On August 25, 2015, opponents of the projects in the East Bay Hills which will destroy hundreds of thousands of trees staged a protest at the headquarters of the Bay Area chapter of the Sierra Club and delivered a petition. The petition (available HERE) asks the Sierra Club to quit advocating for deforestation and pesticide use in the San Francisco Bay Area and to drop its lawsuit which demands eradication of 100% of all non-native trees on 2,059 acres of public land in the East Bay. The protest was successful as measured by the size of the crowd and the even-handed media coverage of the protest.
Update: HERE is a 14 minute video of the demonstration at Sierra Club headquarters on August 25, 2015. The video includes an attempt to discuss the issue with a Sierra Club staff member. Note the factual rebuttals to some of the claims the staff member makes in that conversation. Also, note the final rallying cry, “Poll your membership on this issue.” We will report soon on the follow up to that request. Please stay tuned.
However, although the protest has produced a flurry of defensive propaganda from the Sierra Club, it has not created new opportunities for dialogue with them. We tried to get the issue on the agenda of the Conservation Committee following the protest and once again our request was denied. We were also denied the opportunity to publish a rebuttal to articles in their newsletter about the projects. It is still not possible to post comments on the on-line version of the Yodeler, although each article dishonestly invites readers to “leave a comment.”
And so, open letters to the Sierra Club are the only means of communication available to us. Here are our replies to the latest round of propaganda published in the Yodeler on September 16, 2015 (available HERE). Excerpts from the Sierra Club article are in italics and our replies follow.
“The preferred strategy for vegetation management in the East Bay hills entails removing the most highly flammable, ember-generating trees like eucalyptus in phases — only in select areas considered most at risk for fire along the urban-wild interface.”
Preferred by whom? Neither fire experts nor the public think this project is a good idea, let alone the Sierra Club’s more extreme version of the project demanded by its suit. Over 13,000 public comments on the Environmental Impact Statement were sent to FEMA, of which 90% were opposed to this project according to FEMA. More recently, a petition in opposition to this project has over 64,000 signatures on it. This project is NOT the “preferred strategy for vegetation management in the East Bay hills.”
Eucalyptus is not more flammable than many other trees, including native trees:
- A study by scientists in Tasmania found that the leaves of blue gum eucalypts were more resistant to ignition than other species of Tasmanian vegetation tested. The study credits the “hard cuticle” of the leaf for its ability to resist ignition. (1)
- The National Park Service, which has destroyed tens of thousands of eucalypts and other non-native trees, states that eucalyptus leaves did not ignite during a major fire on Mount Tam. (2)
- The leaves of native bay laurel trees contain twice as much oil as eucalyptus leaves (3) and the fuel ladder to their crowns is much lower than eucalyptus, increasing the risk of crown fires. The “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District states explicitly that bay laurel is very flammable and recommends selective removal.
- Eucalyptus contributed more fuel to the 1991 fire in Oakland because a deep and prolonged freeze the winter before the fire caused eucalyptus and other exotic vegetation to die back. The dead leaf litter was not cleaned up, which contributed to the fire hazard. Such deep freezes are rare in the Bay Area. There has not been such a freeze for 25 years and another is unlikely in the warming climate.
- Ordinarily, eucalyptus does not contribute more fuel to the forest floor than native oak-bay woodland. This is confirmed by the National Park Service, which includes logs in the calculation of fuel loads. (2) Logs are extremely difficult to ignite. The so-called “fire hazard mitigation projects” are leaving all the eucalyptus logs on the ground when the trees are destroyed, suggesting that they aren’t considered a fire hazard. The National Park Service also separates the fuel loads of oaks and bays, which when combined are equal to the fuel load of eucalyptus. Since our native woodland in the East Bay is a mixture of oaks and bays, it is appropriate to combine them when comparing their fuel loads to eucalyptus.
- Eucalypts are sometimes blamed for casting more embers than native trees because they are taller than the oak-bay woodland. However, redwoods are as tall, if not taller, and they were also observed burning in the 1991 fire: On Vicente Road, “Two redwoods up the street caught fire like matchsticks.” (4) Yet, the Sierra Club is not suggesting that redwoods be destroyed to eliminate the risk of casting embers.
The Sierra Club now says the trees will be removed “in phases,” yet in its suit against the FEMA grants it objects to the phasing of tree removals. The main focus of their suit is opposition to the “unified methodology” which proposes to remove trees over the 10 year period of the grant on only 29 acres of the total project acreage of 2,059. To those who objected to this project, that small concession is little consolation, but for the Sierra Club it was a deal-breaker. Their suit demands that all non-native trees be removed immediately on all project acres.
If the Sierra Club withdraws its suit against the FEMA projects, it is free to tell another story, as it attempts to do in its Yodeler article. As long as that suit remains in play, the Sierra Club is stuck with that version of reality.
“Once the flammable non-native trees are removed, less flammable native species can reclaim those areas and provide for a rebound of biodiversity. This model of fire prevention can summarized as the the [sic] “Three R’s”:
REMOVE the most flammable non-native trees in select areas most at risk for fire;
RESTORE those areas with more naturally fire-resistant native trees and plants; and
RE-ESTABLISH greater biodiversity of flora and fauna, including endangered species like the Alameda whipsnake.”
This is a stunning display of ignorance of the project as well as the natural history of the San Francisco Bay Area:
- The FEMA projects do not provide for any planting or funding for planting after the trees are removed. FEMA’s mission is fire hazard mitigation, not landscape transformation. The scientists who evaluated the FEMA projects said that a native landscape is not the likely result of the project: “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.” (5)
- The US Forest Service evaluation of the FEMA projects stated that the resulting landscape would be more flammable than the existing landscape: “Removal of the eucalyptus overstory would reduce the amount of shading on surface fuels, increase the wind speeds to the forest floor, reduce the relative humidity at the forest floor, increase the fuel temperature, and reduce fuel moisture. These factors may increase the probability of ignition over current conditions.” (6)
- The US Forest Service evaluation predicts that the resulting landscape will be “a combination of native and non-native herbaceous and chaparral communities.” Despite the overwhelming evidence that wildfires in California start and spread rapidly in herbaceous vegetation such as dry grass, the myth persists that all non-native trees must be destroyed to reduce fire hazards. An analyst at CAL FIRE has explained to the Center for Investigative Reporting that the reason why wildfires were so extreme this summer is because of the heavy rains in December 2014, which grew a huge crop of grass: “The moisture did little to hydrate trees and shrubs. But it did prompt widespread growth of wild grasses, which quickly dry out without rain. ‘They set seed, they turn yellow and they are done,’ said Tim Chavez, a battalion chief and fire behavior analyst with CAL FIRE. ‘All that does is provide kindling for the bigger fuels.’” (7) We know that more dry grass starts more wildfires, yet the Sierra Club demands that we destroy the tree canopy that shades the forest floor and produces leaf litter, which together suppress the growth of the grasses in which fires ignite.
- The claim that native plants are “naturally fire resistant” is ridiculous. Native vegetation in California—like all Mediterranean climates—is fire adapted and fire dependent. The wildfires all over the west this summer occurred in native vegetation. There are over 200 species of native plants in California that will not germinate in the absence of fire and persist for only 3-5 years after a fire. (8) Although all native vegetation is not equally flammable, many species are considered very flammable, such as coyote brush, bay laurel, and chamise. To say otherwise is to display an appalling ignorance of our natural history.
- There is no evidence that the destruction of our urban forest will result in greater “biodiversity.” There are many empirical, scientific studies that find equal biodiversity in eucalyptus forest compared to native forests. There are no studies that say otherwise, yet the Sierra Club and their nativist friends continue to make this claim without citing any authority other than their own opinions. (9, 10, 11) Bees, hummingbirds, and monarch butterflies require eucalyptus trees during the winter months when there are few other sources of nectar. Raptors nest in our tall “non-native” trees and an empirical study finds that their nesting success is greater in those trees than in native trees.
The Sierra Club’s 3Rs can best be summarized as “repeat, repeat, repeat.” Their 3Rs are based on 3 Myths: (1) eucalyptus trees are the most serious fire hazard; (2) “native” vegetation is categorically less flammable than “non-native” vegetation, and (3) native vegetation will magically return to the hills when trees are clearcut and the hills are poisoned with herbicide. All available evidence informs us that these are fictions that exist only in the minds of the Sierra Club leadership and their nativist friends.
“The Sierra Club’s approach does NOT call for clearcutting. Under “Remove, Restore, Re-establish” thousands of acres of eucalyptus and other non-natives will remain in the East Bay hills. Our proposal only covers areas near homes and businesses where a fire would be most costly to lives and property. In fact, removing monoculture eucalyptus groves and providing for the return of native ecosystems will create a much richer landscape than the alternative — thinning — which requires regularly scraping away the forest floor to remove flammable debris.”
The Sierra Club’s suit against FEMA demands that all eucalyptus and Monterey pine be removed from 2,059 acres of public property. While it is true that the project acres are not 100% of all land in the East Bay, with respect to the project acres, it is accurate to describe the Sierra Club’s suit as a demand for an immediate clearcut of all non-native trees.
Most of the project acres are nowhere near homes and buildings. They are in parks and open spaces with few structures of any kind. CAL FIRE defines “defensible space” required around buildings to reduce property loss in wildfires. CAL FIRE requires property owners to clear flammable vegetation and fuel within 100 feet of structures. Using that legal standard, the FEMA project should not require the removal of all trees from project acres.
As we said earlier, Sierra Club’s description of the landscape that will result from the removal of the tree canopy is contradicted by scientists who evaluated the FEMA project. And their prediction that “thinning” would “require regularly scraping away the forest floor to remove flammable debris” is not consistent with the predictions of those scientists who have advised that the loss of shade and moisture resulting from the complete loss of the tree canopy will encourage the growth of flammable vegetation and require more maintenance than the existing landscape.
“Our preferred approach does NOT focus on eucalyptus merely because they are non-natives. Rather, it is because they pose a far higher fire risk than native landscapes. Eucalyptus shed ten to fifty times more debris per acre than grasslands, native live oak groves, or bay forests — and that debris, in the form of branches, leaves, and long strips of bark, ends up draped in piles that are a near-optimal mixture of oxygen and fuel for fire. Eucalyptus trees ignite easily and have a tendency to dramatically explode when on fire. Also, eucalyptus embers stay lit longer than embers from other vegetation; coming off trees that can grow above 120 feet tall, those embers can stay lit as the wind carries them for miles.”
The Sierra Club’s suit demands the eradication of Monterey pine as well as eucalyptus. The scientists who evaluated the FEMA projects stated that there is no evidence that Monterey pine is particularly flammable and they questioned why they were targeted for eradication: “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.” (5) It is not credible that the Sierra Club’s demand that these tree species be entirely eradicated has nothing to do with the fact that they are not native to the Bay Area. If flammability were truly their only criterion, they would demand the eradication of native bay laurel trees. If fear of lofting embers from tall trees were their only concern, they would demand the eradication of redwoods.
As we said earlier, redwoods looked as though they were exploding when they ignited in the 1991 fire. And we are seeing wildfires all over the west this fire season in which native trees look as though they are exploding when they ignite. That’s what a crown fire looks like, regardless of the species.
It defies reason to think that an ember is capable of traveling miles and still be in flames on arrival. In fact, Sierra Club’s suit says “non-native trees can cast off burning embers capable of being carried up to 2,000 feet in distance.” That’s a fraction of the distance the Sierra Club now claims in its hyperbolic description of the issues in the Yodeler. Surely we can all use a little common sense to consider how unlikely it is that a fragment of a tree small enough to be carried in the wind could travel miles while remaining on fire. Likewise, we must ask why fragments of eucalyptus trees are likely to burn longer than any other ember of equal size. We are not provided with any reference in support of these fanciful claims other than the opinions of the authors.
“Any herbicide use to prevent the regrowth of eucalyptus once they’ve been cut down (they quickly sprout suckers otherwise) would be hand applied in minimal amounts under strict controls. Any herbicide application must undergo a full environmental review to prevent impacts on humans, wildlife, and habitat. There are also methods other than herbicide that can be used to prevent regrowth, and the Sierra Club encourages the agencies that manage the land where fire mitigation occurs to explore these alternatives to find the most sustainable, responsible option.”
Once again, the Sierra Club is stuck with the public record which describes the FEMA projects:
- East Bay Regional Park District has stated in the Environmental Impact Statement for the FEMA project that it intends to use 2,250 gallons of herbicide to prevent the regrowth of eucalyptus. (12) This estimate does not include the herbicides that will be used by UC Berkeley or the City of Oakland. Nor does it include the herbicides that will be needed to kill flammable non-native vegetation such as fennel, hemlock, broom, radish, mustard, etc. Surely, we can all agree that thousands of gallons of herbicide cannot be accurately described as “minimal.”
- The Sierra Club now seems to be suggesting that further environmental review will be required for herbicide use by this project. They are mistaken in that belief. The Environmental Impact Statement for this project is completed and it admits that the project will have “unavoidable adverse impacts” on “human health and safety” and that there will be “potential adverse health effects of herbicides on vegetation management workers, nearby residents, and users of parks and open space.” The Sierra Club’s smoke screen cannot hide that conclusion.
- The FEMA grants have been awarded to the three public land owners and they explicitly provide for the use of herbicides to prevent eucalyptus and acacia from re-sprouting. There is nothing in the Environmental Impact Statement that indicates that “methods other than herbicide can be used to prevent regrowth,” as the Sierra Club now belatedly opines in its latest propaganda. If the Sierra Club wants other methods to be considered, we could reasonably expect they would make such a demand in their suit against FEMA, along with all their other demands. They do not make such a demand in their suit. Therefore, claims that other methods are being explored are not credible.
- Sierra Club’s claim that herbicides will be applied “with strict controls” is not credible because there is no oversight of pesticide application or enforcement of the minimal regulations that exist in the United States. After 25 years of working for the EPA, E.G. Vallianatos wrote in 2014 of his experience with pesticide regulation in Poison Spring: “…the EPA offered me the documentary evidence to show the dangerous disregard for human health and the environment in the United States’ government and in the industries it is sworn to oversee…powerful economic interests have worked tirelessly to handcuff government oversight.”
The Sierra Club has also explicitly endorsed the use of herbicides in the public comments they have submitted on these projects and in other articles in the Yodeler:
- Sierra Club’s written public comment on Scoping for the FEMA EIS: “We are not currently opposed to the careful use of Garlon as a stump treatment on eucalyptus or even broom when applied by a licensed applicator that will prevent spread into adjacent soils or waters.” Norman La Force (on Sierra Club letterhead), September 12, 2010
- “There is no practical way to eliminate eucalyptus re-sprouting without careful use of herbicides.” Yodeler, May 25, 2013
Obfuscation and insincere backpedaling
The latest Yodeler article about the FEMA projects is a lot of hot air. It makes claims about the issues for which it provides no evidence and for which considerable contradictory evidence exists. It contradicts previous statements the Sierra Club has made. Most importantly, as long as Sierra Club’s suit remains in play, the demands the Sierra Club makes in that public document cannot be denied. If the Sierra Club wishes to back away from its previous positions, it must start by withdrawing its suit, which demands that 100% of all non-native trees in the FEMA project areas be destroyed immediately. Withdrawal of the suit would be a most welcome start on the long healing process that is required to mend the damage the Sierra Club has done to its reputation as an environmental organization in the San Francisco Bay Area. However, the Sierra Club will not be able to reclaim its status as an environmental organization without renouncing all pesticide use on our public lands.
The Sierra Club has isolated itself from reality. Its leadership refuses to speak with anyone with whom they disagree. They have become the victims of incestuous amplification. They apparently do not read the documents they use to support their opinions. For example, the Sierra Club suit claims the California Invasive Plant Council (Cal-IPC) has classified blue gum eucalyptus as “moderately” invasive. In fact, Cal-IPC’s rating of blue gum eucalyptus is “limited.” This reflects the fact that a study of aerial photographs of Bay Area parks and open spaces, taken over a 60 year period find that eucalyptus and Monterey Pine forests were smaller in the 1990s than they were in the 1930s. (13)
We will send our petition soon to the national leadership of the Sierra Club. If you have not yet signed our petition, we hope you will consider doing so now.
- Dickinson, K.J.M. and Kirkpatrick, J.B., “The flammability and energy content of some important plant species and fuel components in the forests of southeastern Tasmania,” Journal of Biogeography, 1985, 12: 121-134.
- “The live foliage proved fire resistant, so a potentially catastrophic crown fire was avoided.” http://www.nps.gov/pore/learn/management/upload/firemanagement_fireeducation_newsletter_eucalyptus.pdf
- Ron Buttery et. al., “California Bay Oil. I. Constituents, Odor Properties,” Journal Agriculture Food Chemistry, Vol. 22, No 5, 1974.
- Margaret Sullivan, Firestorm: the study of the 1991 East Bay fire in Berkeley, 1993
- URS evaluation of UCB and Oakland FEMA projects
- FEMA DEIS – evaluation of US Forest Service
- Jon Keeley, Fire in Mediterranean Ecosystems, Cambridge University Press, 2012
- See Table 2.1 in Appendix F: http://www.fema.gov/media-library-data/1416861356241-0d76d1d9da1fa83521e82acf903ec866/Final%20EIS%20Appendices%20A-F_508.pdf
- William Russell and Joe McBride, “Vegetation Change and Fire Hazard in the San Francisco Bay Area Open Spaces,” Landscape and Urban Planning, 2003