On December 1, 2014, FEMA published the final Environmental Impact Statement (EIS) for the projects in the East Bay Hills which propose to destroy hundreds of thousands of non-native trees. FEMA’s email announcement of the publication of the EIS implied that the projects had been revised. Two of the agencies applying for FEMA grants—UC Berkeley and City of Oakland—had originally proposed to destroy all non-native trees on their properties. The third agency –East Bay Regional Parks District—had proposed to thin non-native trees in most areas and destroy all in a few areas. FEMA’s email announcement of the final EIS implied that both UC Berkeley and City of Oakland would be required to use the same “thinning” strategy as East Bay Regional Parks District.
After reading the final EIS, the Hills Conservation Network (HCN) is reporting that FEMA’s email announcement was rather misleading. In fact, both UC Berkeley and City of Oakland will be allowed to destroy all non-native trees on their properties. In a small sub-section (28.5 acres) of their total project acres (406.2 acres), UC Berkeley and City of Oakland are being asked by FEMA to destroy the trees more slowly than originally planned. However, they will all be destroyed by the end of the 10 year project period.
HCN has analyzed the EIS and consulted legal counsel. The following is HCN’s assessment of the EIS and their plans to respond to FEMA. We publish HCN’s assessment with their permission. Note that HCN is asking the public to send comments to FEMA and they are raising funds to prepare for a potential legal suit.
“After having reviewed the Final EIS in depth and having consulted with various stakeholders, HCN has concluded that the Final EIS, in spite of FEMA’s efforts to improve it from the Draft version, remains unacceptable.
While FEMA has made some modifications to portions of the EIS in response to the enormous number of comments submitted last year [more than 13,000], the fact remains that if implemented in their current form, these projects would remove essentially all of the eucalyptus, pines, and acacias from the subject area. While for portions of the area FEMA is now proposing that there be a phased removal of these species, the fact remains that the objective is ultimately to convert the current moist and verdant ecosystem into one dominated by grasses, shrubs, and some smaller trees. This will forever alter the character of these hills that so many of us have grown up with, know and love.
But worse than that, these projects would actually increase fire risk, destabilize hillsides, cause immense loss of habitat, release significant amounts of sequestered greenhouse gases, and require the use of extraordinary amounts of herbicides over a large area for at least a decade.
Additionally, by preemptively clearcutting 7 acres of Frowning Ridge in August of this year, UC not only made a clear violation of FEMA rules but also essentially negated the accuracy and relevance of the EIS. While FEMA acknowledges this in the EIS, they still want to move forward with a document that may no longer accurately reflect the reality of the current environment, the cumulative impacts of these projects, and any of the other factors that underpin the EIS process.
For these reasons, HCN will be submitting a comment letter to FEMA asking that the EIS be pulled back, reworked, and recirculated….at a minimum. Additionally, we are currently exploring legal options should the EIS be finally released on January 5, 2015 in its current form. One way or another, we are committed to ensuring that the will of a small number of influential people doesn’t result in the loss of a treasured resource to the vast majority of us (both human and other).
We ask your support in sending additional comment letters to FEMA [email@example.com] and most importantly that you consider making a tax-deductible contribution to HCN. While we wish we did not have to do this, the fact is that the only way we can have a shot at preventing this irreparable harm from happening is by hiring lawyers, and that is what we will do. This takes money, so please do what you can either by sending a check to HCN at P.O. Box 5426, Berkeley, CA 94705 or by making a donation through our website at http://hillsconservationnetwork.org/HillsConservation3/Support_HCN.html.”
Thanks again for all your support,
Hills Conservation Network