The lead agency for environmental review of distributed-generation
projects is normally the city or county where the project is located. They
do not act as “one-stop shops” for permitting, so projects also have to seek
permits from the various state and federal agencies involved.
and help utilities meet state RPS goals. In California, communities are developing climate action
plans that sometimes set binding greenhouse
gas-emission-reduction goals that renewables
may help to meet. The process for amending the
general plan and zoning code can help to engage
community members in identifying locations
for renewable projects that they can support and
address concerns about visual impacts, safety and
suitability in advance.
Developers can also benefit from such
advance planning. If renewables are considered
in the zoning code, it can eliminate the need
to seek amendments to the general plan, and
in some cases projects may go ahead without
even seeking a conditional-use permit. If public opposition arises regarding a project located
within an area zoned for such use, opponents
will have fewer opportunities to tie up the project in approvals. The decision makers also may
have more incentive to support the project if it
matches the plan they approved.
Environmental Quality Review. Projects in
California are generally required to undergo
comprehensive environmental review under the
California Environmental Quality Act (CEQA).
The level of review required under CEQA
depends upon whether the project is expected to
have significant environmental impacts that cannot be mitigated. In practice, the level of review
— and thereby the amount of time it takes to
complete — can depend upon the motivations
of the permitting agency and the level of public
scrutiny being applied to the project.
The CEQA issue areas that tend to be prob-
lematic for projects of this scale are the same
as those for much larger projects: biological
resources, aesthetics, air quality, cultural resourc-
es and agricultural resources. A key part of the
CEQA analysis is to look at both the individual
impacts of the project as well as any cumulative
proposed in such areas and must still undergo
the proper analysis. As mentioned above, when
considered cumulatively, their impacts may have
particularly significant effects on the amount of
remaining habitat for a species.
Copyright © 2011 by the American Solar Energy Society Inc. All rights reserved.
impacts the project may have when examined
in concert with other projects under consideration in the area. The cumulative impacts will
be increasingly significant for distributed-generation projects proposed where other projects are
also being sited. While a single project may not
have a significant impact on a resource (such as
a plant or animal species), if there are five other
projects in the area they may collectively have a
significant impact. A comprehensive review may
be able to help address and minimize some of the
potential cumulative impacts.
If a community updates its general plan,
as mentioned above, it is required to undergo
CEQA review of the environmental impacts
of the plan. This CEQA review often can act
as a “programmatic” document that looks at
the broad implications, including the cumulative impacts, of the types of development the
plan intends to allow. When specific projects
then are proposed in accordance with the plan,
they can “tier” off from the programmatic document, which sometimes reduces the number of
detailed studies required and may narrow the
range of issues to be considered in the project-level CEQA review. That may enable projects to
be reviewed more quickly, but it will also ensure
better consideration of the cumulative impacts
of siting numerous small projects in a region.
Endangered Species Act Adherence. One of
the most detrimental environmental risks posed
by a renewables project is the effect on the habitat of threatened or endangered species. This is
particularly true for utility-scale projects, which
can require grading of hundreds of acres and
tend to be located on previously undisturbed
land. However, distributed-generation projects
can also encounter species issues. While these
projects more often can be located on disturbed
land and avoid areas of known habitat because
of their smaller footprint, they are not always
getting to comprehensive Planning
The procurement programs for distributed
generation are already underway, so it is important that these comprehensive planning efforts
be initiated quickly in order to be most effective.
Following the models set forth in the DRECP
process and the Renewable Energy Transmission Initiative, the cities and counties in the
heavily prospected areas in the Mojave and
Colorado deserts may want to begin a collective
planning process that brings local governments
together with state and federal resource agencies
to begin the discussion of how to responsibly site
distributed renewable resources on non-public
lands in the region.
More suburban and urbanized cities and
counties that want to encourage renewable
energy development in their communities might
begin by taking a look at whether their zoning
codes sufficiently address the types of renewable
energy development they want to see built. Solar
and other renewables companies can help initiate these discussions in communities that they
hope to develop in someday. This early planning
may make the entitlement process easier in the
long run for everyone. ST
