Relentless War on Eucalyptus – The Example of Glen Canyon

This article is reproduced from MillionTrees.me – the website of Death of a Million Trees with permission and minor formatting changes.

A new front has opened in the relentless war on eucalyptus in California. The drought has given native plant advocates an opportunity to develop a new narrative to justify their demands for eradication of eucalyptus. The opening gambit in this new strategy is an item in Jake Sigg’s “Nature News” of May 16, 2014:

“The prolonged drought of the last 2-3 years seems to be taking its toll. The Tasmanian blue gums in Glen Canyon along O’Shaughnessy Boulevard strongly show drought stress. The stress is more evident from the high cliffs above O’Shaughnessy than it is at ground level. Thinning crowns and discolored foliage was striking. And that was before the recent heat wave. Barring substantial rains–unlikely, but not impossible–the trees are in serious trouble. The City could have an emergency situation and no money to address it.”

RECAP OF THE WAR ON EUCALYPTUS

When public land managers began the war on eucalyptus in the 1980s it did not occur to them that the public would object. So deep was their prejudice against eucalyptus, that they assumed the public shared their opinion. The first two massive projects in the 1980s on National Park Service and State Park properties were greeted with angry public protests. Land managers quickly learned that it was not going to be as easy to eradicate eucalyptus as they had thought. They developed a series of story-lines to justify their projects, which were designed to convince the public that the eradication of eucalyptus is both necessary and beneficial. This is a summary of some of their cover stories with links to articles that debunk them:

Based on our experience, we were immediately suspicious of the new claim that San Francisco’s eucalyptus forest is dying of drought. We know that our predominant species of eucalyptus—Tasmanian blue gum—grows successfully throughout California, all the way to the Mexican border in climates that are much hotter and drier than the Bay Area. We also know that the central and north coast of California is foggy during the dry summer months, which doubles the amount of annual precipitation in the eucalyptus forest. All reliable sources of horticultural information describe blue gum eucalyptus as drought tolerant. Frankly, we couldn’t see how our eucalyptus could be dying of drought.

WHAT IS WRONG WITH OUR EUCALYPTUS FOREST IN GLEN CANYON?

The picture became clearer when Jake Sigg posted the following on his “Nature News” on June 12, 2014:

“The June 10 newsletter [see below*] included an editorial on an evolving catastrophe, mostly involving our numerous plantations of Tasmanian blue gums. The editorial focused primarily on the plantations on O’Shaughnessy Blvd in Glen Canyon and on Mt Sutro, and included a photo of a grove of Mt Sutro dying trees. Here is a photo of the Glen Canyon plantation, taken from above the high cliffs on O’Shaughnessy. The damage is most visible from high, looking down. The discoloration of leaves was very dramatic, but the foliage color and condition is not fully conveyed in the photograph. Some trees defoliated entirely in the prolonged winter dry spell. Look very closely at the juvenile blue leaves of the coppice shoots; anything that appears faintly bluish are new coppice shoots which grew in response to the late rains we had in February and March. Once you see coppice shoots on old trees you know the trees are in trouble. These trees are in double jeopardy, as they invested energy in new shoots, but were betrayed by another dry spell which, under normal circumstances, will last until autumn. Note that you can now see the grassland through the trees; that slope was not previously visible. Even a casual inspection of these groves reveals dead, dying, and stressed trees, and under normal circumstances we will have four or five months of dry. The fire situation is serious right now and is likely to become worse.”

 

View of west side of Glen Canyon Park from Marietta Drive, June 2014

View of west side of Glen Canyon Park from Marietta Drive, June 2014

With more specific information in hand about what Jake Sigg is looking at, we went to see for ourselves. We could see what he was describing from a vantage point on Marietta Drive, west of Glen Canyon Park. We could see lighter colored leaves, but they were more localized than Jake Sigg’s description implied. We didn’t feel qualified to speculate about why the leaves were lighter colored so we recruited an arborist to help us figure out what is happening there. We were fortunate to enlist the help of a certified arborist who has been responsible for urban forests on public lands in the Bay Area for several decades. This is what we learned.

EPICORMIC SPROUTS

Looking through binoculars from our vantage point on Marietta Drive, the arborist said immediately, “Those are epicormic sprouts.” The leaves of epicormic sprouts are distinctively lighter colored than the darker green of mature eucalyptus leaves. They are also a more rounded shape than the long, pointed mature leaves of eucalyptus. This is how Wikipedia describes epicormic sprouts: “Epicormic buds lie dormant beneath the bark, their growth suppressed by hormones from active shoots higher up the plant. Under certain conditions, they develop into active shoots, such as when damage occurs to higher parts of the plant. Or light levels are increased following removal of nearby plants.”

Epicormic sprouts on trees in Glen Canyon Park, June 2014

Epicormic sprouts on trees in Glen Canyon Park, June 2014

The remaining question was why some of the eucalypts, were producing these epicormic sprouts, when most were not. We went down to O’Shaughnessy Blvd to get a closer look, hoping to answer that question. This is what we learned:

  • The understory of non-native shrubs between O’Shaughnessy Boulevard and the trees with epicormic sprouts has been cleared in the past year. We could see the dead brush piled up next to the trees. We had to wonder how people who claim to be concerned about fire hazard could think such huge piles of dead brush were nothing to be concerned about.

 

Remains of dead non-native brush destroyed along O'Shaughnessy Boulevard, June 2014

Remains of dead non-native brush destroyed along O’Shaughnessy Boulevard, June 2014

  • We could see the stumps of some of the dead brush and we wondered if the stumps had been sprayed with herbicides after they were cut. Pesticide use reports for Glen Canyon indicate that O’Shaughnessy was sprayed several times in the past year, twice with products containing imazapyr. Imazapyr is known to be harmful to trees if sprayed in proximity to their roots. The trees with epicormic sprouts were downhill from the understory shrubs that were destroyed, in the probable direction of water and herbicide flow.
  • We found several trees that had been girdled in the past and are now dead.
Girdled tree in Glen Canyon Park, now dead, June 2014

Girdled tree in Glen Canyon Park, now dead, June 2014

THE TREES IN GLEN CANYON PARK

Then we walked into Glen Canyon Park from its southern end. It’s not a pretty sight. Many huge, old eucalypts have been destroyed. When they were destroyed, their stumps were immediately sprayed with herbicide to prevent them from resprouting. The stumps are simultaneously painted with dye so that workers can tell which trees have been sprayed. The dye is no longer visible, but regular visitors took photos of the painted stumps before the dye faded. The spraying of the stumps do not appear on the pesticide use reports of the Recreation and Park Department. We assume that’s because the spraying was done by the sub-contractors who destroyed the trees.

Poisoned and dyed eucalyptus stump, Glen Canyon Park, 2013.  Courtesy San Francisco Forest Alliance

Poisoned and dyed eucalyptus stump, Glen Canyon Park, 2013. Courtesy San Francisco Forest Alliance

The arborist who walked in the forest with us said, “The painting of stumps with RoundUp or Garlon in proximity to trees that are being preserved can kill the neighboring preserved tree. Stumps near living, residual (preserved) trees should not be painted with RoundUp or Garlon if the stumps are within 40’ of mature, blue gums that are slated for preservation.” If the remaining trees are damaged by herbicides, their mature leaves fall and epicormic sprouts will then emerge as the tree recovers.

Some of the stumps of the trees that were destroyed in Glen Canyon Park in 2013.  Taken June 2014

Some of the stumps of the trees that were destroyed in Glen Canyon Park in 2013. Taken June 2014

While the trees were being destroyed in 2013, the Natural Areas Program was eradicating non-native vegetation in the Canyon. They sprayed ivy, blackberry, and valerian with Milestone, which is another herbicide that is known to damage trees if sprayed near their roots. In addition to these official applications of herbicide in this park, there is a long history of unauthorized, illegal herbicide applications by “volunteers,” more appropriately called vandals. We saw a lot of epicormic growth in the Canyon, sprouting from stumps that must be cut back and resprayed with herbicides. It usually takes several retreatments to successfully kill the roots of eucalypts that are destroyed. We also saw epicormic growth from eucalypts that had been severely pruned and were also exposed to a great deal more light because they had lost the shelter of their neighboring trees.

Epicormic growht, Glen Canyon Park, June 2014

Epicormic growth, Glen Canyon Park, June 2014

WRAPPING UP

The trees in Glen Canyon are reacting to the traumas to which they have been subjected: the loss of their neighbors that were either girdled or cut down thereby exposing them to more light and wind, the loss of the shelter of their understory, the application of herbicides known to be harmful to trees. The good news is that there are still plenty of trees in Glen Canyon that have not yet been destroyed and they are in great shape. Here is the view of the tree canopy in Glen Canyon taken from the east side of the park near Turquoise Way. The first picture was taken in December 2012 (before the current round of tree destruction in Glen Canyon Park) and the second picture was taken in May 2014.

Eucalyptus canopy on east side of Glen Canyon Park, taken from Turquoise Way December 2012, before tree destruction began.  Courtesy San Francisco Forest Alliance

Eucalyptus canopy on east side of Glen Canyon Park, taken from Turquoise Way December 2012, before tree destruction began. Courtesy San Francisco Forest Alliance

Same perspective of Glen Canyon tree canopy, taken May 2014.  Courtesy San Francisco Forest Alliance.

Same perspective of Glen Canyon tree canopy, taken May 2014. Courtesy San Francisco Forest Alliance.

These trees are doing just fine because the Natural Areas Program has not yet gone that deeply into the park. But NAP intends to destroy many more trees in Glen Canyon (and elsewhere) when the Environmental Impact Report (EIR) for their management plan (SNRAMP) is finally approved. Then we will see more consequences of the destructive practices of the Natural Areas Program and we will probably hear more bogus explanations for that damage. We expect the EIR to finally be considered for approval at the end of 2014. We will do whatever we can to convince San Francisco’s policy makers that they should approve the “Maintenance Alternative” which would enable NAP to continue to care for the native plant gardens they have created in the past 15 years, but prevent them from expanding further. We hope that our readers will help to accomplish this important task.


*Jake Sigg’s Nature News of June 10, 2014, introduced the theories of Craig Dawson about the health of the Sutro Forest. Mr. Dawson’s speculations are different from Mr. Sigg’s and we will not address them in those post.

Fighting The NAP Nativist Agenda

Once in a while, we want to affirm the values that San Francisco Forest Alliance stands for. We’re a grass-roots organization of people who love nature and the environment, pay taxes responsibly, and want access to our parks and wild places – with our families.

Citizens care about their city Parks, and want to keep healthy trees and to open access to natural areas. Citizens expect city management to act responsibly and in the public trust, for FAIR allocation of 2008 Clean & Safe Neighborhood Parks Bond funds.

SF Recreation and Parks Department (SFRPD) and particularly the Natural Areas Program (NAP), obsessed with Native Plants, is cutting down trees, restricting access, using more toxic herbicides than any other section of SFRPD (excluding Harding Park Golf Course), and using financial resources that could better be used for things our city’s residents really want.

OUR VIDEO

Watch our video on Youtube, (where you can also sign up for the SF Forest Alliance Youtube channel):

OUR MESSAGE TO SAN FRANCISCO AND SFRPD

What we stand for can be summarized in four key areas: Trees, Access, Toxins, Taxes.

 

The Natural Areas Program and Pesticide Use

Pesticide Application Notice - Mt Davidson (Nov 14 and 15th, 2013)

Pesticide Application Notice – Mt Davidson (Nov 14 and 15th, 2013)

We recently received a response from Phil Ginsburg, General Manager of the San Francisco Recreation and Parks Department (SFRPD) , to our concerns regarding the “Natural Areas Program”  (NAP). We thank him for the detailed response, but we still have a number of points of disagreement.

One of them is herbicide use. His letter states, “As a percentage of our overall total, herbicide usage in the Natural Areas comprises only 4%.”

As readers of this website know, that’s very different from our own analysis. We find that NAP uses nearly as much of the ‘Most Hazardous’ and ‘More Hazardous’ herbicide as the rest of SFRPD (ex Harding Golf Course).

And the discrepancy is the more surprising since the source documents are the same – the Monthly Pesticide Use Reports each section submits.

The graph below compares NAP and other SFRPD (ex Harding Golf Course). Not only is NAP clearly using much more than 4%, it also is the largest user of the Most Hazardous (Tier I) chemicals. (The San Francisco Department of the Environment – SFDoE – produces a  “Reduced Risk Pesticide” list each year. This lists pesticides that may be used on city-owned lands, and gives them Tier ratings.)

NAP vs SFRPD Other 2013 by Active Ingredient

WHY THE DISCREPANCY?

Since we don’t know how Mr Ginsburg’s percentage is derived, we can only speculate. Some possible reasons:

1)  Our numbers leave out Harding Golf Course, but they include it.

Here’s why we exclude it: Harding Park Golf Course is under contract to be maintained to tournament-ready standards. This means it uses a lot of pesticides; but it really is outside SFRPD control if San Francisco is to have a PGA-standard golf course. (The city’s other golf courses, where SFRPD actually can determine pesticide use, actually use very little.  Sharp Park, for instance, has used none since August 2010.)

2)  Our numbers are for the most recent year, 2013.

Though the phrasing of the sentence suggests that are considering current usage, they may actually have used historic numbers.  It’s possible that other sections of SFRPD reduced their herbicide usage, even while NAP’s herbicide usage went up. NAP herbicide use rose annually from 2009 through 2013.

B&W Herbicide Use - Natural Areas Program

3) We have only considered the chemicals that are most concerning – the “more hazardous” and “most hazardous” herbicides (those the San Francisco Department of the Environment classifies as Tier II and Tier I) and omitted the “least hazardous” ones (Tier III).   Possibly SFRPD has included Tier III herbicides. We think this would distort the comparison; it would be like comparing pineapples and hand-grenades.

4)  If it’s based on the SF DoE’s new database, it may have data-entry errors, especially for data since 2010 when the new database was instituted. We compiled the Monthly Pesticide Usage reports ourselves, and re-checked them.

HOW WE GOT OUR NUMBERS

For anyone who wants to replicate our calculations, here’s how we made them:

  • We obtained Monthly Pesticide Usage reports from SFRPD under the Sunshine Act. If any of them were unclear, we got clarifications.
  • We compiled this data into a spreadsheet. Then we calculated Tier I and Tier II herbicide usage separately for NAP and for all other SFRPD (excluding Harding Golf Course), using SF DoE’s ratings.
  • We show “Greenmatch” separately – it’s rated Tier II, but it’s an organic herbicide that is less harmful than most Tier II products. Until 2013, it was rated Tier III, least hazardous.
  • [ETA:  We calculated the "Active Ingredient" quantity by using conversion factors provided by the manufacturer of each chemical. (These are available online.)]

In the first two months of 2014, NAP was still the major user of Tier I herbicides, using 8 times as much as all the rest of SFRPD ex Harding.

 

 

 

Improvements to the Glen Canyon Park Playground?

Last month we reported on the status of the Glen Canyon Park Playground Improvements.
We mentioned the new playground and that it will not be the same as it was:-  a steep staircase to the slide and bushes that were at the top – now gone. The kids loved that slide … they played games of imagination and adventure there. Instead of a quirky playground that used the advantages of the site, there’s a standard-issue place that could have been built anywhere. And the wonderful climbing tree the children loved, which was behind the Rec Center – it is now gone.

In honor of the Glen Canyon Park Playground re-opening on March 15th, we are re-issuing a relevant YouTube video

Help us save the urban forests in our San Francisco Parks

How Children Draw ‘Save the Eucalyptus Trees’

Someone sent us these amazing ‘Save the Eucalyptus’ posters, produced by the children in political artist and printmaker Doug Minkler’s art class. They’re used with permission. [Edited to add the artists' names.]

(If your kids are drawing pictures of San Francisco’s wild lands or its birds and animals and trees that you’d like displayed, we’d be happy to use them on this site. Please attach them to an email to SFForestNews at gmail.com and be sure to give permission for us to put them up.)

Save-the-Eucalyptus sm

Save the Eucalyptus by Desiree Minkler

the-morning-before-the-loggers-came sm

The Morning Before the Loggers Came – Desiree Minkler

Whoos-For-Us

Whoos For Us? – Tacy Prins Woodlief

no-more-homeless-owls sm

No More Homeless Owls – Blake Bogert

poisoned-water

Poisoned Water – Ayumi Beeler

SFRPD Herbicide Use – A Correction

We recently reprinted an analysis of herbicide use by Natural Areas Program (NAP) compared with the rest of SFRPD. The conclusion, that NAP’s pesticide use increased in 2013, and it exceeded Other SFRPD (excluding Harding Golf Course) was not quite right. Use did increase in 2013, but Other SFRPD actually used more herbicides than shown in the initial calculation. Details below.

Recently, we published our analysis of the San Francisco Natural Areas Program (NAP)’s use of pesticide, and compared it with the rest of SF Recreation and Parks Department (SFRPD) . We said that NAP’s pesticide use had risen in 2013, and it had used more herbicide than the the rest of SFRPD put together (excluding Harding Park Golf Course).

That’s not quite true. They actually used only 84% as much by volume, and 78% as much by Active Ingredient, with one-quarter of the total area.

Here’s the corrected graph. This one is by volume of herbicide used.

NAP vs SFRPD Other by vol corrected

Here’s the graph we showed earlier:

NAP vs Other SFRPD 2013What’s the difference? In a word, Greenmatch.

WHAT’S GREENMATCH?

Greenmatch is a herbicide based on lemongrass oil, or what is called a “botanical.” It’s actually considered acceptable for organic gardening. We’d known SF Department of the Environment (SF DoE) had rated it Tier III, least hazardous. We’d therefore omitted it from our calculations since we’re concerned with Tier I and Tier II (more hazardous and most hazardous) herbicides.

We hadn’t realized that in 2013, SF DoE had downgraded Greenmatch to Tier II. Thus, to be consistent, we needed to include it. The SFRPD used quite a lot of it – around 280 fl oz, because it is a good option compared to some of the synthetic herbicides. NAP didn’t use any Greenmatch in 2013.

ACTIVE INGREDIENT

Our earlier calculation also looked at simple volumes. We do this calculation because some of the “inert” substances that make up maybe half of the products applied are not necessarily innocuous, and so the total volume matters.

However, we also looked at the “active ingredient” – the amount of actual pesticide. Here’s that graph.

NAP vs SFRPD Other 2013 by Active IngredientAgain, it’s Greenmatch that makes the difference.

NAP USES MORE TIER I HERBICIDES

NAP was by far the largest user of Tier I herbicide -mainly Garlon 4 Ultra. (Other SFRPD used a small amount of Garlon, and one application of Cleary’s fungicide in the Golden Gate nursery, inside a greenhouse.)

Since NAP does not use Greenmatch, we haven’t changed our other assessment – that NAP’s overall herbicide use rose again in 2013. This graph shows volume of herbicide applied.

Volume of pesticide use by NAP 2008-2013This one shows amounts by Active Ingredient. [Edited to Add 6 Feb 2014: The earlier graph has been replaced with this one with corrected 2010 data. ]

B&W Herbicide Use - Natural Areas Program

OUR METHODOLOGY

For those who want to dig into how we got our numbers:

1. Under the Sunshine Act, we obtained the ‘usage reports’ – the monthly reports submitted by each department. This lists how much of each pesticide they used, where, for what purpose, how applied, under what conditions and by whom. NAP usually submits two, separately for pesticides it applies, and the pesticides used by their contractor Shelterbelt. These are what we used for 2011-2013. (For 2010, for NAP we had a mix of monthly reports and compiled data supplied by SF DoE, and for 2009 and 2008, it was compiled data from SF DoE.)

2. If any data were illegible, we requested -and got – clarifications. We entered these data into a spreadsheet. In 2013 we kept a record not only of NAP pesticide use, but also other SFRPD Departments’ herbicide use.

3. We calculated total herbicide use, by product, for NAP and SFRPD Other.

4. We excluded Harding Golf Course. It used a substantial amount of pesticides because it’s required to maintain the course in tournament-ready condition. There’s a contract that’s really outside SFRPD’s control, and so would distort the picture. But we do include the other city-owned golf courses -which are under SFRPD control and actually use little Tier II or Tier I pesticide.

5. We calculate four measures of usage for NAP:

  • Number of applications. This measures the number of opportunities for exposure.
  • Volume of applications. This takes into account that the other ingredients in a pesticide formulation could be chemically active, though not pesticides themselves.
  • Volume by active ingredient. This is the most common measure and the one SF DoE prefers to use; and
  • Volume by acid equivalent. This is largely significant when two or more products with the same active ingredient are being used.

To get the last two measures, we use a factor derived from the Materials Safety Data Sheets for each product.

6. To compare SFRPD Other (excluding Harding) we looked at volume, as well as active ingredient. Those are the graphs shown above. (We couldn’t do an acid equivalent because it doesn’t apply to lemongrass oil in Greenmatch EX.)

We try to be rigorous in our analysis, and offer reproducible results. If we discover errors, we will acknowledge and correct them here.

SF’s Natural Areas Program Beats Own Pesticide Record in 2013

This article is adapted with permission from SutroForest.com

UCSF, which owns and manages most of Mt Sutro Forest, recently decided not to use pesticides there. This may make it the only wild land in San Francisco that is reliably free of pesticides. Most of the others  fall under the misnamed Natural Areas Program (NAP) of San Francisco Recreation and Parks Department (SF RPD). NAP is responsible for around 1100 acres in San Francisco in 32 parks. It has a very different attitude to pesticides.

NAP Number of applicns 2008-2013NAP’s RISING PESTICIDE USE

We’ve been tracking NAP’s rising herbicide use, compiling reports we obtain under San Francisco’s Sunshine Act. (The report for 2012 is HERE; and for 2011 is HERE.) For a year or two, we hoped the rise was an anomaly. Apparently not. With the 2013 data in, the best things we can say are that the rate of increase is not as high as in the last four year; and that the number of applications fell.

But the volume of toxic herbicides used still rose.

People have asked us: But why complain about NAP? Surely a garden like Golden Gate Park with all those lawns and golf courses uses lots more herbicide than NAP? This year, we tracked that too. NAP also uses more pesticides than the rest of SFRPD put together.

NAP USES MORE HERBICIDES THAN THE REST OF SFRPD

NAP vs Other SFRPD 2013NAP, which manages one-fourth of the area under the SF RPD, uses more pesticide than the rest of SF RPD put together. That counts all the golf courses except Harding, which is apparently under contract to be tournament-ready.

Also, NAP is the main user of the most toxic pesticides. San Francisco’s Department of the Environment (SF DoE) – which watches out for pesticide use on city-owned property – rates the permitted pesticides into three Tiers. Tier III is the least hazardous; Tier II is more hazardous; and Tier I is most hazardous. NAP is the major user of the Tier I pesticide, Garlon.

VOLUMES UP

As we mentioned earlier, NAP’s pesticide use continued to increase in 2013, though the number of applications went down. The lower number of applications slightly reduces the opportunities for exposure to freshly applied toxins. But this is more than offset by the fact that actual amounts of pesticides continued to rise – and that many of these chemicals are the ones that are most toxic and very persistent.

Volume of pesticide use by NAP 2008-2013

THE FOUR PESTICIDES NAP USES

NAP currently uses four pesticides: Glyphosate (Roundup/ Aquamaster); Triclopyr (Garlon 4 Ultra); Imazapyr (Polaris or Stalker); and Aminopyralid (Milestone VM). They are all of concern. Of these, SF DoE rates Garlon as Tier I (most hazardous); the remaining three are currently rated as Tier II.

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Despite the manufacturer’s claims, there is evidence that these herbicides are not safe. Our article summarizing this is HERE: Natural Areas Program: Toxic and Toxic-er.

ROUNDUP/ AQUAMASTER (Glyphosate)

Classified as a Tier II (More Hazardous) chemical by the San Francisco Department of the Environment, this is the most-used pesticide of the four. However, there’s been growing evidence that it’s not a safe herbicide.

  1. Toxic to human cells, particularly embryonic and placental cells. Here’s an article in Scientific American, about the effect of Roundup on human cells – not just the active ingredient, Glyphosate, but the “inert” one, POEA. (Aquamaster does not contain POEA.)
  2. Damage to liver, red blood cells, lymph system. Here’s a series of research articles detailing some of illnesses caused by Roundup.
  3. Link to birth defects. Here’s an abstract of a May 2010 article in the journal Chemical Research in Toxicology.
    heart breaking

    heart breaking

    It indicates that Roundup increased retinoic acid activity in vertebrate embryos, causing “neural defects and craniofacial malformations.” The actual article, which we read elsewhere describes some of the birth defects: microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (a single eye in the middle of the forehead); and neural tube defects. Our summary of this article is HERE.

  4. Linked to cancer, specifically, Non-Hodgkins Lymphoma. A 1999 article on research linking Roundup to cancer, specifically non-Hodgkins lymphoma, and HERE is a follow-up published in 2008 in the International Journal of Cancer.
  5. Dangerous to amphibians. This article cites University of Pittsburgh research showing Roundup is highly lethal to amphibians.
  6. Suspected endocrine disruptor. Initial research suggests that it is an endocrine disruptor in human cell lines. It’s on the list of chemicals the EPA is reviewing for endocrine disruption.

GARLON (Triclopyr)

NAP accounts for 96% of the use within SF RPD of this Tier I (Most Hazardous) chemical. Garlon kills broad-leaved plants (not grasses or conifers) by sending them a hormonal signal to grow uncontrollably. This weakens the plant until it dies. Its breakdown products are triclopyr acid and then ‘TCP’ – both of which are, fortunately, somewhat less toxic than Garlon. (Imazapyr, by contrast, has a breakdown product that is neurotoxic.)

Our article is based on the Garlon chapter of Draft Vegetation Management from the Marin Muncipal Water District (which can be found here as a PDF file). It was a pretty thorough multi-source review of what was known about the chemical, and it clarified the risks: birth defects; kidney damage; liver damage; damage to the blood. What stood out, though, was how much is not known, particularly about the effects of repeated low-level exposure. There simply isn’t that much research out there, and few human studies. “Although triclopyr has been registered in the US since 1979, there are still very few studies on triclopyr that are not part of the EPA registration process.” Most of the research that exists is on Garlon 4. What NAP uses is Garlon 4 Ultra. It’s similar but isn’t mixed in kerosine. It’s mixed in a less flammable but apparently equally toxic methylated seed oil.

What is known makes uncomfortable reading.

  • Birth defects. Garlon “causes severe birth defects in rats at relatively low levels of exposure.” The rats were born with brains outside their skulls, or without eyelids. “Maternal toxicity was high” and exposed rats also had more failed pregnancies.
  • Damage to kidneys, liver, blood. Rat and dog studies showed damage to the kidneys, the liver, and the blood. It’s insidious, because there’s no immediate effect that’s apparent. If someone’s being poisoned, they wouldn’t even know it. In a study on six Shetland ponies, high doses killed two ponies in a week, and two others were destroyed.
  • Skin absorption. About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast.
  • Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. “The pharmacokinetics of triclopyr is very different in the dog, which is unique in its limited capacity to clear weak acids from the blood and excrete them in the urine.” Dow Chemical objected when EPA said that decreased red-dye excretion was an adverse effect, so now it’s just listed as an “effect.”
  • Insufficient information. There was insufficient information about Garlon’s potential effect on the immune system, or as an endocrine disruptor.
  • Not quite carcinogenic. It isn’t considered a carcinogen under today’s more lenient guidelines, but would have been one under the stricter 1986 guidelines.
  • Probably alters soil biology. “There is little information on the toxicity of triclopyr to terrestrial microorganisms. Garlon 4 can inhibit growth in the mycorrhizal fungi…” (These are funguses in the soil that help plant nutrition.) No one knows what it does to soil microbes, because it hasn’t been studied.
  • Dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Some effect on honey bees. It doesn’t generally kill adult honeybees, but there are no studies of other insects. Some studies show slight “acute toxicity” to honeybees.
  • Garlon can persist in dead vegetation for up to two years.

Given all the information we do have on this chemical (and all the information we don’t have ) we have to question why native plant restoration is worth spraying poisons on some of the highest points in our city. Garlon must be used when the weather is wet; if the plants don’t have water, they will not grow and the chemical won’t work. But the runoff from these hills is enormous during the rain – it washes down in rivulets and streams, and it will end in the reservoirs, the groundwater, and the bay.

IMAZAPYR

Classified as a Tier II (More Hazardous) chemical by the San Francisco Department of the Environment, this is another pesticide used mainly by NAP. In 2013, NAP accounted for 97% of the imazapyr used by SFRPD. NAP started using Imazapyr even before the SF DoE had approved its use. Now it’s being used in Sutro Forest. Here’s our article on Imazapyr.

The main issues with it are that plants push it out through their root system, so that it can spread and affect other plants; it is very persistent. Its breakdown product is neurotoxic. It’s banned in Europe.

According to a BASF Safety Data Sheet from Europe, it’s “Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment.” However, a BASF Material Safety Data Sheet from the US says, “There is a high probability that the product is not acutely harmful to fish. There is a high probability that the product is not acutely harmful to aquatic invertebrates. Acutely harmful for aquatic plants.”

Interesting.

MILESTONE VM (Aminopyralid)

SF DoE originally classified this chemical as Tier I, Most Hazardous, because of its uncanny persistence. In 2013, it was reclassified as Tier II – More Hazardous. At the time, we protested that the down-classification would increase its use; SF DoE didn’t think so. But this year, NAP’s use of Milestone has risen 200% from 2012. (Only NAP uses Milestone in the SF RPD.)

Milestone is even more persistent that Imazapyr, and can survive being ingested by animals. Thus, if it is used to treat plants and animals eat and excrete them, they spread the poison. It is banned in New York for fear it will get in the groundwater, and was for a time banned in the UK.

STILL RISING

For purists, we also calculated NAP’s pesticide usage based on “Active Ingredient” and based on “Acid Equivalent.” (The post explaining those measure is HERE.) By those calculations, it’s gone up even more.

NAP Pesticide by Active Ingredient 2008-2013NAP Pesticide by Acid Equiv 2008-2013 Index of NAP Pesticide Use 2009-2013

The graph above shows index numbers of the various indicators, with a base of 2008 (i.e, 2008 = 100). After a dip in 2009, NAP’s pesticide use has trended upward for four years. We cannot quite understand the need for the continuous rise in pesticide use in NAP. We can only wonder if it correlates to budget availability.

We call upon SF RPD to stop all Tier I and Tier II herbicide use in Natural Areas. It would make the Natural Areas more … natural. And it would halve SF RPD’s herbicide consumption, and nearly eliminate their use of Tier I pesticides.

NAP vs SF RPD Other 2013

Herbicide use on Mt Davidson – Nov. 2013

We saw this sign posted on Mt Davidson this week:

Pesticide Application Notice - Mt Davidson (Nov 14 and 15th, 2013)

Pesticide Application Notice – Mt Davidson (Nov 14 and 15th, 2013)

It is too wet to apply these herbicides now and these two herbicides are very dangerous, one is banned in Europe and the other in New York:

  • Polaris (Imazapyr). This Tier II herbicide is a problem because it spreads (it doesn’t stay where it’s applied) and it persists (it doesn’t break down easily). It’s a relatively new herbicide, and we don’t know quite what it does – though its breakdown product  is neuro-toxic. It’s banned in Europe, and neighbors are fighting against its use in privately owned forests in Northern California.
  • Milestone (Amino-pyralid). This Tier I toxic chemical sticks around even more persistently than imazapyr. It was banned for a time in the UK because if animals eat and excrete it, the excreta are still poisonous – as is the manure made from it. It’s banned in New York state because they aren’t sure it won’t poison the water. NAP’s used it in Lake Merced, Pine Lake, Glen Canyon, and Mount Davidson, all of which are areas where water contamination is possible.

In our January, 2013 post  (http://sfforest.net/2013/01/17/sfs-natural-areas-program-uses-even-more-pesticides/) we noted that the Natural Areas Program (NAP) used more pesticides than in 2012 than any year beginning in 2008, which was the first year for which we have data provided by the City.

An escalating use of herbicides is bad for the environment and the people, pets and wildlife using these parks. It sends a damaging message about priorities and indicates a lack of success with the NAP program.

In August, 2013, we issued (http://sfforest.net/category/applies-pesticides/) a Rec and Park Dept Pesticides Report for the first half of 2013;  we noted then that Rec and Park uses more herbicides in the natural areas than in the rest of the Parks together. Also, NAP is the main user by far of the most toxic Tier I pesticide:  Garlon.

SF RPD Pesticides Report, 1st Half 2013

In April 2013, we posted about the herbicide use of the Natural Areas Program (NAP) vs the rest of San Francisco’s Recreation and Parks Department (SFRPD). That’s HERE.  This graph is based on the data for half the year, 2013.

SFRPD Pesticides 1H 2013

Though other SF RPD areas have used more herbicides in the second quarter, NAP’s use still far exceeds the total of the rest of the Parks together. (This excludes Harding Golf Course, which is a special case since it has to be kept tournament-ready, but includes all other city golf courses – and Sharp Park, which uses no pesticides at all. It also excludes pesticides used to control insects and animals, for instance “Wasp Freeze.”)

And what’s worse – NAP is the main user by far of the most toxic Tier I pesticide: Garlon. That’s the orange bar in this graph. The rest of SFRPD did use some, but it was so little that it doesn’t even show up on this graph.

Spraying pesticides in Glen Canyon March 2013

Summer Walk on Mt Davidson

A group of 17 neighbors gathered for a summer walk on Mount Davidson …  in typical summer weather: super foggy. The group walked through the beautiful woods, shrouded in mist.

Mt D 6-17-2013

The paused on the road at the turn where 82% of the trees are planned to be clear-cut. It’s one of the loveliest areas of the forest.

Mt D 2 6-17-2013

One observer had never been there and was amazed at the wonder of the forest. No one could understand why 1600 trees should be cut down and the others more made vulnerable to wind-throw.  Instead SF Recreation & Parks Department  has plans for tree-felling, habitat destruction, and a vastly increased use of toxic pesticides under the “Natural Areas Program.”

Mt D 3 6-17-2013

Even the (native) Pacific Reed Grass growing there – that’s a native plant – is a forest species, and thrives in the shade and moisture of the eucalyptus. Nature is opportunistic, and native and exotic species are part of a web of life that’s adapted to the conditions of this site. Non-native plants have added bio-diversity; according to Peter Kareiva, chief scientist at the Nature Conservancy, California now has 25% more plant species than it had before.

Who’s Using Pesticides: Q1 Pesticides Report

We’ve been reporting that San Francisco’s Natural Areas Program (NAP) has been spraying increasing amounts of toxic pesticides in parks used by people, pets, and wildlife.  The San Francisco Department of the environment restricts the use of pesticides of land owned by the city, and it classifies permitted chemicals into three tiers: Tier III is the least hazardous; Tier II, more hazardous and Tier I, most hazardous pesticides.

Recently, someone asked us how NAP’s Tier I and Tier II pesticide use compares with the rest of SF Rec & Parks (SFRPD) usage. We hadn’t compiled the numbers (and neither, as far as we know, had the city).  But we’ve done so now for the first quarter, Jan-March 2013.

It’s pretty bad. NAP used three times as much of the most toxic chemicals as all the other SFRPD departments put together.

NAP vs Other SFRPD

[Edited to Add: We should note that these figures exclude Harding Park Golf Course. That's a separate case because apparently the city is under contract to maintain it to certain specifications that involve substantial amounts of pesticides.]

NAP was the only department to use Tier I herbicides.  They used Garlon 4 Ultra against oxalis in McLaren Park, Bayview Hill, Twin Peaks, and Mount Davidson. No other SFRPD area used any Tier I herbicides.  NAP doesn’t use any Tier III pesticides.

Our “Natural Areas” are getting hit with the most toxic chemicals the city permits.

Which areas did they target?

  • In March, it was Mc Laren and Glen Park.
  • In February, it was Twin Peaks, Mt Davidson, Lake Merced, Pine Lake, and Oak Woodlands in Golden Gate Park.
  • In January, it was Bayview, McLaren, and Twin Peaks.

Most of the pesticides used by NAP were applied by the contractors, Shelterbelt.

If this concerns you – as it does us – write to your representative on the Board of Supervisors. And write to the Mayor. These levels of pesticide use just don’t make sense for so-called “Natural Areas.”

Pesticides and Cancer, Glyphosate and Gut Bugs

Spraying pesticides in Glen Canyon March 2013At the recent “Save the Forests!” meeting, physician Dr Morley Singer told us about an article in the journal of the American Cancer Society that showed links between pesticide use and increased cancer risk. The article is in CA: A Cancer Journal for Clinicians, which is peer-reviewed and highly respected, and he sent us the link.

[HERE's the link to the article:  Increased cancer burden among pesticide applicators and others due to pesticide exposure.]

What caught our eye was glyphosate, the active ingredient in Aquamaster and Roundup,   and the pesticide most used by SF Rec & Parks’ Natural Areas Program (NAP). Glyphosate is associated with Non Hodgkin Lymphoma.

A HIGHER RISK OF CANCER

Pesticides increase the risk of cancer not only for the people who apply these toxins, but also for bystanders.  And it’s not just insecticides, also herbicides, which are much more broadly used. From the abstract:

“A growing number of … studies provide substantial evidence that the pesticidesare associated with excess cancer risk. This risk is associated both with those applying the pesticide and, under some conditions, those who are simply bystanders to the application.”

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

The problem with determining cancer risk from pesticides is that you can’t conduct experiments on people. Experiments on animals would have to be quite long term, and thus expensive.

What you can collect is “epidemiological” evidence – that shows a link between the pesticide and types of cancer (or other conditions), but doesn’t specify how it works. You can also do studies on cells in laboratories, a process that is cheaper (and, frankly, more humane) than doing large experiments on live animals. Those can provide insights to how exactly the toxins work.  Epidemiological evidence is the kind of  evidence that eventually tied cigarette-smoking to lung cancer. The tobacco industry argued that there was no toxicological evidence, but the epidemiological evidence eventually became overwhelming.

As the journal article says: “The use of cultured animal and human cells allows high-throughput assays of pesticide toxicity to be assessed at much lower cost compared with whole-animal studies and without the ethical constraints that limit human studies.”

What the authors did was look at a whole lot of other studies for associations between many types of cancer and many different pesticides. They found a problem.

“In this article, the epidemiological, molecular biology, and toxicological evidence emerging from recent literature assessing the link between specific pesticides and several cancers including prostate cancer, non-Hodgkin lymphoma, leukemia, multiple myeloma, and breast cancer are integrated. Although the review is not exhaustive in its scope or depth, the literature does strongly suggest that the public health problem is real.”

GLYPHOSATE (ROUNDUP, AQUAMASTER) AND HEALTH EFFECTS

One of the pesticides mentioned was glyphosate, the active ingredient of Roundup and Aquamaster. It’s one the pesticides NAP uses most frequently. (In the graphs below, Roundup/ Aquamaster is represented by the olive-green section at the bottom of each column.)

It’s associated with Non Hodgkin Lymphoma, a group of cancers starting from the lymph nodes.

pesticide use number n vol 2008 to 2012

GLYPHOSATE AND GUT PROBLEMS

An article at Rodale.com suggests the growing evidence against glyphosate, possibly the world’s most widely used herbicide: ‘Once called “safer than aspirin,” glyphosate’s reputation for safety isn’t holding up to the scrutiny of independent research. More and more non-industry-funded scientists are finding links between the chemical and all sorts of problems, including cell death, birth defects, miscarriage, low sperm counts, DNA damage, and more recently, destruction of gut bacteria.’

Researchers found that glyphosate residues on food interfere with certain enzymes, with the result that  “…glyphosate enhances the damaging effects of other food borne chemical residues and environmental toxins. Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body.”

[That paper, published this month in the journal Entropy, is HERE.]

It suggests that glyphosate might be causing a lot of the health problems that have been associated with Western diets – including “obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease.”

NATURAL AREAS AND PESTICIDES

Some countries have already moved to limit pesticide use. According to the CA journal article:

“Rather than wait for human carcinogens to be identified, several European countries, including Sweden, Denmark, the Netherlands, and others, have initiated pesticide use reduction policies that have resulted in substantially diminished pesticide use overall. In the United States, a nationwide use reduction policy has met with resistance politically…”

In San Francisco,  the SF Department of the Environment (SF DOE) regulates pesticide use on any city-owned property – including the Natural Areas. It divides permitted pesticides into three Tiers, with Tier III being the least hazardous, Tier II being more hazardous, and Tier I being the most hazardous.

Right now, glyphosate is classified at Tier II. We asked them to consider reclassifying it as Tier I on the basis of the article in the American Cancer Society journal, and the possibility that glyphosate is an endocrine disruptor. SF DOE refused.

Meanwhile, as the graphs above show, NAP’s use of herbicides has been growing, no matter how you calculate it.  We ask that the Natural Areas Program stop using any Tier I or Tier II chemicals in the Natural Areas. Many of these areas are on high ground. Residues could move downhill into residential areas. They are open spaces where people – including kids – wander, where pets explore, and wildlife lives.  The health risks to everyone are not worth the questionable victories against plants NAP dislikes.

Sutro Forest Herbicide Projections: Bad News for San Francisco’s Natural Areas?

pesticide use number n vol 2008 to 2012Our regular readers will know that we’ve been following the Natural Areas Program’s (NAP) increasing use of pesticides with some dismay. When we got the 2012 data, it was clear that pesticide use had increased by every measure. That story is HERE: Natural Areas Program Uses Even More Pesticides.  Imagine our concern, then, when the Sutro Forest Draft Environmental Impact Report outlined the amounts of pesticides they contemplate using as part of their destructive plan for the forest on Mount Sutro Open Space Reserve. It’s between 5 and 15 times the amount that NAP is using on all its properties. (Sutro Forest has been essentially pesticide-free since 2008.)

NAP’s own DEIR on the Significant Natural Resource Areas Management Plan – SNRAMP or Sin-Ramp – doesn’t quantify the amounts of pesticides it would need to implement its plan. But the Sutro Forest numbers suggest that we’re looking at multiples of their existing levels of use.

Like many, we’re very concerned about this pesticide use. It’s bad for human beings, for pets, for the environment and for wildlife. We recently came upon this excellent article by David Stang. It’s reprinted here with permission. Of the pesticides reviewed, NAP is using Milestone VM, Roundup (or Aquamaster, with the same active ingredient – glyphosate), and Imazapyr.  (Note: All the illustrations are ours.)

————————-

THE LAST ROUNDUP

By David Stang

pacific chorus frog - public domain image (NPS)Recently an agricultural services firm was retained to spray the herbicide Milestone VM on nearby pastures to kill clover and other broadleaf plants. After spraying, rains washed some of the herbicide downhill from the pastures into the ponds below. Before the spraying, the ponds were full of tadpoles. A few days after spraying, there were no tadpoles in the ponds examined.

Because none of the tadpoles had legs before the spraying, they could not have developed into adult frogs and walked off. Nor could any predator have managed to get every single one of them. And a “control group” — waterways not affected by pasture runoff — still had the tadpoles they had before this spraying. Adult frogs may have been killed as well – the evenings at the ponds after spraying were much quieter than just prior to the spraying.

We could suspect that pasture runoff of Milestone VM into our ponds is the culprit. A literature search confirms this hypothesis (see below).

Studies have shown that herbicides and pesticides may have both direct and indirect effects on tadpoles:

  • Very, very low concentrations of pesticides and herbicides have been found to be a major factor in high levels of deformities in frogs and tadpoles1, and studies have shown that herbicides such as Roundup cause DNA damage in tadpoles.2
  • Very low concentrations may kill tadpoles and frogs in just one day.3
  • Those that are not killed outright by herbicides may die of delayed effects. Malathion, for instance, in very low doses destroys zooplankton that eat algae that floats in the water. With the zooplankton gone, the algae grew rapidly and prevented sunlight from reaching the algae at the bottom of the pond, which tadpoles eat. Some tadpoles then starve to death.4
  • Tadpoles that do not starve will mature slowly, or grow so slowly that they may not reach maturity.5
  • If tadpoles reach maturity, and become adult frogs, herbicides may weaken their immune systems, leaving them susceptible to chytrid fungus infections.6

The known dangers of herbicides for frogs and toads is acknowledged by the National Park Service which, for Yosemite National Park, required that “Herbicides will not be applied within 750 meters (2,500 feet) of known breeding habitat for the Yosemite toad.”7

Where pasture runoff flows into streams, ponds, or even ditches, the use of herbicide or pesticide in our pastures should be suspended until the dangers of any proposed substance can be carefully evaluated.

Herbicides that are known to be toxic to wildlife include Milestone VM, Roundup, Powerline and Arsenal, and Tordon K. It seems likely that all herbicides are toxic to wildlife.

2013-03-14 (2)Milestone VM

Milestone VM contains the active ingredient aminopyralid.

Aminopyralid dissolves very easily and is persistent in water. It has high leachability and mobility. It is toxic to algae, oysters, aquatic plants8, fish, honeybees and earthworms9.Aminopyralid is also on PAN International’s List of Highly Hazardous Pesticides10.

Recently aminopyralid was at the center of public and media attention in the United Kingdom. Gardeners discovered that using manure from animals that grazed on or were fed hay from aminopyralid-sprayed roadsides caused their garden crops to fail or develop abnormally. In fact, the University of Minnesota Extension Service describes this problem in their fact sheet, “Use Caution When Harvesting and Feeding Ditch Hay.”11

Aminopyralid is of concern to vegetable growers as it can enter the food chain via manure which contains long lasting residues of the herbicide. It affects potatoes, tomatoes and beans, causing deformed plants, and poor or non-existent yields. Problems with manure contaminated with Aminopyralid residue surfaced in the UK in June and July 2008, and at the end of July 2008 Dow AgroSciences (the manufacturer of Milestone) implemented an immediate suspension of UK sales and use of herbicides containing Aminopyralid. A company statement explained: “Consistent with its long-standing commitments to product stewardship, and in cooperation with United Kingdom regulators, Dow AgroSciences has asked the Pesticide Safety Directorate (PSD) for a temporary suspension of sales and use of herbicides containing aminopyralid. The suspension shall remain in place until assurances can be given that the product and subsequent treated forage and resultant animal wastes will be handled correctly.”12

If it is unsafe to eat vegetables raised with manure from pastures treated with Milestone, how safe can it be to eat plants that themselves have been treated with Milestone? Are the horses in treated pastures safe?

Of concern to all is the 2005 claim by the EPA that “There are no acute or chronic risks to non-target endangered or non-endangered fish, birds, wild mammals, terrestrial and aquatic invertebrates, algae or aquatic plants”13, despite the fact that the EPA report cites studies such as “Acute Toxicity to Larval Amphibians Using the Northern Leopard Frog, Rana pipiens, as a Biological Model.”

Even if Milestone/aminopyralid were safe for tadpoles, it would only be when applied at recommended doses to non-sloping land. The recommended dose is just 7 fluid ounces per acre, according to the EPA.14

Roundup

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Other commonly used herbicides also put wildlife at risk. Roundup, for instance, kills birds, fish, tadpoles, bees, worms – at least 76 different species.

Roundup contains glyphosate as its active ingredient. Glyphosate dissolves readily and is very persistent in water. It is toxic to birds, fish, honeybees and earthworms15and is listed by PAN International as a highly hazardous pesticide16. Its maker, Monsanto, was convicted of false advertising in 2007 for its claim that Roundup was “practically non-toxic” to mammals, birds, and fish.17 Some of the scientific evidence for the safety of Roundup comes from studies with falsified results.18

The U.S. Environmental Protection Agency (EPA) has identified 76 species that may be endangered by glyphosate use19.An important study has shown that glyphosate kills tadpoles20. A University of Pittsburgh biologist has found that the herbicide caused an 86-percent decline in the total population of tadpoles.21A recent study found that even at concentrations one-third of the maximum concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.22

Out of concern for these issues as well as human health, European Union member states are warned that they “must pay particular attention to the protection of the groundwater in vulnerable areas, in particular with respect to non-crop uses,” when using glyphosate23.According to EPA, short-term exposure to elevated levels of glyphosate may cause lung congestion and increased breathing rates and, in long-term exposure, kidney damage, reproductive effects24. Glyphosate has also been associated with Parkinson’s disease.25Increased adverse neurologic and neurobehavioral effects have been found in children of applicators of glyphosate26.Female partners of workers who apply glyphosate are at higher risk of spontaneous abortion27.Some glyphosate-based formulations and metabolic products have been found to cause the death of human embryonic, placental, and umbilical cells in vitro even at low concentrations. The effects are not proportional to glyphosate concentrations but dependent on the nature of the adjuvants used in the formulation.28

Powerline and Arsenal

glen canyon imazapyr under treesPowerline and Arsenal contain the active ingredient imazapyr, which has been listed for withdrawal from the market in the European Union.29It is highly soluble and moderately persistent in water. It is also toxic to fish, honey bees and earthworms30. Imazapyr’s potential to leach to groundwater is high and surface runoff potential is high31.One field study found that between 40 and 70 percent of applied imazapyr leached down to the lowest depth tested32. If imazapyr leaches down below 18 inches (where microbial activity is limited) the chemical can be expected to persist for more than a year33.EPA cautions that imazapyr-based herbicides can place terrestrial and aquatic plant species in “jeopardy.”34

Tordon K

Tordon K has the active ingredient picloram. Picloram is a persistent herbicide that is highly leachable, very soluble in water and does not degrade readily in water. It is toxic to birds, fish, honeybees and earthworms. It has also been identified as an endocrine disruptor3536and is on PAN International’s List of Highly Hazardous Pesticides37.EPA’s evaluation of picloram states, “eventual contamination of groundwater is virtually certain in areas where residues persist in the overlying soil. Once in groundwater, the chemical is unlikely to degrade even over a period of several years.”38

Anyone who would advocate against herbicides will face the might of organized agriculture, the lawn care business, and even the EPA. A paper on the Environmental Safety of Forestry Herbicides39, for instance, argues that the herbicides named in the present article – imazypyr, glyphosate, and picloram, as well as many others – are “less toxic than caffeine”, “less toxic than aspirin” and “are safe for animals because the biochemical basis for toxicity does not exist.” The article goes on to claim “herbicides positively affect water quality by reducing sedimentation rates.”

I’d like to think that we could send herbicides to the last roundup. But it seems more likely that herbicides will continue to send wildlife to that roundup.

End Notes

1 Fellers G, Sparling D; Wafting Pesticides taint far-flung frogs, Environmental Toxicology and Chemistry, 2001; Science News, Dec 16,2000, Vol 158, p391; Science News, 9-5-98,p150.

3 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

4 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

10 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_090116.pdf

11 University of Minnosota Extension Service, “Use Caution When Harvesting and Feeding Ditch Hay.” http://www.extension.umn.edu/distribution/livestocksystems/components/M1197.pdf

15 Pesticide Properties DataBase http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

16 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_1101.pdf

18 On two occasions the United States Environmental Protection Agency has caught scientists deliberately falsifying test results at research laboratories hired by Monsanto to study glyphosate. [(US EPA Communications and Public Affairs 1991 "Note to correspondents" Washington DC Mar 1)] [(US EPA Communications and Public Affairs 1991 Press Advisory. "EPA lists crops associated with pesticides for which residue and environmental fate studies were allegedly manipulated". Washington DC Mar 29)] [(U.S. Congress. House of Representatives. Com. on Gov. Oper. 1984. "Problems plague the EPA pesticide registration activities". House Report 98-1147)] In the first incident involving Industrial Biotest Laboratories, an EPA reviewer stated after finding “routine falsification of data” that it was “hard to believe the scientific integrity of the studies when they said they took specimens of the uterus from male rabbits”. [(U.S. EPA 1978 Data validation. Memo from K Locke, Toxicology Branch, to R Taylor, Registration Branch. Washington DC Aug 9)] [(U.S. EPA Office of pesticides and Toxic Substances 1983, "Summary of the IBT review program". Washington D.C. July)] [Schneider, K. 1983. Faking it: The case against Industrial Bio-Test Laboratories. The Amicus Journal (Spring):14-26. Reproduced at [http://planetwaves.net/contents/faking_it.html Planetwaves] ] In the second incident of falsifying test results in 1991, the owner of the lab (Craven Labs), and three employees were indicted on 20 felony counts, the owner was sentenced to 5 years in prison and fined 50,000 dollars, the lab was fined 15.5 million dollars and ordered to pay 3.7 million in restitution. [(US Dept. of Justice. United States Attorney. Western District of Texas 1992. "Texas laboratory, its president, 3 employees indicted on 20 felony counts in connection with pesticide testing". Austin TX Sept 29) ] [(US EPA Communications, Education, And Public Affairs 1994 Press Advisory. "Craven Laboratories, owner, and 14 employees sentenced for falsifying pesticide tests". Washington DC Mar 4)] [http://www.mindfully.org/Pesticide/Roundup-Glyphosate-Factsheet-Cox.htm Glyphosate Factsheet (part 1 of 2) Caroline Cox / Journal of Pesticide Reform v.108, n.3 Fall98 rev.Oct00 ] ] Craven laboratories performed studies for 262 pesticide companies including Monsanto. — http://dic.academic.ru/dic.nsf/enwiki/56554

19 U.S. Department of Agriculture, Forest Service, 1997. Herbicide Information Profile: Glyphosate

20 Hileman, B. (2005) Common herbicide kills tadpoles. Chemical & Engineering News. Washington 83(15):11

22 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Findshttp://www.sciencedaily.com/releases/2005/08/050804053212.htm

23 European Commission, Health & Consumer Protection Directorate-General. Directorate E – Food Safety: plant health, animal health and welfare, international questions. E1 – Plant health. Glyphosate. 6511/VI/99-final. 21 January 2002.

25 Barbosa et al., 2001. Parkinsonism after glycine-derivative exposure. Mov. Disorder. 16: 565-568.

26 Garry et al., 2002. Birth defects, season of conception and sex of children born to pesticide applicators living in the Red River Valley of Minnesota, USA. Environ. Health Perspect. 110: 441-449.

27 Arbuckle et al., 2001. An exploratory analysis of the effect of pesticide exposure on spontaneous abortion in Ontario farm population. Environ. Health Persp. 109: 851-857.

28 Benachour Nora; Gilles- Eric Séralini (December 23, 2008). “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells”. Chemical Research in Toxicology 22: 97. doi:10.1021/tx800218n. http://pubs.acs.org/doi/abs/10.1021/tx800218n%5D.

29 “Pesticides coming off EU market. Pesticide News No. 60, June 2003, pp. 8-10.

31 Washington State Department of Transportation. Imazapyr – Roadside Vegetation Management. Herbicide Fact Sheet. February 2006.

32 Vizantinopoulos, S. and P. Lolos. 1994. Persistence and leaching of the herbicide imazapyr in soil. Bull. Environ. Cont. Toxicol. 52:404-410.

33 “Ecological Risk Assessment of the Proposed Use of the Herbicide Imazapyr to Control Invasive Cordgrass (Spartina spp.) in Estuarine Habitat ofWashington State.” Department of Agriculture, Olympia, WA 98504. Prepared by ENTRIX Inc., Olympia, Washington. Project No. 3000901, October 30, 2003.

34 USEPA. Office of Pesticide Programs. 1987. EEB Review of 241-EEO. Washington, DC (April 21 & June 1)

35 Endocrine disruptors interfere with the endocrine glands that produce hormones that guide the development, growth and reproduction in people and animals. Disruption of hormones, which guide growth, development, intelligence, and reproduction, can result in irreversible harm, which is passed on to future generations.

36 Pesticide Properties Database http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

37 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/gbr.htm

38 U.S. EPA. Prevention, Pesticides, and Toxic Substances. 1995. Reregistration eligibility decision (RED): Picloram. Washington, D.C., Aug.

39McNabb, Ken. Environmental Safety of Forestry Herbicides http://www.aces.edu/pubs/docs/A/ANR-0846/

Glen Canyon: Nesting Season, Habitat Destruction, and Pesticide

The nesting season is in full swing, now, and pictures of baby owls and other baby wildlife are beginning to hit the Internet. Glen Canyon is – or has been – an exceptionally good nesting area, with many kinds of habitat, undisturbed thickets for protected breeding spots, and easy access to food and water.

But the Natural Areas Program doesn’t appear to have registered this. We reported on this last year, and they’re doing it again – breaking down thickets and spraying pesticides, despite the obvious risk of disturbing birds and other wildlife. An observer wrote us: “… a group of four individuals with picks and axes are at it in the mid section of the park.”

Spraying pesticides in Glen Canyon March 2013

“This is way back in the park which we had hoped to keep wild. They’ve already removed much of the understory and now they are poisoning. “

It’s no use to ask the staff to look out for nests. Birds, especially small ones, hide their nests as thoroughly as they can. They’re difficult to find even if you know what to look for. Some are very tiny: a hummingbird’s nest is the size of a quarter. Even with the best will in the world, these workers would find it impossible to guard against disturbing or destroying nests or dens.

2013-03-14 (2)

What is it?  A tank mix of Aquamaster and Milestone, apparently. Aquamaster is glyphosate, the same stuff that goes in Roundup. And Milestone is the pesticide that doesn’t go away (and is therefore banned in New York, which fears it will get into its waterways). The Natural Areas Program has steadily increased its use of pesticides since 2009, and Milestone use has increased particularly sharply in 2012.  It looks like 2013 is off to a good start.  (For more information about the pesticide applications and the pesticides themselves, read SF’s Natural Areas Program Uses Even More Pesticides.)

SF’s Natural Areas Program Uses Even More Pesticides

The 2012 final data are in, and it’s official: In 2012, the Natural Areas Program (NAP) used more pesticides than in any year from 2008 (the first year for which we have data provided by the City). This is true by any measure, as the graphs below indicate. [Note: Graph edited to indicate units]

[Edited to Add: NAP also used more Tier I pesticide - the most toxic - than the rest of SF RPD areas together. HERE]

pesticide use number n vol 2008 to 2012

Depending on the measure you choose, usage has increased anywhere from 12% to 40% from 2011. It’s between 3 and 4 times the usage in 2008.

THE FEARSOME FOUR AGAIN

What pesticides have they been using?

The same as before: Tier II and Tier I pesticides, defined as more hazardous and most hazardous. (For a detailed discussion of these chemicals, click HERE:  Natural Areas Program’s Pesticides: Toxic and Toxic-er.

  • Aquamaster/ Roundup (Glyphosate). (Tier II)  This is one of the world’s most widely used herbicides, but in vitro research has linked these chemicals to changes to human cells, some of which are of the kind that could cause birth-defects. The EPA is studying whether it is an endocrine disruptor. The fact that it’s widely used gives us little comfort; a different widely used herbicide has just been declared unacceptably toxic to bees.
  • Garlon (Triclopyr). (Tier I) To NAP’s credit, they have reduced the use of this extremely toxic herbicide since the peak in 2010. It’s a Tier I pesticide, and associated with numerous diseases in humans, and potential kidney impacts on dogs.
  • Polaris (Imazapyr). This Tier II herbicide is a problem because it spreads (it doesn’t stay where it’s applied) and it persists (it doesn’t break down easily). It’s a relatively new herbicide, and we don’t know quite what it does – though its breakdown product  is neuro-toxic. It’s banned in Europe, and neighbors are fighting against its use in privately owned forests in Northern California.
  • Milestone (Amino-pyralid). This Tier I toxic chemical sticks around even more persistently than imazapyr. It was banned for a time in the UK because if animals eat and excrete it, the excreta are still poisonous – as is the manure made from it. It’s banned in New York state because they aren’t sure it won’t poison the water. NAP’s used it in Lake Merced, Pine Lake, Glen Canyon, and Mount Davidson, all of which are areas where water contamination is possible. [Edited to Add: In 2013, Milestone was reclassified as a Tier II chemical.]

BAD FOR PEOPLE, BUTTERFLIES AND FROGS

Of course these chemicals are not good for people, and one would think that in a city that is so conscious of organic and green produce and products, wild lands would be one area that we’d try to keep organic. Not so. We even found evidence of blackberry bushes being sprayed – during the fruiting season when children and adults, birds and animals feast on the bonanza of berries.

Recent research indicates that both triclopyr and imazapyr are potentially toxic to butterflies – but NAP continues to use both Garlon and Polaris on Twin Peaks, where NAP are also struggling to re-introduce the endangered Mission Blue butterfly. Glyphosate is known to be dangerous to amphibians; but NAP uses Aquamaster around Lake Merced, Pine Lake, and in Glen Canyon – all near water-courses.

Finally, we have another problem with this use: it may be glorifying chemical solutions. A few months ago, a “volunteer” in Glen Canyon was found applying an unapproved pesticide to an area near a trail, without posting any notices or keeping any record of amounts or conditions. He believed he was doing a good thing for the environment. We have heard since of many other instances of random herbicide application in Natural Areas.

PLEASE STOP TIER I AND TIER II PESTICIDES IN NATURAL AREAS

Furthermore, the list of plants on which it’s used also keeps expanding. It’s currently around 30, up from under 2 dozen a year ago. Some of the plants being sprayed aren’t on the list of the California Invasive Plants Council or USDA noxious plants lists.

We ask SF Recreation and Parks Dept  to stop using Tier I and Tier II pesticides in the Natural Areas. An escalating use of herbicides is bad for the environment and the people, pets and wildlife using these parks;  sends a damaging message about priorities; and indicates a lack of success.

Glen Canyon: Stealth Herbicide Use

Some time back, we’d posted an article about the puzzling brown spot in Glen Canyon Park, around a rock near a trail. It looked like herbicide use, but regular visitors to the park hadn’t seen the signs SF Rec and Park must post before spraying herbicides. Also, as the picture below shows, it was close to a trail. Both the Natural Areas Program and the Department of the Environment had said there would be no spraying for 15 feet on either side of a trail. We asked them what was going on, and got no answer.

Now we know.

A “volunteer” was spotted spraying the area early one morning.We’d heard anecdotal reports, but this time, an actual incident was reported to us with evidence of unsupervised use of unapproved products without warning notices, and without public records, in a place where pesticides are not supposed to be sprayed.

Rock formation in Glen Canyon Park

These pictures show the pesticide being used in precisely the area we were concerned about.

So in addition to the recorded herbicide use by the Natural Areas Program, there’s unrecorded and unquantified toxins being used in Glen Canyon by sympathizers.

The herbicide in use – at least on this occasion, as far as we could gauge – was Roundup Ready-to-Use Plus.  The product is described on sale websites as not “pet and livestock-friendly.”

It is not on the Department of the Environment’s approved list of pesticides for use on city-owned properties.

WHAT IS ROUNDUP READY-TO-USE PLUS?

This product contains Glyphosate (the main ingredient in all types of Roundup products, which we’ve described in an earlier article). It also contains Pelargonic Acid, which the University of Florida IFAS extension described as “like diquat.”

About pelargonic acid, the Material Safety Data Sheet  (linked here as a PDF) says “Potential for mobility in soil is very high.”  This means it doesn’t stay where it’s sprayed. It moves around.It also says it is slightly toxic to marine organisms – fish and amphibians.

Besides glyphosate and pelargonic acid, Roundup Ready-to-Use Plus contains “other ingredients” that the manufacturer, Monsanto, does not (and is not required to) reveal.

HOW MUCH TOXIN IN GLEN CANYON?

This makes it clear that no one actually knows how much (or what) pesticides are being sprayed in Glen Canyon.

The Natural Areas Program (NAP) sprayed this park at least 6 times in 2011. Clearly, sympathizers are also spraying it with unapproved products not safe for pets and wildlife, without posting warning notices, and without keeping any public records. It’s likely that they are spraying even more frequently than the NAP – which is apparently turning a blind eye to the problem.

The NAP is based on community “stewardship.”  Evidently, this has encouraged its “volunteers” take matters into their own hands and work unsupervised in ways that threaten our environment.

Blackberry and Pesticides

It’s blackberry season!

All over the city, people are picking the delicious berries off the Himalayan Blackberry bushes. At Twin Peaks, we saw someone intently gathering fruit in a small bowl from bushes below Twin Peaks Boulevard. In Glen Canyon yesterday, children were having a great old time snacking on blackberries along the trails.  The Bernalwood blog announced that Blackberry Season Underway in Bernal Heights. (It has some luscious photographs.) Even the Presidio’s Facebook page had a pictures of a berry bush and said, “It’s blackberry season. Did you know that park visitors are allowed to harvest very small quantities of the five-leaved Himalayan blackberry fruits?”

And we found this delightful video of four generations of San Franciscans making blackberry jam with blackberries picked right here in San Francisco. It’s  the little girl’s first year picking blackberries.

[CLICK on the jam-jar graphic to go to Making Jam with Grandma Kathy.]

It’s not just children who eat blackberries off the bushes. Birds and other wildlife do it too. [CLICK HERE for a link to an article with a great picture of a bird on a blackberry bush.]

So we were dismayed when people reported that pesticides are being used on Mt Davidson (again!) and this time, one of the targets is blackberry – right during the fruiting season. The pesticides being used are Aquamaster (glyphosate) and Polaris (imazapyr). [CLICK HERE for information on these herbicides.]

The notice says “The manufacturer’s notice says it is safe to enter area when the spray has dried. Staff will stay on site until spray has dried.”

We’re not sure that leaves the berries safe to eat.

And as for the area being safe once the spray has dried… we’re not sure about that either.

“Is it even possible for the spray to dry on Mt Davidson?” someone asked. Mt D lies within the fog belt, and it doesn’t dry out in the summer. “It is very, very wet in the green zone of Mt. D right now because of the fog. The paths are very muddy and the water is streaming down the road.” The photograph seems to prove the point. It was sopping wet.

How wet is Mt Davidson in summer?

Like this. This is all water from the cloud forest effect, the moisture precipitated from the fog.

Good News, Sad News at Golden Gate Park’s Oak Woodlands

This is another in our Park Visitor series: First-person accounts of visits to our parks, published with permission. (Golden Gate Park has several areas claimed by the Natural Areas Program, collectively called Oak Woodlands. They include the actual Oak Woodlands at the eastern corner of the park, behind Mc Laren Lodge.)

GREAT NEW TRAIL TO A WONDERFUL FOREST

Thank you to the volunteers and Rec & Park staff that built the new trail in Golden Gate Park Oak Woodlands last weekend!  The new trail creates a new trail entrance off Conservation Drive (east) at the corner of JKF and near McLaren Lodge.   Definitely go enjoy the new trail into the enchanting forest with lovely oaks punctuated by towering eucalyptus, pines, acacia, cypress, and other trees and plants.

I found it fascinating when reading the proposed Significant Natural Resource Areas Plan that the native oaks were planted in the 1870’s when the eastern end of Golden Gate was landscaped.  It is amazing that forests and forest wildlife communities thrive on the coastal sand dunes once called “barren” and how the diverse Golden Gate Park forests help make San Francisco livable for people and wildlife.

BUT ALSO PESTICIDES…

I was quite enjoying our walk until I saw a new pesticide warning sign at the Arguello entrance.   Imazapyr will be sprayed sometime between 8/13 and 8/17 for Kikuyu grass and Chilean Mayten (right).  The sign says “spot spray areas” but be aware that past spraying has often been right next to the trail and are often large patches, particularly when spraying grasses.

…AND HABITAT DESTRUCTION

Just as with the Eucalyptus dominated NAP forests in other Natural Areas, almost all the plants under the oaks are non-natives and are being removed by spraying and pulling which often leaves bare ground.  Unfortunately, removing non-natives doesn’t automatically result in natives magically re-appearing.   Even the newly planted native plant gardens around the Natural Areas seem to struggle with getting established in the remnant sand dune soil even when planted with nursery stock, tended, and hand-watered.

I just hope enough thickets and grass is left for the birds and wildlife that need thickets and grass for nesting and food. I look at the missing understory plants and wonder what Anna’s Hummingbirds will eat since much of the self-sustaining flowering plants are going (e.g., ivy, eucalyptus, blackberries, etc.), what grass seeds will the sparrows and finches eat, where will spiders spin their webs, and where will California Quail hide their nests. Even the oak-loving Western Scrub-Jays eat mostly insects and fruit during spring and summer, and only switch to nuts and seeds during fall and winter.

West of Twin Peaks Central Council opposes Natural Areas Program, Part 2: Trees and Pesticides

This article continues the West of Twin Peaks Central Council (WTPCC) letter opposing the Natural Areas Program (NAP). Emphasis has been added.

Click here for the beginning of the letter.

Click here for Part 3, Park Access and Habitat & Wildlife.

TREE REMOVALS

WTPCC opposes NAP plans to remove healthy trees simply because they are non-native or simply to allow more sunlight to reach newly planted, sun-loving natives on the forest floor. We fully support the removal of hazardous trees in our parks, but NAP’s plans go far beyond that.

We are concerned that the actual number of trees removed will be much higher than the 18,500 listed. NAP does not include any trees or saplings less than 15 feet tall in its count of trees to be removed, yet the SNRAMP makes clear that these “smaller” trees or saplings will be cut down along with the taller ones. A 2007 US Forest Service report noted that just over half (51.4%) of the trees in San Francisco are less than six inches in diameter at breast height. This diameter corresponds to a tree less than 15 feet in height. The removal of these smaller trees will significantly amplify the impact of the removal of the taller trees on aesthetics, erosion, and windthrow in natural areas, yet the Draft NAP DEIR did not consider these additional impacts.

WTPCC is concerned that claims in the Draft DEIR that trees cut down will be replaced on a one-to-one basis by native trees are misleading. The SNRAMP makes no promise to replace trees. In particular, the SNRAMP specifically states that the 15,000+ trees removed at Sharp Park will not be replaced since the natural area will be converted to coastal scrub. In addition, there were few native trees in San Francisco before the Europeans settled the area; the climate was too harsh. Native trees do not grow well in the windy, foggy, sandy or rocky soils present in most natural areas. For example, about a decade ago, NAP planted 25 oak trees at Tank Hill to replace 25 trees cut down by NAP. Only 5 of the replacement oak are still alive, and only one of those has grown.

Our concerns about the 1,600 tree removals planned for Mt. Davidson in particular include:

  • Increased erosion from the loss of the trees
  • Increased water runoff during storms and the potential for damage to park neighbors’ property from the water or mudslides

These concerns were not adequately addressed in the DEIR.

WTPCC is also concerned that the DEIR does not adequately address impacts on carbon sequestration and global warming from NAP’s plans to cut down 18,500 trees. A 2007 US Forest Service survey of San Francisco’s urban forest notes that our trees store 196,000 tons of carbon, adding 5,200 tons of carbon to the storage each year. When a tree is cut down, it releases its stored carbon into the atmosphere (as carbon dioxide) as it decays. California State Law requires the state to reduce greenhouse gas emissions;

NAP’s plans seem to be at odds with this goal. In addition, grassland does not store as much carbon as forests of trees, and the DEIR does not adequately address the impacts on this of NAP’s plans to replace non-native trees with native grasses.

HERBICIDES

WTPCC opposes repeated applications of herbicides in natural areas to remove non-native plants. Applications of herbicides in NAP-managed areas have increased by 330% over the last four years (from a total of 26 applications in 2008 to 86 applications in 2011). Applications will continue to rise, since NAP plans to use repeated herbicide applications to kill the roots of the thousands of trees it plans to cut down. The Draft DEIR does not consider impacts from this increase in usage.

We are also concerned about inadequate and incorrect signage by NAP when it applies herbicides in natural areas. For example, a recent sign warned that herbicides would be applied “throughout” McLaren Park, with no more specific information on where other than “throughout.” People walking in the park had two options – continue to walk in the park and risk exposure to herbicides (since you can’t know from the sign exactly where in the park they were applied) or leave the park. This inadequate signage essentially closed access to large areas of McLaren Park for a period of time as people tried to avoid exposure.

WTPCC is also concerned that NAP applies herbicides incorrectly, causing needless exposure and risk to people, pets, and wildlife from unnecessary spraying. For example, in December 2011, NAP posted a sign that it planned to spray a mixture of glyphosate and imazapyr to eradicate cape ivy in Glen Canyon.

However, the California Invasive Plant Council website says spraying to destroy cape ivy must be done in the late spring, when the plant is “photosynthesizing actively but is past flowering, so the active ingredients [in the herbicide] move down with the sugars that are transported to underground storage organs.” The spraying should never have been done in December when it would not be effective. NAP essentially put people, pets, and wildlife at risk of exposure to the herbicide for no reason, and ensured they would have to reapply the same herbicides a second time in the late spring if they want to kill the cape ivy.

It is not enough to say that NAP herbicide applications are approved as part of the SF Integrated Pest Management Ordinance that governs herbicide use by city agencies and are therefore okay, as the Draft DEIR does. The DEIR should study the application records more closely. There are many cases where NAP usage violated IPM rules. For example, NAP applied imazapyr in 2008 and 2009, two years prior to its approval for use by SF IPM in 2011. NAP “sprayed” Garlon in years prior to 2011, even though SF IPM had approved its use only by “dabbing and injection.” NAP sprayed herbicides containing glyphosate near the water at Lake Merced, even though US Fish and Wildlife regulations ban the use of that herbicide (and many others) where there is red-legged frog habitat; Lake Merced is red-legged frog habitat.

(To be continued: Read HERE for Part 3, Park Access and Habitats & Wildlife.)

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