California’s Department of Pesticide Regulation (DPR) has published a draft of a policy that would replace its Integrated Pest Management policy with a Sustainable Pest Management (SPM) policy that is different in name only. SPM makes a commitment to continue using pesticides in California until 2050, and by implication, beyond. It makes NO commitment to reduce pesticide use or reconsider the current targets of pesticide applications. It claims that the health hazards and damage to the environment will be reduced by identifying “Priority Pesticides” for possible substitution or “eventual elimination.” It doesn’t commit to identifying any specific number of dangerous pesticides nor does it provide specific criteria for selecting these dangerous products. It claims that increased testing and development of new products will result in safer products and puts these judgments into the hands of “stakeholders” with “experiential and observational knowledge” rather than scientists with expertise in soil science, endocrinology, toxicology, epidemiology, biology, botany, horticulture, etc. The “stakeholder” committee that wrote the SPM proposal for urban areas included the manufacturer of pesticides and other users and promoters of pesticides.
That’s not an exhaustive list of the many faults of SPM and the dangers that lurk in it. I hope you will read it yourself and consider writing your own public comment by thedeadline on Monday, March 13, 2023, at 5 pm. The document is available HERE. It’s less than 100 pages long and it is a quick read because it is basically a collection of bullet-points.
This is how to comment: “DPR is accepting public comments to inform the prioritization and implementation of the Roadmap’s recommendations through March 13, 2023 at 5 p.m. Comments can be shared in writing to email@example.com or by mail to the department at 1001 I Street, P.O. Box 4015, Sacramento, CA 95812-4015.” Please note that Department of Pesticide Regulations is not offering revisions, only “prioritization and implementation.”
My public comment on California’s “Sustainable Pest Management Roadmap”
A summary of my public comment is below. A link to the entire comment is provided at the end of the summary:
Public Comment on “Sustainable Pest Management Roadmap” (AKA “Pathway to poisoning the environment for another 25 years”)
My public comment is focused on pesticide use in urban areas because of my personal experience and knowledge of pesticide use where I live. These are the broad topics I will cover in detail with specific examples later in my comment:
Since glyphosate was classified as a probable carcinogen by the World Health Organization in 2015 and the manufacturer of glyphosate settled 100,000 product liability lawsuits by awarding $11 billion to those who were harmed by glyphosate, public land managers have been engaged in the process of substituting other, usually equally or more dangerous herbicides for glyphosate to deflect the public’s concerns. The Sustainable Pest Management Roadmap (SPM) formalizes this process of substitution without addressing the fundamental problems caused by pesticides.
SPM endorses the status quo that exists now. Affixing the word “Accelerating” to SPM is an extreme case of double-speak that deliberately obscures, disguises, distorts, or reverses the meaning of words. SPM ensures that toxic pesticides will be used in California for more than 25 years, to 2050, and likely beyond. SPM therefore accelerates the damage to the environment that is occurring now. Given that climate change will enable the movement of more pests into areas where they are now suppressed by weather, greater use of pesticides should be anticipated so long as the underlying issue is not addressed.
The underlying issue is that pests have been identified for eradication that in some cases cannot be eradicated and in other cases should not have been identified as pests either because they are innocuous or because of the valuable ecological functions they perform. The key question that SPM does not address is whether pesticide use is truly necessary in the first place. Unless we focus on whether a pesticide is actually necessary, all other issues are merely window dressing for perpetual pesticide use.
SPM proposes to identify “Priority Pesticides” for possible substitution without any clear definition of “Priority Pesticides,” a process that is ripe for manipulation. Given the substitutions that are occurring now, we cannot assume that further substitutions would be less toxic. SPM puts the classification of “Priority Pesticides” into the hands of “stakeholders” without clearly identifying who stakeholders are. SPM says “stakeholders” were involved in the development of the proposed policy. Those stakeholders included only users and promoters of pesticide use. There was no representation on the Urban Sub-Group of organizations such as Californians for Pesticide Reform, California Environmental Health Initiative, Beyond Pesticides, Center for Environmental Health, Environmental Working Group, etc. Nor was there any visible expertise in the fields of science that are capable of analyzing and evaluating the impact of pesticides, such as soil science, endocrinology, toxicology, entomology, botany, biology, or horticulture. SPM ensures that this exclusion will continue during the implementation phase by suggesting that “experiential and observational” knowledge should be represented on an equal footing with undefined “science.” The word “science” is being used and abused by advocates for pesticide use who dangle it as a magic talisman, conferring fraudulent credibility.
As a long-time reader of Jake Sigg’s Nature News, I am very familiar with his passionate crusade against Oxalis pes-caprae. When oxalis appears in the landscape in January, Jake gears up his campaign again. This year the WestsideObserver published an article by Jake about oxalis that reaches a new level of urgency and asks land managers to increase their use of herbicides to kill the plant.
In the past, Jake has advised careful and relentless hand-pulling of oxalis with its bulb intact. Now he acknowledges that hand-pulling is useless to eradicate oxalis. Although herbicides have been used on oxalis in San Francisco’s parks for 25 years, Jake now wants MORE herbicides to be used. Over 20% of all herbicide spraying by the Natural Resources Division (NRD) of the Recreation and Park Department was applied to kill oxalis in “natural areas” in 2022. NRD sprayed oxalis 35 times in 2021 and 38 times in 2022.
From January to March, virtually all the herbicides sprayed by NRD in the so-called “natural areas” were sprayed on oxalis. If it were possible to eradicate oxalis with herbicide, why is there more oxalis now than there was 25 years ago, when NRD (then known as the Natural Areas Program) started spraying herbicides in the “natural areas?” A lot of herbicide has flowed under the bridge in the past 25 years, but oxalis thrives. What is the point of pouring more herbicide under the bridge of sighs? We’re pouring more fuel on the fire with nothing to show for it.
The University of California Integrated Pest Management Program explains why it’s not possible to eradicate Oxalis pes-caprae with herbicides: “Several postemergent herbicides including triclopyr and fluroxypyr (selective for broadleaf plants) and glyphosate and glufosinate (nonselective) effectively kill the top growth of this weed but are harmful to most ornamentals, so be careful these herbicides don’t drift onto desirable plants. These herbicides don’t kill the bulbs, and regrowth from bulbs should be expected.” In other words, you can kill the above-ground top growth and other non-target plants in the vicinity, but you won’t kill the oxalis.
On one hand, Jake urges public land managers to escalate chemical warfare against oxalis. On the other hand, he accuses oxalis of “chemical warfare” (AKA allelopathy), secreting chemicals that kill other plants. This accusation is pure speculation on Jake’s part. He offers as “evidence” of his speculation that after oxalis dies back in April “we’re left with bare ground for the rest of summer and autumn.” He ignores the obvious fact that annual spraying of gallons of herbicide on oxalis in the “natural areas” could be causing the bare ground. It has apparently not occurred to him that many herbicides are non-selective, killing everything they touch, not just targeted plants. And those herbicides that claim to be selective are very mobile in the soil, capable of killing adjacent plants through their roots. If you don’t want to see bare ground, don’t spray herbicides!
The study explains why oxalis does not suppress the growth of other plants, including natives. Oxalis makes more phosphorous available in the soil, which essentially acts as a fertilizer for other plants: “These results are consistent with our field data and suggest that Oxalis may improve P availability in the field.”
This study was published in 2007. It found that Oxalis pes-caprae does not suppress the growth of other plants and, in fact, increases nutrients in the soil. Jake apparently doesn’t know about this study and related studies that found that pollinators are as interested in O. pes-caprae as they are in native plants.
Jake’s accusation that oxalis is waging “chemical warfare” against native plants does not come out of nowhere. The same accusation was used against eucalyptus trees for decades until a definitive empirical study proved that eucalyptus is not allelopathic. The California Invasive Plant Council removed that accusation from its evaluation of Blue Gum eucalyptus in 2015 (along with the accusation that eucalyptus kills birds). As the readers of Jake’s Nature News know, his hatred of eucalyptus is second only to his hatred of oxalis. There was never evidence that eucalyptus is allelopathic and there is no evidence that oxalis is allelopathic.
Does biodiversity justify poisoning nature?
Jake justifies his crusade against oxalis based on his belief that its existence threatens biodiversity. Since there is no evidence that oxalis kills other plants, there is no reason to believe its existence threatens biodiversity.
Jake also asks us to include only native plants in the measure of biodiversity, but he is alone in that belief. Scientific measurements of biodiversity include all species of plants and animals, whether considered native or non-native. The Recreation and Open Space Element of San Francisco’s General Plan explicitly acknowledges that both native and non-native plants contribute to biodiversity:“Parks and open spaces in San Francisco include both native and non-native species, both of which can contribute to local biodiversity.” (Policy 4.1, Recreation and Open Space of San Francisco General Plan)
Jake ups the ante against oxalis by claiming that wildlife requires solely native plants, a fundamental tenet in native plant ideology. Again, this claim is unsupported by evidence. As Professor Art Shapiro (UC Davis) says in his Field Guide to Butterflies of the San Francisco Bay and Sacramento Valley Regions,“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.”
On one hand, Jake claims that oxalis deprives birds and other foragers of food. On the other hand, Jake acknowledges that oxalis is foraged by gophers and scrub jays (based on one observation). Jake wants it both ways because that serves his purpose.
If native plants were any benefit to wildlife, that benefit is quashed by the widespread use of herbicides being used in the “natural areas.” For example, Himalayan blackberries are an important source of food for birds and other wildlife in San Francisco’s parks and are also eaten by children visiting the parks. The blackberries are routinely sprayed with herbicides in the so-called “natural areas.” Wildlife is exposed to the herbicides and they are also deprived of important sources of food.
A recent survey of 24,000 gardens in the UK found that pesticide use had a significant effect on bird life. The study found that gardens that used pesticides had fewer species of birds than similar gardens that did not use pesticides:
“Pesticide spraying impacted the positive effect [surrounding habitat quality] had on bird richness. Specifically, ‘species richness [number of species] increases with the surrounding quality, both for gardens that do not use pesticides and for gardens that applied pesticides, but this effect is significantly less strong when pesticides are applied’ the study indicates. Scientists zeroed in on three active ingredients: the weed killer glyphosate, the neonicotinoid insecticide acetamiprid, and the synthetic pyrethroid deltamethrin as resulting in the most damaging pesticide impacts to bird species’ richness.” Note that the study’s definition of “surrounding habitat quality” made no distinction between native and non-native plants. The British are not strong supporters of native plant ideology.
Nativists keep using huge quantities of herbicide to kill vegetation they don’t like, while also claiming that their eradication projects benefit birds. This is a fundamental contradiction. Their eradication projects are harmful to birds and other creatures that live in our parks and open spaces.
In his article, Jake laments that people are accepting changes in the landscape because they don’t remember what the landscape looked like 100 years ago. His “baseline view” of what landscapes should look like is much further in the past than most people’s memories of the landscape.
The climate has changed significantly in the past 100 years. When the climate changes vegetation changes. We should welcome the changes because they are required for the survival of any landscape. When the climate changes, plants and animals must move, adapt, or die. The changing landscape is an indication that plants are adapting to changing conditions.
We cannot stop evolution, nor should we try. Herbicides are a futile attempt to stop evolution. Herbicides cannot stop evolution, because plants evolve a resistance to them. After 25 years of constant herbicide use in San Francisco’s parks and open spaces, we should assume that they are less effective every year.
I welcome comments on my website because I often learn from them. This comment on a recent post inspired me to think about why I often put the word “restoration” in quotation marks when describing projects that are more destructive than constructive:
Oh my, we are back to putting quotes around words we don’t like. An excerpt from this article:
“Many ecological studies and associated “restoration” projects adopt the same viewpoint that destruction is a justifiable method of studying and “restoring” ecosystems. “Restoration” projects often begin by killing all non-native plants with herbicides before attempting to create a native landscape.”
Often? We do a fair amount of underburning around here, primarily to “restore” ecosystem structure and function in mixed conifer. Of the burns I have been involved with, not one involved herbicides and pesticides. I think you put the lie to your own article by this one exaggeration. I suspect if I bothered to look I would find many others.
This is my reply to this comment:
When the word restoration is used appropriately, it is a powerful, positive word. There is a multitude of potential projects in California that would be restorative. Here is a brief list:
There are thousands of “impaired waters” in California identified by the California Clean Water Act, such as septic tanks that leak sewage into our waterways and waters contaminated with mercury and other toxic chemicals.
Dr. Jon Keeley is a respected fire scientist with US Geological Service with expertise in chaparral ecosystems. He explained that 60% of native chaparral species (notably manzanita and ceanothus) are obligate seeders that do not resprout after fire and therefore depend on their dormant seed bank for regeneration. In recent decades the fire interval in chaparral has decreased due to climate change and associated drought. In many places the fire interval has become too short to establish the seed bank needed for regeneration. In those places Dr. Keeley has observed vegetation type conversion to non-native annual grasses. Dr. Keeley Is concerned that vegetation type conversion from forests in some cases and shrublands in others to non-native annual grassland may be the result of shortening fire intervals further “because of the upsurge in state and federal programs to utilize prescription burning to reduce fire hazard.”
Another presentation about a 20-year effort to convert non-native annual grassland to native grassland using prescribed burns at the Santa Rosa Plateau Ecological Reserve reported their failure: “Non-native grass cover significantly decreased after prescribed fire but recovered to pre-fire cover or higher one year after fire. Native grass cover decreased after prescribed fire then recovered to pre-burn levels within five years, but never increased over time. The response of native grass to fire (wild and prescribed) was different across time and within management units, but overall native grass declined.” The audience was audibly unhappy with this presentation. One person asked if the speaker was aware of other places where non-native grass was successfully converted to native grass. The speaker chuckled and emphatically said, “NO. I am not aware of any place where native grasses were successfully reintroduced.”
When describing projects that are more destructive than constructive, I put the word “restoration” in quotes. I stand by that choice.
“Fifty years ago, Congress voted to override President Richard Nixon’s veto of the Clean Water Act. It has proved to be one of the most transformative environmental laws ever enacted.
“At the time of the law’s passage, hundreds of millions of gallons of raw sewage was dumped by New York City into the Hudson River every day. This filth was compounded by industrial contaminants emptied into the river along much of its length. The catch basin for all of this was New York Harbor, which resembled an open sewer. At its worst, 10 feet of raw human waste blanketed portions of the harbor bottom, and certain reaches held little or no oxygen to sustain the life of its fishery. Trash floated among oil slicks.
“Health advisories against eating fish from the Hudson remain, but its ecology has largely recovered, thanks to the law, which imposed strict regulations on what could be discharged into the water by sewage treatment plants, factories and other sources of pollution….”
The NYT article also describes how many animal species benefitted from the reduction in pollution in New York City’s harbor.
“The algal explosion is fueled by warming waters, combined with rising levels of nitrogen that come from the antiquated septic systems that most of the Cape still uses. A population boom over the past half-century has meant more human waste flushed into toilets, which finds its way into waterways.
“More waste also means more phosphorus entering the Cape’s freshwater ponds, where it feeds cyanobacteria, commonly known as blue-green algae, which can cause vomiting, diarrhea and liver damage, among other health effects. It can also kill pets.
“The result: Expanding aquatic dead zones and shrinking shellfish harvests. The collapse of vegetation like eelgrass, a buffer against worsening storms. In the ponds, water too dangerous to touch. And a smell that Ms. Fisher characterizes, charitably, as “earthy.”
“Together, the changes threaten the natural features that define Cape Cod and have made it a cherished destination for generations.”
This an example of the many missed opportunities to restore the environment. Instead of addressing the sources of pollution, such as leaky septic tanks and sewage systems, we invest in projects that contribute to pollution by spraying harmless vegetation with herbicides, killing harmless animals with pesticides and contributing to air pollution by burning vegetation.
Closer to home, the recent torrential rain soaking California is a reminder of our inadequate sewer systems now overflowing from storm drains into city streets and being dumped into the ocean when the drainage gets that far. San Francisco’s antiquated sewage system is an extreme case. When it was built, it funneled storm runoff from city streets into the city’s sewer system, combining residential sewage waste with storm water runoff. When it rains heavily, San Francisco’s sewage system is not capable of treating the increased flow. Such systems have been illegal for decades, but San Francisco has not made the necessary improvements to its sewer system. As the SF Chronicle reports, city streets are now flooded with a toxic mix of rain water and human sewage.
“Restoration” is not a dirty word when used to describe projects that reduce pollution. When projects contribute to pollution they cannot legitimately be called “restorations.”
“This is a superb book. Laura Martin’s research takes us where no restoration literature has gone before, asking, ‘Who gets to decide where and how wildlife management occurs?’ Martin tackles this question with unmatched clarity and insight, illuminating the crucial discussions we must have to secure a future with thriving natural species and spaces.”—Peter Kareiva, President and CEO, Aquarium of the Pacific
The author of Wild by Design, Laura J. Martin, is a professor of environmental history at Williams College.(1) She has written a comprehensive history of ecological restoration in the US that is consistent with my own observations of the restoration industry in the past 25 years. It’s a story of the gradual transition from a conservation ethic to a preservation ethic and finally to the restoration ethic that we see today. The story is punctuated by milestone federal laws and actions that facilitated the transition. Environmental non-profits and academic ecologists used those laws to professionalize and monetize the restoration industry that exists today.
By the end of the 19th Century, the public began to react to the environmental degradation caused by unregulated resource extraction. In 1902, a survey of naturalists around the country determined there were 1,143 bison left in the country; virtually all were in captivity. The American Bison Society was founded in 1905 in reaction to the disappearance of bison in America. Their activism led to the creation of federal game reserves on former Indian reservations where captive bison were introduced. The game reserves were the model for the National Wildlife Refuge system that was greatly expanded by President Teddy Roosevelt.
A photograph from 1892 of a pile of American bison skulls in Detroit, Michigan waiting to be ground for fertilizer or charcoal. (Photo Wikimedia Commons)
The creation of the Wild Flower Preservation Society (WFPS) in 1901 was modeled on the successful campaign of the Audubon Society to save birds killed to serve as ornaments on fancy hats. It was as much a campaign to shame women into abandoning the fashion fad as it was an effort to legally ban the practice. Likewise, the Wildflower Preservation Society applied social pressure. They were critical of organized excursions to visit wildflowers because they picked and trampled the wildflowers. WFPS said that “Weddings are a new menace to our native plants” because of their use of wild flowers. Their criticism was initially aimed at their own community, but “it moved toward policing the behavior of so-called new immigrants to the United States—especially children.” The moralistic scolding by these early native plant advocates was a preview of the finger-wagging now aimed at those who choose to plant a diverse garden.
These advocacy organizations are precursors to the many environmental non-governmental organizations that are influential in pressuring government to invest in ecological restorations today.
Conservation and Preservation
The goals of conservation and preservation are similar, but some differences were observable in the past 200 years. Both ethics are committed to protecting the environment, but conservation allows the sustainable use of natural resources while preservation protects nature from use. The presidencies of both Teddy and Franklin Roosevelt were committed to conservation.
Teddy Roosevelt created the US Forest Service based on the premise that government can and should regulate public lands to manage natural resources. Franklin Roosevelt’s conservation programs were based on the same principle, but were motivated by the economic emergency of the depression as well as the environmental disaster of the Dust Bowl in the Midwest. The Civilian Conservation Corp (CCC) was created to provide jobs as well as to plant a “shelter belt” of trees across the Midwest of the country as a windbreak to stop dust storms (and many other projects). Ecologists were critical of CCC projects because they expanded recreational opportunities and put “a stamp of man’s interference on every natural area they invade.” They preferred to exclude humans and their activities from nature. This is another early indicator of the conflicts between preservation and conservation that persist to the present day.
Government investment in ecological research
Ecological research in the United States was fundamentally altered after World War II, which ended with the beginning of the atomic era. Atomic bombs were dropped on Japan to end the war without much thought given to the consequences. After WWII, the federal government made big investments in science, creating the Atomic Energy Commission and the National Science Foundation, which funded ecological research to study the impact of radiation on the environment and those who live in it. Conservation Sense and Nonsense published an article about those studies and the impact they had on ecological research.
These studies legitimatized destruction of ecosystems to study effects of the destruction and the concept was expanded from radiation to pesticides in the 1960s. They also provided funding to the academic profession of ecology that was small and is now enormous. The dependence of ecological studies on government funding remains to this day and government funding of ecological projects has created the restoration industry that now extends far beyond academia. Destruction of existing habitat is still considered the prerequisite to restoring a historical landscape. Often, destruction is the first and only stage of the project because of the persistent fantasy that the native landscape will regenerate without further help.
In the late 1960s Daniel Simberloff tented and fumigated 6 mangrove islands off the eastern short of Florida with methyl bromide to kill all life on the islands. The objective of the project was to study how long it would take to repopulate the islands with insects.
From Conservation to Restoration
The post-war economic boom of the 50s and 60s greatly increased the impact of human activities on the environment. The federal government built a vast highway system that fragmented and disrupted ecosystems. We built huge dams, and channeled riparian ecosystems. Open space was rapidly covered by housing and industrial development. Wetlands were drained and filled with rubble to create more land.
People who cared about the environment began to react to the loss of nature and wildlife that lives in nature. Although Aldo Leopold is idolized by the native plant movement, his concern about the degradation of nature was primarily for wildlife. His interest in vegetation was as habitat for wildlife. He was opposed to government programs devoted to killing animals perceived as predators of game animals because he believed that wildlife is best served by expanding their habitat. In fact, he was opposed to the expansion of government’s role in conservation because “he believed restoration would be most efficient and effective if pursued by private citizens.” He did not prefer native plants because “Farmers had the opportunity to conserve plants such as ragweed and foxtail (an introduced grass), ones ‘on which game, fur, and feather depend for food.’” In other words, in the 1940s one of the icons of the native plant movement knew that wildlife is not dependent upon native plants for food. One wonders if native plant advocates have actually read Leopold’s treatise, A Sand County Almanac.
Aldo Leopold’s son, Starker Leopold, had as much impact on conservation in the United States as his father. In 1963, he published the Leopold Report that changed the direction of conservation in the National Park Service. The Leopold Report recommended a goal for national parks of maintaining historical conditions as closely as possible to those of “primitive America.”When the Leopold Report was adopted as official policy by the National Park Service in 1967, it committed NPS to restoring park lands to pre-settlement conditions.NPS officially changed this policy in 2021, but we don’t see any change locally in their projects because NPS is decentralized and local parks are autonomous.
Professor Martin says that “historical fidelity did not become a widespread restoration goal among ecologists and environmental organizations until the 1980s.” The arrival of Columbus in the new World in 1492 was arbitrarily selected as the date after which all new plant species were “deemed nonnative, unwanted reminders of human (colonist) presence and activity.” On the West Coast, 1769 is the equally arbitrary date to confer non-native status because it is the date of the first Spanish expedition to California.
Many now question the goal of replicating historical landscapes. After 40 years of effort, there is a growing recognition that it is not a realistic goal, especially in a rapidly changing climate. The Society for Ecological Restoration has changed its definition of ecological restoration from “the goal of intentionally altering a site to establish a defined, indigenous, historic ecosystem” in 1990 to “the process of assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed” in 2002. Try telling that to the restorationists on the ground who are still trying to eradicate naturalized non-native plants that have been here for nearly 200 years. Non-native annual grassland in California is a case in point. It has been repeatedly burned, mowed, plowed, and poisoned for 25 years without any visible progress toward native perennial grassland.
Blaming non-native species
Around the same time that historical fidelity was identified as the goal of “restorations,” land managers and ecologists decided that the existence of non-native species is the main threat to native species. I suppose the “logic” was that the main difference between historical landscapes and present landscapes is the existence of non-native species. Concern about non-native species spread among federal agencies such as the National Park Service and The Nature Conservancy (TNC) began aggressive campaigns to kill non-natives, “which were newly framed as the main threat to wild species…nativity would become a precondition to wildness—of plants and animals both.” TNC’s methods have become increasingly deadly and destructive: using fire and herbicides to kill plants, poisoning honeybees, aerial hunting of sheep, pigs, and goats. As a former donor to TNC, their methods finally became intolerable to me.
Professor Martin believes that the identification of non-native species as the scapegoat was not based on experimental evidence, but merely a description of the strategies used by public land managers, as well as The Nature Conservancy. Non-native species were a convenient scapegoat because they were easily identified and were an easy substitute for identifying and remediating the underlying conditions causing so-called “invasions.” “Although the role of invasive species in native species extinction has since been challenged by some ecologists, the influence of this fear on species management has been enormous…The US federal budget for invasive species management increased by $400 million between 2002 and 2005, for example.”
Endangered Species Act
The Endangered Species Act (ESA) was passed in 1973, along with companion laws such as the National Environmental Protection Act and others. These federal laws created more funding opportunities for ecological projects as well as the legal justification for ecological restoration projects.
Federal laws permit the reintroduction of legally protected plant and animal species to places where they no longer exist. The ESA confers the same protections for reintroduced species as it does for naturally occurring species. Such reintroductions have become a tool for the restoration industry. I have seen that strategy used in the San Francisco Bay Area. If we had not been successful in preventing the reintroduction of a legally protected turtle, it would have justified the destruction of the non-native forest in my neighborhood park because the turtle requires unshaded nesting habitat within 500 feet of the water source in the park. The park remains largely forested because that is one of the few battles we have won in 25 years. Reintroduced, legally protected species are the Trojan horses of ecological restorations.
Compensatory mitigationis an equally powerful tool for the restoration industry. Federal law requires an Environmental Impact Statement (EIS) for projects that will have a significant impact on the environment, such as big developments like building Disney World in Florida. Disney World was built on an enormous wetland that was lost by the development of the park. The EIS for the project agreed that the impact would be great, but it “mitigated” the impact by requiring Disney to fund the creation of a new wetland in a distant location.
The funding generated to create fake wetlands built a new industry of commercial companies to design and build them. Academic restoration ecologists questioned the functional equivalency between created and natural wetlands: “’however accurate [the Comprehensive Everglades Restoration Plan] is the restored community can never be authentic.’” The tension between commercial and academic restorationists continues today.
The Society for Ecological Restoration published findings that mitigation wetlands were not functionally equivalent to the wetlands they were meant to replace. In Florida only half of the promised mitigation projects were actually built. Those that were built were colonized by “undesirable plant species” such as cattail and melaleuca in 32 of 40 projects.
Projects that earn carbon credits are creating the same opportunities to generate funding for restoration projects in distant locations. The Nature Conservancy was successful in defining carbon offsets as an international market when the Kyoto Protocols were signed in 1997. They understood that a reforestation project would be cheaper in Costa Rica (for example) than a comparable energy efficiency project in the US. Such distant projects don’t benefit those in the US who now have a power plant in their backyard that is being offset by a forest in Costa Rica.
It’s a game for those who know how to play. I have witnessed local examples in the Bay Area. An oil spill in the bay generated millions of dollars of compensatory damages to fund unrelated “restoration” projects. How does planting eel grass compensate for hundreds of birds killed by the oil spill? When the San Francisco airport expanded runways, the airport had to pay compensatory mitigation that funded the restoration of native plants at India Basin in San Francisco that hardly compensates for the increased air traffic enabled by the new runway.
Professor Martin is surprisingly frank about the future of ecological restoration in America:
“Whatever paths restorationists choose, restorations must happen in tandem with other changes in human behavior. If we don’t reduce the ongoing harms of racism, fossil fuel burning, overconsumption by the wealthy, and toxic industrial chemicals, restoration will offer no more than a temporary repair, a way to move a problem to some other place or time.”
I would go one step further in my assessment of the restoration industry. I would say that the methods used by restorationists are directly contributing to environmental degradation.
Professor Martin asks the right questions in her concluding chapter: “Who benefits from restoration? Who is harmed?” Those who earn their living in the restoration industry are the primary beneficiaries. According to a 2015 study entitled “Estimating the Size and Impact of the Ecological Restoration Economy,” environmental regulation has created a $25 billion-per-year restoration industry that directly employs more people than coal mining, logging or steel production. Given recent investments in restoration projects of billions of dollars by California and federal infrastructure funding, this figure is undoubtedly an underestimate.
Who is harmed?Wildlife and humans are harmed by the destruction of useful habitat with herbicides. Harmless animals and plants are killed because they have been arbitrarily classified as “invasive.” And all Americans are harmed by the waste of public funds that could be used to benefit society and/or the environment.
(1) Laura J. Martin, Wild by Design: The rise of ecological restoration, Harvard University Press, 2022. All quotes are from this book.
Laura J. Martin is an environmental historian at Harvard University. She wrote two articles (1,2) about the origins of ecological field studies that might help explain the destructive methods still used today by some ecologists. Professor Martin “contendsthat the history of ecosystem science cannot be separated from the history of nuclear colonialism and environmental devastation in the Pacific [Nuclear Testing] Grounds” (2)
When the US dropped two atomic bombs on Japan in 1945, little thought was given to the consequences of atomic bombs because ending the war in the Pacific was the only consideration. Japan surrendered to the US less than one month after the bombs were dropped, effectively ending World War II.
Few doubt that the use of atomic weapons was instrumental in ending World War II. After the war, there was a more sober effort to determine the consequences of using atomic weapons. Some believed that nuclear weapons might replace conventional warfare. Others wanted to understand the impact on life on the planet before making such a momentous decision. This effort was focused on practical considerations such as the impact on the world’s fisheries and food supply. The objective of their initial studies was less concerned about long-term consequences for the environment such as the duration of impacts on living creatures and the environment in which they live.
The US federal government invested heavily in the sciences after World War II. The Atomic Energy Commission (AEC) was established in 1946 and the National Science Foundation (NSF) in 1950. The availability of federal grant funding for academic institutions “dramatically reconfigured the relationships among federal, academic, and corporate spheres.” (2) Increased federal funding greatly increased the number of academic research projects.
Between 1945 and 1970, the US detonated 105 nuclear weapons. The Atomic Energy Commission and later the National Science Foundation paid academic ecologists to conduct field studies at the test sites to determine the impact on animals.
In 1963 the US, Soviet Union, and Great Britain signed a Partial Test Ban Treaty that prohibited all non-wartime detonations except for those done below ground. Testing of the effects of radiation by academic scientists continued because the AEC mass produced radioisotopes and distributed them to American institutions. Scientists were no longer constrained to field sites where atomic bombs had been detonated.
“Thus began a period in which ecologists purposefully destroyed ‘ecosystems’ to study how they recovered.”
Laura Martin, “The World in Miniature”
The availability of radioisotopes made laboratory testing possible, but it also enabled large-scale atomic irradiation experiments such as a forest irradiation project in Georgia that exposed 300 acres of forest to an air-shielded reaction (?) that produced radiation levels comparable to expected fallout following a nuclear catastrophe. The purpose of that experiment was to determine the impact of radiation on forests. The findings were that some tree species were more vulnerable to radiation than others. This finding contributed to the hypothesis “that the greater number of species in an ecosystem, the better that system will be ‘adjusting to stress.’” (1) This is the familiar theory that greater biodiversity enhances resiliency of ecosystems against stressors such as climate change. It remains a cornerstone of conservation science.
These studies are also responsible for the knowledge that radiation—and many other toxic substances such as chemicals—bioaccumulate, first described publicly in 1955, according to Martin. Many toxic substances persist in our bodies throughout our lifetime. The longer we are exposed to them, the more dangerous they are to our health. Women who were exposed to DDT before it was banned in 1972 still have higher levels of DDT in their bodies than women born after 1972. Many toxic chemicals also bioaccumulate in food webs. Top predators in the food web are more heavily burdened with poison than animals at the bottom of the food web because of biomagnification.
Using pesticides to study impacts and recovery
The concept of destroying an ecosystem for the purpose of studying impacts and recovery from impacts was soon extended to using pesticides. In a study funded by NSF in the 1960, herbicides were repeatedly applied to clear-cut plots in the White Mountain National Forest to compare the runoff from “disturbed” watershed with “undisturbed” control watersheds. “They concluded that forest clear-cutting led to the leaching of nutrients from the soil, and ultimately, algal blooms in downstream waters.” (1) (Yet, 60 years later, spraying clear-cuts with herbicides is still the norm in the timber industry.)
Destructive methods used by Daniel Simberloff
The first publication (3) in 1969 of Daniel Simberloff’s academic career was a report of his Ph.D. dissertation project under the direction of EO Wilson at Harvard University. He tented and fumigated with methyl bromide 6 mangrove islands off the Eastern shore of Florida to kill all the insects. His objective was to study how long it would take for insects to recolonize the islands.
Although Simberloff monitored the islands for only one year, he concluded, “The colonization curves plus static observations on untreated islands indicate strongly that a dynamic equilibrium number of species exists for any island.” (3) This is an example of the generalized conclusions of ecological studies noted by Professor Martin: “With ecosystem studies, ecologists claimed that fieldwork conducted in one place could be used to understand other distant and different places. The Pacific Proving Grounds became a model for lakes in Wisconsin, rain forests in Panama, deserts in China…” (2)
Laura Martin says of Simberloff’s study, “Destruction thus became a method of studying ecosystems. As Eugene Odum put it: ‘ecologists need not feel bashful about attacking ecosystems so long as they observe the rules of good science.’” (1)
Methyl bromide used by Simberloff in his thesis project is known to deplete the ozone layer of the atmosphere that shields the Earth from harmful Ultraviolet light that causes skin cancer. Its use was severely restricted by an international treaty in 1989. However, it is still used in the US for agricultural crops as a soil sterilant that kills all living organisms in the soil.
Nearly 60 years after the publication of his Ph.D. study, Daniel Simberloff remains one of the most vocal advocates for the eradication of non-native plants and animals. With few exceptions, those eradications require the use of pesticides. Simberloff may not have known the damage that methyl bromide does in the environment at the time of his study, but surely he knows or should know now. Yet, he is still committed to the eradication of non-native plants, projects that require the use of pesticides.
Many ecological studies and associated “restoration” projects adopt the same viewpoint that destruction is a justifiable method of studying and “restoring” ecosystems. “Restoration” projects often begin by killing all non-native plants with herbicides before attempting to create a native landscape. Rodenticides and insecticides are used to kill non-native animals with the understanding that many native animals will inevitably and unintentionally be killed. The Endangered Species Act accommodates the by-kills of these projects by issuing permits for “incidental takes.” The law and the scientific community make a distinction between killing individual animals and killing animals on a scale that threatens the survival of the species.
Killing and destruction were established as legitimate scientific tools over 70 years ago. Given what we know now about pesticides and radiation and at a time when habitats are being destroyed by human activities and climate change, is it time to question the legitimacy of habitat destruction as a scientific tool?
Professor Martin is also the author of her recently published book, Wild by Design: The Rise of Ecological Restoration. I look forward to reading it. Meanwhile, I hope Professor Martin’s papers about the destructive origins of ecological field studies are a preview of her book.
Update: I have read and summarized Wild by Design in this article, published January 7, 2023.
Happy New Year! We hope 2023 will be a more peaceful year.
I am publishing my letter to the Albany City Council about the City’s plans to destroy most of the eucalyptus forest on Albany Hill. I am publishing it in three segments because it is long. The first segment explained why it is not necessary to destroy the forest. The second segment explained the consequences of destroying the forest. The third and final segment explains why it is unlikely that the forest can be replaced by native trees.
Now you have my version of the full story. If this is a place or an issue you care about, please consider writing a letter of your own to the City Council of the City of Albany.
Conservation Sense and Nonsense
Albany Hill. Source: Google Earth
December 5, 2022
Albany City Council 1000 San Pablo Ave. Albany, CA 94706
Dear Albany City Council:
SEE Part I and Part II of Appealing to the City of Albany to save its eucalyptus forest. Part III is the concluding segment:
The uncertain fate of monarchs on Albany Hill is a suitable introduction to my final issue. The proposed plans for Albany Hill claim the destroyed eucalyptus forest will be replaced by new trees. I will explain why it is unlikely that the eucalyptus forest can be replaced by another forest. Plans for a newly planted forest are described in various ways, some of which seem contradictory:
“[Margot] Cunningham’s [Albany’s Natural Areas Coordinator] team is pursuing grants to cut down most of the blue gums and plant the city’s side of the hill with a mix of native species and more drought tolerant trees for monarchs to roost.” (1)
“WHEREAS, the City is investigating consultants to design a plan to remove eucalyptus in a way that retains and restores more fire-resilient native plant communities and minimizes soil disturbance and soil erosion.” (2)
“More droughty Eucalyptus species can be planted to preserve the butterfly habitat.” (3)
“This plan will include but is not limited to: plantings of other tall trees in areas of the hill where monarchs have traditionally clustered; survey of the existing native understory which will be allowed to grow after eucalyptus removal; and analysis and design of additional plants of Albany Hill-sourced native plants.” (4)
Somehow, this diverse, drought-tolerant, fire-resilient, tall, native (with droughty eucalyptus species?) forest is expected to survive without irrigation: “If drought-tolerant tree species are planted as seedlings, in the fall with sufficient planting site preparation and adequate rain fall, minimal if any irrigation will be required.” (5)When predicting the fate of the existing eucalyptus forest, the plans assume that the drought will continue. When predicting the fate of a replacement forest, the plans assume that the drought will end.
Most public land managers irrigate newly planted trees (whether native or non-native) for at least 3 years. Established trees rarely require irrigation to survive because they have extensive root systems that have better access to moisture in the soil than newly planted trees without extensive root systems. Tree species that are drought-tolerant when mature trees, require irrigation as they grow their root systems. Replacing healthy trees that don’t require irrigation with new trees that require irrigation seems an unwise choice in the middle of an extreme drought.
The City of Albany should have learned that lesson when they built Peggy Thomsen Pierce Street Park at the western foot of Albany Hill. Only native trees were planted in that park. They weren’t irrigated. Five years after the park opened in 2017, most of the trees are dead (see below):
Peggy Thomsen Pierce Street Park, November 2022. Conservation Sense and Nonsense
The City of Albany’s list of approved street trees is a valuable source of information about what tree species are capable of growing in Albany. A tree species that cannot survive conditions for street trees is also unlikely to survive on the ridgeline of Albany Hill, where wind conditions are extreme and there is little moisture. There are about 65 tree species approved for planting as street trees in Albany. Five are native to California, but only three are native to the Bay Area. Native big leaf maples are said to be “in decline.” Buckeyes aren’t suitable street trees, but may be suitable for open space. None of the listed native trees are suitable monarch habitat for a variety of reasons: canopy too dense to provide sufficient sunshine; deciduous therefore bare in winter; short stature, etc.
Historically, areas on Albany Hill that are now forested with eucalyptus were treeless because native trees are not adapted to the challenging climate conditions. If the eucalyptus forest on Albany Hill is destroyed, Albany Hill is likely to be treeless again. That is the horticultural reality of Albany Hill.
It is not necessary to destroy the eucalyptus forest on Albany Hill because it is not dead.
Destroying the eucalyptus forest on Albany Hill will increase fire hazards and safety hazards.
Destroying the eucalyptus forest will destroy habitat of monarch butterflies.
Plans to replace the eucalyptus forest with native trees are unrealistic.
Please consider reinstating the 2012 Albany Hill Creekside Master Plan. It is still a good plan that will not do unnecessary damage to Albany Hill and its human and animal visitors.
cc: Albany Fire Chief Albany Natural Areas Coordinator Albany Urban Forester Creekside Science
I am publishing my letter to the Albany City Council about the City’s plans to destroy most of the eucalyptus forest on Albany Hill. I am publishing it in three segments because it is long. The first segment explained why it is not necessary to destroy the forest. The second segment explains the consequences of destroying the forest. The final segment will explain why it is unlikely that the forest can be replaced by native trees.
Conservation Sense and Nonsense
Albany Hill. Source: Google Earth
December 5, 2022
Albany City Council 1000 San Pablo Ave Albany, CA 94706
The premature destruction of the eucalyptus forest will have many negative consequences:
The loss of significant amounts of fog drop from the tall trees.
The creation of tons of wood debris that will contribute to fire hazards
The regrowth of the trees into unstable multi-stemmed trees with lower fire ladders
The loss of habitat for overwintering monarch butterflies
Harold Gilliam in Weather of the San Francisco Bay Area informs us that tall non-native trees in the East Bay produce significant amounts of water by condensing fog drip: “Eucalyptus and pine groves planted there long ago intercept large amounts of fog and cause a rainlike deposit of moisture. The fog drip during the summer months has been measured at a surprising 10 inches, an amount nearly half as great as the total rainfall…” Average rainfall in the East Bay is 21 inches per year, so this fog precipitation adds nearly 50% to total precipitation.
One of the planning documents for the tree removal project on Albany Hill speculates that there is less fog than in the past in the San Francisco Bay Area. According to an article in the New York Times, many people disagree with that assumption.
By precipitating fog drip during the otherwise dry time of the year, tall non-native trees reduce fire danger during the fire season. Moisture on the forest floor helps to retard ignition and slow the spread of fire. This was observed recently on the west side of Albany Hill when an arsonist set the forest afire in June 2022: “The Albany Hill fire, which was initially estimated around three acres with a slow rate of spread…” The fire was quickly extinguished.
This is where the fire in June 2022 occurred on Pierce St. Note resprouts of the burned trees in November 2022. Conservation Sense and Nonsense
Fog drip from the eucalyptus overstory is also irrigating the forest understory of many native shrub species, predominantly toyon. Historical records of Albany Hill tell us toyon was not there before eucalyptus was planted. The top of the hill is the driest area because it does not benefit from run off compared to lower elevations of the hill. The side of the hill facing the southwest is drier than northeast face of the hill because it is exposed to more sun and wind. Historically, oaks grew only on the northeast side of the hill where they were sheltered from the wind and the soil was moister. One of many questions about the new plans for Albany Hill that should be asked and answered is how the existing native understory can survive without fog drip and the wind shelter of the tall trees.
The City of Albany’s application for a grant from the California Coastal Conservancy predicts this future for Albany Hill: “The project will create more fire-resilient and healthy ecosystems by allowing native plant communities to return after eucalyptus removal…” In fact, the opposite outcome seems more likely. Without the benefit of fog drop from the tall trees and shelter from the wind, the existing native understory is unlikely to survive. The existing native understory did not exist on Albany Hill prior to the planting of eucalyptus.
This map (see below) of tree removal plans for Albany Hill shows where approximately 400 trees will be removed at the top of the hill. (The number of each tree planned for removal is listed on this map, some in sequences such as 1-25, indicating that 25 trees will be removed between the arrows on the map.)
Source: Arborist Report, SBCA Tree Consulting
Returning to the question of fire hazards, what will happen to all that dead wood? We get a preview of the answer to that question because the City of Albany recently destroyed between 14 and 20 eucalyptus trees (reports on the number of destroyed trees vary). We can see what happened to some of the wood (see below):
Some of the destroyed trees are still lying on the ground (see below). This tree has already resprouted.
Multiply that flammable wood debris by 400 to get a picture of the amount of wood debris the proposed project on Albany Hill will create. The arborist’s report for the eucalyptus removal project makes this recommendation regarding wood debris: “Logs and chips to remain – Cut trees, chip brush and allow mulch and logs to remain on the slope.”
We had a recent experience with the wood debris created by similar projects when UC Berkeley destroyed all non-native trees within 100 feet of the north side of Claremont Ave in fall 2020. Huge piles of wood chips and logs were stacked along the road, which the grant application claimed would be disposed of by generating electricity in a biofuels plant. No such biofuels plant exists and there are no plans to build it. Here is a photo (see below) of one of the wood piles that remained along the road for about 9 months before being distributed elsewhere throughout the Berkeley hills:
Bay Nature recently explained why we are unable to dispose of wood debris from the many fuels management projects being done in California. If you ever wondered why there are piles of wood chips in your parks or why the roads in the hills are lined with logs, this article explains. There aren’t enough lumber mills in California to keep up with all the logs or biofuel plants to keep up with the wood chips. Most of the trees killed by bark beetles or by wildfire can’t be salvaged because of the shortage of mills. The wood debris is the fuel for the next wildfire. Turning living trees into dead wood debris does not reduce fire hazards.
In addition to reducing fire hazards, Albany’s new plans for the eucalyptus forest on Albany Hill are also intended to address safety concerns. Based on the assumption that the eucalyptus trees will soon die, Albany wishes to reduce public safety hazards by pre-emptively taking trees down before they fall down. As I’ve said before, the assumption that the trees will soon be dead is mistaken. Furthermore, Albany does not intend to use herbicides on the tree stumps to prevent resprouts, which guarantees that they will resprout, creating multi-stemmed trees that will be less stable than the trees are now.
According to the arborist’s report for Albany Hill, there is also a history of unstable trees that grew from resprouts of destroyed trees: “Stump sprouts – Sixty-nine (69) trees have developed as stump sprouts, or trees that have grown back from the stump after being cut down. Because the prior tree stump eventually rots, the new growth is not always well anchored.” The staff report to the City Council on May 13, 2021 about the project said, “Multi-trunk trees are weaker structurally and produce more fire-hazardous debris than single-trunk trees.”
Trees develop their defenses against the wind as they grow in a particular environment. When their tree neighbors are destroyed, they are suddenly subjected to more wind than they can withstand. The arborist employed by the City of Albany acknowledges the potential for increased risk of windthrow: “Stands of trees act together to resist wind forces. When trees are removed from a stand or grove, the wind forces on the remaining trees are increased. This can be a concern when trees, which are currently considered low risk, receive increased wind exposure due to adjacent tree removal.”
The unstable multi-stemmed trees that grow from resprouts will also be subjected to more wind without the protection of other trees that have been destroyed. The proposed plans for extensive tree removals will result in a more dangerous forest of resprouts that are vulnerable to windthrow.
Destroying 400 eucalyptus trees on Albany Hill would create an overwhelming commitment to control resprouts mechanically. It is a challenge that the City of Albany has not been able to meet in the past, as evidenced by recent resprouts and multi-stemmed trees from past resprouts. However, I don’t mean to imply that I prefer the use of herbicides to prevent resprouts. A new forest of young, unstable eucalyptus trees with lower fire ladders is better than a forest that has been poisoned and the understory with it. Herbicides are also harmful to monarch butterflies and other insects.
My last visit to the City park at the top of Albany Hill was on Sunday, November 20th, the weekend before Thanksgiving, which is the optimal time to see monarch butterflies in their winter roost. We saw many monarchs in the trees that are slated for destruction and as it got warmer in the early afternoon, we watched them flutter to nearby trees. There were many other park visitors. Some were frequent visitors who helped us find the biggest clusters. Other visitors were as excited as we were to find the monarchs for the first time. This is to say, the disappearance of monarchs on Albany Hill would be a disappointment to the visitors to the park.
Monarchs roosting in epicormic sprouts of eucalyptus on the top of Albany Hill, November 20, 2022. Conservation Sense and Nonsense
According to Stuart Weiss of Creekside Science, that’s where monarchs begin their visit to Albany Hill: “…monarchs begin the season on the ridgetop, likely attracted by high insolation [sunshine]. Following the first storms of the season accompanied by strong winds, they move down the SW slope when storm winds (generally southerly) are too strong. The structure of the forest in the Cluster zone consists of a series of openings surrounded by denser forest, allowing some insolation with adequate wind shelter. These cluster sites tend to have visible sky overhead with relatively few canopy openings toward the horizon and moderate exposure to the SW (which may be related to afternoon insolation.”
Stuart Weiss was also interviewed by Bay Nature about the monarch butterflies on Albany Hill: “Weiss wants to preserve the eucalyptuses—invasive non-natives that they are—for the butterflies’ sake. ‘The monarchs made their choice,’ says Weiss. ‘They go for the eucalyptus, so we have to honor that.’ The key to a cozy roost, according to Weiss, is a configuration of mature trees that provide just the right mix of sunshine and protection from wind and storms. Monarchs prefer to cluster along Albany Hill’s city-owned ridgetop early in the season. Later in winter, they cluster on the hill’s privately owned southwestern slope, and near the condos at the foot of the hill’s western flank. The fate of the trees and the butterflies roosting on that land is unclear.”
Eucalypts are the preferred trees for over-wintering monarchs in California according to an analytical study of 205 over-wintering sites: “Three types of trees were used most frequently by roosting monarchs: eucalyptus (75% of the habitats primarily Eucalyptus globulus), pine (20% of the habitats primarily Pinus radiata), and cypress (16% of the habitats Cupressus macrocarpa). Twelve other tree species were identified…with a combined prevalence of only 10%…habitats had smaller populations when the roosting tree type was a species other than eucalyptus, pine, or cypress.”(1) (Three different studies by different authors are the source of these data, therefore they don’t add up to 100%.) In other words, virtually all of the trees used by monarchs for their winter roost are not native to the San Francisco Bay Area.
The third and final segment of my letter to the Albany City Council will be published tomorrow. It will explain why the eucalyptus forest cannot be replaced by native trees. Thank you for your visit today.
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.
I am publishing my letter to the Albany City Council about the City’s plans to destroy most of the eucalyptus forest on Albany Hill. I will publish it in three segments because it is long. The first segment explains why it is not necessary to destroy the forest. The second segment will explain the consequences of destroying the forest. The final segment will explain why it is unlikely that the forest can be replaced by native trees.
Conservation Sense and Nonsense
Albany Hill. Source: Google Earth
December 5, 2022
Albany City Council 1000 San Pablo Ave Albany, CA 94707
RE: Albany Hill Eucalyptus Project
Dear Albany City Council:
I have a sentimental attachment to the City of Albany because I lived there for 5 years at the beginning of my marriage. We still enjoy regular visits to the city’s beauty spots of Albany Hill and the Albany Bulb, as well as Albany’s great restaurants.
The recently published Bay Nature article about Albany Hill alerted me to Albany’s new plans to destroy most of the eucalyptus forest on Albany Hill. I’ve studied the documents about these new plans and I’m writing to express my reservations about the feasibility of the plans. I ask for your consideration of these concerns:
Is it necessary to destroy the eucalyptus forest on Albany Hill?
What are the consequences of destroying the eucalyptus forest?
Is it possible to replace the eucalyptus forest with native trees?
All plants and trees in California are showing signs of drought stress and many are dead because of drought stress, especially in unirrigated parks and open spaces. Eucalyptus trees are not immune to drought stress, although they are coping better than some species that require more water, such as redwood trees.
Native Madrone, north side of Cerritos Creek, 2013. Conservation Sense and Nonsense
SAME Native Madrone on north side of Cerritos Creek is now dead, November 2022. Conservation Sense and Nonsense.
According to the San Francisco Chronicle, over 160 million native conifers have been killed by bark beetles in California’s Sierra Nevada in the past 10 years. As the climate continues to warm, bark beetles are moving north and west into coastal counties. The worst outbreak has been in Lake County, followed by Napa County. 15-25% of conifers on the east side of Napa Valley are dead. Drought conditions are so extreme that oaks are succumbing to drought stress: “That’s how you know things are kind of really bad, when you see oaks succumb to drought stress.’”
Plans to destroy most eucalyptus on Albany Hill are based on observed die-back of the eucalyptus tree canopy. The trees were studied by Matteo Garbelotto’s pathology lab at UC Berkeley. Their report described the impact of the infection:“First, symptoms observed in Eucalyptus were more markedly limited to the foliage and twigs. Leaf blight and twig necrosis were the only symptoms common across all the six areas surveyed and sampled. Branch and stem cankers, wood discoloration and fungal mats were present, but generally were site-specific or shared by trees only in 2 or 3 cases. Extensive heartrot (i.e. decay of the stem core) was not observed in any tree, although, some wood decay was observed both at the base of stems and on branches.”
The City of Albany’s application for a grant from the California Coastal Conservancy assumes that the eucalyptus trees will never recover: “The scientific analysis…determined the trees were in irreversible decline due to drought stress and resulting vulnerability of pathogen attack…” Since all unirrigated trees and plants are showing the same signs of stress, such a verdict would obligate us to destroy most trees in our open space. Given the remarkable regenerative abilities of eucalyptus, they are more likely to survive than most tree species.
Top of Albany Hill, 2015. Conservation Sense and Nonsense
Top of Albany Hill, November 2022. The tops of the canopy are a little thinner than they were in 2015, but not significantly. Conservation Sense and Nonsense
These symptoms were caused by a fungus that infects most eucalyptus in California. The fungus does not usually cause visible damage. Damage is now visible because the trees are stressed by drought. The situation is similar to the death of native conifers in California; native bark beetles have always been present but are now capable of killing the conifers because the trees are weakened by drought. The difference is that it’s not clear the fungus is capable of killing eucalyptus.
Eucalyptus has remarkable regenerative ability to resprout after it has been cut down or burned. One of the goals of the proposed project is a “fire-resilient” ecosystem, which suggests a landscape that is capable of recovering from the inevitable wildfires in a Mediterranean climate. In fact, eucalyptus is a fire-resilient tree species because it resprouts after it is burned. When it is under stress, it drops mature leaves and recovers by producing epicormic sprouts. Eucalyptus trees on the top of Albany Hill are covered in epicormic sprouts, which indicate the trees are not dead and they are trying to recover. Albany’s plans to destroy most of the eucalyptus forest on Albany Hill is based on the mistaken assumption that the trees will eventually die. That is an assumption that is not consistent with the present status of the trees on Albany Hill or with comparable situations in the Bay Area.
Part II of my letter to the Albany City Council will be published tomorrow. Part II will describe the negative consequences of destroying the eucalyptus forest on the top of Albany Hill. Please visit again tomorrow for the next segment of my letter to the Albany City Council. Thank you for your visit today.
Ed Yong introduces us to the topic of his book, An Immense World (1), by inviting us into an imaginary gymnasium populated by a menagerie of animals who perceive their environment in different ways because they have different sensory mechanisms. The elephant is waving its trunk in the air like a periscope, using its strongest sense to smell and taste the room. The mosquito is also relying on its sense of smell to find the source of carbon dioxide that its prey emits as it breathes. The rattlesnake detects the smell of the mouse by flicking its smelling and tasting tongue into the air. The bat finds the spider ensconced in its web by using echolocation sonar to locate it. The human in the room can’t hear the sonar clicks emitted by the bat because the sound is beyond her limited range of hearing. When Yong turns the lights off in the gym, different senses are deployed by different animals. Those who rely on light to perceive the room suddenly lose much information about what’s happening in the room, while other animals suddenly have an advantage.
Yong wants his readers to know about the extraordinary diversity of sensory perception in the animal kingdom. He asks us to appreciate that diversity while resisting the temptation to compare them to the capabilities of humans: “…this is a book not about superiority, but about diversity.” The dominance of one sense over another is usually logical in the context of the environment in which the animal lives. For example, animals that live in a dark environment or are active only at night need a different suite of senses than animals that live above ground and are active only in daylight. In his concluding chapter, Yong urges us to understand how animals perceive the world so that we can mitigate the impacts of human activities on the animals with whom we share the world.
The chemical senses: smell and taste
Yong begins with our weakest senses: smell and taste. Anyone who has walked a dog knows the dog senses the world primarily through its nose. Although dogs can be distracted by a moving squirrel or another dog, they are not there to enjoy the view because they are walking with their nose to the ground. Their nose is informing them of who has been there and many of the characteristics of that animal, such as species and gender. They are also searching for food and their taste in food is radically different from our own. Goose poop is as attractive as the treats we carry to distract them from the squirrels, suggesting subjectivity in the perception of smells and tastes. I doubt that humans would find either the odor or the taste of goose poop appealing and opinions of odors and tastes vary widely among humans whose sensory perception of odor and taste are equally astute.
Our noses are structurally similar to the dog’s nose, but dogs have “more extensive olfactory epithelium, dozens of times more neurons in that epithelium, almost twice as many kinds of olfactory receptors, and a larger olfactory bulb.” Consequently, they can be trained to detect “bombs, drugs, landmines, missing people, bodies, smuggled cash, truffles, invasive weeds, agricultural diseases, low blood sugar, bedbugs, oil pipeline leaks, and tumors.”
“The lives of elephants are dominated by smell.” Their nose is their most conspicuous feature and it is in constant motion to inform the elephant of where it is, where its companions and family members are, and where it is going. Their nose, which both smells and tastes, helps them find water and food.
Our comprehension of what animals smell is limited partly by our own limited sense of smell. The myth that birds can’t smell originated by James Audubon in the 19th Century was not dispelled by research until the 1960s. Yong reports many other errors of scientists in reporting the sensory capabilities of animals. He suspects that many of those errors are yet to be corrected.
The ability to detect and identify odors in the environment are important to many animals because they enable animals to both avoid predators and find prey to eat. The odors that animals emit as pheromones help many animals find and attract their mates. Humans also emit pheromones in sweat and other secretions and they are said to play a role in choosing our mates, although we are rarely conscious of their role in our choices.
Vision and Color
The diversity of the tools of vision in the animal kingdom is remarkable. Our two symmetrical, frontal-facing eyes are not the norm: “eyes can come in eights or hundreds…they can be the size of soccer balls or the size of a amoeba’s nucleus…they can be made of protein or rock…they can appear on mouths, arms, and armor…they can accomplish all of the tasks our eyes can perform, or just a few.” Each variation produces a different visual perception from seeing crisp detail to blurry blotches of light and dark, from seeing in the dark to blindness in bright daylight, from slow-motion snap-shots to high-speed images of motion, from a narrow view of what’s in front of the animal to a 360⁰ view.
Our vision is one of our strongest senses, yet many animals are able to see “better” than we can. (I put “better” in quotes because like everything in the natural world there are pros and cons to every animal’s suite of senses and the judgment depends on the specific environment in which the animal lives.) We can see three colors (red, green, and blue) and all combinations of those colors, but many animals can see another spectrum of color called ultraviolet (commonly abbreviated UV light), adding many colors that we can’t see. Many animals see only gradations of black and white. Color is a function of the eye in coordination with the brain, rather than inherent in the object we perceive.
Birds and bees undoubtedly benefit from their ability to see a full spectrum of color to find and identify plants they need for food. Before the advent of molecular analysis, scientists speculated that birds evolved the ability to see color after plants produced colorful flowers. Now that we know more about the evolutionary sequence of events, we know that plants produced colorful flowers after birds evolved their perception of color. Plants benefit from the visits of birds and bees for pollination services and to spread their seeds to expand their range. Natural selection gave plants with colorful flowers the edge over colorless flowers.
Dogs and many other animals can see only two colors: blue and yellow. About 8% of men and .5% of women are red-green color blind. Their perception of color is the same as dogs. This picture from An Immense World shows the difference between perceiving two compared to three colors:
As late as the 1980s many scientists believed that dogs are color blind. Although the knowledge that dogs can perceive two colors has been known by scientists for some time, many people still don’t know that. This is an ad for colored buttons that are sold to train dogs how to communicate with their guardians. This product is based on the mistaken assumption that dogs can see the same colors that most humans can see.
The consequences of our ignorance of the perceptions of animals
When considering the importance of understanding the perception of animals, there is more at stake than selling products that are based on our knowledge of what animals perceive. The last chapter of Yong’s book is asking us to understand how animals navigate the world so that we can keep them in mind as we continue to alter the environment for our entertainment and convenience.
In particular, Yong is concerned about light and noise pollution that are disruptive to the animal kingdom. When we illuminate our world with 24-hours of light we deprive many animals of the darkness they need to migrate and hunt. When the twin-towers in New York City were destroyed in 2001, they were replaced by a memorial that casts a laser light into the sky to the height of the missing twin-towers on 9/11. The timing is unfortunate for the birds that migrate at that time of year. They become “trapped” in the laser light and are often killed when their navigation is confused by the light. This is just one of many examples of how human activities intrude on the animal kingdom.
Likewise, our activities make so much noise in the environment that we drown out the signals of animals that they need to communicate, hunt, and find their mates.
Unfortunately, Yong misses the opportunity to advocate for reducing the chemical pollution that is equally harmful to animals. The pesticides we spray are masking the chemical cues that enable animals to hunt, avoid their predators, and communicate with their mates and other insects. Professor Ann Rypstra (Miami University, Ohio) gave a presentation to the Beyond Pesticides Forum about this issue in 2021. She said, “the presence of herbicides at non-toxic levels often act as “info-disruptors” when they interfere with the natural flow of information in ways that alter the interactions between and among predators and their prey as well as impacting the landscape for sexual selection.” You can see her presentation HERE.
I have covered a small fraction of the diversity of sensory perception in the animal kingdom. I provide this brief list of some of the topics that I haven’t covered, hoping that you will be inspired to look further into this fascinating topic:
The perception of sound
The perception of vibrations
Echolocation: using sonar to find prey and explore the environment
The use of electric and magnetic fields to perceive the environment and navigate
Humans do not have some of these sensory capabilities, but in many cases we have developed tools that compensate for our limited inherent sensory abilities. Humans have used a compass for over 1,000 years to detect the Earth’s magnetic field to assist navigation. We have learned how to use sonar to emit sounds we cannot hear to locate and explore objects that aren’t visible to us. We have developed night-vision goggles to improve our limited ability to see in darkness. More recently, we have developed microphone equipment to turn the vibrations that insects make into sound we can hear. The sensory capabilities of other animals has alerted us to these opportunities to enhance our sensory capabilities.
An Immense World will give you the full picture. If you want a more detailed summary of the topic than this article provides, I recommend Ed Yong’s article in Atlantic Magazine, available HERE.
Ed Yong, An Immense World: How animal senses reveal the hidden realms around us, Random House, 2022. Most quotes in this article are from this book unless indicated otherwise.
I have attended the annual symposiums of the California Invasive Plant Council (Cal-IPC) for 5 years. I have always learned something new and the most recent symposium in November 2022 was no exception. This year there was a lot of important information about herbicides that are widely used to eradicate non-native plants.
Several presentations reviewed the California laws that regulate pesticide use in California. (Slides for one of those presentations are available HERE.) The laws are designed to reduce risks of exposure to both applicators and the public.
The presentations emphasized the importance of legally mandated personal protective equipment (PPE) for applicators. The minimum PPE required by California law is protective eyewear and chemically resistant gloves:
Source: 2022 Cal-IPC Symposium
The toxicity of pesticides is rated by federal law as “Caution,” “Warning,” or “Danger,” with “Danger” indicating the most toxic and “Caution” the least toxic. These ratings are defined as signal words. Signal words of “Warning” or “Danger” require the applicator to also wear protective coveralls, in addition to protective eyewear and gloves.
Other types of PPE may be required by the product label, shown in this picture:
Source: 2022 Cal-IPC Symposium
Comparing the toxicity of organic and synthetic herbicides
Signal words can be used to compare the acute toxicity of different products. For example, the signal word on glyphosate products is “Caution,” indicating that it is considered less acutely toxic than other herbicides with higher toxicity ratings of “Warning” or “Danger.” Signal words are not a measure of long-term health damage of pesticides, such as cancer or kidney damage. Epidemiological studies of long-term health effects of pesticides are hotly disputed and are usually dismissed by the manufacturers of pesticides.
When glyphosate products were rated as a “probable human carcinogen” by the World Health Organization and tens of thousands of product liability lawsuits were filed by users of glyphosate products with cancer, there was a public backlash against the use of glyphosate partly because it is the most widely used herbicide on the market. Glyphosate is found in most of our food and in the urine of most people. The health damage done by glyphosate is the result of 40 years of widespread use by agriculture. Glyphosate’s “Caution” signal word does not reflect the long-term effects of its use.
What is the difference between synthetic and organic pesticides? In general, organic products are derived strictly from sources in nature with little or no chemical alteration. Synthetic pesticides are products that are produced from chemical alteration.
Are organic pesticides less toxic than synthetic pesticides? The general public tends to assume that organic pesticides are less toxic than synthetic pesticides, such as glyphosate. Based on the signal words the EPA assigns to pesticides to evaluate toxicity, organic pesticides are not necessarily less toxic than some synthetic pesticides. Remember the signal words are “Danger” (the most toxic), “Warning,” and “Caution” (the least toxic.)
Several presentations at the Cal-IPC conference compared the toxicity of organic and synthetic pesticides, using signal words as a proxy for toxicity. This is a slide from one of the presentations:
I also compared the signal words of the organic products used by Marin County and East Bay Regional Park District. Although they are using some organic products not evaluated by the presentation at the Cal-IPC Symposium, many of the organic products they are using have a “Warning” signal word, which means the EPA considers them more toxic than glyphosate.
Clearly organic herbicides are not necessarily less toxic than synthetic herbicides and many organic herbicides are more toxic than glyphosate.
Comparing the efficacy of organic and synthetic herbicides
Here are the results of the field trial (one organic herbicide was removed from the field trial when glyphosate was reported as an undisclosed ingredient in the product):
WeedZap and Fireworxx are the organic herbicides used in the field trial. The organic herbicides used in the field trial were found to be less effective than synthetic herbicides considered equally toxic.
“Organic herbicides kill weeds that have emerged but have no residual activity on those emerging subsequently. Further, while these herbicides can burn back the tops of perennial weeds, perennial weeds recover quickly.”
“These organic products are effective in controlling weeds when the weeds are small but are less effective on older plants.” The organic herbicides were significantly less effective when weeds were more than 12 days old.
“…broadleaf weeds were easier to control [with organic herbicides] than grassy weeds.”
Comparing the cost of organic and synthetic herbicides
The field study comparing organic and synthetic herbicides also compared the costs of these different product types:
In other words, organic herbicides are considerably more expensive than synthetic herbicides.
The publication of the UC Nursery and Floriculture Alliance agrees: organic herbicides “are expensive and may not be affordable…Moreover, because these materials lack residual activity, repeat applications will be needed to control perennial weeds or new flushes of weed seedlings.”
Clearly, organic herbicides are not a substitute for synthetic herbicides because they are not less toxic, not as effective, and are very expensive. Cal-IPC considers that assessment of organic herbicides a justification for continued use of synthetic herbicides. I consider it an argument for declaring a truce in the war on “invasive” species. We have waged that war for over 30 years. We have not won that war. In fact, we lose ground every year. We have done more damage to the environment with our chemicals than the “invasive” species did. We have reached a dead end.
Herbicides and Climate Change
The most valuable lesson I learned at the Cal-IPC Symposium was that climate change is making herbicides less effective. Higher temperatures and higher levels of CO₂ are reducing the effectiveness of herbicides. This revelation was mentioned only briefly in a presentation by Regional Invasive Species and Climate Change (RISCC) Management Networks. A search of the scientific literature substantiated that revelation:
”Herbicide effectiveness in controlling invasive plants under elevated CO2: Sufficient evidence to rethink weeds management:” “We found that responses of the weed species to herbicide under elevated CO2 were species-specific… However, the C3 [cool season] grasses tended to be the most sensitive to herbicide application followed by the herbs and C4 [warm/hot season] grasses while shrubs and vines demonstrated the highest resistance. Our results highlight the need for broader testing to determine the species most likely to exhibit increased tolerance to herbicide in the future in order to improve management options beforehand and thus offset a future liability.”
These studies are just a small selection of the studies that respond to a search for “impact of heat and CO₂ levels on herbicide efficacy.” They all point to yet another reason why the chemical crusade on introduced plants is a dead end.
Climate change is a reality and it is here to stay. Climate change has changed the ranges of where native plants can survive and it has made it impossible to destroy the non-native plants that are capable of surviving in the changed climate. Switching from one poison to another will not overcome the forces of evolution, which dictate that vegetation changes when the climate changes.