Recently, I wrote about how bad the air in Los Angeles has been. We need our plants (and oceans) to keep that pollution down at as great a rate as we can manage. California has a lot of land, as far as states go (~164k square miles), though there’s wide swaths where not much grows. Out to the east of Los Angeles lies many miles of desert.
The powers-that-be crafted a plan to utilize a little more desert land for generating electricity through cleaner means. That’s not totally accurate… The powers-that-be want to streamline a process where desert land can be handed over to energy developers who want to invest in clean energy infrastructure. They’ve written a plan – the DRECP (Desert Renewable Energy Conservation Plan) – to delineate what is allowed to go where. After much back-and-forth, the DRECP was passed (or approved) in 2016. It’s a done deal. Sort of…
I hadn’t heard about this plan when it first came out. I think there was a little too much other wildness going on with American politics and the election system back in 2015-2016 for me to pay attention to this. Roll our clocks forward to 2021, and we get (surprisingly) more off-kilter politics. While looking up how Biden is going to roll back Trump’s rollbacks of environmental protection, I came across this apparently massive change in California desert land management. Land that was very dear to me, with Joshua Tree smack-dab in the middle. This was the first time I dove headfirst in the maps and charts of the DRECP.
And let’s not forget that Trump tried to alter this plan right before his last day in office. The Trump Administration proposed an alteration to what’s allowed on California Desert Conservation Lands, on January 13th of 2021, right before the end of his era. This change would have opened up wide swathes of delicate ecosystems to… well, to not conservationally-friendly uses. About 2 million acres of California National Desert Conservation Land would have lost their protection.
I wanted to understand what had potentially been put at stake. 2 million acres sounded like a lot – but I also didn’t know if that was a lot compared to how much land might otherwise be safe. I needed to understand what the DRECP was all about. While going through the press releases, maps, and decisions, I had to start taking notes; at first just to keep track of the acronyms. I hope my notes are helpful to you in unravelling the many pages of planning and amendments that have happened. The one-sentence summary a few paragraphs above is a pretty accurate idea of the plan. The specifics of what would be allowed where were what interested me.
After reading everything and doing my best to understand it, I have to ask myself – Am I happy with this plan? And honestly, I pretty much am. At least at face value. We do need more space to manufacture or gather more clean energy. The land out along the 10 freeway (near the 62) is already used for some solar and much wind generation. If you’ve driven out along this stretch of desert roads, you’ve probably seen the 300-foot windmills with 150-foot blades, slowly spinning. Or the waves of blinking red lights that line the hillsides during the night. That’s certainly much less disruptive than some other forms of electricity generation.
Time to work my way through the executive summary, sometimes dipping into other documents for further clarification. This post is divided up into the sections that exist in the Executive Summary (ES, an initialism you’ll see more than once). A little below is a list of nearly 25 relevant acronyms, alongside a clickable table of contents. If you’re curious about any of the processes or planning, I hope this summary helps – I know that writing it helped me understand what was happening.
Table of Contents
Click the links to skip ahead in the summary
- Part One : Introduction
- Part Two : Decision
- Part Three : Alternatives
- Part Four : Public Involvement, Consultation, and Coordination
- Part Five : Approval
- Executive Summary of the plan : This is a 28 page document containing notes on the whole project, organized in a similar manner to the detailed 200+ page current plan. This document contains many maps and the salient points. There are also a plethora of acronyms.
- Joe Biden – Climate Plan – The section of Biden’s site that provides an overview of his climate plans and goals
- CalMatters Biden Overview
- DRECP Online Database
- Wildlife.CA Conservation Actions
- BLM announces draft of DRECP – The original BLM.gov announcement and summary.
Useful Acronyms and Initialisms
- ACEC – Area of Critical Environmental Concern
- BLM – Bureau of Land Management.
- CDCA – California Desert Conservation Area. The CDCA Plan is referred to as one of the main land use plans that the DRECP wants to amend.
- CDFW – California Department of Fish and Wildlife.
- CEC – California Energy Commission.
- CMA – Conservation and Management Action. These represent the management decisions and allowable uses in the LUPA. “The CMAs identify a specific set of avoidance, minimization, and compensation measures, and allowable and non-allowable actions for siting, design, pre-construction, construction, maintenance, implementation, operation, and decommissioning activities on BLM-managed lands.” [ES-15]
- DFA – Development Focus Area
- DRECP – Desert Renewable Energy Conservation Plan. This is the name of the plan as a whole, according to the current documents.
- EIR/EIS – Environmental Impact Report / Environmental Impact Statement
- ERMA – Extensive Recreation Management Area.
- ES – Executive Summary. An overview document summarizing the key points of the DRECP.
- ESA – the Endangered Species Act (federal).
- FLPMA – Federal Land Policy and Management Act.
- LUPA – Land Use Plan Amendment. A proposed change to a government’s current plan for land use.
- NHPA – National Historic Preservation Act
- NLCS – National Landscape Conservation System
- PA – Programmatic Agreement
- REAT – Renewable Energy Action Team. These are the agencies that work together to devise and implement the DRECP, otherwise known as REAT Agencies. These agencies are: the BLM, USFWS,
- RMP – Resource Management Plan. Referring to Bishop and Bakersfield, these RMPs cover much of the non-CDCA land being amended.
- ROD – Record of Decision. A document containing a record of decisions made on the DRECP.
- SRMA – Special Recreation Management Area
- USFWS – U.S. Fish and Wildlife Service.
- VPL – Variance Process Lands. These are lands where renewable energy production may be considered without a plan amendment.
Part One: Introduction
1.1 Background and Overview
The Desert Renewable Energy Conservation Plan (DRECP) is a collaborative, interagency landscape-scale planning effort covering 22.5 million acres in seven California counties — Imperial, Inyo, Kern, Los Angeles, Riverside, San Bernardino, and San Diego.ES-1
The Mojave and Colorado/Sonoran deserts are grand, wide, open spaces. They’re host to some pretty unique wildlife and flora, important cultural heritage, and more than a few military bases and mining sites. They’re also quite a draw for tourism and conservation efforts, to see and to manage all the land that these other elements rest on.
The land is also useful for renewable energy. I think we can all agree there’s a fair amount of sunlight in the Mojave desert. This is an easy place for solar energy, as the sky is clear of clouds around 50-70% of the time. Driving over on the 10 or 62, you’ll notice plenty of tall wind farms off on the mountainsides – and a fierce crosswind at the right time of day. Wind farms already exist here in large numbers, so it makes sense this might be a good place to put more.
The government of California has decided that it’s time to devote more of this desert land to renewable energy. I’m not sure if I agree with their methods yet (as I’m taking these notes while reading through the executive summary), so I’m keeping a skeptical eye out. At the end of the day, the DRECP is there to streamline the permitting of renewable energy projects on SoCal desert land. The plan also outlines how (and to what extent) the biological and cultural heritage of these places will be preserved. This plan focuses on the public-use lands in these seven counties.
As another note – The BLM’s land use plan amendment only covers BLM-managed land. They intend the LUPA to be a framework for other portions of the state to streamline their conservation and renewable energy efforts.
Recognizing the diverse values and resources found in the Mojave and Colorado/Sonoran desert regions, the REAT Agencies vision for the DRECP was to:ES-1
1. Advance federal and state natural resource conservation goals and other federal land management goals.
2. Meet the requirements of the federal Endangered Species Act (ESA) and Federal Land Policy and Management Act (FLPMA).
3. Facilitate the timely and streamlined permitting of renewable energy projects.
1.2 Planning Goals
The DRECP has two primary goals. One is to provide a streamlined process for the development of utility-scale renewable energy generation and transmission in the deserts of Southern California consistent with federal and state renewable energy targets and policies. The other is to provide for the long-term conservation and management of special-status species and desert vegetation communities, as well as other physical, cultural, scenic, and social resources within the DRECP Plan Area through the use of durable regulatory mechanisms.ES-2
The DRECP is setting out to balance two sides of a scale; there’s a wide swath of desert land that could be turned over to energy production and land transmission. All that construction (and the physical towers, panels, and wires they’re installing) will disturb or destroy the natural environment, which they should do as little as possible. However, an added bit of pressure – current energy production is both dirty (because it’s still a lot of fossil fuel burning) and insufficient (and potentially going to lead to more brownouts or blackouts during high use times).
The land already has a number of plans and managing entities that dictate where, what, and how construction can happen. The DRECP is meant to create a straightforward path for renewable energy planning and construction in areas that currently have other plans.
The DRECP-affected area is almost the entirety of the California Desert Conservation Area. In areas where the DRECP doesn’t cover the CDCA, it may still dictate some land use allocation decisions in the CDCA areas outside the DRECP.
(Whew… that was a lot of acronyms)
1.3 Planning Process
The BLM LUPA identifies California Desert National Conservation Lands based on those lands having outstanding ecological, cultural, and scientific values, consistent with the Omnibus Act. In addition to specific ecological, cultural, and scientific criteria for inclusion, several factors were considered that affect the context of “nationally significant” and “outstanding” resources and values, including development pressure, landscape intactness, scenic quality, BLM jurisdiction, and landscape linkages.ES-5
Step one, even for a government agency, is to identify the laws pertaining to the land and its use. There’s a slew of regulations and rights on land in California that need to either be followed or rewritten. That are also regulations on the federal level – such as lands identified under the National Landscape Conservation System (NCLS) – that can only be changed by an act of congress.
Once all the available lands had been identified, the BLM looked at the physical location of the sites, as well as their contents. The Approved LUPA identifies three main qualities for consideration when determining the potential future use of any of the DRECP land – renewable energy development, biological conservation, and recreation. On the side of renewable energy, the most compatible locations are those that have access to renewable sources (sunlight, wind), close to existing or planned transmission lines, and that have low biological resource value. For biological conversation, the BLM identified lands that are important to preserving the ecology and life of California Desert National Conservation Lands. And for recreational use, the BLM is looking to refine recreation designations based on input from citizens and significant agencies.
The Approved LUPA makes about 800,000 acres available for renewable energy use. Of that, 388,000 acres (606 square miles… about a 30 * 20 mile area) are designed a Development Focus Area (DFA) for renewable energy, which should be able to provide 27,000 MWs of energy using current technology. Renewable Energy DFAs are those that meet all the requirements – substantial energy generation potential, access to current or planned transmission, and low resource conflicts. For these lands, Conservation Management Actions have been prepared to streamline industrial-scale energy production.
The Approved LUPA also designates 3,956,000 acres (around 6100 square miles) of California Desert National Conservation Lands. On top of that, it allocates 6,527,000 acres of total conservation designations. These conservation lands (and their designated connecting areas) are meant to protect biological, cultural, and natural resource concerns. Connecting land is provided for wildlife to migrate across the desert or shift to adapt to climate change. CMAs have been prepared for these areas to protect these living resources. I find it significant that they’re making allowances for the future shift in acceptable living areas for wildlife. Already, we’re seeing the damage to Joshua Trees from small changes in climate.
Also in this plan are 2,691,000 acres (about 4200 square miles, or 60 * 70 miles) of Special Recreation Management Areas, and 903,000 acres of Extensive Recreation Management Areas. The plan highlights the importance of natural spaces in California Recreation, and protects this use.
Part Two: Decision
2.1 Description of the Approved LUPA
I’ll be straightforward, this section is mostly about maps. I’d recommend looking at the actual maps to ensure you find out the potential plans for any areas you enjoy. For my part, I’ll be doing more digging into the Joshua Tree area. At first blush, it seems that most of Joshua Tree National Park is a “legislatively and legally protected area.” On the west end of the park, there’s overlapping sections of CDNCL (Cali protected desert) and ACEC (critical environmental concern). However, just east of Twentynine Palms is a large swath of cornstalk-yellow BLM land that’s well inside the DRECP Plan Area… which, after examining the map(s) further, seems to also be a crossover of protected areas. It’s safe.
The biggest portion of Development Focus Area seems to be east on the 10, closer to the state border, north of the Chocolate Mountains (I have got to visit those).
|Total BLM LUPA Conservation Designations||6,527,000|
|Recreation Management Areas (SRMAs and ERMAs)||3,595,000|
|General Public Lands||419,000|
|DRECP LUPA Area Total||10,818,000|
The plan divides decisions into two main categories (if you don’t want to use the other categories listed earlier): Desired Outcomes and Allowable Uses. I think those are pretty straightforward.
The resources they’re looking at in the LUPA are:
- Biological Resources
- Air Resources
- Climate Change and Adaption
- Comprehensive Trails and Travel Management
- Cultural Resources and Tribal Interest
- Lands and Realty
- Livestock Grazing
- Recreation and Visitor
- Soil, Water, and Water-Dependent Resources
- Special Vegetation Features
- Visual Resources Management
- Wild Horses and Burros
- Wilderness Characteristics
Much of this chapter also reiterates that the Approved LUPA for the DRECP also covers some areas of the CDCA while identifying lands that are in the CDNCLs (I could probably do a whole sentence of acronyms…). This chapter also reiterates that the Land Use Plan Amendment can only affect what it’s allowed to affect, can’t change any rules that it’s not allowed to change, and doesn’t extend beyond the boundaries of its plan. It also does not contain management-level implementation decisions for specific areas.
Another note – the Approved LUPA only contains “minor modifications, clarifications, and boundary adjustments from the Proposed LUPA.” The Proposed LUPA had alternatives that they were willing to accept, and the Approved LUPA fits with those alternatives.
2.2 Protest Resolution
The BLM Director received 43 timely protest submissions. All but one of the protesting parties had standing and two submissions were dismissed because they did not contain any valid protest points…ES-16
Long story short, the BLM had 43 protests of one sort or another arrive on time to be counted. These were ACEC comments, protests, and public comments. One issue of note was that the Draft LUPA and Proposed LUPA were not made available in timely fashion for public comment (especially when involving the Areas of Critical Environmental Concern). To remedy this, the plan was made available and 60 extra days provided (this was back in 2016). On everything else, the BLM Director concluded that the BLM had followed all the laws, rules, and regulations, and that it had considered all the public input and relevant information.
2.3 Governor’s Consistency Review
In a letter dated January 7, 2016, the Governor’s Office did not identify any inconsistencies between the Proposed LUPA and any state or local plans, policies, or programs.ES-16
Part Three: Alternatives
3.1 Alternatives Considered in Detail
The Proposed LUPA allowed for 4 alternatives (5 if you count the “No Action Alternative,” where the then extant land use just stays as it is). Each alternative was meant to reflect a different balance to the conservation / energy question.
Alternative 1 – The California Desert National Conservation Lands are structured to emphasize intact landscapes and high scenic value. Development would proceed in low biological resource conflict areas.
Alternative 2 – Like Alt 1, this plan maximizes the CDNCL land area. It encourages energy development to have more siting and design flexibility.
Alternative 3 – A variation on Alt 1 that allows for more scientific uncertainty, both in energy development and CDNCL structuring.
Alternative 4 – A variation on Alt 2 that is built to emphasize carrying out the Western Solar Plan.
3.2 Alternatives Considered But Not Carried Forward in Detail
Many members of the public, involved agencies, and stakeholders came forward with other alternatives. Generally, they were incorporated into alternatives 1-4 (and sometimes #5), or were discarded for being too vague or too overreaching.
3.3 Environmentally Preferable Alternative
Alternative 3 (see section 3.1) is the Environmentally Preferable Alternative. However, the BLM determined that the Proposed LUPA met all their requirements and interests in a more effective way.
Part Four: Public Involvement, Consultation, and Coordination
4.1 Public Involvement
Short story even shorter – the BLM allowed The Public and other entities to make comments and raise protests. As an aside – public scoping is a term you’ll come across on occasion. This is essentially letting the public see what’s up for debate and finding out what they think.
4.2 Stakeholder Involvement and Other Outreach
The Stakeholder Committee was composed of individuals from local governments, environmental organizations, electric utilities, renewable energy industry associations, renewable energy project developers, a coalition of Native American tribes, and off-highway vehicle (OHV) associations.ES-19
The BLM consulted with numerous local agencies, such as:
- National Park Service
- USFWS (co-lead on Draft EIS)
- Department of Defense
- California Department of Fish and Wildlife (colead on Draft EIR)
- California Energy Commission (co-lead on Draft EIR)
- California Independent System Operator
4.3 Endangered Species Act Consultation
On August 16, 2016, the USFWS issued its Biological Opinion that the DRECP Proposed LUPA is not likely to jeopardize the continued existence of the aforementioned species or result in the adverse destruction or modification of designated desert tortoise critical habitat.ES-20
4.4 Native American Consultations
In addition to the conferences, other outreach included pre-meetings, numerous technical meetings, individual government-to-government meetings with the federally recognized Indian tribes, formal letters, emails, phone calls, and face-to-face meetings.ES-21
Part Five: Approval
In its entirety, I present this brief yet poignant chapter:
This ROD, as follows, approves the DRECP LUPA to the CDCA Plan, the Bakersfield RMP, and the Bishop RMP.ES-23
And on the page that follows,
INTENTIONALLY LEFT BLANKES-24
Thanks for stopping by! I hope you had a pleasant time checking out the plants. If you’re in the mood for more nature, please stay in touch!