Cal Fire Fails to Address the Fires
that cause nearly all the destruction
Instead, Cal Fire is targeting 10 million acres of native habitat for clearance
by burning, grinding, and herbicide spraying
- a quarter million acres per year -
Cal Fire's Vegetation Treatment Program (VTP) Ignores the Real Risk
1. Nine out of 16,909 fires in California during 2017 and 2018 caused 95% of the damage.
All nine fires occurred under extreme, wind-driven conditions.
2. Cal Fire acknowledges that the VTP will not be effective during wind-driven fires,
the fires that kill the most people and destroy the most homes.
The Solution: Focus on making communities themselves fire resilient
rather than clearing habitat in an attempt to control Nature.
After 15 years of trying to convince Cal Fire to follow the science, protect lives and property from wind-driven fires, and not clear thousands of acres of fragile habitat, we are forced to turn to the courts.
Cal Fire's Vegetation Treatment Program (VTP) targets 10 million acres of habitat to be burned, masticated, or sprayed with herbicides under the guise of fire protection (at an estimated quarter million acres/year).
The Program will make it essentially impossible for independent experts and the public to question environmentally destructive projects that would normally be allowed under the California Environmental Quality Act (CEQA).
The VTP was approved and certified on 12/30/2019. You can find the full Cal Fire VTP document here:
https://bof.fire.ca.gov/projects-and-programs/calvtp/We filed a lawsuit to stop the program on 1/28/2020. The trial date has yet to be set due to the Corona virus pandemic (see Updates below).
Here's an Los Angeles Times editorial from 2013 telling Cal Fire to withdraw their plan and start over. The judgement remains relevant.
Our full analysis of the VTP can be found in our 12/10/2019 comments on the final plan.
4. Please share our petition with everyone you know.
5. Stay informed by signing up for additional information via our email sign-up list in the green box below.
We also encourage you become familiar with the history below of Cal Fire's effort to promote their habitat clearance program. Information regarding Governor Newsom's unfortunate intervention in the process can be found here.
Find out what Cal Fire Plans to do to Your Favorite Wild Place
Go to the Vegetation Treatment Map for the state here. On the right-hand side of the map is a symbol that looks like a stack of paper. Click that. That will open up the menu to allow you to click areas targeted for "ecological restoration" and other environmentally damaging clearance operations that have nothing to do with protecting communities at risk.
As an example of how disconnected the Cal Fire proposed treatments are, look up Indian Canyon, in the Anza-Borrego Desert (see photos below). Unbelievably, the mountains in the background of the photo below are targeted for "ecological restoration" by Cal Fire.
Looking up Indian Canyon, Anza-Borrego Desert. Unbelievably, the mountains in the background are targeted for "ecological restoration" by Cal Fire.
Fragile habitat in the Anza-Borrego Desert targeted for habitat clearance by Cal Fire. Red areas are to be "treated" for ecological restoration. Olive colored lines are proposed fuel breaks on top of desert mountains.
Cal Fire should listen to those who understand wildfire best
- the Australians
On January 2, 2020, NPR's Ailsa Chang talked with Cormac Farrell, an environmental scientist who works in bushfire management, about what Australia has learned from past seasons, and how it's coping with the current one:
CHANG: Now, one suggestion that's been repeated is that there should just be more controlled burns - basically, reduce the fuel sources for these fires. What do you think of that idea?
FARRELL: I think it's a very simplistic way to look at it, and it simply hasn't worked. We've seen in these really catastrophic fire weather conditions that even areas that were fuel-reduced through controlled burning, they're burning again.
Wildfires burning across Australia on Jan. 3, 2020.
Masticators ripped through this pristine stand of chaparral, leaving behind scattered shrubs. This is one of project types, far from any community at risk , that Cal Fire is proposing. Los Padres National Chaparral (Forest) Reserve. Photo from Los Padres Forest Watch.
Old-growth chaparral destroyed by mastication to protect an artificial tree farm (along the ridge) on the Cleveland National Chaparral (Forest) Reserve.
How the VTP violates state law and
threatens the remaining chaparral in California
1. Clearing Mature Chaparral
Anywhere in the State
The VTP has targeted all mature stands of chaparral throughout the state for what it calls, “ecological restoration,” via mastication, burning, herbicide spraying or some other clearance operation.
The VTP never actually justifies this approach. In fact, the VTP makes a concerted effort to explain that chaparral is threatened by too many fires. The only restriction to conducting "ecological restoration" in chaparral is that the community must be outside its natural fire return interval. However, that restriction can be ignored if the project proponent demonstrates habitat function will be improved.
Based on previous determinations, such things as increasing deer browse by clearing chaparral or the desire to increase the number of wildflowers would likely qualify for improved habitat function. The fact that old-growth chaparral itself is an incredibly biodiverse community is ignored.
This component of the VTP basically gives Cal Fire a blank check to clear old-growth chaparral wherever and whenever someone is able to acquire the public funds to do so.
2. Violating State Law
Recognizing the threat of increasing fire frequencies, the California state legislature passed a law that restricts Cal Fire from conducting any clearance projects that cause “type conversion” away from the chaparral and coastal sage scrub currently on site. This restriction is problematic because the state did not define type conversion, allowing the Board of Forestry to do so itself. It did so in a way that is allowing it to so it to circumvent the law's intent.
The way the VTP does this is by defining type conversion in terms of "habitat function," which it defines as the arrangement and capability of habitat to provide the resources needed to support plants and animals. This is completely inconsistent with what type conversion actually is.
And in a clear conflict of interest, the determination of that quality of "habitat function" is the responsibility of the individual or organization that is promoting the clearance project itself.
The VTP considers clearance of up to 65% of an intact chaparral plant community as supporting proper habitat functioning. Cal Fire thinks that clearing most a site's habitat is an ecological plus (see photo below).
This is what 65% clearance looks like. Cal Fire believes this "managed" stand of chaparral retains proper "habitat function." The scattered piles are what is remaining of a once rich Ceanothus/chamise chaparral plant community.
The Board of Forestry has finally begun to produce the required public record documents, a full year after they were obligated to deliver them. We could not begin to develop our legal briefs without these documents. We have experienced similar delays with other California state agencies, unnecessarily delaying legal action. It will take some time to go over the record, after which we will file our initial briefs.
Governor Newsom signed an agreement on 8-12-20, with the US Forest Service (at the direction of the Trump Administration), calling for increasing "treatment" (devegetation, grazing, logging, herbicides) from a 2018 partnership goal of about 50,000 acres per year, to 1 MILLION acres per year by 2025. That's a 2,000% increase in logging and devegetation. Combined with Cal Fire's lobbying efforts in Sacramento to gut any bill that set limits on their habitat clearance operations, we are looking the beginning of the destruction of every accessible wild space left in California. All of this is hidden under the guise of "ecological restoration."
The Board of Forestry and Cal Fire rejected all of our settlement points, claiming they were already addressed in the VTP. They weren't, so we sent a revised, more detailed settlement document on 7/20/2020. We are awaiting a response.
We had the required pre-settlement meeting via phone with the Board of Forestry and Cal Fire. We offered our settlement points (all of which had been included in some form in our prior comment letters). At the end, knowing several of the officials on the call personally, we suggested that we all had the collective wisdom and knowledge to craft a truly successful program that would be superior to anything the court could offer. We then asked if they would be willing to work collaboratively to come up with a positive solution. The attorney for the Board only replied that they would examine our points in good faith.
Lawsuit filed charging the California Board of Forestry and Cal Fire for ignoring science and failing to address the fires that actually cause the most damage.
The Board of Forestry approved and certified the final EIR. The public has 30 days to object.
The Board of Forestry deferred action on the final EIR until the next meeting.
The final EIR has been released and will be considered by the California Board of Forestry on December 11, 2019. It again ignores the wildfires that kill the most people and destroy the most homes.
The latest draft EIR was released June 24. The plan ignores science (again) and proposes to "treat" (clear/burn/spray) chaparral throughout the state. Beautiful, old-growth chaparral is especially targeted.
The new, official final draft has been released. Comments are due January 12, 2018.
A revised draft of the Vegetation Treatment Program was released. It was presented to the Board of Forestry on June 14. The official draft for public CEQA review will be released some time in the future. We are currently studying the new revision.
It is with a great sense of disappointment that the latest draft of the Vegetation Treatment Program did not correct many of the errors and misrepresentations contained in the last version. See above for details and our comment letter on this version.
Our 2015 comment letter on the developing VTP. While we believe the current draft being developed is a vast improvement over previous attempts, it still contains significant contradictions and scientifically unsupportable statements that compromise the achievement of our common goal: protecting life, property, and the natural environment from wildland fire.
A new "Notice of Preparation" (NOP) was issued for the development of a third draft of the VTP EIR. The new draft will likely be released for public comment sometime in early 2016.
At the August 26, 2015 California Board of Forestry meeting, the second draft of the EIR was presented. The board decided the EIR needed further study. The second draft is an improvement, but still contains significant problems including misconceptions regarding chaparral. We offered testimony at the meeting and offered two new research papers that refute the notion that the clearance/burning of chaparral in northern California provides ecological benefits (which the second draft incorrectly claims).
Wilkin et al. (2015). Discusses the trade-offs of reducing chaparral fire hazard in northern California.
Newman et al. (2015). Discusses the negative impacts caused by chaparral clearance in relation to the spread of Lyme disease.
In August, 2014, the California Fire Science Consortium recommended in their peer-review report that the Cal Fire Plan, “undergo major revision if it is to be a contemporary, science-based document." The board then began the process of rewriting the document in the Fall of 2014 with assurances they would be modifying their plan by incorporating the new information and offering opportunities for the original reviewers to provide input on the developing draft.
After the board received criticism from fire scientists that the Plan did not reflect the most current research, the California State Legislature asked the California Fire Science Consortium, an independent network of fire scientists and managers, to review the document.
We have been involved in this process since 2005, long before most environmental groups understood the threat habitat clearance programs, promoted under the guise of fire protection, posed. Our first effort to prevent the wholesale destruction of Nature from misguided fire policy was when San Diego County proposed the clearance of 300 square miles of habitat after the 2003 Cedar Fire. We were fortunately able to stop it. You read the entire story here.
The Cal Fire VTP program is the San Diego County plan on steroids.
Here is our first comment letter (August 31, 2005) on the proposed Cal Fire VTP Program.
The current review process began January, 2013. We submitted a detailed letter along with a petition with 3,080 signatures (and citizen comments) that called on the Board of Forestry to retract its proposed habitat clearance program and to instead work with fire scientists, 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 ecosystem
If you would like to view the Board's original proposal, please send us an email and we can send you a copy. The file is about 20 MB.
The basic points we made in our original comment letter (which still apply to the final 2019 plan) include the following:
1. We Requested the Board of Forestry to retract the Vegetation Treatment Program Programmatic 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.
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.