The NEPA analysis protocol requires an analysis of potential alternatives that would meet the purpose and need of the proposed Project. The alternatives analysis includes an evaluation of impacts of the alternatives, to the level necessary to ascertain a relative comparison of impacts of the proposed Project and those of the alternatives. Alternatives to the proposed Project may include alternative sites, alternative technologies, alternative disposal of the proposed technologies, etc. The alternatives analysis supports the NEPA directive to “use all practicable means and measures to foster and promote the general welfare, create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans.”
Alternative 1—No Action
NEPA analyses must consider the potential effects that would arise if the proposed Project were not to occur. Analysis of the No Action alternative provides a benchmark level of environmental effects by which the effects of the Project and other alternatives can be measured, thereby providing information necessary to allow a logical comparison of effects.
Under the No Action alternative, the application to the BOCC for a permit to develop and construct the Project would not be granted and the Project would not be constructed. The environmental resources in the area would likely continue as is currently occurring. The impacts (beneficial and adverse) to environmental resources associated with the No Action Alternative are discussed under each resource in Chapter 3.
Alternative 2—Proposed Action
A solar developer proposes to construct and operate a 100MW solar power plant. The proposed solar power plant would include the design and construction of a solar PV panel array, access roads, substation, switchyard, and battery storage (BESS). The Project is proposed to connect to an existing transmission line owned and operated by Tri-State, which, due to the size of transmission line and design of the energy grid, would carry the electricity generated at the proposed facility out of the local/regional service area to be distributed elsewhere.
In order to be implemented, the Project would require the following:
- Approval and recommendation of the San Miguel County Planning Commission.
- Licensing and permitting by the San Miguel County BOCC.
- Accepted and permitted by the San Miguel Power Association.
- Lease agreement with the Colorado SLB to develop the east array area.
- Lease agreement with the landowners to develop the west array area.
The Project is proposed as a long-term temporary development based on a 30-year lease of the properties. The solar facility would be in operation for the term of the lease, at the end of which, the facility would be decommissioned and dismantled, and the Project site reclaimed. According to the Project website, the timeline of the Project includes permitting and development in 2023-2024, construction in 2025, and operation by 2026.
2.2.1 Project Components
For purposes of this EA, the following definitions are used with reference to the Project components listed below:
Solar Array Area: The solar array area refers to both the east (Section 1) and west (Section 2) array areas and to all areas within the proposed perimeter fencing; this includes tracker rows and modules, the substation, switchyard, and BESS areas, and staging areas. This also includes any area outside of the perimeter fencing that would incur impacts in the process of constructing the proposed facility, i.e., surface disturbances associated with installing the perimeter fencing and any access roads that begin at local/county roads and enter the perimeter fencing, and electrical servitudes requiring trenching or plowing to install transmission lines.
Proposed Project area: The solar array area and any area within the vicinity of the solar array area that would be impacted by the Project. Generally, the Project Area will refer to the Solar Array area and all areas within a 1-mile radius. However, this may also include areas further away that would incur impacts from the proposed Project. Such areas will be specifically indicated when necessary for the purposes of this EA.
The following information was gathered either from flyers (Appendix A) provided during the May 16, 2023, meeting, or from the Project website:
Solar Array
The Project is designed to be constructed across two array areas, as seen in Figures 3 and 4. The Project would require 189,196 PV modules. The modules are connected in series on tracker rows, which are connected to form power blocks, which are aligned to form the solar array. The modules would be mounted to central beams, forming tracker rows, which are designed to tilt the PV modules to follow the sun throughout the day to maximize exposure to sunlight, and increase effectiveness of the solar array. There would be a total of 30 inverters, which along with the DC-coupled BESS units, collect the power from the power blocks. Note: Though not in the information flyers or on the website, typically, tracker row motors are powered by lithium-ion batteries.
Substation, Switchyard, Battery Energy Storage System (BESS)
A substation, switchyard, and BESS yard are proposed to be constructed within the Section 2 array area. Construction would require clearing, grading, limestone gravel to provide a working surface for access vehicles, and concrete foundation(s) where necessary.
Generation Tie (Gen-tie) Lines
The electricity is carried from the power blocks to the substation by underground gen-tie electrical lines. An undetermined amount of trenching would be required for installation of the gen-tie lines that would run throughout the array areas to tie the power blocks together. Information regarding surface area impacted by trenching was not available.
Access Roads
There would be gravel access roads throughout the array areas. These would be permanent roads to provide access to the Project area for the life of the Project. Access roads would have a 16-ft graded ROW. There would be 7.57 acres of graded/gravel roads in Section 1 and 4.74 acres of graded/gravel roads in Section 2.
Perimeter Fencing
Both array areas would be fenced to prevent wildlife and unauthorized entry to the Project area. Installation of the fencing would incur surface impacts and likely require an approximate 6-foot area of clearing/surface disturbance along the entire length of the fencing. The total linear distance of fencing is not available.
Project Specifications
Project specifications as provided on the information flyer (Appendix A) are provided in Table 2-1, below. 
2.2.2. Construction
Timetable and Workforce
Construction is estimated to take place over a period of 24 to 36 months. It is estimated that 300 full-time employees would be hired for construction. Information regarding housing for workers or how workers would access the area was not available. Parking, transport or traffic patterns have not been identified, but primary access to the Norwood area is typically via CO Hwy 145 from the east, and developed areas such as Ridgway or Montrose.
Construction Methodology
Specific information regarding the construction methodology that would be employed to implement the Project was not provided during the May 16, 2023, meeting or on the Project website. A list of equipment typically used during construction of utility-scale solar facilities is provided in Table 2-2. The following information has been gathered through the author’s professional experience, via industry literature, and available NEPA documents prepared for solar PV projects (BLM, 2019).
Ground Cover Ratio
According to the information flyer, the ground cover ratio of the solar array area would be 31.0%. which means that 31% of the fenced area or 180.02 acres would be effectively covered by PV modules.
Clearing, Grading, Trenching
Topography in the Project area is sloped and variable throughout the Project site. The proposed solar array areas would require some clearing and grading to make the area drivable for vehicles and equipment, and create appropriate grade necessary to keep tracker rows within the engineering and design specifications. Information regarding clearing and grading was not provided during the May 16, 2023, meeting or on the website. The total area that would be graded is not known.
Construction Sequencing
Each element of construction generally requires multiple passes of equipment and vehicles along each tracker row and throughout the proposed solar array areas. Construction of a solar array typically follows the below sequence:
- Geotechnical Investigations: Geotechnical investigations are necessary to finalize engineering specifications.
- Staging Areas: Cleared and graded areas for temporary storage of equipment and materials.
- Site Preparation: Land surveying and site delineation; trenching and excavation; dust, erosion and sediment control measures.
- Solar Array Assembly: Materials and equipment are mobilized to individual solar array block areas; trenching, installation of underground cable, backfill trenches; installation of posts and frames for the tracking system; installation of PV modules; connection of electrical terminations; and inspection, testing, and commissioning equipment. Note: Geotechnical surveys would be necessary to determine which method of “trenching” would be appropriate for burying the MV cable.
- Electrical Collection / Transmission Systems: Installation of the DC and SCADA systems; the power and control equipment; the high, medium, and low voltage cables; grounding of all equipment; and installation of communication systems.
- Substation: Excavation and pouring a foundation; installation of electrical equipment, overhead cabling; installation of a control building; installation of all auxiliary systems (e.g., heating, ventilation, lights).
- Internal roads and transmission access: grading, compacting, and leveling.
Construction Materials and Waste Handling
The Project would require general construction materials and materials specific to construction and installation of a solar power generating plant and associated electrical infrastructure. The Project would be required to handle and dispose of wastes according to San Miguel County policy. Construction waste would be managed according to a Project waste disposal plan; likely stored in dumpsters to be serviced by a solid waste hauler licensed in San Miguel County, Colorado.
2.2.3 Operations and Maintenance
Operation and maintenance (O&M) for the proposed Project would occur for the life of the Project (30 years). Site maintenance would likely include inspections and maintenance of solar arrays and infrastructure, roads, fencing, lighting systems. PV panel washing would also be necessary on an as needed basis. An O&M Plan is not available for the Project. The number of O&M staff and the frequency of inspections/maintenance is not available.
PV Module Washing and Water Needs
PV modules need to be cleaned periodically to maintain optimum efficiency. No information regarding module cleaning or water needs was provided during the May 16, 2023, meeting or on the Project website. According to the Draft Programmatic Environmental Impact Statement for Solar Energy Development in Six Southwestern States, the water demand for a 10-MW PV facility is estimated to be about 0.5 acre-feet (AF) a year for panel washing (BLM and DOE, 2010, 2012). Based on that estimate, the 100 MW Project would require 5AF (1,629,257.14 gallons) annually, or 150 AF (48,877,714.05 gallons) over the 30-year lease term.
2.2.4 Decommissioning and Site Reclamation
Decommissioning would include dismantling all components and removal from the Project site. According to the project proponent, all tracker row supports would be removed; any supports that cannot be pulled from the ground would be cut off at 18 inches below grade. All materials, components, and equipment would be disposed of by appropriate methods and according to county, state or federal regulations. No specific information regarding the reclamation plan, recontouring graded areas or plans to revegetate the site is currently available.
2.3 Alternatives to the Proposed Project
The NEPA environmental review process requires that alternatives that meet the purpose and need of the Project be analyzed to provide a benchmark of potential impacts to which the impacts of the proposed Project could be compared. The intent of the alternatives analysis is to provide a robust discussion of viable alternatives in support of agency review and planning.
Alternative 3 - Dispersed Solar to provide electricity on a local basis.
A true assessment of the immediate and future growth of San Miguel County and region and the electrical needs would provide a basis for planning dispersed solar that could provide electricity for the area and meet the county and state mandates regarding reduction of GHG.
Census data for Norwood and the County indicate that Norwood encompasses approximately 192 incorporated acres, has a population of 551, with 240 (±52) housing units (U.S. Census Bureau, 2021). San Miguel County has a population of 8,003 with 6,638 housing units; and is expected to reach a total population of over 10,914 in 2040. (July 1, 2022) (Census Bureau, 2022).
A simplistic analysis of current population data would indicate that the need for solar-generated power in the county could be met by less than half of the proposed Project. Solar facilities could be dispersed throughout the region, or even on a town-by-town basis to provide adequate power needs, with less direct impact on resources discussed in Chapter 3. This alternative could meet the purpose of providing electricity to San Miguel County communities and align with goals to reduce GHG and be carbon neutral as outlined in the Ouray and San Miguel County Regional Climate Action Plan.
In general, utility-scale systems (solar, wind) require vast resources to construct, have large footprints that impact vast acreage of natural resources and habitat, require vast resources to develop battery storage, and require countless acreage for transmission lines. Localized systems have smaller footprints and have less of an impact on resources to construct and site. Because the facilities are sited within or near the service area, smaller facilities do not require large transmission lines to deliver the service, drastically reducing the associated environmental impacts.
Alternative 4 – Utilizing previously impacted areas.
Siting proposed facilities at brown fields, waste disposal facilities and other locations that already have been severely degraded or converted by previous land-use should be considered as a priority, instead of siting Projects on areas that are in a natural state with high value habitat.