FINDING OF NO SIGNIFICANT IMPACT AND

FINAL ENVIRONMENTAL ASSESSMENT OF

THREE SITE DEVELOPMENT PROJECTS AT THE

NATIONAL RENEWABLE ENERGY LABORATORY

SOUTH TABLE MOUNTAIN SITE

July 2007 

U.S. Department of Energy 

Golden Field Office 

National Renewable Energy Laboratory 

1617 Cole Boulevard 

Golden, Colorado 80401 

DOE/EA-1573 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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TABLE OF CONTENTS 

ACRONYMS AND ABBREVIATIONS ....................................................................................................iv

EXECUTIVE SUMMARY ..........................................................................................................................v

1.0 INTRODUCTION ...........................................................................................................................1

1.1 The National Environmental Policy Act and Related Procedures ...................................... 1

1.2 Background......................................................................................................................... 2

1.3 Purpose and Need ............................................................................................................... 2

1.4 Scoping ............................................................................................................................... 6

1.5 Comments on the Draft EA................................................................................................. 6

2.0 PROPOSED ACTION AND ALTERNATIVES ............................................................................7

2.1 Renewable Fuel Heating Plant............................................................................................ 7

2.2 SolarTAC Project.............................................................................................................. 11

2.3 Mesa Top Photovoltaic Project......................................................................................... 12

2.4 No Action Alternative....................................................................................................... 13

2.5 Alternatives Considered But Not Analyzed...................................................................... 13

3.0 EXISTING ENVIRONMENT AND ENVIRONMENTAL IMPACTS .......................................14

3.1 Environmental Impacts of the Proposed Action ............................................................... 14

3.1.1 Land Use, Planning, Socioeconomics, and Public Policy....................................14

3.1.1.1 Existing Environment..........................................................................14

3.1.1.2 Impacts of the Proposed Action...........................................................15

3.1.2 Traffic and Circulation.........................................................................................17

3.1.2.1 Existing Environment..........................................................................17

3.1.2.2 Impacts of the Proposed Action...........................................................18

3.1.3 Air Quality ...........................................................................................................19

3.1.3.1 Existing Environment..........................................................................19

3.1.3.2 Impacts of the Proposed Action...........................................................20

3.1.4 Visual Quality/Aesthetics ....................................................................................25

3.1.4.1 Existing Environment..........................................................................25

3.1.4.2 Impacts of the Proposed Action...........................................................26

3.1.5 Water Resources ..................................................................................................28

3.1.5.1 Existing Environment..........................................................................28

3.1.5.2 Impacts of the Proposed Action...........................................................29

3.1.6 Geology and Soils................................................................................................30

3.1.6.1 Existing Environment..........................................................................30

3.1.6.2 Impacts of the Proposed Action...........................................................30

3.1.7 Biological Resources and Wetlands.....................................................................31

3.1.7.1 Existing Environment..........................................................................31
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3.1.7.2 Impacts of the Proposed Action...........................................................34

3.1.8 Cultural Resources...............................................................................................35

3.1.8.1 Existing Environment..........................................................................35

3.1.8.2 Impacts of the Proposed Action...........................................................35

3.1.9 Noise....................................................................................................................36

3.1.9.1 Existing Environment..........................................................................36

3.1.9.2 Impacts of the Proposed Action...........................................................37

3.1.10 Waste Management..............................................................................................38

3.1.10.1 Existing Environment..........................................................................38

3.1.10.2 Impacts of the Proposed Action...........................................................39

3.1.11 Public Facilities, Services, and Utilities ..............................................................39

3.1.11.1 Existing Environment..........................................................................39

3.1.11.2 Impacts of the Proposed Action...........................................................40

3.1.12 Energy and Sustainability ....................................................................................40

3.1.13 Intentional Destructive Acts ................................................................................40

3.2 Environmental Consequences of the No Action Alternative ............................................ 41

4.0 CUMULATIVE AND SECONDARY IMPACTS........................................................................43

5.0 COMMITMENT OF RESOURCES AND SHORT-TERM USES...............................................45

5.1 Irreversible/Irretrievable Commitment of Resources ....................................................... 45

5.2 The Relationship between Local Short-Term Uses of the Human Environment and 

the Maintenance and Enhancement of Long-Term Productivity ...................................... 45

6.0 REFERENCES ..............................................................................................................................46

APPENDIX A SCOPING LETTERS...............................................................................................A-1

APPENDIX B SCOPING LETTER DISTRIBUTION LISTS ........................................................ B-1

APPENDIX C RESPONSES RECEIVED TO SCOPING LETTER............................................... C-1

APPENDIX D RESPONSES TO COMMENTS ON THE DRAFT EA..........................................D-1

APPENDIX E DRAFT RFHP CONSTRUCTION PERMIT .......................................................... E-1
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LIST OF TABLES 

Table 3-1. Estimated Annual Emissions at the STM Site, 2001 ........................................................19

Table 3-2. Predicted Emissions Compared to NAAQS .....................................................................21

Table 3-3. Comparison of Maximum Predicted Impact to Health-Based Standards .........................22

Table 3-4. Comparison of Emissions: Current Plant, Proposed Plant, and Open Burning ................23

Table 3-5. Vegetation Types at NREL, STM Site, Golden, Colorado...............................................32

Table 3-6. RFHP Equipment Noise Levels........................................................................................37

Table 3-7. Waste Generation at the STM Site, 2003-2006 ................................................................39

LIST OF FIGURES 

Figure 1-1. Regional Location of the STM Site ....................................................................................3

Figure 1-2. Local Setting of the STM Site ............................................................................................4

Figure 2-1. STM and the Relative Locations of the Three Proposed Projects on the Site ....................8

Figure 2-2. Site Layout of the RFHP.....................................................................................................9

Figure 3-1. Site Development Zones and Proposed Improvements at the STM Site ..........................16

Figure 3-2. View of the Visitors Center, SERF, and Mesa-Top Facilities ..........................................25

Figure 3-3. View of Mesa-Top Facilities, FTLB, and SERF ..............................................................26

Figure 3-4. Simulated View of the Proposed RFHP, with the Proposed MTPP in the Distance ........27

Figure 3-5. Simulated View of the Proposed SolarTAC Project and Parking Area............................27

Figure 3-6. Simulated View of the Proposed MTPP from I-70...........................................................28
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ACRONYMS AND ABBREVIATIONS 

ACGIH American Conference of Governmental Industrial Hygienists 

APE area of potential effects 

BMP best management practice 

°C degree Celsius 

CCR Code of Colorado Regulations 

CDOW Colorado Division of Wildlife 

CDPHE Colorado Department of Public Health and Environment 

CFR Code of Federal Regulations 

CO carbon monoxide 

CO2 carbon dioxide 

dBA A-weighted decibel 

DOE U.S. Department of Energy 

DWOP Denver West Office Park 

EA environmental assessment 

EERE DOE’s Office of Energy Efficiency and Renewable Energy 

EPA U.S. Environmental Protection Agency 

°F degree Fahrenheit 

FTLB Field Test Laboratory Building 

I-70 Interstate 70 

IPCC Intergovernmental Panel on Climate Change 

LOS level of service 

μg/m3

 micrograms per cubic meter 

MTPP Mesa Top Photovoltaic Project 

MW megawatt 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NIOSH National Institute for Occupational Safety and Health 

NOX nitrogen oxides 

NREL National Renewable Energy Laboratory 

OSHA Occupational Safety and Health Administration 

PM10 particulate matter less than 10 microns 

PV photovoltaic 

REL recommended exposure limit 

RFHP Renewable Fuel Heating Plant 

S&TF Science and Technology Facility 

SERF Solar Energy Research Facility 

SO2 sulfur dioxide 

SOTAC Solar Technology Advancement Consortium 

SolarTAC SolarTAC Project (NREL Site) 

SVOC semivolatile organic compound 

STM South Table Mountain 

TAP toxic air pollutant 

TOC total organic carbon 

TLV threshold limit value 

USFWS U.S. Fish and Wildlife Service 

VOC volatile organic compound 
Final Environmental Assessment of Three Site Development Projects 

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EXECUTIVE SUMMARY 

Introduction 

In accordance with the Department of Energy (DOE) National Environmental Policy Act (NEPA) 

implementing regulations, DOE is required to evaluate the potential environmental impacts of DOE 

facilities, operations, and related funding decisions. DOE proposes to construct and operate three site 

development projects at the National Renewable Energy Laboratory’s (NREL) South Table Mountain 

(STM) site: 

• A Renewable Fuel Heating Plant (RFHP) that would use woodwaste as its primary fuel; 

• Various solar technology advancement installations, collectively called SolarTAC; 

• A Mesa Top Photovoltaic Project (MTPP) that would generate about 1.0 megawatt (MW) of solar 

energy for use at the STM site. 

The decision to use federal funds for these three site improvement projects requires that DOE address 

NEPA requirements and related environmental documentation and permitting requirements. In 

compliance with the NEPA (42 U.S.C. 4321) and with DOE’s NEPA implementing regulations (10 CFR 

section 1021.330) and procedures, this environmental assessment (EA) examines the potential 

environmental impacts of DOE’s decision to support this Proposed Action and also examines a No Action 

Alternative. 

In 2003, DOE issued the Final Site-Wide EA of the National Renewable Energy Laboratory’s South Table 

Mountain Complex (DOE/EA-1440). Each of the three proposed projects that are the topic of this EA 

would occur in areas that were analyzed in the site-wide EA. The site-wide EA provides the analytical 

structure to assess the potential environmental impacts of the specific Proposed Action that is the topic of 

this EA. The site-wide EA is incorporated in its entirety into this EA by reference, and this EA tiers off 

the descriptions of the affected environment and the potential environmental impact assessments 

presented in the site-wide EA. The site-wide EA is available at 

http://www.eere.energy.gov/golden/NREL_STM.aspx 

Purpose and Need 

The proposed projects would substantially reduce NREL’s use of natural gas and grid-provided 

electricity, while simultaneously advancing and contributing to commercialization of renewable energy 

technologies. 

Renewable Fuel Heating Plant. The proposed RFHP would reduce NREL’s current STM site natural 

gas consumption by an estimated 75 to 80 percent by using woodwaste to replace most natural gas usage 

in the primary site heating boiler. The project would also showcase the viability of woodwaste biomass 

fuels as an alternative to fossil fuel heating. 

SolarTAC. SolarTAC would accelerate the introduction and recognition of pre-commercial and earlycommercial solar energy technologies in the U.S. marketplace. It would support and promote the 

commercial acceptance of solar energy technologies. The SolarTAC Project would provide a launch pad 

for commercialization of solar-generating technologies in Colorado and elsewhere, such that solar 

technologies would become an increasingly important and ultimately indispensable contributor to the 

energy use profile in the United States and across the world. 
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Mesa Top Photovoltaic Project. The proposed MTPP would generate about 1.0 MW of solar electric 

energy to offset NREL’s growing energy demand. This is consistent with DOE’s long-term site 

development plans and energy goals to increase on-site renewable energy generation at the laboratory. 

Proposed Action and Alternatives 

Renewable Fuel Heating Plant. The RFHP would operate as the primary winter heat source for NREL’s 

research and support facilities and would largely replace the site’s current use of natural gas-fired boilers 

for heat. The Challenger Combustion SystemTM proposed for the plant is designed specifically for the 

combustion of solid waste fuels to optimize energy recovery and minimize air emissions. The RFHP fuel 

would consist of woodwaste such as construction waste, urban tree trimmings, pallets, and forest 

thinnings. Woodwaste acceptance criteria would be developed to ensure that contaminants and 

undesirable components were not combusted in the RFHP. At a minimum, woodwaste containing 

chemically treated, stained, painted, laminated, or otherwise altered wood products would be prohibited. 

Fuel would be delivered three to five times per week at 23 metric tons (25 tons) per load during the 

heating season. Total annual fuel consumption is estimated to be 2,722 metric tons (3,000 tons). 

The burner would be housed in a new building approximately 21 meters (70 feet) long, 11 meters 

(35 feet) wide, and 9 meters (30 feet) high. It would be constructed at the edge of a natural drainage near 

the center of the STM main campus. The building would be constructed of architectural concrete block 

similar to the finish on the existing Field Test Laboratory Building. The stack would extend 3 meters 

(10 feet) above the roof. Construction is projected to take 6 to 7 months. 

In addition to the new building, a driveway would be installed for trucks to access the building, and a 

turnaround area to facilitate delivery truck traffic flow may be installed. A wing wall would be installed at 

the end of the culvert to prevent flooding into the building’s ground floor. 

Pollution control equipment would consist of a multi-cyclone to control particulate matter. The 

combustion unit and associated equipment would be monitored and adjusted to maintain optimal 

efficiency of the pollution control equipment. The major RFHP components would have an estimated 

10- to 30-year lifetime. At the end of its useful lifetime, the RFHP would be decommissioned, removed, 

and disposed of as solid waste or recycled in a manner consistent with NREL’s facilities management and 

waste management policies applicable at that time. 

SolarTAC. The SolarTAC center would showcase and test various solar energy generation, use, control, 

and communications equipment. The area would include residential photovoltaic (PV) systems, utility PV 

systems not requiring special safety precautions, stand-alone PV systems (e.g., bus-stop shelters, remote 

lighting), and similar systems. Solar arrays and communications equipment would be installed on various 

rooftops at NREL and at other locations not accessible to SolarTAC visitors. Plans include a small solar 

demonstration house of approximately 170 to 230 square meters (1,800 to 2,500 square feet) showing 

efficient insulation; a working PV system with inverter, batteries, and appliances; and information 

displays. 

The SolarTAC center would be located primarily outdoors. It would be constructed on approximately 

0.8 hectare (2 acres) of land east of a natural drainage that lies northeast of the NREL Visitors Center. 

The site would be graded, concrete pads would be poured to support solar panels, a foundation would be 

poured for the solar demonstration house, and gravel or road base material would be installed for a 

walkway and access road. Fencing would limit access to potentially dangerous equipment. 
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A 3.6-meter (12-foot) wide contractor access and service drive terminating at a 30-meter (100-foot) 

diameter turnaround area would be constructed immediately east of the proposed main SolarTAC facility 

arrays. A new pedestrian footbridge connecting the main SolarTAC displays to the NREL Visitors Center 

would cross the natural drainageway. Ultimately, the proposed SolarTAC could include construction of a 

new 54-space parking lot in the median area located south of the existing 39-space NREL Visitors Center 

parking lot. 

Mesa Top Photovoltaic Project. The MTPP would be a PV system located adjacent to the existing Solar 

Radiation Research Laboratory. It would convert approximately 2 hectares (5 acres) of open, undeveloped 

mesa-top land to a restricted access area used for the commercial generation of solar energy. It would be 

designed to generate approximately 1.0 MW of solar energy to be used on-site by DOE. The maximum 

allowable PV panel height would be 2.4 meters (8 feet) above the ground to minimize the visual impact of 

the PV system. Concrete pads would be poured to support solar panels, and possibly to support utility 

lines if poles were used. 

The MTPP would be enclosed by a 2-meter (6-foot) chain link fence with three strands of barbed wire on 

top. Motion-activated lighting would provide safety for workers after dark and minimize night shine from 

the mesa top. Once installation was complete, the need for human presence would be rare (probably one 

visit per week for a short inspection). Interconnection to the STM site would likely be through an 

existing, spare 13.2-kilovolt/480-volt three-phase transformer with a 1-MW capacity, located near the 

middle of the proposed MTPP site. 

No Action Alternative 

The three proposed projects would not be implemented and the STM would remain in its current 

configuration. The No Action Alternative would not preclude other development projects from being 

proposed at such time as NREL determined them to be ripe for NEPA action. 

Scoping 

On April 2, 2007, a scoping/consultation letter was distributed to county, state, and federal agencies; 

organizations that may have information regarding potential environmental issues in the vicinity of the 

project site; and 1,470 Pleasant Ridge residential addresses. The only comments received were from the 

Colorado Historic Preservation Officer recommending continued coordination, an effort to which DOE is 

committed; the U.S. Fish & Wildlife Service, which expressed no concerns regarding the proposed 

actions and protected species; and the Colorado Department of Public Health and Environment, which 

acknowledged receipt of the air quality determination letter for the RFHP. 

Environmental Consequences 

The EA identified and assessed the following environmental resource areas: 

Land Use, Planning, Socioeconomics, and Public Policy 

Traffic and Circulation

Air Quality

Visual Quality/Aesthetics

Water Resources

Geology and Soils

Biological Resources and Wetlands

Cultural Resources
Final Environmental Assessment of Three Site Development Projects 

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Noise

Waste Management

Public Facilities, Services, and Utilities

Energy and Sustainability

Intentional Destructive Acts

For many of the environmental resource areas assessed in the EA, the three site improvement projects that 

make up the Proposed Action would not result in either adverse or beneficial impacts because the project 

area and surrounding area lack sensitive receptors or resource areas that would be impacted (e.g., species 

of concern; on-site perennial creeks, streams, ponds, or floodplains; cultural resources; wetlands; lowincome or minority populations; off-site noise receptors; agriculturally productive soils; or high 

commercial- or aesthetic-value geologic resources.) However, implementation of the three site 

improvement projects would result in some environmental impacts. 

The proposed RFHP would result in emissions of criteria air pollutants and toxic air pollutants (TAPs). 

Based on a dispersion modeling analysis of the proposed RFHP, emissions of criteria air pollutants would 

not exceed National Ambient Air Quality Standards (NAAQS), nor would they pose a health risk based 

on the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values 

(TLVs) or the National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure 

Limits (RELs). Although the proposed RFHP would substantially reduce the STM site’s use of and 

reliance on natural gas (a limited and increasingly expensive fossil fuel) and would reduce emissions of 

geologically sequestered carbon dioxide (CO2), it would also increase the site’s net emissions of CO2, a 

greenhouse gas. 

Collectively, the three proposed projects would result in the loss of approximately 3 hectares (8 acres) of 

grassland and shrubland habitat. The RFHP and the SolarTAC Project would be constructed in or 

adjacent to natural drainages, which are among the site’s most productive wildlife habitats and corridors. 

The drainages also support the site’s richest vegetation. The MTPP would be an extension of DOE’s 

existing mesa-top facilities. Although construction in this area was agreed to when the adjacent 

conservation easement was established in 1999, the mesa top is a sensitive environmental area where 

development is discouraged by local government and environmental interest groups. 

Construction of the three proposed facilities would result in short-term (up to 1 year) increases in on-site 

traffic, noise, fugitive dust, auto and equipment emissions, and construction debris. Operationally, the 

proposed RFHP and the MTPP would have little impact on either on-site or off-site traffic. However, the 

proposed SolarTAC Project could attract up to 500 visitors a month. This influx could further strain 

already limited on-site parking and traffic flow. Until supplemental parking for the SolarTAC was 

constructed, there could be a need for NREL visitors to park off-site and walk to the site, or for the site to 

implement shuttle bus service to accommodate visitors. 

The equipment and facilities that would be added to the STM site under the Proposed Action would not 

be unique to the site. The appearance of these facilities would in fact be similar to other buildings and PV 

panels that have been a part of the STM site for many years. As such, the addition of the RFHP, 

SolarTAC, and MTPP would add to, but would not substantially alter, the visual impact and character of 

the site. If the proposed facilities were noticed at all, the casual observer would likely note only that the 

added development resembled the structures already on the site 

The proposed actions would not result in untreated operational discharges of pollutants to surface water or 

groundwater. Drains would be connected to the site’s existing stormwater and sewage lines, and all 
Final Environmental Assessment of Three Site Development Projects 

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discharges to the publicly owned treatment works would meet the requirements of the Metro Wastewater 

Reclamation District and the Pleasant View Water and Sanitation District. 

The new construction would increase the impervious surface area, which could increase quantities of 

stormwater conveyed off-site. Management practices, including stormwater pollution prevention 

measures to minimize runoff, would be implemented to the fullest extent possible during construction to 

minimize degradation of surface water quality due to sediment and various chemicals associated with 

additional vehicles and construction equipment. 

The Proposed Action would not increase the susceptibility of the STM site to intentional destructive acts. 

The Proposed Action would be consistent with the overall objectives and mission of NREL and would 

occur within areas evaluated and committed to for further development in the 2003 site-wide EA. 
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1.0 INTRODUCTION 

The U.S. Department of Energy (DOE) proposes to construct and operate three site development projects 

at the National Renewable Energy Laboratory’s (NREL) South Table Mountain (STM) site: 

• A woodwaste-burning heating plant adjacent to the STM Field Test Laboratory Building (FTLB) 

that would use renewable fuel; 

• Various solar technology advancement installations for research and demonstration at the STM 

complex, primarily northeast of the NREL Visitors Center; 

• A solar power generation project on the STM mesa top. 

In compliance with the National Environmental Policy Act (NEPA) (42 U.S.C. §§ 4321 et seq.) and with 

DOE’s NEPA implementing regulations (Title 10 Code of Federal Regulations [CFR] Part 1021) and 

procedures, this final environmental assessment (EA) examines the potential environmental impacts, both 

individual and cumulative, of the Proposed Action. No other action alternatives are analyzed in this EA. 

For purposes of comparison, this EA also evaluates the impacts that would occur if DOE decided not to 

implement the Proposed Action (the No Action Alternative). 

This final EA has been prepared under DOE’s regulations and guidelines for compliance with NEPA. It is 

being distributed to interested members of the public and to federal, state, and local agencies for review 

and comment prior to DOE’s final decision on the Proposed Action. 

1.1 The National Environmental Policy Act and Related Procedures 

The Council on Environmental Quality regulations for implementing the procedural provisions of NEPA 

(40 CFR Parts 1500-1508) and DOE’s implementing procedures for compliance with NEPA (10 CFR 

Part 1021) require that DOE, as a federal agency: 

• Assess the environmental impacts of its proposed actions; 

• Identify any adverse environmental effects that cannot be avoided should a proposed action be 

implemented; 

• Evaluate alternatives to the proposed action, including a no action alternative; 

• Describe the relationship between local short-term uses of the environment and the maintenance 

and enhancement of long-term productivity; and 

• Characterize any irreversible and irretrievable commitments of resources that would be involved 

should the proposed action be implemented. 

These requirements must be met before a final decision is made to proceed with any proposed federal 

action that could cause significant impacts to human health or the environment. This final EA is intended 

to meet DOE’s regulatory requirements under NEPA and to provide DOE, the State of Colorado, and 

other agency decision-makers with the information they need to make informed decisions in connection 

with this Proposed Action. 
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1.2 Background 

NREL History and Research Mission 

NREL will mark its 30th anniversary in July 2007. In July 1977, DOE opened the Solar Energy Research 

Institute as a federal facility dedicated to harnessing solar power. In 1991, it achieved national laboratory 

status and was renamed the National Renewable Energy Laboratory. Today, NREL is one of 10 DOE 

national laboratories and is the nation’s primary laboratory for renewable energy and energy efficiency 

research and development. NREL’s mission is focused on advancing national energy policy and 

efficiency goals, particularly in the areas of renewable, wind, and solar energy research, development, 

demonstration, and deployment. NREL conducts research activities at the STM site in support of the 

following DOE research programs: 

• Solar energy technologies 

• Geothermal technologies 

• Distributed energy, electrical infrastructure, and reliability 

• Biomass 

• Industrial technologies 

• Freedom car and vehicle technology 

• Hydrogen, fuel cells, and infrastructure technologies 

• Buildings technologies 

• Weatherization and intergovernmental grants 

• Federal energy management 

• Other DOE-sponsored programs 

• Work for others supporting the DOE mission 

NREL is operated for DOE through a partnership between Midwest Research Institute and the Battelle 

Memorial Institute. The laboratory comprises three main sites: STM, the adjacent Denver West Office 

Park (DWOP) in Golden, Colorado, and the National Wind Technology Center located just south of 

Boulder, Colorado. The STM and DWOP sites are collectively referred to as the STM complex. The three 

site development projects that make up the Proposed Action and are the subject of this EA would be 

implemented at the STM site. Figures 1-1 and 1-2 illustrate the regional location and local setting of the 

STM site and the Proposed Action. 

1.3 Purpose and Need 

The purpose of the Proposed Action is to support and advance DOE’s mission in the research and 

development of energy efficiency and renewable energy technologies. DOE’s Office of Energy Efficiency 

and Renewable Energy (EERE) leads the national research effort to develop clean, competitive, and 

reliable energy technologies for the 21st century. The goal of the EERE program is to improve the 

nation's overall economic strength and competitiveness, energy security, and environmental stewardship 

through the development, demonstration, and deployment of clean, competitive, and reliable power 

technologies. The three STM site development projects that make up the Proposed Action would 

contribute to achieving this goal. 

Purpose of the EA 

In 2003, DOE issued the Final Site-Wide EA of the National Renewable Energy Laboratory’s South Table 

Mountain Complex (DOE/EA-1440) (DOE, 2003). That EA addressed future developments, 
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improvements, and on-site activities at the STM complex and future 

changes associated with changes to the STM site boundaries. The 

site-wide EA acknowledged that final designs and locations of some 

proposed or conceptual projects or facilities at the complex were 

uncertain and that various configurations were possible. The sitewide EA was prepared as a “bounding” analysis that would allow for 

future flexibility in implementing a range of potential activities. The 

bounding approach was used to evaluate potential environmental 

impacts resulting from an array of potential development options 

within a conceptually defined “buildout” scenario. The assessment 

considered a range of future site use and development options 

through 2008. In July 2003, DOE determined that the proposed or 

contemplated improvements assessed in the site-wide EA did not 

either individually or collectively constitute a major federal action 

significantly affecting the human environment within the meaning of NEPA. 

The site-wide EA analyzed impacts that would occur if site development occurred in areas that DOE 

believed would minimize the overall environmental impacts associated with sustainable site development. 

Moreover, it identified areas that should be set aside and preserved in a natural or existing state. Each of 

the three proposed projects that are the topic of this EA would occur in areas that were analyzed in the 

site-wide EA. DOE concluded that development in these areas would not constitute a major federal action 

significantly affecting the quality of the human environment. 

The site-wide EA provides the analytical structure to assess the potential environmental impacts of the 

specific Proposed Action that is the topic of this EA. While DOE is also considering several other site 

development projects at this time, based on the availability of funds and project-specific schedules, those 

projects are not ripe for NEPA review at this time and are not evaluated in this EA. 

The site-wide EA is incorporated in its entirety into this EA by reference, and this EA tiers off the 

descriptions of the affected environment and the potential environmental impact assessments presented in 

the site-wide EA. The site-wide EA is available at http://www.eere.energy.gov/golden/NREL_STM.aspx.. 

Within the framework of the site-wide EA, this EA assesses the impacts of implementing the following 

three proposed projects at the STM site: 

• a Renewable Fuel Heating Plant (RFHP); 

• a range of solar-generating installations advanced by the Solar Technology Advancement 

Consortium (SOTAC). SOTAC activities to be conducted at NREL are hereafter referred to as the 

SolarTAC Project. The proposed SolarTAC activities at the NREL site are the only SOTAC 

activities assessed in this EA; and 

• a Mesa Top Photovoltaic Project (MTPP). 

Purpose of the Proposed Projects 

Collectively, the proposed projects would substantially reduce NREL’s use of natural gas and gridprovided electricity, while simultaneously advancing and contributing to commercialization of renewable 

energy technologies. 

Solar Technology 

Advancement Consortium 

(SOTAC) 

SOTAC is a collaboration among 

DOE, utilities, and universities. 

The goal of the consortium is to 

provide research, education, and 

demonstration opportunities to 

accelerate the deployment of precommercial and early 

commercial solar energy 

technologies to the marketplace. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Renewable Fuel Heating Plant. The proposed RFHP would reduce NREL’s current STM site natural 

gas consumption by an estimated 75 to 80 percent and also provide some measure of insulation from the 

volatility of natural gas prices. The project would also showcase the viability of woodwaste biomass fuels 

as an alternative to fossil fuel heating. 

SolarTAC Project. The SolarTAC Project would accelerate the introduction and recognition of precommercial and early-commercial solar energy technologies in the U.S. marketplace. It would support 

and promote the commercial acceptance of solar energy technologies. The SolarTAC Project would 

provide a launch pad for commercialization of solar-generating technologies in Colorado and elsewhere, 

such that solar technologies would become an increasingly important and ultimately indispensable 

contributor to the energy use profile in the United States and across the world. 

Mesa Top Photovoltaic Project. The proposed MTPP would generate about 1.0 megawatt (MW) of solar 

electric energy to offset NREL’s growing energy demand. This is consistent with DOE’s long-term site 

development plans and energy goals to increase on-site renewable energy generation at the laboratory 

1.4 Scoping 

On November 13, 2006, DOE posted a Request for Public and Agency Comments on the Proposed RFHP 

to the DOE Golden Field Office electronic reading room. The announcement invited comments through 

January 5, 2007, and indicated that no formal public scoping meeting was planned for this project. 

On April 2, 2007, DOE posted a Request for Public and Agency Comments on the three projects that are 

the subject of this EA to the DOE Golden Field Office electronic reading room. This announcement 

indicated that no formal public scoping meeting was planned for these projects. A copy of this scoping 

letter is provided in Appendix A. DOE also mailed the scoping letter to the business, agencies, and 

organizations shown in Appendix B and to all known addresses in a nearby residential area called 

Pleasant View; the Pleasant View residential mailing list consisted of 1,470 addresses. DOE received 

three comments on the scope of the EA from federal and state agencies, which are included in 

Appendix C. 

1.5 Comments on the Draft EA 

On June 1, 2007, DOE posted a notice stating that the draft EA was available electronically on its website 

and in hard copy if requested. DOE also mailed notices of availability to the same individuals and 

organizations listed in Appendix B that received the scoping letter. The notice invited readers to comment 

on the analyses provided in the draft EA. 

DOE received three comment letters on the draft EA and has considered all comments in finalizing this 

EA. A summary of comments and DOE’s responses is provided in Appendix D. The comment letters 

necessitated only a few minor clarifications in the text and the addition of a new figure (Figure 2-2) that 

provides detailed location information for the RFHP. 
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2.0 PROPOSED ACTION AND ALTERNATIVES 

Figure 2-1 illustrates the STM and the relative locations of the three proposed projects on the site, and 

Figure 2-2 provides a more detailed layout of the RFHP. 

2.1 Renewable Fuel Heating Plant 

The RFHP would be installed in a new building approximately 21 meters (70 feet) long, 11 meters 

(35 feet) wide, and 9 meters (30 feet) high. The footprint would be approximately 185 to 230 square 

meters (2,000 to 2,500 square feet) in the area behind (north of) the FTLB. The proposed RFHP would be 

constructed at the edge of a natural drainage that provides habitat and corridor passage for wildlife and 

intermittently supports lush vegetation. Construction is projected to take 6 to 7 months. NREL policy 

stipulates that construction debris is to be recycled to the fullest extent possible in order to minimize 

impacts to local landfills. 

The building would have two levels. The ground floor would be at the existing service drive. A wood 

combustor, cyclone, hot water pumps, fuel processing equipment, fuel area, and ash hopper would be 

located on the ground floor. A boiler, expansion tank, truck access, and control room would be located on 

the mezzanine level of the building. If necessary, an enclosed walk could be installed from the FTLB 

mechanical room door to the new building to allow for easier access. The project would include 

installation of hot water distribution lines interconnecting the new facility to the Solar Energy Research 

Facility (SERF) central plant and the FTLB central plant. Detailed physical descriptions, illustrations, 

operating parameters, and economics of the proposed plant are provided in the Final Proposal, 

Renewable Fuel Heating Facility, National Renewable Energy Laboratory, Colorado (Ameresco, 2007) 

and in the On-site Impact Assessment of Proposed Renewable Fuel Heating Plant, Ameresco, NREL, 

Golden Colorado (Trinity Consultants, 2006), both of which are incorporated into this EA by reference. 

A fuel storage area would be designed to store approximately 160 cubic meters (215 cubic yards) 

(equivalent to 4 to 7 days’ worth) of woodwaste. A railed walkway would be installed on one side of the 

area to allow for access to the fuel storage pit. Motors and augers would be accessible on the other side of 

the fuel area to minimize unnecessary entry to the pit. 

Fuel would be delivered at the building’s east side, where a large overhead door would allow trucks to 

back into the fuel storage area. A concrete structure would prevent trucks from encroaching on the 

building footprint. The door would open via an electronic keypad system to limit entrance to authorized 

site personnel. A man door would also be located on the east side of the building to allow access to the 

control room when necessary. This door would be locked to limit unauthorized or unnecessary access. 

The building would be constructed of architectural concrete block. It would be finished with a moisture 

barrier and exterior insulation. The finish would be similar to the FTLB finish. The roof of the building 

would be a single-ply flat construction. The building would be insulated to meet American Society of 

Heating, Refrigerating and Air-Conditioning Engineers standards. A stack would extend 3 meters 

(10 feet) above the roof and would be approximately 56 centimeters (22 inches) in diameter. 

In addition to the new building, a driveway would be installed for trucks to access the building, requiring 

the extension of an existing culvert by 17 to 20 linear meters (55 to 65 linear feet) using 3.6-meter 

(12-foot) by 1.2-meter (4-foot) concrete block (Figure 2-2).The proposed RFHP would be constructed at 

the edge of a natural drainage area that provides habitat and corridor passage for wildlife and 

intermittently supports lush vegetation. DOE may decide to install a turnaround area to facilitate delivery 

truck traffic flow. 
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However, the decision to install a turnaround area and the relative size, if one were installed, has not yet 

been finalized. As shown on Figure 2-2, if a turnaround area were built, it would be a small extension of 

the sides of the existing road. A wing wall would be installed at the end of the culvert to prevent flooding 

into the building’s ground floor. Approximately 1,650 meters (1,800 yards) of asphalt would be poured 

over the culvert for the driveway and the turnaround area. The area over the culvert would be regraded 

with 1.5 meters (5 feet) of fill for proper site drainage. 

The RFHP would operate as the primary winter heat source to NREL’s research and support facilities. 

Heating is currently supplied by natural-gas-fired boilers, and these boilers would remain available to 

supplement or replace RFHP demand as necessary. Fuel would consist of Rocky Mountain Front Range 

woodwaste such as construction waste, urban tree trimmings, pallets, and forest thinnings. 

Equipment Description, Operation, and Specifications 

The Challenger Combustion SystemTM proposed for use in the RFHP is designed specifically for the 

combustion of solid waste fuels to optimize energy recovery and minimize air emissions. The primary 

combustion zone would be lined with high-insulating cast refractory ceramics to minimize heat transfer to 

the unit exterior. 

Woodwaste combustion would begin by directing three levels of air into the combustion zone. Primary air 

would be forced into the combustion zone from beneath the grates, where the fuel would be placed. 

Secondary air would be forced through side grates. Tertiary air would enter through the cast refractory 

located on the sides of the unit to prevent unburned fuel from exiting the unit. 

A secondary ceramic chamber operating at 900 degrees Celsius (°C) (1,650 degrees Fahrenheit [°F]) 

would be included between the primary combustion zone and the boiler to allow for an extended 

combustion zone with a 1.3-second retention time. This design would reduce carbon monoxide (CO) and 

volatile carbon emissions by more than 70 percent. The appropriate combustion temperature would be 

maintained by adjusting fuel feed, fan speed, and air intake. 

Once the fuel was combusted, the stack gas would be transitioned into a hot-water boiler. The boiler 

would be capable of producing up to 9 to 10 million British thermal units per hour of 30 pounds per 

square inch gauge hot water, or approximately 2,800 liters (750 gallons) per minute. Downstream of the 

boiler, exhaust gas would be directed through a multi-cyclone particulate separator. The exhaust gas 

would then pass through an insulated, single-skin flue and be vented to the atmosphere. 

The combustor would be designed as a dual-fuel unit and could be operated on natural gas if woodwastes 

were unavailable. In the event that heating loads in excess of the RFHP output were required, or during 

down-time due to scheduled or unscheduled maintenance, the existing natural gas boilers would be 

brought on-line as needed to meet heating load demands. Natural gas would be utilized in the RHFP 

combustor during start-up, during shut-down, and during periods when the heating load dropped too low 

for woodwaste combustion. 

Pollution control equipment would consist of a multi-cyclone to control particulate matter. The multicyclone would have a design capacity of 10,376 cubic feet per minute at 149°C (300°F). The combustion 

unit and associated equipment would be monitored and adjusted to maintain optimal efficiency of the 

pollution control equipment.

The multi-cyclone would be operated and maintained in accordance with the manufacturer’s 

recommendations and incorporated into NREL’s maintenance procedures. This would include periodic 
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at the National Renewable Energy Laboratory South Table Mountain Site 

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measurement of the system pressure drop, tube cleaning, and visual inspections for plugging, holes, 

spinner damage, and unusual wear patterns. 

Woodwaste fuel would be procured from commercial Front Range sources. Woodwaste acceptance 

criteria would be developed to ensure that contaminants and undesirable components were not combusted 

in the RFHP. At a minimum, woodwastes containing chemically treated, stained, painted, laminated, or 

otherwise altered wood products would be prohibited. Current plans call for approximately 160 cubic 

meters (215 cubic yards) of on-site fuel storage (approximately 59 metric tons [65 tons]). Fuel would be 

delivered three to five times per week at approximately 23 metric tons (25 tons) per load during the 

heating season. Total annual fuel consumption is estimated to be 2,722 metric tons (3,000 tons). 

The major RFHP components would have an estimated 10- to 30-year lifetime. At the end of its useful 

lifetime, the RFHP would be decommissioned, removed, and disposed of as solid waste or recycled in a 

manner consistent with NREL’s facilities management and waste management policies applicable at that 

time. Alternatively, equipment could be refurbished or replaced, as necessary, to continue with RFHP 

operation. 

2.2 SolarTAC Project 

The SolarTAC center would be located primarily outdoors. It would be constructed on approximately 

0.8 hectare (2 acres) of land east of a natural drainage that lies northeast of the NREL Visitors Center. 

This area lies outside the site security area and would be provided by DOE through an agreement with the 

SOTAC. 

Although buildout plans are not final, construction at the 0.8-hectare (2-acre) is estimated to take 

approximately 6 months. The site would be graded over a several-week period, concrete pads would be 

poured to support solar panels, a foundation would be poured for a solar demonstration house, and gravel 

or road base material would be installed for a walkway and access road. Management practices such as 

water spraying for dust suppression and storm water pollution prevention measures to minimize runoff 

would be identified and implemented during construction. 

The SolarTAC center would showcase and test various solar energy generation, use, control, and 

communications equipment. The area would include residential photovoltaic (PV) systems, utility PV 

systems not requiring special safety precautions, stand-alone PV systems (e.g., bus-stop shelters, remote 

lighting), and similar systems. Solar arrays and communications equipment would be installed on various 

rooftops at NREL and at other locations not accessible to SolarTAC visitors. DOE expects that initial 

system sizes would range from 1 to 50 kilowatts. 

Plans include a small solar demonstration house of approximately 170 to 230 square meters (1,800 to 

2,500 square feet) showing efficient insulation; a working PV system with inverter, batteries, and 

appliances; and information displays. A fenced-off area would control access to sensitive research 

equipment or equipment that could pose a hazard without proper training on its correct use. 

A 3.6-meter (12-foot) wide contractor access and service drive terminating at a 30-meter (100-foot)-

diameter turnaround area would be constructed immediately east of the proposed main SolarTAC facility 

arrays. This new driveway would cross a natural drainageway. The vehicle bridge would be strong 

enough to handle a fully loaded cement truck. The access would mainly be for the Fire Department, 

maintenance staff, and other service personnel. The driveway would be chained off to preclude people 

from using it for everyday access to the site.
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A new pedestrian footbridge connecting the main SolarTAC displays to the NREL Visitors Center would 

also cross the natural drainageway. The footbridge would most likely be pre-engineered and constructed 

out of Corten steel, which gains strength as it oxidizes. The bridge would continuously gain a rusty patina 

as it aged, which would help the bridge blend more naturally with the environment. 

Ultimately, the proposed SolarTAC could include construction of a new 54-space parking lot in the 

median area located south of the existing 39-space NREL Visitors Center parking lot. However, 

construction of this new parking area may be included in initial SolarTAC construction to alleviate the 

shortage of available parking. 

2.3 Mesa Top Photovoltaic Project 

The MTPP would be designed to generate approximately 1.0 MW of solar energy to be used on-site by 

DOE. The MTPP may be installed and operated by a contractor. If the project were contracted out, the 

anticipated length of the contract for operation of the system would be 20 years. If the equipment were 

still viable at the end of the 20-year period, it could continue to be used on-site. 

If implemented, the system would probably be a “single-axis design” and/or “fixed-tilt design”. For a 

single-axis design, dark-blue to black-colored panels would be installed parallel to the ground in a northsouth alignment and would rotate east (morning) to west (afternoon). The maximum allowable PV panel 

height would be 2.4 meters (8 feet) above the ground to minimize the visual impact of the PV system. If a 

fixed-tilt design were implemented, the number of panels would increase by about 15 percent, and the 

panels would be installed in rows running east-west and sloped to the south at approximately 40 degrees. 

The proposed installation would be located on approximately 2 hectares (5 acres) of flat land north and 

east of the existing Solar Radiation Research Laboratory and Solar Furnace buildings. Buildout plans are 

not final; however, construction at the site is estimated to take approximately 6 months. Although the site 

is generally flat, grading could be necessary. Concrete pads would be poured to support solar panels, and 

possibly to support utility lines if poles were used. The MTPP would be enclosed by a fence similar to the 

existing fence, which is a 2-meter (6-foot) chain link fence with three strands of barbed wire on top. 

Although there is an existing road to the site, it is likely that a new service drive would be needed within 

the 2-hectare (5-acre) site. The surface of the drive would be permeable material such as road base or 

gravel. Management practices such as water spraying for dust suppression and storm water pollution 

prevention measures to minimize runoff would be identified and implemented during construction. Once 

installation was complete, the need for human presence would be rare (probably one visit per week for a 

short inspection). 

Interconnection would likely be through an existing, spare 13.2-kilovolt/480-volt three-phase transformer 

with a 1-MW capacity. This transformer is located in the middle of the proposed MTPP site, so minimal 

electrical infrastructure would be required between the PV system and the transformer. The transformer 

ties into the NREL 13.2-kilovolt distribution system that feeds all STM site loads. New interconnection 

cables would be installed either on the ground surface, underground, or possibly on a limited number of 

new overhead utility poles and power lines. 

Security lighting would be required. DOE NREL would install lighting similar to lights currently installed 

at DOE’s existing mesa-top facilities. To minimize impacts to dark skies at night, a motion sensor would 

be installed on each light, with the timer set at a relatively short interval, such as the current interval of 

5 minutes. 
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Solar PV panels have useful lives of up to 30 years. Consequently, the panels currently in place at NREL 

and those that would be installed as part of the Proposed Action would eventually be either removed and 

disposed of as waste or recycled. PV products are generally safe for landfills, because PV materials are 

usually encased in glass or plastic, and many are insoluble. Some modules, however, could be classified 

as hazardous waste, a situation that is prompting the PV industry to develop recycling processes for 

modules. Currently, most PV panels and cells collected from NREL research and testing are disposed of 

as hazardous waste due to arsenic, cadmium, or lead content (the lead is not present in the PV panel, but 

in the solder connecting the panel to an electrical junction box). 

Because PV systems are widely dispersed, and because each system has small amounts of semiconductor 

material per cell, recycling PV materials would be a challenging task. The PV industry’s effort to develop 

recycling processes is in response to this challenge. Because solar panel disposal is in its infancy, it is not 

possible to specify how or where the MTPP panels would ultimately be disposed of or recycled. 

2.4 No Action Alternative 

Under the No Action Alternative, the three proposed projects would not be implemented and the STM 

would remain in its current configuration. The No Action Alternative would not preclude other projects 

addressed or contemplated in the site-wide EA from being proposed at such time as NREL determined 

them to be ripe for NEPA action. 

2.5 Alternatives Considered But Not Analyzed 

DOE considered alternative locations for each of the projects that make up the Proposed Action. In 

general, these alternative locations were not further analyzed because the proposed locations evaluated in 

this EA were found to be the most consistent with the overall buildout vision articulated in the site-wide 

EA. 

The proposed location for the MTPP would be much closer to the road, the spare transformer, and the 

existing utility lines than alternative locations, thereby keeping the need for new support infrastructure to 

a minimum. An alternative location for MTPP northeast of a new Science and Technology Facility 

(S&TF) was not further evaluated due to the smaller available area and the possibility of future shading 

from buildings that might be built to the south. An alternative location for the RFHP north of the roadway 

was considered. However, the proposed location for the RFHP was considered better because it is closer 

to the FTLB and SERF. Alternative locations were also considered for the SolarTAC Project; however, 

because those locations had competing proposed uses and because they were all behind the security fence, 

they were not considered further. 
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3.0 EXISTING ENVIRONMENT AND ENVIRONMENTAL IMPACTS 

General Site Description 

The 132-hectare (327-acre) STM site is located on the southeast side of STM, north of Interstate 70 (I-70) 

and west of the I-70 and Denver West Boulevard interchange in unincorporated Jefferson County near 

Golden, Colorado. The DWOP is located in the city of Lakewood. The areas surrounding the STM and 

DWOP sites are within portions of unincorporated Jefferson County, as well as the Cities of Golden and 

Lakewood in Jefferson County. The Pleasant View Metropolitan District, within unincorporated Jefferson 

County, overlies portions of each of these jurisdictions. These jurisdictions are described and illustrated in 

detail in the site-wide EA (DOE, 2003). 

Of the 132 hectares (327 acres) at the STM site, 55 hectares (136 acres) are available for development. 

A total of 72 hectares (177 acres) is protected by a conservation easement, and development on 

5.7 hectares (14 acres) is restricted by utility easements. There are currently seven laboratory facilities, a 

few small test facilities, and several support buildings on the site. The site includes acreage on the STM 

mesa top, slope, and toe and was formerly part of the Colorado National Guard facility, established 

between 1903 and 1924, at Camp George West. Figure 2-1 illustrates the STM site and the locations of 

the three proposed improvement projects that are the subject of this EA. 

The following descriptions of the existing environment and potential environmental impacts tier off and 

generally follow the structure of the site-wide EA (DOE, 2003). The descriptions of the existing 

environment in this EA summarize the descriptions found in the site-wide EA when they remain current; 

otherwise, this EA describes relevant changes since the site-wide EA was issued. Many of the impacts 

expected from the three development projects proposed in this EA are bounded by the impacts reported in 

the site-wide EA. In cases where impacts from any of the three development projects are not bounded by 

the site-wide EA (for example, air quality impacts from RFHP emissions), more detailed discussions are 

provided. 

3.1 Environmental Impacts of the Proposed Action 

3.1.1 Land Use, Planning, Socioeconomics, and Public Policy 

3.1.1.1 Existing Environment 

The descriptions of land use, planning, socioeconomics, and public policy found in the site-wide EA 

remain current and are summarized below. 

Current land use at the site includes research and development facilities, office space, support buildings, 

and testing areas. The STM complex (including the DWOP space that is leased to DOE) provides 

48,000 square meters (516,000 square feet) of facilities and workspace for approximately 1,200 workers 

(employees, temporary personnel, and contract workers). 

A 72-hectare (177-acre) conservation easement was established in 1999 in exchange for 10 hectares 

(25 acres) of developable land that is included in the 55 developable hectares (136 developable acres) on 

the southernmost portion of the site. Jefferson County is designated as the “beneficiary” of this 

conservation easement. The goals of the conservation easement are to: 

• Retain, preserve, and protect natural, scenic, ecological, and historical aspects of the conservation 

easement property; 
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• Protect the ecosystem of the STM area and the sustainable habitat for biodiverse vegetation, 

birds, and terrestrial animals; 

• Ensure the scenic and biological integration with adjoining open-space land; 

• Prevent further industrial, commercial, or residential development of the conservation easement 

property; and 

• Preserve the conservation easement property as natural open space. 

As described in the site-wide EA, DOE has established seven zones on the STM site for the management 

of ongoing and future site land use and development. The zones are illustrated in Figure 3-1. 

The RFHP would be located in Zone 4, the NREL Central Campus. This 22-hectare (55-acre) zone 

includes major DOE facilities such as SERF, FTLB, and the recently completed two-story, approximately 

6,600-square-meter (71,000-square-foot) S&TF. It also includes wet laboratories and space for research 

such as experiments with hydrogen, toxic gases, PV, biofuels, and industrial technology. This portion of 

the site is considered suitable for project demonstration and is considered the center of the STM complex. 

The proposed SolarTAC Project would be constructed partly in Zone 4 and partly in Zone 5, which is 

designated as an area where general research, development, demonstration, and support facilities could be 

located. The MTPP would be located in Zone 1, the top of the Mesa Buildable Area. This 5.3-hectare 

(13-acre) zone includes land designated for specialized research such as solar collection and solar 

radiation. Additional facilities, if any, would be of minimal size, low occupancy, and designed for 

minimal disruption to views of the mesa. There are approximately 42 hectares (105 acres) of mesa-top 

land within the STM site. Approximately 37 hectares (92 acres) of mesa-top land are within the 

conservation easement area, leaving 5 hectares (13 acres) of mesa-top land available for development. 

The mesa top is subject to various local government policies and agreements intended to limit 

development. Previous plans to develop these areas for non-DOE activities have met substantial public 

criticism, have generated broad community controversy, and/or have been denied by local government. 

As a federal agency, DOE is generally exempt from local government regulation; however, DOE is 

sensitive to local community and state concerns. It is DOE’s intent to minimize its developments on the 

mesa top, while still fulfilling its mission of research, development, and technology transfer of renewable 

energy and energy efficiency technologies. 

3.1.1.2 Impacts of the Proposed Action 

The land use, planning, socioeconomics, and public policy impacts of the three proposed site 

development projects are bounded by the discussion of impacts presented in the site-wide EA (DOE, 

2003) and are summarized below. 

Renewable Fuel Heating Plant 

The proposed RFHP would be a de-facto, free-standing annex to the existing FTLB and SERF physical 

plants. It would be situated near the center of the NREL Development Zone 4 (Central Campus), where it 

would be generally consistent with and compatible with the current land use pattern and ongoing NREL 

operations. Its construction would convert approximately 0.2 hectare (0.5 acre) of undeveloped hillside 

and drainageway land between the FTLB and the SERF to site infrastructure use. The RFHP would be 

built adjacent to the FTLB. The major land use issues at the STM (exclusive of mesa-top issues) 
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at the National Renewable Energy Laboratory South Table Mountain Site 

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primarily relate to development in close proximity to residential areas located south of Zone 3 (West 

Campus); residential areas east and west of Zone 6; a planned park located south of Zone 6; and the 

Camden Denver West condominiums located east of Zone 5. The proposed RFHP would not impact land 

use in these areas. 

SolarTAC Project 

The proposed SolarTAC Project would be built in NREL Development Zone 5 (East Campus), with some 

overlap into Zone 4, an area that is undeveloped except for the NREL Visitors Center and east entrance. 

However, Zone 5 is designated as an area where general research, development, demonstration, and 

support facilities could be located. The new installations would allow for increased research, 

development, and demonstration activities that would be consistent with existing and planned uses of 

NREL Development Zones 4 and 5. The major land use issues at the STM (exclusive of mesa-top issues) 

primarily relate to development in close proximity to residential areas located south of Zone 3 (West 

Campus); residential areas east and west of Zone 6; a planned park located south of Zone 6; and the 

Camden Denver West condominiums located east of Zone 5. SolarTAC would not impact land use in 

these sensitive areas. 

Mesa Top Photovoltaic Project 

The proposed MTPP would be located adjacent to the existing Solar Radiation Research Laboratory. It 

would convert approximately 2 hectares (5 acres) of open, undeveloped mesa-top land to a restricted 

access area used for the commercial generation of solar energy. Development of mesa-top areas for nonDOE purposes is discouraged by local government policy and has been the subject of community 

controversy. However, controversies over previous commercial proposals to develop portions of the mesa 

top for activities not related to DOE operations were in part the basis for the land transfer that resulted in 

the formation of the approximately 72-hectare (177-acre) Zone 2 conservation area and the decision to 

prevent development in Zone 7 (Non-contiguous Historic Resource Areas). For these reasons, and 

because the only new development proposed on the 5 hectares (13 acres) of Zone 1 is the MTPP, the land 

use impact on the mesa top would not be major. All of the areas that would be developed for the MTPP 

are areas that were agreed could be developed when the conservation easement was established in 1999. 

The site-wide EA determined that development within the bounding conditions of the EA would have no 

direct impacts on minority populations because no off-site human health or environmental effects of the 

Proposed Action were anticipated, and because no concentrations of minority populations were located in 

the vicinity of the site. The site-wide EA also determined that the Proposed Action would have positive 

direct and indirect economic impacts because it would create jobs and involve substantial construction 

expenditures. The socioeconomic, environmental justice, policy, and planning impacts of the three 

development projects that are the subject of this EA are bounded by the impacts described in the site-wide 

EA. 

3.1.2 Traffic and Circulation 

3.1.2.1 Existing Environment 

The description of existing traffic and circulation at the STM complex reported in the site-wide EA was 

based on consultation with local governments and the information and findings presented in a traffic 

impact study prepared by Felsburg Holt & Ullevig for the STM site in November of 2002 (NREL, 

2002a). Recently, Felsburg Holt & Ullevig have prepared a draft update of the 2002 traffic impact study 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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(NREL, 2007a). Both the 2002 traffic impact study and the 2007 update are incorporated into this EA by 

reference and are summarized below. 

Using methods documented in the Highway Capacity Manual (TRB, 2000), existing peak-hour traffic 

volumes were analyzed to determine existing operational conditions. The Highway Capacity Manual 

describes traffic operational conditions with a level of service (LOS), a qualitative measure based on the 

average delay per vehicle at a controlled intersection. LOSs are described by a letter designation of either 

A, B, C, D, E or F. A LOS “A” represents conditions with minimal delay, while a LOS “F” represents 

conditions with much longer delays. Typically, a LOS “D” or better is considered to be acceptable. The 

results of the analyses indicated that all of the study intersections currently operate at acceptable levels of 

service ranging from LOS A to LOS C during the peak hours.

3.1.2.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

During RFHP construction, there would be a temporary increase in vehicles and increased demand for 

limited on-site parking to accommodate the construction workforce, which DOE estimates would be 2 to 

3 dozen workers for 6 to 7 months. Construction-related traffic impacts are anticipated to be similar in 

nature to, although less severe than, those recently experienced at the site during construction of the 

S&TF. Temporary disruptions of on-site traffic flows and access could occur. DOE does not anticipate 

that construction of the RFHP would impact off-site traffic or parking. 

Operationally, there would be no traffic impacts because no additional personnel would be hired to 

operate the RFHP; the existing boiler plant operators would operate the RFHP as part of their work 

responsibilities. Currently, about 30 trucks per week enter the site for various deliveries. Delivery of 

woodwaste fuel and pick-up of ash would require three to five new truck trips per week during the 

October through May operating season. This would not represent a major increase over the current on-site 

truck traffic. However, the 27- to 31-metric ton (30- to 35-ton) capacity trucks that would be used to 

deliver approximately 23 metric tons (25 tons) of biomass per trip would be large. The trucks would 

unload directly into an interior pit within the RFHP structure. Truck deliveries would be arranged to be 

made Monday through Friday. The large delivery trucks could have difficulty negotiating on-site roads, 

especially when accumulated snow further constricted the roads. DOE is considering a turnaround area to 

expedite woodwaste deliveries at the RFHP. Installation of a large turnaround area would minimize any 

traffic impact such deliveries would have on on-site traffic flow. If no turnaround were installed, 

woodwaste deliveries could temporarily impede on-site traffic flow. 

SolarTAC Project 

Construction of SolarTAC would result in a short-term increase in on-site traffic caused by commuting 

construction workers. In the long term, DOE estimates that the SolarTAC Project could attract 

approximately 500 visitors per month. This could be in addition to the approximately 1,500 individual 

who currently visit the NREL Visitors Center each month. In a later phase of its implementation, the 

proposed SolarTAC would include construction of a new 54-space parking lot in the median area located 

south of the existing 39-space NREL Visitors Center parking lot. However, unless and until construction 

of the new parking area lot was complete, the increased number of visitors would probably result in the 

existing parking area often being filled to capacity. Some visitors might have to park off-site, then walk 

up the road to reach the Visitors Center or the SolarTAC. In areas where sidewalks are lacking, this could 

pose a safety risk to pedestrians. Depending on traffic and the distance to the nearest parking, the use of a 

shuttle bus to transport visitors may be required. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Mesa Top Photovoltaic Project 

Construction of the MTPP would result in a short-term increase in on-site traffic caused by commuting 

construction workers. In the long term, there would be a slight increase in traffic at the mesa top due to 

the need for weekly inspections and system maintenance. 

3.1.3 Air Quality 

3.1.3.1 Existing Environment 

Detailed descriptions of the existing air quality at the STM are provided in the site-wide EA. These 

descriptions address climate (Section 3.3.1), air quality regulatory authorities (Section 3.3.2), emissions 

sources (Section 3.3.3), and STM site permit status (Section 3.3.4). They remain current and are 

summarized or updated below. 

Air Quality 

National Ambient Air Quality Standards (NAAQS) set the absolute upper limits for specific air pollutant 

concentrations in order to protect human health. These pollutants are called criteria pollutants and consist 

of CO, nitrogen oxides (NOX), sulfur dioxide (SO2), ozone, particulate matter less than 10 microns 

(PM10), lead, and volatile organic compounds (VOCs). A geographic area that meets or exceeds the limit 

for a particular criteria pollutant is called a nonattainment area. Areas where pollutants are measured 

below the limits are called attainment areas. The Denver metropolitan area was in attainment for all 

criteria pollutants as of April 2007. 

An air emissions inventory dated July 2001 indicates that the STM site lists numerous stationary sources 

of air emissions. The sources consist of boilers, water heaters, back-up generators, building heaters, and a 

thermochemical process development unit (or thermal oxidizer) used for research activities. Emissions 

from the 2001 inventory are listed in Table 3-1. These emissions are reasonable estimates of current sitewide emissions at the STM because no major additional emitting sources have been added since the sitewide EA. 

With respect to hazardous air pollutants, the STM site emits extremely small quantities of materials from 

laboratory hoods. Examples of the source of these hazardous air pollutants include acetone, cyclohexane, 

toluene, xylene, phosphoric acid, and sulfuric acid. The emission quantities are well below notification 

and permit thresholds. Fugitive dust is also emitted from the STM and DWOP sites in the form of 

unplanned emissions that escape from a process by a route other than a stack, chimney, or vent. These 

emissions are minor. Another source of fugitive dust is windblown soil. Construction activities at the 

STM site have the potential to increase fugitive dust levels by disturbing soil.

Table 3-1. Estimated Annual Emissions at the STM Site, 2001 

Particulates SO2 NOx CO TOC Type of Air Emission 

Tons per Year 

Potential Emissions 2.86 5.18 46.41 23.21 3.63 

Estimated Emissions 0.39 0.13 5.33 3.87 0.55 

TOC = total organic carbon. 

Source: NREL, 2001. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 20 

For State of Colorado permitting requirements, a major stationary source is one that has the potential to 

emit, when operated at maximum load for 8,760 hours per year, more than 100 tons per year of any 

criteria pollutant, or more than 5 tons per year of any hazardous air pollutant. NREL is not a major source, 

and the major source permitting requirements do not apply. Operating permits may be issued for sources 

with thresholds under 100 tons per year; these are called minor sources. NREL currently is not required to 

obtain a minor source operating permit. 

3.1.3.2 Impacts of the Proposed Action 

RFHP Air Quality Impacts 

The proposed RFHP would result in emissions of the following criteria air pollutants: PM10, NOX, sulfur 

oxides, CO, and VOCs. 

The RFHP would also emit both organic and trace element toxic air pollutants (TAPs). In addition, the 

two to five woodwaste delivery trucks per week and one ash removal truck per month during the RFHP 

operating season would result in a small incremental increase in vehicle exhaust emissions at the STM 

site compared to existing emissions. 

A dispersion modeling analysis of the proposed RFHP emissions was conducted in 2006 (Trinity 

Consultants, 2006). The analysis was based on available emission factors provided by the U.S. 

Environmental Protection Agency (EPA) and vendor control data and is incorporated into this EA by 

reference. The screening dispersion modeling analysis was conducted in accordance with EPA’s 

Guideline on Air Quality Models (40 CFR 51, Appendix W) and Screening Procedures for Estimating the 

Air Quality Impact of Stationary Sources, Revised. The modeling analysis used 22 receptors located at the 

S&TF, the SERF, and the FTLB at distances ranging from 13 to 274 meters (42 to 900 feet) from the 

RFHP emission source. TAP emissions were quantified using emission factors from AP-42 for 

uncontrolled wood combustion. Although the increased residence time from the secondary combustion 

chamber would destroy most of the organic emissions, and the multi-cyclone would capture some of the 

TAP emissions, no control was assumed in the analysis. Consequently, the analysis conservatively 

overestimates the TAP emissions. 

DOE filed an Air Pollution Emission Notice and permit application package for the proposed RFHP with 

the Colorado Department of Public Health and Environment (CDPHE) on March 16, 2007 

(NREL, 2007b). In response, CDPHE has issued an initial approval for construction of the proposed 

RFHP as a minor source at a minor facility. The initial approval, shown in Appendix E, lists all applicable 

air permitting requirements for construction of the proposed RFHP and conditions that must be met for 

operation. 

As shown in Table 3-2, the predicted RFHP criteria air pollutant emissions would not exceed NAAQS. 

The dispersion modeling analysis indicated that emissions of TAPs from the RFHP would not pose a 

health risk based on the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold 

Limit Values (TLVs) and the National Institute for Occupational Safety and Health (NIOSH) 

Recommended Exposure Limits (RELs). Specifically, the analysis of emissions from the RFHP as shown 

in Table 3-3 demonstrates that the quantities of pollutants emitted would all be below, and most would be 

several orders of magnitude below, the 8-hour health-based standards. Therefore, there would be no 

impacts to the health of either on-site workers or the off-site public from RFHP emissions. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 21 

Table 3-2. Predicted Emissions Compared to NAAQS 

Pollutant Averaging 

Period 

RFHP Emissions a 

(μg/m3) 

NAAQS b 

(μg/m3) 

NO2 Annual 39 100 

Annual 4 80 

24-hour 22 365 

SO2 

3-hour 50 1300 

PM10 Annual 26 50 

24-hour 129 150 

CO 8-hour 280 10,000 

1-hour 100 40,000 

a. Source: Trinity Consultants, 2006. 

b. Source: CFR, Title 40, Part 50. 

Note: μg/m3

 = micrograms per cubic meter. 

Odor information provided by the vendor (Ameresco, 2007) indicates that noticeable levels of odors 

would be present during start-up and shut-down, corresponding to periods when the operating temperature 

is anticipated to be below 315oC (600oF) to 371oC (700oF). However, odors would be minimized by the 

planned firing of the equipment with natural gas during those periods in order to quickly bring the unit up 

to operating temperature, at which time there would be no discernible odor. If for any reason natural gas 

were not available during start-up and shut down periods, odors could be noticeable for 40 to 60 minutes. 

The woodwaste fuel supply would be contained in an enclosed building with an auger live-bottom 

delivery system. This design would prevent the woodwaste from sitting dormant and decomposing. 

Opacity information provided by the equipment manufacturer indicates that exhaust gases exiting the 

stack would not result in a visible plume at temperatures of 371oC (700oF) and above. It is anticipated that 

opacity would be less than 5 percent. Data collected by the manufacturer on a similar but smaller 

combustion unit indicated opacity at less than 2 percent. Opacity impacts would be minimized by firing 

the equipment with natural gas and quickly heating the system above 371oC (700oF). If for any reason 

natural gas were not available during start-up and shut down periods, opacity impacts could occur for 40 

to 60 minutes. 

Comparison of Greenhouse Gas Emissions 

The current NREL heating plant uses natural gas; the RFHP would predominantly use a biomass fuel 

(woodwastes), with some continued use of natural gas during start-up and shut-downs and during periods 

of low demand. Both the existing natural-gas-fired plant and the RFHP would emit the greenhouse gas 

carbon dioxide (CO2). The Third and Fourth Assessment Reports of the Intergovernmental Panel on 

Climate Change (IPCC, 2001; IPCC, 2007) provide an overview of the global effects of greenhouse gases 

that tend to warm the earth surface by absorbing some of the infrared radiation it emits. 

“The principal anthropogenic [man-made] greenhouse gas is carbon dioxide 

(CO2), whose concentration has increased by 31% since 1750 to a level which is 

likely to have not been exceeded for 20 million years. This increase is 

predominantly due to fossil fuel burning, but also to land-use change, especially 

deforestation. The other significant anthropogenic greenhouse gases are methane 

(CH4) (151% increase since 1750, 1/3 of CO2’s radiative forcing), halocarbons 

such as CFCs and their substitutes (100% anthropogenic, 1/4 of CO2’s radiative 

forcing) and nitrous oxide (N2O) (17% increase since 1750, 1/10 of CO2’s 

radiative forcing).” 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 22 

Table 3-3. Comparison of Maximum Predicted Impact to Health-Based Standards 

Pollutant RFHP Emission 

8-Hr Average (μg/m3

) 

8-Hr Health-Based 

Standard (μg/m3) 

Would this Concentration 

Present a Health 

Hazard? (Yes/No) 

Carbon monoxide 280 40,000 No 

Sulfur dioxide 39 5,000 No 

Nitrogen oxide 340 30,000 No 

VOC 7.9 29,000 No 

Carbon dioxide 240,000 9,000,000 No 

Nitrous oxide 20 46,000 No 

Acetone 0.3 1,187,730 No 

Acetophenone 0.000005 49,141 No 

Acrolein 6.2 250 No 

Benzene 6.5 1,597 No 

bis(2-ethylhexyl) phthalate 0.000073 5,000 No 

Methyl bromide (bromomethane) 0.023 3,883 No 

2-Butanone (MEK) 0.0084 589,829 No 

Carbon tetrachloride 0.07 31,456 No 

Chlorine 1.2 1,450 No 

Chlorobenzene 0.051 46,037 No 

Chloroform 0.044 48,826 No 

Chloromethane (methyl chloride) 0.036 103,247 No 

Crotonaldehyde 0.015 6,000 No 

1,2-Dichloroethane 0.045 4,000 No 

Dichloromethane 0.45 173,681 No 

1,2-Dichloropropane 0.051 350,000 No 

Ethylbenzene 0.048 434,233 No 

Formaldehyde 6.8 20 No 

Methane 33 656,033 No 

Naphthalene 0.15 52,429 No 

Pentachlorophenol 0.000008 500 No 

Phenol 0.079 19,245 No 

Styrene 3 85,202 No 

Tetrachloroethylene 0.059 169,564 No 

Toluene 1.4 188,446 No 

1,1,1-Trichloroethane 0.048 1,900,000 No 

Trichloroethylene 0.047 268,689 No 

Vinyl Chloride 0.028 2,556 No 

o-Xylene 0.039 435,000 No 

Antimony 0.012 500 No 

Arsenic 0.034 10 No 

Barium 0.26 500 No 

Beryllium 0.0017 2 No 

Cadmium 0.0064 2 No 

Chromium 0.033 500 No 

Chromium (VI) 0.0054 50 No 

Cobalt 0.01 20 No 

Copper 0.14 200 No 

Lead 0.075 50 No 

Manganese 2.5 200 No 

Mercury 0.0054 25 No 

Molybdenum 0.0033 10,000 No 

Nickel 0.051 1,500 No 

Phosphorus 0.042 100 No 

Selenium 0.0044 200 No 

Silver 2.6 10 No 

Tin 0.036 2,000 No 

Yttrium 0.00047 1,000 No 

Source: Trinity Consultants, 2006. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 23 

The IPCC (2007) attributes about three-quarters of the anthropogenic emissions of CO2 to the atmosphere 

during the past 20 years to fossil fuel burning. The rest is attributed predominantly to land-use change, 

especially deforestation. 

Table 3-4 shows that the proposed RFHP would emit more CO2, from an absolute quantity perspective, 

than is being currently emitted with natural gas firing. Therefore, a technical review of the available 

literature (Droppo and Yu, 2007) was prepared to address (1) whether, despite an increase in absolute 

CO2 emissions, the RFHP would be considered reasonable and justifiable in terms of greenhouse gas 

emissions and climate change, and (2) how the proposed RFHP combustion process emissions would 

compare with other means of disposing of or using wood chips. 

Table 3-4 compares emissions under the No Action Alternative (i.e., continued operation of the current 

natural gas heating plant), emissions from the proposed RFHP, and emissions from open burning of an 

equivalent mass of wood. 

While the available literature suggests that CO2 emissions from the RFHP would be similar to those that 

would occur from open burning of wood, it also finds that the higher combustion temperatures and 

secondary combustion systems of the RFHP would not emit the greenhouse gas methane (CH4). 

Furthermore, when compared to open burning, the proposed plant would also be desirable in terms of the 

emission of other pollutants. The comparisons in Table 3-4 indicate that open burning would significantly 

increase the emissions of CO, total particulate matter, and VOCs over the RFHP, all of which are criteria 

air pollutants. 

In terms of net CO2 in the atmosphere, the argument has been advanced, based on current scientific 

understanding on climate change processes, that burning wood chips is much more desirable than burning 

a fuel that contains carbon that has been sequestered underground. The CO2 from wood chip combustion 

has a “net zero” emission rate based on factors in EPA’s AP-42 (EPA, 2007). The “net zero” emission 

Table 3-4. Comparison of Emissions: Current Plant, Proposed Plant, and Open Burning 

Proposed RFHP Emission Rate Computed for the Combustion 

of an Equivalent Mass of Wood 

No Action 

(Natural 

Gas) Total from 

Wood and 

Natural Gas 

Wood 

Portion 

Natural 

Gas 

Portion 

Rocky 

Mountain 

Wildfire 

Forest 

Burning AP42 Emission 

Factors (a)

Forest 

Wastes 

Burning AP42 Emission 

Factors (b)

Sundance Fire 

Emission 

Factors from 

Ward and 

Hardy (1991) 

Modeled 

Emissions from 

Eight Major 

California Forest 

Fires (Clinton et 

al., 2006) 

Emission 

Gas 

Tons per Year 

CO 2.06 1.93 1.40 0.53 270 176-380 590 340 - 381 

SO2 0.015 0.586 0.583 0.004 Not listed Not listed Not listed 3.3 -3.6 

NOx 2.45 5.75 5.13 0.63 7.9 Not listed 27 10 - 12 

PM 0.186 5.17 5.13 0.048 33 7.8 – 33 74 Not listed 

PM10 0.047 4.67 4.66 0.012 Not listed Not listed Not listed 35 - 39 

VOC 0.135 0.074 0.040 0.035 47 7.8 - 37 Not listed 24 - 25 

CO2 2,941 5,297 4,544 753 Not listed Not listed 6,030 4,450 – 4,910 

CH4 (c) (c) (c) (c) Not listed Not listed 2.5 - 6.4 14 - 15 

a. Estimated based on Rocky Mountain wildfire forest burning emission factors (AP-42, Table 13.1-3) [EPA, 2007]. 

b. Estimated based on forest wastes burning emission factors (AP-42, Table 2.5-5) [EPA, 2007]. 

c. No value listed; expected to be negligible. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 24 

rate is based on an assumption that CO2 from burning wood from forests represents no increase in the net 

amount of CO2 in the atmosphere. A cycling of carbon between the atmosphere and forests results in no 

net gain or loss of airborne CO2. On the other hand, CO2 from burning natural gas represents an increase 

in the net amount of atmospheric CO2 from the introduction of “new” carbon that has been sequestered 

underground for millennia or longer. Thus, the primary argument supporting the proposed RFHP is to 

reduce the introduction of new carbon into the current atmospheric carbon cycle. 

It should be noted, however, that based on a recent Supreme Court ruling, the EPA’s decision basis for 

not regulating CO2 and other greenhouse gases may change [Massachusetts v. U.S. Environmental 

Protection Agency, 549 U.S. __ (2007) (slip opinion dated April 2, 2007)]. According to the ruling, 

EPA’s action not to regulate greenhouse gas emissions was “arbitrary, capricious, or otherwise not in 

accordance with law”. Under the ruling, EPA must reconsider its decision and ground its reasons for 

action or inaction in the Clean Air Act statute. The ruling states that unless EPA can show that CO2 is not 

involved in the global warming seen around the world, the EPA should regulate it. Given the timing of 

this decision and the fact that the ruling was made in the context of regulating greenhouse gases from new 

motor vehicles, at this time it is too speculative to estimate what actions EPA may take, or what 

regulations might be promulgated, that might affect the RFHP. 

From the viewpoint of minimizing impacts on global climate change, the burning of wood chips also 

tends to be more desirable than the common alterative use of wood chips in composting activities and 

landfilling. Although there is great variability and uncertainty in the published emission rates, the gaseous 

emission from open burning, composting, and landfilling tend to have much larger emissions of 

greenhouse gases, and specifically larger fractions of gases such as methane and ammonia, than the 

proposed process for burning woodwastes. The published source terms for open burning show the RFHP 

option to be preferable from the viewpoint of having lower emissions. Of particular importance are mixes 

of combustion products from these activities. For example, because methane is currently thought to be 

many times more effective for inducing climate changes than CO2, the potentially higher methane levels 

from open burning, composting, and landfilling make these activities less desirable from the viewpoint of 

minimizing the potential impact of greenhouse gas emissions (Droppo and Yu, 2007). 

SolarTAC Air Quality Impacts 

Construction of the SolarTAC may involve scraping and grading up to 0.8 hectare (2 acres) of land, 

which would result in intermittent fugitive dust emissions for up to 6 months. NREL’s standard 

procedures require that construction dust be controlled by spraying or other means to minimize on-site 

and off-site dust. There would also be short-term or intermittent vehicle emissions from construction, 

visitors, and routine maintenance visits. Operations at the proposed SolarTAC would not result in 

emissions of regulated air pollutants. 

MTPP Air Quality Impacts 

Construction of the MTPP may involve scraping and grading up to 2 hectares (5 acres) of land, which 

would result in intermittent fugitive dust emissions for up to 6 months. Dust would be controlled or 

reduced by spraying and other techniques. There would also be short-term or intermittent vehicle 

emissions from construction, visitors, and routine maintenance visits. Operations at the proposed MTPP 

would not result in emissions of regulated air pollutants. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 25 

3.1.4 Visual Quality/Aesthetics 

3.1.4.1 Existing Environment 

With the exception of the recently constructed S&TF, the narrative descriptions and figures illustrating 

the visual and aesthetic environment of the STM presented in the site-wide EA remain current and are 

summarized below. Figures 3-2 and 3-3 illustrate the overall visual environment at the STM complex in 

2007. 

The dominant visual characteristics of the existing STM site include the prominent slope and mesa top 

associated with STM; the DOE facilities located on top of STM; and the SERF, FTLB, S&TF, and 

Visitors Center located at the toe of the slope. The STM site buildings are prominent against the 

landscape of STM. Other less prominent buildings occur at the western end of the site. 

The STM site facilities are designed to reflect the laboratory activities related to modern energy concepts. 

Three of the larger buildings—the SERF, FTLB, and S&TF—are terraced and set against the south slope 

of STM. In addition to the buildings at the STM central campus, DOE has constructed a variety of solar 

testing and measurement structures such as the High Flux Solar Furnace, Solar Radiation Research 

Laboratory, and numerous PV panels situated throughout the site. 

The facilities located on top of STM cover only a small proportion of the overall STM mesa top. The 

remainder of the mesa top is almost entirely undeveloped and is part of the conservation easement 

delineated by Zone 2. DOE’s solar furnace and the surrounding buildings in Zone 1 are visible from offsite locations. A Colorado State Patrol driver training track is also located on top of the mesa, but it is not 

visible from most off-site locations. Other natural areas on the mesa top are within designated Jefferson 

County open space areas or NREL’s on-site conservation area (Zone 2). 

View looking northwest toward STM (telephoto). 

Figure 3-2. View of the Visitors Center, SERF, and Mesa-Top Facilities 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 26 

View from the 6th Avenue frontage road (telephoto). 

Figure 3-3. View of Mesa-Top Facilities, FTLB, and SERF 

3.1.4.2 Impacts of the Proposed Action 

The equipment and facilities that would be added to the STM site under the Proposed Action would not 

be unique to the site. The appearance of these facilities would in fact be similar to other buildings and PV 

panels that have been a part of the STM site for many years. As such, the addition of the RFHP, 

SolarTAC, and MTPP would not alter the current visual character of the site. If the proposed facilities 

were noticed at all, the casual observer would likely note only that the added development resembled the 

structures already on the site. Figures 3-4 through 3-6 provide simulated views of the proposed facilities. 

Renewable Fuel Heating Plant 

The RFHP would be similar in height to the FTLB and, from most off-site observation points, would be 

partially blocked from view by the FTLB. Constructed of the same architectural concrete block as the 

FTLB, its color and texture would blend into the overall view. Figure 3-4 is a simulation of the view 

looking north from the south side of the STM site with the RFHP added. From this vantage point, without 

artificial magnification, the RFHP would be almost indiscernible. As described in Section 3.1.3, at normal 

operating temperatures, no visible plume would exit the RFHP stack. 

SolarTAC Project 

SolarTAC would alter the near-field existing view by installing arrays of PV panels over 0.8 hectare 

(2 acres) of undeveloped area adjacent to and behind the current Visitors Center and converting the 

median in front of the Visitors Center into a parking area (Figure 3-5). Arranged in rows ascending the 

gradual slope of the SolarTAC site, the PV panels would be somewhat consistent in form to the terraced 

appearance of the SERF located nearby and would be similar in appearance to PV panels located 

elsewhere on the STM site. Viewed from a distance, SolarTAC would blend with the overall appearance 

of the STM site and would not represent a unique addition to the site’s overall visual impression. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 27 

Figure 3-4. Simulated View of the Proposed RFHP, with the Proposed MTPP in the Distance 

Figure 3-5. Simulated View of the Proposed SolarTAC Project and Parking Area 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 28 

Figure 3-6. Simulated View of the Proposed MTPP from I-70 

Mesa Top Photovoltaic Project 

The MTPP would be located atop the mesa at about 6,000 feet above sea level. Due to the steepness of the 

mesa’s slope, the MTPP would be almost undetectable by anyone viewing the site from any location 

lower than the mesa top. The terrain within 3 kilometers (2 miles) of the STM site is less than 6,000 feet 

in elevation; therefore, anyone within that area would not see the MTPP. 

As shown in the simulation on Figure 3-4, the MTPP, although remote, would be viewed by residents 

south of the STM site as a dark thin linear feature along the edge of the mesa top adjacent to the already 

existing solar radiation research facilities. Extending approximately 300 to 600 meters (1,000 to 2,000 

feet) along the edge of the mesa top, the MTPP would be visually unique among the miles of undeveloped 

mesa edge atop STM. As viewed by drivers traveling east on I-70 (Figure 3-6), the MTPP would be 

virtually indistinguishable on the horizon. 

3.1.5 Water Resources 

3.1.5.1 Existing Environment 

The descriptions of water resources found in the site-wide EA remain current and are summarized below. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 29 

Surface Water 

There are no perennial creeks, streams, ponds, or floodplains on the STM site. Surface water, when 

present, is not used by NREL. There may be seasonal seeps on the STM site after small amounts of 

surface water percolate through the soil or the fractured basalt that caps STM. Intermittent storms and 

other seasonal precipitation events may cause water to temporarily collect in topographic lows and 

drainages. Surface water may briefly collect in depressions formed in the basalt on the top of the mesa. 

Groundwater 

Groundwater monitoring is not required of NREL by a regulatory agency; however, monitoring wells 

were installed at the STM site, and groundwater baseline data were accumulated beginning in 1990. The 

monitoring wells have since been capped. The most recent groundwater monitoring data were obtained in 

1997. That year, groundwater beneath the site was analyzed for VOCs, semivolatile organic compounds 

(SVOCs), total metals, pesticides, and herbicides. Results of the analysis indicated that the groundwater 

beneath STM is uncontaminated for VOCs, SVOCs, pesticides, and herbicides. Although the samples 

indicated that concentrations of manganese and iron were elevated, the concentrations were within 

naturally occurring variations and no constituent concentrations exceeded national primary drinking water 

standards. 

3.1.5.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

The RFHP would not result in untreated operational discharges of pollutants to surface water or 

groundwater. The RFHP drains would be connected to the site’s existing stormwater and sewage lines, 

and all discharges to the publicly owned treatment works would meet the requirements of the Metro 

Wastewater Reclamation District and the Pleasant View Water and Sanitation District. 

The RFHP would increase the impervious surface area, which could increase quantities of stormwater 

conveyed off-site, increase runoff rates, and incrementally degrade surface water quality. Increased 

turbidity and quantities of various chemicals associated with additional vehicles and construction 

equipment would occur. 

Changes in the quantity of stormwater and runoff rates could incrementally impact localized on-site 

flooding; however, implementation of stormwater pollution prevention measures would minimize off-site 

drainage impacts. During the design process, drainage structures would be designed on-site to minimize 

the increase in the flow rate of stormwater conveyed off-site. Stormwater impacts would be minimized by 

complying with the provisions of NREL’s EPA-issued National Pollutant Discharge Elimination System 

general construction permit. If groundwater were encountered during excavations for the plant, it would 

be pumped from the excavation to a vegetated area rather than into drainage. The vegetated areas would 

act as filters to trap sediment and reduce impacts associated with groundwater disposal. 

SolarTAC Project 

The description of surface water resource impacts provided above for the RFHP are applicable to 

SolarTAC. There would be no impacts to groundwater. The SolarTAC installation and operations would 

result in an increased number of visitor automobiles entering the site. Traces of petroleum products 

originating from leaking vehicles could be transported from the pavement off-site via stormwater. These 

contaminants could contribute to water quality degradation. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 30 

Mesa Top Photovoltaic Project 

The description of surface water resource impacts provided for SolarTAC are also applicable to the 

MTPP. There would be no impacts to groundwater. 

3.1.6 Geology and Soils 

3.1.6.1 Existing Environment 

The detailed descriptions of the site geology and soils found in the site-wide EA remain current and are 

summarized below. 

The STM is located on the gently sloping terrain of the Foothills Province of the Rocky Mountain Front 

Range between the Southern Rocky Mountain Province to the west and Great Plains Province to the east. 

Denver clay loam and Denver cobbly clay loam dominate the soils at STM site where the RFHP and 

SolarTAC installations would be constructed; Lavina loam dominates on the mesa top. Slopes are 

generally less than 9 percent. The STM site is classified as being in Seismic Zone 1, an area of low 

seismic risk. Structures to be built on the STM site would meet the most current Uniform Building Code 

standards appropriate for its designated seismic zone. 

3.1.6.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

Potential geological impacts would closely resemble the geological impacts presented in the site-wide 

EA, which specifically considered construction of the nearby S&TF and other comparable site 

developments. The RFHP would be constructed into a hillside. An area of approximately 185 to 

230 square meters (2,000 to 2,500 square feet) would be disturbed. A geotechnical survey and soil 

sampling were performed on the proposed RFHP site during the planning phase. The report findings were 

used to develop structural designs and determine site preparation and construction requirements. Prior to 

building installation, the site would be excavated as needed for building construction. Resources such as 

concrete aggregate and crushed rock would be required during construction of the RFHP. These materials 

would be obtained from off-site commercial sources or may involve use of material from on-site 

excavations. Excavation may occur below the alluvial surface. Excavation could conceivably go below 

the alluvium if reaching bedrock for stability were necessary. It is unlikely that RFHP construction would 

increase landslide potential at the construction site or elsewhere at the STM site in the future because 

there is no evidence of recent landslides on the south side of STM, and no on-site or off-site construction 

in the immediate vicinity of the STM site has caused slope instability. The necessary excavation into the 

hillside would apply the most current engineering design specifications to avoid slope-stability impacts. 

The RFHP design would include drainage features to ensure stability of the structure, prevent flooding, 

and facilitate installation of an entrance drive. 

SolarTAC Project 

Construction activities associated with the SolarTAC installations would be primarily aboveground, 

surface, or shallow below-ground installations and would not impact existing geologic resources. 

Installation of new SolarTAC facilities, a driveway, and a parking area would disturb approximately 

2 hectares (5 acres) of topsoil. Where installations required removal of topsoil, it would be stockpiled for 

reuse, removed, or redistributed on the site by the contractor. Some soils would be lost due to the physical 

alteration of the existing soil profile. However, the site’s soil is nonproductive from an agricultural 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 31 

standpoint; therefore, the loss of these soils would not represent a major impact. DOE would import fill 

and/or topsoil, if necessary. 

Mesa Top Photovoltaic Project 

Construction activities on the mesa top could disturb the basalt layer that underlies the thin 

(approximately 13-centimeter [5-inch]) Lavina loam soil layer. Electrical interconnection would be 

through an existing, spare transformer. This transformer is located in the middle of the proposed MTPP 

site, so only minimal excavation, or blasting if new utility poles were erected, would be required. 

Approximately 2 hectares (5 acres) of Lavina loam on the mesa top could be disturbed during installation 

of the MTPP panels. Disturbing the soil as a result of construction activities could increase the potential 

for soil particles to be scattered by the wind. Erosion caused by water on mesa-top construction sites 

would be very minor because the mesa top is relatively flat. 

3.1.7 Biological Resources and Wetlands 

3.1.7.1 Existing Environment 

The descriptions of biological resources and wetlands found in the site-wide EA remain current and are 

summarized below. These descriptions relied upon previous reporting and fieldwork performed by 

various consultants at the STM site over the past 16 years, as well as fieldwork conducted in May 2002. 

Additional biological resource information is available in the following reports. 

• Wildlife Survey (Including Migratory Birds and Raptors) at the National Renewable Energy 

Laboratory South Table Mountain Site, Golden, Colorado (NREL, 2005); 

• Vegetation Survey, NREL South Table Mountain Site (NREL, 2002b); 

• National Renewable Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory 

(NREL, 1999); 

• South Table Mountain Conservation Easement Baseline Inventory (NREL, 1998). 

Located at the base of the foothills to the Rocky Mountains, the STM site occurs at elevations ranging 

from 1,762 meters (5,780 feet) to 1,838 meters (6,030 feet) above mean sea level. This coincides with the 

interface between two ecological provinces: the Great Plains-Palouse Dry Steppe Province to the east, and 

the Southern Rocky Mountain Steppe – Open Woodland – Coniferous Forest – Alpine Meadow Province 

to the west. 

Three primary plant communities occur within the proposed project areas at the STM site: grasslands, 

shrublands, and one very small wetland. Table 3-4 in the site-wide EA lists the vegetation types and their 

areal extent; Figure 3.8 in the site-wide EA depicts the locations of these different vegetation types. 

Noxious weeds occur in all vegetation types. The RFHP would be built on previously disturbed and 

ravine shrub habitat, SolarTAC would be installed on mixed grass habitat, and the MTPP would be 

installed on disturbed mesa top land and short grass habitat. Table 3-5 shows variations of these three 

primary types of vegetation and their approximate distributions at the site. 

As shown in Figure 3-9 of the site-wide EA, there are no wetlands in development Zone 1 (top of mesa 

buildable area) and none in the vicinity of the proposed SolarTAC installations. There is one very small 

14-square-meter ([150-square-foot]) palustrine emergent wetland (STM-6) immediately behind 
Final Environmental Assessment of Three Site Development Projects 

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Table 3-5. Vegetation Types at NREL, STM Site, Golden, Colorado 

Vegetation Type Area (Acres) Percent of Site 

Short grass grassland 124 37.9 

Mixed grass grassland 103 31.4 

Tall shrubland 19 5.8 

Short shrubland 16 4.9 

Ravine shrubland 5 1.5 

Wetland <1 0.1 

Disturbed/reclaimed 32 9.8 

Developed 28 8.6 

TOTAL 327 100 

Source: NREL, 2002b. 

Note: To convert acres to hectares, multiply by 0.4. 

(northwest of) the SERF and several hundred feet east of and on the opposite side of the ravine from the 

proposed RFHP site. 

Wildlife habitat at the STM site is almost exclusively grassland and shrubland. The Colorado Division of 

Wildlife (CDOW) has estimated that these habitats may support up to 14 reptile species, 36 mammal 

species, 82 bird species, and 4 amphibian species. 

A wildlife study of the STM was conducted in 1987. The demographics of the area surrounding the STM 

site have changed since that study, and additional development of the STM site has since occurred. At the 

request of NREL, Science Applications International Corporation began a four-season wildlife survey of 

the STM site in the spring of 2004 to update the 1987 data. The 2005 wildlife survey (NREL, 2005) is 

incorporated into this EA by reference; the findings are summarized below. The wildlife survey also 

includes recommendations for consideration during normal site operations and future construction 

projects to minimize adverse impacts to wildlife. These recommendations would be reviewed and 

implemented to the fullest extent possible before and during implementation of the Proposed Action. 

Migratory Birds and Raptors 

Many species of migratory birds occur on the STM site, with many of these species potentially nesting 

on-site. In addition, the STM site may provide important migration and winter habitat for migratory birds. 

Habitat for migrating birds is important, as some of these species may migrate as far south as Central and 

South America. 

Several species of raptors were observed at the STM site, and two species were observed during both 

wildlife surveys (1987 and 2004-2005) nesting on-site: the red-tailed hawk and the American kestrel. 

Both of these species were observed hunting on-site during the 2004-2005 surveys, in addition to the 

Cooper’s hawk. The NREL STM site provides habitat and a prey base of small birds and small mammals 

for these raptor species. Species such as the Swainson’s hawk migrate thousands of miles each year, 

wintering as far south as Argentina and returning to the western United States and Canada to breed. Areas 

such as the STM site may provide a prey source for the Swainson’s hawk and other species during 

migration. 
Final Environmental Assessment of Three Site Development Projects 

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Large Mammals 

Mule deer at the STM site have been observed in all habitat types. Mule deer were often observed in the 

amphitheater drainage or in the tall shrubland on slopes. 

Predators 

Coyotes are one of the most widespread and adaptable carnivores in North America. They occur at all 

elevation levels and in all ecosystems in Colorado. Rabbits and rodents are an important part of the 

coyote’s diet, both of which are abundant on the STM site. Evidence of predation on cottontail rabbits 

(i.e., entrails and fur) was observed during site visits. Coyotes may breed on the STM site, as two 

potential dens were observed on-site in drainage areas. 

Small Mammals 

The deer mouse is the most common small mammal on the NREL STM site. Deer mice can occur 

wherever cover occurs and were observed in the vegetation types sampled on the STM site. This species 

is a generalist and is known to exploit disturbed habitats. Mexican woodrats and prairie voles were more 

restricted than the deer mouse in the habitats they occupied on the STM site. Mexican woodrats are 

associated with rocky slopes and do not build dens away from rocky areas. This species is therefore 

limited as to where it can occur on the STM site. Prairie voles are adapted to the grasslands, constructing 

burrows and runway systems throughout the grassland, essentially limiting this species to the short grass 

and mixed grass vegetation types on the STM site. All of these species are active throughout the year. 

Reptiles/Amphibians 

Several rattlesnakes were observed on the STM site, more often in rocky areas, but also in the grassland. 

A rattlesnake den may be present in the rocks near the top of the mesa slope north of the Visitors Center; 

four rattlesnakes were observed within a few feet of each other, one in the open and three in a rock 

crevice. Hibernation generally occurs in rock outcrops, with this species usually active from mid-April 

through late-September. Although only three species of reptiles and one species of amphibian were 

observed on the STM site, no specific survey methods were employed to identify or count these groups of 

wildlife at STM. 

Species of Concern 

For this EA, a species of concern is defined as those species protected under federal statute, including the 

Endangered Species Act of 1973, as amended; the Bald Eagle Protection Act of 1940, as amended; and 

the CDOW list of endangered, threatened, and wildlife species of concern. Federal agencies are also 

required to abide by the Migratory Bird Treaty Act of 1918, as amended. 

The 2005 survey included a review of the U.S. Fish and Wildlife Service (USFWS) proposed, 

endangered, threatened, experimental, and candidate species and habitat list (USFWS, 2004) and the 

CDOW listing of endangered, threatened and wildlife species of special concern list (CDOW, 2003) for 

species observed on the STM site. No species observed on the STM site during the 1987 or the 2004-2005 

wildlife surveys were present on either agency’s list. However, golden eagles were incidentally observed 

on the STM site (outside of raptor surveys) and are protected under the Bald Eagle Protection Act. Golden 

eagles were observed flying over the site and may use the site for hunting. No golden eagle nests or 

nesting activities were observed on the STM site. 
Final Environmental Assessment of Three Site Development Projects 

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3.1.7.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

The RFHP would be located on previously disturbed land adjacent to a major site road and between the 

FTLB and the SERF. Land clearing, excavation, and construction staging areas would degrade the habitat 

value of the adjacent drainageway. Four standing trees would be destroyed, relocated, or replaced. The 

disturbed area that is not permanently lost as habitat due to new construction would probably have an 

increased susceptibility to noxious weed invasion (discussed further under impacts from the SolarTAC 

installations and MTPP below). If a truck turnaround area were added, there would be a small increase 

(less than an acre) of additional habitat loss. The small wetland area behind the SERF would not be 

impacted by construction or operation of the RFHP. 

SolarTAC Project 

The SolarTAC Project would result in direct, permanent loss of up to 0.8 hectare (2 acres) of mixed grass 

and shrub habitat in Zones 4 and 5. This loss would adversely impact wildlife that currently use the 

habitat. Wildlife impacts from habitat losses would not be major because (1) substantial wildlife habitat 

has been protected on-site and off-site in the project vicinity, and (2) no species of concern have been 

documented within the habitat that would be lost. Secondary impacts due to the loss of this habitat would 

reduce the overall size of local hunting areas of resident mammalian and avian predators such as coyotes, 

fox, red-tailed hawks, and owls. In addition, loss of habitat in Zones 4 and 5 would reduce habitat 

connectivity for land-based animals between the conservation easement in Zone 2 and Lena Gulch, 

located just south of the site at Camp George West. Local populations of mule deer, coyotes, and other 

species that have relatively large foraging areas may be adversely affected by this loss. 

Land clearing and the installation of SolarTAC and MTPP facilities could disturb some existing 

vegetation, making the areas more susceptible to noxious weed invasion. Noxious weeds such as Canada 

thistle, diffuse knapweed, musk thistle, houndstongue, field bindweed, common teasel, jointed goatgrass, 

and dalmatian toadflax occur on the site and are found on either the list of the 10 most widespread 

noxious weeds in the State of Colorado or on Jefferson County’s list of noxious weeds of concern. The 

potential spread of these species, as well as cheatgrass and the other 12 noxious weed species found at the 

STM site, into disturbed areas represents secondary impacts as a result of the Proposed Action. DOE has 

made efforts to combat noxious weed invasion. These efforts include implementation of a noxious weed 

management plan which, among other strategies, calls for the use of a native grassland seed mix to be 

used in restoration areas after construction. 

Mesa Top Photovoltaic Project 

The MTPP would result in direct, permanent loss of up to 2 hectares (5 acres) of mixed grass and shrub 

habitat in Zone 1. This would adversely impact wildlife that currently uses the habitat. Wildlife impacts 

from habitat losses would not be major because (1) substantial wildlife habitat has been protected on-site 

and off-site in the project vicinity, and (2) no species of concern have been documented within the habitat 

that would be lost. Secondary impacts due to the loss of this grassland habitat would reduce the overall 

size of local hunting areas of resident mammalian and avian predators such as coyotes, fox, red-tailed 

hawks, and owls. 

Land clearing and the installation of MTPP facilities could disturb some existing vegetation, making the 

areas more susceptible to noxious weed invasion. Noxious weeds such as Canada thistle, diffuse 

knapweed, musk thistle, houndstongue, field bindweed, common teasel, jointed goatgrass, and dalmatian 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 35 

toadflax occur on the site and are found on either the list of the 10 most widespread noxious weeds in the 

State of Colorado or on Jefferson County’s list of noxious weeds of concern. The potential spread of these 

species, as well as cheatgrass and the other 12 noxious weed species found at the STM site, into disturbed 

areas represents secondary impacts as a result of the Proposed Action. DOE has made efforts to combat 

noxious weed invasion. These efforts include implementation of a noxious weed management plan, which 

calls for the use of a native grassland seed mix to be used in restoration areas after construction. 

3.1.8 Cultural Resources 

3.1.8.1 Existing Environment 

There are no known significant prehistoric archaeological resources within or adjacent to the NREL STM 

property. There are no known significant traditional cultural resources within or adjacent to the STM site. 

Should any evidence of archaeological or cultural resources be discovered at any time during any grounddisturbing activities at the STM site, all work would stop in the vicinity until a qualified archaeologist 

completely evaluated the significance of the find according to criteria established by the National Register 

of Historic Places. 

DOE completed a file search for the entire STM site in June 2005. As a result, eight previously recorded 

features were identified in the STM vicinity (Nelson, 1980). A Class III intensive survey conducted in 

April 2007 identified no other cultural resources in the Proposed Action areas (Rhodes, 2007). 

There are four significant or contributing historic structures on the STM property. Two of these resources, 

the amphitheater and associated footbridge (5JF842) and the ammunition igloo (5JF843), are located in 

Zone 7 (Non-contiguous Historic Resource Areas) and are individually listed on the National Register. 

The remaining resources are within the Camp George West Historic District and contribute to the 

District’s eligibility. These resources are located in Zone 6 and were recorded to the Level II Historic 

American Building Survey/Historic American Engineering Record standards in January 2006 (Rhodes, 

2006) (see Figure 3-1). 

The historic amphitheater is an ovate stone structure built into the natural slope of the hillside with a stone 

projection booth located at the base of the structure. A concrete center aisle separates the theater’s 

concrete and stone seating areas. Some of the associated rock walls and seats have collapsed, and much of 

the area is overgrown with native vegetation. A small stone footbridge leads to the amphitheater. The 

bridge is in good condition. Outside groups have expressed an interest in restoring both of these historic 

structures, but no formal proposal has been submitted. The ammunition igloo dates from World War II. 

3.1.8.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

The RFHP would be constructed in a drainage setting between the existing FTLB and the existing SERF. 

The ammunition igloo is the nearest historic property to this proposed development site but is well 

beyond the proposed area of potential effects (APE). The igloo is located approximately 60 meters 

(180 feet) to the northeast, on the other side of the road. The amphitheater is located up the drainage 

northwest of the proposed RFHP, but none of the recorded features associated with the amphitheater are 

within 100 meters (300 feet) of the proposed facility. Neither the ammunition igloo nor the amphitheater 

would be impacted by the Proposed Action. 
Final Environmental Assessment of Three Site Development Projects 

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SolarTAC Project 

The SolarTAC Center would be located just northeast of the Visitors Center. The SolarTAC is not within 

100 meters (300 feet) of any historic property. One feature was identified in the vicinity by Nelson 

(1980). This feature, consisting of check dams, is located more than 100 meters (300 feet) from the 

proposed development site, in a drainage to the east. This feature would not be impacted by the Proposed 

Action. 

Mesa Top Photovoltaic Project 

The MTPP would occupy a portion of the mesa top above the amphitheater. At the closest point, the 

proposed project area boundary is approximately 40 meters (130 feet) above the historic property. At the 

farthest point, the boundary is over 100 meters (300 feet) away. The mesa top and the amphitheater are 

visually separated by a significant drop in elevation of at least 12 meters (40 feet) at the closest point. The 

amphitheater is well beyond the APE of this Proposed Action and would not be impacted. 

Based on the results of the recent literature search and Class III intensive survey, as well as previous 

surveys and consultations, DOE has determined that the Proposed Action would have no effect on cultural 

resources. A letter confirming the State Historic Preservation Officer’s (SHPO’s) concurrence with a 

finding of “no historic properties affected” is included in Appendix C. 

3.1.9 Noise 

3.1.9.1 Existing Environment 

Detailed descriptions of the existing noise environments at the STM are provided in the site-wide EA. 

These descriptions address sensitive noise receptors (Section 3.4.1), existing noise levels (Section 3.4.2) 

and noise regulations and guidelines (Section 3.4.3). They remain current and are summarized or updated 

below. 

Noise receptors located in the immediate vicinity of the STM site include STM personnel, inhabitants of 

residences to the east and south of the site boundary, and wildlife. With respect to NREL personnel, DOE 

has accepted the Occupational Safety and Health Administration (OSHA) noise regulations and 

guidelines for worker exposure and manages compliance with them. These regulations and guidelines 

focus on noise from machinery, equipment, and tools. DOE maintains compliance with all regulations 

related to worker health and safety. 

Other sensitive receptors in the vicinity include multi-family residences located approximately 15 meters 

(50 feet) east of the site boundary. Two subdivisions composed of single-family residences are located 

south of the STM site. The nearest residence to the site’s southwestern boundary is located approximately 

15 meters (50 feet) away. The nearest residence to the site’s southeastern boundary is located 

approximately 30 meters (100 feet) away. The nearest school, church, or day-care center is about a half 

mile from the site, near 20th and Denver West Parkway. A ball field was recently completed in the open 

area immediately south of the STM site. 

Although noise measurements were not taken for the site-wide EA and noise modeling was not 

performed, site observations indicate that the acoustic environment within the boundaries of the 

southeastern portion of the site can be considered similar to that of an urban location. I-70 is a significant 

noise source throughout the day and during sensitive late-night and early-morning periods. Noise levels 

on the mesa top are typical of a rural location but can be elevated substantially when an adjacent State 
Final Environmental Assessment of Three Site Development Projects 

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 37 

Highway Patrol driver-training track is being used. It is estimated that 24-hour day-night average sound 

levels on the site typically range from 40 to 60 A-weighted decibels (dBA). Most activity and mechanical 

operations at the STM site are conducted within buildings. Construction activity and routine maintenance 

occasionally generate noise. The proposed new park will become another source of noise in the vicinity. 

The State of Colorado Noise Statute (Code of Colorado Regulations [CCR] 25-12-101 through CCR 

25-12-109) has established state-wide standards for noise level limits for various time periods and areas. 

The standards exclude federal entities such as NREL; however, they can be used as guidelines in order to 

evaluate impacts. The most stringent permissible noise levels apply to residential zones, where the 

maximum permissible daytime (7 a.m. to 7 p.m.) noise level is 55 dBA and the noise level is measured at 

a distance of 8 meters (25 feet) from the property line. In addition, construction projects are limited to 

permit conditions or 80 dBA for the period within which the construction is to be completed or a 

reasonable amount of time. 

The City of Denver has promulgated a noise ordinance, Revised Municipal Code, City and County of 

Denver, Colorado, Ordinance No. 628-97, 22 September 1997, Supplement No. 55 (City and County of 

Denver, 1997) that can provide another basis for evaluating noise levels. The type of premises on which 

the noise is generated determines allowable noise levels. In the case of the STM site, the most 

conservative approach is to consider it “industrial premises.” The maximum allowable sound pressure 

level under the Denver ordinance is 80 dBA measured at the site property line between the hours of 7 a.m. 

and 10 p.m.

3.1.9.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

The RFHP would be installed inside a building, so operational noise impacts to the surrounding area 

would be partially attenuated. Table 3-6 shows the major equipment involved in the operation of the 

RFHP that would be heard in the building and approximate decibel levels associated with the equipment. 

Operation of the proposed RFHP would incrementally increase the ambient nose at the STM site. 

Compliance with OSHA requirements for noise exposure is a site mandate. Noise impacts to RFHP 

operators would be reduced by the use of hearing protection equipment as required by OSHA standards or 

as requested by RFHP operators. 

Levels of ambient or intrusive outdoor noise vary extensively at distances greater than about 100 meters 

(330 feet) from the source. This variation is caused by changes in weather and by topographical features 

such as ground cover, hills, trees, structures, and other obstacles between the noise source and the 

Table 3-6. RFHP Equipment Noise Levels 

RFHP Equipment Estimated Indoor Noise Level 

Grinder 85 dBa maximum 

Hot Water Pumps < 49 dBa 

Fans and Ventilation System < 48 dBa 

Augers Minimal 

Screener Minimal 

Source: Ameresco, 2007. 
Final Environmental Assessment of Three Site Development Projects 

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receptor. A rule of thumb (the “Rule of 6”) is that under ideal conditions (no background sound or 

interference), a sound level drops 6 dBa for every doubling of the distance from the source (AEUB, 

2007). The nearest off-site noise receptors to the proposed RFHP noise source would be homes in the 

northeast corner of the Whiteaker subdivision and the northwest corner of the Richards Heights 

subdivision. Both of these off-site receptor areas lie approximately 300 meters (1,000 feet) from the 

proposed location of the RFHP. There are structures between the noise source and the receptors, and the 

receptors are on the other side of the Denver West Parkway. These factors make it difficult to quantify the 

noise impact from the proposed RFHP at these locations. However, applying the Rule of 6 and assuming 

the wood grinder, the loudest source of noise at the RFHP, could generate 85 dBa at a distance of 

10 meters (30 feet), the noise level at the nearest off-site receptors would be approximately 45 dBa. This 

is a conservative (probably high) estimate of off-site noise because the grinder would be housed in a 

building, which would attenuate the noise perceived by off-site receptors. For comparison, 45 dBA is 

approximately the ambient noise level in quiet agricultural areas (EPA, 1978). The noise from the RFHP 

grinder, which would be intermittent, would probably not be noticeable over ambient residential 

neighborhood, street, and highway noise. 

SolarTAC and MTPP Noise Impacts 

Noise impacts due to construction of the SolarTac and MTPP would be similar to those described in detail 

in the site-wide EA (DOE, 2003). Construction-related noise would be expected to occur intermittently 

for the approximately 6 months that the facilities would be under construction. Operation of the proposed 

SolarTAC and MTPP facilities would not result in major increases to existing ambient noise at the STM. 

3.1.10 Waste Management 

3.1.10.1 Existing Environment 

The descriptions of the existing waste management environment found in the site-wide EA remain 

generally current and are summarized or updated below. 

The STM generates a variety of hazardous and non-hazardous wastes from laboratory and mission 

support activities. All waste-handling and disposal activities at both sites comply with the requirements 

and regulations of OSHA, the Resource Conservation and Recovery Act, DOE, and the CDPHE. All 

hazardous wastes are packaged and disposed of through contracted off-site commercial treatment, 

disposal, and recycling firms. Many of the hazardous wastes generated on-site are recycled in accordance 

with CDPHE regulations, including such items as batteries, fluorescent bulbs, and computer monitors. As 

a best management practice (BMP) in order to ensure maximal protection of the environment, many of 

the non-hazardous waste materials (non-regulated waste) generated at the sites are treated in the same 

manner as the hazardous wastes. These materials, although not classified as hazardous, are also recycled 

or disposed of at off-site commercial treatment, storage, disposal, and recycling facilities. 

The STM site is a small-quantity generator, which means that the facility generates more than 

100 kilograms (220.5 pounds) but less than 1,000 kilograms (2,205 pounds) of hazardous waste per 

month. The STM site does not maintain an on-site waste disposal facility. The amount of hazardous and 

non-regulated waste generated by the STM site in recent years is shown in Table 3-7. 
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Table 3-7. Waste Generation at the STM Site, 2003-2006 

Amount Generated 

Category of Waste (gross weight in pounds) 

2003 2004 2005 2006 

Hazardous waste 21,725 19,631 33,370 31,539

Non-regulated waste 5,469 1,645 11,345 7,492 

Note: To convert pounds to kilograms, multiply by 0.45. 

3.1.10.2 Impacts of the Proposed Action 

Renewable Fuel Heating Plant 

RFHP construction would be short-term (approximately 6 to 7 months) and would not substantially 

increase the amounts or types of hazardous materials generated or maintained at the site. In the case of a 

spill or release of chemicals or hydrocarbons during construction activities, existing BMPs and 

procedures associated with spill response and materials handling would minimize impacts to surface 

water. These procedures are defined in the NREL Spill Prevention Control and Countermeasures (SPCC) 

Plan for the STM (NREL, 2006) (Procedure 6.2-10). Any construction debris that could not be recycled 

would temporarily increase the weight and volume of non-regulated waste generated at the site. 

RFHP operations would not generate hazardous waste or non-regulated waste. The ash generated by the 

RFHP would be considered recycled waste, a separate waste category from either hazardous or nonregulated waste. Based on vendor-provided data (Ameresco, 2007), the biomass fuel would be 2 percent 

to 3 percent ash, and the total quantity of RFHP ash generated during an average heating season would be 

83 to 136 metric tons (92 to 150 tons). The ash would be picked up weekly during the peak winter months 

and two to three times a month during non-peak operating months. The ash would be recycled for use in 

mulching mixes or shipped for use in concrete manufacturing. If the ash could not be recycled, it would 

be disposed of off-site at a commercial landfill. Because the STM is located near a very large 

metropolitan area, this increase in landfill waste would not represent a significant impact to regional 

waste management (storage and disposal) operations or capacities. 

SolarTAC Project 

Neither the construction nor the operation of SolarTAC would result in the generation of significant 

quantities of hazardous or non-regulated waste. Any construction debris that could not be recycled would 

temporarily increase the weight and volume of non-regulated waste generated at the site. 

Mesa Top Photovoltaic Project 

Neither the construction nor the operation of the MTPP would result in the generation of significant 

quantities of hazardous or non-regulated waste. Any construction debris that could not be recycled would 

temporarily increase the weight and volume of non-regulated waste generated at the site. 

3.1.11 Public Facilities, Services, and Utilities 

3.1.11.1 Existing Environment 

The detailed descriptions of public facilities, services, and utilities found in the site-wide EA remain 

current. 
Final Environmental Assessment of Three Site Development Projects 

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3.1.11.2 Impacts of the Proposed Action 

The following discussion addresses the impacts of the Proposed Action on the capacity of public 

infrastructure and service providers. Any requisite utility interconnection interruptions during 

construction or operation would be temporary and would be coordinated in advance with the cognizant 

utilities. 

The RFHP and MTPP would have a substantial net positive impact on electric and gas utility 

infrastructure because they would reduce the overall current and projected future demand the STM site 

places on local and regional public utility infrastructures for delivery of natural gas (RFHP) and gridgenerated electricity (MTPP) to the STM site. The RFHP and SolarTAC installations would result in a 

small overall increase in the STM site’s net electric power usage, but this increase would be more than 

offset by the overall decrease in demand for grid-generated power. 

Collectively, the three proposed improvement projects would represent a very minor increase in demand 

for telecommunications, domestic water, or sewage service due to the very low number of additional 

employees and other personnel at the STM site. 

The new facilities and additional staff associated with the Proposed Action would incrementally increase 

demand for police, fire, and ambulance services, but the increases would be considered minor given site 

use, on-site security, and anticipated needs for emergency service providers. 

Because the RFHP would be a wood-burning boiler, it would slightly increase the risk of wildfire on the 

site. The NREL Fire Protection Program currently addresses this and other fire risks. The RFHP proposal 

includes a dry pipe fire suppression system and an alarm system. The potential for particulate emissions 

would be mitigated by a multi-cyclone system. The plant would automatically shut down if the induced 

draft fan serving the cyclone were to fail. 

3.1.12 Energy and Sustainability 

The discussion of energy and sustainability found in the site-wide EA remains current and is applicable to 

the SolarTAC and MTPP projects, which are intended to make a substantial contribution to energy 

efficiency and renewable (sustainable) energy technology. The magnitude of these beneficial impacts 

could range from minor to globally significant, depending on the technology achievements resulting from 

the projects. These direct benefits would also result in indirect and/or secondary beneficial impacts to the 

environment, including, but not limited to, reduced air pollution as compared to emissions generated with 

conventional energy technologies. The RFHP would use renewable biomass in place of a fossil fuel 

whose availability is finite. 

3.1.13 Intentional Destructive Acts 

In December 2006, the DOE Office of General Counsel (formerly the Office of NEPA Policy and 

Compliance) issued interim guidance stipulating that each DOE EIS and EA should explicitly consider 

intentional destructive acts (i.e., acts of sabotage or terrorism). DOE applied a sliding scale in considering 

the potential impacts of intentional destructive acts within the context of the Proposed Action. 

None of the three proposed site improvement projects that are the subject of this EA would involve the 

transportation, storage, or use of radioactive, explosive, or toxic materials. Consequently, it is highly 

unlikely that the projects making up the Proposed Action would be viewed as a potential target by 

saboteurs or terrorists. The wood that would fuel the proposed RFHP is necessarily combustible but it is 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 41 

neither explosive nor highly flammable. The limited quantities of wood that would be stockpiled, the 

facility’s fire suppression and alarm system, and the limited access to the fuel storage pit would limit the 

attractiveness of the facility to saboteurs or terrorists. 

Vandalism of the MTPP PV panels on the mesa top by so-called “eco-terrorists” is a more credible 

intentionally destructive act scenario. However, such vandalism, while potentially disruptive of NREL 

operations, would not pose a risk of adverse impacts to human life, health, or safety. Moreover, the mesatop facilities would be protected by a security fence and motion-sensitive night lighting. In summary, the 

Proposed Action does not appear to offer any targets of opportunity for terrorists or saboteurs to inflict 

significant adverse impacts to human life, heath, or safety. 

3.2 Environmental Consequences of the No Action Alternative 

The environmental consequences of the No Action Alternative would be very similar, and in some 

instances identical, to the Environmental Consequences of the No Action Alternative presented in the 

site-wide EA. These are summarized or updated below. 

Under the No Action Alternative: 

• Existing on-site land uses, site development density, and operations would not change. Fewer 

beneficial economic impacts would result because RFHP, SolarTAC , and MTPP construction 

would not occur, and related job growth and NREL development would be limited. 

• The minor incremental impacts to traffic and parking from site construction and increased visitors 

to SolarTAC installations associated with the Proposed Action would be avoided. An additional 

three to five weekly RFHP fuel-delivery trucks and ash pick-up trucks would not traverse the site 

from October through April. 

• Emissions of criteria air pollutants and TAPs from RFHP operations would not occur. Existing 

emissions from on-site operations would remain at current levels. 

• A new ambient noise source (the RFHP) would not be added to the STM site. Off-site noise 

levels in the area would continue to be dominated by vehicle traffic on I-70.

• There would be no impacts to surface water, stormwater, or groundwater resources. 

• The loss of approximately 3 hectares (7 acres) of grassland habitat on the mesa top and north of 

the NREL Visitors Center would not occur. 

• The site would not generate 83 to 136 metric tons (92 to 150 tons) of non-regulated RFHP ash as 

a waste stream. The quantities and types of hazardous materials and hazardous wastes associated 

with the site would remain consistent with current amounts. 

• The No Action Alternative would limit demand growth for public services and utilities by 

retaining existing employment levels and operational activity at current levels. New facilities and 

modification and expansion of existing facilities would not occur. Incremental capacity impacts 

on existing service providers resulting from the Proposed Action and the impacts of associated 

infrastructure improvements would be avoided.
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 42 

• The STM site’s energy production capacity and energy consumption would remain at current 

levels. The site would not benefit from replacement of up to 80 percent of its natural gas with 

renewable biomass fuel for winter heating, nor would it augment its current electric power 

demand with up to 1 MW of solar power. 

• There would be no improvements made to the middle drainageway. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 43 

4.0 CUMULATIVE AND SECONDARY IMPACTS 

Cumulative impacts result from the incremental impact of a proposed action when added to other past, 

present, and reasonably foreseeable future actions. Secondary impacts are those that are caused by a 

proposed action, but may occur later in time or farther removed in distance, relative to the primary 

impacts of the proposed action (40 CFR section 1508.7). 

The 2003 site-wide EA considered cumulative and secondary impacts of various pending and conceptual 

site development projects and concluded that the incremental contribution to these cumulative and 

secondary impact areas would be insignificant. That EA also concluded that the No Action Alternative 

would not contribute to these impacts. The most important examples of cumulative and secondary 

impacts associated with the site-wide EA Proposed Action were as follows: 

• Traffic congestion at the intersections along Denver West Marriott Boulevard; 

• Regional and local air pollutant emissions; 

• Noise impacts on Pleasant View neighborhoods; 

• Development intensification; 

• Increases in Lena Gulch stormwater flows; 

• Habitat losses from development of natural areas; 

• Demand for energy; and 

• Beneficial impacts from improved alternative energy sources. 

The three proposed site improvement projects that are the subject of this EA were not sufficiently far 

along in their conceptualization to be explicitly discussed in the site-wide EA. However, with the 

exception of visual impacts, the preceding list of cumulative and secondary impact areas bounds those 

that would be associated with these three proposed projects. The following discussions describe the 

potential for the Proposed Action in this EA to result in cumulative and secondary impacts. 

Visual impacts. Construction and operation of the three projects described as the Proposed Action in this 

EA would slightly modify the overall visual impression of the STM by adding facilities on 3 hectares 

(7 acres) of land that is planned for development but is not yet developed. The new development would 

be visually compatible with the STM site. Additionally, commercial development continues to occur 

adjacent to the STM site, altering the visual landscape from open space to offices and residential 

buildings. 

Traffic congestion at the intersections along Denver West Marriott Boulevard. The estimated construction 

workforce for the proposed projects would not be large, nor would the proposed construction be longterm. Construction of the RFHP would only require an estimated 2 to 3 dozen workers for 6 to 7 months. 

No new workers would be hired to operate the RFHP. The proposed SolarTAC could increase the number 

of visitors to the STM site by an estimated 500 per month, or on average about 20 visitors a day. 

However, some visitors to the SolarTAC would car pool, and visitors would not necessarily arrive and 

leave during rush hour. DOE does not expect the three proposed projects to change the current LOS at the 

intersections along Denver West Marriott Boulevard. However, if additional parking were not included in 

Phase I of the SolarTAC Project, vistors could be required to park off-site, ride shuttle buses, or walk in 

the street, which could pose a pedestrian hazard. 

Regional and local air pollutant emissions. Air quality in the Denver metropolitan area has been poor in 

the past but has improved in recent years to the point where the metropolitan area has been redesignated 

as an attainment area. The RFHP’s emissions would not be expected to have any meaningful impact on 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 44 

the metropolitan area’s air quality or attainment designation. However, air pollutant concentrations in the 

metro area are relatively close to the standard for ozone and other pollutants, so every source is 

scrutinized. Given the potential air quality benefits of renewable energy and energy efficiency research to 

be performed at the site, the overall net impact of the three projects on cumulative air quality in the region 

and locally would probably be neutral. The MTPP and SolarTAC would provide a net advantage to air 

quality by harnessing non-polluting solar power, while the RFHP would result in an increase in some 

emissions of criteria air pollutants and hazardous air pollutants. 

Noise impacts on Pleasant View neighborhoods. Noise generated during construction, from vehicle use 

on the site, and from RFHP operations is not expected to cause noise levels that would exceed any 

cumulative noise impact standard. 

Development intensification. The Proposed Action includes new development and improvements on the 

mesa, but it does not create unplanned development or present the potential to open up new off-site areas 

for development. It does not create improved access to real estate, reduce development restrictions, or 

substantially induce new development in unanticipated areas. 

Increases in Lena Gulch stormwater flows, Stormwater flooding in Lena Gulch is created by an off-site 

channel constriction in Camp George West Park. The proposed projects would increase the impervious 

surface area on the STM site. However, DOE does not anticipate this would have any impact on 

stormwater flow in Lena Gulch because a new stormwater retention pond has recently been added at 

Camp George West Park. Improvements to the middle drainage stormwater management infrastructure 

that would be installed as part of the proposed RFHP construction would further reduce the potential for 

increases in Lena Gulch stormwater flows. 

Habitat losses from development of natural areas. The Proposed Action would not have direct impacts on 

protected species or habitats (wetlands) that are the subject of regulations approved to address cumulative 

impacts on biological resources. However, the projects could impact migratory bird species. 

Demand for energy and beneficial impacts from improved alternative energy sources. All projects 

requiring energy have incremental impacts related to energy, but very few offer the possibility of making 

a positive contribution toward renewable energy and energy efficiency. The MTPP and the SolarTAC 

Project are specifically intended to advance the use and acceptance of renewable energy and to enhance 

energy efficiency. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 45 

5.0 COMMITMENT OF RESOURCES AND SHORT-TERM USES 

The discussions in Sections 5.1 and 5.2 below were presented in the site-wide EA and are directly 

applicable to the Proposed Action that is the subject of this EA. 

5.1 Irreversible/Irretrievable Commitment of Resources 

An irreversible commitment of resources is defined as the loss of future options. The term applies 

primarily to the effects of use of nonrenewable resources such as minerals or cultural resources, or to 

those factors such as soil productivity that are renewable only over long periods. It could also apply to the 

loss of an experience as an indirect effect of a “permanent” change in the nature or character of the land. 

An irretrievable commitment of resources is defined as the loss of production, harvest, or use of natural 

resources. The amount of production forgone is irretrievable, but the action is not irreversible. If the use 

changes, it is possible to resume production. 

The Proposed Action would not have irreversible impacts because future options for using this site would 

remain possible. A future decommissioning process could restore the site for alternative uses, ranging 

from natural open space to urban development. No loss of future options would occur. 

The primary irretrievable impacts of the Proposed Action would involve the use of energy, labor, 

materials, and funds, and the conversion of some lands from a natural condition through the construction 

of buildings and facilities. Irretrievable impacts would occur as a result of construction, facility operation, 

and maintenance activities. Direct losses of biological productivity and the use of natural resources from 

these impacts would be inconsequential. 

5.2 The Relationship between Local Short-Term Uses of the Human Environment and the 

Maintenance and Enhancement of Long-Term Productivity 

This section addresses the commitment of resources associated with the Proposed Action relative to the 

loss of long-term productivity associated with these commitments. 

The Proposed Action would commit resources in the form of energy, labor, materials, funds, and land 

over 20 years or more. The justification for these commitments at this time is described in Section 1.3, 

Purpose and Need. Long-term productivity associated with the site relates to biological value as habitat 

and open-space values associated with aesthetic quality and recreation. The Proposed Action would be 

implemented at a site where substantial portions of the land are specifically reserved and preserved for 

these purposes. For these reasons, the incremental loss of biological and open-space values is balanced by 

the protections afforded to the long-term productivity of the site. Improved efficiency and increased 

reliance on renewable energy resources could substantially reduce reliance on coal, oil, and nuclear fuels 

and reduce resource productivity losses in off-site resource extraction areas. The Proposed Action would 

create no long-term risks to public health and safety. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 46 

6.0 REFERENCES 

AEUB (Alberta Energy and Utilities Board). 2007. Directive 038, Noise Control. Pg 41. February 2007. 

http://www.eub.gov.ab.ca/bbs/documents/directives/Directive038.pdf. 

Ameresco (Ameresco Federal Solutions). 2007. Final Proposal, Renewable Fuel Heating Facility, 

National Renewable Energy Laboratory, CO. 

CDOW (Colorado Division of Wildlife). 2003. Colorado Listing of Endangered, Threatened and Wildlife 

Species of Special Concern. Updated April, 2003. Available at 

http://wildlife.state.co.us/species_cons/list.asp. Accessed April 13, 2005. 

City and County of Denver. 1997. Revised Municipal Code, Ordinance No. 628-97, 22, Supplement 

No. 55, September 1997. 

Clinton, NE, P. Gong, and K. Scott. 2006. “Quantification of pollutants emitted from very large wildland 

fires in Southern California, USA,” Atmos. Environ., 40(20), pp. 3686-3695. 

DOE (U.S. Department of Energy). 2003. Final Site-Wide EA of the National Renewable Energy 

Laboratory’s South Table Mountain Complex. DOE/EA-1440. July 2003. 

Droppo, J.G., and Yu, X.Y. 2007. Evaluation of Replacing Natural Gas Heat Plant with a Biomass Heat 

Plant. Technical Report by Pacific Northwest National Laboratory to the Department of Energy, May 

2007. 

EPA (U.S. Environmental Protection Agency). 1978. “Protective Noise Levels: Condensed Version of 

EPA Levels Document.” EPA 550/9-79-100. Available at 

http://www.nonoise.org/library/levels/levels.htm. 

EPA (U.S. Environmental Protection Agency). 2007. “Emissions Factors & AP 42.” Technology Transfer 

Network: Clearinghouse for Inventories & Emissions Factors. Available at 

http://www.epa.gov/ttn/chief/ap42/. 

IPCC (Intergovernmental Panel on Climate Change). 2001. “Mitigation. Contribution of Working Group 

III to the Third Assessment Report of the Intergovernmental Panel on Climate Change.” 

IPCC (Intergovernmental Panel on Climate Change). 2007. “Climate Change 2007: The Physical Science 

Basis: Summary for Policymakers. Contribution of Working Group I to the Fourth Assessment 

Report of the Intergovernmental Panel on Climate Change”. 

Massachusetts v. U.S. Environmental Protection Agency, 549 U.S. __ (2007) (slip opinion dated April 2, 

2007). 

Nelson, Sarah M. 1980. “Historic and Prehistoric Resources, South Table Mountain, Golden, Colorado.” 

NREL (National Renewable Energy Laboratory). 1998. South Table Mountain Conservation Easement 

Baseline Inventory. Prepared by ERO Resources Corporation, Denver, CO. 

NREL (National Renewable Energy Laboratory). 1999. National Renewable Energy Laboratory (NREL) 

Site Conservation Easement Baseline Inventory. Prepared by Dames & Moore. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 47 

NREL (National Renewable Energy Laboratory). 2001. South Table Mountain Emissions Inventory. July. 

NREL (National Renewable Energy Laboratory). 2002a. South Table Mountain Facility, Traffic Impact 

Study. Prepared by Felsburg Holt and Ullevig (FHU). FHU Reference No. 02-150. November. 

NREL (National Renewable Energy Laboratory). 2002b. Vegetation Survey, NREL South Table Mountain 

Site. Prepared by Plantae Consulting Services, Boulder, CO. June. 

NREL (National Renewable Energy Laboratory). 2005. Wildlife Survey (Including Migratory Birds and 

Raptors) at the National Renewable Energy Laboratory South Table Mountain Site Golden, 

Colorado. Prepared by Science Applications International Corporation. June 2005. 

NREL (National Renewable Energy Laboratory). 2006. Spill Prevention Control and Countermeasures 

for the South Table Mountain Site (Procedure No. 6-2.10). June. 

NREL (National Renewable Energy Laboratory). 2007a. “Draft Update South Table Mountain Facility, 

Traffic Impact Study.” Prepared by Felsburg Holt and Ullevig (FHU). FHU Reference No. 

NREL (National Renewable Energy Laboratory). 2007b. Letter of transmittal for the Air Pollution 

Emission Notice (APEN) and permit application package for the proposed RFHP with the Colorado 

Department of Public Health and Environment, March 16, 2007. 

Rhodes, Lori. 2006. Camp George West Level II Historic American Building Survey/Historic American 

Engineering Record (HABS/HAER) Documentation. 

Rhodes, Lori. 2007. Class III Cultural Resources Inventory of the Proposed Renewable Fuel Heating 

Plant, Solar Technology Advancement Consortium, and Solar Electric Generation Project on the 

NREL STM site, Jefferson County, Colorado. Limited-Results Cultural Resources Survey Form. 

TRB (Transportation Research Board). 2000. Highway Capacity Manual, third edition. 

Trinity Consultants. 2006. On-Site Impact Assessment of Proposed Renewable Fuel Heating Plant 

Ameresco, NREL, Golden, Colorado. 

U.S. Fish and Wildlife Service (USFWS). 2004. “Federally Listed and Proposed, Endangered, 

Threatened, Experimental, and Candidate Species and Habitat in Colorado by County.” Updated 

August 2004. Available at: http://mountain-prairie.fws.gov/endspp/CountyLists/COLORADO.htm. 

Accessed April 13, 2005. 

Ward, D.E., and C.C. Hardy. 1991. “Smoke emissions from wildland fires.” Environment International 

17 (1991), pp. 117–134. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-1 

APPENDIX A SCOPING LETTER 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-2 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-3 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-4 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-5 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-6 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-7 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-8 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 A-9 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-1 

APPENDIX B SCOPING LETTER DISTRIBUTION LISTS 

DOE mailed the scoping letter shown in Appendix A to the businesses, agencies, and organizations 

shown in the following mailing list. In addition, DOE mailed the scoping letter to all known Pleasant 

View residential addresses. The residential mailing list consisted of 1,470 addresses. 

4-U Mini Mart 

15750 S. Golden Rd. 

Golden, CO 80401 

 7-Eleven 

16400 S. Golden Rd. 

Golden, CO 80401 

Absolute Tatoo 

15750 S. Golden Rd. 

Golden, CO 80401 

AC Transmission 

15435 W. Colfax Ave 

Golden, CO 80401 

 Ace Liquor Store 

16265 S. Golden Rd. 

Golden, CO 80401 

Adolph Coors Company 

1819 Denver West Drive 

Golden, CO 80401 

Advantage Appraisals Inc. 

795 McIntyre St. 

Golden, CO 80401 

 AMS 

10433 Denver West Parkway 

Golden, CO 80401 

Anderson Services 

1125 Quaker St. 

Golden, CO 80401 

Back Talk System 

14998 W. 6th Ave., 500 

Golden, CO 80401 

 Barnes & Noble 

14371 W. Colfax Ave. 

Golden, CO 80401 

Bed Bath & Beyond 

14275 W. Colfax Ave. 

Golden, CO 80401 

Bilg's Delicatessen 

16400 S. Golden Rd. 

Golden, CO 80401 

 Bldg. 3 

15850 W. 6th Ave 

Golden, CO 80401 

Bobcat of the Rockies 

15680 W. 6th Ave. 

Golden, CO 80401 

Boston Market, Inc. 

14103 Denver West Parkway 

Golden, CO 80401 

 Environmental Compliance 

Office Bureau of Land 

Management 

2850 Younfield Street 

Lakewood, CO 80215 

Calvary Baptist Church 

17050 S. Golden Rd. 

Golden, CO 80401 

Howard Roitman CDPHE 

Office of Environmental Programs 

4300 Cherry Creek Drive, South 

Denver, CO 80246 

 Margie Perkins, Division 

Director CDPHE 

Air Pollution Control Division 

4300 Cherry Creek Drive, South 

Denver, CO 80246-1530 

Steve Gunderson, Division 

Director CDPHE 

Water Quality Control Division 

4300 Cherry Creek Drive, South 

Denver, CO 80246-1530 

Centennial Equipment Co. 

15760 W. 6th Ave 

Golden, CO 80401 

 Christy Sports 

14371 W. Colfax Ave. 

Golden, CO 80401 

Mr. Vince Auriemma City of 

Golden 

Golden Public Works Office 

1445 10th Street 

Golden, CO 80401 

Ms. Katie Fendel City of Golden 

Golden Public Works Office 

911 10th Street 

Golden, CO 80401 

 Ms. Pamela Sheldon City of 

Lakewood Planning Department 

455 S. Allison Parkway 

Lakewood, CO 80226 

Classic Log Homes 

15740 W 6th Ave. 

Golden, CO 80401 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-2 

CMC Challenge-Mfg-Consult 

15744 W 6th Ave 

Golden, CO 80401 

 Coleman Coporation 

Dept. 586 (Real Estate) 

PO Box 2931 

Wichita, KS 67201 

Colorado Business Bank 

15710 W. Colfax Ave. 

Golden, CO 80401 

Colorado Concrete & Pottery 

16601 S. Golden Rd. 

Golden, CO 80401 

 Dr. Dana L. Winkelman, Director 

Colorado Coop Fish & Wildlife 

Research Unit 

201 JVK Wagar Building 

CSU Campus Delivery 1484 

Fort Collins, CO 80523-148 

Mr. Jim Miller Colorado 

Department of Agriculture 

Dir. Of Policy & 

Communication 

700 Kipling Street, Suite 4000 

Lakewood, CO 80215 

Ms. Linda Coulter Colorado 

Department of Agriculture 

700 Kipling Street, Suite 4000 

Lakewood, CO 80215 

 Mr. Curt Eckhart Colorado 

Department of Transportation, 

Region 6 Office 

2000 South Holly Street 

Denver, CO 80222 

Colorado Dept. of Natural 

Resources 

Executive Director's Office 

1313 Sherman Street, 

Room 718 

Denver, CO 80203 

Colorado Dept. of Public Health & 

Environment 

Haz. Materials & Waste Mgmt Div. 

4300 Cherry Creek Drive, South 

Denver, CO 80246-1530 

 Mr. Gerald Craig Colorado 

Division of Wildlife 

State Raptor Biologist 

317 Prospect Road 

Fort Collins, CO 80526 

Mr. Perry Olson Colorado 

Division of Wildlife 

6060 Broadway 

Denver, CO 80216 

Colorado Environmental Coalition, 

Inc. 

1536 Wynkoop 

Denver, CO 80202 

 Mr. Lew Ladwig Colorado 

Geological Survey 

1313 Sherman Street, Rm 715 

Denver, CO 80203 

Management and Conservation 

Colorado Office of Energy 

225 E. 16th Ave, Suite 650 

Denver, CO 80203 

Colorado State Board of Land 

Communication 

1313 Sherman Street, Rm 620 

Denver, CO 80203 

 Mr. Bruce Colter Colorado State 

Forest Service 

Golden District Office 

1504 Quaker Street 

Golden, CO 80401-2956 

Colorado State Patrol 

1096 McIntyre St. 

Golden, CO 80401 

Ms. Rebecca Vickers Colorado 

Transporation Dept. Empire Park 

Environmental Services 

4201 E. Arkansas Ave. 

Denver, CO 80222 

 Columbine Café 

15630 S. Golden Rd. 

Golden, CO 80401 

Communication Industries, Ind 

785 McIntyre St. 

Golden, CO 80401 

Mr. Walter S. Welton, President 

Consolidated Mutual Water 

Company 

12700 W. 27th Ave. 

Lakewood, CO 80215 

 CSI Hobby Greenhouses 

15850 W. Colfax Ave. 

Golden, CO 80401 

Custer & Steinmates 

622 Gardenia Ct. 

Golden, CO 80401 

DAVCO Motors 

795 McIntyre St. 

Golden, CO 80401 

 Day's Inn Motel 

15059 W. Colfax Ave. 

Golden, CO 80401 

DDRC Maintenance Terminal 

16611 S. Golden Rd. 

Golden, CO 80401 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-3 

Delux Towing 

16305 S. Golden Rd. 

Golden, CO 80401 

 Denver Biomaterials Inc 

14998 W. 6th Ave., 700 

Golden, CO 80401 

Mr. Greg Stevinson Denver 

West Ltd. 

1546 Cole Blvd 

Golden, CO 80401 

Ms. Valerie Farnham Denver West 

Ltd. 

1546 Cole Blvd 

Golden, CO 80401 

 Mr. Terry McKee, Omaha 

District Dept. of Army, Corps of 

Engineers 

9307 State Highway 121 

Littleon, CO 80123 

Mr. Hal Simpson Division of 

Water Resources 

1313 Sherman St., Rm 818 

Denver, CO 80203 

DOC 

15000 W. 6th Ave., 102 

Golden, CO 80401 

 Dolls Anonymous 

16399 S. Golden Rd., Unit C 

Golden, CO 80401 

EAP Glass 

616 Moss St. 

Golden, CO 80401 

Eggers Lapidary 

16950 S. Golden Rd. 

Golden, CO 80401 

 Einstein Bagel Company 

14103 Denver West Parkway 

#100 

Golden, CO 80401 

Einstein Bros. Bagels 

14401 W. Colfax Ave. 

Golden, CO 80401 

El Amigo Restaurant 

16399 S. Golden Rd., Unit D 

Golden, CO 80401 

 El Senor Sol 

15900 W. Colfax Ave. 

Golden, CO 80401 

Energy West Controls 

14828 W. 6th Ave. 

Golden, CO 80401 

Enstroms Candies 

14415 W. Colfax Ave. 

Golden, CO 80401 

 Enterprise Car Rental 

885 Lupine St. A 

Golden, CO 80401 

Ms. Christine Shaver 

Environmental Defense Fund, 

Inc. 

Rocky Mountain Office 

2334 North Broadway 

Boulder, CO 80304 

Mr. Wes Wilson EPA Region VII 

NEPA Compliance, 8WMEA 

999 18th Street 

Denver, CO 80202-2466 

 Evergreen Appraisals 

622 Gardenia Ct. 

Golden, CO 80401 

Northwest Mountain Office 

Federal Aviation Administration 

1601 Lind Avenue SW 

Renton, WA 98055-4056 

Five R Repair 

15590 W. Colfax Ave. 

Golden, CO 80401 

 Foothills Chiropractic Health 

Center 

16135 S. Golden Rd. 

Golden, CO 80401 

Foreign Car Service 

16289 W. Colfax Ave. 

Golden, CO 80401 

Francis Veterinary 

16199 S. Golden Rd. 

Golden, CO 80401 

 Ms. Doris DePenning Friends of 

the Foothills 

9285 Blue Mountain Dr. 

Golden, CO 80403 

Ms. Nancy Hollinger Friends of 

the Foothills 

9184 Fern Way 

Golden, CO 80402 

Glasscraft, Inc. 

626 Moss St. 

Golden, CO 80401 

 God's Place 

16399 S. Golden Rd., Unit G 

Golden, CO 80401 

Golden Auto Parts 

16948 S. Golden Rd. 

Golden, CO 80401 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-4 

Mr. Allen Gallamore Golden 

District Forester 

Golden District Office 

1504 Quaker Street 

Golden, CO 80401-2956 

 Golden Gate Parts 

15990 S. Golden Rd. 

Golden, CO 80401 

Mr. Steve Glueck, Director 

Golden Planning & 

Development Department 

1455 10th Street 

Golden, CO 80401 

Gram's Foods 

15710 W. 6th Ave., 710 

Golden, CO 80401 

 Holiday Inn West Village 

14707 W. Colfax Ave. 

Golden, CO 80401 

Hops 

14285 W. Colfax Ave. 

Golden, CO 80401 

Horizon Foods 

16305 S. Golden Rd. 

Golden, CO 80401 

 Intermountain Marketing 

15000 W. 6th Ave., 200 

Golden, CO 80401 

Islamic Center of Golden 

16199 S. Golden Rd. 

Golden, CO 80401 

J. F. Hurlbut Co. 

622 Gardenia Ct. 

Golden, CO 80401 

 Jamba Juice 

14237 W. Colfax Ave. 

Golden, CO 80401 

Jeffco Open Space Foundation, 

Inc. 

5855 Wadsworth Bypass 

Building A, Suite 100 

Arvada, CO 80003 

Mr. Bud Smead, Director Jefferson 

County Public Works Div. 

1700 Arapahoe Street 

Golden, CO 80419 

 C/O John Litz Jefferson County 

Colorado Citzens for Planned 

Growth and Open Space 

11010 W. 29th Avenue 

Lakewood, CO 80215-7120 

Ms. Nanette Neelon Jefferson 

County 

Special Projects Coordinator 

100 Jefferson County Pkwy 

Golden, CO 80419-3500 

Randy B. Holman Jefferson County 

Assessor's Office 

100 Jefferson County Parkway, 

Suite 3550 

Golden, CO 80419 

 Jefferson County 

Highways and Transporation 

100 Jefferson County Pkwy, Ste. 

3500 

Golden, CO 80419 

Jefferson County Department of 

Health 

Environmental Health Division 

260 South Kipling Street 

Lakewood, CO 80226 

Mr. Terry Green Jefferson County 

Emergency Preparedness 

100 Jefferson County Pkwy, 

Suite 4570 

Golden, CO 80419 

 Joy Lucisano Jefferson County 

Open Space 

Acquisitions Specialist 

100 Jefferson County Parkway 

Golden, CO 80419 

Mr. Randy Frank Jefferson 

County Open Space 

700 Jefferson County Pkwy, Ste. 

100 

Golden, CO 80419 

Jefferson County Open Space 

Assistant County Attorney 

100 Jefferson County Pkwy 

Golden, CO 80419 

 Mr. David Field Jefferson County 

Planning & Zoning Office 

100 Jefferson County Parkway 

Ste. 3550 

Golden, CO 80419 

Mr. Preston Gibson, AICP 

Jefferson County Planning & 

Zoning Office 

Planning and Engineering Mgr 

100 Jefferson County Pkwy, 

Suite. 3550 

Golden, CO 80419 

Ms. Karen Hellner Jefferson County 

Planning & Zoning Office 

7000 Jefferson County Pkwy 

Suite 3550 

Golden, CO 80419 

 Jefferson County Public Schools 

1829 Denver West Drive 

Golden, CO 80401 

Mr. Ronald Beckham Jefferson 

County Sheriff 

17900 W. 10th Ave. 

Golden, CO 80401-2679 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-5 

JGS Contractors, Inc. 

855 Lupine St. 

Golden, CO 80401 

 Junction Texaco 

15065 W. Colfax Ave. 

Golden, CO 80401 

K&P Inc. 

777 Nile St. 

Golden, CO 80401 

K.E.M. Printing 

16250 S. Golden Rd. 

Golden, CO 80401 

 Key Bank 

14417 W. Colfax Ave. 

Golden, CO 80401 

Mr. Eric Blank Land & Water 

Fund of the Rockies 

2260 Baseline Road, Suite 200 

Boulder, CO 80302 

Lawson Pain and Body 

910 McIntyre St. 

Golden, CO 80401 

 Le Peep 

14401 W. Colfax Ave. 

Golden, CO 80401 

Leep'in Lizard SAAB 

605 Lupine St. 

Golden, CO 80401 

Mac Vik Plumbing & Heating 

16190 S. Golden Rd. 

Golden, CO 80401 

 Macaroni Grill 

14245 W. Colfax Ave. 

Golden, CO 80401 

Majestic Ventures 

16500 S. Golden Rd. 

Golden, CO 80401 

Mannie and Bo's Pizzeria 

16399 S. Golden Rd., Unit E 

Golden, CO 80401 

 McKee Construction Co. 

795 McIntyre St. 

Golden, CO 80401 

Method Machine Tools, Inc. 

14998 W. 6th Ave. 

Golden, CO 80401 

Mr. Dale Lauer, Board of Directors 

Metro Sanitation District 

952 Moss Street 

Golden, CO 80401 

 Rue Eich Metro Wastewater 

Reclamation District 

6450 York Street 

Denver, CO 

Mier's Deli 

15750 S. Golden Rd. 

Golden, CO 80401 

Mile Hi Chem Dry 

15970 S. Golden Rd. 

Golden, CO 80401 

 Mimi's Café 

14265 W. Colfax Ave. 

Golden, CO 80401 

MLL General Contractors 

665 Moss St. 

Golden, CO 80401 

Mobile Mechanic at the Shop 

15810 W. Colfax Ave. 

Golden, CO 80401 

 Mountain View Laundromat & 

Dry Cleaner 

15940 S Golden Rd. 

Golden, CO 80401 

Mountain View Motel 

14825 W. Colfax Ave. 

Golden, CO 80401 

Mountain View Trailer Village 

16100 S. Golden Rd. 

Golden, CO 80401 

 Mr. Handyman 

622 Gardenia Ct. 

Golden, CO 80401 

National Wildlife Federation 

2260 Baseline Road 

Boulder, CO 80302 

Nationwide Storage 

16845 Mt. Vernon Rd. 

Golden, CO 80401 

 Native Nursery - Tom Gillian 

17025 S. Golden Rd. 

Golden, CO 80401 

Ronald Wopsock & Roland 

McCook Northern Ute Indian 

Tribe 

PO Box 190 

Ft. Duchesene, UT 84026 

Oasis Denver West Apt Homes 

1910 Denver West Drive 

Golden, CO 80401 

 Office Max 

14275 W. Colfax Ave. 

Golden, CO 80401 

Office of Representative Bob 

Beauprez 

4251 Kipling St., Ste. 370 

Wheat Ridge, CO 80033 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-6 

Office of Representative Mark 

Udall 

8601 Turnpike Drive #206 

Westminster, CO 80031 

 Office of Senator Ken Salazar 

2300 15th St., Ste. 450 

Denver, CO 80202 

Ms. Kristine Pollard Office of 

Senator Wayne Allard 

7340 E. Caley, Suite 215 

Englewood, CO 80111 

Old Golden Discount Liquors 

15750 S. Golden Rd. 

Golden, CO 80401 

 Old Navy 

14367 W. Colfax Ave. 

Golden, CO 80401 

On the Border 

14225 W. Colfax Ave. 

Golden, CO 80401 

Outback Steakhouse 

14295 W. Colfax Ave. 

Golden, CO 80401 

 Peregrine Communications Inc. 

14818 W. 6th Ave., 15A 

Golden, CO 80401 

Perfection Tool Repair 

16200 S. Golden Rd. 

Golden, CO 80401 

Performance Plus Auto Care 

16099 S. Golden Rd. 

Golden, CO 80401 

 Planet Honda 

15601 W. Colfax Ave. 

Golden, CO 80401 

Pleasant View Beauty Salon 

15940 S Golden Rd. 

Golden, CO 80401 

Mr. Branden Baalman, Chief 

Pleasant View Fire Department 

955 Moss Street 

Golden, CO 80401 

 Stewart McCallister, District 

Coordinator 

Pleasant View Metro District 

955 Moss Street 

Golden, CO 80401 

Mr. David Councilman 

Pleasant View Water & 

Sanitation District 

955 Moss Street 

Golden, CO 80401 

Pompoms & Whiskers Grooming 

940 McIntyre St. 

Golden, CO 80401 

 Porter Design 

15750 S. Golden Rd., Unit G 

Golden, CO 80401 

Procard, Inc. 

1819 Denver West Drive 

Golden, CO 80401 

Puttin Parts 

16185 S. Golden Rd. 

Golden, CO 80401 

 Quiznos 

14413 W. Colfax Ave. 

Golden, CO 80401 

Ramstetter Excavating 

16599 S. Golden Rd. 

Golden, CO 80401 

Ranniger Systems, Inc. 

795 McIntyre St. 

Golden, CO 80401 

 Reasonable Auto Service 

15735 S. Golden Rd. 

Golden, CO 80401 

Regal Mortgage 

795 McIntyre St. 

Golden, CO 80401 

Richards Agency 

622 Gardenia Ct. 

Golden, CO 80401 

 Rock Rest 

16005 Mt. Vernon Rd. 

Golden, CO 80401 

Mr. David Abelson 

Rocky Flats Coalition of Local 

Government 

8461 Turnpike Dr. 

Westminster, CO 80031 

Roofing Services 

15985 S. Golden Rd., Unit F 

Golden, CO 80401 

 Rose Cleaners 

14407 W. Colfax Ave. 

Golden, CO 80401 

Save the Mesas/Citzens 

Involved 

in the NW Quadrant 

PO Box 16551 

Golden, CO 80402-6009 

Secor 

14998 W. 6th Ave., 800 

Golden, CO 80401 

 Sid's Auto Service 

16305 S. Golden Rd. 

Golden, CO 80401 

Ms. Maggie Fox, Southwest 

Office Sierra Club 

2260 Baseline Road, Suite 105 

Boulder, CO 80302 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-7 

Simplex 

14998 W. 6th Ave., 600 

Golden, CO 80401 

 Sinclair Service Station 

15495 W. Colfax Ave. 

Golden, CO 80401 

Ecological Science Dept. Soil 

Conservation Service 

655 Parfet Street, Rm E20C 

Lakewood, CO 80215 

Clement Frost, Tribal Leader 

Southern Ute Tribe 

PO Box 737 

Ingacio, CO 81137 

 Edna Frost, Director Southern 

Ute Tribe 

Tribal Information Services 

PO Box 737 

Ingacio, CO 81137 

Mr. & Mrs Alden Naranjo 

Southern Ute Tribe 

Ute Language & Culture 

Committee 

PO Box 737 

Ingacio, CO 81137 

Mr. Leonard C. Burch, Chairman 

Southern Ute Tribe 

Ute Language & Culture Committee 

PO Box 737 

Ingacio, CO 81137 

 Mr. Neil Cloud Southern Ute 

Tribe 

NAGPRA Coordinator 

PO Box 737 

Igacio, CO 81137 

Sports Rack Vehicle Outfitter 

15600 W. Colfax Ave. 

Golden, CO 80401 

Mr. Jim Green State Historic Pres. 

Office 

1300 Broadway 

Denver, CO 80203 

 Govenor Bill Owens State of 

Colorado 

136 State Capital 

Denver, CO 80203 

Stevinson Chevrolet 

14700 W. Colfax Ave. 

Golden, CO 80401 

Stevinson Lexus 

801 Indiana Street 

Golden, CO 80401 

 Stevinson Toyota 

15000 W. Colfax Ave. 

Golden, CO 80401 

Table Mountain Conservation 

Fund 

PO Box 16201 

Golden, CO 80402-6004 

Telecommunications Products, Inc. 

795 McIntyre St. 

Golden, CO 80401 

 Telescope Engineering 

15730 W. 6th Ave. 

Golden, CO 80401 

The Salon 

14235 W. Colfax Ave. 

Golden, CO 80401 

Tokyo Joes 

14227 W. Colfax Ave. 

Golden, CO 80401 

 Dr. Kenneth R. Wilson U.S. 

Department Interior Fish & 

Wildlife Service 

Colorado Field Supervisor 

755 Parfet St., Rm 361 

Lakewood, CO 80215 

Eugene H. Backhaus U.S. 

Department of Agriculture 

District Conservationist 

655 Parfet Street, Room E-300 

Lakewood, CO 80215-5517 

Mr. Gary Finstad 

U.S. Department of Agriculture 

Natural Resource Conservation 

Service - Metro Office 

655 Parfet Street, Rm E-300 

Lakewood, CO 80215-5517 

 Mr. Andrew Archuleta U.S. Fish 

and Wildlife Service 

Colorado Field Office 

PO Box 25486-DFC 

Denver, CO 80225-0207 

UA 

14225 W. Colfax Ave. 

Golden, CO 80401 

U-Haul 

15500 W. Colfax Ave. 

Golden, CO 80401 

 Betsy Chapoose Uinta and Ouray 

Ute Tribal Business Council 

PO Box 190 

Ft. Duchesene, UT 84026 

Ultimate Electronics 

14275 W. Colfax Ave. 

Golden, CO 80401 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 B-8 

Mr. Randy Christiansen United 

Power 

# 5 Grouse Dam Rd. 

Golden, CO 80403 

 Universal Surface Counter Tops 

15866 W. 7th Ave., C&D 

Golden, CO 80401 

Mr. Gregory Davis US EPA 

Mailcode: EPR-EP 

999 18th Street, Suite 500 

Denver, CO 80202 

Ms. Carol Campbell US EPA - 

Region VIII 

Director Ecosystem Protection 

999 18th Street, Suite 500 

Denver, CO 80202-2405 

 Mr. Grady Towns US Fish and 

Wildlife Service 

Denver Regional Office 

PO Box 25486 

Denver, CO 80225 

Mr. Terry Knight, Spiritual 

Coordinator Ute Mountain Life 

Tribe 

PO Box 53 

Towaoc, CO 81334 

Ms. Judy Knight-Frank, 

Chairperson Ute Mountain Ute 

Tribal Council 

General Delivery 

Towaoc, CO 81334 

 VFW Post # 4171 

15625 W. 10th Ave. 

Golden, CO 80401 

Videotronix 

15000 W. 6th Ave., 102A 

Golden, CO 80401 

Wa La Hair Studio 

15750 S. Golden Rd. 

Golden, CO 80401 

 Walts Tire Store 

15990 S. Golden Rd. 

Golden, CO 80401 

West Metro Fire Protection 

District 

447 S. Allison Parkway 

Lakewood, CO 80226-3128 

West Side Auto Sales 

676 Moss St. 

Golden, CO 80401 

 Western Roofing 

15810 W. 6th Ave 

Golden, CO 80401 

Ms. Belinda Boiko Yenter 

Companies 

20300 W. Highway 72 

Arvada, CO 80007 

Carl Eiberger 

14330 Fairview Lane 

Golden, CO 80401 

 Craig Cox 

2900 Vance Street 

Denver, CO 80215 

Wilbur between Lodges 

Oglala Sious Tribe 

Pine Ridge, SD 57770 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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APPENDIX C RESPONSES RECEIVED TO SCOPING LETTER 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Final Environmental Assessment of Three Site Development Projects 

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Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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APPENDIX D RESPONSES TO COMMENTS ON THE DRAFT EA 

Comment: I imagine this proposal will stir up a lot of controversy, as the Mesas seem to be quite 

protected by the residents of Golden. I believe the NREL mission is critical and will only benefit the city, 

the state, the nation and the planet. NREL is trying to lead by example and lower their own footprint, all 

while they continue to further research of renewable energies for the nation and the planet. This is much 

bigger, and in my opinion a worthy sacrifice, of a few hundred acres on top of one of our Mesas; 

especially if done in a respectful and courteous manner to the residents of Golden. 

Response: DOE appreciates the support for the mission and goals of NREL expressed by the 

comment. Both the beneficial aspects of the proposed actions and the visual impacts that might 

affect some members of the public have been identified in this EA. While the commenter also 

expressed that even as much as hundreds acres of development on the mesa top would be 

acceptable, DOE notes that the proposed development on the mesa top addressed in this EA 

would be limited to 5 acres, and based on the visual simulations, such development would not 

result in significant visual impacts. 

Comment: I am a resident of Golden and have also spent some time walking around South Table 

Mountain. There are two significant prehistoric sites in the general vicinity of NREL that I don't think are 

on federal lands but I'm not exactly sure where the boundaries are for the various land owners. I'm also 

very interested in the CCC amphitheater and if there are any plans for that area. 

Response: Communications between DOE and the commenter have determined that the cultural 

resource sites are not located in or near the proposed project area and would not be impacted by 

the proposed actions. 

Comment: It is questionable if this project supports the NREL mission such as “advancing and 

contributing to commercialization of renewable energy technologies.” 

Response: The RFHP advances and contributes to the commercialization of this renewable 

energy technology by demonstrating its technical viability, specifically in this geographic region 

and at altitude; demonstrating its financial viability, importantly through a private-sector 

financing mechanism, Energy Savings Performance Contracting (ESPC); and supporting a major 

NREL sustainability project that provides first-hand commercialization experience to NREL 

deployment and R&D personnel that can be transferred to DOE/NREL customers. 

Comment: It appears the manufacturer will obtain operating data from NREL to improve its products, 

possibly advancing a renewable energy technology. If that is the case, is the manufacturer entering into a 

cost sharing arrangement with NREL, as is typically done with research partners having technology 

aligned with the NREL mission? Additionally, the RFHP has been proposed as a capital project for at 

least the last five years, and after going through the formal evaluation process it always fell off the list of 

funded projects. 

Response: There are no cost-sharing requirements in the DOE ESPC that would finance the 

proposed RFHP. The RFHP is not funded by NREL appropriations. Under an ESPC, the 

contractor is required to provide all capital equipment and is responsible for all maintenance, 

repair, replacement and operations, including long-term wood fuel supply. The contractor is paid 

from the energy cost savings realized from the project. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Comment: The EA states that the RFHP will have a 10- to 30-year operating lifetime. This appears rather 

broad and vague, with recognition that it may be the best data available for this technology. Of greater 

concern is that the EA does not state what the RFHP will cost, or what the pay-back period will be. 

Response: Various components of the RFHP have 10- to 30-year life ranges; the contract term 

with the Energy Savings Company (ESCO) is 24 years, and the contract covers replacement (by 

the ESCO) of any component with less than a 24-year expected life. While the Department 

certainly considers life cycle costs in its decision-making, the National Environmental Policy Act 

(NEPA) requires that a federal agency identify in an appropriate NEPA document the 

environmental impacts of its proposed actions before determining a course of action. “For the 

purposes of complying with the Act, the weighing of the merits and drawbacks of the various 

alternatives need not be displayed in a monetary cost-benefit analysis ...” (40 CFR 1502.23). 

Comment: The EA references documents that provide more detail on the exact location, but it does not 

indicate if or where these documents are available for review. 

Response: DOE standard practice is to maintain all reference documents in the project 

administrative record; references are available for review upon request. 

Comment: The EA frequently states that the RFHP will be sited “at the edge of a natural drainage.” 

Given the size of the RFHP and related paved areas, and the size of the natural drainage, it appears that 

the impact will be significant. Clarification of the exact impact on the natural drainage appears necessary. 

Response: DOE has added another figure to the EA clarifying the exact location of the RFHP 

and associated turnaround area (Figure 2-2). The potential impacts to the drainage area resulting 

from the RFHP and turnaround area are discussed in Section 3.1.7.2 of the EA. 

Comment: Whether or not the natural drainage between the FTLB and the SERF qualified as a wetland 

or other type of protected area was always a point of concern for SERI and NREL. It was always my 

understanding that any wetlands were artificial, created by development of the STM site, and therefore 

not protected. Technically it is only a drainage ditch, and the only requirement is that it be capable of 

draining. 

Response: The designation of the arroyo as a drainage way is correct. This drainage has no areas 

of designated wetlands that would require special permitting for construction. As discussed in the 

STM Site-wide EA (DOE/EA #1440), the USACE determined in 1997 that the drainage is not 

considered a water of the United States. NREL’s 2002 Vegetation Survey Report – South Table 

Mountain (June 29, 2002) identifies four small plant communities that supported wetland-type 

plants; these areas would not be affected by the Proposed Action. The vegetation study classifies 

the plant community within the drainages as ravine shrubland. 

Comment: As part of its environmental best-management approach, as previously mentioned, NREL 

intentionally did not build on or across the drainage in the past. This accounts for the distance between the 

FTLB and SERF and the fact that separate utility spines are maintained on either side of the drainage. 

Response: NREL has had a culvert and service road over the drainage since the SERF was built. 

The existing culvert may be extended and two cottonwood trees would be destroyed, relocated, or 

replaced. The new utility spines would be located over the culvert. The building would not extend 

into the drainage. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 D-3 

Comment: The location of the RFHP is contrary to site development concepts previously espoused and 

represents a change in NREL’s approach (if not actual policy) toward utilization of the site and voluntary 

protection of valued natural features. NREL site development planning looking out at least 25 years 

envisioned the area around the FTLB, SERF and S&TF as being a campus environment that would 

promote group interactions in indoor and outdoor settings. Placement of a boiler facility in the middle of 

this campus, along with access roads and heavy trucks delivering wood supplies, does not support such a 

collegial environment and have the appearance of a “wall,” that is, a continuous string of buildings along 

the base of South Table Mountain. 

Response: The proposed location is a compromise between ideal environmental aspects of site 

development and the need for operational efficiency and effectiveness adjacent to the central 

utility plant. NREL site development planning continues to “envision the area around the FTLB, 

SERF, and S&TF as being a campus environment that would promote group interactions in 

indoor and outdoor settings.” The RFHP is located at the northern edge of the buildable portion of 

the site, where there are no current or planned amenity areas (trails, outdoor seating, etc) for staff 

interaction. The staff interaction areas are significantly farther down the arroyo and should not be 

impacted by the location of the RFHP. As discussed in Section 3.1.4.2 of the EA, the RFHP 

would be blocked from view by the FTLB from most off-site observational viewpoints. 

Comment: The EA states that plume modeling established that no adverse health effects will be 

presented to persons in other facilities by the RFHP stack emissions. This “minimum requirement” 

analysis addresses standards established by OSHA and ACGIH, but does not comment on possible reentrainment of odors into the SERF and S&TF ventilation systems. 

Response: DOE and NREL have taken the issue of re-entrainment into consideration in 

preliminary design of the facility’s stack height and will include design requirements in its 

contractual agreement with the ESCO. 

Comment: The EA describes higher odor levels during start-up and shut-down of the RFHP, but there is 

no mention at all about specific odor levels during steady-state operation. 

Response: The RFHP will have dual combustion chambers – the primary combustion chamber is 

fired at up to 1,800°F, and secondary chamber is fired at 3,100°F – resulting in complete 

combustion. NREL has held discussions with four operators of similarly sized wood-fired boilers, 

including visiting one operation in person. In each case, the operators indicated that there were no 

odors during steady-state operation. Experience from other operators of similar systems has also 

shown that there are no noticeable odors. 

Comment: The EA does not address whether the necessary fuel supply will be available for either the 

operating-life or the pay-back period of the RFHP. There is also no mention of the embedded energy costs 

of transporting the waste wood, such as how far away will it be coming from, will those distances 

increase over time, and what will the effects of higher truck fuel costs be.

Response: The ESPC requires that the ESCO remain responsible for wood fuel supply for the 

entire term of the contract. The ESCO has identified a local provider for wood-waste fuel for the 

RFHP. The supplier has been in business for 32 years, is located less than 16 kilometers 

(10 miles) from NREL, has multiple local sources of wood-waste, and can guarantee the monthly 

and annual supply needed to meet the minor load of the RFHP. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 D-4 

Comment: The commenter expressed concern that there would be a significant increase in CO2 emissions 

that would be realized over the use of natural gas. Regardless of the “net” CO2 argument that the EA 

presents around wood versus natural gas, the fact remains that an increase is an increase. 

Response: There would be an increase in absolute quantity: 2,941 tons/year (natural gas) vs. 

5,297 tons/year (4,544 wood and 753 natural gas). This increase of 2,356 tons represents an 

increase of less than 8 percent in the overall laboratory CO2 footprint (30,067 tons, FY06). 

Further, as shown on Table 3-3, from a Maximum Predicted Impact to Health-Based Standards 

perspective, the RFHP emissions (8-hour average (micrograms/m3

) of 240,000 vs. the 9,000,000 

health standard is not significant. NREL’s policy on CO2 is to be “carbon neutral.” It is also 

appropriately NREL’s policy to maximize the use of on-site renewable energy. To this end, the 

Renewable Fuel Heating Plant (RFHP) is expected to reduce laboratory natural gas (fossil fuel) 

use by a significant 75 percent at the South Table Mountain site. By accepted EPA national 

standards (EPA-AP42), the combustion of biomass (wood) waste at facilities such as the RFHP is 

considered to be CO2 “net neutral.” That is, the same amount of CO2 is released during 

combustion of the biomass waste as was sequestered during its relatively recent growth cycle. 

The combustion of natural gas is considered to release “new” carbon into the atmosphere. Even 

though combustion of biomass waste is considered to be CO2 “net neutral,” NREL will purchase 

renewable energy credits (RECs) to offset all CO2 produced by the RFHP. 

Comment: The EA compares the RFHP CO2 emissions with combustion of an equivalent mass of wood 

using a forest fire model. That comparison erroneously assumes that any wood waste not used at the 

RFHP will be subject to open burning with CO2 emissions equal to or greater than the RFHP. Likewise, 

estimates of methane generated by landfilling or natural degradation assume a single, all-consuming end 

for the waste wood. A more accurate model is needed. 

Response: The comparative analyses provided in the EA were based on a technical review of the 

available literature. This review found “open burning” and “landfilling/natural degradation” as 

the best available and quantified alternatives for comparison to combustion. Other alternatives 

such as open decomposition could not be quantifiably compared based on the available scientific 

literature. The analyses were included to provide the reader and the decision-makers with 

additional means of comparing among alternatives but in no way assumed that these would be the 

only alternative pathways for wood waste not used by the RFHP.

Comment: It has come to my attention that the plan to build the RFHP was critical to a LEED 

[Leadership in Energy and Environmental Design] Platinum rating being awarded to the S&TF [Science 

and Technology Facility]. This commitment by the operating contractor may make construction of the 

RFHP a foregone conclusion, and any EA comments submitted by myself and others become moot. 

Response: The S&TF LEED Platinum rating was achieved in part through NREL’s commitment 

to a renewable heating source for the building. In the event the RFHP is not constructed and 

operated, NREL could retain the platinum rating as long as an equivalent amount of renewable 

energy were installed on the building. For example, NREL could use PV to meet the requirement 

instead of heat generated through the RFHP. NREL’s commitment to use of renewable energy 

through the LEED application process in no way represents a foregone commitment to the RFHP; 

other renewable heat sources could be considered through existing review mechanisms, including 

NEPA. 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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APPENDIX E DRAFT RFHP CONSTRUCTION PERMIT 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

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Final Environmental Assessment of Three Site Development Projects 

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Final Environmental Assessment of Three Site Development Projects 

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Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 3 Figure 1-1. Regional Location of the STM Site 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 4 Figure 1-2. Local Setting of the STM Site 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 8 Figure 2-1. STM and the Relative Locations of the Three Proposed Projects on the Site 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 9 Figure 2-2. Site Layout of the RFHP 
Final Environmental Assessment of Three Site Development Projects 

at the National Renewable Energy Laboratory South Table Mountain Site 

 16 Source: DOE, 2003, Figure 2-1 Figure 3-1. Site Development Zones and Proposed Improvements at the STM Site 

.