CalVTP PSA Letter to USLTRCD 20 March 2023


Letter CFC to USLTRCD 3-20-23

Spencer Gordon, Project Manager (via email) March 20, 2023
US-LT Resource Conservation District
9481 El Camino Real
Atascadero, CA 93422

Subject: Cambria Reserves and Hearst Ranch Draft CalVTP PSA

Dear Mr. Gordon,

Thank you for the opportunity to review and comment on the proposed Cambria Reserves
and Hearst Ranch Forest Health Fuels Reduction Projects in Cambria, CA.
We have reviewed the draft CalVTP Project Specific Analysis, and the attached Coastal
Vegetation Treatment Standards. We support the project goals of improving the health of
the Monterey Pine and Coast Live Oak forest in the project areas, and we have the
following recommendations to improve the long-term results of the project.

The proposed removal of large numbers of healthy Monterey Pines and Coast Live Oaks
less than 8 inch diameter does not improve the health of the forest or reduce fire hazard.
Competition among small trees is necessary for forests to evolve and adapt to changing
climate conditions. Healthy Monterey Pines of all sizes have demonstrated that they have
the vigor, disease resistance and growing conditions needed to survive and become the
large trees of the future.

Retaining healthy trees of all sizes is necessary to maximize absorption of CO2 and
sequestration of carbon to control climate warming and the increased fire danger
associated with hot, dry, windy weather. Extensive removal of trees and other vegetation
can increase the rate of fire movement by reducing the windbreak effect of a dense forest,
allowing flames and embers to blow faster and further through the forest. Arbitrary goals
of trees per acre, minimum trunk diameters, and ratios of oaks to pines do not account for
local growing conditions and do not advance the goal of a healthy and safe forest. Only
dead, dying or diseased trees should be removed. We recommend that the PSA’s be revised to ensure that the maximum number of healthy trees are retained.

As stated in the Coastal Vegetation Treatment Standards, removal of trees and understory
vegetation will allow more sunlight to reach the forest floor. Unfortunately, this will result
in the proliferation of invasive non-native vegetation including French Broom and annual
grasses which are more flammable than the existing native vegetation. Past French Broom
burn piles in the Cambria area have often been located dangerously close to existing trees
and other vegetation. Use of portable curtain burners could be a cleaner and safer way to
dispose of French Broom slash. Efforts to cut or pull French Broom must be completed
before seeds form on the plants each year. After seeds form, any handling of the plants
will result in more seeds added to the “seed bank” in the soil.

The fire prevention goals of this project can be accomplished by the proposed shaded fuel
break and defensible space zones specified in the PSA’s. While we support the proposed
treatments in specified defensible space zones, we oppose expansion of defensible space
treatments to the remaining areas of the forest. The goal of this project should not be to
create a visually pleasing “park-like” setting, but should be to retain a mosaic of old and
young growth with diverse habitat structure to maintain wildlife cover and forage, and
prevent soil erosion.

The proposed use of mechanical treatments and mastication on the Monterey Pine and
Coast Live Oak forest understory is not compatible with the requirement to protect coastal
resources and habitat values in this ESHA area. The resulting extensive disturbance of
existing native vegetation and animal habitat will create hotter and dryer conditions in the
understory by reducing shaded areas, and will stimulate growth of flammable invasive
vegetation such as French Broom, Pampas Grass and dry annual grass varieties as noted

We recommend that the PSA specify the use of hand crews to lop and scatter dead
branches to minimize the collateral damage caused by mechanical mastication. Use of
hand crews to lop and scatter dead branches can be cost-effective if they do not attempt to
duplicate mechanical mastication by cutting down all understory vegetation. Proposed
broadcast and pile burning should not be used on these project areas to avoid the obvious
air quality, public health impacts and danger of fire escape.

We recommend adding a requirement to create at least two test plots of one acre each prior to beginning full project operations. These test plots will be used demonstrate the different outcomes of larger versus smaller diameter tree removal criteria, larger versus smaller numbers of retained trees per acre, and the different results of mechanical mastication versus hand crew cutting and scattering dead branches. Representatives of interested agencies and local organizations should be offered field tours of the test plots, and their observations and recommendations should be used as input to adaptive management of the project operations.

After full project operations are underway, representatives of interested agencies and
organizations should be offered field tours of each completed area. We suggest that
interested organizations such as The California Native Plant Society, the Cambria Forest
Committee and Greenspace the Cambria Land Trust be included on the field tours.

We recommend that the draft PSA’s and attached Coastal Vegetation Treatment Standards
be modified as outlined above to better achieve the project’s long term forest health and
fire safety goals, while minimizing unnecessary short and long term adverse impacts to the
coastal resources and habitat values of this important ESHA area.

Yours truly,

Crosby Swartz, President
Cambria Forest Committee

John Seed, President
Greenspace, The Cambria Land Trust


Bradley, C.M., C.T. Hanson, and D.A. DellaSala (2016) Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10): e01492.

Brennan, T.J. and J.E. Keeley (2015) Effect of mastication and other mechanical treatments on fuel structure in chaparral. International Journal of Wildland Fire, 24(7): 949-963.

Campbell, J.L., M.E. Harmon, and S.R. Mitchell (2012) Can fuel-reduction treatments really increase forest carbon storage in the western US by reducing future emissions? Frontiers in Ecology and the Environment, 10(2): 83-90.

Miguel G. Cruz, Martin E. Alexander, and Jelmer E. Dam (2014) Using Modeled Surface and Crown Fire Behavior Characteristics to Evaluate Fuel Treatment Effectiveness: A Caution. Forest Science 60: 1000-1004.

Miguel G. Cruz, Martin E. Alexander, and Paulo A.M. Fernandez (2008) Development of a Model System to Predict Wildfire Behavior in Pine Plantations. Australian Forestry 71: 113-21.

Zald, H.S.J. and C.J. Dunn (2018) Severe fire weather and intensive forest management increase fire severity in a multi-ownership landscape (2018) Ecological Applications 28(4): 1068-1080.

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