Public Comments on California Draft Best Management Practies: Desert Renewable Energy Projects
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.