Environmental consultant evaluates UC Berkeley’s FEMA project

We described the projects that will destroy tens of thousands of trees on public lands in the San Francisco East Bay in recent posts available here and here.  In this post we will focus on the projects on the property of the University of California, Berkeley (UCB) which will destroy 60,000 54,000 trees on 284 acres, cover 20% of those acres in 2 feet of chipped wood, and spray hundreds of gallons of herbicides on the stumps as well as foliar spray non-native vegetation.

The first consultant that was hired by FEMA to conduct the environmental impact review was URS Corporation.  We know that URS Corporation was the consultant at the time of the scoping process in 2010 because we spoke to their representatives at that meeting.  We were able to obtain the evaluation of UCB’s project by the URS Corporation with a public records request (Freedom of Information Act, AKA FOIA).  In this post we will tell you what URS said about UCB’s project in a letter to FEMA dated May 27, 2009.  FEMA posed 6 specific “issues” and we will briefly describe how URS evaluated these issues.  (The issues are quoted verbatim from that letter.)

Issue 1:  Evidence that the supposed habitat restoration benefit will occur, since no plans for revegetation is included in this grant.

URS agrees with UC that the “project will provide better growing conditions for plants in the understory because the plants will have increased access to resources (e.g., sunlight and soil nutrients).”  But they emphatically do not agree with UCB that the post-treatment landscape will be exclusively native:

“However, we question the assumption that the types of vegetation recolonizing the area would be native.  Based on conditions observed during site visits in April 2009, current understory species such as English ivy, acacia, vinca sp., French broom, and Himalayan blackberry would likely be the first to recover and recolonize newly disturbed areas once the eucalyptus removal is complete.  These understory species are aggressive exotics, and in the absence of proactive removal there is no evidence to suggest that they would cease to thrive in the area, especially the French broom which would be the only understory plant capable of surviving inundation by a 2-foot-deep layer of eucalyptus chips.”

URS also observes that wood chip mulch is unlikely to encourage native revegetation over non-native revegetation:

“As written, the current plan assumes native vegetation will reclaim the treatment areas but does not include any plans for native revegetation.  Instead, in order to ‘reduce undesirable weed invasion’ and thus encourage the development of native grasslands, chaparral, and bay/redwood communities, UC plans to apply chip mulch to the ground…It is not clear how the mulch would prevent the proliferation of invasive species while simultaneously encouraging the growth of existing native species.  Despite thorough research, we were unable to find documentation of the ability of exotic chip mulch to suppress undesirable species while encouraging favorable species.”

Issue 2:  Relative fire risk of current vegetation versus chip dominated landscape:  there is no scientific evidence to support the project as proposed.

Although URS agrees with UC that eucalypts are a fire hazard, they question that the eucalypts are more flammable than distributing their dead wood on the ground as wood chips, branches and logs: 

“However, the comparative risk between eucalyptus in the form of a dense standing forest versus the form of a 2-foot-deep mulch layer on the ground is not well documented.  Studies have shown that mulch layers actually can pose a fire risk depending upon the type of material, the depth of the mulch, and the climate of the mulch site….Fire Engineering Magazine recommends that, to reduce the potential for fire in mulch, one should recognize that mulches high in oils ignite more easily and that mulch fires start more readily in hot climates where rain is scarce…Eucalyptus material is high in oils, and the East Bay Hills are subject to long annual periods that are hot and dry.” 

Issue 3.  Potential for introduction of chaparral-dominated landscape and issues associated with fuel-driven fires versus climate-driven fires.

URS notes that the post-treatment landscape is unknown.  However, if UC is right in predicting the return of a native landscape, this is URS’s evaluation of the fire hazard in a native landscape:

“…grasslands fuels burn cooler and faster than eucalyptus material, yet they are easier to ignite and carry fire quickly across a landscape.  Chaparral is one of the most hazardous wildland fuel types in California due to the woody, persistent nature of the plants.  A chaparral-dominated landscape in the post-treatment project area would create a fire hazard profile with its own suite of risks and concerns for fire protection, including flame lengths that far exceed those of the other possible vegetation types.”

URS concludes the analysis of this issue by repeating its concerns regarding the flammability of wood chip mulch: 

“…it may be inaccurate to assume that the chip layer, given its depth, can be ignored as a potential fuel source.  However, such a deep chip layer may have the potential to not only sustain a localized burn but to connect fuels in vegetation types located adjacent to the treatment areas.”

Issue 4.  Justification of two species (Monterey pine and acacia) targeted for removal are a risk.

URS does not believe that Monterey pine and acacia will contribute to fire hazards in the post-treatment project areas:

“The UC inaccurately characterizes the fire hazard risk posed by the two species however…Monterey pine and acacia trees in the treatment area only pose a substantial fire danger when growing within an eucalyptus forest [where they provide fire ladders to the eucalyptus canopy].  In the absence of the eucalyptus overstory, they do not pose a substantial fire hazard.”

Issue 5.  Complete analysis of other practical alternatives…

URS agrees with UC that the cost of annual clearance of ground litter would be prohibitive.  They also agree that “creating strategic fuelbreaks” would not be effective.  However, they say that “thinning targeted species rather than removing all and regularly clearing the understory” should be considered a viable alternative to the proposed project. 

Issue 6.  Document chips will decompose in 3 to 5 years.

UCB’s project intends to distribute wood chips on the forest floor to a depth of 2 feet.  UCB claims that the wood chips will decompose in 3 to 5 years.  URS does not think this is a realistic assessment:

“…literature search did not identify any studies documenting decomposition rates in eucalyptus mulch deeper than 4 inches, which notably is the maximum recommended depth for landscaping…Best scientific judgment suggests that a deeper chip layer would decompose more slowly than a shallow chip layer because it would be more insulated from moisture and less of its surface area would be in contact with decomposing bacteria and fungi found in the soil.”

UCB has ignored the advice of FEMA’s consultant

We have read most of the Draft Environmental Impact Study (DEIS) for this project.  It is about 3,000 pages long, so we won’t claim to have digested it entirely.  However, we can say with some confidence that UCB has ignored most of URS’s scathing criticism of their project.  The only concession that we can see is that UCB now says they will cover only 20% of the project with 2 feet of wood mulch.  However, they intend to cut the remainder of the wood into pieces 2-3 feet long and leave them lying around on the remaining 80% of the project area.  That doesn’t seem like a significant improvement, with respect to fire hazard.  Dead wood is dead wood and tons of it will be lying around when tens of thousands of trees are destroyed.

Why was the Environment Impact Study written by different consultants?

Given that URS was obviously telling UCB something they didn’t want to hear when the process of preparing an environmental impact study began in 2009, we aren’t surprised that URS was not involved in the final preparation of this document.  According to the Draft Environmental Impact Study, the consultants who prepared the report are entirely different.  (DEIS, Section Eight)  URS Corporation is conspicuously absent from the list of preparers of the DEIS.

We rarely subscribe to conspiracy theories.  We usually find incompetence a more realistic explanation for the strange things that happen in our messy world.  However, in this case, let’s just say that this change in the consultants who prepared the DEIS smells bad. 

Please tell FEMA your opinion of these projects

Comments on this document must be submitted by June 17, 2013.  You may submit written comments in several ways:

• Via the project website: http://ebheis.cdmims.com
• By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
• By mail: P.O. Box 72379, Oakland, CA 94612-8579
• By fax: 510-627-7147

 These public lands belong to you and the money that will be used to implement these projects is your tax dollars.  So, please tell the people who work for you what you think of these projects.

Please sign the petition of the Hills Conservation Network in opposition to these projects which is available HERE.