Meeting the pace and scale of clean energy deployment needed to achieve climate targets in the United States needed to mitigate against the worst effects of climate change will depend, in part, on how projects are sited on the millions of acres of federal public lands. Those same public lands also present extensive opportunities to manage ecosystems as carbon sinks and for climate resilience.
Although some public lands that are managed for a specific purpose, such as national parks, national monuments, or wilderness areas, are appropriately off-limits for most new energy infrastructure, a substantial portion of public land is managed for uses that can include clean energy deployment. The federal government is taking positive steps to accelerate infrastructure siting in designated suitable areas and identify opportunities to store more carbon on these lands. Clean Air Task Force (CATF) applauds those efforts and is using our technical and legal expertise to push for effective strategies to address climate change using public lands.
The opportunity and need on public lands
The federal government manages approximately 640 million acres of surface lands and over 700 million acres of the subsurface mineral estate in the United States. Some of these public lands could play an integral role in the clean energy buildout, for example, by hosting clean energy projects and rights-of-way for the electric transmission necessary to connect those projects to the grid.
One agency, the Bureau of Land Management (BLM), manages 244 million acres under a mission for multiple uses, sustained yield of renewable resources, and prevention of degradation of public lands. Under their mission, much of BLM’s land could be available for wind, solar, or geothermal energy development or zero- and low-carbon energy infrastructure such as electric transmission lines and hydrogen or carbon dioxide pipelines. The potential for these projects is tremendous, and CATF is working on an analysis of the capacity for BLM and other federal lands to host or support clean energy infrastructure.
In a supplementary technical analysis, CATF seeks to estimate the technical potential for clean energy infrastructure development on a portion of federal public lands. Read more here.
Multiple congresses and administrations have recognized the value of public lands for clean energy deployment. Congress set a goal of permitting 25 gigawatts of wind, solar, and geothermal energy capacity on public lands by 2025 in the Energy Act of 2020 and created ways to site electric transmission lines and other infrastructure, including hydrogen pipelines, on public lands in the Energy Policy Act of 2005. President Biden issued an executive order directing the Department of the Interior to review siting and permitting processes on public lands with the goal of increasing renewable energy production. In addition, Interior’s Climate Action Plan calls for mainstreaming climate change adaptation in agency policies and plans and the Department of Energy is working to improve interagency coordination of reviews and approvals for transmission projects.
Federal agencies, including BLM, are taking steps toward meeting these clean energy goals. BLM has approved more than 26 utility-scale renewable energy projects since 2021, and, as of the end of October 2023, had 33 renewable energy projects in review with a combined potential capacity of over 20 gigawatts – nearing the “25 by 25” clean energy goal. BLM has also approved 20 generation interconnect, or gen-tie, electric transmission lines, and as part of implementation of the Energy Policy Act of 2005, there are 117 designated energy corridors for transmission and distribution line siting on public lands traversing 5,000 miles.
Despite this progress, the pace of permitting and leasing can often be slow, with high-voltage electric transmission lines and renewable energy projects often taking years or even over a decade to receive all agency approvals. Even though public lands have an expansive potential for clean energy projects, a 2020 report estimated less than five percent of installed renewable energy capacity was located on public lands. Both the pace and scale of development must increase to meet climate goals.
Meeting the opportunity on clean energy deployment and carbon storage
CATF’s Land Systems and Clean Energy Infrastructure Deployment programs are taking action to identify ways to improve permitting reviews, promote best practices for siting and design of clean energy projects on federal land to accelerate clean energy deployment. We are also proposing ways these public lands can be managed to durably store more carbon. This work advances CATF’s mission to safeguard against climate change through deployment of clean energy technology and management of carbon sinks to minimize near term warming.
Recently, CATF used our legal and technical expertise to provide comments on two proposed rules from BLM related to conservation leases for compensatory mitigation, managing for land health, and solar and wind energy development. These comments supported the proposals and suggested ways to strengthen their effectiveness further, including in these three areas:
- CATF called on BLM to accelerate permitting for clean energy infrastructure by providing ways to quickly and durably address any unavoidable impacts through mechanisms such as conservation leases and mitigation banks. These approaches can both improve the timeliness of project approvals for zero- and low-carbon infrastructure and promote ecosystem resilience on public lands.
- CATF supported BLM’s proposal to help accelerate clean energy buildout while protecting ecosystems through reduced rents for wind and solar deployment and prioritization of projects in areas identified as appropriate for development. These policy changes can improve the pace of approval and minimize or avoid land use conflicts for these projects.
- CATF encouraged BLM to manage public lands for ecosystem-based carbon removal and storage and for climate resilience. In addition to clean energy siting, CATF provided recommendations on how management practices to improve climate resilience and increase ecosystem-based carbon removal and storage can be part of how BLM manages ecosystems for land health.
CATF calls on BLM to promptly finalize strong versions of these proposed rules with the recommendations included in our comments. Our experts are also analyzing additional ways to accelerate the pace of deployment for well-planned zero- and low-carbon energy infrastructure on public lands and durable carbon storage.
Effective management of federal public lands is essential for clean energy and transmission deployment, in ways that also protect important habitat and other uses, and those lands are also a tremendous resource for managing ecosystems as carbon sinks. CATF will continue to push for updated policies and practices to manage public lands for climate change deterrence to achieve the agency’s missions and serve the public good.