Subcontract Report

NREL/SR-550-48041

June 2010

Community Response to 

Concentrating Solar Power 

in the San Luis Valley

October 9, 2008 – March 31, 2010

B.C. Farhar, L.M. Hunter, T.M. Kirkland,

and K.J. Tierney

University of Colorado at Boulder
National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393

303-275-3000 • www.nrel.gov

NREL is a national laboratory of the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Operated by the Alliance for Sustainable Energy, LLC

Contract No. DE-AC36-08-GO28308

Subcontract Report

NREL/SR-550-48041

June 2010

Community Response to 

Concentrating Solar Power

in the San Luis Valley 

October 9, 2008 – March 31, 2010

B.C. Farhar, L.M. Hunter, T.M. Kirkland,

and K.J. Tierney

University of Colorado at Boulder

NREL Technical Monitor: Mark Mehos

Prepared under Subcontract No. AEK-9-88340-01
Disclaimer

The views expressed in this report are those of the authors, and do not represent the views or positions 

of the U.S. Department of Energy, the National Renewable Energy Laboratory, the Renewable and 

Sustainable Energy Institute, nor the University of Colorado.

NOTICE

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recommendation, or favoring by the United States government or any agency thereof. The views and 

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iii

Preface

The study "Social, Economic, and Policy Factors Affecting the Siting of a 100-MW 

Concentrating Solar Power (CSP) Facility in Colorado's San Luis Valley" was a joint effort of 

the University of Colorado (CU) and the National Renewable Energy Laboratory (NREL). The 

CU study, conducted at the Institute of Behavioral Science, was funded by NREL and the Energy 

Initiative—now the Renewable and Sustainable Energy Institute (a joint institute of CU and 

NREL). The period of performance for the study was originally November 2006 through 

February 2009. The NREL portion of the study was funded by contract to co-principal 

investigator Barbara Farhar, the first author of this report. The period of performance for the 

contract was October 9, 2008 through March 31, 2010.

A Research Advisory Committee provided guidance on key questions and groups to include in 

the study. Committee members were: Mark Mehos, NREL; Fred Morse, Chairman, Utility-Scale 

Solar Power Division, Solar Energy Industries Association; Mike Wisdom, San Luis Valley 

Regional Development Group; Mike Bowman, 25 x '25; and Marty Smith, Xcel Energy. 

Part of this report is based on interviews with representatives of 25 key stakeholder groups 

within and outside the San Luis Valley. The CU principal investigator was Kathleen J. Tierney, 

Ph.D., and Lori M. Hunter, Ph.D., was also a co-principal investigator. Tracy M. Kirkland, a 

doctoral candidate in the Department of Sociology, provided graduate research assistance on the 

joint project. 

Other research assistance was provided to Dr. Farhar by Gregg Eisenberg (Iron Mountain 

Consulting) who did the primary work on the transmission issues after the interviewing ended, 

and Linda Giudice (graduate student, University of Colorado at Boulder) who did the primary

work on the Bureau of Land Management Programmatic Environmental Impact Statement 

process. Therese Edwards and Teresa Foster provided research assistance on coding. Sarah 

Leshan provided editorial support. 

Many helpful suggestions on the manuscript were made by reviewers Adam Reed, Center for 

Energy and Environmental Security, University of Colorado Law School; Timothy Schoechle, 

Consultant; Fred Morse; and Bill Mansheim, Adams State College. Any errors are the 

responsibility of the authors.
iv

“The Valley is an economically depressed region and CSP represents the biggest 

economic development opportunity that has happened in the world. There is a 

juxtaposition of the vulnerability of the Valley because of its poverty and its unique 

cultural heritage on the one hand and this great opportunity on the other.”

- A stakeholder from outside the Valley 

“I look over this Valley over the last 20 years...when we first got here you could see 

Alamosa, you could see Monte Vista...you could see the population centers. Now, it’s just 

all lights at night. No one seems to want to turn anything off...it’s sad. With this new 

transmission line that is coming in, that’s another indicator that there are just going to be 

more lights. Do we need more light? Are we so afraid of the dark as a culture that we 

have to have lights on 24/7? I think we are. We’re a bunch of fraidy cats...this 

transmission marketing scheme is all fear-based.”

- A stakeholder from within the Valley 

“Our people are very vocal...if they came in and worked with us, there wouldn’t be much 

opposition. But if an outside group tried to come in and strong-arm us, this is a tough 

community. We want to protect the environment and to protect against big government 

and corporations. If it is done properly and through the right channels...so, really, it is 

how it is done.”

- A stakeholder from within the Valley
v

Executive Summary

This report is about the social acceptance of utility-scale renewable energy projects. In particular, 

it focuses on concentrating solar power (CSP) plants in the San Luis Valley (SLV or Valley), a 

large, sunny, high desert in south central Colorado, located within 200 miles of greater Denver. 

The research focused on social factors that may facilitate and impede the adoption and 

implementation of CSP—a technology that captures the sun's thermal energy using curved 

mirrors to focus sunlight onto a high temperature receiver. 

During the winter of 2008-2009, qualitative in-depth interviews were conducted with a purposive 

sample of 25 CSP-related stakeholders inside and outside the SLV of Colorado. Interviews 

focused on the perceived advantages and disadvantages of siting a hypothetical 100-MW CSP

facility in the Valley, the level of community support and opposition to CSP development, and 

related issues, such as transmission. 

Key groups included education, advocacy, and professional organizations within and beyond the 

Valley; SLV economic groups; government and regulatory agencies, organizations, and 

representatives; farmer and rancher groups; CSP industry groups; environmental organizations;

and utilities. Content analysis resulted in five categories of perceived advantages and 

disadvantages: economic, environmental, technological, social-psychological, and regulatory. 

Perceived benefits included potential improvements in the SLV economy, job creation, local tax 

property and other tax revenues to local counties, provision of clean energy, putting land to best 

use, reducing greenhouse gas emissions, addressing climate change, improving the security and 

diversity of power supplies, reducing dependence on imported energy, providing dispatchable 

energy, a source of community pride, positive effects on community identity, and helping to 

meet Colorado's renewable portfolio standard. 

If the not-in-my-backyard (NIMBY) syndrome is defined as a community's hypocritical espousal 

of renewable energy while rejecting its geographical presence, then no evidence was found for a 

“NIMBY-syndrome” response to CSP. Concerns included the need for water for CSP 

development, land-use intensity, concern that a boom-bust cycle might result from CSP plant 

construction and that permanent jobs would be minimal, concern that transmission would be 

needed to export CSP power, hesitation about the efficacy of CSP technology, intermittency of 

solar power, concern that CSP is difficult for residents to conceptualize, and concern that it is 

difficult for Valley residents to deal with Xcel Energy. Valley stakeholders emphasized concerns 

somewhat differently than did those outside the Valley—Valley stakeholders emphasized 

environmental and social-psychological benefits more than stakeholders outside the Valley, 

whereas outside-the-Valley stakeholders tended to emphasize technological benefits (especially 

energy storage). Both groups emphasized the economic advantages for the SLV, but Valley 

stakeholders focused more than outsiders on boom-bust cycle concerns.

Stakeholders indentified supporters and opponents of CSP and transmission development, 

including 125 different stakeholder groups representing agriculturists, farmers, ranchers, and 

their associations; CSP developers and their trade associations; environmental organizations; 

SLV economic development organizations; educational institutions; elected officials, federal 

electricity agencies; federal government entities; state government entities; local and regional 
vi

government entities and non-government organizations; landowners; law firms; private 

companies; the public; solar and sustainable resource advocates; spiritual groups; utilities and 

transmission line owners; and water interests.

Three different models of CSP facility and transmission siting decision-making were elicited 

from stakeholder interviews. These were (1) SLV Power Authority decision-making, (2) county 

permitting, and (3) permitting of utility-scale solar projects on public lands. Some Valley 

stakeholders supported local development and management of distributed energy systems.

In May 2009, just after the interviewing was completed, Xcel Energy and Tri-State Electric 

Generation and Transmission Association filed for a Certificate of Public Convenience and 

Necessity (CPCN) for a 230-kV transmission line from Calumet Substation into the San Luis 

Valley at Highway 160 over La Veta Pass. A controversy erupted over the proposed San Luis 

Valley-Calumet-Comanche transmission line; an adversarial proceeding ensued as part of the 

Public Utilities Commission decision process on the utilities’ application. Leading the opposition 

to the line was the Trinchera Ranch.

The Bureau of Land Management, which has a backlog of applications for permits to site largescale solar facilities on public lands, also conducted public hearings for a Programmatic 

Environmental Impact Statement (PEIS) for solar development on public lands in six western 

states, including the SLV. Decisions on all matters were pending as of March 31, 2010, when 

this report was completed. 

Widespread support was found for “solar energy” development in the SLV and Valley 

stakeholders took a great deal of pride in the SunEdison 8.22-MW PV system near Mosca. 

However, the Valley's residents lack knowledge on renewable energy technologies; for example, 

widespread confusion was found among stakeholders on the difference between PV and solar 

thermal electric systems. Education on renewable energy is needed for the Valley's stakeholders 

and residents.

Siting of CSP facilities and of the transmission line involve complex decision processes with a 

confusing mix of entities and procedures. Public meetings and hearings have been held by 

independent power producers, the Bureau of Land Management, the Rural Utility Service, the 

Colorado Public Utility Commission, and others. Supporters of the transmission line and 

opponents of it have testified at these meetings. Some Valley stakeholders feel overwhelmed by 

the attention and demands on their time made by developers and decision makers. An integrated 

and transparent decision process is needed that fully and effectively integrates federal and state 

policies with concerns of the local area.

State policy recommendations based on the findings include developing education programs for 

SLV residents, integrating Valley decision makers into an energy-water-land group, providing 

training for Valley decision makers, offering workforce training, evaluating models of taxation, 

and forming landholder energy associations. In addition, the SLV could become a laboratory for 

new approaches to CSP facility and transmission siting decision-making. 
vii

Those outside the Valley must address community concerns and engage Valley residents in CSP 

decisions. The opportunity to protect vulnerable communities and to engage them in CSP and 

transmission decisions, benefitting from their expertise rather than treating them as adversaries, 

should parallel in significance the investment in solar technology.
viii

Abbreviations and Acronyms

ARRA American Reinvestment and Recovery 

Act

BLM Bureau of Land Management

CEDA Clean Energy Development Authority

CFR Code of Federal Regulations

COSEIA Colorado Solar Energy Industries 

Association

CPCN Certificate of Public Convenience and 

Necessity

CRES Colorado Renewable Energy Society

CSP concentrating solar power

CU University of Colorado

DG distributed generation

DOE U.S. Department of Energy

DOI U.S. Department of the Interior

DSM demand-side management

DWP Los Angeles Department of Water and 

Power

EMFs electro-magnetic fields

ERZ Energy Resource Zone

FERC Federal Energy Regulatory Commission

FLPMA Federal Land and Policy and 

Management Act

GEO Colorado Governor's Energy Office

IOUs investor-owned utilities

IPP independent power producer

IPPs independent power producers

ITC Investment Tax Credit

kWh/m kilowatt-hours/meter

LGIT large generator integration process

LULUs “locally unwanted land uses”

MOU Memorandum of Understanding

MW megawatt

NEPA National Environmental Policy Act

NERC North American Electric Reliability 

Corporation

NIMBY “not in my backyard”

NOI Notice of Intent

NREL National Renewable Energy Laboratory

PV photovoltaic

PEIS Programmatic Environmental Impact 

Statement

PPA power purchase agreement

PUC Colorado Public Utilities Commission
ix

REC Rural Electric Cooperative

RFR right of first refusal

RMPs Resource Management Plans

ROW rights-of-way

RPS renewable portfolio standards

RUS Rural Utility Services

SESAs Solar Energy Study Areas

SLB State Land Board

SLV San Luis Valley

SWEEP Southwest Energy Efficiency Project

USDA U.S. Department of Agriculture

USFS U.S. Forest Service

WAPA Western Area Power Administration

WECC Western Electric Coordinating Council

WGA Western Governors' Association

WRA Western Resource Advocates
x

Contents

Preface............................................................................................................................................iii

Executive Summary........................................................................................................................ v

Abbreviations and Acronyms ......................................................................................................viii

Contents.......................................................................................................................................... x

1 Introduction and Background ................................................................................................. 1

1.1 Introduction........................................................................................................................ 1

1.2 Sociological Aspects of Renewable Energy Siting............................................................ 2

1.3 Background........................................................................................................................ 3

1.3.1 CSP Technology and the SLV.................................................................................. 4

1.3.1.1 CSP Benefits. ..................................................................................................... 5

1.3.1.2 Policy Recommendations................................................................................... 6

1.3.2 The Research Setting ................................................................................................ 7

1.4 Parts of the Report ............................................................................................................. 8

2 Methods ................................................................................................................................ 10

2.1 Introduction...................................................................................................................... 10

2.2 The Research Questions................................................................................................... 10

2.3 Stakeholder Analysis ....................................................................................................... 11

2.3.1 Sampling ................................................................................................................. 12

2.3.2 Data Collection ....................................................................................................... 13

2.3.3 Analysis................................................................................................................... 14

2.4 Review of the BLM's PEIS Process................................................................................. 14

2.5 The Transmission Controversy........................................................................................ 14

Part One: Findings from the Interviews.................................................................................. 16

3 Perceived Advantages........................................................................................................... 17

3.1 Introduction...................................................................................................................... 17

3.2 Economic Advantages ..................................................................................................... 18

3.3 Environmental Advantages.............................................................................................. 20

3.4 Technological Advantages............................................................................................... 21

3.5 Social-Psychological Advantages.................................................................................... 23

3.6 Policy and Regulatory Advantages.................................................................................. 25

4 Perceived Disadvantages ...................................................................................................... 26

4.1 Introduction...................................................................................................................... 26

4.2 Environmental Disadvantages ......................................................................................... 27

4.2.1 Water Constraints.................................................................................................... 27

4.2.2 Land-Use Intensity.................................................................................................. 28

4.3 Economic Disadvantages................................................................................................. 29

4.4 Technological Disadvantages .......................................................................................... 30

4.5 Social-Psychological Disadvantages ............................................................................... 31

4.6 Policy and Regulatory Disadvantages ............................................................................. 32
xi

5 Community Support and Opposition .................................................................................... 33

5.1 Introduction...................................................................................................................... 33

5.2 Stakeholders Identified Relative to CSP in the SLV ....................................................... 34

5.3 Self Protection in the Valley............................................................................................ 37

5.4 Community Positions for and against Renewable Energy in General............................. 39

5.5 Community Positions for and against CSP Development ............................................... 39

5.6 Don't Know What Stakeholders Feel............................................................................... 43

5.7 Perceived Need for Education ......................................................................................... 43

6 Transmission Issues Raised by Stakeholders........................................................................ 44

6.1 Introduction...................................................................................................................... 44

6.2 Support for Transmission................................................................................................. 44

6.2.1 Desire to Export Power........................................................................................... 44

6.2.2 Need for Security and Redundancy ........................................................................ 45

6.2.3 Need for Improved Power Infrastructure................................................................ 46

6.2.4 Neutral Comments.................................................................................................. 48

6.3 Opposition to Transmission ............................................................................................. 48

6.3.1 Fear of Industrialization of the Valley Floor .......................................................... 48

6.3.2 Aesthetic Concerns ................................................................................................. 48

6.3.3 Fear of Loss of Control........................................................................................... 49

6.3.4 Wildlife Concerns................................................................................................... 49

6.3.5 Legal-Regulatory Concerns.................................................................................... 49

7 CSP Facility and Transmission Siting Decision Models...................................................... 50

7.1 Introduction...................................................................................................................... 50

7.2 SLV Power Authority Decision-Making ......................................................................... 50

7.3 County Permitting............................................................................................................ 53

7.3.1 The Role of Private CSP Development .................................................................. 55

7.3.2 Xcel Energy’s Role................................................................................................. 56

7.3.3 The Role of Colorado Public Utilities Commission (PUC).................................... 57

7.4 Permitting for Solar Energy Development on Public Lands ........................................... 58

7.5 Permitting for Transmission on Public Lands ................................................................. 58

7.6 Other State Organizations with Potential Decision Authority......................................... 59

7.6.1 Governor's Energy Office (GEO) ........................................................................... 59

7.6.2 Clean Energy Development Authority.................................................................... 60

7.6.3 Water Conservation District ................................................................................... 60

7.6.4 Local Representatives and Members of Economic Development Groups ............. 60

7.6.5 Colorado State Land Board..................................................................................... 61

7.6.6 Colorado Department of Transportation................................................................. 61

7.6.7 Colorado State Treasurer's Office........................................................................... 61

7.6.8 Transmission Planning Groups............................................................................... 61

7.7 State Legislation............................................................................................................... 62

7.7.1 S.B. 07-100 ............................................................................................................. 62

7.7.2 SB 07-091 ............................................................................................................... 63
xii

Part Two: The SLV Transmission Controversy ...................................................................... 65

8 The SLV Transmission Controversy .................................................................................... 66

8.1 Introduction...................................................................................................................... 66

8.2 Policy Context.................................................................................................................. 66

8.2.1 Federal Policy ......................................................................................................... 67

8.2.1.1 BLM Policy Memorandum.............................................................................. 67

8.2.1.2 BLM-DOE PEIS.............................................................................................. 67

8.2.1.3 Investment Tax Credit (ITC) .......................................................................... 67

8.2.1.4 DOE Report to Congress ................................................................................. 67

8.2.2 Colorado Policy ...................................................................................................... 67

8.3 The Current Situation....................................................................................................... 68

8.4 Xcel Energy and Tri-State Perspectives .......................................................................... 70

8.5 Trinchera Ranch Perspective ........................................................................................... 71

8.6 Local Environmental Perspectives................................................................................... 72

8.7 Western Resource Advocates Perspective ....................................................................... 74

8.8 Perspectives of the Colorado Division of Wildlife and Colorado Open Lands............... 75

8.9 County Government Perspectives.................................................................................... 75

Part Three: Discussion, Conclusions, and Recommendations............................................... 77

9 Discussion, Conclusions, and Recommendations................................................................. 78

9.1 Summary Review............................................................................................................. 78

9.2 Research Questions and Answers.................................................................................... 79

9.3 Proponent Statements in Light of Study Findings........................................................... 84

9.4 Conclusions...................................................................................................................... 85

9.5 State Policy Recommendations........................................................................................ 86

9.6 Concluding Remarks........................................................................................................ 87

References and Bibliography.................................................................................................... 88

Afterword..................................................................................................................................... 92

Appendix A: Summary of the BLM PEIS Process................................................................. 93

A-1.1 Background.................................................................................................................. 94

A-1.2 Chronology of Key Events.......................................................................................... 94

A-1.2.1 PEIS on Energy Transmission Corridors in the West. ....................................... 96

A-1.2.2 Related Federal Actions...................................................................................... 96

A-1.2.3 PEIS on Solar Energy Development................................................................... 96

A-1.2.4 Designation of the Solar Energy Study Areas (SESAs) in the San Luis Valley. 97

A-1.2.5 Public Comment Process. ................................................................................... 99

A-1.3 Summary.................................................................................................................... 105

Appendix B: Chronology of Key Events in the SLV Transmission Siting Controversy... 106
1

1 Introduction and Background

1.1 Introduction

This report is about the social acceptance of utility-scale renewable energy projects. In 

particular, it focuses on concentrating solar power (CSP) plants in the San Luis Valley―a large, 

sunny, high desert in south central Colorado, located within 200 miles of greater Denver. 

Although this research is primarily focused on generation, transmission issues emerged as an 

important aspect because CSP is most feasible with a means to export the power from the Valley. 

Although the transmission issue that emerged related to CSP, it ultimately pertains to any form 

of utility-scale generation.

Social acceptance of utility-scale renewable energy projects has long been recognized as one of

the most powerful factors in achieving renewable energy goals.1 However, barriers to the social 

acceptance of renewable energy facilities present new challenges that must be addressed if U.S. 

renewable energy objectives are to be met. Unfortunately, little systematic knowledge exists on 

public receptivity to the siting of different types of renewable energy facilities, even though 

facilities differ in characteristics likely to influence public acceptance, such as their appearance 

and the size of their geographic footprints. For example, recent research has focused on the siting 

of large wind turbines,2 but it is not clear how findings from research on that particular 

technology might be transferable to other utility-scale renewable energy facilities. 

The research in this report analyzes social factors that may facilitate and impede the adoption 

and implementation of another type of renewable energy technology—concentrating solar power

(CSP). CSP technologies capture the sun's thermal energy using curved mirrors to focus sunlight 

onto a high temperature receiver. The first commercial CSP plants have been in operation in 

California since the mid-1980s, providing hundreds of megawatts (MW) of the world's lowestcost solar power. The many types of systems under development (parabolic troughs, power 

towers, dish engine systems, and linear Fresnel systems) vary in terms of energy concentration 

technologies used—such as concentration devices, conversion methods, and storage options—

and in terms of their aesthetic features.

Social factors are important in siting decision-making. Although the conventional energy 

industry is well acquainted with prevailing energy facility siting decision-making procedures, the 

renewable energy community is still climbing the learning curve. We found that a major obstacle 

to CSP and transmission siting is the complexity of decision-making on siting central CSP 

facilities and new transmission lines. Decision roles appear to be compartmentalized by various 

groups; the decision processes for this new technology—which are not well understood by 

stakeholders and the public—are not even fully understood by decision makers themselves. An 

integrative decision role seems lacking.

 1

 Carlman 1982; Wustenhagen et al. 2007 2 Alvarez-Farizo and Hanley 2002; Devine Wright 2005; Devlin 2005.
2

Furthermore, contemporary decision models themselves evolved in an earlier era of conventional 

energy development and may be peculiarly suited to the specific needs of those industries. 

Therefore, new decision models are needed that are consonant with the needs of CSP siting. For 

example, competition for extensive real estate is a key issue for CSP in the San Luis Valley 

(SLV). New transmission lines are needed in areas where they have never been located to bring 

CSP electricity to demand centers. This issue can be controversial, even in communities that 

espouse renewable energy development. Key questions about how the SLV can benefit from 

CSP development are identified in this report and remain to be answered. Transmission siting 

also ties into the tension in communities between preferences for distributed photovoltaic (PV)

systems, medium-scale PV systems, and utility-scale centralized solar energy systems (PV or 

CSP).

This report documents experiences and perspectives of stakeholders within and outside the 

Valley. Renewable energy and transmission stalwarts are working diligently to overcome 

institutional barriers to renewable energy development and transform existing siting decision 

processes. In this, they are challenging conventional energy industries and working to forge new 

transmission lines on lands where none existed before to bring far-flung wind, solar, geothermal, 

and other renewable resources to energy demand centers. Inevitably, conflicts arise and 

adversarial proceedings ensue.

The National Environmental Policy Act (NEPA) requires analysis, review, and mitigation of 

negative socio-economic impacts of major proposed actions on federal lands that include federal 

funding and public participation in decision-making. Some of the renewable energy 

community—accustomed to thinking of itself as offering energy solutions superior from an 

environmental perspective to carbon-based electricity—may believe that their proposed projects 

should be exempted from major environmental and socio-economic review processes, especially 

in light of what is increasingly identified as a global climate emergency. From this standpoint, 

any local community identified by scientists, policy makers, and industry as highly suitable for 

solar or wind development should welcome, or at least not resist, proposed renewable energy 

facilities in their areas that have the end goal of decarbonizing the electricity supply.

Nevertheless, local communities are embedded in familiar landscapes, dependent on local 

economic interests, and reliant on a prevailing cultural heritage on which proposed projects may 

uncomfortably impinge. Moreover, they raise questions about local control and about what a 

project can bring to them economically—particularly as projects are carried out by private 

corporations for profit, some of which can be expected to leave the local area. They ask what the 

proposed project will mean to the identity of the local community. These broader issues of 

utility-scale renewable energy project development apply to CSP specifically and to facility and 

transmission siting in the SLV. Although federal action has been taken to speed solar 

development on public lands, the laws and procedures governing socio-economic and 

environmental review and mitigation of adverse socio-economic impacts still need to be 

recognized and respected within and beyond the federal lands.

1.2 Sociological Aspects of Renewable Energy Siting

Research on opposition to facility siting in various contexts has been reported in the social 

science literature, in which researchers present data and arguments about the significance and 
3

meaning of such terms as the NIMBY (“not in my backyard”) and LULUs (“locally unwanted 

land uses”) syndromes. Research on public participation has long suggested that public—and 

especially stakeholder—participation in the decisions surrounding proposed facility siting will 

increase the public's satisfaction with the decision process and its ultimate acceptance of the 

facility.

The social acceptance of technology has been identified as having three dimensions—sociopolitical acceptance, community acceptance, and market acceptance. The research reported here 

focuses primarily on community acceptance, which refers to “specific acceptance of siting 

decisions and renewable energy projects by local stakeholders, particularly residents and local 

authorities.”3 Several factors are thought to be related to community acceptance: (1) distributive 

justice (the distribution of costs and benefits of a renewable energy facility); (2) procedural 

justice (the inclusiveness of the decision-making process); and (3) the amount of trust placed in 

actors from outside the community.4

Although social rejection of energy projects such as nuclear power plants and waste repositories 

is well documented, barriers to social acceptance of “clean” energy facilities present new 

challenges that need to be addressed if carbon-reduction goals are to be met and if renewable 

energy policies are to succeed.5

Little empirical evidence supports the claim that NIMBYism is responsible for a difference 

between favorable attitudes toward renewable energy technologies and community response to 

proposed facilities in a local area.6 Instead, Wolsink argues that the NIMBY label is used to 

discredit opposition concerns and has "become a great hindrance to the handling of critical 

attitudes."7 We find that NIMBY and LULU explanations are oversimplifications of concerns 

expressed by local stakeholders. Instead, our findings reveal that local concerns are complex, 

typically incorporating several elements of social, cultural, technological, political, and 

environmental elements. We also find that local and outside stakeholders, with their different 

perspectives and understandings, are involved in complex and sometimes tense interactions that 

will result in significant legal and regulatory decisions that will in turn permanently affect the 

texture and quality of everyday life for the residents of the San Luis Valley. These situations also 

resonate in other potential large-scale solar energy siting locales.

1.3 Background

The background section has two parts. The first part deals with the reason for the study—the 

National Renewable Energy Laboratory's designation of the SLV as a critical solar resource in 

the State of Colorado.

The second part of the background section deals with the historical, cultural, and demographic 

characteristics of the research setting. These characteristics are germane to understanding the 

 3 Wustenhagen, et al. 2007: 2685

4 Ibid.

5 Eiser, et al. 1988; Heiman and Solomon 2004; Wolsink 2000.

6 Bell et al. 2005; Kahn 2000.

7 Wolsink 2007:2699.
4

complex nature of the Valley's response to projects, why it is a prime solar siting area, and how 

contemporary concerns are rooted in historical development.

1.3.1 CSP Technology and the SLV

In January 2006, the Western Governors' Association (WGA) Solar Task Force Report identified 

the two central-station solar technologies under their consideration: (1) solar thermal electric and 

(2) PV generators. The vast majority of central-station solar projects underway or deployed are 

solar thermal electric (CSP). Although the Task Force believed that central-station flat-plate PV 

deployment will become more commonplace in the future, distributed PV generation has a much 

higher energy market value than central station PV. Therefore, the Task Force focused on CSP 

for its discussion of central-station technology and PV for its discussion of distributed energy 

technology.

According to the report, "The southwestern United States possesses a world-class, welldistributed, and nearly untapped solar energy resource,"

8 a conclusion based on an NREL 

analysis.

9 The WGA identified optimal sites for CSP in six western states (Arizona, California, 

Colorado, New Mexico, Nevada, and Utah). The NREL GIS analysis used the following filters to 

determine which lands were suitable for CSP plants:

• Only lands with an average daily solar resource of 6.75 kilowatt-hours/meter (kWh/m) or 

above

• 500 contiguous acres of land minimum (5 acres/MW for 100-MW CSP plants)

• Land with 1 percent or less slope

• Excluded designated urban areas, national parks, national preserves, wilderness areas, 

wildlife refuges, or water areas.

10

Given these parameters, NREL identified the SLV as the premier site for CSP facility siting in 

the state of Colorado.11 The WGA Task Force estimated the target goal for CSP electricity 

production at 20% of market penetration for the six Southwestern states. Calculations of CSP 

deployment by state resulted in an estimated 5,300 GW peak demand growth in Colorado (of 

34,100 GW in the six-state region). The CSP allocation of this demand growth in Colorado was 

0.1 GW.12

The U.S. Department of Energy (DOE)13

 8 WGA 2006: p. 6

identified seven Western States in the Southwest 

(Arizona, California, Colorado, New Mexico, Nevada, and Utah) with the combination of solar 

resource and available suitable land to generate up to 6,800 GW of electricity. (The electric 

generating capacity of the United States is currently greater than 1,000 GW.) A land area of 

2,124 square miles in Colorado's SLV was identified as part of this prime national solar resource. 

9 Mehos and Owens 2005 10 U.S. Department of Energy 2007 11 U.S. Department of Energy 2007 12 WGA 2006 13 2007, p. 7
5

The DOE report noted that CSP technology operates most efficiently where the skies are clear 

(as they are in the arid SLV). 

1.3.1.1 CSP Benefits.

The DOE and WGA reports identified several benefits of CSP development, as follows:14

• Adding CSP to the generation mix of a state expands domestic energy supply. 

• CSP provides better air quality than other energy sources, avoiding emissions.

• CSP provides a hedge against possible future carbon taxes.

• CSP is flexible enough to be deployed as large central-station power plants or as smallerscale distributed resources.

• CSP provides local economic development benefits (increases in jobs and electricity price 

stability) as long-term fuel costs associated with natural gas and coal are replaced by labor 

costs of operations and maintenance.

• Utilities have operated central station power plants for decades and are more comfortable 

with them than with distributed systems.

• CSP deployment helps meet state renewable portfolio standards (RPS) requirements.

• CSP adds diversity to the energy supply, increases grid security, increases use of local 

resources, and cannot deplete the solar resource. 

The Task Force noted that CSP can be configured as a "hybrid" power facility with auxiliary gasfired equipment to achieve full power and remove intermittency from operation. It noted: "The 

ability to dispatch power during peak demand periods makes CSP an ideal renewable energy 

technology for the Southwest." 15

A California economic benefits study16 found that building between 2,000 and 4,000 MW of 

CSP would benefit California in the following ways:

• Provide $7 to $13 billion in new investment, of which $2.8 to $5.4 billion would be spent in 

California

• Increase gross state product by $13 to $24 billion

• Create 1,500 to 3,000 permanent jobs.

Mark Mehos (NREL), in a National Public Radio interview broadcast on March 15, 2009, said 

that CSP is a "load following" technology allowing utilities to match electricity generation to the 

load requirements of human activity; for example, energy can be stored overnight to meet 

 14 DOE 2007; WGA 2006 15 WGA 2006, p. 14 16 Stoddard, Abiecunas, and O'Connell, 2006
6

morning loads. CSP prices are said to be fixed because there are no fuel components to alter 

them. In the same interview, Fred Morse (Solar Energy Industries Association) said that the 

types of jobs created by CSP are broad, including those in engineering, optics, R&D and 

operations and maintenance. Specific positions would include (but not be limited to)

electricians, heavy equipment operators, and mirror cleaners.

1.3.1.2 Policy Recommendations 

The WGA Task Force made several key policy recommendations relevant to CSP development. 

These included the following.

• Streamlined permitting. Permitting and siting large power plants is costly and timeconsuming.17 The Task Force called for standardized, streamlined fast-track permitting 

procedures for CSP plants "while retaining the need to provide for public oversight and 

protection."18

• Renewable portfolio standards. Renewable energy portfolio standards are known to have 

stimulated central station solar developments.19

• Investment tax credit (ITC). On October 8, 2008, the Emergency Economic Stabilization Act 

(P.L. 110-343) extended the solar 30% Federal ITC to utilities through December 31, 2016 

and extended it to utilities. This extension allows time to design, permit, finance, and build 

central solar power plants, and would give a $ 0.03/kWh price reduction for electricity from 

CSP plants.

 These standards require that a specific 

portion of a state's electricity consumption be met by renewable energy by a certain year (in 

Colorado, the RPS has been increased to 30% by 2020 [H.B. 1001]).

20

• Sales and property tax exemptions. The WGA report recommended that central solar plants 

be exempted from sales and property taxes; they said that the loss of these taxes would be 

offset by new tax revenues generated by economic activity caused by the plants.21

• Aggregation of plant orders and project bids. The WGA recommended that state public 

utility commissions (PUCs) extend power purchase agreements (PPAs) to 30 years.22

Aggregating plant orders would step up early-stage cost reductions.

DOE23 stated that it did not necessarily agree with all of the WGA recommendations. DOE 

announced on September 19, 2009, that it will invest up to $35 million over the next 4 years in 

15 CSP facilities, which will result in up to a $67.6 million investment.24

 17 WGA 2006, p. 19 18 In this regard, the WGA Task Force noted that the BLM has taken steps to facilitate the application and permitting 

process of solar development on public lands (see Appendix A). Another recommended step is the creation of “solar 

development zones” (also mentioned in Appendix A).

19 WGA 2006, p. 21 20 WGA 2006 21 WGA 2006, pp. 22-23 22 WGA 2006, p. 23 23 DOE 2007 24 CRES News, October 2008, p. 2
7

Other than to mention that permitting can be costly, the reports reviewed did not analyze the 

dynamics and concerns of local communities relative to CSP facility siting and transmission 

siting. They did not review land-use impacts. The reports focused on solar resource, technology, 

jobs impacts, economic multiplier effects, and environmental effects.

1.3.2 The Research Setting 

The San Luis Valley of Colorado is a historically and culturally sensitive area. Located in southcentral Colorado and ringed by 14,000-foot-high peaks of the San Juan and Sangre de Cristo 

mountain ranges, the Valley shares a southern border with New Mexico. The six counties of the 

Valley (Alamosa, Conejos, Costilla, Mineral, Rio Grande, and Saguache) comprise more than 

5.2 million acres with 57% federal land, 39% private land, and 4% State government land. 

Patterns of land ownership vary greatly across the Valley's counties. Costilla County is 99.9% 

privately owned whereas Mineral County is 94% federal land. Alamosa County is 61% privately 

owned with 27% federally owned.

The U.S. Forest Service (USFS) of the U.S. Department of Agriculture (USDA) manages 40% 

and the Bureau of Land Management (BLM—of the U.S. Department of the Interior) manages 

12% of the lands in the Valley. The USFS and BLM operate a combined field office there. 

Saguache and Mineral Counties have more National Forest land and Saguache and Conejos have 

the highest concentrations of BLM land. In addition, the Great Sand Dunes National Park and 

other park lands, managed by the National Park Service, comprise 3% of the Valley and the U.S. 

Fish and Wildlife Service holds 2.2% of the land. About 2.1 million acres cover the area defined 

as "the Valley floor."25

Many Native American groups believe that the Valley is the source of life where humans and 

spirits enter and leave this world. The oldest evidence of humans in the San Luis Valley dates 

back an estimated 11,000 years. The area contains some of the oldest prehistoric archeological 

sites in North America. The first people to enter the Valley were nomadic hunters of mammoths 

and prehistoric bison who grazed there.26 The Capote band of the Ute Confederation inhabited 

the SLV in Colorado near the headwaters of the Rio Grande; this band makes up part of the 

present-day Southern Utes with headquarter in Ignacio, Colorado. The Utes hunted for deer, elk, 

antelope, and other game (using Clovis and Folsom arrow points) and gathered seeds, wild 

berries, and fruits. They were also known to have planted and harvested corn, beans, and squash. 

The Utes called the Valley "Tavi-we-a-got" or Big Valley. 

Travel to and from the Valley from New Mexico followed the route of today's Highway 285. 

Although the Valley had been visited by Spanish and American explorers, the Utes and Navajos 

discouraged settlement of the Valley until the 1840s. In 1842, Mexico established land grants in 

the Valley, including the Trinchera, Baca Grande, and Sangre de Cristo. Families occupied the 

land under the Spanish land grants but by feudal tenure and not in fee; thus, the title remained 

with the Spanish crown, which has clouded the land-grant issue until very recently.

27

 25 Both the National Park Service and the U.S. Fish and Wildlife Service are under the U.S. Department of the 

Interior.

26 http://www.kscland.com/slv_history 27 http://www.kmitch.com/Heurfano/sanluis.html
8

In 1848, the SLV was ceded to the United States by Mexico in the treaty of Guadalupe Hidalgo, 

and in 1851 Fort Massachusetts (now Fort Garland), was established. San Luis, the oldest town, 

was founded in 1852 as the first permanent settlement. The San Luis Valley became part of the 

Colorado Territory on February 25, 1861. Congress felt that as much land area as possible should 

be north of the slave-free dividing line. The United States placed most of the Conejos land grant 

into the Rio Grande National Forest.

From 1878-1880, Mormon settlers established the towns of Manassa, Sanford, and Rome. In 

1878, the Denver and Rio Grande Railroad completed a line to Alamosa, thus enabling the 

export of local products. Alamosa, the major town, is 239 miles from Denver and 141 miles from 

Santa Fe. 

Any water needed for CSP development is likely to be a sensitive issue in the Valley. The Valley 

receives a scant 6.5 inches of precipitation a year, and its residents are particularly sensitive to 

water issues. The first recorded water rights in Colorado were filed in this area. The oldest water 

right in Colorado is attributed to the San Luis People's Ditch, with a priority date of April 10, 

1852, in the amount of 21 cubic feet per second from Culebra Creek in Costilla County. 

The total population of the SLV in 2006 was 48,291 with a density of 5.9 people per square mile, 

compared with a Colorado population of nearly 5 million and a land density of 46.4 people per 

square mile. Annual average population growth rates show the region is expected to increase 

0.6% per year until 2011; subsequently, the population growth is projected at 1.1% per year. 

Approximately one-third of the population is Spanish-speaking; about 4.2% of residents are noncitizens.28

The six Valley counties are among the lowest of Colorado's 63 counties in median income, costof-living, and purchasing power. Economic activity historically included wheat and barley

production, and later timber production and gold and silver mining. Ranching came to dominate

the Valley economy by the 1970s. Today the SLV—the highest and largest alpine valley in the 

world—is the largest producer of potatoes in the United States. The sun shines an average of 320 

days per year, and the nights are cool. The land on the Valley floor is flat. The combination of 

sunshine, topography, cool temperatures, high altitude, and scant rainfall combine to yield a 

premier site for CSP.

1.4 Parts of the Report

This report has three parts, which begin after the following section on Methods.

• Part One: Interview Findings. This part contains a preliminary analysis of the qualitative 

stakeholder interviewing completed from October 2008 through March 2009.

• Part Two: Synopsis of the Transmission Controversy. After the interviewing was 

completed, a controversy erupted over a new transmission line to be built from the Calumet 

Substation into the San Luis Valley. This part of the report contains a synopsis of the 

controversy that has engulfed the proposed siting of a transmission line to carry electricity 

out of the SLV to load centers on the Front Range of Colorado.

 28 San Luis Valley Development Resources Group. 2007. Comprehensive Economic Development Strategy.
9

• Part Three: Discussion, Conclusions, and Recommendations. This part discusses 

conclusions from the study and makes state policy recommendations.

In addition, there are two appendixes.

• Appendix A: The BLM PEIS Process. Appendix A contains a summary of the BLM 

Programmatic Environmental Impact Statement (PEIS) process, including excerpts from 

public comments.

• Appendix B: Chronology of Key Events in the Transmission Controversy. 

Appendix B contains a table showing a brief summary of key events in chronological order.
10

2 Methods

2.1 Introduction

This study focused on stakeholder views of a hypothetical 100-MW parabolic trough CSP plant 

to be sited somewhere in the SLV. The plant would generate electricity from a steam turbine and 

could be cooled by water or air, although the latter would be more expensive. It would have 

storage in the form of molten salts, which would keep the power coming well after sunset into 

late evening hours. Qualitative semi-structured interviews with probes for specificity and 

completeness were used to collect data from a purposive sample of stakeholders within and 

outside the Valley. The sample was systematically selected to represent a range of stakeholder 

group perspectives on CSP facility and transmission siting. Interviewees were asked to reflect 

the views of their groups.

2.2 The Research Questions

The study set out to identify social, economic, and policy factors that facilitate and impede the 

siting of a 100-MW CSP in the San Luis Valley. Although considerable research exists on public 

opinion about energy, which documents the persistent preference of the U.S. public for energy 

efficiency and renewable energy sources, little research has focused on perceptions of specific 

renewable energy facilities and renewable energy facility siting issues. Yet, it cannot be taken for 

granted that the public and, more specifically, stakeholders, will accept the siting of renewable 

energy facilities. The Cape Wind controversy over the siting of an offshore wind facility near 

Cape Cod29 is illustrative of the significance of the stakeholder dimensions for impeding the 

siting of wind power, and the Medicine Lake controversy30 shows the difficulty of siting a 

geothermal facility on or near culturally sensitive lands.

At the study's outset, the investigators met with a Research Advisory Committee of key 

stakeholders within and outside the Valley to identify key research questions for the study. As 

might be expected, the stakeholders had a variety of views about and questions for the research. 

These included the following:

• What are the key governmental entities involved in CSP decision-making and how can they 

work together?

• Should there be local ownership of a CSP facility or should it be owned by CSP developers? 

What is the appropriate role of the local players?

• What are new models for siting-decision processes rather than the producer-buyer-purchase 

power agreement model? Can rural electric cooperatives play a larger role and, if so, how? Is 

there a model for developing power locally and using it where it is produced?

• What are the key water, land, and other issues?

• What is the level of awareness and knowledge of key SLV stakeholders?

 29 “For Controversial Wind Farm off Cape Cod, Latest Hurdle is Spiritual.” New York Times, January 5, 2010. 

http://www.nytimes.com/2010/01/05/science/earth/05wind.html. 30 “Dispute Swirls around Geothermal Project.” Klamath Forest Alliance, January 14, 2006. 

http://klamathforestalliance.org/Newsarticles/newsarticle20060115.html and “Medicine Lake Geothermal Leases 

Questioned in Appeal.” Siskiyou Daily News, March 16, 2010.
11

• What is the level of community support and opposition?

• What are the issues relative to transmission, such as crossing federal lands, environmental 

impact statements required, and public participation?

• What are the policy, regulatory, and sociological barriers to CSP development?

• What are the public lands involved in the Valley and what are the implications of CSP 

development on public lands? Is CSP included in the BLM's resource management plans? 

Are there concerns about sensitive Wilderness areas?

• What role are environmentalists playing?

• What are the institutional barriers to CSP siting?

This report documents a portion of the analyses being conducted as part of the Joint CU-NREL 

study.31

Three different approaches were used in this study: (1) stakeholder analysis, (2) review of the 

BLM's PEIS on solar development in six Western states, and (3) preliminary analysis of 

transmission line controversy.

2.3 Stakeholder Analysis 

In-depth focused interviews with stakeholders relative to CSP were conducted in cooperation 

with the University of Colorado. Initially, relevant social science literature was reviewed on 

topics related to facility siting of renewable energy facilities, NIMBY and LULU concepts, 

facility siting controversies, and political and community factors affecting controversies 

surrounding facility siting. Then, relying on guidance from a Research Advisory Committee 

comprised of representatives of key stakeholder groups, and objective methods for identifying 

stakeholders, we identified key stakeholder group categories for the San Luis Valley relative to 

CSP.

The key stakeholder groups represented in the study included the following.

• Education, advocacy, and professional organizations within and beyond the Valley

• Agricultural groups (farmers, ranchers, landholders, and their organizations and associations)

• SLV economic groups

• Government and regulatory agencies, organizations, and representatives

• Solar/CSP industry representatives

• Environmental organizations

• Utilities.

 31 The Research Advisory Committee advised that the study should avoid examining the CSP suppliers, their 

technologies, and factors such as the price of steel—these types of questions were determined to be beyond the 

scope of the study.
12

It was expected that the potential benefits of CSP development would be perceived differentially 

by various stakeholder groups, and indeed, could be perceived differently by stakeholders within 

and beyond the SLV. 32 It was also expected that positions toward CSP development would vary 

by organizational positions in functional and geopolitical domains. So, for example, an 

organization such as the local cattlemen's association would look at CSP development through 

the lens of ranchers potentially concerned about land values and water availability, whereas an 

organization such as a local hotel owner might be thinking of the profit to be made from "heads 

and beds" if a CSP project were to go forward. 

Anticipating and documenting the expected diversity in perspectives of social groups, as well as 

finding common ground among them, can strengthen decision processes by providing objective 

data to support those responsible in working through the multiplicity of interests, power 

hierarchies, knowledge levels, beliefs, and opinions in a project area. Such “working through” 

increases the inclusiveness of the decision-making process, potentially increasing the 

sophistication and effectiveness of decisions. In addition, juxtaposing local views and local 

expertise enables the community itself to more accurately construct the complex and colorful 

tapestry of its own positions, beliefs about impacts, and views on potential benefits and costs. 

Outside stakeholders bring considerable knowledge to consideration of the impacts of CSP 

development. Increasing the awareness on the part of those organizations outside the Valley, in 

positions of decision responsibility, about their own interests and how they relate to those within

the community of the proposed siting contributes "social facts" to illuminate the complex 

problem of utility-scale solar development. 

2.3.1 Sampling

The interviews were conducted with a purposive sample. Because of the limited resources 

available for the project, the stakeholders identified were divided into tiers by type of stakeholder 

group and the first-tier stakeholders were approached for interviews. Interviewees were sent 

letters explaining the study to them and informing them that they had been identified as part of 

the study's sample. Most of the sample agreed to be interviewed; however, some did not. In those 

cases, a back-up organization in that same category was approached. Probably because of 

tensions already mounting about the siting of transmission lines in the Valley, a few stakeholders 

both favorable and unfavorable to CSP development (positions especially seeming to relate to 

the proposed transmission lines) failed to respond or declined to be interviewed. Nevertheless, 

the range of stakeholders interviewed was broad and we were able to complete interviews with 

others in the same stakeholder group. 

The interviews were conducted with representatives of the organizations to which they belonged. 

Therefore, the perspectives given represented the stakeholder groups for which interviewees 

spoke, not their individual attitudes, opinions and views. Between October 2008 and March 

2009, 25 interviews were completed with organizational representatives. Fourteen of the 

interviews were conducted with residents of the San Luis Valley and 11 with knowledgeable 

stakeholders who resided outside the San Luis Valley. Most, but not all, of the organizations 

represented in the sample were located in Colorado. One limitation of the study is that no 

interviews were completed with representatives of the Valley's Spanish land-grant families or 

 32 Babiuch and Farhar. 1994.
13

Native American tribes. The findings cannot be generalized to the population of the San Luis 

Valley or even to all potential stakeholders in the Valley. The findings provide descriptions of 

the key issues and stakeholders—as defined by some of the organizations who know the most—

about the technology, other stakeholders, the decision processes in siting a CSP facility and the 

proposed transmission line, and the community where this would be done.

To appropriately appreciate the interview findings represented in this report, one needs to 

understand the starting positions of the organizations relative to CSP development in the SLV. 

Within the six-county Valley community, organizational representatives knowledgeable about 

their own and others' interests were included. The Valley interviewees varied in their knowledge 

levels about utility-scale solar development, although everyone interviewed knew about the 8.2-

MW SunEdison Solar PV plant sited on Highway 17 near Mosca, and their positive experience 

with it tended to color their responses toward CSP. But if not all were expert on CSP, the Valley 

stakeholders were expert on the Valley, its culture, its residents, its economic situation, and its 

politics. In addition, some of them favored CSP development and others did not; therefore, it was 

possible to capture a variety of organizational views toward CSP and transmission development. 

Those interviewed outside the SLV were highly knowledgeable representatives of organizations 

with a stake of one kind or another in CSP development in the SLV. To capture the range of

relevant stakeholder opinion, those stakeholders were interviewed who, by objective analysis and 

subjective experience, have an interest in what happens in the Valley in terms of large-scale solar 

energy development. Thus, the stakeholders outside the Valley tended to be highly 

knowledgeable about the technology and relevant policy, to be favorable to CSP development, 

and they embraced claims made for its benefits both inside and outside the SLV. However, they 

also knew about potential negative impacts and were concerned that these be accurately 

identified, anticipated, and taken into account in any CSP project planning.

2.3.2 Data Collection

As noted, the interviews were semi-structured, open-ended interviews with extensive probing for 

specificity and completeness of responses.33

 33 The study methods were approved by the Human Research Committee at the University of Colorado. 

Interviewees were promised confidentiality and anonymity.

Questions focused on the stakeholder's definition of 

the then-current situation in the SLV, the perceived advantages and disadvantages of renewable 

energy generally and of CSP in particular, the definition of SLV stakeholders with respect to 

solar energy development, and perceived considerations relative to facility siting and 

transmission. The interviews ranged from 60 to 90 minutes in length and were tape-recorded and 

transcribed verbatim, resulting in approximately 400 pages of field notes.
14

2.3.3 Analysis

These notes were then subjected to content analysis to identify discrete ideas and comments 

volunteered by stakeholder interviewees. The importance of the voluntariness of response is 

underscored; no suggested answers were raised in the interviews, so that the responses emanated 

from the particular stakeholder organizations' own already-held positions. The content analysis 

was intended to identify the scope, range, and texture of ideas about perceived impacts—positive 

and negative—from various stakeholder positions. It is possible to identify the significance, in 

the sense of the "emotional charge" of these issues, as well as to gain insights into what was (at 

the time of the interviews) beginning to shape up to be a difficult controversy about the 

transmission lines proposed to export solar electricity out of the Valley to Colorado's Front 

Range electricity load centers.

2.4 Review of the BLM's PEIS Process

As noted earlier, fostering development of renewable energy is national and state policy. Given 

the amount of federal land in the SLV, and the importance of the Valley as a site for solar 

development, it is inevitable that federal policy on solar siting on public lands would be germane 

to the SLV. By 2008, the BLM had received more than 150 requests nationwide for permits to 

site large-scale solar facilities on public lands, yet the agency's Resource Management Plans 

(RMPs) did not include solar development. By law, land-use permits cannot be issued for actions 

that are not covered in RMPs because environmental and socioeconomic impacts have not yet 

been assessed for such actions. 

During the mid-2000s, federal policy shifted toward fostering utility-scale solar development. To 

streamline the permitting process for these facilities, the BLM initiated a PEIS process to 

examine the impacts of solar developments in six Western states on May 28, 2008. In 2009, 

Secretary of the Interior Ken Salazar established Renewable Energy Coordination offices in 

Arizona, California, Nevada, and Wyoming, and smaller teams in five other states including 

Colorado. This followed on the 2008 announcement by BLM and DOE designating 24 tracts 

totaling 670,000 acres of public lands as Solar Energy Study Areas (SESAs), including 21,000 

acres in the SLV. The four sites are DeTilla Gulch, Fourmile East, Los Mogoles East, and 

Antonito Southeast. 

If fully developed, the Colorado sites could generate more than 4,000 MW. Companies 

proposing projects in these areas would be eligible for faster permitting processes. A PEIS 

addressing the impacts of solar development in six western states is being completed in order to 

speed the permitting of facility siting on public lands. The final PEIS and Record of Decision are 

expected in the fall of 2010. Appendix A of this report provides an overview of the BLM PEIS 

process, public comments from Colorado organizations and individuals, and its current status.

2.5 The Transmission Controversy

A significant controversy erupted in May 2009 when Tri-State Electric Generation and 

Transmission Association and Xcel Energy applied to the Public Utilities Commission of 

Colorado for a Certificate of Public Convenience and Necessity (CPCN) to build a 230-kV 

transmission line into the SLV from Walsenburg to Alamosa, Colorado, along Highway 160 

through the privately owned Trinchera Ranch. Although the stakeholder interviews had yielded 
15

perceptions of transmission issues, they were completed before the legal and community 

opposition to the transmission line crystallized. Therefore, Part Two of the report includes a 

synopsis of the controversy that developed after the interviews were completed based on 

documents, news articles, reports, and other artifacts concerning the transmission line 

controversy. This analysis summarizes a recent history of events leading up to and encompassing 

the controversy, including identification of the key stakeholders and the issues involved. 
16

Part One: Findings from the Interviews
Interview Findings

17

3 Perceived Advantages

3.1 Introduction

Stakeholder informants were asked about their organizations' view on the advantages and 

disadvantages of renewable energy generally and of CSP in the San Luis Valley. The 396 pages 

of text were content-analyzed to discern discrete mentions of perceived advantages of renewable 

energy generally in the context of open-ended questioning; these are considered "responses." 

Five broad categories of advantages were developed from the comments themselves: (1) 

economic, (2) environmental, (3) technological, (4) social-psychological, and (5) policy and 

regulatory. Under each of these broad categories, subcategories were defined. Each response was 

coded by category and subcategory.

Table 1 shows that 231 discrete responses mentioned advantages of renewable energy generally 

and CSP specifically were identified. The table is organized in terms of decreasing frequency of 

mention (or responses) of the different types of advantages, with economic advantages receiving

the most emphasis in the data set overall (44%), followed by environmental advantages (26%), 

technological advantages (19%), social-psychological advantages (9%), and policy and 

regulatory advantages (2%). 

Overall economic advantages are mentioned far more frequently than are environmental or other 

types of advantages by both types of stakeholders. Stakeholder interviewees inside the SLV 

mentioned economic advantages of CSP specifically in the Valley almost twice as often as they 

mentioned economic advantages of renewable energy generally, suggesting that local economic 

advantages of a proposed CSP facility weighs more in locals' positions toward the facility than 

other considerations.

Stakeholders outside the Valley more often mentioned "technological" advantages than did those 

in the Valley, suggesting their higher level of technical sophistication about CSP. Third, 

environmental advantages of both renewable energy generally and of CSP specifically were 

mentioned somewhat more frequently by Valley stakeholders than by outsiders. Fourth, Valley 

stakeholders mentioned "social-psychological" advantages more frequently than did those 

Summary

Stakeholders identified economic, environmental, technological, socialpsychological, and policy and regulatory advantages of renewable energy generally 

and of CSP development. Patterns of response differed somewhat by whether 

interviewees came from within or outside the Valley. Valley stakeholders were 

more articulate and passionate about local economic and socialpsychological/identity values, and those outside the Valley emphasized broad 

environmental and technological advantages. Valley stakeholders were more 

concerned about poverty in the Valley and the cost of electricity, availability and 

persistence of local jobs, and making certain that the Valley's residents would 

benefit financially.
Interview Findings

18

outside the Valley. Each of these the categories of advantages is discussed and exemplified in 

more detail below.

Table 1. Types and Percentage Distribution of Responses about Perceived Advantages from 

Stakeholders within and outside of the San Luis Valley (n=231 comments)

Types of 

Advantages

Renewable Energy

Generally CSP Specifically

% Responses

Within SLV

% Outside 

SLV

% Responses

Within SLV

% Outside 

SLV

%

Totals

Economic 27 38 53 52 44

Environmental 40 34 20 15 26

Technological 25 15 11 26 19

Social-psychological 4 6 16 7 9

Policy and regulatory 4 7 -- -- 2

100%

(n=48)

100%

(n=53)

100%

(n=64)

100%

(n=66)

100%

(n=231)

3.2 Economic Advantages

Economic advantages identified tended to focus on the potential economic impacts of CSP 

within the Valley, rather than on effects of renewable energy generally. The 44% of discrete 

responses categorized as economic (n=67) fell into six somewhat overlapping categories of 

advantages, discussed below. Most frequently mentioned were potential improvements to the 

local SLV economy from the siting of a CSP facility there. Two quotes from Valley 

stakeholders:

...it'll happen. For everyone [but farmers], this is a no-brainer. If we just had the 

wherewithal as a little rural community to make this happen and to be sure that the 

SLV reaps the rewards...how can we make sure that the SLV reaps the rewards? 

Because someone could build a solar plant and all the money leaves the local 

economy...we'll, we've done good for our planet, but how can we make this benefit 

our own economic development?

...our intent to have this valley 100% renewable by the year 2010. And that could 

happen in an hour if Tri-State, Xcel, and Rural Electric all agreed that they could 

get mutual benefit because we could actually purchase enough [renewable energy 

credits] to have the Valley 100% renewable based on existing energy...

Proportionally more stakeholders outside the Valley than within it referred to economic benefits 

for the people living in the SLV; it was one of several benefits of CSP that they cited to describe 

the benefits of siting a CSP facility there.

...the new energy economy has been a huge boom to our state with respect to job 

creation and economic development at a time when we really need it the most.

They use a local resource so they create economic activity in the Valley . . . It adds 

another engine to the Valley's economy. The Valley is pretty much agricultural as I 

understand it, so you bring in a very clean other business.
Interview Findings

19

....having the ability to create a new sustainable energy industry, also looking at 

the opportunity that we could generate as much as $2 billion in new investment in 

rural communities which are so desperately in need of....

On the other hand, Valley stakeholders stressed the idea that renewable energy generally 

creates jobs and that a local CSP facility could lead to the location of a manufacturing 

facility in the Valley. This notion was circulating fairly widely within the Valley at the time of 

the interviews, and appeared to be based on statements made by the CSP industry.

And it would create a large number of construction jobs—about 1,000-2,000 over a 

two-year period) and a smaller number of maintenance jobs, say 60 to 70 full-time 

jobs—permanent, good-paying jobs for the 30- to 50-year life of the plant....

A local informant said:

It's clean, we have a lot of sun, there are no negative effects and it makes some jobs—

and there may be manufacturing jobs—if this were a big site for solar, it could lead to 

the manufacturing of solar components. That would improve the economy. It would be 

good for some businesses—contracting with them to place on rooftops, power their 

business and sell excess to the SLV REC [Rural Energy Cooperative] or Xcel. It's an

advantage for business.

Another economic advantage of renewable energy generally seen as crucial (but not 

specifically mentioned as an advantage of CSP) is that it could stabilize energy prices at a time 

of rapidly increasing prices of coal and natural gas. 

Fuel price stability would probably be the single most important facet with respect 

to CSP...the Governor’s Climate Action Plan...calls for a 20% reduction in 

statewide greenhouse gas emissions by 2020 and an 80% reduction by 2050....it is 

important to note [that] the current Climate Action Plan models a 200-MW 

concentrated solar power facility somewhere in Colorado. 

Two other economic advantages were mentioned: (1) providing tax benefits to local counties 

(which was mentioned more frequently by stakeholders outside the Valley [six mentions] than by 

ones within the Valley [one mention]) and (2) trapping the dollars in the state's economy that are 

now sent out of Colorado. In fact, one Valley interviewee commented that there should be a 

severance tax for exporting solar electricity from the Valley.

Do you recall the Federal Mineral Lease, or the Severance Tax, things that are going 

on with all of that? Did you hear the Western slope and Grand Junction and that area 

talk about their severing the minerals from our...we should get some of the benefit of 

that here, you’ve heard them say that?

Interviewer: Yes.
Interview Findings

20

Stakeholder: While solar is not a severable mineral, locating your things on our 

vistas is use of our resource. Should there be a severance tax and could that tax 

benefit these communities? 

Interviewer: For economic development?

Stakeholder: Yeah, we’ve got the poorest school districts in the state, I mean on and 

on. Could the social gain be...we have this resource here, and people from the outside

want it, they want our sunshine that’s produced in our valley, could we tax for their 

use of our sunshine to benefit communities located here?" 

Although the supporters of CSP development would probably not agree, the prospect of extra local 

tax benefits tailored to the solar resource combined with the clear air and flat land that would help 

mitigate the poverty in the San Luis Valley would very likely be welcome to the Valley community.

3.3 Environmental Advantages

More than a quarter of the responses about the advantages (26%) addressed environmental 

advantages (n=60), mostly of renewable energy generally. Most frequently mentioned were that 

renewable energy, and CSP specifically, puts excellent San Luis Valley solar and natural 

resources, including lands, to best use (25 responses). Following are quotes from SLV 

interviewees.

We have 8,000 square miles, a lot of which is chico brush and land that is not being 

utilized, so there is plenty of room here.

I think the land owners who have owned....it’s just not good farmland. It’s chico 

brush and either maybe they don’t own the water or the soil is not right because there 

is a lot of alkaline in the valley....so, like where they put that SunEdison...maybe that 

is the highest best use for that. So the people who sell that land, that may be their 

only opportunity to sell that land.

If you do some due diligence you can pick areas of the Valley that are fairly rocky, 

areas were farming is not done because soil isn’t good for farming potatoes. Other 

areas aren’t producing much of anything—those areas would be the priority areas for 

solar panels. [The interviewee was talking about the 8.2 MW Sun Edison 

concentrating PV plant—this confusion between CSP and the PV plant existed among 

several SLV stakeholders.]

Another response was:

If you’ve got property that received the same amount of sun as the irrigated acreage 

that provides potatoes for food, you wouldn’t take one in favor of losing the other, but 

you would select the best one for the use. . . I suppose that says this makes more sense 

to sort of take the crops out of projection if you choose fallow land. It’s the highest 

cash use.
Interview Findings

21

A second type of environmental advantage cited (15 mentions) is that renewable energy reduces 

greenhouse gas emissions, addresses climate change, and helps to "save the planet." It can 

probably be assumed that this type of advantage is thought to apply to CSP as well, although no 

responses cited this advantage relative to CSP in the Valley specifically. Quotes from within the 

SLV exemplifying this type of comment are as follows:

Whether you believe in climate change or not, the climate’s different than it used to 

be for whatever reason. The fact is that we need to address that. I think renewable 

energy is important [in addressing climate change].

The biggest advantage is that it is renewable, not a finite source of energy. Reduction of 

greenhouse gas emissions is a benefit to renewable energy development—carbon 

reduction.

Quotes from outside the Valley on this point include:

I think in order of importance, probably climate change and greenhouse gas emission 

reduction targets, secondarily the economic development piece, and perhaps third the 

fuel price stability and long-term cost reduction.

Quantified - 1 billion tons of carbon reductions.

The third type of environmental advantage is the reference to renewable energy as "clean 

energy" and "good for the environment." Thirteen discrete responses, mostly from SLV 

interviewees, referred to clean energy, but only one relative to CSP. Example quotes are as 

follows:

Renewable energy is good simply because it is renewable...it is popular to develop 

renewable energy because of environmental reasons, like clean air and water.

Other environmental advantages identified were that renewable energy uses less water than 

other forms of energy (two responses—one inside and the other outside the Valley), that it helps 

wildlife (two SLV responses), and that it won't disrupt the vistas (two outside responses).

3.4 Technological Advantages

Emerging from the content analysis was a set of stated advantages that were classified as 

"technological" advantages, comprising 19% of the responses. SLV stakeholders mentioned at 

least 17 of these and stakeholders outside the Valley mentioned 25 such responses.

Twenty responses mentioned that renewable energy improves the security and diversity of 

power supplies and reduces dependence on imported energy. One Valley stakeholder put it this 

way:

[What's important] is the ability to attach and I think what it is called is...they’ve got 

to be able to integrate with our system through a substation to get it out, and right 

now there is a 230, actually it’s a double-circuit, 230 transmission line planned in 
Interview Findings

22

the San Luis Valley to Walsenburg, and it is a combination of Xcel and Rural 

Electric and Tri-State that are going to put that transmission line in. 

Interviewer: Is that for sure going to...?

Stakeholder: Oh, yeah. One way or another. And it should be....the SLV doesn't put 

any money in, it is just for the Valley system, and Xcel and Tri-State pay for it. It is 

about an $80 million project. It should be completed by 2012 or 2013. 

Interviewer: And why are they doing this?

Stakeholder: Because we are running out of power in the valley. The last 

transmission line built in San Luis Valley was 35 years ago.

One stakeholder from outside the Valley described the advantages of renewable energy in a 

different way. This interviewee stressed the security value of distributed generation, as shown in 

the following quote:

We talk about what we're doing today as the alternative model and that what we'd be 

doing in the future is going to something traditional, I would say the centralized 

model is the alternative model. For the life of the planet, we have dealt with 

distributed generation and energy for all but about 70 years of the life of this planet. 

Integration of the distributed and larger grid can complement the central system with 

energy efficiency and renewable energy, instead of having another 25 or 30 coal 

plants in the queue in this country; it should be classified as preposterous, when we 

know that with energy efficiency, conservation, and the distributed model, we can 

take this centralized system that we’ve built and is in play and is working well for us, 

and complementing it and meeting our future demands with a much more distributed 

model. 

It’s the smart grid that is the glue or provides the way to accommodate distributed 

and central station. Once we got the next advances in storage, then we really have a 

system...

Advantages of...

It's more resilient. If you look at it from a national security perspective, and you 

quantify and weigh national security, economic security, and environmental benefits, 

this model is what maximizes those three things.

A well-informed stakeholder from outside the Valley talked about the prospect of CSP 

development and the need for a transmission line to enhance the security of the Valley, which 

has been served by only one transmission line coming in from the north.

It was a cooperative transmission line across La Veta Pass into the Valley. It goes 

across some private land, some state land, and then it also might go partially along a 
Interview Findings

23

highway corridor, so you’re bringing it across the pass. What it is is it is a double, I 

think it is a 230-KV line that will be a shared project from Tri-State and Xcel. One, 

they have to have a loop system right now into this valley. Their energy into the valley 

is very insecure because if there were a fire, these guys are toast. There wouldn’t be 

any electricity for quite a while because they are very vulnerable the way the whole 

transmission network is in the San Luis Valley.... it’s for the security of the region.

Another outside stakeholder put it this way:

It's flipped. Energy independence probably takes precedence over clean energy right 

now, and that’s the whole Middle East thing. So the priorities kind of swapped. In 

fact if you listen to Obama’s speech he talks about eliminating our dependence on 

Middle Eastern oil. I mean he says Middle Eastern which is key, by, in ten years, and 

that’s all security.

Clearly, the energy security implications of renewable energy were described from differing 

perspectives, but similar basic themes emerged about increasing U.S. self-sufficiency through 

decreasing foreign imports, and increasing Colorado self-sufficiency by producing Colorado 

power (not importing coal, for example).

A second type of technological advantage was classified as CSP provides dispatchable energy

and is a building block toward baseload electricity. Outside stakeholders (n=13) made more 

comments about this than did Valley stakeholders (n=5). 

CSP has two distinct advantages over PV right now. I think costs are roughly 

equivalent on an energy basis. However, CSP does not suffer the short-term 

intermittency that PV does.... with the SunEdison facility, there is more volatility with 

generation...CSP avoids this because it is a thermal cycle. It is essentially a steam 

turbine and it does not react to individual clouds the way PV does, and it has the 

ability to add storage inherent in the system . . . the advantage of thermal storage is 

that with 100% reliability it meets peak day loads.

3.5 Social-Psychological Advantages

One of the most intriguing perceived advantages identified by Valley stakeholders was the 

discovery that they see the potential for social-psychological advantages. A verbatim sequence 

of one of the SLV stakeholder interviews illustrates this point:

The sun is readily abundant in the valley. This is the land of cool sunshine. It’s 

colder than heck in the winter but we do get a lot of sun, so...there are actually 

some advantages I understand from being at this altitude and this climate for 

concentrated solar because we don’t overheat such as you would say in Death 

Valley. That’s my understanding, I don’t know if that is totally accurate, but I see 

that as a benefit. I think....and this is a real intangible, I don’t know if you know 

this, but the San Luis Valley has five of the poorest counties in the state and this is 

something to be proud of. 
Interview Findings

24

Interviewer: Something cutting-edge....

Stakeholder: Yeah, and, well, it puts a different face on the San Luis Valley as far 

as people on the Front Range come through here and don’t understand the beauty 

of the place because either you love it here or you hate it, but a lot of people from 

the metro areas are like, oh my God, how can you live in a place like this, and a lot 

of people who live here don’t appreciate what they have, so I think changing our 

perception of ourselves....I mean this could be....and that’s why I have a concern 

about....if they come and build everything and then take everything out of the 

valley, if they could just come and build everything and share some of that...it’s 

kind of like Los Alamos, you’re familiar with Los Alamos? Well, it has the highest 

concentration of Ph.D.’s in the country, so if some of that technology comes here 

and some of the people, some of the subject matter experts, and some of the industry 

associated with it, for example the manufacturing of the actual...whether it’s 

instrumentation, maybe it’s just like a silicon chip, I don’t know what it is, if they 

bring industry with it that is associated with it and turn this into....it can't be the 

Silicon Valley, but more value-added than putting the stuff here and then taking 

everything out. 

Interviewer: ...somehow there is a local involvement in that there is some kind of 

manufacturing capability and interest that stays in the valley. Is that the idea?

Stakeholder: Yes. That they’re committed...that they become a valued business and 

they are committed to the sustainability of our valley. I don’t think the majority of 

the citizens in this valley want to change. We don’t want to be another metro center. 

We don’t want to be an Aspen or a...we’ll never be that, but we want to sustain the 

quality of life...

Interviewer: Why not?

Stakeholder: Because the quality of life that is here is that we are not Aspen, we’re 

not Vail, we’re not Denver, we’re not Boulder—that’s the quality that needs to be 

embraced by a business that comes here and understood by a business that comes 

here. One of the unique things—and this is part of our mission, to enhance and 

maintain the unique culture and heritage of the Valley because of the strong 

Hispanic influence, the Native American influence, the Mormon influence—the 

history of the valley needs to be understood by companies that come because the 

majority of the people who live here like it the way it is.
Interview Findings

25

Another Valley stakeholder put it this way:

If you look at demographics of the Mississippi River Delta that compete with the San 

Luis Valley for a poor economic situation, the valley itself is a distressed economic 

area. What would be the impact to the rest of the world, the rest of the United States, 

the rest of Colorado, if the poor San Luis Valley pulled itself up by the bootstraps to 

where it becomes the first renewable valley in America? There would be entire vital 

reach in the ecosystem, the whole dynamic of its own future is suddenly 100% 

renewable energy. Now that’s an opportunity to erase at least one level of myth of 

what you are as opposed to what you aren’t. It is a way for people to socially elevate 

themselves to be able to walk into any store....

Interviewer: A source of pride. 

Stakeholder: It is a source of pride. I mean a little of it is that I don’t like the rahrah, go purple and white, fight-fight story...but there are aspects about being able to 

tell folks that with existing infrastructure, existing people, existing talent, existing 

local money, that you became the first 100% renewable bio-region in the nation, that 

the headwaters of the Rio Grande is 100% renewable. 

3.6 Policy and Regulatory Advantages

The final category of perceived advantages was the recognition that the development of 

renewable energy generally helps Xcel Energy meet its renewable portfolio standards (RPS) 

requirements, with two responses from the Valley and four from outside the Valley on this point. 

An illustrative quote from outside the Valley:

I think Amendment 37 was the primary reason that [Xcel Energy] started acquiring 

solar resources...Amendment 37 tells each Qualified Retail Utility in Colorado how 

much of its retail sales have to come from renewable energies, and there is a carveout within that for solar technologies subject to a retail rate impact cap. If it was 

going to cost too much money to acquire those resources, then the utility doesn't 

have to meet the energy requirements.

Amendment 37 was the first citizen-initiated, statewide RPS in the nation; many SLV citizens 

support the RPS and want it to be met, but did not mention specific advantages to the Valley 

from it.
Interview Findings

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4 Perceived Disadvantages

4.1 Introduction

The field notes were also content-analyzed to discern discrete mentions of perceived 

disadvantages of renewable energy generally and of CSP development specifically. The 

responses on disadvantages lent themselves to categorization in the same categories as the 

responses on perceived advantages: (1) economic, (2) environmental, (3) technological, (4) 

social-psychological and (5) policy and regulatory. Again, under each of these broad categories, 

subcategories were defined. Each response was coded by category and subcategory.

Table 2 shows that 158 responses mentioned disadvantages of renewable energy generally and 

CSP specifically. The table is organized in terms of decreasing frequency of mention (or 

responses) of the different types of disadvantages, with environmental disadvantages receiving 

the most emphasis in the data set overall (42% of the responses), followed by economic 

disadvantages (23%), technological disadvantages (19%), social-psychological disadvantages 

(11%), and policy and regulatory disadvantages (4%). One outside stakeholder said there were 

no disadvantages of CSP siting at all.

Comments on environmental disadvantages occurred more frequently in the interviews than 

other types of disadvantages and represented the most important area of concern for both types 

of interviewees (within Valley n=37; outside Valley n=30). Responses from the Valley cited 

economic disadvantages for renewable energy generally and CSP development specifically 

(n=26) more frequently than responses from outside the Valley (n=10).

Summary

Stakeholders identified potential disadvantages of CSP development. 

Interestingly, the most frequently occurring comments on 

disadvantages pertained to environmental issues, especially 

concerning water constraints and the intensive use of land that CSP 

development would entail. There were also some concerns about 

wildlife, weeds growing under collectors, and the idea that crops could 

not be grown under collectors. In addition, there were many more 

Valley comments (n=23) than outside comments (n=8) on the 

economic disadvantages associated with CSP development, including 

high front-end costs and the potential for a boom-bust cycle in the 

local economy. Other disadvantages remarked on, by both Valley and 

outside stakeholders, related to technological aspects (such as 

intermittency and need for transmission), but more comments from 

Valley than from outside stakeholders focused on social-psychological 

and policy and regulatory disadvantages of CSP development.
Interview Findings

27

Table 2. Types and Percentage Distribution of Responses about Perceived 

Disadvantages from Stakeholders within and outside of the San Luis Valley

(n=158 comments)

Types of 

Disadvantages

Renewable Energy

Generally CSP Specifically

% Responses

Within SLV

% Outside 

SLV

% Responses

Within SLV

% Outside 

SLV

%

Totals

Environmental 24 40 41 48 42

Economic 38 13 27 16 23

Technological 38 20 13 26 19

Social-psychological -- 20 13 8 11

Policy and regulatory -- 7 6 2 4

100%

(n=8)

100%

(n=15)

100%

(n=85)

100%

(n=50)

100%

(n=158)

4.2 Environmental Disadvantages

The most frequently mentioned disadvantages of CSP development were environmental issues. 

The two major perceived environmental disadvantages are (1) water constraints and the (2) landuse intensity of CSP.

4.2.1 Water Constraints

The most frequently occurring environmental comments concerned water availability by 

stakeholders within (n=11) and outside the Valley (n=12). The following two quotes are 

illustrative.

CSP is problematic. It is very problematic in terms of the region’s ability to 

conceptualize what it is going to look like and what it is going to take, that water 

is paramount. You have a hydrology unlike any other place in the world and you 

have citizens in this region who are so committed to their water and using their 

water carefully, using this water...it’s a closed basin...aquifer, part of it is a 

closed basin and then above it is an open aquifer that is what provides the water 

for the irrigation. It’s an extraordinary bit of hydrology here...it's the most 

contentious issue here. That's the problem with CSP. It requires water. You have 

some of the most unbelievable water [battles over water]...these are people who 

are more incented by their environment, their air quality, their water quality, and 

their quality of life than they are incentives by having industry come in...maybe 

that would change if they got a taste of it, but right now, anything that threatens 

their water has them quite concerned.

Developers need to secure access to water—it depends on cooling water, cooling 

tower—evaporates water to cool it. CSP needs 700 gallons of water per MWh. 

This could be an issue in the SLV, but it's not a show-stopper. Fans can be used to 

air dry the plant, but they consume electricity; this would be an economic 

decision based on the cost of water, the availability of water, and a pro forma 

financial model. Technically, at least, it's feasible...everybody knows the SLV is 

an ideal location; farming is on the decline because the water table is lower; 
Interview Findings

28

people are trying to figure out how to make money. They want to tie up both land 

and water...water is in shorter supply than the land.

Another outside stakeholder said:

You shouldn't do CSP without water (just like you shouldn't do coal without 

water), because it ruins the economics.

The integrated analysis of energy and water resources is gaining more attention in research 

circles as it is increasingly understood that developing energy resources depends on water, and 

developing water resources depends on energy.34 Water has historically been and remains a 

contentious issue in the Valley, and knowledgeable interviewees acknowledged this. Indeed, a 

stakeholder analysis of the correlation of CSP and water stakeholders and issues in the SLV 

should be the subject of separate analyses, and other analyses are needed on the regulatory 

implications of CSP and water.

Complicated and difficult-to-understand water issues are involved. According to some Valley 

residents, the SLV has north and south aquifers. Saguache is a closed basin with a three-layered 

physical structure. At the top layer is surface water; the layer underneath is hardpan; the aquifer

lies below. Local residents said that because the layers are relatively impermeable the surface 

water does not recharge the aquifer. Natural artesian wells spring up from the aquifer through 

the hardpan. According to some local residents, water is also pumped out to New Mexico to meet 

water compact agreements.35 One of the interviewees said that the water priority system is being 

circumvented by federal subsidies. The highest priority was said to be surface water rights. With 

more drilling, the surface water was said to be drying up, so the system now is one in which 

people have to buy and pay for the ability to drill based upon the amount of surface water they 

own. Based upon their ability to own or buy surface water rights, some irrigating farmers will 

stay in irrigation and continue pumping. Others will refuse to pay for surface water rights, in 

which case federal subsidies compensate them for taking their land out of irrigation. 

4.2.2 Land-Use Intensity

NREL estimates that CSP technology requires five to ten acres of land per one MW of electric 

capacity.36 If this is the case, then 500 acres to 1,000 acres of land would be needed for a 100-

MW facility. To be cost-effective, a CSP plant has to be a minimum of 100 MW in size and is 

probably limited at 250-300 MW per facility. One Valley stakeholder said that one of the CSP 

developers had said publicly that the company was looking at 5,000 contiguous acres on which 

to site a facility. 

Following are comments from the interviews on the perceived land-use intensity of CSP.

 34 The energy-water nexus was a major theme of the Natural Resource Law Center’s 30th Annual Conference, 

Western Water Law, Policy, and Management: Ripples, Currents, and New Channels for Inquiry held in June 2009 

at the University of Colorado Law School. Sandia National Laboratory has pointed out that there is no national 

research program directed specifically at understanding the “intimate relationship” between energy and water. 

http://www.sandia.gov/energy-water/nexus_overview.htm. See also Webber 2008. 35 This lay description of the SLV hydrology has not been reviewed by water experts. 36 www.nrel.gov/csp/troughnet/faqs.html. The extent of land needed varies by the amount of thermal energy 

storage.
Interview Findings

29

Solar still takes up space in our area.

[Solar energy] is an intensive use of land...

...footprint is a disadvantage in general for renewables...the footprint interacts 

with habitat loss because it requires such a large footprint, so that it's a 

significant concern.

There are rumors out there. Large corporations from California, from Australia, 

from I think I’ve heard Europe, that are talking to groups of people here about 

acquiring land for concentrated solar.... It’s a small community so you hear all of 

this stuff going on. You don’t know what to believe.

Another point a stakeholder made is that there are sensitive wilderness areas in the San Luis 

Valley. The example mentioned was Saddleback Mountain, reaching 7,956 feet, located in 

Conejos County and used for hiking. 

Developers could see threat in land speculators who are driving up the cost of land or tying up 

the land. Developers could see threat in "locking up" land to prevent development of CSP 

projects, although this information must be closely held in the Valley as interviewees did not 

mention any specifics.

Stakeholders varied in defining how much land the Valley comprises. One said that 5,000 acres 

is one-third of the square footage of the Valley. Another said that 95% of the land is federally 

managed. A third mentioned that each of the six counties in the SLV has a different pattern of 

land ownership. Another stakeholder said, "...well there are about 5 million acres in the San Luis 

Valley, and people say, you’re going to use 5,000 acres with solar panels, and I say, but you have 

5 million acres."

4.3 Economic Disadvantages

The most frequently mentioned economic disadvantage of CSP development was that a boombust cycle could result. The cycle would involve the hiring of workers to build the facility with 

the concomitant economic impacts such as increased demand for housing and increased prices in 

general, crowding, and demand on public services, followed by a decline in the number of jobs 

once the facility is built. This boom-bust cycle in energy development has been well-documented 

in the literature.37 One comment from an interviewee outside the Valley related to this is as 

follows:

I think the biggest concern for local residents is something that can happen on a 

national basis anywhere, whether it is a wind development or a coal plant or a 

Wal-Mart, is that locals want to know that they will be benefitting, that there is a 

long-term benefit to them, that there are potential employment opportunities, and 

 37 For example, beginning in 1964, the town of Parachute, Colorado, suffered though a boom-bust cycle brought on 

by the Tosco Corporation Colony oil-shale project, the goal of which was to build a commercial scale plant to 

extract oil from the local shale rocks (Guerrerio 2009).
Interview Findings

30

that essentially a company is not going to come in and develop a project and then 

abscond once the rewards have been taken, that the equipment will be renewed 

and so forth and so on.

Many Valley interviewees used the 8.2-MW SunEdison concentrated PV facility near Mosca as a 

point of reference in discussing the expected impacts of a potential CSP facility.38 One said:

They had temporary jobs to install the solar facility. There were 35 to 38 people 

hired. It paid well. There were 300 at the job fair, and there was a lot of interest 

because it was good pay—$14 to more than $20 per hour. These were laborers, 

electricians, welders, and equipment operators. [The only job since the plant was 

built] is the main supervisor. I don't know of any continuous employment from the 

SunEdison plant.

This interviewee said that when the oil and gas industry came into Parachute, Colorado, they 

created a boom of jobs paying good money, so the rent on homes there had been increasing. 

Then the local people couldn't afford the higher rent, he said, so although it was good for 

businesses like hotels while the boom was going on, the overall economic situation was not good 

for the local residents. The boom cycle was not sustainable.

4.4 Technological Disadvantages

Responses in this category stressed the problem that, for a large CSP facility to be sited in the 

Valley, transmission is needed because the Valley is remote from electricity load centers. Three 

illustrative quotes follow.

One disadvantage is that the electric transmission infrastructure in the Valley is severely 

limited so infrastructure would have to be built.

The challenge of connecting to the existing grid...

The direct drawback would be how are you going to export it? It goes back to bringing 

in new transmission lines.

Another technological disadvantage was that the efficacy of CSP was still in question. CSP was 

perceived by some not to be a proven technology, not yet ready to be commercialized, and that it 

will take time for it to be a reliable technology. Two illustrative quotes follow.

With the solar thermal with storage carve-out, it was an attempt to push that technology 

along, to see how it works in Colorado. Colorado has a good solar resource but we’ve 

got extreme winter cold temperatures and we have got concerns about how solar thermal 

technologies will perform in those extreme winter conditions. 

 38 The 8.22-MW Sun Edison plant was activated on December 17, 2009 near Alamosa, Colorado. It was the largest 

solar PV plant in the United States supporting substation loads for a major public utility. The plant consists of three 

distinct types of solar technologies: (1) single-axis tracking array, (2) fixed mount array, and (3) dual axis tracking 

array with PV concentrator technology. (http://www.sunedison.com; http://www.xcelenergy.com). 
Interview Findings

31

Current solar thermal plants have to be maybe 100 MW in size before they become costefficient.

In addition, some comments from within and beyond the Valley questioned the efficacy of CSP 

as not yet a proven technology or not yet at commercial status. For example, one Valley 

stakeholder said: 

...at this meeting they said concentrated solar hasn't been proven. That's what [one of 

the Valley experts] thinks, and his opinion matters...this technology is pretty much all 

in an experimental phrase. Yeah, some places have had it for awhile, but they are still 

doing a lot of experimentation.

The intermittency of solar power was also mentioned several times (n=12 comments). An 

outside stakeholder said, for example, that a CSP plant would probably have a lower "availability 

factor" than a coal plant.... the sun goes down, but the storage will supplement some of that, but 

if you pushed storage to the point where it was an around-the-clock plant, you'd probably be out 

of the economics." 

4.5 Social-Psychological Disadvantages

Fifteen comments, most by Valley stakeholders, fell into the category termed "socialpsychological" disadvantages. There was concern that a CSP facility would mean inequitable 

benefits—"short-term benefit for the very few"; CSP would be difficult to conceptualize and 

people would not understand the impacts. One Valley stakeholder said: "I think they're favorable 

to solar, but they don't know what concentrated solar is. I would say the majority of people, even 

a super-majority, don't know what that is."

Another point mentioned several times was the fear that renewable energy is "too green" and that 

it could be risky to allow it to come into the Valley. One interviewee put it this way:

...we'll have folks, elected officials, who will say, 'well this concept is too green for 

me' with the idea that if I have to agree with every environmental condition of every 

group that comes in the door, so there is almost a piece that if I let down the guard 

protecting the history of how we've done things in the past and instead pick up the 

idea that by unlocking the door, I'll get more.... If you decide too fast, you can be 

judged the fool, but if you judge too slow it is not often that you become the hero . . . 

and we are trying to answer the question, is it safe? Not the technology side, but that 

they would be judged as making inappropriate decisions...there's the risk. If you say 

let's go build it and it's financed...but in the end it doesn't produce power or some 

new technology comes out that is better or if someone changes the laws...well, they'd 

say those guys didn't think that through very well.
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There is also the sense that it is difficult for the Valley people to deal with Xcel Energy.

There are collaborations [between the rural electric cooperative and Xcel Energy] as 

far as the transmission lines, bringing in a pair of 230-kV lines. The other part, they 

focus very differently because of who their ownership is. That is one reason that I 

think the REC is more cautious in getting involved in renewables—their customers are 

the owners whereas Xcel is much more remote as far as influence one can have on 

them....it's like the big giant that nobody can talk to, whereas the REC has its ears 

open. The corporate world, when they have their mind made up to do something it is 

difficult to make changes and sometimes you have to go through some kind of 

embarrassment such as news media to bring things around a little bit.

This suggests a certain feeling of powerlessness to affect the outcomes of utility-scale energy 

decision-making.

4.6 Policy and Regulatory Disadvantages

One of the types of disadvantages of regional development of CSP that stakeholders mentioned 

in the six counties that compose the SLV involved disjointed county-by-county regulation. One 

Valley stakeholder said:

It's disjointed now. So you could have one county...Saguache has very lax building 

restrictions and it's a very poor county, so say if they want to attract solar into their 

county, that then impacts the surrounding counties because if their incentives are different 

than other counties...with six different counties in the Valley if you don't coordinate the 

plan, it is going to be disjointed.

The regulatory situation at the local level may need further development, a coordinated regional 

approach to be implemented. This could be expensive. Another point is that the BLM has to do 

a NEPA analysis, and that federal regulations have not caught up with CSP development. On 

the other hand, CSP development on private land requires no NEPA analysis. Finally, the point 

was made that the investment tax credit of 30% doesn't help developers because there is no way 

to turn it into money. 

Although these disadvantages could be counted as barriers or as economic effects, the lack of 

adequate regulatory capacity would have negative consequences of various kinds for the people 

of the Valley. In the meantime, counties might compete with each other for siting of a CSP 

facility and each county may not be able to handle the regulatory aspects as effectively as might 

be optimal from the local perspective.
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5 Community Support and Opposition

5.1 Introduction

The stakeholders were queried on their views about whether the community supported or 

opposed the idea of CSP development. In addition, the interviewees were asked who the 

important stakeholders are whose views should be taken into account in CSP and transmission 

siting decisions. Finally, interviewees were asked to express their opinions about who favored 

CSP development and who, if any, opposed it.

The importance of understanding community support and opposition was underscored by one of 

the outside-Valley interviewees who said:

No one is really bird-dogging this issue, because—think about it from the developer's 

standpoint. They want to put in as much time as is needed to be successful in a 

competitive solicitation and so it is unlikely that they are altruistic enough to go on a 

San Luis Valley-wide educational campaign without having been the recipient of an 

award. Once that happens, I think that if the awards are strategic, they could do just 

that to educate the citizens on what their technology is, what they are intending to do, 

but the dynamic that has happened—it takes time and it takes money, and it is not 

necessarily needed in order to respond to an RFP.

Summary

The lines of support and opposition were already shaping up in the fall of 

2008 when the interviews were begun. The main themes that have since 

emerged as the controversy has developed were fairly well described at 

that time. Interviewees described those supporting CSP development as 

county commissioners, farmers with land to sell, those working on 

economic development in various ways, the college, and workforce 

training. Those potentially opposed were identified as the residents of the 

Valley because they would not benefit economically, water interests in 

the SLV, the SLV EcoSystem Council, residents of Crestone, the Rural 

Electric Cooperative, and Spanish land-grant families in Alamosa and 

San Luis. Early on, concerns were expressed about whether the people in 

the Valley would benefit economically, whether the Valley floor would 

be industrialized, and if the cultural heritage of the Valley would be 

preserved. The public meeting processes seemed to involve various 

organizations telling SLV residents about CSP technology and about 

proposed transmission line siting, with each member of the public having 

a turn to share his or her views. None of the interviewees stated that the 

public meetings processes resulted in their feeling "heard," that their 

views had changed, or that any of the input at meetings resulted in 

changes to decisions made.
Interview Findings

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Until someone wins an RFP and proposes to develop a facility in the SLV, we won't know 

what the people think.

In this section of the report, the following materials are covered:

• A comprehensive list of stakeholder groups

• Self protection in the Valley

• Stakeholders' characterization of sentiment toward CSP development and transmission in the 

Valley. 

Inevitably, interviewees mentioned the low levels of public knowledge about CSP, and also 

shared concerns about the self-protective nature of Valley residents, and the issues that are 

shaping opinion about CSP in the Valley.

5.2 Stakeholders Identified Relative to CSP in the SLV 

The interviewees were asked: What parties, organizations, or groups do you consider important 

stakeholders with respect to CSP development in the San Luis Valley? The responses to this 

question have been content-analyzed. At least 125 stakeholder groups (and a few key 

individuals) were identified, and these represent the most important stakeholders relative to the 

proposed project; however, they should be viewed only as a partial list. Although the 

stakeholders identified vary in the influence they might have on the CSP and transmission siting 

decisions, the length of the list illustrates the complexity of the web of socio-economic and 

environmental interests in the SLV.

______________________________________________________________________________

Agriculturists

• Farmers in general (and their organizations)

• Potato growers

• Alligator farmer

• Ranchers (and their organizations)

• SLV Cattlemen's Association

• Colorado Farm Bureau

• Colorado Potato Administrative Committee

• 25 x '25

CSP developers/trade associations

• SkyFuels 

• Abengoa Solar

• Ausra

• Interwest Energy Alliance

• Solar Energy Industries Association

Environmental organizations

• Audubon Society 

• Clean Energy Action

• Colorado Natural Heritage and Rocky Mountain Bird Observatory 

• Colorado Wild
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• Colorado Wildlife Federation

• Crestone Sustainability Initiative

• Cultural Heritage Center 

• Quiet Use Coalition

• Nature Conservancy

• National Wildlife Federation

• Playa Lakes Joint Ventures

• Rio Grande Headwaters Land Trust

• Sangre de Cristo National Heritage Group

• Sierra Club 

• SLV Ecosystem Council 

• SLV Citizen's Alliance

• Western Resource Advocates

• Wilderness Society

• Wildlife groups

Economic development 

• Alamosa Convention and Visitors Bureau

• Bankers

• Chambers of Commerce

• Colorado Renewables Conservation

• Connecting Colorado Renewable Energy Resources 

• SLV Resource Development Group 

• Colorado Energy Forum (representing private investment companies)

• Optisolar

• Upper Rio Grande Economic Development Commission

• Valley Courier (Alamosa newspaper)

Educational institutions

• Adams State College 

• Trinidad State Junior College

Elected officials

• Western Governors' Association

• Then-U.S. Senator Ken Salazar (now Secretary of the Interior)

• U.S. Representative John Salazar and his staff

• State Senator Gail Schwartz

• Governor Bill Ritter

• Boulder City Council, Ken Wilson (named as having an interest)

• Ex-State Senator Gigi Dennis

Federal Government Electricity Agencies

• Federal Energy Regulatory Commission (FERC)

• North American Electric Reliability Corporation (NERC)

• Western Electric Coordinating Council (WECC)

Government/Federal

• Baca National Wildlife Refuge

• Bureau of Land Management
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• Environmental Protection Agency 

• Federal Energy Regulatory Commission

• National Park Service

• National Renewable Energy Laboratory

• Sand Dunes National Park and Preserve 

• U.S. Forest Service

• U.S. Department of Agriculture

• SLV Resource Conservation and Development initiative, U.S. Department of Agriculture

Government/State

• Governor's Energy Office (GEO)

• State legislators

• Clean Energy Development Authority 

• Colorado State Land Board

• Colorado Division of Labor Workforce Center

• Colorado Department of Natural Resources 

• Colorado Department of Transportation

• Colorado Department of the Treasury

• Colorado Public Utilities Commission

• Department of Water Resources

• Colorado Division of Wildlife

Government/NGOs/Local and Regional

• Alamosa City Manager

• Mayor of Crestone

• County commissioners (Alamosa, Conejos, Costilla, Mineral, Rio Grande, Saguache)

• Huerfano County Commissioners

• Alamosa City Manager

• SLV GIS Authority

• Historic Advisory Preservation Committee for Alamosa

• Rio Grande Water Conservancy District

• Upper Rio Grande Economic Development Commission

Landowners

• Crestone Property Owners Association

• Trinchera Ranch (Louis Bacon)

• Billy Joe “Red” McCombs

Law firms

• Energy Minerals Law Center

• Water law teams 

• Front Range attorneys

Private companies

• A&J Solar 

• Black and Veatch 

• Blake Jones, Namaste Solar Electric (a PV entrepreneur)

• Black Hills, LLC 

• Bill Clark Trucking 
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• Natural Power

• SunEdison

Service organizations

• Alamosa Wastewater Treatment Plant

• Hospital in Alamosa

The public 

• Citizens

• The entire population

• Electricity customers

• Local residents

• People who live near the transmission lines

Solar and sustainable resource advocates

• Southwest Energy Efficiency Project (SWEEP)

• Clean Energy Action

• Colorado Solar Energy Industries Association (COSEIA)

• Colorado Renewable Energy Society (CRES)

• Solar Alliance

• SWAT (a Southwestern transmission organization) 

•

• San Luis Valley Solar Association

• San Diegans for Smart Energy

Spiritual groups

• Shuma Institute

Utilities and transmission line owners

• San Luis Valley Power Authority

• San Luis Valley Rural Electric Cooperative

• Tri-State Electric Generation and Transmission Association 

• Xcel Energy

• Public Service Company 

• Colorado Rural Electric Association

• Colorado Independent Energy Association

Water interests

• Rio Grande Water Conservancy District

• San Luis Valley Water Group

• Water law teams of Front Range legal firms

• SLV Water Protection Coalition

• Water Watch Alliance

______________________________________________________________________________

5.3 Self Protection in the Valley

One theme that emerged from the interviews was self-protection in the Valley. Seven of the 15 

Valley respondents talked about the strong community aversion to outsiders coming into the 

Valley and taking advantage of its residents in any way. Even the interviewing for this study was 

seen by a few Valley stakeholders as an intrusion of outsiders into local affairs. One outside 

stakeholder with connections in the Valley put it this way:
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Most rural communities have fear; they're skeptical of folks from outside coming in 

and doing stuff. It's an interesting mix of emotions and you don't want someone from 

the outside coming in, but you don't believe you have the capacity to do it yourself. 

That's true for many rural communities—it's a rural psychological mindset.

A Valley stakeholder put it succinctly:

The biggest issue on the table is will we do it ourselves or will it be done to us and for 

us?

Other respondents from the Valley said the following on this point.

We were looking at concentrated solar and what they were able to produce now in 

terms of megawatts and, obviously, a lot of this information came out of California, 

and then how much land base that was used and then multiplied that land base to 

come up with 5.6 gigawatts. So we started looking at that and thought—my God, 

that’s an industrialization of the Valley floor. And of course they need water, 

concentrated solar needs a fairly substantial amount of water, so the valley has the 

three elements they are looking for which is one of the reasons that European 

companies39 are starting to court the Colorado State legislature. And that’s 

happening now. It has been happening.

Our people are very vocal...if they came in and worked with us, there wouldn’t be 

much opposition. But if an outside group tried to come in and strong-arm us, this is a 

tough community. We want to protect the environment and to protect against big 

government and corporations. If it is done properly and through the right 

channels...so, really, it is how it is done.

The reference to California is an important indicator that local residents opposed to a 

proposed transmission line to export renewable electricity from the SLV were in 

communication with an organized group opposing transmission lines for renewable electricity 

in California (San Diegans for Smart Energy Solutions).40 Local area organized opposition 

groups can and do share information and resources with each other in other parts of the 

country. Interestingly, the issues posted on the San Diego group's web site track closely with 

some of the claimed advantages of the proposed transmission line into the SLV, including the 

following.

• Serious "power gap" without the transmission line

• Proposed line is needed to transport renewable electricity to meet RPS goals

• Protects against fire hazard

• Cost-effective and beneficial to ratepayers

 39 The reference is to European CSP companies. 40 http://www.sdsmartenergy.org/SRPL_mythvsfact.pdf
Interview Findings

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• No significant environmental impacts

• Ensures energy reliability

• Good for the local economy and fosters job creation.

The opponents to transmission attempted to counter each of those points. 

This preliminary evidence suggests that these themes will likely recur in areas of the 

Southwest wherever transmission lines for renewable electricity are proposed. Given the 

commitments of the Western Governors' Association and other key organizations to 

developing transmission to bring renewable electricity to cities, understanding the dynamics 

of these opposition groups is evolving as an important national issue.

5.4 Community Positions for and against Renewable Energy in General

Stakeholders were asked: "Thinking about the SLV community as a whole, and also about 

different groups within the community, what would you estimate is the level of support for 

renewable energy development in general—positive, negative, or don't have an opinion? 

None of the stakeholders within or outside the Valley said that the community was opposed to 

the development of renewable energy in general. In fact, the general sense from the interviews 

was that groups in the Valley strongly support renewable energy. An illustrative quote is as 

follows.

In the Valley, I would say [support for renewable energy] is extremely high. I would say 

a supermajority, how’s that? More than a majority.

Tremendous, very high—without exception folks are buying into renewable energy 

development.

5.5 Community Positions for and against CSP Development

Stakeholders were also asked: "How about levels of support for the proposed CSP facility?” 

Responses differed from the broad support mentioned for renewable energy generally. Of the 15 

Valley stakeholders, only two said that the community favors CSP development, and one of 

those said the community didn't understand what CSP is. Support for solar development is based 

largely on the favorability toward the SunEdison PV plant near Mosca.

Support for Sun Edison was high, so why would people not jump on board and be 

supportive of a CSP project?

A Valley stakeholder said, "The reason the Tri-state people won't build PV systems is the cost 

($0.22/kWh)." Speaking about one of the citizens at a public meeting, this stakeholder said:

[The opponent] thinks we can run the entire Valley on solar and not have any need for 

transmission and most of these people have the idea that we could become isolationists 

and serve our own needs. Well, that's taking some steps back in time that nobody I'm 

familiar with is willing to take.
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On the other hand, half of the stakeholders outside the Valley (5 of 10) said they thought the 

community was favorable to CSP development.

I would say [the level of support] is high. Just from what I’ve heard from economic 

developers, from citizens, from residents. I can't say I’ve talked to a lot and, of 

course, most who have talked to me talked me up, so it’s not...I wouldn’t say I have 

rubbed shoulders with a representative sampling of the valley residents, but from 

what I do hear and read the support is quite high.

Another outside stakeholder said:

I would say mostly positive. Again, I am basing this [on my experience]. I take it that 

their elected representatives were in support. [At] a town meeting in Alamosa last year 

[there were] about 65 people...and I would say that except for the reservations....Well, 

there were two things. One were some reservations about transmission lines, although the 

crowd, on average, overall decided it would probably be worth it, and [there were] a lot of 

advocates there for more decentralized solar instead of just centralized stations. 

A third said that the people are positive "but not terribly knowledgeable." 

Nearly half (n=7) of the Valley interviewees said they believe the SLV community was mixed in 

its reaction to CSP development. The situation is complex. It was said that the county 

commissioners need help in understanding capacity. It was also noted that Representative 

Salazar's aides were hearing from opponents. Some quotes from stakeholders inside the Valley 

exhibiting the community's mixed reaction are as follows:

I think there are certainly cultural issues and issues of sustainability. Commodifiying of 

natural resources seems to be a big concern—the commodification of solar power.

Interviewer: Does that translate to opposition to exporting power out of the Valley?

Stakeholder: Yeah, I think people are concerned about becoming an exporter of power. 

Again, the Valley wants to receive something in return.

Interviewer: And what does ‘cultural issues’ mean?

Stakeholder: Philosophy that solar energy and wind power are appropriate for farm and 

residential areas and sustainability, but on the larger scale it becomes more utility, 

becomes industrial. Even the idea of a major corporation being in control of a local 

resource and making money from it [is a problem]. There are some that want community 

control of it, some who don’t care, and some who are just concerned about the scale of 

the development.
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Another Valley interviewee expressed it this way:

Interviewer: Would the SLV community oppose a project that large?

Stakeholder: It depends on where it is located, but finding that amount of space would be 

very difficult. There is a large environmental contingency that is very active and would 

have concerns. 

Interviewer: What types of concerns do you think they would have?

Stakeholder: So far they are concerned about it being an unsustainable renewable 

energy development, too large of a scale--large plots of land for basically one industrial 

purpose. They have concerns about the water as well—the quantity of and types of 

solutions or lubricants used. Some people are overwhelmed by the size and taking 

agricultural land out of production and decline of a way of life. 

Interviewer: So a concern about the cultural heritage of the Valley? 

Stakeholder: Absolutely, absolutely. And, if they end up putting a large facility on the 

side of a mountain and a big shiny thing, that would raise a lot of concern. 

Interviewer: So aesthetic concerns? 

Stakeholder: Absolutely, the aesthetics. 

Interviewer: What about locating a facility on retired agriculture land? How would that 

be received? 

Stakeholder: I think farmers in particular would be open to that. It’s just a matter of 

logistics.

Another Valley stakeholder spoke of mixed reactions:

Interviewer: So would you say in general people are favorable toward CSP or not?

Stakeholder: I think there are a lot of exaggerations, a lot of anxiety, and there is a 

lot of misinformation...the question is, one, are we going to see generation that is 

simply going to be shipped out of this valley with no revenues/resources left 

behind...what they’re worried about is can there be a way to share in the 

profits/benefits of the industry, long-term jobs, not just short-term jobs, and is there a 

way to also have revenues that will be generated and stay in the region? I have some 

ideas about that.... And there’s a push to have more, what they call, distributed 

generation, to put solar panels on all the houses and the schools and the buildings 

and, therefore, maybe don’t use utility scale. You hear that push back about we don’t 

want to change the culture.... I think you’re in a place that could go one way or the 

other. You could have some development here...here isn't enough...I think the 
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utilities are certainly going to control it because of the power purchase agreements, 

but the question is you want to have it integrate into the value and the culture of the 

region.

Another Valley stakeholder said about the opponents:

They want it to just be for us only and not transmit anything out. They all want 

clean energy but they don’t want to give up...have any environmental impact.

Outside the Valley the view of community support and opposition is different, as would be 

expected. An outside interviewee said: 

I imagine it is like anywhere else. There’re going to be people who are for it and people 

against it.

Another outside stakeholder said:

... that the citizens in the valley are highly interested and whenever there has been 

an event, an educational event, the rooms have been packed. They certainly 

understand the gravity of the situation and the need for energy and the need to 

educate themselves. I think they are understandably tepid about what the impacts 

might be, specifically to their local communities, for the reasons that I mentioned 

about a not well-understood technology and wanting to make sure that their local 

communities benefit from any development in the San Luis Valley. 

Interviewer: So it is clearly understood by the people but not by the.... You mean by 

the people themselves.... You don’t mean by the technologists?

Stakeholder: I think it is a new technology to most people and I think there is a 

good amount of education or a lot of education that would probably need to happen 

in the valley and I think we need to turn that responsibility back over to potential 

developers to educate the citizens in the valley on what the technology is, what it 

isn't, to debunk some myths, but probably, most importantly, not to overpromise. I 

think...the feeling in the valley is a strong interest.

Another stakeholder outside the Valley said:

From the different kinds of groups, I’d say anybody in the economic development area 

would probably be supportive with some caveats probably, but...

Interviewer: What kind of caveats?

Stakeholder: I think that what I hear is probably a realistic concern, is that when there 

is a large plant to be built, of any kind, you can bring in labor, and can tend to come into 

an area, overwhelm the area (maybe, maybe not) and then leave the area. So, there’s a 

kind of preference for local labor and that doesn’t always happen. That was the case in 
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Nevada for Nevada solar power, so that would be one of those caveats.... I think you 

might find groups that are leery of companies coming in and taking advantage of the 

area."

5.6 Don't Know What Stakeholders Feel

Three of the interviewees (two outside and one Valley) said that they didn't know what 

community response toward CSP development was. An outside Valley stakeholder said:

I don't know because I haven't wandered around there and asked people. At [other sites]

public support has been tremendous, very positive. Economic growth, tourism, clean 

energy, it has been exciting. I think the same will be true in the Valley. Whoever develops

the plant has to start meeting early with the local people. It takes a long time to explain 

to people—[questions arise], such as will the mirrors blind pilots? [One developer] had 

to fly over [a] plant and take a video showing that at no angle would the sun's rays be 

reflected up to the airplane.

5.7 Perceived Need for Education

Several interviewees stressed the need for public education. For example, one of the outside 

stakeholders said:

There might be a misperception by the public that these renewables are an 

answer. I don’t think they understand the impact that, especially solar, has on 

the land. And that is you know―one square mile of solar facility equals so many 

megawatts and when you really look at that it’s a square mile of nothing but a 

solar facility. There’s not too much else that happens on that land.

Two Valley stakeholders said:

They don’t know enough. If people were honest with you, I think they would tell you that. 

They just don’t know because of lack of education. Adams State College could play a role 

with that if they wanted to—could be a place where educational forums could take place.

...there is no group that is standing out there saying we need concentrated solar 

power. There is no group that even probably knows what it is.

Pointing to the need for public education, another interviewee from the Valley stated:

[There was] a public meeting last night.... Some of those speakers from Crestone 

there...had no desire for any kind of transmission project and had the desire that 

we produce all of our energy from our own source.... [There have been] more and 

more meetings. Last week [there were] two meetings on transmission lines and all 

these issues get addressed every time [there is] a meeting.... [there will be] another 

series of meetings basically on the transmission line, [I think there should be] a 

focus group of people to deal with energy issues because there are huge issues 

today.
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6 Transmission Issues Raised by Stakeholders

6.1 Introduction

The interviewees were queried on their views of the most important considerations in the siting 

of a transmission line for renewable electricity. They were asked: "From the perspective of your 

organization, what are the most important considerations involved in power transmission?" 

Responses ranged from full support for the transmission through neutral, factual responses, to 

mention of community conflict about transmission, to opposition.

Stakeholders in the Valley said that Rio Grande, Alamosa, and Saguache Counties are interested 

in CSP development. It was generally agreed by knowledgeable stakeholders that new 

transmission lines would be needed if a CSP facility at a scale of about 200 MW were to be 

developed. One said: "The current Climate Action Plan models a 200-MW concentrated solar 

power facility somewhere in Colorado." Viewsheds, availability of water, and availability of 

transmission are the biggest considerations for siting CSP. This section discusses the issues 

raised in the interviews relative to transmission on a continuum from support to opposition. 

6.2 Support for Transmission

As reasons to support transmission, Valley interviewees perceived the following: (1) the desire to 

export power as a way to bring income into the community, (2) the need for security and 

redundancy of the Valley's power supply, and (3) the need for improved power infrastructure.

6.2.1 Desire to Export Power

We located 20 comments from stakeholders inside the Valley that addressed the need for 

transmission to export power. This is one of the most commented-on issues in the interviews. 

One of the Valley interviewees said:

Well, in some ways we have the ability to meet our needs with solar and provide for other 

people’s needs, so we have done a little bit of research, even with people that live in 

Summary

The main reason for CSP development in the Valley is the provision of 

electricity to Colorado’s Front Range cities. Stakeholders outside the 

Valley accepted this premise. Within the Valley, support for more 

transmission lines into the Valley revolved around the desire to increase 

the flow of income into the community by exporting electricity, the need 

for increased security and redundancy of the Valley’s power supply, and 

the need to improve the Valley’s grid and increase its energy supplies. 

Opposition to transmission lines focused on fear of loss of control of local 

land and of the decision processes, aesthetic concerns, fear of 

industrialization of the Valley floor, wildlife concerns and concerns about 

the legal processes at the Colorado Public Utility Commission regarding 

the proposed large-scale transmission line over La Veta Pass and into the 

Valley from the east.
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places like Boulder and asked them if I have a megawatt of power and I’m generating in 

the San Luis Valley, would you have an interest in it? And we’ve got responses that 

include things like not only would I have an interest in it, if it is really renewable and can 

really guarantee that this project could be sited in the San Luis Valley, I will pay you a 

premium. I will give you a $1.30 for your $1 worth of power and I will buy it by 

subscription, I will pay you a year in advance so you have the money to help build the 

facility.

Yeah, it’s about 200 MW as a rule of thumb for a number to use. So if you went to 200

MW, doubled its size, you would meet the demand and then you would have the ability to 

expand to 400 megawatts and instead of importing 200 you’d be exporting the extra 200 

so now your renewable energy generator is exporting 200 MW and generating the same

income that used to leave here as a payment to a utility. 

Interviewer: Okay, so the idea is to own [one or more CSP facilities] locally and first 

meet local demand. 

Stakeholder: That is going to be the most palatable environmentally. 

Interviewer: Okay. What about transmission? I mean transmission is a big issue or 

apparently a big issue, so what about that?

Stakeholder: Well, 100 MW, should we put this on the ground, we meet all the 

conditions that you and I described to date, then we would be meeting half the demand 

of the San Luis Valley.... And second export and bring money into the Valley by selling 

power. 

An outside stakeholder described it this way: 

Really no one can build anything in the SLV until there's a transmission highway to get it 

out.

6.2.2 Need for Security and Redundancy

Valley stakeholders talked about their concerns about the vulnerability of the Valley's electricity 

supply. Ten comments fell into this category. One interviewee from the Valley said:

Interviewer: You mentioned transmission as a limiting factor?

Stakeholder: Yeah. But there is a proposal for Xcel and the REC to go together and put 

a pair of 230-kV [transmission] lines over La Veta Pass from the east, which would be a 

good idea because of the vulnerability that we are in right now because it all comes over 

from the north.
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Another Valley stakeholder said:

It comes from the north, two transmission lines, and last night we even left the Homeland 

Security comment on the table that two guys with one chainsaw could take all the power 

out in this valley. There is no redundant power. All the poles....if you cut four telephone 

poles you can shut down the power in the entire San Luis Valley. It is completely 

inappropriate for any future development. There is a huge significant issue about 

redundancy in transmission lines.

Another stakeholder was asked if they had any thoughts or feelings about the energy leaving the 

SLV to help Denver or the Front Range. The response was:

Yes, positive as long as it promotes revenue. But concerns about transmission—what 

will it take to handle the transmission of solar power. We don’t want to export the 

water. If there is a win-win then the Valley would be all over it.

Another Valley stakeholder said:

So the Valley basically right now uses about 155 MW and I believe you need 1,000 

MW to equal one gigawatt, so then the question becomes, geez, what is all that 

other potential for? Well part of it is redundancy so the Valley has another way to 

get energy if something happens; the other is for the Valley to grow and possibly 

invite industries that have never been able to locate here before. That’s what’s 

being promoted. And then the other piece is that it is a valuable potential to be able 

to export power. For the first time the Valley will become an energy producer, and 

obviously one of those ways the Valley will be able to produce energy is through 

concentrated solar.

6.2.3 Need for Improved Power Infrastructure

At least one Valley respondent said that the SLV needs more power.

Interviewer: So they must be thinking that there is going to be renewable energy 

development in the Valley if they’re building this line. 

Stakeholder: We needed the power in as much as eight or nine years ago, so the 

initial thrust for that line was us needing power to support our developments, our 

growth in the western area, South Fork, Creede. When renewable energy came around 

and NREL named us a spot for really good solar and they passed the renewable energy 

bill, all of those things said to Xcel we’re going to need transmission from the San Luis 

Valley.... [It will happen] one way or another. And it should be.... we don’t put any 

money in, it is just for our system, and Xcel and Tri-State pay for it. It is about an $80 

million project. It should be completed by 2012 or 2013. 
Interview Findings

47

Interviewer: And why are they doing this?

Stakeholder: Because we are running out of power in the valley. The last 

transmission line built in San Luis Valley was 35 years ago. 

Although existing transmission lines could probably support an additional 50-100 MW of CSP 

development, Valley stakeholders made several comments suggesting that the size of the CSP 

plant needed to be as large as 200 MW. As noted earlier, this size of facility would allow local 

demand to be met first and would begin to yield additional electricity for export out of the valley.

Another local stakeholder talked about the scale of a possible CSP facility. 

Is this the one [a Valley expert] keeps talking about that is 5,000 acres and 

enough power to power six planets? ...We talk about it all the time because it is 

considered very important for our economic development. If you take a resource 

like that and don’t leverage it, then you’re really missing the boat. We are 

“green” here in the Valley and it resonates with us. Our agriculture industry is 

having problems because of water and depletion of the aquifer. And since 

agriculture is our number one industry, we need to diversify. Tourism is our 

number two industry, which only represents 11% of our economy. We have 

80,000 square miles here in agriculture production, so...if some of these farms 

converted to a product that did not use so much water that is a good thing.

An outside stakeholder said:

What sets solar thermal apart from PV? PV uses semiconductor—electrons —

generates electricity directly. Solar thermal is a large-scale parabolic 

trough—above 5 MW it's cheaper than PV. Below 5 MW, PV is cheaper. So 

solar thermal gives you the scale. 200 MW is the sweet spot. CSP has 

scalability. You would never have a 200 MW PV system.... The characteristics 

of thermal are that it has more thermal inertia—in the tube is oil at 750 

degrees. If a cloud goes over it, it still stays hot, so it has more even 

performance. PV production is spiky because when it is cloudy, the output 

drops dramatically. So each time a cloud passes over a PV system, the 

production goes way down. Thus, the grid has to be able to handle spikes. 

There is no such limitation for solar thermal, it's very predictable and even....

Stakeholders said that, in the Valley, the transmission issue was as big as the water issue. Yet, it 

seemed to be fairly generally agreed that new transmission had to be built if a CSP plant of any 

economic size (e.g., 200 to 300 MW) is to be sited in the Valley. Looked at another way, a CSP 

plant up to 200 MW could be accommodated on existing lines, but anything beyond that could 

not.
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48

6.2.4 Neutral Comments

Two quotes below illustrate a neutral, fact-based explanation of the transmission situation 

without exhibiting a position.

It’s been all over the newspapers that the SkyFuel wants to do 1 gigawatt power—

they won’t do it all at once though because we don’t have the transmission to handle 

that. They are going to have to build out if that ever happens. But there again, that’s 

5,000 acres.

And,

Number one is current availability of transmission, and we are currently maxed out. 

There are three coming over Poncha Pass—small, medium and larger. There is one 

proposed to come over La Veta Pass.... Second concern is size of a new transmission 

line—can it meet current demand and possible new development. I think solar 

development will go beyond the capacity of the new line (230 KV) that Tri-State and Xcel 

are proposing. If at some point we are going to develop solar power and transport it out 

of the Valley, we need to address this issue. But how do we finance this?

6.3 Opposition to Transmission

As reasons to oppose transmission, Valley interviewees mentioned (1) fear of industrialization of 

the Valley floor, (2) aesthetic concerns, (3) feared loss of control, (4) wildlife concerns, and (5) 

legal-regulatory concerns.

6.3.1 Fear of Industrialization of the Valley Floor

A few comments appeared to oppose transmission lines. Fear of uncontrolled industrialization of 

the Valley floor was expressed in the following quote:

I don’t think anybody in the valley has a problem with a one gigawatt transmission 

line. The problem is once that transmission line gets in here, what are the possibilities 

of taking advantage of that because the loop will then all be there, the loop will be 

formed, and then other industries will be very attracted to the fact that it is in now and 

they may want to develop and build on that and they may want to take it to 5.6 

gigawatts.... All these companies aren’t going to invest in the valley for 1 gigawatt. 

They’re not. They’re going to want more and that’s the quandary. And unfortunately 

that’s what concentrated solar represents.... So are we really thinking in an 

antiquated way by thinking in terms of concentrated solar? Will we end up coming up 

with much more efficient ways of being able to distribute solar other than by 

concentrating it?

Also, concerns about public health and electro-magnetic fields (EMFs) were said to be 

concerns of neighbors living near the proposed lines.

6.3.2 Aesthetic Concerns

A few comments decried a proposed transmission line because it would be "on our vistas" and 

would be aesthetically displeasing, "going over the mountains."
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49

It was noted that one of the Valley's counties opposed transmission lines.

Costilla is most concerned with transmission lines being placed across their county—

aesthetic concerns, and also they want to be sure that they receive local benefits. In 

particular, their largest landowner, Mr. Bacon is concerned about transmission lines 

going across his private land, which is used for ranching and wildlife. He might have 

concerns about future property development. 

6.3.3 Fear of Loss of Control

As noted earlier, Xcel Energy and Tri-State would be granted eminent domain should they be 

granted the CPCN for the transmission line. Some comments expressed fear of loss of local 

control of property legally condemned under eminent domain.

6.3.4 Wildlife Concerns

Concerns were expressed about the possibility that the transmission line would bisect wildlife 

corridors in the La Veta Pass and Trinchera Ranch areas and that transmission lines can be 

hazardous to birds. According to some residents, power poles can give raptors an advantage 

over the other species because transmission lines are required to provide raptor perches.

6.3.5 Legal-Regulatory Concerns

As described in Part Two of the report on the transmission controversy, Louis Bacon, who owns 

the Trinchera Ranch, has hired attorneys to oppose Xcel Energy and Tri-State's application for a 

CPCN to build the transmission line. In interviews, Valley stakeholders had identified Louis 

Bacon's opposition to a proposed transmission line. 
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50

7 CSP Facility and Transmission Siting Decision Models

7.1 Introduction

During the interviews, stakeholders discussed how they believed the decision to site a CSP 

facility would be made. At least three different decision models emerged from the interview 

data: (1) SLV Power Authority decision-making, (2) county permitting, and (3) permitting on 

public lands. Each of these is described in this section. In addition, other organizations have 

decision authority affecting the transmission and siting of a facility.

7.2 SLV Power Authority Decision-Making

A number of stakeholders within and outside the Valley mentioned the concept of a locally

owned 100-MW CSP power plant that would sell electricity. A concern about the security of 

power supplies in the Valley was one motivation for moving ahead. As one community member 

put it: "Any time you can shut an entire population of 18 incorporated communities with a 

chainsaw, cutting four poles.... and worse than that...somebody rolling a car and starting a grass 

fire that could develop into a forest fire would take it out also." 

The only transmission line into and out of the Valley goes over Poncha Pass. As noted earlier, 

Valley stakeholders mentioned that all the Valley's power comes in via the existing transmission 

lines from the north, which leaves the power supply—which lacks redundancy—vulnerable to 

sabotage, forest fire, or other unexpected occurrences. 

Under existing statutes, a local nonprofit was working on forming an SLV Power Authority. The 

primary statute relied upon authorizes a power authority that ties together the cities and counties 

for the sole purpose of providing a "nest." As the leadership becomes more aware of the potential 

of developing solar power for their own purposes, the Power Authority would be available to 

them.

Summary

One of the key points from the interviews is that the facility siting 

and transmission siting decision processes are extraordinarily 

complex and are not well understood by the public. In fact, those 

responsible for decision-making may not themselves fully 

understand them. They may be opaque to the public, which makes 

public comment more difficult. Only a few parts of the decision 

processes appear to be open to public comment. Knowledge of 

how these decision processes work equates to power for those 

organizations "in the know"; local community groups may not 

have access to those processes in a timely way.
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So going again back to 1995 when we first formed the authority and statute, so the 

county commissioners could, for the purpose of telecommunications or power, have a 

body that could manage an authority. It actually became public on March 1, 2006, 

when the National Renewable Energy Lab and Tri-State Generation and Transmission, 

Rural Electric, Xcel Energy, Healthcare Governance and Education all came together 

at Adams State College to talk about the feasibility of doing a 100-MW concentrated 

solar project that would be a locally owned, locally controlled project that would 

redistribute power to the existing utilities—the Rural Electric Cooperative and Xcel 

Energy—as well as some of the people off the grid. Historically, we got a certificate of 

area where some of the primary concentrated populations were served by Xcel Energy 

and the rest of the valley was served by San Luis Valley Rural Electric Cooperative. 

At the time of the interviews, during the fall and winter of 2008-2009, the SLV Power Authority 

was still being developed, although most of the 18 county commissioners had put forward the 

money to start an RFP for a feasibility study. 

A local concern was, reportedly, that SkyFuels and Ausra (CSP developers) had been in the 

Valley discussing the possibility of a 1-GW CSP facility.

The biggest issue on the table was will we do it ourselves or will it be done to us and 

for us. We actually formed a council of governments on July 28, 2008, to formalize the 

revised statutes to enable the county commissioners to form the power authority.

The concept that the local stakeholders were working on involved siting small 0.2-MW projects 

at all 15 substations in the Valley—called "diffused solar"—to make more than enough power to 

meet the valley’s needs. A local stakeholder said:

...amazingly people here control hundreds of millions of dollars in property or hundreds 

of millions of dollars in finances, but when it comes time to do a $100 million project will 

balk that they don’t have that history...

An institutional barrier to "diffused solar" was described by an outside stakeholder. He said that 

the rural electric cooperatives are sold electricity generated from coal plants built with loans 

from the Rural Utility Services (RUS), an agency of the USDA. As part of RUS funding coal 

plants with low- or no-interest loans, the RUS institutes an "all-requirements" contract through 

which cooperative members agree to buy 95% of power for the life of the project. RUS funds 

Tri-State, which distributes electricity to 44 rural electric cooperatives. In this way, the 44 co-ops 

are, in this stakeholder's view, "yoked to coal plants." Although the co-ops could bring on 5% of 

power from another source, this stakeholder said that the regulations to do this are so onerous 

that the co-ops cannot do it. This stakeholder believed that exemptions from the "allrequirement" contracts are needed at the federal level for cooperatives to put "green electrons" 

into their systems.

A related concept is that of a distributed system in which, say, 20-MW plants could be built next 

to existing power substations. In this more distributed model, the dollars generated would stay in 

the state's economies and would be spread across the tax base of the local counties, which would 
Interview Findings

52

keep funds within the state. There could be a higher cost for wholesale electricity, but the 

benefits would far exceed those of the centralized model where so many of the dollars go out of 

the state. 

Another outside stakeholder said, in reference to the idea of a locally funded CSP project, "trying 

to raise $1 billion is very challenging." A CSP development project is very complex, involving 

independent engineers, private auditors to estimate market value, and "it will cost $1 million in 

legal fees alone."

Another outside stakeholder raised a question about whether a local power authority could 

actually own a CSP plant.

Well, we’ve got San Luis Valley Electric Co-op serving part of the valley. We’ve got 

Public Service Company serving part of it, currently Alamosa, and if you are talking 

about somebody who would serve their territory, you’re going to have to get 

legislative41 approval to do that. They are not a utility now and in order to become 

one, if that’s their intent...There are lots of ways of reorganizing entities like cities 

into municipal utilities. It means negotiating with the utility that today holds the 

franchise and condemning the property, all of that stuff, but if they want to be just a 

wholesale supplier to the grid, they’ve got to find a utility to buy their power. If they 

want to become a utility, as in a distribution utility, there’s not enough people in the 

San Luis Valley to use that much power so it’s got to go out of the valley somehow, 

doesn’t it? 

This model of locally owned and operated small-scale CSP facilities distributed over the Valley 

floor was a popular concept among Valley stakeholders.

The situation that was described by stakeholders outside the Valley, however, was that the 

Valley electricity customers could not absorb all of the electricity from a large-scale CSP 

facility; therefore, a new transmission line would be needed.

With respect to development of a local authority, existing statutes may give some legitimacy to 

this effort. Renewable electricity cooperatives have been authorized by Colorado statute to invest 

in generation assets and sell power at wholesale. This would be regulated by the U.S. Federal 

Energy Regulatory Commission (FERC) at the national level; FERC regulates the wholesale 

power market.42 FERC is an independent agency that regulates the interstate transmission of 

natural gas, oil, and electricity. FERC also regulates natural gas and hydropower projects. 

Chairman Jon Wellinghoff recently issued a statement about the integration of renewable 

resources into the nation's electricity grid:

Approximately 9,000 MW of variable energy resources [VERs] went into commercial 

operation in the U.S. during 2009 and a similar number in 2008. Currently, there are 

thousands of MW of VERs, particularly wind, in the process of interconnecting to the 

electric grid. These new resources offer low operating costs and low greenhouse gas 

 41 One reviewer said it could be regulatory rather than statutory authority that is needed. 42 http://www.ferc.gov/about/about.asp
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53

emissions, which can benefit consumers.... VERs also have some operational 

characteristics, which present challenges to system operators. Therefore, it is 

important that the Commission examine the most efficient ways to effectively 

integrate these resources into the electric grid, while maintaining reliability and 

operational stability. We want to examine whether existing rules, regulations, tariffs 

or practices within the Commission’s jurisdiction hinder such efficient integration. I 

look forward to parties’ comments on the issues and questions that the NOI [notice of 

intent] identifies, and to thoughtful and thorough discussion of any reforms that may 

be needed to remove barriers to the full integration of VERS.

The North American Electric Reliability Corporation (NERC) manages the standards for the 

system.43 It ensures the reliability of the bulk power system in North America. NERC develops 

and enforces standards, assesses the adequacy of the electricity supply, monitors the bulk power 

system, and educates industry personnel. It is subject to oversight by FERC, which granted 

NERC the legal authority to enforce reliability standards of all U.S. users, owners, and operators 

of the bulk power system, making standards mandatory and enforceable. It is a non-government 

organization with statutory responsibility.

The Western Electricity Coordinating Council (WECC) markets hydropower.44 WECC is the 

regional entity responsible for coordinating and promoting bulk electric system reliability in the 

Western Interconnection, a synchronized electric grid that spans 1.8 million square miles from 

the Canadian provinces of British Columbia and Alberta, to the northern part of Baja California, 

Mexico.

45 In addition, WECC assures open and nondiscriminatory transmission access among 

members, provides a forum for resolving transmission access disputes, and provides an 

environment for coordinating the operating and planning activities of its members as set forth in 

the WECC Bylaws. Membership in WECC is open to all entities with an interest in the operation 

of the bulk electric system in the Western Interconnection. All meetings are open and anyone 

may participate in WECC’s standards development process.

To understand these complex relationships, the independent power producers (IPPs), the 

investor-owned utilities (IOUs), and WECC all compete to sell power on the electricity markets. 

A San Luis Valley Power Authority would be an IPP competing to sell power. Although there 

are Colorado statutes permitting municipalities to form utility districts, it is less clear that 

counties or multi-county regions have the statutory authority to do so under Colorado law.

7.3 County Permitting

A different model of CSP development is that a private CSP development company (IPP) 

purchases sufficient privately owned land, along with water rights, on which to site a facility. 

This subsection describes interview findings on the role of CSP development, Xcel Energy’s 

role, and the role of the Colorado Public Utilities Commission (PUC). A local stakeholder, who 

seemed to believe that PV and CSP were interchangeable, said that numerous companies (IPPs) 

had been acquiring private land.

 43 http://www.nerc.com/page.php?cid=1 44 http://www.wecc.biz/About/Pages/default.aspx 45 http://www.westgov.org/index.php, glossary, accessed April 20, 2010
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We’ve had 10-15 companies who have approached us, been in to talk to us, and 

acquired land throughout the valley [to build solar collectors] I think already or put an 

option on it....

In this model, the usual permitting processes controlling any facility siting application is used for 

the CSP plant. One Valley stakeholder described it in the following quote.

Well, [there is] zoning and this type of stuff and the control where different things are 

set. We run it before the planning commission and then it comes before [the county 

commissioners] and the planning commission has public meetings and hearings to 

address whatever concerns the residents...if somebody comes and picks out a location 

and this is where they were going to set it, they would have to come before the 

planning commission, take out the proper permits. [The county commissioners] can

either deny it or approve it....

Two major comments from study stakeholders have a bearing on this process. One, from a 

Valley resident, said that the county commissioners tend to avoid their role in public policy.

They just avoid everything and the way to avoid everything is just to say 'I don’t want any 

regulations.' Unfortunately, what they end up doing is inviting all their decision makers 

to come in and make a decision for the rest of the county...County commissioners have a 

lot of authority, but...they don’t exercise it on the level that they could. County 

commissioners.... As a general rule are rather disempowered in this valley. It is kind of 

sad. There are a couple of personalities that really step up to the plate but a lot of them 

are really timid. They are always afraid that they’re going to be sued so they have a 

tendency to fall into this place of inertia. They don’t want to be sued by industry. That 

was said to us when we were working on the [an environmental] issue. We actually had 

the attorney say, well, we’d rather be sued by the environmentalist than...the developer." 

The other comment pertained to the realities of utility decision-making in the state. All of the 

electricity customers are already being served by the SLV Electric Cooperative and by Xcel 

Energy. If someone else tried to serve the SLV territory, then there would have to be legislation 

to permit a new utility to exist. 

There are ways of reorganizing entities into municipal utilities. It means negotiating 

with the utility that today holds the franchise and condemning the property, all of that 

stuff, but if they want to be just a wholesale supplier to the grid, they’ve got to find a 

utility to buy their power. If they want to become a utility, as in a distribution utility, 

there’s not enough people in the San Luis Valley to use that much power so it’s got to 

go out of the valley somehow, doesn’t it? ...There has to be a purchase power 

agreement if they are selling to a utility which actually has customers. If they want to 

become a utility, that means they have customers and they got those customers 

somehow which means somebody else has given them up...if they built a solar plant 

of any reasonable size, you’ve got to sell power outside of the valley. The valley can't 

absorb [that much power]."
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Finally, counties do have the authority of local eminent domain, in which they can take property 

for public purposes.

7.3.1 The Role of Private CSP Development

An outside stakeholder described four roles in getting a CSP plant going:

1. Consultant/technologist partner (the CSP part)

2. Developer - this partner plays the role of securing land, water, transmission, permits, and 

the power purchase agreement (PPA); this partner could be a well-backed developer

3. A company to construct the plant

4. Owner/investor who finances the plant.

Financing a plant would require large investors. The developer pays the CSP and engineering 

companies, and funds the costs of getting options on the land and water permits. All of these 

parts would cost perhaps $2 million. The cost of building a CSP plant is $4,500/kW, assuming a 

system without storage. With this estimate, the cost would be approximately $450 million for a 

100-MW plant. One billion dollars would be needed for a 200-MW plant. According to this 

stakeholder, only the big investors (pension funds and hedge funds) can invest in these projects.

Companies rose up to service large plants and engineering companies got good at 

building them. Developers got efficient at developing these projects. They learned to 

borrow money, build the plant, and arrange a PPA with the utility company. They used 

the contract to finance the construction of the plant and pay it back from revenues 

from selling the electricity. It was a model of finance that was used over and over.... 

The regulated utility has a monopoly, so they can build a plant on their large balance 

sheet; basically it's financed through the rates, with the charge passed on to the 

customers.

Independent companies get a PPA contract from the utility; then go to Wall Street and get 

financing; then the revenues from electricity sales go to service the debt and make a profit.

The same stakeholder went on to say:

But, the business model didn't pan out. The plants were built not in the best places 

to sell electricity to customers. These power plants became "stranded investments." 

Enron was a chimera. They couldn't buy electricity from the desert and sell it in 

California and make a profit. One reason was the inadequacy of the transmission 

lines—this was a factor in the failure.

FERC also defines the "large generator integration process (LGIT)" that guides the process that 

leads to interconnection agreements. The interconnection agreement is between the developer 

and owner of the transmission line. In some cases, the utility owns the line; in other cases it is 

some other entity.

An outside stakeholder said that, relative to distributed technology that some people in the 

Valley want, "PV panels won't have a significant impact on climate change. They won't solve the 

problem because of the spinning reserves issue." This stakeholder went on:
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It's a billion dollar venture. I don't see local ownership. On the other hand, I 

guess—I'm not creative enough to think how the public could have a set tiny percent

—I don't want to go there. Financing a plant in today's market is challenging. I don't 

think local ownership is a good idea—it's not appropriate. It doesn't fit the CSP 

plant—you don't have local ownership of a nuclear plant.

When asked about the effect of the current U.S. economic situation on developing CSP in the 

SLV, this stakeholder said:

It's challenging; the banks have not been lending money and when they do it's for 

higher interest rates and a shorter term. There is a problem on the debt side. [With 

respect to the 30% federal investment tax credit]...It's like getting a library card to a 

library that's closed. There's no way to turn it into money. The tax investors are gone, 

and they were Lehman Brothers and AIG; the stimulus bill has provisions being worked 

out; DOE has a loan guarantee and they'll be slow to work out the program. Financing 

is a challenge. It can be done but it's a lot different than it was a year ago. People can't 

borrow money for a car or house, so how can you borrow money for a power plant at 

$1 billion.... We don't know how the stimulus bill will work, and it's short term. Can 

you get a plant negotiated and get a permit by the end of 2010?...For the banks, there's 

a loan guarantee—but how much will they guarantee—it's still being invented....

It's a challenge, these are expensive plants, there's a utility that's been told to buy green 

energy in Colorado, and if the financing—the fuel for the plant is money (debt and 

equity), and if the cost of the capital is too high, the utility will say, this is too expensive 

for the ratepayers. There is an issue that the stimulus bill and all the help the feds do; 

the feds subsidize the competition; this is a reference point; somehow there's got to be a 

way to finance these plants.

7.3.2 Xcel Energy’s Role

A privately-owned utility, Xcel Energy is a regulated monopoly. Xcel Energy issued an RFP in 

January 2009 for IPPs to propose projects from all sources with bids due back in April 2009. 

This was driven by Amendment 37 legislation and their resource plan filed with the PUC 

(Docket No. 07A-447E). The utility received bids for 12,000 MW of power from all sources. 

Bids included fixed PV, one-axis PV, trough CSP, dish stirling, and power tower. As it pertains 

to the San Luis Valley, the plan is for is 280 MW and 310 MW of incremental solar resources 

across a variety of technologies and developers that would be producing power online by 2015. 

The amount of solar resources could go higher (closer to 380 to 390 MW) if the PUC directed it. 

The bidders are responsible for delivering the power to Xcel Energy's transmission lines, and if 

the site is not next to a transmission line, the bidder would have to build the infrastructure to 

deliver the electricity to Xcel Energy's system.

A 200-MW solar thermal plant with storage is probably going to take about 4 square 

miles so it is not like every project that is bid just happens to lie right next to one of the 

transmission lines, so it is the capacity of the line plus where they are locating, where 
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they are proposing to locate the plant, where the substation is going to be, how much 

connection is going to be required....

According to an outside stakeholder, the IPPs: 

...have all picked their technology; they want to propose and they have picked the 

locations that they want to propose...as part of their due diligence, the utility will 

make sure that if they don't currently have site control that they have a clear path 

to which they can achieve site control.

A decision on the winning bidder should be made soon.

7.3.3 The Role of Colorado Public Utilities Commission (PUC)

Brief background information is needed to understand the role of the PUC in the siting of CSP 

projects and of transmission lines. The PUC authorizes the acquisition of 200 MW of solar with 

storage. The planning process employed, called Least-Cost Planning, means that literally the 

least-cost path to generation requirements are selected. In 2007, the PUC amended its rules to 

allow a deviation from least-cost which was cited as an exception to the statute. Section 40-2-123 

authorizes and exhorts the commission to approve the acquisition of new, clean, renewable 

energy resources that could be deemed demonstration projects of technologies that were not 

available at commercial scale. These are called "Section 123's." It is generally acknowledged that 

these projects are going to be more costly than the equivalent amount and capacity of a fossil 

plant, but they can be selected to give new technology a start in Colorado. Bidders are asked to 

bid competitively for this product. According to this process, 200 to 600 MW will be coming in 

over the next eight years.

Any PPA that involves selling electricity to Xcel Energy would be subject to regulation by the 

PUC. But if the local power authority sold directly to WECC it could avoid PUC regulation.

The PUC might ultimately be the decision authority on the proposed transmission line into the 

Valley. According to an outside stakeholder, before the utility starts acquiring rights of way and 

land to build a transmission line, it needs to obtain a certificate of public convenience and 

necessity (CPCN) from the PUC. The utility has to get approval from the PUC for the line at a 

"conceptual level." The PUC considers the economics of the proposal, the reasons for building

the proposal transmission line, and the impact on the grid. 

If the PUC approves the line, then the utility acquires rights-of-way if need be, in a step-by-step 

process working through landowners, counties, and cities. Typically, the utility pays localities 

for use of rights-of-way, and if need be condemns land and compensates landowners. If there are 

disagreements, the utility has the right to bring them to the PUC to determine whether conditions 

attached by the localities make it economically infeasible to build the line. The PUC essentially 

has backstop authority over such issues. The PUC's charge is to uphold the public interest; it is 

not necessarily to uphold the interest of the localities per se.

Another stakeholder characterized the current energy situation and the role of the PUC 

differently. This stakeholder said of the state's utilities:
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They don't share resources. Classic example right here in Colorado: while we sit here 

having Xcel having 500 MW of excess capacity from Comanche 3, we have Tri-State 

trying to build 700 MW of coal plants in Kansas to bring the power into Colorado to 

serve their growing needs on the front range for the rural electric members.... Court 

decided against it. They're still appealing it in Kansas. Now Tri-State has announced 

it wants to build a nuclear plant near Lamar. We are sitting here in a state with 26 

GW of undeveloped renewable power and we have Xcel that has excess capacity and 

Tri-State who needs capacity, and Xcel who could firm intermittent resources—if you 

just look at Colorado as the sandbox, you'd say "Xcel and Tri-State, you play 

together. You figure out how to give us the maximum amount of renewable energy at 

the least cost.

7.4 Permitting for Solar Energy Development on Public Lands

On April 4, 2007, the U.S. Department of the Interior (DOI) issued an Instruction 

Memorandum (No. 2007-097) to its field officials concerning "Solar Energy Development 

Policy." The policy background in the memorandum refers to an overall strategy "to develop a 

diverse portfolio of domestic energy supplies" in the United States, citing the National Energy 

Policy of 2001 and the Energy Policy Act of 2005 (P.L. 109-58, August 8, 2005). Section 211 

of the Energy Policy Act of 2005 "encourages the approval of at least 10,000 MW of nonhydropower renewable energy projects on the public lands within the next 10 years.”

The memorandum states: "the BLM's general policy is to facilitate environmentally 

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

technology on BLM facilities where feasible." The memorandum instructs field officers to 

process applications for such facilities as right-of-way authorizations under Title V of the 

Federal Land and Policy and Management Act (FLPMA) and Title 43, Part 2804 of the Code 

of Federal Regulations (CFR). Applications for CSP must comply with the BLM's planning, 

environmental, and right-of-way applications requirements. 

The instructions state that these applications "will be identified as a high priority Field Office 

workload and will be processed in a timely manner." They also state that "early public 

notification and involvement of local communities and other interests is also important in 

increasing public acceptance and avoiding potential conflicts, especially in areas where other 

uses exist on the public lands." 

As of October 2008, no applications for large-scale CSP projects had been received by the 

BLM office in the San Luis Valley.

7.5 Permitting for Transmission on Public Lands

The USDA's Rural Utility Service (RUS) finances electricity development through the Rural 

Electrification Cooperatives. RUS is under the USDA Rural Development Utilities Programs. 

The Rural Electrification Act of 1936 provided funding through cooperative electric power 

companies (or co-ops), to electrify the rural areas of the United States, which before then had 

no power. The member-owned co-ops still exist today; their role is to purchase wholesale 

power and distribute it using their own network of transmission and distribution lines. The 
Interview Findings

59

USDA's program now helps rural utilities to expand and update their technologies, working in 

partnership with nonprofits, public bodies, and for-profit utilities. 

Because of its role in financing Tri-State Generation and Transmission Association, Inc., 

which supplies power to rural electric co-ops in several states, including Colorado, and 

because Tri-State is one of the applicants for a CPCN to run a transmission line into the SLV 

from Walsenburg, the RUS was required to hold public hearings in the area of potential 

impact from that line.

7.6 Other State Organizations with Potential Decision Authority

Beyond the decision models described above, there appear to be other organizations with 

decision authorities of various kinds that will influence CSP development in the Valley. 

These include the Governor’s Energy Office, the Water Conservation District, economic 

development groups, the Colorado State Land Board, the Colorado Department of 

Transportation, the Colorado State Treasurer’s Office, the Clean Energy Development 

Authority, and transmission planning groups.

7.6.1 Governor's Energy Office (GEO)

The GEO does not have an impact on facility siting decisions directly. State government is not 

involved in a competitive solicitation (put out by Xcel Energy). However, the GEO has a 

program manager dedicated to renewable energy transmission issues.

Colorado's Governor Bill Ritter had made the "new energy economy" a hallmark of his election 

campaign, and his energy office was tasked with carrying out his goals. The state government 

has a vested interest in ensuring that the first CSP project in the state is sited in an appropriate 

manner and goes very well. In discussing the state's role, a stakeholder said that, although GEO's 

role is to facilitate education on CSP, it is thought that the people in the Valley "need to hear 

from the developers exactly how much water, exactly what the build schedule is, exactly how tall 

the troughs are....” Another interviewee said that GEO could be a point of referral for SLV 

groups toward CSP developers to get information from them. The public's position on a CSP 

facility will not be known until someone wins an RFP and proposes to develop a facility in the 

Valley. One stakeholder thought the GEO could become a liaison or representative of the Valley 

in the CSP decision process. 

CSP developers were already purchasing land in the SLV during 2007 and 2008. Several 

stakeholders mentioned a "tremendous land acquisition" that has been occurring in the Valley, 

especially prior to the issuance of the Xcel Energy RFP during January 2009. One interviewee 

said:

There is a very strong political desire on the part of state government to bring in a CSP 

facility to the Valley.

GEO does have a financing role with respect to proof-of-concept renewable energy projects, and 

is the funnel of federal American Reinvestment and Recovery Act (ARRA) funds to projects 

within Colorado.
Interview Findings

60

7.6.2 Clean Energy Development Authority

H.B. 09-1300 authorizes the Clean Energy Development Authority (CEDA), as a Colorado 

transmission authority. The bill was introduced to the legislature in April 2009, sponsored by 

Representatives Solano, McFadyen, and Rice; and Senators Schwartz, Romer, Heath, and Veiga.

Transmission authorities have recently formed in neighboring states as vehicles for transporting 

renewable energy needed to meet state renewable portfolio standards. Legislators in eight states 

have created transmission authorities since 2005, primarily in the West. H.B. 1300 would 

strengthen CEDA so the Authority could finance transmission projects connecting Colorado’s 

renewable energy resources to loan centers.46

Public Service Company of Colorado pushed an unfriendly amendment to the bill to give the 

utilities the right of first refusal (RFR) before CEDA can proceed with financing projects. If the 

amendment passed, the effect could signal the demise of CEDA and future opportunities to its 

financial support for projects that transmit clean energy.

The CEDA board is unanimously opposed to the amendment because:

• Independent transmission developers seeking CEDA financing would not participate 

because they would not want to reveal proprietary development information to utilities.

• A utility RFR could subject CEDA to unnecessary delays.

• A utility RFR could have the effect of an exercise of undue market power control, 

potentially leading to an anti-competitive outcome.

• A utility RFR could lead to an exercise of undue control by a utility over a public body 

composed of individuals appointed by state elected officials.

HB09-1300 provides strike-below amendments to HB07-1150 that created CEDA. The CEDA 

Board said that CEDA should exist because:

• Transmission authorities have recently formed in neighboring states; 

• Legislators in eight states have created transmission authorities since 2005, primarily in 

the West

• CEDA needs to finance transmission projects connecting Colorado’s vast clean energy 

resources; Colorado should strengthen CEDA to accomplish this. 

• The ARRA has opened new opportunities for CEDA.

7.6.3 Water Conservation District

The Water Conservation District has a key role in ensuring that senior water rights are not 

impinged upon by use of surface water to develop a CSP facility.

7.6.4 Local Representatives and Members of Economic Development Groups

Local groups have authority over positions that they will take regarding local CSP development 

and transmission lines in their areas. Sometimes their positions are formalized in permanent 

groups that are set up to advise federal agencies or other organizations in their decision 

 46

http://www.leg.state.co.us.clics.clics2009a/csl.nsf/fsbillcont/DF3A07B67EB2E7FE87257547007928B9?Open&file

=1300_01.pdf
Interview Findings

61

processes, especially where public comment is mandatory. Such groups do exist in the San Luis 

Valley.47

7.6.5 Colorado State Land Board

One of the interviewees indicated that there has been some interest in developing state lands. A 

2007 Colorado statute allows state lands to be used for solar energy facility siting. If CSP 

facility siting or transmission siting were proposed on state lands, the State Land Board (SLB) 

would be involved. The SLB, a branch of the Colorado Department of Natural Resources, 

manages its 3 million acres of land and 4 million acres of mineral rights for the benefit of eight 

trusts. The eight beneficiary trusts are: (1) School lands, (2) Land for public buildings, (3) Land 

for penitentiary, (4) Land for University (University of Colorado), (5) Salt springs — saline 

lands, (6) Internal improvements, (7) Land for agricultural university (Colorado State 

University), and (8) the Hesperus trust (the Fort Lewis grant). The board is charged with 

generating a reasonable and consistent income for its trust beneficiaries and making its decisions 

based on the long-term best interests of the beneficiaries. 

The State Board of Land Commissioners, established in 1876, oversees the stewardship of the 

use of Colorado's land, from agriculture to mineral exploration to general significant revenue for 

its trust beneficiaries through agricultural leases for grazing and crop lands, mineral 

development, and interest earned on invested funds. In recent years, the board has expanded 

efforts to increase revenue through commercial development activities and leasing land for 

recreational purposes. 

The land board is entering leases for State Land Board land. The State Land Board is working 

on a model solar lease contract for land to be used for solar development.48

7.6.6 Colorado Department of Transportation

A significant amount of property is available for different types of utilities and proximity to 

highways. The railroad is often the straightest line and railroad rights-of-way (ROW) can carry 

transmission lines and power poles.

7.6.7 Colorado State Treasurer's Office

This office was mentioned as a key decision-maker, but its role was not stated.

7.6.8 Transmission Planning Groups

A thicket of groups is working on renewable electricity transmission issues. As explained by one 

outside-the-Valley stakeholder:

The Western Governors' Association has a process underway called the Western 

Renewable Energy Zone process, WREZ, and it’s a process to identify transmission 

areas for renewable resources. And then there are numerous other transmission 

groups where transmission planning is actually carried out, such as Colorado LongRange Transmission Planning Group, CLRTPG. There’s a forest of acronyms here. 

 47 For example, the BLM office in the SLV convenes a local citizen group and meets with it regularly. 48 http://trustlands.state.co.us/Pages/SLB.aspx
Interview Findings

62

There is the CREPC, the Committee for Regional Electric Power Coordination, I 

think, you can Google CREPC and get the expansion. There is the TEPPC, 

Transmission Expansion Power Planning Council, and there are many more 

acronyms. 

In a sense, I say this just to kind of illustrate that there are so many things going on 

which really makes true coordination difficult because you have each of these venues 

answering to different facilities and within each of these organizations also you have 

various utilities, you have investor-owned utilities, you have rural cooperatives, you 

have municipals, you have federal power agencies, you have tribes, you have a 

whole gamut of entities, all of whom answer to different regulatory and oversight 

bodies. Investor-owned utilities have to answer to their regulatory commission, the 

co-ops answer to the Tri-State’s board and their members, municipals answer to city 

councils; tribes, of course, have their own governments, and so it makes 

transmission planning very difficult. 

It is a very complicated issue which has to be resolved soon, very soon, because we 

need to get wind energy from Wyoming to Los Angeles, we need to get solar power 

from Arizona to Los Angeles, we need to get...in a nutshell, we have a great need for 

aggressive interstate transmission of renewable power.

7.7 State Legislation

Two Colorado statutes, both enacted in 2007, have particular relevance for the progress of CSP 

development in the SLV: (1) S.B. 07-100 and (2) S.B. 07-091.

7.7.1 S.B. 07-100

This statute, concerning measures to ensure the adequacy of Colorado’s electricity transmission 

requiring utilities to designate energy resource zones, went into law on March 27, 2007. It 

streamlined transmission approvals by basically allowing the investor-owned utilities to site new 

transmission before projects were developed. Previously, transmission lines could not be built 

without a project at the other end. An outside-the-Valley stakeholder said:

 ...Last year...we got legislation to double the RPS and to streamline the transmission 

approvals. That bill number was SB-100, which streamlined transmission approvals 

basically by allowing the utilities—the investor-owned utilities in this case—to site new 

transmission before projects were developed. Previously, the transmission couldn’t be 

built without a project at the other end, but because transmission can take five years or 

more to build, and a new wind project can take one year, a new CSP project can take two 

or three years, compared to the five years or more that transmission takes, it was a chicken 

and egg thing. We just couldn’t get new transmission sited, yet without transmission new 

projects couldn’t be developed. It was a real chicken and egg problem which SB-100 

began to help overcome.
Interview Findings

63

7.7.2 SB 07-091

The bill, enacted into law May 29, 2007, created a task force to identify the state's renewable 

areas.49 An outside stakeholder said that existing transmission in the Valley would be sufficient 

to handle the transmission needs of a 200-MW CSP plant. This stakeholder said:

Yes, but that would pretty much exhaust, as I understand it...and also, again, I would 

refer you to work with GEO and others on Senate Bill 91 and Senate Bill 100 where they 

were looking at resource zones, especially the Senate Bill 91 report. This is the GEO 

which developed a map of the places where there are the best opportunities for 

renewable energy so that people can start planning transmission to reach those areas. 

The San Luis Valley obviously scores as the best central solar in the state and so the 

utility is planning for an upgrade of transmission east out of the valley. Tri-State and 

Public Service Company have talked about joining forces to build a line out. 

Subsequent to the publication of the S.B. 91 report, the GEO issued another report on 

transmission planning,50 called the Renewable Energy Development Infrastructure or REDI 

report. This is the report referred to in the quote. 51 The report shows the planned transmission 

line from the Walsenburg Substation to the proposed Calumet Substation, and then over La Veta 

Pass into the San Luis Valley. The line crosses the Trinchera Ranch, but almost entirely avoids 

Costilla County. Another stakeholder pointed out that there could be federal NEPA requirements 

if a plant were hooked up to a transmission line that crosses federal lands. One stakeholder 

commented that if the PUC did not accept the transmission line proposed by Xcel Energy and 

Tri-State as shown in the REDI report, then the two utilities would have to move the location of 

the lines and deal with the Western Area Power Administration (WAPA) who owns land in the 

vicinity.

An outside stakeholder said that SB 91 has identified 26 GW of undeveloped renewable energy 

in the state. He said:

We should be looking at green electrons as an export commodity from this state, just 

as we do wheat or cattle, etc. To do that, we are going to need some commitments 

for infrastructure for transmission.

Another outside stakeholder described Sections 123's and 124's bearing on CSP development:

The 124 has no bearing on concentrated solar power, but it is often confused because 

to a layman who might ask well why is Xcel Energy installing all of this PV and no 

CSP, the difference is that Xcel does not own nor do they make money in photovoltaic. 

The difference is that rather than utilizing the 2% retail rate impact tax that is 

authorized in section 124 (that is the no more than 2% of our monthly bill could be 

increased to fund the portfolio standard) CSP is not contained within that 2%, nor is 

 49 Colorado Governor’s Energy Office 2008. 50 Colorado Governor’s Energy Office 2009. 51 Colorado Governor’s Energy Office, 2009. The map of the transmission line referred to is on page 27 of the 

report.
Interview Findings

64

the solar carve-out at all related to concentrating solar power, so the solar carve-out is 

for photovoltaic. That’s 4%. 

Interviewer: 4% is what?

Stakeholder: 4% is approximately . . . 90 . . . MW by 2020. It is important to 

understand the structure of 123 versus 124 if you are really to understand how CSP 

might happen from a statutory and regulatory standpoint in the San Luis Valley. . . .

...One of the things... [to] look into is the property taxation structures for large solar 

plants. Currently they are taxed upon the market value of the system. They are taxed 

upon the value per rated megawatt of the system. What Senator Schwartz has looked 

into is what if that property taxation rate was changed to be a commodity basis, similar 

to the way agricultural land is taxed; for example, the productivity of the land, you get 

so many bushels, for example. Essentially what she has investigated is taxation, and in 

fact there has been a bill on this, Senate Bill 177, that modifies the taxation structure 

for large-scale solar systems. It actually starts the property taxation lower than they 

currently are in the earlier years, but the amount of property tax generated would go 

up over time as their value of that commodity goes up. So as the megawatt hour 

becomes more valuable at the time, that megawatt hour is taxable from a property tax 

basis. 

Interviewer: So that would affect the county.

Stakeholder: Right. Exactly. More importantly, it brings a greater guarantee of longterm revenue to the county whereas the current taxation structure is continuously 

decreasing based on the value of the system. These systems are taking advantage of 

accelerated depreciation so they are depreciating very quickly. I think that is a very 

important piece that Senator Schwartz has hit on. It is unclear what the impact would 

be to a developer.
65

Part Two: The SLV Transmission Controversy
66 

 8 The SLV Transmission Controversy 

8.1 Introduction

This section of the report briefly addresses the transmission controversy that erupted in the 

spring of 2009 after the stakeholder interviews reported in Part One were completed. The debate 

was fueled by the Xcel Energy and Tri-State Generation & Transmission Company (Tri-State) 

filing in May 2009 for a CPCN to build a 230-kV transmission line between Walsenburg and 

Fort Garland over LaVeta Pass, a distance of 95 miles. The rationale for building the line was to 

carry out federal and state policies fostering the development of large-scale renewable energy 

technologies by bringing transmission capabilities to resource-rich areas like the SLV. 

Significant policy development at the federal and state levels had laid the groundwork for a 

transmission line proposal. Federal policy developments described in this report's Introduction 

and Background are mentioned and relevant developments in Colorado policy are summarized. 

The positions of Xcel Energy and Tri-State and of the opponents to the transmission line are 

summarized.

8.2 Policy Context

Federal and state policies favor utility-scale solar development. 

Summary

Within a federal and state policy context broadly supportive of utilityscale solar development, in May 2009, Xcel Energy and Tri-State 

Generation and Transmission Company jointly filed for a Certificate 

of Public Convenience and Necessity (CPCN) to build a 95-mile highvoltage transmission line between Walsenburg and Fort Garland, 

Colorado. This action sparked a public policy debate over preserving 

the Valley's scenic and wildlife resources versus the need to transport 

renewable electricity to the Front Range and to increase power 

reliability in the Valley. The dispute over the proposed placement of 

the SLV-Calumet-Comanche line, planned to be operational by May 

2013, illustrates some of the difficulties and challenges facing largescale renewable power development in rural and scenic areas in the 

United States. The CPCN filing was met with immediate legal 

opposition from Valley stakeholders—notably the Trinchera Ranch, a 

privately held wildlife conservation and hunting preserve. Other 

Valley stakeholders testified for and against the transmission line at 

public hearings held in the area. In Denver, the PUC conducted formal 

hearings on the CPCN docket, and a decision is expected toward the 

end of April 2010. The losing side will likely appeal the decision. 
67

8.2.1 Federal Policy

As noted earlier, Congress has passed legislation and the federal government has adopted strong 

renewable-energy development policies. Among these are the following federal policy actions. 

8.2.1.1 BLM Policy Memorandum

On April 4, 2007, the then Acting Director of BLM James M. Hughes issued an instruction 

memorandum on Solar Energy Development Policy, citing the National Energy Policy Act of 

2001 and the Energy Policy Act of 2005 (P.L. 109-58, August 8, 2005). These statutes 

encouraged the development of renewable energy resources including solar energy. Specifically, 

Section 211 of the 2005 EPAct encourages the approval of at least 10,000 MW of nonhydropower renewable energy projects on the public lands within the next 10 years.

8.2.1.2 BLM-DOE PEIS

As noted earlier, BLM and DOE have joined forces to develop a PEIS to aid in streamlining 

permitting processes for large-scale solar projects on the public lands. The SLV has huge areas 

of public lands (nearly 3 million acres), and four areas of the Valley have been federally 

designated as official solar energy study areas.

8.2.1.3 Investment Tax Credit (ITC)

As noted earlier, in 2008 the federal ITC for solar development was expanded to include utilities 

and extended to 2016. This provides a key financial incentive for large-scale solar development 

by helping to reduce their cost.

8.2.1.4 DOE Report to Congress

As described earlier, the DOE reported to Congress in 2007 that the solar resource and available 

suitable land could support generation of up to 6,800 GW of electricity. Based on geographic 

information system (GIS) and solar resource analysis conducted by NREL, the SLV has been 

identified as a prime national solar resource.

8.2.2 Colorado Policy

In 2004, Colorado voters passed Amendment 37 to the Colorado Revised Statutes, calling for a 

renewable energy portfolio standard (RPS) of 3% beginning in 2007, and incrementing to 6% in 

2011, and then 10% in 2015 and beyond.52 The renewable requirement included a “solar setaside” stating that at least 4% of the renewable generation in each year must come from solar 

resources. Xcel Energy met the first RPS 8 years ahead of schedule.

In 2006, then-candidate for Governor Bill Ritter campaigned on a "new energy economy" as one 

of his three key policy themes. Once elected, the governor established an energy office—the 

Governor's Energy Office (GEO)—to carry out his energy agenda. In 2007, Governor Ritter 

signed into law House Bill 1281 that doubled the RPS requirement (to 20% in 2020) and on 

March 22, 2010, the governor signed into law H.B. 10-1001 increasing the RPS requirement to 

30% by 2020.

 52 The requirement applies to utilities serving 40,000 or more customers; and utilities may hold an election of their 

customers to be included or exempted from the requirement.
68

In December 2009, the GEO released the REDI Report calling for actions to meet a benchmark 

goal for meeting Colorado's RPS and reducing carbon dioxide emissions in Colorado by 20% by 

2020.53 In summary, the report's major recommendations for action included the following.54

• Greatly increase investment in demand-side resource (energy efficiency, demand-side 

management, demand response, and conservation)

• Greatly increase investment in renewable energy development, particularly utility-scale wind 

and solar generation.

• Accelerate construction of high-voltage electric power transmission to deliver renewable 

energy from Colorado's renewable resource generation development areas to the state's major 

load centers.

• Strategically use natural gas-fired power generation to provide needed new power to the grid 

and to integrate naturally variable renewable resources.

• Consider decreasing the utilization factor of coal-fired generation and/or consider early 

retirement of the oldest and least efficient of the state's coal-fired generation stations.

The report noted that "delays associated with siting and permitting of transmission lines will 

hamper Colorado's utility-scale renewable energy development unless modifications are made to 

the process."55 Indeed, the report appears to advocate a state-level transmission permitting 

framework to make local-area transmission siting decisions, citing a 2009 Memorandum of 

Understanding (MOU) between the WGA, the DOI (Interior), the USDA (Agriculture), and DOE 

(Energy). This MOU creates assistance to the WGA's Wildlife Council, working with member 

states, to create state-based decision support systems for such siting decisions. The effort will 

support development of “effective land uses" while providing "healthy and productive 

landscapes."56 The purpose of the MOU is to “help the renewable energy industry reach its 

goals” while also “preserving prairie and mountain ecosystems” in Colorado.

8.3 The Current Situation

Although the ambitious goals of the Colorado RPS could be met partially by distributed 

(customer-owned) generation, it is widely (but not unanimously) agreed that larger-scale solar 

and wind projects in Colorado’s rural areas will need to be built as well (to meet the higher 

RPS). 

The REDI Report focuses on how Colorado can “most effectively address the challenge of 

building new high-voltage transmission lines to deliver utility-scale renewable power from

Colorado’s rich renewable resource generation areas to the market”.57

 53 Colorado Governor’s Energy Office 2009 (REDI Report).

What the Valley lacks is 

adequate transmission infrastructure to bring that resource to market. Local opponents in the 

SLV argue that building huge solar arrays and massive power lines to export renewable energy 

would diminish other environmental values innate to the area. They argue, moreover, that 

approving and constructing large transmission lines before the generation capacity has been put 

under contract is imprudent, calling it the “field of dreams” approach. The GEO and the utilities 

54 Quoted verbatim from page 7 of the REDI report. 55 Ibid, p. 8. 56 Ibid, p. 85. 57 Ibid, p. 6.
69 

argue that lack of adequate transmission access is hindering renewable energy project developers 

from building projects in Colorado and that ”if you build it, they will come.”

Tri-State's customers in the Valley are served by only one transmission line (Tri-State has 

roughly a 100-MW load in the Valley; Xcel Energy has a 25-MW load in the Valley). For TriState, the primary purpose is to solve a critical need to improve the electric service to the Valley 

and more reliably serve their SLV customers. Currently, if a single outage event were to occur on 

the existing Poncha–San Luis Valley (230-kV) transmission line, the remaining system would 

not be able to supply enough power to meet the peak loads in the area. These include agricultural 

water-pumping loads, which are critical for growing crops.

Xcel Energy and Tri-State jointly filed for a Certificate of Public Convenience and Necessity 

(CPCN), seeking permission to build the proposed power lines (and new Calumet substation near 

Walsenburg). This application opened a Docket before the Colorado PUC in which the merits 

and shortcomings of the proposed transmission assets, and the routes of the transmission lines, 

were disputed before the Commission.58 Table B-1 in Appendix B highlights the major 

regulatory events and project milestones. Thus far, there have been four rounds of testimony 

filed before the Colorado PUC. A final decision, likely to be appealed, s expected by the end of

April 2010.

wa

The proposed line would require a 150-foot wide corridor and latticed towers up to 120-feet

high. It would cross La Veta Pass traversing pristine valleys and mountains as it passes by Great 

Sand Dunes National Park, crossing as well areas designated as prime areas for wind and solar 

power development. The exact route has not been selected, and does not have to be selected for 

the CPCN to be granted. If the utilities get the CPCN, they can, if they must, legally condemn 

private lands to build the lines.

In their application for the CPCN, Xcel Energy and Tri-State requested a determination of 

permissible noise levels for electric transmission facilities “notwithstanding the maximum 

permissible noise levels established [elsewhere in law]”.59 The utilities want this threshold

defined by the Commission in order to avoid civil action claims in the future.

A partnership by Xcel Energy and Tri-State Generation to build the (estimated) $180 million 

project to export solar energy (to Colorado load centers) and increase reliable electricity (in the 

Valley and in south-central Colorado) is supported by a number of stakeholders around the state, 

particularly proponents of renewable energy, the Governor’s Energy Office, and the renewable 

energy industry, but faces opposition from a number of opponents as well, including a wealthy, 

local landowner and some environmental organizations based in the Valley.

The landowner, fearful of the visual impact the line would cause as it crosses his 171,000-acre 

Trinchera Ranch, has proposed an alternate plan that would upgrade existing power lines and add 

a new proposed high-power line over Poncha Pass. A federally designated corridor already exists 

at Poncha Pass for future energy lines, connecting to Cañon City. All of the existing transmission 

 

58 Colorado PUC Combined Docket #08E324 and 325

59 Ibid., page 15
70

lines—one 115-kV line and two 230 kV-lines—come over Poncha Pass. According to the 

utilities, for truly reliable service, all transmission resources connecting the Valley to the Front 

Range should not be routed through the same corridor. The utilities argue that the proposed 

alternative is not acceptable because it fails to create the type of redundancy that utilities strive 

for in most transmission applications. One large forest fire or winter storm could take out the 

Poncha Pass lines and leave the valley without electricity.

8.4 Xcel Energy and Tri-State Perspectives

Xcel Energy and Tri-State G&T intend to co-own the proposed transmission assets, although 

they expressed different reasons for needing them.60 Xcel Energy (also known as Public Service 

Company of Colorado) proposed the line to stimulate the development of large-scale solar 

energy (both concentrated PV and solar-thermal plants) in the SLV, also referred to as Energy 

Resource Zone (ERZ) 4. In his testimony filed before the PUC, Gerald Stellern, manager of 

transmission assessment management at Xcel Energy, wrote that “the Project meets the SB-100 

criteria to alleviate transmission constraints to ERZs 4 and 5, and it will allow generation 

resource additions to meet Public Service’s (renewable energy) needs... and can accommodate 

approximately 1,500 MW of new generation.”61 

Xcel Energy pushed an amendment to the bill in June 2009 that would give the utilities the right 

of first refusal (RFR) before CEDA could proceed with financing projects. The CEDA Board is 

unanimously opposed to this amendment. If the amendment passed, the effect could signal the 

demise of CEDA and future opportunities for its financial support for projects that transmit clean 

energy. The CEDA Board is opposed to the amendment because:

• Independent transmission developers seeking CEDA financing would not participate because 

they would not want to reveal proprietary development information to utilities.

• A utility RFR could subject CEDA to unnecessary delays.

• A utility RFR could have the effect of an exercise of undue market power control, potentially 

leading to an anti-competitive outcome. 

• A utility RFR could lead to an exercise of undue control by a utility over a public body 

composed of individuals appointed by state elected officials.

S.B. 100 drove the process of identifying ERZs around the state and potential transmission lines 

that would need to be built. Regarding public outreach associated with S.B. 100, Stellern stated 

that “Public Service has held numerous meetings, workshops, and technical sessions to plan the 

S.B. 100 projects by communicating the information to all stakeholders. The result of that work 

was five Energy Resource Zones and eight projects that were presented to the Commission in 

November 2008 in an information filing.”62

 60 Tri-State and Public Service have agreed to an MOU specifying the allocation of ownership, costs, capacity rights, 

and maintenance agreements for each segment. For example, Public Service will have 60% of the capacity rights in 

the new San Luis Valley–Calumet segment, and will bear 60% of the costs. 61 Direct Testimony and Exhibits of Gerald M. Stellern, Xcel Energy. October 28, 2009. 62 Ibid, page 11.
71

In its rebuttal testimony, Xcel Energy responded to some of the arguments presented by other 

stakeholders before the PUC.63 Karen Hyde explained that Xcel Energy cannot agree with 

Western Resource Advocates’ (WRA) position that the proposed project can “provide access 

only to renewable resources.” She also discussed why the positions held by the interveners for 

Trinchera Ranch, that the transmission lines “should only be built to accommodate generation 

under contract [in the Valley]... are short-sighted, imprudent, and unlikely to meet Public 

Service’s solar resource plans over the next several years.” Xcel Energy argued that alternative 

plans and routes proposed by Trinchera Ranch do not look out far enough into the future. “The 

potential solar resources in the San Luis Valley are in the thousands of megawatts, not hundreds. 

Artificially limiting transmission to the bare minimum necessary to connect resources that result 

(only) from the 2007 Resource Planning Docket would not be wise.”64

She explained why the transmission lines have to be built ahead of the generation market—that 

is, before firm commitments to develop solar energy in the Valley are under contract. “The 

availability of transmission capacity is watched carefully by bidders; they will look to develop 

projects in areas where it is likely that they will have an economic advantage over bidders in 

other areas.” 

Xcel Energy also disagreed with a study done by engineers hired by Trinchera Ranch that 

describe alternative routes through Poncha Pass, thus avoiding the Ranch. "We believe that the 

proposed southern transmission route makes the best sense from reliability and quite frankly a 

common-sense standpoint," said Xcel Energy spokesman Mark Stutz.65 A new Poncha Pass line 

would require an extra 60 to 70 miles of line at about $1 million a mile.

Tri-State, which provides electricity to rural electric cooperatives, including the SLV REC, has 

asked the federal government to secure financing for the transmission line. This request triggered 

prescriptive public proceedings in the local area. The Rural Utilities Service (RUS) decided that 

Tri-State must complete a more complex environmental impact statement rather than a simpler 

environment assessment on the impact of the proposed project transmission line on the 

environment.

“The project sponsors announced that the Rural Utilities Service will require an environmental 

impact statement, a more exhaustive level of review than the utilities planned for. The Rural 

Utilities Service is the federal agency that funds rural utility projects and is considering loaning 

$82.3 million for this project.”66

8.5 Trinchera Ranch Perspective

The Trinchera Ranch in the San Luis Valley changed hands in 2007 from Steve Forbes to 

billionaire hedge-fund manager Louis Moore Bacon. Forbes said he had sold the 171,000-acre 

ranch near Fort Garland to Bacon because Bacon had a solid conservation record and could be 

trusted to preserve the ranch. The Pueblo Chieftain said Bacon paid $175 million for the ranch, 

 63 Rebuttal Testimony and Exhibits, Karen Hyde, Xcel Energy, December 2, 2009. 64 Ibid. page 7. 65 The Denver Post. 66 “Power line project spurs fight over route in southern Colorado,” The Gazette, R. Scott Rappold, Nov. 7, 2009.
72

which has views of 14,000-foot-high peaks—one of the highest prices ever paid for a ranch. The 

Forbes family had held the ranch, 160 miles south of Denver, for four decades.67

Bacon had set up the Moore Charitable Foundation in 1992 to aid nonprofit groups that focus 

primarily on conservation and the protection of natural resources.68 "Louis Bacon has 

passionately devoted much of his life and resources to the protection of extraordinary 

properties," Forbes said. "By finding such a committed owner, we are certain Trinchera will 

thrive and be enjoyed, as it is, for years to come." A spokesman for Bacon called the ranch an 

extraordinary property for its scenic grandeur and unspoiled natural habitat. 

Bacon strongly opposes the proposed power line and has hired lawyers, engineers, and an 

independent transmission analyst to fight it. The Ranch filed testimony and developed a report 

proposing alternatives to the currently proposed La Veta Pass route, which crosses the ranch.

Among the proposed alternatives are:

• Upgrade existing lines and a transformer

• Add 150-MW of solar energy with power storage to reliably service the Valley

• Add a 230-kV line north over Poncha Pass.

"All these alternatives meet the reliability need, allow for getting solar out of the Valley and are 

less expensive than the proposed line," said Cody Wertz, a spokesman for Trinchera Ranch. 

"Xcel and Tri-State have not shown there is a demonstrable (reliability) risk over Poncha Pass," 

Wertz said.69

In his testimony before the PUC on behalf of Trinchera Ranch and Blanca Holdings, Michael 

McFadden argued that “lower cost alternatives will accomplish the same goals as the facilities 

proposed by the Company.”70 Moreover, he argued that “there are no commitments or 

assurances that generation capacity sufficient to justify the proposed transmission facilities will 

be constructed and connected to the system. Without these assurances, these facilities cannot be 

considered used and useful.” He concludes his argument by suggesting that the PUC should 

“place the risk of failing to attract sufficient generation on the shareholders, not the customers.”71

8.6 Local Environmental Perspectives

The Colorado PUC held public hearings in the area (on Nov. 9, 2009, in Walsenburg, and Nov. 

10, 2009, in Alamosa) to receive public commentary from local stakeholders. Two SLV 

groups—the San Luis Valley Ecosystem Council and Colorado Open Lands—offered pertinent 

comments opposing the proposed lines. 

 67 CBS, Denver, http://cbs4denver.com/business/forbes.ranch.colorado.2.597781.html 68 Ibid. 69 Proposed transmission line for San Luis Valley sparks debate,” Mark Jaffe, The Denver Post, October 30, 2009 70 Answer Testimony of Michael McFadden, On Behalf of Blanca Ranch Holdings, Colorado PUC, December 2, 

2009

71 Ibid. 
73

The San Luis Valley Ecosystem Council strongly criticized the proposed line. Its comments 

emphasized the benefits of distributed generation and the environmental impacts transmission 

lines and new bulk-power generation facilities would likely have on local ecosystems:

Study after study concludes that distributed, or small-scale, rather than concentrated or 

industrial-scale, generation projects are more cost effective, more efficient and much 

quicker to bring online. Studies also show that small-scale projects provide long-term 

financial benefits to local communities through sustainable jobs, robust returns on 

investment for local businesses and homeowners, and reduced carbon footprints. 

Furthermore, energy that is produced in the place where it is used is much more efficient 

since it eliminates transmission losses and large-scale production inefficiencies. Without 

question, distributed generation projects have dramatically less impact on the 

environment.72

The council believes that system reliability and voltage loads would best be served by creating a 

locally generated source of electrical power supply and transmission.

We already have the existing infrastructure through our 30 odd sub-stations and center 

pivot corners (for example). It could come online more quickly than a transmission line 

and be much more cost-effective for consumers. This self-sustaining alternative deserves 

to be given thorough analysis.

Several important historic resources are located within the proposed transmission corridor plans. 

These include the Sangre de Cristo National Heritage Area and the Los Caminos Antiguos 

Scenic By-way. Because of these two special designations, the council believed that it is 

important to preserve the visual landscape and that the transmission line would diminish the 

historic integrity of the area.73 Moreover, Mt. Blanca is considered one of four mountain peaks in 

the Four Corners area to be sacred among various tribes who inhabited and traded in this area. 

The council argues that tribes should be consulted as an integral part of this public process. 

According to the council, habitat fragmentation; threatened, endangered and sensitive species 

habitat; as well as critical cores and linkages for wildlife habitat will be impacted by the 

proposed transmission line. Wildlife habitat fragmentation caused by transmission lines 

(including branch power-lines), pipelines (including feeder pipelines) and roads occur both 

during and after construction. As such, wildlife habitat must be examined on an individual 

project and site-specific basis. The only way to accomplish this requirement is to ensure that the 

transmission corridor is spatially evaluated for direct, indirect, and cumulative impacts.

Proponents and opponents alike spoke at PUC public hearing on November 9th (Walsenberg) and 

10th (Alamosa). Considerable concern was expressed that large central-station solar power 

facilities would consume precious Valley water. Residents suggested the power lines be buried, 

 72 Testimony filed to the Colorado PUC by Christine Canaly, Director, The San Luis Valley Ecosystem Council , 

November 10, 2009.

73 Areas in the National Landscape Conservation System including National Heritage Areas are governed by other 

laws requiring protection as a priority to protect objects of historic or scientific interest, and must be managed to 

protect those values as a priority over other uses.
74

but the utilities said that would increase the cost ten-fold. Adding to residents’ consternation, 

they learned that the utilities could use eminent domain to seize rights-of-way from property 

owners unwilling to sell.

The utilities issued a “route refinement,” eliminating the route through the rural La Veta Acres 

subdivision 10 miles west of La Veta, instead proposing to run the lines far to the north. The 

announcement of the route change “shocked and delighted opponents,” including Public Outcry 

Over Stealing Scenic Excellence, a still-forming group of about 60 residents who had planned to 

urge the utilities to adopt a different route.74

In criticizing the transmission plan, residents claimed they were not notified about the August 

2009 public hearing. They claimed that nearly 40 homes and historic buildings were omitted 

from the initial survey for the line. Tri-State acknowledged that there were problems with maps 

the utilities used to identify the originally proposed routes. “There were instances where there 

could have been properties and structures that were not appearing on the maps we used,” Jones 

said. The new proposed route would not add to the cost of the project, nor would it impact any 

residential areas as dense as La Veta Acres, he said.75

8.7 Western Resource Advocates Perspective

Western Resource Advocates, an environmental law firm with a history of intervening before the 

Colorado PUC, filed testimony in support of the line, but with a few conditions to ensure that the 

lines only serve renewable energy projects and that environmental impacts are limited.

In WRA’s Surrebuttal,76 Tom Darin commented that “the importance of WRA’s proposed 

conditions on each CPCN,” and responded to the applicants’ comments and objections with 

regard to the proposed conditions for each CPCN. The issues fell into three primary categories: 

(1) demand-side management (DSM) and distributed generation (DG); (2) the use of the 

proposed transmission lines to facilitate the development and delivery of renewable energy, as 

described in the applications; and (3) the responsible mitigation of visual impacts, and the 

importance of early consideration and planning that is necessary to be sure that visual impacts 

are properly incorporated into transmission siting and design.”

Mr. Darin wrote that the utilities’ objections to WRA’s proposed conditions generally fell into 

these five categories:

1. DSM, DG, and environmental concerns, such as visual impacts, are not relevant in a CPCN 

proceeding.

2. Reporting on DSM and DG is either redundant or over-burdensome, and the commission’s

interest in such information would be beyond its jurisdiction as it relates to Tri-State.

3. Applying a rebuttable presumption to future generation facility CPCN applications before the 

commission would frustrate FERC’s open access requirements.

4. Requiring a percentage of the proposed transmission line’s capacity to be committed to

 74 Ibid. 75 Ibid. 76 Surrebuttal Testimony submitted by Tom Darin on Behalf of WRA, January 10, 2010, before the Colorado PUC.
75

renewable energy prior to commencing construction of the proposed facilities might pose 

implementation challenges based on Xcel Energy’s experience relative to a similar condition 

in a CPCN hearing in Minnesota.

5. WRA seemed to single out visual impact as a key area for mitigation.

8.8 Perspectives of the Colorado Division of Wildlife and Colorado Open Lands

The conservation group Colorado Open Lands and the Colorado Division of Wildlife (CDOW) 

voiced concerns about the impact a transmission line could have on scenic and wildlife 

resources. The 140-mile line would have "a negative impact on the land and resources," Daniel 

Pike, president of Colorado Open Lands, said in his testimony.77

The CDOW also commented on the potential environmental impacts of each segment of the 

proposed lines. Identifying the best corridors is “probably the most important factor for 

CDOW.”78 Southwest Regional Manager Thomas Spezze wrote that from Walsenburg to La 

Veta Pass, “our preference is for corridor segments C, E, G, and H because they have the fewest 

additional impacts. This route uses an existing right-of-way where large transmission lines 

already exist” (to minimize the impacts on elk, deer, and antelope winter ranges).79

Avian concerns were a much more pressing issue to the CDOW. “There are numerous migratory 

birds that use what is considered a triangle of very important wetlands, grain fields, and roosting 

areas to the north, south, and east of the proposed corridors.” Also, during the spring and fall of 

every year, thousands of Sandhill Cranes will use these areas for feeding and roosting. Pelicans 

will also migrate between the San Luis Lakes, the Alamosa Wildlife Refuge, Smith Reservoir.”

To avoid avian transmission line collisions, “we recommend marking all lines, especially the top 

wire, throughout the entire project. CDOW recommends that Tri-State install Yellow Swan 

Flight Diverters on overhead static wires. It is possible to stagger Swan Flight Diverters to 

minimize the number of devices required and cost.”

CDOW’s primary concern regarding aquatic species “is to protect riparian habitat along all 

streams, reduce erosion and sedimentation by minimizing stream crossings, and protect Rio 

Grande cutthroat waters.”80 In all corridors, CDOW “recommends riparian habitat protection to 

minimize sedimentation and erosion by providing a minimum of a 50-foot no disturbance buffer 

zone on each side of the stream, and avoiding surface disturbance within 300 feet of the riparian 

zone to the maximum extent practicable.”81

8.9 County Government Perspectives

The proposed transmission corridors go through Alamosa, Costilla, and Huerfano Counties. 

Some county commissioners were favorable. In testimony at a local PUC hearing, 

commissioners for each affected county supported building the transmission line.

 77 Proposed transmission line for San Luis Valley sparks debate,” Mark Jaffe, The Denver Post, October 30, 2009. 78 Letter submitted Aug., 12, 2008, to Nicole Korbe, Senior Environmental Planner, Re: Tri-State 230-kilovolt 

Transmission Line Project Proposal (Walsenburg to San Luis Valley Sub-station), by Thomas Spezze, Southwest 

Region Manager, CDOW 79 Ibid. 80 Ibid. The Rio Grande Cutthroat Trout is a candidate species under the Endangered Species Act. And a “Colorado 

species of special concern.” 81 Ibid.
76

"We are in favor of the transmission line and more solar energy in the valley," San Luis County 

Commissioner Darius Allen said.82 The line was expected to ensure electricity supplies to power 

the 3,000 sprinklers used by Valley farms. "If we have the power interrupted, it would be 

devastating," Allen said. Rio Grande County Commissioner Doug Davie said that losing power 

on a 120-acre sprinkler could curb a potato yield by seven sacks an acre per day, worth about 

$5,400.83

County commissioners clearly anticipate financial benefits. Unless WGA recommendations are 

adopted, the utilities will be paying property taxes to the counties for relevant portions of the 

lines. In addition, jobs could be created if personnel are hired to maintain the line. 

 82 “Counties support new power line for San Luis Valley,” The Denver Post, Mark Jaffe, Nov. 11, 2009. 83 Ibid.
77

Part Three: Discussion, Conclusions, and 

Recommendations
78

9 Discussion, Conclusions, and Recommendations

U.S. public policy fosters increasingly widespread use of renewable energy. The purpose of a 

stakeholder analysis is to gain understanding of the ways in which stakeholders perceive 

renewable energy technology (in this case, CSP) and how it can best be used. Do they understand 

it? What is the expertise that local stakeholders can bring to Colorado energy decision-making 

processes? The point of the analysis is to provide information that helps to improve the process 

of renewable energy siting in Colorado.

The research stance taken in this study is one of neutrality in what has become a conflicted 

community. The range of opinions about the positives and negatives of CSP development in the 

SLV was identified qualitatively. The purpose is to describe the perceptions among stakeholders

within and outside the Valley, and to hold up a mirror on the viewpoints contained within the 

decision process. Most of the key issues are likely represented in these report’s findings. 

Better ways to site renewable energy transmission lines are needed. Other renewable resource 

transmission controversies are occurring elsewhere in the country, one in southern California. 

"Facing enormous costs and fierce opposition from environmental groups, the Los Angeles 

Department of Water and Power (DWP) announced on March 10, 2010, that it had dropped plans 

to build an 85-mile-long ‘green’ power transmission line across desert wilderness preserves and 

scenic ridgelines. The announcement reflected a shift in policy toward developing renewable 

resources closer to the DWP's existing power corridors. The DWP submitted a right-of-way 

grant application to the U.S. Forest Service in 2007 for the project, designed to bring electricity 

generated by solar, geothermal, wind and nuclear power to Los Angeles from the southeastern 

California deserts and Arizona. Environmental and community groups were outraged by the 

DWP's plans to route high-voltage lines and 16-story towers through the Big Morongo Canyon 

Preserve north of Palm Springs, Pioneertown near Yucca Valley, Pipes Canyon Wilderness 

Preserve and a corner of the San Bernardino National Forest before linking with existing DWP 

power lines in Hesperia."

84

This part of the report provides summary review of how the Valley situation developed, answers 

the research questions raised by the Research Advisory Committee identified in the report’s 

Introduction and Background, discusses policy actions proposed by solar advocates in light of 

the study’s findings, presents broad conclusions, and recommends state policy and research 

actions.

9.1 Summary Review

The early signs of opposition to the transmission were already evident in October 2008 and 

probably sooner. The opponents made no secret of their concerns, stating in public meetings that 

although they favored distributed solar development, they opposed a second transmission line 

into the Valley over La Veta Pass. They raised a number of concerns publicly, including the 

industrialization of the Valley, the large amount of land required, and the water needed for a 

large-scale solar facility. Other stakeholders within the Valley were aware of these opponents 

 84 ”DWP drops plan to build 85-mile power transmission line across the desert.” 2010. Louis Sahagun, Los Angeles 

Times, March 11. 
79

and their concerns. Stakeholders from outside the Valley who had visited and attended meetings 

there were also aware of these individuals and groups and the nature of their concerns.

Nevertheless, the responsibility for attending to local concerns apparently rested with the private 

independent power producers (IPPs) who were submitting bids to Xcel Energy to produce 

renewable electricity. As part of their bids, these developers were expected to vouch for the fact 

that they could deliver the electricity to the utility's transmission lines. This meant that they had 

obtained, or expected to obtain, local permits to site their facilities.

The Xcel Energy RFP for bids for solar power went out as a direct consequence of Colorado's 

renewable portfolio standard (RPS) that resulted from the passage of citizen-initiated 

Amendment 37 and subsequent state legislation. The latest RPS legislation (H.B. 10-1001, 

March 2010) mandates that 30% of retail electricity produced by investor-owned utilities must 

come from renewable resources. A minimum of 1.5% must be from onsite generation and 28.5% 

from utility-scale projects. 

Although those in control of the bureaucratic process and the IPPs may have understood the 

relevant legal actions they had to take for their desired outcomes, many local stakeholders—

whose neighborhoods would be impacted—were confused about those decision processes and 

were sometimes frightened by unknown technology, economic risks, and outside organizations 

with the clout to seriously affect them. Typically, they did not have the expertise (nor necessarily 

the wherewithal to purchase it) that could provide them with third-party technical advice on the 

potential economic, environmental, water, land, societal, and other impacts of such 

developments, but had to rely on the testimony of those organizations responsible for, and 

seemingly wedded to, CSP development.

The process took on an adversarial tone when Xcel Energy and Tri-State filed for a Certificate of 

Public Convenience and Necessity (CPCN) with the Colorado Public Utilities Commission to 

build the San Luis Valley-Calumet-Comanche transmission line over La Veta Pass. As was 

summarized in Part Two, lawyers represented both sides of this issue. Although organizations 

provided public briefings on their plans and posted information and maps on the Web, no one 

appeared to have legal responsibility for educating the citizenry or mitigating potential adverse 

environmental or societal impacts.

9.2 Research Questions and Answers

As described in the Introduction to this report, the study’s Research Advisory Committee asked 

several key research questions. These questions are answered below with brief summaries of 

findings from the study. 

• What is the level of awareness and knowledge of key SLV stakeholders?

The need for education was a familiar theme in the interviews. Many of the stakeholders 

believed that the local community should be educated so that they understand more about 

why CSP development is necessary; how it contributes to the goals of the federal and state 

policy communities; how it helps the environment; how the Valley needs more electricity; 

why its electricity supply is vulnerable; why distributed solar PV cannot provide all of that 
80

electricity and security; what the impacts would be on their communities, landscape, and 

water; and what benefits—especially economic benefits—the Valley populace would enjoy 

as a result of the development. 

• What is the level of community support and opposition?

There is a high level of support in the Valley for renewable energy development. Many 

Valley stakeholders appear to favor solar development. The Valley's lengthy history of 

grassroots activism and support for passive solar buildings, solar thermal, and PV seems to 

inform this solar consciousness. Added to that is the successful integration of the 8.2-MW 

Sun Edison PV plant sited near the town of Mosca. However, some stakeholders believed 

that most SLV residents do not understand CSP. Those characterized as supportive included 

the county commissioners, farmers with land to sell, those working on economic

development in the Valley, the college, and those concerned about workforce opportunities. 

Those opposed were (accurately or not) identified as water interests, environmental groups, 

the Trinchera Ranch, residents of Crestone (a Valley community near the Sand Dunes 

National Park and Preserve), the rural electric cooperative, and Spanish land-grant families in 

Alamosa and San Luis.

The perceived benefits of CSP development can be classified into five categories as follows.

(1) Economic benefits (potential improvements in the SLV economy, job creation, provision 

of tax benefits to local counties, trapping dollars in Colorado's economy)

(2) Environmental benefits (puts lands and solar resources to best use, reduces greenhouse 

gas emissions; addresses climate change, helps "save the planet," is "clean energy")

(3) Technological benefits (improves security and diversity of power supplies, reduces 

dependence on imported energy, provides dispatchable energy)

(4) Social-psychological benefits (solar development can become a source of pride, 

positively affects the community identity)

(5) Policy benefits (the community wants RPSs to be met).

Some differences between the perspectives of stakeholders within the Valley and those 

outside the Valley were observed. The responses of inside-the-Valley stakeholders gave 

greater emphasis to environmental and social-psychological benefits, whereas outside-theValley responses emphasized technological benefits (especially energy storage). Both groups 

emphasized the economic advantages, but inside-the-Valley responses focused more on the 

concern about the potential for a boom-bust cycle than did outsiders.

• What are the key water, land, and other issues?

Following is a summary of the concerns expressed in the interviews.
81

- Environmental concerns (the need for water for CSP development; land-use intensity)

- Economic concerns (concern that the Valley benefit economically, concern that a boombust cycle might occur from the CSP plant construction and that permanent jobs would be 

minimal)

- Technological concerns (concern that transmission would be needed to export CSP 

power; the technical efficacy of CSP was still in question; the intermittency of solar power 

was also a concern)

- Social-psychological concerns (concern that CSP is difficult to conceptualize; that it is 

difficult for the Valley people to deal with Xcel Energy)

- Policy and regulatory concerns (need for environmental impact statements; concern that 

regulation has not caught up with CSP development; lack of effectiveness of the 30% 

investment tax credit).

Local opposition to the San Luis Valley-Calumet-Comanche transmission line has organized 

and is waging a campaign to get the line stopped. The organized opposition, led by a local 

environmental group, is in contact with opposition groups in other parts of the country to 

share information and strategies on bringing proposed transmission projects to a halt.

• Should there be local ownership of a CSP facility or should it be owned by CSP developers? 

What is the appropriate role of the local players?

The answer depends on the perspective of the stakeholders. The SLV Resource Development 

Group believes that the local San Luis Valley Power Authority should own a CSP facility. 

The CSP developers believe that a CSP facility is too large, complex, and expensive to be 

locally owned. Local actors play key roles in ensuring local benefits and identifying negative 

impacts that must be mitigated. Generally speaking, the stakeholders outside the Valley want 

private ownership. Although some stakeholders support no export of power, others favor the 

revenues such exports would bring. The researcher's view is that the local players should 

have actual decision authority over the siting of CSP facilities on private lands. The part that 

distributed generation can play in providing electricity self-sufficiency to the Valley is 

currently unknown.

• What are the key governmental entities involved in CSP decision-making and how can they 

work together?

At the federal level, the key entities are the BLM, DOE, USFWS, RUS, FERC, and NERC. 

The USFS could also be involved. At the state level, the key entities are the state legislature, 

the PUC, and the GEO. Other state entities are also involved. At the local level, the county 

commissioners are the key decision makers, but the SLV Power Authority could possibly 

also be involved. The ways in which many decision-making entities could productively work 

together still need to be worked out; defining them is far beyond the scope of this study. 

Some preliminary actions are suggested in the policy recommendations in this report.
82

• What are new models for the siting decision processes rather than the producer-buyerpurchase power agreement model? Can rural electric cooperatives play a larger role and, if 

so, how? Is there a model for developing power locally and using it where it is produced?

Some Valley stakeholders have put forward a concept of meeting local power needs with a 

distributed system in which small solar installations at Valley substations would be 

complemented by distributed generation (rooftop PV and solar thermal) along with smartgrid technology so that the Valley could become energy self-sufficient. Their vision is of a 

locally owned solar network run by an SLV Power Authority into which local funds would 

be invested. The SLV Power Authority proponents believe that the local area has the 

financial wherewithal to develop and own a 100-MW CSP facility. The revenues from the 

electricity sales from this authority would be public revenues that could be used for schools, 

job training, welfare, and other services needed in this economically challenged region.

This distributed-system idea is unlikely to work, however, unless the existing institutional 

structure for power generation and delivery is changed. The barrier is that the SLV REC must 

still purchase power from Tri-State under its long-term contract. The SLV Power Authority 

would not be able to sell its power to the REC for local distribution until someone bought out 

the Tri-State contract. The key question is: who would buy out the local utility’s contract 

with power providers? The answer would probably have to be that the federal government 

would have to release the REC from long-term liabilities if it wanted communities to 

establish local area generation based on local sustainable energy. Otherwise, new sustainable 

energy would have to be exported to load centers to meet new demand.

• What are the issues relative to transmission, such as crossing federal lands, environmental 

impact statements required, and public participation?

The need for transmission was recognized by several stakeholders whose understanding is 

that the SLV needs to improve its aging grid infrastructure, which has been neglected for 30 

years. It was also believed that more electricity is needed in the Valley, but there was an 

emphasis that local demand should be met locally. Some stakeholders are interested in the 

ability to export electricity, thus bringing jobs and income into the Valley.

Concerns about transmission focused on concern about the "industrialization of the Valley 

floor," aesthetic concerns about the scenic attributes of the SLV (the 14,000-foot peaks of the 

Sangre de Cristo mountains and Mt. Blanca, the Blanca Ranch, and Trinchera Ranch areas; 

feared loss of control of decisions affecting the Valley; wildlife issues; and adversarial 

proceedings regarding the route of power lines.

The lines of local arguments can be succinctly summarized as follows:

- Should the SLV export power? Yes or no?

- (If yes), Should the line go over La Veta Pass or Poncha Pass?

- (If yes or no), To what degree should the SLV develop distributed energy 

systems?
83

There are proponents and opponents for each of these positions.

• What are the policy, regulatory, and sociological barriers to CSP development?

Although those in control of the bureaucratic process and the independent power producers 

understood the legal actions they had to take for the outcome they wanted to achieve, the 

local stakeholders—those whose neighborhoods would be impacted—exhibited confusion 

about those decision processes and were often frightened by unknown technology, economic 

risks, and outside organizations with the clout to seriously affect them. Typically, they did 

not have the expertise (nor necessarily the wherewithal to purchase it) that could provide 

them with third-party technical advice on the potential economic, environmental, water, land, 

societal, and other impacts of such developments, but had to rely on the testimony of those 

organizations seemingly wedded to, and responsible for, the CSP development.

• What are the public lands involved in the Valley and what are the implications of CSP 

development on public lands? Is CSP included in the BLM's resource management plans? 

Are there concerns about sensitive wilderness areas?

As part of its ongoing efforts to increase domestic energy production and ensure greater 

energy security, the Bureau of Land Management (BLM) initiated a joint Programmatic 

Environmental Impact Statement (PEIS) with the U.S. Department of Energy (DOE) to 

assess the environmental, social, and economic impacts associated with utility-scale solar 

energy development on BLM-managed public land in six western States: Arizona, California, 

Colorado, Nevada, New Mexico, and Utah. The Notice of Intent (NOI) was published in the 

Federal Register on May 29, 2008.85

The BLM took this action after it became apparent that it had a backlog of applications for 

permits to develop large-scale solar energy projects on public lands but it could not issue 

permits because solar development was not part of its resource management plans. As the 

bureau works to develop a programmatic EIS that will streamline local areas, its personnel 

are climbing a learning curve about the potential land-use and other impacts of these projects. 

A final PEIS and Record of Decision is anticipated before the end of 2010.

• What role are environmentalists playing?

Local environmentalists are opposed to the proposed SLV-Calumet-Comanche transmission 

line. They favor distributed solar generation, including rooftop PV, in the SLV. Western 

Resource Advocates, an environmental organization based in Boulder, has intervened in the 

application for the CPCN to support the transmission line with certain limitations.

• What are the institutional barriers to CSP siting?

As noted, the decision processes are extremely complex, displaying a confusing mix of 

entities and procedures. Three siting decision models were identified (1) decisions by the 

 85 Solar Energy Development PEIS Webmaster, solareiswebmaster@anl.gov
84

SLV Power Authority, (2) county permitting, and (3) permitting on public lands. These 

processes are not well understood by the public, and not even by many of the Valley's 

stakeholders. As mentioned earlier, a Valley economic development group has fostered the 

creation of an SLV Power Authority that would tie together the cities and counties to provide 

an organization to develop local solar power. The main concern was if the six-county region 

would develop solar energy itself or have it "done to us and for us." The group formed a 

council of governments to enable the formation of the power authority. Another model is 

siting projects developed by IPPs, which obtain permits from local counties. This model 

involves decision-making by Xcel Energy and the PUC because the IPPs must have a PPA to 

guarantee sales of their electricity in order to obtain the financing necessary to build the 

project. Finally, because of the large percentage of public lands in the SLV, some of the 

permits for large-scale solar projects will be granted by the BLM.

9.3 Proponent Statements in Light of Study Findings

Three statements by those advocating utility-scale solar development and renewable energy 

transmission lines seem to go to the heart of some of the concerns of the SLV community.

(1) Utility Goal for Large-Scale Generation. The ultimate intention of Xcel and Tri-State is to 

provide transmission for a very large amount of electricity from the SLV, as voiced by Karen 

Hyde in PUC hearings on the line: “The potential solar resources in the San Luis Valley are 

in the thousands of megawatts, not hundreds. Artificially limiting transmission to the bare 

minimum necessary to connect resources that result (only) from the 2007 Resource Planning 

Docket would not be wise."86 This statement lends support to the concerns, valid or not, that 

CSP development would result in the "industrialization of the Valley floor." The utilities 

expect that, in the future, "thousands of megawatts" would be generated in the Valley, which 

would require tens of thousands of acres. If the expectation were not there, the transmission 

line would not have been proposed. Indeed, the goal of significant reductions in carbondioxide emissions would be enhanced by such large-scale development.

(2) Statewide Permitting. The WGA Task Force recommended statewide permitting for CSP 

siting; this approach appears also to be favored by GEO staff. This process could, if 

actualized, remove local control of land-use decisions on CSP facility siting and transmission 

siting. Such a decision would intensify concerns in the Valley.

(3) Solar Exemption from Sales and Property Taxes. The WGA Task Force report 

recommended that central solar plants be exempted from sales and property taxes, stating that 

the loss of these taxes would be offset by new tax revenues generated by economic activity 

caused by the plants.87

 86 Rebuttal Testimony and Exhibits, Karen Hyde, Xcel Energy, December 2, 2009 (described in Part Two of this 

report.)

If enacted, this proposal would remove one of the key benefits 

anticipated by county commissioners for their local counties—the property tax revenues to be 

paid by the facilities themselves. These tax revenues are viewed as fundamental benefits of 

solar development by SLV stakeholders. The prevention of property tax revenues for local 

counties could negatively affect perceived distributive justice; that is, the perceived equity of 

the distribution of costs and benefits from renewable energy development.

87 WGA 2006, pp. 22-23
85

As they become known and understood by SLV residents, these policy recommendations could 

intensify community opposition to CSP siting and the proposed transmission line over La Veta 

Pass. They provide some factual support to fears about the loss of local control over land uses 

and about marring of scenic areas and viewsheds. The recommendations could also mean a 

potential loss of relative economic advantages to the tax base of SLV counties often cited by 

stakeholders as a benefit of CSP development. 

9.4 Conclusions

Several broad conclusions emerge from the study as follows.

• Widespread support for solar energy development. Although the preferences on how it 

should be done vary, a common element of SLV stakeholders is broad favorability toward 

the development of renewable energy resources, and a great deal of local pride in the 

SunEdison plant near Mosca and other solar facilities being developed.

• Lack of knowledge and need for education. The SLV lacks knowledge on renewable 

energy. There is widespread confusion about the difference between PV and solar thermal 

electric systems and lack of knowledge about how CSP differs from other solar thermal 

electric systems.

• Complex decision processes lack transparency. CSP and transmission decision processes are 

extremely complex. They currently involve a confusing mix of entities and procedures. There 

seems to be a tendency to keep relevant information secret, open only to those in the power 

structure for proprietary and adversarial reasons or "in the know" for political reasons. An 

integrated and transparent decision process that fully integrates federal and state policies with 

concerns of the local area would increase effectiveness and social acceptance of renewable 

energy siting decisions.

• Public participation processes are more procedural than substantive. Public meetings and 

hearings have been held by IPPs, BLM, RUS, PUC and others at which supporters of the 

transmission line and opponents of it have testified. Although these events provide a formal 

mechanism for local-area stakeholder to be heard, the processes duplicate each other and are 

burdensome to the local community. John Villyard, Chief Executive of the SLV REC, said: 

“I wish NREL had never put the Valley on the solar map. Every week I’ve got developers 

coming into our offices with plans to put solar plants in the Valley. ...[The Valley] just feels 

overwhelmed....”88 The effect of the public testimony on bureaucratic and private industry 

decisions is as yet unclear, especially in the milieu of the adversarial proceedings at the PUC 

regarding the transmission line, which could continue for some time. The outcome of these 

processes could affect perceived procedural justice; that is, the perceived inclusiveness of the 

decision process.

 88 The Denver Post, December 13, 2009, p. K-8.
86

• Social-psychological effects are not understood. Stakeholders within the SLV mentioned 

social-psychological benefits from solar development and also potential harms. Little 

attention has been paid to these types of impacts in project siting, yet they involve 

fundamental issues of community identity.

• Organized opposition to the La Veta Pass transmission line. The advent of an organized 

opposition to the proposed transmission line over La Veta Pass that involves several 

organizations, including the Trinchera Ranch, is problematic for the successful resolution of 

this particular project.

• Outside-the-Valley stakeholders are not fully informed about nor engaged in Valley 

concerns.

The problems with CSP in the SLV reveal broader issues with respect to renewable energy 

siting, although CSP problems are not necessarily identical with problems in siting wind 

facilities. For example, when wind turbines are sited, other land uses such as grazing or growing 

crops can continue, but when utility-scale solar facilities are installed, the land cannot be used in 

any other way. While also being land intensive, CSP precludes other simultaneous uses of the 

land.

9.5 State Policy Recommendations

A set of recommendations relative to state policy actions that could be taken is discussed.

These are related to the report's findings.

• Ensure that SLV community concerns are addressed and that Valley stakeholders and 

residents are engaged in CSP-related and transmission decisions.

• Develop education programs for SLV residents. Local institutions of higher education 

should be funded to conduct education programs for SLV residents on energy efficiency, 

energy conservation, renewable energy distributed generation, and central-station systems. 

This funding should be provided by a consortium of partners, including developers, state 

government, and federal government agencies. 

• Integrate local decision-makers. A San Luis Valley energy-water-land group should be 

formed to represent Valley-wide energy, water, and land-use concerns in integrated siting 

and other decision-making processes at regional, state, and federal levels. This group should 

conduct analyses and take informed positions—reaching consensus as often as possible—on 

the integration of broad local and regional energy, land-use, and water concerns. Its primary 

purpose would be to integrate natural resources expertise. The activities of this group should 

be funded by federal, state and local programs, environmental organizations, and the 

renewable energy industry. Cognizant federal agencies could fund the organization and 

support of this group, the administration of which could be based at an SLV institution of 

higher education.

89

 89 A quote from a Valley stakeholder: "There should be a focus group of people to deal with energy issues because 

there are huge issues today."
87

• Offer workforce training. Local colleges should be funded to conduct workforce training 

on vocations related to employment opportunities in connection with distributed and largescale solar development in the Valley in partnership with the state community colleges and 

state and local workforce development officers.

• Provide training for SLV decision makers. Local educational organizations, in partnership 

with the legal educators, should organize workshops and seminars for city, county, and 

federal officials in the SLV on the statutory and regulatory implications of renewable energy 

decision-making at the state and federal levels. 

• Proactively approach spiritual interests The spiritual aspects of solar development should 

be explored as soon as possible.

• Evaluate models of taxation. Alternative models of taxation that would compensate the 

SLV community for the expenses involved in mitigating the impacts of CSP and 

transmission development should be investigated.

• Potentially form landholder energy associations. Such associations could create a public 

sphere for understanding and developing policy positions supported by the citizens of 

Colorado in renewable energy resource areas, beginning with the SLV.

9.6 Concluding Remarks

The SLV could become a laboratory for new approaches to siting decision-making, one that is 

sorely needed at the national level as other controversies concerning renewable energy and 

transmission siting at Cape Cod, San Diego, Medicine Lake, and other areas, make clear. As a 

human community, not an unpopulated desert, the SLV and its scenic and wildlife corridors, 

federal lands, and National Parks must be respected and protected. The opportunity to protect 

vulnerable communities and to engage them in CSP and transmission decisions, benefiting from 

their expertise rather than treating them as adversaries, should parallel in significance the 

investment in solar technology.

No matter what the ultimate outcome is in the SLV, the development of the SLV Power 

Authority should be further investigated in that it could be a useful test case on how small- to 

medium-scale solar installations integrated with utility substations and smart grids could be 

organized and managed. The most effective, socially acceptable institutional arrangements for 

generation and distribution of solar power may yet need to be invented.

 
88

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Afterword

On June 3, 2010, the New York Times90 reported on the SLV controversy, terming it a "bitter 

fight over solar's future," and pointing out that the path to a new energy future "will not be 

without its own messy entanglements of politics, power, and place." The Times story reported 

that in May 2010, Xcel Energy said that delays in the project, which they blamed on Louis 

Bacon and his lawyers, had "undermined the potential development of solar power in Alamosa." 

A utility spokesman reportedly said that the utility "may have to go somewhere else." However,

a spokesman for Mr. Bacon said he believed the utility was reconsidering for economic reasons 

and scapegoating Mr. Bacon. "Blame the billionaire," he said.

On June 5, 2010, the Denver Post91

 90 Johnson 2010. 

reported that Xcel Energy had asked the Colorado PUC to 

reduce the amount of solar power that it is required to obtain. Xcel Energy reportedly said it 

could modify current transmission lines and provide 185 MW of solar energy by a 2015 

deadline, a 48% reduction in existing requirements for solar power.

91 Migoya 2010.
93

Appendix A: Summary of the BLM PEIS Process
94

Summary of the BLM PEIS Process:

The U.S. Bureau of Land Management's and U.S. Department of 

Energy's Programmatic Environmental Impact Statement

for Utility-Scale Solar Energy Development

A-1.1 Background

As part of its ongoing efforts to increase domestic energy production and ensure greater energy 

security, the Bureau of Land Management (BLM) initiated a joint Programmatic Environmental 

Impact Statement (PEIS) with the Department of Energy (DOE) to assess the environmental, 

social, and economic impacts associated with utility-scale solar energy development on BLMmanaged public land in six western States: Arizona, California, Colorado, Nevada, New 

Mexico, and Utah. The Notice of Intent (NOI) was published in the Federal Register on May 29, 

2008.92

A-1.2 Chronology of Key Events

As the federal government moved to implement a policy of increased development of solar 

resources, it became clear that the public lands would have to be used for this purpose. The BLM 

had a backlog of applications for permits to develop large-scale solar facilities on public lands. 

However, permits cannot be issued for any activity that is not included in the Bureau's Resource 

Management Plans (RMPs); therefore, the RMPs have to be modified to allow permits to be 

granted. To facilitate this process, the BLM and DOE joined together to conduct a programmatic 

environmental impact statement on large-scale solar development in six Western states. Once the 

PEIS process is completed, it would be for permits to be granted more readily than otherwise 

would have been the case. Table A-1 summarizes the key events in the PEIS process and the 

designation of solar study areas in the six states. 

The BLM has conducted two different PEISs. One was for the transmission corridors, which has 

been completed and the record of decision announced. The other, which is ongoing, was for 

solar development on public lands. This PEIS is the focus of this section of the report. 

 92 Solar Energy Development PEIS Webmaster, solareiswebmaster@anl.gov
95

Table A-1. Chronology of Key Events in the Management of BLM Public Lands 

for Large-Scale Solar Energy Development

Date Key Event

2008 – ongoing BLM has a backlog of hundreds of solar energy and wind project 

applications for siting permits on public lands

December 2008 BLM issues a Final PEIS for itself, DOE, USDA, and USDOD identifying 

energy transport corridors to facilitate the development of renewable 

energy resources 

January 2009 Following on the energy corridors PEIS, BLM and USFS issued Records of 

Decision amending 130 land-use plans to designate 6,000+ miles of energy 

corridors in 11 Western states

May 28, 2008 BLM-DOE initiated another joint PEIS for utility-scale solar energy 

development on BLM-managed public lands in six Western states: Arizona, 

California, Colorado, New Mexico, Nevada, Utah with Notice of Intent (NOI) 

published in Federal Register as of this date. 

May-July 2008 Public Scoping Comments period on the joint PEIS 

March 11, 2009 Secretary of Interior Ken Salazar issues Secretarial Order No. 3285 

announcing a policy goal of identifying and prioritizing specific locations 

best suited for large-scale production of solar energy

May 5, 2009 Secretary of Interior Ken Salazar announces formation of four Renewable 

Energy Coordination offices in Arizona, California, Nevada, and Wyoming 

and smaller renewable energy teams in Colorado, Nevada, New Mexico, 

and Oregon

June 30, 2009 BLM designates 21,000 acres in the San Luis Valley of Colorado as Solar 

Energy Study Areas (SESAs) (of 670,000 acres total) with NOI published in 

the Federal Register.

July-September 

2009

BLM-DOE consider public comments on the PEIS for solar development.

September 14, 

2009

Last day of public scoping meetings on the PEIS

Summer/Fall 

2010

Planned release of Draft PEIS

Late fall 2010 

(TBD)

Final PEIS and Record of Decision to be released
96

A-1.2.1 PEIS on Energy Transmission Corridors in the West. 

The joint PEIS, released at the end of 2008, identifies energy corridors in the West for 

transmission and distribution lines that will help facilitate the development of renewable energy 

resources. The energy corridors could also carry pipelines for oil, natural gas, and hydrogen. 

Approximately 5,000 miles (8,000 km) of energy corridors are located on BLM-managed lands, 

while nearly 1,000 miles (1,600 km) of energy corridors are on U.S. Forest Service lands. 

Roughly 120 miles (190 km) of corridor segments are on lands managed by the Bureau of 

Reclamation, the National Park Service, and the Department of Defense. 93

The BLM and the U.S. Forest Service issued Records of Decision in mid-January 2009 to amend 

130 of their land use plans to support the designation of more than 6,000 miles (9,700 km) of 

energy transport corridors on federal lands in 11 Western states. The amendments were based on 

analyses presented in a Final PEIS that was prepared by the BLM, DOE and the U.S. 

Departments of Agriculture and Defense as part of their work to implement the Energy Policy 

Act of 2005. 

A-1.2.2 Related Federal Actions. 

On May 5, 2009, Ken Salazar, Secretary of the Interior, pledged to create four Renewable 

Energy Coordination Offices, one each in California, Nevada, Wyoming and Arizona. In 

addition, Salazar proposed the creation of smaller renewable energy teams located in New 

Mexico, Idaho, Utah, Colorado and Oregon. Such offices will expedite production of renewable 

energy on public lands.94 The renewable energy offices and teams are being set up to expedite 

applications, processing, reviews, and permitting of renewable energy projects. Salazar said the 

Interior Department is investing $41 million through the President's economic recovery plan to 

facilitate a rapid and responsible move to large-scale production of renewables on Bureau of 

Land Management lands. Currently, the Interior Department has a backlog of hundreds of solar 

energy and wind project applications for siting on BLM lands. The new offices will also improve

the BLM's coordination with state agencies and other federal agencies, including DOE and the 

U.S. Environmental Protection Agency. 95

A-1.2.3 PEIS on Solar Energy Development.

On May 28, 2008, BLM and DOE announced their new PEIS process. With Notice of Intent 

(NOI) published in the Federal Register on June 30, 2009, the BLM announced the availability 

of maps that identified 24 tracts of BLM-administered land for in-depth study for solar 

development, and requested public comment on those study areas. Public comments were 

accepted in the six Western states from July-September 2009. According to the Solar Energy 

Development Programmatic EIS website, the release of the Draft Solar Energy Development 

PEIS was originally scheduled for spring of 2009. However, BLM and DOE have agreed to 

postpone completion of the Draft PEIS in order to more closely align the proposed alternatives in 

the Draft EIS with Secretarial Order No. 3285 (issued March 11, 2009 by the Secretary of the 

 93 Programmatic EIS Web site or the West-wide Energy Corridor Programmatic EIS, corridoreiswebmaster@anl.gov

94 The Interior Department Web site, www.doi.gov/news/09_News_Releases/031109c

95 The Interior Department Web site, www.doi.gov/news/09_News_Releases/031109c
97

Interior), which announced a policy goal of identifying and prioritizing specific locations best 

suited for large-scale production of solar energy. 

A-1.2.4 Designation of the Solar Energy Study Areas (SESAs) in the San Luis 

Valley. 

With anthropogenic climate change acknowledged by the government, industry, and the broader 

public coupled with the high cost of oil and gas, national focus on renewable energy targets and 

appropriate technology is growing. As noted earlier, research on solar energy potential indicates 

that the San Luis Valley (SLV) is a prime location for solar development, making it one of the 

most favorable locations in Colorado to develop solar projects, especially utility-scale solar

energy projects. 

The BLM's plan for SESAs totals 670,000 acres, including 21,000 acres in Colorado’s San Luis 

Valley. The goal, according to the BLM, is to speed project permitting for utility-scale solar 

power projects. The 24 tracts being considered for the study areas are being evaluated for their 

environmental and resource suitability for large concentrating solar power and photovoltaic 

systems installations.

96 In the course of the PEIS analyses, the agencies have identified a number 

of tracts of BLM-administered land for in-depth study for solar development. Four study areas 

have been identified in Colorado: Antonito Southeast (9,598 acres), De Tilla Gulch (1,522 

acres), Fourmile East (3,882 acres), and Los Mogotes East (5,909 acres). 97

 96 Solar Energy Development PEIS Webmaster, solareiswebmaster@anl.gov 97 Solar Energy Development PEIS Webmaster, solareiswebmaster@anl.gov
98

Figure 1. Solar Energy Study Areas in Colorado (June 5, 2009)

Credit: Argonne National Laboratory

The Colorado locations could generate up to 4,182 MW of solar power if fully developed, 

according to the U.S. Department of the Interior. If areas are deemed suitable for large solar 

projects, then companies would have the option of building installations with a capacity of 10-

MW or more. According to the Secretary of Interior, companies proposing projects in these areas 

would be eligible for faster permit processing. 98

Because developing these types of facilities has environmental implications, public discourse is 

encouraged, and is, in fact, required through NEPA. 

 

98 Solar Energy Development PEIS Webmaster, solareiswebmaster@anl.gov
99

A-1.2.5 Public Comment Process. 

The BLM accepted comments on the scope of the PEIS through July 15, 2009 and held public 

scoping meetings in the six states through September 14, 2009.99 The Solar Energy Development 

Programmatic EIS website is the online center for public information and contains 35 public 

comments from organizations and individuals recorded through September 14, 2009. The 

organizations and individuals represented include: 

 99 Solar Energy Development PEIS Webmaster, solareiswebmaster@anl.gov

Organizations:

Arizona Wilderness Coalition

Californians for Western Wilderness

California Native Plant Society

California Wilderness Coalition Center for Native Ecosystems (Pollock, Robertson) 

Colorado Environmental Coalition (Curtiss) 

Defenders of Wildlife

Desert Protective Council 

Grande Water Conservation District

Great Old Broads for Wilderness (Egan) 

Mesa County, Planning and Economic Development (Larsen, Price) 

Mojave Desert Land Trust

National Trust for Historic Preservation (Pahl, Poston, Hartig, Schwendler) 

National Wildlife Federation

Natural Resources Defense Council

New Mexico Wilderness Alliance

Rio Grande Water Conservation District (Vandiver) 

Saguache County Board of County Commissioners (Pace, Spearman, Joseph)

San Luis Valley Ecosystem Council (Canaly) 

San Luis Valley Water Protection Coalition (Crowley)

Sierra Club

Soda Mountain Wilderness Council

Southern Utah

The Wilderness Society (Daue) 

Western Resource Advocates (Darin) 

Western Resource Advocates

Wilderness Alliance

Wild Utah Project

Wyoming Outdoor Council 

Individuals:

Austin, Gay (Gunnison; CO)

Barker, Claire (2) (Mosca, CO)

Barker, Donald (CO)

DeHerra, Guillermo (Location Withheld) 

Diss, Orville, (Center, CO)

Howard, Eugene D. (Denver, CO)

Mitson, Loretta M. (Manassa, CO) 

Naylor, Thomas A. (Fairplay, CO)

Plutschuck, Donna M. (Lakewood, CO)

Smith, Jeff (Location Withheld)

Smith, Cecelia (Crestone, CO) 

Zenoit, Michael (Denver, CO)
100

Although it was not possible to include all public comments posted on the PEIS website the 

selection of comments included in this report represents a range of issues and their pros and 

cons. The comments fall under four broad categories, defined as (1) energy systems impacts 

(renewable/conventional), (2) environmental impacts, (3) economic impacts, and (4) the PEIS 

process itself.

 

Energy Systems (Renewable/Conventional)

Issues include renewable development, dependency on fossil fuels, use of conventional and other 

(i.e. wind energy sources), GHG emissions, job creation and cost benefit analysis. Related 

submission(s) are presented below.

. 

Private citizen Mitsin commented in part: “I believe that solar development should be treated 

just like agriculture. We need to support large scale agribusiness as well as small scale family, 

community (CSA) farms. We need to encourage large scale solar development as well as smallscale solar generation on every possible rooftop and home. BUT, we need to be very careful 

where we site large-scale agribusiness as well as where we site large scale solar energy 

generators. Utilizing public lands for solar generation is not a good choice. 

As an individual who utilizes passive solar collectors on my home, I do not have to be convinced 

of the viability of small-scale solar utilization. I do not believe that the power distribution 

companies have really explored the possibility and necessity of generating power closer to its 

point of use. Transporting power over long distances only serves to reduce the net gain of kWh. 

Ideally, solar generators need to be sited closer to the cities, where the production can be 

maximized.” Adding: “ If the Solar Rewards Program was adequately funded instead with the 

millions of dollars that are earmarked to be squandered on hundreds of miles of high voltage 

lines, and the cost of acquiring lands for right-of-way, maybe we could get more of the 

population behind a real grassroots interest in satisfying and generating more of our energy 

needs right in our own communities. Let’s not 'pave paradise and put up a parking lot.' There is 

plenty of private land to use for solar generation. Don't use our public lands for that, or we will 

never get them back. Public lands are sacred.” 100

The National Trust for Historic Preservation commented in part: “The National Trust for 

Historic Preservation (National Trust) commends the efforts of the Bureau of Land Management 

for (BLM) to identify appropriate areas for solar energy development while limiting impacts to 

significant cultural resource. We feel strongly that by incorporating the results of tribal 

consultation and previous cultural resources inventories into the development of the solar 

Programmatic Environmental Impact Statement (PEIS) and the specific Solar Energy Study 

Areas (SESAs), BLM can facilitate efficient and cost-effective renewable energy development 

while protecting the invaluable, significant cultural resources that are present on America’s 

federal public lands. At the same time, we believe that efficiency and reduction of energy use at 

private and public scales should be a focus of rent and future energy planning. Rather than 

simply producing and transmitting more energy, we would simultaneously work to reduce our 

energy needs.”101

 100 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record no. 60236 101 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record no. 60224
101

Environmental Impacts. Issues include concern for ecosystems, species analysis, and 

distribution. Related submission(s) are included below.

San Luis Valley Ecosystem Council (SLVEC) comments in part: “The mission of SLVEC is 

to protect and restore—through research, education, and advocacy— the biological diversity, 

ecosystems, and natural resources of the Upper Rio Grande bioregion, balancing ecological 

values and human needs. SLVEC works as the only local public lands advocacy organization 

that is concerned about protecting and restoring intact ecosystems and wildlife corridors, from 

the mountain peaks to the rivers along the valley floor, and into New Mexico. We encourage both 

a national and a regional conversation on energy use and, especially, on fossil fuels and their 

impacts to climate change. It is imperative that our country makes the transition to the use of 

renewable energy sources. The warming effects are being felt in the San Luis Valley, as in other 

parts of the world, and are impacting wildlife, water supplies, and forest health. We believe that 

renewable energy can offer a clean, affordable, sustainable, and environmentally friendly 

alternative. We support a measured approach, however, to the switch to alternatives. We 

recognize the unique and valuable aspects of the San Luis Valley. We understand that the Valley 

has enormous potential in the area of solar production, and has a long history of supporting 

solar energy on a smaller scale. We encourage the development of renewable energy strategies 

that will promote the long-term health and well being of the community, and protect the 

environment, critical habitat, wildlife, sensitive corridors, and water, as well as the history and 

culture of this agro-pastoral community. We urge the DOE and BLM to take a long term view 

when considering the scale, siting, water demands and the building of new transmission lines 

that will be required to accommodate Utility Scale Solar development in a culturally and 

ecologically sensitive area like the San Luis Valley (SLV). It is imperative that solar 

development remain responsible and that renewable energy development does not compromise 

this area’s unique values. We recommend a national model of appropriate energy development 

based on what is currently being implemented in European countries. They appear to exercise a 

threefold strategy; emphasis on flexibility in size and scale fitted to location and need, 

constructing open ended systems that can rapidly integrate new technologies, and suitably 

subsidizing research and development that encompasses a range of alternative energy 

sources.

102

Rio Grande Water Conservation District commented in part: “The District Board of 

Directors does not have a policy of opposition to solar power. However, we are very aware that 

some types of solar generation can use significant amounts of water. In fact, we are lead to 

believe that some solar generation techniques use almost the same amount of water as a coalfired generation system. As you know, the State of Colorado is a prior appropriation state. The 

Federal Government and its agencies have been joined in the State water rights process 

pursuant to the McCarran Amendment. And, pursuant to that joinder, the Bureau of Land 

Management has sought and obtained any reserved water rights to which it is entitled. Any water 

required for solar generation must therefore be acquired pursuant to Colorado law and will be 

governed by the doctrine of prior appropriation.”103

 102 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 60126 103 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record No. 007
102

Private citizen Austen wrote: “Dear Personnel, I am writing to you about my concern 

regarding the Solar Energy Development project proposed on BLM lands across the West. I am 

concerned that this project may damage or destroy threatened, endangered, or sensitive plant 

and/or rare lichen populations. Are plant surveys, plant BA's, and plant BE's going to be 

conducted by qualified Botanists for the project area? 104

Private citizen Barker commented in part: “The economic benefit to communities 

affected―specifically individuals whose property value plunges and community business 

economics-dependent on non-industrialized ambiance―are not well regulated or methodically 

reimbursed for losses incurred secondary to solar and transmission development. Much falls 

under 'eminent domain.' All industry-solar included-require some water-if only to wash panels 

free of dust-which is plentiful in many of the scoped regions. Other technologies to provide 

storage capability of energy-utilize the equivalent in water consumption to present agribusiness-BUT-utilizes it 12 months out of the year-instead of just three. Unregulated or legal 

changes in regulations of water use-make sunny, arid climates very vulnerable to continuing 

water issues that devastate the local eco-systems. The agricultural industry is already struggling 

with this issue, another "layer" of industrial usage permits would be paradoxical under the guise 

of "green". At present-I acknowledge that the energy industry/energy consumer is at a 

crossroads-under the time limit of legal change in Colorado-to increase "green energy 

consumption and development by 10%. We are also at a crossroads where moving too fast and 

in the "path of least resistance and cost" will cost our future generations dearly. We KNOW thiseven though the technology is new-the pitfalls are predictable. Let us NOT repeat history-please. 

Uphold public lands for public enjoyment, open space, environmental sanctity and eco-system 

balancing. The issue is already difficult enough without adding another layer of potential 

problems.”105

Economic Impacts. Issues include the benefits of job creation, concern over property values, 

tourism due to a changed landscape. Related submission(s) are included below.

Private citizen Diss commented: “I would encourage use of the BLM land in the San Luis 

Valley in Colorado for Solar development. The SLV is one of the most depressed areas in the 

entire country. The entire economy of this valley is based on the price of potatoes. With 

increasing pressure from State and other entities to cut back on water consumption, this valley 

will literally dry up and blow away without some other economic base that doesn’t require much 

water.”106

Private citizen Smith commented: “My thought is that we develop our natural resource (oil,

gas and nuclear) before we subsidize renewables. The amount we can generate from renewables 

is minuscule to that of other sources. Not to mention the job loss in developing renewables is 

nearly 3 to 1 vs. developing our natural resources. A great example is the solar panels put atop 

the museum of science and natural history in Denver. It was considered by the Administrators to 

put solar panels on their building but after discovering the return on investment took 114 years 

and the panel’s life was 25 years it logically was shelved. Then appears the government who is 

 104 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record no. 60163 105 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record no. 61049 106 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record no. 60155
103

willing to take taxpayer money to fund renewable energy. Not with logic but with taxpayer 

money to appease the greenies. What a waste and if that kind of investment continues the 

taxpayers will run out of money. As a business decision and that's how it has to be looked at it's 

a no brainer.

Private citizen Howard commented: “Please do proceed with evaluating public lands for 

solar. We need to break our country's dependence on OIL and instead of DRILLING in sensitive 

areas that could spoil the land and doesn't move to solve the problem, install SOLAR PV, 

THERMAL and Wind on public lands that go to make our country a safer place and energy 

independent from the rest of the world. THIS is a GREAT USE of Public lands that belong to all 

Americans. Thank you for listening to me.”107

Private citizen Plutshuck commented: “Finally! The BLM & the US Government have to help 

in whatever way possible with developing renewable energy. Not only does it put people to work, 

it maintains Americans' standard of living while reducing greenhouse gases. Please, install solar 

and wind power.”108

Private anonymous citizen commented: “I support the choice of the solar study areas in 

Colorado. I live in Antonito and not too far from the study just south of Antonito. This location is 

ideal for the purpose intended and solar energy is vital to the future of our country. I hope that 

the government will help those of us in small rural towns to obtain affordable means of using 

alternative energy sources such as solar and wind power. I also think that wind power study 

areas should be established; and, the locations chosen for the solar study are also viable for 

wind power study.”109

PEIS Process. Issues include regulatory practice, water and land use and appropriation, siting, 

and transmission, proximity to urban centers, infrastructure, robust planning and assessment. 

Related submission(s) are included below. 

The Wilderness Society joint submission stated in its introduction: “We support BLM’s to 

develop clear and comprehensive guidelines for responsible solar energy development, identify 

lands appropriate for solar projects as open for development, and close all other lands to 

development as part of the Solar Energy PEIS. The release of proposed SESAs for public review 

and comment is an important next step showing the BLM’s commitment to this approach and 

providing more detail on how it can be accomplished. We are encouraged by the BLM’s 

statements that important screening criteria (including critical wildlife habitat, special 

management areas, and visual resources) have already been applied to SESAs. Further, 

establishing SESAs better enables a landscape-level analysis of solar development and 

associated transmission on public lands in the West.”110

Mesa County Department of Planning and Economic Development commented in part:

“The PDF maps on the Solar PEIS website provide insufficient detail to evaluate the 4 sites 

 107 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 60119 108 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 60064 109 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 60111 110 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record no. 60247
104

proposed in Colorado. The data used to create these maps should be made available for 

download in formats that can be used by popular GIS software. Additionally, maps should be 

made available interactively online similar to http://www.nrel.gov/eis/imby/.” “The PEIS should 

take into account existing infrastructure and proximity to urban areas in a formula for 

calculating suitability of BLM land for solar development. The map titled “Solar Potential from 

Concentrating Collector,” shows that the tracts in southern Colorado that are part of this PEIS 

provide 6.0 to 6.5 kWh/sq. meter/day. Other areas managed by BLM of slightly less available 

solar energy with values of 5.5 to 6.0 kWh/sq.meter/day that are closer to urban areas and are 

located along existing transmission lines were not considered for this PEIS. Electrical 

transmission loss over long distances may negate the slightly higher (10%) solar energy 

available in the PEIS study area. New electrical transmission corridors and higher capacity 

transmission lines will consume land and create their own negative environmental and aesthetic 

impacts. As part of the draft Solar PEIS, areas slightly less than 6.0 to 6.5 kWh/sq. meter/day, 

should be considered and included as one of the alternatives if they are more efficient by their 

close proximity to existing infrastructure.”111

Saguache County Board of County Commissioners commented in part: “The solar energy 

generation advances at a rapid pace. Yet, the new large-scale fields being developed are new to 

all of us. Little is known of the potential impacts of the infrastructure and processing of solar 

energy at this scope. It is essential that adequate baseline information be available, and 

monitoring reviews be included in arrangements between the BLM and industry, to assure early 

detection and mitigation of currently unforeseen impacts.” 112

Private citizen Barker commented in part: “Solar development―while 'greener' in SOME 

ways, on a utility-scale basis― disrupts the landscape, denies access, develops access where 

none was and changes the shade/sun/water cycle so critical to many of the areas being "scoped". 

Thousands of solar panels precede the problem of removal of obsolete panels-which are toxicand presently non-recyclable. I fear greatly the setting of "precedence" through "NEED" under 

the guise of green energy. Denying known problems of environmental/socio-economic damage to 

communities affected and warping industrial sized solar development potential to fit a gas/coal 

model. Solar is most effective close to its source of consumption. Utility scale or personal panel 

placement. ALL of Colorado (Western United States) has great solar potential and tracts of 

industrial land, private land and public right of ways perfect for locale community use-specific 

development. Hurrying to seek a path of least resistance, under the pressure of federal and state 

scrutiny, will make it more difficult or impossible in the future, to mitigate applications for 

development of any and every kind on our gorgeous public lands. Utility scale solar energy 

development presently is tied into transmission line development. Connecting large tracts of 

land, over miles of more land to reach each other. Toxic views, migratory and native bird 

threats, extension of development in even more "open space" beyond the immediate utility solar 

plant, and only token legal attention to environmental/socio-economic impacts of the 

communities and ecosystems involved.” 113

 111 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/ public comment record No. 61085 112 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 60102 113 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 61049
105

Private citizen DeHerra commented in part: “In the American West there are old sayings that 

in simple ways tell the story. For Solar Energy Project Development in the San Luis Valley there 

is such an appropriate old saying, ‘you have to strike when the iron is hot,’ which is a must for 

branding calves with a hot iron. In the United States today there is tremendous interest in 

renewable energy and a multitude of government incentives for such projects. The heightened 

interest by the American people and the public policy and incentives created by the new Obama 

administration are driven by the global financial crisis, price of oil nearing peak supply, turmoil 

in the Middle East, and the need to move America to new energy sources and away from foreign 

oil. However there are limitations to the market opportunities, so as the market for solar energy 

heats up, it would be smart to ‘strike when the iron is hot’. What this means for the Bureau of 

Land Management (BLM) in the rule making process of this programmatic EIS, is that action 

taken to allow the private sector to utilize these public lands for solar energy development must 

be swift, with minimal or reasonable regulation adopted in an open process to allow for fair 

competition. In addition, other measures by federal and state governments will need to be 

initiated and/or continued for solar energy to be competitive with fossil fuels for commercial 

power generation.” From page 7 - “The PEIS effort should continue and rules and regulations 

issued to allow companies to compete for fast track licensing of the two tracts of land. This new 

technology and the tremendous human and natural energy potential have certainly motivated me 

to get involved and likely return to my homeland. Over the last half century, one of the greatest 

exports from the San Luis Valley has been people; it is now time to bring them home as new jobs 

and opportunities are created.”114

A-1.3 Summary

The PEIS designated tracts of U.S. public lands in the West as prime zones for utility-scale solar 

energy development, funded environmental studies, opened new solar energy permitting offices 

and is working to speed reviews of industry proposals. Under this initiative, 24 tracts of Bureau 

of Land Management-administered land located in six western states, known as Solar Energy 

Study Areas, would be fully evaluated for their environmental and resource suitability for largescale solar energy production. The objective is to provide landscape-scale planning and zoning 

for solar projects on BLM lands in the West, allowing a more efficient process of solar 

development. The schedule for release of the draft PEIS will be determined after the evaluation 

of comments from the current scoping period addressing the solar energy study areas. The Draft 

PEIS is expected to be available for public review and comment in late summer or early fall 

2010. 115

 114 Solar Energy Development PEIS Webmaster at http://solareis.anl.gov/public comment record no. 60213

115 Bureau of Land Management/Colorado at www.blm.gov/co/st/en/BLM_Programs/energy/renewable_energy.print.html
106

Appendix B: Chronology of Key Events in the SLV 

Transmission Siting Controversy
107

Table B-1. Chronology of Key Events in the Controversy over Siting 

New Transmission Lines and Substation in the San Luis Valley

Date Key Event

March 2007 S.B. 100 passes in the Colorado legislature and is signed into law 

by Governor Ritter

January 2009 BLM and USFS issued Records of Decision amending 130 land-use 

plans to designate 6,000+ miles of energy corridors in 11 Western 

states

April 2009 H.B. 1300 authorizes the “Clean Energy Development Authority” 

(CEDA), a Colorado “transmission authority”.

May 2009 Applicants Xcel Energy and Tri-State Electric Generation and 

Transmission Association file for a Certificate of Public Convenience 

and Necessity (CPCN) (Colorado PUC Docket Number PUC 

Combined Docket #08E324 and 325) 

June 2009 Tri-State submits “Alternative Evaluation” to the USDA which 

evaluates alternative transmission routes

October 28, 

2009

Interveners in Combined Docket #08E324 and 325 submit answer 

testimony

November 9 and 

10, 2009

The PUC holds public hearings in Walsenburg and Alamosa, 

Colorado, concerning the application for a CPCN by Xcel Energy 

and Tri-State 

December 2, 

2009

Interveners in Combined Docket #08E324 and 325 submit rebuttal 

and answer testimony

January 18, 

2010

Sur-rebuttal Testimony was filed by applicants, WRA and Trinchera 

Ranch
F1146-E(10/2008)

REPORT DOCUMENTATION PAGE Form Approved

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1. REPORT DATE (DD-MM-YYYY)

June 2010

2. REPORT TYPE

Subcontract Report

3. DATES COVERED (From - To)

October 9, 2008 – March 31, 2010

4. TITLE AND SUBTITLE

Community Response to Concentrating Solar Power in the San Luis 

Valley

5a. CONTRACT NUMBER

DE-AC36-08-GO28308

5b. GRANT NUMBER

5c. PROGRAM ELEMENT NUMBER

6. AUTHOR(S)

B.C. Farhar, L.M. Hunter, T.M. Kirkland, and K.J. Tierney

5d. PROJECT NUMBER

NREL/SR-550-48041

5e. TASK NUMBER

CP09.5202 

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Institute of Behavioral Science and 

Renewable and Sustainable Energy Institute, 

University of Colorado at Boulder 

483 UCB 

Boulder, CO 80309-0483

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NREL

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NREL Technical Monitor: Mark Mehos

14. ABSTRACT (Maximum 200 Words)

This report is about the social acceptance of utility-scale concentrating solar power (CSP) plants in the San Luis Valley, 

approximately 200 miles southwest of Denver, Colorado. The research focused on social factors that may facilitate and impede 

the adoption and implementation of CSP. During the winter of 2008-2009, interviews were conducted with a purposive sample of 

25 CSP-related stakeholders inside and outside the Valley. Interviews focused on the perceived advantages and disadvantages 

of siting a hypothetical 100-MW CSP facility in the Valley, the level of community support and opposition to CSP development, and 

related issues, such as transmission. State policy recommendations based on the findings include developing education programs 

for Valley residents, integrating Valley decision makers into an energy-water-land group, providing training for Valley decision 

makers, offering workforce training, evaluating models of taxation, and forming landholder energy associations. In addition, the 

SLV could become a laboratory for new approaches to CSP facility and transmission siting decision-making. The author 

recommends that outside stakeholders address community concerns and engage Valley residents in CSP decisions. Engaging the 

residents in CSP and transmission decisions, the author says, should take parallel significance with the investment in solar 

technology.

15. SUBJECT TERMS

utility-scale concentrating solar power; CSP; concentrating solar power; San Luis Valley; social factors; adoption of CSP; CSPrelated stakeholders; advantages and disadvantages of siting; community support; opposition to CSP; transmission; State policy 

recommendations; education; training; workforce training; taxation; landholder energy associations; siting decision-making; 

community concerns;

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