Tuesday, August 5, 2003

Letter to CDF re Lost Camp

Hi Rich, thanks for your reply, in which you wrote,

Thanks for the informative e-mail. Please follow up with a printed version sent to Mr. Bill Schultz for a formal response.

I am mailing a printed version today.

Prior to the formal response I want to say a few words about the protection of historic sites which include trails. Current rules, regulations, and laws do not provide protection for all such resources. Only "significant" historic sites, as defined by the Forest Practice Rules, require protection. Text from the 2003 is as follows:

Significant archaeological or historical site means a specific location which may contain artifacts. or objects and where evidence clearly demonstrates a high probability that the site meets one or more of the following criteria:

(a) Contains information needed to answer important scientific research questions.
(b) Has a special and particular quality such as the oldest of its type or best available example of its type.
(c) Is directly associated with a scientifically recognized important prehistoric event or person.
(d) Involves important research questions that historical research has shown can be answered only with archaeological methods (excavation).
(e) Has significant cultural or religious importance to Native Americans as defined in 14CCR895.1.

Criteria c is most frequently used when evaluating the significance of trails. The Emigrant Trails (Donner, Lassen, Nobles, etc) fit this criteria due to their importance in providing routes to the California Gold Rush and the settling of the west. Other local trails have a more difficult time qualifying under this or other criteria. If you feel that your trails qualify under one or more of these criteria by all means let us know in writing......

So, this is an excerpt from CDF's Forest Practice Rules. But, what of Federal laws, such as the National Historic Preservation Act; or CEQA? I suppose it is likely enough that the Forest Practice Rules have been carefully worded so as to comply with existing state and federal statutes.

And, in what way is the utter destruction of hiking trails consistent with CDF's avowed mission to sustain recreational resources?

Now, I call these trails "historic trails." Suppose instead we simply call them "trails," and do not appeal at all to their historic nature. Where in the Forest Practice Rules does it condone the destruction of trails?

Thank you very much for your consideration of these matters, Rich.


Russell Towle

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