MEMO TO: ACT 2 Team, USFS Aug. 15, 2001

FROM: Mary Ann Matthews, Conservation Chair, Monterey Bay Chapter
California Native Plant Society

RE: DFPZ Project

Thank you for sending the Monterey Bay Chapter of CNPS a copy of the scoping
letter for the proposed DFPZ project for the Monterey Division of the Los
Padres National Forest. Because we only received the letter a few days ago
and the deadline is upon us, we have not been able to canvass many of our
knowledgeable members; but we would like to submit the following comments.
(By way of background, I studied fire ecology at Cal Poly and served for
over 15 years as State Forestry Coordinator for CNPS.)

While we support the concept of defensible zones from wildfire, we are very
concerned about the extent of the proposal outlined in your letter. If the
principal purpose is to prevent loss of life and protect structures, studies
show that the most critical factor is the 100-200 feet surrounding
buildings, as well as the construction materials used in the buildings
themselves. As this area is generally in private property adjoining the
forest, it would seem to us that the primary effort should be directed
toward educating property owners about actions to provide maximum protection
from fires. Those forest roads used for access to occupied structures should
be given top priority. We strongly question the need to treat the roads
adjoining wilderness where no structures are located. In any case, treating
roads up to 1000 feet on each side would intrude on designated or de facto
wilderness in many cases and would be excessive in most cases.

We are concerned by the proposal to plant native trees and manage for native
grasses, apparently after removing the native vegetation. As chaparral and
oak woodland are the dominant vegetation types on many of the roadsides
proposed for treatment, this sounds like type conversion to us, a scheme
that was tried in the 1980s South Coast Fuel Break. That project resulted in
the destruction of sensitive habitat and led to infestation by invasive pest
plants such as French broom. Those of us who regularly botanize along these
roads were disgusted by the mess that was made by bulldozers and later by
firewood collectors. The original intent was to maintain the fuel break by
the use of herbicides, but there was so much opposition to this plan on
public health, biological, and esthetic grounds that it was abandoned.
Ultimately the plants that were native to the sites, such as chamise,
manzanita, and ceanothus, grew back thicker than ever, except where they
were displaced by weedy non-natives. Perhaps the moral is: Mother Nature
bats last.

We have repeatedly seen that in worst-case scenarios, fires are only stopped
when the weather changes. In less-than-worst-case scenarios, many fires are
beneficial to the natural communities and should be allowed to burn as long
as they do not threaten developed areas. Prescribed fire is a useful tool
when it most closely mimics natural fire, but it needs to be undertaken in
small acreages over time to achieve a patchwork of young growth at different
stages of recovery. Following an accurate prescription is obviously
essential. Thinning and chipping is important in the immediate vicinity of
structures, but has not been shown to be cost-effective or desirable in the
natural forest more remote from developed areas; and often the type of
disturbance connected with this technique leads to invasion by non-native

We appreciate the helpful map which was enclosed with the Aug. 2 letter and
would like to make a few specific comments on the areas shown for treatment.
We realize the total of 18,760 acres is the maximum possible that would be
treated over a 10-year period, but even half that number seems unrealistic
and unnecessary. Major sections of the Nacimiento-Fergusson Road, the Cone
Peak Road, the Memorial Park Road, the Arroyo Seco Road, Piney Creek Road,
and Chews Ridge-Tassajara Road are vegetated by native chaparral, often
containing sensitive species of plants and animals, and have few or no
structures that need to be protected. Areas that have burned in recent fires
will obviously not need to be treated for a period of years that will depend
on specific community type, slope, soil, aspect, etc.

In summary, we would like to see this proposal go forward as pilot project
in areas with human-occupied structures that are most at risk--those in
areas with heavy fuel build-up, for example. As a general rule we see no
necessity for extending defensive zones into wilderness, or for that matter,
suppression of natural fires in wilderness. Since most fires are believed to
be caused by human activity along roads, selective and sensitive treatment
of the immediate road edge would be the most cost-effective and useful
method of minimizing wildfire potential. Further, the USFS should allocate a
portion of the suppression funds for educational and patrolling efforts and
should strictly implement fire season closures as necessary.

We hope we will have a more adequate opportunity to comment on the document
that comes out of this study.




Dear Ms. Matthews;

Thank you for your comments on the Monterey DFPZ project. The Forest
Service is in agreement with your points and would like to work closely
with the Native Plant Society to ensure the best outcome for this project.
Yours and other comments indicate that our letter did not do as good a job
of describing our proposal as we hoped. A couple of points that we should
have emphasized are:
1) All proposed activities would be on National Forest system lands
managed by the Monterey Ranger District and would be outside Wilderness
areas. There would be no treatment around private structures. Fuels
treatments around Forest Service Administrative structures are proposed for
this project.
2) There would be no wholesale vegetation management activities in any of
the proposed units.
-The acreage figures were displayed to indicate how much area is
within unit boundaries and not how much area would be treated.
-Variable width DFPZs were proposed with a maximum width of 1000 feet
to allow flexibility for treatments on small areas (no larger than 20
acres). Treatments within the variable width DFPZs would vary from no
treatment up to a 20 acre burn.
-Specific treatments of individual areas would be designed by a Forest
Service fuels specialists and botanist to be appropriate for existing
vegetation conditions and to have no effect on sensitive plants.
-Management for native grasses would be done in small areas < 1 acre
by enhancing conditions under which they could compete with other plants.
The only seeding that would be done would be where past management
actions, such as tractor fire line construction, has disturbed or removed
-Planting of trees would only be done in small areas where shaded
microclimate conditions would have beneficial effects on fuels composition
and where historic records indicate planting would emulate past
vegetation conditions.
3) Clearing of roadsides is not proposed. The only cutting proposed would
be to thin small areas where thick growth has developed continuous fuels
and to prune trees to break-up vertical fuel continuity.
4) There are no proposed type conversions. Our intent is to work at
enhancing existing vegetation conditions.

Your comments and suggestions will incorporated in a comprehensive analysis
and used in final project design. We hope to work closely with you on
this. Mike Foster ( , the Forest Service botanist
working on the project, will be coordinating directly with the Native Plant
society. He will be contacting you in the next month he doesn't hear from
you. There are also going to be some public meetings to discuss this
project and Fire Management Strategy for the Ventana/Silver Peak wilderness
areas (analysis not started yet). We will be sure you are on the mailing
list for these meetings.

Your issues will be fully addressed in the analysis and any suggestions you
have for refining final project design would be greatly appreciated. I
wanted to send this note off quickly to apologize for the slow mail and
short response period. Please take the time to canvas knowledgeable
members and get their feedback on this project. Input from your group is
very important for ensuring the best possible outcome for people and the

Thanks, Annie Buma - Project Manager


Dear Ms. Buma and colleagues:

Thank you for your amazingly prompt response to the comments emailed last
night on behalf of the Monterey Bay Chapter of CNPS. We appreciate being
reassured that there is no plan for type conversion and that the kinds of
vegetation management described in the letter of Aug. 2 would be carried out
on a much smaller scale than appeared to be the case in the letter. We are
well aware that the major problem in protecting private property from fires
originating in the forest (and vice versa) is that the USFS has no control
over those lands; however, we reiterate that public education both on
recommendations for vegetation management and construction materials should
be a significant part of the USFS effort. We earnestly entreat the USFS not
to repeat the mistakes of the South Coast Fuel Break plan of the 80s.

We look forward to working with you as this plan takes shape in order to
assure maximum protection for sensitive plant habitats on the forest.

Sincerely yours,

Mary Ann Matthews