American River Community Coalition’s comments on the Auburn State Recreation Area’s Preliminary General Plan (July 9, 2020)
On behalf of residents and visitors to the communities of the Georgetown Divide in El Dorado County, California, the American River Community Coalition (ARCC, formerly the Divide Action Coalition) is reviewing the 717-page California State Parks (CSP) Auburn State Recreation Area’s (ASRA) Preliminary General Plan and is greatly disappointed with the document. While all comments were recorded and acknowledged, very few of the extensive concerns for public safety voiced by the public and emergency response agencies submitted to the CSP were incorporated with any meaningful, measurable, management specifics to mitigate those valid concerns into the revised final plan.
Even more disturbing are the dismissive responses to serious concerns outlined by overtaxed emergency response managers about lack of staff, equipment, and funding.
The ASRA Preliminary General Plan as proposed uses a flawed, pre-determined formula of expansion with ambiguous mitigation measures that do little to engage the surrounding communities to participate in significant improvements to ASRA.
For example, the plan preparers continue to state that a 30% increase in visitation by 2040 is inevitable. Visitation can be controlled by putting in place systems other parks within the State Parks system use to control crowding, such as instituting reservation systems and/or limiting parking opportunities. No visitor capacity controls are suggested in this plan.
FIRE
According to the ASRA Plan revisions, an Auburn Fire Management Plan was recently developed by the Bureau of Reclamation. It was not included as an attachment to the Plan. Thus, the public and perhaps affected agencies have little knowledge of its content. ARCC has requested a copy of this plan.
The agencies’ answer to fire mitigation is to direct visitors to developed facilities (see below).
“The majority of wildfires within ASRA/APL were caused by negligent or illegal activities including fireworks, arson, shooting, smoking, and illegal campfires–the exact types of activities that are more likely to occur when visitation is not managed and directed to appropriately designed and staffed facilities like those proposed in the Preliminary GP/Draft RMP.”
The majority of the people who use ASRA do not stay in existing developed facilities. Nor are they likely to do so when facilities are built. People visit ASRA to hike, run, ride horses or bikes, cool off at the river or seek the solitude that a 30,000-acre recreation area provides. They do not stay at “facilities”. They park their cars and go elsewhere. Negligent or illegal activities will continue or increase with increased visitation. This “mitigation measure” just won’t work.
The plan states that the agencies will complete an extensive amount of vegetation management, roadway improvements for emergency access and coordination/compliance with fire agencies. There is nothing in the document that addresses on-going funding needs to maintain this level of management and coordination. They say that 68% of all visitors are local and regional and it is the local governments’ job to provide and pay for increased emergency response on ASRA (Response to comment from Placer County Fire Chief, Brian Estes).
In addressing the comments from most of the fire agencies responsible for emergency response and/or mutual aid fire response, the response to concerns were dismissive and defensive. This is unacceptable.
Examples:
“The actions of CSP and Reclamation did not create a wildfire risk near developed communities. Rather, urban development has encroached into the naturally fire prone area surrounding ASRA/APL.
…the Draft EIR/EIS determined that the GP/RMP provided sufficiently protective wildfire risk-reduction measures to address the existing wildfire risk and offset the incremental increased risks from visitation that could occur under the GP/RMP.”
TRAFFIC
State law says ASRA cannot expand if existing traffic at the Confluence is heavily congested. To get around that requirement, State Parks’ paid for a study that gave them the result they needed. How is that possible? The study is fatally flawed and anyone who frequently travels through ASRA lands on Highway 49 knows how congested it is, particularly through the summer season due to increased visitation.
Examples: The study claims the busiest time at the Confluence is the weekday morning commute, not the weekend. The downhill section from the Quarry to the river is shown as having no slope (0% grade). The roadway lanes are listed as 12 feet wide when it is actually 10 feet in many places. Nowhere in the study are the hairpin turns and blind corners accounted for. Weekend traffic is described as cars only; no trucks, campers, or horse trailers. The average speed from the bridge to the quarry with light traffic is assumed to be over 40 mph. Residents would like to know who is able to travel through this canyon traveling continuously at that speed.
Over half of the public comments express concerns about traffic and fire evacuation routes. The “master response” to these concerns focuses almost entirely on new parking spaces, not congestion. It concludes by claiming that adding capacity for 400,000 additional visitors will reduce traffic. A park-wide emergency evacuation plan has yet to be drafted.
Per the Plan:
“In summary, the Preliminary GP/Draft RMP would not substantially contribute to additional visitation near the Confluence that could exacerbate the existing parking, roadway congestion and pedestrian crossing issues. Instead, it includes numerous measures to reduce congestion at the Confluence and increase safety.”
RIVER RESCUES
State Parks claims they have staff to handle river rescues. Current status: In the seven days between June 18 through June 24, there were 6 river rescues involving 12 victims where two forks of the American River meet in Auburn State Recreation Area (also known as the Confluence). In each rescue, park rangers required EXTENSIVE and EXPENSIVE back up from state and county agencies. Agencies that responded to assist with these State Park river rescues (6-8 agencies per rescue) included Cal Fire, Placer County Firefighters, Placer County Technical Rescue Team, Auburn City Fire Department, El Dorado County Fire Protection District, American Medical Response, Placer County Sheriff’s Dive Team and California Highway Patrol Valley Division Air Operations.
Who pays for these State Park “back up services”? We do, through our state and local taxes. Between 36 to 48 emergency visits by first responder agencies called to the Confluence in seven days. How much did that cost? And what could those agencies have been doing instead? Perhaps responding to a fire a mile from their station, near the Northside School, had they not been at the river rescue?
State Parks should be responsible for paying for emergency services that follow from their decisions on park operations. For now, they keep making plans that ignore these hazards and their associated expenses in money and in lives.
Even State Parks’ staff admit new visitors are unaware of river hazards. Yet the ASRA Preliminary Management Plan’s proposals will exacerbate risks by establishing new campgrounds at the river’s edge.
Per the Auburn Journal, 6/22/20: “The rate of rescues this last weekend is something we haven’t seen for a very long time; it’s abnormally high,” said Mike Howard, superintendent of Auburn State Recreation Area.
Per the Auburn Journal, 6/22/20:
“The rate of rescues this last weekend is something we haven’t seen for a very long time; it’s abnormally high,” said Mike Howard, superintendent of Auburn State Recreation Area.
Howard said the increase in visitors may be because the weather is warmer, and it doesn’t look like it’s going to let up anytime soon.
“A lot of it has to do with a tremendous amount of new visitors to the area,” Howard said. “They aren’t accustomed to river swimming and don’t understand how strong a river can be.”
What new swimmers also might not realize is the river level triples in the afternoon because each day water is released upstream from Oxbow Reservoir, which takes seven hours to reach the Confluence area, Howard said.
The Divide community sees few actual improvements in vegetation management, traffic control, evacuation planning, trail safety or emergency response in ASRA. Past practices inform future expectations. The agencies have failed to continuously fund effective operation and maintenance of ASRA. Therefore, without assured funding, the Divide community is extremely concerned that even a minimum amount of vegetation management will be completed to protect our communities from catastrophic fire. Communities that have existed for generations, not just in the last few years.
The comment and response process that is part of CEQA/NEPA requirements is intended to encourage public involvement to partner with government planners and result in a better, safer project. It is a travesty that State Parks’ has chosen to ignore input, issue nonsensical responses, and proceed with their pre-determined plans that ignored serious public concerns. But what is most distressing of all is the missed opportunity for the community to partner with the land management agencies now and into the future. We offered our assistance to make ASRA a better place and they chose to ignore us. We will not go away quietly.