HOPE - Helping Our Peninsula's Environment

Box 1495, Carmel, Ca 93921 / 831/624-6500

 Board of Directors

Monterey Bay U. Air Pollution Control District May 14, 2002

Re: DEIR Smoke Management Program (SMP)

SCH 20011221144

Dear Board and Staff,

We apologize that these comments are at the last minute, but our analysis resources are stretched to the limit (with comments on Fort Ord's RI/FS, General Plans from Monterey County (we do appreciate and support your comments on the harm from diesel) and Monterey City and some 3 dozen other projects).

Neither I, nor any of HOPE's decision makers, will benefit financially from our recommendations here.


There is a lot to like in the proposed program.


However, we are startled and alarmed with the response (on page 3)

"...the objective of the SMP is to allow for increased burning." !!!

We are strongly opposed to this goal.

Having expertise in the extremely low occurrence of thunderstorms and natural lightning caused fire for the Monterey Bay Area we find no ecosystem health basis for any human subsidy of burning - a clearly deadly activity both directly from flames and indirectly through smoke.

Third, we strongly oppose allowing a burn to exceed the AQMP budget.

As the document itself admits it would be inconsistent with the AQMP (p 4-18). As we understand the Clean Air Act the AQMP must be revised before CARB or the USEPA can allow any exception or inconsistency to it.



There is no evidence presented to support this. This unsupported idea is from Harold Biswell's book which admittedly has no explicit references. "I have not documented the text (and deluged the reader) with reference after reference." Biswell, p 17 This makes Biswell's references unverifiable.

There is abundant evidence that lightning caused fires are rare - probably occurs less often than every 500 years, and potentially burn the entire base no more often than tens of thousands of years, if ever.

"The lowest incidence of lightning fires in California, by far, in the 1970's decade occurred in the Santa Cruz/San Mateo, Sonoma and Monterey/San Benito County Ranger units according to a U.S. Forest Service analysis of some 76,000 fires throughout California (Keeley)." (Jon Keeley's 1982 work - See Figure 1)



Backing this up are multiple lines of research including Burton L. Gordon's book which states "Having searched written records covering some 125 years (and consulted local park rangers and city fire departments), the writer concludes that it is impossible to extrapolate a credible natural burn cycle of less than 500 years for the coastal half of the Monterey Bay area-and for the inland half, less than 300 years."


Lightning Rare Near Sea Level Elevation

Lightning strikes and rainfall generally increase as an air mass lifts to traverse land rising from the sea. Similarly, lightning strikes decrease in number as land forms lower to sea level (Gordon). Keeley's USFS study of 100,000 fires in California in the 1970's under USFS jurisdiction found less than one percent of lightning caused fires occurred below 250 meters (800 feet) in elevation. This must be tempered by the fact that Forest Service has relatively fewer lands at or near sea level. Unfortunately, CDF data covering more lower elevation lands did not include fire altitudes. As far as I can determine no part of the proposed burn areas exceeds 830 feet above sea level. Thus, lightning strikes causing natural fires at this location are highly likely exceedingly rare.



Fish & Wildlife Service stated "Burning...may have a positive effect because the maritime chapparal community that supports sand gilia and Monterey spineflower is adapted to occasional natural fires." FWS Mar 1999 p 14

This is a wildly unsupported and highly misleading conclusion.

Having completed two Freedom of Information Act requests on the Ventura office on exactly this information I can state there is no evidence in this record or at Fish & Wildlife Service (unless they withheld information which would be a violation of law) that any ESA listed plant species at Fort Ord needs fire for regeneration. The evidence that does exist, solidly refutes the FWS conclusion.

Further, consider the headline from a 30-Nov-2001press release announcing the December 2001 Conservation Biology issue focusing five articles on prescribed burning.

"Prescribed Burning: Do we really know what we're doing?"

"New research shows that prescribed burning may be used too widely. The theory is that by reducing the unnatural fuel buildup caused by decades of fire suppression, prescribed burning reduces the risk of catastrophic fires. But, this theory doesn't fit all ecosystems and prescribed burning can sometimes cause more harm than good."


"Although prescription burning has proven to be a viable means of reducing fire hazard in some forest types, it is not appropriate for the boreal forests of Canada and the chaparral shrublands of southern California," says Jon Keeley of the USGS in Sequoia-Kings Canyon National Parks, Three Rivers, California. Keeley and other researchers explore fire management in five papers in the December issue of Conservation Biology.


The EPA's comments on the Army RI/FS asserts that "a second unnatural burn that took place before mature chaparral species could produce seeds could destroy the habitat permanently." (RI/FS p D2)

This is a significant unrecognized environmental impact. Please revise the DEIR.

Rhetorically - if burning is so natural, and so frequent, how has the ecosystem survived this principle?

SMP Page 4-43 "Generally, prescribed burning is believed to benefit the overall health of the fire-adapted ecosystem."

There are serious problems with this assertion.

1) This came from a report about the Sierra Nevada - which may not apply to the Central Coast.

2) "fire-adapted ecosystem" is not defined thus is untestable or unfalsifiable making it only an opinion - not a scientific claim.

3) "overall health" is not defined thus is untestable or unfalsifiable making it only an opinion - not a scientific claim.


SMP Page 4-43 "the communities proposed for treatment have evolved with recurring fire..."

There are serious problems with this assertion.

Which communities?

In any case there is no supporting evidence in the record for this.

The evidence which does exist, strongly contradicts the concept that fire is frequent enough to influence a Monterey Bay area plant or one of its ecosystems.


SMP "Some rare natural communities, such as cypress forests, bishop pine forests, Monterey pine forest, are adapted to fire and require fire to remain viable."

There are serious problems with this assertion. This is wholly unsupported by any evidence and the evidence which does exist strongly contradicts the concept that fire is frequent enough to influence a Monterey pine forest or a Monterey Cypress forest, or its ecosystems.

SMP "The loss of individual plants within rare natural communities is considered less-than-significant because ...."

We find this false. The correct interpretation of CEQA and case law (Guideline 15065 and Mira Monte Homeowners Association) is stated in the page's last sentence "Either direct mortality or harm to one individual or habitat degradation is considered a significant impact on these species."

While Monterey pine are not yet officially ESA listed, Yadon's piperia and 29 other officially listed and protected plant species are, live in its understory and depend upon Monterey pine forest habitat.

SMP Page 4-40 second paragraph

We suggest the following text changes.

Change from "The plant communities..." to "Some plant communities..."

Change from "dynamics of these communities..." to "dynamics of some communities..."

No evidence that decreasing burns can increase wildfires.


250 acre Limit is Too Big - Use 25 acres.We recommend requiring Smoke Management Plans for fires of 25 acres and larger. As you may know the 1997 Fort Ord burn was only planned to burn 32 acres, burned some 700 acres and its impacts to human health, our natural environment and our local political climate continue today.

(Page 4-5) Please add the phrase "32 acre" in the sentence "a prescribed burn in 1997 at the former Fort Ord..." so it reads "a 32 acre prescribed burn in 1997 at the former Fort Ord..."

SMP The phrase "Fire-intolerant plants are killed by fire." p 4-40 is either puzzling or incomplete. All plants are killed by fire. There is simply no plant that can survive a sufficiently hot or long duration fire. Please remove or clarify this statement.

SMP Page 4-41 states there are 60 special-status wildlife species located in the Central Coast. A list of only 33 follows.

We are alarmed that the DIER could be used to justify creating 1300 foot wide fuelbreaks (p 4-4)

SMP Table 4-1 does not add up unless the sign is reversed from "<2000" to ">2000".

SMP Page 4-8 fourth paragraph could be improved by mentioning that "the velocity of wind and volume of air at night is some ten times smaller than during the day."

SMP Page 4-35 Under the Emergency Spill Containment Plan - we feel it should have a mandatory training component.

Page 4-38 (last paragraph) What does the "91,000" mean?


We respectfully request this document be set aside until the next Board meeting and revised to address our very serious concerns.

With all due respect,

David Dilworth, Executive Director


Gordon, Burton L., 1996. "Monterey Bay Area: Natural History and Cultural Imprints", Boxwood Press, Pacific Grove, California. 375 p.

 Keeley, Jon E., 1982. "Distribution of Lightning and Man Caused Wildfires in California", General Technical Report. PSW-58. Berkeley, CA: Pacific SW Forest and Range Experiment Station, USFS, U.S. DoA.