BREAKING: task force recommendations shape newly released Rock Springs plan
August 22, 2024 – Today, the Bureau of Land Management released its proposed Rock Springs Resource Management Plan, outlining management direction for almost 3.6 million acres of public lands in southwest Wyoming. The proposed plan clearly reflects and incorporates feedback from tens of thousands of public comments and input from local stakeholders, including the task force Gov. Mark Gordon convened in late 2023.
The Wyoming Outdoor Council and Wyoming Wilderness Association both served on the governor’s task force alongside representatives with interests in oil and gas, grazing, energy production, motorized recreation, sportsmen groups, and trona industry. The task force also included elected officials from communities in Sweetwater County as well as the Speaker of the House and President of the Senate for the Wyoming Legislature. This group developed more than 100 consensus-based recommendations, supported by all stakeholders, to improve the plan and delivered these recommendations to the BLM during the agency’s public comment period.
The BLM took the task force’s consensus-based comments seriously. The proposed Rock Springs Resource Management Plan reflects task force recommendations including maintaining access for the local trona mining industry, retaining the OHV play area in parts of the Killpecker Sand Dunes, and protecting the unique natural and cultural values of Boar’s Tusk.
In response to the plan’s release, WOC and WWA issued the following statements:
“We’re pleased to see the BLM incorporated public feedback and input from Gov. Gordon’s task force into a plan that serves local communities, iconic landscapes, and wildlife,” said Alec Underwood, program director for the Wyoming Outdoor Council. “Among other important agreements, the task force reached consensus on the need to protect gold-standard habitat and other significant natural values in the Big Sandy Foothills and Northern Red Desert, such as Boar’s Tusk. It’s encouraging to see the BLM’s responsiveness, as well as the agency’s efforts to build on the task force’s strong foundation where agreement wasn’t reached, as they did for the Big Sandy Foothills. While the plan could be improved — protections for the iconic big game migration corridors in the region, for example, fall short of the mark — we appreciate that the agency worked diligently to ensure that updated management direction will conserve some of our country’s best remaining wildlife habitat, while also maintaining all of the unique recreational opportunities found within the field office.”
“It is a testament to the dedication of all who love and care for the lands within the Rock Springs Field Office that the proposed plan includes some robust, durable, and reasonable conservation measures for the Northern Red Desert and Big Sandy Foothills. We applaud the BLM for making the hard decisions necessary to ensure these wild and working landscapes continue to thrive for future generations to use and enjoy,” said Lauren Marsh, BLM program manager for Wyoming Wilderness Association. “We are, however, disappointed that some key provisions in the draft RMP were not carried forward in the proposed plan, namely recognizing Lands with Wilderness Characteristics (LWCs) and important protections for the hoodoo-studded wildlands surrounding Adobe Town. Nevertheless, we appreciate the willingness of the BLM to take to heart the concerns of local Wyoming residents as expressed through public comment and recommendations from Governor Gordon’s task force. What you see reflected in the plan for the northern portion of the Field Office — and taskforce recommendations — is how much Wyomingites value wildlife and the wildlands that support them, even under the demands of a largely extraction-based economy.”
The issuance of the Proposed Resource Management Plan and Final Environmental Impact Statement initiates a 30-day public protest period and 60-day governor’s consistency review. The agency will finalize the plan after resolving issues raised in these processes.
DIRECTORS’ MESSAGES ON RECENT PARCEL 194 PRESS, PART 2: ON THE Ground
Recent press concerning the Wyoming Outdoor Council’s efforts to protect critical pronghorn migratory habitat has caused a bit of a stir in certain circles — and we’d like to set the record straight with an important message for the WOC community and other Wyomingites.
In this second part of a two-part message, WOC’s program director, Alec Underwood, responds to biased reporting and industry perspectives on WOC’s involvement in the July 2023 oil and gas lease sale, and lays out the need for reforms. If you haven’t already, be sure to read Part 1: On the Media, in which executive director Carl Fisher lays out this recent experience with the media in greater detail.
Setting the Record Straight on State Oil and Gas Leasing
There’s that common saying, that wildlife don’t know political or human-made boundaries. The complicated matrix of Wyoming land ownership can vex people, too — making it all the more important that we work together to build common-sense plans and policies to protect our uniquely Wyoming values.
Wyoming is not immune to major challenges for wildlife and occasionally, we see the threat of short-sighted development that warrants bold action to prevent it. Recent articles penned by Cowboy State Daily reporter Pat Maio paint a misleading picture of WOC’s involvement in state oil and gas lease sales, while taking as fact the lone perspective of industry. In an effort to provide transparency and factual information to the public, we at the Wyoming Outdoor Council would like to set the record straight.
Though we are not against oil and gas leasing or other forms of industrial development, most people can agree that some places are just too special to develop. That was the case with ‘parcel 194’ in the Office of State Lands and Investments’ July 2023 oil and gas lease sale. The 640-acre tract of land is located squarely in a bottleneck portion of the Sublette Pronghorn migration corridor, a pinch-point that is vital to the herd’s seasonal movements.
Many Wyomingites know the story of how nearly 50 percent of the Sublette herd perished during the winter of 2023 — dropping from an estimated 43,000 animals to 24,000. That’s why we were alarmed when the state offered a development lease directly in this incredibly sensitive habitat for pronghorn. After raising our concerns with state leadership, the auction went forward with parcel 194 included, and without any stipulations in place to protect migratory big game. Left with no other options and the threat of future development in this sensitive habitat, we decided to participate in the oil and gas lease auction.
Parcels offered in OSLI’s July 2023 oil and gas lease sale, overlaid with migratory data for the Sublette Pronghorn herd. Each yellow line represents a single radio-collared animal’s journey between summer and winter range. Parcels offered are bordered in blue; parcel 194 is visible at the bottom of the image. (Image: The Wilderness Society)
We did not take this action lightly nor is it a standard practice for WOC. In our eyes, our bid was an effort to demonstrate that we could still produce revenue for our state while also preserving important wildlife habitat. It was not an effort to “drive up prices” or start a “bidding war,” as falsely mischaracterized in Cowboy State Daily’s articles. Regardless, we were not the high bidder for the parcel, and we turned our efforts toward the State Board of Land Commissioners, urging them not to issue the lease.
Despite having the support of both OSLI and the Wyoming Game and Fish Department for a new protective stipulation for the parcel, and hearing from hundreds of Wyomingites who wrote in opposition to leasing the ground in the first place, the Board issued the lease as-is — without any considerations for migratory pronghorn.
The story of parcel 194 represents a larger issue within the system of state trust lands: There is no clear alternative to protect key habitat or other values from development, while also respecting the mandate to provide revenue for state trust beneficiaries. Given there is great interest from the public in how state lands are used (think Casper Mountain or Munger Mountain), we hope our state leaders are listening and will commit to solving this very real problem.
The recent changes to defining “qualified bidders” in state oil and gas lease sales brings into question how the Board of Land Commissioners makes decisions on state lands leases. Take for example that according to testimony from OSLI in a February 2024 legislative committee hearing, only 27 percent of state land oil and gas leases ever make it to production. Does that sound like a system that is fulfilling the Board’s constitutional charge of optimizing revenue?
Also important to note, the Board has full discretion in their duty to protect and care for all state lands This includes the ability to withdraw lands to protect economic or environmental interests. In addition to what conservation groups may be willing to pay for protecting a parcel, what is the long-term value of protecting the most sensitive habitat for thousands of migrating pronghorn?
The Wyoming Outdoor Council has always been committed to finding common-sense solutions to any issue that we work on. That’s why we’ve been calling for increased screening for conservation conflicts before sensitive habitat is leased, as well as urging state leaders and OSLI to develop a formal conservation leasing program. We believe the state can, and should, do better to address these known conflicts with other values.
Oil and gas production on state lands is undoubtedly a primary driver of revenue for our schools and other public institutions, and we respect that. But that shouldn’t preclude us from discovering new avenues to conserve important habitat on state lands and monetize them for the beneficiaries in a sustainable manner.
Using a word recently penned to describe our advocacy, the real “shenanigans” being played are by those who, on occasion, would rather sell out our wildlife for short-term gains. Rest assured, we’ll keep seeking solutions and advocating for conservation of the things that make Wyoming such a special place. We invite anyone who cares about healthy landscapes, clean air, clean water, and wildlife to join us in those efforts.
Alec Underwood is the program director for the Wyoming Outdoor Council. He resides in Lander.
DIRECTORS’ MESSAGES ON RECENT PARCEL 194 PRESS, PART 1: ON THE MEDIA
Recent press concerning the Wyoming Outdoor Council’s efforts to protect critical pronghorn migratory habitat has caused a bit of a stir in certain circles — and we’d like to set the record straight with an important message for the WOC community and other Wyomingites.
In this first part of a two-part message, WOC’s executive director, Carl Fisher, lays out a recent experience we had with the media. Be sure to also read Part 2: On the Ground, in which program director Alec Underwood responds substantively on issues concerning parcel 194 and needed reforms for leasing of state lands.
You really can’t believe everything you read
For one Wyoming media outlet, the state’s Fourth of July celebrations must have fallen short, because it decided to set off some fireworks of its own. Unfortunately, their bombastic display was itself pretty short on substance — being composed instead of the sorts of fictions that only exist in the imagination. As such, the Wyoming Outdoor Council was the undeserving recipient of what you might describe as an industry hit job. The result? WOC will no longer respond to media inquiries from Cowboy State Daily, until trust can be restored and these issues resolved.
The issue erupted around a well-known news story from last year, about WOC going to great lengths to protect a state parcel within the Sublette Pronghorn migration corridor — including bidding on parcel 194. Subsequently, in this past Legislative Budget Session, an industry-initiated bill, HB141, directed modification of administrative rules defining what constitutes a “qualified bidder” in state oil and gas lease sales, and directed the Office of State Land and Investments to develop criteria for qualified bidders. The bill was passed and signed by the governor on March 8, 2024. From what we can tell, Governor Gordon recently put through an emergency order in an effort to enact the legislated policy (which had yet to take effect), due to pressure from industry and fear-mongering that “billionaires” and “activists” would wreak havoc on the auction. WOC, for one, had no intentions of this, and the media firestorm created by the Petroleum Association and Kirkwood Cos. could have been resolved with a simple phone call, as we frequently do for them.
For years, WOC and other wildlife and conservation organizations have had concerns about development of land, which lies directly in the path of migrating Sublette Pronghorn. These concerns became urgent in July 2023, when parcel 194 was put on the auction block for leasing. WOC did, in fact, legally bid on parcel 194 in last year’s July auction. WOC is not fundamentally against leasing for oil and gas, or the auction process for that matter. Just as oil and gas wishes there was better guidance around what constitutes a qualified bidder, we believe the state has an obligation to develop better guidance around which state parcels should be leased for development, and which should be protected for their importance for wildlife and other irreplaceable environmental attributes.
According to Cowboy State Daily, WOC “duped” oil and gas companies during this auction and our sole intent was to drive up costs, play shenanigans, and start a bidding war. The titles and subtitles of the articles were bad, really bad, and the accusations of the reporter about WOCs intentions were malicious. Here are the reporter’s own words: “There’s a lot of disdain, I’m finding out, for the Wyoming Outdoor Council because they’ve gotten to the point now where, I mean, theoretically, you know, if you’re taking leases out of the hands of oil and gas companies, that hurts education in Wyoming, right? Because a lot of that money, that royalty money goes directly to education.” We think Cowboy State Daily was duped into carrying water for industry in penning these biased and one-sided articles. The reporter’s own bias clearly comes through in his words.
Over the course of several days (July 4–8), four articles (three written and one video) were published. As the situation developed, I had a very pleasant call with the editor of Cowboy State Daily, who ultimately agreed to modify the headlines, bylines, and add an accompanying editor’s note, and I look forward to working with them over the coming weeks and months to build trust. On one hand, I sympathize: The issues we and media outlets work on are complex and require a level of policy wonkiness I wouldn’t wish upon most people. Expeditiously translating these into the public vernacular is more an art than a science. On the other, it is the job of the media to report the facts, and Cowboy State Daily is, as its name implies, a daily — meaning the damaging and false narrative that was perpetuated is impossible to unsee. I remind my staff that you can’t un-ring a bell, and that it’s virtually impossible to put a bullet back into the barrel. Honesty and integrity are vital to our kindling of the public trust and our way of accomplishing our mission.
The irony is that Cowboy State Daily’s accusations lack basic understanding of the system that is set up to fund schools and a dozen or so other entities that benefit Wyoming citizens. And to put a bid in during an auction naturally increases the cost for the next person. We’d welcome Pat Maio, Pete Obermueller, and Steve Degenfelder to any livestock auction in the state to show that this is common practice — it’s how auctions work. Further, if another energy company offered up $5 when the last bid was $3, you’d say they were “outbid.” Cowboy State Daily stated that WOC “duped” them. Even the Office of State Land and Investment acknowledged we did nothing wrong. So, it appears the energy industry concocted a media strategy to drag WOC publicly, and Cowboy State Daily took the bait — hook, line and sinker.
Pronghorn and natural gas infrastructure (Image: Theo Stein / USFWS / FlickrCC)
Our intentions in bidding on parcel 194 were two-fold. First, we wanted to protect critical habitat in a migration bottleneck. Second, we sought to demonstrate that conservation interests and values could monetize state lands for beneficiaries. WOC showed up with real money over three times the prior bid. We were proud to try, and sad we failed — not for ourselves, but for the Sublette Pronghorn herd. And at the end of the day, the beneficiaries of state land leases won the day, as they do at any competitive auction that generates revenue for critical programs. Let’s talk about what royalties could and should emerge from a conservation lease.
So, there is no mechanism for conservation leasing and a rule was just passed that clarifies who can bid on oil and gas lease sales. The amount of bellyaching and press that accompanies state protection of the oil and gas honeyhole — which is now less competitive — is pretty extraordinary. If you want to really generate some revenue for Wyoming’s beneficiaries, it’s time to make lease sales competitive again, and allow a diversity of monied interests to vie for these parcels, be it for energy, conservation, recreation, or one of Wyoming’s many other values in the land. The proof is right there in the pudding: They wanted to get it for $3/acre, we went to $18. Are we promoting auctions for the beneficiaries, or fire sales on Wyoming’s landscapes? We believe we can lease, monetize and protect.
Here’s my promise to the state and energy developers like Kirkwood Cos.: If they’re willing to give up the lease and protect the bottleneck, we’ll cut ’em a check, because we don’t believe you can put a price on the viability of this herd. We get it, energy development is critical to Wyoming, but so too are our wildlife, our water and air, how we manage and lease our land, and for whom. Human and natural systems are complex. Our solutions should not oversimplify the challenges, or else we’re shifting burdens to something else, sometimes unknowingly, but the worst of us do it knowingly and for our own benefit.
At the Wyoming Outdoor Council, we welcome your questions and opinions. As executive director, I encourage them. Your inquiries and ideas (whether from members, partners or media) improve our work. We work to answer them expeditiously, but if you don’t get an answer immediately, we respectfully request that you not fabricate an answer for us. Instead, politely try again, we’ll in turn, reciprocate. We will work to be solutions-oriented, innovative, not positional, pragmatic members of the communities to which we belong and call home.
We felt compelled to share this story because we don’t believe it to be a one-off. It was for me here at WOC, but I’ve heard a number of stories from within and beyond our organization. I look forward to straightening things out with Cowboy State Daily, and frankly with Steve Degenfelder and Pete Obermueller. For more information on what WOC did at the July 2023 lease sale on parcel 194 and what our motivations were, it’s important to read program director Alec Underwood’s piece On the Ground: Setting the Record Straight on State Oil and Gas Leasing.
Carl Fisher is the executive director for the Wyoming Outdoor Council, a statewide organization committed to protecting Wyoming’s environment and quality of life now, and for future generations. Our environment includes land, water, air, wildlife, vegetation, cultural resources, and people — past, present and future.
SOS: SAVE OUR SAGE-GROUSE AND THE PLACES THEY CALL HOME
Your voice makes a difference! Will you urge the Bureau of Land Management to take assertive action to save the Greater sage-grouse and Wyoming’s unmatched sagebrush habitat? Find suggested talking points to help you write your comment below.
It’s no secret that the Greater sage-grouse, a symbol of the West’s sweeping sagebrush landscapes, is imperiled. Dire statistics on habitat loss and dwindling populations — echoed across studies and countless articles — paint a sobering picture for the beloved bird:
“Remaining sagebrush covers less than half its historic extent.”
“We are losing 1.3 million acres of sagebrush annually.”
“Sage-grouse populations have declined 80% since 1965.”
“Greater sage-grouse numbers have been cut almost in half over the past 20 years.”
From the heart of sagebrush country in Wyoming, where the ravages of invasive annual grasses and wildfire have yet to create the mass devastation they have in places like Nevada, it can be hard to comprehend how precarious the situation has become. But unfortunately, Wyoming is not immune to the threats eating away at sage-grouse populations and their habitats. Our state stewards the lion’s share of the world’s remaining sage-grouse and sagebrush — all the more reason to confront these threats head-on.
Of course, Western states have worked collaboratively for years to counteract threats and stave off an endangered species listing (read more here), but it’s clear more needs to be done to support sage-grouse. Fortunately, the Bureau of Land Management is now in the process of updating sage-grouse management plans across the whole of the bird’s range. What does this process mean for us? It means we have a chance to encourage strong action from the agency that manages more sage-grouse habitat than any other, including about 18 million acres right here in Wyoming.
The sagebrush steppe is home to a rich tapestry of over 300 species. How the BLM manages sagebrush habitat has far-reaching implications for an entire ecosystem of plants and animals that need our help, including pronghorn, mule deer, pygmy rabbits, ferruginous hawks, sage thrashers, parasol buckwheat…. The list goes on! As go the sage-grouse, so go our Western rangelands and sagebrush dependent species — which is why it’s imperative the BLM take assertive action to protect sage-grouse and shore up the best remaining sagebrush habitat with this plan.
We can all play a role in guiding the agency to do just that. The BLM is accepting public comments through June 13, and your comments have the power to shape the final plan the BLM adopts.
In addition to sharing your personal connection to sage-grouse and the sagebrush ecosystem in Wyoming, you can also can urge the BLM do the following:
Grant Wyoming’s irreplaceable sage-grouse habitats the strongest protections. Wyoming is home to over a third of the world’s sage-grouse population because it contains the best remaining habitat. Chief among these, the Golden Triangle in southwest Wyoming boasts the densest populations of sage-grouse on the planet. The unmatched habitat in the Golden Triangle should be granted the strongest possible protections.
Direct development away from healthy habitat. There are many demands on BLM lands, but there is also ample acreage available to meet those demands. Infrastructure and energy development should be directed outside of Priority Habitat Management Areas to ensure sage-grouse are afforded the quality habitat they need to thrive.
Rely on the best available science to guide management decisions. Efforts to conserve the sage-grouse and its habitat can best be achieved by taking advantage of the latest research and science. The final management plans should lean heavily on the wealth of new data available to allow nimble, adaptive management responses to aberrant declines in sage-grouse populations across jurisdictional boundaries.
Maintain gene flow and habitat connectivity. Wyoming has the most robust population of remaining sage-grouse, but we shouldn’t keep all our eggs in that one basket. Critical connectivity areas, on the Montana border in northeast Wyoming and on the Utah border in southwest Wyoming, must remain open to allow for gene flow and dispersal between Wyoming’s populations and those in neighboring states.
Take bold action to conserve the habitat sage-grouse rely on. Western states, federal agencies, and private partners have been working together for over a decade to halt sage-grouse population declines, yet population indicators show we are losing this bird across its broader range. Because of this, stronger conservation measures should be adopted at every turn when weighing various management actions.
Enhancing Protections for the Sage-Grouse: A Pivotal Moment for Conservation
This opinion piece was originally published in the Casper Star Tribune on May 8, 2024 and is republished here with permission. See the original op-ed here.
In June 2007 then Wyoming Governor Dave Freudenthal called on the leaders of Wyoming’s industries, non-governmental organizations and government agencies to gather in Casper for his Sage Grouse Summit. It was an event he hosted and moderated on the stage at Krampert Theatre at Casper College flanked by Directors of BLM Wyoming, Wyoming Game and Fish Department, and the Wyoming Wildlife and Natural Resource Trust.
Freudenthal didn’t mince words, “The scientific picture is clear,” he said. “We need to roll up our sleeves and develop a plan to protect and restore core sage grouse habitat. We have a narrow window of opportunity to protect the grouse and prevent it from being listed as an endangered species,”
These words catalyzed policy-making efforts in Wyoming, often mirrored in other states, which were then largely incorporated into rangewide plans approved by the BLM and USFS in 2015. Cumulatively these plans provided the U.S. Fish and Wildlife Service with the basis to determine the Greater Sage-Grouse was not warranted for listing under the Endangered Species Act. Unfortunately, the plans developed in 2015 were never fully implemented.
After a 33-year career with the Wyoming Game and Fish Department, the last 15 years of which were as the state’s sage-grouse coordinator, I learned that this is about much more than just a bird. The problems associated with a breakdown in the health of sagebrush country resulting from massive wildfires, invasive plants like cheatgrass, woody species expansion, and human infrastructure and disturbance impacts all of us, here in Wyoming and across the West. These lands underpin the economies of our rural communities.
Using satellite imagery we’ve recently learned that we’re losing 1.3 million acres of functioning sagebrush habitat every year. And because the bird depends on healthy sagebrush habitat, the rangewide population of sage-grouse has declined 80 percent since 1965 and half of that decline has happened since 2002. Many of Wyoming’s populations have suffered less than those in some other states thanks to our soils and climate being better suited to growing sagebrush than other plants. And there have been short-term increases in some populations over the last two years thanks to less drought. But over the long-term all populations have declined in spite of the massive and well-intended efforts undertaken to prevent the need to list the species as threatened or endangered.
So, almost two decades after Governor Freudenthal convened stakeholders in Casper, the window to ensure a future for the bird is even narrower. But we have now an opportunity to course correct and realize a healthier future for this ecosystem. The BLM, which oversees 69 million acres of sage-grouse habitat across 10 states, and 18 million acres of land in the Cowboy State, is currently updating the prior plans using new science and input from its partners.
As I review the plan and discuss the issues with former colleagues I’ve come to the conclusion that it is now imperative that all of our collaborative conservation efforts shift from a sage-grouse focus to a sagebrush biome focus in order to more effectively address the threats facing not only sage-grouse but the entire ecosystem and those species, including human users, reliant on it. I implore the BLM to better incorporate this concept into their decision document.
Paramount to any plan must be a commitment to transparency and collaboration in managing the sage-grouse habitat. Open data sharing across administrative boundaries is essential in fostering an inclusive environment where scientists, policy makers, and the public can access and contribute to the ecological data that guide management decisions. This approach not only enhances the trust and cooperation among stakeholders but also strengthens the scientific basis for those decisions and provides defensible evidence of the successes and failures of management actions. With sound data incorporated into adaptive management tools like the Targeted Annual Warning System outlined in the draft plan, managers can quickly respond to threats such as habitat degradation or sudden population declines.
Finally, there are some relatively intact landscapes that rise above others in terms of their value to sage-grouse and associated species. I support efforts to secure the most effective protections for these “best of the best” areas which are resistant to impacts like invasive species and resilient in their ability to return to good habitat after an impact such as wildfire. They are the cornerstones upon which the survival of the sage-grouse depends. Irreplaceable places, such as the Golden Triangle in western Wyoming, have such high biological value that these should have the highest level of protections.
The current proposal by the BLM to update its sage-grouse management plans is an important step forward. By focusing on strategic habitat management, implementing open data practices and advanced adaptive management tools, we can forge a sustainable path for the sage-grouse. This approach will not only benefit the bird but also the myriad other species and human communities that rely on a healthy sagebrush ecosystem. It’s a chance to reaffirm our commitment to conserving a vital part of our natural heritage thereby ensuring that we hand these natural resources in good condition to future generations.
Have questions about the BLM’s updated sage-grouse management plans? Send us an email or write a comment below.
Meeting the Moment: Planning for a Responsible Energy Future with the Western Solar Plan
Attend our virtual Conservation Cafeteria on the Western Solar Plan on Wednesday, April 3 at noon — RSVP here.
If you’ve been following national energy trends, you may have noticed that 2022 was a big year. It was the first year in recent history that renewable energy surpassed coal generation in the U.S. As the cost of renewable energy continues to decline, and numerous state and federal policies continue to encourage decarbonization, it’s clear that renewable energy is here to stay. And that means states like Wyoming need to start preparing for new types of energy infrastructure on their lands.
For Wyoming, the implications of a transition to low-carbon and renewable energy are difficult to overstate, especially considering the footprint of utility-scale renewable energy and its potential impacts to wildlife, habitats, open spaces, and cultural resources across the state. Fortunately for one key renewable energy resource that Wyoming has in abundance — sunlight — we have a once-in-a-generation opportunity to ensure that this development is sited right from the start. That’s where the Western Solar Plan comes in.
The 2012 Western Solar Plan is getting updated — and Wyoming is included!
The Bureau of Land Management is currently proposing to expand and update its 2012 Western Solar Plan, which will help identify the best locations across the West for future utility-scale solar development — in this case, solar facilities that produce 5 megawatts or more on public lands. The plan aims to proactively screen for wildlife, sensitive habitats, cultural resources, and other values and resources that could conflict with solar energy development. Wyoming wasn’t included in the 2012 plan, back when solar energy cost roughly 10 times what it costs today. But the updated plan includes Wyoming and other newcomers, including Montana, Idaho, Oregon, and Washington.
Having Wyoming included in the updated Western Solar Plan is great news! This policy update was a core recommendation of the Renewable Energy Siting Collaborative, a convening of industry, conservation groups, academics and other stakeholders that the Wyoming Outdoor Council helped facilitate in 2021. The large footprint that solar energy needs to produce electricity means that inappropriately sited projects could have devastating consequences for Wyoming’s migrating ungulate herds and fragile habitats. We’ve unfortunately witnessed this firsthand with the Sweetwater Solar Facility, the state’s first utility-scale solar project on public lands. This facility was placed along a pronghorn migration route north of Green River, creating a barrier along the animals’ path that funneled them onto a county highway, creating a dangerous situation for pronghorn and motorists alike. It’s an example that shows the impact these facilities can have on wildlife and just how important it is to site projects in ways that avoid sensitive habitats.
Help us achieve the best outcome for Wyoming
From now until April 18, the BLM is seeking comments on five different alternatives for the updated Western Solar Plan through its e-planning website. BLM’s preferred alternative (alternative 3) would leave 2.98 million acres (roughly 17 percent) of BLM land in Wyoming open for solar development applications. Stated simply — we think this is too much.
Wyoming is unique in its open spaces, unfragmented habitats, and iconic seasonal wildlife migrations. Solar development in particular presents an impenetrable barrier for big game that threatens connectivity on these landscapes. This is why we are urging our members to tell the BLM to select an alternative that further narrows where solar projects can exist, while still leaving enough acreage available to help our nation reach important climate goals.
Specifically, we urge our members to support alternative 5, which requires that solar energy development on public lands meet the following criteria:
Be located on previously disturbed lands with diminished integrity
Be located within 10 miles of existing or proposed transmission corridors
Be located on slopes less than 10 degrees
Not conflict with 21 resource-based exclusions that BLM has identified for all alternatives. (A full list of these exclusions can be found starting on page 21 of the draft plan.)
Even when considering these criteria, alternative 5 still allows for applications for solar development in 1.4 million acres of public lands in Wyoming. This is about 50 times more than the BLM expects will actually get developed by 2045 in their reasonably foreseeable development scenario for Wyoming (below). Alternative 5 also adds an additional safeguard by only considering applications on previously disturbed lands which would help ensure that the loss of unfragmented and healthy habitat is minimized and that future solar development is directed away from these areas.
Figure 1: BLMS Reasonably Foreseeable Development Scenario. Available here.
Speak up for Wyoming’s wildlife
Finally, we need your help speaking up for Wyoming’s wildlife in the plan. As drafted, the Western Solar Plan excludes solar development from big game migration corridors and winter ranges only where this habitat is identified and explicitly singled out for exclusion in existing land use plans. Unfortunately, most of Wyoming’s resource management plans are severely outdated and provide little to inadequate acknowledgement for big game migrations and winter-range in relation to renewable energy projects. Biologists have collected huge amounts of data in recent years to delineate migratory routes and improve understanding of how animals are using crucial winter range in Wyoming. Very little of this has been included or updated in resource management plans.
If this plan is to be successful for Wyoming and avoid harm to our wildlife, it needs to avail itself of the best available science on migrations and winter ranges. In your comments, tell the BLM that it needs to revise its big game exclusion criterion (criterion 9) to protect identified big game crucial winter range and migration corridors from utility-scale solar development regardless of the direction offered in applicable land use plans. The risks to our ungulate herds are too great to ignore the best available data waiting on land use plan revisions that may take decades.
Help Us Meet the Moment
It’s not everyday in our work as conservation advocates that we get the chance to raise our voice in support of planning efforts with the potential to have such an impact as the Western Solar Plan. As many of you know, this work is so frequently driven by the need to react to bad ideas and policies that threaten conservation values. This plan is different. It sets the rules that will govern solar development on public land for decades to come. From our vantage point at WOC, we are entering a time when the country’s energy future is at a crossroads — and Wyoming stands to play an important role in choosing which path we take. With an updated Western Solar Plan, we have a rare opportunity to be proactive and reduce many of the resource conflicts that we’ve sadly grown accustomed to on our public lands. We can plan for the development that will be needed to power our country while also meeting our long-term climate goals and protecting the wildlife and the very things that make Wyoming special.
IMAGINE THIS: It’s spring in Wyoming’s Red Desert, and daybreak unfolds around you. As the sun crests the horizon and illuminates mile upon mile of open sagebrush country, the songbirds’ dawn chorus reaches its crescendo. Sage thrashers and Brewer’s sparrows sing their hearts out. At intervals, the resonant “wups” of displaying Greater sage-grouse join in. Far in the distance, bands of mule deer amble along a well-worn game trail, browsing their way towards summer pasture as the snows recede. A pair of ferruginous hawks wheel overhead in the brightening sky.
It’s a scene that has played out largely unchanged for millenia. Whether today, 100 years ago, or 10,000 years ago, people have experienced the vastness and natural bounty of the Red Desert. These days, as wildlife and the lands they rely on are increasingly whittled into the margins, fewer and fewer places on Earth can offer the same. The Red Desert’s immense territory of sagebrush is a precious thing, supporting groups of species you can’t find many places in North America anymore. It is worth our time and toil to keep it whole and healthy for those who come after us.
Thankfully, we have a brief opportunity to make a big impact. With the revision of the Rock Springs Resource Management Plan by the Bureau of Land Management, the managers who oversee land use in the Red Desert are reassessing everything. The agency will carefully weigh public comments as it decides how best to manage these lands for decades to come. If we want to uphold the Red Desert’s extraordinary wildlife legacy, now is the time to speak up in favor of management directives that will help conserve the area’s exceptional natural resources.
Image: Ken Driese
The BLM is choosing between management actions that will make a real difference to the wildlife that depend on these lands for their survival. Whether you want to see the world’s longest mule deer migration persist, provide desert elk with safe birthing grounds, ensure better nest success for hawks and eagles, or see the most densely populated Greater sage-grouse habitat on the planet protected, your input during this process is critical. With foresight and careful management, generations of people and animals yet to come will be able to experience the Red Desert much the same as those who came before. The opportunity to make that careful, balanced management a reality is here — and it is up to us to speak to the values we hold dear on this landscape.
On Monday, Feb. 27, 2023, the Wyoming Outdoor Council joined a number of organizations in calling on the Secretary of the Interiorto enact long-overdue oil and gas leasing reforms that were put forward by Congress as part of the Inflation Reduction Act. Finalizing these reforms will protect taxpayers from footing the bill for cleaning up drilling sites, protect wildlife habitat and areas with cultural and historic value, and stop “over-the-counter” noncompetitive lease sales at bargain basement rates.
Pay your way
Bond amounts required to cover clean-up costs for drilling on federal land have not been updated in more than 60 years. The Office of Government Accountability reported in 2019 that 84% of bonds, representing 99.5% of wells on Bureau of Land Management lands, would be insufficient to cover the cost of reclamation even in low-cost scenarios. Oil and gas companies can afford to pay the full costs of properly plugging and reclaiming wells sites and owe it to taxpayers to do so.
No ad hoc nominations
At present, the BLM’s “informal” nomination process allows any company to put forward any parcel of public land for leasing, regardless of the land’s potential to produce oil and gas or how valuable the land is for cultural resources and wildlife. Shifting to a “formal” nomination process could require strategic identification of which lands to make available for nomination ahead of time, upholding the agency’s charge to manage for multiple uses and protecting parcels with high cultural and conservation values.
Identify conflicts ASAP
Under a “formal” nomination process, there could be screens to identify conflicts with other uses, resources, and potential returns to taxpayers. Setting up routine screening with nationwide and state-specific criteria at the outset of the lease sale process would help the BLM identify which lands to lease.
No freebies
The Inflation Reduction Act did away with noncompetitive leasing, which for decades had allowed companies to pay rock bottom prices to lease public lands that did not receive bids at auction. Despite this, the recent Draft Environmental Assessment for the BLM Wyoming Second Quarter 2023 Federal Oil and Gas Lease Sale included a provision stating noncompetitive leasing would be allowed. Formal revisions to BLM regulations would put a clear end to noncompetitive leasing and create consistency among BLM offices and projects.
The Bureau of Land Management rang in the new year with a bang and has cued up a public comment doubleheader for two upcoming oil and gas lease sales. I hope you’ll take advantage of this opportunity to share your views on both sales with the BLM in one fell swoop!
First up, the newly proposed September lease sale would open more than 95,000 acres of public land to oil and gas development, 20 percent of which overlaps priority sage-grouse habitat. With sagebrush habitat in freefall, and ongoing sage-grouse population declines, we should be shoring up the best remaining sage-grouse habitat, not leasing it out for industrial development. Also of concern is a parcel directly adjacent to, and possibly overlapping, two Wilderness Study Areas (Alkali Basin/East Sand Dune and Red Lake) and 19 parcels in crucial winter range for mule deer, pronghorn, and elk.
I do have some good news to share: Thanks in part to public comments from people like you, the BLM issued an Environmental Assessment that could remove 80,000 acres of public land from the June lease sale, much of which was also in priority sage-grouse habitat. Now is the time to let the BLM know that we are in favor of these deferrals. That said, dozens of parcels are still being offered in priority sage-grouse habitat along with three parcels in Wyoming’s officially designated Baggs mule deer migration corridor. I encourage you to speak up on behalf of these conservation values on our public lands.
Your comments can be brief and highlight your own personal connection to the wildlife and landscapes in question. You may also want to highlight that:
The BLM has made previous commitments to avoid new surface disturbance in high priority habitat, yet both proposed sales include parcels that lie within this core sage-grouse habitat.
Across the West, we are losing 1.3 million acres of sagebrush habitat annually and the primary threat to sagebrush in Wyoming is development. Protecting core, healthy tracts of sagebrush habitat from disturbance is crucial to the ecosystem and benefits many other species of wildlife that depend on sagebrush.
More than 8 million acres of public lands in Wyoming are already leased to oil and gas companies, with 4.2 million acres sitting idle and undeveloped. Companies have ample opportunity for drilling without the BLM leasing additional parcels.
Comments on the September sale are due Jan. 19, and comments for the June sale are due Jan. 23.
Thank you for your commitment to the lands and wildlife that sustain us all!
The Bureau of Land Management has announced plans to lease more than 250,000 acres of public lands in Wyoming for oil and gas development in the beginning of 2023. Sage-grouse habitat is impacted on nearly every acre of the proposed lease sale.
Greater sage-grouse have declined across their range by 80% since 1965, and habitat loss is a significant driver in those declines. We are losing sagebrush habitat at a rate of 1.3 million acres a year throughout the West, but Wyoming is a bright spot, retaining more intact sagebrush habitat than any other state in the union. Wyoming has a valuable role to play in preserving sage-grouse populations and the sagebrush ecosystem by shoring up our remaining stretches of healthy habitat.
We at the Wyoming Outdoor Council believe the BLM should, at minimum, remove all parcels encompassing “priority” or “core” sage-grouse habitat from this sale — although offering any parcels within “general” sage-grouse habitat is also ill-advised. The development that we allow in Wyoming has far-reaching implications for the persistence of sage-grouse nationally, and staving off an Endangered Species Act listing depends on providing these birds the space they need on the landscape. Given the downward trajectory of sage-grouse numbers, we should not be offering up sage-grouse habitat for industrial development.
The BLM is accepting public scoping comments until Nov. 7 to identify issues that should be addressed in the agency’s environmental review. If you have a moment, send a brief, personal message to the BLM asking that sage-grouse core areas be removed from the sale. Sharing your concerns with the sale, and your personal connection to the wildlife and landscapes that will be affected, can help influence the agency to take conservation values into account.
In your comments, you may want to highlight that:
The vast majority of the proposed lease sale falls in sage-grouse habitat (205 out of 209 parcels). The BLM has made previous commitments to avoid new surface disturbance in high priority habitat, yet 70 of the parcels lie within this core sage-grouse habitat.
Across the West, we are losing 1.3 million acres of sagebrush habitat annually and the primary threat to sagebrush in Wyoming is development. Protecting core, healthy tracts of sagebrush habitat from disturbance is crucial to the ecosystem and benefits numerous other species of wildlife that depend on sagebrush.
More than 8 million acres of public lands in Wyoming are already leased to oil and gas companies, with 4.2 million acres sitting idle and undeveloped. Companies have ample opportunity for drilling without the BLM leasing additional parcels.
Thank you for taking the time to be a champion for our wild species and wild places. If you have questions, please reach out to Meghan Riley, the Outdoor Council’s public lands and wildlife advocate.
