The draft Environmental Impact Report (DEIR) for Oakland’s Vegetation Plan (OVMP) has been published. When the DEIR is approved and funding is identified, implementation will finally begin after a process that began four years ago. The plan and its EIR are available HERE. The deadline for public comments on the DEIR is January 22, 2021. The email address for submitting public comments is DEIRfirstname.lastname@example.org
The primary purpose of the plan is to reduce fire hazards in High Fire Hazard Zones in Oakland by reducing fuel loads on about 2,000 acres of public land and 300 miles of roadside. Although there were many issues, the primary battle lines were drawn by these issues at the beginning of the process and they remain:
- On one side, some people were concerned by the scale of tree removals that were considered and the herbicides that would be needed to control the resprouts of the trees after removal. If the plan as proposed is approved, herbicides will be permitted in places where they were prohibited in the past.
- On the other side, some survivors of the 1991 Oakland wildfire and native plant advocates who are their allies, want all non-native trees to be destroyed and replaced with native plants. They are not satisfied with plans to thin trees around structures and roadsides.
The consequences of destroying Oakland’s urban forest
The survivors of the 1991 fire in Oakland asked that the OVMP be radically revised at a public hearing about the OVMP DEIR on December 16, 2020. They called their version of a vegetation management plan Alternative 5. It is an alternative that does not exist in the DEIR. These are the major elements of what they asked for:
- They ask that all non-native trees be destroyed everywhere in the treatment areas. They ask that the trees be clear-cut rather than thinned, as proposed by the plan. They ask that tree removals not be confined to defensible space around structures, as proposed by the plan.
- They ask that removed trees and non-native vegetation be replaced with native trees and vegetation.
- They ask that roadside clearance of vegetation occur 100 feet from both sides of the road rather than 30 feet as the OVMP proposes.
- They expressed concern about dead trees. They are apparently unaware of the epidemic of Sudden Oak Death that has killed 50 million native oaks in the past 15 years and is spreading rapidly.
The OVMP DEIR is responsive to some of these concerns.
- The OVMP DEIR makes a commitment to seeding areas that are steep and barren after vegetation removal with seeds of native plants. The purpose of this seeding is to minimize the potential for erosion.
- The OVMP DEIR makes a commitment to replant trees removed in riparian areas as required by Oakland’s ordinance to protect creeks.
- The OVMP makes a commitment to remove all dead trees in treatment areas. Sudden Oak Death (SOD) is the probable cause of the dead trees described at the public hearing. SOD has been found in many treatment areas in the plan: Garber Park, Shepherds Canyon, Dimond Canyon Park, Joaquin Miller Park, Leona Heights Park, Knowland Park, and Sheffield Village. (OVMP DEIR 3.4-87)
Increasing roadside clearance to 100 feet would increase the acreage of roadside tree removals and vegetation required by the OVMP by 233%. The consequences of such extensive removals can be seen on Claremont Ave, west of Grizzly Peak. These removals were done by UC Berkeley. Catastrophic erosion after intense rainfall looks inevitable.
Huge piles of wood chips and logs must be disposed of. Such piles of wood chips are known fire hazards until they are spread or disposed of. The wood chip piles resulting from roadside clearance on Claremont Ave cannot be spread because the quantity exceeds available land. UC Berkeley has made a commitment to build a biofuels plant to burn the wood chips to generate electricity for campus facilities. The OVMP does not make a commitment to build a biofuels plant to properly dispose of wood chips and it mandates a limit of 6 inches of wood chip mulch on the ground. Please look at these pictures of some of the wood debris created by clearcutting less than one mile of roadside on Claremont Ave. Then consider that the OVMP proposes to treat 300 miles of roadside. Multiply these piles of wood chips and logs by 300 to consider the consequences of “Alternative 5.”
Update: Since publishing this article, I have learned that UC Berkeley has NOT built a biofuels plant to dispose of the wood debris to meet Cal Fire grant requirements for reducing greenhouse gas emissions. Nor does UC Berkeley intend to build a biofuels plant. The disposition of the wood debris from this project has not yet been determined. This is the final paragraph of my formal complaint to Cal Fire about this project: “In conclusion, the grant application for this project makes a commitment to reducing greenhouse gas emissions that is based on the assumption that a biofuels plant will generate electricity from the wood debris. Such a plant has not been built and UC Berkeley apparently does not intend to build such a plant. Other claims made in the grant application about carbon storage are based on inaccurate claims about carbon storage. Grant guidelines state, “Failure to meet the agreed upon terms of achieving required GHG reduction may result in project termination and recovery of funds.” In other words, Cal Fire should terminate this project and recover any funds that have been remitted to UC Berkeley. The project is a misuse of grant funds because it will increase fire hazards and increase greenhouse gas emissions. Without imputing motives, on the face of it, the grant application looks fraudulent.” The full story of how this project has violated grant guidelines as well as the description of the project itself in the grant application is told HERE. January 18, 2021
One of many piles of wood chips, Claremont Ave, November 2020
Oakland does not want a biofuels plant because it will significantly increase pollution. Sierra Club Magazine reports that “The manufacturing of biomass-energy wood pellets requires drying the logged material in a wood-fired process, then pressing the dried wood into pellets—and every step emits significant amounts of air pollution. According to the Environmental Integrity Project study, the emissions from the facilities include fine particulate matter, nitrogen oxides, carbon monoxide, and volatile organic compounds. Wood-pellet manufacturing emits a form of soot and dust called PM 2.5, which can pass deep into the lungs and depress lung function, worsen asthma, and cause heart attacks. Volatile organic compounds, when exposed to sunlight, transform into ozone, which is especially dangerous to children and the elderly.”
This aerial view of the clear cut on Claremont Ave makes it clear that this is a native plant “restoration,” not fire hazard mitigation. The north side of the road has been clear cut 100 feet from the road where the trees were non-native. There has been no comparable clearance on the south side of the road where the trees are native. The native trees are predominantly native bay laurels that are known to be highly flammable. The leaves of bay laurel contain more oil than the leaves of eucalyptus and the branches grow to the ground, providing a fire ladder to the tree canopy. If fire hazard mitigation were the goal of this project, both sides of the road would have been treated the same.
The cost of Alternative 5 would be prohibitive. The plan would need to be rewritten and a new EIR prepared. The first plan took four years to prepare; the second will take nearly as long after new funding is secured for it. Funding for implementing the OVMP has not been identified. The City of Oakland is currently running an annual budget deficit of $62 million. Budget cuts are planned to address the deficit, including 10 mandatory furlough days for police and firemen.
One of many reasons why I love my home, Oakland, is its deep commitment to equity. If Oakland had the resources to fund restoration of approximately 2,000 acres of public land and 300 miles of roadside to native vegetation, it is unlikely to spend those resources in the wealthiest communities in Oakland on a project that would bring little benefit for the poorest communities in Oakland. Oakland’s Equitable Climate Action Plan (ECAP) is a case in point. Its forestry section is devoted to planting trees in the poorest neighborhoods that suffer the most air pollution and have the fewest trees, as it should be.
I am sympathetic to the survivors of the 1991 Oakland fire as well as to those who have been injured by chemicals to which they were exposed. Fire survivors have had a traumatic experience that has irrevocably altered their perception about the causes of wildfire. There are also other survivors of the 1991 fire who watched native redwoods and oaks burn. Their understanding of wildfire is therefore different, but it is more consistent with the wildfires of the past 5 years that have occurred in predominantly native vegetation. Native vegetation in California is fire adapted and fire dependent. Non-native vegetation is not inherently more flammable than native vegetation.
Public Policy requires compromise
Thinning of non-native forests and herbicide treatment to prevent resprouting is not without risks. We will lose some of our protection from wind. The trees that remain will be more vulnerable to windthrow. There may be some erosion in steep areas. The herbicide that is usually used to prevent resprouts (triclopyr) kills tree roots by traveling from the freshly cut stump through the roots of the tree. The roots of trees are intertwined with the roots of their neighbors that are often damaged by the herbicide and sometimes killed. The herbicide kills mycorrhizal fungi that live on the roots as well as microbes in the soil. Their loss reduces the health of the soil, handicapping the survival of remaining and new plants. This damage to soil is one of many reasons why native plant “restorations” are frequently unsuccessful after scorched earth eradications. Both triclopyr and imazapyr are on the list (California Code of Regulations 6800) of pesticides that have “the potential to contaminate groundwater” because they are very mobile and persistent in the soil.
I accept these risks in the interests of reducing fire hazards. I have asked for a few tweaks to the plan, including continuing to prohibit foliar spraying of herbicides in public parks and open spaces. These are the compromises that must be made to make public policy. We cannot paralyze ourselves by letting the perfect be the enemy of the good. Oakland needs a Vegetation Management Plan that is effective, affordable, and safer than other alternatives. That’s what the Oakland Vegetation Management Plan is.