Why landscape-scale planning and early Tribal engagement can improve energy development.
By the time an archaeological survey begins, some of the most consequential decisions affecting cultural resources may already have been made.
A developer has identified a property. Preliminary engineering has established a preferred layout. Access roads and transmission connections are being considered. Project schedules and financial assumptions may already depend on the selected location.
Archaeological investigations and Tribal consultation can still influence those decisions. But the flexibility to avoid sensitive places may be considerably narrower than it was during initial planning.
What if cultural-resource considerations entered the process before individual project boundaries were established?
California’s approach to regional energy planning offers an opportunity to examine that question.
Looking Beyond Individual Project Sites
Project-level environmental review generally focuses on a defined undertaking or proposed development.
Landscape-scale planning begins with a different perspective.
Rather than asking only what cultural resources might be affected by a particular project, regional planning can consider broader patterns of land use, environmental sensitivity, cultural landscapes, and potential development conflicts.
This distinction matters for energy development.
Energy production facilities, transmission corridors, pipelines, access roads, and associated infrastructure can affect extensive areas. Their impacts may extend beyond individual archaeological sites to include culturally significant landscapes, traditional places, access routes, and relationships between communities and their ancestral lands.
Identifying these considerations earlier can create opportunities to evaluate alternatives before substantial commitments have been made.
However, regional planning presents its own challenges. Cultural significance cannot always be represented through conventional archaeological site records or generalized GIS datasets.
And information that is useful for planning may also be culturally sensitive.
A California Example: San Joaquin Valley Solar Planning
In May 2026, the California Energy Commission (CEC) presented information about regional approaches to incorporating Tribal cultural-resource considerations into renewable-energy planning.
One example was the San Joaquin Valley solar-planning initiative, which examined potential least-conflict areas across approximately 9.5 million acres in eight counties.
The effort brought together agencies, agricultural interests, conservation organizations, industry representatives, and Tribes.
Its approach to Tribal cultural resources included early consultation, virtual and in-person meetings, and Tribally led information gathering and GIS mapping.
Tribal participants also reviewed the resulting information before approved findings were incorporated into publicly available planning materials.
This is an important distinction from planning approaches that rely exclusively on existing archaeological inventories.
Previously recorded archaeological sites represent only part of the cultural landscape. Survey coverage varies, archaeological records may be incomplete, and many places of cultural importance are not identifiable through conventional archaeological methods.
Tribally led information gathering can contribute knowledge and perspectives that would otherwise be missing from regional planning.
An important component of this approach is Tribal participation in determining how cultural information is used and what may be publicly disclosed. The CEC presentation identifies Tribal review and approved publication as part of the planning process. This illustrates how landscape-scale planning can incorporate culturally sensitive information without requiring unrestricted public access to the underlying data.
Earlier Planning Does Not Replace Project-Level Review
Regional planning can provide valuable context for development decisions, but it is necessarily broader and less detailed than investigations conducted for individual projects. Understanding that distinction is essential to using landscape-scale information appropriately.
Regional datasets have limitations. Cultural landscapes may extend beyond mapped boundaries. New information may emerge through consultation, archaeological investigation, or changes in project design.
For federal undertakings subject to the National Historic Preservation Act, Section 106 requirements remain applicable regardless of earlier regional planning. Similarly, projects subject to the California Environmental Quality Act (CEQA) must address applicable environmental review requirements, including consideration of historical resources and Tribal cultural resources.
Landscape-scale planning does not replace project-specific cultural-resource identification, evaluation, impact assessment, or consultation required under applicable federal and state law.
Instead, regional planning can help identify potential conflicts and inform the evaluation of development alternatives before individual projects are fully defined.
The value of early planning is not that it eliminates subsequent review. It is that better information earlier in the process may create more opportunities for avoidance, thoughtful design, and meaningful consideration of alternatives.
What This Means for Project Development
For developers and environmental consultants, early cultural-resource planning can improve the quality of initial decisions.
It can help identify issues that warrant additional investigation before property acquisition or engineering commitments become difficult to change.
It may also reduce the likelihood that significant cultural-resource concerns first emerge when project schedules are already under pressure.
For Tribes, earlier engagement can provide opportunities to influence broader planning decisions rather than responding only to individual proposals.
But these benefits depend on meaningful participation.
Early outreach alone is not sufficient if the planning process cannot accommodate Tribal recommendations or if sensitive information is collected without appropriate agreements governing its use.
The objective should be to develop planning approaches that are technically useful, culturally informed, and responsive to the communities whose ancestral landscapes may be affected.
Better Decisions Begin Before Project Design
Meeting California’s energy needs will require substantial infrastructure development.
Meeting those needs while protecting cultural resources demands more than increasingly sophisticated archaeological investigations after project locations have been selected.
It also requires considering cultural landscapes, Tribal knowledge, and potential development conflicts during earlier planning.
The San Joaquin Valley example demonstrates one approach to incorporating Tribally led information gathering and spatial analysis into that process.
It does not eliminate the need for subsequent Section 106 or CEQA review where applicable, nor does it resolve every challenge associated with sensitive cultural information.
But it illustrates an important principle.
The most effective opportunity to avoid a cultural-resource conflict may come long before anyone draws the final project boundary.
Further Reading
California Energy Commission. Tribal Affairs Roundtable 11, May 12, 2026. Publicly docketed May 28, 2026, TN 270325. See presentation slides 90–92 for the San Joaquin Valley example and slides 99–101 for advance planning. CEC Public Docket — 25-OIIP-01.
Advisory Council on Historic Preservation. Section 106 Regulations, 36 CFR Part 800. ACHP — Section 106 Regulations.
California Environmental Quality Act. California Public Resources Code, Division 13, and CEQA Guidelines, including provisions addressing historical resources and Tribal cultural resources.