This is the last in a series of rebuttals to the Sierra Club’s “pre-buttal” to a letter from a Sierra Club member to members of the San Francisco Bay Chapter of the Sierra Club about the Club’s support for deforestation and pesticide use on our public lands.
The truth about how much herbicide will be used
Sierra Club misrepresents volume of herbicide use: “If used, herbicide would be applied in minute quantities under strict environmental controls.” (1)
East Bay Regional Park District (EBPRD) informs us in the Draft Environmental Impact Statement (DEIS) for the FEMA project in the East Bay Hills that it intends to use 2,250 gallons of herbicide on its project acres to destroy non-native vegetation and prevent the trees they destroy from resprouting. You can see the detailed table of their intended herbicide use for yourself by looking at the DEIS. (2) On what planet would 2,250 gallons be called “minute quantities?”
EBRPD intentions were to “thin” non-native trees, not destroy them all. The Sierra Club has sued EBRPD to force them to destroy ALL non-native trees on their project acres. If the Sierra Club lawsuit is successful, EBRPD will be forced to destroy MORE trees than it wanted to destroy. That means it will be forced to use EVEN MORE herbicide than it intended to use, i.e., MORE than 2,250 gallons.
EBRPD is only ONE of the three public land owners that are participating in the FEMA project. The other two public land owners (UC Berkeley and City of Oakland) intend to destroy ALL non-native trees on their project acres. That means they will have to use EVEN MORE herbicide than EBRPD intended to use per acre of project area.
Sierra Club fabricates an argument we have not made: “Comparing this use of herbicide to the regular broadcast spraying of farmland elsewhere is a misrepresentation of fact.” (1)
This is a red herring, intended to confuse you with an argument that no one has made in opposition to this project. We have not likened pesticides used for these projects with agricultural use of pesticides. We aren’t being given a choice between agricultural pesticides and pesticides in our parks. The Sierra Club is asking us to accept additional pesticides in our parks on top of the agricultural pesticides we are already exposed to and over which we have no control. Since many pesticides accumulate in our bodies over our lifetimes, additional pesticide exposure results in greater toxicity and potential for damage to our health.
Sierra Club fantasizes about the post-project landscape: “Concerns about not planting trees to replace those being removed miss the mark. Replanting is not necessary. (1)
Knowledgeable organizations do not share the Sierra Club’s fantasy that native trees will magically emerge from 2 feet of eucalyptus wood chip mulch to colonize the bare ground. Here is a partial list of the environmental consultants, governmental agencies, and environmental organizations that have refuted this fiction:
- URS Corporation is the environmental consultant initially hired to complete the environment impact review of the FEMA projects. Their report said: “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.”
- The US Forest Service evaluated the FEMA projects. This is their prediction of the post-project landscape: “a combination of native and non-native herbaceous and chaparral communities.”
- The California Native Plant Society predicted the post-project landscape in its written public comment on the Draft Environmental Impact Statement (DEIS) with this rhetorical question: “What mechanism is being instituted by FEMA in this DEIS to guarantee a commitment of money and personnel for management of greatly increased acreages of newly created annual weedy grassland?”
- The Audubon Society predicted the post-project landscape in its written public comment on the DEIS: “There is no support for the conclusion that native vegetation will return on its own. This plan may not result in an increase in native trees and plants…Heavy mulching will delay or prevent the growth of native species.”
Sierra Club and Claremont Canyon Conservancy (CCC) repeatedly refer to Site 29 on Claremont Blvd as a model for the FEMA projects. They fail to acknowledge that Site 29 is not representative of most FEMA project areas because CCC planted native trees (primarily redwoods) on Site 29 and the microclimate of Site 29 is not typical of other project areas. Site 29 is a riparian corridor—there is a creek running through it—so there is more available water than in most project areas. It is also protected from wind and sun by hills on north and south sides of the site. CCC has not made a commitment to plant native trees on 2,000 acres of the FEMA project areas and even if it did, it could not expect the same results in radically different microclimates such as sunny, windy ridge lines with no available water source.
Fundamentals of carbon storage
Sierra Club does not understand the fundamentals of carbon storage: “Carbon sequestering and erosion control will not be reduced by removing eucalyptus trees… Indeed, reducing the fire danger by removing the eucalyptus will do much to prevent the release of tons of carbon that occurs during a wildfire. [x]” (1)
Sierra Club continues with the fiction that non-native trees will burn while native trees will not. There is no evidence behind that story, and much evidence to the contrary. The numerous wildfires throughout California each summer demonstrate that native trees and shrubs are extremely flammable—easily ignited and burning vigorously once ignited. Native trees, shrubs, and grasses also release their stored carbon when they burn. The NSF article cited by the Sierra Club in support of its bogus statement does not suggest that prospectively destroying forests is a means of preventing carbon loss.
Destroying eucalyptus trees will release hundreds of thousands of tons of carbon stored in those trees. That’s a simple, inarguable fact. There are no plans to replace the eucalyptus with “native trees.” A small portion of the carbon released by eucalyptus destruction may be recaptured by the grasses and shrubs that will grow in place of the eucalyptus, but the net loss of stored carbon to the atmosphere from the eucalyptus is huge and permanent. Further, the eucalyptus would have continued to store even more carbon if left in place. That future carbon sequestration is also lost.
The DEIS for the FEMA-funded projects tries to minimize the loss of stored carbon from destruction of eucalyptus by quantifying only carbon loss from the destruction of tree trunks, ignoring leaves, branches, roots, understory, forest floor litter, and soil. But even they acknowledge, “…the planned growth of oak and bay woodlands and successional grassland containing shrub islands would not sequester as much carbon as the larger eucalyptus and pines and the denser coastal scrub that would be removed.” (DEIS 5.6-11)
Killing habitat needed by wildlife
Sierra Club does not know who lives in our urban landscapes: “Native landscapes provide habitat for much more diverse ecosystems.” (1)
There are many studies that find that our non-native landscape provides valuable habitat and no studies that say otherwise:
- “Most California natives in cultivation are of no more butterfly interest than nonnatives, and most of the best butterfly flowers in our area are exotic.” (3)
- “[T]he science does not support the supposition that native plantings are required for biodiversity…it is clear that an automatic preference for native trees when planning in urban areas is not a science-based policy.” (4)
- “Three types of trees were used most frequently by roosting monarchs [in California]: eucalyptus (75% of the habitats primarily Eucalyptus globulus), pine (20% of the habitats primarily Pinus radiata), and cypress (16% of the habitats primarily Cupressus macrocarpa)” (5)
- “In the first half of the 20th century, the Anna’s Hummingbird bred only in northern Baja California and southern California. The planting of exotic flowering trees provided nectar and nesting sites, and allowed the hummingbird to greatly expand its breeding range…Anna’s Hummingbird populations increased by almost 2% per year between 1966 and 2010, according to the North American Breeding Bird Survey…Thanks to widespread backyard feeders and introduced trees such as eucalyptus, it now occurs in healthy numbers all the way to Vancouver, Canada.” (6)
“Fourteen of 27 nests in 1994 and 38 of 58 nests in 1995 were in exotic trees, predominantly eucalyptus. Nesting and fledging success were higher in exotic trees than in native trees in both years, owing in part to greater stability and protective cover. Most nest trees in upland areas were exotics, and even in riparian habitats, where tall native cottonwoods and sycamores were available, Red-shouldered Hawks selected eucalyptus more often than expected based on availability.” (7)
- A study that compared species diversity and abundance of plants, invertebrates, amphibians, birds, and rodents in eucalyptus forest with oak-bay woodland in Berkeley, California reported this finding: “Species richness was nearly identical for understory plants, leaf-litter invertebrates, amphibians and birds; only rodents had significantly fewer species in eucalypt sites. Species diversity patterns…were qualitatively identical to those for species richness, except for leaf-litter invertebrates, which were significantly more diverse in eucalypt sites during the spring.” (8)
We could provide many more citations from studies that consistently find that our existing non-native landscape is essential to wildlife and that destroying it will be harmful to wildlife, particularly considering the enormous amount of herbicide that will be used. We ask this common-sense, rhetorical question, “How could destroying most of our landscape provide a more diverse ecosystem?” It defies logic.
Environmentalism gone awry
If the Sierra Club would replace a few of its lawyers with a few scientists, perhaps we would not be having this debate. Environmentalism has gone astray because it is not knowledgable about some basic scientific issues, such as carbon storage, the toxicity of herbicides, and the habitat needed by our wildlife. Climate change is the environmental issue of our time. If an environmental organization does not understand the fundamentals of carbon storage it is not capable of doing its job. The Sierra Club must improve its knowledge of the Bay Area environment or it will fade into irrelevance in the struggle to protect that environment.
(2) See Table 2.1 in Appendix F: http://www.fema.gov/media-library-data/1416861356241-0d76d1d9da1fa83521e82acf903ec866/Final%20EIS%20Appendices%20A-F_508.pdf
(3) Arthur Shapiro, Field Guide to Butterflies of the San Francisco Bay and Sacramento Valley Regions, University of California Press, 2007
(4) Linda Chalker-Scott, “Nonnative, Noninvasive Woody Species Can Enhance Urban Landscape Biodiversity,” Arboriculture & Urban Forestry, 2015, 41(4): 173-186
(5) Dennis Frey and Andrew Schaffner, “Spatial and Temporal Pattern of Monarch Overwintering Abundance in Western North America,” in The Monarch Butterfly Biology and Conservation, Cornell University Press, 2004.
(6) Cornell Ornithology Laboratory https://www.allaboutbirds.org/guide/annas_hummingbird/id
(7) Stephen Rottenborn, “Nest-Site selection and reproductive success of urban red-shouldered hawks in Central California,” J. Raptor Research, 34(1):18-25
(8) Dov Sax, “Equal diversity in disparate species assemblages: a comparison of native and exotic woodlands in California,” Global Ecology and Biogeography, 11, 49-52, 2002.