California Natural Resources Agency has published the draft of “Pathways to 30X30 California” and has invited the public to comment on the draft by February 15, 2022. “Pathways to 30X30” is the last in a series of documents that defines the program before implementation in February 2022, when distribution will begin of $15 Billion dollars to public and non-governmental agencies to fund specific projects.
To recap the process that began in October 2020 with the passage of an Executive Order:
In October 2020, Governor Newsom signed Executive Order N-82-20 “enlisting California’s vast network of natural and working lands – forests, rangelands, farms, wetlands, coast, deserts and urban greenspaces – in the fight against climate change. A core pillar of Governor Newsom’s climate agenda, these novel approaches will help clean the air and water for communities throughout the state and support California’s unique biodiversity.” The program and its implications are described by Conservation Sense and Nonsense HERE.
California Natural Resources Agency held a series of public workshops in summer 2021 that were theoretically an opportunity for the public to participate in the process of defining the program. Conservation Sense and Nonsense identified potential opportunities as well as pitfalls of the program HERE.
California Natural Resources Agency published the first draft of implementation plans in fall 2021. Conservation Sense and Nonsense published its favorable opinion of the first draft that is available HERE.
The draft of the final implementation document is disappointing. My public comment on the draft of “Pathways to 30X30” is below. To preview it briefly here, this is its concluding paragraph: “California’s 30X30 initiative had great potential to improve the environment rather than damaging it further. Instead, draft “Pathways to 30X30” suggests that opportunity may be squandered. Of course, the proof will be in the projects, but for the moment it looks as though the lengthy public process may have been a charade intended to benefit the “restoration” industry, not the environment or the public.”
Please consider writing your own public comment by February 15, 2022.
Letter via postal mail: California Natural Resources Agency, 715 P Street, 20th Floor, Sacramento, CA 95814;
Voice message: 1 (800) 417-0668.
There will be a virtual meeting on Tuesday, February 1, 2022, 3-6 pm in which the public will be invited to make 2 minute comments. Register HERE.
TO: California Natural Resources Agency
RE: Public comment on draft “Pathways to 30X30”
I have attended the public workshops regarding the 30X30 initiative and sent written feedback when given the opportunity. I am therefore in a position to tell you that the “Draft Pathways to 30X30” is a significant retreat from principles defined by previous drafts because it is so vague that it is meaningless. Any project could be approved within its limitless boundaries. The document puts CNRA in the position to do whatever it wishes, including violate principles defined in previous draft documents.
My public comment is a reminder of commitments made in previous drafts and a request that they be reinstated in the final version of the Draft “Pathways to 30X30” document:
“Pathways to 30X30” must confirm its commitment to reducing the use of pesticides on public lands. The draft mentions the need to “avoid toxic chemicals” only in the context of working lands. That commitment must also be made for public parks and open spaces because widespread pesticide use is exposing the public and wildlife to dangerous pesticides and killing harmless plants while damaging the soil.
Unlike the previous draft, “Climate Smart Strategy,” “Pathways to 30X30” requires the exclusive use of native plants, which contradicts the commitment to “promote climate-smart management actions.” The ranges of native plants have changed and must continue to change because native plants are no longer adapted to the climate. We cannot reduce greenhouse gas emissions causing climate change if we cannot plant tree species that are capable of surviving in our changed climate, as acknowledged by previous draft documents. As Steve Gaines said in the January 12th public meeting regarding “Pathways to 30X30,” “We must help species move [because the changing climate requires that they do].”
There are significant omissions in “Pathways to 30X30” that epitomize my disappointment in this draft:
The draft kicks the can down the road with respect to integrating climate change into consideration of projects funded by the initiative: “Designations have not yet been established that emphasize climate benefits such as carbon sequestration or buffering climate impacts. While the definition of conserved lands for 30×30 builds upon existing designations, it will be important to integrate climate…” (pg 26) Climate change is the underlying cause of most problems in the environment, yet “Pathways to 30X30” dodges the issue by declining to take the issue into consideration as it distributes millions of grant dollars to projects that are toxic band aides on the symptoms of climate change.
The 30X30 initiative made a commitment to protecting 30% of California’s land and coastal waters. At 24%, we are close to that goal for land, but at only 16% we are far from the goal for coastal waters. Yet, the draft declines to protect more marine waters: “MPA [Marine Protected Areas] Network expansion will not be a component of meeting the State’s 30×30 marine conservation goals.” (pg 29, deeply embedded in fine print) The excuse for this omission is that the decadal review of existing MPAs won’t be completed for another year. That is not a legitimate reason for refusing to designate new MPAs. The evaluation of existing MPAs can and should be completed and inform the management of new MPAs going forward.
The lack of guidance in “Pathways to 30X30” is particularly dangerous because California law has recently been revised to exempt projects considered “restorations” from CEQA requirements for Environmental Impact Reports for three years, ending January 1, 2025. An Environmental Impact Report is the public’s only opportunity to preview planned projects and challenge them within the confines of CEQA law. The public is effectively shut out from the process of distributing millions of grant dollars of the public’s tax money by this blanket exemption on CEQA requirements for an EIR.
The Draft of “Pathways to 30X30” writes a big blank check for projects that will potentially increase the use of pesticides on our public lands and increase greenhouse gas emissions by destroying plants and trees that sequester carbon and are capable of surviving our current and anticipated climate.
California’s 30X30 initiative had great potential to improve the environment rather than damaging it further. Instead, draft “Pathways to 30X30” suggests that opportunity may be squandered. Of course, the proof will be in the projects, but for the moment it looks as though the lengthy public process may have been a charade intended to benefit the “restoration” industry, not the environment or the public.
There are chemical and non-chemical approaches to native plant restoration. Neither succeeds. Non-chemical methods are labor-intensive, which makes them prohibitively expensive. Chemicals are cheaper and they kill non-native plants, but they don’t restore native plants because they kill them and damage the soil. Either strategy must be repeated continuously to be maintained. This article is the 25-year story of reaching the conclusion that neither chemical nor non-chemical approaches are capable of restoring native plants on a landscape scale. Where do we go from here?
In 2014, the California Invasive Plant Council (Cal-IPC) conducted a survey of land managers to learn what methods they were using to control plants they considered “invasive.” The Cal-IPC survey reported that herbicides are used by94% of land managers and 62% use them frequently. Glyphosate was the most frequently used herbicide by far. In 2014, no other eradication method was used more frequently than herbicides.
We have learned a great deal about the dangers of herbicides since 2014.
The World Health Organization has categorized the most frequently used herbicide—glyphosate—as a probable carcinogen.
The US Environmental Protection Agency has finally published its Biological Evaluation (BE) of the impact of glyphosate products(all registered formulations of glyphosate products were studied) on endangered animals (mammals, birds, amphibians, reptiles, fish, invertebrates) and plants. The BE reports that 1,676 endangered species are “likely adversely affected” by glyphosate products. That is93% of the total of 1,795 endangered species evaluated by the study. Both agricultural and non-agricultural uses of glyphosate products were evaluated by the BE. Although only endangered plants and animals were evaluated by the BE, we should assume that all other plants and animals are likewise harmed by glyphosate because the botanical and physiological functions of plants and animals are the same, whether or not they are endangered.
How have land managers responded to the dangers of herbicides?
Chris Geiger, director of the integrated pest management program at the San Francisco Department of the Environment, told San Francisco Public Press that although the city has reduced its use of glyphosate outside parks, it won’t ban glyphosate because it hasn’t found a more efficient or safer alternative for controlling some weeds. He said, “In habitat management, there are certain plants you cannot remove from a natural area by hand.”
San Francisco’s IPM program recently published “Pest Prevention by Design Guide” that illustrates the bind they are in with respect to promoting native plants while trying to reduce pesticide use. On the one hand, the Guide promotes the use of native plants in landscape design plans by making the usual claim that “Native species are generally best suited to supporting local insect populations and ecosystems.” On the other hand, the Guide recommends the use of “pest resistant” species that are not eaten by insects and grazing animals and are capable of outcompeting weeds. Can’t have it both ways, folks!!
East Bay Regional Park District has made a commitment to phase out the use of glyphosate in developed areas such as parking lots, playgrounds and picnic areas. However, EBRPD remains committed to using glyphosate and other herbicides to eradicate non-native plants on undeveloped park land. In 2020, no glyphosate was used in developed areas, but about 23 gallons of glyphosate were used to eradicate non-native plants on undeveloped park land. Twenty-one gallons of triclopyr were also used to eradicate non-native shrubs and to prevent non-native trees from resprouting after they were cut down. They continued the 15-year effort to eradicate spartina marsh grass with imazapyr. A few other selective herbicides were used on other eradication projects. (2)
In the San Francisco Bay Area, most land managers are still committed to using herbicides, particularly in so-called “natural areas,” regardless of the damage herbicides do to human health, wildlife, and native plants. In fact, the City of Oakland is planning to begin using herbicides on 2,000 acres of public parks and open spaces for the first time to implement its vegetation management plan. The vegetation management plan is both a fuels reduction program and a “resource protection” program, which is a euphemism for native plant “restoration.”
“It is estimated that if the City were to rely on hand removal and mechanical treatments in place of herbicide, it would cost the City up to 40 times more to treat these areas than under the VMP. The cost for herbicide treatments, not including any associated physical treatments, is approximately $250-$500 per acre. This reflects a range of potential vegetation conditions, vegetation types, and densities. The cost for hand removal and mechanical treatments is estimated at approximately $1,000-$4,000 per acre, using the same range of site-specific conditions.” (page 5-9)
In other words, herbicides are the preferred method of killing non-native plants because it is the cheapest method. However, there is another reason why herbicides are preferred to non-chemical methods. There isn’t a non-chemical method that is more effective than using herbicides.
Looking for an alternative to herbicides
As we should expect, new information about glyphosate has increased the public’s awareness of the dangers of pesticides. California Invasive Plant Council has responded to the public’s growing awareness and concern about the herbicides to which they are exposed in our public parks and open spaces. They recently published a comprehensive 300-page brochure entitled “Best Management Practices for Non-Chemical Weed Control.” (1) Many highly qualified land managers participated in the preparation of this credible publication. The Cal-IPC brochure is credible because it frankly admits that no method of eradication is without problems. Irrigation and intensive planting are required for good results, but without continuing regular maintenance the results are only temporary. Few land managers have the resources needed for success.
If you wonder why herbicides are the preferred method of eradicating non-native plants, reading Cal-IPC’s brochure about non-chemical methods will tell you why. There is no non-chemical method that achieves better results than using herbicide.
Herbicides are not a magic bullet
Herbicides are the most frequently used method of killing non-native plants, but using herbicides does NOT result in a native landscape.“Lessons learned from invasive plant control experiments: a systematic review and meta-analysis,” analyzed 355 studies published from 1960 to 2009 to determine which control efforts were most effective at eradicating the target plants and which method was most successful in restoring native plants. The analysis found that “More than 55% of the studies applied herbicide for invasive plant control.” Herbicides were most effective at reducing invasive plant cover, “but this was not accompanied by a substantial increase in native species,” because, “Impacts to native species can be greatest when programs involve herbicide application.” It’s not possible to kill non-native plants without simultaneously killing native plants and damaging the soil.
Reaching a dead—and deadly—end
Public land managers in the San Francisco Bay Area have been trying to restore native landscapes for over 25 years. Every project begins by eradicating non-native plants, usually with herbicides. Our public parks have been poisoned repeatedly, but native landscapes have not replaced the plants that were killed. Meanwhile, we have learned that herbicides are dangerous to our health and animals who live in our parks.
The only viable alternative to using herbicides to “restore” native plants is to change the goals for native plant restorations such that herbicides won’t be required:
An exclusively native landscape cannot be achieved where native plants have never existed, such as the many parks along the bay waterfront that were built on landfill. It is an unrealistic goal.
Given that no effective method of achieving this unrealistic goal has been found after 25 years and the most popular method is poisoning our environment, it is time to stop trying.
Smaller, achievable goals must be set. Landscape scale projects should be abandoned and replaced with small scale projects where native plants already exist.
Smaller areas can be managed without using herbicides because they will be affordable to manage with labor-intensive methods that are more expensive.
If smaller projects are more successful, they will be less controversial. The projects are unpopular partly because they aren’t successful.
We’ll get to the study later, but first let’s address the statement about ecological fitting. Ecological fitting is more accurately described as an observation, rather than a theory or hypothesis and it does not originate with Art Shapiro. The first observation of ecological fitting was recorded by Dan Janzen in 1980 and described by other ecologists as “the process whereby organisms colonize and persist in novel environments, use novel resources or form novel associations with other species as a result of the suites of traits that they carry at the time they encounter the novel condition.” (1) Ecological fitting is an alternative to the view that relationships between plants and insects and parasites and hosts are the result of co-evolution. It is consistent with the observation that adaptation to new arrivals in an ecosystem often occurs without evolutionary change and can occur more rapidly than co-evolution would require.
Ecological Laboratory Science
The Burghardt/Tallamy study is a laboratory experiment in the sense that it creates an artificial environment by planting a garden in which it chooses the plant species and then inventories the insect visitors to the garden. In one garden, native plant species were paired with a closely related species of non-native plant in the same genus (called congeners). In another, distant garden, native plant species were paired with unrelated species of non-native plants. The insect visitors that were counted are specifically the larvae stages (caterpillars) of lepidoptera (moths and butterflies). The adult stage of the caterpillars (moths and butterflies) were not inventoried, nor were members of the other 28 insect orders.
The study considers caterpillars “specialists” if they feed on three or fewer plant families. The authors make this determination based on scientific literature and on observations of their artificially created garden. Using scientific literature, 30% of visiting caterpillar species to the experimental garden were specialists. Using actual visits to their experimental garden, 64% of visiting caterpillars were specialists. The difference is as we should expect because the scientific literature is based on the behavior of caterpillars in the field, but the study confines the choices of the caterpillars to a few specific plant species chosen by the authors of the study. In other words, caterpillars in the experimental garden had fewer choices of plant species.
The inventory of caterpillars was conducted over two summer months in 2008 and three summer months in 2009. Findings were very different in the two years of the study: “We found no difference between the total Lepidoptera larvae supported by native plants and their non-native congeners in 2008, but found over three fold more larvae on natives in 2009. In 2008 there was no difference in the abundance of generalists on native and non-native congeners, but natives supported more than twice as many generalists as non-natives in 2009.” (2) Similar results were reported for species richness (number of different larvae species). When paired with unrelated non-native plants, caterpillars showed a significant preference for native plant species, as we should expect because the plants were not chemically similar.
Although on average, native species attracted more
caterpillars than the non-native congener with which they were paired, the
strength of that difference varied significantly. One matched pair
attracted eight times as many caterpillars to the native plant compared to the
non-native plant. Another matched pair
attracted slightly more caterpillars to the non-native plant compared to the
The Burghardt/Tallamy study is often cited by native plant advocates in support of their belief that insects require native plants for survival. This generalization is not supported by the results of the Burghardt/Tallamy study because:
Statements made by native plant advocates about the degree to which caterpillars are “specialized” are often exaggerated. When a diverse landscape is available to caterpillars, scientific literature reports that specialization to a few plant families is found in only 30% of the 72 caterpillar species identified by this study.
The Burghardt/Tallamy study was conducted on the East Coast where the climate is different than California. It snows in the winter and it rains during the summer, unlike most of California. Our native plants are therefore different from natives on the East Coast. The Burghardt/Tallamy study was conducted in the summer months from June to August. Native plants in California are no longer blooming and many are dormant during summer months unless they are irrigated. The findings of the Burghardt/Tallamy study are therefore not applicable to California unless they can be replicated here.
Comparison of laboratory with field studies
The Burghardt/Tallamy study does not contradict the findings of Professor Art Shapiro because Professor Shapiro is studying butterflies (not moths) in “natural areas” that have not been artificially created by choosing a limited number of plant species. In other words, the adult and larvae stages of butterflies that Professor Shapiro studies have more options, and when they do they are as likely to choose a non-native plant as a native plant for both host plant and food plant. You might say, Professor Shapiro’s study occurs in the “real world” and the Burghardt/Tallamy study occurs in an artificially created world.
The credibility and relevance of Professor Shapiro’s studies are also based on 47 years of visiting his research plots at least 250 days per year, that is, year around. During that period of time, he recorded his observations and they were statistically analyzed for the study he published in 2003. (3) His study is of particular interest as the climate changes rapidly because the length of the study also enables us to observe the impact of climate change on our butterfly population in the Bay Area. In contrast the Burghardt/Tallamy study was conducted in a total of 5 months over a total of two years. Population trends cannot be determined from such a short study.
Burghardt/Tallamy study is consistent with
mission of Million Trees
The Burghardt/Tallamy study does not contradict anything Million Trees advocates for. Decisions to plant a particular species and the decision to eradicate a particular species are entirely different. Gardeners should plant whatever they prefer, in my opinion. When planting decisions are made for public land, I prefer that plants be capable of surviving current local and climate conditions. When my tax dollars are being spent, I prefer that they not be wasted. Besides, I hate watching plants and trees die in the parks I visit.
This study is consistent with my view that non-native plants don’t threaten the survival of insects unless they replace native plants that insects prefer. The Burghardt/Tallamy study quite rightly does not say that they do. Local experience in the Bay Area informs me that they rarely do. To the extent that they have replaced native plants, they are better adapted to current conditions in a specific location. Eradicating them rarely results in native plants successfully replacing them. As the climate continues to rapidly change, the failure of native plant “restorations” is inevitable because vegetation changes when the climate changes.
The Burghardt/Tallamy study does not justify eradication of non-native plants because it does not take into account the damage done by the methods used to eradicate non-native plants. Since most eradication projects use herbicides, we speculate that more harm is done to insects by herbicides than by the existence of non-native plants.
Many thanks to Jake Sigg for creating this opportunity for
dialogue with native plant advocates. I
am grateful for the window into the community of native plant advocates that
Jake’s Nature News provides.
Agosta, Salvatore J.; Jeffrey A. Klemens (2008). “Ecological fitting by phenotypically flexible genotypes: implications for species associations, community assembly and evolution”. Ecology Letters. 11 (11): 1123–1134.
Oyster Bay is one of several East Bay Regional Parks along the east side of the bay that is a former garbage dump built on landfill. We visited Oyster Bay for the first time in 2011 after a former Deputy General Manager of the park district told us that it is a “beautiful native plant garden” and a model for a similar project at Albany Bulb, another former garbage dump being “restored” by the park district.
When we visited seven years ago, we found a park in the early stages of being destroyed in order to rebuild it as a native plant museum. Since there were never any native plants on this landfill, we can’t call it a “restoration.” We took many pictures of the park in 2011 that are available HERE.
Seven years ago, most of Oyster Bay was acres of non-native annual grasses. Since then, most of those acres of grassland have been plowed up and are in various stages of being planted with (one species?) native bunch grass (purple needle grass?).
On our May 1st visit, there were at least 8 pesticide application notices posted where the native bunch grass has been planted. Several different herbicides will be used in those sprayings: glyphosate, Garlon (triclopyr), and Milestone (aminopyralid).
Grassland “restoration” in California is notoriously difficult. Million Trees has published several articles about futile attempts to convert non-native annual grassland to native grassland:
We wish EBRPD good luck in this effort to convert acres of non-native annual grass into native bunch grass. Frankly, it looks like a lot of public money down the drain to us. It also looks like an excuse to use a lot of herbicide. Who benefits from this project? Not the taxpayer. Not the park visitor who is now exposed to a lot of herbicide that wasn’t required in the past. Not the wildlife, birds, and insects that lived in and ate the non-native vegetation. (We spotted a coyote running through the stumps of bunch grass. Was he/she looking for cover?)
Destroying trees and replacing them
When we visited Oyster Bay in 2011, many trees had already been destroyed, but there was still a dense forest of non-native pittosporum. That forest is gone and the park district has planted one small area with native trees as a “visual screen” of the Waste Management Facility next door. We identified these native trees and shrubs: ironwood (native to the Channel Islands), coast live oak, buckeye, toyon, juniper, mallow, holly leaf cherry, and redbud.
We also saw a notice of herbicide application near the trees. The ground around the trees was covered in green dye, which is added to herbicide when it is sprayed so that the applicator can tell what is done. There were men dressed in white hazard suits, driving park district trucks, apparently getting ready to continue the application of herbicides.
It wasn’t a fun day at the park and it isn’t fun to write about it. I decided to tell you about this visit after reading the most recent edition of the Journal of the California Native Plant Society, Fremontia (Vol. 46 No. 1). The introductory article of this “Special Issue on Urban Wildlands” is illustrated with a photo of Oyster Bay. I nearly choked on this statement in that article: “In order to control invasive plants, agencies and volunteers have sometimes resorted to using herbicides as a step in integrated pest control. While use of herbicides is contentious, the use for spot treatments has enabled small groups of volunteers to successfully eliminate invasive weeds in some areas where future herbicide use will not be needed.”
Attempting to eradicate non-native plants is NOT a short-term project. It is a forever commitment to using herbicides…LOTS of herbicide. To claim otherwise is to mislead, unless you are completely ignorant of what is actually being done.
You are paying for this
Another reason why I am publishing this article is to inform you that you are paying for these projects. The park district recently published a list of 492 active park improvement projects in 2018 (scroll down to page 71), many of which are native plant “restorations.” The majority of them are being paid for with grants of public money from federal, State, and local agencies as well as a few parcel taxes. Taxpayers had the opportunity to vote for the parcel taxes. They will have the opportunity to vote for new sources of funding for these projects:
Proposition 68 will provide $4.1 BILLION dollars for “park and water” improvements. It will be on your ballot on June 5, 2018. Roughly a third of the money will be allocated for “protection of natural habitats.” (1) Although the project at Oyster Bay does not look “natural” to us, that’s how the park district and other public agencies categorize these projects that (attempt to) convert non-native vegetation to native vegetation.
Measure CC renewal will be on the ballot in Alameda and Contra Costa counties on November 6, 2018. The park district has made a commitment to allocate 40% of the available funding to “natural resource projects.” Although the anticipated revenue (about $50 million) seems small, it is used as leverage to apply for big State grants, which require cost-sharing funding. Measure CC is essentially seed money for the much bigger federal and State funding sources.
I would like to vote for both of these measures because our parks are very important to me. If voting for these measures would actually improve the parks, I would do so. But that’s not what I see happening in our parks. What I see is a lot of damage: tree stumps, piles of wood chips, dead vegetation killed by herbicides, herbicide application notices, signs telling me not to step on fragile plants, etc.
“States big bond for little projects,” SF Chronicle, May 5, 2018
East Bay Regional Park District is preparing to put a parcel tax on the ballot in 2018 that will extend the funding of park improvements for another 15 years. The public has been invited to tell the park district what improvement projects should be funded by the parcel tax in the future. We are publishing a series of such public comments that we hope will inspire the public to submit their own suggestions to the park district.
CC: Board of Directors
FROM: Park Advocate
RE: Suggestion for Measure CC Projects
Climate change is the environmental issue of our time. The climate has changed and it will continue to change. If park improvement projects are going to be successful, they must have realistic goals that take into consideration the changes that have occurred and the changes anticipated in the future.
The restoration of native grassland is an example of a project that is not realistic, given current environmental conditions. Grassland in California has been 98% non-native annual grasses for over 150 years. Mediterranean annual grasses were brought from Mexico to California by the cattle of the Spaniards in the early 19th century.
David Amme is one of the co-founders of The California Native Grass Association and was one of the authors of East Bay Regional Park District’s “Wildfire Hazard Reduction and Resource Management Plan” while employed by EBRPD. In an article he wrote for Bay Nature he listed a few small remnants of native grasses in the East Bay and advised those who attempt to find them, “As you go searching for these native grasses, you’ll see firsthand that the introduction of the Mediterranean annual grasses is the juggernaut that has forever changed the balance and composition of our grasslands.” That article is available HERE.
The park district seems to understand the futility of trying to transform non-native annual grassland to native bunch grasses. Here are two signs in two of the EBRPD’s parks that acknowledge the reality of California’s grassland.
Yet, despite this acknowledgement, the park district continues to expand its efforts to transform the parks into native grassland. Park visitors recently observed a failed experiment to introduce native grasses to one of the parks. Six plots of ground were fenced. Two of the plots were control plots in which whatever non-native weeds had naturalized were allowed to grow unmolested. Two of the plots were mulch/seeded with native grasses and two of the plots were fabric/seeded with native grasses. There was no observable difference in plant composition or abundance between the seeded and unseeded plots. There was no observable difference in the outcome of the two different seeding methods that were used. In other words, native grasses were not successfully introduced to this park. My correspondence with the EBRPD employee who was responsible for this project is attached.
The park in which this experiment was conducted is Albany Bulb. Albany Bulb is the former garbage dump of the City of Albany. It was built on landfill in the bay. The soil is not native and there were never any native plants on it. It does not seem a promising candidate for a native plant “restoration.” Unfortunately, Albany Bulb is not an atypical park along the bay. There are many other parks along the bay that were built on landfill and in which the park district is attempting to establish native plant gardens. This does not seem a realistic objective for these parks.
Update: One year after the experimental planting of native wildflowers at Albany Bulb, there is no evidence of that effort. The trail-sides are mowed weeds and the upslope from the trail is studded with blooming non-native oxalis and wild radish.
Albany Bulb will soon be closed to the public for a major “improvement” project. Albany Landfill Dog Owners Group and Friends expects the park to be closed for about one year. They are unsure if the park will allow dogs off leash when the park re-opens. More information about the “improvement” project is available on their website: http://www.aldog.org/announcements-2. They suggest that you sign up on their website to be notified of the progress of the project and the status of the re-opening of the park.
This is not to say that there aren’t many worthwhile park improvement projects that are both realistic and needed.Dredging Lake Temescal is an example of a worthy project. As you know, Lake Temescal was a popular place for people to swim until recently. In the past few years it often has been closed to the public because of toxic algal blooms. The algal blooms are caused by two closely related factors. The water is warmer than it was in the past because of climate change and the lake is shallower than it was in the past because of sediment deposited into the lake.
The park district has tried to address this issue by using various chemicals to control the growth of the algae. Although that has occasionally been successful for brief periods of time, it is not a long term solution to the problem. Furthermore, it is a good example of why the park district uses more chemicals than necessary. If the park district would address the underlying cause of the problem—that is, the depth of the lake—it would not be necessary to keep pouring chemicals into the lake. Dredging Lake Temescal should be a candidate for Measure CC funding.
And so I return to the point of this suggestion for Measure CC: Please plan projects that take into consideration the reality of climate change, that address the underlying causes of environmental issues, and that have some prospect for success.
Thank you for your consideration.
Send your comments regarding Measure CC renewal to firstname.lastname@example.org
Send copies to staff and board members of East Bay Regional Park District
Robert Doyle, General Manager email@example.com
Ana Alvarez, Deputy General Manager firstname.lastname@example.org
Casey Brierley, Manager of Integrated Pest Management email@example.com
Board of Directors:
Beverly Lane, Board President firstname.lastname@example.org
Whitney Dotson email@example.com
Dee Rosario firstname.lastname@example.org
Dennis Waespi email@example.com
Ellen Corbett firstname.lastname@example.org
Ayn Wieskamp email@example.com
Colin Coffey firstname.lastname@example.org
It is my pleasure to publish a guest post about dune “restorations” in Humboldt County that began about 30 years ago. Like most “restorations,” these projects are primarily destroying non-native plants. More often than not, they don’t plant native plants to replace the plants they destroy, although the stated goal is to “restore” native plants.
Uri Driscoll tells us why the non-native plants were planted over 100 years ago and the consequences of removing them. According to Mr. Driscoll’s Facebook page, he has lived in Arcata, Humboldt County since 1983. He has had a life-long interest in outdoor recreation, horses, organic farming, and conservation. He is a member of Arcata’s Open Space and Agriculture Committee.
If you live in the San Francisco Bay Area, you might think these projects are not relevant to us. In fact, they have everything to do with us because there are many similar projects here and the issues with those projects are similar.
The San Francisco peninsula was about half barren sand dunes when Europeans first arrived at the end of the 18th century. About 30 years ago, native plant advocates decided they wanted whatever open space that still remains on the peninsula to be returned to pre-settlement conditions, including sand dunes where they existed in the past.
As residential neighborhoods in San Francisco were developed, iceplant and European beach grass were planted on the sand dunes to hold the sand in place. Native dune plants are not capable of stabilizing sand for long, before strong winds move the sand beneath them. In fact, the long term survival of native dune plants is dependent upon these disturbances.
Iceplant has been removed from several sand hills in residential neighborhoods, dumping sand on the properties at the base of the hills. The Great Highway, which separates Ocean Beach from the residential Sunset District is often closed because of drifting sand after removal of beach grass.
In fact, everyone living on the coast of California should have an interest in the preservation of our sand dunes because they are our first line of defense against rising sea levels and the intense storms associated with climate change. If non-native plants and trees are needed to maintain the stability of our sand dunes, so be it. Competing agendas must take a back seat to the safety of our coastal communities.
Stable Dunes or Native Plants?
The North and South Spits of Humboldt County are the physical barrier between Humboldt Bay and the Pacific Ocean. After the introduction of European beach grass (Ammophila arenaria) in the early 1900’s there has been a substantial stabilizing effect on the dunes as they grew wider and taller. Prior to the establishment of the grass our dunes consisted of wide expanses of unvegetated, open, moving sand. This is in sharp contrast to the variety of plant cover we have today.
In the 1980s public land managers began removing European beach grass with the goal of restoring native vegetation. This is the story of the consequences of their projects.
Foredunes (the sand ridges parallel to and closest to the shore) with open, actively moving sands have a very high potential for accelerated erosion. The foredunes of the North Spit and South Spit are still extremely vulnerable to accelerated erosion caused by disturbances to the vegetation. A beach and dunes management plan and Environmental Impact Report (EIR) was developed in 1993 to address such issues.
Of greater concern, waves have washed over the foredunes on both spits where waves have breached the foredune where vegetative cover had been removed. Repeated overwash events would significantly and immediately impact the only access road to the South Spit and the municipal water main and water treatment facilities on the North Spit.
These dunes could again be set in motion by removal of the protective cover of native and non-native vegetation. Indeed, the intention to remobilize dunes was identified in the Conditional Use Permit application Bureau of Land Management (BLM) submitted for vegetation removal at Table Bluff County Park, a portion of the South Spit. However, those intentions are contrary to the local Humboldt Bay Beach and Dune Management Plan and accompanying EIR.
The danger is that the South Spit’s dune topography is characterized as typically low and narrow. With erosion and subsequent lowering of the foredune that occurs following vegetation removal, the right combination of concurrent high-magnitude seismic subsidence and wave attack could cause collapse of the land barrier between the Ocean and Humboldt Bay. With anticipated sea level rise we would see this risk multiply.
The problem is that the previous and on-going work to remove European beach grass from the North and South Spits (in the effort to restore natural conditions and processes) has not and does not provide for the immediate re-establishment of other comparable vegetative cover to trap moving sand and prevent accelerated dune erosion. By not including this mandated mitigation measure, there is a real, legitimate potential for significant, cumulative environmental impact.
Why was European beach grass introduced?
The important thing to understand is that this specific type of beach grass (Ammophila arenaria) was introduced in Humboldt County in the early 1900’s. It was done in order to stabilize dunes to protect growing communities and infrastructure. It had the additional benefit of creating extensive coastal wetlands and wildlife habitat. By collecting sand from the beach the grass builds protective and multiple parallel ridges and accompanying deflation planes. These depressions behind the ridges act as sheltered nurseries for new plant and animal life. This process can take several decades but is reversed rapidly after the grass is removed. Such an effect has happened not only in Humboldt County but also in Point Reyes where valuable wetlands and organic pastures have been smothered by destabilized sand.
Why was European beach grass removed?
When the efforts to remove the non-native, albeit naturalized grasses began in the early 1990’s invasive biology was in its infant stages. Not much was known about the impacts from the eradication efforts of dominant species. But to some it was important to return coastal areas to the pre-beach grass era so native plants would not be out-competed.
Recognizing that manual eradication was very expensive and time consuming, California State Parks decided to bulldoze 40+ acres of Little River State Beach to provide plover breeding areas. Unfortunately, as Humboldt State Professor Mark Colwell noted in his 2008 report “importantly, eggs often fail to hatch in restored areas.” This is largely because ravens and crows find it easy to locate the nests in open sand areas.
The Lanphere-Christenson Dunes Refuge director Eric Nelson determined during a 2016 Climate Ready project that the foredunes were being excessively eroded by the 25 California Conservation Corp (CCC) workers who were digging out beach grass. His decision to spray glyphosate and imazapyr instead of hand removal was carried out despite public opposition. It remains unclear whether, despite acknowledging excessive erosion from manual eradication efforts, the refuge will return to using that method again.
The public takes notice of the consequences
Some of us who live near these project areas and use them for recreation started noticing native tree mortality and changes to the landforms caused by removing the stabilizing grasses. We started doing some initial research. We began looking into coastal development permits, beach and dunes management plans and monitoring reports. Our findings revealed the project areas that actually had permits also had mitigation requirements. Those included immediate replanting and strict monitoring to make sure topography and landforms were not altered. When we inquired about the monitoring and replanting programs we found those to be significantly deficient and in some cases non-existent.
Our next step was to approach the various regulatory agencies. US Fish and Wildlife Service, California Department of Fish and Wildlife and the State Water Board should be interested in the freshwater wetland infill we were witnessing. The Harbor District and the municipal water district have a major interest in securing the two 42-inch industrial water mains protected by the same beach grass that was being removed. The Manila Community Service District maintains a waste water treatment facility on the dunes. We thought the California Coastal Commission would certainly want to know that these unauthorized alterations to coastal landforms were taking place. We felt sure the County planning department that issued some of the permits would take enforcement action.
We brought photo and research documents from Oregon and Washington (2 and 3), made presentations and had meetings, site visits and sent email communications to no avail.
We stepped back and took a look at the board of directors for the non-profit called Friends of the Dunes (FOD) that has been promoting the grass removal from the very beginning. They had grown from a small, broken down 400 square foot building with a net worth of about $20,000 in 2004 to 60 + acres of ocean front property with a 3000 square foot building and a net worth of over $3.4 million in 2014. The board of directors at the time consisted of employees of most of the agencies listed above. We understood then why we were running into so many road blocks.
Our community is well known for environmental activism. So why the hesitation of local environmental organizations like the North Coast Environmental Center (NEC), Environmental Protection Information Center, and Bay Keeper to call out such impacts caused by bulldozers, herbicide spraying and wetland infilling? We can only presume that the banner of “restoration” has been used as a blindfold.
Some significant successes….more to do
We have had worthy successes. Through our efforts the California Coastal Commission has asked the Bureau of Land Management (BLM) for a new determination to address the impacts related to the Ocean Day activities involving 1000 school children digging grasses from the dunes. So far, the BLM does not think it needs to provide that. BLM puts on the event but the Coastal Commission bankrolls it. We do not know yet what the Commission’s response will be to that refusal.
The town of Manila has stopped grass removal activities in its management area and has supported the planting of native pine trees (Pinus contorta, contorta) in the dunes, which we did last February.The County planning department is engaged and acknowledges that there has been no contract with the California Conservation Corp or BLM for prior grass removal at the County Park and will not allow any more vegetation removal until a Memorandum of Understanding is developed.
The Coastal Commission has committed to reviewing the authorization allowances for BLM’s grass removal over the rest of the South Spit. The existing Plan states a two-acre area would be subjected to grass removal strictly for monitoring purposes not the mile long area subjected to eradication to date. BLM contends that authorization extends over the whole 800-acre Spit but have not been able to provide supporting documents.
The North Coast Environmental Center and even the Friends of the Dunes (FOD) took a position against spraying herbicides on the dunes.
Former board members of the FOD that are regulatory agency officials have resigned their director positions.
Communities around the country are hosting events to plant beach grasses like the ones that have been removed here. Recognition of the incredible value of stabilized dunes is becoming more wide spread. The “non-native” label is becoming more questioned.
Setting new goals and looking ahead
For us on the North Coast of California we need a much more cost effective and precautionary approach than tearing out plants that have beneficial attributes.We need to allow the beach grass to do its job of stabilizing and protecting our dunes. As we allow it to do that, the beach grass “declines in vigor” (4). When that happens, other plant and animal species utilize those protections from the harsh winds and tides of the Pacific and establish heathy vibrant wildlife habitat. Our local and migratory wildlife depend on it. And so do we.
Uri Driscoll, Arcata, California
We commend the people of Humboldt County for paying attention to the damage that is being done to their public land and we congratulate them on the progress they have made to prevent further damage. We are impressed with the methodical approach they have taken to convincing public land managers to reconsider the goals of the project and the methods being used to accomplish them.
We wish them the best of luck with their efforts. We are grateful to Uri Driscoll for taking the time and trouble to share this story with our readers.
(1) South Spit Interim Management Plan 2002.
(2) Evaluating Coastal Protection Services Associated with Restoration Management of an Endangered Shorebird in Oregon, U.S.A. Lindsey Carrol
On December 15,2016, the San Francisco Planning commission will hold a public hearing to consider certification of the Environmental Impact Report for the Natural Areas Program. If the EIR is certified, the Recreation and Park Commission will consider formally adopting the management plan for the Natural Areas Program at the same hearing. The Recreation and Park Commission will have the option of adopting one of the alternatives to the management plan. The San Francisco Forest Alliance will ask that the Maintenance Alternative be adopted by the Recreation and Park Commission because it is the “environmentally superior” alternative which will destroy the least number of trees and use the least amount of pesticides.
If you can attend this hearing and make public comment, please contact the SF Forest Alliance (email@example.com) for the details about where and when the hearing will take place. If you can’t attend the hearing, please consider sending an email to the Recreation and Park Commission (firstname.lastname@example.org) by Monday, December 12, 2016 (the deadline for submission of written public comments to be included in the agenda packet of the commissioners).
We lived in San Francisco for nearly 30 years and our local park was designated a “natural area” in 1997. Based on our experience with the Natural Areas Program, we have sent the following email to the Recreation and Park Commission. We hope that our letter will help you write your own public comment.
Subject: Approve the Maintenance Alternative for SNRAMP
Dear Recreation and Park Commissioners,
Since the Natural Areas Program was created 20 years ago, hundreds of healthy trees have been destroyed and over one thousand trees died slowly after being surreptitiously girdled by vandals calling themselves native plant advocates in the 32 so-called “natural areas.” Hundreds of gallons of herbicide have been sprayed on harmless plants, many that provided valuable habitat and food for wildlife. Trails have been closed and big signs installed instructing park visitors to stay on the trails that remain. Fences have been installed in some parks to enforce those restrictions.
After all that destruction and restriction, what has been accomplished? Non-native plants have been repeatedly eradicated in the “natural areas” and native plants were planted. These native plant gardens have repeatedly failed: the native plants die and the non-native plants return, in some cases many times. Native trees have been planted in a few “natural areas” but most have died, despite being irrigated during an extreme drought. After wasting millions of dollars and the associated labor, there is little to show for that investment after 20 years.
Therefore, I am writing to ask the Recreation and Park Commission to vote to adopt the Maintenance Alternative as provided by the Environmental Impact Report that was 10 years in the making. The Maintenance Alternative would enable the Recreation and Park Department to continue to take care of the “natural areas” they have already created, but it would prevent further tree destruction, further restrictions on recreational access, and require fewer pesticide applications.
Besides the obvious lack of success of the Natural Areas Program after 20 years of effort, there are many other reasons why it would be wise for the Recreation and Park Department to quit throwing good money after bad money. Here are some of those reasons:
The Natural Areas Program was predicated on the mistaken assumption that native plants are superior to non-native plants as habitat for animals. In fact, in the past 20 years multitudes of empirical studies have been conducted that prove that wildlife has no preference for native plants. Wildlife is just as likely to use non-native plants as they are native plants.
The Natural Areas Program also assumed that greater biodiversity would be achieved by eradicating non-native plants. They were mistaken in that assumption as well. Studies have been conducted all over the world in the past 20 years that find no decrease in plant biodiversity resulting from introduced plants.
The climate has changed since Europeans arrived in the Bay Area in 1769 and it will continue to change. The plants that existed here in the distant past are no longer adapted to current conditions. The ranges of native plants and animals must change if they are to survive in the long run. Therefore, demanding that historical landscapes be re-created serves no useful purpose.
The native trees of California are dying by the millions. The US Forest Service informs us that 102 million native conifers have died in the Sierra Nevada in the past 6 years. University of Cambridge recently published a study about Sudden Oak Death in which they reported that 5 million oak trees have died in California since 1995 and that the epidemic is “unstoppable.” There are SOD infections in Golden Gate Park and the Arboretum. The US Forest Service tells us that Coast Live Oaks will be virtually gone from California by 2060. A study of redwoods predicts that its native range will shift north into Oregon by the end of this century. In other words, if we want trees in California, many of them will have to be non-native trees adapted to a hotter, drier climate.
Environmental conditions in a densely populated urban area such as San Francisco are also incompatible with the unrealistic goals of the Natural Areas Program. The heat island effect of urban areas exacerbates climate change. Increased levels of soil nitrogen caused by the burning of fossil fuels promotes the growth of weeds.
The Natural Areas Program was a good idea that has outlived its usefulness. We may try to keep it alive for sentimental reasons, but expanding it would be rewarding failure. Please adopt the Maintenance Alternative.
This article is our Christmas present to our readers. We celebrate the holidays with good news about the birds living in cities all over the world.
Subirdia was written by John Marzluff, an academic ornithologist at University of Washington. (1) He reports many years of his research and that of his graduate students about the birds that live in urban and suburban Seattle as well as surrounding forest reserves. He also reports on countless studies of bird populations in similar settings all over the world. All of those studies reach remarkably similar conclusions.
It took me a long time to read this book because its introduction was off-putting. Virtually every plant and animal was preceded by the qualifier of “native” or “non-native.” The implication of the introduction was that the most important feature of every plant and animal is whether or not it is native. As our readers know, we consider the nativity of plant and animal species largely irrelevant. All plants and animals are at home in our ideal nature.
When I finally got around to reading Subirdia I was pleasantly surprised. Although the author has a preference for native plants and animals, in fact, his research and that of others does not justify his obsession. Where birds are actually found in the greatest numbers is where the habitat is most diverse, not necessarily exclusively native.
Suburbia is very birdy
The conventional wisdom is that cities are inhospitable places for birds and other wildlife. After all, haven’t we paved over much of their habitat, interrupted their movements by fragmenting their habitat, and drained or covered water resources? In fact, bird populations in urban areas all over the world are both plentiful and diverse.
After years of counting numerous bird species in his hometown of Seattle, the author of Subirdia wondered if Seattle might be unique because it is heavily forested. After conducting similar surveys in 10 cities around the world, Marzluff is convinced that birds are successfully adapting to rapid urbanization of human society. The urban centers of cities in North and Central America, New Zealand and Europe support an average of 23 bird species. He found the least number of bird species (11) in Auckland, New Zealand and the greatest number (31) in St. Andrews, Scotland.
Another popular myth about the loss of bird diversity in the Anthropocene is that the globalization of human civilization produces “homogenized” nature. That is, many people believe that bird populations may not be in decline, but there are a few hardy species that dominate everywhere. Again, Marzluff’s studies do not corroborate that belief. Five bird species are found in cities all over the world (house sparrows, starlings, Canadian geese, mallard ducks, and rock pigeons). However, these ubiquitous species are not the predominant bird species he found in cities. Of the 151 different bird species he found in the 10 cities he visited, 75% of them were unique to each of the cities. “Homogenization is barely perceptible.” (1)
Comparing bird populations in cities with nature reserves
Marzluff also compared bird populations in cities with undeveloped nature preserves. Once again, cities still look like good homes for birds. He finds twice as many bird species in Ketchikan, Alaska as in the nearby wildlands along the Naha River, “a remote wilderness fifty miles away…that required powerboat, kayak, and hiking to attain.” (1)
He also visited Yellowstone National Park, a 2.2 million acre protected area within an undeveloped ecosystem of nearly 20 million acres, where he counted 26 bird species in four days. From there, he flew to New York City where he counted 31 bird species in Central Park in only three days. Historical records of bird surveys in Central Park and Yellowstone National Park indicate that about 200 bird species have been found in both parks since the late 19th century. “From a bird’s perspective, a large park created by human hands or by nature is not all that different.” (1)
Accommodating birds in cities
Marzluff’s concluding chapters advise city dwellers how to encourage and support birds. His “ten commandments” for accommodating birds make no mention of planting native plants or eradicating non-native plants:
“Do not covet your neighbor’s lawn.”
“Keep your cat indoors.”*
“Make your windows more visible to birds that fly near them.”
“Do not light the night sky.”
“Provide food and nest boxes.”
“Do not kill native predators.”
“Foster a diversity of habitats and natural variability within landscapes.”
“Create safe passage across roads and highways.”
“Ensure that there are functional connections between land and water.”
“Enjoy and bond with nature where you live, work, and play!”
Marzluff expresses a strong preference for native plants throughout his book, but his research in Seattle is inconsistent with that preference: “The forests of Seattle and its suburbs now embrace 141 species of trees, including 30 native species and ornamentals from North and South America, Europe, Asia, and Africa. Some are problematic invaders, but in total they provide a diverse menu of foods and nesting and roosting sites for birds.” (1)
Why a preference for natives?
Another academic scientist in Washington State, Linda Chalker-Scott, directly addresses the vexing question of why public policies which mandate the use of native plants have proliferated despite the lack of evidence that they are superior in any way. She focuses on this question: “Do native and nonnative woody species differ in how they affect species diversity?” Her literature search found 120 studies from 30 countries that quantified the biodiversity of birds, insects, mammals, reptiles, and other plants in woody plants and trees in urban landscapes.
The analysis of these studies reveals that “the science does not support the supposition that native plantings are required for biodiversity…it is clear that an automatic preference for native trees when planning in urban areas is not a science-based policy.” (2) The assumption that native plants are superior to non-native plants is based on these misconceptions:
The definitions of native and alien species are value judgments, not science-based concepts.
Native plants are often poorly suited to environmental conditions in urban areas, such as compacted soil and changes in the climate. Conversely, introduced plants are often well suited to these urban conditions.
Many introduced plants provide valuable ecological benefits. For example, they often provide food, pollen, and nectar resources during winter months when native plants are dormant.
Doug Tallamy is the academic scientist most closely associated with the native plant ideology. His claim that insects require native plants is based on his mistaken assignment of nativity to an entire genus, when only a few species within that genus are actually native. For example, there are over 35 species of milkweed in the genus Asclepias, but only two species are native to California. Most members of the milkweed family are useful to monarch butterflies. It is therefore not accurate to claim that monarchs require native plants. They have lived all over the world for over 200 years in some places where there are no native species of milkweed.
Chalker-Scott’s meta-analysis of 120 studies concurs with Mr. Marzluff: “The published research overwhelmingly identifies diversity, structure, and function as the most important vegetation characteristics for enhancing community biodiversity…In fact, sometimes landscapes require the inclusion of exotic trees and control of natives to maintain diversity.” (2)
Doing more harm than good
Our readers know that we do not begrudge the preference of native plant advocates for native plants. We encourage them to plant whatever they want. We only ask that they stop destroying the plants they don’t like. That request is based on our belief that they are doing far more harm to our public lands than any perceived benefit of native plants. Much of that harm is caused by the widespread use of herbicides to destroy non-native vegetation. These herbicides are known to damage the soil and they migrate in the soil, damaging neighboring plants that are not targeted. These issues are surely a factor in the conspicuous lack of success of their “restorations.” There is also mounting evidence of the toxicity of herbicides to bees, birds, and other animals including humans.
But there is another, equally important reason why we object to the futile attempts to eradicate non-native plants. They are providing valuable habitat for wildlife. Even when they are replaced by native plants after being destroyed, the animals that depended upon them are not necessarily restored to the landscape. In fact, few projects plant natives after the eradication of non-natives.
A recently published study (3) of the removal of Amur honeysuckle (Lonicera maackii) is an example of the loss of valuable habitat. The hypothesis of this study was that “invasion of urban habitats by exotic plants was the underlying mechanism driving changes in bird-plant networks.” The study tested this hypothesis by comparing forest plots dominated by honeysuckle with those in which honeysuckle had been removed and the surrounding forest habitat replicated. They measured nesting birds, nest predators, and nest survival.
They found that the lowest overall nest survival rates were found in the plots in which honeysuckle had been removed. In other words, “…removal of invasive honeysuckle from urban forests did not restore network structure to that of rural landscapes.” The authors concede, “This finding was not consistent with our original hypothesis that invasion of forests by the exotic Amur honeysuckle was responsible for the urban-associated changes in bird-plant networks.” They conclude, “The degree to which native communities can be restored following removal of exotic plants remains unclear.”
Actually, we think it is quite clear that eradicating non-native plants does not benefit man or beast. We marvel that the fantasy persists that there is some theoretical benefit to killing harmless plants, despite the consistent lack of evidence of any benefit and the considerable evidence of the harm of such attempts.
*Like most ornithologists, Marzluff comes down hard on cats as killers of birds in his book. However, he cites just one study about predation of fledglings. The study used radio transmitters to determine the fate of 122 newly fledged birds over a period of two years.
The results do not justify the demonization of cats: “Only 20 percent of radio-tagged birds died during our study. Birds such as Cooper’s hawks and mammals such as Townsends’ chipmunks, ermine, and Douglas squirrels were the most likely predators. The most notorious of all bird predators, the out-of-the-house cat, was implicated in only one death, though we could never be entirely sure which mammal or which bird had killed the fledging.” (1) Marzluff credits a neighborhood coyote for controlling the cat population. Frankly, that doesn’t make sense. Chipmunks and squirrels are just as likely to be prey for the coyotes.
We have reported on similar studies which reach the same conclusions. A meta-analysis of 8 studies of nest predators of song birds in North America used video cameras to identify the predators of 242 depredation events. Only one of those nest predators was a cat.
We have no objection to the general advice to keep your cat indoors. (We have never had a cat and don’t plan to.) However, we think that estimates of birds killed by cats are greatly exaggerated. Humans seem to have an unfortunate desire to look for scapegoats and cats seem to fit the bill for bird lovers.
John M. Marzluff, Welcome to Subirdia, Yale University Press, 2014
Linda Chalker-Scott, “Nonnative, Noninvasive Woody Species Can Enhance Urban Landscape Biodiversity,” Arboriculture & Urban Forestry, 2015, 41(4): 173-186
Amanda D. Rodewald, et. al., “Does removal of invasives restore ecological networks? An experimental approach,” Biological Invasions, March 2015
On November 19, 2015, a visitor to Mount Davidson park in San Francisco video recorded a pesticide application that is available here:
One of the people who saw that video reported several concerns regarding that pesticide application to the city employees who are responsible for the regulation of pesticide use in San Francisco. Here is the email he sent to Kevin Woolen in the Recreation and Park Department and Chris Geiger in the Department of the Environment:
To: Kevin Woolen email@example.com
Dear Mr. Woolen,
I understand that you are responsible for the records of pesticide applications on properties managed by San Francisco’s Recreation and Park Department. I have heard you speak at public meetings, so I am aware that you have some expertise in that area. Therefore, I am writing to you about a pesticide application on Mt. Davidson on November 19, 2015. That pesticide application was recorded by this video: https://www.facebook.com/ForestAlliance/videos/934479473312166/?fref=nf
I have several concerns about this pesticide application:
One of the herbicides that was sprayed was Stalker with the active ingredient imazapyr. I notice that most of the spraying was done around a tree, which was not a target of the application according to the posted Pesticide Application Notice. As you may know, imazapyr is not supposed to be sprayed under and around non-target trees according to the manufacturer’s label: http://www.cdms.net/ldat/ld01R013.pdf: “Injury or loss of desirable trees or other plants may result if Stalker is applied on or near desirable trees or other plants, on areas where their roots extend, or in locations where the treated soil may be washed or moved into contact with their roots”
The Pesticide Application Notice says that the application method will be “spot treatment/daub cut stem.” This does not seem to be an accurate description of the application method on November 19th. It seems that “backpack sprayer” would be a more accurate description of this particular pesticide application.
The Pesticide Application Notice says that Himalayan blackberries were one of the targets of this Pesticide Application. As you know, birds and other wildlife cannot read the signs that are posted to warn the public about these applications. Can you assure me that the Himalayan blackberries were no longer fruiting? Does the Recreation and Park Department have a policy against spraying vegetation when there are fruits eaten by birds and other wildlife? If not, would the Recreation and Park Department consider adopting such a policy?
Although Garlon was not used in this particular pesticide application, it is often used in San Francisco’s so-called “natural areas.” Therefore, it is worth mentioning that Garlon is also known to be mobile in the soil and there are documented incidents of it damaging non-target trees when it has been sprayed on the stumps of nearby trees after they were destroyed.
Thank you for your consideration. I hope you will share my concerns with the staff and contractors who are engaged in these pesticide applications.
Cc: Chris Geiger firstname.lastname@example.org
This is not an isolated incident. Park visitors in San Francisco have been complaining for years about pesticide use in parks that were designated as “natural areas” over 15 years ago. Ironically, those areas were never sprayed with pesticides before being designated as “natural areas.” In fact, they really were natural areas prior to being officially designated as such. Plants and animals lived in peace in those places before being “managed” by people who are committed to eradicating all non-native plants in many of San Francisco’s parks.
What can you do about it?
If you are opposed to pesticide use in San Francisco, or you object to the pointless destruction of harmless plants that are useful to wildlife, here are a few things you can do to express your opinion and influence the public policy that allows pesticide use in the public parks of San Francisco:
You can join over 11,000 people who have signed a petition to prohibit the use of pesticides in public parks. The petition is HERE. The San Francisco Chronicle reported on pesticide use in San Francisco’s parks and the petition against that use. (Available HERE)
You can sign up HERE to be notified of the annual meeting in which pesticide policy in San Francisco is discussed for subsequent approval by the Environment Commission. That meeting has been scheduled in December in past years. Update: The annual meeting has been announced. “Annual Public Hearing on Pest Management Activities on City Properties and San Francisco’s Draft 2016 Reduced-Risk Pesticide List 4:30-7:00 pm
Wednesday, December 16, 2015 Downstairs Conference Room, 1455 Market St. (near 11th St.; Van Ness MUNI stop)” The meeting agenda is available HERE.
You can apply for one of the two vacant seats on the Environment Commission. These seats have been vacant for nearly a year. In the past, the Environment Commission has actively promoted pesticide use in San Francisco’s “natural areas.” Qualifications and duties of commissioners are available HERE.
Appointments to the Environment Commission are made by Mayor Ed Lee. If you don’t want to serve on the Environment Commission, you can write to Mayor Lee (email@example.com) and ask him to appoint people to the Commission who do not support the use of pesticides in San Francisco’s public parks.
The parks of San Francisco belong to the people of San Francisco. They have paid to acquire those properties for public use and they are paying the salaries of those who are “managing” the parks. If you don’t like how parks are being managed, you have the right to express your opinion. Our democracy works best when we participate in the public policy decisions that affect us.
What does this have to do with the East Bay?
Our readers in the East Bay might wonder what this incident has to do with you. Parks in the East Bay are also being sprayed with herbicides for the same reasons.HERE are reports of pesticide use by the East Bay Regional Park District.
Many of the pesticide applications on the properties of EBRPD are done by the same company that sprayed herbicides on Mount Davidson on November 19, 2015. That company is Shelterbelt Builders. You can see their trucks in the above video. Pesticide use reports of San Francisco’s Recreation and Park Department often report that pesticide applications were done by Shelterbelt.
Shelterbelt Builders is based in the East Bay. One of its owners is Bill McClung who is a member of the Claremont Canyon Conservancy and a former officer of that organization. The Claremont Canyon Conservancy is the organization that is demanding the eradication of all non-native trees on public land in the East Bay Hills. Here is a description of Mr. McClung’s responsibilities on Shelterbelt’s website:
“Bill McClung joined Shelterbelt in 1997 to help refocus Shelterbelt on native plant restoration and open land management/fire safety. After his house burnt down in the 1991 Oakland Fire, this former book publisher became interested in how wildland and fire are managed in the East Bay Hills. He became a member of the Berkeley Fire Commission in 1994 and has a strong interest in the vegetation prescriptions of the Fire Hazard Program & Fuel Reduction Management Plan for the East Bay Hills issued in 1995 by the East Bay Hills Vegetation Management Consortium and the East Bay Regional Park District Wildfire Hazard Reduction and Resource Management Plan Environmental Impact Report of 2009/10. He has managed many properties in the East Bay where wildfire safety and native habitat preservation are twin goals, and continues to work on interesting and biologically rich lands in the Oakland Hills.”
Claremont Canyon Conservancy
The Claremont Canyon Conservancy held their annual meeting on November 15, 2015. Oakland’s Mayor, Libby Schaaf, was one of the speakers. Although she took questions at the end of her presentation, one of the officers of the Conservancy called on the questioners. There were many people in the audience who are opposed to the FEMA projects that will destroy over 400,000 trees in the East Bay Hills and many of us tried to ask questions. With one exception, the person controlling the questions only called on known, strong supporters of the FEMA project. Therefore, those who wished to express their opposition to the FEMA projects to the Mayor were denied that opportunity. Fortunately, there were many demonstrators outside the meeting who could not be denied that opportunity.
Norman LaForce was the other main speaker at the meeting. He is an elected officer of the Sierra Club and he identified himself as one of the primary authors of the project to destroy all non-native trees in the East Bay Hills. (An audio recording of his complete presentation is available here: ) This is the paraphrased portion of his presentation specifically about the herbicides that will be used by the FEMA project:
“Part of the FEMA program will be to use herbicides in a concentrated, careful program of painting or spraying herbicides to prevent the trees from resprouting. It may need to be done more than once but ultimately the suckers give up. There is no other way to do that cost effectively.
People are saying that glyphosate causes cancer. Radiation causes cancer but when people get cancer they are often treated with radiation. Nobody tells them they can’t have radiation because it causes cancer.
There are a lot of people of a certain age in this room who are probably taking Coumadin as a blood thinner for a heart condition. Coumadin is rat poison. Nobody tells them they can’t take Coumadin.*
You must take dosage and exposure into consideration in evaluating the risks of pesticides.
Nature Conservancy used glyphosate on the Jepson Prairie.
State Parks used Garlon on Angel Island when they removed eucalyptus.
The European Union says that glyphosate does not cause cancer, so I don’t know if it does. I’m not going to take a position on that.
Now they are saying that red meat causes cancer.
We need to put aside the question of pesticides. They will be used properly. We must proceed in a scientific manner.”
We leave it to our readers to interpret Mr. LaForce’s justification for pesticide use. He seems to be suggesting that pesticides are good for our health. There are instances in which pesticides do more good than harm, but using them to kill harmless plants in public parks isn’t one of them, in our opinion. Since many chemicals accumulate in our bodies throughout our lives, it is in our interests to avoid exposure when we can. If we must take Coumadin for our health, that’s all the more reason why we should avoid unnecessary exposure to rat poison when we can.
Connecting the dots
We have tried to connect the dots for our readers. Here are the implications of what we are reporting today:
Pesticide applications in San Francisco are probably damaging the trees that are not the target of those applications. The food of wildlife may be poisoned by those pesticide applications.
You can influence the public policy that is permitting pesticide use in San Francisco.
The same company that is spraying pesticides in San Francisco is also doing so in the East Bay.
That company is also actively engaged in the attempt to transform the landscape in the San Francisco Bay Area to native plants. They have an economic interest in native plant “restorations.”
The Sierra Club is actively promoting the use of pesticides on our public lands.
*Coumadin is prescribed for people who are at risk of heart attack or stroke caused by blood clots. Coumadin thins the blood and suppresses blood coagulation. Rat poison kills animals by bleeding them to death. There is a fine line between preventing blood clots and bleeding to death. Therefore, people who take Coumadin have frequent blood tests to check that the dosage is at the optimal level. Rat poisons are killing many animals that are not the target of the poison. Animals such as owls, hawks, vultures are often killed by eating dead rodents that have been poisoned. We should not conclude that rat poison is harmless because humans are using it in carefully controlled doses. Herbicides being sprayed in our public lands are not being closely monitored as Coumadin use is.
Tao Orion is the author of Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration, the latest in the rapidly growing literature about the futile and destructive attempts to eradicate non-native species. Ms. Orion will give a workshop at a PLACE for Sustainable Living on Thursday, September 17, 2015:
“Rethinking Invasive Species from a Permaculture Perspective”
Thursday, September 17, 2015, 6-8 pm
PLACE for Sustainable Living
1121 64th St, Oakland, CA 94608
Donations $12-$25 requested
Update: This is the answer PLACE for Sustainable Living gave to a question about wheelchair accessibility: “It is not wheel chair accessible yet – we have carried wheelchair persons up the steps with their wheelchairs – we can arrange for that. And the yard is filled with chipwood, wheel chairs have rolled over fine, but not sure if everyone in them can push through. Our friend, male, can push through fine.” Please contact PLACE for Sustainable Living directly if you have specific questions about accessibility. (addendum dated 9/10/15)
Update #2: Ms. Orion’s presentation has been cancelled because the venue is not wheelchair accessible. CUIDO (an organization which represents disabled people) asked that it be moved to a facility with wheelchair accessibility or cancelled. Such a facility could not be found, so it has been cancelled.
Update #3: Some adjustments have been made in plans for Ms. Orion’s presentation which are apparently acceptable to at least some members of the disabled community. Ms. Orion has therefore decided against cancelling it. Sorry for the confusion.
Ms. Orion is visiting the Bay Area from the Willamette Valley in Oregon, where she has a small farm in the country. She has a degree in agroecology and sustainable agriculture from UC Santa Cruz and she has studied at the Columbines School of Botanical Studies in Eugene, Oregon. She teaches permaculture design at Oregon State University and a non-profit sustainable-living educational organization. She has also worked as a permaculture designer for ecological restorations.
Beyond the War on Invasive Species
The first chapter of Ms. Orion’s book is a breakthrough because it is an explicit indictment of pesticides used by so-called “restoration” projects. Although previously published books were critical of invasion biology and the ecological industry it spawned, pesticides were barely mentioned in them. In contrast, it is primarily the use of pesticides in ecological “restorations” that convinced Ms. Orion that the war on invasive species is doing more harm than good.
Concern about unwanted plants – AKA weeds – is as old as human engagement in agriculture, that is, thousands of years old. And most of the plant and animal species now considered “invasive” were introduced by humans to serve a variety of purposes, including aesthetics, such as mute swans and multiflora roses. Some of these introduced plants and animals had unintended consequences such as competing with native plants and animals for available resources. Concern – even regret – about these introductions has increased greatly in the past 25 years. Attempts to manage these introductions has escalated from import limitations to fines and penalties and finally to attempts to eradicate plants and animals with pesticides.
The role of the pesticide industry in the escalating war on “invasive” species
Ms. Orion turns to the public record to make the case that the current focus on eradicating introduced species using pesticides was influenced by business interests. She points out that the federal Invasive Species Advisory Committee is a consortium of academic, professional, and business interests, including at least two people who are employed by manufacturers of pesticides. They make invasive species management policy recommendations to the National Invasive Species Council (NISC), created by Executive Order in 1999. The federal government is spending over $1 billion annually on research and control of “invasive” species, including pesticide applications.
The NISC is modeled after the California Exotic Pest Plant Council, created in 1992. That Council is now known as the California Invasive Plant Council (Cal-IPC). Cal-IPC brought together representatives from government agencies and non-profit environmental organizations, as well as manufacturers of pesticides and spray equipment: “Monsanto has sponsored Cal-IPC since its inception and both DuPont and Dow AgroSciences have also supported the group.” (1)
The first annual conference of Cal-IPC in 1993 featured an employee of Monsanto, Dr. Nelroy Jackson. Jackson’s presentation to Cal-IPC stated that “chemical weed control is the optimal method for control and removal of exotic plant species during…most native habitat restoration projects.”
Jackson’s involvement in escalating attempts to eradicate introduced species is troubling, but is not the only example of such collaboration between the “restoration” industry and the manufacturers of pesticides. The Weed Science Society, which advocates for “research, education, and awareness of weeds in managed and natural ecosystems,” has employees of Dow Agrosciences, Syngenta, and Dow Chemical on its board of directors. Those manufacturers of pesticides, as well as Monsanto, Bayer Crop Science, Dupont, and BASF Corp are also donors to the weed society, at the highest levels of donations.
The manufacturers of pesticides also influence the “restoration” industry by investing and participating in the consulting firms that write environmental impact reports for ecological “restoration” projects, such as Tetra Tech (which wrote the draft Environmental Impact Report for San Francisco’s so-called Natural Areas Program).
The manufacturers of pesticides influence public policy regarding ecological “restoration” by making large tax-deductible contributions to many land-grant universities that conduct research on agriculture: “A 2012 Report from Food and Water Watch found that nearly 25% of funding for agricultural research at public universities comes from private companies.” (1) This is one of many reasons why there is so little research done on non-chemical approaches to ecological restoration.
As disturbing as this collaboration between the government and the pesticide industry is, the evidence of the relationships between trusted non-profit environmental organizations and corporate interests is even more so. Nature Conservancy, National Audubon Society, and Ducks Unlimited all have close relationships with the manufacturers of pesticides and receive funding from them.
Ms. Orion’s next chapters are more similar to the books that precede hers. There are several examples of specific “invasions” that illustrate the point that “invasive” species are usually symptoms of changes in the environment, rather than causes of those changes. Attempting to eradicate them does not reverse the changes in the environment and often causes more environmental damage. “Invasive” species are often performing valuable ecological functions that are not understood until they are eradicated. We have reported many examples of these issues and won’t repeat them here. However, Ms. Orion’s telling of the history of Asian Carp in the Mississippi River and the Great Lakes was new to us and is well worth a retelling.
Asian carp has been a mainstay in the diet of the Chinese for several thousand years, according to their historical literature. Asian carp are well adapted to aquaculture techniques, so they have the potential to replace or supplement other sources of protein. They were introduced to the Midwest in the early 1800s and they spread throughout the Mississippi River many decades ago. Although they are prevalent in the Mississippi River, they have not driven any native fish to extinction. Yet, despite their usefulness and the lack of evidence that they have caused any harm, they suddenly became the latest invasion crisis when it was feared they would soon enter the Great Lakes. A government fisheries biologist put that fear into perspective:
“We are trying to keep invasive Chinese carps out of the Great Lakes, to protect an invasive (yet purposefully stocked) Pacific salmon fishery, which was stocked as a management tool to control hyper-abundant alewifes, another invasive fish species, because the native piscivore, the Lake Trout, was nearly wiped out by another invasive species, the sea lamprey, because people built the Welland Canal around Niagara Falls to promote intercontinental shipping deep into the Great Lakes basin.” (1)
It makes the head spin to follow the “logic” of this sequence of events, which we paraphrase, “we solved one problem by creating another, then we solved that problem by creating another…ad infinitum.“ This is an ecosystem that has been radically altered by man, including reversing the flow of the Chicago River which connects the Mississippi River to the Great Lakes to solve Chicago’s sewage problems. The water is warmer, polluted with agricultural runoff, and there is no longer a seasonal, cleansing water surge. These changes in the environment set the stage for the arrival of Asian Carp in the Great Lakes. The habitat for native fish has been radically altered such that removal of Asian carp from the river is an irrelevant, inconsequential improvement of habitat needed by native fish.
Despite what would seem overwhelming evidence that Asian carp could be a valuable food source and that being rid of them is unlikely to benefit anyone, here is a brief list of what has been done so far to try to prevent them from entering the Great Lakes:
US Army Corps of Engineers constructed a submerged electric fence to shock and kill the fish as they enter the Great Lakes. The fence cost millions of dollars but is largely ineffective.
Other researchers have suggested a system of strobe lights and bubble and sound barriers to stop the northward migration of Asian carp.
Ms. Orion’s closing chapters reflect her training in permaculture design. She considers the tending of the wild by Native Americans a model for ideal stewardship of the land. And she advocates for land management strategies that reflect the realities of our changed environment and are sustainable into the future. We will let her speak for herself:
“Holistic restoration planning requires an honest accounting of what has come to pass as well as a comprehensive view of what we can do about it. The problems are complex, and the solutions are likely to be more so…Navigating from a paradigm that views invasive species as scourges to one that looks at them as opportunities for deeper ecological and economic engagement will take time and commitment, especially because the old paradigm is so entrenched politically, economically, and academically. The tide is shifting though, as more and more of us are coming to realize that the herbicide-based eradication approach to restoration is outmoded—a futile attempt to regain an imagined past—and we need to be focusing our time, resources, and energy on adapting to the future.” (1)
Please show your support for Tao Orion and her book by attending her workshop on Thursday, September 17th.
(1) Tao Orion, Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration, Chelsea Green Publishing, 2015