Renewable Energy Development
Climate change poses a threat to historic places both within and far beyond our nation's boundaries. Accordingly, the National Trust for Historic Preservation fully supports efforts to expand our nation's renewable energy portfolio, and we recognize that federal public lands will play a significant role in the development of these resources. Still, while the need to "green" our energy supply is urgent, utility-scale renewable energy projects must be sited in ways that minimize harm to our nation's most treasured places. Therefore, the National Trust for Historic Preservation is working to ensure that significant historic and cultural resources—and their surrounding landscapes—are preserved on federal public lands while supporting the responsible development of solar, wind and geothermal projects and associated transmission lines.
Humans have lived on and modified landscapes in what is now the United States for more than 12,000 years, leaving behind both highly visible and subtle traces of their activities. These traces are perhaps best preserved on federal public lands that have seen relatively little agricultural production and development. While the locations of some cultural resources, such as national monuments, national historic landmarks, national historic districts and national scenic byways, have been more or less defined, the locations and boundaries of many other cultural resources—including historic trails, traditional cultural properties, Native American sacred sites and prehistoric and historic archaeological sites—are often unknown or unrecorded. As a result, they are at risk from development projects that may unwittingly be proposed for their exact locations. Furthermore, utility-scale renewable energy projects and their associated transmission lines frequently span thousands of acres of land and, thus, may dramatically alter the integrity of cultural resources' viewsheds and surrounding landscapes. Preservation of these spatial contexts is vital for appreciating how people interact with one another and with their environments in the past and present.
Responsible Renewable Siting Depends on Early Cultural Resource Inventories
Federal land management agencies, including the Bureau of Land Management (BLM) and U.S. Forest Service (USFS), are required to comply with the National Environmental Policy Act and analyze a variety of alternative locations for their projects. They also must comply with Section 106 of the National Historic Preservation Act (NHPA) and identify ways to avoid, minimize or mitigate adverse effects on identified historic properties. Unfortunately, BLM and USFS historically have not had the money or the staff to adequately inventory their public lands for cultural resources before development projects are proposed; the more extreme case is the BLM, which has surveyed only approximately 7% of its lands for cultural resources. Furthermore, thorough Section 106 cultural resource surveys are often performed after preferred project locations are chosen. As a result, agencies often learn exactly what resources will be impacted by renewable energy projects after the projects are well along, and the only option for satisfying NHPA regulations is mitigating impacts to cultural resources. This generally means excavating (and thereby destroying) archaeological sites or preparing educational materials to tell people about cultural resources after the latter are already gone. While excavations can yield valuable information, they are expensive and time consuming and permanently remove sites from the archaeological record. Even more importantly, mitigating visual impacts to significant cultural and historic viewsheds is difficult and mitigating adverse effects to Native American sacred sites is essentially impossible. Thus, to facilitate smart renewable energy development while protecting irreplaceable cultural resources, BLM and USFS should proactively inventory their lands and consult with Native American tribes before specific projects are proposed. That way, agencies can determine where significant cultural resources are located and, ideally, guide renewable energy projects to other locations so that adverse impacts to resources are avoided, not just mitigated.
In order to ensure that renewable energy developers do not site projects in areas that contain significant historic and cultural resources, the National Trust for Historic Preservation continues to advocate for increased BLM and USFS funding for proactive cultural resource inventories and to monitor permitting activities by federal agencies. We also provide feedback and siting recommendations for specific renewable energy projects. Federal land managers, project proponents and the interested public must take this opportunity to work together to advance our renewable energy goals while protecting irreplaceable traces of our past and landscapes that are vital for the survival of our diverse North American cultures.
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The three documents linked below outline our specific recommendations for solar, wind and transmission line development that is compatible with historic and cultural resource preservation.
Recommendations for Utility-Scale Solar Energy Development
