Fuels Management – Conservation Sense and Nonsense

Oakland’s Vegetation Management Plan Is Headed in a Destructive Direction

Oakland has been trying to adopt a vegetation management plan (VMP) to mitigate fire hazards since November 2016. The plan has been drafted three times in 2018, 2019, and 2020 and a draft Environmental Impact Report was also published in 2020. All three versions of the plan were acceptable to me and many others. Every version would have removed dead trees and thinned non-native trees on 2,000 acres of public land and 300 miles of roadsides in Oakland, leaving the tree canopy intact so that the forest floor would be shaded, suppressing the growth of weedy vegetation that ignites easily and keeping the forest floor moist, which retards fire ignition.

Unfortunately, none of the proposed vegetation management plans were acceptable to native plant advocates who want all non-native trees in project areas in Oakland to be destroyed and the land replanted with native plants and trees. The plan they are demanding is a native plant restoration, not a wildfire hazard mitigation plan. Since they have successfully prevented Oakland from addressing wildfire hazards for eight years, we might assume they aren’t concerned about wildfire.

A fourth version of the plan and a new Environmental Impact Report are expected to be published in September 2023 and there will be a new public comment period in October. Based on written and oral public comments at public hearings, we predict that the revised plan is likely to be far more destructive than previous drafts of the plan. Based on that prediction, I am alerting you to the need to read the revision and write a public comment. Please ask to be notified of the publication of the plan by sending an email to info@oaklandvegmanagement.org .

Update: The revised Oakland Vegetation Management Plan and revised Draft Environmental Impact Report were published on September 20, 2023. These documents are available HERE. There will be a public hearing by the Oakland Planning Commission on November 1, 2023. The deadline for public comment will be November 4, 2023. Comments can be submitted by email DEIR-comments@oaklandvegmanagement.org or by mail to Montrose Environmental, attention Ken Schwarz, 1 Kaiser Plaza, Suite 340, Oakland CA 94612.

When I have read the revised plan and its revised EIR, I will post a draft of my public comment on the draft by October 1^st.

– Webmaster, Conservation Sense and Nonsense, September 20, 2023

What do opponents of previous plans want?

There is a wide range of opinions about a vegetation management plan for Oakland. I will use the public comment of the California Society of American Foresters (SAF) on the third version of the VMP as a representative opinion and the best available predictor of where the fourth revision is likely headed. The entire comment of the Society of American Foresters (SAF) is available HERE and here are some of the revisions SAF is asking for:

“Ecological restoration should be a goal of the VMP, including the establishment of native plant species where nonnative species dominate…Thinning of dense stands of nonnative tree species should only be done as part of an overall strategy of restoration, i.e., the goal of any tree removals should always be to eventually convert these stands to native tree or vegetation cover in order to build greater ecological resiliency.”
“In concert with the goal of ecological restoration, adaptive management in light of climate change should guide management practices and restoration plans. Adaptive management strategies that incorporate new information and changing conditions will be critical to ecosystem restoration. Annual grasslands may become more dominant, oak woodlands less so in the planning area in the future as climate changes. Management targets in many cases will have to be based on anticipated future conditions.”
“However, if thinning is kept as the desired practice, we ask that you design each entry to be sufficiently intensive to assure that tree crowns will not close before the next thinning entry (10 years from now?) and indeed is sufficiently thinned to allow work towards establishing native vegetation in these stands.”
“The use of prescribed fire as a vegetation maintenance tool should have been considered and included in the VMP especially on ridges where fire moving from adjacent jurisdictions might occur, or along power-line transmission corridors.”
“The vegetation management zones along roadsides, especially along routes of egress, should be modified to extend 100 feet from roadside edges and should include any trees with underlying structural or health conditions that are tall enough to fall onto streets and roads. This may in some cases require looking outside of the 100-foot roadside clearance.”
“It is important that the use of triclopyr herbicides is included to treat cut stumps in eucalyptus to prevent sprouting. Glyphosate herbicides will not be effective in treating eucalyptus stumps and will result in resprouts.”
“There should be an Ecological Restoration Guide added to the appendices…This new appendix would outline the City of Oakland’s current ecological restoration efforts, identify stakeholders (e.g., city departments, Oakland Wildlands Stewards, etc.) and their roles…”

Native plant restoration, NOT wildfire hazard mitigation

The Society of American Foresters (SAF) is asking the City of Oakland to make a commitment to eradicating all non-native trees in project areas and replacing them with native plants. Such a plan would not reduce wildfire hazards in Oakland because native vegetation is not inherently less flammable than non-native vegetation. Most wildfires in California occur in native chaparral and native conifer forests.

The plan proposed by the Society of American Foresters (SAF) is a native plant restoration plan, NOT a wildfire hazard mitigation plan. Their proposal would destroy much of Oakland’s urban forest, which would not be replaced by native trees:

Non-native trees were planted in Oakland in the 19th century because there were few native trees: “Vegetation before urbanization in Oakland was dominated by grass, shrub, and marshlands that occupied approximately 98% of the area.” (1) Non-native tree species in the East Bay are adapted to soil and microclimate conditions that are not suitable for native species.
Grassland was the dominant vegetation type of pre-settlement Oakland partly because of the land management practices of Native Americans and the stock grazing of early settlers: “Native Americans played a major role in creation of grasslands through repeated burning and these disturbance-dependent grasslands were maintained by early European settlers through overstocking of these range lands with cattle and sheep. Twentieth century reduction in grazing, coupled with a lack of natural fires and effective suppression of anthropogenic fires, have acted in concert to favor shrubland expansion.” (2)
Grassland in California is not native to California. Mediterranean annual grasses were brought to California in the early 19^th century by the grazing herds of Spanish-Mexicans. California’s native bunch grasses are not adapted to heavy grazing by herds of domesticated animals. The grassland of California is about 99% non-native (Allan Schoenherr, A Natural History of California, UC Press, 1992). Attempts to convert annual grasslands to native bunch grass have not been successful. A team of scientists at UC Davis spent $450,000 and 8 years trying to convert 2 acres of grassland to native bunch grasses without success. Grassland that will replace our urban forest will not be native.
Grass is easily ignited and fires move quickly through grassland, particularly in a wind-driven fire. The deadly, destructive fires in Maui, Hawaii are a case in point. When agricultural fields of sugar cane, pineapple and other tropical fruit left Maui they were quickly succeeded by non-native grass that was considered a factor in the spread of fire. (3) Dormant, dry annual grassland in the East Bay Hills will be more flammable than the living vegetation that native plant advocates want to destroy.
A small redwood grove was the only pre-settlement exception to the otherwise treeless Oakland hills: “…for thousands of years [the Oakland hills] were treeless meadows, visited seasonally under Indigenous management…The one exception was the redwood groves of the southern Oakland Hills, a restricted forest that extended a few miles eastward from upper Dimond Canyon over the ridgetop to the outskirts of Moraga.” (4) Much of this grove still exists today because coastal redwoods are vigorous resprouters when they are burned or cut down.
SAF also predicts a vegetation type-conversion from forest to grassland: “Annual grasslands may become more dominant, oak woodlands less so in the planning area in the future as climate changes.” Grassland will naturally succeed to shrubland without regular burning, which SAF recommends to reduce fuel loads.
Prescribed burns in densely populated urban areas are rarely approved by Bay Area Air Quality Management District because they pollute the air and often cause uncontrolled wildfires. California law regarding liability for damage caused by prescribed burns was revised in 2022 to provide legal protections for those who manage prescribed burns. The revised law lowers the standard for liability to gross negligence from a previous standard of simple negligence. (5)

Consequences of landscape conversion to grass and shrubs

Destroying thousands of trees will increase air pollution and reduce air quality. Destroying thousands of trees will increase greenhouse gas emissions causing climate change by releasing the carbon stored by the trees that are destroyed and reducing carbon sequestration going forward because the destroyed forest will not be replaced by a forest of native trees.

There was little biodiversity in Oakland’s pre-settlement forest: “Oakland’s original species composition has increased from approximately 10 tree species to more than 350…Today [1993], only 31% of existing trees are native to Oakland, the plurality of trees (38%) are native to Australia/New Zealand.” (1) Destroying thousands of non-native trees in Oakland will reduce the biodiversity of our forest. A more diverse forest is more resilient, particularly in a changing climate, with extreme and variable weather conditions.

Increasing 300 miles of roadside clearance from 30 feet (as proposed by the 3^rd version of the VMP) to 100 feet (as proposed for the 4^th version of the VMP) will produce wood debris on a scale that cannot be disposed of. We know what the outcome will be because of a similar project on Claremont Ave, where eucalyptus was clear cut 100 feet from the north side of 1.1 miles of the road in fall 2020. Below are pictures of the piles of wood chips and logs that remained along that stretch of road for about 9 months while project managers tried to figure out what to do with the wood debris, which was eventually dispersed throughout the hills. UC Berkeley implemented the project with funding from Cal-Fire.

The north side of Claremont Ave. was clear cut 100 feet from the road. The south side of the road was not cut because the trees are native. There is a creek flowing at the bottom of the canyon that creates the moist conditions needed for native trees, which will not grow where non-native trees now grow. Photo by Doug Prose, courtesy Hills Conservation Network.

One of many piles of logs, Claremont Ave, November 2020. It took about 9 months for the logs to be dispersed along roads in the hills. Photo by Doug Prose, courtesy Hills Conservation Network.

One of many piles of wood chips, Claremont Ave, November 2020

The roads in the East Bay hills are now lined with logs, preventing people from pulling off the road. No native plants or trees were planted after the trees were destroyed. Three years later, the clear cut roadside is vegetated with non-native annual grasses and coyote brush, a pioneer native shrub.

The project on the property of UC Berkeley was very small in comparison to the Oakland vegetation management plan that will clear cut 300 miles of roads, producing at least 300 times the amount of wood debris. What will Oakland do with the wood debris that is produced from the destructive VMP that native plant advocates demand? Tons of wood debris lying on the ground is far more flammable than living trees, which is another indication that the VMP that native plant advocates demand is not about mitigating fire hazards. It’s about their preference for a native landscape that is not less flammable than the landscape they demand be destroyed. Like all Mediterranean climates, our native vegetation is fire adapted and fire dependent. A significant number of our native species will not regenerate in the absence of fire. Most wildfires in California in the past 5-10 years have occurred in native chaparral and native conifer forests.

NY Times reported that 150 homes burned in this wind-driven fire in San Diego in 2003, but the eucalyptus surrounding the neighborhood did not burn. The flammability of eucalyptus trees is exaggerated to justify their destruction. NY Times photo

The more trees that are destroyed, the more herbicide will be required to prevent the trees from resprouting. SAF is correct in saying that tricopyr will be needed to kill the roots of the trees to prevent them from repsouting. Glyphosate will not accomplish that task. Triclopyr is more toxic than glyphosate. Triclopyr has a signal word of “warning” and glyphosate has a less toxic signal word of “caution.” Triclopyr kills the roots of woody plants by traveling from the cut stump to the roots of the plant in the soil. Triclopyr is known to kill mycorrhizal fungi in the soil, which are essential to the health of plants growing in the soil. The more herbicide that is used to kill the roots of destroyed trees, the less likely a newly planted native landscape is to survive. All the more reason to assume that the destroyed forest will not be replaced by a native landscape.

In Summary

The landscape that native plant advocates demand for Oakland will be predominantly non-native annual grasses.
Native trees will not replace the trees that are destroyed because they are not adapted to most places where non-native trees now live and because there is no available funding to purchase native plants, plant them on thousands of acres of public land, and irrigate them until they are established. Similar fuels management projects done by East Bay Regional Parks District, East Bay Municipal Utilities District, and UC Berkeley have not planted a native landscape to replace trees that have been destroyed.
Non-native annual grasses will naturally succeed to shrubs in the absence of frequent fire. Shrublands are more flammable than the existing urban forest because fire travels on the ground, unless wind-driven fire ignites tree canopies. In that case everything burns, both native and non-native trees. The wind-driven fire in Oakland in 1991 spared no trees in burned areas, whether native or non-native.
The project would produce many tons of flammable wood debris that has no commercial value and no place to be safely disposed of.
The loss of our urban forest will increase air pollution in Oakland, contribute to greenhouse gas emissions causing climate change, and raise temperatures in a city that is already a heat-island.
Herbicides needed to prevent the urban forest from resprouting will poison the soil and suppress the growth of a new landscape.

If you live in Oakland City Council District 4 or 6, you are likely to be directly affected by Oakland’s vegetation management plan. The most effective way to influence the VMP is to express your opinion to your representative on the City Council, as well as our at-large representative on the Council. Contact information for members of the Oakland City Council is available HERE.

(1) David Nowak, “Historical vegetation change in Oakland and its implications for urban forest management,” Journal of Arboriculture, September 1993
(2) Jon E. Keeley, “Fire history of San Francisco East Bay Region and implications for landscape patterns,” International Journal of Wildland Fire, September 2005.
(3) https://www.nytimes.com/2023/08/13/us/hawaii-wildfire-factors.html
(4) Andrew Alden, Deep Oakland: How geology shaped a city, Heyday, 2023.
(5) https://kion546.com/news/2022/01/04/new-california-law-changes-liability-for-out-of-control-prescribed-burns/

Forest Action Brigade: “Oakland’s Vegetation Management Plan is significantly improved”

The City of Oakland began the process of developing a Vegetation Management Plan (VMP) over three years ago. The purpose of the VMP is “to evaluate the specific wildfire hazard factors in the Plan Area [2,000 acres of city-owned parks and open space and 300 miles of roadsides] and provide a framework for managing vegetative fuel loads…such that wildfire hazard is reduced and negative environmental effects resulting from vegetation management activities are avoided or minimized.” (revised VMP, page 3)

The first draft of the VMP was published in June 2018. There were significant issues with the first draft that were described by Million Trees HERE.

The VMP was revised and published on November 1, 2019. It is available HERE. Written comments can be submitted until December 12, 2019. Scoping comments may be submitted by email (arobinsonpinon@oaklandca.gov) or by mail to Angela Robinson Piñon, 250 Frank H. Ogawa Plaza, Suite 4314, Oakland California 94612. “Scoping” is the first step in the process of preparing an Environmental Impact Report (EIR). The purpose of scoping is to identify the issues that must be evaluated by the EIR.

The Forest Action Brigade accepts the revised VMP because fire hazards are real and compromise is needed to address them. Public comments submitted by the Forest Action Brigade regarding scoping for the EIR explain our reasoning. See below. We believe the revised VMP will reduce fire hazards in Oakland without destroying more trees than necessary and limiting herbicide use primarily to preventing trees from resprouting after they are removed. It is counterproductive to destroy more trees than necessary because climate change has made wildfires more frequent and destructive and carbon sequestered by mature trees is one of the most effective means of reducing greenhouse gas emissions causing climate change.

TO: Angela Robinson Pinon, Oakland Fire Department
arobinsonpinon@oaklandca.gov
FROM: Forest Action Brigade
RE: Oakland’s Vegetation Management Plan, Scoping Comments for EIR

The revised Vegetation Management Plan is a significant improvement over the first draft. We accept the revised Vegetation Management Plan for the City of Oakland because:

Standards for creating and maintaining defensible space around structures, along roadsides, and on ridgelines are reasonable and consistent with both fire science and State law.

Forests will be thinned, but “broad based tree removal is not proposed.” Mature trees will be retained, which reduces carbon loss. Fire ladders to tree canopies will be eliminated.

Forest canopy will be retained so the forest floor is shaded and growth of flammable understory grasses and shrubs is suppressed. Density of the canopy will be reduced, but the canopy will be intact.

Herbicide will be used to prevent resprouts of trees that are removed, but foliar spraying will be “minimized.” The VMP acknowledges that vegetation killed by foliar spraying is left in place and becomes dry, easily ignited fuel.

Best Management Practices for herbicide use require that all applications be done by certified applicators and requests for herbicide application be approved by a licensed pest control advisor.

The revised VMP acknowledges that the flammability of plants and trees is unrelated to the nativity of the species. The VMP classifies some species of both native and non-native plants and trees as “pyrophytic.” Non-native plants are not inherently more flammability than native plants. Flammability is related to the physical and chemical characteristics of plants, not their nativity.

The VMP clearly states that the implementation of the VMP is the responsibility of the Oakland Fire Department. OFD is not obligated to respond to the wishes of advocacy organizations unless their proposals are consistent with fire hazard mitigation.

The revised VMP will reduce fuel loads and risk of ignition. The revised VMP is a fire hazard reduction project with one exception: the VMP continues to propose the destruction of individual non-native trees within stands of native trees. However, that proposal is ranked as Priority 3 and is therefore unlikely to be funded. Oakland’s Tree Services Division is inadequately funded and severely understaffed. Tree Services does not have the resources to remove trees unless they are dead or pose a hazard to the public. Neither Tree Services nor this VMP is responsible for landscape type conversion: “This VMP does not propose vegetation type conversion as an end goal or strategy…” (Page 1) Moreover, such unnecessary removal of mature trees damages the surrounding environment, especially in riparian areas, and increases carbon loss, contributing to climate change.

If the VMP is ultimately funded by renewal of the parcel tax for fuels management, revenues should not be used to hire contractors to destroy individual non-native trees within stands of native trees because that would not reduce fire hazards. The previous parcel tax was cancelled by voters partly because it was misused to fund native plant projects that conflict with fire hazard mitigation. When native plant advocates plant rare, protected plants in Oakland’s parks and open spaces (which they do), they then oppose fuels management that threatens the plants they prefer. It is not possible to mow a meadow of grass to prevent ignition without simultaneously destroying individual plants in that meadow. We saw that principle at work at the public hearing by the Planning Commission on November 20, 2019. The parcel tax that we would vote for would explicitly prohibit the use of the revenue for vegetation type conversion that is incompatible with fire hazard mitigation.

Scoping Issues

These issues must be addressed by the Environmental Impact Report for the revised VMP, as required by CEQA State law:

Carbon loss resulting from tree removals must be estimated. Mitigation for carbon loss must be proposed or negative environmental impact must be acknowledged and estimated. Carbon loss contributes to climate change and climate change is making wildfires more frequent and intense. Therefore carbon loss increases wildfire hazards and must be estimated by the EIR for this project.

The EIR must identify the herbicides and estimate the quantities that will be used to implement the VMP. The amount and impact of pesticides to be used in the VMP should be compared with Oakland’s current levels of herbicide use in the city, including roadside applications. Known hazards of the herbicides that will be used should be acknowledged by the EIR, such as collateral damage to non-target trees and vegetation, damage to the soil, risks to wildlife and human health, mobility and persistence in the environment, etc. The EIR should mitigate for the increased herbicide use by providing mechanisms for accountability to the public, such as a yearly publicly accessible report on pesticides used in this project, including brand names, location, date, method of application, and quantities. Prohibition of herbicide applications by “volunteers” who are not employees or contractors of the City of Oakland should also be added to Best Management Practices to prevent unauthorized herbicide applications in Oakland.

CEQA requires that alternative plans must be considered by an EIR. Typically, “no project” is one of the alternatives. A third alternative should be less destructive, not more destructive than the proposed project. For example, an alternative to destroying only non-native trees, as proposed by the VMP, would be to destroy bay laurels that are also a pyrophytic species, as well as vectors for Sudden Oak Death that has killed 50 million oaks in California since 1995. In 2019, the rate of SOD infection increased from 1% to 12% in one year in sampled trees between Richmond and San Leandro. Source: https://www.sfchronicle.com/environment/article/Sudden-oak-death-spreading-fast-California-s-14815683.php?cmpid=gsa-sfgate-result

There are several advantages to thinning bays and Monterey pines rather than eucalyptus:

Every dead oak becomes fuel. Therefore, reducing SOD infections prevents oaks from becoming fuel.

Bays branch to the ground, providing fuel ladders that are difficult to eliminate because the tree trunk often sprawls on the ground.

Removing bays instead of eucalyptus also reduces carbon loss because bays are smaller trees and they have shorter lives than eucalyptus trees, which are expected to live another 200-300 years in the Bay Area based on their longevity in their native range.

Monterey pine has a shorter lifespan than eucalyptus and it is a soft-wood tree. Therefore, removal of Monterey pine will result is less carbon loss than destruction of eucalyptus. Furthermore, Monterey pines do not resprout after destruction. Therefore, they will not require herbicide treatment to prevent resprouts as eucalyptus does. Many Monterey pines in the East Bay are nearing the end of their lives because of when they were planted as well as pine pitch canker infection.

“We ask that a 4^th alternative be considered by the EIR. A “no pesticides” alternative would acknowledge the public’s concerns about the potential for increased pesticide use in Oakland that could be enabled by the completion of the EIR. That alternative must propose a method of preventing tree resprouts without using herbicides. There are precedents for such methods. East Bay Municipal Utilities District does not use herbicides to prevent resprouts. UCSF does not use any pesticides in the Sutro Forest where thousands of trees have been destroyed and thousands more will be destroyed in the future.” Addendum 12/2/19

CEQA requires that cumulative impacts of similar projects be identified by the EIR. Fuels management projects similar to the VMP are being implemented all over the East Bay. Tree removals by PG&E should be included. The cumulative impact of all fuels management projects in the East Bay must be acknowledged by the EIR.

We hope the revised VMP will survive the public process required to bring it to fruition because we believe it will reduce fire hazards in its present form. We believe that fire hazards are real and that compromise is needed to address them. We congratulate the consultants who prepared the VMP and OFD for shepherding it to completion. Those who were involved in its preparation listened patiently and were responsive to the public’s concerns. We are grateful.

Forest Action Brigade