October 2011 – Conservation Sense and Nonsense

Natural Areas Program violates San Francisco’s pesticide policy

As the deadline for written comments on the Draft Environmental Impact Report on the Natural Resource Areas Management Plan approaches (October 31, 2011), we are reprinting with permission a post from the Save Sutro website about the many violations of San Francisco’s pesticide policy by the Natural Areas Program.

Anyone with the time and patience to read the 600+ page EIR knows that it does not provide us with any information about the volume of pesticides used by the Natural Areas Program. Instead, it claims that the pesticides used by the Natural Areas Program will have no impact on the environment because they are following the rules; therefore, by definition there can be no negative impact on the environment. This seems a non-sequitur to us. But, even if we accepted this illogical premise, the fact is, they AREN’T following the rules. Save Sutro tells us about the many violations of the city’s pesticide policy by the so-called Natural Areas Program.

Details about how to submit your public comment by October 31 are provided at the end of this post.

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As we noted in our previous post, the San Francisco Natural Areas Program seems to be using increasing amounts of toxic pesticides. From time to time, we’ve posted information here about pesticide use in the Natural Areas Program (NAP) lands. Roundup, Garlon, Imazapyr in Glen Canyon, at Pine Lake, on Twin Peaks, Mt Davidson, in the Interior Greenbelt — usually with a photograph. (Search this site on any pesticide name to see other relevant posts.)

What our readers have pointed out to us is that many of these violate the rules of the San Francisco Department of the Environment (SF DoE). We really appreciate SF DoE regulating toxic pesticides. They’re our second line of defense, when the Environmental Protection Agency seems all too ready to approve first and question later (or not question later). But they can only be effective if their rules stick.

What do we mean, violations? Well, here are a few, all from 2009 and 2010. Were there others? We don’t know.

A BUNCH OF VIOLATIONS

Missing dates on notices. The signs for pesticide spraying are meant to warn people — both the NAP staff and the general public with their kids and pets — that toxic chemicals are in use in an area. It’s pretty well-designed; it requires the dates the application is planned, how it will be applied, and then when it’s been used and when it will be safe to go back in there. But as with every precaution from seat-belts to poison symbols, it only works if it’s used. From the time we started collecting notices (pictures, not the actual notices), we often found key data missing: the date and time of the actual application. That means it’s never clear when (or whether) the pesticides were used and whether it’s safe to re-enter.

Using pesticides before they’re approved. In 2009, when we published a photograph someone sent us of Imazapyr usage at Pine Lake in Stern Grove, other readers were surprised. How come? SF DoE hadn’t approved it for use, had it?

They hadn’t.

It’s been approved only in 2011, as a Tier II pesticide.

Using pesticides where they’re not approved. In November 2010, we saw a notice that said they were spraying Aquamaster (glyphosate, same active ingredient as Roundup) “near shoreline” of Lake Merced. The target plant was “ludwigia – aquatic weed.” Also known as water-primrose, this grows in the water and presumably that’s what they were after. Except… Lake Merced is red-legged frog habitat. Use there is restricted: “Note prohibition on use within buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” (Glyphosate is death on frogs.) This was a lot less than 60 feet.

Spraying when they shouldn’t be spraying. According to the SF DoE, here’s how Roundup should be used: “Spot application of areas inaccessible or too dangerous for hand methods, right of ways, utility access, or fire prevention…OK for renovations but
must put in place weed prevention measures. Note prohibition on use within
buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” But according to all the notices (and the records) they’ve been using a backpack sprayer.

Spraying Garlon without a respirator. The signs said Garlon. The SF DoE regs said that this Tier I pesticide was for “Use only for targeted treatments of high profile or highly invasive exotics via dabbing or injection. May use for targeted spraying only when dabbing or injection are not feasible, and only with use of a respirator. HIGH PRIORITY TO FIND ALTERNATIVE.” The person spraying wore a blue “space-suit” — but no respirator. (Don’t know who it was, whether a Parks employee or someone from contractor Shelterbelt. Whoever, please be careful. The regs are there for a reason.)

Poorly maintained data. Pesticide use is recorded, and again the records are pretty specific. The serial number of the use, and the date. The chemical used, its trade name and chemical name and its EPA number. Where it’s been applied, and what it’s targeting. Who applied it. Analyzing these records would give a pretty good idea of who’s using what, where and why. But… the records aren’t complete, or at least they don’t appear to be. We’ve found notices in the field with no corresponding database entry.

IMPLICATIONS FOR THE DEIR

We understand how these violations occur. We don’t attribute adverse motives to NAP; they’re not going through the books thinking, which rule shall we break today? Remembering all the restrictions, maintaining records and filling in signs is tedious, and it’s easy to forget in the press of work. Even NASA makes mistakes.

Still, the objective of the rules is to keep us all safer and reduce the use of toxins as far as possible. With good reason, we don’t think the NAP is able to comply.

As readers will be aware, the Draft Environmental Impact Report (DEIR) for the San Francisco Natural Areas Management Plan is now open for public comment. What the DEIR says is: “Pesticide and herbicide use in the Natural Areas would be in accordance with the SFRPD’s Integrated Pest Management (IPM) Program and San Francisco’s Integrated Pest Management Ordinance...”

Seriously? Can they even do it?

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[Edited to add:

For readers who are interested in commenting on the DEIR:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

“Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17 31, 2011. [Please note, the deadline has been extended.] Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”]

The toxic pesticides used by San Francisco’s Natural Areas Program

We are reprinting with permission an article from the Save Sutro website about the pesticides being used by San Francisco’s Natural Areas Program. The Save Sutro website is a valuable source of reliable information on any topic it covers, but it is especially knowledgeable about the pesticides being used in San Francisco.

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It’s no surprise that people are beginning to associate San Francisco’s Natural Areas Program with pesticides. It’s been using them (if the city’s records are accurate) at an increasing rate.

In 2009, it applied Garlon 16 times; in 2010, it was 36 times.
It applied Roundup (or Aquamaster, also glyphosate) only 7 times in 2009, but 42 times in 2010.

The Draft Environmental Impact Report (DEIR) on the SF Natural Areas Program is rather coy about pesticides. It doesn’t say how much it’ll use, just that it will follow all the rules when using them. (They actually have a poor track record there, but we’ll go into that in another post. [Edited to Add: We did.]) Today, we want to talk about the pesticides on their list: Roundup or Aquamaster (glyphosate); Garlon (triclopyr); Polaris (imazapyr); Milestone (aminopyralid).

SF’s Dept of the Environment classifies all of these as Tier I (Most Hazardous) or Tier II (Hazardous). There’s no mention of using any Tier III (Least Hazardous) chemicals.

ROUNDUP or AQUAMASTER (Glyphosate)

We’ve talked before of Roundup, a Tier II pesticide. We hope that in view of the new research that has been surfacing, SF’s DoE will revisit that classification and consider if it deserves a Tier I rating.

heart breaking

It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).
Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

Classified as Tier I, Garlon is even more hazardous than Roundup. In 2010, NAP used this pesticide 36 times (sometimes in combination with Roundup, which it has said it will no longer do). We’ve written about Garlon before, Garlon in our Watershed — which has more details — and many times since then. In brief, these are the main issues:

Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
Rat and dog studies showed damage to the kidneys, the liver, and the blood.
About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, it’s absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
Garlon can persist in dead vegetation for up to two years.

The DEIR has said that the SF NAP’s phasing out Garlon. We have some doubts; its tree-felling program will be futile without Garlon to prevent re-sprouts.

POLARIS, HABITAT (Imazapyr)

This is a very new pesticide, and not much is known about it — except that it’s very persistent. SF’s DoE has recently approved it for use as a Tier II hazard. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment. We’ve written about this one, too, when NAP recently started using it on Twin Peaks and Glen Canyon. (Actually, NAP had started using it prior to SF DoE’s approval , in Stern Grove and also at Lake Merced in 2009 and some unspecified NAP area in 2008.)

About its impact on people, we wrote: “it can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”

It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001.

MILESTONE (Aminopyralid)

Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. While the DEIR lists this as a chemical used by the NAP, they actually used Milestone very little (twice in 2010). Fortunately. SF DoE classifies it as Tier I, Most Hazardous. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.

Nevertheless, after an outcry and problems, Dow AgroSciences has stopped selling Milestone in the UK until it’s figured out.

Note to NAP and SFRPD: Don’t put clippings treated with Milestone in the green bin!

PESTICIDE CONSPIRACY THEORIES

When we first started researching pesticide use in “Natural Areas” (and shocking a lot of people who’d assumed “Natural” meant natural), conspiracy theories arose: The chemicals companies were subverting the decision-makers; Pesticides were being portrayed as ecological, and the marketing machine was convincing them; Maybe there were even payoffs!

We think the explanation is much simpler: Those in charge of the Natural Areas are being asked to do the impossible. They’re given a large area, (ETA: it’s as big as Golden Gate Park but in 32 separate locations) in the middle of a city where conditions don’t even approximate those of the pre-industrial era, and asked to return it to a specific moment in time.

It doesn’t want to go.

WHY NATURAL AREAS FIGHT BACK

Someone described the effort to “restore” the “Natural Areas” to “Native plants” as a constant battle. It is, and here’s why:

Stopping natural succession. Some areas are harder than others. Grasslands want to grow shrubs, native or not. Then, in pre-industrial San Francisco, along would come ~~grazing~~ browsing animals, or lightning strikes, or a landslide or two, and the shrubs would lose and the grass would win. Preserving grasslands requires killing the shrubs, and in the absence of animals and fires and landslides, it’s pesticides. Repeatedly.

Battling successful plants. And then there are the plants that do want to grow there, that grow there naturally (even if, like many San Franciscans, they’re not from here). These we call invasive, and want to get rid of them. That’s more pesticides. And since the plants are good at what they do, they have to be strong pesticides. Repeatedly.

“Invaders” compete with each other. Even if the pesticides clear an area of one kind of “invasive” plant, unless the space is intensively gardened, it’ll be taken over by other “invaders.” More pesticides.

The bison in the room (it’s native, unlike the elephant) is this: Contrary to the belief that Native Plants are so adapted to a particular place that “restorations” can be achieved merely by eradicating unwanted plants — Native Plant gardens need the same kind of maintenance and care as any garden.

Without the Sutro Stewards’ volunteers working there every month or so, the Native Garden on top of Mount Sutro would revert to its natural state: a mix of native and introduced plants. (No pesticides are used in that area, or indeed anywhere on UCSF’s Mount Sutro space. It may be the last pesticide-free wild area in San Francisco.)

Is the Natural Areas Program, as it’s currently managed, worth it? We think not, because of:

the ongoing and growing need for toxic herbicides;
the destruction of habitat for insects, birds and animals that rely on it (and this includes native species, most of which have adapted to introduced plants);
we think it’s an expensive misdirected effort in terms of time and treasure.

It makes sense to define small areas as Native Gardens, focus on those, and make them succeed. That can be done — as the Native Garden on Mount Sutro proves — without toxic chemicals.

Professor Arthur Shapiro’s comment on the Environmental Impact Report for the Natural Areas Program

Mission Blue butterfly — Mission blue butterfly Wikimedia Commons

With permission and in its entirety we are publishing the comment of Arthur M. Shapiro. He is Distinguished Professor of Evolution and Ecology at UC Davis and a renowned expert on the butterflies of California. We hope that you will take his credentials into consideration as you read his opinion of native plant restorations in general and the Natural Areas Program in San Francisco in particular. We hope that Professor Shapiro’s comment will inspire you to write your own comment by the deadline, which has been extended to October 31, 2011. Details about how to submit your comment are available here.

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October 6, 2011

Mr. Bill Wycko

San Francisco Planning Department

Re: DRAFT EIR, NATURAL AREAS PROGRAM

Dear Mr. Wycko:

Consistent with the policy of the University of California, I wish to state at the outset that the opinions stated in this letter are my own and should not be construed as being those of the Regents, the University of California, or any administrative entity thereof. My affiliation is presented for purposes of identification only. However, my academic qualifications are relevant to what I am about to say. I am a professional ecologist (B.A. University of Pennsylvania, Ph.D. Cornell University) and have been on the faculty of U.C. Davis since 1971, where I have taught General Ecology, Evolutionary Ecology, Community Ecology, Philosophy of Biology, Biogeography, Tropical Ecology, Paleoecology, Global Change, Chemical Ecology, and Principles of Systematics. I have trained some 15 Ph.D.s, many of whom are now tenured faculty at institutions including the University of Massachusetts, University of Tennessee, University of Nevada-Reno, Texas State University, and Long Beach State University, and some of whom are now in government agencies or in private consulting or industry. I am an or the author of some 350 scientific publications and reviews. The point is that I do have the bona fides to say what I am about to say.

At a time when public funds are exceedingly scarce and strict prioritization is mandatory, I am frankly appalled that San Francisco is considering major expenditures directed toward so-called “restoration ecology.” “Restoration ecology” is a euphemism for a kind of gardening informed by an almost cultish veneration of the “native” and abhorrence of the naturalized, which is commonly characterized as “invasive.” Let me make this clear: neither “restoration” nor conservation can be mandated by science—only informed by it. The decision of what actions to take may be motivated by many things, including politics, esthetics, economics and even religion, but it cannot be science-driven.

In the case of “restoration ecology,” the goal is the creation of a simulacrum of what is believed to have been present at some (essentially arbitrary) point in the past. I say a simulacrum, because almost always there are no studies of what was actually there from a functional standpoint; usually there are no studies at all beyond the merely (and superficially) descriptive. Whatever the reason for desiring to create such a simulacrum, it must be recognized that it is just as much a garden as any home rock garden and will almost never be capable of being self-sustaining without constant maintenance; it is not going to be a “natural,” self-regulating ecosystem. The reason for that is that the ground rules today are not those that obtained when the prototype is thought to have existed. The context has changed; the climate has changed; the pool of potential colonizing species has changed, often drastically. Attempts to “restore” prairie in the upper Midwest in the face of European Blackthorn invasion have proven Sisyphean. And they are the norm, not the exception.

The creation of small, easily managed, and educational simulacra of presumed pre-European vegetation on San Francisco public lands is a thoroughly worthwhile and, to me, desirable project. Wholesale habitat conversion is not.

A significant reaction against the excesses of the “native plant movement” is setting up within the profession of ecology, and there has been a recent spate of articles arguing that hostility to “invasives” has gone too far—that many exotic species are providing valuable ecological services and that, as in cases I have studied and published on, in the altered context of our so-called “Anthropocene Epoch” such services are not merely valuable but essential. This is a letter, not a monograph, but I would be glad to expand on this point if asked to do so.

I am an evolutionary ecologist, housed in a Department of Evolution and Ecology. The two should be joined at the proverbial hip. Existing ecological communities are freeze-frames from a very long movie. They have not existed for eternity, and many have existed only a few thousand years. There is nothing intrinsically sacred about interspecific associations. Ecological change is the norm, not the exception. Species and communities come and go. The ideology (or is it faith?) that informs “restoration ecology” basically seeks to deny evolution and prohibit change. But change will happen in any case, and it is foolish to squander scarce resources in pursuit of what are ideological, not scientific, goals with no practical benefit to anyone and only psychological “benefits” to their adherents.

If that were the only argument, perhaps it could be rebutted effectively. But the proposed wholesale habitat conversion advocated here does serious harm, both locally (in terms of community enjoyment of public resources) and globally (in terms of carbon balance-urban forests sequester lots of carbon; artificial grasslands do not). At both levels, wholesale tree removal, except for reasons of public safety, is sheer folly. Aging, decrepit, unstable Monterey Pines and Monterey Cypresses are unquestionably a potential hazard. Removing them for that reason is a very different matter from removing them to actualize someone’s dream of a pristine San Francisco (that probably never existed).

Sociologists and social psychologists talk about the “idealization of the underclass,” the “noble savage” concept, and other terms referring to the guilt-driven self-hatred that infects many members of society. Feeling the moral onus of consumption and luxury, people idolize that which they conceive as pure and untainted. That may be a helpful personal catharsis. It is not a basis for public policy.

Many years ago I co-hosted John Harper, a distinguished British plant ecologist, on his visit to Davis. We took him on a field trip up I-80. On the way up several students began apologizing for the extent to which the Valley and foothill landscapes were dominated by naturalized exotic weeds, mainly Mediterranean annual grasses. Finally Harper couldn’t take it any more. “Why do you insist on treating this as a calamity, rather than a vast evolutionary opportunity?” he asked. Those of us who know the detailed history of vegetation for the past few million years—particularly since the end of Pleistocene glaciation—understand this. “Restoration ecology” is plowing the sea.

Get real.

Sincerely,

Arthur M. Shapiro

Distinguished Professor of Evolution and Ecology

Fabricating “facts” to support native plant restorations.

We have been debating with native plant advocates for a long time, so we’re never surprised when they repeat vague generalities to support their ideology. But when these fabricated “facts” are repeated in legal documents such as the Draft Environmental Impact Report (EIR) for the Natural Areas Program (NAP) we must admit that we’re shocked! Apparently, the highly paid professionals who write such documents don’t expect the public to actually read the references they cite to support the statements they fabricate. We will take our readers on a tour of some of the phony “science” used to defend the destruction of San Francisco’s urban forest in order to restore native grassland and scrub to San Francisco’s urban parks.

Why is carbon storage such an issue in this debate about the Natural Areas Program?

The urban forest of San Francisco stores 196,000 tons of carbon and adds to that accumulated store of carbon at an annual rate of 5,200 tons per year according to the US Forest Service survey. About 25% of the annual rate of sequestration and the accumulated storage of carbon are accomplished by the blue gum eucalyptus, the chief target for destruction by NAP’s plans. When a tree is destroyed, it releases the carbon that has accumulated throughout its lifetime into the atmosphere as Carbon Dioxide as it decays. Carbon Dioxide is the predominant greenhouse gas that is causing climate change.

Carbon storage by tree species, San Francisco. US Forest Service

Since greenhouse gases are regulated in California by a law that commits the state to reduce greenhouse gas emissions, the Environmental Impact Report (EIR) for the Natural Areas Program (NAP) goes to great lengths to make the case that destroying thousands of trees will not violate California law. Here are just a few of the “facts” fabricated by the EIR to convince the public that NAP’s plans to convert San Francisco’s urban forest into grassland and scrub will not harm the environment.

Grassland in the San Francisco Bay Area does NOT lower ground temperature

The EIR claims:

“According to a study presented at the American Geophysical Union’s meeting, grasslands above 50 degrees latitude reflect more sun than forest canopies, thereby keeping temperatures lower by an average of 0.8 degree Celsuis.” ( EIR, page 457, cited source(1))

This statement in the EIR does not apply to the San Francisco Bay Area and the reference used to support it misrepresents the cited study:

The entire continental United States, including the San Francisco Bay Area, is below 50 degrees latitude. In other words, this statement—even if it were true—does not apply to the San Francisco Bay Area.
The statement is taken out of the context of the article. The entire sentence in which this statement appears actually says, “Grassland or snowfields, however, reflected more sun, keeping temperatures lower. Planting trees above 50 degrees latitude, such as in Siberia, could cover tundras normally blanketed in heat-reflecting snow.” It does not snow in the San Francisco Bay Area. Therefore, this statement does not apply to the San Francisco Bay Area.
The article being quoted by the EIR is NOT the scientific study, but rather a journalistic article in The Guardian, a newspaper in England, in which the author of the study has been misquoted and his study misrepresented.
The day after this article appeared in The Guardian (and also in the New York Times), The Guardian published an op-ed (which also appeared in the New York Times) by the author of the scientific study, Ken Caldeira in which he objected to the misrepresentation of his study:

“I was aghast to see our study reported under the headline “Planting trees to save planet is pointless, say ecologists.” (December 15). Indeed, our study found that preserving and restoring tropical forests is doubly important, as they cool the earth both by removing the greenhouse gas carbon dioxide from the atmosphere and by helping produce cooling clouds. We did find that preserving and restoring forests outside the tropics does little or nothing to help slow climate change, but nevertheless these forests are a critical component of Earth’s biosphere and great urgency should be placed on preserving them.”(2) (emphasis added)

As if this misrepresentation of the facts weren’t bad enough, we find in Appendix A of the EIR that this isn’t the first time that someone has informed the authors of the EIR that this statement is not accurate. One of the public comments submitted in 2009 in response to the Initial Study quotes Ken Caldeira’s op-ed in the New York Times. Yet, two years later, the author of the EIR persists in repeating this misrepresentation of Professor Caldeira’s (Stanford University) research. One wonders if the public comments were even read, judging by the repetition of the pseudoscience in the Initial Study that the public commented on in the first round. It seems that the “public process” is merely going through the motions.

Grassland does NOT store more carbon than forests

The EIR also claims:

“Research studies have concluded that grassland and scrub habitat could act as a significant carbon sink.” (page 457, cited studies(3))

Once again, the cited study does not support the statement in the EIR:

Again, the statement has been taken out of context. The entire sentence reads, “We conclude that grasslands can act as a significant carbon sink with the implementation of improved management.” This sentence appears in the abstract for the publication.(4)
One wonders if the authors of the EIR read the entire article or just the abstract. The point of the study is that land management techniques such as fertilization, irrigation, introduction of earthworms, plowing and fallow techniques, etc., can improve the sequestration of carbon in the soil of croplands and pastures. This study is obviously irrelevant to the Natural Areas Program, which is not engaged in agriculture or pasturage and will not use any of these techniques.
However, the study is relevant in one regard. It reports that when forest is converted to grassland, no amount of “management techniques” compensates for the loss of the carbon in the trees that are destroyed:

“Though more than half of the rain forest conversion studies (60%) resulted in increased soil Carbon content, net ecosystem Carbon balance…decreased substantially due to the loss of large amounts of biomass carbon.”

The second study cited in support of the claim about carbon storage in grassland reports that increased levels of Carbon Dioxide in the air increases carbon accumulation in the soil. This study tells us nothing about the relative merits of grassland and forests with respect to carbon storage. Another study reports a similar relationship between global warming and carbon storage in trees: “…warmer temperatures stimulate the gain of carbon stored in trees as woody tissue, partially offsetting the soil carbon loss to the atmosphere.” (5)

A pointless debate that misses the point

The misuse of these studies illustrates one of the fundamental issues with this pointless debate about the relative merits of grassland and forests. Even if grassland were superior to forests with respect to carbon storage—and it’s NOT—it would never compensate for the loss of carbon associated with destroying a forest that is storing hundreds of thousands of tons of carbon. The merits of planting trees where none presently exist is a fundamentally different argument than the merits of destroying trees. The trees are here now. No amount of grassland will compensate for the loss of the carbon presently stored by the forest that native plant advocates demand be destroyed.

If there is a sound argument for destroying trees, this isn’t it. Grassland does not store more carbon than trees and will never compensate for the loss of the tons of carbon released into the atmosphere when trees are destroyed. (Please visit our post “Facts about carbon storage do not support assumptions of native plant advocates”) Native plant advocates would be wise to abandon this particular line of unreasoning.

Although we are not scientists, we read the work of scientists. The studies conducted by scientists are not theoretical speculations about the benefits of one plant compared to another. Rather they report the results of controlled experiments, such as actually measuring the amount of carbon in the plant and/or soil and reporting the results of those experiments. Native plant advocates would be wise to spend less time trading baseless generalizations amongst themselves and spend more time reading the scientific reports of actual evidence.

Please comment on the Draft Environmental Impact Report for the Natural Areas Program

Please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks. There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*. Here are the details about the public’s opportunities to comment on the EIR for the Natural Areas Program:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

“Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17, 2011*. Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

*[ETA: The deadline for written comments has been extended to October 31, 2011 at the request of the Planning Commission.]

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”

(1) Jha, Alok. The Guardian. “Planting Trees to Save Planet is Pointless, Say Ecologists.” Friday, December 15, 2006.

(2) Caldeira, Ken, “Planting trees is far from pointless.” The Guardian, December 16, 2006.

(3) Conant, L., Paustian K, and Elliot E. 2001. “Grassland Management and Conversion into Grassland Effects on Soil Carbon.” Natural Resource Ecology Laboratory. Colorado State University. Fort Collins, USA. Sponsor: US Environmental Protection Agency, Ruminant Livestock Efficiency Program. 2001, and

Hu, S., Chapin, Firestone, Field, Chiariello. 2001. “Nitrogen limitation of microbial decomposition in a grassland under elevated C02,” Nature 409: 188-191.

(4) Conant, Paustian, Elliott, “Grassland Management and Conversion into Grassland Effects on Soil Carbon,” Ecological Applications, 11 (2) 2001, 341-355.

(5) Melillo, J., Butler, S., Johnson, J., Mohan, J., Steudler, P., Lux, H., Burrows, E., Bowles, F., Smith, R., Scott, L., Vario, C., Hill, T., Burton, A., Zhouj, Y, and Tang, J. Soil warming carbon-nitrogen interactions and carbon-nitrogen budgets. PNAS, May 23, 2011