In January 2024, the Bureau of Land Management (BLM) released a draft proposal outlining six options for allocating public land to solar development, each with different criteria. The agency estimates that over the next 20 years, 700,000 acres of BLM-managed land across the western United States will be needed for large-scale solar projects. As part of this update, the BLM revised the exclusion criteria from the 2012 plan and introduced 21 new resource-based criteria. The BLM also intends to eliminate the “variance” category, designating all lands as either available or unavailable for utility-scale solar development.
On April 18th, 2024, New Mexico Wild submitted detailed technical comments on the draft programmatic environmental impact statement (Draft PEIS) for utility-scale solar and the associated resource management plan (RMP) amendments. Our comments aim to ensure that the BLM’s proposal strikes a balance between the need for renewable energy development and the protection of New Mexico’s unique landscapes, wildlife, and cultural resources. We believe that a thoughtful, science-based approach to land management is essential for achieving a sustainable future for our state and the nation as a whole.
To learn more about our position and recommendations, view our full comments here.
Background
In 2012, the BLM adopted the current version of the Western Solar Plan, which covers 6 states in the southwest, including New Mexico. The plan addresses “utility-scale solar facilities,” which is defined to include projects with capacities of 20 megawatts (MW) or greater that generate electricity that is delivered into the electricity transmission grid.
Under the current plan, BLM land in New Mexico is divided into three categories:
- Solar Energy Zones (SEZs): Priority areas that have been identified as well-suited for utility-scale production of solar energy where solar development is incentivized. Solar projects in SEZs must include design features specified by BLM to ensure environmentally responsible development. (29,964 acres)
- Variance Areas: Areas that are potentially available for utility-scale solar development but where developers must go through a variance process to obtain approval. (4,184,520 acres)
- Exclusion Areas: Areas where utility-scale solar projects are not allowed based on a list of 32 exclusion criteria, which are intended to avoid resource conflicts and reserve public lands for other uses.
In 2023, BLM announced a proposal to update the plan to cover 11 western states, including New Mexico, and to adjust the criteria for determining which areas are open to utility-scale solar. During the scoping period, New Mexico Wild submitted written comments, asking BLM to consider the following issues:
- Smart Siting: BLM should ensure that utility-scale solar projects are sited on previously degraded or previously disturbed lands, near roads, planned and existing transmission lines, and energy load centers. This approach will avoid and minimize impacts on remote, undisturbed lands and prevent further habitat fragmentation and resource degradation.
- Lands with Wilderness Characteristics: New Mexico Wild has identified 2.9 million acres of BLM-managed lands with wilderness characteristics across the state. BLM has fallen behind on maintaining updated inventories of these lands and identifying Wilderness quality lands in current Resource Management Plans (RMPs). BLM should ensure that intact landscapes with high conservation value are not adversely impacted by solar development due to BLM’s failure to update its inventories.
- Nominated ACECs: BLM’s exclusion criteria should include lands that have been nominated as Areas of Critical Environmental Concern and are still in the process of being evaluated by BLM.
- Wildlife Habitat and Wildlife Corridors: Given that habitat loss and fragmentation are leading threats to biological diversity, BLM should exclude from utility-scale solar development biodiversity hotspots, wildlife and bird migration corridors, and ecologically intact landscapes that enhance connectivity between suitable habitat, including those that may become suitable under future climate conditions. The BLM should also exclude suitable, potentially suitable, and occupied lesser prairie chicken habitat.
- Chaco Canyon: Given that the BLM recently enacted a 10-mile mineral withdrawal buffer around Chaco Culture National Historical Park to protect resources, BLM should exclude this area from utility-scale solar for consistency with the intent of the withdrawal.
- Variance Areas: BLM should simplify the solar program by eliminating the variance process and recategorizing lands as either open or closed to utility-scale solar. This will focus BLM’s limited agency resources on processing applications in priority areas.
In January 2024, BLM released a draft proposal with six alternatives, each proposing to make different amounts of public land available to solar development applications under different criteria. BLM projects that 700,000 acres of BLM-managed land will be needed for utility-scale solar development over the next 20 years. The BLM reviewed and updated the exclusion criteria from the 2012 plan and proposed a new list of 21 resource-based exclusion criteria. The BLM also proposes to eliminate the “variance” category, meaning that all lands will be identified as either open or closed to utility-scale solar.
- No Action
- Keep using the 2012 Western Solar Plan for 6 southwestern states including NM.
- 3 categories of BLM land: (1) SEZ areas (29,964 acres in NM), (2) Variance areas (4,184,520 acres in NM), (3) Exclusion areas (9,548,306 acres in NM).
- Exclusions are based on 32 categories in the 2012 plan.
- Alternative 1
- Program expands to 11 western states
- 2 categories of BLM land: (1) open for solar development (6,301,088 acres in NM); and (2) excluded from solar development (7,192,304 acres in NM)
- 1 category for exclusion: must fall into one of the 21 resource-based exclusion categories.
- Alternative 2
- Program expands to 11 western states
- 2 categories of BLM land: (1) open for solar development (5,000,154 acres in NM); and (2) excluded from solar development (8,493,238 in NM)
- 2 categories for exclusions: (1) the 21 resource-based exclusion categories; and (2) land with a slope that exceeds 10%.
- Alternative 3 (BLM’s preferred alternative)
- Program expands to 11 western states
- 2 categories of BLM land: (1) open for solar development (2,987,559); and (2) excluded from solar development (8,525,548 acres in NM for resource-based reasons; 1,980,285 acres in NM due to being to far from transmission lines)
- 3 categories for exclusion: (1) 21 resource-based exclusion categories; (2) lands with a slope that exceeds 10%; and (3) areas more than 10 miles from existing or planned transmission lines (greater than 110kV).
- Alternative 4
- Program expands to 11 western states
- 2 categories of BLM land: (1) Open for solar development (1,765,014 acres in NM); and (2) Excluded from solar development (8,493,238 acres in NM for resource based reasons, 3,235,140 acres in NM undisturbed lands)
- 3 categories for exclusion: (1) 21 resource-based exclusion categories; (2) lands with a slope that exceeds 10%; and (3) intact lands, or less than 40% invasive weed cover.
- Alternative 5
- Program expands to 11 western states
- 2 categories of BLM land: (1) Open for solar development (1,301,315 acres in NM); and (2) Excluded from solar development (8,525,548 acres in NM for resource-based reasons plus 3,666,529 acres in NM that are either too far from power lines or don’t meet disturbed land criterion)
- 4 categories for exclusion: (1) 21 resource-based exclusion categories; (2) lands with a slope that exceeds 10%; and (3) areas more than 10 miles from existing or planned transmission lines (greater than 110kV); and (4) areas more than 10 miles from existing or planned transmission lines (greater than 110kV).
