Bureau of Land Management Solar Energy Permitting and Program Resources
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Variance Protocol for Resources and Values of Units of the National Park Service

The BLM has adopted the following protocol for variance applications that have the potential to impact resources and values of units of the National Park System and other special status areas under the National Park Service (NPS) Administration.

Proximity to Units of the NPS

The construction and operation of utility-scale solar energy projects and related transmission infrastructure near units of the National Park System and other special areas administered by the NPS, including National Historic Trails, may significantly affect park programs, resources, and values. For example, ecological resources (such as habitat and migration of species) and physical resources (such as wind, water, air, and scenic views) cross park boundaries, and park boundaries often do not contain all of the natural resources, cultural sites, and scenic vistas that affect the quality of the park visitor's experience within these special places.

High-Potential Conflict Exclusions

The NPS has identified areas within the proposed variance areas where utility-scale solar energy development poses a high potential for conflict with the natural, cultural, and/or visual resources administered by the NPS. The BLM has excluded from the Solar Energy Program approximately 821,000 acres (3,322 km2) of land that coincides with NPS-identified areas of high-potential conflict.

Maps of NPS High-Potential Conflict Areas

Maps and data documenting areas of high-potential conflict with units of the National Park System, historic trails, and other areas under NPS administration are available on the 2012 Solar PEIS Archives. This information will promote public awareness and notify industry where additional documentation may be required to proceed with an application in variance areas. The maps and data are regarded as a first-order approximation of landscape-scale conditions and potential resource conflict and will be updated as new information and analytical tools are developed.


The BLM will utilize these maps and data in the screening of proposed solar energy projects in variance areas. In cases where a utility-scale solar energy development right-of-way (ROW) application is submitted in a variance area identified as having a high potential for conflict with the resources of a unit of the National Park System or special areas administered by the NPS, additional documentation will be required. This documentation may include information to verify any or all of the following potential resource conditions resulting from the proposed project:

  • Increased loading of fine particulates (criteria pollutants: PM2.5 and PM10 [particulate matter with a diameter of 2.5 µm or less and 10 µm or less, respectively]) and reduced visibility in Visual Resource Management (VRM) Class I and sensitive Class II areas;
  • Vulnerability of sensitive cultural sites and landscapes, loss of historical interpretative value due to destruction or vandalism;
  • Altered frequency and magnitude of floods, and water quantity and quality;
  • Reduced habitat quality and integrity and wildlife movement and/or migration corridors, increased isolation and mortality of key species;
  • Fragmentation of natural landscapes;
  • Diminished wilderness, scenic viewsheds, and night-sky values on landscapes within and beyond boundaries of areas administered by the NPS; and
  • Diminished cultural landscape qualities within and beyond boundaries administered by the NPS.


The documentation provided by an applicant must be sufficiently detailed as determined by the BLM and NPS. The documentation should represent the findings of science and the analyses of scientifically trained specialists in the appropriate natural, visual, and/or cultural resource disciplines. The NPS will prepare a response to the BLM regarding the following:

  1. Whether the proposed project meets NPS protection, conservation, and/or restoration objectives; and
  2. Whether the resource conflict documentation is adequate to support a finding by the NPS and BLM that the proposed project is likely to avoid a high potential for conflict with resources and values associated with a National Park or other special status area under the administration of the NPS.

NPS Involvement

The NPS will continue to refine data for determining resource conflict and provide this information to the BLM for use in the variance process. The NPS will assist the BLM in identifying alternate project locations if there is insufficient information to verify potential resource conflict with sensitive resources and values of National Park and other NPS special status areas. In all cases, evaluations will be performed to ensure that natural, visual, and cultural resources of units of the National Park System and other special areas administered by the NPS are protected.