The ultimate success of this Draft PEIS hinges on the ability of the BLM to reduce conflict – particularly with the grazing community and grazing permit holders that have been ranching on BLM lands for decades. The County calls on the BLM to incorporate Alternative 6 into its analysis and once again open the Western Solar PEIS for public comment to highlight the federal understanding of these issues and to show dedicated interest in preserving the multiple uses and sustained yields mandates required by the Federal Lands Policy Management Act. The County recognizes that this request does not align with the BLM’s predetermined timeline; however, incorporating Alternative 6 into the analysis is necessary to meet the requirements of NEPA to analyze a full range of alternatives.

Furthermore, the County calls on the BLM to significantly reduce the number of acres across Utah and the 11-state planning area available for utility-scale solar. The BLM’s utility-scale solar goal calls for 700,000 acres across the 11-state planning area over the next 20 years. Unfortunately, the BLM’s preferred alternative (Alternative 3) would put an unnecessary target on 22 million acres – 32 times the area needed to achieve the goal. The County recognizes that utility-scale solar project developers need options to determine the feasibility of projects; however, 32 times the land necessary to meet the goal is unacceptable. In fact, five times the goal would still be acceptable because it highlights that the PEIS process did not accurately analyze BLM-administered lands that would be best suited for utility-scale solar development. Analyzing and Adopting Alternative 6 to refine utility-scale solar areas that are “disturbed lands” and “low conflict lands” would significantly limit the multiplier effect and decrease contention and fears related to this PEIS. This is the only path forward to expedited utility-scale solar on public lands.

In conclusion, the County recognizes that the BLM’s 2012 Western Solar PEIS was ineffective. Furthermore, the County hopes that this version of the Western Solar PEIS will not be dead on arrival because the BLM failed to work with state and local governments during the planning processes to allow utility-scale solar on “disturbed lands” and “low conflict lands.” Displacing valid, existing rights, including but not limited to grazing rights, will not be tolerated. The County is very displeased with the BLM’s failure to work with Cooperating Agencies and to consider all reasonable alternatives. The County welcomes utility-scale solar development on public lands where and when conflicts can be avoided, minimized, or mitigated. Alternatives 1 through 5 do not provide sufficient accountability to allow for these desired outcomes. Duchesne County opposes Alternatives 1 through 5 and requests that the BLM analyze and adopt Alternative 6 as the most reasonable alternative. This alternative will still provide ample opportunity for utility-scale solar development on public lands.

The goal of 700,000 acres across the 11-state planning area is still possible if the BLM makes a significant and immediate course correction, complies with state and local resource management plans, reduces conflicts, and is more intentional about the scale and scope of the Utility-Scale Solar Energy Draft PEIS. Otherwise, this Draft PEIS will be very difficult to adopt and implement.

The parties discussed the letter. Commissioner Killian makes a motion to accept and sign the letter. Commissioner Miles seconded the motion. Commissioner Killian voted aye, Commissioner Miles voted aye, and Commissioner Hansen voted aye. The motion passed.

Discussion of Possible Subjects for the Next Meeting

Consideration of Minutes for Combined Commission Meeting held April 8, 2024

The parties reviewed the combined Commission meeting minutes on April 8, 2024. Commissioner Miles made a motion to approve the minutes for April 8, 2024, as presented. Commissioner Killian seconded the motion. Commissioner Miles voted aye, Commissioner Killian voted aye, and Commissioner Hansen voted aye. The motion passed.

Calendaring & Weekly Update on Events

Recess 9:50 a.m. to 10:02 a.m.

Commissioner Killian made a motion to recess. Commissioner Miles seconded the motion. Commissioner Killian voted aye, Commissioner Miles voted aye, and Commissioner Hansen voted aye. The motion passed.