By Frank Landis, Conservation Committee Chair & Rare Plants Chair
I’ll start with some good news. As I semi-predicted last month, the developers behind Adara (nee Otay Village 14) filed a lastminute “Objection” to stop the ruling being finalized and them being ordered to cover the plaintiff’s costs. They made some interesting claims about why it was critical that the EIR not be decertified, that the ruling was wrong (of course) and that, because they didn’t lose on every single issue brought up in the suit, they won and shouldn’t have to pay up.
The judge disagreed. We’ll see what happens next. Personally, I hope that nothing gets built in that part of Proctor Valley.
The noted ecologist Steve Carpenter once wrote, “Ecology isn’t rocket science; it’s much more difficult.” While planning isn’t ecology, I’m simply going to propose that rocket science, planning, and CEQA actually have a lot in common. And I’m also going to vent about the Alpine County Park and its, erm, rather problematic draft EIR, which I’m writing comments on right now. This is a small project that should have a small DEIR that I wouldn’t have needed to comment on. Instead, it’s a mess, because the planners doing it didn’t treat it like it was rocket science.
The similarity isn’t that CEQA requires complex physical equations. Where planning, CEQA, and rocketry are similar is that, to keep from cratering on launch, the project has to integrate a lot of working parts. This isn’t about hacking rocket equations, it’s a problem of management rooted in imagination and the ability to think laterally.
In a rocket, the bottom stage has to lift a lot of stuff from a standing start up to the top of the densest part of the atmosphere. That’s why it’s basically huge tanks of fuel and a motor that turns what would otherwise be a titanic explosion into highly directed thrust. To keep weight within limits, everything that contains these dangerous fuels and hot exhaust has to be as light as possible. The upper smaller stages speed the rocket up, get it into the upper atmosphere, and ultimately boost it up to orbital speed. And, park design and rocket design have some similarities these days, at least in terms of making everything multifunctional.
In the case of Alpine County Park, the land is a parcel the County bought right next to Wright’s Field. It’s in the MSCP preserve boundary, so 75% of the parcel has to be set aside, while 25% can be developed. What part of the parcel to develop, the perennial grassland or the boulders? We’ll come back to that. What to build on the 25%? The planners decided they wanted a big park to suck in 500 people per day. Why? We’ll come back to that, too. So, the rocket science part of this is trying to bring in a lot of people while not trashing the part you want preserved. And then you have annoying outsiders like, well, me, helpfully pointing out the need to consider recreation ecology, which, as a field, studies how recreation impacts plants and animals.
Now there are a couple of ways to do this. One is to take the hint about recreation ecology seriously and pay attention to the fact that County and other Parks are seeing parcels overrun by people making their own trails. They’d then look at the park site, see that there’s already an unauthorized trail system there, and realize they had a problem.
Or, they could do what they did, which is to ask someone to write a nice little essay about recreation ecology in the DEIR. They then make maps that hide how many trails are onsite and write in the DEIR that unauthorized trails will be closed with signs and fences. That fulfills the bureaucratic part of CEQA, but it doesn’t really do anything to actually protect the animals and plants in the preserve. So long as wire-cutters and saws are cheaper than fences and signs, vandalism will not have solely technical solutions.
How do you protect the wildlife (or in CEQA-ese, mitigate the impacts from recreation)? Normally, planners write these documents called Resource Management Plans. Sometimes these RMPs are even read and used. Or, as in the Alpine County Park DEIR, you can defer writing the RMP until later. If you’re a CEQA wonk, you know that deferred mitigation is a frequent charge in litigation, but heck, if you’re a planner, maybe litigation fees don’t come out of your budget or something.
Imagine building a rocket this way. Perhaps the part about how you get your payload from the bottom of the stratosphere to the top of it and up into the mesosphere is left as a problem to be solved once the rocket gets there?
Then there’s where you build the “active recreation park. Do you choose the boulder-covered slope or the open slope with the rare perennial grassland? The latter of course. To keep costs down, you map it as a big flat area. It actually slopes about 3% from top to bottom, but that’s what the earth movers are for. But destroying rare perennial grassland requires mitigation. Does the county have any unpreserved grassland left? Doesn’t matter, they’ll just call it “Tier I habitat” and mitigate it by buying an appropriate amount of “Tier I habitat” somewhere else. They’re all interchangeable on paper, after all.
But let’s be ecologists: why is there an unusual grassland there? It turns out that the boulders continue on underground, but they’re embedded in and mostly covered by really dense, shrink-swell clay. It’s a vertisol if you’re a soils nerd. This clay shrinks, cracks, and gets really hard when it’s dry, and swells into shoe-sucking adobe goo when it’s wet. This is classic habitat for vernal pools and San Diego thornmint (Acanthomintha ilicifolia), both of which are present next door in Wright’s Field. Vertisols are notoriously annoying to build on, not good places for trees, and known for making mud puddles out of lawns if the drainage isn’t exceptionally good.
So how do you turn a heavy clay slope into a flat set of lawns? Well, it doesn’t show in the park description, but there’s going to be a lot of earthmoving, terracing, and cut slopes. The clay will be removed to bedrock and pounded into impermeability. All plant roots in the soil will be removed and discarded, thereby blowing all that sequestered carbon into the air. New topsoil will be brought in, and drains…they will be made to happen no problem. If you’re wondering how far over budget this will go, so am I.
As for greenhouse gases, rather than admit that keeping a vast expanse of lawn going requires continual greenhouse gas emissions, it’s better to do accounting tricks to pretend it’s not a problem. This is normal for some developers. It gets annoying with a County that’s allegedly trying to go carbon neutral by 2035. They need to go well beyond going through the motions.
Wildfire, did you say? Why yes, it is in a very high fire hazard zone. But that’s okay, the park is up to code so it’s not only fireproof, it’s possibly a place where people can evacuate to. In reality, the landscaping is not up to the code the County passed last month (see my previous article), and the long, linear parking lots are completely surrounded by trees that hopefully won’t catch fire during a Santa Ana. And, hopefully, people trying to escape the park will be allowed onto South Grade Road, major evacuation route that it is.
And yes, I can go on, but this isn’t a rocket park, it’s a science fiction exercise, where the plan won’t match the reality. What’s really unfortunate is that, despite County claims that Alpine is deficient in park acreage, the numbers they present in the DEIR itself show this is not the case. Someone wants to build a big, 1990s style mega-lawn, and they’re going to do it come drought or high fire. I was even scolded at great length by a planner in a meeting, about how I didn’t appreciate everything wonderful they were doing for Alpine.
What does the site really need? Well, it contains the unofficial parking lot for Wright’s Field, and it gets a few dozen people per day. They just need to upgrade and formalize the dirt parking lot a bit, move a few boulders to keep big vehicles from driving onto Wright’s Field, write a RMP to keep the existing trails from proliferating, contract out the work to the Wright’s Field crew, and save the grassland as a habitat mitigation bank and carbon sequestration area. That’s pretty much what the surrounding community actually wants. But apparently listening and doing the right thing is rocket science these days.