Western Solar Plan
April 18, 2024 - Basin & Range Watch along with a few other conservation groups submitted extensive comments on the Bureau of Land Management's Utility-Scale Solar Energy Development draft Programmatic Environmental Impact Statement (PEIS) and Resource Management Plan Amendment which will update the Western Solar Plan. We support conserving all Mojave desert tortoise known occuppied habitat, all migration corridors for big game, all rare plant areas, and much more in extensive solar exclusion areas. Read more below. See our comment here:
WWP-BRW-WEG-ACC-Solar PEIS-2024-compressed.pdfThe solar industry along with several national environmental groups also submitted comments, and these ask the Bureau of Land management (BLM) for more ways to allow solar development and less restrictions. We include these public comments here:
Clearway Comments on BLM Draft Western Solar PEIS.pdfBLM PEIS _ SEIA Comments_04.18.2024.pdf2024-04-22_Solar PEIS Principles - ENGO+Industry_FINAL.pdf
Slides from BLM public meetings on the Solar PEIS 2024.
Conservation Must Balance Energy Development
The Preferred Alternative (3) would allow at a minimum 700,000 acres of lands to be developed for utility-scale solar projects. This is a huge area of public lands. Any update to the Plan should take a landscape-scale approach to planning. This includes ensuring that lands for conservation and recreation are identified before new areas for renewable energy development, and that any
development is balanced with additional conservation, with an open and transparent public and stakeholder process. Huge areas of high-quality habitat for sensitive species, federally Threatened species, and other wildlife and rare plants has already been developed for utility-scale solar projects on public lands across the Western US, especially in California, Nevada, and Arizona deserts and grasslands. This energy build-out must now be balanced with conservation of intact landscapes, healthy native plant communities, and thriving habitats.
We Need a Better Alternative
We do not support any of the Alternatives presented in the PEIS. Even Alternative 5 has too much intact high-quality habitat for imperiled species. All Nevada Alternatives are based on existing or future transmission plans. They are "excluding" areas 10 miles away from transmission on Alternative 3 but BLM is assuming the
Greenlink Transmission Projects and Gridliance upgrades are already approved – this is predecisional. BLM should analyze a Conservation Alternative which values public land natural and cultural
resources very highly and gives incentives to solar developers to build on brownfields, degraded lands, old mine sites, superfund sites on public lands. With substantial incentives, such a conservation
alternative could significantly reduce harmful impacts to natural and cultural resources. A prioritization process should give highest priority to truly disturbed lands (and not Mojave Desert scrub, Sonoran Desert arid habitats, saltbush scrub, sagebrush scrub, or grasslands. The Need for solar energy on public lands wildlife habitats and intact ecosystems would be much reduced if Distributed Generation in the existing built environment—rooftops and parking lot canopies—was maximized. It’s time for BLM to balance rampant renewable energy development on public lands habitats with conservation of wildlands, wildlife and natural ecosystems. BLM should incentivize solar developers to avoid sensitive habitats, wildlife connectivity corridors, and all occupied habitats for Threatened and Endangered species, as well as avoid many other important areas of public lands as we detail below.
Camera trap photo of desert kit fox vixen and pup on a solar project under construction in the West Mojave Desert of California, 2023. This natal den originally had (6) pups that were monitored during pupping season. Once the pups were approximately 8 weeks old the den pups split into groups of (3) and dispersed to two separate dens on site. The wildlife biological monitor kept data on the progress of the dens. Once pupping season was over the wildlife biologist used passive relocation hazing techniques to disperse the adolescent kit fox from the work site. Some of this group of kitfoxes will likely return to the exact same burrow site later in the year or next season to re-dig and possibly raise next year’s pups. Excavation of a den site does NOT prevent repatriation of a site by kit foxes. They have loyalty to a den site no matter whether it is excavated or backfilled.
The desert kit fox (Vulpes macrotis arsipus) is a BLM Sensitive Species in certain states.
Currently on some solar projects under construction, desert kit fox clans live in solar projects under construction, and are monitored by a wildlife biological monitor. There is not a set protocol from California Department of Fish and Wildlife but there are approved methods for passive relocation and evicting kit foxes from solar project construction sites that are being tested.
Kit fox families may be allowed to den in spring inside zones of the solar fields under construction during their 1st year as pups, and allowed to disperse in the fall. Their pupping den will then be excavated forcing them to find an alternate burrow outside the fence line to make a new den. Fence lines are usually more than a square mile and patch-worked in the landscape causing dislocation even outside of all the fence lines. It becomes more and more difficult for kit foxes to navigate the landscape. Many solar projects are now 10-12 square miles in size, the size of some towns and cities.
Kit foxes tend to have multiple dens spread over an area of two square miles or more. Large solar installations are usually much larger (to 10 square miles or more) and can very well encompass entire kit fox territories, including most or all kit fox family dens. This could push kit fox territories into each other’s hunting territories, and could result in competition for food and shelter. This could also put them at risk of predation, such as from coyotes, as they search for new resources. BLM needs to analyze these impacts and not ignore solar project impacts to desert kit foxes.
Kit foxes across the Western states will need to be evicted out of their burrows and home territories to make more room for solar projects--and those photovoltaic panels could just as easily go onto rooftops and over parking lots in load centers.
