Intersect Power Response to the January 26, 2021 Letter from United States Fish and Wildlife Service to the County of Alameda Community Development Department re: the Aramis Solar Energy Generation and Storage Project’s Final Environmental Impact Report

Intersect Power Response to the January 26, 2021 Letter from United States Fish and Wildlife Service to the County of Alameda Community Development Department re: the Aramis Solar Energy Generation and Storage Project’s Final Environmental Impact Report

The greatest single conservation threat facing amphibians in the coming decades is global warming. To reverse this alarming trend, we need to move as quickly as possible to decarbonize our economy.  The Aramis Renewable Energy Project achieves not only the critical goal of decarbonization, but it also enhances the land to sequester carbon, and it has been thoughtfully designed to enhance habitat for vulnerable species, including amphibians.

Intersect Power stands firmly behind the quality of the Aramis project’s biological survey work, which was conducted over multiple years by experts, and included protocol-level and focused surveys for amphibians and other taxa. There is no potential breeding habitat for California red-legged frog or California tiger salamander on the Aramis project site, and the comprehensive surveys did not detect any frog or salamander individuals. San Joaquin kit foxes also are not present at the site, and haven’t been seen in Alameda County for decades. Intersect Power sited the Aramis project on its particular plot of land because of its low potential for harm and its high potential for local benefits.

 The Aramis project is one of a handful of locations where modifying current land management practices in favor of renewable energy generation has the potential to improve the quality of habitat for a wide range of species while directly offsetting fossil fuel generation in Alameda County. The solar arrays have been deliberately designed to avoid areas with higher potential habitat value, namely Cayetano Creek, which will be protected from development activities.

 The County’s EIR is a high-quality document that complies fully with the law. Accordingly, the EIR includes comprehensive mitigation measures to ensure avoidance of harm to amphibians and other species. In particular, installation of an exclusionary fence with one-way doors is required well in advance of project construction, prior to the wet season, immediately preceding on-site work for the Aramis project. While there is no evidence that amphibians are present, their life history dictates that they would move from their upland refuges to off-site breeding ponds. The one-way doors would ensure they cannot re-enter the site. Therefore, construction may proceed with no risk of harm to these species.

 Land management practices that currently make the Aramis project site largely inhospitable to amphibians, namely disking, which churns up the soil where salamanders might otherwise aestivate, will be eliminated. We anticipate that long-term operation of the solar field may result in a net benefit to the species. Additionally, if San Joaquin kit foxes do return to Alameda County, the project site will provide for safe passage, hunting ground for their favored rodent and rabbit prey, and even denning and pupping habitat.

Intersect Power holds the wildlife agencies in the highest regard and takes any feedback they provide on projects very seriously. In response to recent concerns expressed by representatives of the United States Fish and Wildlife Service and the California Department of Fish and Wildlife that cryptic amphibian species, like California tiger salamander, are difficult to detect, we are in close consultation with the agencies to collaborate on the best path forward for the species and the project. We look forward to working closely with agency staff, and we thank them for their service protecting biodiversity. 

Intersect Power is proud to have support for the Aramis project from leading environmental organizations such as the Sierra Club: www.intersectpower/aramis/partnership.

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