Franciscan manzanita: The confiscation of public land

Update:  US Fish & Wildlife published the final rule designating critical habitat for Franciscan manzanita on December 20, 2013.  230.2 acres of land in San Francisco have been designated as critical habitat:  46.6 acres of federal land, 172.8 acres of parks owned by San Francisco’s Recreation and Parks Department, and 10.8 acres of private land.  The complete document is available here.  The document responds to public comments and explains any differences between the proposed designation and the final rule.  It makes interesting reading. 


On September 5, 2012, US Fish & Wildlife (USFWS) announced that Franciscan manzanita is now an endangered species.  In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive.  It was transplanted to an undisclosed location in the Presidio in San Francisco.

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of  land in San Francisco as critical habitat for the Franciscan manzanita.   Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio.  (Details about all the critical habitats are available here.)  Forty of the 318 acres are on private land.  Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

The taxonomy of manzanita is ambiguous

There are 96 species of manzanita in California (1).  The ranges of most of these species are extremely small because the manzanita hybridizes freely and therefore adaptive radiation has resulted in a multitude of species, sub-species, and varieties that are adapted to micro-climates.  Many of these species are locally rare, which is consistent with the fact that 6 species of manzanita have already been designated as endangered, two of which are limited to the San Francisco peninsula:  Raven’s manzanita and Franciscan manzanita.

The genetic relationship between these two species of manzanita is ambiguous, which is reflected in the constantly shifting opinions of biologists about the taxonomy (species classification) of manzanita.  The 2003 Recovery Plan for Raven’s manzanita recounted the long history of these shifting views.  For some time, Raven’s and Franciscan manzanitas were considered the same species.  Then, for an equally long time, they were considered sub-species of the same species, Arctostaphylos hookeri.  It was not until 2007, that Raven’s was reclassified as a sub-species of Arctostaphylos montana.  Presently, Franciscan manzanita is classified as its own species, Arctostaphylos franciscana. 

Clearly, this history of the biological opinion regarding these two species of manzanitas suggests they are closely related and morphologically (AKA anatomically) similar.  The Recovery Plan concludes, “The idea of ‘pure’ species in Arctostaphylos, with its many poorly defined taxa and prevalent hybridization has often been difficult to apply over the history of taxonomic work in the genus.”

To add to the confusion regarding the provenance of Franciscan manzanita, some biologists are of the opinion that the individual plant that was discovered on Doyle Drive is actually a hybrid, not a pure-bred Franciscan manzanita.  The East Bay Regional Park District botanical garden in Tilden Park has planted a clone of the individual plant from Doyle Drive.  It is labeled as a hybrid of Arctostaphylos uva-ursi, which is one of the few species of manzanita with a wide range.

This is the label on the “Doyle Drive” manzanita in Tilden Park Botanical Garden, indicating that it is a hybrid.

The park ranger who led us to this plant in the Tilden garden, pointed out that the plant is morphologically distinct from the Franciscan manzanita that has been resident in that garden for about 50 years.  He expressed his opinion that the Doyle Drive manzanita was properly labeled as a hybrid.

In what sense is the Franciscan manzanita “endangered?”

Franciscan manzanita has been available for purchase in nurseries for about 50 years.  It has been propagated by taking cuttings and therefore they are presumed to be genetically identical clones.  However, given that this plant has been sold to the public for a long time, we have no way of knowing exactly where they have been planted or if some have successfully reproduced by germinating seeds.  For all we know, this plant is thriving somewhere, perhaps even in a place we might call “wild.”  Perhaps the plant found on Doyle Drive was purchased in a nursery!

The individual plant found on Doyle Drive has been defined by USFWS as Franciscan manzanita despite the fact that some biologists consider it a hybrid of another species.  We understand that the motivation for designating this individual as an endangered species and providing it with critical habitat is based on an assumption that it is genetically different from the Franciscan manzanita that can be purchased in nurseries and that the chances of survival of the species may be improved by cross-fertilization of these two plants such that greater genetic diversity results from their union.

Yet we are offered no evidence of the genetic composition of the Doyle Drive individual or Franciscan manzanita sold in nurseries.  Nor are we provided any evidence that the Doyle Drive individual is even a genetically “pure” Franciscan manzanita rather than a hybrid of another species altogether.

If we weren’t being asked to devote 318 acres of land to the propagation of a plant with such ambiguous taxonomy, we might not question how little information we have been provided.  The technology of mapping the genome of this plant is available to us.  Why aren’t we making use of this technology to resolve these ambiguities?  The cost of planting 318 acres with this endangered plant far exceeds the cost of such genetic analysis.

We aren’t told what it will cost to plant 318 acres with this endangered plant, but we know that the cost of the recovery plan for Raven’s manzanita and lessingia was estimated as $23,432,500 in 2003.  Presumably that is an indication that the proposal for Franciscan manzanita will be a multi-million dollar effort.  The cost of transplanting the single plant from Doyle Drive to the Presidio was reported as over $200,000. (1)

Thirty years of endangered status for Raven’s manzanita has not saved this plant

We have already made the point that Raven’s and Franciscan manzanitas are closely related.  In its proposal for the designation of critical habitat for Franciscan, USFWS confirms this close relationship by referring us to the Recovery Plan for Raven’s.  In other words, the characteristics and horticultural requirements of these two species are so similar that a separate Recovery Plan for Franciscan is not necessary.  The Recovery Plan for Raven’s is applicable to Franciscan.

Therefore, we should assume that the fate of the recovery effort for Franciscan will be similar to that for the Raven’s.  Raven’s was designated as endangered in 1979.  Its first recovery plan was published in 1984 and the second in 2003.  Many 5-year reviews of its endangered status have been done during this 33 year period.  The most recent 5-year review was published in June 2012; that is, very recently.

So what does USFWS have to show for 33 years of effort to save Raven’s manzanita from extinction?  Almost nothing:

  • Clones of the single plant in the wild exist in several botanical gardens.  These clones are genetically identical and their growth in maintained gardens does not meet ESA standards for recovery.
  • “The wild plant has been observed to set seed although no natural seedling establishment is known to have occurred.” (6)
  • The plant has been the victim of twig blight several times, but the fungus cannot be treated because it would damage the mycorrhizal fungi in the soil upon which the plant is dependent.
  • The seeds depend upon animal predators for dispersal which are largely absent in an urban area.
  • The pollinators of manzanita have not been identified and therefore there is no assurance that they still exist in this location.
  • The 5-year review concludes that:  “…recovery sufficient to warrant full delisting is not projected in the foreseeable future for [Raven’s manzanita] and may not be possible.”

We can’t appreciate the significance of the utter failure of this effort without some mention of the extreme methods used to overcome these obstacles.

The seed of manzanita is germinated by fire.  However, the exact relationship between fire and germination is not known.  Therefore, many complex experiments have been conducted on the few viable seeds produced by the Raven’s manzanita in a futile effort to determine the winning combination.  These experiments are described in detail in an article in Fremontia (1).  In short, various combinations of fire, heat, cold, smoke, liquid smoke, etc., were tried and failed to determine exactly what triggers germination of manzanita seeds.

We should remind our readers of the legal definition of “recovery” according to the Endangered Species Act.  According to the 5-year review for Raven’s manzanita, here are two of the criteria for recovery toward which there has been no progress in 33 years:

  • “At least five spontaneously reproducing variable populations are established in reserves…in San Francisco…”
  • “At least two sexually reproduced generations are established within the Presidio.”

Frankly, it is no longer credible to expect the recovery of Raven’s manzanita and this failure implies the same fate for Franciscan manzanita.

Can the public parks of San Francisco meet the horticultural requirements of Franciscan manzanita?

The public parks of the City of San Francisco cannot meet the horticultural requirements of the Franciscan manzanita because it requires fire to germinate its seeds. 

All of the critical habitats proposed by USFWS in San Francisco’s public parks are designated “natural areas.”  According to the DRAFT Environmental Impact Report of the “Significant Natural Resource Areas Management Plan,” prescribed burns are prohibited in the natural areas.  Therefore, unless there are unplanned wildfires in the six public parks proposed as critical habitat, it will not be physically possible to “spontaneously reproduce” this plant, as required by the Endangered Species Act. 

Granted, the City of San Francisco could revise its management plan for the natural areas to allow—or even require—prescribed burns in the six parks proposed as critical habitat.  In that case, the citizens of San Francisco would be subjected to air pollution and risk of causing an uncontrolled wildfire in surrounding residential communities.  The Natural Areas Program would be subject to even more criticism than it already endures.

The Natural Areas Program is extremely controversial in the City of San Francisco because it destroys healthy non-native trees, it sprays pesticides on non-native vegetation in public areas, it destroys the habitat of wildlife, and it limits the public’s recreational access to trails which are often fenced.  Subjecting the natural areas to prescribed burns is surely the bridge too far for the public which would jeopardize the future of the entire program.  Why would the City of San Francisco be willing to push the public over the edge by requiring prescribed burns in six urban parks in densely populated residential communities?

Furthermore, some of the proposed critical habitat is in heavily forested areas, which are not compatible with the requirement of manzanita for full sun.  As they were on behalf of Raven’s manzanita, these trees would be destroyed.  The City of San Francisco is already planning to destroy 18,500 trees over 15 feet tall to accommodate its desire to reintroduce native plants to forested areas. (3)  How many more trees would need to be destroyed to accommodate Franciscan manzanita?  How much more carbon dioxide would be released into the atmosphere by the destroyed trees?

Bayview Hill is one of the proposed critical habitats which are heavily forested.  According to SNRAMP (3), 17.16 acres of Bayview Hill is forested.  Given that Bayview Hill is the only proposed critical habitat which is outside the known historic range of Franciscan manzanita, the loss of 17 acres of trees does not seem a fair trade for a plant with few prospects for survival.

The proposed critical habitat in Glen Canyon Park (inaccurately called Diamond Heights by the proposal) is also forested in a portion of the 34 proposed acres of critical habitat.  This is a park in which the destruction of trees is being hotly contested.  The community in this park does not need the additional controversy of tree destruction for the sole purpose of planting an endangered species.

Proposed critical habitat in other city parks is likely to be controversial for other reasons, primarily because additional restrictions on recreational access will undoubtedly be required to protect this endangered plant.  Bernal Hill is an example of a city park with a huge community of visitors who will undoubtedly be enraged by further loss of recreational access.  They have already been squeezed by the restrictions imposed by the Natural Areas Program.

This proposal for critical habitat is not good public relations for the Endangered Species Act

The City of San Francisco is the second most densely populated city in the country.  It is comprised of only 29,888 acres.   There are only 3,317 acres of City-managed parks in the city. (2) The proposed critical habitat in City-managed parks is 196 acres, 6% of total City-managed park land in San Francisco.

Please ask yourself these questions:

  • Does it make sense for 6% of all City-managed park land to be permanently committed to planting an endangered plant which can be purchased in nurseries?
  • Does it make sense to confiscate 6% of all public parks for a plant the identity of which we are not certain?
  • Does it make sense to throw the public out of 6% of all public parks on behalf of a plant that will never be able to spontaneously reproduce unless there is an accidental wildfire?

We think the answers to these questions are no, no, and no.  This is an ill-advised proposal which makes a mockery of the Endangered Species Act.  This is an important law that is trivialized by a proposal that will be physically impossible to implement without endangering the public and damaging the environment. 

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn:  FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.



(1)      Gluesenkamp, Michael, et al., “Back from the Brink:  A Second Chance at Discovery and Conservation of the Franciscan Manzanita,” Fremontia, V37:4/38:1, 2009-2010

(2)      Harnik, Peter, Inside City Parks, Trust for Public Land, 2000

(3)      San Francisco Recreation and Park Department, “Significant Natural Research Area Management Plan (SNRAMP),” 2006

(4)      San Francisco Recreation and Park Department, “DRAFT Environmental Impact Report for SNRAMP,” 2011

(5)      USFWS, “Designation of Critical Habitat for Franciscan Manzanita,” September 5, 2012

(6)      USFWS, “5-Year Review of Endangered Status of Raven’s Manzanita,” June 2012

(7)      USFWS, “Recovery Plan for Coastal Plants of the Northern San Francisco Peninsula,” 2003

The Healthy Trees of San Francisco

The San Francisco Natural Areas Program (NAP) plans to destroy thousands of healthy trees in San Francisco’s parks.  The Draft Environmental Impact Review (EIR) for NAP’s destructive plan reaches the bizarre conclusion that removing thousands of trees will have no significant impact on the environment.   This conclusion is based on several fictional premises.  In a previous post we examined the fictional claim that all the trees that will be removed will be replaced within the natural areas by an equal number of trees that are native to San Francisco.  In this post we will examine another of the fictional premises:  that only dead, dying, hazardous, or unhealthy trees will be removed.

We have many reasons to challenge the truth of the claim that only dead, dying, hazardous or unhealthy trees will be removed:

  • The management plan for the Natural Areas Program tells us that young non-native trees under 15 feet tall will be removed from the natural areas.  By definition these young trees are not dead or unhealthy because they are young and actively growing.
  • The management plan has not selected only dead, dying, hazardous trees for removal.  Trees have been selected for removal only in so far as they support the goal of expanding and enhancing areas of native plants, especially grasslands and scrub.
  • The predominant non-native tree in San Francisco, Blue Gum eucalyptus lives in Australia from 200-400 years, depending upon the climate.(1)  In milder climates, such as San Francisco, the Blue Gum lives toward the longer end of this range. 
  • However, there are many natural predators in Australia that were not imported to California. It is possible that the eucalypts will live longer here:  “Once established elsewhere, some species of eucalypts are capable of adjusting to a broader range of soil, water, and slope conditions than in Australia…once released from inter-specific competitions and from native insect fauna…”(2)
  • The San Francisco Presidio’s Vegetation Management Plan reports that eucalypts in the Presidio are about 100 years old and they are expected to live much longer: “blue gum eucalyptus can continue to live much longer…”(3)
  • The Natural Areas Program has already destroyed hundreds of non-native trees in the past 15 years.  We can see with our own eyes, that these trees were not unhealthy when they were destroyed.

How have mature trees been selected for removal?

The EIR wants us to believe that only dead, dying, hazardous trees will be removed from the natural areas.  This claim is contradicted by the management plan that the EIR is claiming to evaluate.  Not a single explanation in the management plan for why specific trees over 15 feet tall have been selected for removal is based on the health of the trees.  Trees less than 15 feet tall will also be removed, but are not counted by the management plan.

  • Lake Merced:  The explanation for removing 134 trees is “To maintain and enhance native habitats, it is necessary to selectively remove some trees.”
  • Mt. Davidson:  The explanation for removing 1,600 trees is: “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-grassland ecotone, invasive blue gum eucalyptus trees will be removed in select areas. Coastal scrub and reed grass communities require additional light to reach the forest floor in order to persist “
  • Glen Canyon:  The explanations for removing 120 trees are:  “to help protect and preserve the native grassland” and “to increase light penetration to the forest floor”
  • Bayview Hill:  The explanation for removing 505 trees is:  “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-grassland ecotone, invasive blue gum eucalyptus trees will be removed in select areas.”
  • McLaren:  The explanation for removing 805 trees is:  “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-scrub-grassland ecotone, invasive trees will be removed in select areas. Coastal scrub and grassland communities require additional light to reach the forest floor in order to persist.”
  • Interior Greenbelt:  The explanation for removing 140 trees is:  “In order to enhance the seasonal creek and sensitive species habitat that persists in the urban forest understory, invasive blue gum eucalyptus trees will be removed in select areas.”
  • Dorothy Erskine:  The explanation for removing 14 trees is:  “In order to enhance the grassland and wildflower community, removal of some eucalyptus trees is necessary.”

In not a single case does the management plan for the Natural Areas Program corroborate the claim made in the EIR that only dead, dying, diseased, or hazardous trees will be removed.  In every case, the explanation for the removal of eucalypts is that their removal will benefit native plants, specifically grassland and scrub.  The author of the EIR has apparently not read the management plan or has willfully misrepresented it. 

The track record of tree removals in the natural areas

Although it’s interesting and instructive to turn to the written word in the management plan for the Natural Areas Program to prove that the EIR is based on fictional premises, the strongest evidence is the track record of tree removals in the past 15 years.  As always and in every situation, actions speak louder than words.

Hundreds of trees have been removed in the natural areas since the Natural Areas Program began 15 years ago.  We’ll visit a few of those areas with photographs of those tree removals to prove that healthy, young non-native trees have been destroyed.  This track record predicts the future:  more healthy young trees will be destroyed in the future for the same reason that healthy young trees were destroyed in the past, i.e., because their mere existence is perceived as being a barrier to the restoration of native grassland and scrub.

Girdled trees, Bayview Hill, 2010
  • The first tree destruction by the Natural Areas Program and its supporters took the form of girdling about 1,000 healthy trees in the natural areas about 10 to 15 years ago.  Girdling a tree prevents water and nutrients from traveling from the roots of the tree to its canopy.  The tree dies slowly over time.  The larger the tree, the longer it takes to die.  None of these trees were dead when they were girdled.  There is no point in girdling a dead tree.

    One of about 50 girdled trees on Mt. Davidson, 2003
  • Many smaller trees that were more easily cut down without heavy equipment were simply destroyed, sometimes leaving ugly stumps several feet off the ground.

    Bayview Hill, 2002
  • About 25 young trees were destroyed on Tank Hill about 10 years ago.  The neighbors report that they were healthy trees with trunks between 6″ to 24″ in diameter and therefore fairly young trees.  The trees that remain don’t look particularly healthy in the picture because they were severely limbed up to bring more light to the native plant garden for which the neighboring trees were destroyed.  The neighbors objected to the removal of the trees that remain.  The Recreation and Park Department agreed to leave them until they were replaced by native trees.  Only 4 of the more than two dozen live oaks that were planted as replacements have survived.  They are now about 36″ tall and their trunks are about 1″ in diameter. 

    Tank Hill, 2002
  • About 25 young trees were destroyed in 2004 at the west end of Pine Lake to create a native plant garden that is now a barren, weedy mess surrounded by the stumps of the young trees that were destroyed.

    Pine Lake "Natural Area" 2011
  • About 25 trees of medium size were destroyed at the southern end of Islais Creek in Glen Canyon Park about 6 years ago in order to create a native plant garden. 
  • Many young trees were recently destroyed in the natural area called the Interior Greenbelt.  These trees were destroyed in connection with the development of a trail, which has recently become the means by which the Natural Areas Program has funded tree removals with capital funding.

    Interior Greenbelt Natural Area, 2010. Courtesy SaveSutro

There was nothing wrong with any of these trees before they were destroyed.  Their only crime was that they were not native to San Francisco.  There are probably many other trees that were destroyed in the natural areas in the past 15 years.  We are reporting only those removals of which we have personal knowledge.

If you care about the trees of San Francisco….

If you care about the trees of San Francisco, please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks.  There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*.  Details about how to comment are available here.

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

(1) Jacobs, Growth Habits of the Eucalyptus, 1955, page 67

(2) Doughty,  The Eucalyptus, 2000, page 6

(3) San Francisco Presidio’s Vegetation Management Plan, page 28