Open letter to Nature in the City

Latest Pesticide Application Notice, Glen Park, March 3, 2012

Nature in the City (NIC) is one of the non-profit organizations in San Francisco that supports native plant “restoration” projects in our public lands, especially the Natural Areas Program (NAP) in the Recreation and Park Department.  We recently published a response to a NIC newsletter which described critics of NAP as “a handful of people” and accused them of “misrepresenting” NAP’s plans for San Francisco’s parks.  In their most recent newsletter they seem to have changed their tune.  This suggests they are starting to take criticism of NAP more seriously.  But does it suggest any change in actions or plans?  With this open letter, we will ask Nature in the City for clarification.

Here is NIC’s latest attempt to communicate with NAP critics or discredit them.  We don’t know which.

Restore to 1769 or to Now?!

I often hear the question, “to what year do you restore?” Some folks are skeptical about ecological restoration since, of course, we can’t turn back the clock!

Some skeptics sardonically say, “are you going back to the ice age, pre-last glacial maximum (22,000 BP)? Well, then, Monterey Pine are native…”

In fact, the answer I give is that we restore to now. Ecological restoration, like all human activities, has a social and environmental context, which is historical indeed, but also very current. And restoration is about healing and looking toward a brighter future, not looking back into the abyss of ecological destruction. Thus, we Spring Forward, taking into account current conditions, constraints, as well as opportunities.

We document historical ecology; are blessed with knowledge of and from a recent and current indigenous cultural context; and study nearby ecological reference sites. Meanwhile, we have laws, recent history, and communities that present a unique local context in every case. Wildlife habitat now takes diverse forms, including in the human-dominated landscape.

If restoring integrity and biodiversity are always the goals, the specifics can vary widely. And this is just fine, because restoration should be a community-driven, democratic process, like every other human endeavor.
-Peter Brastow


Open Letter to Nature in the City:

We are writing to request clarification of your newsletter of March 8, 2012. 

What does it mean to “restore to now?”  If we are satisfied with our parks now, why do they need to be restored?  Isn’t that a contradiction?  If not, what—if anything—does that mean? 

Why is it necessary to “heal” a park that we don’t think is in “the abyss of destruction?”  What if we think that spraying our parks with gallons of pesticides is sending us into “the abyss of destruction?”  Is there a “brighter future” in spraying places called “natural areas” with pesticides 86 times in one year? 

What does it mean to “restore integrity and biodiversity?”  If biodiversity is the goal of the Natural Areas Program why are they eradicating non-native species, thereby reducing biodiversity?  As for “integrity,” we assume NIC means in the sense of “unimpaired.”  But we don’t consider our parks impaired, so we aren’t concerned about their “integrity.” 

Talking out of both sides of your mouth

The tone of the latest NIC newsletter is definitely an improvement over the previous accusatory tone.  However, it isn’t comprehensible, nor is it credible because it is contradicted by the words and actions of NIC.  Here are a few phrases from NIC’s public comment on the Draft Environmental Impact Review (DEIR) of the Natural Areas Program:

“…the analysis [of the DEIR] neglects to fully address the long-term impact of invasive plants from the retention of invasive weed-nurturing eucalyptus groves in the MA-3 areas.”

In other words, NIC wants all the eucalypts destroyed in all of the acres of “natural areas.”  Expanding tree removals into the lowest-priority management areas (MA-3) would increase the number of tree removals substantially.  MA-3 acres are 42% of the total acres of “natural areas.”  The management plan currently prohibits removal of healthy trees in MA-3 acres. 

The DEIR reports that the Maximum Restoration Alternative would have the most impact on the environment.  NIC says in its written public comment on the DEIR that this judgment “may be…a misinterpretation of the intent of CEQA.”  Peter Brastow, Founding Director of NIC, said during his public testimony to the Planning Commission on October 6, 2011, that the Maximum Restoration Alternative should be designated as the environmentally superior alternative in the final version of the Environmental Impact Report.  The Maximum Restoration Alternative would expand all the destructive activities of NAP into all 1,107 acres of “natural areas:” tree removals, eradication of non-native plants, reintroduction of legally protected species, recreational access restrictions, etc. 

But Mr. Brastow is not satisfied with maximizing native plant restorations in San Francisco’s parks.  In his public comment for the revision of the Recreation, Open Space Element (ROSE) of San Francisco’s General Plan, he proposes that a new agency be created to manage all public lands in San Francisco as “natural areas.”  All open space in the city, currently managed by Public Utilities, Port, and Public Works agencies as well as Recreation and Park should be “become part of a single natural resources agency.”  This new agency would “Integrate the protection and restoration of biodiversity within all open space management activities (not just natural areas), e.g., native plant landscaping in designed landscapes, wildlife management and monitoring in all parks, etc.” 

But why stop there?  Mr. Brastow also proposes in his public comment on the ROSE that these principles be extended to private yards:  “Conserve private open space, especially rear yards, as habitats and habitat connectors.” 

Is there any way to reconcile these demands to expand the empire of the Natural Areas Program into every piece of vacant property in San Francisco, both private and public, with the empty phrases of NIC’s latest newsletter?

Looking how far back into the botanical past?

Before we leave this contentious topic, we will address NIC’s opening gambit, “Restore to 1769 or Now?”  The author goes on to dismiss 1769 as the standard, preferring a more forward looking goal.  However, he is once again stuck with the written record, which establishes the pre-European landscape as the goal of the Natural Areas Program.

The management plan for the Natural Areas Program says explicitly that. “The following are the list of criteria…to determine the location of potential plant re-introductions:   Evidence of historic presence (based on Howell et al. 1958).” (page 2-6) And Howell (1958) says that “Native plant [is] present within the geographic limits of present-day San Francisco prior to the arrival of Portola expedition in 1769.” 

NIC may be prepared to welcome plants into San Francisco that arrived after 1769, but until the language in the management plan (and other similar documents such as “Assessment for Forestry Operations,” for Recreation and Park Department, June 2010.) is changed, we will continue to assume that is the standard used by the Natural Areas Program.

Making Peace

The tone of the latest NIC newsletter is welcome and we hope it is a first step toward resolving the conflict over the future of San Francisco’s parks.  If this is a sincere effort to address the objections of San Franciscans to the destructive and restrictive actions of the Natural Areas Program, the next step should be to demonstrate intentions with actions.  We therefore ask Nature in the City to join us in making the following requests of the Natural Areas Program and the Recreation and Park Department:

  • The Natural Areas Program should STOP spraying pesticides in the so-called “natural areas” NOW.
  • The Natural Areas Program should STOP expanding their native plant gardens until the Environmental Impact Report is complete and approved.
  • The Natural Areas Program should STOP destroying non-native plants and healthy trees until the Environmental Impact Report is complete and approved.

These actions would set the stage for the next step.  A lawyer and a critic of the Natural Areas Program has notified the Planning Department, the Natural Areas Program, and the City Attorney that the public comment period for the Draft Environmental Impact Report for the Natural Areas Program did not meet legal standards.  The law requires that notice of the public comment period be posted in all the natural areas and mailed to the neighbors of the natural areas.  Neither of these requirements was met.  Therefore, the lawyer requests that the public comment period be announced as required by law and repeated.

Since NIC says in its current newsletter that “restoration should be a community-driven, democratic process” NIC should agree that another properly announced public comment period is required.  The public cannot participate in this “democratic process” if they are unaware of what is planned for their parks.  

The DEIR must also be revised to accurately identify the Maintenance Alternative as the environmentally superior alternative.  And, finally, when the Planning Commission holds a hearing on the DEIR, the time of that hearing must be announced in advance and adhered to so that those who want to speak have the opportunity to do so (unlike the hearing on October 6, 2011 when the time was changed with little warning and many people were deprived of the opportunity to speak).

Actions speak louder than words!

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