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FEMA sees through the smokescreen

September 24, 2010
The Federal Emergency Management Agency (FEMA) has seen through the smokescreen that native plant advocates have created as a pretext for destroying non-native trees in the San Francisco Bay Area.  Native plant advocates claim that destroying non-native trees will reduce fire hazard.  As taxpayers, and as fans of all trees, we commend FEMA for preserving their limited resources for legitimate disaster mitigation.
 
In February 2010, UC San Francisco (UCSF) announced that it had withdrawn its application for FEMA funding to destroy most of the eucalypts on 14 acres of the Sutro Forest.  When making that announcement UCSF explained that FEMA would require a comprehensive Environmental Impact Study before the grant would be awarded which would result in a two-year delay in the implementation of the project.  UCSF preferred to pay for the project with its own funds rather than delay it during the environmental review.  Therefore, UCSF withdrew its application for FEMA funding.  Since then, UCSF has proceeded with its plans, expanding them to 40 acres, and continues to claim that there is extreme fire hazard in the Sutro Forest which it claims will be mitigated by the project.

Sutro Forest on a typically foggy day in late summer. Courtesy SaveSutro.wordpress.com

We now know there is more to the story than is revealed by UCSF’s announcement.  The neighbors of the Sutro Forest who have been trying to save their forest for over a year, have since obtained correspondence from FEMA regarding UCSF’s grant applications through a public records request.    The correspondence with FEMA indicates that:

  • UCSF misrepresented and exaggerated the fire hazard on Mount Sutro by rating it as “extreme.”  FEMA confirmed with the state’s fire authority that fire hazard on Mount Sutro is moderate, CAL Fire’s lowest rating of fire hazard.  (1) 
  • FEMA asked UCSF to explain how fire hazard would be reduced by eliminating most of the existing forest, given that: (2)
    • Reducing moisture on the forest floor by eliminating the tall trees that condense the fog from the air could increase the potential for ignition, and
    • Eliminating the windbreak that the tall trees provide has the potential to enable a wind-driven fire to sweep through the forest unobstructed.
  • FEMA asked UCSF to consider alternatives to its project, which would have the potential to mitigate fire hazard to the built environment by creating defensible space around buildings, structural retrofits, and vegetation management projects. (3)

UCSF has elected to ignore this advice from FEMA, choosing instead to proceed with its project as originally designed using  its own funds at a time of extreme budgetary limitations.  Clearly this is an indication that fire hazard mitigation is not the purpose of their project.  UCSF chooses to increase fire hazard rather than reduce it, putting themselves and their neighbors at risk.

FEMA is now engaged in a comprehensive Environment Impact Study of four similar projects in the East Bay hills that propose to destroy hundreds of thousands of trees.  The applicants are UC Berkeley, the City of Oakland, and East Bay Regional Park District.  Fire hazard in the East Bay is greater than in San Francisco because the summer is hotter, the frequency of Diablo winds is greater, and there are rare deep freezes that cause some non-natives to die back, creating dead leaf litter on the forest floor.  However, the remaining issues are the same as those on Mount Sutro: 

  • The loss of tall trees will reduce moisture on the forest floor and eliminate the shade that maintains that moisture.  The remaining native landscape will be predominantly grassland studded with scrub, chaparral, and short native trees in sheltered ravines.  This will be a flammable landscape, not less flammable than the existing landscape.
  • The loss of the windbreak provided by the tall trees will enable a wind-driven fire to travel unhindered through the community.
  • The projects in the East Bay hills do not provide defensible space around homes, which would reduce fire hazard to homes and those who live in them, the stated purpose of FEMA grants.

We hope that FEMA will see the similarity between the East Bay projects and those in San Francisco and advise the applicants in the East Bay to revise their projects so that they are appropriately aimed at creating defensible space around homes.  Destroying hundreds of thousands of trees will not make us safer.  In fact, it is likely to increase the risk of wildfire.

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Sources:

(1) Excerpt from FEMA’s letter of October 1, 2009, regarding UCSF’s grant applications:

“In its response to provide a clarification of the wildfire hazard, UCSF inaccurately interprets a map, provides inadequate details regarding the history of wildfires in the Sutro Forest, and provides a simplistic and ineffective comparison of the wildfire hazard in the Sutro Forest to the hazard in other areas that have burned in the San Francisco Bay Area…The 2007 FHSZ [Fire Hazard Severity Zones] map shows the Sutro Forest to have a “Moderate” wildfire hazard in the 2007 FHSZ maps.  “Moderate” is the lowest of the three fire hazard severity zones…”

(2) Excerpt from FEMA’s letter of October 1, 2009, regarding UCSF’s grant applications:

“Commenters argue that the proposed projects would increase wildfire hazard by removing some of the material that collects fog drip and keeps the forest moist and resistant to ignition and fire, thus allowing the forest to dry out more easily and increase the relative hazard for ignition.  Can UCSF specifically address this comment and describe how overall forest moisture content will change after implementation of the proposed projects?  Please provide scientific evidence to support any claims.”

“Additionally, several of these unsolicited public comments have stated that the proposed projects could result in changed wind patterns on Mount Sutro which could also increase the wildfire hazard in the forest.  New wind patterns could reduce biomass moisture as well as reduce the effective windbreak created by the current forest.  These comments argue that the effective windbreak created by the existing forest limits the potential for wildfire spread in the forest and the immediately surrounding area.  As UCSF has stated, winds are a contributing factor in wildfires.  Provide a citable and logical defense regarding how the proposed projects, and the resulting changes in wind patterns, would not result in an increase in the wildfire hazard in the Sutro Forest.”

(3) “Assuming that UCSF has been able to establish a clear need for wildfire mitigation activities, UCSF must conduct a more thorough analysis to identify alternatives to the proposed projects that could mitigate wildfire hazard in the Sutro Forest to the vulnerable built environment.  These alternatives must be technically, economically, and legally practical and feasible and can include activities not eligible for FEMA grant funding.  As described in FEMA’s Wildfire Mitigation Policy…wildfire mitigation grants are available for defensible space, structural retrofit, and vegetation reduction projects.  It would seem reasonable that alternatives to the proposed projects could include defensible space or retrofit projects.”    (emphasis added)

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