Oyster Bay: A firehose of public funding supplies a firehose of herbicides

Oyster Bay is one of several East Bay Regional Parks along the east side of the bay that is a former garbage dump built on landfill.  We visited Oyster Bay for the first time in 2011 after a former Deputy General Manager of the park district told us that it is a “beautiful native plant garden” and a model for a similar project at Albany Bulb, another former garbage dump being “restored” by the park district.

When we visited seven years ago, we found a park in the early stages of being destroyed in order to rebuild it as a native plant museum.  Since there were never any native plants on this landfill, we can’t call it a “restoration.”  We took many pictures of the park in 2011 that are available HERE.

We recently decided it was time to revisit the park when we noticed pictures of it in the recently published annual report of the park district’s Integrated Pest Management program, indicating recent changes in the development of the park.  My article today is about what is happening now at Oyster Bay.  It is still not a “beautiful native plant garden.”

“Restoring” grassland

Non-native annual grassland. Oyster Bay April 2011

Seven years ago, most of Oyster Bay was acres of non-native annual grasses.  Since then, most of those acres of grassland have been plowed up and are in various stages of being planted with (one species?) native bunch grass (purple needle grass?).

Stages of grassland conversion. Oyster Bay May 2018

On our May 1st visit, there were at least 8 pesticide application notices posted where the native bunch grass has been planted.  Several different herbicides will be used in those sprayings:  glyphosate, Garlon (triclopyr), and Milestone (aminopyralid).

Herbicide Application Notices, Oyster Bay May 2018

Grassland “restoration” in California is notoriously difficult.  Million Trees has published several articles about futile attempts to convert non-native annual grassland to native grassland:

We wish EBRPD good luck in this effort to convert acres of non-native annual grass into native bunch grass.  Frankly, it looks like a lot of public money down the drain to us.  It also looks like an excuse to use a lot of herbicide.  Who benefits from this project?  Not the taxpayer.  Not the park visitor who is now exposed to a lot of herbicide that wasn’t required in the past.  Not the wildlife, birds, and insects that lived in and ate the non-native vegetation. (We spotted a coyote running through the stumps of bunch grass.  Was he/she looking for cover?)

Redwing blackbird in non-native mustard. Oyster Bay May 2018

Destroying trees and replacing them

P1010129
Pittosporum forest was an excellent visual screen, sound barrier, and wind break. It was healthy and well-suited to the conditions on this site. It was probably home to many animals. Oyster Bay April 2011

When we visited Oyster Bay in 2011, many trees had already been destroyed, but there was still a dense forest of non-native pittosporum.  That forest is gone and the park district has planted one small area with native trees as a “visual screen” of the Waste Management Facility next door.  We identified these native trees and shrubs:  ironwood (native to the Channel Islands), coast live oak, buckeye, toyon, juniper, mallow, holly leaf cherry, and redbud.

Native trees planted at Oyster Bay, May 2018
Ground around trees is green with dye used when herbicide is sprayed. Oyster Bay, May 2018

We also saw a notice of herbicide application near the trees.  The ground around the trees was covered in green dye, which is added to herbicide when it is sprayed so that the applicator can tell what is done.  There were men dressed in white hazard suits, driving park district trucks, apparently getting ready to continue the application of herbicides.

Will the trees survive this poisoning of the soil all around them?  There are many examples of trees being killed by spraying herbicides under them.  Herbicides are often mobile in the soil.  Herbicides damage the soil by killing beneficial microbes and mycorrhizal fungi that facilitate the movement of water and nutrients from the soil to the tree roots.

Herbicide sprayed around newly planted trees. Oyster Bay May 2018

Not a fun day at the park

It wasn’t a fun day at the park and it isn’t fun to write about it.  I decided to tell you about this visit after reading the most recent edition of the Journal of the California Native Plant Society, Fremontia (Vol. 46 No. 1).  The introductory article of this “Special Issue on Urban Wildlands” is illustrated with a photo of Oyster Bay.  I nearly choked on this statement in that article:  “In order to control invasive plants, agencies and volunteers have sometimes resorted to using herbicides as a step in integrated pest control.  While use of herbicides is contentious, the use for spot treatments has enabled small groups of volunteers to successfully eliminate invasive weeds in some areas where future herbicide use will not be needed.” 

That is a PATENTLY FALSE statement.  The California Invasive Plant Council conducted a survey of land managers in 2014.  Ninety-four percent of land managers reported using herbicides to control plants they consider “invasive.”  Sixty-two percent reported using herbicides frequently.  The park district’s most recent IPM report for 2017 corroborates the use of herbicides to eradicate plants they consider “invasive.”  The park district report also makes it clear that they have been spraying herbicide for a very long time.  For example, they have been spraying non-native spartina marsh grass (in the bay and along creeks) with imazapyr for 15 years!

Attempting to eradicate non-native plants is NOT a short-term project.  It is a forever commitment to using herbicides…LOTS of herbicide.  To claim otherwise is to mislead, unless you are completely ignorant of what is actually being done. 

You are paying for this

Another reason why I am publishing this article is to inform you that you are paying for these projects.  The park district recently published a list of 492 active park improvement projects in 2018 (scroll down to page 71), many of which are native plant “restorations.” The majority of them are being paid for with grants of public money from federal, State, and local agencies as well as a few parcel taxes.  Taxpayers had the opportunity to vote for the parcel taxes.  They will have the opportunity to vote for new sources of funding for these projects:

  • Proposition 68 will provide $4.1 BILLION dollars for “park and water” improvements. It will be on your ballot on June 5, 2018. Roughly a third of the money will be allocated for “protection of natural habitats.” (1) Although the project at Oyster Bay does not look “natural” to us, that’s how the park district and other public agencies categorize these projects that (attempt to) convert non-native vegetation to native vegetation.
  • Measure CC renewal will be on the ballot in Alameda and Contra Costa counties on November 6, 2018.  The park district has made a commitment to allocate 40% of the available funding to “natural resource projects.” Although the anticipated revenue (about $50 million) seems small, it is used as leverage to apply for big State grants, which require cost-sharing funding.  Measure CC is essentially seed money for the much bigger federal and State funding sources.

I would like to vote for both of these measures because our parks are very important to me.  If voting for these measures would actually improve the parks, I would do so.  But that’s not what I see happening in our parks.  What I see is a lot of damage:  tree stumps, piles of wood chips, dead vegetation killed by herbicides, herbicide application notices, signs telling me not to step on fragile plants, etc.

Stay out of Oyster Bay to avoid unnecessary exposure to herbicides and keep your dogs out of Oyster Bay for the same reason. Unfortunately wildlife doesn’t have that option. They live there. Oyster Bay, May 2018

  1. “States big bond for little projects,” SF Chronicle, May 5, 2018

Beyond Pesticides: The voice of reason about pesticides

Beyond Pesticides logo

I attended my first Beyond Pesticides forum in 2014 in Portland, Oregon.  I have been a member of and donor to Beyond Pesticides ever since.  And I have purchased only organic food since attending that forum, because of a field trip to a community of farm workers that convinced me that growing our food without using pesticides benefits both consumers and producers of America’s food.  

In a recent letter to the National Invasive Species Council, Beyond Pesticides describes their organization and mission:

Founded in 1981 as a national, grassroots, membership organization that represents community-based organizations and a range of people seeking to bridge the interests of consumers, farmers and farmworkers, Beyond Pesticides advances improved protections from pesticides and alternative pest management strategies that reduce or eliminate a reliance on pesticides.” (The letter is available HERE: Beyond Pesticides – ISAC Comment )

 I receive emails from Beyond Pesticides at least once a week, alerting me to opportunities to influence the laws and policies that regulate pesticide use in America.  As you might expect, the frequency of those alerts has accelerated a great deal in the past year, as the federal government is actively engaged in the process of dismantling many federal regulations, including those that regulate pesticides.

 The National Invasive Species Council recently invited the public to submit public comments in answer to a few specific questions, in preparation for the next meeting of the Invasive Species Advisory Council.  Today I am publishing an excerpt of the letter of Beyond Pesticides in answer to those questions (some emphasis added).  I am doing so because I consider this letter a wise and informed critique of the entire concept of “invasive species” and the pesticides used to eradicate them.

 I am also alerting the readers of Million Trees to the opportunity to attend the annual forum of Beyond Pesticides in Irvine, California, April 13-14, 2018.  Information about that meeting is available below.

 Million Trees


“The National Invasive Species Council (NISC) posed four questions for public input to the forthcoming meeting of the Invasive Species Advisory Council (ISAC). We find it most helpful to begin with the fourth: “How can NISC foster the development and application of innovative tools and technologies to enable the prevention, eradication, and control of invasive species in a more timely and effective manner?”

In order to address this question, NISC and ISAC need to first address the question, “What is an ‘invasive species’?”

‘Invasive species’ have frequently provided a reason for dispersing toxic chemicals in the environment, often with a sense of urgency and an assumed indisputable benefit. This unsupported (and sometimes unstated) assertion of benefit is a claim to virtue that allows environmental harm instead of preventing it.

In the context of other federal, state, and local laws, the regulatory definition of ‘invasive species’ gives broad authority to agencies to use all means at their disposal to rid the jurisdiction of non-native organisms causing economic harm, as well as harm to health and the environment. Many local ordinances that ban or restrict pesticide use make an exception for ‘invasive species,’ presumably under the mistaken assumption that in doing so they are protecting the environment. Instead, they are allowing environmental harm through the spread of toxic substances.

The use of the term ‘invasive species’ as a claim to virtue that is used to promote any and every attempt to exterminate any unwanted organisms is very disturbing. It is important to understand the problems that lead to the use of toxic chemicals, beginning with the cause. In the case of situations involving so-called ‘invasive species,’ we find that few, if any, involve species that are truly ecologically invasive—that is, capable of invading and persisting in intact ecosystems. Instead, such situations usually involve species that can take advantage of disturbed habitats (‘weeds’ or ‘weedy species’). As such, the emphasis should be placed on healing the disturbance (to which end, so-called ‘invasives’ may sometimes be helpful), rather than killing the opportunist colonizer.

We do not take the position that such opportunist colonizers should never be removed or managed. We do believe that the decision concerning whether such action should be taken should be based on the situation at hand and not on a claim to virtue that makes extermination of non-natives a righteous cause.

Redefining ‘invasive species’ to be limited to those species that can invade and damage intact ecological communities will directly ‘foster the development and application of innovative tools and technologies to enable the prevention, eradication, and control of invasive species in a more timely and effective manner’ (NISC) because resources will be directed only at those species that truly present an ecological threat. It will prevent those resources from being squandered in ways that are ecologically destructive.

The sharper focus that this redefinition will bring to the NISC and ASIC will enable them to explore approaches such as those that Beyond Pesticides has used in working with National Parks, local governments, and tribes to manage ecological problems in a way that is truly protective of biodiversity.”

Terry Shistar, Ph.D.
Board of Directors
Beyond Pesticides


Beyond Pesticides will soon hold its annual forum in Irvine, California, April 13-14, 2018.  As usual, the forum will include highly qualified speakers who are knowledgeable about so-called “invasive species,” and the evolutionary principles that raise questions about the necessity and futility of trying to eradicate them.   Two of the speakers are important to our local effort to stop the use of pesticides to eradicate non-native plant species:  Dr. Scott Carroll and Professor Tyrone Hayes.

Dr. Scott Carroll is an evolutionary biologist affiliated with UC Davis.  He has published several influential studies about the speed of adaptation and evolution that enables introduced plants to join native ecosystems without long-term negative consequences of their introduction.  He has coined the concept of “Conciliation Biology,” which advocates that we turn from efforts to eradicate non-native species in favor of a new approach which manages the co-existence of native and non-native species. 

Professor Tyrone Hayes (UC Berkeley) is best known for his criticism of the herbicide, atrazine, which is harmful to the frogs that he studies.  Unfortunately, Professor Hayes’ opposition to atrazine does not extend to the pesticides being used in the San Francisco Bay Area to eradicate non-native trees and prevent them from resprouting.  Professor Hayes accepts the premise that eucalyptus trees are detrimental to native plants, which justifies the use of herbicides to destroy them, in his opinion.  The herbicide that is used for that purpose (Garlon with active ingredient triclopyr) is just as toxic as atrazine.  Both are organochlorine products that bioaccumulate, persist in the environment for decades, and are endocrine disruptors. 

The Beyond Pesticides forum is likely to generate some lively discussion of the issues that are relevant in the San Francisco Bay Area.  Details about the conference are available HERE.  Beyond Pesticides makes every effort to make these forums affordable for activists.  I have attended two of these conferences.  They were excellent opportunities to learn more about pesticides, to meet other activists, and to get ideas about how to advocate more effectively for more responsible pesticide use in our community.

I am very grateful to Beyond Pesticides for their leadership in the effort to reduce pesticide use in the United States.  They are a reliable source of information about pesticides and their activism is an inspiration to those who are engaged in this effort on a local level.

Million Trees

A Bold Initiative: East Bay Regional Park District should stop using pesticide

In preparation for writing the ballot measure that will renew Measure CC (the parcel tax that has funded park improvements since 2005), East Bay Regional Park District has invited the public to suggest projects for the parcel tax renewal that will be on the ballot in November 2018.  The park district must receive the public’s suggestions by the end of the December to be considered when they write the ballot measure at the beginning of 2018. 

The Sierra Club has submitted its requests to the park district for Measure CC projects, which are broadly described in this recently published column in the San Francisco Examiner.  The Sierra Club’s letter making these requests is available HERE:  Measure CC – from Sierra Club 2  

Million Trees is publishing the suggestion of Marg Hall and Jean Stewart for major investments in the park district’s Integrated Pest Management Program to achieve the ultimate goal of using no pesticides in the parks.

Million Trees


December 8, 2017

To:      publicinformation@ebparks.org

CC:      EBRPD Directors (blane@ebparks.org; wdotson@ebparks.org; drosario@ebparks.org; dwaespi@ebparks.org; ecorbett@ebparks.org; awieskamp@ebparks.org; ccoffey@ebparks.org)

Re:  Measure CC Comments/Proposals

Back in 2004, we both voted for Measure CC out of a desire to support the East Bay Regional Parks. At the time, we couldn’t have imagined that the euphemism “resource-related projects” meant funding the destruction of thousands of healthy eucalyptus trees and the subsequent application of pesticides. (1)  Had this fact been clearly stated, we never would have supported CC. We’ll present herein proposals for Measure CC expenditures which are designed to shift EBRPD to a no-pesticide policy.

PESTICIDES IN THE PARKS ARE NOT POPULAR

A large segment of the local community opposes the use of public money to fund pesticide applications in our parks.  Jane Goodall has observed that humans are the only animal species that insists on spoiling its own nest.  It is self-destructive and unethical of us to poison our own nest, not to mention the homes of countless other species.  Historically, environmentalists have opposed pesticide use; however, the local Sierra Club chapter, in a departure from this tradition, insists that poison be used in East Bay parks to remove “invasive non-native plants.”  They invoke the benign-sounding term “restoration” to garner support for this ecological insanity.  Note that the San Francisco Bay Chapter has never permitted a vote by members on the question of pesticide policies.  In the face of their refusal to poll their own members, community activists conducted a survey of Sierra Club members.  Over 1,876 local members mailed in their response, of whom 1,851 expressed disagreement with their own leadership!  (25 expressed agreement.)  For perspective, that’s more respondents than vote in the chapter elections!  (In 2015, the candidate for Chapter Executive Committee with the greatest number of votes received only 1,139 votes.)

WHAT’S IN THAT STUFF YOU’RE SPRAYING?

Pesticide regulation in the US is weak, compromised by a cozy relationship with manufacturers.  Pesticides have not been proven to be safe, despite approval of certain chemicals by the EPA.  Bear in mind that in the US, the benefit of the doubt is given to the pesticide maker–no precautionary approach here–so we really don’t know the full extent of damage.  Active ingredients are, of course, poisons, since they’re specifically designed to kill plants and animals.  But so-called “inert” ingredients are poisonous as well.

Among the EPA’s many regulatory failures is the fact that, for the most part, “inert ingredients” get a pass.  Pesticide formulations (e.g. Roundup) contain chemicals intended to increase potency.  Agricultural pesticides contain more than 50% inert ingredients.  Independent scientists investigating the safety of inert ingredients have uncovered evidence of harm that should be of great concern, including many hundreds of hazardous chemicals, carcinogens, and even chemicals considered to be active ingredients when used in a different product. (2)

DDT provides an illustrative cautionary tale. While it was banned in the US in 1972, DDT continued to be used in pesticides as an “inert” (!) ingredient, in a product named Kelthane. (3) This continued for TEN years! Even though DDT (and DDE, its metabolite) is a potent endocrine disruptor, the causal link to breast cancer has been hard to establish.  Among the reasons for this is that breast cancer’s long latency period made such research challenging. Just two years ago the results of a large study conducted by Kaiser Oakland were released. (9,300 women with a 54-year follow-up.) Blood levels of pregnant women were tested between the years 1959 and 1962. Female offspring of those who tested with high DDT levels were 4 times likelier to develop breast cancer by age 52, compared with controls. (4) Women are still paying the price for the regulatory failures of the past. Don’t you owe it to future generations to ask yourselves what other time bombs lurk in the chemical poisons you spread?

POISON WHACK-A-MOLE

EBRPD often uses glyphosate (aka Roundup), long touted as extremely safe by manufacturers.  In 2015, the World Health Organization declared glyphosate to be a “probable human carcinogen.”  However, merely focusing on Roundup can lull us into believing that the solution lies in banning glyphosate.  This naive thinking fails to take into account the legions of newer and less-scrutinized pesticides lining up to take Roundup’s place in a game of poison whack-a-mole.

Pesticide Application Notice, Heron’s Head, 2012

Two projects which were funded by Measure CC “required” pesticides: triclopyr (Garlon) to prevent the re-sprouting of eucalyptus trees, and imazapyr (Polaris) to remove the “non-native” grass Spartina along San Francisco’s Bay shoreline.   EBRPD’s own literature counts among successful CC projects: “Marsh cleanup at Martin Luther King Jr. Regional Shoreline, including Clapper Rail habitat enhancement and Spartina control” as well as “restoration of grasslands…at Pt. Pinole Regional Park”. (5) Based on your own reports, Spartina control projects have required the application of hundreds of gallons of imazapyr, some by aerial spray.

Imazapyr is toxic to fish, aquatic organisms and bees. Water soluble, it’s highly mobile and persistent; in one Swedish study, it was detectible in ground water eight years after application. (6)

As for triclopyr, much of the information has not been publicly shared. Thus scientists’ ability to conduct a well-informed evaluation of its safety is limited. We do know, however, that it significantly increases the frequency of breast cancer in both rats and mice. Despite this finding, the EPA has violated its own guidelines by refusing to classify this chemical as a carcinogen. We also know it has an adverse effect on frogs at very low exposures, and it causes documented harm to birds, fish, beneficial insects, and non-targeted plants. (7)

We can’t afford to wait 50 years to know a pesticide’s full effect. Especially now, under the current administration, corporations and politicians not only bully scientists but are systematically destroying the EPA.  Now more than ever, local communities urgently need to rise to the occasion. This is where you come in.

DARE TO BE BOLD

Though she was writing about agricultural pesticides, Sandra Steingraber throws down a highly relevant challenge:

“I believe it is time for a new human experiment. The old experiment…is that we have sprayed pesticides which are inherent poisons…throughout our shared environment. They are now in amniotic fluid. They’re in our blood. They’re in our urine. They’re in our exhaled breath. They are in mothers’ milk….What is the burden of cancer that we can attribute to this use of poisons in our agricultural system?…We won’t really know the answer until we do the other experiment, which is to take the poisons out of our food chain, embrace a different kind of agriculture, and see what happens.” (8)

We propose a bold initiative. You’ve created an admirable IPM program; why not build on it by taking up Steingraber’s challenge? Use CC funding to make a commitment to a “no pesticide” policy. This would provide national leadership at a time when it is desperately needed. 

Here are some practical suggestions to that end:

Expand IPM funding: Give staff the resources they need to innovate.

Go Deep: “Invasive” plants are not a problem to be eradicated but a symptom of an underlying dysfunction. Hire experts who can help you develop holistic solutions to ecosystem imbalances. Two who come to mind are Tao Orion (author of Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration) and Caroline Cox (Center for Environmental Health). (9) Send your IPM staff to the yearly Beyond Pesticides conference.

Adopt the Precautionary Principle, which is based on the understanding that decision-makers have a social responsibility to protect the public from harm. The burden of proof of the harmlessness of a proposed action shifts from poison-manufacturers to…you.

Red-tailed hawk nesting in eucalyptus. Courtesy urbanwildness.org

Plant tall trees: Having already cut thousands of living tall trees, you’re now faced with the reality of climate change. Reforestation becomes an urgent ethical imperative. Tall trees are not only carbon sinks; they also capture fog, provide raptor habitat (thus eliminating the need for rodenticides), and provide natural, nonchemical undergrowth suppression, especially in those same areas where you’ve been reapplying pesticides over and over, in a futile attempt to kill “weeds”. And of course, it goes without saying: no more cutting of healthy trees, young or old!

Experiment: Expand your existing programs of experimental plots testing various pesticide-free approaches to management of “invasive” or “opportunistic” plants.

Avoid “Restoration”: These projects almost always involve pesticides which damage the soil and many non-targeted plants and animals. If a goal can’t be achieved without them, it’s not worth doing. Restoration projects should be based in science rather than prejudice. Tao Orion’s chapter on Spartina eradication compellingly makes this case. (10)

Embrace change: Rigid nativism has no place on this planet, whether applied to humans, plants, or animals. Once you begin to appreciate those resilient plants and animals that have managed to adapt to each other in a new environment, you’ll stop fretting over their immigration status, and you won’t be so tempted to employ pesticides.

Jean Stewart, El Sobrante, CA
Marg Hall, Berkeley, CA

NOTE: Both authors have had cancer. Jean Stewart, a botanist, acquired cancer as a result of exposure to herbicides while handling them in a lab. Her tumor required several surgeries, leaving her disabled. Marg Hall reports: “I was diagnosed with invasive breast cancer in 2015. While I don’t know my mom’s blood levels of DDT when I was in her womb, there are still detectable levels of DDT in my household dust—45 years after it was banned from use!”

FOOTNOTES:

  1. Full text of Measure CC (July 20, 2004) and Approval of Spending Plan (Aug 3, 2004), Section 5, “Use of Tax Proceeds.” http://www.ebparks.org/Assets/Features/Measure+CC/fulltextmeasurecc.pdf
  2. Orion, T., Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration (Chelsea Green Publishing, 2015), p.26. Also, Cox and Surgan, “Unidentified Inert Ingredients in Pesticides: Implications for Human and Environmental Health,” Environmental Health Perspectives (2006): 1803-1806. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1764160/
  3. Vallianatos, E.G. & Jenkins, M., Poison Spring: The Secret History of Pollution and the EPA (Bloomsbury Press, 2014), ch.4.
  4. Cohn, B. et al, “DDT Exposure in Utero and Breast Cancer,” The Journal of Clinical Endocrinology and Metabolism, August 2015, vol. 100, Issue 8. “DDT Exposure in Utero and Breast Cancer.”
  5. http://www.ebparks.org/Assets/Agendas+Packets+Minutes/3.+Park+Advisory+-+Committee+Meetings/06-26-2017/06-26-2017++-+Park+Advisory+Packet.pdf (see Attachment 2, p. 2)
  6. Correspondence from Beyond Pesticides (a nonprofit in Washington, DC, founded in 1981) to Massachusetts Dept. of Agricultural Resources, Feb. 18, 2014, pp. 7-8
    http://www.beyondpesticides.org/assets/media/documents/NSTAR 2014 YOP Comments 2-18-2014.pdf
  7. For a detailed independent review of triclopyr, see Cox, C., “Herbicide Factsheet: Triclopyr”, Journal of Pesticide Reform, Winter 2000, Vol. 20, No. 4
    https://d3n8a8pro7vhmx.cloudfront.net/ncap/pages/26/attachments/original/1428423464/triclopyr.pdf?1428423464
    And here’s a helpful pesticide directory:
    http://www.pesticide.org/pesticide_factsheets
  8. Steingraber, S. quoted in President’s Cancer Panel Report: Reducing Environmental Cancer Risk: What We Can Do Now; April 2010, Section 2, page 45. Read the President’s Cancer Panel’s Report.
    http://steingraber.com/1447/
  9. Cox, C. “Band-Aids Are Not Enough,” Journal of Pesticide Reform, Spring 1997, Vol. 17, No.1
    http://eap.mcgill.ca/MagRack/JPR/JPR_30.htm
  10. Orion, T., Ibid, Ch. 2

Renewal of Measure CC is an opportunity to determine the future of parks in the East Bay

In 2004, voters in Alameda and Contra Costa counties approved Measure CC, a parcel tax, to provide additional funding to East Bay Regional Park District for “Park Access, Infrastructure and Safety Improvements, Resource-Related Projects, and Reserve for Unknown Events.”  Measure CC also stipulated that “the overall commitment to natural resources shall be no less than 30% of the revenue raised by the entire measure.” (1) Measure CC is projected to provide about $47 million in the 15 years of its life. (2)

The park district is planning to put Measure CC on the ballot for renewal next year.  It’s time to look at how the park district spent our tax dollars and decide if we want to continue to give them our tax dollars for another 15 years.  If you want Measure CC funding to be used differently, now is the time to tell East Bay Regional Park District what you want…BEFORE the ballot measure is written.

Fuels Management vs. Resource Management?

The park district budgeted $10.2 million of Measure CC funding for “fuels management,” about 22% of the total available funding from Measure CC.  To date, the park district has appropriated $8.8 million of that budget allocation and spent $6.3 million.

The park district describes “fuels management:”  “All vegetation/fuels management projects for fuels reduction are in coordination with the protection and enhancement of wildlife habitat in fuel break areas and are therefore considered to be resource related.” (2)  In other words, the park district considers destroying vegetation and cutting down trees a part of its “commitment to natural resources.”

These descriptions of Measure CC projects illustrate the close relationship between fuels management and resource management: 

  • “Assess and remove hazardous trees, promote native tree regeneration.” (2)
  • “Manage exotic plant species and promote fire resistant natives to reduce the risk of wildfires.” (2)
  • “Manage vegetation for fuels reduction in coordination with the protection and enhancement of wildlife habitat in fuel break areas to provide defensible space and meet Hills Emergency Forum flame length standard.” (2)

The park district’s policies and practices are based on mistaken assumptions:

  • There is no evidence that native plants and trees are less flammable than non-native plants and trees. In fact, available evidence suggests that native landscapes in California are highly flammable.
  • Most monarchs in California spend the winter months roosting in eucalyptus trees. These trees are being destroyed in East Bay parks where monarchs have roosted in the past, such as Point Pinole.

    There is no evidence that destroying non-native trees will “enhance wildlife habitat.” In fact, wildlife habitat is being destroyed by “fuels management” projects.

The destruction of non-native trees is also controversial because the stumps of the trees and shrubs that are cut down must be sprayed with herbicide to prevent them from resprouting.  The park district used an average of 26 gallons of Garlon each year from 2000 to 2015 and 39 gallons in 2016, for that purpose.

There is a wide range of opinions about the tree removals that the park district has done since their program began in 2011, after approval of the “Wildfire Hazard Reduction and Resource Management Plan” and the associated Environmental Impact Report.  At one extreme, some people want the park district to destroy ALL non-native trees on its property.  They consider “thinning” inadequate. The Sierra Club is in that camp and has sued to enforce their wishes.  At the other extreme, some people don’t want any trees to be removed, although most would make an exception for dead and hazardous trees.

Tilden Park, Recommended Treatment Area TI001, June 5, 2016. This in one of the projects of East Bay Regional Park District, in process

After observing the park district’s tree removal projects, I have reached the conclusion that they represent a middle ground that I can accept because in many cases the canopy is intact and the forest floor is still shaded.  The shade retains the moisture that retards fire ignition as well as suppresses the growth of weeds that ignite more easily during the dry season.  In the 20+ years that I have defended our urban forest, I was always willing to accept a compromise and the park district’s methods look like a compromise to me.  I still have concerns about tree removals and they are explained HERE.  You must reach your own conclusions.

So, what’s the beef?

Unfortunately, coming to terms with the park district’s tree removals has not resolved my misgivings about how Measure CC money has been used.  In a nutshell, I believe that the park district’s “resource management” projects are based on outdated conservation practices.  I believe the park district is trying to re-create historic landscapes that are no longer adapted to environmental conditions.  Their projects are often not successful because they do not take the reality of climate change into consideration, nor do they look to the future of our environment.  They are stuck in the past.

One of the projects funded by Measure CC is typical: the effort to eradicate non-native spartina marsh grass from all park properties. The park district has been participating in the effort to eradicate all non-native spartina marsh grass from the entire West Coast for 14 years.  In the first few years, EBPRD aerial sprayed from helicopters several hundred gallons of herbicide per year.  Now the quantity of herbicide is about 25 gallons per year.

California Clapper Rail

We have known for several years that the eradication of non-native spartina has decimated the population of endangered California rails.  In 2016, a paper was published in a peer reviewed scientific journal about the huge declines in the rail population that were caused by the eradication of spartina.

The reason why the rails have been harmed by the eradication of their habitat is that non-native spartina provides superior cover for the rail.  The non-native species of spartina grows taller, more densely, and it doesn’t die back in the winter as the native species of spartina does.  When the rail begins its nesting season, there is no cover for the birds.  They are therefore being killed by their many predators.

The fact that non-native spartina provides superior cover for the birds is related to a second issue.  Non-native spartina provides superior protection from winter storm surges compared to the native species which provides no protection, even when it grows and it is NOT growing.

The US Geological Survey recently reported that sea level on the Coast of California is predicted to rise as much as 10 feet in just 70 years.  USGS predicted that 67% of Southern California’s beaches are expected to be lost by the end of the century.  Marsh grass for coastal protection is more important than ever.

The third issue is that eradicating non-native spartina has not resulted in the return of native spartina.  Even when extensive planting has been done, native spartina does not provide habitat or storm surge protection in the San Francisco Bay Area.  We should be asking if pouring hundreds of gallons of herbicide on the ground might be a factor in the unsuccessful attempt to bring native spartina back to the Bay Area.

Finally, recently published studies that compared native with non-native marsh grasses and aquatic plants with respect to the ecological functions they perform.  These studies both say, “If you look at the role of exotic water plants in an ecosystem, you won’t find any significant differences compared to indigenous species.”

The spartina eradication project is an example of conservation that no longer makes sense.  It damages the environment with herbicides.  It destroys the habitat of rare birds.  It exposes our shoreline to strong storm surges and rising sea levels.  Native vegetation does not return when it is eradicated.

Looking forward, not back

The parks are very important to me.  I visit them often and I treasure those visits.  I would like to vote for Measure CC.  I hope that the measure on the ballot will give me a reason to vote for it.

I will be looking for a revised definition of “resource management” in the ballot measure, one that acknowledges that climate change is the environmental issue of our time and that conservation must be consistent with the changes that have already occurred, as well as look forward to the changes that are anticipated in the future.  Specifically, “resource management” must respect the landscape we have now, which means not trying to eradicate it, particularly by spraying it with herbicides.  Resource management projects must be based on reality, rather than on fantasies about the past.

Opportunities to tell EBRPD what you want from Measure CC

East Bay Regional Park District is holding public meetings about Measure CC to give the public the opportunity to provide input regarding future park needs and priorities:

November 4, 10-12, Harrison Recreation Center, 1450 High St, Alameda

November 8, 2:30-4:30 pm, David Wendel Conference Center, 1111 Broadway, 19th Floor, Oakland

EBRPD asks that the public RSVP by sending an email to Monique Salas at msalas@ebparks.org or call 510-544-2008.

If you can’t attend, please send written feedback here:  publicinformation@ebparks.org.  Please tell East Bay Regional Park District what you want Measure CC funding to pay for. 


  1. Full Text of Measure CC
  2. Agenda of Park Advisory Committee, June 26, 2017. Scroll down to Measure CC Renewal Spending Plan

Butterfly Bush: An example of the escalating war on non-native plants

The war on so-called “invasive species” continues to escalate.  One of the indicators of this escalation is the recently revised California Invasive Plant Council’s (Cal-IPC) inventory of “invasive” plants.  Nearly 100 plant species were added, a 50% increase in the inventory. 

Scabiosa is one of 87 plants recently added to the inventory of “invasive” plants in California, despite the fact that is isn’t invasive in California. Scabiosa is very useful to bees because it blooms prolifically for much of the year.

More alarming is that most of the additions to the list are not considered “invasive” in California.  Rather, a new category of “potentially” invasive plants was created, based on their behavior elsewhere.  Many of the plants in the new category are considered invasive in Hawaii, a place with a distinctly different climate than California.  Hawaii is a tropical climate, hotter than much of California and wetter and more humid than everywhere in California.

The big increase in the number of plant species now designated as “invasive” in California is a concern partly because of the herbicides that are usually used to eradicate them.  Not only do we lose that plant species in our landscape when it is added to the hit list, we can also expect to see an increase in the use of the herbicides that are used to kill it.

Increased use of herbicides

Native plant advocates are aggressively defending the use of herbicides. Policies and practices are being developed to accommodate increased use of herbicides on our public lands.

East Bay Municipal Utilities District (EBMUD) is evaluating its Integrated Pest Management Program (IPM), including practices and policies regarding pesticide use.  The first draft of EBMUD’s revised IPM program was made available to the public in July 2017.  The draft adds several new goals to the IPM program:  “habitat protection and restoration,” reducing populations of “invasive plant species,” and “use of alternative vegetation such as native plants.”  EBMUD is the supplier of our drinking water in the East Bay and the quality of the water they supply should be the top—if not the only—priority.  If destroying non-native plants requires greater use of herbicides, that goal contradicts EBMUD’s obligation to providing safe drinking water.

Garlon sprayed on the trail in a San Francisco park. San Francisco Forest Alliance

San Francisco’s IPM program has also changed some policies to accommodate use of herbicides in parks on plants the Natural Resource Division of the parks department considers “invasive.”  The parks department restricts all park access to the established trails in the 33 “natural areas” where non-native plants are eradicated and replaced by native plants.  The new IPM policy permits the spraying of herbicides without posting pesticide application notices in places that are “publicly inaccessible.”  In other words, pesticide application notices are no longer required in the “natural areas” unless herbicides are sprayed on the trails.  One way to reduce the public’s opposition to pesticides is to hide their use and this policy seems designed to do that.

Update:   The San Francisco Forest Alliance (SFFA) has informed me that Chris Geiger, head of San Francisco’s IPM program, has given assurances that the IPM program will no longer offer City departments a blanket exemption to apply herbicides without posting in areas the department considers “publicly inaccessible”.  Previous to this, each land manager was empowered to make their own decisions as to which areas they considered “publicly inaccessible”.  The IPM group did not provide oversight of the decisions or keep records of which areas were exempted.  Now specific exemptions will be issued and recorded on the IPM exemptions webpage.  Chris Geiger reports RPD will not be requesting any posting exemptions.   SFFA is still waiting for formal written documentation of this change.

San Francisco’s IPM Program is also demonstrating its commitment to native plants and the eradication of non-native plants by sponsoring a webinar on October 5th, 2017, featuring Doug Tallamy:  The Plant-Pollinator Connection: Why Pollinators Need Native Plants.”  Tallamy is the academic entomologist who has devoted his career to the promotion of native plants based on his claim that insects at the base of the food web are dependent upon native plants.  He has said in many publications that non-native plants will cause the collapse of our ecosystems.  Many of the statements he makes in support of his dire theory are not accurate.

This post will focus on the intersection of these symptoms of the escalating war on “invasive” plants:  the expansion of California’s inventory of “invasive” plants and the closely associated claim that non-native plants must be eradicated because they compete with the native plants required by wildlife.  We use buddleia, commonly known as butterfly bush, as an example.

Butterfly Bush (Buddleia):  friend or enemy of butterflies?

Monarch nectaring on butterfly bush. butterflybush.com

Buddleia is one of 87 plant species recently added to Cal-IPC’s inventory of “invasive” plant because it is considered invasive outside of California.  Buddleia is called butterfly bush because it produces large quantities of nectar that attract swarms of butterflies.  Since buddleia is very appealing to butterflies, it is popular with gardeners who like to see butterflies in their gardens.

Since buddleia is obviously useful to butterflies and Doug Tallamy claims to be concerned about the welfare of our pollinators, why is he telling gardeners to quit planting buddleia?  His advice is based on the fact that buddleia is considered invasive in some places and his belief that it will eventually be invasive everywhere.  In fact, that’s his belief about all non-native plants:  they may not be invasive now, but he predicts that eventually they all will be invasive.

Secondly, Tallamy argues that although buddleia provides food for butterflies, it is not a host plant for butterflies.  The host plant is where butterflies lay their eggs and where the caterpillar feeds when the eggs hatch.  The choice of host plant species is much smaller than the number of food plant species available to butterflies, but it is not as small as Tallamy thinks it is.  Tallamy does not seem to realize that many plants are chemically similar, which enables butterflies to make a transition from a native plant to a chemically similar non-native plant.  Here in California, many butterfly species have made that transition and a few butterfly species are dependent upon abundant non-native plants that are available year-around because their original native host plant is dormant much of the year.

Buddleia “starves” butterflies?

This is Tallamy’s apocalyptic prediction about the fate of butterflies if gardeners continue to plant buddleia:

“It’s no exaggeration to say that when you choose which plants to include in your garden, even the beautiful, seemingly harmless butterfly bush, you’re deciding if members of your community’s local food web will be nourished or unintentionally starved.  And to get to that mind frame, which is a way of thinking that truly benefits nature, including its butterflies, you’re going to have to come to a harsh realization: You need to stop planting the butterfly bush—forever.” (1)

Ironically, this harsh verdict on buddleia was published by a blog entitled, “Organic Life.”  Is Organic Life unaware of the fact that the most widely used method of eradicating non-native plants is spraying herbicides?  The consequence of adding more plant species to the long list of “bad plants,” is more pesticide use.  That’s not very “organic.”

What amoral, selfish gardener would plant buddleia in their garden after such a severe scolding?  First, let’s stop and think about the logic of the claim that buddleia will disrupt the “food web” and starve butterflies.  Since buddleia is an excellent source of nectar and swarms of butterflies are observed nectaring on buddleia, how could we be “starving” them?  Professor Art Shapiro (UC Davis), our local butterfly expert, said when asked about this article, “The ‘disrupting food webs’ argument is ludicrous. It’s equivalent to saying that if you eat popcorn rather than apples, you’re contributing to unemployment in the apple-picking industry.”

Is buddleia a host plant for butterflies?

Now let’s consider the argument that we should not plant buddleia in our gardens because although it feeds butterflies, it isn’t their host plant where they lay their eggs.  The problem with that argument is that it isn’t true!!

Checkerspot laying eggs on buddleia, near Santa Barbara. Photo by Marc Kummel

In 1940, Charles M. Dammers reported that the Variable Checkerspot (Euphydryas chalcedona) “can use” buddleia as a substitute for its usual native host in southern California desert-mountain areas, based on a laboratory study of the larval stages of its caterpillar on buddleia.   In 2001, chemical analysis of buddleia found that it is chemically similar to the native host of the checkerspot, which confirmed the potential for such a substitution.

The first actual observation of checkerspot butterflies breeding spontaneously and successfully on buddleia was in Mariposa County, California in the Sierra Nevada foothills.  “Mariposa” is Spanish for butterfly.  Mariposa County was named by an early Spanish explorer who saw many butterflies near Chowchilla.

Checkerspot bred successfully on buddleia in 2005 and in subsequent years.  This colony of checkerspot on buddleia was reported in 2009:  “We conclude that buddleia davidii [and other species of buddleia] represents yet another exotic plant adopted as a larval host by a native California butterfly and that other members of the genus may also be used as the opportunity arises.” (2)

Variable checkerspot. Photo by Roger Hall

More recently, a gardener in Mendocino County also reported the use of buddleia as the host plant of checkerspot:

“By now I am questioning how it was that butterfly larvae were using my butterfly bush as a host plant, completely against everything I’d ever heard. How was this possible? I emailed Art Shapiro, a very well-known butterfly expert and author, sending him a pic. He wrote back to confirm they were butterfly larvae, but added, ‘These are not mourning cloak butterflies. They are checkerspots. And the only time I’m aware this has happened [like, ever, except one in a lab in 1940…] is in Mariposa County.’” (3)

Bad rap for non-native plants

When the native plant movement began some 30 years ago, native plant advocates promoted their agenda with a straight-forward claim that they are superior to non-native plants.  The public was initially resistant to that argument because non-native plants have been around for a long time and people have become fond of them.

Native plant advocates began to fabricate stories about the evils of non-native plants to convince the public that eradicating them was necessary because they are harmful to wildlife and they damage the environment.  The Million Trees blog was created to address those claims.

But Doug Tallamy’s active participation in the crusade against non-native plants is a special case because he is an academic entomologist, credentials that make him more influential with the public.  For that reason, Million Trees has critiqued several of his publications.  We publish this critique of Tallamy’s opinion of buddleia for several reasons:

  • Buddleia is very useful to butterflies. The loss of buddleia in our gardens would be a loss to butterflies.
  • San Francisco’s IPM program is using Doug Tallamy’s mistaken theories to promote the use of herbicides to eradicate non-native plants in San Francisco.
  • Buddleia is one of 87 plants that have been classified as “invasive” by the California Invasive Plant Council despite the fact that it is NOT invasive in California. The expansion of the list of “invasive” plants in California to include plants that are NOT invasive in California, will increase the use of herbicides and will eliminate plants that are performing valuable ecological functions.

  1. https://www.rodalesorganiclife.com/garden/never-plant-butterfly-bush  (N.B.  The butterfly in the photo in this article is European Small Tortoiseshell, found in Britain and in Europe.  The caterpillar in the photo is the monarch caterpillar on its host plant, milkweed.  Buddleia is food for both of these butterfly species.)
  2. Arthur M. Shapiro and Katie Hertfelder, “Use of Buddleia as Host Plant by Euphydryas chalcedona in the Sierra Nevada foothills, California,” News of the Lepidopterists’ Society, Spring 2009
  3. http://plantwhateverbringsyoujoy.com/never-pull-up-and-discard-what-you-cannot-identify/

The consequences of dune “restoration” in coastal California

It is my pleasure to publish a guest post about dune “restorations” in Humboldt County that began about 30 years ago.  Like most “restorations,” these projects are primarily destroying non-native plants.  More often than not, they don’t plant native plants to replace the plants they destroy, although the stated goal is to “restore” native plants.

 Uri Driscoll tells us why the non-native plants were planted over 100 years ago and the consequences of removing them.  According to Mr. Driscoll’s Facebook page, he has lived in Arcata, Humboldt County since 1983.  He has had a life-long interest in outdoor recreation, horses, organic farming, and conservation.  He is a member of Arcata’s Open Space and Agriculture Committee.

 If you live in the San Francisco Bay Area, you might think these projects are not relevant to us.  In fact, they have everything to do with us because there are many similar projects here and the issues with those projects are similar. 

Bird’s eye view of San Francisco in 1868. US Library of Congress

 The San Francisco peninsula was about one-third barren sand dunes when Europeans first arrived at the end of the 18th century.  About 30 years ago, native plant advocates decided they wanted whatever open space that still remains on the peninsula to be returned to pre-settlement conditions, including sand dunes where they existed in the past.

These are the sand dunes in San Francisco where Golden Gate Park was built by creating a windbreak by planting trees. The windbreak stabilized the sand dunes and made it possible to plant and sustain vegetation behind the protection of the windbreak. San Francisco Public Library, historical photo collection.
Pacheco & 32nd Ave, San Francisco, 1943. San Francisco Public Library, historical photo collection

As residential neighborhoods in San Francisco were developed, iceplant and European beach grass were planted on the sand dunes to hold the sand in place.  Native dune plants are not capable of stabilizing sand for long, before strong winds move the sand beneath them.  In fact, the long term survival of native dune plants is dependent upon these disturbances. 

Trees were planted on the windward side of residential areas to protect them against the wind.  Sand on the leeward side of the trees was stabilized by the windbreak.  One of the first dune “restorations” in San Francisco proposed to destroy about 4,000 trees in the Presidio in order to restore an endangered dune plant, Lessingia germanorum.  The purpose of destroying the trees was to enable the sand to move again, ensuring the long-term survival of a native dune plant that exists only on the San Francisco peninsula.

Iceplant has been removed from several sand hills in residential neighborhoods, dumping sand on the properties at the base of the hills.  The Great Highway, which separates Ocean Beach from the residential Sunset District is often closed because of drifting sand after removal of beach grass.

In fact, everyone living on the coast of California should have an interest in the preservation of our sand dunes because they are our first line of defense against rising sea levels and the intense storms associated with climate change.  If non-native plants and trees are needed to maintain the stability of our sand dunes, so be it.  Competing agendas must take a back seat to the safety of our coastal communities.

Million Trees


Stable Dunes or Native Plants?

The North and South Spits of Humboldt County are the physical barrier between Humboldt Bay and the Pacific Ocean.  After the introduction of European beach grass (Ammophila arenaria) in the early 1900’s there has been a substantial stabilizing effect on the dunes as they grew wider and taller.  Prior to the establishment of the grass our dunes consisted of wide expanses of unvegetated, open, moving sand. This is in sharp contrast to the variety of plant cover we have today.

Humboldt Bay

In the 1980s public land managers began removing European beach grass with the goal of restoring native vegetation.  This is the story of the consequences of their projects.

Foredunes (the sand ridges parallel to and closest to the shore) with open, actively moving sands have a very high potential for accelerated erosion.  The foredunes of the North Spit and South Spit are still extremely vulnerable to accelerated erosion caused by disturbances to the vegetation.  A beach and dunes management plan and Environmental Impact Report (EIR) was developed in 1993 to address such issues.

Of greater concern, waves have washed over the foredunes on both spits where waves have breached the foredune where vegetative cover had been removed.  Repeated overwash events would significantly and immediately impact the only access road to the South Spit and the municipal water main and water treatment facilities on the North Spit.

These dunes could again be set in motion by removal of the protective cover of native and non-native vegetation.  Indeed, the intention to remobilize dunes was identified in the Conditional Use Permit application Bureau of Land Management (BLM) submitted for vegetation removal at Table Bluff County Park, a portion of the South Spit.  However, those intentions are contrary to the local Humboldt Bay Beach and Dune Management Plan and accompanying EIR.

The danger is that the South Spit’s dune topography is characterized as typically low and narrow.  With erosion and subsequent lowering of the foredune that occurs following vegetation removal, the right combination of concurrent high-magnitude seismic subsidence and wave attack could cause collapse of the land barrier between the Ocean and Humboldt Bay.  With anticipated sea level rise we would see this risk multiply.  

Source: 2008-2014 BLM monitoring report

The problem is that the previous and on-going work to remove European beach grass from the North and South Spits (in the effort to restore natural conditions and processes) has not and does not provide for the immediate re-establishment of other comparable  vegetative cover to trap moving sand and prevent accelerated dune erosion.  By not including this mandated mitigation measure, there is a real, legitimate potential for significant, cumulative environmental impact.

Why was European beach grass introduced?

The important thing to understand is that this specific type of beach grass (Ammophila arenaria) was introduced in Humboldt County in the early 1900’s.  It was done in order to stabilize dunes to protect growing communities and infrastructure. It had the additional benefit of creating extensive coastal wetlands and wildlife habitat.  By collecting sand from the beach the grass builds protective and multiple parallel ridges and accompanying deflation planes. These depressions behind the ridges act as sheltered nurseries for new plant and animal life. This process can take several decades but is reversed rapidly after the grass is removed. Such an effect has happened not only in Humboldt County but also in Point Reyes where valuable wetlands and organic pastures have been smothered by destabilized sand.

Why was European beach grass removed?

When the efforts to remove the non-native, albeit naturalized grasses began in the early 1990’s invasive biology was in its infant stages. Not much was known about the impacts from the eradication efforts of dominant species.  But to some it was important to return coastal areas to the pre-beach grass era so native plants would not be out-competed.

Every movement needs a poster child.  About this same time a cute little shore bird named the western snowy plover became just that.  Even though it is registered as a threatened species on the west coast, other parts of the country and Mexico have significant and stable populations.   We were told by local biologist Ron LaValley that the non-native grass needed to be removed to recover the local plover’s populationThis claim contradicted his original report showing plover eggs nestled in the non-native grass.  He was later convicted and sent to jail for falsifying data and embezzling a million dollars from similar projects involving the spotted owl.

Recognizing that manual eradication was very expensive and time consuming, California State Parks decided to bulldoze 40+ acres of Little River State Beach to provide plover breeding areas. Unfortunately, as Humboldt State Professor Mark Colwell noted in his 2008 report “importantly, eggs often fail to hatch in restored areas.”  This is largely because ravens and crows find it easy to locate the nests in open sand areas.

The Lanphere-Christenson Dunes Refuge director Eric Nelson determined during a 2016 Climate Ready project that the foredunes were being excessively eroded by the 25 California Conservation Corp (CCC) workers who were digging out beach grass.  His decision to spray glyphosate and imazapyr instead of hand removal was carried out despite public opposition.  It remains unclear whether, despite acknowledging excessive erosion from manual eradication efforts, the refuge will return to using that method again.

Lanphere Dunes and Mad River Slough

The public takes notice of the consequences

Some of us who live near these project areas and use them for recreation started noticing native tree mortality and changes to the landforms caused by removing the stabilizing grasses.   We started doing some initial research.  We began looking into coastal development permits, beach and dunes management plans and monitoring reports.  Our findings revealed the project areas that actually had permits also had mitigation requirements.  Those included immediate replanting and strict monitoring to make sure topography and landforms were not altered.  When we inquired about the monitoring and replanting programs we found those to be significantly deficient and in some cases non-existent.

Taking action

Our next step was to approach the various regulatory agencies.  US Fish and Wildlife Service, California Department of Fish and Wildlife and the State Water Board should be interested in the freshwater wetland infill we were witnessing.  The Harbor District and the municipal water district have a major interest in securing the two 42-inch industrial water mains protected by the same beach grass that was being removed.  The Manila Community Service District maintains a waste water treatment facility on the dunes.  We thought the California Coastal Commission would certainly want to know that these unauthorized alterations to coastal landforms were taking place. We felt sure the County planning department that issued some of the permits would take enforcement action.

The town of Manila’s water treatment facility

We brought photo and research documents from Oregon and Washington (2 and 3), made presentations and had meetings, site visits and sent email communications to no avail.

We stepped back and took a look at the board of directors for the non-profit called Friends of the Dunes (FOD) that has been promoting the grass removal from the very beginning.  They had grown from a small, broken down 400 square foot building with a net worth of about $20,000 in 2004 to 60 + acres of ocean front property with a 3000 square foot building and a net worth of over $3.4 million in 2014.  The board of directors at the time consisted of employees of most of the agencies listed above.  We understood then why we were running into so many road blocks.

Our community is well known for environmental activism.  So why the hesitation of local environmental organizations like the North Coast Environmental Center (NEC), Environmental Protection Information Center, and Bay Keeper to call out such impacts caused by bulldozers, herbicide spraying and wetland infilling?  We can only presume that the banner of “restoration” has been used as a blindfold.

Some significant successes….more to do

We have had worthy successes.  Through our efforts the California Coastal Commission has asked the Bureau of Land Management (BLM) for a new determination to address the impacts related to the Ocean Day activities involving 1000 school children digging grasses from the dunes.  So far, the BLM does not think it needs to provide that.  BLM puts on the event but the Coastal Commission bankrolls it.  We do not know yet what the Commission’s response will be to that refusal.

The town of Manila has stopped grass removal activities in its management area and has supported the planting of native pine trees (Pinus contorta, contorta) in the dunes, which we did last February.  The County planning department is engaged and acknowledges that there has been no contract with the California Conservation Corp or BLM for prior grass removal at the County Park and will not allow any more vegetation removal until a Memorandum of Understanding is developed.

The Coastal Commission has committed to reviewing the authorization allowances for BLM’s grass removal over the rest of the South Spit.  The existing Plan states a two-acre area would be subjected to grass removal strictly for monitoring purposes not the mile long area subjected to eradication to date.  BLM contends that authorization extends over the whole 800-acre Spit but have not been able to provide supporting documents.

The North Coast Environmental Center and even the Friends of the Dunes (FOD) took a position against spraying herbicides on the dunes.

Former board members of the FOD that are regulatory agency officials have resigned their director positions.

Communities around the country are hosting events to plant beach grasses like the ones that have been removed here.  Recognition of the incredible value of stabilized dunes is becoming more wide spread.  The “non-native” label is becoming more questioned.

Setting new goals and looking ahead

For us on the North Coast of California we need a much more cost effective and precautionary approach than tearing out plants that have beneficial attributes.  We need to allow the beach grass to do its job of stabilizing and protecting our dunes.  As we allow it to do that, the beach grass “declines in vigor” (4).  When that happens, other plant and animal species utilize those protections from the harsh winds and tides of the Pacific and establish heathy vibrant wildlife habitat. Our local and migratory wildlife depend on it. And so do we.

Uri Driscoll, Arcata, California


We commend the people of Humboldt County for paying attention to the damage that is being done to their public land and we congratulate them on the progress they have made to prevent further damage.  We are impressed with the methodical approach they have taken to convincing public land managers to reconsider the goals of the project and the methods being used to accomplish them. 

We wish them the best of luck with their efforts.  We are grateful to Uri Driscoll for taking the time and trouble to share this story with our readers.

Million Trees 


(1) South Spit Interim Management Plan 2002.

(2) Evaluating Coastal Protection Services Associated with Restoration Management of an Endangered Shorebird in Oregon, U.S.A.  Lindsey Carrol

(3) Sally Hacker, Oregon State University http://rsif.royalsocietypublishing.org/content/12/106/20150017

(4) The Nature Conservancy Element Stewardship Abstract For AMMOPHILA ARENARIA,  Andrea Pickart

Tamarisk beetle: A case study in the dangers of biological controls to eradicate non-native species

Our readers were introduced to Matt Chew in his guest post about the economic interests of ecological “restorations.”  Dr. Chew is a faculty member of Arizona State University’s Center for Biology and Society and an instructor in the ASU School of Life Sciences. 

The most recent newsletter (see page 8) of the California Invasive Plant Council (Cal-IPC) informed us that the beetle that was introduced in Arizona to eradicate tamarisk has spread to California, where it was not introduced.  When the beetle was originally introduced, its spread beyond where it was introduced was not predicted, based on climatic restrictions on its life cycle.  As usual, evolution overturns the best laid plans.  According to Cal-IPC, Rapid evolution in this developmental trait, however, allowed beetles to stay active later in the season and thus facilitated their expansion southward…”   

Tamarisk defoliated by tamarisk leaf beetle along Colorado River, near Needles, California

The rapid defoliation of tamarisk throughout the southwest, including California, is an immediate threat to the endangered Southwestern willow flycatcher, which long ago adapted to tamarisk in the absence of its native host, willow.  The native willow requires a great deal more water than tamarisk. Therefore, willow died off when water throughout the southwest was diverted out of riparian corridors for human consumption and agricultural production.

Dr. Chew is an expert on tamarisk and the role it plays in the ecosystems of the southwest and so we asked him to write another guest post for us on this topic.  He has generously obliged with this detailed history of biocontrols and their use to eradicate non-native species. 

Biocontrols are also topical because a new biocontrol was recently approved by the USDA to eradicate cape ivy.  This biocontrol was eagerly anticipated by native plant advocates and is likely to be widely used by land managers in California.  Therefore, this is a timely opportunity to learn about the pros and cons of biocontrols.  How long will it take the introduced insect to start feeding on the many other species of ivy that are not considered “invasive?”

Evolution and natural selection are wild cards in attempts to eradicate non-native plants and animals.  Although there are many dangerous consequences of using pesticides, the role that evolution plays in rendering pesticides useless is less understood and taken into consideration.  Much like the hungry beetle that now is running rampant in the southwest, the weeds that are continuously sprayed with herbicide are also adapting and evolving defenses against the chemicals being used to eradicate them.  There are now millions of acres of agricultural crop land infested by weeds that are immune to the pesticides that were sprayed on them for decades.  Our pesticides are now useless on these “superweeds.” Instead of getting off the pesticide treadmill, we are developing stronger—and therefore more toxic—herbicides.

There are many reasons why we object to the eradication of non-native plants and animals.  The tamarisk beetle is an example that illustrates a few of our objections:

  • Many of the plants being eradicated are providing food and habitat for animals. The animals that depend upon them are being harmed by their elimination.
  • The methods used to eradicate non-native species often have unintended, negative consequences, such as breeding “superweeds” that cannot be eradicated.
  • The puny tools of humans are often powerless against the much stronger forces of nature, such as natural selection and evolution. These forces of nature should be treated with greater respect, particularly by people who call themselves “scientists.”

Million Trees


Southwestern willow flycatcher

From California to Texas and occasionally beyond, tamarisks are among the most talked-about introduced plants in the US. Most of that discussion consists of familiar anti-alien dogma, augmented by the long-obsolete assertion that tamarisks are profligate water-guzzlers. Suffice for now to say that anti-tamarisk sentiment led to state and federal suppression policies beginning around 1940, and eventually to legislation at both levels. Little more than accumulated bad reputation of tamarisk and its presence in the region of interest led the US Fish and Wildlife Service to include tamarisks among the supposed threats to the persistence of the Southwestern Willow Flycatcher (Empidonax traillii extimus) when that subspecies was formally listed “endangered” in 1993. All of that meant both political will and appropriations were applied to the US Department of Agriculture’s search for biological control agents to deploy as “counter-pests” against tamarisks. By 1998 they had their critter, an Asian leaf-eating beetle that putatively specialized on tamarisks and would rather die than eat anything else.

By that time, though, circumspection had set in, because especially in southern Arizona the endangered birds had taken to nesting in tamarisk stands. USDA promised USFWS that their armored foreign legion would not jeopardize flycatcher populations. USDA argued that the beetles they were about to propagate and release by the multi-millions were genetically incapable of surviving below 38° North latitude. In addition to famously dividing North from South Korea, that frontier runs from near the tip of Point Reyes through Stockton and Mono Lake; just south of Tonopah, Nevada; south of Canyonlands Nation Park; through Moffat and Swink, Colorado; on through the Garden City Kansas and increasingly irrelevant points east. Southern Arizona would surely never see a tamarisk leaf beetle. “Because SCIENCE!” Hold that thought.

In 1952 the otherwise obscure and perhaps pseudonymous writer Rose Bonne copyrighted a succinct cautionary account of biological pest control. Perhaps it was read or sung or shown to you as a child: I know an Old Lady [who swallowed a fly].  Ms. Bonne denied knowing how or why the old lady swallowed the fly, but considered it portentous: “Perhaps she’ll die!” Subsequent actions had definite (if sometimes puzzling) rationales. The next four animals consumed represented a hopeful trophic cascade: the Old Lady swallowed a spider to catch the fly, then a bird to catch the spider, a cat to catch the bird and a dog to catch the cat. At that point, distended and incoherent, she panicked, swallowing a goat to catch the dog, a cow to catch the goat, then finally, fatally, a horse. (Revisionists inserted a pig between the goat and the cow. If you doubt me, Google it.)

The history of biocontrols

We can barely pause to consider the long and checkered history of biological control. Its inception required a few conditions, which may have arisen in different orders in different places.  A sense of ownership, territorial claims or resource collection rights seems necessary, as does dissatisfaction with the dictates of fate. Why attempt to affect an outcome without expecting to benefit from the effort? A bit of empirical, practical natural history knowledge is also indispensable. Together they add up to the possibility of acting on the basis that “the enemy of my enemy is my friend,” to garner a greater share of whatever natural product seems desirable. Dogs to guard flocks and cats to discourage rodents are biological controls. The more organized and concentrated agriculture became, the greater the need for knowledge of “natural enemies” to enlist as economic allies. Even after revolutions in industrial chemistry offered alternatives, better living was still sometimes available through biology.

With private property rights come boundary disputes, complaints about trespass and spillover effects of management decisions. Public property, especially where subject to intensive multiple use mandates, adds complexity and diversity (if not novelty) to the mix. Rights collide with powers and authorities. Politically compromised jurisdictions—like U.S. state authority over wildlife except where superseded by federal laws and treaties or licensed to private parties—are endless fodder for litigation and finger pointing. All the while, science reconstructs what is known or considered knowable, changing expectations, affecting policies and destabilizing political balances.

Modern civilizations depend upon the plants they have introduced

Modern agricultural, horticultural and forestry practices are all legacies of the Renaissance, Reformation and Enlightenment motivations underpinning European colonialism. Empires were assembled and contested primarily for their economic advantages. During the past half-millennium they generated new wealth and new social classes that developed new governments. Among the array of actions those governments continue to undertake is facilitating the redistribution of valuable plants and animals. A visit to any retail food market reveals our near-total embrace of that redistribution. Almost every staple ingredient in every foodstuff is raised or grown far from its “wild” point of origin. Even insistent locavores prefer locally raised food, not locally evolved food. A negligible fraction of us recognize never-transported, never-domesticated edible organisms. Fewer still could survive on them as hunter-gatherers. Such are among the generally intended, hoped-for, positive outcomes of imperial colonialism. Famine is unnecessary, though it is a political tool, deployable as a weapon.

Fish, meat and leather, plant and animal fibers, timber, pulp and derived products can still be wild harvested, but are mostly and increasingly farmed. Anything worth gathering is worth cultivating, from redwood trees to bison to sugarcane to minks to soybeans to insects, yeasts, and bacteria. Even aspirational exceptions like native plant gardening are actually impossible to accomplish: seed intentionally transported from one location to another has been biogeographically rerouted; plants sold by native plant nurseries are raised in multi-source, formulated soils in plastic pots. Even simply deciding to leave a plant where it was found can render it an artifact, and there may no longer be any wilderness so remote that the configuration of its biota remains uninfluenced by human agency.

Benefits of introduced species often outweigh harm

We are told that some of the consequences of all this redistributed and reconfigured biota are marginally negligible. Others are cutting into the profits. Some organisms are moved around unintentionally and unknowingly (zebra mussels, various “blight” fungi) often because unaware transportation technology designers and operators never prevented their distribution. Many intentionally abducted and marooned populations are behaving in unexpected ways, thriving without always accomplishing their intended purposes (alligator apples and cane toads in Australia; house sparrows and wild carrots in North America) or even significantly over-achieving (“Asian” carps and kudzu in North America; rhododendrons and grey squirrels in Britain). Even where post-colonial inclinations to recover and reinstate pre-colonial values are tolerated, they hardly withstand translation into economic choices.  We are adeptly, fundamentally invested in moving things around. We are likewise invested in competition, and building coalitions and alliances to help us win competitions. Especially competitions we thoughtlessly or accidentally set in motion.

Tamarisk on the Colorado River

The Old Lady who swallowed the fly would probably have been fine had she not overthought the problem. The fly was doubtless well on its way to being digested by the time she found a spider, which was likewise moribund before a bird came to hand. Maybe should could have swallowed a willow flycatcher (already protected by the Migratory Bird Treaty Act) and skipped the spider? Had the US Army Corps of Engineers, the USDA and others not overthought the problem in the late 19th and early 20th centuries, they might have come up with suitable alternatives to planting tamarisks to stabilize Texas barrier islands, deepening Four Corners arroyos and fly-away Dust Bowl topsoils. Yes, tamarisks, too, were brought to us to biologically control problems of our own making and conception. Then we needed a beetle…

As things turned out, USDA scientists were either mistaken or disingenuous regarding the latitudinal limits of their tamarisk leaf beetles. Likewise, even about the identity of the beetles, which is why I haven’t inflicted their Latin epithets on you yet. By 2010, sniping between USFWS and USDA, abetted by various conflicting conservation NGOs, led to a new “Biological Assessment” for the federally imposed tamarisk leaf beetle invasion. (I usually avoid using “invasion” in such circumstances, because invading exceeds many capacities of so-called “invasive species.” This was a real invasion, though, planned and carried out by people, not beetles. Beetles merely bred and spread.) One species of beetle became five, four which had been introduced: Diorhabda carinulata; D. elongata; D. sublineata; and D. carinata. Some were quite well-adapted to life in southern Arizona (31-32° N) and beyond. Furthermore, the endangered birds were also nesting in tamarisks in southern Utah, c. 37° N. USDA washed its hands of the federal program and revoked federal permits to release beetles; but that had no effect on the State of Colorado, which was heavily invested in producing them and continues to do so.

Distribution of tamarisk leaf beetle. Tamarisk Coalition
Tamarisk leaf beetle

Fast-forward to 2017. Tamarisk leaf beetles have been spreading along Arizona waterways at rates up to ten times faster than their most ardent cheerleaders imagined they could, and from multiple directions. They will arrive in almost every known Southwestern Willow Flycatcher nesting area sometime this year. By next spring those riparian thickets will be defoliated just at the point when the nestlings most require thermal cover (i.e., shade). Thanks to Reclamation-Era water diversion projects, attempts to re-vegetate those areas with willows will require constant gardening. Reclamation replaced willow habitat with tamarisk habitat. Nevertheless, the birds persisted. Beetle releases suppressed the tamarisks, but will almost certainly fail to eliminate them entirely. Beetles are just another evolutionary pressure on a tamarisk population that is already unlike any other in the world due to unforeseen hybridizing among several species. New tamarisks and new beetles are evolving. Maybe the beetles will try a bite of something else. They’re in California now; could they find something there? Maybe the birds will evolve to eat the beetles, although that hasn’t happened yet. Perhaps the day will come when the Southwestern Willow Flycatcher gives way to the Tamarisk Beetlebird. It might not even take very long. But don’t bet on it. And don’t bet on biologists, bureaucrats or any other ambitious adults to re-learn the lesson of unintended consequences they laughed at as children, then (like so many other lessons) forgot.

Matt Chew

Where is the invasion biology debate headed?

Mark Davis speaking at Beyond Pesticides conference, April 2017

Mark Davis is Professor of Biology at Macalester College in St. Paul, Minnesota.  He is one of the first academic ecologists to publicly express skepticism of invasion biology.  His book, Invasion Biology, was published by Oxford University Press in 2009.  It was the first critique of invasion biology written by an academic scientist. Professor Davis cites the many empirical studies that find little evidence supportive of the hypotheses of invasion biology. 

In 2011, Nature magazine published an essay written by Professor Davis and 18 coauthors entitled, “Don’t Judge Species on their Origins.”  This essay suggested that conservationists evaluate species based on their ecological impact, rather than whether or not they are natives.  The essay initiated an intense debate in the academic community of ecologists that continues today. 

Professor Davis spoke at the Beyond Pesticides conference in Minneapolis at the end of April 2017. (Video available HERE) He described invasion biology as an irrational ideology that is based on nostalgia for the past and a belief that wildlands are being damaged by “alien invaders.”  In fact, the perceived damage is largely in the eye of the beholder, depending largely on one’s membership in a group benefiting from the nativism paradigm, such as chemical manufacturers, conservation organizations, government agencies, and employees.  Some academic careers are also at stake.  Futile attempts to re-create historical landscapes always have the potential to make things worse.  In many instances, it is more sensible to change one’s attitude about the changing landscape than trying to change nature.

We invited Professor Davis to write a guest post for publication on Million Trees.  We asked him to express his opinion on these questions: 

  • Has the status of invasion biology changed much since Nature published your essay 2011?
  • Has increased knowledge of climate change had an impact on the status of invasion biology in academia?
  • What do you think is the future of invasion biology both as an academic discipline and as public policy?

Professor Davis’s guest post addresses these questions.  We are grateful to Professor Davis for his many contributions to our understanding of the fallacies of invasion biology and for his thoughtful guest post.

Million Trees


Competition to define nature

In the past few years, a new perspective has been taking hold in the field of ecology.  Referred to as ‘ecological novelty’ it emphasizes that many factors are producing ecologically novel environments.  Climate change (which includes changes in temperatures and patterns of precipitation), increased atmospheric carbon dioxide, which affects photosynthetic rates, increased atmospheric deposition of nitrogen (the whole earth is being fertilized due to the increased nitrogen we are pouring into the atmosphere), and the introduction of new species are all rapidly changing our environments.

A strength of the term ecological novelty is that unlike the invasion vocabulary it is simply descriptive.  It simply states that ecosystems are changing and are different than they were in the past, even the recent past.  It says nothing about whether this change is good or bad.  In this paradigm, species can be referred to as novel species, new arrivals, or long-term residents.

The less biased ecological novelty paradigm differs dramatically from the more ideological nativism paradigm.  It differs in the language it uses and it differs in the implied direction that land management should proceed.  More generally, it forsakes the normative atmosphere that permeates restoration ecology, conservation biology, and invasion biology, all of which have been substantially guided by the nativism paradigm.

The Sutro Forest in San Francisco is a good example of a novel ecosystem. It is a thriving mix of native and non-native species. Much of it will be destroyed by the irrational belief that native species are superior to non-native species.  Million Trees

Currently, invasion biologists are trying to discredit ecological novelty as a valid or valuable perspective.  This is hardly surprising since the ecological perspective would displace the nativism paradigm, and many stakeholders have much to lose if the nativism paradigm were abandoned, e.g. chemical companies, restoration and management companies, local, state, and national agencies, to name just a few.  Not surprisingly, articles trying to shore up invasion ecology and to keep it relevant have been common in recent years.

While the public may not be aware of it, there exists a heated competition to define natureWhich side wins will significantly determine how nature is managed.  Given that the redistribution of species is only going to increase in upcoming decades, it is hard to imagine that people will still be so preoccupied with origins by the middle of the century.  Like the notion of wilderness, the nativism paradigm is more of a twentieth century concept, while the construct of ecological novelty is more fitting for the twenty first century.

Undoubtedly, nativist groups will still exist and will still be preoccupied with trying to restore their vision of the past.  But, due to the number of species being moved to new regions, much more attention likely will be given to the function of species than their origins, if only for pragmatic reasons.  For people coming of age now, cosmopolitanization is the new normal, both with respect to people and other species.  We will still carry our predispositions to divide the world into us and them, but it should be clear to most that the nativism perspective will be obsolete and that beyond the creation of museums, restoring the past will not be possible, whether a city or a forest.

Currently Earth is the only planet we know of where life exists.  In this context, the desire and practice of declaring some species as aliens, exotics, or invaders seems sadly provincial and even unseemly.  Roman playwrite Publius Terentius Afer (aka Terence) wrote in his play Heauton Timorumenos, “Homo sum, humani nihil a me alienum puto”, or “I am human, and nothing of that which is human is alien to me.” To those who still see such value in distinguishing native from alien species, I say, “I am of the planet Earth and nothing of that which is earthly is alien to me.”

Mark Davis

The Ecological “Restoration” Industry: Follow the money

Matt Chew is one of many professional academics that criticize invasion biology.  Unlike most, he emphasizes explaining the weaknesses of eco-nativism using scientific, historical, and philosophical methods, depending on the issue.  This has made him a useful collaborator and resource for like-minded but primarily science-oriented colleagues. Million Trees is deeply grateful for his willingness to speak publically about the fallacies of invasion biology, including the generous gift of his time in writing this guest post for us.

Dr. Chew is a faculty member of Arizona State University’s Center for Biology and Society and an instructor in the ASU School of Life Sciences.  He teaches courses including the History of Biology, Biology and Society, and a senior conservation biology course in “novel ecosystems,” described HERE on the university’s “ASU Now” news website.

He was also a speaker at the 2013 annual conference of Beyond Pesticides.  A video of his presentation is available HERE (go to 24:40).  He says that “invasive” plants are convenient scapegoats that are presenting a marketing opportunity for the manufacturers of pesticides. Invasion biology is at the core of the greening of pesticides.

In his guest post, Matt helps us to understand how he chose to pursue a multidisciplinary critique of one topic rather than adopting a single disciplinary approach and identity. He began his professional career as a practicing conservation biologist, experiencing firsthand the sometimes startling disconnects between laws, policies, aspirations, public expectations, and realities “on the ground.” 

We celebrate April Fool’s Day with Matt Chew’s article.  When we waste our money on ecological “restorations” the joke is on us!

Million Trees

Matt Chew with his class in novel ecosystems

Those familiar with my academic work know I invest most of my efforts documenting and explaining the flaws and foibles of “invasion biology.” But I got into this messy business as a practical conservation biologist, a natural resources planner “coordinating” the Arizona State Natural Areas Program during the late 1990s. I found the toxic nativism of natural areas proponents morbidly fascinating, and the practical politics of natural areas acquisition and management morbidly galling. I chose to follow my fascination. But as “Death of a Million Trees” marks the end of its seventh year as a WordPress blog, and in light of recent decisions by Bay Area authorities, it’s time for a galling reminder:  Follow the money.

Authorities responsible for suburban fire suppression and recovery necessarily view stands of living trees as liabilities. They can’t see the forest for the fuels. The prospect of eliminating them merely drives their value further into the negative. That it must be subsidized is ironic because eucalyptus and Monterey pine are plantation grown in many countries for timber or pulp. But they aren’t traditional sources of California wood products and a glut of more familiar drought-killed trees awaits salvage far from finicky neighbors.

So condemned trees can’t just be disappeared by pointing them out to eager loggers. “Concept planning” can be fairly vague, but “action planning” must be very specific. A job this big requires both general and sub-contracting. It requires hiring and training and supervising. Capital equipment will be acquired, maintained and repaired. Affected areas must be surveyed and material volumes estimated. Before trees can be felled, access routes must be surveyed and created. After trees are felled they must be sectioned, staged, loaded and hauled away for disposal. More often they are shredded in place. At every step, someone pays and someone profits.

Where “ecological restoration” is the objective, stumps must be pulled or blasted and roots must be excavated. The eucalyptus seed bank will need to be eliminated or rendered inert. Perhaps even a century’s accumulation of organic topsoil will need amending, or removing and replacing to reconstitute prehistoric substrates. Seed suppliers and nurseries will be contracted to provide plant “native” materials. After the armies of tree-fellers and stump-blasters will come waves of laborers, tractors, diggers, spreaders, and planters in an endless relay of trucks. Ecological restoration is farming, all the more so in proximity to a cityscape arrayed in exotic plants. If all goes well and the rain falls in judicious quantities at auspicious times, planting will be followed by perpetual weeding. At every step, someone pays and someone profits.

It’s hardly surprising that FEMA has no intention of underwriting restoration on that scale. Their plans envision minimally spreading shredded wood, leaving a layer up to two feet deep to gradually decompose, and hoping whatever oaks and other present understory plants they haven’t accidentally fractured or flattened will thrive in the sudden absence of big trees. Two feet of material will gradually compact, but assurances that it will rot into organic soil within a few years are pretty optimistic. Whether and when it will support anything resembling a native plant assemblage is dubious. Meanwhile, some viable stumps will require recurring treatment with the herbicide du jour and occasional supplemental felling. It’s not a reset-and-forget strategy. It’s just the first step of a long and contentious cycle of interventions. And of course, at every step, someone pays and someone profits.

Whenever public property and expenditure is concerned there should be an open procurement process with a clear data trail. A call for proposals is written and published, bids are received, contracts awarded, and work commences. But we can be certain that by the time the prospect of deforesting the Bay Area was openly discussed by policymakers, potential bidders were positioning themselves to influence the shape of the emerging policy and take advantage of it. And various interest groups who saw deforesting the hillsides as a means to their ends became a de facto coalition of advocates. Some acted more openly than others, and some to greater effect. But prominent nonprofit organizations expect returns on their investments. Nothing happens unless someone pays and someone profits.

Some of the premises underlying the logic of the program will inevitably be faulty. Should it falter at any step due to unforeseen events (e.g., meteorological, horticultural, ecological, economic or political), contingencies will be implemented… if funds are available. There are only three certainties. Firstly, no action occurs unless someone pays and someone profits. Secondly, nature, within which I include all aspects of human society, is complex and capricious. No one can predict with much certainty how a post-deforestation landscape will look or function. Finally, a coalition of the discontented will emerge and agitate for improvements that require someone to pay, and allow someone to profit.  As Nancy Pelosi recently reminded us, “we’re capitalist and that’s just the way it is.”   

Matt Chew

 

 

Integrated Pest Management is a sham!!

Many thanks to Marg Hall for this guest post about the pesticides being used by the supplier of our drinking water in the East Bay and for the research she did to inform the public that there is a BIG gap between written policies and the reality of pesticide use on our public lands.


One day last winter, I came upon a crew cutting down about 50 eucalyptus trees on what appeared to be EBMUD lands in the East Bay hills. (East Bay Municipal Utility District, EBMUD, manages the local drinking water lands and infrastructure.) Knowing that rain was predicted, and that the standard procedure is to apply the nasty herbicide Garlon to the cut tree stumps to prevent re-sprouting, I stopped to ask the workers about the job.  The contractor (Expert Tree Service) refused to answer my questions, even the most basic one: who hired them?

Tree removals done by EBMUD on Grizzly Peak Blvd
Tree removals done by EBMUD on Grizzly Peak Blvd (prior to the incident reported by Marg Hall)

I thought it an especially bad idea to apply Garlon in the drinking water watershed during the rainy season, so I stopped them by simply refusing to leave the work area until I got some answers. It was easy. I was polite but firm. The police were called. After being threatened by the contractor with per-minute fines for delaying the work, and a trip to jail from the police, I left them to their destruction. This is how I became interested in the management of EBMUD lands.

On a personal note, I had just been diagnosed with breast cancer. Ironically, I’d been looking for hiking trails where I didn’t have to confront the risk of cancer-causing pesticide applications. The whole situation made me very grumpy.

Following up, I was assured by EBMUD staff that they do NOT allow contractors to apply herbicides to cut eucalyptus stumps, and that very few, in fact almost no, herbicides are used in the drinking watershed lands. OK, that sounded pretty good. Wanting to verify this claim, I filed a public records request to EBMUD.

Aerial spraying pesticides on public parks

Meanwhile, we (FAB, The Forest Action Brigade, a grass roots group with which I am affiliated) heard of a plan by East Bay Regional Park District (EBRPD) to aerial spray from a helicopter (yes, you read that correctly!) an herbicide named Milestone (which is prohibited for use in New York State because it is very persistent and mobile in the soil). This was to be done in Briones Park, an area that directly supplies two creeks that feed into the Briones water reservoir.

Mobilizing public support, we were able to stop that spraying, but among our growing concerns we now added the safety of our drinking water. Even though this spray was planned by the East Bay Regional Parks District (EBRPD), the staff from the Water District (EBMUD) knew about it, and didn’t try to stop it…until we raised the issue.

Management of wastershed land by supplier of our drinking water

Last summer, EBMUD invited public comment on a draft update of their Watershed Management Master Plan. In this document, an Integrated Pest Management (IPM) program was referenced (available here: ebmud-ipm-program). Curious, we obtained copies of this document.

On paper it looks pretty solid. Like most IPM programs, this one contained written assurances that only minimal pesticides will be used, and then only as a last resort. Quarterly meetings of the IPM committee would provide oversight, meet and compile reports of pesticide usage. Among committee goals are: approve pesticide use requests, ensure consistency among work groups regarding pest management, and advise on pest management strategies. The guidelines require that pesticides be used only after certain damage thresholds are reached, with follow-up evaluations of effectiveness, and documentation of adverse side effects on non-targeted organisms.

Reading this leads one to the conclusion that the land management practices are just a step below organic gardening practices. With such controls and alternatives, what could possibly go wrong?

Control of pesticide use is more theoretical than real

As I soon learned when I started asking for public records, the IPM program as outlined in the EBMUD Watershed Management draft plan is a “paper only” plan. The oversight committee has not met in 15 years, and in fact only actually met for several years (the program started in 1996). There has been no oversight, no annual report, and wildly inconsistent use has developed over the various work units at EBMUD. They do follow minimal state reporting and training requirements, but that’s it.

I found no comprehensive evaluation of pesticide use, no analysis of levels of use, or experiments with alternatives, as one would expect in an “integrated” approach. Instead I received pages and pages of daily logs by individual workers documenting pesticide use. There appear to be no restrictions on use as long as the applicators documented applications, and the pesticides used were on the approved list of pesticides. The list of approved pesticides is long and includes known carcinogens.

Since nobody at EBMUD was keeping track, several of us embarked on a labor-intensive project to sort through records ourselves and tally an annual pesticide total. We focused on EBMUD properties in Alameda and Contra Costa Counties and usage for the year 2015. We were disheartened by our findings. In these areas, EBMUD made 647 applications by truck, backpack or by hand of herbicides totaling over 700 gallons and 205 pounds.

We compared the use of pesticides by EBMUD with those used by EBRPD.  EBRPD used significantly less herbicide than EBMUD in 2015. EBRPD used 193 gallons of herbicide (glyphosate, Garlon, Oryzalin) in 2015 (and smaller quantities of specialty herbicide for specific projects).  EBRPD has 120,536 acres of property compared to only 28,000 acres of EBMUD property.

Many environmentalists concerned about pesticide use had thought EBMUD carried out a more environmentally respectful philosophy of land management. This is not true. While the Watershed and Recreation work unit reported using only 8 gallons of pesticides that year, they constitute only one of several work units. EBMUD staff in the Watershed and Recreational work unit believe that is the sum total of pesticides used in “the watershed” and that pesticide usage is low. While some of the maintenance operations are outside of the drinking water watershed lands, some are not. Nevertheless this distinction is meaningless since all land is a “watershed” whether it drains to Briones reservoir or the San Francisco Bay. Furthermore, applications of pesticide are routinely done in areas open to the public.

One such application was documented last fall by someone walking on a public road in her neighborhood who took this video (If the video won’t play for you, try clicking on this link to the video HERE:

https://youtu.be/3mRpcZFPCdc?t=2

In it you see vast quantities of Roundup (glyphosate), applied from a truck-mounted tank using a garden hose. That method of application explains why the volume of EBMUD’s pesticide use is so high.  Competent and responsible pesticide applicators use a spray nozzle to reduce the flow and spread the herbicide more evenly.

Inexplicably, the worker was soaking bare ground along the side of a road. It is pointless to apply Roundup to bare ground.  It is a foliar spray that must be applied to actively growing plants.  It has no effect on seeds, roots, or tubers in the ground.  This is explained clearly on the manufacturer’s label for the product.

This spraying was done in a residential neighborhood (Carisbrook Road, Montclair area of Oakland). No pesticide application notices were posted before, during or after the application in violation of EBMUD’s IPM guidelines, which say, “If there is likely to be public contact with the area to be sprayed with pesticide, adequate notification or posting should be conducted.”

Carisbrook Reservois on Carisbrook Road in Montclair, Oakland, where pesticides were sprayed by East Bay Municipal Utilities District
Carisbrook Reservoir on Carisbrook Road in Montclair, Oakland, where pesticides were sprayed by East Bay Municipal Utilities District

The video was sent to EBMUD board members. EBMUD’s response was a defense of this application as consistent with existing policy and regulation. They also claimed that the herbicide was not sprayed on a pedestrian path.  In fact, the spraying occurred on a public road in a residential neighborhood that was used as a path by those who live in the neighborhood, such as the woman who recorded the video.

How to achieve REAL control over pesticide use on public land

That raises the obvious question: if this pesticide application is acceptable, what good is an IPM program except as a means to mislead the public into thinking we are being protected?

There’s an easier, simpler way to obtain the kind of protection we need: Forget IPM. Institute a total ban. No pesticides.  PERIOD.  It can be done.

Marin Municipal Water District has banned all pesticide use on their properties.  Organic farmers do it. Why not demand this from our local land managers?

Public Policy is in OUR hands

In recent decades, public land managers have been using public tax money to apply more and more pesticides in public spaces. In the years ahead, as the Republicans dismantle the Environmental Protection Agency, destroying what little (pathetic) regulation that we now have, we local activists will need to do our own protecting.

It starts here, in our own backyards. We know there is tremendous popular support for this. People really don’t like to be exposed to pesticides when they visit public parks. Robust local activism is our only hope. Yes, we can!!

Marg Hall