The Destruction of Chaparral
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 (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
1. The Wrong Approach
To speed up the process of reforestation in Cuyamaca Rancho State Park after the 2003 Cedar Fire, the department is chewing up large sections of fragile, pyrogenic habitat with giant mastication machines, ripping up the soil in the process, spraying herbicides on what is left, then igniting the remains.
This ecologically destructive project is based on the incorrect claims that post-fire Ceanothus growth is somehow unnatural, created by an unnaturally high-intensity wildfire. What the department should be asking is, "How did the Ceanothus seeds get into the soil in the first place?" Their presence indicates that infrequent, high-intensity wildfire is the natural condition for the Park. For example, the Santiago Canyon Fire burned much of the Park in 1889, which is why many of the older trees date back to that period.
Beautiful, white-flowering Ceanothus palmeri created a rich pyrogenic habitat after the 2003 Cedar Fire. The presence of this species indicates that the historical fire pattern included infrequent, high-intensity wildfire.
2. Massive Soil Disturbance
In order to efficiently remove the natural, pyrogenic habitat that was in the Park, the department had to use giant masticators to mow down the shrubs, killing whatever pine saplings were present, and ripping up the soil as a consequence. Soil is not something most people think about, but it is a factor that would have been discussed if the department had gone through the legal CEQA process. Forest soil is incredibly complex. By moving giant machines through the fragile habitat, that complexity is compromised. It will take decades, if not centuries to repair the damage done.
3. Invasive Weeds
One of the many negative consequences of soil disturbance is that invasive, non-native weeds and grasses can gain a foothold, spread, and change the ecology of an area forever. As can be seen in this photo, cheatgrass and other weeds have filled the void created by the Park in their mastication/burning program. Sadly, when this spot was burned, many of the oaks that had survived the 2003 Cedar Fire were killed.
4. An Unnatural Mix
Park management has decided to "reforest" Cuyamaca with Jeffrey and sugar pines. However, Coulter pines are the predominant species present and that's what has been naturally emerging in the new, pyrogenic landscape.
If the Park management wanted to plant favored trees, they could have done so by opening up small areas around campgrounds and other areas frequented by visitors and planting there. This would have been an ecologically sound process.
The naturally seeding Coulter pines in this photo were able to thrive because they were shaded by the surround Ceanothus and manzanita shrubs. Unfortunately, the shrubs were all cleared by a Cal Fire crew, leaving the saplings vulnerable to drought. A number of the saplings were cut down in the process.
5. Carbon "Sequestration?"
Burning and removing native vegetation to sequester carbon is an oxymoron. Regardless, we have no way of knowing how much actual carbon sequestration will occur because no one is actually measuring it in the Park. Since most of the first wave of tree planting ended in failure, we are wondering how that wasted effort (and the carbon released doing so) is being accounted for in the millions of dollars budgeted to reduce carbon via tree planting
This area was prescribed burned and well as sprayed with herbicide prior to the planting of plantation trees (3 seen with black rectangular shade structures).
Loss in Cuyamaca
A visual experience that describes how Nature lost in Cuyamaca Rancho State Park.
The Details: Getting Rid of the "Invading" Chaparral
Grinding up Habitat
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 and the manner in which they are planted reflects more of a commercial 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. 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.
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."
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.
Report: State Parks Conducting Cuyamaca Project Contrary to 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."
PLEASE SIGN OUR PETITION.
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
August 4, 2020:Please sign our new petition which calls on California State Parks to stop destroying the park's fragile, pyrogenic habitat in Cuyamaca and to begin respecting the Indigenous Peoples that were forced off the lands State Parks manage. Specifically,We call on California State Parks to:
1. Rename Stonewall Peak to reflect Kumeyaay values, not those of the Confederacy (the peak was named by Confederate sympathizers for General Stonewall Jackson). In addition, collaborate with local Indigenous Peoples to replace all place names that dishonor civil rights, equality, and people of color with names that honor the legacies of the Indigenous cultures that have enriched the land with their presence.
2. The Kumeyaay did not use poisons, chain saws, and giant grinding machines, as State Parks is now using in Cuyamaca Rancho State Park to force Nature to comply with their demands. Indigenous Peoples work with Nature because they respect its power - California needs to do the same, not use legal loop holes to avoid proper environmental reviews as was done with the "reforestation" project at Cuyamaca Rancho. Indigenous Peoples and other community members must be allowed to provide input as required under the California Environmental Quality Act which State Parks violated in 2009. Therefore, the Cuyamaca Rancho "reforestation" and habitat clearance project needs to be stopped until a full environmental assessment has been completed.
3. Go beyond performance actions (acknowledging racism, increasing diversity funding, etc.) to implement true transformation, including:
- structural changes to ensure diversity within public programs
- make parks more accessible and welcoming to people of color
- more people of color in leadership/ranger positions
- honor Indigenous history and culture throughout parks
- recognize the forced removal of Indigenous Peoples from park lands
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 Fire page.
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.
Acorn grinding area in Cuyama Rancho State Park where the Kumeyaay made food for their familes for countless generations.