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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />38 <br />The Renewable Energy Potential Report provides a map of biomass potential in the <br />planning area.115 <br /> <br />Contradicting the lack of in-depth analysis of renewable energy potential, the BLM <br />assumes that “the demand for renewable energy ROWs would increase over the life of this <br />RMP.” DEIS 4-336. The basis for this assumption and the magnitude of this increase go <br />unexplained. Yet, ultimately, BLM dismisses the potential for renewable energy development in <br />the planning area, stating that: “Although state of Colorado policies and financial incentives are <br />classified as favorable for renewable energy development, the UFO does not rank nationally <br />among the top 25 BLM field offices with potential.” DEIS 3 -151. The DEIS further states that <br />“the demand for renewable energy-related ROWs should increase nationally, although within the <br />planning area, the potential for wind, solar, and biomass energy is considered to be low relative <br />to other field offices in BLM.” DEIS 3-152. This dismissive approach ignores the high potential <br />found for solar photovoltaic resources, and future economic conditions and energy demand in the <br />planning area. The planning area’s national rank is immaterial to BLM’s requirement to <br />adequately analyze the potential for renewable energy. <br /> <br />A Comparative Summary of Alternatives is presented in Table 2-1. DEIS 2-8. It shows <br />that many resource uses were considered, including coal and fluid minerals, but, other than <br />addressing ROWs and utility corridors generally, the table plainly illustrates how the <br />Alternatives considered fail to incorporate renewable energy as a resource. The DEIS fails to <br />even list renewable energy development as an Alternatives Considered but Eliminated from <br />Detailed Analysis. DEIS 2-15. On the other hand, the DEIS provides an extensive look at coal, <br />DEIS 4 -11, and fluid minerals leasing, DEIS 4 -12. The Uncompahgre Field Office also <br />conducted an extensive Reasonable Foreseeable Development Scenario report for oil and gas <br />development in 2012.116 <br /> <br />Importantly, the BLM also fails to consider the impacts of coal and oil and gas <br />development on renewable energy resources and the potential incompatibility of these resource <br />uses. The DEIS identifies the impacts of protections for ecological, scenic and recreational <br />resources on wind and solar development, including exclusion and avoidance areas. DEIS 2-376. <br />But the DEIS does not examine in depth the impact of oil and gas development on high <br />renewable energy potential areas, simply stating generally that: <br /> <br />Implementing management for the following resources would have negligible or no <br />impact on renewable energy and are therefore not discussed in detail: air quality, <br />climate, soils and water, vegetation, fish and wildlife, special status species, wild horses, <br />wildland fire ecology and management, cultural resources, paleontological resources, <br />lands with wilderness characteristics, forestry and woodland products, livestock grazing, <br /> <br />115 Id. at 5-5 (Fig. 5-1). 116 Uncompahgre Field Office, Reasonable Foreseeable Development Scenario for Oil and Gas <br />for the Uncompahgre Field Office, Colorado, 2012, available at <br />http://www.blm.gov/style/medialib/blm/co/information/nepa/uncompahgre_field/13- <br />22_bull_mountain.Par.0265.File.dat/UncompahgreRFD_Feb_2012.pdf (attached as Exhibit 40) <br />(“UFO RFD”).