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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />35 <br />E. BLM Must Explicitly Consider a Renewable Energy Alternative or Include <br />Renewable Energy as a Priority Element in Each Alternative. <br /> <br />None of the alternatives considered look specifically at renewable energy. However, a <br />transition to clean energy is critical to achieving the national climate goals discussed in Section I <br />of these comments. <br /> <br />Several statements of national policy in regulations and executive orders create an obligation <br />for BLM to look more closely at renewable energy as a resource in the Uncompahgre Field <br />Office planning area. As of 2010, these include: <br /> <br />• The Energy Policy Act of 2005 (Title II, Sec. 211), which requires the DOI to approve at <br />least 10,000 megawatts of non-hydropower renewable energy on public lands by 2015. <br />The President has requested that BLM produce an additional 10,000 megawatts beyond <br />that mandated in the Energy Policy Act of 2005. <br /> <br />• Secretarial Order 3285, which requires the DOI to identify and prioritize specific <br />locations best suited for large-scale renewable energy production. <br /> <br />• Instruction Memorandum 2007-097, Solar Energy Development Policy (BLM 2007), <br />establishes policy for the processing of right-of-way (ROW) applications for solar energy <br />development projects on BLM-administered lands and evaluating the feasibility of <br />installing solar energy systems on BLM administrative facilities and projects. <br /> <br />• Instruction Memorandum 2006-216, Wind Energy Development Policy (BLM 2006), <br />provides guidance on implementing the Record of Decision for the Programmatic <br />Environmental Impact Statement (EIS) on Wind Energy Development (BLM 2005) and <br />processing ROW applications for wind energy projects on BLM-administered lands. <br />Instruction Memorandum 2009-043, Wind Energy Development Policy (BLM 2009b), <br />provides updated guidance on processing ROW applications for wind energy projects on <br />BLM-administered lands. <br /> <br />• Instruction Memorandum 2004-227, Biomass Utilization Strategy (BLM 2004), updated <br />in July 2005, provides sets of goals to help focus and increase utilization of biomass from <br />BLM lands. In June 2005, the final rule in the Federal Register revised the authority of <br />48 Code of Federal Regulations (CFR) Part 1452 by adding 1452.237-71, which is a new <br />contract clause for removal and utilization of woody biomass generated as a result of land <br />management service contracts whenever ecologically and lawfully appropriate. The BLM <br />issued Instruction Memorandum 2009-120 in May 2009, which updated the contract <br />clause for utilization for woody biomass. <br /> <br />The BLM recognizes that “potential solar, biomass, wind, and geothermal resources <br />occur in various locations and forms within the planning area.” DEIS 3-151. While “there are no <br />permit applications or current leases for concentrated solar, wind generation, biomass, or <br />geothermal energy production within the planning area,” by omission this indicates that there are