Public opposition to pesticide use in our public parks

On November 19, 2015, a visitor to Mount Davidson park in San Francisco video recorded a pesticide application that is available here:

glyphosate spraying on Mt Davidson - nov 19, 2015

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

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:

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:  “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”

Here is a newspaper article about unintentional damage done to trees by spraying an imazapyr herbicide beneath them:

  • 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

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 ( 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 began the eradication of non-natve vegetation in Glen Canyon in November 2011
Shelterbelt began the eradication of non-natve vegetation in Glen Canyon in November 2011

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.

Demonstration at meeting of Claremont Canyon Conservancy, November 15, 2015
Demonstration at meeting of Claremont Canyon Conservancy, November 15, 2015

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.


Beyond the War on Invasive Species

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

Beyond the War on Invasive SpeciesThe 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.

National Invasive Species Council

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 then describes the use of pesticides by the “restoration” industry.  She also describes some of the damage pesticides are known to do, such as killing microbes in the soil and binding minerals in the soil.  She describes the persistence and mobility of pesticides in the environment.  She describes the inadequacy of testing and regulation of pesticides in the United States.  These issues are well known to the readers of Million Trees, so we won’t repeat them here, but new readers can click on the blue links to visit posts about those issues.

All introduced species are presumed to be harmful

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.

Song dynasty painting attributed to Liu Cai (c.1080–1120). Contains various types of fish and other marine animals, such as goldfish, perch, catfish, carp, minnows, bass, and shrimp.
Song dynasty painting attributed to Liu Cai (c.1080–1120). Contains various types of fish and other marine animals, such as goldfish, perch, catfish, carp, minnows, bass, and shrimp.

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:

Fish kill using rotenone.
Fish kill using rotenone.
  • 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.
  • The Illinois Department of Natural Resources dumped 2,200 gallons of rotenone into sanitary and ship canals feeding into the Great Lakes. This poison kills all gilled animals. The result:  “Among the tens of thousands of dead fish, researchers found one Asian carp.” (1) This fiasco cost $3 million.
  • Other researchers have suggested a system of strobe lights and bubble and sound barriers to stop the northward migration of Asian carp.

Permaculture philosophy

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 

A retired university planner critiques the FEMA projects in the East Bay Hills

We recently finished reading all of the 13,000 public comments on the FEMA draft EIS.  FEMA says that about 90% of the comments are opposed to the project and having read the comments that seems about right. 

It was a very rewarding experience to read the comments and we recommend it to anyone who is discouraged or doubtful that we can prevent the destruction of our urban forest in the East Bay (available HERE).

There were many excellent comments, many from people with specific expertise and knowledge of the issues that inform our opposition to these projects.  We plan to publish a few of them, as we obtain permission from their authors.  Today, we publish the public comment of Christopher Adams, with his permission.  We hope you are as impressed with his astute analysis as we are.


 Comments on Hazardous Fire Risk Reduction, East Bay Hills, CA,

Draft EIS

Prepared by Christopher Adams


My comments here are made solely in my capacity as a private citizen, but I think it is germane to state my background. I am a retired university planner, and for several years I directed the office which was responsible for review of every environmental document prepared by all the campuses and other facilities of the University of California. In addition, I was directly involved with the drafting, the public hearings, and the response to comments and preparation of two major Environmental Impact Reports, prepared under the California Environmental Quality Act for a UC campus. I also live near the EB Hills in an area subject to wild fires and share the concerns of others about the risk of fire.


The Hazardous Fire Risk Reduction, East Bay Hills, CA, Draft EIS is a deficient document, beginning with its basic premise. While purportedly for the purposes of fire management, the proposed actions appear to be mostly motivated by a dream of a restoring the EB Hills to some imagined Eden prior to the European and American colonization of California. Instead of applying scientific and policy analysis to the impacts of the proposed actions the DEIS authors appear to have decided that the proposed clear cutting and herbicide measures are the right ones for fire protection and then cherry‐picked evidence, whether in the description of existing conditions or the possible alternatives solutions, which supports this conclusion. The DEIS rejects out of hand fire management alternatives that do not involve clear cutting and massive application of herbicides. In so doing the DEIS is a classic example of post hoc rationalization. Unless the DEIS is re‐issued with corrections and additions responding to the comments below, I believe that FEMA is seriously exposed to potential litigation. More significantly, if FEMA does not consider other less draconian and less expensive fire management measures, it will not be serving the interests of the citizens most impacted by fire danger, not to mention the taxpayers who will ultimately foot the bill.

Specific Comments:

The DEIS fails to note the existence of native trees which are specifically susceptible to the effects of one of the herbicides proposed for use. Section notes that the native trees in the woodlands include madrone (Arbutus menziesii). However, in Section Strawberry Canyon‐PDM there is no mention of madrones in the list of trees in the “native forest” (first paragraph of section). This is a significant omission, because there are madrones in Strawberry  Canyon, yet in the third paragraph of this same section one of the two herbicides proposed for use to stifle stump regeneration is Stalker (imazapyr) which has been identified elsewhere as being used specifically to eliminate madrones. According to the EPA Reregistration Eligibility Decision for Imazapyr: “Imazapyr use at the labeled rates on non‐crop areas when applied as a spray or as a granular to forestry areas present risks to non‐target plants located adjacent to treated areas.” (1)

The DEIS fails to acknowledge the growing threat of French broom in the UCB area.

While the presence of eucalyptus, Monterey pine, and acacia is repeatedly discussed, there is almost no mention of the rapid invasion of French broom. It is mentioned only in passing and without its scientific name in the discussion in Section under “Northern Coastal Scrub.” While French broom has been rapidly increasing in the upper slopes of the Strawberry Canyon PDM and Claremont PDM areas, there is no mention of it at these locations in the DEIS. This plant is an active pyrophyte which chokes out native vegetation, can be poisonous to livestock, and is of limited benefit to native animals. The increase in sunlight from the proposed removal of large amounts of eucalyptus will encourage its spread. There is no mention of the fire risk from French broom in the discussion of fire risk in Northern Coastal Scrub, Section, and I could find no mention of its removal anywhere in the document.

The UCB project description does not explain if a fuel break is planned in the UCB areas and if so to describe it.

Section 1.1.1 UCB states that it will follow the “same general approach…which is included in Oakland’s grant application (see Section 1.1.2 below).” In Section 1.1.2 it is stated there the Oakland PDM would “create a fuel break on the west side of Grizzly Peak Boulevard north and east of the Caldecott Tunnel [presumably this means the west entrance to the tunnel].” UCB Strawberry Canyon properties also abut Grizzly Peak Boulevard, so the statement of “the same general approach” implies that UCB also proposes a “fuel break,” but none is described. Since the term “fuel break” implies clearing to the bare soil, with potential significant environmental impacts, this is a serious omission.

The DEIS fails to consider the impact on global climate change by the wholesale destruction of trees. The DEIS states that for UCB Strawberry Canyon alone 12,000 trees will be destroyed. Because trees absorb CO2 at an average rate of 13 pounds per year, this represents a potential loss in CO2 absorption of 78 tons per year. Given the growth patterns of native trees in Berkeley, which tend to be riparian or to grow on north facing slopes in a widely scattered pattern, the number of replacement trees will not come close to compensating for those destroyed. The difference should be estimated and calculated.

The DEIS fails to consider an actual and accomplished fuel management program when dismissing the alternative described in Section

The Lawrence Berkeley National Laboratory (LBNL) is located on 175 acres on the north side of Strawberry Canyon immediately adjacent to the UCB and EBRPD areas described in the DEIS. LBNL, which is managed by the University of California, employs more than 4,000 persons on this site in laboratory buildings and with equipment that is worth several billion dollars. LBNL has recently completed a fire management program which is essentially what is described in Section of the DEIS, Removal of Brush, Surface Fuels, Lower Limbs and Small Trees. The entire project was completed within the LBNL maintenance budget without special grants and has given the laboratory a great deal of fire security, according to its professional fire personnel. Yet there is no reference to this in the DEIS. The LBNL program is further described in the following links. This first links to a powerpoint slides; the second to a video discussion of the slides. http://www.lbnl‐ on%2C%20Lab%20Fire%20Marshal.pdf


The links convey much more effectively than my comments how an alternative to massive clear cutting and massive application of herbicides will effectively accomplish the goal of managing fire in the East Bay Hills.

The DEIS is incomplete and verging on the dishonest about the use of herbicides.

“Management of resprouts without herbicides is expensive….and thus was removed from further study.” This ignores the management of resprouts used successfully by LBNL as described in the above referenced powerpoint and video. There is no study about the use of herbicides at the scale proposed, e.g. 12,000 trees in Strawberry Canyon alone, on human populations, let alone native plants and animals.

The DEIS fails completely to discuss the realities of encouraging native plants after the clear cutting and heavy and repeated application of herbicides.

1) Restoration ecology is barely in its infancy, yet this DEIS expects us to accept on faith alone that when the clear cutting is done and the slopes sprayed with herbicides the native vegetation will miraculously reappear.

2) At the present time live oaks and bays are common on the north side (south facing side) of Strawberry Canyon under eucalyptus. This is probably because the fog drip from the eucalyptus and the shade encourage their growth in what would otherwise be a very dry area. Compare, for example, on slopes of similar aspect in portions of the EB Hills behind El Cerrito or Fremont. There is nothing in the DEIS to explain how native trees will increase or survive after the clear cutting has destroyed their source of water and shade.

3) Because of the abundance of deer in Strawberry Canyon and adjacent areas, small trees need to be protected against browsing. (See the LBNL powerpoint for an illustration of wire protective cages. http://www.lbnl‐ on%2C%20Lab%20Fire%20Marshal.pdf) The DEIS says nothing about preventing deer browsing.

4) California native oaks of several species, including Quercus agrifolia are subject to the fungal disease Sudden Oak Death Syndrome (SODS), which has been found in the East Bay Hills. The DEIS fails to discuss the existence of SODS or its impact on replacement vegetation after the clear cutting and application of herbicides.

5) The DEIS states that “alleopathic oils” in the leaves and bark of eucalyptus suppress the growth of other vegetation. Yet the DEIS fails to state how covering slopes two feet deep with eucalyptus slash will not inhibit growth of new “native” plants.

6) Native California bunch grasses have largely been supplanted by European annual grasses, many of which form mats which choke out other plants. Similarly native shrubs such as coyote bush (Baccharis species) are being supplanted by invasive plants such as broom. The DEIS fails to explain how native plants will succeed in competition for sun and water with these plants.

The DEIS fails to consider the aesthetic impact to views from the trails and roads within the canyon and from houses near it after the clear cutting.

Section 4.12.2 of the DEIS states that a goal of the UCB LRDP (2005) is to “Maintain the visual primacy of the natural landscape in the hill campus” but there is no mention of the impact of clear cutting on this natural landscape. The north side of the lower portion of Strawberry Canyon forms the main campus of Lawrence Berkeley National Laboratory (LBNL). While individual buildings at LBNL are attractive in design, the overall effect of the site is essentially industrial, similar to an office park one might see along a freeway. The views of LBNL from the fire road that winds through the canyon are now largely screened by the large trees which will be destroyed by clear cutting. The trees also offer cooling shade to those using the area for recreation. The fire road is a major recreation amenity for UCB students, employees, and neighbors, used daily by hundreds of hikers, joggers, dog walkers, and mountain bikers. Removal of most of the trees as proposed will completely change the views enjoyed from the fire road. The DEIR provides absolutely no analysis of this impact either verbally or by providing illustrations of any viewing point in Strawberry Canyon. Most of the discussion of Section 5.8 is oriented to views over the hills from high points to the bay, which indeed may be improved by clear cutting. There is no discussion of views from within the areas to be clear cut and no reference to Strawberry Canyon.

The DEIS bases its list of plant species slated for destruction on incomplete and inaccurate botanical and fire danger information.

The authors of the DEIS seem not to understand the difference between “native” and “endemic” and they seem to have arbitrarily selected some “native” plants to extirpate while keeping others based on criteria having little or no relationship to fire hazards. Section states that “Non native trees, including all eucalyptus, Monterey pine, and acacia would be cut down.” The Jepson Manual  (2), which is the definitive source for California plants divides the state into geographic areas. According to Jepson Monterey pines (Pinus radiata) are native to California, and while not endemic to the EB Hills, they are native in the geographic area CCo, which includes both portions of Monterey County and the EB Hills with similar climatic conditions. Coast redwoods (Sequoia sempervirens) are also found in Strawberry Canyon but not as an endemic. They are also native to the geographic area (CCo). In contrast to Monterey pines, however, Coast Redwoods appear to escape destruction by clear cutting; at least there is no mention of such action in the DEIS. Another native and Strawberry Canyon endemic, California Bay (Umbellularia californica), is specifically listed in the DEIS to be retained. But in a publication of the University of California Cooperative Extension (3) it is listed as a “High Fire Hazard Native Tree.” Note that these comments are not meant to imply favoring destruction of redwoods or bay trees but to further illustrate the inaccurate information and the arbitrary nature of the DEIS conclusions. Similarly cypress species which grow in parts of Strawberry Canyon are also listed as pyrophites in this UC document, but the DEIS does not propose their extirpation.

The DEIS fails to consider the impact on Strawberry Creek of run‐off from the predicted massive amounts of slash, from the standpoint of hydrology and flood control or the impact on the biota of the creek.

Section of the DEIS states within Strawberry Canyon there will be clear cutting on 56 acres and that the downed trees will be chipped and left on 20% of the site at a depth of 2 feet. Based on these numbers the cumulative amount of material on the ground will be 975,744 cubic feet (.2 x 56 x 43,560 x 2). If merely 1% of this material is washed away in a storm, which seems a very conservative estimate considering the slopes where the material would be placed, there could be more than 1,000 cubic yards of slash material washed into Strawberry Creek. The DEIS does not discuss the impact on the biota of the creek of this potential massive amount of new material. Nor does the DEIS discuss the impact of this material on stream flow in storm conditions. Given that the culverts in the lower levels of the creek, near the Haas Clubhouse and the University Botanic Garden, are only about 9.5 square feet in cross section (See Figure 1.), there is a strong likelihood that the slash material would block the culverts and cause flooding. Section states that “if the site yields a large number of large tree trunks,” some “may” be removed or used for other purposes than left on the site; however, the DEIS fails to state the criteria for determining what the “large number” is that would trigger such action. The hydrologic and ecological impacts are presumably left to the loggers to evaluate.

FEMA comment - Adams 1 copy

Figure 1, Culvert on lower fire trail, near Botanic Garden


The DEIS implies that trees other than eucalyptus, Monterey pines, and acacias will not be cut, but current actions in Strawberry Canyon suggest that UCB will cut anything at any time regardless of environmental regulations. The DEIS must be amended and re‐issued to include other UCB actions as part of cumulative impacts.

During the past week (June 6‐13, 2013) I have personally observed the cutting of at least six healthy, mature California live oaks, bays, and cypresses in Strawberry Canyon. (See Figures 2 and 3.) The oaks were particularly magnificent, and their destruction is tragic. I am familiar with the needs for passage of fire trucks as I own woodland property on a narrow privately maintained road. None of the trees just cut would have prevented passage of trucks, but I was told by one of the tree cutters that the excuse was “Fireman.” To my knowledge this cutting was done without any compliance with the California Environmental Quality Act (CEQA), which is the state equivalent of NEPA and applies to all UCB actions. This cutting constitutes a violation of the CEQA Guidelines Section 15304, which states that exemptions from CEQA apply only to actions “which do not involve the removal of healthy, mature, scenic trees.” If UCB is flagrantly cutting trees now, while the DEIS is out for public comment, what can we expect once the NEPA process is completed?

FEMA comment - Adams 2 copy

Figure 2. Bay stump on lower fire trail, cut on or about June 11 2013, diameter +/‐42”

FEMA comment - Adams 3 copy

Figure 3. Live oak stump on lower fire trail, cut on June 10, 2013, diameter +/‐ 38”

(1) EPA 738‐R‐06‐007, 2006

(2) The Jepson Manual of Vascular Plants of California, 2nd Edition, UC Press, 2012

(3) Pyrophytic vs. Fire Resistant Plants, FireSafe Marin in Cooperation with University of California Cooperative Extension, October 1998

Thank you, Mr. Adams, for taking the time and trouble to write this excellent public comment on the FEMA draft EIS.


“Tending the Wild:” Our changing relationship with nature

We recently introduced our readers to a book about the land management practices of Native Americans in California, Tending the Wild:  Native American Knowledge and the Management of California’s Natural Resources.  (1) Drawing from this valuable resource, we will describe how the relationship of humans with nature has changed several times since the arrival of humans in California approximately 12,000 years ago.  We will conclude by raising questions about our current relationship with nature, as reflected in our land management practices.

The relationship of Native Americans with nature

Basket CA Native AmericanWe will let the author of Tending the Wild speak for Native Americans, based on her extensive research of their culture and land-management practices:

“Although native ways of using and tending the earth were diverse, the people were nonetheless unified by a fundamental land use ethic:  one must interact respectfully with nature and coexist with all life-forms.  This ethic transcended cultural and political boundaries and enabled sustained relationships between human societies and California’s environments over millennia.  The spiritual dimension of this ethic is a cosmology that casts humans as part of the natural system, closely related to all life-forms.  In this view, all non-human creatures are ‘kin’ or ‘relatives,’ nature is the embodiment of the human community, and all of nature’s denizens and elements—the plants, the animals, the rocks, and the water—are people.  As ‘people,’ plants and animals possessed intelligence, which meant that they could serve in the role of teachers and help humans in countless ways—relaying messages, forecasting the weather, teaching what is good to eat and what will cure an ailment.” (1)

We emphasize that Native American culture considered humans a part of nature because this viewpoint provides contrast to modern interpretations of the relationship between humans and nature. 

Exploitation of nature by early settlers

When Europeans began to establish settlements in California in the late 18th century, they brought with them an entirely different viewpoint about their relationship with nature.  Natural resources were to be exploited and humans were the master of the natural world which was in their service.

Western pioneer ranch
Western pioneer ranch. Painting by John Olson Hammerstad, 1842-1925.


The first phase of European settlement was the importation of huge herds of livestock by the Spanish coming from Mexico:

“During the Mission era…grazing was among the activities that caused the greatest damage.  Coastal prairies, oak savannas, prairie patches in coastal redwood forests, and riparian habitats, all rich in plant species diversity and kept open and fertile through centuries of Indian burning, became grazing land for vast herds of cattle, sheep, goats, hogs, and horses owned by Spanish missions and rancheros.  By 1832 the California missions had more than 420,000 head of cattle, 320,000 sheep, goats, and hogs, and 60,000 horses and mules…overgrazing eliminated native plant populations, favored alien annuals, and caused erosion…A great variety of alien [plant] species were introduced inadvertently during the Mission Period.  Research has shown that European forbs and grasses…were brought into California at this time, contained in adobe bricks, livestock feed, livestock bedding, and other materials.  Soon these alien [plants] overwhelmed the native species, markedly changing the character and diversity of grasslands and other habitats west of the inner Coast Ranges.”  (1)

Tending the Wild reports that during this early phase of European settlement, Native Americans were quick to adapt to the changing landscape.  They incorporated useful new plants into their diets.  Likewise, we see today new plants and animals quickly enter the food web.


Hydraulic gold mining in California.
Hydraulic gold mining in California.

These changes in the landscape paled in comparison to the exploitation of the land that began in 1849 when gold was discovered in California and the huge influx of Americans of diverse European descent arrived.  Here are a few examples:

  • “…by the 1870s ‘more men made their living in the broader geography and economy of farming—48,000—than in all the mines of the Sierra footholls—36,000.’ To accommodate the acreage devoted to growing crops, marshes were drained, underground water was tapped by artesian wells, streams and rivers were dammed and diverted for irrigation, and lands were fenced.  In the process huge tracts of former native grasslands, riparian corridors, and vernal pools were converted to artificial, human-managed agricultural systems.” (1)
  • “Five million acres of wetland in California have been reduced by 91% through diking, draining, and filling for agriculture, housing, or other purposes.” (1)
  • By 1900, 40% of California’s 31 million acres of forest were logged.
  • “By the early 1900s, the numbers of marine mammals, wildfowl, elk, deer, bear, and other birds and mammals had been so drastically reduced that Joseph Grinnell would write, ‘Throughout California we had been forcibly impressed with the rapid depletion everywhere evident among the game birds and mammals.’” (1)
  • Between 1769 and 1845, the population of Native Americans in California dropped from an estimated 310,000 to 150,000. Between 1845 and 1855, the population of Native Americans dropped from 150,000 to 50,000.

Romanticizing Nature

Meanwhile, in Europe and the East Coast of the US, a new view of nature was being articulated.  The Romantic movement viewed nature as an escape from the stress of urban life, a tranquil retreat from civilization.  In California, John Muir was strongly influenced by Romanticism: 

“Muir and those with similar views responded to the destruction and exploitation of California’s natural resources with a preservationist ethic that valued nature above all else but which defined nature as that which was free of human influenceThus while he championed the setting aside of parks as public land, Muir also contributed to the modern notion that the indigenous inhabitants of the state had no role in shaping its natural attributes.” (1)

Muir was unable to fit Native Americans into his idealized view of nature.  He wrote this account of Miwok Indians in the Sierra Nevada in 1869:

“’We had another visitor from Browns’ Flat to-day, an old Indian woman with a basket on her back.  Her dress was calico rags, far from clean.  In every way she seemed sadly unlike Nature’s neat well-dressed animals, though living like them on the bounty of wilderness.  Strange that mankind alone is dirty.  Had she been clad in fur, or cloth woven of grass or shreddy bark, like the juniper or libocedrus mats, she might have seemed a rightful part of wilderness; like a good wolf at least, or bear.  But no point of view that I have found are such debased fellow beings a whit more natural than the glaring tailored tourists we saw that frightened the birds and the squirrels.’” (1)

Sharp Park, Pacifica, CA.  Photo by Erica Reder, SF Public Press
Sharp Park, Pacifica, CA. Photo by Erica Reder, SF Public Press

In this romanticized view of nature, humans are not welcome Humans defile the purity of nature.  This is the prevailing viewpoint today among those who consider themselves environmentalists, park advocates, and conservationists.  They advocate for “wilderness” where “humans may visit, but not remain.”  They post signs, advising visitors to look but not touch.  Their “restoration” projects put nature behind a fence.  They complain about immigration.

The condescending attitude articulated by John Muir toward Native Americans was instrumental in our ignorance of their land management practices.  Europeans considered Native Americans primitive and therefore did not expect to learn anything useful from them.  Europeans imported and grew their own food from their original homes because they were unaware of how local food sources could be grown and used.  Our knowledge of Native American culture is recent and it comes too late to ever be fully informed because those who tended the land are long since gone.  Furthermore, this new knowledge of land management practices of Native Americans is not well known, certainly not among native plant advocates who are attempting to re-create a landscape which was created by methods they do not understand.

Redefining ecological “restoration”

The author of Tending the Wild admires Native American culture as well as the landscape that was created by their land management practices.  Therefore, she concludes her book with a proposal that we adopt their land management methods:

“What then, should be the goal of ecological restoration?  Restoring landscapes and ecosystems to a ‘natural’ condition may be impossible if that natural condition never existed…Restorationists must at the very least acknowledge the indigenous influence in shaping the California landscape.  This chapter advocates an additional step—using indigenous people’s knowledge and methods to carry out the restoration process, to return landscapes to historical conditions and restore the place of humans in this continuing management.”  (1)

In our previous post, we described some of the land management practices of Native Americans, particularly the importance of setting fires.  Adopting these management practices for ecological restorations would require us to make a permanent commitment to setting fires.  Fires pollute the air, release greenhouse gases into the atmosphere, and endanger lives and property.  Therefore, this is surely not a proposition that can be reasonably applied to our densely populated urban parks.  The maximum population of Native Americans prior to the arrival of Europeans is estimated to have been 310,000.  The population of California was estimated to be over 38 million in 2013.  Land management practices that were appropriate for a human population of only 310,000 are not appropriate for a population of over 38 million.

Furthermore, the land management practices of Native Americans were useful for their culture.  They tended the landscape in order to feed, clothe, heal, and house themselves.  If that specific landscape is no longer useful for those purposes, why would we consider it an ideal landscape?  In what sense would it be superior to the landscape that occurs naturally without setting fires or intensively gardening our open spaces?

A more realistic paradigm is needed

We believe a more sustainable paradigm for managing nature is needed.  Although we won’t presume to define this new paradigm, we will suggest some parameters:

  • Humans are as much a part of nature as any other animal. Therefore, conservation goals must accommodate the presence of humans.  However, humans must respect plants and animals as equal partners in achieving conservation goals.
  • Since we live in a free society, we must assume that human populations will grow in proportion to the choices of humans. And since we are a nation of laws, we must assume that immigration will occur as allowed by our laws.  Conservation goals must be consistent with the realities of human population density.
  • Conservation goals should look forward, not back. Goals should reflect the changes in the environment that have already taken place and anticipate the changes that are expected in the future.
  • The distinction between native and non-native species should be only one of several criteria to determine whether a species “belongs here.” If plants and animals are sustaining themselves without human subsidy, we should acknowledge and appreciate the functions they perform in the ecosystem.  This approach will reduce the use of herbicides, now being used to eradicate plants perceived to be “non-native,” in our parks and open spaces.
  • Conservation goals should be realistic within the confines of available resources and in competition with other priorities.
  • There are pros and cons to every change we make in the landscape. Whenever we alter the landscape, if our land management methods damage the environment by using pesticides, killing animals or destroying their food resources and homes, contributing to greenhouse gases, restricting recreational access, etc., we must have solid evidence that the benefits to the environment will be greater than the damage we foresee.  If there is no net benefit, we should leave it be.

Can you add to or suggest revisions of this list of a new conservation ethic?  Surely there are as many opinions as there are readers of Million Trees.  We would like to hear your ideas.



  1. M. Kat Anderson, Tending the Wild: Native American Knowledge and the Management of California’s Natural Resources, University of California Press, 2005 (This is the source of most of the information in this article.)

A defensive tirade from invasion biologists

Pesticide use by land managers in California.  Source California Invasive Plant Council
Pesticide use by land managers in California. Source California Invasive Plant Council

An international team of invasion biologists has just published a defense of their academic turf, invasion biology.  (1) Daniel Simberloff, an American member of the team, is the most relentless defender of the crusade to eradicate all non-native species, wherever they are found, all over the world.  Their publication acknowledges the mounting criticism of this crusade and attempts to respond to that criticism, but what is most notable is what is missing from their attempt to defend their opinions.  They make no mention of the harmful methods used to eradicate non-native species:

Keep these damaging methods in mind as we visit the hypocritical and contradictory arguments used to justify the projects for which these invasion biologists advocate.  They set up “novel ecosystems” as the straw man to which they compare the goals of invasion biology.  They define novel ecosystems as “a new species combination that arises spontaneously and irreversibly in response to anthropogenic land-use changes, species introductions, and climate change, without correspondence to any historical ecosystem.”

“Lack of rigorous scrutiny”

Their primary criticism of the concept of “novel ecosystems” is that it has not been “subjected to the scrutiny and empirical validation inherent in science” and its definition is “impaired by logical contradictions and ecological imprecisions.”   These criticisms apply equally to invasion biology.

Hypothesis n % of supporting studies % of decline in support
Invasional meltdown




Novel weapons




Enemy release




Biotic resistance




Tens rule




Island Susceptibility




Although support is strongest for the invasional meltdown hypothesis, recent studies are less supportive than early studies, indicating substantial decline in supporting evidence.  Declining evidence of invasional meltdown is consistent with the fact that exotic species are eventually integrated into the food web which reduces their populations, stabilizing their spread. There is apparently little evidence that islands are more susceptible to invasion than continents and few studies have been done to test the hypothesis.

If empirical validation and semantic precision are required to establish the credibility of scientific hypotheses, invasion biology has failed that test.

“Precautionary principle of conservation and restoration”

These invasion biologists define the precautionary principle of conservation and restoration as follows:  “we should seek to reestablish –or emulate, insofar as possible—the historical trajectory of ecosystems, before they were deflected by human activity.”  This is an unusual use of the precautionary principle, which is more typically defined as avoiding damage to the environment by not using potentially harmful methods, even in the absence of solid evidence of such harm.  The precautionary principle was not used when the following “restoration” projects were defined or implemented:

Ivy in the Conservatory in Central Park, New York City
Ivy in the Conservatory in Central Park, New York City

In 1996, Daniel Simberloff made this statement in his publication about the hazards of biological controls:  “…are there any protocols for biological-control introductions that would prevent all disasters?  Probably not…” (2) Yet, in 2013, he expressed his support for the introduction of non-native insects to control cape ivy at a conference at UC Davis sponsored by the California Department of Food and Agriculture.  Although cape ivy is despised by native plant advocates, it is not an agricultural pest and therefore causes no economic damage to ecosystems, unless money is wasted on attempts to eradicate it.

“All ecosystems should be considered candidates for restoration”

In response to those who find value in novel ecosystems, these invasion biologists find none.  They reject the possibility that there is ever a point at which it may not be possible to re-create a historical landscape.  They continue to believe that ANY and ALL radically altered landscapes CAN and SHOULD be considered candidates for restoration.  Their only caveat to this universal goal is that “damaged ecosystems…should be evaluated for feasibility, desirability, and cost-effectiveness, on a case-by-case basis, so that informed and science-based policy decisions can be made, in consultations with scientists, restoration practitioners, stakeholders, and advisors.”

These criteria for potential “restoration” have nothing to do with reality:

  • Most projects in the San Francisco Bay Area have not provided cost estimates when they were planned. The public demanded cost estimates for the projects of the Natural Areas Program in San Francisco, but these demands were ignored.  Therefore, “cost-effectiveness” is not usually considered when these projects have been shoved down the public’s throat.
  • We consider the public to be “stakeholders” in decisions to radically alter our public open spaces. We are the visitors to these areas and our tax dollars pay for their acquisition, maintenance, and “restoration.”  Yet, managers of public land are consistently making those decisions without taking the public’s opinion into consideration.  Most projects are planned and executed without any public participation.  In the few cases in which there are environmental impact reviews, the projects are implemented regardless of overwhelming opposition of the public.

 “Human-damaged ecosystems can be at least partially restored”

The demonstrated futility of “restoration” projects is one of many reasons why there is waning public support for attempting them.  Yet, invasion biologists who authored this diatribe claim that “restored sites recovered on average 80-86% of biodiversity and ecosystem services…and showed improvements of 125-144% over degraded ones.”  This claim is contradicted both by other scientific studies and by experience with local projects:

  • “…this paper analyses 249 plant species reintroductions worldwide by assessing the methods used and the results obtained from these reintroduction experiments…Results indicate that survival, flowering and fruiting rates of reintroduced plants are generally quite low (on average 52%, 19%, and 16% respectively). Furthermore, our results show a success rate decline in individual experiments with time.  Survival rates reported in the literature are also much higher (78% on average) than those mentioned by survey participants (33% on average).” (3)
  • Dunnigan Test Plot, Augusst 2011.  The result of an eight-year effort to restore native grassland.  Does it look "biodiverse?"
    Dunnigan Test Plot, August 2011. The result of an eight-year effort to restore native grassland. Does it look “biodiverse?”

    There is frequently a discrepancy between the success rates claimed in papers and those actually observed. For example, Cal-Trans gave researchers at UC Davis $450,000 to restore 2 acres of non-native annual grassland to native grassland.  UC Davis researchers spent 8 years and used multiple methods to achieve this transition.  When they ran out of money, they declared success in their published report.  They defined success as 50% native plants which they expected to last 10 years before being entirely replaced by non-native annual grasses again.  Do you consider that a success?

  • On a more anecdotal level, we watch established landscapes that have required no maintenance in the past being transformed into weedy messes by failed “restoration” projects. Then, adding insult to injury, we hear those who are responsible for these failures tell us how successful they are.

“Inadequate political will”

The authors of this publication conclude:

“No proof of ecological thresholds that would prevent restoration has ever been demonstrated.  Often the threshold that obstructs a restoration project is not its ecological feasibility, but its cost, and the political will to commit to such cost.” (1)

We are reminded of an old football adage:  “The best defense is a good offense.”  In other words, invasion biology is under fire, but the reaction of invasion biologists is to demand more….more money, more effort, and the commitment of public land managers to “restore” all ecosystems, regardless of what the public wants.  And in support of that aggressive strategy, they refuse to acknowledge the damage that is being done to the environment and the animals that live in it, by the projects they demand.

The authors of this defensive tirade have hammered another nail in the coffin of invasion biology.

  1. Carolina Murcia, James Aronson, Gustavo Kattan, David Moreno-Mateos, Kingsley Dixon, Daniel Simberloff, “A critique of the ‘novel ecosystem’ concept,” Trends in Ecology and Evolution, October 2014, Vol. 29, No. 10
  2. Daniel Simberloff and Peter Stiling, “How Risky is Biological Control?” Ecology, 77(7), 1996, pp 1965-1974
  3. Sandrine Godefroid, et. al., “How successful are plant species reintroductions?” Biological Conservation,   144, Issue 2, February 2011

Where does it end?

It is our pleasure to republish with permission a post from the website of Flood Creek Non-Nativist Landcare Group.  Flood Creek is located in Braidwood, New South Wales, Australia.  Across Australia, Landcare is a popular volunteer-based environmental movement which enjoys general support from government in the form of occasional financial grants. Over the last 25 years, many Landcare groups have undertaken projects with the stated goal of eradicating non-native plants based on a belief that native plants and animals would benefit.  That strategy will sound familiar to our readers, as will the damage to the environment which it causes.  

The Non-Nativist Landcare Group is a small team of people with a history of participation in Landcare who want to foster a discussion of current nativist approaches to environmental management, and question their outcomes.  Based on their experiences with conventional Landcare projects, the Non-Nativist Landcare Group has concluded that these often do more harm than good.  The Group describes their mission:   “Above all, this discussion is inspired by the goal of taking a more ecologically-based and functional approach to Australian socio-ecological systems and their health. We seek to highlight the inconvenient-truth that rational environmental management can never be based upon a simple mantra of “natives good, non-natives bad”. Extermination is rarely an effective way to promote landscape diversity and resilience.”

Please visit their website and wish them well in their effort to find a less destructive approach to land management.

When you look at the willful and wanton environmental destruction conveyed in these photographs you must ask yourself: ‘how could anyone do this in the name of environmentalism?’ After all the disturbance we’ve already inflicted upon this biosphere, how is this really helping?

Flood Creek 1


In this example of willow demolition, the trees were cut down and dragged away and the stumps were poisoned. Then (for some unfathomable reason) a drainage ditch was excavated into the floodplain. In the photo below, the main flow-line is 40m off to the left.

Flood Creek 2

Apart from the economic motives at play (a theme for a future post), I can think of only one reason why an ‘environmentalist’ might condone this kind of damage and disturbance. It must be to do with that old adage, ‘the end justifies the means‘.

The reasoning seems to be: ‘Sure, it makes a big mess and causes erosion, and nutrient release, and carbon emissions, and local temperature increases, and loss of habitat, but it’s necessary because we’re going to make Australia a place for natives-only again.’

So that’s the end we’re aiming for: a ‘native-only’ Australia. And these photos show the means we must accept along the way.  It seems we’re just going to remove all of the non-natives from this continent so the environment is back to ‘pristine’ again and then we can stop with the chainsaws and excavators and herbicides in the name of ‘saving’ the environment.

Flood Creek 3

We just want 1788-Australia back. Presumably without the dingoes and without the previous intrinsic Aboriginal management; plus with a few minor additions like cattle; and sheep; and horses; and apples; and asparagus; and hops; and wheat; and rice; and trout; and tomatoes; and lettuce; and cats; and dogs; and goldfish; and maybe just one or two other things, but that’s it! And we want all the ‘invasive’ natives, like Cootamundra Wattle, and Sweet Pittosporum, and Kookaburras to know their place and to go back where they were when Europeans first arrived….And stay there forever and ever….And not move just because the climate or fire regime has changed. And this won’t happen by itself so we’ll need funding and legislation and heavy machinery. And we’re going to fix it all ‘real good’ without knowing what it was actually like or exactly what species existed in many parts of the country back in 1788. And….and…..

Flood Creek 4

….And then again……When you think about it…..Are we ever actually going to achieve anything even remotely approaching a native Australia?…..really?

I doubt it.

And I’d doubt the sincerity (or sanity) of anyone who says that we could. Surely nobody actually believes this?

So, given this impossibility, it seems pretty reasonable to ask ourselves: ‘how can the end justify the means, when it’s clear there really is no conceivable end?’ If it just goes on and on forever, then how do we justify these means to no end at all? How do we live with this permanent state of expensive self-congratulatory environmental vandalism?

More importantly, given how well-supported the above activities currently are, how do objecting grassroots Landcarers begin to articulate new ways to work with the adaptive living-landscapes around us? And how do we influence the direction of our own movement so that participation in Landcare is not assumed to mean support for this destruction?

All the death and destruction in these photographs is familiar to us here in the San Francisco Bay Area.  The only difference is that the trees that were destroyed in this project were willows, which are native in California, but not native in Australia.  That difference helps us appreciate the arbitrariness of nativism, which treats eucalyptus as demons and willows as the “good” trees in California.  

We have yet to witness a “restoration” that wasn’t far more destructive than constructive.  And based on our experience in the San Francisco Bay Area, we can venture an answer to the rhetorical question, “Where does it end?”  It doesn’t end because every “restoration” is quickly occupied again by the plants that were destroyed by herbicide applications.  As long as the objective continues to be to kill everything non-native and re-populate a landscape with native plants, the project will never be complete. 

 Therefore, it only ends when the goal is revised and/or the effort is no longer funded.  And the only way to achieve that revised goal is for the public to object to the destruction of their public lands.  So, if you are tired of witnessing these destructive projects, speak up!  Tell your elected representatives that you don’t want your tax dollars spent on the pointless ruin of public open space. 

Coastal Trees Endangered by Nativism

We are pleased to publish a guest post by Moro Buddy Bohn, who is trying to save a forest of Monterey Cypress and his home of 55 years from being inundated by sand.   The sand lying between his beachfront home and the ocean has been destabilized by the removal of European beach grass at Salmon Creek State Beach by the US Army Corps of Engineers (and local State Park refusal to replant it).  Moro tells us about this issue in the hope of finding help to save what’s left of the bird and animal-habitat beach forest being destroyed by runaway sand.  Please contact him at if you would like to participate in his advocacy effort or volunteer to help shovel sand away from the trunks of trees that can still be saved.

Salmon Creek

Moro is a professional classical guitarist-composer and author of Kin to the Wind, the story of his youthful round-the-world travels through 50 nations that included an Arabian Desert crossing by camel in the company of Bedouin smugglers.  Visit his website for a sampling of his music and a description of his book.


Endangered oceanfront Monterey cypress trees along Sonoma Coast
Endangered oceanfront Monterey cypress trees along Sonoma Coast

Northern California’s coastal cypress trees are endangered by nativists in control of State Parks. Entrusted to look after our trees, they’re actually destroying them. They employ slow suffocation as opportunities arise, for it’s cheaper than clear-cutting. They’ve allowed a sand dune tsunami to form and swallow our mini forest of Monterey cypress trees at Sonoma Coast’s South Salmon Creek Beach State Park near Bodega Bay.

Their ecological thought is presently gripped by an ideology espoused in WWII Germany known as nativism, understandably dubbed a pseudoscience by horrified witnesses to the destruction. Nativists protect life forms they think are “native.” They treat other forms as “exotic alien invaders” and destroy them on public lands when/as funds are available.

I watched our Salmon Creek cypress tree saga begin more than 50 years ago. Human encroachment had destroyed our “native” grass, destabilizing the sand dunes. So the deeper-rooting European grass was chosen, after years of study, and planted to save our homes, the fishing industry, and Salmon Creek itself. The sand having been re-stabilized, a forest of Monterey pine and cypress trees, together with other coast-enhancing flora now considered “exotic alien invaders,” were then planted by Park rangers who understood that these were the only plants proven capable of withstanding beach abuse.

But nativism took control of ecological thought in the early eighties, causing ecologists in charge at State Parks to begin orchestrating the destruction of these same “alien exotics.”

Nativists are now actually destroying the tougher species they planted in Salmon Creek, attempting to replace them with the weaker, shallower-rooting “native” species that died out because they couldn’t coexist with 20th-century human invasion.

So beach forest endangerment isn’t from man generally, but from this new breed of men who’ve taken over California’s coasts, beaches and parks and practice nativism. They’ve dubbed Monterey cypress trees unlucky enough to be outside the Monterey Bay Area as “non-native scrub.” But Sonoma Coast’s “non-native scrub” lucky enough to be on private property is often highly prized and cared for by residents who consider cypress trees among the most exquisite of nature’s creations.

Much admired by State Highway 1 motorists, this Monterey cypress graces a Sonoma coast property.
Much admired by State Highway 1 motorists, this Monterey cypress graces a Sonoma coast property.
“Non-native scrub” (Monterey cypress) adorning the Bodega Harbor Clubhouse parking lot.
“Non-native scrub” (Monterey cypress) adorning the Bodega Harbor Clubhouse parking lot.

These photos generate a question. Why can’t Sonoma Coast State Parks people express as much pride in their cypress trees as Sonoma Coast property owners do, and treasure them as do the State Parks people at Pt. Lobos State Park south of Carmel?

Is it because nativist pseudoscientists say the trees are “invading” from Monterey and Carmel? Is that the reason they’re dubbed “alien scrub” and being allowed to be buried by windblown sands? Incredibly the answer is yes, based on my interviews with them.

The obvious flaw in nativism is that no one can define what’s “native” and what isn’t. For species migration has been going on since life began on the earth. The question, “native to when,” is therefore begged, and nativism’s hollow sophistry is thus exposed.

How did cypress trees get to Monterey initially? Were they not invaders there too at some point when nativists weren’t around to mourn losing the area’s treeless heritage and combat them with mass arborcide campaigns?

Nativists claim “invader” plants threaten biodiversity, but the opposite is often true. For example, studies show “invading” eucalyptus trees are home to 47 native California bird species, host an understory of 36 plant species, and are preferred by wintering monarch butterfly congregations. Author, lecturer and conservationist J.L. Hudson says,

“The ‘anti-exotics’ movement is a growing threat to biodiversity conservation efforts. In the past 10 years, the mythology of ‘invasive non-native species’ has spread from a minor pseudoscience indulged in by the gullible fringe, to a growing extremist movement uncritically embraced by otherwise responsible environmental groups…It is ominous.. that during Adolf Hitler’s Third Reich, the National Socialists (Nazi Party) had a program to rid the landscape of  ‘foreign’ plants.”

Dr. Suzanne Valente posted a comment on blog #93, by Point Reyes Light publisher-editor emeritus David Mitchell, about the fallacy of nativism in general. She says,

“We should recognize nativism shows no respect for the sanctity of life, all life…”

So it would appear Sonoma Coast is far from alone in the abuse it receives at the hands of nativists in charge who’ve been entrusted by the public to protect it. The resurgence of nativism during the 1980s has become, in fact, an issue of worldwide concern.

At Sonoma Coast’s Salmon Creek Beach, a moving dune (now known as the big South Salmon Tsunami) began in the early 1980s when the U.S. Army Corps of engineers used heavy equipment to re-float a beached Coast Guard ship. The cranes and tractors tore out a healthy section of European grass that had been planted by a massive cooperative effort between Parks, citizen volunteers and the US Dept. of Agriculture in the ‘50s and ‘60s after native grass and shrubs had been destroyed by normal beach abuse of human influx.

The Army offered to replant the grass. But State Parks, while vowing to take care of the forest, took no action and allowed the Army’s 5-year Statute of Limitations of Liability to expire. For nativism had by then taken a stranglehold on ecological thought, and replanting of “invading” European grass was unthinkable.

So the multi-acre South Salmon Tsunami began. It has swallowed much of the beach’s thriving mini forest that was planted, prior to the rise of nativism, by predecessors of the current regime at State Parks. The forest that still remains is endangered by the runaway tsunami of sand.

Some of the endangered mini beach forest during a golden afternoon at Salmon Creek Beach
Some of the endangered mini beach forest during a golden afternoon at Salmon Creek Beach

This endangered forest mingles the bouquet of fresh salty air, flowering blossoms, rosemary, and pine cones. A virtual oceanfront paradise, it’s enjoyed by birds who sing to the accompaniment of gentle surf sound.

Little passageways lead through friendly tree branches to quiet mini sanctuaries where beachgoers meditate, and quail, jackrabbits, raccoons, deer, possums and birds make their nests, relate in privacy, and munch on seeds or succulent blossoms.

But the runaway South Salmon Tsunami—now a 30-foot-high wall of sand moving (by State Parks measurement) at 12-plus feet per year (about 3 inches per week)—will soon bury it. It has already buried dozens of cypress trees and now threatens homes.

The big South Salmon Tsunami
The big South Salmon Tsunami

The tsunami slowly suffocates the trees at 3 inches per week as seen below.

Current cypress tree victim breathing its last
Current cypress tree victim breathing its last

If not followers of Pythagoras who described trees and plants as ensouled entities, many local residents view the mass arborcide—death by suffocation at 3 inches per week—as macabre and immoral. A Bodega Bay resident recently declared that when she sees a tree destroyed for no good reason, she feels “…a deep pain, like a stabbing in the heart. By allowing the harming of trees, we destroy a part of ourselves. And that’s immoral.”

The trees could be saved by stabilizing the tsunami with European grass, the one ground cover determined by the USDA, after extensive study, to root deeply enough to withstand modern beach abuse and hold the sand in place. But nativists in charge won’t consider it. And along rural, less frequented, less windy coastal areas, they’re actually destroying the European grass at considerable public expense and replacing it with weaker native grass that will hold only so long as those areas remain less frequented.

It’s logical that when an ecosystem can no longer survive, owing to a newly arrived hazard such as human beach abuse, a new ecosystem capable of living with that environmental abuse needs to be introduced. But the nativists at State Parks want only to reestablish the failed ecosystem.

Their most recent planting of the shallow-rooting native grass at Salmon Creek Beach parking lot in 1993 has failed, having been torn out by log-dragging bonfire builders and children playing.

So the nativists are fully aware native grass no longer survives here. But they still cannot rationalize planting a so-called “alien species” (European grass) to benefit other “aliens” such as Monterey cypress and pine trees, ice-plant, lupine, possums (“invaders” from Georgia), deer, jackrabbits and raccoons (all of them “invaders” of sorts—some from far away) who take sanctuary among “alien” trees to enjoy “alien invader” birds singing.

Homes Threatened

Below is a view from atop South Salmon Tsunami’s cutting edge, looking toward its next victims—trees and homes in its path.

South Salmon Tsunami, having swallowed dozens of trees, is now approaching homes.
South Salmon Tsunami, having swallowed dozens of trees, is now approaching homes.

Salmon Creek Itself—and Children—Jeopardized Too

Extreme abuse by man and horse has also destroyed marsh vegetation alongside Salmon Creek itself, about 300 yards north of the great South Salmon Tsunami.

This destruction has created another runaway dune, encouraging tunnel digging that proved fatal for a Tucson ten-year-old over Labor Day Weekend, 2007. He crawled into the tunnel he’d dug, and it collapsed on him. His 15-year-old brother, digging near him, couldn’t get to him in time. Locals hope his death won’t be in vain or go unheeded.

Two years earlier, in 2005, a Salmon Creek homeowner had written to the local State Parks resource ecologist, “We feel that the dune poses an attractive nuisance to the many small children who play on it and fear that they will either be injured by hidden broken glass/rusty nails, etc. or by becoming buried in the unstable sand or by having a spinal cord injury secondary to jumping off the steep dune.”

That same ecologist met with Salmon Creek homeowners shortly after getting the letter.  Ironically he told us that loose sand poses no threat to children playing, or to the park.

But ten-year-old Andrew Waldrup of Tucson, AZ, was killed within two years, and windblown sand is now being pushed into the creek by foot traffic of man and horse. This affects the fishing industry, for salmon need the creek for their annual migrations.

In the face of all this, State Parks continues to dodge requests that they terrace the sand, plant vegetation proven to withstand modern beach abuse, and thus end the ecological disaster, public nuisance and danger the unstabilized sand poses.

Loose sand, pushed by foot traffic, sloughing off into Salmon Creek
Loose sand, pushed by foot traffic, sloughing off into Salmon Creek

So there’s been no meaningful action—only broken promises, false starts, and plantings of native grasses that couldn’t and didn’t last because native grass cannot withstand modern beach abuse as has long been proven.

Still More Trees Being Buried at South Salmon Parking Lot

Still more bird-habitat Monterey cypress trees, about 200 yards north of the great South Salmon Tsunami, are now also endangered, being directly in the path of the Parking Lot Tsunami that killed Andrew. This new tsunami, made from loose sand alongside the creek, is being allowed to advance from the creek and bury a stand of cypress trees at the South Salmon Creek Beach parking lot entrance.

Volunteers with shovels might still be able to save some of these half-buried trees if something is done soon. But there’s no chance of that until nativism is challenged and replaced by common sense. Park ecologists don’t consider the arborcide immoral at all. So loss of the Monterey cypress continues as trees are victimized by pseudoscience.

Cutting edge of Parking Lot Tsunami burying cypress trees at South Salmon parking lot entrance
Cutting edge of Parking Lot Tsunami burying cypress trees at South Salmon parking lot entrance

Source of the Tsunami

The denuded bank of Salmon Creek, shown below, provides the sand that’s burying these trees. This photo looks down the tsunami’s windward side toward uncovered sand that will need stabilization to protect the creek, its inhabitants, the trees, and children playing.

Source of the Parking Lot Tsunami--a vast area of grassless dune alongside Salmon Creek
Source of the Parking Lot Tsunami–a vast area of grassless dune alongside Salmon Creek

Snowy Plover Endangered by Loss of European Grass

Beach vandals harass even the bravest surviving snowy plovers, stealing their driftwood logs behind which they nest out of the wind, to make bonfires. Unleashed dogs have all but annihilated this tiny bird whose one last refuge, paradoxically, is in the concealment provided them by the tall, coastal European grass that State Park nativists are actively destroying at many beaches while simultaneously bemoaning the plover’s demise.

Spotted Owl Endangered by Loss of European Grass and Tree Burial

European grass, when maintained, serves trees by stabilizing the sand, preventing our uniquely fierce, prolonged, Sonoma Coast windstorms from creating tsunamis. The trees in turn serve birds and man with homes and shade.

A spotted owl, former resident of a Salmon Creek cypress tree, recently became a refugee when the big South Salmon Tsunami swallowed his abode. So he came to live with me for awhile, perching on a 4×12 beam out of the wind along the leeward side of my home. He’d swoop down on suspicious wiggles in the European grass to gather his meals. I owe the honor of his visit to nativists who willfully let the tsunami bury his natural home.

Monterey Pine Falsely Accused of Being Non-native

Monterey Pines, like Monterey Cypress, are also considered “invading, alien scrub” when outside Monterey County. But Connie Millar, U.S. Forest Service ecologist, advocates planting them where fossils found throughout California prove they lived during the middle Miocene and Pleistocene Ages and are of late returning home.

She tells the tragic story of a No. Calif. state park where a forest of Monterey pines considered “alien invaders” was cut down by nativists ignorant of our natural history, the philosophy of the sanctity of life, and the common sense realization that even if there are no fossils proving “native” status, a tree or plant serving birds, man, and environment with its beauty and function—and harming no one—should be saved whenever possible.

Driftwood Road Arch, below, is artfully created by two “alien invader” Monterey pines reaching out over Driftwood Road. The arch gives welcome shade on hot days. But this pair of “invaders,” directly in the dune’s path, will be buried if public apathy continues.

Driftwood Rd. Arch, artfully providing shade, is in line to be swallowed by the moving dune
Driftwood Rd. Arch, artfully providing shade, is in line to be swallowed by the moving dune

Invasion a Mythology

To prevent still further destruction of our forests, the mythology of “invasion” needs to be recognized for what it is—mythology. An old ranger I met at the beach once told me there’s no reason for nativism in Salmon Creek. For tourist abuse at this beach is so harsh, even European grass, the world’s toughest, is severely challenged.

Like me, he loves all trees, grasses and shrubs. He says the anti-exotic programs looked harmless enough at the start. “But people just weren’t thinking,” he said, and that’s how nativism, with its mass arborcide and other beach forest destruction, gained momentum and became established. But now he agrees it needs to be stopped. So I propose a five-step plan to save Salmon Creek’s trees and mini forest:

Five-Step Plan

1) Get applicable nativist policies overridden (an exception granted for heavily abused public land) so that the planting of European grass for long-term dune stabilization (followed by replacement of the buried trees, flowers and shrubs capable of withstanding Salmon Creek’s uniquely tough beach abuse) will be permitted here again.

2) The moving dune’s steep slopes need to be reshaped, creating flat terraces that will discourage sand surfers and prevent windswept sands from covering the newly planted baby shoots of European grass.

3) Then, according to the USDA brochure, Sand Dune Control Benefits Everybody—The Bodega Bay Story (circulated in 1967), the entire dune should be planted with shoots of European beach grass during December and January—18-inch pre-started clones—75,000 clones per acre at nine-inch depth with spacing of 12 to 15 inches between clones.

4) Fence off the dune to protect baby shoots from abuse by vandals, sand surfers, run-jump-and-sliders, log draggers and jackrabbits. 1000-dollar-fine signs for fence violators could be posted along the fence and enforced by rangers (a source of much-needed income for State Parks!).

5) Per USDA instructions, apply a 20-20-0 fertilizer at 200 lbs. per acre each February, for 3 years, on the new plantings.

Nativists Will Fight All Rescue Attempts

Stimulus Funding will need to be applied for and received by benignly motivated, clear thinkers at State Parks.

Nativists everywhere will certainly object to the rescuing of “alien” trees and will fight it.  But assuming enough of them can be convinced to help put an end to the arborcide of Salmon Creek’s remaining forest, there will still be the taking and approving of bids, and time-consuming greenhouse preparation of the 18-inch clones. So constructive litigation will need to begin soon, for sand is already climbing the trunks of remaining trees.

Nativism’s Further Devastation in Nahcotta, WA

In Willapa Bay, Nahcotta, WA, the state and county are implementing the current West Coast Governor’s Action Plan by spraying imazapyr-glyphosate-containing herbicides along the tidal flats to eradicate “invading” spartina grass. But Spartina is considered precious along the Atlantic Coast. Dr. James Morris, Director of Baruch Institute of Marine and Coastal Science, showed in his 2011 PIEL Conference discourse that spartina isn’t harmful and provides economic benefits that dwarf the $25M taxpayer dollars so far spent on local spraying that primarily serves the toxin makers. “Not all ‘invasives’ are troublesome—some are beneficial,” he says. He recommends action against “invasives” be taken on a case by case basis. Author-Professor Michael Pollan recently remarked, “the war on ‘invasive species’ has been founded more on ideology than science.”


Although we are unfamiliar with this specific project, we are well aware of the consequences of removing non-native vegetation which stabilizes the coastal dunes of California.   The first book we read about ecological “restorations” was Ecology and Restoration of Northern California Coastal Dunes by Andrea Pickart and John Sawyer (Sacramento: California Native Plant Society, 1998).  Ms. Pickart was the manager of the Lanphere Dunes near Arcata, California.  She acknowledges in that book that native dune plants do not stabilize sand.  In fact, many native dune plants require transporting dunes for propagation and long-term survival.  We have visited that project which is open to the public on a very limited basis because of the fragility of a native dune landscape. 

We have not verified any of the factual information in Moro’s article. However, Moro has provided the following bibliography of his sources.  

Recommended reading/viewing:  (Below are 12 data sources for this article)

The Monterey Pine through geologic time

Eco-fascism in the Pt. Reyes National Seashore

Natives Vs. Exotics: The Myth Of The Menace

Axelrod, D.I., and F. Govean. 1996. An early Pleistocene closed-cone pine forest at Costa Mesa, southern California. International Journal of Plant Science 157(3):323–329.

Millar, C.I. 1998. Reconsidering the Conservation of Monterey Pine. Fremontia 26(3):12–16.

USDA Brochure 1967  Sand Dune Control Benefits Everybody—The Bodega Bay Story.

How Understanding Evolution Can Help Us Conserve Species.

In Jeopardy: The Future of Orgainc, Bioidynamic, Transitional Agriculture

Dr. James Morris, Spartina (videotaped PIEL Conference discourse of Mar. 5, 2011)

Michael Pollan quoted in “Rethinking ‘Invasive Species’: Environmentalism Gone Awry?”–  October 8, 2012 Symposium flyer

David Theodoropoulos, Invasion Biology (PIEL panel) 

Ludwig Report 

Ecological “restoration” projects: Scientific or public policy decisions?

Invasive and Introduced Plants and Animals:  Human Perceptions and Approaches to Management is edited by two British academics.  It is a collection of articles written by invasion biologists as well as scientists who are critical of invasion biology.  It attempts to present the entire spectrum of opinion on the debate that is the primary subject of the Million Trees blog:  “Our intention is to stimulate the reader to question ideas and received wisdom [about invasion biology], and to try to establish the interface between objective science and subjective sociocultural fashions and values.  (1)  That is, the evaluation of invasion biology involves both science and public opinion.

Using both criteria, the authors evaluate conservation projects in their concluding chapter of the book:  “We perceive that present approaches:

  • Generally lack scientific rigour in their justification;
  • Fail to inform and engage and call upon all stakeholders…;
  • Rarely provide a holistic (for example, catchment wide) context or strategy;
  • Almost always lack financial or human resources to be long-term effective;
  • Have no realistic long-term targets, and if they do, no effective monitoring towards achievement…”   

This evaluation of ecological “restoration” projects fits perfectly with our opinion of projects in the San Francisco Bay Area.  These projects are not based on sound science. They are initiated behind the public’s back and are therefore rarely supported by the public. Most importantly, they are usually unsuccessful.  Typically, the projects are far more destructive than constructive.  We are losing the trees we value and the habitat needed by wildlife and in return we are usually left with barren, weedy messes.

Based on these shortcomings, the authors point to new approaches that address past failures. 

Acknowledge ambiguity and change

First, we must accept that the distinction between native and exotic plants is often ambiguous and the distinction between plants that are harmful and those that are not is even less clear.  Dividing up the natural world into good and bad, is a fool’s errand that does not acknowledge that such judgments are ultimately a matter of opinion. 

How many times have we heard native plant advocates say, “I hate eucalyptus”?  More often, they dress up their hatred in more valid arguments, such as eucalyptus is flammable, or they aren’t healthy, or they kill other plants or they aren’t useful to wildlife.  Those who defend eucalyptus know that these accusations are not true or equally true of some native trees.  Therefore, that argument can’t be resolved with facts because in the end there is a range of subjective opinion that can’t be changed with facts.

The Berkeley Meadow is a 72-acre native plant garden on a former garbage dump on landfill.
The Berkeley Meadow is a 72-acre native plant garden on a former garbage dump on landfill.

Secondly, we must accept that returning landscapes to prehistoric conditions is impossible.  Nature moves forward, not back.  Humans have fundamentally altered the environment and reversing those changes is not physically possible.  If we have unrealistic goals for conservation projects, we can expect failures.  When native plant gardens are installed on landfill that served as garbage dumps for decades (as they have been in the East Bay), we should not be surprised when they are unsuccessful.

Setting realistic goals

Ironically, the authors recommend larger projects rather than smaller projects.  Because ecosystems are integrated, attempts to change only a segment of an integrated system are doomed to fail.  The 1,100 acres of city-managed park land that have been designated as “natural areas” in San Francisco are chopped into 32 pieces, some as small as one-third of an acre.  When non-native plants are eradicated, these tiny plots are quickly repopulated with the same weeds from adjacent areas.  Sharp Park in Pacifica is the only “natural area” that may be capable of functioning as an ecosystem in the long-term because of its size and its relative physical isolation.

Letting the public decide

Finally, we must acknowledge that the alteration of our public lands is not a scientific decision.  It is a public policy decision.  In a democracy this means that the public must decide.  In the vast majority of cases, the public has not been given the opportunity to make the decision because the managers of our public lands have been making these decisions for us.  They do so by claiming that it is a scientific, not a public policy decision and that their expertise puts them in a position to impose their will on the public.  The authors of the book we are reviewing today challenge this claim:  “Yet in interventions conservation practice hides behind a veneer of pseudoscience and certainly challenges democratic processes.”  Hear, hear!!!  Thank you for this astute observation, which we see played out repeatedly in the San Francisco Bay Area.

The authors conclude with this advice to those who are responsible for ecological “restorations”:  “It is important to recognize the subjectivity of decision-making processes, and the cultural and historical origins of many of today’s problem species.”


(1)    Invasive & Introduced Plants and Animals:  Human Perspectives, Attitudes, and Approaches to Management, editors Ian Rotherham, Robert Lambert, Earthscan Publishing, London, Washington, DC, 2011.

When the cure is worse than the disease: Incompetent pesticide use

One of our readers sent us a link to an article about a “restoration” project gone awry in his neighborhood. Mount Baldhead is a city-owned park in Saugatuck, Michigan. US Fish & Wildlife funded a $700,000 federal grant to eradicate non-native plants on Mount Baldhead and several other municipal parks in the area. The grant was used to hire “certified applicators” to spray the non-native plants with imazapyr. Mount Baldhead was sprayed in summer 2010 and again in fall 2011. In spring 2012, the native oaks and maples, under which the non-native plants had grown and were sprayed, began to show signs of damage. Now a significant portion of the native forest is leafless and barren.

Mount Baldhead, Saugatuck, Michigan.  A clearer view of the damage is available in the article to which we provide a link.  We were denied permission to publish that picture.
Mount Baldhead, Saugatuck, Michigan. A clearer view of the damage is available in the article to which we provide a link above. We were denied permission to publish that picture.

The soil on Mount Baldhead is being studied to determine how far the pesticide has seeped into areas where it was not sprayed. This information may predict the extent of the eventual damage to the native forest. The ultimate fate of the trees that have been damaged is not known. There is no antidote to the pesticide. Will the trees survive? We don’t know yet.

What does it mean to be a “certified applicator” of pesticides?

This story is of interest to us because imazapyr is being widely used in the San Francisco Bay Area and its use has increased substantially in the past year.

Because imazapyr is being used heavily, we have read the manufacturer’s label for the formulated products (Habitat and Polaris) and the federally mandated Material Safety Data Sheet.

Therefore, we know that imazapyr should not be sprayed under trees you do not want to kill. This is a product that is mobile in the soil. It is capable of traveling from the roots of the plant on which it is sprayed into the roots of adjacent plants on which it has not been sprayed, killing or damaging plants that were not the intended targets of the spraying.

In December 2011, we witnessed imazapyr being used in San Francisco’s public parks for the first time. It was being sprayed on cape ivy under native willow trees. We doubt that the willows were the intended targets of the spraying since they are native. We wonder if the willows will survive in the long run.

These incidents make us ask what, if anything, it means to be a “certified applicator” of pesticides. Does the certification require the applicator to read the manufacturer’s label? If so, does the certification require the applicator to actually follow the directions on the manufacturer’s label? Clearly, this isn’t happening and there don’t seem to be any consequences for the “certified applicator” who kills plants and trees that he/she wasn’t hired to destroy. So, we conclude that such certification is meaningless.

The Million Trees mantra

Native plant advocates believe their projects benefit the environment. We do not see the benefit they claim. This is what we see:

• Increasing use of toxic pesticides is required to kill non-native vegetation. These pesticides are inherently hazardous and their incompetent use makes them even more hazardous.
• The wildlife that lives in our open spaces is being poisoned by these pesticides and they are losing their homes and their sources of food.
• The results of these projects do not justify these dangerous practices. The projects often look more dead than alive.

Our urban forest is under siege

The urban forest on Mt. Davidson is slated for destruction.

According to California Trees (1) the US Forest Service has determined that tree cover in the country’s urban areas is decreasing by 4 million trees a year.  Although no research has been done on tree loss throughout California, the US Forest Service reported a one-percent decline in trees and shrubs in Los Angeles despite a big campaign to plant one million trees there.

You might think that the loss of trees in urban areas is the result of increasing development and you would probably be at least partially correct.  But many trees are lost for more trivial reasons that we think could be easily prevented.  Here are some local examples of trees in the Bay Area that were needlessly destroyed or soon will be.

  • The City of Oakland has a “view ordinance” which guarantees homeowners the preservation of their view at the time they purchased their home.  This view ordinance was invoked by a resident in the Oakland hills who demanded that her neighbor and the City of Oakland destroy trees obstructing her view.  Her neighbor purchased her house because of its forested view.  Yet, the desire for a forested view was trumped by her neighbor’s desire for a treeless view.  The law required that 25 trees be destroyed on private property and 21 trees on city property in order to restore the view of a 95-year old property owner who no longer lives in her home.  When trees are destroyed for such trivial reasons, we should not be surprised by the following compendium of absurd excuses to destroy trees.  (The story is here.)
  • The people of San Francisco are trying to prevent the destruction of their urban forest which is almost entirely non-native.  The City of San Francisco is systematically destroying non-native trees in order to return the landscape to its historical origins as grassland and dune scrub.  The latest battle in this long war is a particular park, Glen Canyon, in which the City proposes to destroy about 160 trees in the short -run and 300 trees in the long-run.  A handful of the trees are hazardous and aren’t disputed, but most have been evaluated as “poor suitability” which is the latest euphemism used by native plant advocates to describe non-native trees.  They propose to replace most of the trees with native shrubs and a few tall trees that are native to California, but not to San Francisco, such as Douglas Fir and Cottonwoods.  It remains to be seen if either of these species will survive in San Francisco.  Douglas Fir requires more rainfall than San Francisco receives and Cottonwoods are hot-climate trees which don’t tolerate mild temperatures without seasonal fluctuations.  We suspect that is the strategy, i.e., to plant trees for the sole purpose of placating the public without any intention that the trees will survive.  (The story is here.)
  • The space shuttle Endeavor was recently retired from service.  Its permanent home is now a museum in Los Angeles, where 400 street trees were destroyed to accommodate the delivery of the space shuttle from the airport to the museum.  The neighbors were not pleased, as you might imagine.  They unfortunately live in a blighted part of Los Angeles, so they didn’t have the clout needed to save their trees.  Do you think these trees would have been destroyed in Beverly Hills?  We doubt it.  (The story is here.)
  • The neighbors of Dimond Park in Oakland are trying to save the trees in their park from being destroyed by a “restoration.”  We often marvel at the use of the word “restoration” to describe projects which are more accurately described as “destruction.”  This is yet another native plant project, which is hell bent to remake nature to its liking.  In this case 42 trees would be destroyed, of which 27 are native, including 17 redwood trees.  Please help the neighbors save their trees by signing their petition which is available here.
  • Finally, we share the story of a property owner on 65th St in Oakland who with a great deal of courage and tenacity was able to save most of the street trees on her block from being destroyed by the City of Oakland.  The trees weren’t posted as required by Oakland’s ordinance.  The crew who came to cut them down couldn’t tell her why they were being cut down, nor could they tell her who owned the trees.  We encourage you to read her story because it will give you a brief lesson on the difficulty of advocating against the needless destruction of trees.

Deforestation causes climate change

We have been accumulating these stories in the past few months, but are finally inspired to share them with our readers because of the recent storm on the East Coast, Sandy, which caused over $50 billion in damage and the lives of over 100 people.  What’s the connection?  The connection is that Sandy has finally forced people to take the threats of climate change more seriously. 

When will this new interest in climate change translate to an interest in saving our trees?   Probably not soon, because few people understand that globally, deforestation contributes 20% of greenhouse gases that cause climate change.  The public and its elected representatives are focused primarily on transportation as the source of climate change.  Transportation contributes only 10% of greenhouse gases globally. 

Here in California, we are gearing up to put our climate change law (AB 32) into action by creating a cap and trade auction which will enable emitters of greenhouse gases to purchase carbon offsets.  Ironically, one of the things that carbon emitters can do to offset their contribution to greenhouse gases is to plant trees.  Yet, those who destroy trees are not being required to purchase carbon offsets.  Until the people who destroy trees are required to pay for the damage they do to the environment, we are unlikely to see a change in the cavalier attitude that governments seem to have about destroying trees.   


(1)    California Trees, Winter 2012, Vol 20, no 2