Protest: 

Protest on the Old Spanish National Historic Trail with Public Employees for Environmental Responsibility:

Comments on the Draft Solar PEIS:

Scoping comments:

The Federal Register notice today announced BLM's plans to open ip millions of acres of wildlands and intact ecosystems and recreation lands in the Western U.S to energy development: In compliance with the National Environmental Policy Act of 1969, as amended (NEPA), and the Federal Land Policy and Management Act of 1976, as amended (FLPMA), the Bureau of Land Management (BLM) has prepared a Final Programmatic Environmental Impact Statement (EIS) and Proposed Resource Management Plan (RMP) Amendments for Utility-scale Solar Energy Development and by this notice is announcing the start of a 30-day protest period. (https://www.federalregister.gov/documents/2024/08/30/2024-19478/notice-of-availability-of-the-final-programmatic-environmental-impact-statement-for-utility-scale)

The Good: most modeled Mojave desert tortoise habitat (outside of and including critical habitat) and some modeled greater sage grouse and Gunnison’s sage grouse habitat are solar exclusion areas. Basin & Range Watch pushed for this.

The sage grouse map looks like a partial placeholder for an Area of Critical Environmental Concern (ACEC) nomination by conservation groups in 2023 (see below). Solar exclusion areas include some sage grouse Priority Habitat Management Areas, but Wyoming seems to be largely left out for exclusion. The BLM may be preserving some of these habitats for an ACEC designation when Resource Management Plans are revised in the future. Basin & Range Watch pushed for sage grouse protection.

Ranges of several other federally Threatened and Endangered species such as the Dixie Valley toad in Nevada, and a list of rare plants, are excluded from solar energy development. This is good.

Big game migration corridors are to be solar exclusion areas following Resource Management Plans, and state agency input. Not all of these are mapped. Basin & Range Watch pushed for protecting all big game migratory corridors.

Lands with Wilderness Characteristics are excluded, although BLM's map leaves out many of these areas. Visual Resource Classes I and II are excluded, but this is not surprising (areas we think are beautiful, but that BLM has classified as so ugly that they can be industrialized). Tribal Interest Areas in New Mexicio are excluded-good. 

National Scenic Trails, including any associated corridor, are excluded.

Species Conservation Agreements/Strategies are excluded--all areas where BLM has agreements with US Fish and Wildlife Service and/or state and other agency partners to manage senstive species habitat "in a manner that would preclude large-scale impacts/disturbance, such as solar energy development."

Specific areas in states are also excluded from new solar development, such as Ivanpah Valley.

The Bad: the definition of “disturbed lands” is not scientifically viable. They are labeling cheatgrass areas which are currently in this sanpshot of time in an early seral state, wildfire burn scars, and livestock grazing disturbances as solar development areas. This denies ecological succession and that these areas can gradually recover and restore if the disturbance is lessened or removed. Invasive weeds may dominate in one drought year, then fade away and native bunchgrasses dominate the next year during favorable rains. We have seen it. Tribal management of landscapes also seems to be ignored and overlooked when deciding on these "human settlement" dates and vegetation departure measures. The discussion of the defintion of "disturbed lands" is highly problematic.

The Ugly: the Proposed Plan says: Lands available are those within 15 miles of existing and planned transmission lines with a capacity of 69 kV or greater or within 15 miles of an existing designated energy corridor, unless otherwise excluded by resource-based criteria. This opens up huge new areas across remote wild public lands, where proposed transmission lines such as Greenlink West deviate from following existing highways, and cross basins and mountains. 

Will the new “solar energy zones” (developments allowed areas) be wide swaths along the proposed Greenlink West and North Transmission Projects, developing huge areas below 10% slope in wild parts of Nevada, some of which are remote and away from highways? The Esmeralda County, Nevada, Tomopah areas, Amargosa Valley, South Pahrump valley, and many basins in northern nevada are thrown under the bus for solar development, despiote being wild, intact landscapes, biodiverse ecosystems, rural economic activities.

Some solar applications are grandfathered in and some are not? We are digging into this.

We will protest this 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:

The 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:

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.