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

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

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

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


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

Draft EIS

Prepared by Christopher Adams


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


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

Specific Comments:

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

FEMA comment - Adams 1 copy

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


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

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

FEMA comment - Adams 2 copy

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

FEMA comment - Adams 3 copy

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

(1) EPA 738‐R‐06‐007, 2006

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

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

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


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.


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*

  Strawberry Canyon





  Frowning Ridge (in Oakland)


38,000 32,000



60,000 54,000

  North Hills Skyline


  Caldecott Tunnel




25,735 23,161



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*

Sobrante Ridge



Wildcat Canyon



Tilden Park



Claremont Canyon



Sibley Volcanic






Redwood Park



Leona Canyon



Anthony Chabot



Lake Chabot










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.


(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.



(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)

Sudden Oak Death

Coast live oak, Mountain View Cemetery, Oakland

The coast live oak that is native to the Bay Area is one of our favorite trees and we would be happy to see more of them.  However, the epidemic of Sudden Oak Death that is killing oaks in California and Oregon makes us question the wisdom of replacing non-native trees with oaks that may not survive that epidemic.  Since any dead tree is more flammable than any living tree, we are also skeptical about claims that restoration of the oak-studded grassland will reduce fire hazard in the Bay Area.

Sudden Oak Death, US Forest Service photo

 The pathogen (Phytophthora ramorum) that causes Sudden Oak Death (SOD) was reported  on the UC Berkeley campus in 2002.  At that time it also existed at the UC Botanical Garden and the researcher who identified the pathogen speculated that it probably existed throughout the East Bay.  By 2008, the SF Chronicle reported   that the infestation of SOD existed in several parks in the East Bay.  The researcher estimated that about 20% of all coast live oaks in the East Bay are infected with the pathogen that will eventually kill them.

In February 2008, the California Oak Mortality Task Force estimated  that ”millions of tanoak and coast live oak” have been killed by SOD in California.  Thirty four other species of trees and shrubs are also infected with the pathogen, including bay laurels and redwoods.  Although these species are not usually killed by the pathogen they are vectors of the disease.  The bay laurel is singled out by the scientific literature as being particularly effective at transmitting the pathogen to the oaks that are then killed.

The “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District proposes to destroy most non-native trees on over 1,500 acres of parkland.  The “vegetation management goal” for most of these acres is the restoration of “oak-bay woodland.”  And so we ask these rhetorical questions:

  • What is the probability that coast live oak will survive the deadly SOD pathogen in the Bay Area?
  • Does the proximity of bay laurel to the local oak population increase the probability of infection?
  • If the oaks are killed by SOD will the risk of wildfire in the East Bay hills increase?
  • If the non-native trees are destroyed and the oaks are killed by SOD will the resulting landscape be entirely treeless?

We believe these are legitimate questions and when we have asked them of native plant advocates we have not heard an adequate answer.  We believe that eradicating non-native plants and trees without a clear understanding of the future of the natives, is irresponsible.