Mohave County Supervisors
700 W. Beale Street
Kingman, AZ 96401
RE: Opposition to the Resolution Implementing the Moratorium on the Designation of the E (Energy Overlay) Zone
Dear Chairman and Supervisors,
The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We urge you to vote NO on the moratorium on renewable energy projects in Mohave County at the Board of Supervisors meeting on October 16, 2023.
Economic Benefits. This moratorium will affect the county’s opportunity to benefit from the tax revenues of these projects which could address some of the county’s potential budget deficit issues. In August 2023, the Board voted for a hiring freeze until plans could be made to address the County’s potential $18.5 million deficit. The County is considering an 18% budget cut that would affect, “one-in-five county employees” according to the County’s Chief Financial Officer. Utility scale solar projects could help the County avoid the economic difficulties from the necessary austerity measures it will need to take to address this budget deficit.
For example, constructing a 100 MW utility scale project, depending on equipment costs, labor costs, financing costs, and other federal incentives, could cost between $100 - $200 million. The tax revenue from this project using the standard formula of Property Tax Revenue = Assessed Property Value × Property Tax Rate, could be between $1.25 – 2.5 million a year. If we then assume that the following projects: White Hills (450 MW), Mineral Park Solar (275 MW), and Leo Solar (300 MW), all projects proposed on public lands in Mohave County, being considered by the BLM, were on private property, the county could easily collect between $12.8 to $25.6 million per year in tax revenues. This would essentially solve the County’s budget deficit issues.
AriSEIA did commission a study by Elliott D. Pollack & Company to assess the benefit to the County of a sample solar + storage project. The study is attached and found that the total economic impact of a single project was $442.5 million in economic impact countywide. The fiscal or tax impact of a single project to the County would be nearly $31 million.
Low Water Usage. The draft of the resolution implementing the moratorium, incorrectly cites the study by Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review, to justify the statement, “WHEREAS a significant amount of water and other resources are necessary to maintain solar panels in desert and arid environments.” In the Kahled et al. study, the researchers attempt to understand the environmental conditions that may affect the performance of solar systems during their operational lifecycle by conducting a review of the academic literature on the topic. While their study shows that dust and humidity do affect the performance of solar systems, they show that the use of hydrophobic (water repelling) and hydrophilic (water dispersing) coating materials for the panels help clean them by sweeping away all the dirt during a rain. While the study suggests that sprinkling water on the solar modules helps reduce their temperature thereby improving performance, it does not discuss how much water is needed to perform this. In fact, the study suggests that properly tilted solar modules with the necessary cooling and self-cleaning material would require as little water as possible during their lifecycle. In fact, operators of solar farms do not wash the panels, as it costs more to do than the benefit obtained.
A study from researchers at the Brookhaven National Laboratory, shows that when compared to conventional power generation technologies such as coal and natural gas, solar actually uses far less water during its lifecycle. That study looked at the lifecycle uses of water of different generation technologies across the United States and concluded that solar and wind are the best options for conserving water supply, when compared to coal, nuclear, oil/gas, and biomass technologies.
Another study by researchers at the National Renewable Energy laboratory (NREL), estimated both the water withdrawal and consumption of electricity generating technologies. Again, they found that solar and wind technologies use less water than their counterpart energy technologies. This study looked at the use of water through the entire lifecycle of the technology from component manufacturing to fuel acquisition to power plant operation and decommissioning, and concluded that the water used by thermoelectric plants, such as coal, oil/gas, and nuclear for water cooling still dominate the entire water value chain in electricity production.
Panel Safety. The draft resolution states that the “impact of these renewable energy projects on the local population and environment over a long period of time is unknown.” This is not the case. The long-term impacts of some renewable energy technologies such as solar and wind, on host and surrounding communities have been extensively studied in the United States and other parts of the world. One such study on the environmental impacts during the installation and operation of large-scale solar power plants studied these effects with respect to land use, climate, geohydrological resources, and human health in comparison to traditional power systems. They found that solar causes less exposure to hazards like mercury, cadmium, and particulate matter.
Further, risks of site contamination are much less than for most other industrial uses because solar technologies employ few toxic chemicals and those used are present in very small quantities. Testing shows that silicon and cadmium telluride (CdTe) panels are both safe to dispose of in landfills and are also safe in worst case conditions of abandonment or damage in a disaster. Multiple sources report that most modern solar panels (both crystalline silicon and cadmium telluride) pass the Toxic Characteristic Leaching Procedure (TCLP), which is a test method used to determine whether a waste is a toxic hazardous waste.
Interconnected Grid. During the public hearing meetings on August 7, 2023, and September 5, 2023, some residents and other stakeholders raised the issue of the location of these large utility scale solar projects in Mohave County. They were specifically concerned about the fact that the power generated from the solar farms may not be used by residents of Mohave County. This is a misunderstanding of how the U.S. electric power grid operates and how electricity is regulated at the Federal and State levels. Utility scale solar projects can only be located in areas where land is plentiful and the solar resource – the sun – is abundant. This makes Arizona a good location for these projects. In addition, once a generation asset is connected to the transmission system, there is no way of determining which electrons go to a specific consumer. This is because electricity takes the path of least resistance. Hence there is no way of knowing if the electricity used by residents in Mohave County was generated in Mohave County. The important issue is that there should always be enough capacity on the grid to meet the demand in real time, which is consistently changing. If this is not the case, the reliability of the grid could be called into question.
For example, UNS Energy Inc. (UNSE) owns a total of 291 MW of installed thermal capacity from three natural gas generation plants. Only Black Mountain is in Mohave County, with Valencia and Gila River projects located in Nogales and Maricopa respectively. UNSE also purchases about 36% firm capacity through wholesale market power purchase agreements (PPA) to address summer peaks, and also purchases over 89.4% of its renewable energy resources through PPAs with third parties. This is similar to Mohave Electric Cooperative (MEC), which is a member of the Arizona Electric Power Cooperative (AEPCO). AEPCO is the generation and transmission (G&T) co-op utility for Mohave and six other distribution co-ops in Arizona, New Mexico, and California. While MEC owns two solar farms in southeast Fort Mohave, AEPCO, from which it purchases most of its electricity, owns generation assets throughout Arizona and California. This means that Mohave County residents are consuming electricity generated in other counties in Arizona and even in California. The interconnected nature of the US electric power grid is a strength. If a major generation plant in Mohave County fails, its residents can be rest assured that they have access to power from Nevada, California, New Mexico, and other states in the west.
Environmental Impact Statements. The draft of the resolution stated that “additional information and research are needed to determine the allowable groundwater usage and suitable areas for large projects such as solar, wind, and geothermal. The location of a facility that uses water, while on the surface may fit the area and general plan, may overuse water and other resources in the groundwater basin.” The draft went on to refer to the environmental impact statement on the Desert Sunlight Solar Farm, one of the largest solar farms in the country located on the California Desert Conservation Area, to justify that claim. This is incorrect.
The California Desert Conservation Area is a vast ecosystem located in Southern California managed by the BLM. Based on the environmental impact statement, the BLM amended the “California Desert Conservation Area Plan (CDCA Plan) to allow for solar energy and of a right-of-way (ROW) grant to lease” the land to the developers of the project, which was commissioned in 2015. In fact, according the BLM, many of the adverse impacts of the projects “to biological resources, cultural resources, land use, visual resources, hydrology, water quality, and water use,” were adequately “avoided or substantially reduced based on compliance with applicable laws, ordinances, regulations and standards, and compliance with measures provided” in the impact statement. Hence by conducting the environmental impact study, the effects of the project on wildlife, groundwater, and other resources were adequately known and appropriately mitigated. In fact, a 230 MW Battery Energy Storage System (BESS) was added to the Desert Sunlight Solar farm in August 2022. Conducting an environmental impact study is standard procedure for utility scale solar projects.
For the reasons articulated above, please vote no on the draft resolution and reject a renewables moratorium in Mohave County.
Autumn T. Johnson
 River City Newspapers, County to Consider Exceptions to Hiring Freeze, Aug 30, 2023, available here https://www.havasunews.com/news/county-to-consider-exceptions-to-hiring-freeze/article_8cbda648-45fa-11ee-bf3b-1b533a671250.html.
 Today’s News Herald, As County Faces $18.5 Million Deficit, Departments Present Bleak View of Possible Cuts, September 20, 2023, available here https://www.havasunews.com/news/as-county-faces-18-5-million-decit-departments-present-bleak-view-ofpossible-cuts/article_fdd35ab2-581f-11ee-8a65-e36102c35e70.html.
 Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review, 10 ENERGY SCI. ENG. 656, 664-65.
 Vasilis Fthenakis, Hyung Chul Kim, Life-cycle uses of water in U.S. electricity generation, Renewable and Sustainable Energy Reviews, Volume 14, Issue 7, 2010, Pages 2039-2048, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2010.03.008.
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 Damon Turney, Vasilis Fthenakis, Environmental impacts from the installation and operation of large-scale solar power plants, Renewable and Sustainable Energy Reviews, Volume 15, Issue 6, 2011, Pages 3261-3270, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2011.04.023.
 Parikhit Sinha, Potential Environmental Hazards of Photovoltaic Panel Disposal: Discussion of Tammaro et al. (2015), available here https://doi.org/10.1016/j.jhazmat.2016.04.021.
 Human Health Risk Assessment Methods for PV Part 3: Module Disposal Risks, 2020, Report IEA-PVPS T12-16: 2020, ISBN 978-3-906042-96-1.
 Health and Safety Impacts of Solar Photovoltaics, NC Clean Energy Technology Center, North Carolina State University, May 2017.
 UNS Electric Inc, 2020 Integrated Resources Plan (IRP), available here https://docs.uesaz.com/wp-content/uploads/UNSE-2020-Integrated-Resource-Plan.pdf.
 US DOE, Office of NEPA Policy and Compliance, EIS-0048, June 24, 2011.
 Energy Storage News, 230MW BESS Comes Online at Bureau of Land Management Site in California, August 17, 2022, available here https://www.energy-storage.news/230mw-bess-comes-online-at-bureau-of-land-management-site-in-california/.
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