Author: Conservation Sense and Nonsense

A rare sighting of a Summer Tanager in San Francisco

We are reprinting a post from the Save Sutro Forest blog about a rare sighting of a Summer Tanager in San Francisco.  With permission and with minimal edits necessary to change the source of the pictures of  tanagers, we share this story with our readers.  Please visit the story on the Save Sutro Forest website to see photos of the actual female bird that was seen in San Francisco.

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One of the more interesting groups to watch, if you like birds, is the Yahoo group SF Birds. (Anyone can read it, but you must join to post in it. [ETA: It’s apparently been changed to a members-only group; only members can read it.]) It has over 1,000 members at this writing, but a smaller dedicated group of local birders use it to communicate the whereabouts of rare-in-San Francisco species. Often, someone follows up with links to beautiful photographs. That’s where we found the story of the Summer Tanager.

Male Summer Tanager. Wikipedia Commons

THE SUMMER TANAGER VISITS SAN FRANCISCO

This is a small songbird that’s a rare winter visitor to San Francisco. The males are a bright red color, the females and immature males are yellow. They feed on insects (bees, wasps and so on) and berries. Recently, birder Alan Hopkins reported seeing a female Summer Tanager in Golden Gate Park: “… you will find English Ivy growing up some trees. The tanager was catching bees that are feeding on the ivy.”

Of course, other birders followed up. Steven Tucker wrote: “…the Summer Tanager was where Alan described it. There are 2 huge columns of ivy adjacent to one another; the tanager was often in the right-hand clump or in the Eucalyptus trees around it.”

Then birder Mark Rauzon posted some wonderful pictures of this little bird in his Zenfolio portfolio. “I found it by it’s ‘churrip’ call at 1:30pm, Monday in the ivy covered Eucalyptus … It was bee-eating and occasionally dropping down to eat blackberries, where I had this face to face encounter.” (The pictures here are reproduced with his permission. They’re copyright. Anyone who wants to use them should check with him at mjrauz@aol.com )

NON-NATIVE PLANTS AS HABITAT

It’ll come as no surprise to birders that non-native plants provide habitat. After all, many of the posts in the SF Bird group describe birds in flowering eucalyptus trees, either for the nectar or the insects attracted to the nectar. (We hope that any birders who still believe eucalyptus trees suffocate birds will check this article, Another Eucalyptus Myth: Bird Death) They mention birds in the blackberry bushes, which provide not only food by way of berries and insects, but excellent cover. Like the notes above, they mention birds hiding in ivy.

In our article Interwoven and Integrated: Non-native and Native Species in Life’s Web, we described how native species and non-native species are part of the same functional habitat. This is another example.

  • The eucalyptus (non-native) provides support for the ivy (non-native)
  • which attracts insects (both native and non-native),
  • which become food for the Summer Tanager and other birds (mostly native).

The blackberry bushes work in much the same way; they attract insects, they provide berries, and they provide hiding places. So does eucalyptus – it flowers through the year, and particularly in winter, provides sustenance to birds and insects. It also provides nesting spots and cover.

Pointing this up was the most recent post [ETA:  No longer available to non-members] on the Summer Tanager, from Richard Bradus: “…an immature Red-tailed Hawk alighted, drawing an even dozen Ravens in pursuit. As they rose and flew off the bushes came alive, and out popped the female Summer Tanager. It made a few sorties from the ivy then, after devouring a particularly fat insect (bee?), it retreated to cover.”

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Million Trees Webmaster:  People who like birds pay attention to where they are and know they make good use of non-native plants and trees in San Francisco.  We had two old English holly trees in our yard in San Francisco which were probably planted around the same time our house was built in 1908.  They were visited every year by a flock of Cedar Waxwings, one of the most beautiful birds I have seen in the United States.  Their arrival each year was announced by the high-pitched, thin whistle of their call.  Then we could watch them with binoculars from our second story as they feasted on the berries of the holly trees.  It was an annual treat both for us and for the Waxwings as they passed through San Francisco.  Would they find enough to eat if there were no non-native trees and plants?  I don’t know, but I DO wonder.

Cedar Waxwing. Wikimedia Commons

Quibbling with the terminology of invasion biology

We believe the key word in Invasion Biology—invasion—is overused and that the adjective—invasive—is used indiscriminately to describe non-native plants, whether they are invasive or not.  We have already told our readers about photographic evidence of open space in the Bay Area taken over decades which proves the eucalypts and Monterey pines are not expanding their range.  Yet, these are two of the nearly 200 species of non-native plants on the California Invasive Plant Council’s list of “invasive species.”

Now we will use another non-native species as an example of how invasiveness is exaggerated by invasion biology.  Apparently many earthworms in the United States are non-native.  That’s because much of the population of native earthworms was wiped out by the glaciers that receded about 10,000 years ago. 

When Europeans began to colonize the country 500 years ago, earthworms were one of many species of plants and animals that they brought with them.  Like many non-native species, earthworms were transported unwittingly, first in the ballast of ships and then in the soil that accompanied plants that were purposefully transported.  In modern times, most earthworms are said to be introduced into new areas primarily by fishermen who use them as bait and then dispose of their surplus bait by throwing them on the ground.

Some 500 years later, invasion biologists are concerned about the impact that non-native earthworms are having on the ecology that evolved without earthworms.  Since glaciers did not extend as far south and west as California and the Bay Area, we don’t know if there are native earthworms here.  So, as you read about the impact that earthworms are said to have on the northern hardwood forests of the Great Lakes Region (Minnesota, Wisconsin, Michigan) and the northeast, you can’t assume that these observations apply locally.

The last period of glaciation in the United States

Since the hardwood forests of the northern and eastern states of the country evolved without earthworms for about 10,000 years, the duff (organic matter) on the forest floor is essential to the sustainability and health of the understory as well as the regeneration of the forest.  Earthworms digest the duff, incorporating it into the soil, and thereby deprive the native plants and trees of the nutrients that they depend upon for germination and survival. 

Although we accept that non-native earthworms may be having a negative impact on the native forests in these areas, we don’t think it is appropriate to call the earthworms invasive because they aren’t moving.  They exist only where man has introduced them.  Genetic studies have determined that isolated populations of non-native earthworms are unrelated to one another.  Their location in urban areas and around lakes and streams where fishermen visit implies that the earthworms are dispersed by man.  And they move very slowly, one-half to 1 kilometer (5/8th of a mile) every 100 years!*

Yet, those who study the earthworms and the managers of public lands who are trying to prevent the further introductions of earthworms consistently describe the worms as “invasive.”  Granted, it is a quibble, but we think this is a misleading description because it implies that the earthworm is to blame for whatever damage is being done to the native ecology when the blame clearly belongs to man.  The earthworms aren’t going anywhere.  Wherever they are found, they were put there by man.  The earthworm is another scapegoat for the harmful activities of man. 

On the bright side, invasion biologists and land managers aren’t trying to eradicate the non-native earthworm.  They are merely trying to educate fishermen to dispose of their surplus worms in the trash, rather than leaving them on the ground.  They concede that it’s impossible to get rid of earthworms where they now exist.  So, at least the soil isn’t being poisoned with pesticides in a futile attempt to return the land to its wormless history.

Once again, we urge invasion biologists to be more discriminating with their designation of “invasive species.”  We believe this term should only be applied to species that are expanding their ranges rapidly and that are actually causing damage in the environment.  Given the impact of climate change, native species are as likely to become invasive as non-native species.  If the term is used more accurately and less often, fewer efforts to eradicate hundreds of plant and animal species would be required.  Therefore those eradication efforts that are truly necessary would be less destructive and more successful.  The field of invasion biology would be more credible and enjoy more public support.

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* Hale, Cindy, “Evidence for human-mediated dispersal of exotic earthworms:  support for exploring strategies to limit further spread,” Molecular Ecology, (2008) 17, 1165-1169

Nativism is shooting us in the foot

A few months ago, we told you about one of the many projects to eradicate a plant species that is considered non-native.  In this case, smooth cordgrass (Spartina alterniflora) is native to the East and Gulf coasts of the US, but is considered non-native on the West Coast, despite the fact that it has been here for over one hundred years.  About $12 million was spent in the past 10 years on this effort, and the projection is that another $16 million will be spent in the next 10 years.

California Clapper Rail. British Wikipedia

When we told you about this project, we speculated that it was having a negative effect on an endangered species, the Clapper Rail.  The non-native Spartina provides cover that is superior to the native variety of Spartina.  It grows more densely and it doesn’t die back during the winter months, as the native variety does.  We also pointed out that the Clapper Rail is abundant on the East and Gulf coasts and is only considered endangered on the West Coast. 

Since we told you about this eradication project, we’ve learned a few things about the Clapper Rail that we hope will interest you, as it does us. 

  • This seems to be another case in which native plant advocates are looking for a scapegoat, when they should be looking at themselves.  Native plant advocates would like you to believe that the Clapper Rail is endangered on the West Coast because of the introduction of non-native red fox.  The red fox is yet another creature that nativists wish to eradicate in the Bay Area.  Apparently it has not occurred to them that the red fox is native to the East Coast, where the Clapper Rail is thriving.  Hmmm, that seems like a bit of contradiction, No?
  • We have learned of the displacement of Clapper Rails from marshes in which the non-native Spartina in being eradicated.
  • The Point Reyes Bird Observatory, a nationally recognized institution that conducts research on birds, has concluded that the Spartina eradication project is having a negative effect on the Clapper Rail.

Evidence that eradication of Spartina alterniflora is harmful to Clapper Rails

In July, a Clapper Rail was seen and photographed at Heron’s Head in southeastern San Francisco.  There was quite a bit of excitement about this sighting because a Clapper Rail had not been seen in San Francisco for decades.  That excitement dissipated when we learned more about where this bird came from, which provided a probable reason for the move. 

The Clapper Rail was wearing a radio collar that had been put on him and 109 other rails by the USGS to track their movements.  He had moved from Colma Creek, 11 km south of Heron’s Head, which is one of nearly 200 Spartina “control sites” in the San Francisco Estuary.  The bird sighted at Heron’s Head is one of three Clapper Rails that have left Colma Creek since 2007, when the radio collars were placed.  The Spartina control project has been going on for nearly 10 years, so we have no way of knowing how many Clapper Rails were displaced prior to 2007.

In October 2011, the Point Reyes Bird Observatory issued the first-ever “State of the Birds Report for San Francisco Bay:”  “Based on decades of monitoring, 29 partners detail the actions needed to keep birds and their habitats thriving as sea levels rise and extreme storm events increase due to global climate change.”  This report acknowledges the role that the Spartina eradication project plays in the continuing decline of the population of Clapper Rails in the Bay Area:

“The Clapper Rail’s rebound during the 1990’s was possibly due to fox control but also coincided with the rapid invasion of a tall non-native plant (invasive Spartina).  This invader benefited rails because it provided nesting habitat and protection from predators and high tides.  Beginning in the mid-2000s, the rail population declined sharply, due in part to the removal of invasive Spartina, which threatens tidal flat and marsh ecosystems as a whole.  This recent decline may be leveling off, but the future of Clapper Rails in San Francisco Bay remains tenuous.”

This is another example of the harmful obsession with non-native plants, which seems to trump other considerations, such as the welfare of the animals that benefit from the plants.  As is often the case with such eradication projects, Spartina is being eradicated with an herbicide, imazapyr.  This is a new herbicide about which little is known.  The analysis which was done to justify its use in the Spartina eradication project admits that no studies have been done on its effect on shorebirds, including the endangered Clapper Rail.  The Material Safety Data Sheet mandated by the Environmental Protection Agency tells us that imazapyr is “not readily biodegradable.”  So, in the event that we eventually learn that this herbicide is harmful to shorebirds and/or to us, we can be assured that it will still be in the environment, in the nearly 200 sites in the San Francisco Estuary on which it is currently being sprayed.  Imazapyr is also being sprayed–sometimes from helicopters–in hundreds of places along the West Coast, including in other states.  (A new post on Save Sutro reports more alarming information about imazapyr.)

The cost of nativism

This is an example of the harmful effects of attempting to eradicate non-native species.  It reminds us of a recent editorial in the New York Times about the new law in Alabama which is considered the most extreme anti-immigration law in the country.  The opponents of immigration are delighted with the new law.  The farmers of Alabama are warning us that they cannot replace the immigrants who are fleeing the state. Most of the work in the country’s agriculatural fields and orchards is being done by immigrants.  These are jobs that Americans are no longer willing to do.  This is just one of many unintended consequences of such xenophobic extremism.   We consider the Spartina eradication project another example of nativism run amok.

Our cosmopolitan viewpoint embraces ALL nature

Song Sparrow in non-native wild radish

Many passionate, well-informed comments were sent to San Francisco’s Planning Department about the Draft Environmental Impact Report (DEIR) for the Natural Resources Areas Management Plan (SNRAMP).  Today we’re celebrating the end of the comment period by telling you about one of our favorite comments.

This comment was written by a talented photographer of wildlife in San Francisco’s parks who prefers to remain nameless.  She has exhibited her photos in several venues around town, including San Francisco’s Main Library.  She wrote her comment primarily on behalf of the wildlife that lives in our parks and she illustrated it with beautiful photographs of the birds, insects, amphibians, reptiles, and mammals that she has photographed nesting, hiding, hunting, roosting, slithering in non-native plants and trees.

Garter snake in eucalyptus leaf litter

We will share the heart of her comment with you.  The soul of her comment is her photographs which were all taken in the parks of San Francisco.

“NAP is actually harming the environment by destroying trees, established habitat, and established ecosystems which include our existing wildlife. NAP wants to recreate our environment as one of native grasses which might have existed in the area in 1776 — in very delimited spaces this seems fine, but they should not be taking over our parks which have evolved on all levels since that time. The grasses were native to a sand-dune ecology, but that is no longer the case within the city, and the grasses provide no protective habitat to the animals which now occupy these spaces — animals which are not on NAP’s “specified” or “endangered” lists. There has been an alarmingly high rate of failure when “endangered” species have been introduced — this is because they are no longer suited to this environment which has evolved and changed since 1776. NAP is a political program, not a program based on science, and one which is hampering people’s enjoyment and use of their parks.”

Anise Swallowtail butterfly in non-native fennel

Although we have been engaged in this debate about destructive native plant “restorations” in the Bay Area for many years, we are still shocked by some of the arguments used to defend them.  Nature in the City is one of many organizations in San Francisco which considers itself an “environmental” organization.  In its latest newsletter, recruiting comments in support of the Environmental Impact Report, Nature in the City characterized critics of the Natural Areas Program and the DEIR as the “anti-nature forces.”  As we have said before, “environmentalism” has been stolen from us by the native plant movement, which we firmly believe is doing more harm than good to our environment. 

Frog hiding in pond plants

When was “nature” redefined exclusively as “native?”  We didn’t get that memo.  We are committed to preserving the habitat of all animals that live in San Francisco, whether the animals are native or non-native or the habitat that shelters and feeds them is native or non-native.  How does that make us “anti-nature?”

Honeybee in non-native wild mustard

Natural Areas Program violates San Francisco’s pesticide policy

As the deadline for written comments on the Draft Environmental Impact Report on the Natural Resource Areas Management Plan approaches (October 31, 2011), we are reprinting with permission a post from the Save Sutro website about the many violations of San Francisco’s pesticide policy by the Natural Areas Program. 

Anyone with the time and patience to read the 600+ page EIR knows that it does not provide us with any information about the volume of pesticides used by the Natural Areas Program.  Instead, it claims that the pesticides used by the Natural Areas Program will have no impact on the environment because they are following the rules; therefore, by definition there can be no negative impact on the environment.  This seems a non-sequitur to us.  But, even if we accepted this illogical premise, the fact is, they AREN’T following the rules.  Save Sutro tells us about the many violations of the city’s pesticide policy by the so-called Natural Areas Program.

Details about how to submit your public comment by October 31 are provided at the end of this post.

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As we noted in our previous post, the San Francisco Natural Areas Program seems to be using increasing amounts of toxic pesticides. From time to time, we’ve posted information here about pesticide use in the Natural Areas Program (NAP) lands. Roundup, Garlon, Imazapyr in Glen Canyon, at Pine Lake, on Twin Peaks, Mt Davidson, in the Interior Greenbelt — usually with a photograph. (Search this site on any pesticide name to see other relevant posts.)

What our readers have pointed out to us is that many of these violate the rules of the San Francisco Department of the Environment (SF DoE). We really appreciate SF DoE regulating toxic pesticides. They’re our second line of defense, when the Environmental Protection Agency seems all too ready to approve first and question later (or not question later). But they can only be effective if their rules stick.

What do we mean, violations? Well, here are a few, all from 2009 and 2010. Were there others? We don’t know.

A BUNCH OF VIOLATIONS

Missing dates on notices. The signs for pesticide spraying are meant to warn people — both the NAP staff and the general public with their kids and pets — that toxic chemicals are in use in an area. It’s pretty well-designed; it requires the dates the application is planned, how it will be applied, and then when it’s been used and when it will be safe to go back in there. But as with every precaution from seat-belts to poison symbols, it only works if it’s used. From the time we started collecting notices (pictures, not the actual notices), we often found key data missing: the date and time of the actual application. That means it’s never clear when (or whether) the pesticides were used and whether it’s safe to re-enter.

Using pesticides before they’re approved. In 2009, when we published a photograph someone sent us of Imazapyr usage at Pine Lake in Stern Grove, other readers were surprised. How come? SF DoE hadn’t approved it for use, had it?

They hadn’t.

It’s been approved only in 2011, as a Tier II pesticide.

Using pesticides where they’re not approved. In November 2010, we saw a notice that said they were spraying Aquamaster (glyphosate, same active ingredient as Roundup) “near shoreline” of Lake Merced. The target plant was “ludwigia – aquatic weed.” Also known as water-primrose, this grows in the water and presumably that’s what they were after. Except… Lake Merced is red-legged frog habitat. Use there is restricted: “Note prohibition on use within buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” (Glyphosate is death on frogs.) This was a lot less than 60 feet.

Spraying when they shouldn’t be spraying. According to the SF DoE, here’s how Roundup should be used: “Spot application of areas inaccessible or too dangerous for hand methods, right of ways, utility access, or fire prevention…OK for renovations but
must put in place weed prevention measures. Note prohibition on use within
buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” But according to all the notices (and the records) they’ve been using a backpack sprayer.

Spraying Garlon without a respirator. The signs said Garlon. The SF DoE regs said that this Tier I pesticide was for “Use only for targeted treatments of high profile or highly invasive exotics via dabbing or injection. May use for targeted spraying only when dabbing or injection are not feasible, and only with use of a respirator. HIGH PRIORITY TO FIND ALTERNATIVE.” The person spraying wore a blue “space-suit” — but no respirator. (Don’t know who it was, whether a Parks employee or someone from contractor Shelterbelt. Whoever, please be careful. The regs are there for a reason.)

Poorly maintained data. Pesticide use is recorded, and again the records are pretty specific. The serial number of the use, and the date. The chemical used, its trade name and chemical name and its EPA number. Where it’s been applied, and what it’s targeting. Who applied it. Analyzing these records would give a pretty good idea of who’s using what, where and why. But… the records aren’t complete, or at least they don’t appear to be. We’ve found notices in the field with no corresponding database entry.

IMPLICATIONS FOR THE DEIR

We understand how these violations occur. We don’t attribute adverse motives to NAP; they’re not going through the books thinking, which rule shall we break today? Remembering all the restrictions, maintaining records and filling in signs is tedious, and it’s easy to forget in the press of work. Even NASA makes mistakes.

Still, the objective of the rules is to keep us all safer and reduce the use of toxins as far as possible. With good reason, we don’t think the NAP is able to comply.

As readers will be aware, the Draft Environmental Impact Report (DEIR) for the San Francisco Natural Areas Management Plan is now open for public comment. What the DEIR says is: “Pesticide and herbicide use in the Natural Areas would be in accordance with the SFRPD’s Integrated Pest Management (IPM) Program and San Francisco’s Integrated Pest Management Ordinance...”

Seriously? Can they even do it?

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[Edited to add:

For readers who are interested in commenting on the DEIR:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

“Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17 31, 2011. [Please note, the deadline has been extended.] Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”]

The toxic pesticides used by San Francisco’s Natural Areas Program

We are reprinting with permission an article from the Save Sutro website about the pesticides being used by San Francisco’s Natural Areas Program.  The Save Sutro website is a valuable source of reliable information on any topic it covers, but it is especially knowledgeable about the pesticides being used in San Francisco. 

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It’s no surprise that people are beginning to associate San Francisco’s Natural Areas Program with pesticides. It’s been using them (if the city’s records are accurate) at an increasing rate.

    • In 2009, it applied Garlon 16 times; in 2010, it was 36 times.
    • It applied Roundup (or Aquamaster, also glyphosate) only 7 times in 2009, but 42 times in 2010.

The Draft Environmental Impact Report (DEIR) on the SF Natural Areas Program is rather coy about pesticides. It doesn’t say how much it’ll use, just that it will follow all the rules when using them. (They actually have a poor track record there, but we’ll go into that in another post. [Edited to Add: We did.]) Today, we want to talk about the pesticides on their list: Roundup or Aquamaster (glyphosate); Garlon (triclopyr); Polaris (imazapyr); Milestone (aminopyralid).

SF’s Dept of the Environment classifies all of these as Tier I (Most Hazardous) or Tier II (Hazardous). There’s no mention of using any Tier III (Least Hazardous) chemicals.

ROUNDUP or AQUAMASTER (Glyphosate)

We’ve talked before of Roundup, a Tier II pesticide. We hope that in view of the new research that has been surfacing, SF’s DoE will revisit that classification and consider if it deserves a Tier I rating.

  • heart breaking

    It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).

  • Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
  • It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

Classified as Tier I, Garlon is even more hazardous than Roundup. In 2010, NAP used this pesticide 36 times (sometimes in combination with Roundup, which it has said it will no longer do). We’ve written about Garlon before, Garlon in our Watershed — which has more details — and many times since then. In brief, these are the main issues:

  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, it’s absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist in dead vegetation for up to two years.

The DEIR has said that the SF NAP’s phasing out Garlon. We have some doubts; its tree-felling program will be futile without Garlon to prevent re-sprouts.

POLARIS, HABITAT (Imazapyr)

This is a very new pesticide, and not much is known about it — except that it’s very persistent. SF’s DoE has recently approved it for use as a Tier II hazard. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment. We’ve written about this one, too, when NAP recently started using it on Twin Peaks and Glen Canyon. (Actually, NAP had started using it prior to SF DoE’s approval , in Stern Grove and also at Lake Merced in 2009 and some unspecified NAP area in 2008.)

About its impact on people, we wrote: “it can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”

It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001.

MILESTONE (Aminopyralid)

Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. While the DEIR lists this as a chemical used by the NAP, they actually used Milestone very little (twice in 2010). Fortunately. SF DoE classifies it as Tier I, Most Hazardous. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.

Nevertheless, after an outcry and problems, Dow AgroSciences has stopped selling Milestone in the UK until it’s figured out.

Note to NAP and SFRPD: Don’t put clippings treated with Milestone in the green bin!

PESTICIDE CONSPIRACY THEORIES

When we first started researching pesticide use in “Natural Areas” (and shocking a lot of people who’d assumed “Natural” meant natural), conspiracy theories arose: The chemicals companies were subverting the decision-makers; Pesticides were being portrayed as ecological, and the marketing machine was convincing them; Maybe there were even payoffs!

We think the explanation is much simpler: Those in charge of the Natural Areas are being asked to do the impossible. They’re given a large area, (ETA: it’s as big as Golden Gate Park but in 32 separate locations) in the middle of a city where conditions don’t even approximate those of the pre-industrial era, and asked to return it to a specific moment in time.

It doesn’t want to go.

WHY NATURAL AREAS FIGHT BACK

Someone described the effort to “restore” the “Natural Areas” to “Native plants” as a constant battle. It is, and here’s why:

  • Stopping natural succession. Some areas are harder than others. Grasslands want to grow shrubs, native or not. Then, in pre-industrial San Francisco, along would come grazing browsing animals, or lightning strikes, or a landslide or two, and the shrubs would lose and the grass would win. Preserving grasslands requires killing the shrubs, and in the absence of animals and fires and landslides, it’s pesticides. Repeatedly.
  • Battling successful plants. And then there are the plants that do want to grow there, that grow there naturally (even if, like many San Franciscans, they’re not from here). These we call invasive, and want to get rid of them. That’s more pesticides. And since the plants are good at what they do, they have to be strong pesticides. Repeatedly.
  • “Invaders” compete with each other. Even if the pesticides clear an area of one kind of “invasive” plant, unless the space is intensively gardened, it’ll be taken over by other “invaders.” More pesticides.

The bison in the room (it’s native, unlike the elephant) is this: Contrary to the belief that Native Plants are so adapted to a particular place that “restorations” can be achieved merely by eradicating unwanted plants — Native Plant gardens need the same kind of maintenance and care as any garden.

Without the Sutro Stewards’ volunteers working there every month or so, the Native Garden on top of Mount Sutro would revert to its natural state: a mix of native and introduced plants. (No pesticides are used in that area, or indeed anywhere on UCSF’s Mount Sutro space. It may be the last pesticide-free wild area in San Francisco.)

Is the Natural Areas Program, as it’s currently managed, worth it? We think not, because of:

  • the ongoing and growing need for toxic herbicides;
  • the destruction of habitat for insects, birds and animals that rely on it (and this includes native species, most of which have adapted to introduced plants);
  • we think it’s an expensive misdirected effort in terms of time and treasure.

It makes sense to define small areas as Native Gardens, focus on those, and make them succeed. That can be done — as the Native Garden on Mount Sutro proves — without toxic chemicals.

Professor Arthur Shapiro’s comment on the Environmental Impact Report for the Natural Areas Program

Mission blue butterfly Wikimedia Commons

With permission and in its entirety we are publishing the comment of Arthur M. Shapiro.  He is Distinguished Professor of Evolution and Ecology at UC Davis and a renowned expert on the butterflies of California.  We hope that you will take his credentials into consideration as you read his opinion of native plant restorations in general and the Natural Areas Program in San Francisco in particular.  We hope that Professor Shapiro’s comment will inspire you to write your own comment by the deadline,  which has been extended to October 31, 2011.  Details about how to submit your comment are available here.

*************************

October 6, 2011

Mr. Bill Wycko

San Francisco Planning Department

                              Re: DRAFT EIR, NATURAL AREAS PROGRAM

Dear Mr. Wycko:

Consistent with the policy of the University of California, I wish to state at the outset that the opinions stated in this letter are my own and should not be construed as being those of the Regents, the University of California, or any administrative entity thereof. My affiliation is presented for purposes of identification only. However, my academic qualifications are relevant to what I am about to say. I am a professional ecologist (B.A. University of Pennsylvania, Ph.D. Cornell University) and have been on the faculty of U.C. Davis since 1971, where I have taught General Ecology, Evolutionary Ecology, Community Ecology, Philosophy of Biology, Biogeography, Tropical Ecology, Paleoecology, Global Change, Chemical Ecology, and Principles of Systematics. I have trained some 15 Ph.D.s, many of whom are now tenured faculty at institutions including the University of Massachusetts, University of Tennessee, University of Nevada-Reno, Texas State University, and Long Beach State University, and some of whom are now in government agencies or in private consulting or industry. I am an or the author of some 350 scientific publications and reviews. The point is that I do have the bona fides to say what I am about to say.

 At a time when public funds are exceedingly scarce and strict prioritization is mandatory, I am frankly appalled that San Francisco is considering major expenditures directed toward so-called “restoration ecology.” “Restoration ecology” is a euphemism for a kind of gardening informed by an almost cultish veneration of the “native” and abhorrence of the naturalized, which is commonly characterized as “invasive.” Let me make this clear: neither “restoration” nor conservation can be mandated by science—only informed by it. The decision of what actions to take may be motivated by many things, including politics, esthetics, economics and even religion, but it cannot be science-driven.

In the case of “restoration ecology,” the goal is the creation of a simulacrum of what is believed to have been present at some (essentially arbitrary) point in the past. I say a simulacrum, because almost always there are no studies of what was actually there from a functional standpoint; usually there are no studies at all beyond the merely (and superficially) descriptive. Whatever the reason for desiring to create such a simulacrum, it must be recognized that it is just as much a garden as any home rock garden and will almost never be capable of being self-sustaining without constant maintenance; it is not going to be a “natural,” self-regulating ecosystem. The reason for that is that the ground rules today are not those that obtained when the prototype is thought to have existed. The context has changed; the climate has changed; the pool of potential colonizing species has changed, often drastically. Attempts to “restore” prairie in the upper Midwest in the face of European Blackthorn invasion have proven Sisyphean. And they are the norm, not the exception.

The creation of small, easily managed, and educational simulacra of presumed pre-European vegetation on San Francisco public lands is a thoroughly worthwhile and, to me, desirable project. Wholesale habitat conversion is not.

A significant reaction against the excesses of the “native plant movement” is setting up within the profession of ecology, and there has been a recent spate of articles arguing that hostility to “invasives” has gone too far—that many exotic species are providing valuable ecological services and that, as in cases I have studied and published on, in the altered context of our so-called “Anthropocene Epoch” such services are not merely valuable but essential. This is a letter, not a monograph, but I would be glad to expand on this point if asked to do so.

I am an evolutionary ecologist, housed in a Department of Evolution and Ecology. The two should be joined at the proverbial hip. Existing ecological communities are freeze-frames from a very long movie. They have not existed for eternity, and many have existed only a few thousand years. There is nothing intrinsically sacred about interspecific associations. Ecological change is the norm, not the exception. Species and communities come and go. The ideology (or is it faith?) that informs “restoration ecology” basically seeks to deny evolution and prohibit change. But change will happen in any case, and it is foolish to squander scarce resources in pursuit of what are ideological, not scientific, goals with no practical benefit to anyone and only psychological “benefits” to their adherents.

If that were the only argument, perhaps it could be rebutted effectively. But the proposed wholesale habitat conversion advocated here does serious harm, both locally (in terms of community enjoyment of public resources) and globally (in terms of carbon balance-urban forests sequester lots of carbon; artificial grasslands do not). At both levels, wholesale tree removal, except for reasons of public safety, is sheer folly. Aging, decrepit, unstable Monterey Pines and Monterey Cypresses are unquestionably a potential hazard. Removing them for that reason is a very different matter from removing them to actualize someone’s dream of a pristine San Francisco (that probably never existed).

Sociologists and social psychologists talk about the “idealization of the underclass,” the “noble savage” concept, and other terms referring to the guilt-driven self-hatred that infects many members of society. Feeling the moral onus of consumption and luxury, people idolize that which they conceive as pure and untainted. That may be a helpful personal catharsis. It is not a basis for public policy.

Many years ago I co-hosted John Harper, a distinguished British plant ecologist, on his visit to Davis. We took him on a field trip up I-80. On the way up several students began apologizing for the extent to which the Valley and foothill landscapes were dominated by naturalized exotic weeds, mainly Mediterranean annual grasses. Finally Harper couldn’t take it any more. “Why do you insist on treating this as a calamity, rather than a vast evolutionary opportunity?” he asked. Those of us who know the detailed history of vegetation for the past few million years—particularly since the end of Pleistocene glaciation—understand this. “Restoration ecology” is plowing the sea.

Get real.

                                    Sincerely,

                                     Arthur M. Shapiro

                                     Distinguished Professor of Evolution and Ecology

Professor Arthur M. Shapiro, at work, UC Davis

Fabricating “facts” to support native plant restorations.

We have been debating with native plant advocates for a long time, so we’re never surprised when they repeat vague generalities to support their ideology.  But when these fabricated “facts” are repeated in legal documents such as the Draft Environmental Impact Report (EIR) for the Natural Areas Program (NAP) we must admit that we’re shocked!  Apparently, the highly paid professionals who write such documents don’t expect the public to actually read the references they cite to support the statements they fabricate.  We will take our readers on a tour of some of the phony “science” used to defend the destruction of San Francisco’s urban forest in order to restore native grassland and scrub to San Francisco’s urban parks.

Why is carbon storage such an issue in this debate about the Natural Areas Program?

The urban forest of San Francisco stores 196,000 tons of carbon and adds to that accumulated store of carbon at an annual rate of 5,200 tons per year according to the US Forest Service survey.  About 25% of the annual rate of sequestration and the accumulated storage of carbon are accomplished by the blue gum eucalyptus, the chief target for destruction by NAP’s plans.  When a tree is destroyed, it releases the carbon that has accumulated throughout its lifetime into the atmosphere as Carbon Dioxide as it decays.  Carbon Dioxide is the predominant greenhouse gas that is causing climate change. 

Carbon storage by tree species, San Francisco. US Forest Service

Since greenhouse gases are regulated in California by a law that commits the state to reduce greenhouse gas emissions, the Environmental Impact Report (EIR) for the Natural Areas Program (NAP) goes to great lengths to make the case that destroying thousands of trees will not violate California law.  Here are just a few of the “facts” fabricated by the EIR to convince the public that NAP’s plans to convert San Francisco’s urban forest into grassland and scrub will not harm the environment.   

Grassland in the San Francisco Bay Area does NOT lower ground temperature

The EIR claims:

“According to a study presented at the American Geophysical Union’s meeting, grasslands above 50 degrees latitude reflect more sun than forest canopies, thereby keeping temperatures lower by an average of 0.8 degree Celsuis.” ( EIR, page 457, cited source(1))

This statement in the EIR does not apply to the San Francisco Bay Area and the reference used to support it misrepresents the cited study:

  • The entire continental United States, including the San Francisco Bay Area, is below 50 degrees latitude.  In other words, this statement—even if it were true—does not apply to the San Francisco Bay Area.
  • The statement is taken out of the context of the article.  The entire sentence in which this statement appears actually says, “Grassland or snowfields, however, reflected more sun, keeping temperatures lower.  Planting trees above 50 degrees latitude, such as in Siberia, could cover tundras normally blanketed in heat-reflecting snow.”  It does not snow in the San Francisco Bay Area.  Therefore, this statement does not apply to the San Francisco Bay Area.
  • The article being quoted by the EIR is NOT the scientific study, but rather a journalistic article in The Guardian, a newspaper in England, in which the author of the study has been misquoted and his study misrepresented.
  • The day after this article appeared in The Guardian (and also in the New York Times), The Guardian published an op-ed (which also appeared in the New York Times) by the author of the scientific study, Ken Caldeira  in which he objected to the misrepresentation of his study:

“I was aghast to see our study reported under the headline “Planting trees to save planet is pointless, say ecologists.” (December 15).  Indeed, our study found that preserving and restoring tropical forests is doubly important, as they cool the earth both by removing the greenhouse gas carbon dioxide from the atmosphere and by helping produce cooling clouds.  We did find that preserving and restoring forests outside the tropics does little or nothing to help slow climate change, but nevertheless these forests are a critical component of Earth’s biosphere and great urgency should be placed on preserving them.”(2) (emphasis added)

As if this misrepresentation of the facts weren’t bad enough, we find in Appendix A of the EIR that this isn’t the first time that someone has informed the authors of the EIR that this statement is not accurate.  One of the public comments submitted in 2009 in response to the Initial Study quotes Ken Caldeira’s op-ed in the New York Times.  Yet, two years later, the author of the EIR persists in repeating this misrepresentation of Professor Caldeira’s (Stanford University) research.  One wonders if the public comments were even read, judging by the repetition of the pseudoscience in the Initial Study that the public commented on in the first round.  It seems that the “public process” is merely going through the motions.

Grassland does NOT store more carbon than forests

The EIR also claims:

“Research studies have concluded that grassland and scrub habitat could act as a significant carbon sink.” (page 457, cited studies(3))

Once again, the cited study does not support the statement in the EIR:

  • Again, the statement has been taken out of context.  The entire sentence reads, “We conclude that grasslands can act as a significant carbon sink with the implementation of improved management.”  This sentence appears in the abstract for the publication.(4)
  • One wonders if the authors of the EIR read the entire article or just the abstract.  The point of the study is that land management techniques such as fertilization, irrigation, introduction of earthworms, plowing and fallow techniques, etc., can improve the sequestration of carbon in the soil of croplands and pastures.  This study is obviously irrelevant to the Natural Areas Program, which is not engaged in agriculture or pasturage and will not use any of these techniques. 
  • However, the study is relevant in one regard.  It reports that when forest is converted to grassland, no amount of “management techniques”  compensates for the loss of the carbon in the trees that are destroyed:

“Though more than half of the rain forest conversion studies (60%) resulted in increased soil Carbon content, net ecosystem Carbon balance…decreased substantially due to the loss of large amounts of biomass carbon.” 

The second study cited in support of the claim about carbon storage in grassland reports that increased levels of Carbon Dioxide in the air increases carbon accumulation in the soil.  This study tells us nothing about the relative merits of grassland and forests with respect to carbon storage.  Another study reports a similar relationship between global warming and carbon storage in trees:  “…warmer temperatures stimulate the gain of carbon stored in trees as woody tissue, partially offsetting the soil carbon loss to the atmosphere.” (5)

A pointless debate that misses the point

The misuse of these studies illustrates one of the fundamental issues with this pointless debate about the relative merits of grassland and forests.  Even if grassland were superior to forests with respect to carbon storage—and it’s NOT—it would never compensate for the loss of carbon associated with destroying a forest that is storing hundreds of thousands of tons of carbon.  The merits of planting trees where none presently exist is a fundamentally different argument than the merits of destroying trees.  The trees are here now.  No amount of grassland will compensate for the loss of the carbon presently stored by the forest that native plant advocates demand be destroyed.

If there is a sound argument for destroying trees, this isn’t it.  Grassland does not store more carbon than trees and will never compensate for the loss of the tons of carbon released into the atmosphere when trees are destroyed. (Please visit our post “Facts about carbon storage do not support assumptions of native plant advocates”)  Native plant advocates would be wise to abandon this particular line of unreasoning. 

Although we are not scientists, we read the work of scientists.  The studies conducted by scientists are not theoretical speculations about the benefits of one plant compared to another.  Rather they report the results of controlled experiments, such as actually measuring the amount of carbon in the plant and/or soil and reporting the results of those experiments.  Native plant advocates would be wise to spend less time trading baseless generalizations amongst themselves and spend more time reading the scientific reports of actual evidence. 

Please comment on the Draft Environmental Impact Report for the Natural Areas Program

Please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks.  There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*.  Here are the details about the public’s opportunities to comment on the EIR for the Natural Areas Program:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

“Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17, 2011*. Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

*[ETA:  The deadline for written comments has been extended to October 31, 2011 at the request of the Planning Commission.]

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”

(1) Jha, Alok.  The Guardian.  “Planting Trees to Save Planet is Pointless, Say Ecologists.”  Friday, December 15, 2006.

(2) Caldeira, Ken, “Planting trees is far from pointless.” The Guardian, December 16, 2006.

(3) Conant, L., Paustian K, and Elliot E. 2001. “Grassland Management and Conversion into Grassland Effects on Soil Carbon.”  Natural Resource Ecology Laboratory.  Colorado State University. Fort Collins, USA.  Sponsor:  US Environmental Protection Agency, Ruminant Livestock Efficiency Program.  2001, and

Hu, S., Chapin, Firestone, Field, Chiariello.  2001.  “Nitrogen limitation of microbial decomposition in a grassland under elevated C02,” Nature 409:  188-191. 

(4) Conant, Paustian, Elliott, “Grassland Management and Conversion into Grassland Effects on Soil Carbon,”  Ecological Applications, 11 (2) 2001, 341-355.

(5) Melillo, J., Butler, S., Johnson, J., Mohan, J., Steudler, P., Lux, H., Burrows, E., Bowles, F., Smith, R., Scott, L., Vario, C., Hill, T., Burton, A., Zhouj, Y, and Tang, J. Soil warming carbon-nitrogen interactions and carbon-nitrogen budgets. PNAS, May 23, 2011

 

Environmental Impact Report for the Natural Areas Program is based on a HUGE mistake!

There is a HUGE mistake in the Environmental Impact Report (EIR) for the Natural Areas Program (NAP), which will fundamentally alter the public’s perception of the EIR.

The EIR says on page 2 in the Summary that the “Maximum Restoration Alternative” is the “Environmentally Superior Alternative.”  The statement on page 2 is WRONG!  The “Maintenance Alternative” is the “Environmentally Superior Alternative,” as explained on page 525-526 of the EIR.

When we first informed our readers of the publication of the Environmental Impact Report (EIR) for the Natural Areas Program (NAP) on September 9, 2011, we also announced that the EIR considers the “Maximum Restoration Alternative” the “Environmentally Superior Alternative.”  The “Maximum Restoration Alternative” proposes an aggressive expansion of the NAP that will destroy more trees, require more herbicide use, close more trails and other recreational access, and permit NAP to plant more legally protected species that could require more restrictions in the future.   When we announced this proposed expansion of the program, we were reporting what the EIR says on page 2 in the Summary of the EIR. 

So, we repeat, the statement on page 2 is wrong.  The “Maximum Restoration Alternative” is NOT the “Environmentally Superior Alternative.”  The “Environmentally Superior Alternative” is the “Maintenance Alternative.”  The correct statement does not appear in the EIR until the very end of the document:

“The Maximum Recreation and Maintenance Alternatives are the environmentally superior alternatives because they have fewer unmitigated significant impacts than either the proposed project or the Maximum Restoration Alternative. Between the Maximum Recreation Alternative and the Maintenance Alternative, the Maintenance Alternative would be the environmentally superior alternative for two reasons. While the two alternatives have the same number of significant and unavoidable impacts under CEQA, the Maintenance Alternative has fewer potential environmental effects than the Maximum Recreation Alternative. First, the Maintenance Alternative would not create new trails, the construction of which could result in impacts to sensitive habitats and other biological resources. Second, over time the Maximum Recreation Alternative would result in Natural Areas with less native plant and animal habitat and a greater amount of nonnative urban forest coverage. The Maintenance Alternative, on the other hand, would preserve the existing distribution and extent of biological resources, including sensitive habitats. For these reasons, the Maintenance Alternative is the environmentally superior alternative.” (EIR, page 525-526) (emphasis added)

The contradiction between what appears on page 2 of the EIR and page 526 was pointed out to the staff of the Planning Department responsible for managing the public comment period and certification of the EIR.  That staff member confirmed that the statement on page 2 is wrong and the statement on page 526 is correct.  However, she refused to correct the error until the public comment period is over and the Final Environmental Impact Report is published.

Unfortunately, this mistake and the refusal to correct it before the public comment period is complete will jeopardize the fairness of the process.  Native plant advocates are already recruiting their speakers for the public hearing by the Planning Commission on October 6, 2011, and the written comments which are due on October 17, 2011*.  They are urging their supporters to advocate for the “Maximum Restoration Alternative” and they are incorrectly informing them that this is the “Environmentally Superior Alternative.”  We have no reason to believe that they are aware of the mistake on page 2 of the EIR.  They are probably sincere in their belief that the “Maximum Restoration Alternative” is the “Environmentally Superior Alternative.”  Few readers are likely to read the entire EIR and will therefore be unaware of the mistake on page 2.

This mistake will mislead the public into supporting the “Maximum Restoration Alternative” that expands the destructive and restrictive aspects of the Natural Areas Program.  Furthermore, and perhaps more importantly, this expansion is NOT legal because it violates the requirements of the California Environmental Quality Act (CEQA), which requires that the “Environmentally Superior Alternative” have the least negative impact on the environment of all proposed alternatives:

“§21002.  APPROVAL OF PROJECTS; FEASIBLE ALTERNATIVE OR MITIGATION MEASURES

The Legislature finds and declares that it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would  substantially lessen the significant environmental effects of such projects,  and that the procedures required by this division are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.”  CEQA Guidelines, page 2 (emphasis added)

Pardon our paranoia….

 This is a huge mistake which could profoundly prejudice the public to support the “Maximum Restoration Alternative” which proposes an expansion of the Natural Areas Program.  We ask these rhetorical questions:

  •  Who wrote page 2 of the EIR, which incorrectly identifies the “Maximum Restoration Alternative” as the “Environmentally Superior Alternative” and why?
  • Why does the Planning Department refuse to correct this error before the public comment is complete?

If you attend the public hearing on October 6, 2011, please inform the Planning Commission of this error and write by the deadline of October 17, 2011*, in support of the “Maintenance Alternative” which will do less damage to the environment than the proposed project and the other proposed alternatives.  Here are the details about the opportunities for public comment:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

 “Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17, 2011^. Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

*[ETA:  The deadline for written comments has been extended to October 31, 2011, at the request of the Planning Commission.]

The Healthy Trees of San Francisco

The San Francisco Natural Areas Program (NAP) plans to destroy thousands of healthy trees in San Francisco’s parks.  The Draft Environmental Impact Review (EIR) for NAP’s destructive plan reaches the bizarre conclusion that removing thousands of trees will have no significant impact on the environment.   This conclusion is based on several fictional premises.  In a previous post we examined the fictional claim that all the trees that will be removed will be replaced within the natural areas by an equal number of trees that are native to San Francisco.  In this post we will examine another of the fictional premises:  that only dead, dying, hazardous, or unhealthy trees will be removed.

We have many reasons to challenge the truth of the claim that only dead, dying, hazardous or unhealthy trees will be removed:

  • The management plan for the Natural Areas Program tells us that young non-native trees under 15 feet tall will be removed from the natural areas.  By definition these young trees are not dead or unhealthy because they are young and actively growing.
  • The management plan has not selected only dead, dying, hazardous trees for removal.  Trees have been selected for removal only in so far as they support the goal of expanding and enhancing areas of native plants, especially grasslands and scrub.
  • The predominant non-native tree in San Francisco, Blue Gum eucalyptus lives in Australia from 200-400 years, depending upon the climate.(1)  In milder climates, such as San Francisco, the Blue Gum lives toward the longer end of this range. 
  • However, there are many natural predators in Australia that were not imported to California. It is possible that the eucalypts will live longer here:  “Once established elsewhere, some species of eucalypts are capable of adjusting to a broader range of soil, water, and slope conditions than in Australia…once released from inter-specific competitions and from native insect fauna…”(2)
  • The San Francisco Presidio’s Vegetation Management Plan reports that eucalypts in the Presidio are about 100 years old and they are expected to live much longer: “blue gum eucalyptus can continue to live much longer…”(3)
  • The Natural Areas Program has already destroyed hundreds of non-native trees in the past 15 years.  We can see with our own eyes, that these trees were not unhealthy when they were destroyed.

How have mature trees been selected for removal?

The EIR wants us to believe that only dead, dying, hazardous trees will be removed from the natural areas.  This claim is contradicted by the management plan that the EIR is claiming to evaluate.  Not a single explanation in the management plan for why specific trees over 15 feet tall have been selected for removal is based on the health of the trees.  Trees less than 15 feet tall will also be removed, but are not counted by the management plan.

  • Lake Merced:  The explanation for removing 134 trees is “To maintain and enhance native habitats, it is necessary to selectively remove some trees.”
  • Mt. Davidson:  The explanation for removing 1,600 trees is: “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-grassland ecotone, invasive blue gum eucalyptus trees will be removed in select areas. Coastal scrub and reed grass communities require additional light to reach the forest floor in order to persist “
  • Glen Canyon:  The explanations for removing 120 trees are:  “to help protect and preserve the native grassland” and “to increase light penetration to the forest floor”
  • Bayview Hill:  The explanation for removing 505 trees is:  “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-grassland ecotone, invasive blue gum eucalyptus trees will be removed in select areas.”
  • McLaren:  The explanation for removing 805 trees is:  “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-scrub-grassland ecotone, invasive trees will be removed in select areas. Coastal scrub and grassland communities require additional light to reach the forest floor in order to persist.”
  • Interior Greenbelt:  The explanation for removing 140 trees is:  “In order to enhance the seasonal creek and sensitive species habitat that persists in the urban forest understory, invasive blue gum eucalyptus trees will be removed in select areas.”
  • Dorothy Erskine:  The explanation for removing 14 trees is:  “In order to enhance the grassland and wildflower community, removal of some eucalyptus trees is necessary.”

In not a single case does the management plan for the Natural Areas Program corroborate the claim made in the EIR that only dead, dying, diseased, or hazardous trees will be removed.  In every case, the explanation for the removal of eucalypts is that their removal will benefit native plants, specifically grassland and scrub.  The author of the EIR has apparently not read the management plan or has willfully misrepresented it. 

The track record of tree removals in the natural areas

Although it’s interesting and instructive to turn to the written word in the management plan for the Natural Areas Program to prove that the EIR is based on fictional premises, the strongest evidence is the track record of tree removals in the past 15 years.  As always and in every situation, actions speak louder than words.

Hundreds of trees have been removed in the natural areas since the Natural Areas Program began 15 years ago.  We’ll visit a few of those areas with photographs of those tree removals to prove that healthy, young non-native trees have been destroyed.  This track record predicts the future:  more healthy young trees will be destroyed in the future for the same reason that healthy young trees were destroyed in the past, i.e., because their mere existence is perceived as being a barrier to the restoration of native grassland and scrub.

Girdled trees, Bayview Hill, 2010
  • The first tree destruction by the Natural Areas Program and its supporters took the form of girdling about 1,000 healthy trees in the natural areas about 10 to 15 years ago.  Girdling a tree prevents water and nutrients from traveling from the roots of the tree to its canopy.  The tree dies slowly over time.  The larger the tree, the longer it takes to die.  None of these trees were dead when they were girdled.  There is no point in girdling a dead tree.

    One of about 50 girdled trees on Mt. Davidson, 2003
  • Many smaller trees that were more easily cut down without heavy equipment were simply destroyed, sometimes leaving ugly stumps several feet off the ground.

    Bayview Hill, 2002
  • About 25 young trees were destroyed on Tank Hill about 10 years ago.  The neighbors report that they were healthy trees with trunks between 6″ to 24″ in diameter and therefore fairly young trees.  The trees that remain don’t look particularly healthy in the picture because they were severely limbed up to bring more light to the native plant garden for which the neighboring trees were destroyed.  The neighbors objected to the removal of the trees that remain.  The Recreation and Park Department agreed to leave them until they were replaced by native trees.  Only 4 of the more than two dozen live oaks that were planted as replacements have survived.  They are now about 36″ tall and their trunks are about 1″ in diameter. 

    Tank Hill, 2002
  • About 25 young trees were destroyed in 2004 at the west end of Pine Lake to create a native plant garden that is now a barren, weedy mess surrounded by the stumps of the young trees that were destroyed.

    Pine Lake "Natural Area" 2011
  • About 25 trees of medium size were destroyed at the southern end of Islais Creek in Glen Canyon Park about 6 years ago in order to create a native plant garden. 
  • Many young trees were recently destroyed in the natural area called the Interior Greenbelt.  These trees were destroyed in connection with the development of a trail, which has recently become the means by which the Natural Areas Program has funded tree removals with capital funding.

    Interior Greenbelt Natural Area, 2010. Courtesy SaveSutro

There was nothing wrong with any of these trees before they were destroyed.  Their only crime was that they were not native to San Francisco.  There are probably many other trees that were destroyed in the natural areas in the past 15 years.  We are reporting only those removals of which we have personal knowledge.

If you care about the trees of San Francisco….

If you care about the trees of San Francisco, please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks.  There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*.  Details about how to comment are available here.

*[ETA:  The deadline for written comments has been extended to October 31, 2011, at the request of the Planning Commission.]

(1) Jacobs, Growth Habits of the Eucalyptus, 1955, page 67

(2) Doughty,  The Eucalyptus, 2000, page 6

(3) San Francisco Presidio’s Vegetation Management Plan, page 28