ACTION ALERT: Ask BLM to protect important public lands from renewable energy development

• January 30, 2023
• Hayley Paronish

The Bureau of Land Management (BLM) is undertaking a preliminary scoping effort that may update their 2012 Plan for solar energy (2012 Western Solar Plan) on public lands in California and the other southwestern states that were part of that Plan (Arizona, Colorado, Nevada, New Mexico, and Utah).  This proposed update may also amend the 2016 Desert Renewable Energy Conservation Plan (DRECP) that covered about 10 million acres (about 10% of California) in Inyo, Kern, Los Angeles, San Bernardino, Riverside, Imperial, and San Diego Counties. In addition, it will also consider whether to expand the 2012 Plan to include public lands in the western states that were not previously included in the 2012 Plan and change what lands might be off-limits to solar, as well as create new areas for solar.

The DRECP was approved only 6 ½ years ago (which is a relatively short time when it comes to agency land use plans).  It was developed as a result of eight years of public participation and collaboration between federal, state and local government, community members and user groups. This work included hundreds of public meetings and more than 16,000 public comments, discussion and complex negotiations between diverse stakeholders and community members across seven counties.  The DRECP is designed to balance renewable energy development with conservation and recreation on more than 10.5 million acres of BLM-managed public lands in the California desert.  Since the DRECP was signed in 2016, neither the DRECP itself nor renewable energy projects using the DRECP have been challenged by a lawsuit – proof that the DRECP is working and has broad consensus and support from local communities and other desert users.  It is critical that the DRECP not be opened up for revisions as part of this process.  That would be a tremendous setback for developing renewable energy and protecting public lands in the California desert.  In fact, the BLM should use the DRECP as a model of successful landscape scale renewable energy planning if and when it updates the 2012 Plan.

In addition to lands in the DRECP planning area in the California Desert, we have reason to believe that the following areas in California are particularly at risk of new solar development:  BLM lands in the Mother Lode, Applegate, and Eagle Lake Field Offices; the Modoc Plateau; and the Carrizo Plain area, especially the Diablo Range and Western Kern County.  We have provided some general comments about these areas, but if you have any specific concerns, please be sure to include them in your comments.

Please make the following general comments about a potential update to the 2012 Western Solar Plan:

• Any update to the Plan should take a landscape-scale approach to planning, ensuring lands for conservation and recreation are identified before new areas for renewable energy development and that any development is balanced with additional conservation.
• BLM must continue to exclude lands within the National Landscape Conservation System and Areas of Critical Environmental Concern (ACECs) from renewable energy development.
• Many BLM Resource Management Plans (RMPs) are decades old and are in need of being revised. RMPs are land use plans that establish goals and objectives to guide future land and resource management actions implemented by the BLM.  As BLM considers the lands that it manages for renewable energy development, BLM cannot rely on outdated information from existing RMPs.  Instead, there must be an updated robust environmental analysis at the local level to properly inform such development.
• Request that the BLM examine the suitability of BLM lands for wind energy development in a separate review process

Please ask the BLM to exclude the following key lands from renewable energy development if it decides to proceed with updating its Plan:

• All Lands identified as having Wilderness Characteristics: The 2012 Plan currently excludes Lands with Wilderness Characteristics (LWCs) from development, but only if they are protected by an existing RMP.  Numerous BLM RMPs across the West are in the midst, or cusp, of active RMP revision processes. In places where robust LWC inventories have been completed, but final plan decisions have yet to be made regarding the management of these lands, all lands identified as LWCs should be excluded from development.
• Lands nominated as Areas of Critical Environmental Concern: The 2012 Plan currently excludes ACECs.  However, areas that have been nominated as ACECs should also be excluded from development, especially if the existing RMP has not been updated recently.
• Wildlife migration corridors.
• Important sage-grouse habitat: The existing Plan does not reflect the changes made to a multi-state Sage-Grouse Plan or a planning process that is underway that is not anticipated to be completed until 2023.  BLM should complete the current Sage-Grouse plans to inform the 2012 Plan planning process. In particular, as the BLM finalizes the priority habitat management areas and sagebrush focal areas, these habitats should also be excluded.

Please make the following DRECP-specific comments:

• Please exclude all lands in the DRECP planning area from any update to the 2012 Plan. The DRECP was an 8-year collaborative planning process and is working.  Inclusion of these lands would undermine this previous work and the current balance of renewable energy, conservation, and recreation in the California Desert.
• The DRECP should be used as a model for future BLM planning of renewable energy development.

It is imperative that the BLM hear from Californians, so that they can take our opinions and concerns into consideration when deciding if and how to amend their 2012 Plan.  California is already contributing a large amount to federal renewable energy goals.  While CalWild supports renewable energy development, it should not come at the cost of ecological, cultural, historic, scenic, or other important values.

You will need to use the BLM’s e-planning site to submit comments.  Because comments that are placed in the comment box are limited to 5,000 characters, we recommend that you create a separate document that contains your comment letter and upload that document into your e-planning comment.

It is imperative that the BLM hear from Californians so that they can take our opinions and concerns into consideration when deciding if and how to amend their 2012 Plan. *The comment deadline is Wednesday, March 1st, 2023. 

Sample comment letter:

“ To Whom It May Concern,

I’m writing to provide scoping comments on the BLM’s scoping effort on the 2012 Western Solar Plan.

I have the following general comments:
• Any update to the Plan should take a landscape-scale approach to planning. This includes, ensuring lands for conservation and recreation are identified before new areas for renewable energy development, and that any development is balanced with additional conservation.
• BLM must continue to exclude all lands within the National Landscape Conservation System and Areas of Critical Environmental Concern (ACECs) from renewable energy development.
• Many BLM Resource Management Plans (RMPs) are decades old and are in need of being revised. As BLM considers the lands that it manages for renewable energy development, BLM cannot rely on outdated information from existing RMPs. Instead, there must be an updated robust environmental analysis at the local level to properly inform such development.
• BLM should examine the suitability of BLM lands for wind energy development in a separate review process.

I ask BLM to specifically exclude renewable energy development from the following:
• All Lands identified as having Wilderness Characteristics: The 2012 Western Solar Plan current excludes Lands with Wilderness Characteristics (LWCs) from development, but only if they are protected by an existing RMP. Numerous BLM RMPs across the West are in the midst, or cusp, of active RMP revision processes. In places where robust LWC inventories have been completed, but final plan decisions have yet to be made regarding the management of these lands, all lands identified as LWCs should be excluded from development.
• Lands nominated as Areas of Critical Environmental Concern (ACECs): The 2012 Plan currently excludes ACECs. However, areas that have been nominated as ACECs should also be excluded from development, especially if the existing RMP has not been updated recently.
• Wildlife migration corridors.
• Important sage-grouse habitat: The existing Plan does not reflect the changes made to a multi- state Sage-Grouse Plan or a planning process that is underway that is not anticipated to be completed until 2023. BLM should complete the current Sage-Grouse plans to inform the 2012 Plan planning process. In particular, as the BLM finalizes the priority habitat management areas and sagebrush focal areas, these habitats should also be excluded.

Please exclude all lands within the DRECP planning area from any update to the 2012 Western Solar Plan. The DRECP was an 8-year collaborative planning process and is working. Inclusion of these lands would undermine this previous work and the current balance of renewable energy, conservation, and recreation in the California Desert. The DRECP should be used as a model for future BLM planning of renewable energy development.

We will be taking a close look at the lands within the Mother Lode, Applegate, and Eagle Lake Field Offices to ensure that there are no resource conflicts with any proposed renewable energy development. We urge BLM to exclude lands in those Field Offices as mentioned above. In addition, we ask that the Carrizo Plain area and Modoc Plateau not be made sacrifice zones for renewable energy development in California. These areas hold rare and intact landscapes found nowhere else. We urge the BLM to evaluate these areas carefully and avoid developing in remote areas, intact habitat areas, areas that connect or are near already protected areas.

Sincerely, “

You will need to use the BLM’s e-planning site to submit comments. Because comments placed in the comment box are limited to 5,000 characters, we recommend that you create a separate document that contains your comment letter and upload that document into your e-planning comment.