Embers start spot fires: The real and the imagined stories

Bay Nature recently published an article about the 1991 fire in the East Bay Hills and the closely related belief that such a fire can be prevented in the future by destroying all non-native trees.  To Bay Nature’s credit, it was a more balanced article than most.  Although the article was heavily weighted in favor of those who want to destroy all non-native trees in the hills, several defenders of our urban forest were also interviewed.

However, the article contains a fantasy about future fires that feeds into the fear of fire that has been fostered by those who advocate for removing all non-native trees:

“A strong wind begins blowing over the hills from the east. And then somehow—maybe a spark from a car, maybe a tossed cigarette—the whole dry, airy mess catches fire.  Now the flames on the ground are 30 feet high and even higher off the boughs, roaring like a jet engine. At the fire’s edges, trees appear to explode as the volatile oils in their leaves reach their boiling point and vaporize. The heat of the fire forms a convection column, with 60-mile-per-hour winds that rip burning strips of bark from the trees and toss them upward. This is another of blue gums’ talents—its bark makes ideal braziers. Tucked away inside a rolled-up strip of bark, a fire might live for close to an hour and fly 20 miles.” (1)

Although we have read many times in the plans to destroy trees that eucalyptus casts embers starting spot fires, we have never seen such an extreme description of how far embers could travel while still on fire and capable of starting a spot fire.  So, we tracked down the source of this theoretical scenario with the help of the author who cited this as the source of the theoretical scenario:  “The potential for an internally convoluted cylinder of bark to be transported tens of kilometres in a continuously flaming state is indicated by the sample that maintained flaming combustion for the entire experiment…This would correspond to a flameout time of almost 2000 s for a sample 2700 mm long, a lofted height of 9600 m and a spotting distance of ~37 km.” (2)

First let’s translate that quote into measurements we commonly use to appreciate how extreme this particular test was:  “This would correspond to a flameout time of almost 33 minutes for a sample 9 feet long, a lofted height of 6 miles and a spotting distance of 23 miles, traveling at 41 miles per hour.”  That is a very long ember, lofted a great distance at a great speed (but NOT 60 mph), staying lit for a long time (but NOT “close to an hour”).  

Theory vs. Reality

The study that was the source of the extreme prediction in Bay Nature about the distance that burning embers can travel was conducted on samples of Eucalyptus viminalis bark (NOT Blue Gum Eucalyptus, E. globulus) “tethered in a vertical wind tunnel.”  These are not real-world conditions.  So, how does this theoretical study compare to real-world conditions?

The FEMA Technical Report about the 1991 fire in the East Bay Hills contains a map of the full extent of the 1991 fire.  As you can see on this map, the maximum distance from the northern-most edge of the fire to the southern edge of the fire is less than 3 miles…not remotely close to 20 miles.  In other words, embers could not have started fires 20 miles away because the fire wasn’t even close to 20 miles long.

1991-fire-map-2

The FEMA Technical Report doesn’t tell us what the wind speeds were during the 1991 fire, although they describe the wind as being strong at several times during the fire.  If there is any evidence that winds were as much as 60 miles per hour, it’s not evidence we have been able to find.  We found a source of wind speeds measured on the Bay Bridge, including historical records.  This website says the strongest wind measured since 2010 was 31 miles per hour in April 2013.  That suggests that 60 mph winds are probably unusual in the San Francisco Bay Area.

The FEMA Technical Report doesn’t report any observations of firebrands or burning embers from eucalyptus.  The report mentions embers twelve times, but identifies the source of those embers only once.  In that one case, the source of embers was “a growth of brush”….not a eucalyptus tree or any tree, for that matter.  There are anecdotal reports of finding debris from the fire as  far as San Francisco, but no reports that the debris was still on fire or that it started another fire.

US Forest Service study of embers in actual fires

US Forest Service participated in a comprehensive study of “spotting ignition by lofted firebrands” based on actual wildfires all over the world, including the 1991 fire in the East Bay Hills. (3)  There is nothing in that study that corroborates the claim that eucalyptus bark embers are capable of travelling 20 miles while remaining lit and therefore capable of starting spot fires:

  • “In the wildland-urban interface fires in California—Berkeley in 1923, Bel-Air in 1961, Oakland 1991—wooden shingles which were popular in California as roof material, assisted fire spread. Wooden shingles increase fire hazard owing to both ease of ignition and subsequent firebrand production.
  • “Unlike the flying brush brands which are often consumed before rising to great heights, the flat wood roofing materials soared to higher altitudes carried by strong vertical drafts…”
  • The only firebrand found in the 1991 Oakland Hills fire was found approximately 1 km (.6 mile) west from the perimeter of the fire. It was a cedar shingle.  Here is a photograph of that shingle:  ember-1991-fire-2
  • Cylinder shaped embers do not travel as far as flat particles. Firebrands in the shape of cylinders were found to have a maximum spotting distance of 2050 meters, because “cylinders always fall tumbling.”
  • “The increased burning time inherent in larger firebrands was cancelled out by an increased time of flight because larger firebrands move more slowly.”
  • In a study of 245 extinguished fires, experiments and simulations, and observing 48 wildfires, “The longest spotting distance was observed as 2.4 km.”

This comprehensive study of actual wildfires all over the world finds no evidence of embers capable of travelling 20 miles while still burning and starting spot fires.  It reports that wooden shingles were the only observed burning embers in the 1991 fire and that wooden shingles are particularly vulnerable to being lofted as embers in a wildfire.  There are countless houses in the East Bay Hills covered in wooden shingles, yet instead of addressing that obvious source of embers, we are destroying blameless trees.

Developing the Cover Story

Claims about the extreme flammability of eucalyptus have escalated in the past 15 years as opposition to destroying trees and associated pesticide use has escalated.  Nativists have become increasingly dependent on flogging the fear factor as their other storylines have been dismantled by empirical studies and reality:

  • Monarch butterflies roosting in eucalyptus tree.
    Monarch butterflies roosting in eucalyptus tree.

    The “invasiveness” of eucalyptus has been downgraded by the California Invasive Plant Council from “moderate” to “limited,” their lowest rating. There is little evidence that eucalyptus is invasive unless planted along streams and swales that carry their seeds.

  • There are many empirical studies that find that all forms of wildlife—such as insects and birds—are served equally well by both native and non-native plants. Some iconic species—such as Monarch butterflies, bees, hummingbirds, hawks, owls—are dependent upon eucalyptus for winter nectar and safe nesting habitat.
  • Huge global studies of biodiversity report that the introduction of non-native species has resulted in no net loss of biodiversity. This is particularly true of introduced plants.  There is not a single instance of extinction caused by a non-native plant in the continental United States.
  • Climate change is making nativism increasingly irrelevant. California’s native conifers, oaks, and redwoods are dying by the millions.  Unless we want a treeless landscape, we must plant tree species that are capable of tolerating changed climate conditions.

    Owl nesting in eucalyptus, courtesy urbanwildness.com
    Owl nesting in eucalyptus, courtesy urbanwildness.com

These studies have left nativists with few tools to justify the eradication of non-native plants.  We can see the development of the FIRE!! cover story in the archives of the conferences of the California Invasive Plant Council.  In 2004 Cal-IPC held a workshop regarding exotic trees and shrubs.  Over 30 representatives of major managers of public lands attended, such as National Park Service, San Francisco’s Natural Areas Program, Marin County Open Space, etc.  The record of this meeting reflects the dependence upon fire to justify the eradication of non-native shrubs and trees:  “Golden Gate National Recreation Area:  ‘inform public ahead of time; use threat of fire danger to help build support for invasive plant removal projects.’”  The Golden Gate National Recreation Area—a National Park–advises other land managers to frighten the public into accepting the loss of their trees. 

Subterfuge is also recommended to land managers to hide the eradication of shrubs and trees from the public:  “To avoid public upset, drilling around into tree buttress roots and injecting 25% glyphosate…Trees die slow and branches fall slowly, so won’t pose an immediate hazard.”  In other words, land managers were advised to kill trees using a method that won’t be visible to the public. 

Perhaps most disturbing of all is that those who attended this workshop admit that they don’t really know if eucalyptus trees are more flammable than native vegetation and some doubt that they are:  “People are afraid of fire.  Help them understand Eucalyptus trees and other invasive plants are very fire hazardous.  Is there any solid research about Eucalyptus and fire?  Are Eucalyptus and brooms any greater fire danger than native chaparral?”  In other words, even those who wish to destroy non-native shrubs and trees seem to understand that fire is a cover story for which no supporting evidence exists. The evidence has been fabricated to support the cover story.

We now seem to live in a fact-free world in which various interests can make things up and distribute them on the internet with impunity.  The mainstream press is dying and is being replaced by fact-free social media.  If we are to protect ourselves from such manipulation, we must drill down into these storylines.  In the case of eucalyptus, we have debunked the myth that it is more dangerous than the replacement landscape.  Now it’s up to us to disseminate that information far and wide as an antidote to fear-driven nativism. 


  1. Zach St George, “Burning Question in the East Bay Hills: Eucalyptus is flammable compared to what? Bay Nature, October-December 2016
  2. James Hall, et. al., “Long-distance spotting potential of bark strips of a ribbon gum (Eucalyptus viminalis), International Journal of Wildland Fire, 2015, 24, 1109-1117
  3. Eunmo Koo, et. al., “Firebrands and spotting ignition in large-scale fires,” International Journal of Wildland Fire, 2010, 19, 818-843

FEMA funding for East Bay tree destruction is cancelled!

We republish with permission a Huffington Post article by Jennifer and Nathan Winograd about the cancellation of FEMA funding for the destruction of hundreds of thousands of trees on the properties of UC Berkeley and the City of Oakland.  We are grateful to the Winograds and to the thousands of people who participated in the effort to prevent these projects from being implemented, including the Hills Conservation Network, which bravely filed the expensive lawsuit that resulted in this outcome.

It remains to be seen if the City of Oakland and UC Berkeley will implement their plans using other fund sources.  We therefore urge our readers to continue to follow the issue until we have some assurance that the plans have been abandoned.

The Winograds have also provided the following introduction to their Huffington Post article, which explains that this outcome could have been avoided if those who demanded the destruction of our urban forest had been willing to engage in a meaningful dialogue about the projects.

“Many of us tried to engage in meaningful dialog with Bay Area politicians and land managers about our objections to the clear cutting and poisoning of the hills. We were rebuffed. Some, like Mayor Libby Schaaf, did not even extend the courtesy of a reply. Others, like Dan Kalb, Oakland City Councilmember, calls anyone who disagrees with him “stupid.” We tried to engage the media — local newspapers, television and radio, magazines — and with few exceptions, our objections were largely ignored. When we were mentioned, we were ridiculed. Refusing to give us a fair hearing, the Contra Costa Times and San Francisco Chronicle claimed we were indifferent to public safety. Regardless of how many experts — including the U.S. Forest Service, the EPA, and former firefighters — substantiated our concerns, they remained defiant, insisting that even more forests should be clear cut and more poisons be spread. With local politicians, the media, and proponents refusing to engage in reasonable dialog, this left opponents no choice but to force the discussion in a court of law. That lawsuit, filed by Hills Conservation Network, ultimately prevailed with FEMA, which withdrew millions of dollars in funding to the City of Oakland and UC Berkeley. That’s a good thing and here’s why:”


FEMA Pulls Funding for Oakland, Berkeley Clear Cutting

Eucalyptus forest, Lake Chabot
Eucalyptus forest, Lake Chabot

The City of Oakland just lost millions of dollars in federal funding. Given what the intended use of that money was for, that’s a good thing. Combined with similar funding for UC Berkeley and the East Bay Regional Parks District (EBRPD), over 400,000 trees across seven Bay Area cities were to be chopped down and thousands of gallons of cancer-causing herbicides spread on their stumps to prevent regrowth. Slated for eradication were the vast forests above the Caldecott Tunnel and Caldecott Field, North Hills Skyline, Strawberry and Claremont Canyons in Berkeley, and 11 regional parks including Sibley, Huckleberry, and Redwood in Oakland. Costing nearly $6 million, the plan would have radically transformed the character and appearance of the Oakland hills. Why?

The Scripps Ranch Fire of 2003 burned 150 homes but none of the Eucalyptus abutting those homes.
The Scripps Ranch Fire of 2003 burned 150 homes but none of the Eucalyptus abutting those homes.

If you believe proponents, it is because the trees pose a heightened risk of fire. Since the infamous Firestorm of 1991 which burned scores of homes and killed 25 people, they have worked tirelessly to turn public opinion in the East Bay against Eucalyptus and Monterey Pine trees. Chief among their claims is that these trees were to blame for the ferocity of that fire because they are alleged to possess unusually high quantities of volatile oils that make them more flammable and prone to shooting off embers which enable the spread of fire. These claims have been repeated so many times they are often regarded as self-evident, even though the evidence does not support them, nor does the history relating to the ignition and spread of past fires. Indeed, the 1991 fire itself (and a later 2008 fire) started in grasses, the very sort of vegetation that clearcutting is intended to proliferate throughout the hills. In fact, the stated aim of the deforestation effort is to replace Oakland forests containing species of trees that are among some of the tallest in the world with shallow grasses that are highly susceptible to fire and which the EBRPD admits are “one of the most dangerous vegetation types for firefighter safety due to the rapid frontal spread of fire that can catch suppression personnel off guard.”

In a report highlighting the heightened fire risk which would have resulted from this plan, David Maloney, former Chief of Fire Prevention at the Oakland Army Base, criticized the spread of misinformation about these trees as motivated by native plant ideology, calling it “a land transformation plan disguised as a wildfire hazard mitigation plan” that will “endanger firefighters and the general public” and “be an outrageous waste of taxpayer money.” And he’s not alone in his concerns.

The U.S. Forest Service objected, saying it would “increase the probability of [fire] ignition over current conditions” because “removal of the overstory trees can introduce changes to the environment which increase fire behavior in undesirable ways.”

The U.S. Fire Administration Technical Report on the 1991 Fire led to the conclusion that removal of the trees would lead to growth of highly flammable brush species, noting that “brush fuel types played a significant role in the progression of the fire” and that brushland made up “a large portion of the available fuel.”

The Environmental Protection Agency stated that it is predicated on “extensive use of herbicides” and “risks posed to human health and the environment from that use.” It went on to express concern about the “potential impacts of climate change,” including “the length and severity of the fire season.”

FEMA itself admitted that the plan would result in “unavoidable adverse impacts … to vegetation, wildlife and habitats, protected species, soils, water quality, aesthetics, community character, human health and safety, recreation, and noise.”

During the summer, 5,200 California firefighters battled 14 fires across the state. The vast majority of the fires were in grass and brush, with a few in so-called “native” Oak woodlands.
During the summer, 5,200 California firefighters battled 14 fires across the state. The vast majority of the fires were in grass and brush, with a few in so-called “native” Oak woodlands.

But you would not know any of this by reading Bay Area newspapers, watching Bay Area television news programs, listening to local radio stations, reading local magazines, or hearing Bay Area politicians. These are discussions those who oppose this plan tried to engage in with the Mayor, the Oakland City Council, the media and even plan supporters in order to find a compromise, but were rebuffed. Instead, the “need” for deforestation and herbicide use was deemed “self-evident” and opponents were labeled as indifferent to public safety who debased the memory of those who died in the 1991 Firestorm.

In the absence of public discussion about the expertly substantiated criticism that the plan would have increased rather than reduced fire risk, exposed citizens to huge amounts of dangerous chemicals, released over 17,000 metric tons of greenhouse gases into our environment, poisoned and displaced wildlife, radically altered the appearance of our parks, threatened homeowners values by degrading the aesthetics upon which those values depended, eliminated erosion control for hillside homes, and caused a variety of other harms, the public was denied information that would have allowed them to make a sound and informed choice. This troubling bias does not honor the memory of those who died in that tragic fire 25 years ago; it shames it. Their loss should have served to embolden our resolve to prevent a recurrence of their tragedy through rigorous public debate, rather than hobbled us with emotionally charged rhetoric that stifled discussion before it was allowed to begin and threatened to turn the response to that fire into the root cause of yet another disaster.

For while opponents sought to elevate the discussion on this plan to prevent a future tragedy, local media, politicians, and supporters proved themselves incapable of moving beyond a narrative that was so sensationalist and even after more than two decades, so raw, that the abandonment of caution, reason, and critical analysis were paradoxically and counterproductively portrayed as the moral high ground. It left opponents no choice but to force the discussion in a court of law, a point of view that ultimately prevailed with FEMA. Whether the Mayor, City Council, deforestation advocates, and Bay Area media outlets learn from their failings going forward remains to be seen. But one thing is abundantly clear. If the result of the lawsuit proves anything, it proves opponents of deforestation and poisoning were right.

Another attack on our urban forest by a public land manager

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.

Lafayette Reservoir, one of many EBMUD properties in the East Bay
Lafayette Reservoir, one of many EBMUD properties in the East Bay

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 HEREEBMUD is accepting written public comments on the draft Master Plan until September 2 extended to Friday, September 16, 2106.   Comments should be sent to watershedmasterplan@ebmud.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. 

If you are watching the news, you know that there are now eight wildfires raging in California.  All of these wildfires are occurring in native vegetation.  The claim that non-native trees are more flammable than native trees and vegetation is nativist propaganda. 

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.

Sign the petition!
Sign the petition!

saveeastbayhills

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.

Very truly yours,
Save the East Bay Hills

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.” http://www.nps.gov/pore/learn/management/upload/firemanagement_fireeducation_newsletter_eucalyptus.pdf
  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
  7. https://www.revealnews.org/article/rampant-california-wildfires-can-be-blamed-on-last-decembers-rain/?utm_source=Reveal%20Newsletters&utm_campaign=2d4c52ebf5-The_Weekly_Reveal_09_24_159_23_2015&utm_medium=email&utm_term=0_c38de7c444-2d4c52ebf5-229876797
  8. Jon Keeley, Fire in Mediterranean Ecosystems, Cambridge University Press, 2012
  9. https://milliontrees.me/2011/02/04/biodiversity-another-myth-busted-2/
  10. https://milliontrees.me/2013/04/09/biodiversity-of-the-eucalyptus-forest/
  11. https://milliontrees.me/2013/11/22/invertebrates-such-as-insects-are-plentiful-in-the-eucalyptus-forest/
  12. See Table 2.1 in Appendix F: http://www.fema.gov/media-library-data/1416861356241-0d76d1d9da1fa83521e82acf903ec866/Final%20EIS%20Appendices%20A-F_508.pdf
  13. William Russell and Joe McBride, “Vegetation Change and Fire Hazard in the San Francisco Bay Area Open Spaces,” Landscape and Urban Planning, 2003

A retired university planner critiques the FEMA projects in the East Bay Hills

We recently finished reading all of the 13,000 public comments on the FEMA draft EIS.  FEMA says that about 90% of the comments are opposed to the project and having read the comments that seems about right. 

It was a very rewarding experience to read the comments and we recommend it to anyone who is discouraged or doubtful that we can prevent the destruction of our urban forest in the East Bay (available HERE).

There were many excellent comments, many from people with specific expertise and knowledge of the issues that inform our opposition to these projects.  We plan to publish a few of them, as we obtain permission from their authors.  Today, we publish the public comment of Christopher Adams, with his permission.  We hope you are as impressed with his astute analysis as we are.


 

 Comments on Hazardous Fire Risk Reduction, East Bay Hills, CA,

Draft EIS

Prepared by Christopher Adams

Introduction:

My comments here are made solely in my capacity as a private citizen, but I think it is germane to state my background. I am a retired university planner, and for several years I directed the office which was responsible for review of every environmental document prepared by all the campuses and other facilities of the University of California. In addition, I was directly involved with the drafting, the public hearings, and the response to comments and preparation of two major Environmental Impact Reports, prepared under the California Environmental Quality Act for a UC campus. I also live near the EB Hills in an area subject to wild fires and share the concerns of others about the risk of fire.

Summary:

The Hazardous Fire Risk Reduction, East Bay Hills, CA, Draft EIS is a deficient document, beginning with its basic premise. While purportedly for the purposes of fire management, the proposed actions appear to be mostly motivated by a dream of a restoring the EB Hills to some imagined Eden prior to the European and American colonization of California. Instead of applying scientific and policy analysis to the impacts of the proposed actions the DEIS authors appear to have decided that the proposed clear cutting and herbicide measures are the right ones for fire protection and then cherry‐picked evidence, whether in the description of existing conditions or the possible alternatives solutions, which supports this conclusion. The DEIS rejects out of hand fire management alternatives that do not involve clear cutting and massive application of herbicides. In so doing the DEIS is a classic example of post hoc rationalization. Unless the DEIS is re‐issued with corrections and additions responding to the comments below, I believe that FEMA is seriously exposed to potential litigation. More significantly, if FEMA does not consider other less draconian and less expensive fire management measures, it will not be serving the interests of the citizens most impacted by fire danger, not to mention the taxpayers who will ultimately foot the bill.

Specific Comments:

The DEIS fails to note the existence of native trees which are specifically susceptible to the effects of one of the herbicides proposed for use. Section 4.2.2.2.1 notes that the native trees in the woodlands include madrone (Arbutus menziesii). However, in Section 3.4.2.1.1 Strawberry Canyon‐PDM there is no mention of madrones in the list of trees in the “native forest” (first paragraph of section). This is a significant omission, because there are madrones in Strawberry  Canyon, yet in the third paragraph of this same section one of the two herbicides proposed for use to stifle stump regeneration is Stalker (imazapyr) which has been identified elsewhere as being used specifically to eliminate madrones. According to the EPA Reregistration Eligibility Decision for Imazapyr: “Imazapyr use at the labeled rates on non‐crop areas when applied as a spray or as a granular to forestry areas present risks to non‐target plants located adjacent to treated areas.” (1)

The DEIS fails to acknowledge the growing threat of French broom in the UCB area.

While the presence of eucalyptus, Monterey pine, and acacia is repeatedly discussed, there is almost no mention of the rapid invasion of French broom. It is mentioned only in passing and without its scientific name in the discussion in Section 4.2.2.2.3 under “Northern Coastal Scrub.” While French broom has been rapidly increasing in the upper slopes of the Strawberry Canyon PDM and Claremont PDM areas, there is no mention of it at these locations in the DEIS. This plant is an active pyrophyte which chokes out native vegetation, can be poisonous to livestock, and is of limited benefit to native animals. The increase in sunlight from the proposed removal of large amounts of eucalyptus will encourage its spread. There is no mention of the fire risk from French broom in the discussion of fire risk in Northern Coastal Scrub, Section 4.3.3.2.5, and I could find no mention of its removal anywhere in the document.

The UCB project description does not explain if a fuel break is planned in the UCB areas and if so to describe it.

Section 1.1.1 UCB states that it will follow the “same general approach…which is included in Oakland’s grant application (see Section 1.1.2 below).” In Section 1.1.2 it is stated there the Oakland PDM would “create a fuel break on the west side of Grizzly Peak Boulevard north and east of the Caldecott Tunnel [presumably this means the west entrance to the tunnel].” UCB Strawberry Canyon properties also abut Grizzly Peak Boulevard, so the statement of “the same general approach” implies that UCB also proposes a “fuel break,” but none is described. Since the term “fuel break” implies clearing to the bare soil, with potential significant environmental impacts, this is a serious omission.

The DEIS fails to consider the impact on global climate change by the wholesale destruction of trees. The DEIS states that for UCB Strawberry Canyon alone 12,000 trees will be destroyed. Because trees absorb CO2 at an average rate of 13 pounds per year, this represents a potential loss in CO2 absorption of 78 tons per year. Given the growth patterns of native trees in Berkeley, which tend to be riparian or to grow on north facing slopes in a widely scattered pattern, the number of replacement trees will not come close to compensating for those destroyed. The difference should be estimated and calculated.

The DEIS fails to consider an actual and accomplished fuel management program when dismissing the alternative described in Section 3.3.1.1.

The Lawrence Berkeley National Laboratory (LBNL) is located on 175 acres on the north side of Strawberry Canyon immediately adjacent to the UCB and EBRPD areas described in the DEIS. LBNL, which is managed by the University of California, employs more than 4,000 persons on this site in laboratory buildings and with equipment that is worth several billion dollars. LBNL has recently completed a fire management program which is essentially what is described in Section 3.3.1.1 of the DEIS, Removal of Brush, Surface Fuels, Lower Limbs and Small Trees. The entire project was completed within the LBNL maintenance budget without special grants and has given the laboratory a great deal of fire security, according to its professional fire personnel. Yet there is no reference to this in the DEIS. The LBNL program is further described in the following links. This first links to a powerpoint slides; the second to a video discussion of the slides. http://www.lbnl‐cag.org/docManager/1000000159/Berkeley%20Lab%20Fire%20Safe%20Vegetati on%2C%20Lab%20Fire%20Marshal.pdf

http://www.lbnl‐cag.org/Content/10024/preview.html

The links convey much more effectively than my comments how an alternative to massive clear cutting and massive application of herbicides will effectively accomplish the goal of managing fire in the East Bay Hills.

The DEIS is incomplete and verging on the dishonest about the use of herbicides.

“Management of resprouts without herbicides is expensive….and thus was removed from further study.” This ignores the management of resprouts used successfully by LBNL as described in the above referenced powerpoint and video. There is no study about the use of herbicides at the scale proposed, e.g. 12,000 trees in Strawberry Canyon alone, on human populations, let alone native plants and animals.

The DEIS fails completely to discuss the realities of encouraging native plants after the clear cutting and heavy and repeated application of herbicides.

1) Restoration ecology is barely in its infancy, yet this DEIS expects us to accept on faith alone that when the clear cutting is done and the slopes sprayed with herbicides the native vegetation will miraculously reappear.

2) At the present time live oaks and bays are common on the north side (south facing side) of Strawberry Canyon under eucalyptus. This is probably because the fog drip from the eucalyptus and the shade encourage their growth in what would otherwise be a very dry area. Compare, for example, on slopes of similar aspect in portions of the EB Hills behind El Cerrito or Fremont. There is nothing in the DEIS to explain how native trees will increase or survive after the clear cutting has destroyed their source of water and shade.

3) Because of the abundance of deer in Strawberry Canyon and adjacent areas, small trees need to be protected against browsing. (See the LBNL powerpoint for an illustration of wire protective cages. http://www.lbnl‐ cag.org/docManager/1000000159/Berkeley%20Lab%20Fire%20Safe%20Vegetati on%2C%20Lab%20Fire%20Marshal.pdf) The DEIS says nothing about preventing deer browsing.

4) California native oaks of several species, including Quercus agrifolia are subject to the fungal disease Sudden Oak Death Syndrome (SODS), which has been found in the East Bay Hills. The DEIS fails to discuss the existence of SODS or its impact on replacement vegetation after the clear cutting and application of herbicides.

5) The DEIS states that “alleopathic oils” in the leaves and bark of eucalyptus suppress the growth of other vegetation. Yet the DEIS fails to state how covering slopes two feet deep with eucalyptus slash will not inhibit growth of new “native” plants.

6) Native California bunch grasses have largely been supplanted by European annual grasses, many of which form mats which choke out other plants. Similarly native shrubs such as coyote bush (Baccharis species) are being supplanted by invasive plants such as broom. The DEIS fails to explain how native plants will succeed in competition for sun and water with these plants.

The DEIS fails to consider the aesthetic impact to views from the trails and roads within the canyon and from houses near it after the clear cutting.

Section 4.12.2 of the DEIS states that a goal of the UCB LRDP (2005) is to “Maintain the visual primacy of the natural landscape in the hill campus” but there is no mention of the impact of clear cutting on this natural landscape. The north side of the lower portion of Strawberry Canyon forms the main campus of Lawrence Berkeley National Laboratory (LBNL). While individual buildings at LBNL are attractive in design, the overall effect of the site is essentially industrial, similar to an office park one might see along a freeway. The views of LBNL from the fire road that winds through the canyon are now largely screened by the large trees which will be destroyed by clear cutting. The trees also offer cooling shade to those using the area for recreation. The fire road is a major recreation amenity for UCB students, employees, and neighbors, used daily by hundreds of hikers, joggers, dog walkers, and mountain bikers. Removal of most of the trees as proposed will completely change the views enjoyed from the fire road. The DEIR provides absolutely no analysis of this impact either verbally or by providing illustrations of any viewing point in Strawberry Canyon. Most of the discussion of Section 5.8 is oriented to views over the hills from high points to the bay, which indeed may be improved by clear cutting. There is no discussion of views from within the areas to be clear cut and no reference to Strawberry Canyon.

The DEIS bases its list of plant species slated for destruction on incomplete and inaccurate botanical and fire danger information.

The authors of the DEIS seem not to understand the difference between “native” and “endemic” and they seem to have arbitrarily selected some “native” plants to extirpate while keeping others based on criteria having little or no relationship to fire hazards. Section 3.4.2.1.1 states that “Non native trees, including all eucalyptus, Monterey pine, and acacia would be cut down.” The Jepson Manual  (2), which is the definitive source for California plants divides the state into geographic areas. According to Jepson Monterey pines (Pinus radiata) are native to California, and while not endemic to the EB Hills, they are native in the geographic area CCo, which includes both portions of Monterey County and the EB Hills with similar climatic conditions. Coast redwoods (Sequoia sempervirens) are also found in Strawberry Canyon but not as an endemic. They are also native to the geographic area (CCo). In contrast to Monterey pines, however, Coast Redwoods appear to escape destruction by clear cutting; at least there is no mention of such action in the DEIS. Another native and Strawberry Canyon endemic, California Bay (Umbellularia californica), is specifically listed in the DEIS to be retained. But in a publication of the University of California Cooperative Extension (3) it is listed as a “High Fire Hazard Native Tree.” Note that these comments are not meant to imply favoring destruction of redwoods or bay trees but to further illustrate the inaccurate information and the arbitrary nature of the DEIS conclusions. Similarly cypress species which grow in parts of Strawberry Canyon are also listed as pyrophites in this UC document, but the DEIS does not propose their extirpation.

The DEIS fails to consider the impact on Strawberry Creek of run‐off from the predicted massive amounts of slash, from the standpoint of hydrology and flood control or the impact on the biota of the creek.

Section 3.4.2.1 of the DEIS states within Strawberry Canyon there will be clear cutting on 56 acres and that the downed trees will be chipped and left on 20% of the site at a depth of 2 feet. Based on these numbers the cumulative amount of material on the ground will be 975,744 cubic feet (.2 x 56 x 43,560 x 2). If merely 1% of this material is washed away in a storm, which seems a very conservative estimate considering the slopes where the material would be placed, there could be more than 1,000 cubic yards of slash material washed into Strawberry Creek. The DEIS does not discuss the impact on the biota of the creek of this potential massive amount of new material. Nor does the DEIS discuss the impact of this material on stream flow in storm conditions. Given that the culverts in the lower levels of the creek, near the Haas Clubhouse and the University Botanic Garden, are only about 9.5 square feet in cross section (See Figure 1.), there is a strong likelihood that the slash material would block the culverts and cause flooding. Section 3.4.2.1 states that “if the site yields a large number of large tree trunks,” some “may” be removed or used for other purposes than left on the site; however, the DEIS fails to state the criteria for determining what the “large number” is that would trigger such action. The hydrologic and ecological impacts are presumably left to the loggers to evaluate.

FEMA comment - Adams 1 copy

Figure 1, Culvert on lower fire trail, near Botanic Garden

 

The DEIS implies that trees other than eucalyptus, Monterey pines, and acacias will not be cut, but current actions in Strawberry Canyon suggest that UCB will cut anything at any time regardless of environmental regulations. The DEIS must be amended and re‐issued to include other UCB actions as part of cumulative impacts.

During the past week (June 6‐13, 2013) I have personally observed the cutting of at least six healthy, mature California live oaks, bays, and cypresses in Strawberry Canyon. (See Figures 2 and 3.) The oaks were particularly magnificent, and their destruction is tragic. I am familiar with the needs for passage of fire trucks as I own woodland property on a narrow privately maintained road. None of the trees just cut would have prevented passage of trucks, but I was told by one of the tree cutters that the excuse was “Fireman.” To my knowledge this cutting was done without any compliance with the California Environmental Quality Act (CEQA), which is the state equivalent of NEPA and applies to all UCB actions. This cutting constitutes a violation of the CEQA Guidelines Section 15304, which states that exemptions from CEQA apply only to actions “which do not involve the removal of healthy, mature, scenic trees.” If UCB is flagrantly cutting trees now, while the DEIS is out for public comment, what can we expect once the NEPA process is completed?

FEMA comment - Adams 2 copy

Figure 2. Bay stump on lower fire trail, cut on or about June 11 2013, diameter +/‐42”

FEMA comment - Adams 3 copy

Figure 3. Live oak stump on lower fire trail, cut on June 10, 2013, diameter +/‐ 38”

(1) EPA 738‐R‐06‐007, 2006

(2) The Jepson Manual of Vascular Plants of California, 2nd Edition, UC Press, 2012

(3) Pyrophytic vs. Fire Resistant Plants, FireSafe Marin in Cooperation with University of California Cooperative Extension, October 1998


Thank you, Mr. Adams, for taking the time and trouble to write this excellent public comment on the FEMA draft EIS.

 

Hills Conservation Network files suit to stop FEMA grants in East Bay Hills

Ten years after UC Berkeley, City of Oakland, and East Bay Regional Park District applied for FEMA grants to fund the destruction of hundreds of thousands of non-native trees on 1,000 acres of public open space, FEMA announced its final decision on Thursday, March 5, 2015.  FEMA’s announcement of that final decision, which was sent to those who commented on the draft plans, implied that the projects had been revised to be less destructive.  In fact, those who take the time to read the final version of the plans will learn that the original plans are fundamentally unchanged in the final version.

East Bay Regional Park District (EBRPD) will destroy about 90% of the trees in its project area, as originally planned.  “Thinning” is not an accurate description of EBRPD’s project.  UC Berkeley (UCB) and City of Oakland will destroy 100% of all non-native trees on their project properties.  On a small portion of UCB and Oakland property (29 of 460 acres), tree removals will be phased over the 10-year project period.  In other words, the final version of these projects will destroy as many trees as originally proposed by the grant applicants.  However, FEMA has refused to fund tree removals on Frowning Ridge (185 acres) because UC Berkeley removed hundreds of trees there before the Environmental Impact Statement was complete, in violation of FEMA policy.

UC Berkeley destroyed hundreds of trees on Frowning Ridge in August 2014, before the Environmental Impact Statement was complete.
UC Berkeley destroyed hundreds of trees on Frowning Ridge in August 2014, before the Environmental Impact Statement was complete.

The Hills Conservation Network (HCN) filed suit to prevent the funding and implementation of these projects on March 6, 2015.  Below is the press release announcing HCN’s suit.  Please contact the Hills Conservation Network if you wish to contribute to the cost of this suit:    http://www.hillsconservationnetwork.org/HillsConservation3/Blog/Blog.html or email inquiries@hillsconservationnetwork.org


 

Hills Conservation Network

Preserving the East Bay Hills

March 6, 2015                                                                                                          

For Immediate Release

HCN announces lawsuit against FEMA EIS

Today the Hills Conservation Network, an Oakland, CA based environmental non-­‐profit, filed suit against the Federal Emergency Management Agency, also naming the Regents of the University of California, the City of Oakland, and East Bay Regional Park District in the suit.

The suit was filed in opposition to the Record of Decision released March 5, 2015 finalizing FEMA’s decision to award approximately $7.5 million in fire risk mitigation grants. The suit contends that the Environmental Impact Study used as part of the grant process was significantly flawed, and as such cannot be used to justify awarding these funds.

The lawsuit argues that FEMA did not consider a reasonable range of alternatives and reached unsupportable conclusions in deciding to allow the three agencies named in the suit to remove large numbers of healthy trees, with the goal of eradicating certain species of non-­‐native trees (acacia, Monterey pine, eucalyptus) by the end of ten years.  HCN proposed a more nuanced approach that would have resulted in higher levels of fire risk mitigation at a much lower cost and with far less environmental damage than the current plan that calls for the removal of well in excess of 100,000 healthy trees that provide shade canopy (preventing the growth of highly flammable weeds) as well as storing tons of carbon that contribute to the greenhouse gases warming our planet.

This step marks the latest chapter in this process that began in 2005. During the Draft EIS review in 2013 approximately 13,000 comment letters were received by FEMA, 90% of them opposed to the proposed projects. In response to this public outcry FEMA reworked the EIS, and while the Final EIS is somewhat less destructive than the Draft EIS, it essentially calls for the same level of environmental damage, but over a longer time period.

The Hills Conservation Network is an Oakland, California based 501c3 comprised of residents of the Oakland hills that were directly affected by the 1991 fire. Several members of the group lost their homes in this conflagration and have committed themselves to driving change in Oakland to ensure that similar events never happen again. Members of HCN have been involved in the Grand Jury investigation of the ’91 fire and in developing enhanced emergency response capabilities in Oakland.

Please direct inquiries to Dan Grassetti at 510-­‐849-­‐2601.

################

Final Environmental Impact Statement for FEMA projects in the East Bay is NOT an improvement!

On December 1, 2014, FEMA published the final Environmental Impact Statement (EIS) for the projects in the East Bay Hills which propose to destroy hundreds of thousands of non-native trees.  FEMA’s email announcement of the publication of the EIS implied that the projects had been revised.  Two of the agencies applying for FEMA grants—UC Berkeley and City of Oakland—had originally proposed to destroy all non-native trees on their properties.  The third agency –East Bay Regional Parks District—had proposed to thin non-native trees in most areas and destroy all in a few areas.  FEMA’s email announcement of the final EIS implied that both UC Berkeley and City of Oakland would be required to use the same “thinning” strategy as East Bay Regional Parks District.

After reading the final EIS, the Hills Conservation Network (HCN) is reporting that FEMA’s email announcement was rather misleading.  In fact, both UC Berkeley and City of Oakland will be allowed to destroy all non-native trees on their properties.  In a small sub-section (28.5 acres) of their total project acres (406.2 acres), UC Berkeley and City of Oakland are being asked by FEMA to destroy the trees more slowly than originally planned.  However, they will all be destroyed by the end of the 10 year project period.

HCN has analyzed the EIS and consulted legal counsel.  The following is HCN’s assessment of the EIS and their plans to respond to FEMA.  We publish HCN’s assessment with their permission.   Note that HCN is asking the public to send comments to FEMA and they are raising funds to prepare for a potential legal suit.


 “After having reviewed the Final EIS in depth and having consulted with various stakeholders, HCN has concluded that the Final EIS, in spite of FEMA’s efforts to improve it from the Draft version, remains unacceptable.

While FEMA has made some modifications to portions of the EIS in response to the enormous number of comments submitted last year [more than 13,000], the fact remains that if implemented in their current form, these projects would remove essentially all of the eucalyptus, pines, and acacias from the subject area. While for portions of the area FEMA is now proposing that there be a phased removal of these species, the fact remains that the objective is ultimately to convert the current moist and verdant  ecosystem into one dominated by grasses, shrubs, and some smaller trees. This will forever alter the character of these hills that so many of us have grown up with, know and love.

But worse than that, these projects would actually increase fire risk, destabilize hillsides, cause immense loss of habitat, release significant amounts of sequestered greenhouse gases, and require the use of extraordinary amounts of herbicides over a large area for at least a decade.

Additionally, by preemptively clearcutting 7 acres of Frowning Ridge in August of this year, UC not only made a clear violation of FEMA rules but also essentially negated the accuracy and relevance of the EIS. While FEMA acknowledges this in the EIS, they still want to move forward with a document that may no longer accurately reflect the reality of the current environment, the cumulative impacts of these projects, and any of the other factors that underpin the EIS process.

For these reasons, HCN will be submitting a comment letter to FEMA asking that the EIS be pulled back, reworked, and recirculated….at a minimum. Additionally, we are currently exploring legal options should the EIS be finally released on January 5, 2015 in its current form. One way or another, we are committed to ensuring that the will of a small number of influential people doesn’t result in the loss of a treasured resource to the vast majority of us (both human and other).

We ask your support in sending additional comment letters to FEMA [ebh-eis@fema.dhs.gov] and most importantly that you consider making a tax-deductible contribution to HCN. While we wish we did not have to do this, the fact is that the only way we can have a shot at preventing this irreparable harm from happening is by hiring lawyers, and that is what we will do. This takes money, so please do what you can either by sending a check to HCN at P.O. Box 5426, Berkeley, CA 94705 or by making a donation through our website at http://hillsconservationnetwork.org/HillsConservation3/Support_HCN.html.”

Thanks again for all your support,

Hills Conservation Network

FEMA has published the final Environmental Impact Statement for projects in the East Bay Hills

Readers of Million Trees will recall some of the most controversial projects in the San Francisco Bay Area which propose to destroy hundreds of thousands of trees in the East Bay Hills.  The owners of these properties—UC Berkeley, City of Oakland, and East Bay Regional Park District—applied for grants from the Federal Emergency Management Agency (FEMA) to fund these projects, based on the claim that fire hazards would be reduced  by the projects.  Detailed descriptions of the proposed projects as originally planned are available HERE

The public comment period on the Draft Environmental Impact Statement closed in June 2013.  FEMA has announced the publication of the final Environmental Impact Statement (EIS), which is available HERE FEMA now reports that it received more than 13,000 public comments and informs us that the final EIS reflects the concerns expressed in the public comments as well as the analysis of “subject matter experts.”  We haven’t read either the public comments or the final EIS yet, so we are only quoting excerpts directly from FEMA’s announcement so that you have this information as soon as possible.  If you read these documents, we welcome your reaction to them. 


Here are excerpts from FEMA’s announcement of the final EIS (emphasis added):

“One of the major revisions to the draft EIS influenced by information gathered during the public process is that FEMA will not fund the proposed methodology of eradicating designated tree species without a phased approach.  The originally proposed eradication methodology to completely and immediately remove the “overstory” was deemed not to satisfy the purpose and need for the grant of fire reduction, and therefore did not meet hazard mitigation program eligibility requirements.

Identifying and analyzing implementation options is another required element of the National Environmental Policy Act (NEPA) decision-making process that must be explored before federal funding can be awarded.  Based on input and issues raised during the public comment process, and in consultation with the grantee, sub applicants, and cooperating federal agencies, FEMA revised the vegetation management methodology for two of the three sub applicants – City of Oakland and UC Berkeley.  The revisions align the majority of proposed projects with a thinning alternative, the approach originally proposed by East Bay Regional Parks District as described in the Draft EIS.

The thinning approach has been scientifically validated by subject matter experts to effectively reduce fire risk.   The revised vegetation management methodology will result in fewer trees being removed in any single year in certain areas, with the same total fuel reduction accomplished by the conclusion of the project.  The EIS considers the overall impacts to the environment based on the amount of land treated and consequent impacts to resources.  Each grant applicant is responsible for their ongoing land management practices and determination for how much vegetation will be removed to accomplish their fire reduction goals within the scope of the vegetation management approach defined in the EIS.  Clear-cutting, a logging practice, is not part of the methodology considered in the EIS for any of the projects.


The final EIS and response to comments are available on the web at:   http://ebheis.cdmims.com/FinalDocuments.aspx

and will also be made available at http://www.fema.gov/environmental-historic-preservation-documents.

The public also may view hard copies of the EIS at the following locations:

  • Oakland Main Library, 125 14th Street Oakland, CA 94612
  • Oakland Rockridge Library, 5366 College Avenue Oakland, CA 94618
  • Berkeley Main Library, 2090 Kittredge Street Berkeley, CA 94704
  • San Leandro Main Library, 300 Estudillo Avenue San Leandro, CA 94577
  • Richmond Main Library, 325 Civic Center Plaza Richmond, CA 94804
  • FEMA Region IX Headquarters, 1111 Broadway, Suite 1200, Oakland, CA 94607-4052
  • East Bay Regional Park District, 2950 Peralta Oaks Court, Oakland, CA 94605-0381
  • City of Oakland, Office of the City Clerk, Oakland City Hall, 2nd Floor, 1 Frank H. Ogawa Plaza, Oakland, CA 94612
  • California Governor’s Office of Emergency Services, Hazard Mitigation Grant Program Unit 10390 Peter A. McCuen Blvd First Floor Sacramento, CA 95655

 

Escalating war on trees in the East Bay

The Federal Emergency Management Agency (FEMA) has been considering grant applications for “fire hazard mitigation” in the East Bay since 2005, when the first of these applications was submitted. After years of debate about whether or not the projects achieve the stated purpose and at what cost to the taxpayers and the environment, FEMA finally agreed to resolve the controversial issues by mandating an environmental impact review, which began in 2010. The Draft Environmental Impact Statement (DEIS) was published in April 2013 and the public comment period on that draft closed in June 2013.

FEMA tells us they received over 3,500 public comments on the draft, so needless to say it is taking some time to analyze and respond to those comments. Based on questions raised by public comments, FEMA sent questions to the applicants in October 2013, requesting clarification of their project plans. The applicants responded in November 2013, by revising their project plans. UC Berkeley and the City of Oakland responded that they now plan to “thin” rather than to remove all non-native trees, consistent with the original intentions of East Bay Regional Park District. FEMA now predicts that the final EIS will be published around the end of 2014.

Grant applicants are champing at the bit

The applicants for these grants are getting restless for award of the grant which will fund the removal of tens of thousands of trees or more. We recently reported to our readers that UC Berkeley began to destroy trees on its property in late August 2014, before the grant has been approved. The trees that were destroyed are still lying on the ground, looking like bonfires waiting to happen.

Some of the hundreds of trees destroyed by UC Berkeley in August 2014
Some of the hundreds of trees destroyed by UC Berkeley in August 2014

More recently, Claremont Canyon Conservancy has successfully recruited 12 East Bay elected officials to ask FEMA for immediate release of the grant funds, as well as “complete removal” of all eucalyptus trees, rather than thinning as originally proposed by East Bay Regional Park District and as revised by the City of Oakland and UC Berkeley in November 2013. This request was reported by the San Francisco Chronicle, Contra Costa Times, and ABC TV news. Based on these news sources, as well as the website of the Claremont Canyon Conservancy, we can report that the following East Bay elected officials have signed this request:

City of Oakland
Jean Quan, Mayor of Oakland
Dan Kalb, Oakland City Council
Rebecca Kaplan, Oakland City Council
Larry Reid, Oakland City Council
Libby Schaaf, Oakland City Council

City of Berkeley
Tom Bates, Mayor of Berkeley
Jesse Arreguin, Berkeley City Council
Laurie Capitelli, Berkeley City Council
Susan Wengraf, Berkeley City Council
Gordon Wozniak, Berkeley City Council

State of California
Nancy Skinner, State Assembly
Loni Hancock, State Senate

We have an unsigned copy of a letter to FEMA:

Pols letter to Amaglio

– end letter –

We cannot report with confidence that all these politicians sent the same letter because Oakland Councilman Dan Kalb is the only politician who has responded to our public records request. Mr. Kalb’s request is similar, but requests “funding to remove a substantial number of the eucalyptus trees.” Mr. Kalb’s letter seems to acknowledge that requesting removal of all eucalyptus trees would be inconsistent with the City of Oakland’s November 2013 revision of its original grant application; he says, “I know that the City of Oakland has submitted some revised language as requested by [FEMA].” The elected officials who signed the above letter do not seem to realize that their request contradicts the agreement with FEMA in November 2013 to thin rather than to remove all non-native trees on their properties. Or perhaps they have changed their minds.

This eucalyptus forest at the North Oakland Sports Facility will be  destroyed by the City of Oakland.
The City of Oakland wants to destroy this eucalyptus forest at the North Oakland Sports Facility. Note that where they have destroyed eucalyptus in the past, they have not controlled the resprouts. The grey-green small trees near the base of the hill are eucalyptus resprouts.

Stunning display of ignorance

We are rarely surprised by the extreme views of native plant advocates, but the letter sent by East Bay elected officials is a stunning display of ignorance, mendacity, or both:

  • The claim that native plants are less flammable than non-native plants is entirely fallacious. The indigenous landscape of California is highly flammable as is demonstrated by wildfires throughout California every year. In virtually every case, those wildfires occur in native landscapes.
  • This statement is not even superficially logical: “thinning will enable the Diablo Winds to blow through the eucalyptus more readily, thus enhancing the fire danger…” Obviously, destroying ALL the trees will provide even less of a barrier to Diablo winds.
  • The public record does not support the contention that eucalyptus is more flammable than any other type of vegetation. HERE is a report of the public record of the 1991 Oakland wildfire.
  • Oaks and bays have indeed grown in Clarement Canyon since eucalypts were removed there because it is a riparian corridor where trees are sheltered from the wind and water is funneled to them. However, that is not typical of regrowth after removal of the tree canopy in most locations where eucalypts have been removed. The more likely outcome is non-native annual grasses, as explained HERE by the environmental consultant who evaluated the plans of UC Berkeley. Since fire ignites more readily in grass, fire hazards are not reduced by this transition.
Non-native annual grassland now occupies most of the area where UC Berkeley destroyed 18,000 trees about 10 years ago.
Non-native annual grassland now occupies most of the area where UC Berkeley destroyed 18,000 trees about 10 years ago.

News sources also interviewed Jon Kaufman, a spokesperson for Claremont Canyon Conservancy who expressed his frustration that their desire for the destruction of non-native trees in the East Bay Hills is being delayed by FEMA: “With fire season approaching, it’s a good time to remind FEMA they need to get off their asses.” His insulting approach cannot be called a charm offensive.

Mr. Kaufman is quoted as making the following misstatement of fact: “But Kaufman said no spraying would be involved and that herbicide will be applied topically to the stumps with a brush.” We have heard native plant advocates make this claim many times. Perhaps some of them even believe it. FEMA asked for clarification from grant applicants about their plans for herbicide applications in October 2013. The applicants replied in November 2013 that they will apply Garlon according to the manufacturer’s label.

Mr. Kaufman’s claim that herbicide will not be sprayed is contradicted by the manufacturer of Garlon, DowAgra. The manufacturer describes the method of cut-stump application: “Treat the exposed cambium area and the root collar (exposed bark on the side of the stump) down to the soil line. Be sure to treat the entire circumference of the tree. To ensure effective control on large trees, also treat any exposed roots (knees) that surround the stump.” This method is illustrated on the manufacturer’s website by videos of the applicator using spraying equipment.

The herbicides needed to destroy non-native vegetation are also foliar sprayed, as described by the Draft EIS. It is a fiction that non-native trees and plants can be eradicated without spraying herbicides. The use of large quantities of herbicides is nearly as controversial as the loss of our urban forest.

Are you a voter in Oakland or Berkeley?

If you are a voter in Oakland or Berkeley and you care about the preservation of our urban forest and/or object to the hazards created by spraying our public lands with herbicides, you should know that some of the politicians who signed the letter to FEMA are on the ballot on November 4, 2014. You can take their support for clear cutting all eucalyptus in the Oakland/Berkeley hills into consideration in your vote. Better yet, you could write to them to tell them your opinion of their misguided support for removing all non-native trees on public property. We do not expect our public officials to be experts in horticulture or fire science. However, we think it is irresponsible for public officials to endorse the position of a particular interest group without making an effort to inform themselves of opposing viewpoints.

Here is a list of the candidates you will find on your ballot:

City of Oakland – Candidates for Mayor
Jean Quan http://www.oaklandnet.com/contactmayor.asp
Rebecca Kaplan atlarge@oaklandnet.com
Libby Schaaf lschaaf@oaklandnet.com

City of Berkeley – Candidates for City Council
Jesse Arreguin – District 4 – running unopposed

There is also a petition in opposition to these destructive projects available HERE.

The only logical resolution

One wonders how FEMA can now award grants to the City of Oakland or to UC Berkeley. In November 2013, these public agencies told FEMA, in writing, that they will thin rather than clear cut all non-native trees on their properties. In August 2014, UC Berkeley destroyed all eucalyptus trees on a portion of the project area, which should be a demonstration of UCB’s intentions. Actions speak louder than words, even written words.

In the case of the City of Oakland, elected officials in positions of authority, including the sitting Mayor of Oakland, have contradicted the City of Oakland’s written commitment to FEMA to thin rather than to clear-cut by asking FEMA to immediately release grant funds to clear-cut all eucalyptus from their properties.

How can FEMA trust these agencies to do what they have said in writing they intend to do? The only logical response to the request of these elected officials is to inform UC Berkeley and the City of Oakland that they have effectively rescinded their grant applications.

Is UC Berkeley building a bonfire during fire season?

If you are watching the news, you know that wildfires are raging all over California. One of those fires destroyed most of the small town of Weed a few days ago. The San Francisco Chronicle reported that fire and made a rare acknowledgement of the flammability of native California vegetation: “…the native fuels adapted over thousands of years to the lightning-caused fires that regularly broke out in California. The most problematic in a drought situation, he said, are manzanita, younger ponderosa pine trees and incense cedars. The three are all highly flammable and close to the ground, creating a fuel ladder from the grass to the overstory trees.” The article also noted that fires usually start in grasses and are then fanned by high winds into wildfires that destroy everything in their path.

Yet, the fiction continues in the San Francisco Bay Area that only non-native trees are to blame for wildfires and that they must all be destroyed to reduce fire hazards. In fact, when the trees are destroyed, the unshaded ground is quickly populated by grasses that are the type of vegetation in which virtually all of our fires start.

In the height of fire season, UC Berkeley has recently destroyed many trees in the East Bay Hills and left them lying on the ground to dry out. These huge piles of dead vegetation look like bonfires waiting to happen. We are grateful to our readers for alerting us to this new round of destruction. They have given us permission to publish their letter to the Federal Emergency Management Agency and UC Berkeley. We hope you will consider writing your own letter to express your concern.


 

Alessandro Amaglio [alessandro.amaglio@dhs.gov]
Region IX Environmental Officer
Federal Emergency Management Agency
Oakland, CA

RE: East Bay Hills – Environmental Impact Statement – FEMA – RIX

Dear Mr. Amaglio,

We are writing to tell you that UC Berkeley is in the process of destroying eucalyptus and some pine on its property. Judging by the Pesticide Application Notice posted on Grizzly Peak Blvd near South Park Drive, the trees were destroyed August 24-26, 2014. The scale of the removals is not entirely visible because the property goes down a steep slope that we could not cover. Based on what was visible to us, it appears that at least 100 trees were destroyed on a few acres.

P1010390

We believe the trees are being destroyed within the area for which UC Berkeley has applied for a FEMA grant to remove all non-native trees. We have used the maps in the Draft EIS to make this determination. Therefore, it seems appropriate that FEMA should be informed about this.

P1010400

While we visited the property on Monday, September 15, 2014, we could hear chainsaws in the distance but could not determine where the sound was coming from. Therefore, we suspect that more trees are being destroyed, but cannot determine exactly where.

P1010384

The Pesticide Application Notice gave the name of a person at UC Berkeley (Gary Imazumi) who is responsible for this project. (For the record, we are not responsible for the graffiti scrawled on that sign.) We have contacted him and asked for more information about the entire scale of the project and a timeline for its completion. We have also asked him what will be done with the huge piles of dead vegetation that are now lying on the ground. We have not received a response to our questions.

This incident raises the following questions and concerns:

  • Has the Draft EIS for the FEMA grants to UC Berkeley for tree removal been approved?
  • Has the FEMA grant to UC Berkeley been awarded?
  • If the EIS and/or the grant have not been approved, can UC Berkeley be reimbursed for expenses it incurs prior to the award of the grant?
  • The trees that UC Berkeley destroyed on August 24-26 are still lying on the ground several weeks after they were cut down. They have not been chipped or hauled away.  The Draft EIS made a commitment to chip the destroyed trees and distribute them on the ground.  Is there any time frame for this disposition of the destroyed trees?  Should the public expect dead trees to spend weeks or more on the ground after they are cut down?
  • As you know and the daily news confirms, we are now in the height of fire season. Does it seem consistent with fire hazard mitigation to use chainsaws at this time of year, particularly after several years of drought?
  • Does it seem consistent with fire hazard mitigation to leave dead vegetation lying on the ground during the height of the fire season? Does FEMA believe that dead vegetation is less flammable than living, standing trees?

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We understand that some of these questions are rhetorical and we don’t expect answers to any but the first three questions. The rhetorical questions are not intended to put you in an awkward position. They are intended to express our opinion of UC Berkeley’s hypocritical claim that destroying living trees will reduce fire hazards. We just want FEMA to know what is happening and to take it into consideration before finalizing the EIS and/or awarding the grant, if FEMA has not already done so.

Thank you for your consideration.

[Concerned citizens of Oakland]

Cc: Gary Imazumi, Manager, Grounds Operations, UCB [garyi@berkeley.edu]
Sal Genito, Associate Director, Grounds, Custodial, Environmental Services, UCB [salgenito@berkeley.edu]
R’obert Newell, Acting Assistant Vice Chancellor, Physical Plant, UCB [rbnewell@berkeley.edu]


 

Update:  On December 1, 2014, FEMA published the final Environmental Impact Statement for the “Fire Hazard Mitigation Grants” in the East Bay Hills.  As a result of UC Berkeley’s premature removal of trees in the project area prior to the publication of the EIS and prior to the award of the grants, the final EIS says that UC Berkeley will not be awarded grant funding for the Frowning Ridge portion of their grant application.  The following is an excerpt from the Executive Summary of the final EIS (page 17) which is available HERE.  However, we should not assume that this prohibition will remain when the EIS is officially approved by the “Decision of Record” on January 5, 2015, because we assume it is being challenged by those who support this project.

“In August 2014, UCB undertook environmental treatment measures on approximately 7.5 acres of the 185.2-acre project area at Frowning Ridge. According to UCB, they felled 150 eucalyptus, Monterey pine, and acacia trees, and applied an herbicide to eucalyptus and acacia stumps. In undertaking these actions prior to issuance of the final EIS, UCB failed to comply with both the specific conditions of the grant and also the NEPA requirement which limits applicant action during the NEPA process under 40 CFR 1506.1. Both required UCB to refrain from action until FEMA had completed its environmental review. As a result, the Frowning Ridge project area is no longer eligible for PDM program grant funding.

Nonetheless, the environmental analysis of the impacts of the proposed action at Frowning Ridge has not been removed from the final EIS because it is part of the review and consideration that FEMA has undertaken in concluding whether to fund the proposed actions. FEMA will continue to work with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service to determine whether UCB’s unauthorized work at Frowning Ridge negatively affects UCB’s other projects at Strawberry Canyon and Claremont Canyon and will make further decisions regarding these projects in the Record of Decision.”