Tag: Federal Emergency Management Agency (FEMA)

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.

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.
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
  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 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:

  1. Via the project website: http://ebheis.cdmims.com
  2. At the public meetings listed above
  3. By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
  4. By mail: P.O. Box 72379, Oakland, CA 94612-8579
  5. 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

FEMA sees through the smokescreen

The Federal Emergency Management Agency (FEMA) has seen through the smokescreen that native plant advocates have created as a pretext for destroying non-native trees in the San Francisco Bay Area.  Native plant advocates claim that destroying non-native trees will reduce fire hazard.  As taxpayers, and as fans of all trees, we commend FEMA for preserving their limited resources for legitimate disaster mitigation.
 
In February 2010, UC San Francisco (UCSF) announced that it had withdrawn its application for FEMA funding to destroy most of the eucalypts on 14 acres of the Sutro Forest.  When making that announcement UCSF explained that FEMA would require a comprehensive Environmental Impact Study before the grant would be awarded which would result in a two-year delay in the implementation of the project.  UCSF preferred to pay for the project with its own funds rather than delay it during the environmental review.  Therefore, UCSF withdrew its application for FEMA funding.  Since then, UCSF has proceeded with its plans, expanding them to 40 acres, and continues to claim that there is extreme fire hazard in the Sutro Forest which it claims will be mitigated by the project.

Sutro Forest on a typically foggy day in late summer. Courtesy SaveSutro.wordpress.com

We now know there is more to the story than is revealed by UCSF’s announcement.  The neighbors of the Sutro Forest who have been trying to save their forest for over a year, have since obtained correspondence from FEMA regarding UCSF’s grant applications through a public records request.    The correspondence with FEMA indicates that:

  • UCSF misrepresented and exaggerated the fire hazard on Mount Sutro by rating it as “extreme.”  FEMA confirmed with the state’s fire authority that fire hazard on Mount Sutro is moderate, CAL Fire’s lowest rating of fire hazard.  (1) 
  • FEMA asked UCSF to explain how fire hazard would be reduced by eliminating most of the existing forest, given that: (2)
    • Reducing moisture on the forest floor by eliminating the tall trees that condense the fog from the air could increase the potential for ignition, and
    • Eliminating the windbreak that the tall trees provide has the potential to enable a wind-driven fire to sweep through the forest unobstructed.
  • FEMA asked UCSF to consider alternatives to its project, which would have the potential to mitigate fire hazard to the built environment by creating defensible space around buildings, structural retrofits, and vegetation management projects. (3)

UCSF has elected to ignore this advice from FEMA, choosing instead to proceed with its project as originally designed using  its own funds at a time of extreme budgetary limitations.  Clearly this is an indication that fire hazard mitigation is not the purpose of their project.  UCSF chooses to increase fire hazard rather than reduce it, putting themselves and their neighbors at risk.

FEMA is now engaged in a comprehensive Environment Impact Study of four similar projects in the East Bay hills that propose to destroy hundreds of thousands of trees.  The applicants are UC Berkeley, the City of Oakland, and East Bay Regional Park District.  Fire hazard in the East Bay is greater than in San Francisco because the summer is hotter, the frequency of Diablo winds is greater, and there are rare deep freezes that cause some non-natives to die back, creating dead leaf litter on the forest floor.  However, the remaining issues are the same as those on Mount Sutro: 

  • The loss of tall trees will reduce moisture on the forest floor and eliminate the shade that maintains that moisture.  The remaining native landscape will be predominantly grassland studded with scrub, chaparral, and short native trees in sheltered ravines.  This will be a flammable landscape, not less flammable than the existing landscape.
  • The loss of the windbreak provided by the tall trees will enable a wind-driven fire to travel unhindered through the community.
  • The projects in the East Bay hills do not provide defensible space around homes, which would reduce fire hazard to homes and those who live in them, the stated purpose of FEMA grants.

We hope that FEMA will see the similarity between the East Bay projects and those in San Francisco and advise the applicants in the East Bay to revise their projects so that they are appropriately aimed at creating defensible space around homes.  Destroying hundreds of thousands of trees will not make us safer.  In fact, it is likely to increase the risk of wildfire.

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Sources:

(1) Excerpt from FEMA’s letter of October 1, 2009, regarding UCSF’s grant applications:

“In its response to provide a clarification of the wildfire hazard, UCSF inaccurately interprets a map, provides inadequate details regarding the history of wildfires in the Sutro Forest, and provides a simplistic and ineffective comparison of the wildfire hazard in the Sutro Forest to the hazard in other areas that have burned in the San Francisco Bay Area…The 2007 FHSZ [Fire Hazard Severity Zones] map shows the Sutro Forest to have a “Moderate” wildfire hazard in the 2007 FHSZ maps.  “Moderate” is the lowest of the three fire hazard severity zones…”

(2) Excerpt from FEMA’s letter of October 1, 2009, regarding UCSF’s grant applications:

“Commenters argue that the proposed projects would increase wildfire hazard by removing some of the material that collects fog drip and keeps the forest moist and resistant to ignition and fire, thus allowing the forest to dry out more easily and increase the relative hazard for ignition.  Can UCSF specifically address this comment and describe how overall forest moisture content will change after implementation of the proposed projects?  Please provide scientific evidence to support any claims.”

“Additionally, several of these unsolicited public comments have stated that the proposed projects could result in changed wind patterns on Mount Sutro which could also increase the wildfire hazard in the forest.  New wind patterns could reduce biomass moisture as well as reduce the effective windbreak created by the current forest.  These comments argue that the effective windbreak created by the existing forest limits the potential for wildfire spread in the forest and the immediately surrounding area.  As UCSF has stated, winds are a contributing factor in wildfires.  Provide a citable and logical defense regarding how the proposed projects, and the resulting changes in wind patterns, would not result in an increase in the wildfire hazard in the Sutro Forest.”

(3) “Assuming that UCSF has been able to establish a clear need for wildfire mitigation activities, UCSF must conduct a more thorough analysis to identify alternatives to the proposed projects that could mitigate wildfire hazard in the Sutro Forest to the vulnerable built environment.  These alternatives must be technically, economically, and legally practical and feasible and can include activities not eligible for FEMA grant funding.  As described in FEMA’s Wildfire Mitigation Policy…wildfire mitigation grants are available for defensible space, structural retrofit, and vegetation reduction projects.  It would seem reasonable that alternatives to the proposed projects could include defensible space or retrofit projects.”    (emphasis added)