Category: Ecology

The Endangered Species Act: Static law meets dynamic nature

Once passed, laws rarely change and when they do it takes an arduous effort that tests a rigid political and judicial system.  Nature, on the other hand, is inherently dynamic and we are usually powerless to stop it from changing even when we try.  So, when a law is designed to control nature, we can expect some conflict between static law and dynamic nature.  Forty years after the Endangered Species Act was passed, that conflict is becoming progressively more apparent and problematic.

San Franciscans recently had an opportunity to comment on the designation of 270 acres of city parkland as critical habitat for the endangered Franciscan manzanita which illustrated some of these conflicts.  This rare plant requires full sun, which predicts that all trees will be destroyed in those acres, as they were for the closely related, endangered Raven’s manzanita.  The seeds of both of these plants germinate only after fires, which may mean that prescribed burns will be required for the long-term survival of the plants.  Restrictions on recreational access are also likely.

Are these sacrifices worth making?  Are the prospects of the long-term survival of these rare plants good enough to justify these sacrifices?  That’s for you to judge.

The Antioch Dunes

Lange's metalmark butterfly, USFWS photo
Lange’s metalmark butterfly, USFWS photo

Let’s consider those questions within the context of the Antioch Dunes, a National Wildlife Refuge northeast of San Francisco which is the home of three endangered species, including Lange’s metalmark butterfly.   Antioch Dunes was designated as a national wildlife refuge in 1980, four years after the metalmark was given endangered status.

It is 55 acres along the southern shore of the San Joaquin River east of the city of Antioch.  Historically it was a system of enormous sand dunes that was an accumulation of glacial sands washed down from the Sierras over millennia.  Some of the dunes were as high as 120 feet.  Because it was a unique habitat, surrounded by different vegetation, it was home to many endemic species that existed only there.  As the dunes were diminished by decades of mining for building materials, those endemic species became progressively more rare.  The remaining dunes were fragmented into two segments separated by a gypsum plant that spews gypsum dust onto the plants.  This is just one of many factors that have decimated the population of plants and insects.

Lange's metalmark caterpillar on naked-stemmed buckwheat. USFWS photo.
Lange’s metalmark caterpillar on naked-stemmed buckwheat. USFWS photo.

Historically, the dunes were unstabilized sand, known as “transporting dunes.”  The sand shifts in the wind, which some plants are specifically adapted to.  The host plant of Lange’s metalmark, naked-stemmed buckwheat, is such a plant that requires the shifting sands for its long-term survival.  The buckwheat is the only plant the metalmark will lay its eggs on.

The “creative destruction” of the shifting sands also helps to control the non-native weeds that compete with the native plants.

When Lange’s metalmark and two rare plants (Antioch Dunes evening primrose and Contra Costa wallflower) were given endangered status in 1976, the owners of the property assumed that the federal government would soon purchase the land for their long-term protection.  They sold most of the remaining sand in preparation for that sale.  The short-term consequence of endangered status was not positive because the sand dunes were further depleted by the rush to profit before the sale of the land to the federal government as a wildlife refuge.

Efforts to recover the population of Lange’s metalmark butterfly

Antioch Dunes evening primrose. USFWS photo.
Antioch Dunes evening primrose. USFWS photo.

Managers of Antioch Dunes have trucked in tons of sand to restore the dunes.  They have aggressively managed the non-native weeds that compete with the host plant of the butterfly and other rare plants.  They use herbicides and prescribed burns in addition to hand-pulling the weeds.  They have planted thousands of the rare plants in an attempt to restore the population. 

In 1986, they closed the dunes to the public—except for a monthly guided tour—after the dunes were trampled by thousands of people trying to catch a glimpse of Humphrey, the whale that lost his way into the delta and had to be coaxed back out to sea by playing recordings of whale vocalizations.

After a one-day peak count of 2,342 butterflies in 1999, the population plummeted to only 45 in another one-day count in 2006.  Clearly something drastic had to be done to turn the decline around.  A captive breeding program began the following year.  A biologist at Moorpark Community College in Southern California captured a few ovulating females and carried them home to Moorpark to lay their eggs.  The story of how the butterflies and their offspring were tended by students at the college is mindboggling:

“Each [of the 27 newly-hatched butterflies] had to be fed two or three times a day, by hand, with a Q-tip soaked in honeywater—an aggravating job that wound up taking all morning.  In the afternoon, the [new generation of butterflies brought from the dunes] were transferred onto potted buckwheat plants so they could keep laying eggs.  (Students assemble homemade enclosures for each butterfly by shoving the buckwheat through the bottom of an upside-down quart-sized clear plastic deli container…ventilating it, and sealing it off from pests with duct tape and toilet paper.)  The other butterflies, meanwhile, spent their afternoon split into groups of four or five.  The hope is that these adults will pair off and breed, and students sign up for one-hour ‘mating watch’ shifts to keep them under observation…The students also have to move the containers frequently from place to place, in and out of shade, to keep the butterflies inside from getting too hot or too cold, and to try to catch a certain mysterious quality of dappled sunlight that appears to put the insects in the mood. “ (1)

This labor-intensive, tedious exercise has been done annually since 2007.  In 2008, the enterprise was able to reintroduce 30 butterflies to Antioch Dunes.  In 2012, the total annual count of butterflies at Antioch Dunes was 32, up from 28 the previous year.  Not much to show for the effort of the Moorpark students and faculty.

What are the prospects for survival of Lange’s metalmark butterfly?

As you might expect, the answer to that question varies depending on who you ask.  Two of the oldest, most experienced butterfly experts—Jerry Powell (Emeritus Professor, UC Berkeley) and Rudi Mattoni—say it’s hopeless.  They find the continuing effort laughable.

Powell has been studying the Antioch Dunes for decades.  He sees the selection of Lange’s metalmark as the sole insect species on which to lavish attention and support, extremely stupid.  All the insect populations on the Antioch Dunes have been decimated by encroaching civilization.  All the plants and animals at the Dunes form a complex ecosystem that can’t be separated into a few species that can be saved in isolation from their community.  Powell was interviewed by the author of Wild Ones:  “He told me that any work to recover the Lange’s is decades beyond the point of diminishing returns, and even if it were possible, the agency’s strategies were, in his opinion, completely misguided.”

Mattoni spent decades trying to save several species of rare butterflies in Southern California from extinction.  At the age of 76, he abruptly threw up his hands and moved to Argentina.  The author of Wild Ones interviewed him via Skype:  “’There’s a clause right near the top [of the Endangered Species Act] that nobody remembers,‘ he said, ‘And it’s the whole soul of the Endangered Species Act.’  It begins, ‘The purposes of this Act are to provide a means whereby the ecosystems upon which endangered and threatened species depend may be conserved.’”  Then Mattoni explained why he walked away from a long career of trying to save rare butterflies, “The butterflies were just a means to preserve wild places, but all the attention got lavished on the butterflies themselves…Once the habitat is gone, it’s gone,” Mattoni said.  ‘It’s too complex—you can’t put these things back.’”

So, where does the author of Wild Ones find a more optimistic viewpoint for the survival of the metalmark or least ideas about what to do to save it?  He interviews Brent Plater, former lawyer for Center for Biological Diversity, now owner of his own legal-suit machine, Wild Equity Institute.  Plater tells him that he is preparing to sue to prevent the opening of gas-fired energy plants near Antioch Dunes.  The plants will be less polluting than petroleum fuel plants, but Plater isn’t a “better-is-best” kinda guy.  He doesn’t want ANY energy producing plants near the Antioch Dunes because they increase nitrogen levels in the air and nitrogen encourages the growth of non-native weeds that compete with the rare native plants.  The Wild Equity website announces that suit was filed on July 24, 2013, against EPA for approving permits to the builders of the new energy plants.

The Shifting Baselines Syndrome

What distinguishes the optimists from the pessimists in this debate?  Age is one difference.  Wild Ones tells us about the “shifting baselines syndrome” which explains why the old scientists are less likely to be optimistic than the young lawyer.  We form our opinion of what is “normal” in nature when we are young.

When Professor Powell and Mr. Mattoni were young the Antioch Dunes were teeming with insects, the sand dunes were nearly intact, and the native plants were still thriving.  Compared to that baseline, the Antioch Dunes are totally trashed and the prospect of returning them to their previous glory seems preposterous to them.

Mr. Plater’s view of what is normal for the Antioch Dunes is a small population of butterflies, native plants overrun by non-native plants, and sand that was trucked in and bulldozed into dunes. It’s not difficult to improve on that landscape.  Reducing nitrogen levels in the air seems a suitable improvement.

Furthermore, Powell and Mattoni are no longer earning their living trying to save rare butterflies, while Mr. Plater’s suit will fill the coffers of his non-profit institute if he wins or even if he just tries.  He and his colleagues were recently awarded $386,000 for their legal “expenses” for their suit on behalf of two endangered species at Sharp Park near San Francisco despite the fact that they didn’t win that suit.  When one earns one’s living trying to save rare butterflies, surely one believes it is a worthwhile effort.

What is worth doing?

The author of Wild Ones doesn’t offer a particular answer to this question, but he does point in a direction.  He visits two neighboring populations of metalmark butterflies.  One population in Mendota, about 120 miles away from the Antioch Dunes, looks identical to the Lange’s metalmark, in his opinion.  But DNA tests say it’s not identical to the Lange’s metalmark.  The metalmark population near Mt. Diablo, just ten miles away, looks less like the Lange’s metalmark, but its DNA is very similar, just .5% (one-half percent) difference in their DNA.

The proximity of these sub-species of metalmarks illustrates one of the issues with the Endangered Species Act.  DNA analysis, which was not readily available when the Endangered Species was passed, is making it possible to split species into more and more sub-species.  The smaller the populations of sub-species, the more likely they are to dwindle as the climate changes and habitat disappears.  The Endangered Species Act would be a less blunt instrument if it applied to species, rather than to small, isolated populations of sub-species.

The author of Wild Ones tells us about a breeding program for a butterfly in which markedly different physical characteristics were achieved in just seven generations.  He wonders if by selective breeding of the butterfly that is very closely related genetically to Lange’s metalmark, we would have a butterfly that not only looked identical but would be nearly identical genetically.  Echoes of Frankenstein come to mind.  Is it a freak show or is it a way to resurrect the Lange’s metalmark with a lot less fuss?  Again, we leave that to you.

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Jon Mooallem, Wild Ones, Penquin Press, New York, 2013

“The Eucalyptus is Part of California”

Monarch butterflies over-winter in California's eucalyptus groves
Monarch butterflies over-winter in California’s eucalyptus groves

The East Bay Express has published an op-ed in defense of the much maligned eucalyptus.  “The Eucalyptus is Part of California” is by Gregory Davis, a Berkeley resident.  We summarize the main points for our readers:

  • University of California, Berkeley’s plan to destroy all non-native trees—primarily eucalyptus, Monterey pine, and acacia—is characterized as a “meat-axe approach.” 
  • Applying herbicides repeatedly to prevent regrowth of non-natives is “tantamount to opening a can of worms.”  We don’t know the consequences of dousing our public land with toxic chemicals, just as we didn’t know that using Agent Orange during the War in Vietnam would permanently damage that country and its citizens.
  • The moderate approach advocated by the Hills Conservation Network is more reasonable.  Thinning and selective removal will do less damage.
  • Flammability of eucalyptus groves has been greatly exaggerated. 
  • Eucalyptus has lived in California longer than most of us have been alive.  They are more native than we are.
  • The loss of the “beauty and majesty” of eucalyptus in the hills will make hiking in the East Bay hills a less pleasant experience.  “Anyone who has hiked up the trail under the green canopy of these tall, stately, plumed-top, evergreen trees knows how precious they are.”

Thank you, Mr. Davis, for writing this article and to the East Bay Express for publishing it.  Critics of the native plant movement are learning that they must speak up if we are to save our trees.  The projects that destroy our trees finally became so big and so visible, that more people are aware of them and are more willing to defend our trees.

Eucalyptus Forest
Eucalyptus Forest

Public comment for Franciscan manzanita reopened to July 29, 2013

Update:  US Fish & Wildlife published the final rule designating critical habitat for Franciscan manzanita on December 20, 2013.  230.2 acres of land in San Francisco have been designated as critical habitat:  46.6 acres of federal land, 172.8 acres of parks owned by San Francisco’s Recreation and Parks Department, and 10.8 acres of private land.  The complete document is available here.  The document responds to public comments and explains any differences between the proposed designation and the final rule.  It makes interesting reading. 

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We have just learned—belatedly—that US Fish & Wildlife has reopened the public comment period for the designation of critical habitat for the endangered Franciscan manzanita in San Francisco’s public parks.  The new public comment deadline is July 29, 2013.  The announcement tells us that public comment period has been reopened for the following reasons:

  • Acreage of critical habitat has been revised to correct previous errors
  • Seventy-three acres of San Francisco’s city-managed parks have been added “at the request of the staff of the Recreation and Park Department.”
  • The National Park Service and the Presidio have both asked that some of their property be removed from the designation of critical habitat.
  • A Draft Economic Analysis has been added:  “…total potential incremental economic impacts in areas proposed as critical habitat over the next 20 years (2013 to 2032) will be approximately $28,222 ($1,411 annualized)…”  Given that the cost estimate for the recovery plan for the closely related Raven’s manzanita (and lessingia) was estimated as $23,432,500 in 2003, we consider this cost estimate for reintroduction of Franciscan manzanita ridiculous.

 Does San Francisco’s Recreation and Park Department understand that the Endangered Species Act provides the same legal protection for reintroduced species as it does naturally occurring endangered species, such as the red-legged frog and the San Francisco garter snake at Sharp Park?  The Recreation and Park Department was recently ordered by a federal judge to pay $386,000 of legal expenses of organizations that sued the Department on behalf of these endangered species.  The Department would be wise to consider that such suits on behalf of Franciscan manzanita would be likely if the Department does not conduct prescribe burns and/or does not destroy all trees in critical habitat because both are required for the survival of this species. 

We are reprinting below our original article of October 23, 2012, describing the horticultural requirements of Franciscan manzanita and our concerns about its reintroduction in the city-managed parks of San Francisco. 

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On September 5, 2012, US Fish & Wildlife (USFWS) announced that Franciscan manzanita is now an endangered species. In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive. It was transplanted to an undisclosed location in the Presidio in San Francisco.

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of land in San Francisco as critical habitat for the Franciscan manzanita. Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio. (Details about all the critical habitats are available here.) Forty of the 318 acres are on private land. Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

The taxonomy of manzanita is ambiguous

There are 96 species of manzanita in California (1). The ranges of most of these species are extremely small because the manzanita hybridizes freely and therefore adaptive radiation has resulted in a multitude of species, sub-species, and varieties that are adapted to micro-climates. Many of these species are locally rare, which is consistent with the fact that 6 species of manzanita have already been designated as endangered, two of which are limited to the San Francisco peninsula: Raven’s manzanita and Franciscan manzanita.

The genetic relationship between these two species of manzanita is ambiguous, which is reflected in the constantly shifting opinions of biologists about the taxonomy (species classification) of manzanita. The 2003 Recovery Plan for Raven’s manzanita recounted the long history of these shifting views. For some time, Raven’s and Franciscan manzanitas were considered the same species. Then, for an equally long time, they were considered sub-species of the same species, Arctostaphylos hookeri. It was not until 2007, that Raven’s was reclassified as a sub-species of Arctostaphylos montana. Presently, Franciscan manzanita is classified as its own species, Arctostaphylos franciscana.

Clearly, this history of the biological opinion regarding these two species of manzanitas suggests they are closely related and morphologically (AKA anatomically) similar. The Recovery Plan concludes, “The idea of ‘pure’ species in Arctostaphylos, with its many poorly defined taxa and prevalent hybridization has often been difficult to apply over the history of taxonomic work in the genus.”

To add to the confusion regarding the provenance of Franciscan manzanita, some biologists are of the opinion that the individual plant that was discovered on Doyle Drive is actually a hybrid, not a pure-bred Franciscan manzanita. The East Bay Regional Park District botanical garden in Tilden Park has planted a clone of the individual plant from Doyle Drive. It is labeled as a hybrid of Arctostaphylos uva-ursi, which is one of the few species of manzanita with a wide range.

This is the label on the “Doyle Drive” manzanita in Tilden Park Botanical Garden, indicating that it is a hybrid.

The park ranger who led us to this plant in the Tilden garden, pointed out that the plant is morphologically distinct from the Franciscan manzanita that has been resident in that garden for about 50 years. He expressed his opinion that the Doyle Drive manzanita was properly labeled as a hybrid.

In what sense is the Franciscan manzanita “endangered?”

Franciscan manzanita has been available for purchase in nurseries for about 50 years. It has been propagated by taking cuttings and therefore they are presumed to be genetically identical clones. However, given that this plant has been sold to the public for a long time, we have no way of knowing exactly where they have been planted or if some have successfully reproduced by germinating seeds. For all we know, this plant is thriving somewhere, perhaps even in a place we might call “wild.” Perhaps the plant found on Doyle Drive was purchased in a nursery!

The individual plant found on Doyle Drive has been defined by USFWS as Franciscan manzanita despite the fact that some biologists consider it a hybrid of another species. We understand that the motivation for designating this individual as an endangered species and providing it with critical habitat is based on an assumption that it is genetically different from the Franciscan manzanita that can be purchased in nurseries and that the chances of survival of the species may be improved by cross-fertilization of these two plants such that greater genetic diversity results from their union.

Yet we are offered no evidence of the genetic composition of the Doyle Drive individual or Franciscan manzanita sold in nurseries. Nor are we provided any evidence that the Doyle Drive individual is even a genetically “pure” Franciscan manzanita rather than a hybrid of another species altogether.

If we weren’t being asked to devote 318 acres of land to the propagation of a plant with such ambiguous taxonomy, we might not question how little information we have been provided. The technology of mapping the genome of this plant is available to us. Why aren’t we making use of this technology to resolve these ambiguities? The cost of planting 318 acres with this endangered plant far exceeds the cost of such genetic analysis.

We aren’t told what it will cost to plant 318 acres with this endangered plant, but we know that the cost of the recovery plan for Raven’s manzanita and lessingia was estimated as $23,432,500 in 2003. Presumably that is an indication that the proposal for Franciscan manzanita will be a multi-million dollar effort. The cost of transplanting the single plant from Doyle Drive to the Presidio was reported as over $200,000. (1)

Thirty years of endangered status for Raven’s manzanita has not saved this plant

We have already made the point that Raven’s and Franciscan manzanitas are closely related. In its proposal for the designation of critical habitat for Franciscan, USFWS confirms this close relationship by referring us to the Recovery Plan for Raven’s. In other words, the characteristics and horticultural requirements of these two species are so similar that a separate Recovery Plan for Franciscan is not necessary. The Recovery Plan for Raven’s is applicable to Franciscan.

Therefore, we should assume that the fate of the recovery effort for Franciscan will be similar to that for the Raven’s. Raven’s was designated as endangered in 1979. Its first recovery plan was published in 1984 and the second in 2003. Many 5-year reviews of its endangered status have been done during this 33 year period. The most recent 5-year review was published in June 2012; that is, very recently.

So what does USFWS have to show for 33 years of effort to save Raven’s manzanita from extinction? Almost nothing:

  • Clones of the single plant in the wild exist in several botanical gardens. These clones are genetically identical and their growth in maintained gardens does not meet ESA standards for recovery.
  • “The wild plant has been observed to set seed although no natural seedling establishment is known to have occurred.” (6)
  • The plant has been the victim of twig blight several times, but the fungus cannot be treated because it would damage the mycorrhizal fungi in the soil upon which the plant is dependent.
  • The seeds depend upon animal predators for dispersal which are largely absent in an urban area.
  • The pollinators of manzanita have not been identified and therefore there is no assurance that they still exist in this location.
  • The 5-year review concludes that: “…recovery sufficient to warrant full delisting is not projected in the foreseeable future for [Raven’s manzanita] and may not be possible.”

We can’t appreciate the significance of the utter failure of this effort without some mention of the extreme methods used to overcome these obstacles.

The seed of manzanita is germinated by fire. However, the exact relationship between fire and germination is not known. Therefore, many complex experiments have been conducted on the few viable seeds produced by the Raven’s manzanita in a futile effort to determine the winning combination. These experiments are described in detail in an article in Fremontia (1). In short, various combinations of fire, heat, cold, smoke, liquid smoke, etc., were tried and failed to determine exactly what triggers germination of manzanita seeds.

We should remind our readers of the legal definition of “recovery” according to the Endangered Species Act. According to the 5-year review for Raven’s manzanita, here are two of the criteria for recovery toward which there has been no progress in 33 years:

  • “At least five spontaneously reproducing variable populations are established in reserves…in San Francisco…”
  • “At least two sexually reproduced generations are established within the Presidio.”

Frankly, it is no longer credible to expect the recovery of Raven’s manzanita and this failure implies the same fate for Franciscan manzanita.

Can the public parks of San Francisco meet the horticultural requirements of Franciscan manzanita?

The public parks of the City of San Francisco cannot meet the horticultural requirements of the Franciscan manzanita because it requires fire to germinate its seeds.

All of the critical habitats proposed by USFWS in San Francisco’s public parks are designated “natural areas.” According to the DRAFT Environmental Impact Report of the “Significant Natural Resource Areas Management Plan,” prescribed burns are prohibited in the natural areas. Therefore, unless there are unplanned wildfires in the six public parks proposed as critical habitat, it will not be physically possible to “spontaneously reproduce” this plant, as required by the Endangered Species Act.

Granted, the City of San Francisco could revise its management plan for the natural areas to allow—or even require—prescribed burns in the six parks proposed as critical habitat. In that case, the citizens of San Francisco would be subjected to air pollution and risk of causing an uncontrolled wildfire in surrounding residential communities. The Natural Areas Program would be subject to even more criticism than it already endures.

The Natural Areas Program is extremely controversial in the City of San Francisco because it destroys healthy non-native trees, it sprays pesticides on non-native vegetation in public areas, it destroys the habitat of wildlife, and it limits the public’s recreational access to trails which are often fenced. Subjecting the natural areas to prescribed burns is surely the bridge too far for the public which would jeopardize the future of the entire program. Why would the City of San Francisco be willing to push the public over the edge by requiring prescribed burns in six urban parks in densely populated residential communities?

Furthermore, some of the proposed critical habitat is in heavily forested areas, which are not compatible with the requirement of manzanita for full sun. As they were on behalf of Raven’s manzanita, these trees would be destroyed. The City of San Francisco is already planning to destroy 18,500 trees over 15 feet tall to accommodate its desire to reintroduce native plants to forested areas. (3) How many more trees would need to be destroyed to accommodate Franciscan manzanita? How much more carbon dioxide would be released into the atmosphere by the destroyed trees?

Bayview Hill is one of the proposed critical habitats which are heavily forested. According to SNRAMP (3), 17.16 acres of Bayview Hill is forested. Given that Bayview Hill is the only proposed critical habitat which is outside the known historic range of Franciscan manzanita, the loss of 17 acres of trees does not seem a fair trade for a plant with few prospects for survival.

The proposed critical habitat in Glen Canyon Park (inaccurately called Diamond Heights by the proposal) is also forested in a portion of the 34 proposed acres of critical habitat. This is a park in which the destruction of trees is being hotly contested. The community in this park does not need the additional controversy of tree destruction for the sole purpose of planting an endangered species.

Proposed critical habitat in other city parks is likely to be controversial for other reasons, primarily because additional restrictions on recreational access will undoubtedly be required to protect this endangered plant. Bernal Hill is an example of a city park with a huge community of visitors who will undoubtedly be enraged by further loss of recreational access. They have already been squeezed by the restrictions imposed by the Natural Areas Program.

This proposal for critical habitat is not good public relations for the Endangered Species Act

The City of San Francisco is the second most densely populated city in the country. It is comprised of only 29,888 acres. There are only 3,317 acres of City-managed parks in the city. (2) The proposed critical habitat in City-managed parks is 196 acres, 6% of total City-managed park land in San Francisco.

Please ask yourself these questions:

  • Does it make sense for 6% of all City-managed park land to be permanently committed to planting an endangered plant which can be purchased in nurseries?
  • Does it make sense to confiscate 6% of all public parks for a plant the identity of which we are not certain?
  • Does it make sense to throw the public out of 6% of all public parks on behalf of a plant that will never be able to spontaneously reproduce unless there is an accidental wildfire?

We think the answers to these questions are no, no, and no. This is an ill-advised proposal which makes a mockery of the Endangered Species Act. This is an important law that is trivialized by a proposal that will be physically impossible to implement without endangering the public and damaging the environment.

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at http://www.regulations.gov (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn: FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.

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Bibliography

(1) Gluesenkamp, Michael, et al., “Back from the Brink: A Second Chance at Discovery and Conservation of the Franciscan Manzanita,” Fremontia, V37:4/38:1, 2009-2010

(2) Harnik, Peter, Inside City Parks, Trust for Public Land, 2000

(3) San Francisco Recreation and Park Department, “Significant Natural Research Area Management Plan (SNRAMP),” 2006

(4) San Francisco Recreation and Park Department, “DRAFT Environmental Impact Report for SNRAMP,” 2011

(5) USFWS, “Designation of Critical Habitat for Franciscan Manzanita,” September 5, 2012

(6) USFWS, “5-Year Review of Endangered Status of Raven’s Manzanita,” June 2012

(7) USFWS, “Recovery Plan for Coastal Plants of the Northern San Francisco Peninsula,” 2003

The international crusade against non-native plants

Some years ago we set up a few Google alerts on the topics we cover on Million Trees so that we would be informed of new developments.  One of those Google alerts was “invasive species.”  We receive a daily barrage of articles about the international crusade against non-native plants.  Once in a great while we are also treated to a small voice of reason in this otherwise unreasonable crusade. 

Nanaimo, Briish Columbia
Nanaimo, Briish Columbia

Here is a letter to the editor of the Nanaimo News Bulletin in Nanaimo, British Columbia, Canada written by someone responding to a local attempt to eradicate non-native plants, AKA “invasive species.”  We could have written this letter ourselves.  It represents our viewpoint perfectly. 

Published: April 23, 2013 7:00 AM

“To the Editor,

Re: City leading attack on invasive plants, April 18.

Once they were weeds, and we got rid them when they were in our way.

Now they’re “invasive species”, and we’re urged to get rid of them even when they’re not in the way.

Why? Because they’re “alien.”

This, of course, is nonsense.

Nature doesn’t recognize man-made boundaries or discriminate between “native” and “alien” plants. Apart from a few well-known examples, most people don’t know the difference either. Most of the plants in our gardens are “alien.”

One of the favourite targets is Scotch broom. It’s claimed that broom crowds out native species, though we’re never told what they are. No wonder, since broom thrives on ground disturbed by human activity such as roadways and abandoned fields.

Far from being a nuisance, it’s a nitrogen-fixing plant that enriches the soil. One of the many myths spread about broom is that its pollen is an allergen.

Not so. A University of B.C. study has shown that its pollen grains are too large to cause an allergic reaction.

Now the City of Nanaimo wants to get rid of the blackberries that we look forward to in August and September. It’s the wrong kind of blackberry, apparently.

It has decided to designate May as “Invasive Plant Awareness Month” and is encouraging residents to remove the aliens from wherever they are.

Goodness knows what the city will look like after the eco-warriors have gone on the rampage with their brushhooks.

We do not live in an unchanging Garden of Eden. Nature is dynamic. Birds carry seeds over hundreds of miles and new plants grow where they didn’t grow before.

Human attempts to halt natural growth and development are arrogant and doomed to failure. By all means get rid of weeds on your property or on public land where they’re a nuisance.

Otherwise, let nature take its course, and don’t feel you’re somehow saving the planet by hacking away at a plant just because it’s on an “alien” hit list.

Gregory Roscow

Nanaimo”

If you share this viewpoint without expressing it when confronted with the relentless public relations campaign in support of destructive “restoration” projects, we urge you to speak up.  There are many of us who object to these destructive projects, but few are expressing their concern about the loss of ecologically valuable plants and trees. 

Many thanks to Mr. Roscow for his eloquent defense of defenseless plants in Nanaimo, British Columbia.

Forests respond to climate change

This is a story that passes for good news at a time of global warming. A new study based on data from 21 broadleaf forests in northern latitudes over a 20 year period reports that forests in some places seem to be capable of achieving normal rates of growth while using less water. For the moment, the assumption is that increased levels of carbon dioxide are essentially acting as a fertilizer, promoting growth with less water. This suggests that at least in some locations, it might be possible for forests to survive through the droughts caused by climate change.

Broadleaf forest. Blue Ridge Parkway
Broadleaf forest. Blue Ridge Parkway

Like most changes in the environment, there are pros and cons to forests using less water because forests recycle the water into the atmosphere where it becomes rain clouds. If the forests take up less water, they will probably supply less moisture to agricultural areas downwind of the forests.

Where forests exist on the perimeters of their climatic ranges, they are not faring as well. In the American West, for example, there are massive tree die-offs caused by less rainfall and snow as well as beetle infestations where temperatures are no longer cold enough to kill them in the winter.

Scientists had predicted some growth benefit from higher levels of carbon dioxide, but this study found the benefit to be far greater than previously predicted. Higher growth rates also predict that forests will be capable of absorbing more carbon dioxide because carbon storage is mainly proportionate to biomass.

Trees absorb carbon dioxide through the pores in their leaves, called stomata. Scientists hypothesize that trees don’t need to open their pores as wide when carbon dioxide levels are higher. Since moisture is lost when the pores open, less moisture is lost if the pores don’t open as wide. That’s the working theory of this new research.

Harvard Arboretum
Harvard Arboretum

The forest at the Harvard arboretum was one of the forests included in this study. It has the longest continuous record of forest growth in the world.

Many questions remain. Which species are becoming more efficient in their water use? Are there intervening factors that are reducing water use? Will this trade-off between water use and carbon dioxide levels have an upper limit?

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Sources:
“Some Trees Use Less Water Amid Rising Carbon Dioxide, Paper Says,” New York Times, 7/11/13

“Trees Use Water More Efficiently as Atmospheric Carbon Dioxide Rises,” Science Digest, 7/10/13

Professor Joe McBride defends the forest on Mount Davidson

With great pleasure we share with our readers the following letter from Professor Joe R. McBride to Phil Ginsburg, the General Manager of San Francisco’s Recreation and Park Department, expressing his criticism of the plans of the Natural Areas Program to destroy 1,600 trees on Mount Davidson.

 Joe McBride is Professor of Environmental Science in the College of Natural Resources at University of California, Berkeley and an expert on urban forestry in the San Francisco Bay Area and around the world.  He is the author of many studies of urban forests, several of which he cites in his letter to the General Manager.  He is particularly expert on the failure of trees caused by extreme wind conditions. 

Professor McBride kindly accepted the invitation of several neighbors of Mount Davidson to read the plans of the Natural Areas Program (SNRAMP) for Mount Davidson and tour the mountain with them to evaluate those plans within the context of the actual conditions there.  The neighbors and all lovers of the urban forest are extremely grateful to him for his time and willingness to share his expertise and decades of experience with us to help us save this beautiful forest from being needlessly destroyed.

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June 29, 2013

Mr. Phil Ginsburg
General Manager
San Francisco Recreation and Park Dept.
San Francisco, CA 94117

Re: Significant Natural Resource Areas Management Plan for Mt. Davidson Park

Dear Mr. Ginsburg,

I am writing to express my concern over the plan for removal of trees on Mt. Davidson.  This concern is based on the historical importance of the trees, their contribution to San Francisco landscape, and several specific aspects of the Significant Natural Resource Areas Management Plan for San Francisco. As a Professor of Urban Forestry at the University of California I have for many years studied plantations of trees in the city and compiled several reports for the U.S. Army, National Park Service, Presidio Trusts, and the Golden Gate Conservancy concerning the condition and management of eucalyptus, Monterey pine, and Monterey cypress stands.  My concern over the proposed management plan for Mt. Davidson is based both on my experience in urban forestry and on my experience as a citizen of the Bay Area who has enjoyed the urban forests of San Francisco for many years.  These concerns are elaborated in the following paragraphs.

The eucalyptus and Monterey cypress on Mt. Davidson were planted under the direction of the former Mayor of San Francisco, Adolph Sutro.  He was also responsible for planting other areas in the city that have subsequently become city parks.  The plantations he established have served to protect park users from the wind, provide wildlife habitat, and in some cases define the visual character of the San Francisco landscape.  They present an important historical heritage that I think should not be discarded lightly.  I found no mention of the historical significance of the Mt. Davidson forest in justification for the proposed management in the Natural Areas Resource Management Plan for San Francisco.  San Francisco might review the vegetation management plan developed by the Presidio Trust for the National Park Service to see the approach taken at the Presidio to maintain and manage historically significant forest plantations.

From a number of vantage points in San Francisco one can see several of the city’s hilltops covered in plantations of eucalyptus and Monterey cypress.  These plantations stand in contrast to the architecture that surrounds them.  They have been part of the San Francisco landscape for over one hundred years.  Eucalyptus plantations are as much a part of the California landscape as the coastal grassland, chaparral, and oak woodland plant communities for many people growing up in the Bay Area.  I did not find the visual value of the eucalyptus and Monterey cypress plantations on Mt. Davidson addressed in the plan.  I was, however, alarmed by the use of the term ”invasive forest” in reference to eucalyptus plantations.  This is a pejorative term that should not be applied to eucalyptus plantations.  I have found little evidence of eucalyptus invading adjacent areas of grassland or other native vegetation types in the San Francisco Bay areas in studies I conducted in open space areas (McBride, Sugihara, and Amme, 1987; McBride, Cheng, and Chorover, 1989; Cheng and McBride, 1992; Russell and McBride, 2003).  Comparison of photographs of Mt Davidson taken in the 1920s and 1950s show no evidence of the eucalyptus invading the adjacent grassland area (Proctor, 2006).  These photographs indicate that a stable boundary exists between the eucalyptus plantation and the adjacent grassland.  I see no justification for the establishment of a stable boundary between the eucalyptus and grassland habitats as called for in the “Site Improvements” section of the Significant Natural Resource Areas Management Plan. Mt Davidson 1885

MD 1927 RPD presentation        MD 2010 RPD

My concerns over the management plan for the eucalyptus and Monterey cypress plantation on Mt. Davidson are based on portions of the Significant Natural Resources Areas Management Plan : 5. General Recommendations, 6.2 Mount Davidson, Appendix F Urban Forestry Statements.  I am concerned with the justification for tree removal and the proposed levels (%) of trees to be removed.

Justification for Tree Removal

The primary justification for tree removal in the documents is the restoration of native habitat.  Various statements are made concerning the minimal amount of habitat within the eucalyptus urban forest.  This assumption is not supported by any data or reference to publications on this topic.  Stebbins (1976) concluded that eucalyptus plantations in the East Bay were far richer habitats for vertebrates than either redwood or Monterey forest and that they vie with ‘dry’ chaparral and grasslands in species diversity and ’attractiveness’ to vertebrate species.

The general recommendation to maintain a basal area between 200 and 600 square feet per acre is appropriate.  However, a conflict exists at Mt. Davidson where some stands (MA-1c) within the plantation currently have basal areas less than 200 square feet yet the plan proposes the removal of 82% of the trees.  I think there is a problem with the use of tree density measured in eucalyptus stands in Glen Canyon Park in developing the proposed cutting of trees at Mt. Davidson.  The point-quarter survey mentioned in Appendix F (Urban Forest Statements) of the Significant Natural Resources Areas Management Plan indicates a tree density of 353 trees per acre.  Three eucalyptus plantations measured in the Golden Gate National Recreation Area had tree densities of 50, 98, and 726 trees per acre (McBride, Cheng, and Clausen, 2004).  These numbers demonstrate the wide range of tree densities found within eucalyptus plantations in San Francisco.  I estimated the tree density in stand MA-1c from Google Earth images of Mt. Davidson to range from 24 to 33 trees per acre.  Trees in this stand average about 24 inches in diameter.  Trees of this size with a density of 33 trees per acre would have a basal area of a little over 100 square feet per acre (103.6 square feet).  No trees from the area designated MA-1c could be removed if the basal area recommendation was followed.  The same would apply to stands MA-2e and MA-2c where recommendations are for removal of 23% and 31% respectively.  I think a major shortcoming of the Plan is that lack of stand-specific tree density data.

Various sections of the Significant Natural Resource Areas Management Plan justify tree removal as a means of allowing re-vegetation with native understory vegetation.  Species commonly found in the understories of native forests and woodlands of the Bay Area are adapted to the low light intensity of these forests and woodlands.  Removing the eucalyptus overstory up to 82% as proposed for area MA-1c will expose the ground surface to light levels that most native understory plants will not be able to tolerate.  The management plan also points out that removal of eucalyptus will result in the promotion of growth of existing exotic understory species.  These will no doubt, compete with any native species for the site.  The suggestion that these exotic species will be controlled by manual removal and the use of herbicides indicates the City is prepared for a large investment of time and labor to combat these plants.  Projects to eliminate exotic understory plants at the Presidio after overstories of Eucalyptus and Monterey cypress have been removed have proved to be very expensive and only partially successful.

The Significant Natural Resource Areas Management Plan states that the proposed forest management will not result in long-term changes in recreational use of the natural areas.  I cannot agree with this conclusion.  The proposed cutting of trees will increase the windthrow and wind breakage of the remaining trees.  Trees that have grown up together in a plantation have buffered each other from the wind.  When individuals are exposed by the removal of surrounding trees they are very vulnerable to the wind.  This is well documented in studies of native forests and forests which have been thinned or opened for subdivision development (Franklin and Forman, 1987; McBride, 1999, 2002, 2003; Sinton et al, 2000).  The tree fall and wind breakage hazard to walkers using the Mt. Davidson area after the proposed tree removal and thinning would, I believe, seriously compromise the use of the area for recreational purposes.  The existing forest plantations currently contribute to the use of Mt. Davidson by walkers because of the reduction in wind velocity by the trees.  Forest plantations studied at the Presidio and at Lands End significantly reduce wind velocity and protect people walking from uncomfortable wind chill effects (McBride, 2002; McBride and Leffingwell, 2003).  Choice of coastal bluff trails at the Sea Ranch made by walkers is often dependent on the amount of protective cover from the wind provided by areas planted with Monterey cypress.  The exposure of Mt. Davidson to winds from the ocean will result in a less pleasant recreational experience if trees are removed.

There is an assumption in the Significant Natural Resource Areas Management Plan that minimal impact will occur to species such as hawks and owls as a result of tree removal because the overall acreage of the forest will remain high.  This is not a valid assumption for two reasons.  First, hawks and owls choose specific trees for nesting and perching.  These trees are chosen on the basis of their position in a forest stand and the structure of the tree.  Nests are used by some species year after year so that the removal of a nesting tree can present a major problem for the specific bird using the tree.  Avoiding the cutting of nest trees during the nesting season, but felling of these trees after the nesting season is a major impact that should not be part of the management plan.  It is also important to not remove trees surrounding nesting trees.  Most recovery plans for rare and threatened tree nesting birds require a protected area with a minimum radius of 300’ around a nesting tree.  No trees can be removed within this zone.

In the “Site Improvements” section of the Significant Natural Resource Areas Management Plan it is suggested that the management proposals will improve the health of the eucalyptus forest.  It is suggested that tree thinning will promote a more healthy forest.  This certainly is true in densely stocked forest stands, but I did not observe conditions in the eucalyptus plantations where tree density required thinning.  Several standing dead eucalyptus trees are present at Mt. Davidson, but the standing dead trees I examined had all been girdled.  It was evident that some individual or individuals have had a vendetta against eucalyptus trees and had girdled trees in the past.  I did not see any indication of natural mortality in the overstory of the plantations.  Concern has been raised over the potential for ivy to grow up the trunks and eventually smother the eucalyptus trees.  I have not observed this taking place in eucalyptus plantations in the East Bay.  Ivy (English and Algerian) may climb the trunks of trees, but in my experience it does not have the capacity to grow over the smaller limbs and branches.  There were a couple of eucalyptus snags completely covered by ivy at Mt. Davidson, but these snags were the result of girdling of the trees snags, not the growth of ivy.  The ivy, Cape ivy, and the Himalayan blackberry in the under story of the eucalyptus plantation are restricting establishment of eucalyptus seedlings.  I do not see this as a problem at the current age of the plantation.  Perhaps in another hundred years an examination of the plantation could establish the need for regeneration.  At this time in the life of the Mt. Davidson plantation I do not consider the lack of regeneration a problem.  Removal of the exotic understory species at this time would reduce the habitat quality of the plantation, especially the removal of Himalayan blackberry that provides a valuable food source for many species.

I conclude that the Significant Natural Resource Areas Management Plan for the removal and thinning of different portions of the eucalyptus plantation on Mt. Davidson is not justified.  The plantation serves an important role in the history and visual characteristics of the city.  Trees and the existing understory provide habitat for wildlife and wind protection for walkers.  The justifications for the management prescriptions have not been properly developed.  Furthermore, the cost of removal of the trees seems unjustified in view of other priorities in the San Francisco budget.

Sincerely,
        
Joe R. McBride
Professor

CC:  Mayor Edwin M. Lee
City and County of San Francisco Board of Supervisors
San Francisco Recreation and Park Commission
San Francisco Planning Commission
San Francisco Urban Forestry Council
Park, Recreation and Open Space Advisory Committee
Bill Wycko, Environmental Review Officer (Case No. 005.1912E)

Literature Cited

Cheng, S. and J.R. McBride. 1992. Biological Assessment of Mills Creek Riparian Corridor. Report to the California Department of Parks and Recreation. Monterey Co., CA 89p.

Franklin, J. and R.T.T. Forman. 1987. Creating landscape patterns by forest cutting: ecological consequences and principles. Landscape ecology 1:5-18.

McBride, J. R. 1999. Identification of areas of high windthrow potential at the Sea Ranch. McBride and McBride. Consulting Landscape Ecologists. Berkeley, CA.

McBride, J. R. 2002. Presidio of San Francisco Wind Study, First Phase.  Report to the Presidio Trust. San Francisco, CA. 35 p.

McBride, J. R. 2003. Re-evaluation of the windthrow problem at The Sea Ranch. Report to the Planning Department. The Sea Ranch, CA. 6 p.

McBride, J. R. and J. Leffingwell. 2003. Effects of Forest Stands on the Microclimates of the Presidio. Report to the Presidio Trust. San Francisco, CA. 27 p.

McBride, J.R., N. Sugihara and D. Amme. 1987. Vegetation Assessment. In: D. Boyd (Ed.)  Environmental assessment for Eucalyptus Removal on Angel Island. California Dept. Parks and Recreation, Sacramento, CA. pp 23-45

McBride, J.R., S. Cheng and J. Chorover. 1989. Natural Resources Assessment – Jack London State    Park. Calif. Dept. Parks and Recreation. Sacramento, CA. 432 p.

Proctor, J. 2006. San Francisco’s West of Twin Peaks. Charleston, SC: Arcadia Publishing.

Russell, W. H. and J. R. McBride. 2003. Landscape scale vegetation-type conversion and fire hazard in the San Francisco Bay Area open spaces. Landscape and Urban Planning 64:201-208.

McBride, J. R. , S. Cheng, and J. Clausen. 2004. Vegetation management Strategy for Lands End, GGNRA. Report to the Golden Gate National Park Conservancy. San Francisco, CA

Sinton, D. S. et al.  2000. Windthrow disturbance, forest composition, and structure in the Bull Run Basin, Oregon. Ecology 81(9): 2539-2556.

Stebbins, R. 1976. Use of habitats in the East Bay Regional Parks by free-living vertebrate animals. August 1975. In “Vegetation Management Principles and Policies for the East Bay Regional Park District”.  East Bay Regional Parks District. Oakland, CA.

“Invasion Biology: Critique of a Pseudoscience”

Broom is the likely occupant of East Bay public land now shaded by non-native trees that will be destroyed the FEMA projects. Share alike.
Broom is the likely occupant of East Bay public land now shaded by non-native trees that will be destroyed by the FEMA projects. Share Alike.

Invasion Biology:  Critique of a Pseudoscience is a book by David Theodoropoulos. (1)  He explains in the preface of the book, how he arrived at the conclusion that invasion biology is a pseudoscience and why he felt compelled to explain that conclusion in his book.

Theodoropoulos was from an early age a lover of nature and he always spent much of his time outdoors, observing nature.  He recalls noticing decades before writing his book that some plant species—such as broom—tended to occupy disturbed ground such as roadsides.  He was also aware that introduced species of plants were contributing to biological diversity.  Putting those two observations together, he concluded that plants that are introduced and dispersed by the activities of man are integrating into ecosystems and increasing biodiversity.

As the hysteria about “alien invasions” began to mount in the 1990s, Theodoropoulos could not reconcile this anxiety with his observations of nature.  He read the studies that supported invasion biology and found their scientific methods and their conclusions unsatisfactory.  He concluded that the fear of introduced plants was motivated by “psychological factors” that are not supported by scientific evidence. 

As he shared his observations with others, he was subjected to abusive attacks by proponents of invasion biology, which ultimately compelled him to write his book to defend his opinion of invasion biology.  He explains why he wrote his book:

“During the past decade ‘invader’ fears have reached a fevered pitch, with  a constant barrage from the media fanning the flames, and a huge volume of literature has been published, produced by scientists with a self-interest in promoting this ideology.  Corporate and bureaucratic interests have intruded, pushing their agendas of profit and control.  Finally, the use of invader fears to justify total human control of the natural world has shown that the ideology has reached a dangerous place.”   (emphasis added)

David Theodorpoulos will be speaking in the East Bay on Sunday, July 14, 2013.  Here is the announcement of this event by its sponsor East Bay Pesticide Alert:

INVASION BIOLOGY

OR INTEGRATION BIOLOGY?

Who is behind the deforestation and pesticiding of the East Bay Hills, from Richmond to Hayward?

**Slideshow with narration, followed by discussion**

DAVID THEODOROPOULOS

Conservation Biologist and Author:

Invasion Biology: Critique of a Pseudoscience

+ Update from Save Mt. Sutro Forest

SUNDAY, JULY 14, 2013, 6:30PM (doors open 6PM)

Historic Hall, Berkeley Fellowship of Unitarian Universalists

1924 Cedar (one block east of MLK, Jr. Way)

Hear about Invasion Biology from a different perspective of non-native species, based on Evolutionary Biology, and find out about the native plant restoration movement’s connection to the pesticide industry.

**Please refrain from using scented products prior to attending **Wheelchair accessible

Co-sponsored by East Bay Pesticide Alert (dontspraycalifornia.org) (see wildfire pages) & Social Justice Committee BFUU (bfuu.org)

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We have read Mr. Theodoropoulos’ book and we have heard him speak.  We can highly recommend both his book and his talk as informative and interesting.   We can also recommend the speaker about the Sutro Forest in San Francisco.  If you are not aware of how widespread the destruction of non-native plants and trees is, you will want to hear about the plans to destroy over 30,000 trees on Mount Sutro in San Francisco.  Please come to learn about the destructive consequences of projects that are attempting to convert our diverse landscape into native plant advocates’ fantasy of what it looked like 250 years ago.

Update:  A video of this presentation is now available here.

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(1)    Avvar Books, 2003

Harassment by native plant zealots

Ruth Bancroft Garden is a mix of native and non-native plants
Ruth Bancroft Garden is a mix of native and non-native plants

The following exchange of emails was recently posted to the faculty email list at City College of San Francisco.  The first email was sent by a student at City College to the President of the Board of Trustees of the College and the Chancellor.  (Written communications to public employees are in the public record.) The second email was sent by the Chairman of the Environmental Horticulture and Floristry program at City College. 

“On Wed, Apr 24, 2013 at 12:03 AM, Denise Louie,  email address redacted

Hello President Rizzo, Chancellor Scott-Skillman and Sustainability Committee members,

 Today I spoke with Environmental Horticulture instructor Gus Broucaret while his class was removing plants outside the Environmental Horticulture building.  He indicated his plan was to replant similar non-native plants.   I pointed out that the CCSF Sustainability Plan calls for planting native plants and urged him to reconsider his plant choices.  If no one has done so, I suggest you request that all Environmental Horticulture faculty and staff be asked to follow principles of the Sustainability Plan.  That includes planting [local] native plants, removing and avoiding invasive plants, conserving resources like water, and the like.

 At the same time, I heard that a native plant installation had been designed for the front of EHD.  The plan was drafted and did go through certain review processes, only to have been shelved.  I suggest you ask the EHD chair to present the written plan for a native plant installation in front of EHD, so that interested stakeholders may see it and discuss it further. It is entirely possible to create a local native plant landscape that yields cut flowers, berries and greens for flower arrangement classes.

The online CCSF employee directory does not show an email address for Mr.  Broucaret, so I intend to call him to inform him of my mention of his name in this email.

 Thank you,
 Denise Louie
 Member, Sustainability Committee”
 

“Steven Brown, email address redacted 4/25/2013 3:12 PM

This is absolute harassment and illegal behavior.

Denise Louie has no business interrupting instructors during class times, period. She has done so several times now.

This student doesn’t know anything about what she is talking about. And she does not represent the sustainability committee.

My instructors have all been advised to call the campus police if she interrupts them.

She has been removed from our department in the past and has had instructions not to be here.

I have filled out paper work many times to try to end this harassment.

I had no idea this incident had occurred until now.

I am extremely upset about this and will be looking into hiring an attorney to sue the school for not taking steps to prevent this behavior. This harassment has gone on for three years now!

We have cooperated with the sustainability plan which is a guide. Title five is law, the Ed code is law.

This has to stop”

The Chairman of the Environmental Horticulture & Retail Floristry program is featured in a video about the program on the CCSF website.  In that video, he explains that “Horticulture is the decorative use of plants…We teach our students how to use plants in an urban landscape and how to maintain that landscape.”  This suggests that students in that program can expect to learn about both native plants and the thousands of species of non-native plants that are planted in our gardens.  A horticulture program that uses exclusively native plants would not provide its students with the education they need to be gardeners. 

In the 15 years in which we have been engaged in the effort to prevent the destruction of our non-native urban forest we have witnessed and been subjected to harassment from native plant zealots.  We have been threatened and accused of wrongdoing of which we are innocent.  Therefore, we sympathize with the Chairman of the CCSF horticulture program. 

At the same time, we acknowledge that there is a wide range of both opinion and behavior amongst native plant advocates, just as there is a wide range within the community of their critics.  We do not wish to paint native plant advocates with a broad brush.  We only wish to remind them that such attempts at intimidation do not reflect well on their community.

Above and below the middle ground are trees that will be destroyed by the FEMA project. The middle ground is a preview of the landscape these projects hope to achieve. Photo taken from Skyline Blvd, south of Claremont Blvd, looking north to Frowning Ridge.
Above and below the middle ground are trees that will be destroyed by the FEMA project. The middle ground is a preview of the landscape these projects hope to achieve. Photo taken from Grizzly Peak Blvd, south of Claremont Blvd, looking north to Frowning Ridge.

We received many more comments than usual during the public comment period for the FEMA projects in the East Bay Hills.  We posted many of the comments we received from supporters of the project.  We did not post comments from those who called us names and/or threatened us.  When we refused to post those comments, the threats and name-calling escalated, making it even less likely that we would post their inflammatory comments. 

Another theme in the dialogue with native plant advocates, which was repeated by some media coverage of this episode, is their deep state of denial of the strength of the opposition to the destructive projects they demand.  They repeatedly portray critics of these projects as a “tiny band” and similar minimizing descriptions. 

They are very mistaken.   The primary supporter of the FEMA projects, The Claremont Canyon Conservancy, claims in its public comment (available on CCC’s website) to represent 500 families.  Yet, the Conservancy’s on-line petition supporting the FEMA projects has less than 500 signatures.  In contrast, the petition which criticizes the FEMA projects has over 5,700 signatures.    The opposition to these projects has overwhelmed the support, which will surely be reflected in the public comments.  As these projects get bigger, greater numbers of trees are in jeopardy, and the devastating consequences are more apparent, the opposition will also get bigger and noisier.  We will eventually be heard. 

Media coverage of FEMA projects: The good, the bad, and the ugly

Anise Swallowtail butterfly in non-native fennel
Anise Swallowtail butterfly in non-native fennel

The public comment period for the FEMA project in the East Bay that proposes to destroy nearly half a million trees will close on Monday, June 17, 2013, at midnight.  If you want to express your opinion of these projects, it’s time to do so.  Detailed information about the projects and how to comment on them is available HERE.

The projects have drawn quite a bit of media coverage, starting with Beyond the Chron blog in mid-May and quickly picked up by many other internet sources of information.  Most of those internet sources referred their readers to the Million Trees blog for more information.  In May we had over 12,000 visitors to our articles about these projects.

Both the Oakland Tribune and the San Francisco Chronicle covered the story.  The Tribune coverage was appallingly inaccurate and biased.  The Chronicle coverage was more balanced than it usually is about native plant restoration projects, which the Chronicle usually supports without reservation.

The winner of the booby prize for balanced and fair reporting of the projects goes to the Sierra Club Yodeler which expressed its unqualified support for the projects at the same time it demonstrated total ignorance of the projects (or chose to misrepresent them):

  • Sierra Club said, “We want to avoid past mistakes, when agencies simply stripped off vegetation and then walked away, leaving the land clear for exotic and even more-flammable vegetation.”  This is precisely what these projects plan to do…destroy everything then walk away without planting anything.
  • Sierra Club said, “The Park District is now implementing that program, and we are monitoring the progress.”  If they are monitoring that program, why don’t they know what the Park District is doing?
  • Sierra Club said, “The preferred alternative involves application of the herbicide glyphosate (trade name Roundup) to the stumps to prevent re-sprouting. There is no practical way to eliminate eucalyptus infestations without herbicide, and glyphosate is relatively low in toxicity.”  The Sierra Club is simply wrong.  These projects will use Garlon (with active ingredient triclopyr) and/or Stalker (with active ingredient imazapyr)—not glyphosate (Roundup)–to prevent the trees from resprouting.  Both products are rated by the EPA as more toxic, more persistent, and more mobile in the soil than glyphosate.  Glyphosate (Roundup) will be foliar sprayed on non-native vegetation.  Recent studies report that glyphosate (Roundup) is not a benign pesticide.

There are some scathing comments on the Yodeler article from people who know enough about the project plans to inform the Club that they have run off the rails…into the weeds!!  The Club seems not to have noticed this attempt to set them straight.  When someone called them weeks later to ask about the projects, they repeated the same misinformation to the caller.

(Update:  One of our readers informed the Sierra Club of the inaccuracy of its Yodeler report about the FEMA projects in the East Bay (see comment below).  We are pleased to report that the Sierra Club has revised its Yodeler report on June 19, 2013.  It now acknowledges that native plants will not be planted by these projects.  Consistent with the Draft Environmental Impact Statement for these projects, the Yodeler now claims that native plants will be “recruited” into the areas in which non-native plants and trees will be destroyed. 

We think that is an unlikely outcome of these projects and FEMA’s environmental consultant agrees with us about that (explained here).  However, at least the Yodeler article is now consistent with the written plans for the project. 

The Yodeler also acknowledges the use of Garlon to kill the roots of the trees that will be destroyed.

Thanks to our readers for alerting the Sierra Club to the inaccuracy of their description of this project.  We are sorry that the Sierra Club continues to support the project now that they have a better understanding of the written plans. 6/19/13) 

Owl nesting in eucalyptus, courtesy urbanwildness.com
Owl nesting in eucalyptus, courtesy urbanwildness.com

On the positive side of the ledger, we commend the East Bay Express for its article about these projects.  The author deserves credit for actually reading about the projects before she wrote her report!!!  She read the letter from FEMA’s environmental consultant which we reported to our readers here.  In a nutshell, the consultant said that UC Berkeley’s project could increase fire hazards by leaving a 2-foot wood chip mulch on the ground and that conversion to a native landscape was an improbable outcome of the project since nothing will be planted.

Song Sparrow in non-native wild radish
Song Sparrow in non-native wild radish

Our personal favorite for coverage of this project is Nathan J. Winograd’s article, “Biological Xenophobia:  The Environmental Movement’s War on Nature,” which was published by the Huffington Post.   Mr. Winograd is highly qualified to express his opinion of these projects.  He has devoted his personal and professional life to the welfare of animals. He is best known for his advocacy for “no-kill” shelters for our animals.  He was the lawyer for the SPCA in San Francisco when the GGNRA started to destroy non-native trees and fence the public out of their properties to protect their fragile native plant museums.  So, he has been a long-time observer of the destructive and restrictive consequences of native plant projects.  He was prompted to write this article by this latest round of destruction, that is, the FEMA projects in the East Bay.

Here are a few choice phrases from Mr. Winograd’s excellent article:

“Invasion biologists believe that certain plants and animals should be valued more than others if they were at a particular location ‘first.”  When the species that were there ‘first’ are in the same habitat with a species that came later, they assert that the latter should be eradicated.”

 “And the nativist movement is getting worse and increasingly violent, both in rhetoric (fish they don’t value are called ‘missiles with fins’) and in deeds.  At a time of climate change, in a country that needs more trees, not less, nativists in the San Francisco Bay Area are proposing the clear cutting of upwards of half a million trees on San Francisco’s Mount Sutro and in the Oakland and Berkeley hills as part of their ongoing war against the Eucalyptus.  After the trees are clear-cut thousands of gallons of toxic herbicides, will be spread throughout wildlife corridors in order to prevent resprouting.”

“An authentic environmentalism would not advocate that humans seek out and destroy living things for simply obeying the dictates of the natural world, such as migration and natural selection. It would not condone the killing of those plants and animals who find themselves in parts of the world where, for whatever arbitrary reason — be they economic, commercial or aesthetic — some humans do not want them to be. An authentic environmentalism would not exacerbate suffering, call for killing and seek the destruction of natural places.”

“Indeed, “invasion biology” is a faux environmentalism, used to disguise the ugly truth about what is really motivating its adherents: an intolerance of the foreign that we have rejected in our treatment of one another, a biological xenophobia that seeks to scapegoat plants and animals for the environmental destruction caused by one species and one species alone: humans.”

There are nearly 500 comments on Mr. Winograd’s article and they are as interesting as the article itself.  They are a microcosm of this debate between nativists and those with a more cosmopolitan view of nature.  We aren’t disinterested observers, so our opinion of the comments of nativists may not be entirely objective.  However, we find many of their comments condescending and uninformed, a contradictory mix of sentiments.

We thank our readers for informing themselves about the FEMA projects and we hope that you now have the information you need to write your public comment by the deadline, June 17, 2013.  Here is where you can send your comment:

  1. Via the project website: http://ebheis.cdmims.com
  2. By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
  3. By mail: P.O. Box 72379, Oakland, CA 94612-8579
  4. By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars.  So, please tell the people who work for you what you think of these projects.

Guest article about FEMA projects by a student of the forest

A few days ago we received a comment from a fellow tree-lover and student of the forest that deserves our attention.  He visited the project areas that may soon be cleared of all non-native trees and expressed his opinion of this planned devastation.  With his permission, we are posting his comment as an article.

His name is Deane Rimerman and he describes himself as “Hybrid Car Geek, PNW Landscape Restorationist, Web Builder, Arborist, Writer, Poem Performer, Life-long Photographer & Audio Engineer” on his website.  

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Frowning Ridge before "vegetation management"
Frowning Ridge before “vegetation management”

Yesterday I toured the Oakland hills for the first time since I visited it a week after the 1991 fires. That torched landscape turned me into a lifelong student of the forest. So after my visit back to those hills yesterday I started reading everything I could about these FEMA plans!

In the interest of providing the most value I’ll focus on what’s not been mentioned yet in the debates I’ve read on this website thus far. Primarily it revolves around moisture and the value of tall standing trees for the purpose of capturing fog drip during the dry season.

I once worked with a forester named Rudolph Becking on studies that show 200 foot tall old growth redwoods can capture up to 7 inches of fog drip during the dry season. The biggest tallest eucalyptus,and pines, invasive or not also have the ability to do this. And if we’re talking about fire safety don’t we want to increase humidity in soil and in the air during the hottest driest times of the year? If the answer is yes, that can be done by protecting sites that are most exposed to fog in the dry season.

Frowning Ridge after 1,900 trees were removed from 11 acres in 2004
Frowning Ridge after 1,900 trees were removed from 11 acres in 2004

Also eucalyptus are huge water users only when they are young and exposed to full sun, but like most trees, once in a closed canopy forest they consume far less water during the dry season compared to open canopy forests.

Point being, we need to maintain landscapes that don’t dry out because plant and tree diversity won’t thrive and really aggressive invasive weeds will take over if we don’t intentionally map out and seek to protect the highest existing levels of soil moisture. The SF Bay Area climate is very arid.  If a time of drought were to coincide with this fire hazard removal plan, we could have a mass die-off native species and an even greater shift to drought tolerant non-native weeds that will eliminate most biodiversity.

And regardless of drought, desert like alterations to the landscape is what happens when we lose too much shade and moisture all at once. Many native plants growing under semi-shade conditions right now can’t survive if all the non-natives are clearcut or near clearcut as proposed in this plan.

Also what is missing from this landscape is lots of tall dead trees that act as bioreactors for flora fauna and rhizo diversity. Tall dead trees are like a bank account for future healthy soil, homes for so many birds and bugs too. There is a great poverty of standing deadwood on this landscape, yet no significant mention of snag retention and snag creation in this plan.  If we cut down all the largest live and dead standing trees there will be no large downed log recruitment for another century and that would be a misguided tragedy that will further impoverish the soil.

In a word: DIVERSITY.  You don’t have to cut down all the trees to increase diversity. We could have thousands of us spending every winter in these hills replanting hundreds of different species of native plants, as well as clearing weeds away from existing native plants in a low-impact site-specific way.  This of course is a labor intensive approach and humans have been manipulating these hills for thousands of years in very labor intensive ways.

In my view we’ve neglected these lands for too long and it’s about time we get back to all of us working together as volunteers meant to cultivate a garden of biodiversity with an eye toward carbon absorption and keeping as high as possible soil moisture and air moisture in order to prevent catastrophic fires.

But instead in this plan we see the usual lazy, super aggressive approach in which a forester, whose job is to cut down forests, is asked to solve our problems. And without any site-specific observation of fog drip and areas of high soil moisture in the dry season we log the forests as quickly and cheaply as possible thinking if we do it severely enough we won’t ever have to come in and fix anything ever again.

The homeowner version of these two approaches is akin to one homeowner who makes their landscape beautiful with hard work and lots of hands-on low impact cultivation of plant and tree diversity without herbicides. And then we have the other lazy homeowner who hates his yard and weedwacks his yard to bare ground every other year thinking once he does it one more time (and even more severely this time with extra herbicide) he won’t ever have to do it again.

And habitat-wise, if we inoculate eucalyptus and pine with heart wood rot to create cavities for habitat we will help fuel the whole food chain, not to mention create homes for myriad species.

And to all the folks who say these hills were mostly shrub oak and grassland I say that natural ecosystems in this region were mosaics of conifer and hardwood woodlands amongst mosaics of shrublands and small grassy meadows and it was all maintained by humans who for thousands of years used fire to maximize productivity in traditional cultivation areas. Those cultivation practices were based on specific sites where species grew best. The current plan as proposed is the antithesis of this. The current plan treats the whole landscape as if there’s very little variability of moisture levels and species compositions.  It’s as if the planners know more about growing corn in Iowa than they do about growing an ecosystem in the arid San Francisco Bay Area.

Frowning Ridge 2013
Frowning Ridge 2013

Lastly, the Monterey Pine is entirely native to a landscape that’s less than 100 miles away. And yes some of these pines might be a hybridized New Zealand variety but so what?

I’ll have more to say on all this soon… Maybe a whole website or book perhaps? 🙂

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Remember that public comments are due by June 17, 2013.  You may submit written comments in several ways:

  1. Via the project website: http://ebheis.cdmims.com
  2. By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
  3. By mail: P.O. Box 72379, Oakland, CA 94612-8579
  4. By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars.  So, please tell the people who work for you what you think of these projects.