Following the closure of the 90 day public comment period on its Supplement to the Draft Programmatic Environmental Impact Statement for Solar Energy Development (Solar PEIS), the U.S. Interior Department is working towards finalizing the countrys first public land solar energy program.
The U.S. Bureau of Land Management (BLM), which in October announced that under the proposed program new solar energy zones (SEZ) on public lands would be identified in six U.S. states in order to boost deployment of utility-scale solar projects, had been seeking input on the Solar PEIS. Since the issuance in December 2010 of a draft version, over 100,000 comments have been collected.
In a bid to ensure a "smart from the start" program is created, a group of 20 solar industry stakeholders, including, Abengoa Solar, BrightSource Energy, First Solar, SunPower and the Solar Energy Industries Association, submitted a joint letter to the Interior on January 27, outlining their recommendations on how to successfully take the program forward.
In the letter, the parties agreed that "(1) solar energy development in the right places on public lands is necessary to achieve our renewable energy goals; protect desert ecosystems, landscapes and species; and fight rapid climate change; and (2) zones are an accepted land use planning tool that can facilitate solar development, especially by clustering projects around transmission, minimizing other infrastructure needs and reducing the footprint of that development."
They added that the zones thus far identified 17 SEZs totaling around 285,000 acres in Arizona, California, Colorado, Nevada, New Mexico and Utah, have been identified are just a "starting point" and that a "more robust" system of zones should be created going forward.
In total the parties put forward eight recommendations. They broadly encompass:
- Pending applications
They ask that, among other things, BLM scrutinize pending applications to assure they meet both the financial and technical qualifications. They also call for the removal of denying pending applications because of their location in proposed exclusion areas. "We urge BLM not to change the deadline for these applications again," they wrote.
- Variance process
"We agree that the variance process is intended to be the exception, not the rule," they stated. However, they argue that the process needs "modification". For instance, they believe that a requirement regarding the Desert Tortoise needs review.
- Use of height and technology limitations in designated SEZs
They call for the removal of the height and technology limitations applied to areas described as requiring VRM Class II or III "consistent" mitigation, and that they should be deal with on a case by case basis under the NEPA process.
- Slope and insolation exclusion criteria
"Slope and insolation are technical criteria or constraints. They should be listed separately from other exclusion criteria," said the parties. They added, "We agree that there could be some flexibility to develop on lands with greater than five percent slope."
- Areas where future applications for large-scale solar development should be prohibited
They are in agreement that new applications for large-scale solar development in Ivanpah Valley (California and Nevada) and Pisgah Valley should be prohibited.
- Protocol for new SEZ identification, including West Mojave SEZ The parties stipulated that the identification of new SEZs is "critical to the enduring success of a zone-based solar energy development framework as is the prompt designation of new zones."
- SEZ mitigation plan recommendations
"We are in agreement that the solar energy program should include the elements of a mitigation program that are transparent, systematic, and based on sound science, require ongoing monitoring, and address clear conservation priorities," said the letter. The parties have, however, not reached an agreement on the specific elements.
A number of recommendations were submitted, which aim to improve coordination, integration of land use and transmission planning, and to improve the transmission analysis methodology.
Commenting, Chase Huntley, Director of Renewable Energy Policy at The Wilderness Society and one of the letter’s signees, said, "We are at a critical juncture in the future of solar development on our public lands.
"We have seen a tremendous amount of leadership from staff at the Department of the Interior to ensure we develop a strong solar program. Over the next few months we hope to see them finalizing a plan that strikes a balance between wildlands and wildlife protection while creating certainty and a level playing field for the solar industry."