Nearly a HALF MILLION trees will be destroyed if these East Bay projects are approved

This is a revision of an article that was published on May 5, 2013.  In our haste to inform our readers of these projects during the public comment period, we published before we had read the entire Environmental Impact Study.  We are forced to revise our estimates based on further reading of the document.  We apologize for the confusion and thank you for your patience.

On May 29, 2013, we found an error in the number of trees that will be removed at Frowning Ridge.  We show our corrections so as not to mislead our readers.  Again, our apologies.

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The Federal Emergency Management Agency (FEMA) has been considering grant applications for “fire hazard mitigation” in the East Bay since 2005, when the first of these applications was submitted. After years of debate about whether or not the projects achieve the stated purpose and at what cost to the taxpayers and the environment, FEMA finally agreed to resolve the controversial issues by mandating an environmental impact review, which began in 2010. Although FEMA paid for the environmental review, the grant applicants conducted it and it represents their opinions of their projects.

This eucalyptus forest at the North Oakland Sports Facility will be entirely destroyed.
This eucalyptus forest at the North Oakland Sports Facility will be entirely destroyed.

These are the projects for which the Million Trees blog was created and for which it was named. Our opinion of these projects is unchanged by the environmental impact review. These projects will not achieve their stated objectives. Instead they will damage the environment and endanger the public.

The Draft Environmental Impact Statement (DEIS) for these projects was published by FEMA on April 25, 2013. It is available here. This is a brief description of the projects, our initial assessment of the DEIS, and information about how you can participate in the decision-making process which will ultimately determine the fate of these projects.

Description of the projects in the East Bay

Three different owners of public land have applied for these grants: University of California at Berkeley (UCB), City of Oakland, and East Bay Regional Park District (EBRPD). The projects of UCB and Oakland are similar and they are different from the projects of EBRPD, so we will describe them separately. These are the locations of the projects of UCB and Oakland, their acreage, and the estimated number of trees that will be removed by these projects:

Project Area

Project Acreage

Estimated Tree Removals*

UCB
  Strawberry Canyon

56.3

22,000

  Claremont

42.8

  Frowning Ridge (in Oakland)

185.2

38,000 32,000

Sub-Total

284.3

60,000 54,000

Oakland
  North Hills Skyline

68.3

  Caldecott Tunnel

53.6

Sub-Total

121.9

25,735 23,161

TOTAL

406.2

85,735 77,161

*UCB estimated tree removals are provided by the DEIS; Oakland estimated tree removals are extrapolated assuming the same number of trees per acre (60,000 54,000 ÷ 284.3 = 211 190 trees per acre X 121.9 acres = 25,735 23,161 trees removed by the projects of the City of Oakland)

UCB and Oakland plan to remove all non-native trees (eucalyptus, Monterey pine, acacia, etc.) and vegetation from the project area. All non-native trees up to approximately 24 inches in diameter at breast height (DBH) will be cut into wood chips and scattered on the ground of the project area. They estimate that 20% of the project area will be covered with wood chips to a depth of 24 inches. The DEIS estimates that the wood chips will take from 5 to 10 years to decompose. Larger trees will be cut up and scattered on the site.

Although UCB and Oakland do not intend to plant the project areas (unless erosion subsequent to tree removals demands seeding of native grasses and herbaceous plants), they predict that the project area will eventually become native grassland, scrub, and forest of coast live oak, California bay laurel, big-leaf maple, California buckeye, and California hazelnut. They predict that this conversion from non-native to native vegetation will be accomplished by “recruitment” from areas where these plants exist, into the areas where non-native plants and trees will be removed.

The stumps of eucalypts and acacia will be sprayed with an herbicide (Garlon with the active ingredient triclopyr) soon after the trees are cut down to prevent resprouting. An estimated 1 – 2 ounces of formulated herbicide will be required for each stump. Based on an experiment conducted by East Bay Regional Park District, an estimated 5% of the trees will require retreatment of subsequent resprouts. They are therefore predicting that between 703 633 and 1,407 1,266 gallons of herbicide will be required to prevent resprouting if only 5% of the stumps require retreatment as they claim. Monterey pines will not require herbicide treatment which reduces this estimate proportionately, although we are not provided with enough information to make this calculation. Herbicide (Roundup with active ingredient glyphosate) will also be sprayed to control non-native vegetation, but no estimates of quantities required for that purpose are provided by the DEIS.

The fire hazard mitigation projects of the East Bay Regional Park District were described in detail in its “Wildfire Hazard Reduction and Resource Management Plan” of 2009. EBRPD has applied for FEMA funding for about one-third of the “recommended treatment areas” in that plan. The FEMA DEIS considers all recommended treatment areas on EBRPD property, including those for which FEMA funding has not been requested. The recommended treatment areas for which FEMA funding has not been requested are called “Connected Action Acres.” The “Connected Action Acres” have undergone environmental review under California law (CEQA) and are therefore approved for implementation, which has already begun.

Project Area

Project Acres

Connected Action Acres

Total Acres

Estimated Tree Removals*

EBRPD
Sobrante Ridge

4.1

0

Wildcat Canyon

65.6

46.6

Tilden Park

132

194.2

Claremont Canyon

35.3

130.4

Sibley Volcanic

47.5

118.4

Huckleberry

17.8

.3

Redwood Park

58.4

92.8

Leona Canyon

4.6

0

Anthony Chabot

200

478.2

Lake Chabot

4.8

0

Miller-Knox

22.2

0

TOTAL

592.3

1,060.7

1,653

400,602 409,176

*Estimated Tree Removals: Neither the DEIS nor EBRPD’s “Wildfire Plan” provides an estimate of the number of trees they plan to destroy. Furthermore their plans for tree removals are complex and variable. All non-native trees (eucalypts, Monterey pines, acacia) will be removed in some recommended treatment areas, but in most they will be thinned to spacing of 25 to 30 feet. The final Environmental Impact Report for the “Wildfire Plan” provides an estimate of the existing tree density of existing eucalypts on EBRPD property (page 392). Acres of eucalypts in the entire project area are provided by the DEIS (page 4.2-6).  Our estimate of tree removals is based on those figures (1).

This eucalyptus forest at Chabot Park will be thinned to about 60 trees per acre.
This eucalyptus forest at Chabot Park will be thinned to about 60 trees per acre.

This estimate does not include the Monterey pines and acacia that will be removed by EBRPD, for which inadequate information is available to provide an estimate.

EBPRD plans to cut the trees into wood chips which will be scattered to cover 20% of the project to maximum depth of 4-6 inches. The remainder of the wood will be burned in piles. Other non-native vegetation will be destroyed with herbicides and/or prescribed burns. These prescribed burns will not be funded by FEMA.

EBRPD’s plans to convert the project area to native vegetation are similar to the plans of both UCB and Oakland. EBRPD also does not plan to plant project areas with native vegetation. EBRPD also plans to use herbicides on the stumps of eucalypts and acacia which we estimate will require a mind-boggling 3,286 3,356 to 6,572 6,713 gallons of herbicide.

Million Trees’ assessment of these projects

We have surely exhausted your patience with the mind-numbing detail needed to describe these projects accurately. Therefore, we will provide only a brief outline of our assessment of these projects:

*  These projects are more likely to increase the risk of wildfires than to reduce that risk.

By distributing tons of dead wood onto bare ground

By eliminating shade and fog drip which moistens the forest floor, making ignition more likely

By destroying the windbreak that is a barrier to wind driven fires typical of wildfires in California

By expanding the oak-bay woodland being killed by Sudden Oak Death, thereby adding more dead wood

*  These projects will damage the environment by releasing hundreds of thousands of tons of carbon dioxide into the atmosphere from the destroyed trees, thereby contributing to climate change.

*  These projects will endanger the public by dousing our public lands with thousands of gallons of toxic herbicides.

Erosion is likely on steep slopes when the trees are destroyed and their roots are killed with herbicides.

Non-native vegetation such as broom, thistle, and hemlock are more likely occupants of the unshaded, bared ground than native vegetation which will not be planted by these projects.

Prescribed burns will pollute the air and contribute to the risk of wildfire, endangering lives and property.

*  These projects are an inappropriate use of the limited resources of the Federal Emergency Management Agency which are for the expressed purpose of restoring communities destroyed by disasters such as floods and other catastrophic events and preparing communities for anticipated catastrophic events. Most of the proposed projects in the East Bay are miles away from any residences.

Update:  Please visit THIS post for the current status of these projects.  In summary:  East Bay Regional Park District is implementing its original plans.  City of Oakland is developing a new “Vegetation Management Plan.”  UC Berkeley is suing to re-instate its FEMA grant funding so that it can implement its original plans.

How to participate in this decision-making process

The Hills Conservation Network has created a petition to oppose these projects. It is available HERE.

You can also participate in this decision. FEMA will host three public meetings in May 2013:

Tuesday, May 14, 2013, 2:00 p.m. – 4:00 p.m., Richard C. Trudeau Center, 11500 Skyline Boulevard Oakland, CA 94619

Tuesday, May 14, 2013, 6:00 p.m. – 8:00 p.m., Richard C. Trudeau Center, 11500 Skyline Boulevard Oakland, CA 94619

Saturday, May 18, 2013, 10:00 a.m. – 12:00 p.m., Claremont Middle School, 5750 College Avenue Oakland, CA 94618

Comments on this document must be submitted by June 17, 2013. You may submit written comments in several ways:

  1. Via the project website: http://ebheis.cdmims.com
  2. At the public meetings listed above
  3. By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
  4. By mail: P.O. Box 72379, Oakland, CA 94612-8579
  5. By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars. So, please tell the people who work for you what you think of these projects.

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(1)           Calculation of estimated tree removals by East Bay Regional Park District,  Update:  We understand the weakness of this estimate.  Unfortunately, the DEIS does not provide sufficient information to improve its accuracy.  Again, our apologies.

Existing average density of eucalypts 650 trees per acre
minus Planned average density of eucalypts 60 trees per acre
equals Number of eucalypts removed 590 trees per acre
times Total acres of eucalypts in project areas 824.3
equals Total number of eucalypts removed 486,337
minus Trees removed by UCB & Oakland 85,735 77,161
equals Eucalypts removed by EBRPD 400,602 409,176

(UN)controlled Burns

Today’s SF Chronicle reports that yet another “controlled” (AKA “prescribed”) burn is responsible for a wildfire in California.  This fire in the Santa Cruz Mountains burned 485 acres in October 2009, injuring 4 of the 1,700 firefighters who fought it at a cost of $4 million.  That cost doesn’t include the claims for damages of the property owners who lost their homes.

This isn’t the only controlled burn that has caused major wildfires in California and elsewhere.  For historical perspective, let’s start with the Bandelier Monument Fire in New Mexico.  This fire, began in May 2000 as a prescribed burn and eventually burned over 45,000 acres, threatened the Los Alamos National Laboratory and destroyed 235 structures.  The Department of the Interior suspended all prescribed burns while an inquiry was conducted and policy was revised to theoretically prevent similar accidents.

Did revision of policy stop so-called controlled burns from causing wildfires in our national parks?  No, it did not.  In October 2009, the Big Meadow Fire in Yosemite began as a prescribed burn and eventually burned 7,425 acres.  NPS apparently hadn’t learned much from their bad experience 9 years earlier at the Bandelier Monument.

Yosemite Big Meadow Fire, NPS photo

The National Park Service isn’t the only manager of public land that has had bad luck with controlled burns.  In 2003, the California State Park Department was responsible for starting a fire on San Bruno Mountain in South San Francisco intended to burn 6 acres that eventually burned 72 acres and came perilously close to homes, according to the SF Chronicle.

We should not be surprised by the unpredictable results of prescribed burns.  Fire scientists at UC Berkeley conducted a series of experimental prescribed burns in chaparral in Northern California, hoping to arrive at a model of fire behavior that would improve the predictability of such burns.  They arrived at the conclusion that “…it is extremely difficult to predict with certainty where the fire will spread…For more than half of the transects installed, the flaming front did not traverse the transects as predicted…” (1)

You might ask, “If these prescribed burns keep causing major wildfires, why do we continue starting them?”  Good question, and we are going to answer that.  The conventional wisdom is that because fires have been suppressed in the past century or so, fuel has built up that has become extremely dangerous.  Theoretically, we must restore the “natural” fire cycle to prevent this dangerous build up of fuel that will inevitably cause a huge wildfire if we don’t reduce the fuel load with smaller (hopefully) fires.  Sounds like a good argument, but is it true?  Some scientists say it isn’t.

Jon E. Keeley, Ph.D. (Biologist, US Geological Service) says in “Fire Management in the California Shrublands,”

“Fire management of California shrublands has been heavily influenced by policies designed for coniferous forests, however, fire suppression has not effectively excluded fire from chaparral and coastal sage scrub landscapes and catastrophic wildfires are not the result of unnatural fuel accumulation. There is no evidence that prescribed burning in these shrublands provides any resource benefit and in some areas may negatively impact shrublands by increasing fire frequency. Therefore, fire hazard reduction is the primary justification for prescription burning, but it is doubtful that rotational burning to create landscape age mosaics is a cost effective method of controlling catastrophic wildfires.”

Obviously, there isn’t scientific consensus that prescribed burns reduce fire hazard, so perhaps there is another reason why we pursue this dangerous course.  Yes, there is, and once again we turn to the native plant movement to explain why we are harming our environment and posing unnecessary dangers to animals, including humans.

The scientific literature is rampant with evidence that periodic fire is essential to the health of native plants.  Here is an example from a renowned academic book about California’s ecology that has the status of a standard textbook:

“The [chaparral] community has evolved over millions of years in association with fires, and in fact requires fire for proper health and vigor.  Thus it is not surprising that most chaparral plants exhibit adaptations enabling them to recover after a burn.  Many species are sprouters; the aboveground parts may be killed, but new growth arises from roots or buds at the base of the stem…Other species have seeds that require fire in order to break dormancy; they will not germinate unless they have been heated.  The cones of some chaparral conifers open only after they have been heated.  Some herbaceous species will not germinate unless there is ash on the ground when it rains…In the absence of fire, a mature chaparral stand may become senile, in which case growth and reproduction are reduced.”  (Schoenherr, A Natural History of California, 1992, UC Press)

This is also an opportunity to show how the native plant agenda has been adopted by local managers of our public lands. The “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District announces its intention to conduct prescribe burns for the following purposes:

  • “Grassland and Herbaceous Vegetation…broadcast burns in the summer or early fall [fire season] are known to favor native plants.” (page 128)
  • “Maritime Chaparral…This [native] vegetation type and the Manzanita it supports are also fire dependent. Without disturbance by fire the Manzanita does not reproduce, becomes decadent, and is replaced by shade tolerant species.” (page 132)
  • “North Coastal Scrub…This plant community [of native plants] is adapted to natural fire cycles, and most species found within this plant community resprout easily to rejuvenate individual specimens after fire, or require fire to trigger germination.”  (page 139)
  • “[Native] Coyote Brush Scrub…is adapted to natural fire cycles.  Most species resprout easily to rejuvenate individual specimens after fire, or requires fire to trigger germination.” (page 149)

Are any of these purposes related to reducing fire hazard?  You be the judge.

The management plan of San Francisco’s Natural Areas Program also announces its intention to use prescribed burns in the Initial Study (the first stage of environmental review under CEQA) of the program, but offers no information about the effect of these burns on the environment.  In a city such as San Francisco, in which there is no history of wildfire, we must assume that the sole purpose of these burns will be to benefit native plants.

Clearly controlled burns frequently cause major wildfires.  Fires, whether intentional or not, also release harmful particulates into the air and reduce air quality.  There is no evidence that controlled burns prevent wildfires.  Yet, there is considerable evidence that they benefit native plants.  We conclude that the primary purpose of controlled burns is to benefit native plants. 

 


(1) Scott Stephens, et. al., “Measuring the rate of spread of chaparral prescribed fires in Northern California,” Fire Ecology, Vol. 4, No. 1, 2008