Open letter to Nature in the City

Latest Pesticide Application Notice, Glen Park, March 3, 2012

Nature in the City (NIC) is one of the non-profit organizations in San Francisco that supports native plant “restoration” projects in our public lands, especially the Natural Areas Program (NAP) in the Recreation and Park Department.  We recently published a response to a NIC newsletter which described critics of NAP as “a handful of people” and accused them of “misrepresenting” NAP’s plans for San Francisco’s parks.  In their most recent newsletter they seem to have changed their tune.  This suggests they are starting to take criticism of NAP more seriously.  But does it suggest any change in actions or plans?  With this open letter, we will ask Nature in the City for clarification.

Here is NIC’s latest attempt to communicate with NAP critics or discredit them.  We don’t know which.

Restore to 1769 or to Now?!

I often hear the question, “to what year do you restore?” Some folks are skeptical about ecological restoration since, of course, we can’t turn back the clock!

Some skeptics sardonically say, “are you going back to the ice age, pre-last glacial maximum (22,000 BP)? Well, then, Monterey Pine are native…”

In fact, the answer I give is that we restore to now. Ecological restoration, like all human activities, has a social and environmental context, which is historical indeed, but also very current. And restoration is about healing and looking toward a brighter future, not looking back into the abyss of ecological destruction. Thus, we Spring Forward, taking into account current conditions, constraints, as well as opportunities.

We document historical ecology; are blessed with knowledge of and from a recent and current indigenous cultural context; and study nearby ecological reference sites. Meanwhile, we have laws, recent history, and communities that present a unique local context in every case. Wildlife habitat now takes diverse forms, including in the human-dominated landscape.

If restoring integrity and biodiversity are always the goals, the specifics can vary widely. And this is just fine, because restoration should be a community-driven, democratic process, like every other human endeavor.
-Peter Brastow


Open Letter to Nature in the City:

We are writing to request clarification of your newsletter of March 8, 2012. 

What does it mean to “restore to now?”  If we are satisfied with our parks now, why do they need to be restored?  Isn’t that a contradiction?  If not, what—if anything—does that mean? 

Why is it necessary to “heal” a park that we don’t think is in “the abyss of destruction?”  What if we think that spraying our parks with gallons of pesticides is sending us into “the abyss of destruction?”  Is there a “brighter future” in spraying places called “natural areas” with pesticides 86 times in one year? 

What does it mean to “restore integrity and biodiversity?”  If biodiversity is the goal of the Natural Areas Program why are they eradicating non-native species, thereby reducing biodiversity?  As for “integrity,” we assume NIC means in the sense of “unimpaired.”  But we don’t consider our parks impaired, so we aren’t concerned about their “integrity.” 

Talking out of both sides of your mouth

The tone of the latest NIC newsletter is definitely an improvement over the previous accusatory tone.  However, it isn’t comprehensible, nor is it credible because it is contradicted by the words and actions of NIC.  Here are a few phrases from NIC’s public comment on the Draft Environmental Impact Review (DEIR) of the Natural Areas Program:

“…the analysis [of the DEIR] neglects to fully address the long-term impact of invasive plants from the retention of invasive weed-nurturing eucalyptus groves in the MA-3 areas.”

In other words, NIC wants all the eucalypts destroyed in all of the acres of “natural areas.”  Expanding tree removals into the lowest-priority management areas (MA-3) would increase the number of tree removals substantially.  MA-3 acres are 42% of the total acres of “natural areas.”  The management plan currently prohibits removal of healthy trees in MA-3 acres. 

The DEIR reports that the Maximum Restoration Alternative would have the most impact on the environment.  NIC says in its written public comment on the DEIR that this judgment “may be…a misinterpretation of the intent of CEQA.”  Peter Brastow, Founding Director of NIC, said during his public testimony to the Planning Commission on October 6, 2011, that the Maximum Restoration Alternative should be designated as the environmentally superior alternative in the final version of the Environmental Impact Report.  The Maximum Restoration Alternative would expand all the destructive activities of NAP into all 1,107 acres of “natural areas:” tree removals, eradication of non-native plants, reintroduction of legally protected species, recreational access restrictions, etc. 

But Mr. Brastow is not satisfied with maximizing native plant restorations in San Francisco’s parks.  In his public comment for the revision of the Recreation, Open Space Element (ROSE) of San Francisco’s General Plan, he proposes that a new agency be created to manage all public lands in San Francisco as “natural areas.”  All open space in the city, currently managed by Public Utilities, Port, and Public Works agencies as well as Recreation and Park should be “become part of a single natural resources agency.”  This new agency would “Integrate the protection and restoration of biodiversity within all open space management activities (not just natural areas), e.g., native plant landscaping in designed landscapes, wildlife management and monitoring in all parks, etc.” 

But why stop there?  Mr. Brastow also proposes in his public comment on the ROSE that these principles be extended to private yards:  “Conserve private open space, especially rear yards, as habitats and habitat connectors.” 

Is there any way to reconcile these demands to expand the empire of the Natural Areas Program into every piece of vacant property in San Francisco, both private and public, with the empty phrases of NIC’s latest newsletter?

Looking how far back into the botanical past?

Before we leave this contentious topic, we will address NIC’s opening gambit, “Restore to 1769 or Now?”  The author goes on to dismiss 1769 as the standard, preferring a more forward looking goal.  However, he is once again stuck with the written record, which establishes the pre-European landscape as the goal of the Natural Areas Program.

The management plan for the Natural Areas Program says explicitly that. “The following are the list of criteria…to determine the location of potential plant re-introductions:   Evidence of historic presence (based on Howell et al. 1958).” (page 2-6) And Howell (1958) says that “Native plant [is] present within the geographic limits of present-day San Francisco prior to the arrival of Portola expedition in 1769.” 

NIC may be prepared to welcome plants into San Francisco that arrived after 1769, but until the language in the management plan (and other similar documents such as “Assessment for Forestry Operations,” for Recreation and Park Department, June 2010.) is changed, we will continue to assume that is the standard used by the Natural Areas Program.

Making Peace

The tone of the latest NIC newsletter is welcome and we hope it is a first step toward resolving the conflict over the future of San Francisco’s parks.  If this is a sincere effort to address the objections of San Franciscans to the destructive and restrictive actions of the Natural Areas Program, the next step should be to demonstrate intentions with actions.  We therefore ask Nature in the City to join us in making the following requests of the Natural Areas Program and the Recreation and Park Department:

  • The Natural Areas Program should STOP spraying pesticides in the so-called “natural areas” NOW.
  • The Natural Areas Program should STOP expanding their native plant gardens until the Environmental Impact Report is complete and approved.
  • The Natural Areas Program should STOP destroying non-native plants and healthy trees until the Environmental Impact Report is complete and approved.

These actions would set the stage for the next step.  A lawyer and a critic of the Natural Areas Program has notified the Planning Department, the Natural Areas Program, and the City Attorney that the public comment period for the Draft Environmental Impact Report for the Natural Areas Program did not meet legal standards.  The law requires that notice of the public comment period be posted in all the natural areas and mailed to the neighbors of the natural areas.  Neither of these requirements was met.  Therefore, the lawyer requests that the public comment period be announced as required by law and repeated.

Since NIC says in its current newsletter that “restoration should be a community-driven, democratic process” NIC should agree that another properly announced public comment period is required.  The public cannot participate in this “democratic process” if they are unaware of what is planned for their parks.  

The DEIR must also be revised to accurately identify the Maintenance Alternative as the environmentally superior alternative.  And, finally, when the Planning Commission holds a hearing on the DEIR, the time of that hearing must be announced in advance and adhered to so that those who want to speak have the opportunity to do so (unlike the hearing on October 6, 2011 when the time was changed with little warning and many people were deprived of the opportunity to speak).

Actions speak louder than words!

Response to Nature in the City

Nature in the City (NIC) is one of many organizations that support native plant “restorations” in San Francisco as well as the principle entity which engages in them, the Natural Areas Program (NAP) of the Recreation and Park Department.  NIC is consistently critical of anyone who questions the value of these restorations, but in their most recent newsletter they confront our objections directly.  Although we don’t presume to represent the many constituencies which are critical of the Natural Areas Program, we are responding in this post to NIC based on our knowledge of the issues. (The NIC newsletter is in quotes and is italicized.  Our response is not italicized.)

“Natural Areas in 2012

Last fall saw the the [sic] Planning Commission public meeting for the Draft Environmental Impact Report (DEIR) for the Significant Natural Resource Areas Management Plan.  Some time later this year, the City will issue a Final Environmental Impact Report, which may be appealed by opponents of the Natural Areas Program.

Unfortunately, a handful of people are still propagating misinformation about the rationale, values, and intention of ecological restoration, management and stewardship, and of the City’s celebrated Natural Areas Program.”

Webmaster:  Critics of the Natural Areas Program cannot be described accurately as a “handful of people.”  We now have four websites(1) representing our views and there have been tens of thousands of visits to our websites.  Comments on our websites are overwhelmingly supportive of our views. Our most recently created website, San Francisco Forest Alliance, lists 12 founding members.  That organization alone exceeds a “handful of people.”

Our objections to the Natural Areas Program have also been reported by three major newspapers in the past month or so (San Francisco Examiner, Wall Street Journal,  Sacramento Bee).

 Many critics of NAP have been engaged in the effort to reduce its destructive and restrictive impacts on our parks for over 10 years.  Scores of public meetings and hearings have been held to consider our complaints.  We consistently outnumbered public speakers in support of NAP until 2006, when the NAP management plan was finally approved by the Recreation and Park Commission.  Although we were outnumbered for the first time, there were over 80 speakers who asked the Recreation and Park Commission to revise NAP’s management plan to reduce its negative impact on our parks.

The public comments on the NAP DEIR are the most recent indicator of the relative size of the groups on opposite sides of this issue.  These comments were submitted in September and October 2011.  We obtained them with a public records request.  The Planning Department reported receiving about 400 comments.  In analyzing these comments, we chose to disregard about half of them because they were submitted as form letters, even though they were from dog owners who were protesting the loss of their off-leash privileges in the natural areas.  We also leave aside the comments from golfers whose only interest is in retaining the golf course at Sharp Park.  In other words, we set aside the majority of the comments critical of the NAP management plan in order to focus on those comments that demonstrate a comprehensive understanding of the impact of NAP on the city’s parks.  Of the comments remaining, those critical of NAP and its deeply flawed DEIR outnumbered comments in support of the NAP DEIR about three to one.  We urge NAP supporters to read these public comments to learn about the wide range of criticisms of NAP, including pesticide use, destruction of trees, recreational access restrictions, loss of wildlife habitat and more. 

We will challenge NIC’s accusation that we are “propagating misinformation” within the context of their specific allegations:

“Contrary to the many myths that continue to percolate, the Natural Areas Plan and Program seek to do the following (among other worthwhile endeavors):

1.       Protect and conserve our City’s natural heritage for its native wildlife and indigenous plant habitats and for the overall health of our local ecosystem;”

Webmaster:  Since the majority of acreage claimed as natural areas by NAP 15 years ago had no native plants in them, there is little truth to the claim that NAP is protecting our “natural heritage.”  The so-called “natural area” at Balboa and the Great Highway is typical of the “natural areas.”  There is photographic evidence that it was built upon for about 150 years.  It was the site of Playland by the Beach before it was designated a “natural area.”  Sand had to be trucked onto the property and disked down 18” into the construction rubble, then shaped into dunes by bulldozers before native plants could be planted on it. 

Natural Area at Balboa & Great Highway under construction

We don’t make any distinction between “native wildlife” and any other wildlife currently living in our city.  We value them all.  Most are making use of existing vegetation, whether it is native or non-native.  They do not benefit from the loss of the blackberries that are their primary food source or the loss of the thickets or trees that are their homes.  We do not believe that wildlife in San Francisco benefits from the destructive projects of the Natural Areas Program.  See photos of insects, birds, and other wildlife using non-native plants in the natural areas here.

Damselflies mating on ivy, Glen Canyon Park

We do not think an ecosystem that has been sprayed with herbicides qualifies as a “healthy ecosystem.”  NAP sprayed herbicides at least 86 times in 2011.  Their use of herbicides has increased over 330% in the last 4 years.  NAP uses herbicides that are classified as more toxic than those most used by other city departments.  Last spring, 1,000 visitors to Glen Canyon Park signed a petition, asking the Natural Areas Program to stop using pesticides in their park.  This petition was given to Scott Wiener, the Supervisor representing the district in which Glen Canyon Park is located.

These are statements of fact that can be easily verified by the public record.

2.       “Educate our culturally diverse city about the benefits of local nature and about helping with natural areas stewardship in your neighborhood;”

Webmaster:  Although we value education, we do not consider the staff of NAP and/or its supporters qualified to provide it.  We hear them make statements that are demonstrably not true, such as “grassland stores more carbon than trees.”  We see them spray herbicides in the dead of winter that are supposed to be sprayed in the spring when the plants are actively growing.  We watch them plant things where they won’t grow, such as sun-loving plants in deep shade and plants in watersheds where they will soon be drowned by seasonal rains.

And we also have had bad experiences with the volunteers who are called “stewards” by NAP, but sometimes act more like vandals.  We see them spraying herbicides that they aren’t authorized to use.  We see them hacking away at trees that haven’t been designated for removal.  NAP is not providing the necessary guidance and supervision to the volunteers many of whom seem to consider themselves the de facto owners of the parks. 

3.       “Manage the City’s wildlands for public access, safety and the health of the “urban forest.””

Webmaster:  We do not oppose the removal of hazardous trees.  However, we also know that most of the trees that have been designated for removal by the NAP management plan are NOT hazardous.  They have been selected for removal solely because they are not native and are perceived to be obstacles to the reintroduction of native plants.  Claims to the contrary are inconsistent with the management plan as well as our experience in the past 15 years.  (Watch video about the destruction of 1,600 trees over 15 feet tall planned for Mt. Davidson.)

“We hear occasional complaints about public access and tree removal. Three simple facts are thus:

1. Every single natural area in the City has at least one trail through it, where one can walk a dog on a leash;”

Webmaster:  The loss of recreational access in the natural areas is real, not imagined.  The following are verbatim quotes from the NAP management plan:

  • “Approximately 80 percent of the SFRPD off-leash acreage is located within Natural Areas.” (page 5-8).  The NAP DEIR proposes to close or reduce the size of several off-leash areas.  The DEIR provides no evidence that these areas have been negatively impacted by dogs.  It also states that all off-leash areas in the natural areas are subject to closure in the future if it is considered necessary to protect native plants.  Since NAP has offered no evidence that the proposed immediate closures are necessary, one reasonably assumes it will offer no evidence if it chooses to close the remainder of the 80% of all off-leash areas in San Francisco located in natural areas.  We know from the DEIR public comments that NAP supporters demand their closure.
  • Public use in all Natural Areas, unless otherwise specified, should encourage on-trail use… Additionally, interpretive and park signs should be installed or modified as appropriate to include “Please Stay on Trails” with information about why on-trail use is required.”  (page 5-14)   In other words, the only form of recreation allowed in the natural areas is walking on a trail.  Throwing a ball or frisbee, having a picnic on the grass, flying a kite, climbing the rocks are all prohibited activities in the natural areas.  And in some parks, bicycles have been prohibited on the trails by NAP. 
  • “Finally, this plan recommends re-routing or closing 10.3 miles of trail (approximately 26 percent of total existing trails).” (page 5-14)  So, the only thing visitors are allowed to do in a natural area is walk on the trails and 26% of all the trails in the natural areas will be closed to the public.

2. “The act of removing (a small subset of) non-native trees, e.g., eucalyptus, that are in natural areas has the following benefits:
   a. Restores native habitat for indigenous plants and wildlife;
   b. Restores health, light and space to the “urban forest,” since the trees are all crowded together and being choked by ivy;
   c. Contributes to the prevention of catastrophic fire in our communities.”

Webmaster:  Destroying non-native plants and trees does not restore indigenous plants and wildlife. Native plants do not magically emerge when non-native plants and trees are destroyed. Planting indigenous plants might restore them to a location if they are intensively gardened to sustain them.  However, in the past 15 years we have seen little evidence that NAP is able to create and sustain successful native plant gardens.  Native plants have been repeatedly planted and they have repeatedly failed. 

NAP has not “restored” the health of the urban forest.  They remove trees in big groups as they expand their native plant gardens.  They are not thinning trees.  They are creating large openings for the grassland and dune scrub that they plant in the place of the urban forest.  Every tree designated for removal by the NAP management plan is clearly selected for its proximity to native plants.  It is disingenuous to suggest that NAP’s tree removal plans are intended to benefit the urban forest.

Of all the fictions fabricated by native plant advocates to justify the destruction of our urban forest, the claim that its destruction will “prevent catastrophic fire” is the most ridiculous.  The native ecology of California is highly flammable.  Most fires in California are in native chaparral.  According to San Francisco’s hazard mitigation plan, there has never been a wildfire in San Francisco (2) and one is unlikely in the future because the climate is mild and moist.  When it is hot in the interior, it is foggy in San Francisco.  The hot winds that drive most fires in California never reach San Francisco because it is separated from the hot interior by the bay.  San Francisco is surrounded by water, which moderates its climate and virtually eliminates the chances of wildfire. The tall non-native trees precipitate moisture from the summer fog, which moistens the forest floor and reduces the chances of ignition.  In the unlikely event of a wind-driven fire, the trees provide the windbreak which would stop the advance of the fire. 

3. “The overall visual landscape of the natural areas will not change since only a small subset of trees are planned to be removed over a 20-year period.”

Webmaster:  In addition to the 18,500 trees over 15 feet tall which NAP proposes to destroy, the NAP management plan also states its intention to destroy non-native trees less than 15 feet tall.  In other words, the future of the forest will also be killed.  The intention is to eliminate the urban forest in San Francisco’s parks over the long term.  Yes, this will take some time, but the long-term intention to eliminate the forest is clear.

“Please feel free to email if you would like more clarification about the intention, values and rationale of natural resources management.”

Webmaster:  We urge our readers to take NIC up on this offer to provide  ”more clarification” of its spirited defense of the Natural Areas Program. 

  • Do you think NIC is deluded about there being only a “handful of people” that are critical of the Natural Areas Program?
  • Did you notice that NIC does not acknowledge the use of herbicides by NAP?  Do you think that a fair representation of criticism of NAP can omit this issue?
  • If you visit a park that is a natural area, do you think NAP has demonstrated in the past 15 years what NIC claims it is accomplishing?
  • Do you think NIC has accurately described recreational access restrictions in the natural areas?
  • Do you think that San Francisco’s urban forest will be improved by the destruction of 18,500 mature trees and countless young trees?

(1) Save Sutro Forest, Urban Wildness, San Francisco Forest Alliance, Death of a Million Trees

(2) “The California Department of Forestry and Fire Protection (CAL FIRE) has no record of any wildfire in San Francisco.” San Francisco Hazard Mitigation Plan, 2008, page 5-18.

Our cosmopolitan viewpoint embraces ALL nature

Song Sparrow in non-native wild radish

Many passionate, well-informed comments were sent to San Francisco’s Planning Department about the Draft Environmental Impact Report (DEIR) for the Natural Resources Areas Management Plan (SNRAMP).  Today we’re celebrating the end of the comment period by telling you about one of our favorite comments.

This comment was written by a talented photographer of wildlife in San Francisco’s parks who prefers to remain nameless.  She has exhibited her photos in several venues around town, including San Francisco’s Main Library.  She wrote her comment primarily on behalf of the wildlife that lives in our parks and she illustrated it with beautiful photographs of the birds, insects, amphibians, reptiles, and mammals that she has photographed nesting, hiding, hunting, roosting, slithering in non-native plants and trees.

Garter snake in eucalyptus leaf litter

We will share the heart of her comment with you.  The soul of her comment is her photographs which were all taken in the parks of San Francisco.

“NAP is actually harming the environment by destroying trees, established habitat, and established ecosystems which include our existing wildlife. NAP wants to recreate our environment as one of native grasses which might have existed in the area in 1776 — in very delimited spaces this seems fine, but they should not be taking over our parks which have evolved on all levels since that time. The grasses were native to a sand-dune ecology, but that is no longer the case within the city, and the grasses provide no protective habitat to the animals which now occupy these spaces — animals which are not on NAP’s “specified” or “endangered” lists. There has been an alarmingly high rate of failure when “endangered” species have been introduced — this is because they are no longer suited to this environment which has evolved and changed since 1776. NAP is a political program, not a program based on science, and one which is hampering people’s enjoyment and use of their parks.”

Anise Swallowtail butterfly in non-native fennel

Although we have been engaged in this debate about destructive native plant “restorations” in the Bay Area for many years, we are still shocked by some of the arguments used to defend them.  Nature in the City is one of many organizations in San Francisco which considers itself an “environmental” organization.  In its latest newsletter, recruiting comments in support of the Environmental Impact Report, Nature in the City characterized critics of the Natural Areas Program and the DEIR as the “anti-nature forces.”  As we have said before, “environmentalism” has been stolen from us by the native plant movement, which we firmly believe is doing more harm than good to our environment. 

Frog hiding in pond plants

When was “nature” redefined exclusively as “native?”  We didn’t get that memo.  We are committed to preserving the habitat of all animals that live in San Francisco, whether the animals are native or non-native or the habitat that shelters and feeds them is native or non-native.  How does that make us “anti-nature?”

Honeybee in non-native wild mustard