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.


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.


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.


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?


[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.”]

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