Imperial County’s sweeping industrial development plan promises a clean energy future. A coalition of community groups and scientists says the environmental review is riddled with failures.
The Salton Sea region sits on one of the world’s largest lithium deposits, a resource essential for electric vehicle batteries and the clean energy transition. Imperial County has drafted a major plan called the Lithium Valley Specific Plan (LVSP) to guide decades of industrial development in the area: lithium extraction, geothermal energy, manufacturing, data centers, logistics hubs, and more.
On the surface, this sounds like an economic opportunity and a climate win. But a coalition of environmental groups, community organizations, and researchers has filed formal comments arguing that the environmental review for this plan is deeply inadequate, and that it puts some of California’s most vulnerable communities at serious risk.
What is the Lithium Valley Specific Plan?
The LVSP is a sweeping land use document meant to govern how a large stretch of Imperial County, much of it along the southern shore of the Salton Sea, gets developed over the next three decades. While it’s framed around renewable energy and lithium recovery, it also opens the door to data centers, mega-warehouses, and other heavy industry. Some of these buildings could be up to 1.3 million square feet each.
Before a plan this large can be approved, California law (CEQA – the California Environmental Quality Act) requires a rigorous environmental review: an honest accounting of what harm the plan could cause and what can be done to prevent it. The coalition argues that the current draft falls far short of that standard in nearly every category.
Wildlife and wetlands are being undervalued
The entire project area sits within an Audubon Important Bird Area of Global Importance. Millions of migratory shorebirds, waterfowl, and songbirds depend on the Salton Sea as one of the last wetland strongholds on the Pacific Flyway. California has already lost an estimated 96% of its historic wetlands and the Salton Sea’s remaining habitat is irreplaceable.
The plan acknowledges it would affect only 3.2% of the Salton Sea. But that framing is misleading. The southern shoreline, where most of the development is planned, is the most ecologically productive part of the Sea. The shallow, muddy flats there are rich in biofilm, the primary food source for small shorebirds during migration. Losing or degrading this zone would have impacts far beyond what the percentage suggests.
The coalition also points out that the plan relies on a habitat assessment from 2002 – 23 years ago. The Salton Sea’s shoreline has receded far more rapidly than anyone predicted back then. Science from 2002 cannot adequately describe what is at stake today.
The air quality analysis ignores the people living here
Imperial County already has some of the highest particulate matter concentrations in California. The region around the Salton Sea has been designated an AB 617 community, California’s official recognition that a place bears a disproportionate pollution burden. Pediatric asthma rates here are well above the state average.
The environmental review models air emissions from the project but fails to connect those emissions to real health outcomes like asthma attacks, emergency room visits, and cardiovascular disease in the communities that would breathe them. It does not conduct a health risk assessment. It does not account for how multi-year drilling operations, diesel trucks, and dust from construction will compound the pollution burden that already exists.
Perhaps most critically, the analysis ignores climate change. Higher temperatures accelerate dust mobilization and ozone formation. Over a 30-year development horizon, failing to account for a warmer, drier future means the health risks are almost certainly being underestimated.
The water math doesn’t add up
The plan would convert large areas of agricultural land to industrial use. Today, water that drains off those farms flows into the Salton Sea, roughly 40,000 acre-feet per year. Once the land stops being farmed, that water disappears. The plan’s own water analysis estimates a reduction of about 16,400 acre-feet per year reaching the Sea.
What does that mean in practice? Less water means more exposed lakebed, or playa, which turns to toxic dust. The coalition estimates this reduction alone would expose roughly 2,900 additional acres of playa. At the cost California currently spends on dust suppression, that translates to about $88 million in new infrastructure costs. The plan does not acknowledge these costs, let alone propose that the developers who cause them should help pay for them.
The energy analysis overpromises
The plan bills itself as a clean energy project, but the energy analysis is built on shaky assumptions. At full buildout, the plan’s own numbers show that nearly all electricity generated on-site would be consumed on-site, leaving very little surplus for the grid.
Meanwhile, the plan includes data centers and hydrogen production facilities, two of the most energy-intensive uses that exist. The coalition cites federal research showing data centers already consume about 4.4% of all U.S. electricity, a figure projected to nearly triple by 2028. Describing these facilities as “not inherently energy intensive,” as the draft environmental review does, strains credibility.
There’s also the question of whether the local utility, Imperial Irrigation District, can even handle the demand. IID has publicly stated that 17% of its critical power assets have exceeded their useful life and estimates needing a $3.34 billion infrastructure investment over the next 15 years. The plan assumes IID can absorb massive new demand without significant strain, with no evidence to support that assumption.
A process that short-circuits community protection
One of the coalition’s most fundamental objections is structural: the plan designates enormous industrial uses, including those 1.3-million-square-foot logistics centers and data centers, as permitted by right, meaning future projects within those categories would require only ministerial approval, with no additional environmental review.
CEQA exists precisely to catch problems before they become irreversible. Allowing the largest, most impactful projects to skip that process defeats the entire purpose of the law. The coalition is asking that clear thresholds be established: any future project that would generate significant water use, air emissions, or greenhouse gases must trigger its own environmental review before it can be approved.
What our coalition is demanding:
- Redesign the plan to avoid placing industrial development in the most critical wetland and bird habitat
- Use current science, not 2002 data, to assess wildlife and water impacts
- Conduct a real health risk assessment that links emissions to health outcomes in affected communities
- Account for the water the Salton Sea will lose and require developers to fund dust mitigation
- Honestly assess energy demand, including from data centers and hydrogen facilities
- Require project-level environmental review for high-impact uses instead of rubber-stamping them
- Conduct a genuine environmental justice analysis of cumulative harms on frontline communities
The bottom line
No one in this coalition is opposed to clean energy or economic development in Imperial County. The region has long been underinvested, and its communities deserve jobs and prosperity. But a development plan of this scale, covering 30 years and thousands of acres along a fragile, shrinking lake, demands an honest accounting of its consequences.
As drafted, the Lithium Valley Specific Plan’s environmental review fails that test. It relies on outdated science, circular logic, and unsupported assumptions. It ignores the health of the people who already live with some of the worst air quality in California. And it sets up a process that could lock in decades of irreversible harm before anyone gets the chance to say stop.
The coalition is asking Imperial County to do what the law requires: take a hard, honest look and get it right before it’s too late.
The public comment period for the Lithium Valley Specific Plan environmental review has been extended to April 17, 2026 at 5:00 pm, but comments must be received by that time to count. This is your opportunity to tell Imperial County that this plan needs to get it right for the Salton Sea, its wildlife, and the communities that live here. Written comments can be submitted by email to publiccomment@co.imperial.ca.us or by mail to Imperial County Planning & Development Services Department, 801 Main Street, El Centro, CA 92243. Be sure to include “LVSP 2025” in the subject line of your email or on your envelope. Comments submitted any other way will not be included in the official record. Only written submissions to that email or address are accepted; oral comments and submissions sent elsewhere will not be considered.
Signed by Alianza Coachella Valley, Los Amigos de la Comunidad, Coachella Valley Parents, Lideres Campesinas, Imperial Valley Equity and Justice, Leadership Counsel for Justice & Accountability, Audubon California, Sierra Club CA/NV Desert Committee, and researchers at UCLA, Loma Linda University School of Public Health, and Brown University.
