1state. Under the program alternative, the overall percentage of available lands that would be

2developed based on the RFDS projections is about 1.1%. Under the SEZ alternative, the

3 overall percentage of available lands that would be developed based on the RFDS projections 4 is about 75%.

5

6 Table 2.4-2 compares the amount of land needed to support the RFDS-based projections 7 of solar development to the amount of land that would be made available for solar development

8in each state under the BLM’s action alternatives. Because the SEZs proposed under both

9 alternatives do not make enough land available to meet the RFDS requirements in some states

10(e.g., Arizona and Colorado, and likely also California), the BLM has initiated efforts to identify

11new SEZs through ongoing state-based efforts (see Section 2.2.2.2.6). The BLM also anticipates

12that it will identify additional SEZs in other states in the near future using the protocol for

13identifying new SEZs presented in Section A.2.6 of Appendix A. There is also the opportunity to

14develop projects outside of SEZs in variance areas, in accordance with the variance process

15described in this Final PEIS (see Section 2.2.2.3.1).

16

17Solar development on both BLMand non-BLM-administered lands (estimated as

1832,000 MW) is relevant for the evaluation of DOE’s alternatives, because DOE may support

19solar projects on federal, state, tribal, or private lands, as well as on BLM-administered lands. A

20small portion of the solar development in the six-state study area would be supported by DOE.

21However, through emphasizing support of projects researching ways to decrease environmental

22impacts (e.g., to decrease water consumption or land use), DOE could influence the course

23of future solar development such that lower impact technologies would be employed.

24

25

26 2.5 OTHER ALTERNATIVES AND ISSUES CONSIDERED

27

28The BLM and DOE considered a number of additional alternatives and issues beyond

29those described in Sections 2.2 and 2.3 during the preparation of this PEIS. This process included

30a review of the public comments received during the initial scoping period held in 2008 (which

31are summarized in the scoping summary report [DOE and BLM 2008); the second scoping

32period held in 2009; the comment period on the Draft Solar PEIS held December 17, 2010,

33through May 2, 2011; and the comment period on the Supplement to the Draft Solar PEIS held

34October 2011 through January 2012. (See Chapter 14 for a discussion of the public scoping

35activities.)

36

37Many of the suggestions provided through external scoping were incorporated into the

38Solar PEIS, including, but not limited to, the analysis of mitigation requirements; the exclusion

39of sensitive areas and, conversely, the development of some sensitive areas with appropriate

40mitigation; and focusing development in areas with existing transmission lines and roads to

41minimize the need for new infrastructure. Recommendations that the agencies analyze various

42development levels and scenarios were considered in constructing the RFDS analyzed in this

43PEIS. As discussed in Section 2.4, the agencies elected to evaluate a relatively high development

44scenario corresponding to most renewable energy required to meet RPS demands coming from

45solar sources in order to establish an upper bound on potential environmental impacts. Similarly,

46recommendations that the PEIS evaluate new and evolving solar energy technologies were

1 considered in defining the scope of the PEIS analyses; however, the agencies determined it was 2 appropriate to evaluate only those technologies considered to be technically and economically 3 viable within the 20-year time frame being assessed.

4

5 The following sections discuss other suggestions that were considered. 6 7

8 2.5.1 Distributed Generation

9

10A number of comments were received during the public scoping period suggesting that

11the agencies evaluate distributed generation of solar energy resources as opposed to, or in

12addition to, the development of centralized, utility-scale solar energy facilities. Distributed

13generation refers to the installation of small-scale solar energy facilities at individual locations

14at or near the point of consumption (e.g., use of solar PV panels on a business or home to

15generate electricity for on-site consumption). Distributed generation systems typically generate

16less than 10 MW. Other terms for distributed generation include on-site generation, dispersed

17generation, distributed energy, and others.

18

19As discussed in Section 1.2, current research indicates that development of both

20distributed generation and utility-scale solar power will be needed to meet future energy needs

21in the United States, along with other energy resources and energy efficiency technologies

22(NREL 2010). For a variety of reasons (e.g., upper limits on interconnecting and integrating

23distributed generation into the electric grid, cost, technical challenges related to voltage control

24and system protection with high-penetration PV, and continued dependency of buildings on grid-

25supplied power), distributed solar energy generation alone cannot meet the goals for renewable

26energy development. Ultimately, both utility-scale and distributed generation solar power will

27need to be deployed at increased levels, and the highest penetration of solar power overall will

28require a combination of both types (NREL 2010).

29

30Alternatives incorporating distributed generation with utility-scale generation, or looking

31exclusively at distributed generation, do not respond to the agencies’ purpose and need for

32agency action in this PEIS. The applicable federal orders and mandates providing the drivers for

33specific actions being evaluated in this PEIS compel the agencies to evaluate utility-scale solar

34energy development. As discussed in Section 1.1, the Energy Policy Act of 2005 (P.L. 109-58)

35requires the Secretary of the Interior to seek to approve non-hydropower renewable energy

36projects on public lands with a generation capacity of at least 10,000 MW of electricity by 2015;

37this level of renewable energy generation cannot be achieved through distributed generation

38systems. In addition, Order 3285A1 issued by the Secretary of the Interior requires the BLM and

39other Interior agencies to undertake multiple actions to facilitate large-scale solar energy

40production (Secretary of the Interior 2010). Accordingly, the BLM’s purpose and need for

41agency action in this PEIS is focused on the siting and management of utility-scale solar energy

42development on public lands (see Section 1.3.1). Furthermore, the agency has no authority or

43influence over the installation of distributed generation systems, other than on its own facilities,

44which the agency is evaluating at individual sites through other initiatives.

45

2mission; however, it is being handled in other initiatives separate from this PEIS. DOE

3recognizes that the present electric grid, built decades ago, was based on a centralized

4generation approach and was not designed to handle high levels of distributed renewable

5 energy systems. In 2007, DOE launched the Renewable Systems Interconnection (RSI) study

6to identify the technical and analytical challenges that must be addressed to enable high

7penetration levels for distributed energy systems, with a particular emphasis on solar PV

8 systems (see http://www1.eere.energy.gov/solar/rsi.html). As a result of the RSI study, in 2008, 9 DOE initiated the Solar Energy Grid Integration Systems (SEGIS) program to further develop

10electronics and build smarter, more interactive systems and components so that solar energy can

11be integrated into the electric power distribution and transmission grid at higher levels.

12

13In addition, in 2011, the DOE launched the Rooftop Solar Challenge to accelerate

14significant improvements in market conditions for solar PV projects. This nationwide effort

15engages diverse teams of local and state governments, along with utilities, installers, non-

16governmental organizations (NGOs), and others to make solar energy more accessible and

17affordable. These collaborative teams are working to reduce administrative barriers to residential

18and small commercial PV solar installations by streamlining, standardizing, and digitizing

19administrative processes. Complex permitting and grid connection processes increase the cost of

20solar energy systems and limit the growth of the solar industry. The objective of the Challenge is

21to make the process of going solar simpler, faster, and more cost-effective for residents and

22businesses.

23

24Through these efforts, DOE is actively pursuing the expansion of distributed generation

25systems and their contribution to the country’s electricity supply. While distributed generation of

26solar energy clearly is an important component of DOE’s SunShot Initiative and Solar Energy

27Technologies Program, inclusion in this analysis of an alternative incorporating distributed

28generation does not address the DOE’s purpose and need to satisfy both E.O.s and respond to

29this congressional mandate and promote, expedite, and advance the production and transmission

30of environmentally sound energy resources, including renewable energy resources and, in

31particular, cost-competitive solar energy systems at the utility scale (see Section 1.4.1).

32

33

34 2.5.2 Conservation and Demand-Side Management

35

36Like the requests for distributed generation alternatives, recommendations that the

37BLM and DOE evaluate alternatives incorporating conservation of energy and demand-side

38management do not respond to the purpose and need for agency action in this PEIS. In general,

39conservation initiatives would be designed to reduce energy consumption levels in order to

40reduce the need for increased electricity generation capacity. Demand-side management would

41involve specific actions taken by utilities, their regulators, and other entities to induce, influence,

42or compel consumers to reduce their energy consumption, particularly during periods of peak

43demand.

44

45While these types of initiatives are important components of the country’s efforts to

46address future energy needs, they do not respond to the purpose and need for agency action in

1 this PEIS as defined by the agencies (see Sections 1.3 and 1.4). These efforts do not address the

2agencies’ purpose and need to satisfy both E.O.s and respond to this congressional mandate and

3promote, expedite, and advance the production and transmission of environmentally sound

4 energy resources, including renewable energy resources and in particular, cost-competitive solar 5 energy systems at the utility scale.

6

7

8 2.5.3 Analysis of Life-Cycle Impacts of Solar Energy Development

9

10Several comments were submitted suggesting that this PEIS should address impacts

11associated with the life cycle of solar energy development, including the manufacturing of solar

12facility components. The action agencies recognize that consideration of life-cycle impacts will

13provide valuable information supporting energy policy development in this country. However,

14the impacts associated with other solar energy life-cycle activities were not determined to be

15connected actions for the purposes of this PEIS (40 CFR 1508.25(a)(1)). As appropriate, these

16types of activities would be addressed as part of the cumulative effects analysis in project-

17specific environmental reviews.

18

19For DOE, life-cycle analysis of energy development is an important research topic. Such

20analyses are being conducted by DOE across its programs, including life-cycle analyses for solar

21energy technologies.

22

23

24 2.5.4 Analysis of Development on Other Federal, State, or Private Lands

25

26Comments were received suggesting that the scope of the PEIS include evaluation of

27development on other federal lands (e.g., lands managed by the DoD), state lands, and private

28lands. A related suggestion was to sell BLM-administered public land to the private sector and

29limit all utility-scale solar power facilities to only private land. Alternatives based on these

30suggestions do not respond to the purpose and need for agency action in this PEIS and would

31not meet the objectives established for the BLM by the Energy Policy Act of 2005 and

32Secretarial Order 3285A1, both of which require the BLM to facilitate renewable energy

33development on public lands. However, the BLM may decide to dispose of some parcels of land

34through land sales or exchanges to support the development of solar energy on a case-by-case

35basis. The BLM’s existing ROW regulations (43 CFR Part 2800), existing land sale regulations

36(43 CFR Parts 2710 and 2711), and existing exchange regulations (43 CFR Part 2200) provide

37for these possible procedural approaches. The NEPA analysis contained in the Solar PEIS will

38be used to the extent practicable to support such future decisions; however, additional NEPA

39analysis may be necessary.

40

41It is also important to point out that the analysis of solar energy development on other

42federal or private lands is encompassed in the scope of the PEIS analysis. The geographic scope

43of DOE’s analysis includes all lands in the six-state study area. As discussed in Section 1.4.1,

44DOE may support solar projects on all types of lands, including BLM-administered lands

45and other federal, state, tribal, and private lands. The description of the affected environment

46in Chapter 4 and the results of the analysis of potential impacts and mitigation measures in