The City of Oakland began the process of developing a Vegetation Management Plan (VMP) over three years ago. The purpose of the VMP is “to evaluate the specific wildfire hazard factors in the Plan Area [2,000 acres of city-owned parks and open space and 300 miles of roadsides] and provide a framework for managing vegetative fuel loads…such that wildfire hazard is reduced and negative environmental effects resulting from vegetation management activities are avoided or minimized.” (revised VMP, page 3)
The first draft of the VMP was published in June 2018. There were significant issues with the first draft that were described by Million Trees HERE.
The VMP was revised and published on November 1, 2019. It is available HERE. Written comments can be submitted until December 12, 2019. Scoping comments may be submitted by email (firstname.lastname@example.org) or by mail to Angela Robinson Piñon, 250 Frank H. Ogawa Plaza, Suite 4314, Oakland California 94612. “Scoping” is the first step in the process of preparing an Environmental Impact Report (EIR). The purpose of scoping is to identify the issues that must be evaluated by the EIR.
The Forest Action Brigade accepts the revised VMP because fire hazards are real and compromise is needed to address them. Public comments submitted by the Forest Action Brigade regarding scoping for the EIR explain our reasoning. See below. We believe the revised VMP will reduce fire hazards in Oakland without destroying more trees than necessary and limiting herbicide use primarily to preventing trees from resprouting after they are removed. It is counterproductive to destroy more trees than necessary because climate change has made wildfires more frequent and destructive and carbon sequestered by mature trees is one of the most effective means of reducing greenhouse gas emissions causing climate change.
TO: Angela Robinson Pinon, Oakland Fire Department
FROM: Forest Action Brigade
RE: Oakland’s Vegetation Management Plan, Scoping Comments for EIR
The revised Vegetation Management Plan is a significant improvement over the first draft. We accept the revised Vegetation Management Plan for the City of Oakland because:
- Standards for creating and maintaining defensible space around structures, along roadsides, and on ridgelines are reasonable and consistent with both fire science and State law.
- Forests will be thinned, but “broad based tree removal is not proposed.” Mature trees will be retained, which reduces carbon loss. Fire ladders to tree canopies will be eliminated.
- Forest canopy will be retained so the forest floor is shaded and growth of flammable understory grasses and shrubs is suppressed. Density of the canopy will be reduced, but the canopy will be intact.
- Herbicide will be used to prevent resprouts of trees that are removed, but foliar spraying will be “minimized.” The VMP acknowledges that vegetation killed by foliar spraying is left in place and becomes dry, easily ignited fuel.
- Best Management Practices for herbicide use require that all applications be done by certified applicators and requests for herbicide application be approved by a licensed pest control advisor.
- The revised VMP acknowledges that the flammability of plants and trees is unrelated to the nativity of the species. The VMP classifies some species of both native and non-native plants and trees as “pyrophytic.” Non-native plants are not inherently more flammability than native plants. Flammability is related to the physical and chemical characteristics of plants, not their nativity.
- The VMP clearly states that the implementation of the VMP is the responsibility of the Oakland Fire Department. OFD is not obligated to respond to the wishes of advocacy organizations unless their proposals are consistent with fire hazard mitigation.
The revised VMP will reduce fuel loads and risk of ignition. The revised VMP is a fire hazard reduction project with one exception: the VMP continues to propose the destruction of individual non-native trees within stands of native trees. However, that proposal is ranked as Priority 3 and is therefore unlikely to be funded. Oakland’s Tree Services Division is inadequately funded and severely understaffed. Tree Services does not have the resources to remove trees unless they are dead or pose a hazard to the public. Neither Tree Services nor this VMP is responsible for landscape type conversion: “This VMP does not propose vegetation type conversion as an end goal or strategy…” (Page 1) Moreover, such unnecessary removal of mature trees damages the surrounding environment, especially in riparian areas, and increases carbon loss, contributing to climate change.
If the VMP is ultimately funded by renewal of the parcel tax for fuels management, revenues should not be used to hire contractors to destroy individual non-native trees within stands of native trees because that would not reduce fire hazards. The previous parcel tax was cancelled by voters partly because it was misused to fund native plant projects that conflict with fire hazard mitigation. When native plant advocates plant rare, protected plants in Oakland’s parks and open spaces (which they do), they then oppose fuels management that threatens the plants they prefer. It is not possible to mow a meadow of grass to prevent ignition without simultaneously destroying individual plants in that meadow. We saw that principle at work at the public hearing by the Planning Commission on November 20, 2019. The parcel tax that we would vote for would explicitly prohibit the use of the revenue for vegetation type conversion that is incompatible with fire hazard mitigation.
These issues must be addressed by the Environmental Impact Report for the revised VMP, as required by CEQA State law:
- Carbon loss resulting from tree removals must be estimated. Mitigation for carbon loss must be proposed or negative environmental impact must be acknowledged and estimated. Carbon loss contributes to climate change and climate change is making wildfires more frequent and intense. Therefore carbon loss increases wildfire hazards and must be estimated by the EIR for this project.
- The EIR must identify the herbicides and estimate the quantities that will be used to implement the VMP. The amount and impact of pesticides to be used in the VMP should be compared with Oakland’s current levels of herbicide use in the city, including roadside applications. Known hazards of the herbicides that will be used should be acknowledged by the EIR, such as collateral damage to non-target trees and vegetation, damage to the soil, risks to wildlife and human health, mobility and persistence in the environment, etc. The EIR should mitigate for the increased herbicide use by providing mechanisms for accountability to the public, such as a yearly publicly accessible report on pesticides used in this project, including brand names, location, date, method of application, and quantities. Prohibition of herbicide applications by “volunteers” who are not employees or contractors of the City of Oakland should also be added to Best Management Practices to prevent unauthorized herbicide applications in Oakland.
- CEQA requires that alternative plans must be considered by an EIR. Typically, “no project” is one of the alternatives. A third alternative should be less destructive, not more destructive than the proposed project. For example, an alternative to destroying only non-native trees, as proposed by the VMP, would be to destroy bay laurels that are also a pyrophytic species, as well as vectors for Sudden Oak Death that has killed 50 million oaks in California since 1995. In 2019, the rate of SOD infection increased from 1% to 12% in one year in sampled trees between Richmond and San Leandro. Source: https://www.sfchronicle.com/environment/article/Sudden-oak-death-spreading-fast-California-s-14815683.php?cmpid=gsa-sfgate-result
There are several advantages to thinning bays and Monterey pines rather than eucalyptus:
- Every dead oak becomes fuel. Therefore, reducing SOD infections prevents oaks from becoming fuel.
- Bays branch to the ground, providing fuel ladders that are difficult to eliminate because the tree trunk often sprawls on the ground.
- Removing bays instead of eucalyptus also reduces carbon loss because bays are smaller trees and they have shorter lives than eucalyptus trees, which are expected to live another 200-300 years in the Bay Area based on their longevity in their native range.
- Monterey pine has a shorter lifespan than eucalyptus and it is a soft-wood tree. Therefore, removal of Monterey pine will result is less carbon loss than destruction of eucalyptus. Furthermore, Monterey pines do not resprout after destruction. Therefore, they will not require herbicide treatment to prevent resprouts as eucalyptus does. Many Monterey pines in the East Bay are nearing the end of their lives because of when they were planted as well as pine pitch canker infection.
- “We ask that a 4th alternative be considered by the EIR. A “no pesticides” alternative would acknowledge the public’s concerns about the potential for increased pesticide use in Oakland that could be enabled by the completion of the EIR. That alternative must propose a method of preventing tree resprouts without using herbicides. There are precedents for such methods. East Bay Municipal Utilities District does not use herbicides to prevent resprouts. UCSF does not use any pesticides in the Sutro Forest where thousands of trees have been destroyed and thousands more will be destroyed in the future.” Addendum 12/2/19
- CEQA requires that cumulative impacts of similar projects be identified by the EIR. Fuels management projects similar to the VMP are being implemented all over the East Bay. Tree removals by PG&E should be included. The cumulative impact of all fuels management projects in the East Bay must be acknowledged by the EIR.
We hope the revised VMP will survive the public process required to bring it to fruition because we believe it will reduce fire hazards in its present form. We believe that fire hazards are real and that compromise is needed to address them. We congratulate the consultants who prepared the VMP and OFD for shepherding it to completion. Those who were involved in its preparation listened patiently and were responsive to the public’s concerns. We are grateful.
Forest Action Brigade