The City of Oakland applied for a FEMA pre-disaster mitigation grant in 2005 to clear-cut all non-native trees on 122 acres of city owned property in the East Bay hills, based on the claim that it would reduce fire hazards. FEMA cancelled that grant in September 2016 in settlement of a lawsuit against the project.
The City of Oakland began the process of writing a new plan to reduce fire hazards in the hills by hiring a consultant to develop a Vegetation Management Plan in November 2016. The new plan will be much more comprehensive than the original plan, covering 1,925 acres of open space and 308 miles of roadside in Oakland. Oakland also made a commitment to an open public process to develop the plan. A survey of public opinion was conducted and two public meetings were held in 2017.
A draft of Oakland’s Vegetation Management Plan is now available HERE. There are detailed maps of the areas that will be covered by the plan. We suggest you take a look at those maps to determine what effect the plan will have on your neighborhood and the parks and open spaces you visit.
A public meeting about the draft was held on May 23, 2018 and written public comments will be accepted until June 11, 2018. Comments may be submitted in the following ways: Download comment card; Email VMPcomments@oaklandvegmanagement.org; Mail: 266 Grand Avenue, Suite 210, Attn: Ken Schwarz, Oakland, CA 94610. We hope you will participate in this public process that will determine the future of much of the landscape in the Oakland hills.
We are publishing an excerpt of the written public comment of one of our readers, which we hope will help you understand the issues and to write a comment of your own. Asterisks indicate where some detail has been omitted. You can see the entire public comment HERE: Oakland Draft Vegetation Management Plan – public comment
Horizon Water & Environment
266 Grand Avenue, Suite 210
Oakland, CA 94610
I am broadly supportive of the Draft Vegetation Management Plan (DVMP) because:
- It will create defensible space around structures in Very High Wildfire Hazard Severity Zones.
- It will clear easily ignited vegetation on roadsides in places where fire hazards are greatest.
- It sets priorities for implementation in places where fire hazards are greatest.
These three elements of the plan will reduce fire hazards while limiting destruction of trees and vegetation and being fiscally responsible.
My public comment will identify some weaknesses in the plan and make specific suggestions for improving the plan with the goal of minimizing fire hazards as well as collateral damage to the environment.
The 300-foot “buffer” zone is unnecessarily destructive. California law requires 100-feet of defensible space around structures. The DVMP proposes extending defensible space along roadsides and around structures to 300-feet, the length of a football field. Such a wide clearance of vegetation greatly exceeds California fire code and is therefore unnecessarily destructive. In a recently published op-ed in the Los Angeles Times, two academic scientists confirm our understanding of how to keep our communities safe: “The science is clear that the most effective way to protect homes from wildfire is to make homes themselves more fire-safe, using fire-resistant roofing and siding, installing ember-proof vents and exterior sprinklers, and maintaining “defensible space” within 60 to 100 feet of individual homes by reducing grasses, shrubs and small trees immediately adjacent to houses. Vegetation management beyond 100 feet from homes provides no additional protection.”
The buffer zone should be eliminated, reduced in size, or reduced to Priority 3 so that it is less destructive and costly.
The description of herbicide use in the draft is unnecessarily vague, because it provides no information about what herbicides will be used and the health and environmental hazards of specific herbicides. Nor does it explain how, where, or why herbicides will be used.
Instead of providing that information, the plan describes the public’s opposition to herbicides as “social stigma,” which implies that our opposition is a baseless prejudice against herbicides. In fact, our opposition is based on scientific information about the dangers of herbicides and those dangers must be acknowledged by the final version of this plan.
The dangers of herbicides are well documented and well known. ****** Here is a brief list of some of the most recent studies that conclude that glyphosate products are very dangerous to the health of animals and humans:
- The International Agency for Research on Cancer classified glyphosate as a “probable human carcinogen” in 2015. The IARC is composed of an international team of scientists convened by the World Health Organization of the United Nations.
- The State of California responded to that news by requiring all glyphosate products sold in the State to be labeled as carcinogens. The State was sued several times by the manufacturer of Round Up—Monsanto–to prevent the labeling requirement. The State of California recently won in the state court of appeals. Unless Monsanto appeals and wins in the State Supreme Court, all glyphosate products will be labeled as carcinogens in California.
- US National Toxicology Program recently conducted tests on formulated glyphosate products for the first time. In the past, tests were conducted only on the active ingredient…that is glyphosate alone. The formulated products that are actually applied as weed killers contain many other chemicals, some of which are not even known. The head of the National Toxicology Program Laboratory, told The Guardian newspaper the agency’s work is ongoing but its early findings are clear on one key point. “We see the formulations are much more toxic. The formulations were killing the cells. The glyphosate really didn’t do it,” DeVito said. A summary of the NTP analysis said that “glyphosate formulations decreased human cell ‘viability’, disrupting cell membranes. Cell viability was ‘significantly altered’ by the formulations, it stated.”
- The Global Glyphosate Study is being conducted by six scientific institutions all over the world. ******* This international consortium of scientific institutions recently published preliminary resultsof their study: “The results of the short-term pilot study showed that glyphosate-based herbicides (GBHs) were able to alter certain important biological parameters in rats, mainly relating to sexual development, genotoxicity and the alteration of the intestinal microbiome, at the ‘safe’ level of 1.75 mg/kg/day set by the U.S. Environmental Protection Agency (EPA).” In other words, at doses deemed safe by the US EPA, significant negative health effects were found in animals used in testing.
- The German Agriculture Minister announced on April 17, 2018 that she was finalizing a draft regulation to end use of the weed-killer glyphosate in household gardens, parks and sports facilities, and to set “massive” limits for its use in agriculture. Germany is one of 25 countries that have issued outright bans on glyphosate, imposed restrictions or have issued statements of intention to ban or restrict glyphosate-based herbicides, including Roundup Countless US states and cities have also adopted such restrictions. 
- Marin Municipal Water District quit using all pesticides in 2015. In a letter to East Bay Municipal Utilities District, a member of the Board of MMWD explains why that decision was made. (Attachment 2) MMWD hired scientists at UC Davis to conduct a study of the biological persistence of glyphosate. They found that glyphosate persisted for at least 84 days when applied to foliage, and perhaps longer after the study ended.
Garlon with the active ingredient triclopyr is more toxic than glyphosate. Garlon is the herbicide that is used to prevent eucalyptus and acacia from resprouting when the trees are destroyed. Its use was also specifically allowed for that purpose by Oakland City Council Resolution 79133. Although the DVMP does not mention its use, we assume—unless specifically told otherwise by the final version of the VMP—that Garlon will be used to control resprouts.
Triclopyr is an organochlorine product, in the same family of pesticides as DDT, which was banned in the US in 1972. Organochlorine products bioaccumulate and are very persistent in the environment. Nearly 50 years after it was banned, DDT is often found in the ground, in the water, and in people’s bodies. Organochlorine products are endocrine disrupters.The Pesticide Research Institute did a risk assessment of triclopyr for the California Invasive Plant Council. They reported that triclopyr “poses reproductive and developmental risks to female applicators.” 
- The Pesticide Research Institute did a risk assessment of triclopyr for Marin Municipal Water District in which they informed MMWD that birds and bees are both harmed by triclopyr and mycorrhizal fungi in the soil are damaged by triclopyr.
More research has been done on Round Up than on Garlon because it is more widely used. It is more widely used, partly because it is actually less dangerous than Garlon (it is also a non-selective plant-killer). Because of the toxicity of Garlon, several public land managers in the Bay Area have made a commitment to controlling resprouts without using herbicides: ******** Marin Municipal Water District, Marin County Parks and Open Space, UC San Francisco, and East Bay Municipal Utilities District (the supplier of our drinking water).
There is no evidence that eucalyptus is inherently more flammable than native trees. ******** Eradicating non-native trees and shrubs will not reduce fire hazards because they are not inherently more flammable than the native vegetation that will remain. Therefore, the reduction of fuel loads must be based on flammability, NOT the nativity of the flammable species. The nativity of plant species is irrelevant to reducing fire hazards and must be abandoned as criterion for destroying plants and trees.
I support the thinning of eucalyptus, acacia, Monterey pine and cypress to reduce fuel loads, as long as the canopy is intact. ******** When the canopy is intact, the forest floor is shaded which retains moisture that retards ignition and suppresses the growth of easily ignited weeds. The DVMP proposes to thin the targeted non-native trees to distances of 35 feet, creating gaps in the canopy of 10 feet within the 300-foot “buffer zone.” The distance between the trees must be reduced to 25 feet to maintain the canopy. In addition to reducing fire hazards, maintaining the canopy will also be less destructive and will reduce the amount of stored carbon released into the atmosphere.
My greatest disappointment in the DVMP is its proposal to remove all individual non-native trees where they presently exist in native vegetation outside the “buffer zone.” ******** Removing non-native trees in riparian areas and in redwood groves as proposed by the DVMP is not fire hazard mitigation because fire hazards in those areas are minimal.
Furthermore, destroying healthy trees damages the trees that remain because the herbicide that is used to prevent eucalyptus and acacia from resprouting is mobile in the soil and it is known to damage mycorrhizal fungi in the soil that is essential to the health of the native trees. ******* It is not possible to destroy isolated trees without damaging neighboring trees in close proximity. ****** Studies show that eucalyptus trees in native forests are not doing any damage to neighboring trees. ********
If individual non-native trees within native vegetation are not doing any environmental damage and do not increase risk of fire they should not be destroyed because destroying them WILL damage native vegetation. Please leave them alone!
Putting the DVMP into the long-term big picture
Finally, I suggest that we all take a step back from the details of the DVMP and consider the proposal in the context of the entire environment. The final VMP must minimize damage to the environment while mitigating fire hazards because:
- The climate has changed and it will continue to change. When the climate changes, the vegetation changes. That is one of the axioms of ecology and it will continue to be. If non-native plants and trees are better adapted to the current and anticipated climate, we should abandon futile attempts to force plants to live where we want them to live.
- If we want trees in California, we must look to the future, not the past. 130 million native conifers have died in California since 2010. 5-10 million oaks in California have been killed by Sudden Oak Death. The future of redwoods in California is in jeopardy because they require a lot of water and they don’t tolerate wind.
A climate change specialist at the US Forest Service tells us in a recent study that native tree species are the most vulnerable to climate change. USFS found that native trees are more vulnerable to the changes in temperature, precipitation, growing season, and other effects of accumulating greenhouse gases. The assessment found that 88 percent of invasive tree species are expected to prove resilient in the changing climate, ranked with low vulnerability, compared to 20 percent of natives.
- We are contributing to climate change by destroying healthy trees that are storing tons of carbon that will be released into the atmosphere as the destroyed trees decay. The primary reason why wildfires are more frequent and more intense is because of the warmer, drier climate. Therefore destroying more trees than necessary increases fire hazards because we are exacerbating climate change by destroying more trees than necessary.
- It is a fiction that destroying trees will release less carbon than the wildfires imagined by those who demand their destruction. According to a recently completed study at Oregon State University, “wildfire is not the biggest source of climate-warming carbon dioxide in Oregon forests—logging and wood products are.”
The trees that will be destroyed in Oakland will not be used as lumber, which means they will contribute even more carbon to the atmosphere. Timber that is used for building retains its stored carbon until the building deteriorates or is destroyed.
- The herbicides that are used to destroy vegetation and prevent trees from resprouting damage the soil and pose serious health risks to animals and humans. The more vegetation and trees the VMP destroys, the greater the damage caused by herbicides. Therefore, we must minimize the amount of vegetation that is destroyed as much as possible if herbicides are used.
We achieve nothing if the damage we do to the environment and to ourselves is greater than real or imagined reduction in fire hazards.
Thank you for your consideration.