SAN GORGONIO CHAPTER

4079 Mission Inn Avenue, Riverside, CA 92501 (951) 684-6203 Regional Groups Serving Riverside and San Bernardino Counties: Big Bear, Los Serranos, Mojave, Moreno Valley, Mountains, Tahquitz, Santa Margarita

P. O. Box 106 Barstow, CA 92312 March 14, 2014 Randy Moore, Regional Forester USDA Forest Service Attn: SoCal LMP 1323 Club Drive Vallejo, CA 94592

Dear Mr. Moore, The San Gorgonio Chapter of the Sierra Club is hereby appealing the San Bernardino National Forest LMP Plan Amendment lack of recommended wilderness for the Cucamonga C IRA. The responsible official for this document is: Forest Supervisor Jody Noiron. We do applaud the wilderness recommendations that the Forest made in the original Land Management Plan adopted in 2006: Cactus Springs A (21 acres), Cucamonga B (6,516 acres), Heartbreak Ridge (5,142 acres), Pyramid Peak B (9,004 acres), Raywood Flat B/Mill Creek Sub- unit (1,901 acres), Raywood Flat B/Yucaipa Ridge Sub-unit (1,939 acres) and Sheep Mountain Wilderness Addition (1,823 acres). These are well deserving of their “recommended wilderness” status. We would like to hereby explain why it is a grave error on the Forest Service’s part not to recommend any wilderness for the Cucamonga C IRA. The statement is made in page 13 of the Record of Decision that “Another 9,755 acres of the Cucamonga B and Cucamonga C IRAS offer limited opportunities for solitude and challenge, have low wilderness values and characteristics, has uses that cannot be effectively managed as wilderness, and are not needed a part of the wilderness preservation system. It is my decision that this additional BCNM zoning here will provide the best mix of suitable uses for this portion of the IRAs.” On page 1 of our comment letter on the DSEIS, we stated: “The LMP did not recommend any portion of Cucamonga C as wilderness leaving 4,102 acres as non-wilderness even though the adjacent Angeles National Forest recommended adjacent IRA lands to the west as recommended wilderness. Cucamonga C’s southern boundary is San Sevaine Road 1N34. The southwest boundary to Cucamonga C begins at the boundary between the Angeles and San Bernardino NFs in Sections 6 and 7, T 1N R 8W. The boundary for our recommended Addition follows the border from its contact point with the southern boundary of the Cucamonga Wilderness to Forest Service System Road 1N35. Then, the boundary follows both 1N35 and 1N34 eastward at a distance of 300 feet from the centerline. The boundary continues east like this until 7W04 and the Joe Elliot Tree Memorial cherry-stemmed road is met. This is where the proposed wilderness addition meets the Forest Service recommended wilderness boundary for Cucamonga B IRA.”

1 In Appendix 4, page 15 of the FSEIS, the Forest Service gave their response to this statement. They said: “The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned.” This does not answer our statement that the adjacent Angeles National Forest deems their Cucamonga A IRA has recommended wilderness and just across the border the San Bernardino National Forest staff deems Cucamonga C as only warranting BCNM protection. We stated in page 5 of our San Gorgonio Chapter, Sierra Club letter the following: Here's how and why it meets the definition of wilderness: The Cucamonga Wilderness was created by the 1964 Wilderness Act. Its boundaries are section lines which exclude many lovely bordering canyons. It makes sense to round off the old boundaries to include the lovely surrounding canyons including Cucamonga, Day, and Deer Canyon headwaters. Vegetation on Sevaine Ridge consists of mature stands of mixed conifer with some black oak, scattered areas of scrub oak and chaparral, and some isolated pockets of Bigcone Douglas-fir. Some of the largest sugar pine in Southern are found on San Sevaine Ridge. The south facing slopes through the area are primarily chaparral. The area contains significant deer habitat and a large portion of the San Gabriel bighorn sheep (Ovis Canadensis nelsoni) population. Cucamonga, Deer, and Day Canyons are the primary wintering ranges for bighorn sheep. Most of the perennial streams support trout. California spotted owls dwell in the steep wooded canyons. San Sevaine has been identified as a culturally sensitive area with many archaeological sites.

It has the following outstanding social and ecological values: Cucamonga B and C are prime winter habitat for San Gabriel Bighorn Sheep (Ovis Canadensis nelsoni) herds. There is a wilderness trailhead located at the Joe Elliot Tree Memorial. This is a very challenging trail to Cucamonga Peak at 8859’, one of the highest peaks in the region. The Joe Elliott Tree, a mammoth sugar pine 7 feet 6 inches in diameter, is believed to be the largest conifer in . Sadly, it has fallen down in the primitive campground located here. The tree is named in honor of the supervisor of the San Bernardino NF from 1929 to 1935. Outstanding views of all the are found here. Middle and South Fork Lytle Creek watershed as well as Cucamonga, Day, and Deer Canyon headwaters are located here.

Here's why your arguments against the area in the forest plan were wrong: The narrative for these two IRAs fails to explain how plants and wildlife, including the southwestern willow flycatcher, arroyo toad, California red-legged frog, Nevin’s barberry, Nelson’s bighorn sheep and mountain yellow-legged frog will be affected by the fact that 2,966 acres of this area is in BC and DAI zones (where communication site construction, public woodcutting, commercial logging, “temporary” road construction, energy development, permanent road construction, new utility corridor construction, construction of buildings and mechanized vehicle use are allowed) and that 4077 acres are in the BCNM zone (where communication site construction, commercial logging, “temporary” road construction, energy development and mechanized vehicle use are allowed.) The assessment also states that the SBNF has a low ability to preserve the areas’ landform types and ecosystems, but fails to explain why. Is this confirmation that the SBNF plans to excessively alter the areas’ ecosystems? The use of short, generic, and utterly unsupported reassurances about the future wellbeing of plants and animals in the acres of the severe development threat posed by the zoning schemes described above does not under any circumstances constitute a complete and fair analysis. The need rating for these areas would have been higher had it been given a fair and appropriate

2 evaluation. Neither the public, nor the Regional Forester can make informed decisions regarding roadless areas when the FEIS and ROD fail to meet the standards set forth in NEPA. On page 303 of Appendix 2, the false statement is made: “Some mountain biking opportunities would also be foregone with wilderness recommendation.” Certainly, the now washed out Cucamonga Truck Trail 1N34 is still open to mountain bikes and the Sierra Club knows of any Forest Service system roads or trails that would be closed by recommended this IRA as wilderness.

Here's how it can be managed as a viable recommended wilderness: All 4,102 acres of Cucamonga C IRA should be added to the 6,260 acres recommended in Cucamonga B. There is no reason why Cucamonga Canyon wash should not receive wilderness protection. This would do much to protect the south side of the Cucamonga Wilderness. There is no reason why the Wilderness boundaries should be section lines here. This will also do much to protect sensitive Nelson Bighorn Sheep habitat. As stated on page 304 of Appendix 2, “San Gabriel bighorn sheep are affected by development. There is a need to provide a sanctuary for certain biotic species, including the San Gabriel bighorn sheep.”

In reading Appendix 4 of the FSEIS on its final two pages, we found a very supportive letter from the Fire Protection District Prevention Bureau. It states on page 1 and 2 of the letter: The Cucamonga Canyon watershed and Cucamonga Creek are important and valuable water resources for the City of Rancho Cucamonga and nearby communities. The canyon in recent years has seen increased use as a recreational area due, in large part, to social media making wider percentage of the southern California population aware of an area in the canyon that has come to be known as Sapphire Falls. This recreational use is noted in Appendix 2 of the SEIS. In the past 12 months, the Fire District has responded 22 times to Cucamonga Canyon to rescue people who have become trapped in the canyon. In the recent past, two visitors to the canyon have fallen to their deaths. The rescues and the deaths resulted from unrestricted and ill- advised access to dangerous areas of the canyon. In addition to the health and life safety concerns that exist in Cucamonga Canyon, the environmental damage being done to the canyon and the adverse impact to the water resources are a concern to the Fire District. The canyon walls are a favorite target of spray paint graffiti. Trash and other debris regularly find their way into Cucamonga Creek. The Fire District has a vested interest in protecting the canyon’s vital water supply to the community and is a supporter of a healthy community and environment. As mentioned in the Wilderness Section on page 228 of the SEIS, a Wilderness designation for Cucamonga C will “generally allow natural processes to occur with few restrictions or restraints. When management actions are taken, the most common type of wilderness management is the control of visitation and recreation.” Such management would greatly benefit Cucamonga Canyon, its environment, and the watershed and would provide a higher level of public safety for an area with a history of injury and death to those who are unfamiliar with the area and its terrain. For these reasons, the Rancho Cucamonga Fire District supports Alternative 3 of the SEIS for areas Cucamonga B and Cucamonga C.

We agree wholeheartedly with every word of this comment letter. One only has to look a few miles west to Ice House Canyon entry trails to the Cucamonga Wilderness in the Angeles National Forest to see how a watershed area can be better managed as wilderness. We do agree with the Forest Service’s recent action to close the Sapphire Falls Trail due to the high fire

3 danger, but a second step of recommending Cucamonga C IRA as wilderness should also be taken to better protect the upper reaches of Cucamonga Canyon.

We request a resolution meeting with the Forest Service. We would like to have the Rancho Cucamonga Fire District representatives invited to join us.

Sincerely,

______Joyce Burk SoCal Forests Committee Chair (760)220-0204

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