Dec 11, 2015. Cal4Wheel has filed a protest of the recently released Desert Renewable Energy Conservation Plan.
After reviewing the documents, Cal4Wheel believes the DRECP, as modified from previous versions, is regressive and limits public participation in future site-specific/project level analysis opportunities. Cal4Wheel objects to the “ground disturbance” caps which are applied in an arbitrary manner. Such specific criteria is not appropriate for a “programmatic” document as they apply limitations that confine future projects in scope. Cal4Wheel believes the agency has exceeded the guidance for a programmatic document in developing the DRECP. The DRECP does make decisions – both inside and outside the WMRNP project area - to approve or deny specific projects based on the management prescriptions or caps assigned to the various “zones” (e.g. SRMA/ERMA/NLCS/ACEC/Conservation/Ground Disturbance Caps, etc.). That action does imply decisions on land use allocations, allowable uses, and management actions, which are beyond the “programmatic” scope of the document at a programmatic level.
A copy of the protest letter is available here.