The destruction of chaparral through "reforestation"
Above: Large stands of ceanothus cut down as well as dead tress which provide valuable habitat. The area is being prepared for a prescribed burn. See fire line to the left. Below: A short video summarizing the issue.
The Basic Issue
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, 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.
The Three Basic Problems with the "Reforestation" Project
1. An Unnatural Mix. California State Parks decided, unilaterally, that they were going to recreate a forest that had been there prior to the 2003 Cedar Fire, and which had sprouted hundreds of years ago when the climate was colder (adult trees are typically more resilient than tree seedlings). Park management wants Jeffrey and sugar pines, not Coulter pines. It's been Coulter pines that have been sprouting up in the post-fire landscape because the climate's warmer and Coulter pines are growing better with the new conditions. However, park management apparently thinks Coulter pines are undesirable, so they're using funds meant to deal with climate change (because the climate's warmer) to plant tree species that grew up in a colder climate.
This represents a logical contradiction.
2. The Wrong Method. We would have had no problems if park management decided to cut back a few ceanothus here and there to make small gaps, and used those gaps to plant tree seedlings. We would have probably assisted in a volunteer effort to help. However, chewing up the landscape with mastication machines is an extremely destructive alternative, and is based on the incorrect assumptions that post-fire ceanothus growth is unnatural, that growing saplings wouldn't be able to shade out the ceanothus in 20 years, that the ceanothus aren't providing anything useful on the slope, and that ceanothus are some kind of invading native weeds. These assumptions are reflective of the pervasive "shrubs bad, trees good" bias.
3. Carbon "Sequestration." Burning and removing native vegetation to sequester carbon is questionable at the very least. Who is counting the actual carbon and who is responsible for making sure there will be a net gain in carbon storage at the end of this project?
Cuyamaca managers are planting trees every 15 feet and appear to be trying to get most or all of these trees to grow to maturity to fulfill their multi-million dollar carbon sequestration contract. They're also planning to keep the tree farm "open" by lighting prescribed fires, which is in the re-vegetation plan they gave themselves the CEQA exemption to perform. This then poses a conflict. Assuming all those trees grow to maturity (which is questionable), they shouldn't thin them out if they want to follow their legal sequestration obligations.
2. WRITE A LETTER/EMAIL TO THE PARKS DIRECTOR with copies to the Secretary for Natural Resources and the governor. Ask them to stop the "reforestation project" at Cuyamaca Rancho State Park and require the Parks Department to conduct a full Environmental Impact Report for any additional reforestation activities as Parks should have done in the first place.
Lisa Mangat, Director California Department of Parks and Recreation 1416 9th St. Sacramento, CA 95814 EMAIL: firstname.lastname@example.org
John Laird, Secretary California Natural Resources Agency 1416 9th St., Suite 1311 Sacramento, CA 95814 EMAIL: email@example.com
Govenor Jerry Brown c/o State Capitol, Suite 1173 Sacramento, CA 95814 EMAIL: Contact
Getting Rid of the "Invading" Chaparral
In a misguided attempt to alter the natural post-fire succession process after the 2003 Cedar Fire in San Diego County, managers at Cuyamaca Rancho State Park are grinding up and burning large stands of ceanothus (which they consider an "unnatural invasion") and planting pine trees. The trees being planted are not preserving the "genetic integrity" of the natural ecosystem as many are from different populations and they do not match the natural variation of tree species at Cuyamaca. The species mix used and the manner in which they are planted reflects more of a commerical tree plantation than a natural forest.
Millions in dollars in grants from corporations are funding the clearcut/tree planting project for "carbon sequestration" (i.e. planting trees to remove carbon from the atmosphere). Ironically, the grinding and burning of the recovering chaparral and the trees killed in the project will release a significant amount of carbon. Reportedly, another 2,500 acres of ceanothus removal is planned. Professionals within the State Park system itself have objected to this project, but when millions of dollars have been contributed and a bureaucracy has been established, it can be extremely difficult to turn the tide.
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.
Avoiding Environmental Law
To skip the usual planning process, State Parks filed an emergency exemption to the California Environmental Quality Act (CEQA) on August 3, 2009 for their "Reforestation Project." This allowed them to avoid public comment, avoid requirements that they consider the environmental impacts of their project, and avoid input from outside experts to assist in considering alternative actions. When a government agency charged with protecting the state's natural resources fails to properly consider the environmental impacts of such a large, habitat altering project, it needs to be challenged by the public.
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.
We unfortunately missed our opportunity to respond because we were focused on stopping the county's clearance plans.
Here is 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 San Diego County used in their plan and the same one the judge rejected when ruling against the county in our case. He found that a multi-year project to radically alter habitat is clearly NOT an emergency.
Citizens only have 35 days to appeal an agency's use of a CEQA exemption, so we cannot pursue that course. However, we are investigating other options.
History of Actions/Events
October 4, 2012: We submitted a Public Records Act request to State Parks for all documents relating to their so-called "reforestation" project in Cuyamaca.
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.
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.
March 15, 2013: After digesting all the documents we have acquired through our Public Records Request, we have unfortunately concluded that we cannot use the courts to challenge the current habitat destruction (termed "reforestation") project currently underway at the park.
State Parks filed a emergency exemption back in August, 2009, to develop a yet-to-be-written, 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.
Citizens only have 35 days to challenge these kinds of exemptions.
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 ago. The contract for the work implies that even more acreage could be added.
Already, with less than half that acreage having been altered, the reforestation project has impacted the park by risk and actuality of burning unplanned areas during controlled burns, road expansion with its visual and runoff impacts on the Park, watershed damage from erosion off 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.
February 25, 2014: A prescribed burn in the park across from the Paso Picacho campground got out of control and burned trees that had survived the 2003 Cedar Fire.
November 14, 2014: State Parks Commission hearing 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.
Feb 4, 2015: Prescribed burn conducted on Middle Peak. Winter burns can cause significant ecological damage due to the fact that there is still moisture in the soil which turns to steam, potentially cooking the native seed bank. Also, winter is the time when many chaparral plants are most vulnerable because they are just beginning to send out new sprouts. More on this topic on our Prescribed Burns page.
There was quite an animated discussion on our Facebook page about the 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.
Without the clearcut. Healthy post-fire ceanothus stand on Middle Peak in Cuyamaca Rancho State Park prior to being "masticated" and burned.
Significant soil disturbance has been caused by the use of grinders and heavy equipment to "masticate" the ceanothus. A pine sapling can be seen in the foreground. The rectangular black piece of netting to the right of the sapling is to protect the plant from the sun. This is the second tree planting attempt. Significant losses of saplings reportedly occurred during the first try.
Looking down slope to the west, the ceanothus clearcut area is as far as the eye can see. The "masticated" remains of the original plants are the naked burned sticks coming out of the ground. In addition to the clearcutting treatment, the area was also burned prior to the tree planting. The ceanothus continues to resprout from the underground burls and germinates from new seedlings.
As with many vegetation "management" projects, the newly disturbed, exposed soil is fertile ground for invasive weeds. This patch is composed primarily of cheatgrass. During this initial visit we saw only a few areas compromised in this manner. However, there is a definite cause for concern that the weeds will spread further.
The smoke column from the February 4, 2015 prescribed burn on Middle Peak in Rancho Cuyamaca State Park.
Post February 4, 2015 prescribed burn. All of the native shrubs have been burned as well as many of the standing snags (dead trees). Note the rectangular black screen in the lower left. This is to provide shade for the planted conifer seen tipping over. The replanted conifers are between ten to fifteen feet apart.
Another ceanothus clearcut area on the west slope of Stonewall Peak as seen from Middle Peak. This area now has a significant number of invasive weeds.
California State Parks Conducting Project Contrary to the Best Available Science
Below are the conclusions of a study reviewing the post fire environment of Cuyamaca Rancho State Park.
Dense shrub cover, primarily Ceanothus palmeri, has established on about 40% of the area surveyed, especially in stands with higher former forest cover and fire severity. About half of these stands had lower shrub cover, averaging 32%, and half had high cover, averaging 70%. On a landscape scale I recommend no vegetation management of C. palmeri dominated stands. Ceanothus is a nitrogen fixing genus of California shrubs that serves an important ecosystem function, especially following fire on low-nutrient soils in California’s montane forests. These shrub stands will naturally thin over time, resulting in lower, patchier cover, and allowing establishment of conifers.
Site-specific removal of shrubs over small areas may be required for tree planting projects, but the disadvantage of Ceanothus removal, again, is that it may affect the availability of nutrients for successful tree establishment... In the stands examined that fell at lower elevations in the forested zone (1300-1400 m), shrub cover averaged around 60% and chaparral species dominated vegetation recovery, especially Ceanothus leucodermis. Again, Ceanothus plays an important nutrient cycling role post-fire in California ecosystems. These sites appear to be following a normal trajectory of succession for chaparral-dominated sites. There is no indication that vegetation management is required.