San Gabriel Mountains and Watershed Special Resource Study
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Significance and Suitability

 

·        This is a very valuable resource adjacent to very large population center. Potential benefit to cost ratio is very high. Easily equals value of Santa Monica NRA and merits comparable response.

·        Some of the language seems pretty overblown in its description of what is largely a lot of chaparral.

·        As the Puente-Chino Hills serves as the southern boundary of our community we are pleased to learn that the National Park Service in its San Gabriel River Watershed Study Act recognizes it as a nationally significant habitat resource. We support the comments on the preliminary alternatives in the San Gabriel Watershed and Mountains Special Resource Study and urge the National Park Service to include our Puente-Chino Hills in the San Gabriel Watershed National Recreation Area.

·        The two areas contain a combination of themes and resources not found in any national park unit or comparably managed area.

·        The City believes that the preliminary findings regarding the purported "national significance" and "suitability" of the Puente-Chino Hills area for inclusion in the national park system that form the underlying basis for this alternative are not supported by the facts or consistent with established NPS criteria for evaluating resources.

·        Given the brevity of the self-described "summary" on page 3 of the Newsletter with respect to potential nationally significant resources in the PCH area, it is somewhat difficult for the City to respond in detail. Nevertheless, what is immediately obvious to even the casual reviewer is the attempt to literally "link" the PCH area to the San Gabriel Mountains. (See page 4 of the Newsletter: "The two areas contain a combination of themes and resources not found in any national park...."). While we recognize they are part of the same Study area, the two areas are very different in terms of resources and are separated by one of the most densely populated urban areas in the country. As the Newsletter aptly describes it, the PCH is indeed "an island of open space surrounded by urbanized areas." The description of the multiple significant resources in the San Gabriel Mountains contains five distinct categories (geology, architecture, scientific research and discovery, dynamic river systems, and biodiversity), whereas the PCH area offers a single potential category (biodiversity). In short, minus the "combination" with the San Gabriel Mountains, the purported significance of the PCH area is limited to a single factor. With respect to this single factor, the summary on page 3 of the Newsletter asserts that there is an "abundance of endemic, threatened and rare plants and animals" within the vaguely defined Puente-Chino Hills area. The City is not aware of any published biological survey reports that would substantiate this finding for areas within the City's holdings.

·        The Newsletter also alleges that the Puente-Chino Hills contain outstanding examples of coastal sage scrub ("CSS") and the best remaining stands of California walnut-dominated woodlands south of Ventura County. The vegetation present on the City's Tonner Canyon holdings is dominated by northern mixed chaparral, a common habitat type. CSS is extremely limited onsite, and comprises somewhere on the order of less than 2% of the total area. With respect to California walnut-dominated woodlands, there are some scattered stands in Tonner Canyon, but significant portions recently burned in the 2008 Freeway Complex fire and previously burned in the 1990 Carbon Canyon fire. While these recent natural impacts are regrettable, the remaining unaffected woodland areas can hardly be described as meeting the NPS criteria of a "relatively unspoiled example of a resource." The Tonner Canyon floor and some hillside areas of the City's holdings contain permanent improvements that have been and continue to be used for camping, sports and other recreational activities by the Boy Scouts and other organizations. Oil extraction remains active as is cattle grazing, and urban encroachment along the ridgeline is visible from many locations within the property. While the City's Tonner Canyon property allows for public enjoyment and recreation in a generally attractive setting (i.e., where suburban sprawl and oil extraction activities are not visible), the City does not believe that its holdings, nor the adjacent holdings of Aera Energy LLC ("Aera"), rise to the requisite level of being an "unspoiled example of a resource." For the above reasons, the City respectfully requests that the NPS reconsider its preliminary finding regarding the significance of the limited resources identified in the PCH area, and appropriately revise such analysis in the final version of the Study.

·        Just as the PCH area by itself lacks the variety of resources that are found in the San Gabriel Mountains, the summary at page three of the Newsletter similarly attempts to compensate for the modest size of this area by another act of combination: "the Puente-Chino Hills and the Santa Ana Mountains, connected together, encompass about 500,000 acres of wildlands" (emphasis added). Any connection between the Puente-Chino Hills and the Santa Ana Mountains/Cleveland National Forest would include Chino Hills State Park, which is already protected state parkland. Moreover, by process of elimination, given that the Cleveland National Forest consists of over 460,000 acres and the Chino Hills State Park is approximately 15,000 acres -this would leave less than 25,000 acres of land not already under federal and state control, of which 5,000 acres is controlled by the City and an additional 3,000 acres are owned by Aera. In short, approximately one-third of the PCH area consists of the land holdings of the City and Aera. In light of the foregoing facts regarding the Study's apparent overestimate of the significance of the biological resources in the PCH area, and the proximity of Chino Hills State Park and the Cleveland National Forest, the purported finding on page four of the Newsletter regarding the PCH area being "suitable" for inclusion in the national park system is clearly at odds with the criteria listed in that section since CSS habitat and walnut woodlands are already "comparably represented and protected for public enjoyment" by both federal and state agencies.

·        With respect to Alternative B, the unconcealed need to link the so-called Puente-Chino Hills area to other existing publicly protected lands that do have readily apparent significant resources simply underscores the City's concern that the preliminary finding of national significance for the PCH area itself (much of it owned the City) is really just a case of the "significance" tail wagging the federal "funding" dog. The City cannot support strained interpretations of well-established NPS regulations, however, to achieve this funding purpose. Accordingly, the City does not support Alternative B at this time, and strongly recommends that the NPS consider other approaches to bringing additional federal funding for parks and open space to our region.