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and Nevada, USA, in recent years. See, e.g. , Hadassah M. Reimer & Sandra A.
Snodgrass, Tortoises, Bats, and Birds, Oh My: Protected Species Implications
for Renewable Energy Projects , 46 Idaho L. Rev. 545, 560-61 (2010)
(describing opposition from environmental groups to proposed Searchlight
Wind Project in Southern Nevada based in possible disruption of tortoise
habitat); U.S. Bureau of Land Management, McCoy Solar Energy Project
(2013), available at www.blm.gov/pgdata/etc/medialib/blm/wo/MINERALS__
REALTY__AND_RESOURCE_PROTECTION_/energy/priority_projects.
Par.56888.File.dat/McCoy%20Solar%20fact%20sheet.pdf (describing offsite
mitigation measures in connection with McCoy Wind Project in California
aimed at protecting desert tortoise habitat).
5 See, e.g ., McCoy Solar Energy Project, supra note 4 (describing developer's
purchase of mitigation lands to protect habitat of Mojave fringe-toed lizard).
6 Specifically, fears over impacts on giant kangaroo rat populations have
generated opposition to utility-scale solar energy projects in California in recent
years. See, e.g ., David Sneed, Giant Kangaroo Rat Puts Kink in California
Valley Solar Project , The Tribune (San Luis Obispo, CA) (Sept. 11, 2010),
available at www.sanluisobispo.com/2010/09/11/1284985/giant-kangaroo-rat-
puts-kink-in.html (last visited June 10, 2013) (describing how the discovery
of burrowing holes of endangered giant kangaroo rats that a proposed solar
energy project would likely require a scaling-back of the project).
7 In particular, conflicts with the Amargosa toad in Nevada, USA, have compli-
cated the siting of solar energy projects. See Reimer & Snodgrass, supra note
4 at 576-77.
8 Solar energy projects have been blamed for the deadly disruption of desert kit
fox habitats in California, USA. See, e.g ., Louis Sahagun, Canine Distemper
in Kit Foxes Spreads in Mojave Desert, Los Angeles Times (Apr. 18, 2012),
available at http://articles.latimes.com/2012/apr/18/local/la-rme-0418-foxes-
distemper-20120418 (last visited June 10, 2013) (describing a possible link
between stress from “hazing techniques” used to force the foxes from their
habitats in connection with the Genesis Solar Energy Project in southern
California may have contributed to the outbreak of a deadly disease among the
local population of this endangered mammal species).
9 Climate Wire, Offshore Wind Turbines Keep Growing in Size , Scientific
American (Sept. 19, 2011), available at www.scientiicamerican.com/article.
cfm?id=ofshore-wind-turbines-keep (last visited Oct. 11, 2013) (describing
how environmental groups were “lobbying for construction to be halted” on
a wind farm of the shore of Germany because they were “worried about the
effect of construction noises on porpoises”).
10 One recent effort to mitigate impacts of a wind energy project on bighorn
sheep populations involved the Ocotillo Wind Energy Facility in California,
USA. To review the mitigation and monitoring plan for the project, visit www.
ocotilloeccmp.com/Wild1s_PBS_MMP.pdf (last visited June 10, 2013).
11 See IPCC Technical Paper V: Climate Change and Biodiversity at 16 (§ 6.21)
(Apr. 2002), available at www.ipcc.ch/pdf/technical-papers/climate-changes-
biodiversity-en.pdf (last visited June 13, 2012) (describing evidence that
climate change may “increase species losses”).
12 For one prominent scholar's recent examination of the unique tension between
green energy development and wildlife conservation, see generally J. B. Ruhl,
Harmonizing Commercial Wind Power and the Endangered Species Act
through Administrative Reform , 65 V. and. L. Rev. 1769 (2012).
13 For a discussion of the ethical, as opposed to economic, arguments against
renewable energy development in valued habitat areas, see generally Lodor,
 
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