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7 ANALYSIS OF DOE’S ALTERNATIVES

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Through this PEIS, DOE is evaluating two alternatives: a proposed action (action

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alternative) and a no action alternative (see Section 2.3).

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DOE developed the proposed environmental guidance presented in Section 2.3.2 of this

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Final Solar PEIS to facilitate the advancement of solar energy development. Under the proposed

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action, DOE would adopt this programmatic guidance, including recommended environmental

10practices and mitigation measures, for consideration in its investment and deployment strategies

11and decision-making process. This guidance would provide DOE with a tool for making more

12informed, environmentally sound decisions on DOE-supported solar projects. In the Final

13Programmatic EIS, DOE has identified the proposed action (action alternative) as its preferred

14alternative.

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16The proposed action has been developed to support DOE in meeting the mandates

17discussed in Section 1.1 of this Final PEIS that provide the purpose and need for agency action.

18Specifically, these mandates are established by E.O. 13212, “Actions to Expedite Energy-

19Related Projects” (Federal Register, Volume 66, page 28357, May 22, 2001); E.O. 13514,

20“Federal Leadership in Environmental, Energy, and Economic Performance” (Federal Register,

21Volume 74, page 52117, Oct. 5, 2009); and Section 603 of EISA (P.L. 109-58). Collectively,

22these mandates require DOE to promote, expedite, and advance the production and transmission

23of environmentally sound energy resources, including renewable energy resources and solar

24energy and, in particular, cost-competitive solar energy systems at the utility scale.

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26Under the no action alternative, DOE would continue to conduct environmental reviews

27of DOE-supported solar projects on a case-by-case basis. It would not adopt programmatic

28guidance regarding environmental practices and mitigation recommendations to apply to DOE-

29supported solar projects.

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31This chapter presents an analysis of DOE’s two alternatives in terms of their

32effectiveness in meeting the mandates established for the agency. Specifically, the alternatives

33are analyzed in terms of their potential to affect the pace and cost of solar energy development,

34the environment, and socioeconomic setting.

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36Sections 7.1 and 7.2 present the analysis of the two alternatives. Section 7.3 discusses

37the cumulative impacts of the alternatives. Section 7.4 discusses the other NEPA considerations

38related to the proposed action, including unavoidable adverse impacts, short-term uses of the

39environment and long-term productivity, irreversible and irretrievable commitment of resources,

40and mitigation of adverse impacts.

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Final Solar PEIS

7-1

July 2012

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7.1 IMPACTS OF DOE’S PROPOSED ACTION

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The proposed guidance presented in Section 2.3 is intended to better enable DOE to

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comprehensively determine where to make technology and resource investments to minimize

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the environmental impacts of solar technologies for DOE-supported solar projects.

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DOE could also consider the proposed guidance in establishing environmental mitigation

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recommendations to be considered by project proponents. The recommendations contained in the

9guidance, which are based upon the analysis of impacts of solar energy development and

10potentially applicable mitigation measures presented in Chapter 5 of the Draft and Final Solar

11PEIS, would help DOE ensure that adverse environmental impacts of DOE-supported solar

12projects would be avoided, minimized, or mitigated.

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14Collectively, streamlined environmental reviews and quicker project approval processes

15would likely increase the pace of DOE-sponsored development and reduce the costs to industry,

16regulatory agencies, and stakeholders. These outcomes would support the mandates of

17E.O.s 13212 and 13514 and Section 603 of EISA.

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19Increasing the pace of solar energy development would, in turn, translate into other

20benefits. Utility-scale solar energy development would result in reduced GHG emissions

21and combustion-related pollutants, if the development results in avoided electricity generation by

22fossil fuel power plants (see Section 5.11.4 of the Draft and Final Solar PEIS). If the pace of

23solar energy development is faster as a result of DOE’s proposed action, the potential beneficial

24impacts of reduced GHG emissions would be realized at a faster rate.

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26Utility-scale solar energy development would result in local and regional economic

27benefits in terms of both jobs and income created (see Section 5.17.2 of the Draft Solar PEIS).

28The associated transmission system development and related road construction would also

29produce new jobs and income. These benefits would occur as both direct impacts, resulting from

30wages and salaries, procurement of goods and services, and collection of state sales and income

31taxes, and indirect impacts, resulting from new jobs, income, expenditures, and tax revenues

32subsequently created as the direct impacts circulate through the economy. Increasing the pace of

33solar energy development would cause these economic benefits to be realized at a faster pace as

34well.

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36As discussed in Section 5.17.1.1 of the Draft Solar PEIS, there may be some adverse

37socioeconomic impacts resulting from changes in recreation, property values, and environmental

38amenities (e.g., environmental quality, rural community values, or cultural values), and

39disruption potentially associated with solar development. There could also be beneficial

40socioeconomic impacts in these areas resulting from economic growth and a positive reception to

41the presence of a renewable energy industry. Increasing the pace of solar energy development

42would also speed up the pace of these types of socioeconomic changes. At the programmatic

43level, it is difficult to quantify these impacts.

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45In summary, the proposed programmatic guidance that DOE has developed under its

46proposed action would likely minimize the potential adverse environmental impacts of solar

Final Solar PEIS

7-2

July 2012

1 energy development for DOE-supported projects. As a result of adopting this guidance in various 2 DOE solar-related programs, the pace of solar energy development could increase.

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5 7.2 IMPACTS OF THE NO ACTION ALTERNATIVE

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7 Under the no action alternative, DOE would continue its existing case-by-case process 8 for addressing environmental concerns for DOE-supported solar projects. It would not adopt

9programmatic environmental guidance to apply to DOE-supported solar projects. As a result,

10DOE would not undertake any efforts (i.e., programmatic environmental guidance) to

11programmatically promote the reduction of environmental impacts of solar energy development

12or streamline environmental reviews for DOE-supported projects. Such achievements, and the

13potential benefits in terms of increased pace of solar energy development and decreased

14associated costs, might occur under the no action alternative, but they would not be

15programmatically promoted by DOE (by adoption of programmatic environmental guidance

16with recommended environmental practices and mitigation measures).

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19 7.3 CUMULATIVE IMPACTS

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21As discussed in Section 6.5, the purpose of this cumulative impact assessment is to

22determine how the environmental, social, and economic conditions within the six-state study

23area may be incrementally affected by DOE’s alternatives over the next 20 years. The CEQ, in

24its regulations implementing the procedural provisions of NEPA (40 CFR 1500–1508), defines

25cumulative effects as follows:

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27“... the impact on the environment which results from the incremental impact of

28the action when added to other past, present, and reasonably foreseeable future

29actions regardless of what agency (Federal or non-Federal) or person undertakes

30such other actions” (40 CFR 1508.7).

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32Typically, the “incremental impact of the action” is characterized in terms of a specific,

33quantifiable set of activities. In a programmatic impact analysis, this type of characterization

34might be based on a projected amount of development expected to occur as a result of the

35proposed action. DOE and the BLM developed an RFDS for solar energy development in the

36six-state study area over the next 20 years (see Section 2.4), which projects the amount of solar

37energy in megawatts that might be developed in each state by about 2030. The RFDS analysis

38also estimates how many acres of land might be required to support the projected development.

39The projected levels of development and estimated acres developed are presented in Table 2.4-1.

40Across the six-state study area, the RFDS projects that about 6,000 to 32,000 MW of solar

41energy capacity would be developed over the next 20 years on BLM-administered lands as well

42as other federal, state, tribal, or private lands. On the basis of the highest projection, assuming

439 acres/MW (0.04 km2/MW), this amount of development could require approximately

44285,500 acres (1,155 km2) of land.

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Final Solar PEIS

7-3

July 2012