“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.

Is UC Berkeley building a bonfire during fire season?

If you are watching the news, you know that wildfires are raging all over California. One of those fires destroyed most of the small town of Weed a few days ago. The San Francisco Chronicle reported that fire and made a rare acknowledgement of the flammability of native California vegetation: “…the native fuels adapted over thousands of years to the lightning-caused fires that regularly broke out in California. The most problematic in a drought situation, he said, are manzanita, younger ponderosa pine trees and incense cedars. The three are all highly flammable and close to the ground, creating a fuel ladder from the grass to the overstory trees.” The article also noted that fires usually start in grasses and are then fanned by high winds into wildfires that destroy everything in their path.

Yet, the fiction continues in the San Francisco Bay Area that only non-native trees are to blame for wildfires and that they must all be destroyed to reduce fire hazards. In fact, when the trees are destroyed, the unshaded ground is quickly populated by grasses that are the type of vegetation in which virtually all of our fires start.

In the height of fire season, UC Berkeley has recently destroyed many trees in the East Bay Hills and left them lying on the ground to dry out. These huge piles of dead vegetation look like bonfires waiting to happen. We are grateful to our readers for alerting us to this new round of destruction. They have given us permission to publish their letter to the Federal Emergency Management Agency and UC Berkeley. We hope you will consider writing your own letter to express your concern.


 

Alessandro Amaglio [alessandro.amaglio@dhs.gov]
Region IX Environmental Officer
Federal Emergency Management Agency
Oakland, CA

RE: East Bay Hills – Environmental Impact Statement – FEMA – RIX

Dear Mr. Amaglio,

We are writing to tell you that UC Berkeley is in the process of destroying eucalyptus and some pine on its property. Judging by the Pesticide Application Notice posted on Grizzly Peak Blvd near South Park Drive, the trees were destroyed August 24-26, 2014. The scale of the removals is not entirely visible because the property goes down a steep slope that we could not cover. Based on what was visible to us, it appears that at least 100 trees were destroyed on a few acres.

P1010390

We believe the trees are being destroyed within the area for which UC Berkeley has applied for a FEMA grant to remove all non-native trees. We have used the maps in the Draft EIS to make this determination. Therefore, it seems appropriate that FEMA should be informed about this.

P1010400

While we visited the property on Monday, September 15, 2014, we could hear chainsaws in the distance but could not determine where the sound was coming from. Therefore, we suspect that more trees are being destroyed, but cannot determine exactly where.

P1010384

The Pesticide Application Notice gave the name of a person at UC Berkeley (Gary Imazumi) who is responsible for this project. (For the record, we are not responsible for the graffiti scrawled on that sign.) We have contacted him and asked for more information about the entire scale of the project and a timeline for its completion. We have also asked him what will be done with the huge piles of dead vegetation that are now lying on the ground. We have not received a response to our questions.

This incident raises the following questions and concerns:

  • Has the Draft EIS for the FEMA grants to UC Berkeley for tree removal been approved?
  • Has the FEMA grant to UC Berkeley been awarded?
  • If the EIS and/or the grant have not been approved, can UC Berkeley be reimbursed for expenses it incurs prior to the award of the grant?
  • The trees that UC Berkeley destroyed on August 24-26 are still lying on the ground several weeks after they were cut down. They have not been chipped or hauled away.  The Draft EIS made a commitment to chip the destroyed trees and distribute them on the ground.  Is there any time frame for this disposition of the destroyed trees?  Should the public expect dead trees to spend weeks or more on the ground after they are cut down?
  • As you know and the daily news confirms, we are now in the height of fire season. Does it seem consistent with fire hazard mitigation to use chainsaws at this time of year, particularly after several years of drought?
  • Does it seem consistent with fire hazard mitigation to leave dead vegetation lying on the ground during the height of the fire season? Does FEMA believe that dead vegetation is less flammable than living, standing trees?

P1010396

We understand that some of these questions are rhetorical and we don’t expect answers to any but the first three questions. The rhetorical questions are not intended to put you in an awkward position. They are intended to express our opinion of UC Berkeley’s hypocritical claim that destroying living trees will reduce fire hazards. We just want FEMA to know what is happening and to take it into consideration before finalizing the EIS and/or awarding the grant, if FEMA has not already done so.

Thank you for your consideration.

[Concerned citizens of Oakland]

Cc: Gary Imazumi, Manager, Grounds Operations, UCB [garyi@berkeley.edu]
Sal Genito, Associate Director, Grounds, Custodial, Environmental Services, UCB [salgenito@berkeley.edu]
R’obert Newell, Acting Assistant Vice Chancellor, Physical Plant, UCB [rbnewell@berkeley.edu]


 

Update:  On December 1, 2014, FEMA published the final Environmental Impact Statement for the “Fire Hazard Mitigation Grants” in the East Bay Hills.  As a result of UC Berkeley’s premature removal of trees in the project area prior to the publication of the EIS and prior to the award of the grants, the final EIS says that UC Berkeley will not be awarded grant funding for the Frowning Ridge portion of their grant application.  The following is an excerpt from the Executive Summary of the final EIS (page 17) which is available HERE.  However, we should not assume that this prohibition will remain when the EIS is officially approved by the “Decision of Record” on January 5, 2015, because we assume it is being challenged by those who support this project.

“In August 2014, UCB undertook environmental treatment measures on approximately 7.5 acres of the 185.2-acre project area at Frowning Ridge. According to UCB, they felled 150 eucalyptus, Monterey pine, and acacia trees, and applied an herbicide to eucalyptus and acacia stumps. In undertaking these actions prior to issuance of the final EIS, UCB failed to comply with both the specific conditions of the grant and also the NEPA requirement which limits applicant action during the NEPA process under 40 CFR 1506.1. Both required UCB to refrain from action until FEMA had completed its environmental review. As a result, the Frowning Ridge project area is no longer eligible for PDM program grant funding.

Nonetheless, the environmental analysis of the impacts of the proposed action at Frowning Ridge has not been removed from the final EIS because it is part of the review and consideration that FEMA has undertaken in concluding whether to fund the proposed actions. FEMA will continue to work with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service to determine whether UCB’s unauthorized work at Frowning Ridge negatively affects UCB’s other projects at Strawberry Canyon and Claremont Canyon and will make further decisions regarding these projects in the Record of Decision.”