Someone new on the scene recently asked me to explain the history of what went wrong at Cotoni Coast Dairies. After many, many years, the property still isn’t being managed for wildlife or public safety, and it still isn’t open to the public. As a prelude to this, I urge readers to read my essay on how the Bureau of Land Management (BLM) came to manage the property in the first place…a curious story, indeed. This essay compliments that prior essay with more details, especially since BLM took over managing the property. Soon, I’ll be writing the third in this series with suggestions about what is needed to improve this unfortunate situation.
Years of On the Ground Nothing, or Worse
Since its purchase for conservation, Cotoni Coast Dairies has a history of very little stewardship and management. Trust for Public Land purchased the property in 1998 and held it until 2014. During that time, managers working for the Trust for Public Land did almost nothing to maintain the property. Occasionally, someone would show up to clear some anticipated future trail. For instance, TPL contractors extensively cleared riparian vegetation along Liddell Creek, chainsawing decades-old willow trees that shaded endangered fish habitat and provided cover for the endangered California red-legged frog. They argued that the clearance was along an ‘existing road,’ and they started putting this trail on early maps as a favored future public access point. (The trail later appeared on BLM’s maps, but federal wildlife protection agency personnel demanded otherwise, so the trail disappeared from plans.) Otherwise, TPL let fences, gates, and culverts rust away, roads and trails erode, weeds spread, and fuels build up creating hazardous conditions for future wildfires.
Eight years ago, BLM took over management of Cotoni Coast Dairies, and those same patterns largely continued. Early on, BLM staff constructed a new trail, carving through nests of state-listed sensitive wildlife without required State consultation. Like TPL, BLM staff have either overlooked erosion issues along roads or graded long abandoned ‘existing roads’ (aka ‘future trails’) with uncannily similar detrimental impacts to rare fish and amphibians. Meanwhile, terrible weeds and immense wildfire risks continued to spread across the property. The reason BLM staff have given for such poor stewardship: ‘we don’t have an approved plan.’ That changed, but management hasn’t…except for one new stretch of cattle fence and subset of future trails being created mainly by volunteers. The trails and fence came before any work on invasive species or wildfire mitigation, so we sadly sense BLM staff priorities have been directed away from conservation towards recreational access.
Decades of Funky Planning and Community Engagement
Staff from both TPL and BLM have sporadically spent a bit of time working on poor planning processes or participating in largely perfunctory public meetings about property management at Cotoni Coast Dairies. In the year 2000, TPL convened and facilitated a Community Advisory Group (CAG) to advise on guidelines meant to be used by future managers. A few of us on the CAG were asked to provide feedback about the biological portion of those guidelines, but we were unable to improve the largely cursory and incomplete biological assessments used to guide future property management. It is unclear if those guidelines have ever been used by BLM, or if TPL even cares.
BLM has done little to inventory the property, so it has very poor information with which to plan its management. Like TPL, BLM staff have shunned offers to improve biological survey data and so, as with the TPL plans, BLM’s plans have overlooked species and ecosystems that are easily identified and/or previously catalogued by reputable sources. This alienates the conservation community including the wealth of well-trained scientists that this region enjoys.
Instead of the long series of TPL’s CAG meetings, BLM staff showed up for a single community-engagement-style meeting convened and facilitated by the Land Trust of Santa Cruz County. That meeting surprisingly and very oddly focused on weighing pros and cons of parking lot locations, but it was never clear why public input was sought or what became of it afterwards. In the midst of this, an outside funder parachuted in hundreds of thousands of dollars so that several local organizations could mount a seemingly ‘grassroots’ Monument Campaign.
In 2015, The Sempervirens Fund led the “Monument Campaign,” a fast-paced, highly scripted, well-funded effort to organize rallies and letter writing to show public support for National Monument designation of Cotoni Coast Dairies. In what is increasingly common “fake news,” the bulk of the Monument Campaign messaging was about opening the property for public use, while in fact Monument designation is more about improving conservation of the property…which would typically increase limitations on public access. This nonsense was compounded by campaign organizers’ refusal to address how designation would increase deed restriction protections already in place from TPL. Furthermore, organizers dismissed concerns about managing the anticipated influx of visitors drawn to something called a National Monument. How important the Monument Campaign was in Obama’s designation is unclear, but the divisions in the community were deep and lasting. Organizers were successful in coalescing well-meaning but very poorly informed people whose nonsensical byline was “Monument designation means my family will be able to visit!” On the other hand, there was a surprisingly politically diverse coalition equipped with well-informed questions and concerns that were never addressed. After that local experience, it is difficult for me to believe that any political faction is immune from using scripted ‘truthiness,’ hype, or even lies when they feel those tools necessary in attracting popular support for secret agendas. Unsurprisingly, leaders of the ephemeral Monument Campaign movement have since disappeared from involvement, leaving the aftermath for the real, long-term grassroots organizations to deal with, and we have yet to experience any conservation benefit of Monument designation.
Pop Up Trail Plans, Abandoned
As the Monument Campaign launched in 2015, BLM issued a proposal for the property’s first public access trail, aka the “Laguna Trail,” in an expedited environmental review process that showed our community how poorly equipped BLM staff were to adequately plan for the property. BLM staff relied on old, insufficient biological inventories for their analysis, failed to survey for endangered species, and did not include any analysis of how the trail would address social equity concerns in providing for visitor use. BLM staff did not respond to the many concerns raised by the public but instead completed their pro-forma circulation and approval of planning documents and rapidly deployed machinery and workers to clear the trail. Trail construction proceeded without conforming to even the nominal environmental guidelines outlined in BLM’s planning documents. The hastily constructed trail cut through state-protected wildlife habitat, degraded historical artifacts, and came very close to a native village site which BLM failed to plan for protecting. In addition, if the project had proceeded, BLM would have opened a trail beginning at Laguna Creek Road and Highway 1 without any new parking, litter, or bathroom facilities, without sufficient staffing for enforcement or interpretation, and without a recreational plan for the property as a whole to analyze how to best protect wildlife while providing public access. This pop up trail was BLM’s way of introducing themselves to the land and to our community.
Introductions to BLM Planning Procedures
As the first federal land manager in the County, it was BLM staff who introduced our community to the federal government’s environmental planning process. This introduction was surprising in many ways. We had been accustomed to public lands managers paying careful attention to protecting “environmentally sensitive habitat areas” (ESHA) according to Coastal Commission rules. Not so with this property – BLM staff didn’t even provide the public maps of those regulated habitat areas in any of their planning documents! With the promise of National Monument protections, we were hopeful that BLM staff would follow the required and highly regimented process outlined in BLM’s policy “Manual 6220,” which provides staff with guidelines on how to manage national monuments. Again, not so! In fact, BLM staff have not used the 6220 manual and have neglected any public acknowledgement of the manual, as if they do not intend to use it, at all. Moreover, BLM staff have never specifically acknowledged the many species and ecosystems protected through the monument designation process. Monument management protocol seems irrelevant to BLM staff, who are apparently bent on expediting the public access so vocally anticipated by the Monument Campaign (coincidence?).
Expediting Public Access
BLM staff have chosen expediency over thoroughness in each of their property planning exercises. For their most recent property-wide plan, instead of data-based predictions of visitor use, BLM staff chose a largely arbitrary low-ball figure of 250,000 anticipated visitors/year for the property. Instead of the logical in-depth alternatives analysis of a full Environmental Impact Statement (EIS), BLM staff have chosen expedited Environmental Analysis (EA) processes, complete with incredible conclusions of ‘Finding of No Significant Impact (FONSI),’ despite significant contrary expert testimony that has gone unaddressed and unacknowledged. As we learned for the first time about its ‘federal consistency process,’ the Coastal Commission recently mandated that BLM use a phased approach to opening the property to public use. The Coastal Commission required that only if/when the BLM proved it could adequately manage public use could it open the full range of parking lots and trails; that proof requires monitoring and such monitoring would normally require a baseline inventory of sensitive natural resources, but we have yet to see that happen…we don’t even know the language to which the BLM and the Coastal Commission have agreed.
Nipping at the Community
My personal interactions with BLM staff have historically been less than pleasant, perhaps because those staff members are unused to much public engagement. My experience of poor interactions with BLM staff isn’t isolated. Someone suggested that this might be partly because those staff feel ‘rocked back on their heels’ because of criticism of their work, which is odd because our comments have been professional, polite, and part of what BLM should expect as public lands planning processes. A BLM staffer told me long ago that their colleagues were in for a surprise as they encountered the very actively involved communities of Santa Cruz County’s North Coast. Previously, most BLM staff working at Cotoni Coast Dairies had worked very much out of the public eye, in remote parts of California with little/no public oversight.
While we can’t ascertain why BLM staff have avoided offers for assistance, their subterfuge is as enlightening as it has been damaging. My compassion about staff feeling rocked back on their heels is limited because BLM staff have sought to discredit my work and harm my reputation, even approaching employers with false information to negatively affect my job while also giving ultimatums to conservation networks to preclude my participation. During one encounter at a public meeting, a BLM staff person told me that they would never collaborate with me or the groups with whom I worked because I was “against any public access at Cotoni Coast Dairies.” That was an incorrect statement about my position that I had likewise been hearing from a particularly activist, radical group of mountain bikers. As this BLM staff person echoed that quote, it was possible to better understand communication channels and allegiances.
My earliest interactions with BLM staff at Cotoni Coast Dairies were when I proposed assistance for biological monitoring. I and a few other biologists offered BLM free assistance with biological surveys to improve their understanding of the property. After that proposal, over a very long time, a BLM staff person strung us along through an incorrect informal process without ever encouraging us or acknowledging the potential value of such work. There was a chain of calls and emails that each ended with something like ‘well, maybe….’ By the time we subsequently discovered the correct application process and applied in that way, leadership had changed and the application was then officially refused.
Cumulative Impacts: Traffic, Trauma, Toilets and Trash (the 4 T’s)
It is important to view BLM’s problems in the context of issues related to visitor access on conservation lands throughout Santa Cruz County. As with all of the other public lands managers, BLM has been planning for visitor use and conservation in a vacuum, as if the surrounding lands don’t exist: this is a deeply flawed perspective. Much of the land from Santa Cruz City to the County line is heavily used by recreational visitors. Most weekends, parking lots overflow with cars and parked cars dangerously line the highway. There are too few trash cans and toilets to serve those visitors. Police and emergency responders are stretched to respond to the many accidents such visitation is bound to create.
County Parks, State Parks, the City of Santa Cruz, the Rail Trail, and BLM each have their own properties to manage and the same 4 T’s issues to address, but they aren’t doing it collaboratively. It is clear that none of those agencies has the resources to address those issues and so those issues are borne by our community. Visitors have come to expect trashy beaches. Emergency responders have come to expect exhaustion and insufficient support. Visitors with elderly family members or small children are avoiding parks due to dangerous or disgusting conditions. As each agency plans in isolation to provide for the maximum number of visitors, parks managers are dooming wildlife and visitor experience – the carrying capacity for the entire North Coast will be surpassed. It is no wonder that our community does not trust BLM to be able to manage their land and the visitors that they plan on attracting. BLM entered an arena of mistrust and fueled the fire with their own mistakes.
Who is Responsible?
Those of you who know me well know I don’t like the passive tense: I like clearly stating the subjects of verbs…who (specifically) is responsible for doing what (specifically). And yet, agencies like BLM are opaque…staff even refuse to specify who is specifically responsible for anything you might witness happening. But, placing the entire blame of the tragedy of Cotoni Coast Dairies on current BLM staff is unfair. Local, state and federal elected officials also bear some responsibility; good intel is that some of them have even winked behind closed doors in Washington DC, saying that local concerns needn’t be addressed. But again, placing a large amount of blame on elected officials also doesn’t seem fair: after all, they should be swayed by popular opinion (or at least election).
We saw how enough funding swayed popular opinion with the Monument Campaign, right? Apparently, no funders have been inspired to sway popular opinion in favor of wildlife protection on conservation lands in this particularly biodiverse region. Even if they did, there is a dearth of organizations who would lead that campaign. And so, in regard to the tragedies unfolding at Cotoni Coast Dairies and across Santa Cruz County’s North Coast, we must bear the brunt of blame within our community, which has long lacked leadership, energy, and focus on environmental conservation. For more on that, read my essay “Democracy and the Environment.” And, stay tuned for the third in this series of essays where I will outline steps forward out of this unfortunate predicament.
-this article adapted and updated from what appeared in late March at Bruce Bratton’s blog BrattonOnline.com