Solar Done Right

Let Interior know how you feel about public lands solar development

Posted In | By Chris Clarke

Why on earth are we targeting millions of acres of undeveloped public land for Big Solar? Read our report “Wrong from the Start,” which outlines the flaws in Interior’s plan, and the sane alternatives that could bring us faster, less damaging renewable energy. You can send your own comments to the government and use these talking points to guide you.

Key Talking Points

We encourage our supporters to comment on the Solar Energy Draft Programmatic Environmental Impact Statement. You can file your comments here. While it’s best to use your own words to express your knowledge, personal experience and concerns when responding to NEPA documents, below are some key points to assist you in formulating your comments:

Fundamental Flaws

• Large-scale, centralized renewable energy generation on public lands is an agency choice, not a federal mandate. The Energy Act of 2005 does not order the administration to site renewable energy facilities on public lands, and the administration is wrong to use the Act as cover.
• The DPEIS promotes an outmoded, top-down approach to energy production that is financially wasteful and environmentally irresponsible, and out of touch with current market and technology trends.
• The DPEIS promotes massive subsidies to the same irresponsible corporations that profited from oil and gas development on public lands and waters (BP, Chevron) and contributed to the financial meltdown (Morgan Stanley, Goldman Sachs).
• The DPEIS puts industry interests above the public good and fails to adequately consider more cost-effective and environmentally responsible approaches to renewable energy development.

Impacts

• The DPEIS promotes hundreds of square miles of industrialization with long-term, irreversible, cumulative ecological impacts to fragile deserts and grasslands.
• Proposed mitigation measures are inadequate to address unresolved, deferred, and poorly understood impacts from large-scale solar development.
• Impacts will affect up to 100% of each site and endure for decades or even centuries, with the little prospect for restoration.
• Assessment of visual, economic and environmental impacts is inadequate in all three proposed alternatives.
• The DPEIS fails to assess impacts from transmission line upgrades that will be required by the projects. 
• The DPEIS cannot ensure protection and enhancement of the Nation’s water, wildlife, and other natural resources under any of the PEIS alternatives.
• The DPEIS provides no scientific evidence that large-scale solar will reduce net greenhouse gas emissions once construction, transmission, and the disruption of carbon-sequestering ecosystems are taken into account.
• BLM planning documents never contemplated this scale of development and have no relevant guidelines that limit acceptable change.

Alternatives

• The DPEIS fails to consider sound alternatives including conservation, distributed generation, and solar development in the built environment.
• The DPEIS should include a Disturbed Lands alternative. Large-scale centralized solar plants should only be built on the millions of acres of abandoned mine lands, brownfields, and federal and non-federal Superfund sites identified by EPA and others as suitable for solar and other non-fossil-fuel energy projects.
• The DPEIS should include a Distributed PV alternative that directs solar development to the built environment.  When all costs are factored in—including new transmission infrastructure and transmission line losses—local, distributed solar PV is comparable in efficiency, faster to bring online, and more cost-effective than remote utility-scale solar plants.