eucalyptus destruction – Page 4 – Conservation Sense and Nonsense

Photographic evidence that eucalyptus is NOT invasive

Our subscribers have probably noticed that we are studying the case the California Invasive Plant Council (Cal-IPC) has made to classify Blue Gum eucalyptus (Eucalyptus globulus) as “invasive.” We have reported to our readers that Cal-IPC has made speculative claims about harm to wildlife that are unsupported by scientific evidence:

Monarch butterflies overwintering in California are using predominantly tall non-native trees, especially eucalyptus. There is no evidence that the monarchs overwintered in California prior to the planting of these non-native trees, contrary to the claim of Cal-IPC.
Contrary to the claim of Cal-IPC, there is no evidence that eucalyptus trees kill birds.

Is Blue Gum eucalyptus invasive?

In this post, we will look at the “evidence” provided by Cal-IPC that Blue Gum eucalyptus is invasive in California. Here is how Cal-IPC described the “local rate of spread with no management” of Blue Gum eucalyptus:

“Once a tree matures and produces seed, it can produce a profusion of progeny within a few years; doubling of stand area within 10 years possible but not well documented Without quantitative data, this response is conservative; stands have certainly expanded far beyond initial plantings in many locations, based on unpublished photodocumentation (1, 2) and personal observations (3)” [numbers refer to cited “references”]

And here is the “evidence” Cal-IPC provides in support of this rather dire prediction of the invasiveness of Blue Gum in California:

“Potts, Michael. 2003. About this edition. Caspar News. Online @ http://casparcommons.org/Press/News0305.htm. 2. Site Stewardship Program, Parks Conservancy. Unpublished photographs of Oakwood Valley, Marin Headlands, Golden Gate National Recreation Area. 3. Warner, PJ. 2004. Personal observations from 1980-2004 working in and adjacent to Eucalyptus stands in Marin, Sonoma, and Mendocino Counties, CA. 707/937-9172; pwarner@mcn.org.”

With the exception of an article in “Caspar News,” all evidence provided by Cal-IPC is unpublished. Although the one written source is described as “Caspar News,” in fact its title is “Caspar Newsletter.” The edition of this newsletter that is cited is the first unprinted edition of the “Caspar Newsletter.” Some of the unpublished “evidence” cited by Cal-IPC is described as “personal observations” of Peter Warner, who is the author of the Cal-IPC assessment for Blue Gum eucalyptus.

Therefore, the only source of information about the invasiveness of Blue Gum that we can evaluate is the one that is available on the internet HERE.

First a word about the town of Caspar, which is located 4 miles north of Mendocino on the coast of California. According to the 2010 census, it has a population of 509 souls. We celebrated New Years Eve there many years ago in a rocking bar, so we have fond memories of it. It is a lovely little town. We mention its small size to put its newsletter into perspective. It’s hardly mainstream journalism.

The article in the “Caspar Newsletter” starts with the recommendation of Peter Warner to eradicate all eucalyptus in Caspar:

“In this newsletter you find several articles written by strong advocates of dire means, including the authoritative Eucalyptus indictment written by State Parks’ expert on managing exotics Peter Warner, who advocates a draconian solution: cutting and then careful application of a dire chemical to eliminate every tree.”

In other words, the “Caspar Newsletter” is merely a repetition of Peter Warner’s agenda to eradicate eucalyptus and poison them with herbicides to prevent them from resprouting. It’s not an independent source of information.

Photographic evidence of invasiveness?

The only photographic evidence of the invasiveness of Blue Gum eucalyptus provided by Cal-IPC’s assessment is in the article in “Caspar News:”

"Eucalyptus encroaching on the ocean view" — “Eucalyptus encroaching on the ocean view”

There are three problems with this photograph with respect to the claim that it is evidence of the invasiveness of eucalypts:

We are asked to trust the memory of the photographer about the history of this eucalyptus grove. Credible evidence of spread of the eucalyptus grove would provide dated photographs taken at each period of time represented in this photo, i.e., 1989, 1994, 1999, and 2003.
We see the ocean in the far distance, west of this grove of trees. As the forest approaches the ocean, we see that the trees are smaller. This is as we would expect, because the wind from the ocean has suppressed the growth of the trees on the windward side of the grove. The fact that wind suppresses the growth of trees was established by Joe R. McBride in his study of trees in the San Francisco Presidio which the Presidio contracted with him to conduct: “Wind at the Presidio affects tree growth, form, and mortality. Exposure to winds in excess of 5 mph usually results in the closure of the stomata to prevent the desiccation of the foliage (Kozlowski and Palhardy, 1997) Photosynthesis is thereby stopped during periods of moderate to high wind exposure resulting in a reduction in tree growth…Eucalyptus showed the greatest reduction in growth with trees at the windward edge being only 46 percent as tall as trees on the leeward side.” (1) (emphasis added)
The photographer asks us to believe that the eucalyptus forest is spreading towards the ocean. Given that the seeds of eucalyptus are dispersed by gravity and wind and that the wind is coming from the ocean, we would not expect the eucalypts to spread towards the ocean, but rather on the leeward side of the forest.

In other words the “evidence” provided by the Cal-IPC assessment that E. globulus is very invasive is not supported by the evidence that is provided.

It is possible to document invasiveness with photographic evidence. We have provided our readers with two such examples that indicate that Blue Gum eucalyptus is not invasive in the San Francisco Bay Area:

In “Vegetation Change and Fire Hazard in the San Francisco Bay Area Open Spaces,” William Russell (USGS) and Joe McBride (UC Berkeley) used aerial photos of Bay Area parks taken over a 60 year period from 1939 to 1997, to study changes in vegetation types. They studied photos of 3 parks in the East Bay (Chabot, Tilden, Redwood), 2 parks in the North Bay (Pt Reyes, Bolinas Ridge), and one on the Peninsula (Skyline). These photos revealed that grasslands are succeeding to shrubland, dominated by native coyote brush and manzanita. Eucalyptus and Monterey pine forests actually decreased during the period of study. In those cases in which forests increased in size, they were native forests of oaks or Douglas fir. In other words, they found no evidence that non-native trees are invading native trees or shrubs.
Another example of photographic evidence that E. globulus is not invasive is from Mount Davidson in San Francisco. Adolph Sutro purchased Mount Davidson in 1881. He planted it—and other properties he owned in San Francisco—with eucalyptus because he preferred a forest to the grassland that is native to the hills of San Francisco. Here are historical photos of what Mt. Davidson looked like in 1885, 1927 and 2010:

Since Sutro didn’t own all of Mt. Davidson, there was a sharp line between the forest and the grassland when this photo was taken in 1927.

Over 80 years later, in a photo taken in 2010, there is still a sharp line between the forest and the grassland. We see more trees in the foreground where residential areas have been developed and home owners have planted more trees, but the dividing line on the mountain is nearly unchanged.

There is one well-documented case of significant expansion of planted E. globulus on Angel Island. Using historical records of planting of E. globulus on 23.6 acres as well as observations of uniform spacing of those plantings, McBride et. al., determined that E. globulus spread to 86.1 acres. The trees were planted starting in the mid-1870s to 1933 and their spread was measured in 1988. The authors of the study reported that most spreading occurred in areas of high soil moisture, such as swales, and in disturbed areas such as road cuts. This is also the only documented case of significant expansion of planted E. globulus mentioned in the US Forest Service plant data base. (2)

The one exception to the general rule that Blue Gum eucalyptus has not been invasive in California is consistent with what we know about Angel Island and about the limitations of seed dispersal and germination rates of Blue Gum eucalyptus:

Angel Island is an extremely windy and foggy place because it is located in the San Francisco Bay, close to the Golden Gate to the Pacific Ocean, where wind and fog enter the bay.
Eucalyptus seeds are dispersed by gravity and wind. Therefore we can expect seeds to travel further in a very windy place.
Optimal soil moisture increases the success of seed germination. Fog drip increases soil moisture and spreading of the eucalyptus forest on Angel Island occurred in drainage swales, where moisture would be greatest.

How invasive is Blue Gum eucalyptus?

Blue Gum eucalyptus is rarely invasive. The only documented case of significant spread of eucalyptus forest occurred in ideal conditions for seed dispersal and germination. Therefore, Cal-IPC’s claim that Blue Gum eucalyptus is extremely invasive is exaggerated at best and fabricated at worst.

If our readers are aware of any other documented cases of spreading of eucalyptus, we invite them to inform us. We are committed to accurately informing ourselves and our readers of the reality of invasiveness of Blue Gum eucalyptus.

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(1)	“Presidio of San Francisco, Wind Study, First Phase,” Joe R. McBride, circa 2002, page 6.  (unpublished, contracted study) 
(2)	“Focused Environmental Study, Restoration of Angel Island Natural Areas Affected by Eucalyptus,” California State Parks and Recreation, July 1988, pg 47 & 51.

“The Eucalyptus is Part of California”

Monarch butterflies over-winter in California's eucalyptus groves — Monarch butterflies over-winter in California’s eucalyptus groves

The East Bay Express has published an op-ed in defense of the much maligned eucalyptus. “The Eucalyptus is Part of California” is by Gregory Davis, a Berkeley resident. We summarize the main points for our readers:

University of California, Berkeley’s plan to destroy all non-native trees—primarily eucalyptus, Monterey pine, and acacia—is characterized as a “meat-axe approach.”
Applying herbicides repeatedly to prevent regrowth of non-natives is “tantamount to opening a can of worms.” We don’t know the consequences of dousing our public land with toxic chemicals, just as we didn’t know that using Agent Orange during the War in Vietnam would permanently damage that country and its citizens.
The moderate approach advocated by the Hills Conservation Network is more reasonable. Thinning and selective removal will do less damage.
Flammability of eucalyptus groves has been greatly exaggerated.
Eucalyptus has lived in California longer than most of us have been alive. They are more native than we are.
The loss of the “beauty and majesty” of eucalyptus in the hills will make hiking in the East Bay hills a less pleasant experience. “Anyone who has hiked up the trail under the green canopy of these tall, stately, plumed-top, evergreen trees knows how precious they are.”

Thank you, Mr. Davis, for writing this article and to the East Bay Express for publishing it. Critics of the native plant movement are learning that they must speak up if we are to save our trees. The projects that destroy our trees finally became so big and so visible, that more people are aware of them and are more willing to defend our trees.

Professor Joe McBride defends the forest on Mount Davidson

With great pleasure we share with our readers the following letter from Professor Joe R. McBride to Phil Ginsburg, the General Manager of San Francisco’s Recreation and Park Department, expressing his criticism of the plans of the Natural Areas Program to destroy 1,600 trees on Mount Davidson.

Joe McBride is Professor of Environmental Science in the College of Natural Resources at University of California, Berkeley and an expert on urban forestry in the San Francisco Bay Area and around the world. He is the author of many studies of urban forests, several of which he cites in his letter to the General Manager. He is particularly expert on the failure of trees caused by extreme wind conditions.

Professor McBride kindly accepted the invitation of several neighbors of Mount Davidson to read the plans of the Natural Areas Program (SNRAMP) for Mount Davidson and tour the mountain with them to evaluate those plans within the context of the actual conditions there. The neighbors and all lovers of the urban forest are extremely grateful to him for his time and willingness to share his expertise and decades of experience with us to help us save this beautiful forest from being needlessly destroyed.

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June 29, 2013

Mr. Phil Ginsburg
General Manager
San Francisco Recreation and Park Dept.
San Francisco, CA 94117

Re: Significant Natural Resource Areas Management Plan for Mt. Davidson Park

Dear Mr. Ginsburg,

I am writing to express my concern over the plan for removal of trees on Mt. Davidson. This concern is based on the historical importance of the trees, their contribution to San Francisco landscape, and several specific aspects of the Significant Natural Resource Areas Management Plan for San Francisco. As a Professor of Urban Forestry at the University of California I have for many years studied plantations of trees in the city and compiled several reports for the U.S. Army, National Park Service, Presidio Trusts, and the Golden Gate Conservancy concerning the condition and management of eucalyptus, Monterey pine, and Monterey cypress stands. My concern over the proposed management plan for Mt. Davidson is based both on my experience in urban forestry and on my experience as a citizen of the Bay Area who has enjoyed the urban forests of San Francisco for many years. These concerns are elaborated in the following paragraphs.

The eucalyptus and Monterey cypress on Mt. Davidson were planted under the direction of the former Mayor of San Francisco, Adolph Sutro. He was also responsible for planting other areas in the city that have subsequently become city parks. The plantations he established have served to protect park users from the wind, provide wildlife habitat, and in some cases define the visual character of the San Francisco landscape. They present an important historical heritage that I think should not be discarded lightly. I found no mention of the historical significance of the Mt. Davidson forest in justification for the proposed management in the Natural Areas Resource Management Plan for San Francisco. San Francisco might review the vegetation management plan developed by the Presidio Trust for the National Park Service to see the approach taken at the Presidio to maintain and manage historically significant forest plantations.

From a number of vantage points in San Francisco one can see several of the city’s hilltops covered in plantations of eucalyptus and Monterey cypress. These plantations stand in contrast to the architecture that surrounds them. They have been part of the San Francisco landscape for over one hundred years. Eucalyptus plantations are as much a part of the California landscape as the coastal grassland, chaparral, and oak woodland plant communities for many people growing up in the Bay Area. I did not find the visual value of the eucalyptus and Monterey cypress plantations on Mt. Davidson addressed in the plan. I was, however, alarmed by the use of the term ”invasive forest” in reference to eucalyptus plantations. This is a pejorative term that should not be applied to eucalyptus plantations. I have found little evidence of eucalyptus invading adjacent areas of grassland or other native vegetation types in the San Francisco Bay areas in studies I conducted in open space areas (McBride, Sugihara, and Amme, 1987; McBride, Cheng, and Chorover, 1989; Cheng and McBride, 1992; Russell and McBride, 2003). Comparison of photographs of Mt Davidson taken in the 1920s and 1950s show no evidence of the eucalyptus invading the adjacent grassland area (Proctor, 2006). These photographs indicate that a stable boundary exists between the eucalyptus plantation and the adjacent grassland. I see no justification for the establishment of a stable boundary between the eucalyptus and grassland habitats as called for in the “Site Improvements” section of the Significant Natural Resource Areas Management Plan.

My concerns over the management plan for the eucalyptus and Monterey cypress plantation on Mt. Davidson are based on portions of the Significant Natural Resources Areas Management Plan : 5. General Recommendations, 6.2 Mount Davidson, Appendix F Urban Forestry Statements. I am concerned with the justification for tree removal and the proposed levels (%) of trees to be removed.

Justification for Tree Removal

The primary justification for tree removal in the documents is the restoration of native habitat. Various statements are made concerning the minimal amount of habitat within the eucalyptus urban forest. This assumption is not supported by any data or reference to publications on this topic. Stebbins (1976) concluded that eucalyptus plantations in the East Bay were far richer habitats for vertebrates than either redwood or Monterey forest and that they vie with ‘dry’ chaparral and grasslands in species diversity and ’attractiveness’ to vertebrate species.

The general recommendation to maintain a basal area between 200 and 600 square feet per acre is appropriate. However, a conflict exists at Mt. Davidson where some stands (MA-1c) within the plantation currently have basal areas less than 200 square feet yet the plan proposes the removal of 82% of the trees. I think there is a problem with the use of tree density measured in eucalyptus stands in Glen Canyon Park in developing the proposed cutting of trees at Mt. Davidson. The point-quarter survey mentioned in Appendix F (Urban Forest Statements) of the Significant Natural Resources Areas Management Plan indicates a tree density of 353 trees per acre. Three eucalyptus plantations measured in the Golden Gate National Recreation Area had tree densities of 50, 98, and 726 trees per acre (McBride, Cheng, and Clausen, 2004). These numbers demonstrate the wide range of tree densities found within eucalyptus plantations in San Francisco. I estimated the tree density in stand MA-1c from Google Earth images of Mt. Davidson to range from 24 to 33 trees per acre. Trees in this stand average about 24 inches in diameter. Trees of this size with a density of 33 trees per acre would have a basal area of a little over 100 square feet per acre (103.6 square feet). No trees from the area designated MA-1c could be removed if the basal area recommendation was followed. The same would apply to stands MA-2e and MA-2c where recommendations are for removal of 23% and 31% respectively. I think a major shortcoming of the Plan is that lack of stand-specific tree density data.

Various sections of the Significant Natural Resource Areas Management Plan justify tree removal as a means of allowing re-vegetation with native understory vegetation. Species commonly found in the understories of native forests and woodlands of the Bay Area are adapted to the low light intensity of these forests and woodlands. Removing the eucalyptus overstory up to 82% as proposed for area MA-1c will expose the ground surface to light levels that most native understory plants will not be able to tolerate. The management plan also points out that removal of eucalyptus will result in the promotion of growth of existing exotic understory species. These will no doubt, compete with any native species for the site. The suggestion that these exotic species will be controlled by manual removal and the use of herbicides indicates the City is prepared for a large investment of time and labor to combat these plants. Projects to eliminate exotic understory plants at the Presidio after overstories of Eucalyptus and Monterey cypress have been removed have proved to be very expensive and only partially successful.

The Significant Natural Resource Areas Management Plan states that the proposed forest management will not result in long-term changes in recreational use of the natural areas. I cannot agree with this conclusion. The proposed cutting of trees will increase the windthrow and wind breakage of the remaining trees. Trees that have grown up together in a plantation have buffered each other from the wind. When individuals are exposed by the removal of surrounding trees they are very vulnerable to the wind. This is well documented in studies of native forests and forests which have been thinned or opened for subdivision development (Franklin and Forman, 1987; McBride, 1999, 2002, 2003; Sinton et al, 2000). The tree fall and wind breakage hazard to walkers using the Mt. Davidson area after the proposed tree removal and thinning would, I believe, seriously compromise the use of the area for recreational purposes. The existing forest plantations currently contribute to the use of Mt. Davidson by walkers because of the reduction in wind velocity by the trees. Forest plantations studied at the Presidio and at Lands End significantly reduce wind velocity and protect people walking from uncomfortable wind chill effects (McBride, 2002; McBride and Leffingwell, 2003). Choice of coastal bluff trails at the Sea Ranch made by walkers is often dependent on the amount of protective cover from the wind provided by areas planted with Monterey cypress. The exposure of Mt. Davidson to winds from the ocean will result in a less pleasant recreational experience if trees are removed.

There is an assumption in the Significant Natural Resource Areas Management Plan that minimal impact will occur to species such as hawks and owls as a result of tree removal because the overall acreage of the forest will remain high. This is not a valid assumption for two reasons. First, hawks and owls choose specific trees for nesting and perching. These trees are chosen on the basis of their position in a forest stand and the structure of the tree. Nests are used by some species year after year so that the removal of a nesting tree can present a major problem for the specific bird using the tree. Avoiding the cutting of nest trees during the nesting season, but felling of these trees after the nesting season is a major impact that should not be part of the management plan. It is also important to not remove trees surrounding nesting trees. Most recovery plans for rare and threatened tree nesting birds require a protected area with a minimum radius of 300’ around a nesting tree. No trees can be removed within this zone.

In the “Site Improvements” section of the Significant Natural Resource Areas Management Plan it is suggested that the management proposals will improve the health of the eucalyptus forest. It is suggested that tree thinning will promote a more healthy forest. This certainly is true in densely stocked forest stands, but I did not observe conditions in the eucalyptus plantations where tree density required thinning. Several standing dead eucalyptus trees are present at Mt. Davidson, but the standing dead trees I examined had all been girdled. It was evident that some individual or individuals have had a vendetta against eucalyptus trees and had girdled trees in the past. I did not see any indication of natural mortality in the overstory of the plantations. Concern has been raised over the potential for ivy to grow up the trunks and eventually smother the eucalyptus trees. I have not observed this taking place in eucalyptus plantations in the East Bay. Ivy (English and Algerian) may climb the trunks of trees, but in my experience it does not have the capacity to grow over the smaller limbs and branches. There were a couple of eucalyptus snags completely covered by ivy at Mt. Davidson, but these snags were the result of girdling of the trees snags, not the growth of ivy. The ivy, Cape ivy, and the Himalayan blackberry in the under story of the eucalyptus plantation are restricting establishment of eucalyptus seedlings. I do not see this as a problem at the current age of the plantation. Perhaps in another hundred years an examination of the plantation could establish the need for regeneration. At this time in the life of the Mt. Davidson plantation I do not consider the lack of regeneration a problem. Removal of the exotic understory species at this time would reduce the habitat quality of the plantation, especially the removal of Himalayan blackberry that provides a valuable food source for many species.

I conclude that the Significant Natural Resource Areas Management Plan for the removal and thinning of different portions of the eucalyptus plantation on Mt. Davidson is not justified. The plantation serves an important role in the history and visual characteristics of the city. Trees and the existing understory provide habitat for wildlife and wind protection for walkers. The justifications for the management prescriptions have not been properly developed. Furthermore, the cost of removal of the trees seems unjustified in view of other priorities in the San Francisco budget.

Sincerely,

Joe R. McBride
Professor

CC: Mayor Edwin M. Lee
City and County of San Francisco Board of Supervisors
San Francisco Recreation and Park Commission
San Francisco Planning Commission
San Francisco Urban Forestry Council
Park, Recreation and Open Space Advisory Committee
Bill Wycko, Environmental Review Officer (Case No. 005.1912E)

Literature Cited

Cheng, S. and J.R. McBride. 1992. Biological Assessment of Mills Creek Riparian Corridor. Report to the California Department of Parks and Recreation. Monterey Co., CA 89p.

Franklin, J. and R.T.T. Forman. 1987. Creating landscape patterns by forest cutting: ecological consequences and principles. Landscape ecology 1:5-18.

McBride, J. R. 1999. Identification of areas of high windthrow potential at the Sea Ranch. McBride and McBride. Consulting Landscape Ecologists. Berkeley, CA.

McBride, J. R. 2002. Presidio of San Francisco Wind Study, First Phase. Report to the Presidio Trust. San Francisco, CA. 35 p.

McBride, J. R. 2003. Re-evaluation of the windthrow problem at The Sea Ranch. Report to the Planning Department. The Sea Ranch, CA. 6 p.

McBride, J. R. and J. Leffingwell. 2003. Effects of Forest Stands on the Microclimates of the Presidio. Report to the Presidio Trust. San Francisco, CA. 27 p.

McBride, J.R., N. Sugihara and D. Amme. 1987. Vegetation Assessment. In: D. Boyd (Ed.) Environmental assessment for Eucalyptus Removal on Angel Island. California Dept. Parks and Recreation, Sacramento, CA. pp 23-45

McBride, J.R., S. Cheng and J. Chorover. 1989. Natural Resources Assessment – Jack London State Park. Calif. Dept. Parks and Recreation. Sacramento, CA. 432 p.

Proctor, J. 2006. San Francisco’s West of Twin Peaks. Charleston, SC: Arcadia Publishing.

Russell, W. H. and J. R. McBride. 2003. Landscape scale vegetation-type conversion and fire hazard in the San Francisco Bay Area open spaces. Landscape and Urban Planning 64:201-208.

McBride, J. R. , S. Cheng, and J. Clausen. 2004. Vegetation management Strategy for Lands End, GGNRA. Report to the Golden Gate National Park Conservancy. San Francisco, CA

Sinton, D. S. et al. 2000. Windthrow disturbance, forest composition, and structure in the Bull Run Basin, Oregon. Ecology 81(9): 2539-2556.

Stebbins, R. 1976. Use of habitats in the East Bay Regional Parks by free-living vertebrate animals. August 1975. In “Vegetation Management Principles and Policies for the East Bay Regional Park District”. East Bay Regional Parks District. Oakland, CA.

Guest article about FEMA projects by a student of the forest

A few days ago we received a comment from a fellow tree-lover and student of the forest that deserves our attention. He visited the project areas that may soon be cleared of all non-native trees and expressed his opinion of this planned devastation. With his permission, we are posting his comment as an article.

His name is Deane Rimerman and he describes himself as “Hybrid Car Geek, PNW Landscape Restorationist, Web Builder, Arborist, Writer, Poem Performer, Life-long Photographer & Audio Engineer” on his website.

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Frowning Ridge before "vegetation management" — Frowning Ridge before “vegetation management”

Yesterday I toured the Oakland hills for the first time since I visited it a week after the 1991 fires. That torched landscape turned me into a lifelong student of the forest. So after my visit back to those hills yesterday I started reading everything I could about these FEMA plans!

In the interest of providing the most value I’ll focus on what’s not been mentioned yet in the debates I’ve read on this website thus far. Primarily it revolves around moisture and the value of tall standing trees for the purpose of capturing fog drip during the dry season.

I once worked with a forester named Rudolph Becking on studies that show 200 foot tall old growth redwoods can capture up to 7 inches of fog drip during the dry season. The biggest tallest eucalyptus,and pines, invasive or not also have the ability to do this. And if we’re talking about fire safety don’t we want to increase humidity in soil and in the air during the hottest driest times of the year? If the answer is yes, that can be done by protecting sites that are most exposed to fog in the dry season.

Frowning Ridge after 1,900 trees were removed from 11 acres in 2004

Also eucalyptus are huge water users only when they are young and exposed to full sun, but like most trees, once in a closed canopy forest they consume far less water during the dry season compared to open canopy forests.

Point being, we need to maintain landscapes that don’t dry out because plant and tree diversity won’t thrive and really aggressive invasive weeds will take over if we don’t intentionally map out and seek to protect the highest existing levels of soil moisture. The SF Bay Area climate is very arid. If a time of drought were to coincide with this fire hazard removal plan, we could have a mass die-off native species and an even greater shift to drought tolerant non-native weeds that will eliminate most biodiversity.

And regardless of drought, desert like alterations to the landscape is what happens when we lose too much shade and moisture all at once. Many native plants growing under semi-shade conditions right now can’t survive if all the non-natives are clearcut or near clearcut as proposed in this plan.

Also what is missing from this landscape is lots of tall dead trees that act as bioreactors for flora fauna and rhizo diversity. Tall dead trees are like a bank account for future healthy soil, homes for so many birds and bugs too. There is a great poverty of standing deadwood on this landscape, yet no significant mention of snag retention and snag creation in this plan. If we cut down all the largest live and dead standing trees there will be no large downed log recruitment for another century and that would be a misguided tragedy that will further impoverish the soil.

In a word: DIVERSITY. You don’t have to cut down all the trees to increase diversity. We could have thousands of us spending every winter in these hills replanting hundreds of different species of native plants, as well as clearing weeds away from existing native plants in a low-impact site-specific way. This of course is a labor intensive approach and humans have been manipulating these hills for thousands of years in very labor intensive ways.

In my view we’ve neglected these lands for too long and it’s about time we get back to all of us working together as volunteers meant to cultivate a garden of biodiversity with an eye toward carbon absorption and keeping as high as possible soil moisture and air moisture in order to prevent catastrophic fires.

But instead in this plan we see the usual lazy, super aggressive approach in which a forester, whose job is to cut down forests, is asked to solve our problems. And without any site-specific observation of fog drip and areas of high soil moisture in the dry season we log the forests as quickly and cheaply as possible thinking if we do it severely enough we won’t ever have to come in and fix anything ever again.

The homeowner version of these two approaches is akin to one homeowner who makes their landscape beautiful with hard work and lots of hands-on low impact cultivation of plant and tree diversity without herbicides. And then we have the other lazy homeowner who hates his yard and weedwacks his yard to bare ground every other year thinking once he does it one more time (and even more severely this time with extra herbicide) he won’t ever have to do it again.

And habitat-wise, if we inoculate eucalyptus and pine with heart wood rot to create cavities for habitat we will help fuel the whole food chain, not to mention create homes for myriad species.

And to all the folks who say these hills were mostly shrub oak and grassland I say that natural ecosystems in this region were mosaics of conifer and hardwood woodlands amongst mosaics of shrublands and small grassy meadows and it was all maintained by humans who for thousands of years used fire to maximize productivity in traditional cultivation areas. Those cultivation practices were based on specific sites where species grew best. The current plan as proposed is the antithesis of this. The current plan treats the whole landscape as if there’s very little variability of moisture levels and species compositions. It’s as if the planners know more about growing corn in Iowa than they do about growing an ecosystem in the arid San Francisco Bay Area.

Lastly, the Monterey Pine is entirely native to a landscape that’s less than 100 miles away. And yes some of these pines might be a hybridized New Zealand variety but so what?

I’ll have more to say on all this soon… Maybe a whole website or book perhaps? 🙂

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Remember that public comments are due by June 17^,2013. You may submit written comments in several ways:

Via the project website: http://ebheis.cdmims.com
By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
By mail: P.O. Box 72379, Oakland, CA 94612-8579
By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars. So, please tell the people who work for you what you think of these projects.

FEMA projects in the East Bay deny carbon loss

Hummingbird in eucalyptus flower. Courtesy Melanie Hoffman — Hummingbird in eucalyptus flower. Courtesy Melanie Hofmann

Our readers know that one of many reasons why we object to the destruction of healthy trees is that they are sequestering and storing carbon which is released as carbon dioxide into the atmosphere when the trees are killed and as wood decays. Carbon dioxide is the predominant greenhouse gas that is causing climate change. We believe that addressing climate change should be considered our highest environmental priority.

Although we like native plants and would like to conserve them, they will not survive in their historical ranges in a changing climate. Therefore, native plant advocates should join us in making climate change a higher priority than destroying our existing landscape in places where native plants may no longer be adapted if that destruction contributes to climate change.

Federal and State policies and laws have been adopted to address climate change and the main point of an environmental impact study is to assure the public that the project complies with all laws. Therefore, the Draft Environmental Impact Study (DEIS) for the FEMA projects in the East Bay that will destroy tens of thousands of healthy trees stands on its proverbial head trying to deny that carbon loss resulting from these projects will not violate these laws. These projects are described in detail HERE.

The point of this article is to inform the public of some of the flaws in the DEIS with respect to its analysis of carbon loss resulting from these projects. (This will not be a complete list of omissions and errors in the DEIS regarding carbon loss. A complete list would be too technical and lengthy.)

Only 15% of carbon storage in the existing forest has been quantified by the DEIS

The DEIS quantifies only two sources of carbon dioxide emissions resulting from this project: the fossil fuels used by motorized equipment during the project and the trunks of the trees greater than 5” in diameter that will be destroyed. Calculating loss of stored carbon based solely on the trunks of the trees that will be destroyed excludes the following sources of stored carbon in the forest: the understory, the forest floor layer (e.g., duff and litter), the bark, roots, and branches of the trees, and the soil. RA Birdsey of the US Forest Service reports (1) that only 15% of total carbon stored in forest ecosystems in the United States is contained in the trunk:

Allocation of carbon in forest ecosystems and trees

US Forests, 1992

1%	Foliage
5%	Roots
15%	Bole (trunk)
9%	Other wood above ground
	29%	Tree
	61%	Soil
	8%	Forest floor
	1%	Understory
	99%	Total

Although the soil will remain when the trees are destroyed, there is scientific evidence that there will be some loss of soil carbon as a result of this project: “…a major forest disturbance, such as a clearcut harvest, can increase coarse litter and oxidation of soil organic matter. The balance of these two processes can result in a net loss of 20% of the initial carbon over a 10-15 year period following harvest.” (1) The destruction of all non-natives trees on 400 acres of UC Berkeley and the City of Oakland properties and 90% of the trees on 1,600 acres of East Bay Regional Park District, surely qualifies as a “major forest disturbance” which will result in loss of carbon stored in the soil of the forest.

The DEIS pretends there is no carbon loss from prescribed burns

East Bay Regional Park District plans to chip the trees that are destroyed and distribute them on 20% of the project areas to a depth of 4-6 inches. They plan to burn the wood that cannot be distributed on the ground without exceeding these limits. This excess wood will be burned in piles. In addition to pile burns, EBRPD also plans to conduct broadcast burns for the purpose of destroying non-native vegetation and vegetation debris considered potential fuel for a fire.

The DEIS does not quantify the carbon that will be released by these burns, citing an EPA policy of 1996: “It should be noted that the emission of CO₂ from burning has not been calculated since the removal of the vegetation would allow new vegetation to grow, eventually consuming at least a portion [of] the CO₂ released during burning, as noted in EPA emission factor guidance (EPA 1996)”

This EPA policy regarding CO₂ emissions from prescribed burns has been revised to include carbon emissions from prescribed burns. In response to climate change, the EPA established an “Emission Inventory Improvement Program” (EIIP) in 1997. Since then, the EIIP has continuously expanded and improved the National Emissions Inventory (NEI). The NEI for 2008 is available on the EPA website. It includes reporting of CO₂ emissions resulting from prescribed burns. Data for each type of emission is available on the internet. It can be sorted by state. The 2008 NEI reports that the State of California emitted 2,156,547 tons of carbon dioxide from prescribed burns in 2008.

Obviously, the DEIS is mistaken in its outdated claim that the EPA excludes emissions from prescribed burns from calculations of greenhouse gas emissions. Furthermore, whether or not the carbon released by prescribed burns must technically be reported, that carbon is, in fact, released to the atmosphere. Such a legalistic quibble ignores the fact that carbon released by prescribed burns has the same harmful environmental consequences as any other carbon release.

Loss of the ability of the existing forest to sequester carbon in the future is not quantified

In addition to the grossly underestimated loss of carbon stored in the existing forest ecosystem, the DEIS does not quantify the loss of the ability of the existing forest to sequester carbon in the future. The DEIS acknowledges that the post-treatment landscape will be less capable of sequestering carbon than the existing landscape:

“The proposed and connected actions would also be self-mitigating to some degree in the absence of a wildfire, because native vegetation would partially replace the non-native vegetation removed. However, the planned growth of oak and bay woodlands and successional grassland containing shrub islands would not sequester as much carbon as the larger eucalyptus and pines and the denser coastal scrub that would be removed.” (DEIS 5.6-11)

The DEIS cannot claim that legal thresholds for carbon loss are not violated without quantifying this decrease in the ability to sequester carbon.

Blue gums live in Australia from 200 to 500 years. (2) They live toward the longer end of the range in milder climates such as the San Francisco Bay Area. Most Blue Gum eucalypts were planted in the East Bay between 1886 and 1913, according to David Nowak of the US Forest Service. (3) Therefore, they are not more than 130 years old. They can be expected to continue to sequester carbon for at least 100 years and perhaps 300 years.

The native trees that the proposed projects claim will occupy the ground now occupied by non-native trees are significantly smaller than the existing trees. Since carbon sequestration and storage are proportionate to biomass, the native trees will not compensate for the loss of the ability of the existing forest to sequester carbon. The DEIS reports in Table 4.7-1 that the oak-bay woodland in the project areas is storing only 8.97 metric tons of CO2 per acre, compared to 325.91 metric tons per acre in the eucalyptus forest and 184.61 metric tons per acre in the Monterey pines.

Furthermore, the predominant native tree is being killed by Sudden Oak Death (SOD) at an epidemic rate, so its future is both unlikely and unknown. SOD exists in the project areas, which is reported HERE.

Misinterpreting or misrepresenting science

The DEIS sets up a straw man to support its claim that the FEMA projects will not increase carbon dioxide emissions by offering a false choice between theoretical carbon loss from a wildfire vs. carbon loss from destruction of the non-native forest. This false choice violates both federal and state law regulating environmental impact studies because the measure of environmental impact as defined by those laws require that the study compare the existing, baseline condition to the potential impact resulting from the proposed project. In other words, the existing condition is the forest that exists now, not a theoretical forest that has been destroyed by fire.

Adding insult to injury, the DEIS tries to prove its theoretical straw man by misinterpreting or misrepresenting scientific studies:

“Studies indicate that if a wildfire occurs, the proposed type of vegetation management sequesters more carbon in the long term than leaving the sites untreated. Two wildfire modeling studies indicated that thinning would reduce damage caused by wildfires, allowing faster regrowth after a fire (Hurteau and North 2010; Wiedinmyer and Hurteau 2010). The Wiedinmyer and Hurteau (2010) study included the use of prescribed burning as a treatment method.” (DEIS 5.6-11)

In fact, these studies don’t say what the DEIS claims they say:

In “Prescribed fire as a means of reducing forest carbon emissions in the Western United States,” (4) the authors compare carbon loss from prescribed burns with carbon loss from wildfires in the same locations and reach the conclusion that prescribed burns result in less carbon loss than wildfires without prescribed burns. However, the prescribed burns they are considering were restricted to the understory and did not include any trees: “The fraction of fuel consumed in prescribed fires was applied only to the surface fuel fraction (including herbaceous, fine, and coarse fuels of the total fuel loading model…); no live or standing dead trees are assumed to burn in prescribed fires.” Therefore, this study is not applicable to the proposed project which intends to burn the remains of hundreds of thousands living trees which will obviously release far more carbon into the atmosphere than the prescribed burns in this study as well as reduce carbon sequestration into the foreseeable future.

In “Carbon recovery rates following different wildfire risk mitigation treatments,” (5) the authors compare several different methods of fuel reduction with respect to how long it takes for the forest to recoup the carbon loss from those methods. It finds that the forest is unable to recoup the loss of carbon when the destruction of the overstory canopy is the method used because of the large amount of carbon stored in large trees: “Overstory tree thinning treatments resulted in a large carbon deficit and removed many of the largest trees that accumulate the most carbon annually, thereby increasing carbon stock recovery time.” In fact, this is precisely the method that will be used by the proposed project. Therefore, this study makes the point that this project will permanently reduce the ability to sequester carbon by destroying large trees that will not be replaced. In other words, this study contradicts rather than supports the assumptions of the DEIS regarding carbon storage.

In “High-severity wildfire effects on carbon stocks and emissions in fuels treated and untreated forests,” (6) the authors compare carbon loss from wildfires in a thinned forest (both loss from treatment and loss from subsequent wildfires) with carbon loss from wildfires in the same locations without thinning. They conclude that such thinning results in more total carbon loss than wildfires without such thinning in the short run. However, because more trees remain after wildfire in a treated forest, the ability of the forest to sequester carbon in the long term can recoup much of the loss of the treatment. The forests they are considering have average densities of 1536 stems per hectare and thinning is limited to stems of less than 18 inches in diameter. This study is therefore not relevant to the proposed project because the forests in the proposed project are significantly less dense and are being completely destroyed by UCB and Oakland and more drastically thinned by EBRPD compared to the study. In other words, a much greater percentage of total carbon storage will be lost by the proposed projects in the short run because a higher percentage of total trees will be destroyed, including all large trees which store more carbon than smaller trees. In addition much more capability to sequester carbon will be lost in the long run because few trees will remain.

All of these studies have in common that they have measured all sources of carbon in the forest: carbon in the soil and roots, in the branches and leaves, in the understory, in the duff and leaf litter. In contrast, the DEIS quantifies only the amount of carbon stored in the trunks of the trees. All other sources of carbon are ignored.

It’s time to send your public comment on these projects

Remember that public comments are due by June 17^,2013. You may submit written comments in several ways:

Via the project website: http://ebheis.cdmims.com
By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
By mail: P.O. Box 72379, Oakland, CA 94612-8579
By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars. So, please tell the people who work for you what you think of these projects.

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(1) “Carbon Changes in US Forests,” RA Birdsey and LS Heath, US Forest Service Gen. Tech. Report RM-GTR-271, 1995

(2) Eucalypt ecology: Individuals to ecosystems, by Jann Elizabeth Williams, John Woinarski ,Cambridge University Press, 1997

(3) David Nowak, “Historical vegetation change in Oakland and its implications for urban forest management,” Journal of Arboriculture, 19(5), September 1993,

(4) Christine Wiedinmyer and Matthew Hurteau, “Prescribed fire as a means of reducing forest carbon emissions in the Western United States,” Environmental Science Technology, 2010, 44, 1926-1932

(5) Matthew Hurteau and Malcolm North, “Carbon recovery rates following different wildfire risk mitigation treatments,” Forest Ecology and Management, 260 (2010) 930-937

(6) Malcolm North and Matthew Hurteau, “High-severity wildfire effects on carbon stocks and emissions in fuels treated and untreated forest,” Forest Ecology and Management, 261 (2011) 1115-1120

Environmental consultant evaluates UC Berkeley’s FEMA project

We described the projects that will destroy tens of thousands of trees on public lands in the San Francisco East Bay in recent posts available here and here. In this post we will focus on the projects on the property of the University of California, Berkeley (UCB) which will destroy ~~60,000~~ 54,000 trees on 284 acres, cover 20% of those acres in 2 feet of chipped wood, and spray hundreds of gallons of herbicides on the stumps as well as foliar spray non-native vegetation.

The first consultant that was hired by FEMA to conduct the environmental impact review was URS Corporation. We know that URS Corporation was the consultant at the time of the scoping process in 2010 because we spoke to their representatives at that meeting. We were able to obtain the evaluation of UCB’s project by the URS Corporation with a public records request (Freedom of Information Act, AKA FOIA). In this post we will tell you what URS said about UCB’s project in a letter to FEMA dated May 27, 2009. FEMA posed 6 specific “issues” and we will briefly describe how URS evaluated these issues. (The issues are quoted verbatim from that letter.)

Issue 1: Evidence that the supposed habitat restoration benefit will occur, since no plans for revegetation is included in this grant.

URS agrees with UC that the “project will provide better growing conditions for plants in the understory because the plants will have increased access to resources (e.g., sunlight and soil nutrients).” But they emphatically do not agree with UCB that the post-treatment landscape will be exclusively native:

French broom in Oakland, CA. Beautiful but hated by native plant advocates. Share alike

“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.”

URS also observes that wood chip mulch is unlikely to encourage native revegetation over non-native revegetation:

“As written, the current plan assumes native vegetation will reclaim the treatment areas but does not include any plans for native revegetation. Instead, in order to ‘reduce undesirable weed invasion’ and thus encourage the development of native grasslands, chaparral, and bay/redwood communities, UC plans to apply chip mulch to the ground…It is not clear how the mulch would prevent the proliferation of invasive species while simultaneously encouraging the growth of existing native species. Despite thorough research, we were unable to find documentation of the ability of exotic chip mulch to suppress undesirable species while encouraging favorable species.”

Issue 2: Relative fire risk of current vegetation versus chip dominated landscape: there is no scientific evidence to support the project as proposed.

Although URS agrees with UC that eucalypts are a fire hazard, they question that the eucalypts are more flammable than distributing their dead wood on the ground as wood chips, branches and logs:

“However, the comparative risk between eucalyptus in the form of a dense standing forest versus the form of a 2-foot-deep mulch layer on the ground is not well documented. Studies have shown that mulch layers actually can pose a fire risk depending upon the type of material, the depth of the mulch, and the climate of the mulch site….Fire Engineering Magazine recommends that, to reduce the potential for fire in mulch, one should recognize that mulches high in oils ignite more easily and that mulch fires start more readily in hot climates where rain is scarce…Eucalyptus material is high in oils, and the East Bay Hills are subject to long annual periods that are hot and dry.”

Chips of destroyed trees, UC Berkeley project. Photo courtesy Hills Conservation Network

Issue 3. Potential for introduction of chaparral-dominated landscape and issues associated with fuel-driven fires versus climate-driven fires.

URS notes that the post-treatment landscape is unknown. However, if UC is right in predicting the return of a native landscape, this is URS’s evaluation of the fire hazard in a native landscape:

“…grasslands fuels burn cooler and faster than eucalyptus material, yet they are easier to ignite and carry fire quickly across a landscape. Chaparral is one of the most hazardous wildland fuel types in California due to the woody, persistent nature of the plants. A chaparral-dominated landscape in the post-treatment project area would create a fire hazard profile with its own suite of risks and concerns for fire protection, including flame lengths that far exceed those of the other possible vegetation types.”

URS concludes the analysis of this issue by repeating its concerns regarding the flammability of wood chip mulch:

“…it may be inaccurate to assume that the chip layer, given its depth, can be ignored as a potential fuel source. However, such a deep chip layer may have the potential to not only sustain a localized burn but to connect fuels in vegetation types located adjacent to the treatment areas.”

Issue 4. Justification of two species (Monterey pine and acacia) targeted for removal are a risk.

URS does not believe that Monterey pine and acacia will contribute to fire hazards in the post-treatment project areas:

“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.”

Issue 5. Complete analysis of other practical alternatives…

URS agrees with UC that the cost of annual clearance of ground litter would be prohibitive. They also agree that “creating strategic fuelbreaks” would not be effective. However, they say that “thinning targeted species rather than removing all and regularly clearing the understory” should be considered a viable alternative to the proposed project.

Issue 6. Document chips will decompose in 3 to 5 years.

UCB’s project intends to distribute wood chips on the forest floor to a depth of 2 feet. UCB claims that the wood chips will decompose in 3 to 5 years. URS does not think this is a realistic assessment:

“…literature search did not identify any studies documenting decomposition rates in eucalyptus mulch deeper than 4 inches, which notably is the maximum recommended depth for landscaping…Best scientific judgment suggests that a deeper chip layer would decompose more slowly than a shallow chip layer because it would be more insulated from moisture and less of its surface area would be in contact with decomposing bacteria and fungi found in the soil.”

UCB has ignored the advice of FEMA’s consultant

We have read most of the Draft Environmental Impact Study (DEIS) for this project. It is about 3,000 pages long, so we won’t claim to have digested it entirely. However, we can say with some confidence that UCB has ignored most of URS’s scathing criticism of their project. The only concession that we can see is that UCB now says they will cover only 20% of the project with 2 feet of wood mulch. However, they intend to cut the remainder of the wood into pieces 2-3 feet long and leave them lying around on the remaining 80% of the project area. That doesn’t seem like a significant improvement, with respect to fire hazard. Dead wood is dead wood and tons of it will be lying around when tens of thousands of trees are destroyed.

Why was the Environment Impact Study written by different consultants?

Given that URS was obviously telling UCB something they didn’t want to hear when the process of preparing an environmental impact study began in 2009, we aren’t surprised that URS was not involved in the final preparation of this document. According to the Draft Environmental Impact Study, the consultants who prepared the report are entirely different. (DEIS, Section Eight) URS Corporation is conspicuously absent from the list of preparers of the DEIS.

We rarely subscribe to conspiracy theories. We usually find incompetence a more realistic explanation for the strange things that happen in our messy world. However, in this case, let’s just say that this change in the consultants who prepared the DEIS smells bad.

Please tell FEMA your opinion of these projects

Comments on this document must be submitted by June 17, 2013. You may submit written comments in several ways:

Via the project website: http://ebheis.cdmims.com
By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
By mail: P.O. Box 72379, Oakland, CA 94612-8579
By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars. So, please tell the people who work for you what you think of these projects.

Please sign the petition of the Hills Conservation Network in opposition to these projects which is available HERE.

The last public meeting for the FEMA projects in the East Bay is Saturday, May 18, 2013 – video available

This is one of many trees in the East Bay that have already been destroyed because it is not native.

We have just received a link to a video about the FEMA projects in the East Bay hills. (Available here) The video was created by someone who attended the second public meeting on Tuesday, May 14, 2013.

We don’t agree with everything he says, but we certainly agree with his main point: VERY FEW MEMBERS OF THE PUBLIC IN THE EAST BAY KNOW ABOUT WHAT IS PLANNED FOR THEIR PUBLIC LANDS. THEY ARE NOT AWARE THAT TENS OF THOUSANDS OF NON-NATIVE TREES WILL BE DESTROYED.

We join the creator of this passionate video in urging you to attend the last public meeting about these projects which will take place on Saturday, May 18, 2013, 10:00 a.m. – 12:00 p.m., Claremont Middle School, 5750 College Avenue, Oakland, CA 94618.

For more information about these projects and other ways in which you can comment on the plans please visit this Million Trees post. Written public comments are due by June 17, 2013.

Update: The San Francisco Forest Alliance has posted a report about this hearing which is available here.

Update 2: A video of the hearing is now available here.

Nearly a HALF MILLION trees will be destroyed if these East Bay projects are approved

This is a revision of an article that was published on May 5, 2013. In our haste to inform our readers of these projects during the public comment period, we published before we had read the entire Environmental Impact Study. We are forced to revise our estimates based on further reading of the document. We apologize for the confusion and thank you for your patience.

On May 29, 2013, we found an error in the number of trees that will be removed at Frowning Ridge. We show our corrections so as not to mislead our readers. Again, our apologies.

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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. Although FEMA paid for the environmental review, the grant applicants conducted it and it represents their opinions of their projects.

This eucalyptus forest at the North Oakland Sports Facility will be entirely destroyed.

These are the projects for which the Million Trees blog was created and for which it was named. Our opinion of these projects is unchanged by the environmental impact review. These projects will not achieve their stated objectives. Instead they will damage the environment and endanger the public.

The Draft Environmental Impact Statement (DEIS) for these projects was published by FEMA on April 25, 2013. It is available here. This is a brief description of the projects, our initial assessment of the DEIS, and information about how you can participate in the decision-making process which will ultimately determine the fate of these projects.

Description of the projects in the East Bay

Three different owners of public land have applied for these grants: University of California at Berkeley (UCB), City of Oakland, and East Bay Regional Park District (EBRPD). The projects of UCB and Oakland are similar and they are different from the projects of EBRPD, so we will describe them separately. These are the locations of the projects of UCB and Oakland, their acreage, and the estimated number of trees that will be removed by these projects:

Project Area	Project Acreage	Estimated Tree Removals*
UCB
Strawberry Canyon	56.3	22,000
Claremont	42.8	22,000
Frowning Ridge (in Oakland)	185.2	~~38,000~~ 32,000
Sub-Total	284.3	~~60,000~~ 54,000
Oakland
North Hills Skyline	68.3
Caldecott Tunnel	53.6
Sub-Total	121.9	~~25,735~~ 23,161
TOTAL	406.2	~~85,735~~ 77,161

*UCB estimated tree removals are provided by the DEIS; Oakland estimated tree removals are extrapolated assuming the same number of trees per acre (~~60,000~~ 54,000 ÷ 284.3 = ~~211~~ 190 trees per acre X 121.9 acres = ~~25,735~~ 23,161 trees removed by the projects of the City of Oakland)

UCB and Oakland plan to remove all non-native trees (eucalyptus, Monterey pine, acacia, etc.) and vegetation from the project area. All non-native trees up to approximately 24 inches in diameter at breast height (DBH) will be cut into wood chips and scattered on the ground of the project area. They estimate that 20% of the project area will be covered with wood chips to a depth of 24 inches. The DEIS estimates that the wood chips will take from 5 to 10 years to decompose. Larger trees will be cut up and scattered on the site.

Although UCB and Oakland do not intend to plant the project areas (unless erosion subsequent to tree removals demands seeding of native grasses and herbaceous plants), they predict that the project area will eventually become native grassland, scrub, and forest of coast live oak, California bay laurel, big-leaf maple, California buckeye, and California hazelnut. They predict that this conversion from non-native to native vegetation will be accomplished by “recruitment” from areas where these plants exist, into the areas where non-native plants and trees will be removed.

The stumps of eucalypts and acacia will be sprayed with an herbicide (Garlon with the active ingredient triclopyr) soon after the trees are cut down to prevent resprouting. An estimated 1 – 2 ounces of formulated herbicide will be required for each stump. Based on an experiment conducted by East Bay Regional Park District, an estimated 5% of the trees will require retreatment of subsequent resprouts. They are therefore predicting that between ~~703~~ 633 and ~~1,407~~ 1,266 gallons of herbicide will be required to prevent resprouting if only 5% of the stumps require retreatment as they claim. Monterey pines will not require herbicide treatment which reduces this estimate proportionately, although we are not provided with enough information to make this calculation. Herbicide (Roundup with active ingredient glyphosate) will also be sprayed to control non-native vegetation, but no estimates of quantities required for that purpose are provided by the DEIS.

The fire hazard mitigation projects of the East Bay Regional Park District were described in detail in its “Wildfire Hazard Reduction and Resource Management Plan” of 2009. EBRPD has applied for FEMA funding for about one-third of the “recommended treatment areas” in that plan. The FEMA DEIS considers all recommended treatment areas on EBRPD property, including those for which FEMA funding has not been requested. The recommended treatment areas for which FEMA funding has not been requested are called “Connected Action Acres.” The “Connected Action Acres” have undergone environmental review under California law (CEQA) and are therefore approved for implementation, which has already begun.

Project Area	Project Acres	Connected Action Acres	Total Acres	Estimated Tree Removals*
EBRPD
Sobrante Ridge	4.1	0
Wildcat Canyon	65.6	46.6
Tilden Park	132	194.2
Claremont Canyon	35.3	130.4
Sibley Volcanic	47.5	118.4
Huckleberry	17.8	.3
Redwood Park	58.4	92.8
Leona Canyon	4.6	0
Anthony Chabot	200	478.2
Lake Chabot	4.8	0
Miller-Knox	22.2	0
TOTAL	592.3	1,060.7	1,653	~~400,602~~ 409,176

*Estimated Tree Removals: Neither the DEIS nor EBRPD’s “Wildfire Plan” provides an estimate of the number of trees they plan to destroy. Furthermore their plans for tree removals are complex and variable. All non-native trees (eucalypts, Monterey pines, acacia) will be removed in some recommended treatment areas, but in most they will be thinned to spacing of 25 to 30 feet. The final Environmental Impact Report for the “Wildfire Plan” provides an estimate of the existing tree density of existing eucalypts on EBRPD property (page 392). Acres of eucalypts in the entire project area are provided by the DEIS (page 4.2-6). Our estimate of tree removals is based on those figures (1).

This eucalyptus forest at Chabot Park will be thinned to about 60 trees per acre.

This estimate does not include the Monterey pines and acacia that will be removed by EBRPD, for which inadequate information is available to provide an estimate.

EBPRD plans to cut the trees into wood chips which will be scattered to cover 20% of the project to maximum depth of 4-6 inches. The remainder of the wood will be burned in piles. Other non-native vegetation will be destroyed with herbicides and/or prescribed burns. These prescribed burns will not be funded by FEMA.

EBRPD’s plans to convert the project area to native vegetation are similar to the plans of both UCB and Oakland. EBRPD also does not plan to plant project areas with native vegetation. EBRPD also plans to use herbicides on the stumps of eucalypts and acacia which we estimate will require a mind-boggling ~~3,286~~ 3,356 to ~~6,572~~ 6,713 gallons of herbicide.

Million Trees’ assessment of these projects

We have surely exhausted your patience with the mind-numbing detail needed to describe these projects accurately. Therefore, we will provide only a brief outline of our assessment of these projects:

* These projects are more likely to increase the risk of wildfires than to reduce that risk.

By distributing tons of dead wood onto bare ground

By eliminating shade and fog drip which moistens the forest floor, making ignition more likely

By destroying the windbreak that is a barrier to wind driven fires typical of wildfires in California

By expanding the oak-bay woodland being killed by Sudden Oak Death, thereby adding more dead wood

* These projects will damage the environment by releasing hundreds of thousands of tons of carbon dioxide into the atmosphere from the destroyed trees, thereby contributing to climate change.

* These projects will endanger the public by dousing our public lands with thousands of gallons of toxic herbicides.

* Erosion is likely on steep slopes when the trees are destroyed and their roots are killed with herbicides.

* Non-native vegetation such as broom, thistle, and hemlock are more likely occupants of the unshaded, bared ground than native vegetation which will not be planted by these projects.

* Prescribed burns will pollute the air and contribute to the risk of wildfire, endangering lives and property.

* These projects are an inappropriate use of the limited resources of the Federal Emergency Management Agency which are for the expressed purpose of restoring communities destroyed by disasters such as floods and other catastrophic events and preparing communities for anticipated catastrophic events. Most of the proposed projects in the East Bay are miles away from any residences.

Update: Please visit THIS post for the current status of these projects. In summary: East Bay Regional Park District is implementing its original plans. City of Oakland is developing a new “Vegetation Management Plan.” UC Berkeley is suing to re-instate its FEMA grant funding so that it can implement its original plans.

How to participate in this decision-making process

The Hills Conservation Network has created a petition to oppose these projects. It is available HERE.

You can also participate in this decision. FEMA will host three public meetings in May 2013:

Tuesday, May 14, 2013, 2:00 p.m. – 4:00 p.m., Richard C. Trudeau Center, 11500 Skyline Boulevard Oakland, CA 94619

Tuesday, May 14, 2013, 6:00 p.m. – 8:00 p.m., Richard C. Trudeau Center, 11500 Skyline Boulevard Oakland, CA 94619

Saturday, May 18, 2013, 10:00 a.m. – 12:00 p.m., Claremont Middle School, 5750 College Avenue Oakland, CA 94618

Comments on this document must be submitted by June 17, 2013. You may submit written comments in several ways:

Via the project website: http://ebheis.cdmims.com
At the public meetings listed above
By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
By mail: P.O. Box 72379, Oakland, CA 94612-8579
By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars. So, please tell the people who work for you what you think of these projects.

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(1) Calculation of estimated tree removals by East Bay Regional Park District, Update: We understand the weakness of this estimate. Unfortunately, the DEIS does not provide sufficient information to improve its accuracy. Again, our apologies.

	Existing average density of eucalypts	650 trees per acre
minus	Planned average density of eucalypts	60 trees per acre
equals	Number of eucalypts removed	590 trees per acre
times	Total acres of eucalypts in project areas	824.3
equals	Total number of eucalypts removed	486,337
minus	Trees removed by UCB & Oakland	~~85,735~~ 77,161
equals	Eucalypts removed by EBRPD	~~400,602~~ 409,176

Vandalism by native plant advocates spreads to the East Bay

Girdling a tree by cutting through the outer layer of bark into the woody trunk eventually kills the tree by interrupting the channel through which the tree receives moisture and nutrients from its roots. The bigger the tree, the longer it takes to die, but the death of a girdled tree is inevitable.

Girdled trees, Bayview Hill, San Francisco

Between about 1998 and 2003, approximately 1,200 non-native trees in San Francisco were girdled by native plant advocates, including a few who were employees of the Recreation and Park Department’s so-called Natural Areas Program. This vandalism was finally stopped after one of the native plant advocates was caught and prosecuted and the Recreation and Park Department was embarrassed by the media coverage.

In addition to killing trees by girdling them, an entomologist has published a study which reports that Australian pests of eucalypts were intentionally and illegally introduced to California for the purpose of killing non-native eucalypts. These stories are told here.

More recently, we have learned that native plant advocates are also spraying non-native vegetation in public parks in San Francisco with herbicides, in violation of San Francisco’s policy regarding pesticide use. The people who are spraying these herbicides are not authorized to do so. They are not posting notices of the application of herbicides as required by law. They are also using herbicides that are not approved for use in San Francisco’s public properties. That story is told here.

Guerilla Gardening in the East Bay

These guerilla tactics have recently spread to the East Bay. Shortly before Christmas in December 2010, the neighbors of Garber Park (Evergreen Lane) in the Oakland hills were shocked when an enormous crane pulled up to their park and began to take down several huge eucalyptus trees. The neighbors had been told nothing about their destruction and they had no idea why they were being destroyed. A little frantic investigation revealed that one of their neighbors had requested that the trees be removed and, because she was willing to pay for their removal, the City of Oakland obliged her without any further consultation with her neighbors. Needless to say, many neighbors were not pleased with this undemocratic method of altering their neighborhood landscape. That story was reported in the Hills Conservation Network newsletter which is available here.

Eucalypts destroyed Garber Park, December 2010. Photo by Michael Wallman — Eucalypts destroyed in Garber Park, December 2010. Photo by Michael Wallman

The removal of those trees was the first step in an ambitious project to eradicate non-native plants and trees in Garber Park and replace them with native plants. That project is described on the website of the “Garber Park Stewards.”

Garber Park native plant "restoration" — Garber Park native plant “restoration”

On a recent visit to this wild 13-acre park, we saw little evidence of this effort. A rough, barely passable trail meanders through the park. Most of the trees are native oaks, bays, big leaf maples, and buckeyes. The tangled understory is a mix of natives (cow parsnip, horsetail, poison oak, etc) and non-natives (annual grasses, forget-me-knots, etc). The only evidence of the work of the stewards was typical of these projects: a small patch of bare ground with colored flags.

Now more eucalypts are being destroyed in Garber Park by girdling them. A chain saw was apparently used to cut into the cambium of the tree, which is the channel that carries nutrients from the roots of the trees to its canopy. Something was painted or sprayed into the cuts which we speculate is an herbicide that will accelerate the death of the trees.

We speculate that the girdling of these trees was not authorized by the City of Oakland. The neighbors of the park say they were not informed that the trees were going to be destroyed. Therefore, we assume that this is a case of vandalism which we hope will be reported to the police as such.

Eucalyptus stump and dead litter, Garber Park. If you were concerned about fire hazard, would you leave dead litter in the park for over 2 years?

We have no idea who girdled the trees in Garber Park. We therefore make no accusations. However, based on our experience in San Francisco, we speculate that whoever killed these trees believes their destruction will enhance the native plant restoration project. There are few eucalypts in this park. We saw only one that was not either girdled or a stump. We wonder what harm these few trees could do in this wild place. They are clearly not spreading

We repeat the Million Trees mantra

We say at every opportunity that we like native plants and trees and we encourage native plant advocates to plant them. We ask only that they stop destroying the plants and trees that have lived peacefully in the San Francisco Bay Area for over 100 years and are performing valuable ecological functions. We remind native plant advocates that we live in a democracy and that our public lands belong to all of us. If the landscape is to be permanently altered, a democratic process should be used to reach that conclusion.

Why does UCSF want to destroy the Sutro forest?

The short answer to that question is “I don’t know.” However, since many of the over 1,200 signers of the petition to University of California San Francisco (UCSF) to save the forest have asked this question, it seems that they deserve some answer. So, in this post, we will tell you the reasons that UCSF has given for its plans to destroy the forest.

UCSF makes two erroneous claims about the Sutro forest which it uses to justify its destruction. They claim that the forest is unhealthy and that destroying most of the forest will benefit the few trees that remain. They also claim that the forest is very flammable and that destroying most of the forest will make it less flammable. This is our response to these claims.

The Sutro Forest is not unhealthy

The Save Sutro website recently posted the professional opinion of two arborists who evaluated the Sutro forest and pronounced it healthy. We recommend that article as a starting point for anyone who wishes to be reassured on this important point.

The Draft Environmental Impact Report for UCSF’s planned project claims that the forest is old and dying. If we don’t beat it to the punch and kill it first, it will soon die without our help. An analogy comes to mind: “We had to destroy the village to save it,” which was the explanation given for the destruction of a village during the Vietnam War. It didn’t make sense then and it doesn’t make sense now.

The fact is, the Sutro forest is young and in the prime of its life. Eighty-two percent of the forest is blue gum eucalyptus. Blue gums live in Australia from 200 to 500 years. (1) They live toward the longer end of that range in milder climates such as the San Francisco Bay Area. The blue gum eucalypts were planted on Mount Sutro in the 1880s. It is still a young forest.

Another indication that the forest is young is that the individual trees are small by blue gum standards. The study plots used by the Draft Environmental Impact Report (DEIR) to calculate how much carbon is stored in the trees found that 77% of the trunks of the trees are 5 inches in diameter at breast height or less (if the study plots are representative of the entire forest, which is questionable). It also says that this species of eucalyptus grows very fast and that its trunk is 9 inches in diameter after only three years of growth. In other words, the DEIR claims that the trees are old and no longer growing, yet it says that most of the trees are very small and it intends to destroy the small trees, not the big ones. This is just one of many contradictions that we find in the DEIR.

There is little risk of wildfire in the Sutro Forest

One of the most powerful rhetorical tools used by native plant advocates to justify the destruction of our urban forest and motivate the public to pay for these expensive projects is the fear of fire. UCSF uses this strategy as well. Frankly, we doubt that UCSF believes it themselves because they applied for a Federal Emergency Management Agency (FEMA) grant to pay for this project in 2008. FEMA informed UCSF that there is little risk of wildfire on Mount Sutro. UCSF withdrew its grant application rather than answer FEMA’s questions.

FEMA asked UCSF to supply scientific evidence that the project would reduce fire risk despite the fact that the project would reduce fog condensation from the tall trees which moistens the forest floor, making ignition unlikely. FEMA also asked for scientific evidence that a wind driven wildfire would not be more likely after the destruction of the wind break provided by the forest. UCSF chose to withdraw its grant application, presumably because they could not answer those questions.

In 2010, UCSF applied for another fire hazard mitigation grant from the California Fire Safe Council. The Council has funded 150 such grants in California, but they denied UCSF’s application. That suggests that the California Fire Safe Council shares FEMA’s opinion.

You might ask, where is UCSF getting the money to pay for this project? We don’t know, but we consider that a legitimate and important question given that UCSF is a publicly funded enterprise.

UCSF may not be able to answer FEMA’s questions, but we can, using specific scientific studies. In 1987, 20,000 hectares burned in a wildfire in the Shasta-Trinity National Forest. The effects of that fire on the forest were studied by Weatherspoon and Skinner of the USDA Forest Service. They reported the results of their study in Forest Science. (2) They found the least amount of fire damage in those sections of the forest that had not been thinned or clear-cut. In other words, the more trees there were, the less damage was done by the fire. They explained that finding:

“The occurrence of lower Fire Damage Classes in uncut stands [of trees] probably is attributable largely to the absence of activity fuels [e.g., grasses] and to the relatively closed canopy, which reduces insolation [exposure to the sun], wind movement near the surface, and associated drying of fuels. Conversely, opening the stand by partial cutting adds fuels and creates a microclimate conducive to increased fire intensities.”

In other words the denser the forest,

The less wind on the forest floor, thereby slowing the spread of fire
The more shade on the forest floor.
- The less flammable vegetation on the forest floor
- The more moist the forest floor

All of these factors combine to reduce fire hazard in dense forest. Likewise, in a study of fire behavior in eucalyptus forest in Australia, based on a series of experimental controlled burns, wind speed and fire spread were significantly reduced on the forest floor.(3) Thinning the forest will not reduce fire hazard. In fact, it will increase fire hazard.

Jon E. Keeley of the USGS is a world-renowned expert on the fire ecology of California. We have read his recently published book (Fire in Mediterranean Ecosystems: Ecology, Evolution and Management, Cambridge University Press, 2011) and many of his articles. Anyone with a sincere interest in wildfire hazards in California would be wise to read these publications. Reference to Keeley’s work is conspicuously absent from the Draft EIR.

Keeley’s most recently published study of specific wildfires in the Wildland-Urban-Interface (WUI) of California is most relevant to consideration of wildfire hazard in the Sutro Reserve. (4) The authors studied the property damage resulting from specific wildfires in California “…and identified the main contributors to property loss.” Keeley and his colleagues found that steep slopes in canyons that create wind corridors were the best predictors of fire damage and that grassy fuels were more likely to spread the fire than woody fuels. Applying these observations to Mount Sutro, its topography is the biggest factor in the potential for wildfire and substituting the forest with grassland and scrub will result in more dangerous fuel loads.

Scripps Ranch fire, San Diego, 2003. All the homes burned, but the eucalypts that surrounded them did not catch fire. New York Times — Scripps Ranch fire, San Diego, 2003. All the homes burned, but the eucalypts that surrounded them did not catch fire.

UCSF and native plant advocates make allegations about the flammability of eucalypts by misrepresenting actual wildfires in the Bay Area. These allegations are addressed elsewhere on Million Trees, which we invite you to visit if you have more questions:

All pain, no gain

So, if the forest is healthy and destroying it does not reduce fire hazards, how can UCSF justify all the damage this project will do to the environment:

- Releasing thousands of tons of carbon dioxide into the atmosphere that are stored in the trees and significantly reducing the ability of the forest to sequester carbon in the future, thereby contributing to climate change.
- Increasing air pollution by reducing the ability of the forest to absorb air pollutants.
- Using pesticides to destroy the vegetation in the understory and preventing the trees that are destroyed from resprouting.
- Destroying the food and cover of the birds and animals that live in the forest.
- Eliminating the noise and wind barrier that protects UCSF’s neighbors
- Increasing the risk of wildfire by eliminating the windbreak, reducing the moisture in the forest, and littering the forest with the dead logs and wood chips of the trees that are destroyed.

We can’t imagine why UCSF wants to destroy its forest. We understand why native plant advocates support this project because they are making the same demands all over the Bay Area. They want land managers to destroy non-native trees because they believe that destroying them will result in the return of native plants. The UCSF project makes no commitment to plant native plants after the forest is destroyed, with the exception of a few small areas and then only if “money is available.” Native plants will not magically emerge from the wood-chip tomb on the forest floor. Is it possible that UCSF shares the fantasy of native plant advocates that this destructive project will result in a landscape of grassland and chaparral which is the native landscape on Mount Sutro? Surely a scientific institution of such distinction knows better. Or it should.

Here are the things you can do to help us save this beautiful forest:

Sign the petition to save the forest. Available here.
Attend and speak at a UCSF hearing about the project: Monday, February 25, 2013, 7 pm, Millberry Union Conference Center, 500 Parnassus Ave, Golden Gate Room
Submit a written public comment by 5 PM, March 19, 2013 to UCSF Environmental Coordinator Diane Wong at EIR@planning.ucsf.edu or mail to UCSF Campus Planning, Box 0286, San Francisco, CA 94143-0286. Include your full name and address.
Write to the Board of Regents to ask why a public medical institution is engaging in such a controversial, expensive, and environmentally destructive act. Address: Office of the Secretary and Chief of Staff to the Regents, 1111 Franklin St., 12^th Floor, Oakland, CA 94607  Fax: (510) 987-9224
Subscribe to the website SaveSutro.com for ongoing information and analysis.

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(1) Eucalypt ecology: Individuals to ecosystems, by Jann Elizabeth Williams, John Woinarski ,Cambridge University Press, 1997

(2) Weatherspoon, C.P. and Skinner, C.N., “An Assessment of Factors Associated with Damage to Tree Crowns from the 1987 Wildfires in Northern California,” Forest Science, Vol. 41, No 3, pages 430-453

(3) Gould, J.S., et. al., Project Vesta: Fire in Dry Eucalyptus Forests, Commonwealth Scientific and Industrial Research Organisation and Department of Environment and Conservation, Western Australia, November 2007

(4) Alexandra Syphard, Jon E. Keeley, et. al., “Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildire.” PLOS ONE, March 18, 2012