“The Eucalyptus is Part of California”

Monarch butterflies over-winter in California's eucalyptus groves
Monarch butterflies over-winter in California’s eucalyptus groves

The East Bay Express has published an op-ed in defense of the much maligned eucalyptus.  “The Eucalyptus is Part of California” is by Gregory Davis, a Berkeley resident.  We summarize the main points for our readers:

  • University of California, Berkeley’s plan to destroy all non-native trees—primarily eucalyptus, Monterey pine, and acacia—is characterized as a “meat-axe approach.” 
  • Applying herbicides repeatedly to prevent regrowth of non-natives is “tantamount to opening a can of worms.”  We don’t know the consequences of dousing our public land with toxic chemicals, just as we didn’t know that using Agent Orange during the War in Vietnam would permanently damage that country and its citizens.
  • The moderate approach advocated by the Hills Conservation Network is more reasonable.  Thinning and selective removal will do less damage.
  • Flammability of eucalyptus groves has been greatly exaggerated. 
  • Eucalyptus has lived in California longer than most of us have been alive.  They are more native than we are.
  • The loss of the “beauty and majesty” of eucalyptus in the hills will make hiking in the East Bay hills a less pleasant experience.  “Anyone who has hiked up the trail under the green canopy of these tall, stately, plumed-top, evergreen trees knows how precious they are.”

Thank you, Mr. Davis, for writing this article and to the East Bay Express for publishing it.  Critics of the native plant movement are learning that they must speak up if we are to save our trees.  The projects that destroy our trees finally became so big and so visible, that more people are aware of them and are more willing to defend our trees.

Eucalyptus Forest
Eucalyptus Forest

The Environmental Protection Agency evaluates the Environmental Impact Statement for FEMA projects in the East Bay

The Environmental Protection Agency (EPA) has published its comment on the Draft Environmental Impact Statement (DEIS) for the FEMA projects in the East Bay.  It is available here: FEMA DEIS – public comment – EPA.  We are pleased to tell you that the EPA shares many of our concerns about the environmental impact of these projects and they consider the evaluation of those impacts by the DEIS inadequate.  The EPA has rated this project “Environmental Concerns – Insufficient Information.”  These are the definitions of those terms:

  • “Environmental Concerns:  The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment.  Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact…”
  • “Insufficient Information:  The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment…”

EPA says, “The project could result in degradation of natural resources”

The EPA shares our opinion about the probable outcome of the proposed project:

“The document assumes that areas will naturally regenerate, once rid of non-native species.  We are concerned that some of the aspects of the project would result in degradation of natural resources and may not provide for natural regeneration.  Further, while the DEIS includes a discussion of climate change, it does not include a detailed discussion of the potential impact of climate change on the Project area.  Current research indicates that climate change could impact the amount, timing and intensity of rain and storm events; increase the length and severity of the fire season; modify the rate and distribution of harmful timber insects and diseases; and aggravate already stressed water supplies.  A significant change in the weather patterns could have important implications for the management of the Project area.”

FEMA proposed project on the right. Claremont Blvd. westbound.
FEMA proposed project on the right. Claremont Blvd. westbound.

The EPA recommends that the final EIS take into consideration the impact that climate change will have on the success of the project.  For example, as plants and animals move in response to climate change, they may no longer be viable in their historic ranges, which this project attempts to replicate.  Ironically, the project contributes to climate change by releasing tons of greenhouse gases that cause climate change.  The DEIS does not acknowledge or analyze these factors.

Completed project 10 years later

A completed project 10 years later. Southbound Grizzly Peak Blvd.

EPA says, “We note that extensive use of herbicides is proposed”

Yes, indeed, this project will require thousands of gallons of herbicide and we are delighted that the EPA has noticed this as well as the serious deficiencies of information in the DEIS regarding herbicide use:

  • There are many different formulations of Roundup with different properties, yet the DEIS does not identify which formulation of Roundup will be used.   Therefore we cannot evaluate its toxicity.
  • The DEIS does not clearly state which herbicide products will be used for what purpose and in what locations.
  • The DEIS does not clearly state the method of application of herbicides.
  • The DEIS does not acknowledge that both triclopyr and imazapyr “can migrate through the soil” which will damage the native trees and vegetation this project claims to promote.
  • The DEIS evaluates the impact of herbicides only on endangered species which may or may not be the most sensitive species to herbicides.  The final EIS must evaluate the impact of herbicides on the most sensitive species of animals, whether or not they are endangered.

The EPA is equally concerned about the impact of herbicides on human health and safety.  It therefore notes the following deficiencies in the DEIS in that regard:

  • Reports of toxicity of herbicides in the DEIS are incomplete and inaccurate.
  • The DEIS does not acknowledge the “possibility of people and or animals entering the treated areas and coming in contact with herbicides already applied.”  The Final EIS (FEIS) should therefore “clarify that there is potential for human exposure even if the chemicals do not move from the application site.”  Further, “The FEIS should include a mitigation measure to remove fruiting or other edible vegetation.”

The EPA also noted many of the troubling inaccuracies and contradictions in the DEIS that were also a concern to us:

  • The DEIS claims as “mitigation” the requirements on the labels of the herbicide products that will be used.  These are mandatory requirements for legal use of the products, not voluntary measures that can be described as “mitigation.”
  • Likewise, the DEIS claims that requiring applicators of herbicides to wear protective clothing is a “Best Management Practice.”  Wearing protective clothing is required for legal application of herbicides, not a voluntary measure.
  • Several contradictory statements are made in the DEIS regarding maximum wind speeds beyond which herbicides should not be applied.
  • The DEIS claims that the “Lowest Observed Adverse Effect Levels” of herbicides can be estimated from an experimentally derived “No-observed Adverse Effect Level” without providing any supporting reference.  The EPA asks, basically, where does that claim come from?
  • The EPA points out inconsistent and incorrect use of the phrase “Certified Pesticide Applicator.”  That may seem a small quibble, but it means that we have no idea what the qualifications will be of the people who will apply herbicides.
  • The DEIS announces that a specific adjuvant or surfactant will be used without telling us anything about the properties of that product.  The adjuvant or surfactant is the inert ingredient in a formulated herbicide product that delivers the active ingredient (the poison) to the plant.
  • The DEIS uses an outdated EPA study about the effect of glyphosate on rabbits to report the toxicity of the product on rats.  Whoops!  Old data about the wrong animal!  Picky, picky.

EPA asks, “Are the trees being removed for development?”

The EPA has apparently noticed that the DEIS mentions the long-term plans to build on some of the project areas of UC Berkeley.  Therefore, it wants to know if that’s why the trees are being destroyed: 

“Given that development is not included in the purpose and need for this Project, it is unclear whether the trees in these overlap areas would be removed for construction purposes regardless of whether they are removed as part of the proposed Project or not.”

Government is doing its job!

We are amongst the slim majority of voters who believe that government has an important job to do.  We are often disappointed by government, but we aren’t inclined to kill it because it is sometimes incompetent.  We are therefore very pleased to tell our readers that the EPA has apparently read the DEIS published by its sister/brother agency, The Federal Emergency Management Agency.  Although they did not identify many of the important issues in the DEIS, they identified some of them.  For that we are grateful as well as hopeful that the sponsors of these destructive projects will be forced to at least modify them, if not abandon them altogether.  Thank you, EPA!

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

Why does UCSF want to destroy the Sutro forest?

The short answer to that question is “I don’t know.”  However, since many of the over 1,200 signers of the petition to University of California San Francisco (UCSF) to save the forest have asked this question, it seems that they deserve some answer.  So, in this post, we will tell you the reasons that UCSF has given for its plans to destroy the forest.

UCSF makes two erroneous claims about the Sutro forest which it uses to justify its destruction.  They claim that the forest is unhealthy and that destroying most of the forest will benefit the few trees that remain.  They also claim that the forest is very flammable and that destroying most of the forest will make it less flammable.  This is our response to these claims.

The Sutro Forest is not unhealthy

Mount Sutro Forest
Mount Sutro Forest

The Save Sutro website recently posted the professional opinion of two arborists who evaluated the Sutro forest and pronounced it healthy.  We recommend that article as a starting point for anyone who wishes to be reassured on this important point.

The Draft Environmental Impact Report for UCSF’s planned project claims that the forest is old and dying.  If we don’t beat it to the punch and kill it first, it will soon die without our help.  An analogy comes to mind: “We had to destroy the village to save it,” which was the explanation given for the destruction of a village during the Vietnam War.  It didn’t make sense then and it doesn’t make sense now.

The fact is, the Sutro forest is young and in the prime of its life.  Eighty-two percent of the forest is blue gum eucalyptus.  Blue gums live in Australia from 200 to 500 years. (1)  They live toward the longer end of that range in milder climates such as the San Francisco Bay Area.  The blue gum eucalypts were planted on Mount Sutro in the 1880s.  It is still a young forest.

Another indication that the forest is young is that the individual trees are small by blue gum standards.  The study plots used by the Draft Environmental Impact Report (DEIR) to calculate how much carbon is stored in the trees found that 77% of the trunks of the trees are 5 inches in diameter at breast height or less (if the study plots are representative of the entire forest, which is questionable).  It also says that this species of eucalyptus grows very fast and that its trunk is 9 inches in diameter after only three years of growth.  In other words, the DEIR claims that the trees are old and no longer growing, yet it says that most of the trees are very small and it intends to destroy the small trees, not the big ones.  This is just one of many contradictions that we find in the DEIR. 

There is little risk of wildfire in the Sutro Forest

One of the most powerful rhetorical tools used by native plant advocates to justify the destruction of our urban forest and motivate the public to pay for these expensive projects is the fear of fire.  UCSF uses this strategy as well.  Frankly, we doubt that UCSF believes it themselves because they applied for a Federal Emergency Management Agency (FEMA) grant to pay for this project in 2008. FEMA informed UCSF that there is little risk of wildfire on Mount Sutro. UCSF withdrew its grant application rather than answer FEMA’s questions.

FEMA asked UCSF to supply scientific evidence that the project would reduce fire risk despite the fact that the project would reduce fog condensation from the tall trees which moistens the forest floor, making ignition unlikely.  FEMA also asked for scientific evidence that a wind driven wildfire would not be more likely after the destruction of the wind break provided by the forest.  UCSF chose to withdraw its grant application, presumably because they could not answer those questions. 

In 2010, UCSF applied for another fire hazard mitigation grant from the California Fire Safe Council.  The Council has funded 150 such grants in California, but they denied UCSF’s application.  That suggests that the California Fire Safe Council shares FEMA’s opinion.

You might ask, where is UCSF getting the money to pay for this project?  We don’t know, but we consider that a legitimate and important question given that UCSF is a publicly funded enterprise. 

UCSF may not be able to answer FEMA’s questions, but we can, using specific scientific studies.   In 1987, 20,000 hectares burned in a wildfire in the Shasta-Trinity National Forest.  The effects of that fire on the forest were studied by Weatherspoon and Skinner of the USDA Forest Service.  They reported the results of their study in Forest Science. (2)  They found the least amount of fire damage in those sections of the forest that had not been thinned or clear-cut.  In other words, the more trees there were, the less damage was done by the fire.  They explained that finding:

“The occurrence of lower Fire Damage Classes in uncut stands [of trees] probably is attributable largely to the absence of activity fuels [e.g., grasses] and to the relatively closed canopy, which reduces insolation [exposure to the sun], wind movement near the surface, and associated drying of fuels.  Conversely, opening the stand by partial cutting adds fuels and creates a microclimate conducive to increased fire intensities.”

In other words the denser the forest,

  • The less wind on the forest floor, thereby slowing the spread of fire
  • The more shade on the forest floor.
    • The less flammable vegetation on the forest floor
    • The more moist the forest floor

All of these factors combine to reduce fire hazard in dense forest. Likewise, in a study of fire behavior in eucalyptus forest in Australia, based on a series of experimental controlled burns, wind speed and fire spread were significantly reduced on the forest floor.(3)   Thinning the forest will not reduce fire hazard.  In fact, it will increase fire hazard.

Jon E. Keeley of the USGS is a world-renowned expert on the fire ecology of California.  We have read his recently published book (Fire in Mediterranean Ecosystems:  Ecology, Evolution and Management, Cambridge University Press, 2011) and many of his articles.  Anyone with a sincere interest in wildfire hazards in California would be wise to read these publications.  Reference to Keeley’s work is conspicuously absent from the Draft EIR. 

Keeley’s most recently published study  of specific wildfires in the Wildland-Urban-Interface (WUI) of California is most relevant to consideration of wildfire hazard in the Sutro Reserve.  (4) The authors studied the property damage resulting from specific wildfires in California “…and identified the main contributors to property loss.”  Keeley and his colleagues found that steep slopes in canyons that create wind corridors were the best predictors of fire damage and that grassy fuels were more likely to spread the fire than woody fuels.  Applying these observations to Mount Sutro, its topography is the biggest factor in the potential for wildfire and substituting the forest with grassland and scrub will result in more dangerous fuel loads. 

Scripps Ranch fire, San Diego, 2003.  All the homes burned, but the eucalypts that surrounded them did not catch fire.  New York Times
Scripps Ranch fire, San Diego, 2003. All the homes burned, but the eucalypts that surrounded them did not catch fire.

UCSF and native plant advocates make allegations about the flammability of eucalypts by misrepresenting actual wildfires in the Bay Area.  These allegations are addressed elsewhere on Million Trees, which we invite you to visit if you have more questions:

All pain, no gain

So, if the forest is healthy and destroying it does not reduce fire hazards, how can UCSF justify all the damage this project will do to the environment:

    • Releasing thousands of tons of carbon dioxide into the atmosphere that are stored in the trees and significantly reducing the ability of the forest to sequester carbon in the future, thereby contributing to climate change.
    • Increasing air pollution by reducing the ability of the forest to absorb air pollutants.
    • Using pesticides to destroy the vegetation in the understory and preventing the trees that are destroyed from resprouting.
    • Destroying the food and cover of the birds and animals that live in the forest.
    • Eliminating the noise and wind barrier that protects UCSF’s neighbors
    • Increasing the risk of wildfire by eliminating the windbreak, reducing the moisture in the forest, and littering the forest with the dead logs and wood chips of the trees that are destroyed.

We can’t imagine why UCSF wants to destroy its forest.  We understand why native plant advocates support this project because they are making the same demands all over the Bay Area.  They want land managers to destroy non-native trees because they believe that destroying them will result in the return of native plants.  The UCSF project makes no commitment to plant native plants after the forest is destroyed, with the exception of a few small areas and then only if “money is available.”  Native plants will not magically emerge from the wood-chip tomb on the forest floor.  Is it possible that UCSF shares the fantasy of native plant advocates that this destructive project will result in a landscape of grassland and chaparral which is the native landscape on Mount Sutro?  Surely a scientific institution of such distinction knows better.  Or it should. 

Here are the things you can do to help us save this beautiful forest:

  • Sign the petition to save the forest.  Available here.
  • Attend and speak at a UCSF hearing about the project:  Monday, February 25, 2013, 7 pm, Millberry Union Conference Center, 500 Parnassus Ave, Golden Gate Room                                                                             
  • Submit a written public comment by 5 PM, March 19, 2013 to UCSF Environmental Coordinator Diane Wong at EIR@planning.ucsf.edu or mail to UCSF Campus Planning, Box 0286, San Francisco, CA 94143-0286.  Include your full name and address.
  • Write to the Board of Regents to ask why a public medical institution is engaging in such a controversial, expensive, and environmentally destructive act.  Address:   Office of the Secretary and Chief of Staff to the Regents,
1111 Franklin St., 12th Floor, Oakland, CA 94607
  Fax: (510) 987-9224
  • Subscribe to the website SaveSutro.com for ongoing information and analysis.


(1)     Eucalypt ecology: Individuals to ecosystems, by Jann Elizabeth Williams, John Woinarski ,Cambridge University Press, 1997

(2)     Weatherspoon, C.P. and Skinner, C.N., “An Assessment of Factors Associated with Damage to Tree Crowns from the 1987 Wildfires in Northern California,” Forest Science, Vol. 41, No 3, pages 430-453

(3)     Gould, J.S., et. al., Project Vesta:  Fire in Dry Eucalyptus Forests, Commonwealth Scientific and Industrial Research Organisation and Department of Environment and Conservation, Western Australia, November 2007

(4)     Alexandra Syphard, Jon E. Keeley, et. al., “Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildire.” PLOS ONE, March 18, 2012

Formidable odds against reintroduction of Mission Blue butterfly

Mission Blue butterfly. Wikimedia Commons

The Mission Blue butterfly is a federal endangered species which existed historically on Twin Peaks in San Francisco.  San Francisco’s Natural Areas Program has been trying to reintroduce the Mission Blue to Twin Peaks for several years, so far with limited success.  Visit the Save Sutro website for a detailed description of these efforts which began in 2009.

The “Recovery Action Plan for the Mission Blue Butterfly at Twin Peaks Natural Area” acknowledges the difficulty of this undertaking.  It cites a study of 226 attempts to reintroduce butterflies where they have been extirpated (locally extinct).  These attempts lasted an average of 15 years.  Only 29 of the attempts were ultimately successful.  So what are the odds of success on Twin Peaks?

Identified obstacles to success

The federal Endangered Species Act requires that a recovery plan be written for each endangered species.  These recovery plans are a valuable source of information about each endangered species, the factors that resulted in their endangered status, and the plans to promote the recovery of the population.  From the recovery plan for the Mission Blue, we learn of several issues that make its reintroduction problematic at best:

  • The Mission Blue is dependent upon just 3 species of lupine for its development.  Two of these exist on Twin Peaks, but the predominant species is infected with a fungal pathogen which flares up during warmer, wetter weather.  The small population of Mission Blues on Twin Peaks crashed in 1998 when the fungal pathogen killed many of the lupines. 
  • The lupine is crowded out by scrub species if natural disturbances such as fire do not prevent natural succession from grassland to scrub such as native coyote brush.
  • Non-native species of plants are also competitors of the native lupines and their growth is encouraged by higher levels of nitrogen in the soil found in urban environments as a result of the burning of fossil fuels. 

The Natural Areas Program cannot control these factors:

  • There is no known cure for the fungal pathogen that is killing lupine.  In wetter years, it is likely to kill some of the lupine on Twin Peaks again, as it has in the past.
  • The Draft Environmental Impact Report for the Natural Areas Programs says that prescribed burns will not be conducted in the “natural areas.”  Prescribed burns are conducted by the State parks department periodically on San Bruno Mountain, where a viable population of Mission Blue butterflies exists.  This method of preventing natural succession to scrub in order to maintain a population of the butterfly’s host plant will not be an option on Twin Peaks. 
  • We should probably assume that existing automobile traffic in San Francisco will continue to contribute to nitrogen in the soil for the foreseeable future.  Higher levels of nitrogen will promote the growth of the non-native vegetation that competes with the native lupine upon which the Mission Blue depends.

Unidentified obstacles to success

Pesticide Application Notice, Twin Peaks

In addition to the issues that have been identified by federal and local recovery plans, the Natural Areas Program has introduced a new threat to the Mission Blue.  Herbicides are being used on Twin Peaks to control non-native vegetation.  Twin Peaks was sprayed with herbicides 16 times in 2010 and 19 times in 2011.  Are these herbicides a factor in the limited reproductive success of the Mission Blues that have been reintroduced to Twin Peaks?

A recently published study reports that the reproductive success of the Behr’s metalmark butterfly was significantly reduced (24-36%) by herbicides used to control non-native vegetation.  Two of those pesticides are used on Twin Peaks, imazapyr and triclopyr.  Triclopyr was used most often on Twin Peaks in 2010 and imazapyr in 2011.

The study does not explain how this harm occurs.  It observes that the three herbicides that were studied work in different ways.  It therefore speculates that the harm to the butterfly larva may be from the inactive ingredients of the pesticides which they have in common, or that the harm comes to the larva from the plant which is altered in some way by the herbicide application.  Either theory is potentially applicable to the herbicides used on Twin Peaks and consequently harmful to the Mission Blue.

Native plant advocates would like us to believe that the herbicides used to eradicate non-native plants are not harmful to animals, including humans. In fact, they don’t know that. The truth is that no one knows if herbicides are harmful to animals because there is almost no research that would answer this question.  The tests required by law by the Environmental Protection Agency to put new chemicals on the market are very limited.  The honeybee is the only insect on which the EPA is required to test chemicals before they are put on the market.  No tests are required for butterflies or any other insect. 

US Fish & Wildlife funded the research on the Behr’s metalmark butterfly which suggests that herbicides are harmful to butterflies.  US Fish & Wildlife is also the co-sponsor and co-funder of the reintroduction of the Mission Blue butterfly on Twin Peaks.  Will US Fish & Wildlife advise the Natural Areas Program that herbicide use on Twin Peaks should be stopped? 

In a more perfect world we would have the wisdom to stop using pesticides until we had some scientific evidence that they are not harmful to us and the animals with which we share the planet.

Low doses of pesticides are also hazardous to our health

We are reprinting, with permission, an article on the Save Sutro website about recent research reporting that even low doses of chemicals can be harmful to our health.  This research has serious implications for the pesticides being used by the many “restoration” projects in the San Francisco Bay Area.  This article is focused on pesticide use by San Francisco’s misnamed Natural Areas Program.  In fact, every manager of public land in the Bay Area that engages in native plant “restorations” uses pesticides to eradicate non-native species. 


When we speak up against the Natural Area Program’s frequent pesticide use, its supporters frequently tell us that – compared with say commercial agriculture – the Natural Areas Program (NAP) uses small amounts of toxic chemicals. “The dose makes the poison,” they argue.

But it’s not true.

For now, we’ll leave aside the question of whether it’s reasonable to compare NAP to  commercial agriculture (where fears of chemicals are driving a growing Organic movement). What we’d like to talk about today is recent research about pesticides, specifically, endocrine disruptors. Here’s a quote from the abstract of a study by a group of scientists:

“For decades, studies of endocrine-disrupting chemicals (EDCs) have challenged traditional concepts in toxicology, in particular the dogma of “the dose makes the poison,” because EDCs can have effects at low doses that are not predicted by effects at higher doses….

“…Whether low doses of EDCs influence certain human disorders is no longer conjecture, because epidemiological studies show that environmental exposures to EDCs are associated with human diseases and disabilities. We conclude that when nonmonotonic dose-response curves occur, the effects of low doses cannot be predicted by the effects observed at high doses.”

[Ref: Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses, Vandeberg et al, in Endocrine Reviews, March 2012]


The NAP uses several pesticides rated as “Hazardous” or “Most Hazardous” by San Francisco’s Department of the Environment. But the one they’ve favored is glyphosate — better known as Roundup or Aquamaster.

It’s strongly suspected of being an endocrine disruptor.

Here’s a 2009 study: Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines.

Another study, also published in 2009, looked at puberty and testosterone: Prepubertal exposure to commercial formulation of the herbicide glyphosate alters testosterone levels and testicular morphology. The abstract of the study ends with this sentence, “These results suggest that commercial formulation of glyphosate is a potent endocrine disruptor in vivo, causing disturbances in the reproductive development of rats when the exposure was performed during the puberty period.”

And here’s a study published in 2007, reflecting the research of a group of scientists from Texas A&M: Alteration of estrogen-regulated gene expression in human cells induced by the agricultural and horticultural herbicide glyphosate


Most people weren’t aware that pesticides were being used in so-called “Natural Areas.” The notices were small and well below eye-level. You had to be looking for them, which isn’t likely for most people out hiking or jogging by, or keeping an eye on small kids. In recent months, the labeling has improved, with taller posts and clearer information.

Now that people are beginning to notice, they’re also objecting. The response we hear most often is “Why would they use herbicides in a natural area?”

So the NAP has started posting explanations, justifying its use of toxic herbicides justifiable against “invasive plants.”

These plants, they say, are “a handful of non-native species” that are “displacing the rich biodiversity of native flora and degrading our natural heritage.”


We have several problems with this statement.

  • If it’s a “handful,” the NAP must have very big hands. From the pesticide application records, we’ve counted nearly twenty-five different plant species under attack by chemicals — including a couple that aren’t actually non-native.
  • There’s no evidence that all these plants are invasive and that they’re “displacing the rich biodiversity.” Native plants and non-native plants thrive together in natural mixed ecosystems. NAP can never eliminate all the non-native plants; the best it can achieve is a different mix, precariously maintained through intensive gardening.
  • There’s also no evidence it’s working. Using chemicals to kills things is cheap and easy, but it leaves a gap where something else will grow. Given that San Francisco’s environment has changed greatly since the 1776 cut-off used to define “native” plants, it’s not going to be those plants. Rather, what will naturally grow back will be the most invasive plant at the site. An excuse for more herbicides.
  • The NAP is destroying habitat in its quest to kill native plants. Many of the plants destroyed are bushes that provide cover and nesting places, or flowering plants that offer nectar to butterflies, bees and other pollinators and the birds and animals that feed on them. The “native flora” don’t necessarily provide much of either, even if they can be successfully gardened.

Bowling Alone with the Sierra Club

In 2000 Robert Putnam’s (Harvard University) masterpiece of American social science, Bowling Alone* was published.  He reported the significant decline of all forms of civic participation in American society and politics from the P.T.A. to voting.  Religious participation is the notable exception to this trend. 

We are deeply concerned about the increasing isolation of Americans from one another and we believe that the polarization of viewpoints, particularly in politics, is one of the consequences of this trend.  Only the highly motivated extremes of opinion are still engaged in the civic dialogue.  The middle ground is no longer represented in the debate.  However, we will focus on the topic that is relevant to Million Trees, that is, the implications for the environmental movement. 

Bowling Alone. Attribution: Xiaphias

Membership in environmental organizations reached its peak in 1995, according to Bowling Alone after decades of enormous growth since the 1960s.  This peak was consistent with public opinion regarding environmentalism.  In 1990 three-quarters of Americans considered themselves “environmentalists.”  By the end of the decade, that percentage had dropped to only 50%. 

The growth in membership was achieved by the use of a new marketing tool known as direct mail.  Think about it.  How many invitations do you receive in the mail from non-profit organizations, asking you to contribute to a wide-range of worthy causes?   Typically these organizations spend between 20-30% of their budgets on such fund raising and the rate of return on these solicitations is only 1-3% of the cost depending upon the quality of the mailing list.  Using this technique, Greenpeace tripled its membership between 1985 and 1990 to 2.35 million.

What does “membership” mean?

After tripling its membership, Greenpeace lost 85% of its members in the next 8 years.  The drop-out rate after the first year is typically 30% in these organizations.  

In fact, most contributors to these organizations don’t even consider themselves “members” in the usual sense of that word.  The commitment to the organization doesn’t extend far beyond writing a check.  Only 8% of contributors to the Environmental Defense Fund, for example, described themselves as “active” in the organization. 

These organizations are therefore distinctly different from their historical antecedents.  Participants in the civil rights movement frequently put their lives on the line.  The social lives of Rotary Club members revolved around the Rotary lodge. 

Since few people are active participants in environmental organizations, they have become “bureaucratized,” meaning they are run by and for paid professionals.  Most members have little idea what policies the professional staff has adopted on their behalf. 

The Sierra Club

In 1989, a survey of Sierra Club members determined that only 13% of its members had attended even one meeting of the Sierra ClubThe Bay Area Chapter of the Sierra Club claims to have 10,000 members, but chapter leadership of a group (the chapter is broken into many geographical groups, such as the San Francisco Group)was elected by as few as 59 votes.  The top vote-getter in the Club’s most recent election received 327 votes in a Chapter-wide race, but only one chapter group (Northern Alameda County) had more candidates than there were available seats.  In other words, there was no competition for most of the leadership seats. 

Yet, the incumbents in these leadership positions are free to determine the local policies of the Sierra Club.  Here are a few recent examples of positions taken by the Bay Area Chapter of the Sierra Club:

The opinion of the membership is not asked when these policy positions are taken by the leadership.  However, if members read the chapter’s quarterly newsletter (The Yodeler) they have the opportunity to learn about them after the fact.

The influence of the Sierra Club

We believe that the influence of the Sierra Club exceeds the size of its membership.  The Sierra Club endorses candidates for political office.  These endorsements are highly sought after because politicians believe that the endorsement confers the votes of its membership.  This belief was recently tested in the race for mayor of San Francisco. 

State Senator Leland Yee sought and received the endorsement of the Sierra Club in his bid for mayor of San Francisco.  In the past, he had been critical of the Natural Areas Program.  His stated reason for that criticism was that the veneration of native plants was offensive to his roots as an immigrant.  In particular, the Chinese community suffered horrendous discrimination in California in the 19th Century.  The rhetoric of the native plant movement is reminiscent of the xenophobia from which the Chinese community has suffered historically. 

It seems unlikely that Senator Yee’s emotional reaction to nativism changed when he sought the endorsement of the Sierra Club, but he had to disavow that opinion in order to receive the Club’s endorsement.  He did so because he believed that the votes of Sierra Club members would help him to be elected mayor of San Francisco.  His bet did not pay off.  He did not win.  In fact, he came in fourth. 

We hope that political candidates in the future will heed this warning.  The Sierra Club may have many “members” but that membership does not necessarily confer votes.  The vast majority of “members” have no commitment to the policy positions taken by the Club.

An appeal to Sierra Club members

There were over 4,000 public comments on the Environmental Impact Study for the Dog Management Plan of the Golden Gate National Recreation Area (GGNRA).  The Dog Management Plan proposes to eliminate about 80% of existing off-leash areas, which are now only 1% of the 74,000 acres of GGNRA property.  The Sierra Club supports that plan.  There were thousands of comments from people with dogs who are presently enjoying the small areas now available to them for off-leash recreation.  Sixty-four of those people said they are Sierra Club members.  That’s enough members to elect someone to a leadership position in the Club.

If you are a member of the Sierra Club, here’s what you can do to influence the Club’s policies:

  • Inform yourself of the policies of the Sierra Club. 
  • If you don’t agree with those policies, we urge you to vote in the election of officers to the leadership positions in the Sierra Club.
  •  If you don’t know the policies of the candidates, ask them. 
  •  If there are no candidates that represent your viewpoint, find candidates who do.
  • If you can’t find a candidate you can support, it’s time to vote with your feet.
  • If you leave the Club tell them why. 

Quit Bowling Alone!

Attribution: GNU Free Documentation

*Putnam, Robert, Bowling Alone:  The Collapse and Revival of American Community, Simon & Schuster, New York, 2000.  All quotes in this post are from Bowling Alone unless otherwise noted.

Natural Areas Program violates San Francisco’s pesticide policy

As the deadline for written comments on the Draft Environmental Impact Report on the Natural Resource Areas Management Plan approaches (October 31, 2011), we are reprinting with permission a post from the Save Sutro website about the many violations of San Francisco’s pesticide policy by the Natural Areas Program. 

Anyone with the time and patience to read the 600+ page EIR knows that it does not provide us with any information about the volume of pesticides used by the Natural Areas Program.  Instead, it claims that the pesticides used by the Natural Areas Program will have no impact on the environment because they are following the rules; therefore, by definition there can be no negative impact on the environment.  This seems a non-sequitur to us.  But, even if we accepted this illogical premise, the fact is, they AREN’T following the rules.  Save Sutro tells us about the many violations of the city’s pesticide policy by the so-called Natural Areas Program.

Details about how to submit your public comment by October 31 are provided at the end of this post.


As we noted in our previous post, the San Francisco Natural Areas Program seems to be using increasing amounts of toxic pesticides. From time to time, we’ve posted information here about pesticide use in the Natural Areas Program (NAP) lands. Roundup, Garlon, Imazapyr in Glen Canyon, at Pine Lake, on Twin Peaks, Mt Davidson, in the Interior Greenbelt — usually with a photograph. (Search this site on any pesticide name to see other relevant posts.)

What our readers have pointed out to us is that many of these violate the rules of the San Francisco Department of the Environment (SF DoE). We really appreciate SF DoE regulating toxic pesticides. They’re our second line of defense, when the Environmental Protection Agency seems all too ready to approve first and question later (or not question later). But they can only be effective if their rules stick.

What do we mean, violations? Well, here are a few, all from 2009 and 2010. Were there others? We don’t know.


Missing dates on notices. The signs for pesticide spraying are meant to warn people — both the NAP staff and the general public with their kids and pets — that toxic chemicals are in use in an area. It’s pretty well-designed; it requires the dates the application is planned, how it will be applied, and then when it’s been used and when it will be safe to go back in there. But as with every precaution from seat-belts to poison symbols, it only works if it’s used. From the time we started collecting notices (pictures, not the actual notices), we often found key data missing: the date and time of the actual application. That means it’s never clear when (or whether) the pesticides were used and whether it’s safe to re-enter.

Using pesticides before they’re approved. In 2009, when we published a photograph someone sent us of Imazapyr usage at Pine Lake in Stern Grove, other readers were surprised. How come? SF DoE hadn’t approved it for use, had it?

They hadn’t.

It’s been approved only in 2011, as a Tier II pesticide.

Using pesticides where they’re not approved. In November 2010, we saw a notice that said they were spraying Aquamaster (glyphosate, same active ingredient as Roundup) “near shoreline” of Lake Merced. The target plant was “ludwigia – aquatic weed.” Also known as water-primrose, this grows in the water and presumably that’s what they were after. Except… Lake Merced is red-legged frog habitat. Use there is restricted: “Note prohibition on use within buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” (Glyphosate is death on frogs.) This was a lot less than 60 feet.

Spraying when they shouldn’t be spraying. According to the SF DoE, here’s how Roundup should be used: “Spot application of areas inaccessible or too dangerous for hand methods, right of ways, utility access, or fire prevention…OK for renovations but
must put in place weed prevention measures. Note prohibition on use within
buffer zone (generally 60 feet) around water bodies in red-legged frog habitat.” But according to all the notices (and the records) they’ve been using a backpack sprayer.

Spraying Garlon without a respirator. The signs said Garlon. The SF DoE regs said that this Tier I pesticide was for “Use only for targeted treatments of high profile or highly invasive exotics via dabbing or injection. May use for targeted spraying only when dabbing or injection are not feasible, and only with use of a respirator. HIGH PRIORITY TO FIND ALTERNATIVE.” The person spraying wore a blue “space-suit” — but no respirator. (Don’t know who it was, whether a Parks employee or someone from contractor Shelterbelt. Whoever, please be careful. The regs are there for a reason.)

Poorly maintained data. Pesticide use is recorded, and again the records are pretty specific. The serial number of the use, and the date. The chemical used, its trade name and chemical name and its EPA number. Where it’s been applied, and what it’s targeting. Who applied it. Analyzing these records would give a pretty good idea of who’s using what, where and why. But… the records aren’t complete, or at least they don’t appear to be. We’ve found notices in the field with no corresponding database entry.


We understand how these violations occur. We don’t attribute adverse motives to NAP; they’re not going through the books thinking, which rule shall we break today? Remembering all the restrictions, maintaining records and filling in signs is tedious, and it’s easy to forget in the press of work. Even NASA makes mistakes.

Still, the objective of the rules is to keep us all safer and reduce the use of toxins as far as possible. With good reason, we don’t think the NAP is able to comply.

As readers will be aware, the Draft Environmental Impact Report (DEIR) for the San Francisco Natural Areas Management Plan is now open for public comment. What the DEIR says is: “Pesticide and herbicide use in the Natural Areas would be in accordance with the SFRPD’s Integrated Pest Management (IPM) Program and San Francisco’s Integrated Pest Management Ordinance...”

Seriously? Can they even do it?


[Edited to add:

For readers who are interested in commenting on the DEIR:

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17 31, 2011. [Please note, the deadline has been extended.] Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”]

The toxic pesticides used by San Francisco’s Natural Areas Program

We are reprinting with permission an article from the Save Sutro website about the pesticides being used by San Francisco’s Natural Areas Program.  The Save Sutro website is a valuable source of reliable information on any topic it covers, but it is especially knowledgeable about the pesticides being used in San Francisco. 


It’s no surprise that people are beginning to associate San Francisco’s Natural Areas Program with pesticides. It’s been using them (if the city’s records are accurate) at an increasing rate.

    • In 2009, it applied Garlon 16 times; in 2010, it was 36 times.
    • It applied Roundup (or Aquamaster, also glyphosate) only 7 times in 2009, but 42 times in 2010.

The Draft Environmental Impact Report (DEIR) on the SF Natural Areas Program is rather coy about pesticides. It doesn’t say how much it’ll use, just that it will follow all the rules when using them. (They actually have a poor track record there, but we’ll go into that in another post. [Edited to Add: We did.]) Today, we want to talk about the pesticides on their list: Roundup or Aquamaster (glyphosate); Garlon (triclopyr); Polaris (imazapyr); Milestone (aminopyralid).

SF’s Dept of the Environment classifies all of these as Tier I (Most Hazardous) or Tier II (Hazardous). There’s no mention of using any Tier III (Least Hazardous) chemicals.


We’ve talked before of Roundup, a Tier II pesticide. We hope that in view of the new research that has been surfacing, SF’s DoE will revisit that classification and consider if it deserves a Tier I rating.

  • heart breaking

    It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).

  • Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
  • It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

Classified as Tier I, Garlon is even more hazardous than Roundup. In 2010, NAP used this pesticide 36 times (sometimes in combination with Roundup, which it has said it will no longer do). We’ve written about Garlon before, Garlon in our Watershed — which has more details — and many times since then. In brief, these are the main issues:

  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, it’s absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist in dead vegetation for up to two years.

The DEIR has said that the SF NAP’s phasing out Garlon. We have some doubts; its tree-felling program will be futile without Garlon to prevent re-sprouts.


This is a very new pesticide, and not much is known about it — except that it’s very persistent. SF’s DoE has recently approved it for use as a Tier II hazard. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment. We’ve written about this one, too, when NAP recently started using it on Twin Peaks and Glen Canyon. (Actually, NAP had started using it prior to SF DoE’s approval , in Stern Grove and also at Lake Merced in 2009 and some unspecified NAP area in 2008.)

About its impact on people, we wrote: “it can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”

It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001.

MILESTONE (Aminopyralid)

Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. While the DEIR lists this as a chemical used by the NAP, they actually used Milestone very little (twice in 2010). Fortunately. SF DoE classifies it as Tier I, Most Hazardous. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.


It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.

Nevertheless, after an outcry and problems, Dow AgroSciences has stopped selling Milestone in the UK until it’s figured out.

Note to NAP and SFRPD: Don’t put clippings treated with Milestone in the green bin!


When we first started researching pesticide use in “Natural Areas” (and shocking a lot of people who’d assumed “Natural” meant natural), conspiracy theories arose: The chemicals companies were subverting the decision-makers; Pesticides were being portrayed as ecological, and the marketing machine was convincing them; Maybe there were even payoffs!

We think the explanation is much simpler: Those in charge of the Natural Areas are being asked to do the impossible. They’re given a large area, (ETA: it’s as big as Golden Gate Park but in 32 separate locations) in the middle of a city where conditions don’t even approximate those of the pre-industrial era, and asked to return it to a specific moment in time.

It doesn’t want to go.


Someone described the effort to “restore” the “Natural Areas” to “Native plants” as a constant battle. It is, and here’s why:

  • Stopping natural succession. Some areas are harder than others. Grasslands want to grow shrubs, native or not. Then, in pre-industrial San Francisco, along would come grazing browsing animals, or lightning strikes, or a landslide or two, and the shrubs would lose and the grass would win. Preserving grasslands requires killing the shrubs, and in the absence of animals and fires and landslides, it’s pesticides. Repeatedly.
  • Battling successful plants. And then there are the plants that do want to grow there, that grow there naturally (even if, like many San Franciscans, they’re not from here). These we call invasive, and want to get rid of them. That’s more pesticides. And since the plants are good at what they do, they have to be strong pesticides. Repeatedly.
  • “Invaders” compete with each other. Even if the pesticides clear an area of one kind of “invasive” plant, unless the space is intensively gardened, it’ll be taken over by other “invaders.” More pesticides.

The bison in the room (it’s native, unlike the elephant) is this: Contrary to the belief that Native Plants are so adapted to a particular place that “restorations” can be achieved merely by eradicating unwanted plants — Native Plant gardens need the same kind of maintenance and care as any garden.

Without the Sutro Stewards’ volunteers working there every month or so, the Native Garden on top of Mount Sutro would revert to its natural state: a mix of native and introduced plants. (No pesticides are used in that area, or indeed anywhere on UCSF’s Mount Sutro space. It may be the last pesticide-free wild area in San Francisco.)

Is the Natural Areas Program, as it’s currently managed, worth it? We think not, because of:

  • the ongoing and growing need for toxic herbicides;
  • the destruction of habitat for insects, birds and animals that rely on it (and this includes native species, most of which have adapted to introduced plants);
  • we think it’s an expensive misdirected effort in terms of time and treasure.

It makes sense to define small areas as Native Gardens, focus on those, and make them succeed. That can be done — as the Native Garden on Mount Sutro proves — without toxic chemicals.

Environmental Impact Report of Natural Areas Program proposes aggressive expansion

Fifteen years after San Francisco’s Natural Areas Program (NAP) began operation and 5 years after its management plan was approved, the Draft Environmental Impact Report (EIR) has finally been published.  We will briefly summarize the history of NAP, describe the plans as they were approved in 2006, and conclude with a comparison between those plans and the proposal in the EIR to aggressively expand NAP.

The Management Plan for the Natural Areas Program

In 1995 the Recreation and Park Commission approved the designation of 31“natural areas” in parks managed by the city of San Francisco. This designation committed 25% of the city’s park acreage in San Francisco, 33% including the city of Pacifica to the Natural Areas Program.  

Most park visitors were unaware of this designation until 5 years later when they finally had access to a draft of the management plan after a lengthy battle to make it available.  At that point, many park visitors could see where the Natural Areas Program was headed and many of them reacted negatively to the prospect of the destruction of non-native trees and restrictions on recreational access in popular, heavily visited parks.

The result of the long debate with the public was a revised management plan that separated the natural areas into three “management areas.”  These management areas (MAs) set priorities for the restoration of parkland to native plants:  MA-1 was the highest priority, MA-2 the second priority, and MA-3 the lowest priority.  The appeal of these priorities to critics of NAP was the commitment that there would be no tree removals in the MA-3 areas and that no legally protected species would be planted or reintroduced there, which might require further access restrictions in the future.  Forty-two percent of the total 1,080 acres of natural areas was designated as MA-3.

The management plan* was approved in 2006, after two days of public hearings at which about 200 public comments were heard by the Recreation and Park Commission.  Supporters of NAP outnumbered critics of the program.  The main message of the critics of the program was that the acreage committed to natural areas should be reduced to places in which native plants existed, which would not include acreage designated MA-3.

There were two trivial caveats to the approval of the program:  defining the circumstances under which cats could be removed from the natural areas and specifying that tree removals must be done by the Urban Forestry Division of the Recreation and Park Department (RPD).  These are some of the main features of the approved management plan:

  • Tree removals.  18,500 trees over 15 feet tall were designated for removal in MA-1  and   MA-2 areas.   In addition, non-native trees under 15 feet tall would be removed in these areas, but were not quantified because the plan did not define them as “trees”
  • Trails.  10.3 miles of trails were designated for closure in these areas.  That represented 26% of all trails in the natural areas.
  • Dog Play Areas are those areas in parks that have been officially designated for off-leash recreation.  The NAP management plan identified several dog play areas that would be monitored for possible closure in the future if necessary to protect native plants.  Those dog play areas were in Bernal Hill, McLaren and Lake Merced parks. 
  • Golf Course at Sharp Park will be reconfigured to accommodate populations of two endangered species.

The Environmental Impact Report of the Natural Areas Program

Five years after the approval of the management plan, the Environmental Impact Report (EIR) has finally been published.  The EIR identifies 4 alternatives to move forward with the implementation of the plan. The EIR identifies the “Maximum Restoration Alternative” as the “Environmentally Superior Alternative” described as follows:

“This alternative seeks to restore native habitat and convert nonnative habitat to native habitat wherever possible throughout the Natural Areas, including all management areas.”

[ETA:  This article has been updated by a more recent post which reports that a mistake has been found in the Draft Environmental Impact Report (DEIR):  The “Maximum Restoration Alternative” is not the “Environmentally Superior Alternative” as the DEIR claims on page 2.  The “Maintenance Alternative” is the “Environmentally Superior Alternative” as the DEIR says on page 526.  The mistake on page 2 has been reported to the Planning Department.  The Planning Department has acknowledged the error on page 2 and has made a written commitment to correct the error in the Final Environmental Impact Report.  Unfortunately, this correction will not be made until the public comment period is over.]

In other words, the preferred alternative would do away with the priorities identified in the management plan and treat all three management areas the same.  These are the specific implications of this proposal as described by the EIR:

  • Trees.  Non-native trees would also be removed in the MA-3 areas.  The number of trees over 15 feet tall that will be removed will exceed 18,500, but the EIR does not quantify how many trees will be removed.
  • Trails.  More trails would be closed in the MA-1 and MA-2 areas, but the EIR is not specific about how many miles of trail will be closed.
  • Dog Play Areas.  All dog play areas in MA-1 and MA-2 areas would be closed.  This will close the dog play areas in Buena Vista and Golden Gate (Southeast) parks and what little remained of McLaren (Shelley Loop) and Bernal Hill after the closures mandated by the management plan.  Dog play areas in MA-3 areas will be monitored and closed in the future if necessary to protect native plants.  The EIR predicts that all of these closures in addition to the anticipated closures of GGNRA properties to off-leash dogs will result in heavier usage of the dog play areas that remain.
  • Golf Course at Sharp Park would be further reduced by expanded habitat for endangered species.
  • Other access restrictions.  Legally protected species will be introduced in MA-3 areas, which may require further restrictions on access in the future.

The other alternatives identified in the EIR are:

  • “No Project Alternative – Under this alternative, the SFRPD would continue with the management activities authorized under the 1995 management plan.”  This alternative will close the dog play areas that were monitored since the management plan was approved in 2006: the Mesa at Lake Merced, portions of Bernal Hill and McLaren (Shelley Loop).
  • “Maximum Recreation Alternative – This alternative seeks to restore and improve recreational access to the Natural Areas wherever it does not interfere with the continued existence of native species and federally or state-listed sensitive species.”
  • “Maintenance Alternative – This alternative seeks to maintain the current distribution of native and nonnative habitat and species throughout the Natural Areas.  Under this alternative there would be no conversion of nonnative habitat to native habitat; other features of the Natural Areas would be retained.”

Rewarding Failure

Park visitors who have been watching the restoration efforts of the Natural Areas Program for the past 15 years might be surprised that NAP apparently wishes to expand its restoration efforts.  Repeated clearing of non-native plants and planting of native plants has been spectacularly unsuccessful.  Here’s a photo history of the effort at Pine Lake in Stern Grove:

One of several clearing and plantings of south shore of Pine Lake, 2003
The results, south shore of Pine Lake, 2011
North shore of Pine Lake, 2003
Results, north shore Pine Lake, 2011

If NAP has been unable to successfully restore 58% of acres of natural areas (MA-1 and MA-2) they have been actively working on for the past 15 years, why would they want to expand their empire by adding MA-3 acreage to their agenda, committing them to actively restoring all 1,080 acres of natural areas?  Aren’t they biting off more than they can chew?

Where will the money come from to fund this expanded effort?

Although NAP and its many supporters believe that this lack of success is because they haven’t been adequately funded, the NAP staff is one of the only divisions in the Recreation and Park Department that hasn’t been cut in the past 10 years.  While other gardeners have been laid off, the NAP staff has remained the same size.  How many gardeners will it take to expand their restoration efforts to the MA-3 areas as the EIR proposes?  Remember that the MA-3 areas are 42% of the total NAP acreage.  Will NAP be given a 42% increase in their staff?  One wonders where the money for such an increase in staff would be taken from.

How much more herbicide will be used in this expanded effort?

Will a 42% increase in actively management NAP acreage require more herbicide use?  The Natural Areas Program applied herbicides to the so-called “natural areas” 69 times in 2010. Most of those applications were of the most toxic herbicide (Garlon) for which the Natural Areas Program was granted exceptional permission to use by the Department of the Environment.  How much more herbicide must be used by NAP if they actively manage the MA-3 areas?  The EIR is curiously silent on this question.

Public Comment Opportunities

The public will have two opportunities to comment on the EIR and its “environmentally superior alternative” which will aggressively expand the restoration efforts of the Natural Areas Program, require more tree removals and recreational access restrictions, probably cost much more, and probably increase the use of herbicides.

  • “A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”
  • “Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17, 2011*. Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”
  • “If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”

*[ETA:  The deadline for written comments has been extended to October 31, 2011, at the request of the Planning Commission.]

If you have an opinion about the expansion of the Natural Areas Program proposed by the Environmental Impact Report  you would be wise to speak/write now.  It is your last opportunity to do so.


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