Selby Rocks on Carrizo Plain

Contents

• Why Cal French walked across California, March 20-May 5, 2011
• 2/01/11:  A Chorus of Concern on Carrizo Solar Projects
• 5/22/09: Comments on the Draft Resource Management Plan
• Updates
• Our Position on Solar
• No Drilling
• Carrizo Plain National Monument Overseers
• Carrizo Plain Overview
• An Apparent Past
• Human History
• The Underground Landscape
• Looking Back, Going Forward
• How to Get There
• Lodging and Camping Facilities
• Additional Information
• The Nature Conservancy's Carrizo Plain (Home Page)
• The BLM's Information Page on Carrizo Plain
  

A Chorus of Concern on Carrizo

Following are representative excerpts of comments filed by environmental groups and the California Dept. of Fish and Game on the environmental impact reports of the California Valley Solar Ranch and Topaz Solar Farm. Full text at: http://www.slocounty.ca.gov/planning/environmental/EnvironmentalNotices/optisoloar/responses.htm

and http://www.sloplanning.org/EIRs/CaliforniaValleySolarRanch/index.htm#v2

Audubon Society

While Audubon California supports renewable energy to reduce the impacts of climate change, we advocate for avoidance of habitat disturbance over mitigation. We are especially concerned about the inadequate level of effort in the DEIR on the many species of birds in the project vicinity.... The science is insufficient to know with a reasonable degree of certainty whether a mobile species, such as the Kit Fox or Pronghorn Antelope, will utilize the corridors between solar arrays, or whether foxes will pass through the fencing and use the solar array areas themselves.

Center for Biological Diversity

It is hard to imagine a proposed project site with more endangered and imperiled species on site than the project described in the [CVSR] EIR. The proposed project will result in significant unmitigable impacts to biological resources both on the proposed project site and cumulatively for the region.... The DEIR fails to consider potential alternatives that would protect the most sensitive lands from future development. Alternative siting such as the Westlands Solar Park, which is on abandoned agricultural fields, and alternative technologies (including distributed PV on commercial rooftops and near existing substations) should have been fully considered in the DEIR, because these alternatives would eliminate the impacts to species, soils, and water resources in the California Valley, which is part of the larger Carrizo Plain.... In its discussion of the need for renewable energy production, the [Topaz] DEIR fails to address risks associated with global climate change in context the need for climate change adaptation strategies (e.g., conserving intact wild lands and the corridors that connect them). All climate change adaptation strategies underline the importance of protecting intact wild lands and associated wildlife corridors as a priority adaptation strategy measure….. [The project] could undermine a meaningful climate change adaptation strategy with a poorly executed climate change mitigation strategy. The way to maintain healthy, vibrant ecosystems is not to fragment them and reduce their biodiversity.

Defenders of Wildlife

Despite Project improvements, the DEIR has multiple flaws. It fails to analyze a reasonable range of alternatives, narrowly defining the project's objectives in such a way as to preclude assessment of many viable alternatives on private and public degraded land. In addition, the DEIR does not adequately address the significant loss of habitat and cumulatively significant impacts of a project that spans more than 2,000 acres of relatively undisturbed grassland.... The Westlands CREZ Alternative is feasible based on a CEQA feasibility analysis. It is capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.... It should be considered for adoption due to the inability to mitigate impacts to San Joaquin kit fox and giant kangaroo rat on the proposed project site.

Natural Resources Defense Council

The two projects impact the same species of concern and together have the potential to significantly reduce the width and permeability of a key migration corridor that runs up and down the Carrizo Plain.... impacts to [kit fox] will have cumulative impacts far beyond Carrizo that will prevent recovery of the species.... Given the significant impacts of the project and the cumulative impacts anticipated if both projects mentioned above are developed, we are very concerned about the lack of a clearly described mitigation plan in the DEIR

The Nature Conservancy

Based on the wide-ranging impacts to species and the lack of sufficient, effective and appropriate mitigation, the Conservancy must register deep concern with the project.... The mitigation package should not include fragmented lands within the project's footprint that are unused for photovoltaic panels...because of the uncertainty as to whether kit fox or other wide-ranging species would actually use these sites.... Without a thorough plan to accomplish these goals and others, efforts to mitigate losses to San Joaquin Valley threatened and endangered species could fail, exacting a devastating toll on the Carrizo Plain core populations and recovery of the species overall.

North County Watch

Although the large scale industrial solar project that is the subject of this EIR is located outside the Carrizo Plain National Monument on adjacent private lands, its development and operation will necessarily have significant, irreversible, individual and cumulative adverse spillover effects on vital public values of the Monument.… The significant adverse effects on the essential, intrinsic values of the Monument – its isolation, tranquility, visual integrity, cultural sacredness – cannot be mitigated and are scarcely discussed in the DEIR. 

Sierra Club

We are concerned with the [Topaz] DEIR's finding that “the Proposed Project would contribute to a cumulatively considerable impact to wildlife connectivity or corridors when combined with impacts from past, present, and reasonable future projects (Class I for San Joaquin Kit Fox).” Specifically, “the two solar projects that would be located in the Carrizo Plain would reduce the existing corridor available to wildlife by 50 percent, nearly bisecting the Carrizo Plain into a north and south section.” the DEIR proposes that “For SJKF, while impacts related to habitat loss may be mitigated through the acquisition and conversion of agricultural lands to more compatible uses, ultimately these projects would be major barriers to movement in the region….” The DEIR's vague reference to “dramatic cost reductions” in residential and commercial solar PV technology since 2007 should be replaced with actual, current figures for purposes of comparison.… Southern California Edison's 500MW urban warehouse PV project is based on First Solar's PV technology and demonstrates that distributed PV installations can be built in urban areas cost-effectively.

California Department of Fish and Game

The Department recommends that this Project be relocated to impaired agricultural lands in the Central Valley, or to otherwise disturbed lands that are not considered critical for the recovery of multiple State and Federally listed species.... Any project in the Westlands CREZ would substantially reduce or even eliminate impacts to the species that occur on the proposed project site. Many of the species do not even occur within the Westlands CREZ, which is expected to support only low numbers of a few special status species.

March 2009
The Carrizo Management Plan Needs You

The Bureau of Land Management has released the public dreaft of the Resource Mangement Plan for Carrizo Plain National Mangement Plan (RMP). Now they need to hear from you.

Specifically, they need to hear that the Monument is a special and fragile place –that’s why it was given special status and the way it is management should be special, too.

The Carrizo Plain National Monument is a uniquely diverse landscape. It is a singular place of national and worldwide significance.

Its species, communities and ecosystems are extremely rare and imperiled. The very future of its extraordinary plants and animals, unique ecosystems and other outstanding features could very well depend on the decisions made in the RMP.
Because of its significance, designation as a National Monument and inclusion in the National Landscape Conservation System, the BLM should manage the Carrizo Plain National Monument differently than other BLM lands. The BLM should prioritize resource preservation.

The Natural Area Plan and the preferred alternative in the February 2004 draft of the Environmental Assessment provided a solid foundation for future management. The BLM should build upon these recommendations.

The valuable and fragile evidence of pre-historic and historic peoples should be protected. Painted rock and other archaeological and historic sites within the Monument preserve an important span of history. The BLM should ensure that it manages the Monument to provide for their preservation and restoration.
The road system on the ground should support transportation needs around the Monument, but must also support protection of the Monument’s natural values:
The natural splendor of the Monument is best protected by limiting the number of roads. The BLM should limit the roads in the Monument to those that support the mission of protecting the Monument’s values.

The BLM should consider the road network and fencing across the Monument in the context of the connectivity of the landscape.

The BLM should consider removing fences which inhibit the movement of pronghorn.
The BLM should consider closing and rehabilitating redundant roads, roads that serve no visitor or administrative purpose, and roads in sensitive resources areas.

There are a number of locations where off-road vehicle use is occurring contrary to the Monument proclamation and the current management plan. The BLM should document off-road vehicle use, analyze its impacts and develop a plan to address the impacts including signage, law enforcement and restoration.

Grazing/invasive species need to be managed to protect the natural environment. The BLM should analyze the impacts of livestock grazing to plant and animal species and ecosystems. The BLM should permit livestock grazing only if it can be demonstrated to benefit native species and ecosystems.

The BLM should consider phasing out the remaining long-term grazing leases and replacing them with annual free use permits if grazing is used as a resource management tool.

Invasive species need to be managed to protect the natural environment, but the BLM should permit livestock grazing only if it can be demonstrated to benefit native species and ecosystems. Livestock grazing has been found to be detrimental to plant and animal species and ecosystems in the Carrizo Plain National Monument.

The BLM should develop fire management policies and prescriptions for the Monument which provide for the use of naturally occurring fire to restore and maintain the Monument’s species and ecosystems.

Oil and gas drilling can impact the natural landscape, plants and animals:  The BLM needs to address the potential impacts of oil and gas drilling on split estate lands.

Only responsible hunting and firearm use should be permitted. Hunting is one of many ways that visitors use the monument. However, the BLM should consider the impacts of non-game hunting to the Monument’s ecosystems and to threatened and endangered species found on the Carrizo Plain, including the San Joaquin kit fox and the San Joaquin antelope squirrel. The BLM should consider limiting hunting to game species in season.

The BLM should consider prohibiting the use of lead bullets, because lead poisoning from those bullets can kill the California condor, an endangered species, golden eagles, and other raptors.

Target shooting can result in the accumulation of litter, soil contamination by lead and wildfires. It can also impact the safety and experience of visitors. The BLM should maintain its current policy of directing target shooters to facilities outside the Monument.

Now is the time to develop a smart approach to managing visitors to the Monument Visitor use is expected to increase and the BLM should identify ways to accommodate current and future visitor use in a way which will prevent or lessen the potential impacts of visitor use.

In the spring of 2007, the Bureau of Land Management renewed the long-delayed planning process for Carrizo Plain National Monument, including the preparation of a broad environmental impact statement. This "scoping process" is to address the circumstances and values inherent in management of the 250,000 acres of public lands contained within the Carrizo Plain
National Monument, an important unit of the National Landscape Conservation System (NLCS).

The designation of National Monuments, together with the establishment of the NLCS, represents the cornerstone of a new era in land stewardship. The eyes of the nation will be focused on the results achieved, and on the BLM's ability to fulfill this new mission of stewardship to: "conserve, protect, and restore these nationally significant landscapes that have outstanding cultural, ecological, and scientific values for the benefit of current and future generations."

Read the comments of The Wilderness Society, Los Padres ForestWatch, Sierra Club, California Wilderness Coalition, Defenders of Wildlife, Center for Biological Diversity, Californians for Western Wilderness, Western Watersheds, and Natural Resources Defense Council on the scope of the process that BLM should undertake to protect this priceless natural landscape in San Luis Obispo County.

TAKE ACTION
Copies of the CPNM Draft RMP/Draft EIS are available online www.ca.blm.gov/bakersfield. Comments are due by April 22. Send your comments via fax: (661) 391-6143, email at cacarrizormp@ca.blm.gov, or mail to:
CPNM RMP
Bureau of Land Management
3801 Pegasus Drive
Bakersfield CA 93308

June 2008
What Price Solar?

On April 11, I attended my third California Energy Commission (CEC) meeting dealing with the proposed Thermal Solar energy facility proposed for Carrizo Plain. The electricity will be generated with a stream generator. The plant will use curved mirrors to focus the sun on a system of water filled pipes, creating steam to run the generators. The Carrizo Energy Solar Farm (CESF) is designed to generate 177 megawatts. The facility will have a standard 115-foot cooling tower and 40-foot observation towers. The plant will cover one square mile and be enclosed by a 10-foot chain link fence. Ausra is the applicant. Ausra has an option to buy an adjacent 2000 acres for its construction lay down site and future expansion. Solar facilities on the Carrizo offer a 10-15% greater efficiency. Construction could take up to 3 years, involve hundreds of employees on multiple shifts, and have 50 permanent employees. The Plain is remote and difficult to access. It has been the ancestral home of the Chumash Indians for as long as 15,000 years.
 
Ausra estimates that the plant will use 22 Acre Feet per Year of water and infrequently a peak daily usage of 700,000 gallons per day. CEC staff is concerned that Carrizo Plain may currently be in an overdraft situation. According to CEC documents, the safe yield of the aquifer is 600 AFY. The existing water demand is 930 AFY and projected to rise in the future.
 
The environmental impacts will be assessed by the CEC under a process called Preliminary Assessment which closely parallels a CEQA review.
 
The environmental impacts are extensive. The Carrizo Plain and the Carrizo National Monument are home to several federally endangered, threatened and rare species including the San Joaquin Kit Fox, blunt-nose leopard lizard, San Joaquin antelope squirrel, and the giant kangaroo rat. It provides habitat for many listed species including the California jewelflower, Hoover’s wool-star and San Joaquin woolythreads.
 
Other State and federally listed endangered species or, species of concern that could be affected by the project include the Tulare grasshopper mouse, Tipton kangaroo rat, and Pallid bat.
 
The Carrizo is critical habitat for the condor, has thriving herds of reintroduced pronghorn antelope and Tule elk. The location proposed for the plant and the lay down area are favorite pasturing and calving sites for the antelope. Fencing will impede the movement of these and other animals. A variety of raptors use the area for roosting, nesting, foraging and wintering.
 
The site and construction lay down area are bisected by an environmentally significant water carrying swale. If it is determined that this drainage is under the jurisdiction of the U.S. Fish and Wildlife Service through the Endangered Species Act Section 10 process, the preparation of a Habitat Conservation Plan will be required.

Incidental Take Permits and Streambed Alteration Permits may be required and would be under the jurisdiction of California Fish and Game. Fish and Game has determined that this project would likely result in a “take” of the California listed and Federally endangered San Joaquin Kit Fox and may affect other listed species. Impacts to State listed species under the California Endangered Species Act (CESA) must be fully mitigated, a standard much more stringent than CEQA’s requirement to mitigate to less than significant level. The site impacts Wildlife and Habitat Corridors and would likely require habitat mitigation at a ration higher than 4:1 to fully mitigate habitat loss. Habitat of equal or higher biological value would be required for off-site mitigation.
 
The California Department of Fish and Game has determined that “The project would create a substantial, permanent, impermeable barrier for pronghorn at the highway (58) and within the core of one group’s home range. It would further degrade connectivity between all of the pronghorn groups in San Luis Obispo county.” (Document submitted to CEC by DFG, March 26, 2008)
 
In addition to this proposal, Opti-solar has initialized discussions with the county for the permitting of a 550 MW photovoltaic facility adjacent to the CESF site. The Opti-solar plant would cover 8 square miles. This facility would be likely to generate similar environmental impacts. The cumulative impacts of the two facilities on the Carrizo Plain would be considerable.
 
The approval process will take up to one year. 

April 2008
Carrizo's Not For Drilling

With the price of a barrel of oil climbing ever skyward, the same question that has defined the long fight over drilling for oil in the Arctic National Wildlife Refuge has now become much more immediate for San Luis Obispo County: Is it worth destroying one of the Earth’s special places for a small potential amount of oil?

The answer to that question is heading our way in the form of a proposal by Vintage Production, a subsidiary of Occidental Petroleum, to explore for oil in the Carrizo Plain. Although Carrizo is a National Monument, the mineral rights for about half of its 250,000 acres remain in private hands.

"The Carrizo Plain National Monument is a very special place," said Alice Bond of the Wilderness Society. "It is home to the highest concentration of threatened and endangered species in California, including the giant kangaroo rat, San Joaquin kit fox, and the blunt-nosed leopard lizard. It is one of the last remaining remnants of the San Joaquin grassland ecosystem providing essential habitat to these species."

These fauna, as well as the endangered plant species and Carrizo’s status as critical habitat for the California condor and the first site in the state to host reintroduced pronghorn antelope and herds of Tule elk, make a any proposal for industrial activity there acutely problematic. Bond points out that "thousands of acres outside the Monument boundaries have already been severely impacted by oil and gas operations, which is why the National Monument is so important to these species."

Vintage proposes to use thumper trucks, which deploy seismic equipment to transmit powerful vibratory sound waves deep into the earth. Additional exploration would involve dynamiting and drilling exploratory wells, all within the known range of the endangered giant kangaroo rat -- which burrows underground and thumps to communicate -- and all obviously highly destructive.
The Bureau of Land Management is tasked with protecting the natural and cultural "objects" – plants, animals, glyphs, geological features — of the Monument. "Thumper trucks, underground explosions, and all the other exploratory activities are going to disturb the objects," said Cal French, Chair of the Sierra Club’s California-Nevada Regional Conservation Committee. "If Vintage then finds enough to start drilling wildcats, then a whole new round of assaults will ensue. If they do find significant oil, driving along Soda Lake Road will be like a trip from Maricopa to McKittrick."

Vintage Production does not have a reputation as a good steward of the land. "They are responsible for last year’s oil spill in the Los Padres and nearly a dozen others in the forest over the past four years," said Jeff Kuyper, Executive Director of Los Padres ForestWatch.

The Sierra Club, Wilderness Society, ForestWatch and many other local, state and national organizations are committed to the defense of Carrizo Plain, and will not permit its destruction for a negligible amount of oil. The BLM must closely scrutinize any exploration applications, finalize the update of the Resource Management Plan (see "What Carrizo Needs Now," July 2007 Santa Lucian) and have strong wildlife standards in place before allowing any exploration.

Carrizo Plain National Monument Overseers

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Carrizo Plain Overview

There is, on the Carrizo a wildness--wildness on a scale that allows us to imagine what much of California was like 300 years ago. Known to the Spanish as "Llano Estero," or salt marsh plain, this arid and treeless basin harbors the largest remaining example of habitats that were once abundant in the southern San Joaquin Valley. Most of the surviving habitat is protected within the boundaries of the 180,000-acre Carrizo Plain National Monument where an array of rare plants and animals, including the greatest concentration of threatened and endangered vertebrates in the state, continue to thrive.

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An Apparent Past

Soda Lake, the centerpiece of the plain, is all that remains of this prehistoric sea. One of the largest undisturbed alkali wetlands in the state, the 3,000-acre lake provides important habitat for migratory birds, including shorebirds, waterfowl and a quarter of the state's wintering sandhill crane population. With no outlet, the water that pools in the lake during the winter evaporates leaving behind a glistening expanse of sulfate and carbonate salts that appear to ripple and sway in the heat waves of summer.

View of Soda Lake

The San Andreas Fault, Wallace Creek

Nowhere does the Carrizo flaunt its geologic past as it does on the northeastern edge of the plain where the San Andreas Fault cuts through the foot of the Temblors. Here stream channels suddenly shift up to one-half mile north as they cross the fault line, and fault-trimmend ridges rise sharply from plain to form the Panorama and Elkhorn Hills. This complex and corrugated topography, the most spectacular along the fault's 650 mile long corridor, is best viewed in the long, soft shadows of early morning and late afternoon.

Human History

Great herds of horses, cattle and sheep thrived on the diverse vegetation. Eventually this overgrazing destroyed much of the native flora. Seeds of exotic plants, many of which were inadvertently carried in the hair, wool and feet of the Spanish livestock, found the overgrazed range a perfect place to germinate and grow. Today, more than half the grasses and other flowers that bloom on the Carrizo each spring, as in most grasslands across the state ar plants native to Europe and Asia.

Dryland grain farming joined ranching as a major human use of the Carrizo Plain in 1885, when the first homesteaders began to settle here. In was not until 1912, however, and the advent of mechanized agriculture, that large-scale farming became possible. In the years between the two world wars, vast acres of grassland were put under the plow even though the Carrizo's limited and unpredictable rainfall, averaging 8-10" per year, made such ventures risky. The plow lines visible along the foothills bordering the plain serve as reminders of those human days.

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The Underground Landscape

Burrowing animals do more than find protection when they dig underground. By turning and mixing large quantities of soil, fertilizing it with their waste, and dispersing seeds, they also play an important role in maintaining plant communities on the Carrizo.

Like animals, more than half of the plant life on the Carrizo is hidden below ground. Native perennial plants, such as common saltbush and desert needlegrass, survive the drying effects of the Carrizo's sun and wind by tapping deep water sources with their enormous root systems. This strategy is markedly different from that of the shallow rooted annual plants, which escape the Carrizo's harsh environment by flowering, setting seed and dying before the dry summer heat sets in.

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Looking Back, Going Forward

Other steps are being taken to restore the Carrizo Plain to pre settlement conditions. Cattle grazing is being used as a tool to shift the competitive balance between the exotic annual grasses that come up in the early days of spring. Before the later blooming native perennials begin their period of rapid growth the cattle are taken off the range. Years of this type of management should favor the reestablishment and expansion of the Carrizo's native flora.

Natural history studies of the Plain's many imperiled plants and animals are also underway. This research will help shape management strategies for sensitive species, like the blunt-nosed leopard lizard and the California jewel flower, on the Carrizo Plain and elsewhere.

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How to Get There

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Lodging and Camping Facilities

• Carrizo Plains Lodge
  12906 Soda Lake Road
  California Valley, CA 93453
  (805)475-2363
  
  
• Selby Campground
  Primitive Camping, horse corral
  No water, Pit Toilet

 

• KCL Ranch Campground

Primitive Camping
No water, Pit Toilet

Additional Information

• The Nature Conservancy

Carrizo Plain National Monument
P.O. Box 3098
California Valley, CA 93453
(805)475-2360
• Guy L. Goodwin Education Center

Carrizo Plain Visitor Center
California Valley, CA 93453
(805)475-2131
• Bureau of Land Management

Caliente Resource Area
3801 Pegasus Drive.
Bakersfield, CA 93308-6837
• California Dept. of Fish and Game

Region 3
P.O. Box 47
Yountville, CA 94599

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