FEMA – Conservation Sense and Nonsense

Sierra Club cannot hide behind its smokescreen

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

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

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

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

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

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

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

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

A study by scientists in Tasmania found that the leaves of blue gum eucalypts were more resistant to ignition than other species of Tasmanian vegetation tested. The study credits the “hard cuticle” of the leaf for its ability to resist ignition. (1)
The National Park Service, which has destroyed tens of thousands of eucalypts and other non-native trees, states that eucalyptus leaves did not ignite during a major fire on Mount Tam. (2)
The leaves of native bay laurel trees contain twice as much oil as eucalyptus leaves (3) and the fuel ladder to their crowns is much lower than eucalyptus, increasing the risk of crown fires. The “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District states explicitly that bay laurel is very flammable and recommends selective removal.
Eucalyptus contributed more fuel to the 1991 fire in Oakland because a deep and prolonged freeze the winter before the fire caused eucalyptus and other exotic vegetation to die back. The dead leaf litter was not cleaned up, which contributed to the fire hazard. Such deep freezes are rare in the Bay Area. There has not been such a freeze for 25 years and another is unlikely in the warming climate.
Eucalyptus logs line the roads where UC Berkeley has destroyed trees. Do they look less flammable than living trees?
Ordinarily, eucalyptus does not contribute more fuel to the forest floor than native oak-bay woodland. This is confirmed by the National Park Service, which includes logs in the calculation of fuel loads. (2) Logs are extremely difficult to ignite. The so-called “fire hazard mitigation projects” are leaving all the eucalyptus logs on the ground when the trees are destroyed, suggesting that they aren’t considered a fire hazard. The National Park Service also separates the fuel loads of oaks and bays, which when combined are equal to the fuel load of eucalyptus. Since our native woodland in the East Bay is a mixture of oaks and bays, it is appropriate to combine them when comparing their fuel loads to eucalyptus.
Eucalypts are sometimes blamed for casting more embers than native trees because they are taller than the oak-bay woodland. However, redwoods are as tall, if not taller, and they were also observed burning in the 1991 fire: On Vicente Road, “Two redwoods up the street caught fire like matchsticks.” (4) Yet, the Sierra Club is not suggesting that redwoods be destroyed to eliminate the risk of casting embers.

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

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

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

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

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

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

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

The FEMA projects do not provide for any planting or funding for planting after the trees are removed. FEMA’s mission is fire hazard mitigation, not landscape transformation. The scientists who evaluated the FEMA projects said that a native landscape is not the likely result of the project: “However, we question the assumption that the types of vegetation recolonizing the area would be native. Based on conditions observed during site visits in April 2009, current understory species such as English ivy, acacia, vinca sp., French broom, and Himalayan blackberry would likely be the first to recover and recolonize newly disturbed areas once the eucalyptus removal is complete. These understory species are aggressive exotics, and in the absence of proactive removal there is no evidence to suggest that they would cease to thrive in the area, especially the French broom which would be the only understory plant capable of surviving inundation by a 2-foot-deep layer of eucalyptus chips.” (5)
The US Forest Service evaluation of the FEMA projects stated that the resulting landscape would be more flammable than the existing landscape: “Removal of the eucalyptus overstory would reduce the amount of shading on surface fuels, increase the wind speeds to the forest floor, reduce the relative humidity at the forest floor, increase the fuel temperature, and reduce fuel moisture. These factors may increase the probability of ignition over current conditions.” (6)
The US Forest Service evaluation predicts that the resulting landscape will be “a combination of native and non-native herbaceous and chaparral communities.” Despite the overwhelming evidence that wildfires in California start and spread rapidly in herbaceous vegetation such as dry grass, the myth persists that all non-native trees must be destroyed to reduce fire hazards. An analyst at CAL FIRE has explained to the Center for Investigative Reporting that the reason why wildfires were so extreme this summer is because of the heavy rains in December 2014, which grew a huge crop of grass: “The moisture did little to hydrate trees and shrubs. But it did prompt widespread growth of wild grasses, which quickly dry out without rain. ‘They set seed, they turn yellow and they are done,’ said Tim Chavez, a battalion chief and fire behavior analyst with CAL FIRE. ‘All that does is provide kindling for the bigger fuels.’” (7) We know that more dry grass starts more wildfires, yet the Sierra Club demands that we destroy the tree canopy that shades the forest floor and produces leaf litter, which together suppress the growth of the grasses in which fires ignite.
The claim that native plants are “naturally fire resistant” is ridiculous. Native vegetation in California—like all Mediterranean climates—is fire adapted and fire dependent. The wildfires all over the west this summer occurred in native vegetation. There are over 200 species of native plants in California that will not germinate in the absence of fire and persist for only 3-5 years after a fire. (8) Although all native vegetation is not equally flammable, many species are considered very flammable, such as coyote brush, bay laurel, and chamise. To say otherwise is to display an appalling ignorance of our natural history.
When did “environmentalism” devolve into demonizing trees?
There is no evidence that the destruction of our urban forest will result in greater “biodiversity.” There are many empirical, scientific studies that find equal biodiversity in eucalyptus forest compared to native forests. There are no studies that say otherwise, yet the Sierra Club and their nativist friends continue to make this claim without citing any authority other than their own opinions. (9, 10, 11) Bees, hummingbirds, and monarch butterflies require eucalyptus trees during the winter months when there are few other sources of nectar. Raptors nest in our tall “non-native” trees and an empirical study finds that their nesting success is greater in those trees than in native trees.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Obfuscation and insincere backpedaling

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

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

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

Dickinson, K.J.M. and Kirkpatrick, J.B., “The flammability and energy content of some important plant species and fuel components in the forests of southeastern Tasmania,” Journal of Biogeography, 1985, 12: 121-134.
“The live foliage proved fire resistant, so a potentially catastrophic crown fire was avoided.” http://www.nps.gov/pore/learn/management/upload/firemanagement_fireeducation_newsletter_eucalyptus.pdf
Ron Buttery et. al., “California Bay Oil. I. Constituents, Odor Properties,” Journal Agriculture Food Chemistry, Vol. 22, No 5, 1974.
Margaret Sullivan, Firestorm: the study of the 1991 East Bay fire in Berkeley, 1993
URS evaluation of UCB and Oakland FEMA projects
FEMA DEIS – evaluation of US Forest Service
https://www.revealnews.org/article/rampant-california-wildfires-can-be-blamed-on-last-decembers-rain/?utm_source=Reveal%20Newsletters&utm_campaign=2d4c52ebf5-The_Weekly_Reveal_09_24_159_23_2015&utm_medium=email&utm_term=0_c38de7c444-2d4c52ebf5-229876797
Jon Keeley, Fire in Mediterranean Ecosystems, Cambridge University Press, 2012
https://milliontrees.me/2011/02/04/biodiversity-another-myth-busted-2/
https://milliontrees.me/2013/04/09/biodiversity-of-the-eucalyptus-forest/
https://milliontrees.me/2013/11/22/invertebrates-such-as-insects-are-plentiful-in-the-eucalyptus-forest/
See Table 2.1 in Appendix F: http://www.fema.gov/media-library-data/1416861356241-0d76d1d9da1fa83521e82acf903ec866/Final%20EIS%20Appendices%20A-F_508.pdf
William Russell and Joe McBride, “Vegetation Change and Fire Hazard in the San Francisco Bay Area Open Spaces,” Landscape and Urban Planning, 2003

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

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

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

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

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

Hills Conservation Network

Preserving the East Bay Hills

March 6, 2015

For Immediate Release

HCN announces lawsuit against FEMA EIS

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

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

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

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

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

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

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2014 Wrap-Up and 2015 Preview

Our last post of 2014 will summarize wins and losses in our effort to save our urban forest and preview the local issues that remain unresolved. 2014 has been a year of many accomplishments, but there have been disappointments as well.

2014 Accomplishments

Good news always comes first! We are most grateful for the hard work of the San Francisco team with whom we collaborate. After herculean effort, they completed most of the presentations to the members of the Board of Supervisors about the forthcoming approval process for the Environmental Impact Review of San Francisco’s Natural Areas Program, which has been in the works for eight years…and still counting. We are advocating for the Planning Commission and the Board of Supervisors to approve the “environmentally superior” Maintenance Alternative, which would enable the Natural Areas Program to maintain the native gardens they have created in the past 15 years, but would prohibit expansion of those gardens. The Maintenance Alternative could save about 18,500 healthy non-native trees from being needlessly destroyed and significantly decrease herbicide use in our parks.

Because native plant advocates have succeeded in convincing many politicians that their projects are “science-based,” the San Francisco team was particularly glad to have three lectures at the Commonwealth Club by academic scientists, which challenged the unfounded assumptions of the native plant ideology:

Dr. Scott Carroll, “Conciliation Biology: An Approach to Conservation that Reconciles Past, Present and Future Landscapes in Nature”
Professor Arthur M. Shapiro, “Ecological Communities and the March of Time”
Professor Joe R. McBride, “The History, Ecology and Future of Eucalyptus Plantations in the Bay Area”

These presentations were very well attended, including by native plant advocates. They were entirely successful from our standpoint, though they seem to have had little influence on the opinions of native plant advocates, many of whom seemed not to understand the scientific information being presented.

In March 2014, UCSF announced that they have put their plans to destroy most trees on Mount Sutro on indefinite hold. This decision was made in response to the public’s overwhelming opposition to these plans during the public comment period for the Draft Environmental Impact Report in March 2013. However, UCSF has destroyed about 1,200 trees during the past 18 months which they claimed would mitigate immediate hazards. UCSF has also made a commitment to not using herbicides on Mount Sutro. UCSF has provided no estimated time frame for announcing a new plan. Please visit Save Mount Sutro Forest for a more detailed description of that announcement. We consider this a “holding pattern” because we know that UCSF is under constant pressure from those who want the Sutro Forest to be destroyed.

Invasion biology is being revised by academic scientists who inform us that empirical studies do not support the hypotheses of invasion biology. Here are a few of the highlights from the scientific literature:

Climate change is rendering the concept of “native” irrelevant. The ranges of plants and animals have changed and will continue to change in the future, as they have many times in the past 500 million years.
Plants and animals from places with long, stable evolutionary histories have adaptive advantages over those with a shorter evolutionary history. It may be futile to attempt to eradicate species with such adaptive advantages.
There is no evidence that biodiversity has decreased anywhere in the world as a result of introduced species.

Likewise, mainstream media has become more even-handed in its coverage of invasion biology and native plant “restorations.” Here are a few specific examples:

National Geographic has published a critique of invasion biology by Emma Marris. This represents a change of direction for National Geographic which has been consistently supportive of invasion biology in the past.
The San Francisco Examiner published an op-ed about the Natural Areas Program, which was critical of both the program and its cost.
The Nature Conservancy explicitly stated on its website that it is not necessary to eradicate eucalyptus in California.

2014 Disappointments

The publication of the final Environmental Impact Statement for FEMA projects in the East Bay Hills was the biggest disappointment of 2014. There were over 13,000 public comments on the draft and they were overwhelmingly opposed to the proposed projects. Yet, the projects are fundamentally unchanged by the final EIS, which will be officially approved by a “Decision of Record” on January 5, 2015. We are grateful to the Hills Conservation Network for their continuing opposition to these projects and we urge our readers to support their effort.

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

We were outraged by UC Berkeley’s destruction of hundreds of non-native trees on their property in August 2014, prior to the approval of these FEMA grants. And we were also appalled by the letters sent to FEMA by elected officials in the East Bay in July, demanding that funding be immediately released and approved for use to destroy all non-native trees on their properties.

In San Francisco, our biggest disappointment of 2014 was the approval of the revised Recreation and Open Space Element (ROSE) of the city’s General Plan, which has committed the city to managing all open space as “natural areas.” The ROSE defines “natural areas” so broadly that it includes not only areas that currently contain existing remnants of SF’s pre-settlement habitat, but also areas that could support native plants if they were planted there, or, in other words, nearly all open space in SF, including people’s back yards. This policy commits the city to managing nearly ALL open space in San Francisco, including that in private hands, the same way as the Natural Areas Program manages its lands. As disappointing as that decision was, it was also instrumental in producing one of the biggest accomplishments of 2014. We were successful in convincing the State of California to decline to fund a grant application which would have implemented the plans to convert all open space in San Francisco to native plant gardens. That so-called “biodiversity program” continues, but is presumably handicapped by the loss of that fund source.

Looking forward in 2015

In the past six months, the San Francisco team has devoted a great deal of time and effort to influencing the city’s Urban Forestry Council (UFC) to adopt “best management practices” that would discourage the destruction of healthy trees. The UFC has hosted a “listening series” of presentations by those who advocate for the eradication of eucalyptus forests as well as those who are opposed to that destruction. Native plant advocates have introduced new justifications for destroying the eucalyptus forests:

They claim that eucalyptus forests are dying of disease, drought, old-age, etc. We have sought the advice of many professional arborists and academic ecologists who assure us these claims are inaccurate.
They claim that the health of the eucalyptus forests would be improved by radical “thinning.” The scientific literature informs us that mature forests do not benefit from thinning because mature trees are unable to respond positively to increased light and wind. Thinning is only beneficial to young trees and even then, the disturbance can damage the trees that remain. Radical thinning of the mature eucalyptus forest is likely to destroy the few trees that will remain.

The UFC has completed its listening series and will probably reach its conclusions in 2015. Based on the meetings we have attended and the conversations we have had with members of the UFC, we are not hopeful about the outcome. They seem to be sympathetic to the demands of those who want the non-native forests of San Francisco to be destroyed. In that case, their “best management practices” could be specifically supportive of the plans of the Natural Areas Program to destroy 18,500 trees in San Francisco and Pacifica. If you would like to express your opinion to the Urban Forestry Council, you can write to them here: SFUrbanForestCouncil@sfgov.org.

We also expect the final Environmental Impact Report for San Francisco’s Natural Areas Program to be published in 2015. We will make our best effort to convince the Planning Commission and the Board of Supervisors to approve the Maintenance Alternative. However, we should all understand that the lack of an approved EIR does not seem to have prevented the Natural Areas Program from destroying trees whenever and wherever they wish. Many trees (perhaps a few hundred) in Glen Canyon Park, McLaren Park and Pine Lake in Stern Grove have been destroyed without an approved Environmental Impact Report. In other words, the Environmental Impact Report seems increasingly irrelevant to what is actually being done in our parks.

A few of the trees destroyed recently in Pine Lake "natural area" — A few of the trees destroyed recently in Pine Lake “natural area”

The President of the San Francisco Forest Alliance, Carolyn Johnston, ran for a seat on the Executive Committee of the San Francisco Group of the Sierra Club. If you follow the controversy about the Natural Areas Program in San Francisco, you may be aware of the Sierra Club’s role in supporting the nativist agenda (HERE is an example of their role). Carolyn lost by only 6 votes. If everyone in San Francisco who abandoned the Sierra Club because of its support for turning urban parks into native plant gardens, would renew their membership, maybe we could win a seat next year. We are grateful to Carolyn for running.

We also expect a final response from the California Invasive Plant Council to our request that Blue Gum eucalyptus be removed from its list of “invasive” plants.

In summary

Science is rapidly revising the unfounded assumptions of invasion biology and climate change is making the concept of “native” meaningless. But these realities are having no apparent influence on public policy, which seems to be immune to such facts. Popular culture always lags behind science.

Million Trees is changing its emphasis in response to these political realities. In 2015, we will focus on the science that is revising invasion biology because that’s where progress is being made. This type of research is both difficult and time-consuming for us because we do the background reading to understand the scientific literature and produce accurate reports that are accessible to the layperson. We therefore expect to publish new articles only once each month in 2015. As always, we invite guest authors to step forward with news of new developments that we are not covering.

Thank you for your readership in 2014 and for any help you gave us in 2014 on our various initiatives. We wish you all a Happy New Year in 2015.

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

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

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

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

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

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

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

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

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

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

Thanks again for all your support,

Hills Conservation Network

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

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

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

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

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

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

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

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

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

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

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

Media coverage of FEMA projects: The good, the bad, and the ugly

Anise Swallowtail butterfly in non-native fennel

The public comment period for the FEMA project in the East Bay that proposes to destroy nearly half a million trees will close on Monday, June 17, 2013, at midnight. If you want to express your opinion of these projects, it’s time to do so. Detailed information about the projects and how to comment on them is available HERE.

The projects have drawn quite a bit of media coverage, starting with Beyond the Chron blog in mid-May and quickly picked up by many other internet sources of information. Most of those internet sources referred their readers to the Million Trees blog for more information. In May we had over 12,000 visitors to our articles about these projects.

Both the Oakland Tribune and the San Francisco Chronicle covered the story. The Tribune coverage was appallingly inaccurate and biased. The Chronicle coverage was more balanced than it usually is about native plant restoration projects, which the Chronicle usually supports without reservation.

The winner of the booby prize for balanced and fair reporting of the projects goes to the Sierra Club Yodeler which expressed its unqualified support for the projects at the same time it demonstrated total ignorance of the projects (or chose to misrepresent them):

Sierra Club said, “We want to avoid past mistakes, when agencies simply stripped off vegetation and then walked away, leaving the land clear for exotic and even more-flammable vegetation.” This is precisely what these projects plan to do…destroy everything then walk away without planting anything.
Sierra Club said, “The Park District is now implementing that program, and we are monitoring the progress.” If they are monitoring that program, why don’t they know what the Park District is doing?
Sierra Club said, “The preferred alternative involves application of the herbicide glyphosate (trade name Roundup) to the stumps to prevent re-sprouting. There is no practical way to eliminate eucalyptus infestations without herbicide, and glyphosate is relatively low in toxicity.” The Sierra Club is simply wrong. These projects will use Garlon (with active ingredient triclopyr) and/or Stalker (with active ingredient imazapyr)—not glyphosate (Roundup)–to prevent the trees from resprouting. Both products are rated by the EPA as more toxic, more persistent, and more mobile in the soil than glyphosate. Glyphosate (Roundup) will be foliar sprayed on non-native vegetation. Recent studies report that glyphosate (Roundup) is not a benign pesticide.

There are some scathing comments on the Yodeler article from people who know enough about the project plans to inform the Club that they have run off the rails…into the weeds!! The Club seems not to have noticed this attempt to set them straight. When someone called them weeks later to ask about the projects, they repeated the same misinformation to the caller.

(Update: One of our readers informed the Sierra Club of the inaccuracy of its Yodeler report about the FEMA projects in the East Bay (see comment below). We are pleased to report that the Sierra Club has revised its Yodeler report on June 19, 2013. It now acknowledges that native plants will not be planted by these projects. Consistent with the Draft Environmental Impact Statement for these projects, the Yodeler now claims that native plants will be “recruited” into the areas in which non-native plants and trees will be destroyed.

We think that is an unlikely outcome of these projects and FEMA’s environmental consultant agrees with us about that (explained here). However, at least the Yodeler article is now consistent with the written plans for the project.

The Yodeler also acknowledges the use of Garlon to kill the roots of the trees that will be destroyed.

Thanks to our readers for alerting the Sierra Club to the inaccuracy of their description of this project. We are sorry that the Sierra Club continues to support the project now that they have a better understanding of the written plans. 6/19/13)

Owl nesting in eucalyptus, courtesy urbanwildness.com

On the positive side of the ledger, we commend the East Bay Express for its article about these projects. The author deserves credit for actually reading about the projects before she wrote her report!!! She read the letter from FEMA’s environmental consultant which we reported to our readers here. In a nutshell, the consultant said that UC Berkeley’s project could increase fire hazards by leaving a 2-foot wood chip mulch on the ground and that conversion to a native landscape was an improbable outcome of the project since nothing will be planted.

Our personal favorite for coverage of this project is Nathan J. Winograd’s article, “Biological Xenophobia: The Environmental Movement’s War on Nature,” which was published by the Huffington Post. Mr. Winograd is highly qualified to express his opinion of these projects. He has devoted his personal and professional life to the welfare of animals. He is best known for his advocacy for “no-kill” shelters for our animals. He was the lawyer for the SPCA in San Francisco when the GGNRA started to destroy non-native trees and fence the public out of their properties to protect their fragile native plant museums. So, he has been a long-time observer of the destructive and restrictive consequences of native plant projects. He was prompted to write this article by this latest round of destruction, that is, the FEMA projects in the East Bay.

Here are a few choice phrases from Mr. Winograd’s excellent article:

“Invasion biologists believe that certain plants and animals should be valued more than others if they were at a particular location ‘first.” When the species that were there ‘first’ are in the same habitat with a species that came later, they assert that the latter should be eradicated.”

“And the nativist movement is getting worse and increasingly violent, both in rhetoric (fish they don’t value are called ‘missiles with fins’) and in deeds. At a time of climate change, in a country that needs more trees, not less, nativists in the San Francisco Bay Area are proposing the clear cutting of upwards of half a million trees on San Francisco’s Mount Sutro and in the Oakland and Berkeley hills as part of their ongoing war against the Eucalyptus. After the trees are clear-cut thousands of gallons of toxic herbicides, will be spread throughout wildlife corridors in order to prevent resprouting.”

“An authentic environmentalism would not advocate that humans seek out and destroy living things for simply obeying the dictates of the natural world, such as migration and natural selection. It would not condone the killing of those plants and animals who find themselves in parts of the world where, for whatever arbitrary reason — be they economic, commercial or aesthetic — some humans do not want them to be. An authentic environmentalism would not exacerbate suffering, call for killing and seek the destruction of natural places.”

“Indeed, “invasion biology” is a faux environmentalism, used to disguise the ugly truth about what is really motivating its adherents: an intolerance of the foreign that we have rejected in our treatment of one another, a biological xenophobia that seeks to scapegoat plants and animals for the environmental destruction caused by one species and one species alone: humans.”

There are nearly 500 comments on Mr. Winograd’s article and they are as interesting as the article itself. They are a microcosm of this debate between nativists and those with a more cosmopolitan view of nature. We aren’t disinterested observers, so our opinion of the comments of nativists may not be entirely objective. However, we find many of their comments condescending and uninformed, a contradictory mix of sentiments.

We thank our readers for informing themselves about the FEMA projects and we hope that you now have the information you need to write your public comment by the deadline, June 17, 2013. Here is where you can send your comment:

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.

The Sierra Club instructs FEMA

Those who are still members of the Sierra Club, but are concerned about the Club’s endorsement of projects to destroy trees and use toxic poisons to kill their roots, might be interested in the Club’s public comment (scroll down to Appendix F “Written Comments) to Federal Emergency Management Agency (FEMA) in preparation for the Environmental Impact Study of four such projects in the East Bay hills.

The Chairman of the Bay Area Chapter of the Sierra Club begins by asking FEMA to ignore those who are critical of these projects: “1. We urge FEMA to discount the views of any individual or group that uses sophomoric name calling tactics in the press or in their FEMA scoping comments to categorize people or advocacy groups as ‘nativists’ (or other similar pejorative labels)…”

Apparently the author does not consider calling someone “sophomoric” an example of “name-calling.” Webster defines “sophomoric” as “intellectually pretentious and conceited but immature and ill-informed.” Hmmm…that sounds pretty insulting to us.

We don’t use the word “nativist” here on Million Trees, not because we consider it an inaccurate description, but rather because we have been told that it offends native plant advocates. Since our goal on Million Trees is to inform, rather than to offend, we stick with the clunky phrase, “native plant advocates.”

What about “other similar pejorative labels?” Does the Club also object to the phrase “native plant advocates?” We are at a loss to arrive at some phrase that would appease them. For the moment, we’ll stick with “native plant advocates” to describe those who advocate for the restoration of native plants to our public lands. After all, the Sierra Club freely admits its preference for native plants in their letter: “We obviously prefer our local native species and plant communities when compared to…introduced species.”

The Sierra Club also instructs FEMA to put the restoration of native plant communities on an equal footing with fire hazard mitigation: “We also urge FEMA to ensure that natural resource protection is given equal status with fire hazard reduction work when final projects are developed.” The letter provides a detailed description of the “natural resource protection” it has in mind. In this context, that phrase translates to “native plant restoration.”

Since the stated purpose of FEMA’s pre-disaster and hazard mitigation grants is to reduce fire hazard to the built environment and the humans who live in it, this doesn’t seem an appropriate request. FEMA’s legal and fiduciary responsibility is to respond to disasters when they occur and to reduce the potential for disasters in the future. FEMA seems to have its hands full doing just that. FEMA’s assigned mission does not include native plant restoration.

As we observed in our post “Open Letter to the Sierra Club,” the Club tends to ignore the fact that the tree destruction for which they advocate requires the use of toxic herbicides. However, in its public comment letter to FEMA, the Club acknowledges the use of such herbicides and endorses their use: “We are not currently opposed to the careful use of Garlon…” On our page about “Herbicides,” we report that the EPA classifies Garlon as “hazardous” and we cite the laboratory research on Garlon, indicating that it is harmful to many species of animals and is mobile in soil and water.

We hope that FEMA will maintain its mandated focus on hazard mitigation, its sole responsibility to the taxpayers. If the taxpayers wish to fund native plant restorations, they should do so by designating an appropriate fund source. FEMA is not an appropriate fund source for native plant restorations.