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April 11th, 2024

Mr. Jeremy Bluma, Acting Division Chief
National Renewable Energy Coordination Office
BLM Headquarters
1849 C Street NW
Washington, DC 20006

Submitted online and via email: [email protected]

Re: Utility-Scale Solar Energy Development PEIS/RMPA

The Montana Chapter of Backcountry Hunters & Anglers (BHA) consists of approximately 2,500 dues-paying members and thousands of supporters. Our mission statement is to ensure North America's outdoor heritage of hunting and fishing in a natural setting, through education and work on behalf of wild public lands, waters, and wildlife.

Montana BHA applauds the BLM for revisiting the 2012 solar plan in a proactive way. We appreciate the opportunity to participate, and that the BLM has already incorporated some of our comments from the public scoping process into the draft PEIS. This process has the potential to reduce haphazard solar development under the status quo and could result in critical exclusions to development that are not currently in place. On behalf of our membership, we would ask the BLM to further consider the following:

1. Montana BHA recommends Action Alternative 5

Montana BHA recommends that the BLM proceed with Action Alternative 5. This alternative will protect the largest amount of wildlife habitat and undisturbed lands, while still allowing over 8 million acres of BLM land to be available to solar development. The BLM has established that the Reasonably Foreseeable Development Scenario (RFDS) is 700,000 acres of land. This means that only 8% of the lands available for application would be needed to meet the RFDS projection of lands needed for development. This will give solar companies plenty of flexibility to choose prime locations for solar development that have minimal impact on outdoor recreation, wildlife, and wild places.

2. Wildlife and Habitat

Montana BHA is primarily concerned about the impact of solar facilities and transmission lines on big-game species. We are especially concerned because the draft PEIS did not include data on big-game migration corridors for Montana. This is an oversight that must be addressed. We ask that the BLM coordinate with Montana FWP and USGS to incorporate the best available data on big game migration corridors and big game winter ranges in Montana and exclude these areas from potential solar development.

Montana BHA is also concerned about the impact of solar development on ground-nesting birds, including waterfowl, sage grouse, and sharp-tailed grouse. The addition of transmission lines and other structures to grassland habitat will negatively impact ground nesting birds.[1] 

We ask that the BLM consult with Montana FWP and USFWS Habitat and Population Evaluation Team (HAPET) to exclude critical breeding and nesting habitat from potential solar development. In the event where wildlife or habitat impacts cannot be avoided, offsetting mitigation efforts and costs must be required and applied in ways that provide a net gain for wildlife habitat.

3. Undisturbed Lands and Lands with Wilderness Characteristics

Montana BHA appreciates the BLM including Wilderness Study Areas and Lands with Wilderness Characteristics in the list of exclusions for solar development. We are recommending Action Alternative 5 because of the additional restriction of solar development on undisturbed lands. The risk involved with the construction and operations of solar development by spreading noxious weeds and compromising native prairie is too high to proceed in these highly sensitive and specially designated landscapes.

4. Public Lands and Access

Outdoor Recreation accounts for 4.3% of Montana’s GDP, higher than any other state.[1] BLM lands throughout the state offer some of the best hunting opportunities for both residents and nonresidents, for species ranging from upland birds to big game. Access to these lands and the undeveloped wildlife habitat they provide is critical for hunter success and opportunity, generating important revenue for the state of Montana, and responsible for filling a lot of freezers.

Additionally, in Montana alone, there are more than 1.5 million acres of federal public land that are inaccessible due to being landlocked by private property.[2] To that end, we would ask the BLM seek to avoid future solar projects on BLM lands that abut other public lands, public rights-of-way, and waterways, but also BLM lands accessible through Montana’s various public access agreements and/or easements. In other words, we ask the BLM to avoid solar projects in areas that provide high-value recreational opportunities (including hunting and fishing) or adjacent public access.

Conclusion

The Montana Chapter of Backcountry Hunters & Anglers recommends that the BLM adopt Action Alternative 5 because it protects the largest amount of wildlife habitat and undisturbed lands. Additionally, we ask that the BLM include the best available data for big game migration corridors, winter range and critical ground nesting bird habitat in Montana and exclude these areas from solar development. Thank you for your time and consideration.

Signed,

Manning Rushton, Northeastern Montana Board Member (volunteer)
Jake Schwaller, Eastern Montana Conservation Leader (volunteer)
on behalf of the Montana Chapter of Backcountry Hunters & Anglers

[1] Montana FWP Working Grasslands Initiative. https://myfwp.mt.gov/getRepositoryFile?objectID=93921

[2] Bureau of Economic Analysis. “Outdoor Recreation Satellite Account, U.S. and States, 2020.” (2021) https://www.bea.gov/sites/default/files/2021-11/orsa1121.pdf

[3] Theodore Roosevelt Conservation Partnership and OnX Maps. “Off Limits but Within Reach: Unlocking the West’s Inaccessible Public Lands.” (2019) https://www.trcp.org/unlocking-public-lands/

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