Re: Proposed Determination of Critical Habitat for the Alameda
Whipsnake, RIN 1018-AF98
Dear Sir:
I would like to respond to the May 4, 2000 letter to you on
this subject from Robert E. Doyle, Assistant General Manager of
the East Bay Regional Park District. Although he talked about me
(libeled me, actually), he didn't bother to send me a copy of his
letter. That alone should arouse the suspicion that he may not be
telling the truth. Luckily, a friend discovered it and sent me a
copy.
Mr. Doyle claims that hiking, mountain biking, and horseback
riding on whipsnake habitat are harmless to the snake. He also
says "nor are we aware of any information that describes or
documents significant negative effects of non-motorized trail
uses on whipsnakes or their habitat. We are unaware of any single
incident in which whipsnake mortality has occurred on District
lands . due to any agency actions or public usage. . While one
dead whipsnake was found at Black Diamond Mines, several experts
examined the snake and could not determine a cause of death".
Actually, Professor Robert Stebbins, an expert herpetologist whom
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you undoubtedly know, said that the snake's injuries were
"consistent with being hit by a bicyclist". He told me that it
looked like its tail got caught in the spokes after it was hit.
Mr. Doyle should know this, since I wrote the East Bay Regional
Park District (EBRPD) about this on July 2, 1995 (see
http://home.pacbell.net/mjvande/aws1.htm) and July 5, 1995
(http://home.pacbell.net/mjvande/ebrpd10.htm).
Professor Stebbins also told me that a whipsnake den was
destroyed by a bulldozer (luckily, the snake wasn't home at the
time). Hiking trails are often maintained by bulldozer in EBRPD,
so it is preposterous to say that hiking, biking, and horseback
riding are harmless to the whipsnake! In Tilden Park EBRPD
designated four areas in one of their park plans as whipsnake
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habitat. But four hiking-and-mountain biking trails run through
the areas they designated! That doesn't give one the feeling that
the Park District takes the protection of listed species very
seriously!
Since I had heard a lot about the snake, but had never seen
one in the wild, I went to Tilden one day to try to find one. I
almost stepped on one! It was hidden in the grass growing in the
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trail (EBRPD calls these trails, but they are actually the width
of a road and are maintained as roads). It was a juvenile, about
18-24 inches long. If a hiker can practically step on one, then,
clearly, hiking is a threat to the snake. If I had been on a
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bike, the snake would be dead. This is to say nothing about the
presence of humans, which would tend to drive the snake away from
the resources that it needs (e.g. fence lizards). Fence lizards
(per Gary Beeman, a biologist from Lafayette) like to lay their
eggs in the soft dirt in or next to trails. Recreational use of
those trails, and bulldozing them, undoubtedly kills many of
those eggs and hence harms the whipsnake.
Mr. Doyle claims to need fire roads and need to bulldoze
them. I have heard that East Bay Municipal Utility District mows
theirs, rather than bulldozing them, preventing erosion and
minimizing harm to wildlife. Perhaps roads are needed for law
enforcement, but how many? It is unclear how many roads are
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needed in a given park, if any. Most of EBRPD's law enforcement
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problems are related to the presence of automobiles! So the
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roads, rather than being a benefit, are actually the cause of the
problems! When I asked them why they weren't patrolling mountain
biker scofflaws, they told me that they were too busy with
automobile-related crimes!
Mr. Doyle claims that roads are needed as fire breaks.
Again, how many are really needed, if any? There is really
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nothing in the parks so valuable that it is worth destroying the
park's wildlife (for whom the park exists, really) to "protect"
it from fire. The purpose of a park is to protect wildlife, not
to protect surrounding homeowners from the effects of being near
nature, to which they voluntarily subjected themselves by
choosing to live there. There is nothing in the parks so valuable
that it should take precedence over the protection of wildlife,
such as the whipsnake.
Mr. Doyle claims that EBRPD closes roads and trails to
protect wildlife, such as the California newt on South Park
Drive. I am not aware of any trails ever being closed. He also
neglected to mention that the road was closed only to cars, not
to bicycles. So much for their concern for the newt.
Mr. Doyle asks that reservoirs and parking lots be excluded
from the critical habitat. I presume that this is only so that
the park district can manage them without regard to the
whipsnake, just as they have managed the rest of their holdings,
for as long as I have watched them.
Mr. Doyle claims that "continued public support for
acquisition of regional parklands in inextricably tied to the
need for appropriate access". First of all, EBRPD has
demonstrated consistently over the many years I have watched them
that they have no idea what is "appropriate access", consistent
with the protection of wildlife. Second, I am not convinced that
acquisition by EBRPD is the best way to protect wildlife, and
therefore something that we should be overly concerned about.
EBRPD seems most concerned about getting the maximum number of
people into the parks, and making their access as easy as
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possible, even by motor vehicle, mountain bike, or animals used
as vehicles. This is clearly not in the best interests of the
wildlife, especially species like the whipsnake that are very
sensitive to the presence and activities of humans.
I urge you to use your common sense, and ignore Mr. Doyle's
letter, which represents an old, obsolete, pre-ESA way of
thinking.
Sincerely,
Michael J. Vandeman, Ph.D.
References:
Knight, Richard L. and Kevin J. Gutzwiller, eds. Wildlife and
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Recreationists. Covelo, California: Island Press, c.1995.
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Vandeman, Michael J. http://home.pacbell.net/mjvande
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I am working on creating wildlife habitat that is off-limits to
humans ("pure habitat"). Want to help? (I spent the previous 8
years fighting auto dependence and road construction.)
http://www.imaja.com/change/environment/mvarticles/
More!: http://home.pacbell.net/mjvande