Category: Herbicides/Pesticides

Response to Nature in the City

Nature in the City (NIC) is one of many organizations that support native plant “restorations” in San Francisco as well as the principle entity which engages in them, the Natural Areas Program (NAP) of the Recreation and Park Department.  NIC is consistently critical of anyone who questions the value of these restorations, but in their most recent newsletter they confront our objections directly.  Although we don’t presume to represent the many constituencies which are critical of the Natural Areas Program, we are responding in this post to NIC based on our knowledge of the issues. (The NIC newsletter is in quotes and is italicized.  Our response is not italicized.)

“Natural Areas in 2012

Last fall saw the the [sic] Planning Commission public meeting for the Draft Environmental Impact Report (DEIR) for the Significant Natural Resource Areas Management Plan.  Some time later this year, the City will issue a Final Environmental Impact Report, which may be appealed by opponents of the Natural Areas Program.

Unfortunately, a handful of people are still propagating misinformation about the rationale, values, and intention of ecological restoration, management and stewardship, and of the City’s celebrated Natural Areas Program.”

Webmaster:  Critics of the Natural Areas Program cannot be described accurately as a “handful of people.”  We now have four websites(1) representing our views and there have been tens of thousands of visits to our websites.  Comments on our websites are overwhelmingly supportive of our views. Our most recently created website, San Francisco Forest Alliance, lists 12 founding members.  That organization alone exceeds a “handful of people.”

Our objections to the Natural Areas Program have also been reported by three major newspapers in the past month or so (San Francisco Examiner, Wall Street Journal,  Sacramento Bee).

 Many critics of NAP have been engaged in the effort to reduce its destructive and restrictive impacts on our parks for over 10 years.  Scores of public meetings and hearings have been held to consider our complaints.  We consistently outnumbered public speakers in support of NAP until 2006, when the NAP management plan was finally approved by the Recreation and Park Commission.  Although we were outnumbered for the first time, there were over 80 speakers who asked the Recreation and Park Commission to revise NAP’s management plan to reduce its negative impact on our parks.

The public comments on the NAP DEIR are the most recent indicator of the relative size of the groups on opposite sides of this issue.  These comments were submitted in September and October 2011.  We obtained them with a public records request.  The Planning Department reported receiving about 400 comments.  In analyzing these comments, we chose to disregard about half of them because they were submitted as form letters, even though they were from dog owners who were protesting the loss of their off-leash privileges in the natural areas.  We also leave aside the comments from golfers whose only interest is in retaining the golf course at Sharp Park.  In other words, we set aside the majority of the comments critical of the NAP management plan in order to focus on those comments that demonstrate a comprehensive understanding of the impact of NAP on the city’s parks.  Of the comments remaining, those critical of NAP and its deeply flawed DEIR outnumbered comments in support of the NAP DEIR about three to one.  We urge NAP supporters to read these public comments to learn about the wide range of criticisms of NAP, including pesticide use, destruction of trees, recreational access restrictions, loss of wildlife habitat and more. 

We will challenge NIC’s accusation that we are “propagating misinformation” within the context of their specific allegations:

“Contrary to the many myths that continue to percolate, the Natural Areas Plan and Program seek to do the following (among other worthwhile endeavors):

1.       Protect and conserve our City’s natural heritage for its native wildlife and indigenous plant habitats and for the overall health of our local ecosystem;”

Webmaster:  Since the majority of acreage claimed as natural areas by NAP 15 years ago had no native plants in them, there is little truth to the claim that NAP is protecting our “natural heritage.”  The so-called “natural area” at Balboa and the Great Highway is typical of the “natural areas.”  There is photographic evidence that it was built upon for about 150 years.  It was the site of Playland by the Beach before it was designated a “natural area.”  Sand had to be trucked onto the property and disked down 18” into the construction rubble, then shaped into dunes by bulldozers before native plants could be planted on it. 

Natural Area at Balboa & Great Highway under construction

We don’t make any distinction between “native wildlife” and any other wildlife currently living in our city.  We value them all.  Most are making use of existing vegetation, whether it is native or non-native.  They do not benefit from the loss of the blackberries that are their primary food source or the loss of the thickets or trees that are their homes.  We do not believe that wildlife in San Francisco benefits from the destructive projects of the Natural Areas Program.  See photos of insects, birds, and other wildlife using non-native plants in the natural areas here.

Damselflies mating on ivy, Glen Canyon Park

We do not think an ecosystem that has been sprayed with herbicides qualifies as a “healthy ecosystem.”  NAP sprayed herbicides at least 86 times in 2011.  Their use of herbicides has increased over 330% in the last 4 years.  NAP uses herbicides that are classified as more toxic than those most used by other city departments.  Last spring, 1,000 visitors to Glen Canyon Park signed a petition, asking the Natural Areas Program to stop using pesticides in their park.  This petition was given to Scott Wiener, the Supervisor representing the district in which Glen Canyon Park is located.

These are statements of fact that can be easily verified by the public record.

2.       “Educate our culturally diverse city about the benefits of local nature and about helping with natural areas stewardship in your neighborhood;”

Webmaster:  Although we value education, we do not consider the staff of NAP and/or its supporters qualified to provide it.  We hear them make statements that are demonstrably not true, such as “grassland stores more carbon than trees.”  We see them spray herbicides in the dead of winter that are supposed to be sprayed in the spring when the plants are actively growing.  We watch them plant things where they won’t grow, such as sun-loving plants in deep shade and plants in watersheds where they will soon be drowned by seasonal rains.

And we also have had bad experiences with the volunteers who are called “stewards” by NAP, but sometimes act more like vandals.  We see them spraying herbicides that they aren’t authorized to use.  We see them hacking away at trees that haven’t been designated for removal.  NAP is not providing the necessary guidance and supervision to the volunteers many of whom seem to consider themselves the de facto owners of the parks. 

3.       “Manage the City’s wildlands for public access, safety and the health of the “urban forest.””

Webmaster:  We do not oppose the removal of hazardous trees.  However, we also know that most of the trees that have been designated for removal by the NAP management plan are NOT hazardous.  They have been selected for removal solely because they are not native and are perceived to be obstacles to the reintroduction of native plants.  Claims to the contrary are inconsistent with the management plan as well as our experience in the past 15 years.  (Watch video about the destruction of 1,600 trees over 15 feet tall planned for Mt. Davidson.)

“We hear occasional complaints about public access and tree removal. Three simple facts are thus:

1. Every single natural area in the City has at least one trail through it, where one can walk a dog on a leash;”

Webmaster:  The loss of recreational access in the natural areas is real, not imagined.  The following are verbatim quotes from the NAP management plan:

  • “Approximately 80 percent of the SFRPD off-leash acreage is located within Natural Areas.” (page 5-8).  The NAP DEIR proposes to close or reduce the size of several off-leash areas.  The DEIR provides no evidence that these areas have been negatively impacted by dogs.  It also states that all off-leash areas in the natural areas are subject to closure in the future if it is considered necessary to protect native plants.  Since NAP has offered no evidence that the proposed immediate closures are necessary, one reasonably assumes it will offer no evidence if it chooses to close the remainder of the 80% of all off-leash areas in San Francisco located in natural areas.  We know from the DEIR public comments that NAP supporters demand their closure.
  • “Public use in all Natural Areas, unless otherwise specified, should encourage on-trail use… Additionally, interpretive and park signs should be installed or modified as appropriate to include “Please Stay on Trails” with information about why on-trail use is required.”  (page 5-14)   In other words, the only form of recreation allowed in the natural areas is walking on a trail.  Throwing a ball or frisbee, having a picnic on the grass, flying a kite, climbing the rocks are all prohibited activities in the natural areas.  And in some parks, bicycles have been prohibited on the trails by NAP. 
  • “Finally, this plan recommends re-routing or closing 10.3 miles of trail (approximately 26 percent of total existing trails).” (page 5-14)  So, the only thing visitors are allowed to do in a natural area is walk on the trails and 26% of all the trails in the natural areas will be closed to the public.

2. “The act of removing (a small subset of) non-native trees, e.g., eucalyptus, that are in natural areas has the following benefits:
   a. Restores native habitat for indigenous plants and wildlife;
   b. Restores health, light and space to the “urban forest,” since the trees are all crowded together and being choked by ivy;
   c. Contributes to the prevention of catastrophic fire in our communities.”

Webmaster:  Destroying non-native plants and trees does not restore indigenous plants and wildlife. Native plants do not magically emerge when non-native plants and trees are destroyed. Planting indigenous plants might restore them to a location if they are intensively gardened to sustain them.  However, in the past 15 years we have seen little evidence that NAP is able to create and sustain successful native plant gardens.  Native plants have been repeatedly planted and they have repeatedly failed. 

NAP has not “restored” the health of the urban forest.  They remove trees in big groups as they expand their native plant gardens.  They are not thinning trees.  They are creating large openings for the grassland and dune scrub that they plant in the place of the urban forest.  Every tree designated for removal by the NAP management plan is clearly selected for its proximity to native plants.  It is disingenuous to suggest that NAP’s tree removal plans are intended to benefit the urban forest.

Of all the fictions fabricated by native plant advocates to justify the destruction of our urban forest, the claim that its destruction will “prevent catastrophic fire” is the most ridiculous.  The native ecology of California is highly flammable.  Most fires in California are in native chaparral.  According to San Francisco’s hazard mitigation plan, there has never been a wildfire in San Francisco (2) and one is unlikely in the future because the climate is mild and moist.  When it is hot in the interior, it is foggy in San Francisco.  The hot winds that drive most fires in California never reach San Francisco because it is separated from the hot interior by the bay.  San Francisco is surrounded by water, which moderates its climate and virtually eliminates the chances of wildfire. The tall non-native trees precipitate moisture from the summer fog, which moistens the forest floor and reduces the chances of ignition.  In the unlikely event of a wind-driven fire, the trees provide the windbreak which would stop the advance of the fire. 

3. “The overall visual landscape of the natural areas will not change since only a small subset of trees are planned to be removed over a 20-year period.”

Webmaster:  In addition to the 18,500 trees over 15 feet tall which NAP proposes to destroy, the NAP management plan also states its intention to destroy non-native trees less than 15 feet tall.  In other words, the future of the forest will also be killed.  The intention is to eliminate the urban forest in San Francisco’s parks over the long term.  Yes, this will take some time, but the long-term intention to eliminate the forest is clear.

“Please feel free to email steward@natureinthecity.org if you would like more clarification about the intention, values and rationale of natural resources management.”

Webmaster:  We urge our readers to take NIC up on this offer to provide  ”more clarification” of its spirited defense of the Natural Areas Program. 

  • Do you think NIC is deluded about there being only a “handful of people” that are critical of the Natural Areas Program?
  • Did you notice that NIC does not acknowledge the use of herbicides by NAP?  Do you think that a fair representation of criticism of NAP can omit this issue?
  • If you visit a park that is a natural area, do you think NAP has demonstrated in the past 15 years what NIC claims it is accomplishing?
  • Do you think NIC has accurately described recreational access restrictions in the natural areas?
  • Do you think that San Francisco’s urban forest will be improved by the destruction of 18,500 mature trees and countless young trees?

(1) Save Sutro Forest, Urban Wildness, San Francisco Forest Alliance, Death of a Million Trees

(2) “The California Department of Forestry and Fire Protection (CAL FIRE) has no record of any wildfire in San Francisco.” San Francisco Hazard Mitigation Plan, 2008, page 5-18.

Ivy Eradication: A Comedy of Errors

When the concert meadow in San Francisco’s Stern Grove was renovated in 2005, at a cost of $15 million, we were surprised that ivy was planted as the ground cover because ivy grows rampant in Stern Grove, shrouding many of the trees.  But, hey!  Who are we to question the choices of horticultural professionals? 

Ivy planted in Stern Grove, 2005

Now ivy is being sprayed with herbicide–presumably with the intention of killing it–by San Francisco’s Natural Areas Program in other parks in San Francisco, so one wonders if the staff who plant it are aware of the future of the ivy they plant.  Seems like another case of man creating problems which he then must solve.  Perhaps full employment is the objective, rather than the creation of a beautiful garden.  But we digress.

Ivy climbing trees in Stern Grove

Combining pesticides

Many members of the public are of the opinion that all pesticide (herbicides, insecticides, etc.) applications are inappropriate in a park that has been designated as a “natural area.”  Last year, the public complained about the spraying of Garlon in the natural areas by the Natural Areas Program because it is classified by the city’s Integrated Pest Management (IPM) policy as “Most Hazardous.”  Consequently, the Natural Areas Program significantly reduced its use of Garlon in 2011. 

For the most part they have substituted a mixture of glyphosate and imazapyr for Garlon. Is this an improvement?  Maybe not.  Although glyphosate and imazapyr have a lower hazard rating of “More Hazardous,” the Natural Areas Program increased their pesticide applications in 2011 at least 20% compared to 2010.  But more importantly, little is known about the toxicity of imazapyr and nothing is known about the toxicity of combining glyphosate and imazapyr.(1)  Imazapyr was approved for use in California in 2005, so only the minimal tests required by law have been done on it.

The manufacturer’s labels for these herbicides suggest that combining them is not an approved use.  The label for Aquamaster (glyphosate) does not include imazapyr on the list of pesticides with which it can be safely combined.  And the Polaris (imazapyr) label says it should not be combined with another pesticide unless it is expressly recommended by the manufacturer of that pesticide.

The “Aquatic Pesticide Application Plan for the San Francisco Estuary Invasive Spartina Project” is cited by San Francisco’s IPM program as the evaluation upon which it based its decision to add imazapyr to the list of pesticides approved for use in San Francisco in 2010.   The evaluation explained why imazapyr is being combined with glyphosate by the non-native Spartina eradication project. 

Imazapyr is apparently slow acting.  It can take some months before it kills the plant on which it is sprayed.  Glyphosate, on the other hand, is fast acting.  The plant on which it is sprayed begins to yellow and die within a few weeks.  Glyphosate is therefore used by the Spartina eradication project to provide quicker feedback to those spraying the herbicide.  They know within a few weeks if they have sprayed in the right place.  They don’t have to wait for the next season to spray again if necessary. 

Pesticide Application Notice, Glen Canyon Park, December 2011

 However, glyphosate should be applied to perennial broadleaf plants during their reproductive stage of growth, when they are budding in the late spring and summer, according to the manufacturer.  In Glen Canyon Park, a mixture of glyphosate and imazapyr was sprayed on ivy in December 2011, clearly not the recommended time period for spraying.  A month later, there is no indication that the ivy was damaged by this spraying.  This suggests that there was no point in combining glyphosate and imazapyr in this application.  The public was exposed to the unnecessary risk of combining these herbicides, with no potential benefit of taking that risk.

 

Pesticides accumulate and persist in the soil

Was it appropriate for the city’s IPM program to use the evaluation of imazapyr for the Spartina project as the basis of their decision to approve its use by the Natural Areas Program?  We don’t think so.  The circumstances of the Spartina project are substantially different from those of its use by the Natural Areas Program.

Imazapyr is used to eradicate non-native Spartina in a tidal estuary.  For that reason the evaluation of its use assured the public that this herbicide would not accumulate in the environment because it would be flushed away from the ground by the tide twice each day. 

The evaluation also said that when imazapyr was used in a pond or stable water source, it persisted in the ground for a longer period of time.  In fact, that’s exactly how imazapyr is being used by the Natural Areas Program.  It has been used at Lake Merced and at Pine Lake, both stable water sources.  It is also being used in Glen Canyon Park, which is a watershed. 

We don’t assume that imazapyr is being used safely to eradicate Spartina.  However, even if it is, it does NOT follow that it is safe for use in watersheds that are not tidal, such as those being sprayed by the Natural Areas Program. 

Collateral damage of pesticides

Glyphosate is a non-selective herbicide.  That is, it kills any plant it is sprayed on at the right stage of its growth.  But imazapyr is far more insidious as a killer of plants because it is known to travel from the roots of the plant that has been sprayed to the roots of other plants.  For that reason, the manufacturer cautions the user NOT to spray near the roots of any plant you don’t want to kill.  For example, the manufacturer says explicitly that imazapyr should not be sprayed under trees, because that tree is likely to be killed, whether or not that was the intention. 

Pesticide Application Notice under willow trees in Glen Canyon Park, December 2011

Much of the ivy that was sprayed by the Natural Areas Program in Glen Park in December 2011 was sprayed under willow trees.  The willow trees are native, so it seems unlikely that they intended to kill them.

Resistance to pesticides

The Federal Drug Administration recently banned some use of antibiotics in domesticated animals because the bacteria antibiotics are intended to kill are developing resistance to the antibiotics.  This resistance is becoming increasingly dangerous to humans who are also the victims of those bacteria.  Antibiotics are being rendered useless by overuse on domesticated animals.  When humans need them, they won’t work because bacteria have developed a resistance to them.

Likewise, plants and animals are also capable of developing resistance to pesticides.  Glyphosate is the most heavily used herbicide in agriculture.  Recent research indicates that weeds are developing resistance to glyphosate. 

The manufacturer of imazapyr says explicitly that repeated use of this herbicide is likely to result in resistance to it over the long term:  “When herbicides with the same mode of action are used repeatedly over several years to control the same weed species in the same application site, naturally occurring resistant weed biotypes may survive…propagate and become dominant in that site.”   So, does it make sense to use imazapyr on a plant as persistent as ivy? 

The GGNRA reported spending $600,000 over 3 years trying to eradicate ivy from 127 sites.  They were successful in only 7 of the sites.(2)  Obviously eradicating ivy is not a one-shot deal.

If ivy must be eradicated, pesticides do not have to be used to do it.  The Audubon Canyon Ranch in Bolinas Lagoon reported “qualified” success using hand-pulling methods on 5 acres over 5 years “utilizing 2375 volunteer hours.”  Biannual monitoring of resprouts will be required for the foreseeable future.  It’s a big commitment, but at least it is safe. 

All risk, no reward

Congratulations to any reader with the patience to slog through this tedious list of apparently incompetent use of pesticides by San Francisco’s misnamed Natural Areas Program.  We reward your persistence with this summary:

  • Combining pesticides is risky business because the toxicity of such combinations has not been tested.  Therefore, when there is no benefit in doing so, these combinations should be avoided.
  • A pesticide that is appropriate for one purpose is not necessarily appropriate for another.  In this case, imazapyr may not accumulate and persist in a tidal estuary, but it is more likely to do so in a stable watershed.
  • The Natural Areas Program may be killing plants it does not intend to kill by using herbicides indiscriminately.
  • Herbicides should not be used repeatedly on the same plants in the same locations because the plants will develop resistance to those herbicides. 
  • If the Recreation and Park Department is planting ivy in one park and destroying it another, could it be such a bad plant that it is worthwhile to expose the public to toxic pesticides?  We don’t think so, but if we are wrong, then ivy should be removed by hand without using pesticides.

(1) “Aquatic Pesticide Application Plan for the San Francisco Estuary Invasive Spartina Project,” August 2010, page 32.

(2) Liston, Heather, “Reuniting old adversaries can beat back exotic invaders,” California Wild, Winter 2006

Bowling Alone with the Sierra Club

In 2000 Robert Putnam’s (Harvard University) masterpiece of American social science, Bowling Alone* was published.  He reported the significant decline of all forms of civic participation in American society and politics from the P.T.A. to voting.  Religious participation is the notable exception to this trend. 

We are deeply concerned about the increasing isolation of Americans from one another and we believe that the polarization of viewpoints, particularly in politics, is one of the consequences of this trend.  Only the highly motivated extremes of opinion are still engaged in the civic dialogue.  The middle ground is no longer represented in the debate.  However, we will focus on the topic that is relevant to Million Trees, that is, the implications for the environmental movement. 

Bowling Alone. Attribution: Xiaphias

Membership in environmental organizations reached its peak in 1995, according to Bowling Alone after decades of enormous growth since the 1960s.  This peak was consistent with public opinion regarding environmentalism.  In 1990 three-quarters of Americans considered themselves “environmentalists.”  By the end of the decade, that percentage had dropped to only 50%. 

The growth in membership was achieved by the use of a new marketing tool known as direct mail.  Think about it.  How many invitations do you receive in the mail from non-profit organizations, asking you to contribute to a wide-range of worthy causes?   Typically these organizations spend between 20-30% of their budgets on such fund raising and the rate of return on these solicitations is only 1-3% of the cost depending upon the quality of the mailing list.  Using this technique, Greenpeace tripled its membership between 1985 and 1990 to 2.35 million.

What does “membership” mean?

After tripling its membership, Greenpeace lost 85% of its members in the next 8 years.  The drop-out rate after the first year is typically 30% in these organizations.  

In fact, most contributors to these organizations don’t even consider themselves “members” in the usual sense of that word.  The commitment to the organization doesn’t extend far beyond writing a check.  Only 8% of contributors to the Environmental Defense Fund, for example, described themselves as “active” in the organization. 

These organizations are therefore distinctly different from their historical antecedents.  Participants in the civil rights movement frequently put their lives on the line.  The social lives of Rotary Club members revolved around the Rotary lodge. 

Since few people are active participants in environmental organizations, they have become “bureaucratized,” meaning they are run by and for paid professionals.  Most members have little idea what policies the professional staff has adopted on their behalf. 

The Sierra Club

In 1989, a survey of Sierra Club members determined that only 13% of its members had attended even one meeting of the Sierra Club.  The Bay Area Chapter of the Sierra Club claims to have 10,000 members, but chapter leadership of a group (the chapter is broken into many geographical groups, such as the San Francisco Group)was elected by as few as 59 votes.  The top vote-getter in the Club’s most recent election received 327 votes in a Chapter-wide race, but only one chapter group (Northern Alameda County) had more candidates than there were available seats.  In other words, there was no competition for most of the leadership seats. 

Yet, the incumbents in these leadership positions are free to determine the local policies of the Sierra Club.  Here are a few recent examples of positions taken by the Bay Area Chapter of the Sierra Club:

The opinion of the membership is not asked when these policy positions are taken by the leadership.  However, if members read the chapter’s quarterly newsletter (The Yodeler) they have the opportunity to learn about them after the fact.

The influence of the Sierra Club

We believe that the influence of the Sierra Club exceeds the size of its membership.  The Sierra Club endorses candidates for political office.  These endorsements are highly sought after because politicians believe that the endorsement confers the votes of its membership.  This belief was recently tested in the race for mayor of San Francisco. 

State Senator Leland Yee sought and received the endorsement of the Sierra Club in his bid for mayor of San Francisco.  In the past, he had been critical of the Natural Areas Program.  His stated reason for that criticism was that the veneration of native plants was offensive to his roots as an immigrant.  In particular, the Chinese community suffered horrendous discrimination in California in the 19th Century.  The rhetoric of the native plant movement is reminiscent of the xenophobia from which the Chinese community has suffered historically. 

It seems unlikely that Senator Yee’s emotional reaction to nativism changed when he sought the endorsement of the Sierra Club, but he had to disavow that opinion in order to receive the Club’s endorsement.  He did so because he believed that the votes of Sierra Club members would help him to be elected mayor of San Francisco.  His bet did not pay off.  He did not win.  In fact, he came in fourth. 

We hope that political candidates in the future will heed this warning.  The Sierra Club may have many “members” but that membership does not necessarily confer votes.  The vast majority of “members” have no commitment to the policy positions taken by the Club.

An appeal to Sierra Club members

There were over 4,000 public comments on the Environmental Impact Study for the Dog Management Plan of the Golden Gate National Recreation Area (GGNRA).  The Dog Management Plan proposes to eliminate about 80% of existing off-leash areas, which are now only 1% of the 74,000 acres of GGNRA property.  The Sierra Club supports that plan.  There were thousands of comments from people with dogs who are presently enjoying the small areas now available to them for off-leash recreation.  Sixty-four of those people said they are Sierra Club members.  That’s enough members to elect someone to a leadership position in the Club.

If you are a member of the Sierra Club, here’s what you can do to influence the Club’s policies:

  • Inform yourself of the policies of the Sierra Club. 
  • If you don’t agree with those policies, we urge you to vote in the election of officers to the leadership positions in the Sierra Club.
  •  If you don’t know the policies of the candidates, ask them. 
  •  If there are no candidates that represent your viewpoint, find candidates who do.
  • If you can’t find a candidate you can support, it’s time to vote with your feet.
  • If you leave the Club tell them why. 

Quit Bowling Alone!

Attribution: GNU Free Documentation

*Putnam, Robert, Bowling Alone:  The Collapse and Revival of American Community, Simon & Schuster, New York, 2000.  All quotes in this post are from Bowling Alone unless otherwise noted.

Nativism is shooting us in the foot

A few months ago, we told you about one of the many projects to eradicate a plant species that is considered non-native.  In this case, smooth cordgrass (Spartina alterniflora) is native to the East and Gulf coasts of the US, but is considered non-native on the West Coast, despite the fact that it has been here for over one hundred years.  About $12 million was spent in the past 10 years on this effort, and the projection is that another $16 million will be spent in the next 10 years.

California Clapper Rail. British Wikipedia

When we told you about this project, we speculated that it was having a negative effect on an endangered species, the Clapper Rail.  The non-native Spartina provides cover that is superior to the native variety of Spartina.  It grows more densely and it doesn’t die back during the winter months, as the native variety does.  We also pointed out that the Clapper Rail is abundant on the East and Gulf coasts and is only considered endangered on the West Coast. 

Since we told you about this eradication project, we’ve learned a few things about the Clapper Rail that we hope will interest you, as it does us. 

  • This seems to be another case in which native plant advocates are looking for a scapegoat, when they should be looking at themselves.  Native plant advocates would like you to believe that the Clapper Rail is endangered on the West Coast because of the introduction of non-native red fox.  The red fox is yet another creature that nativists wish to eradicate in the Bay Area.  Apparently it has not occurred to them that the red fox is native to the East Coast, where the Clapper Rail is thriving.  Hmmm, that seems like a bit of contradiction, No?
  • We have learned of the displacement of Clapper Rails from marshes in which the non-native Spartina in being eradicated.
  • The Point Reyes Bird Observatory, a nationally recognized institution that conducts research on birds, has concluded that the Spartina eradication project is having a negative effect on the Clapper Rail.

Evidence that eradication of Spartina alterniflora is harmful to Clapper Rails

In July, a Clapper Rail was seen and photographed at Heron’s Head in southeastern San Francisco.  There was quite a bit of excitement about this sighting because a Clapper Rail had not been seen in San Francisco for decades.  That excitement dissipated when we learned more about where this bird came from, which provided a probable reason for the move. 

The Clapper Rail was wearing a radio collar that had been put on him and 109 other rails by the USGS to track their movements.  He had moved from Colma Creek, 11 km south of Heron’s Head, which is one of nearly 200 Spartina “control sites” in the San Francisco Estuary.  The bird sighted at Heron’s Head is one of three Clapper Rails that have left Colma Creek since 2007, when the radio collars were placed.  The Spartina control project has been going on for nearly 10 years, so we have no way of knowing how many Clapper Rails were displaced prior to 2007.

In October 2011, the Point Reyes Bird Observatory issued the first-ever “State of the Birds Report for San Francisco Bay:”  “Based on decades of monitoring, 29 partners detail the actions needed to keep birds and their habitats thriving as sea levels rise and extreme storm events increase due to global climate change.”  This report acknowledges the role that the Spartina eradication project plays in the continuing decline of the population of Clapper Rails in the Bay Area:

“The Clapper Rail’s rebound during the 1990’s was possibly due to fox control but also coincided with the rapid invasion of a tall non-native plant (invasive Spartina).  This invader benefited rails because it provided nesting habitat and protection from predators and high tides.  Beginning in the mid-2000s, the rail population declined sharply, due in part to the removal of invasive Spartina, which threatens tidal flat and marsh ecosystems as a whole.  This recent decline may be leveling off, but the future of Clapper Rails in San Francisco Bay remains tenuous.”

This is another example of the harmful obsession with non-native plants, which seems to trump other considerations, such as the welfare of the animals that benefit from the plants.  As is often the case with such eradication projects, Spartina is being eradicated with an herbicide, imazapyr.  This is a new herbicide about which little is known.  The analysis which was done to justify its use in the Spartina eradication project admits that no studies have been done on its effect on shorebirds, including the endangered Clapper Rail.  The Material Safety Data Sheet mandated by the Environmental Protection Agency tells us that imazapyr is “not readily biodegradable.”  So, in the event that we eventually learn that this herbicide is harmful to shorebirds and/or to us, we can be assured that it will still be in the environment, in the nearly 200 sites in the San Francisco Estuary on which it is currently being sprayed.  Imazapyr is also being sprayed–sometimes from helicopters–in hundreds of places along the West Coast, including in other states.  (A new post on Save Sutro reports more alarming information about imazapyr.)

The cost of nativism

This is an example of the harmful effects of attempting to eradicate non-native species.  It reminds us of a recent editorial in the New York Times about the new law in Alabama which is considered the most extreme anti-immigration law in the country.  The opponents of immigration are delighted with the new law.  The farmers of Alabama are warning us that they cannot replace the immigrants who are fleeing the state. Most of the work in the country’s agriculatural fields and orchards is being done by immigrants.  These are jobs that Americans are no longer willing to do.  This is just one of many unintended consequences of such xenophobic extremism.   We consider the Spartina eradication project another example of nativism run amok.

Natural Areas Program violates San Francisco’s pesticide policy

As the deadline for written comments on the Draft Environmental Impact Report on the Natural Resource Areas Management Plan approaches (October 31, 2011), we are reprinting with permission a post from the Save Sutro website about the many violations of San Francisco’s pesticide policy by the Natural Areas Program. 

Anyone with the time and patience to read the 600+ page EIR knows that it does not provide us with any information about the volume of pesticides used by the Natural Areas Program.  Instead, it claims that the pesticides used by the Natural Areas Program will have no impact on the environment because they are following the rules; therefore, by definition there can be no negative impact on the environment.  This seems a non-sequitur to us.  But, even if we accepted this illogical premise, the fact is, they AREN’T following the rules.  Save Sutro tells us about the many violations of the city’s pesticide policy by the so-called Natural Areas Program.

Details about how to submit your public comment by October 31 are provided at the end of this post.

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As we noted in our previous post, the San Francisco Natural Areas Program seems to be using increasing amounts of toxic pesticides. From time to time, we’ve posted information here about pesticide use in the Natural Areas Program (NAP) lands. Roundup, Garlon, Imazapyr in Glen Canyon, at Pine Lake, on Twin Peaks, Mt Davidson, in the Interior Greenbelt — usually with a photograph. (Search this site on any pesticide name to see other relevant posts.)

What our readers have pointed out to us is that many of these violate the rules of the San Francisco Department of the Environment (SF DoE). We really appreciate SF DoE regulating toxic pesticides. They’re our second line of defense, when the Environmental Protection Agency seems all too ready to approve first and question later (or not question later). But they can only be effective if their rules stick.

What do we mean, violations? Well, here are a few, all from 2009 and 2010. Were there others? We don’t know.

A BUNCH OF VIOLATIONS

Missing dates on notices. The signs for pesticide spraying are meant to warn people — both the NAP staff and the general public with their kids and pets — that toxic chemicals are in use in an area. It’s pretty well-designed; it requires the dates the application is planned, how it will be applied, and then when it’s been used and when it will be safe to go back in there. But as with every precaution from seat-belts to poison symbols, it only works if it’s used. From the time we started collecting notices (pictures, not the actual notices), we often found key data missing: the date and time of the actual application. That means it’s never clear when (or whether) the pesticides were used and whether it’s safe to re-enter.

Using pesticides before they’re approved. In 2009, when we published a photograph someone sent us of Imazapyr usage at Pine Lake in Stern Grove, other readers were surprised. How come? SF DoE hadn’t approved it for use, had it?

They hadn’t.

It’s been approved only in 2011, as a Tier II pesticide.

Using pesticides where they’re not approved. In November 2010, we saw a notice that said they were spraying Aquamaster (glyphosate, same active ingredient as Roundup) “near shoreline” of Lake Merced. The target plant was “ludwigia – aquatic weed.” Also known as water-primrose, this grows in the water and presumably that’s what they were after. Except… Lake Merced is red-legged frog habitat. Use there is restricted: “Note prohibition on use within buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” (Glyphosate is death on frogs.) This was a lot less than 60 feet.

Spraying when they shouldn’t be spraying. According to the SF DoE, here’s how Roundup should be used: “Spot application of areas inaccessible or too dangerous for hand methods, right of ways, utility access, or fire prevention…OK for renovations but
must put in place weed prevention measures. Note prohibition on use within
buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” But according to all the notices (and the records) they’ve been using a backpack sprayer.

Spraying Garlon without a respirator. The signs said Garlon. The SF DoE regs said that this Tier I pesticide was for “Use only for targeted treatments of high profile or highly invasive exotics via dabbing or injection. May use for targeted spraying only when dabbing or injection are not feasible, and only with use of a respirator. HIGH PRIORITY TO FIND ALTERNATIVE.” The person spraying wore a blue “space-suit” — but no respirator. (Don’t know who it was, whether a Parks employee or someone from contractor Shelterbelt. Whoever, please be careful. The regs are there for a reason.)

Poorly maintained data. Pesticide use is recorded, and again the records are pretty specific. The serial number of the use, and the date. The chemical used, its trade name and chemical name and its EPA number. Where it’s been applied, and what it’s targeting. Who applied it. Analyzing these records would give a pretty good idea of who’s using what, where and why. But… the records aren’t complete, or at least they don’t appear to be. We’ve found notices in the field with no corresponding database entry.

IMPLICATIONS FOR THE DEIR

We understand how these violations occur. We don’t attribute adverse motives to NAP; they’re not going through the books thinking, which rule shall we break today? Remembering all the restrictions, maintaining records and filling in signs is tedious, and it’s easy to forget in the press of work. Even NASA makes mistakes.

Still, the objective of the rules is to keep us all safer and reduce the use of toxins as far as possible. With good reason, we don’t think the NAP is able to comply.

As readers will be aware, the Draft Environmental Impact Report (DEIR) for the San Francisco Natural Areas Management Plan is now open for public comment. What the DEIR says is: “Pesticide and herbicide use in the Natural Areas would be in accordance with the SFRPD’s Integrated Pest Management (IPM) Program and San Francisco’s Integrated Pest Management Ordinance...”

Seriously? Can they even do it?

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[Edited to add:

For readers who are interested in commenting on the DEIR:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

“Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17 31, 2011. [Please note, the deadline has been extended.] Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”]

The toxic pesticides used by San Francisco’s Natural Areas Program

We are reprinting with permission an article from the Save Sutro website about the pesticides being used by San Francisco’s Natural Areas Program.  The Save Sutro website is a valuable source of reliable information on any topic it covers, but it is especially knowledgeable about the pesticides being used in San Francisco. 

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It’s no surprise that people are beginning to associate San Francisco’s Natural Areas Program with pesticides. It’s been using them (if the city’s records are accurate) at an increasing rate.

    • In 2009, it applied Garlon 16 times; in 2010, it was 36 times.
    • It applied Roundup (or Aquamaster, also glyphosate) only 7 times in 2009, but 42 times in 2010.

The Draft Environmental Impact Report (DEIR) on the SF Natural Areas Program is rather coy about pesticides. It doesn’t say how much it’ll use, just that it will follow all the rules when using them. (They actually have a poor track record there, but we’ll go into that in another post. [Edited to Add: We did.]) Today, we want to talk about the pesticides on their list: Roundup or Aquamaster (glyphosate); Garlon (triclopyr); Polaris (imazapyr); Milestone (aminopyralid).

SF’s Dept of the Environment classifies all of these as Tier I (Most Hazardous) or Tier II (Hazardous). There’s no mention of using any Tier III (Least Hazardous) chemicals.

ROUNDUP or AQUAMASTER (Glyphosate)

We’ve talked before of Roundup, a Tier II pesticide. We hope that in view of the new research that has been surfacing, SF’s DoE will revisit that classification and consider if it deserves a Tier I rating.

  • heart breaking

    It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).

  • Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
  • It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

Classified as Tier I, Garlon is even more hazardous than Roundup. In 2010, NAP used this pesticide 36 times (sometimes in combination with Roundup, which it has said it will no longer do). We’ve written about Garlon before, Garlon in our Watershed — which has more details — and many times since then. In brief, these are the main issues:

  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, it’s absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist in dead vegetation for up to two years.

The DEIR has said that the SF NAP’s phasing out Garlon. We have some doubts; its tree-felling program will be futile without Garlon to prevent re-sprouts.

POLARIS, HABITAT (Imazapyr)

This is a very new pesticide, and not much is known about it — except that it’s very persistent. SF’s DoE has recently approved it for use as a Tier II hazard. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment. We’ve written about this one, too, when NAP recently started using it on Twin Peaks and Glen Canyon. (Actually, NAP had started using it prior to SF DoE’s approval , in Stern Grove and also at Lake Merced in 2009 and some unspecified NAP area in 2008.)

About its impact on people, we wrote: “it can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”

It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001.

MILESTONE (Aminopyralid)

Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. While the DEIR lists this as a chemical used by the NAP, they actually used Milestone very little (twice in 2010). Fortunately. SF DoE classifies it as Tier I, Most Hazardous. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.

Nevertheless, after an outcry and problems, Dow AgroSciences has stopped selling Milestone in the UK until it’s figured out.

Note to NAP and SFRPD: Don’t put clippings treated with Milestone in the green bin!

PESTICIDE CONSPIRACY THEORIES

When we first started researching pesticide use in “Natural Areas” (and shocking a lot of people who’d assumed “Natural” meant natural), conspiracy theories arose: The chemicals companies were subverting the decision-makers; Pesticides were being portrayed as ecological, and the marketing machine was convincing them; Maybe there were even payoffs!

We think the explanation is much simpler: Those in charge of the Natural Areas are being asked to do the impossible. They’re given a large area, (ETA: it’s as big as Golden Gate Park but in 32 separate locations) in the middle of a city where conditions don’t even approximate those of the pre-industrial era, and asked to return it to a specific moment in time.

It doesn’t want to go.

WHY NATURAL AREAS FIGHT BACK

Someone described the effort to “restore” the “Natural Areas” to “Native plants” as a constant battle. It is, and here’s why:

  • Stopping natural succession. Some areas are harder than others. Grasslands want to grow shrubs, native or not. Then, in pre-industrial San Francisco, along would come grazing browsing animals, or lightning strikes, or a landslide or two, and the shrubs would lose and the grass would win. Preserving grasslands requires killing the shrubs, and in the absence of animals and fires and landslides, it’s pesticides. Repeatedly.
  • Battling successful plants. And then there are the plants that do want to grow there, that grow there naturally (even if, like many San Franciscans, they’re not from here). These we call invasive, and want to get rid of them. That’s more pesticides. And since the plants are good at what they do, they have to be strong pesticides. Repeatedly.
  • “Invaders” compete with each other. Even if the pesticides clear an area of one kind of “invasive” plant, unless the space is intensively gardened, it’ll be taken over by other “invaders.” More pesticides.

The bison in the room (it’s native, unlike the elephant) is this: Contrary to the belief that Native Plants are so adapted to a particular place that “restorations” can be achieved merely by eradicating unwanted plants — Native Plant gardens need the same kind of maintenance and care as any garden.

Without the Sutro Stewards’ volunteers working there every month or so, the Native Garden on top of Mount Sutro would revert to its natural state: a mix of native and introduced plants. (No pesticides are used in that area, or indeed anywhere on UCSF’s Mount Sutro space. It may be the last pesticide-free wild area in San Francisco.)

Is the Natural Areas Program, as it’s currently managed, worth it? We think not, because of:

  • the ongoing and growing need for toxic herbicides;
  • the destruction of habitat for insects, birds and animals that rely on it (and this includes native species, most of which have adapted to introduced plants);
  • we think it’s an expensive misdirected effort in terms of time and treasure.

It makes sense to define small areas as Native Gardens, focus on those, and make them succeed. That can be done — as the Native Garden on Mount Sutro proves — without toxic chemicals.

Environmental Impact Report of Natural Areas Program proposes aggressive expansion

Fifteen years after San Francisco’s Natural Areas Program (NAP) began operation and 5 years after its management plan was approved, the Draft Environmental Impact Report (EIR) has finally been published.  We will briefly summarize the history of NAP, describe the plans as they were approved in 2006, and conclude with a comparison between those plans and the proposal in the EIR to aggressively expand NAP.

The Management Plan for the Natural Areas Program

In 1995 the Recreation and Park Commission approved the designation of 31“natural areas” in parks managed by the city of San Francisco. This designation committed 25% of the city’s park acreage in San Francisco, 33% including the city of Pacifica to the Natural Areas Program.  

Most park visitors were unaware of this designation until 5 years later when they finally had access to a draft of the management plan after a lengthy battle to make it available.  At that point, many park visitors could see where the Natural Areas Program was headed and many of them reacted negatively to the prospect of the destruction of non-native trees and restrictions on recreational access in popular, heavily visited parks.

The result of the long debate with the public was a revised management plan that separated the natural areas into three “management areas.”  These management areas (MAs) set priorities for the restoration of parkland to native plants:  MA-1 was the highest priority, MA-2 the second priority, and MA-3 the lowest priority.  The appeal of these priorities to critics of NAP was the commitment that there would be no tree removals in the MA-3 areas and that no legally protected species would be planted or reintroduced there, which might require further access restrictions in the future.  Forty-two percent of the total 1,080 acres of natural areas was designated as MA-3.

The management plan* was approved in 2006, after two days of public hearings at which about 200 public comments were heard by the Recreation and Park Commission.  Supporters of NAP outnumbered critics of the program.  The main message of the critics of the program was that the acreage committed to natural areas should be reduced to places in which native plants existed, which would not include acreage designated MA-3.

There were two trivial caveats to the approval of the program:  defining the circumstances under which cats could be removed from the natural areas and specifying that tree removals must be done by the Urban Forestry Division of the Recreation and Park Department (RPD).  These are some of the main features of the approved management plan:

  • Tree removals.  18,500 trees over 15 feet tall were designated for removal in MA-1  and   MA-2 areas.   In addition, non-native trees under 15 feet tall would be removed in these areas, but were not quantified because the plan did not define them as “trees”
  • Trails.  10.3 miles of trails were designated for closure in these areas.  That represented 26% of all trails in the natural areas.
  • Dog Play Areas are those areas in parks that have been officially designated for off-leash recreation.  The NAP management plan identified several dog play areas that would be monitored for possible closure in the future if necessary to protect native plants.  Those dog play areas were in Bernal Hill, McLaren and Lake Merced parks. 
  • Golf Course at Sharp Park will be reconfigured to accommodate populations of two endangered species.

The Environmental Impact Report of the Natural Areas Program

Five years after the approval of the management plan, the Environmental Impact Report (EIR) has finally been published.  The EIR identifies 4 alternatives to move forward with the implementation of the plan. The EIR identifies the “Maximum Restoration Alternative” as the “Environmentally Superior Alternative” described as follows:

“This alternative seeks to restore native habitat and convert nonnative habitat to native habitat wherever possible throughout the Natural Areas, including all management areas.”

[ETA:  This article has been updated by a more recent post which reports that a mistake has been found in the Draft Environmental Impact Report (DEIR):  The “Maximum Restoration Alternative” is not the “Environmentally Superior Alternative” as the DEIR claims on page 2.  The “Maintenance Alternative” is the “Environmentally Superior Alternative” as the DEIR says on page 526.  The mistake on page 2 has been reported to the Planning Department.  The Planning Department has acknowledged the error on page 2 and has made a written commitment to correct the error in the Final Environmental Impact Report.  Unfortunately, this correction will not be made until the public comment period is over.]

In other words, the preferred alternative would do away with the priorities identified in the management plan and treat all three management areas the same.  These are the specific implications of this proposal as described by the EIR:

  • Trees.  Non-native trees would also be removed in the MA-3 areas.  The number of trees over 15 feet tall that will be removed will exceed 18,500, but the EIR does not quantify how many trees will be removed.
  • Trails.  More trails would be closed in the MA-1 and MA-2 areas, but the EIR is not specific about how many miles of trail will be closed.
  • Dog Play Areas.  All dog play areas in MA-1 and MA-2 areas would be closed.  This will close the dog play areas in Buena Vista and Golden Gate (Southeast) parks and what little remained of McLaren (Shelley Loop) and Bernal Hill after the closures mandated by the management plan.  Dog play areas in MA-3 areas will be monitored and closed in the future if necessary to protect native plants.  The EIR predicts that all of these closures in addition to the anticipated closures of GGNRA properties to off-leash dogs will result in heavier usage of the dog play areas that remain.
  • Golf Course at Sharp Park would be further reduced by expanded habitat for endangered species.
  • Other access restrictions.  Legally protected species will be introduced in MA-3 areas, which may require further restrictions on access in the future.

The other alternatives identified in the EIR are:

  • “No Project Alternative – Under this alternative, the SFRPD would continue with the management activities authorized under the 1995 management plan.”  This alternative will close the dog play areas that were monitored since the management plan was approved in 2006: the Mesa at Lake Merced, portions of Bernal Hill and McLaren (Shelley Loop).
  • “Maximum Recreation Alternative – This alternative seeks to restore and improve recreational access to the Natural Areas wherever it does not interfere with the continued existence of native species and federally or state-listed sensitive species.”
  • “Maintenance Alternative – This alternative seeks to maintain the current distribution of native and nonnative habitat and species throughout the Natural Areas.  Under this alternative there would be no conversion of nonnative habitat to native habitat; other features of the Natural Areas would be retained.”

Rewarding Failure

Park visitors who have been watching the restoration efforts of the Natural Areas Program for the past 15 years might be surprised that NAP apparently wishes to expand its restoration efforts.  Repeated clearing of non-native plants and planting of native plants has been spectacularly unsuccessful.  Here’s a photo history of the effort at Pine Lake in Stern Grove:

One of several clearing and plantings of south shore of Pine Lake, 2003
The results, south shore of Pine Lake, 2011
North shore of Pine Lake, 2003
 
Results, north shore Pine Lake, 2011

If NAP has been unable to successfully restore 58% of acres of natural areas (MA-1 and MA-2) they have been actively working on for the past 15 years, why would they want to expand their empire by adding MA-3 acreage to their agenda, committing them to actively restoring all 1,080 acres of natural areas?  Aren’t they biting off more than they can chew?

Where will the money come from to fund this expanded effort?

Although NAP and its many supporters believe that this lack of success is because they haven’t been adequately funded, the NAP staff is one of the only divisions in the Recreation and Park Department that hasn’t been cut in the past 10 years.  While other gardeners have been laid off, the NAP staff has remained the same size.  How many gardeners will it take to expand their restoration efforts to the MA-3 areas as the EIR proposes?  Remember that the MA-3 areas are 42% of the total NAP acreage.  Will NAP be given a 42% increase in their staff?  One wonders where the money for such an increase in staff would be taken from.

How much more herbicide will be used in this expanded effort?

Will a 42% increase in actively management NAP acreage require more herbicide use?  The Natural Areas Program applied herbicides to the so-called “natural areas” 69 times in 2010. Most of those applications were of the most toxic herbicide (Garlon) for which the Natural Areas Program was granted exceptional permission to use by the Department of the Environment.  How much more herbicide must be used by NAP if they actively manage the MA-3 areas?  The EIR is curiously silent on this question.

Public Comment Opportunities

The public will have two opportunities to comment on the EIR and its “environmentally superior alternative” which will aggressively expand the restoration efforts of the Natural Areas Program, require more tree removals and recreational access restrictions, probably cost much more, and probably increase the use of herbicides.

  • “A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”
  • “Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17, 2011*. Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”
  • “If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”

*[ETA:  The deadline for written comments has been extended to October 31, 2011, at the request of the Planning Commission.]

If you have an opinion about the expansion of the Natural Areas Program proposed by the Environmental Impact Report  you would be wise to speak/write now.  It is your last opportunity to do so.

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*Type in search box:  Natural Areas Program management plan

Are native species inherently superior to non-native species?

The native plant movement is based on the fundamental assumption that native species of plants and animals are inherently superior to non-native species.  The basis of this assumption seems to vary.  Sometimes the explanation offered is as simple as “the non-native doesn’t belong here.”  It’s not clear what that statement means.  Putting it in the best light, it implies that there is some optimal ecology that is best represented by exclusively native species.  A less generous interpretation would be that non-native plant and animal species are the non-human equivalent of illegal immigrants. 

We will examine this claim of the superiority of native species in the context of bees to make the point that nature is complex and cannot be oversimplified by such a sweeping generalization.

Professor Gordon Frankie, our local expert on the bees of the Bay Area, says that native bees are superior pollinators to the European honeybee.  If that were true, we would consider that a legitimate basis for the judgment that, in this case, the native bee is superior to the non-native bee.  However, the evidence available to us suggests that a comparison of the native to the non-native bee is more complicated.

In considering this question, we will focus on agriculture rather than residential gardens, because agriculture is economically more important and for the same reason more is known about the role of bees in agriculture.

Why would native bees be superior pollinators than non-native bees?

We know of two specific examples of native bees that are more effective pollinators of agricultural crops.  Both cases illustrate the pros and cons of native bees as agricultural pollinators.

Bumblebee on Cotoneaster, Albany Bulb

There are some crops—tomatoes, cranberries, blueberries, eggplants, and kiwi fruits—that are effectively pollinated by native bumblebees (Bombus) because of their unique method of pollination.  This method is called “buzz-pollination” or “sonication” and it is described as “an intense vibration, like a tuning fork being struck, pollen gathered from other flowers literally exploded off Bombus.”(1)

Unfortunately, though its pollination technique is superior, other characteristics of the native bumblebee have limited its usefulness in agriculture.  The crops with which it is most effective produce only pollen.  Therefore, the bumblebee must be provided with an alternate source of nectar to fulfill its dietary needs.(2)  

The bumblebee, like most native bees, is solitary.  It does not live in hives like the social European honeybee.  Therefore, it cannot be transported where and when it is needed, as the honeybee can.  An attempt at a high-tech solution to this limitation ended in disaster:  “In the 1990s, a bumblebee species Bombus occidentalis, was made extinct when experimenting breeders mixed species in Europe and shipped queens back to America.  The queens carried with them an exotic disease that Bombus occidentalis has no immunity for.”   Growers of tomatoes are now “forced to resort to less efficient pollinators.”  (Schacker 2008). 

Another example of a native bee that is a superior pollinator of an agricultural crop is the alkali bee which is the most efficient pollinator of alfalfa, a crop that is essential to the dairy and beef industries.  “Alfalfa flowers…keep their sexual parts hidden, under tension like a spring.  Bees must trip the spring to get at the pollen, and in so doing, they are hit on the head—something honey bees are not particularly fond of.  The alkali bees…don’t mind getting hit on the noggin and will happily pollinate a field of alfalfa.”  (Schacker 2008). 

Native bee approaching nest in ground, Albany Bulb

Unfortunately, the alkali bee, like 85% of native bees in the US, nests in the ground, in particular the alkaline soils of the western US for which it is named.  As cropland in the west expanded, the alkali bee was virtually wiped out by plowing up the ground in which it nested.  A leafcutter bee was imported from Canada as a substitute, but a fungus is now infecting its larvae. (Schacker 2008)

These disadvantages of native bees can be compensated for by providing nesting and nectar sources adjacent to croplands.  These hedgerows must be large enough to provide sufficient nesting opportunities and nectar sources. 

However, such hedgerows do not solve all the potential problems of using native bees as pollinators.  Because the bees are resident year around and cannot be transported, they cannot be removed when the crops are sprayed with pesticides.  And the pesticides are very damaging to the bees.  Therefore, a commitment to providing hedgerows for a resident bee population is also a commitment to organic agriculture, i.e., without using pesticides. 

This is not to say that the honeybees aren’t being adversely affected by the use of pesticides in the crops they are pollinating.  The impact of pesticides on  honeybees would be exacerbated if they were resident when pesticides were applied to the crop.  As it is, the honeybee is being affected by the residues of the pesticides on the crops they pollinate.  This is considered one of the primary reasons for Colony Collapse Disorder of commercial honeybees which has been destroying about one-third of commercial honeybee hives in the past few years.

Unlike most native bees, the European honeybee does not hibernate.  It is therefore available year around to be transported where and when it is needed.  Most native bees hibernate, but not necessarily at the same time.  Different species of native bees hibernate at different times and are therefore available for pollination at different times. 

Most native bees are more selective in their pollination than the European honeybee which is an extreme generalist:  “honeybees have the greatest pollen dietary range…of any known pollinator.” Although there are “only a handful of well-documented cases in North America of truly monolectic bees [a bee that visits only one kind of flower]” (Buchmann 1996), the flower preferences of native bees are narrower than that of the European honeybee.  While some native bees may prefer native plants, honeybees are willing to pollinate both native and non-native plants.  This is important because virtually all of our agricultural crops are non-native.

Native bees are not inherently superior to non-native bees

Honeybee hives, USDA photo

In summary, the European honeybee has several important advantages over native bees as pollinators of agricultural crops:

  • Because the honeybee is a social bee that lives in hives, it can:
    • Be transported where and when it is needed
    • Be removed from the agricultural crop when it is sprayed with pesticides
    • Does not need to be provided with nesting space and an alternate food supply
  • The honeybee is available for pollination services year around because it does not hibernate.
  • The honeybee pollinates a wider range of flowers than most native bees.

While native bees may be more efficient pollinators of residential gardens, there are a number of disadvantages to using native bees for agricultural pollination.  Although many of these obstacles can be overcome with greater use of resources, we cannot agree with the assumption of native plant advocates that native bees are inherently superior to the non-native European honeybee.  As with all sweeping generalizations, the truth is usually more complicated because nature is complex and man’s understanding of it is limited.

(1) Schacker, Michael, A Spring without Bees, Lyons Press, Guilford, Conn, 2008.

(2) Buchmann, S, and Nabhan, G, The Forgotten Pollinators, Island Press, 1996

“Museumification” of our parks separates children from nature

The Berkeley Meadow

We recently published an article about the Berkeley Meadow, a 72-acre fenced pen for native plants and animals.  In response, one of our readers alerted us to a video cartoon about the Berkeley Meadow which we recommend to you.  “Grandpa Takes the Kids to the Plant Zoo” captures the absurdity of this “restoration” project.

The sentiments expressed by the children in this video remind us of an article published in 2004 about similar restoration projects in Chicago and San Francisco.  “Urban Park Restoration and the ‘Museumification’ of Nature” was written by Dr. Paul Gobster after he visited the Bay Area as a visiting professor at UC Berkeley, collaborating with colleagues in landscape architecture.

Dr. Gobster is a social scientist with the US Forest Service, stationed in the Chicago area and the editor of a book* about the restoration movement there.  The restorations in Chicago are similar to those in the San Francisco Bay Area because both places were primarily grassland prior to the arrival of Europeans.   Restorations in both areas therefore require the destruction of most trees.  In the Chicago area, many of the trees are native because of the natural succession of grassland to shrubland and finally to forest.  The fires of Native Americans that sustained the grassland were stopped at the time of settlement.

In “Museumification,” Dr. Gobster expresses his opinion of the restorations in the San Francisco Bay Area and in Chicago:

“…it is my contention that little headway has been made in exploiting the key role urban parks might have in strengthening the ties between nature and culture.  To the contrary, some current attempts at ecological restoration in urban parks may distance people from the experience of nature even further than did earlier naturalistic designs, leading to a form of detached observation not unlike what one might experience in a museum.  Instead of providing a bridge between nature and the city…park restoration can lock nature inside the gates of paradise and leave people on the outside looking in.”

Dr. Gobster is particularly concerned about the impact of “museumification” of parks on children who should be the primary beneficiaries of our parks.  Their earliest experiences with nature may foster a lifelong interest in nature or an alienation from it.

“The wild and weedy nature that existed in many of these urban park areas prior to restoration provided [a setting for unstructured play]…Now displaced by a more ecologically diverse yet more fragile nature, these kinds of activities are discouraged just as they are in more manicured park settings.  Children are much less likely to attain satisfying nature experiences through passive forms of interaction and thus may be disproportionately affected by such changes.  The result of this museumification is that we are creating a significant gap in the spectrum of nature experiences available to urban children precisely at the nearby places where children stand the best chances for getting acquainted with nature.  Thus while striving to achieve authenticity in the restoration of ecosystems we may be sacrificing the authenticity of children’s nature experiences.”

Children discovering nature. NPS photo

In “Grandpa Takes the Kids to the Plant Zoo,” we see that the kids are uninterested in looking at the plants on the other side of the fence.  They ask Grandpa to take them elsewhere so they can play.  Grandpa must also ask them not to touch the few plants within reach because they have been sprayed with herbicides.  The park is not accessible to the kids because it is behind a fence and it has also been sprayed with herbicides, so it’s not a safe place for them to play.  In the East Bay Regional Park District, for example, herbicide use in its restoration projects (AKA “resource management”) increased 300% in 2009.  Herbicides had not been sprayed in the Serpentine Prairie prior to 2009, when it was fenced for “restoration.”  Now it is sprayed with herbicides, mowed, planted, and is due for periodic prescribed burns to prevent its succession to shrubs and subsequently to oak woodland.

When we alienate children from nature, we jeopardize the future of our parks.  If parks are not viewed as useful places, they will not enjoy the support needed to sustain them.  And if nature is not viewed as valuable, we undermine the public’s support for preservation of the environment.  As adults debate the merits of native plant restorations, they should keep in mind the needs of children because the future of our public lands is in their hands and children are unable to speak for themselves in the public policy arena. 

* Gobster & Hull, eds., Restoring Nature, Washington DC, Island Press, 2000

Spartina alterniflora: Treasured on the East Coast, reviled on the West Coast

Spartina alterniflora (Smooth Cordgrass) is a species of marsh grass native to the Atlantic and Gulf coasts of the United States, where it is considered a valuable plant making important contributions to the coastal ecology:

  •  Its dense growth provides protection against storm surge and “erosion control along shorelines, canal banks, levees, and other areas of soil-water interface.”(1)
  • It filters nutrients, sediments and toxins from the water that flows off the land before reaching the ocean, acting as a natural water treatment facility.
  • It provides cover and food for birds, mammals and marine animals that live in the coastal marsh.  Many other marsh plants occupy the same marshlands.

    Spartina alterniflora, Smooth Cordgrass. USDA photo

Where Smooth Cordgrass has died back in its native range, the dieback has been considered a serious environmental threat:

  • In 2001 the Governor of Louisiana declared a “state of emergency” when Smooth Cordgrass declined and the state obtained $3 million of federal funding to study and hopefully reverse the decline.  This study resulted in the development of a method of aerial seeding of Smooth Cordgrass to restore declining areas of marshland.(2)
  • A similar, but smaller dieback of Smooth Cordgrass in Georgia led to a collaborative research and on-going monitoring effort by 6 research institutions in Georgia.(3)
  • Similar dieback of Smooth Cordgrass has been reported as far north as the coast of Maine.  A researcher at the Connecticut Agricultural Experiment Station is quoted in that report as saying, “In New Orleans, if their marshes were intact, the storm surge of Katrina would not have reached the levees.”(4)

The war on Smooth Cordgrass in the West Coast 

Smooth Cordgrass is not native on the Pacific Coast of the United States.  Therefore it is treated as an alien invader to be eradicated with herbicides:

  • $24 million was spent to eradicate Smooth Cordgrass in San Francisco and Willapa Bay from 2000 to 2010 (5)
  • $16.3 million is projected to be spent on eradication efforts on the entire West Coast from 2011 to 2020 (6)

In 2006, 2,000 acres were treated with herbicides to eradicate Smooth Cordgrass in the San Francisco Estuary.    Most were retreated 3 to 5 times after initial treatment.  In 2010, twenty five sites were slated for retreatment, usually with herbicides.  The San Francisco Estuary Invasive Spartina Project (ISP) “defines a need for a zero tolerance threshold on invasive Spartina in the San Francisco Bay.”(7)

The ISP reports that imazapyr (Habitat) will be used in most sites, although it will sometimes be mixed with glyphosate (Roundup). (See SaveSutro for more information about imazapyr and its use in San Francisco.)  The ISP acknowledges that:

  •  “little is known about the interactive effects” of combining these herbicides or any of the surfactants used with these herbicides.
  • These herbicides will be applied using a variety of methods, including aerial spraying by helicopter.
  • Although the ISP considers imazapyr a relatively non-toxic herbicide, it also acknowledges that imazapyr has only been used since 2005.  Therefore, “Only few toxicity studies exist for birds…no data exist for the potential toxicity of imazapyr to shorebirds.”(8) Given that one of the stated purposes of eradicating Smooth Cordgrass is to benefit the endangered Clapper Rail, it seems surprising that nothing is known about the effects of imazapyr on any shorebird, including the Clapper Rail.

Why is Smooth Cordgrass treasured on the East Coast and reviled on the West Coast?  That question was asked and answered by Professor James Morris at an Environmental Law Conference in Eugene, Oregon on March 5, 2011.  Professor Morris studies Smooth Cordgrass at the Baruch Institute for Marine & Coastal Sciences at the University of South Carolina.  We urge our readers to watch a video of his presentation to the conference in Oregon.  We will draw upon that video in addressing the claims (9) made by those who are attempting to eradicate Smooth Cordgrass on the West Coast:

Indictment:  Smooth Cordgrass will invade mud flats, eliminating valuable habitat for plants and animals that inhabit that segment of marshland.

Defense:  According to Professor Morris, Smooth Cordgrass was introduced to the West Coast in shipments of Eastern oysters over 100 years ago without eliminating mudflats.  Europe has had similar experience with Smooth Cordgrass which was introduced there to reduce sediment in harbors.  Professor Morris showed pictures of Danish and Dutch estuaries in which Smooth Cordgrass has existed since the 1930s without radically altering the composition of the marshland.

Indictment:  Smooth Cordgrass will invade waterways, making them impassable.

Defense:  Again, since this has not happened in 100 years, there is no reason to assume it will happen in the future.  Furthermore, the USDA describes the narrow range of Smooth Cordgrass:  “the width and thickness of vegetative colonies are controlled by a number of site specific conditions such as elevation, shoreline slope, and frequency, depth and duration of flooding” as well as salinity and acidity.  In other words, the range of Smooth Cordgrass is limited.

Indictment:  Smooth Cordgrass does not provide habitat value equal to the native species of cordgrass with which Smooth Cordgrass competes, particularly for the endangered Clapper Rail.

Defense:  Mike Casazza at the Dixon Field Station of the USGS is presently studying the effect of eradicating Smooth Cordgrass on the reproductive success of the Clapper Rail:  “Removal of invasive Spartina accomplishes the goal of Spartina eradication, but if rails fail to survive and reproduce, then the goal of species protection is unfulfilled…the potential for impact from invasive Spartina removal and the potential for mitigation by rail ecology and behavior remain poorly understood.”(10)  Clapper Rails live in Smooth Cordgrass on the East Coast:  “numerous” Clapper Rail families were observed nesting in Smooth Cordgrass on Dewees Island, South Carolina.(11)

Indictment:  Smooth Cordgrass is outcompeting the native Pacific Cordgrass (Spartina foliosa) by displacement and hybridization.

Defense:  This is probably true because of the characteristics of the Pacific Cordgrass:  “S. foliosa occupies a very limited range in the intertidal zone, and the leaves and stems wither in fall and shed in the winter, leaving sparse standing matter that is ineffective at trapping sediment.  Seedlings of S. foliosa are seldom found in established marshes and appear only intermittently in sheltered upper mudflats.”(12)  In other words, the range of the native cordgrass is narrower, it does not grow as densely, and it is not foliated year around, thereby creating opportunities for the non-native cordgrass to occupy bare ground.  Since marsh grasses are beneficial to the environment and its inhabitants, the ability of Smooth Cordgrass to occupy this vacuum seems a benefit, particularly since native cordgrass is less capable of removing sediments from water, reducing its effectiveness as a filter of pollutants from water flowing into the bay.(13)

Smooth Cordgrass is treasured on the East and Gulf Coasts because it performs valuable ecology services.  Although it performs the same ecological functions on the West Coast, it is being eradicated.  The evidence available to us suggests that we are spending a lot of money and effort, as well as using a lot of herbicides, to eradicate Smooth Cordgrass only because it is not native to the West Coast.   

  • Smooth Cordgrass provides superior storm surge protection particularly during winter months when native cordgrass is dormant.
  • Smooth Cordgrass is more capable of filtering pollutants from water flowing into the bay.
  • Smooth Cordgrass provides at least equal habitat quality to the endangered Clapper Rail and probably other marsh plants and animals as well.
  • Smooth Cordgrass has not blocked waterways or eliminated mud flats in comparable situations over long periods of time

We invite our readers to supply us with evidence that there are legitimate reasons for the campaign against Smooth Cordgrass.

(2) Dorset Hurley, “Geogia’s Marsh Die Back and Louisiana’s Marsh Browning,” Altamaha Riverkeeper

(3) Ibid.

(4) “What’s killing off our salt marshes,” Going Coastal Magazine, September 15, 2008

(5) “West Coast Governor’s Agreement on Ocean Health,” May 2010, page 5

(6) Ibid., page 6

(7) “San Francisco Estuary Invasive Spartina Project, 2010 Pesticide Application Plan,” page 15.

(8) Ibid. page 31

(9) “West Coast Governor’s Agreement on Ocean Health,” May 2010

(10) “Ecology of California Clapper Rail in the San Francisco Bay/Delta Region,” USGS Western Ecological Research Center

(11) Judy Drew Fairchild, “Watch for Clapper Rails and chicks,” Dewees Island, SC

(12)“West Coast Governors’ Agreement on Ocean Health,” May 2010, page 12

(13) “San Francisco Estuary Invasive  Spartina Project, 2010 Pesticide Application Plan,” page 10