On Monday night, July 10, the Cambridge Conservation Commission heard the Department of Conservation and Recreation's request for a three-year extension for DCR work at Magazine Beach. I submitted the letter posted here.
A bit of background: In September, 2004, even as the bees were tumbling in the flowers, this project ripped out a beautiful stand of plants all along the riverfront, and planted, at great expense, items chosen by the DCR's design consultant.
These delicate designer plants have been protected for almost two years by barriers on land and in the water that just coincidentally have kept the White Geese from feeding at Magazine Beach. The destruction of the flowering plants and the starvation of the White Geese are part of the same misguided policy of eradicating species deemed "non-native" and "invasive" from the Charles River parkland. The DCR and City of Cambridge have jointly been pursuing this policy at Magazine Beach.
As you can see from the letter, the Cambridge Conservation Commission believes lawn grasses are "native plants." However, they are no more or less "native" than the Charles River White Geese themselves. Whether "native" or not, the grass at Magazine Beach's 7 acres is the White Geese's primary food source. Only their friends' year-round efforts to protect the geese and to provide other food have kept the animals alive since the beginning of the project at Magazine Beach.
The City of Cambridge is footing the $1.5 million bill for this work on state parkland.
The Conservation Commission voted to continue the hearing to its August 14, 2006 meeting.
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To the Cambridge Conservation Commission:
re: DCR request for 3-year extension, DEP File No. 123-166, Magazine Beach
The original Environmental Notification Form and Notice of Intent for this project were in error. In concept and execution the project has been flawed. Consequently the request for a three-year extension should be denied.
The ENF Project Narrative (September, 2003) acknowledges that much of the land subject to flooding at Magazine Beach, i.e., the target of Phases 1a and 1b, is “often considered to be valuable wildlife habitat, especially [as at Magazine Beach] within the buffer zone of a bank or bordering vegetated wetland.” The Narrative asserts, however, that Magazine Beach’s habitat is not protected because it has been “so extensively altered by human activity that [its] important wildlife habitat functions have been effectively eliminated.” This is patently false.
The habitat value of such land at Magazine Beach has not yet been eliminated. The project before you will do so, however. It is, itself, a critical part of the DCR’s progressive elimination of habitat at Magazine Beach, is itself an environmental crime the Wetlands Protection Act is designed to prevent. As executors of the law you should deny the DCR’s request and pursue remedies for the damage done to date.
The history of the fallen willow at the upriver portion of Phase 1a, shown on all plans submitted to the Commission, indicates the problems of the DCR’s representations on this score. The tree provided valuable habitat for turtles, waterfowl, and other animals. The DCR cut up and removed the viable, living tree during the course of the project, then failed to tell the truth about it at a December 1, 2005 public meeting in Cambridge.
Further, Magazine Beach’s grassy meadows are the primary food source of the Charles River White Geese and, after the DCR’s exclusion of Canada geese from much of the lower Charles, of Canadas as well. Large groups of Mallard ducks and gulls of all sorts also rest and feed there. The habitat value of Magazine Beach is great, but doomed if the Commission grants this extension.
The ENF claims the project conforms to the Coastal Zone Management Program’s Habitat Policy #1, and will “enhance the existing habitat value of the Charles River bank” (p. 11). To the contrary, at minimum, Phase 1a has already prevented waterfowl from feeding there, beginning in September, 2004, and destroyed the willow. Completion of Phase 1a and Phase 1b will permanently destroy this primary source of food.
Thus, rather than increase public access to and uses of the Charles River, the project will permanently reduce them. Softball, soccer, small boat launchings, wildlife viewing, and quiet enjoyment of the air, land, and water were all possible before the project. To date, Phase 1a has already greatly diminished passive uses: gone are the White Geese and easy public access to the length of the water’s edge. If the Commission grants this extension, it will permanently remove Magazine Beach from the city’s (and region’s) scarce stock of passive open space—critical habitat for humans who enjoy time with the natural world on the river.
To cite only a few more examples of the agency’s failure to comply with the Order of Conditions, please note that erosion on the new walkway has not been remedied, the disturbed area by the puddle has not been reseeded. Beyond this, the DCR’s bridge at the riverfront fails to comply with the Americans with Disabilities Act and has already caused at least one bicycle accident. Only another major infusion of capital and an extended Order of Conditions will remedy these failures?
At Magazine Beach, the Commission faces a fundamental problem of the DCR’s “vegetation management” and “restorations” involving “native” or “non-invasive” plants. In its original Order of Conditions (July 15, 2003) at No. 36, the Commission assumes that lawn grasses are “native” plants (it does not specify whether “native” to North America, the East Coast, southern New England, or the Charles River, and from what date). Although you accept these grasses as “native,” they are no more so than the Charles River White Geese: early colonists had to import seeds for pasturage to North America, and lawn grasses are descended from the imports.
Conceptually, the project aims to “restore” Magazine Beach to some landscape it never was. The plants that grew on the lower Charles from the last Ice Age to the damming of the Charles changed with time and the course of the river, but they were always plants adapted to tidal flows of salty water. The section of Magazine Beach this project is to “restore” may have been entirely underwater, or tidal flat. In either case it did not have the plants the DCR’s designer chose for the banks of the now-freshwater Charles.
It may be time for the Commission to clarify issues of “native” and “invasive” plants in order properly to evaluate such “restorations.” The science of the terms is obviously confused (see Stephen Jay Gould, “An Evolutionary Perspective on Strengths, Fallacies, and Confusions in the Concept of Native Plants,” Arnoldia, Vol. 58, No 1 [1998], pp. 2-10); the confusion affects the Commission’s acts. Extending the Order of Conditions without a public process of clarification would be a mistake.
At Magazine Beach, the wind, water, and birds planted the asters, goldenrod, convolvulus, false indigo, and other plants that the DCR, with the Commission’s consent, eradicated there in September, 2004. These formed a stable, low-cost, beautiful, and “native,” even “natural” border at the river’s edge. Interestingly, it lacked purple loosestrife, a “non-native invasive” in the Commission’s terms. Following the “restoration,” however, purple loosestrife is now at Magazine Beach and will be spreading.
The Commission may wish to grant the agency the benefit of the doubt, as in so many previous DCR projects. Given the fundamental errors grounding the DCR’s effort here, you would in that case abdicate a grave responsibility to the public to protect our wetlands and associated resource areas.
Yours sincerely,
Marilyn Wellons
