It’s been a couple of months since the community rallied together to voice our concerns regarding the U.S. Marine Corps’ new Special Use Airspace (SUA) proposal, R2509, over Johnson Valley. As we mentioned after thousands of you took action, we’re now in a “waiting” period— which has been exacerbated by the government shutdown. However, since that time, the Marine Corps Air Ground Combat Center in 29 Palms released fact sheets (1,2) regarding their proposal.
We appreciate the Marines’ willingness to share information with the public and their continued commitment to national security and safe training operations. Their mission is essential, and we approach these conversations with full respect for the role they serve.
At the same time, the recreation community, local businesses, and event organizers have a responsibility to carefully review how these proposals may affect public access, the community, safety, and long-standing shared-use arrangements in Johnson Valley. After studying the Draft Environmental Assessment and comparing its contents to the Marine Corps fact sheet, we identified several places where the public messaging does not align with the details in the environmental documents.
Our goal is not to criticize, but to provide clarity.
Respectful disagreement is part of the public process, and we’ve prepared a point-by-point comparison to help our members understand what the EA actually proposes, where key uncertainties exist, and what still needs to be addressed before long-term decisions are made. With government agencies back open, our intent is to ensure that every stakeholder—including the Marines—has accurate information and that the shared-use principles established by Congress are upheld.
Below, you’ll find a straightforward breakdown of the claims presented in the fact sheet and how they compare to what the EA itself describes.
Thank you for staying engaged and for helping protect responsible recreation in Johnson Valley.
Johnson Valley: Claims vs Reality
Activation Days
MARINES: “The Marine Corps would only activate the Restricted Area (RA) over Johnson Valley for up to 60 days per year, often coinciding with pre-scheduled closure periods for military training.”
BRC RESPONSE:
The Draft EA describes the establishment of permanent SUA over Johnson Valley. The “up to 60 days” limit only appears buried in Appendix E and is not incorporated into the actual Preferred Alternative narrative. The purpose and need section of the EA states, ““The purpose of the Proposed Action is to provide permanent SUA above and adjacent to the Combat Center to support current and future training activities 365 days per year.” If it is in fact only up to 60 days as appendix E states, the purpose and need section needs to be amended.
Airspace Altitude
MARINES: “The floor of the airspace would be set at an altitude compatible with recreation when the Shared Use Area is open to the public.”
BRC RESPONSE:
The EA never defines what altitude is considered “compatible with recreation” or provides an enforceable floor elevation. It leaves the decision to “dynamic procedures,” giving the Marines discretion to set the floor, including at surface level, at any time. The lack of defined altitude limits for “compatibility” creates uncertainty and risk for helicopter operations, drones, and event filming in Johnson Valley.
Recreation Protection
MARINES: “The Marine Corps is committed to honoring the shared aspect of the Johnson Valley Shared Use Area and minimizing disruption to recreation activities.”
BRC RESPONSE:
The Draft EA fails to analyze recreation as a distinct impact area. There is no quantification of economic loss, event disruption, or public access implications for Johnson Valley users. Statements of intent are not substitutes for enforceable commitments. BRC and partners have repeatedly requested that recreation impacts be formally analyzed and mitigated, not merely addressed with public-relations assurances.
The National Defense Authorization Act of 2024 explicitly creates a “Resource Management Group to develop and implement a public outreach plan to inform the public of land use changes and safety restrictions affecting the withdrawn areas.” We have not seen transparency from this group to gather feedback in the past several years. This proposal is not compliant with the law which also, “requires the Shared Use Area to be used for public recreation and natural resources conservation.”
365 Days vs. 60 Days
MARINES: “The EA’s Preferred Alternative (Alternative 2) would support training 365 days per year while limiting R-2509 activation to 60 days.”
BRC RESPONSE:
These two statements are contradictory. The Preferred Alternative explicitly says the SUA system would support training 365 days per year, which means the infrastructure and regulatory authority would exist continuously. Without explicit language limiting activation, the “up to 60 days” is advisory, not binding.
Future Activations
MARINES: “Regardless of any future adjustments to activation days, recreation access will be preserved through established dynamic floor procedures.”
BRC RESPONSE:
This statement anticipates the potential increase of activation days beyond 60, confirming that expanded use is contemplated. “Dynamic floor procedures” are not defined or legally enforceable; they are operational policies that could change without additional environmental review. This suggests an incremental expansion of restrictions once the permanent SUA is approved.
King of the Hammers
MARINES: “The proposed airspace will not impact King of the Hammers (KOH) helicopter or drone use and we will continue to coordinate with Hammerking Productions.”
BRC RESPONSE:
The Draft EA includes no analysis of KOH’s operational needs, flight corridors, or economic contributions. The claim of “no impact” is unsupported by data or modeling. Coordination promises are informal and cannot replace enforceable conditions or memoranda of understanding protecting event operations. Without defined procedures, future conflict with FAA or training schedules is likely.
Medevac Access
MARINES: “Medevac access will not be compromised; training will be suspended if needed to facilitate emergency aircraft.”
BRC RESPONSE:
The EA provides no time-bound guarantee for medevac clearance and does not include simulation or response-time analysis. “If needed” and “facilitate coordination” are discretionary phrases, not binding standards. Given the scale of the proposed SUA, there must be written, enforceable protocols guaranteeing immediate clearance for emergency aircraft at all times.
Old Environmental Review
MARINES: “Effects were already analyzed in the 2012 EIS and were found to have no significant impacts.”
BRC RESPONSE:
The 2012 EIS already addressed Marine Expeditionary Brigade (MEB) training, but airspace conditions have changed significantly since then, including FAA’s Southern California Metroplex redesign and increased civilian air traffic (EA §3.2). The Marines’ reliance on outdated modeling fails NEPA’s requirement to use current data reflecting the changed airspace environment. A new or supplemental EIS, not a limited EA, should be required.
Temporary Flight Restriction (TFR) Justification
MARINES: “TFRs cannot be used for planned training because they are reactive, not proactive.”
BRC RESPONSE:
Temporary Flight Restrictions (TFRs) are already the standard FAA mechanism for time-limited military training and special events across the U.S. The claim that TFRs are “incompatible” is overstated, the FAA frequently issues recurring TFRs for predictable operations. TFRs provide accountability, transparency, and public notice, something permanent SUA lacks.
Safety & Predictability
MARINES: “Permanent SUA would improve safety for military and civilian pilots by providing predictable charted boundaries.”
BRC RESPONSE:
While charting can improve predictability, the proposal simultaneously removes flexibility for recreation and general aviation and grants permanent control to the Marines. It shifts Johnson Valley from a shared-use model, defined in the 2014 National Defense Authorization Act, to a military-first regime with no sunset provision or periodic review.
FAA Coordination
MARINES: “The Marine Corps has worked closely with the FAA and other stakeholders to develop several proposals for Permanent SUA.”
BRC RESPONSE:
The EA states, “The FAA is the agency with jurisdiction by law and special expertise with respect to changes” We are unsure why the Marines are conducting the NEPA analysis when the FAA has jurisdiction. BRC is also unaware of who the stakeholders are that the Marine Corps has worked closely with. We do not believe motorized recreation users have had their voices heard and have not been considered stakeholders.
