An epilogue to the saga of the San Francisco Natural Areas Program

On December 15, 2016, the San Francisco Planning Commission approved the Environmental Impact Report for the Natural Areas Program and the Recreation and Parks Commission approved the management plan for the Natural Areas Program.  The public hearing was over 6 hours long and is available for viewing HERE.  Although we watched the hearing, we won’t try to summarize it here because readers can watch it if they wish.  Rather we will comment on a few conspicuous observations about the hearing.

The most noteworthy feature of the hearing was that virtually all of the supporters of the EIR and the Natural Areas Program were allowed to speak first.  Critics of the program were called on last.  If you have spoken at such a hearing, you know that speakers submit a speaker’s card on which they indicate their support or opposition for the agenda item when they arrive.  Typically, speakers are called in the order in which they arrive at the hearing.  This usual procedure was apparently not followed in this case.

The main disadvantage of not being called upon in the order in which speakers arrive is that when a hearing is 6 hours long, many people with other responsibilities—such as work or family obligations—are forced to leave before their names are called.  In the case of this hearing, I heard a number of names called of people whom I knew to be critics of NAP, who did not speak, presumably because they waited their turn but weren’t called in the order of their arrival.

Another conspicuous feature of this hearing was that the vast majority of speakers in favor of the EIR and the management plan either work directly for the program or are affiliated with it.  Many supporting speakers were representatives of non-profits that conduct similar projects or they bring children into the parks to “educate” them about native plants.  Their presence at the hearing was therefore a work responsibility which enabled them to spend an unlimited amount of time at the hearing.

This is an illustration of the biggest obstacle to the realization that nativism is a destructive agenda based on outdated scientific hypotheses for which there is no empirical evidence.  In a word, “restoration” ecology is now a multi-million dollar industry in which many people are employed.  Therefore, there is vested economic interest in continuing such efforts whether or not they are successful or beneficial.

Criticisms of the Natural Areas Program and its EIR

The speakers who opposed the approval of the management plan and its EIR were members of the general public who are neighbors of the so-called “natural areas.”  They mentioned the destruction of trees (and the subsequent loss of sequestered carbon) and the use of herbicides as their primary objection to the plans.  Another important issue was the restrictions on recreational access such as the closure of 10 miles of trails and the requirement that all access be confined to the trails that remain.  These are issues with which our readers are familiar, so we won’t elaborate.

Comments based on personal experience with specific “natural areas” seemed most effective.  One fellow said he had participated as a volunteer in several big plantings of native plants in a natural area.  The plants died each time and presently few plants have survived several attempts to “restore” this so-called natural area.  This experience had led this speaker to conclude that attempts to “restore” this park to native plants were futile.

A neighbor of Glen Canyon Park showed pictures of the impact on her neighborhood of the destruction of trees in the park several years ago.  Her neighborhood has lost its windbreak and therefore dust from the bare ground is blowing into their homes.  Their beautiful view of the trees has been replaced by bare ground.

The Natural Areas Program began 20 years ago and has been fully staffed and funded since its inception.  Therefore, it should be judged by what it has accomplished.  It has closed trails, destroyed trees, and built fences.  It has repeatedly destroyed vegetation with herbicides and planted those areas with native plants.  The native plants have died, in some cases several times in 20 years.  In other words, it has little useful to show for 20 years of investment of effort and money.  Since it has not been successful after 20 years, it seems insane to invest another 20 years of money and effort.  Remember that one definition of insanity is doing the same thing over and over and expecting a different outcome.

Support for the Natural Areas Program

We hesitate to use the word “lie” to describe the justifications for the Natural Areas Program, but after listening to hours of testimony by its supporters, we will use that word to describe a few of their claims:

  • The most effective lie is that all the trees they destroy will be replaced with native trees. In fact, no such commitment is made in the management plan, which says explicitly that the natural areas will be converted to grassland and dune scrub.  This “replacement” fiction is mentioned in the EIR.  However, the EIR makes no commitment to planting the replacement trees in the areas or even the same parks where the trees are destroyed.  This important caveat to the commitment to replace the trees was not mentioned by any of the speakers in support of the plans, including NAP’s leadership.  In the case of the 15,000 trees that will be destroyed at Sharp Park, calling those removals anything other than a clear-cut is a lie.
  • Inaccurate descriptions of NAP’s use of herbicides also qualify as lies. The executive director claimed during the hearing that only 2.67 quarts of “active ingredient” were used in the natural areas in 2016. In fact, public records requests inform us that NAP used 1 gallon (4 quarts) of active ingredient from January 2016 to October 2016.  The “active ingredient” is only a fraction of the amount of the formulated product.  The “inert” ingredients in the formulated product are often considered hazardous.  In other words, reporting only the volume of active ingredient underestimates the amount of herbicide being applied.  The number of pesticide applications done by NAP is another way to evaluate the magnitude of pesticides used by NAP.  From January 2016 to October 2016, pesticides were applied in the natural areas 111 times, which is 85% of all pesticide applications in park areas other than Harding Park (which is a golf course maintained to professional competition standards with contractual obligations regarding turf maintenance).  A full report of NAP’s pesticide use is available HERE.

    Courtesy San Francisco Forest Alliance
    Courtesy San Francisco Forest Alliance
  • Claims that the forest in the natural areas will be “managed” for forest health are false. The management plan says explicitly that the trees will be removed for the purpose of expanding native plant gardens that require full sun.  These areas will not be “thinned” as supporters claim.  Rather they will be removed along the leading edge of the forest in order to create more unshaded ground for planting native plants.  The health of the trees is not the criterion for their removal.  These tree removals will not benefit the forest.

However, most of the statements made by supporters are not lies.  Rather they are faithful repetitions of an ideology that most of them probably believe.  Here are a few examples:

  • Nativists believe that native animals require native plants. There is no empirical evidence to support that belief.  All empirical studies find equal numbers of insects, birds, amphibians, etc., using non-native plants.
  • Nativists claim that native pollinators require specific native plants. With few exceptions this belief is mistaken.  The monarch butterfly, for example, is as willing and able to use one of the many non-native species of milkweed as it is a native species.  Some butterflies require a specific genus of plant as its host, but a genus is typically composed of hundreds of species of which many are not native.
  • Nativists believe that the immutable relationship between specific animals and specific plants has evolved over “thousands of years.” They are mistaken.  Animals adapt much more quickly to changes in the environment.  Many changes in plants and animals have been observed over a period of years, rather than a period of centuries, let alone millennia.

Many of the supporters of the NAP plans mentioned that native plants would somehow mitigate climate change.  This is a mysterious notion that I cannot explain.  If we are destroying tens of thousands of trees that store tons of carbon, how can we claim this will reduce climate change?  The grassland that is the goal of these “restoration” projects will store a small fraction of the amount of carbon stored by the trees.  Is this absurd claim a reflection of ignorance about carbon storage?  Or is it a strategy intended to confuse the public?  Whatever the motivation, the claim that native plants mitigate climate change is NOT true.

The nativists apparently do not understand that the ranges of native plants and animals have changed in response to changes in the climate and they will continue to change.  They aren’t stopping climate change by planting native plants.  In fact, climate change requires that the concept of “native” be redefined.  That’s why their projects are unrealistic and futile because they are based on a climate that no longer exists.

The epilogue

The San Francisco Forest Alliance has announced its intention to appeal the certification of the Environmental Impact Report to the San Francisco Board of Supervisors.  This appeal will be heard sometime in 2017.  You will be notified of the hearing if you will subscribe to the Forest Alliance website:  http//

Meanwhile, the Forest Alliance will ask the City of San Francisco to prohibit the use of the most toxic herbicides in the city’s parks.  There will be two public hearings regarding the city’s pesticide policies and practices:

  • Monday, December 19, 2016, 5 pm. This is a public hearing by San Francisco’s Integrated Pest Management (IPM) Program.  Details about that hearing are available HERE.
  • Tuesday, January 24, 2017. The Commission on the Environment will consider the recommendations of the IPM Program at this hearing.  The Forest Alliance will publish the details of that hearing when they are available.

Best Wishes for a BETTER 2017

The certification of the EIR and the approval of the NAP management plan is not the holiday gift that we were hoping for.  In fact, the entire year of 2016 wasn’t much of a gift to those who believe government has an important and valuable job to do.  We look forward to a better year in 2017 and we wish our readers all the best for the New Year.