California’s “Sustainable Pest Management Roadmap” is a 25-year poisonous pathway

California’s Department of Pesticide Regulation (DPR) has published a draft of a policy that would replace its Integrated Pest Management policy with a Sustainable Pest Management (SPM) policy that is different in name only.  SPM makes a commitment to continue using pesticides in California until 2050, and by implication, beyond.  It makes NO commitment to reduce pesticide use or reconsider the current targets of pesticide applications.  It claims that the health hazards and damage to the environment will be reduced by identifying “Priority Pesticides” for possible substitution or “eventual elimination.”  It doesn’t commit to identifying any specific number of dangerous pesticides nor does it provide specific criteria for selecting these dangerous products.  It claims that increased testing and development of new products will result in safer products and puts these judgments into the hands of “stakeholders” with “experiential and observational knowledge” rather than scientists with expertise in soil science, endocrinology, toxicology, epidemiology, biology, botany, horticulture, etc.  The “stakeholder” committee that wrote the SPM proposal for urban areas included the manufacturer of pesticides and other users and promoters of pesticides. 

That’s not an exhaustive list of the many faults of SPM and the dangers that lurk in it.  I hope you will read it yourself and consider writing your own public comment by the deadline on Monday, March 13, 2023, at 5 pm.  The document is available HERE.  It’s less than 100 pages long and it is a quick read because it is basically a collection of bullet-points.

This is how to comment:  “DPR is accepting public comments to inform the prioritization and implementation of the Roadmap’s recommendations through March 13, 2023 at 5 p.m. Comments can be shared in writing to or by mail to the department at 1001 I Street, P.O. Box 4015, Sacramento, CA 95812-4015.” Please note that Department of Pesticide Regulations is not offering revisions, only “prioritization and implementation.” 

My public comment on California’s “Sustainable Pest Management Roadmap”

 A summary of my public comment is below.  A link to the entire comment is provided at the end of the summary:

Public Comment on
“Sustainable Pest Management Roadmap”
(AKA “Pathway to poisoning the environment for another 25 years”)

My public comment is focused on pesticide use in urban areas because of my personal experience and knowledge of pesticide use where I live.  These are the broad topics I will cover in detail with specific examples later in my comment:

  • Since glyphosate was classified as a probable carcinogen by the World Health Organization in 2015 and the manufacturer of glyphosate settled 100,000 product liability lawsuits by awarding $11 billion to those who were harmed by glyphosate, public land managers have been engaged in the process of substituting other, usually equally or more dangerous herbicides for glyphosate to deflect the public’s concerns.  The Sustainable Pest Management Roadmap (SPM) formalizes this process of substitution without addressing the fundamental problems caused by pesticides. 
  • SPM endorses the status quo that exists now.  Affixing the word “Accelerating” to SPM is an extreme case of double-speak that deliberately obscures, disguises, distorts, or reverses the meaning of words.  SPM ensures that toxic pesticides will be used in California for more than 25 years, to 2050, and likely beyond.  SPM therefore accelerates the damage to the environment that is occurring now.  Given that climate change will enable the movement of more pests into areas where they are now suppressed by weather, greater use of pesticides should be anticipated so long as the underlying issue is not addressed.
  • The underlying issue is that pests have been identified for eradication that in some cases cannot be eradicated and in other cases should not have been identified as pests either because they are innocuous or because of the valuable ecological functions they perform.  The key question that SPM does not address is whether pesticide use is truly necessary in the first place.  Unless we focus on whether a pesticide is actually necessary, all other issues are merely window dressing for perpetual pesticide use. 
  • SPM proposes to identify “Priority Pesticides” for possible substitution without any clear definition of “Priority Pesticides,” a process that is ripe for manipulation. Given the substitutions that are occurring now, we cannot assume that further substitutions would be less toxic. SPM puts the classification of “Priority Pesticides” into the hands of “stakeholders” without clearly identifying who stakeholders are.  SPM says “stakeholders” were involved in the development of the proposed policy.  Those stakeholders included only users and promoters of pesticide use.  There was no representation on the Urban Sub-Group of organizations such as Californians for Pesticide Reform, California Environmental Health Initiative, Beyond Pesticides, Center for Environmental Health, Environmental Working Group, etc.  Nor was there any visible expertise in the fields of science that are capable of analyzing and evaluating the impact of pesticides, such as soil science, endocrinology, toxicology, entomology, botany, biology, or horticulture.  SPM ensures that this exclusion will continue during the implementation phase by suggesting that “experiential and observational” knowledge should be represented on an equal footing with undefined “science.”  The word “science” is being used and abused by advocates for pesticide use who dangle it as a magic talisman, conferring fraudulent credibility. 

My entire public comment is available here:

A Milestone for Million Trees

As the Million Trees blog approaches the anniversary of its eighth year, we are celebrating a milestone. Yesterday, Million Trees reached a total of 250,000 individual views of posts on Million Trees.  We now have over 300 subscribers and we are averaging about 150 views per day.  About 25% of our readers are outside the United States.  Since nativism in the natural world is an international fad, we are gratified that Million Trees is being read by people in other countries.  Million Trees is also proud and grateful for the participation of several academic scientists who have written informative guest posts for Million Trees in the past year.  Thank you, Dr. Matt Chew, Professors Mark Davis and Art Shapiro, and Dr. Jacques Tassin for your help!

Our most popular posts have each been visited by over 10,000 readers.  They are, in the order of their popularity:

  • “Darwin’s Finches: An opportunity to observe evolution in action.”  This article about the speed with which adaptation and evolution occur in a rapidly changing environment is the bedrock of the Million Trees blog.  Nativists mistakenly believe that evolution is much slower than it is.  Therefore, nativists believe plant and animal species are nearly immutable and that they are locked into mutually exclusive relationships, which are, in fact, extremely rare in nature.
  • “Nearly a HALF MILLION trees will be destroyed in the East Bay if these projects are approved.” The Million Trees blog was created to inform the public that nativism is destroying our urban forest in the San Francisco Bay Area.  Our urban forest is composed of predominantly non-native trees.  If they are destroyed, we will not have an urban forest because native trees will not survive in our changed and rapidly changing environment.  Non-native trees were planted here because people wanted trees and native trees existed only in riparian corridors where they were sheltered from the wind and there was sufficient water.
  • “Falling from Grace: The history of eucalyptus in California.”  Because people wanted trees, they planted non-native trees that were capable of surviving in the San Francisco Bay Area.  Non-native trees were valued for nearly one hundred years until nativism got a death grip on our public lands. This article on Million Trees tells the history of why eucalypts were planted and why they “fell from grace.”

In the past year, one of the most popular posts on Million Trees was “Krakatoa:  A case study for species dispersal.”  This post has been viewed by over 7,000 readers.  Understanding how plants and animals were dispersed around the world by natural means–such as by birds, wind, and ocean currents—is another way to realize that the concept of “native vs. non-native” is an artificial construct with little practical meaning.  Plants and animals have always moved and they will continue to move.  In fact, as the climate changes, they MUST move if they are to find the environmental conditions in which they can survive.

Million Trees Commitment

Million Trees will continue to advocate for the preservation of our urban forest in the San Francisco Bay Area.  Our strategy is to inform the public of the many projects that are destroying our forests and to describe the damage that is being done by those projects.  We are particularly concerned about the use of pesticides to eradicate non-native plants and trees.  We are equally committed to providing our readers the latest scientific discoveries that relegate invasion biology to a scientific back-water.  We are hopeful that the gap between public policy and the scientific knowledge discrediting invasion biology will eventually be bridged and bring an end to this destructive fad.

Public reactions to conferences on invasive species are always illuminating

I am publishing a guest post by Jacques Tassin, who tells us of his personal experiences with presenting his findings about invasive species in public forums.  Jacques Tassin is a French ecologist. He has been working on invasive species for more than twenty years, especially on islands in the West Indian Ocean and Pacific Ocean.

Jacques Tassin

Dr.Tassin agreed to tell us about his interactions with the public because he believes the public’s views of invasive species are poorly understood and that improved understanding of the public’s views would improve communication about this controversial topic. 

I must add that my personal experiences with such interactions have revealed the same themes.  The public feels strongly that it is possible—even necessary—to control nature.  And much of that sentiment is based on guilt about the damage that humans have done to nature and a desire for redemption.  I prefer to respond to that viewpoint by informing the public of the damage being done in the name of “restoration.”  We cannot redeem ourselves by doing yet more damage.  However, I share Dr. Tassin’s frustration with scientists who are unwilling to speak to the public in ways that the public can comprehend.

Jacques Tassin is a new voice on Million Trees.  I am grateful for his participation in our discussion of invasion biology.

Million Trees

It takes much energy for a scientist to go down to the arena to meet the general public, for example in the form of a conference. But it is well worth it. On the one hand, because it allows scientists to hear a different kind of discourse than media coverage of the issue. On the other hand, because the comments and questions from the public are often very significant.

Following the publication of my book La Grande invasion: qui a peur des espèces invasives ? (The Great Invasion: Who Fears Invasive Species?) published in editions Odile Jacob in 2014, I was often invited to such meetings. I can distinguish several types of public reactions to my conferences.

The main one is the public’s seeming intolerance of the idea that we can agree to do nothing about the progression of an invasive species, even if it is proven that nothing can be done about it, or that the species in question does not have a clearly negative ecological or economic impact. Farmers and hunters are particularly opposed to this view of not intervening and therefore not controlling the environment. For these people, it is a question of putting nature in its place.

The public also strongly rejects the possibility that we cannot redeem our faults, or that we may not be able to undo what we have done, if we do not deal with invasive species. This reaction is the result of an activist stance that is particularly present in nature conservation associations. The remark that comes up most often is “we’re not going to sit back and watch.”

Finally, the third most frequent reaction is the belief that each invasive species introduced somewhere necessarily takes the place of another species. This principle of musical chairs seems deeply rooted in everyone’s mind. It is not certain that this is due to the theories of Robert MacArthur and E.O. Wilson’s about island biogeography. It seems much more likely that, deep in our imagination, the arrival of an intruder will end up with the departure of one of us.

In any case, it seems to me that the debate about invasion biology is far more concerned with social psychology than with the science of invasions. I am now certain that those who focus their discourse on the biological and ecological dimension of invasive species are headed in the wrong direction. Today, invasion biology is more in the field of psychology and beliefs than it is a question of a rational discourse. But it is clear that scientists are particularly ill-suited for this dialogue. Journalists who are used to talking to hundreds of thousands of listeners on the radio or in the press are much better equipped to do so. Scientists must learn from journalists how to communicate with the public about invasive species, whatever the public’s opinion of invasive species.

Jacques Tassin

Further Reading:

Tassin J., Thompson K., Carroll S.P., Thomas C.D. (2017). Determining whether the impacts of introduced species are negative cannot be based solely on science: a response to Russell and Blackburn. Trends in Ecology and Evolution, 32 (4) : 230-231.

Tassin, J. and C. Kull (2015). Facing the boader dimensions of biological invasions. Land Use Policy 42 : 165-169.

Tassin, J. (2014). La grande invasion. Qui a peur des espèces invasives ? Editions Odile Jacob. Paris, 216 p.

Another legal victory in the long fight to save our urban forest

The Hills Conservation Network (HCN) has won the third legal battle against the many attempts to destroy the urban forest in the East Bay.  Every lawsuit they have filed has resulted in significant victories that have prevented three public land managers from destroying as many trees as they wanted.  We will briefly describe HCN’s early victories and end by telling you about their most recent victory.  Finally, we will explain the implications of those legal successes for the threats to the urban forest that are still anticipated.

East Bay Regional Park District

Frowning Ridge after 1,900 trees were removed from 11 acres in 2004.  This is one of UC Berkeley’s first projects to destroy all non-native trees on its properties.

When UC Berkeley clear cut all non-native trees on about 150 acres of their properties in the hills over 10 years ago, there was no opportunity for the public to object to those projects because there was no environmental impact review.  Those projects were a preview of the damage that other public land managers intended and they helped to mobilize opposition to the projects when they were formally presented to the public.

The East Bay Regional Park District (EBRPD) published its “Wildfire Hazard Reduction and Resource Management Plan” in 2009.  That plan proposed to radically thin and/or clear cut all non-native trees on several thousand park acres.  Along with HCN, I was one of the members of the public who objected to those plans for many reasons:  the loss of stored carbon and carbon storage going forward, the pesticides used to poison the non-native trees and vegetation, the increased fire hazard resulting from grassy vegetation that occupies the unshaded forest floor when the trees are destroyed.

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

EBRPD chose to ignore our objections and published an Environmental Impact Report based on the unrevised plans.  We repeated our objections to the project when the EIR was published.  The Hills Conservation Network filed their first lawsuit against the EBRPD EIR, which did not adequately address the environmental impacts of the plans.  HCN and EBRPD engaged in a long and arduous negotiation which resulted in a settlement that saved many trees in Claremont Canyon and some in other project areas.  EBRPD continues to implement their plans as revised by the HCN settlement. 

UC Berkeley and City of Oakland

Meanwhile, UC Berkeley and City of Oakland wrote their own plans and applied to FEMA for grants to implement their plans.  Their plans were more extreme than those of EBPRD.  They proposed to clear cut ALL non-native trees on their project acres. 

Once again, along with HCN, I asked that FEMA not fund those grants to UC Berkeley and City of Oakland because of the environmental damage they would do and the increased fire hazard that would result if the projects were implemented.  FEMA’s response to our objections was to require an Environmental Impact Study (the federal equivalent of an EIR) for the projects.

I joined HCN in recruiting over 13,000 public comments on the Draft Environmental Impact Study (EIS).  About 90% of those public comments were opposed to the projects.  Despite that public opposition, the EIS was approved with a few small concessions.  A few project acres would be “thinned” over a 10-year period, but ultimately all non-native trees would be destroyed on the project acres of UC Berkeley and City of Oakland.

HCN sued FEMA to prevent the funding of the projects as described by the EIS.  The Sierra Club prevented any negotiation from taking place by counter-suing.  The Sierra Club lawsuit demanded that EBRPD clear-cut ALL non-native trees.  The Sierra Club was not satisfied with the radical thinning that EBRPD is doing on most project acres.  These competing lawsuits produced a stalemate that lasted until September 2016, when FEMA cancelled all grant funding to UC Berkeley and City of Oakland in settlement of HCN’s lawsuit against FEMA.

That was truly a fantastic victory that was not anticipated.  In fact HCN’s lawsuit only asked that UC Berkeley and City of Oakland scale back their plans to use the same “thinning” strategy being used by EBRPD.  To this day, it feels like a gift.

Sierra Club’s lawsuit to force EBRPD to clear cut non-native trees on their property was dismissed by the same judge who approved the FEMA settlement.  The Sierra Club has filed an appeal of that dismissal.  Sierra Club remains fully committed to its agenda of destroying all non-native trees and using pesticides to prevent them from resprouting.

UC Berkeley’s response to losing FEMA grant

UC Berkeley attempted to satisfy CEQA requirements for an Environmental Impact Report for their FEMA project by writing an addendum to their Long Range Development Plan.  They claimed that their Long Range Development Plan adequately evaluated environmental impacts of their planned tree removals.  If they had succeeded, they would have been in a position to implement their plan without FEMA funding. 

The Hills Conservation Network filed their third lawsuit against UC Berkeley on the grounds that a brief addendum to UC’s long-range development plan did not meet legal requirements for an EIR.  The judge who heard arguments for a permanent injunction to delay implementation of the project until completion of a full EIR, agreed with HCN.  He pointed out to UC Berkeley’s lawyer that the description of the project in the long-range development plan bore little resemblance to the project presently planned.  The judge had done his homework.

The final chapter in this legal saga was that UC Berkeley attempted to avoid paying HCN’s legal fees.  California’s environmental law (CEQA) requires that the losing party pay the legal fees of the winning party.  This provision is intended to enable small citizen groups to challenge deep pocket corporations and institutions.  HCN (and its legal representative) had been adequately compensated in its first two legal battles, but UC Berkeley thought it could refuse.

The judge thought otherwise.  Not only did he require UC Berkeley to pay for its illegal attempt to avoid environmental impact review, he commended HCN for its public service:  “The Court determines that Petitioners were a successful party in this action, and that this case resulted in enforcement of important public rights and conferred a significant benefit on the public.” Yes, indeed, HCN has performed a valuable public service and we are grateful for the judge’s recognition.

For the moment, we believe that UC Berkeley’s plans to destroy all non-native trees are on hold.  They have several options.  They can complete an EIR for the original plans.  Or they can revise or abandon their plans.  We will watch them closely.

Update:  On June 14, 2017, UC Berkeley filed a lawsuit against FEMA and California Office of Emergency Services to reverse the settlement that cancelled the FEMA grants to destroy all non-native trees on UC Berkeley project acres.  (Media report on UCB lawsuit is available HERE.)  HCN is developing a legal strategy to address this latest move by UC Berkeley.  UC Berkeley’s lawsuit implies that they are still committed to their original plans to destroy all non-native trees. 

City of Oakland’s response to loss of FEMA grants

The reaction of City of Oakland to the cancellation of their FEMA grant was thankfully very different from UC Berkeley’s reaction.  In November 2016, they signed a contract to write a vegetation management plan for the purpose of reducing fire hazards.  That contract makes a commitment to conducting a complete public process, including an environmental impact review.  The contractor has already held two public meetings and an on-line survey.  We will participate in this process and we urge others to participate.  Sign up HERE to be notified of the public meetings.

The Oakland Fire Department has announced the next public meeting regarding the development of the vegetation management plan on Thursday, June 29, 2017 to provide project updates and offer an opportunity to ask questions/provide feedback. Project staff will be available to give a summary of the community survey responses received in March/April 2017, and to provide an update on Vegetation Management Plan development, methodologies, and work completed and underway.

  • Public Meeting: June 29, 2017, 5:30 PM – 7:30 PM
    Richard C. Trudeau Conference Center
    11500 Skyline Blvd
    Oakland, CA 94619

These are the Oakland city properties that will be covered by the vegetation management plan: 1,400 acres of parks and open spaces and 300 miles of roadsides.  Interactive map is available here:

We are hopeful that Oakland’s vegetation management plan will be one that we can live with.  The City of Oakland should understand that another lawsuit is an alternative if the vegetation management plan is as destructive as their original plans. 

Although I contributed to the cost of HCN’s lawsuits (along with many others), I don’t have the stomach to engage in them.  Therefore, I am deeply grateful to HCN for their courage and fortitude in preventing the total destruction of our urban forest.  Although I was skeptical of legal challenges as the way to prevent the destruction of our urban forest, I am now a convert.  The HCN lawsuits were the most effective tool we had.

The evolving goals of ecological “restorations”

We are publishing a “progress report” from a member of our tree team who attended a Weed Management Workshop on June 3, 2017.  This report suggests that the goal of local ecological “restorations” may be more realistic than they were in the past and potentially less destructive. 


I attended a Weed Management Workshop this morning that was co-sponsored by East Bay Regional Park District and the California Invasive Plant Council.  It was attended by about 70 people, representing many of the “stewardship” organizations engaged in native plant “restorations.”  The main speakers were Doug Johnson, Executive Director of the California Invasive Plant Council and Pam Beitz, a member of the Integrated Pest Management staff of the East Bay Regional Park District.

The primary purpose of the workshop was to recruit new volunteers for the many “restoration” projects in the East Bay.  Similar workshops will be offered in Mill Valley (June 17), San Jose (June 24), and Portola Valley (July 15).  Since volunteers do not use pesticides or heavy equipment, those methods of eradicating “invasive” plants were not discussed. [Information about remaining workshops available HERE.]

Although the usual accusations about the negative impact of “invasive” plants were discussed, the speakers made several acknowledgements about limitations on their objectives that represent significant progress in the 25-year debate about invasion biology.

In the spirit of encouragement, I will tell you about a few of them.

Doug Johnson set the tone at the beginning of the workshop when he said, “Non-native plants aren’t evil.  It’s important not to get ideological about this.”  The audience did not react negatively to his appeal to base judgments about non-native plants on their ecological function and impacts on ecosystems.

Pomo gathering seeds, 1924. Smithsonian photo archieve

Pam Beitz acknowledged that the historical landscapes, which “restorations” attempt to recreate were, in fact, manmade.  She provided several observations from Kat Anderson’s Tending the Wild to illustrate that point.  Native Americans intensively gardened the landscape to foster the plants they needed for food, shelter, and tools.  The implication of that history of our landscape is that ecological “restoration” must make a permanent commitment to managing the landscape. [HERE is an article on Million Trees about “Tending the Wild.”]

Beitz said the goal of these weed management projects is to eliminate “invasive” plants from a small enough area that it can be managed for the long term.  She said it is no longer considered feasible to eradicate “invasive” plants.

In answer to the question, “Why manage the wildlands?” Beitz said, “Because we are driven to alter our environment.”  She also said that human disturbance maximizes biodiversity, citing a study by Joe Connell that found the greatest diversity where there are intermediate levels of disturbance.  This is a radical departure from the earlier view that the most effective conservation eliminates all human activities.

There were also many representatives of local “restoration” projects who described their projects and recruited more volunteers.  Some of their presentations indicated the shifting emphasis of native plant “restorations.”

  • Margot Cunningham of Friends of Albany Hill said that 50% of the 300 plants on Albany Hill are natives, despite the fact that it is heavily forested in eucalyptus, and that many of those native plants are growing under the eucalypts.  She said there are 100 species of butterflies and moths and that monarchs roost in the eucalyptus trees.  There are 80 species of birds.  Her organization is trying to eliminate plants they consider invasive, such as ivy. [HERE is an article on the Million Trees blog about Albany Hill, which corroborates the view of Friends of Albany Hill.]  

    Native toyon under eucalyptus on Albany Hill
  • Wendy Tokuda is one of the most prominent native plant advocates in the East Bay.  She described several of the projects she has been working on for about 10 years, such as trying to eliminate broom along 3 miles of a trail in EBRPD.  She emphasized the importance of focusing one’s effort on a small enough area that the goal can be both attained and sustained. [HERE is an article on the Million Trees blog about the 10-year attempt to eradicate broom on a trail in the East Bay Regional Park District.]  

Broom on EBRPD trail after 10 years of effort, April 2017

  • Friends of Five Creeks said, “In a city, stewardship is forever.”

I have been following the native plant movement for over 20 years.  I believe this workshop articulated some significant departures from their original agenda:

  • There is a new understanding that the historical landscape was created by humans.
  • Any attempt to recreate the historic landscape will require a permanent commitment to manage the landscape.
  • Because of the scale of such an undertaking, it is not realistic to transform all open space to pre-settlement conditions.  Projects must be scaled to match available resources.

Anonymous member of the tree team

The observation that humans are “driven to alter our environment” struck a chord.  We are in the camp that prefers not to interfere with the workings of nature any more than necessary because we believe that human knowledge is inadequate to presume to make better management decisions than natural processes.  There are pros and cons to every change in nature.  Some plant and animal species will benefit and some will be harmed.  It’s like flipping a coin.  I prefer to put the coin in the hands of nature, rather than the hands of humans.  However, we understand and are sympathetic to the human desire to “help” nature. 

Robin and chicks. Courtesy SF Forest Alliance

A recent article in the New York Times provided a good example of how the good intentions of humans often lead to intrusions into the natural world.  The author explained how she became the self-appointed guardian of birds nesting in her garden.  Her small dog was a predator of fledgling birds.  She felt obligated to identify all the nests in her garden so that she could keep her dog indoors when the birds left the nest. 

When her dog died, she discovered that she could not give up that role.  If one bird was competing with another for a nesting spot, she found herself choosing sides, although she knew she had no business choosing winners and losers in the natural world:   “It is wrongheaded to interfere in nature when something is neither unnatural nor likely to upset the natural order.  I can’t help myself…It’s humiliating, all the ways I’ve interfered.”

We know that volunteers in “restoration” projects mean well.  Since they don’t use pesticides or have access to the heavy equipment needed to destroy trees, we don’t argue with them directly.  Our advocacy for the preservation of our urban forest is aimed at the managers of our public lands because we are as much the owners of those lands as anyone else and our tax dollars are used to fund their projects.

Million Trees

Subirdia: Birds adapt to the Anthropocene

christmas-holly-4This article is our Christmas present to our readers.  We celebrate the holidays with good news about the birds living in cities all over the world.

Subirdia was written by John Marzluff, an academic ornithologist at University of Washington. (1)  He reports many years of his research and that of his graduate students about the birds that live in urban and suburban Seattle as well as surrounding forest reserves.  He also reports on countless studies of bird populations in similar settings all over the world.  All of those studies reach remarkably similar conclusions.

It took me a long time to read this book because its introduction was off-putting.  Virtually every plant and animal was preceded by the qualifier of “native” or “non-native.”  The implication of the introduction was that the most important feature of every plant and animal is whether or not it is native.  As our readers know, we consider the nativity of plant and animal species largely irrelevant.  All plants and animals are at home in our ideal nature.

Owl nesting in eucalyptus, courtesy
Owl nesting in eucalyptus, courtesy

When I finally got around to reading Subirdia I was pleasantly surprised.  Although the author has a preference for native plants and animals, in fact, his research and that of others does not justify his obsession.  Where birds are actually found in the greatest numbers is where the habitat is most diverse, not necessarily exclusively native.

Suburbia is very birdy

The conventional wisdom is that cities are inhospitable places for birds and other wildlife.  After all, haven’t we paved over much of their habitat, interrupted their movements by fragmenting their habitat, and drained or covered water resources? In fact, bird populations in urban areas all over the world are both plentiful and diverse.

After years of counting numerous bird species in his hometown of Seattle, the author of Subirdia wondered if Seattle might be unique because it is heavily forested.  After conducting similar surveys in 10 cities around the world, Marzluff is convinced that birds are successfully adapting to rapid urbanization of human society.  The urban centers of cities in North and Central America, New Zealand and Europe support an average of 23 bird species.  He found the least number of bird species (11) in Auckland, New Zealand and the greatest number (31) in St. Andrews, Scotland.

Starling in breeding plumage. Creative Commons - Share Alike
Starling in breeding plumage. Creative Commons – Share Alike

Another popular myth about the loss of bird diversity in the Anthropocene is that the globalization of human civilization produces “homogenized” nature.  That is, many people believe that bird populations may not be in decline, but there are a few hardy species that dominate everywhere.  Again, Marzluff’s studies do not corroborate that belief.  Five bird species are found in cities all over the world (house sparrows, starlings, Canadian geese, mallard ducks, and rock pigeons).  However, these ubiquitous species are not the predominant bird species he found in cities.  Of the 151 different bird species he found in the 10 cities he visited, 75% of them were unique to each of the cities.   “Homogenization is barely perceptible.” (1)

Comparing bird populations in cities with nature reserves

Marzluff also compared bird populations in cities with undeveloped nature preserves.  Once again, cities still look like good homes for birds.  He finds twice as many bird species in Ketchikan, Alaska as in the nearby wildlands along the Naha River, “a remote wilderness fifty miles away…that required powerboat, kayak, and hiking to attain.” (1)

He also visited Yellowstone National Park, a 2.2 million acre protected area within an undeveloped ecosystem of nearly 20 million acres, where he counted 26 bird species in four days.  From there, he flew to New York City where he counted 31 bird species in Central Park in only three days.  Historical records of bird surveys in Central Park and Yellowstone National Park indicate that about 200 bird species have been found in both parks since the late 19th century.  “From a bird’s perspective, a large park created by human hands or by nature is not all that different.”  (1)

Accommodating birds in cities

Marzluff’s concluding chapters advise city dwellers how to encourage and support birds.  His “ten commandments” for accommodating birds make no mention of planting native plants or eradicating non-native plants:

  • “Do not covet your neighbor’s lawn.”
  • “Keep your cat indoors.”*
  • “Make your windows more visible to birds that fly near them.”
  • “Do not light the night sky.”
  • “Provide food and nest boxes.”
  • “Do not kill native predators.”
  • “Foster a diversity of habitats and natural variability within landscapes.”
  • “Create safe passage across roads and highways.”
  • “Ensure that there are functional connections between land and water.”
  • Enjoy and bond with nature where you live, work, and play!”

Marzluff expresses a strong preference for native plants throughout his book, but his research in Seattle is inconsistent with that preference:  “The forests of Seattle and its suburbs now embrace 141 species of trees, including 30 native species and ornamentals from North and South America, Europe, Asia, and Africa.  Some are problematic invaders, but in total they provide a diverse menu of foods and nesting and roosting sites for birds.”  (1)

Why a preference for natives?

Garter snake in eucalyptus leaf litter. Courtesy Urban Wildness
Garter snake in eucalyptus leaf litter. Courtesy Urban Wildness

Another academic scientist in Washington State, Linda Chalker-Scott, directly addresses the vexing question of why public policies which mandate the use of native plants have proliferated despite the lack of evidence that they are superior in any way.  She focuses on this question:  “Do native and nonnative woody species differ in how they affect species diversity?”  Her literature search found 120 studies from 30 countries that quantified the biodiversity of birds, insects, mammals, reptiles, and other plants in woody plants and trees in urban landscapes.

The analysis of these studies reveals that “the science does not support the supposition that native plantings are required for biodiversity…it is clear that an automatic preference for native trees when planning in urban areas is not a science-based policy.” (2) The assumption that native plants are superior to non-native plants is based on these misconceptions:

  • The definitions of native and alien species are value judgments, not science-based concepts.
  • Native plants are often poorly suited to environmental conditions in urban areas, such as compacted soil and changes in the climate. Conversely, introduced plants are often well suited to these urban conditions.
  • Many introduced plants provide valuable ecological benefits. For example, they often provide food, pollen, and nectar resources during winter months when native plants are dormant.
  • Tropical milkweed is not native to California. (Asclepias curassavica) Creative Commons
    Tropical milkweed is not native to California. (Asclepias curassavica) Creative Commons

    Doug Tallamy is the academic scientist most closely associated with the native plant ideology. His claim that insects require native plants is based on his mistaken assignment of nativity to an entire genus, when only a few species within that genus are actually native.  For example, there are over 35 species of milkweed in the genus Asclepias, but only two species are native to California.  Most members of the milkweed family are useful to monarch butterflies.  It is therefore not accurate to claim that monarchs require native plants.  They have lived all over the world for over 200 years in some places where there are no native species of milkweed.

Chalker-Scott’s meta-analysis of 120 studies concurs with Mr. Marzluff:  “The published research overwhelmingly identifies diversity, structure, and function as the most important vegetation characteristics for enhancing community biodiversity…In fact, sometimes landscapes require the inclusion of exotic trees and control of natives to maintain diversity.” (2)

Doing more harm than good

Our readers know that we do not begrudge the preference of native plant advocates for native plants.  We encourage them to plant whatever they want.  We only ask that they stop destroying the plants they don’t like.  That request is based on our belief that they are doing far more harm to our public lands than any perceived benefit of native plants.  Much of that harm is caused by the widespread use of herbicides to destroy non-native vegetation.  These herbicides are known to damage the soil and they migrate in the soil, damaging neighboring plants that are not targeted.  These issues are surely a factor in the conspicuous lack of success of their “restorations.”  There is also mounting evidence of the toxicity of herbicides to bees, birds, and other animals including humans.

But there is another, equally important reason why we object to the futile attempts to eradicate non-native plants.  They are providing valuable habitat for wildlife.  Even when they are replaced by native plants after being destroyed, the animals that depended upon them are not necessarily restored to the landscape.  In fact, few projects plant natives after the eradication of non-natives.

Japanese honeysuckle. Attribution William Rafti
Japanese honeysuckle. Attribution William Rafti

A recently published study (3) of the removal of Amur honeysuckle (Lonicera maackii) is an example of the loss of valuable habitat.  The hypothesis of this study was that “invasion of urban habitats by exotic plants was the underlying mechanism driving changes in bird-plant networks.”  The study tested this hypothesis by comparing forest plots dominated by honeysuckle with those in which honeysuckle had been removed and the surrounding forest habitat replicated.  They measured nesting birds, nest predators, and nest survival.

They found that the lowest overall nest survival rates were found in the plots in which honeysuckle had been removed.  In other words, “…removal of invasive honeysuckle from urban forests did not restore network structure to that of rural landscapes.”  The authors concede, “This finding was not consistent with our original hypothesis that invasion of forests by the exotic Amur honeysuckle was responsible for the urban-associated changes in bird-plant networks.”  They conclude, “The degree to which native communities can be restored following removal of exotic plants remains unclear.” 

Actually, we think it is quite clear that eradicating non-native plants does not benefit man or beast. We marvel that the fantasy persists that there is some theoretical benefit to killing harmless plants, despite the consistent lack of evidence of any benefit and the considerable evidence of the harm of such attempts. 

*Like most ornithologists, Marzluff comes down hard on cats as killers of birds in his book.  However, he cites just one study about predation of fledglings.  The study used radio transmitters to determine the fate of 122 newly fledged birds over a period of two years.

The results do not justify the demonization of cats:  “Only 20 percent of radio-tagged birds died during our study.  Birds such as Cooper’s hawks and mammals such as Townsends’ chipmunks, ermine, and Douglas squirrels were the most likely predators.  The most notorious of all bird predators, the out-of-the-house cat, was implicated in only one death, though we could never be entirely sure which mammal or which bird had killed the fledging.”  (1) Marzluff credits a neighborhood coyote for controlling the cat population.  Frankly, that doesn’t make sense.  Chipmunks and squirrels are just as likely to be prey for the coyotes.

We have reported on similar studies which reach the same conclusions.  A meta-analysis of 8 studies of nest predators of song birds in North America used video cameras to identify the predators of 242 depredation events.  Only one of those nest predators was a cat.

We have no objection to the general advice to keep your cat indoors. (We have never had a cat and don’t plan to.)  However, we think that estimates of birds killed by cats are greatly exaggerated.  Humans seem to have an unfortunate desire to look for scapegoats and cats seem to fit the bill for bird lovers.

  1. John M. Marzluff, Welcome to Subirdia, Yale University Press, 2014
  2. Linda Chalker-Scott, “Nonnative, Noninvasive Woody Species Can Enhance Urban Landscape Biodiversity,” Arboriculture & Urban Forestry, 2015, 41(4): 173-186
  3. Amanda D. Rodewald, et. al., “Does removal of invasives restore ecological networks? An experimental approach,” Biological Invasions, March 2015

Sierra Club cannot hide behind its smokescreen

On August 25, 2015, opponents of the projects in the East Bay Hills which will destroy hundreds of thousands of trees staged a protest at the headquarters of the Bay Area chapter of the Sierra Club and delivered a petition.  The petition (available HERE) asks the Sierra Club to quit advocating for deforestation and pesticide use in the San Francisco Bay Area and to drop its lawsuit which demands eradication of 100% of all non-native trees on 2,059 acres of public land in the East Bay.  The protest was successful as measured by the size of the crowd and the even-handed media coverage of the protest.

Sierra Club protest, August 25, 2015. About 80 people attended the peaceful protest.
Sierra Club protest, August 25, 2015. About 80 people attended the peaceful protest.

Update:  HERE is a 14 minute video of the demonstration at Sierra Club headquarters on August 25, 2015.  The video includes an attempt to discuss the issue with a Sierra Club staff member.  Note the factual rebuttals to some of the claims the staff member makes in that conversation.  Also, note the final rallying cry, “Poll your membership on this issue.”  We will report soon on the follow up to that request.  Please stay tuned.  

However, although the protest has produced a flurry of defensive propaganda from the Sierra Club, it has not created new opportunities for dialogue with them.  We tried to get the issue on the agenda of the Conservation Committee following the protest and once again our request was denied. We were also denied the opportunity to publish a rebuttal to articles in their newsletter about the projects. It is still not possible to post comments on the on-line version of the Yodeler, although each article dishonestly invites readers to “leave a comment.”

And so, open letters to the Sierra Club are the only means of communication available to us.  Here are our replies to the latest round of propaganda published in the Yodeler on September 16, 2015 (available HERE).  Excerpts from the Sierra Club article are in italics and our replies follow.


“The preferred strategy for vegetation management in the East Bay hills entails removing the most  highly flammable, ember-generating trees like eucalyptus in phases — only in select areas considered most at risk for fire along the urban-wild interface.”

Preferred by whom?  Neither fire experts nor the public think this project is a good idea, let alone the Sierra Club’s more extreme version of the project demanded by its suit.  Over 13,000 public comments on the Environmental Impact Statement were sent to FEMA, of which 90% were opposed to this project according to FEMA.  More recently, a petition in opposition to this project has over 64,000 signatures on it.  This project is NOT the “preferred strategy for vegetation management in the East Bay hills.”

Eucalyptus is not more flammable than many other trees, including native trees: 

  • A study by scientists in Tasmania found that the leaves of blue gum eucalypts were more resistant to ignition than other species of Tasmanian vegetation tested. The study credits the “hard cuticle” of the leaf for its ability to resist ignition. (1)
  • The National Park Service, which has destroyed tens of thousands of eucalypts and other non-native trees, states that eucalyptus leaves did not ignite during a major fire on Mount Tam.  (2)
  • The leaves of native bay laurel trees contain twice as much oil as eucalyptus leaves (3)  and the fuel ladder to their crowns is much lower than eucalyptus, increasing the risk of crown fires. The “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District states explicitly that bay laurel is very flammable and recommends selective removal.
  • Eucalyptus contributed more fuel to the 1991 fire in Oakland because a deep and prolonged freeze the winter before the fire caused eucalyptus and other exotic vegetation to die back. The dead leaf litter was not cleaned up, which contributed to the fire hazard.  Such deep freezes are rare in the Bay Area.  There has not been such a freeze for 25 years and another is unlikely in the warming climate.

    Eucalyptus logs line the roads where UC Berkeley has destroyed trees. Do they look less flammable than living trees?
    Eucalyptus logs line the roads where UC Berkeley has destroyed trees. Do they look less flammable than living trees?
  • Ordinarily, eucalyptus does not contribute more fuel to the forest floor than native oak-bay woodland. This is confirmed by the National Park Service, which includes logs in the calculation of fuel loads. (2) Logs are extremely difficult to ignite.  The so-called “fire hazard mitigation projects” are leaving all the eucalyptus logs on the ground when the trees are destroyed, suggesting that they aren’t considered a fire hazard.  The National Park Service also separates the fuel loads of oaks and bays, which when combined are equal to the fuel load of eucalyptus.  Since our native woodland in the East Bay is a mixture of oaks and bays, it is appropriate to combine them when comparing their fuel loads to eucalyptus.
  • Eucalypts are sometimes blamed for casting more embers than native trees because they are taller than the oak-bay woodland. However, redwoods are as tall, if not taller, and they were also observed burning in the 1991 fire:  On Vicente Road, “Two redwoods up the street caught fire like matchsticks.” (4)  Yet, the Sierra Club is not suggesting that redwoods be destroyed to eliminate the risk of casting embers.

The Sierra Club now says the trees will be removed “in phases,” yet in its suit against the FEMA grants it objects to the phasing of tree removals.  The main focus of their suit is opposition to the “unified methodology” which proposes to remove trees over the 10 year period of the grant on only 29 acres of the total project acreage of 2,059.  To those who objected to this project, that small concession is little consolation, but for the Sierra Club it was a deal-breaker.  Their suit demands that all non-native trees be removed immediately on all project acres. 

If the Sierra Club withdraws its suit against the FEMA projects, it is free to tell another story, as it attempts to do in its Yodeler article.  As long as that suit remains in play, the Sierra Club is stuck with that version of reality.

“Once the flammable non-native trees are removed, less flammable native species can reclaim those areas and provide for a rebound of biodiversity. This model of fire prevention can summarized as the the [sic] “Three R’s”:

REMOVE the most flammable non-native trees in select areas most at risk for fire;

RESTORE those areas with more naturally fire-resistant native trees and plants; and

RE-ESTABLISH greater biodiversity of flora and fauna, including endangered species like the Alameda whipsnake.”

This is a stunning display of ignorance of the project as well as the natural history of the San Francisco Bay Area:

  • The FEMA projects do not provide for any planting or funding for planting after the trees are removed. FEMA’s mission is fire hazard mitigation, not landscape transformation.  The scientists who evaluated the FEMA projects said that a native landscape is not the likely result of the project:  “However, we question the assumption that the types of vegetation recolonizing the area would be native.  Based on conditions observed during site visits in April 2009, current understory species such as English ivy, acacia, vinca sp., French broom, and Himalayan blackberry would likely be the first to recover and recolonize newly disturbed areas once the eucalyptus removal is complete.  These understory species are aggressive exotics, and in the absence of proactive removal there is no evidence to suggest that they would cease to thrive in the area, especially the French broom which would be the only understory plant capable of surviving inundation by a 2-foot-deep layer of eucalyptus chips.” (5)
  • The US Forest Service evaluation of the FEMA projects stated that the resulting landscape would be more flammable than the existing landscape: “Removal of the eucalyptus overstory would reduce the amount of shading on surface fuels, increase the wind speeds to the forest floor, reduce the relative humidity at the forest floor, increase the fuel temperature, and reduce fuel moisture.  These factors may increase the probability of ignition over current conditions.” (6)
  • The US Forest Service evaluation predicts that the resulting landscape will be “a combination of native and non-native herbaceous and chaparral communities.” Despite the overwhelming evidence that wildfires in California start and spread rapidly in herbaceous vegetation such as dry grass, the myth persists that all non-native trees must be destroyed to reduce fire hazards.  An analyst at CAL FIRE has explained to the Center for Investigative Reporting that the reason why wildfires were so extreme this summer is because of the heavy rains in December 2014, which grew a huge crop of grass:  “The moisture did little to hydrate trees and shrubs. But it did prompt widespread growth of wild grasses, which quickly dry out without rain.  ‘They set seed, they turn yellow and they are done,’ said Tim Chavez, a battalion chief and fire behavior analyst with CAL FIRE. ‘All that does is provide kindling for the bigger fuels.’” (7) We know that more dry grass starts more wildfires, yet the Sierra Club demands that we destroy the tree canopy that shades the forest floor and produces leaf litter, which together suppress the growth of the grasses in which fires ignite. 
  • The claim that native plants are “naturally fire resistant” is ridiculous. Native vegetation in California—like all Mediterranean climates—is fire adapted and fire dependent. The wildfires all over the west this summer occurred in native vegetation.  There are over 200 species of native plants in California that will not germinate in the absence of fire and persist for only 3-5 years after a fire. (8) Although all native vegetation is not equally flammable, many species are considered very flammable, such as coyote brush, bay laurel, and chamise.  To say otherwise is to display an appalling ignorance of our natural history.

    When did "environmentalism" devolve into demonizing trees?
    When did “environmentalism” devolve into demonizing trees?
  • There is no evidence that the destruction of our urban forest will result in greater “biodiversity.” There are many empirical, scientific studies that find equal biodiversity in eucalyptus forest compared to native forests.  There are no studies that say otherwise, yet the Sierra Club and their nativist friends continue to make this claim without citing any authority other than their own opinions.  (9, 10, 11)  Bees, hummingbirds, and monarch butterflies require eucalyptus trees during the winter months when there are few other sources of nectar. Raptors nest in our tall “non-native” trees and an empirical study finds that their nesting success is greater in those trees than in native trees.

The Sierra Club’s 3Rs can best be summarized as “repeat, repeat, repeat.”  Their 3Rs are based on 3 Myths:  (1) eucalyptus trees are the most serious fire hazard; (2) “native” vegetation is categorically less flammable than “non-native” vegetation, and (3) native vegetation will magically return to the hills when trees are clearcut and the hills are poisoned with herbicide.  All available evidence informs us that these are fictions that exist only in the minds of the Sierra Club leadership and their nativist friends.

 “The Sierra Club’s approach does NOT call for clearcutting. Under “Remove, Restore, Re-establish” thousands of acres of eucalyptus and other non-natives will remain in the East Bay hills. Our proposal only covers areas near homes and businesses where a fire would be most costly to lives and property. In fact, removing monoculture eucalyptus groves and providing for the return of native ecosystems will create a much richer landscape than the alternative — thinning — which requires regularly scraping away the forest floor to remove flammable debris.”

The Sierra Club’s suit against FEMA demands that all eucalyptus and Monterey pine be removed from 2,059 acres of public property.  While it is true that the project acres are not 100% of all land in the East Bay, with respect to the project acres, it is accurate to describe the Sierra Club’s suit as a demand for an immediate clearcut of all non-native trees.

FEMA Project Areas
FEMA Project Areas

Most of the project acres are nowhere near homes and buildings.  They are in parks and open spaces with few structures of any kind.  CAL FIRE defines “defensible space” required around buildings to reduce property loss in wildfires.  CAL FIRE requires property owners to clear flammable vegetation and fuel within 100 feet of structures.  Using that legal standard, the FEMA project should not require the removal of all trees from project acres.

As we said earlier, Sierra Club’s description of the landscape that will result from the removal of the tree canopy is contradicted by scientists who evaluated the FEMA project.  And their prediction that “thinning” would “require regularly scraping away the forest floor to remove flammable debris” is not consistent with the predictions of those scientists who have advised that the loss of shade and moisture resulting from the complete loss of the tree canopy will encourage the growth of flammable vegetation and require more maintenance than the existing landscape.

“Our preferred approach does NOT focus on eucalyptus merely because they are non-natives. Rather, it is because they pose a far higher fire risk than native landscapes. Eucalyptus shed ten to fifty times more debris per acre than grasslands, native live oak groves, or bay forests — and that debris, in the form of branches, leaves, and long strips of bark, ends up draped in piles that are a near-optimal mixture of oxygen and fuel for fire. Eucalyptus trees ignite easily and have a tendency to dramatically explode when on fire. Also, eucalyptus embers stay lit longer than embers from other vegetation; coming off trees that can grow above 120 feet tall, those embers can stay lit as the wind carries them for miles.”

The Sierra Club’s suit demands the eradication of Monterey pine as well as eucalyptus.  The scientists who evaluated the FEMA projects stated that there is no evidence that Monterey pine is particularly flammable and they questioned why they were targeted for eradication:  “The UC inaccurately characterizes the fire hazard risk posed by the two species however…Monterey pine and acacia trees in the treatment area only pose a substantial fire danger when growing within an eucalyptus forest [where they provide fire ladders to the eucalyptus canopy].  In the absence of the eucalyptus overstory, they do not pose a substantial fire hazard.”  (5)  It is not credible that the Sierra Club’s demand that these tree species be entirely eradicated has nothing to do with the fact that they are not native to the Bay Area.  If flammability were truly their only criterion, they would demand the eradication of native bay laurel trees.  If fear of lofting embers from tall trees were their only concern, they would demand the eradication of redwoods.

As we said earlier, redwoods looked as though they were exploding when they ignited in the 1991 fire.  And we are seeing wildfires all over the west this fire season in which native trees look as though they are exploding when they ignite.  That’s what a crown fire looks like, regardless of the species.

It defies reason to think that an ember is capable of traveling miles and still be in flames on arrival.  In fact, Sierra Club’s suit says “non-native trees can cast off burning embers capable of being carried up to 2,000 feet in distance.”  That’s a fraction of the distance the Sierra Club now claims in its hyperbolic description of the issues in the Yodeler.  Surely we can all use a little common sense to consider how unlikely it is that a fragment of a tree small enough to be carried in the wind could travel miles while remaining on fire.  Likewise, we must ask why fragments of eucalyptus trees are likely to burn longer than any other ember of equal size.  We are not provided with any reference in support of these fanciful claims other than the opinions of the authors.

“Any herbicide use to prevent the regrowth of eucalyptus once they’ve been cut down (they quickly sprout suckers otherwise) would be hand applied in minimal amounts under strict controls. Any herbicide application must undergo a full environmental review to prevent impacts on humans, wildlife, and habitat. There are also methods other than herbicide that can be used to prevent regrowth, and the Sierra Club encourages the agencies that manage the land where fire mitigation occurs to explore these alternatives to find the most sustainable, responsible option.”

Once again, the Sierra Club is stuck with the public record which describes the FEMA projects:

  • East Bay Regional Park District has stated in the Environmental Impact Statement for the FEMA project that it intends to use 2,250 gallons of herbicide to prevent the regrowth of eucalyptus.  (12)  This estimate does not include the herbicides that will be used by UC Berkeley or the City of Oakland.  Nor does it include the herbicides that will be needed to kill flammable non-native vegetation such as fennel, hemlock, broom, radish, mustard, etc.  Surely, we can all agree that thousands of gallons of herbicide cannot be accurately described as “minimal.”
  • The Sierra Club now seems to be suggesting that further environmental review will be required for herbicide use by this project. They are mistaken in that belief.  The Environmental Impact Statement for this project is completed and it admits that the project will have “unavoidable adverse impacts” on “human health and safety” and that there will be “potential adverse health effects of herbicides on vegetation management workers, nearby residents, and users of parks and open space.”  The Sierra Club’s smoke screen cannot hide that conclusion.
  • The FEMA grants have been awarded to the three public land owners and they explicitly provide for the use of herbicides to prevent eucalyptus and acacia from re-sprouting. There is nothing in the Environmental Impact Statement that indicates that “methods other than herbicide can be used to prevent regrowth,” as the Sierra Club now belatedly opines in its latest propaganda.  If the Sierra Club wants other methods to be considered, we could reasonably expect they would make such a demand in their suit against FEMA, along with all their other demands.  They do not make such a demand in their suit.  Therefore, claims that other methods are being explored are not credible.
  • Sierra Club’s claim that herbicides will be applied “with strict controls” is not credible because there is no oversight of pesticide application or enforcement of the minimal regulations that exist in the United States. After 25 years of working for the EPA, E.G. Vallianatos wrote in 2014 of his experience with pesticide regulation in Poison Spring:  “…the EPA offered me the documentary evidence to show the dangerous disregard for human health and the environment in the United States’ government and in the industries it is sworn to oversee…powerful economic interests have worked tirelessly to handcuff government oversight.”

The Sierra Club has also explicitly endorsed the use of herbicides in the public comments they have submitted on these projects and in other articles in the Yodeler:

  • Sierra Club’s written public comment on Scoping for the FEMA EIS: “We are not currently opposed to the careful use of Garlon as a stump treatment on eucalyptus or even broom when applied by a licensed applicator that will prevent spread into adjacent soils or waters.”  Norman La Force (on Sierra Club letterhead), September 12, 2010
  • “There is no practical way to eliminate eucalyptus re-sprouting without careful use of herbicides.” Yodeler, May 25, 2013

Obfuscation and insincere backpedaling

The latest Yodeler article about the FEMA projects is a lot of hot air.  It makes claims about the issues for which it provides no evidence and for which considerable contradictory evidence exists.  It contradicts previous statements the Sierra Club has made.  Most importantly, as long as Sierra Club’s suit remains in play, the demands the Sierra Club makes in that public document cannot be denied.  If the Sierra Club wishes to back away from its previous positions, it must start by withdrawing its suit, which demands that 100% of all non-native trees in the FEMA project areas be destroyed immediately.  Withdrawal of the suit would be a most welcome start on the long healing process that is required to mend the damage the Sierra Club has done to its reputation as an environmental organization in the San Francisco Bay Area.  However, the Sierra Club will not be able to reclaim its status as an environmental organization without renouncing all pesticide use on our public lands. 

The Sierra Club has isolated itself from reality.  Its leadership refuses to speak with anyone with whom they disagree.  They have become the victims of incestuous amplification.  They apparently do not read the documents they use to support their opinions.  For example, the Sierra Club suit claims the California Invasive Plant Council (Cal-IPC) has classified blue gum eucalyptus as “moderately” invasive.  In fact, Cal-IPC’s rating of blue gum eucalyptus is “limited.”  This reflects the fact that a study of aerial photographs of Bay Area parks and open spaces, taken over a 60 year period find that eucalyptus and Monterey Pine forests were smaller in the 1990s than they were in the 1930s.  (13)

We will send our petition soon to the national leadership of the Sierra Club.  If you have not yet signed our petition, we hope you will consider doing so now. 


  1. Dickinson, K.J.M. and Kirkpatrick, J.B., “The flammability and energy content of some important plant species and fuel components in the forests of southeastern Tasmania,” Journal of Biogeography, 1985, 12: 121-134.
  2. “The live foliage proved fire resistant, so a potentially catastrophic crown fire was avoided.”
  3. Ron Buttery et. al., “California Bay Oil. I. Constituents, Odor Properties,” Journal Agriculture Food Chemistry, Vol. 22, No 5, 1974.
  4. Margaret Sullivan, Firestorm: the study of the 1991 East Bay fire in Berkeley, 1993
  5. URS evaluation of UCB and Oakland FEMA projects
  6. FEMA DEIS – evaluation of US Forest Service
  8. Jon Keeley, Fire in Mediterranean Ecosystems, Cambridge University Press, 2012
  12. See Table 2.1 in Appendix F:
  13. William Russell and Joe McBride, “Vegetation Change and Fire Hazard in the San Francisco Bay Area Open Spaces,” Landscape and Urban Planning, 2003

Mysterious semantics of the native plant movement

In 2000, we wrote a public comment about plans to close areas at Fort Funston for native plant restoration that began with this quotation from Henry David Thoreau:

It is in vain to dream of a wildness distant from ourselves.  There is none such.  It is the bog in our brain and bowels, the primitive vigor of Native in us, that inspires that dream.  Thoreau

We chose that quote to introduce our comment about Fort Funston because it is a place that was entirely altered to serve as a military fort, its sand dunes stabilized with ice plant and studded with gun bunkers; it is not a place that is easily imagined as a pristine native landscape.  As with most poetry, Thoreau’s exact meaning escaped us, but what resonated was the suggestion that “wildness” exists in our minds, not in the material world.  We found comfort in knowing that over 150 years ago, Thoreau was as mystified by the concept of wildness as we are today.

Fort Funston
Fort Funston San Francisco 2011

Today, we revisit the question of the meaning of wildness or wilderness, prompted by the publication of an op-ed by Mark Dowie in the Point Reyes Light. (1)  Dowie is a journalist who is best known as the author of Conservation Refugees, in which he informs us that hundreds of thousands of indigenous people all over the world have been evicted from their ancestral lands by public and private land owners who believe humans are antithetical to their conservation goals.  Dowie tells us that the tradition of evicting humans in the interests of preserving “wilderness” began with the eviction of Native Americans from Yosemite Valley as advocated by John Muir.  This concept of preserving land by excluding all human activities is aptly called fortress conservation. 

Dowie begins his op-ed in the Light with the observation that some words have “attained such a vague and ambiguous definition that [they have] become virtually meaningless.”  The word “sustainability” has attained such status, he says and we agree.  But his focus in his op-ed is on the word “wilderness” because it is a word that has become a tool in a dispute about land use in Point Reyes, where Dowie lives.

The National Park Service defines “wilderness”

Drakes Estero.  NPS photo
Drakes Estero. NPS photo

After a protracted battle that lasted years, the National Park Service was finally successful in shutting down the Drakes Bay Oyster Company based on its contention that the existence of the oyster farm violated a commitment to return the Point Reyes National Seashore to “wilderness.”  This was a battle that tore a small community apart and the wounds from that fight are still deep.

Mark Dowie was one of many people who opposed the closing of the oyster farm and he was often eloquent in its defense in the Light.  One of many issues in this controversy was the National Park Service’s claim that the oyster farm was harming the environment.  Highly qualified scientists debunked that claim and after a review by the National Academy of Science, the claims of the National Park Service were entirely discredited.  Unfortunately, that had no influence on the final decision to close the oyster farm.

Within days of the oyster farm closing its retail operation, those who demanded its closure were on the warpath again.  In an op-ed published by the Oakland Tribune, William Katz asked the National Park Service to evict ranchers and dairy farmers in Point Reyes:  “The European invasion of this side of the continent over just the last 200 years is obviously a done deal.  This fact makes it especially necessary to complete the original mandate of the park’s creation by removing the ranchers and their bovine accoutrements and re-establishing a natural area in which we may only be visitors.”  The connection between those two sentences eludes us.  In fact, they seem contradictory.

Dowie searches for the meaning of “wilderness”

And so, the question of what defines a “wilderness” is still very much alive in Point Reyes.  Mark Dowie tells us that he has been actively seeking a meaningful definition for some years.  He turned to several indigenous cultures based on the modern assumption that pre-European cultures occupied the elusive “wilderness:”

“Over the next four years of research, I met and conversed with many indigenous people who thrived in landscapes that looked as wild as anywhere I had ever been, whose language had no words for ‘wild,’ or ‘wildness,’ or ‘wilderness.’  Naturally, I began to wonder why societies populated by urbane people who spend most of their lives, if not all of them, on the streets of places like New York City, London, Rome, Los Angeles and Winnipeg do have a word for wilderness.  And I wondered what exactly they meant by it, if anything.”

“What I finally figured out about ‘wilderness’ was that it’s really a concept that does not translate well from language to language, especially from western to indigenous languages.  So it’s really not the word that has to be translated, but an entire ecological enthnography.”

And so, Dowie turns to those who use the word “wilderness” as their definition of the goal for what our public lands and open spaces should look like and what activities should be allowed in them:

I recently overheard a debate in which to refine and defend his own personal definition, a local wilderness romantic divided the whole concept into two separate categories—uppercase and lowercase wilderness. Uppercase, he said, was “real” wilderness: vast roadless, trail-free areas occupied by many species, including large predators that want to eat humans.  Lowercase wilderness could be found in state and national parks; as virtual or abstract wilderness, it was a cunning, managed artifice of the uppercase version designed to convince eco-tourists that they are having a true wilderness experience.  The argument descended from there into such ridiculous semantic subterfuge that I walked away mumbling to myself that wilderness may not be a word at all, or a place for that matter, but as Roderick Nash concludes at the end of his 400-page tome on the subject, merely “a state of mind.” And that if wilderness exists at all, it could be as easily found and appreciated under a bench in Central Park as on the barrens of Baffin Island.”

Some of the stumps of the trees that were destroyed in Glen Canyon Park in 2013.  Taken June 2014
Some of the stumps of the trees that were destroyed in Glen Canyon Park in 2013. Taken June 2014

Yes, Mr. Dowie, you have indeed found the mysterious meaning of the word “wilderness” as a “bog in the brain,” to quote Mr. Thoreau.  We have our own example of a similar debate with native plant advocates about the future of Glen Canyon Park in San Francisco.  Our readers will remember Glen Canyon as the scene of the devastating removal of many huge, old trees and the repeated spraying of herbicides to prevent the trees from resprouting and destroy the non-native understory.  To those who objected to this destructive project, a native plant advocate responded:

Please note the term “wilderness.” It implies natural, native flora and fauna; the wild plants and the bird and animal populations that support one another. That is what we want to have if we want a wild retreat. A morass of garden escapes and foreign invasive species is to be deplored. Let’s progress toward returning the area to a REAL wilderness. Do not let the concept that a plant’s becoming established in an area is a sign of its becoming native to the area. It remains an invasive element, a weed. It disrupts and destroys the normal habitat of native plants, animals, and insects in its surroundings.  It will be a huge and long term task, but we can restore the entire canyon to a truly wilderness state. Let’s get started!”

In this version of “wilderness,” trees and plants must be sprayed with herbicide and a new landscape planted.  The result—if it is successful—will be an entirely artificial landscape.  There will be nothing “REAL” about it.

 Language is an obstacle to agreement

 One of many obstacles to reaching agreement with native plant advocates about the future of our public lands and open spaces is that we don’t share a vocabulary.  “Wilderness” is one of many words that cannot be defined by our mutual understanding.

“Sustainability” is another word that is used by native plant advocates, which we believe is inappropriately applied to the projects they demand because it is inconsistent with the realities of climate change and evolution.   The landscapes they are creating are no longer adapted to current environmental conditions.  They are not sustainable.

 “Integrity” has recently become a favorite buzzword of nativists, used to describe their idealized landscape.  We have absolutely no idea what that word means in the context of the contrived landscapes they attempt to create.

And so the debate continues with no end in sight.  Meanwhile our public lands are being destroyed in response to the demands of native plant advocates.  For us the word “wilderness” is now synonymous with “destruction,” which creates a fortress in which humans are not welcome.


(1) Mark Dowie, “The tortured semantics of wilderness,” Point Reyes Light, September 4, 2014

The unintended consequences of micromanaging nature

We must tell our readers about the collateral damage of misguided attempts to manage nature more often than we would like.  We prefer positive stories, but in the hope of a better future we must also inform the public of the unintended consequences of the many projects that are killing one species of plant or animal based on the mistaken assumption that another plant or animal will benefit. 

Trumpeter swan by James Audubon
Trumpeter swan by James Audubon

In this case, a project sponsored by the Nature Conservancy decimated the population of rare Arctic grayling fish in Centennial Valley, Montana, by damming the streams to create ponds for the benefit of the equally rare trumpeter swan.  The grayling had spawned in those streams and the population plummeted when the streams were dammed. 

The Nature Conservancy scientist who was interviewed by National Public Radio for this story said, “There are lots of examples where we try something that sounds like a good idea [and it] turns out not to be that good of an idea.  Then [we] remedy it and—hopefully—never try it again.”    

Unfortunately, they ARE trying it again.  Now the scientists are trying to compensate for the damage to the grayling population by killing cutthroat trout that is considered a predator to the grayling.  The cutthroat is not native, so that also makes it a candidate for eradication.  It’s as though we are on a killing treadmill.  One mistake seems to lead to another. 

Stop and think before you shoot!

Cockatoo.  Creative Commons
Cockatoo. Creative Commons

A bird lover in Hawaii takes a more thoughtful approach to the suggestion that introduced cockatoos and African parrots should be shot, based on the assumption that they are competing with the dwindling population of native birds.  He points out that the native birds nest in the ground, while the cockatoos and parrots nest in cavities in the trees.  Most of the native birds are nectar eaters, while the cockatoos and parrots eat seeds and nuts.  So, he wonders if the introduced birds are really a threat to the native birds.

The exotic birds are either escaped pets or the descendents of them.  The author of the article urges pet owners to take care of their pets and make a permanent commitment to their care.  Releasing them into the forest is making them a target for people who think killing them would benefit other birds. 

The author is not opposed to killing non-native animals when absolutely necessary, but he is at least willing to carefully consider if it is necessary, in his opinion.   He is comfortable with the killing of rats, pigs, and feral cats, for example.

Million Trees takes this question a step further.  We don’t think humans should micromanage nature.  We don’t have enough information to presume to know better than nature what is best.  We also have our own anthropomorphic criteria for which species is more important than another.  Our judgment is self-serving and is not a substitute for the even-hand of nature.   Nature follows the simple rule of “survival of the fittest.”  Nature is as likely to save the lowly spider as it is to save the beautiful trumpeter swan.

A parable to illustrate the point

This parable, retold in Fanaticism of the Apocalypse (1) illustrates the futility of man’s attempt to control nature:

“Noah, as he is loading the animals onto the Ark, is alarmed by the large number of candidates.  Mammals, birds, marsupials, penguins, primates, and lizards have already gone on board.  The ass, the ox, the giraffe, the elk, the stag, the lion, and the cat urge the patriarch to raise the gangplank and close the hatches.  The boat is chock-full, the cedar hull is about to crack open, the Deluge is threatening.  Outside, a crowd of harmful or misshapen pests—cockroaches, toads, slugs, spiders—asks to be taken on.  The toad speaks on behalf of his unsightly comrades:  he pleads their cause with eloquence, pointing out to the Patriarch that they perform a useful function in nature.  In God’s design, nothing is ugly or repugnant:  everything is ingenious, even invertebrates, mollusks are necessary.  No one has the right to destroy these creatures of the Lord.  But Noah turns on his heel and decides to raise the anchor.  Then a cloud of insects and pests assails him:  fleas climb on his legs, crabs crawl in his pubic hair, lice swarm on his head, leeches, stinkbugs, and mosquitoes stick to his skin without him noticing them.  Snakes slip into his flowing hair, spiders take up residence in his beard.  That is how the whole bestiary was spared.”

We fiddle with nature at our own peril. 


(1)    Pascal Bruckner, The Fanaticism of the Apocalypse, Polity, May 2013

Forests respond to climate change

This is a story that passes for good news at a time of global warming. A new study based on data from 21 broadleaf forests in northern latitudes over a 20 year period reports that forests in some places seem to be capable of achieving normal rates of growth while using less water. For the moment, the assumption is that increased levels of carbon dioxide are essentially acting as a fertilizer, promoting growth with less water. This suggests that at least in some locations, it might be possible for forests to survive through the droughts caused by climate change.

Broadleaf forest.  Blue Ridge Parkway
Broadleaf forest. Blue Ridge Parkway

Like most changes in the environment, there are pros and cons to forests using less water because forests recycle the water into the atmosphere where it becomes rain clouds. If the forests take up less water, they will probably supply less moisture to agricultural areas downwind of the forests.

Where forests exist on the perimeters of their climatic ranges, they are not faring as well. In the American West, for example, there are massive tree die-offs caused by less rainfall and snow as well as beetle infestations where temperatures are no longer cold enough to kill them in the winter.

Scientists had predicted some growth benefit from higher levels of carbon dioxide, but this study found the benefit to be far greater than previously predicted. Higher growth rates also predict that forests will be capable of absorbing more carbon dioxide because carbon storage is mainly proportionate to biomass.

Trees absorb carbon dioxide through the pores in their leaves, called stomata. Scientists hypothesize that trees don’t need to open their pores as wide when carbon dioxide levels are higher. Since moisture is lost when the pores open, less moisture is lost if the pores don’t open as wide. That’s the working theory of this new research.

Harvard Arboretum
Harvard Arboretum

The forest at the Harvard arboretum was one of the forests included in this study. It has the longest continuous record of forest growth in the world.

Many questions remain. Which species are becoming more efficient in their water use? Are there intervening factors that are reducing water use? Will this trade-off between water use and carbon dioxide levels have an upper limit?

“Some Trees Use Less Water Amid Rising Carbon Dioxide, Paper Says,” New York Times, 7/11/13

“Trees Use Water More Efficiently as Atmospheric Carbon Dioxide Rises,” Science Digest, 7/10/13