Bureau of Land Management Solar Energy Program Western Solar Plan
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Solar Regional Mitigation Strategies

The Bureau of Land Management (BLM) worked to develop Solar Regional Mitigation Strategies (SRMSs) for solar energy zones between 2012 and 2018. In late 2018, the BLM issued IM-2019-018, establishing policy that compensatory mitigation could not be required as a condition for project approvals. At that time, the BLM had completed SRMS documents for eight solar energy zones (three in Arizona, two in Nevada, and 3 in Colorado — see below). Development of SRMSs had begun for four additional zones in New Mexico and Utah. The draft and final regional SRMS documents included recommended per-acre CM fees for solar energy zones based on unavoidable impacts to vegetation communities and associated ecosystem services.

With the issuance of IM 2021-038 on July 14, 2021, the BLM rescinded the previous IM-2019-018. The BLM expects to also establish compensatory mitigation policies which are aligned with EO 13990, SO 3398, and the priorities of the Department. Until new policies are established, 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.

The SEZ characterization data and discussion of potential impacts of development in the SRMS documents may prove useful for consideration during project permitting activities. Additionally, the BLM conducted outreach to support the SRMS projects with a broad representation of stakeholders, including industry, state and local governments, tribes, and local communities, and this stakeholder input to the SRMS documents remains valuable. Links to the SRMS documents are provided below.

Afton Solar Energy Zone (SEZ):
Arizona SRMS (3 SEZs):
Arizona SEZ Mitigation web pages (Agua Caliente, Brenda, and Gillespie)
Colorado SRMS (3 SEZs):
Utah SRMS (3 SEZs):

While developing the solar regional mitigation strategies, the BLM also released its draft Procedural Guidance for Developing Solar Regional Mitigation Strategies. That guidance is available below.

The regional mitigation strategies were conducted in accordance with the BLM's mitigation policy, Manual Section-1794, and Mitigation Handbook (H-1794-1).


As an incentive to develop projects in SEZs, the BLM has begun to establish regional mitigation strategies for all SEZs. Regional mitigation strategies are expected to simplify and improve the mitigation process for future projects in SEZs.

Regional mitigation strategies developed for SEZs will be used to inform leasing decisions and project authorizations within SEZs. They will be developed through a transparent stakeholder and public engagement process. As described in Appendix A, Section A.2.4 of the Final Solar PEIS (PDF, 3.0 MB), the BLM expects that regional mitigation strategies will consist of the following elements:

  1. A description of SEZ and regional baseline conditions against which unavoidable impacts are assessed;
  2. An assessment of the unavoidable impacts and identification of which unavoidable impacts warrant off-site mitigation;
  3. The identification of regional mitigation goals;
  4. The identification of a method for calculating recommended mitigation fees for unavoidable adverse impacts that warrant mitigation;
  5. The identification and recommendation of a management structure to hold and apply any mitigation investment funds;
  6. The evaluation and recommendation of appropriate mitigation investment locations, objectives, and/or actions; and
  7. Planning for mitigation implementation and the development of long-term monitoring and adaptive management recommendations to evaluate and maximize the effectiveness of off-site mitigation actions.
Updated: 9/30/2021