Pesticide use in public parks in the San Francisco Bay Area

San Francisco Forest Alliance (SFFA) is a 501(c)4 not-for-profit organization with a mission of inclusive environmentalism. SFFA fights to protect our environment through outreach and providing information. SFFA opposes the unnecessary destruction of trees, opposes the use of toxic herbicides in parks and public lands, and supports public access to our parks and conservation of our tree canopy.

With permission, Conservation Sense and Nonsense is republishing SFFAs annual report on pesticide use by San Francisco’s Recreation and Park Department.  The report separates pesticide use in so-called “natural areas” from other park areas and finds that most pesticides are used in “natural areas.”  Conservation Sense and Nonsense is grateful to SFFA for compiling and reporting this important information. 

Conservation Sense and Nonsense follows pesticide use by the East Bay Regional Park District (EBRPD), where the pattern of pesticide use is similar to San Francisco’s Recreation and Park Department.  EBRPD has restricted spraying of glyphosate pesticides in developed areas of the park while continuing to use pesticides in naturalized areas to eradicate non-native plants.  In other words, most pesticide use in the public parks of the San Francisco Bay Area is devoted to eradicating non-native plants.

Conservation Sense and Nonsense


As we usually do, we compiled the pesticide usage data for San Francisco Recreation and Parks Department for 2021.  (We exclude Harding Park – but not the other golf courses – from this analysis because it’s externally-managed under a PGA contract to be kept tournament-ready at all times.) We’re pleased to note that SFRPD has reduced its pesticide usage in comparison to 2020 and 2019. 

NATIVE PLANT AREAS USE MORE OF THESE TOXIC HERBICIDES

But this is not true of the Natural Resources Division (this includes PUC areas managed in the same way – i.e. use of toxic herbicides against plants they dislike). Their usage has risen and is the highest it’s ever been from 2016.

The Natural Resources Department (NRD, formerly the Natural Areas Program or NAP) is the entity that is trying to bring “native” plants to more than a thousand acres of our parks, cuts down trees and restricts access to people and their pets.  NRD, which accounts for perhaps a fourth of the land area, used over 70% of the pesticides measured as active ingredients in fluid ounces.

NRD – and PUC lands that they are managing the same way – continued to increase their use of triclopyr since the new pesticide Vastlan has been designated Tier II (More Hazardous) instead of Garlon, which was Tier I (Most Hazardous). In both herbicides, the active ingredient is triclopyr. They also increased their usage of imazapyr, and continued to use Roundup, though in smaller quantities than before.

Here are the two earlier graphs lined up to show the comparison. The Native Plant areas used more herbicides in 2021 than they had ever used in the last six years – or that the other SFRPD departments together used in the same time. Their failure to reduce usage in 2021 is in stark contrast to the more than 50% drop in the other SFRPD.


SFRPD Other (i.e. other than the Native plant areas) uses mainly Polaris (imazapyr) and Clearcast ( ammonium salt of imazamox). The native plant areas, NRD / SFPUC, use large amounts of triclopyr, (Garlon and Vastlan), as well as some glyphosate (Roundup).

A FAILING STRATEGY

The NRD’s continually growing usage of the herbicides is a sign that this strategy is failing. They have been using hazardous chemicals on some 50 target species of plants year after year. Theoretically, the point of using toxic herbicides on unwanted species is to allow the desired species to replace them.  Instead, the growing usage of these chemicals shows that if anything, the situation is only made worse.

This stands to reason; “invasive” plants are successful because they are better adapted to current conditions. If they are destroyed with herbicides, the replacement is likely to be the next best adapted (thus, invasive) species. Given 50 target species, the bench is deep. This leads to a vicious cycle of hazardous herbicide use, clearly visible in the graph above.

PESTICIDES COME TO SHARP PARK 

For many years since we started compiling these data, Sharp Park has been off-limits for pesticides. We’ve seen very minimal usage – maybe 3 or 4 times over all the years. It’s home to the red-legged frog, and the San Francisco garter snake.

In 2021, that changed. In the space of one year, pesticides were applied 9 times. We did anticipate this would happen as NRD extended its grip on this park.

TIER HAZARD RATINGS

San Francisco’s Department of the Environment (SFEnvironment) assigns Tier hazard ratings to the various pesticides it uses. Tier III is Least Hazardous, Tier II is More Hazardous, and Tier I is Most Hazardous.  Over the years we have been following this usage, we have seen various chemicals being moved from one Tier to another. Milestone was moved from Tier I to Tier II; Glyphosate (Roundup, Aquamaster)  from Tier II to Tier I; and triclopyr (Garlon, Garlon 4 Ultra, Turflon, Vastlan) from Tier I to Tier II (for Vastlan and Turflon). Avenger was moved from Tier II to Tier III, which we think makes sense and makes analysis easier. We analyze the usage of Tier I and Tier II herbicides.

REDUCE OR ELIMINATE HERBICIDE USE

SF Forest Alliance has been trying to encourage SFRPD to reduce or eliminate Tier I and Tier II herbicide use. Some years ago, it appeared that pesticide usage was declining, especially after the Roundup revelations. When we wrote our Pesticides report for 2016, the other areas of SFRPD had slashed their herbicide use; the NRD accounted for 74% of pesticide usage. The 2021 data have renewed our hope that SFRPD’s other departments will adopt a cautious approach to the use of toxic herbicides. Unfortunately, this does not appear true of the nativist departments, NRD / PUC.


Every year, the San Francisco Forest Alliance also makes public comment at the annual review of San Francisco’s Integrated Pest Management program.  Conservation Sense and Nonsense is grateful for SFFA’s vigilance of pesticide use in San Francisco’s public parks.  Below is an excerpt from SFFA’s public comment to the Commission on the Environment regarding San Francisco’s IPM program.

Conservation Sense and Nonsense


Once again we are sending our comments emphasizing the self-evident truth that high toxicity herbicides are dangerous, unnecessary, and should never be used…

Below are the points we have repeated year after year for many years:

  • Herbicidal chemicals are more toxic, more persistent, more mobile and more dangerous than their manufacturers disclose;
  • The aesthetic or ideological “danger” from “weeds” is not a risk to health and welfare;
  • Scientific studies associate exposure to herbicides with cancer, developmental and learning disabilities, nerve and immune system damage, liver or kidney damage, reproductive impairment, birth defects, and disruption of the endocrine system;
  • There is no safe dose of exposure to those chemicals because they persist in soil, water, and animal tissue, so even low levels of exposure could still accumulate and harm humans, animals, and the environment;
  • Especially vulnerable individuals include infants, children, pregnant women, the elderly, people with compromised immune systems and chemical sensitivities;
  • Toxic runoff from herbicides pollute streams and groundwater, and therefore the drinking water sources;
  • Herbicides are harmful to pets and wildlife – including threatened and endangered species, plants, and natural ecosystems;
  • Herbicides are harmful to soil microbiology and contaminate soil into the future, reducing biodiversity in sensitive areas…

San Francisco Forest Alliance, July 11, 2022

New funding creates new threats to eucalyptus trees

I recently received a message, asking for help to save a grove of eucalyptus trees on the Napa River from destruction:  “I live in Napa on the river where eucalyptus trees are going to be cut down that are home to owls, ravens, herons, egrets and more for over 50 years.  Could you please help save these beautiful trees and wildlife? Any suggestions or ideas would be greatly appreciated.”

Eucalyptus trees on Milton Road on the Napa River
Owls nest in the trees on Milton Road

I learned a few more details by speaking with the neighbor of the trees.  The trees are on State property and the project was going to be funded by California Department of Fish & Wildlife (CDFW).  There are few trees in this neighborhood and therefore few alternatives for the birds that roost and nest in the eucalyptus trees

Eucalyptus grove on the Napa River in which many birds nest and roost

The neighbors asked if herbicides would be used to prevent the trees from resprouting.  That was a concern partly because the well that supplies their drinking water is within 60 feet of the trees.  Before they received an answer to that question, they were informed that “CDFW has decided to halt their project of cutting down the eucalyptus trees on Milton Road!”  We don’t know why CDFW changed its mind, but we would like to believe the questions raised by the neighbors may have helped.  Thanks and congratulations to the neighbors of the eucalyptus grove on the Napa River.

Eucalyptus trees threatened in El Granada

Shortly before I heard from folks in Napa, I learned about a project to destroy eucalyptus in a small community on the coast of San Mateo County.  It’s a foggy coastal location, much like Mount Sutro in San Francisco, where fog drip from the trees during summer months keeps the ground moist and reduces fire hazards. 

The community has made a video (available HERE) about the project and the issues it raises.  It is an even-handed presentation that acknowledges the fire hazards of dense forests in the hills surrounding their community and contrasts that risk with the lower risk of the widely spaced trees in the medians of their village on flat land.  The video explains the many important functions that trees perform to store carbon, improve air quality, provide wind protection and habitat for birds.  The people of El Granada would like the project to reduce fire hazards in the hills, but retain the trees in their street medians because of their ecological value.  It’s a reasoned and reasonable approach.

Source: El Granda Advocates. http://egadvocates.org

The people of El Granada ask for your help to save some of their trees.  Their website (available HERE) invites you to sign their petition.

Predictable…and probably only the beginning

The State of California has committed billions of dollars in fire hazard mitigation, climate change, and biodiversity.  We watched the budgetary plans for these projects being developed in the past year and the plans were recently approved.  Now communities all over California are applying for State grants to implement projects like the two I have described today.  Now it’s up to communities to watch as plans are developed and participate in the process to ensure that the plans reflect their wishes.  It’s your money and your community.  Pay attention and engage in the process.

Postscript…different, but the same

Days before publishing this article, I received an email from Santa Barbara:  Well it is with great sadness we have to report that The University of California at Santa Barbara (UCSB) is again trying to destroy hundreds of Eucalyptus trees here at the University.  They want to destroy what is known as “The Eucalyptus Curtain” the boundary between the University and Isla Vista the college town here.” 

“Eucalyptus Curtain,” UC Santa Barbara. Source: localwiki.org

Some people who are trying to save this grove of eucalyptus are appealing to the California Coastal Commission.  They suggest those who share their opinion contact the CCC HERE.

In this case, the motivation for destroying these trees is not the usual allegation that they are a fire hazard.  According to this article in localwiki, the trees will be destroyed to build more student and faculty housing.  There is no question in my mind that we need more housing and I am rarely opposed to any housing project, including this one.  However, the consequences of destroying these trees are the same regardless of the motivation:

Eucalyptus and Bee, painting by Brian Stewart

Weeds are making a comeback!

While the native plant movement remains strong in California and locally in the San Francisco Bay Area, some communities are waking up to the fact that weeds make valuable contributions to our gardens and the wildlife that lives in them.  The British have always been ahead of us in welcoming plants from all over the world in their gardens.  The British have been enthusiastic importers of plants from all over the world for hundreds of years.  They had one of the biggest empires in the world, spanning the globe from India to Africa, Australia, New Zealand, and America, which put them in a unique position to sample the botanical riches of the world.

The English garden, where plants from all over the world are welcome

In a recent article in The Guardian, an English gardener describes her journey from fighting the weeds in her garden to her new relationship with them:  “I remember writing, many years ago, about my fight to get rid of these dandelions. Clearly, I didn’t win. Now, when I am greeted by them, I am glad I lost the battle. These days, I truly consider them friends…they are welcome in my garden, because I know they do more good than harm.”

The English gardener reminds us that the war on weeds began only recently.  Going deep into agricultural history, weeds were natural forage that were a part of our diet. Weeds fed our domesticated animals, stuffed our mattresses and made twine and rope. Many have medicinal properties, but most have marketable substitutes now. They were tolerated on the edges of agricultural fields and in our gardens.

The typical American lawn, maintained with pesticides and fertilizer is not habitat for pollinators or other insects. Source: Pristine Lawn Care Plus

The war on weeds began after World War II, when chemicals were introduced to agriculture.  Pesticides were considered benign for decades.  We have learned only recently of the dangers of some pesticides. The promotion of pesticides changed the aesthetics of gardening, initiating an era in which weeds were banished from our agricultural fields and our gardens.  

Note the drone hovering over the children in a strawberry field. Drones are the latest development in chemical warfare. They are used to spot non-native plants in open space as well as to aerial spray pesticides. They are cheaper than other methods of application and for that reason are likely to increase the use of pesticides.

Do not underestimate the power of propaganda to promote the use of pesticides:  “A publishing company linked to the most powerful agricultural lobby group in the U.S. is releasing children’s books extolling the benefits of pesticides and nitrogen fertilizers.”  Industrial agriculture begins the indoctrination of the public at childhood. 

Bumblebee in clover. Source: buzzaboutbees.net

Weeds made their way back into our gardens partly by evolving resistance to the pesticides we used for decades to kill them.  There is growing awareness of the impact of pesticides on insects and wildlife.  As populations of pollinators decline, we are more willing to indulge their preference for weeds such as dandelions and clover.  Weeds are often the first to arrive in the spring garden, as native bees are emerging from their winter hibernation in ground nests.  Weeds prolong the blooming season in our gardens, providing nectar and pollen before cultivated plants are blooming. 

“No Mow May” comes to America!

“No Mow May” originated in Britain out of concern for declining populations of bees.  Communities make a commitment to stop mowing their lawns in May to let the weeds dominate their lawns.  Weeds such as dandelions and clover give the bees an early boost in the spring that studies show increases bee populations.  Lawns maintained with pesticides and fertilizers provide poor habitat for bees. 

Two professors in the Midwest of the US introduced “No Mow May” to their community in Wisconsin in 2020.  They signed up 435 residences to participate in “No Mow May” and studied the impact:  “They found that No Mow May lawns had five times the number of bees and three times the bee species than did mown parks. Armed with this information, they asked other communities to participate.”  According to the New York Times, “By 2021, a dozen communities across Wisconsin had adopted No Mow May. It also spread to communities in Iowa, Minnesota, Illinois and Montana.”

Farmers climb on board

Hedgerows are the backbone of the English countryside.  They are a complex bramble of woody and herbaceous plants that traditionally served as fences, separating roads from agricultural fields and confining domesticated animals.  They nearly disappeared when industrial agriculture dictated that fields be cultivated from edge to edge. They are making a comeback in the English countryside as farmers realize that their loss contributed to the loss of wildlife.  The concept of hedgerows as vital habitat is slowly making its way to America.

US Department of Agriculture reports improvements in agricultural practices in the past 10 years:  more no-till farming that reduces fossil fuel use and carbon loss from the soil; more efficient irrigation methods; broader field borders for pollinators and wildlife; more crop rotations that reduce disease and insect pests; reduction of nitrogen and phosphorous run-off; reduction in diesel fuel use, etc.  These are all well-known methods of reducing environmental damage from industrial agriculture, but there is now evidence that farmers are actually adopting them. 

Nativists are late to the game

We see progress being made to reduce pesticide use and provide more diverse habitat for wildlife, but nativists drag their feet.  They continue to use pesticide to eradicate non-native plants and they deny the value of non-native plants to insects and wildlife, despite overwhelming evidence to the contrary. 

In a recent comment posted on Conservation Sense and Nonsense, a nativist explains the justification for using herbicides to eradicate non-native plants:  “No one likes herbicides, but in the absence of a labor force willing to abandon its modern conveniences to do very hard work, they are important tools in restoration ecology, and methods are improving as a result of careful science to determine how the least amount of them could be used to gain the greatest amount of benefits to the maximum amount of species. Throwing those tools away is about like tossing chemotherapy or vaccinations because of that “all-or-nothing” black or white point of view that native plant supporters are being (unjustly) accused of.”

For nativists, the harm done by non-native plants is greater than the harm done by pesticides.  This equation does not take into consideration the benefits of many non-native plants to wildlife and it underestimates the damage caused by pesticides to the environment and its inhabitants.   

A Natural History of the Future

“The way out of the depression and grief and guilt of the carbon cul-de-sac we have driven down is to contemplate the world without us. To know that the Earth, that life, will continue its evolutionary journey in all its mystery and wonder.” Ben Rawlence in The Treeline

Using what he calls the laws of biological nature, academic ecologist Rob Dunn predicts the future of life on Earth. (1)  His book is based on the premise that by 2080, climate change will require that hundreds of millions of plant and animal species—in fact, most species–will need to migrate to new regions and even new continents to survive.  In the past, conservation biologists were focused on conserving species in particular places.  Now they are focused on getting species from where they are now to where they need to go to survive.

In Dunn’s description of ecology in the future, the native plant movement is irrelevant, even an anachronism.  Instead of trying to restore native plants to places where they haven’t existed for over 100 years, we are creating wildlife corridors to bypass the obstacles humans have created that confine plants and animals to their historical ranges considered “native.” 

The past is the best predictor of the future. Therefore, Dunn starts his story with a quick review of the history of the science that has framed our understanding of ecology.  Carl Linnaeus was the first to create a widely accepted method of classifying plants and animals in the 18th century.  Ironically, he lived in Sweden, one of the places on the planet with the least plant diversity.  Colombia, near the equator, is twice the size of Sweden but has roughly 20 times the number of plant species because biodiversity is greatest where it is hot and wet.

Global Diversity of Vascular Plants. Source: Wilhelm Barthlott, et. al., “Global Centers of Vascular Plant Diversity,” Nova Acta Leopoldina, 2005

 

Humans always have paid more attention to the plants that surround us and the animals most like us.  Dunn calls this the law of anthropocentrism.  We are the center of our own human universe.  Consequently, our awareness of the population of insects that vastly outnumber us came late to our attention in the 20th century.  In the 21st century we learned that all other forms of life are outnumbered by the microbial life of bacteria, viruses, and fungi that preceded us by many millions of years.  Our knowledge of that vast realm of life remains limited although it is far more important to the future of the planet than we realize because those forms of life will outlast our species and many others like us.

Tropical regions are expanding into temperate regions

The diversity and abundance of life in hot and wet tropical climates give us important clues about the future of our warming climate.  We tend to think of diversity as a positive feature of ecosystems, but we should not overlook that tropical regions are also the home of many diseases, such as malaria, dengue fever, zika, and yellow fever that are carried by insects that prey on animal hosts, including humans.  In the past, the range of these disease-carrying insects was restricted to tropical regions, but the warming climate will enable them to move into temperate regions as they warm. The warming climate will also enable the movement of insects that are predators of our crops and our forests into temperate regions.  For example, over 180 million native conifers in California have been killed in the past 10 years by a combination of drought and native bark beetles that were killed during cold winters in the past, but no longer are.  Ticks are plaguing wild animals and spreading disease to humans in the Northeast where they did not live in the cooler past. 

Human populations are densest in temperate regions“The ‘ideal’ average annual temperature for ancient human populations, at least from the perspective of density, appears to have been about 55.4⁰F, roughly the mean annual temperature of San Francisco…” (1) This is where humans are most comfortable, free of tropical diseases, and where our food crops grow best.  As tropical regions expand into temperate regions, humans will experience these issues or they will migrate to cooler climates if they can.

Our ability to cope with the warming climate is greatly complicated by the extreme variability of the climate that is an equally important feature of climate change.  It’s not just a question of staying cool.  We must also be prepared for episodic extreme cold and floods alternating with droughts. Animals stressed by warmer temperatures are more easily wiped out by the whiplash of sudden floods or drought.

Diversity results in resiliency

Diversity can be insurance against such variability.  If one type of crop is vulnerable to an insect predator, but another is not, growing both crops simultaneously increases resiliency.  That principle applies equally to crops that are sensitive to heat, cold, drought, or floods. 

Agricultural biodiversity. Source: Number of harvested crops per hectar combining 175 different crops. Source: Monfreda et al. 2008. “Farming the planet: Geographic distribution of crop areas, yields, physiological types, and net primary production in the year 2000”. Global Biogeochemical Cycles, Vol. 22.

Historically, cultures that grew diverse crops were less likely to experience famine than those that cultivated monocultures.  The Irish potato famine of the mid-19th century is a case in point.  The Irish were dependent upon potatoes partly because other crops were exported to Britain by land owners. When the potato crop was killed by blight, more than one million people died in Ireland and another million left Ireland.  The population dropped about 20-25% due to death and emigration.  The diversity of crops in the United States (where corn is the commodity crop) and Brazil (where soy is the commodity crop) is very low, compared to other countries.  This lack of diversity makes us more vulnerable to crop failure and famine, particularly in an unpredictable climate.

Change in total use of herbicides, antibiotics, transgenic pesticide producing crops, glyphosate, and insecticides globally since 1990. Source: A Natural History of the Future

Instead of increasing crop diversity, we have elected to conduct chemical warfare on the predators of our crops by using biocides, such as pesticides for agricultural weeds and insects and antibiotics for domesticated animals.  The scale of our chemical warfare has increased in response to growing threats to our food supply.  This is a losing strategy because as we increase the use of biocides we accelerate evolution that creates resistance to our biocides. We are breeding superweeds, insects, and bacteria that cannot be killed by our chemicals.  This strategy is ultimately a dead end.

Evolution determines winners and losers

Inevitably, evolution will separate the survivors of climate change from its victims. Dunn reminds us that “The average longevity of animal species appears to be around two million years…” for extinct taxonomic groups that have been studied.  In the short run, Dunn bets on the animals that are most adaptable, just as Darwin did 160 years ago.  The animals most capable of inventing new strategies to cope with change and unpredictability will be more capable of surviving.  In the bird world, that’s corvids (crows, ravens, jays, etc.) and parrots.  In the animal world that’s humans and coyotes.  We aren’t helping adaptable animals survive because we are killing abundant animals based on a belief it will benefit rare animals.  Even in our urban setting, the East Bay Regional Park District contracts Federal Wildlife Services to kill animals it considers “over-abundant,” including gulls, coyotes, free-roaming cats, non-native foxes, and other urban wildlife throughout the Park District.  We are betting on evolutionary losers.

 

If and when humans create the conditions that cause our extinction, many of our predators are likely to disappear with us.  Bed bugs and thousands of other human parasites are unlikely to survive without us.  Many domestic animals will go extinct too, including our dogs.  On the bright side, Dunn predicts that cats and goats are capable of surviving without us.             

Timeline of the evolution of life. Source: CK-12 Foundation

However, in the long run Dunn bets on microbial life to outlast humans and the plants and animals with which we have shared Earth.  Humans are late to the game, having evolved from earlier hominoids only 300,000 years ago, or so.  The plants and animals that would be recognizable to us preceded us by some 500 million years, or so.  But microbial life that is largely invisible to us goes back much further in time and will undoubtedly outlast us.  Dunn says microbial life will give a big, metaphorical sigh of relief to see us gone and our environmental pollutants with us.  Then microbial life will begin again the long process of rebuilding more complex life with their genetic building blocks and the tools of evolution. 

Some may consider it a sad story.  I consider it a hopeful story, because it tells me that no matter what we do to our planet, we cannot kill it.  For the moment, it seems clear that even if we are not capable of saving ourselves at least we can’t kill all life on Earth.  New life will evolve, but its features are unfathomable because evolution moves only forward, not back and it does not necessarily repeat itself. 


  1. A Natural History of the Future, Rob Dunn, Basic Books, 2021

Beyond the War on Invasive Species: Interview with Tao Orion

I am republishing with permission a portion of Kollibri terre Sonnenblume’s interview of Tao Orion.  Kollibri is a writer, photographer, tree hugger, animal lover, and cultural dissident. Kollibri was born and raised in Nebraska, earned a Bachelor of Arts in Writing at the St. Olaf Paracollege, and lived in the Twin Cities and Boston before moving to Portland in 2001. Since 2011, Kollibri has lived predominantly in rural areas in the Western US, working in agriculture and exploring wildtending. Kollibri has published several books, including The Troubles of ‘Invasive’ Plants (with Nicole Patrice Hill), originally a zine and soon to be published as a book.  Kollibri has also recorded interviews available as podcasts, “Voices for Nature & Peace,” which can be found at radiofreesunroot.com.

Conservation Sense and Nonsense


Tao Orion, author of “Beyond the War on Invasive Species”

Tao Orion is the author of “Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration.” She is a permaculture designer, teacher, homesteader, and mother living in the southern Willamette Valley of Oregon. I interviewed her on May 18, 2020, for my podcast, “Voices for Nature & Peace.” What follows is a partial transcript of that conversation, edited for clarity. [Listen to the entire interview here]

Kollibri terre Sonnenblume, macska moksha press

K: A lot of people have heard the term, “invasive species” and most of them of course are assuming it’s something bad, but when it comes right down to it, it’s actually very difficult to define the term and we could even say that there isn’t one definition of that term.

T: Yes, that’s something that I found really interesting as I was researching my book, because I was really trying to find out if there was a clear, objective description of what an invasive species is, and I found that even the National Invasive Species Council—which in the US is the federal government level board that looks at invasive species issues—spent years on deliberating on the definition and even so, they weren’t able to come up with something that I felt was purely an objective description that could be [applied] in all contexts. It seemed to vary from place to place and time to time.

K: Monsanto was one of the companies involved in setting [that council] up.

T: That’s another disturbing element about how the big frenzy around invasive species and the purported damage that they do came to be so popular; a lot of that was informed and funded by pesticide interests to spur the sale of products, herbicides in particular, to deal with species invasions.

K: I think that most people are probably not aware of the fact that the use of pesticides and herbicides has been rising over the last 20 years, not falling. I think people hear about organic agriculture and they think we must be on the right path. But due in part to the war on invasives and also due to genetically modifying crops to be Round-up Ready so they can survive the use of pesticides—these two things seem to have driven an increase in the use of pesticides over the last 20 years.

T: Yes, it’s definitely alarming. My background is in organic agriculture. I was immersed in that world. Even before writing this book, I was under the impression that herbicides were somewhat less toxic in the realm of pesticide toxicity [as opposed to insecticides or fungicides, for example]. In researching herbicides more for invasive species management and agriculture in general, I learned a lot more about their toxicity and insidious toxicity to insects and mammals and other lifeforms that I don’t think gets talked about enough. People assume they’re more ecologically benign, but really they’re not, and that’s important to bring to the table.

K: One thing you mentioned in your book that I hadn’t thought about much before is that it’s not only the active ingredient in a pesticide, but also the adjuvants—the things that they add to the active ingredient to help it stick to plants or to help make it soluble in water, etc.

T: Yeah, that was a big realization for me too. We talk about these two different terms: “Round Up” is the trade name of the herbicide, of which “glyphosate” is considered the active ingredient. Glyphosate is the ingredient that’s tested for pesticide registration purposes, but that might be only ten percent of a mixture that’s sold in the bottle. The rest of that solution is made up of other ingredients that help the herbicide stay on the plant if it rains or if its windy, or help the herbicide active ingredient penetrate the cells of the plant. A lot of these are trade secrets so they’re not tested and the manufacturers don’t have to say what’s in there. But one compound that has been pulled out and studied by independent researchers is POEA [polyoxyethyleneamine], which has been shown to make glyphosate penetrate human placental cells. So even if you come into contact with glyphosate itself, that wouldn’t necessarily happen, but if you come into contact with Round Up, which contains this adjuvant, POEA, it can actually then allow the glyphosate to enter into the cell. Because that’s what it’s in there to do.

K: The reason we’ve been talking about pesticides because herbicides are such a big part of getting rid of “invasive” species… But your book tries to turn things on its head and to question the concept of whether we should be trying to eradicate them.

T: Yes. I was shocked when I started working in the field of ecological restoration, coming from a background in organic agriculture. I had heard of “invasive species” before but when I got into this context, I was around people who did this professionally, it was just assumed that I was going to use herbicides and I would be totally fine with that, because that’s just what everybody did. The whole context was, “we have to get rid of these plants at all costs, and if we do, everything will be okay.” [Laughs.] That’s the the framework in which we’re approaching ecosystem restoration, and to me, I was amazed because from a more holistic perspective, I could see right off the bat that in every case where invasive species were thriving, there were other things going on in the ecosystem that pesticides weren’t going to address.

It’s the same in conventional agriculture. If you’re having, quote, pest pressure issues, the issue isn’t the pest, the issue is the soil or the plant stress or drought stress. There’s all these different things playing into the manifestation of pest pressure in the ecosystem. So, taking that knowledge a few steps further to ecosystem restoration I think is really necessary. A lot of people involved in these contexts are really highly trained ecologists and it’s still hard for me to square that with the belief that herbicides, pesticides are the only solution. These are often people who are shopping at organic food markets, and only buy organic food, and believe really strongly in that framework for food production, and yet are making decisions about ecosystem restoration outside of agricultural contexts that rely on pesticides and I just think that really needs to be questioned.

I had some very interesting discussions over the years and maybe the needle is starting to shift a little bit, although as you mention, sometimes these discussions flare up online where people are really quite defensive about their position and belief around this.

K: The issue tends to infect any discussion around plants. I’ve been using a couple of plant ID groups on Facebook because I’m in a new area and I’m seeing things coming up and I’m like, “What is this?” Of course if you’re in a native plant group, that’s definitely going to be someplace where [the invasive framework] is strong. You know, a native-plants-equals-good, non-native-plants-equals-bad, black and white paradigm. Which brings us around to looking at the invasive plant not being a problem in and of itself but of being a symptom of something going on.

T: That’s a huge part of the conversation that a lot of folks really aren’t willing to easily engage in, but the design of our livelihood system has really degraded ecosystems to a place where native flora and fauna aren’t thriving. You know, to really sit with that, and acknowledge it, think about how we might approach things differently as a basis for our understanding is challenging. It’s a lot easier to blame the messenger. Also I think one of the things that’s really missing from the discussion of native plants is the fact that native ecosystems were or are managed by indigenous people. They don’t just exist in a vacuum, free from people’s influence and the whole idea of this “pristine” wilderness is very much a western, colonial thought pattern that definitely needs to be disrupted.

K: What you’re referring to in part is that when people are designating a plant as invasive or non-native, there’s a point in time they’re referring to, and that might be different from place to place, but it’s generally accepted in the United States that anything anything that showed up after 1492 is not native. There are people who are willing to describe most non-native plants as “invasive” or throw them in that bin as soon as possible, and then the poisons come out, so this is an important issue.

T: Yes, but we don’t really know the social, ecological, economic context that was going on at that point in time that led to a particular assemblage of plants. There’s no doubt that the floral and faunal assemblies were different, but we should think really hard about why they’ve changed. Draining the wetlands of the Sacramento and San Joaquin valleys in California has major ecological implications. Damming the Colorado River for hydro-power and irrigation capacity has major ecological implications. These bigger scale things that we do—that we support—are going to change the surrounding ecosystem. If we can acknowledge that and observe what’s happening because of those major shifts, I think we’ll be in a better position to understand so called “invasions” from a more holistic perspective.

K: Because the entry of an invasive plant or animal into a landscape is in virtually all cases preceded by a human-caused disturbance of some kind.

T: It’s interesting. When I was writing, [I wondered if I] should I put forward the idea of reclaiming a different name because “invasive species” has kind of this negative connotation, but the more I looked into evolutionary biology and some of the ways—in the deep time perspective—how systems have changed, “invasion” is one of these processes and it’s not unnatural. Taking that longer term perspective is important as well. That’s how plants came to be on land. There were marine beds of algae hanging out in the shallow seas a couple billion years ago and eventually, speciation happened because of changing conditions and the land was “invaded” by those plants. You just see that change over time leading to the type of biodiversity that we have now, punctuated by other kinds of events of course, but it’s not something that’s “outside the realm of nature,” which is how invasive species are situated in a lot of discussions.

Words Matter: “Die-Off” vs. “Die-Back”

California has been in severe drought conditions for over 10 years.  Climate change is the underlying reason for the extremity of the drought.  Maintaining our carbon sinks that sequester greenhouse gases causing climate change is one of our most important defenses against climate change and forests are one of our primary carbon sinks.  Unfortunately, California’s forests are dying of drought and associated insect infestations. You might think that given these conditions, we would try to preserve our forests. 

In fact, the drought has accelerated the war on our non-native urban forest in the San Francisco Bay Area.  All trees and plants have suffered during our prolonged drought.  Where trees are not irrigated in our parks and open spaces, signs of drought stress are visible.  Today, I am publishing my letter to the IPM Director and Fire Chief of East Bay Regional Park District about the need to make a distinction between dead trees and trees that are not dead, but showing symptoms of prolonged drought. My letter explains why we must distinguish between dead (described as “die-off”) and living trees (described as “die-back”) when making commitments to destroy trees that we desperately need during this climate crisis.

Links are provided to email addresses of recipients of my letter.  Please consider writing a letter of your own.


To:   Pam Beitz, Aileen Theile

CC:  Natural and Cultural Resources Committee, Matteo Garbelotto

As you know, the Park District hired the Garbelotto Lab at UC Berkeley to evaluate two species of trees in the parks, acacia and eucalyptus.  The reports of the Garbelotto Lab were recently published on the Lab’s website.  I am writing to ask that responsible staff read those reports and make adjustments in plans to remove trees as needed, based on those reports. 

Source: Report of Garbelotto Laboratory
Acacia die-off in Leona Canyon, East Bay Regional Park District. Source: US Forest Service

The diagnoses for acacia and eucalyptus are entirely different.  The pathogens are different in the two tree species.  The pathogens killing acacia are new and they are lethal.  The pathogens found in eucalyptus are not new.  They have been latent and asymptomatic in eucalyptus for decades and have only become symptomatic because of the stress of drought. The pathogens found in eucalyptus disfigure leaves and twigs, but are not fatal. 

Much like the microbes (bacteria, viruses, fungi, parasites) in our bodies that outnumber human cells, every tree is inhabited by microbes that are usually asymptomatic.  If similar tests were done on other tree species in the Bay Area, similar results would be found where trees are not irrigated.  The pathogens are always there.  Drought has made them visible.  If we were obligated to destroy every tree in the parks showing signs of drought stress, we would be required to remove most trees in the parks. 

There are significant disadvantages to destroying living trees:

  • A dead tree is not capable of resprouting, but a living tree is capable of resprouting unless it is a species that is not capable of resprouting. Eucalyptus, acacia, redwoods (not candidates for removal, but dying of drought nonetheless) and bay laurels are all vigorous resprouters.  The stumps of these living tree species will require herbicide applications to prevent them from resprouting. 
  • The herbicides used to prevent resprouting travel through the roots of the tree to kill the roots. Herbicides used to prevent resprouting damage the roots of neighboring plants and trees connected by their mycelium networks. 
  • The trees that are destroyed release their stored carbon into the atmosphere contributing to the greenhouse gasses causing climate change. In the absence of those trees, less carbon dioxide is removed from the atmosphere in the future.  Since the underlying cause of increased frequency and intensity of wildfires is the warmer/drier climate, removing living trees increases wildfire risks in the future.
  • As more trees die, wood debris has accumulated to the point that there isn’t sufficient disposal capacity. When roadsides in the Berkeley hills were clearcut over one year ago, it took 9 nine months to dispose of the wood debris.  Huge piles of wood debris were stacked on roadsides, creating a fire hazard.  The more trees that are destroyed, the more wood debris is created.
One of many piles of logs, Claremont Ave, November 2020. Photo by Doug Prose, courtesy Hills Conservation Network.

I am therefore concerned about the Park District’s plans to remove one million trees from parks in the East Bay, according to press coverage: “In consultation with academics and state experts, they’ve identified a mass die-off of trees in the parks as a result of stress from drought, climate change and a proliferation of non-native species. Now they estimate they need to remove more than 1 million trees on their land, at a cost of $20 million to $30 million in one park alone. One area of the die-off, located between Mt. Diablo and communities in Oakland and Berkeley, is particularly concerning to Fire Chief Aileen Theile.”  

In an earlier media interview Fire Chief Theile included eucalyptus in the list of dead trees: “The die-off, first noticed last October, has mostly hit eucalyptus, acacias, pines and bay laurels and has expanded this summer amid an exceptional drought.”  Oaks are strangely absent from that list of dead trees, although it is well known that there are thousands of dead oaks in the Park District that have not been removed.

In summary, I ask for your reconsideration of Park District plans and public communications regarding tree removals in the parks:

  • The Park District should confine plans for tree removals to dead trees. Dead trees are public safety risks that should be mitigated. Drought stressed trees that may be unsightly are not a priority for removal.  Given our heavy rains in December, it is still possible that many will recover.
  • Park District communications with the public should make a distinction between “die-off” and “die-back.” Acacias are accurately described as experiencing a die-off.  Eucalyptus are accurately described as experiencing a die-back.

Thank you for your consideration.

“When the Killing’s Done” Maybe never.

I have few opportunities to read fiction because most of my time is spent trying to keep up with rapidly evolving ecological science.  I was grateful for the chance to read the fictional account of island eradications on the Channel Islands because it closely relates to my interest in the planned eradication of mice on the Farallon Islands, which is still pending and as controversial as similar projects on the Channel Islands.  TC Boyle’s book foretells the Farallones project as he sends a member of the fictional project team to the Farallon Islands after completion of the project on the Channel Islands.

When the Killing’s Done by TC Boyle is not entirely fictional. (1)  It is impressively accurate in its description of the eradication projects themselves, but Boyle weaves a tight fictional plot around the key players who implemented the project and those who fought like hell to prevent it from happening.  Like other books by Boyle that I have read, When the Killing’s Done creates intense suspense that moves the reader along at top speed.  His characters are vivid and complex. 

Boyle lives in Montecito, near Santa Barbara, close to the Channel Islands.  No doubt he followed the projects closely as they were debated and resisted by opponents, who were primarily animal rights activists according to Boyle’s account.  In interviews after the publication of the book in 2011, Boyle claimed not to have a personal opinion of the projects:  “I’m not an activist in any way. With certain exceptions, I don’t think politics and art mix very well.”  He sees value in both sides of the debate and the characters in his story have much in common.  The antagonists are vegetarians who value nature and care deeply about the environment and the animals who live in it.  I believe this common ground is also true of the adversaries in the debate about the Farallones project and others like it.

However, the ending of the book suggests that Boyle doubts the ability of humans to control nature.  Although the projects on the Channel Islands were completed to the satisfaction of the land managers–National Park Service and The Nature Conservancy—the final image in Boyle’s story is of animals considered non-native on the Islands making their way to the shore of the Island.  The implication is that maybe the killing is never done and that is the crux of the problem with island eradications in general and the planned mice eradication on the Farallon Islands in particular.

Rat eradication on Anacapa Island

The aerial application of rodenticide to kill rats on Anacapa Island in 2001-2002 was the first of its kind in North America.  The project was also unique because it was complicated by the need to spare a population of endemic native mice on Anacapa.  Over 1,000 native mice were captured before the aerial application of rodenticide and released back on the island after the poison was no longer effective. 

Anacapa Island is the usual success story cited by supporters of the Farallones project where non-native mice are the target for eradication.  Native mice on Anacapa were not considered a threat to birds, but non-native mice on the Farallones are, although there is no evidence that mice actually harm birds on the Farallones either.  The operative word here is “native.”  The mice on the Farallones are targets only because they aren’t native.  The mice on Anacapa undoubtedly eat vegetation too, but that’s not considered a problem so long as they are native.   The mice on Anacapa are probably an important source of food for birds, just as they on the Farallones. 

If mice are not harmful to birds, there is no legitimate reason to poison them, along with untold numbers of non-target animals.  The mice on the Farallones are targets only because they aren’t native. 

Killing of non-target animals

Rodenticides are indiscriminate killers of warm blooded animals, including birds.  An animal who eats rodenticide slowly bleeds to death.  The grisly process of dying takes about 10-20 days.  If poisoned mice are eaten by other animals that animal is also poisoned.  It is therefore inevitable that non-target birds who are predators of mice will be killed by widespread dispersal of rodenticide pellets on the ground that can also be directly eaten by birds and other animals.  This deadly sequence of events has been demonstrated many times by island eradications using rodenticides all over the world and the project on Anacapa Island is no exception. 

Billboard sponsored by Raptors Are The Solution (RATS)

Raptors are the main predators of mice.  Therefore, 63% of raptors on Anacapa Island (37 of 59 individual birds) were captured and either relocated or kept in captivity until the project was done, according to the first study of the project published in 2005. According to that study, “The fate of the remaining birds of prey on the island is unclear. There is evidence that some birds survived the bait application… However, three barn owls, six burrowing owls and an American kestrel either died while in captivity or were found dead on the island. The American kestrel and a burrowing owl that were captured in 2001, after the bait application, likely died from brodifacoum poisoning.” The analysis of the project considers these deaths “negligible.”

A total of 94 seed-eating birds were also found dead after the poison drop.  Most were song birds, but an additional 6 birds were too decomposed to identify the species.  The study notes that these collateral kills were consistent with other similar projects.

Western Gull on Channel Islands. NPS photo

The study makes no mention of gulls that were undoubtedly killed by the project.  Gulls are omnivorous scavengers for whom dead and dying mice are ideal food, preferable to dive bombing for French fries on your picnic table.  According to the National Park Service, “Western gulls are the most abundant breeding seabird in the Channel Islands National Park, with a population estimated at more than 15,000.” Shortly after the poison drop, dead seabirds washed up on the shore near the Santa Barbara harbor.  UC Santa Barbara’s daily newspaper said, “…a strong correlation exists between the National Park Service’s most recent airdrop of pesticide on Anacapa Island and the dead birds.”

In other words, those who implemented the eradication project on Anacapa are probably not telling the full story about the death of non-target birds.  The death of hundreds of gulls is anticipated by the promoters of the project on the Farallones.  If the organization that implements the project is the same organization that monitors and reports on the project (as was the case for the projects on the Channel Islands), we may never know the actual impact on the birds living on the Farallones.

Those who promote these poisonous projects justify the death of non-target birds by saying they are “incidental” and have no lasting impact on the species population.  They will apply for and receive “incidental take permits” in advance of the Farallones project that will satisfy legal requirements of the Migratory Bird Treaty Act and the Endangered Species Act.  The lawsuit that was filed to prevent the Anacapa project was overturned on those grounds.

The killing is never done

Rat eradication on Anacapa and pig eradication on Santa Cruz (where over 5,000 pigs were shot by sharpshooters and 54 Golden Eagles were removed because they were predators of endemic foxes) are the focus of TC Boyle’s masterful book.  Both were implemented and considered successful by the organizations that implemented the projects.  Although land managers are no longer killing animals (to our knowledge) in the Channel Islands they are waging a continuous war on non-native plants by spraying them with herbicide.  When we visited Santa Cruz Island in 2010, we witnessed the application of Garlon on non-native fennel.

Roundup (glyphosate) has been used on the Farallon Islands every year since 1988.  Between 2001-2005, an average of 226 gallons of herbicide were used annually (5.4 gallons per acre per year), according to the annual report of the Farallon National Wildlife Refuge.  Given that these islands are not far from the California coast and are visited by thousands of migratory birds every year, we must expect that the arrival of new plants to the islands will be continuous: seeds are eaten and carried by birds; seeds are carried by birds in their feathers and feet; wind and storms carry seeds to the islands, etc.

The Environmental Protection Agency recently published a Biological Evaluation of glyphosate products.   EPA reports that glyphosate is “likely to adversely affect” 93% of legally protected endangered and threatened plants and animals. That finding applies equally to all plants and animals, whether they are legally protected or not because the physiological processes of species in the same order are similar.

The Environmental Impact Statement for the Farallones project accuses mice of eating vegetation, although far more vegetation is probably killed by herbicides.  Non-native vegetation arrives on the Farallones partly because birds eat it and carry it to the Farallones.  Animals do not care if edible vegetation is native.  Nativism is a human prejudice not shared by animals who seek food and shelter wherever they can find it.

The constant poisoning of plants is perhaps a trivial consideration in comparison to the futility of trying to eradicate mice.  Although rats have been successfully (leaving aside the death of non-target animals) eradicated by some projects, attempts to eradicate mice have been significantly less successful. 

A study of 139 attempted eradications on 107 Mediterranean islands in eight countries, with Greece, Italy, and Spain accounting for the highest number found that eradication projects targeted 13 mammal species. The black rat was the target of over 75% of the known attempted eradications in the Mediterranean Basin; other species targeted were feral goat, house mouse, European rabbit, and domestic cat. The most widely used technique was poisoning (77% of all eradications), followed by trapping (15%) and hunting (4%).  Techniques were largely target-specific.

The average failure rate of the projects was about 11%, but success was defined only as the death of animals living on the islands at the time of the project. However, this percentage varied according to species. The failure rate of house mouse eradication was 75%. Reinvasion occurred after 15% of eradications considered initially successful. 

Farallon Islands, NOAA

The proposed project on the Farallon Islands is a dead end in many ways.  It will kill many non-target animals. It will probably not be successful in the short run or the long run.  Every time it is repeated it will kill more animals. Furthermore, it is pointless because mice do not harm birds on the Farallon islands. 


  • T.C. Boyle, When the Killing’s Done, Viking, 2011.

California Natural Resources Agency writes a BIG blank check to the “restoration” industry

California Natural Resources Agency has published the draft of “Pathways to 30X30 California” and has invited the public to comment on the draft by February 15, 2022.  “Pathways to 30X30” is the last in a series of documents that defines the program before implementation in February 2022, when distribution will begin of $15 Billion dollars to public and non-governmental agencies to fund specific projects. 

To recap the process that began in October 2020 with the passage of an Executive Order:

  • In October 2020, Governor Newsom signed Executive Order N-82-20 “enlisting California’s vast network of natural and working lands – forests, rangelands, farms, wetlands, coast, deserts and urban greenspaces – in the fight against climate change. A core pillar of Governor Newsom’s climate agenda, these novel approaches will help clean the air and water for communities throughout the state and support California’s unique biodiversity.” The program and its implications are described by Conservation Sense and Nonsense HERE.
  • California Natural Resources Agency held a series of public workshops in summer 2021 that were theoretically an opportunity for the public to participate in the process of defining the program.  Conservation Sense and Nonsense identified potential opportunities as well as pitfalls of the program HERE.
  • California Natural Resources Agency published the first draft of implementation plans in fall 2021.  Conservation Sense and Nonsense published its favorable opinion of the first draft that is available HERE.

The draft of the final implementation document is disappointing.  My public comment on the draft of “Pathways to 30X30” is below.  To preview it briefly here, this is its concluding paragraph:  “California’s 30X30 initiative had great potential to improve the environment rather than damaging it further.  Instead, draft “Pathways to 30X30” suggests that opportunity may be squandered.  Of course, the proof will be in the projects, but for the moment it looks as though the lengthy public process may have been a charade intended to benefit the “restoration” industry, not the environment or the public.”

Please consider writing your own public comment by February 15, 2022.

  • Email: CaliforniaNature@Resources.ca.gov;
  • Letter via postal mail: California Natural Resources Agency, 715 P Street, 20th Floor, Sacramento, CA 95814;
  • Voice message: 1 (800) 417-0668.
  • There will be a virtual meeting on Tuesday, February 1, 2022, 3-6 pm in which the public will be invited to make 2 minute comments.  Register HERE.

TO:        California Natural Resources Agency

RE:         Public comment on draft “Pathways to 30X30”

I have attended the public workshops regarding the 30X30 initiative and sent written feedback when given the opportunity.  I am therefore in a position to tell you that the “Draft Pathways to 30X30” is a significant retreat from principles defined by previous drafts because it is so vague that it is meaningless. Any project could be approved within its limitless boundaries. The document puts CNRA in the position to do whatever it wishes, including violate principles defined in previous draft documents.

My public comment is a reminder of commitments made in previous drafts and a request that they be reinstated in the final version of the Draft “Pathways to 30X30” document:

  • “Pathways to 30X30” must confirm its commitment to reducing the use of pesticides on public lands.  The draft mentions the need to “avoid toxic chemicals” only in the context of working lands.  That commitment must also be made for public parks and open spaces because widespread pesticide use is exposing the public and wildlife to dangerous pesticides and killing harmless plants while damaging the soil.
  • Unlike the previous draft, “Climate Smart Strategy,” “Pathways to 30X30” requires the exclusive use of native plants, which contradicts the commitment to “promote climate-smart management actions.”  The ranges of native plants have changed and must continue to change because native plants are no longer adapted to the climate.  We cannot reduce greenhouse gas emissions causing climate change if we cannot plant tree species that are capable of surviving in our changed climate, as acknowledged by previous draft documents. As Steve Gaines said in the January 12th public meeting regarding “Pathways to 30X30,” “We must help species move [because the changing climate requires that they do].”

There are significant omissions in “Pathways to 30X30” that epitomize my disappointment in this draft:

  • The draft kicks the can down the road with respect to integrating climate change into consideration of projects funded by the initiative:  “Designations have not yet been established that emphasize climate benefits such as carbon sequestration or buffering climate impacts. While the definition of conserved lands for 30×30 builds upon existing designations, it will be important to integrate climate…” (pg 26)  Climate change is the underlying cause of most problems in the environment, yet “Pathways to 30X30” dodges the issue by declining to take the issue into consideration as it distributes millions of grant dollars to projects that are toxic band aides on the symptoms of climate change.
  • The 30X30 initiative made a commitment to protecting 30% of California’s land and coastal waters.  At 24%, we are close to that goal for land, but at only 16% we are far from the goal for coastal waters.  Yet, the draft declines to protect more marine waters:  “MPA [Marine Protected Areas] Network expansion will not be a component of meeting the State’s 30×30 marine conservation goals.” (pg 29, deeply embedded in fine print) The excuse for this omission is that the decadal review of existing MPAs won’t be completed for another year.  That is not a legitimate reason for refusing to designate new MPAs.  The evaluation of existing MPAs can and should be completed and inform the management of new MPAs going forward. 

The lack of guidance in “Pathways to 30X30” is particularly dangerous because California law has recently been revised to exempt projects considered “restorations” from CEQA requirements for Environmental Impact Reports for three years, ending January 1, 2025. An Environmental Impact Report is the public’s only opportunity to preview planned projects and challenge them within the confines of CEQA law.  The public is effectively shut out from the process of distributing millions of grant dollars of the public’s tax money by this blanket exemption on CEQA requirements for an EIR. 

The Draft of “Pathways to 30X30” writes a big blank check for projects that will potentially increase the use of pesticides on our public lands and increase greenhouse gas emissions by destroying plants and trees that sequester carbon and are capable of surviving our current and anticipated climate. 

California’s 30X30 initiative had great potential to improve the environment rather than damaging it further.  Instead, draft “Pathways to 30X30” suggests that opportunity may be squandered.  Of course, the proof will be in the projects, but for the moment it looks as though the lengthy public process may have been a charade intended to benefit the “restoration” industry, not the environment or the public. 

It’s time to comment on the deadly project on the Farallon Islands

US Fish and Wildlife proposes to aerial bomb 1.5 tons of rodenticide on the Farallon Islands to kill mice that do not harm birds, as explained in articles published earlier by Conservation Sense and Nonsense.  The California Coastal Commission declined to approve the project in 2019.  At the request of US Fish and Wildlife, the California Coastal Commission will reconsider the Farallon Islands project at their meeting on December 16, 2021.  It’s time to make your opinion of this project known to the Coastal Commission.  The Environmental Impact Statement for the project explains the project and its anticipated impacts. 

Click on this pictures of the Farallon Islands to see a video prepared by the Ocean Foundation about the islands and the proposed project.

Below is my message to the Coastal Commission. Beyond Pesticides has also provided a sample comment letter that is available HERE.   Please consider sending your own comment to the Commission here: EORFC@coastal.ca.gov. The deadline to send a written comment is 5 pm, Friday, December 10, 2021.  You can also submit a request to speak on agenda item 11b at the meeting HERE.   The deadline to request to speak is 5 pm, Wednesday, December 15, 2021. 


Update:  The project on the Farallon Islands that will aerial drop 1.5 tons of rodenticide to kill mice that have lived there for over 200 years was approved by the California Coastal Commission on December 16, 2021.  Speakers in opposition to the project did an outstanding job.  Jane Goodall recorded a message against the project.  The vote was 5-3.  Doubtful Commissioners asked some excellent questions and did not receive clear answers from US Fish & Wildlife.  As the meeting wore on over 7 hours, the project made less and less sense.  https://www.sfchronicle.com/climate/article/California-Coastal-Commission-approves-mouse-16709056.php


Dear California Coastal Commission, 

Please take my comments into consideration when evaluating the proposed project on the Farallon Islands.  I hope the Coastal Commission will confirm their lack of support of the project at your December 2021 meeting.

Thank you for your consideration.

Public Comment on Farallon Islands project

I am opposed to the plans to aerial bomb rodenticides on the Farallon Islands to eradicate mice for several reasons:

  • The project admits that hundreds of non-target birds will be killed by the rodenticide, either directly or by eating poisoned mice.  In September 2020, California banned the use of the rodenticide that will be used by this project because of the deadly impact on non-target wildlife, yet an exemption was created that will enable its use by this project.  The promoters of this project cannot deny that hundreds, if not thousands of non-target animals will be killed by this project.  That outcome is now confirmed by California State Law and by similar projects elsewhere in the world.   
  • The EIS clearly states that mice are not harming birds or chicks, the claimed beneficiaries of this project.  The EIS clearly states that a small population of burrowing owls is blamed for eating birds and chicks of other bird species. Removing the owls from the Farallon Islands is the non-toxic solution to the perceived problem. Yet, “…translocation of burrowing owls in lieu of eradicating mice was not considered as an alternative.” (pg 47)  The EIS then contradicts itself by offering translocation as mitigation for anticipated collateral bird mortality: “Migrant species including burrowing owls would be transported off the island released into suitable habitat on the mainland.” (pg 73)  Translocation is possible, but eradicating non-native mice is clearly the objective, not protecting bird species.  The mice are prey to many bird species.  Their loss will harm birds, not help them.
  • The food web on the Farallon Islands has not been adequately studied.  The project plan reports that the mice are a source of food for burrowing owls.  However, the project plan has not identified all of the predators of the mice.  Therefore, the project has not evaluated the extent to which the entire food web would be disrupted by the elimination of a major source of prey for birds of prey.  All predators of the mice are at risk of eating the poisoned mice and being killed by the poison.  Details on that issue are provided below.

These are the inadequacies of the EIS for this project:

Resident Burrowing Owls should be removed from Farallon Islands

The owls are the predators of the ashy storm petrel, not the mice.  Therefore, the owls are the obvious target for removal.  Given their small number relative to the large population of mice, their removal would be easier and less deadly to every animal living on the islands. 

This strategy was successfully used by the National Park Service to save the endangered Channel Island Fox on the Channel Islands.  Golden Eagles were not considered “native” to the Channel Islands.  They arrived in the 1990s because of feral pigs and goats that had been introduced to the islands.  When NPS took over management of the islands, they removed the feral pigs and goats, but not the Golden Eagles.  Deprived of the food the eagles came for, the eagles turned to preying on the Channel Island Fox, nearly driving it to extinction.  From 1999 to 2006, the eagles were trapped and moved off the island: “In order to mitigate golden eagle predation on island foxes, The Santa Cruz Predatory Bird Research Group, with the support of the Park Service and The Nature Conservancy, relocated golden eagles to distant sites on the California mainland. A total of 44 golden eagles, including 10 eaglets born on the islands, were trapped and relocated, and monitoring indicates that none have returned.” NPS considers the removal of eagles the primary factor in saving the Channel Island Fox from extinction.  The 44 birds that were removed were more than 4 times more numerous than the 8-10 burrowing owls on the Farallon Islands.  They are enormous carnivorous birds, compared to the pint-sized, ground-dwelling burrowing owls. 

Please note that the threat to the fox posed by Golden Eagles was created by the removal of the prey of the Golden Eagles without adequate analysis and understanding of the food web.  NPS should have predicted that the loss of the preferred prey of Golden Eagles would disrupt the food web in ways that could have been predicted.  Now other “experts” are poised to make a similar mistake at the expense of thousands of rare birds and marine mammals on the Farallons.

The Madrone Chapter of Audubon Society in Santa Rosa opposes this project and agrees that relocation of burrowing owls is “feasible and could be planned and carried out.”

Disrupting the Food Web

The EIS has not adequately analyzed the food web on the Farallon Islands and has therefore not identified the environmental impact of eradicating an important source of food for the animals that live on the island. 

This depiction of a fresh-water aquatic food web is an example of the complexity of food webs.  The food web on the Farallon Islands is probably very different, but remains largely unknown because the EIS does not analyze it or describe it.  Source:  Creative Commons-Share Alike

According to the EIS, there are many birds of prey on the Farallon Islands, most migrating, but some resident:  falcons, hawks, kites, eagles, owls, and kestrels. Most of the migrating raptors are on the island in the fall, when the mouse population is at its peak.  The EIS acknowledges that the raptors probably eat mice on the island, but dismisses that as a significant issue. However, it would be a significant factor in evaluating environmental impact if migrating raptors compensate for the loss of mice as their prey by preying on birds or salamanders.  The EIS does not address the important question of what birds of prey will eat if mice are eradicated. 

Given that mice are expected to survive for 21 days after being poisoned, and the poison is expected to be effective for over 100 days, it is more likely that many birds of prey will be killed by eating poisoned dead or dying mice. The number of days the rodenticide is expected to be effective exceeds the known limits of hazing effectiveness. For that reason, the EIS says the project will “attempt” to capture raptors present on the island prior to and during bait application.  An unsuccessful “attempt” will result in the death of raptors.

There are also many animals living on the Farallons that could eat the poison or the poisoned mice, but not killed by the poison, such as invertebrates and Dungeness crabs.  Although they are not killed, they would be contaminated by the poison they eat and become killers of the animals that eat them, such as birds and marine mammals. 

The EIS states that many of the insects that live on the Farallons are detritivores that feed on decomposing carcasses, such as the poisoned mice.  Then they become killers of the warm-blooded animals that eat them.  The Farallon Islands are located within the Dungeness crab fishery.  If they are contaminated by poison pellets or fish, they could become killers throughout the fishery.  According to the EIS, “Adult crabs are opportunistic feeders, but prefer clams, fish, isopods and amphipods. Cannibalism is common. Several species of predators feed on Dungeness crabs, especially the pelagic larvae and small juveniles, including octopuses, larger crabs and predatory fish such as salmon, flatfishes, lingcod, cabezon and various rockfishes. They are numerous in offshore areas of the Gulf of the Farallones, and support one of the most productive fisheries in California.”

A similar mistake was made by a rat eradication project on the Palmyra atoll.  The first attempt to eradicate the rats in 2002 failed partly because Palmyra’s abundant land crabs outcompeted the rodents for the poisonous bait. The crabs’ physiology allowed them to eat the poison—the anticoagulant brodifacoum—without ill effect.  The reason why this attempt failed was that the “experts” who designed this poison drop did not realize that the rats lived in the coconut palms and didn’t spend much time on the ground.  In other words, the poison wasn’t dropped where the rats lived.  The second drop was delivered to the crowns of the palms:  “The crowns became a convenient platform for stashing cotton gauze sacks of poison bait, delivered by workers firing slingshots or dangling from helicopters.”  This project is now focused on eradicating 30,000 adult palms and over 2 million juvenile palms from Palmyra using herbicide.  These island eradications have repeatedly demonstrated that they are not successful and they ultimately put land managers on a perpetual pesticide treadmill.   The result is a poisoned environment that is dangerous to every living plant and animal on the island.

Ironically, the explosion of the mouse population on the Farallons was the unintended consequence of inadequate understanding of the food web:  “House mice and other animals such as cats and rabbits were introduced to the island when ships landed there in the 19th century. While the cats and rabbits have been removed, the mice population has exploded to an estimated 60,000, or about 500 mice per acre.”  One of the primary predators of the mice was removed, which resulted in increased population of their prey, the mice.  Now USFWS proposes to eradicate the prey, which will have unintended consequences, such as the death of the predators who will eat the poisoned mice, or the predators of the mice eating bird eggs and chicks instead, or predators not having adequate food, or all of the above.   

Rodenticides are known killers of birds of prey

This article published by Beyond Pesticides explains how birds of prey are killed by rodenticides:  “While a rodent is likely to die from this poison, ingesting it also turns it into a sort of poison Trojan horse for any predator that may take advantage of its slow decline. An eagle that eats a poisoned rodent at the edge of death will be the next to succumb to the anticoagulant effects ‘Humans need to understand that when those compounds get into the environment, they cause horrible damage to many species, including our national symbol, the bald eagle,’” said the scientist who conducted a study of eagle deaths that found: “‘The vast majority of bald and golden eagles in the United States are contaminated with toxic anticoagulant rodenticides, according to research published earlier this month.’” We know that 46 bald eagles and over 420 seabirds were killed by the rat eradication attempt on Rat Island in Alaska, but we don’t know how many more were contaminated with rodenticide and are handicapped by sub-lethal effects. 

Source: Beyond Pesticides

Temporary Results

One of many reasons the mouse eradication project on the Farallon Islands is controversial is that similar projects all over the world are not successful.  Some are not successful in the short run and are immediately done again. Lehua is one of the Hawaiian Islands on which extermination was attempted and failed.  An evaluation of that attempt was published in 2011 to determine the cause of the failure so that a subsequent attempt would be more successful.  That evaluation included this report on the success of similar attempts all over the world:  “An analysis of 206 previous eradication attempts against five species of rodents on islands using brodifacoum or diphacinone is presented in an appendix to this report. For all methods, 19.6% of 184 attempts using brodifacoum failed, while 31.8% of 22 attempts using diphacinone failed. The Farallons project plans to use brodifacoum. 

Some are not successful in the long run.  Rodenticides were aerial bombed on the Lord Howe Islands in Australia in 2019 at a cost of $16 million. Two years later, two rats (one male and one pregnant female) have been found.  Genetic tests will determine if they arrived from elsewhere or are descendants of the original population. An article in The Guardian explains the elaborate effort on Lord Howe to find new rats and exterminate them.  This strategy might work on an inhabited island, such as Lord Howe, but it is not an effective strategy on the Farallons because it is not inhabited, has only occasional visitors, and its steep, rocky terrain is not easily monitored.  New mice or rats could be undetected on the Farallons long before anyone would know it. 

This is an example of one of the fundamental truths of the “restoration” industry:  The work is NEVER done.  It must be done repeatedly.  The cost is daunting, the collateral damage to non-target animals often unacceptable, the results only temporary.  The cost-benefit ratio is unfavorable.

Ethical considerations

For the record, I would like to clearly state my objection to the Farallons project.  I consider it unethical to kill one species of animal based on a presumed benefit to another animal species.  In this case, the chosen scapegoat is considered a non-native animal that has lived on the Farallon Islands for nearly 200 years and is therefore fully integrated into the food web.  There are hundreds of thousands of sea birds and mammals living on the Farallons.  They are the best testament to the fact that mice have not been harmful to birds and other animals on the Farallons.

Hundreds of non-target animals will be killed by this project because of the toxicity of the rodenticide and the random manner in which it will be applied on the island.  The project will clearly do a great deal of harm to all life on the Farallons and its benefits are obscure at best. Please do not endorse this pointless, deadly project.   


Environmental Protection Agency acknowledges that herbicides harm wildlife

“Restoration” professionals aggressively defend their use of herbicides because it is their preferred method to eradicate non-native plants.  Herbicides are the primary method of killing non-native plants because it is the cheapest method.  When the California Invasive Plant Council conducted a survey of land managers about the methods they use, they learned that 62% of those surveyed reported using herbicides regularly.  Only 6% of land managers said they don’t use herbicides.

The public usually accepts this poisoning of their parks and open spaces because they believe that wildlife benefits from the eradication of non-native plants.  Although there is little scientific evidence that supports that opinion, it is widely considered the conventional wisdom.  Now we have scientific confirmation that wildlife is harmed by the herbicides used to kill non-native vegetation.  That new evidence is the focus of today’s report on the Conservation Sense and Nonsense blog.

EPA Biological Evaluation of Glyphosate and Atrazine

The U.S. Environmental Protection Agency has published the final version of its biological evaluation of the most commonly used herbicide by the managers of our public lands, glyphosate.  EPA reports that glyphosate is “likely to adversely affect” 93% of legally protected endangered and threatened plants and animals.  EPA also published similar findings for atrazine that is available HERE. 

Source: EPA biological evaluation of glyphosate

This evaluation is the result of a long-fought battle with the EPA.  The settlement of a lawsuit brought by Center for Biological Diversity and Pesticide Action Network in 2016 required the EPA to conduct this evaluation.  A draft of the biological evaluation was published about one year ago and the final version one year later confirms the findings reported by the draft version.  Thank you CBD and PAN for your persistence!

Significance of EPA’s biological evaluation

The public tends to believe the law protects all wildlife, but that is not the case. The fact is, legal protection only applies to species designated by US Fish & Wildlife Service as threatened or endangered.  If a project is known to kill wildlife, there is no legal recourse unless the species has been officially designated as endangered or threatened. 

The more herbicide we use, the more likely wildlife is to become endangered and therefore eligible for endangered status.  Monarch butterflies are a case in point.  Their dwindling population is attributed to the widespread use of herbicides on weeds that provide nectar and pollen needed by all pollinators, including monarchs.  Monarchs and bees are also directly harmed by insecticides such as neonicotinoids.    

Hence, the EPA’s responsibility to conduct a scientific evaluation of the effect of herbicides on wildlife applied only to legally protected species.  However, it is essential to understand that the finding applies equally to all plants and animals, whether they are legally protected or not because the physiological processes of all species are similar.  For example, all legally protected amphibians are “likely adversely affected” by glyphosate, according to the EPA’s biological evaluation.  We must assume that all amphibians—whether protected or not—are also adversely affected by glyphosate.

California red-legged frogs are legally protected as an endangered species. Source: USGS
Pacific chorus frogs are not legally protected because they aren’t designated as threatened or endangered. Attribution

What’s to be done about pesticides that harm wildlife?

According to Sustainable Pulse the next official step is:  “The EPA’s evaluations now go to the U.S. Fish and Wildlife Service and National Marine Fisheries Service in the final step of the consultation process to determine what on-the-ground conservation measures are needed to minimize harm to these species and ensure these pesticides do not push any endangered species towards extinction” 

Defenders of wildlife and the public lands on which they live should not stop there.  These are the logical consequences of the fact that the most widely used herbicides should not be used on our public lands:

  • Where pesticides have been banned, they are often accompanied by exemptions for ecological “restorations.”  For example, when rodenticides were banned in California in 2020, exemptions were made for projects claiming to “restore” habitat.  When UC Berkeley banned the use of glyphosate on lawns and playing fields, they exempted glyphosate use off-campus to “restore” habitat.  When East Bay Regional Parks banned glyphosate for use in developed areas such as parking lots and picnic areas, they exempted glyphosate use to “restore” habitat.  These exemptions should be rescinded because they are harmful to wildlife living on undeveloped public land.  Wildlife does not live on parking lots and playing fields.  Wildlife lives in undeveloped areas vegetated with both native and non-native plants. 
  • The State of California recently granted a 3-year exemption from CEQA requirements for environmental impact review for projects claiming to “restore” habitat. Available HERE; see (11) This exemption should be revised so that projects that use pesticides are not eligible for exemption from CEQA requirements. 
  • Native plant advocates and “restoration” professionals must quit claiming that projects using herbicides will benefit wildlife, because clearly, they DON’T!