(CA) Anza-Borrego Desert State Park General Plan/EIR Comment

[Ed A. Stevens]

For those wishing to comment on the Anza-Borrego Desert Sate Park
General Plan/EIR, these comments are compliments of the Backcountry
Horsemen.....

Pick and chose or use as you wish...

Comment deadline is March 3, 2003.


February 19, 2003

Environmental Coordinator
C/O Southern Service Center
California Department of Parks & Recreation
8885 Rio San Diego Drive Suite 270
San Diego, CA 92108

Dear Sir or Madam:

Please accept the following as my comments regarding the proposed
Draft General Plan for Anza-Borrego Desert State Park. Anza-Borrego
Desert State Park's purpose as stated in the General Plan document
is: "...to make available to the people forever, for their
inspiration, enlightenment, and enjoyment, a spacious example of the
plains, hills, and mountains of the Western Colorado
Desert.representing all the varied scenic, historic, scientific, and
recreational resources of the region." How is this statement of
purpose affected by the further refining of the Park's Management
through the implementation of Public Resources Code Section 5019.53,
PRC Section 5019.68, and PRC Section 5019.71? As I read these
sections of the California Public Resources Code it appears that the
recreation element of the purpose for the Park is being seriously
neglected while the preservation aspects of these PRC codes are being
given emphasis that will have a cumulative effect of severely
limiting the ability of the average Park visitor to have a
"wilderness experience". The preferred alternative of the General
Plan seeks to limit the Focused Use Zones to about 1% of the Parks
total landmass. If we accept the potential visitorship growth
projections as stated in this document it will inevitably lead to
exactly the type of overcrowding and congestion at certain times of
the year that park visitors are seeking to get away from.

The language in the State Wilderness Classification, PRC Section
5019.68 refers to an area that, "has been substantially restored to a
near-natural appearance." What is a "near-natural appearance"? How is
it defined? What Criteria has been established for this designation?
By whom was it defined?

The same PRC Section refers to, "without permanent improvements or
human habitation, other than semi-improved, or structures which
existed at the time of the classification of the area as a state
wilderness." Does this language include roads and trail corridors
that existed when the State Wilderness Classification was
established? It should. It appears that the County of San Diego's
assertion of its rights under RS 2477 would mean that any roads and
trails corridors that existed at the time the Park was established in
1933. Under the PRC Section 5019.53 that classifies the area as a
State Park, "improvements may be undertaken to provide for
recreational activities including, but not limited to, camping,
picnicking, sightseeing, nature study, hiking and horseback riding,
so long as such improvements involve no major modification of lands,
forests, or waters." The continued maintenance of historic trail
corridors and existing roadways within the Park boundaries is not
only desirable to the bulk of park visitors; it is mandated by the
PRC code.

The Park Mission Statement as printed in this document appears to
focus on the protection and managing of resources at the expense of
"serving the needs of the public which are consistent with park
objectives" unless the public needs to be excluded from the Park. If
the public needs to be excluded from the Park, then the management
goal of "instilling an appreciation for, and making available these
treasured qualities and experiences for present and future
generations" cannot be met.

The Park Visitor Survey and the visitation numbers as published in
this document do not support the claim in this document that the Park
is in peril due to increased population in neighboring areas. The
Park environment is replete with visitation limiting factors, such
as, the extreme temperature ranges. While a good wildflower year can
increase Park visitors to around one-third of a million. This level
of visitation only lasts for a very brief time in the spring. For
most of the year daily temperatures tend to be in excess of 100
degrees Fahrenheit. This has a naturally limiting effect on Park
Day-Use Visitors. Again, based on the Park Visitor Survey, as I read
it, most of those surveyed support either no change in Park
Management Strategies or alternative 1. This alternative would best
address the present and future needs of the public that wish to
experience the Park and gain an appreciation of the natural and
cultural resources of ABDSP. The information collected at the Public
Scoping Meetings and through the Park Visitor Survey clearly
indicates the public's desire to continue to visit and experience the
Park and it's incredible cultural and natural resources in a manner
consistent with the Declaration of Purpose, PRC, Section 5002.2(b).
Further restriction of visitor access and the cumulative impact to
existing outdoor recreation activities of such restrictions are
unacceptable to current Park visitors and the general public.

The objective of the Park Mission Statement states in part, "to
preserve the landscape and scenery of the Park in a pristine
condition" This is very subjective as the term "pristine condition"
is not quantifiable and lacks concrete definition. What criteria have
been established to define this term? Who defined it? What methods of
measuring this condition have been established? Who will be
responsible to measure and report on these conditions?

The Vision Statement for ABDSP also refers to "the vast desert
landscape and scenery being preserved in a pristine condition. The
full array of natural and cultural resources are cared for so as to
perpetuate them for all time." this statement is a fallacy. We cannot
"perpetuate anything for all time". The guiding principle at work in
the world is CHANGE. Erosion is a natural occurrence over time making
it impossible to maintain the integrity of geological formations and
outcrops over time. There is also a question of how the term
"integrity" of a given geological feature is defined. What criteria
are used to determine this integrity? How were these criteria
developed? By whom? Where will these criteria be presented for public
review and comment?

The stated Management Goal that "land management actions will be
based on sound scientific data" must be adhered to. The statement "if
such data does not currently exist and resource integrity appears in
imminent danger" is very subjective. It violates the stated goal and
prevents effective public oversight of management decisions. This
will lead to conflicts between Park visitors, trail users and Park
Management. It is, in my opinion, imperative that a Citizens Advisory
Council, which will be made up of representatives of all Park user
groups, be established to review all land management actions before
implementation. This will assist Park Land Managers by providing both
a wide range of viewpoints to guide the decision making process and a
strong group of potential advocates for implementation.

Under the heading of Geology, one guideline states, " Identify and
monitor significant geological features. Take protective measures
where necessary." How will the need for protective measures be
determined? Who will make these determinations? What criteria will be
used? How can the public be assured that any protective measures
undertaken will be implemented only after a balanced peer-reviewed
decision making process?

Under the heading of Soils, one guideline states, "Identify and
protect natural sand sources that supply the material for sand dune
systems throughout the Park." This guideline is probably unachievable
since the Park Boundaries do not include all potential sources of the
material for sand.

Under the heading of Hydrology, while I agree, in substance, with the
stated goal, "Protect the surface water and groundwater of ABDSP and
strive to restore sustainable and ecologically functional watersheds
throughout the region." This goal is beyond the scope of influence of
Park Management Staff. Any portions of watersheds that affect the
Park that are outside the Park boundaries are, in many circumstances,
private property. They are therefore outside the sphere of influence
of Park Management staff.

Under the heading of Paleontology, the goals and guidelines, again,
express concepts that are not achievable. To protect and preserve
them in perpetuity from natural degradation is not possible. It
totally disregards that the guiding principle of the world is CHANGE.

Under the heading of Significant and Sensitive Biota, the opening
sentence of the discussion is based on the false hypothesis that,
"the present rate of decline and extinction of plants and animals
supports the current global biodiversity crisis exists." The rapid
expansion of populations of keystone species, such as, mountain lions
and wolves, the top predators in the North American food chain
indicates that very positive changes are occurring. In fact the major
factor in the decline of the peninsular bighorn sheep populations in
ABDSP is mountain lion predation. Peregrine falcons have been
de-listed, bald eagles are candidates for de-listing, trumpeter swans
are thriving. Canada goose, snow goose, and white-tailed deer
populations are at nuisance levels from the Eastern Seaboard through
the Midwest. Elk and American bison herds are larger than they have
been since the 1930's. The least Bell's vireo thrives along Southern
California rivers where the riparian corridors have either been
actively restored or simply allowed to restore themselves. White
ibis, snowy egret, wood stork, great egret and tri-colored heron are
nesting in record numbers in the Everglades. The number of nesting
birds is five times what it was five years ago. The point is the
"global biodiversity crisis" is certainly waning rapidly across the
North American Continent. The introduction of the concept of
"stochastic influences" with regard to the preservation of amphibian
species in the Park seeks to change a fundamental principle that
underlies all conservation and preservation planning. The concept
that natural selection in the process of biodiversity and speciation
has ended and that the survival of species will be dependent upon the
vagaries of human goodwill and ecological consciousness has not been
documented or proven. Introducing it into a General Plan document is
unacceptable. It is simply another methodology for ignoring that the
"global biodiversity crisis" is an unfounded myth.

The stated goal "Protect the native biota of ABDSP" begs the
question, what are native biota? What criteria were used to determine
when a species is considered native? Is there a particular timeline
to determine a native species as opposed to non-native? If so what is
it? Where is it published? When and by who was it peer-reviewed?

The guideline, which reads, California State Parks will identify
situations where State and Federal environmental legislation is not
adequate to protect native biota. California State Parks will be
proactive in biological conservation when the legislative process
appears too slow, driven by economic or political interests or to be
focused on a species when other levels of biological organization may
be more appropriate units of conservation.."This is or should be
beyond the scope of CSP staff responsibilities. It is not appropriate
to use of CSP staff and resources to interfere with the legislative
process. It is a source of on-going frustration that public agencies,
such as, the US Fish & Wildlife Service and the National Forest
Service are so encumbered by the filing of lawsuits and the need to
respond to them that they are unable to meet deadlines and fulfill
their responsibilities towards currently listed species.

Under the heading Exotic Biota, "Exotic species are those that have
been introduced by human actions to an ecological system from which
they did not originate." By this definition all species could be
considered exotic. Evidence of human activities have been found in
ABDSP that appears to date back to the early Holocene period
approximately 10,000 to 8,000 years before present. This period also
correlates to a series of climate shifts with the advance and retreat
of glaciers further north. The warming and cooling cycles would have
caused changes in biota. This discussion also expresses the concept
that specific biological systems typically express a degree of
balance that supports or perpetuates the species native to that
system. This is a fallacy. If, in fact, this hypothesis were true
there would be no biodiversity because there would be no change in
biological systems.

Under the heading Landscape Linkages, one guideline states, ".
California State Parks will advocate the protection of key parcels
within identified landscape linkages through acquisition or other
conservation mechanisms and discourage projects or components of
projects that decrease the viability of such linkages." This
certainly appears to be outside the CSP sphere of influence. While it
may or may not be acceptable for CSP to dictate land use within the
boundaries of the land they hold in trust for the citizens of
California, I believe it is necessary for land use planning to be
consistent with County General Plans. How has this issue been
addressed and incorporated into this document? The idea that CSP will
seek to dictate land use issues on lands that they do not own is
unacceptable, unconstitutional and probably illegal.

Under the heading Cultural Resources, one guideline states, Conduct
research on known roads, trails, natural corridors and segments of
historic routes of travel to identify their builders, periods of use,
and periods of historical significance." I submit that any and all
known roads, trails, natural corridors and segments of historic
routes of travel be kept open to modern day Park visitors as they
have already been used for human activities and will benefit future
generations in by increasing their understanding of the lengths to
which early peoples and pioneers went to settle the North American
Continent. While I agree, in principle, with the guideline to
"Conduct oral history interviews with descendants of families who
grazed livestock within the Park." I am concerned with the negative
image the terminology "highlight its profound effects upon the
landscape" presents. Again this is a very subjective viewpoint that
not all interested =
parties share.

The stated Goal, "Protect, stabilize, and preserve cultural resources
within ABDSP." is a noble one; I have grave reservations about how
this can be implemented. The discussion of assessment of visitor use
effects is appears to leave the determination of site-specific
closures, moving roads, trails or camping locations open to arbitrary
interpretation in a manner that is not consistent with "serving the
needs of the public.." There are many guidelines listed under this
goal that seriously overstep the boundaries of reasonable and logical
Park management principles, ignore the cumulative impacts upon public
recreational activities within the Park, and are far beyond the
capacity of Park management to achieve.

The stated Goal, Identify, document, protect, and interpret, if
appropriate, archaeological and historic-period resources within
culturally sensitive areas, and establish means to minimize impacts
from visitor use." Includes a number of guidelines that will if
implemented as written abrogate the public process of review. They
will also deny visitor access to historical and cultural treasures
that form the basis for the Park's existence.

Under the heading Recreation, there is a guideline "Assess current
and potential recreational activities for compatibility with State
Park, Wilderness, Cultural Preserve and other land designations." How
are these designations prioritized? Who will make the decisions
regarding prioritization? What criteria will be used? How has it been
developed? How has CSP preserved pre-existing Wilderness rights?

Under the guideline, "Assess primitive camping locations and other
areas of active recreation for archeological sites." What is the
timeline that will determine that these primitive camping locations
are candidates for protection as archeological sites on the basis of
the longevity of their existence? For example, the shelter built near
the top of San Jacinto Peak by the Civilian Conservation Corps in the
1930's is being considered for cultural protection from visitors to
San Jacinto State Park. There is an existing CCC campsite in
Oriflamme Canyon that is adjacent to the existing California Riding
and Hiking Trail. How can this be developed for current visitor use
since it is a pre-existing improvement that should no require an EIR
process? The protection measures delineated under the guideline
listed above which include: "closing areas to camping, restriction of
vehicular use, moving the alignment of trails and roads, and creation
of new cultural preserves and other measures" can all be used to
justify unreasonable restrictions of Park visitor use even in the
proposed Focused Use Zones.

Under the heading Leadership the stated goal, "Act as a leader among
agencies and groups that are active in providing recreation and
preservation by nurturing partnerships and advocacy of the Park's
mission." Will, in my opinion, require major philosophical changes on
the part of current Park Management Staff. I truly hope they can
achieve them. The guideline that states, "Lead efforts to develop a
sustainable relationship between human culture and wild nature." Begs
the question, how is a sustainable relationship defined? It must be
clearly defined in order to be developed.

Under the heading Community Involvement and Marketing, one Goal
states: All potential appropriate user groups, especially
non-traditional groups, will be encouraged to visit the Park." How
and by whom will the appropriateness of a user group be determined?
What criteria will be used? Who will develop the criteria? Another
Guideline states: "Encourage and develop volunteer groups and work
programs that are consistent with park needs and values." Given past
experience with CSP Management staff and equestrian volunteers, it is
my opinion that this goal will need a lot of work. There is an
additional guideline that states: ".Recognize and build on a mutually
supportive relationship between the Park and the community of Borrego
Springs." This guideline will require major efforts on the part of
Park staff. Their total disregard for community planning efforts and
the economic impacts of previous land use decisions has created a
hostile environment that will be difficult to overcome. An a
additional Goal plans to "Manage staff and resources to effectively
deal with the Park's highly cyclical visitation. Promote visitation
during less crowded periods." Again, given past experience with Park
Management staff, in my opinion, it will be difficult to meet these
goals.

The Draft General Plan document lists a number of goals and
guidelines that deal Real Property Additions and Management. Given
its current level of staffing and with the prospect of budget cuts
due to the huge state budget deficit, it will be difficult for Park
Management staff to effectively manage the land it currently has
responsibility for. A series of goals that encourage additional land
acquisition seems unwise at best. According to this document as of
2002 the area patrolled by a single ranger at ABDSP averaged nearly
100,000 acres. This indicates a serious lack of ability of Park staff
to effectively manage and protect the resources they are currently
responsible for. It is ludicrous to expect to continue to acquire
properties under these circumstances. The Coyote Canyon Public Use
Plan was outlined in 1995. It closed a significant portion of Coyote
Canyon to traditional uses and changed visitor impacts to other
sections of the canyon. It was to be reviewed in five years. We are
told that the proposed review was not completed until 2002. It has
still not been made available to interested parties who have asked
for it repeatedly. This inability to meet deadlines and respond to
reasonable interested party requests reinforces that Park staff
cannot adequately manage and protect the resources they are currently
responsible for.

In summation, this Draft General Plan lists a number of future
planning efforts that will have to be made, the Backcountry Camping
Management Plan, the Roads Management Plan, the Trails Management
Plan, the Cultural Resources Management Plan, the Natural Resources
Management Plan, the Interpretive Management Plan, and the Facilities
Management Plan. All these planning efforts appear to be creating a
whole new bureaucracy with duplication of efforts and serious impacts
on already limited staff capabilities to meet Park needs. The number
of proposed planning efforts are almost certain to cause confusion,
conflict and an unparalleled level of redundancy. The amount of staff
time and costs related to all these planning efforts will be
staggering. It will be difficult for interested parties to stay
engaged in the planning process with so many planning efforts that
each take time and effort to review and comment on. It has the
cumulative effect of unnecessarily restricting recreational
activities, which is in direct conflict with the expressed desires of
the majority of interested parties who took part in the planning
process. It is in direct conflict with the interests expressed in the
comments of the majority of people who filled out the Park Visitor
Survey. It is unfair to the citizens of California who have funded so
many bond acts for parks and recreation and who expect to be able to
enjoy recreational activities on the land so acquired to proceed with
the preferred alternative. Thank you for the opportunity to comment
on this Draft General Plan.

--
John Stewart
Director, Environmental Affairs, UFWDA, http://www.ufwda.org
Recreation Access and Conservation Editor, http://www.4x4wire.com

A fundamental law of public land access is:

Increased habitat designation for threatened and endangered species
is directly proportional to loss of access to public lands.