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Robert Abbey, Director Dear Director Abbey: The Public Lands Foundation wishes to compliment you and your staff, along with the Department of Energy and Argonne National Laboratory, who developed the Draft Programmatic Environmental Impact Statement (DPEIS) on Solar Energy Development in Six Southwestern States. It is an outstanding example of how National Environmental Policy Act (NEPA) documents should be developed. We commend you for the work done to collect and analyze the information about the land, the technology and the impacts of solar energy development on BLM lands. And, we also appreciate the process that has been provided for public input during the 90-day comment period. As you know, the Public Lands Foundation is a national non-profit conservation organization formed in 1987 that advocates and works for the retention of public lands in public hands, professionally and sustainably managed for the responsible common use and enjoyment of the American people. Our members are predominantly retired former Bureau of Land Management (BLM) employees with many years of experience in natural resources management. Three alternatives are considered in the DPEIS. They are: · No Action Alternative, · Solar Energy Development Program Alternative (the Preferred Alternative), which would allow solar energy facility applications on nearly 22 million acres of BLM lands in six states (Arizona, California, Colorado, Nevada, New Mexico and Utah), and · Solar Energy Zone (SEZ) Alternative, which would allow utility scale solar energy developments on 677,400 acres of BLM lands in 24 Solar Energy Zones in the same six states. The Public Lands Foundation believes these provide an appropriate range of alternatives for consideration. And, we endorse the SEZ Alternative. There is no need to allow solar energy developments to scatter across nearly 22 million acres of BLM lands in these six western states at this early stage of the federal government’s solar energy initiative. The BLM has identified 677,400 acres in 24 Solar Energy Zones in these six states where solar energy developments can be concentrated and probably approved without significant conflicts with other environmental and public values. And, these SEZ areas should be used for the first stage of this solar energy initiative. We also believe that any leasing in the SEZs should be done competitively. The Reasonably Foreseeable Development Scenario (page ES-12 of the Executive Summary of the PEIS), estimates the amount of solar energy generation on BLM-administered lands in the study area over the 20-year study period to be about 24,000 megawatts (MW), with a corresponding dedicated use of about 214,000 acres of BLM-administered lands. This is evidence that the SEZ Alternative, which includes 677,400 acres, is more than adequate for the 20-year study period. To address the situation where additional solar energy development is required, we recommend that a process be developed to designate additional SEZ areas as the need arises in the future. If a decision is made to adopt the preferred alternative, then we believe that a modification to that alternative be considered. We believe that the approach being analyzed in Arizona BLM’s Restoration Design Energy Development Project EIS should be applied for areas outside the SEZs in all six states. This approach considers suitable disturbed lands across all ownerships and is a much better approach for considering additional new development areas. This approach is very reasonable, focuses on disturbed lands, and would provide greater certainty for potential developers by eliminating much of the conflict being experienced currently in California. We also believe that any areas identified through this process should only be made available for competitive leasing after being nominated by potential developers for consideration. These lands should not be made available through application. We recently learned that the Bureau of Reclamation (Reclamation) is considering and planning for the development of renewable energy facilities on its Project lands. We have been told that solar facilities at pump stations and hydraulic generation along canals are being examined. In a state like Arizona, we are told that 14 percent of energy consumption is used to move water for the Central Arizona Project. This is quite significant! A West-wide look by Reclamation at replacing traditional energy usage with new renewable energy sources seems to us to be something that should be considered in the Reasonably Foreseeable Development Scenario. It is not currently mentioned. The DPEIS does not address or consider renewable energy development on public lands withdrawn by the military. We know that there are many obstacles to planning and actually accomplishing this development, but those obstacles need to be overcome. There are very many disturbed areas on these withdrawn lands, some areas are clearly suited for solar and wind development and others could be leased for geothermal energy. Some of the challenges are legal requirements that could be changed; others involve the need to develop an approach that rewards the military by allowing revenue sharing from the leases to be used for Base Operations. We believe that the Defense Department, Department of Energy and the Department of the Interior must put aside their differences and work together to present Congress with a recommended solution. The Country needs these agencies to resolve this issue! The Public Lands Foundation endorses the criteria that are used to identify public land areas that should be off limits for solar energy facilities (pages ES-8 and 9). In addition to these criteria, the PLF strongly urges the BLM to consider the following three suggestions in siting and developing solar energy facilities: · siting facilities near existing transmission line corridors, and as close as possible to the urban centers which use the energy, · authorizing low water use facilities rather than those which require large quantities of water for steam generation of energy, and · only permitting the use through issuance of rights-of-way or competitive leases, not by sale of the land, and with strong requirements and bonding to ensure that the facilities are removed and the lands are again made available for new technology and the needs of future generations. PLF Position Statement 2010-20, “Impacts of Solar and Wind Energy Development and Production on the National System of Public Lands,” which was approved by our Board of Directors on December 3, 2010, is enclosed for your consideration. Thank you for the opportunity to provide input. Sincerely, /s/ Henri Bisson Henri Bisson, President Enclosure PLF Position Statement 2010-20, “Impacts of Solar and Wind Energy Development and Production on the National System of Public Lands”
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