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ARTICLES

 

 

 

BLM's proposed Review of DRECP
is a bad idea

March 13, 2018
by Lisbet Thoresen
Public Lands Representative for San Diego Mineral & Gem Society, Inc.
Chair, PLAC-South, California Federation of Mineralogical Societies, Inc.
(updated 3/19/2018)

#DRECP 

 

Two things Rockhounds can do –
1.) Write or sign onto a comment letter
2.) Attend the BLM's Special DAC meeting in Victorville on 3/20/18

Comment Period Deadline: March 22, 2018
Rockhounds, get your name on a letter
and say NO to opening a Review of DRECP …

BLM opened a 45-day comment period on February 2nd. Rockhounds have until March 22nd to submit letters.

SDMG has prepared a detailed comment letter
(https://goo.gl/kNbkiM)
telling BLM "No to a DRECP Review."

If you or your club would like to sign onto SDMG's letter,
we need to hear from you ASAP
download a "how to" flyer (2 easy steps) »

 

 

If you want to write you own letter,
email or post it to BLM by March 22, 2018

  • BLM-California State Director
    2800 Cottage Way
    Rm W-1623
    Sacramento, CA 95825

  • Written comments also are accepted electronically at: BLM_CA_DRECP@blm.gov

 

For more information on DRECP, contact:

Jeremiah Karuzas
Renewable Energy Lead
2800 Cottage Way
Rm W-1623
Sacramento, CA 95825

916-978-4644 or jkaruzas@blm.gov

 

SOME USEFUL RESOURCES

What's the difference between
a great letter,
a good letter,
and a bad letter »

Want to write your own letter?
Things you should know about DRECP and some tips on making comments »

Why opening DRECP to Review is unnecessary and could be bad for Rockhounds »

What did Rockhounds get in DRECP?
What are the misconceptions about what it did not do?
Download a Rockhound Fact Sheet »

 

BLM Schedules Special DAC meeting
Agenda: DRECP Review
March 20, 2018, noon to 5PM

Hilton Garden Inn, Mirage Room
12603 Mariposa Rd.
Victorville, CA 92395

BLM needs to hear one simple message from Rockhounds –
NO to the DRECP Review.

Lisbet Thoresen plans on attending the DAC meeting to tell BLM "Leave the DRECP alone." If you cannot attend the meeting but would like to add your voice to the chorus, email editor@sdmg.org with your name, city and club affiliation.

 

 

Who opposes the DRECP Review?

Karen Douglas
Commissioner, California Energy Commission (one of the original architects of DRECP)

 

John Laird
California Secretary for Natural Resources Agency

 

California Desert Coalition and Bodie Hills Conservancy

 

Vet Voice Foundation

 

The Pew Charitable Trusts

 

Alliance for Desert Preservation (A4DP)

 

Mojave Communities Conservation Collaborative (M3C)

 

Newberry Springs Economic Development Association

 

Lucerne Valley Economic Development Association

 

Lucerne Valley Museum and History Association

 

National Parks Conservation Association

 

… and many other conservation groups

 

 

 

BLM schedules
a special meeting of the Desert District Advisory Council (DAC)

March 20, 2018
noon to 5PM
Rockhounds, the DAC is your liaison to BLM –
Ask the council how amending the DRECP
would provide more opportunities for recreational users
than they can ask for now without a review.

Location:
Hilton Garden Inn, Mirage Room
12603 Mariposa Rd.
Victorville, CA 92395

noon to 5PM
2PM - CDCA presention (DRECP)

BLM's Desert District Advisory Council (DAC) will hold its first meeting in over one year. The DRECP Review prompted the special meeting. Rockhounds, attend the meeting to learn more about the proposed Review to amend the DRECP, take the opportunity to speak on record and ask the DAC questions about the Review process. You can tell them what you think about it, too.

According to BLM's press release, the Review has one stated objective: provide more opportunity (i.e., land) for more renewable energy projects. That means land designated for other Stakeholders has to be re-designated for Industry, which risks upending the compromise it took 8 years to achieve among 50 Stakeholder groups. Providing more renewable energy opportunities in and around recreation areas also means more intrusion of utility-scale projects into unspoiled wildlands and viewscapes.

The California Energy Commission has already told BLM that it does not need more renewable energy opportunities at this time.

Rockhounds do not need the Review to ask for accommodations beyond those the DRECP currently allows. Let's move forward.

Download the DAC meeting agenda »

Download a Fact Sheet on What Rockhounds got in DRECP, misconceptions about what DRECP did not do, and what amending DRECP could mean for Rockhounds »

Things you should know about DRECP and some tips on making comments to BLM ».

Download the BLM press release on the March 20 DAC meeting »


 

What is DRECP?

 

The Desert Renewable Energy Conservation Plan (DRECP) is the largest land use plan amendment in California state history. It is a 12,000-page programmatic guideline for management planning of federal lands in California's deserts. Its objective is to balance multiple uses and conservation goals with renewable energy (RE) development. Its scope encompasses coordination with private landowners to build RE projects. DRECP is not itself a management plan – it is a top-level guideline for spelling out the details that go into each and every management plan covering different areas within the plan's boundaries. (Rockhounds will have to stay engaged and participate in the preparation of individual management plans as they are developed over the next 25 years.)

After more than eight years of planning and tough negotiation among many Stakeholders who have competing interests over the same areas, DRECP achieved a difficult balance. Like any compromise, no one got everything they wanted, but copius inputs from 50 Stakeholder groups and the public, including 16,000+ letters submitted to DRECP, influenced how the Record of Decision (ROD) was crafted. The ROD was published on September 14, 2016.

 

DRECP has two parts. Conservation and recreation received first consideration in the Phase I implementation. Within the 22.5 million acres covered under DRECP, 3.6 million acres were designated for recreational uses, including Rockhounding (aka "hobby collecting"). "Development Focus Areas" (DFAs) in the Draft DRECP were modified in the ROD to accommodate recreational uses, including Rockhounding, specifically.

The ROD designated 400,000 acres of DFAs on federal lands for renewable energy. Phase II Implementation focuses on fast-track permitting of 500 renewable energy projects over the next 10 years (from the date of the ROD, 9/14/2016). The California Energy Commission, which is one of the original architects of DRECP, has said this goal is adequate to meet the state's energy needs through 2040.

BLM proposes DRECP Review (FR Doc. 2018-02098, February 2, 2018). BLM is now under enormous pressure from Industry advocates with support from Executive Order 13783 to revise DRECP to create more opportunities for renewable energy development. The California Energy Commission, which was one of the architects of DRECP and helped calculate California's renewable energy needs through 2040, has told BLM that amending the plan is unnecessary. In a March 5th press release, John Laird, California Secretary for Natural Resources Agency, wrote:

"Reopening the plan is a waste of time and resources that will result in uncertainty, delay, and litigation. Reopening will stall renewable energy projects on public lands and impose major new costs on stakeholders without benefit. Instead, BLM should work proactively with the state, local governments, tribal leadership, and other stakeholders to implement the plan effectively and resolve issues with implementation as they arise." [read the whole letter]

The DRECP is here to stay. It will be the prevailing guideline for land use management planning, whether or not BLM's proposed Review goes forward. Either way, BLM is committed to renewable energy development in California's deserts, so Stakeholders concerned with preserving natural features and cultural resources in their deserts can look forward to having to defend them against industrialization well into the foreseeable future.

 

There is no upside for Rockhounds,
if BLM opens DRECP to Review,
but there is risk of downside.

BLM's goal in amending the DRECP has only one objective: to make available more land for developing industrial-scale renewable energy projects and commercial mining. That will require land designated for other Stakeholders having to to be re-designated for Industry. Doing that is almost sure to unravel the fragile compromise it took eight years of tough negotiation to achieve among 50 Stakeholder groups.

DRECP has only begun to be implemented, so there are no data to provide either quantitative or qualitative references to justify amending the plan at this time, much less to provide help identifying what kind of amending would make sense. While BLM appears to be focusing on conservation designations to achieve its goal, other Stakeholders should not expect to escape unscathed. There is no such thing as surgical targeting when there are 50 Stakeholders involved who are perpetually competing for the same land.

For one thing, opening DRECP to review will not give rockhounds more accommodations than they can ask for currently without a review. However, it could make them vulnerable to losing accommodations or eroding quality of life values they enjoy now. It should be obvious that providing more renewable energy opportunities in or around recreation areas would mean more intrusion of utility-scale projects into unspoiled wildlands and viewscapes that all desert lovers cherish. Conversely, preserving the DRECP means preserving quality of life values, whether you're a resident or a visitor to the desert. The plan preserves the local economies of gateway communities which are powered by a well-managed landscape to support tourism.

Let's not risk shattering the compromises that got Rockhounds what they asked for in DRECP by re-opening it to review at this time.

 

What DRECP ROD did for Rockhounds
and what it did not do.

There are some misconceptions and inaccurate information floating around the web about the constraints imposed on recreational users by the DRECP ROD. In fact, Rockhounds obtained significant accommodations based on numerous comment letters on the Draft DRECP (2/23/2015), with Development Focus Areas (DFA) and other potential encroachments by possible Industrial projects removed or redrawn where adjacencies or overlaps created potential conflicts. See: Exhibit 2 in SDMG's comment letter at: https://goo.gl/kNbkiM (short URL). Conservation and Recreation were big winners at the expense of Renewable Energy under DRECP's allocations. Recreational designations (SRMA and ERMA) were created which had not existed previously.

Here are some specifics on what Rockhounds got* –

  • BLM eliminated at least two proposed DFAs that would have conflicted with rockhounding activities (Lonely Butte and Brown Hill), and has also clarified that rockhounding is an allowable activity in Special Recreation Management Areas (SRMA). Proposed DFAs around Brown Butte and Gem Hill were eliminated to allow continued access to these sites.
  • The SRMA in the Amargosa/Grimshaw area was expanded to include Sperry Wash, which is popular for rockhounding. The designated route remains open to allow for responsible access for rock collecting and other recreation activities.
  • The DRECP did not close designated routes in the Mojave Trails (Route 66) area, so access remains open to popular rockhounding sites such as Chambless.
  • Designation of the Savahia Peak Rock Collection Area along Highway 95 in the Chemehuevi Valley. The management prescription for this area recognizes that "[t]his area is heavily dependent on the use of motorized-vehicles to access the area due to its remoteness, while the recreation action is hiking areas seeking out that one perfect specimen to add to one's own collection." The open designated routes will conform to the Northern and Eastern Colorado Desert Coordinated Management Plan 2002.
  • Some SRMAs overlap National Landscape Conservation System (NCLS) lands to provide emphasis on recreational values in management plans. However, where SRMAs do not overlap with NLCS lands, the DRECP still allows for continued use of designated routes for recreational activities that do not conflict with the values of the NLCS lands. (See page II.3-225 of the Final DRECP)

Here are some things DRECP DID NOT DO and does not require a Review to change –

  • To date, BLM has not restricted hobby collecting anywhere in DRECP's recreation- or conservation-designated areas, and previously existing routes of access to collecting areas have not been closed. (Drafting of management plans will determine what's permissible where – this is where Rockhounds should direct their focus: provide input during the management plans drafting process.)
  • A Review is not required for BLM to accommodate specific recreational uses in conservation-designated areas, for example, Rockhounding is allowed in the Area of Critical Concern (ACEC) in the Cady Mountains, now within the Mojave Trails National Monument.
  • To date, not a single open ORV route has been closed under DRECP.
  • DRECP does not have to be re-written for BLM to be able to revise its travel management plans.
  • To date, no mining claims for locatable minerals of interest to Rockhounds have been rescinded or rejected.
  • To date, none of the areas with recreational designations within DRECP's boundaries have been withdrawn from mineral entry.
  • The proposed mineral withdrawal of ca. 1.3 million acres within DRECP's boundaries (FR Doc. 2016-31231, 12/28/16) was prompted under the previous administration by some conservation groups concerned with large-scale mining on CDNCL-designated lands. The withdrawal was cancelled on 2/9/2018. (If the DRECP Review goes forward, conservation groups will almost certainly use the opportunity to fight for getting the mineral withdrawal restored.)
  • To date, not a single lawsuit against DRECP has been filed.

* Input provided by Shaun Gonzales.

 

DRECP is here to stay. It will be the prevailing guideline for land use management planning, whether or not BLM's proposed Review goes forward. Either way, BLM is committed to renewable energy development in California's deserts, so Stakeholders concerned with preserving natural features and cultural resources in their deserts can look forward to having to defend them against industrialization well into the foreseeable future.

Under any circumstance, DRECP's implementation must conform with existing federal statutes such as the Federal Lands Policy and Management Act of 1976 (FLPMA)(43 U.S.C. 1714), the National Environmental Policy Act of 1970 (NEPA), the Mining Act of 1872, and other applicable laws.

 

 

Some documents and resources on the DRECP Review

Fact Sheet on What Rockhounds got from DRECP and misconceptons about what DRECP did not do (3/13/2018)

Flyer with FAQS on DRECP and tips for writing effective comments on BLM's proposed Review

BLM Press Release on DAC Meeting scheduled for March 20, 2018, Victorville, CA (3/12/18)

BLM's schedule of public meetings on DRECP (2/8/18)

BLM Press Release on DRECP Review (2/1/18)

Federal Register notice on the DRECP Review (2/2/18)
https://www.federalregister.gov/d/2018-02098 (short url)
(Federal Register Document Citation: 83 FR 4921
Docket Number 2018-02098)

 

 

Cite this article: L. Thoresen. 13 March 2018. BLM's proposed Review of DRECP is a bad idea. San Diego Mineral & Gem Society, Inc. Available online at: http://www.sdmg.org/articles/201803/BLMs-proposed-DRECP-review-is-a-bad-idea.

When you tweet this article, use the hashtag #DRECP. 

 

 

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