1. Greater Sage-Grouse: Implications for Wind
Energy Permitting on Federal Lands
Michael S. Hildner
Bureau of Land Management
Washington, DC
mhildner@blm.gov
Kevin J. Rice and Drew Vankat
EMPSi
Boulder, CO
kevin.rice@empsi.com
drew.vankat@empsi.com
Abstract—This paper summarizes the primary habitat allocations and conservation measures in the
Bureau of Land Management and US Forest Service’s recently completed greater-sage grouse
management strategy. Implications for siting wind energy projects are discussed, with a focus on
understanding key features that can affect a project’s location and configuration and critical paths in the
permitting process.
Introduction
In 2010, the US Fish and Wildlife Service determined that the greater sage-grouse (GRSG) was
warranted for protection under the Endangered Species Act but that its listing was precluded by
other priority species. In response to this determination, the Bureau of Land Management
(BLM), in coordination with the US Forest Service, the US Fish and Wildlife Service, and state
and local agencies, developed a landscape-level management strategy to conserve important
GRSG habitat. This strategy involved revising or amending 98 federal land use plans in 10 states
across the West. The goal was the long-term, range-wide, GRSG conservation and habitat
restoration.
On September 18th
, 2015, the approved Bureau of Land Management GRSG land use plan
revisions and amendments were published. The US Fish and Wildlife Service called it “the
largest landscape-scale conservation planning effort in US history.” On October 2nd
, 2015, the
US Fish and Wildlife Service determined that the GRSG did not warrant protection under the
Endangered Species Act.
Federal land use plans form the basis for every action and approved use on public lands,
including wind energy uses. This paper describes how the recently approved GRSG land use
plans affect wind energy siting and provides strategies for how to avoid delays and conform to
land use plans.
A. Habitat Management Areas: Managing Disturbance in GRSG Habitat
The GRSG plans seek to limit or eliminate surface disturbance in key GRSG habitat
administered by the BLM, while minimizing surface disturbance in less important habitat. It is
important to understand where and how the GRSG plans manage surface disturbance. This is
because wind energy development—both the wind turbines themselves and ancillary features,
such as access roads—inherently requires some form of surface disturbance.

2. The principal mechanism through which the GRSG plans address surface disturbance is land use
allocations. Land use allocations determine the particular uses (including wind energy) that are
allowed, restricted, or prohibited on BLM-administered lands (BLM 2005, p. 13). The GRSG
plans allocate GRSG habitat on BLM-administered lands as either a Priority Habitat
Management Area (PHMA) or a General Habitat Management Area (GHMA).1
These are
defined as follows:
 PHMA—BLM-administered lands that have the highest GRSG habitat value (BLM
2015a, p. 1-15; 2015b, p. 1-15). A PHMA is typically lands near GRSG leks and other
key habitat types, such as winter concentration areas, brood rearing habitat, and
connectivity areas. In general, resource uses and activities are substantially restricted in
PHMAs.
 GHMA—BLM-administered lands that are less important to conserving GRSG, but
where special management still applies to sustain populations (BLM 2015a, p. 1-15;
2015b, p. 1-15). There is more flexibility regarding the level of resource use and activity
that may be allowed in GHMAs.
The availability of PHMAs and GHMAs for wind energy varies by state. In most states, a PHMA
is an exclusion area for wind energy. In exclusion areas, wind energy is not allowed under any
circumstances. On the other hand, a GHMA is typically an avoidance area for wind energy. In
avoidance areas, wind energy may be allowed with special stipulations, such as seasonal
restrictions, micro-siting criteria, and noise limitations. In a few states, a GHMA is an open area
for wind energy, which means that wind energy is allowed, subject to standard terms and
conditions (BLM 2005).
The availability of PHMAs and GHMAs for wind energy by state is described in Table 1 and is
depicted in Figure 1:
Table 1—Availability of BLM-administered GRSG Habitat Management Areas for Wind
Energy
PHMA (Acres) GHMA (Acres)
California Exclusion—386,000 Avoidance—370,000
Colorado Exclusion—921,000 Avoidance—803,000
Idaho Exclusion—4,181,000 Open—1,956,000
Montana Exclusion—3,120,000 Avoidance—2,519,000
Nevada Exclusion—8,922,000 Avoidance—5,350,000
North Dakota Exclusion—32,000 Avoidance—100
Oregon Exclusion/Avoidance—4,585,0002
Avoidance—5,625,000
South Dakota Exclusion—127,000 Avoidance—23,000
Utah Exclusion—2,025,000 Open—502,000
Wyoming Avoidance—7,826,000 Open—9,332,000
1
GHMA and PHMA comprise most of the GRSG habitat on BLM-administered lands. In a few states, there are
additional categories of habitat management area, such as Important Habitat Management Areas in Idaho.
2
The PHMA in Lake, Malheur, and Harney Counties is an avoidance area, while PHMAs in the rest of Oregon is an
exclusion area.

3. Figure 1. Wind Energy GRSG Constraints
The GRSG plans do not exclude wind energy from a large amount of BLM-administered lands
with high wind energy potential. The majority (91%) of BLM-administered GRSG habitat
management areas excluded from wind energy development have either low (<6.0 m/s) or
medium (6.0-7.0 m/s) wind energy potential.
Table 2 describes the availability of BLM-administered lands with low, medium, and high wind
energy potential.
Table 2—Availability of BLM-Administered GRSG Habitat Management Areas and Wind
Energy Potential (Approximate Acres)
Open (Acres) Avoidance (Acres) Exclusion (Acres)
Low wind energy
potential (< 6.0
3,612,000 11,659,000 10,481,000

4. m/s)3
Medium wind
energy potential
(6.0-7.0 m/s)
5,701,000 11,526,000 7,579,000
High wind energy
potential (> 7.0
m/s)
2,476,000 3,918,000 1,656,000
B. Additional Key Conservation Measures in GRSG Habitat
In addition to land use allocations, the GRSG plans establish additional measures to manage
disturbance and improve BLM-administered GRSG habitat. While these measures do not
determine the availability of BLM-administered land for wind energy per se, they do manage the
intensity and manner in which wind energy projects can be sited and permitted on BLM-
administered GRSG habitat.
The key additional disturbance measures are summarized below.
 Density and Disturbance Caps—In PHMAs only, all discrete, anthropogenic surface
disturbance (including wind turbines, roads, and power lines) is limited by a 3 percent
disturbance cap (except in Wyoming).4
If this disturbance cap is exceeded in PHMAs,
then no further anthropogenic surface disturbance will be permitted by the BLM until
disturbance has been reduced to less than 3 percent (BLM 2015a, p. 1-21; BLM 2015b,
p. 1-23). The disturbance cap is applicable
in PHMAs only, so it will not affect wind
energy projects in California, Colorado,
Idaho, Montana, Nevada, North Dakota,
South Dakota, and Utah; in these states, the
PHMA is already excluded from wind
energy development. In Wyoming and parts
of Oregon, the footprint of wind energy
projects will need to be minimized or
phased in, to stay under the disturbance
caps.
The GRSG plans also establish a density cap in PHMAs, which limits the density of
energy and mining facilities to an average of 1 facility per 640 acres. If the average
density of energy and mining facilities is greater than that ratio, the BLM will defer the
proposed project or will require that the project be collocated into an existing disturbed
area (BLM 2015a; BLM 2015b). The density cap may affect the spacing and
configuration of wind turbine arrays in PHMAs. Again, the density cap will affect wind
3 80m wind data from AWS Truepower
4
In Wyoming, the disturbance cap is 5 percent. It is measured by a different method, which includes other
disturbances, aside from discrete anthropogenic disturbance, such as fire.
Other Land Use Allocations
The GRSG plans determine land use
allocations for a variety of other uses,
including mineral development and
rights-of-way, including those for
transmission lines. The GRSG plans
also address existing utility corridors in
BLM-administered GRSG habitat.

5. energy projects only in Wyoming and parts of Oregon, because PHMAs in other states
are already excluded from wind energy development.
 Lek Buffer Protocol—The BLM will apply GRSG lek buffers during the project
permitting phase. The BLM will not authorize wind energy infrastructure within 3.1
miles of a lek, unless a more appropriate buffer is determined through site-specific
analysis. Wind energy infrastructure near leks is discouraged in GHMAs, but may be
allowed in limited cases (BLM 2015a; BLM 2015b).
 Required Design Features (RDF)—RDFs are design specifications that proponents of
wind energy projects in BLM-administered GRSG habitat will be required to meet; this
requirement also extends to ancillary features, such as access roads. Among other best
management practices, examples of RDFs include limiting noise during breeding season,
installing anti-perch devices, and implementing dust abatement measures (BLM 2015a;
BLM 2015b)
 Mitigation and Net Conservation Gain—For wind energy projects in BLM-
administered GRSG habitat, the BLM will require that the project provide a net
conservation gain to GRSG. This will be achieved by first avoiding and minimizing
impacts. The BLM will require compensatory mitigation to offset any remaining,
unavoidable impacts of wind energy (BLM 2015a; BLM 2015b).
C. Understanding the Permitting Process and Avoiding Delays
Applications for proposed wind energy development projects on BLM-administered lands are
processed as rights-of-way under the Federal Land Policy and Management Act. Processing
applications must comply with federal
planning, environmental, and right-of-way
requirements.
The first step in applying for a right-of-way on
BLM-administered lands is to contact the BLM
office with management responsibility for the
land where the right-of-way is needed.
In accordance with Instruction Memorandum
No. 2011-061, the BLM requires that all prospective applicants schedule and participate in at
least two pre-application meetings with the BLM before accepting a right-of-way application for
a wind energy development. Such meetings provide an opportunity to discuss land use and siting
constraints, environmental issues, and objectives and interests of the applicant. These include
environmental issues related to GRSG. In addition, pre-application meetings provide an
opportunity to initiate early consultation with federal, state, tribal, and local government
agencies.
Wind Testing
The GRSG plan land use allocations for
wind energy do not apply to meteorological
towers and other wind-testing devices.
While wind testing may be allowed in
BLM-administered GRSG habitat, it would
still be subject to other GRSG conservation
measures established in the land use plan,
such as seasonal restrictions.

6. Following the pre-application meetings, applicants submit right-of-way applications to the BLM,
along with cost recovery fees, with a plan of development, maps, and other project details. The
BLM reviews the applications for land use plan conformance; environmental analysis and
resource studies may follow. Applications with low resource conflicts are generally considered
projects that can be more easily processed, while applications with high resource conflicts are
generally more difficult to process.
To avoid permitting delays for new projects that could affect GRSG, it is critical that the
applicant understand where and how land use allocations for GRSG could affect the project.
Incorporating land use constraints into project planning and configuration before the pre-
application meetings take place may expedite the process and could help avoid delays at later
stages.
The following are tasks and resources that can be completed before the pre-application meeting
to reduce the risk of delays:
 Identify and review the applicable land use plan or land use plan amendment in the
proposed project area.
 Determine if PHMAs or GHMAs occur within the proposed project area.
 If PHMAs or GHMAs occur in the project, the project is likely subject to land use
constraints (right-of-way avoidance or exclusion) and other key conservation measures
described in Section B. Determine if there are alternative sites that could avoid GRSG
habitat. Even if there are no other alternative
sites, it is still important to document why other
locations are not feasible. This information is
discussed in the pre-application meetings and
could be included in the environmental
analysis, as part of the alternatives considered
but eliminated from further analysis.
 Review RDFs in the applicable land use
plan or land use plan amendment to determine
which of them might be applicable to the
project.
 Recognize that if a project results in
residual impacts of GRSG habitat loss and
degradation, after avoidance and minimization
measures are applied, then a compensatory
mitigation may be required to provide a net conservation gain to the species.
The requirements for siting wind developments on non-federal land will differ than those for
developments on federal lands. However, some states have GRSG regulatory mechanisms that
are applicable to all projects requiring a state permit, regardless of landownership. For example,
Rulemaking
The BLM is currently undergoing a
rulemaking process that would “promote the
use of preferred areas for solar and wind energy
development and establish competitive
processes, terms, and conditions (including
rental and bonding requirements) for solar and
wind energy development rights-of-way”. This
rulemaking effort will affect the process for
receiving a wind energy ROW on BLM-
administered lands. For more information, see
the Proposed Rule published in the Federal
Register, Vol. 79, No. 189 on September 30,
2014.

7. projects in Wyoming are subject to special conservation measures, such as timing limitations,
density disturbance restrictions, and no surface occupancy stipulations. Recognizing the
implications of state regulations and coordinating early with the state wildlife department may
reduce the risk of project delays.
Detailed documentation of the site screening process will also support permitting and NEPA
requirements for projects on federal land. This is because developers are required to consider
alternatives to their proposed project and to show why those alternatives are or are not feasible to
analyze or develop.
Using geospatial data can add certainty and clear documentation to the site screening process.
Consultants and government agencies have identified and developed spatial tools that may be a
valuable addition to wind energy developer datasets. Examples are customized GIS databases
and mapping tools, such as the West-wide Wind Mapping tool, which is under development by
the BLM and is scheduled for public release in summer 2016.
D. Conclusions
GRSG plans have introduced new project site constraint considerations on a broad scale across
the West. Developers who thoroughly vet their proposed projects will begin the formal
permitting process with a decided advantage, in terms of schedule and budget.
The three keys to successfully siting wind energy projects in GRSG habitat are as follows:
1. Key GRSG Management Concepts—Understand the six core GRSG management
concepts as they relate to wind energy development: PHMAs, GHMAs, lek buffers,
disturbance caps, mitigation, and RDFs. Incorporate these concepts into your initial site
screening criteria.
2. Data—Geospatial data are becoming increasingly important and powerful tools for
screening prospective sites. Incorporate GRSG habitat data into traditional
considerations, such as proximity to transmission lines and wind resource potential. Do
this early in the process.
3. Documentation—Document your site screening process as it relates to GRSG
management. Be prepared to discuss how you will address GRSG management at your
initial pre-application meeting with the permitting agency and associated federal, state,
and local agencies.
E. References
BLM (US Department of the Interior, Bureau of Land Management). 2005. Land Use Planning
Handbook, H-1601-1. Washington, DC.
_____. 2015a. Record of Decision and Approved Resource Management Plan Amendments for
the Great Basin Region, Including the Greater Sage-Grouse Sub Regions of Idaho and

8. Southwest Montana, Nevada and Northeastern California, Oregon, and Utah. Prepared by
US Department of the Interior, Bureau of Land Management, Washington, DC.
_____. 2015b. Record of Decision and Approved Resource Management Plan Amendments for
the Rocky Mountain Region, Including the Greater Sage-Grouse Sub-Regions of
Lewistown, North Dakota, Northwest Colorado, Wyoming, and Approved Resource
Management Plans for Billings, Buffalo, Code, HiLine, Miles City, Pompeys Pillar
National Monument, South Dakota, and Worland. Prepared by US Department of the
Interior, Bureau of Land Management, Washington DC.