In particular, we showed EBMUD officials photos of inappropriate applications of herbicide, specifically RoundUp (glyphosate). The photos showed that District employees were spraying RoundUp in residential neighborhoods without posting pesticide application notices. They weren’t wearing protective gear. They were spraying RoundUp on bare ground, which is not how RoundUp should be applied because it is not a pre-emergent that is effective on seeds or roots. It must be sprayed on green vegetation during the growing season. In one case, the District employee was spraying RoundUp from an ordinary garden hose, which means far more herbicide was being applied than necessary, even if anything were growing there. In other words, the manner in which RoundUp was being applied suggested that District employees didn’t understand what they were doing.
EBMUD officials were responsive to our report. They hired a Pesticide Control Advisor as a consultant to evaluate their program who identified several significant deficiencies in the District’s IPM program. The District responded by making many improvements in their use of pesticides, such as:
There is now a comprehensive, annual training program for all employees who apply pesticides.
There are now more accurate and complete records of EBMUD’s pesticide use.
The PCA consultant was retained on a contractual basis to monitor some pesticide applications for compliance with product labels and District policies.
An annual report of the District’s pesticide use, including quantities and products, is presented to the Board at an annual meeting and posted to the District’s website. (1)
The District’s IPM Program guidelines were updated and posted to the website in April 2021. (2)
The revised guidelines are more comprehensive and detailed. Requirements for posting notices of pesticide applications are clearer. (2)
Some of these improvements have probably contributed to the decrease in pesticide use in the past five years from over 600 gallons per year to over 400 gallons per year. Most pesticide used by EBMUD is herbicide and most herbicide used by EBMUD is glyphosate products.
EBMUD is still using a lot of herbicide, but their practices are safer for their employees and the public. Their pesticide applications are more visible to the public and the public now has access to information about their pesticide applications.
EBMUD uses pesticides primarily to maintain their facilities. Little pesticide is used on EBMUD’s watershed property. EBMUD does not use herbicide to prevent eucalyptus and bay laurel resprouts when those tree species are destroyed. Most trees destroyed by EBMUD are intended to reduce fire hazards and many of the tree removals are requested by Cal Fire.
It pays for the public to pay attention to what is happening on our public lands and to speak up if you see something that doesn’t make sense to you. There are usually mechanisms for figuring out what is happening, asking questions, and making your concerns known.
Changing public policy isn’t easy, but it can be done. It’s often frustratingly slow and it takes persistence. Personally, I have found it more effective to be consistently polite and as patient as needed to get your message through. In the case of EBMUD’s pesticide use practices, there is more they can do to reduce their use of pesticides, so the public should continue to pay attention because the quality of our water is extremely important to our health.
Annual IPM Report is available HERE. Scroll down to to “Integrated Pest Management” and lick on “Annual IPM Report.”
IPM Guidelines are available HERE. Scroll down to “Integrated Pest Management” and click on “IPM Guidelines 2021.”
I began studying the native plant movement and the “restoration” projects it spawned over 20 years ago when I learned about a proposal to change my neighborhood park in San Francisco in ways that were unacceptable to me. Virtually all the trees in the park were non-native and the original proposal would have destroyed most of them. The trees provide protection from the wind as well as a visual and sound screen from the dense residential neighborhood. A treeless park in a windy location is not a comfortable place to visit.
The original plans would have made the park inhospitable to visitors for several other reasons, particularly by reducing recreational access to the park. The prospect of losing my neighborhood park turned me into an activist. I eventually learned there were similar plans for most major parks in San Francisco. My neighborhood organized to prevent the destruction of our park and to some extent we succeeded. However, we were unable to prevent the city-wide plan from being approved in 2006, after fighting against it for nearly 10 years.
When I moved to the East Bay, I learned that similar projects are even more destructive than those in San Francisco, I have spent the last 20 years informing myself and others of these plans, visiting those places, and using whatever public process that was available to oppose the plans. The following paragraphs are brief descriptions of the projects I have studied for over 20 years.
Tree Destruction Projects in the East Bay
East Bay Municipal Utilities District (EBMUD) is the public utility that supplies our water in the East Bay. To accomplish that task, EBMUD manages 28,000 acres of watershed land. Like most open space in the Bay Area, the vegetation on EBMUD’s land is a mix of native and non-native species. EBMUD destroys non-native trees which it believes to be a fire hazard. EBMUD uses herbicides to “control” non-native vegetation, but it does not use herbicides on tree stumps to prevent resprouting. EBMUD reports using 409 gallons of herbicide and 6 gallons of insecticide in 2019. Of the total amount of herbicide, 338 gallons were glyphosate-based projects. EBMUD says “minor amounts of rodenticide were applied by contractors.”
The East Bay Regional Park District (EBRPD) approved the “Wildfire Hazard Reduction and Resource Management Plan” and its Environmental Impact Report in 2009. This plan is removing most eucalyptus, Monterey pine, and acacia from several thousand acres of parkland. Forests are being thinned from an average density of 600 trees per acre to approximately 60 trees per acre. These plans are being implemented and funding for completion of the project has been secured. Herbicides are used to prevent the trees from resprouting and to destroy vegetation deemed “invasive.”
UC Berkeley clear-cut over 18,000 non-native trees from 150 acres in the Berkeley hills in the early 2000s. UCB applied for a FEMA grant to complete their clear-cutting plans. The FEMA grant would have clear cut over 50,000 non-native trees from about 300 acres of open space in the Berkeley hills.
In 2016, FEMA cancelled grant funding as a result of a lawsuit and subsequent appeals from UCB were defeated several years later. In 2019, UCB revised its original plans. With the exception of clear-cutting ridgelines, the revised plan will thin non-native forests. Herbicides will be used to prevent the trees from resprouting.
The City of Oakland applied for a FEMA grant in collaboration with UC Berkeley to clear cut non-native trees on over 120 acres in the Oakland hills. That FEMA grant was cancelled at the same time UC Berkeley lost its grant funding. Oakland has also revised its plans for “vegetation management” since the FEMA grant was cancelled. The revised plan will thin non-native forests on over 2,000 acres of parks and open space. The plan is undergoing environmental review prior to implementation. Herbicide use to implement the plan is being contested.
Tree Destruction Projects in San Francisco
The Natural Areas Program (now called Natural Resources Division) of the City of San Francisco has destroyed thousands of trees in 32 designated areas of the city’s parks since the program began in 1995. The management plan for the Natural Areas Program was approved in 2006, after 10 years of opposition. The plan proposes to destroy an additional 18,500 trees over 15 feet tall and untold numbers of smaller trees that the plan chooses not to define as trees. Herbicides are used to “control” non-native vegetation and prevent trees from resprouting after they are cut down.
University of California at San Francisco (UCSF) began its effort over 20 years ago to destroy most non-native trees on 66 acres of Mount Sutro. UCSF applied for a FEMA grant to implement those plans based on their claim that the Sutro Forest is a fire hazard. UCSF withdrew the grant application after FEMA asked for evidence that the forest is a fire hazard. San Francisco is cool and foggy in the summer, making fires rare and unlikely.
UCSF’s plans to destroy most trees on Mount Sutro were approved in April 2018. Many trees on Mount Sutro have been destroyed since the project was approved and more will be destroyed before the project is complete. UCSF made a commitment to not use pesticides in the Sutro Forest. Many of the trees that have been destroyed have therefore resprouted. Unless the resprouts are cut back repeatedly, the forest is likely to regenerate over time.
Tree Destruction Projects on Federal Lands
The federal government is one of the largest landowners in the Bay Area. Golden Gate National Recreation Area (75,500 acres), Point Reyes National Seashore (28,800 acres), and Muir Woods National Monument are operated by the National Park Service. The Presidio in San Francisco is a National Park that is presently controlled by a non-profit trust. These parks have engaged in extensive tree-removal on the public lands they control. Information available on their websites does not enable us to quantify the acres or number of trees that have been removed or are planned for removal in the future. Therefore, we will describe those projects in the broad terms available to us.
There are two main categories of tree-destruction projects on these federal lands. There are many large-scale “restoration” efforts that have required the removal of all non-native vegetation, including trees. These attempts to eradicate non-native plants are based on a misguided belief native plants will magically return. Herbicides are used by National Park Service to destroy non-native vegetation, although specific information is difficult to obtain because NPS is not responsive to inquiries and the federal public records law can take years to respond.
Eradication efforts fail regardless of method used
In “Lessons learned from invasive plant control experiments: a systematic review and meta-analysis,” scientists analyzed 355 studies of attempts to eradicate non-native plants from 1960 to 2009. The scientists determined the methods used and the efficacy of those methods. More than 55% of the projects used herbicides, 34% used mechanical methods (such as mowing, digging, hand-pulling), 24% burned the vegetation, and 19% used all three methods. The study found that herbicides most effectively reduced “invasive” plant cover, but this did not result in a substantial increase in native species because impacts to native species are greatest when projects involve herbicide application. Burning projects reduced native coverage and increased non-native coverage. In other words, it doesn’t matter what method is used, eradicating non-native plants does not result in the return of native plants. We didn’t need a study to tell us this. We can see the results with our own eyes.
Flammability of plants is unrelated to nativity
The other, larger category of tree-removal projects on these federal lands are the so-called “fuel management projects.” The flammability of non-native plants and trees is exaggerated in order to justify their destruction. Native plants are not inherently less flammable than non-native plants.
In fact, native vegetation in California is fire adapted and fire dependent for germination and survival. The California Native Plant Society recently revised its “Fire Recovery Guide. The Guide now says, “California native plants are not inherently more likely to burn than plants from other areas.” This statement is the mirror image of what defenders of our urban forest have been saying for 25 years: “Non-native trees are not inherently more flammable than native trees.” Both statements are true and they send the same message: flammability is unrelated to the nativity of plants. “Think instead about characteristics of plants,” according to the CNPS “Fire Recovery Guide.”
There are undoubtedly many other similar projects of which we are unaware. I report only on projects that I have direct knowledge about and that I have visited.
Why I opposed these projects
The San Francisco Bay Area was nearly treeless before early settlers planted non-native trees. Non-native trees were planted because they are better adapted to the harsh coastal winds than native trees. The treeless grassland was grazed by deer and elk and burned by Native Americans to promote the growth of plants they ate and fed the animals they hunted. Grazing and burning maintained the grassland, preventing natural succession to shrubs and trees.
Modern land use and management policies have suppressed fire and reduced grazing in the Bay Area. Consequently grasslands are naturally converting to chaparral and scrub. Although managers of public lands often describe these changes in the landscape as “invasions,” Jon Keeley (Ph.D. biologist, USGS) considers them a natural succession: “These changes are commonly referred to as shrub invasion or brush encroachment of grasslands. Alternatively, this is perhaps best viewed as a natural recolonization of grasslands that have been maintained by millennia of human disturbance.”
When trees are destroyed, the unshaded ground is quickly colonized by weeds that are then sprayed with herbicide. Even environmental organizations that support the destruction of non-native trees agree about the results of these projects:
The California Native Plant Society predicted the post-project landscape in its written public comment on the Draft Environmental Impact Statement (DEIS) of the FEMA project in the East Bay hills with this rhetorical question: “What mechanism is being instituted by FEMA in this DEIS to guarantee a commitment of money and personnel for management of greatly increased acreages of newly created annual weedy grassland?”
The Audubon Society predicted the post-project landscape in its written public comment on the DEIS: “There is no support for the conclusion that native vegetation will return on its own. This plan may not result in an increase in native trees and plants…Heavy mulching will delay or prevent the growth of native species.”
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?
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:
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.”
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.
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!!
The Marin Municipal Water District stopped using herbicides on its properties in about 2005, in response to the public’s concerns. MMWD then hired consultants to evaluate the risks of using herbicides. As a result of those studies, MWWD decided in 2015 to make a permanent commitment to NOT using herbicides on its properties.
A member of the Board of Directors of MMWD has written a public comment for the East Bay Municipal Utilities District Master Plan in which he explains why MMWD made this decision. His letter is available here: MMWD – public comment from Board member
Here is a summary of the reasons why MMWD no longer uses herbicides on its properties:
The International Agency for Research on Cancer reclassified glyphosate as a “probable carcinogen.”
The California Office of Environmental Health Hazard Assessment has recommended that glyphosate be listed under Proposition 65.
A study conducted by researchers at UC Davis found that glyphosate persisted for at least 84 days when applied to foliage. “The clear inference from this study is that glyphosate could well migrate to water courses and streams which feed MMWD’s reservoirs.”
The toxicity of herbicides to aquatic life and habitat is well documented.
The persistent toxicity of many herbicides decreases soil biota which reduces CO2 absorption. “Hence, it appears that the non-pesticide approach may well assist with society’s ongoing efforts to remediate GHG through regenerative forestry practices.”
Thank you, MMWD, for writing this letter to EBMUD about their use of pesticides on our watershed in the East Bay. EBMUD should follow your lead!
Please write your own public comment on the East Bay Municipal Utilities District Master Plan. Public comments are due by Friday, September 16, 2016. Comments should be sent to email@example.com or by mail to Doug Wallace, EBMUD, 375 11th St, Oakland, CA 94607.
There is also a petition to EBMUD that we encourage you to sign:
East Bay Municipal Utilities District (EBMUD) is the public utility that supplies our water in the East Bay. To accomplish that task, EBMUD manages thousands of acres of watershed land. Like most open space in the Bay Area, the vegetation on EBMUD’s land is a mix of native and non-native species.
EBMUD is revising its Master Plan. The draft Master Plan makes a commitment to destroy all eucalyptus and Monterey pines in favor of native vegetation. The draft Master Plan is available HERE. EBMUD is accepting written public comments on the draft Master Plan until September 2, 2016 extended to Friday, September 16, 2016. Comments should be sent to firstname.lastname@example.org or by mail to Doug Wallace, EBMUD, 375 11th St, Oakland, CA 94607.
There is also a petition to EBMUD that we encourage you to sign:
One of the reasons why we are concerned about the revised East Bay Watershed Master Plan (EBWMP) is that EBMUD is using a lot of pesticide now. The draft Master Plan says that “pesticides have been detected in District reservoirs.”The Master Plan renews its commitment to “replace non-native forests with native species over the long term.” In this post, we will tell you about the pesticides that EBMUD is using now and explain how destroying trees is likely to increase their pesticide use.
How much pesticide is EBMUD using now?
We have obtained the Pesticide Use Reports (PURs) that EBMUD submitted to Alameda and Contra Costa Agriculture Departments, as required by law. According to these Pesticide Use Reports, EBMUD applied herbicides 647 times in 2015. It used 700.91 gallons and 205.75 lbs. of herbicide in 2015. Of that total herbicide quantity, 255 gallons were glyphosate products.
That is probably an underestimate of the amount of pesticide EBMUD used because:
Many of the PURs did not provide any information about the number of applications. Therefore, the total number of applications is higher than 647.
EBMUD (and all other “permittees”) is not required to report to the county pesticide applications done by contractors. For example, EBMUD’s PURs do not include any rodenticide applications, which EBWMP says it uses. That is an indication that the reports are not complete.
Is that a lot of pesticide?
Compared to other public land managers, EBMUD is using a LOT of pesticide. East Bay Regional Park District (EBRPD) is an appropriate reference point. 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. EBRPD’s reports include most pesticide applications done by contractors, according to EBPRD.
In contrast, EBMUD used 700.91 gallons and 205.75 lbs of herbicide on only 28,000 acres of property. In other words, EBMUD pesticide use looks extreme when compared to EBRPD pesticide use. The fact that EBMUD is responsible for supplying our drinking water (and the park district is not) makes the discrepancy that much more disturbing. It seems that they should be using significantly less than they are using now.
The loss of shade will put EBMUD onto the pesticide treadmill
Destroying all non-native trees will promote the growth of weeds because shade is the most benign method of suppressing weed growth. Most herbicide applications are for the purpose of killing weeds. We have experience in the East Bay with the rampant growth of weeds where trees have been destroyed. UC Berkeley destroyed all eucalyptus on the south side of Claremont Blvd at signpost 29 about 10 years ago. They spread several feet of wood chips on the ground where they destroyed the trees, hoping to suppress the growth of weeds. Signpost 29 is now dominated by weeds, including where wood chips were piled high. Here are a few pictures that illustrate that weeds quickly colonize the bare ground when trees are destroyed. Note that the weeds are dead where they have been sprayed with herbicide. Dead weeds are more flammable than weeds that are still green, so killing them before they are dormant needlessly increases fire hazards.
Destroying trees will eliminate shade. The loss of shade will increase the growth of weeds. More weeds will require more herbicide applications to destroy the weeds. Using more herbicide will contaminate the watershed and reduce water quality. Shade is the most benign method of controlling weeds.
How will EBMUD prevent resprouts without using more pesticide?
One of the “Guidelines for Eucalyptus Management” in the Master Plan is: “Prior to any harvest activities, ensure that adequate stump-sprouting control methods are available to reduce fire hazards and protect water quality.” This is an artful and fundamentally dishonest dodge. EBMUD must inform the public of the methods they intend to use. If herbicides are used for this purpose, EBMUD’s use of pesticides will increase substantially.
The majority of public land managers are now using Garlon to prevent eucalyptus resprouts, i.e., East Bay Regional Park District, City of Oakland, UC Berkeley, and National Park Service. East Bay Regional Park District said in the Environmental Impact Statement for the FEMA project that it planned to use 2,250 gallons of Garlon for that purpose.
Garlon, with the active ingredient triclopyr, is one of the most toxic herbicides on the market. The risk assessment of triclopyr that was done for Marin Municipal Water District says that Garlon is acutely toxic to aquatic life and moderately toxic to birds and bees. It is also known to damage mycorrhizal fungi in the soil, which will retard the growth of anything planted when the trees are destroyed. The risk assessment done for the California Invasive Plant Council says that Garlon “poses developmental and reproductive risks” to female applicators.
Garlon is sprayed on the tree stump shortly after the tree is destroyed, while the cambium layer is still alive and capable of transporting the herbicide into the roots of the trees. It prevents resprouts by killing the roots. This usually has to be done several times. Garlon is known to be mobile in the soil, which is why it frequently damages non-target trees that are growing closely enough that their root structure intertwines with the roots of eucalyptus.
The only public land manager that has made a commitment to destroy approximately 15,000 eucalyptus without using herbicides is UCSF for its open space on Mount Sutro in San Francisco (to our knowledge). They have been destroying eucalyptus on their properties for several years. You can visit their property to see that they are not successfully controlling resprouts of the trees they have destroyed.
Marin Municipal Water District (MMWD) recently made a commitment to not using any herbicides on its properties. It did not make that commitment willingly. It was forced to make that commitment by its customers, who fought for years to accomplish that ban on herbicide use. EBMUD should take heed. The more pesticide EBMUD uses, the more likely the public will protest that use. I don’t know if MMWD has stopped destroying eucalyptus on its property. Given that it cannot use pesticides, it would be wise to stop destroying eucalyptus trees.
If EBMUD persists with its plans to destroy all eucalyptus trees on its properties it must inform the public of what method it intends to use to prevent resprouts. EBMUD must choose between two bad options if it destroys the trees. If it uses herbicides to prevent resprouts, it will contaminate our water supply. If it controls resprouts by cutting them down once or twice a year, it will substantially increase its labor costs. The best option is to abandon the foolish plan to destroy all eucalyptus on its property.
What is EBMUD’s job?
The main mission of EBMUD is to supply clean drinking water to communities in the East Bay. Any other objective—such as conservation of native plants—must be considered secondary to the mission of providing clean water. If the conservation or restoration of native plants is in conflict with EBMUD’s obligation to provide clean drinking water, it must abandon or revise that commitment so that it is consistent with EBMUD’s main mission.
Please sign the petition and send a written public comment to EBMUD by September 2, 2016 extended to Friday, September 16, 2016. Thank you for your help.
East Bay Municipal Utilities District (EBMUD) is the public utility that supplies our water in the East Bay. To accomplish that task, EBMUD manages thousands of acres of watershed land. Like most open space in the Bay Area, the vegetation on EBMUD’s land is a mix of native and non-native species.
EBMUD is revising its Master Plan. The draft Master Plan renews its commitment to destroying all eucalyptus and Monterey pines in favor of native vegetation. The draft Master Plan is available HERE. EBMUD is accepting written public comments on the draft Master Plan until September 2 extended to Friday, September 16, 2106. Comments should be sent to email@example.com or by mail to Doug Wallace, EBMUD, 375 11th St, Oakland, CA 94607.
EBMUD held a public meeting about its draft Master Plan on Monday, August 15, 2016. That meeting was attended by over 200 people. Most of the crowd seemed to be there to defend their access to EBMUD trails by bicycles.
There were 10 speakers who defended our trees against pointless destruction and the consequent pesticide use to prevent their resprouting. As usual, the Sierra Club came to object to increased access for bicycles and to demand the eradication of our trees. As usual, claims of extreme flammability of non-native trees was their stated reason for demanding the destruction of the trees. Update: HERE is a video of speakers at the EBMUD meeting for and against tree destruction and pesticide use.
Furthermore, our native trees are dying of drought and disease. This article in the East Bay Times informs us that 70 million native trees have died in the past four drought years and that the millions of dead trees have substantially increased fire hazards. In other words, it is profoundly stupid to destroy healthy, living trees at a time when our native trees are dying and pose a greater fire hazard.
We are grateful to Save the East Bay Hills for permitting us to publish their excellent letter to EBMUD about their misguided plans to destroy our urban forest. We hope that their letter will inspire others to write their own letters to EBMUD by September 2, 2016. Save the East Bay Hills is a reliable source of information about our issue. Thank you, Save the East Bay Hills for all you do to defend our urban forest against pointless destruction.
Update: Save the East Bay Hills has also created a petition to EBMUD that we hope you will sign and share with others. The petition is available HERE.
August 15, 2016
Douglas I. Wallace
Environmental Affairs Officer
Master Plan Update Project Manager
East Bay Municipal Utility District
375 11th Street
Oakland, CA 94607
Dear Mr. Wallace,
This letter serves as our response to the East Bay Municipal Utility District’s invitation for the public to review and comment on the draft of the East Bay Watershed Master Plan (“Draft Master Plan”) update. There is much in the plan to recommend itself and much that leaves a lot to be desired.
We are grateful that the Draft Master Plan recognizes the value of trees regardless of their historical antecedents, specifically noting that,
“Eucalyptus trees provide a source of nectar and pollen that attracts insects, which in turn serve as a prey base for birds and other animals. Hummingbirds and many migratory bird species feed extensively on the nectar. In addition, eucalyptus trees produce an abundant seed crop. These tall trees are used as roosting sites for birds. Bald eagles have roosted in eucalyptus groves in the San Pablo Reservoir watershed, and a great blue heron rookery exists in the eucalyptus trees at Watershed
Headquarters in Orinda. A great blue heron and great egret rookery was active near the northern arm of Chabot Reservoir in the recent past.”
The Draft Master Plan recognizes, “the ecological value and likely permanence of certain nonnative species and habitats,” including Eucalyptus and Monterey Pine. It recognizes that these two species of trees, especially Monterey Pine “provide stability to watershed soils” and “provide erosion control with a widespreading root system.”
It recognizes that they provide “protection from solar exposure, wind, and noise.”
It recognizes that they “provide biodiversity value (bald eagle and other raptor species) on District watershed lands.” For example, “Monterey Pine seeds provide food for small rodents, mammals and birds…”
It cites to the EBMUD Fire Management Plan which recognizes the value of trees in mitigating fire: “They do not represent a significant fire hazard when the understory is maintained for low fire intensities… Stands that are well spaced with light understory, proper horticultural practices, and maintenance of trees, e.g. spacing and above-ground clearance, can serve to minimize fire hazard.”
It admits that removing the trees would lead to inevitable grasses and shrubs which increase the risk of fire: “The most susceptible fuels are the light fuels (grasses, small weeds, or shrubs)…”
Finally, it recognizes that these tall trees occupy a very small portion of District lands: 1% for Eucalyptus and 2% for Monterey Pines.
Given their immense beauty, the habitat they provide, their mitigation against fire, the erosion control, all the other recognized benefits, and the fact that they occupy such a small percentage of overall District lands, why does the Draft Master Plan propose that they be eradicated over time?
The answer appears to be nothing more than perceived public will:
“As this species is considered a nonnative pyrophyte, regional pressure is present to reduce the number of Monterey Pine stands.”
“As a nonnative pyrophyte, eucalyptus plantations are a target of regional public pressure for removal.”
This is a misreading of the public will. The Draft Master Plan is elevating the nativist agenda of a loud, vocal minority over good sense, good science, ecological benefit, protection against fire, and the desires of the vast majority of residents and users of District lands. How do we know?
The City of Oakland, the University of California, and the East Bay Regional Park District have also proposed eradicating Monterey Pine and Eucalyptus trees and of the 13,000 comments received by FEMA during the public comment period following its draft plan, roughly 90% were in opposition by FEMA’s own admission. Moreover, over 65,000 people have petitioned the City of Oakland to abandon its effort to remove the trees.
That EBMUD does not hear from people who find beauty, shade, and benefit in the trees is not because they do not care; rather, it is because most members of the public do not understand the extent to which these trees are under siege by nativists, nor the level of cooperation these individuals are receiving from public lands managers to see their vision prevail.
For most members of the public, it simply strains credulity that those tasked with overseeing our public lands would cooperate with efforts to destroy not only large numbers of perfectly healthy trees, but given their height and beauty, trees that are the most responsible for the iconic character of East Bay public lands and the appeal of our most beloved hiking trails. And for what end? To treat our public lands as the personal, native plant gardens of those who subscribe to such narrow views. In short, there is no widespread desire to get rid of these trees and they should not be removed.
Indeed, the Draft Master Plan recognizes several “emerging challenges” as a result of climate change including, but not limited to, “increasing average temperatures, prolonged droughts, erosion, decreased soil moisture, and augmented risk of fires.” Tall trees like Eucalyptus and Monterey Pine help mitigate these challenges. For example, fog drip falling from Monterey Pines in the East Bay has been measured at over 10 inches per year. In San Francisco, fog drip in the Eucalyptus forest was measured at over 16 inches per year.
Moreover, Eucalyptus trees are an important nesting site for hawks, owls and other birds and are one of the few sources of nectar for Northern California bees in the winter. Over 100 species of birds use Eucalyptus trees as habitat, Monarch butterflies depend on Eucalyptus during the winter, and Eucalyptus trees increase biodiversity. A 1990 survey in Tilden Park found 38 different species beneath the main canopy of Eucalyptus forests, compared to only 18 in Oak woodlands. They also prevent soil erosion in the hills, trap particulate pollution all year around, and sequester carbon.
Many of these benefits are especially important in light of Sudden Oak Death which the Draft Master Plan admits is an ongoing challenge and is likely to increase because of climate change. If Sudden Oak Death impacts oak woodlands and EBMUD intentionally cuts down Eucalyptus and Monterey Pine which are proving themselves more suitable for the environment, it risks a treeless landscape, which would not only be a loss of beauty and loss of wildlife habitat, but exacerbate the challenges already faced by EBMUD as a result of climate change.
We also object to the Draft Master Plan accepting the labels “native” and “non-native” and making decisions based on that fact alone. “Non-native” and “invasive species” are terms that have entered the lexicon of popular culture and become pejorative, inspiring unwarranted fear, knee-jerk suspicion, and a lack of thoughtfulness and moral consideration. They are language of intolerance, based on an idea we have thoroughly rejected in our treatment of our fellow human beings — that the value of a living being can be reduced merely to its place of ancestral origin.
Each species on Earth, writes Biology Professor Ken Thompson, “has a characteristic distribution on the Earth’s land surface… But in every case, that distribution is in practice a single frame from a very long movie. Run the clock back only 10,000 years, less than a blink of an eye in geological time, and nearly all of those distributions would be different, in many cases very different. Go back only 10 million years, still a tiny fraction of the history of life on Earth, and any comparison with present-day distributions becomes impossible, since most of the species themselves would no longer be the same.”
This never-ending transformation — of landscape, of climate, of plants and animals — has occurred, and continues to occur, all over the world, resulting from a variety of factors: global weather patterns, plate tectonics, evolution, natural selection, migration, and even the devastating effects of impacting asteroids. The geographic and fossil records tell us that there is but one constant to life on Earth, and that is change.
Even if one were to accept that the terms “native” and “non-native” have value, however, not only do they not make sense as it relates to Monterey Pine and Eucalyptus, but the outcome would not change for three reasons. First, Monterey Pine and Eucalyptus provide numerous tangible benefits as previously discussed, while the claimed “problem” of their foreign antecedents is entirely intangible. That a plant or animal, including the millions of humans now residing in North America, may be “non-native” is a distinction without any practical relevance beyond the consternation such labels may inspire in those most prone to intolerance; individuals, it often seems, who demand that our collectively owned lands be forced to comply to their rigid and exiguous view of the natural world. What does it matter where these trees once originated if they provide such tremendous beauty and benefit here and now?
Second, the fossil record demonstrates that Monterey Pine are, in fact, “native” to the East Bay. (See, e.g., http://evolution.berkeley.edu/evolibrary/article/montereypines_01.) Monterey Pine fossils from the middle Miocene through the Pleistocene have been found in several East Bay locations. Similarly, since Eucalyptus readily hybridizes with other species, many experts now claim that California Eucalyptus hybrids could rightly be considered native, too.
Of more immediate concern, however, is that the five narrowly defined “native” stands of Monterey Pine — the Año Nuevo-Swanton area in San Mateo and Santa Cruz Counties, the Monterey Peninsula and Carmel in Monterey County, Cambria in San Luis Obispo County, and Guadalupe and Cedros Islands off Baja California in Mexico — are in danger. In light of escalating temperatures due to climate change, to save Monterey Pine requires “a new foundation for conservation strategies of the species and its associated ecosystems. If Monterey pine has long existed in small, disjunct populations and if these have regularly shifted in location and size over the California coast in response to fluctuating climates… then it would be consistent to extend our conservation scope…” “Areas not currently within its [narrowly defined so-called] native range could be considered suitable habitats for Monterey pine conservation.” (Millar, C., Reconsidering the Conservation of Monterey Pine, Fremontia, July 1998.)
As tree lovers and environmentalists in Cambria are banding together to determine how, if at all, they can save their precious remaining Monterey Pines now dying from drought in record numbers, here in the East Bay – less than 224 miles away – land managers at EBMUD are considering plans to willfully destroy them in record numbers. It is ecologically irresponsible and for those of us who dearly love the stunning, even arresting, beauty of these trees, it is also truly heartbreaking.
Third, and perhaps more importantly, removing Eucalyptus and restoring “native” plants and trees is not only predicated on the ongoing use of large amounts of toxic pesticides, it does not work, a fact acknowledged by cities across the country. In the last ten years, the City of
Philadelphia has planted roughly 500,000 trees, many of which are deemed “non-native” precisely because “native” trees do not survive. “[R]ather than trying to restore the parks to 100 years ago,” noted the City’s Parks & Recreation Department, “the city will plant non-native trees suited to warmer climates.”
For all these reasons, we oppose the elimination of Monterey Pine and Eucalyptus, even if phased over time as proposed, and likewise oppose EBMUD’s participation in the destruction of similar Pine and Eucalyptus forests in the Caldecott Tunnel area, in partnership with outside agencies. We ask that these be stricken from the Master Plan.
Finally, we oppose the ongoing and, if the trees are cut down, potentially increasing use of pesticides and ask that a ban on their use be put in effect in the final Master Plan, for the following reasons:
● Extremely low levels of pesticide exposure can cause significant health harms, particularly during pregnancy and early childhood.
● Children are more susceptible to hazardous impacts from pesticides than are adults and compelling evidence links pesticide exposures with harms to the structure and functioning of the brain and nervous system and are clearly implicated as contributors to the rising rates of attention deficit/hyperactivity disorder, widespread declines in IQ, and other measures of cognitive function.
● Cancer rates among children are increasing at an alarming rate and pesticide exposure contributes to childhood cancer, as well as other increasingly common negative health outcomes such as birth defects and early puberty.
● Approximately 4,800,000 children in the United States under the age of 18 have asthma, the most common chronic illness in children, and the incidence of asthma is on the rise. Emergence science suggests that pesticides may be important contributors to the current epidemic of childhood asthma.
● Animals, including wildlife and pets, are at great risk from exposure to pesticides, including lethargy, excessive salivation, liver damage, blindness, seizures, cancer, and premature death.
● Pesticides contain toxic substances, many of which have a detrimental effect on animal health, including pets, raptors, deer, and other wildlife, which is compounded when the bodies of poisoned animals are ingested by subsequent animals.
● The U.S. Environmental Protection Agency has recommended non-chemical approaches, such as sanitation and maintenance.
These concerns are compounded by the fact that pesticides are to be administered near reservoirs, threatening the safety and integrity of our water supply and the water supply of the plants and animals who also depend on it. These reasons are why the Marin Municipal Water District removed the use of herbicides from further consideration in its Draft Plan and maintained the pesticide ban it has had in place for several years.
Pesticides are not only dangerous, they are also incredibly cruel. Rodenticides, for example, are opposed by every animal protection group in the nation because not only do they kill animals, but they do so in one of the cruelest and most prolonged ways possible, causing anywhere from four to seven days of suffering before an animal finally comes to the massive internal bleeding these poisons facilitate. This long sickness period often includes abnormal breathing, diarrhea, shivering and trembling, external bleeding and spasms, suffering and death that is perpetuated when their dead bodies are ingested by subsequent animals, such as owls and raptors. Put simply, EBMUD should not be in the business of targeting any healthy animals, trees, and plants for elimination; and doing so by pesticides harms animals well beyond the target species, including humans.
In summary, public agencies overseeing public lands have a responsibility to minimize harm and reject radical transformations of those lands and the ecosystems they contain, especially in absence of any clear public mandate. Not only have these lands been handed down in trust from prior generations for us to enjoy, preserve, and bequeath to future generations, but there is a reasonable expectation on the part of most citizens that those overseeing our collectively owned lands not undertake agendas to destroy large numbers of healthy trees, kill healthy animals, and poison our environment. Regardless of how Eucalyptus and Monterey Pine trees may be maligned by the extreme few, they are beloved by the many, being in large part responsible for the East Bay’s beauty, iconic character and treasured, shady walking trails and picnic areas.
In the case of EBMUD, this orientation is even more alarming and a violation of the public trust because it elevates the ideological driven, nativist agenda of the few above the agency’s primary mandate and interests of the many: ensuring the integrity and safety of our water supply and the plants and animals who reside there. Adopting plans to alter pre-existing landscapes through the use of toxic pesticides in order to placate unreasonable and xenophobic demands on lands that contain the public’s precious reserves of drinking water is a deep inversion of priorities.
We respectfully request that these proposed ends and means be stricken from the Master Plan.