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!

Damnation Spring: When fact meets fiction

“It’s a vivid portrayal of the land and its people, a snapshot of a not-so-distant time…And it’s a glorious book — an assured novel that’s gorgeously told.” –New York Times

Damnation Spring is a novel based on the true history of herbicide use by the timber industry in America and elsewhere.  The story begins in the late-1970s shortly after environmental legislation started to regulate the timber industry.  At that time the timber industry had been using Agent Orange for many years to destroy the forest understory and build roads in preparation for clear-cuts as well as after clear-cuts to eliminate competition for tree seedlings.

After a century of clearcutting, this forest, near the source of the Lewis and Clark River in Clatsop County, Oregon, is a patchwork. In each patch, most of the trees are the same age. Photo by Walter Siegmund

The story takes place in a small community of loggers in Northern California.  Their employer is fighting with the federal government for permission to clear cut one of the last old growth forests in Northern California.  It’s a desperately poor community, partly because logging is a seasonal business that provides erratic employment at its best.  The dangerous work orphans many children and disables those who survive their injuries.  It is physically challenging work best performed by young men, not the community of aging loggers without any retirement benefits that would enable them to retire.  It’s a dead-end job in an all-but-dead community.

The visible threats to this community are real, but the long-term threat is less visible.  Agent Orange has contaminated the drinking water of the community.  It’s a deadly herbicide that persists in the environment and in our bodies.  It causes miscarriages and birth defects that are inherited by subsequent generations.  It causes cancer and many other sub-lethal health issues such as frequent nose-bleeds.  America’s use of Agent Orange in Vietnam has sickened, killed and disabled several generations of Vietnamese and American Veterans of the Vietnam War. 

US Army helicopter spraying Agent Orange over Vietnam. Public Domain

But Damnation Spring is a novel, so where is the drama?  The drama is created by the division between the loggers who desperately cling to their dead-end employment and their wives who have experienced repeated miscarriages, still births, and disabled children.  Many wives have experienced more loss than they can tolerate and are ready to object to the poisoning of their water by the herbicides used to facilitate logging.  Their objection is threatening to prevent the timber company from getting the approval needed to continue their clear cuts. 

The result is violent intimidation of the families who are prepared to object to the logging methods that are poisoning them.  The homes of these families are burned and they are threatened if they don’t fall into line to support the continued logging of the remaining forest.  Damnation Spring weaves this toxic mix of conflict into an engaging story with many sympathetic characters.  It is a rewarding book to read. 

Although Agent Orange is no longer used by the timber industry, the basic strategy of the timber industry remains.  Glyphosate is most commonly used by the industry to aerial spay herbicide after forests are clear cut.  The theory is that this reduces competition for the replanted forest.  Since glyphosate and other herbicides are known to damage the soil, it’s doubtful that the new forest benefits from this dousing of the ground. 

This is a familiar scenario that is not unique to the timber industry.  Coal miners are a case in point.  It’s a dangerous occupation with no future.  Yet, coal miners are as wedded to the jobs that damage their lungs as the loggers in the Pacific Northwest are to theirs.  It seems that these poor communities are unable to imagine a better future for themselves.  They resist efforts to regulate their industries.  The regulations are intended to make their jobs safer and improve their environment by reducing pollution and the global warming it causes.  Have we failed to offer them the alternatives that could improve their lives? 

Draft of California’s Climate Smart Strategy looks promising

California has made a $15 Billion budget commitment to address climate change and protect biodiversity. The California Natural Resources Agency (CNRA) held a series of workshops to explain the initiative and give the public an opportunity to provide feedback to CNRA.  Sixteen hundred Californians participated in those workshops, including me. 

California Natural Resources Agency recently published a draft of the first installment of implementation plans:  “Natural and Working Lands Climate Smart Strategy.”  The public is invited to comment on this draft.  The deadline for comment is November 9, 2021.  There are three ways you can send your comments and feedback:  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.

Update: The deadline for public comment has been extended to Wednesday, November 24, 2021.

Below is the comment that I submitted today.  I focused my attention on the portions of the draft that are relevant to my urban home, such as developed land and urban forests.  My comment may not be relevant to your concerns, so I encourage you to write a comment of our own.  If you find issues in the draft that I haven’t mentioned please post a comment here to alert other readers.


TO:  California Natural Resources Agency

RE: Public Comment on “Natural and Working Lands Climate Smart Strategy”

Thank you for this opportunity to comment on the draft of California’s Climate Smart Land Stretegy.

I find much to like in the draft of California’s Climate Smart Land Strategy.  In particular:

  • The draft makes a commitment to reduce pesticide use on public lands, for example:

Priority nature-based solutions for developed lands: 

“low-chemical management of parks and open spaces in and around cities to beneft underserved communities who are often the most negatively affected by health impacts related to air pollution and extreme heat caused by urban heat islands.”

“Prioritize protection of public safety by ecologically treating vegetation near roads and energy infrastructure.”

“Utilize safer, more sustainable pest management tools and practices to combat invasive species and accelerate the transition away from harmful pesticides.”

  • The draft makes a commitment to expanding, maintaining and preserving urban forests:

Priority nature-based solutions for developed lands: 

“Increase development and maintenance of both urban tree canopy and green spaces to moderate urban heat islands, decrease energy use, and contribute to carbon sequestration.”

“Maintain urban trees to provide vital ecosystem services for as long as feasible”

  • The State of California defines the urban forest broadly and the draft acknowledges its importance in climate smart land management:

“California Public Resources Code defines urban forests as “those native or introduced trees and related vegetation in the urban and near‐urban areas, including, but not limited to, urban watersheds, soils and related habitats, street trees, park trees, residential trees, natural riparian habitats, and trees on other private and public properties.”  Urban forests are our opportunity to apply climate smart land management in the places most Californians call home. The character of urban forests is diverse, which heavily influences the localized selection of management options and outcomes related to both carbon storage and co-benefits.”

  • The draft acknowledges that suitability to a specific location and climate are the appropriate criteria for planting in the urban forest.  Because native ranges are changing in response to changes in the climate, whether or not a tree is native to a specific location is no longer a suitable criterion.

Utilize place-based tree and plant selection and intensity, to ensure the species selection process considers climate, water, and locally-specific circumstances.”

  • The draft acknowledges the importance of forests to maintain carbon sinks to reduce greenhouse gas emissions that cause climate change.  The urgent need to address climate change must trump nativists’ desire to replicate treeless historical landscapes. 

“Healthy forests can serve as reliable carbon sinks, both because they are able to store significant amounts of carbon and because they are at a lower risk of carbon loss due to climate impacts such as wildfire and drought. After large, high-severity fires, some of California’s forests may convert to shrublands and grasslands59 that are not capable of supporting the same level of carbon storage as forests.

“…shrublands and chaparral store substantially less carbon, and the dynamics of their growth and disturbance are less well known. Evidence indicates that shrublands in California are burning more frequently than they would have historically, leading to degraded conditions, possible conversion to grasslands, and reduced carbon storage in above ground biomass.”

Making these commitments operational implies that the State must also make these commitments:

  • The State of California should not fund projects that destroy healthy trees for the sole purpose of replicating treeless historical landscapes, especially on developed lands.
  • The State of California should not fund projects that destroy functional landscapes and healthy trees, particularly by using herbicides.

Suggested improvements in the draft

These commitments in the draft should be revised:

Implement healthy soils practices, including through native plant landscaping and mulch and compost application.”

The word “native” should be deleted because the nativity of a plant is irrelevant to soil health.  Introduced plants do not damage soil, but using herbicides to kill them does damage the soil by killing beneficial microbes and mycorrhizae.   

“Increase drought-tolerant yards and landscaping through, for example, native plant species replacements and lawn removal and by adopting, implementing and enforcing the State’s Model Water Efficient Landscaping Ordinance.”

The word “native” should be replaced by “drought-tolerant,” which would include many native species, but not all.  Redwoods are an example of a native tree that is definitely not drought-tolerant.  Many species of drought-tolerant plants have been introduced to California from other Mediterranean climates that are well adapted to our climate and the anticipated climate in the future.

California’s urban forest is predominantly non-native because these are the tree species that are adapted to our climate and can survive harsh urban conditions. Professor Matt Ritter of CalPoly is the source of these data. He presented this slide at a conference of the California Urban Forest Council on October 14, 2021.

Where appropriate and applicable, Departments should rely on the Class 33 categorical exemption for small habitat restoration projects in the CEQA Guidelines”

Such exemptions should not be granted to projects that will use pesticides because they will damage the environment, including the soil, and the wildlife that lives there.  Such a specific limitation is consistent with commitments in the draft to reduce pesticide use in parks and open spaces around cities because those are the places where such small projects (5 acres or less) are likely to be proposed.  Such a limitation on the use of this exemption to CEQA requirements should be added to the final draft because it does not explicitly exist in the code.

The importance of setting priorities

The strength of the draft is its emphasis on addressing the sources of climate change.  All projects funded by this initiative must be consistent with that over-riding mission because climate change is the primary threat to all ecosystems. Reducing the sources of greenhouse gases causing climate change is a prerequisite for protecting biodiversity.

I appreciate the mention of opportunities to remediate brownfields, but I believe a broader commitment to addressing sources of pollution is needed:

“Ensure brownfield revitalization supports community efforts to become more resilient to climate change impacts by incorporating adaptation and mitigation strategies throughout the cleanup and redevelopment process. These efforts also increase equity, as many climate vulnerable communities live close to brownfields and other blighted properties.”

Julie Bargmann was recently awarded the Oberlander Prize in Landscape Architecture for her ground-breaking work to bring blighted land back to useful life in the heart of post-industrial cities. Her work is unique because it transforms abandoned industrial land into beautiful public space while honoring and preserving its history.  She brings new meaning to the word “restoration.”  She does not begin by destroying functional landscapes.  She provides a model for a new approach that is particularly important to underserved inner-city communities.  I live in Oakland, where I see many such opportunities to restore public land to useful life without the scorched-earth strategies commonly used by ecological “restorations.”

Julie Bargmann projects. Source: NPR News Hour

When ecological restorations are funded without addressing sources of pollution, valuable resources are often wasted.  The recent oil leak from an oil platform off the coast of Southern California is a case in point.  Millions of dollars were spent restoring a wetland that was doused with oil for the second time. Yet, some of the oil platforms in California waters are no longer productive, but have not been safely decommissioned.  This is putting the conservation cart before the horse. 

Talbert Marsh. Source: Huntington Beach Wetland Conservancy

We are about to make enormous investments in the expansion of wetlands, as we should.  At the same time, we should address the sources of pollution that will despoil those wetlands, such as many miles of impaired waters in the watersheds that drain into the wetlands.  For example, the draft touts seagrasses as carbon sinks and acknowledges pollution as one of the major threats to seagrass:  “The leading causes of seagrass loss are nutrient pollution, poor water clarity, disease, and disturbance.”

At every turn, climate smart solutions should stay focused on the underlying causes of problems in the environment, rather than cosmetic solutions that don’t address those causes.  Quibbling about whether or not marsh grass is native or non-native is like arguing about the color of the lifeboat. Let’s focus on whether or not a landscape is functional as a carbon sink.

In conclusion

The draft gives me hope that the State of California can do something useful with our tax dollars to address climate change without damaging the environment further.  The draft shows the influence of learned hands with good intentions.  Now let’s see specific projects funded that are consistent with the goals defined by the draft.  That’s where the rubber meets the road.