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Check Out Our Ray-Bans!

Feds freeze new solar projects on public land, pending review

Posted at 8:27 AM on 27 Jun 2008

The Bush administration has put a moratorium on new solar projects on public land pending large-scale study of their environmental impacts, a process which could take about two years. Since 2005, over 130 solar-plant proposals have been filed for large-scale solar projects that together would cover some 1 million acres of BLM land, if approved. Officials at the Interior Department have said that temporarily halting the cascade of solar power projects will give them time to develop criteria to apply to future projects, thereby potentially speeding the permitting process down the road. Many in the solar industry are incensed about the sudden solar-project stoppage, which, together with the unsure future of the renewable-energy tax credit, could slow industry growth. "It doesn't make any sense," said a solar-company exec. In contrast, the leasing process for oil and gas development on public lands has sped up significantly in recent years, with the number of permits now far outpacing the industry's drilling capacity.

source:  The New York Times
see also, in Gristmill:  How to strangle an industry, the concern troll way

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Comments: (26 comments)

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Pacific Power takes same approach

Pacific Power is using the same/similiar  approach to blocking solar power - using a technicality:

Portland, OR -- Responding to Pacific Power's actions that have threatened the solar industry in Oregon, a large group of public interest organizations, cities and solar energy companies are intervening before the Oregon Public Utility Commission (PUC) in hopes of allowing the current boom in solar electric development to continue. By raising questions about a common financing method that allows governments and non-profits to purchase solar electricity at affordable rates, Pacific Power's PUC filing has effectively frozen Oregon's progress on solar installations.  In addition, Pacific Power is questioning a long-established policy allowing its customers to sell excess power they generate from their solar electric systems back to the utility as a credit against their energy bill.
Portland General Electric does not share Pacific Power's concerns.  The Oregon Solar Energy Industries Association (OSEIA), Renewable Northwest Project, the Citizens' Utility Board of Oregon, Environment Oregon, the Natural Resources Defense Council and the League of Oregon Cities have all submitted petitions to intervene in the PUC docket (DR 40).  Additional interveners include Oregon Department of Energy, Oregon Department of Transportation and the Energy Trust of Oregon.
"With the federal solar tax credits expiring at the end of the year, Pacific Power's filing has created a major stumbling block for solar in Oregon at the worst possible time." said Suzanne Leta Liou, senior policy advocate for Renewable Northwest Project. "Financing for dozens of solar projects across the state are now in peril, making it close to impossible for public entities and non-profit organizations to have on-site renewable energy generation."
"Our nation is facing an energy crisis of monumental scope.  Surmounting this crisis will require innovation, leadership and a willingness to embrace change by all," said Joe Reinhart, executive director of OSEIA.  "As consumers we have every right to expect Pacific Power to act as a responsible corporate citizen in embracing solutions and not impeding solutions."

Yours truly, SMC

Lawyering

This kind of action is designed to dry up already scarce capital for renwewables.  Rove and Cheney chuckle with glee when they commit crimes like this.

Wouldn't we like to wipe that smirk off their perverted mugs?  Campaign for Obama and your local and state democrats.  That'll do it.

http://amazngdrx.blogharbor.com/blog John Schneider, Northern Wisconsin

Wrong Direction

This is what solar power advocates get for blindly advocating big solar, which will be environmentally destructive.  I hope these projects are stopped permanently.  As I've said ad nauseum, what's needed is locally produced energy, like solar panels on people's roofs, not more destruction of ecosystems, in this case mainly desert ecosystems.

I agree 100% with Wolverine...

"Big solar" isn't gonna be much better for consumers than deregulated "big nuke" or "big coal."  We need to decentralize the grid and tell people to live within their local means.  I'm sure we could all live at the bottom of the Arctic Ocean in a glass dome if we paved over the Mojave desert with solar panels and pumped the energy to where it is "needed."  The reality of the matter is that our populations are too big and too dense and they don't produce enough of the basics locally - food, lumber, energy.  

If I can easily put solar panels on top of my townhouse and meet most or all of my energy needs, why should I pay a monthly bill to a big energy company?  Why pave over natural areas when we've got thousands of acres of rooftops that are wasted?  

Think of places like Phoenix, AZ, where its sunny probably 360 days a year.  Why do we need a major solar utility in the adjacent desert when all of the houses and office buildings there could be modified to produce a large amount of electricity.

I see this issue as key to sustainability.  It's like the argument raging over organic/local/conventional agriculture.  Part of moving away from conventional involved decentralization and more local production.  Most of us agree that a 1-acre lawn is a huge waste of fertilizer and water that should be used to produce food.  So why do we think differently about our energy sources?

Il faut cultiver notre jardin.

Frustrating

I just heard that Exxon is planning on selling off all of their gas stations and investing more into the refining process.

Coupled with this little update, it is hard not to feel deflated.

I agree with Wolverine - we should focus on solar panels on houses before mass plants. It still infuriates me that oil and gas development can continue full speed ahead.

Ecosystem limits

In the desert ecosystems where these concentrated solar thermal plants are proposed, the primary productivity of the ecosystems is (unless I'm wrong) water limited, not light limited.

I would think that the cooler temperatures in the shadows of the solar collectors would encourage primary productivity and thus carbon sequestration.  While it is true that the species that take advantage of the new conditions may be different from the native species...  well, there's this thing called global warming, and niches (and niche optimized species) are changing all over the world.  A few hundred acres of low-productivity desert is a small price to pay (if it is a 'price' at all) for displacing whoever much coal.

While I support subsidies for rooftop solar, it is not an either/or.  The money for these industrial scale solar thermal generation stations in the deserts is not coming out of public  coffers, but from venture capital.

Bikes can save us!!

local power generation

I'll third or fourth the motion. Wolverine is correct.

I'm surprised by two things.

First, how can environmentalists fall for the notion that deserts are barren landscapes devoid of unique organisms worthy of protection. Advocates of big solar sound just like the corporate shills who view the ANWR as a barren and otherwise useless landscape where no one and apparently no animals worth protecting live. Desert life is some of the most sensitive and most poorly understood on the planet. It also recovers from disturbance very very slowly.

Second, concentrated sources of energy are a national security issue. Photovoltaic systems installed on homes, hospitals, businesses, et cetera would reduce the possibility of entire grids collapsing and shutting down urban areas. Why don't environmentalists mention this when promoting alternative sources of energy? Even Dick Cheney recognizes the value of being off the grid!

Put solar where we've already destroyed the natural landscape, on roof tops! And make sure people own the systems they rely on. It is time to reduce corporate control over our lives, not reinforce it.

Photovoltaic Systems

First, I am an environmentalist and I do not feel deserts are barren wastelands!

Second, I do not support big solar installations destruction of desert lands by these installations or the infrastructure needed by them.

Third, I do support solar panels on rooftops. I have both solar PV and solar hot water on my roof.  Do you or do you just blow hot air about it?

Fourth, Try not to make sweeping assertions as you will find you are wrong most of the time.

Pax

My Apologies to BobG...

I should have added a few additional words. My remarks were not intended as a sweeping assertion. Please allow me to clarify.

When I said "...how can environmentalists fall for the notion..." I was not referring to all environmentalists -- that would be absurd! It was shorthand for "environmentalists who feel there is no problem with large scale solar installations in the desert". I cannot imagine that someone who cares about the environment would think large-scale solar installations in the desert are a good idea, unless they haven't been to or read about deserts. It really suggests they think deserts are barren landscapes.

Nor was I suggesting that all environmentalists or others who care about the environment are interested in large scale solar installations in deserts. I do no how you reached that conclusion, but I'm responsible for my words. My fault.

Nor was I suggesting that no environmentalists support rooftop installations. I'm just surprised that someone out there is not using the national security issue as a talking point. Those opposed to protecting our environment seem to go on about how it will harm our economy and jeopardize national security. They accuse environmentalist of being fools and not living in reality. Well, it seems to me that encouraging the use of photovoltaics could be presented a national security issue, something liberal, conservatives, Democrats, Republicans, Greens, Libertarians, et cetera should ALL be able to get behind. I'm not saying you are part of the problem, not at all. I want to know, however, why there aren't any political candidates pushing this issue. Seems like a no-brainer. The nation will be stronger. Industry wins. Labor wins. Homeowners win.

To answer your question... no, I don't have photovoltaics or solar water heating installed on my home. I simply cannot afford the upfront cost right now. The last estimate I got was about $28,000 to power our 1100-1200 square foot house.

But I don't understand why, just because I can't afford to personally install photovolatics, I can't oppose large-scale installations and hope  government agencies, political candidates, and advocacy groups might find ways to encourage more use of photovoltaics and perhaps bring down the price for people who would like to take advantage of the technology.

As far as sweeping assertions are concerned, I fully agree with you. Most, virtually all, sweeping assertions are inaccurate. Again, I didn't intend my remarks as sweeping assertions. I myself am very annoyed by a variety of sweeping assertions. I could list a few that appear on this website, but I suspect it would annoy those already aware of where I stand on those issues.

Peace.

double standard (i.e. oil'n'gas)

This is strangely ironic, considering that the desert of the Four Corners area is scarred every few hundred feet with one road after another, for servicing oil and gas wells.  How could solar
installations have more impact than that?  This decision smells of a spiteful double standard.

Smart Tactic

It's a pretty tactful move on the administration's part as it divides the environmentalist community so thoroughly. We can see this here somewhat.

I am completely comfortable

As an environmentalist, I am completely comfortable with SOME loss of animal habitat for renewable energy projects.  SOME sacrifice is OK when compared to the massive destruction that AGW can produce.

In this crisis case,  I want local solar panels on my house AND large centralized plants.  I really think both are needed to meet the needs of a busy city. Yes, even with negawatts and conservation and efficiency.

Remember, we want to completely replace coal for buildings AND gasoline for autos.  That is huge.

I would like to see environmental impact studies and judge for myself how it compares to a 5 degree increase in global temps.

OF COURSE one has to build things carefully in an environment.  And creating a situation where species sustainability become threatened is intolerable.  But some minor hits have to be OK!

Honestly guys, what kind of perfect situation do you think we are going to have here?   I say speed is more important than perfection.  

Someone explain to me a scenario where an important extinction will take place with a solar plant installed.

Purity and perfection are luxuries we cannot afford.  Lets do it ten times faster and do it in a style that is "mostly right, most of the time".

Wiscidea, My Apologies As Well

Sorry for my knee jerk reaction to what seemed like yet another slam to enviornmentalists. I have heard environmentalists blamed for a huge number of things and being the 'bad people' for so long it finally welled up. Thank you for your clarification.

Pax

Lets be realistic

I want to second the perspective of christophersj.  Rapid deployment of ALL TYPES of solar and wind projects is necessary to slow down coal electricity generation, and to reduce subsequent global-warming-induced damage to much more biologically diverse marine (e.g. coral reefs) and terrestrial (e.g., non-fire-adapted forests) environments.  We have to remember that we are in a critical, damage-control situation.

Also, I am a terrestrial ecologist who has spent 15 years working in arid ecosystems on public lands in the West.  I agree that these systems have notable landscape scaled diversity (across habitats).  But, there are truly massive expanses of homogeneous habitat (e.g., arid grasslands and sagebrush steppe on the Colorado Plateau and in the Great Basin and Upper Chihuahuan) with fairly low species diversity, high functional redundancy, and homogeneous community composition.  It would not take long (one meeting of arid land ecologists followed by a concerted effort for one month to synthesize conclusions) for the BLM to come up with an initial set of criteria for reducing damage to critical habitats (avoid high elevation habitats, riparian forests, playas and other water features - there is diversity where there is moisture and topography).  This two year moratorium is an obvious stall tactic designed to give proponents of nuclear and coal power an opportunity to get some money out of Washington before renewable energy scales up and becomes less expensive and thus clearly economically superior.

Here Come The Conservatives

Christopher and Tdmeeh just don't get it.  Humans have already ruined almost all of the land on Earth.  To allow further destruction or at least denigration of natural habitats should be strongly opposed.  We should be advocating for major reductions in energy use coupled with locally generated sources of energy, not crap like this proposal, which is just more environmental destruction.

HA!


Ha!  That's my entertainment for the day:  me and an experienced desert ecologist being called "conservatives".

You know, if both the thug-deniers AND the radical environmentalist BOTH give me a hard time in here I might be saying something reasonable.

The thing is Wolverine, you and I really agree on probably 80% of the issues and it will take all of us to get this show on the road.

Reducing consumption is a HUGE piece of the puzzle, I agree. Healthy biodevirsity and habitat is also HUGE.   I just ask that you might look at the size of the challenge ahead then visualize the speed needed to transition.

Termite mounds and elephant trails have environmental impacts, so will we.  "Mostly right" may have to be "good enough".  I'm not saying this to contradict you in any way, but to prepare you for the way this whole transition is probably going to go down.

And I am an optimist who thinks we can do it.  But I am also a realist and know that there is no such thing as perfection.

Assumptions

A few comments on the assumptions embedded in wolverine's last post.  

First, despite what you might think, wolverine, I am also very aware and very bothered by pervasive human impacts on ecosystems.  And, I agree with you that we should be advocating heavy duty conservation measures, local production and consumption of food and power, and thoughtful population control.

Keep in mind, however, that these principles have been advocated for a long time, and that this has not substantially reduced human impacts on our environment.  "Progress" has marched on, all over our vision.  So it seems like it is time to expand our horizons and promote both local-scaled and large-scaled projects.  In my opinion, we have to offer up a utility-scaled substitute for the new coal and nuclear plants that are now being planned and built, or we are in for environmental damage on an unprecedented scale.

The second assumption I'd like to highlight is the one that BLM land is dominated by natural habitats.  This, unfortunately, is not true.  There are some areas on BLM land where humans have had minor impacts, but the majority of BLM land is heavily influenced by humans.  

This includes thousands of hectares that are obviously altered by natural gas, oil, and mineral exploration, extraction, and transportation.  Then there are the hundreds of thousands of hectares that are leased out to livestock producers and subsequently over-grazed.  What's even more destructive to native ecosystems are the huge expanses of invasive plants.  Cheatgrass, alone, covers whole basins and has now altered fire regimes.  Altering the fire regime effects every organism on the range, from the soil microbe to the large herbivore, and entirely rearranges ecosystem functioning.

So, I don't mean to prolong a battle of opinions with this post.  Your message actually got me thinking about how it is important to guide society toward local-scaled sustainability, this seems to be a good endpoint to shoot for. I also got to thinking about how promoting large scaled solar and wind projects seems, at first, to be counter productive.  I guess I just see them as a fairly benign means for us to buy the time necessary for our society to value and adopt local-scaled solutions.

There are at three silver linings to this delay

First, it will give the scientists who are measuring the rate at which deserts absorb carbon dioxide more time to complete their studies. In May 2008, Desert Research Institute in Nevada reported results from a study in the Mojave Desert of the southwestern U.S. They found that "The annual removal of the greenhouse gas [carbon dioxide] from the atmosphere was upwards of 100 grams of carbon per square metre, on a par with some temperate forests."

http://news.dri.edu/nr2008/Mojave_051208.php

According to the DRI press release, they are conducting more research this summer to see how much carbon dioxide is being removed by the biotic crust that forms on desert soils. That crust is fragile stuff which can take hundreds of years to form. If it is removing carbon dioxide from the atmosphere in significant quantities, this has huge potential implications for how the desert should be treated, not just in regard to building renewable energy facilities, but also as to whether off-road vehicles should be allowed to drive cross-country (not on trails) across desert lands that are publicly owned.

Second, it will give the California Energy Commission a chance to get ready for the wave of applications headed its way. In California, central-station solar energy generating facilities over a certain size (50 MW?) have to be permitted by the California Energy Commission (CEC) even if the project is on U.S. Bureau of Land Management (BLM) land. When I've talked to some CEC representatives in the past, they have expressed concern about having enough staff to process all the large-scale solar applications that they expect to land on their doorstep. According to some BLM staff I've talked to, funding will be an issue at the CEC because the CEC does not recover costs of the environmental review from the applicant, while BLM does. In other words, if what I was told is accurate, the costs of the environmental review will be borne by the CEC (as funded by CA taxpayers), and if they don't have enough in their current budgets for all the review, well, then things get pretty interesting. It's true that the CEC does have an application fee, but the BLM staff I've talked to didn't think that was adequate to cover the costs of processing the application, especially the necessary environmental review.

It should also be remenbered that there have already been a LOT of renewable energy applications submitted to the BLM in the western U.S. even before the delay. Here's a link that shows the solar, wind, and geothermal leases and applications for just ONE BLM district in California, the California Desert District, which is also designated as a National Conservation Area.

http://www.blm.gov/pgdata/etc/medialib/blm/ca/pdf/cdd/ene ...

Unfortunately, the map at the link doesn't overlay with designated critical habitat for endangered species, and it should. That is an issue that will likely come up in the programmatic environmental impact statement (PEIS) that the BLM is preparing for solar. Should large-scale solar facilities be allowed in designated critical habitat for endangered species, remembering that critical habitat has been identified as that necessary for the species to recover and be delisted as endangered? (I'm simplifying a little, but you can easily Google critical habitat to find its exact legal definition.)

The third silver lining is that this PEIS will help to standardize BLM procedures. Right now, each BLM office is doing things differently because they don't have much written guidance. I have been told that insiders such as a former high-level Department of the Interior official have been hired as consultants by companies wanting to build giant desert solar facilities on BLM land. These insider consultants are applying political pressure to attempt to get special treatment for their clients that other renewable energy companies don't get. Having a PEIS will better level the playing field among the companies. I personally support a level playing field because many of the renewable energy developers these days are from the fossil-fuel industry. It's too soon to know how many of them are serious about building renewables and how many are just speculators.

Correction to title in earlier post

"There are at LEAST three silver linings"

Sigh.

More on this issue and avoiding infighting

The above post is one of three on this exact issue.  The post at this link has many more comments:

http://gristmill.grist.org/story/2008/6/27/01236/3260

There is a distinction between, on the one hand, reducing the ultimate rate and amount of fossil fuels consumed through displacement of fossil fuels with renewable energy, and, on the other hand, adapting to the increasing scarcity of fossil fuels by supplementing fossil fuel energy with renewable energy without actually reducing the rate of consumption or ultimate amount of fossil fuels burned.  

The first situation would be beneficial to non-human elements in the environment.  The second situation would be an example of a species turning to a lower intensity resource as its higher intensity resources are consumed, and while it would help humans adapt to their changing environment it may not reduce ultimate human impacts on non-human elements of the environment.  

Some people are called more toward protecting the non-human elements of the environment and point out that renewable energy deployment will not as a logical necessity reduce human impacts to non-human things because renewable energy deployment consumes resources.  They worry that deployment of renewable energy technologies may not help the non-human environment because it could be mostly a human adaptation to an increasingly burdened environment and not a lessening of the ultimate human footprint.  They are skeptical that unbridled renewable energy development will advance their values and would like to see quantified proof that it is making a difference in reducing the human footprint at a global level and not just making this footprint deeper.  Some of these people see that a human crash is biologically inevitable and prefer to protect specific places and their inhabitants.  

Others are called more to protect the human environment and see that renewable energy deployment is necessary over the long run to human survival.  They are more concerned about using renewable energy to help avoid a societal crash as fossil fuel reserves deplete and population increases.  They understand that we face tremendous challenges but must do as much as we can to lessen the risk of human catastrophe because that would harm everything on Earth.  

Many of us value both perspectives.  Both of these perspectives have merit and are important, but neither has a corner on "the truth."  It is the tension in these values that can help us discern how to address specific energy needs.  

I find it helpful to think about renewable energy from both perspectives, because it helps me appreciate the concerns and values of both sides, and to remember that those of us who are concerned about fossil fuel consumption, renewable energy and the environment have much more in common with each other than we do with those who are care primarily about near-term personal gain and comfort, who prefer a more "reactive" approach to the challenges we all face.  

Those who value desert environments can help by being skeptical of industry solutions or proposals that use unproven technology or target sensitive areas because these may be designed to create fights between us.  Not all renewable energy proposals have merit or integrity.  Renewable energy is a tool, and as with all tools, it can be used for good or ill intent.

Those who value renewable energy can help by aiding in our choices about when, where and how to deploy specific technologies. While I appreciate that some want to deploy all renewable energy technologies everywhere as fast as possible, resource and technological limitations will result in differences in deployment rates and appropriate applications of technology. They can help us find the best solutions for particular places and communities and also help us distinguish the relative merit of industry proposals.  

Since there are many appropriate places for renewable energy development, it seems to me that there may be a high correlation between proposed renewable energy projects with significant impacts on sensitive habitats and political manipulation by individuals with a political agenda who are using specific renewable energy technologies inappropriately as a tool to accomplish other unjust objectives.  For different reasons all of us can call BS on dubious proposals.

As we move into an era of declining fossil fuel extraction rates due to "peak" effects, it will become increasingly important to track changes (up or down) of fossil fuel extraction rates in light of peaking dynamics so that we can determine whether and to what degree renewable energy deployment is in fact slowing greenhouse gas emissions more than that caused by a declining resource base. That way we can have a clear understanding of what we are doing to our environment and the degree to which we are, or are not, succeeding in our efforts.  


Clarification

By "above post" I mean the original article entitled, "Check Out Our Ray-Bans!" and not the comment immediately proceeding mine.  

Sorry for the confusion.  

Bottom line,

collecting solar energy will create a lot of shade. Solar homes will have to spread themselves out so they won't shade their solar neighbors, which is not optimal. Dense housing cannot make much use of on-site solar because the solar footprint will be small. Dense housing will rely on off-site solar. Destroying ecosystems to build solar power is a no-no.

In the end, it all comes down to biodiversity. Poison Darts--Protecting the biodiversity of our world
Land Tax

I just heard that Exxon is planning on selling off all of their gas stations and investing more into the refining process.

Well, if 150 mpg plug in hybrids, which actually need zero gasoline for trips under 40miles per day, were about to hit the market in 2 years...wouldn't you?

The refining process can produce the higher ticket plastics and other products that actually bring in more money than gasoline (which is really a by product, not the most important, of oil refining).

This is what solar power advocates get for blindly advocating big solar, which will be environmentally destructive.  I hope these projects are stopped permanently.  As I've said ad nauseum, what's needed is locally produced energy, like solar panels on people's roofs, not more destruction of ecosystems, in this case mainly desert ecosystems.

In the spirit of cap and trade, why don't we add penalties to big solar so that they have to pay the full brunt of their impact on land and land usage.

local power generation

The best idea for that so far is the Genepax MEA generator...

http://techon.nikkeibp.co.jp/english/NEWS_EN/20080616/153 ...

(Don't bother skepticalizing about it...I know..I know...)
As someone who has camped in Oregon BLM land, I think that every single square mile is sacred...


could say so much...

grrr... i have so much to comment on, but not too much time...  i think we need as many renewables as we can as FAST as we can.  I agree with christopher above, and others about little damage in the near future (and i believe the damage would be minimal) to avoid MASSIVE damage later (that's the whole point of switching our generation infrastructure to renewables in the first place, right?)  

And another thing...I feel I have some credibility to the following comment as well, since I work as an energy engineer/consultant, who deals with PV, wind, solar thermal, etc., along WITH ECM's (Energy Conservation Measures) every day...Distributed generation is AWESOME...whenever I fly anywhere, and when you get close enough to the ground you see all these barren roofs that are PERFECT real-estate for PV/solar thermal (and wind to a lesser extent), it's depressing.  THAT SAID - and the point I want to stress more than anything - CSP (Concentrated Solar Power), at least the newer designs, GENERATE DISPATCHABLE POWER!!!  This means they can TRULY replace coal/nuclear/nat. gas as BASE LOAD GENERATORS...You need energy storage systems to accomplish this, which is extremely capital-intensive, thus making distributed energy storage not feasible (unless heavily subsidized, which would be great).

OK - gotta go, too much time on this already, but i want to close echoing what some1 said earlier...  This is a daunting task we are facing trying to replace fossil-fuel generation, and we need all the help we can get.

Rooftops

This thread (and the related ones) inspired me to do some research and look at the potential rooftop solar has.  I used optimistic assumptions so what I care up with is limiting case: real world limits are almost certainly lower.

I'd be really grateful if Sunflower, Solarwind, and HiTension who all have professional expertise in ths area would comment and refine the info.

Overturned!


Solar Moratorium Scrapped,
Bureau Of Land Management To Allow New Plants

BLM's decision to reverse the solar application moratorium comes as the alternative energy industry remains jittery about another issue: a $6 billion package of alternative energy tax credits, including about $1.3 billion for solar, that's gotten stalled in Congress. Reid wants to get that resolved after lawmakers return from the July 4 holiday.

There are currently nine utility-scale solar plants in the U.S. capable of producing a combined 425 megawatts of solar power, according to the Solar Energy Industries Association.

Solar industry officials and environmental groups agreed that BLM, which has granted numerous leases to the oil and gas industry, needs to move faster on the solar proposals.
http://www.huffingtonpost.com/2008/07/02/solar-moratorium ...



-David Ahlport

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