Tag: Natural Areas Program

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

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

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

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

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

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

ROUNDUP or AQUAMASTER (Glyphosate)

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

  • heart breaking

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

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

GARLON (Triclopyr)

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

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

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

POLARIS, HABITAT (Imazapyr)

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

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

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

MILESTONE (Aminopyralid)

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

What?

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

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

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

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

PESTICIDE CONSPIRACY THEORIES

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

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

It doesn’t want to go.

WHY NATURAL AREAS FIGHT BACK

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

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

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

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

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

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

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

Professor Arthur Shapiro’s comment on the Environmental Impact Report for the Natural Areas Program

Mission blue butterfly Wikimedia Commons

With permission and in its entirety we are publishing the comment of Arthur M. Shapiro.  He is Distinguished Professor of Evolution and Ecology at UC Davis and a renowned expert on the butterflies of California.  We hope that you will take his credentials into consideration as you read his opinion of native plant restorations in general and the Natural Areas Program in San Francisco in particular.  We hope that Professor Shapiro’s comment will inspire you to write your own comment by the deadline,  which has been extended to October 31, 2011.  Details about how to submit your comment are available here.

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October 6, 2011

Mr. Bill Wycko

San Francisco Planning Department

                              Re: DRAFT EIR, NATURAL AREAS PROGRAM

Dear Mr. Wycko:

Consistent with the policy of the University of California, I wish to state at the outset that the opinions stated in this letter are my own and should not be construed as being those of the Regents, the University of California, or any administrative entity thereof. My affiliation is presented for purposes of identification only. However, my academic qualifications are relevant to what I am about to say. I am a professional ecologist (B.A. University of Pennsylvania, Ph.D. Cornell University) and have been on the faculty of U.C. Davis since 1971, where I have taught General Ecology, Evolutionary Ecology, Community Ecology, Philosophy of Biology, Biogeography, Tropical Ecology, Paleoecology, Global Change, Chemical Ecology, and Principles of Systematics. I have trained some 15 Ph.D.s, many of whom are now tenured faculty at institutions including the University of Massachusetts, University of Tennessee, University of Nevada-Reno, Texas State University, and Long Beach State University, and some of whom are now in government agencies or in private consulting or industry. I am an or the author of some 350 scientific publications and reviews. The point is that I do have the bona fides to say what I am about to say.

 At a time when public funds are exceedingly scarce and strict prioritization is mandatory, I am frankly appalled that San Francisco is considering major expenditures directed toward so-called “restoration ecology.” “Restoration ecology” is a euphemism for a kind of gardening informed by an almost cultish veneration of the “native” and abhorrence of the naturalized, which is commonly characterized as “invasive.” Let me make this clear: neither “restoration” nor conservation can be mandated by science—only informed by it. The decision of what actions to take may be motivated by many things, including politics, esthetics, economics and even religion, but it cannot be science-driven.

In the case of “restoration ecology,” the goal is the creation of a simulacrum of what is believed to have been present at some (essentially arbitrary) point in the past. I say a simulacrum, because almost always there are no studies of what was actually there from a functional standpoint; usually there are no studies at all beyond the merely (and superficially) descriptive. Whatever the reason for desiring to create such a simulacrum, it must be recognized that it is just as much a garden as any home rock garden and will almost never be capable of being self-sustaining without constant maintenance; it is not going to be a “natural,” self-regulating ecosystem. The reason for that is that the ground rules today are not those that obtained when the prototype is thought to have existed. The context has changed; the climate has changed; the pool of potential colonizing species has changed, often drastically. Attempts to “restore” prairie in the upper Midwest in the face of European Blackthorn invasion have proven Sisyphean. And they are the norm, not the exception.

The creation of small, easily managed, and educational simulacra of presumed pre-European vegetation on San Francisco public lands is a thoroughly worthwhile and, to me, desirable project. Wholesale habitat conversion is not.

A significant reaction against the excesses of the “native plant movement” is setting up within the profession of ecology, and there has been a recent spate of articles arguing that hostility to “invasives” has gone too far—that many exotic species are providing valuable ecological services and that, as in cases I have studied and published on, in the altered context of our so-called “Anthropocene Epoch” such services are not merely valuable but essential. This is a letter, not a monograph, but I would be glad to expand on this point if asked to do so.

I am an evolutionary ecologist, housed in a Department of Evolution and Ecology. The two should be joined at the proverbial hip. Existing ecological communities are freeze-frames from a very long movie. They have not existed for eternity, and many have existed only a few thousand years. There is nothing intrinsically sacred about interspecific associations. Ecological change is the norm, not the exception. Species and communities come and go. The ideology (or is it faith?) that informs “restoration ecology” basically seeks to deny evolution and prohibit change. But change will happen in any case, and it is foolish to squander scarce resources in pursuit of what are ideological, not scientific, goals with no practical benefit to anyone and only psychological “benefits” to their adherents.

If that were the only argument, perhaps it could be rebutted effectively. But the proposed wholesale habitat conversion advocated here does serious harm, both locally (in terms of community enjoyment of public resources) and globally (in terms of carbon balance-urban forests sequester lots of carbon; artificial grasslands do not). At both levels, wholesale tree removal, except for reasons of public safety, is sheer folly. Aging, decrepit, unstable Monterey Pines and Monterey Cypresses are unquestionably a potential hazard. Removing them for that reason is a very different matter from removing them to actualize someone’s dream of a pristine San Francisco (that probably never existed).

Sociologists and social psychologists talk about the “idealization of the underclass,” the “noble savage” concept, and other terms referring to the guilt-driven self-hatred that infects many members of society. Feeling the moral onus of consumption and luxury, people idolize that which they conceive as pure and untainted. That may be a helpful personal catharsis. It is not a basis for public policy.

Many years ago I co-hosted John Harper, a distinguished British plant ecologist, on his visit to Davis. We took him on a field trip up I-80. On the way up several students began apologizing for the extent to which the Valley and foothill landscapes were dominated by naturalized exotic weeds, mainly Mediterranean annual grasses. Finally Harper couldn’t take it any more. “Why do you insist on treating this as a calamity, rather than a vast evolutionary opportunity?” he asked. Those of us who know the detailed history of vegetation for the past few million years—particularly since the end of Pleistocene glaciation—understand this. “Restoration ecology” is plowing the sea.

Get real.

                                    Sincerely,

                                     Arthur M. Shapiro

                                     Distinguished Professor of Evolution and Ecology

Professor Arthur M. Shapiro, at work, UC Davis

Fabricating “facts” to support native plant restorations.

We have been debating with native plant advocates for a long time, so we’re never surprised when they repeat vague generalities to support their ideology.  But when these fabricated “facts” are repeated in legal documents such as the Draft Environmental Impact Report (EIR) for the Natural Areas Program (NAP) we must admit that we’re shocked!  Apparently, the highly paid professionals who write such documents don’t expect the public to actually read the references they cite to support the statements they fabricate.  We will take our readers on a tour of some of the phony “science” used to defend the destruction of San Francisco’s urban forest in order to restore native grassland and scrub to San Francisco’s urban parks.

Why is carbon storage such an issue in this debate about the Natural Areas Program?

The urban forest of San Francisco stores 196,000 tons of carbon and adds to that accumulated store of carbon at an annual rate of 5,200 tons per year according to the US Forest Service survey.  About 25% of the annual rate of sequestration and the accumulated storage of carbon are accomplished by the blue gum eucalyptus, the chief target for destruction by NAP’s plans.  When a tree is destroyed, it releases the carbon that has accumulated throughout its lifetime into the atmosphere as Carbon Dioxide as it decays.  Carbon Dioxide is the predominant greenhouse gas that is causing climate change. 

Carbon storage by tree species, San Francisco. US Forest Service

Since greenhouse gases are regulated in California by a law that commits the state to reduce greenhouse gas emissions, the Environmental Impact Report (EIR) for the Natural Areas Program (NAP) goes to great lengths to make the case that destroying thousands of trees will not violate California law.  Here are just a few of the “facts” fabricated by the EIR to convince the public that NAP’s plans to convert San Francisco’s urban forest into grassland and scrub will not harm the environment.   

Grassland in the San Francisco Bay Area does NOT lower ground temperature

The EIR claims:

“According to a study presented at the American Geophysical Union’s meeting, grasslands above 50 degrees latitude reflect more sun than forest canopies, thereby keeping temperatures lower by an average of 0.8 degree Celsuis.” ( EIR, page 457, cited source(1))

This statement in the EIR does not apply to the San Francisco Bay Area and the reference used to support it misrepresents the cited study:

  • The entire continental United States, including the San Francisco Bay Area, is below 50 degrees latitude.  In other words, this statement—even if it were true—does not apply to the San Francisco Bay Area.
  • The statement is taken out of the context of the article.  The entire sentence in which this statement appears actually says, “Grassland or snowfields, however, reflected more sun, keeping temperatures lower.  Planting trees above 50 degrees latitude, such as in Siberia, could cover tundras normally blanketed in heat-reflecting snow.”  It does not snow in the San Francisco Bay Area.  Therefore, this statement does not apply to the San Francisco Bay Area.
  • The article being quoted by the EIR is NOT the scientific study, but rather a journalistic article in The Guardian, a newspaper in England, in which the author of the study has been misquoted and his study misrepresented.
  • The day after this article appeared in The Guardian (and also in the New York Times), The Guardian published an op-ed (which also appeared in the New York Times) by the author of the scientific study, Ken Caldeira  in which he objected to the misrepresentation of his study:

“I was aghast to see our study reported under the headline “Planting trees to save planet is pointless, say ecologists.” (December 15).  Indeed, our study found that preserving and restoring tropical forests is doubly important, as they cool the earth both by removing the greenhouse gas carbon dioxide from the atmosphere and by helping produce cooling clouds.  We did find that preserving and restoring forests outside the tropics does little or nothing to help slow climate change, but nevertheless these forests are a critical component of Earth’s biosphere and great urgency should be placed on preserving them.”(2) (emphasis added)

As if this misrepresentation of the facts weren’t bad enough, we find in Appendix A of the EIR that this isn’t the first time that someone has informed the authors of the EIR that this statement is not accurate.  One of the public comments submitted in 2009 in response to the Initial Study quotes Ken Caldeira’s op-ed in the New York Times.  Yet, two years later, the author of the EIR persists in repeating this misrepresentation of Professor Caldeira’s (Stanford University) research.  One wonders if the public comments were even read, judging by the repetition of the pseudoscience in the Initial Study that the public commented on in the first round.  It seems that the “public process” is merely going through the motions.

Grassland does NOT store more carbon than forests

The EIR also claims:

“Research studies have concluded that grassland and scrub habitat could act as a significant carbon sink.” (page 457, cited studies(3))

Once again, the cited study does not support the statement in the EIR:

  • Again, the statement has been taken out of context.  The entire sentence reads, “We conclude that grasslands can act as a significant carbon sink with the implementation of improved management.”  This sentence appears in the abstract for the publication.(4)
  • One wonders if the authors of the EIR read the entire article or just the abstract.  The point of the study is that land management techniques such as fertilization, irrigation, introduction of earthworms, plowing and fallow techniques, etc., can improve the sequestration of carbon in the soil of croplands and pastures.  This study is obviously irrelevant to the Natural Areas Program, which is not engaged in agriculture or pasturage and will not use any of these techniques. 
  • However, the study is relevant in one regard.  It reports that when forest is converted to grassland, no amount of “management techniques”  compensates for the loss of the carbon in the trees that are destroyed:

“Though more than half of the rain forest conversion studies (60%) resulted in increased soil Carbon content, net ecosystem Carbon balance…decreased substantially due to the loss of large amounts of biomass carbon.” 

The second study cited in support of the claim about carbon storage in grassland reports that increased levels of Carbon Dioxide in the air increases carbon accumulation in the soil.  This study tells us nothing about the relative merits of grassland and forests with respect to carbon storage.  Another study reports a similar relationship between global warming and carbon storage in trees:  “…warmer temperatures stimulate the gain of carbon stored in trees as woody tissue, partially offsetting the soil carbon loss to the atmosphere.” (5)

A pointless debate that misses the point

The misuse of these studies illustrates one of the fundamental issues with this pointless debate about the relative merits of grassland and forests.  Even if grassland were superior to forests with respect to carbon storage—and it’s NOT—it would never compensate for the loss of carbon associated with destroying a forest that is storing hundreds of thousands of tons of carbon.  The merits of planting trees where none presently exist is a fundamentally different argument than the merits of destroying trees.  The trees are here now.  No amount of grassland will compensate for the loss of the carbon presently stored by the forest that native plant advocates demand be destroyed.

If there is a sound argument for destroying trees, this isn’t it.  Grassland does not store more carbon than trees and will never compensate for the loss of the tons of carbon released into the atmosphere when trees are destroyed. (Please visit our post “Facts about carbon storage do not support assumptions of native plant advocates”)  Native plant advocates would be wise to abandon this particular line of unreasoning. 

Although we are not scientists, we read the work of scientists.  The studies conducted by scientists are not theoretical speculations about the benefits of one plant compared to another.  Rather they report the results of controlled experiments, such as actually measuring the amount of carbon in the plant and/or soil and reporting the results of those experiments.  Native plant advocates would be wise to spend less time trading baseless generalizations amongst themselves and spend more time reading the scientific reports of actual evidence. 

Please comment on the Draft Environmental Impact Report for the Natural Areas Program

Please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks.  There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*.  Here are the details about the public’s opportunities to comment on the EIR for the Natural Areas Program:

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

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

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

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

(1) Jha, Alok.  The Guardian.  “Planting Trees to Save Planet is Pointless, Say Ecologists.”  Friday, December 15, 2006.

(2) Caldeira, Ken, “Planting trees is far from pointless.” The Guardian, December 16, 2006.

(3) Conant, L., Paustian K, and Elliot E. 2001. “Grassland Management and Conversion into Grassland Effects on Soil Carbon.”  Natural Resource Ecology Laboratory.  Colorado State University. Fort Collins, USA.  Sponsor:  US Environmental Protection Agency, Ruminant Livestock Efficiency Program.  2001, and

Hu, S., Chapin, Firestone, Field, Chiariello.  2001.  “Nitrogen limitation of microbial decomposition in a grassland under elevated C02,” Nature 409:  188-191. 

(4) Conant, Paustian, Elliott, “Grassland Management and Conversion into Grassland Effects on Soil Carbon,”  Ecological Applications, 11 (2) 2001, 341-355.

(5) Melillo, J., Butler, S., Johnson, J., Mohan, J., Steudler, P., Lux, H., Burrows, E., Bowles, F., Smith, R., Scott, L., Vario, C., Hill, T., Burton, A., Zhouj, Y, and Tang, J. Soil warming carbon-nitrogen interactions and carbon-nitrogen budgets. PNAS, May 23, 2011

 

Environmental Impact Report for the Natural Areas Program is based on a HUGE mistake!

There is a HUGE mistake in the Environmental Impact Report (EIR) for the Natural Areas Program (NAP), which will fundamentally alter the public’s perception of the EIR.

The EIR says on page 2 in the Summary that the “Maximum Restoration Alternative” is the “Environmentally Superior Alternative.”  The statement on page 2 is WRONG!  The “Maintenance Alternative” is the “Environmentally Superior Alternative,” as explained on page 525-526 of the EIR.

When we first informed our readers of the publication of the Environmental Impact Report (EIR) for the Natural Areas Program (NAP) on September 9, 2011, we also announced that the EIR considers the “Maximum Restoration Alternative” the “Environmentally Superior Alternative.”  The “Maximum Restoration Alternative” proposes an aggressive expansion of the NAP that will destroy more trees, require more herbicide use, close more trails and other recreational access, and permit NAP to plant more legally protected species that could require more restrictions in the future.   When we announced this proposed expansion of the program, we were reporting what the EIR says on page 2 in the Summary of the EIR. 

So, we repeat, the statement on page 2 is wrong.  The “Maximum Restoration Alternative” is NOT the “Environmentally Superior Alternative.”  The “Environmentally Superior Alternative” is the “Maintenance Alternative.”  The correct statement does not appear in the EIR until the very end of the document:

“The Maximum Recreation and Maintenance Alternatives are the environmentally superior alternatives because they have fewer unmitigated significant impacts than either the proposed project or the Maximum Restoration Alternative. Between the Maximum Recreation Alternative and the Maintenance Alternative, the Maintenance Alternative would be the environmentally superior alternative for two reasons. While the two alternatives have the same number of significant and unavoidable impacts under CEQA, the Maintenance Alternative has fewer potential environmental effects than the Maximum Recreation Alternative. First, the Maintenance Alternative would not create new trails, the construction of which could result in impacts to sensitive habitats and other biological resources. Second, over time the Maximum Recreation Alternative would result in Natural Areas with less native plant and animal habitat and a greater amount of nonnative urban forest coverage. The Maintenance Alternative, on the other hand, would preserve the existing distribution and extent of biological resources, including sensitive habitats. For these reasons, the Maintenance Alternative is the environmentally superior alternative.” (EIR, page 525-526) (emphasis added)

The contradiction between what appears on page 2 of the EIR and page 526 was pointed out to the staff of the Planning Department responsible for managing the public comment period and certification of the EIR.  That staff member confirmed that the statement on page 2 is wrong and the statement on page 526 is correct.  However, she refused to correct the error until the public comment period is over and the Final Environmental Impact Report is published.

Unfortunately, this mistake and the refusal to correct it before the public comment period is complete will jeopardize the fairness of the process.  Native plant advocates are already recruiting their speakers for the public hearing by the Planning Commission on October 6, 2011, and the written comments which are due on October 17, 2011*.  They are urging their supporters to advocate for the “Maximum Restoration Alternative” and they are incorrectly informing them that this is the “Environmentally Superior Alternative.”  We have no reason to believe that they are aware of the mistake on page 2 of the EIR.  They are probably sincere in their belief that the “Maximum Restoration Alternative” is the “Environmentally Superior Alternative.”  Few readers are likely to read the entire EIR and will therefore be unaware of the mistake on page 2.

This mistake will mislead the public into supporting the “Maximum Restoration Alternative” that expands the destructive and restrictive aspects of the Natural Areas Program.  Furthermore, and perhaps more importantly, this expansion is NOT legal because it violates the requirements of the California Environmental Quality Act (CEQA), which requires that the “Environmentally Superior Alternative” have the least negative impact on the environment of all proposed alternatives:

“§21002.  APPROVAL OF PROJECTS; FEASIBLE ALTERNATIVE OR MITIGATION MEASURES

The Legislature finds and declares that it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would  substantially lessen the significant environmental effects of such projects,  and that the procedures required by this division are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.”  CEQA Guidelines, page 2 (emphasis added)

Pardon our paranoia….

 This is a huge mistake which could profoundly prejudice the public to support the “Maximum Restoration Alternative” which proposes an expansion of the Natural Areas Program.  We ask these rhetorical questions:

  •  Who wrote page 2 of the EIR, which incorrectly identifies the “Maximum Restoration Alternative” as the “Environmentally Superior Alternative” and why?
  • Why does the Planning Department refuse to correct this error before the public comment is complete?

If you attend the public hearing on October 6, 2011, please inform the Planning Commission of this error and write by the deadline of October 17, 2011*, in support of the “Maintenance Alternative” which will do less damage to the environment than the proposed project and the other proposed alternatives.  Here are the details about the opportunities for public comment:

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

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

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

The Healthy Trees of San Francisco

The San Francisco Natural Areas Program (NAP) plans to destroy thousands of healthy trees in San Francisco’s parks.  The Draft Environmental Impact Review (EIR) for NAP’s destructive plan reaches the bizarre conclusion that removing thousands of trees will have no significant impact on the environment.   This conclusion is based on several fictional premises.  In a previous post we examined the fictional claim that all the trees that will be removed will be replaced within the natural areas by an equal number of trees that are native to San Francisco.  In this post we will examine another of the fictional premises:  that only dead, dying, hazardous, or unhealthy trees will be removed.

We have many reasons to challenge the truth of the claim that only dead, dying, hazardous or unhealthy trees will be removed:

  • The management plan for the Natural Areas Program tells us that young non-native trees under 15 feet tall will be removed from the natural areas.  By definition these young trees are not dead or unhealthy because they are young and actively growing.
  • The management plan has not selected only dead, dying, hazardous trees for removal.  Trees have been selected for removal only in so far as they support the goal of expanding and enhancing areas of native plants, especially grasslands and scrub.
  • The predominant non-native tree in San Francisco, Blue Gum eucalyptus lives in Australia from 200-400 years, depending upon the climate.(1)  In milder climates, such as San Francisco, the Blue Gum lives toward the longer end of this range. 
  • However, there are many natural predators in Australia that were not imported to California. It is possible that the eucalypts will live longer here:  “Once established elsewhere, some species of eucalypts are capable of adjusting to a broader range of soil, water, and slope conditions than in Australia…once released from inter-specific competitions and from native insect fauna…”(2)
  • The San Francisco Presidio’s Vegetation Management Plan reports that eucalypts in the Presidio are about 100 years old and they are expected to live much longer: “blue gum eucalyptus can continue to live much longer…”(3)
  • The Natural Areas Program has already destroyed hundreds of non-native trees in the past 15 years.  We can see with our own eyes, that these trees were not unhealthy when they were destroyed.

How have mature trees been selected for removal?

The EIR wants us to believe that only dead, dying, hazardous trees will be removed from the natural areas.  This claim is contradicted by the management plan that the EIR is claiming to evaluate.  Not a single explanation in the management plan for why specific trees over 15 feet tall have been selected for removal is based on the health of the trees.  Trees less than 15 feet tall will also be removed, but are not counted by the management plan.

  • Lake Merced:  The explanation for removing 134 trees is “To maintain and enhance native habitats, it is necessary to selectively remove some trees.”
  • Mt. Davidson:  The explanation for removing 1,600 trees is: “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-grassland ecotone, invasive blue gum eucalyptus trees will be removed in select areas. Coastal scrub and reed grass communities require additional light to reach the forest floor in order to persist “
  • Glen Canyon:  The explanations for removing 120 trees are:  “to help protect and preserve the native grassland” and “to increase light penetration to the forest floor”
  • Bayview Hill:  The explanation for removing 505 trees is:  “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-grassland ecotone, invasive blue gum eucalyptus trees will be removed in select areas.”
  • McLaren:  The explanation for removing 805 trees is:  “In order to enhance the sensitive species habitat that persists in the urban forest understory and at the forest-scrub-grassland ecotone, invasive trees will be removed in select areas. Coastal scrub and grassland communities require additional light to reach the forest floor in order to persist.”
  • Interior Greenbelt:  The explanation for removing 140 trees is:  “In order to enhance the seasonal creek and sensitive species habitat that persists in the urban forest understory, invasive blue gum eucalyptus trees will be removed in select areas.”
  • Dorothy Erskine:  The explanation for removing 14 trees is:  “In order to enhance the grassland and wildflower community, removal of some eucalyptus trees is necessary.”

In not a single case does the management plan for the Natural Areas Program corroborate the claim made in the EIR that only dead, dying, diseased, or hazardous trees will be removed.  In every case, the explanation for the removal of eucalypts is that their removal will benefit native plants, specifically grassland and scrub.  The author of the EIR has apparently not read the management plan or has willfully misrepresented it. 

The track record of tree removals in the natural areas

Although it’s interesting and instructive to turn to the written word in the management plan for the Natural Areas Program to prove that the EIR is based on fictional premises, the strongest evidence is the track record of tree removals in the past 15 years.  As always and in every situation, actions speak louder than words.

Hundreds of trees have been removed in the natural areas since the Natural Areas Program began 15 years ago.  We’ll visit a few of those areas with photographs of those tree removals to prove that healthy, young non-native trees have been destroyed.  This track record predicts the future:  more healthy young trees will be destroyed in the future for the same reason that healthy young trees were destroyed in the past, i.e., because their mere existence is perceived as being a barrier to the restoration of native grassland and scrub.

Girdled trees, Bayview Hill, 2010
  • The first tree destruction by the Natural Areas Program and its supporters took the form of girdling about 1,000 healthy trees in the natural areas about 10 to 15 years ago.  Girdling a tree prevents water and nutrients from traveling from the roots of the tree to its canopy.  The tree dies slowly over time.  The larger the tree, the longer it takes to die.  None of these trees were dead when they were girdled.  There is no point in girdling a dead tree.

    One of about 50 girdled trees on Mt. Davidson, 2003
  • Many smaller trees that were more easily cut down without heavy equipment were simply destroyed, sometimes leaving ugly stumps several feet off the ground.

    Bayview Hill, 2002
  • About 25 young trees were destroyed on Tank Hill about 10 years ago.  The neighbors report that they were healthy trees with trunks between 6″ to 24″ in diameter and therefore fairly young trees.  The trees that remain don’t look particularly healthy in the picture because they were severely limbed up to bring more light to the native plant garden for which the neighboring trees were destroyed.  The neighbors objected to the removal of the trees that remain.  The Recreation and Park Department agreed to leave them until they were replaced by native trees.  Only 4 of the more than two dozen live oaks that were planted as replacements have survived.  They are now about 36″ tall and their trunks are about 1″ in diameter. 

    Tank Hill, 2002
  • About 25 young trees were destroyed in 2004 at the west end of Pine Lake to create a native plant garden that is now a barren, weedy mess surrounded by the stumps of the young trees that were destroyed.

    Pine Lake "Natural Area" 2011
  • About 25 trees of medium size were destroyed at the southern end of Islais Creek in Glen Canyon Park about 6 years ago in order to create a native plant garden. 
  • Many young trees were recently destroyed in the natural area called the Interior Greenbelt.  These trees were destroyed in connection with the development of a trail, which has recently become the means by which the Natural Areas Program has funded tree removals with capital funding.

    Interior Greenbelt Natural Area, 2010. Courtesy SaveSutro

There was nothing wrong with any of these trees before they were destroyed.  Their only crime was that they were not native to San Francisco.  There are probably many other trees that were destroyed in the natural areas in the past 15 years.  We are reporting only those removals of which we have personal knowledge.

If you care about the trees of San Francisco….

If you care about the trees of San Francisco, please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks.  There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*.  Details about how to comment are available here.

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

(1) Jacobs, Growth Habits of the Eucalyptus, 1955, page 67

(2) Doughty,  The Eucalyptus, 2000, page 6

(3) San Francisco Presidio’s Vegetation Management Plan, page 28

Destroying the Trees of San Francisco

The San Francisco Natural Areas Program (NAP) plans to destroy thousands of trees in San Francisco’s parks.  The Draft Environmental Impact Report (EIR) for NAP’s destructive plan reaches the bizarre conclusion that removing thousands of trees will have no significant impact on the environment.   This conclusion is based on several fictional premises.  In this post we will examine one of those premises:   that all the trees that are removed will be replaced within the natural areas by an equal number of trees that are native to San Francisco.

The EIR supports this fictional premise by falsely reducing the number of trees that will be removed by:

  • Not counting trees less than 15 feet tall, despite the fact that the US Forest Service survey of San Francisco’s urban forest reports that the trunks of most (51.4%) trees in San Francisco are less than 6 inches in diameter at breast height, the functional equivalent of trees less than 15 feet tall.
  • Not counting the hundreds of trees that were destroyed prior to the approval of the NAP management plan at Pine Lake, Lake Merced, Bayview Hill, Glen Canyon parks, etc.
  • Not counting tree removals proposed by the “Maximum Restoration Alternative” which the EIR says is the “Environmentally Superior Alternative.” [ETA: The Planning Department later admitted that this is a mistake in the EIR.  The “Maintenance Alternative” is the “Enviromentally Superior Alterantive.”]

However, even artificially reducing the number of tree removals does not make “one-to-one” replacement a realistic goal.

The natural history of trees in San Francisco

The primary reason why we know that it will not be possible to grow thousands more native trees in the natural areas in San Francisco is that there were few native trees in San Francisco before non-native trees were planted by European settlers in the late 19th century.  San Francisco’s “Urban Forest Plan” which was officially adopted by the Urban Forestry Council in 2006 and approved by the Board of Supervisors describes the origins of San Francisco’s urban forest as follows:

“No forest existed prior to the European settlement of the city and the photographs and written records from that time illustrate a lack of trees…Towards the Pacific Ocean, one saw vast dunes of sand, moving under the constant wind.  While there were oaks and willows along creeks, San Francisco’s urban forest had little or nothing in the way of native tree resources.  The City’s urban forest arose from a brief but intense period of afforestation, which created forests on sand without tree cover.”

San Francisco in 1806 as depicted by artist with von Langsdorff expedition. Bancroft Library

The horticultural reality of trees native to San Francisco

More importantly, the reality is that even if we want to plant more native trees in San Francisco, they will not grow in most places in San Francisco.  We know that for several reasons: 

  • There are few native trees in San Francisco now.  According to the US Forest Service survey of San Francisco’s urban forest only two species of tree native to San Francisco were found in sufficient numbers to be counted in the 194 plots they surveyed:  Coast live oak was reported as .1% (one-tenth of one percent) and California bay laurel 2.1% of the total tree population of 669,000 trees.
  • The city of San Francisco maintains an official list of recommended species of trees for use by the Friends of the Urban Forest and the Department of Public Works.  The most recent list categorizes 27 species of trees as “Species that perform well in many locations in San Francisco.”  There is not a single native tree in that category.  Thirty-six tree species are categorized as “Species that perform well in certain locations with special considerations as noted.”  Only one of these 36 species is native to San Francisco, the Coast live oak and its “special considerations” are described as “uneven performer, prefers heat, wind protection, good drainage.”  The third category is “Species that need further evaluation.”  Only one (Holly leaf cherry) of the 22 species in that category is native to San Francisco. 
  • Finally, where native trees have been planted by NAP to placate neighbors who objected to the removal of the trees in their neighborhood parks, the trees did not survive.

Will NAP plant trees that won’t survive?

Given what we know about the horticultural requirements of the trees that are native to San Francisco, what are we to think of the claim that all non-native trees removed by the Natural Areas Program will be replaced by native trees?  Is there any truth to this claim?  Will native trees be planted that won’t survive?  Or will they just not plant the trees that they claim will be planted?

We turn to the management plan for the Natural Areas Program for the answer to this question.  In fact, the management plan proves that NAP has no intention of planting replacement trees for the thousands of trees they intend to destroy.  The “Urban Forestry Statements” in Appendix F of the management plan contain the long-term plans for the natural areas in which trees will be destroyed.  All but one of these specific plans is some variation of “conversion of some areas of forest to scrub and grasslands.”  The exception is Corona Heights for which the plans are “converted gradually to oak woodland.”  The Corona Heights natural area is 2.4 acres, making it physically impossible to plant thousands of oaks in that location.

NAP plans to destroy 1,600 trees over 15 feet tall on Mt. Davidson and more if the EIR is approved.

  

Putting the magnitude of the proposed tree removals into perspective

It isn’t easy to confront public policies.  We all have better things to do.  So, before we leave this issue, let’s consider the magnitude of the loss of thousands of trees in San Francisco.  We turn to the survey of San Francisco’s urban forest by the US Forest Service to put the proposed tree removals into perspective:

  • There are only 669,000 trees in San Francisco, with a tree cover of only 11.9% of the land.  Of the 14 cities in the US reported by this survey, only Newark, New Jersey has a smaller tree canopy, covering 11.5% of the land.
  • Most of these trees are small:  51.4% have trunk diameters of less than 6” at breast height.
  • The highest densities of trees are found in San Francisco’s open spaces, such as parks.
  • The trees and shrubs of San Francisco remove 260 tons of air pollutants (CO, NO₂ , O₃, PM₁₀, SO₂) per year
  • The trees of San Francisco now store 196,000 tons of carbon.  Stored carbon is released into the atmosphere when trees are destroyed and as they decay as chips or logs on the ground.
  • In San Francisco, the blue gum eucalyptus stores and sequesters the most carbon (approximately 24.4% of the total accumulated carbon stored and 26.4% of annual rate of carbon sequestered).  Most of the trees that have been destroyed in the past and will be destroyed in the future by NAP are blue gum eucalyptus. 

If you care about the trees of San Francisco, please keep in mind that the public will have an opportunity to comment on the proposal to remove thousands of trees in the city’s parks.  There will be a public hearing on October 6, 2011, and the deadline for submitting a written comment is October 17, 2011*.  Details about how to comment are available here.

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

Environmental Impact Report of Natural Areas Program proposes aggressive expansion

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

The Management Plan for the Natural Areas Program

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

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

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

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

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

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

The Environmental Impact Report of the Natural Areas Program

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

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

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

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

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

The other alternatives identified in the EIR are:

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

Rewarding Failure

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

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

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

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

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

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

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

Public Comment Opportunities

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

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

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

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

———————————

*Type in search box:  Natural Areas Program management plan

Concern about herbicide use: Legitimate or “chemophobia”?

Recently there was a brief dialogue about herbicide use in San Francisco’s so-called “natural areas” in Jake Sigg’s Nature News that was of some interest to those who consider such use a contradiction in a public park designated as a “natural area”:

  •  Jake Sigg:  “Spurious, damaging information being circulated regarding herbicide use in our open spaces:  Mischievous people…are circulating false information…whipping up fears that have no foundation”  (Nature News, February 14, 2011)
  • Reader:  “…Garlon is legally classified as a hazardous chemical.  I am therefore writing to supply you with information from reputable sources.  I ask that in your future communications on this subject, you accurately describe the facts that are known about this chemical.” (Nature News, February 18, 2011)
  • Jake Sigg:  “The chemophobia rampant in this country is primarily based on emotion and anxiety, and does us a great disservice.” (Nature News, February 18, 2011)
  • Jake Sigg:  “The anti-herbicide crazies quickly seize on articles like this NYT one as proof of their contentions…” (Nature News, March 30, 2011)

This dialogue and the positive feedback that Mr. Sigg reported from his readers in support of herbicide use, suggest that herbicides are an important tool for the native plant movement.  They are anxious not to lose this tool in their crusade to eradicate non-native plants and trees.  After researching how much herbicide is being used by the Natural Areas Program, we can understand why they angrily defend its use.

Herbicide use by San Francisco’s Natural Areas Program

The Natural Areas Program (NAP) reports having used herbicides 69 times in 2010:  36 applications of Garlon, 31 applications of Roundup, and 2 applications of Milestone.  Putting those numbers into perspective, other areas (those not designated as “natural areas”) in the Recreation and Park Department sprayed Garlon, the most hazardous chemical, only a few times in 2010.

About 20% of these herbicide applications were done by a contractor who was paid $9,000 per application.  The employees of this contractor are therefore equally committed to this source of revenue, contributing to the economic interest that is a motivating factor in the native plant movement.

Not all of the “targets” of these sprayings are identified, but those that are include:  oxalis, blackberry, ivy, fennel, cotoneaster, hemlock, pampas grass, broom, erharta grass, mustard, and thistle.  Blackberry is an important source of food for wildlife in the city. We hope that children in the park do not graze on the blackberries.  Garlon was also sprayed on Scabiosa, which has not been identified as an “invasive plant” by the California Invasive Plant Council.

Glen Canyon, with a creek running through it and a year-around day care center adjacent to that creek, was sprayed 12 times.  Twin Peaks, the watershed to that creek, was sprayed 16 times.  Lake Merced was sprayed 3 times, despite the fact that it has been officially designated as red-legged frog habitat.

What is known about these chemicals?

The City’s policy regarding “Integrated Pest Management” classifies the chemicals used on city properties in terms of the risks associated with their use.  Here is how the City’s policy classifies these chemicals: 

  • Garlon:  Tier I, Most Hazardous.  Use Limitations:  “Use only for targeted treatments of high profile or highly invasive exotics via dabbing or injections.  May use for targeted spraying only when dabbing or injection are not feasible and only with use of a respirator.  HIGH PRIORITY TO FIND ALTERNATIVE.”
  • Roundup:  Tier II, Less Hazardous.  Use Limitations:  “Spot application of areas inaccessible or too dangerous for hand methods, right of ways, utility access, or fire prevention.  Use for cracks in hardscape, decomposed granite and edging only as last resort.  OK for renovations but must put in place weed prevention measures.  Note prohibition on use within buffer zone 60 feet around water bodies in red-legged frog habitat.”
  • Milestone:  Tier I, Most Hazardous

    Spraying Garlon on Twin Peaks without use of the respirator required by City policy, February 2011

Federal law also requires that chemicals be evaluated by the Environmental Protection Agency (EPA) before being commercially available to consumers.  The EPA conducts a number of tests of toxicity, reports the results of those tests on a mandated Material Safety Data Sheet (MSDS), and classifies the chemical with respect to its relative toxicity.  Here are a few highlights from the MSDS for these chemicals:

  • Garlon 4 Ultra is defined as a “Hazardous Chemical” according to the OSHA Hazard Communication Standard.  “Material is highly toxic to aquatic species” and “slightly toxic to birds.”
  •  Roundup Pro is defined as a “Hazardous Chemical” according to the OSHA Hazard Communication Standard. Toxicological effects in rats:  “decrease in body weight gain; histopathologic effects.”  “Moderately toxic” to aquatic life.

The Marin Municipal Water District (MMWD) quit using all herbicides in 2005 in response to the public’s protests.  They have been engaged in a process of evaluating herbicides for possible use in the future.  In 2008, MMWD contracted for a risk assessment of 5 herbicides they were considering for possible use.  That risk assessment determined that Garlon 4 Ultra is the most hazardous of the 5 chemicals that were evaluated.    MMWD is not considering the use of Garlon in the future. 

Does NAP’s herbicide use conform to the City’s Integrated Pest Management Law?

 San Francisco’s Integrated Pest Management Ordinance makes the following commitments regarding pesticide use on the city’s properties:

  • 300a “…the policy of the City..to eliminate or reduce pesticide applications on City property to the maximum extent possible.”
  • “The City…shall assume pesticides are potentially hazardous to human and environmental health.”
  • “The City shall give preference to reasonably available nonpesticide alternatives when considering the use of pesticides.”
  • “Consider the use of chemicals only as a last resort.”
  • “This Chapter applies the Precautionary Principle to the selection of reduced risk pesticides and other pest management techniques.”

The City’s ordinance that obligates the City to follow the Precautionary Principle makes this commitment:

“A central element of the precautionary approach is the careful assessment of available alternatives using the best available science. An alternatives assessment examines a broad range of options in order to present the public with the consequences of each approach. The process takes short-term versus long-term effects or costs into consideration, and evaluates and compares the adverse or potentially adverse effects of each option, giving preference to those options with fewer potential hazards. This process allows fundamental questions to be asked: ‘Is this potentially hazardous activity necessary?’ ‘What less hazardous options are available?’ and ‘How little damage is possible?’”

We do not believe that herbicide use by the Natural Areas Programs meets the standards of either the City’s ordinance about pesticide use or its commitment to the Precautionary Principal.  These laws are theoretically rigorous, but the enforcement of those laws is not.  The Natural Areas Program is using an herbicide (Garlon) categorized by City policy as the “Most Hazardous” most of the time.  They are using that chemical in sensitive areas in which water can be contaminated and in which children can be exposed.  Their use of that hazardous chemical has increased over time and they have been using that chemical for at least 5 years, perhaps longer (the 2006 management plan for the Natural Areas Program reports the use of this chemical).  If Garlon has not been capable of eradicating in 5 years, the non-native plants that are the target of the Natural Areas Program, it is not likely to do so in the foreseeable future.  

Legitimate concern or “chemophobia”?

Let the reader be the judge.  Given what we know about these chemicals, the frequency of their use, the length of that use, and the locations of that use:

  • Do you think there is reason to be concerned about the herbicides that are being sprayed on our public parks? 
  • Do you think that places that have been designated as “natural areas” should be sprayed with herbicides which are legally and officially designated as hazardous chemicals? 

Photographic evidence that eucalypts are not invasive

One of native plant advocates’ favorite justifications for eradicating eucalypts is the claim that they are invasive.  But are they?  In one of our early posts (“ALIEN INVADERS!!  Another Scary Story”) we reported a scientific study, based on photographic evidence over a 60 year period, that eucalyptus and other non-native trees have not invaded public lands in Marin, Alameda and San Mateo counties.  In fact, the non-native forests in these public lands decreased in size, while native forests increased in size. 

Now we have photographic evidence that eucalyptus has not been invasive when planted in San Francisco.  Adolph Sutro purchased Mt. Davidson in 1881.(1)  He planted it—and other properties he owned in San Francisco—with eucalyptus because he preferred a forest to the grassland that is native to the hills of San Francisco.  Here is a historical photo of what Mt. Davidson looked like in 1885:

Sutro foretold the future of his property:

“…people… will wander through the majestic groves rising from the trees we are now planting, reverencing the memory of those whose foresight clothed the earth with emerald robes and made nature beautiful to look upon.”(2)

Since Sutro didn’t own all of Mt. Davidson, there was a sharp line between the forest he planted and the grassland when this photo was taken in 1927.

Over 80 years later, in a photo taken in 2010, there is still a sharp line between the forest and the grassland.  We see more trees in the foreground where residential areas have been developed and home owners have planted more trees, but the dividing line on the mountain is nearly unchanged.  The eucalyptus forest has not invaded the grassland.

Adolph Sutro would be saddened by a walk in the forest on Mt. Davidson to see over 50 dead and dying trees that have been girdled by native plant advocates.  And the Natural Areas Program’s management plans for Mt. Davidson also announce the intention to destroy 1,600 more trees over 15 feet tall.  Smaller trees to be destroyed are not quantified by the plan. 

Despite the lack of evidence, the California Invasive Plant Council (CIPC) has designated both the eucalyptus and the Monterey pine as “moderately invasive.”  There is even less evidence that Monterey pine grow where not intentionally planted.  These trees and many of the nearly 200 plants on the CIPC “hit list” are on that list because they aren’t native, not because they are invasive.  Few of these plants are truly invasive, but CIPC designates them as such so that their eradication can be justified.  

What is natural?

The branch of San Francisco’s Recreation and Park Department dedicated to the preservation and restoration of native plants to the city’s parks calls itself the Natural Areas Program (NAP).  And the 32 parks or portions of parks within NAP’s jurisdiction are called Natural Areas.  In this post we will visit a few of these areas to ask if they are accurately described as “natural.”

Parcel 4, Balboa & Great Highway, 1868

The Natural Area known as Parcel 4 is at the corner of Balboa and the Great Highway.  A photograph taken in 1868 of that location indicates that it has been continuously built upon for nearly 150 years.  Long-term residents of San Francisco will remember it as the location of Playland by the Beach.  After Playland was closed, the city purchased the property for $3.05 million in 1993 with the intention of putting a sewer pipe under it, then restoring it to dune vegetation.  The soil was essentially building rubble, so the city had to buy $47,000 of sand and disk it down 18 inches to amend the soil in preparation for planting dune vegetation.  The sand was bulldozed into simulated dune shapes and planted in 2002.  The restoration was described in the newsletter of the Coalition of San Francisco Neighborhoods in April 2003, in an article entitled “Sand Francisco.”  Does this sound “natural” to you?

Parcel 4 under construction, 2002
Eight years later, 2010

India Basin is a Natural Area on the east side of the city, on the bay.  The east shore of the city was where most industrial development was located until industry left the city beginning in the 1960s.  Much of the soil was landfill.  Like Parcel 4, the landfill was bull-dozed into a simulated wetland, hoping to restore tidal action.  Native pickle-weed was planted several times in the mud-filled basins.  We haven’t visited this area for several years.  Perhaps they have finally been successful in that effort.  This is what we found there on our last visit:  native plants along the trail, surrounded by plastic and woodchips to discourage weeds and huge, empty, mud basins off shore.    It didn’t look natural to us.

India Basin, 2003

Many of the Natural Areas in San Francisco are less artificial than these two extreme examples.  Some of the Natural Areas weren’t built upon in the past, but had no native plants in them when they were designated as Natural Areas.  Pine Lake is an example of such a Natural Area.  Even where native plants actually existed, their populations were small and isolated in comparison to the acreage designated as a Natural Area.  Over 1,000 acres of city-managed parkland have been designated as Natural Areas, 25% of all parkland in San Francisco and 33% if Pacifica is included in the calculation.

Sculpture of “Albany Bulb Greeter”

Now we will visit the Albany Bulb for contrast.  Albany Bulb is also landfill that was for many years the Albany city dump.  When the dump was closed, the Bulb became a park.  It is a wild and wonderful place.  There are few native plants, other than the ubiquitous coyote bush that seems to thrive almost anywhere.  In the spring, Albany Bulb is a riot of color.  These are the competitive non-natives that native plant advocates wring their hands about.  They are there because they are best adapted to the current conditions in this location…the heavily amended soil, the higher levels of CO₂, the warmer climate, the use by humans and their animal companions. 

Valerian and wild mustard, Albany Bulb. Both are non-native plants.

If all of these non-native plants and trees were eradicated from the Albany Bulb, would native plants magically appear?  Based on our experience, we don’t think so.  The conditions that supported the plants that are native to the Bay Area are gone for good.  It is a fantasy that the existence of non-native plants is the only obstacle to the return of the natives.  Visiting a few places where this strategy has been tried will confirm this.  Unless the natives are aggressively planted, irrigated for several years, fenced for protection, weeded or sprayed with herbicides regularly, they do not return.  Can such intensive gardening be called “natural?”