“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.

Spartina eradication is now a zombie project

Over 20 years ago the governors of California, Oregon, and Washington made a commitment to eradicate non-native spartina marsh grass on the entire West Coast of the country.  Intensive aerial spraying of herbicide killed over 95% of non-native spartina about 10 years ago, but the project continues in the San Francisco Bay.  The goal is now the eradication of hybrid spartina that grows at the same marsh elevations as native spartina and is so visually similar that it requires 500 genetic tests every year to determine that it is a hybrid before it is sprayed with herbicide (1). This article will explain why the Invasive Spartina Project in the San Francisco Bay Estuary is now a zombie project, a project that is dead, but is not being allowed to rest in peace.

Click on the picture to see the presentation of the Invasive Spartina Project to the California Invasive Plant Council on June 11, 2021. This is the source of some of the information in this article. Answers to questions at the end of the presentation are particularly important.

Hybridization is the boogey man of plant nativism

Hybrid spartina is being hunted because it outcompetes native spartina.  Nativists fear the loss of native spartina as a distinct species.  Rather than seeing the potential for a new, improved species of spartina, they see it as a loss of biodiversity, rather than an increase in biodiversity. 

Non-native spartina is also accused of “invading” mudflats where some animal species require that type of environment. However, that accusation is contradicted by these photos where native spartina has been planted on mudflats at Eden Landing. The source of these photos is the June 2021 presentation of the Invasive Spartina Project.

Hybridization is an important evolutionary tool that frequently increases biodiversity by creating new species on the margins of ranges where closely related species encounter one another.  For example, hybridization is credited with creating over 500 species of oaks all over the world that are well-adapted to their respective microclimates.  The rapidly changing climate and the globalization of trade have created more opportunities for hybridization and resulting speciation. 

Advances in molecular analysis has informed us of the frequency of hybridization and its benefits to biodiversity:

“With the growing availability of genomic tools and advancements in genomic analyses, it is becoming increasingly clear that gene flow between divergent taxa can generate new phenotypic diversity, allow for adaptation to novel environments, and contribute to speciation. Hybridization can have immediate phenotypic consequences through the expression of hybrid vigor. On longer evolutionary time scales, hybridization can lead to local adaption through the introgression of novel alleles and transgressive segregation and, in some cases, result in the formation of new hybrid species.” 

Restoration and expansion of wetlands is extremely important as we prepare for anticipated rising sea levels.  If hardier, denser, stronger hybrid species of marsh grass are available why would we reject that opportunity?  Nativist ideology should not deprive us of this opportunity. 

Native species are not inherently superior to species that are better adapted to present environmental conditions.  The rapidly changing climate requires corresponding changes in vegetation to adapt to present conditions.  Extreme weather events are natural selection events that kill species that are no longer adapted to the climate.  We cannot stop evolutionary change, nor should we try.

Why does this matter?

If herbicides were not required to eradicate hybrid spartina perhaps I could shrug and move on.  Hundreds of gallons of imazapyr herbicide were used by East Bay Regional Park District to aerial spray non-native spartina for the first few years of the eradication project.  In 2020, EBRPD used 43 gallons of imazapyr for “ecological function,” a nebulous category that includes spartina eradication. 

When the Invasive Spartina Project (ISP) made a presentation to the California Invasive Plant Council in June 2021, the public asked several questions about the toxicity of the herbicide (imazapyr) that is used to eradicate spartina (1). The ISP mistakenly claimed that imazapyr is not harmful to humans and wildlife because it uses a different metabolic pathway to kill plants that does not exist in animals.  They probably believe that claim, but they are wrong.

 A similar claim was made for glyphosate for 40 years.  We now know that the claim about a “unique pathway” for glyphosate existing only in plants is not true.  In 2020, plaintiffs in a class-action suit against Monsanto alleging that it falsely advertised that the active ingredient in Roundup only affects plants were awarded $39.5 million.  The settlement also requires that the inaccurate claim be removed from the labels of all glyphosate products: “…[plaintiff] says Monsanto falsely claimed through its labeling that glyphosate, the active ingredient in Roundup, targets an enzyme that is only found in plants and would therefore not affect people or pets. According to the suit, that enzyme is in fact found in people and pets and is critical to maintaining the immune system, digestion and brain function.”

I asked Beyond Pesticides for help to determine if the exclusive pathway claim was true of imazapyr.  Beyond Pesticides informs me that both imazapyr and glyphosate use metabolic pathways that exist in animals. I summarize their response:  “You asked about the ALS pathway that is the target of imazapyr—is there a comparison to glyphosate?  [According to] the research I found, I think the comparison is valid.  This early paper appears to clearly state that ALS is a pathway found in yeast and bacteria as well as plants (2). Another early paper which identified ALS as coming from bacteria, fungi, and plants (3).”  These pathways exist in bacteria that reside in our bodies and perform important functions, particularly in our digestive and immune systems.  When we damage those bacteria, we are damaging our health.

Please note that both of these studies of imazapyr are nearly 40 years old.  If pesticides were being evaluated and regulated, the public and the users of imazapyr might know that it is harmful to animals.  I provided this information to the Invasive Spartina Project.  They responded that their use of imazapyr is legal.  Unfortunately, they are right.  Because there is no regulation of pesticide use in the United States, the Invasive Spartina Project has the legal right to use it.  But is it ethical?  I asked the Invasive Spartina Project to quit making the inaccurate claim that imazapyr kills plants, but cannot harm animals.  They did not respond to that request.

Unfortunately the judicial system is our only recourse to take dangerous chemicals off the market.  For example, chlorpyrifos that is known to damage children’s brains was finally banned as the result of a court order.  The EPA refused to ban chlorpyrifos, but a lawsuit finally resulted in a judge requiring that the EPA either provide studies proving its safety or ban its sale.  The EPA could not prove its safety, so it had no choice but to finally ban it. 

What about the animals?

Ridgway rail. Source: Cornell Ornithology Laboratory

The only issue that temporarily brought the spartina eradication project to a halt was the impact it has had on endangered Ridgway rail. Ridgway rail is a close relative to the Clapper rail on the East and Gulf coasts where the spartina species considered non-native here (S. alterniflora) is native.  Clapper rails are abundant where S. alterniflora resides.

“Fig. 2.  In marshes where invasive Spartina was present in large densities, populations declined rapidly commensurate with the amount of Spartina removed [from 2005 to 2011].” (4)

The eradication of Ridgway rail breeding habitat in the San Francisco Bay reduced the rail population significantly by 2011, according to the US Geological Service and the US Fish and Wildlife Service (4). The loss of rails was greatest where the most non-native spartina was killed with herbicide.  In response, USFWS mandated a moratorium on eradication in areas where rails were nesting (5). According to the ISP 2020 survey of rails in the project areas, the rail population rebounded where eradication was stopped.  When treatment resumed in 2018, the number of Ridgway rails in the previously restricted areas declined by 9% in the following year.  That outcome was predicted by the USFWS Biological Opinion: “In the 2018 Biological Opinion, the Service estimated that rails inhabiting the nine previously-restricted sub-areas may be lost due to mortality or exhibit decreased reproductive success due to loss of hybrid Spartina cover when treatment of these sub-areas resumed.”

Clearly, the endangered Ridgway rail has been harmed by spartina eradication, as USGS and USFWS concluded in their analysis that was published in 2016 (4):

“California [now known as Ridgway rail] rail survival was higher prior to invasive Spartina eradication than after eradication or compared to survival in a native marsh. The combined indication of these studies is that tall vegetation structure provides California rails with both higher quality nesting substrate and refuge cover from predation, particularly during high tides. Thus, habitat structure provided by invasive Spartina in heavily infested marshes may facilitate California rail survival, and continued efforts to remove invasive Spartina from tidal salt marshes could lead to further California rail population declines….” (4)

Given that Ridgway rail is protected by the Endangered Species Act, it is difficult to understand why this project is allowed to continue.  Much like the unregulated use of pesticides, it will probably take a lawsuit to enforce the Endangered Species Act on behalf of endangered Ridgway rail. When government is not functional, the judicial system can sometimes compensate.

Let’s bury this zombie project

The US Geological Service and the US Fish and Wildlife Service have put their finger on the failure of the Invasive Spartina Project.  The same could be said of many other pointless eradication projects:

“Removing the source of that novel habitat without addressing pre-existing native habitat quality limitations threatens to re-create an ailing landscape for California rails by dogmatically adhering to specific management approaches. In essence, the conservation community is choosing the winners and losers in this ecosystem by failing to solve the underlying problems that will support a healthy species community with all constituent members.” (4)

The spartina eradication project serves no useful purpose.  In fact, it damages the environment and the animals that live in it.  We cannot stop evolution, nor should we try.  Let natural selection determine the plant species that are best adapted to our environment and the animals that live in it.  Not only would we benefit from better protection for our coastline from rising sea levels, we could reduce our exposure to dangerous pesticides that are harmful to our health, as well as improve habitat for wildlife.  This project is doing more harm than good. 


  1. Presentation of Invasive Spartina Project to California Invasive Plant Council, June 2021 
  2. Falco, S.C., Dumas, K.S. and Livak, K.J., 1985Nucleotide sequence of the yeast ILV2 gene which encodes acetolactate synthase
  3. LaRossa, R.A. and Smulski, D.R., 1984. ilvB-encoded acetolactate synthase is resistant to the herbicide sulfometuron methylJournal of bacteriology160(1), pp.391-394.
  4. M.L. Casazza, et.al., “Endangered species management and ecosystem restoration: finding the common ground,” Ecology and Society, 2016, 21(1):19. http://dx.doi.org/10.5751/ES-08134-210119
  5. Adam Lambert et.al., “Optimal approaches for balancing invasive species eradication and endangered species management,” Science, May 30, 2014, vol. 344 Issue 6187

“A history of food, from sustainable to suicidal”

“A brilliant and insightful explanation of the food system. Bittman’s writing is succinct and entertaining, and his recommendations are spot on.” –David Kessler, MD, former FDA commissioner

Mark Bittman’s new book, Animal, Vegetable, Junk, is best described by its subtitle, A history of food, from sustainable to suicidal.  Bittman starts the story at the beginning, nearly 300,000 years ago when humans were hunter/gatherers.  The transition from a hunter/gatherer to an agricultural society began only 10,000 years ago.  It was a long, slow transition that happened unevenly all over the world.  Hunter gatherer societies still exist in the Amazon and perhaps elsewhere.  Where nature was generous, hunting/gathering persisted longer.  For example, indigenous people in California were still hunters/gatherers when Europeans arrived and indigenous people on the East coast had developed agricultural societies.

The conventional wisdom has been until recently that sedentary agriculture is superior to hunting/gathering as a lifestyle and a producer of food.  Bittman and Yuval Harari in Sapiens—the sweeping history of human civilization—disagree.  The diets of hunters/gatherers are more diverse, which makes them healthier and less vulnerable to famine.  If you can’t find what you need in one place, you move to another.  Families of hunter/gatherer societies are small because mothers can’t carry more than one child at a time, so there is no advantage to the large families required by farming.  Women’s role as gatherer is as important as man’s role as hunter, making the family less patriarchal than agriculture societies.  A mobile society has less impact on the land and is less likely to deplete resources, such as water and soil.  Communities were smaller, making them less vulnerable to communicable diseases.

The invention of the plow more than 2,000 years ago was one of the first significant turning points in the development of agriculture.  The plow requires the strength of men to operate, making the participation of women in food production less important.  A division of labor between the genders developed, along with the gender power hierarchy that persists today.  This division of labor was consistent with the need for families to have more children and therefore more farm hands. 

As the population of humans in agricultural society increased, so did the pressure on the land to be more productive.  Farmers knew and still know that the soil requires regeneration if it is to remain fertile.  Such practices as planting cover crops between cash crops to return vegetation to the soil, are not new.  Farmers also knew that leaving land fallow for a season or two enables the soil to recover from the loss of nutrients required to grow crops.  Rotating crops helps to control pests and diseases that are usually associated with one type of crop, but not another.  But the pressure to produce more food as the population increases puts pressure on farmers to squeeze more from the soil than it has to give in the long term.

Mechanization of agriculture

Mechanization was the most significant incremental step on the long road to the dead end that we now face in agriculture.  John Deere introduced his steel-bladed plow in the middle of the 19th century that was capable of breaking the tough sod of the Mid-Western prairie.  Deere mass-produced the steel plow using the assembly-line methods of the industrial revolution.  By 1859 John Deere was making 10,000 plows in a year. 

Although the Deere plow was a significant invention, the advent of the steam and then gas-powered tractor shortly thereafter were the true game changers that started the transition from family farms to the corporate agriculture of today:  “In 1830 it took a farmer and a horse at least seventy-five hours to produce a hundred bushels of corn.  BY 1930 that same task took as little as fifteen hours.  Production grew in parallel, from 173 million bushels of wheat in 1859 to 287 million by the century’s end.  The big difference was the tractor.”

The tractor was only the beginning of mechanization of agriculture.  There are now enormous machines, such as harvesters that cost half a million dollars and more.  Family farmers can’t afford to buy these machines.  They aren’t useful to small land-holders because huge farms are needed to pay for the cost of these machines.  Farmers who tried to stay in the game took huge loans to buy them.  Agriculture is risky business because the climate is changeable and unpredictable.  In drought years, many farmers with small holdings lost their land because they couldn’t repay their loans. 

Cornfield

Corporate interests are in a position to obtain the necessary loans and buy out the small land-holders.  Family farms are a thing of the past.  The romanticized notion of family farms is a fiction. Family farmers understand that destroying their soil is not in the interests of their family. Corporate interests have a short-term perspective when making business decisions.  Therefore, regenerative agricultural methods such as cover crops, rotating crops, and leaving land fallow are also a thing of the past.   

The Green Revolution

The so-called “green revolution” was the response to the destruction of agricultural land.  By the 1930s, the soil in agricultural America was exhausted.  The result of a century of short-term perspective agriculture that didn’t give back to the soil what was taken from it was the Dust Bowl of the 1930s. 

The Dust Bowl

Instead of returning to regenerative agricultural methods, the response was the introduction of chemical fertilizers and pesticides. Sixty years of pesticide use has bred many weed and insect species that are resistant to pesticides because no amount of chemistry can outwit evolution. In addition to introducing toxic chemicals into the environment, these chemicals exacerbated the trend toward bigger, corporate-owned agricultural lands because chemicals are expensive.  They must be purchased in advance of realizing the income of selling a crop, requiring bigger loans. According to Bittman, John Deere company makes four times as much money from financing these loans as from selling farm equipment. More family farms failed and their land was consolidated into huge acreages owned by corporate interests with short-term goals for higher profits.

The chemical warfare waged by industrial agriculture escalated greatly when Monsanto’s Roundup Ready seeds were introduced in 1996.  These genetically modified seeds enabled the indiscriminate spraying of the non-selective herbicide, glyphosate on commodity crops.  The seeds are expensive and their patents require that they only be used once.  They greatly increased farmer’s dependence on loans to finance the planting of their crops.  This indiscriminate spraying of glyphosate on commodity crops used in all processed food and animal feed means that we are now eating and drinking food laced with glyphosate, a probable carcinogen.

Chemical fertilizers deliver phosphorous to the soil, needed for plant growth.  Run off from agricultural land pollutes our lakes and rivers, killing fish and making water unsafe to drink or swim in.  Pesticides are indiscriminately killing insects, many of which are beneficial, such as our pollinators.  Pesticides are found in our water, our soil, and our food.  Little is known about the effects of these chemicals on our health or on wildlife, but what we know suggests they are probably more dangerous than we realize.  For example, recent research suggests that chemicals that disrupt our endocrine systems are probably reducing fertility, causing birth defects and contributing to gender dysphoria. 

Consequences of agricultural surpluses

Bigger is not better in agriculture because bigger also means that only a handful of crops are grown on huge corporate farms.  It is more expensive to grow diverse crops, requiring different cultivation methods and inputs.  Huge machines are operated more efficiently on huge plots of land.  Most agricultural land in America is devoted to growing crops of corn, soy beans, and wheat.  So much of America’s farm land is devoted to these commodity crops that they produce huge surpluses that require a global market to sell them to.

The global marketplace for commodity agricultural crops has fundamentally changed many countries.  The North American Free Trade Agreement (NAFTA) forced farmers in Mexico to abandon their small farms and move to cities to take low-paying manufacturing jobs because they could not compete against cheaper American corn.  The diet and health of the Mexican people has deteriorated significantly because they no longer have access to the variety of fruit and vegetables their small properties produced.  Their healthy fruit juices have been replaced by sodas made from corn syrup, resulting in high rates of obesity and diabetes.

Children’s cereals. Glyphosate residues are found in most cereal.

The diet of Americans has also been changed radically by the marketing campaigns designed to sell surplus commodities.  A surplus of milk produced the “Got milk?” advertising campaign that sold milk to adults for whom milk is rarely healthy.  Bittman says that 65% of adults are lactose intolerant, which he knows from personal experience.  He was forced to drink milk until he left home.  He was plagued by indigestion until he was able to quit drinking milk as an adult. 

Far more pernicious, is the advertising campaign that convinced mothers to quit breast feeding in favor of feeding formula.  This insidious campaign used guilt to pressure mothers by making the inaccurate claim that formula is healthier for their babies.  Breast feeding is the primary means that a baby’s immune system develops.  Formula contains higher levels of sugar that sets the stage for life-long eating habits that are not healthy.  High levels of obesity and diabetes begin at childhood and are very difficult to change later in life.  The advertising campaign was global and it did more damage in undeveloped countries where the water needed to dilute formula is often not safe.  Although the health consequences of using formula are well known, the advertising campaign continues to this day.  The New York Times ran a full-page advertisement for formula recently, using convenience as its approach, suggesting that modern mothers should not be guilt-tripped into breast feeding. 

Not the end of the story

We landed in this dietary and environmental disaster zone over thousands of years of small, incremental changes that were imperceptible at the time.  We could not foresee the consequences of the cumulative effect of each small step along the road to this dead end.  And Bittman says we can back out of this dead end in the same way, by making small steps back to regenerative farming.  Bittman’s final chapters are devoted to the many projects all over the world devoted to restoring our agricultural land, our diets, and our health. 

This brief summary of Bittman’s book does not do it justice.  There are a multitude of other important factors to consider, such as the huge contribution that industrial agriculture is making to climate change and the changes in raising animals that are just as unhealthy as how we are growing our plant-based food.  I can’t say that Bittman’s book is a pleasant read, but I assure you that it is important. 

Update on California’s 30X30 initiative: The good, the bad, and the ugly

In May 2021, Conservation Sense and Nonsense introduced California’s $11 billion investment in addressing climate change and protecting biodiversity by protecting 30% of land and coastal waters by 2030 (30X30). Since then, 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. Today I am reporting what I learned about the initiative and tell you my opinion of what I learned.

Update: The final California budget commits $15 billion for climate change and protecting biodiversity.

Good news always comes first

The Land Conservation Panel identified the opportunity to remediate degraded spaces that will address many of the objectives of the 30X30 initiative.  Many degraded spaces are found in poor communities that are exposed to toxic waste and pollution.  Eliminating public health hazards in these communities will not only improve their health, it will make those spaces available for recreational and other purposes.  Here are just a few of many such opportunities in California:

Superfund sites in California as of 2013. Source: Environmental Protection Agency
  • There are 94 toxic waste Superfund sites in California.  Where these sites are threatening the health and safety of the public they should be high priorities for remediation.  For example, nearly 30,000 corroding barrels of DDT were recently found on the ocean floor near Catalina Island.  The extent of that particular toxic dump was not known at the time the LA Times reported it, but investigating scientists speculated that as many as half a million barrels may have been dumped by the manufacturer of DDT.
  • There are 47,000 abandoned mine sites in California, according to the Bureau of Land management.  84% of those sites present physical safety hazards and 11% of the sites present environmental safety hazards.  Abandoned mine sites that are potential recreational areas in underserved communities should be considered high priorities for remediation.
  • The California Clean Water Act identifies “impaired waters.”  The list of impaired waters is long and it is alarming.  It identifies pollution with toxic substances such as mercury, diazinon, sewage from leaking septic tanks, sedimentation from erosion, run off of agricultural chemicals, etc.  Addressing these issues will reduce public health hazards and improve fish and wildlife habitat.  Most rivers in California are ultimately watersheds into the ocean, therefore cleaning up these “impaired waters” will also improve ocean health.  At this time of extreme drought and the expectation of continuing drought, water quality should be a high priority for the 30X30 initiative.
  • There are over 5,000 orphan oil wells in California with no known responsible operator.  Capping and retiring these oil wells would reduce health hazards and make the land available for recreational and other uses.  These abandoned oil wells are frequently found in economically disadvantaged areas such as Bakersfield and poor areas in the Los Angeles basin, which is all the more reason to remediate this blight on the landscape. 

The remediation of hazardous pollution would benefit Californians, reducing health hazards for humans and wildlife and potentially making land available for other useful purposes.  Remediating polluted, dangerous land must be a higher priority than funding the horticultural preferences of hobbyists with romantic notions about recreating a landscape that is long gone and cannot be replicated.  If we are to achieve durable objectives, we must have realistic expectations and goals that are consistent with current and anticipated climate conditions.  Thriving landscapes that do not require irrigation should not be replaced with fragile landscapes that require irrigation and access restrictions.  No land that requires pesticides to accomplish “conservation” goals can legitimately be called “conserved.”

Not so good indicators of destructive projects

Although the Summary Document of the Panel for Coastal Waters made vague references to the importance of “Linking protection of land and coastal ecosystems through adjacent terrestrial and marine protected areas,” the words “watershed” and “wetlands” do not appear in the Summary Document.  No specific suggestions were made to address the close relationship between coastal land and coastal waters.

The preservation and expansion of wetlands will reduce the flow of pollution from land to ocean by acting as a filter of runoff from the land.  Wetlands are also one of our chief defenses against rising sea levels if they are expanded to perform that function.  Wetlands are the nurseries of our fisheries and they provide essential habitat for wildlife.  Wetlands are also significant carbon sinks.  Yet the Summary Document makes no mention of these essential functions that contribute to healthy oceans.

Cleaning up the watersheds that are now draining toxic pollutants into the ocean is a more worthwhile endeavor than anything suggested by the Coastal Waters Summary Document. Most rivers in California are ultimately watersheds into the ocean, therefore cleaning up these “impaired waters” will also improve ocean health.  Many important fish species that migrate from ocean to rivers are killed or harmed by these hazardous contaminants.  The ocean is only as healthy as its watersheds.

Instead of addressing the opportunities to expand wetlands and cleaning up watersheds, the Coastal Waters Panel is proposing an outdated “restoration” approach that begins with killing plants and animals. The attempt to “restore” kelp forests is one of the few specific examples of possible projects that is mentioned in the Panel’s Summary Document.  Like most of these futile projects, that project begins by killing thousands (millions?) of the chosen scapegoat, purple urchins, predators of kelp.  Where urchins are killed kelp is being replanted.  Like most of these projects, the chosen method does not address the underlying causes for declining kelp forests that were killed by ocean heat waves.  Ocean heat waves are a consequence of inexorable climate change.  It is delusional to assume that the heat waves that killed the kelp will not occur again.  Furthermore, the massive die-off of sea stars from a mysterious “wasting syndrome” is an important factor in the explosion of urchin populations that are prey of sea stars.  As you might know, sea stars are making a comeback.  Sea Otters are also predators of urchins.  If their populations weren’t repeatedly suppressed by commercial fishing interests, urchins would have more predators.  In other words, present methods of “restoring” kelp forests are based on inadequate understanding of the food web and the underlying causes of the loss of kelp forests.  Is anyone trying to breed a more heat-tolerant variety of kelp?  Is anyone looking for a functional equivalent in warmer waters?  In other words, the loss of kelp forests is a serious problem, but the methods being used to address it are amateurish and futile.

The Ugly:  Composition of 30X30 panels is deeply flawed

There are representatives of organizations on two 30X30 panels that promote and participate in island eradication projects such as the Farallon Islands project that proposes to kill mice by aerial bombing 1.5 tons of rodenticide on the islands.  One representative on the Biodiversity Panel identifies himself as a “conservation entrepreneur” and the founder of Island Conservation, the organization that has conducted more than 350 island eradications in 65 countries around the world and is participating in the Farallons project.  One member of the Coastal Waters Panel represents Point Blue, an organization that has participated in many deadly projects.  Point Blue actively promotes the Farallons project and has participated in its development. 

The Farallon Islands project is another example of a project that has selected an animal scapegoat for eradication without addressing the underlying cause of the perceived problem, which is a dwindling population of ashy storm petrels.  Mice are the chosen scapegoat despite the fact that they do not harm any birds or their chicks.  The mice are blamed because they are the preferred prey of a small number (8-10) of burrowing owls that prey on the petrel chicks when mice are not available.  The burrowing owls could easily be non-lethally removed from the island (Try walking up to a burrowing owl.  Chances are it won’t flinch.)  The National Park Service removed 44 Golden Eagles from the Channel Islands because they were preying on Channel Island Foxes (after NPS eradicated sheep and goats from the islands that were the Eagles’ preferred prey).  USFWS proposes to kill the mice by aerial bombing 1.5 tons of rodenticides on the Farallons and they acknowledge that hundreds (thousands?) of non-target birds are likely to be collateral damage, as they have been in hundreds of similar projects all over the world.  USFWS claims that the burrowing owls will “go away” if their preferred prey is eliminated.  It seems more likely that the burrowing owls will either be killed by the rodenticide or will eat more birds if that’s all there is to eat.  Second-generation rodenticides were recently banned in California because they are killing non-target birds and mammals.  Unfortunately an exemption for projects considered ecological “restorations” was carved out of that ban. Why the proposed Farallons project is considered a “restoration” is a mystery to me. 

We saw burrowing owls in Argentina in 2010. We walked up to them to test the claim that they are easily disturbed by people. We got even closer than this before the owl reacted.

Similar island eradications have been completed all over the world.  Rats are the usual target of those projects and unlike the mice on the Farallons, there is evidence that rats are capable of harming birds.  However, a significant portion of those projects were unsuccessful because rats are resourceful creatures capable of reproducing quickly after their population is reduced.  More importantly, those projects have killed thousands of non-target birds who ate the poison (or poisoned rats) and contaminated the water around the islands, harming fish and marine mammals that live around the islands.

Island eradications done by Island Conservation

As I told California Natural Resources Agency in my written public comments, Point Blue and Island Conservation should not be represented on 30X30 panels because they are likely applicants for projects that will be funded by the state.  This is a serious conflict of interest.  Point Blue is involved in hundreds of destructive projects all over California, including surveying barred owls in preparation for shooting them. Island Conservation has published a study that identified other islands off the coast of California for potential island eradications.  If these organizations are in a position to influence the types of projects that are funded by the 30X30 initiative, they will be in a position to profit from creating projects they can perform. 

Several of the public commenters at the Coastal Waters workshop on August 17th mentioned that there is no representation on the Coastal Waters Panel of recreational and commercial fishermen.  Other panels include representation of recreational interests because increasing recreational opportunities is one of the primary goals of the 30X30 initiative.  Point Blue should be replaced on the Coastal Waters Panel by representation of recreational and commercial fishermen. 

Where do we go from here?

You can view the 30X30 workshops on CNRA’s You Tube Channel. You can read the recommendations of the 30X30 panels on CNRA’s website.  And you can respond to CNRA’s invitation to send them pictures of successful restoration projects:

“If you or your organization has images of before and after climate smart land management projects, successful nature-based solutions; or iconic California landscapes we would love to feature them!…If your organization is interested in sharing pictures, please email them to Heather Williams at the California Natural Resources Agency (CNRA) by September 17. Please include a description/caption of the image, the organization’s name, and the image date(s). Send only high-resolution images (1200×800 or larger). By emailing these pictures, you give CNRA the right to use these images in our nature-based solutions and climate-smart land efforts.”

Organizations that will compete for $11 billion of grant funds will undoubtedly provide many beautiful pictures of their projects.  If you have pictures of projects that were not successful, you may send them as well. 

There will be another round of workshops to review draft plans in Fall 2021.  You can ask to be notified of those workshops and register to attend them by sending an email to californianature@ca.gov.  Plans will be finalized for implementation in January 2022. 

The 30X30 initiative has the potential to be constructive by addressing important issues with viable projects.  It also has the potential to be destructive by destroying harmless plants and animals, poisoning our land, and installing replacement landscapes that are not adapted to current and anticipated environmental conditions.  Our participation in the development of the plans is our only means of influencing the outcome.  California taxpayers will pay for these projects, whether we like them or not.  It is in our hands.

Collaboration triumphs over competition in the forest

“Ecosystems are so similar to human societies—they’re built on relationships. The stronger those are, the more resilient the system.” Suzanne Simard, Finding the Mother Tree

Suzanne Simard is an academic scientist of forestry of some renown because her research has revealed that the forest is a community of plants and trees that share resources to their mutual and communal benefit.  Her recently published memoir, Finding the Mother Tree, about her 40-year career in forestry is deeply personal and informative. 

Simard grew up in the forests of British Columbia in an extended family of traditional loggers who used manual methods to selectively remove individual trees, leaving forests intact.  This is physically demanding and dangerous work, making it a predominantly male occupation. 

After her education as a forester, Simard joined the Canadian Forest Service and a profession dominated by men and committed to maximizing profit by clear cutting patches of forest with mechanized methods.  This policy requires the destruction of all vegetation in clear cuts considered potential competition for the next crop of timber.  After mechanical removal, the ground is sprayed with herbicide from helicopters before being replanted with tree seedlings.  This policy is called “free to grow,” a misnomer that was eventually revealed by Simard’s research.  The plant and tree neighbors of the seedlings are their collaborators in the enterprise of the entire forest, functioning as an ecosystem that creates a home for every life form in the community.

Suzanne Simard’s lonely professional journey in forestry

One of Simard’s first assignments as a forester was to assess the health of seedlings planted in a clear cut.  The seedlings were not doing well.  It became her mission to find out why.  A lifetime of observing healthy forests had taught her that the soil is occupied by vast networks of fungi that connect the plants and trees.  These mycorrhizal fungi transfer moisture and nutrients from the soil to the trees and plants, to their benefit.  She speculated that the destruction of all vegetation in clear cuts was eliminating that support structure and she designed experiments to test her hypothesis. 

Douglas fir forest, MacMillan Provincial Forest, Vancouver, British Columbia

Her experimental plots were divided into areas with varying degrees of vegetation clearance.  At one extreme, seedlings were isolated by sheets of metal buried deep into the soil that prevented development of mycorrhizal networks to support the seedlings.  Decades later, these isolated seedlings were the most likely to have died.  The seedlings that survived most often were on the perimeter of clear cuts, with access to the surrounding intact forest.

The relationships between tree and plant species and their mycorrhizal networks vary by plant and fungi species.  There are thousands of mycorrhizal fungi species associated with trees and about half are generalists that associate with most tree species.  Specialist species of fungi are confined to a narrower range of tree species, genera, or families.  There are fewer species of mycorrhizae associated with plants and most are generalists. 

The specifics of fungal associations between trees also varies, which requires that we describe a specific relationship.  Simard’s original studies focused on the fungal associations between Douglas fir and birch trees.  Birch trees were destroyed in the clear cuts that were then planted with Douglas fir seedlings that were not doing well.  Simard’s experiments eventually revealed that birch trees and firs mutually benefit one another through their fungal networks.  Carbon stored and the sugar produced by photosynthesis by firs are shared with deciduous birch during winter months while they are leafless.  In summer months when birch are foliated, they store more carbon that is shared with firs.  Birch is resistant to a root pathogen to which firs are susceptible.  In a sharing fungal relationship between birch and firs, birch confers some of that resistance to the root pathogen onto their fir neighbors.

Nitrogen is essential to plant and tree health, but not all species are capable of converting atmospheric nitrogen to soil nitrogen available to plants.  When a nitrogen-fixing plant is associated with a plant without that capability, it can share its nitrogen with its neighbor through their fungal network. 

A mature tree can store more moisture than its young seedlings without extensive root structure.  The mature tree can share its stored moisture with struggling seedlings through its fungal network.  Seedlings with access to that network are more likely to survive while establishing their own root structures.  Research of Simard’s graduate students and collaborators eventually found that such sharing of resources between mature and young trees occurs more frequently within the same species, but sharing also occurs with unrelated tree species.  The mature trees nurture their offspring, enabling their survival and the survival of the species.  They are, in effect, Mother Trees.

MacMillan Provincial Forest, Vancouver, British Columbia

Herbicides used to kill vegetation in clear cuts

Another early assignment by the forest service required that Simard determine the most effective herbicide regimen to kill plants in clear cuts perceived to be potential competitors of the seedlings of the next timber crop.  Simard and her sister applied several different concentrations of herbicide to vegetation and predictably determined that the most concentrated formulation of herbicide was the most deadly.  Glyphosate is the most commonly used herbicide for this purpose.

This particular episode in Simard’s early career was disturbing in view of the fact that she eventually developed breast cancer that nearly killed her.  Simard and her sister were uncomfortable about their assignment and they suited up cautiously as best they knew how while applying herbicide.  The Simard sisters felt ill after an application and they sought medical help from whom they learned that their masks did not contain the necessary filters.  Required safety measures for herbicide applicators are only as good as the knowledge on which they are based.  That knowledge moves slowly forward and becomes more alarming as we learn more.

What has the timber industry learned from Simard’s research?

The short answer to that question is very little.  The strategy of the timber industry in both Canada and the US remains clear cuts that destroy all trees and vegetation followed by herbicide application by helicopter to kill all herbaceous vegetation before seedlings are planted.  Simard reports that concentrations of herbicide have been reduced recently.  She also says that a few large, mature trees are sometimes spared by clear cuts. 

Recent knowledge of the health effects of glyphosate is causing some concern, but few changes in policy or practice have been made.  Declining moose populations in a region of Canada led to decreased herbicide applications.  Legislators in the State of Maine recently passed a law to ban herbicide applications in timber clear cuts.  That legislation was then vetoed by the Governor of Maine.

Strangely, none of these reports of reduced herbicide use by the timber industry mention that herbicides are known to damage mycorrhizae.  Health concerns are cited as the sole reason for reducing herbicide use despite the fact that we now know the importance of mycorrhizal networks to the health and survival of forests.  While Simard opposes the use of herbicides in forests, she does not explicitly connect herbicides with the destruction of mycorrhizal networks that enable the survival of tree seedlings. 

Are these studies relevant to our urban forest?

Those who are looking for support for our urban forest in Simard’s work will be disappointed.  Her focus is on the health and preservation of native forests. In fact, she has harsh words for “exotic weed invasions:” She says they are accelerating the decline of native grassland “possibly by sending the native grasses some poisons or an infection to finish the murder.  Or starving them, taking over their energy, degrading the native prairie. Like the invasion of the body snatchers.  Or the colonization of the Americas by Europeans.”  Note that her indictment is speculative and not the conclusion of an empirical study.   

But the principles of Simard’s findings are relevant to our concerns for the destruction of our urban forests and the herbicides used for that purpose.  Mycorrhizal fungi are as essential to urban forests as they are to native forests.  Herbicides used in our urban forests are as damaging to fungal networks as they are to clear cuts of native forests. 

Trees, Truffles, and Beasts (1) was written by academic foresters in Oregon and Australia who are primarily concerned about the destructive consequences of destroying native forests and replacing them with timber plantations, often of another, faster growing species.  Ironically, in the case of old growth eucalyptus forests in Australia, the choice of replacement species is often Monterey pines.  Since some species of mycorrhizal fungi are specific to certain species or types of trees, this change of species is not successful without the inoculation of appropriate species of fungi.  For example, some of the mycorrhizal fungi that grow on the roots of conifers are not found on eucalyptus species.

I corresponded with the authors of Trees, Truffles, and Beasts to confirm that fungi are found in the eucalyptus forests of California.  Since eucalyptus was brought to California as seeds, rather than potted plants, I needed confirmation that our eucalyptus forests are also enjoying the benefits of mycorrhizal fungi.  We are grateful that the authors replied.  They report that eucalyptus forests in California are indeed populated with generalist fungi, including some species that are native to Australia.  Therefore, we can assure our readers that our description of how the forest functions as a community applies to the eucalyptus forest in California, as well as in Australia.

When eucalyptus is destroyed in California their stumps are immediately sprayed with herbicide (usually Garlon) so the tree does not resprout.  The herbicide is carried into the roots of the tree through the cambium layer that is briefly functional after the tree is destroyed.  Garlon is known to damage mycorrhizal fungi.

Herbicide is also used to destroy the non-native vegetation that thrives in the full sun after trees are destroyed.  Glyposate that is commonly used for that purpose is known to kill microbes that are essential to soil health, handicapping any replacement planting. 

Suzanne Simard’s mission

Before leaving the Canadian Forest Service, Suzanne Simard made every effort to inform her colleagues of the damage being done by the timber industry and the potential for more successful planting of a new generation of timber if policy and practice were revised to preserve soil health.  In a male-dominated profession that was committed to the methods being used, her message fell on deaf ears.  In fact, her colleagues were openly hostile to her message, making the offer of an academic position welcome relief that gave her more freedom to conduct research and deliver her message.

After recovering from a nearly fatal bout of breast cancer, Simard became more committed to bringing her research to the attention of the public.  She has delivered inspiring and wildly successful TED talks and she was immortalized as the heroine of The Overstory (2), the barely fictional account of defenders of the forest that made Simard’s research accessible to the general public.

Finding the Mother Tree, Suzanne Simard’s memoir, is a sad reminder of the difficulty of bucking conventional wisdom that is deeply rooted in the profit motive.  In the case of the timber industry, competition remains the dominant narrative that drives policy and the consequences of that approach are unnecessarily destructive.    


  1. Chris Maser, Andrew W. Claridge, James M. Trappe, Trees, Truffles, and Beasts, Rutgers University Press, 2008
  2. The Overstory, Richard Powers, W.W. Norton and Company, 2019.