by: Friends of Bidwell Park
Re: Comment on Draft Bidwell Park Master Management Plan and Environmental Impact Report
Jeff Mott, land manager for the adjacent Big Chico Creek Ecological Reserve, submitted numerous vegetation management comments during the MMP review process. Even though he's considered to be an expert on local wildland management issues, many of his comments and observations were ignored. We are submitting them again in the hope that this time his very relevant advice will be incorporated into the document so that the document reflects local conditions and knowledge, rather than generic boilerplate. His comments are indicated with a light blue background. Some of his comments were incorporated in minor ways in the document but the format in which he provided them is more useful from a land management perspective.
4/ 3.1.3.2 wildland fire
California's oak woodlands have a long history of both "natural" wildfire (e.g. wildfire caused by lightening strikes) and human generated wildfire (e.g. fires set by Native Americans, Spaniards, and ranchers) (Keeley 2001a 2001b 2002, Blackburn and Anderson 1993). Generally, low to moderate intensity ground fires have little to no impact on mature oaks and oak seedlings, most of which are capable of resprouting following a fire (most mature blue and valley oaks do not stump-sprout after a fire, only seedlings and pole-sized trees will sprout), and studies have consistently documented the resiliency of oaks to fires of all intensities (Griffin 1980, Plumb 1980, Tietje et al 2001, Fry 2002, Dagit 2002). In fact, oaks may even benefit from wildfire. Some researchers have suggested that the recruitment of new oak seedlings may increase after a wildfire, possibly because oak seedlings are better able to germinate and grow with the temporary lapse in competition from herbaceous plants (Davis et al 1991, Gordon and Rice 1993, Gordon and Rice, 2000). In spite of the research, Bidwell Park and the surrounding area lost many mature blue oaks where the intensity of fire was low to moderate. This is due to an accumulation of fuel at the base of the trees that caused the cambium to burn. Many of the trees did not die until several years after the fire.
While oaks have evolved various adaptation that allow them to cope with and, in some cases, benefit from periodic wildfires, it should be noted that most all oaks, including valley oaks and blue oaks are extremely sensitive to the sort of wind-driven, brush- fueled wildfire that could potentially occur within Bidwell Park. And, even though all oaks are capable of resprouting following wildfires (see resprouting comment above), oaks vary in their tolerance of fire and their resprouting abilities. Valley oaks, relative to other oaks, have the lowest tolerance of wildfire and are the least likely to resprout following a wildfire (mature Valley Oaks, the small ones resprout). Most other oaks found in Bidwell Park are able to survive most wildfires and will resprout from the root crown following a wildfire (Garrison et al 1996).
Section 5 of this document discusses wildfire prevention and the use of fire as a management tool in more detail.
Meadows in the park make up less than 5% of the overall landscape but they provide important habitat for wildlife and humans. Some of the meadows in the Park are created by springs and seeps that keep them wet during a good part of the summer months. Others meadows exist due to dry, shallow soils, native peoples maintaining open spaces, and intense grazing practiced by the European settlers. The wet meadows and meadows with shallow soils naturally keep brush and trees from encroaching. Wet meadows act as important water retention reservoirs that retain, and slowly release water into the hydrologic system. Compaction of these meadows from grazing, roads, excessive human use, trails, heavy equipment, and vehicles reduces their capacity to hold and retain water. Other meadows created by pre and post settlers, and intense fire, are often home to sensitive plant and animal species.
Bidwell Park incorporates a significant portion of the Big Chico Creek Watershed. As water becomes a limited resource in California, emphasis on water supply will become increasingly critical. Wet meadow maintenance and restoration is emerging as a major supply strategy to meet the water needs of humans and wildlife. We need to preserve this resource, which will require education and outreach to the various park user groups.
Management options for meadows that contain significant archeological resources will need to be discussed with the local Mechoopda tribe and community professionals. Since the natural fire regime has drastically changed in the past 100 years, many meadows are converting to brush and trees. Questions will arise whether to maintain these meadows by burning and hand pruning, or allow them to convert to another habitat type.
The chaparral and mixed hardwood habitat association contains a broad diversity of plants that can not be characterized by several major dominant species. This habitat is highly variable and changes rapidly as you move short distances across the landscape. The dominant species can be California bay, black oak, interior live oak, buck brush, foothill pine, and a combination of these plus many others. This habitat is important wintering ground for the East Tehama Deer herd and is home to many bird, reptiles, mammals, and other organisms that don't exist anywhere else in Bidwell Park. The most important aspect in managing this habitat is to introduce disturbance so various age classes of plants are maintained. Disturbance can be in the form of fire, or cutting and pruning decadent stands of brush to promote stump sprouting.
Management issues associated with controlled burning are discussed in section 1/5, Fire Management. In general, the public is fairly aware of the benefits of using fire as a management tool. However, creating fuel breaks, hand cutting brush, removing dead plant material to save a mature tree from fire are not practices that have been widely used until recently. Therefore, there may be some resistance from the public unless adequate education and outreach accompany these activities. In addition, it is still viewed by some that if you leave the forest alone, it will take care of itself. Unfortunately, fire suppression activities have modified the forest habitat and we are gradually seeing our forests convert to grassland and brush. Maintenance of the ecosystem is necessary if diversity is to be maintained.
Big Chico Creek and the riparian areas that flank the creek are home to numerous sensitive species including the spring run Chinook salmon, western pond turtle, foothill yellow legged frog and other plant and animal species. At certain times of the year, human activities along the stream are fairly intense. Swimming in the creek when the spring run salmon are migrating and holding in pools undoubtedly places additional stress on the fish. Basking habitat for turtles is limited when humans occupy the same areas during the summer months. As human use increases along the stream, trash and fecal coliform will degrade water quality.
Another major impact on the riparian and stream system is the invasion of non native plants such as Spanish broom, Himalayan blackberry, vinca, ailanthus, arundo and others. The non-native bullfrog is reducing the native population of yellow-legged frogs in Upper Park and surrounding areas. These invasive species out-compete the native plants and animals for resources and quickly become dominant. The stream depends on native plants to provide nutrients and shade that cools water temperatures for the survival of the salmon, rainbow trout and others.
Managing human activity along the stream could be expensive and difficult to enforce. A public education campaign is probably the best avenue to illicit changes in behavior. The Park already has a competent group of volunteers to help eradicate invasive plants and these people should be supported to remove plants and control vegetation around mature trees. The neighboring property to the north (Big Chico Creek Ecological Reserve) will assist with road improvements, bullfrog eradication and Spanish broom removal. They are also available for consultation and assistance on other ecological issues.
The lack of information about practical, area-specific fire management implementation techniques is one of the greatest disappointments of the Bidwell Park MMP/EIR. This section mostly regurgitated the 1991 Wildfire Management Plan, which, for the most part, was never implemented. The MMP admits that "No fire protection plan for Bidwell Park currently exists." (2.4.6.1) and "The city does not have specialized equipment specifically for wildland fires." (2.4.6.1). In the list of EDAW Plan Preparers (5.2), there is no one listed with expertise in fire management. There's no one from the Butte County Fire Safe Council listed either.
Catastrophic fire is one of the greatest threats faced by both Lower and Upper Park. The "should" in "The Park Division should develop a fuels management program." (C.5.5) needs to be replaced by a "shall."
Jeff Mott submitted suggestions and practical advice regarding fire management, which was also ignored. Friends of Bidwell Park requests that his comments be added to the MMP. The BCCER, in just a few years and working with an equally limited budget and staff, has managed to significantly reduce the potential impacts of future wildfires at the BCCER. The City of Chico has done little to reduce potential impacts in Bidwell Park during the same time period.
Fire is the single greatest external force affecting terrestrial ecosystems in Northern California. Depending on circumstances it can be a force for change (as causing a stand of trees to be replaced by shrubs) or for stability (preventing shrub encroachment into a meadow or reducing fuel load to a level where mature trees are not damaged by subsequent fires.)
Fire suppression has been shown to be inadequate and counterproductive since it allows fuel to accumulate. Each year the amount spent on fire-fighting goes up and so does the damage done by wild fires. Effective habitat management must assume fire will occur and focus on controlling the effect of that inevitable fire on the ecosystem.
Fire depends on weather and slope, which cannot be controlled, and fuel, which can. While all organic material in an ecosystem could be fuel in a sufficiently hot fire, in most wildland fires only certain components of the available fuel contribute to the fire. Chief among these are small-diameter dead wood not in contact with the ground and thick, waxy or resinous leaves such as those of buck brush, toyon, bay, mazanita, scrub oak, interior-live oak, and needles of conifers. These fuels generate enough quick heat to kill mature trees, which, themselves, are seldom consumed in a wildfire. An equally bad source of fire damage comes from slow-burning ground fuels like duff or dry logs that often accumulate on the uphill side of trees and generate localized heat for long periods after the passing of the fire front.
Even when the fire is hot enough to kill their leaves, many trees will survive, sprouting new limbs and leaves. However, if the base of the trunk is heated enough to kill the cambium layer, the tree will be effectively girdled and will die in a few years if not immediately. When only one side is heated enough to kill the cambium, bark will eventually peal from the killed spot, permitting invasion of fungus and insects that further weaken the tree. If not felled by wind or gravity, the tree will gradually grow new tissues around the wound and seal it off. A second fire coming before the dead wood is covered may burn into that dead wood and enlarge the wound. Repeated assaults will weaken the tree to the point where it eventually falls.
Since the fuel load around the base of a tree will determine the severity of fire damage to the tree, removal of this lethal basal fuel load will increase the chance of a given tree surviving the next fire. Dead wood and waxy-leafed shrubs should not be left within 10 feet of the base and heavy duff such as squirrel-dissected pine cones or rotting logs should not be left within three feet of the trunk. Leaning dead trees that will obviously fall against the base of another tree should also be removed. When working with limited funds, logical triage should be practiced with the amount of effort expended to protect an individual tree based on that tree's relative value (see box) and probability of surviving another fire. Effort should generally be concentrated on trees with little or no basal damage.
Size—larger individuals are more valuable because they provide more ecosystem structure and require a longer time for replacement. However, a range of sizes is important to perpetuate the population. Different ages also provide different resources to other species (for example, juvenile oaks provide deer and rabbit browse while adult oaks yield acorns eaten by many species.)
Scarcity in that area—Since nearly all species have other species that depend on them for some aspect of their life cycle, presence of even a few individuals of a large organism like a tree may substantially increase local biodiversity.
Living spaces—damaged or even dead trees may provide cavities for dens or food caches.
Cluster—A group of trees provides a different habitat than does a single tree; therefore a group of trees equates to a valuable resource component.
Snags (standing dead trees) are a valuable component of the woodland ecosystem and should be left whenever practical since they provide perches for birds and food for insects such as beetles and termites that, in turn, provide food for other species. Snags are particularly valuable for woodpecker habitat.
Maintenance of a shaded fuel break may be thought of as shifting dominance from shrubs to trees. In the absence of fire, the various tree species gradually overgrow and outcompete the shrubs, which eventually die. If no fires occur for sufficient time the trees get very large and the shrub layer completely decomposes; subsequent fires can run over the ground killing seedlings without hurting the mature trees. However, if a fire comes through while there is still a mixture of shrubs and trees, the shrub layer will burn with enough heat to kill many of the trees. The shrubs will regenerate from the roots or from seeds and, with the fire-killed trees, soon provide enough fuel to carry another fire that will kill still more trees. Thus, a series of fires spaced a few years apart will create a shrub-dominated system.
To create a fuel break we artificially generate a system that mimics the mature forest. We remove shrubs, surface and ladder fuels, selectively leaving trees that will eventually be large enough to suppress shrub growth.
Fuel breaks don't stop a fire but they create an area of reduced fire intensity, providing a starting line for firefighters or reducing the heat that sweeps into an adjacent habitat.
Prescribed burns are obviously not an option in Lower Bidwell Park. The text needs to state that this applies to Middle and Upper Park only. Additional language should be added to develop fuel reduction methods that are appropriate to Lower Park
O.PS/ES-6 See above.
"A Wildfire response plan should be developed..." This is not an optional element of the MMP—a Wildfire response plan shall be developed" is more appropriate language.
Considering that this table notes that the potential for extreme wildfire within Lower Bidwell Park is 66% (almost as high as in Upper Park), much more attention should have been paid in the following pages to fuel reduction techniques that are suitable for Lower Park. Most of the focus is on Upper Park. A major fire in Lower Park would have catastrophic effects on not just the park, its vegetation and wildlife, but would also cause a significant economic loss for adjacent property owners, whose property values would likely plummet.
It's very surprising that the Chico Fire Department made only recommendations that apply to Upper Park. Were they specifically asked to comment regarding the fire dangers of Lower Park? Have they been consulted regarding the creation of a fuels management plan for Lower Park?
The paragraph about fire breaks ignores the "shaded fuel break" techniques which have proven to be more effective and less environmentally damaging. Why was no discussion of shaded fuel breaks included?
1. Since the 1991 Wildfire Mgt. Plan study indicated that the most serious threat is in Lower Park, why is there so little information in this plan regarding possible solutions to this problem?
2. "...approximately 162 wildfires had occurred in Bidwell Park between 1981 and 1990." Please update information regarding the number of wildfires that have occurred in Bidwell Park. Data that's 17 years old is not useful, especially since park usage and types of activities (e.g. mountain biking, disc golf) have increased significantly and also the park size has increased by 1457 acres since then. Also, please break out fires by location within the park.
"Implementation of the BPMMP and associated Park Improvement Projects would not result in significant adverse effects on aesthetic resources. With regards to several aesthetic resources such as scenic vistas and viewsheds, the proposed projects would result in a beneficial impact to the environments."
Regarding the proposed disc golf project, Friends of Bidwell Park does not think that replacing wildflower fields with 6" of mulch, smothering tree trunks in protective wraps, possibly installing larger shields to protect tree branches, delineating hundreds of feet of trail with tree branches or rocks (perhaps denuding the rest of the site to supply these), installing 36 or more 4'x12' concrete pads, and covering the historic Humboldt Road would provide aesthetic improvements to this site.
"Projects would only result in negligible additional trip generation from recreational users, as the projects are mostly aimed at accommodating existing uses."
Please show projected usage of the disc golf site, including possible tournaments. Please explain how a disc golf facility, 4.5 miles from Bruce Rd. with no public transportation available to it, would not have additional vehicle trips to the site as the facility was developed and became more well-known.
"Bidwell Park provides a large, continuous habitat for many plant and wildlife species.
It also functions as a migration corridor for wildlife. These functions will be preserved and enhanced by implementation of the proposed corridor and no cumulative impacts to biological resources are expected to result from project implementation."
Please explain why the cumulative impacts arising from anticipated eventual development of Parcels 8 and 9 of the Canyon Oaks subdivision have not been included in this discussion. Earlier developments in Canyon Oaks have curtailed ridgetop wildlife migration, fragmented habitat, reduced the areas available for native plants and animals, introduced new invasive horticultural plant species to the park, impacted the park's viewshed, and created new trails.
Please explain why the cumulative biological impacts arising from the construction of two new bridges in Upper Park, which will provide increased access to the south side of Upper Park, have not been evaluated.
Please explain why the cumulative impact to Humboldt Road arising from the Oak Valley subdivision has not been included in this EIR.
"Implementation of the BPMMP and the four Park Improvement Projects would result in no impacts of fire protection, police protection, schools, Park, or other public facilities and less than significant impacts on the maintenance of public facilities. Thus, the proposed project is not expected to result in cumulative impacts on local or regional public services."
You have not provided any information regarding the last 17 years of fire history in Bidwell Park. How can the potential impact on fire protection be evaluated for the disc golf course site when the fire history of this site is unknown?
Has the Chico Fire Department been consulted regarding the proposed disc golf course plan to use 6" of mulch to reduce soil compaction at that site? Considering the lack of enforcement of the May-Nov Upper Park smoking ban at this site and the thousands of cigarette butts currently littering the barren ground there, the potential for fire seems to be increased with this proposal.
It's disingenuous to state that a project which has the potential to bring hundreds, if not thousands, of new park users to the Disc Golf/Trailhead Area will not create the potential for more wildfire, especially when you consider that many of these new users may be from out of the area and not familiar with the May-Nov smoking ban or the risk of wildfire in the area.
If Chico firefighters are busy fighting a wildfire at the remote Hwy 32 sites, of course, it will have an impact on their ability to simultaneously fight fires in the urban area.
"Implementation of the BPMMP and the four Park Improvement Projects will not result in an increase in traffic levels in the Park, adversely affect the local transit system or have an adverse effect on existing parking or in an increased demand for new parking. With regards to increase in circulation hazards at the Disc Golf/Trailhead area, coordination with Caltrans will be required."
You have not provided any past, current or projected future traffic information regarding the disc golf project to support the accuracy of this statement. Will a turnout lane be required on Hwy 32? Has any study been done regarding the prevalence of alcohol consumption at the site such as counting the beer cans & bottles in the site's 2 trash cans over a few months? Park visitors leaving this site pull directly onto a highway that has a 65 MPH speed limit and limited visibility in both directions—there's no margin for error. Have accidents occurred more or less frequently on that section of roadway than other access points?