ACTION NEEDED: Get your comments on Western Solar Plan by April 18

Rose Winn, UPLA’s Natural Resource Consultant, BLM Western Solar Plan (PEIS Comment)

Please get yours sent in before April 18!

There is a shift happening on public lands with the core driver centered in renewable energy: solar and wind power. The climate change agenda is rapidly impacting the priorities that public land managers place on “multiple-use management” of our public lands.

There has been a significant increase of solar farms on public land in recent years. The BLM Western Solar Plan created in 2012 identifies public lands eligible for fast-track solar farm development in multiple states, including: Utah, Colorado, Arizona, Montana, New Mexico, California, Washington, Oregon, and others. The BLM is currently updating the Western Solar Plan in order to expand areas of public land suitable for solar energy development to meet a net carbon electricity goal by 2035. Public comments are now being accepted on the Solar Programmatic Environmental Impact Statement. We need OHV enthusiasts to submit public comments to tell BLM to exclude your favorite OHV riding areas from the plan. With this current plan there is a variance process that potential solar projects have to go through in order to be approved. These renewable energy developments often conflict with recreation use, which should be a core variance within the approval process.

On the positive side, all of the five Alternatives proposed for the Western Solar Plan exclude Special Recreation Management Areas (SRMAs) from solar energy development; thus, these areas could be affected only indirectly by solar energy facilities located close to their boundaries. However, on the negative side, the range of indirect impact on the quality and viability of the OHV riding experience at SRMAs is vast, including:

  • Change in the overall character of undeveloped BLM-administered lands to an industrialized, developed area that would displace people who are seeking more rural or primitive surroundings for recreation.
  • Changes to the visual landscape, impacts on vegetation, development of roads, and displacement of wildlife species resulting in reduction in recreational opportunities could degrade the recreational experience near where solar energy development occurs.

Additionally, the potential for solar projects to close public access to designated OHV routes that are outside of SRMAs is a real and impending threat to the future of OHV recreation in many popular areas of BLM land throughout the West, including Utah. The proposed plan states:

“Many BLM field offices have completed planning activities to designate lands for OHV use. Under these plans, areas open to application for solar energy development may be available for OHV use, and solar energy development in these areas would displace this use. Applications for solar energy facilities may include areas containing designated open OHV routes, thereby eliminating public access along those routes.”

It is imperative for OHV enthusiasts to submit comments on the BLM Western Solar Plan to urge the BLM to exclude areas with designated OHV routes from the range of available land for construction of solar projects, and, to exclude construction of solar projects near the borders of SRMAs.

Public comments will be accepted through April 18. For more information on the BLM Western Solar Plan, and to submit a comment, go to: https://eplanning.blm.gov/eplanning-ui/project/2022371/510

Rose prepared some talking points for you to use when writing your own comments. These should be used as idea starters for you, please don’t just copy and paste them. Form letters or comments with same language are not effective.  It’s not necessary to incorporate all of these in your comments, pick the couple that are most important to you, however, we need lots of comments regarding the first talking point and request them to remove that language about solar energy plants replacing currently designated OHV routes.

If you have questions or would like to discuss how you will craft a comment for the Western Solar Plan, please reach out to UPLA Public Policy Consultant, Rose Winn: rose@utahpla.com.

Plan website: https://eplanning.blm.gov/eplanning-ui/project/2022371/570

Public comment deadline: April 18, 2024

Send your comments via email to: solar@blm.gov

  • Utah Public Land Alliance’s Natural Resources Consultant, Rose Winn, is tracking comments for this Solar Plan. Please add Rose to the “CC” field of your email: rose@utahpla.com.

(Sample comment letter  below, but please make it your own, don’t try to copy and paste.)

Key Talking Points:

  • Note that the potential for solar projects to close public access to designated OHV routes that are outside of SRMAs is a real threat to the future of OHV recreation in many popular areas of BLM land. The proposed plan states on page 5-159 of the 2023 Draft Solar PEIS Volume 1 (Section 5.14 Recreation, 5.14.1 Direct and Indirect Impacts, 5.14.1.1 Construction and Operations):
    • “Many BLM field offices have completed planning activities to designate lands for OHV use. Under these plans, areas open to application for solar energy development may be available for OHV use, and solar energy development in these areas would displace this use. Applications for solar energy facilities may include areas containing designated open OHV routes, thereby eliminating public access along those routes.”
  •  Urge the BLM to cite the following as explicit exclusions within all 5 Alternatives:
    • Exclude designated OHV routes and open OHV riding areas from the range of available land for construction of solar projects
    • Exclude construction of solar projects near the borders of Special Recreation Management Areas
    • Exclude all designated outdoor recreation areas (including dispersed camping, designated camping, mining, along with all forms of outdoor recreation) from the range of available land for construction of solar projects.
  • Thank the BLM for excluding land within Special Recreation Management Areas from solar energy development, and urge them to maintain this exclusion within the final draft regardless of which Alternative or combination of Alternatives is selected.
  • Name all BLM OHV riding areas that you have, or would like to in the future, recreate at. Wherever possible, itemize the features that make that riding area unique and of high-value to the OHV rider experience. Note how a solar facility development within or nearby that riding area would negatively impact the rider experience and/or wildlife and wildlife habitat in the region.
  • The negative impacts of solar facilities on wildlife is of importance to OHV enthusiasts given that a major element of why we enjoy OHV recreation is to get out in nature and view / observe wildlife in its native habitat. Solar facilities destroy habitat for all species that inhabit the footprint where the facility is constructed; they displace wildlife, leading to higher concentrations of species in surrounding areas as those species are forced to flee the solar facility area to survive. This will inflict harm on wildlife as there will be more competition for food and habitat for all species including mammals, birds, amphibians, reptiles, and insects.
  • Solar facilities on OHV riding areas would also displace OHV riders. This will create a higher concentration of people riding in other OHV areas, which will create new negative impact on natural and cultural resources in other areas, thus jeopardizing the long-term viability of other OHV areas, and thereby inflicting harm directly on the OHV recreation community. For this reason, the BLM should exclude designated OHV routes, open OHV riding areas, Special Recreation Management Areas, and lands near the borders of Special Recreation Management Areas from the range of available land for construction of solar projects.
  • OHV recreation accounts for a huge segment of the outdoor recreation economy. Outdoor recreation contributes over $1.1 trillion to the US economy. For this reason the BLM should exclude designated OHV routes, open OHV riding areas, Special Recreation Management Areas, lands near the borders of Special Recreation Management Areas, and all designated outdoor recreation areas from the range of available land for construction of solar projects.
    • There is some info that may be of interest to cite from this article on the value of the outdoor recreation economy
  • You may suggest that solar facility development is not suitable for construction on America’s public lands, which are intended to be used, stewarded, and protected for the benefit of all Americans. Solar facilities destroy the recreational, resource, cultural, and ecological values of our public lands. Solar facilities are best suited for urban and developed areas – such as rooftops in cities and elevated coverings over parking lots. One of the issues that the BLM has noted in the Western Solar Plan is a desire to place solar facilities near existing power transmission lines – so public lands, which are inherently distant from transmission lines – are unsuitable. Constructing solar facilities in urban, developed areas is more efficient as transmission lines are already in near proximity.
  • If you’d like to see a sample comment letter, Sample Template Comment Letter