South Skyline Association

March 19, 1999

Northern Service Center
Department of Parks and Recreation
1725 23rd Street, Suite 200
Sacramento, CA 95816

The South Skyline Association represents more than 200 residents and owners in the Skyline area surrounding much of Castle Rock State Park. As neighbors, we have an intimate knowledge of the natural resources and usage patterns in the Park. Many of us are users of the Park ourselves. Some of us donate hours of volunteer labor to maintain and protect Park resources. Our two volunteer fire departments are frequently first at the scene of emergencies in the Park. All of us are impacted by the presence of large numbers of Park visitors. We are therefore submitting several questions as part of the CEQA review of the Draft General Plan.

Castle Rock State Park is greatly in need of planning; both the general planning currently underway and the more detailed management and protection plans that we anticipate will follow in short order. We are therefore gratified that the State Department of Parks and Recreation is taking this first step.

There are many aspects of the Draft Plan that we find encouraging and urge the Department to retain, specifically the following:

	The practice of acquiring additional land only from willing sellers.
	The creation of the large natural preserve within the Park, including the Lion Caves area and Kings Creek drainage.
	The elimination of rock climbing from the natural preserve.
	The importance of identifying, evaluating, and protecting resources and of educating the public about their fragile nature.
	The outreach to more moderate members of the climbing community to develop guidelines for climbing which protect the rocks and the resources associated with them.
	The maintenance of current policies restricting mountain bikes.
	The identification of access and parking problems, especially the review of roadside parking sites along Highways 9 and 35 for possible closure or enhancement.
	The coordination with adjacent private landowners and public agencies such as the San Lorenzo Valley Water District, Santa Clara County Parks, and the Midpeninsula Regional Open Space District. All these own vast acreage that is part of the same ecosystem and recreational area.
	The identification and proposed preservation of historical features.
	The attention to the layout and use of trails.

There are, however, some issues of great concern to us on which we request clarification of the Department's intentions.

1. Staffing. The general Plan, as a management document, makes many recommendations regarding management of natural preserves, visitor contact and education, enforcement of climbing guidelines, supervision of parking and camping areas, etc. Implementation will clearly require substantial expansion of current staffing. For example, during Phase I of the parking proposal there will be two "main" entrances. Today, with only one ranger, the Park is understaffed and its resources are widely acknowledged to be in a state of decline. If this situation continues, no plan will be able to reverse this degradation and stop the "rogue user" activity that is already taking place.

   Questions regarding Staffing:

   	How will the Department ensure that adequate funding will be available to provide sufficient numbers of rangers and other staff as the various recommendations in the Plan are implemented?
   	How will Park resources be protected if funding is not available for adequate staffing?
   	How will volunteers be utilized to supplement the staff?

   
   

2. Impact on Neighbors. The Park has a history of increasing impacts on its neighbors. Neighbors' homes have been broken into, water tanks drained, and residents harassed and occasionally threatened by Park visitors. These incidents are too frequently the result of people being excluded from the Park because of its restrictions on use of mountain bikes or on alcohol consumption.

   The easement through Indian Rock Ranch was especially troublesome until its use was reduced. The Plan document notes, however, that this "route is authorized for hikers and equestrians." Moreover, the Plan recommends several projects in close proximity to private residences such as a trail on future easements along the Kings Creek Truck Trail, the Partridge proposals, and the Environmental Living Program at Tin Can Ranch.

   Questions regarding Impact on Neighbors:

   	What measures will be taken to mitigate the impact of Park visitors on neighboring residents?
   	How will locations for trails, parking, access points and other visitor amenities be chosen to minimize trespass and vandalism on neighboring properties?
   	What management measures will be taken to minimize trespass and vandalism on neighboring properties?
   	What use is intended for the easement through Indian Rock Ranch?
   	What measures will be taken to ensure that developments and activities within the Park do not degrade neighboring residents' water supplies?

   
   

3. Baseline Resource Inventory and Carrying Capacity. In its discussion of carrying capacity, the Plan suggests the collection of "baseline resource information," the "setting of standards," and the "establishment of resource monitoring" to determine carrying capacity and to prevent resource degradation from too much public use. We strongly support this recommendation and want to ensure that it is implemented in an effective and timely manner. Many feel strongly that serious resource degradation is already taking place. We could give many examples. One is that Tafoni fretwork has been irreparably destroyed in areas currently accessible to visitors. Moreover, it is seriously threatened in areas where rogue rock climbers are currently opening new access.

   An inventory of all Tafoni in the Park is urgently needed. Further, many of the rocks unique to the Castle Rock area have been denuded of lichen and moss through overuse by climbers.

   Questions regarding Baseline Resource Inventory and Carrying Capacity:

   	How will the Department ensure that a baseline resource information collection program is given high priority and is adequately funded?
   	How will the data collection program work?
   	How will limits of acceptable change be established?
   	How will citizens participate in establishing the limits of acceptable change?
   	How will ongoing monitoring programs work?
   	How often will data be collected to determine if degradation has occurred?
   	How will the results of the resource monitoring be used in the management of the Park?

   
   

4. Walk-in Camping. The Plan appropriately identifies a number of constraints on public access in the Partridge Farm area, including prehistoric sites, a unique black oak forest and the Lion Caves. Yet, walk-in camping, a new user activity, is proposed for this area. This camping would put the sensitive resources within a few minutes walk a full 24 hours every day. We are further concerned that the availability of overnight parking will make it even easier for illegal camping to occur outside the campground. Park neighbors among our members have had to deal with a number of illegal campfires over the years from such camping. We are opposed to the establishment of new walk-in camping.

   Questions regarding Walk-in Camping:

   	What data supports the need stated in the Plan for walk-in camping?
   	How will the Department limit access by overnight campers to prehistoric sites, Lion Caves and other sensitive resources?
   	Does the high cost of meeting the quality standards required for drinking water justify the benefit provided by the campsites?
   	How will the department prevent use of the overnight parking areas for camping outside of designated areas?
   	How will illegal campfires outside the campground be prevented?
   	How will decisions be made about closing the walk-in camping during periods of high fire danger?
   	How will sewage from the campground be disposed of?

   
   

5. Citizens Advisory Councils. We found the General Plan Citizens Advisory Committee to be extremely valuable and useful in our understanding the Department's needs and issues -- and as a vehicle for us to communicate our knowledge of Park resources and usage patterns. We are very disappointed about its discontinuance. We believe that input from people such as ourselves would be very helpful to the Department in preparing the best possible plans and in gaining public support for them.

   Questions regarding Citizens Advisory Councils:

   	How will the Department obtain public input from people like us as it proceeds with preparation of the numerous subsidiary plans mentioned in the General Plan?
   	Will citizens' advisory councils be established?
   	How will we be able to influence the preparation and implementation of the use, development, and management plans?

Thank you for the opportunity to comment on the Plan. We look forward to your responses to our questions and to working with you in the future to refine the Plan.

Sincerely,	Judith H. Lovell,
	President, South Skyline Association