“Restoration” projects in the Bay Area are more destructive than constructive

I began studying the native plant movement and the “restoration” projects it spawned over 20 years ago when I learned about a proposal to change my neighborhood park in San Francisco in ways that were unacceptable to me.  Virtually all the trees in the park were non-native and the original proposal would have destroyed most of them.  The trees provide protection from the wind as well as a visual and sound screen from the dense residential neighborhood.  A treeless park in a windy location is not a comfortable place to visit.

The original plans would have made the park inhospitable to visitors for several other reasons, particularly by reducing recreational access to the park.  The prospect of losing my neighborhood park turned me into an activist.  I eventually learned there were similar plans for most major parks in San Francisco.  My neighborhood organized to prevent the destruction of our park and to some extent we succeeded.  However, we were unable to prevent the city-wide plan from being approved in 2006, after fighting against it for nearly 10 years.

When I  moved to the East Bay, I learned that similar projects are even more destructive than those in San Francisco,  I have spent the last 20 years informing myself and others of these plans, visiting those places, and using whatever public process that was available to oppose the plans.  The following paragraphs are brief descriptions of the projects I have studied for over 20 years.

Tree Destruction Projects in the East Bay

East Bay Municipal Utilities District (EBMUD) is the public utility that supplies our water in the East Bay.  To accomplish that task, EBMUD manages 28,000 acres of watershed land.  Like most open space in the Bay Area, the vegetation on EBMUD’s land is a mix of native and non-native species.  EBMUD destroys non-native trees which it believes to be a fire hazard.  EBMUD uses herbicides to “control” non-native vegetation, but it does not use herbicides on tree stumps to prevent resprouting.  EBMUD reports using 409 gallons of herbicide and 6 gallons of insecticide in 2019.  Of the total amount of herbicide, 338 gallons were glyphosate-based projects.  EBMUD says “minor amounts of rodenticide were applied by contractors.”

The East Bay Regional Park District (EBRPD) approved the “Wildfire Hazard Reduction and Resource Management Plan” and its Environmental Impact Report in 2009.  This plan is removing most eucalyptus, Monterey pine, and acacia from several thousand acres of parkland.  Forests are being thinned from an average density of 600 trees per acre to approximately 60 trees per acre.  These plans are being implemented and funding for completion of the project has been secured.  Herbicides are used to prevent the trees from resprouting and to destroy vegetation deemed “invasive.”

UC Berkeley clear-cut over 18,000 non-native trees from 150 acres in the Berkeley hills in the early 2000s.  UCB applied for a FEMA grant to complete their clear-cutting plans.  The FEMA grant would have clear cut over 50,000 non-native trees from about 300 acres of open space in the Berkeley hills.

Frowning Ridge, UC Berkeley, 2010

In 2016, FEMA cancelled grant funding as a result of a lawsuit and subsequent appeals from UCB were defeated several years later.  In 2019, UCB revised its original plans.  With the exception of clear-cutting ridgelines, the revised plan will thin non-native forests.  Herbicides will be used to prevent the trees from resprouting.

The City of Oakland applied for a FEMA grant in collaboration with UC Berkeley to clear cut non-native trees on over 120 acres in the Oakland hills.  That FEMA grant was cancelled at the same time UC Berkeley lost its grant funding.  Oakland has also revised its plans for “vegetation management” since the FEMA grant was cancelled.  The revised plan will thin non-native forests on over 2,000 acres of parks and open space.  The plan is undergoing environmental review prior to implementation.  Herbicide use to implement the plan is being contested.

Tree Destruction Projects in San Francisco

The Natural Areas Program (now called Natural Resources Division) of the City of San Francisco has destroyed thousands of trees in 32 designated areas of the city’s parks since the program began in 1995.  The management plan for the Natural Areas Program was approved in 2006, after 10 years of opposition.  The plan proposes to destroy an additional 18,500 trees over 15 feet tall and untold numbers of smaller trees that the plan chooses not to define as trees.   Herbicides are used to “control” non-native vegetation and prevent trees from resprouting after they are cut down.

Sutro Forest 2010

University of California at San Francisco (UCSF) began its effort over 20 years ago to destroy most non-native trees on 66 acres of Mount Sutro.  UCSF applied for a FEMA grant to implement those plans based on their claim that the Sutro Forest is a fire hazard.  UCSF withdrew the grant application after FEMA asked for evidence that the forest is a fire hazard.  San Francisco is cool and foggy in the summer, making fires rare and unlikely.

Sutro Forest with resprouts of destroyed trees. November 2019

UCSF’s plans to destroy most trees on Mount Sutro were approved in April 2018.  Many trees on Mount Sutro have been destroyed since the project was approved and more will be destroyed before the project is complete.  UCSF made a commitment to not use pesticides in the Sutro Forest.  Many of the trees that have been destroyed have therefore resprouted.  Unless the resprouts are cut back repeatedly, the forest is likely to regenerate over time.

  Tree Destruction Projects on Federal Lands

The federal government is one of the largest landowners in the Bay Area.  Golden Gate National Recreation Area (75,500 acres), Point Reyes National Seashore (28,800 acres), and Muir Woods National Monument are operated by the National Park Service.  The Presidio in San Francisco is a National Park that is presently controlled by a non-profit trust.  These parks have engaged in extensive tree-removal on the public lands they control.  Information available on their websites does not enable us to quantify the acres or number of trees that have been removed or are planned for removal in the future.  Therefore, we will describe those projects in the broad terms available to us.

There are two main categories of tree-destruction projects on these federal lands.  There are many large-scale “restoration” efforts that have required the removal of all non-native vegetation, including trees.  These attempts to eradicate non-native plants are based on a misguided belief native plants will magically return.  Herbicides are used by National Park Service to destroy non-native vegetation, although specific information is difficult to obtain because NPS is not responsive to inquiries and the federal public records law can take years to respond.

Eradication efforts fail regardless of method used

In “Lessons learned from invasive plant control experiments:  a systematic review and meta-analysis,” scientists analyzed 355 studies of attempts to eradicate non-native plants from 1960 to 2009.  The scientists determined the methods used and the efficacy of those methods.  More than 55% of the projects used herbicides, 34% used mechanical methods (such as mowing, digging, hand-pulling), 24% burned the vegetation, and 19% used all three methods.  The study found that herbicides most effectively reduced “invasive” plant cover, but this did not result in a substantial increase in native species because impacts to native species are greatest when projects involve herbicide application.  Burning projects reduced native coverage and increased non-native coverage. In other words, it doesn’t matter what method is used, eradicating non-native plants does not result in the return of native plants.   We didn’t need a study to tell us this.  We can see the results with our own eyes.

Flammability of plants is unrelated to nativity

The other, larger category of tree-removal projects on these federal lands are the so-called “fuel management projects.”  The flammability of non-native plants and trees is exaggerated in order to justify their destruction.   Native plants are not inherently less flammable than non-native plants.

In fact, native vegetation in California is fire adapted and fire dependent for germination and survival.  The California Native Plant Society recently revised its “Fire Recovery Guide. The Guide now says, “California native plants are not inherently more likely to burn than plants from other areas.”  This statement is the mirror image of what defenders of our urban forest have been saying for 25 years:  “Non-native trees are not inherently more flammable than native trees.”  Both statements are true and they send the same message: flammability is unrelated to the nativity of plants.  “Think instead about characteristics of plants,” according to the CNPS “Fire Recovery Guide.”

There are undoubtedly many other similar projects of which we are unaware.  I report only on projects that I have direct knowledge about and that I have visited.

Why I opposed these projects

The San Francisco Bay Area was nearly treeless before early settlers planted non-native trees.  Non-native trees were planted because they are better adapted to the harsh coastal winds than native trees.  The treeless grassland was grazed by deer and elk and burned by Native Americans to promote the growth of plants they ate and fed the animals they hunted.  Grazing and burning maintained the grassland, preventing natural succession to shrubs and trees.

Native Americans setting grass fire, painting by Frederic Remington, 1908

Modern land use and management policies have suppressed fire and reduced grazing in the Bay Area.  Consequently grasslands are naturally converting to chaparral and scrub.  Although managers of public lands often describe these changes in the landscape as “invasions,” Jon Keeley (Ph.D. biologist, USGS) considers them a natural succession“These changes are commonly referred to as shrub invasion or brush encroachment of grasslands.  Alternatively, this is perhaps best viewed as a natural recolonization of grasslands that have been maintained by millennia of human disturbance.” 

Early settlers planted trees to protect their residential communities and their crops from wind.  The urban forest also provides sound and visual screens around parks that are surrounded by dense residential neighborhoods.  Urban forests are storing carbon that is released as greenhouse gas when they are destroyed. They also reduce air pollution by filtering particulates from the air.

When trees are destroyed, the unshaded ground is quickly colonized by weeds that are then sprayed with herbicide.  Even environmental organizations that support the destruction of non-native trees agree about the results of these projects:

  • The California Native Plant Society predicted the post-project landscape in its written public comment on the Draft Environmental Impact Statement (DEIS) of the FEMA project in the East Bay hills with this rhetorical question: “What mechanism is being instituted by FEMA in this DEIS to guarantee a commitment of money and personnel for management of greatly increased acreages of newly created annual weedy grassland?”
  • The Audubon Society predicted the post-project landscape in its written public comment on the DEIS: “There is no support for the conclusion that native vegetation will return on its own.  This plan may not result in an increase in native trees and plants…Heavy mulching will delay or prevent the growth of native species.”

To summarize:  I am opposed to destroying our urban forests because they perform many important ecological functions, including providing habitat for wildlife.  Furthermore, the herbicides used to destroy the forest and control weeds that thrive in the absence of shade, damage the soil and create unnecessary health hazards to humans and other animals.

An epilogue to the saga of the San Francisco Natural Areas Program

On December 15, 2016, the San Francisco Planning Commission approved the Environmental Impact Report for the Natural Areas Program and the Recreation and Parks Commission approved the management plan for the Natural Areas Program.  The public hearing was over 6 hours long and is available for viewing HERE.  Although we watched the hearing, we won’t try to summarize it here because readers can watch it if they wish.  Rather we will comment on a few conspicuous observations about the hearing.

The most noteworthy feature of the hearing was that virtually all of the supporters of the EIR and the Natural Areas Program were allowed to speak first.  Critics of the program were called on last.  If you have spoken at such a hearing, you know that speakers submit a speaker’s card on which they indicate their support or opposition for the agenda item when they arrive.  Typically, speakers are called in the order in which they arrive at the hearing.  This usual procedure was apparently not followed in this case.

The main disadvantage of not being called upon in the order in which speakers arrive is that when a hearing is 6 hours long, many people with other responsibilities—such as work or family obligations—are forced to leave before their names are called.  In the case of this hearing, I heard a number of names called of people whom I knew to be critics of NAP, who did not speak, presumably because they waited their turn but weren’t called in the order of their arrival.

Another conspicuous feature of this hearing was that the vast majority of speakers in favor of the EIR and the management plan either work directly for the program or are affiliated with it.  Many supporting speakers were representatives of non-profits that conduct similar projects or they bring children into the parks to “educate” them about native plants.  Their presence at the hearing was therefore a work responsibility which enabled them to spend an unlimited amount of time at the hearing.

This is an illustration of the biggest obstacle to the realization that nativism is a destructive agenda based on outdated scientific hypotheses for which there is no empirical evidence.  In a word, “restoration” ecology is now a multi-million dollar industry in which many people are employed.  Therefore, there is vested economic interest in continuing such efforts whether or not they are successful or beneficial.

Criticisms of the Natural Areas Program and its EIR

The speakers who opposed the approval of the management plan and its EIR were members of the general public who are neighbors of the so-called “natural areas.”  They mentioned the destruction of trees (and the subsequent loss of sequestered carbon) and the use of herbicides as their primary objection to the plans.  Another important issue was the restrictions on recreational access such as the closure of 10 miles of trails and the requirement that all access be confined to the trails that remain.  These are issues with which our readers are familiar, so we won’t elaborate.

Comments based on personal experience with specific “natural areas” seemed most effective.  One fellow said he had participated as a volunteer in several big plantings of native plants in a natural area.  The plants died each time and presently few plants have survived several attempts to “restore” this so-called natural area.  This experience had led this speaker to conclude that attempts to “restore” this park to native plants were futile.

A neighbor of Glen Canyon Park showed pictures of the impact on her neighborhood of the destruction of trees in the park several years ago.  Her neighborhood has lost its windbreak and therefore dust from the bare ground is blowing into their homes.  Their beautiful view of the trees has been replaced by bare ground.

The Natural Areas Program began 20 years ago and has been fully staffed and funded since its inception.  Therefore, it should be judged by what it has accomplished.  It has closed trails, destroyed trees, and built fences.  It has repeatedly destroyed vegetation with herbicides and planted those areas with native plants.  The native plants have died, in some cases several times in 20 years.  In other words, it has little useful to show for 20 years of investment of effort and money.  Since it has not been successful after 20 years, it seems insane to invest another 20 years of money and effort.  Remember that one definition of insanity is doing the same thing over and over and expecting a different outcome.

Support for the Natural Areas Program

We hesitate to use the word “lie” to describe the justifications for the Natural Areas Program, but after listening to hours of testimony by its supporters, we will use that word to describe a few of their claims:

  • The most effective lie is that all the trees they destroy will be replaced with native trees. In fact, no such commitment is made in the management plan, which says explicitly that the natural areas will be converted to grassland and dune scrub.  This “replacement” fiction is mentioned in the EIR.  However, the EIR makes no commitment to planting the replacement trees in the areas or even the same parks where the trees are destroyed.  This important caveat to the commitment to replace the trees was not mentioned by any of the speakers in support of the plans, including NAP’s leadership.  In the case of the 15,000 trees that will be destroyed at Sharp Park, calling those removals anything other than a clear-cut is a lie.
  • Inaccurate descriptions of NAP’s use of herbicides also qualify as lies. The executive director claimed during the hearing that only 2.67 quarts of “active ingredient” were used in the natural areas in 2016. In fact, public records requests inform us that NAP used 1 gallon (4 quarts) of active ingredient from January 2016 to October 2016.  The “active ingredient” is only a fraction of the amount of the formulated product.  The “inert” ingredients in the formulated product are often considered hazardous.  In other words, reporting only the volume of active ingredient underestimates the amount of herbicide being applied.  The number of pesticide applications done by NAP is another way to evaluate the magnitude of pesticides used by NAP.  From January 2016 to October 2016, pesticides were applied in the natural areas 111 times, which is 85% of all pesticide applications in park areas other than Harding Park (which is a golf course maintained to professional competition standards with contractual obligations regarding turf maintenance).  A full report of NAP’s pesticide use is available HERE.

    Courtesy San Francisco Forest Alliance
    Courtesy San Francisco Forest Alliance
  • Claims that the forest in the natural areas will be “managed” for forest health are false. The management plan says explicitly that the trees will be removed for the purpose of expanding native plant gardens that require full sun.  These areas will not be “thinned” as supporters claim.  Rather they will be removed along the leading edge of the forest in order to create more unshaded ground for planting native plants.  The health of the trees is not the criterion for their removal.  These tree removals will not benefit the forest.

However, most of the statements made by supporters are not lies.  Rather they are faithful repetitions of an ideology that most of them probably believe.  Here are a few examples:

  • Nativists believe that native animals require native plants. There is no empirical evidence to support that belief.  All empirical studies find equal numbers of insects, birds, amphibians, etc., using non-native plants.
  • Nativists claim that native pollinators require specific native plants. With few exceptions this belief is mistaken.  The monarch butterfly, for example, is as willing and able to use one of the many non-native species of milkweed as it is a native species.  Some butterflies require a specific genus of plant as its host, but a genus is typically composed of hundreds of species of which many are not native.
  • Nativists believe that the immutable relationship between specific animals and specific plants has evolved over “thousands of years.” They are mistaken.  Animals adapt much more quickly to changes in the environment.  Many changes in plants and animals have been observed over a period of years, rather than a period of centuries, let alone millennia.

Many of the supporters of the NAP plans mentioned that native plants would somehow mitigate climate change.  This is a mysterious notion that I cannot explain.  If we are destroying tens of thousands of trees that store tons of carbon, how can we claim this will reduce climate change?  The grassland that is the goal of these “restoration” projects will store a small fraction of the amount of carbon stored by the trees.  Is this absurd claim a reflection of ignorance about carbon storage?  Or is it a strategy intended to confuse the public?  Whatever the motivation, the claim that native plants mitigate climate change is NOT true.

The nativists apparently do not understand that the ranges of native plants and animals have changed in response to changes in the climate and they will continue to change.  They aren’t stopping climate change by planting native plants.  In fact, climate change requires that the concept of “native” be redefined.  That’s why their projects are unrealistic and futile because they are based on a climate that no longer exists.

The epilogue

The San Francisco Forest Alliance has announced its intention to appeal the certification of the Environmental Impact Report to the San Francisco Board of Supervisors.  This appeal will be heard sometime in 2017.  You will be notified of the hearing if you will subscribe to the Forest Alliance website:  http//sfforest.org.

Meanwhile, the Forest Alliance will ask the City of San Francisco to prohibit the use of the most toxic herbicides in the city’s parks.  There will be two public hearings regarding the city’s pesticide policies and practices:

  • Monday, December 19, 2016, 5 pm. This is a public hearing by San Francisco’s Integrated Pest Management (IPM) Program.  Details about that hearing are available HERE.
  • Tuesday, January 24, 2017. The Commission on the Environment will consider the recommendations of the IPM Program at this hearing.  The Forest Alliance will publish the details of that hearing when they are available.

Best Wishes for a BETTER 2017

The certification of the EIR and the approval of the NAP management plan is not the holiday gift that we were hoping for.  In fact, the entire year of 2016 wasn’t much of a gift to those who believe government has an important and valuable job to do.  We look forward to a better year in 2017 and we wish our readers all the best for the New Year.


An announcement from the San Francisco Forest Alliance about their plans

We are publishing the following email message from the San Francisco Forest Alliance.  They are thanking their supporters for their help at the public hearing about the Natural Areas Program and its Environmental Impact Report.  They are announcing their intention to appeal that decision to the San Francisco Board of Supervisors.  And they inform their supporters of an opportunity to ask the Integrated Pest Management (IPM) Program to prohibit the use of the most toxic types of herbicide in the city’s so-called “natural areas.”  That hearing will take place on Monday, December 19, 2016.  Please help them if you can.


San Francisco SFFA supporters / concerned residents:

Thank you for sending in your letters and braving the rain to sit through the hours long joint meeting of the Planning Commission and SF Recreation and Parks Commission.

Yes, we lost last Thursday and now, with a heavy heart, but with a sense of pride and integrity, please rest assured that we did everything we could to convince the two commissions to see our side.

Thank you for your efforts and for working together, in solidarity and with gratitude from the SFFA leadership.  We will appeal the decision to approve the EIR and will go before the Board of Supervisors next year with an emotional plea that they do the right thing. The City cannot implement the SNRAMP while the EIR is under appeal.

In the meantime, and because the SNRAMP cannot operate without the use of herbicides in city parks, there is something we can now do:

Attend an important hearing on Monday Dec 19th in City Hall at 5 PM.

San Francisco’s Integrated Pest Management (IPM) Program is hearing public input on the guidelines for Tier 1 herbicides and on the approved pesticide list for 2017.

This hearing on the Integrated Pest Management program will be at City Hall on Monday, Dec. 19th at 5 pm, room 408.

We hope you can come because this is our main chance to influence any policy decisions about herbicides for the coming year.

If you plan to attend and make public comment please use our email box  sfforestnews@gmail.com  and leave us your name and phone number so we can coordinate our public input – it is not too late

Important Reading Materials: For those who are planning to speak – those of us who are concerned about pesticide use in our city, please read Attachments B and C(click to access the documents)

B. Draft 2017 San Francisco Reduced Risk Pesticide List, including Draft Restrictions on “most hazardous” (Tier I) herbicides

C. Summary of issues raised regarding pest management for City properties, with agency responses

Note:  It is important that you read these documents prior to making any public comments!

Public opinion does make a difference!

San Francisco Forest Alliance


If you’re on Facebook, please “like” our page: https://www.facebook.com/ForestAlliance

Please sign our petition if you have not already done so.


The final episode in the 20-year saga of San Francisco’s “Natural Areas Program”

the-end-is-nearOn December 15, 2016, the San Francisco Planning commission will hold a public hearing to consider certification of the Environmental Impact Report for the Natural Areas Program. If the EIR is certified, the Recreation and Park Commission will consider formally adopting the management plan for the Natural Areas Program at the same hearing.  The Recreation and Park Commission will have the option of adopting one of the alternatives to the management plan.  The San Francisco Forest Alliance will ask that the Maintenance Alternative be adopted by the Recreation and Park Commission because it is the “environmentally superior” alternative which will destroy the least number of trees and use the least amount of pesticides. 

If you can attend this hearing and make public comment, please contact the SF Forest Alliance (sfforestnews@gmail.com) for the details about where and when the hearing will take place.  If you can’t attend the hearing, please consider sending an email to the Recreation and Park Commission (recpark.commission@sfgov.org) by Monday, December 12, 2016 (the deadline for submission of written public comments to be included in the agenda packet of the commissioners). 

We lived in San Francisco for nearly 30 years and our local park was designated a “natural area” in 1997.  Based on our experience with the Natural Areas Program, we have sent the following email to the Recreation and Park Commission.  We hope that our letter will help you write your own public comment.

Subject:  Approve the Maintenance Alternative for SNRAMP

Dear Recreation and Park Commissioners,

Since the Natural Areas Program was created 20 years ago, hundreds of healthy trees have been destroyed and over one thousand trees died slowly after being surreptitiously girdled by vandals calling themselves native plant advocates in the 32 so-called “natural areas.”  Hundreds of gallons of herbicide have been sprayed on harmless plants, many that provided valuable habitat and food for wildlife.  Trails have been closed and big signs installed instructing park visitors to stay on the trails that remain. Fences have been installed in some parks to enforce those restrictions.

This sign in a "natural area" has been altered to express the public's opinion of the Natural Areas Program. Courtesy San Francisco Forest Alliance.
This sign in a “natural area” has been altered to express the public’s opinion of the Natural Areas Program. Courtesy San Francisco Forest Alliance.

After all that destruction and restriction, what has been accomplished?  Non-native plants have been repeatedly eradicated in the “natural areas” and native plants were planted.  These native plant gardens have repeatedly failed:  the native plants die and the non-native plants return, in some cases many times.  Native trees have been planted in a few “natural areas” but most have died, despite being irrigated during an extreme drought.  After wasting millions of dollars and the associated labor, there is little to show for that investment after 20 years.

Therefore, I am writing to ask the Recreation and Park Commission to vote to adopt the Maintenance Alternative as provided by the Environmental Impact Report that was 10 years in the making.  The Maintenance Alternative would enable the Recreation and Park Department to continue to take care of the “natural areas” they have already created, but it would prevent further tree destruction, further restrictions on recreational access, and require fewer pesticide applications.

Besides the obvious lack of success of the Natural Areas Program after 20 years of effort, there are many other reasons why it would be wise for the Recreation and Park Department to quit throwing good money after bad money.  Here are some of those reasons:

  • The Natural Areas Program was predicated on the mistaken assumption that native plants are superior to non-native plants as habitat for animals. In fact, in the past 20 years multitudes of empirical studies have been conducted that prove that wildlife has no preference for native plants.  Wildlife is just as likely to use non-native plants as they are native plants.
  • The Natural Areas Program also assumed that greater biodiversity would be achieved by eradicating non-native plants. They were mistaken in that assumption as well.  Studies have been conducted all over the world in the past 20 years that find no decrease in plant biodiversity resulting from introduced plants.
  • The climate has changed since Europeans arrived in the Bay Area in 1769 and it will continue to change. The plants that existed here in the distant past are no longer adapted to current conditions.  The ranges of native plants and animals must change if they are to survive in the long run.  Therefore, demanding that historical landscapes be re-created serves no useful purpose.
  • The native trees of California are dying by the millions. The US Forest Service informs us that 102 million native conifers have died in the Sierra Nevada in the past 6 years.  University of Cambridge recently published a study about Sudden Oak Death in which they reported that 5 million oak trees have died in California since 1995 and that the epidemic is “unstoppable.”  There are SOD infections in Golden Gate Park and the Arboretum.  The US Forest Service tells us that Coast Live Oaks will be virtually gone from California by 2060.  A study of redwoods predicts that its native range will shift north into Oregon by the end of this century.  In other words, if we want trees in California, many of them will have to be non-native trees adapted to a hotter, drier climate. 
  • Environmental conditions in a densely populated urban area such as San Francisco are also incompatible with the unrealistic goals of the Natural Areas Program. The heat island effect of urban areas exacerbates climate change.  Increased levels of soil nitrogen caused by the burning of fossil fuels promotes the growth of weeds.

The Natural Areas Program was a good idea that has outlived its usefulness.  We may try to keep it alive for sentimental reasons, but expanding it would be rewarding failure.  Please adopt the Maintenance Alternative.

Thank you for your consideration.


Low doses of pesticides are also hazardous to our health

We are reprinting, with permission, an article on the Save Sutro website about recent research reporting that even low doses of chemicals can be harmful to our health.  This research has serious implications for the pesticides being used by the many “restoration” projects in the San Francisco Bay Area.  This article is focused on pesticide use by San Francisco’s misnamed Natural Areas Program.  In fact, every manager of public land in the Bay Area that engages in native plant “restorations” uses pesticides to eradicate non-native species. 


When we speak up against the Natural Area Program’s frequent pesticide use, its supporters frequently tell us that – compared with say commercial agriculture – the Natural Areas Program (NAP) uses small amounts of toxic chemicals. “The dose makes the poison,” they argue.

But it’s not true.

For now, we’ll leave aside the question of whether it’s reasonable to compare NAP to  commercial agriculture (where fears of chemicals are driving a growing Organic movement). What we’d like to talk about today is recent research about pesticides, specifically, endocrine disruptors. Here’s a quote from the abstract of a study by a group of scientists:

“For decades, studies of endocrine-disrupting chemicals (EDCs) have challenged traditional concepts in toxicology, in particular the dogma of “the dose makes the poison,” because EDCs can have effects at low doses that are not predicted by effects at higher doses….

“…Whether low doses of EDCs influence certain human disorders is no longer conjecture, because epidemiological studies show that environmental exposures to EDCs are associated with human diseases and disabilities. We conclude that when nonmonotonic dose-response curves occur, the effects of low doses cannot be predicted by the effects observed at high doses.”

[Ref: Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses, Vandeberg et al, in Endocrine Reviews, March 2012]


The NAP uses several pesticides rated as “Hazardous” or “Most Hazardous” by San Francisco’s Department of the Environment. But the one they’ve favored is glyphosate — better known as Roundup or Aquamaster.

It’s strongly suspected of being an endocrine disruptor.

Here’s a 2009 study: Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines.

Another study, also published in 2009, looked at puberty and testosterone: Prepubertal exposure to commercial formulation of the herbicide glyphosate alters testosterone levels and testicular morphology. The abstract of the study ends with this sentence, “These results suggest that commercial formulation of glyphosate is a potent endocrine disruptor in vivo, causing disturbances in the reproductive development of rats when the exposure was performed during the puberty period.”

And here’s a study published in 2007, reflecting the research of a group of scientists from Texas A&M: Alteration of estrogen-regulated gene expression in human cells induced by the agricultural and horticultural herbicide glyphosate


Most people weren’t aware that pesticides were being used in so-called “Natural Areas.” The notices were small and well below eye-level. You had to be looking for them, which isn’t likely for most people out hiking or jogging by, or keeping an eye on small kids. In recent months, the labeling has improved, with taller posts and clearer information.

Now that people are beginning to notice, they’re also objecting. The response we hear most often is “Why would they use herbicides in a natural area?”

So the NAP has started posting explanations, justifying its use of toxic herbicides justifiable against “invasive plants.”

These plants, they say, are “a handful of non-native species” that are “displacing the rich biodiversity of native flora and degrading our natural heritage.”


We have several problems with this statement.

  • If it’s a “handful,” the NAP must have very big hands. From the pesticide application records, we’ve counted nearly twenty-five different plant species under attack by chemicals — including a couple that aren’t actually non-native.
  • There’s no evidence that all these plants are invasive and that they’re “displacing the rich biodiversity.” Native plants and non-native plants thrive together in natural mixed ecosystems. NAP can never eliminate all the non-native plants; the best it can achieve is a different mix, precariously maintained through intensive gardening.
  • There’s also no evidence it’s working. Using chemicals to kills things is cheap and easy, but it leaves a gap where something else will grow. Given that San Francisco’s environment has changed greatly since the 1776 cut-off used to define “native” plants, it’s not going to be those plants. Rather, what will naturally grow back will be the most invasive plant at the site. An excuse for more herbicides.
  • The NAP is destroying habitat in its quest to kill native plants. Many of the plants destroyed are bushes that provide cover and nesting places, or flowering plants that offer nectar to butterflies, bees and other pollinators and the birds and animals that feed on them. The “native flora” don’t necessarily provide much of either, even if they can be successfully gardened.

(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