Forest Action Brigade: “Oakland’s Vegetation Management Plan is significantly improved”

The City of Oakland began the process of developing a Vegetation Management Plan (VMP) over three years ago.  The purpose of the VMP is “to evaluate the specific wildfire hazard factors in the Plan Area [2,000 acres of city-owned parks and open space and 300 miles of roadsides] and provide a framework for managing vegetative fuel loads…such that wildfire hazard is reduced and negative environmental effects resulting from vegetation management activities are avoided or minimized.” (revised VMP, page 3)

The first draft of the VMP was published in June 2018.  There were significant issues with the first draft that were described by Million Trees HERE.

The VMP was revised and published on November 1, 2019.  It is available HERE.  Written comments can be submitted until December 12, 2019. Scoping comments may be submitted by email (arobinsonpinon@oaklandca.gov) or by mail to Angela Robinson Piñon, 250 Frank H. Ogawa Plaza, Suite 4314, Oakland California 94612.  “Scoping” is the first step in the process of preparing an Environmental Impact Report (EIR). The purpose of scoping is to identify the issues that must be evaluated by the EIR.

The Forest Action Brigade accepts the revised VMP because fire hazards are real and compromise is needed to address them.  Public comments submitted by the Forest Action Brigade regarding scoping for the EIR explain our reasoning. See below. We believe the revised VMP will reduce fire hazards in Oakland without destroying more trees than necessary and limiting herbicide use primarily to preventing trees from resprouting after they are removed.  It is counterproductive to destroy more trees than necessary because climate change has made wildfires more frequent and destructive and carbon sequestered by mature trees is one of the most effective means of reducing greenhouse gas emissions causing climate change.

TO: Angela Robinson Pinon, Oakland Fire Department
arobinsonpinon@oaklandca.gov
FROM: Forest Action Brigade
RE: Oakland’s Vegetation Management Plan, Scoping Comments for EIR

The revised Vegetation Management Plan is a significant improvement over the first draft.  We accept the revised Vegetation Management Plan for the City of Oakland because:

  • Standards for creating and maintaining defensible space around structures, along roadsides, and on ridgelines are reasonable and consistent with both fire science and State law.
  • Forests will be thinned, but “broad based tree removal is not proposed.” Mature trees will be retained, which reduces carbon loss.  Fire ladders to tree canopies will be eliminated.
  • Forest canopy will be retained so the forest floor is shaded and growth of flammable understory grasses and shrubs is suppressed. Density of the canopy will be reduced, but the canopy will be intact.
  • Herbicide will be used to prevent resprouts of trees that are removed, but foliar spraying will be “minimized.” The VMP acknowledges that vegetation killed by foliar spraying is left in place and becomes dry, easily ignited fuel.
  • Best Management Practices for herbicide use require that all applications be done by certified applicators and requests for herbicide application be approved by a licensed pest control advisor.
  • The revised VMP acknowledges that the flammability of plants and trees is unrelated to the nativity of the species. The VMP classifies some species of both native and non-native plants and trees as “pyrophytic.” Non-native plants are not inherently more flammability than native plants.  Flammability is related to the physical and chemical characteristics of plants, not their nativity.
  • The VMP clearly states that the implementation of the VMP is the responsibility of the Oakland Fire Department. OFD is not obligated to respond to the wishes of advocacy organizations unless their proposals are consistent with fire hazard mitigation.

The revised VMP will reduce fuel loads and risk of ignition.  The revised VMP is a fire hazard reduction project with one exception:  the VMP continues to propose the destruction of individual non-native trees within stands of native trees.    However, that proposal is ranked as Priority 3 and is therefore unlikely to be funded. Oakland’s Tree Services Division is inadequately funded and severely understaffed.  Tree Services does not have the resources to remove trees unless they are dead or pose a hazard to the public.  Neither Tree Services nor this VMP is responsible for landscape type conversion: “This VMP does not propose vegetation type conversion as an end goal or strategy…” (Page 1)  Moreover, such unnecessary removal of mature trees damages the surrounding environment, especially in riparian areas, and increases carbon loss, contributing to climate change.

If the VMP is ultimately funded by renewal of the parcel tax for fuels management, revenues should not be used to hire contractors to destroy individual non-native trees within stands of native trees because that would not reduce fire hazards.  The previous parcel tax was cancelled by voters partly because it was misused to fund native plant projects that conflict with fire hazard mitigation.  When native plant advocates plant rare, protected plants in Oakland’s parks and open spaces (which they do), they then oppose fuels management that threatens the plants they prefer.  It is not possible to mow a meadow of grass to prevent ignition without simultaneously destroying individual plants in that meadow.  We saw that principle at work at the public hearing by the Planning Commission on November 20, 2019.  The parcel tax that we would vote for would explicitly prohibit the use of the revenue for vegetation type conversion that is incompatible with fire hazard mitigation.

Scoping Issues

These issues must be addressed by the Environmental Impact Report for the revised VMP, as required by CEQA State law:

  • Carbon loss resulting from tree removals must be estimated. Mitigation for carbon loss must be proposed or negative environmental impact must be acknowledged and estimated. Carbon loss contributes to climate change and climate change is making wildfires more frequent and intense.  Therefore carbon loss increases wildfire hazards and must be estimated by the EIR for this project.
  • The EIR must identify the herbicides and estimate the quantities that will be used to implement the VMP. The amount and impact of pesticides to be used in the VMP should be compared with Oakland’s current levels of herbicide use in the city, including roadside applications. Known hazards of the herbicides that will be used should be acknowledged by the EIR, such as collateral damage to non-target trees and vegetation, damage to the soil, risks to wildlife and human health, mobility and persistence in the environment, etc.  The EIR should mitigate for the increased herbicide use by providing mechanisms for accountability to the public, such as a yearly publicly accessible report on pesticides used in this project, including brand names, location, date, method of application, and quantities. Prohibition of herbicide applications by “volunteers” who are not employees or contractors of the City of Oakland should also be added to Best Management Practices to prevent unauthorized herbicide applications in Oakland.
  • CEQA requires that alternative plans must be considered by an EIR. Typically, “no project” is one of the alternatives.  A third alternative should be less destructive, not more destructive than the proposed project.  For example, an alternative to destroying only non-native trees, as proposed by the VMP, would be to destroy bay laurels that are also a pyrophytic species, as well as vectors for Sudden Oak Death that has killed 50 million oaks in California since 1995.  In 2019, the rate of SOD infection increased from 1% to 12% in one year in sampled trees between Richmond and San Leandro.   Source:  https://www.sfchronicle.com/environment/article/Sudden-oak-death-spreading-fast-California-s-14815683.php?cmpid=gsa-sfgate-result

There are several advantages to thinning bays and Monterey pines rather than eucalyptus:

  • Every dead oak becomes fuel. Therefore, reducing SOD infections prevents oaks from becoming fuel.
  • Bays branch to the ground, providing fuel ladders that are difficult to eliminate because the tree trunk often sprawls on the ground.
  • Removing bays instead of eucalyptus also reduces carbon loss because bays are smaller trees and they have shorter lives than eucalyptus trees, which are expected to live another 200-300 years in the Bay Area based on their longevity in their native range.
  • Monterey pine has a shorter lifespan than eucalyptus and it is a soft-wood tree. Therefore, removal of Monterey pine will result is less carbon loss than destruction of eucalyptus. Furthermore, Monterey pines do not resprout after destruction.  Therefore, they will not require herbicide treatment to prevent resprouts as eucalyptus does.  Many Monterey pines in the East Bay are nearing the end of their lives because of when they were planted as well as pine pitch canker infection.
  • “We ask that a 4th alternative be considered by the EIR.  A “no pesticides” alternative would acknowledge the public’s concerns about the potential for increased pesticide use in Oakland that could be enabled by the completion of the EIR.  That alternative must propose a method of preventing tree resprouts without using herbicides.  There are precedents for such methods.  East Bay Municipal Utilities District does not use herbicides to prevent resprouts.  UCSF does not use any pesticides in the Sutro Forest where thousands of trees have been destroyed and thousands more will be destroyed in the future.”  Addendum 12/2/19
  • CEQA requires that cumulative impacts of similar projects be identified by the EIR. Fuels management projects similar to the VMP are being implemented all over the East Bay. Tree removals by PG&E should be included. The cumulative impact of all fuels management projects in the East Bay must be acknowledged by the EIR.

We hope the revised VMP will survive the public process required to bring it to fruition because we believe it will reduce fire hazards in its present form.  We believe that fire hazards are real and that compromise is needed to address them.  We congratulate the consultants who prepared the VMP and OFD for shepherding it to completion. Those who were involved in its preparation listened patiently and were responsive to the public’s concerns.  We are grateful.

Forest Action Brigade

Tilden Park, October 2016. East Bay Regional Park District has thinned this area to distances of 25 feet between remaining trees. The forest floor is still shaded because the canopy is intact.

Study design determines study findings

Million Trees can never resist a response to misinformation we find in Jake Sigg’s Nature News. (In this case, the statement originates with one of Jake’s readers, not Jake himself.)

“This study takes some of the life out of Art Shapiro’s ecological fitting theory:  Non‐native plants supported significantly fewer caterpillars of significantly fewer specialist and generalist species even when the non‐natives were close relatives of native host plants.”  “Non-native plants reduce abundance, richness, and host specialization in lepidopteran communities” by Karin Burghardt, Doug Tallamy, et, al. (Ecosphere, November 2010).

We’ll get to the study later, but first let’s address the statement about ecological fitting.  Ecological fitting is more accurately described as an observation, rather than a theory or hypothesis and it does not originate with Art Shapiro.  The first observation of ecological fitting was recorded by Dan Janzen in 1980 and described by other ecologists as “the process whereby organisms colonize and persist in novel environments, use novel resources or form novel associations with other species as a result of the suites of traits that they carry at the time they encounter the novel condition.” (1) Ecological fitting is an alternative to the view that relationships between plants and insects and parasites and hosts are the result of co-evolution.  It is consistent with the observation that adaptation to new arrivals in an ecosystem often occurs without evolutionary change and can occur more rapidly than co-evolution would require.

The Colorado potato beetle readily devours an introduced relative of its Solanum hosts as a result of ecological fitting.  (Hsiao, T. H. (1978). “Host plant adaptations among geographic populations of the Colorado potato beetle”. Entomologia Experimentalis et Applicata. 24 (3)) USDA photo

Ecological Laboratory Science

The Burghardt/Tallamy study is a laboratory experiment in the sense that it creates an artificial environment by planting a garden in which it chooses the plant species and then inventories the insect visitors to the garden.  In one garden, native plant species were paired with a closely related species of non-native plant in the same genus (called congeners).  In another, distant garden, native plant species were paired with unrelated species of non-native plants.  The insect visitors that were counted are specifically the larvae stages (caterpillars) of lepidoptera (moths and butterflies).  The adult stage of the caterpillars (moths and butterflies) were not inventoried, nor were members of the other 28 insect orders.

Source: handsontheland.org

The study considers caterpillars “specialists” if they feed on three or fewer plant families.  The authors make this determination based on scientific literature and on observations of their artificially created garden.  Using scientific literature, 30% of visiting caterpillar species to the experimental garden were specialists.  Using actual visits to their experimental garden, 64% of visiting caterpillars were specialists.  The difference is as we should expect because the scientific literature is based on the behavior of caterpillars in the field, but the study confines the choices of the caterpillars to a few specific plant species chosen by the authors of the study.  In other words, caterpillars in the experimental garden had fewer choices of plant species.

The inventory of caterpillars was conducted over two summer months in 2008 and three summer months in 2009.  Findings were very different in the two years of the study:  “We found no difference between the total Lepidoptera larvae supported by native plants and their non-native congeners in 2008, but found over three fold more larvae on natives in 2009.  In 2008 there was no difference in the abundance of generalists on native and non-native congeners, but natives supported more than twice as many generalists as non-natives in 2009.” (2) Similar results were reported for species richness (number of different larvae species).  When paired with unrelated non-native plants, caterpillars showed a significant preference for native plant species, as we should expect because the plants were not chemically similar.

Caterpillar of Anise swallowtail butterfly on its host plant, non-native fennel. Berkeley, California

Although on average, native species attracted more caterpillars than the non-native congener with which they were paired, the strength of that difference varied significantly.  One matched pair attracted eight times as many caterpillars to the native plant compared to the non-native plant.  Another matched pair attracted slightly more caterpillars to the non-native plant compared to the native plant.  

The study authors interpret the significant differences between findings in the first and second years as an indication that caterpillars accumulated more rapidly on native plants than on non-native plants.  They speculate that a longer study would have found even greater preferences for native plants compared to non-native congeners.  Given that adaptation to introduced species occurs over time that is a counter-intuitive prediction.  In fact, many studies find that insects have made a successful transition from native to non-native hosts within a few generations.

Limitations of laboratory studies

The Burghardt/Tallamy study is often cited by native plant advocates in support of their belief that insects require native plants for survival.  This generalization is not supported by the results of the Burghardt/Tallamy study because:

  • The study results are not relevant to all insects.  The findings apply only to the larvae stages of moths and butterflies.  The adult stages of moths and butterflies also require nectar and pollen from a much broader range of plants than their host plant, where the adult lays its eggs and caterpillars feed before becoming flying adults.  At the adult stage of their lives, they become pollinators.  Studies of the preferences of pollinators consistently find that a diverse garden that prolongs the blooming period is most useful to them. 
  • The study does not support the claim that caterpillars consistently choose native plants in preference to closely related non-native plants over time.  In fact, other studies find such preferences fade over longer periods of time.
  • Statements made by native plant advocates about the degree to which caterpillars are “specialized” are often exaggerated.  When a diverse landscape is available to caterpillars, scientific literature reports that specialization to a few plant families is found in only 30% of the 72 caterpillar species identified by this study. 
  • The Burghardt/Tallamy study was conducted on the East Coast where the climate is different than California.  It snows in the winter and it rains during the summer, unlike most of California.  Our native plants are therefore different from natives on the East Coast.  The Burghardt/Tallamy study was conducted in the summer months from June to August.  Native plants in California are no longer blooming and many are dormant during summer months unless they are irrigated.  The findings of the Burghardt/Tallamy study are therefore not applicable to California unless they can be replicated here.
This is the Serpentine Prairie in Oakland. It is one of the native plant “restorations” done by East Bay Regional Park District. About 500 trees (including native oaks) were destroyed to return the prairie to native grassland. This is what it looks like in June.

Comparison of laboratory with field studies

The Burghardt/Tallamy study does not contradict the findings of Professor Art Shapiro because Professor Shapiro is studying butterflies (not moths) in “natural areas” that have not been artificially created by choosing a limited number of plant species.  In other words, the adult and larvae stages of butterflies that Professor Shapiro studies have more options, and when they do they are as likely to choose a non-native plant as a native plant for both host plant and food plant.  You might say, Professor Shapiro’s study occurs in the “real world” and the Burghardt/Tallamy study occurs in an artificially created world. 

Anise Swallowtail butterfly in non-native fennel. Courtesy urbanwildness.org

The credibility and relevance of Professor Shapiro’s studies are also based on 47 years of visiting his research plots at least 250 days per year, that is, year around.  During that period of time, he recorded his observations and they were statistically analyzed for the study he published in 2003. (3)  His study is of particular interest as the climate changes rapidly because the length of the study also enables us to observe the impact of climate change on our butterfly population in the Bay Area.  In contrast the Burghardt/Tallamy study was conducted in a total of 5 months over a total of two years.  Population trends cannot be determined from such a short study.

Burghardt/Tallamy study is consistent with mission of Million Trees

The Burghardt/Tallamy study does not contradict anything Million Trees advocates for.  Decisions to plant a particular species and the decision to eradicate a particular species are entirely different.  Gardeners should plant whatever they prefer, in my opinion.  When planting decisions are made for public land, I prefer that plants be capable of surviving current local and climate conditions.  When my tax dollars are being spent, I prefer that they not be wasted. Besides, I hate watching plants and trees die in the parks I visit.

This study is consistent with my view that non-native plants don’t threaten the survival of insects unless they replace native plants that insects prefer.  The Burghardt/Tallamy study quite rightly does not say that they do.  Local experience in the Bay Area informs me that they rarely do.  To the extent that they have replaced native plants, they are better adapted to current conditions in a specific location.  Eradicating them rarely results in native plants successfully replacing them.  As the climate continues to rapidly change, the failure of native plant “restorations” is inevitable because vegetation changes when the climate changes.

Site 29 on Claremont Blvd in Oakland is one of the places where UC Berkeley destroyed about 19,000 trees about 14 years ago. Non-native weeds thrive in the sun where trees were destroyed. Poison hemlock and thistle (both non-native) are 8 feet tall where not sprayed with herbicide. Site 29, May 2016.

The Burghardt/Tallamy study does not justify eradication of non-native plants because it does not take into account the damage done by the methods used to eradicate non-native plants.  Since most eradication projects use herbicides, we speculate that more harm is done to insects by herbicides than by the existence of non-native plants.

The decision to eradicate non-native plants must also take into consideration whatever benefit the plants may provide, such as food for wildlife.  For example, even if a plant species isn’t a host plant, it might be a food plant. Butterfly bush (Buddleia) is an example of a plant that is very useful to pollinators, including butterflies, but native plant activists advocate for its eradication. 

Monarch nectaring on butterfly bush. butterflybush.com

Many thanks to Jake Sigg for creating this opportunity for dialogue with native plant advocates.  I am grateful for the window into the community of native plant advocates that Jake’s Nature News provides.

  1. Agosta, Salvatore J.; Jeffrey A. Klemens (2008). “Ecological fitting by phenotypically flexible genotypes: implications for species associations, community assembly and evolution”. Ecology Letters11 (11): 1123–1134. 
  2. “Non-native plants reduce abundance, richness, and host specialization in lepidopteran communities” by Karin Burghardt, Doug Tallamy, et, al. (Ecosphere, November 2010).
  3. SD Graves and AM Shapiro, “Exotics as host plants of the California butterfly fauna,” Biological Conservation, 110 (2003) 413-433

Happy New Year and Farewell

The Million Trees blog is folding its tent and moving on because most of the projects in the San Francisco Bay Area that I have followed for 20 years have been approved, funded, and are being implemented.  Every public land manager in the Bay Area has made a commitment to destroying most non-native trees and using pesticides for that purpose.

If you wish to continue following the development of these projects, I recommend these websites:  San Francisco Forest Alliance Defend East Bay Forests, Save the East Bay Hills, and Hills Conservation Network.

For the record, this is a brief summary of my beliefs about the environment:

If I return to the blogosphere in the future, the title and mission of a new blog would change.  The focus would be the science that informs my commitment to the cosmopolitan landscape that exists, rather than the fantasized landscape of the past.  I will also continue to inform readers of new studies that find evidence of the damage that pesticides do to the environment and its inhabitants.  If you are a subscriber to the Million Trees blog, you will be informed if I publish a new blog.

Thank you for your readership.

Million Trees

More opposition to Measure FF

As you make the important decision about voting on Measure FF, please take into consideration that Million Trees and the Forest Action Brigade are not the only East Bay residents who plan to vote against Measure FF.  Today we tell you more about why many East Bay voters have made that decision.

Post-election update:  Measure FF passed easily.  In Alameda County 85% of voters approved Measure FF.  In Contra Costa County 80% of voters approved Measure FF.  These were the vote tallies on the day after the election, on November 7th.  

A ’91 fire victim and survivor tells us why he will vote against Measure FF

The East Bay Times published the following op-ed about Measure FF on October 4th. It was written by Peter Scott. He states his opposition to Measure FF clearly and emphatically.  Emphasis and photo have been added.

“Save trees, ‘no’ on Alameda County’s Measure FF”

“Alameda County’s proposed Measure FF, East Bay Regional Park District Parcel Tax Renewal, appears innocent enough: improvements in area parks, safety, a 20-year continuation of a 2004 plan to enhance the public’s enjoyment of East Bay Regional Park District (EBRPD) properties.

And the tax — a dollar a month per single-family residence and $69 a month for multifamily units in Alameda County — seems affordable. But wait: Half of the money raised by this measure would fund destruction of thousands of healthy, mature trees in the East Bay hills.

This isn’t the first time this deforestation has been proposed. In 2013, FEMA offered a similar plan, to be implemented by UC Berkeley, the city of Oakland and the EBRPD. After the plan’s environmental impact was discussed in three public hearings, citizens responded with 13,000 written comments, which, by FEMA’s count, were 90 percent against the plan.

The reason, subsequently confirmed in litigation, was that the plan would involve significant, permanent negative impacts to the environment but would still fail to achieve its stated goal — to reduce risk of fire in the hills. The U.S. Forest Service commented that in terms of mitigating risk, it would be better to do nothing than to proceed with FEMA’s plan. The reason this type of proposal keeps popping up is because it is the object of long-term lobbying by a clique of nativists who want to rid the hills of species they don’t like. Their reasoning depends on myths such as these:

  • Once upon a time, before white people came and changed things, the hills were a stable environment of so-called native vegetation that was healthy and inherently fire-resistant;
  • “native” species tend to be less likely to ignite, and they have manageable flame lengths (the distance at the ground from the flame’s leading edge to its tip);
  • and trees are the culprit and were the primary reason that the 1991 fire burned out of control.

These statements are not only incorrect, they are the opposite of the truth. The old landscape burned regularly; the flame lengths of “native” brush and grasses are multiples of mature trees’ flame lengths and create conflagrations that fire personnel won’t fight because they spread and change direction so fast; the 1991 fire was a STRUCTURE fire, not a vegetation fire: houses set fire to trees, not the other way around.

Factually, the ’91 fire was human-caused. First, it was a contractor’s construction debris fire that escaped into the brush; secondly, it was a reignition from embers that the Oakland Fire Department had failed to extinguish. The official report examining the causes doesn’t mention trees but does criticize the OFD’s failures in its incident command’s preparation, training and management during the fire. Of the 16 major fires in the hills since 1905, there are basically two categories: human-caused (10 fires) and “unknown cause” — it’s a safe bet most of those “unknowns” were also human-caused.

If Measure FF is truly focused on fire risk mitigation, it would fund regular removal of fine fuels around the base of the trees — as EBMUD does so successfully — because it is the brush, grasses and debris on or near the ground that are most likely to ignite and are key to the fire’s spread and ferocity. Leave the tall trees alone, because they reduce wind, shade the ground, catch fog drip and discourage growth of flammable, weedy plants. If trees are not cut down, then repeated applications of herbicides to kill re-sprouts are unnecessary.

Measure FF proposes to fund some good things — maintenance and improvements in the parks — but they make FF a Trojan horse. They are sugar-coating on a foul and foolish enterprise: deforestation to create so-called “oak-bay savannahs,” which are actually grass- and brush-covered hills, dotted with occasional low trees — the type of landscape that has been burning so fast and ferociously in Lake and Sonoma counties and throughout the state. We must send the FF authors back to the drawing board, telling them to come back to us when they have plan that will actually reduce, not increase, the fire hazard.”

Peter Scott, Oakland, California

No one is more knowledgeable about East Bay fire history and fire hazard mitigation than Peter Scott.  He is a founding member of the Claremont Canyon Conservancy and the Hills Conservation Network.  He is passionate about fire safety in the East Bay partly because of his personal loss.  His home burned down in 1970 and 1991 and his mother was killed in the 1991 fire.  Since 1991, he has made fire hazard mitigation one of his personal priorities.  Peter Scott and his wife, Teresa Ferguson, instigated the Civil Grand Jury report about the ’91 fire.

Alameda County Green Party says “NO on Measure FF”

The Alameda County Green Party has recommended that “green” voters vote NO on Measure FF, with reservations. This was a difficult decision for the Green Party, as it was for us. We all love the parks and we know that some of the money raised by Measure FF will be used to make needed and appropriate park improvements. They explain their reservations and the reluctant conclusion they reached in their Green Voter Guide that is available on line. Here’s what they say about their decision (emphasis added):

“The Green Party of Alameda County recommends a NO vote, with reservations, on Measure FF (Alameda/Contra Costa Counties):

If approved by voters, Measure FF would simply continue existing Measure CC funding. Voters passed Measure CC in 2004 to provide local funding for park infrastructure, maintenance, safety, and services. Measure CC is a $12/year parcel tax that is set to expire in 2020. Measure FF is expected to raise approximately $3.3 million annually until it expires in 20 years.

Measure CC boasts a long list of successful improvement to East Bay Regional Parks in areas of public safety, wildfire mitigation, healthy forest management, shoreline protection, environmental stewardship, habitat preservation, park infrastructure and maintenance, recreational and educational programming, and visitor services.

While impacts of the Measure have been wide-ranging and largely celebrated, record California wildfires in 2018 have caused both opponents and proponents of the Measure to highlight the wildfire mitigation aspect of the program. Neither Measure CC nor Measure FF contains language that details how to approach reducing wildfires, however, Measure CC’s funds helped in developing the Wildfire Hazard Reduction and Resource Management Plan (“Plan”) that was approved in 2010 by the East Bay Regional Parks District (EBRPD) Board of Directors.

Proponents state that passing Measure FF is critical to continue to reduce risk of wildfires along the wildland-urban interface. They accept that thinning of certain tree species and controlled use of herbicides are tools outlined in the Plan to accomplish the task.

Opponents are against unnecessary removal of non-native species and use of herbicides (EBRPD has expanded use of herbicides and clear-cutting), arguing that extreme fires are driven by effects of climate change, not a particular tree species. Opponents agree with many fire experts that the key defense of homes against wildfire is defensible space, and argue that clear-cutting removes trees that sequester carbon (mitigating climate change) and removes the canopy that provides habitat for species and helps cool the environment. On pesticide use, they simply say: “If organic farmers can do it, so can EBRPD!”

We agree with the opponents: There are environmentally-sensitive alternate approaches to reducing wildfire risk that do not involve removing so many trees and applying poisons in East Bay parks, but the EBRPD Board must be willing to implement them. Vote “No” to send a message to the Board that we can do better. Our reservations are that we like the parks and want to protect them, and we appreciate most of the improvements that Measure FF funds.”

Alameda County Green Party

We are deeply grateful to the Green Party for their decision and we commend them for considering all sides of this complex issue, which is seldom done by political organizations.

Deliver the message to the Park District

Whatever the outcome of this election, votes against Measure FF will deliver a clear message to the Park District:  STOP destroying healthy trees and killing harmless plants and trees with dangerous pesticides!! 

This is the big, beautiful yard sign that you can put in your yard and neighborhood road medians in the East Bay.

Peter Scott and the Green Party have delivered this message and you have the opportunity to add your voice by placing a yard sign in your own yard and in the road medians in your neighborhood in the East Bay.  The Forest Action Brigade is offering yard signs at no cost to you.  Request your yard sign by contacting the Forest Action Brigade:  forestactionbrigade@gmail.com or call (510) 612-8566.

Vote NO on Measure FF!!

A vote against Measure FF on the ballot for the November 6, 2018 election is a vote against pesticide use in the East Bay.  If Measure FF passes, it will renew a parcel tax for 20 years.  For the past 15 years, the parcel tax has funded the destruction of thousands of trees on thousands of acres of public parks in the East Bay.  The renewal of the parcel tax will increase the percentage of available funds for tree removals and associated pesticide use from 30% to 40% of funds raised by the parcel tax.

Post-election update:  Measure FF passed easily.  In Alameda County 85% of voters approved Measure FF.  In Contra Costa County 80% of voters approved Measure FF.  These were the vote tallies on the day after the election, on November 7th.  

Tree removals increase pesticide use because herbicides are required to prevent the trees from resprouting.  Also, when the shade of trees is eliminated, the unshaded ground is soon colonized by weeds that are then sprayed with herbicide.  The destruction of trees has put public land managers on the pesticide treadmill.

The public tried hard to convince the East Bay Regional Park District to stop destroying healthy trees and quit using pesticides in our parks.  We attended public hearings and wrote letters to Park District leadership and its governing board.  We made many suggestions for useful park improvements that would be constructive, rather than destructive.  Our requests and suggestions were ignored.

After making every effort to avoid opposition to Measure FF, we reluctantly take a stand against it.  The parks are important to us and we would much prefer to support park improvements.  Unfortunately, Measure FF will not improve the parks.  Rather, it will continue down the destructive path the Park District has been on for the past 15 years. In fact, Measure FF would escalate the destruction and poisoning of our public lands.

On Friday, August 31st, the Forest Action Brigade participated in a press conference rally at Bayer headquarters in Berkeley. Bayer is the new owner of Monsanto, the manufacturer of glyphosate. The rally was sponsored by a labor organization that is concerned about exposing workers to glyphosate, which is probably a carcinogen.  The President of the Forest Action Brigade, Marg Hall, spoke at the rally.

The Voter Information Guides in Contra Costa and Alameda counties have published the following argument against Measure FF that was submitted by the Forest Action Brigade.  We hope you will read it and take this important opportunity to protect our public parks from being needlessly damaged.

Million Trees

Argument Against Measure FF

“We love public parks, and we support taxation which benefits the common good. Nevertheless, We urge a NO vote. East Bay Regional Parks District (EBRPD) has previously used this measure to destroy, unnecessarily, thousands of healthy trees under pretexts such as “hazardous tree” designations and “protection against wildfires”. But fire experts point out that tree shade retains moisture, thereby reducing fire danger. The measure has also funded so-called “restoration”—destruction of “non-native” plants, in a futile attempt to transform the landscape back to some idealized previous “native” era.

EBRPD’s restoration and tree-cutting projects often utilize pesticides, including glyphosate (Roundup), triclopyr, and imazapyr. We agree with the groundswell of public sentiment opposing the spending of tax dollars on pesticides applied to public lands. Not only do pesticides destroy the soil microbiome; they also migrate into air, water arid soil, severely harming plants, animals, and humans. Because EPA pesticide regulation, especially under the current administration, is inadequate, it is imperative that local jurisdictions exercise greater oversight. While EBRPD utilizes “Integrated Pest Management” which limits pesticide use, we strongly advocate a no pesticide policy, with a concomitant commitment of resources.

Given the terrifying pace of climate change, it is indefensible to target certain species of trees for eradication. All trees—not just “natives” —are the planet’s “lungs,” breathing in carbon dioxide and breathing out oxygen. When a tree is destroyed, its air-cleansing function is forever eliminated, and its stored carbon is released into the atmosphere, thus worsening climate change.

Throughout history, plants, animals, and humans have migrated when their given habitats became unlivable. Adaptation to new environments is at the heart of evolutionary resilience. To claim that some species “belong here” and others do not strikes us as unscientific xenophobia.

Until EBRPD modifies its approach, we urge a NO vote.”

Forest Action Brigade

Do not be misled

The arguments in favor of Measure FF are misleading.  East Bay Regional Parks District attempts to portray a destructive agenda as a constructive agenda.  Please look beneath these pretty-sounding euphemisms for the destructive projects of Measure FF:

·       EBRPD claims Measure FF will “protect against wildfires.”  Destroying harmless trees miles away from any residential structures and replacing the shaded, moist forest with dry grassland that easily ignites will NOT “protect against wildfires.”

·       EBRPD claims Measure FF will “enhance public safety” and “preserve water quality.”  Spraying thousands of acres of open space in our water shed with pesticides will endanger the public and contaminate our water supply.

·       EBRPD claims Measure FF will “protect redwoods and parklands in a changing climate.”  Destroying hundreds of thousands of healthy trees, storing millions of tons of carbon, will exacerbate climate change.  Our redwood forest in the East Bay was confined to less than 5 square miles prior to settlement because of the restrictive horticultural requirements of this treasured native tree.  Because redwoods require more water than most of our urban forest, it is a fantasy that they can be expanded beyond their native footprint.  Where they have been planted outside of that range, many are already dead.

·       EBRPD claims Measure FF will “restore natural areas.”  Our pre-settlement landscape in the East Bay was predominantly grassland in which fire hazards are greatest.  A landscape that has been sprayed with pesticide cannot be accurately described as “natural.”  Previous attempts to convert non-native annual grassland to native grassland have consistently failed, partly because the soil has been poisoned with herbicide.

You can help

The Forest Action Brigade is offering yard signs in opposition to Measure FF (shown below).  Request your yard sign by contacting the Forest Action Brigade: forestactionbrigade@gmail.com or call (510) 612-8566.  Please state how many signs you would like and the neighborhood where you plan to place them.  These are the East Bay cities in which Measure FF will be on the ballot:  Oakland, Alameda, Piedmont, Berkeley, Emeryville, Albany, Richmond, San Pablo, El Cerrito.  These cities are the top priority for yard sign placement.

Million Trees

Wildfire cover story is the lie that binds

Native plant advocates originally thought they would be able to destroy all non-native trees in California based entirely on their preference for native plants.  People who value our urban forest quickly challenged that assumption.  Native plant advocates devised a new strategy based on fear.  Fear is the most powerful justification for many public policies that deliver a wide range of agendas, including the current prejudices against immigrants that is shared by many native plant advocates.  After the destructive wildfire in Oakland in 1991, native plant advocates seized on fear of fire to convince the public that all non-native trees must be destroyed.  They made the ridiculous claim that native plants and trees are less flammable than non-native plants and trees.

Scripps Ranch fire, San Diego, 2003. All the homes burned, but the eucalypts that surrounded them did not catch fire. New York Times

Like most lies, the wildfire cover story has come back to bite the nativists.  As wildfires rage all over the west, becoming more frequent and more intense, the public can see with their own eyes that every fire occurs in native vegetation, predominantly in grass and brush and sometimes spreading to native forests of conifers and oak woodlands.  It has become difficult for nativists to convince the public that native vegetation isn’t flammable because the reality of wildfires clearly proves otherwise.

Vegetation that burned in the North Bay files of October 2017. Source: Bay Area Open Space Council

Recently, nativists have become the victims of their own wildfire cover story as they try to reconcile the contradictions in their hypocritical agendas.  These contradictions are now visible both nationally and locally in the San Francisco Bay Area.  We will tell you about the lie that binds nativism today.

Sierra Club caught in the wringer of its own making

The New York Times published an op-ed by Michael Brune, Executive Director of the Sierra Club, and Chad Hansen, ecologist and member of the Sierra Club Board of Directors.  They informed us of a proposed federal farm bill to destroy trees on thousands of acres of national forests without any environmental review.  The stated purpose of this federal plan is to reduce wildfire hazards.

The national leaders of the Sierra Club emphatically disagree that destroying trees will reduce fire hazards.  In fact, they say “increased logging can make fires burn more intensely” because “Logging, including many projects deceptively promoted as forest ‘thinning,’ removes fire-resistant trees, reduces the cooling shade of the forest canopy and leaves behind highly combustible twigs and branches.”

They point out that climate change and associated drought have increased the intensity of wildfires.  Therefore, they say we must “significantly increase forest protection, since forests are a significant natural mechanism for absorbing and storing carbon dioxide.”  Destroying forests contributes to climate change and climate change is causing more wildfires.

The leaders of the Sierra Club tell us that the most effective way to reduce damage caused by wildfires is to “focus on fire-safety measures for at-risk houses.  These include installing fire-resistant roofing, ember-proof exterior vents and guards to prevent wind-borne embers from igniting dry leaves and pine needles in rain gutters and creating ‘defensible space’ by reducing combustible grasses, shrubs and small trees within 100 feet of homes.  Research shows these steps can have a major impact on whether houses survive wildfires.”

Does that strategy sound familiar?  Perhaps you read that exact strategy here on Million Trees or on many other local blogs that share our view that destroying trees is not the solution to fire hazard mitigation and safety. 

Unfortunately, the Sierra Club continues to talk out of both sides of its mouth.  While the national leadership speaks rationally on the subject of wildfires, the local leadership of the San Francisco Bay Chapter of the Sierra Club continues to demand that all non-native trees in the Bay Area be destroyed. 

The City of Oakland recently published a draft of its Vegetation Management Plan (VMP) with the stated purpose of reducing fire hazards.  The draft plan recommends removal of most non-native trees on 2,000 acres of open space and along 300 hundred miles of roads.  The plan seemed unnecessarily destructive to those who value our urban forest and have a sincere interest in reducing fire hazards, but it was unacceptable to the local chapter of the Sierra Club because it does not go far enough to destroy all non-native trees.  Here are some of the revisions they demand in their public comment (1) on the draft VMP:

  • “…removal of all second-growth eucalyptus trees, coppice suckers and seedlings in city parks…”
  • “…removal of 20-year old Monterey Pine seedlings that were allowed to become established after the original pines burned and were killed in the 1991 fire…”
  • “…identify areas of overly mature and near hazardous Monterey Pine and Cypress trees that could be removed…”
  • “…recommend adoption of specific updated IPM policies for the city to implement that will allow appropriate and safe use of herbicides…”
  • “The Sierra Club has developed the right approach to vegetation management for fire safety…The Sierra Club’s program for vegetation management can be summarized by the Three R’s:”
    • “Remove fire dangerous eucalyptus, pine, and other non-native trees and other fire dangerous vegetation like French and Scotch broom…”
    • “Restore those areas with more fire safe native trees like bays, oaks, laurels and native grasslands…”
    • “Re-establish the greater biodiversity of flora and fauna that results from the return of more diverse habitat than exists in the monoculture eucalyptus plantations…”

The local chapter of the Sierra Club is making the same demands for complete eradication of non-native trees in the East Bay Regional Park District.  The pending renewal of the parcel tax that has paid for tree removals in the Park District for the past 12 years was an opportunity for the Sierra Club to make its endorsement of the renewal contingent upon the Park District making a commitment to remove all non-native trees (and many other commitments).

“…the Sierra Club believes it is critical that in any renewal of Measure CC [now Measure FF on the November 2018 ballot] funding for vegetation management should be increased for the removal of non-natives such as eucalyptus and their replacement with restored native habitat…Measure CC [now FF] funds should not be used to thin eucalyptus but must be allocated to the restoration of native habitat.” (1)

The Sierra Club has endorsed the renewal of the parcel tax—Measure FF—that will be on the ballot in November 2018.  In other words, the Park District has made a commitment to removing all non-native trees on our parks.  We have reported on some of the clear cuts that the Park District has done in the past 6 months.

Sibley Volcanic Reserve. Photo by Larry Danos, March 2018

The national Sierra Club and the San Francisco Bay Chapter of the Sierra Club are at odds on fire hazard mitigation.  The national leadership understands that destroying trees will not reduce fire hazards.  They also understand that destroying trees will contribute to climate change that is causing more destructive wildfires.  The local leadership clings to the cover story that native trees are less flammable than non-native trees.

Local nativists change their tune

There is no history of wildfires in San Francisco and there is unlikely to be in the future because it is foggy and soggy during the dry summer months when wildfires occur.  But the reality of the climate conditions and the absence of fire in the historical record never prevented nativists in San Francisco from trying to use the fire cover story to support their demand that thousands of non-native trees be destroyed. 

Summer fog blanket over San Francisco. Courtesy Save Mount Sutro Forest.

Jake Sigg, retired San Francisco Recreation and Parks Department (SFRPD) gardener who is considered the doyen of the Native Plant movement in San Francisco, has a widely circulated email newsletter. In that newsletter, he repeatedly claimed that eucalyptus were dying during the extreme drought and had to be destroyed so they would not cause a catastrophic wildfire.  In fact, eucalyptus did not die in San Francisco or elsewhere in the Bay Area during the drought because they are the most drought-tolerant tree species in our urban forest.  More native trees died in California during the drought than non-native trees. 

Jake Sigg made those dire predictions before the native plant agenda was finally approved in 2017 after 20 years of heated debate and before many wildfires in California have established the truth that wildfires start in grass and brush and seldom in forests and in every case in exclusively native vegetation.

So, to accommodate this new reality, Jake Sigg has changed his tune.  He got his wish that thousands of non-native trees be destroyed in San Francisco as well as a commitment to restore the native grassland that he prefers.  Consequently it is no longer consistent with that agenda to claim that there are acute fire hazards in San Francisco, requiring the destruction of flammable vegetation.

The San Francisco Chronicle published an article about the concerns of park neighbors about dead/dying/dormant grass and brush in parks that they believe is a fire hazard and they want the San Francisco park department to clear that flammable vegetation.  Jake Sigg is now quoted as saying that it isn’t necessary to clear that vegetation—which he prefers—because there are no fire hazards in San Francisco: 

“What protects much of San Francisco’s forested area is the city’s famed fog, said Jake Sigg, a conservation chairman of the local chapter of the California Native Plant Society.  While walking on Mount Davidson on a recent afternoon, he said, one area was so muddy from fog that he has to be careful not to slip…’In the past, (fires) haven’t been too much of a concern for the simple reason that we have had adequate rainfall,’ Sigg said.”

According to nativists, the wet eucalyptus forest must be destroyed, but the dead/dried flammable brush and grassland must be preserved because it is native.

Serpentine Prairie restoration. East Bay Regional Park District

The elusive truth

Despite the constantly shifting story, we are not fooled.  The truth is that native vegetation is just as flammable as non-native vegetation and that destroying trees—regardless of their nativity—will not reduce fire hazards.


(1) These letters on Sierra Club letterhead were obtained by public records requests and are available on request.

Finding the middle ground between competing conservation strategies

Today Million Trees strays off its well-worn path of informing readers of specific projects in the San Francisco Bay Area that destroy our urban forest and spray our public lands with herbicides.  Under the guidance of Charles C. Mann’s latest book, The Wizard and the Prophet (1), we’ll take a detour into the philosophical tenets of conservation.  There are competing visions of the future of humans on Earth and they are instrumental in producing different conservation strategies.

We begin by introducing Charles C. Mann because his previous books are essential to our understanding of ecology.  His 1491 informed us that the New World “discovered” by Columbus was not the pristine landscape that modern-day native plant advocates are attempting to re-create.  Rather it was a land that had been radically altered by indigenous people who had lived in the Western Hemisphere for over 10,000 years.  The landscape had been extensively gardened for food production.  The large animals had been hunted to extinction.  The landscape in the West and Midwest was dominated by open grassland because it had been regularly burned, preventing natural succession to shrubs and trees.

Native Americans setting grass fire, painting by Frederic Remington, 1908

Early explorers carried diseases to the New World to which they were immune, but the native people were not.  By the time settlers arrived two hundred years after early explorers, most of the native people had died of the diseases introduced by the explorers.  Populations of bison and other grazing animals exploded when those who hunted them were killed by disease.  The grazing animals maintained the open grassland that had been created by the fires of the hunters.  Archaeological research has only recently revealed the extent of native populations throughout the New World.

Charles Mann’s second book, 1493, reported the global exchange of plants and animals between the New and the Old Worlds that fundamentally altered both worlds.  The extent and long history of that exchange makes it impossible for us to see those introduced plants, animals, objects as foreigners who “don’t belong here.”

Different visions of the future

Million Trees is indebted to Charles Mann for the books that are the foundation of our cosmopolitan viewpoint of the world.  Mann’s new book, The Wizard and The Prophet is equally important because it helps us understand the interminable debate about conservation.  There is a dark view of the future of the environment that predicts nothing but doom and gloom.  Extinctions dominate their predictions of the future and humans are seen as the destroyers of nature.  The more optimistic view of conservation predicts that the Earth will survive the changes made by humans because humans are capable of innovating to avoid the doom predicted by the pessimists.

Mann describes these contrasting views through the lives of two 20th Century men whom he calls the prophet and the wizard.  The prophet is William Vogt, who believed that the growing population of humans threatened the future of the Earth.  The wizard is Norman Borlaug, who won the Nobel Prize in 1970 for developing more productive agricultural crops, collectively called the “Green Revolution.”

The prophet believed that the resources needed to sustain life on Earth are finite and the human population was quickly reaching the point at which sources of food, energy, and water would soon be exhausted, threatening all life with extinction.  The wizard devoted his life to expanding food resources to feed the growing human population.  These viewpoints are inherently contradictory because making more food available enables more people to survive and increase human populations.  Vogt tried to cut off the sources of funding for the agricultural projects of Borlaug.

Different conservation methods:  Food

Mann applies these different viewpoints to each major resource issue to explain why the pros and cons of different approaches to conservation are debated, beginning with food production.  The Green Revolution occurred in the 1960s when subsistence crops such as wheat, corn, and rice were improved using breeding techniques.  Borlaug developed a variety of wheat that was both resistant to stem rust, its most persistent enemy, and produced more wheat for harvest.  Working in a desperately poor part of Mexico, with inadequate resources, Borlaug spent 15 years combining thousands of different varieties of wheat to find the winning combination.  His work was done prior to our knowledge of DNA and molecular analysis, so it was a process of trial and error.  It is a heart-wrenching story of brute labor in extreme conditions.  The story is important to our understanding of genetic modification because it reminds us that genetic modification is as old as agriculture itself, although it was called “breeding” until we learned what we now know about DNA.

File:Wheat yields in Least Developed Countries.svg

Mann visits some of the many modern methods of genetic engineering, such as the attempt to “revise” photosynthesis to enable plants to store more carbon, use less water, and tolerate higher temperatures.   These projects are controversial with the public, who are deeply suspicious of all genetic engineering.  In 1999, about one-quarter of Americans considered genetically modified organisms unsafe.  Sixteen years later, 57% of Americans said GMOs are dangerous.

The debate about the value or risks of GMOs is an example of the competing visions of conservation.  The prophets see risk and the wizards see opportunities.  Surely, there ARE risks, but do they outweigh opportunities?  That is the middle ground in the debate.  Mann departs from his neutral stance to take a position on GMOs.  He quotes many scientific sources in support of his opinion that there is far more opportunity than risk in genetic engineering.  My personal opinion is that GMOs are being unfairly judged because of the development of seeds that enable the indiscriminate use of pesticides.  The pesticides are damaging the environment, not the genetically modified seeds.


Update:  I sent this article to Charles Mann to thank him for his work and invite him to correct any errors I may have made.  He has offered this “tiny clarification:”

I was actually trying to do something very slightly different. The argument about GMOs is frequently posed in terms of health risks–are they safe to eat? In my view, the evidence to date is overwhelming that there is no particular reason to think that GMO crops pose more dangers to human health than crops developed by conventional breeding. At the same time, there are a host of reasons to think that the now-conventional industrial-style agriculture brought to us by the Green Revolution has problems: fertilizer runoff, soil depletion, the destruction of rural communities, etc. GMOs are often said by advocates of industrial ag to be the only way to keep this system going so that we can feed everyone in the world of 10 billion. If you already think that industrial ag is a big problem, then of course you would oppose a technology that is supposed to keep it going. That seems to me a better, more fruitful ground to argue.”  Charles C. Mann

I agree that “industrial ag is a big problem,” and I am grateful for this clarification.


Different conservation methods:  Water

The availability of adequate water is a limitation for agriculture that provides another example of competing approaches to conservation.  The wizards want dams to control available water and maximize its use for agriculture by storing water during rainy periods and using it during dry periods.  They also want desalination plants to convert salt water to fresh water.  97.5% of all water on Earth is salt water.  It is not useful for agriculture and it is not drinking water for humans.

Prophets want to tear down existing dams to make more water available for non-human inhabitants of the Earth.  They also object to desalination plants because they kill marine life, discharge pollutants, and use a lot of energy.  Water conservation is the preferred solution to water shortages according to prophets.

Hetch Hetchy canyon was dammed nearly 100 years ago. The dam is the primary source of water for the City of San Francisco and many surrounding communities. The dam generates the electricity that runs San Francisco’s transportation system without using fossil fuels. Sierra Club and other environmental organizations have sued several times to tear down the dam.   Inklein English Wikipedia photo

Different conservation methods:  Energy

Energy is required for every human enterprise:  heat, cooking, transportation, light, industrial production, etc.  Wood was the primary source of energy for thousands of years until coal began to be used in China around 3,400 B.C.  Although coal is still used, petroleum began to replace it as the primary source of fuel in the 19th century.  The supply of coal and petroleum was considered finite until recently.  Thanks to the wizards, extraction methods have been continuously developed such that the supply is now considered effectively infinite as long as increasingly more destructive methods are used, such as fracking and strip mining.

The prophets want to replace fossil fuels as the primary source of energy because of concerns about climate change and pollution.  Although they are supportive of developing renewable sources of energy, they often object to specific projects with side-effects.  They object to wind turbines because they sometimes kill birds.  They object to large solar farms because they displace wildlife.  Their preferred approach to energy is conservation.  They want us to learn to live with less energy.

The wizards focus on improving existing sources of energy with fewer impacts on the environment.  They envision a massive energy grid that can store and share the power generated by renewable sources so that energy is available to everyone at all times whether the wind blows or the sun shines.  The prophets object to such big projects.  They want energy to be produced locally and available locally.  The Sierra Club is opposed to a California Assembly bill that would create a regional power grid.

Different conservation methods:  Climate Change

All of these issues come together when climate change is debated.  Wizards are working on geo-engineering approaches to reducing greenhouse gas emissions, such as burying carbon in the ground.  Their public policy approaches to the issue are also complex and on a large scale, such as cap-and-trade systems to create a profit-motive for reducing carbon emissions. 

Prophets are unwilling to take the risks associated with geo-engineering strategies and they are skeptical that cap-and-trade will be more than a means of avoiding the sacrifices needed to reduce greenhouse gas emissions.  The Sierra Club was instrumental in preventing the State of Washington from passing a revenue-neutral cap-and-trade law.  The Sierra Club also opposed the recent renewal of California’s cap-and-trade law.  Market-based approaches to reducing greenhouse gas emissions may not be the strongest policy tools, but they are the only tools available in the US because there is not sufficient political support for stronger policies.  Only 11 states have been able to enact market-based laws, such as cap-and-trade.  Sierra Club policies are often far removed from political realities.

Unintended consequences

Charles Mann does his best to avoid choosing a side in these debates and on the whole he succeeds.  He wants readers to understand that for every conservation method there is a cost and he dutifully tells us about the horrifying consequences of rigidly following one path rather the other.

Vogt, the prophet, firmly believed that the Earth and its human inhabitants would only survive if humans would voluntarily adopt public policies that would limit the growth of human population.  This goal was not popularized until The Population Bomb was written by Paul Ehrlich and published by the Sierra Club in 1968.  Mandatory population control became the official public policy in Mexico, Bolivia, Peru, Indonesia, and especially India.  In the 1970s and 80s millions of women were sterilized in India, often against their will.  In China the one-child policy adopted in 1980 forced tens of millions of abortions, many of which killed mothers.  Birth control was forced on women in Egypt, Tunisia, Pakistan, South Korea and the Philippines.

There is constant pressure within the Sierra Club to adopt an anti-immigration policy.  The Club had such a policy until 1996 and there have been several attempts since to reinstate that policy.  I digress to express my personal opinion that immigration is not a legitimate environmental issue because the environment is global.  The migration of people from Central America to North America does not fundamentally alter the impact on the environment.  If migrants have better access to birth control and education for women in North America, the size of their families would likely decrease.

The Sierra Club, like most mainstream environmental organizations, is firmly in the camp of the prophets.  They cast humans as the enemy of nature and their policies reflect their misanthropy.  They oppose every housing development project and all recreational access to public lands in California.

The Green Revolution and the way of the wizard carries its own baggage.  The new crops and the resources needed to produce them were not equitably distributed in the places where they were needed the most.  The richest farmers and biggest land owners in both India and Mexico were the primary beneficiaries of the improved agricultural methods.  But it wasn’t just inequitable distribution that did the most damage.  The poorest farmers owned the most marginal land.  Improved crops made their land more valuable.  It was suddenly worthwhile for land owners to dispossess their tenant farmers. The poorest farmers became the poorest homeless people in the huge cities of India and Mexico.

The Green Revolution also greatly increased the use of synthetic fertilizers that have caused nitrogen and phosphorus pollution from agricultural runoff.  And pesticides were another tool of the Green Revolution with their own suite of negative environmental consequences.

Both cases illustrate the important role that governments play in environmental policy.  Neither the extreme application of population control methods nor the inequitable distribution of agricultural resources were inevitable.  In the hands of competent, democratic government both methods had the potential to improve the well-being of humans without damaging the environment.

The Middle Ground:  All of the Above

I see Mann’s book about competing conservation strategies as an endorsement of the middle ground.  My own strong commitment to the middle ground probably influences my reaction to Mann’s book.  The concept of “population control” is as unappealing to me as some of the geo-engineering projects being developed to address climate change.

“Population control” is antithetical to a free society.  The middle ground is universal and free access to birth control, early sex education, and educating women in developing countries.  Educating women is the most effective method of reducing birth rates.

2014 UN Human Development Index. Human Development Index map. Darker is higher. Countries with a higher HDI usually have a lower birth rate, known as the fertility-income paradox.

The risks of geo-engineering solutions to climate change are too great to pursue without careful scientific analysis to fully understand the risks before they are implemented on a large scale.  Likewise, I am opposed to building new nuclear power plants until and unless we have a safe method of disposing of the nuclear waste generated by those plants.

Ironically, the middle ground is in some sense, the most aggressive conservation strategy because it is ALL OF THE ABOVE.  The consequences of climate change are too dire to choose one path and abandon the other.  We must carefully go down every path available.  We must do what we can to limit the increase in human population—within the constraints of a free society—and we must aggressively pursue the technological innovations that are needed to protect the environment from the activities of humans.  We must develop new sources of energy that do not emit greenhouse gas emissions as well as reduce our use of limited resources, such as water and energy.

I conclude with an important caveat.  This article does not do justice to Mann’s brilliant book.  I have only scratched the surface of Mann’s complex and deeply informed book.  Charles Mann made a presentation to the Long Now Foundation in San Francisco shortly after the publication of his book.  A video of his presentation is available HERE.  The video will help bridge the gap between this brief summary and reading Mann’s important book.


  1. Charles C. Mann, The Wizard and The Prophet: Two Remarkable Scientists and Their Dueling Visions to Shape Tomorrow’s World, Alfred Knopf, 2018

Adapting to more wildfire in western North American forests as the climate changes

The National Academy of Sciences (NAS) has published its recommendations for a new approach to managing forests in the American West to adapt to the increasing frequency and intensity of wildfires in the changing climate.  The authors of the NAS publication regarding adaptive forest management in the changing climate are 12 academic scientists from major public universities in 8 western states. (1)

Although the National Academy of Sciences was created by an Act of Congress in 1863, during the Lincoln administration, it is a non-governmental non-profit that receives no direct government funding.  Its charge is “providing independent, objective advice to the nation on matters related to science and technology. … to provide scientific advice to the government ‘whenever called upon’ by any government department.” Members of the Academy serve without salary as “advisers to the nation.” Election to the National Academies is one of the highest honors in the scientific field. The independence of NAS is ensured by lack of governmental funding and salaries to its members.  However, 85% of NAS funding is government grants and contracts. (2)

In other words, this publication is an important policy document, prepared by distinguished scientists and published by America’s most prestigious scientific institution.  It deserves our attention and respect.

Why is a new forest management approach needed?

In the past, forest management policies have focused primarily on preventing fire, reducing fuel loads, and restoring burned areas.  Given the increasing intensity and frequency of wildfires, there is a new understanding that these approaches are no longer adequate to address new conditions created by the changed and changing climate.  The new approach recognizes that fuels reduction cannot alter regional wildfire trends and therefore must adapt ecosystems and residential communities to more frequent fires, including “planning residential development to withstand inevitable wildfire.”  This represents a shift from restoring historical conditions, now considered unsustainable, to developing fire-adapted communities.

The authors of this publication tell us that managing forest fuels has been ineffective:  “Mechanical fuels treatments on the US federal lands over the last 15 years totaled almost 7 million hectares, but the annual area burned has continued to set records.  Regionally, the area treated has little relationship to trends in the area burned, which is influenced primarily by patterns of drought and warming.”  Where fuels treatment was done, wildfires subsequently occurred:  “10% of the total number of US Forest Service forest fuels treatments completed in the 2004-2013 period in the western United States subsequently burned in the 2005-2014 period.”  This suggests that “most treatments have little influence on wildfire.” In any case, only 40% of wildfires occurred in forests since 1984, with most fires burning grasslands and shrublands.  Clearly, these projects have been a waste of time, trees, and taxpayer money.

This area on the west side of Grizzly Peak Blvd is known as Frowning Ridge. It is one of the first areas that was clear-cut by UC Berkeley over 10 years ago. Destroying the trees did not prevent the grass and shrubs from igniting in the August 2017 fire. Pictures of that area before and after the trees were destroyed are available here: https://milliontrees.me/2013/06/08/guest-article-about-fema-projects-by-a-student-of-the-forest/  The fire in August 2017 was stopped when it reached the forest on the opposite side of the road.

Nor do the authors consider “thinning” of forests a viable method of reducing fire hazards because “when thinning is combined with the expected warming, unintended consequences may ensue, whereby regeneration is compromised and forested areas convert to non-forest.”  When trees are thinned, the trees that remain are more vulnerable to wind and they lose the ability to share resources with the neighboring trees that have been removed.

Tilden Park, October 2016. East Bay Regional Park District has radically thinned this area to distances of 25 feet between remaining trees. This area is about 2 miles away from any residential structures. Cal Fire defines “defensible space” as 100 feet around structures.

There are two major reasons for increased wildfire hazards.  More than 50% of the increase in areas burned by wildfire in the American West is attributed to climate change.  The expansion of residential development into forested areas—called the Wildland-Urban-Interface (WUI)—is the second factor:  “Between 1990 and 2010, almost 2 million homes were added in the 11 states of the western United States, increasing the WUI by 24%.”  35% of wildfires in the WUI since 2000 were in California, more than any other state.

What is the new management goal?

Whereas past policies were designed to maintain forest conditions to historical conditions, this is no longer considered a realistic goal.  The recommended goal is now “supporting species compositions and fuel structure that are better adapted to a warming, drying climate with more wildfire.”  Sounds like planting tree species that are adapted to new climate conditions, doesn’t it?

The other, equally important new goal is to reduce the vulnerability of communities to wildfire by “changing building codes to make structures more fire-resistant…and providing incentives, education, and resources to reduce vulnerability to future wildfire.”  The only tree removals that make sense to the authors are those immediately around residential communities, “strategically located to protect homes and the surrounding vegetation.”  That is the principle of creating “defensible space” immediately around structures:  “fuels management for home and community protection will be most effective closest to homes…where ignition probabilities are likely to be high.”

Source: Cal Fire

These strategies are called “transformative resilience,” which “refers to planned fundamental change in response to drastically altered disturbances that have the potential to create broad-scale, systemic shifts in ecological states or radical shifts in values, beliefs, social behavior, and multilevel governance.”  The authors of these policy recommendations acknowledge that such rapid and radical shifts in social and ecological transformation are rare and difficult to achieve.  We certainly agree with that observation.

The urgently needed paradigm shift

Public policy and conventional wisdom is wedded to the past.  The public is unable or unwilling to acknowledge the realities of climate change.  They remain committed to “restoring” the landscape to an imagined pre-settlement ideal in the distant past.  And public land managers remain committed to creating that fantasy landscape, by destroying existing landscapes and using herbicides to do so.  They destroy the trees of the future and plant the trees of the past.  And they destroy trees miles from any residential properties while property owners resist the creation of defensible space needed to protect their homes.

The authors of the NAS publication clearly state the risks of continuing down that path:  “[Such policies] may be the easiest, most familiar path with the least uncertainty, but this approach is short-sighted and could come at the cost of adaptation to future wildfire as climate change continues.”

They also urge the public to wake up to this new reality:  “Some ecosystems will survive and thrive as they adapt to novel future conditions, but not all.  Embracing rather than resisting ecological change will require a significant paradigm shift by individuals, communities, and institutions and will challenge our conservation philosophies.”

Our safety and the future of our land are at stake.  We must take our heads out of the sand and look forward instead of back to a past that is long gone and will not return.  Since climate change is causing more wildfires, destroying more trees than necessary to achieve fire safety is counterproductive because deforestation is the source of about 10% of carbon emissions contributing to climate change.


(1) Tania Schoennagel, et. al., “Adapt to more wildfire in western North American forests as climate changes,” Proceedings of National Academy of Sciences, May 2017

(2) Wikipedia https://en.wikipedia.org/wiki/National_Academy_of_Sciences

Endangered Species Law is under fire

Like most of our federal laws and regulations intended to protect the environment, the Endangered Species Act is under fire because the political party now in power is opposed to government regulations that impose any perceived limitations on economic activity.  There are a number of laws grinding their way through the legislative process that would revise, if not gut the ESA.*

I have mixed feelings about the threats to weaken the ESA because there is widespread agreement that the law could be improved.  When it was created, over 40 years ago, it was based on the scientific knowledge available at the time.  For example, recently available molecular analysis has greatly improved our ability to accurately identify species.

Climate change was but a glimmer on the distant horizon 40 years ago.  Now most people understand that climate change will cause many extinctions that the ESA is powerless to prevent.  Emaciated polar bears standing on small islands of ice are the poster children for the impact of climate change on rare animals.

The political threats to the ESA have focused the attention of the media on specific examples of endangered species and the efforts to prevent their extinction.  Each one illustrates a different issue with the existing law.

Attempts to solve one problem cause other problems

Greater sage grouse

The Greater sage grouse is a critically endangered bird (although not officially designated as such) that requires sagebrush for its home.  In an effort to expand habitat for the grouse, land managers destroyed native junipers that were spreading into grouse habitat.  A few years later they determined that destroying the trees did not produce the desired habitat.  Instead, non-native annual grasses have colonized the bare ground and many sapling junipers are growing from the seed bank left by the trees that were destroyed. (1)

Instead of calling the tree destruction a failed experiment, the scientists now propose to escalate the eradication effort.  They now plan to use herbicides and prescribed burns to eradicate the non-native annual grasses.  Given the persistence of herbicides in the soil, more sagebrush may not be the ultimate outcome.  And the sage grouse are unlikely to benefit from either poisoned vegetation or fires in their habitat.

Some extinctions are the unintended consequence of misguided “conservation” efforts

When European rabbits were intentionally imported to Australia, predictably the population quickly exploded.  A virus was then intentionally imported to kill the rabbits.  Like many biocontrols, the virus spread into the native range of the rabbits about 20 years ago, including into Spain.

Iberian lynx. Creative Commons

The Iberian lynx is very rare partly because it is a picky eater.  Curiously, rabbits are the strongly preferred prey of the Iberian lynx.  There were enough rabbits available for the lynx until the rabbits were wiped out by the virus that was unintentionally imported to Spain.  The population of Iberian lynx plummeted to only 100 known individuals.  That’s when the EU version of the ESA kicked into action.

The Iberian lynx is now bred in captivity, a complex and challenging process likened to “having a nursery for rich kids in which you have a teacher for each kid.”  Needless to say that is an expensive proposition.  Releasing the lynx back into the wild required that 50,000 rabbits (costing $12.30 each) be simultaneously released into lynx territory.  The project cost $42 million over a period of 7 years.  (2)

The Spanish environmental official responsible for the project was visibly irritated when asked about the cost of the program.  He said “some ‘ignorant’ pundits were drawing unflattering comparisons between how much was being spent on the lynx compared to funding allocated to offset social issues such as unemployment.”  The strongest defenses of extreme efforts to save rare species are made by those who earn their living on them. (2)

Growing number of “conservation reliant” species

An article in the New York Times magazine recently asked this rhetorical question, “Should some species be allowed to die out?”  (3) The article focused on Hawaii because it is a place where heroic efforts have been made to save endangered species.  Nearly 50% of 1,280 federal endangered species are in Hawaii.  Over 80% of all endangered species are considered “conservation reliant,” a term used to describe the plants and animals that are permanently on life support.  They will not survive if not permanently tended by humans in hothouses and animal shelters.

Hawaii has the most endangered species because they evolved in isolation in a distant place with no interaction with the outside world until about 700 years ago.  That isolation cannot be recreated without stopping all trade and travel to and from Hawaii.  That is clearly not going to happen.  If the underlying conditions that cause extinctions cannot be reversed, no amount of human effort is likely to prevent the extinction.

Although I consider most of these efforts futile, that is not the conventional wisdom.  There are over 300 comments on the article in the NY Times that are overwhelmingly supportive of the ESA and the heroic efforts to save rare species.

Confiscation of private land

Dusky gopher frog

The ESA enables the government to designate both public and private land as “critical habitat” for endangered animals.  The US Supreme Court has agreed to hear a case about the application of the Endangered Species Act that enabled the federal government to designate 1,600 acres of private land as critical habitat for an endangered frog. That designation will prevent the land owner from developing the land or using it for a different purpose other than providing POTENTIAL habitat for a frog that has not been seen in that part of the country since 1965.  US Fish & Wildlife also concedes that the frog cannot live on the land in its present condition and requires modification to accommodate the needs of this frog.  (4)

Needless to say, private land owners aren’t enthusiastic about the loss of the use of their land for purposes other than supporting a specific rare animal.

Assisted migration?

Torreya taxifolia near Cincinnati, Ohio

Torreya taxifolia, commonly known as Florida nutmeg, was classified as endangered in 1984.  It was attacked by a fungal blight about 70 years ago that has decimated its population in its small native range on the Florida panhandle.  It is an example of one of the major obstacles to keeping rare plants alive because it is very difficult to propagate:

Unlike most plants, the tree has so-called recalcitrant seeds, which cannot be preserved in conventional seed banks because they can’t survive drying. This necessitated the development of a tissue-culture system for the species called somatic embryogenesis. Embryos are surgically removed from fully developed seeds, then cultured in vitro to encourage the formation of multiple embryos. These can be safely preserved in a new cryogenic storage unit obtained by Atlanta Botanical Garden, in which the resulting plantlets are coaxed into a state of suspended animation at -321° Fahrenheit in liquid nitrogen.” (5)

This labor-intensive method of germinating the seeds of Torreya taxifolia has enabled scientists to grow Torreya in several botanical gardens in places distant from its native range.  Tree activists want to introduce the tree to wildlands in distant locations where the fungal pathogen that is killing the tree in its native range doesn’t exist.  This is called “assisted migration,” a controversial strategy that is prohibited by the ESA.  Moving endangered plants and animals requires the approval of the US Fish and Wildlife Service, permission they have so far denied for Torreya.

The ESA defines the criteria for recovery and removal of endangered status.  The plant must be living on its own “in the wild” and must successfully reproduce naturally for at least two generations.  Given the circumstances of this rare tree and many other “conservation reliant” species, it seems they are permanently doomed to be permanently legally protected endangered species.

The ESA’s reluctance to enable the movement of species from their native ranges is inconsistent with the realities of climate change.  When the climate changes, the vegetation changes.  To prevent that from happening is to doom the vegetation and the animals that require the vegetation to extinction.  The ESA has become an obstacle to survival, rather than a tool to ensure survival.

Improving the Endangered Species Act?

In summary, the Endangered Species Act can be improved to achieve its original purpose as a means of preventing extinctions of plants and animals, as illustrated by the examples listed above:

  • Actions intended to help a rare species should not inflict further damage on the environment, such as biocontrols, pesticides, and killing other animals considered competitors.
  • Plant and animal species that require permanent human intervention to survive should be removed from life support after decades of such intensive care. Humans often make that choice for themselves at the end of life and it is widely considered a humane choiceTriage is an ethical strategy in the medical profession and it should be in conservation as well.
  • Private property rights should be respected by the Endangered Species Act. The political cost of such confiscations are too high a price to pay for the meager benefits to the species in question.
  • If the underlying cause of an extinction is a fundamental change in the environment that cannot or will not be changed, it is pointless to aim conservation efforts at symptoms of the change, rather than causes of the change. For example, if melting Arctic ice opens a corridor between the Atlantic and Pacific oceans, it is pointless to try to prevent the movement of sea life between those oceans.
  • Plants and animals that can no longer survive in their native ranges because of changes in conditions, should be carefully considered for introduction to places with suitable conditions.

This wish list has nothing to do with the legislative effort to weaken the ESA.  That political effort is in the service of economic interests, such as fossil fuel exploitation and mining, and is not intended to benefit the rare plants and animals presently protected by the law. 


* “But under the Trump administration, at least 63 separate legislative efforts to weaken the [ESA] act have been undertaken since January 2017, according to the Centre for Biological Diversity.”  New York Times, April 22, 2018.

  1. http://www.argusobserver.com/news/tree-removal-could-spread-invasive-grasses/article_88eba0da-2a5b-11e8-862a-6734dbe7a90a.html
  2. https://www.nytimes.com/2018/03/31/world/europe/iberian-lynx-spain-portugal.htmlhttps://www.nytimes.com/2018/03/31/world/europe/iberian-lynx-spain-portugal.html
  3. https://www.nytimes.com/2018/03/13/magazine/should-some-species-be-allowed-to-die-out.html?hpw&rref=magazine&action=click&pgtype=Homepage&module=well-region&region=bottom-well&WT.nav=bottom-well
  4. https://www.cnn.com/2018/01/22/politics/dusky-gopher-frog/index.html
  5. https://e360.yale.edu/features/for-endangered-florida-tree-how-far-to-go-to-save-a-species-torreya

 

Action Opportunity: Draft of Oakland’s Vegetation Management Plan

The City of Oakland applied for a FEMA pre-disaster mitigation grant in 2005 to clear-cut all non-native trees on 122 acres of city owned property in the East Bay hills, based on the claim that it would reduce fire hazards.  FEMA cancelled that grant in September 2016 in settlement of a lawsuit against the project. 

The City of Oakland began the process of writing a new plan to reduce fire hazards in the hills by hiring a consultant to develop a Vegetation Management Plan in November 2016.  The new plan will be much more comprehensive than the original plan, covering 1,925 acres of open space and 308 miles of roadside in Oakland.  Oakland also made a commitment to an open public process to develop the plan.  A survey of public opinion was conducted and two public meetings were held in 2017. 

A draft of Oakland’s Vegetation Management Plan is now available HERE.  There are detailed maps of the areas that will be covered by the plan.  We suggest you take a look at those maps to determine what effect the plan will have on your neighborhood and the parks and open spaces you visit.

 A public meeting about the draft was held on May 23, 2018 and written public comments will be accepted until June 11, 2018. Comments may be submitted in the following ways: Download comment card; Email VMPcomments@oaklandvegmanagement.org; Mail:  266 Grand Avenue, Suite 210, Attn: Ken Schwarz, Oakland, CA 94610.  We hope you will participate in this public process that will determine the future of much of the landscape in the Oakland hills.

We are publishing an excerpt of the written public comment of one of our readers, which we hope will help you understand the issues and to write a comment of your own.  Asterisks indicate where some detail has been omitted.  You can see the entire public comment HERE: Oakland Draft Vegetation Management Plan – public comment

 Million Trees


Ken Schwarz
Horizon Water & Environment
266 Grand Avenue, Suite 210
Oakland, CA 94610

I am broadly supportive of the Draft Vegetation Management Plan (DVMP) because:

  • It will create defensible space around structures in Very High Wildfire Hazard Severity Zones.
  • It will clear easily ignited vegetation on roadsides in places where fire hazards are greatest.
  • It sets priorities for implementation in places where fire hazards are greatest.

These three elements of the plan will reduce fire hazards while limiting destruction of trees and vegetation and being fiscally responsible.

My public comment will identify some weaknesses in the plan and make specific suggestions for improving the plan with the goal of minimizing fire hazards as well as collateral damage to the environment.

The 300-foot “buffer” zone is unnecessarily destructive.  California law requires 100-feet of defensible space around structures.  The DVMP proposes extending defensible space along roadsides and around structures to 300-feet, the length of a football field.  Such a wide clearance of vegetation greatly exceeds California fire code and is therefore unnecessarily destructive.  In a recently published op-ed in the Los Angeles Times, two academic scientists confirm our understanding of how to keep our communities safe:  “The science is clear that the most effective way to protect homes from wildfire is to make homes themselves more fire-safe, using fire-resistant roofing and siding, installing ember-proof vents and exterior sprinklers, and maintaining “defensible space” within 60 to 100 feet of individual homes by reducing grasses, shrubs and small trees immediately adjacent to houses. Vegetation management beyond 100 feet from homes provides no additional protection.”[1]

The buffer zone should be eliminated, reduced in size, or reduced to Priority 3 so that it is less destructive and costly. 

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

The description of herbicide use in the draft is unnecessarily vague, because it provides no information about what herbicides will be used and the health and environmental hazards of specific herbicides.  Nor does it explain how, where, or why herbicides will be used.

Instead of providing that information, the plan describes the public’s opposition to herbicides as “social stigma,” which implies that our opposition is a baseless prejudice against herbicides.  In fact, our opposition is based on scientific information about the dangers of herbicides and those dangers must be acknowledged by the final version of this plan.

The dangers of herbicides are well documented and well known. ****** Here is a brief list of some of the most recent studies that conclude that glyphosate products are very dangerous to the health of animals and humans:

  • The International Agency for Research on Cancer classified glyphosate as a “probable human carcinogen” in 2015. The IARC is composed of an international team of scientists convened by the World Health Organization of the United Nations.
  • The State of California responded to that news by requiring all glyphosate products sold in the State to be labeled as carcinogens. The State was sued several times by the manufacturer of Round Up—Monsanto–to prevent the labeling requirement.  The State of California recently won in the state court of appeals[2].  Unless Monsanto appeals and wins in the State Supreme Court, all glyphosate products will be labeled as carcinogens in California.
  • US National Toxicology Program recently conducted tests on formulated glyphosate products for the first time. In the past, tests were conducted only on the active ingredient…that is glyphosate alone. The formulated products that are actually applied as weed killers contain many other chemicals, some of which are not even known. The head of the National Toxicology Program Laboratory, told The Guardian newspaper the agency’s work is ongoing but its early findings are clear on one key point. “We see the formulations are much more toxic. The formulations were killing the cells. The glyphosate really didn’t do it,” DeVito said. A summary of the NTP analysis said that “glyphosate formulations decreased human cell ‘viability’, disrupting cell membranes. Cell viability was ‘significantly altered’ by the formulations, it stated.”[3]
  • The Global Glyphosate Study is being conducted by six scientific institutions all over the world. ******* This international consortium of scientific institutions recently published preliminary resultsof their study: “The results of the short-term pilot study showed that glyphosate-based herbicides (GBHs) were able to alter certain important biological parameters in rats, mainly relating to sexual development, genotoxicity and the alteration of the intestinal microbiome, at the ‘safe’ level of 1.75 mg/kg/day set by the U.S. Environmental Protection Agency (EPA).”[4]  In other words, at doses deemed safe by the US EPA, significant negative health effects were found in animals used in testing.
  • The German Agriculture Minister announced on April 17, 2018 that she was finalizing a draft regulation to end use of the weed-killer glyphosate in household gardens, parks and sports facilities, and to set “massive” limits for its use in agriculture.[5] Germany is one of 25 countries that have issued outright bans on glyphosate, imposed restrictions or have issued statements of intention to ban or restrict glyphosate-based herbicides, including Roundup  Countless US states and cities have also adopted such restrictions. [6]
  • Marin Municipal Water District quit using all pesticides in 2015. In a letter to East Bay Municipal Utilities District, a member of the Board of MMWD explains why that decision was made.  (Attachment 2)  MMWD hired scientists at UC Davis to conduct a study of the biological persistence of glyphosate.  They found that glyphosate persisted for at least 84 days when applied to foliage, and perhaps longer after the study ended.

Garlon with the active ingredient triclopyr is more toxic than glyphosate.  Garlon is the herbicide that is used to prevent eucalyptus and acacia from resprouting when the trees are destroyed.  Its use was also specifically allowed for that purpose by Oakland City Council Resolution 79133.   Although the DVMP does not mention its use, we assume—unless specifically told otherwise by the final version of the VMP—that Garlon will be used to control resprouts.

  • Triclopyr is an organochlorine product, in the same family of pesticides as DDT, which was banned in the US in 1972. Organochlorine products bioaccumulate and are very persistent in the environment.  Nearly 50 years after it was banned, DDT is often found in the ground, in the water, and in people’s bodies.[7]
  • Organochlorine products are endocrine disrupters. The Pesticide Research Institute did a risk assessment of triclopyr for the California Invasive Plant Council.  They reported that triclopyr “poses reproductive and developmental risks to female applicators.” [8]
  • The Pesticide Research Institute did a risk assessment of triclopyr for Marin Municipal Water District in which they informed MMWD that birds and bees are both harmed by triclopyr and mycorrhizal fungi in the soil are damaged by triclopyr.[9]

More research has been done on Round Up than on Garlon because it is more widely used.  It is more widely used, partly because it is actually less dangerous than Garlon (it is also a non-selective plant-killer).  Because of the toxicity of Garlon, several public land managers in the Bay Area have made a commitment to controlling resprouts without using herbicides: ******** Marin Municipal Water District,  Marin County Parks and Open Space, UC San Francisco, and East Bay Municipal Utilities District (the supplier of our drinking water).

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

There is no evidence that eucalyptus is inherently more flammable than native trees. ******** Eradicating non-native trees and shrubs will not reduce fire hazards because they are not inherently more flammable than the native vegetation that will remain.  Therefore, the reduction of fuel loads must be based on flammability, NOT the nativity of the flammable species.  The nativity of plant species is irrelevant to reducing fire hazards and must be abandoned as criterion for destroying plants and trees.

Vegetation that burned in the North Bay fires of October 2017 was almost exclusively native. Source: Bay Area Open Space Council

I support the thinning of eucalyptus, acacia, Monterey pine and cypress to reduce fuel loads, as long as the canopy is intact.  ******** When the canopy is intact, the forest floor is shaded which retains moisture that retards ignition and suppresses the growth of easily ignited weeds. The DVMP proposes to thin the targeted non-native trees to distances of 35 feet, creating gaps in the canopy of 10 feet within the 300-foot “buffer zone.”  The distance between the trees must be reduced to 25 feet to maintain the canopy.  In addition to reducing fire hazards, maintaining the canopy will also be less destructive and will reduce the amount of stored carbon released into the atmosphere.

Tilden Park, October 2016. East Bay Regional Park District has thinned this area to distances of 25 feet between remaining trees. The forest floor is still shaded because the canopy is intact.

My greatest disappointment in the DVMP is its proposal to remove all individual non-native trees where they presently exist in native vegetation outside the “buffer zone.” ******** Removing non-native trees in riparian areas and in redwood groves as proposed by the DVMP is not fire hazard mitigation because fire hazards in those areas are minimal.

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

Furthermore, destroying healthy trees damages the trees that remain because the herbicide that is used to prevent eucalyptus and acacia from resprouting is mobile in the soil and it is known to damage mycorrhizal fungi in the soil that is essential to the health of the native trees.  ******* It is not possible to destroy isolated trees without damaging neighboring trees in close proximity. ****** Studies show that eucalyptus trees in native forests are not doing any damage to neighboring trees. ********

If individual non-native trees within native vegetation are not doing any environmental damage and do not increase risk of fire they should not be destroyed because destroying them WILL damage native vegetation.  Please leave them alone!

 Putting the DVMP into the long-term big picture

Finally, I suggest that we all take a step back from the details of the DVMP and consider the proposal in the context of the entire environment.  The final VMP must minimize damage to the environment while mitigating fire hazards because:

  • The climate has changed and it will continue to change. When the climate changes, the vegetation changes.  That is one of the axioms of ecology and it will continue to be.  If non-native plants and trees are better adapted to the current and anticipated climate, we should abandon futile attempts to force plants to live where we want them to live.
  • If we want trees in California, we must look to the future, not the past. 130 million native conifers have died in California since 2010. 5-10 million oaks in California have been killed by Sudden Oak Death. The future of redwoods in California is in jeopardy because they require a lot of water and they don’t tolerate wind.

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

A climate change specialist at the US Forest Service tells us in a recent study that native tree species are the most vulnerable to climate change. USFS found that native trees are more vulnerable to the changes in temperature, precipitation, growing season, and other effects of accumulating greenhouse gases. The assessment found that 88 percent of invasive tree species are expected to prove resilient in the changing climate, ranked with low vulnerability, compared to 20 percent of natives.[10]

  • We are contributing to climate change by destroying healthy trees that are storing tons of carbon that will be released into the atmosphere as the destroyed trees decay. The primary reason why wildfires are more frequent and more intense is because of the warmer, drier climate.  Therefore destroying more trees than necessary increases fire hazards because we are exacerbating climate change by destroying more trees than necessary.
  • It is a fiction that destroying trees will release less carbon than the wildfires imagined by those who demand their destruction. According to a recently completed study at Oregon State University, “wildfire is not the biggest source of climate-warming carbon dioxide in Oregon forests—logging and wood products are.”[11]

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

The trees that will be destroyed in Oakland will not be used as lumber, which means they will contribute even more carbon to the atmosphere.  Timber that is used for building retains its stored carbon until the building deteriorates or is destroyed.

  • The herbicides that are used to destroy vegetation and prevent trees from resprouting damage the soil and pose serious health risks to animals and humans. The more vegetation and trees the VMP destroys, the greater the damage caused by herbicides.  Therefore, we must minimize the amount of vegetation that is destroyed as much as possible if herbicides are used.

We achieve nothing if the damage we do to the environment and to ourselves is greater than real or imagined reduction in fire hazards.

Thank you for your consideration.

Resident of
Oakland, California
June 2018


[1] http://www.latimes.com/opinion/op-ed/la-oe-hanson-miller-governor-fire-orders-20180525-story.html

[2] https://www.sfgate.com/news/article/State-can-label-widely-used-herbicide-as-possible-12849147.php

[3] https://www.theguardian.com/us-news/2018/may/08/weedkiller-tests-monsanto-health-dangers-active-ingredient

[4]https://sustainablepulse.com/2018/05/22/monsanto-in-epic-fail-with-attempted-attack-on-global-glyphosate-study/?utm_source=newsletter&utm_medium=email&utm_campaign=gmos_and_pesticides_global_breaking_news&utm_term=2018-05-23#.WwhUfkgvyUl

[5] https://sustainablepulse.com/2018/04/17/germany-moving-ahead-with-plans-to-restrict-weed-killer-glyphosate/?utm_source=newsletter&utm_medium=email&utm_campaign=gmos_and_pesticides_global_breaking_news&utm_term=2018-04-18#.WwhWWUgvyUl

[6] https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-roundup-lawsuit/where-is-glyphosate-banned/

[7] https://www.sciencealert.com/ddt-consistently-found-in-humans-study

[8] https://www.pesticideresearch.com/site/pri-resource-centers/weed-management-resource-center/herbicide-risk-comparisons/workers/

[9]http://www.marinwater.org/DocumentCenter/View/254/HRA_Chap4_Triclopyr_1_1_2010

[10] https://www.forbes.com/sites/jeffmcmahon/2018/04/15/hug-your-native-trees-goodbye-thanks-to-climate-change/#4ad4a4176abd

[11] https://www.hcn.org/articles/climate-change-timber-is-oregons-biggest-carbon-polluter