Grey Hayes
Bratton Online January 23, 2023 https://brattononline.com/ In my last column at BrattonOnline.com, I outlined the tragic history of the 5,600 acre Cotoni Coast Dairies property leading to BLM’s takeover of managing the property and urging readers to pay more attention and to be more active in the evolution of that management. January 30th is an important deadline that provides you an opportunity to help better protect the property: BLM is proposing sweeping regulations that supposedly ‘protect’ this public land, but they are acting prematurely. After reading this, I am hoping that you will write a public comment note suggesting a delay for BLM’s rulemaking until that agency completes its required planning process for protecting Cotoni Coast Dairies as it is supposed to be with its designation as part of a National Monument. If you want to cut this read short and write comments, skip the upcoming critique and go to the last section below for more guidance. Designed to be a Federal Yawner If you were managing BLM and you didn’t want anyone to comment on your oversight of Cotoni Coast Dairies, you’d design public comment period notifications to be filled with confusing jargon, contradictory statements, and pointless direction for commenters. Here’s a link to the current set of rules which would govern Cotoni Coast Dairies in perpetuity and which BLM has published for public review through January 30. Confusing Jargon The press release announcing this public comment period opens with this typically confusing jargon: “The supplementary rule would provide consistency and uniformity for visitors.” Huh? And there’s more confusing jargon – the comment period is about a ‘supplementary rule‘ – supplementary to what, you might ask, aren’t all rules supplementary? This seems either deeply philosophical or something that might better contemplated by Zippy. Contradictory Statements The press release for this public comment period begins with a curious and confusing quote from Acting Central Coast Field Manager Shekeetah Allen Genoway: “We believe this plan will help…” (emphasis mine) Errr…I thought this was a ‘supplementary rule‘ not a plan?? Someone at BLM might be reading this and scoffingly muttering ‘Big Deal!’ ‘What’s the Diff?’ or ‘Who Cares!?’ Well, there is a big difference between a rule and a plan, and it is BLM’s duty to engage with and educate the public about said differences. Pointless Direction Acting Central Coast Field Manager Shekeetah Allen Genoway’s quote goes on to give very narrow advice on what the BLM hopes the public will comment about: “We are seeking public comments to help us clarify language in the rules to ensure they are easily understood by users and public.” (Jargon note: anyone who might visit the property is known to BLM as a ‘user,’ but I’m unclear about the difference between ‘users’ and ‘public’) In short, BLM says that if the rules aren’t clear, then please give them feedback on how to make them clearer. In other words, don’t question the rules…don’t think about why such rules are necessary…don’t suggest better rules or how to improve the rules-making processes, etc. However, the rationale for public comment periods in a democracy is to open up all of those subjects for discussion. The Wizard of Odd Don’t pay attention to the man behind the curtain! If you are brave enough to open the Federal Yawner ‘Supplementary Rule,’ you can get to the root of what I see as the Big Problem by reading the ‘Discussion’ section. There, you will find a profoundly deceptive misstatement: “The BLM completed the Cotoni-Coast Dairies Resource Management Plan (RMP) Amendment on June 23, 2021, to establish land use decisions that protect the objects and values of the Cotoni-Coast Dairies unit of the California Coastal National Monument and support responsible recreation opportunities.” In fact, the RMP did not contain a list of the ‘objects and values’ called out in the Obama Administration’s Monument designation for the property. Therefore, the plan could not and did not ‘establish land use decisions that protect‘ them. Moreover, the RMP’s recreational planning analyses harkened back to pre-WWI-style parks planning with no mention of modern recreational planning principles: social carrying capacity analysis (to avoid overcrowding and user conflicts – for instance, mountain bikers vs. family hikers with small children, or natural resource carrying capacity analysis (to avoid disturbing sensitive wildlife, etc.). So, the plan could not and did not ‘establish land use decisions….{sic}(that) support responsible recreation opportunities.’ In sum, this current proposed “supplementary” rule compounds and builds on the shaky house of cards that has been BLM’s balderdash-based planning for Cotoni Coast Dairies. And, it is on that level that I urge you to give feedback to BLM. What to Do? The best current direction for BLM is to keep the property closed until the requisite planning processes have been completed and there is a credible approach from which to establish regulations for the property. According to BLM’s guidelines for managing National Monument properties (Manual 6220), the agency is required first to undertake studies inventorying the ‘objects and values’ of the Monument and determining how best to protect them. And yet, BLM has been opposing conservationists and the State of California’s natural resource protection agencies in its attempt to avoid such work. The proposed “Supplementary” Rule compounds BLM’s prior mistakes, and in doing so confuses the public into thinking they are embarking on good conservation work by limiting visitor use. You might find it confusing to oppose such a ‘supplementary’ rule when it allows BLM to enforce off-limits areas if what we are looking for is to protect the large swaths of Cotoni Coast Dairies from being ‘loved to death’ by visitors. Perhaps they might need some rules like this, but the BLM’s decision to make these rules is premature. They must first recognize, list, and analyze the human impacts on the ‘objects and values’ protected by Monument designation. For now, if we show BLM we aren’t fooled by their tactics and demand that they do a more complete job of protecting resources, BLM will be forced to follow its own guidelines and get the planning right. And so, I urge you to please write the BLM and let them know that they should complete the planning and analysis outlined in their guidelines for managing National Monuments (Manual 6220) before they create regulations that may or may not be necessary. A short note would suffice: Bureau of Land Management, BLM Central Coast Field Office, 940 2nd Ave., Marina, CA 93933, or emailed to: [email protected] or https://www.blm.gov/ Grey Hayes
Bratton Online January 16, 2023 https://brattononline.com/ Ever since the United States Department of Interior’s Bureau of Land Management (BLM) took control of 5800 acres of northern Santa Cruz County, conservationists have been asking themselves “what have we done?” The fateful transfer day was in 2014 when a private land trust, the Trust for Public Land, donated the property to BLM. It would be years before the negative repercussions of that handover were obvious. 7 years later BLM unveiled a draft management plan for Cotoni Coast Dairies, a document rife with errors including tables cut-and-paste from other plans from faraway places, lists of misidentified species, and proposals with little analysis and findings absent scientific rigor. How did such a bungling land management agency gain control of such a precious part of California’s coast? The story unfolds… BLM’s Standard Bearers Support Poor Standards As one comes to expect in our community, unctuous support for BLM’s draft plan for the property was lugubriously lauded by affiliates of profiteering recreational industries and their political hacks while conservationists carefully documented voluminous errors and omissions and suggested reasonable improvements to protect natural resources while providing access to open space. Subsequently, BLM perfunctorily changed the plan to address only the most egregious errors and, as expected, chose the ‘moderate use’ alternative, publishing an Environmental Analysis (EA), the easy, low-input, and cheap means for the agency to officially finalize approval. Shortly thereafter, conservationists filed an appeal to the Department of Interior and BLM asked for two extensions of the appeal window. During those extensions, and before the appeal was settled, BLM staff bulldozed areas of the property to prepare for one of its planned, but not yet permitted, parking lot. We don’t yet know which BLM official ordered that disgusting and undemocratic act, but we will find out. Conservationists won their appeal, but meanwhile the BLM had destroyed sensitive coastal prairie and cut trees that had long supported the federally threatened monarch butterfly. Meanwhile, it became clear that the only other parking lot location that BLM’s faulty plans had analyzed could not progress as planned because the road to the parking lot traversed private property without the consent of the owners. That was almost as surprising as the Coastal Commission’s allowance for that access road, which would have also paved a stream channel. It seems wherever one looks these days, the Coastal Commission pushes for maximizing public access even if it means careless destruction of natural resources. That matches well with BLM’s management philosophy. No One Home and No Friends Left Back in 2014, someone working at BLM told me that their office was ill-prepared for Santa Cruz. For years, their staff had managed land where there was no conservation constituency, where nature degrading recreational activities and other “resource” uses were unquestioned. Since BLM moved into Santa Cruz County and took control of Cotoni Coast Dairies, they have been unable to retain consistent managers: two field managers overseeing the property have departed and the newest one is rumored to be ‘remotely managing’ the property while living far away from the region. And yet, our community has long offered BLM friendship. At first, BLM welcomed enthusiastic friendships, signing partnership agreements with the University of California at Santa Cruz and the Amah Mutsun Tribe. Now, BLM only admits to being partners with the group previously known as Mountain Bikers of Santa Cruz (see sidebar, from BLM’s Cotoni Coast Dairies property homepage). Why has BLM rejected its tribal and science partners in favor of the mountain biking industry? We need to go back to the beginning of the story to understand. Swiss Dairyman and Subdivision Moguls The Cotoni Coast Dairies got its two last names from a Swiss dairy and land investment company, which started in 1901 and ended in 1998 when the investors sold to the Trust for Public Land instead of a subdivision mogul. For 97 years, the land referred to locally as ‘Coast Dairies’ was managed by farmers and ranchers who made it clear that the public was unwelcome. Much of the rest of the County had been explored by botanists and wildlife experts whose wisdom and documentation led to so many parks purchases. But this was not the case with this huge part of the County: it had remained largely uncharted. In 1997, real estate magnate Brian Sweeney announced that he had an option to build more than a hundred luxury homes on the property. The owners were able to quote extravagant property value, so conservationists had to raise a lot of funding to conserve the property and thwart the threat from development. Without biological surveys, conservationists had to convince funders about the value of the ‘spectacular views’ and recreational potential instead of conservation values. That seems to me to be how the seed was sown for how people came to value the property in the years to come. Trust for Public Land: 14 Years at Coast Dairies After purchasing the property, for 14 years the TPL managed the property while trying to find a way out. TPL managed to give State Parks the ocean side of the property, including the beaches. State Parks opened those beaches to public access without any planning or environmental review. It took many more years to find any organization willing to own the inland portion of the property. TPL solicited proposals from various potential landowners. UC Santa Cruz made a proposal, which didn’t work out. Meanwhile, it was costing TPL a lot of money and headaches to retain the property and the funders wanted it opened for public access. As a last resort, TPL turned to the federal land management agency that had long served as property managers of the last resort: BLM…there didn’t seem to be another option. Besides, some of the illuminati of open space purchasers thought perhaps it could soon be a part of The Great Park, owned and managed by the National Park Service. The Great Park For a while after TPL purchased the property, the Open Space Illuminati advertised something called “The Great Park,” an expansive interconnected park system, with a National Park nucleus derived from Coast Dairies and the adjoining San Vicente Redwoods. For a while, it seemed like this idea had become fet a compli, but enough powerful opponents started asking questions…politics changed…and perhaps funders’ willingness waned. After some time, the Great Park was a dim memory held only by a few. A National Monument As the Great Park idea waned, a new idea dawned: Cotoni Coast Dairies could become part of a National Monument! Charged up with a great deal of funding from the Weiss Family Foundation, the Open Space Illuminati parachuted in something that appeared to be popular movement: glossy brochures and websites popped up and The Monument Campaign was born. When conservationists exclaimed concern at the number of visitors that would be attracted to the property with such a designation, the Illuminati said ‘Shut up! This is the only way to make BLM accountable to protecting the property!’ They succeeded: in the last days of the Obama Administration, the president decreed that the property would become part of the California Coastal National Monument. Post Monument Blues Shortly after the President’s decree, the BLM dissolved the only staff positions whose work entailed guaranteeing protection under National Monument regulations. Since then, the BLM has refused to abide by its own regulations for managing National Monuments. Meanwhile, the Great Park and Monument Campaign Illuminati have likewise disappeared from the scene, their concerns for protecting the land swept away as they entered the next funding cycle’s focus in some other arena. Enter stage left the influential Outdoor Industry Association where business and profits pour from Nature commodified. Advertisements for ‘rad times’ on Santa Cruz County trails bring thousands of visitors, supporting a ‘green’ economy. Sales of super-expensive bikes skyrocket. Many conservationists are getting too old for the fight. It is easy to see what we have done, but what’s next is anyone’s guess. Best to stay apprised and keep asking questions; perhaps this is a good time for a renewed conservation movement in Santa Cruz County. |
Categories
All
Archives
March 2024
|