February 28th, 2023

Mr. Jeremy Bluma,

Acting Division Chief

National Renewable Energy Coordination Office

BLM Headquarters

1849 C Street NW

Washington, DC 20006

Submitted electronically at [email protected]

Re: Notice of Intent to Prepare a Programmatic Environmental Impact Statement to Evaluate Utility-Scale Solar Energy Planning and Amend Resource Management Plans for Renewable Energy Development (87 Fed. Reg. 75284)

Dear Mr. Bluma:

Please accept these comments on behalf of the Montana Chapter of Backcountry Hunters & Anglers regarding the Bureau of Land Management’s (BLM) Notice of Intent (NOI) to Prepare a Programmatic Environmental Impact Statement to Evaluate Utility-Scale Solar Energy Planning and Amend Resource Management Plans for Renewable Energy Development (Solar PEIS). As the agency revisits the 2012 Western Solar Plan, we offer the following comments:

    1. Introduction

The Montana Chapter of Backcountry Hunters & Anglers consists of approximately 3,000 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. To each of these pillars, unique circumstances apply in the state of Montana, so on behalf of our membership we would ask the BLM to consider the below factors as it proceeds with the Solar PEIS.

    2. Wildlife and Habitat

The BLM maintains land across Montana’s diverse landscape, and all manner of wildlife species exist on these lands. Threatened species, like the sage grouse, have been brought back from the edge of extinction in large part because of habitat available on BLM lands. Iconic species like the American bison once roamed much of the land now held by BLM, and species like mule deer and pronghorn use these lands as migration corridors, and elk use BLM lands for winter range.

First, we ask that the BLM exclude lands with hiqh-value wildlife habitat. Additionally, we ask that the BLM coordinate closely with Montana FWP and the USGS to incorporate the best available migration data into the PEIS Alternatives to update the mapping for Big Game Migratory Corridors and Big Game Winter Ranges and exclude these areas from solar development as well.

Furthermore, the multiple-use mandate of our public lands is something we believe in and support. BLM lands often involve multiple stakeholder interests, for example grazing leases with stipulations that offer wildlife habitat protections. We’d ask the BLM to consider excluding existing multiple-use properties from future solar projects or work to integrate solar projects with multiple-use lands for the benefit of all stakeholders.

In the event where wildlife or habitat impacts cannot be avoided, offsetting mitigation efforts and costs must be required and applied in ways that benefit Montanans, our wildlife, and our access.

    3. 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.

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 unique Block Management Program, easements, and any other public land access agreements negotiated between private landowners and the state. In other words, we ask the BLM to avoid solar projects in areas that provide high-value recreational opportunities (including hunting and fishing) or additional public access.

    4. Conclusion

The Montana Chapter of Backcountry Hunters & Anglers asks that you give the above comments consideration, and we appreciate the opportunity to be a part of the public planning process. We look forward to reviewing the final Solar PEIS and commenting further when more details are released.

Signed,

Jake Schwaller, Eastern Montana Conservation Leader (volunteer)

The Montana Chapter of Backcountry Hunters & Anglers

[1] 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

[2] 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/