Today’s the deadline for commenting on the draft Desert Renewable Energy Conservation Plan (DRECP). Many of the people I know have been putting in long hours for the last several months pulling their comments together on the plan, which is gargantuan.
The plan covers 22 million acres of the California desert, with a huge amount of land proposed as renewable energy Development Focus Areas (DFAs) and an even huger amount proposed for a modicum of protection, but what that protection actually entails is a matter of both vagueness and controversy.
I suspect that most of the comments submitted by today on the DRECP will dive into the details to a formidable degree. One such set of comments, crafted by Basin and Range Watch, was so good I signed onto it myself.
But the comments I submitted today were very specific, and concerned an issue not addressed in the draft DRECP itself.
Here they are.
I am Chris Clarke, a resident of Joshua Tree in San Bernardino County, and of the 22-million-acres covered by the draft Desert Renewable Energy Conservation Plan (DRECP). I work as a journalist covering renewable energy issues for KCET TV in Los Angeles, but I make these comments solely on my own behalf as a private citizen.
These comments are submitted in addition to a comment letter by Laura Cunningham and Kevin Emmerich of Basin and Range Watch, which I co-signed.
My comment here centers on the fact that the identification of Development Focus Areas (DFAs) in the draft DRECP has been tainted by an instance of personal malfeasance by high-ranking Interior Department staff, to the extent that the ecological and energy resource justifications for any of the wind-oriented DFAs are now likewise tainted with the prospect that they may have been tailored to maximize the personal gain of Interior Department brass rather than to either develop renewable energy or protect public lands’ biological resources.
On November 7, 2014, the Interior Department’s Office of the Inspector General posted a report on its investigation of malfeasance by Steve Black, a senior counselor to former Interior Secretary Ken Salazar and Interior’s lead on renewable energy siting. The report identified several areas in which Black at least appears to have improperly influenced renewable energy policy to benefit either his own professional advancement or that of his then-paramour, Manal Yamout, who at the time worked for NextEra Energy Resources.
According to that report, which I have attached, Black put pressure on federal agency staff preparing the draft DRECP to increase the acreage of wind-oriented Development Focus Areas in the draft DRECP. This pressure induced staff to reconsider areas they had previously ruled out as too ecologically sensitive or lacking in wind potential, or both.
At the time that Black pressured DRECP authors to increase the amount of acreage available in the draft DRECP’s wind DFAs, he was seeking employment as the Executive Director of the American Wind Energy Association (AWEA). Black did not notify the Interior Department of his conversations with AWEA until nearly two months after he pressured agency staff to add wind DFAs to the draft DRECP.
According to a timeline included in the Inspector General’s report, NextEra Energy Resources’ Vice President of Development, a member of AWEA’s board of directors, asked Black in early January of 2013 whether he should add Black’s name to a list of candidates for AWEA’s Executive Director position. Black agreed but asked that his interest in the position be kept quiet.
On January 11 of that year, Black received an email from the director of the California Wind Energy Association, a member group of AWEA, complaining that his group felt the draft DRECP should include far more wind development areas.
On January 17, says the Inspector General’s report, Black directed state and federal agency staff working on the draft DRECP to — in the words of the report — “find more areas in the plan for wind development.” The DRECP program manager — not identified by name in the Inspector General’s report, but presumably Vicki Campbell — told investigators, again in the words of the report, that
“she and other DRECP team members disagreed with Black about adding certain areas for renewable energy development to the DRECP because the areas were not biologically supportable. She said that the areas were ultimately added, but the DRECP team decided to add requirements for them to mitigate the environmental issues. She said this was one of the ways the team ‘dealt’ with Black’s involvement. She stated that DOI officials, including Black, also asked the team to find more areas for wind development in the DRECP, but doing so would be difficult in the desert because the eagles and condors that lived there were ‘not real compatible with giant spinning blades.’”
Black did not inform Interior Department ethics staff of his interest in the AWEA position, according to the Inspector General’s report, until March 4, at which point he was informed that he “should not engage in matters that affected AWEA’s finances.”
Had Black informed Interior ethics staff of his interest in the AWEA position when it first arose, in January, that proscription would assuredly have included intervening to increase the acreage available for wind development in the draft DRECP.
Black’s unethical tinkering in the DFA selection process is a matter of public record. And yet the draft DRECP contains no indication as to which DFAs may have been included or expanded as a result of Black’s influence.
And that means that those of us who are observing and commenting on the DRECP process can not extend our full confidence that those DFAs were selected and mapped under the highest scientific standards required by the National Environmental Policy Act, the California Environmental Quality Act, and general best practices followed by the state and federal agencies contributing to the draft plan.
Ethical lapses like those Black committed must not be allowed to shape land management decisions and policy in the California Desert. At a very minimum, the Interior Department should fully disclose precisely which areas were added to the roster of wind Development Focus Areas as a result of Steve Black’s unethical influence into the process. Those DFAs should be removed from the final DRECP or else supported with the best available science to explain just why the initial decision by agency staff to exclude them from consideration should not be trusted.
Without such disclosure and transparency, the full plan will remain shadowed by the suspicion that the DFAs were chosen more to benefit Steve Black’s personal and financial well-being than to move California to a renewable energy future, or to protect its irreplaceable desert public lands.
Thank you for this opportunity to comment.
PO Box 1086
Joshua Tree, CA 92252