1available within the SEZs would slightly exceed the amount of land required to support the

2RFDS projected development of 24,000 MW (which corresponds to about 214,000 acres

3 [866 km2]). However, as shown in Table 2.4-2 of this Final Solar PEIS, in two states (Arizona 4 and Colorado), the amount of land that would be available for ROW application would not be

5enough to support the total state-specific development projected in the RFDS. Specifically, in

6Arizona, the projected RFDS development would require 21,816 acres (88.3 km2), which

7 exceeds the 5,966 acres (24 km2) that would be available under the SEZ alternative. In Colorado, 8 19,746 acres (80 km2) would be developed under the RFDS, which exceeds the 16,308 acres

9(66 km2) that would be available under the SEZ alternative. In addition, in California, a

10projected 138,789 acres (562 km2) would be developed under the RFDS, which constitutes 90%

11of the 153,627 acres (622 km2) that would be available.

12

13Potential resource conflicts and constraints on development within some SEZ areas are

14known to exist; these constraints are discussed in each of the SEZ-specific analyses presented in

15Chapters 8 through 13 of the Draft Solar PEIS and updated in the Final Solar PEIS. The SEZ-

16specific analyses discuss areas within many of the SEZs that either should not be developed or

17should have development restrictions (e.g., areas with ephemeral stream channels or floodplains,

18areas with military flight restrictions for facilities with tall structures, areas with potential visual

19resource conflicts, and areas close to residences for noisy technologies). It is also recognized that

20some SEZ areas will likely require additional exclusions or restrictions, the extent of which may

21not be known until siteand project-specific environmental analyses can be completed. Given

22these factors, it is possible that, even in states other than Arizona and Colorado, the amount of

23land that would be available under the SEZ alternative might not be enough to support full

24development.

25

26Because this alternative may not make an adequate amount of land available to support

27the RFDS projections, at least in some states, it is possible that the total amount of utility-scale

28solar energy developed on BLM-administered lands over the 20-year study period could be

29constrained unless the BLM identifies additional SEZs (as described in Section 2.2.2.2.6 of this

30Final Solar PEIS).

31

32

33 6.3 IMPACTS OF THE NO ACTION ALTERNATIVE

34

35Under the no action alternative, solar energy development would continue on BLM-

36administered lands in accordance with the terms and conditions of the existing Solar Energy

37Policies (See Section A.1 of Appendix A). The BLM would not implement a comprehensive

38program to provide guidance to BLM field staff, developers, and other stakeholders in the six-

39state study area. Specifically, the required ROW authorization policies and design features, and

40land use plan amendments proposed in this PEIS would not be implemented. Future solar energy

41projects and land use plan amendments would continue to be evaluated solely on an individual,

42case-by-case basis.

43

44The following subsections discuss the effectiveness of the no action alternative in

45meeting the BLM’s established program objectives.

46

1 6.3.1 Facilitate Near-Term Solar Energy Development (Pace of Development)

2

3 The pace of solar energy development on BLM-administered lands would not be 4 enhanced by the no action alternative:

5

6• Developers and stakeholders would have less direction from the BLM as to

21The extended development time lines likely to result under the no action alternative could

22jeopardize developers’ business agreements, potentially putting any given project at risk of

23abandonment. In addition, extended time lines could increase the costs for all concerned parties,

24including the government, developers, and stakeholders. Furthermore, developers could elect to

25avoid delay and uncertainty by shifting their projects to state, tribal, and private land with

26potentially less federal environmental oversight (Section 6.3.2). If this shift were to occur,

27resulting in less development of solar energy on BLM-administered lands, this outcome would

28be in conflict with the mandates of the Energy Policy Act of 2005 and Secretarial Order 3285A1

29(Secretary of the Interior 2010).

30

31

32 6.3.2 Minimize Environmental Impacts

33

34In general, direct and indirect environmental impacts associated with individual utility-

35scale solar energy projects under the no action alternative could be similar to those under the

36proposed action alternatives (see Sections 6.1.2 and 6.2.2), because the BLM is required to

37identify and address environmental impacts of all ROW authorizations and conform to existing

38land use plan decisions. However, the no action alternative would do little to avoid impacts on

39sensitive resources, resource uses, and special designations by way of programmatic exclusions.

40Instead, BLM field staff would be required to review applications to ensure that these areas are

41properly addressed. In addition, without programmatic guidance on design features, the potential

42for field staff to require varying mitigation measures from project to project would be high. Lack

43of consistency could translate into inadequate mitigation of impacts for some projects and overly

44onerous mitigation requirements for other projects. Furthermore, the comprehensive monitoring

45and adaptive management strategies regarding solar energy development as suggested under the

46action alternatives would not necessarily be part of the no action alternative. Table 6.12

1 summarizes the environmental impacts that might be associated with solar energy development 2 under this alternative.

3

4 If the absence of a comprehensive program were to result in delays in processing ROW 5 applications on BLM-administered lands or in increases in the cost of developing solar power on 6 BLM-administered lands, developers could respond by focusing their development efforts on

7 state-owned, tribal, and private lands. While solar energy development on nonfederal lands is 8 subject to a wide array of environmental reviews and approvals by virtue of state and local

9 permitting processes, it may not be subject to NEPA requirements if federal funding or 10 permitting is not required for the project.

11

12By maintaining access to the 98 million acres (400,000 km2) of land currently available

13for ROW application, the BLM would provide ample opportunities to site solar energy projects

14on lands that are, or are near, degraded, disturbed, or previously disturbed sites.

15

16

17 6.3.3 Minimize Social and Economic Impacts

18

19If the pace of utility-scale solar energy development under the no action alternative were

20slower than under the action alternatives, there could be a delay in the economic benefits from

21the development in the six-state study area, in terms of direct and indirect jobs created and

22income in the communities.

23

24Under current policy, all solar projects on BLM-administered lands require ROW rental

25payments to the federal government, which include an acreage component and capacity fee

26component. Under the no action alternative, however, the BLM would not conduct competitive

27leasing in SEZs as proposed under the action alternatives. As a result, potential revenues to the

28government related to utility-scale solar energy development on BLM-administered lands may

29be lower under this alternative.

30

31In addition, it is anticipated that the no action alternative would cause BLM staff to spend

32additional time and resources on the reviews and approvals of utility-scale ROW applications,

33and this will incur greater costs to the agency and the applicants. Developers might propose

34projects in inappropriate locations, opportunities to tier analyses from this programmatic

35evaluation would not exist, and ROW authorizations would require individual land use plan

36amendments.

37

38

39 6.3.4 Provide Flexibility to Solar Industry

40

41The relatively large amount of land available for utility-scale ROW applications under

42the no action alternative, particularly when compared to the amount of land that would be needed

43to support the projected RFDS, provides a great degree of flexibility in identifying appropriate

44locations for utility-scale development (i.e., economically attractive locations with minimal

45environmental or cultural resource conflicts). However, under the no action alternative,

1 programmatic guidance would not be provided to developers with respect to lands and projects 2 that ultimately may not be approvable by the BLM.

3

4

5 6.3.5 Optimize Existing Transmission Infrastructure and Corridors

6

7 The relatively large amount of land available for utility-scale ROW applications under 8 the no action alternative provides a great degree of flexibility in identifying locations for utility-

9scale development that optimize existing transmission infrastructure and designated transmission

10corridors. However, under the no action alternative, little guidance would be provided to

11developers with respect to lands and projects that ultimately may not be approvable by the BLM.

14 6.3.6 Standardize and Streamline the Authorization Process

15

16Under the no action alternative, the BLM would not implement a comprehensive program

17to standardize and streamline the agency’s review and approval of utility-scale solar energy

18ROW authorizations, including policies, exclusions, design features, and associated land use plan

19amendments. The BLM would continue to address issues as they arise through individual policy

20statements and guidance.

21

22

23 6.3.7 Meet Projected Demand for Solar Energy Development

24

25Under the no action alternative, lands currently off-limits to utility-scale solar energy

26development (i.e., the NLCS lands, as identified in Table 2.2-2 of this Final Solar PEIS) would

27remain unavailable for ROW application. Applications for utility-scale solar development would

28be accepted in all other areas and reviewed in the context of existing land use plan decisions.

29Under the no action alternative, approximately 98 million acres (400,000 km2) of BLM-

30administered lands could be considered for ROW application. This amount of land is several

31orders of magnitude greater than the amount of land likely to be developed during the 20-year

32study period on the basis of the RFDS projections (214,000 acres [866 km2]), although ROW

33applications likely would not be approved on a large percentage of these lands because of

34conflicts with known resources, resource uses, and existing special designations.

35

36

376.4 COMPARISON OF ALTERNATIVES AND SELECTION OF PREFERRED

38ALTERNATIVE

39

40Table 6.4-1 provides a summary-level comparison of the alternatives with respect to the

41objectives established for the action and the extent to which each alternative would assist the

42BLM in meeting the projected demands for solar energy development (as presented in

43Sections 6.1 through 6.3).

44