The Destruction of Chaparral through "reforestation"
California State Parks and the managers at Cuyamaca Rancho State Park violated both the intent and the spirit of California's Environmental Quality Act (CEQA). They used a legal loophole (an emergency exemption), one that was declared invalid by the court in a similar situation, to avoid conducting a thorough analysis of a major habitat altering "reforestation" project that has had significant environmental impacts. The maneuver also excluded public comment.
In doing so, California State Parks violated its own guidelines - to preserve and protect representative landscapes that have been dedicated to the State Park system, to be managed as "composite wholes," and to allow such landscapes to recover naturally from occurrences such as fire. If you ask them why are they burning and grinding up the chaparral in Cuyamaca, they will label the natural, post-fire habitat with the derogatory term "brushfields," which they claim are hindering conifer regeneration and will slow the rate of forest succession. This is false and is exactly the same thing timber companies have claimed for years to justify turning early seral forests into tree farms. What they really mean to say is that state parks is getting millions of dollars in carbon credit dollars to plant trees and that they are impatient. The ecological damage they are causing to the park as a result is extensive.
The Five Basic Problems with the "Reforestation" Project
1. The Wrong Approach
2. Massive Soil Disturbance
3. Invasive Weeds
4. An Unnatural Mix
5. Carbon "Sequestration?"
Loss in Cuyamaca
The Details: Getting Rid of the "Invading" Chaparral
By causing disturbances to soil, streambeds, and the natural process of succession, California State Parks is violating its own mission - to preserve and protect representative landscapes that have been dedicated to the State Park system, to be managed as ecological wholes.
State Parks filed their CEQA exemption three months after we had filed our intent to sue San Diego County for the very same reason - the improper use of the emergency exemption clause (to start clearing more than 300 square miles of native habit in the backcountry without properly considering environmental impacts). County officials were likely in close consultation with the park. Here's the language used in the Parks' exemption:
"Adopt and implement vegetation restoration plan for fire-damaged areas of Cuyamaca Rancho State Park. Ninety-five percent of the park's mixed conifer forest was burned in the 2003 Cedar Fire, for which a state of emergency was declared by the governor."
This was exactly the same rationale the judge ruled against in our lawsuit against San Diego County. He found that a multi-year project to radically alter habitat is clearly NOT an emergency.
Report: State Parks Conducting Cuyamaca Project Contrary to Science
Wade Crowfoot, SecretaryCalifornia Natural Resources Agency1416 9th St., Suite 1311Sacramento, CA 95814EMAIL: http://resources.ca.gov/contact-us/
Governor Gavin Newsomc/o State Capitol, Suite 1173Sacramento, CA 95814EMAIL: https://govapps.gov.ca.gov/gov40mail/ ---------View our closed petition from 5 years ago to Governor Brown.
History of Actions/Events
There was quite an animated discussion on our Facebook page about the 2015 prescribed burn that provides good insight into how various interests view the practice. Unfortunately, we found many commented subjectively without actually examining the cited research they were criticizing. Here is the full discussion preserved as a pdf. November 14, 2014: State Parks Commission hearing met to approve the Draft Environmental Impact Report for the General Plan. The Plan mentioned the "reforestation project" a number of times, but failed to include any details necessary for the public to properly evaluate its impact. The Report was approved. The final document is available on the web. February 25, 2014: A prescribed burn in the Park below Stonewall Peak got out of control and burned trees that had survived the 2003 Cedar Fire.
November 12, 2013: A public meeting was held by State Parks to discuss the developing draft of a new Cuyamaca Rancho State Park General Plan. We requested that the "reforestation project" be addressed in the plan. Why? At 2,500 acres, the "reforestation project" is planned to be at least ten times larger than the emergency CEQA exemption permit that was issued five years prior. The contract for the work implies that even more acreage could be added.
With less than half that acreage having been altered, the reforestation project has already negatively impacted the Park by prescribed burns outside the original planning area, road expansion with its visual and runoff impacts, watershed damage from erosion from reforestation plots and roads, exotic plant invasion, wildlife habitat alteration (including a formerly open-water stream being filled in), and reduction in native plant abundance and distribution. The project has far more impact than any other activity already mapped and presented to the public in scoping meetings, and therefore must be included in the General Plan Update. The costs and benefits of the project can then be analyzed under CEQA and, in that process, also be opened for public comment. March 15, 2013: After digesting all the documents acquired through our Public Records Request, we unfortunately concluded that we could use the courts to challenge the current habitat destruction (termed "reforestation") project currently underway at the park.
Why? State Parks filed an emergency exemption on August, 2009, to develop a broad-based "vegetation restoration plan" for the park (meaning they didn't have to submit their plan for independent review by citizens and scientists). The description of the plan in the exemption document was one sentence long. This was a violation of the emergency exemption clause in the state environmental law because such exemptions apply to true emergencies like a dam is about to bust, or a building is about to fall into the ocean. A decade or more project does not qualify as an "emergency" as the courts ruled in our cause against San Diego County. Citizens only have 35 days to challenge these kinds of exemptions. We were unaware of the exemption until it was too late. December 23, 2012: Received from State Parks a CD containing a partial fulfillment of our request for information. State Parks indicated they would be providing more in approximately four weeks.
December 17, 2012: Sent State Parks an intent to file a Complaint for Declaratory and Injunctive Relief against the California State Department of Parks and Recreation for their failure to produce documents relating to the destruction of native habitat as part of their project. October 4, 2012: We submitted a Public Records Act request to State Parks for all documents relating to their "reforestation" project in Cuyamaca.