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 alternatives@cdpr.ca.gov 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.
Spraying Garlon on Twin Peaks in San Francisco, February 2011
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.
One of many pesticide application notices on oxalis in Glen Canyon Park in February 2023.
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.
Chemical Warfare?
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!
Jake asks for more research on how oxalis interacts with other plants in his article published by Westside Observer. He is apparently unaware of the research that has been done by scientists at University of Montana to address the question of how competitive oxalis is in plant communities that include native plants: “Oxalis is a poor competitor. This is consistent with the preferential distribution of Oxalis in disturbed areas such as ruderal habitats, and might explain its low influence on the cover of native species in invaded sites.”
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.”
coyote hunting in oxalis field. Copyright Janet Kessler
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.
Jake’s Lament
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.
While San Francisco’s Recreation and Park Department has significantly reduced its use of herbicides since 2010, the Natural Resources Division that is responsible for the “natural areas” has not. Natural Resources Division is now using more herbicides than the rest of the parks. Source: San Francisco IPM Program, Department of Environment
“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.
Sharp Park, Pacifica, CA. Photo by Erica Reder, SF Public Press
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.
Restoration Goals
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.
Conclusion
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.
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.
In conclusion:
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
Resolution No. 2021-105. A resolution of the Albany City Council, authorizing the appropriation of funds to the Albany Hill Eucalyptus Project in the amount of $100,000
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.
As you know, many public land managers have destroyed eucalyptus trees, but the City of Albany was not planning to destroy the eucalyptus forest on Albany Hill until recently. According to the 2012 “Albany Hill Creekside Master Plan,” the eucalyptus forest would be “phased out” slowly over time by removing hazardous trees as necessary to ensure public safety, removing new seedlings where the forest interfaces with native oak woodland, and not replacing trees that die of old age. I expressed my support for this approach to management of the eucalyptus forest on Albany Hill on my website, Conservation Sense and Nonsense.
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.
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.
The California Native Plant Society (CNPS) held a conference in October for the first time since 2018. There were two main themes of the conference:
Money: The State of California is making a huge investment in the environment with many interrelated goals:
“30 X 30” is shorthand for the goal of protecting 30% of California’s land and coastal waters by 2030.
Developing “nature-based solutions” to address the threats of climate change.
Vegetation and forest management to reduce wildfire hazards.
Protecting and enhancing California’s biodiversity.
Fire: The frequency and intensity of wildfire is of concern to all Californians, but the California Native Society has a particular interest in fire because it is viewed as a tool to enhance native plant abundance and control the spread of non-native plants that outcompete native plants.
Money
If attendance were the sole measure of success, the conference was a resounding success. The conference was sold out with record-breaking attendance of 1,200 people. That’s a 50% increase in attendance since 2018, when 800 people attended. People came to learn about the many opportunities for public funding of their “restoration” projects and they were not disappointed.
Jennifer Norris, Deputy Secretary for Biodiversity and Habitat for the California Natural Resources Agency (CNRA) was one of the keynote speakers. She and many other staff of CNRA made presentations at the conference to inform the community of native plant advocates about the many new opportunities to obtain grants for their projects. This slide (below) shown at the conference, itemized by state agencies the $1.631 Billion budget for just the 30 X 30 portion of the CNRA’s environmental grant programs. It does not include Cal-Fire funding for forestry projects to reduce wildfire hazards and address climate change. Nor does it include $10 million of new funding for Weed Management Areas, which funds projects that attempt to eradicate non-native plants and $10 million of new funding for the state council for invasive species. State funding is also supplemented by new federal funding in support of a national goal of achieving 30 X 30.
But money isn’t the only element of this state program that native plant advocates are excited about. They have also been gifted a three-year moratorium on requirements for Environmental Impact Reports for their projects. There will therefore be no requirements for a public process to review plans and comment on them.
An anxious applicant for state grant funding asked a speaker representing the Wildlife Conservation Board about a rumor that projects using herbicides would not be funded. The speaker’s reassuring answer was, “We are not rejecting projects using herbicides.” Applicants are being asked to complete a questionnaire about herbicides they plan to use, but the speaker was quick to add, “We have not rejected any [such applications] so far.” She assured the audience that “You are all careful” in your use of herbicides.
Huge buckets of money are being distributed with no restrictions on the use of herbicides and no vetting process such as an environmental impact review with opportunities for the public to comment. It seems inevitable that some of the projects will unintentionally do more harm than good, and the public will have nothing to say about which projects are funded.
Fire
Alexii Sigona was the first keynote speaker for the conference. He is a member of the Amah Mutsun-Ohlone Tribal Band (not a federally recognized tribe) and a Ph.D. candidate at UC Berkeley in the Department of Environmental Science. He explained that there are 600 recognized members of the Amah Mutsun Band in a wide region around Pescadero, Hollister, and San Juan Bautista. They collaborate with organizations such as CNPS because they don’t have the resources to manage their ancestral tribal lands. He described some of the projects they engage in:
Landscape scale removal of “invasive” plants.
Plug planting of 120,000 native grass plants.
Creating “native hedgerows” for food sources.
Removal of native Douglas Firs “encroaching” on grassland. They have removed 5,000 native Douglas fir trees. He acknowledged that this project caused some concern about erosion and aesthetics. Removal of native Douglas fir was mentioned by several other speakers during the conference. It is an example of the preference of native plant advocates for grassland because it is the pre-settlement vegetation. Native coyote brush is another target of eradication projects that attempt to prevent natural succession of grassland to other vegetation types.
There is great interest among native plant advocates in the land management practices of Native Americans because controlled burns were Native Americans’ most important tool to maintain grassland species needed for food and for their prey. Controlled burns are important to native plant advocates because they believe they are beneficial to native plants and help to control non-native plants. Prescribed burns are also currently popular with many public land managers and they are the current fad among many fire scientists.
Two presentations at the conference suggest that prescribed burns are not compatible with the preservation of native chaparral, nor are they capable of converting non-native grassland to native grassland.
This (above) is the concluding slide of Jon E. Keeley’s presentation. Dr. Keeley is a respected fire scientist with US Geological Service with expertise in chaparral species. 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 the existence of 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.” (1) This concern extends to some conifer species that do not resprout. Some are serotinous conifers whose cones are sealed shut and do not release their seeds in the absence of fire.
This is a familiar theme for much of Dr. Keeley’s research. He asks that land managers balance the conflicting goals of resource management and fire hazard reduction.
This (above) is the concluding slide (sorry for the poor quality of my photo) of a presentation about a 20-year effort at the Santa Rosa Plateau Ecological Reserve to convert non-native annual grassland to native grassland, using annual (sometimes bi-annual) prescribed burns. Many different methods were used, varying timing, intensity, etc. The abstract for this presentation reports failure of the 20-year effort: “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.” (1)
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.”
Another questioner prefaced her question with the admission that “I’m new here and all this is new to me.” Then she suggested that Native Americans are having some success using prescribed fire and that they should be consulted. The speaker graciously replied that she planned to do so.
Keep in mind that Native Americans weren’t historically using prescribed fire to convert annual grasses to native grasses. Their burns were intended to maintain native grassland in the absence of competing non-native annual grassland. Their objectives were different and they were operating in a very different climate and environment.
Estimates of the pre-settlement population of Native Americans in Californiarange from 138,000 to 750,000. The population of Native Americans is estimated to have been reduced to as few as 25,000 after the arrival of Europeans due to disease and violence. There are now over 39 million Californians and only 630,000 of them were Native Americans in the 2020 census. Land management practices that are suitable for a population of less than 1 million seasonally migrating Californians are not necessarily suitable for a population of over 39 million sedentary Californians.
The futility of trying to eradicate non-native plants
The Invasive Spartina Project (ISP) is another 20-year eradication project that is doomed to failure. The presentation about the ISP was bravely made by Dr. Debra Ayres, one of the creators of the ISP in 1998. With intensive effort and hundreds of gallons of herbicide (imazapyr), non-native spartina marsh grass has been greatly reduced in the San Francisco Bay, but the hybrid of non-native S. alterniflora and native S. foliosa persists. Dr. Ayres explained why:
The spartina hybrid is reproductively stronger in every way than either of its parent species. Dr. Ayres predicts that the hybrid will eventually replace both of its parent species:
If the goal of this project was to eradicate non-native spartina, hybrid spartina will accomplish that goal. You might think that this prediction would end the futile attempt to eradicate the hybrid, but you would be wrong. There is no intention of abandoning this 20-year project. More funding is assured by the California Coastal Conservancy and the project continues to provide well-paid jobs.
Dr. Ayres ended her presentation with this enigmatic statement: “Evolution doesn’t stop just because we think it has to.”She seems to acknowledge that humans cannot stop evolution, yet she seems to recommend that we continue to try doing so. If those positions seem contradictory, that’s because they are. The bottom line is that as long as public funding continues to be available, this project will continue.
A central theme of the nativist agenda is the futile desire to prevent hybridization because it has the potential to replace a species considered “native.” They fail to understand that hybridization is an important evolutionary tool that helps plant and animal species adapt to changes in environmental conditions by favoring traits that are better adapted to new conditions. Humans cannot stop evolution, nor should we try.
San Francisco
I have a special interest in San Francisco because I lived there for nearly 30 years. The native plant movement is very strong in San Francisco and there were several presentations about the success of the movement at the conference.
Sunset Blvd being built on barren sand in 1931
One of the projects is trying to turn Sunset Blvd on the western side of San Francisco into a native plant garden. I lived in that district and am therefore familiar with Sunset Blvd as the major north-south traffic artery through the district. It is important as the only wind break in the windiest district of the city, which is only 13 short blocks from the ocean. The district is virtually treeless because of wind conditions and the pre-settlement landscape of barren sand. Sunset Blvd is therefore the oasis of the Sunset District. In the past, it was the only place to take a long walk in the shelter of the tall Monterey pines and cypress and tall-shrub understory. The lawn beneath the trees was the only place for children to play close to their homes.
San Francisco’s Department of Public Works (DPW) is responsible for maintaining the medians in San Francisco. It was therefore DPW’s responsibility to replace the wind break on Sunset Blvd that is dying of old age. That’s not what they chose to do. They are replacing the lawn with native shrubs and the tall trees with small native trees that won’t provide shelter from the wind.
The spokesperson for DPW acknowledged that the project is controversial. Neighbors of Sunset Blvd valued the sheltered recreational space provided by the 2.5 mile-long and wide median. Native plant advocates and their allies want to create a wildlife corridor through the western edge of the city. The spokesperson for DPW said that their plans are a compromise between these different viewpoints. I don’t know if the neighbors agree, but I can say that native plant advocates are thrilled with the new native plant gardens on Sunset Blvd based on their presentation at the CNPS conference.
Planting Sunset Blvd. with native plants, December 2020
Native plant advocates prevailed on Sunset Blvd because CNPS bought or raised all the native plants and provided volunteers to plant them and maintain them for 3 years. DPW couldn’t look their gift horse in the mouth. DPW hired 6 new gardeners to support maintenance of Sunset Blvd. This is an example of how the money that is flowing into such projects will transform many places into native plant gardens.
Sunset Blvd and Taraval, spring 2022
So, let’s look at the result of these projects. Presenters of these projects showed many beautiful pictures of newly planted native gardens on Sunset Blvd (above). The pictures were taken in spring, when native plants briefly flower. But that’s not what these places look like most of the year. They will look better if they are irrigated year-round, but that would defeat the purpose of replacing the lawn to reduce water usage. Unlike native plants, lawn turns brown during the dry season if it isn’t watered, but it is still functional as walkable ground.
Here’s what that garden at Sunset Blvd and Taraval looks like most of the year:
Sunset Blvd & Taraval, October 23, 2022
There was also a presentation by a spokesperson from San Francisco’s Public Utilities Commission (PUC) about the creation of rain gardens in San Francisco. San Francisco’s sewer system was built long ago when regulations did not require the separation of street run off from residential sewage. When it rains, the sewage treatment plant is overwhelmed by street run off. The sewage treatment plant releases untreated sewage and run off into the ocean, in violation of federal standards for water treatment.
Rain garden on Sunset Blvd as shown at the CNPS Conference
Rain Garden on Sunset Blvd in August 2022. They aren’t pretty year around.
The PUC is developing rain gardens to redirect street run off away from sewage treatment plants into the ground so that treatment plants are not overwhelmed during heavy rain. The San Francisco Chronicle recently reported that 151 rain gardens have been installed so far. It seems a very good idea, but native plant advocates are not happy with the rain gardens because the PUC has not made a commitment to plant exclusively native plants in the rain gardens. The audience pressured the speaker about this issue. He advised them to lobby the PUC to make a commitment to plant only native plants in the rain gardens. I have no doubt that they will take his advice. Given their influence and their access to public funding, I would be surprised if the PUC continues to resist their demands.
Conclusion
I have undoubtedly exhausted your patience, although there is much more I could tell you about, including several projects that look promising because they are exploring the importance of soil health to achieve successful results.
The conference themes in 2022 were consistent with the previous two conferences I have attended since 2015. This is my summary of the fundamental errors of the nativist agenda in the natural world. They are as apparent in 2022 as they were in 2015:
The futility of trying to eradicate non-native plants that are better adapted to current environmental conditions.
The futile and harmful attempts to prevent natural succession and hybridization.
The contradictory goals of fuels management and resource management.
The lack of understanding that vegetation changes when the climate changes. The ranges of native plants have changed and will continue to change. The pre-settlement landscape of the 18th century cannot be recreated.
The lack of understanding of the importance of soil health to ecological restoration and associated ignorance (or denial) of the damage that pesticides do to the soil.
(1) Abstracts for all presentations are available on the CNPS website.
“The way out of the depression and grief and guilt of the carbon cul-de-sac we have driven down is to contemplate the world without us. To know that the Earth, that life, will continue its evolutionary journey in all its mystery and wonder.” — Ben Rawlence in The Treeline
Ben Rawlence, the author of The Treeline: The Last Forest and the Future of Life on Earth, visited forests in Arctic regions to report the impact of climate change on forests and indigenous communities who inhabit those regions. The climate is changing more drastically and quickly in Arctic regions, compared to temperate regions because rapidly melting ice is no longer reflecting light back into the atmosphere. The dark ocean waters and forest canopy are absorbing heat, accelerating global warming. As ice retreats on land and melts into oceans, mosses and lichens grow on bared ground and the forest spreads northward aided by elevated levels of carbon dioxide, which increases photosynthesis, boosting plant growth.
Rawlence visited Arctic regions in Scotland, Norway, Siberia, Alaska, Canada, and Greenland. Source: CIA World Fact Book
As forests advance north, hybridization enables the selection of the species best adapted to the changed and rapidly changing conditions: “Sorbus are found all around the boreal region, from Scandinavia to Siberia, and everywhere have shown an ability to adapt by hybridizing vigorously. The capacity to hybridize is a survival strategy, a useful skill for the Anthropocene, and the rowan is a survivor par excellence.” (1)
While forests advance north, the southern edge of forests in northern latitudes is dying in the warming climate from drought, wildfires, insects and pathogens that are fostered by warmer temperatures. Where permafrost is melting in warming temperatures, trees are drowning in water. Boreal forests in Arctic regions are a pock-marked mosaic of dead and dying trees, burned skeletons in some places, standing dead, clothed in brown canopies in other places.
NASA satellite photo of dozens of wildfires in Eastern Siberian forests in July 2022
These changes in vegetation have an impact on every other living inhabitant of Arctic regions. Where vast herds of caribou and reindeer lived in the past and indigenous people migrated to follow them, changes in vegetation have drastically reduced their numbers. Where winter snow was dry and crisp in the past, reindeer could dig to find lichen that sustained them during the winter. Snow is wetter during warmer winters and episodically freezes to form a hard crust, making lichen inaccessible to reindeer.
Range of reindeer (Rangifer tarandus) known as caribou in North America.
Indigenous people such as Sámi in Norway and Nganasen in Siberia no longer migrate to follow reindeer herds. Rawlence visits these communities and reports that they are fatalistic about the changes in the environment. They understand why their lives have changed and they anticipate more changes in the future, but they also understand that they are powerless to change this trajectory. Inuits in Alaska must periodically move homes to escape rising sea levels, yet they support the development of fossil fuels in Alaska because their primary source of income is tax revenue from the fossil fuel industry: “Sure, there’s change. There are cherry trees in Fairbanks. But everyone has five hundred dollars a month in their pockets. We haven’t paid state income tax for thirty years and there’s zero unemployment. It still looks pretty nice.” (1) Rawlence calls this the hydrocarbon compromise.
On a trip to Norway in 2017, one of our stops on an organized excursion above the Arctic circle was to visit this staged performance by a Sámi with his sole reindeer.
Global significance of changes in Arctic regions
Those who live in temperate regions, such as the US, might wonder what these changes in Arctic regions have to do with us. Out of sight, out of mind. Those who are inclined to shrug at the news about the Arctic would be wise to read The Treeline to understand the impact of changes in the Arctic on the entire world.
Impact on marine life
Rising sea levels are the most immediate and obvious consequence of melting ice sheets and glaciers as well as warming ocean temperatures. Water trapped in ice and snow is fresh water. Adding fresh water to the oceans lowers salinity with consequences for the circulation of nutrients in the ocean: “Siberia’s rivers are discharging 15 percent more water into the ocean than a decade ago…This seems to be changing the salinity of the Arctic Ocean, and may in turn affect the Arctic pump. This is the process by which salty water sinks to the bottom, causing a cycle in which the deeper water mixes with nutrients from the sea floor and rises again to the surface feed phytoplankton.”Phytoplankton are the foundation of the marine food web: “This stimulation of plankton growth is also the reason the entry points to the Arctic Ocean…are among the richest feeding grounds on earth for marine animals and birds.” (1)
As forests die in riparian corridors that feed into the ocean, phytoplankton are also robbed of the iron needed to reproduce and divide: “Iron made available by trees is the foundation of the food web in the ocean.” (1)
Impact on global weather
Weather on the planet is a finely tuned balance of air and ocean currents that are easily disrupted by small changes in temperature and chemical composition of the atmosphere. The loss of sea ice changes the course of ocean currents that alter food webs and atmospheric currents associated with ocean currents. The loss of trees disrupts air currents that carry moist air from oceans to continental interiors, causing drought. The chaotic weather events that we now experience are the result of these disruptions in the delicate balance of air and water currents that determine our weather.
The seasonal pulse of oxygen in the spring when deciduous trees leaf out is muddled by unseasonal heat that suppresses photosynthesis. Trees close the pores of their leaves (stomata) to reduce the loss of moisture as protection against the heat, which stops photosynthesis, in turn stopping the conversion of carbon dioxide to oxygen. Tree growth stops without photosynthesis. Seasonal patterns of life are disrupted such as the nesting season of birds and the availability of insects that must coincide with nesting season for reproductive success. The daily pulse of temperatures from day to night is shallow and indistinct. Warmer nights no longer provide a respite from the stress caused by high heat during the day.
Consequences of thawing permafrost
Long before the last ice age that ended about 10,000 years ago, northern latitudes now dominated by ice were covered in dense forest. The remains of those forests now buried by ice are frozen peatlands called permafrost. Carbon stored by plants during their lifetimes is returned to the atmosphere when the plant dies and decomposes in dry climates. Peatlands are unique in accumulating carbon in layers of dead vegetation that does not decompose in the watery bogs that limit surface oxygen. “Canada’s Hudson Bay Lowlands, the largest intact peatland in the world, stores as much as five times more carbon than the equivalent area in the Amazon rainforest.” (2)
Warming temperatures and wildfires in the boreal forests of Canada, Alaska, and Siberia are thawing permafrost, destabilizing infrastructure such as roads and gas pipelines. According to Rawlence, Conoco Phillips, which is drilling for oil in Alaska, is refrigerating permafrost to prevent fracturing their pipelines.
The nightmare scenario that could be triggered by the sudden release of carbon dioxide and methane by thawing permafrost in Siberia, is described by a Dutch climate scientist in The Treeline: “There is twice as much greenhouse gas—carbon dioxide, methane, and nitrous oxide—stored in the permafrost as currently is in the atmosphere, enough to accelerate warming exponentially and effectively end life on earth as we know it if it were released at once…’The larger public still thinks that climate change will be gradual. They are not alive to the fact that it will be abrupt and what that means in terms of climate disasters and the suffering of our children.’” (1)
A Caveat
The author of The Treeline, Ben Rawlence, is a British writer. His previous books were Radio Congo: Signals of Hope From Africa’s Deadliest War about civil war in Congo and City of Thorns: Nine Lives in the World’s Largest Refugee Camp about a refugee camp in Somalia. He was a researcher for the Africa division of Human Rights Watch. He is not a trained ecologist or botanist.
The Treeline reflects Rawlence’s background and lack of background. He is passionate about the dire consequences of climate change, but his inadequate botanical knowledge requires readers to beware. Professor Art Shapiro wrote a review available on Amazon that details some of the inaccuracies in The Treeline and puts these issues in perspective: “Reading this book is like listening to a great symphony while one instrument, say an oboe, is infuriatingly out of tune.” (3) I took Professor Shapiro’s advice and read The Treeline for the big picture, not for the details, of which many are speculative in any case. Our understanding of the consequences of climate change is imperfect. Still, I believe The Treeline is well worth reading and Rawlence’s elegant writing is also a reward.
Ben Rawlence, The Treeline: The Last Forest and the Future of Life on Earth, St. Martin’s Press, 2022
In American Eden, Victoria Johnson tells the remarkable story of an American physician, David Hosack, who brought knowledge of the medicinal properties of plants to America at the end of the 18th century. The medicinal properties of plants have been known to humans for thousands of years, but incorporating that knowledge into modern medical science began only in the 18th century.
Traditional knowledge of the medicinal properties of plants was closely tied to many religious superstitions. The Doctrine of Signatures seemed a logical botanical belief at a time when plants were one of man’s few medicinal tools and religion was a powerful influence in human society. The Doctrine of Signatures, which was actively promoted by the church in 17th century Europe, was based on a belief that God had “signed” plants with certain suggestive shapes and colors to inform humans of their medicinal properties. For example, a heart-shaped leaf was considered God’s message to us that a particular plant would be beneficial to the human heart and this message was strengthened by a flesh-colored flower. Every plant was believed to be useful in some way if man could only discern its use. Else why would they have been created, since the Garden of Eden was created for the benefit of man? The church encouraged man’s study of plants as a way to worship God’s creation. (2)
David Hosack
Medical science was equally burdened with harmful, often deadly, medical practices such as bleeding and prescribing mercury. When David Hosack began practicing medicine in New York at the end of the 18th century he was acutely aware of the limitations of the tools of his profession. He could see the promise of prescribing plant extracts to his patients, but he was frustrated by his limited knowledge of plants, their uses and his access to them.
He decided that learning more about botany and horticulture were the prerequisites for developing the medicines his patients needed. He went to England and Scotland where he studied for two years under the tutelage of the pioneers of the botanical science that was beginning to transform medicine.
The development of the Linnaean system of classifying species earlier in the 18th century enabled a more systematic study of plants based on their close relationships and similarities. Physicians and apothecaries had for centuries relied on inaccurate rules to try to divine the medicinal properties of specific plants. Medicinal properties cannot be determined by a particular color, shape, or smell. Linnaeus’s new framework classified plants into orders, classes, families, genera, and species, groups with similar medicinal properties because they were chemically similar. Plants in the same order were expected to share some of the same medical properties. Plants in the same class share more properties, families still more and the most similarity is found within a genus. “By way of example, Linnaeus noted that the various known species of Convolvulus, a genus in the bindweed family that included morning glories, all appeared to have purgative effects on the body.” (1)
In Scotland and England the knowledge of the medical uses of plants and the classification of plants according to the Linnaean system led to the development of botanical gardens where new plants with these properties could be studied and medical students were taught to identify the plants and learn their medical uses. These botanical gardens enabled the incorporation of botanical knowledge into medical knowledge. The gardens collected plants from all over the world that were recognized as the close relatives to plants from closer to home and were considered equally valuable as potential therapeutic drugs.
These botanical gardens fostered a cosmopolitan view of plants that actively sought and welcomed new plants from the regions of the world that were being newly explored. The Linnaean classification system made it possible for new plants to be incorporated into the global family of plants. We have lost this sense of a global family of plants. Instead of classifying plants according to their membership in families, orders, and classes, the plant world has been artificially divided into two meaningless categories: native and non-native. These categories prevent us from understanding the close relationships between plants. The native plant movement has turned most of the plant world into aliens. Just as dividing the human race into white and non-white is prejudicial and harmful, dividing the plant world into native and non-native is equally pernicious.
The Consequences of Putting Plants into “Native” Strait-Jackets
Milkweed is an example of the consequences of classifying plants based on their native status. There are about 200 species of milkweed in the Asclepias genus and they are distributed broadly across Africa, North America, and South America. There are a few species of milkweed native to the Bay Area, but the most popular species of milkweed, tropical milkweed (Asclepias curassavica), is not. It is popular with home gardeners because it is a strikingly beautiful plant and it is evergreen, unlike our native milkweed, which is deciduous, therefore not available in winter months.
Monarch butterflies are dependent upon milkweed as its host plant. They lay their eggs on milkweed and their caterpillars eat milkweed. In the past, monarchs in California spent the winter roosting in trees along the coast of California. They did not breed during the winter. They moved inland during summer months where they bred.
Because of global warming, monarchs have begun to breed during the winter months in California and the existence of tropical milkweed in gardens in coastal California has made that possible: “the [monarch] population boom in the Bay Area had not been seen before. It was unusually warm that fall, which may have accounted for the numbers. And tropical milkweed, which unlike native milkweed flowers through the winter and creates a suitable habitat for breeding, was abundant in gardens.” (3)
Scientists with a commitment to the survival of monarchs have welcomed this development: “But the growth of local, breeding monarchs is seen, at least by some, as a sign of the resilience of the monarchs, their ability to find new ways to persist in the face of an increasingly threatened migration. Might we be seeing the growth of a resident population of monarchs in the Bay Area?” (3)
“Hugh Dingle, a retired University of California at Davis entomology professor who has studied monarch butterfly migration for more than two decades, said the bans are “basically a wasted effort” and that the focus should be on larger threats such as pesticide and herbicide use. All species of milkweed carry parasites that can affect monarch populations, Dingle said.”
“Arthur Shapiro, a UC Davis professor who has studied monarch butterflies for the past six decades, described the rationale behind the bans as “hogwash.” Shapiro, Dingle and other researchers said winter breeding among monarch butterflies is a relatively new behavior and one influenced by warmer winter temperatures caused by climate change.”
“David James, an associate entomology professor at Washington State University who has studied monarch butterfly breeding and migration in the Bay Area, said there is a case to be made about the tropical milkweed as being a vital resource for the monarchs in a changing climate.”
“Leslie McGinnis, a UC Berkeley doctoral candidate studying monarch populations and working with gardeners in the East Bay, said the bans take a “simplistic view” of the threats that monarchs face, including the fact that many native milkweed plants supplied to nurseries can also be sprayed with pesticides. The bans, she said, can work to disenfranchise or demonize people that have tropical milkweed who instead could be partners in working to help restore monarch populations.”
Native plant advocates are wedded to a past that is long gone. The climate has changed and it will continue to change. Monarchs and other animals are trying to adapt to the changed conditions. Their survival depends on their ability to adapt. The native plant movement has become a form of climate change denial. Their irrational hatred of introduced plants is damaging the environment with herbicides and harming wildlife.There is no evidence that tropical milkweed is harmful to monarchs.
Update: Professor Art Shapiro has kindly offered this addition to the many benefits of tropical milkweed, which is also a reminder that both native and non-native plants often have medicinal properties: “Asclepias curassavica is known as “cancerillo” in rural Latin America and a root extract is reputed to have anti-cancer properties. It has a huge number of ethnobotanical uses. Because steroid cardenolides are highly toxic, it should not be used except under the guidance of an expert herbalist. I do not know if the alleged anti-cancer activity has been formally investigated. Virtually every rural peasant I have asked about it in Colombia, Mexico, Peru, Argentina and Chile knows its reputation.” Thank you, Professor Shapiro, for this useful information. Professor Shapiro has traveled widely in Latin America to visit his butterfly friends. October 1, 2022
Elgin Botanical Garden
David Hosack studied under the tutelage of the botanical pioneers in England who taught physicians how to use plants to treat their patients. When he returned home in 1794 he was determined to establish a botanical garden in New York that would be available to medical students at Columbia College, where he taught. The botanical garden was needed to collect plants from all over the globe, including the unsettled regions of the new nation. That was his life’s work.
Hosack began his venture by trying to convince Columbia College that a botanical garden was needed to educate physicians and supply them with the medicines they needed for their patients. It was his intention to collect plants from all over the world to study their medicinal properties and make more therapeutic remedies available to physicians and their patients. Every plant in the world was potentially useful in his opinion. He named the garden Elgin Botanical Garden after his father’s home town in Scotland.
Elgin Botanical Garden, 1810
When Hosack was unable to convince Columbia College to make this investment for their medical school, he built the garden himself at his expense. He also tirelessly recruited plant specimens from all over the world. Although he built a world-class institution, he was draining his personal resources. He tried and eventually convinced the State of New York to buy the garden from him. The State acquired the garden, but did not provide for its maintenance. Hosack lost control over the management of the garden and it was quickly gutted by unscrupulous managers who sold the collection for personal gain. The garden was in ruins when Hosack died in 1835. The garden is commemorated by a small plaque on the Rockefeller Center that occupies the ground where the Elgin Botanical Garden was built.
The Historical Context
The story of David Hosack’s extraordinary accomplishments takes place within the context of early American history. Hosack knew every major player in American politics, government, literature, science, and business. He was personal friends with both Alexander Hamilton and Aaron Burr. He was asked by Hamilton to attend the duel with Aaron Burr and he attended his death after the duel in 1804. Hosack had strong feelings about the obligations of physicians to remain neutral in all political matters. Although he had a strong affection for Hamilton, he maintained his friendship with Aaron Burr until his death. Burr’s sad story appears many times in American Eden, as he descends into a life of obscurity because of his role in Hamilton’s death, a choice he is said not to have regretted.
Many other important people appear in the story as Hosack befriends them and often plays a role in their success. Napoleon Bonaparte’s botanist is among those who revered Hosack. When Napolean sent him to America to collect new plants, Hosack took him under his wing. He studied plants at the Elgin Botanical Garden while earning his degree as a physician. Hosack and Alire Raffeneau Delile had a life-long correspondence. Hosack’s son, Dr. Alexander Hosack, visited Delile in France after his father’s death. Delile recognized him instantly as Hosack’s son and embraced him warmly. He showed Alexander Hosack his prized possession, his long correspondence with David Hosack.
David Douglas, the Scottish botanist who named many American native plant species during his expeditions in America was a friend of Hosack. Douglas visited California where he named Douglas fir and Douglas iris, among others. Douglas studied with Hosack and later acknowledged his importance to American botany by naming a new genus of wildflower he found in the Western US Hosackia, as a tribute to his favorite American.
Hosackia oblongifolia
American Eden is a rewarding book for many reasons, including an intimate glimpse into the lives and events of early America. It is also a reminder of the heavy price of botanical ignorance that is relevant to the horticultural controversies of today.
American Eden: David Hosack, Botany, and Medicine in the Garden of the Early Republic, Victoria Johnson, W.W. Norton & Company, 2018
Weeds: In Defense of Nature’s Most Unloved Plants, Richard Mabey, Profile Books Ltd, London, 2010
San Francisco Forest Alliance (SFFA) is a 501(c)4 not-for-profit organization with a mission of inclusive environmentalism. SFFA fights to protect our environment through outreach and providing information. SFFA opposes the unnecessary destruction of trees, opposes the use of toxic herbicides in parks and public lands, and supports public access to our parks and conservation of our tree canopy.
With permission, Conservation Sense and Nonsense is republishing SFFAs annual report on pesticide use by San Francisco’s Recreation and Park Department. The report separates pesticide use in so-called “natural areas” from other park areas and finds that most pesticides are used in “natural areas.” Conservation Sense and Nonsense is grateful to SFFA for compiling and reporting this important information.
Conservation Sense and Nonsense follows pesticide use by the East Bay Regional Park District (EBRPD), where the pattern of pesticide use is similar to San Francisco’s Recreation and Park Department. EBRPD has restricted spraying of glyphosate pesticides in developed areas of the park while continuing to use pesticides in naturalized areas to eradicate non-native plants. In other words, most pesticide use in the public parks of the San Francisco Bay Area is devoted to eradicating non-native plants.
Conservation Sense and Nonsense
As we usually do, we compiled the pesticide usage data for San Francisco Recreation and Parks Department for 2021. (We exclude Harding Park – but not the other golf courses – from this analysis because it’s externally-managed under a PGA contract to be kept tournament-ready at all times.) We’re pleased to note that SFRPD has reduced its pesticide usage in comparison to 2020 and 2019.
NATIVE PLANT AREAS USE MORE OF THESE TOXIC HERBICIDES
But this is not true of the Natural Resources Division (this includes PUC areas managed in the same way – i.e. use of toxic herbicides against plants they dislike). Their usage has risen and is the highest it’s ever been from 2016.
The Natural Resources Department (NRD, formerly the Natural Areas Program or NAP) is the entity that is trying to bring “native” plants to more than a thousand acres of our parks, cuts down trees and restricts access to people and their pets. NRD, which accounts for perhaps a fourth of the land area, used over 70% of the pesticides measured as active ingredients in fluid ounces.
NRD – and PUC lands that they are managing the same way – continued to increase their use of triclopyr since the new pesticide Vastlan has been designated Tier II (More Hazardous) instead of Garlon, which was Tier I (Most Hazardous). In both herbicides, the active ingredient is triclopyr. They also increased their usage of imazapyr, and continued to use Roundup, though in smaller quantities than before.
Here are the two earlier graphs lined up to show the comparison. The Native Plant areas used more herbicides in 2021 than they had ever used in the last six years – or that the other SFRPD departments together used in the same time. Their failure to reduce usage in 2021 is in stark contrast to the more than 50% drop in the other SFRPD.
SFRPD Other (i.e. other than the Native plant areas) uses mainly Polaris (imazapyr) and Clearcast ( ammonium salt of imazamox). The native plant areas, NRD / SFPUC, use large amounts of triclopyr, (Garlon and Vastlan), as well as some glyphosate (Roundup).
A FAILING STRATEGY
The NRD’s continually growing usage of the herbicides is a sign that this strategy is failing. They have been using hazardous chemicals on some 50 target species of plants year after year. Theoretically, the point of using toxic herbicides on unwanted species is to allow the desired species to replace them. Instead, the growing usage of these chemicals shows that if anything, the situation is only made worse.
This stands to reason; “invasive” plants are successful because they are better adapted to current conditions. If they are destroyed with herbicides, the replacement is likely to be the next best adapted (thus, invasive) species. Given 50 target species, the bench is deep. This leads to a vicious cycle of hazardous herbicide use, clearly visible in the graph above.
PESTICIDES COME TO SHARP PARK
For many years since we started compiling these data, Sharp Park has been off-limits for pesticides. We’ve seen very minimal usage – maybe 3 or 4 times over all the years. It’s home to the red-legged frog, and the San Francisco garter snake.
In 2021, that changed. In the space of one year, pesticides were applied 9 times. We did anticipate this would happen as NRD extended its grip on this park.
TIER HAZARD RATINGS
San Francisco’s Department of the Environment (SFEnvironment) assigns Tier hazard ratings to the various pesticides it uses. Tier III is Least Hazardous, Tier II is More Hazardous, and Tier I is Most Hazardous. Over the years we have been following this usage, we have seen various chemicals being moved from one Tier to another. Milestone was moved from Tier I to Tier II; Glyphosate (Roundup, Aquamaster) from Tier II to Tier I; and triclopyr (Garlon, Garlon 4 Ultra, Turflon, Vastlan) from Tier I to Tier II (for Vastlan and Turflon). Avenger was moved from Tier II to Tier III, which we think makes sense and makes analysis easier. We analyze the usage of Tier I and Tier II herbicides.
REDUCE OR ELIMINATE HERBICIDE USE
SF Forest Alliance has been trying to encourage SFRPD to reduce or eliminate Tier I and Tier II herbicide use. Some years ago, it appeared that pesticide usage was declining, especially after the Roundup revelations. When we wrote our Pesticides report for 2016, the other areas of SFRPD had slashed their herbicide use; the NRD accounted for 74% of pesticide usage. The 2021 data have renewed our hope that SFRPD’s other departments will adopt a cautious approach to the use of toxic herbicides. Unfortunately, this does not appear true of the nativist departments, NRD / PUC.
Every year, the San Francisco Forest Alliance also makes public comment at the annual review of San Francisco’s Integrated Pest Management program. Conservation Sense and Nonsense is grateful for SFFA’s vigilance of pesticide use in San Francisco’s public parks. Below is an excerpt from SFFA’s public comment to the Commission on the Environment regarding San Francisco’s IPM program.
Conservation Sense and Nonsense
Once again we are sending our comments emphasizing the self-evident truth that high toxicity herbicides are dangerous, unnecessary, and should never be used…
Below are the points we have repeated year after year for many years:
Herbicidal chemicals are more toxic, more persistent, more mobile and more dangerous than their manufacturers disclose;
The aesthetic or ideological “danger” from “weeds” is not a risk to health and welfare;
Scientific studies associate exposure to herbicides with cancer, developmental and learning disabilities, nerve and immune system damage, liver or kidney damage, reproductive impairment, birth defects, and disruption of the endocrine system;
There is no safe dose of exposure to those chemicals because they persist in soil, water, and animal tissue, so even low levels of exposure could still accumulate and harm humans, animals, and the environment;
Especially vulnerable individuals include infants, children, pregnant women, the elderly, people with compromised immune systems and chemical sensitivities;
Toxic runoff from herbicides pollute streams and groundwater, and therefore the drinking water sources;
Herbicides are harmful to pets and wildlife – including threatened and endangered species, plants, and natural ecosystems;
Herbicides are harmful to soil microbiology and contaminate soil into the future, reducing biodiversity in sensitive areas…
Conservation Sense and Nonsense 