Best Sent by April 11, 205

Sample Email Response
Western Joshua Tree Conservation Act
FINAL Public Feedback!

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Thank You for your Support!

Try to send before April 11, 2025 but you can send it anytime!
ZOOM INFO for the April 16/16 FINAL Public Comment Meeting
(Register even if you cannot attend)

TO:

WJT@wildlife.ca.gov, fgc@fgc.ca.gov

BCC:

slaytonk@kerncounty.com, mcnamarad@kerncounty.com, simona@kerncounty.com, planning@kerncounty.com, zoning@kerncounty.com, aratina@avantus.com, WJT@wildlife.ca.gov , fgc@fgc.ca.gov, info@seia.org, cainfo@precisionresource.com, website@calssa.org, info@calmatters.org, publicadvisor@energy.ca.gov, tdp@cpuc.ca.gov, assignmentdesk@kqed.org, info@calssa.org, district1@kerncounty.com, district2@kerncounty.com, fgc@fgc.ca.gov , Fosterja@kerncounty.com, antonarosj@kerncounty.com, sandersk@kerncounty.com, saidib@kerncounty.com, ekapcd@kerncounty.com, loreleio@kerncounty.com, info@joshuatreeonfilm.com

SUBJECT LINE:

WJTCA does not stop the Deforestation of the Mojave Desert. It is just a fee schedule designed by/for the Solar Industry, bypassing CESA protections and punishing residential Homeowners.

BODY:

Feedback on the Draft Western Joshua Tree Conservation Plan

Summary: The current draft of the Western Joshua Tree Conservation Plan (WJTCA) is ineffective in protecting Joshua Tree forests and undermines meaningful conservation efforts.

1. Fundamental Weaknesses of the WJTCA

  • The WJTCA is a Pay-to-Play scheme. Its main function is to impose a fee schedule—it has no authority to stop even a single Joshua Tree from being cut down.

  • The WJTCA lacks enforcement power. Unlike the California Endangered Species Act (CESA), it cannot halt or deny destructive projects, including those by industrial solar developers.

  • The WJTCA incentivizes destruction. Solar developers are offered discounted “bulk rates” for removing trees en masse. This incentivizes the clear-cutting of entire forests. Where are the public records or minutes from the meeting that approved these discounts?

  • The WJTCA is inefficient and inequitable. It punishes homeowners with time-consuming, burdensome permit requirements—just to remove a single tree—while industrial projects can eliminate thousands with a single permit.

  • It is not scalable. The plan cannot handle thousands of individual homeowner requests efficiently, while it streamlines destruction for large projects.

  • The plan’s origin is flawed. It was modeled after an Emergency Order issued by Director Bonham, which allowed 15 solar projects to bypass all CESA protections without proper review. This was a dangerous precedent. Bonham should be held accountable for undermining CESA.

2. Erosion of Public Trust and CESA Integrity

  • CESA once offered real protection. On September 22, 2020, Joshua Trees had enforceable protections under CESA, which had the power to halt harmful projects. That protection was gutted by the Emergency Order.

  • The process has damaged CESA’s credibility. Despite being a CESA-listed species, Joshua Tree forests continue to be bulldozed. This is a public relations disaster for the state’s endangered species protections.

  • The WJTCA favors industry voices. Fish & Game has met with solar industry representatives but ignored homeowners. This is evident in public forums, where solar interests are now silent—likely because they’ve already been accommodated—while homeowners continue to voice concerns.

3. False Solutions: Transplanting and Replanting

  • Transplanting is greenwashing. In Fish & Game’s own data, transplanted Joshua Trees had a 64% mortality or poor health rate after just two years.

  • Seedling reforestation doesn’t work. In the science-based well-managed Cima Dome project, 80% of Joshua Tree seedlings died within two years.

  • You cannot recreate a Joshua Tree forest. The only proven way to protect these forests is to leave them intact.

4. Better Models and Legal Protections Exist

  • Arizona protects its desert species. In Arizona, it is a felony to cut down a Saguaro Cactus. Developers would never risk jail time or fines to bulldoze Saguaro fields. But homeowners can still apply for a permit to remove plants from residental property. This approach truly protects forests!

  • California can adopt a similar model. We need strong, enforceable protections for Joshua Trees, with appropriate allowances for homeowners—not a policy that sacrifices forests to corporate convenience.

Conclusion:

The WJTCA is a weak and inequitable plan that prioritizes industry interests over ecological integrity and community concerns. It offers no real protection to Joshua Tree forests, undermines public trust, destroys the reputation of CESA and attempts to pass off ineffective mitigation strategies as conservation. A meaningful conservation plan must include enforceable protections, public accountability, and a commitment to ecological science—not just a fee schedule.

 
 
 
 

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