, sandy dunes form a distinctive and interesting 

visual feature that is visible from nearly 10 miles away in almost any direction.

Photograph 1. View from KOP 1 faces north toward the Anaconda Moly Substation
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-95

3.12.3.3.2 KOP 2 – Anaconda Moly Substation

KOP 2 is located at the western edge of the Anaconda Moly Substation (Photograph 2; view 

faces south toward the Crescent Dunes along the existing TL corridor). The landscape in this area 

is relatively flat, with a few hills in the middleground. The background distances reveal highrelief, fault-block mountains that form a distinct line along the horizon. Vegetation in this area is 

limited to low-lying desert scrub that creates a coarse texture in the foreground. There is an 

access road to the Anaconda Moly Substation off of Pole Line Road. Viewers from KOP 2 would 

likely be limited to those with access to the substation.

Photograph 2. View from KOP 2 faces south toward the Crescent Dunes along the existing TL

corridor
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-96

3.12.3.3.3 KOP 3 – Anaconda Moly Substation

KOP 3 is approximately 1.5 miles southwest of the Anaconda Moly Substation. Facing southeast 

from the roadway, the existing TL corridor is evident (Photograph 3). The landscape in this area 

is relatively flat with some hills in the middleground. Vegetation is sparse and limited to desert 

scrub typical of the region. High-relief mountains are evident in the seldom seen distance zone.

Photograph 3. KOP 3 is the view facing southeast toward the project area from the Anaconda

Moly Substation access road
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-97

3.12.3.3.4 KOP 4 – Pole Line Road

KOP 4 faces east toward the Crescent Dunes from the intersection of Pole Line Road and the 

unpaved access road to Crescent Dunes (Photograph 4). The landscape in this area is flat in the 

foreground and middleground with low-lying desert scrub vegetation. Exposed soil unpaved 

roads provide access to Crescent Dunes to the east. High-relief mountains are visually dominant 

in the background and form the horizon line. These mountains dominate the viewshed.

Photograph 4. KOP 4 faces east toward the Crescent Dunes from the intersection of Pole Line 

Road and the unpaved access road to Crescent Dunes
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-98

3.12.3.3.5 KOP 5 – Penstemon Court

KOP 5 is located slightly higher (on a hill) with views to the north toward the proposed project

(Photograph 5). This area is characterized by panoramic views of expansive desert with low-lying 

desert scrub and some hills evident in the middleground. High-relief mountains are evident in

the background and seldom seen distances form the horizon line. Because of the relatively flat

nature of the landscape, unobstructed viewing conditions exist for over 15 miles. Additionally, 

with distance, the detail and texture within the landscape appears as horizontal striations in 

background distances. There are approximately 100 residences in this area; views from these 

residences are over 10 miles away.

Photograph 5. KOP 5 at Penstemon Court to the north
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-99

3.12.3.3.6 KOP 6 – Miller’s Rest Stop

Miller’s Rest Stop is located approximately 11 miles from the proposed project area (Photograph 

6). The rest stop is located off Interstate 6, and the existing TL corridor is evident in this area. 

The landscape is characterized largely by bare earth and sparse vegetation. Views of the 

mountains are a dominant visual feature and form the horizon line. Crescent Dunes is evident in 

the background. Views from this area would largely be from travelers along Interstate 6.

Photograph 6. KOP 6 at Miller’s Rest Stop to the east

3.12.3.4 Alternative Area

Located slightly north of the Proposed Area, the Alternative Area is in an aesthetic setting that is 

the same as the Proposed Area. The conceptual footprint of Alternative 1 is located on the cusp 

of the Crescent Dunes SRMA, and Alternative 2 is located closer to Pole Line Road (see Figure 3-

1 for project layout). Residences located to the south are approximately 12 miles away from the 

Alternative Area. Additionally, this area is used by off-highway vehicle recreationists accessing 

the Crescent Dunes SRMA. 

3.12.3.5 Borrow Pit

The borrow pit area is an existing industrial use located outside of the viewshed. None to very 

few sensitive viewers are likely to see this area.

3.12.3.6 TL and Anaconda Moly Substation

The proposed TL and substation would connect the existing Anaconda Moly substation to the 

proposed power block location at the project site. The majority of the proposed TL would follow 

the existing Miller’s to Anaconda Moly TL corridor oriented northeast-to-southwest. The TL

corridor would run perpendicular to Pole Line Road in the vicinity of the proposed project site, 

then parallel the road before connecting with the proposed power block.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-100

The landscape in the area of the TL corridor is flat desert valley, bounded by high-relief, faultblock mountains in the seldom seen distance zone (beyond 15 miles). Views of the proposed TL

would be evident from Pole Line Road but would likely be indiscernible from other areas.

Recreationists using the Crescent Dunes SRMA would be able to see the proposed TL from some 

vantage points. 

3.12.3.7 CESA

The CESA, or viewshed, is defined as the area where the project facilities, including the solar

field and TLs, are visible. The viewshed has an approximate radius of 10 miles in any direction

from the project site. The proposed project would not be a dominant visual feature beyond 

5 miles, and views beyond 10 miles of the project would be very difficult to discern.

3.13 Hazardous Materials

3.13.1 Area of Analysis and Methodology 

A Phase I Environmental Site Assessment (Phase I ESA) was performed by JBR (JBR 2010b). The 

areas assessed included the Proposed Area, the Alternative Area, the borrow pit, and the TL and 

substation corridor (see Figure 3-1), totaling approximately 7,050 acres. The Phase I ESA goal 

was to gather evidence of the use of hazardous materials and petroleum products on-site and 

off-site near the subject property that may have resulted in environmental hazards.

The analysis included an online data source review and interviews with relevant agency 

personnel.

3.13.2 Regulatory Framework 

The Phase I ESA was conducted in accordance with the scope and limitations of American 

Society for Testing and Materials (ASTM) Standard Practice E 1527-05, and the standards for 

conducting all appropriate inquiries set forth by EPA in 40 CFR 312.

The use, storage, and disposal of hazardous materials are regulated by several local, state, and 

federal agencies. Table 3-43 summarizes the various regulations and regulatory agencies. Laws 

and regulations related to hazardous waste and regulated, non-hazardous waste are 

summarized in Table 3-46.

3.13.3 Affected Environment 

3.13.3.1 Proposed Area

The Phase I ESA did not reveal any recognized environmental conditions (RECs) as defined by 

ASTM E 1527-05.

3.13.3.2 Alternative Area

The Phase I ESA did not reveal any RECs as defined by ASTM E 1527-05.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-101

3.13.3.3 Borrow Pit

The Phase I ESA did not reveal any RECs as defined by ASTM E 1527-05.

3.13.3.4 TL and Anaconda Moly Substation

The Phase I ESA did not reveal any RECs as defined by ASTM E 1527-05.

Table 3-43. Summary of applicable regulations for the use, storage, and disposal of hazardous 

materials

Regulation Requirements/Applicability 

Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA or Superfund), 

as amended by the Superfund Amendments and

Reauthorization Act of 1986 (SARA): 42 United States 

Code (USC) Section 9601 et seq., 40 Code of Federal 

Regulations (CFR) Part 302

Requires notification to various agencies when there is a 

release of hazardous substances from a facility.

Emergency Planning and Community Right to Know Act 

of 1986 (EPCRA), commonly known as SARA Title III: 42

USC Section 11001 et seq., 40 CFR Parts 350, 355 370, 

and 372

Requires inventory reporting, planning, and reporting for 

storage and release of hazardous and acutely hazardous 

materials.

EPCRA, Section 302 (Public Law 99–499), 42 USC 11022

Requires agency notification if extremely hazardous 

substances are stored in excess of Threshold Planning 

Quantities.

EPCRA, Section 311 (Public Law 99–499), 42 USC 11021

Requires that either material data safety sheets for all 

hazardous materials or a list of all hazardous materials be 

submitted to Nevada Emergency Response Commission 

and local fire department.

EPCRA, Section 313 (Public Law 99–499), 42 USC 11023 Requires annual reporting of releases of hazardous 

materials.

Occupation Safety and Health Administration, 29 USC 

Section 651 et seq., 29 CFR Part 1910, Safety and Health

Regulations for Construction: 29 CFR Part 1926

Specifies standards for hazardous materials storage, 

handling, and worker protection in emergencies.

Oil Pollution Prevention: 40 CFR Part 112

Requires the preparation of a Spill Prevention Control and

Countermeasure Plan if storage capacity exceeds certain

volumes, and should there be a reasonable possibility that 

the tank(s) may discharge oil into navigable waters of the 

United States.

Hazardous Materials Transportation, 49 CFR 171–172 Requires transporters of hazardous materials to properly 

label, manifest, package, and ship hazardous materials.

Chemical Accident Prevention Provisions, 40 CFR Part 68

Requires the preparation of a Risk Management Plan if 

certain listed toxic or flammable substances are used in 

excess of the listed threshold quantity.

Chemical Facility Antiterrorism Standard, 6 CFR Part 27

Requires facilities that possess any “chemicals of interest” 

above threshold quantities must register and provide 

specified information to the U.S. Department of 

Homeland Security.

Hazard Communication (HAZCOM) Program, 

29 CFR 1910.1200, Safety and Health for Construction, 

29 CFR 1926.1 et seq. 

Requires employers to implement HAZCOM Standard that 

gives workers the right to know the hazards and identities 

of chemicals in their workplaces (29 CFR 1910.1200). 

Requires written procedures and personnel protective 

equipment for employees working with hazardous 

materials.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-102

Table 3-44. Summary of regulations applicable to hazardous and non-hazardous wastes

Regulation Requirements/Applicability Administering Agency

Resource Conservation and

Recovery Act (RCRA), 42 United 

States Code (USC) 6901 et. seq. 

(1976), 40 Code of Federal 

Regulations (CFR) Parts 260, 261, 

262, Hazardous Waste Management

Applicable to Generators

Requires hazardous waste generators to 

obtain an Environmental Protection Agency 

Identification (EPA ID) number and annually 

register with the Nevada Division of 

Environmental Protection (NDEP) to

accumulate and store hazardous waste for 

no more than 90 days and ship hazardous 

waste under a manifest to a licensed 

disposal site. Requires generator to identify 

and profile hazardous waste, store 

hazardous waste in appropriate containers, 

label containers stored on-site and 

transported to disposal site, and train 

operators in hazardous waste management.

EPA Region IX

NDEP

RCRA; 42 USC 6901 et. seq. (1976), 

40 CFR 263, Hazardous Waste 

Transportation, Nevada Revised 

Statutes (NRS) 459 

Requires hazardous waste generator to use 

registered transporters of hazardous wastes 

that have an EPA ID number, use manifests 

to accompany waste shipments, and 

conduct proper cleanup of any hazardous 

waste discharges.

EPA Region IX

NDEP

Nevada Department of

Transportation

Universal Waste, 60 Federal 

Register (FR) 25542, May 11, 1995, 

as amended at 64 FR 36488, July 6, 

1999; 70 FR 45520, August 5, 2005, 

40 CFR 273 

Requires management, employee training, 

and proper disposal of universal waste that 

includes batteries, fluorescent lamps, 

mercury switches, and pesticides.

EPA Region IX

NDEP

Used Oil Solid Waste Disposal Act, 

as amended [42 USC 6905, 6912(a),

6921 through 6927, 6930, 6934, and 

6974]; and Comprehensive 

Environmental Response,

Compensation, and Liability Act [42 

USC 9601(37) and 9614(c)], 

40 CFR 279, Nevada Administrative 

Code Chapter 444

Requires generators of used oil to prevent 

spills and correctly label, store, transport, 

and dispose of/recycle used oil.

NDEP

EPA Region IX

3.13.4 CESA

The Phase I ESA did not reveal any RECs as defined by ASTM E 1527-05.

3.14 Range Resources

3.14.1 Area of Analysis and Methodology 

This section addresses range resources, which include livestock grazing and wild horses, within 

the detailed area of analysis that includes the Proposed Area, Alternative Area, borrow pit, and 

the TL corridor. This section provides a discussion of the livestock grazing areas, class of livestock 

grazed, and existing grazing management. The proposed project is not within a Herd 

Management Area for wild horses or burros. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-103

3.14.2 Regulatory Framework 

3.14.2.1 BLM Standards and Guidelines for Livestock Grazing

BLM has established Standards and Guidelines by the Secretary of the Interior (43 CFR 4180). 

The purpose of these Standards and Guidelines is to ensure that the BLM administration of 

grazing helps preserve currently healthy conditions and restores healthy conditions of 

rangelands.

3.14.2.2 BLM RMPs

In addition, the BLM Tonopah RMP that covers the project area has developed rangeland 

programs that authorize livestock grazing on public lands [43 CFR 1601.0-5(b) and CFR 4100.08]. 

The regulations require that BLM manage livestock grazing on public lands under the principle of 

multiple use and sustained yield. To accomplish this, rangeland has been broken down into 

controllable allotments to manage short- and long-term objectives for livestock grazing. 

Allotments are leased to permittees for a defined period of time. Allotments are managed to 

increase availability of forage and develop improvements, and are evaluated periodically to 

determine whether management goals are being met.

3.14.2.3 Allotment Grazing Management Plan

A Grazing Management Plan has not been developed for the affected grazing allotment; 

therefore, management of grazing follows the guidelines provided in the RMP. 

3.14.3 Affected Environment 

3.14.3.1 Proposed Area

3.14.3.1.1 Livestock Grazing

The study area is open to livestock grazing as managed by BLM. The Proposed Area, the 

Alternative Area, the borrow pit, and the TL and Anaconda Moly Substation corridor are within 

the San Antone Grazing Allotment (Allotment Number 0073) based on BLM allotment maps 

(Figure 3-20). The San Antone Grazing Allotment covers 442,555 acres. One permittee is 

authorized to graze within this allotment, and the permittee is authorized to graze cattle at a 

stocking level of 13,505 animal unit months (32.7 acres per animal unit month). Access to the 

proposed project is along US 95, and then along SH 89 (Pole Line Road), which passes through 

the extreme northeastern edge of the Monte Cristo Grazing Allotment. However, because no 

construction would occur within this allotment, the area potentially affected is very small, and 

the same individual holds permits for grazing this allotment and the San Antone allotment and 

manages them as one—this evaluation does not address the Monte Cristo Allotment separately.

Grazing allotment management is guided by objectives and guidelines established in the RMP. 

Based on the RMP, the San Antone Allotment has been assigned an allotment management 

category of “Improve,” which indicates that the management of the allotment is to focus on 

improving the current unsatisfactory resource condition.
Anaconda Substation

Borrow Pit

Alternatives/

Proposed Area

6

San Antone

Monte Cristo

Ralston

Ione

Toiyabe National Forest

Toiyabe National Forest

Smoky Francisco

Montezuma

Smoky

Hunts Canyon

City of Tonopah

Columbia Salt Marsh Silver King

Private Land

0 510

Miles

Legend

Borrow Pit (40 acre)

Transmission line

Alternative Area

Proposed Area

Grazing Allotment Boundary Aerial Source: ESRI 2010, Allotment data: BLM May 2009

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures\Allotment_figure\Allotment.mxd

Tonopah

Figure 3-20 Grazing Allotments Within

the Big Smoky Valley

Crescent Dunes 

Solar Energy Project

Project Site

NEVADA

Anaconda Substation
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-105

Important forage production plant species within this allotment include Indian ricegrass, 

winterfat, galleta grass, sand dropseed, shadscale, kochia, Nevada Ephedra, fourwing saltbush, 

and squirreltail (BLM 1997) (see Section 3.2, Vegetation) for MLRA ecological units within the 

project area, and forage species typically produced within these units include the species listed 

as important forage species. 

No naturally occurring seeps or springs are present within or near the Proposed Area, the 

Alternative Area, the borrow pit, and the TL and Anaconda Moly Substation corridor. Also, no 

troughs, pipelines, or wells for cattle use have been developed near the Proposed Area or within 

the borrow pit or alignment for the TL corridor. 

No fences, corrals, cattle guards, or other range improvements have been made in the vicinity of 

the proposed project, alternatives, or ancillary facilities. 

3.14.3.2 Alternative Area

Existing conditions are the same as for the Proposed Area.

3.14.3.3 Borrow Pit

Existing conditions are the same as for the Proposed Area.

3.14.3.4 TL and Anaconda Moly Substation

Existing conditions are the same as for the Proposed Area.

3.14.3.5 CESA

Existing conditions are the same as for the Proposed Area.

3.15 Recreation and Wilderness

This section describes recreational opportunities in the project area and provides a discussion of 

the relevant recreation plans and policies. 

3.15.1 Area of Analysis and Methodology 

The area of analysis for recreation and wilderness resources includes the Proposed Area, 

Alternative Area, borrow pit, and TL corridor. The CESA for recreation/wilderness resources 

includes all federal, state, local, and private recreational areas within 25 miles of the project 

area.

To assess the existing condition of recreation and wilderness, the locations of national forests, 

wilderness areas, wilderness study areas, hunting units, campgrounds, and SRMAs were 

reviewed and are illustrated on Figures 3-21 and 3-22. In addition, these resources were 

evaluated within a 10-mile radius of the project area to assess potential cumulative effects 

(Figure 3-22). Additionally, the Statewide Comprehensive Outdoor Recreational Plan, hunter 

information sheets, and NDOW Big Game Statistics were reviewed to identify recreational 

opportunities within the project area.
Borrow Pit

Anaconda-Moly Substation

Crescent Dunes 

SRMA

¬«89

Aerial Source: ESRI 2010

Figure 3-21 Recreational

Management Areas

within the Project Area

Crescent Dunes 

Solar Energy Project

0 0.6 1.2

Miles

± !

Project Site

NEVADA

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\SRMA_Map_SMALL_042910.mxd

Legend

Transmission line

Alternative Area

Proposed Area

Borrow Pit (40 acre)

Rights-of-way avoidance areas (Crescent Dunes SRMA)

Nevada Test and Training Range

TRAC-ON Trail
Tonopah

Nellis Test and 

Training Range

(Nellis Air Force Base)

Borrow Pit

Anaconda-Moly Substation

Humboldt-Toiyabe National Forest Humboldt-Toiyabe National Forest

211

173

212

0

162

161

251

171

205

172

Arc Dome Wilderness

Aerial Source: ESRI 2010

Figure 3-22 Recreation

Management Areas Within

the Cumulative Effects Study Area

Crescent Dunes 

Solar Energy Project

0 5 10

Miles

± !

Project Site

NEVADA

G:\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\SRMA_Map_042610.mxd

Legend

Transmission line

Arc Dome Wilderness

Borrow Pit (40 acre)

Hunting Units

CESA (25-mile buffer)

Humboldt-Toiyabe National Forest

Alternative Area

Proposed Area

Rights-of-way avoidance area seasonal

Rights-of-way avoidance areas (Crescent Dunes SRMA)

Nevada Test and Training Range
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-108

3.15.2 Regulatory Framework 

3.15.2.1 BLM and Tonopah RMP

The RMP provides the TFO with a comprehensive framework for managing 6.1 million acres of 

public land in Nye and Esmeralda counties. All public land within the planning area, unless 

otherwise classified as ROWs avoidance areas, is available for land use leases and permits under 

Section 302 of the FLPMA (43 CFR 2920). Regarding the ROWs avoidance areas, the RMP directs 

that ROWs and other discretionary land actions will be granted only if no feasible alternative 

routes are available. Any such leases, grants, or permits will include appropriate stipulations to 

protect the area’s special values.

3.15.2.2 Nevada Hunting Statutes and Regulations

Hunting in the state of Nevada is governed by Nevada state law (NRS 503.005–503.660) and is

implemented by NDOW in accordance with regulations NAC 503.141– 503.195.

3.15.3 Affected Environment 

3.15.3.1 Proposed Area

3.15.3.1.1 Recreational Opportunities

The Crescent Dunes are unvegetated sand dunes that lie to the northeast of the Proposed Area. 

BLM manages Crescent Dunes as an SRMA that is approximately 3,000 acres (Figure 3-21). 

According to the RMP, vehicle use within the SRMA is limited to existing roads and trails. Offhighway vehicle use on unvegetated sand areas may be allowed provided that such vehicle use 

is compatible with the areas’ values (BLM 1997). The BLM estimates that average annual 

visitation is 1,200 people (BLM 2010f). The RMP identifies this area as a ROW avoidance area. 

The Proposed Area does not overlap this SRMA ROW avoidance area. The only access to the 

dunes is an unnamed dirt road that diverges from Pole Line Road (Figure 3-21). This unnamed 

dirt road would be the same road that would lead to the Proposed Area. Currently, the Crescent 

Dunes SRMA is a semi-primitive recreational area with no established campground or facilities. 

Lack of any developed facilities may give recreationalists a sense of a remote recreational 

experience meaning that there is a lack of man-made structures and sounds.

Additionally, other recreational vehicle use may take place within the proposed project area. For 

example, TRAC-ON, a Las Vegas based recreation company, provides 3-5 day motorcycle and 

ORV tours of central Nevada; one of the routes passes through the Proposed area. TRAC-ON 

received a BLM Special Recreation Permit in August 2010 for the trail.

3.15.3.1.2 Hunting

The Proposed Area is completely within Hunting Unit 173. According to NDOW, mule deer, 

pronghorn antelope, and bighorn sheep are present within this hunting unit. However, it is 

unlikely that bighorn sheep would be found in the project area because this species prefers 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-109

higher elevation habitats and spend the majority of time at elevations above 11,000 feet 

(NDOW 2010a).

Although NDOW says that mule deer may be found throughout the hunt unit, during hunting 

season NDOW specifies that the highest deer densities can be found above the pinyon-juniper 

habitat at higher elevations (between 8,500 and 10,000 feet) in more open habitat (NDOW 

2010b). Also, according to NDOW, pronghorn sheep are spread out throughout this hunting unit. 

However, during hunting season, NDOW specifies that pronghorn antelope are associated with 

water sources or alfalfa fields (NDOW 2010c). 

3.15.3.1.3 Wilderness Areas and Wilderness Study Areas

No designated Wilderness Areas or Wilderness Study Areas were identified in within the 

proposed area.

3.15.3.2 Alternative Area

The existing condition of the Alternative Area is similar to the Proposed Area, except that the 

Alternative Area overlaps approximately 130 acres of the ROWs avoidance area that is identified 

as the Crescent Dunes SRMA (Figure 3-22).

3.15.3.3 Borrow Pit

No specific recreational opportunities were identified within the borrow pit area.

3.15.3.4 TL and Anaconda Moly Substation

No specific recreational opportunities were identified within the TL and Anaconda Moly 

Substation corridor.

3.15.3.5 CESA

In addition to the recreational opportunities within the detailed study area, BLM and U.S. Forest 

Service lands are public lands that provide a wide variety of dispersed outdoor recreational 

opportunities within the CESA (Figure 3-22). 

USDA Forest Service

The Humboldt-Toiyabe National Forest, managed by the U.S. Forest Service, provides numerous 

recreational opportunities within 25 miles of the project area. No private outdoor recreational 

opportunities were identified within the CESA.

The Humboldt-Toiyabe National Forest is a 2.5-million-acre national forest that is the largest 

national forest outside of Alaska. Recreational opportunities include hiking, camping, hunting, 

wildlife viewing, fishing, snowmobiling, cross-country skiing, and other activities. The southern 

boundary of the Humboldt-Toiyabe National Forest is approximately 19 miles from the Proposed 

Area. Located within the Toiyabe-Humboldt National Forest is Peavine Creek Campground, 

which is approximately 30 miles from the area of analysis. Peavine Creek Campground and the 

southeastern portion of the Humboldt-Toiyabe National Forest are most easily accessible from a 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 3-110

unnamed dirt road that diverts from SH 376. The southern end of the range is most accessible 

by way of Pole Line Road and Peavine Creek Road. The southwestern portion of the Toiyabe 

Range is accessible by an unnamed dirt road that diverges from Pole Line Road.

ROW Avoidance Areas

An additional ROWs avoidance area was identified within the CESA on the western side of the 

Monitor Range (Figure 3-22), approximately 23 miles from the proposed project site. This area is 

identified as a sage-grouse hunting area, and must be avoided seasonally (February 15–May 15).

Hunting

Hunting is permitted on public land (BLM and U.S. Forest Service) within defined hunting 

seasons. NDOW manages hunting by hunt units (i.e., hunting management units throughout 

Nevada). A number of hunting units are within the CESA, including:

• southern portion of Units 161, 162, 171, 172, and 173 

• eastern portion of Unit 205 and 211

• northern portion of Unit 212

• western portion of Unit 251

Species hunted within the CESA of the project area within these hunting units include mule 

deer, desert bighorn sheep, and pronghorn antelope. Within hunt units 161, 162, and 171, the 

Big Smoky Valley was identified as a good location to hunt pronghorn antelope. Unit 173 within 

the Arc Dome Wilderness Area of the Toiyabe Range was identified as good hunting grounds for 

mule deer. The Monte Cristo Range (unit 211) may have good hunting grounds for bighorn 

sheep, although NDOW claims that most animals are located in the more western portions of 

the units. Lastly, mule deer may be found in low densities throughout hunting units 212 and 

251. 

Wilderness Areas and Wilderness Study Areas

No Wilderness Areas or Wilderness Study Areas were identified within the CESA.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-1 

4.0Environmental Consequences

This chapter discusses the environmental consequences that would result from construction and 

operation of the facility and associated components (TL, substation, borrow pit) of the Proposed 

Action, Alternative 1, Alternative 2, and the No Action Alternative. The impact analysis focuses 

on potential direct, indirect, and cumulative effects on each resource area described in 

Chapter 3.0, Affected Environment.

Direct Effects

Direct effects are the impacts caused by the construction and operation of the proposed project 

and alternatives and occur at the same time and place. 

Indirect Effects

Indirect effects occur in the near and distant future and are caused by the proposed project and 

alternatives. The effects can be both short- and long-term effects.

Cumulative Effects

Cumulative effects are the sum of direct and indirect impacts of past, present, and reasonably 

foreseeable future projects in addition to the proposed project or alternatives in the CESA. As 

described in Chapter 3.0, Affected Environment, this area changes depending on the specific 

resource category.

The environmental consequences analysis has been prepared by imposing the Proposed Action, 

Alternative 1, Alternative 2, borrow pit, TL, and substation acreages onto data discussed in 

Chapter 3.0 for the Proposed Area, Alternative Area, borrow pit, TL, and substation. Table 4-1 

lists the acreage used for the evaluations documented in this chapter.

Table 4-1. Estimated area (in acres) for each project component used in the assessment of 

impacts

Component

Right-of-Way (acreage)

Proposed Action Alternative 1 Alternative 2

Temporary Permanent Temporary Permanent Temporary Permanent

Project site 0 1,498 0 1,499 0 1,499

Access road 0 2 0 5 0 2 

Transmission 

line and 

substation

173 173 136 136 127 127

Borrow pit 40 0 40 0 40 0 

Total 213 1,673 176 1,640 167 1,628
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-2 

4.1 Vegetation

4.1.1 Methods 

Biologists analyzed the effects of the Proposed Action, Alternative 1, Alternative 2, borrow pit, 

and the TL and Anaconda-Moly Substation corridor on vegetation resources. To assess the direct 

effects on vegetation resources, biologists used GIS to overlay the footprints of the project 

components on the mapped vegetation communities and land cover types to identify those 

resources that would be directly affected by project construction. The biologists then used GIS 

and the same datasets to calculate the amount of those resources in the CESA to gain insight as 

to the regional abundance of the communities that would be affected. 

As part of the analysis of effects to vegetation, a noxious weed assessment was conducted in 

accordance with BLM Manual 9015. The first step in this analysis was to assign a numerical 

rating for Factor 1, which is the likelihood of noxious weed species spreading to the project area. 

Factor 2, which is the consequence of noxious weed establishment in the project area, was also 

given a numerical rating. These two factors were then multiplied and that value used to identify

a risk rating for the project. The risk rating then identified guidelines for noxious weed control in 

the project area.

4.1.2 Proposed Action 

4.1.2.1 Construction

Direct Effects

Construction activities associated with the Proposed Action would result in direct effects, 

including the removal of topsoil and vegetation within the project areas during grading 

activities. Approximately 1,500 acres (including the access road) would be graded in order to 

construct the project facilities (i.e., heliostats, power block, evaporation ponds, and 

administrative buildings), and a paved access road (Table 4-2). Within these areas, the 

constructed facilities would be present for the life of project, which is anticipated to be 33 years. 

Revegetation and reclamation activities following decommissioning and removal of the project 

would result in eventual reestablishment of vegetative cover (a reclamation plan is being 

developed by BLM). Table 4-2 presents the amount of vegetation communities or land cover 

types that would be replaced with project facilities and the percentage of that vegetation 

community or land cover type affected within the CESA (Figure 4-1).
Crescent Dunes Road

¬«89

Pole Line Road

0 0.5 1

Miles

Legend

Roads Alternative 1

Alternative 2

Proposed Alternative

±

Source: USGS

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\Veg_Proposed_AlternativeArea_Ch4.mxd

Figure 4-1 Vegetation / Land Cover Types

within the Alternatives

Crescent Dunes

Solar Energy Project

!

Project Site

NEVADA

Inter-Mountain Basins Active and Stabilized Dunes

Inter-Mountain Basins Playa

Inter-Mountain Basins Mixed Salt Desert Scrub

Inter-Mountain Basins Semi-Desert Shrub Steppe

Inter-Mountain Basins Greasewood Flat

Barren Lands
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-4 

Table 4-2. Summary of effects to vegetation communities or land cover types for the 

Proposed Action in the project footprint and the CESA 

Southwest Regional Gap Analysis Project 

Vegetation Community or Land Cover Type

Area Replaced 

by Project 

Facilities 

(acres)

Vegetation 

Community/ 

Land Cover in 

Project Area 

(%)

Vegetation 

Community/ 

Land Cover 

Affected 

in the CESA 

(%)

Inter-Mountain Basins Mixed Salt Desert Scrub 1,325 88.4% 1.61% 

Inter-Mountain Basins Semi-Desert Shrub-Steppe 57 3.8% 2.02% 

Inter-Mountain Basins Greasewood Flat 83 5.5% 2.68% 

Barren Lands, Non-specific 35 2.3% 6.39% 

Total 1,500 100.0% 12.70% 

As illustrated in Table 4-2, the majority of the acreage that would be affected for the proposed 

project consists of Inter-Mountain Basins Mixed Salt Desert Scrub (1,325 acres), which is a small 

amount (1.61%) of the available salt desert scrub within the CESA (total area of 81,993 acres). 

This means that the majority of the vegetation that would be affected for the project is not 

unique habitat throughout the CESA. Similarly, only a small amount of Inter-Mountain Basins 

Semi-Desert Shrub Steppe (57 acres), Inter-Mountain Basins Greasewood Flat (83 acres), and 

Barren Lands (35 acres) would be affected compared with the available amount of these 

vegetation communities within the CESA. 

Another direct effect of the proposed project is the potential for the introduction of noxious 

weeds into the project area. Noxious weed species were not found within the Proposed Area

during field surveys, but were present in adjacent areas (i.e., near the borrow pit). The 

establishment of noxious weeds would have an effect on vegetation adjacent to the project 

area. Noxious weed species can displace native vegetation and diminish wildlife habitat quality. 

To determine the potential for noxious weeds in the project area, a Noxious Weed Risk 

Assessment was performed (see Section 4.1.1). Table 4-3 summarizes the results of the Noxious 

Weed Risk Assessment and the value assigned to the two risk factors. 

Table 4-3. BLM noxious weed risk assessment factors and rating risk assessment factors 

worksheet (BLM 1992) 

Factor Rating for the Proposed Action Value

Factor 1 – Likelihood of Noxious 

Weed Species Spreading to Project 

Area

Low: Noxious weed species present in areas adjacent to but 

not within the project area. Project activities can be 

implemented and prevent the spread of noxious weeds into 

the project area.

1 

Factor 2 – Consequence of Noxious 

Weed Establishment in Project Area

Possible adverse effects on site and possible expansion of 

infestation within project area. Cumulative effects on native 

plant community are likely but limited.

5 

Total Risk Rating (Factor 1 Rating Value * Factor 2 Rating Value) 5 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-5 

As presented in Table 4-3, the total risk rating for the proposed project is less than 10, resulting 

in a low risk rating. For this rating, BLM recommends proceeding with the project as planned. 

The Proponent would be required to initiate control treatment on noxious weed populations if 

they become established in the project area.

In addition to noxious weeds, the Proposed Area may be more vulnerable to the introduction of 

invasive species such as cheatgrass, Russian thistle, and halogeton. These species are not 

currently included on the NDA’s Noxious Weed List, but are considered aggressive and can 

potentially dominate areas after introduction. Russian thistle and halogeton were documented 

in the Proposed Area, and project activities could further the establishment of these species. 

Cheatgrass was not documented in the Proposed Area, but is widespread throughout the Great 

Basin and could be introduced because of increased traffic in the area. 

Indirect Effects

Vegetation in the project area will be removed during construction activities; therefore, no 

indirect effects to vegetation are associated with construction of the Proposed Action.

4.1.2.2 Operation

Direct Effects

Vegetation within the project area would be removed during construction activities, so no direct 

effects to vegetation are likely to occur during operation of the Proposed Action. Ongoing 

maintenance activities within the heliostat field, particularly the use of water for cleaning 

mirrors, may increase the potential for the establishment of noxious and invasive weed species 

within the developed areas, which then could spread to adjacent areas. Weed control measures 

within the project area would minimize the likelihood of this occurring.

Indirect Effects

Vegetation in the project area would be removed during construction activities, so no indirect 

effects to vegetation are likely to occur with operation of the Proposed Action. 

4.1.3 Alternative 1

4.1.3.1 Construction

Direct Effects

The direct effects for Alternative 1 are similar to those for the Proposed Action, only differing in 

the acreage of vegetation communities or land cover types that would be affected (1,504 acres

including access road). Table 4-4 presents the acreage of each of the vegetation communities or 

land cover types that would be affected during grading activities (Figure 4-1).
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-6 

Table 4-4. Summary of effects to vegetation communities or land cover type for Alternative 1 

in the project footprint and the CESA

Southwest Regional Gap Analysis Project

Vegetation Community or Land Cover Type

Area Replaced 

by Project 

Facilities 

(acres)

Vegetation 

Community/ 

Land Cover in 

Project Area 

(%)

Vegetation 

Community/ 

Land Cover 

Affected 

in the CESA 

(%)

Inter-Mountain Basins Mixed Salt Desert Scrub 1,473 98.0% 1.77% 

Inter-Mountain Basins Semi-Desert Shrub-Steppe 3 0.2% 0.11% 

Inter-Mountain Basins Active and Stabilized Dune 8 0.5% 16.23% 

Barren Lands, Non-specific 20 1.3% 3.76% 

Total 1,503 100.0% 21.87% 

As presented in Table 4-4, most of the acreage that would be affected for Alternative 1 consists 

of Inter-Mountain Basins Mixed Salt Desert Scrub (1,473 acres), which is a small amount (1.77%) 

of the available salt desert scrub within the CESA (81,993 acres). This means that the majority of 

the vegetation that would be affected for the project is not unique habitat throughout the CESA. 

Similarly, only a small amount of Inter-Mountain Basins Semi-Desert Shrub Steppe (3 acres) and 

Barren Lands (20 acres) would be affected compared with the available amount of these 

vegetation communities within the CESA. However, approximately 8 acres of Inter-Mountain 

Basins Active and Stabilized Dunes would be affected by the proposed project, and this is a 

relatively high percentage (16.23%) of this unique land cover type available throughout the 

CESA. 

No noxious weeds were observed within Alternative 1; therefore, the noxious weed assessment 

for Alternative 1 is the same as the Proposed Action (see Table 4-3). The total risk rating for 

Alternative 1 is less than 10, resulting in a low risk rating. For this rating, the BLM recommends 

proceeding with the project as planned. The Proponent would be required to initiate control 

treatment on noxious weed populations if they become established in the project area. 

Indirect Effects

Vegetation in the project area would be removed during construction activities; therefore, no 

indirect effects to vegetation are associated with construction of the Alternative 1.

4.1.3.2 Operation

Direct Effects

Vegetation within the project area would be removed during construction activities, so no direct 

effects to vegetation are likely to occur during operation of the Alternative 1. Ongoing 

maintenance activities within the heliostat field, particularly the use of water for cleaning 

mirrors, may increase the potential for the establishment of noxious and invasive weed species 

within the developed areas, which then could spread to adjacent areas. Weed control measures 

within the project area would minimize the likelihood of this occurring.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-7 

Indirect Effects

Vegetation in the project area would be removed during construction activities, so no indirect 

effects to vegetation are likely to occur with operation of Alternative 1. 

4.1.4 Alternative 2

4.1.4.1 Construction

Direct Effects

The direct effects for Alternative 2 are similar to those for the Proposed Action, only differing in 

the acreage of vegetation communities or land cover types that will be affected (1,401 acres

including access road). Table 4-5 presents the acreage of the four vegetation communities or 

land cover types that would be affected during grading activities (Figure 4-1).

Table 4-5. Summary of effects to vegetation communities or land cover type for Alternative 2

in the project footprint and the CESA

Southwest Regional Gap Analysis Project

Vegetation Community or Land Cover Type

Area Replaced 

by Project 

Facilities 

(acres)

Vegetation 

Community/ 

Land Cover in 

Project Area 

(%)

Vegetation 

Community/ 

Land Cover 

Affected 

in the CESA 

(%)

Inter-Mountain Basins Mixed Salt Desert Scrub 1,491 99.3% 1.80%

Inter-Mountain Basins Semi-Desert Shrub-Steppe 2 0.1% 0.08%

Inter-mountain Basins Playa 2 0.1% 1.55%

Barren Lands, Non-specific 6 0.4% 1.21%

Total 1,501 100.0% 4.64%

As shown in Table 4-5, most of the acreage that would be affected for Alternative 2 consists of 

Inter-Mountain Basins Mixed Salt Desert Scrub (1,491 acres), which is a small amount (1.80%) of 

the available salt desert scrub within the CESA (81,993 acres). This means that the majority of 

the vegetation that would be affected for the project is not unique habitat throughout the CESA. 

Similarly, only a small amount of Inter-Mountain Basins Semi-Desert Shrub Steppe (2 acres), 

Inter-Mountain Basins Playa (2 acres), and Barren Lands (6 acres) would be affected compared 

with the available amount of these vegetation communities within the CESA.

No noxious weeds were observed within Alternative 2; therefore, the noxious weed assessment 

for Alternative 2 is the same as for the Proposed Action (see Table 4-3). The total risk rating for 

Alternative 2 is less than 10, resulting in a low risk rating. For this rating, the BLM recommends 

proceeding with the project as planned. The Proponent would be required to initiate control 

treatment on noxious weed populations if they become established in the project area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-8 

Indirect Effects

Vegetation in the project area would be removed during construction activities; therefore, no 

indirect effects to vegetation are associated with construction of Alternative 2.

4.1.4.2 Operation

Direct Effects

Vegetation within the project area would be removed during construction activities, so no direct 

effects to vegetation are likely to occur during operation of Alternative 2. Ongoing maintenance 

activities within the heliostat field, particularly the use of water for cleaning mirrors, may 

increase the potential for the establishment of noxious and invasive weed species within the 

developed areas, which then could spread to adjacent areas. Weed control measures within the 

project area would minimize the likelihood of this occurring.

Indirect Effects

Vegetation in the project area would be removed during construction activities, so no indirect 

effects to vegetation are likely to occur with operation of Alternative 2. 

4.1.5 Borrow Pit

The following subsections summarize the impacts of the construction and operation of the 

borrow pit together because the borrow pit would be open only until completion of 

construction of the generation facility. 

Direct Effects

Expansion of the borrow pit would result in the removal of vegetation and topsoil, as well as the 

underlying materials that would be used for construction activities. Approximately 40 acres of 

vegetation would be removed for the expansion of the pit, affecting only the Inter-mountain 

Basins Mixed Salt Desert Scrub vegetation communities (Table 4-6). All construction activities 

are anticipated to remain within the area proposed for the pit, therefore, no temporary direct 

effects are likely to occur.

Table 4-6. Summary of effects to vegetation communities or land cover type for the borrow 

pit

Southwest Regional Gap Analysis Project

Vegetation Community or Land Cover Type

Area Replaced 

by Project 

Facilities 

(acres)

Vegetation 

Community/ 

Land Cover in 

Project Area 

(%)

Vegetation 

Community/ 

Land Cover 

Affected 

in the CESA 

(%)

Inter-Mountain Basins Mixed Salt Desert Scrub 40 100.0% 0.05%

Total 40 100.0% 0.05%
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-9 

As mentioned under the Proposed Action, noxious weeds were found adjacent to the borrow 

pit. Although the BLM risk rating for noxious weeds in the area is low (see Table 4-3), 

construction activities particularly near the borrow pit may facilitate the spread of noxious 

weeds throughout the project area. Three tamarisk plants and tall whitetop were found in a 

nearby wash. However, because these species are dependent on moist environments like those 

associated with the wash, it is unlikely that these species would spread to other parts of the 

project area. The majority of the project area is a drier environment that would not support 

such species.

Indirect Effects

Vegetation in the project would be removed during construction activities; therefore, no 

indirect effects to vegetation are likely to occur with construction of the borrow pit.

4.1.6 TL and Anaconda-Moly Substation

4.1.6.1 Construction

Direct Effects

Construction activities associated with the TL would result in both temporary and permanent 

direct effects on vegetation. Direct effects would be the removal of approximately 173 acres of 

vegetation to install TL poles and associated spur roads (i.e., construction and maintenance 

access roads that branch from the existing Pole Line Road and the other access roads). The short 

spur road and an area at the base of each tower would be graded to remove vegetation, as well 

as topsoil for the base of the towers. These facilities and the associated impacts would remain 

for the life of the project. In addition to these effects, temporary disturbances are likely to occur 

with construction and installation of the TL. Although the TL corridor would not be graded, 

trucks and equipment may drive over and crush existing vegetation to allow for tensioning of 

the lines and other activities. This temporary disturbance area is expected to be minimal 

because the TL corridor is directly adjacent to the existing Pole Line Road until it converges with 

the existing Anaconda-Millers TL, where an existing two-track dirt road is present. By avoiding 

the grading and vegetation removal in these temporary disturbance areas, vegetation may 

recover rapidly. Although efforts would be made to avoid it, some construction activities would 

require vegetation removal for safety or quality reasons. In those cases, vegetation would be cut 

at the ground surface, allowing the plants to sprout from the remaining crown. 

The TL and Anaconda-Moly Substation may be more vulnerable to the introduction of invasive 

species such as cheatgrass, Russian thistle, and halogeton. Seeds of these species are easily 

spread because their seeds can get caught in vehicle tires and, if deposited in disturbed areas, 

could proliferate. Cheatgrass was not documented in the proposed corridor, but is widespread 

throughout the Great Basin and could be introduced because of increased traffic and 

disturbances during construction. Washing vehicles prior to arrival on site can mitigate this 

potential effect. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-10

Indirect Effects

Where needed, vegetation would be removed for construction of the TL and substation; 

therefore, no indirect effects to vegetation are likely to occur with construction of the TL and 

Anaconda-Moly Substation.

4.1.6.2 Operation

Direct Effects

Generally, direct effects on vegetation from the normal operation and maintenance of the TL 

and substation are anticipated to be minimal. Maintenance of the access spur roads and base of 

transmission towers may include periodic removal of vegetation to minimize fire risks; however, 

those activities would be minimal.

Indirect Effects

Vegetation within the project area would be removed during construction activities, so no direct 

effects to vegetation are likely to occur during operation of the TL or the Anaconda-Moly 

Substation. 

4.1.7 No Action Alternative

Under the No Action Alternative, no project-related impacts to existing vegetation communities 

or land cover types would occur. 

4.1.8 Summary of Impacts 

Direct impacts would include the removal of vegetation within the project area as the result of 

grading and construction activities. Indirectly, the project may increase the likelihood for the 

introduction and proliferation of invasive weed species in the surrounding area; however, there 

is a low risk for the introduction of noxious weeds into the surrounding area. 

4.1.9 Mitigation

Between 1,628 and 1,673 acres of natural vegetation would be removed as a result of the 

various components of this project. Cactus and yucca would be salvaged in coordination with 

BLM. In coordination with BLM, the Proponent is developing a reclamation plan to be 

implemented at the termination of the lease. 

The Proponent has developed a Preliminary Weed Risk Assessment and will develop Weed 

Management Plan (WMP) for the project. The WMP will prescribe management actions for 

monitoring and eradicating specified species by BLM-approved methods. The WMP also will 

describe applicable regulations for the use of herbicides on federally managed lands in Nevada, 

and provide the basis for proper management and use of herbicides in the project area. A 

preemergent herbicide would be applied in the spring, and spot foliar applications would be 

used throughout the year to maintain the area free of vegetation. Typically, operations and 

maintenance requirements for native landscapes are low once established. The WMP will 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-11

include weeding, annual pruning, and soil monitoring, if necessary. Weeding should occur 

frequently, typically weekly, during the initial growth period to ensure that invasive plants do 

not mature and set seed. Weeding activities would follow the approved WMP. Once the native 

plant species are established, weeding frequency would drop to less frequent intervals.

4.2 Wildlife

4.2.1 Methods 

Biologists analyzed the effects of the Proposed Action, Alternative 1, Alternative 2, borrow pit, 

and the TL and Anaconda-Moly Substation corridor on wildlife resources. Direct impacts to 

wildlife were assessed by taking into consideration how construction and operation of the 

facilities may directly kill, injure, harm, or harass wildlife, or affect wildlife behavior patterns. To 

assess the indirect effects on wildlife resources, biologists identified the type and quantity of 

terrestrial wildlife habitat affected as a result of project levels of surface disturbance in relation 

to the habitat available throughout the CESA (see Section 4.1). 

4.2.2 Proposed Action 

4.2.2.1 Construction

Direct Effects

Direct effects to wildlife may include injury or mortality during initial grading activities. Some 

wildlife such as game and bird species that are particularly mobile may be able to avoid injury or 

mortality by leaving the area. However, some wildlife such as smaller mammals and lizards, 

especially nocturnal species or species that utilize burrows, may be injured or killed during 

grading or clearing activities. 

Increased traffic and newly established access roads in the area may result in an increase of 

vehicle-wildlife collisions, resulting in animal injury or death. This may be of particular concern 

for larger mammals (such as coyotes and kit foxes), game animals (such as deer and pronghorn), 

and smaller species that utilize roads as a heat source (such as snakes and lizards). The effect on 

birds is anticipated to be minimal given that birds are generally able to avoid vehicles traveling 

on roads. 

Although temporary in nature, direct effects may occur as a result of increased noise levels 

associated with construction activities. Noise may cause wildlife to avoid the area, resulting in a 

disruption of normal behavioral patterns. 

The proposed project also may directly affect wildlife species by removing approximately 

1,500 acres of habitat. However, most of this habitat consists of Inter-mountain Basins Mixed 

Salt Desert Scrub (see Section 4.1). This is a relatively small proportion (less than 2 percent) of 

the available salt desert scrub habitat available throughout the CESA. The Proposed Action 

would not remove any specialized or unique habitat throughout the region. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-12

Indirect Effects

Wildlife may be indirectly affected because of increased human activity in the area. This 

increased activity may cause wildlife to avoid the adjacent area, possibly affecting migration and 

other activities. 

4.2.2.2 Operation 

Direct Effects

One of the major direct effects to wildlife associated with operation of the Proposed Action 

would be the effect of the evaporation ponds on wildlife, particularly birds. Since most birds in 

the project area are considered migratory birds and effects to migratory birds and year-round 

resident birds are the same, evaporation pond effects on birds are discussed in Section 4.4.

The evaporation ponds could potentially attract other wildlife to the project site, although larger 

wildlife would be excluded from the area by a fence that surrounds the facility. The water in the 

evaporation ponds would be saturated with salt (making a brine solution). Wildlife that could 

breach the fence and access the ponds (such as mice, bats, and reptiles) may die or become ill 

by ingesting toxic levels of salt. 

Indirect Effects

Wildlife may be indirectly affected because of increased human activity in the area. This 

increased activity may cause wildlife to avoid the adjacent area, possibly affecting migration and 

other activities. 

4.2.3 Alternative 1 

4.2.3.1 Construction

Direct Effects

Direct effects associated with Alternative 1 are similar to those for the Proposed Action, except 

that Alternative 1 would remove approximately 8 acres of Inter-Mountain Basins Active and 

Stabilized Dunes, which is a relatively large percentage (16.23 percent) of this habitat type 

available throughout the CESA (see Section 4.1). Removal of this type of habitat may affect 

species that specifically depend on this habitat, such as kangaroo rats and mice. Kangaroo mice 

are considered a special status species and are addressed in Section 4.4.

Indirect Effects

Indirect effects associated with the construction of Alternative 1 would be the same as those 

associated with the Proposed Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-13

4.2.3.2 Operation

Direct Effects 

Direct effects associated with the operation of Alternative 1 would be the same as those 

associated with the Proposed Action.

Indirect Effects

Indirect effects associated with the operation of Alternative 1 would be the same as those 

associated with the Proposed Action.

4.2.4 Alternative 2 

4.2.4.1 Construction

Direct Effects

Direct effects on wildlife associated with the construction of Alternative 2 would be similar to 

those of the Proposed Action. Alternative 2 may indirectly affect wildlife species by removing 

approximately 1,501 acres of habitat. However, most of this habitat consists of Inter-mountain 

Basins Mixed Salt Desert Scrub (see Section 4.1). This is a relatively small proportion (less than 

2 percent) of the available salt desert scrub habitat available throughout the CESA. Alternative 2 

would not remove any specialized or unique habitat throughout the region.

Indirect Effects

Indirect effects associated with the construction of Alternative 2 would be the same as those 

associated with the Proposed Action.

4.2.4.2 Operation

Direct Effects 

Direct effects on wildlife associated with the operation of Alternative 2 would be the same as 

those associated with the Proposed Action.

Indirect Effects

Indirect effects associated with the operation of Alternative 2 would be the same as those 

associated with the Proposed Action.

4.2.5 Borrow Pit

The following subsections summarize the impacts of the construction and operation of the 

borrow pit together because the borrow pit would be open only until completion of 

construction of the generation facility. 

Direct Effects

Construction of the borrow pit may directly affect wildlife species by removing approximately 

40 acres of habitat. However, all of this habitat consists of Inter-mountain Basins Mixed Salt 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-14

Desert Scrub (see Section 4.1). The vegetation communities affected would be relatively small 

proportions (less than 1 percent) of the available habitat throughout the CESA. Construction of 

the borrow pit would not remove any specialized or unique habitat throughout the region. 

Indirect Effects

Indirect effects associated with the construction of the borrow pit would be the same as those 

associated with the Proposed Action.

4.2.6 TL and Anaconda-Moly Substation Corridor 

4.2.6.1 Construction

Direct Effects

Direct effects on wildlife associated with construction of the TL and Anaconda-Moly Substation 

corridor would be similar to those of the Proposed Action; between approximately 127 and 

173 acres (depending on the alternative chosen) of wildlife habitat would be removed to install 

TL poles and spur roads. The new TL would be located in an existing utility corridor, paralleling 

an existing TL (Anaconda-Millers), along Pole Line Road. The existing utility corridor includes an 

existing maintenance road (2-track dirt) for the Anaconda-Millers TL. Because the proposed TL 

would follow existing roads (ROW), no new barriers would impede wildlife movement 

throughout the lower Big Smoky Valley; therefore, impacts to wildlife would be minimal.

Indirect Effects

Indirect effects associated with the construction of the TL and Anaconda-Moly Substation would 

be the same as those associated with the Proposed Action.

4.2.6.2 Operation

Direct Impacts 

The major direct effect on wildlife associated with the TL and Anaconda-Moly Substation 

corridor is the potential effect of power lines on birds. Since the effects to year-round resident 

birds would be the same as the effects to migratory birds, TL effects are discussed in Section 4.4. 

Indirect Effects

Indirect effects associated with the operation of the TL and Anaconda-Moly Substation would be

the same as those associated with the Proposed Action.

4.2.7 No Action Alternative

Under the No Action Alternative, no project-related impacts to wildlife would occur. 

4.2.8 Summary of Impacts 

Impacts to wildlife are likely to include the loss of habitat attributable to conversion to the 

generation facility, excavation of aggregate in the borrow pit, and construction of the TL. During 

these activities, wildlife that is unable to flee the area may be injured or killed by heavy 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-15

equipment. Additional injuries or deaths may occur as a result of vehicle collisions involving 

construction and operation vehicles, as well as those vehicles being driven by employees 

commuting to and from their residences and the project site. It is possible that some wildlife 

may be affected by the brine formed in the on-site evaporation ponds.

4.2.9 Mitigation

In addition to fencing that would exclude larger wildlife, the evaporations ponds would covered 

with a porous screen, which would allow evaporation but exclude wildlife (i.e. birds, mice and 

bats). Additional mitigation is described in Section 4.5.11. Mitigation would be further

developed in coordination with NDOW as part of the Industrial Artificial Pond Permit.

4.3 Special Status Plant Species

4.3.1 Methods 

Biologists analyzed the effects of the Proposed Action, Alternative 1, Alternative 2, borrow pit, 

and TL and Anaconda-Moly Substation corridor on special status plant species. To assess the 

direct effects on special status plant species, biologists used GIS to overlay the footprints of the 

project components on the mapped special status plant species to identify those resources that 

would be directly affected by project construction. Because of the lack of data on regional 

distribution of this species, the biologists then used GIS and the same datasets to calculate the 

percentage of special status plant species potential habitat that would be affected throughout 

the CESA. Figure 4-2 shows the Nevada oryctes habitat that would be affected by the Proposed 

Action, Alternative 1, and Alternative 2.

4.3.2 Proposed Action Alternative 

4.3.2.1 Construction

Direct Effects

Construction activities associated with the Proposed Action would directly affect Nevada oryctes 

by removing plants and suitable habitat within the project areas during grading activities. 

Approximately 1,374 acres of suitable habitat for Nevada oryctes would be graded in order to 

construct the project facilities (i.e., heliostats, power block, evaporation ponds, and 

administrative buildings) and a paved access road. This is approximately 5.3 percent of the 

available suitable habitat identified within the CESA (25,880 acres).
Crescent Dunes Road

¬«89 Pole Line Road

0 0.51

Miles

 Legend

Proposed Alternative

Alternative 2

Alternative 1

Road

±

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_3\Nev_Oryc_Habit.mxd

Figure 4-2 Nevada

Oryctes Habitat Affected

by the Alternatives

Crescent Dunes

Solar Energy Project

!

Project Site

NEVADA

Potential Habitat

Suitable Habitat

Vegetation Type

Barren Land

Greasewood

Lemon Scurfpea

Nevada Dalea
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-17

Indirect Effects

Nevada oryctes and associated habitat within the project area would be removed during 

construction activities, and all construction activities would stay within the disturbed area; 

therefore, no indirect effects on Nevada oryctes are associated with construction of the 

Proposed Action. 

4.3.2.2 Operation

Direct Effects

Nevada oryctes and associated habitat within the project area would be removed during 

construction activities, so no direct effects on Nevada oryctes are likely to occur during 

operation of the Proposed Action. 

Indirect Effects

Nevada oryctes and associated habitat in the project area would be removed during 

construction activities, so no indirect effects to this species are likely to occur with operation of 

the Proposed Action.

4.3.3 Alternative 1

4.3.3.1 Construction

Direct Effects

Construction activities associated with Alternative 1 would directly affect Nevada oryctes by 

removing plants and suitable habitat within the project area during grading activities. 

Approximately 803 acres of suitable habitat for oryctes would be graded in order to construct 

the project facilities (i.e., heliostats, power block, evaporation ponds, and administrative 

buildings) and a paved access road (Figure 4-2). This is approximately 3.1 percent of the 

available suitable habitat identified within the CESA (25,880 acres).

Indirect Effects

Nevada oryctes and associated habitat within the project area would be removed during 

construction activities; therefore, no indirect effects to vegetation would be associated with 

construction of Alternative 1.

4.3.3.2 Operation

Direct Effects

Nevada oryctes and associated habitat within the project area would be removed during 

construction activities, so no direct effects to Nevada oryctes are anticipated during operation of 

the Alternative 1. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-18

Indirect Effects

Nevada oryctes and associated habitat in the project area would be removed during 

construction activities, so no indirect effects to vegetation are likely to occur with operation of 

Alternative 1. 

4.3.4 Alternative 2

4.3.4.1 Construction

Direct Effects

Construction activities associated with Alternative 2 would directly affect Nevada oryctes by 

removing plants and suitable habitat within the project areas during grading activities. 

Approximately 434 acres of suitable habitat for oryctes would be graded in order to construct 

the project facilities (i.e., heliostats, power block, evaporation ponds, and administrative 

buildings) and a paved access road (Figure 4-2). This is approximately 1.7 percent of the 

available suitable habitat identified within the CESA (25,880 acres).

Indirect Effects

Nevada oryctes and associated habitat within the project area would be removed during 

construction activities; therefore, no indirect effects to vegetation are associated with 

construction of Alternative 2.

4.3.4.2 Operation

Direct Effects

Nevada oryctes and associated habitat within the project area would be removed during 

construction activities, so no direct effects to Nevada oryctes are likely to occur during 

operation of Alternative 2. 

Indirect Effects

Nevada oryctes and associated habitat in the project area would be removed during 

construction activities, so no indirect effects to vegetation are likely to occur with operation of 

Alternative 2. 

4.3.5 Borrow Pit

The following subsections summarize the impacts of the construction and operation of the 

borrow pit together because the borrow pit would be open only until completion of 

construction of the generation facility. 

Direct Effects

No special status plant species or Nevada oryctes habitat were found in the borrow pit; 

therefore, no direct effects to special status plants species are associated with construction of 

the borrow pit.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-19

Indirect Effects

No special status plant species or Nevada oryctes habitat were found in the borrow pit; 

therefore, no indirect effects to special status plants species are associated with construction of 

the borrow pit. 

4.3.6 TL and Anaconda-Moly Substation Corridor 

4.3.6.1 Construction

Direct Effects

In 2009, one Nevada oryctes plant was found within the TL corridor, and the northern portion of 

the corridor was classified as suitable habitat. However, only a relatively small area within the TL

corridor would be affected by grading and excavation activities needed to install TL poles. 

Indirect Effects

Construction activities within the TL corridor may increase the spread of nonnative invasive 

plant species throughout the area (see Section 4.1). Introduction of nonnative invasive plant 

species could potentially displace Nevada oryctes or limit its reproduction success because 

invasive species can often dominate areas, out-competing native plants. Mitigation measures 

would be taken to limit the spread of invasive species throughout the TL area (see Section 4.1).

4.3.6.2 Operation

Direct Effects

No direct effects to special status plant species are associated with operation of the TL and 

Anaconda-Moly Substation corridor.

Indirect Effects

No indirect effects to special status plant species are associated with operation of the TL and 

Anaconda-Moly Substation corridor.

4.3.7 No Action Alternative

Under the No Action Alternative, no project-related impacts to special status plant species

would occur. 

4.3.8 Summary of Impacts 

Direct impacts to Nevada oryctes would include removing plants and suitable habitat areas 

during grading activities. Indirect impacts may include the introduction on nonnative invasive 

species into adjacent oryctes habitat, which may potentially affect habitat quality and oryctes

reproduction success. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-20

4.3.9 Mitigation

BLM, NDOW, and TSE is in the process of developing a mitigation plan for impacts to wildlife, 

the final plan will be included as part of the Final EIS. 

4.4 Special Status Wildlife Species

4.4.1 Methods 

Biologists analyzed the effects of the Proposed Action, Alternative 1, Alternative 2, borrow pit, 

and TL and Anaconda-Moly Substation corridor on special status wildlife species. Direct impacts 

to special status wildlife were assessed by taking into consideration how construction and 

operation of the facilities may directly injure, harm, or harass special status wildlife species, or 

affect their behavior patterns. To assess the indirect effects on special status species, biologists 

identified the type and quantity of terrestrial wildlife habitat affected as a result of project levels 

of surface disturbance in relation to the habitat available throughout the CESA (see Section 4.1). 

4.4.2 Proposed Action 

4.4.2.1 Construction

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects to pale kangaroo mice would include injury or mortality during initial grading 

activities associated with construction of the facility and roadway, and the resulting loss of 

habitat. Mice occupying approximately 1,466 acres of habitat would be directly affected 

(Figure 4-3). This is approximately 5 percent of the available potential habitat identified within 

the CESA (29,343 acres).

Direct effects to a wide variety of special status bat species would include the removal of 

approximately 1,673 acres of potential foraging habitat. The Proposed Action would not restrict 

bat migration throughout the lower Big Smoky Valley.

Golden Eagles and Migratory Birds

Golden eagles and migratory birds would be directly affected because the project would remove 

approximately 1,500 acres of potential foraging habitat for golden eagles and nesting and 

foraging habitat for migratory birds. However, most of this habitat consists of Inter-mountain 

Basins Mixed Salt Desert Scrub, and this represents a relatively small proportion (less than 

2 percent) of the available salt desert scrub habitat available throughout the CESA and a small 

area in relation to the lower Big Smoky Valley. The Proposed Action would not restrict bird 

migration throughout the lower Big Smoky Valley, but may destroy a small proportion of the 

available migratory bird habitat and golden eagle foraging habitat.
Crescent Dunes Road

¬«89

Pole Line Road

0 0.5 1

Miles

 Legend

Proposed Alternative

Alternative 2

Alternative 1

Road

±

Source: Solar Reserve 2010.

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\Pale_Kang_Mouse_Ch4.mxd

Figure 4-3 Pale Kangaroo Mouse Habitat

and Project Alternatives

Crescent Dunes

Solar Energy Project

!

Project Site

NEVADA

Habitat Suitability

Not Suitable

Potential

Suitable

Vegetation Type

Barren Land

Greasewood

Lemon Scurfpea

Nevada Dalea
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-22

Because most birds are highly mobile, and initial construction activities would not occur during 

nesting periods, it is unlikely that grading activities associated with project construction would 

result in bird injury or death because most birds can flee the area. However, a few species such 

as burrowing owls may be more susceptible to injury or death during grading activities because 

they may hide in their burrows and not be able to flee in time. Grading activities could destroy 

nests; however, disturbances to nesting birds would be avoided by implementing mitigation 

measures. Mitigation would include restricting grading activities during migratory bird breeding 

season (April 1 – August 31) or having a monitoring biologist on-site during grading activities so 

that nests can be identified and avoided. Increased noise levels during construction may cause 

birds to avoid the area temporarily, possibly disrupting normal behavior patterns. 

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no direct effects to special status reptile species are likely to occur with construction 

of the project.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No direct effects of the Proposed Action on special status insects are likely to occur because 

these species are associated with the Crescent Dunes, and the dunes do not extend into the 

Proposed Area.

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

No indirect effects on the pale kangaroo mouse or special status bat species from the 

construction of this project are likely to occur. 

Golden Eagles and Migratory Birds

No indirect effects on golden eagles or migratory birds from the construction of the proposed 

project are likely to occur. 

Reptiles

No special status reptiles were observed or have the potential to occur within the Proposed 

Area; therefore, no direct effects to special status reptiles are associated with construction of 

the Proposed Action.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No indirect effects of the Proposed Action on these special status insects are likely to occur 

because these species are associated with the Crescent Dunes, and the dunes do not extend 

into the Proposed Area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-23

4.4.2.2 Operation

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects to pale kangaroo mice and bats may result from the operation of the facility’s 

evaporation ponds. Mice and bats may be attracted to the water in the ponds (and would not be 

excluded by the fence around the facilities). The water in the evaporation ponds would be 

saturated with salt (making a brine solution). If mice or bats ingest water from the pond, they 

may become ill or die from sodium toxicity. Mice and bats could also fall into the ponds and 

drown if no escape route is available.

Golden Eagles and Migratory Birds

Direct effects may include bird injury or mortality during operation because of the presence of 

evaporation ponds associated with the facility, the presence of additional structures in the area, 

and the presence of the high-temperature central receiver. The evaporation ponds may attract 

birds to the project site. The water in the evaporation ponds would be saturated with salt 

(making a brine solution). Birds using the evaporation pond could ingest the brine and die from 

sodium toxicity if a freshwater source is not available nearby (USFWS 2009b). Additionally, birds 

that utilize the water may experience a build-up of sodium crystals in their feathers, resulting in 

a reduction of the feathers’ thermoregulatory properties, causing the birds to die of 

hypothermia during cold weather (USFWS 2009b). A porous screen would cover the evaporation 

ponds this minimizing/eliminating these effects on golden eagles and migratory birds.

A potential direct effect of the project on golden eagles and other migratory birds is death or 

injury resulting from collisions with structures associated with the project. A variety of species of 

birds have been documented colliding with buildings and other structures, resulting in death or 

injury. Such collisions probably occur because of the reflection of the sky in the structure. A 

study on a project similar to this proposed project found that a variety of migratory birds were 

injured or killed after colliding with various components of the facility (McCrary et al. 1986). 

However, the study found that only a small proportion (less than 1 percent) of the birds in the 

area were affected. 

Another potential direct effect on golden eagles and other migratory birds is injury or death 

associated with the heat generated by the central receiver/tower component of the proposed 

project. Reflected solar energy would be focused on the central receiver/tower, causing the 

surface temperature of the receiver to exceed 1,000 degrees Fahrenheit during the day. In the 

40-week study at the previously mentioned project site with the central receiver, several birds 

were found dead at the base of the central tower; they had been severely singed or burned 

(McCrary et al. 1986). The dead birds were small, fast-flying species (swallows), and the authors 

speculated that the birds may have been unable to alter course at high speeds to avoid the heat 

in time to prevent injury. Based on these findings, it is possible that other migratory birds that 

fly at elevations similar to the receiver (600 feet), and those attracted to the tower as a 

potential perch or roost site, including golden eagles, may be at risk of death or injury. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-24

Reptiles

No special status reptiles were observed or have the potential to occur within the Proposed 

Area; therefore, no direct effects to special status reptile species are associated with operation 

of the project.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

As stated previously, it is unlikely that special status insects would be found in the Proposed 

Area; therefore, no direct effects to special status insects are likely to occur from operation of 

the Proposed Action.

Indirect Effects

Mammals: Pale Kangaroo Mouse and Bats

Pale kangaroo mouse habitat and bat foraging habitat within the project area would be 

removed during construction activities. No indirect effects to these species are likely to occur 

during operation of the facility. 

Additionally, project structures may provide roosting opportunities for raptors, owls, and other 

predatory birds that prey on sensitive species such as the pale kangaroo mouse and various bat 

species, thus increasing predation pressure on these sensitive species.

Golden Eagles and Migratory Birds

Migratory bird habitat and golden eagle foraging habitat within the project area would be 

removed during construction activities. No indirect effects to these species are likely to occur 

during operation of the facility. 

Reptiles

No special status reptiles were observed or have the potential to occur within the project area. 

No indirect effects to special status reptile species are associated with operation of the 

Proposed Action.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

As stated previously, it is unlikely that special status insects would be found in the Proposed 

Area. No indirect effects to special status insects are likely to result from operation of the 

Proposed Action.

4.4.3 Alternative 1

4.4.3.1 Construction

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects on special status mammal species associated with the construction of 

Alternative 1 would be similar to those associated with the Proposed Action, including the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-25

potential injury and death of mice in the area and the loss of habitat associated with 

construction of the facility. However, Alternative 1 would remove 1,191 acres of pale kangaroo 

mouse habitat. Additionally, Alternative 1 would remove 306 acres of potential habitat, which is 

greasewood dominated mixed salt desert scrub with sandy soil or “mini” dune features. This is 

approximately 4.1 percent of the available potential habitat identified within the CESA 

(29,343 acres).

Direct effects to a wide variety of special status bat species would include the removal of 

approximately 1,640 acres of potential foraging habitat. Alternative 1 would not restrict bat 

migration throughout the lower Big Smoky Valley.

Golden Eagles and Migratory Birds

Direct effects on golden eagles and migratory birds associated with construction of Alternative 1 

would be the same as those associated with the Proposed Action.

Reptiles

No special status reptiles were observed or have the potential to occur within the Proposed 

Area; therefore, no indirect effects to special status reptile species are associated with 

operation of the Proposed Action.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Alternative 1 would have the greatest potential effects on special status insect species 

compared with the other alternatives because this location would grade approximately 8 acres 

of Inter-Mountain Basins Active and Stabilized Dunes Habitat (see Section 4.1). This is the 

specific habitat on which these species depend. Direct effects to special status insect species 

may include injury or mortality during initial grading activities associated with construction of 

the facility and roadway. Insects may be able to avoid injury or death by flying away from 

grading activities.

Indirect Effects 

Mammals: Pale Kangaroo Mice and Bats

Indirect effects to special status mammal species associated with the construction of 

Alternative 1 would be the same as those associated with the Proposed Action. 

Golden Eagles and Migratory Birds

Indirect effects to golden eagles and migratory birds associated with the construction of 

Alternative 1 would be the same as those associated with the Proposed Action.

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no indirect effects to special status reptile species are likely to occur with operation 

of Alternative 1.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-26

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Indirect effects to special status insect species would include habitat loss (see Section 4.1). 

Alternative 1 would remove 8 acres of the Crescent Sand Dunes (also known as Inter-mountain 

Basins Active and Stabilized Dunes), and this is a relatively high proportion (16.23 percent) of 

sand dune habitat available within the CESA. 

4.4.3.2 Operation

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects to special status mammal species associated with operation of Alternative 1 would 

be the same as those associated with the Proposed Action. 

Golden Eagles and Migratory Birds

Direct effects to golden eagles and migratory birds associated with operation of Alternative 1 

would be the same as those associated with the Proposed Action. 

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no direct effects to special status reptile species are associated with operation of 

Alternative 1.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Special status insect habitat would be removed during grading activities associated with the 

construction of the facility and roadway; therefore, no direct effects to special status insects 

would be associated with the operation of Alternative 1.

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

Indirect effects to special status mammals associated with operation of Alternative 1 would be 

the same as those associated with the Proposed Action.

Golden Eagles and Migratory Birds

Indirect effects to golden eagles and migratory birds associated with operation of Alternative 1 

would be the same as those associated with the Proposed Action. 

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no direct effects to special status reptile species are associated with the operation of 

Alternative 1.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-27

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Special status insect habitat would be removed during grading activities associated with the 

construction of the facility and roadway; therefore, no direct effects to special status insects 

would be associated with the operation of Alternative 1.

4.4.4 Alternative 2

4.4.4.1 Construction

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects on special status mammal species associated with construction of Alternative 2 

would be similar to those associated with the Proposed Action, including the potential injury or 

death of mice in the area and the loss of habitat associated with construction of the facility. 

Alternative 2 would remove the least amount of pale kangaroo mouse habitat (434 acres), and a 

smaller portion of this area has sandy soils (because of the distance from the dunes) and 

contains less lemon scurfpea and Nevada dalea-dominated mixed salt desert scrub vegetation. 

Additionally, 761 acres of potential habitat (i.e., greasewood-dominated areas with sandy soils) 

would be removed. This is approximately 2.7 percent of the available suitable habitat identified 

within the CESA (29,343 acres). 

Direct effects to a wide variety of special status bat species would include the removal of 

approximately 1,628 acres of potential foraging habitat. Alternative 2 would not restrict bat 

migration throughout the lower Big Smoky Valley.

Golden Eagles and Migratory Birds

Direct effects on golden eagles and migratory birds associated with the construction of 

Alternative 2 would be the same as those associated with the Proposed Action. 

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no indirect effects to special status reptile species are associated with construction of 

Alternative 2. 

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No direct effects to special status insect species are associated with the construction of 

Alternative 2 because these species are endemic to the Crescent Dunes, and the dunes do not 

extend into the Alternative 2 project area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-28

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

Indirect effects to special status mammal species associated with construction of Alternative 2 

would be the same as those associated with the Proposed Action. 

Golden Eagles and Migratory Birds

Indirect effects to golden eagles and migratory birds associated with construction of 

Alternative 2 would be the same as those associated with the Proposed Action. 

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no indirect effects to special status reptile species are associated with construction of 

Alternative 2.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No indirect effects to special status insect species are associated with construction of 

Alternative 2 because these species are endemic to the Crescent Dunes, and the dunes do not 

extend into the Alternative 2 project area. 

4.4.4.2 Operation

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects to special status mammal species associated with operation of Alternative 2 would 

be the same as those associated with the Proposed Action.

Golden Eagles and Migratory Birds

Direct effects to golden eagles and migratory birds associated with operation of Alternative 2 

would be the same as those associated with the Proposed Action.

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no direct effects to special status reptile species are associated with the operation of 

Alternative 2.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No direct effects to special status insect species are associated with the operation of 

Alternative 2 because these species are endemic to the Crescent Dunes, and the dunes do not 

extend into the Alternative 2 project area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-29

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

Indirect effects to special status mammals associated with operation of Alternative 2 would be 

the same as those associated with the Proposed Action.

Golden Eagles and Migratory Birds

Indirect effects to golden eagles and migratory birds associated with operation of Alternative 2 

would be the same as those associated with the Proposed Action.

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no direct effects to special status reptile species are associated with the operation of 

Alternative 2.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No indirect effects to special status insect species are associated with the operation of 

Alternative 2 because these species are endemic to the Crescent Dunes, and the dunes do not 

extend into the Alternative 2 project area.

4.4.5 Borrow Pit

The following subsections summarize the impacts of the construction and operation of the 

borrow pit together because the borrow pit will be open only until completion of construction of 

the generation facility. 

4.4.5.1 Construction

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

No direct effects to pale kangaroo mice are associated with construction of the borrow pit

because habitat for this species is not present. 

Direct effects to a wide variety of special status bat species would include the temporary 

removal of approximately 40 acres of potential foraging habitat. Construction of the borrow pit 

would not restrict bat migration throughout the lower Big Smoky Valley.

Golden Eagles and Migratory Birds

Direct effects to golden eagles and migratory birds associated with construction of the borrow 

pit would be the same as those associated with construction of the Proposed Action in that 

40 acres of potential foraging habitat would be lost.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-30

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no direct effects to special status reptiles are associated with construction of the 

borrow pit. 

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Special status insect species are associated only with the Crescent Dunes, which are not located 

near the borrow pit; therefore, no direct effects to special status insect species are associated 

with construction of the borrow pit. 

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

Indirect effects to special status mammal species associated with construction of the borrow pit

would be the same as those associated with construction of the Proposed Action.

Golden Eagles and Migratory Birds

No indirect effects to golden eagles and migratory birds associated with construction of the 

borrow pit were identified.

Reptiles

No special status reptiles were observed or have the potential to occur within the project area; 

therefore, no indirect effects to special status reptiles are associated with construction of the 

borrow pit. 

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Special status insect species are only associated with the Crescent Dunes, which are not located 

near the borrow pit; therefore, no indirect effects to special status insect species are associated 

with construction of the borrow pit. 

4.4.6 TL and Anaconda-Moly Substation Corridor 

4.4.6.1 Construction

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Direct effects of TL construction activities would be similar to those associated with the 

Proposed Action in those areas with potential habitat. Mice, if present, could be injured or 

crushed during initial grading activities and TL installation, and habitat would be lost. 

Golden Eagles and Migratory Birds

Direct effects of TL construction activities would be similar to those associated with construction 

of the Proposed Action in that potential foraging habitat would be lost (see Section 4.4.2.1). 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-31

Reptiles

No special status reptile species were observed or have the potential to occur within the TL 

area; therefore, no direct effects to special status reptile species are associated with 

construction of the TL.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Since special status insect species are associated only with the Crescent Dunes, which are not 

located near the TL, no direct effects are associated with construction of the TL.

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

No indirect effects to special status mammal species have been identified from construction of 

spur roads and installation of TL poles. 

Golden Eagles and Migratory Birds

No indirect effects to golden eagles and other migratory birds have been identified from the 

construction of spur roads and installation of TL poles. 

Reptiles

No special status reptile species were observed or have the potential to occur within the TL 

area; therefore, no indirect effects to special status reptile species are associated with 

construction of the TL.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

Since special status insect species are associated only with the Crescent Dunes, which are not 

located near the TL; therefore, no indirect effects are associated with construction of the TL.

4.4.6.2 Operation

Direct Effects

Mammals: Pale Kangaroo Mice and Bats

Because habitat for special status mammal species would be removed during initial grading 

activities associated with installation of the TL and completion of spur roads, no additional direct 

effects from operation of the TL are likely to occur.

Golden Eagles and Migratory Birds

Direct effects resulting from operation of the TL on migratory birds may include injury or 

mortality attributable to TL collisions and/or electrocutions. Birds may collide with TLs because 

TLs are not readily visible to them. Recent research has shown that the rate of bird collisions 

may be closely related to bird size (Janss and Ferrer 1998). This means that larger birds in the 

project area may be particularly at risk because it is harder for them to change direction quickly. 

Smaller birds such as passerines are generally much more agile and may be better at avoiding 

TLs. Because the TL would be built in a corridor that already contains several TLs, the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-32

concentration of TLs may make them more visible, therefore making it more likely for birds to 

avoid the area. Bird electrocutions occur when the bird’s body bridges the gap between two 

energized components of the TL (Harness and Wilson 2001). Once again, larger birds with 

greater wingspans may be much more susceptible to electrocution because larger wingspans 

can increase the potential for two points of contact. This potential effect can be mitigated by 

spacing the wires appropriately so that it is impossible for the wingspan of the largest birds in 

the area to contact two wires. Current design standards dictate these specifications.

In addition to collisions and electrocutions, electromagnetic fields may affect birds that roost or 

nest near TLs. Electromagnetic fields could affect a number of factors including but not limited 

to fertility rates, nest success, egg quality, and hatch success (Fernie et al. 2000). Some studies 

suggest that effects of electromagnetic fields are species-specific (Doherty and Grubb 1997), so 

the complete range of effects for birds in the area is unknown.

Not all direct impacts of the TL may be adverse. Recent research shows that raptors and Corvids

(ravens) may benefit from the presence of TLs because they may provide more roosting or 

nesting opportunities (Steenhof et al. 1993). This study also found that nest success for golden 

eagles was higher (10 percent) for nests on TLs than for nests in cliffs.

Indirect Effects

Mammals: Pale Kangaroo Mice and Bats

Introduction of a new TL throughout the valley may increase perching opportunities for raptors, 

owls, and other avian predators. These avian species may increase the predation pressures on 

vulnerable species, such as the pale kangaroo mice and bat species in the area.

Golden Eagles and Migratory Birds

Because habitat for golden eagles and migratory birds would be removed during initial grading 

and excavation activities, no additional indirect impacts are likely to occur with operation of the 

TL and Anaconda-Moly Substation corridor.

4.4.7 No Action Alternative

Under the No Action Alternative, no project-related impacts to special status wildlife species

would occur. 

4.4.8 Summary of Impacts 

Mammals: Pale Kangaroo Mice and Bats

Impacts to pale kangaroo mice would include direct mortality during grading and the removal of 

suitable habitat. Impacts to special status bat species would include the removal of 

approximately 1,628 to 1,673 acres of potential foraging habitat.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-33

Golden Eagles and Migratory Birds

Impacts to golden eagles and migratory birds would include potential injury or mortality 

attributable to the operation of the facility or TL and the removal of approximately 1,628 to 

1,673 acres of potential foraging habit. Impacts to migratory birds would include the loss of 

approximately 1,628 to 1,673 acres of potential nesting and foraging habitat.

4.4.9 Mitigation

Mammals: Pale Kangaroo Mice and Bats

A mitigation plan is being developed between TSE, BLM, and NDOW, and will be included as part 

of the Final EIS. Mitigation would include raptor deterrent mechanisms on TLs and any vertical 

structures that could promote predation by raptors. The evaporations ponds would be covered 

with a porous screen, which would allow evaporation but exclude wildlife (i.e. bats and mice).

Golden Eagles and Migratory Birds

In order to minimize impacts to migratory birds during initial grading activities, the Proponent 

would avoid land clearing activities such as vegetation removal during the avian breeding season 

(April 1 to August 31). These dates may be modified by BLM based on specific site and weather 

conditions. If land clearing activities take place during the avian breeding season, a qualified 

biologist would conduct preconstruction surveys in the affected area to identify nests and 

breeding birds. If active nests were located, then a protective buffer zone would be delineated 

around the area (approximately 100 feet) and land-clearing activities would be restricted within 

this buffer zone. An Avian Protection Plan (APP) is being developed by the proponent in 

corporation with the BLM, and USFWS that will detail additional monitoring, mitigation, and an 

adaptive management approach. The APP will be included as part of the Final EIS. 

Reptiles

No sensitive reptile species were identified in the proposed project area; therefore, no 

mitigation measures would be required.

Insects: Aegialia Scarab, Crescent Dunes Aphodious Scarab, and Crescent Dunes Sirican Scarab

No mitigation is proposed.

4.5 Water Quality and Quantity

4.5.1 Methods 

This section presents impacts that project actions, including construction and operation, may 

have on the hydrologic environment. This section includes mitigation measures to avoid or 

eliminate these impacts or reduce the effects. The groundwater portion of this section has been 

developed using data from the analytical hydro-geological report prepared by the Proponent

(WorleyParsons 2010a). 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-34

The hydro-geological report outlines the data and methods used to assess the potential effects 

of water use for construction and operation of the proposed project, including the effects from 

the original point of diversion, which was located approximately 10.6 miles northwest of the 

project site(s). The location of the final point of diversion would be within the project area 

boundary based on the alternative chosen.

The proposed project would use the following amounts of water, regardless of the location:

• 500 acre-feet for the first year of construction

• 150 acre-feet per year for the next 2 years of construction

• 600 acre-feet per year for the operation of the proposed project

TSE has estimated the life cycle of the project to be 30 years, but has indicated that, with 

proper maintenance, the life cycle could be extended an additional 20 years to a total life cycle 

of 50 years. The numerical model was run for a 53-year time period to encompass 3 years of 

project construction and the 50-year operational life of the project as the reasonably 

foreseeable development scenario. Groundwater would be pumped from on-site wells for both 

construction and project operation. The model showed the anticipated drawdown contours for 

the 53-year water usage. The area analyzed included the 1-foot drawdown contour for the 

53-year scenario.

Data from the test well boring show that the groundwater table from which water is pumped is 

located approximately 172 feet bgs and is not connected to any surface water features. 

Therefore, when describing the drawdown contour, it should be noted that it occurs 

approximately 172 feet bgs. In addition, the 10-foot drawdown contour occurs in an 

approximately 5-foot radius from the well. 

To simulate aquifer recovery at the end of project life, the numerical model was run for 

153 years, including 53 years of pumping at the project area, followed by 100 years of 

groundwater level recovery. Thus, the assumption was made that actual recovery would take 

less than 100 years, in order to allow the model simulation to capture the full time period of 

recovery. The purpose of this section is to estimate the time period required for groundwater 

levels to recover after 53 years of project-related pumping.

Six hundred AFY of steady-state agricultural pumping was simulated to turn off as it is diverted 

to the project area for 53 years. During the 100-year period of recovery evaluation, the original 

600 AFY of diverted agricultural pumping was not restored to agricultural use in the model 

simulation. This matches the expected conditions that would likely occur. As a result of the 

diverted agricultural pumping not being restored, the aquifer was simulated to recover to above 

pre-pumping steady state groundwater levels. However, this effect does not change the time 

period needed for recovery from project pumping because each well affects the aquifer 

individually.
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-35

See Section 4.5.10 for a list of the expected drawdown of existing wells within the 53-year, 

1-foot drawdown contour.

4.5.2 Proposed Action 

4.5.2.1 Construction

For purpose of water impacts during construction, the analysis used the impacts derived from 

the operational water consumption of 600 AFY.

The existing test well would be used as a source of construction water for the Proposed Action. 

Figure 4-4 shows the 1-foot contour for the 53-year scenario.

Direct Effects

Drawdown imposed by a well on another nearby pumping well can have adverse effects on the 

performance of that nearby well and is referred to as interference drawdown, or well 

interference. Specific potential adverse effects that could be evaluated using model results 

reported in this document include the following:

• Interference drawdown can result in the water level of an aquifer being drawn down 

below the screen of the well (i.e., the well goes dry). 

• Interference drawdown can result in the water level of an aquifer being drawn down to 

a point where the affected well’s capacity to pump water is decreased and the well can 

no longer produce the amount of water that is needed for a particular use, or the well is 

at risk of becoming damaged and unusable over time because of exposure of the well’s 

screen above the water table and resulting corrosion. 

• Interference drawdown can result in the water level in the affected well being drawn 

down to near the intake of the well’s pump, requiring lowering of the pump intake in 

order for the well to remain operational. 

• Interference drawdown can cause a decrease in groundwater level in the affected well 

such that the well and pump can continue to operate and produce adequate amounts of 

water, but pumping must occur at either greater frequency or duration, and/or water 

must be lifted to a greater height, resulting in greater operational and maintenance 

costs. 
Source: Worley Parsons, 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\1_ft_cont_Const_Act.mxd

Figure 4-4 1-foot Drawdown

Contour for Construction Activities

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-37

The extent and type of well interference experienced by an affected well depends on 

hydrogeologic conditions in the aquifer as well as characteristics of the affected well. These 

factors include the following:

• the amount of interference drawdown that is applied (which varies with the distance of 

the affected well from the proposed project well/wells)

• the depth and screened interval of the affected well

• the thickness of saturated sediments penetrated by the affected well

• local variations in the transmissivity of the saturated sediments in which the affected 

well is completed, if any

• the condition and efficiency of the affected well

• the affected well’s pump specifications, including its rating curve, the depth at which the 

pump intake is set, and the resulting pumping water level in the well during operation

• the minimum required water production rate of the well

As shown in Figures 4-4 to 4-7, the amount of interference drawdown induced at the closest 

existing well ranges from approximately 1 to 2.5 feet for wells within 5 miles of the production 

well for the proposed project, Alternative 1, and Alternative 2 locations. This amount of 

drawdown will not result in wells going dry, their well screens being exposed, or the wells having 

a noticeably diminished capacity. Other wells located at a greater distance would experience 

lesser effects.

Lowering the water table would cause an incremental increase in electrical costs to pump 

groundwater from a greater depth and possibly higher maintenance costs over time or per unit 

of water pumped. For the limited amount of predicted interference drawdown, this effect 

would be relatively small.

Accidental spills from vehicles, motorized machinery, and heavy equipment could result in 

potential discharge of contaminants; however, applicable spill management plans would be 

implemented to minimize such impacts. In addition, no seeps or springs are located in or 

adjacent to the Proposed Action. The proposed project well has a depth to groundwater of 

172 feet bgs (WorleyParsons 2010a). The wellhead protection area of the project well could be 

affected by on-site discharged contaminants. 

Surface Water

Because the drawdown of groundwater would occur approximately 172 feet bgs, and would not 

be connected to surface water resources, no direct impacts to surface water are likely.

The potential of a large storm occurring during construction on disturbed surfaces within the 

proposed project site could increase sediment transport in stormwater runoff. 

Accidental spills from vehicles, motorized machinery, and heavy equipment could result in 

potential discharge of contaminants. The potential for accidental spills and the additional 

impervious areas (paved access roads, unpaved perimeter roads surfaced with rock, and several 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-38

buildings and enclosures—with some buildings only temporary for construction) could result in 

increased pollutant loading of stormwater surface runoff during a storm. 

The location of temporary construction facilities and laydown areas may affect the existing 

drainage patterns and runoff of the project site. 

Indirect Effects

Groundwater

Water quality could potentially be affected by naturally occurring high-TDS water below the 

playa (in the southern part of the Tonopah Flat Subarea) migrating with pumping from the well.

Upon completion of construction, the well used for construction water would be capped in 

accordance with local and state regulations. A new well will be installed at the power block area 

of the Proposed Action to provide water during operation.

The modeled recovery time was shown to approximately 40 years, if the project well was 

pumped for 53 years. It should be noted that the construction water would be needed for only 

3 years and, therefore, the recovery time would be shortened.

Surface Water

Because the drawdown of groundwater would occur at 172 feet bgs and because groundwater 

is not connected to surface water resources, no direct impacts to surface water are likely.

An increase in stormwater runoff flows generated by the addition of impervious areas could 

potentially result in the extension of downstream limits of existing ephemeral streams crossing 

the proposed project site. Currently, these ephemeral streams lose definition before reaching 

Peavine Creek, as shown in Figure 3-7. The effect of increased runoff could result in flow 

reaching closer to Peavine Creek. 

The potential for a large storm occurring during construction on disturbed surfaces within the 

proposed project site could increase sediment transport in stormwater runoff. If disturbed 

surfaces remain exposed (possibly denuded of vegetation) during long storms, the increased 

sediment in runoff could potentially clog the culvert under Pole Line Road (SH 89) and/or 

possibly discharge to Peavine Creek, creating turbidity and degrading water quality downstream.

4.5.2.2 Operation

During operation of the project, water usage would be 600 AFY. The water use would result in 

industrial wastewater effluent that would be discharged to evaporation ponds as described in 

Chapter 2. A wastewater plan was prepared (WorleyParsons 2010b) that describes this effluent 

and its components. 

In a 30-year operating life of the evaporation ponds, up to 3 feet of sludge may accumulate in 

the base of the ponds that consists of precipitated solids from the evaporated wastewater. The 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-39

total amount of accumulated solids is estimated to be approximately 50,000 tons. The predicted 

chemical makeup of the sludge, based on the raw water chemistry, is provided in Table 4-7. The 

concentration of chemical constituents expected in the evaporation residue is compared to the 

TCLP as reported under CFR Part 261, Section 261.24; however, there are no TCLP limits for the 

expected chemicals in the sludge. Therefore, it would be considered a non-hazardous waste 

under federal regulations.

The action leakage rate (ALR) is the allowable leakage from the primary liner system above 

which contingency actions are triggered. According to 40 CFR Section 264.222, the ALR is 

defined as “...the maximum design flow rate that the leak detection system can remove without 

the fluid head on the bottom liner exceeding 1 foot.” The ALR must also include an adequate 

safety margin to allow for variability in the containment system design (e.g., liner and collection 

pipe slope, interstitial fill hydraulic conductivity, thickness of drainage material).

The estimated ALR for the evaporation ponds is 2,750 gallons per acre per day, which is based 

on one standard hole per acre, a drainage layer geonet with hydraulic conductivity of 0.06 m/s, 

and a 50 percent safety factor. The assumption underlying this ALR calculation would be verified 

in the actual constructed ponds. Based on a 10-acre pond, each evaporation pond would have 

an ALR of 27,750 gallons per day. However, the ALR would need field verification because this 

rate would vary depending on the actual drainage material used and its hydraulic conductivity.

Waterfowl and other birds may be attracted to the evaporation ponds. The use of anti-perching 

devices around the perimeter of each pond would assist in excluding ravens and other birds 

from accessing the edge of the ponds to drink the water. Additionally, operational design of the 

ponds is such that a minimum freeboard of 2 feet would be maintained at all times, and the 

interior slopes of the ponds would be at a 33 percent (a 3:1 slope). These project design features 

would make it difficult for perching birds and/or shorebirds to access the water, and are 

anticipated to minimize risk to wildlife by minimizing availability of water as a new subsidy. 

However, in the event that a bird or other animal accidentally falls into the ponds, they would 

be able to crawl out using the textured portion of the liner that would be present in each corner 

of the pond for that purpose. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS | 4-40

1 Table 4-7. Predicted chemical makeup of the pond sludge

Constituent

Concentration in

EP Discharge

(mg/L)

Conversion 

to lbs/gal

Solids 

per year

(lbs)

Total Residue

Mass at Clean 

Out (lbs)

Total Residue

Mass After 30 Years

(lbs)

Weight 

(%)

Weight 

(ppm)

TCLP

(mg/L)

Cations

Calcium 206 0.001722 59,419 415,932 1,782,566 1.8184% 18,184 * 

Magnesium 79 0.000659 22,743 159,204 682,305 0.6960% 6,960 * 

Potassium 187 0.001557 53,698 375,887 1,610,943 1.6433% 16,433 * 

Sodium 3,327 0.027763 957,752 6,704,265 28,732,562 29.3104% 293,104 * 

Anions

Chloride 533 0.004448 153,431 1,074,016 4,602,927 4.6955% 46,955 * 

Fluoride 24.0 0.000200 6,904 48,328 207,121 0.2113% 2,113 * 

Silica 

(dissolved) 176 0.001470 50,717 355,021 1,521,517 1.5521% 15,521 * 

Sulfate 6,817 0.056891 1,962,611 13,738,276 58,878,326 60.0625% 600,625 * 

Metals

Manganese 0.67 0.000006 193 1,354 5,804 0.0059% 59 * 

Zinc 0.504 0.000004 145 1,016 4,353 0.0044% 44 * 

Total 11,350 3,267,614 22,873,299 98,028,424 100.00% 1,000,000

TDS 11,410 0.095220 3,284,867 22,994,071 98,546,018

Conversion Factors:

8.34 lb H2O to 1 gallon of H2O 8.345

Average wastewater flow rate (gal/min) 130.2

Operation time (min/year) 264,960

Wastewater quantity (gal/year) 34,497,792

Notes: Regulatory standards/reportable quantities are for mentioned elements only. * Not listed/no standards

1) Constituents in the evaporation pond discharge are based on the raw water constituents. 

2) There may be other constituents in the residue; however, they are not listed because they have not been evaluated.

3) If the parameter was not detected in the groundwater, then it is considered to have zero residue in the sludge. 

4) All waste would be non-volatile and would be collected in the evaporation ponds.

5) All species removed by MMF and RO would be returned to the evaporation ponds. 

6) A comparison to TDS values is provided to show the consistency of the calculation.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-41

Because the ponds would remain uncovered to maximize evaporation and to avoid trapping birds under 

netting or monofilament arrays, it is anticipated that primarily waterfowl such as ducks and geese would 

be able to access the evaporation ponds by landing on the water.

Adaptive measures that would be taken, as necessary, to keep birds from using the ponds include:

• In the event that climatic conditions are such that evaporation must be increased to maintain 

pond levels below the freeboard limits, evaporative disposal nozzles (see, for example, 

<www.bete.com/applications/disposal.html>) would be used to increase wastewater 

evaporation rates.

• An air cannon would be used to haze waterfowl and frighten them away from the evaporation 

ponds. The air cannon would be stored on-site, but would be used only under this circumstance

because birds may become acclimated to the disturbance caused by air cannon hazing, if used 

on a regular basis. The air cannon would be used until the evaporation process was completed 

in the pond, or until the crystallized salts returned to solution.

• A “Bird-B-Gone Balloon” (a visual scare device) or other hazing devices would be deployed into 

the pond to discourage waterfowl from landing on the pond.

Direct Effects

During operation of the Proposed Action, the well would be located within the power block area, 

approximately 5,000 feet south of the test well. According to the hydrogeological model information, 

the geological features of this area are similar to that of the test well location, and the same drawdown 

contour can be expected from pumping water at this location (WorleyParsons 2010b). Figure 4-5 shows 

the 1-foot contour for the 53-year scenario at this location. 

Direct effects would be similar to those discussed in Section 4.5.2.1. 
Source: Worley Parsons, 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\53_year_Prop_Alterntv.mxd

Figure 4-5 The 1-foot contour for

the 53-year scenario for the 

Proposed Alternative.

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-43

Indirect Effects

Groundwater

The model showed that the recovery time for pumping groundwater for a 50-year lifetime of the project 

would be 47 years.

Accidental spills from vehicles, motorized machinery, and heavy equipment could result in potential 

discharge of contaminants. Project operation activities could result in contamination of the wellhead 

protection area of the project well on-site. The proposed project well would have a depth to 

groundwater of 172 feet bgs (WorleyParsons 2010a).

Surface Water

Because the drawdown of groundwater would occur at 172 feet bgs, and is not connected to surface 

water resources, no indirect impacts to surface water are likely.

Accidental spills from vehicles, motorized machinery, and heavy equipment during facility operations 

and maintenance could result in discharge of contaminants. The potential for accidental spills and the 

additional impervious areas (paved access roads, unpaved perimeter roads surfaced with rock, and 

several buildings and enclosures) could result in increased pollutant loading of stormwater surface 

runoff during a storm. 

The location of operation facilities and addition of impervious areas may affect the existing drainage 

pattern and runoff of the project site. 

4.5.3 Alternative 1

4.5.3.1 Construction

Direct Effects

Groundwater

Direct effects of the construction of Alternative 1 on groundwater would be similar to those described 

for the Proposed Action because the groundwater resource data are similar for both sites. 

Surface Water

Direct effects of the construction of Alternative 1 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites. 

Indirect Effects

Groundwater

Indirect effects of the construction of Alternative 1 on groundwater would be similar to those described 

for the Proposed Action. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-44

Surface Water

Indirect effects of the construction of Alternative 1 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites. 

4.5.3.2 Operation

During operation of Alternative 1, the well would be located within the power block area, approximately 

1.85 miles north of the test well. The geological features of this area are similar to that of the test well 

location, and the same drawdown contour can be expected from pumping water at this location 

(WorleyParsons 2010b). Figure 4-6 shows the 1-foot drawdown contour for the 53-year scenario at this 

location. 

Direct Effects

Groundwater

Impacts would be similar to those described for the Proposed Action.

Surface Water

Direct effects of the construction of Alternative 1 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites. 

Indirect Effects

Groundwater

Indirect effects to groundwater would be similar to those described for the Proposed Action. The model 

showed that the recovery time for a well at this location would be 37 years.

Surface Water

Indirect effects of the construction of Alternative 1 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites. 
Source: Worley Parsons, 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\53_year_Alterntv_1.mxd

Figure 4-6 The 1-foot contour for

the 53-year scenario for the 

Alternative 1. In-direct Effects.

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-46

4.5.4 Alternative 2

4.5.4.1 Construction

Direct Effects

Groundwater

Direct effects of the construction of Alternative 2 on groundwater would be similar to those described 

for the Proposed Action because construction water would be delivered from the same point.

Surface Water

Direct effects of the construction of Alternative 2 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites. 

Indirect Effects

Groundwater

Indirect effects of the construction of Alternative 2 on groundwater would be similar to those described 

for the Proposed Action because construction water would be delivered from the same point.

Surface Water

Indirect effects of the construction of Alternative 2 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites. 

4.5.4.2 Operation

During operation of Alternative 2, the well would be located within the power block area, approximately 

2.4 miles northwest of the test well. The geological features of this area are similar to that of the test 

well location, and the same drawdown contour can be expected from pumping water at this location 

(WorleyParsons 2010b). Figure 4-7 shows the 1-foot drawdown contour for the 53-year scenario at this 

location. 
Source: Worley Parsons, 2010

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\53_year_Alterntv_2.mxd

Figure 4-7 The 1-foot contour for

the 53-year scenario for the 

Alternative 2.

Crescent Dunes Solar Energy Project
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-48

Direct Effects

Groundwater

Direct effects would be similar to those described for the Proposed Action. 

Surface Water

Direct effects of the operation of Alternative 2 on surface water would be similar to those described for 

the Proposed Action because the terrain is similar for both sites. 

Indirect Effects

Groundwater

Indirect effects to groundwater would be similar to those described for the Proposed Action. The model 

showed that the recovery time for a well at this location would be 32 years.

Surface Water

Indirect effects of the operation of Alternative 2 on surface water would be similar to those described 

for the Proposed Action because the terrain is similar for both sites

4.5.5 TL and Anaconda-Moly Substation Corridor 

4.5.5.1 Construction

Direct Effects

Groundwater

Construction of the TL corridor is not expected to affect groundwater. 

Surface Water

The potential of a large storm occurring during construction on disturbed surfaces within the TL corridor 

could increase sediment transport in stormwater runoff. 

Accidental spills from vehicles, motorized machinery, and heavy equipment could result in potential 

discharge of contaminants. The potential for accidental spills and the additional impervious areas (paved 

access roads, unpaved perimeter roads surfaced with rock, and several buildings and enclosures—with 

some buildings only temporary for construction) could result in increased pollutant loading of 

stormwater surface runoff during a storm. 

The location of temporary construction laydown areas may affect the existing drainage pattern and 

runoff along the TL corridor. The location of transmission towers should avoid the ephemeral streams 

passing through the TL corridor to the extent feasible. TL construction activities and the placement of 

transmission towers could alter the normal flow of the defined ephemeral washes.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-49

Indirect Effects

Groundwater

Construction of the TL corridor is not expected to affect groundwater. 

Surface Water

A potential increase of stormwater runoff flows generated by the increase of soil compaction during 

construction could result in the extension of downstream limits of the existing ephemeral streams 

crossing the TL corridor. Currently, these ephemeral streams lose definition before reaching Peavine 

Creek. The increased runoff could result in flow reaching closer to Peavine Creek. 

The potential of a large storm occurring during construction on disturbed surfaces within the proposed 

project site could increase sediment transport in stormwater runoff. If disturbed surfaces remain 

exposed (possibly denuded of vegetation) during long storms, the increased sediment in runoff could 

potentially discharge to Peavine Creek, creating turbidity and degrading water quality downstream. 

4.5.5.2 Operation

Direct Effects

Groundwater

Operation of the TL and Anaconda-Moly Substation is not expected to affect groundwater. 

Surface Water

Operation of the TL and Anaconda-Moly Substation is not expected to affect surface water. 

Indirect Effects

Groundwater

Operation of the TL and Anaconda-Moly Substation is not expected to affect groundwater. 

Surface Water

Operation of the TL and Anaconda-Moly Substation is not expected to affect surface water. 

4.5.6 Borrow Pit

The following subsections summarize the impacts of the construction and operation of the borrow pit 

together because the borrow pit would be open only until the completion of construction of the 

generation facility. 

Direct Effects

Groundwater

Water to support excavation of aggregate would be provided from the proposed well within the 

Proposed Action; therefore, no impact to groundwater associated with activities at the borrow pit 

during construction are likely. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-50

Surface Water

The potential of a large storm occurring during construction (excavation) on disturbed surfaces within 

the borrow pit site could increase sediment transport in stormwater runoff. If disturbed surfaces remain 

exposed during long storms, the increased sediment in runoff could potentially discharge to the 

ephemeral Peavine Creek, creating turbidity and degrading water quality downstream. 

Accidental spills from vehicles, motorized machinery, and heavy equipment could result in potential 

discharge of contaminants. The potential for accidental spills could result in increased pollutant loading 

of surface runoff during a storm that could discharge to the ephemeral Peavine Creek. 

Indirect Effects

Groundwater

There should be no impacts to groundwater associated with activities at the borrow pit during 

construction. 

Surface Water

Surface water runoff can have both direct and indirect effects. Contamination from spills can lead to 

effects such as small mammal fatalities, and subsequent predator/scavengers consumption. 

4.5.7 Point of Diversion 

Water rights for supplying the proposed project would be obtained by purchasing existing certificated 

water rights for agricultural use located in agricultural area 2 in the same basin as the proposed project 

site. Currently, this water is used for irrigation to grow and harvest alfalfa. If the water were diverted to 

the plant, the 853 AFY could no longer be used for the production of alfalfa.

It is likely that the land currently irrigated would be fallowed and, during the project lifetime, would 

revert back to native vegetation. Once alfalfa is no longer grown, the jobs associated with the alfalfa 

crop would no longer be needed. However, this discrepancy would be made up by the number of jobs 

the construction and operation of the project would generate.

4.5.8 PWR 107

Construction and operation of the proposed project should have no known direct or indirect effects on 

PWR 107 waters. The modeling showed no connection between the groundwater and springs/seeps, 

and further all identified PWR 107 locations outside the 1-foot drawdown contour.

There should be no known cumulative effects attributable to proposed project construction and 

operation activities. The 1-foot drawdown of the proposed well pumping is expected to be 

approximately 172 feet bgs and should not have an effect on the PWR 107 waters within the 

groundwater CESA (WorleyParsons 2010a). 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-51

4.5.9 No Action Alternative

Under the No Action Alternative, potential impacts to hydrological resources associated with this project 

would not occur. 

4.5.10 Summary of Impacts 

As discussed previously, there is a potential for direct, indirect, and cumulative impacts to hydrological 

resources associated with various tasks of construction and operation of the proposed project. 

Groundwater

Potential direct impacts to groundwater associated with this proposed project include:

• contamination entering the wellhead protection area 

• proposed well pumping causing drawdown, affecting nearby existing wells

• restrictions to existing well access or use 

Potential indirect impacts to groundwater associated with this proposed project include:

• contamination entering groundwater within the CESA 

• proposed well pumping causing drawdown, affecting existing springs or wells within the CESA

Table 4-8 shows the results provided in the Groundwater Evaluation Report regarding the drawdown on 

each of the existing wells within the CESA.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-52

Table 4-8. Estimated drawdown on existing wells within the CESA

Well Number 

Pumping Location 

TW-1 Alt-2 Alt-1 Proposed 

11 1.03 0.98 0.97 1.11 

12 1.01 0.98 0.96 1.07 

13 1.01 0.97 0.95 1.07 

16 0.88 0.76 0.79 1.00 

20 0.97 0.77 0.84 1.15 

21 0.97 0.77 0.84 1.15 

22 0.97 0.77 0.84 1.15 

23 0.99 0.81 0.87 1.16 

24 0.84 0.67 0.73 0.99 

43 2.11 1.57 1.78 2.61 

44 2.11 1.57 1.78 2.61 

45 1.21 1.09 1.11 1.34 

Surface Water

Potential direct impacts to surface water associated with this proposed project include:

• increased runoff flows

• increased sediment transport

• increased discharge and transport of contaminants

• possible effects to drainage paths or altered flow 

Potential indirect impacts to surface water associated with this proposed project include:

• altered flow or drainage paths

• increased sediment or contaminants in downstream water, creating turbidity or degrading 

water quality downstream

4.5.11 Mitigation

Mitigation measures to avoid or eliminate the potential impacts to hydrological resources associated 

with various tasks of construction and operation of the proposed project are discussed below. 

General water quality is protected under the Clean Water Act. All surface water runoff that would occur 

during and after construction as a result of the project would be controlled in accordance with the 

requirements of the construction and operational (post-construction) NPDES Stormwater Permit and 

other applicable laws, ordinances, regulations, and standards.

SPCC plans would be prepared for project construction and operation, to include spill prevention and 

countermeasure procedures to be implemented. To the extent practicable, SPCC would minimize the 

use of and need for disposal of hazardous and toxic wastes. The implementation of BMPs would prevent 

transport of contamination to the environment. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-53

The preparation and implementation of a construction SWPPP (a requirement of NPDES) that includes 

site-specific BMPs would mitigate and reduce erosion and water pollution.

BMPs may include: 

• silt barriers installed during construction to filter or contain sediment transport

• frequent inspection and cleaning of construction equipment to reduce or prevent contamination

• equipment fueling and service at designated locations away from drainage paths and wells to 

minimize contamination transport

As discussed in Section 2.5.2, grading of the site would allow storm flows to follow preexisting paths. 

The power island would be graded to direct rainfall within the power island to detention/retention 

basins adjacent to the on-site salt tanks to infiltrate into the ground instead of flowing off-site. Small 

ditches would be constructed along roadways and culverts as needed where washes cross roads. 

Transmission towers to be located along the proposed TL corridor would be positioned to avoid existing 

drainage paths of ephemeral washes to mitigate the potential for altered flow paths.

Facility water needs are estimated to be less than the anticipated maximum water right quantity to be 

acquired and would not negatively affect or alter the appropriation of groundwater. 

The Proponent has filed for an approved jurisdictional determination requesting that the ephemeral 

Peavine Creek and its tributaries not be subject to jurisdiction under the Clean Water Act because they 

have been determined to be isolated intrastate waters (JBR 2010a).

Evaporation Ponds Avian and Wildlife Monitoring and Protection

A detailed monitoring and mitigation plan would be developed in coordination with NDOW as part of 

the Artificial Industrial Pond Permit application process. Initial mitigation and monitoring measures are 

described below.

Avian monitoring at the evaporation ponds would be conducted twice monthly for the first 2 years of 

project operation and would continue at least monthly over the life of the project. The monitor (an 

appointed biologist or Environment Compliance Manager) would identify bird species and/or functional 

groups (e.g., waterfowl, waders, shorebirds, upland shorebirds) and wildlife observed utilizing the 

ponds, record the behavior of the birds and wildlife (e.g., feeding, swimming, wading, nesting), and note 

any mortalities or physical infirmities (e.g., birth defects or reduced growth) associated with any animals

observed on or adjacent to the evaporation ponds. This information would be compiled and submitted 

to NDOW on a quarterly basis in accordance with the AIPP guidelines and permit requirements. Any 

dead bird or wildlife that could be safely retrieved from the evaporation ponds would be collected by a 

biologist or Environment Compliance Manager and sent to a qualified laboratory to determine whether

the mortality was directly related to salt toxicity or encrustation. In accordance with the AIPP guidelines 

and permit requirements, all mortalities or injuries would be reported to NDOW within 24 hours of the

observation. Documented mortality resulting from salt toxicity or encrustation would result in corrective 

measures or additional mitigation actions implemented in coordination with NDOW, BLM, and any other 

appropriate agencies. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-54

Each active evaporation pond would be outfitted with a level gauge for daily water level measurements, 

a hydrometer for daily salinity measurements, and a direct reading thermometer with the temperature 

data recorded at least diurnally. If the average overnight water temperature in the active evaporation 

ponds is at or below 4 degrees Celsius, a visual survey of the ponds would be conducted immediately on 

the following morning. If upon inspection of the active ponds, the designated representative observes 

evidence of recent substantive increases in salt crystallization anywhere within the pond (e.g., at or near 

the waterline) all wastewater would be pumped into one or two ponds to increase the pond volume and 

lower the average salinity within the pond(s). At the same time, the remaining pond or ponds would be 

pumped dry. The pond to which the combined flow is discharged during this time would be rotated each 

year periodically as needed so that water levels do not rise too high and minimum freeboard 

requirements are met.

4.6 Air Quality

This section describes the analysis conducted to assess the air quality impacts and to assess whether the 

proposed project conforms to Clean Air Act requirements and complies with state and local air quality 

requirements. Emission estimates are presented for project construction, commissioning, and 

operation. While the proposed solar power project would represent a significant reduction in 

greenhouse gas emissions relative to fossil fuel-based power generation projects, the relatively small 

amount of greenhouse gas emissions associated with the proposed project is provided for informational 

purpose. No conclusions regarding the significance of the greenhouse gas emissions are made in the 

analysis.

4.6.1 Methodology 

For this project, the air quality impact analysis includes the entire proposed project site, the alternative

sites, the borrow pit, the TL, and the Anaconda-Moly Substation corridor. The impacts do not 

substantively change for the alternative sites to necessitate separate evaluations.

In this section, the proposed project evaluation for air quality conformity is discussed. The annual direct 

and indirect criteria pollutant emission rates were calculated for the three phases of the project—

construction, commissioning, and operation. The first two phases are nonrecurring, discrete, and of 

limited duration and extent. The first phase is the 30-month construction period for the permanent 

facilities, including the heliostat field, the liquid salt tower receiver, piping and storage systems, power 

generating block systems, and buildings. The construction phase also encompasses the salt melting and 

conditioning (“salt commissioning”) activities. The second phase includes the power block 

commissioning activities. The third and final phase is the steady state operation of the facility. The 

criteria pollutants evaluated include oxides of nitrogen (NOx), oxides of sulfur (SOx), volatile organic 

compounds (VOCs), CO, PM10, and PM2.5. 

Greenhouse gas emissions, which include carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O),

were calculated for all three phases of the project. As previously noted, emissions of 

hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6) will be present, but 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-55

they are expected to be insignificant for the proposed project. A quantification of HFCs, PFCs, and SF6

was, therefore, not included in the analysis. 

Hazardous air pollutants (HAPs) for the proposed project, which are mainly associated with mobile and 

construction sources powered by diesel fuel, were determined and found to be minor and well within 

the applicability thresholds of the National Emissions Standards for Hazardous Air Pollutants.

4.6.2 Proposed Project Emission Estimates

4.6.2.1 Construction

Short-term emissions would be generated from the installation of a 638-foot-tall solar receiving tower, 

the steam turbine power block, up to 17,500 heliostats, and various auxiliary equipment and ancillary 

structures. Approximately 1,600 acres (Table 4-1 shows the acreage associated with each alternative) of 

the total land holding would experience temporary disturbance during construction activities, which are 

expected to occur for approximately 30 months, resulting in between 1,652 and 1,673 acres (depending 

on alternative) of permanently disturbed land area.

Emissions were estimated for construction equipment exhaust, on-site and off-site motor vehicle 

exhaust, re-entrained road dust, fugitive dust emissions from soil disturbance, fugitive emissions from 

wind erosion of stockpiles, and fugitive emissions from a temporary concrete batch plant.

The salt commissioning activities would take place during the construction phase of the project and 

would involve the melting, heating, and conditioning of approximately 70 million pounds of sodium 

nitrate and potassium nitrate salts. The salt commissioning process is expected to take approximately 90 

days and is planned to begin in the 18th month of construction. A detailed description of the salt system 

commissioning process is provided in Chapter 2. This section presents the analysis of the combined 

emissions from the concurrently scheduled construction and salt commissioning activities.

Construction Schedule 

Project construction and initial commissioning would occur over approximately 30 months, from 

December 2010 to the third quarter of 2013. An overall project schedule is provided in the project 

description section. Construction would progress from site preparation to construction of the central 

receiver tower and molten salt system, then to construction of the power block and heliostat field. 

Other project requirements such as access roads, facility buildings, and new TLs would be constructed at 

the appropriate time during the overall construction schedule.

Estimated Construction Emissions

On-site and off-site project emissions were divided into three categories: vehicle and construction 

equipment exhaust, fugitive dust generated by vehicles and construction equipment, and wind-driven 

fugitive dust. Construction equipment exhaust emissions were estimated using the URBEMIS2007 

(version 9.2.4) emission factors. Fugitive dust emissions from the concrete batch plant were estimated 

using EPA-approved emission factors published in AP-42 (EPA 2006). Fugitive dust emissions from paved 

and unpaved roads were estimated using EPA-approved emission factors and methodology published in 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-56

AP-42 (EPA 2006). These emission factors were reduced by 68 percent based on the proposed watering 

of traveled roads twice a day. 

Fugitive dust emissions from soil disturbance (e.g., grading activities) were estimated based on the 

controlled emission factor published in URBEMIS. These emissions were assumed to have 50 percent 

control of fugitive dust emissions by the application of water to the disturbed surface. Fugitive dust 

emissions from wind erosion of material stockpiles were estimated using the methodology published in 

AP-42 (EPA 2006). On-road exhaust emissions were estimated using EMFAC2007 (version 2.3) emission 

factors. On-road and off-road exhaust emissions were estimated assuming the use of ultra low sulfur 

diesel fuel.

Construction emissions also would be generated during installation of a 9.5-mile-long TL. Off-site 

emission sources include the exhaust emissions from construction equipment and motorized vehicles 

used to install the TL poles and pull conductors, as well as the exhaust emissions from motor vehicles 

traveling to and from the planned work sites (e.g., delivery trucks and worker vehicles). Minor amounts 

of fugitive dust also would be generated by construction activities and vehicle travel on roadways. The 

emission calculation methodology for the off-site construction activities was similar to the methodology 

for estimating on-site construction emissions.

Maximum annual emissions were estimated based on the number and type of construction equipment, 

the number of heavy-duty trucks, fugitive dust, and the roundtrip workforce commutes projected for 

each month of construction. The maximum annual construction emissions were estimated as the sum 

of the maximum monthly emissions over a 12-month period.

The maximum annual construction emissions are presented in Table 4-9. The detailed emission 

calculations for construction are provided in the Air Emissions Sources and Inventory Report (Solar 

Reserve 2010).

Table 4-9. Maximum annual criteria pollutant emission estimates from construction activities

Construction Emission Source

Emissions (tons per year)

NOx CO VOC SO2 PM10 PM2.5

On-site construction emissions 26.1 14.0 3.0 0.03 28.4 4.4 

Off-site vehicle emissions 5.8 15.5 1.9 0.02 7.6 0.9 

Off-site construction emissions 2.9 1.7 0.3 0.004 2.3 0.3

Greenhouse gas emissions from construction activities are presented in Table 4-10. Construction 

equipment emissions and fuel use were estimated using emission factors from the California Climate 

Action Registry (CCAR) General Reporting Protocol (version 3.1) (CCAR 2009) and fuel consumption rates 

from the OFFROAD2007 model. Vehicle emissions and fuel use (trucks and worker commutes) were 

estimated using emission factors from the CCAR General Reporting Protocol (version 3.1) and EPA fuel 

economy values. This approach meets the reporting requirements of the Nevada Bureau of Air Quality 

Planning (BAQP).
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-57

Estimated total fuel use during construction would be 1,485,848 gallons of diesel and 1,168,622 gallons 

of gasoline. Detailed greenhouse gas emission and fuel use calculations are included in Air Emissions 

Sources and Inventory Report (Solar Reserve 2010). 

Table 4-10. Nonrecurring greenhouse gas emissions estimates for construction activities

Duration

Greenhouse Gas Emissions (metric tons)

CO2 CH4 N2O CO2 Equivalent

Maximum annual (tonnes/year) 7,037 0.30 0.146 7,089 

Maximum project (tonnes/project) 9,415 0.48 0.228 9,496 

Note: Tonnes are in metric tons. 

4.7.2.1.3 Emissions Associated with Salt Commissioning Activities

The salt melting and heating processes would produce limited emissions of criteria pollutants resulting 

from the combustion of gaseous fuels in two temporary gas-fired convection heaters with rating 

capacities of 55 million British thermal units per hour (MMBtu/hr) and 20 MMBtu/hr. Propane was 

chosen for the analysis, but other fuels might include natural gas or liquefied natural gas as potential

alternatives (there is no pipeline connection proposed for the project location and there is one potential 

liquefied natural gas truck terminal within a reasonable distance). Criteria and greenhouse gas emissions 

have been estimated using the highest emission rates among the fuel types considered. The NOx

emissions for the two heaters were estimated assuming the heaters would be equipped with both 

ultralow NOx burners and flue gas recirculation. Minimal to no fugitive particulate emissions would be 

generated during the handling of the solid salts because the solid salts would be handled in an indoor 

environment. Furthermore, the salts are greatly hydrophilic (high tendency in absorbing moisture) and 

tend to solidify and remain in solid form. 

The salt conditioning (i.e., the process of bringing salt up to its operating temperature range) would 

result in the release of NO2 from the oxidation of magnesium nitrate impurity in the salt solution; this 

emission source would be separate from the combustion emissions from the heating process described 

above. The NO2 estimates for the salt conditioning process assumed all the magnesium nitrate impurity 

as guaranteed by the supplier for each salt oxidizes completely and releases entirely from the liquid 

solution. This is conservative because the actual magnesium nitrate impurity is substantially less than 

the supplier guarantee level. To further reduce the potential emission from this process, the project is in 

the process of identifying sources and methods to further reduce the magnesium impurity in the salt. If 

achievable, salt conditioning would become unnecessary.

In the event that ultralow magnesium impurity salts are not available, the release of NO2 from the salt 

conditioning process would be controlled by a multistage chemical wet scrubber. The project Proponent 

may also consider other control options such as the use of selective catalytic reduction. The emission 

estimates and analysis were conducted on the basis of the multistage chemical wet scrubber for 

controlling NO2 emissions. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-58

After the salt commissioning activity is completed, the two gas-fired heaters and the NO2 scrubber 

system would be dismantled and removed from the project site. 

The criteria pollutant emissions estimated for the salt commissioning process are presented in Table 4-

11. The detailed emission calculations for commissioning are provided in the Air Emissions Sources and 

Inventory Report (Solar Reserve 2010).

Table 4-11. Nonrecurring criteria pollutant emission estimates for salt system commissioning 

activities

Salt System Commissioning NOx CO VOC SO2 PM10 PM2.5

Melting (lb/period) 1,282 12,327 1,644 2,465 1,151 1,151 

Heating (lb/period) 186 1,790 239 358 167 167 

Conditioning (lb/period)* 17,901 — — — — — 

Total salt system commissioning period, tons 

(all phases) 9.7 7.1 0.9 1.4 0.7 0.7 

*Conditioning emissions represent post-control emissions; this process would be unnecessary with ultralow magnesium 

impurity salts. 

lb/period = pound(s) per duration of the commissioning activities

The greenhouse gas emissions resulting from the salt commissioning process are presented in Table 4-

12. Salt commissioning activities would result in direct greenhouse gas emissions associated with 

combustion of propane in the salt heaters and indirect greenhouse gas emissions associated with 

electricity necessary to maintain the hot salt tank temperature during the conditioning period. 

Greenhouse gas emissions from propane combustion in the salt heaters were estimated using emission 

factors from Nevada’s draft Greenhouse Gas Emissions Mandatory Reporter Monitoring Guidelines 

(2008b). Indirect greenhouse gas emissions from electricity used to maintain salt temperature were 

estimated using emission factors from the CCAR (2009) General Reporting Protocol. Since the draft 

guidance for greenhouse gas emissions by the CEQ is currently under review, the greenhouse gas 

emissions are presented here for informational purposes only at this time, and no conclusions regarding 

significance are presented. 

Table 4-12. Nonrecurring greenhouse gas emission estimates for salt commissioning activities

Greenhouse Gas Emissions (metric tons)

CO2 CH4 N2O CO2 Equivalent

Total 12,442 0.24 0.03 12,458 

4.6.2.2 Commissioning (Plant-Wide) Phase

The power block commissioning phase of the project would involve the steam blows and steam turbine 

startup activities. This phase of commissioning is expected to take place during the final months of 

construction and would follow the salt commissioning activities. The power block commissioning 

activities would not involve in any combustion of fossil fuels. As a result, no emissions of air pollutants 

would occur during the power block commissioning phase.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-59

4.6.2.3 Operational Phase

Criteria Emission Estimates

The proposed project is based on concentrating solar-thermal power technology, which uses reflecting 

mirrors, called heliostats, to redirect sunlight onto a receiver on top of a tower near the center of the 

solar field. Liquid salt would be heated as it passes through the receiver and would be stored and 

circulated through a series of heat exchangers to generate high-pressure superheated steam. The steam 

would then be used to power an STG at conventional temperatures and pressures to produce electricity. 

The steam from the STG would be condensed using a steam condensing system and returned via 

feedwater pumps to the heat exchangers where the high-pressure superheated steam would be 

regenerated.

The plant is designed to capture available solar energy whenever the sun is not obscured by dense cloud 

cover. The thermal storage system would be sized so that the receiver and collector systems would be 

able to capture solar energy during the day and store the energy for use during hours with intermittent 

cloud cover or during evening hours when electric demand is still high. During off-generation hours, 

electricity would be back-fed from the power grid to maintain the hot salt tank temperature and 

balance-of-plant systems in a standby state. No fossil fuel-based combustion is proposed for the power 

generation process of this project. As a result, no criteria pollutant or HAP emissions would be

generated from normal electrical generating operations or system start-up and shut-down events. 

Although the solar-thermal power generation would not consume fossil fuels, the project prescribes two 

diesel-powered emergency generators and two diesel-powered emergency fire pumps. These units would 

be strictly for emergency response and would not normally be in operation. Additionally, these shopassembled, skid-mounted modular units would be certified to EPA standards for engines of their 

respective application.

The primary function of the emergency generators would be to provide relatively instantaneous backup 

power needed to redirect the heliostat field flux off the solar receiver during loss of liquid salt flow 

emergencies. The emergency generators are approximately 4,000 brake-horsepower each and would be 

activated in test mode once every 2 weeks to meet supplier guarantee and the NFPA and insurance 

carrier requirements on maintenance and testing.

Emissions of NOx, CO, PM10, PM2.5, and SOx from the new diesel-powered emergency generators and 

emergency fire pumps were estimated assuming they would meet the EPA Tier II and Tier III emission 

standards, respectively.

To conserve water use and optimize plant performance, the project Proponent has proposed the use of 

hybrid cooling for the steam cycle. In addition to an air-cooled condenser, the project would implement 

a small water-cooled condenser. The condenser would reject its heat through a cooling tower. This 

cooling tower would also provide cooling to various ancillary heat sources from the power block. The 

cooling tower would have an approximate water recirculation rate of 24,093 gallons per minute and 

would be equipped with a mist elimination system rated at 0.001 percent by weight efficiency. The 

PM10 and PM2.5 emissions from the cooling tower were calculated based on the measured TDS
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-60

concentration in the groundwater. Although the cooling tower may not be required during lowtemperature hours, the emission estimates were conservatively based on a 50 percent annual capacity 

factor (i.e., 4,400 hours).

Annual criteria pollutant emissions for the operational phase of the plant are presented in Table 4-13.

The emergency diesel engine emissions are based on 60 minutes of maintenance testing once every 

2 weeks. The diesel-driven fire pumps emissions were based on 30 minutes of weekly testing. The 

annual cooling tower emissions were conservatively based on 4,400 hours of operation per year at a 

conservative 10 cycles of concentration. 

Table 4-13. Annual criteria pollutant emissions from on-site stationary sources during the operation 

phase 

Emission Source NOx SO2 VOC CO PM10/ 

PM2.5

Maximum Annual Emissions, lbs/yeara

Emergency generator (Unit 1) 1,174 1.17 23.1 145 6.9 

Emergency generator (Unit 2) 1,174 1.17 23.1 145 6.9 

Emergency fire pump (Unit 1) 99 0.17 1.6 19 3.6 

Emergency fire pump (Unit 2) 99 0.17 1.6 19 3.6 

Cooling tower — — — — 3,925 

Total Project (lb/yr) 2,546 2.7 49.4 328 3,946 

Total Project (tpy) 1.27 0.001 0.02 0.16 1.97 a Annual emissions are based on 26 hours of testing per unit. See Appendix 4.7-B.

Notes:

lb/year = pound(s) per year

tpy = ton(s) per year

Indirect criteria pollutant emissions from worker commutes, trucks used to wash the heliostats, and 

material deliveries were also calculated. These emissions are presented in Table 4-14. Exhaust 

emissions were estimated using emission factors from EMFAC2007 (version 2.3) database. Fugitive dust 

emissions from paved and unpaved roads were estimated using EPA-approved emission factors and 

methodology published in AP-42 (EPA 2006). Detailed calculations are included in the Air Emissions 

Sources and Inventory Report (Solar Reserve 2010). 

Table 4-14. Annual criteria pollutant emissions from worker commute, heliostat washing, and 

deliveries during operation

Emission Source

Emissions (lb/yr)

VOC CO NOx SOx PM10 PM2.5

Worker commute 137 5,407 587 9 803 240 

Trucks used for 

heliostat washing 155 257 575 1 10,160 1,040 

Material deliveries 111 507 2,195 4 155 98 

Total (lb/yr) 403 6,171 3,357 13 11,118 1,378 

Total (tpy) 0.2 3.1 1.7 0.01 5.6 0.7 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-61

Greenhouse Gas Emission Estimates

Combustion of diesel fuel in the emergency fire pump engines and the emergency generators during 

weekly and biweekly testing would result in emissions of CO2, CH4, and N2O. Greenhouse gas emissions 

for normal facility operations were calculated based on the maximum fuel use predicted for the project 

and emission factors contained in the Nevada Greenhouse Gas Emissions Mandatory Reporter 

Monitoring Guidelines (2008). The emission factors used to estimate the greenhouse gas emissions are 

summarized in the Air Emissions Sources and Inventory Report (Solar Reserve 2010). Emissions of CO2, 

CH4, and N2O resulting from operation of the proposed project are presented in Table 4-15. 

Table 4-15. Annual greenhouse gas emissions from on-site stationary sources

Emission Source 

Estimated Emissions (metric tons/year)

CO2 CH4 N2O CO2

Equivalent

Emergency generator (Unit 1) 45.7 0.039 0.008 49 

Emergency generator (Unit 2) 45.7 0.039 0.008 49 

Emergency fire pump (Unit 1) 8.3 0.0003 0.0001 8 

Emergency fire pump (Unit 2) 8.3 0.0003 0.0001 8 

Total emissions 108 0.079 0.016 114 

Notes: CO2 = carbon dioxide, CH4 = methane, N2O = nitrous oxide

Indirect greenhouse gas emissions from worker commutes, the trucks used to wash the heliostats, and 

material deliveries were calculated as part of the analysis. The greenhouse gas emissions are presented 

in Table 4-16. Emissions were estimated using emission factors from the CCAR General Reporting 

Protocol (version 3.1). Detailed calculations are included in the Air Emissions Sources and Inventory 

Report (Solar Reserve 2010). 

Table 4-16. Annual greenhouse gas emissions from worker commute, heliostat washing, and 

deliveries during operation

Emission Source

Greenhouse Gas Emissions (metric tons/year)

CO2 CH4 N2O CO2 

Equivalent

Worker commute 635 0.019 0.01 640 

Trucks used to wash 

heliostats 16 0.0005 0.0005 16 

Material deliveries 172 0.005 0.005 172 

Total emissions 823 0.025 0.016 828 

Notes: CO2 = carbon dioxide, CH4 = methane, N2O = nitrous oxide

4.6.3 Air Quality Conformity Assessment

The Clean Air Act General Conformity Requirements for the NEPA process provide the following 

conformity review steps.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-62

1. Determine whether criteria pollutants or their precursors would be emitted from the proposed 

project. 

2. Determine whether emissions of criteria pollutants or precursors would occur in a nonattainment or 

maintenance area. 

3. Determine whether the proposed project is exempt from conformity determination. 

4. Estimate emissions and compare to the threshold emissions and the nonattainment or maintenance 

area’s emissions inventory.

As discussed in the previous sections, there are criteria pollutants and precursors emissions associated 

with the construction and operation of the proposed project. However, as stated in the environmental 

setting section and the EPA’s Green Book (2010) on Nye County, the proposed project is located in a 

region currently classified as being in attainment for all pollutants. In accordance with the second step 

of the conformity determination process, the project would, therefore, be deemed in conformance with 

the national air quality goals and objectives.

In the highly unlikely event that the attainment status for the region changes any of the pollutants in the 

near future to a level immediately higher (i.e., “from attainment to maintenance status”), the following 

tables provide a comparison of the project emissions to the conformity threshold for each pollutant. 

Table 4-17 summarizes emission from the construction phase, which includes the salt commissioning 

activities. Table 4-18 shows the emission estimates for the project when the plant is in steady state 

operation. As stated in the previous section, emission associated with indirect vehicular sources include 

daily site employee commute, third-party trips to the plant, and wash trucks that travel in the heliostat 

field.

As shown in these tables, the estimated project emissions for each phase and activity are well below the 

conformity thresholds. A review of the emission inventory for Nye County through the EPA AirData 

database suggests that the estimated project emissions would be well below the 10 percent mark of the 

regional total emission inventory.

Table 4-17. Air quality conformity determination for project construction phase 

Pollutant

Construction Phase Emissions (tons/year)

On-site 

Construction

Off-site 

Construction

Off-site 

Vehicle

Salt 

Commissioning

Conformance 

Thresholdsa

Clean Air Act 

Conformance

VOC 3.0 2.9 0.3 0.9 100 Yes

CO 14.0 15.5 1.7 7.1 100 Yes

NOX 26.1 5.8 2.9 9.7 100 Yes

SOX 0.03 0.02 0.004 1.4 100 Yes

PM10 28.4 7.6 2.3 0.7 100 Yes

a Conformance thresholds are for areas classified with “maintenance” requirement status. This is conservative because

the project area has met attainment status for all pollutants.

Notes: CO = carbon monoxide, NOx = oxide of nitrogen, SOx = oxide of sulfur, PM10 = particulate matter, VOC = 

volatile organic compound
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-63

Table 4-18. Air quality conformity determination for project operation phase

Pollutant

Operation Phase (tons/year)

On-site Stationary 

Sources

On-site/Off-site 

Vehicle Sources

Conformance 

Thresholdsa

Clean Air Act 

Conformance

VOC 0.02 0.2 100 Yes

CO 0.16 3.1 100 Yes

NOX 1.27 1.7 100 Yes

SOX 0.00 0.01 100 Yes

PM10 1.97 5.6 100 Yes

a Conformance thresholds are for areas classified with “maintenance” requirement status. This is conservative 

because the project area has met attainment status for all pollutants.

Notes: CO = carbon monoxide, NOx = oxide of nitrogen, SOx = oxide of sulfur, PM10 = particulate matter, VOC = 

volatile organic compound

4.6.3.1 Regional Conformity

In addition to federal air quality conformity, the proposed project will also meet state and regional air 

quality goals and objectives. Nevada implements these goals and objectives through it state 

implementation plan, which consists of air pollution strategies, state statutes, rules, and local 

ordinances. In its implementation plan, Nevada provides for three areas jurisdictions: the NDEP through 

the BAQP and Air Pollution Control; Clark County, which encompasses Las Vegas; and Washoe County, 

which covers the Reno-Sparks metropolitan area. The proposed project is neither in Clark nor Washoe 

counties; in addition, as an electric generating facility, the project would be under the jurisdiction of 

NDEP.

Prior to the start of construction, the project Proponent will have submitted the necessary permit 

applications to BAQP of NDEP and obtained the necessary permits to construct. In this process, the 

project Proponent will have to demonstrate compliance with all applicable codes and regulations. The 

BAQP will also perform the necessary compliance determination, which will include best available 

control technology and the necessary modeling to demonstrate compliance with ambient air quality 

standards. The issuance of the permit would constitute conformance to state and regional air quality 

requirements.

Based on the sources and emission estimates provided in the previous subsections, it appears that the 

facility would qualify for BAQP’s Class 2 operating permits status. These permits are typically provided 

for facilities that emit less than 100 tons per year for any one regulated pollutants. This category 

appears to be consistent with the federal air quality conformity thresholds. Based on the information 

provided above, key conditions anticipated for these permits would include but not be limited to:

• The temporary salt melter and heater shall be equipped with low NOx burner and flue gas 

recirculation. 

• Emissions resulting from the oxidation of magnesium impurity in the salt during the salt 

conditioning process shall be controlled, unless the project is able to locate an ultralow 

magnesium salt that renders the salt conditioning process unnecessary.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-64

• The project shall equip the cooling tower with a mist elimination system that has an efficiency 

rating of 0.001 percent by weight.

• Emergency diesel-fired equipment shall be certified to meet applicable EPA emission standards 

for the respective class of equipment.

In addition, the project will apply for and obtain a Surface Area Disturbance permit from the bureau 

because the expected area of disturbance will exceed 5 acres. Consistent with the project intent and as 

required for the Surface Area Disturbance permit, a dust control plan will be filed with and approved by 

the NDEP-BACP. Key conditions of the permit would include but not limited to:

• Provide grid construction power to the site as soon as possible to minimize the use of portable 

diesel-powered generators during construction.

• Limit traffic speeds on unpaved roads to 15 miles per hour.

• Water all active construction areas twice daily.

• Use ultralow sulfur diesel for the construction fleet of vehicle and equipment.

• Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at 

least 2 feet of freeboard.

• Apply a nontoxic soil stabilizer on all unpaved access roads, parking areas, and staging areas at 

the construction site.

• Sweep daily, with water sweepers, all paved access roads, parking areas, and staging areas at 

the construction site.

• Enclose, cover, water daily, or apply a nontoxic soil binder to exposed stockpiles of soil, sand, or 

similar materials.

4.6.4 Alternatives and Cumulative Effects Analysis 

The air quality impact evaluation discussed in this section includes the construction and operational 

phases of the plant from both on-site and off-site sources, the construction of the TL, and the operation 

of the borrow pit. Since there are no other known projects in the project vicinity, this evaluation also 

represents the cumulative effect analysis. Also, because the operational and construction emissions 

would be the same for the Proposed Action and the two other alternatives (Alternatives 1 and 2), the air 

quality evaluation under the Proposed Action applies to the two alternatives.

4.6.5 Summary of Impact Analysis 

A thorough review of the construction activities and the operational phase of the proposed plant 

suggest that the associated emissions would be within established federal, state, and regional 

thresholds. Furthermore, the proposed project is located in a region that EPA has categorized as an 

attainment area for all regulated pollutants. As such, the proposed project with all its proposed emission 

control strategies is not expected to cause a violation of established air quality standards and would

conform to federal air quality goals and objectives. Through the permit application process with NDEPBAPC, the proposed project would also conform to regional air quality requirements and objectives. The 

proposed project would have less-than-significant mitigated air quality impacts.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-65

4.7 Cultural Resources

This section evaluates the effects of project construction and operation that the Proposed Action, 

Alternative 1, Alternative 2, the TL and substation, and the borrow pit may have on existing cultural 

resources. Also considered are the effects of the No Action Alternative. Subsection 4.7.6 presents the 

summary of impacts. Finally, Subsection 4.7.7 discusses proposed measures to avoid, reduce, or mitigate 

adverse effects to cultural resources. The evaluation focuses solely on the historic properties identified 

in Chapter 3.

4.7.1 Methods 

Methods employed to identify historic properties for this analysis included preparing a Class I literature 

review, undertaking a Class III cultural resources survey, and conducting a TCP study. The literature 

review consulted site and survey records obtained from the BLM TFO in Tonopah, Nevada; the online 

NVCRIS; GLO plat maps and historic topographic and other maps accessed at the University of Nevada, 

Reno, Mary B. Ansari Map Library; and the Nevada Bureau of Mining and Geology Web site. The Class III 

survey was performed by archaeologists walking parallel, pedestrian, systematically spaced transects 

and documenting their findings through notation, photography, and collection of GIS data for all cultural 

resources encountered during fieldwork. 

4.7.2 Proposed Action 

4.7.2.1 Construction

Direct Effects

Construction would have direct effects on four existing properties recommended eligible for listing on 

the NRHP: CrNV-62-14707, 14718, 14731, and 14734. Possible direct effects would be surface or 

subsurface disturbances caused by construction activities. Unanticipated discoveries encountered 

during construction could also result in direct effects to unknown historic properties within the 

Proposed Action.

Indirect Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no indirect impacts are associated with construction of the project. 

4.7.2.2 Operation

Direct Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no direct impacts are associated with operation of the project. Undiscovered historic properties could 

be directly affected by operation of the facility. 

Indirect Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no indirect impacts are associated with operation of the project. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-66

4.7.3 Alternative 1

4.7.3.1 Construction

Direct Effects

Construction would have direct effects on one existing historic property: CrNV-61-14853. Unanticipated 

discoveries encountered during construction could also result in direct effects to unknown historic 

properties within Alternative 1.

Indirect Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no indirect impacts are associated with construction of the project. 

4.7.3.2 Operation

Direct Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no direct impacts are associated with operation of the project. Undiscovered historic properties could 

also be directly affected by operation of the facility. 

Indirect Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no indirect impacts are associated with operation of the project. 

4.7.4 Alternative 2

4.7.4.1 Construction

Direct Effects

Construction of Alternative 2 would result in direct effects to eight known historic properties: CrNV-61-

14824, 14830, 14864, 14867, 14877, 14881, 14888, and 14893. Construction could also result in direct 

effects to unanticipated discoveries.

Indirect Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no indirect impacts are associated with construction of the project. 

4.7.4.2 Operation

Direct Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no direct impacts are associated with operation of the project. Undiscovered historic properties could 

also be directly affected by operation. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-67

Indirect Effects

Any existing property eligible for listing on the NRHP would be salvaged prior to construction; therefore, 

no indirect impacts are associated operation of the project. 

4.7.5 TL and Anaconda-Moly Substation Corridor 

4.7.5.1 Construction

Direct Effects

No historic properties are known to be present within the boundaries of the TL and substation. Direct 

effects are not likely to occur; however, discovery of unanticipated finds during construction could result 

in direct effects to unknown historic properties.

Indirect Effects

No historic properties are known to be present within the boundaries of the TL and substation; 

therefore, indirect effects are not likely to occur.

4.7.5.2 Operation

Direct Effects

No direct effects to historic properties are likely to occur as a result of the operation of the TL and 

substation.

Indirect Effects

No indirect effects to historic properties are likely to occur as a result of the operation of the TL and 

substation.

4.7.6 Borrow Pit

The following subsections summarize the impacts of construction and operation of the borrow pit 

together because the borrow pit would be open only until the completion of construction of the 

generation facility. 

4.7.6.1 Direct Effects

No historic properties are known to be present within the boundaries of the borrow pit. Direct effects to 

historic properties are not likely to occur; however, discovery of unanticipated finds during construction 

could result in direct effects to as yet unknown historic properties.

4.7.6.2 Indirect Effects

No historic properties are present within the boundaries of the borrow pit; therefore, no indirect effects 

are likely to occur.

4.7.7 No Action Alternative

The No Action Alternative would have no project-related impacts—direct or indirect—to cultural 

resources.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-68

4.7.8 Summary of Impacts 

Development of the Proposed Action would affect four historic properties. Eight historic properties 

would be affected by Alternative 2. Only one known historic property would be affected by Alternative 

1. No impacts are likely to occur for the TL and substation or the borrow pit. Unanticipated discoveries 

during project construction could result in impacts to currently unidentified historic properties for any of 

the alternatives as well as for the TL and substation or borrow pit.

4.7.9 Mitigation

Further archaeological data collection would be needed to mitigate the adverse impacts to historic 

properties. A Historic Property Treatment Plan (HPTP) will be developed. The HPTP lists all historic 

properties to be adversely affected by the project and specify and describe in detail the mitigation 

measures—site avoidance, testing, data recovery, or monitoring—to be implemented prior to and/or 

during construction, including the management and protocol of any unanticipated discoveries.

4.8 Native American Religious Concerns

This section evaluates direct and indirect effects of project construction and operation that the 

Proposed Action, Alternative 1, Alternative 2, the TL and substation, and the borrow pit may have on 

Native American religious concerns (traditional and cultural sites, activities, resources).

To date, no specific prehistoric, ethnohistoric, or contemporary traditional and cultural resources, sites, 

or associated activities have been identified by tribal participants. However, considering that Native 

American consultation is ongoing, opportunities still exist to participate and identify concerns. Thus, 

specific direct and indirect impacts are not definitive at this time. 

Possible impacts to tribal resources will be analyzed in a general sense, given current tribal input and the 

possibility of new and inadvertent discoveries, and will apply to the construction and operation of the 

Proposed Action, Alternative 1, Alternative 2, the TL and substation, and the borrow pit.

For cultural resources, treatment plan development and subsequent data recovery (excavation) of 

identified prehistoric or ethnohistoric archaeological sites are considered an acceptable mitigation 

measure. However, with regard to Native American religious concerns and to the tribes, proposed 

“mitigation” is often considered an adverse impact to tribal beliefs, customs, and traditional and cultural 

lifeways. 

As stated earlier under Chapter 3, in Section 3.9.4.2, tribal participants have provided input on the 

following concerns: potential impacts to water sources and avoidance of identified cultural resources, 

further tribal participation (monitor or observer opportunities) during implementation of a cultural 

resources treatment plan (data recovery) or during new surface disturbance associated with 

construction activities, general concerns about possible impacts to older sites along the “old lakeshore” 

or within the dunes (Crescent Dunes), maintenance of existing access routes, and archaeological site 

inspections (BLM Cultural Resources Specialist accompanied by a tribal representative) to ensure 

construction activities do not degrade sites identified for avoidance.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-69

4.8.1 Methods 

Methods used to identify tribal concerns—which include traditional and cultural sites, activities, and 

resources—were: reviewing existing ethnographic literature and census records, providing to tribal 

entities the services of an ethnographer, conducting a Class I literature review and undertaking a Class III 

cultural resources survey, participating in (and continuing to provide opportunities for) site visits with 

participating tribal entities, conducting follow-up communications (by phone and e-mail), and 

conducting briefings and follow-up meetings.

4.8.2 No Action Alternative

The No Action Alternative would have no project-related impacts—direct or indirect—to Native 

American religious concerns.

4.8.3 Summary of Impacts 

At this time, given the known and provided information, there exists some potential (not definitive) to 

affect project area specific archaeological sites and associated artifacts of concern. Potential impacts 

could occur because of cultural resources treatment plan implementation and the lack of avoidance of 

prehistoric and/or ethnohistoric archaeological sites. Based on previous consultations, historic sites 

appear to be of little concern, unless they are associated with specific family histories and ancestral 

habitations (i.e., homesteads located on turn-of-the-century allotment lands).

Considering that some impacts may not be known until after (or during) project development (i.e., 

inadvertent discovery of previously unidentifiable subsurface deposits) and the fact that consultation is 

ongoing, specific resource identification and subsequent determinations of impacts are not conclusive.

4.9 Land Use and Access

This section describes the potential impacts of construction and operation of the proposed project on 

land use and access in the area of analysis and CESA as described in Section 3.8.

4.9.1 Methods 

The impact analysis for the land use and access areas was based on review of the existing conditions (as 

described in Section 3.8) and focuses on the following issues: 

• conformity of the proposed project with federal and local land use plans, ordinances, and 

policies

• the potential for the proposed project to have direct and/or indirect land use and access 

conflicts with existing and planned uses

Project construction and operation would be considered to have an impact on land use and access if 

they would:

• permanently preclude a permitted or current land use over a substantial area
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-70

• permanently displace existing, developing, or approved urban/industrial buildings or activities 

over a substantial area (i.e., residential, commercial, industrial, governmental, or institutional)

• conflict with an existing ROW

• substantially conflict with applicable general and regional plans and/or approved or adopted 

policies, goals, or operations of communities or governmental agencies

4.9.2 Proposed Action 

4.9.2.1 Construction

Direct Effects

The Proposed Action would have long-term direct impacts on potential uses of BLM-administered land 

within the analysis area by removing approximately 1,500 acres of lands from potential public use or 

disposal for the duration of the lease. Table 4-1 summarizes the amount of permanent land disturbance 

that would be associated with the project’s construction. 

The Proposed Action would have no direct effects to the authorized and pending BLM rights-of-way 

identified in Table 3-21 and presented in Figure 3-11. The meteorological tower is associated with this 

project and would remain if this project is developed. 

The project would directly affect the grazing allotment by reducing the grazing potential, but only 

slightly. This impact is further summarized in Section 4.14 and Table 4-26. 

The Proposed Action would have no direct effects on the restrictions on off-highway vehicles and would 

have minor effects on recreation uses established in the area, which are summarized in Section 4.15. 

The Proposed Action would not affect the mineral leasing restrictions (no surface occupancy) adjacent 

to the project area. 

The Proposed Action would not affect the intended use of the BLM-designated adjacent utility corridor. 

The Proposed Action is within the U.S. Department of Defense Airspace Consultation Area, and could 

directly affect airspace use in the area. The U.S. Navy has expressed concerns about the potential 

impacts of this site on infrequent flights through this region; however, the FAA reviewed the proposed 

location and concluded the Proposed Action posed no hazard to aviation in the area. The FAA 

determined (FAA 2010b): 

"... that the structure would have no substantial adverse effect on the safe and efficient 

utilization of the navigable airspace by aircraft or on the operation of air navigation facilities.

Therefore, pursuant to the authority delegated to me, it is hereby determined that the structure 

would not be a hazard to air navigation provided the following condition(s) is (are) met:

As a condition to this Determination, the structure is marked and/or lighted in 

accordance with FAA Advisory circular 70/7460-1 K Change 2, Obstruction Marking and 

Lighting, 24-hr hi-strobes - Chapters 4,7(HIWOL),&12."
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-71

The U.S. Air Force has indicated that this location would affect instrumentation in the region that is used 

in training activities on the Nevada Test and Training Range located southeast of the project area. 

The use of Crescent Dunes Road would not be affected by the proposed project. The proposed project 

would result in the loss of access to the lands within the proposed project area, but would not otherwise 

minimize or prevent access to the adjacent areas or the region. 

The Proposed Action is within the boundary of the Nye County Planning Area mapped as federal lands; 

however, land requested under the Proponent’s ROW application is entirely under the jurisdiction of the 

BLM TFO. No residential, commercial, industrial, or institutional uses are located within the analysis 

area, so no effects on such uses would result from the project. 

The Proposed Action is consistent with the policies, goals, objectives, and land use descriptions set forth 

in the Nye County Comprehensive Plan and the BLM Tonopah Resource Management Plan. 

Indirect Effects

The proposed project is not likely to have indirect effects on the potential land use on or access to public 

lands in the region.

4.9.2.2 Operation

Direct Effects

Any direct effects to land use or access would occur during construction activities as identified above,

and would continue during the operation of the facility. 

Indirect Effects

No indirect effects to land use or access are likely to occur with operation of the proposed project. 

4.9.3 Alternative 1

4.9.3.1 Construction

Direct Effects

Many of the impacts to land use and access described for the Proposed Action would be the same for 

Alternative 1. However, Alternative 1 is not consistent with several of the policies, goals, objectives, and 

land use descriptions set forth in BLM’s Tonopah Resource Management Plan. 

As with the Proposed Action, Alternative 1 would have long-term direct impacts on potential uses of 

BLM-administered land within the analysis area by removing approximately 1,504 acres of lands from 

potential public use or disposal for the duration of the lease. Table 4-1 summarizes the amount of 

permanent land disturbance that would be associated with the project’s construction. 

As with the Proposed Action, Alternative 1 would have no direct effects to the authorized and pending 

BLM rights-of-way identified in Table 3-21 and presented in Figure 3-11. The meteorological tower is 

associated with this project and would remain if this project is developed. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-72

As with the Proposed Action, Alternative 1 would directly affect the grazing allotment by reducing the 

grazing potential, but only slightly. This impact is further summarized in Section 4.14 and Table 4-26. 

Unlike the Proposed Action, Alternative 1 would directly affect approximately 130 acres of the ROW

avoidance area that is established for protection of the Crescent Dunes, and is in direct conflict with the 

intent of that set-aside. This impact is further summarized in Section 4.15. 

The proposed project would have no direct effects on the restrictions on off-highway vehicles and 

recreation uses established in the area, which are summarized in Section 4.15. However, Alternative 1 

overlaps a portion of the SRMA that encompasses the Crescent Dunes area. Construction and fencing of 

the facility would exclude use of a portion of that area, reducing potential recreational use. 

Alternative 1 would encroach on an area designated with mineral leasing restrictions (no surface 

occupancy) on the eastern side of the project area. Structures would be established within the restricted 

area, in direct conflict with the intended protections. 

Alternative 1 would not affect the intended use of the BLM-designated adjacent utility corridor. 

As with the Proposed Action, Alternative 1 is within the U.S. Department of Defense Airspace 

Consultation Area, and could directly affect airspace use in the area. The U.S. Navy has expressed 

concerns about the potential impacts of this site on infrequent flights through this region; however, the 

FAA reviewed the proposed location and concluded the proposed project posed no hazard to aviation in 

the area (FAA 2010c). The U.S. Air Force has indicated that this location would not affect 

instrumentation in the region that is used in training activities on the Nevada Test and Training Range 

located southeast of the project area. 

The use of Crescent Dunes Road would not be affected by Alternative 1. The proposed project would 

result in the loss of access to the lands within the proposed project area, but would not otherwise 

minimize or prevent access to the adjacent areas or the region. 

Alternative 1 is within the boundary of the Nye County Planning Area mapped as federal lands; however, 

land requested under the Proponent’s ROW application is entirely under the jurisdiction of the BLM 

TFO. No residential, commercial, industrial, or institutional uses are located within the analysis area, so 

no effects on such uses would result from the project. 

Indirect Effects

No indirect effects to land use or access are likely to occur with operation of the proposed project. 

4.9.3.2 Operation

Direct Effects

Any direct effects to land use would occur during construction activities as identified previously, so no 

additional direct effects to land use are likely to occur during operation or maintenance of the facility.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-73

Indirect Effects

No indirect effects to land use or access are likely to occur with operation of the proposed project. 

4.9.4 Alternative 2

4.9.4.1 Construction

Direct Effects

Many of the impacts to land use and access described for the Proposed Action would be the same for 

Alternative 2. Alternative 2 is consistent with several of the policies, goals, objectives, and land use 

descriptions set forth in the BLM Tonopah Resource Management Plan. 

As with the Proposed Action, Alternative 2 would have long-term direct impacts on potential uses of 

BLM-administered land within the analysis area by removing approximately 1,504 acres of lands from 

potential public use or disposal for the duration of the lease. Table 4-1 summarizes the amount of 

permanent land disturbance that would be associated with the project’s construction. 

As with the Proposed Action, Alternative 2 would have no direct effects to the authorized and pending 

BLM rights-of-way identified in Table 3-21 and presented in Figure 3-11. The meteorological tower is 

associated with this project and would remain if this project were developed. 

As with the Proposed Action, Alternative 2 would directly affect the grazing allotment by reducing the 

grazing potential, but only slightly. This impact is further summarized in Section 4.14 and Table 4-26. 

As with the Proposed Action, Alternative 2 would not affect the ROW avoidance area that is established 

for protection of the Crescent Dunes located east of the project area. 

The proposed project would have no direct effects on the restrictions on off-highway vehicles and 

recreation uses established in the area, which are summarized in Section 4.15. Alternative 2 would not 

affect the SRMA that encompasses the Crescent Dunes area. 

Alternative 2 would not affect the area designated with mineral leasing restrictions (no surface 

occupancy) east of the project area. 

Alternative 2 would not affect the intended use of the BLM-designated adjacent utility corridor. 

As with the Proposed Action, Alternative 2 is within the U.S. Department of Defense Airspace 

Consultation Area, and could directly affect airspace use in the area. However, the FAA reviewed the 

proposed location and concluded the proposed location posed no hazard to aviation in the area (FAA 

2010d). No objections were noted in the declaration from FAA. 

The use of Crescent Dunes Road would not be affected by Alternative 2. The proposed project would 

result in the loss of access to the lands within the proposed project area, but would not otherwise 

minimize or prevent access to the adjacent areas or the region. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-74

Alternative 2 is within the boundary of the Nye County Planning Area mapped as federal lands; however, 

land requested under the Proponent’s ROW application is entirely under the jurisdiction of the BLM 

TFO. No residential, commercial, industrial, or institutional uses are located within the analysis area, so 

no effects on such uses would result from the project. 

Alternative 2 is consistent with the policies, goals, objectives, and land use descriptions set forth in the 

Nye County Comprehensive Plan and the BLM Tonopah Resource Management Plan. 

Indirect Effects

No indirect effects to land use or access are likely to occur with operation of the proposed project. 

4.9.4.2 Operation

Direct Effects

Any direct effects to land use would occur during construction activities as identified above, so no 

additional direct effects to land use are likely to occur during operation or maintenance of the facility.

Indirect Effects

No indirect effects to land use or access are likely to occur with operation of the proposed project. 

4.9.5 TL and Anaconda-Moly Substation Corridor 

4.9.5.1 Construction

Direct Effects

Impacts to land use and access from the construction of the TL and substation are summarized in this 

subsection. The TL and substation are consistent with the policies, goals, objectives, and land use 

descriptions set forth in the BLM’s Tonopah Resource Management Plan. 

Unlike other components of the project, the proposed TL and substation are within an existing utility 

corridor and, therefore, would have no long-term direct impacts on potential uses of BLM-administered 

land. The new TL would be designed and constructed in accordance with current design standards to 

ensure no interference with the function and safety of the existing line. Table 4-1 summarizes the 

amount of permanent land disturbance that would be associated with construction of the TL. 

The TL and substation would have no direct effects to the authorized and pending BLM rights-of-way 

identified in Table 3-21 and presented in Figure 3-11. 

The TL would have negligible direct effects on the grazing allotment by reducing the grazing potential 

through the loss of a very small amount of forage production potential. This impact is further 

summarized in Section 4.14 and Table 4-26. 

The proposed TL would have no direct effects on the restrictions on off-highway vehicles and recreation 

uses established in the area, which are summarized in Section 4.15. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-75

As with the other portions of the project, the TL and substation are within the U.S. Department of 

Defense Airspace Consultation Area, but fall below the height limitation (200 feet) within which 

consultation is required. Therefore, no impacts to airspace are likely to occur from the TL.

The proposed TL is within the boundary of the Nye County Planning Area mapped as federal lands; 

however, land requested under the Proponent’s ROW application is entirely under the jurisdiction of the 

BLM TFO. No residential, commercial, industrial, or institutional uses are located within the analysis 

area, so no effects on such uses would result from the project. 

The TL and substation are consistent with the policies, goals, objectives, and land use descriptions set 

forth in the Nye County Comprehensive Plan and the BLM’s Tonopah Resource Management Plan. 

Indirect Effects

No indirect impacts of the construction of the TL and substation are likely to occur regarding land use 

and access.

4.9.5.2 Operation

Direct Effects

No direct effects on land use or access as a result of operation of the TL are likely to occur.

Indirect Effects

No indirect effects on land use or access as a result of operation of the TL are likely to occur.

4.9.6 Borrow Pit

Direct Effects

Impacts to land use and access from the construction of the borrow pit are summarized in this 

subsection. The borrow pit is consistent with the policies, goals, objectives, and land use descriptions set 

forth in the BLM Tonopah Resource Management Plan. 

Unlike the other components of the project, the borrow pit would have short-term, but not long-term, 

direct impacts on potential uses of BLM-administered land within the analysis area. The borrow pit 

would be in use only during construction of the proposed project, and then would be recontoured and 

revegetated, making it available for other future uses. Approximately 40 acres of land would be 

removed from short-term potential public use, and then be released sometime in the future (see Table 

4-1). 

The borrow pit would have no direct effects on the authorized and pending BLM rights-of-way adjacent 

to the project that are identified in Table 3-21 and presented in Figure 3-11. 

The borrow pit would have negligible direct effects on the grazing allotment by reducing the grazing 

potential through the loss of only 40 acres of forage production potential. This impact is further 

summarized in Section 4.14 and Table 4-26. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-76

Construction and operation of the borrow pit would have no direct effects on transportation along the 

existing SH 68, which passes through the area proposed for the borrow pit. Some impacts on traffic may 

result because of the construction and hauling vehicles that would use this road to move materials to 

the construction site. These impacts would cease upon completion of the construction of the generation 

facility and the TL. 

The proposed borrow pit is within the boundary of the Nye County Planning Area mapped as federal 

lands; however, land requested under the Proponent’s ROW application is entirely under the jurisdiction 

of the BLM TFO. No residential, commercial, industrial, or institutional uses are located within the 

analysis area, so no effects on such uses would result from the project. 

The borrow pit is consistent with the policies, goals, objectives, and land use descriptions set forth in the 

Nye County Comprehensive Plan and the BLM’s Tonopah Resource Management Plan. 

Indirect Effects

No indirect impacts on land use or access are likely to occur from the proposed borrow pit. 

4.9.7 No Action Alternative

With the No Action Alternative, no project-related impacts to land use or access would occur. The No

Action Alternative is consistent with the policies, goals, objectives, and land use descriptions set forth in 

the Nye County Comprehensive Plan and the BLM’s Tonopah Resource Management Plan. 

4.9.8 Summary of Impacts 

Potential impacts on land use and access from the proposed project and its various components are 

relatively limited. The proposed project and the associated alternatives would not create hazards to air 

traffic according to determinations reached by the FAA. Alternative 1 would encroach on a ROW

avoidance area for recreation (SRMA) and a no surface occupancy area for mining, both associated with 

the Crescent Dunes. Existing rights-of-way, mining claims, and other leases have been identified near or 

within the proposed project, but none of these have been identified as potentially conflicting with the 

project.

4.9.9 Mitigation

No mitigation has been identified as being needed to address impacts on land use or access.

4.10 Soils

4.10.1 Methods 

The detailed study areas for soils at the Crescent Dunes Solar Energy Project (the proposed project) are 

the individual project areas associated with the Proposed Area (encompassing the Proposed Action), 

Alternative Area (a single area that encompasses Alternatives 1 and 2), TL and substation corridor, and 

the borrow pit (Figure 3-1). Soils were identified and mapped for the detailed study areas as stipulated 

by the data adequacy standards. The CESA for soils at the project consists of the area within a 5-mile 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-77

radius of the project areas and proposed facilities (Figure 3-4). Identification and mapping of soils for the 

CESA was not stipulated by the data adequacy standards and was not performed.

The primary source of information for soils was the U.S. Department of Agriculture (USDA) NRCS online 

Web Soil Survey, which was accessed to obtain the soils data presented in this document (NRCS 2009). 

The specific soil survey represented by the data obtained through the Web Soil Survey is the survey of 

the Big Smoky Valley Area, Nevada, Part of Nye County. Information related to the principal soil orders 

and dominant suborders as provided by the BLM in the Data Adequacy Standards is also used.

As used in this section of the EIS, the term “soil” refers to the naturally weathered geologic sediments 

existing in layers or horizons of minerals and/or organic constituents of variable thickness, which differ 

from the geologic parent material (rock) in their morphological, physical, chemical, and mineralogical 

properties as well as their biological characteristics. 

NRCS identifies and delineates soils into units with the objective of separating the landscape into 

segments with similar use and management requirements. Soils within the detailed study areas were 

described based on ten factors stipulated by the Data Adequacy Standards, including soil series name, 

texture, permeability, pH, available water capacity, hydrologic group, wind and water erosion hazard, 

landscape position, depth to bedrock, and suitability as topsoil for reclamation. This information is 

presented separately for each detailed study area in Section 3.9.

For the purpose of this EIS, project construction, operation, and maintenance activities could have direct 

and indirect impacts (effects) to soils if:

• on-site erosion increases

• on-site erosion results in downstream sedimentation

• increased soil compaction occurs

• there is a decrease in the potential or increase in the time period for revegetation or 

reclamation

Construction, operation, and maintenance activities could result in these direct and indirect impacts 

through the following ground-disturbing activities:

• excavation, blading, and/or grading for construction of project structures, buildings, and 

infrastructure

• construction of new roads and improvement of existing access roads

• temporary stockpiling of soil or construction materials and side-casting of soil and vegetation

• use of designated equipment staging areas

• soil compaction and dust

• equipment access through non-sensitive stream channels (defined as streams that do not 

support sensitive species, critical habitat, or woody riparian vegetation)
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4.10.2 Proposed Action 

4.10.2.1 Construction

Direct Effects

Erosion

Construction of the project would result in surface disturbances and removal of vegetation leading to 

increased on-site soil erosion potential. On-site soil loss could increase if disturbed soils were left 

exposed during periods of high precipitation, runoff, and winds.

Compaction

Soils with high clay content and saturated by storm events or by overwatering during dust control are 

susceptible to compaction by vehicles and construction equipment. Compacted soils can resist or delay 

reestablishment of vegetation and success in reclamation objectives.

Indirect Effects

Erosion

Construction of the project could result in surface disturbances and removal of vegetation, leading to 

increased on-site soil erosion. Sedimentation into ephemeral washes located downstream within the 

CESA, or beyond, could increase if disturbed soils were left exposed during periods of high precipitation 

and runoff. Off-site deposition of on-site soil eroded by wind could increase within the CESA, or beyond, 

if disturbed soils were left exposed.

Diminished Reclamation/Revegetation

Loss of topsoil through construction activity or construction-induced erosion, or over-compaction of 

topsoil from construction activity, can delay or reduce reclamation success following decommissioning. 

These conditions, alone or in concert, could make it difficult for native plant species to reestablish. The 

loss of topsoil can make plant establishment more difficult because of unfavorable nutrient level, water 

capacity, or permeability characteristics of surface soil remaining after topsoil loss. Over-compaction of 

soil can resist seed movement into the soil profile, seed germination, and subsequent seedling growth 

through the soil, and movement of water and nutrients into the root zone. These indirect effects are not 

expected to occur off-site within the CESA or beyond.

4.10.2.2 Operation

Direct Effects

Erosion 

Operation of the project is not expected to result in increased on-site soil erosion. 

Compaction 

Operation of the project is not expected to increase soil compaction or resist or delay reestablishment 

of vegetation or success in reclamation objectives.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-79

Indirect Effects

Erosion

Operation of the project is not expected to result in sedimentation into streams and water bodies 

located hydraulically downstream or off-site deposition of on-site soil eroded by wind.

Diminished Reclamation/Revegetation

Operation of the project is not expected to resist or delay reestablishment of vegetation or success in 

reclamation objectives.

4.10.3 Alternative 1

4.10.3.1 Construction

Direct Effects

Direct effects of construction of Alternative 1 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

Indirect Effects

Indirect effects of construction of Alternative 1 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

4.10.3.2 Operation

Direct Effects

Direct effects of operation of Alternative 1 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

Indirect Effects

Indirect effects of operation of Alternative 1 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

4.10.4 Alternative 2

4.10.4.1 Construction

Direct Effects

Direct effects of construction of Alternative 2 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

Indirect Effects

Indirect effects of construction of Alternative2 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

4.10.4.2 Operation

Direct Effects 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-80

Direct effects of operation of Alternative 2 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

Indirect Effects

Indirect effects of operation of Alternative 2 are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

4.10.5 TL and Anaconda-Moly Substation Corridor 

4.10.5.1 Construction

Direct Effects

Direct effects of construction of the TL and Anaconda-Moly substation corridor are anticipated to be 

similar to those described for the Proposed Action because the soils in the areas and the proposed 

activities are similar.

Indirect Effects

Indirect effects of construction of the TL and Anaconda-Moly substation corridor are anticipated to be 

similar to those described for the Proposed Action because the soils in the areas and the proposed 

activities are similar.

4.10.5.2 Operation

Direct Effects

Direct effects of operation of the TL and Anaconda-Moly substation corridor are anticipated to be similar 

to those described for the Proposed Action because the soils in the areas and the proposed activities are 

similar.

Indirect Effects

Indirect effects of operation of the TL and Anaconda-Moly substation corridor are anticipated to be 

similar to those described for the Proposed Action because the soils in the areas and the proposed 

activities are similar.

4.10.6 Borrow Pit

Direct Effects

Direct effects of construction of the borrow pit are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.

Indirect Effects

Indirect effects of construction of the borrow pit are anticipated to be similar to those described for the 

Proposed Action because the soils in the areas and the proposed activities are similar.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-81

4.10.7 No Action Alternative

Under the No Action Alternative, impacts to existing soils resources associated with this project would 

not occur. Soils impacts could occur in other areas if planning efforts pursue other transmission and/or 

generation projects to meet the projected energy shortfalls.

4.10.8 Summary of Impacts 

The potential for direct, indirect, and cumulative impacts associated with construction of the project 

exist. Impacts may include increased erosion, increased soil compaction, and diminished potential for 

revegetation. Direct, indirect, and cumulative impacts associated with operation of the project are not 

expected.

4.10.9 Mitigation

Mitigation of potential direct, indirect, and cumulative impacts are discussed separately below for each 

potential impact identified.

Erosion

The objectives of erosion mitigation are to reduce short-term erosion and sedimentation, as well as 

quickly restore topography and vegetation to preconstruction conditions in all areas required and 

approved by BLM. Measures to be implemented by the project Proponent during project construction 

and reclamation are listed below.

Implementation of the following measures and practices would minimize the effects of grading, 

excavation, and other surface disturbances in all project areas. Schedules and specifications on the use 

of these features would be included in the Construction, Operation, and Maintenance Plan (COM Plan). 

• Confine all vehicular and equipment traffic associated with construction to the construction 

footprint, material yards, and access roads designated in the COM plan.

• Limit soils and vegetation disturbance and removal to the minimum areas necessary for access 

and construction.

• Where vegetation removal is necessary, use cutting/mowing methods instead of blading, 

wherever possible.

• Adhere to a construction methodology that mitigates impacts in sensitive areas during severe 

weather events.

• Prior to work on the project, inform all construction personnel of environmental concerns, 

pertinent laws and regulations, and elements of the erosion control plan.

• Minimize grading to the greatest extent possible. Where required, grading should be conducted 

away from drainages and watercourses to reduce the risk of material entering these features.

• Graded material should be sloped and bermed to reduce surface water flows across the graded 

area.

• Replace excavated materials and minimize the time between excavation and backfilling.

• Direct dewatering operations to stable surfaces to avoid soil erosion.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-82

• Use detention basins, certified weed-free straw bales or wattles, or silt fences where 

appropriate to reduce soil loss from erosion.

• Use drainage control structures including culverts, ditches, water bars (berms and cross ditches), 

and sediment traps, as necessary, to direct surface drainage away from disturbed areas and 

minimize runoff and sedimentation down-slope from all disturbed areas.

• Implement other appropriate BMPs to minimize erosion-related impacts during site preparation 

and construction, and subsequent reclamation.

• Reestablish native vegetation and, if necessary, non-persistent, non-invasive, non-native 

vegetation in highly erodible areas as soon as possible following construction.

In areas of highly erodible soils, construction equipment and techniques that minimize surface 

disturbance, soil compaction, and loss of topsoil would be used, such as vehicles with low ground 

pressure tires. Erosion control measures, in accordance with the Soil Conservation and Erosion Control 

Plan, would be installed prior to construction in potential soil erosion areas. Erodible slopes that do not 

require grading should be cleared using equipment that results in little to no soil disturbance. 

Compaction

Construction, operation, and maintenance activities would be restricted when the soil is too wet to 

support construction or maintenance equipment (i.e., when heavy equipment creates ruts in excess of 4 

inches deep over a distance of 100 feet or more in wet or saturated soils). If soil is too wet, one or more 

of the following measures would apply:

• Where feasible, route all construction or maintenance activities to avoid wet areas as long as 

the route does not enter sensitive resource areas.

• If wet areas cannot be avoided, implement BMPs for use in these areas during construction and 

improvement of access roads, and during subsequent reclamation. Appropriate BMPs include 

use of wide-track or balloon-tire vehicles and equipment, or other approved weight dispersing 

systems, geotextile cushions, pre-fabricated equipment pads, and other materials to minimize 

damage to soil. If BMPs cannot be successfully applied, construction or routine maintenance 

activities would not be allowed in these areas until the project conditions improve and 

construction activity can proceed without damage to soils.

• Limit construction equipment access to the minimum amount feasible, remove and separate 

topsoil in wet or saturated areas, and stabilize subsurface soils with a combination of one or 

more of the following: grading to dewater problem areas, use of weight dispersion mats, and 

erosion control measures such as surface rilling and back-dragging. Following construction, 

regrade and recontour the area, replace topsoil, and reseed to achieve preconstruction native 

plant densities.

Diminished Reclamation/Revegetation

Vegetation removal and soil disturbances (including temporary road improvements) would be 

minimized. Where vegetation removal is required, mowing or cutting methods would be used to the 

greatest extent possible. Topsoil removed during clear and grub activity and grading and excavation 

required for construction would be collected and stockpiled on-site. Stockpiles would be protected from 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-83

wind and water erosion through establishment of native vegetation and temporary or permanent 

erosion control BMPs including weed-free straw bales or wattles for the duration of facility construction, 

operation, and decommission. Following decommission, the stockpiled topsoil would be replaced across 

the site where topsoil was previously removed to provide a proper soil substrate for seeding or planting 

and enhance reestablishment of native vegetation to preconstruction conditions.

4.11 Social and Economics

4.11.1 Methods 

Implementation of any of the action alternatives would have direct and indirect effects on local and 

regional social and economic conditions. These would be the result of temporary (during construction) 

and permanent (during operations) activities. No differences are anticipated in the effects on these 

resources from the different action alternatives. As such, the following sections will not differentiate 

between the action alternatives but, rather, will present all potential effects of any action alternative, as 

well as the effects of the No Action Alternative, cumulative impacts, and proposed mitigation.

The work force will remain the same for any of the alternatives, the TL, substation, and borrow pit, and 

it is concluded that the socioeconomic factors would not change with each of these actions. Therefore, 

the results of the Proposed Action remain the same for each of the other action alternatives. 

4.11.2 Proposed Action 

4.11.2.1 Construction

Direct Effects

Social Conditions

The following subsections contain an analysis of impacts on the local and regional social conditions, 

specifically population and housing, during construction.

Population 

During the anticipated 30-month construction phase, an average of 250 construction personnel would 

be on site, with a peak of 400–500 personnel. Where possible, construction workers would be hired 

from the local and regional workforce. Table 4-19 illustrates the forecast construction industry work 

force in the county and the state.

Table 4-19. County and state construction industry work force

Area 2008 Workforce 2010 Workforce Forecast

Nye County, Nevada 1,571 Not available

Esmeralda County, Nevada 24 Not available

Nevada 116,500 85,895 

Source: Nevada Department of Employment, Training, and Rehabilitation: Nevada Workforce Informer 2010
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-84

If communities of 25,000 or more residents are located within 60–70 miles of the construction site, a 

substantial number of construction workers can be hired within the region (EPRI 1982). The closest 

communities to the project area are shown in Table 4-20, along with the community population and 

approximate travel distance to the project area.

Table 4-20. Communities, population, and travel distance from project site

Community Population Travel Distance

Tonopah, Nevada 2,580 13 

Goldfield, Nevada 441 40 

Silver Peak, Nevada 141 68 

Round Mountain, Nevada 837 70 

Pahrump, Nevada 38,247 180 

Ely, Nevada 4,291 181 

Las Vegas, Nevada 591,422 224 

Reno, Nevada 218,143 251 

Carson City, Nevada 56,506 250 

Source: Nevada State Demographer’s Office, 2009 Estimates by County

With limited opportunities to hire a construction work force in the immediate project area, a substantial 

temporary work force is anticipated. At the peak of construction, the local population could increase by 

20 percent or more. 

Housing

Of the housing units in the project area, approximately one-third are rental properties (City-data.com 

2010). With a projected vacancy rate of 29 percent to 49 percent, it is anticipated that there would be 

approximately 150 rental properties available for temporary workers. Eight hotels/motels are present in 

Tonopah and one in Goldfield. Based on the available information, guest rooms are available at these 

facilities. Accommodations are also available at recreational vehicle facilities, mobile home parks, and 

campgrounds. 

Public Services

Law Enforcement

During construction, security would be provided by on-site personnel and, as needed, the Nye County 

Sheriff’s Department. The on-site guards would be tasked with controlling entering and exiting of 

vehicles and personnel. During off hours, the guards would perform fire and security watch.

Fire and Emergency Medical Services

As a backup to the on-site services, the Tonopah Fire and Emergency Medical Services has 14 emergency 

medical technicians and 3 ambulances, which are backed up by a volunteer hazardous materials team 

from Tonopah and Round Mountain. The Nye Regional Medical Center (Tonopah) is equipped to provide 

immediate medical care and has emergency medical flight services to emergency care units in Las Vegas 

and Reno.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-85

Utilities

Water required for construction and operation of the facility would be acquired from a new 

groundwater well on the project site. No additional water would be required.

Temporary sanitary facilities would be provided at the site, including portable toilets in the construction 

area. A temporary septic system would be installed during the construction phase and would be 

abandoned upon completion of construction.

Schools

Families relocating during construction would reside in existing housing within the communities 

surrounding the project site. The Nye County School District has an established schooling program that 

would accommodate the relocating families.

Economic Conditions and Fiscal Resources

Total expenditures for construction, including materials, supplies, and equipment, of any of the action 

alternatives is anticipated to be between $700 million and $800 million over the 30-month construction 

period. Typically, 250 personnel would be employed, with up to 500 personnel during peak construction 

periods. Similar to personal income, the gross state product for Nevada would experience an increase of 

up to $160 million per year directly or indirectly as a result of construction (Nevada State 

Demographer’s Office 2008).

Indirect Effects

For each construction-related job created by a 100-megawatt solar energy facility, there can be up to 

two additional indirect or induced jobs created during the construction phase. With up to 500 jobs onsite during peak construction, up to 1,000 indirect or induced jobs would be created. This would result in 

an influx of approximately $140 million of personal income in Nevada per year of construction. 

4.11.2.2 Operation

Direct Effects

Social Conditions

The following subsections contain an analysis of impacts on the local and regional social conditions, 

specifically population and housing, during operations. 

Population

As part of the operations, the project Proponent anticipates employing 30 to 40 full-time employees. 

This staff would include engineering and administrative staff, skilled workers, and operators. The facility 

would be operated up to 7 days a week and 24 hours per day. While some of this staff may be hired 

locally, it is anticipated that many of them would relocate to the area from the region or nationally. This 

would result in a potential 2 percent increase in the local population.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-86

Housing

The project area is experiencing a residential vacancy rate of 29 to 49 percent. It is assumed any need 

for permanent housing for operations staff would be accommodated within the existing market. No 

additional housing would be required.

Public Services

Law Enforcement

During operations, security would be provided by on-site personnel and, as needed, by Nye County 

Sheriff’s Department. The on-site guards would be tasked with controlling entering and exiting of 

vehicles and personnel. During off hours, the guards would perform fire and security watch.

Utilities

All water needs at the project site would be accommodated through the use of a new groundwater well 

installed for construction. No additional water sources would be required. 

Schools

Families relocating during construction would reside in existing housing within the communities 

surrounding the project site. The Nye County School District has an established schooling program, 

which would accommodate the relocating families.

Economic Conditions and Fiscal Resources

Throughout the life of the proposed action facility, it is anticipated that up to 50 employees would be 

required to operate and maintain the site. Similar to personal income, the gross state product for 

Nevada would experience an increase of up to $22.7 million per year directly or indirectly as a result of 

operations (Nevada State Demographer’s Office 2008).

Indirect Effects

For each job directly created by the operation and maintenance of the facility, there would be up to 3 

additional indirect or induced jobs created. This would result in an influx of approximately $30 million of 

personal income in Nevada per year of operation.

4.11.3 No Action Alternative

Under the No Action Alternative, the previously described action alternative impacts would not occur. 

However, the land would remain available for use consistent with the existing BLM land use plan, 

including potential other renewable energy projects. Both state and federal law support the increased 

use of renewable power generation because such renewable projects would likely be developed on 

other sites in the region. 

The temporary and permanent impacts associated with identification of an action alternative would not 

occur, including the need for temporary housing, the increase in personal income, and the increase in 

the Nevada gross state product.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-87

4.11.4 Summary of Impacts 

The following subsections summarize the anticipated construction and operation of the project as 

related to socioeconomic impacts.

4.11.4.1 Construction

• While some construction work force is available locally, the majority would relocate to the 

surrounding communities temporarily. This could increase the local population by 20 percent or 

more during the peak of construction, resulting in the need for temporary work force housing. 

• Through direct, indirect, and induced impacts during the peak of construction, approximately 

1,500 jobs would be created, $140 million of personal income would be added to the State of 

Nevada annually, and $160 million would be added to the gross state product annually.

4.11.4.2 Operation and Maintenance

• While some operations and maintenance work force is available locally, the majority would 

relocate to the surrounding communities. This could increase the local population by 2 percent 

or more. However, enough existing residential properties exist to accommodate the relocating 

workforce.

• Through direct, indirect, and induced impacts during operations and maintenance of the facility, 

approximately 200 jobs would be created, $30 million of personal income would be added to 

the State of Nevada annually, and $22.7 million would be added to the gross state product 

annually.

4.11.5 Mitigation

Following are the proposed mitigation measures for the socioeconomic impacts associated with the 

construction and operations/maintenance phases of the proposed project:

• In coordination with the Tonopah Town Board, develop a housing and rental plan to coordinate 

available rental property in and around Tonopah. 

• If available rental properties do not meet needs, work with the Town Board to develop a 

temporary trailer park for relocating work force members in town or at the site. 

4.12 Visual Resources

4.12.1 Methods 

The visual resource analysis discussed in this section followed the BLM VRM system as an objective 

methodology to assess the aesthetic conditions of the landscape, characterize the current viewing 

environment, and evaluate the potential effects of the proposed project on the environment. The 

analysis included an evaluation of existing visual conditions and an impact analysis that considered

viewer sensitivity and visual contrast. Where BLM VRM guidelines do not apply (e.g., non-BLMadministered lands), an inventory of aesthetic conditions was conducted using BLM visual resource 

inventory guidelines to determine public sensitivity toward the introduction of the proposed facilities.
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Viewer Sensitivity

The viewer sensitivity analysis determined the classes of viewers or viewer groups that would 

experience the visual landscape. That is, viewer sensitivity establishes what the visual response is to the 

introduction of the proposed project in the viewshed. 

Viewer sensitivity is influenced by existing topography, vegetation, and urban development or 

structures. Views of the proposed project typically would diminish with distance, topographic or 

landform interference, overgrown vegetation, and other structural impediments. 

Viewer sensitivity was established by evaluating the types of viewers and their proximity to the 

proposed project. Viewer sensitivity is ranked from high to low, with “high” being the most sensitive 

viewing condition (Table 4-21). The viewer sensitivity analysis also considered the frequency, duration, 

and type of viewing conditions. Additionally, viewer sensitivity is affected by viewer activity, awareness, 

perception, and visual expectations.

Table 4-21. Sensitivity ratings for viewer types

Viewer Sensitivity Rating Viewer Type

High Residents within viewing proximity to project

Medium Recreationists within viewing proximity to project

Low Motorists and non-recreational travelers along roadway

Visual Contrast

Visual contrast is the measure of the degree of perceived change that would occur in the landscape 

attributable to potential effects from the proposed project (e.g., construction, use, and maintenance). 

BLM’s visual contrast rating system was used to determine visual effects and identify measures to 

mitigate these effects. The contrast rating form was completed at all KOPs that represent important 

views (HDR 2010). 

Visual Simulations

To indicate the probable visual effects of the proposed action alternatives, computer-aided simulations 

were prepared. These simulations not only represent effects at KOPs, but also broadly represent typical 

views in the project area. These simulations removed elements of the existing conditions and added the 

features of the proposed build alternatives. The purpose of the simulations was to provide a comparison 

of visual changes. Not all potential views were reproduced or simulated. Visual simulations were 

performed based on the determination of sensitivity from these KOPs. The visual simulations provided a 

general depiction of the scale and significance of the solar facility as it would likely appear from the 

selected KOPs. 

Visual Impact Evaluation

The visual impact evaluation determined the degree of change and the viewer response to change after 

the proposed facility is introduced into the environment. All of the previously listed criteria helped to 

determine the level of impact including exposure, viewer sensitivity, simulations, and visual contrast 

ratings. Additionally, other factors helped determine the level of impact for each proposed action
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-89

alternative including the cultural significance and the local values. A visual resource specialist used all 

these factors to assign each proposed action alternative a visual impact level. Visual impact levels, 

definitions, and examples are presented in Table 4-22. 

Effects from the proposed project were considered for both phases of the project, construction and 

operation. Building on the baseline of environmental conditions, the visual contrast rating system and 

viewer sensitivity analysis were applied to each proposed action alternative. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-90

Table 4-22. Visual impact levels defined

Impact 

Level General Definition Definition Specific to Visual Resources Examples 

Major

Effects that potentially 

would cause significant 

change or stress to an 

environmental resource or 

use, or severe adverse or 

exceptional beneficial 

effects 

Visual contrasts resulting from 

construction disturbances and 

the presence of new facilities 

that would substantially alter 

the scenic value of the 

landscape and would dominate 

views from sensitive 

viewpoints

• Structures that significantly impede and 

obstruct scenic views, such as impeding a 

view from a scenic turnout or observation 

point

• Construction that would irrevocably damage 

scenic quality

• Facilities that would be seen in the 

foreground to middleground distance zones 

in previously undisturbed, highly scenic 

landscapes 

Moderate

Effects that potentially 

would cause some change 

or stress to an 

environmental resource or 

use, or readily apparent 

effects to scenic quality

Visual contrasts that would 

diminish the scenic quality of 

the landscape and would easily 

be noticeable from sensitive 

viewpoints

• Vertical structures that may detract from 

existing scenic quality

• Facilities would be visible in the foreground 

to middleground distance zones from 

sensitive viewpoints

• Facilities parallel to highly scenic landscape 

that have not been previously disturbed

Minor Effects that are potentially 

detectable but slight

Visual contrasts that diminish 

the scenic quality of the 

landscape to a minimal degree 

and are potentially noticeable 

when viewed from moderately 

sensitive viewpoints

• Facilities would be visible in middleground or 

background distance zones from moderate 

sensitivity viewpoints, or parallel to existing 

facilities in a previously disturbed landscape, 

or landscapes of common scenic quality

Negligible

Effects that potentially 

cause an insignificant or 

indiscernible change or 

stress to an environmental 

resource or use, effects

range from immeasurable 

and undetectable to low 

levels of detection

Visual contrasts that would not 

diminish the scenic quality of 

the landscape

• Temporarily displacing vegetation while 

maintenance and/or construction occurs

• Facilities would be visible in the background 

distance zone, where new facilities parallel 

existing facilities or traverse previously 

disturbed landscape in landscapes of 

common to minimal scenic quality

None

No discernable or 

measureable effects would 

result

No discernable or measureable 

visual contrast • No project activity would take place

Distance Zones

To establish the impacts of the proposed project on the visual environment, the following distance 

zones (Table 4-23) were used to describe perception thresholds, the scale and nature of the objects 

being viewed, and the viewing environment. The perception of the landscape character, including form, 

line, texture, and color, is among other complex phenomena, largely a function of changing distance 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-91

from a viewing point. Landscape elements tend to become less obvious and less detailed at greater 

distances. Perception of texture and color become less noticeable with increased distance. 

Table 4-23. Distance zones (from BLM 1986a) 

Distance Zone Distance 

(in miles) Summary of Definition

Foreground/Middleground 0 to 5

These areas can be seen from each travel route for a 

distance of 3 to 5 miles where management activities may 

be viewed in detail.

Background 6 to 15

These areas can be seen from each travel route to 

approximately 15 miles. To be included within this 

distance zone, vegetation should be visible at least as 

patterns of light and dark.

Seldom Seen Beyond 15 These areas are beyond the background zones. 

Source: BLM Manual H-8410-1. Visual Resource Inventory. 1986.

4.12.2 Proposed Action 

The landscape in the Proposed Area is generally characterized by flat desert with low-lying desert scrub 

vegetation bounded by high-relief fault-block mountains in the seldom seen distance zone (over 

15 miles away). Landscape in the region appears desolate, that is, devoid of any major cultural 

modification aside from a paved two-lane rural highway and a power line corridor (oriented northeast 

and southwest) that bisects the landscape approximately 3 miles north of the Proposed Area. The colors 

within the landscape are limited to bands of earth tone browns and tans with few other distinguishing 

colors, creating a relatively homogenous appearance. 

The most distinctive natural feature in the area is the Crescent Dunes SRMA. The Crescent Dunes are 

relatively unique because they are smooth, undulating sand dunes that are visible from over 5 miles 

away. 

The closest residences to the Proposed Area are approximately 10 miles away to the south. The 

residential area is on the outskirts of Tonopah, located off of Radar Road. Most of the residences in this 

area are single-family detached homes. Approximately 10 houses (located at a slightly higher elevation) 

currently have views of the Crescent Dunes in the distance and, as such, would have views of the 

Proposed Area. Views from this area may be slightly obstructed by vegetation, topography, and 

distance. 

The Proposed Area is located immediately adjacent to Pole Line Road, which is a paved two-lane 

highway. This road provides access to residences and farmland and the existing Anaconda-Moly 

substation from US 95. Pole Line Road has a very low level of daily traffic. 

Given the special recreation designation of the Crescent Dunes, the area supports some recreational 

activity, although no signs indicating recreational areas are apparent. The Crescent Dunes and the 

surrounding landscape are used by off-highway vehicle recreationists, as evidenced by an extensive 

network of four-wheel-drive trails and staging areas located sporadically throughout the area.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-92

4.12.2.1 Construction

Direct Effects

Visual effects resulting from the construction of the proposed facility are considered short-term and 

would include the implementation of mitigation measures (e.g., dust abatement, phased construction) 

intended to minimize effects to the aesthetic environment. During construction, large equipment, 

vehicles, and materials would be present and visible on the project site. Given that there are no other 

construction activities within the viewshed, the visual effects of construction are likely to be moderate 

for recreationists (with a medium sensitivity rating) and moderate for travelers (with a low sensitivity 

rating) traveling along Pole Line Road. 

Indirect Effects

No indirect effects to visual resources are likely to occur.

4.12.2.2 Operation

Visual simulations were prepared for the Proposed Action at each of the six KOPs. Given the height of 

the central receiver tower and the distance from the project site, the project may be highly visible from 

KOP 1 and KOP 4; moderately visible from KOP 3; and barely visible from KOP 2, KOP 5, and KOP 6. 

Therefore, the visual contrast rating, viewer sensitivity analysis, and visual impact analysis are included 

for only KOP 1, KOP 3, and KOP 4.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-93

KOP 1

Visual Simulation from Crescent Dunes (KOP 1) to the Proposed Action. 

KOP 1 is located on the Crescent Dunes just northeast of the Proposed Action. This KOP was chosen to 

represent views that recreationists would see while using the dunes. From this location, the view is to 

the southwest and looks out over the wide-open valley floor in the foreground and middleground. Low 

shrubs and grasses sparsely cover the valley floor. The Monte Cristo Mountain Range forms a rugged 

horizon line in the background. 

In relation to the surrounding landforms, the Proposed Action would result in a moderate contrast in 

form, line, color, and texture. The tower would be a new structure in the surrounding flat landscape, 

introducing a strong vertical line. The central receiver tower would be approximately 1.5 miles from this 

KOP. At this distance, the tower and surrounding heliostat field would be clearly visible from the dunes. 

Additionally, the Proposed Action would result in a moderate contrast of texture because the solar 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-94

panels would create a repetitive texture on the landscape that would be moderately different from the 

texture of the surrounding landforms. Additionally, at this distance, the tower may appear white, and 

the reflective properties of the heliostats may appear to have a water-like effect on the surrounding 

landscape.

The primary type of viewer in this area is the off-highway vehicle recreationist. Typically, off-highway 

vehicle users are considered to have moderate viewer sensitivity because their primary objective is not 

to view scenic vistas. They often travel at speeds that are not conducive to viewing the landscape. 

However, because this area is undeveloped, recreationists who frequent this area may enjoy the sense 

of isolation from the modern world. For this reason, recreationists in the Crescent Dunes SRMA may be 

more sensitive to changes in the landscape. 

Based on visual contrast, viewer sensitivity, and the KOP distance from the proposed project, the overall 

visual impact rating for the Crescent Dunes SRMA is considered major. This level of change is consistent 

with development of a VRM Class IV landscape, which allows “for major modifications to the existing 

characteristic of the landscapes” (BLM 1986).
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-95

KOP 3

Visual Simulation from the Anaconda-Moly Substation Access Road (KOP 3) to the Proposed Action.

KOP 3 is located at the junction of Pole Line Road and the Anaconda-Moly substation access road, 

approximately 5.6 miles from the Proposed Action. This KOP was chosen to represent the view that 

travelers would have while driving along the Anaconda-Moly mine access road. From this location, the 

project is visible to the southeast and looks over the wide-open valley floor in the foreground and 

middleground. The San Antonio Mountains are visible in the background. The Proposed Action would 

introduce a weak visual contrast for form, line, color, and texture into the viewshed because the central 

receiver tower and surrounding heliostats would barely be discernable from this distance. Viewers in 

this area would likely be commuters. Typically, commuters have a low sensitivity rating because they are 

traveling at high speeds and tend to be focused on the road rather than the surrounding landscape. The 

overall visual impact rating associated with the proposed action is moderate because of the lack of 

sensitive viewers in the area and the distance from the proposed facility.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-96

KOP 4

Visual Simulation from Pole Line Road (KOP 4) to the Proposed Action.

KOP 4 is located at the junction of Pole Line Road and the Crescent Dunes access road, approximately 

1.8 miles from the central tower of the Proposed Action. This KOP was chosen to represent the view 

that travelers would have while driving along Pole Line Road. From this location, the view is to the east 

and looks over the valley. The Crescent Dunes are visible in the foreground and the San Antonio 

Mountains are visible in the middleground. The Proposed Action would introduce a moderate visual 

contrast for form, line, color, and texture because the facilities would be dominant in the foreground. 

Viewers in this area would likely be commuters traveling to work or home. Typically, these viewers 

would be considered low sensitivity viewers because they pass through the area frequently, traveling at 

high speeds, and tend to be focused on the road and not on the surrounding landscape. Based on the 

scenic quality of the area, viewer sensitivity, and the visual contrast evaluation, the visual impact rating 

is considered moderate.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-97

4.12.2.2.1 Indirect Effects

No indirect effects to visual resources are likely to occur.

4.12.3 Alternative 1

4.12.3.1 Construction

Direct Effects

Visual effects resulting from the construction of Alternative 1 would be the same as those presented for 

the Proposed Action.

Indirect Effects

No indirect effects to visual resources are likely to occur.

4.12.3.2 Operation

Visual effects for Alternative 1 would be similar as those for the Proposed Action. Visual simulations for 

KOP 1, KOP 3, and KOP 4 are provided on subsequent pages.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-98

KOP 1

Visual Simulation from the Crescent Dunes (KOP 1) to Alternative 1.

KOP 1 is located on the Crescent Dunes just southeast of Alternative 1. The visual contrast rating, viewer 

sensitivity analysis, distance from the KOP, and the visual impact analysis are the similar to those 

associated with the Proposed Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-99

KOP 3

Visual Simulation from the Anaconda-Moly Substation Access Road (KOP 3) to Alternative 1.

KOP 3 is located approximately 3.8 miles from Alternative 1. Although the Alternative 1 is slightly closer 

to this KOP (approximately 1.8 miles closer), the visual contrast rating, viewer sensitivity analysis, 

distance from the KOP, and the visual impact analysis are similar to those associated with the Proposed 

Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-100

KOP 4

Visual Simulation from Pole Line Road (KOP 4) to Alternative 1.

KOP 4 is located approximately 1.7 miles southwest of the Proposed Action. The visual contrast rating, 

viewer sensitivity, and visual contrast evaluation are the same as those associated with the Proposed 

Action.

Indirect Effects

No indirect effects to visual resources are likely to occur.

Indirect Effects

No indirect effects to visual resources are likely to occur.

4.12.4 Alternative 2

4.12.4.1 Construction

Direct Effects

Visual effects resulting from construction of Alternative 2 would be similar to those presented for the 

Proposed Action.

Indirect Effects

No indirect effects to visual resources are likely to occur.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-101

4.12.4.2 Operation

Visual effects for Alternative 2 would be similar to those associated with the Proposed Action. Visual 

simulations for KOP 1, KOP 3, and KOP 4 are provided below. 

KOP 1

Visual Simulation from the Crescent Dunes (KOP1) to Alternative 2. 

KOP 1 is located on the Crescent Dunes approximately 1.8 southeast of Alternative 2. The visual contrast 

rating, viewer sensitivity analysis, distance from the KOP, and visual impact analysis would be the same 

as those associated with the Proposed Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-102

KOP 3

Visual Simulation from the Anaconda-Moly Substation Access Road (KOP 3) to Alternative 2.

KOP 3 is located approximately 2.9 miles from Alternative 2. Although Alternative 2 would be slightly 

closer to this KOP (approximately 2 miles closer), the viewer contrast rating, viewer sensitivity analysis, 

and overall visual impact analysis would be similar to those associated with the Proposed Action.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-103

KOP 4

Visual Simulation from Pole Line Road (KOP 4) to Alternative 2. 

KOP 4 is located approximately 1.6 miles from Alternative 2. The visual contrast rating, viewer 

sensitivity, and the visual impact analysis would be the same as those associated with the Proposed 

Action.

Indirect Effects

No indirect effects to visual resources are likely to occur.

4.12.5 TL and Anaconda-Moly Substation Corridor 

The proposed TL and substation would connect the existing Anaconda-Moly substation to the proposed 

power block location at the project site. The majority of the proposed TL would follow the existing 

Miller’s to Anaconda-Moly TL corridor, oriented northeast to southwest. The TL corridor would run 

perpendicular to Pole Line Road in the vicinity of the proposed project site, then would parallel the road 

before connecting with the proposed power block. 

The landscape in the area of the TL corridor is flat desert valley, bounded by high-relief, fault-block 

mountains in the seldom seen distance zone (beyond 15 miles). 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-104

Views of the proposed TL would be evident from Pole Line Road but would likely be indiscernible from 

other areas. 

Recreationists (with a medium viewer sensitivity rating) using the Crescent Dunes SRMA would likely be 

able to see the proposed TL from the Crescent Dunes, resulting in a moderate effect. 

4.12.5.1 Construction

Direct Effects

The construction of the TL facilities is considered a short-term visual effect. During construction, large 

equipment, vehicles, and materials would be present and visible on the project site and within the TL

corridor. 

Indirect Effects

No indirect effects to visual resources are likely to occur.

4.12.5.2 Operation

Direct Effects

TL facilities would be used to connect the proposed substation to the existing Anaconda-Moly 

substation. This TL corridor would primarily be constructed within the existing Miller’s to AnacondaMoly TL corridor, with connections to the proposed substation and solar field diverging from the existing 

corridor. The proposed 230 kV TL poles would be constructed on “H”-frame wooden structures, which 

span approximately 500 feet apart. 

KOP 2 is located at the Anaconda-Moly substation, approximately 8.1 miles north of the project area. 

This KOP was chosen to represent views from travelers on the Anaconda-Moly substation access road. 

From this location, the view is to the southeast and looks out over the wide-open valley floor in the 

foreground and middleground. The San Antonio Mountains are visible in the background. The proposed 

solar facility would be barely discernible because of the distance; however, this view represents the 

visual impacts of the transmission line. The new transmission line would result in a moderate contrast in 

form, line, and texture by introducing new vertical and horizontal lines into the surrounding landscape. 

Viewers in this area would likely be traveling to the existing substation. Typically, commuters have a low 

sensitivity rating because of constant motion and high traveling speeds. As a result, commuters tend to 

focus on the road and not the surrounding scenery. The visual contrast in this area is considered minor 

because while the TLs would be evident, they would not be a dominant feature in the viewshed because 

they would be among many TLs in the existing corridor. Based on the scenic quality, visual contrast 

rating, and viewer sensitivity in the area, the overall visual impact rating associated with the TL is minor 

because of the lack of sensitive viewers in the area and the existing TLs already present within the 

corridor.

Indirect Effects

No indirect effects to visual resources are likely to occur.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-105

4.12.6 Borrow Pit

The borrow pit area is an existing industrial use area located outside of the viewshed. None to very few 

sensitive viewers are likely to see this area. 

4.12.6.1 Construction

Direct Effects

No effects on visual resources are likely to occur. 

Indirect Effects

No effects on visual resources are likely to occur. 

4.12.6.2 Operation

Direct Effects

No effects on visual resources are likely to occur. 

Indirect Effects

No effects on visual resources are likely to occur. 

4.12.7 No Action Alternative

The No Action Alternative would result in no change to the visual landscape. 

4.12.8 Summary of Effects 

The proposed solar energy generating facility would have an estimated footprint of 1,628–1,673 acres, 

which would house the solar field, administration buildings, evaporation pond, generation transmission 

tie line, substation, and ancillary facilities. The solar field would have approximately 17,500 heliostats, or 

solar reflector panels, that would stand approximately 25 feet in height. The heliostats would be

arranged asymmetrically in an array oriented within a 4,300-foot-diameter circle. The power block, 

located in the center of the solar field, would have a diameter of approximately 800 feet and would 

house storage tanks, a steam turbine, an air-cooled condenser, transformers, heat exchanges, buildings, 

and the central receiver tower, which would stand at approximately 633 feet in height and would be the 

tallest (most visible) element of the project. 

Additionally, linear facilities would include the overhead TLs and access roads. The proposed TLs would 

run about 6 miles due north of the solar field and would be placed in the existing TL corridor when 

possible. The outgoing TL would follow Pole Line Road and head north to the Miller’s to Anaconda-Moly 

TL and parallel the existing corridor to the Anaconda-Moly substation to interconnect with the electrical 

grid. For most of the distance between the project site and Anaconda-Moly substation, the TL would be 

placed within existing ROW. The proposed power line poles are approximately 80 feet tall and would be

cor-ten steel 230 kV single-circuit monopoles. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-106

Roads would be built to provide access to the project site from Pole Line Road. Major access roads to 

the project will be surfaced with asphalt and will have a width of 24-feet wide within 80-foot ROW. 

Traffic on these roads will occur predominantly during construction. There will also be unpaved 

perimeter roads constructed and located to provide access from the power block to the east and south 

edges of the solar field and around the perimeter of the solar field. 

Table 4-24 summarizes visual effects of introducing the aforementioned project components into the 

existing environment from selected KOPs within the visual resources study area. 

Table 4-24. Visual effects summary for KOPs for each proposed action alternative

KOPs/Action Alternative Viewer Sensitivity Construction Effects Operation Effects

Proposed Action

KOP 1 Recreationists – medium/high Moderate Major

KOP 3 Travelers – low Moderate Moderate

KOP 4 Travelers – low Moderate Moderate

Alternative 1

KOP 1 Recreationists – medium/high Moderate Major

KOP 3 Travelers – low Moderate Moderate

KOP 4 Travelers – low Moderate Moderate

Alternative 2

KOP 1 Recreationists – medium/high Moderate Major

KOP 3 Travelers – low Moderate Moderate

KOP 4 Travelers – low Moderate Moderate

4.12.9 Mitigation

The project location would be integrated with the surrounding landscape to avoid conflict with 

significant aesthetic conditions. Mitigation measures would include color treating the buildings, the 

backs of the solar panels, and the central receiving tower to a BLM-approved color that blends into the 

surrounding landscape. Subsequent to construction, restoration efforts would be made in areas that 

were temporarily disturbed. 

Given the importance of maintaining dark sky conditions, conscious efforts would be made to protect 

the current dark skies from light pollution. The FAA requires lighting on any temporary or permanent 

structure that exceeds an overall height of 200 feet above ground level. In order to maintain dark sky 

conditions and minimize visual disturbance, it is recommended that the central receiver tower be 

illuminated with white lighting during daytime hours and red strobe lights during the night. Additionally, 

perimeter lighting, including lighting used to illuminate walkways, roadways, equipment yards, and 

parking lots, would be shielded so that light would be cast in a downward direction. Low-pressure 

sodium lighting would be used to reduce or eliminate detrimental lighting impacts and prevent 

unnecessary light pollution. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-107

The TL poles would be constructed of wooden “H”-frame poles, which tend to blend into the landscape 

with distance. Given the flat, expansive nature of the landscape, the poles would provide less structural 

contrast as they blend into the horizon and skyline. The appearance of the poles would be similar to the 

existing wood power line poles present in the corridor. 

4.13 Hazardous Materials

4.13.1 Methods 

A variety of chemicals and hazardous substances would be stored and used during construction and 

operation of the project. The storage, handling, and use of all chemicals would be conducted in 

accordance with applicable laws, ordinances, and regulations. The analysis in this section included a 

review of the Proponent’s Plan of Development (Tonopah Solar Energy 2009), which lists the expected 

hazardous materials that would be stored and used during construction and operation of the proposed 

facility.

As discussed in Chapter 2, the proposed project alternatives would be designed to meet all applicable 

standards to reduce the risk of an accidental release, operated in a manner that complies with safety 

standards and practices, and maintained to provide a safe workplace for personnel and to prevent 

significant adverse off-site impacts. 

Construction and operation would involve the use of the latest industrial technology and design

standards and would adhere to regulatory health and safety codes and guidelines. Training, operating, 

inspection, and maintenance procedures that would minimize the risk and severity of potential upset 

conditions would be implemented.

4.13.2 Proposed Action 

4.13.2.1 Construction

During construction, several hazardous materials would be used, including diesel fuel, gasoline, oil, 

lubricants, welding gases, solvents, and paints. During the startup, the solar facility would require the 

use of large amounts of nitrate salt (NaNO3, CAS 7631-99-4; and KNO3, CAS 7757-79-1) at the site. The 

salt would be melted once during construction of the project and would be used throughout the project 

life at temperatures between 550°F and 1050°F.

Flammable materials, such as paint and solvents, would be stored in approved flammable material 

cabinets. Any welding gases would be stored in approved metal cylinders. A temporary 10,000-gallon 

aboveground storage tank would be used to supply diesel fuel during construction of the facility. The 

tank would be located in the temporary lay down area and would be double walled or located within a 

containment area in accordance with applicable regulations.

The salt would be delivered in 1-ton “super sacks,” which can be stored on-site until melted for use in 

the plant process. The salt must be heated until fluid for use in the system, and would be stored within 

the lay down area of the site until it is heated, liquefied, and sent to the storage tanks. The solid salt 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-108

would be heated to liquid form using propane gas. It is not anticipated that the salt would have to be 

refilled during operation of the plant because it would be stored in a fully closed system.

A hazardous materials and waste management plan would be implemented prior to construction of the 

proposed project that would instruct workers on the applicable procedures on hazardous materials 

storage and waste disposal. A SWPPP would be in place before construction detailing the BMPs for 

managing any stormwater runoff.

Direct Effects

The potential for hazardous material spills would increase during the construction phase of the project; 

however, by implementing the plans listed in Section 4.13.9, the direct effects of construction of the 

proposed project would be minimal.

Indirect Effects

If proper cleanup of any hazardous material spills in the construction phase were not implemented, the 

potential for soil contamination to remain and the potential to migrate with stormwater runoff from the 

construction area would exist. By implementing the plans and control measures listed in Section 4.13.9, 

the indirect effects of the project would be minimal.

4.13.2.2 Operation

Hazardous materials would be used and stored at the facility during operation and maintenance; a list of 

the materials expected to be used during operation is presented in Table 4-25.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-109

Table 4-25. Hazardous materials that would be used during project operation

Material 

Chemical Abstract 

Service Number 

(CAS No.)

Use Hazardous 

Characteristics 

Estimated 

Quantity 

On Site

Carbon dioxide (gas) 124-38-9 Generator purging Asphyxiant, 

compressed gas 25,000 scf

Carbon dioxide 

(liquid) 124-38-9 Fire suppression

Asphyxiant, 

compressed liquid, 

cryogen

25,000 lb

Diesel fuel (no. 2) 68476-34-6 Fuel for emergency generator, fire water 

pump, and diesel storage for vehicle use Toxic, combustible 11,500 gal

Ferric chloride 

solution 7705-08-0 Possible use for water pretreatment Toxic 3,000 gal

Hydrogen 1333-74-0 Generator cooling Toxic, flammable, 

explosive 24,000 scf

Hydrated lime 1305-62-0 Possible use for water pretreatment Toxic, corrosive 2,000 cf

Lubricating oil Various Mechanical equipment lubrication Toxic, combustible 25,000 gal

Mineral oil Various Transformer oil Toxic, combustible 100,000 gal

Nitrogen 7727-37-9 Blanketing Asphyxiant, 

compressed gas 400 lb

Sodium carbonate 497-19-8 Water pretreatment Toxic 2,000 cf

Sulfur hexafluoride TBD Contained in switchgear devices Toxic 200 lb

Sodium hydroxide 

(50% by weight) 1310-73-2 Possible water demineralizer media regeneration Toxic, corrosive 3,000 gal

Sulfuric acid 

(29% by weight) 7664-93-9 Batteries Toxic, corrosive 2,000 gal

Sulfuric acid 

(93% by weight) 7664-93-9 RO feed pH control, possibly water 

demineralizer media regeneration Toxic, corrosive 5,000 gal

The project would produce maintenance and plant wastes typical of a power generation plant. These 

wastes would be managed in accordance with a waste management plan. Wastes may include oily rags, 

broken and rusted metal and machine parts, defective or broken solar mirrors and electrical materials, 

empty containers, and other miscellaneous solid wastes including the typical refuse generated by 

workers. These materials would be collected by a local waste disposal company and disposed at a 

landfill permitted to receive these wastes. Waste collection and disposal would be in accordance with 

applicable regulatory requirements to minimize health and safety effects, prevent leaks and spills, and 

prevent potential contact with stormwater.

Several methods would be used to properly manage and dispose of hazardous wastes generated by the 

project. Waste lubricating oil would be recovered and recycled by a waste oil recycling contractor. 

Spent lubrication oil filters would be disposed of in a Class I landfill. Workers would be trained to handle 

hazardous wastes generated at the site.

Chemical cleaning wastes would consist of alkaline and acid cleaning solutions used during preoperational chemical cleaning of heat exchangers after the units are put into service. These wastes, 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-110

which can contain elevated metal concentrations, would be temporarily stored on-site in portable tanks, 

and would be disposed of off-site by a chemical cleaning contractor in accordance with applicable 

regulatory requirements.

Industrial wastewater would consist of a relatively small amount of blowdown from the steam system 

and reverse osmosis treatment return flow. This wastewater would be disposed in evaporation ponds at 

the site. The ponds would be designed to hold the accumulated sludge/precipitated solids for the 

33-year operational life of the facility. Pond cleanout is, therefore, not proposed as a regular part of 

maintenance activities; however, cleanout could be required to support unscheduled maintenance, 

repairs, or contingency responses. The general requirements for undertaking cleanout works for 

evaporation ponds are outlined below.

Before water could be pumped out of the pond for maintenance, the capacity of the other evaporation 

ponds would be assessed to verify that sufficient capacity exists to contain wastewater from continued 

operation for a sufficient amount of time to allow planned maintenance activities. Design estimates 

indicate that if one pond is undergoing cleanout activities, the additional two ponds could operate 

effectively for up to 1 year.

A manually placed pumping system would be used to transfer the water into an adjacent evaporation 

pond. Because the bases of the ponds would not be covered with a hard liner/protective layer, care 

must be taken with pump placement to avoid damaging the pond liners or transfer piping. During pond 

drainage, the flow rates from the pumps would be monitored to ensure that the outflow would not 

negatively affect the receiving evaporation pond.

Dust generated during the activities would be controlled through moisture conditioning, if needed. 

Wastewater would not be used as a dust suppression agent. Work would be conducted pursuant to the 

TSE site health and safety program and under a job-specific safety analysis. 

Sludge removal activities would be conducted on an as-needed basis. The sludge would be removed by a 

pumping or vacuum system if fluid, or should be dried and removed using light excavation and loading 

equipment light enough to not damage the liner system. Ramps constructed of granular material at least 

1 foot thick may be placed to serve as a working platform for equipment access, if necessary. The sludge 

would be sampled and analyzed to meet the characterization requirements of the receiving disposal 

facility because this would determine the transportation and disposal methodology. 

A technical document would be submitted to NDEP to permit evaporation ponds for industrial 

wastewater disposal at the site. The document would include waste characterization, impoundment 

design, leak collection and detection, construction and operating parameters for the ponds, and closure 

requirements.

Direct Effects

Once the project were constructed, all hazardous materials would be stored in accordance with 

applicable regulations as listed in Section 3.13, and managed in accordance with the plans listed in 

Section 4.13.9. Operation of the facility would increase the risk of accidental spills; however, through 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-111

implementation of the mitigation measures and proper housekeeping at the facility, no direct effects are 

likely to occur.

Indirect Effects

By implementing the required mitigation measures and plans, any potential for long-term effects are not 

likely to occur; therefore, no indirect effects are likely to occur from the operation and maintenance of 

the facility.

4.13.3 Alternative 1

The construction and operation of Alternative 1 would be the same as for the Proposed Action; 

therefore, Alternative 1 would have the same direct and indirect effects as the Proposed Action.

4.13.4 Alternative 2

The construction and operation of Alternative 2 would be the same as for the Proposed Action; 

therefore, Alternative 1 would have the same direct and indirect effects as the Proposed Action.

4.13.5 TL and Anaconda-Moly Substation Corridor 

Construction of the TL would require that hazardous materials be transported and used along the 7- to 

9-mile-long TL route. The main hazardous material during construction of the TL would be diesel and 

gasoline fuel for the construction trucks. The fuel would be stored in the trucks, and refueling would 

take place from the 10,000-gallon tank located at the temporary lay down area as described in 

Section 4.13.2.1.

Applicable plans would be implemented to minimize and clean any spills during the construction phase, 

as described in Section 4.13.9.

4.13.5.1 Construction

Direct Effects

The potential for minor spills, mainly vehicle and equipment fuel, would be present throughout the 

construction of the TL and substation; however, by implementation of the mitigation measures and 

proper housekeeping during the construction phase no direct effects are likely to occur.

Indirect Effects

By implementing the required mitigation measures and plans, any potential for long-term effects are not 

likely to occur; therefore, no indirect effects are likely to occur from construction of the TL and 

substation. 

4.13.5.2 Operation

Once constructed, the TL would require only periodic inspections, which would be accomplished by a 

service vehicle using the adjacent maintenance road. No hazardous materials would be used for the 

periodic inspections, except vehicle fuel stored in the gas tank.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-112

Direct Effects

Because of to the minimal amount of hazardous materials required during operation of the TL, no direct 

effects are likely to occur from construction of the TL.

Indirect Effects

No indirect effects are likely to occur during construction of the TL.

4.13.6 Borrow Pit

The borrow pit would be used only during parts of the construction phase, and would mainly require 

that diesel fuel and gasoline be available at the site for the construction vehicles and aggregate 

equipment. The fuel would be stored in accordance with applicable regulations, and the plans described 

in Section 4.13.9 would be implemented during operation of the pit.

The following subsections summarize the impacts of construction and operation of the borrow pit 

together because the borrow pit would be open only until the completion of construction of the 

generation facility.

Direct Effects

The potential for minor spills, mainly vehicle and equipment fuel, would be present throughout the 

operation of the borrow pit. However, through implementation of the mitigation measures and proper 

housekeeping during the construction phase, no direct effects are likely to occur.

Indirect Effects

By implementing the required mitigation measures and plans, any potential for long-term effects are not 

likely to occur; therefore, no Indirect effects are likely to occur from use of the borrow pit.

4.13.7 No Action Alternative

Under the No Action Alternative, no project-related impacts from hazardous materials would occur. 

4.13.8 Summary of Impacts 

• An increase of accidental hazardous material spills may occur.

• Larger spills may leek into the proposed facility’s groundwater well, affecting groundwater.

4.13.9 Mitigation

During facility construction, various hazardous materials and one regulated substance would be stored 

on-site. Construction service personnel would follow general industry health, safety, and environmental 

BMPs for filling and servicing construction equipment and vehicles. The BMPs are designed to reduce 

the potential for incidents involving hazardous materials. They include the following:

• Refueling and maintenance of vehicles and equipment would occur only in designated areas 

that are either bermed or covered with concrete, asphalt, or other impervious surfaces to 

control potential spills. Employees would be present during refueling activities. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-113

• Vehicle and equipment service and maintenance would be conducted only by authorized 

personnel. 

• Refueling would be conducted only with approved pumps, hoses, and nozzles. 

• Catch-pans would be placed under equipment to catch potential spills during servicing. 

• All disconnected hoses would be placed in containers to collect residual fuel from the hoses. 

• Vehicle engines would be shut down during refueling. 

• No smoking, open flames, or welding would be allowed in refueling or service areas. 

• Refueling would be performed away from bodies of water to prevent contamination of water in 

the event of a leak or spill. 

• When refueling is completed, the service truck would leave the project site. 

• Service trucks would be provided with fire extinguishers and spill containment equipment, such 

as absorbents. 

• Should a spill contaminate soil, the soil would be put in containers and disposed of as 

appropriate. All containers used to store hazardous materials would be inspected at least once 

per week for signs of leaking or failure. All maintenance and refueling areas would be inspected 

monthly. Results of inspections would be recorded in a logbook that would be kept on-site. 

In the unlikely event of a spill, the spill may need to be reported to the appropriate regulatory agencies 

and cleanup of contaminated soil could be required. Small spills would be contained and cleaned up 

immediately by trained, on-site personnel. Larger spills would be reported by emergency phone 

numbers to obtain help from off-site containment and cleanup crews. All personnel working on the 

project during the construction phase would be trained in handling hazardous materials and the dangers 

associated with hazardous materials. An on-site health and safety person would be designated to 

implement health and safety measures. If there is a large spill from a service or refueling truck, 

contaminated soil would be placed into barrels or trucks by service personnel for off-site disposal at an 

appropriate facility in accordance with the law. If a spill involves hazardous materials quantities equal to 

or greater than the specific Reportable Quantity (42 gallons for petroleum products), all federal, state, 

and local reporting requirements would be followed. In the event of a fire or injury, the local fire 

department would be called. 

In addition to these BMPs to address accidental hazardous materials releases, a construction site 

security plan would be prepared to address hazardous materials security and would include the 

following elements: 

• descriptions of the site perimeter fencing and access security 

• evacuation procedures 

• a protocol for contacting law enforcement in the event of conduct endangering the facility, its 

employees, its contractors, or the public 

• a site access protocol for contractors and vendors, including applicable personnel background 

checks consistent with state and federal law regarding security and privacy 

• a protocol for hazardous materials vendors to prepare and implement security plans in 

accordance with 49 CFR 172.800 and to ensure that all hazardous materials drivers are in 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-114

compliance with personnel background security checks in accordance with 49 CFR Part 172, 

Subpart I 

• a protocol for ensuring the security of nitrate salts in accordance with DHS measures to protect 

listed Chemicals of Interest (risk: theft) in accordance with 6 CFR Part 27 

During facility operation, various hazardous materials and one regulated substance would be stored onsite as shown in Table 4-25. MSDS for the chemicals likely to occur on-site during operation of the 

proposed project can be found in the Plan of Development (Tonopah Solar Energy 2009). 

During operation of the facility, all hazardous materials would be handled and stored in accordance with 

applicable codes and regulations specified in Section 3.13. Some general measures that would be 

implemented include:

• provision of an automatic sprinkler system for indoor hazardous material storage areas 

• provision of an exhaust system for indoor hazardous material storage areas 

• separation of incompatible materials by isolating them from each other with a noncombustible 

partition 

• spill control in all storage, handling, and dispensing areas 

• separate secondary containment for each chemical storage system; secondary containment is 

required to hold the entire contents of the tank plus the volume of water for the fire 

suppression system that could be used for fire protection for a period of 20 minutes in the event 

of a catastrophic spill 

The above mitigation measures will be outlined in the following plans:

Health and Safety Requirements – To comply with regulations set forth by OSHA and the Nevada 

Division of Industrial Relations, health and safety programs would be established for construction and 

operations at the site that would document potential hazards and requirements for establishing and 

maintaining a safe working environment during construction and operation. The programs would

include identification of all hazardous substances and chemicals used at the site, including MSDS, a 

communication and training program, labeling, and identification of hazards and safe work practices. In 

addition, safety showers and eyewashes would be provided adjacent to, or in the vicinity of, chemical 

storage and use areas. Plant personnel would use approved personal protective equipment during 

chemical spill containment and cleanup activities. Personnel would be properly trained in the handling 

of these chemicals and instructed in the procedures to follow in case of a chemical spill or accidental 

release. Adequate supplies of absorbent material would be stored on-site for spill cleanup.

Construction and Operating SWPPPs – The project would comply with the requirements of the NPDES 

through preparation and implementation of a SWPPP and filing of an NOI to comply with the General 

Construction and General Industrial Stormwater NPDES permit. The plans would include procedures to 

be followed during construction to prevent erosion and sedimentation, non-stormwater discharges, and 

contact between stormwater and potentially polluting substances.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-115

Hazardous Materials Management Plans (HMMPs) – HMMPs would be filed with Nye County for the 

construction and operation of the facility. The plans would inventory the hazardous materials and waste 

properties, quantities, storage containers and locations, and contingency planning and emergency 

response procedures. 

SPCC Plans – SPCC Plans would be prepared for construction and operation of the site. The plans would 

include spill prevention and countermeasures procedures to be implemented, including (but not limited 

to) a spill record (if applicable), analysis of potential spills, description of containment facilities, fill and 

overfill prevention facilities, spill response procedures, personnel training, and spill prevention. In 

addition, all spills would be reported to the BLM Hazardous Materials Coordinator.

4.14 Range Resources

4.14.1 Methods 

The environmental consequences of the proposed project on range resources were evaluated by 

reviewing the proposed activities associated with the project components and evaluating each of the 

range resources individually. The primary evaluation focused on the extent to which livestock grazing 

would be affected either because of the loss of forage production relative to the grazing allotment or by 

altering the grazing management within the allotment. 

Project construction and operation activities would affect range resources (livestock grazing) if they:

• result in loss of forage such that it would adversely affect livestock operations and dramatically 

reduce the number of AUMs available

• substantially disrupt livestock movement and migration routes for wild horses

• substantially increase human disturbance/harassment to wild horses, burros, or livestock

• substantially conflict with the use of existing livestock grazing areas and HMAs for wild horses

Actual impacts to acreages of the allotment and forage production, and the resulting AUMs, would 

depend on the alternative selected and the final designs of the project. However, to address the 

potential for the loss of AUMs, BLM notified the permittee that the authorized grazing could be reduced 

to approximately 434,875 acres and 13,270 AUMs (a reduction of about 1.7 percent) because the 

permittee had requested a much larger area in the original ROW application. This number will be 

adjusted when the final alternative is selected and the ROW granted. The impacts of each of the 

alternatives are evaluated based on the acreage of impacts presented in Table 4-1 at the beginning of 

this chapter.

4.14.2 Proposed Action 

4.14.2.1 Construction

The following section describes impacts to range resources that would occur as a result of constructing 

the Proposed Action. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-116

Direct Effects

Construction of the generation facility under the Proposed Action would result in the long-term loss of 

approximately 1,500 acres of forage production and livestock grazing area, which amounts to 46 AUMs. 

This area would be within the security fence, inaccessible to cattle, and nearly all of the area would be 

disturbed for the construction of the heliostats and other facilities. The reduction in potential cattle 

production because of the loss of the AUMs from the generation facility is approximately 0.4 percent of 

the current authorized grazing level (reduction from 13,505 AUM to 13,453 AUM). 

The proposed project would result in increased vehicle traffic on the existing SH 69 from US 95 to the 

proposed project site, with the greatest increase occurring during the construction period. Increased 

traffic on these roads may result in a minimal increase in the potential death or injury of cattle caused 

by vehicle collisions. The occurrence of these impacts is expected to be infrequent because of the low 

density of cattle in this large allotment and the speed limits currently established on these roads. 

In cases where projects are proposed near water sources, or crossing traditional movement paths 

between grazing areas and water sources, substantial impacts to grazing and grazing management can 

occur. However, for this project, no natural or constructed water sources are known to occur in the 

vicinity of the Proposed Area. For these reasons, no impacts to water sources or associated movement 

patterns are expected. 

Indirect Effects

Indirect effects on range resources from construction of the Proposed Action are likely to be limited to 

the areas adjacent to the construction area and would result from increased presence of humans and 

noise during construction, which may cause livestock to leave the vicinity of the construction areas. No 

impacts are likely to occur to water sources in the region; therefore, no reductions in water availability 

would occur. No additional potential indirect effects have been identified. 

4.14.2.2 Operation

Direct Effects

Operation of the power generation facility is expected to have few direct effects on range resources 

other than the continued loss of forage production and grazing opportunities that are associated with 

construction of the facility. 

Indirect Effects

Indirect effects of operations of the facility on range resources would continue to be the increased 

human presence in the area and the potential that livestock would avoid the area adjacent to the 

project area. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-117

4.14.3 Alternative 1

4.14.3.1 Construction

Direct Effects

The direct effects of construction of Alternative 1 would be similar to the effects described for the 

Proposed Action. The total acreage removed as a result of construction of the facility would be 

1,504 acres, and the grazing potential would be reduced by 46 AUMs. The reduction in potential cattle 

production attributable to the loss of the AUMs from the generation facility is approximately 0.4 percent

of the current authorized grazing level (reduction from 13,505 AUM to 13,453 AUM). 

Indirect Effects

The indirect effects of construction of Alternative 1 would be similar to the effects described for the 

Proposed Action. 

4.14.3.2 Operation

Direct Effects

The direct effects of operation of Alternative 1 would be similar to the effects described for the 

Proposed Action. 

Indirect Effects

The indirect effects of operation of Alternative 1 would be similar to the effects described for the 

Proposed Action. 

4.14.4 Alternative 2

4.14.4.1 Construction

Direct Effects

The direct effects of construction of Alternative 2 facility be similar to the effects described for the 

Proposed Action. The total acreage removed as a result of construction of the facility would be 

1,501 acres, and the grazing potential would be reduced by 46 AUMs. The reduction in potential cattle 

production attributable to the loss of the AUMs from the generation facility is approximately 0.4 percent

of the current authorized grazing level (reduction from 13,505 AUM to 13,455 AUM). 

Indirect Effects

The indirect effects of construction of Alternative 2 would be similar to the effects described for the 

Proposed Action. 

4.14.4.2 Operation

Direct Effects

The direct effects of operation of Alternative 2 would be similar to the effects described for the 

Proposed Action. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-118

Indirect Effects

The indirect effects of operation of Alternative 2 would be similar to the effects described for the 

Proposed Action. 

4.14.5 TL and Anaconda-Moly Substation Corridor 

This section describes the potential effects associated with the TL and substation that would be 

constructed if any of the three action alternatives are selected. 

4.14.5.1 Construction

Direct Effects

Construction of the TL towers and the associated access pullouts from the existing power line road 

would result in between 127 and 173 acres of new disturbance and loss of forage production, which 

amounts to between 4 and 5 AUMs. The range of impacts associated with construction of the TL is 

attributable to the varying distances between the generation facilities and the substation, and thus the 

number of towers required. In addition to the long-term disturbance of grazing areas with the 

construction of the access spurs, some construction activities may result in only temporary disturbance 

of the vegetation. The type of disturbance would vary in nature, with some temporary disturbance 

requiring removal of vegetation and leveling of the ground surface, and others requiring only crushing or 

cutting of the vegetation. Temporary disturbance associated with the facility is expected to result in 

between 127 and 173 acres of disturbance, such as crushed or cut vegetation that would be able to 

recover after construction is complete. This disturbance would result in a temporary reduction in forage 

production for between 4 and 5 AUMs. 

In cases where projects are proposed near water sources, or crossing traditional movement paths 

between grazing areas and water sources, substantial impacts to grazing and grazing management can 

occur. However, for this project, the TL does not appear to cross known movement paths nor is it near 

any water resources. The TL would not be fenced during construction; therefore, cattle movement 

would not be restricted. 

No range improvements such as fences, gates, or cattle guards are present within the project area. 

Therefore, no impacts to range improvements are likely to result from the construction of the TL or 

substation. 

The construction of the new TL and expanded substation would result in increased vehicle traffic along 

Pole Line Road, resulting in a potential increase in death or injury of cattle caused by vehicle collisions. 

The occurrence of these impacts is expected to be infrequent because of the low density of cattle in this 

large allotment and the low vehicle speeds associated with construction. 

Indirect Effects

No indirect effects of the construction of the new TL are likely to occur on range resources. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-119

4.14.5.2 Operation

Direct Effects

Operation of the TL may include occasional monitoring and maintenance of the transmission towers, 

which would include vehicle traffic on the existing access road. Vehicle traffic could result in death or 

injury of cattle resulting from collisions, but such accidents are unlikely because of the speed limits on 

the roads. 

Indirect Effects

Operation of the TL and the substation is not anticipated to have indirect effects on range resources.

4.14.6 Borrow Pit

4.14.6.1 Construction

Direct Effects

Expansion of the borrow pit is anticipated to require approximately 40 acres of previously undisturbed 

area may be removed from forage production. The loss of this amount of area would equate to 1 AUM 

within the allotment. However, the subsequent reclamation of the area makes this impact temporary in 

nature. Expansion of the borrow pit would be conducted in accordance with BLM guidelines currently in 

place for the existing facility to prevent cattle from entering the facility and potentially being killed or 

injured. No other direct effects on range resources are anticipated.

Indirect Effects

No indirect effects on range resources are anticipated from construction of the borrow pit. 

4.14.6.2 Operation

Direct Effects

No direct effects on range resources as a result of operation of the borrow pit are anticipated.

Indirect Effects

No indirect effects on range resources as a result of operation of the borrow pit are anticipated.

4.14.7 No Action Alternative

Under the No Action Alternative, impacts to range resources associated with this project would not 

occur. 

4.14.8 Summary of Impacts 

As stated in the previous sections, the primary effect on range resources resulting from implementation 

the Proposed Action or the other action alternatives would be the loss of forage production and the 

associated reduction in grazing. Table 4-26 presents the estimates of acreage to be lost to the 

construction of the Proposed Action and each alternative, as well as the estimated AUMs that would be 

lost. In each case, the number of AUMs is small relative to the current preference of 13,505 AUMs. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-120

Table 4-26. Grazing acreage and AUM reductions attributable to project components and alternatives 

Project Component/Alternative

Long-term Impact Temporary Impact

Acreage AUMs Acreage AUMs 

Proposed Project Area

Generation facility 1,500 46 52 2 

Transmission line and substation 173 5 173 5 

Borrow pit 0 40 1 

Total 1,673 52 265 3 

New Authorized Totals 440,882 13,453 — — 

Alternative 1

Generation facility 1,504 46 52 2 

Transmission line and substation 136 4 136 4 

Borrow pit 0 40 1 

Total 1,640 50 228 7 

New Authorized Totals 440,918 13,455 — — 

Alternative 2

Generation facility 1,501 46 52 2 

Transmission line and substation 127 4 127 4 

Borrow pit 0 40 1 

Total 1,628 50 219 7 

New Authorized Totals 440,927 13,484 — — 

Note: AUM = animal unit month

4.14.9 Mitigation

The project would be designed to minimize impacts where possible, and construction measures would

be taken to reduce long-term impacts during construction of the facility and the TLs, such as blading 

only areas that are needed for long-term access. Mitigation of these impacts would include recontouring 

and revegetating the area after removal and decommissioning of the facility at the end of the lease 

period. Goals of the revegetation plan are to return the site to a condition of production of comparable 

type and volume of forage and to a sustainable ecological condition. 

Mitigation for temporary impacts would vary by the type and severity of the impact. Impacts requiring 

removal of vegetation would be mitigated through revegetation efforts as described in the Revegetation 

Plan. These efforts may include salvage and subsequent redistribution of topsoil, distribution of seeds to 

promote reestablishment of native plants, and control of noxious and invasive weed species. Where 

possible, vegetation would be crushed to allow the necessary construction access, minimizing impacts to 

the vegetation and the soils. In other cases, plants may be cut to allow construction access, retaining a 

root stock to provide a base for resprouting and more rapid plant reestablishment. 

4.15 Recreation and Wilderness

4.15.1 Methods 

A recreation specialist analyzed the effects of the Proposed Action, Alternative 1, Alternative 2, the TL 

and Anaconda-Moly substation corridor, and the borrow pit on recreation and wilderness resources. To 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-121

assess the direct effects on recreation and wilderness, GIS was used to overlay the footprints of the 

project components on the mapped recreation and wilderness resources within the proposed project 

area to identify those resources that would be directly affected by the project construction and 

operation (Figure 4-8). 

4.15.2 Proposed Action 

4.15.2.1 Construction

Direct Effects

The recreational opportunities identified in the project area are the Crescent Dunes ROW avoidance 

area (i.e., the SRMA), the TRAC-ON trail ride route, and Hunting Unit 173 (see Section 3.15). The 

Proposed Area does not encroach upon the Crescent Dunes ROW avoidance area; therefore, no effects 

to the ROW avoidance area are anticipated. The proposed project would affect the existing TRAC-ON 

trail ride route by building the facility over the existing trail. Construction of the solar facility would 

result in decreased scenic quality and increased traffic throughout the area, affecting recreational 

opportunities within the Crescent Dunes SRMA. Project construction would be visible from the Crescent 

Dunes SRMA, Crescent Dunes Road, and Pole Line Road (see Section 4.12). Construction of the solar 

facility may reduce a recreationist’s sense of a remote experience. 

The Proposed Action could directly affect hunting activities by removing approximately 1,500 acres of 

potential hunting grounds for pronghorn, mule deer, and bighorn sheep within Hunting Unit 173. 

However, during hunting season, pronghorn have an affinity for areas with water sources, most likely 

alfalfa fields (NDOW 2010c). Mule deer and bighorn sheep prefer more mountainous habitat (above 

8,500 feet) (NDOW 2010a, 2010b). Because the Proposed Area is at a relatively low elevation (below

5,000 feet) and does not contain any water sources or alfalfa fields, it is unlikely that game species 

would utilize the project area during hunting season; therefore, no direct effects to hunting during 

construction activities are anticipated. 

Indirect Effects

Construction of the Proposed Action would not impede access to the Crescent Dunes or optimal hunting 

areas (i.e., nearby mountains and water sources); therefore, no indirect effects to recreational 

opportunities are anticipated. 

4.15.2.2 Operation

Direct Effects

As previously stated, the Proposed Action would not encroach upon the Crescent Dunes ROW avoidance 

area or optimal hunting areas; therefore, no direct impacts to recreational opportunities are associated 

with the operation of the Proposed Action. However, operation of the solar facility would result in 

decreased scenic quality and increased traffic throughout the area, affecting recreational opportunities 

within the Crescent Dunes SRMA. The project would be visible from the Crescent Dunes SRMA, Crescent 

Dunes Road, and Pole Line Road (see Section 4.12). The presence of the solar facility may detract from a 

recreationist’s remote experience.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-122

Indirect Effects

Operation of the proposed project would not impede access to the Crescent Dunes or optimal hunting 

areas (i.e., nearby mountains and water sources); therefore, no indirect impacts to recreational 

opportunities are anticipated.

4.15.3 Alternative 1

4.15.3.1 Construction

Direct Effects

Direct effects of construction of Alternative 1 would be similar to that of the Proposed Action except 

that construction of Alternative 1 would result in direct effects to approximately 130 acres of the 

Crescent Dunes ROW avoidance area (Figure 4-8). During construction, this area would fenced in, 

graded, and permanently converted into project facilities for the life of the project, thus restricting 

recreational access to that portion of the ROW avoidance area. 

Similar to the Proposed Action, construction of Alternative 1 would remove approximately 1,504 acres 

of potential hunting grounds. However, as previously stated, this would have minimal impact on hunting 

activities because game animals would not likely be found in the Alternative 1 area during hunting 

season. 

Indirect Effects

Construction of the proposed project would not impede access to the Crescent Dunes or optimal 

hunting areas (i.e., nearby mountains and water sources); therefore, no indirect effects to recreational 

opportunities are anticipated. 
Borrow Pit

Anaconda-Moly Substation

Crescent Dunes 

SRMA

¬«89

Source: USGS

Figure 4-8 SRMA 

(rights-of-way avoidance area)

and Alternatives

Crescent Dunes 

Solar Energy Project

0 0.5 1

Miles

± !

Project Site

NEVADA

\Projects\LasVegas\Projects\SolarReserve\CrescentDunesEIS\map_docs\mxd\Figures_Ch_4\SRMA_Map_Alts.mxd

Legend

Proposed Transmission Line

Borrow Pit (40 acre)

Rights-of-way avoidance areas (Crescent Dunes SRMA)

TRAC-ON Trail

Alternative 1

Alternative 2

Proposed Alternative
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-124

4.15.3.2 Operation

Direct Effects

Direct effects of operation of Alternative 1 would be similar to that of the Proposed Action except that 

approximately 130 acres of the Crescent Dunes ROW avoidance area and 1,504 acres of potential 

hunting grounds would be permanently converted into project facilities during construction; therefore,

no direct impacts to recreation resources are associated with operation of the facility.

Indirect Effects

Operation of Alternative 1 would not impede access to the majority of the Crescent Dunes ROW 

avoidance areas (approximately 2,770 acres) or optimal hunting grounds; therefore, no indirect impacts 

to recreational resources are associated with operation of the facility.

4.15.4 Alternative 2

4.15.4.1 Construction

Direct Effects

Direct effects from construction of Alternative 2 would be similar to the Proposed Action in that this 

location would not affect the Crescent Dunes ROW avoidance areas, and construction of Alternative 2 

would remove approximately 1,501 acres of potential hunting grounds in Hunting Unit 173. As 

previously stated, this would have minimal impact on hunting activities because game animals would 

not utilize the habitat in the Alternative 2 area during hunting season. Therefore, no direct effects on 

recreation are associated with the construction of Alternative 2.

Indirect Effects

Construction of Alternative 2 would not impede access to the Crescent Dunes or optimal hunting areas 

(i.e., nearby mountains and water sources); therefore, no indirect effects to recreational opportunities 

are anticipated. 

4.15.4.2 Operation

Direct Effects

As previously stated, the project area would not encroach upon the Crescent Dune ROW avoidance area 

or optimal hunting areas; therefore, no direct impacts to recreational opportunities are associated with 

the operation of Alternative 2.

Indirect Effects

Operation of Alternative 1 would not impede access to the Crescent Dunes or optimal hunting areas 

(i.e., mountains and water sources); therefore, no indirect impacts to recreational opportunities are 

anticipated.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-125

4.15.5 TL and Anaconda-Moly Substation Corridor 

4.15.5.1 Construction

Direct Effects

Direct effects from construction of the TL and Anaconda-Moly substation would be similar to the 

Proposed Action in that this location would not affect the Crescent Dunes ROW avoidance areas or 

optimal hunting habitat; therefore, no effects to recreational resources are associated with the 

construction of the TL and Anaconda-Moly substation.

Indirect Effects

Construction of the TL and Anaconda-Moly substation corridor would not impede access to nearby 

recreational opportunities; therefore, no indirect effects to recreation are associated with construction 

of the TL and Anaconda-Moly substation.

4.15.5.2 Operation

Direct Effects

Direct effects from operation of the TL and Anaconda-Moly substation would be similar to the Proposed 

Action in that this location would not affect the Crescent Dunes ROW avoidance areas or optimal 

hunting habitat; therefore, no effects to recreational resources are associated with operation of the TL 

and Anaconda-Moly substation.

Indirect Effects

Operation of the TL and Anaconda-Moly substation corridor would not impede access to nearby 

recreational opportunities (i.e., Crescent Dunes or optimal hunting grounds); therefore, no indirect 

effects to recreation are associated with operation of the TL and Anaconda-Moly substation.

4.15.6 Borrow Pit

4.15.6.1 Construction

Direct Effects

Direct effects from construction of the borrow pit would be similar to the Proposed Action in that this 

location would not affect the Crescent Dunes ROW avoidance areas. Construction of the borrow pit 

would remove approximately 40 acres of potential hunting grounds within Hunting Units 171 and 173. 

As previously stated, this would have minimal impact on hunting activities because game animals would 

not utilize the habitat in the borrow pit area during hunting season. Therefore, no direct effects on 

recreation are associated with the construction of the borrow pit.

Indirect Effects

Construction of the borrow pit would not impede access to nearby recreational or wilderness 

opportunities; therefore, no indirect effects are associated with construction of the borrow pit.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-126

4.15.6.2 Operation

Direct Effects

Direct effects from operation of the borrow pit would be similar to the Proposed Action in that this 

location would not affect the Crescent Dunes ROW avoidance areas or optimal hunting habitat; 

therefore, no effects to recreational resources are associated with operation of the borrow pit.

Indirect Effects

Operation of the borrow pit would not impede access to nearby recreational opportunities (i.e., 

Crescent Dunes or optimal hunting grounds); therefore, no indirect effects are associated with 

construction of the borrow pit.

4.15.7 No Action Alternative

Under the No Action Alternative, no project-related impacts to existing recreation or wilderness would 

occur. 

4.15.8 Summary of Impacts 

As stated in the previous sections, the primary effect on recreation and wilderness resources of the 

proposed project or the other action alternatives would be the loss approximately 1,652–1,673 acres of 

BLM land that is currently used for recreational activities such as hunting. Additionally, Alternative 1 

would affect approximately 130 acres of the SRMA, which is currently used primarily as an off-road 

vehicle use area. 

4.15.9 Mitigation

The TRAC-ON Trail ride route would be affected only by the Proposed Action. If the Proposed Action is 

selected as the BLM-preferred alternative; then the TRAC-ON Trail ride route would need to be rerouted 

around the project area. Two possible new routes include: rerouting the trail to the north of the project 

where it would intersect with the Crescent Dunes access road, or rerouting the trial to the south of the 

project where it would intersect with Pole Line Road.

4.16 Unavoidable Adverse Environmental Impacts

Unavoidable adverse impacts are those impacts that would occur after implementation of all committed 

and recommended mitigation. Unavoidable impacts do not include temporary or permanent impacts 

that would be mitigated by the actions of the project. They also do not include impacts from speculative 

events such as hazardous waste spills that are not contained and removed promptly in accordance with 

accepted industry standards or regulatory requirements.

The Proponent has committed to implementing mitigation measures in the project design to avoid or 

minimize potential impacts from construction and operation of the proposed project. However, 

unavoidable adverse impacts would result from the project. The proposed project would result in the 

unavoidable removal of vegetation, wildlife habitat, and grazing potential within the portions of the 

project area proposed for construction of the generation facility, borrow pit, and the TL towers. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-127

However, these impacts would be reversed with revegetation and reclamation of the site upon 

decommissioning of the facility. Individuals of various wildlife species within the proposed project area 

that may not be able to move from the area would be killed during construction of the proposed 

project. 

The aesthetic nature of the area would be unavoidably altered as a result of the proposed project, 

although efforts would be made to minimize the impact. The structures associated with the generation 

facility would alter the viewshed until the facility is decommissioned and removed. 

If additional mitigation requirements are identified through other permitting processes, the Proponent 

would develop appropriate measures in consultation with the requesting agency and include these in 

the project design. 

4.17 Irreversible and Irretrievable Commitment of Resources

This section describes the irreversible and irretrievable commitments of resources associated with 

construction and operation of the proposed project. A commitment of resources is irreversible when 

primary or secondary impacts limit the future options for a resource. The term applies primarily to the 

effects or use of nonrenewable resources, such as minerals or cultural resources, or to those factors, 

such as soil productivity, that are renewable only over very long periods of time.

Irretrievable is a term that applies to the loss of production, harvest, or use of natural resources. For 

example, livestock forage production from an area is lost while an area is serving as a mining area. The 

production lost is irretrievable, but the action is not irreversible. If the use changes and the mine is 

reclaimed, it is possible to resume forage production. Irreversible and irretrievable impacts of the 

Proposed Action are summarized in Table 4-27.

Implementation of the proposed project would result in the consumption of energy as it relates to the 

fuel needed for construction-related activities. Large amounts of gasoline and diesel petroleum products 

would be required for project construction. Additionally, construction would require the manufacture of 

new materials, some of which would not be recyclable at the end of the lifetime of the proposed 

project. The raw materials and energy required for the production of these materials would also result 

in an irretrievable commitment of natural resources. Operation of the proposed project would not cause 

a substantial increase in the consumption or use of nonrenewable resources.

Construction and operation of the proposed project would require the use of a limited amount of 

hazardous materials such as fuel, lubricants, and cleaning solvents. All hazardous materials would be 

stored, handled, and used in accordance with BMPs and applicable federal, state, and local regulations, 

including a construction-phase SWPPP and an operational phase SWPPP. Assuming appropriate 

implementation of these plans and practices as recommended in the conditions of certification, 

potential degradation of the environment attributable to accidental spills associated with the proposed 

project’s use of hazardous materials would not occur.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-128

Table 4-27. Irreversible and irretrievable commitment of resources by the Proposed Action

Resource Irreversible? Irretrievable? Commitments Explanation

Vegetation 

resources No Yes Approximately 1,628–1,673 acres of land would be committed for the life of the project, but could be reclaimed upon decommissioning. 

Wildlife resources No Yes

A total of 1,628–1,673 acres of wildlife habitat would be lost to 

development of the facility, but could be reclaimed upon 

decommissioning.

Special status 

species No Yes Habitat and an undetermined sum of individuals 

Water quality and 

quantity No Yes Water that is removed from the aquifer and used in the operations would not be available for other uses.

Wetlands, riparian 

zones, and waters 

of the United 

States

No No No wetlands, riparian zones, or waters of the United States are present 

in the project area.

Hazardous 

materials No No

No irreversible or irretrievable commitment of resources or impact is 

anticipated. However, if a spill were to affect a sensitive resource, an 

irretrievable impact could occur pending the recovery of the resource.

Air quality No No Emissions from the project would not deteriorate the existing air quality 

of the air quality management area.

Cultural resources Yes No Cultural resources would be documented and mitigated

Land use and 

access No Yes

Approximately 1,628–1,673 acres would be committed to the proposed 

project, which would not be available for other land uses or access 

within that area. The area would be available for other land uses and 

access upon decommissioning and reclamation of the area. 

Geology, minerals, 

paleontology Yes Yes

Mineral resources that are mined from the borrow pit (aggregate, sands, 

other construction materials) would no longer be available for future 

production. Impacts to paleontological resources (if present) would be 

irreversible.

Soils No No Soils excavated from the borrow pit or the generation site would be 

salvaged and stockpiled for future use in reclamation. 

Social, economic No No No socioeconomic resources would be irreversibly or irretrievably 

committed to this project. 

Environmental 

justice No No No environmental justice populations would be affected by the project; therefore, no associated resources would be committed.

Noise No No Noise is not considered irreversible because it would cease when 

construction and operation of the facility cease.

Visual resources No Yes

Impacts to visual resources would result from construction/operation of 

the facilities. Successful reclamation procedures at the end would return 

the visual continuity. However, because of the extended time required 

for the desert to recover to the point of such disturbances being 

unnoticeable, the commitment could be deemed irreversible.

Range resources No Yes

Temporary loss of 50–52 animal unit months throughout the life of the 

project, but reclamation of the facility after decommissioning would 

return the site to previous production levels. 

Recreation/

wilderness No Yes

Approximately 1,628–1,673 acres of lands potentially used for recreation 

would be committed to the project, but the lands would be available 

upon decommissioning of the area. 

Transportation/

traffic No No No commitment of resources associated with transportation would 

occur.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-129

4.18 Relationship between Short-Term Uses and Long-Term Productivity of 

the Environment

NEPA requires consideration of the relationship between short-term uses and long-term productivity of 

the environment (40 CFR 1502.16). This section discusses the short-term use of the local environment 

and the maintenance and enhancement of long-term productivity as a result of construction and 

operation of the proposed project.

For the purposes of this discussion, “short-term” is defined as the period from the onset of construction 

activities through the initiation of project operation. “Long-term” is defined as the entire operational life 

of the solar energy plant, which is anticipated to be 3 years of construction and 30 years or more of 

operation.

4.18.1 Short-Term Uses

The proposed short-term uses of the natural environment associated with the Proposed Action are the 

development of about 1,628–1,673 acres of land for the proposed solar power plant and ancillary 

facilities, the borrow pit, and TL; the consumptive use of approximately 800 AFY of groundwater over a 

30-month construction period; and the direct loss of localized vegetation and wildlife resources. Shortterm effects on the natural environment would result from land-clearing and construction activities. 

These would be related primarily to soil disturbance and air quality effects from site clearing and

grading, and an increase in noise and traffic in the local area.

Short-term effects on social and economic resources would be beneficial and would include an increase 

in revenue for some local businesses such as construction suppliers, hotels, restaurants, gas stations, 

and grocery stores.

4.18.2 Long-Term Productivity of the Environment 

The long-term productivity of the areas affected by the proposed project would depend on the 

effectiveness of the decommissioning and revegetation efforts that would be implemented in the 

project area. A reclamation plan would include recontouring the site after the facility is removed and 

redistributing topsoil prior to revegetating the site. Because of the low precipitation and relatively brief 

growing season in this high desert, reestablishing a fully functioning and productive ecosystem would

take time. Long-term effects to resources important to Native Americans would include visual effects.

4.19 Cumulative Impacts

4.19.1 Actions Considered for Cumulative Analysis

The CEQ regulations for implementing NEPA define cumulative effects as: 

“... the impact on the environment which results from the incremental impact of the action 

[project] when added to other past, present, and reasonably foreseeable future actions 

regardless of what agency (Federal or non-Federal) or person undertakes such other actions. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-130

Cumulative impacts can result from individually minor but collectively significant actions taking 

place over a period of time.” (40 CFR 1508.7)

Past, present, and reasonably foreseeable future actions will be identified for the geographic and 

temporal scope for the resources considered in the cumulative effects analysis. 

4.19.2 Regulations and Guidance

Cumulative effects may result from actions that include current and projected area development, 

management activities and authorizations on public land, land use trends, and applicable 

industrial/infrastructure components. Although the individual impacts of each separate project may not 

be significant, the additive effects of multiple projects could be. These past, present, and reasonably 

foreseeable future actions are analyzed to the extent that “they are relevant and useful in analyzing 

whether the reasonably foreseeable effects of the agency proposal for action and its alternatives may 

have an additive and significant relationship to those effects.”

4.19.3 Methodology for Assessing Cumulative Impacts 

The principles for cumulative effects analysis identified by CEQ—Considering Cumulative Effects under 

the National Environmental Policy Act (CEQ 1997)—have gained acceptance for use. These principles are 

based on the premise that resources, ecosystems, and the human community each can experience 

effects. For each of these, there are thresholds, or levels, of stress beyond which their desired 

conditions degrade.

Each affected resource, ecosystem, or human community must be analyzed in terms of its capacity to 

accommodate additional effects, based on its own geographic and temporal parameters. Appropriate 

cumulative effects analyses focus on what is needed to ensure long-term productivity or sustainability of 

the resource.

Information about past, present, and reasonably foreseeable future activities in the CESA were gathered 

from BLM, Nye County, and other agencies; land use plans; and personal communications with public 

agency representatives.

The approach to cumulative impacts of the proposed project considers “past” projects to be those that 

have completed construction and are in operation. These projects are included in the environmental 

baseline, described in the affected environment portion of each resource area. Since the impact analysis 

in each resource area assesses impacts in terms of changes to existing environmental conditions, past 

projects are not separately addressed in the cumulative analysis. “Present” projects include those that 

are currently under construction or have been fully permitted such that they are likely to be part of the 

existing environment when the proposed project has begun construction.

“Reasonably foreseeable” future projects are those for which a formal application has been filed and 

substantive progress has been made to move the projects forward. The working definition of 

“reasonably foreseeable” projects on BLM land is based on whether or not a draft or final Plan of 

Development has been filed with BLM by an applicant. The projects specifically considered in the 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-131

cumulative scenario for this project include other solar power projects and mining projects proposed on 

public land managed by BLM. 

4.19.4 Past and Present Actions

CEQ NEPA regulations and guidance on cumulative effects do not require development of a catalog of 

specific past actions or quantification of these actions in a cumulative effects analysis, and CEQ 

recognizes that this may not be practical and the information may not be available (40 CFR 1500–1508; 

and CEQ 2005). Therefore, description or quantification of individual past actions is typically not 

performed. However, past actions are considered collectively in describing the current health of each 

resource. 

Present actions are actions that are ongoing at the time of the analysis and are described individually. 

4.19.5 Reasonable Foreseeable Future Actions

Reasonably foreseeable future actions are those for which there are existing decisions, funding, formal 

proposals, or which are highly probable based on known opportunities or trends (BLM 2008a). When 

identifying reasonably foreseeable future actions for the cumulative effects analysis, reasonably 

foreseeable actions will include those actions within the geographic and temporal scope that meet one 

of more of the following criteria: 

• The action is included in an adopted long-range or comprehensive plan.

• The action is included in an existing proposal, such as a submitted permit application.

• The action has a commitment of resources, such as funding.

• If the action is federal, the NEPA process has been initiated.

In addition to these criteria, BLM considered the cumulative effects area for each resource area. BLM 

identified the resource with the largest CESA, which is socioeconomics (50-mile radius). Even though the 

cumulative area for other resources is substantially smaller, BLM determined that projects within 50 

miles could potentially affect socioeconomics and/or environmental justice (Table 4-28). 

Sierra Geothermal Power is proposing development of a geothermal energy facility in the southernmost 

portion of the Big Smoky Valley, approximately 15 miles north of Silver Peak, in Esmeralda County. This 

project is proposed on approximately 9,660 acres of lands managed by BLM. The project is 

approximately 25 miles from the proposed project, but is within the southern extent of the Big Smoky 

groundwater subbasin. 

Indeck Energy Services, LLC, has proposed development of a 20 MW solar energy project on 150 acres 

of lands that would be leased from Nye County at the Tonopah Airport, which is located approximately 8 

miles east of the town of Tonopah. The proposed project would be located approximately 13 miles from 

the project site. 

Iberdrola Solar has proposed development of a 30 MW photovoltaic solar energy project on 

approximately 200 acres of lands to be leased from Nye County at the Tonopah Airport. The airport is 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-132

approximately 8 miles east of the town of Tonopah, which is approximately 13 miles from the project 

site. 

Nye County has proposed development of a new TL from the Tonopah Airport, east of the town of 

Tonopah, in Nye County. The 3-mile-long TL would connect renewable energy projects proposed at the 

airport and an existing line along SH 6. The project is approximately 13 miles from the proposed project 

site. 

Midway Gold Corporation has proposed expanded exploration and future development of a mine 

approximately 20 miles east the project area. The project is east of the San Antone Mountains.

Tonopah Solar Energy, LLC, may consider purchasing the lands on which the project is being constructed 

subsequent to the ROW lease. 

Tonopah Solar Energy, LLC, may consider continuing operation of the plant for an additional 20-year 

period, thereby extending the total project lifetime to 50 years. If the project will operate for an 

additional 20 years, the identified direct, indirect, and cumulative effects would also continue for 

20 years.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-133

Table 4-28. Reasonable and foreseeable future projects

4.19.6 Cumulative Impacts, by Resource

Vegetation

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Wildlife

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Project Name

Project 

Proponent/

BLM Applicant

Location 

(County) Description Size (Acres)

Alum Site – 

Geothermal 

Exploration

Sierra Geothermal 

Power, Corp. 

15 miles north of Silver Peak, 

25 miles from project, 

southern extent of Big Smoky 

Valley (Esmeralda County)

Geothermal exploration for a potential 

geothermal energy facility. In 2010 

plan. Exploration continuing.

9,660 

Tonopah Airport 

Transmission Line Nye County

Transmission line from 

Tonopah Airport to the 

existing transmission line 

along State Highway 6 

(3 miles) (Nye County)

Development of 3 miles of power 

transmission line from airport to 

existing transmission line along State 

Highway 6. Planning stages.

TBD

Tonopah Airport 

Solar Project – 

Indeck

Indeck

Tonopah Airport, 8 miles east 

of Tonopah on State 

Highway 6 (Nye County)

Develop up to 20 MW of solar energy 

on airport property. Lease agreement 

signed with Nye County.

150 

Tonopah Airport 

Solar Project – 

Iberdrola

Iberdrola Solar Tonopah Airport, 8 miles east 

of Tonopah (Nye County)

Develop 10–30 MW of photovoltaic 

power on airport property. Planning 

stage for a potential lease agreement 

with Nye County for a 10–30 MW

photovoltaic facility.

200 

Midway Exploration 

Project (Mining)

Midway Gold 

Corporation

15 miles north of Tonopah; 

20 miles from project over 

San Antone Mountains; at 

State Highway 376 and 

Belmont Road, Ralston Valley 

(Nye County)

Proposed expanded exploration and 

development of an underground 

mine. BLM’s 2009 planning schedule 

indicated this project is on hold 

pending evaluation of water 

treatment options. No mention in the 

2010 planning schedule.

TBD

Crescent Dunes 

Solar Energy Project 

(Disposal) 

Tonopah Solar 

Energy Current project

Tonopah Solar Energy may propose to 

purchase the land after construction 

of the facility is completed. 

1,700 

Notes: BLM = Bureau of Land Management; MW = megawatt; TBD = to be determined
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-134

Special Status Species (Plants)

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Special Status Species (Wildlife)

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Water and Water Quality

Of the potential impacts identified, increased runoff and sediment transport are expected to have a 

potential cumulative effect. If ground surface disturbances in the surrounding watershed or adjacent 

areas have occurred in the past, are currently occurring, or will occur in the future attributable to 

activities unrelated to the proposed project (i.e., recreational vehicle use), cumulative impacts related to 

the project could occur within the CESA. 

Air Quality

At this time, there are insufficient data on the reasonably foreseeable future projects in the CESA to 

adequately perform an impact analysis (data are not available specifically on air quality emissions from 

these projects). If any of the listed projects were constructed during the same period as the Crescent 

Dunes Solar Energy Project, there may be an increase in dust emissions within the CESA. 

Cultural Resources

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Land Use and Access

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. However, if at the end of the 30-year lease term the land is made available 

by BLM for purchase, TSE may purchase the land, and it would be converted to permanent private 

ownership. BLM would not have control over any reclamation of the land, and it would be removed 

from public use.

Social and Economics

It is likely that development of this project—combined with development of reasonably foreseeable 

future projects—may have impacts on socioeconomics in the CESA. To date, insufficient information is 

available on the reasonably foreseeable future projects to make such an impact analysis and determine 

the potential cumulative effects.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 4-135

Visual Resources

The cumulative area, or viewshed, is defined as the area wherein the project facilities, including the 

solar field and TLs, are visible. The viewshed has an approximate radius of 10 miles in any direction from 

the project site. The proposed project would not be a dominant visual feature beyond 5 miles, and views 

beyond 10 miles of the project would be very difficult to discern. No other projects exist within the 10-

mile radius of this project; therefore, this project would not contribute to any visual cumulative impacts.

Hazardous Materials

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Range Resources

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.

Recreation and Wilderness 

At this time, there are no known or reasonably foreseeable future projects within the CESA that would 

create a cumulative effect. Therefore, the proposed Crescent Dunes Solar Energy Project is unlikely to 

have impacts that would combine cumulatively with other related past, present, and reasonably 

foreseeable future projects.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 5-1 

5.0Consultation and Coordination

This chapter summarizes the consultation and coordination activities conducted with interested 

agencies, organizations, tribes, and individuals for the proposed Crescent Dunes Solar Energy Project. 

The primary goal of the NEPA public involvement process is to ensure that all interested and affected 

parties are aware of the proposed project. For the purposes of public involvement, the NEPA process is 

divided into two phases: the scoping period and the Draft EIS review period. The scoping period includes

the initial presentation of the proposed project to the public and opportunities for the public and agency 

representatives to provide comments on the proposed project. The Draft EIS review period presents the 

public with opportunities to comment on the document. More information on these phases is presented 

in the sections below

5.1 Public Involvement Process

5.1.1 Scoping 

The Federal Register NOI was published on November 24, 2009, marking the beginning of the scoping 

period for the project. The scoping period ended on December 24, 2009. This period fulfilled the BLM 

minimum requirement of a 30-day scoping period. 

Announcements for the public scoping meetings were published in a variety of local newspapers (see 

Table 5-1). Additionally, scoping meeting dates, times, and locations were posted on the BLM TFP Web 

site (BLM 2010b). A public service announcement was also made on News 88.9 KNPR Nevada Public 

Radio on November 24, 2009. 

Public meetings are required when there is a substantial “environmental controversy concerning the 

proposed action or substantial interest in holding the [meeting]” or when there is a “request for a 

hearing by another agency with jurisdiction over the action” (40 CFR 1506.6). Public scoping meetings 

locations, dates, and number of attendees are provided in Table 5-1. In accordance with BLM 

requirements, sign-in sheets were provided and attendees were encouraged to sign in. 

Table 5-1. Public meeting information

Meeting Location Date

Number 

of Attendees

Tonopah Convention Center

301 Brougher Ave

Tonopah, Nevada

Thursday, December 17, 2009 42 

BLM Southern Nevada District Office

4701 N. Torrey Pines Drive

Las Vegas, Nevada

Friday, December 18, 2009 6 

Note: All meetings were held from 6–8 p.m.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 5-2 

5.1.2 Final Environmental Impact Statement

Members of the public, agencies, organizations, tribes, and jurisdictions will be provided an opportunity 

to comment on the Draft EIS. 

Upon receipt and consideration of the public comments on the DEIS, the BLM TFO will publish the FEIS. 

Concurrently, the BLM TFO may publish a ROD and authorize the ROW applications. The ROD would

identify the selected alternative for the proposed project. 

5.2 Formal Consultation with Interested Agencies and Tribal Government

Formal consultation was initiated by the BLM TFO in November 2009, when the project information was 

relayed to five tribes and various other family members known to have interests in the Tonopah and/or 

Big Smoky Valley areas. Consultation letters were subsequently distributed to the tribes, requesting 

their respective input on the project.

The BLM TFO conducted a site visit with the Timbisha on April 7, 2010. Present at the meeting were 

representatives of the Timbisha: Barbara Durham (Tribal Historic Preservation Office), Grace Goad, 

Pauline Esteves, Ed Esteves, Madeline Esteves, and Ted James. BLM was represented by TFO Manager 

Thomas Seley, TFO Archaeologist Scott Stadler, and Susan Rigby. The BLM Battle Mountain District 

Office was represented by Renewable Energy Coordination Office Manager Timothy Coward, Wendy 

Seley of Lands and Realty, and William Coyle of GIS. The Timbisha representatives were given a brief 

overview of the project and its alternative areas, followed by a site visit to the project area.

BLM conducted a second field trip and meeting with the Yomba Shoshone Tribe on July 12, 2010. The 

Yomba Shoshone Tribe was represented by Teola Brady, and Ester Birchim. Attendees from BLM 

included TFO Manager Thomas Seley, and TFO Archaeologist Susan Rigby. The Battle Mountain District 

Office was represented by Renewable Energy Coordination Office Manager Timothy Coward, and Battle 

Mountain District Office Native American Coordinator Gerald Dixon. 

5.3 List of Agencies, Organizations, and Persons to Whom Copies of the 

Environmental Impact Statement Were Sent

5.3.1 Federal Government

• BLM 

• Mojave South – Great Basin Resource Advisory Council 

• NRCS

• U.S. Air Force, 98th Range Wing, Nellis Air Force Base (98th RANW/XPL) 

• U.S. Air Force (HQ-USAF/LEEV) Environmental Division 

• U.S. Army Corps of Engineers 

• U.S. Army Corps of Engineers, Regulatory Section 

• U.S. Department of Energy, Office of Environmental Compliance (EH-23) 

• EPA

• EPA, Region IX 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 5-3 

• USFWS

• U.S. Air Force, Office of the Deputy A/S Environment, Safety, Occupational Health 

• U.S. Department of Agriculture, Humboldt Toiyabe National Forest 

• U.S. Department of the Interior, Bureau of Reclamation, Denver Federal Center (D-150) 

• U.S. Department of the Interior, Geological Survey, Environmental Affairs Program 

• U.S. Department of the Interior, National Park Service (2310), Division of Environmental Quality 

• U.S. Department of the Interior, Natural Resources Library 

• U.S. Department of the Interior, Office of Environmental Policy and Compliance 

5.3.2 State Government 

• Nevada Outdoor Recreation Association 

• NDOW

• NDOT 

• NDEP, Bureau of Air Pollution Control 

• NDEP, Bureau of Mining Regulation and Reclamation 

• NDEP, Bureau of Waste Management 

• Nevada Division of Minerals 

• Nevada Legislature 

• Nevada SHPO

• State of Nevada/Department/Administration State Clearinghouse 

• Wild Horse Commission

5.3.3 Local Government

• Nye County Environmental Department 

• Tonopah Chamber of Commerce 

• Tonopah Public Utilities 

• Tonopah Town Board 

• Town of Manhattan 

• Town of Round Mountain

5.3.4 Tribal Government 

• Ely Shoshone Tribe 

• Duckwater Shoshone Tribe 

• Timbisha Shoshone Tribe 

• Yomba Shoshone Tribe

5.3.5 Other Organizations 

• Earthworks 

• Friends of Nevada Wilderness 

• Great Basin Resource Watch 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 5-4 

• High Country Hay 

• Lahontan Audubon Society 

• Nevada Cattlemen’s Association

• Nevada Miner’s & Prospector’s Association 

• Nevada Mining Association

• Nevada Wilderness Project 

• Sierra Club 

• Nevada Wildlife 

• Truckee River Ranches 

• Western Mining Action Project 

• Western Watersheds Project

5.3.6 Elected Government Officials

• Joni Eastley, Nye County Commissioner

• Lorinda Wichman, Nye County Commissioner

• Nancy Boland, Esmeralda County Commissioner

• John Ensign, U.S. Senator 

• Ed Goedhart, Assemblyman 

• Jim Gibbons, Governor 

• Dean Heller, U.S. Congressman 

• Harry Reid, U.S. Senator 

5.3.7 Availability

Copies of the Crescent Dunes Solar Energy Project EIS are available for public review at the following 

public libraries and BLM offices:

Tonopah Library

167 South Central Street

Tonopah, NV 89049

The Beatty Library District

400 North Fourth Street

PO Box 129

Beatty, NV 89003-0129 

BLM Battle Mountain District Office

50 Bastian Road

Battle Mountain, NV 89820

BLM Tonopah Field Office

1553 South Main Street

Tonopah, NV 89049
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 6-1 

6.0List of Preparers and Reviewers

Table 6-1. List of BLM Reviewers.

Resource/Responsibility BLM Team 

Member Degree and Experience BLM Office Location

BLM Project Lead, National 

Environmental Policy Act 

Compliance Lead

Dave Davis

BS Forest Resources & 

Conservation, Wildlife, 

Range

30+ years experience

Battle 

Mountain 

District Office

Native American Traditional 

Values Gerald Dixon BS Cultural Anthropology

14 years experience

Battle 

Mountain 

District Office

Hydrology - Water Quality (Surface 

and Ground) and Water Use

Jon Sherve

MS 

Hydrology/Hydrogeology

BA Biological Sciences

16 years experience

Battle 

Mountain 

District Office

Tom Olsen

PhD Geology, Engineering, 

MS, BS Geology

28 years experience

Nevada State 

Office

Recreation/VRM/Wilderness Barb Kelleher BS Recreation

20 + years experience

Nevada State 

Office

Floodplains/Wetlands/Riparian Robert Hassmiller

BS Resource Conservation 

(emphasis in Terrestrial 

Systems and Hydrology)

5 years experience

Battle 

Mountain 

District Office

Hazmat Daniel Tecca BS Chemistry

19 years experience

Battle 

Mountain 

District Office

Migratory Birds, Wildlife, 

Threatened and Endangered 

Species (Plants and Animals), 

Special Status Species

Susan Cooper MS Zoology

10 years experience

Mount Lewis 

Field Office

Access and Land Use Wendy Seley

BA Business Management 

(emphasis Outdoor 

Recreation)

25 years experience

Battle 

Mountain 

District Office 

(RECO)

GIS William Coyle

MS GIS/Cartography

BS Park and Resource 

Management

1 year experience

Battle 

Mountain 

District Office 

(RECO)

Project Manager Timothy Coward 31 years project 

management experience

Battle 

Mountain 

District Office 

(RECO)
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 6-2 

Resource/Responsibility BLM Team 

Member Degree and Experience BLM Office Location

Cultural Resources, 

Paleontological Resources, Native 

American Traditional Values

Scott Stadler MS Anthropology

18 years experience

Tonopah Field 

Office

Susan Rigby

MA Anthropology

BS Biology

BS Geology

16 years experience

Tonopah Field 

Office

Migratory Birds, Wildlife, 

Threatened and Endangered 

Species (Plants and Animals), 

Special Status Species

Devin Englestead Tonopah Field 

Office

Minerals

Alan Buehler BS Geology

30 years experience

Tonopah Field 

Office

Duane Bays

MS Environmental Science

BS Environmental Science

BS Geology

9 years experience

Tonopah Field 

Office

Range Sheryl Post BS Range Science

15 years experience

Tonopah Field 

Office

Noxious Weeds, Invasive, Nonnative species Sheryl Post BS Range Science

15 years experience

Tonopah Field 

Office

Vegetation

Sheryl Post BS Range Science

15 years experience

Tonopah Field 

Office

Marc Pointel

BS Range Science/ Wildlife 

Science

35 years experience

Tonopah Field 

Office

Threatened and Endangered 

Species (Plants), Special Status 

Species

Marc Pointel

BS Range Science/ Wildlife 

Science

35 years experience

Tonopah Field 

Office

Soils Marc Pointel

BS Range Science/ Wildlife 

Science

35 years experience

Tonopah Field 

Office

Wild Horse and Burros Dustin Hollowell BS Forestry, Wildlife Mgmt

MS Range/Wildlife Science

Tonopah Field 

Office

Renewable Energy Coordinator Erin Eastvedt J.D. (Law)

1 year experience

Nevada State 

Office

Planning and Environmental 

Coordinator Brian Amme BA Cultural Anthropology

22 years experience

Nevada State 

Office

Hydrologist Sarah Peterson MS Hydrology

11 years experience

Nevada State 

Office

State Lead Travel Management Leo Drumm BS Recreation

31 years experience

Nevada State 

Office
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 6-3 

Table 6-2. Environmental Impact Statement Contractor and Subcontractors

Role/Responsibility Name/Firm Degree(S) Years of 

Exp.

Project Manager, NEPA 

Compliance, Hazardous 

Materials/Waste

Henrik Christensen

HDR

B.S. Environmental Mgmt 20

Assistant Project Manager, 

Vegetation, Wildlife, Special Status 

Species, Visual, Recreation and 

Wilderness

Stephanie Locke

HDR

M.S. Biology

B.S. Biology 6 

Range Resources, Biological 

Resources

Danny Rakestraw

HDR

M.S. Wildlife Ecology

B.S. Wildlife Ecology 21

Land Use, Recreation Sherri McMahon

HDR

M.A. Business Admin/Mgmt 19

GIS Support Preston Kessinger

HDR

B.S. Geography 11

Environmental Justice Audrey Unger

HDR

MEP. Environmental Policy 

and Management

B.S. Environmental 

Sciences/Studies

8 

Geology, Soils, Paleontology Gregg Mitchell

HDR

B.S. Environmental 

Technology

A.A. Liberal Arts/Sciences

22

Air Quality, Noise Dustin Watson

HDR

MEP Environmental

Sciences/Studies

BS Planning

19

Socio/Economic Resources Amy Edwards

HDR

M.S. Civil Engineering

B.S. Civil Engineering 19

Water Resources, 

Wetlands/Riparian Habitats

Scott Mars

HDR

M.S. Environmental

Engineering

B.S. Environmental

Engineering

22

Transportation/Traffic Laycee Kolkman, PE

HDR

M.S. Civil Engineering

B.S. Civil Engineering 7 

Visual Resources Pam Cecere

HDR

M.S. Community/Reg. 

Planning

B.A. Political

Science/Government

6 

Cultural Resources Marc Brodbeck

HDR

M.A. Anthropology

B.A. Anthropology 24

Native American Consultation

Ginny Bengston 

Bengston 

Consulting

M.A Anthropology

B.S. Anthropology 21
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 6-4 

Table 6-3. Technical Studies and Design Contractor(s) 

Role/Responsibility Name/Firm Degree(S) Years of Exp.

Engineering Manager, Project 

Description, Figures

Bob Anders, 

WorleyParsons B.S. Civil Engineering 26 

Environmental Manager Deborah Builder, 

WorleyParsons

J.D. Law

M.S. Environmental Studies

B.S. Biology

12

Groundwater Resources - impact 

evaluation preparation and 

technical peer review

Mike Tietze, 

WorleyParsons B.S. Geology 26 

Air Quality Review Joel Reisman, 

WorleyParsons

M.S. Mechanical Engineering

B.S. Mechanical Engineering

42 total; 30 

in air quality

Wastewater Plan which included 

design of the evaporation ponds Janine Forrest, 

WorleyParsons

B.S. Environmental 

Engineering 7 

Groundwater modeling, GER 

report review, GER work planning 

assistance 

Dennis Jamison, 

WorleyParsons

M.S. Engineering Science 

B.S. Geology 31

Groundwater modeling, GER 

report review, GER work planning 

assistance 

Andie Gehlhausen, 

WorleyParsons

B.A. Geology, 

M.S. Hydrogeology, 7 

Groundwater Basin Profile Miles Kenney, 

WorleyParsons

B.S. Geological Science & 

Chemistry

Ph.D Geological Sciences

20

Civil Engineer re: Site Design 

(survey coordination, drainage 

design, grading design, roadways 

and utilities, etc.)

Dave Alcoa, 

WorleyParsons

B.S. Engineering

M.S. Civil Engineering

Professional licenses in NV & 

CA

45

Project Manager - Test Well 

Program

Ed Baquerizo B.S. Environmental Biology

M.S. Water Resource

Engineering

25

Senior Technical Specialist Richard Antoline B.S. Chemical Engineering 10

Table 6-4. Project Proponent(s) 

Role/Responsibility Name/Firm Degree(S) Years of Exp.

Project Director Rob Howe

SolarReserve

B.S. Mechanical Engineering; 

B.S Foreign Service

M. A. International 

Economics

22 

Consultant (former Project 

Director)

Julie Way

SolarReserve 

(consultant)

B.S. Mechanical Engineering; 

M.B.A. 

25
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 6-5 

Role/Responsibility Name/Firm Degree(S) Years of Exp.

Senior Engineer

(Technical/System Review

Air Quality Review)

Charles Diep

SolarReserve

B.S. Chemical Engineering

P.E. Mechanical Engineering

21

Project Engineer David De Andrade

SolarReserve

M.S. Electrical Engineering;

P.E. license in Control 

Systems (registered in CA)

7.5

Project Engineer Scott Kaminski

SolarReserve

B.S. Human Resources 

Management

25

Development Manager Vaughan Johnson

SolarReserve

B.S. Civil Engineering;

P.E. license in Civil 

Engineering (registered in NJ, 

CA)

13

VP Development Tom Georgis

SolarReserve

B.A. International Studies;

M.B.A. 

20
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 7-1 

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Solar Energy Project. March 9, 2010. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-1 

8.0Glossary

Acre-foot: A unit commonly used for measuring the volume of water; equal to the quantity of water 

required to cover one acre (43,560 square feet or 4,047 square meters) to a depth of 1 foot (0.30 meter) 

and equal to 43,560 cubic feet (1,234 cubic meters), or 325,851 gallons.

Action: In the context of the National Environmental Policy Act (NEPA), describes activities proposed to 

meet a specific purpose and need and that may have effects on the environment, which are potentially 

subject to Federal control and responsibility. Federal actions generally fall into the categories of 

adoption of official policy, formal plans, and programs; or approval of specific projects. For this 

document, the term action applies to this specific project.

Affected environment: Existing biological, physical, social, and economic conditions of an area subject 

to change, both directly and indirectly, as the result of a proposed human action. 

Air quality: A measure of the health-related and visual characteristics of the air, often derived from 

quantitative measurements of the concentrations of specific injurious or contaminating substances.

Allotment:A unit of land suitable and available for livestock grazing that is managed as one grazing unit. 

Alluvium: A general term for clay, silt, sand, gravel, or similar consolidated material deposited during 

comparatively recent geologic time by a stream or other body of running water in the bed of the stream, 

river, or floodplain, or as a cone or fan at the base of a mountain slope.

Alternative: Any one of a number of options for a project.

Ambient: The surrounding natural conditions (or environment) in a given place and time, most 

commonly applied to air quality and noise.

American Indian tribe (or tribe): Any American Indian group in the conterminous United States that the 

Secretary of the Interior recognizes as possessing tribal status (listed periodically in the Federal 

Register).

Animal Unit Month: Grazing of a 1,000 pound cow with suckling calf for 1 month (or equivalent 

metabolic weight of other kinds of livestock). 

Angle of Incidence: The angle that a ray of sun makes with a line perpendicular to the surface. 

Aquifer: A water-bearing rock unit (unconsolidated or bedrock) that will yield water in a usable quantity 

to a well or spring.

Archaeological site: A discrete location that provides physical evidence of past human use.

Archaeology: The scientific study of the life and culture of past, especially ancient, peoples, as by 

excavation of ancient cities, relics, artifacts, etc.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-2 

Area of Critical Environmental Concern (ACEC): A Bureau of Land Management (BLM) designation 

pertaining to areas where specific management attention is needed to protect and prevent irreparable 

damage to important historical, cultural, and scenic values, fish or wildlife resources, or other natural 

systems or processes, or to protect human life and safety from natural hazards.

A-Weighted Sound Levels: Decibels (referenced to 20 micro-Pascals) as measured with an Aweighting 

network of a standard sound level meter, abbreviated dB(A).

Background (visual): That portion of the visual landscape lying from the outer limit of the middleground 

to infinity. Color and texture are subdued in this area, and visual sensitivity analysis here is primarily 

concerned with the two-dimensional shape of landforms against the sky.

Base Load: The average amount of electric power that a utility must supply in any period.

Baseline: The existing conditions against which impacts of the proposed action and its alternatives can 

be compared.

Basin: A depressed area having no surface outlet (topographic basin); a physiographic feature or 

subsurface structure that is capable of collecting, storing, or discharging water by reason of its shape 

and the characteristics of its confining material (water); a depression in the earth’s surface, the lowest 

part often filled by a lake or pond (lake basin); a part of a river or canal widened (drainage, river, stream 

basin).

Best Management Practices (BMPs): A suite of techniques that guide, or may be applied to, 

management actions to aid in achieving desired outcomes and help to protect the environmental 

resources by avoiding or minimizing impacts of an action.

Borrow: Earth material, such as sand or gravel, which has been taken from one location to be used as at 

another location.

Borrow Pit: An excavated area from which borrow has been obtained.

Clean Air Act of 1990: Federal legislation governing air pollution. The Clean Air Act established National 

Ambient Air Quality Standards for carbon monoxide, nitrogen oxide, ozone, particulate matter, sulfur 

dioxide, and lead. Prevention of Significant Deterioration classifications define the allowable increased 

levels of air quality deterioration above legally established levels and include the following:

Class I – minimal additional deterioration in air quality (certain national parks and wilderness areas).

Class II – moderate additional deterioration in air quality (most lands)

Class III – greater deterioration for planned maximum growth (industrial areas)

Clean Water Act of 1987: National environmental law enforced by the U.S. Environmental Protection 

Agency that regulates water pollution.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-3 

Code of Federal Regulations: The compilation of federal regulations adopted by federal agencies 

through a rule-making process. 

Cone of Depression: The depression of groundwater levels around a pumping well caused by the 

withdrawal of water. 

Cooperating Agency: Assists the lead Federal agency in developing an environmental assessment or 

environmental impact statement. The Council on Environmental Quality regulations implementing NEPA

define a cooperating agency as any agency that has jurisdiction by law or special expertise for proposals 

covered by NEPA (40 CFR 1501.6). Any Federal, state, or local government jurisdiction with such 

qualification may become a cooperating agency by agreement with the lead agency.

Council on Environmental Quality (CEQ): An advisory council to the President of the United States 

established by the National Environmental Policy Act of 1969. It reviews Federal programs for their 

effort on environmental studies, and advises the President on environmental matters. 

Cultural resources: Remains of human activity, occupation, or endeavor as reflected in districts, sites, 

buildings, objects, artifacts, ruins, works of art, architecture, and natural features important in human 

events.

Cumulative effect (or impact): The impact on the environment that results from the incremental impact 

of the action when added to other past, present, and reasonably foreseeable actions. Cumulative 

impacts are evaluated as part of the environmental impact statement (EIS), and may include 

consideration of additive or interactive effects regardless of what agency or person undertakes the 

other actions.

Decibel: A unit for expressing the relative intensity of sounds on a logarithmic scale from zero for the 

average least perceptible sound to about 130 for the average level at which sound causes pain to 

humans. For traffic and industrial noise measurements, the A-weighted decibel, a frequency-weighted 

noise unit, is widely used. The A-weighted decibel scale corresponds approximately to the frequency 

response of the human ear and thus correlates well with loudness.

Discharge: Outflow of surface water from a stream or canal (water). Discharge from an industrial facility 

that may contain pollutants harmful to fish or animals if it is released into nearby water bodies usually 

requires a permit issued by the U.S. Environmental Protection Agency and is monitored.

Distance zone: A visibility threshold distance where visual perception changes. They usually are defined 

as foreground, middleground, and background.

Drainage: The natural channel through which water flows some time of the year; natural and artificial 

means for affecting discharge of water as by a system of surface and subsurface passages. 

Drawdown: The lowering of the water level in a well as a result of withdrawal; the reduction in 

groundwater level at a point caused by the withdrawal of water from an aquifer. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-4 

Easement: A right afforded a person, agency, or organization to make limited use of another’s real 

property for access or other purposes.

Ecology: The relationship between living organisms and their environment.

Effect (or impact): A modification of the existing environment as it presently exists, caused by an action 

(such as construction or operation of facilities). An effect may be direct, indirect, or cumulative. The 

terms effect and impact are synonymous under the NEPA. A direct effect is caused by an action and 

occurs at the same time and same place (40 CFR 1508.8(a)). An indirect effect is caused by the action 

later in time or farther removed in distance, but still reasonably foreseeable. Indirect effects may 

include growth-inducing effects and other effects related to induced changes in the pattern of land use, 

population density or growth rate, and related effects on air and water and other natural systems, 

including ecosystems.

Electrical grid: An integrated system of electricity distribution, usually covering a large area.

Emission: Effluent discharged into the atmosphere, usually specified by mass per unit time, and 

considered when analyzing air quality.

Endangered Species: Plant or animal species identified by the Secretary of the Interior as endangered in 

accordance with the 1973 Endangered Species Act; Any species in danger of extinction throughout all or 

a significant portion of its range. 

Endangered Species Act of 1973: The Endangered Species Act requires Federal agencies to seek to 

conserve threatened and endangered species, use applicable authorities in furtherance of the purposes 

of the Endangered Species Act, and avoid jeopardizing the continued existence of any species that is 

listed or proposed for listing as threatened and endangered or destroying or adversely modifying its 

designated or proposed critical habitat. The U.S. Fish and Wildlife Service and the National Marine 

Fisheries Service are responsible for administration of this act.

Environment: The surrounding conditions, influences, or forces that affect or modify an organism or an 

ecological community and ultimately determine its form and survival.

Environmental Impact Statement (EIS): A document prepared to analyze the impacts on the 

environment of a proposed action and released to the public for review and comment. An EIS must 

meet the requirements of NEPA, CEQ, and the directives of the agency responsible for the proposed 

action.

Environmental justice: The fair treatment and meaningful involvement of all people regardless of race, 

color, national origin, or income with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies. Fair treatment means that no group of people including 

racial, ethnic, or socioeconomic group should bear a disproportionate share of the negative 

environmental consequences resulting from industrial, municipal, and commercial operations or the 

execution of Federal, state, local, and tribal programs and policies (see Executive Order 12898).
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-5 

Ephemeral wash or stream: A stream that flows only in direct response to precipitation in the 

immediate watershed or in response to the melting of a cover of snow and ice, and that has a channel 

bottom that is always above the local water table.

Erosion: The wearing away of the land surface by running water, wind, ice, or other geologic agents and 

by such processes as “gravitation creep.”

Eutectic: A single chemical composition that solidifies at a lower temperature than any other 

composition.

Federal Register: Published by the Office of the Federal Register, National Archives and Records 

Administration, the Federal Register is the official daily publication for rules, proposed rules, and notices 

of Federal agencies and organizations, as well as executive orders and other presidential documents.

Floodplain: That portion of a river or stream valley, adjacent to a river channel, that is built of sediments 

and is inundated with water when the stream overflows its banks.

Fluid Minerals: A BLM regulatory and legal term used to denote petroleum and natural gas resources.

Foreground: The visible area from a viewpoint or use area out to a distance of 0.5 mile. The ability to 

perceive detail in a landscape is greatest in this zone.

Fossil: Any remains, trace, or imprint of a plant or animal that has been preserved by natural processes 

in the earth’s crust since some past geologic time.

Geographic information system: A system of computer hardware, software, data, people and 

applications that capture, store, edit, analyze, and graphically display a potentially wide array of 

geospatial information.

Geology: The science that relates to the earth, the rocks of which it is composed, and the changes that 

the earth has undergone or is undergoing.

Global warming: An increase in the average temperature of the earth’s atmosphere and oceans. The 

term also is used to describe the theory that increasing temperatures are the result of a strengthening 

greenhouse effect caused primarily by manmade increases in carbon dioxide and other greenhouse 

gases. 

Groundwater: Subsurface water that fills available openings in rock or soil materials to the extent that 

they are considered saturated.

Habitat: A specific set of physical conditions in a geographic area(s) that surrounds a single species, 

group of species, or large community. In wildlife management, the major components of habitat are 

food, water, cover, and living space.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-6 

Heliostat: A mirror that reflects solar rays onto a central receiver. A heliostat automatically adjusts its 

position to track daily or seasonal changes in the sun's position. The arrangement of heliostats around a 

central receiver is also called a solar collector field or array.

Hydrology: The study of the movement, distribution, and quality of water throughout the earth, 

addresses both the hydrologic cycle and water resources.

Impact (or effect): A modification of the existing environment as it presently exists, caused by an action 

(such as construction or operation of facilities). An impact may be direct, indirect, or cumulative. The 

terms effect and impact are synonymous under NEPA.

Indirect effect (or impact): Secondary effects that occur in locations other than the initial action or later 

in time, but that are caused by the proposed action.

Infrastructure: The facilities, services, and equipment needed for a community or facility to function, 

such as and including roads, sewers, water lines, and electric lines.

Insolation: The solar power density incident on a surface of stated area and orientation, usually 

expressed as Watts per square meter or Btu per square foot per hour. 

Invasive species: Describes a large number of nonnative plant species whose introduction causes or is 

likely to cause economic or environmental harm or harm to human health.

Irretrievable: Applies primarily to the lost production of renewable natural resources during the life of 

the project. 

Irreversible: Applies primarily to the use of nonrenewable resources, such as minerals, cultural 

resources, wetlands, or to those factors that are renewable only over long time spans, such as soil 

productivity. Irreversible also includes loss of future options. 

Key Observation Point: An observer position on a travel route used to determine visible area. 

Kilowatt (kW): A standard unit of electrical power equal to 1000 watts, or to the energy consumption at 

a rate of 1000 joules per second. 

Kilowatt-Hour (kWh): 1,000 thousand watts acting over a period of 1 hour. The kWh is a unit of energy. 

1 kWh=3600 kJ. 

Labor force: All persons 16 years of age or over who are either employed or unemployed and actively 

looking for a job.

Land use plan: A plan or document developed by a government entity that outlines specific functions, 

uses, or management-related activities of an area, and may be identified in combination when joint or 

seasonal uses occur and may include land used for support facilities that are an integral part of the use.

Landform: A term used to describe the many land surfaces that exist as a result of geologic activity and 

weathering (e.g., plateaus, mountains, plains, and valleys).
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-7 

Landscape: An area composed of interacting ecosystems that are repeated because of geology, 

landform, soils, climate, biota, and human influences throughout the area. Landscapes are generally of a 

size, shape, and pattern, which are determined by interacting ecosystems. 

Lease: An authorization or contract by which one party (lessor) conveys the use of property toanother 

(lessee) in return for rental payments. In cases of resource production, lessees pay royalties to the lessor 

in addition to rental payments.

LEQ: The equivalent sound level, or the time-integrated continuous sound level, that represents the 

same sound energy as the varying sound levels, over a specified monitoring period.

Megawatt (MW): A unit for measuring power equal to 1,000 kilowatts, or 1 million watts. The 

productive capacity of electrical generators is measured in megawatts.

Mineral resources: Any inorganic or organic substance occurring naturally in the earth that has a 

consistent and distinctive set of physical properties. Examples of mineral resources include coal, nickel, 

gold, silver, and copper.

Minimal (impact): Unless otherwise specified, “minimal” shall mean non-deleterious impacts that are 

measurable on the short term.

Mitigation: The abatement or reduction of an impact on the environment by (1) avoiding a certain 

action or parts of an action, (2) employing certain construction measures to limit the degree of impact, 

(3) restoring an area to preconstruction conditions, (4) preserving or maintaining an area throughout the 

life of a project, (5) replacing or providing substitute resources to the environment, or (6) gathering data 

(e.g., archaeological or paleontological) prior to disturbance.

Molten salt: A heat transfer medium found inside the central receiver. Can be heated up to 1,200°F. 

Molten salt is primarily used due to the fact that it can remain heated for a long period of time, even 

after the sun has set.

Multi-Use: Land use where a combination of use types can be found in close proximity together: 

commercial, residential, public, industrial, etc.

National Ambient Air Quality Standards: The allowable concentrations of air pollutants in the air 

specified by the Federal government. The air quality standards are divided into primary standards 

(based on the air quality criteria and allowing an adequate margin of safety and requisite to protect the 

public health) and secondary standards (based on the air quality criteria and allowing an adequate 

margin of safety and requisite to protect the public welfare) from any unknown or expected adverse 

effects of air pollutants.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-8 

National Environmental Policy Act of 1969 (NEPA): An Act that establishes policy, sets goals, and 

provides means for carrying out the environmental protection policy of the Nation. In accordance with 

NEPA, all Federal agencies must prepare a written statement on the environmental impacts of a 

proposed action. The provisions to ensure that Federal agencies act according to the letter and spirit of 

NEPA are in the CEQ regulations for implementing NEPA (43 CFR 1500-1508).

National Pollutant Discharge Elimination System: As authorized by the Clean Water Act, the National 

Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating 

point sources that discharge pollutants into waters of the United States. Industrial, municipal and other 

facilities must obtain permits if their discharges go directly to surface waters of the United States. These 

permits are referred to as NPDES permits and are administered by the USEPA. 

National Register of Historic Places: A listing, maintained by the Secretary of the Interior, of districts, 

sites, buildings, structures, and objects worthy of preservation. To be eligible a property must normally 

be at least 50 years old, unless it has exceptional significance, and have national, State, or local 

significance in American history, architecture, archaeology, engineering, or culture; and possess integrity 

of location, design, setting, material, workmanship, feeling, and association; and (a) be associated with 

events that have made a significant contribution to the broad patterns of history, (b) be associated with 

the lives of persons significant in our past, or (c) embody the distinctive characteristics of a type, period, 

or method of construction; represent the work of a master; possess high artistic values; or represent a 

significant and distinguishable entity whose components may lack individual distinction; or (d) have 

yielded, or may be likely to yield, information important to prehistory or history.

Native American Graves Protection and Repatriation Act: A Federal law passed in 1990 that provides a 

process for museums and Federal agencies to return certain Native American cultural items -- human 

remains, funerary objects, sacred objects, or objects of cultural patrimony -- to lineal descendants, and 

culturally affiliated Indian tribes and Native Hawaiian organizations. 

Negligible (impact): Unless otherwise specified, “negligible” shall mean impacts of such a small scale 

such as to be non-measurable.

Nevada Administrative Code:The text of the regulations implementing the laws passed by the Nevada 

legislature. 

Nevada Revised Statutes:The text of laws passed by the Nevada legislature. 

Noise Emission: The industry standard format of sound power level, which is the total acoustic power 

radiated from a given sound source as relates to a reference power level of 10 picowatts. Sound power 

level differs from sound pressure level, which quantifies the fluctuations in air pressure caused by 

acoustic energy.

Noise Level Measurements: Unless otherwise indicated, the use of A-weighted and "slow" response of a 

noise monitoring instrument complying with at least Type 2 requirements as defined by the latest 

revision of American National Standard Institute (ANSI) S1.4 Specification for Sound Level Meters.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-9 

Nonattainment area: An air quality control region (or portion thereof) in which the U.S. Environmental 

Protection Agency has determined that ambient air concentrations exceed national ambient air quality 

standards for one or more criteria pollutants.

Noxious weed: Nonnative plant species that negatively impact crops, native plant communities, and/or 

management of natural or agricultural systems. Noxious weeds are officially designated by a number of 

states (including Nevada) and Federal agencies.

Particulates: Minute, separate particles, such as dust or other air pollutants.

Perennial stream: A stream or that part of a stream that flows continuously during all of the calendar 

year as a result of groundwater discharge or surface runoff.

Perennial yield: The amount of usable water from a groundwater aquifer that can be withdrawn 

economically and consumed each year for an indefinite period of time. It cannot exceed the natural 

recharge to that aquifer and ultimately is limited to maximum amount of discharge that can be used for 

beneficial use.

Playa: The shallow central lake basin of a desert plain, in which water gathers after a rain and is 

evaporated.

Public land: Land or interest in land owned by the United States and administered through the Secretary 

of the Interior through the BLM without regard to how the United States acquired ownership, except 

lands on the Outer Continental Shelf, and land held in trust for the benefit of American Indians, Aleuts, 

and Eskimos.

Range: A large, open area of land over which livestock can wander and graze.

Rare: A plant or animal of limited distribution and/or abundance. May be locally abundant in a limited 

area or few in number over a wide area.

Recharge: Replenishment of a groundwater reservoir (aquifer) by the addition of water, through either 

natural or artificial means.

Reclamation: Restoration of land disturbed by natural or human activity (e.g., mining, pipeline 

construction) to original contour, use, or condition. Also describes the return of land to alternative uses 

that may, under certain circumstances, be different from those prior to disturbance.

Recontouring: Return a surface to or near to its original form through some type of action such as 

grading.

Record of Decision: A document separate from, but associated with, an EIS that publicly and officially 

discloses the responsible official’s decision on a proposed action.

Region of Influence: Area which is impacted by activities related to the project. Varies by species and 

activity. 
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-10

Revegetation: The reestablishment and development of self-sustaining plant cover. On disturbed sites, 

this normally requires human assistance such as reseeding.

Reverse osmosis: A separation process that uses pressure to force a solvent through a membrane that 

retains the solute on one side and allows the pure solvent to pass to the other side. More formally, it is 

the process of forcing a solvent from a region of high solute concentration through a membrane to a 

region of low solute concentration by applying a pressure in excess of the osmotic pressure.

Right-of-way: Land authorized to be used or occupied for the construction, operation, maintenance, and 

termination of a project, such as a road or utility.

Riparian: Situated on or pertaining to the bank of a river, stream, or other body of water. Riparian is

normally used to refer to plants of all types that grow along streams, rivers, or at spring and seep sites. 

Rural: Sparsely settled places away from the influence of large cities and towns. Such areas are distinct 

from more intensively settled urban and suburban areas, and also from unsettled lands such as outback 

or wilderness. People tend to live in villages, on farms, and in other isolated houses on large plots of 

land.

Scoping: The process open to the public early in the preparation of an EIS for determining the scope of 

issues related to a proposed action and identifying significant issues to be addressed in an EIS.

Sediment: Particulate matter that can be transported by fluid flow, and which eventually is deposited; 

Material suspended in or settling to the bottom of a liquid. Sediment input comes from natural sources, 

such as soil erosion and rock weathering, construction activities, or anthropogenic sources, such as 

forestry or agricultural practices. 

Sediment Load: The amount of sediment (sand, silt, and fine particles) carried by a stream or river. 

Sedimentation: The result when soil or mineral is transported by moving water, wind, gravity, or glaciers 

and deposited in streams or other bodies of water, or on land. Also, letting solids settle out of 

wastewater by gravity during treatment.

Sensitive receptor: In terms of noise, people or animals that may hear a noise or be sensitive to 

increased noise levels within their range of hearing.

Sensitive Receptor Location: A location of regulatory compliance where particular sensitivities to noise 

exist, such as residential areas, institutions, hospitals, parks, or other environmentally sensitive areas.

Sensitivity: The state of being readily affected by the actions of external influence.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-11

Special Development Area: sets aside public or private areas of special interest that would be subject to 

a specific plan of development or a Development Agreement in accordance with Nye County Code Title 

16.32. SDA is a mixed-use designation and a variety of land uses might be proposed for approval, such as 

the Yucca Mountain Project Gateway Area Concept Plan, and projects under review by the Bureau of 

Land Management, such as the Solar Energy Facilities. A property owner/developer must provide a 

specific plan of development for the subject property and obtain recommendations from the Planning 

Committee and the Town Advisory Board prior to Nye County Commission approval.

Solar Energy: Electromagnetic energy transmitted from the sun (solar radiation). The amount that 

reaches the earth is equal to one billionth of total solar energy generated, or the equivalent of about 

420 trillion kilowatt-hours.

Solar power tower: A solar energy conversion system that uses a large field of independently adjustable 

mirrors(heliostats) to focus solar rays on a near single point atop a fixed tower (receiver). The 

concentrated energy may be used to directly heat the working fluid of a Rankine cycle engine or to heat 

an intermediary thermal storage medium (such as a molten salt).

Sound Pressure Level (SPL): The observable effect of acoustic energy radiation, quantifying the sound 

level as perceivable by the receiver. When Sound Pressure is used to describe a noise source, the 

distance between source and receiver must be known in order to yield useful information about the 

power rating of the source.

Solar Thermal Electric Systems: Solar energy conversion technologies that convert solar energy to 

electricity by heating a working fluid to power a turbine that drives a generator. Examples of these 

systems include central receiver systems, parabolic dish, and solar trough.

Special status species: Wildlife and plant species either federally listed or proposed for listing as 

endangered or threatened; state-listed; or priority species of concern to Federal agencies or tribes.

Species:A group of individuals of common ancestry that closely resemble each other structurally and 

physiologically, and in nature interbreed producing fertile offspring. 

Sound power Level (PWL): A specialized analytical metric used to fully quantify the acoustic energy 

emitted by a source which is considered a complete value without the accompanying information on the 

position of measurement relative to the source. It may be used to calculate the sound pressure level at 

any desired distance away from the source.

Surface water: All bodies of water on the surface of the earth and open to the atmosphere such as 

rivers, lakes, reservoirs, ponds, seas, and estuaries.

Surfactant: Any substance that when dissolved in water or an aqueous solution reduces its surface 

tension or the interfacial tension between it and another liquid.

Terrain: Used to describe the geophysiographic characteristics of land in terms of elevation, slope, and 

orientation.
Proposed Crescent Dunes Solar Energy Project: Draft EIS| 8-12

Thermal storage: Storage of heated material for later heating or generation of steam for power 

production, potentially at night. 

Threatened Species: Any species of plant or animal that is likely to become endangered within the 

foreseeable future throughout all or a significant portion of its range. Animal or plant species that are 

listed under the Federal Endangered Species Act of 1973, as amended (federally listed), or under similar 

state laws (statelisted).

Total dissolved solids: A term that describes the quantity of dissolved material in a sample of water.

Traditional cultural places: These named places (landscape features) comprise the cultural landscape 

that provides the context for evaluating specific traditional cultural properties.

Transmissivity: The rate at which water is transmitted through a unit width of the aquifer under a unit 

hydraulic gradient.

Tribe: Any Indian tribe, band, group, or community having a governing body recognized by the Secretary 

of Interior.

Vegetation community or association: Species of plants that commonly live together in the same region 

or ecotone.

Visibility: The distance to which an observer can distinguish objects from their background. The 

determinants of visibility include the characteristics of the target object (shape, size, color, pattern), the 

angle and intensity of sunlight, the observer’s eyesight, and any screening present between the viewer 

and the object (i.e., vegetation, landform, even pollution such as regional haze).

Visual resource management classes: Categories assigned to public lands based on scenic quality, 

sensitivity level, and distance zones. There are four classes, each of which has an objective that 

prescribes the amount of change allowed in the characteristic landscape. 

Waters of the United States: All water bodies that are currently used, were used in the past, or may be 

susceptible to use in interstate or foreign commerce, including adjacent wetlands and tributaries; and all 

waters by which the use, degradation, or destruction of which would affect or could affect interstate or 

foreign commerce.

Watershed: All land and water within the confines of a drainage. 

Well field: Area containing one or more wells that produce usable amounts of water or oil.

Wetlands: Areas that are inundated or saturated by surface water or groundwater at a frequency and 

duration sufficient to support, and that under normal circumstances do support, a prevalence of 

vegetation typically adapted for life in saturated soil conditions. Examples of wetlands include marshes, 

shallow swamps, lakeshores, wet meadows, estuaries, and riparian areas.

Wilderness: An area formally designated by Congress as part of the National Wilderness Preservation 

System.