EHL and its allies submitted comments on the environmental document prepared by the Federal Bureau of Investigation (FBI) for its bid to take over the El Toro Conservation Area in Orange County.


A forgotten gem was uncovered in 1995, when a 900-acre corner of the former Marine Corps Air Station El Toro was found to have rare, low elevation coastal sage scrub with astonishingly high densities of coastal cactus wrens and federally listed California gnatcatchers. The land is also a wildlife corridor, and its grasslands are important for burrowing owl and vernal pool restoration. The Orange County Central-Coastal NCCP/HCP Implementing Agreement called for the US Fish and Wildlife Service (FWS) to bring this biologically irreplaceable federal land – termed the El Toro Conservation Area – into the reserve system. The Federal Aviation Administration (FAA) became temporary steward of the land.

Despite concerted effort by EHL and others, however, the FWS abandoned this commitment to its own HCP. The land is now set to be transferred from the FAA to the FBI for law enforcement training. An “Environmental Assessment” prepared for the transfer states there will be no change in use. However, contrary to its signed Use Agreements, the FBI has already expanded training operations compared to the limited uses authorized by the NCCP/HCP, claiming an area of 200 acres compared to the actually authorized 20 acres. And past FBI plans have shown major rifle range expansions, violating the core principles of reserve design.

EHL, other conservation groups, and the City of Irvine submitted extensive comments on the legal inadequacy of the Environmental Assessment and requested a full Environmental Impact Study. Very importantly, though, the City of Irvine also called for a Memorandum of Understanding with the FBI to establish use areas compatible with the NCCP/HCP and for joint management. Thus far, the FBI has rejected this constructive initiative, further breaking with the long-standing federal commitments. EHL fully supports the City in its efforts to protect the NCCP and to reach an accommodation with the FBI.