Escalating war on trees in the East Bay

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. The Draft Environmental Impact Statement (DEIS) was published in April 2013 and the public comment period on that draft closed in June 2013.

FEMA tells us they received over 3,500 public comments on the draft, so needless to say it is taking some time to analyze and respond to those comments. Based on questions raised by public comments, FEMA sent questions to the applicants in October 2013, requesting clarification of their project plans. The applicants responded in November 2013, by revising their project plans. UC Berkeley and the City of Oakland responded that they now plan to “thin” rather than to remove all non-native trees, consistent with the original intentions of East Bay Regional Park District. FEMA now predicts that the final EIS will be published around the end of 2014.

Grant applicants are champing at the bit

The applicants for these grants are getting restless for award of the grant which will fund the removal of tens of thousands of trees or more. We recently reported to our readers that UC Berkeley began to destroy trees on its property in late August 2014, before the grant has been approved. The trees that were destroyed are still lying on the ground, looking like bonfires waiting to happen.

Some of the hundreds of trees destroyed by UC Berkeley in August 2014
Some of the hundreds of trees destroyed by UC Berkeley in August 2014

More recently, Claremont Canyon Conservancy has successfully recruited 12 East Bay elected officials to ask FEMA for immediate release of the grant funds, as well as “complete removal” of all eucalyptus trees, rather than thinning as originally proposed by East Bay Regional Park District and as revised by the City of Oakland and UC Berkeley in November 2013. This request was reported by the San Francisco Chronicle, Contra Costa Times, and ABC TV news. Based on these news sources, as well as the website of the Claremont Canyon Conservancy, we can report that the following East Bay elected officials have signed this request:

City of Oakland
Jean Quan, Mayor of Oakland
Dan Kalb, Oakland City Council
Rebecca Kaplan, Oakland City Council
Larry Reid, Oakland City Council
Libby Schaaf, Oakland City Council

City of Berkeley
Tom Bates, Mayor of Berkeley
Jesse Arreguin, Berkeley City Council
Laurie Capitelli, Berkeley City Council
Susan Wengraf, Berkeley City Council
Gordon Wozniak, Berkeley City Council

State of California
Nancy Skinner, State Assembly
Loni Hancock, State Senate

We have an unsigned copy of a letter to FEMA:

Pols letter to Amaglio

– end letter –

We cannot report with confidence that all these politicians sent the same letter because Oakland Councilman Dan Kalb is the only politician who has responded to our public records request. Mr. Kalb’s request is similar, but requests “funding to remove a substantial number of the eucalyptus trees.” Mr. Kalb’s letter seems to acknowledge that requesting removal of all eucalyptus trees would be inconsistent with the City of Oakland’s November 2013 revision of its original grant application; he says, “I know that the City of Oakland has submitted some revised language as requested by [FEMA].” The elected officials who signed the above letter do not seem to realize that their request contradicts the agreement with FEMA in November 2013 to thin rather than to remove all non-native trees on their properties. Or perhaps they have changed their minds.

This eucalyptus forest at the North Oakland Sports Facility will be  destroyed by the City of Oakland.
The City of Oakland wants to destroy this eucalyptus forest at the North Oakland Sports Facility. Note that where they have destroyed eucalyptus in the past, they have not controlled the resprouts. The grey-green small trees near the base of the hill are eucalyptus resprouts.

Stunning display of ignorance

We are rarely surprised by the extreme views of native plant advocates, but the letter sent by East Bay elected officials is a stunning display of ignorance, mendacity, or both:

  • The claim that native plants are less flammable than non-native plants is entirely fallacious. The indigenous landscape of California is highly flammable as is demonstrated by wildfires throughout California every year. In virtually every case, those wildfires occur in native landscapes.
  • This statement is not even superficially logical: “thinning will enable the Diablo Winds to blow through the eucalyptus more readily, thus enhancing the fire danger…” Obviously, destroying ALL the trees will provide even less of a barrier to Diablo winds.
  • The public record does not support the contention that eucalyptus is more flammable than any other type of vegetation. HERE is a report of the public record of the 1991 Oakland wildfire.
  • Oaks and bays have indeed grown in Clarement Canyon since eucalypts were removed there because it is a riparian corridor where trees are sheltered from the wind and water is funneled to them. However, that is not typical of regrowth after removal of the tree canopy in most locations where eucalypts have been removed. The more likely outcome is non-native annual grasses, as explained HERE by the environmental consultant who evaluated the plans of UC Berkeley. Since fire ignites more readily in grass, fire hazards are not reduced by this transition.
Non-native annual grassland now occupies most of the area where UC Berkeley destroyed 18,000 trees about 10 years ago.
Non-native annual grassland now occupies most of the area where UC Berkeley destroyed 18,000 trees about 10 years ago.

News sources also interviewed Jon Kaufman, a spokesperson for Claremont Canyon Conservancy who expressed his frustration that their desire for the destruction of non-native trees in the East Bay Hills is being delayed by FEMA: “With fire season approaching, it’s a good time to remind FEMA they need to get off their asses.” His insulting approach cannot be called a charm offensive.

Mr. Kaufman is quoted as making the following misstatement of fact: “But Kaufman said no spraying would be involved and that herbicide will be applied topically to the stumps with a brush.” We have heard native plant advocates make this claim many times. Perhaps some of them even believe it. FEMA asked for clarification from grant applicants about their plans for herbicide applications in October 2013. The applicants replied in November 2013 that they will apply Garlon according to the manufacturer’s label.

Mr. Kaufman’s claim that herbicide will not be sprayed is contradicted by the manufacturer of Garlon, DowAgra. The manufacturer describes the method of cut-stump application: “Treat the exposed cambium area and the root collar (exposed bark on the side of the stump) down to the soil line. Be sure to treat the entire circumference of the tree. To ensure effective control on large trees, also treat any exposed roots (knees) that surround the stump.” This method is illustrated on the manufacturer’s website by videos of the applicator using spraying equipment.

The herbicides needed to destroy non-native vegetation are also foliar sprayed, as described by the Draft EIS. It is a fiction that non-native trees and plants can be eradicated without spraying herbicides. The use of large quantities of herbicides is nearly as controversial as the loss of our urban forest.

Are you a voter in Oakland or Berkeley?

If you are a voter in Oakland or Berkeley and you care about the preservation of our urban forest and/or object to the hazards created by spraying our public lands with herbicides, you should know that some of the politicians who signed the letter to FEMA are on the ballot on November 4, 2014. You can take their support for clear cutting all eucalyptus in the Oakland/Berkeley hills into consideration in your vote. Better yet, you could write to them to tell them your opinion of their misguided support for removing all non-native trees on public property. We do not expect our public officials to be experts in horticulture or fire science. However, we think it is irresponsible for public officials to endorse the position of a particular interest group without making an effort to inform themselves of opposing viewpoints.

Here is a list of the candidates you will find on your ballot:

City of Oakland – Candidates for Mayor
Jean Quan http://www.oaklandnet.com/contactmayor.asp
Rebecca Kaplan atlarge@oaklandnet.com
Libby Schaaf lschaaf@oaklandnet.com

City of Berkeley – Candidates for City Council
Jesse Arreguin – District 4 – running unopposed

There is also a petition in opposition to these destructive projects available HERE.

The only logical resolution

One wonders how FEMA can now award grants to the City of Oakland or to UC Berkeley. In November 2013, these public agencies told FEMA, in writing, that they will thin rather than clear cut all non-native trees on their properties. In August 2014, UC Berkeley destroyed all eucalyptus trees on a portion of the project area, which should be a demonstration of UCB’s intentions. Actions speak louder than words, even written words.

In the case of the City of Oakland, elected officials in positions of authority, including the sitting Mayor of Oakland, have contradicted the City of Oakland’s written commitment to FEMA to thin rather than to clear-cut by asking FEMA to immediately release grant funds to clear-cut all eucalyptus from their properties.

How can FEMA trust these agencies to do what they have said in writing they intend to do? The only logical response to the request of these elected officials is to inform UC Berkeley and the City of Oakland that they have effectively rescinded their grant applications.

The Environmental Protection Agency evaluates the Environmental Impact Statement for FEMA projects in the East Bay

The Environmental Protection Agency (EPA) has published its comment on the Draft Environmental Impact Statement (DEIS) for the FEMA projects in the East Bay.  It is available here: FEMA DEIS – public comment – EPA.  We are pleased to tell you that the EPA shares many of our concerns about the environmental impact of these projects and they consider the evaluation of those impacts by the DEIS inadequate.  The EPA has rated this project “Environmental Concerns – Insufficient Information.”  These are the definitions of those terms:

  • “Environmental Concerns:  The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment.  Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact…”
  • “Insufficient Information:  The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment…”

EPA says, “The project could result in degradation of natural resources”

The EPA shares our opinion about the probable outcome of the proposed project:

“The document assumes that areas will naturally regenerate, once rid of non-native species.  We are concerned that some of the aspects of the project would result in degradation of natural resources and may not provide for natural regeneration.  Further, while the DEIS includes a discussion of climate change, it does not include a detailed discussion of the potential impact of climate change on the Project area.  Current research indicates that climate change could impact the amount, timing and intensity of rain and storm events; increase the length and severity of the fire season; modify the rate and distribution of harmful timber insects and diseases; and aggravate already stressed water supplies.  A significant change in the weather patterns could have important implications for the management of the Project area.”

FEMA proposed project on the right. Claremont Blvd. westbound.
FEMA proposed project on the right. Claremont Blvd. westbound.

The EPA recommends that the final EIS take into consideration the impact that climate change will have on the success of the project.  For example, as plants and animals move in response to climate change, they may no longer be viable in their historic ranges, which this project attempts to replicate.  Ironically, the project contributes to climate change by releasing tons of greenhouse gases that cause climate change.  The DEIS does not acknowledge or analyze these factors.

Completed project 10 years later

A completed project 10 years later. Southbound Grizzly Peak Blvd.

EPA says, “We note that extensive use of herbicides is proposed”

Yes, indeed, this project will require thousands of gallons of herbicide and we are delighted that the EPA has noticed this as well as the serious deficiencies of information in the DEIS regarding herbicide use:

  • There are many different formulations of Roundup with different properties, yet the DEIS does not identify which formulation of Roundup will be used.   Therefore we cannot evaluate its toxicity.
  • The DEIS does not clearly state which herbicide products will be used for what purpose and in what locations.
  • The DEIS does not clearly state the method of application of herbicides.
  • The DEIS does not acknowledge that both triclopyr and imazapyr “can migrate through the soil” which will damage the native trees and vegetation this project claims to promote.
  • The DEIS evaluates the impact of herbicides only on endangered species which may or may not be the most sensitive species to herbicides.  The final EIS must evaluate the impact of herbicides on the most sensitive species of animals, whether or not they are endangered.

The EPA is equally concerned about the impact of herbicides on human health and safety.  It therefore notes the following deficiencies in the DEIS in that regard:

  • Reports of toxicity of herbicides in the DEIS are incomplete and inaccurate.
  • The DEIS does not acknowledge the “possibility of people and or animals entering the treated areas and coming in contact with herbicides already applied.”  The Final EIS (FEIS) should therefore “clarify that there is potential for human exposure even if the chemicals do not move from the application site.”  Further, “The FEIS should include a mitigation measure to remove fruiting or other edible vegetation.”

The EPA also noted many of the troubling inaccuracies and contradictions in the DEIS that were also a concern to us:

  • The DEIS claims as “mitigation” the requirements on the labels of the herbicide products that will be used.  These are mandatory requirements for legal use of the products, not voluntary measures that can be described as “mitigation.”
  • Likewise, the DEIS claims that requiring applicators of herbicides to wear protective clothing is a “Best Management Practice.”  Wearing protective clothing is required for legal application of herbicides, not a voluntary measure.
  • Several contradictory statements are made in the DEIS regarding maximum wind speeds beyond which herbicides should not be applied.
  • The DEIS claims that the “Lowest Observed Adverse Effect Levels” of herbicides can be estimated from an experimentally derived “No-observed Adverse Effect Level” without providing any supporting reference.  The EPA asks, basically, where does that claim come from?
  • The EPA points out inconsistent and incorrect use of the phrase “Certified Pesticide Applicator.”  That may seem a small quibble, but it means that we have no idea what the qualifications will be of the people who will apply herbicides.
  • The DEIS announces that a specific adjuvant or surfactant will be used without telling us anything about the properties of that product.  The adjuvant or surfactant is the inert ingredient in a formulated herbicide product that delivers the active ingredient (the poison) to the plant.
  • The DEIS uses an outdated EPA study about the effect of glyphosate on rabbits to report the toxicity of the product on rats.  Whoops!  Old data about the wrong animal!  Picky, picky.

EPA asks, “Are the trees being removed for development?”

The EPA has apparently noticed that the DEIS mentions the long-term plans to build on some of the project areas of UC Berkeley.  Therefore, it wants to know if that’s why the trees are being destroyed: 

“Given that development is not included in the purpose and need for this Project, it is unclear whether the trees in these overlap areas would be removed for construction purposes regardless of whether they are removed as part of the proposed Project or not.”

Government is doing its job!

We are amongst the slim majority of voters who believe that government has an important job to do.  We are often disappointed by government, but we aren’t inclined to kill it because it is sometimes incompetent.  We are therefore very pleased to tell our readers that the EPA has apparently read the DEIS published by its sister/brother agency, The Federal Emergency Management Agency.  Although they did not identify many of the important issues in the DEIS, they identified some of them.  For that we are grateful as well as hopeful that the sponsors of these destructive projects will be forced to at least modify them, if not abandon them altogether.  Thank you, EPA!

Environmental consultant evaluates UC Berkeley’s FEMA project

We described the projects that will destroy tens of thousands of trees on public lands in the San Francisco East Bay in recent posts available here and here.  In this post we will focus on the projects on the property of the University of California, Berkeley (UCB) which will destroy 60,000 54,000 trees on 284 acres, cover 20% of those acres in 2 feet of chipped wood, and spray hundreds of gallons of herbicides on the stumps as well as foliar spray non-native vegetation.

The first consultant that was hired by FEMA to conduct the environmental impact review was URS Corporation.  We know that URS Corporation was the consultant at the time of the scoping process in 2010 because we spoke to their representatives at that meeting.  We were able to obtain the evaluation of UCB’s project by the URS Corporation with a public records request (Freedom of Information Act, AKA FOIA).  In this post we will tell you what URS said about UCB’s project in a letter to FEMA dated May 27, 2009.  FEMA posed 6 specific “issues” and we will briefly describe how URS evaluated these issues.  (The issues are quoted verbatim from that letter.)

Issue 1:  Evidence that the supposed habitat restoration benefit will occur, since no plans for revegetation is included in this grant.

URS agrees with UC that the “project will provide better growing conditions for plants in the understory because the plants will have increased access to resources (e.g., sunlight and soil nutrients).”  But they emphatically do not agree with UCB that the post-treatment landscape will be exclusively native:

French broom in Oakland, CA.  Beautiful but hated by native plant advocates.  Share alike
French broom in Oakland, CA. Beautiful but hated by native plant advocates. Share alike

“However, we question the assumption that the types of vegetation recolonizing the area would be native.  Based on conditions observed during site visits in April 2009, current understory species such as English ivy, acacia, vinca sp., French broom, and Himalayan blackberry would likely be the first to recover and recolonize newly disturbed areas once the eucalyptus removal is complete.  These understory species are aggressive exotics, and in the absence of proactive removal there is no evidence to suggest that they would cease to thrive in the area, especially the French broom which would be the only understory plant capable of surviving inundation by a 2-foot-deep layer of eucalyptus chips.”

URS also observes that wood chip mulch is unlikely to encourage native revegetation over non-native revegetation:

“As written, the current plan assumes native vegetation will reclaim the treatment areas but does not include any plans for native revegetation.  Instead, in order to ‘reduce undesirable weed invasion’ and thus encourage the development of native grasslands, chaparral, and bay/redwood communities, UC plans to apply chip mulch to the ground…It is not clear how the mulch would prevent the proliferation of invasive species while simultaneously encouraging the growth of existing native species.  Despite thorough research, we were unable to find documentation of the ability of exotic chip mulch to suppress undesirable species while encouraging favorable species.”

Issue 2:  Relative fire risk of current vegetation versus chip dominated landscape:  there is no scientific evidence to support the project as proposed.

Although URS agrees with UC that eucalypts are a fire hazard, they question that the eucalypts are more flammable than distributing their dead wood on the ground as wood chips, branches and logs: 

“However, the comparative risk between eucalyptus in the form of a dense standing forest versus the form of a 2-foot-deep mulch layer on the ground is not well documented.  Studies have shown that mulch layers actually can pose a fire risk depending upon the type of material, the depth of the mulch, and the climate of the mulch site….Fire Engineering Magazine recommends that, to reduce the potential for fire in mulch, one should recognize that mulches high in oils ignite more easily and that mulch fires start more readily in hot climates where rain is scarce…Eucalyptus material is high in oils, and the East Bay Hills are subject to long annual periods that are hot and dry.” 

Chips of destroyed trees, UC Berkeley project.  Photo courtesy Hills Conservation Network
Chips of destroyed trees, UC Berkeley project. Photo courtesy Hills Conservation Network

Issue 3.  Potential for introduction of chaparral-dominated landscape and issues associated with fuel-driven fires versus climate-driven fires.

URS notes that the post-treatment landscape is unknown.  However, if UC is right in predicting the return of a native landscape, this is URS’s evaluation of the fire hazard in a native landscape:

“…grasslands fuels burn cooler and faster than eucalyptus material, yet they are easier to ignite and carry fire quickly across a landscape.  Chaparral is one of the most hazardous wildland fuel types in California due to the woody, persistent nature of the plants.  A chaparral-dominated landscape in the post-treatment project area would create a fire hazard profile with its own suite of risks and concerns for fire protection, including flame lengths that far exceed those of the other possible vegetation types.”

URS concludes the analysis of this issue by repeating its concerns regarding the flammability of wood chip mulch: 

“…it may be inaccurate to assume that the chip layer, given its depth, can be ignored as a potential fuel source.  However, such a deep chip layer may have the potential to not only sustain a localized burn but to connect fuels in vegetation types located adjacent to the treatment areas.”

Issue 4.  Justification of two species (Monterey pine and acacia) targeted for removal are a risk.

URS does not believe that Monterey pine and acacia will contribute to fire hazards in the post-treatment project areas:

“The UC inaccurately characterizes the fire hazard risk posed by the two species however…Monterey pine and acacia trees in the treatment area only pose a substantial fire danger when growing within an eucalyptus forest [where they provide fire ladders to the eucalyptus canopy].  In the absence of the eucalyptus overstory, they do not pose a substantial fire hazard.”

Issue 5.  Complete analysis of other practical alternatives…

URS agrees with UC that the cost of annual clearance of ground litter would be prohibitive.  They also agree that “creating strategic fuelbreaks” would not be effective.  However, they say that “thinning targeted species rather than removing all and regularly clearing the understory” should be considered a viable alternative to the proposed project. 

Issue 6.  Document chips will decompose in 3 to 5 years.

UCB’s project intends to distribute wood chips on the forest floor to a depth of 2 feet.  UCB claims that the wood chips will decompose in 3 to 5 years.  URS does not think this is a realistic assessment:

“…literature search did not identify any studies documenting decomposition rates in eucalyptus mulch deeper than 4 inches, which notably is the maximum recommended depth for landscaping…Best scientific judgment suggests that a deeper chip layer would decompose more slowly than a shallow chip layer because it would be more insulated from moisture and less of its surface area would be in contact with decomposing bacteria and fungi found in the soil.”

UCB has ignored the advice of FEMA’s consultant

We have read most of the Draft Environmental Impact Study (DEIS) for this project.  It is about 3,000 pages long, so we won’t claim to have digested it entirely.  However, we can say with some confidence that UCB has ignored most of URS’s scathing criticism of their project.  The only concession that we can see is that UCB now says they will cover only 20% of the project with 2 feet of wood mulch.  However, they intend to cut the remainder of the wood into pieces 2-3 feet long and leave them lying around on the remaining 80% of the project area.  That doesn’t seem like a significant improvement, with respect to fire hazard.  Dead wood is dead wood and tons of it will be lying around when tens of thousands of trees are destroyed.

Why was the Environment Impact Study written by different consultants?

Given that URS was obviously telling UCB something they didn’t want to hear when the process of preparing an environmental impact study began in 2009, we aren’t surprised that URS was not involved in the final preparation of this document.  According to the Draft Environmental Impact Study, the consultants who prepared the report are entirely different.  (DEIS, Section Eight)  URS Corporation is conspicuously absent from the list of preparers of the DEIS.

We rarely subscribe to conspiracy theories.  We usually find incompetence a more realistic explanation for the strange things that happen in our messy world.  However, in this case, let’s just say that this change in the consultants who prepared the DEIS smells bad. 

Please tell FEMA your opinion of these projects

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

 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.

Please sign the petition of the Hills Conservation Network in opposition to these projects which is available HERE.

 

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.

*******************************

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