The Large-Scale Solar Association (“LSA”) and the Solar Energy Industry Association (“SEIA”) (collectively “Joint Parties”) offer these comments in response to the Draft Best Management Practices and Guidance Manual for Desert Renewable Energy Projects (hereinafter“BMP Recommendations”). Executive Order S-14-08 directs the State’s agencies to plan for and implement a 33% renewable portfolio standard (“RPS”) by 2020 and to develop BMP Recommendations. The Joint Parties appreciate the opportunity to have participated in the October 13th workshop on the RPS Executive Order, S-14-08 and are looking forward to participating in developing the Desert Renewable Energy Conservation Plan (“DRECP”). The Joint Parties support the work called for by S-14-08. Advancing the State’s goal of increasing renewable energy and decreasing greenhouse gas (“GHG”) emissions is not inconsistent with protecting the State’s environmental resources. Environmental stewardship and GHG reduction goals can and should be aligned through policies that recognize an appropriate balance between the two. Both may be achieved through careful and integrated planning that takes into account both the complementary goals of protecting the State’s natural resources and promoting the development of environmentally compatible renewable generating facilities. To further these objectives, collaboration among the various stakeholders will be necessary.
As discussed in further detail below, the S-14-08 process should be more transparent than is contemplated by the BMP Recommendations. The conservation and renewable development communities must be more closely involved in development of the draft study areas for the DRECP. The draft BMP Recommendations are helpful in informing developers of work that should be done prior to filing applications, but certain aspects of the document require further vetting. For example, the direction to obtain a power purchase agreement (“PPA”) and a system impact study prior to filing an Application for Certification (“AFC”) is commercially unrealistic.
In addition, the BMP Recommendations should not be adopted by the Renewable Energy Action Team (“REAT”) agencies and should remain an informational, guidance document. The DRECP and the BMP Recommendations should also be further clarified to not apply to projects that are currently in the permitting pipeline. These and other more specific comments on the BMP Recommendations are detailed below.