RAPID/Best Practices/Landscape-Scale Mitigation
Development of landscape-scale mitigation plans have the potential to increase the effectiveness of conservation measures while streamline permitting of transmission and other renewable energy projects. This would be accomplished by collecting key data regarding sensitive resources, analyzing this data to identify areas that should be avoided to protect key resources or areas that are more appropriate for project implementation, and by defining mitigation requirements for certain resources that could be impacted.
- Hold early discussions with project proponents regarding key design features of proposed projects, so that agencies can identify serious and potentially project-threatening environmental impacts on the front end.
- When creating a landscape-scale mitigation plan, incorporate public involvement strategies early in the process and include agencies, tribes, scientists, resource specialists, non-government organizations, the public, and other stakeholders in order to help inform the identification of important data, conservation priority areas, and other critical aspects of the mitigation planning process.
- For environmental impacts that cannot be avoided, apply new tools that will facilitate meaningful, landscape-level mitigation investments in sensitive areas while, at the same time, enable agencies to guide impactful development to the most appropriate areas.
- To ensure durability of mitigation measures over time establish monitoring programs for landscape-level mitigation plans to evaluate effectiveness through specific metrics, and adjust through adaptive management as needed.
The concept of landscape-scale mitigation is still new to land management agencies, and strategies for implementing landscape-scale mitigation plans are still in development through pilot projects.
Solar Programmatic Environmental Impact Statement (Western Solar Plan) – Identified “solar energy zones” that have fewer environmental conflicts, adequate access to transmission, and other features making them suitable for solar project development. Information about the Western Solar Plan can be found at http://blmsolar.anl.gov/. As part of the Western Solar Plan, there is an ongoing collaborative effort in Colorado to identify a regional mitigation strategy for Solar Energy Zones in the San Luis Valley. Additional information can be found at: http://www.blm.gov/co/st/en/fo/slvfo/solar/solar_regional_mitigation.html.
Geothermal Programmatic Environmental Impact Statement – Contained a landscape-scale mapping analysis across western states that identified “exclusion” lands that are closed to geothermal leasing, and listed stipulations and best management practices for geothermal development. Additional information can be found at: http://www.blm.gov/wo/st/en/prog/energy/geothermal/geothermal_nationwide.html.
Desert Renewable Energy Conservation Plan – The Desert Renewable Energy Conservation Plan (DRECP) is a collaborative effort between the California Energy Commission, California Department of Fish and Wildlife, the U.S. Bureau of Land Management, and the U.S. Fish and Wildlife Service (collectively, the Renewable Energy Action Team) that aims to balance conservation of desert ecosystems with development of renewable energy projects in seven California counties (Imperial, Inyo, Kern, Los Angeles, Riverside, San Bernardino, and San Diego). One of the main goals of the DRECP is to develop an “efficient and effective biological mitigation and conservation program providing renewable project developers with permit timing and cost certainty under the federal and California Endangered Species Acts.”
The DRECP identifies certain areas that should be protected from development for conservation purposes and also areas that are more appropriate for development (Development Focus Areas) throughout the 7-county planning area (22 million acres). The comprehensive Draft DRECP and EIR/EIS published in December 2014. The comment period on the Draft DRECP and EIR/EIS ends in February 2015. The Draft DRECP and EIR/EIS not only evaluates potential impacts to species, habitats, and ecoregions in the 7-county planning area, but also identifies conservation areas in the planning area, and mitigation strategies that apply beyond the boundaries of the conservation areas.
Additional information can be found at: www.drecp.org
In October 2013, the Secretary of the Interior issued Secretarial Order 3330, Improving Mitigation Policies and Practices of the Department of the Interior. The purpose of Order 3330 is to establish a Department-wide mitigation strategy to ensure consistency and efficiency in review and permitting of infrastructure development projects – including high-voltage transmission lines – while conserving natural and cultural resources. The Secretarial Order was a direct response to the May 2013 Presidential Memorandum Modernizing Federal Infrastructure Review and Permitting Regulations, Policies, and Procedures, which directed federal agencies to review and revise permitting regulations with the goal of streamlining these processes while protecting resources.
There are five factors listed in Order 3330 as central to developing this department-wide mitigation strategy:
- The use of a landscape-scale approach to identify and facilitate investment in key conservation priorities in a region;
- Early integration of mitigation considerations in project planning and design;
- Ensuring the durability of mitigation measures over time;
- Ensuring transparency and consistency in mitigation decisions; and
- A focus on mitigation efforts that improve the resilience of our Nation’s resources in the face of climate change.
What is Mitigation?
In the context of energy projects, mitigation can generally be defined as measures taken to avoid, minimize, or reduce the severity of environmental impacts. The “mitigation hierarchy” refers to the order in which mitigation strategies are preferred if possible:
- Avoidance. Avoidance is applied during early project planning when efforts are made to site facilities away from sensitive resources. Avoidance strategies include:
- Not undertaking projects or elements of projects that could result in adverse impacts;
- Avoid impacting environmentally sensitive areas; and
- Implementing preventative measures to stop adverse impacts from occurring.
- Minimization. Minimizing strategies can be applied when impacts are identified to limit the degree, extent, magnitude, or duration of adverse impacts. Minimization strategies include:
- Scaling down proposals;
- Redesigning elements of a project. For example, for visual resources structure type, material, and placement can be varied to reduce visual impact depending on distance, terrain, critical viewpoints, and vegetation; and
- Employing supplementary measures to manage impacts.
- Compensatory Mitigation. When adverse environmental impacts are unavoidable, compensatory mitigation strategies can be used as a “last resort” to offset impacts. Compensatory mitigation strategies that may be employed include:
- Replacement of the same resource values at another location. This could occur through mitigation banking or in-lieu fees.
What is landscape-scale mitigation?
In April 2014, the Department of the Interior released the report “A Strategy for Improving the Mitigation Policies and Practices of The Department of the Interior,” which provides a definition of “landscape-scale” or “landscape-level” mitigation:
- In the mitigation context, the landscape approach dictates that it is not sufficient to look narrowly at impacts at the scale of the project; it is necessary to account for impacts to resource values throughout the relevant range of the resource that is being impacted. While “landscape-scale” and “regional” are not synonymous, they indicate a similar consideration of interacting systems at a scale larger than the ecosystem, and should not be constrained by administrative boundaries.
- David J. Hayes, Deputy Secretary, U.S. Department of the Interior (U.S. Department of the Interior). 2013. Addressing the Environmental Impacts of Large Infrastructure Projects at the Department of the Interior: Making “Mitigation” Matter. 1 Edition. Washington, D.C.: U.S. Department of the Interior.
- Renewable Energy Action Team. Desert Renewable Energy Conservation Plan [Internet]. California. DRECP. [updated 2015/04/30;cited 2015/04/30]. Available from: http://www.drecp.org/
- Secretarial Order 3330, Improving Mitigation Policies and Practices of the Department of the Interior (2013).
- BARACK OBAMA. 5/17/2013. Presidential Memorandum – Modernizing Federal Infrastructure Review and Permitting Regulations, Policies, and Procedures. Memorandum sent to THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES.
- UNEP. 2002. United Nations Environment Programme Environmental Impact Assessment Training Resource Manual, Second Edition. 2002. Topic 7 – Mitigation and impact management. 2 Edition. Chatelaine, Geneva, Switzerland. UNEP. UNEP Environmental Impact Assessment Training Resource Manual, Second Edition; 2: 303-321p.
- Clement, J.P. et al.. 2014. “A Strategy for Improving the Mitigation Policies and Practices of The Department of the Interior.” A Report to the Secretary of the Interior from the Energy and Climate Change Task Force. April 2014.. Washington, D.C.: DOI.