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Focusing on Quality: Measuring Practices Rather Than Approval Times

By Laura Hersch

A promising development to continue the drive towards a clean energy economy may be a federal one: renewable energy deployed on public lands. The Department of the Interior (DOI) in cooperation with agencies such as the Department of Energy (DOE), the Bureau of Indian Affairs, and the Bureau of Land Management (BLM), utilizes leasing strategies to deploy renewable energy projects on federal lands. Of the estimated 640 million acres of federal land, the BLM manages 248.3 million acres with the BLM and Congress’ joint jurisdiction constituting over 10 percent of total land use in the United States. According to the DOE, the development of solar photovoltaic energy on just 0.6 percent of the nation’s land mass could supply power to every home in the nation.

In Section 211 of the Energy Policy Act of 2005, Congress instructed the Secretary of the DOI to install 10,000 MW of renewable energy capacity on public lands by 2015. Following the mandate, the BLM instituted a “fast track” process in which existing applications became the priority for the agency allowing for 3,600 MW of solar-generated electricity to be approved by the end of 2010. “Smart from the start” policies improved early consultation and transparency within the environmental analysis stage, clarifying the National Environmental Policy Act (NEPA) documentation requirements and expectations. The goal of 10,000 MW of capacity was met in 2012.

As part of the Obama administration’s Climate Action Plan, the DOI was further charged with installing 20,000 MW of major renewable generation projects on public lands by 2020. Recently, the Trump administration has sought to increase the efficiency of the infrastructure project approval process required under NEPA. “Streamlining” has been cited by the current administration as a way to fix a “badly broken” system. Accordingly, improving bureaucratic efficiency could offer a significant boost to utility-scale renewable energy development at a time when the residential market has contracted. An additional initiative to enhance accountability through the One Federal Decision procedure came with the release of Executive Order 13807 in August 2017. This act signaled the modification of processes to develop “energy production and generation including… fossil, renewable, nuclear and hydro sources” with an average Environmental Impact Statement (EIS) approval rate of two years.

By my findings, in the past seven years, solar project EIS approvals required an average of 23 months for processing. Therefore, within the category of “major infrastructure projects,” solar project EIS approvals already coincide with the administration’s proposed two-year approval rate. This achievement has been due not only to the “Fast Track” and “Smart from the Start” initiatives, but also the creation of Solar Energy Zones by the BLM’s Western Solar Plan, designating thousands of acres of public lands with high solar radiation potential for energy development. This forward thinking planning for renewable energy generation deployment has exhibited the strengths of dynamic federalism through a self-initiated streamlined process of Environmental Assessments.

Additionally, in 2016, the DOI approved the Desert Renewable Energy and Conservation Plan (DRECP). The DRECP lays out a multi-use, multi-project plan located in the desert of Southern California with 388,000 acres of Development Focus Areas designed for 27 GW of renewable capacity development. The Renewable Energy Action Team (REAT) formed by BLM, the U.S. Fish and Wildlife Service, the California Energy Commission and the California Department of Fish and Wildlife, to oversee the plan’s creation, has demonstrated how transparent coordination can achieve federal mandates and state electricity goals.

The harmonized efforts of the Western Solar Plan and DRECP have produced streamlined processes through thorough investigations conducted during plan processing. By my analysis of 24 major solar energy project approvals, the orchestration of multi-project energy plans can produce an improved metric for power over time by a factor of 60. While interviewing Ray Brady, the past manager of the BLM's National Renewable Energy Coordination Office, he said, “I don’t think BLM should be placed in a position for a mandated time frame for processing actions.”

Laura Hersch is a Data Analyst at the Energy Information Administration and completing her MS in Energy Policy and Climate at Johns Hopkins University in May.


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