What can I do? Please urge the BLM to keep renewable energy development away from high-value lands in the Eastern Sierra by submitting a comment letter today. Please note the following: -
The deadline for submitting comments is Wednesday, March 1. - You will need to use the BLM’s e-planning site to submit comments. Because comments placed in the comment box are limited to 5,000 characters, we recommend that you create a separate document (for example in Word) that contains your comment letter, check the character count, and upload that document into your e-planning comment.
- Below is our sample comment letter with suggested talking points. Please feel free to use it, customizing it as needed.
Sample Comment Letter (Well under 5,000 characters) To Whom It May Concern, I’m writing to provide scoping comments on the BLM’s scoping effort on the 2012 Western Solar Plan.
I have the following general comments:
• California’s BLM lands outside of the DRECP include important natural resource areas, including the Bodie Hills and Mono Basin. Many of these areas include rare and intact landscapes found nowhere else. We urge the BLM to evaluate these areas carefully and avoid developing in remote areas, intact habitat areas, and areas that connect or are near already protected areas.
• Continue the current exclusion for Bi-State Sage Grouse habitat.
• Any update to the Plan should take a landscape-scale approach to planning. This includes ensuring lands for conservation and recreation are identified before new areas for renewable energy development and that any development is balanced with additional conservation.
• BLM must continue to exclude all lands within the National Landscape Conservation System and Areas of Critical Environmental Concern (ACECs) from renewable energy development.
• Many BLM Resource Management Plans (RMPs) are decades old and are in need of being revised, including within the Bishop Field Office. As BLM considers the lands that it manages for renewable energy development, it cannot rely on outdated information from existing RMPs. Instead, there must be an updated, robust environmental analysis at the local level to properly inform such development.
• BLM should examine the suitability of BLM lands for wind energy development in a separate review process.
I ask BLM to specifically exclude renewable energy development from the following:
• All Lands identified as having Wilderness Characteristics. The 2012 Western Solar Plan currently excludes Lands with Wilderness Characteristics (LWCs) from development, but only if they are protected by an existing RMP. Numerous BLM RMPs across the West are in the midst or on the verge of active RMP revision processes. In places where robust LWC inventories have been completed but final plan decisions have yet to be made regarding the management of these lands, all lands identified as LWCs should be excluded from development.
• Areas with important natural and cultural resources. For example, the exclusion criteria should include lands with habitat connectivity, important plant areas, updated critical habitat, and other resource criteria. The BLM should ensure tribes are consulted and involved early in this process to avoid impacting culturally significant resources and landscapes.
• Lands nominated as Areas of Critical Environmental Concern (ACECs). The 2012 Plan currently excludes ACECs. However, areas that have been nominated as ACECs should also be excluded from development, especially if the existing RMP has not been updated recently.
• Wildlife migration corridors, including avian species. Bighorn sheep herds and corresponding intermountain habitat and winter ranges for elk, deer, pronghorn, and bighorn sheep.
• Important sage-grouse habitat. The existing Plan does not reflect the changes made to a multi-state Sage-Grouse Plan or a planning process that is underway that is not anticipated to be completed until 2023. BLM should complete the current Sage-Grouse plans to inform the 2012 Plan planning process. In particular, as the BLM finalizes the priority habitat management areas and sagebrush focal areas, these habitats should also be excluded.
• All lands within the DRECP planning area must be excluded from any update to the 2012 Western Solar Plan. The DRECP was an 8-year collaborative planning process and is working. The inclusion of these lands would undermine this previous work and the current balance of renewable energy, conservation, and recreation in the California Desert. The DRECP should be used as a model for future BLM planning of renewable energy development.
Sincerely, |
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