- •VOLUME 1 CONTENTS
- •NOTATION
- •ENGLISH/METRIC AND METRIC/ENGLISH EQUIVALENTS
- •EXECUTIVE SUMMARY
- •ES.1 Background
- •ES.2 BLM Proposed Action
- •ES.2.1 BLM Purpose and Need
- •ES.2.2 BLM Scope of Analysis
- •ES.2.3 Applications for Solar Energy Development on BLM Lands
- •ES.2.4 BLM Alternatives
- •ES.2.4.1 Program Elements Common to Both BLM Action Alternatives
- •ES.2.4.3 Solar Energy Zone Program Alternative
- •ES.2.4.4 No Action Alternative
- •ES.2.4.5 Reasonably Foreseeable Solar Energy Development
- •ES.2.4.6 Summary of Impacts of BLM’s Alternatives
- •ES.2.4.7 BLM’s Preferred Alternative
- •ES.3 DOE Proposed Action
- •ES.3.1 DOE Purpose and Need
- •ES.3.2 DOE Scope of Analysis
- •ES.3.3 DOE Alternatives
- •ES.3.3.2 No Action Alternative
- •ES.3.4 Summary of Impacts of DOE’s Alternatives
- •ES.4 Public Involvement, Consultation, and Coordination
- •ES.5 References
- •1 INTRODUCTION
- •1.1 Applicable Federal Orders and Mandates
- •1.1.1 Executive Order 13212
- •1.1.2 Energy Policy Act of 2005
- •1.1.3 Energy Independence and Security Act of 2007
- •1.1.4 DOI Secretarial Order 3285A1
- •1.1.5 Executive Order 13514
- •1.1.6 DOI Secretarial Order 3297
- •1.3 BLM Requirements and Objectives for the PEIS
- •1.3.1 BLM’s Purpose and Need
- •1.3.2 BLM Decisions To Be Made
- •1.3.3 Authorization Process for Solar Energy Development on BLM Lands
- •1.3.3.1 New Applications
- •1.3.3.2 Pending Applications
- •1.3.3.3 Approved Applications
- •1.3.4 BLM Land Use Planning Process
- •1.3.5 BLM Scope of the Analysis
- •1.3.5.1 Program Analysis Versus SEZ-Specific Analysis
- •1.3.6 BLM Planning Criteria
- •1.4 DOE Requirements and Objectives for the PEIS
- •1.4.1 DOE’s Purpose and Need
- •1.4.2 DOE Decisions To Be Made
- •1.4.3 DOE Scope of the Analysis
- •1.5 Cooperating Agencies
- •1.6.1 Renewable Portfolio Standards and Other Regional and State Initiatives
- •1.6.2 Related Initiatives
- •1.6.2.1 Energy Corridor Designation
- •1.6.2.3 California Desert Renewable Energy Conservation Plan
- •1.6.2.4 Arizona Restoration Design Energy Project
- •1.6.2.5 Wind Energy Development PEIS
- •1.6.2.6 Geothermal PEIS
- •1.8 References
- •2.1 Introduction
- •2.2 BLM Alternatives
- •2.2.1 Program Elements Common to Both BLM Action Alternatives
- •2.2.1.1 Right-of-Way Authorization Policies
- •2.2.1.2 Monitoring, Adaptive Management, and Mitigation
- •2.2.1.3 Design Features
- •2.2.1.4 Segregation of Lands with Potential for Solar Development
- •2.2.2.1 Proposed Right-of-Way Exclusion Areas
- •2.2.2.2 Proposed Solar Energy Zones
- •2.2.2.3 Proposed Variance Areas for Utility-Scale Solar Energy Development
- •2.2.2.4 Land Use Plans To Be Amended
- •2.2.3 SEZ Program Alternative
- •2.2.3.1 Proposed Right-of-Way Exclusion Areas
- •2.2.3.2 Proposed Solar Energy Zones
- •2.2.3.3 Solar Energy Zone Policies
- •2.2.3.4 Land Use Plans To Be Amended
- •2.3 DOE Alternatives
- •2.3.1 No Action Alternative
- •2.3.2 Action Alternative—DOE’s Proposed Programmatic Environmental Guidance
- •2.3.2.1 General Mitigation Measures
- •2.3.2.2 Institutional and Public Outreach
- •2.3.2.3 Land Use
- •2.3.2.4 Water Resources and Erosion Control
- •2.3.2.5 Biological Resources
- •2.3.2.6 Air Quality
- •2.3.2.7 Cultural Resources and Native American Interactions
- •2.3.2.8 Visual Resources and Aesthetics
- •2.3.2.9 Socioeconomics
- •2.3.2.10 Environmental Justice
- •2.3.2.11 Safety and Health
- •2.4 Description of Reasonably Foreseeable Development Scenario
- •2.4.1 Comparison of RFDS with Lands Available under the Action Alternatives
- •2.5 Other Alternatives and Issues Considered
- •2.5.1 Distributed Generation
- •2.5.2 Conservation and Demand-Side Management
- •2.5.3 Analysis of Life-Cycle Impacts of Solar Energy Development
- •2.5.4 Analysis of Development on Other Federal, State, or Private Lands
- •2.5.5 Restricting Development to Previously Disturbed Lands
- •2.5.6 Restricting Development to Populated Areas
- •2.5.7 Restricting Development to the Fast-Track Project Applications
- •2.5.8 Analysis of Development on the Maximum Amount of Public Lands Allowable
- •2.5.9 Changes to BLM’s Proposed Solar Energy Zones
- •2.5.10 Other Suggested Alternatives
- •2.5.11 DOE Environmental Requirements
- •2.6 References
- •3.1 Technologies
- •3.2 Development Process Overview for All Technologies
- •3.2.1 Site Characterization
- •3.2.2 Site Preparation and Construction
- •3.2.3 Operations
- •3.2.4 Decommissioning and Reclamation
- •3.2.5 Transmission Facilities
- •3.4 Transportation Considerations
- •3.6 Health and Safety Aspects of Solar Energy Projects
- •3.7 Existing Agency Processes and Guidance
- •3.8 References
- •4 UPDATE TO AFFECTED ENVIRONMENT
- •4.1 Introduction
- •4.2 Lands and Realty
- •4.4 Rangeland Resources
- •4.4.1 Livestock Grazing
- •4.4.2 Wild Horses and Burros
- •4.4.3 Wildland Fire
- •4.5 Recreation
- •4.6 Military and Civilian Aviation
- •4.7 Geologic Setting and Soil Resources
- •4.7.1 Geologic Setting
- •4.7.2 Geologic Hazards
- •4.7.3 Soil Resources
- •4.8 Minerals
- •4.9 Water Resources
- •4.9.1 Surface Water Resources
- •4.9.2 Groundwater Resources
- •4.9.3 Water Rights, Supply, and Use
- •4.10 Ecological Resources
- •4.10.1 Vegetation
- •4.10.2 Wildlife
- •4.10.3 Aquatic Biota
- •4.10.3.1 Pacific Northwest Hydrologic Region
- •4.10.3.2 Lower Colorado, Rio Grande, and Great Basin Hydrologic Regions
- •4.10.3.3 California Hydrologic Region
- •4.10.3.4 Upper Colorado River Hydrologic Region
- •4.10.3.5 Missouri River Basin Hydrologic Region
- •4.10.4 Special Status Species
- •4.11 Air Quality and Climate
- •4.11.3 Update to Section 4.11.2.4 of the Draft Solar PEIS: Visibility Protection
- •4.11.4 Update to Section 4.11.2.5 of the Draft Solar PEIS: General Conformity
- •4.11.5 Addition of New Section 4.11.4: Toxic Dust and Snowmelt
- •4.12 Visual Resources
- •4.13 Acoustic Environment
- •4.14 Paleontological Resources
- •4.15 Cultural Resources
- •4.16 Native American Concerns
- •4.17 Socioeconomics
- •4.18 Environmental Justice
- •4.19 References
- •4.20 Errata to Chapter 4 of the Draft Solar PEIS
- •5.1 Introduction
- •5.2 Lands and Realty
- •5.4 Rangeland Resources
- •5.4.1 Livestock Grazing
- •5.4.2 Wild Horses and Burros
- •5.4.3 Wildland Fire
- •5.5 Recreation
- •5.6 Military and Civilian Aviation
- •5.7 Geologic Setting and Soil Resources
- •5.8 Minerals
- •5.9 Water Resources
- •5.10 Ecological Resources
- •5.10.1 Vegetation
- •5.10.2 Wildlife
- •5.10.3 Aquatic Biota and Habitats
- •5.10.3.1 Common Impacts
- •5.10.3.2 Technology-Specific Impacts
- •5.10.4 Special Status Species
- •5.11 Air Quality and Climate
- •5.11.1 Common Impacts
- •5.11.1.1 Construction: Update to Section 5.11.1.2 of the Draft Solar PEIS
- •5.11.1.2 Operations: Update to Section 5.11.1.3 of the Draft Solar PEIS
- •5.12 Visual Resources
- •5.13 Acoustic Environment
- •5.13.1 Common Impacts
- •5.13.1.1 Construction: Update to Section 5.13.1.2 of the Draft Solar PEIS
- •5.13.1.2 Operations: Update to Section 5.13.1.3 of the Draft Solar PEIS
- •5.14 Paleontological Resources
- •5.15 Cultural Resources
- •5.15.1 Common Impacts
- •5.16 Native American Concerns
- •5.17 Socioeconomics
- •5.18 Environmental Justice
- •5.19 Transportation
- •5.20 Hazardous Materials and Waste
- •5.21 Health and Safety
- •5.22 References
- •5.23 Errata to Chapter 5 of the Draft Solar PEIS
- •6 ANALYSIS OF BLM’S SOLAR ENERGY DEVELOPMENT ALTERNATIVES
- •6.1.2 Minimize Environmental Impacts
- •6.1.3 Minimize Social and Economic Impacts
- •6.1.4 Provide Flexibility to Solar Industry
- •6.1.5 Optimize Existing Transmission Infrastructure and Corridors
- •6.1.6 Standardize and Streamline the Authorization Process
- •6.1.7 Meet Projected Demand for Solar Energy Development
- •6.2 Impacts of the SEZ Program Alternative
- •6.2.2 Minimize Environmental Impacts
- •6.2.3 Minimize Social and Economic Impacts
- •6.2.4 Provide Flexibility to Solar Industry
- •6.2.5 Optimize Existing Transmission Infrastructure and Corridors
- •6.2.6 Standardize and Streamline the Authorization Process
- •6.2.7 Meet Projected Demand for Solar Energy Development
- •6.3 Impacts of the No Action Alternative
- •6.3.2 Minimize Environmental Impacts
- •6.3.3 Minimize Social and Economic Impacts
- •6.3.4 Provide Flexibility to Solar Industry
- •6.3.5 Optimize Existing Transmission Infrastructure and Corridors
- •6.3.6 Standardize and Streamline the Authorization Process
- •6.3.7 Meet Projected Demand for Solar Energy Development
- •6.5 Cumulative Impacts
- •6.5.1 Overview of Activities in the Six-State Study Area
- •6.5.1.1 Energy Production and Distribution
- •6.5.1.2 Other Activities and Trends
- •6.5.2 Cumulative Impact Assessment for Solar Energy Development
- •6.5.2.1 Lands and Realty
- •6.5.2.2 Specially Designated Areas and Lands with Wilderness Characteristics
- •6.5.2.3 Rangeland Resources
- •6.5.2.4 Recreation
- •6.5.2.5 Military and Civilian Aviation
- •6.5.2.6 Geologic Setting and Soil Resources
- •6.5.2.7 Mineral Resources
- •6.5.2.8 Water Resources
- •6.5.2.9 Ecological Resources
- •6.5.2.10 Air Quality and Climate
- •6.5.2.11 Visual Resources
- •6.5.2.12 Acoustic Environment
- •6.5.2.13 Paleontological Resources
- •6.5.2.14 Cultural Resources
- •6.5.2.15 Native American Concerns
- •6.5.2.16 Socioeconomics
- •6.5.2.17 Environmental Justice
- •6.5.2.18 Transportation
- •6.6 Other NEPA Considerations
- •6.6.1 Unavoidable Adverse Impacts
- •6.6.2 Short-Term Use of the Environment and Long-Term Productivity
- •6.6.3 Irreversible and Irretrievable Commitment of Resources
- •6.6.4 Mitigation of Adverse Effects
- •6.7 References
- •7 ANALYSIS OF DOE’S ALTERNATIVES
- •7.1 Impacts of DOE’s Proposed Action
- •7.2 Impacts of the No Action Alternative
- •7.3 Cumulative Impacts
- •7.4 Other NEPA Considerations
- •7.4.1 Unavoidable Adverse Impacts
- •7.4.2 Short-Term Use of the Environment and Long-Term Productivity
- •7.4.3 Irreversible and Irretrievable Commitment of Resources
- •7.4.4 Mitigation of Adverse Effects
- •14.1 Public Scoping and Public Outreach
- •14.2 Government-to-Government Consultation
- •14.3 Coordination of BLM State and Field Offices
- •14.4 Agency Cooperation, Consultation, and Coordination
- •14.5 References
- •15 LIST OF PREPARERS
- •16 GLOSSARY
- •FIGURE ES.2-1 Areas Proposed for Exclusion Since Publication of the Supplement to the Draft Solar PEIS Based on Continued Consultation with Cooperating Agencies and Tribes
- •FIGURE ES.2-4 BLM-Administered Lands in Colorado Available for Application for Solar Energy ROW Authorizations under the BLM Alternatives Considered in This PEIS
- •FIGURE 1.2-2 Solar Direct Normal Insolation Levels in the Southwestern United States
- •FIGURE 2.2-3 BLM-Administered Lands in Colorado Available for Application for Solar Energy ROW Authorizations under the BLM Alternatives Considered in This PEIS
- •FIGURE 2.2-7 Areas Proposed for Exclusion Since Publication of the Supplement to the Draft Solar PEIS Based on Continued Consultation with Cooperating Agencies and Tribes
- •TABLE ES.2-3 Proposed SEZs and Approximate Acreage by State
- •TABLE ES.2-5 Summary-Level Assessment of Potential Environmental Impacts of Utility-Scale Solar Energy Development by Alternative
- •TABLE ES.2-6 Comparison of BLM’s Alternatives with Respect to Objectives for the Agency’s Action
- •TABLE 2.2-3 Proposed SEZs and Approximate Acreage by State
- •TABLE 4.15-3 ACECs Designated for Protection of Cultural Resource Values That Are near BLM-Administered Lands Available for Application through the Variance Process
- •TABLE 6.1-2 Summary-Level Assessment of Potential Environmental Impacts of Utility-Scale Solar Energy Development by Alternative
- •TABLE 6.4-1 Comparison of BLM’s Alternatives with Respect to Objectives for the Agencies’ Action
- •TABLE 6.5-10 Recreational Visits for the BLM and NPS in FY 2000 and FY 2010 and for USFS in FY 2000 and FY 2010
1 development assumed to occur on the variance lands, the program alternative meets the projected 2 demand for solar energy development.
3
4
5 6.2 IMPACTS OF THE SEZ PROGRAM ALTERNATIVE
6
7Under the SEZ program alternative (hereafter referred to as the “SEZ alternative”), the
8 BLM would adopt the same set of programmatic ROW authorization policies and design features
9for utility-scale solar energy development as proposed under the program alternative, but would
10authorize such solar energy development only within SEZs. Unlike the program alternative,
11lands outside of SEZs would be excluded from utility-scale solar energy ROW applications.
12Under this alternative, about 285,000 acres (1,153 km2) of BLM-administered lands would be
13available for ROW applications. As part of this Final Solar PEIS, the BLM has also proposed a
14protocol to identify new or expanded SEZs (see Section A.2.6 of Appendix A). Per the proposed
15protocol, new SEZs would be relatively large areas that provide highly suitable locations for
16utility-scale solar development: locations where solar development is economically and
17technically feasible, where there is good potential for connecting new electricity-generating
18plants to the transmission distribution system, and where there is generally low resource conflict.
19The identification of new or expanded SEZs would have to go through a land use planning
20process and would be subject to the appropriate environmental analysis.
21
22Under the SEZ alternative, the elements of the BLM’s new program under this alternative
23would be implemented through amendment of the land use plans within the six-state study area
24and other applicable policy-making tools.
25
26The following subsections discuss the effectiveness of the SEZ alternative in meeting the
27BLM’s established program objectives and describe the potential environmental impacts of the
28alternative.
29
30
31 6.2.1 Facilitate Near-Term Solar Energy Development (Pace of Development)
32
33The impacts on the pace of development under the SEZ alternative would be much the
34same as those described for the program alternative in Section 6.1.1. Elements of the
35authorization process (including the proposed competitive process) and incentives for projects in
36SEZs described in this Final Solar PEIS (Section 2.2.2.2.3) could reduce the amount of time and
37resources allocated by government, developers, and stakeholders to obtain ROW authorizations.
38As with the program alternative, these outcomes would likely increase the agency’s ability to
39meet the mandates of the Energy Policy Act of 2005 and Secretarial Order 3285A1 (Secretary of
40the Interior 2010).
41
42
43 6.2.2 Minimize Environmental Impacts
44
45Similar to the program alternative, environmental impacts under the SEZ alternative
46would be minimized in the following ways:
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1• SEZs have been identified as areas where there is generally low resource
2 |
conflict. Because the land area for utility-scale solar energy development |
3 |
would be restricted to SEZs, known sensitive resources would be avoided for |
4 |
the most part, SEZ-specific design features would protect sensitive resources |
5 |
identified in SEZs, and uncertainty regarding the distribution of impacts, |
6 |
including possible fragmentation of habitat, would be reduced. |
7 |
|
8• The proposed programmatic and SEZ-specific design features would address
9 |
the full array of potential impacts associated with each phase of development. |
10 |
In addition, regional mitigation plans for SEZs would be developed to address |
11 |
unavoidable resource impacts. |
12 |
|
13 |
• The concentration of development in the SEZs could allow for the |
14 |
consolidation of related infrastructure (e.g., roads, transmission lines) and less |
15 |
total land disturbance. |
16 |
|
17 |
• Additional environmental analysis, and the coordination and/or consultation |
18 |
with other federal and state agencies, government-to-government consultation, |
19 |
and public input required prior to authorization of individual projects in SEZs |
20 |
would ensure thorough review of the proposed locations of development. |
21 |
|
22 |
• The requirement to implement a monitoring and adaptive management |
23 |
strategy would ensure that appropriate mitigation measures would be |
24 |
implemented if unforeseen impacts were identified during project planning, |
25 |
construction, and/or operations. |
26 |
|
27 |
• Because of the closer proximity of individual solar development projects to |
28 |
one another that could occur under the SEZ alternative, cumulative impacts |
29 |
for some resources (e.g., water, visual, and socioeconomics) in localized areas |
30 |
around the SEZs could be high; however, the certainty of the project locations |
31 |
might allow these impacts to be more easily addressed. An analysis of the |
32 |
potential cumulative impacts for each SEZ was included in Chapters 8 |
33 |
through 13 of the Draft Solar PEIS and has been updated as necessary for the |
34 |
Final Solar PEIS. |
35 |
|
36By making a specific set of lands available for ROW application (285,000 acres
37[1,153 km2]), the BLM may limit opportunities to site solar energy projects on lands determined
38to be degraded or previously disturbed. However, the BLM’s proposed protocol to identify new
39SEZs emphasizes the use of degraded, disturbed, or previously disturbed areas, including
40possible partnerships with nonfederal landowners, as appropriate places to site new SEZs
41(see Section A.2.6 of Appendix A).
42
43Table 6.1-2 summarizes the environmental impacts that might be associated with
44solar energy development under the SEZ alternative and the extent to which the impacts would
45be mitigated by the programmatic exclusions, policies, and design features. As reflected in that
46table, it is not possible to fully assess the impacts on some resources (e.g., specially designated
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1areas and lands with wilderness characteristics, recreation, military aviation, water resources,
2 vegetation, wildlife and aquatic biota, special status species, visual resources, cultural resources, 3 Native American concerns, and environmental justice), because they are dependent on specific 4 project details not defined at the programmatic level. This type of analysis would be conducted 5 through additional project-specific analyses that would be required prior to the development of 6 projects in SEZs.
7
8Through the SEZ-specific analyses completed as part of the Draft Solar PEIS, the BLM
9discovered some potentially significant impacts on various resources and resource uses that
10could result from solar energy development in the SEZs. As discussed in detail in Section 6.1.2
11on the program alternative, modifications made to the SEZs, along with implementation of
12ROW authorization policies and programmatic and SEZ-specific design features would minimize
13environmental impacts of development in the SEZs.
14
15It is anticipated that the program elements that make up the SEZ alternative would
16collectively allow the BLM to effectively identify and avoid, mitigate, and minimize potential
17adverse environmental impacts.
18
19
20 6.2.3 Minimize Social and Economic Impacts
21
22The potential socioeconomic impacts of the SEZ alternative would be similar to those
23described for the program alternative; however, both the economic benefits and the potential
24adverse economic and social impacts would be concentrated solely in the vicinity of the SEZs.
26The BLM would incur agency-related costs associated with developing, implementing,
27and managing solar energy development on BLM-administered lands. This is particularly true in
28SEZs where the BLM has committed to undertaking upfront site-specific analyses and
29consultations as well as incentives. For all projects in SEZs, the federal government will collect
30income from ROW rental payments, which include an acreage component and capacity fee
31component. Further, as discussed in Section 2.2.2.2.1 in this Final Solar PEIS, the BLM is
32proposing to offer lands within SEZs through a competitive process (see Section 2.2.2.2.1 of this
33Final Solar PEIS), which could result in increased revenue to the federal government. A
34competitive process, however, could increase costs for developers of solar facilities.
35
36
37 6.2.4 Provide Flexibility to Solar Industry
38
39By making fewer BLM-administered lands available for utility-scale solar energy
40development as compared to the program alternative, the SEZ alternative could reduce the
41flexibility of both the agency and developers in terms of identifying appropriate locations for
42utility-scale development. There are likely to be economically attractive sites for solar energy
43development outside of the SEZs that can meet the environmental protection measures outlined
44in the Solar PEIS. It is important to note, however, that the BLM is committed to evaluating the
45need for new or expanded SEZs in each of the six states a minimum of every 5 years as
46described in the proposed SEZ identification protocol (see Section A.2.6 of Appendix A). The
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1BLM will also allow petitions for new or expanded SEZs to consider solar energy development
2in specific areas of interest to industry. Consistent with existing regulations, applicants may
3 request that the BLM amend a land use plan to allow for an otherwise nonconforming proposal 4 (BLM Land Use Planning Handbook H-1601-1, Section VII(B) [BLM 2005]). While this may
5allow for some flexibility to develop outside of the currently proposed SEZs, it does not provide
6the same level of flexibility as the variance process proposed under the program alternative
7 (because a land use plan amendment would be required for development outside of SEZs in all 8 cases under the SEZ alternative).
9
10
11 6.2.5 Optimize Existing Transmission Infrastructure and Corridors
12
13Under the SEZ alternative, future solar energy development would be limited to SEZs.
14All of the proposed SEZs are located near existing transmission lines and/or corridors, and
15development in the SEZs is expected to make use of this existing transmission infrastructure.
16Under the SEZ alternative, however developers would have fewer opportunities to take
17advantage of other existing transmission infrastructure as compared to the program alternative.
19The BLM is proposing to undertake a variety of activities that will help steer future
20utility-scale solar energy development to the SEZs (see Section 2.2.2.2.3 of this Final Solar
21PEIS). These include an evaluation of the transmission needs and impacts to support anticipated
22solar development within SEZs and a commitment to engage in ongoing and comprehensive
23transmission planning efforts to ensure the recognition of SEZs as a priority in transmission
24development. The BLM will also offer incentives to developers willing to build transmission to
25SEZs. In addition, the BLM’s proposed SEZ identification protocol takes into account proximity
26to existing transmission infrastructure (see Section A.2.6 of Appendix A). Further, the BLM will
27allow petitions for new or expanded SEZs to consider solar energy development in specific areas
28of interest to industry such as in proximity to new foundational transmission lines.
29
30
31 6.2.6 Standardize and Streamline the Authorization Process
32
33The SEZ alternative would standardize requirements and reduce uncertainty for project
34applicants. It would streamline project review and approval processes, and ensure consistency in
35how utility-scale ROW applications are managed. Because the SEZ alternative would limit
36utility-scale development to those areas most intensively studied in the Solar PEIS, it is likely
37that BLM staff efforts to review and approve ROW applications would be reduced under this
38alternative (due to the opportunity for extensive tiering to the analyses presented in the Solar
39PEIS and the decisions implemented in the resultant ROD and land use plan amendments).
40
41
42 6.2.7 Meet Projected Demand for Solar Energy Development
43
44Assuming a build-out of 80% of the total land area within the currently proposed SEZs
45over the 20-year study period, the amount of land available for development under the SEZ
46alternative would be about 228,000 acres [923 km2]). Across all six states, the total lands
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