Say No to a San Gabriel National Recreation Area

Voice your opposition by April 30.

I typically avoid using Dan’s Hiking Pages and Blog to engage in political issues. It’s about hiking and trails and helping folks enjoy the great outdoors.

But I’m venturing out on a limb to urge hikers and those who love the San Gabriel Mountains to say NO to the proposed San Gabriel National Recreation Area. The public comment period ends on April 30, so I would ask you to consider contacting Congresswoman Judy Chu and expressing your opposition to this proposed legislation.
Email Rep. Judy Chu: SGRec@mail.house.gov
(See sample letter below.)

There are three pieces of legislation that Rep. Chu is proposing:
1) San Gabriel National Recreation Area
2) Wilderness Designation (View map)
3) Wild and Scenic River Designation (View map)

The public comment period for the second and third items ends on May 30, and I will comment on those in a later post. So for now, I urge you to say no to proposed National Recreation Area (which is commonly being referred to as an NRA...not to be confused with the rifle folks).

For the last month I have done extensive reading, attended meetings, had various conversations, and dialoged with elected officials, municipal staff, and other community leaders. I’ve used every ounce of objectivity and mental acuity to arrive at a reasonable and informed understanding of the proposed legislation. I admit that it’s a complex issue and that I don’t claim to have all the answers or to be an expert. But I’ve always believed that normal citizens should be able to evaluate a piece of legislation from a lay person’s perspective and reasonably sense whether the law is good or not. If the complexities of the proposed legislation overwhelm us and we simply abdicate the decision to the “experts,” then it’s probably not a good law.

I do not believe the proposed San Gabriel NRA is good legislation. You may read the draft legislation for yourself. It is 37 pages, but it is double spaced and has real wide margins. The possible consequences if this law is enacted are enormous, so it’s worth taking some time to read the legislation and become informed.

Before I give my reasons for opposing the proposed legislation, here are the stated purposes within the draft legislation:

SEC. 3. ESTABLISHMENT OF SAN GABRIEL NATIONAL RECREATION AREA.
(a) PURPOSES.—The purposes of this Act are—.
(1) to conserve, protect, and enhance for the benefit and enjoyment of present and future generations the ecological, scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources of the recreation area;
(2) to provide environmentally responsible, well-managed recreational opportunities within the recreation area, and improve access to and from the recreation area;
(3) to provide expanded educational and interpretive services that will increase public understanding of and appreciation for the natural and cultural resources of the recreation area;
(4) to facilitate the cooperative management of the lands and resources within the recreation area, in collaboration with the State and political subdivisions of the State, historical, business, cultural, civic, recreational, tourism and other nongovernmental organizations, and the public; and
(5) to preserve the discretion of all persons, entities, and local government agencies in activities relating to integrated water management, flood protection, water conservation, water quality, water rights, water supply, public roads and bridges, and utilities affecting the recreation area.

These purposes sound wonderful. Who wouldn’t want those things?! As a hiker and lover of the outdoors, I applaud the objectives. Just look at the verbs: conserve, protect, enhance, provide, facilitate, preserve. These are good things. I believe, however, that the legislation is fundamentally flawed and is not the answer.

Here are my primary reasons for opposing the proposed San Gabriel National Recreation Area:

1. Bloated federal bureaucracy
2. Lack of clear boundaries
3. Lack of public awareness
4. Catering to special interests
5. Environmental extremism
6. Misguided expectations
7. Hidden agendas
8. Possible loss of use and access
9. Lack of funding

1. Bloated federal bureaucracy. Superimposing the U.S. Park Service on top of the U.S. Forest Service in cooperative roles in our San Gabriel Mountains seems to me to be misguided. For one, it seems improbable that this arrangement wouldn’t lead to redundancy, inefficiency, and waste. Really, one need not have a Ph.D. in U.S. Government to recognize a likely boondoggle.

And this for me is the elephant in the room. Groups like the San Gabriel Valley Council of Governments (COG) have been thoroughly vetting the fine details of the legislation and diligently working with Rep. Chu to ensure that such things as water rights and private property rights are protected. But I’m not hearing many of those in an official capacity step back and ask, Is this whole NRA idea the best approach? In other words, the focus tends to be upon mitigating the bad things the NRA could do to us and ignoring whether or not it will accomplish its goals in an efficient manner.

It’s like if someone invents a complex gadget for buckling a belt. You stand in front of the mirror and two mechanical hands emerge from the wall and manipulate the ends of the belt until it is snuggly fastened around your waste. Never mind that it takes three minutes for the process and the machines cost $25K, Underwriter Laboratories found it to be safe and free from mechanical flaws with no negative impacts on the interior environment. And that’s how I feel about this proposed NRA legislation; if it is fundamentally a bad idea, you can vet the snot out of it and it’s still a bad idea.

Another concern about the bureaucracy is the question, Do we really think that two different cabinet agencies can play well together? The USFS is under the Department of Agriculture and the USPS is under Department of Interior. I’m sorry, but I just don’t have any confidence that that arrangement would work well.

I think the best solution would be for Congresswoman Chu to focus on fixing both agencies for optimum effectiveness. How about moving the USFS into the Department of Interior? That way both the Parks and the Forests and under one umbrella! I really believe that the best solution is to reinvent the Forest Service for the 21st Century.

2. Lack of clear boundaries. Boundaries as shown on NRA map are fuzzy and unclear and there is no technical legal description provided. The draft legislation states, “As soon as practicable after the date of the enactment of the Act, the Secretary shall file a map and legal description of the recreation areas…” That means we won’t know for sure what the boundaries are until the law is passed! That’s huge! And there have been a lot of officials raising that point. (View full map)

Obviously when they drew the map, they had very specific purposes of where the boundary is. And the boundary would correspond to GPS data points. The Feds have that information but they won’t release it to the public. All we have is this map with a fat, fuzzy line. Look at this map section from Azusa to Claremont. It looks like the line roughly outlines the base of the foothills, but provides no detail. Are there homes and businesses within that boundary or up against that boundary?

All this begs the question, Why does Rep. Chu withhold that information? Is it because she does not want to alarm local residents when they see the NRA boundary running along their back fence? It seems very likely to me that the fuzzy boundaries are a cunning tactic rather than an innocuous oversight or inability to find a GIS professional to render a clear map for public inspection.

In a letter to Judy Chu dated March 27, 2014, State Senator Bob Huff makes this point: “It appears from the preliminary maps that residential properties could be located within the NRA, and I believe the potential impacts to the property owners must be fully understood prior to any decision making.”

Unfortunately, from what I can tell, the vast majority of residents in or near the NRA boundary are completely unaware of the legislation and how it may impact them. For example, in Azusa, where I live, it does not appear that there has been any effort by the city to communicate with home owners who may be affected. Yet Councilman Angel Carrillo voted at the San Gabriel Valley Council of Governments (COG) to endorse the legislation anyway. At the Glendora city council meeting on April 22, several residents expressed their concerns about the NRA boundary. Mayor Judy Nelson made a motion to provide more information to the public, including a letter to all owners of affected properties. The council rejected that motion and resolved instead to endorse the legislation (Ayes: Davis, Tessitor, Santoro; Nay: Nelson; Not present: Murabito).

It’s been very troubling to me to observe what seems to be a rush by officials to move the legislation along, almost as if to get it passed before the public wakes up to the reality of what the Feds are trying to do. But in all fairness, many of these officials have been studying the evolution of the legislation for years and may just be eager to move on with it. My sense is that the deadlines for public comments are artificially imposed by Rep. Chu and create undue haste to sidestep public awareness.

3. Lack of public awareness. It appears to me that the public is woefully unaware of Rep. Chu’s legislation and have not been given adequate opportunity to understand it and provide comments. The congresswoman has hosted some town hall meetings this past year in the San Gabriel Valley, however, I never heard about them and am running into many people who have never heard about the meetings nor are aware of the legislation.

Some of those who attended town hall meetings have expressed that they felt the meetings were highly orchestrated and more like propaganda machines than an honest public forum. They say that questions were submitted by attendees, but event leaders were selective of what questions were publically addressed; questions that raised salient concerns where conveniently buried.

In my City of Azusa, I’ve not seen any communication about the NRA and its possible impacts on our community…and we are the Canyon City! I’ve found nothing on the city website. I’ve sent several emails to city council members and made comments at a recent council meeting, but the council seems to be uninterested in holding a community forum and agendizing a public hearing. I have specifically requested that each council member publically state his position regarding the NRA. Councilmen Angel Carrillo and Uriel Macias have both responded via email and publically in the meeting. Mr. Carrillo supports the NRA and voted for the COG to endorse it (the city manager stated that Carrillo is free to cast votes at the COG according to his own judgment representing the city with no obligation to represent a consensus). Mr. Macias expressed concerns about the legislation, particularly the impact the NRA may have on infrastructure and first responders in Azusa due to increased traffic. He also feels the legislation does not provide adequate representation on the oversight entities. Mayor Rocha and councilmen Gonzales and Alvarez remain strangely silent. My impression is that there is no sense of need for the public to be aware of and engaged with the proposed legislation. And that’s a colossal irony in that there are hundreds of acres of private property in Azusa that are included in the proposed NRA boundaries.

I’ve heard city leaders report that Rep. Chu has been transparent, engaging, and responsive to input. And indeed she has made many revisions to the draft legislation in response to feedback. My sense, however, is that she has been focused on stakeholders and special interest groups and largely skirted the general public.

4. Catering to special interests. I’ve been to two meetings recently where the public was given the opportunity to comment on the legislation. One was a meeting of the COG governing board on April 17. There were 17 persons who made comments. Of those, 13 were opposed to the legislation. Most of them were just folks from the community, and many of them had only heard about the proposed NRA recently. The four speakers who spoke in favor of the NRA were representing organizations like the Sierra Club and the Wilderness Society. These kinds of speakers are usually paid lobbyists promoting their special interests. The young woman from the Sierra Club was touting their thousands of supporters. But why couldn’t she get a few of those to come with her? And who are they and what zip codes do they live in? And what was the mechanism used to gather those “supporters”? Was it a button on their website that said, “If you would like to protect the San Gabriel Mountains, click Like.”?

At the Glendora city council meeting on April 22, there were 15 speakers…10 were against the NRA and five were for it. All those who spoke in favor of the NRA were reps from special interest groups and three were the same lobbyists who were at COG meeting. It appears that they just cycle through the various cities and meetings and expect the “thousands” in their back pockets to trump the concerned local citizens. One of the speakers was a young man in training with the San Gabriel Mountains Forever Leadership Academy and learning to be a lobbyist like the paid lobbyists of the academy staff. When asked by a local member of a successful environmental group why he knew about the relatively new Forever group, but never involved himself in helping in the local San Gabriel Mountains and foothills, there was no reply! He just walked right on by and gave out his tech business card...not even an environmental card!

I don’t want to dwell on anecdotes, but they help illustrate the nature of special interest groups. These groups don’t represent the majority, and their activism creates an illusion of wide-spread support for legislation.

One speaker, George Sanchez, was representing the Wilderness Society. Headquartered in Washington DC, they have been around for nearly 80 years and appear to be a big player in the public lands arena. He mentioned that he leads the Leadership Academy for San Gabriel Mountains Forever (SGMF). When I looked through their website, it appears to me that they are a front for the DC based Wilderness Society. SGMF claims to be “a diverse partnership of residents, cities, local business owners, faith and community leaders, health and environmental justice organizations, and recreation and conservation groups that are working to protect the San Gabriel Mountains and Watershed.” That sounds great, but how real are their partnerships? They mention “conservation groups” yet they have never talked with the leadership of such local groups as the Glendora Conservancy and the San Gabriel Regional Conservancy and sought to understand the significant work they do in local conservation. This is mind boggling to me! How can they talk about being a diverse partnership of residents to protect the San Gabriel Mountains and watersheds without ever making an effort to connect with key, grassroots players who are in the trenches of local conservation?

Again, the COG can vet the snot out the NRA yet ignore the big picture of who is driving the legislation and the hidden agendas of the Feds and special interest groups to come in and overshadow local interest and control.

5. Environmental extremism. It seems that this NRA (particularly when taken together with Wilderness and Wild and Scenic) kowtows to environmental zealots. These aren’t bad people. It’s just that their passion for the planet fosters ideologies that are out of line with mainstream America. And some of these groups have powerful lobbyists who strongly influence legislation and policies. Now the good side is that they have made significant contributions for preserving our environment. The downside is that policies can become out of balance and driven by the minority. Some of these environmental zealots have been at odds with the Forest Service. So they are doing an end run to accomplish their agenda by pushing an NRA which is more favorable to their ideologies.

Part of my concern is what I see as a radical prioritization of the needs of animals over the needs of people. We see the water crisis that occurred in Central California when water was prioritized for the delta smelt. What are the potential losses to recreation and water supply if our San Gabriel River is prioritized for the Santa Ana sucker? And look at the Williams Rock area in the Angeles National Forest: 1,000 acres of pristine, beautiful recreational resource, along with a portion of the historic Pacific Crest Trail, closed indefinitely because of a yellow legged frog. Do we really think giving the Feds and environmental extremists more control of our mountains will enhance recreational use?!

I don’t pretend to understand all the complexities of proposed NRA (and the Wild and Scenic and Wilderness), but it sure seems to me that the very heart of this proposed law is about expanding the role and control of the federal government and about advancing the agenda of environmental extremists.

6. Misguided expectations. There is an implied tone within the NRA legislation that the U.S Forest Service is failing to appropriately steward the natural resources and provide acceptable recreational opportunities. So the Park Service is the savior. But what can they really do that the Forest Service can’t do without more money and some reinvention? Look at the West Fork San Gabriel River on a typical holiday weekend like Labor Day. There will be a gazillion people there…leaving tons of trash and dirty diapers, trampling the vegetation, vandalizing facilities, building dams, blasting their music, yelling and screaming, urinating in the river. What can a Park Service employee do that the Forest Service employee can’t do? Does a park ranger have some magical power to prevent people from peeing in the river? What mystical education plan can they possibly offer to keep yahoos from littering? Does Park Service signage have special power to make people act civilly? Really, do we actually think we can legislate behavior? Oh I know, they’ll put up beautiful interpretive signs which will miraculously make everyone love nature. Yeah right, like PS signs will fare better against vandals’ spray paint than FS signs! Are they going to install spray paint detectors at every forest entrance and trailhead? How will an NRA keep idiots from cutting switchbacks and carving their initials in trees?

The NRA promises “to provide expanded educational and interpretive services that will increase public understanding of and appreciation for the natural and cultural resources of the recreation area.” What a bunch of empty clichés! Proponents for the legislation are claiming to have widespread public support for the NRA. Well, of course people are going to express desire to see the ideals promised in this legislation come to reality. But that doesn’t prove that the NRA is smart solution. It just proves that people are fed up with federal government deficiencies. So do we really believe that bringing in one ailing department of federal government to prop up another ailing department of federal government is the answer? That’s the elephant in the room. Again, I think the real answer is to reinvent the USFS for 21st century and give them enough money to fulfill the lofty ideals that are touted in this legislation.

7. Hidden agendas. This ties in closely with the other points. I’m not a conspiracy theorist and don’t know the extent of what might be behind this NRA and other legislation. All of us have hidden agendas to some degree; it’s part of navigating life and using tactics to get what we want. But I think transparency and honesty are the best approach.

One point of specific concern I have is the proposed boundaries and what is the intent of encompassing open spaces beyond the National Forest boundary. Why can’t the NRA boundary be congruent with the ANF boundary (aside from the Emerald necklace)? Why do the Feds want to extend their reach into hundreds of acres within the cities of Azusa and Glendora and other foothill communities? The legislation makes assurances that they won’t take away local control or impose regulations over non-federal lands. But if they are not going to affect those lands in any way, why include them?

This is a huge issue for me. I don’t want the federal government extending its reach beyond federally-owned lands into my backyard. And I suspect that there is some unspoken intent that by including non-fed property into an NRA, at some point it will provide at least a small foothold as a starting point for the Feds to move toward greater control. Even if the language in this draft is solid in its assurances, we have no idea how that could change once it makes it into congressional sub-committees and to the floors of the House and Senate. We don’t know what changes Rep. Chu may make to the legislation before submitting it to Congress. Even just striking a few words or phrases here or there could make a huge difference in how the law will impact our lives and local open spaces.

8. Possible loss of use and access. The proposed legislation makes lots of assurances on what it won’t do (for example, supposedly it won’t take private property or water rights, etc.) but it is scant on what it will do. That’s left to the management entity to draw up a plan. It speaks of protecting and preserving the natural spaces, which are code words for adding regulations, restrictions, and prohibitions. The very nature of protecting something is to guard it and restrict its use. If we want to keep a lawn from showing wear, we put up a sign, “Keep off the grass.” This legislation seems to me to have more potential to restrict use than it does to open up the forest for greater access and use. As an avid hiker, I have unparalleled access to my beloved San Gabriel Mountains. What possibly could an NRA do to enhance that? On the other hand, there are examples of how NRAs and other federal designations across the country have targeted the closure of ski areas, closed down forest roads, restricted public access, and so on. (Read example of Yosemite)

9. Lack of funding. In the meetings and conversations I’ve been in over the past month, a question I hear frequently asked is, How much is this NRA going to cost and how is it going to be funded? And I’ve not heard the question answered! And oddly enough, if you look at Rep. Chu’s FAQ page, the question is not even there:
http://chu.house.gov/content/san-gabriel-national-recreation-area-proposal-faq

The reality is, both the USFS and the USPS have had significant cutbacks over the years that have caused a reduction in services to the public. I believe it is irresponsible to support legislation without a clear funding plan.

Conclusion and Contact Information

Creating a San Gabriel National Recreation Area has noble objectives but is not the answer. It makes no sense to take one broken department of government and lay it over another. The solution is to reinvent the U.S. Forest Service for the 21st Century. Perhaps it would be good to move it over to the Department of Interior so that the Forest Service and Park Service are under the same cabinet secretary.

Voice your opposition to the proposed NRA by April 30. Let’s thank Congresswoman Judy Chu for her gallant efforts for recreation and the environment, but urge her to find on a better solution.

Email Rep. Judy Chu: SGRec@mail.house.gov

Here is the letter I sent:

April 25, 2014 The Honorable Judy Chu Congresswoman, 27th District 527 S. Lake Ave, Suite 106 Pasadena, CA 91101 RE: Opposition to the San Gabriel National Recreation Area Dear Congresswoman Chu, I applaud your desire and efforts to increase recreation opportunities and protection of our wilderness and natural resources in the San Gabriel Mountains and Valley. These are incredible treasures for millions of Southern California residents. I do not believe, however, that the creation of the San Gabriel National Recreation Area is the right solution. Superimposing the U.S. Park Service on top of the U.S. Forest Service in cooperative roles in our San Gabriel Mountains seems probable that this arrangement would lead to redundancy, inefficiency, and waste. I think the far better solution would be to focus on fixing both agencies for optimum effectiveness. How about moving the USFS into the Department of Interior? That way both the Parks and the Forests are under one umbrella. But regardless of the department, the Forest Service should be reinvented for the 21st Century and resourced to effectively fulfill the kind of purposes stated in the proposed NRA. One point of specific concern I have is the proposed boundaries and what is the intent of encompassing open spaces beyond the forest boundary. Why can’t the NRA boundary be congruent with the Angeles National Forest boundary (aside from the emerald necklace)? Why do you want to extend federal reach into hundreds of acres within our foothill communities? The legislation makes assurances that you won’t take away local control or impose regulations over non-federal lands. But if the legislation is not going to affect those lands in any way, why include them? I would rather see those lands kept out of the NRA boundary. Thank you for your consideration. Sincerely, Dan Simpson Azusa, CA