United States 

Department of 

Agriculture 

Forest 

Service 

August 2012 

Environmental 

Assessment 

Cedar Creek Falls Visitor Use Permit System 

Palomar Ranger District, Cleveland National Forest 

San Diego County, California 

 
Location of Action: National Forest System lands on the Cleveland National 

Forest San Diego County, California 

Type of Document: Environmental Assessment 

Lead Agency: USDA Forest Service 

Responsible Official: William Metz, Cleveland National Forest Supervisor

Contact Person: Bjorn Fredrickson, Recreation and Lands Officer 

 Palomar Ranger District, Cleveland National Forest 

 1634 Black Canyon Road 

 Ramona, California 92065 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs 

and activities on the basis of race, color, national origin, age, disability, and where 

applicable, sex, marital status, familial status, parental status, religion, sexual 

orientation, genetic information, political beliefs, reprisal, or because all or part of an 

individual’s income is derived from any public assistance program. (Not all prohibited 

bases apply to all programs.) Persons with disabilities who require alternative means 

for communication of program information (Braille, large print, audiotape, etc.) should 

contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). 

To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 

1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-

3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and 

employer. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

 

Table of Contents 

Summary of Proposal .................................................................................................... i

1 - Introduction and Need for the Proposed Action ................................................... 1

1.1 Document Structure ..............................................................................................................1 

1.2 Location ................................................................................................................................1 

1.3 Existing Condition ................................................................................................................7 

1.4 Purpose and Need for Action ..............................................................................................10 

1.5 Decision Framework ...........................................................................................................13 

1.6 Public Involvement .............................................................................................................13 

1.7 Issues ...................................................................................................................................14 

2 - Alternatives, including the Proposed Action ....................................................... 14

2.1 Alternatives ..........................................................................................................................15 

 2.1.1 Alternative 1: No Action .............................................................................................15 

 2.1.2 Alternative 2: Proposed Action ...................................................................................15 

2.1.2.1 Adaptive Management.....................................................................17 

 2.1.3 Alternative 3: Permanent Closure ...............................................................................19 

 2.1.4 Changes Between the Draft EA and Final EA ............................................................19 

 2.1.5 Alternatives Considered and Dropped .......................................................................20 

 2.1.6 Alternatives Considered but Eliminated from Detailed Study .....................................21 

 2.1.7 Comparison of Alternatives .........................................................................................21 

3 - Environmental Consequences ............................................................................. 23 

 3.0.1 Cumulative Effects Common to the Physical, Biological, and Social Environments .23 

3.1 Physical Environment .........................................................................................................24 

 3.1.1 Soils .............................................................................................................................24 

 3.1.2 Water ...........................................................................................................................25 

3.2 Biological Environment ......................................................................................................26 

 3.2.1 Wildlife .......................................................................................................................26 

 3.2.2 Listed Species .............................................................................................................27 

 3.2.3 Vegetation ...................................................................................................................28 

3.3 Social Environment .............................................................................................................29 

 3.3.1 Public Health and Safety .............................................................................................29 

 3.3.2 Scenery and Recreation ...............................................................................................30 

 3.3.3 Heritage .......................................................................................................................32 

 3.3.4 Adjacent Private Property (SDCE) .............................................................................33 

 3.3.5 Environmental Justice (Executive Order 12898) ........................................................34 

4 - Persons, Groups, Organizations, and Agencies Consulted ............................... 35 

5 - References ............................................................................................................. 36 

List of Tables 

Table 1: Summary of Cedar Creek Falls parking patterns observed on busy days in SDCE and 

Along Eagle Peak Road in 2007 and 2011 ...................................................................................8 

Table 2: Summary of estimated Cedar Creek Falls visitation on busy days in 2007 and 2011, 

based on the parking patterns depicted in Table 1 .......................................................................9 

Table 3: Projected daily visitation to the Cedar Creek Falls visitor use permit area, based on 

the initial proposal to issue 75 visitor use permits per day ........................................................16 

Table 4: Metrics that govern the increases and/or decreases in the number of visitor use 

permits issued .............................................................................................................................18 
List of Figures 

Figure 1: Project Area Map ......................................................................................................... 3 

Figure 2: Visitor Use Permit Area Detail .................................................................................... 4 

Figure 3: Cedar Creek Falls Alcohol Prohibition Map ................................................................ 5 

Figure 4: Cedar Creek Falls Cliff Closure Map ........................................................................... 6 

Appendices 

Appendix A: Tribal Consultation .............................................................................................. 38 

Appendix B: Cedar Creek Falls Visitor Use Permit System Questions and Answers............... 39 

Appendix C: Response to Comments Received During Scoping and Comment Period ........... 42 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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SUMMARY OF PROPOSAL 

The proposed action is to designate a visitor use permit area in the vicinity of Cedar 

Creek Falls (CCF). Visitors to this area would be required to obtain a visitor use permit 

through the National Recreation Reservation Service (NRRS). A limited number of 

visitor use permits would be issued each day. The number of visitor use permits issued 

would be adjusted as determined by an adaptive management process. The proposed 

action also includes permanently prohibiting the possession of alcohol at CCF, along the 

trail and at the trailheads; and permanently closing the cliff faces surrounding CCF to 

public access. 

This project addresses concerns related to: 

• Public health and safety at CCF, and on the San Diego River Gorge Trail (SDRG 

Trail) and Eagle Peak Road (Trail) 

• Resource impacts stemming from high levels of recreational use at CCF, and on 

the SDRG Trail and Eagle Peak Road (Trail) 

• Traffic congestion and parking concerns in the San Diego Country Estates 

(SDCE) neighborhood that result from high levels of recreational use at CCF 

There is a high public demand for recreation opportunities in the CCF area. Implementing 

a visitor use permit system as well as prohibiting alcohol consumption and access to the 

cliff access will maintain these opportunities while mitigating the natural resource, 

recreation, and social concerns listed above. 

The environmental assessment does not identify any significant environmental 

consequences resulting from the proposed action. 

Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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1 - INTRODUCTION 

1.1 - Document Structure __________________________ 

The Forest Service has prepared this Environmental Assessment in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal laws and regulations. This Environmental 

Assessment (EA) discloses the direct, indirect, and cumulative environmental impacts that would result 

from the proposed action and alternatives. The document is organized into four chapters:

• Chapter one - Introduction: This section includes information on the existing condition and purpose and 

need for the project, including a summary of Cleveland National Forest Land Management Plan 

direction as it relates to the project. This section also provides an overview of how the Forest Service 

informed the public of the proposed action and draft EA. 

• Chapter two - Alternatives, including the Proposed Action: This section provides a description of the 

proposed action as well as possible alternative methods for achieving the stated purpose. These 

alternatives were developed based on issues raised internally, by the public, and by other agencies. This 

section also includes a discussion of alternatives initially considered but dropped. 

• Chapter three - Environmental Consequences: This section describes the environmental effects of 

implementing the proposed action and alternatives. This analysis is organized by resource. Within each 

section, relevant information on the affected environment is described, followed by the effects of the No 

Action Alternative that provides a baseline for evaluation and comparison of the other alternatives that 

follow. 

• Chapter four – Persons, Groups, Organizations, and Agencies Consulted: This section provides an 

overview of the persons, groups, organizations, and agencies consulted as part of this project. 

• Chapter five – References: This section lists the references to published and unpublished sources cited in 

the body of the EA. This section also provides a list of preparers and those groups, organizations, and 

agencies consulted during the development of the environmental assessment. 

• Appendices: The appendices include information regarding Tribal consultation on this project; questions 

and answers about the proposed visitor use permit system; and responses to the comments received 

during the project’s scoping and comment periods. 

Additional documentation, including more detailed analyses of the project’s effects on natural resources, 

additional background information, and public comments, may be found in the project record located at the 

Palomar Ranger District Office in Ramona, CA. 

1.2 - Location ____________________________________ 

The location of the project area is Cedar Creek Falls (CCF) and its immediate vicinity within the San Diego 

River Gorge, as well as the trailheads and trails that lead to CCF. CCF is accessed from the west via the San 

Diego River Gorge Trail and Trailhead (“SDRG Trail” and “SDRG Trailhead,” respectively). Visitors 

access CCF from the east via an abandoned section of Eagle Peak Road, hereafter referred to as “Eagle Peak 

Road (Trail).” No developed trailhead facilities exist at any point along Eagle Peak Road (Trail), though 

visitors using the eastern access to CCF typically park at a large, undeveloped dirt pullout traditionally used 

by forest visitors, hereafter referred to as “Saddleback Trailhead.” 

The legal land description of the project area is Township 14 South, Range 2 East, Sections 1 and 2; 

Township 13 South, Range 2 East, Sections 34, 35, and 36; and Township 13 South, Range 3 East, Section 

31; San Bernardino Meridian. See Figure 1 on page 3 for a map of the project area. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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The proposed visitor use permit area is located in the immediate vicinity of CCF. The legal land description 

of the visitor use permit area is Township 14 South, Range 2 East, Sections 1 and 2; and Township 13 

South, Range 2 East, Section 36; San Bernardino Meridian. See Figure 2 on page 4 for a map of the 

proposed visitor use permit area. 

The proposed permanent alcohol prohibition would cover the project area. The legal land description of the 

proposed alcohol prohibition is Township 14 South, Range 2 East, Sections 1 and 2; Township 13 South, 

Range 2 East, Sections 34, 35, and 36; and Township 13 South, Range 3 East, Section 31; San Bernardino 

Meridian. See Figure 3 on page 5 for a map of the proposed Cedar Creek Falls Alcohol Prohibition. 

The proposed permanent cliff closure at CCF would be located in Township 14 South, Range 2 East, 

Section 1, San Bernardino Meridian. See Figure 4 on page 6 for a map of the proposed Cedar Creek Falls 

Cliff Closure. 

 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Figure 1. Project Area Map 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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Figure 2. Visitor Use Permit Area Detail 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Figure 3. Cedar Creek Falls Alcohol Prohibition Map
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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Figure 4. Cedar Creek Falls Cliff Closure Map 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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1.3 Existing Condition_____________________________ 

Currently, CCF can be accessed from both the west and east sides of the Palomar Ranger District via the 

SDRG Trailhead and Saddleback Trailhead, respectively. Until the completion of the SDRG Trail and 

Trailhead in the spring of 2011, access to this recreation destination from the west side of the Palomar 

Ranger District was via informal, user-created trails. Visitors from the east have traditionally used 

Saddleback Trailhead and Eagle Peak Road (Trail), which is currently gated near the junction of Eagle Peak 

and Cedar Creek Roads. 

On July 9, 2011, CCF, the SDRG Trail and Trailhead, Eagle Peak Road (Trail), and the Saddleback 

Trailhead were temporarily closed using a Forest Order (Order No. 02-11-05, followed by Order No. 02-11-

09). The purpose of this order was to allow the Forest Service to address public health and safety issues and 

resource issues associated with recreational use at CCF. On April 1, 2012 this Forest Order was modified to 

restore public access to CCF via the Saddleback Trailhead and Eagle Peak Road (Trail); as of April, 2012 

the area surrounding the SDRG Trail and Trailhead remains temporarily closed (Order No. 02-12-04). In 

addition, two new temporary Forest Orders were implemented on April 1, 2012. The first of these Orders 

prohibits the possession and consumption of alcohol at CCF, along the SDRG Trail and Eagle Peak Road 

(Trail), and at the SDRG and Saddleback Trailheads (Order No. 02-12-05). The second of these Orders 

closes the cliff faces surrounding CCF to public access, which in effect prohibits visitors from climbing on 

and jumping from the cliffs surrounding CCF (Order No. 02-12-06). 

Parking 

The SDRG Trailhead parking lot, adjacent to the San Diego Country Estates (SDCE), accommodates 29 

vehicles, including 2 ADA compliant parking spaces. No developed parking currently exists at the 

Saddleback Trailhead, although visitors have long used a large, undeveloped dirt pullout at the junction of 

Eagle Peak and Cedar Creek Roads as an informal parking area. The developed parking area at the SDRG 

Trailhead was not designed to regulate or limit visitation to the Cleveland National Forest or to prevent 

forest visitors from parking on County roads, but rather to alleviate some parking congestion on County 

roads. 

CCF has long been a popular recreation destination in San Diego County, though recreational use of this 

area has increased in recent years. See Table 1 for a summary of visitor use levels in 2007 as compared to 

2011. Overflow parking in recent years in SDCE that is associated with public visitation to CCF has been 

observed most frequently on the following County of San Diego maintained public roads: 

• Thornbush Road 

• Love Lane 

• Cathedral Way 

• Cherish Way 

• Bellbottom Way 

• Ramona Oaks Road 

All parking associated with public access to CCF from the east side of the Palomar Ranger District occurs at 

or adjacent to the Saddleback Trailhead on Eagle Peak Road, a County of San Diego maintained public dirt 

road. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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Table 1. Summary of CCF parking patterns routinely observed on busy days in SDCE (adjacent to SDRG 

Trailhead) and at Saddleback Trailhead in 2007 and 20111

2007 2011 

Vehicles parked per day in SDCE 50-60 200-300

Vehicles parked per day at Saddleback Trailhead 20 80

Total vehicles parked per day at or near both trailheads 70-80 280-380

Proportion of vehicles parking in SDCE 71-75% 71-79%

Proportion of vehicles parking at Saddleback Trailhead 25-29% 21-29%

Vehicles parked in SDCE on busiest day observed 730 

Visitation Estimates 

Forest Service staff – which began monitoring parking levels at the SDRG Trailhead in 2007 and 

collectively has years of experience managing CCF and the surrounding area – estimate that the average 

vehicle at the trailheads that lead to CCF has historically contained approximately 3 people. The Forest 

Service therefore assumes that on average each vehicle at the SDRG Trailhead and Saddleback Trailhead 

continues to contain 3 hikers. Use in the CCF area has grown from approximately 210 to 240 hikers on a 

typical busy day in 2007 to 840-1140 hikers per day on a typical busy day in 2011. On the busiest day 

observed in 2011 this estimate of average vehicle occupancy yields a figure of approximately 2,190 

individuals accessing the SDRG Trailhead and Trail. It is important to note that this latter figure does not 

include the additional visitation that occurred from the Saddleback Trailhead on this busy day because no 

traffic counts were collected at the Saddleback Trailhead at that time. 

While Forest Service staff estimate that vehicles at the SDRG and Saddleback Trailheads have historically 

contained an average of 3 visitors, a number of other sources of information about vehicle occupancy in this 

area exist as well. For instance, San Diego Sheriff’s Department Deputies posted at the SDRG Trailhead 

between July 9, 2011 and November, 13, 2011 counted an average of 2.1 occupants per vehicle that pulled 

up to the trailhead, although the trailhead was closed during this period (Sgt. Bavencoff, personal 

communication, January 10, 2012). Additionally, in 2009 the Forest Service undertook a study of 

recreational use characteristics across the Cleveland National Forest as part of the Forest Service National 

Visitor Monitoring Use survey. The results of this survey show that vehicles visiting the Cleveland National 

Forest contained an average of 2.3 individuals (USDA, 2009). Table 2 provides the full range of known 

vehicle occupancy estimates that may apply to this area. 

 

1

 These figures are based on both long-term Forest Service staff observations and a San Diego County Traffic Advisory 

Committee (2011) study. The San Diego County Traffic Advisory Committee study of daily traffic volumes in the neighborhood 

adjacent to the SDRG Trailhead occurred in April and May of 2011. This report details the figures presented in this document and 

is available in the project record. Estimates of vehicles at the Saddleback Trailhead are based on Forest Service observations. 

Figures related to the number of vehicles parking in the vicinity of the SDRG and Saddleback Trailheads are for the number of 

vehicles observed throughout the course of one day, not the number of vehicles observed at one time. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Table 2. Summary of estimated CCF visitation on average busy days in 2007 and 2011, based on the 

parking patterns depicted in Table 12

Total visitors Visitors at CCF, 

based on 95% 

visitation rate 

Visitors at CCF, 

based on 90% 

visitation rate 

Visitation in 2007 @ 3 

visitors per vehicle 

210-240 200-228 189-216 

Visitation in 2011 @ 3 

visitors per vehicle 

840-1,140 798-1,083 756-1,026 

Visitation in 2007 @ 2.3 

visitors per vehicle 

161-184 153-175 145-166 

Visitation in 2011 @ 2.3 

visitors per vehicle 

644-874 612-830 580-747 

Visitation in 2007 @ 2.1 

visitors per vehicle 

147-168 140-160 132-151 

Visitation in 2011 @ 2.1 

visitors per vehicle 

588-798 559-758 529-718 

Increased public use of this area over the past 5 years is likely the result in part of a rise in media attention, 

especially in the form of social media – CCF now has its own “Facebook” page as well as dedicated pages 

on other social media and Internet sites. Further complicating this issue, three consecutive wet years 

following a prolonged drought resulted in higher visitation year-round in 2011 in contrast to the past when 

visitor use substantially declined when the water dried up. Trail improvements completed in the spring of 

2011 and high levels of media attention to the controversies surrounding CCF contributed to and increased 

use and exacerbated management challenges. 

Health and Safety

Since 1998 three individuals have died while jumping from the cliffs into the pool below CCF, and others 

have suffered severe injury, including permanent paralysis. Additionally, in 2012 one individual died from 

heat stroke on Eagle Peak Road (Trail). According to the San Diego Sheriff’s Department, CCF and the 

SDRG Trail produce more rescues than any other area in the San Diego County Sheriff’s jurisdiction. 

During the 2010 calendar year, Sheriff’s Department rescue personnel conducted a total of 31 helicopter 

medical assist calls to the CCF area. In 2011 the Sheriff’s Department conducted 31 helicopter medical 

assist calls between January 1 and July 9, when the area surrounding CCF was closed to public access (Lt. 

Richardson, personal communication, March 20, 2012). Approximately ninety percent of these calls were 

related to dehydration; the remaining rescues were associated with injuries and other medical conditions, 

some sustained by visitors who were jumping and diving from the cliffs surrounding CCF. 

The CCF area has had a history of alcohol consumption by visitors. Safety issues stemming from alcohol 

use are exacerbated by hot temperatures routinely exceeding 100 degrees Fahrenheit during the summer 

months. Further, by 2011 large assemblages of young people and partying had become common around 

CCF – prior to its temporary closure in July of 2011 the area had become known widely as a “party spot.” 

 

2

 The vast majority of visitors to the Cleveland National Forest who park in SDCE and at the Saddleback Trailhead intend to visit 

CCF. Forest Service staff estimate that up to 95% of visitors to this area seek to visit CCF. The “95% visitation rate” and “90% 

visitation rate” columns in Table 2 depict estimated use levels over the course of a busy day at CCF if 95% and 90% forest-related 

recreational traffic in SDCE and at the Saddleback Trailhead is related visitation at CCF. It is important to note that these 

visitation estimates do not mean that all the visitors that visit CCF over the course of the day are present at the same time. Rather, 

visitors have historically visited CCF for varying lengths of time between the early morning and evening hours. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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Issues related to illegal campfires, jumping or diving from cliffs, and dehydration are intensified by alcohol 

use. 

Resource and Social Impacts 

Increasing visitation to CCF over time has resulted in resource impacts at CCF, and along the SDRG Trail 

and Eagle Peak Road (Trail). Signage and other infrastructure, such as wire fencing, are increasingly being 

torn down by recreationists at CCF and along the trails. Littering has become commonplace at CCF and 

along the trails. User-created trails are causing erosion and are threatening the integrity of the existing trails. 

The “party atmosphere” that has developed at CCF over the past few years is often associated with illegal 

campfires, which risk igniting a wildfire in the San Diego River Gorge. Littering and the creation of social 

trails also impact wildlife and plant species, and degrade riparian areas and water quality. Federally listed 

endangered and threatened species that occur in the project area and may be impacted by the extreme levels 

of visitation observed in early 2011 include Arroyo Southwestern Toad, California Gnatcatcher, Least Bell’s 

Vireo, and Southwestern Willow Flycatcher. 

The SDRG Trailhead parking lot can accommodate 29 vehicles. During busy periods at CCF in the past 

hundreds of motor vehicles spilled over into the SDCE neighborhood. With hundreds of motor vehicles 

consistently parking in the neighborhood in the past, neighbors from SDCE complained of trespass, unruly 

forest visitor behavior, traffic congestion, and speeding on neighborhood streets, and also frequently 

reported that large groups are partying at CCF or the SDRG Trailhead. 

1.4 - Purpose and Need for Action___________________ 

For the following reasons there is a need for managing visitor use at CCF: 

1. Visitation at CCF on a busy weekend day or holiday has increased from approximately 210 to 240 

people in 2007 to approximately 840 to 1,140 in 2011 with resulting impacts to natural and social 

resources. 

2. Risky visitor activities at CCF have resulted in deaths, severe injuries, heat-related illness, and 

dehydration. Instances of heat-related illness and dehydration in particular have increased in recent 

years. 

3. The ongoing growth in visitation levels at CCF has been linked to increasing vandalism of recreation 

infrastructure, littering, and user-created trails. Associated impacts occur to wildlife and plant 

species, riparian areas, and water quality. Littering and the creation of social trails potentially impact 

a number of federally listed endangered and threatened species in the project area, including Arroyo 

Southwestern Toad, California Gnatcatcher, Least Bell’s Vireo, and Southwestern Willow 

Flycatcher. 

4. Increasing visitation at CCF has resulted in overflow parking in the SDCE neighborhood growing 

from approximately 50-60 vehicles on a typical busy day in 2007 to 200-300 on a typical busy day 

and more than 700 on the busiest day observed in 2011. This increased level of overflow parking in 

SDCE is associated with a growth in the number of complaints about private property trespass, 

unruly forest visitor behavior, and traffic congestion on neighborhood streets. 

In meeting this need, the proposal must meet the following purposes: 

1. Provide for public access to and use of CCF. There is a high level of public demand for recreational 

opportunities at CCF and it is expected that this demand with continue or perhaps grow. CCF is an 

important public resource, and it is therefore necessary to provide reasonable access to this unique 

and popular natural feature. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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2. Provide for public safety. The current party atmosphere and associated alcohol use have created an 

unsafe situation due to the steep cliff faces surrounding CCF along with difficult hiking conditions 

on the SDRC Trail and Eagle Peak Road (Trail). 

3. Manage for an environmentally sustainable ecosystem and positive visitor experience. Currently 

visitors litter and create social trails, which damage vegetation; cause soil erosion; degrade riparian 

areas and water quality; and potentially disturb endangered, threatened, and sensitive species. 

4. Reduce overflow parking impacts in SDCE. 

Relevant Cleveland National Forest Land Management Plan Direction 

The proposed action works toward the forest management goals as described in the 2005 Revised Cleveland 

National Forest Land Management Plan (Forest Plan) (USDA, 2005). Forest Plan strategies, standards, and 

guidelines relevant to the proposed visitor use permit area are summarized below:

REC - 2 – Sustainable Use and Environmental Design (Forest Plan Part 2, CNF Strategy, pg. 103) 

Analyze, stabilize and restore areas where visitor use is negatively affecting recreation experiences, public 

safety and environmental resources. Manage visitor use within the limits of identified capacities: 

• Implement control measures in specific high-use areas as use levels become a concern. 

• Implement Adaptive Mitigation for Recreation Uses in existing and new recreation sites and uses 

whenever a conflict between uses or sensitive resources is detected. 

TRANS - 3 – Improve Trails (Forest Plan Part 2, CNF Strategy, pg. 109) 

Develop an interconnected, shared-use trail network where compatible and support facilities compliment 

local, regional and national trails and open space, and also enhance day-use opportunities and access for the 

general public: 

• Construct and maintain the trail network to levels commensurate with area objectives, sustainable 

resource conditions, user safety, and the type and level of use. Convert ecologically sustainable 

unclassified roads and trails, and other roads that meet the need for trail-based recreation. 

• Maintain and/or develop access points and connecting trails linked to the surrounding communities 

and to create opportunities for non-motorized trips of short duration. 

• New trail construction projects will emphasize development of partnerships and cooperative 

agreements for construction, future maintenance, and reconstruction. 

Fish and Wildlife Standards (Forest Plan Part 3: Design Criteria for Southern California Forests, pgs. 6-8). 

• S11: When occupied or suitable habitat for a threatened, endangered, proposed, candidate or 

sensitive (TEPCS) species is present on an ongoing or proposed project site, consider species 

guidance documents to develop project-specific or activity-specific design criteria. This guidance is 

intended to provide a range of possible conservation measures that may be selectively applied during 

site specific planning to avoid, minimize or mitigate negative long-term effects on TEPCS species 

and habitat. 

• S12: When implementing new projects in areas that provide for threatened, endangered, proposed, 

and candidate species, use design criteria and conservation practices so that discretionary uses and 

facilities promote the conservation and recovery of these species and their habitats. Accept short-
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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term impacts where long-term effects would provide a net benefit for the species and its habitat 

where needed to achieve multiple-use objectives. 

• S24: Mitigate impacts of ongoing uses and management activities on threatened, endangered, 

proposed, and candidate species. 

• S33. Manage Special Interest Areas so that activities and discretionary uses are either neutral or 

beneficial for the resource values for which the area was established. Accept short-term adverse 

impacts to these resource values if such impacts will be compensated by the accrual of long-term 

benefit. 

Soil, Water, Riparian and Heritage Standards (Forest Plan Part 3: Design Criteria for Southern California 

Forests, pg. 11). 

• S50: Mitigate long term impacts from recreation use to soil, watershed, riparian or heritage 

resources. 

Appendix D – Adaptive Mitigation for Recreation Uses & Recreation Implementation Guidelines (Forest 

Plan Part 3: Design Criteria for Southern California Forests, pgs. 63-64). 

These guidelines apply to all existing and new recreation sites and uses whenever a conflict between uses or 

sensitive resources is detected. Sensitive resources include threatened, endangered, proposed, candidate, and 

sensitive species and habitats; riparian habitats, soil and watersheds; heritage resources; user conflicts; or 

other resources. The management actions will be implemented in the order (education; perimeter control; 

management presence; redirection of use-if appropriate) listed below unless analysis of the conflict clearly 

indicates a stronger measure is immediately necessary. The actions and practices include, but are not limited 

to: 

1. Conservation Education 

• Use information networks, including public service announcements, internet sites and links, and 

visitor guides, newsletters to communicate information regarding sensitive resources. 

• Install and maintain appropriate multilingual information boards, interpretive panels and regulatory 

signs at developed sites and dispersed areas within sites of sensitive resources. 

2. Perimeter Control 

• Modify visitor access to manage use. Install and maintain appropriate fencing or other barriers to 

protect sensitive resource areas. Limit the number of users at the site or area. 

3. Presence 

• Provide adequate management presence to ensure protection of sensitive resources. This presence 

could include Forest Service personnel, peer education, concessionaires, other permit holders, and 

volunteer support. 

4. Direct Action 

• Where visitor use is restricted – a) Limit or control use at developed recreation sites and areas 

through a permit system; b) When other actions are ineffective enact and enforce Forest Orders to 

protect sensitive resource areas through use of seasonal or temporary closures; c) Seek opportunities 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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to proactively design and locate new facilities and areas for re-distributing human use away from 

sensitive resources. 

• Limit visitor use of recreation sites and areas through diurnal, seasonal or temporary closures during 

critical life cycle periods for affected threatened, endangered, proposed, candidate, and sensitive 

species. 

Upper San Diego River: Standards, Desired Conditions and Program Emphasis (Forest Plan Part 2, 

CNF Strategy, pg. 67).

• Maintain as a remote, natural appearing landscape that functions as a respite for the surrounding 

urban population. Attributes to be preserved (or restored) over time include a diverse mosaic of 

natural habitats, rare plant and wildlife communities and the undisturbed character and panoramic 

views and features. Opportunities for developed recreation and trails (including the Trans-County 

Trail) improve through time. Program emphasis for the Upper San Diego River Place includes 

maintaining a natural appearing setting for dispersed recreation activities and to increase public 

understanding of natural systems through education and interpretation. Recreation management in 

the vicinity of CCF will be improved. Acquire rights-of-way to improve administrative and public 

access. Plan a trail system and develop support facilities commensurate with forest plan objectives 

to allow safe access to popular destinations, including an east/west section of the Trans-County 

Trail. Support the efforts of the San Diego River Conservancy to the extent feasible. Assess the 

landscape for opportunities to provide developed campgrounds and enhanced trail-based recreation. 

Conserve biological values associated with the Research natural Areas. Monitor coastal sage scrub in 

the San Diego River bottom and take adaptive management measures to protect important habitats as 

necessary. Develop management plans for special areas.

1.5 - Decision Framework __________________________ 

The environmental assessment (EA) discloses environmental effects of the no-action alternative, a proposed 

action, and a permanent closure alternative. The Responsible Official, the Cleveland National Forest 

Supervisor, will make a decision based on the review of the EA. The Forest Supervisor’s decision will 

include: 

1. Whether to proceed with the proposed action, “no action,” or permanent closure alternative.

2. Whether the decision that is selected would have significant impacts. If a determination is made that 

no impact is significant, then a “Finding of No Significant Impact” (FONSI) would be prepared. 

Significant impacts would require the preparation of an Environmental Impact Statement [40 CFR 

1501.4 (c) and (e)].

The Forest Supervisor’s decision will be documented in a separate Decision Notice (FSH, 1909.15 - 40).

1.6 - Public Involvement ___________________________ 

The proposal was first listed in the Schedule of Proposed Actions in September, 2011. A legal notice 

offering a 30 day scoping period on the proposed action was printed in the San Diego Union Tribune on 

December 13, 2011. The Forest Service also posted notices at the two trailheads that lead to CCF, a 

hardware store in the San Diego Country Estates, in the front office of the Palomar Ranger District, and on a 

number of social media sites with dedicated CCF pages. Finally, the proposal was provided to interested 

agencies, groups and individuals, and Tribes for input during scoping between December 13, 2011 and 

January 12, 2012, including to the SDCE Association and its members. A legal notice of the EA’s comment 

period was published in the San Diego Union Tribune on April 17, 2012. At this time the draft EA was 

provided to the same groups, organizations, Tribes, and individuals contacted during scoping. In addition, as 

part of the public involvement process the agency convened a series of three stakeholder dialogue sessions 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

14 

between August and October, 2011. These dialogue sessions were attended by representatives of recreation 

user groups, local governments, and elected officials. The notes from these dialogue sessions can be found 

in the project record. 

All input received during the course of scoping, the comment period, and other public involvement activities 

was considered by an interdisciplinary team (IDT). A summary and response to comments received during 

the scoping and comment periods can be found in Appendix C. Thirty (30) scoping comments, seventeen 

(17) comment period comments, and notes about other public involvement activities can be found in the 

project record. These comments either resulted in new project design features or did not generate significant 

issues related to the proposal. 

1.7 - Issues ______________________________________ 

Based on internal and external scoping, the interdisciplinary team (ID team) developed a list of issues. The 

ID team decided the following issues warranted full analysis in this EA to determine their significance 

and/or contributed to project design features. 

• Impacts to human health and safety: specifically concerns related to heat-related illness, alcohol 

use, and visitors jumping from the cliffs surrounding CCF. 

• Increasing visitation trends that have led to traffic congestion and parking in the adjacent 

SDCE neighborhood: including forest visitors parking on County roads, traffic congestion on 

neighborhood streets, littering, and private property trespassing. 

• Impacts to soils: specifically erosion resulting from the proliferation of user-created trails. 

• Impacts to water quality: both downstream and immediately on site. 

• Impacts to wildlife: including federally listed threatened and endangered species, Forest Service 

Management Indicator Species, and animal species on the R5 Regional Forester Sensitive animal 

species list. 

• Impacts to vegetation: including riparian vegetation, R5 Regional Forester Sensitive plant species, 

Forest Service Management Indicator Species, and federally listed threatened and endangered 

species. 

• Impacts to scenery and recreation: specifically recreation access, the quality of visitor 

experiences, and scenery. 

• Impacts to cultural resources: including pre-historic and historic sites. 

• Environmental justice concerns: specifically the impact of the $6 administrative fee associated 

with the proposed visitor use permit on low-income communities. 

2 - ALTERNATIVES, INCLUDING THE PROPOSED ACTION 

This chapter describes and compares the alternatives considered for this project. This chapter includes a 

description of each alternative, a table that allows for the comparison of the alternatives, an overview of 

changes to the proposal over the course of the project, and a discussion of alternatives considered by 

eliminated from detailed study. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

15 

2.1 - Alternatives _________________________________ 

2.1.1 - Alternative 1 

No Action 

Under the No Action alternative, historic management would continue to guide management of the project 

area. A visitor use permit area would not be established in the vicinity of CCF; a permanent alcohol 

prohibition would not be implemented at CCF, along the SDRG Trail and Eagle Peak Road (Trail), or at the 

SDRG and Saddleback Trailheads; the cliff faces at CCF would not be closed to public access; and the 

temporary forest orders that have been instituted in the project area would expire. Access to CCF, from both 

the SDRG and Saddleback Trailheads, would remain unlimited. 

2.1.2 - Alternative 2

Proposed Action 

The proposed action includes the designation of a visitor use permit area in the immediate vicinity of CCF 

to manage visitation at this site in order to decrease the severity of resource impacts at CCF, and along the 

SDRG Trail and Eagle Peak Road (Trail). The proposed visitor use permit area is illustrated graphically in 

Figure 2, Visitor Use Permit Area Detail, on page 4. It also includes Forest Orders that prohibit the 

possession of alcohol at CCF, along the SDRG Trail and Eagle Peak Road (Trail), and at the SDRG and 

Saddleback Trailheads (Figure 3, page 5), as well as the closure of the cliff faces at CCF to public access 

(Figure 4, page 6), in order to address public health and safety concerns. The Forest Service assumes that by 

managing visitation at CCF and altering the typical visitor clientele that these actions will also reduce social 

impacts in SDCE as compared to those observed in the past. 

The visitor use permit system would allow visitors to reserve the opportunity to visit the visitor use permit 

area in the immediate vicinity of CCF via the National Recreation Reservation Service (NRRS). NRRS 

allows visitors to make reservations online or by phone.3 In addition to allowing members of the public to 

reserve the opportunity to visit the visitor use permit area on a given day, NRRS would present the Forest 

Service with a novel opportunity to provide visitors – as part of their visitor use permit package – with 

information related to public health and safety and relevant Leave No Trace recreation principles. 

Specifically, the Forest Service would use the NRRS system to include educational information on the 

following topics in the visitor use permit packet: 

• The length and difficulty of the hike to CCF 

• How to prepare for the hike, including proper attire and footwear, and the need to bring adequate 

food and water 

• Local weather patterns and potential hazards along the trail and at CCF 

• Area regulations, including the alcohol prohibition and closure of cliff faces at CCF 

• Proper techniques for the disposal of human waste and trash along the trail and in the vicinity of 

water bodies (“Leave No Trace” and “Pack it in, pack it out” practices) 

• Limiting resource impacts by staying on designated trails 

• Respecting wildlife and plant communities 

The visitor use permit is designed to manage the number of groups allowed to access CCF from the SDRG 

and Saddleback Trailheads on a given day; this number – set initially at 75 – is based on a balance between 

 

3 NRRS currently charges an administrative fee of $6 per visitor use permit reserved. This administrative cost is distinct from a 

recreation fee, and is not collected or retained by the Forest Service. See Appendix B, Cedar Creek Falls Visitor Use Permit 

System Questions and Answers, for additional information about the mechanics of the proposed visitor use permit system. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

16 

resource and social impacts, as well as providing continued public access to this popular site.4 A visitor use 

permit would allow a group of up to 5 people – the maximum capacity of a typical passenger vehicle – to 

access the visitor use permit area surrounding CCF.5 The visitor use permit system would therefore initially 

allow a maximum of 375 recreationists to access the visitor use permit area in a given day. Figure 2 on page 

4, Visitor Use Permit Area Detail, provides a map of the visitor use permit area. No visitor use permit would 

be required to hike on the SDRG Trail or Eagle Peak Road (Trail) for those visitors who do not seek to visit 

CCF. 

While the initial proposal to issue 75 visitor use permits per day would allow a maximum of 375 people to 

access the visitor use permit area surrounding CCF in one day, it is unlikely that each and every visitor use 

permit reserved would be filled to capacity with a group of 5. Rather, the number of people attached to each 

visitor use permit may be between 2.1 and 3.0 per vehicle (see Table 2, Section 1.3). If these estimates for 

average group size hold true at CCF, average daily visitation to the visitor use permit area may be between 

158 and 225 people. 

Table 3. Projected daily visitation to the CCF visitor use permit area, based on the initial proposal to issue 

75 visitor use permits per day. 

Estimated average 

group size 

Source of estimate Total average daily visitation 

3 Forest Service staff observations 225 

2.3 National Visitor Use Monitoring 

study (USDA, 2009) 

173 

2.1 San Diego Sheriff Department 

deputies (Sgt. Bavencoff, personal 

communication, January 10, 2012) 

158 

Regardless of average group size, the number of visitor use permits issued would be fluid and would be 

adjusted according to an adaptive management process, as described below in Section 2.1.2.1 of the EA. 

The ultimate goal of employing the adaptive management process is to recognize uncertainty in natural 

resource concerns and maintain the 2007 baseline condition of resources in the project area while providing 

for continued recreation access. Based on estimates of average daily visitation (Table 3) and average 

vehicular traffic at the trailheads that lead to CCF (Section 1.3), the initial figure of 75 visitor use permits 

represents a level of use similar to that which was observed in 2007. As such, this level of use will allow the 

Forest Service to strike a balance between experiencing unacceptable impacts as described in Section 1.3 of 

this document and allowing the public to enjoy continued access to CCF. 

The requirement that visitors obtain a visitor use permit to visit CCF would be enforced under 36 CFR 

261.50(a), Prohibitions in Areas Designated by Order. Currently, the fine for violating an Order in Southern 

California is $75. 

See Appendix B to this document for additional details about the mechanics of the visitor use permit. 

 

4

 The visitor use permit would apply to recreationists and other forest visitors seeking to visit CCF. In addition to issuing visitor 

use permits to recreationists and other forest visitors on a given day, the Forest Service reserves the right to grant volunteers 

engaged in monitoring or stewardship activities access to the visitor use permit area in order to complete their volunteer activities. 

5

 The Forest Service assumes that members of groups that have obtained a visitor use permit will travel together to the SDRG and 

Saddleback Trailheads in one vehicle. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

17 

In addition to the proposed visitor use permit area and adaptive management process, a number of other 

actions would address health and safety concerns in the project area. Specifically, the Forest Service would 

permanently prohibit the consumption of alcohol within the visitor use permit area, at the SDRG and 

Saddleback Trailheads, and within 1⁄4 mile of the SDRG Trail and Eagle Peak Road (Trail) on National 

Forest System lands. It would also permanently close the cliff faces surrounding CCF to public use. For 

maps of these actions, see Figure 3, Cedar Creek Falls Alcohol Prohibition, on page 5; Figure 2, Visitor Use 

Permit Area Detail, on page 4; and Figure 4, Cedar Creek Falls Cliff Closure, on page 6. 

The Forest Service would also make every effort possible to notify visitors about the visitor use permit 

required to visit CCF prior to their arrival at the trailhead. Proposed steps include: 

• Installing “Visitor Use Permit Required to Visit CCF” or similar signs as appropriate to inform the 

public about the visitor use permit system. 

• Issuing a news release prior to the implementation of the visitor use permit system. 

• Posting notification about the visitor use permit system on the Cleveland National Forest website 

and on social media sites with dedicated CCF Pages. 

• Posting information about alternate hikes in and around Ramona and Julian, CA on the Cleveland 

National Forest website and at the trailheads that lead to the CCF. 

2.1.2.1 – Adaptive Management 

Employing “adaptive management” would help the Cleveland National Forest find the right balance 

between providing recreation access to CCF and meeting intended environmental outcomes. According to 

36 CFR 220.3, adaptive management is “a system of management practices based on clearly identified 

intended outcomes and monitoring to determine if management actions are meeting those outcomes; and, if 

not, to facilitate management changes that will best ensure that those outcomes are met or re-evaluated. 

Adaptive management stems from the recognition that knowledge about natural resource systems is 

sometimes uncertain.” Further, 36 CFR 220.5(e)(2) states that “an adaptive management proposal or 

alternative must clearly identify the adjustment(s) that may be made when monitoring during project 

implementation is not having its intended effect, or is causing unintended and undesirable effects. The [EA] 

must disclose not only the effect of the proposed action or alternative but also the effect of the adjustment.” 

In order to allow the Forest Service to determine when project implementation is not having its intended 

effect, or is causing unintended and undesirable effects, the following metrics are proposed for monitoring. 

The intent is to address the concerns and needs related to natural resources as outlined in Sections 1.3 and 

1.4 of this document, as well as additional resource concerns raised by members of the interdisciplinary 

team and the public. Each metric includes a threshold or limit which, if exceeded, would trigger a quarterly 

(every three months) 20% reduction in visitor use in the first year of project implementation. Adjustments to 

the number of visitor use permits issued in subsequent years would occur on a bi-annual (every six months) 

or annual basis as resource conditions warrant. 

1. Litter: Marginal Condition Class within the visitor use permit area according to the Rapid Trash 

Assessment Worksheet for three consecutive weeks, based on weekly monitoring during the high 

water period (typically November through May).6

 

6

 The Rapid Trash Assessment Worksheet was developed by the San Francisco Bay Regional Water Quality Control Board 

Surface Water Ambient Monitoring Program (SWAMP, 2007). Trash monitoring will be conducted weekly by District Staff 

during the high water period which varies year to year, though typically occurs between November and May. This period is 

usually characterized by the highest levels of use observed at Cedar Creek Falls. Trash monitoring will use trash monitoring 

forms modified from the Rapid Trash Assessment Worksheet to fit the needs of the project area. Other periodic monitoring may be 

conducted by the Forest Service, San Diego River Park Foundation, or volunteers. If monitoring finds that the presence of trash is 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

18 

2. Wetland and riparian health: A negative annual trend within the visitor use permit area according 

to the California Rapid Assessment Method (CRAM), based on 2012 conditions.7 Additionally, any 

substantial increases in sedimentation to the stream channel would be evaluated on an as-needed 

basis by the Forest Hydrologist in accordance with the Forest Service Best Management Practices 

Form R30.8

3. Erosion: An increasing trend in the area impacted by user-created trails within the visitor use permit 

area, based on a 2012 baseline and twice-yearly monitoring.9

Table 4. Metrics that govern the increases and/or decreases in the number of visitor use permits issued 

Metric Frequency of Monitoring Resource Value(s) Addressed 

Litter Weekly during high water 

period (typically November 

through May). Monthly 

outside of this period. 

Water quality, scenery, human health 

Wetland and Riparian Health Annually Water quality, wildlife habitat, threatened 

and endangered species, vegetation, soils 

Erosion Bi-annually Soils, water quality, wildlife habitat, 

scenery, vegetation 

The above metrics include a trigger point or threshold at which point natural resource conditions have 

exceeded acceptable conditions. If at any point any of these metrics were exceeded, the number of visitor 

use permits issued would be decreased by 20% on a quarterly basis in the first year of project 

implementation. Adjustments to the number of visitor use permits issued in subsequent years would occur 

on a bi-annual (every six months) or annual basis as resource conditions warrant. Use would continue to be 

decreased until no metric was exceeded, and therefore conditions in the project area were within the 

baseline condition. 

If no metric were exceeded for a period of 3 months in the first year of project implementation the number 

of visitor use permits issued would be increased by 10% (potential increases in the number of visitor use 

permits issued in subsequent years would occur on a bi-annual or annual basis as resource conditions 

warranted).10 The intent of building the potential to increase the number of visitor use permits offered on a 

 

in the Marginal Condition Class for a single week, education and enforcement activities will occur. The Rapid Trash Assessment 

Worksheet can be found on pages 40-42 of the SWAMP Final Technical Report, located at: 

http://www.swrcb.ca.gov/rwqcb2/water_issues/programs/SWAMP/swampthrashreport.pdf. 

7

 California Rapid Assessment Method (CRAM) is a standardized protocol for assessing the health of wetlands and riparian 

habitats (Collins et al, 2008). CRAM is applicable to all wetland types and is designed for assessing ambient conditions within 

watersheds throughout the state of California. The CRAM Methodology has been adopted by the State and Regional Water 

Quality Control boards for consistency across water agencies and regions. Two sites will be identified in the visitor use permit 

area and the CRAM assessment will be conducted at each site once per year during the CRAM assessment window between 

February and April. CRAM assessments will be conducted by Cleveland National Forest Watershed Staff with assistance from 

the San Diego River Park Foundation or other volunteers. The CRAM form for riverine systems can be found at 

http://www.cramwetlands.org/documents/2008-09-30_CRAM_5.0.2_Field_Book_Riverine_FormOnly.pdf. 

8

 As it pertains to sedimentation, Forest Service Best Management Practices Form R30 documents whether there is little or no 

evidence of sediment movement, sediment movement evident but has not reached the stream channel, or evidence of sediment 

reaching the stream channel. 

9

 The area impacted by user-created trails will be measured using the ratio of mileage of user-created trails to system trails in the 

visitor use permit area. 

10 Metrics that are monitored on a bi-annual or annual basis contain several three-month periods. In the first year of project 

implementation these metrics will not prevent a quarterly increase in the number of visitor use permits issued if all other proposed 

metrics are within the bounds of the baseline condition during periods when the longer-term metrics are not scheduled for 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

19 

daily basis into the visitor use permit system is to balance the natural resource concerns outlined in Sections 

1.3 and 1.4 of this document with the mandate in the Cleveland National Forest Land Management Plan to 

meet the needs of growing, urban, and diverse population (Part 2, pgs. 24-25) and to provide safe public 

access to popular recreation destinations in the CCF area (Part 2, pg. 67). The possibility of increasing the 

number of visitor use permits issued on a daily basis by 10% if no metric is exceeded for 3 months ensures 

that the Forest Service takes a more conservative approach to increasing than to decreasing the number of 

visitor use permits issued. 

In addition to the possibility of increasing the number of visitor use permits issued each quarter, the Forest 

Service reserves the right under this alternative to suspend the requirement that visitors obtain a visitor use 

permit to visit CCF on days where use is projected to be low, defined as days when not all available visitor 

use permits are reserved. Reservation trends over time will suggest when use is likely to be low in the 

future, though it is likely that these days will occur outside of the summer season as well as outside of 

weekends, holidays, and school breaks throughout the rest of the year. Further, the Forest Service will only 

reduce the number of visitor use permits available when one or more triggers are exceeded by permitted 

visitors in the visitor use permit area. Finally, in order to ensure a balance between continued public access 

to CCF and resource concerns, the Forest Service would not reduce the number of visitor use permits to visit 

CCF below 30. 

Requiring a visitor use permit in a limited area around CCF as well as potentially lifting the visitor use 

permit requirement on low-use days would allow the Forest Service to address the natural resource concerns 

outlined above in Sections 1.3 and 1.4 of this document while allowing for continued public access to the 

San Diego River Gorge by hikers, hunters, equestrians, and mountain bikers, which would minimize the loss 

of recreation access to National Forest System lands. 

2.1.3 - Alternative 3 

Permanent Closure 

The permanent closure alternative designates a permanent closure area in the immediate vicinity of CCF to 

prohibit visitation to this site. The boundary of the permanent closure alternative is the same as the boundary 

of the proposed visitor use permit area, outlined in Alternative 2 and illustrated in Figure 2. A permanent 

closure would improve public health and safety, decrease the severity of resource impacts at CCF and along 

the SDRG Trail and Eagle Peak Road (Trail), and reduce impacts to the SDCE neighborhood, but would 

adversely impact recreational users seeking to visit CCF. 

This alternative would not affect trail users or hunters seeking to access areas outside of the immediate area 

surrounding CCF. 

2.1.4 - Changes Between the Draft EA and Final EA 

Adaptive Management System 

The adaptive management system metrics presented in the draft EA that were related to parking in SDCE 

and to helicopter rescues were dropped from the final EA. These metrics were dropped because the Forest 

Service does not have the authority to manage parking and congestion on County public roadways or to 

manage search and rescue operations (which are also the responsibility of the County). Because the Forest 

Service does not have the authority to undertake these actions it cannot tie its management of CCF to them. 

 

monitoring. Following the first year of project implementation adjustments to the number of visitor use permits issued will occur 

bi-annually or annually as resource conditions warrant. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

20 

It should be noted that the Forest Service assumes that by managing public use at CCF issues pertaining to 

past patterns of parking in SDCE and helicopter rescues at CCF will be reduced. 

Several clarifications to the adaptive management system were also made in the final EA. First, the final EA 

was clarified to note that the proposed adaptive management metrics apply only to the visitor use permit 

area. Second, the final EA was clarified to note that both increases and decreases in the number of visitor 

use permits offered will occur on a quarterly basis in the first year of project implementation; in no case will 

they occur more frequently. In subsequent years adjustments to the number of permits offered would be 

made on a bi-annually or annually as resource conditions warrant. Finally, the final EA was clarified to note 

that issues pertaining to public health and safety will be addressed by the proposed alcohol prohibition and 

cliff closure. The Forest Service also assumes that the management of public use at Cedar Creek Falls will 

improve public health and safety more broadly. Issues pertaining to resource impacts in the visitor use 

permit area will be addressed by the proposed adaptive management system. 

2.1.5 - Alternatives Considered and Dropped 

Eagle Peak Road Parking Improvements 

The proposed action shared with the public during the scoping period contained a proposal to improve 

parking opportunities at the Saddleback Trailhead. The proposed parking improvements included the 

development of an unpaved parking area at the junction of Eagle Peak and Cedar Creek Roads, as well as 

the construction of a trail from the Saddleback Trailhead to the San Diego River Park Foundation’s 

southernmost Eagle Peak Preserve property. 

Analysis of the environmental effects of the proposed parking improvements by the interdisciplinary team 

determined that the development of an additional parking area outside of the existing dirt pullout used for 

parking at the Saddleback Trailhead and the construction of a trail to the San Diego River Park Foundation’s 

Eagle Peak Preserve property would likely adversely impact critical habitat for the California Gnatcatcher. 

Potential archaeological issues related to the parking improvements as initially proposed also exist. 

 

The Cleveland National Forest is additionally in the midst of a project to designate a number of areas as 

recommended wilderness, which could result in changes to land use designations to the east of Eagle Peak 

Road in the vicinity of the project area. Given the potential for new land use designations in this area, 

parking and recreation access issues may need to be revisited again in the future. Thus, due to unforeseen 

environmental impacts and the possibility of changes to land use designations, it was deemed that proposed 

parking improvements at the Saddleback Trailhead should be deferred until a future date. The title of this 

project was modified to reflect this determination. 

It is recognized that deferring proposed parking improvements at the Saddleback Trailhead will result in the 

Cleveland National Forest being unable in the short term to solve ongoing emergency and administrative 

access concerns along Eagle Peak Road during busy periods at CCF as originally discussed in the proposal 

shared during the scoping period, which occur when parked vehicles restrict the right-of-way in narrow 

sections of the road. However, the proposed visitor use permit area described in Section 2.1.2 of the EA 

would allow the Forest Service to manage recreational use at CCF. The Forest Service therefore assumes 

that emergency and administrative access along Eagle Peak Road on many days would be improved due to 

managed visitation at CCF. Further, the Forest Service is working with the Sheriff’s Department and 

California Highway Patrol with respect to actions within their jurisdictional authorities to address concerns 

related to emergency and administrative access. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

21 

2.1.6 - Alternatives Considered but Eliminated from Detailed Study 

Construction of a New Trailhead on Ramona Oaks Road

Federal agencies are required by the National Environmental Policy Act (NEPA) to rigorously explore and 

objectively evaluate all reasonable alternatives, and briefly discuss the reasons for eliminating any 

alternatives that were not developed in detail (40 CFR 1502.4). 

Many ideas have been suggested and explored in arriving at the current alternatives considered in detail in 

the EA. Addressing each of these suggestions in detail would create an unmanageably large number of 

alternatives that would not be helpful to the decision maker or public. Also, some recommendations would 

not fully address or would conflict with the purpose and need of this project, may result in new 

environmental or social impacts, and/or would be infeasible to implement. 

The alternative to construct a trailhead at the end of Ramona Oaks Road would result in the construction of 

a new trailhead approximately 1⁄2 mile from the existing SDRG Trailhead. Under this alternative the existing 

trailhead would either remain open or be permanently closed and decommissioned. 

This alternative does not fully address the concerns outlined in Sections 1.3 and 1.4 of the EA, and further 

would create new impacts to a different segment of the community in SDCE as well as new resource 

impacts. Specifically, trailhead design at the end of Ramona Oaks Road would require a larger footprint of 

disturbance on the landscape as compared to that which currently exists from informal public use at this 

location; trailhead construction at this location would adversely impact critical habitat for the endangered 

California gnatcatcher; construction of a trail off the end of Ramona Oaks Road would require the trail 

crossing a deep ravine, resulting in a complex project with potentially significant impacts to soil, water, and 

watershed resources; trailhead construction at the end of Ramona Oaks Road be very costly and an unwise 

use of taxpayer dollars in light of the 2009 Forest Service investment in the SDRG Trailhead; the long-term 

maintenance of a second trailhead facility in close proximity to the existing SDRG Trailhead is infeasible 

given current, predicted, and historic Forest Service budgetary trends; and topography at Ramona Oaks 

Road would make it difficult or impossible to conceal trailhead facilities from adjacent residences. The 

Forest Service has also heard on several occasions that the residents on the north side of Ramona Oaks Road 

do not support the construction of a trailhead at the end of Ramona Oaks Road due to potential impacts from 

a trailhead in their neighborhood. 

2.1.7 - Comparison of Alternatives 

This comparison of alternatives provides a summary of the effects of implementing each alternative. 

Information in the table is focused on instances where different levels of effects or outputs can be 

distinguished quantitatively or qualitatively among alternatives. 

Table 5. Comparison of Alternatives 

Alternative 1

(No Action) 

Alternative 2

(Proposed Action) 

Alternative 3

 

Visitor use levels at 

CCF 

Unlimited use would be 

allowed at CCF. According to 

historic use patterns in this 

area, average use at CCF 

during the spring months may 

average 700-1,100 people on 

a typical busy day and up to 

2,400 people on busy days. 

Initially 75 visitor use permits of up 

to 5 individuals per visitor use 

permit, or a maximum of 375 

people, would be allowed to access 

CCF per day. However, based on 

historic use patterns, average daily 

use at CCF would likely be closer 

to 225. The number of visitor use 

permits issued could be adjusted 

upward or downward according to 

continued monitoring and a series 

of metrics (detailed in Section 

2.1.2.1 of this document) that 

All public access to and 

recreational use at CCF 

would be prohibited. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

22 

address the natural resource 

concerns outlined in Sections 1.3 

and 1.4 of this document. 

 

Access to trails 

and the San Diego 

River Gorge 

Access to all parts of the San 

Diego River Gorge, the 

SDRG Trail, and the Eagle 

Peak Road (Trail) would be 

unlimited. 

Access to the San Diego River 

Gorge, the SDRG Trail, and the 

Eagle Peak Road (Trail) would be 

unlimited. Access to CCF would be 

managed as described above. 

Access to the San Diego 

River Gorge, the SDRG 

Trail, and the Eagle Peak 

Road (Trail) would be 

unlimited. All access to 

CCF would be prohibited. 

 

Alcohol 

consumption 

Forest visitors could possess 

and consume alcohol at CCF, 

at the SDRG and Saddleback 

Trailheads, and along the 

SDRG Trail and Eagle Peak 

Road (Trail) unless a 

temporary closure prohibited 

alcohol possession and 

consumption. 

The consumption and possession 

of alcohol would be permanently 

prohibited in the visitor use permit 

area surrounding CCF, within a 3⁄4 

mile buffer of the SDRG Trail and 

Eagle Peak Road (Trail), and at the 

SDRG and Saddleback Trailheads. 

Forest visitors could 

possess and consume 

alcohol at the SDRG and 

Saddleback Trailheads, 

and along the SDRG Trail 

and Eagle Peak Road 

(Trail). All public access to 

CCF would be 

permanently prohibited. 

 

Access to cliff 

faces at CCF 

Forest visitors could climb on 

all the cliff faces surrounding 

CCF unless a temporary 

closure closed the cliff faces 

to public access. 

Visitors with a visitor use permit to 

visit CCF could visit CCF, but 

would be prohibited from climbing 

on the cliff faces surrounding CCF. 

All public access to CCF 

and the cliff faces 

surrounding CCF would be 

permanently prohibited. 

 

Rescues The County of San Diego 

maintains the responsibility 

for all search and rescue 

operations in the vicinity of 

CCF. The increasing pattern 

of search and rescue needs 

as observed in early 2011 

would likely continue. 

The County of San Diego maintains 

the responsibility for all search and 

rescue operations in the vicinity of 

CCF. The Forest Service assumes 

that rescue patterns at CCF would 

be reduced from levels observed in 

early 2011 due to management of 

use levels at CCF under the visitor 

use permit system. 

The County of San Diego 

maintains the responsibility 

for all search and rescue 

operations in the vicinity of 

CCF. Search and rescue 

needs at CCF would likely 

decrease because all 

public access to CCF 

would be permanently 

prohibited. 

 

Resource impacts The pattern of user-created 

trail proliferation and littering 

along the trails leading to 

CCF as observed in early 

2011 would likely continue. A 

potential also exists for 

impacts to water quality, 

riparian health, soil, plants, 

and wildlife, including 

sensitive and endangered 

species. 

Visitor use at CCF would be 

adjusted up or down such that no 

increasing trend in the area 

impacted by user-created trails 

existed, litter conditions were not 

rated as “marginal” or below for any 

three consecutive weeks according 

to the Rapid Trash Assessment 

Worksheet (see Section 2.1.2.1 of 

this document), and a negative 

trend for wetland and riparian 

health did not exist for any annual 

period according to the California 

Rapid Assessment Method 

(CRAM) (see Section 2.1.2.1 of this 

document). As such, any potential 

impacts to water quality, soils, 

scenery, wildlife, plants (including 

sensitive and endangered plant 

and animal species), and riparian 

health would be reduced compared 

to historic conditions. 

Patterns of user-created 

trail proliferation and 

littering, as well as 

potential impacts to water 

quality, riparian health, 

soil, plants, and wildlife 

would likely decrease 

dramatically because all 

public access to CCF 

would be permanently 

prohibited. 

 

Overflow parking 

impacts to San 

Diego Country 

Estates 

neighborhood 

The County of San Diego has 

jurisdiction of all County 

maintained public roadways. 

Patterns of overflow parking 

and issues associated with 

The County of San Diego has 

jurisdiction of all County maintained 

public roadways. The Forest 

Service assumes that patterns of 

overflow parking and issues 

The County of San Diego 

has jurisdiction of all 

County maintained public 

roadways. Patterns of 

overflow parking and 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

23 

parking as observed in early 

2011 would likely continue. 

associated with parking would be 

reduced from levels observed in 

early 2011 due to restrictions on 

use levels at CCF under the visitor 

use permit system. 

issues associated with 

parking would likely 

decrease dramatically 

because all public access 

to CCF would be 

permanently prohibited. 

3 - ENVIRONMENTAL CONSEQUENCES 

This chapter provides an overview of the physical, biological, and social environments of the project area 

and the potential changes to those environments that result from implementing each of the alternatives. 

Included in this analysis is an assessment of the cumulative effects of the alternatives on the physical, 

biological, and social environments. The cumulative effects on the physical, biological, and social 

environments are the same under the three alternatives. This chapter also presents the scientific and 

analytical basis for comparison of the three alternatives presented in chapter 2 of the EA. 

3.0.1 – Cumulative Effects Common to the Physical, Biological, and Social 

Environments 

This section evaluates the cumulative effects of the three alternatives to the physical, biological, and social 

environments. 

Cumulative effects on the physical, biological, and social environments are the same under all alternatives. 

The cumulative effects are summarized directly below, followed by a discussion of the direct and indirect 

effects of each alternative on each of the physical, biological, and social environments. 

Cumulative impacts are those impacts resulting from the incremental impact of an action when added to 

other past, present, or reasonably foreseeable actions. 

The cumulative effects analysis area for this project is approximately 4,000 acres in size and includes an 

approximate 2 mile by 3 mile area of land between the San Diego Country Estates east to Saddleback and 

Eagle Peak Road. This area encompasses activities associated with the SDRG Trail, Eagle Peak Road 

(Trail), CCF, and other activities within the general area. This area also includes the current temporary 

Forest area closure of a 0.75 mile buffer along the SDRG Trail (Forest Order No. 2-12-04). Land ownership 

within the cumulative effects area is comprised of Forest Service, and private (San Diego Country Estate) 

lands. This area is characterized by open, rugged and relatively undisturbed land that is bordered to the 

north and west by the communities of San Diego Country Estates and Barona Mesa. 

The principal historic action within this area has been non-motorized recreation and limited activities 

associated with the Helix Water District facilities downstream (the Helix property in the San Diego River 

Gorge was acquired by the Forest Service in July, 2012, so is now comprised entirely of National Forest 

System lands). Due to its rugged landscape and limited access, human activities are still relatively limited 

and confined to a small area within the San Diego River Gorge. Current activities within the cumulative 

effects analysis area include fuels management activities along the periphery of SDCE, limited tribal land 

use, and recreational activities at CCF. Potential future actions within the region include recreational use 

and management in the vicinity of CCF, and habitat restoration efforts within the San Diego River 

Watershed. 

The primary Forest Service management emphasis for this area is maintaining a natural, undeveloped 

landscape for dispersed recreation, preserving and restoring sensitive natural resource values, and improving 

recreation management of the CCF area. Primary use occurs along existing roadways and trails with little 

activity outside of the road and trail corridors. Proposed future Forest Service management activities within 

the cumulative effects area include continued fuels management along the wildland-urban interface, 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

24 

increased recreation management of the CCF area, management of feral pigs, the preservation and 

restoration of riparian and coastal sage scrub habitat within the area, and possible designation of some lands 

adjacent to the project area as recommended wilderness. 

Management of feral pigs may include limited and occasional area closures to hunting during active 

trapping activities, which is currently under NEPA consideration, or result in the eradication of feral pigs in 

the San Diego River Gorge. Temporary closures to hunting or decreased feral pig populations may result in 

a slight hunting-related reduction in visitation to the San Diego River Gorge and area surrounding CCF. A 

slight reduction in hunting-related visitation to the project area would likely have beneficial effects to 

natural and social resources in this area. 

In 2012 the Forest Service also acquired lands that are adjacent to CCF, which are known as the Helix 

property. The addition of the Helix property to the National Forest System could increase the number of 

visitors to this area, but would disperse them over a larger area. Future recreation management in this area 

that is beyond the scope of this project would be designed to address issues pertaining to natural and social 

resources, and would therefore have beneficial or neutral effects on these resources. Preservation and 

restoration of riparian and coastal sage scrub habitat in the project area would have beneficial effects on 

natural and social resources. Fuels management projects are designed through the NEPA process to have 

neutral effects on natural and social resources, and may in fact benefit these resources due to the reduction 

in severity of potential future wildfires. 

If the Cleveland National Forest recommended wilderness designation and one or more wilderness areas 

were ultimately designated in the vicinity of CCF it is possible that the Saddleback Trailhead would become 

a focal point for access to these areas. Effects on natural and social resources in the project area that resulted 

from potential wilderness recommendation or designation would likely be neutral overall. However, beyond 

the project area wilderness designation could provide new wilderness recreation opportunities and may limit 

others, specifically those that depend on motorized use on Cedar Creek Road in the event that this road were 

ever to be closed. The potential for recommended wilderness would likely have little or no effect on 

residents of SDCE. 

3.1 - Physical Environment _________________________ 

This section evaluates impacts of the three alternatives to soils and water. 

3.1.1 - Soils 

Soils mapped within the project area are generally derived from young fluvial deposits or granitic bedrock. 

Soils on low gradient slopes are Anderson or Ramona gravelly to very gravelly sandy loams. These soils 

have high rock content and are results of fluvial deposits from the San Diego River and/or Cedar Creek at 

some time in the past. Soils adjacent to the streams and in active channel areas are mapped Riverwash. 

These soils are young and have not had sufficient time to develop distinguishing morphological 

characteristics. 

Direct and Indirect Effects of Alternative 1: No Action 

The no action alternative would maintain the conditions within the project area as described in Section 1.3 

of the EA. These conditions were not sufficient to protect soil resources. Visitor use was exceptionally 

heavy. On weekend days, visitor numbers were at times in the thousands and concentrated in a small area. 

Users created numerous trail shortcuts. By choosing the no action alternative, the soil resources of the 

Cleveland National Forest would not be protected and the relevant laws and agency guidance regarding soil 

resources would not be sufficiently addressed. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

25 

Direct and Indirect Effects of Alternative 2: Proposed Action 

The proposed action would be superior for protecting soil resources because it would manage recreation and 

therefore reduce pressure on soils observed in the past. The proposed action also includes educational 

materials to discourage littering, improper disposal of human waste, and trampling riparian vegetation and 

streams. The proposed action would enact measures to prevent sedimentation in riparian areas and stream 

channels in the visitor use permit area. Overall the proposed action is better at protecting soil resources and 

following legal and agency guidance, direction, and regulation. 

The adaptive management process defines a baseline condition for the visitor use permit area. As it relates 

to soil resources, this baseline condition is defined as a stable or negative trend in the area impacted by user 

created trails in the visitor use permit area, which can result in erosion. If this or other metrics related to 

environmental conditions were exceeded, the number of visitor use permits issued would be decreased in 20 

percent increments until the overall baseline condition is achieved. If no metric were exceeded for a period 

of 3 months, the number of visitor use permits issued daily would be increased by 10 percent in order to 

provide for continued recreation demands in this area, so long as they remain within the bounds of the 

baseline condition. The metrics that define the overall baseline condition are defined in more depth in 

Section 2.1.2.1 of the EA. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

The permanent closure alternative would prohibit visitation to CCF. The permanent closure alternative 

would be beneficial for the protection of soil resources because it would vastly decrease recreation pressures 

observed in the past. The permanent closure alternative would reduce sedimentation into riparian areas and 

stream channels. Overall, the permanent closure alternative is superior in its protection of soil resources 

according to legal and agency guidance, direction, and regulation. 

3.1.2 - Water 

The project area is located within two 6th level Hydrologic Unit Code (HUC) watersheds: 16,300 acre 

Cedar Creek watershed (HUC = 180703040501) and to the north the 26,200 acre Ritchie Creek-San Diego 

River watershed (HUC = 180703040502). The watershed designations used by the Forest Service come 

from the National Hydrologic Database maintained by the United States Geologic Survey. The State of 

California and Regional Water Quality Control Boards use different watershed scales and boundaries. 

The project area includes Cedar Creek and the scenic/recreation resource CCF. Adjacent and downstream 

from CCF and the proposed visitor use permit area is the San Diego River and associated floodplains 

designated by the State Department of Water Resources. This area contains important headwater and 

riparian habitat. 

Direct and Indirect Effects of Alternative 1: No Action 

The no action alternative would maintain the conditions within the project area as described in Section 1.3 

of the EA. Management under these conditions was not sufficient to protect water resources. Visitor use was 

exceptionally heavy. On weekend days, visitor numbers were at times in the thousands and concentrated in a 

small area. There were hundreds of hours of human water contact, trash and litter was prominent, and users 

created numerous trail shortcuts. By choosing the no action alternative, the water resources of the Cleveland 

National Forest would not be protected and the relevant laws and agency guidance regarding water 

resources would not be sufficiently addressed. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

The proposed action would be superior for protecting water resources because it would manage recreation 

pressures observed in the past. The proposed action also includes educational materials to discourage 

littering, improper disposal of human waste, and trampling riparian vegetation and stream conditions. The 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

26 

proposed action would lower the hours of water contact recreation and enact measures to prevent 

sedimentation into riparian areas and stream channels. Overall the proposed action is sufficient at protecting 

watershed resources and following legal and agency guidance, direction, and regulation. 

The adaptive management process defines a baseline condition for the visitor use permit area. As it relates 

to water resources, this baseline condition is defined by metrics pertaining to litter, wetland and riparian 

health, sedimentation, and erosion. Under this condition, litter conditions would not be classified as 

marginal for any period of three weeks or more according to a rapid trash assessment, California Rapid 

Assessment Method trends for wetland and riparian health would not exhibit a negative annual trend, 

substantial increases in stream channel sedimentation would not occur, and there would be no increasing 

trend in the area impacted by user-created trails in the visitor use permit area. If these metrics exceeded, the 

number of visitor use permits issued would be decreased in accordance with the adaptive management 

system until the overall baseline condition is achieved. If no metric were exceeded for a period of 3 months, 

the number of visitor use permits issued daily would be increased by 10 percent in order to provide for 

continued recreation demands in this area, so long as resource conditions remain acceptable. The metrics 

that define the overall baseline condition are defined in more depth in Section 2.1.2.1 of the EA. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

The permanent closure alternative would prohibit visitation to CCF. The permanent closure alternative 

would be beneficial for the protection of water resources because it would vastly decrease recreation 

pressure in this area as observed in the past. The permanent closure alternative would lower the hours of 

water contact recreation and reduce sedimentation in riparian areas and stream channels. Overall the 

permanent closure alternative is superior at protecting watershed resources and following legal and agency 

guidance, direction, and regulation. 

3.2 - Biological Environment _______________________ 

This section evaluates impacts of the three alternatives to Wildlife, Listed Species, and Vegetation. Effects 

of the proposed action to listed species (proposed, endangered, threatened, or sensitive) are described in 

detail in a biological evaluation included in the project record. 

3.2.1 - Wildlife 

Direct and Indirect Effects of Alternative 1: No Action 

Under the no action alternative it is reasonable to assume that visitor use to the CCF area will continue to 

increase beyond levels observed in early 2011. Impacts associated with this increased use of the area 

surrounding CCF will result in resource damage to both habitat and disturbance to wildlife species. 

Unmanaged recreation within this relatively small geographical area will eventually result in significant 

negative impacts to habitat, vegetation and water quality within this sensitive riparian area. Large 

unmanaged numbers of hikers will also negatively affect coastal sage scrub and California gnatcatcher 

habitat through the proliferation of user-created trails. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

No negative direct or indirect effects are expected to wildlife species or habitat from the implementation of 

the Cedar Creek Falls Visitor Use Permit System. This project is an administrative action and does not 

involve any physical action or disturbance to listed species, habitat, or other pertinent natural resources. 

Positive indirect effects from the proposed action include managing the number of people that visit the CCF 

area which is beneficial to wildlife species. Managing the number of people that visit the area will reduce 

direct human impacts and disturbance to species and their habitat, as well as associated impacts such as 

water quality issues, litter, noise, and habitat disturbance. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

27 

The adaptive management process defines a baseline condition for the visitor use permit area. As it relates 

to wildlife, this baseline condition is defined by metrics pertaining to wetland and riparian health, 

sedimentation, and erosion. Under this condition California Rapid Assessment Method trends for wetland 

and riparian health would not exhibit a negative annual trend, substantial increases in stream channel 

sedimentation would not occur, and there would be no increasing trend in the area impacted by user-created 

trails within the visitor use permit area. If these or other metrics related to environmental conditions were 

exceeded, the number of visitor use permits issued would be decreased in accordance with the adaptive 

management system until the overall baseline condition is achieved. If no metric were exceeded for a period 

of 3 months, the number of visitor use permits issued would be increased by 10 percent in order to provide 

for continued recreation demands in this area, so long as they remain within the bounds of the baseline 

condition. The metrics that define the overall baseline condition of the visitor use permit area are defined in 

more depth in Section 2.1.2.1 of the EA. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

No negative direct or indirect effects are expected to wildlife species from the implementation of 

Alternative 3. This alternative represents an administrative action and does not involve any physical action 

or disturbance to listed species, habitat, or other pertinent natural resources. 

The vast majority of visitors to the San Diego River Gorge seek to visit CCF, and so under Alternative 3, 

which would prohibit all access to CCF, use of this area would likely dramatically decrease. Positive direct 

effects that would stem from a reduction in the number of people that visit the San Diego River Gorge 

include benefits to wildlife species. Controlling the number of people that visit the area would reduce direct 

human impacts and disturbance to species and their habitat, as well as associated impacts such as water 

quality issues, litter, noise, and habitat disturbance. 

3.2.2 - Listed Species 

Listed species considered in this analysis are those which are state or federally threatened, endangered or 

candidate, or on the Regional Forester’s Sensitive Species List. Only those species that are known or have 

the potential to occur on the Cleveland National Forest or general vicinity of the project area are considered 

in this analysis, and only those species known or with the potential to occur within the project area are 

addressed in detail. Seventy-eight endangered, threatened, candidate, and sensitive plant and animal species 

are listed as occurring or potentially occurring on the Cleveland National Forest, including 26 animal and 52 

plant species. 

Information on listed species which have the potential to occur within the proposed project area were 

identified from field surveys, USDA Forest Service databases, files and reports, project wildlife reports, and 

the California Natural Diversity Data Base (CNDDB). Thirteen listed animal species are known or have the 

potential to occur within the proposed project area. Four are federally listed and 9 are listed as Forest 

Sensitive. Federally listed endangered and threatened species that are known to occur in the project area 

include Arroyo Southwestern Toad, California Gnatcatcher, Least Bell’s Vireo, and Southwestern Willow 

Flycatcher. A habitat suitability analysis was conducted for listed plant species utilizing Forest records and 

information collected during field site visits of the project area. There is no modeled habitat for any 

federally-listed plant species at the trailhead or along the trail alignment. One Forest Listed Sensitive plant 

species potentially occurs within the project area. No additional listed species were discovered, and there are 

no known records for the project area for any other listed plant species. Additional information regarding 

listed species can be found in the Biological Evaluation/Biological Assessment in the project record. 

Direct and Indirect Effects of Alternative 1: No Action 

Under the Alternative 1 it is reasonable to assume that visitor use to the CCF area will continue to increase 

beyond levels observed in early 2011. Impacts associated with this increased use of the area surrounding 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

28 

CCF will result in resource damage to both habitat and disturbance to wildlife species, including Arroyo 

Southwestern Toad, California Gnatcatcher, Least Bell’s Vireo, and Southwestern Willow Flycatcher. 

Unmanaged recreation within this relatively small geographical area will eventually result in significant 

negative impacts to habitat, vegetation and water quality within this sensitive riparian area. Large 

unmanaged numbers of hikers will also negatively affect coastal sage scrub and California Gnatcatcher 

habitat through the proliferation of user-created trails. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

No negative direct or indirect effects are expected to any federally listed or Forest Sensitive wildlife and 

plant species from the implementation of the Cedar Creek Falls Visitor Use Permit System. This project is 

an administrative action and does not involve any physical action or disturbance to listed species, habitat, or 

other pertinent natural resources. 

Positive indirect effects from the proposed action include managing the number of people that visit CCF, 

which is beneficial to listed wildlife species that are known to occur in the project area, including Arroyo 

Southwestern Toad, California Gnatcatcher, Least Bell’s Vireo, and Southwestern Willow Flycatcher. 

Controlling the number of people that visit CCF will reduce direct human impacts and disturbance to these 

listed species and their habitat, as well as associated impacts such as water quality issues, litter, noise, and 

habitat disturbance. 

The adaptive management process defines a baseline condition for the visitor use permit area. As it relates 

to listed species, this baseline condition is defined by metrics pertaining to wetland and riparian health, 

sedimentation, and erosion. Under this condition California Rapid Assessment Method trends for wetland 

and riparian health would not exhibit a negative annual trend, substantial increases in stream channel 

sedimentation would not occur, and there would be no increasing trend in the area impacted by user-created 

trails within the visitor use permit area. If these or other metrics related to environmental conditions were 

exceeded, the number of visitor use permits issued would be decreased in accordance with the adaptive 

management system until the overall baseline condition is achieved. If no metric were exceeded for a period 

of 3 months, the number of visitor use permits issued would be increased by 10 percent in order to provide 

for continued recreation demands in this area, so long as they remain within the bounds of the baseline 

condition. The metrics that define the overall baseline condition are defined in more depth in Section 2.1.2.1 

of the EA. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

No negative direct or indirect effects are expected to any federally listed or Forest Sensitive wildlife and 

plant species from the implementation of Alternative 3. This alternative represents an administrative action 

and does not involve any physical action or disturbance to listed species, habitat, or other pertinent natural 

resources. 

Positive indirect effects from Alternative 3 include managing the number of people that visit CCF, which 

would be beneficial to listed wildlife and plant species. Managing the number of people that visit CCF 

would reduce direct human impacts and disturbance to listed species and their habitat, as well as associated 

impacts such as water quality issues, litter, noise, and habitat disturbance. 

3.2.3 - Vegetation 

Direct and Indirect Effects of Alternative 1: No Action 

Under the Alternative 1 it is reasonable to assume that visitor use to CCF will continue to increase beyond 

levels observed in early 2011. Impacts associated with this increased use of CCF will result in resource 

damage to both vegetation and habitat. Unmanaged recreation within this relatively small geographical area 

will eventually result in significant negative impacts to habitat, vegetation and water quality within this 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

29 

sensitive riparian area. Large unmanaged numbers of hikers will also negatively affect coastal sage scrub 

and California Gnatcatcher habitat through the proliferation of user-created trails. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

No negative direct or indirect effects are expected to any plant species from the implementation of the 

Cedar Creek Falls Visitor Use Permit System. This project is an administrative action and does not involve 

any physical action or disturbance to vegetation, habitat, or other pertinent natural resources. 

Positive indirect effects from the proposed action include managing the number of people that visit the CCF 

area, which is beneficial to plant species. Managing the number of people that visit CCF will reduce direct 

human impacts and disturbance to plant species and their habitat, as well as associated impacts such as 

water quality issues, litter, noise, and habitat disturbance. 

The adaptive management process defines a baseline condition for the visitor use permit area. As it relates 

to vegetation, this baseline condition is defined by metrics pertaining to wetland and riparian health, 

sedimentation, and erosion. Under this condition California Rapid Assessment Method trends for wetland 

and riparian health would not exhibit a negative annual trend, substantial increases in stream channel 

sedimentation would not occur, and there would be no increasing trend in the area impacted by user-created 

trails. If these or other metrics related to environmental conditions were exceeded, the number of visitor use 

permits issued would be decreased in accordance with the adaptive management system until the overall 

baseline condition is achieved. If no metric were exceeded for a period of 3 months, the number of visitor 

use permits issued would be increased by 10 percent in order to provide for continued recreation demands in 

this area, so long as they remain within the bounds of the baseline condition. The metrics that define the 

overall baseline condition are defined in more depth in Section 2.1.2.1 of the EA. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

No negative direct or indirect effects are expected to any plant species from the implementation of 

Alternative 3. This alternative represents an administrative action and does not involve any physical action 

or disturbance to vegetation, habitat, or other pertinent natural resources. 

Positive indirect effects from the proposed action include managing the number of people that visit CCF, 

which is beneficial to plant species. Managing the number of people that visit the area will reduce direct 

human impacts and disturbance to plant species and their habitat, as well as associated impacts such as 

water quality issues, litter, noise, and habitat disturbance. 

3.3 - Social Environment___________________________ 

This section evaluates impacts of the three alternatives to public health and safety, scenery management and 

recreation, heritage resources and tribal relations, and environmental justice. 

3.3.1 - Public Health and Safety 

Each year hikers who are unprepared for hot weather and the steep terrain in the area surrounding CCF are 

rescued by helicopter. A number of rescues were historically conducted each year, although in recent years 

an increased need for rescues has been reported by the County of San Diego. In 2010 the Sheriff’s 

Department conducted 31 helicopter rescues in this area, and between January 1, 2011 and July 9, 2011 the 

conducted an additional 31 helicopter rescues. 

CCF has become known as a party spot where visitors congregate, consume alcohol, and jump from the 

cliffs into the pool below the waterfall. Crowds frequently form to watch and cheer for the cliff jumpers. 

Since 1998 three individuals have died while jumping from the cliffs into the pool below CCF and others 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

30 

have suffered severe injury, including permanent paralysis. In 2012 a visitor died from heat stroke on Eagle 

Peak Road (Trail). 

Direct and Indirect Effects of Alternative 1: No Action 

There would be a number of negative effects to the health and safety of recreationists at and around CCF 

under the no action alternative. Namely, the increasing trend of dehydration and heat exhaustion incidents 

on the trail to CCF, as well as the continued potential for injuries and fatalities at CCF, would likely 

continue. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

Designating a visitor use permit area in the immediate vicinity of CCF has potential positive impacts to 

public health and safety. Historically, the vast majority of visitors to the San Diego River Gorge have sought 

to access CCF. The Forest Service assumes that a reduction in visitation to CCF may also result in the need 

for fewer helicopter rescues and could additionally shift the atmosphere at CCF from a “party spot” to a 

remote backcountry location. This potential shift in atmosphere has the potential to result in fewer visitors 

jumping from cliffs and consuming alcohol at CCF, which equates to a lower risk of injury or death as well 

as fewer instances of dehydration and heat exhaustion. 

Implementing a permanent alcohol prohibition at CCF, along the SDRG Trail and Eagle Peak Road (Trail), 

and at the SDRG and Saddleback Trailheads, and implementing permanent cliff closures would have a 

positive impact on public health and safety at CCF and along the SDRG Trail and Eagle Peak Road (Trail). 

These measures would encourage a shift in the atmosphere at CCF from a “party spot” to a remote 

backcountry location. Because recreationists would be prohibited from climbing on the cliff faces 

surrounding CCF and hence jumping into the pool below CCF, visitors would face a dramatically reduced 

likelihood than in the past of suffering severe injury or death in the vicinity of CCF. The permanent alcohol 

prohibition would also likely result in fewer instances of dehydration than have been observed in the past. 

Together these measures would likely contribute to a reduced need for search and rescue operations at and 

around CCF. 

No construction is planned for this project outside of installing signage in the vicinity of the project area. 

Installation of signage presents a potential for minor short-term safety risks to workers. In accordance with 

Forest Service Health and Safety Code Handbook (FSH 6709.4), working with tools requires all Forest 

Service employees to use proper personal protective equipment (PPE). Monitoring for compliance with the 

Forest Service safety code would be accomplished through on-site inspections and reviews of accident 

reports. Potential short term-safety risks associated with signage installation are countered by long-term 

health and safety benefits to the recreating public. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

Permanently closing the area in the immediate vicinity of CCF has positive impacts to public health and 

safety. Historically, the vast majority of visitors to the San Diego River Gorge have sought to access CCF. 

As such, prohibiting visitation to CCF would also likely result in the need for search and rescue operations, 

and eliminate the risks associated with visitors jumping from cliffs and consuming alcohol at CCF. 

3.3.2 - Scenery and Recreation 

CCF is located in a canyon bordered by steep walls, which opens into a flat valley where Cedar Creek flows 

into the San Diego River. The Saddleback Trailhead is characterized by a flat, graded area that recreationists 

use for parking. This flat area is adjacent to the junction of Eagle Peak and Cedar Creek Roads. The scenic 

integrity objective for the area encompassed by the proposed action is high. A scenic integrity objective of 

high means that the landscape appears unaltered. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

31 

Chaparral communities dominate the hillsides above CCF and along Eagle Peak Road, though Engelmann 

oaks can be found in patches along Eagle Peak Road. This area is very rural – few residences can be seen 

from Eagle Peak Road, which is traveled primarily by recreationists and residents. From the Saddleback 

Trailhead the scenery is dominated by National Forest System lands to the south, east, and west. Eagle Peak 

Preserve is located approximately two-tenths of a mile to the north, and still further north are additional 

private lands. 

Recreation in this area includes a number of traditional Forest Service offerings, including hiking, 

equestrian use, mountain biking, and swimming in the pool beneath CCF. Camping in the vicinity of the 

project area has historically been limited due to challenging terrain, and most existing campsites are illegal 

due to their proximity to streams and trails. The vast majority of recreation use in this area is day use and 

occurs at CCF. However, the San Diego River Gorge has become quite well known for pig hunting in recent 

years, and a small number of visitors use Eagle Peak and Cedar Creek Roads for motorcycle touring. It 

should be pointed out that only highway-legal motorcycles are allowed on Eagle Peak Road. The Cleveland 

National Forest also maintains a picnic area at the SDRG Trailhead. 

Direct and Indirect Effects of Alternative 1: No Action 

There would be no direct effects to recreation or visual quality under the no action alternative. According to 

the Cleveland National Forest Land Management Plan, the desired condition of “the Upper San Diego River 

Place is maintained as a remote, natural appearing landscape that functions as respite for the surrounding 

urban population” (67). Indirect effects of this alternative on recreation include impacts to the remote 

character of this landscape due to high levels of visitation and the “party” atmosphere at CCF, as well as the 

destruction of recreation infrastructure along the SDRG Trail by some recreationists. Indirect effects on 

scenery include the proliferation of user-created trails and littering at CCF and along the trails as a historic 

consequence of high levels of visitation. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

The designation of a visitor use permit area in the immediate vicinity of CCF according to the proposed 

action would negatively impact recreation opportunities in this area in that it would manage the number of 

people allowed to access CCF; visitors would no longer be able to spontaneously visit this popular 

recreation destination. However, aside from prohibiting access to the cliff faces surrounding CCF and 

therefore jumping from the cliffs into the pool below CCF and rock climbing, the proposed action would 

have no effect on the breadth of recreation opportunities available in the San Diego River Gorge. The loss of 

the opportunity to cliff jump, which is not a traditional Forest Service recreational activity, would be offset 

by associated improvements to public health and safety. It is noted that an established rock climbing route 

exists in this area and will be affected by the closure of the cliff faces. However, this route is not known to 

be one that is popular or even actively used. 

By managing the number of recreationists allowed to access CCF on a given day the proposed action would 

have an indirect positive impact on the quality of the recreation experience in the visitor use permit area and 

on the trails leading to CCF. This indirect benefit would result from better alignment with the Cleveland 

National Forest Land Management Plan, which classifies this area as a “remote, natural appearing landscape 

that functions as respite for the surrounding urban population” (USDA, 2005: 67). 

Because management of the number of people allowed to access CCF under the proposed action is balanced 

by an increase in the quality of the recreation experience, and because the visitor use permit area would be 

limited in size and additionally there are many other dispersed recreation settings on the forest, the impacts 

of the proposed action to overall recreation opportunities on the Palomar Ranger District would be minimal. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

32 

The Forest Service assumes that designating a visitor use permit area would result in a positive effect on 

scenery across the broader landscape by reducing overall recreation demand and the associated impacts 

stemming from the proliferation of user-created trails and littering. 

The adaptive management process defines a baseline condition for the CCF area. As it relates to recreation 

and scenery, this baseline condition is defined by metrics pertaining to litter and erosion. Under the baseline 

condition, litter conditions would not be classified as marginal for any period of three weeks or more 

according to a rapid trash assessment and no increasing trend in the area impacted by user-created trails 

would exist. If these or other metrics related to environmental conditions were exceeded, the number of 

visitor use permits issued would be decreased in accordance with the adaptive management system until the 

overall baseline condition is achieved. If no metric were exceeded for a period of 3 months, the number of 

visitor use permits issued would be increased by 10 percent in order to provide for continued recreation 

demands in this area, so long as they remain within the bounds of the baseline condition. The metrics that 

define the overall baseline condition are defined in more depth in Section 2.1.2 of this document. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

Implementing a permanent closure in the vicinity of CCF would have a direct, negative effect on recreation 

in the San Diego River Gorge. This would likely occur because the majority of visitors to this area seek to 

visit CCF, and many of these visitors swim in the pool below CCF. A permanent closure in the vicinity of 

CCF would therefore reduce the scope of recreation opportunities on this part of the forest and would 

further force a potentially substantial number of recreationists to find recreation opportunities elsewhere. 

Although a permanent closure in the vicinity of CCF is associated with direct, negative effects, this 

alternatively may also result in several indirect benefits to recreation opportunities in the San Diego River 

Gorge. In particular, this alternative would not affect trail users or hunters that do not seek to visit CCF, 

which means that recreation experiences in this broader area would be characterized by a greater degree of 

solitude and may therefore be of higher quality to many visitors. 

Implementing a permanent closure may have a positive effect on scenery by reducing the overall demand on 

the landscape and the associated impacts stemming from the proliferation of user-created trails and littering. 

3.3.3 – Heritage and Tribal Relations 

Direct and Indirect Effects of Alternative 1: No Action 

There would be no direct, indirect, or cumulative effects to heritage resources under the no action alternative 

because this alternative does not include ground disturbing activities, nor are there ongoing impacts under 

the existing condition to known heritage sites within the project area. 

The Barona Band of Mission Indians and Viejas Band of Kumeyaay Indians have expressed concerns to the 

Cleveland National Forest that recreational use at CCF increases the likelihood of trespass onto the Capitan 

Grande Indian Reservation. Under the no action alternative it is likely that unmanaged recreational use as 

observed prior to the July 9, 2011 temporary closure of CCF and the surrounding area (Forest Order Nos. 

02-11-05 and 02-11-09) would begin to occur again at CCF. Tribal relations may be strained under this 

alternative because it does not address the trespass concerns expressed by the Barona Band of Mission 

Indians and Viejas Band of Kumeyaay Indians. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

The establishment of the visitor use permit system itself will not result in any new ground disturbing 

activities or increased impacts to the visitor use permit area that would have the potential to have effects on 

historic properties, and would actually reduce potential impacts by managing the number of visitors to the 

area. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

33 

The installation of signage using t-posts is exempt from heritage review based on the Cleveland National 

Forest Heritage Resources Management Program Programmatic Agreement Compliance Form. If needed, 

the potential installation of signage using other materials will proceed after receiving a heritage exemption. 

Under the proposed action recreational use at CCF would be managed via the proposed visitor use permit 

system. The Forest Service therefore assumes that fewer instances of trespass onto the Capitan Grande 

Indian Reservation would occur than may have occurred in the past, prior to the July 9, 2011 temporary 

closure of CCF (Forest Order Nos. 02-11-05 and 02-11-09). 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

There would be no direct, indirect, or cumulative effects to heritage resources under the permanent closure 

alternative because this alternative does not include ground disturbing activities, nor are there ongoing 

impacts under the existing condition to known heritage sites within the project area.

Under the permanent closure alternative visitation to CCF would be prohibited, which would drastically 

limit visitation to the San Diego River Gorge as compared to historic levels. It is therefore likely that that 

fewer instances of trespass onto the Capitan Grande Indian would occur than may have occurred in the past, 

prior to the temporary closure of CCF (Forest Order Nos. 02-11-05 and 02-11-09). 

3.3.4 – Adjacent Private Property (SDCE) 

Potential impacts to private properties that are adjacent to the project area in SDCE are primarily a result of 

high levels of public visitation at CCF and in the San Diego River Gorge. These impacts include traffic 

congestion (see Section 3.3.1 of the EA), parking on County-maintained public roads in SDCE, trespass on 

private property, and undesirable public behavior at and around the SDRG Trailhead. However, a number of 

public comments also stated that many members of the community adjacent to the SDRG Trailhead moved 

to SDCE due to its proximity and uninhibited access to the Cleveland National Forest. Therefore potential 

actions to address the impacts as described above may result in decreased access by members of the SDCE 

community consistent with use restrictions experienced by the public more broadly.

Direct and Indirect Effects of Alternative 1: No Action 

There would be a number of negative effects to adjacent property owners in SDCE under the no action 

alternative. Resident complaints of parking and traffic congestion on County-maintained public roads, 

private property trespass, and undesirable public behavior at and around the SDRG Trailhead by 

recreationists visiting CCF would continue. There is a high likelihood that visitation levels at CCF as 

observed in early 2011 (see Section 1.3 of the EA) would occur again. As would be the case for the general 

public, residents of SDCE living adjacent to the SDRG Trailhead would continue to have uninhibited access 

to CCF and the local trail system. 

Direct and Indirect Effects of Alternative 2: Proposed Action 

Designating a visitor use permit area in the immediate vicinity of CCF has potential positive impacts to 

private property adjacent to the SDRG Trailhead in SDCE. Historically, the vast majority of visitors to the 

San Diego River Gorge have sought to access CCF. As such, the Forest Service assumes that by managing 

the numbers of visitors to CCF via a visitor use permit system that issues pertaining to parking and 

congestion on public roadways, private property trespass, and undesirable public behavior at the SDRG 

Trailhead would likely be reduced. However, management of visitation at CCF would also apply to 

residents in SDCE, many of whom previously enjoyed uninhibited access to this area. The designation of a 

visitor use permit area in the vicinity of CCF would therefore require preplanning and a reservation on the 

part of SDCE residents as would be the case with the general public. It should also be noted that potentially 

high demand for visitor use permits on weekend and holiday days may lead to some would-be visitors, 

including those in SDCE, being unable to obtain a visitor use permit to visit CCF. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

34 

Implementing a permanent alcohol prohibition at CCF, along SDRG Trail and Eagle Peak Road (Trail), and 

at the SDRG and Saddleback Trailheads; and implementing permanent cliff closures would also likely have 

a positive impact on private property adjacent to the SDRG Trailhead in SDCE. These measures would 

encourage a shift in the atmosphere at CCF from a “party spot” to a remote backcountry location. This shift 

in atmosphere would encourage recreational use that is more consistent with traditional recreation on 

National Forest System lands, such as hiking and viewing scenery, rather than issues observed at CCF, 

including alcohol consumption and partying. The Forest Service assumes that a recreational visitor clientele 

that is similar to that traditionally observed on National Forest System lands would be less likely on average 

to trespass on private property and engage in undesirable public behaviors adjacent to private property. 

Direct and Indirect Effects of Alternative 3: Permanent Closure 

Permanently closing the area in the immediate vicinity of CCF would have positive impacts to private 

property adjacent to the SDRG Trailhead in SDCE. Historically, the vast majority of visitors to the San 

Diego River Gorge have sought to access CCF. As such, by prohibiting access to CCF it is likely that issues 

pertaining to parking and traffic congestion on public roadways, private property trespass, and undesirable 

public behavior in SDCE would be dramatically reduced. However, prohibiting visitation to CCF would 

apply to both the general public as well as residents of SDCE, many of whom previously enjoyed 

uninhibited access to CCF. 

3.3.5 - Environmental Justice (Executive Order 12898) 

Executive Order 12898 “Federal Actions to Address Environmental Justice in Minority Populations and 

Low-Income Populations” requires that federal agencies make achieving environmental justice part of their 

mission by identifying and addressing, as appropriate, disproportionately high and adverse human health 

and environmental effects of their programs, policies, and activities on minority and low-income 

populations. The USDA Departmental Regulation on Environmental Justice (USDA, 1997) determination 

procedure for environmental justice issues states, “An environmental justice issue arises where conduct or 

action [by a USDA agency] may involve a disproportionately high and adverse environmental or human 

health effect on an identifiable low-income or minority population” (2).11 As it pertains to this project, the 

Council on Environmental Quality (CEQ) “Environmental Justice Guidance Under the National 

Environmental Policy Act” states (8-9): 

Agencies should consider the composition of the affected area to determine whether minority 

populations, low-income populations, or Indian tribes are present in the area affected by the 

proposed action, and if so whether there may be disproportionately high and adverse human 

health or environmental effects on minority populations, low income populations, or Indian 

tribes. 

The proposed action and alternatives were assessed to determine whether they would disproportionately 

impact minority or low-income populations. Alternatives 1 and 3 would have equal effects on all members 

of the public including minority and low-income populations with the exception of members of the Barona 

Band of Mission Indians and Viejas Band of Kumeyaay Indians, who would be prohibited from visiting a 

portion of their ancestral territory under Alternative 3 if CCF were permanently closed to public access. 

 

11 Neither the USDA Departmental Regulation on Environmental Justice nor the CEQ Environmental Justice Guidance defines 

“low-income population.” As such, this project uses a Colorado Department of Transportation (CDOT) Technical Memorandum 

(CH2M Hill, 2004) definition of “low-income population.” The technical memorandum defines a “low-income population” as a 

population in which 30% or more of households are defined as “low-income” based on US Census tracts or Housing and Urban 

Development data. Because the CDOT project for which the technical memorandum was prepared leveraged federal funding, the 

technical memorandum defined “low-income population” in order to ensure compliance with Executive Order 12898. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

35 

The proposed action would have no effect on the civil rights of any individual. Women, Native Americans, 

and other minority groups would not be impacted by the proposed action any differently than any other 

public group.12 

According to 2010 census data and maps included in the project record, poverty rates in communities 

surrounding the project area range from 0 to 20%. Across San Diego County more broadly, the nearest 

census tracts to the project area in which poverty rates exceed 30% and are therefore defined as “lowincome populations” are located in Lakeside, CA; El Cajon, CA; and Escondido, CA. These census tracts 

are no closer than 20 miles from any access point to the project area. Therefore, there are no adverse effects 

of the proposed action on low-income communities since none are located in the area affected by or 

adjacent to the project area. 

Executive Order 12898 does not mandate that agencies consider the effects of their projects on low-income 

households unless these households exist within low-income populations. Nonetheless, the $6 NRRS 

administrative cost associated with reserving a visitor use permit may deter individuals from low-income 

households from visiting CCF. However, the overall impact of this administrative fee on recreationists more 

broadly would be very minor due to the large number of popular, high quality, and free recreational 

opportunities throughout San Diego County. Many of these recreational opportunities include water 

features, including waterfalls in numerous locations.

4 - GROUPS, ORGANIZATIONS, AND AGENCIES 

CONSULTED 

The Forest Service consulted the following Tribes; Federal, State, and local agencies; and organizations 

during the development of this EA: 

ID TEAM MEMBERS: 

Criley, Lance Environmental Coordinator 

Fredrickson, Bjorn IDT Leader, EA Editor, and Recreation Specialist 

Friedlander, Joan Unit Line Officer 

Harvey, Steve Forest Archaeologist 

Heys, Jeffrey Environmental Coordinator 

Jimenez, Jason Watershed Specialist 

Metz, William Deciding Official 

Staudenmayer, Liz GIS Specialist 

Wells, Jeff Wildlife Biologist 

Winter, Kirsten Forest Biologist

TRIBES: 

Alvarez, Sheilla Barona Band of Mission Indians 

Butz, Don Viejas Band of Kumeyaay Indians 

Romero, Edwin Chairman, Barona Band of Mission Indians 

FEDERAL, STATE, AND LOCAL AGENCIES: 

Bavencoff, Christina San Diego Sheriff’s Department 

 

12 If unanticipated effects of the proposed action on a minority or low-income population affected by the proposed action were to 

arise, the Forest Service would consider making an exception to the requirement that the affected group obtain a visitor use permit 

to visit CCF. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

36 

Collins, Jeff Office of County Supervisor Dianne Jacob 

Downs, Janice Office of County Supervisor Dianne Jacob 

Gibson, Eric County of San Diego Department of Planning and Land Use 

Harrison, Michael Office of Congressman Duncan Hunter 

Hickman, Carl County of San Diego Public Works Department 

Jacob, Dianne Supervisor, Second District, County of San Diego 

Nelson, Mike San Diego River Conservancy 

Pasumarthi, Murali County of San Diego Public Works Department 

Piva, Jim Ramona Community Planning Group 

Perkins, Emily San Diego Public Utilities Department 

Richardson, Todd San Diego Sheriff’s Department 

Sutton, Julie San Diego Sheriff’s Department 

ORGANIZATIONS: 

Allied Climbers of San Diego 

Backcountry Horsemen of California, San Diego 

Ramona Trails Association 

San Diego Country Estates Association 

San Diego River Park Foundation 

5 - REFERENCES 

Bavencoff, Christina. 2012. Sergeant. San Diego Sheriff’s Department. Pers. Comm. 

California Natural Resources Agency. 2007. “Frequently Asked Questions About CEQA.” 12 June 2012 

<http://ceres.ca.gov/ceqa/more/faq.html> 

CH2M Hill. 2004. “US 36 Definition of ‘Low-Income’ for Environmental Analysis." 6 pp. 

Collins, J.N. E.D. Stein, M. Sutula, R. Clark, A.E. Fetscher, L. Grenier, C. Grosso, and A. Wiskind. 2008. 

“California Rapid Assessment Method (CRAM) for Wetlands.” Version 5.0.2. 151 pp. 

Council on Environmental Quality. 1997. “Environmental Justice: Guidance Under the National 

Environmental Policy Act.” 40 pp. 

County of San Diego Department of Public Works. 2012. “Public Road Standards.” 66 pp. 

County of San Diego Land Use and Environment Group. 2011. “County of San Diego Guidelines for 

Determining Significance and Report Format and Content Requirements: Transportation and 

Traffic.” Second Modification. 51 pp. 

Executive Order No. 12898. 59 Federal Register 32 (February 16, 1994). 5 pp. 

Richardson, Todd. 2012. Lieutenant. San Diego Sheriff’s Department. Pers. Comm. 

San Diego County Traffic Advisory Committee. 2011. “Committee Report on Parking Prohibitions on 

Cathedral Way, Sugar Plum Way, Thornbush Road, Love Lane, Cherish Way and Bellbottom Way.” 

5 pp. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Surface Water Ambient Monitoring Program. 2007. “A Rapid Trash Assessment Method Applied to 

Waters of the San Francisco Bay Region: Trash Measurement in Streams.” Final Technical Report. 

55 pp. 

SWAMP. See Surface Water Ambient Monitoring Program. 

USDA. See U.S. Department of Agriculture. 

U.S. Department of Agriculture. Departmental Regulation No. 5600-002: Environmental Justice (December 

15, 1997). 34 pp. 

U.S. Department of Agriculture. Forest Service. 2005. Land Management Plan: Cleveland National Forest. 

San Diego, CA. 

---. 2009. National Visitor Use Monitoring Results. Cleveland National Forest. 

 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

38 

Appendix A: Tribal Consultation ____________________ 

Introduction

Forest Service Manual (FSM) section 1563.01b outlines the requirement that National Forests consult and 

coordinate with Tribes regarding National Forest System project planning and decision making. In 

accordance with Executive Order 13175, Consultation and Coordination with Indian Tribal Governments; 

Department Regulation 1340-007, Policies on America Indians and Alaska Natives; and Department 

Regulation 1350-001, Title 40 of the Code of Federal Regulations, parts 1500-1509 (40 CFR parts 1500-

1509) require Federal agencies to invite Tribes to participate in the scoping process for projects and 

activities that affect Tribes and require NEPA documentation. Section 1501.2 requires that: “The Federal 

agency consults early with appropriate State and local agencies and Indian Tribes and with interested 

persons and organizations.” The below documentation of consultation and response to comments received 

from Tribes during consultation comply with the requirement that the Forest Service consult with Indian 

Tribes early in the NEPA process, in accordance with 40 CFR 1501.2(d)(2). Responses to comments 

received from State and local agencies, interested persons, and interested organizations can be found in 

Appendix C. 

Response to Comments Received During Consultation 

1. The Barona Band of Mission Indians and Viejas Band of Kumeyaay Indians have indicated that they 

do not support the Forest Service lifting the temporary closure order (Forest Order Nos. 02-11-05 

and 02-11-09) first put into place in the area surrounding CCF in July, 2011. Of central concern 

regarding this area is that recreational access to CCF facilitates trespass onto the Capitan Grande 

Indian Reservation. 

Response: The Cleveland National Forest is unable to indefinitely extend the current Forest Closure Order 

surrounding CCF to address concerns associated with trespass onto the Capitan Grande Indian Reservation. 

First, this concern is outside the scope of the purpose and need of the project. Second, permanently closing 

this area would be in direct contradiction to the Cleveland National Land Management Plan (2005), which 

emphasizes the provision and improvement of dispersed recreation opportunities in the San Diego River 

Gorge and around CCF (Part 2, pg. 67). 

In an effort to reduce trespass into the Capitan Grande Reservation from the CCF area, the Cleveland 

National Forest has agreed to work in partnership with the Barona Band of Mission Indians and Viejas Band 

of Kumeyaay Indians to address this concern by analyzing the feasibility of several mitigation measures, 

including conducting cadastral survey of the shared Reservation and Forest boundary, and the installation of 

boundary markers and additional property ownership signage at the northern edge of the Capitan Grande 

Indian Reservation.

 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Appendix B: Cedar Creek Falls Visitor Use Permit Questions and 

Answers ________________________________________ 

Why is the Forest Service proposing to require visitors to obtain a visitor use permit to visit Cedar 

Creek Falls? 

The Forest Service is proposing to require a visitor use permit to visit Cedar Creek Falls to address a 

variety of environmental and social issues that have resulted from busy periods of visitation at this 

site in the past. See Section 1.4 of this document for additional information. 

Who needs to obtain a visitor use permit? 

Visitors to Cedar Creek Falls and its immediate vicinity need to obtain a visitor use permit. The 

visitor use permit area is depicted in Figure 2 on page 4 of this document. 

Hikers, bicyclists, and equestrians who would like to use the San Diego River Gorge Trail and/or 

Eagle Peak Road (Trail) would not be required to obtain a visitor use permit so long as they do not 

enter the visitor use permit area. 

Where can I obtain a visitor use permit?

Visitor use permits must be obtained from the National Recreation Reservation Service (NRRS). 

Visitor use permits can be reserved online at www.recreation.gov or by toll-free phone at 1-877-444-

6777. 

How much does a visitor use permit cost? How is the fee for the visitor use permit used? 

A visitor use permit costs $6. The fee for the visitor use permit is an administrative fee retained by 

NRRS for the administration of the visitor use permit reservation system. This administrative fee is 

not retained by the Forest Service. 

How many people can be included on a single visitor use permit? 

Up to five people can be included on a visitor use permit. Groups that include more than five people 

would need to obtain more than one visitor use permit. 

What if more than five people want to visit Cedar Creek Falls together? Can one person reserve more 

than one visitor use permit? 

A single visitor use permit allows up to five people visit Cedar Creek Falls. If a group of more than 

five wants to visit Cedar Creek Falls the group would be required to obtain more than one visitor use 

permit. A single person can reserve more than one visitor use permit in order to accommodate 

groups larger than five so long as additional visitor use permits are available. Visitor use permits will 

be available for reservation on a first-come, first-served basis. 

Do all members of a group of up to five visitors need to be listed on the visitor use permit? 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

40 

Yes. Each member of a group of up to five visitors must be listed on the visitor use permit. All 

members must also carry government-issued photo identification unless they are dependent minors 

under the age of 16 with their parents. 

What if I enter the visitor use permit area without obtaining a visitor use permit? 

Any person entering the visitor use permit area without obtaining a visitor use permit will be subject 

to a $75 fine and must leave the visitor use permit area. 

What if I am listed on a visitor use permit but do not carry my ID with me? 

Any visitor entering the visitor use permit area without government-issued identification, even if 

they are listed on a visitor use permit, will be subject to a $75 fine and must leave the visitor use 

permit area. 

What if I change my plans after reserving my visitor use permit? 

After reserving your visitor use permit you will be able to make changes to the members of your 

group until you print your visitor use permit. Making changes to your visitor use permit will allow 

you to change the people you include in your group. You will only be able to print your visitor use 

permit within two weeks of your planned visit. Two weeks prior to your visit to Cedar Creek Falls 

NRRS will send you a reminder email to print your visitor use permit. 

At this time you are not able to obtain a refund of your $6 reservation fee from NRRS or change the 

date of your reservation if you are unable to visit Cedar Creek Falls on the day of your reservation. 

In the future it is possible that NRRS may allow changes in the date for your reservation at no 

additional cost so long as visitor use permits are still available on the day of your desired visit. 

How many visitor use permits will be available each day? 

Initially 75 visitor use permits will be available each day. The number of visitor use permits 

available may be adjusted up or down in accordance with environmental monitoring as described in 

Section 2.1.2.1 of this document. In order to ensure a balance between continued public access to 

Cedar Creek Falls and environmental conditions the Forest Service will not decrease the number of 

visitor use permits issued below 30. There is no maximum cap on the number of visitor use permits 

that could be issued if environmental conditions remained consistent with the monitoring metrics 

outlined in Section 2.1.2.1 of this document. 

When will visitor use permits be available for reservation? 

Visitor use permits will be available for reservation upon the implementation of the Cedar Creek 

Falls Visitor Use Permit System. Following this initial implementation of the Visitor Use Permit 

System permits will be available for reservation for the upcoming calendar year on December 26 of 

each year. For example, reservations will open for 2014 beginning on December 26, 2013. So long

as visitor use permits are available, visitor use permits can be reserved at a minimum of 1 day prior 

to your visit. 

Is the visitor use permit a parking permit?
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

41 

No. The visitor use permit is not a parking permit. All visitors who enter the Cedar Creek Falls 

visitor use permit area must be listed on a visitor use permit. Visitors must also have their visitor use 

permit and government-issued photo identification on their person. Only dependent minors under the 

age of 16 who are present with their parents do not need to carry photo identification. 

How will the visitor use permit prevent forest visitors from parking on County public roadways?

The visitor use permit will not prevent forest visitors from parking on County public roadways 

because the Forest Service does not have the jurisdictional authority to manage parking or traffic on 

County roads. However, the Forest Service assumes that by managing the number of people allowed 

to visit Cedar Creek Falls on a given day, issues pertaining to parking and traffic congestion on 

County public roadways will be less severe than during periods of busy use at Cedar Creek Falls as 

observed in the past. 

Will the parking spaces at the San Diego River Gorge Trailhead be reserved for visitors to Cedar 

Creek Falls that have obtained a visitor use permit? 

No. The parking spaces at the San Diego River Gorge Trailhead will not be reserved for visitors to 

Cedar Creek Falls that have obtained a visitor use permit. This trailhead, including the parking area, 

is for the use of all forest visitors regardless of their destination. 

Does the visitor use permit allow me to consume alcohol and jump from the cliffs at Cedar Creek 

Falls? 

The visitor use permit does not allow visitors to consume alcohol or jump from the cliffs at Cedar 

Creek Falls. Instead, it grants access to the visitor use permit area surrounding CCF. The possession 

and consumption of alcohol remains prohibited in this area and the cliffs surrounding Cedar Creek 

Falls remain closed to public access (including climbing on and jumping from the rocks and cliffs 

surrounding CCF) as outlined in Section 2.1.2 and depicted in Figure 4 on page 6 of this document. 

 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

42 

Appendix C: Response to Comments Received During Scoping and 

Comment Period _________________________________ 

Introduction

The Forest Service has documented, analyzed, and responded to the public comments received during the 

scoping and comment periods for the Cedar Creek Falls Visitor Use Permit System EA. Appendix C 

summarizes the comments received during the scoping and comment periods and provides the agency’s 

response to those comments. These responses comply with 40 CFR 1503.4, Response to Comments, of the 

National Environmental Policy Act (NEPA) regulations. 

Comment Analysis and Response 

Public comments submitted regarding the Cedar Creek Falls Visitor Use Permit System were documented, 

compiled, categorized, and analyzed in order to capture all viewpoints and concerns submitted during the 

official scoping and comment periods. Information from meetings, letters, emails, and other sources are all 

included in this response to comments. The response to comments helps the USDA Forest Service clarify, 

adjust, or incorporate additional technical information into the EA. 

Analysts read all public responses and identified separate comments within them that relate to a particular 

concern, resource consideration, and/or requested management action. Analysts categorized each comment 

into a topic area that is specifically relevant to this project. After categorizing comments, responses were 

written to address the public input that was received. The interdisciplinary team provided any 

recommendations for improvement to the proposed action to the Palomar District Ranger for review, 

consideration, and action. In general, the agency responds in the following five basic ways to substantive 

public comments, as prescribed in 40 CFR 1503.4: 

1. Modifying alternatives. 

2. Developing and analyzing alternatives not initially given consideration. 

3. Supplementing, improving, or modifying the analysis documented in the EA. 

4. Making factual corrections. 

5. Explaining why the comments do not need further Forest Service response. 

This response document is organized based on the categorization of comments into themes, as described 

above. Therefore, the Response to Comment Appendix C does not directly match the organization of the EA 

and is instead more closely tied to the concerns that the public shared during the scoping period with the 

proposed action. Comments that may have fit into several categories were addressed only once. 

It is important to point out that the consideration of public comments is not a vote-counting process in which 

the project outcome is determined by the majority opinion. Relative depth of feeling and interest among the 

public can serve to provide a general context for decision-making. More importantly, it is the 

appropriateness, specificity, and factual accuracy of comment content that serves to provide the basis for 

modifications to planning documents and decisions. Further, because respondents are self-selected, they do 

not constitute a random or representative public sample. NEPA encourages all interested parties to submit 

comments as often as they wish regardless of age, citizenship, or eligibility to vote. Respondents may 

therefore include businesses, people from other countries, children, and people who submit multiple 

comments. Every substantive comment and suggestion has value, whether expressed by one respondent or 

many. All input is read and evaluated, and the analysis team attempts to capture all relevant public concerns 

in the analysis process. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Response to Comments 

Proposed Action 

1. Possession of alcohol in the area, including the SDRC Trailhead and Saddleback Trailhead 

leading to CCF, should be permanently prohibited. 

Response: Section 2.1.2 of the EA includes proposals to permanently prohibit the possession of alcohol at 

CCF, along the SDRG Trail and Eagle Peak Road (Trail), and at the SDRG and Saddleback Trailheads; 

permanently close the cliff faces surrounding CCF to entry to prohibit jumping into the pool below CCF; 

designate a visitor use permit area in the immediate vicinity of CCF; and provide a variety of educational 

materials to visitors. It is anticipated that together these approaches will address challenges observed in the 

past at CCF more effectively than any single approach. 

2. Jumping from and climbing the cliffs surrounding CCF should be prohibited. Violators should 

be cited or arrested. 

Response: See response to comment 1. Additionally, the Forest Service does not have the legal authority to 

prohibit members of the public from jumping from cliffs, but can close specific areas – such as the tops of 

cliff areas – to entry. 

3. The Cleveland National Forest should install a pipe fence around the top of the cliffs to prevent 

visitors from approaching too close to the cliff edges. 

Response: The proposed action shared during scoping and in the draft EA included the installation of 

fencing around the top of the cliffs above CCF. Upon further review, it has been determined that fencing in 

this location may discourage visitors from approaching too close to the cliff edges, though it would not 

prevent or prohibit them from doing so. In addition to the questionable effectiveness of this fencing, 

potential impacts to scenery and workplace hazards associated with its installation and maintenance have 

resulted in this aspect of the proposed action as originally shared being dropped. 

4. The visitor use permit system will not address all of the ongoing issues associated with CCF. 

Response: See response to comment 1. 

5. Educational efforts would be more effective in addressing the ongoing issues around CCF than 

a visitor use permit system. 

Response: See response to comment 1. 

6. Installing fencing on the cliff faces surrounding CCF may adversely impact the scenery at this 

site. 

Response: See response to comment 3. 

7. The proposed action does not consider the difference between “long term” and “short term” 

visitors and the resulting effects on parking capacity at trailhead facilities. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

44 

Response: It is recognized that use patterns at CCF vary from day to day and throughout the day. Cleveland 

National Forest Recreation staff observations over the years indicate that on most days there is fairly 

consistent turnover among visitors and that some visitors stay longer than others. However, neither parking 

capacity at trailhead facilities nor the distinction between “long term” and “short term” visitors have a role 

in determining the number of proposed visitor use permits that will be offered to the public each day, and so 

do not require further analysis. See Section 2.1.2.1 of the EA for information on the adaptive management 

process that will govern the number of visitor use permits that will be offered to the public each day. 

8. The proposed action does not outline enforcement and safety mitigations necessary to maintain 

the area surrounding CCF. 

Response: This comment is not clear in its definition of “maintain the area surrounding CCF.” Nonetheless, 

the proposed action outlines a number of “safety mitigations.” Additionally, based on past and current 

experience the Cleveland National Forest can successfully enforce the proposed regulations outlined in 

Section 2.1.2 of the EA based on its current law enforcement capabilities and consistent with all laws, 

regulations, and other legal requirements such as the Cleveland National Forest’s Land Management Plan. 

9. How will the Forest Service prevent people from jumping off the cliffs into the pool below 

CCF? 

Response: Members of the public will be deterred from jumping off the cliffs into the pool below CCF 

using a combination of a closure of the cliff areas surrounding CCF, educational outreach, and enforcement 

of the cliff closure. 

10. How will the Forest Service prevent the possession and consumption of alcohol? 

Response: The Forest Service is currently and will continue to address alcohol possession and use by 

members of the public through enforcement of an Alcohol Prohibition (Forest Order 02-12-05, 36 CFR 

261.58 [bb]). 

11. The Forest Service should not regulate dangerous natural features. The prohibition on alcohol 

possession will adequately address this challenge. Alternatively, the Forest Service could close 

the area that leads up to the highest cliffs adjacent to CCF. The smaller cliffs should not be 

closed to public access and the bolted rock climbing route in the vicinity of CCF should not be 

closed. 

Response: The Forest Service believes that all of the components of the proposed action together will allow 

it to most effectively manage the challenges outlined in Sections 1.3 and 1.4 of the EA at this time. 

12. The Forest Service should address issues pertaining to helicopter rescues with improved 

signage and educational materials, potable water, the presence of a trailhead host, and a shade 

structure constructed part way down the trail. 

Response: The Forest Service believes at this time that all of the components of the proposed action 

together will allow it to most effectively manage the challenges outlined in Sections 1.3 and 1.4 of the EA. 

The addition of potable water and a trailhead host in the future at the SDRG Trailhead will complement the 

proposed action. 

The Forest Service is not currently considering constructing a shade structure along the trail because the 

topography and vegetation along the trail are such that a structure would be visible from miles away, and 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

45 

therefore such an action would likely impact the aesthetic qualities of the area within a radius of several 

miles. Building a shade structure in an area inaccessible by vehicle would also be infeasible to maintain over 

the long term. 

13. The proposed metrics to gauge project success are not workable because they are difficult to 

implement, can be misleading, and can be manipulated. For instance, the metric on social 

impacts contradicts the goal of increasing public access if resource impacts are low. Other 

metrics can be distorted by members of the public who seek to decrease public use in this area. 

Response: The metric on social impacts was dropped from the proposed action because issues pertaining to 

parking on County public roadways are outside the jurisdiction of the Forest Service. For further 

information see Section 2.1.5 of the EA. Additionally, it should be noted that a variety of environmental and 

social values are at play at CCF, some of which contradict one another. These contradictions are reflective 

of the complexity of managing this area. See Section 2.1.2.1 of the EA for an explanation of how the Forest 

Service will address any potential manipulation of the proposed metrics. 

14. Conducting the CRAM assessment once per year as proposed will not allow the Forest Service 

to establish 3-month trends. 

Response: See Section 2.1.2.1 of the EA for an explanation of how monitoring on an annual or bi-annual 

basis will factor into the adaptive management system. 

15. A more appropriate way to address littering concerns than the proposed visitor use permit 

system would be to educate visitors, organize volunteer clean-ups, and enforce existing 

regulations. 

Response: The proposed visitor use permit system is designed to address a number of concerns, including 

littering. Beyond the visitor use permit system, the proposed action includes education on Leave No Trace 

and “pack it in, pack it out” ethics. See Section 2.1.2.1 of the EA for further information. The Forest Service 

believes that the proposed action in its entirety will allow it to most effectively manage littering and other 

concerns, and has additionally always encouraged volunteer engagement. 

New Alternatives That Should Be Considered 

16. The Cleveland National Forest should provide potable water and a host at the SDRG 

Trailhead prior to reopening the area surrounding CCF. 

Response: The SDRG Trailhead does not currently have potable water, which precludes keeping a host on 

site. The Forest Service is working with local and regional water authorities based on a previous NEPA 

decision to obtain potable water, and will provide a host when this individual can be provided with water. 

Access points to a very small minority of backcountry sites in the National Forest System provide potable 

water and a host, and National Forests are not required by law or agency policy to provide water and hosts 

at their recreation sites. So, while the Forest Service is currently working to develop a potable water source 

and has built a host site at the SDRG Trailhead, these features are not required to open and maintain a 

trailhead. 

17. Visitors to CCF should be required at a minimum to bring 100 ounces of water, sunscreen, 

proper footwear, a map, and a flashlight on their hike. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

46 

Response: The Code of Federal Regulations (CFRs) does not grant the Forest Service the legal authority to 

require visitors to carry these items with them when they visit National Forest System lands. Existing 

signage and educational materials provided with visitor use permits will advise hikers of the risks of 

recreating in this area as well as the means to mitigate those risks.

18. The trails leading to CCF should be open only for day use. 

Response: This recommendation was not studied in detail because many of the issues outlined in Sections 

1.3 and 1.4 of the EA, which are addressed by the proposed action (Section 2.1.2 of the EA), are related to 

recreational use that occurs during daylight hours rather than at night. Therefore the Cleveland National 

Forest is not proposing at this time to close the trails that lead to CCF between sunset and sunrise, which 

among other recreational groups would unduly impact hunters. 

19. Minors under the age of 18 should be prohibited from entering the area surrounding CCF 

unless there is a minimum of one adult over the age of 30 for every four minors. 

Response: The Forest Service is prohibited to discriminate between visitors on the basis of age, race, color, 

national origin, disability, sex, marital status, familial status, parental status, religion, sexual orientation, 

genetic information, political beliefs, reprisal, or income source, and so cannot impose age restrictions on 

visitors. 

20. Swimming in the pool below CCF should be prohibited. 

Response: Visitors swimming in the pool below CCF are not inherently causing any of the issues outlined 

in Sections 1.3 and 1.4 of the EA and therefore prohibiting swimming at this site would not address the 

purpose and need of the project. Rather, high levels of visitation and the historic tendency of visitors to 

jump from the cliffs into this pool contribute to these issues. As such, the Cleveland National Forest is 

proposing to manage access to CCF and close the cliff faces surrounding CCF to public entry as outlined in 

Section 2.1.2 of the EA. In an effort to preserve as many recreational opportunities that are not directly 

related to health and safety or resource concerns as possible, the Cleveland National Forest is not 

considering closing the pool below CCF to swimming at this time. 

21. Hikers seeking to access the San Diego River Gorge should be evaluated on the basis of their 

physical condition. Visitors not meeting a minimum standard should not be allowed to access 

the project area. 

Response: The Forest Service is prohibited to discriminate between visitors on the basis of ability, race, 

color, national origin, disability, age, sex, marital status, familial status, parental status, religion, sexual 

orientation, genetic information, political beliefs, reprisal, or income source, and so cannot impose visitor 

restrictions based on fitness. 

22. The SDRG Trailhead should be permanently closed and reserved only for emergency use. 

Response: Closing the SDRG Trailhead or obliterating the SDRG Trail would be in direct contradiction 

with Cleveland National Forest Land Management Plan (2005). See Section 1.4 of the EA for relevant 

guidance from the Land Management Plan. 

23. Obliterating the SDRG Trail is preferable to implementing a visitor use permit system because 

visitation levels did not pose problems prior to the construction of the trail. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

47 

Response: See response to comment 22. Additionally, the SDRG Trail and Trailhead were developed in 

part to address the resource impacts resulting from decades of use on unofficial trails leading to the highly 

popular CCF. Obliterating the trail would not prevent development of user-created trails to access the gorge, 

so would not meet the purpose and need of this project to reduce resource impacts or prevent undesirable 

visitor behavior. 

24. Permit requirements generally reduce access to public lands for recreational purposes, though 

CCF presents many management challenges. The best approach would be to obliterate the 

trail, though if this is not possible a visitor use permit may help to minimize past management 

issues. 

Response: See response to comment 22. 

25. Vegetation should be restored on the hillsides surrounding CCF to discourage visitors from 

scrambling to the top of the cliffs surrounding CCF. 

Response: The Cleveland National Forest believes that a more effective way to prevent recreationists from 

scrambling to the top of the cliffs surrounding CCF is to close these areas to public entry. Without closures 

in place efforts to restore vegetation would be hampered by continued recreation pressure, and it is hoped 

that the closures will allow the vegetation to naturally return to these sites.

26. The CCF area should be turned over to the National Park Service to be effectively managed. 

Response: This comment does not define “effective management” nor does the Forest Service agree that its 

management is not effective. Further, this comment is outside the scope of this project. 

27. The Cleveland National Forest should implement a policy that requires visitors to carry their 

human waste out of the San Diego River Gorge. 

Response: The Cleveland National Forest does not currently have water quality or other data or 

observations that suggest that human waste is an issue in the San Diego River Gorge. However, the litter 

metric outlined in Section 2.1.2.1 of the EA addresses human waste in addition to litter and other hazardous 

materials. If human waste becomes a problem in the future the Cleveland National Forest will take steps to 

address this issue by reducing the number of visitor use permits granted in accordance with the proposed 

adaptive management system. Adaptive management steps to address other potential environmental impacts 

are presented in Section 2.1.2.1 of the EA. 

28. The SDRG Trail and Trailhead should remain closed for an additional year to allow for a 

decrease in public interest in these sites. 

Response: The Forest Service will re-open the SDRG Trail and Trailhead when it is determined that 

recreational use at this site can be managed according to standards in the Cleveland National Forest Land 

Management Plan. See Section 1.4 of the EA for relevant Land Management Plan direction. Additionally, 

access to CCF has already been restored from the Saddleback Trailhead, and so the continued closure of the 

SDRG Trail and Trailhead may not lead to a decrease in public interest in this highly popular site. 

29. The Forest Service should de-emphasize CCF to discourage use of this area by removing the 

large interpretive signs located at the trailheads. 
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48 

Response: The signs at the trailheads that lead to CCF are primarily focused on regulatory and warning 

information at this time, and so it is unlikely that these signs are encouraging greater use of this area. 

Interpretive signs may be installed in the future in an effort to continue to educate the public about potential 

safety concerns and responsible recreation techniques, though it is expected that CCF rather than trailhead 

signage will continue to be the primary interest of visitors. 

Environmental Analysis and Consequences 

Depth of Analysis 

30. The Forest Service should prepare an EIS for this project because the draft EA does not 

adequately address public safety issues, traffic impacts, and environmental impacts in the 

project area. 

Response: The proposed action directly addresses historic and ongoing public safety issues and 

environmental impacts in the project area, and indirectly addresses traffic congestion adjacent to the project 

area by managing public use at CCF and tying future use levels at CCF to a baseline condition defined by 

the metrics presented in Section 2.1.2.1 of the EA. The project will not result in new impacts nor will it lead 

to an increase in historic levels of impact. Therefore, no significant impacts exist, so an EIS need not be 

completed for this project. 

31. Section 1.7 of the draft EA states, “No significant issues were identified by the interdisciplinary 

team or during scoping.” This statement is incorrect. There are obvious, significant impacts to 

County roadways and resources related to SDCE that have not been fully evaluated or 

mitigated by the proposed action. 

Response: The Forest Service determines “significance” as defined by NEPA. No significant impacts would 

result from the proposed action. See the Finding of No Significant Impact (FONSI). See also response to 

comment 30. 

32. Response to comment 109 in the draft EA (response to comment 172 in the EA) indicates that 

the Forest Service was aware that visitor patterns at CCF had been increasing for a number of 

years prior to the development of the SDRG Trailhead. Based on this recognition and recent 

documented issues, the Forest Service must identify impacts and analyze mitigation for the 

impacts to the human environment in SDCE and surrounding County roadways caused by 

building a trailhead that is unable to accommodate projected visitors. 

Response: The Forest Service is not required under NEPA to revisit or analyze past decisions. However, 

response to comment 30 describes how the proposed action will address issues associated with increasing 

patterns of public use at CCF that have occurred since 2007. 

33. Section 3.3 of the draft EA does not mention project impacts to County of San Diego 

infrastructure and/or resources, financial or otherwise. An EIS should be prepared to evaluate 

impacts to the adjacent County jurisdiction, including roadways and impacts to residents. 

Response: See response to comment 30. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

49 

Soils 

34. The project should be designed to minimize the potential for soil erosion related to 

construction during and after construction of the trail and parking area. 

Response: After discovering unanticipated wildlife and cultural resource issues the Cleveland National 

Forest elected to modify the proposed action and drop the proposal to construct a trail and parking area at 

the Saddleback Trailhead. See Section 2.1.5 of the EA for additional information. Regardless, it should also 

be mentioned that the Forest Service uses “Best Management Practices” in all of its construction projects to 

minimize the potential for soil erosion and other issues. 

Physical Environment 

35. The proposed action does not address how up to 375 recreationists per day would impact the 

area surrounding CCF. 

Response: The proposed action outlines a baseline condition based on “thresholds” for both existing 

concerns and potential future resource concerns as outlined in Section 2.1.2.1 of the EA. The intent is to 

allow the maximum amount of recreational access possible while remaining consistent with the baseline 

condition in order to achieve a balance between public use at this popular recreation destination and 

resource conditions. Thus, if any of the thresholds were exceeded the number of visitor use permits issued 

per day, and thus the maximum number of recreationists allowed to access CCF, would be decreased. 

Defining a baseline condition and the mechanisms by which to attain it allows for a more accurate 

understanding of future resource conditions than evaluating the impacts associated with a specific level of 

visitation, as different visitors vary in the level of their respect for the land and experience with low-impact 

recreation techniques. The figure of 375 recreationists represents an initial approximation of the number of 

visitors the area can sustain without further environmental degradation on a daily basis. This figure is based 

on past experience of Forest Service personnel, estimates of average group size, and parking turnover. 

However, monitoring will allow for adjustments to the use level at CCF per Section 2.1.2.1 of the EA in 

order to maintain baseline resource conditions. 

36. The proposed action, which would allow 75 visitor use permits and up to 375 hikers per day 

access CCF, is environmentally unsound. An environmental analysis, coupled with facility 

limitations, should provide the basis on the number of visitor use permits issued each day. 

Response: The commenter does not provide any documented evidence to support this comment. The Forest 

Service is unaware of any environmental analysis beyond that already disclosed that will reveal information 

more accurate than the outcome from monitoring under the adaptive management system as proposed in 

Section 2.1.2.1 of the EA. See Sections 3.1 through 3.3 for the Cleveland National Forest’s analysis of the 

environmental and social consequences associated with the alternatives presented in the EA. 

37. There is no toilet facility in the area around CCF. The proposed action does not address 

potential issues of human waste nor does it provide mitigation of potential environmental 

impacts in the project area. 

Response: See response to comment 27. 
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50 

38. A port-a-potty should be installed in the vicinity of CCF to address potential issues of human 

waste. 

Response: See response to comment 27. Further, vehicular access to the San Diego River Gorge is not 

adequate to allow the placement and maintenance of a port-a-potty in the vicinity of CCF. Restroom 

facilities are provided at the SDRG Trailhead. 

 Biological Environment 

39. Based on the intent of the project to manage use, the project may indirectly result in increased 

use of unofficial trails or creation of illegal trails. The EA should evaluate the potential for 

direct or indirect effects to biological and cultural resources from increased unofficial or illegal 

trail use. 

Response: Use will only be managed within the immediate vicinity of CCF and it is therefore anticipated 

that the project will result in an overall reduction in the proliferation of user-created trails. Further, the 

adaptive management system as outlined in Section 2.1.2.1 of the EA is designed such that user created 

trails will remain stable or decrease as compared to 2012 conditions. 

Cleveland National Forest Law Enforcement Officers and Forest Protection Officers will enforce the 

proposed use restrictions regardless of the route by which visitors attempt to access the proposed visitor use 

permit area outlined in Section 2.1.2 of the EA. The Cleveland National Forest is also unaware of any 

correlation between the management of visitor use and the use or creation of unofficial trails. Furthermore, 

unless otherwise posted, National Forest System lands are open to public access regardless of the presence 

of a trail. 

Additionally, attempting to identify and quantify the future use and proliferation of unofficial trails or the 

creation of illegal trails would be highly speculative. As mentioned in the EA, the proposed action contains 

a monitoring metric related to the proliferation of unofficial trails in the visitor use permit area. If such 

degradation of the natural resource base is detected, visitor use levels will be managed accordingly. 

40. Biological surveys, especially for California gnatcatcher, burrowing owl, and raptors should be 

considered for any trail construction or design. 

Response: After discovering unanticipated wildlife and cultural resource issues the Cleveland National 

Forest elected to modify the proposed action and drop the proposal to construct a trail and parking area at 

the Saddleback Trailhead. As such, no trail construction will occur as a part of this project. See Section 

2.1.5 of the EA for additional information. Further, it should be mentioned that all Forest Service projects 

require the completion of a biological evaluation and assessment, which analyzes potential impacts to these 

and other endangered, threatened, and sensitive plant and animal species. 

41. Project impacts that could have potentially adverse effects to the unincorporated County or 

County facilities should evaluate and mitigate environmental impacts using the County of San 

Diego’s Guidelines for Determining Significance. 

Response: The County’s guidelines for determining significance are based on requirements of the 

California Environmental Quality Act (CEQA). This project is not subject to CEQA because the proposed 

action lies entirely on National Forest System lands. As such, this project is subject to the National 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

51 

Environmental Policy Act (NEPA) and the significance criteria found in the regulations for implementing 

NEPA at 40 CFR 1508.27. 

 Social Environment 

42. The EA should properly analyze the archaeological and historic significance of the area and 

the potential effects from the proposed action to cultural resources.

Response: See Section 3.3.3 of the EA. 

43. It is not clear how the project proposes to relieve impacts to the San Diego Country Estates 

(SDCE) neighborhood adjacent to the SDRG Trailhead. Please further describe ongoing 

problems occurring in SDCE and how the proposed project would improve the situation. 

Response: See Section 1.3 of the EA for a description of ongoing issues that are occurring in SDCE. Given 

that these issues are related primarily to traffic congestion and parking in the neighborhood adjacent to the 

SDRG Trailhead, the Forest Service assumes that managing use at CCF via the proposed visitor use permit 

system outlined in Section 2.1.2 of the EA will in turn reduce impacts such as consistently high levels of 

overflow parking in the neighborhood adjacent to the trailhead. It is important to point out that the Forest 

Service cannot prohibit or control parking on County (public) roadways. Only the County has the authority 

to directly manage parking on County-maintained roads. 

44. The EA should analyze the potential visual and aesthetic resource impacts of the proposed 

action. 

Response: See Section 3.3.2 of the EA. 

45. Visitation for public viewing of Mildred Falls should be considered in planning for this project. 

Response: This comment is outside the scope of this project. 

46. The EA should include a traffic assessment to determine the project’s potential effect on 

circulation and County-maintained roads in the vicinity of the project area. 

Response: According to the “County of San Diego Guidelines for Determining Significance and Report 

Format and Content Requirement: Transportation and Traffic,” traffic impact studies may apply to specific 

land development or road improvement projects (3), pursuant to the California Environmental Quality Act 

(CEQA) (i).13 CEQA applies to certain activities of state and local public agencies.14 No infrastructure 

construction or land development will occur as part of this project, and the Forest Service is a federal, not 

state, agency. As such, the Cleveland National Forest is not obligated to conduct a traffic assessment as part 

of this project. 

Regardless, based on the initial proposal to issue 75 visitor use permits per day, no more than 75 vehicles 

total will initially be authorized to utilize the trailheads that lead to CCF for the purposes of visiting CCF. 

Based on estimates of use patterns presented in Section 1.3 of the EA, approximately 71 to 79% of traffic 

 

13 The document “County of San Diego Guidelines for Determining Significance and Report Format and Content Requirement: 

Transportation and Traffic” can be accessed at http://www.sdcounty.ca.gov/dplu/docs/Traffic_Guidelines.pdf. 

14 This information was accessed on the CEQA Frequently Asked Questions website, at 

http://www.ceres.ca.gov/ceqa/more/faq.html. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

52 

associated with visitation to CCF utilizes the SDRG Trailhead, whereas the remaining 21 to 29% of traffic is 

via the Saddleback Trailhead. The initial figure of 75 visitor use permits issued per day therefore suggests 

that approximately 16 to 22 vehicles (or 32 to 44 average daily trips) would seek access to CCF via the 

Saddleback Trailhead, and 53 to 59 vehicles (or 106 to 118 average daily trips) would seek to access CCF 

via the SDRG Trail. These estimates are based on the Forest Service assumption that each group that has 

obtained a visitor use permit will travel to the trailhead in one vehicle. Additionally, based on Forest Service 

staff observations over time, average use patterns at CCF are such that visitors come and go throughout the 

day, and not all visitors necessarily drive to the trailheads. If we assume that this use is spread primarily 

over 8 hours, the average number hourly trips throughout the busy part of the day at the SDRG Trailhead, 

where most use occurs, is 14.75. Other traffic to this area would not be associated with this project, so 

according to the “County Criteria for the Need to Prepare a Traffic Impact Study (TIS),” no additional 

traffic analysis would be required because hourly trips are fewer than 20. 

It should be emphasized that this analysis of traffic patterns was completed as a courtesy to the County and 

is intended for informational purposes only, as the Cleveland National Forest is not obligated to conduct a 

traffic assessment as described above. 

47. Any requirement by the County to conduct a Traffic Impact Study is not justification to 

reduce visitation to this site. Further, in 2010 and 2011 hundreds of vehicles visited this area 

on a typical busy day. 

Response: See response to comment 46 for an explanation as to why the Forest Service is not required to 

conduct a Traffic Impact Study as part of this project. See Sections 1.3 and 1.4 of the EA for rationale as to 

why the Forest Service is proposing to manage use at this site. 

48. The proposed visitor use permit system discriminates against minors and others who do not 

have a credit card because NRRS requires a credit card to make a reservation. 

Response: Visitor use permits are required at a variety of Forest Service sites across the National Forest 

System. Forest Service policy directs all National Forest System units to use NRRS for all reservable 

recreation opportunities (FSM 2334.35). Further, NRRS allows individuals to make reservations with credit 

cards, debit cards, or prepaid cards, such as those offered by Visa and Mastercard. Individuals of any age 

who are not able to obtain a credit card could use a debit or prepaid card to reserve a visitor use permit. 

Funding and Forest Service Staffing 

49. There is enough demand for recreation at CCF that the Cleveland National Forest should have 

money available to hire permanent staff for this area. 

Response: Despite an ongoing need for management in the area surrounding CCF, funding for Forest 

Service recreation programs is not directly tied to recreation demand. 

50. The Forest Service must ensure that no County resources will be necessary for safe operation 

of this area. 

Response: County law enforcement and emergency services staffs have responded to incidents in the CCF 

area in the past and have the discretion to do so at times in the future because in many cases these incidents 

are under the jurisdictional authority of the County. San Diego County has authorized the Sheriff’s 

Department to perform search and rescue and emergency response operations across the County. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

53 

51. The draft EA does not identify impacts to the County if CCF is designated as a visitor use 

permit area. The action will compel the County to provide unbudgeted public services 

including enforcement, rescue services, parking mitigation, and mitigation for quality of life 

issues. 

Response: See response to comment 50. Further, the proposed action does not compel the County of San 

Diego to take any action. 

52. Local law enforcement and fire departments are frequently diverted from their normal duties 

to responds to emergency calls in the project area. 

Response: The emergency calls in the project area that local law enforcement and fire departments respond 

to fall under the jurisdictional authority of the responding agencies. These incidents could therefore be 

considered “normal duties” associated with any area of high public use within San Diego County for these 

respective departments. 

Enforcement 

53. The Cleveland National Forest does not have adequate enforcement personnel to ensure that 

the project is successful. 

Response: This comment does not define “success.” Further, rules and regulations that result from the 

proposed action would be enforced by both law enforcement officers and forest protection officers. The 

Cleveland National Forest’s law enforcement resources are comparable to or greater than those of national 

forests across the nation, and we will use a targeted approach to law enforcement (focusing available law 

enforcement resources at CCF during busy periods) rather than having officers on site at all times. To date 

this strategy has been effective in managing the temporary closure order put into place around CCF in July, 

2011, as well as in other locations. The Forest Service is confident that this approach will continue to be 

successful in the future based on past experience, including at this site. Further, educational materials will 

be included with the visitor use permit, which will better inform visitors about the regulations and 

appropriate behaviors in this area. Improved education is expected to decrease the need for law enforcement 

over time as visitors become more familiar with area regulations. 

54. If Forest Service budgets are being cut and no money is available for increased management 

and enforcement in the area surrounding CCF, CCF should remain closed. 

Response: The Forest Service is not proposing to obtain increased enforcement resources as part of this 

project. See response to comment 53 for additional discussion of the Forest Service approach to law 

enforcement as it pertains to this project. Further, leaving CCF closed requires management of the closure. 

Managing a closure requires staffing in line with or greater than managing the proposed visitor use permit 

system. 

55. It is erroneous for the draft EA to state support for a “targeted” approach to enforcement 

(focusing available law enforcement resources at CCF during busy periods) by using the 

temporary July 2011 closure as an example. Enforcement of a closure is significantly different 

than enforcing an active trail site. It is the [County’s] understanding that there is an extremely 

limited number of USFS staff available for enforcement, so proper enforcement will not be 

possible. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

54 

Response: The commenter does not describe their definition of “proper” enforcement. Nonetheless, see 

response to comment 53 for an explanation of the standard Forest Service approach to law enforcement, 

which currently applies to CCF. This approach has applied to CCF in the past and will continue to do so in 

the future. 

Additionally, aside from the proposed alcohol prohibition on the SDRG Trail and Eagle Peak Road (Trail), 

enforcement needs on these trails (an “active trail site” according to the commenter) will be comparable to 

other Forest Service trails. Further, the area closures that have been in place across the project area in recent 

months are much more challenging to enforce than the proposed visitor use permit area would be due to the 

large area that the closures cover. See Section 2.1.2 and Figure 2 in the EA for an overview of the proposed 

visitor use permit area, which will be much smaller in size than the closure areas. Other enforcement will 

occur at times at the trailheads that lead to CCF, which are discrete points on the landscape, and so will also 

allow for efficient, effective law enforcement operations. 

56. Enforcement of a visitor use permit area, alcohol prohibition, and campfire prohibition 

requires that law enforcement officers be posted at CCF 24 hours per day, 7 days per week. 

Response: See response to comment 53. Additionally, no law enforcement agency can monitor all areas or 

issues at all times. 

57. On weekends and during the summer months a minimum of six law enforcement officers 

should be posted at CCF and the trailheads that lead to CCF. On weekdays at least four law 

enforcement officers should be posted at CCF and trailheads. 

Response: See response to comment 53 for a brief overview of typical Forest Service law enforcement 

staffing. Further, the commenter does not provide justification as to why the suggested staffing levels should 

be implemented and does not take into consideration other pressures and constantly shifting law 

enforcement needs and priorities. 

58. Without adequate enforcement no management system will address the ongoing issues 

associated with CCF. 

Response: The Forest Service believes that its enforcement resources are sufficient for the successful future 

management of CCF in accordance with the proposed action. Further, the adaptive management strategy 

provides for managing visitor numbers if specified resource impacts exceed the proposed metrics. 

59. The draft EA notes that a targeted approach to enforcement will be used at CCF. This will not 

be effective, as hikers without visitor use permits will visit CCF when they realize that law 

enforcement officers are not present. 

Response: See response to comment 53. 

60. The fine for breaking new rules in the project area should be increased. 

Response: This comment is outside the scope of this project because the Forest Service does not establish 

the financial penalties associated with violating various laws. The fines for violating various laws and 

regulations proposed as part of this project are set by the District Attorney’s Office of the Department of 

Justice. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

55 

61. It is difficult for law enforcement and emergency response organizations to quickly respond to 

issues at and around CCF due its remote location. 

Response: The Cleveland National Forest recognizes that the remote location of CCF presents challenges 

for law enforcement and emergency response operations. As such, the forest is looking for ways to improve 

the accessibility of the area. In the interim, targeted law enforcement operations are at times being staged in 

the area surrounding CCF so that law enforcement officers and forest protection officers are already on 

scene during busy periods of visitation when many enforcement or emergency response needs arise. 

62. Law enforcement officers should take a “zero tolerance” approach to violations or illegal 

activity during the initial implementation of the project. A public education program should be 

simultaneously implemented to ensure that visitors are aware of new regulations. 

Response: The Forest Service anticipates focusing its enforcement resources on CCF when the SDRG Trail 

is reopened and in the future during busy periods in an effort to effectively educate the public and address 

potential law enforcement issues in the project area. This being said, law enforcement personnel are trained 

to assess a given situation and tailor their response to violations of the law or regulations based on the 

severity of the action in question, their sense of safety, and whether or not an opportunity exists to educate 

the individual in question. Public education will be used to ensure that visitors are aware of new regulations. 

63. The Cleveland National Forest should enforce regulations and issue citations for all 

infractions. Rather than issuing warnings, the maximum penalty possible, including arrest, 

should be imposed on members of the public violating the law or regulations. 

Response: See response to comment 62. 

64. CCF presents challenges law enforcement officer safety when only one or two officers engage 

in enforcement activities at CCF. 

Response: Forest Service law enforcement officers are trained to work alone or in small groups in remote 

areas, and this is a common, accepted part of their jobs. Potential safety concerns are addressed in part by 

the training and tools provided to law enforcement personnel. 

65. A strong enforcement presence when the SDRG Trail is reopened will be beneficial in 

educating the public about area regulations and minimizing future problems. 

Response: See response to comment 62. 

66. CCF should remain closed until an enforcement plan is mutually agreed upon by the San 

Diego Sheriff’s Department, California Highway Patrol, Cal Fire, and the Cleveland National 

Forest. 

Response: The Cleveland National Forest is engaged in ongoing coordination meetings with the San Diego 

Sheriff’s Department and Cal Fire regarding the management of CCF, and looks forward to continued 

cooperation with its partners in matters of law enforcement. These meetings focus on clarifying 

jurisdictional authorities and the commitment of resources and personnel to CCF based on current priorities 

and capabilities. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

56 

67. It is arbitrary and capricious to reach the conclusion that the proposed action will not result in 

significant impacts in the absence of an enforcement plan. An enforcement plan should identify 

staffing, locations, and hours of enforcement. 

Response: See comment 53 for an overview of the approach that the Forest Service takes to law 

enforcement. This approach will also apply to CCF and is standard across the agency. The Cleveland 

National Forest has law enforcement resources that are comparable to or greater than those of other national 

forests. 

The baseline condition in the project area is represented by historic conditions and public use patterns at 

CCF, which are described in Section 1.3 of the EA. A complete lack of enforcement of the visitor use permit 

system would likely result in a return to the baseline condition, which would result in the status quo rather 

than impacts, significant or not, as defined under NEPA. Finally, by publically publishing its enforcement 

plans the Cleveland National Forest would likely compromise the effectiveness of its law enforcement 

operations, increasing the likelihood of a return to the challenges outlined in Section 1.3 of the EA. 

See response to comment 30 for additional discussion of why the proposed action will not result in 

significant, adverse impacts. 

68. The Cleveland National Forest should reimburse the San Diego Sheriff’s Department to cover 

the cost of all overtime incurred enforcing the closure order put into place in July, 2011. 

Response: Absent an agreement by the Forest Service to reimburse the County for costs associated with 

enforcement of the closure order put into place in July, 2011, the Cleveland National Forest is unaware of 

any legal basis for the County to hold the Forest Service liable for these costs. This is in large part due to the 

fact that it is the jurisdictional responsibility of the County to perform search and rescue operations, as well 

as provide law enforcement in unincorporated areas of the County, such as in SDCE. 

69. The Cleveland National Forest should approach the San Diego River Conservancy about the 

River Conservancy’s willingness to reimburse the San Diego Sheriff’s Department and 

California Highway Patrol for personnel who work at CCF. 

Response: See response to comment 68. 

70. Vehicles parked at the trailhead should be subject to inspection of all contents and 

compartments without a warrant by law enforcement personnel. 

Response: The Code of Federal Regulations (CFRs) does not grant the Forest Service the authority to 

search and inspect visitors’ vehicles without a warrant. Furthermore, the Fourth Amendment to the 

Constitution of the United States guards against unreasonable searches and seizures, including of vehicles, 

without probable cause or reasonable suspicion of criminal activity. This suggestion is additionally outside 

the scope of this project. 

71. The San Diego Sheriff’s Department and California Highway Patrol should be granted the 

authority to engage in enforcement activities on the Cleveland National Forest. 

Response: County and State law enforcement officers have the jurisdiction to enforce many laws on 

National Forest System lands. However, it would require an Act of Congress to allow the Forest Service to 

grant local and state law enforcement officers with CFR enforcement authorities, which allow for the 

proposed visitor use permit area, alcohol prohibition, and cliff closure. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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72. To date, current enforcement efforts have been focused at the trailheads leading to the San 

Diego River Gorge. 

Response: This comment is a matter of opinion and is speculative in nature. The Cleveland National Forest 

has enforced area regulations both at the trailheads leading to the San Diego River Gorge and in the 

immediate vicinity of CCF, where people are most likely to congregate or be intercepted by Forest Service 

law enforcement personnel. 

73. The $6 administrative fee associated with the visitor use permit should be used to fund 

enforcement activities in the project area. 

Response: The National Recreation Reservation Service (NRRS) fee associated with the visitor use permit 

system is collected by NRRS to cover the administrative costs associated with running the reservation 

system. The NRRS fee is distinct from a Forest Service Standard Amenity Fee, and no part of the NRRS fee 

is retained by the Cleveland National Forest, and as such cannot be used to fund enforcement activities in 

the area surrounding CCF. 

Standard Amenity Fees can be charged only at developed recreation sites that contain picnic tables, trash 

collection, toilet facilities, parking, interpretive signing, and security. While the San Diego River Gorge 

contains all of these required amenities, requiring a fee at this trailhead would therefore provide a financial 

incentive for forest visitors to park on County roads rather than in the trailhead parking lot because the 

Forest Service does not have the authority to levy parking fees on County roads. 

74. Remote surveillance cameras should be installed at the trailheads leading to CCF to enhance 

law enforcement capabilities. 

Response: The Cleveland National Forest is not currently considering installing remote surveillance 

cameras at its trailheads because it is unclear how this approach would improve enforcement outcomes for 

the proposed visitor use permit area, alcohol prohibition, and closure of cliff faces. Of particular importance 

here is that violations of the proposed visitor use permit area and closure of cliff faces occur in the 

immediate vicinity of CCF, not at the trailheads. The open possession and consumption of alcohol occurs at 

CCF and along the trails the vast majority of the time as well, not at the trailheads. 

Public Health and Safety 

75. The Cleveland National Forest should not close the cliffs surrounding CCF because the Forest 

Service is under no legal obligation to prevent the public from experiencing the natural 

hazards associated with cliffs, climbing, rappelling, or jumping into pools of water. 

Response: The Cleveland National Forest is not proposing to close the cliffs surrounding CCF because it is 

under a legal obligation to do so. Rather, this action is being proposed to improve public health and safety as 

well as address an ongoing and consistent pattern of injuries and fatalities associated with risky behaviors at 

this site. 

76. The public should not be prohibited from jumping from the rocks on the northwest side of the 

pool below CCF. These rocks range from 2 to 10 feet in height and provide an opportunity for 

people to learn to jump from progressively higher heights. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

58 

Response: The Forest Service believes that it is necessary to close all cliffs and rocks adjacent to CCF to 

public entry and jumping in order to address an ongoing and consistent pattern of injuries and fatalities 

associated with risky behaviors at this site. For one, the depth of the water in the pool below CCF is 

variable, and at times poor visibility obscures potential hazards below the water’s surface. Second, to close 

some but not all cliff areas to public entry may create confusion for the public and enforcement challenges, 

which together could result in recreationists unknowingly engaging in unsafe and prohibited activities at this 

site. 

77. Children and young adults are attracted to CCF to jump into the pool below CCF, an activity 

that is inherently dangerous. 

Response: The Cleveland National Forest does not disagree that some individuals may seek to visit CCF to 

jump from rocks into the pool below CCF and that this activity in many instances is dangerous. However, 

public lands, which make up approximately one-third of the United States, have many dangers associated 

with their features and the activities that visitors choose to undertake. There are over twenty waterfalls on 

this District alone. The visitor is ultimately responsible for her/his personal safety and wellbeing when using 

these lands. 

78. The Cleveland National Forest should remove rocks at the downstream end of the pool below 

CCF to eliminate the pool and the safety issues associated with visitors jumping from the rocks 

surrounding CCF. 

Response: The Cleveland National Forest believes that the proposed action will allow it to successfully 

manage the issues described in Section 1.3 of the EA. Further, to permanently drain the pool below CCF 

would likely adversely impact a number of forest resources, and so may ultimately not be an 

environmentally feasible management approach nor would it be consistent with the Land Management Plan. 

79. A lifeguard should be posted at CCF during daylight hours on weekends and holidays. 

Response: The Forest Service does not traditionally staff its undeveloped swimming areas with lifeguards, 

nor does it have the resources to do so. Additionally, as described in response to comment 77, public lands 

make up one-third of the United States. These lands are largely undeveloped and are not managed like a city 

or county park. 

80. A new trailhead at the end of Ramona Oaks Road would address safety concerns at CCF 

because it is 100 feet lower than the SDRG Trailhead, and would therefore result in fewer 

visitors experiencing heat exhaustion. Existing shade trees in the vicinity of Ramona Oaks 

Road will further address the issue of heat related illness. 

Response: Most cases of observed heat exhaustion on the SDRG Trail occur on the trail rather than at the 

trailhead, so it is doubtful that new parking facilities located 100 feet lower in elevation than the present 

facilities would substantially reduce instances of visitors experiencing heat exhaustion along the trail. The 

SDRG Trailhead also contains a shade structure. 

See Section 2.1.6 of the EA for additional discussion of the issues pertaining to the construction of an 

alternate trailhead location at the end of Ramona Oaks Road. 

81. Access to CCF should be prohibited during periods of high fire danger. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Response: This comment is outside the scope of this project. However, the Cleveland National Forest has in 

the past implemented emergency area closures during periods of extreme fire danger and may elect to do so 

again in the future. 

82. The trailheads that lead to the San Diego River Gorge should be closed during periods of 

extremely hot weather. 

Response: The Cleveland National Forest is not currently considering implementing area closures in the 

area surrounding CCF due to hot weather conditions because as a rule the Forest Service seeks to provide as 

much public access to public lands as possible. Further, it is ultimately the responsibility of forest visitors, 

not the Forest Service, to ensure that they are prepared for extreme weather conditions. 

83. A permanent helipad should be constructed near CCF to improve emergency response and 

enforcement capabilities. 

Response: A permanent helipad was designated in the vicinity of CCF in early 2011 in coordination with 

the San Diego Sheriff’s Department. 

84. The Cleveland National Forest should patrol the trails leading to the San Diego River Gorge 

using a motorized four-wheeler in order to allow for the delivery of fluids as well as to improve 

rescue transport of distressed hikers. 

Response: The landscape surrounding the SDRG Trail is classified as “Semi-Primitive, Non-Motorized,” 

meaning that the use of motorized equipment is inconsistent with the Cleveland National Forest Land 

Management Plan. Eagle Peak Road (Trail) is not safely passable for a motorized vehicle at this time. 

85. The response to comment 84 (response to comment 58 in the draft EA) notes that ATV use on 

the SDRG Trail is inconsistent with management classification of this area as Semi-Primitive, 

Non-Motorized. This results in helicopter rescue operations. Aren’t helicopters motorized? 

Response: Occasional aircraft access is generally acceptable in lands classified by the Forest Service as 

Semi-Primitive, Non-Motorized, particularly for emergency search and rescue operations. In addition to 

their consistency with this land management classification, helicopter operations are generally less obtrusive 

and far more effective for rescue operations than ATVs in unroaded, remote terrain. 

86. The draft EA describes existing problems of restricted emergency access along Eagle Peak 

Road during busy periods at CCF. Does the Forest Service propose to use signage, increased 

patrols, or other measures to address this issue? 

Response: The Forest Service assumes that the management of public use at CCF will in turn improve past 

problems related to traffic congestion on Eagle Peak Road. Additionally, Eagle Peak Road is a Countymaintained road. The Forest Service therefore does not have the authority to impose or enforce parking 

restrictions, or otherwise manage traffic unless vehicles are parked in such a manner that they are blocking 

the right of way. In such cases Forest Service law enforcement officers can and do issue parking citations. 

The Forest Service has relayed concerns regarding this issue to the California Highway Patrol and San 

Diego Sheriff’s Department, and is currently working with the Sheriff’s Department and Cal Fire to address 

a number of issues at Cedar Creek Falls. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

60 

87. The draft EA identifies an existing problem with parking at the Saddleback Trailhead, thus 

making it unsafe for vehicles to pass and rendering the road inaccessible for emergency 

vehicles. The EA does not describe whether parking will be prohibited or restricted on this 

road. If parking will not be restricted, the impacts to public safety from the inability of 

emergency vehicles being able to access this area should be discussed, analyzed, and mitigated. 

Response: See response to comment 86. 

Search and Rescue 

88. People who are rescued or evacuated from the area surrounding CCF should be fined and/or 

pay the costs of the rescue operation. 

Response: This comment is outside the scope of this project because search and rescue operations are 

outside the jurisdictional authority of the Forest Service. Rather, the County of San Diego has authorized the 

Sheriff’s Department to perform such search and rescue operations. Any changes to this policy would have 

to be brought about by the County. 

89. The San Diego Sheriff’s Department should be granted with vehicle access along the SDRG 

Trail. 

Response: See response to comment 84. 

Volunteers 

90. The Cleveland National Forest should develop a volunteer patrol program in the project area. 

Response: The Cleveland National Forest currently has a volunteer safety patrol program in place on many 

busy days in the area surrounding CCF. This program focuses on educating visitors about weather 

conditions, hazards, and the difficulty of the hike to and from CCF; assisting members of the public who are 

near or in distress; and helping to coordinate rescue operations as necessary. 

91. Volunteers do not have enforcement capabilities, and so the use of volunteers to address safety 

and resource concerns in the project area does not adequately address the concerns outlined in 

Sections 1.3 and 1.4 of the EA. 

Response: Forest Service volunteers are prohibited from engaging in law enforcement activities, which 

includes making contact with visitors observed breaking forest rules or violating the law. Rather, in these 

instances volunteers are instructed to notify law enforcement. See response to comment 90 for an example 

of volunteer actions that are appropriate and that address some of the concerns outlined in Sections 1.3 and 

1.4 of the EA. 

92. A host at the SDRG Trailhead would not be able to enforce rules and regulations in the area 

surrounding CCF. 

Response: See response to comment 91. 

Infrastructure Improvements 
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93. The Cleveland National Forest should work with the San Diego River Park Foundation to 

explore trail connections between Eagle Peak Preserve and the trail that continues to the San 

Diego River Gorge, as well as improvements such as an emergency helicopter landing site, 

potable water facility, a pump-out comfort station, and interpretive elements for Eagle Peak 

Preserve. 

Response: This comment is outside the scope of this project because it does not meet the purpose and need 

outlined in Section 1.4 of the EA. 

94. The EA should include figures and graphics that clearly portray the location of existing and 

proposed improvements, as well as local roadways. 

Response: See Figures 1, 2, 3, and 4 of the EA. 

95. Will the proposed project result in the need for additional infrastructure and/or utilities? 

Response: Aside from signage in the project area the proposed action does not include the development of 

any infrastructure or utilities. For further information see Section 2.1.2 of the EA. 

96. A permanent kiosk and dumpster should be located in the vicinity of CCF.

Response: The Cleveland National Forest installed what it believes to be adequate signage in the vicinity of 

CCF during spring and summer of 2011. Vehicular access to the San Diego River Gorge is not adequate to 

allow the placement of a dumpster in the vicinity of CCF nor should the taxpayer bear the financial burden 

of removing trash from this site for the convenience of hikers when visitors can otherwise carry out the 

limited quantity of trash that would be on their person. 

Noise 

 

97. The EA should analyze the potential impacts of noise from construction activity on sensitive 

species. 

Response: No construction activities outside of the installation of signage in the project area will occur as 

part of this project. For further information see Sections 2.1.2 and 2.1.5 of the EA. 

Campfires 

98. A prohibition should be placed on fires and smoking in the project area. 

Response: This comment is outside the scope of this project. Campfires outside of the fire rings in 

developed campgrounds are prohibited at all times across the Cleveland National Forest, including in the 

San Diego River Gorge. At this time the Cleveland National Forest has not identified a need to prohibit 

smoking in its dispersed areas except for during extreme fire conditions. 

99. Issues related to campfires and overnight camping in the area surrounding CCF should be 

addressed. 

Response: See response to comment 98 for a discussion of campfires. Illegal campfires are addressed using 

law enforcement actions. Overnight camping is prohibited within 200 feet of water and trails, and targeted 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

62 

enforcement actions occur to address this issue. While these regulations would in effect prohibit camping at 

CCF and in the proposed visitor use permit area, it is important to point out that camping is allowed in other 

parts of the San Diego River Gorge and Cedar Creek drainage. 

Dogs 

100. It should be required that dogs remain on a leash at all times in the area surrounding 

CCF. 

Response: Dogs must be under the control of their at all times on National Forest System lands. According 

to 36 CFR § 261.8 (d), visitors are prohibited from “possessing a dog not on a leash or otherwise confined.” 

101. People should be prohibited from bringing dogs to CCF. 

Response: The Code of Federal Regulations (CFRs) does not grant the Forest Service the authority to 

prohibit visitors from bringing dogs with them when they visit National Forest System lands. 

102. Dogs of primarily the pit bull breed should be prohibited in the area surrounding CCF. 

Response: The Code of Federal Regulations (CFRs) does not grant the Forest Service the authority to 

prohibit visitors from bringing specific breeds of dog with them when they visit National Forest System 

lands. 

Education 

103. The Forest Service should install informational signage along Eagle Peak Road so that 

uniformed visitors who seek to visit CCF but do not have a visitor use permit do not 

unnecessarily travel all the way to the Saddleback Trailhead. 

Response: The Cleveland National Forest proposes to take a number of approaches to educating visitors 

about safe hiking practices and methods of minimizing resource impacts. See Section 2.1.2 of the EA for 

further information. 

104. Signs that educate the public about the visitor use permit system should be placed at the 

trailheads leading to CCF. 

Response: See response to comment 103. 

105. The Cleveland National Forest should install signage at the junction of Eagle Peak and 

Boulder Creek Roads that outlines the need to carry water on the hike to the San Diego River 

Gorge. 

Response: See response to comment 103 

106. The Cleveland National Forest should provide information on the “ten essentials” to 

visitors. 

Response: See response to comment 103. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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107. Current signage at and around CCF is inadequate. Signage should be larger and more 

conspicuous. 

Response: The Forest Service seeks to strike a balance between providing adequate information to visitors 

and maintaining an undeveloped atmosphere in its dispersed recreation areas. At this time signage in the 

area surrounding CCF exists and is adequate to meet current management needs, though the Forest Service 

will continue to assess these needs as they evolve. 

108. Signage in the vicinity of CCF should be improved to discourage people from getting 

lost. 

Response: See response to comment 107. 

109. The Cleveland National Forest should overstate the difficulty of the hike to CCF to 

discourage unprepared hikers from making the trip. 

Response: The Cleveland National Forest endeavors to provide visitors with accurate, true information. 

Therefore, while the forest can educate visitors about potential hazards associated with recreation on 

National Forest System lands, it cannot overstate these hazards. 

110. Signage rather than fencing on the cliff faces and above CCF will sufficiently deter 

visitors from jumping from the cliffs. 

Response: See response to comment 3. 

111. Warning and mileage signage should be placed in increments along the SDRG Trail 

and Eagle Peak Road (Trail) to educate visitors about the remaining distance to CCF. 

Response: The Forest Service does not typically install mileage markers on its trails, and rather 

concentrates educational and warning signs at trailheads. However, the Forest Service is currently in the 

process of developing and installing mileage markers in quarter-mile increments along the trails that lead to 

CCF. 

112. How will the Forest Service warn hikers about the difficult trail conditions and the need 

to take adequate water? 

Response: See Section 2.1.2 of the EA. 

Social Setting 

113. To allow impacts to the San Diego Country Estates equal in magnitude to those during 

the summer of 2011 is unacceptable. 

Response: See Section 2.1.2 of the EA. 

Visitor Use Permits 

Issuing Visitor Use Permits 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

64 

114. How will parking areas be monitored to ensure that all vehicles have visitor use 

permits? 

Response: The proposed visitor use permit system will require that hikers seeking to enter the visitor use 

permit area surrounding CCF have a visitor use permit on their person or in their group rather than in their 

vehicle. The Code of Federal Regulations (CFRs) does not grant the Forest Service the authority to require 

parking permits. Visitor use permits therefore cannot be specific to an individual trailhead or vehicle. See 

Appendix B to this document for additional details on the mechanics of the visitor use permit process. 

115. A visitor use permit system should be implemented to manage the number of visitors 

allowed to access the area surrounding CCF. The visitor use permit should consist of a stub 

left in the visitor’s vehicle and a stub kept on the person of every visitor associated with the 

vehicle. 

Response: See response to comment 114, Appendix B, and Section 2.1.2 of the EA. 

116. The Cleveland National Forest should assign a specific number of visitor use permits to 

each trailhead that leads to CCF. 

Response: See response to comment 114. 

117. If 75 visitor use permits will be offered each day 25 should be made available for online 

reservation and the remaining should be available on a first-come, first-served basis at each 

trailhead. 

Response: Visitor use permits would not be offered in person on a first-come, first-served basis because the 

Cleveland National Forest does not have the workforce capacity to accommodate this workload, and given 

the capacity such an approach would still not be a cost efficient use of personnel. Further, offering visitor 

use permits in person on a first-come, first-served basis would unfairly favor locals visiting this popular 

recreation destination. 

In accordance with national Forest Service policy, visitor use permits will be reservable through the 

National Recreation Reservation Service (NRRS) (FSM 2334.35), which will provide all members of the 

public with an equal opportunity to obtain a visitor use permit. Individuals without a credit card can use a 

debit or prepaid card to obtain a visitor use permit from NRRS. 

118. Visitor use permits should be issued for morning or afternoon hours to control hiker 

turnover in the project area. 

Response: Forest Service policy requires that all reservable recreation opportunities be managed through 

the National Recreation Reservation Service (NRRS). NRRS does not specify the time of day that visitors 

are allowed to use their visitor permits. Rather, the visitor use permits are valid throughout the course of the 

day for which they are issued, and any potential issues with hiker turnover will be addressed via the 

adaptive management process outlined in Section 2.1.2.1 of the EA if necessary. 

119. Residents from SDCE and other organized groups should be granted special access to 

CCF, either by giving them a waiver for the visitor use permit requirement or by granting 

them a permanent visitor use permit. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

65 

Response: The national public share equal ownership in public lands, including the Cleveland National

Forest, with residents of SDCE. Therefore, residents of SDCE and other groups who may wish to visit CCF 

must obtain a visitor use permit consistent with the requirements for other members of the public. 

120. A special allotment of visitor use permits should be set aside for residents of SDCE. 

Response: See response to comment 119. 

121. The Forest Service should issue visitor use permits only to residents of SDCE. 

Response: See response to comment 119. 

122. Individuals with a Military ID card (active duty or retired) or a California 

Distinguished Veteran Pass should be given a waiver for the visitor use permit requirement. 

Response: See response to comment 119. 

123. Some visitors like to use the trails in the area surrounding CCF, but do not actually 

visit CCF. The Forest Service should not require a visitor use permit to hike on the trail. 

Response: The proposed visitor use permit system would apply only to the area immediately surrounding 

CCF and would not impact trail users who do not seek to visit CCF. For further information see Appendix 

B, Figure, 2 and Section 2.1.2 of the EA. 

124. Visitation patterns at CCF vary greatly by season and day. A visitor use permit should 

not be required to visit CCF on days when use is predicted to be low, because many days only 

a small handful of people visit CCF. 

Response: See Section 2.1.2.1 of the EA. 

125. Unmonitored use of the SDRG Trail threatens the safety of visitors to CCF as well as 

the success of the project. The EA should address how this area will be monitored and how 

visitors in violation of the visitor use permit requirement will be handled. 

Response: Monitoring is an integral part of the proposed adaptive management system. See Section 2.1.2.1 

of the EA for an overview of how the visitor use permit area will be monitored. Response to comments 53 

and 62 describe the typical Forest Service approach to law enforcement and how law enforcement officers 

typically address violations of area regulations or laws, including those that occur at CCF. 

126. The draft EA fails to address if other users of the trail and trailhead such as 

equestrians, bicyclists, hikers, and hunters must have a visitor use permit to access the 

trailhead and trail. 

Response: Appendix B and Section 2.1.2.1 in both the EA and draft EA explains that visitors to the SDRG 

Trail (including equestrians, bicyclists, hikers, and hunters) will not be required to obtain a visitor use 

permit unless they seek to access the visitor use permit area in the immediate vicinity of CCF, as depicted in 

Figure 2 of the EA and draft EA. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

66 

127. Will there be visitors coming from other parking locations on foot? What are current 

and future bicycle and equestrian uses in the area, and how will non-parking visitors be 

accounted for? 

Response: Residents of SDCE have visited the area surrounding CCF by foot, bicycle, and horse in the past 

and will likely continue to do so in the future. It is therefore likely that this area will continue to 

accommodate visitors who travel to the trailhead by a variety of means. 

Historically some equestrian and bicycle use occurred in this area, though in recent years this use has been 

dwarfed by the volume of hiking use. It is likely that the volume of non-hiking use in this area will remain 

relatively consistent in the future, though the management of visitation at CCF under the proposed action 

may result in equestrian and bicycle use comprising a larger share of total use since total use will decrease 

under the proposed action. 

See response to comment 126 for an overview of how visitors who do not drive to the trailhead will be 

accounted for. 

Use Levels and Quotas 

128. The number of visitor use permits issued should be based on law enforcement 

capabilities and environmental analysis. 

Response: Initial use levels under the proposed visitor use permit system are based on a balance between 

achieving baseline resource conditions and providing public access to CCF. Use numbers can be adjusted up 

or down according to a series of metrics that define a baseline condition. For further information about the 

proposed adaptive management approach see Section 2.1.2.1 of the EA. Sections 3.1 through 3.3 of the EA 

describe the environmental and social effects of the project’s alternatives. 

129. The project description states that there will be a limited number of visitor use permits 

that visitors may reserve. Is this number based on parking capacity? 

Response: See response to comment 128. 

130. The Cleveland National Forest should base the number of visitor use permits it issues 

on the parking capacity at the SDRG Trailhead. 

Response: See response to comment 128. 

131. Determining the correct number of visitor use permits to issue in one day is a 

challenging task. The Cleveland National Forest should start with a low number of visitor use 

permits and increase the number of visitors permitted to visit CCF only if hiking traffic is 

manageable. 

Response: See response to comment 128. Additionally, see comments 135 and 137 to understand the 

diversity of public opinion regarding use levels at CCF. 

132. The proposal to initially permit 75 visitor use permits of up to 5 to access CCF each day 

is allows too many people in the project area. The Cleveland National Forest should start out 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

67 

by allowing 25 visitor use permits per day, or a number that is lower than the number of 

parking spaces available at the SDRG Trailhead. 

Response: See response to comment 128. 

133. It is possible that many more visitors than the 75 groups permitted to visit CCF will use 

the SDRG Trail each day, which would impact the neighborhood adjacent to the trailhead to a 

greater degree than anticipated in the draft EA. 

Response: See response to comment 126, 128, and 134. Additionally, the management of parking and 

traffic congestion is outside the jurisdiction of the Forest Service and is the responsibility of the County. 

134. The proposal to initially offer 75 visitor use permits per day is too high. Such a level of 

use will result in crowding, noise, and pollution at CCF. Further, parking is not adequate for 

this level of use prior to considering the number of unpermitted hikers, mountain bikers, and 

equestrians that may park in trailhead areas. 

Response: See response to comments 126 and 128. Additionally, see comments 135 and 137 to understand 

the diversity of public opinion regarding use levels at CCF. 

135. The proposal to initially issue 75 visitor use permits per day is too low. This figure is 

based on estimates and does not capture use on busy days in 2007. The 2009 Decision Memo 

for the SDRG Trail and Trailhead predicted increased visitation. Increased public use of 

National Forest System lands is a positive trend. 

Response: See response to comment 128. 

136. The Forest Service is using law enforcement challenges to justify managing visitation to 

CCF. The draft EA does not demonstrate that issuing only 75 visitor use permits per day will 

address violations of regulations and/or the law. 

Response: Section 1.4 of the EA outlines the purpose and need of the proposed action. This project 

proposes to address resource and social impacts associated with historically high levels of public visitation 

at CCF, not violations of regulations and/or the law. See response to comment 128 for further discussion of 

initial use levels under the proposed visitor use permit system, and how these use levels will conform with a 

baseline resource and social condition. 

137. CCF is the most popular waterfall in San Diego County. It is not a “remote 

backcountry area.” Therefore it is not necessary to manage use at this site due to 

environmental impacts. A system that issued 160 visitor use permits per day would be 

sufficient to prevent most environmental impacts. 

Response: The popularity of CCF does not diminish the remote and rugged characteristics of the landscape 

that surrounds CCF or the obligation of the Forest Service to address conflicts between recreational uses and 

sensitive resources. 

The Forest Service is unaware of any environmental analysis that suggests that 160 visitor use permits per 

day would prevent most environmental impacts in the project area. See Section 2.1.2.1 of the EA for an 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

68 

overview of how environmental and social concerns will be monitored as part of this project, and how the 

outcome of this monitoring will govern how many visitor use permits are issued each day. 

Geographic Area

138. The eastern boundary of the proposed visitor use permit area should be extended to 

encompass the area above CCF. 

Response: The proposed visitor use permit area encompasses the area immediately above CCF. For further 

information see Figure 2 of the EA. 

Parking 

 

Existing Parking Issues 

139. The EA should include a clear description of roads in the area that are affected by the 

existing parking and emergency access problems. 

Response: See Section 1.3 of the EA. 

140. Is the project going to propose measures to prevent or reduce the potential for illegal 

parking, use of unofficial trails, or creation of illegal trails? 

Response: The Cleveland National Forest does not have the legal authority to implement or enforce parking 

restrictions on County-maintained roads, and so has limited abilities to address potential issues of illegal 

parking. Only the County can restrict parking on County roads, and currently no parking restrictions apply 

to any of the roads near the SDRG or Saddleback Trailheads. As such, no potential issues of illegal parking 

currently exist. 

The creation of illegal trails will be addressed using wire fencing and other enforcement actions as 

necessary. Members of the public are free to access National Forest System lands as they wish unless they 

are otherwise closed by Forest Order. As such, use of social trails by the public is typically legal. 

141. Hikers who do not have visitor use permits but may be seeking access to the San Diego 

River Gorge or the local trail system may park at the trailheads that serve the project area. 

Response: Parking facilities at the SDRG Trailhead are available for use by any forest visitor on a firstcome, first-served basis. For further information see response to comment 127 and Appendix B to this 

document. 

142. The Cleveland National Forest completed a survey in the past to determine that 29 

parking spaces would be adequate for the SDRG Trail and Trailhead. In retrospect 29 parking 

spaces is not adequate to meet the interest of trail users. 

Response: The decision to develop 29 parking spaces at the San Diego River Gorge Trailhead was not 

explicitly made to meet all future demand for parking. Rather, this decision was made to move some 

parking off of County-maintained roads. Further, prior to the construction of the parking lot, forest visitors 

regularly parked on County-maintained roads in the San Diego Country Estates and additionally have 

consistently visited CCF since decades prior to the construction of the San Diego Country Estates. The San 
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Diego Country Estates was established and zoned by the County in 1975, long after members of the public 

had already established this area as an informal, albeit regular access point to CCF. 

143. Issues associated with parking and traffic in the neighborhood adjacent to the SDRG 

Trailhead go back to 2005, so using 2007 as the baseline condition is unacceptable. 

Response: It is a matter of opinion that using 2007 conditions as a baseline for this project is unacceptable. 

The Forest Service assumes that the visitor use permit system will reduce congestion in SDCE, though the 

Forest Service does not have the authority to manage parking or congestion on public roadways. It is the 

responsibility of the County to manage parking and congestion on public roadways in SDCE. 

 Proposed Parking Improvements 

144. The public scoping notice identifies an existing problem with parking at the Saddleback 

Trailhead, thus making it unsafe for vehicles to pass and rendering the road inaccessible for 

emergency vehicles. How will the project be designed to improved emergency access? Will 

parking be proposed to be prohibited or restricted on this road? If so, please describe the 

proposed mechanisms. 

Response: By managing the number of people allowed to access CCF each day via the proposed visitor use 

permit system, the Forest Service assumes that parking pressures at the Saddleback Trailhead will be 

relieved on many days. The Cleveland National Forest does not have the authority to establish parking 

restrictions at the Saddleback Trailhead along Eagle Peak Road because it is a County-maintained road. 

145. Any design for trail or parking improvements should include elements to discourage 

ongoing issues of off-road motorcycle use. 

Response: The initial proposal to develop trail or parking improvements was dropped prior to the 

publication of the draft EA. See response to comment 34 for additional information. 

146. New parking facilities should not be constructed at the Saddleback Trailhead because 

use at CCF is already too high. 

Response: See response to comment 34. 

 Parking, Other 

147. The Forest Service should construct a trailhead at the terminus of Ramona Oaks Road. 

Trailhead facilities at the end of Ramona Oaks Road would not impact neighboring residents, 

but would allow for much more overflow parking as compared to the current facilities. 

Response: The final EA has been updated to include a discussion of the alternative to construct a new

trailhead at the end of Ramona Oaks Road. For further information see Section 2.1.6 of the EA. 

Additionally it should be pointed out that while the construction of a new trailhead at the end of Ramona 

Oaks Road, approximately 1⁄2 mile from the SDRG Trailhead, may not impact SDCE residents that have 

thus far expressed concerns related to the SDRG Trailhead, this alternative would likely impact an entirely 

new set of stakeholders living adjacent to Ramona Oaks Road in SDCE. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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148. In 2005 a number of SDCE residents together recommended that the SDRG Trailhead 

be located at the end of Ramona Oaks Road. This alternative would reduce the length and 

elevation gain of the hike, would better accommodate visitor traffic than the streets 

surrounding the current trailhead, would allow for horse trailer access, would not be visible 

from most nearby residences, and has utilities available. Public input was not adequately 

considered in the decision to construct the SDRG Trailhead at the end of Thornbush Road. 

Response: This project was not designed to revisit the previous Forest Service decision to construct an 

official trailhead in the current location of the SDRG Trailhead, which for decades has historically been 

used by members of the public as an unofficial trailhead. The purpose of this project is rather to address a 

variety of issues resulting from a pattern of increasing public use at CCF. 

Given the challenging terrain off the end of Ramona Oaks Road it is likely that sustainable trail design that 

accommodates the contours of the land would result in a longer, not shorter hike. The perspectives of local 

residents were one among many other factors that led to the 2009 decision to construct the trailhead in its 

current location; the opinion of one individual or a group of individuals does not necessarily trump other 

factors or the input of other members of the public. See Section 2.1.6 of the EA for a brief treatment of the 

alternative to construct a new trailhead at the end of Ramona Oaks Road as part of this project. 

149. The draft EA should contain additional alternatives because the proposed action is the 

only viable alternative. The construction of a parking lot at the end of Ramona Oaks Road 

should be analyzed as an alternative in the EA. 

Response: The final EA has been updated to consider the construction of a trailhead and parking lot at the 

end of Ramona Oaks Road. For further discussion of this issue see Section 2.1.6 of the EA. The alternatives 

examined in detail are the only alternatives that have been identified thus far that would be feasible for the 

Forest Service to implement. 

150. A number of stakeholders, including individual members of a dialogue group convened 

by the Forest Service, recommended that the Forest Service construct a trailhead at the end of 

Ramona Oaks Road. The SDCE HOA verbally offered to grant a permanent easement to the 

Forest Service to construct this parking area. The Forest Service did not consider this 

alternative in the draft EA. 

Response: The final EA has been updated to consider the construction of a trailhead and parking lot at the 

end of Ramona Oaks Road. For further discussion of this issue see Section 2.1.6 of the EA. 

151. There is no official horse trailer parking in the vicinity of the SDRG Trailhead. Horse 

trailer parking should be developed at the end of Ramona Oaks Road and at the Saddleback 

Trailhead to allow for improved equestrian access to the San Diego River Gorge. The Forest 

Service is discriminating against equestrians by not proposing equestrian facilities at the end 

of Ramona Oaks Road, as was originally proposed as a part of this project in the Saddleback 

area. 

Response: The Forest Service does not provide facilities for all types of users in all locations, nor is the 

Cleveland National Forest proposing any construction in the vicinity of the SDRG Trailhead as part of this 

project. See Section 2.1.6 of the EA for an explanation as to why no facilities were proposed at the end of 

Ramona Oaks Road at this time. See Section 2.1.5 of the EA for an explanation as to why the proposal to 

develop parking facilities at the Saddleback Trailhead was dropped. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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152. The metric related to parking suggests that the Forest Service is attempting to increase 

the average level of parking on neighborhood roads to 50 motor vehicles per day. 

Response: The adaptive management metric related to parking presented in the draft EA was dropped 

because the Forest Service does not have the authority to manage or regulate parking or congestion on 

County roads. 

153. The draft EA states that the visitor use permit is not intended to prevent parking on 

County roads in the vicinity of the SDRG Trailhead. Yet, it also states that traffic on 

neighborhood streets places children and other residents at risk when they walk or ride 

bicycles in their neighborhoods. 

Response: Discussion of risk as it relates to traffic congestion in the draft EA refers to the extreme level of 

congestion observed in the spring of 2011, which was characterized by hundreds of cars in SDCE each day. 

Parking occurs daily on public roads across San Diego County, and in many locations throughout the 

County many hundreds of motor vehicles may park in a single neighborhood in one day. Section 1.4 of the 

EA explains that this project is intended to address a variety of issues associated with the extreme growth in 

use levels at CCF that have occurred in the past five years, including public safety. The Forest Service 

assumes that by managing public use of CCF, congestion in SDCE will be vastly reduced as compared to 

extreme levels observed in 2011. The Forest Service also does not believe that public use of County roads in 

SDCE places adjacent residents at undue risk more than in other comparable locations across the County. 

To elaborate further, the County of San Diego Public Road Standards defines Residential Cul-De-Sac roads 

as being designed to accommodate fewer than 400 average daily vehicular trips (Section 4, p. 16). 

Residential Loop roads less than 600 feet in length are designed to accommodate fewer than 200 average 

vehicular trips (Section 4, p. 16). The County of San Diego Public Road Standards states, “Loop roads in 

excess of 600 feet shall be constructed to residential or residential collector standards in accordance with 

projected average daily trips” (Section 4, p. 16). Residential and Residential Collector roads are designed to 

accommodate fewer than 1,500 and fewer than 4,500 daily trips, respectively (Section 4, p. 9).15 

According to Forest Service measurements on May 23, 2012, Thornbush Road is 1,270 feet in length.16

Thornbush Road forms a loop with Cathedral Way. If Thornbush Road is indeed considered to be a 

Residential Loop road it would have been designed according to County standards to accommodate fewer 

than 1,500 average daily trips at a minimum.17 Cathedral Way is 900 feet in length according to Forest 

Service measurements and forms a loop with Thornbush Road. It would therefore have been designed

according to County standards to accommodate fewer than 1,500 average daily trips at a minimum. 

Bellbottom Way, Cherish Way, and Love Lane are Cul-De-Sac roads, and so would have been designed 

according to County standards to accommodate fewer than 400 average daily trips. 

Given the allowable traffic volumes presented in the County of San Diego Public Road Standards, projected 

average traffic levels under the proposed action, detailed in Section 2.1.2.1 of the EA, will have minimal to 

no impact on the capacity of the roads adjacent to the SDRG Trailhead. In fact, the extreme levels of traffic 

observed in 2011 and described in Section 1.3 of the EA would also likely have not resulted in average daily 

 

15 The County of San Diego Public Road Standards can be found at http://www.sdcounty.ca.gov/dpw/docs/pbrdstds.pdf. 

16 For the sake of consistency measurements were made by GPS and using a distance measuring wheel. The distances measured 

by these respective devices were within three feet of one another. 

17 Thornbush Road would not be considered a Residential Cul-De-Sac Road because it exceeds 600 feet in length (Section 4, p. 

16). 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

72 

trips exceeding County design standards. Therefore, according to County standards projected traffic 

volumes associated with the proposed action will not place local residents at undue risk. 

It should also be noted that SDCE was established with minimal buffering next the National Forest System 

lands and preexisting recreational uses. It would have been the responsibility of County planners at the time 

that SDCE was established to foresee potential increases in recreational conflicts or uses on roadways 

adjacent to the long-term access point to CCF from Ramona. 

154. The draft EA does not identify how the project will relieve traffic and parking impacts 

to the SDCE neighborhood adjacent to the SDRG Trail. 

Response: Section 3.3.4 in the EA discusses how the Forest Service assumes that the proposed action will 

reduce use at CCF and therefore relieve congestion and parking issues in SDCE. See response to comment 

153 for further discussion of this issue. 

155. The Forest Service did not take into consideration future parking challenges and 

suggested that County roadways in the vicinity of the trailhead would handle the offsite 

parking needs of visitors. County roadways cannot provide adequate parking for these 

visitors, thus creating a significant, unmitigated impact to the environment on County 

facilities. The Forest Service must take responsibility for mitigation of future parking issues 

caused by the trail. 

Response: See response to comments 32, 46, and 153. Members of the public in San Diego County are 

entitled to park on County public roadways unless otherwise posted by the County. The Forest Service does 

not have the authority to manage parking on County roadways. Additionally, the Forest Service assumes 

that by managing public use at CCF, historic issues pertaining to parking in SDCE will improve. 

156. Beach communities routinely accommodate thousands of motor vehicles on summer 

days, resulting in heavy traffic and all available street parking being occupied. No law 

prohibits parking on public streets elsewhere, so the Forest Service should not limit parking on 

County roads adjacent to its trailhead. 

Response: The Forest Service does not have the authority to limit parking on County roads and is not 

proposing to do so. 

157. Why should residents of SDCE be subject to the burdens of Forest Service 

administrative decisions that allow parking on County roads? 

Response: The Forest Service does not have the authority to manage parking on County roads. Only the

County has the authority to restrict or prohibit parking on County roads and thus far the County has not 

elected to disallow parking on County roads in the vicinity of the SDRG Trailhead despite Forest Service 

suggestions to do so. 

158. Public parking on County roads should be a non-issue for the Forest Service. This is a 

City, County, and/or law enforcement issue. 

Response: See response to comments 153, 155, 156, and 157. 

Trails 
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159. The Cleveland National Forest should ensure that it manages litter and trash collection 

in order to maintain the visual qualities of CCF and the surrounding landscape. 

Response: The proposed adaptive management system that will determine visitor use levels at CCF is based 

on a baseline condition that is in part defined by the ability of the Cleveland National Forest to keep up with 

the management of litter in the visitor use permit area. For further information see Section 2.1.2.1 of the EA. 

160. The Cleveland National Forest should regularly pick up trash and conduct maintenance 

activities in the CCF area. 

Response: See response to comment 159. 

Roads 

161. The Cleveland National Forest should restore vehicular access to CCF via Eagle Peak 

Road (Trail). 

Response: The Cleveland National Forest has discussed the restoration of vehicular access along Eagle 

Peak Road (Trail) to improve law enforcement and emergency response capabilities. However, the County 

currently has jurisdiction over this portion of the Eagle Peak Road (Trail). Further, the restoration of this 

portion of the road would be extremely costly. The comment also does not address the purpose and need of 

the project. 

Corrections and Clarifications to the Draft EA 

162. The response to comment 54 in the draft EA (response to comment 80 in the EA) 

provides incorrect information with regard to the support of local residents, availability of an 

easement, and the location benefits of a trailhead at the end of Ramona Oaks Road.

Response: The response to comment 54 in the draft EA was updated in the final EA (see response to 

comment 80) to reflect more detailed information as to the 2009 decision to construct the SDRG Trailhead 

in its current location. 

163. Comments 33-37 in the draft EA (comments 54, 56, 57, and 58 in the EA) are not 

adequately addressed by referring to response to comment 32 (response to comment 53 in the 

EA). 

Response: The relevant responses have been updated in the EA to reflect additional detail. 

164. The word “managing” in the Summary of the draft EA should be changed to 

“prohibiting” alcohol consumption and cliff climbing. 

Response: This comment is largely a matter of semantics, though “managing” was changed to “prohibiting” 

in the summary of the EA. 

165. Response to comments 69 and 70 in the draft EA (response to comments 98 and 99 in 

the EA) do not address overnight camping as stated. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

74 

Response: Comment 69 in the draft EA does not mention overnight camping. Response to comment 70 in 

the draft EA (response to comment 99 in the EA) has been updated to address camping. 

166. The proposed trail from the Saddleback Trailhead to the Eagle Peak Preserve property 

will increase use to this area. 

Response: The Cleveland National Forest dropped from consideration the proposal to construct a trail 

connection between the Saddleback area and the Eagle Peak Preserve property prior to issuing the draft EA. 

See Section 2.1.5 of the EA for additional information. 

167. The discussion of the existing condition in the draft EA is not clear as to whether the 

baseline condition is represented by the current public closure or the several years preceding 

the closure. Based on the dates of the scoping notice and draft EA, as well as the descriptions of 

the alternatives, the current state of [temporary] closure should represent the baseline 

condition. In this case, the proposed action would likely result in significant impacts to the 

physical, biological, and social environments. 

Response: The baseline condition is represented by historic conditions and public use patterns at CCF, not 

conditions under temporary Forest Orders. Forest Orders expire one year or less after being issued. The 

dates of the scoping notices and draft EA are coincidental with respect to the current Orders in place at and 

around CCF. Additionally, these Orders were put into place precisely to provide a respite from baseline 

conditions so that the Forest Service could complete planning for the proposed action, including issuing a 

scoping notice, draft EA, and final EA. 

The proposed action directly addresses historic and ongoing public safety issues and environmental impacts 

in the project area by managing public use at CCF and tying future use levels at CCF to a baseline condition 

defined by the metrics presented in Section 2.1.2.1 of the EA. The project will not result in new impacts nor 

will it lead to an increase in historic levels of impact. Therefore, no significant impacts exist. 

168. Section 1.3 of the draft EA notes historic volumes of vehicles parked in the vicinity of 

the SDRG Trailhead is 200-300 per day and a maximum is assumed to be 730 per day. More 

information must be provided in order to properly evaluate this data. This information also 

raises the issue whether or not these volumes should be used as default values for calculations 

in the document. If so, the document should be revised to include this information and evaluate 

its significance. 

Response: The data cited in the above comment was collected by the San Diego County Traffic Advisory 

Committee, as cited in Section 1.3 of the EA and draft EA. This is the only known traffic volume data 

available at the SDRG Trailhead outside of ongoing, anecdotal Forest Service observations. These 

observations do roughly corroborate the data collected by the County Traffic Advisory Committee, which 

was used by the San Diego County Department of Transportation to authorize parking restrictions in SDCE, 

although to this date these parking restrictions have not been implemented. 

This data represents the baseline condition for this project given that it is presented in the “Existing 

Condition” section of the EA and draft EA. See response to comment 167 for further discussion of the 

concept of a baseline. The Forest Service assumes that by managing public use at CCF past patterns of 

congestion in SDCE as reflected in the discussion of baseline conditions in Section 1.3 of the EA will be 

reduced. Beyond representing the baseline condition in this project there is nothing significant known about 

this data. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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169. The visitation estimations in Section 1.3 of the draft EA note that on the busiest 

weekend day observed in 2011 an estimated 2,190 visitors accessed the SDRG Trailhead and 

Trail. An estimate of the “busiest weekend day” in the CCF area should include visitors 

coming from both trailheads. 

Response: Section 1.3 of the draft EA reads, “On the busiest weekend day observed in 2011 this estimate of 

average vehicle occupancy yields a figure of approximately 2,190 individuals accessing the SDRG Trail and 

Trailhead.” This statement does not purport to convey a visitation estimate for the greater CCF area. 

This being said, as stated in Section 1.3 of the EA and draft EA approximately 80 vehicles parked along 

Eagle Peak Road in the vicinity of the Saddleback Trailhead on a busy day in 2011. Using an average 

vehicle occupancy estimate of 3, this would yield approximately 240 additional visitors to CCF for an 

estimated busy day total of 2,430 visitors. 

170. Appendix C should include the dates for the scoping period. 

Response: The date of the scoping notice is listed in Section 1.6 of the EA and draft EA, titled “Public 

Involvement.” 

Miscellaneous and Outside the Scope 

171. The analysis should include figures and graphics of County-maintained roadways that 

are affected by the existing parking and emergency access problem. 

Response: Section 1.3 of the EA and draft EA list and describe the County roads that are affected by 

existing parking and emergency access problems. These roads are easily viewed on Google Maps or other 

mapping sites. Providing further detail on these roads in the form of figures and graphics is beyond the 

scope of this analysis. 

172. The Cleveland National Forest did not adequately forecast the impacts of the original 

developments to the SDRG Trail and Trailhead to the San Diego Country Estates

neighborhood. 

Response: This comment is outside the scope of this project. 

173. The Cleveland National Forest is not interested in adopting the recommendations from 

members of the community surrounding the SDRG Trailhead, and rather has an internally 

designed agenda that does not regard the community input it solicited. 

Response: The Cleveland National Forest takes and values all public input into account equally. As such, 

the public participation process is not a “vote,” and a given group of stakeholders does not have more 

influence in a project than any other group. For further information about the public participation process, 

see the “Comment Analysis and Response” description at the start of Appendix C. 

174. Parking prohibitions have been approved by the County of San Diego. If traffic 

stemming from visitation to the Cleveland National Forest impacts homeowners adjacent to 

the SDRG Trailhead, these prohibitions may be put into place. Parking prohibitions could 

relocate existing issues associated with parking to Ramona Oaks Road. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

76 

Response: The County of San Diego has full jurisdiction to manage parking issues on County-maintained 

roads. Further, it is the perspective of the Forest Service that has been communicated to the County that 

more comprehensive parking restrictions than those that have been proposed would directly address and 

may solve many of the issues outlined in Section 1.3 of the EA. 

175. A number of environmental concerns associated with visitation to Mildred Falls could 

be addressed by the installation of guard rails and signage to dictate the flow of foot traffic 

near CCF. 

Response: Issues associated with visitation to Mildred Falls are outside the scope of this project. 

176. The Cleveland National Forest should consider constructing new trails in the vicinity of 

the San Diego River to meet the public demand for access to free-flowing streams. 

Response: The Cleveland National Forest is seeking via this project only to manage recreational issues and 

demand at CCF, and is further not aware of high levels of public demand for access to other parts of the San 

Diego River Gorge. 

177. The Cleveland National Forest should not build a new road in the project area.

Response: The Cleveland National Forest is not proposing to build any new roads in the project area.

178. The closure of the area surrounding CCF should only be temporary. 

Response: The closure of the area surrounding CCF, which was initially implemented in July, 2011, was 

temporary. Access to CCF via the Saddleback Trailhead was restored on April 1, 2012. 

179. The SDRG Trail and Trailhead should be reopened promptly. The irresponsible acts of 

a small subset of visitors are impacting other, responsible recreationists who seek access to this 

area. 

Response: The Cleveland National Forest is currently working to balance access concerns with the 

challenges outlined in Sections 1.3 and 1.4 of the EA, and will reopen the SDRG Trail and Trailhead when 

these challenges can be managed. 

180. The Cleveland National Forest should require that visitors to CCF have an Adventure 

Pass. 

Response: The Forest Service does not have the legal authority to require that visitors display an Adventure 

Pass outside of Standard Amenity Fee Sites and High Impact Recreation Areas. The larger area around CCF 

does not currently have the amenities required to be classified as a Standard Amenity Fee Site or High 

Impact Recreation Area, and so the Cleveland National Forest is unable to require that visitors have an 

Adventure Pass to visit this area. 

181. The Cleveland National Forest should build a bridge across the San Diego River in the 

vicinity of CCF. 

Response: The Cleveland National Forest has analyzed potential resource impacts associated with 

recreation at CCF. The rock stepping stones currently placed in the San Diego River at its junction with the 
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77 

SDRG Trail are adequate to mitigate potential resource impacts associated with foot traffic through this 

area, and so the forest is not currently considering building a bridge across the San Diego River. 

182. If visitation levels at CCF regularly exceed 100 people at one time it will be necessary 

for the Cleveland National Forest to develop infrastructure improvements adjacent to CCF to 

accommodate this use. 

Response: The proposed adaptive management system defines a baseline condition based on a number of 

resource conditions. Potential impacts to the resource base, not the number of people visiting CCF, will 

determine the need for potential future management action. For further information about the proposed 

adaptive management system see Section 2.1.2.1 of the EA. 

183. Access to the project area should remain closed until the Cleveland National Forest is 

able to implement a new management system that manages public use of CCF. 

Response: Access to CCF via the Saddleback Trailhead was restored on April 1, 2012. Future decisions on 

access will be revisited as needed. 

184. The issues observed at CCF in recent years need to be addressed. However, instituting a 

visitor use permit system would be an unacceptable response to these issues. 

Response: This comment does not elaborate as to why the proposed visitor use permit system is 

unacceptable, nor does it offer any other ideas to address the issues observed at and around CCF in recent 

years. Further, the Forest Service believes that the proposed action is the best available tool to balance 

resource and social concerns with continued public access to this popular recreation destination. 

185. Eagle Peak Road (Trail) is a County road and therefore should be open to public offhighway vehicle use. 

Response: This comment is outside the scope of this project. 

186. A number of suggestions submitted during the scoping period were rejected using a 

variety of bureaucratic excuses, such as “no CFR authority,” “not required by law,” “not the 

responsibility of the Forest Service,” “prohibited to discriminate,” etc. 

Response: The Forest Service is required in planning and implementing projects to adhere to federal laws, 

agency policy, and Land Management Plan direction. 

187. Does the proposed action include the installation of an early warning sound alarm 

system for fires? 

Response: This comment is outside the scope of this project. Campfires are prohibited outside of fire rings 

in developed recreation sites across the Cleveland National Forest, and this project therefore does not 

address issues associated with campfires because they are already prohibited in the project area. 

188. The SDCE community is very concerned about the threat of wildfire. 

Response: See response to comment 98. 
Cedar Creek Falls Visitor Use Permit System Environmental Assessment 

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189. A home was recently broken into near the SDRG Trailhead. 

Response: This comment does not pertain to this project. Further, the SDRG Trailhead and Trail were 

closed at the time of this burglary. 

190. Impacts to residents near the SDRG Trailhead are adequately balanced by the benefits 

these residents enjoy due to their proximity to the improved trail system. 

Response: This statement is conjectural and is outside the scope of this project. 

191. Visitor use permits are not needed for the vast majority of day hikes on public lands, 

many of which are more impacted than the CCF area. Examples include Bright Angel Trail in 

Grand Canyon National Park, various hikes in Yosemite National Park, Angels Landing in 

Zion National Park, and various hikes in Joshua Tree National Park. 

Response: This comment is outside the scope of this project. 

192. The proposed action is over-reaching in its attempt to improve public safety. There are 

many places on public lands that are more dangerous than CCF. 

Response: This comment is outside the scope of this project. 

193. The sub-heading “Social Impacts” in Section 1.7 of the draft EA is incorrect because it 

diminishes the actual challenges faced by residents due to parking problems. This sub-heading 

should be changed to “Quality of Life Issues.” 

Response: This comment is a matter of semantics and is outside the scope of this project.

194. The 2009 “Initial Study” [Decision Memo] on the construction of the SDRG Trail and 

Trailhead highlighted a number of concerns expressed by SDCE residents and stated that the 

project would address these concerns. When the project was implemented, none of the 

concerns raised by local residents were addressed. In essence, all of the transportation and 

traffic findings in the initial study [Decision Memo] were wrong. 

Response: The 2009 Decision Memo on the construction of the SDRG Trail and Trailhead notes that some 

SDCE residents had expressed concerns regarding forest visitors parking on County roads. By constructing 

a parking lot this project directly addressed these concerns. It should additionally be noted that only the 

County can prohibit or restrict public parking on County roads. The Forest Service has neither the authority 

nor the obligation to prevent public use of and parking on County roads. 

The Decision Memo also notes that residents of SDCE had complained of trail users requesting to use 

bathroom facilities and to obtain drinking water. A restroom facility was constructed at the trailhead as a 

component of the 2009 project and the Forest Service continues to work with the Ramona Municipal Water 

District, San Diego County Water Authority, and the Metropolitan Water District of Southern California to 

address onerous local regulations related to the provision of potable water at the SDRG Trailhead, which is 

outside the jurisdictional boundary of these water authorities. 
Environmental Assessment Cedar Creek Falls Visitor Use Permit System 

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Beyond the concerns shared by SDCE residents, the construction of the SDRG Trail and Trailhead directly 

addressed a number of other resource and safety concerns. Concerns expressed by a specific interest group 

such as residents of SDCE do not necessarily take precedence over the concerns of other members of the 

public or those related to environmental impacts, health and safety, public access, or other issues. 

The 2009 Decision Memo predicted that following the construction of the SDRG Trail and Trailhead a 

limited amount of additional use of this site may occur as a result of the improvements. The improvements 

indeed may have attracted additional use, but it should be emphasized that public use at CCF and at other 

waterfalls across the Palomar Ranger District had grown exponentially due to factors unknown by the Forest 

Service in 2009 prior to the time the trail and trailhead were completed in 2011. As such, it is unlikely that 

the trail and trailhead improvements alone resulted in this extreme growth in public use at CCF because 

much of this growth in use occurred during the two years preceding the completion of the trail and trailhead 

project. 

195. Eagle Peak Road (Trail) should be rehabilitated to allow for ATV and Side by Side 

vehicle use. User conflicts would be addressed through the visitor use permit system. 

Response: This comment is outside the scope of this project. This being said, the area surrounding Eagle 

Peak Road (Trail), including the trail, is zoned in the Cleveland National Forest Land Management Plan as 

Backcountry Motorized Use Restricted. To open this trail to motorized use would directly contradict Land 

Management Plan direction. Further, allowing the use of motorized vehicles on a trail that is frequented by 

hikers, equestrians, and bicyclists would likely result in significant public safety concerns and user conflicts. 

It is not clear how the proposed visitor use permit system, as purported in the above comment, would 

address these issues.