A. INTRODUCTION

Eric K. Solorio

A.1 PERMITTING AGENCIES AUTHORITIES, RESPONSIBILITIES AND

PROCESSES

The California Energy Commission (CEC) and the Bureau of Land Management (BLM)

have prepared this joint, detailed analysis and statement known as a Staff

Assessment/Draft Plan Amendment/Draft Environmental Impact Statement

(SA/DPA/DEIS). The Draft Plan Amendment pertains to the BLM’s California Desert

Conservation Area Plan of 1980 as Amended. The analysis and statement are

commonly referred to as a “joint, environmental document” because the SA/DPA/DEIS

addresses the requirements of the California Environmental Quality Act (CEQA) and

also the National Environmental Policy Act (NEPA). CEQA is a statute that requires

state (CEC) and local agencies to identify the significant environmental impacts of their

actions and to avoid or mitigate those impacts, if feasible. NEPA requires federal

agencies (BLM) to integrate environmental values into their decision making processes

by considering the environmental impacts of their proposed actions and reasonable

alternatives to those actions.

For clarity, staff emphasizes to the reader that this “joint, environmental document”, is

being used by the CEC and also the BLM, in separate and distinctly different licensing,

permitting and or authorization processes. Overall, both the BLM and the CEC will rely

on the SA/DPA/DEIS document in very similar ways (i.e. considering the proposed

project’s impacts on the environment).

Because the BLM and the CEC, respectively, will each rely upon this document to

comply with different environmental regulations, there are certain portions of the

document titled “CEQA purposes only” or “NEPA purposes only” or use other similar

language. The CEQA only portions are identified for the benefit of the CEC’s

environmental review process while the NEPA only portions are identified for the benefit

of the BLM’s environmental review process. The balance of the document is for the

benefit of both agencies respective, environmental reviews.

The authors of this SA/DPA/DEIS are CEC staff, hereafter referred to as “staff”. Prior to

drafting the joint document, the BLM and the CEC conducted multiple site visits, in order

to examine the physical characteristics of the proposed project site. Both agencies also

conducted joint review of the AFC, POD and related information regarding the proposed

project. The BLM and the CEC also organized, noticed and held five public meetings

and workshops to discuss the proposed project. The BLM has also reviewed the

administrative draft of the SA/DPA/DEIS and provided written comments to the authors

for incorporation into the SA/DPA/DEIS.

A.1.1 ENERGY COMMISSION’S AUTHORITY AND RESPONSIBILITIES

The Energy Commission has the authority to certify the construction, modification, and

operation of thermal electric power plants 50 megawatts (MW) or larger. The Energy

Commission certification is in lieu of any permit required by state, regional, or local

agencies; and federal agencies to the extent permitted by federal law (Pub. Resources

Code, § 25500). The Energy Commission must review thermal power plant Applications

for Certification (AFC) to assess potential environmental impacts including potential

impacts to public health and safety, potential measures to mitigate those impacts, and

compliance with applicable governmental laws or standards (Pub. Resources Code, §

25519 and § 25523(d)).

The Energy Commission’s siting regulations require staff to independently review the

AFC and assess whether all of the potential environmental impacts have been properly

identified, and whether additional mitigation or other more effective mitigation measures

are necessary, feasible, and available (Cal. Code Regs., tit. 20, § 1742 and

§ 1742.5(a)).

In addition, staff must assess the completeness and adequacy of the measures

proposed by the applicant to ensure compliance with health and safety standards, and

the reliability of power plant operations (Cal. Code Regs., tit. 20, § 1743(b)). Staff is

required to develop a compliance plan to ensure that applicable laws, ordinances,

regulations, and standards (LORS) are met (Cal. Code Regs., tit. 20, § 1744(b)).

Staff conducts its environmental analysis in accordance with the requirements of CEQA.

No additional environmental impact report (EIR) is required because the Energy

Commission’s site certification program and production of a Staff Assessment (SA), has

been certified by the California Resources Agency as meeting all requirements of a

certified regulatory program (Pub. Resources Code, § 21080.5 and Cal. Code Regs., tit.

14, § 15251 (j)). The Energy Commission is the CEQA lead agency.

A.1.2. ENERGY COMMISSION’S SITE CERTIFICATION PROCESS

Upon the Energy Commission receiving a complete Application for Certification (AFC),

Commission staff begins preparing an SA. The analyses contained in a SA are based

upon information from the: 1) AFC, 2) responses to data requests, 3) supplementary

information from local, state, and federal agencies, interested organizations, and

individuals, 4) existing documents and publications, 5) independent research, and 6)

comments received at public workshops. The analyses for most technical areas include

discussions of proposed conditions of certification. Each proposed condition of

certification is followed by a proposed means of verification that the condition of

certification has been met. The SA presents staff’s conclusions about potential

environmental impacts and conformity with LORS, as well as proposed conditions that

apply to the design, construction, operation, and closure of the facility.

Upon completion of the SA, it is published and made available to the applicant,

interveners, public, agencies and interested parties. Following publication of the SA,

staff provides a public comment period to resolve issues between the parties and to

narrow the scope of disputed issues that would likely be presented at evidentiary

hearings held by the Energy Commission. During the comment period, staff will conduct

additional public workshops to discuss its conclusions, proposed mitigation, and

proposed compliance-monitoring requirements. Based on dialogue at the workshops

and written comments from agencies and the general public, staff may chose to refine

its analysis, correct minor errors, and or finalize conditions of certification to reflect

areas where agreements have been reached with the parties. If necessary, staff will

then publish an Errata to the Staff Assessment which corrects any minor errors in the

SA, elaborates on any details to proposed mitigation measures and addresses the

comments received. When producing a joint environmental document, staff will publish

its Errata simultaneously with and as part of the Final Environmental Impact Statement.

The final document for this review will be titled Staff Assessment; Errata/Proposed Plan

Amendment/Final Environmental Impact Statement (SAE/PPA/FEIS).

For the Energy Commission’s purposes in considering the RSPP, the SAE/PPA/FEIS is

not the decision document for the Commission’s proceedings nor does it contain

“findings” of the Energy Commission related to environmental impacts or the project’s

compliance with local/state/federal legal requirements. The SAE/PPA/FEIS will be

entered into the evidentiary record and serve as Energy Commission staff’s testimony in

evidentiary hearings to be held by the Committee of two Commissioners along with a

hearing officer, who are overseeing this case. The Committee will hold evidentiary

hearings and will consider all the evidence entered into the record including evidence

presented by staff, the applicant, all parties, government agencies and public

comments, prior to proposing its decision. At the public hearings, all parties will be

afforded an opportunity to present evidence and to rebut the testimony of other parties,

thereby creating a hearing record on which a decision on the project can be based. The

hearing before the Committee also allows all parties to argue their positions on disputed

matters, if any, and it provides a forum for the Committee to receive comments from the

public and other governmental agencies. It is important to distinguish that the

Commission’s hearing process is completely separate from the BLM’s process. As

such, evidence presented at the Commission’s hearings is not evidence, facts or

findings that is before the BLM.

Following the evidentiary hearings, the Committee’s recommendation to the full Energy

Commission on whether or not to approve, modify or deny the proposed project will be

contained in a document entitled the Presiding Member’s Proposed Decision (PMPD).

Following publication, the PMPD is circulated for 30 days, in order to receive written

public and agency comments. At the conclusion of the comment period, the Committee

may prepare a revised PMPD. The final step is presentation of the PMPD by the

hearing officer to the full Commission for consideration and issuance of an order

granting or denying of a license to construct and operate the proposed facility.

A.1.3 BUREAU OF LAND MANAGEMENT’S AUTHORITY,

RESPONSIBILITIES, AND PURPOSE AND NEED

A.1.3.1 Bureau Of Land Management’s Authority and Responsibilities

Applications to construct and operate commercial solar energy facilities on public lands,

managed by the BLM, are processed as right-of-way (ROW) authorizations under Title

V of the Federal Land Policy and Management Act (FLPMA) of 1976 [43 United States

Code (U.S.C.) 1701 et seq.], and Title 43, Part 2804 of the Code of Federal Regulations

(CFR). Applications submitted to the BLM for commercial solar energy development

projects use Form SF-299. Additional authorities consistent with BLM for processing

such applications (SF-299), include the following:

• The Energy Policy Act of 2005 (Epact), which says “It is the sense of Congress that

the Secretary of the Interior should, before the end of the 10-year period beginning

on the date of enactment of this Act [August 8, 2005] seek to have approved nonhydropower

renewable energy projects located on the public lands with a generation

capacity of at least 10,0000 megawatts of electricity.”; and

• Secretarial Order 3285, dated March 11, 2009, which "establishes the development

of renewable energy as a priority for the Department of the Interior".

In processing the ROW applications and considering taking related actions to change

land use designations, the BLM is required under the NEPA to conduct a

comprehensive environmental review of the proposed project. For the RSPP, this NEPA

review will be documented in the form of an SA/DPA/DEIS and a subsequent

SAE/PPA/FEIS.

A.1.3.2 BLM Land Use Plan Conformance

The principal land use plan affecting this proposed project is the U.S. Bureau of Land

Management’s (BLM) California Desert Conservation Area (CDCA) Plan of 1980, as

amended, and the West Mojave Desert Management Plan (WEMO), which amends the

CDCA Plan for those specific areas of the Mojave Desert. In the CDCA Plan, the

location of the proposed facility includes land that is unclassified and small amount of

classified as Multiple-Use Class L (Limited Use). The Plan states that solar power

facilities may be allowed within Limited Use areas after the NEPA requirements are met

by considering the environmental impacts and reasonable alternatives to the action. The

majority of the Project is located in unclassified BLM-administered land. The BLM

manages these parcels on a case-by-case basis.

This DEIS acts as the mechanism for complying with those NEPA requirements.

Because solar power facilities are an allowable use of the land as it is classified in the

CDCA Plan, the proposed action does not conflict with the Plan. However, Chapter 3,

“Energy Production and Utility Corridors Element” of the Plan states that “Sites

associated with power generation or transmission not identified in the Plan will be

considered through the Plan Amendment process.” Because the proposed facility is not

currently identified within the CDCA Plan, the plan would require an amendment to

authorize the proposed project.

As specified in Chapter 7, Plan Amendment Process, there are three categories of Plan

Amendments, including:

• Category 1, for proposed changes that will not result in significant environmental

impact or analysis through an Environmental Impact Statement;

• Category 2, for proposed changes that would require a significant change in the

location or extent of a multiple-use class designation; and

• Category 3, to accommodate a request for a specific use or activity that will require

analysis beyond the Plan Amendment Decision.

Based on these criteria, approval of the proposed project would require a Category 3

amendment.

The Implementation section of the Energy Production and Utility Corridors Element of

the CDCA Plan lists a number of Category 3 amendments that have been approved

since adoption of the Plan in 1980. An additional amendment is proposed to be added

to this section of the Plan, and would read “Permission granted to construct solar

energy facility (proposed Ridgecrest Solar Power Project (RSPP).” a.1.3.3 Bureau of

Land Management’s right-of-way grant process.

Under federal law, the BLM is responsible for processing requests for rights-of-way to

construct systems for generation, transmission, and distribution of electric energy on the

public lands. In response to Solar Millennium’s application for a ROW grant (CACA

049016) on public land together with a Plan of Development (POD) to develop the

RSPP, the BLM and CEC generated this SA/DPA/DEIS to evaluate the potential

environmental impacts of the proposed action, the No Action alternative, and other

alternative actions that may meet BLM’s purpose and need. The following outlines the

BLM’s public comment timing and process:

1. The Notice of Availability (NOA) publication in the Federal Register will begin the

90-day public comment period on the SA/DPA/DEIS

2. Following completion of the comment period, BLM will review and develop

responses to comments that were submitted by the public and other agencies. The

responses to the comments will be incorporated into a joint SAE/PPA/FEIS, which

will also include identifying the BLM’s preferred project alternative. A Notice of

Availability (NOA) of the joint SAE/PPA/FEIS will be published in the Federal

Register when the SAE/PPA/FEIS becomes available for public review.

3. The SAE/PPA/FEIS will be available for public review for 30-days before the BLM

issues a Record of Decision (ROD). The Decision is appealable to the Interior Board

of Land Appeals upon issuance of the ROD.

A.1.3.4 BLM’s Purpose and Need for the Proposed action

NEPA guidance published by the Council on Environmental Quality (CEQ) states that

environmental impact statements’ Purpose and Need section “shall briefly specify the

underlying purpose and need to which the agency is responding in proposing the

alternatives including the proposed action” (40 CFR §1502.13). The following discussion

sets forth the purpose of, and need for, the project as required under NEPA.

Solar Millennium, LLC, has submitted an amended application to apply for a ROW

authorization to construct and operate a parabolic trough, solar thermal, generating

facility with a capacity of 250 megawatts. The project would connect to the existing

Southern California Edison 230-kilovolt (kV) Inyokern/Kramer Junction transmission

line. About a mile and half long portion of this 230 kV transmission line and about a mile

and a half long portion of a 115 kV line would be realigned to avoid the project area.

The amended application requests an approximately 3,995-acre ROW that would

contain two solar fields, a power block, construction areas, a dry-cooling tower, steel

transmission towers with associated transmission lines, access roads, three covered

water tanks, an underground water pipeline, a water treatment facility, an electrical

switchyard, a land treatment unit for bioremediation of any soil that may be

contaminated by heat transfer fluid, an office, a warehouse, a parking lot, and facility

perimeter fencing. The application is for a project that would be located approximately

five miles southwest of the city of Ridgecrest in Kern County, California.

The BLM’s purpose and need is to respond to Solar Millennium, LLC’s application will

be consistent under FLPMA for a ROW grant to construct, operate and decommission a

solar generation facility and associated infrastructure in compliance with FLPMA, BLM

ROW regulations, and other applicable federal laws. BLM’s review of Solar Millennium,

LLC’s application is also consistent with the following laws and directives pertaining to

renewable energy resources:

• Section 211 of the Energy Policy Act of 2005, enacted in August 2005 states, “It is

the sense of Congress that the Secretary of the Interior should, before the end of the

10-year period beginning on the date of enactment of this Act [August 8, 2005] seek

to have approved non-hydropower renewable energy projects located on the public

lands with a generation capacity of at least 10,0000 megawatts of

electricity.”Instruction Memorandum 2007-097, dated April 4, 2007, Solar Energy

Development Policy establishes BLM policy to ensure the timely and efficient

processing of energy ROWs for solar power on the public lands.

• Secretarial Order 3283 Enhancing Renewable Energy Development on the Public

Lands signed January 16, 2009. This order facilitates the Department of the

Interior’s efforts to achieve the goals established in Sec. 211 of the Energy Policy

Act of 2005.

• Secretarial Order 3285 Renewable Energy Development by the Department of the

Interior, signed March 11, 2009. The order establishes the development of

renewable energy as a priority for the Department of the Interior and establishes a

Departmental Task Force on Energy and Climate Change.

The decision BLM makes is whether or not to grant a ROW and if so, under what terms

and conditions, and whether to amend the CDCA land use plan. The SA/DPA/DEIS will

be used to analyze the impacts of these decisions.

Modifying the existing route network is a part of the purpose and need for this project.

The purpose and need for this project also includes compliance with 43 CFR 8342.1

which establishes criteria to consider when making route designations. The

designations should be based on the protection of the resources of the public lands,

promotion of the safety of the users of the public land, and to minimize the conflicts

among the various users of the public lands. They also must be in accordance with the

following criteria:

• Areas and trails shall be located to minimize the damage to soil, watershed,

vegetation, air, or other resources of the public lands, and to prevent impairment of

wilderness suitability.

• Areas and trails shall be located to minimize harassment of wildlife or significant

disruption of wildlife or significant disruption of wildlife habitats. Special attention

would be given to protect endangered or threatened species and their habitats.

• Areas and trails shall be located to minimize conflict between OHV use and other

existing or proposed recreational uses of the same or neighboring public lands, and

to ensure the compatibility of such uses with existing conditions in populated areas,

taking into account noise and other factors.

• Areas and trails would not be located in officially designated wilderness areas or

primitive areas. Areas and trails would be located in natural areas only if the

authorized officer determines that vehicle use in such locations would not adversely

affect their natural, esthetic, scenic, or other values for which such areas are

established.

A.1.4 BLM STATUTORY SECTIONS

This section discusses the following topics that are required to be addressed by

environmental impact statements and reports by federal and/or California statutes,

regulations, or policy:

• Relationship Between Short-Term Uses of the Environment and the Maintenance

and

• Enhancement of Long-term Productivity

• Irreversible and Irretrievable Commitment of Resources

• Growth-Inducing Effects of the Proposed Action

• Energy Consumption and Conservation

A.1.4.1 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF

THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT

OF LONG-TERM PRODUCTIVITY

Consideration of energy development permits on BLM managed lands is a trade-off

between a permitted short-term use of the desert environment in exchange for other

uses, including conservation and habit uses that would be effective in the longer term.

In the short term, the development alternatives allow commercial energy generation use

of desert lands. New disturbance would occur on the development land. This use is

incompatible with habitat conservation on the same land.

In the long term, despite these uses, the previous establishment of a habitat

conservation area, including tortoise DWMAs and other conservation areas, would

ensure that desert ecosystems would be maintained and enhanced with nearly 98

percent of the 2.2 million acre WEMO planning area maintained in an undisturbed

condition. Additionally, an acquisition program to acquire and enhance the protection

of private lands would be established with the required mitigation.

Closure of off highway vehicle routes through the project area, will be off-set by creation

of alternate routes around the project area to allow appropriate access to sites visited by

the public. These new routes would be maintained, however, thus minimizing losses of

recreation and commercial access. This would be accomplished by the design of a

network that provided appropriate access in a manner that avoided sensitive resource

sites. Access would continue to be provided for a variety of activities, including

equestrian staging areas, recreational touring, rock hounding, mineral exploration, and

other legitimate uses.

At the end of the term of the right of way, the land would be reclaimed and returned to

its prior condition and use, returning to long term productivity.

A.1.4.2 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT

OF RESOURCES

Authorized take of habitat would result in the permanent loss of wildlife and plant

habitat. Once new ground disturbance occurs, the natural habitat eliminated by this

would no longer be available to sensitive wildlife and plant species. This could include

desert tortoise habitat. Direct take of individuals could also occur. Given the large scale

of the conservation areas on other BLM managed lands, these disturbances are not

likely to threaten the survival and recovery of sensitive species. Designation of

conservation areas and previous closure of routes within those areas enhanced

ecosystem conservation for the land within the West Mojave Plan.

All undertakings that involve ground disturbing activities would require site-specific

cultural analysis that may include surveys, recording of historic and prehistoric sites,

and determinations of eligibility of sites to the National Register of Historic Places.

Potential impacts to Native American values would be analyzed. Mitigation measures

would be identified and implemented if necessary. Avoidance of impacts to cultural

resources is the preferred mitigation measure, but is not always possible or feasible. A

decision to mitigate impacts to cultural resources by data recovery, instead of avoidance

and consequent removal of cultural resources from the area constitutes a residual

impact to the site. Sites would rarely, if ever, be completely excavated. Mitigation by

data recovery results in a steady loss of archaeological sites, and reduces opportunities

for interpretation in their natural context.

Parts of allotments no longer available for grazing use would be lost for the reasonably

foreseeable future. The amount of land removed from the allotment would not result in a

loss of livestock production.

In processing the application for this renewable energy project, BLM has made no

irreversible or irretrievable commitment of resources.

A.1.4.3 GROWTH-INDUCING EFFECTS OF THE PROPOSED

ACTION

Population growth in the West Mojave is projected to range between 1.59% and 2.21%

per year for the 30-year term of the project. Adoption of streamlined procedures for

complying with the California and federal endangered species acts increases the

likelihood that growth rates will approximate the latter figure. This is based upon the

assumption that applicants for discretionary development permits will have a higher

incentive to pursue high desert projects due to the reduction and/or elimination of costs

associated with obtaining those permits, and (more significantly) the elimination of

delays currently inherent in the permit approval process. This growth would be focused

in the vicinity of currently urbanized areas, including incorporated cities, rather than in

more remote desert regions.

This individual project is not expected to have a significant growth-inducing effect on the

development of BLM-administered public lands. As more energy development projects

are authorized the State of California and the United States will be closer to meeting

their renewable energy goals and thus reducing the demand for future projects.

A.1.4.4 ENERGY CONSUMPTION AND CONSERVATION

Any development project would result in a direct change to the regional level of energy

development and a minimal change to the regional level of energy conservation and

consumption.

A.1.5 U.S. DEPARTMENT OF ENERGY (DOE), LOAN GUARANTEE

PROGRAM (LGP) OFFICE’S PURPOSE AND NEED STATEMENT

Solar Millennium has also applied to the United States (US) Department of Energy

(DOE) for a loan guarantee pursuant to Title XVII of the EPAct. Title XVII of EPAct

authorizes the United States Secretary of Energy to make loan guarantees for a variety

of types of projects, including those that "avoid, reduce, or sequester air pollutants or

anthropogenic emissions of greenhouse gases, and employ new or significantly

improved technologies as compared to commercial technologies in service in the United

States at the time the guarantee is issued." The two principal goals of the loan

guarantee program are to encourage commercial use in the United States of new or

significantly improved energy-related technologies and to achieve substantial

environmental benefits. The purpose and need for action by DOE is to comply with their

mandate under EPAct by selecting eligible projects that meet the goals of the Act.

Should DOE enter into negotiation of a possible loan guarantee with the applicant, DOE

would become a cooperating agency in developing the FEIS. The need includes

consideration for this or other funding available through the DOE. Should DOE accept

the application as suitable for this funding, DOE may adopt this EIS, or become a

cooperating agency in developing the FEIS. If so, this SA/FEIS may be used by DOE to

meet the NEPA requirements in making a determination of funding.

A.1.6 U.S. FISH AND WILDLIFE SERVICE’S AUTHORITY AND

RESPONSIBILITIES

The U.S. Fish and Wildlife Service (USFWS) is charged with protection of threatened

and endangered species under the Federal Endangered Species Act (ESA), 16 U.S.C.

1531. ESA requires federal agencies to consult with the USFWS or the National

Oceanic and Atmospheric Administration (NOAA) when a federal action is likely to

adversely affect listed species or critical habitat. Consultation is initiated by the lead

federal agency (BLM) through the preparation and submission a Biological Assessment

(BA) to USFWS/NOAA which describes the proposed project, its effects on the

specie(s) and its habitat, and related avoidance and minimization measures.

Upon receipt of the BA, the USFWS/NOAA will begin formal consultation with the BLM

to discuss the proposed action. Following consultation, the USFWS/NOAA will then

issue a Biological Opinion (BO). The BO may find the BLM’s proposed action will result

in “jeopardy” to the listed species, as a whole. If so then the proposed action cannot be

taken. Alternatively, if the USFWS/NOAA concludes the proposed action will not result

in "jeopardy” to the listed species, as a whole, then the BO will authorize the “incidental

take” of the listed species1, and contain specific avoidance and minimization measures

which must be implemented if the proposed action is approved by the BLM. The BO

must be obtained from the USFWS and considered by the BLM, before the BLM issues

a Record of Decision.

A.1.7 KERN COUNTY AIR POLLUTION CONTROL DISTRICT’S

AUTHORITY AND RESPONSIBILITIES

The project site is located in the Mojave Desert Air Basin2 and is under the jurisdiction

of the Kern County Air Pollution Control District (KCAPCD). Based upon the authorities

in 40 Code of Federal Regulations (CFR) Part 52 and 40 CFR Part 60, the District is

responsible for issuing the federal New Source Review (NSR) permit and has been

delegated enforcement of the applicable New Source Performance Standard (Subpart

IIII).

A.1.8 CALIFORNIA DEPARTMENT OF TRANSPORTATION

(CALTRANS)

Caltrans has jurisdiction over encroachments to its transportation facilities and related

easements and rights-of way. Regarding the proposed RSPP, CalTrans has authority to

consider granting an encroachment permit for the RSPP to cross under US Route 395

with a water line, and also granting a right-of-way and related encroachment permit for a

potential new access from US Route 395 to the project site.

1 The BO would not authorize take of listed plant species. For purposes of this document the BO

would potentially authorize the incidental take of the Desert Tortoise.

2 The Mojave Desert Air Basin lies inland east of the San Joaquin Valley Air Basin to the west and

north and east of the South Coast Air Basin. The desert portions of Kern, San Bernardino, Riverside, and

Los Angeles counties are within its boundaries.

A.1.9 KERN COUNTY, CALIFORNIA

The county of Kern has jurisdiction to issue building permits to the RSPP. Building

permits issued by the county are considered ministerial, in nature. The county also has

jurisdiction to issue discretionary approvals for any easements, rights-of-way and or

encroachment permits where county facilities are concerned.

A.2 ORGANIZATION OF THE STAFF ASSESSMENT/ DRAFT PLAN

AMENDMENT/DRAFT ENVIRONMENTAL IMPACT STATEMENT

(SA/DPA/DEIS)

The SA/DPA/DEIS contains an Executive Summary, Introduction, Project Description,

and Project Alternatives. The environmental, engineering, and public health and safety

analysis of the proposed project is contained in a discussion of 20 technical areas. Each

technical area is addressed in a separate chapter. These chapters are followed by a

discussion of facility closure, project construction and operation compliance monitoring

plans, and a list of CEC and BLM staff that assisted in preparing and reviewing this

report.

Each of the 20 technical area assessments includes a discussion of:

• Laws, ordinances, regulations, and standards (LORS);

• The regional and site-specific setting;

• Project specific and cumulative impacts;

• Mitigation measures;

• Closure requirements;

• Conclusions and recommendations; and

• Conditions of certification for both construction and operation (if applicable).