Public comment for Franciscan manzanita reopened to July 29, 2013

Update:  US Fish & Wildlife published the final rule designating critical habitat for Franciscan manzanita on December 20, 2013.  230.2 acres of land in San Francisco have been designated as critical habitat:  46.6 acres of federal land, 172.8 acres of parks owned by San Francisco’s Recreation and Parks Department, and 10.8 acres of private land.  The complete document is available here.  The document responds to public comments and explains any differences between the proposed designation and the final rule.  It makes interesting reading. 

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We have just learned—belatedly—that US Fish & Wildlife has reopened the public comment period for the designation of critical habitat for the endangered Franciscan manzanita in San Francisco’s public parks.  The new public comment deadline is July 29, 2013.  The announcement tells us that public comment period has been reopened for the following reasons:

  • Acreage of critical habitat has been revised to correct previous errors
  • Seventy-three acres of San Francisco’s city-managed parks have been added “at the request of the staff of the Recreation and Park Department.”
  • The National Park Service and the Presidio have both asked that some of their property be removed from the designation of critical habitat.
  • A Draft Economic Analysis has been added:  “…total potential incremental economic impacts in areas proposed as critical habitat over the next 20 years (2013 to 2032) will be approximately $28,222 ($1,411 annualized)…”  Given that the cost estimate for the recovery plan for the closely related Raven’s manzanita (and lessingia) was estimated as $23,432,500 in 2003, we consider this cost estimate for reintroduction of Franciscan manzanita ridiculous.

 Does San Francisco’s Recreation and Park Department understand that the Endangered Species Act provides the same legal protection for reintroduced species as it does naturally occurring endangered species, such as the red-legged frog and the San Francisco garter snake at Sharp Park?  The Recreation and Park Department was recently ordered by a federal judge to pay $386,000 of legal expenses of organizations that sued the Department on behalf of these endangered species.  The Department would be wise to consider that such suits on behalf of Franciscan manzanita would be likely if the Department does not conduct prescribe burns and/or does not destroy all trees in critical habitat because both are required for the survival of this species. 

We are reprinting below our original article of October 23, 2012, describing the horticultural requirements of Franciscan manzanita and our concerns about its reintroduction in the city-managed parks of San Francisco. 

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On September 5, 2012, US Fish & Wildlife (USFWS) announced that Franciscan manzanita is now an endangered species. In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive. It was transplanted to an undisclosed location in the Presidio in San Francisco.

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of land in San Francisco as critical habitat for the Franciscan manzanita. Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio. (Details about all the critical habitats are available here.) Forty of the 318 acres are on private land. Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

The taxonomy of manzanita is ambiguous

There are 96 species of manzanita in California (1). The ranges of most of these species are extremely small because the manzanita hybridizes freely and therefore adaptive radiation has resulted in a multitude of species, sub-species, and varieties that are adapted to micro-climates. Many of these species are locally rare, which is consistent with the fact that 6 species of manzanita have already been designated as endangered, two of which are limited to the San Francisco peninsula: Raven’s manzanita and Franciscan manzanita.

The genetic relationship between these two species of manzanita is ambiguous, which is reflected in the constantly shifting opinions of biologists about the taxonomy (species classification) of manzanita. The 2003 Recovery Plan for Raven’s manzanita recounted the long history of these shifting views. For some time, Raven’s and Franciscan manzanitas were considered the same species. Then, for an equally long time, they were considered sub-species of the same species, Arctostaphylos hookeri. It was not until 2007, that Raven’s was reclassified as a sub-species of Arctostaphylos montana. Presently, Franciscan manzanita is classified as its own species, Arctostaphylos franciscana.

Clearly, this history of the biological opinion regarding these two species of manzanitas suggests they are closely related and morphologically (AKA anatomically) similar. The Recovery Plan concludes, “The idea of ‘pure’ species in Arctostaphylos, with its many poorly defined taxa and prevalent hybridization has often been difficult to apply over the history of taxonomic work in the genus.”

To add to the confusion regarding the provenance of Franciscan manzanita, some biologists are of the opinion that the individual plant that was discovered on Doyle Drive is actually a hybrid, not a pure-bred Franciscan manzanita. The East Bay Regional Park District botanical garden in Tilden Park has planted a clone of the individual plant from Doyle Drive. It is labeled as a hybrid of Arctostaphylos uva-ursi, which is one of the few species of manzanita with a wide range.

This is the label on the “Doyle Drive” manzanita in Tilden Park Botanical Garden, indicating that it is a hybrid.

The park ranger who led us to this plant in the Tilden garden, pointed out that the plant is morphologically distinct from the Franciscan manzanita that has been resident in that garden for about 50 years. He expressed his opinion that the Doyle Drive manzanita was properly labeled as a hybrid.

In what sense is the Franciscan manzanita “endangered?”

Franciscan manzanita has been available for purchase in nurseries for about 50 years. It has been propagated by taking cuttings and therefore they are presumed to be genetically identical clones. However, given that this plant has been sold to the public for a long time, we have no way of knowing exactly where they have been planted or if some have successfully reproduced by germinating seeds. For all we know, this plant is thriving somewhere, perhaps even in a place we might call “wild.” Perhaps the plant found on Doyle Drive was purchased in a nursery!

The individual plant found on Doyle Drive has been defined by USFWS as Franciscan manzanita despite the fact that some biologists consider it a hybrid of another species. We understand that the motivation for designating this individual as an endangered species and providing it with critical habitat is based on an assumption that it is genetically different from the Franciscan manzanita that can be purchased in nurseries and that the chances of survival of the species may be improved by cross-fertilization of these two plants such that greater genetic diversity results from their union.

Yet we are offered no evidence of the genetic composition of the Doyle Drive individual or Franciscan manzanita sold in nurseries. Nor are we provided any evidence that the Doyle Drive individual is even a genetically “pure” Franciscan manzanita rather than a hybrid of another species altogether.

If we weren’t being asked to devote 318 acres of land to the propagation of a plant with such ambiguous taxonomy, we might not question how little information we have been provided. The technology of mapping the genome of this plant is available to us. Why aren’t we making use of this technology to resolve these ambiguities? The cost of planting 318 acres with this endangered plant far exceeds the cost of such genetic analysis.

We aren’t told what it will cost to plant 318 acres with this endangered plant, but we know that the cost of the recovery plan for Raven’s manzanita and lessingia was estimated as $23,432,500 in 2003. Presumably that is an indication that the proposal for Franciscan manzanita will be a multi-million dollar effort. The cost of transplanting the single plant from Doyle Drive to the Presidio was reported as over $200,000. (1)

Thirty years of endangered status for Raven’s manzanita has not saved this plant

We have already made the point that Raven’s and Franciscan manzanitas are closely related. In its proposal for the designation of critical habitat for Franciscan, USFWS confirms this close relationship by referring us to the Recovery Plan for Raven’s. In other words, the characteristics and horticultural requirements of these two species are so similar that a separate Recovery Plan for Franciscan is not necessary. The Recovery Plan for Raven’s is applicable to Franciscan.

Therefore, we should assume that the fate of the recovery effort for Franciscan will be similar to that for the Raven’s. Raven’s was designated as endangered in 1979. Its first recovery plan was published in 1984 and the second in 2003. Many 5-year reviews of its endangered status have been done during this 33 year period. The most recent 5-year review was published in June 2012; that is, very recently.

So what does USFWS have to show for 33 years of effort to save Raven’s manzanita from extinction? Almost nothing:

  • Clones of the single plant in the wild exist in several botanical gardens. These clones are genetically identical and their growth in maintained gardens does not meet ESA standards for recovery.
  • “The wild plant has been observed to set seed although no natural seedling establishment is known to have occurred.” (6)
  • The plant has been the victim of twig blight several times, but the fungus cannot be treated because it would damage the mycorrhizal fungi in the soil upon which the plant is dependent.
  • The seeds depend upon animal predators for dispersal which are largely absent in an urban area.
  • The pollinators of manzanita have not been identified and therefore there is no assurance that they still exist in this location.
  • The 5-year review concludes that: “…recovery sufficient to warrant full delisting is not projected in the foreseeable future for [Raven’s manzanita] and may not be possible.”

We can’t appreciate the significance of the utter failure of this effort without some mention of the extreme methods used to overcome these obstacles.

The seed of manzanita is germinated by fire. However, the exact relationship between fire and germination is not known. Therefore, many complex experiments have been conducted on the few viable seeds produced by the Raven’s manzanita in a futile effort to determine the winning combination. These experiments are described in detail in an article in Fremontia (1). In short, various combinations of fire, heat, cold, smoke, liquid smoke, etc., were tried and failed to determine exactly what triggers germination of manzanita seeds.

We should remind our readers of the legal definition of “recovery” according to the Endangered Species Act. According to the 5-year review for Raven’s manzanita, here are two of the criteria for recovery toward which there has been no progress in 33 years:

  • “At least five spontaneously reproducing variable populations are established in reserves…in San Francisco…”
  • “At least two sexually reproduced generations are established within the Presidio.”

Frankly, it is no longer credible to expect the recovery of Raven’s manzanita and this failure implies the same fate for Franciscan manzanita.

Can the public parks of San Francisco meet the horticultural requirements of Franciscan manzanita?

The public parks of the City of San Francisco cannot meet the horticultural requirements of the Franciscan manzanita because it requires fire to germinate its seeds.

All of the critical habitats proposed by USFWS in San Francisco’s public parks are designated “natural areas.” According to the DRAFT Environmental Impact Report of the “Significant Natural Resource Areas Management Plan,” prescribed burns are prohibited in the natural areas. Therefore, unless there are unplanned wildfires in the six public parks proposed as critical habitat, it will not be physically possible to “spontaneously reproduce” this plant, as required by the Endangered Species Act.

Granted, the City of San Francisco could revise its management plan for the natural areas to allow—or even require—prescribed burns in the six parks proposed as critical habitat. In that case, the citizens of San Francisco would be subjected to air pollution and risk of causing an uncontrolled wildfire in surrounding residential communities. The Natural Areas Program would be subject to even more criticism than it already endures.

The Natural Areas Program is extremely controversial in the City of San Francisco because it destroys healthy non-native trees, it sprays pesticides on non-native vegetation in public areas, it destroys the habitat of wildlife, and it limits the public’s recreational access to trails which are often fenced. Subjecting the natural areas to prescribed burns is surely the bridge too far for the public which would jeopardize the future of the entire program. Why would the City of San Francisco be willing to push the public over the edge by requiring prescribed burns in six urban parks in densely populated residential communities?

Furthermore, some of the proposed critical habitat is in heavily forested areas, which are not compatible with the requirement of manzanita for full sun. As they were on behalf of Raven’s manzanita, these trees would be destroyed. The City of San Francisco is already planning to destroy 18,500 trees over 15 feet tall to accommodate its desire to reintroduce native plants to forested areas. (3) How many more trees would need to be destroyed to accommodate Franciscan manzanita? How much more carbon dioxide would be released into the atmosphere by the destroyed trees?

Bayview Hill is one of the proposed critical habitats which are heavily forested. According to SNRAMP (3), 17.16 acres of Bayview Hill is forested. Given that Bayview Hill is the only proposed critical habitat which is outside the known historic range of Franciscan manzanita, the loss of 17 acres of trees does not seem a fair trade for a plant with few prospects for survival.

The proposed critical habitat in Glen Canyon Park (inaccurately called Diamond Heights by the proposal) is also forested in a portion of the 34 proposed acres of critical habitat. This is a park in which the destruction of trees is being hotly contested. The community in this park does not need the additional controversy of tree destruction for the sole purpose of planting an endangered species.

Proposed critical habitat in other city parks is likely to be controversial for other reasons, primarily because additional restrictions on recreational access will undoubtedly be required to protect this endangered plant. Bernal Hill is an example of a city park with a huge community of visitors who will undoubtedly be enraged by further loss of recreational access. They have already been squeezed by the restrictions imposed by the Natural Areas Program.

This proposal for critical habitat is not good public relations for the Endangered Species Act

The City of San Francisco is the second most densely populated city in the country. It is comprised of only 29,888 acres. There are only 3,317 acres of City-managed parks in the city. (2) The proposed critical habitat in City-managed parks is 196 acres, 6% of total City-managed park land in San Francisco.

Please ask yourself these questions:

  • Does it make sense for 6% of all City-managed park land to be permanently committed to planting an endangered plant which can be purchased in nurseries?
  • Does it make sense to confiscate 6% of all public parks for a plant the identity of which we are not certain?
  • Does it make sense to throw the public out of 6% of all public parks on behalf of a plant that will never be able to spontaneously reproduce unless there is an accidental wildfire?

We think the answers to these questions are no, no, and no. This is an ill-advised proposal which makes a mockery of the Endangered Species Act. This is an important law that is trivialized by a proposal that will be physically impossible to implement without endangering the public and damaging the environment.

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at http://www.regulations.gov (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn: FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.

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Bibliography

(1) Gluesenkamp, Michael, et al., “Back from the Brink: A Second Chance at Discovery and Conservation of the Franciscan Manzanita,” Fremontia, V37:4/38:1, 2009-2010

(2) Harnik, Peter, Inside City Parks, Trust for Public Land, 2000

(3) San Francisco Recreation and Park Department, “Significant Natural Research Area Management Plan (SNRAMP),” 2006

(4) San Francisco Recreation and Park Department, “DRAFT Environmental Impact Report for SNRAMP,” 2011

(5) USFWS, “Designation of Critical Habitat for Franciscan Manzanita,” September 5, 2012

(6) USFWS, “5-Year Review of Endangered Status of Raven’s Manzanita,” June 2012

(7) USFWS, “Recovery Plan for Coastal Plants of the Northern San Francisco Peninsula,” 2003

Center for Biological Diversity is about power and control

We try to give people the benefit of the doubt.  We assume that native plant advocates believe what they say even when we know what they’re saying isn’t true.  We assume they share our commitment to protecting the environment even though we don’t agree about how to achieve that goal.

When the Center for Biological Diversity (CBD) was required by the Arizona Supreme Court to pay $600,000 in punitive damages for fabricating fraudulent evidence to support their unsuccessful effort to take federal grazing rights from a rancher in Arizona, we assumed it was just an example of over-zealous environmentalism.  People who believe they are on an important mission sometimes think the means they use to achieve their goals are justified by the righteous ends of their cause.

However, recent events have forced us to reconsider our generous interpretation of CBD’s motives.  In particular, we find the Center for Biological Diversity’s action and inaction on these two local issues contradictory:

  • On one hand, CBD filed for endangered status for the Franciscan manzanita.  CBD’s clone, Wild Equity (founded by a former employee of CBD), sued when endangered status was delayed.  They demanded the designation of critical habitat—including 196 acres of San Francisco’s public parks– for a plant which is likely a hybrid of one of the most common species of manzanita and will require dangerous and polluting wildfires to reproduce.  This seems consistent with CBD’s long track-record of aggressively protecting rare plants and animals despite negative impact on humans.
  • On the other hand, CBD has thus far done nothing on behalf of the endangered Clapper Rail.  It has been over a year since studies have shown that the eradication of non-native Spartina marsh grass in San Francisco Bay has decimated the small population of this rare bird.  The assumption is that the Rail is exposed to its predators–particularly during nesting season–by eradication of dense, year-round cover provided by Spartina.  It’s also possible that the pesticide (imazapyr) used to eradicate Spartina is a factor, because the effect of imazapyr on shore birds has not been tested.  The absence of action on behalf of the Rail seems inconsistent with CBD’s extreme actions on behalf of other endangered plants and animals.
California Clapper Rail

Is Center for Biological Diversity motivated by money?

So how do we reconcile these seemingly inconsistent actions vs. inactions of CBD?  What motivates their selection of particular species of plants and animals for protection? 

Ted Williams calls himself an “environmental extremist.”  He is the author of a regular column in Audubon Magazine which is appropriately entitled, “Incite.”  One of Williams’ articles demonizing eucalyptus is typical of the provocative approach of his column.  In that article, he fabricated “data” about bird deaths to justify the crusade to eradicate eucalypts. 

Williams is proud of his credentials as an environmental provocateur and he uses those credentials to defend his criticism of Center for Biological Diversity in an article in High Country News (1).  He expresses his opinion that CBD is motivated by money.  He points out that CBD has filed hundreds of suits against the federal government, using environmental laws, such as the Endangered Species Act, and that every time it wins it collects attorney fees from the federal government.   The cost and number of these suits has become a major obstacle to US Fish & Wildlife and the Environmental Protection Agency in fulfilling their mandate to protect rare species.

Although these accusations are accurate, we don’t think this is an adequate explanation for CBD’s choice of issues to pursue.  We turn to the New York Times to put this accusation into perspective.  The Times reports (2) that CBD had filed 700 lawsuits when the article was published in March 2010, and they were successful in those suits 93% of the time.  Those suits forced the government to list 350 endangered species and designate 120 million acres of critical habitat for their recovery. 

However, revenue generated by the success of these suits was only $1.4 million in 2008, compared with $7.6 million from contributions and grants.  In other words, only 16% of CBD’s revenue in 2008 came from their suits against the federal government. 

Furthermore, the founder and Executive Director of CBD earned $116,000 in 2008, which doesn’t seem out of line for an organization with over 60 employees and offices all over the country (including the San Francisco Bay Area). 

We don’t think the leadership of CBD is motivated by money. 

It’s about power and control

We turn to the New Yorker magazine (3) to understand and explain the motivation of Center for Biological Diversity and its local ally, Wild Equity.  In 1999, the New Yorker published an in-depth study of the leadership of CBD entitled, “No People Allowed.” 

The article reports the creation of CBD and its early history in the southwest where it was founded and is still headquartered.  Their initial efforts were direct-action, typical of traditional environmental organizations; then they discovered the power of the law:  “’We’re crazy to sit in trees when there’s this incredible law where we can make people do whatever we want,;” said Robin Silver, one of the founders of CBD.    

Using federal environmental laws, they apparently brought the timber industry in the southwest to a virtual halt and they were making similar progress in eliminating all grazing in the southwest when the article was published.  Perhaps there was some benefit to the environment, but there was also significant economic loss to the human community in the southwest, according to the New Yorker.

So, what does CBD want?  The New Yorker tells us that the founder’s deconstructionist philosophy is “a decentering and disempowering of the human.”  Their goal is described:  “…the center is endeavoring to undo the dominion of man over animals and plantsthe only way to get to the desired state is to deconstruct stuff that exists in the world:  legal arrangements, social and economic forms, and even physical structures.”  CBD’s Executive Director tells us his motivation in the New Yorker article as well as the long term goal of CBD:  “[Kieran] Suckling cheerfully admitted that he’s ‘using one side of industrial society against itself,’ but only temporarily; in the long run, he says, there will be a new order in which plants and animals are part of the polity.  For example, legal proceedings could be conducted outdoors—in which case ‘the trees will make themselves felt.’”

“Good” tree may stay

We find the reference to the desires of trees particularly interesting.  Apparently Mr. Suckling believes he speaks for the trees.  What about the non-native trees which CBD demands we destroy on behalf of other plants and animals which it prefers?  Mr. Suckling apparently considers himself the spokesperson for just particular trees of his choosing.  Apparently the rights of trees will be limited to native trees when CBD has successfully established this new order.

“Bad” tree must go.

Mr. Suckling also implies that CBD’s control of the environment is only temporary until the new order is established in which plants and animals are in control.  This reminds us of a similar fantasy about a new social and economic model which was originally proposed by Karl Marx.  In creating the concept of communism, he envisioned a temporary dictatorship of elites which would eventually be ceded to a “dictatorship of the proletariat.”  The world has now witnessed many attempts to install communism as the governing economic model, but we have not seen the dictatorship of elites willingly cede their power to the people. 

This quote of CBD’s Executive Director from Ted Williams’ article, also helps us to understand why CBD sues the federal government to achieve their goals:  “’They [employees of federal agencies] feel like their careers are being mocked and destroyed—and they are,’ he told the High Country News.  ‘So they become much more willing to play by our rules.’”   In other words, suing—and the threat of suit—is CBD’s means of controlling the federal agencies that are responsible for protecting the environment, i.e., forcing them to do what CBD wants.

Humans will always be in control of land-use decisions.  It’s only a question of which humans are in control and CBD intends to be the humans in control.  If we hand them that power, we will find it difficult to wrest it from them if we decide they are not using that power wisely or fairly. 

We can’t defend all of the activities of humans when we damage the environment to suit our purposes.  However, we don’t think the Center for Biological Diversity would be a better steward of our land.  Even if they were capable of wise land-use decisions, we are unwilling to suspend democratic methods of making those decisions.  As human society repeatedly demonstrates, absolute power corrupts absolutely.  We are no more willing to hand our fate to Center for Biological Diversity than to any other despot, benevolent or not.

We invite Center for Biological Diversity to prove us wrong

We would like Center for Biological Diversity to prove us wrong.  CBD can demonstrate that their motivation is not simply the confiscation of public land from human use as a means of destroying human society and civilization.  They can start by filing suit on behalf of the endangered Clapper Rail to stop the pointless and destructive eradication of non-native Spartina in San Francisco Bay, using a toxic pesticide about which little is known.  CBD can demonstrate their commitment to protecting animals even if humans are not punished by that effort.

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(1)    Ted Williams, “Extreme Green,” High Country News, May 21, 2011

(2)    Anne Mulkern, et. al., “Brazen Environmental Upstart Brings Legal Muscle, Nerve in Climate Debate,” New York Times, March 30, 2010.

(3)    Nicholas Lemann, “No People Allowed,” New Yorker, November 22, 1999.

Franciscan manzanita: The confiscation of public land

Update:  US Fish & Wildlife published the final rule designating critical habitat for Franciscan manzanita on December 20, 2013.  230.2 acres of land in San Francisco have been designated as critical habitat:  46.6 acres of federal land, 172.8 acres of parks owned by San Francisco’s Recreation and Parks Department, and 10.8 acres of private land.  The complete document is available here.  The document responds to public comments and explains any differences between the proposed designation and the final rule.  It makes interesting reading. 

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On September 5, 2012, US Fish & Wildlife (USFWS) announced that Franciscan manzanita is now an endangered species.  In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive.  It was transplanted to an undisclosed location in the Presidio in San Francisco.

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of  land in San Francisco as critical habitat for the Franciscan manzanita.   Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio.  (Details about all the critical habitats are available here.)  Forty of the 318 acres are on private land.  Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

The taxonomy of manzanita is ambiguous

There are 96 species of manzanita in California (1).  The ranges of most of these species are extremely small because the manzanita hybridizes freely and therefore adaptive radiation has resulted in a multitude of species, sub-species, and varieties that are adapted to micro-climates.  Many of these species are locally rare, which is consistent with the fact that 6 species of manzanita have already been designated as endangered, two of which are limited to the San Francisco peninsula:  Raven’s manzanita and Franciscan manzanita.

The genetic relationship between these two species of manzanita is ambiguous, which is reflected in the constantly shifting opinions of biologists about the taxonomy (species classification) of manzanita.  The 2003 Recovery Plan for Raven’s manzanita recounted the long history of these shifting views.  For some time, Raven’s and Franciscan manzanitas were considered the same species.  Then, for an equally long time, they were considered sub-species of the same species, Arctostaphylos hookeri.  It was not until 2007, that Raven’s was reclassified as a sub-species of Arctostaphylos montana.  Presently, Franciscan manzanita is classified as its own species, Arctostaphylos franciscana. 

Clearly, this history of the biological opinion regarding these two species of manzanitas suggests they are closely related and morphologically (AKA anatomically) similar.  The Recovery Plan concludes, “The idea of ‘pure’ species in Arctostaphylos, with its many poorly defined taxa and prevalent hybridization has often been difficult to apply over the history of taxonomic work in the genus.”

To add to the confusion regarding the provenance of Franciscan manzanita, some biologists are of the opinion that the individual plant that was discovered on Doyle Drive is actually a hybrid, not a pure-bred Franciscan manzanita.  The East Bay Regional Park District botanical garden in Tilden Park has planted a clone of the individual plant from Doyle Drive.  It is labeled as a hybrid of Arctostaphylos uva-ursi, which is one of the few species of manzanita with a wide range.

This is the label on the “Doyle Drive” manzanita in Tilden Park Botanical Garden, indicating that it is a hybrid.

The park ranger who led us to this plant in the Tilden garden, pointed out that the plant is morphologically distinct from the Franciscan manzanita that has been resident in that garden for about 50 years.  He expressed his opinion that the Doyle Drive manzanita was properly labeled as a hybrid.

In what sense is the Franciscan manzanita “endangered?”

Franciscan manzanita has been available for purchase in nurseries for about 50 years.  It has been propagated by taking cuttings and therefore they are presumed to be genetically identical clones.  However, given that this plant has been sold to the public for a long time, we have no way of knowing exactly where they have been planted or if some have successfully reproduced by germinating seeds.  For all we know, this plant is thriving somewhere, perhaps even in a place we might call “wild.”  Perhaps the plant found on Doyle Drive was purchased in a nursery!

The individual plant found on Doyle Drive has been defined by USFWS as Franciscan manzanita despite the fact that some biologists consider it a hybrid of another species.  We understand that the motivation for designating this individual as an endangered species and providing it with critical habitat is based on an assumption that it is genetically different from the Franciscan manzanita that can be purchased in nurseries and that the chances of survival of the species may be improved by cross-fertilization of these two plants such that greater genetic diversity results from their union.

Yet we are offered no evidence of the genetic composition of the Doyle Drive individual or Franciscan manzanita sold in nurseries.  Nor are we provided any evidence that the Doyle Drive individual is even a genetically “pure” Franciscan manzanita rather than a hybrid of another species altogether.

If we weren’t being asked to devote 318 acres of land to the propagation of a plant with such ambiguous taxonomy, we might not question how little information we have been provided.  The technology of mapping the genome of this plant is available to us.  Why aren’t we making use of this technology to resolve these ambiguities?  The cost of planting 318 acres with this endangered plant far exceeds the cost of such genetic analysis.

We aren’t told what it will cost to plant 318 acres with this endangered plant, but we know that the cost of the recovery plan for Raven’s manzanita and lessingia was estimated as $23,432,500 in 2003.  Presumably that is an indication that the proposal for Franciscan manzanita will be a multi-million dollar effort.  The cost of transplanting the single plant from Doyle Drive to the Presidio was reported as over $200,000. (1)

Thirty years of endangered status for Raven’s manzanita has not saved this plant

We have already made the point that Raven’s and Franciscan manzanitas are closely related.  In its proposal for the designation of critical habitat for Franciscan, USFWS confirms this close relationship by referring us to the Recovery Plan for Raven’s.  In other words, the characteristics and horticultural requirements of these two species are so similar that a separate Recovery Plan for Franciscan is not necessary.  The Recovery Plan for Raven’s is applicable to Franciscan.

Therefore, we should assume that the fate of the recovery effort for Franciscan will be similar to that for the Raven’s.  Raven’s was designated as endangered in 1979.  Its first recovery plan was published in 1984 and the second in 2003.  Many 5-year reviews of its endangered status have been done during this 33 year period.  The most recent 5-year review was published in June 2012; that is, very recently.

So what does USFWS have to show for 33 years of effort to save Raven’s manzanita from extinction?  Almost nothing:

  • Clones of the single plant in the wild exist in several botanical gardens.  These clones are genetically identical and their growth in maintained gardens does not meet ESA standards for recovery.
  • “The wild plant has been observed to set seed although no natural seedling establishment is known to have occurred.” (6)
  • The plant has been the victim of twig blight several times, but the fungus cannot be treated because it would damage the mycorrhizal fungi in the soil upon which the plant is dependent.
  • The seeds depend upon animal predators for dispersal which are largely absent in an urban area.
  • The pollinators of manzanita have not been identified and therefore there is no assurance that they still exist in this location.
  • The 5-year review concludes that:  “…recovery sufficient to warrant full delisting is not projected in the foreseeable future for [Raven’s manzanita] and may not be possible.”

We can’t appreciate the significance of the utter failure of this effort without some mention of the extreme methods used to overcome these obstacles.

The seed of manzanita is germinated by fire.  However, the exact relationship between fire and germination is not known.  Therefore, many complex experiments have been conducted on the few viable seeds produced by the Raven’s manzanita in a futile effort to determine the winning combination.  These experiments are described in detail in an article in Fremontia (1).  In short, various combinations of fire, heat, cold, smoke, liquid smoke, etc., were tried and failed to determine exactly what triggers germination of manzanita seeds.

We should remind our readers of the legal definition of “recovery” according to the Endangered Species Act.  According to the 5-year review for Raven’s manzanita, here are two of the criteria for recovery toward which there has been no progress in 33 years:

  • “At least five spontaneously reproducing variable populations are established in reserves…in San Francisco…”
  • “At least two sexually reproduced generations are established within the Presidio.”

Frankly, it is no longer credible to expect the recovery of Raven’s manzanita and this failure implies the same fate for Franciscan manzanita.

Can the public parks of San Francisco meet the horticultural requirements of Franciscan manzanita?

The public parks of the City of San Francisco cannot meet the horticultural requirements of the Franciscan manzanita because it requires fire to germinate its seeds. 

All of the critical habitats proposed by USFWS in San Francisco’s public parks are designated “natural areas.”  According to the DRAFT Environmental Impact Report of the “Significant Natural Resource Areas Management Plan,” prescribed burns are prohibited in the natural areas.  Therefore, unless there are unplanned wildfires in the six public parks proposed as critical habitat, it will not be physically possible to “spontaneously reproduce” this plant, as required by the Endangered Species Act. 

Granted, the City of San Francisco could revise its management plan for the natural areas to allow—or even require—prescribed burns in the six parks proposed as critical habitat.  In that case, the citizens of San Francisco would be subjected to air pollution and risk of causing an uncontrolled wildfire in surrounding residential communities.  The Natural Areas Program would be subject to even more criticism than it already endures.

The Natural Areas Program is extremely controversial in the City of San Francisco because it destroys healthy non-native trees, it sprays pesticides on non-native vegetation in public areas, it destroys the habitat of wildlife, and it limits the public’s recreational access to trails which are often fenced.  Subjecting the natural areas to prescribed burns is surely the bridge too far for the public which would jeopardize the future of the entire program.  Why would the City of San Francisco be willing to push the public over the edge by requiring prescribed burns in six urban parks in densely populated residential communities?

Furthermore, some of the proposed critical habitat is in heavily forested areas, which are not compatible with the requirement of manzanita for full sun.  As they were on behalf of Raven’s manzanita, these trees would be destroyed.  The City of San Francisco is already planning to destroy 18,500 trees over 15 feet tall to accommodate its desire to reintroduce native plants to forested areas. (3)  How many more trees would need to be destroyed to accommodate Franciscan manzanita?  How much more carbon dioxide would be released into the atmosphere by the destroyed trees?

Bayview Hill is one of the proposed critical habitats which are heavily forested.  According to SNRAMP (3), 17.16 acres of Bayview Hill is forested.  Given that Bayview Hill is the only proposed critical habitat which is outside the known historic range of Franciscan manzanita, the loss of 17 acres of trees does not seem a fair trade for a plant with few prospects for survival.

The proposed critical habitat in Glen Canyon Park (inaccurately called Diamond Heights by the proposal) is also forested in a portion of the 34 proposed acres of critical habitat.  This is a park in which the destruction of trees is being hotly contested.  The community in this park does not need the additional controversy of tree destruction for the sole purpose of planting an endangered species.

Proposed critical habitat in other city parks is likely to be controversial for other reasons, primarily because additional restrictions on recreational access will undoubtedly be required to protect this endangered plant.  Bernal Hill is an example of a city park with a huge community of visitors who will undoubtedly be enraged by further loss of recreational access.  They have already been squeezed by the restrictions imposed by the Natural Areas Program.

This proposal for critical habitat is not good public relations for the Endangered Species Act

The City of San Francisco is the second most densely populated city in the country.  It is comprised of only 29,888 acres.   There are only 3,317 acres of City-managed parks in the city. (2) The proposed critical habitat in City-managed parks is 196 acres, 6% of total City-managed park land in San Francisco.

Please ask yourself these questions:

  • Does it make sense for 6% of all City-managed park land to be permanently committed to planting an endangered plant which can be purchased in nurseries?
  • Does it make sense to confiscate 6% of all public parks for a plant the identity of which we are not certain?
  • Does it make sense to throw the public out of 6% of all public parks on behalf of a plant that will never be able to spontaneously reproduce unless there is an accidental wildfire?

We think the answers to these questions are no, no, and no.  This is an ill-advised proposal which makes a mockery of the Endangered Species Act.  This is an important law that is trivialized by a proposal that will be physically impossible to implement without endangering the public and damaging the environment. 

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at http://www.regulations.gov (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn:  FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.

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Bibliography

(1)      Gluesenkamp, Michael, et al., “Back from the Brink:  A Second Chance at Discovery and Conservation of the Franciscan Manzanita,” Fremontia, V37:4/38:1, 2009-2010

(2)      Harnik, Peter, Inside City Parks, Trust for Public Land, 2000

(3)      San Francisco Recreation and Park Department, “Significant Natural Research Area Management Plan (SNRAMP),” 2006

(4)      San Francisco Recreation and Park Department, “DRAFT Environmental Impact Report for SNRAMP,” 2011

(5)      USFWS, “Designation of Critical Habitat for Franciscan Manzanita,” September 5, 2012

(6)      USFWS, “5-Year Review of Endangered Status of Raven’s Manzanita,” June 2012

(7)      USFWS, “Recovery Plan for Coastal Plants of the Northern San Francisco Peninsula,” 2003