For the record..... is it on BLM land or Paiute Reservation land.?
There is a large reservation Paiute down in southern Nevada. Solar farms might be the next Indian Casino bubble. There are tons of vacant reservation land in Utah, Nevada and especially Arizona.
I don't know, and I don't think it makes any difference. If the feds want to offset land they will do it.
In Michigan, we have a combined fed and Michigan offset requirement for using wetlands. You are allowed to fill wetlands, as long as you "offset" the fill with creation of new wetlands where there were none before. If you are a private individual, you must "offset" one and a half acres for every single acre you fill. A neighbor had to "offset" three acres in order to fill a third of an acre. He also had to give up three hundred feet of lake shoreline in order to use fifteen feet. If you are the state, you must "offset" only one acre for every acre you fill. How fair is that? In other words, the feds can do whatever they want to do.