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Solar Public Comment

A PLACE TO START IS TO PARTICIPATE IN PUBLIC COMMENT

Use any of the talking points here to create your personal public comment.

 

Written comments are due through next Thursday, April 18, 2024.

 

              Part of the “let’s just see what’s possible”, scenario playing itself out right now, is the federal government’s role in deciding where investing in renewable energy will take place.

 The Bureau of Land Management (BLM) administers more surface land (245 million acres or one-tenth of America’s land base) and more subsurface mineral estate (700 million acres) than any other government agency in the United States. Multiple uses under BLM jurisdiction include renewable energy development (solar, wind, other); conventional energy development (oil and gas, coal); livestock grazing; hardrock mining (gold, silver, other), timber harvesting; and outdoor recreation (such as camping, hunting, rafting, and off-highway vehicle driving). Currently, The BLM has released a Draft Utility-Scale Solar Energy Development Programmatic Environmental Impact Statement (Draft Solar Programmatic EIS) which is now available for public comment. Written comments are due through Thursday, April 18, 2024.

 

 

Background

 

              This current BLM Draft Solar Programmatic EIS evaluates five action alternatives, each opening different amounts of public land to solar development applications under different criteria, such as proximity to transmission infrastructure. These alternatives exclude certain public lands — such as protected lands, designated critical habitat, and areas where important cultural resources exist — from solar energy development and identify areas available to solar development proposals. The reason for this type of large-scale planning, is BLM anticipates it will expedite implementation of national clean energy goals. Your public input will inform a Final Solar Programmatic EIS and Record of Decision (ROD). As you may recall, this current BLM Programmatic EIS updates the 2012 Western Solar Plan, which identified four areas within the San Luis Valley for Solar Energy Zones (SEZ’s). Only two of these areas now remain, Detilla Gulch (near Villa Grove), which has already been leased to an energy company, signed in 2023; and Antonito Southeast (southeast of Antonito). SLVEC participated in the previous 2012 Western Energy Plan, and will provide comment on this current draft plan.  We invite you to please participate in this public comment process as well.

 

Post office US mail:

 

Date

 

Jeremy Bluma 

Bureau of Land Management

Attn: Draft Solar EIS

1849 C Street NW

Washington, DC 20240

 

Or Submitted electronically via e-planning: https://eplanning.blm.gov/eplanning-ui/project/2022371/510

 

Re: Comments on the Draft Programmatic Environmental Impact Statement for Utility-Scale Solar Energy Development (DOI-BLM-HQ-3000-2023-0001-RMP-EIS)

 

Dear Mr. Bluma:

 

 

  • Thank you for giving the public an opportunity to respond to, and offer input into the BLM and Department of Energy (DOE) Programmatic Environmental Impact Statement (PEIS) process for agency wide solar energy programs and policy.

  • A national and a regional conversation on energy use and, especially, on fossil fuels and their impacts to climate change, is encouraged. It is imperative that our country makes the transition to the use of renewable energy sources.  The warming effects are being felt in the San Luis Valley, as well as in other parts of the world, and are impacting wildlife, water supplies, and forest health.

 

  • We urge the BLM to adopt Alternative 5, provided in the draft solar PEIS.  Alternative 5 best achieves the goal of balancing conservation with opportunities for renewable energy development. Siting solar projects on previously degraded landscapes close to transmission lines will ensure that we use lands efficiently and preserve more important cultural, ecological, and historical resources.

 

  •  Within the San Luis Valley (SLV), 39,100 acres will be analyzed as part of the preferred alternative 3. Alternative 5 appears to understand that we currently do not have the transmission capacity available for large scale solar energy development. We prefer support for building large scale solar projects on private land, which is likely to have already been degraded; and also provide opportunity for private landowners to lease or sell their property to energy companies. In the SLV, this is critical, because of aquifer depletion, and rules by the State of Colorado promulgating that aquifer levels come into compliance by 2030. Solar development on private land thus provides opportunity for Agricultural producers to be able to transition to renewable energy production, and create a financial incentive that would offset ground water pumping.

 

  • Thank you for excluding solar development from lands further than 10 miles from existing and/or planned transmission lines in the agency’s preferred alternative and Alternative 5. Siting solar on previously disturbed and degraded landscapes will also help reduce conflicts between resources and solar projects. Such lands also tend to be closer to existing infrastructure necessary for solar projects, such as roads.

 

  • The San Luis Valley already has a contract leased with a company on BLM lands located in the northern Solar Energy Zone (DeTilla Gulch SEZ), selected through the 2012 Western Solar Energy Plan, and there is currently no large scale transmission capacity to enable its development.

 

  • SLVEC supports development of large scale solar on private lands, which likely already contain disturbed lands. We support private landowners leasing or selling to companies near the 31 existing sub-stations that are located throughout the San Luis Valley. Please see The Nature Conservancy map.

 

  • We recognize the unique and valuable aspects of the San Luis Valley.  We understand that the Valley has enormous potential in the area of solar production, and has a long history of supporting solar energy on a smaller scale.  We encourage the development of renewable energy strategies that will promote the long-term health and well-being of the community, traditional uses, and protect the environment, critical habitat, wildlife, sensitive corridors, and water, as well as the history and culture of this agro-pastoral community.

 

  • We urge the DOE and BLM to take a long term view when considering the scale, siting, water demands and the building of new transmission lines that will be required to accommodate Utility Scale Solar development in a culturally and ecologically sensitive area like the San Luis Valley (SLV). It is imperative that solar development remain responsible and that renewable energy development does not compromise this area’s unique values.

 

  • We recommend a national model of appropriate energy development based on what is currently being implemented in European countries. They appear to exercise a three-fold strategy; emphasis on flexibility in size and scale fitted to location and need, constructing open ended systems that can rapidly integrate new technologies, and suitably subsidizing research and development that encompasses a range of alternative energy sources.

 

  • The Antonito Southeast Solar Energy Zone (SEZ), still remains in place from the previous 2012 Western Solar Plan.  We recommend its removal. The Antonito SE SEZ is located near the designated Cumbres/Toltec Cultural Area of Critical and Environmental Concern (ACEC). The visual resource there, which supports a narrow gauge railroad, deserves protection from large scale development, which would completely change the visual timelessness character that currently exists there.

 

Three of the other 2012 Western Solar Plan considerations:

a.    Four-mile East SEZ-NW corner of Hwy 150 and 160 intersection, (Gateway to Great Sand Dunes National Park), has been removed from consideration.

b.    Los Mogotes East SEZ- directly west of Town of Romeo & Hwy 285, has also been removed from consideration.

c.    DeTilla Gulch- near where Hwy 285 and Hwy 17 converge.  A contract has already been signed for this SEZ in late 2023.

 

 

Public comments are due Thursday, April 18 at https://eplanning.blm.gov/eplanning-ui/project/2022371/510

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