In the Solar PEIS, the BLM committed to preparing solar regional mitigation strategies (SRMSs) for the solar energy zones (SEZs). These regional mitigation strategies were intended to simplify and improve the mitigation process for future solar projects in SEZs.
On March 2, 2016, the BLM released the Regional Mitigation Strategy for the Arizona SEZs – Final Report (PDF, 5.5 MB). The Brenda SEZ is included in the strategy. The strategy identifies mitigation priorities and options in advance of development, and takes into account the resource conditions of the land and regional trends informed by BLM's recent Rapid Ecoregional Assessments. The strategy was developed in collaboration with stakeholders to address key issues such as where and how mitigation may be achieved and the costs associated with doing so.
With IM-2019-018, the BLM established policy that compensatory mitigation could not be required as a condition for project approvals. However, with the issuance of IM 2021-038 on July 14, 2021, the BLM rescinded the previous IM-2019-018. The BLM expects to establish policies which are aligned with EO 13990, SO 3398, and the priorities of the Department. During this interim period offices should consider and implement compensatory mitigation on a case-by-case basis, in consultation with state office and national office program specialists and the Office of the Solicitor as needed.