- Major Threat to Nature in California - 1/3rd of state targeted for habitat clearance
Your right to challenge clearance projects may be taken away
CalFire plans to grind, burn, graze, and herbicide up to 2 million acres of natural habitat in California per decade under their proposed program.
The California Board of Forestry and CalFire released a proposal to target about 38 million acres (1/3rd of the entire state) to be burned, chewed-up, or sprayed with herbicides. This increases its habitat clearance program five times over current levels. If approved, the proposal will exempt individual clearance projects from the citizen and independent scientific oversight that is currently required under the California Environmental Quality Act (CEQA).
The comment period on the proposal ended February 25, 2013. We submitted a detailed letter along with a petition with 3,080 signatures (with citizen comments) that called on the Board of Forestry to retract its proposed habitat clearance program and to instead to work with the California Natural Resources Agency and the Senate Committee on Natural Resources and Water to create a Comprehensive Fire Protection Program that:
- focuses on actual assets at risk rather than habitat clearance - preserves the rights of citizens to object to destructive projects - incorporates the most current science - understands the difference between forests and other ecosystems
We are waiting to hear back from the Board of Forestry. To stay up to date on this matter please go to our CONTACT page and sign up on our email list.
and finally our February 25, 2013 Addendum to our comment letter. We expanded on our comments regarding legal issues, type conversion, and the importance of actually incorporating citizen input into the planning process.
Here are some of our basic points we made in our comment letter: 1. We Requested the Board of Forestry to retract the Vegetation Treatment Program Program EIR (Environmental Impact Report) and create a program that will properly consider the entire fire environment, reflect regional differences, allow for independent oversight, and incorporate the most up to date science. 2. The Wrong Focus. This program focuses entirely on clearing vegetation, despite extensive scientific research that clearly indicates the best way to protect lives, property, and the natural environment from wildfire is by addressing the entire fire environment: ignitability of structures, community and regional planning, and science-based vegetation management within and directly around communities at risk. Leave the natural landscape alone! Concentrate where the actual risks are: in and around communities. Additional details here: Protecting Your Home 3. Inadequate Alternatives. By law this document is required to offer reasonable alternatives to the proposed program. The only differences between the alternatives offered are different mixes of methods to clear vegetation. There is no alternative that looks at the entire fire environment (see #2 above).
4. Impossible to Determine Impacts. The Vegetation Treatment Program is so generalized that it is impossible to determine its environmental impacts on wildlife, plant communities, water and air quality, visual and aesthetic resources, recreation, soils, and invasive weed spread. There are no maps showing the location of clearance projects, only estimated number of acres per region.
5. Taking Away Citizen Rights. All projects within the scope of this Program will only be evaluated by a yet-to-be formulated checklist. They will not be reviewed through the California Environmental Quality Act (CEQA) as they normally are now. This will prevent citizens and independent scientists from challenging a project under CEQA that they feel is environmentally damaging. Citizens have the right to have individual projects thoroughly evaluated under CEQA. 6. Underlying Bias. This proposal is based on the questionable, overly-broad assumption that past fire suppression efforts have allowed a buildup of unnatural amounts of vegetation across the landscape, thus creating a fire hazard. While it may be true that some forests have been negatively impacted by fire suppression, this is not true for many other ecosystems, especially the chaparral. The proposal takes a simplistic, forest-centric approach that attempts to make fire issues out as broadly similar across the region, when in fact they are very different. Additional details here: Fire and Science
7. Ignored Contrary Views. By law this document is supposed to make an honest effort to review points of disagreement among experts. It failed to do so in areas such as the effectiveness of vegetation treatments, prescribed burns, and impact of fire severity in forests. 8. Cumulative Impacts Dismissed. The document only considers clearance programs conducted by other agencies and timber harvest activities in determining cumulative impacts. It does not include the impact of increased fire frequency on ecosystems, such as chaparral, already impacted by such a trend. Such an approach precludes a proper analysis of cumulative effects.
The "masticated" remains of a beautiful, old-growth chaparral stand near Santa Barbara.
Los Angeles Times Lead Editorial
Cal Fire's flawed fire plan
Critics say it's outdated, contains many inaccuracies and could cause major environmental damage.
March 11, 2013
California has a love-hate relationship with wildfire. We can't live with it and can't live without it. For thousands of years, fire — caused mainly by lightning — was a natural part of the landscape, which evolved to thrive on and even require occasional blazes. The cones of the Tecate cypress, for example, a tree that grows only in Southern California and Baja Mexico, will open to release their seeds only after a scorching.
Yet out-of-control fires also imperil property, homes and sometimes lives. And when they blacken the same ground too often, they devastate nature as well, creating the conditions for invasive annual weeds to dominate, weeds that take away habitat for animals and provide more combustible fuel for future fires. Most wildfires in Southern California now are caused by humans, and they're far more frequent.
Obviously, the task of protecting the public from wildfires without imperiling the balance of nature is complicated. It calls for exacting science and sensitivity to the many ecosystems found in the state — scrub, chaparral, coastal redwood forests, ponderosa pine forests of the Sierra Nevada and more.
Unfortunately, that's not what California has gotten in a draft environmental impact report from the state Department of Forestry and Fire Protection that outlines fire-management plans for 38 million acres of the state — pretty much all the land that isn't controlled by the federal government. The 1,300-page Cal Fire report, called a program EIR, is intended to set out an overarching policy for deciding where and how to alter the natural landscape to curb wildfire's threat to buildings and lives. Once it is approved by the state Board of Forestry and Fire Protection, individual projects to thin or clear vegetation mechanically, spray herbicides or conduct prescribed burns would not need to undergo separate environmental studies under the California Environmental Quality Act.
For all its length, though, the report is disturbingly vague about what the state proposes to do and where. Many wildfire experts say the study is outdated on the science of fire ecology and treats very different natural landscapes as though they were the same. The state's Department of Fish and Wildlife responded to the report with serious criticisms, saying among other things that the plan could cause substantial environmental damage. A letter from the National Park Service is downright scathing, slamming the report for numerous inaccuracies, accusing Cal Fire of ignoring important scientific studies and openly questioning whether the plan even meets the legal requirements for this type of EIR.
"If implemented, the proposed program would cause significant, irreversible and unmitigable environmental impacts to natural resources in the Santa Monica Mountains National Recreation Area on a large scale, while producing few if any of the fire safety benefits stated as goals of the program. As such, it would represent a very poor use of public funds," wrote Robert S. Taylor Jr., a fire specialist with the Park Service. "I strongly recommend that Cal Fire withdraw the current proposal and produce a new one based on best available science."
Both agencies criticize the report's call for fire breaks in the backcountry, far from developed land. Most of the blazes that cause serious damage to homes, fire ecologists say, occur in the most extreme conditions — hot weather, dry vegetation and Santa Ana-strength winds. They skip right across fire breaks in the backcountry; the best way to prevent or reduce damage is to create 100 feet or so of thinned, defensible space between buildings and the wilderness so that firefighters have safe access.
Though George Gentry, Cal Fire's executive officer, concedes that the report might be too vague, he defends it by saying that plans to thin, mow, burn or spray specific areas would go through further approval processes. That isn't good enough. Future fire-mitigating actions will be based on this document, or what's the point? If the EIR is adopted, no one will be able to use CEQA, the state's signature environmental protection law, to prevent possibly useless work at taxpayer expense that also might irreversibly damage the state's wild land.
Instead of tweaking the report and taking it to the board for approval this spring as planned, Cal Fire should adopt Taylor's suggestion, withdraw the EIR and start over — consulting the experts who pointed out its flaws. If California is to have a comprehensive plan for surviving in a fire-prone region, it should be the strongest one possible.