California Natural Resources Agency writes a BIG blank check to the “restoration” industry

California Natural Resources Agency has published the draft of “Pathways to 30X30 California” and has invited the public to comment on the draft by February 15, 2022.  “Pathways to 30X30” is the last in a series of documents that defines the program before implementation in February 2022, when distribution will begin of $15 Billion dollars to public and non-governmental agencies to fund specific projects. 

To recap the process that began in October 2020 with the passage of an Executive Order:

  • In October 2020, Governor Newsom signed Executive Order N-82-20 “enlisting California’s vast network of natural and working lands – forests, rangelands, farms, wetlands, coast, deserts and urban greenspaces – in the fight against climate change. A core pillar of Governor Newsom’s climate agenda, these novel approaches will help clean the air and water for communities throughout the state and support California’s unique biodiversity.” The program and its implications are described by Conservation Sense and Nonsense HERE.
  • California Natural Resources Agency held a series of public workshops in summer 2021 that were theoretically an opportunity for the public to participate in the process of defining the program.  Conservation Sense and Nonsense identified potential opportunities as well as pitfalls of the program HERE.
  • California Natural Resources Agency published the first draft of implementation plans in fall 2021.  Conservation Sense and Nonsense published its favorable opinion of the first draft that is available HERE.

The draft of the final implementation document is disappointing.  My public comment on the draft of “Pathways to 30X30” is below.  To preview it briefly here, this is its concluding paragraph:  “California’s 30X30 initiative had great potential to improve the environment rather than damaging it further.  Instead, draft “Pathways to 30X30” suggests that opportunity may be squandered.  Of course, the proof will be in the projects, but for the moment it looks as though the lengthy public process may have been a charade intended to benefit the “restoration” industry, not the environment or the public.”

Please consider writing your own public comment by February 15, 2022.

  • Email: CaliforniaNature@Resources.ca.gov;
  • Letter via postal mail: California Natural Resources Agency, 715 P Street, 20th Floor, Sacramento, CA 95814;
  • Voice message: 1 (800) 417-0668.
  • There will be a virtual meeting on Tuesday, February 1, 2022, 3-6 pm in which the public will be invited to make 2 minute comments.  Register HERE.

TO:        California Natural Resources Agency

RE:         Public comment on draft “Pathways to 30X30”

I have attended the public workshops regarding the 30X30 initiative and sent written feedback when given the opportunity.  I am therefore in a position to tell you that the “Draft Pathways to 30X30” is a significant retreat from principles defined by previous drafts because it is so vague that it is meaningless. Any project could be approved within its limitless boundaries. The document puts CNRA in the position to do whatever it wishes, including violate principles defined in previous draft documents.

My public comment is a reminder of commitments made in previous drafts and a request that they be reinstated in the final version of the Draft “Pathways to 30X30” document:

  • “Pathways to 30X30” must confirm its commitment to reducing the use of pesticides on public lands.  The draft mentions the need to “avoid toxic chemicals” only in the context of working lands.  That commitment must also be made for public parks and open spaces because widespread pesticide use is exposing the public and wildlife to dangerous pesticides and killing harmless plants while damaging the soil.
  • Unlike the previous draft, “Climate Smart Strategy,” “Pathways to 30X30” requires the exclusive use of native plants, which contradicts the commitment to “promote climate-smart management actions.”  The ranges of native plants have changed and must continue to change because native plants are no longer adapted to the climate.  We cannot reduce greenhouse gas emissions causing climate change if we cannot plant tree species that are capable of surviving in our changed climate, as acknowledged by previous draft documents. As Steve Gaines said in the January 12th public meeting regarding “Pathways to 30X30,” “We must help species move [because the changing climate requires that they do].”

There are significant omissions in “Pathways to 30X30” that epitomize my disappointment in this draft:

  • The draft kicks the can down the road with respect to integrating climate change into consideration of projects funded by the initiative:  “Designations have not yet been established that emphasize climate benefits such as carbon sequestration or buffering climate impacts. While the definition of conserved lands for 30×30 builds upon existing designations, it will be important to integrate climate…” (pg 26)  Climate change is the underlying cause of most problems in the environment, yet “Pathways to 30X30” dodges the issue by declining to take the issue into consideration as it distributes millions of grant dollars to projects that are toxic band aides on the symptoms of climate change.
  • The 30X30 initiative made a commitment to protecting 30% of California’s land and coastal waters.  At 24%, we are close to that goal for land, but at only 16% we are far from the goal for coastal waters.  Yet, the draft declines to protect more marine waters:  “MPA [Marine Protected Areas] Network expansion will not be a component of meeting the State’s 30×30 marine conservation goals.” (pg 29, deeply embedded in fine print) The excuse for this omission is that the decadal review of existing MPAs won’t be completed for another year.  That is not a legitimate reason for refusing to designate new MPAs.  The evaluation of existing MPAs can and should be completed and inform the management of new MPAs going forward. 

The lack of guidance in “Pathways to 30X30” is particularly dangerous because California law has recently been revised to exempt projects considered “restorations” from CEQA requirements for Environmental Impact Reports for three years, ending January 1, 2025. An Environmental Impact Report is the public’s only opportunity to preview planned projects and challenge them within the confines of CEQA law.  The public is effectively shut out from the process of distributing millions of grant dollars of the public’s tax money by this blanket exemption on CEQA requirements for an EIR. 

The Draft of “Pathways to 30X30” writes a big blank check for projects that will potentially increase the use of pesticides on our public lands and increase greenhouse gas emissions by destroying plants and trees that sequester carbon and are capable of surviving our current and anticipated climate. 

California’s 30X30 initiative had great potential to improve the environment rather than damaging it further.  Instead, draft “Pathways to 30X30” suggests that opportunity may be squandered.  Of course, the proof will be in the projects, but for the moment it looks as though the lengthy public process may have been a charade intended to benefit the “restoration” industry, not the environment or the public. 

Update on California’s 30X30 initiative: The good, the bad, and the ugly

In May 2021, Conservation Sense and Nonsense introduced California’s $11 billion investment in addressing climate change and protecting biodiversity by protecting 30% of land and coastal waters by 2030 (30X30). Since then, the California Natural Resources Agency (CNRA) held a series of workshops to explain the initiative and give the public an opportunity to provide feedback to CNRA.  Sixteen hundred Californians participated in those workshops, including me. Today I am reporting what I learned about the initiative and tell you my opinion of what I learned.

Update: The final California budget commits $15 billion for climate change and protecting biodiversity.

Good news always comes first

The Land Conservation Panel identified the opportunity to remediate degraded spaces that will address many of the objectives of the 30X30 initiative.  Many degraded spaces are found in poor communities that are exposed to toxic waste and pollution.  Eliminating public health hazards in these communities will not only improve their health, it will make those spaces available for recreational and other purposes.  Here are just a few of many such opportunities in California:

Superfund sites in California as of 2013. Source: Environmental Protection Agency
  • There are 94 toxic waste Superfund sites in California.  Where these sites are threatening the health and safety of the public they should be high priorities for remediation.  For example, nearly 30,000 corroding barrels of DDT were recently found on the ocean floor near Catalina Island.  The extent of that particular toxic dump was not known at the time the LA Times reported it, but investigating scientists speculated that as many as half a million barrels may have been dumped by the manufacturer of DDT.
  • There are 47,000 abandoned mine sites in California, according to the Bureau of Land management.  84% of those sites present physical safety hazards and 11% of the sites present environmental safety hazards.  Abandoned mine sites that are potential recreational areas in underserved communities should be considered high priorities for remediation.
  • The California Clean Water Act identifies “impaired waters.”  The list of impaired waters is long and it is alarming.  It identifies pollution with toxic substances such as mercury, diazinon, sewage from leaking septic tanks, sedimentation from erosion, run off of agricultural chemicals, etc.  Addressing these issues will reduce public health hazards and improve fish and wildlife habitat.  Most rivers in California are ultimately watersheds into the ocean, therefore cleaning up these “impaired waters” will also improve ocean health.  At this time of extreme drought and the expectation of continuing drought, water quality should be a high priority for the 30X30 initiative.
  • There are over 5,000 orphan oil wells in California with no known responsible operator.  Capping and retiring these oil wells would reduce health hazards and make the land available for recreational and other uses.  These abandoned oil wells are frequently found in economically disadvantaged areas such as Bakersfield and poor areas in the Los Angeles basin, which is all the more reason to remediate this blight on the landscape. 

The remediation of hazardous pollution would benefit Californians, reducing health hazards for humans and wildlife and potentially making land available for other useful purposes.  Remediating polluted, dangerous land must be a higher priority than funding the horticultural preferences of hobbyists with romantic notions about recreating a landscape that is long gone and cannot be replicated.  If we are to achieve durable objectives, we must have realistic expectations and goals that are consistent with current and anticipated climate conditions.  Thriving landscapes that do not require irrigation should not be replaced with fragile landscapes that require irrigation and access restrictions.  No land that requires pesticides to accomplish “conservation” goals can legitimately be called “conserved.”

Not so good indicators of destructive projects

Although the Summary Document of the Panel for Coastal Waters made vague references to the importance of “Linking protection of land and coastal ecosystems through adjacent terrestrial and marine protected areas,” the words “watershed” and “wetlands” do not appear in the Summary Document.  No specific suggestions were made to address the close relationship between coastal land and coastal waters.

The preservation and expansion of wetlands will reduce the flow of pollution from land to ocean by acting as a filter of runoff from the land.  Wetlands are also one of our chief defenses against rising sea levels if they are expanded to perform that function.  Wetlands are the nurseries of our fisheries and they provide essential habitat for wildlife.  Wetlands are also significant carbon sinks.  Yet the Summary Document makes no mention of these essential functions that contribute to healthy oceans.

Cleaning up the watersheds that are now draining toxic pollutants into the ocean is a more worthwhile endeavor than anything suggested by the Coastal Waters Summary Document. Most rivers in California are ultimately watersheds into the ocean, therefore cleaning up these “impaired waters” will also improve ocean health.  Many important fish species that migrate from ocean to rivers are killed or harmed by these hazardous contaminants.  The ocean is only as healthy as its watersheds.

Instead of addressing the opportunities to expand wetlands and cleaning up watersheds, the Coastal Waters Panel is proposing an outdated “restoration” approach that begins with killing plants and animals. The attempt to “restore” kelp forests is one of the few specific examples of possible projects that is mentioned in the Panel’s Summary Document.  Like most of these futile projects, that project begins by killing thousands (millions?) of the chosen scapegoat, purple urchins, predators of kelp.  Where urchins are killed kelp is being replanted.  Like most of these projects, the chosen method does not address the underlying causes for declining kelp forests that were killed by ocean heat waves.  Ocean heat waves are a consequence of inexorable climate change.  It is delusional to assume that the heat waves that killed the kelp will not occur again.  Furthermore, the massive die-off of sea stars from a mysterious “wasting syndrome” is an important factor in the explosion of urchin populations that are prey of sea stars.  As you might know, sea stars are making a comeback.  Sea Otters are also predators of urchins.  If their populations weren’t repeatedly suppressed by commercial fishing interests, urchins would have more predators.  In other words, present methods of “restoring” kelp forests are based on inadequate understanding of the food web and the underlying causes of the loss of kelp forests.  Is anyone trying to breed a more heat-tolerant variety of kelp?  Is anyone looking for a functional equivalent in warmer waters?  In other words, the loss of kelp forests is a serious problem, but the methods being used to address it are amateurish and futile.

The Ugly:  Composition of 30X30 panels is deeply flawed

There are representatives of organizations on two 30X30 panels that promote and participate in island eradication projects such as the Farallon Islands project that proposes to kill mice by aerial bombing 1.5 tons of rodenticide on the islands.  One representative on the Biodiversity Panel identifies himself as a “conservation entrepreneur” and the founder of Island Conservation, the organization that has conducted more than 350 island eradications in 65 countries around the world and is participating in the Farallons project.  One member of the Coastal Waters Panel represents Point Blue, an organization that has participated in many deadly projects.  Point Blue actively promotes the Farallons project and has participated in its development. 

The Farallon Islands project is another example of a project that has selected an animal scapegoat for eradication without addressing the underlying cause of the perceived problem, which is a dwindling population of ashy storm petrels.  Mice are the chosen scapegoat despite the fact that they do not harm any birds or their chicks.  The mice are blamed because they are the preferred prey of a small number (8-10) of burrowing owls that prey on the petrel chicks when mice are not available.  The burrowing owls could easily be non-lethally removed from the island (Try walking up to a burrowing owl.  Chances are it won’t flinch.)  The National Park Service removed 44 Golden Eagles from the Channel Islands because they were preying on Channel Island Foxes (after NPS eradicated sheep and goats from the islands that were the Eagles’ preferred prey).  USFWS proposes to kill the mice by aerial bombing 1.5 tons of rodenticides on the Farallons and they acknowledge that hundreds (thousands?) of non-target birds are likely to be collateral damage, as they have been in hundreds of similar projects all over the world.  USFWS claims that the burrowing owls will “go away” if their preferred prey is eliminated.  It seems more likely that the burrowing owls will either be killed by the rodenticide or will eat more birds if that’s all there is to eat.  Second-generation rodenticides were recently banned in California because they are killing non-target birds and mammals.  Unfortunately an exemption for projects considered ecological “restorations” was carved out of that ban. Why the proposed Farallons project is considered a “restoration” is a mystery to me. 

We saw burrowing owls in Argentina in 2010. We walked up to them to test the claim that they are easily disturbed by people. We got even closer than this before the owl reacted.

Similar island eradications have been completed all over the world.  Rats are the usual target of those projects and unlike the mice on the Farallons, there is evidence that rats are capable of harming birds.  However, a significant portion of those projects were unsuccessful because rats are resourceful creatures capable of reproducing quickly after their population is reduced.  More importantly, those projects have killed thousands of non-target birds who ate the poison (or poisoned rats) and contaminated the water around the islands, harming fish and marine mammals that live around the islands.

Island eradications done by Island Conservation

As I told California Natural Resources Agency in my written public comments, Point Blue and Island Conservation should not be represented on 30X30 panels because they are likely applicants for projects that will be funded by the state.  This is a serious conflict of interest.  Point Blue is involved in hundreds of destructive projects all over California, including surveying barred owls in preparation for shooting them. Island Conservation has published a study that identified other islands off the coast of California for potential island eradications.  If these organizations are in a position to influence the types of projects that are funded by the 30X30 initiative, they will be in a position to profit from creating projects they can perform. 

Several of the public commenters at the Coastal Waters workshop on August 17th mentioned that there is no representation on the Coastal Waters Panel of recreational and commercial fishermen.  Other panels include representation of recreational interests because increasing recreational opportunities is one of the primary goals of the 30X30 initiative.  Point Blue should be replaced on the Coastal Waters Panel by representation of recreational and commercial fishermen. 

Where do we go from here?

You can view the 30X30 workshops on CNRA’s You Tube Channel. You can read the recommendations of the 30X30 panels on CNRA’s website.  And you can respond to CNRA’s invitation to send them pictures of successful restoration projects:

“If you or your organization has images of before and after climate smart land management projects, successful nature-based solutions; or iconic California landscapes we would love to feature them!…If your organization is interested in sharing pictures, please email them to Heather Williams at the California Natural Resources Agency (CNRA) by September 17. Please include a description/caption of the image, the organization’s name, and the image date(s). Send only high-resolution images (1200×800 or larger). By emailing these pictures, you give CNRA the right to use these images in our nature-based solutions and climate-smart land efforts.”

Organizations that will compete for $11 billion of grant funds will undoubtedly provide many beautiful pictures of their projects.  If you have pictures of projects that were not successful, you may send them as well. 

There will be another round of workshops to review draft plans in Fall 2021.  You can ask to be notified of those workshops and register to attend them by sending an email to californianature@ca.gov.  Plans will be finalized for implementation in January 2022. 

The 30X30 initiative has the potential to be constructive by addressing important issues with viable projects.  It also has the potential to be destructive by destroying harmless plants and animals, poisoning our land, and installing replacement landscapes that are not adapted to current and anticipated environmental conditions.  Our participation in the development of the plans is our only means of influencing the outcome.  California taxpayers will pay for these projects, whether we like them or not.  It is in our hands.