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.

 

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

Glen Canyon Park: One Year after Start of Tree Destruction

The Glen Canyon Playground and Tennis Court Project – as the city is calling this – is nearly completed. In February or March 2014 there will be great fanfare at the completion of this project.

Video update to the Glen Canyon Park tree demolition project

Is it an improvement? Well, there is a new playground at least, but it will not be the same as it was: a steep staircase to the slide and bushes that were at the top – gone. The kids loved those; 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, behind the Rec Center – also gone. The new kids will not know what they missed.

The City Arborist report stated that only 1 tree was truly hazardous, yet 42 trees were destroyed. Equally troubling is the deliberate relocation of tennis courts that destroyed 11 healthy and majestic Eucalyptus guarding the Park’s entrance.

Question: Why was there no attempt to incorporate these trees into the overall design goal that could have been achieved without sacrificing space for the playground and ball field?

Answer: San Francisco taxpayers “purchased” a native plant garden as part of the project and ensured all those “poor suitability / non-native” trees were eliminated.

Functional, Beautiful Ecosystems Should Be Left Alone; the Parks need maintenance, not destruction.

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While you are on YouTube, why not Subscribe to our Channel and keep up with our latest videos by the San Francisco Forest Alliance?

YouTubeChannel-HomePage

YouTubeChannel-HomePage

Merely follow step one or two to Subscribe to our Channel:

Step 1) Do you have a YouTube account? OK then, its easy to subscribe …just click this link http://www.youtube.com/subscription_center? add_user=SFForestAlliance

Any users who are logged into YouTube already need only to click that link and then confirm the subscription and they’ll be added to our Channel.

Step 2) Not on YouTube account yet? All you need to do is watch one of our YouTube videos, click on the”Subscribe” button / link, which is directly across from the Name of our Channel: San Francisco Forest Alliance. Or, the “subscribe” button may appear below the video title.

The last step is to sign in to your Google account or register with a Gmail, YouTube or Google+ account.

Glen Canyon Park: Nine Months after Tree Destruction

Video update to the Glen Canyon Park tree demolition project

San Francisco’s Wreck and Park Department is now calling this “The Glen Canyon Playground and Tennis Court Project“.  This is only a continuation of the mis-information that have been provided as the Glen Canyon Park Improvement Plan (note: they are spending $5,800,000 of the 2008 Park Bond Fund for Glen Canyon “renovations”).

You will be seeing in this new video a bit more than just preparations for a new playground and 2 new tennis courts. The damage to Glen Canyon Park by the city is significant; we thought the project was the “removal and pruning of select trees”, but it is much more than that. And the wonderful children’s climbing tree is now gone; it once stood behind the Rec Center.

Here is a reminder [Beginning of Glen Canyon Park tree destruction] of what was once there. On January 10, 2013 we reported on the start of this demolition project by the city. The grand eucalyptus trees at the Elk Rd entrance, over a century old, were quickly destroyed. Hundreds of other trees in the canyon, the ones the children love and climb in, the ones the birds nest in and bats hide in, the ones that feed the and protect the wildlife of this canyon – all will be gone by the time this project is completed next year.

all the trees in this picture will be gone in a few days

All these trees are gone

Tree 22 with kids

There’s bare ground where this wonderful climbing tree stood

Before tree removal

Before tree removal and so different now

 

Long Lost Manzanita Brings Newfound Problems (Westside Observer re-post)

Editor Notes:
This is a reposting of  an important story about the plan to reintroduce Franciscan manzanita into City park land – and now also private property along Marietta Drive in the Miraloma Park neighborhood. We also want to refer to important background information about the ambiguity of the taxonomy of manzanita.  Click here

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George Wooding

George Wooding

LONG LOST MANZANITA BRINGS NEWFOUND PROBLEMS
By George Wooding

Westside neighbors are concerned a rare manzanita plant will have a profound impact on neighborhood habitats and uses.

franciscan manzanita

Franciscan manzanita

In 2009, a 14-foot wide Arctostaphylos franciscana (Franciscan manzanita) — a plant thought to be extinct in the wild for the last 60 years — was discovered in the Presidio during the 2009 Doyle Drive rebuild. It was deemed to be the last wild Franciscan manzanita and immediately labeled a genetically-unique plant that needed to be saved.

“Does it make sense for over six percent — 318 acres — of City-managed park land to be permanently committed to planting an endangered species that can be readily purchased in nurseries?”

Flash forward to 2013. In just four years, 424 plants genetically identical to the Franciscan manzanita found in the Doyle Drive construction site have been propagated via cuttings, according to Betty Young, director of nurseries for the Golden Gate National Parks Conservancy, who is coordinating the effort.Manzanita habitat

On September 5, 2012 the U.S. Fish and Wildlife Service issued its proposed designation of 11 areas in San Francisco as critical habitat for the endangered manzanita plant. That proposed designation includes part of Mt. Davidson. Critical habitats are places where endangered plants are either known to have existed in the past, or are places that provide what a plant needs to survive.

By June 28, 2013 the Fish and Wildlife Service designated 318 acres in San Francisco as critical habitat for the plant.

Critical Habitat vs. Eminent Domain

One of the new critical area habitats for the manzanita plant includes the area along Marietta Drive facing O’Shaughnessy Hollow all the way down along O’Shaughnessy Boulevard, and includes all of the open space known as Reservoir Lands at Glen Park, which has trails currently accessible on Marietta Drive.

The designation of 3.2 acres of private property directly below Marietta Drive as critical habitat has been controversial. The backyards of 22 homes on Marietta Drive are now designated as critical habitat for the Franciscan manzanita. The government cannot use critical habitat designations to take over or control property rights.

However, at the September 23 West of Twin Peaks Central Council meeting, it was stated that the Fish and Wildlife Service may use “eminent domain” to control the 3.2 acres for possible reforestation. But according to Robert Moler, Assistant Field Supervisor for External Affairs for the Fish and Wildlife Service, “Activities on private lands that don’t require Federal permits or funding are not affected by a critical habitat designation.” In other words, private citizens will still be able to control 100% of their land regardless of a critical habitat determination.

manzanita brush

“Eminent Domain is completely different than a critical habitat designation. Eminent domain is the power of the state to seize private property without the owner’s consent. A critical habitat designation only delineates the best places an organism can survive.”

NAP Clams Up

All of this Mt. Davidson land is controlled by the SF Rec & Parks (RPD). The RPD’s Native Area Plants Department (NAP) will be overseeing the replanting of the Franciscan manzanita throughout this area. Unfortunately, NAP has not met with neighbors to discuss its plans to reestablish the manzanita. Nor has any government agency contacted the neighborhoods about the manzanita. Calls to NAP Director, Lisa Wayne, were not returned.

As with other NAP projects, public access to large areas may become off-limits so that the Francisco manzanita can become reestablished. Neighbors are worried that large sections of Mt. Davidson might be closed to the public for years while the wild Franciscan manzanita is getting established. NAP has been completely silent on whether it will designate open space areas as being off-limits, and for how long.

It cost San Francisco $205,075 to dig up and replant the last remaining wild Franciscan manzanita, including $100,000 to pay for the “hard removal,” $79,470 to pay for the “establishment, nurturing and monitoring” of the plant for a decade after its “hard removal,” and $25,605 to cover the “reporting requirements” for the decade after the “hard removal.”

The Franciscan manzanita is also a commercially cultivated species of shrub that can be purchased from nurseries for as little as $15.98 per plant, and have been available for purchase in nurseries for about 50 years. The plants are propagated by taking cuttings and, therefore, are presumed to be almost genetically-similar.

The last wild Franciscan manzanita may have been found, but it may be a hybrid of the manzanita plants found in nurseries. Recent taxonomic revisions have established Franciscan manzanita as a separate species, based primarily on genetic comparisons, including the fact that Franciscan manzanita has 13 pairs of chromosomes, while its closest relative (A. montana ravenii )  has 26 chromosome pairs.

Manzanita seeds are germinated by fire, but the exact relationship between germination and fire isn’t known. This is why the plant is constantly cloned. The plant also requires full sunlight. How many trees will NAP cut down to provide the Franciscan manzanita with full sunlight?

The Francisco manzanita is listed as an endangered species. The Endangered Species Act listing for the rare bush means anyone who removes or tampers with the plant could face criminal prosecution and fines. The designation also qualifies the plant for federal conservation funds.

Does it make sense for over six percent — 318 acres — of City-managed park land to be permanently committed to planting an endangered species that can be readily purchased in nurseries? How will the Franciscan manzanita be able to survive without fire?

Neighbors need to know what is happening with the 318 acres of San Francisco private and public land that will be used to replant the manzanita, and how the critical habitat determination will impact public open space. RPD outreach to neighborhoods continues to be poor and disingenuous. NAP has stonewalled the public far too long and must be required to meet with Westside neighbors.

by George Wooding, Midtown Terrace Homeowners Association

Update – “Unsuitable” tree removals on Creekside Trail, Glen Canyon Park

On October 24th we reported the planned tree removals along the Creekside Trial (west side of Islais Creek) in Glen Canyon. We are now submitting aftermath photos: the conditions now, after the Glen Canyon Trails project “tree work”.

Background: HORT Science, recipient of Park Bond funding, is used by the Rec and Park Park dept to assess the suitability of  trees located along the proposed trails. Their September 6, 20013 report for Glen Canyon Park is here. In summary they recommended that 30 trees be removed: 26 blue gums, 2 arroyo willows and one each of yellow willow and Monterey cypress. Ten (10) trees were identified as needing to be pruned including 6 arroyo willow, 2 blue gum, one Monterey cypress and one river red gum.

Trails are temporarily closed during the tree cutting

Trails are temporarily closed during the tree cutting

Park and Rec is calling this “…completing hazardous tree mitigation work”  but does not address how these trees could be saved by re-rerouting or narrowing trails, thinning the crowns, pruning and tipping, weight redistribution, limb removal, and cabling or bracing.

Cut stump along Creekside Trail

Cut stump along Creekside Trail

Even healthy eucalyptus trees are rated negatively by HORT and RPD as unsuitable for preservation merely because they are not native and therefore considered invasive.

tree workers cut limb by limb

tree workers cut limb by limb

cut limbs are tied and lowered to the ground

cut limbs are tied and lowered to the ground

Cut Stump along trail to Glenridge Co-Op Nursery School

Cut Stump along trail to Glenridge Co-Op Nursery School

Banana Slug Way - as this trail is known - will be transformed

Banana Slug Way – as this trail is known – will be transformed

A retaining wall is planned along here (steel posts,and wood planks)

A retaining wall is planned along here (steel posts,and wood planks)

A crane was used on Alms Road, (Tuesday, October 29) to take out a tree that had the misfortune of growing in the middle of Islais Creek.  A Blue gum, trunk diameter 50 inches, was deemed a potential hazard (said HORT: “Center of creek. Stands alone. Leaning & bowed E. over Alms Road.” ).

Replacing trees with concrete retaining walls to make a natural area more natural?

Eucalyptus Stump - middle of Islais Creek (did it impeded the flow of creek water? )

Eucalyptus Stump – middle of Islais Creek (did it impeded the flow of creek water? )

A 50 inch diameter Eucalyptus - likely one of the older trees in Glen Canyon Park

A 50 inch diameter Eucalyptus – likely one of the older trees in Glen Canyon Park

Mature trees absorb carbon and make our air cleaner. Dead ones release carbon and add to green house gases. 

Once trees, now logs (easy removal via Alms Road)

Once trees, now logs (easy removal via Alms Road)

Fallen Euchs near Silver Tree day camp

Fallen Euchs near Silver Tree day camp

Some of HORT’s reasons for the decisions to remove selected trees: “poor form & structure”;  “Sharp lean E. over trail”;  “upright but one-sided towards trail”;  “Leans over trail”;  “cracked branches”.

Let’s repair these trees rather than destroy them. It would cost less money and be better for the environment.

"poor form & structure"

“poor form & structure”

"Sharp lean E. over trail"

“Sharp lean E. over trail”

"upright but one-sided towards trail"

“upright but one-sided towards trail”

Ugly stumps left to remind us of how well are Park Bond dollars are being used to destroy our parks.

"Leans over trail"

“Leans over trail”

"cracked branches"

“cracked branches”

Per community requests, Rec and Park will allow the “Ticket Tree” to be a stump. This is a Monterey Cypress stump just west of the trail from the Rec Center to Silver Tree Day camp. They have cut it off higher than just a stump to accommodate popular children’s play with the slot in the tree; children use it as a mail box to deliver
letters to each other.

Are our children being taught by RPD that the best tree is a dead stump?

Ticket Tree before cutting

Ticket Tree before cutting

We did notice a larger than usual cutting of trees near the ball field.  This is how it looked before the recent cuts:

Prior view:  from small ball field

Prior view: from small ball field

And how it looks now.

Current view; from small ball field

Current view; from small ball field

View from Bosworth Street (cuts made for a paved walkway down to field)

View from Bosworth Street (cuts made for a paved walkway down to field)

The city’s Rec and Park Department is “excited to be starting this extensive capital improvement project, funded by the 2008 Clean and Safe Neighborhood Parks Bond and by multiple Habitat Conservation Program grants.”

We, however, are less excited when we observe the tree damage to what was a wonderful, quirky trail on west side of Islais Creek in Glen Canyon Park.

Note that the 2008 parks bond allocated $900,000 of the $5 million Parks Trails Improvement Program
for this Glen Canyon project.  That’s alot of money for ADA compliant pathways, ‘turnpike’ parkways, retaining walls, split rail fences – from Bosworth St, all the way up to Portloa Drive, past the School of the Arts (SOTA).

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Note: Photographs were taken recently, all are accredited to Ron Proctor.

Endangered Manzanita – Reopened Comments until July 29, 2013

six-dollar franciscan manzanita

Franciscan Manzanita – Nursery specimen, six dollars

US Fish and Wildlife Service (USFWS) has reopened the comment period  for its designation of “critical habitat” for an endangered manzanita.

[You can find the Notification HERE]

This designation will likely mean significant access restrictions and possibly other unfortunate effects such as tree-removal and prescribed burns.

The new notice adds new acreage – especially around McLaren Park and Glen Canyon Park (wrongly labeled Diamond Heights) – to bring the total in Natural Areas to 203 acres (of a total of ~1100 acres of Natural Area Program land)

If you wish to comment, you can do so online HERE (look for the “comment now” button on the top right) or mail them a letter. Comments will not be anonymous. If you already sent a comment last time round, you don’t have to re-send it. It’s on record. But if you have additional thoughts, you can certainly send an additional comment.

From US FWS website:

Written Comments: You may submit written comments by one of the following methods:

(1) Electronically: Go to the Federal eRulemaking Portal: http://www.regulations.gov. Search for Docket No. FWS-R8-ES-2012-0067, which is the docket number for this rulemaking.

(2) By hard copy: Submit by U.S. mail or hand-delivery to: Public Comments Processing, Attn: FWS-R8-ES-2012-0067; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, MS 2042-PDM; Arlington, VA 22203.

We request that you send comments only by the methods described above. We will post all comments on http://www.regulations.gov. This generally means that we will post any personal information you provide us (see the Public Comments section below for more information). [That's at the same link.]

BACKGROUND

Some months ago, a specimen of manzanita (arctostaphylos franciscana)  – found during the Doyle Drive project in San Francisco – was declared a federal endangered species.

Though difficult to grow from seed, this manzanita is easy to clone.  You can buy plants originating from cuttings (from a different specimen of the same plant) for about $6.

The details are HERE

US Fish and Wildlife Service is in the process of designating critical habitat for this plant within San Francisco.

If this manzanita, which now has the legal status of a Federally endangered species, is planted in these areas, it will get the same protection as if it occurred there naturally. This will likely mean access restrictions; it could mean the felling of trees because this species needs full sun; and potentially might even require prescribed burns (to allow its seeds to germinate).

We wrote about that HERE.

COMMENT PERIOD REOPENED

US FWS has reopened its comment period. It discovered it was inadvertently using the wrong map, which overstated all the acreages. It’s corrected the acreage in its revised notification. It is currently asking for a total of  197 acres, of which 51 are Federal, 133 are city-owned, and 13 are private.

  • More importantly, the National Parks Service has asked for a reduction in the Federal areas, to protect its restoration efforts for other Native Plants, and also to preserve its historic forests.
  • Meanwhile, SFRPD staff have proposed an additional 73 acres to be designated as critical habitat: 56 acres in McLaren Park (which was not included earlier at all); and an additional 14 acres in “Diamond Heights” (actually, Glen Canyon and the area above O’Shaughnessy Boulevard). It’s also requested the designation of 3 acres of private land in the same area.
  • If this goes through as notified, nearly a fifth of the Natural Areas (203 acres of 1100) will be designated critical habitat for this plant – even though the plant was originally found only in four locations in San Francisco.

WHERE ARE THESE AREAS?

The colored map here broadly indicates all the areas that are to be designated as critical habitat.

Franciscan Manzanita map updated July 2013In more detail, here is the revised map for Glen Canyon. The two areas called “Subunit 9A” and “subunit 9B” are newly added to the proposed designation of critical habitat.

glen canyon updated 1

These are the two maps for McLaren Park. This park was not included in the earlier designation.

mclaren 1 sm mclaren 2 sm

WHAT DOES “CRITICAL HABITAT” MEAN?

By designating “critical habitat” the USFWS says, in essence, that these areas are so important to the conservation of the species that they must not be changed by the Federal government – or by any activity it funds or authorizes.

From the USFWS notification:

Section 3 of the Act defines critical habitat as the specific areas within the geographical area occupied by a species, at the time it is listed in accordance with the Act, on which are found those physical or biological features essential to the conservation of the species and that may require special management considerations or protection, and specific areas outside the geographical area occupied by a species at the time it is listed, upon a determination that such areas are essential for the conservation of the species.

“If the proposed rule is made final, section 7 of the Act will prohibit destruction or adverse modification of critical habitat by any activity funded, authorized, or carried out by any Federal agency. Federal agencies proposing actions affecting critical habitat must consult with us on the effects of their proposed actions, under section 7(a)(2) of the Act.”

If these “endangered” plants are introduced, we can expect that the Natural Areas Program will want to protect them. This may mean:

  • Restricting access (perhaps with fencing);
  • Cut down any trees shading the plants since they require full sun; and
  • Maybe even seek to get permission for prescribed burns, since it’s possible the Franciscan manzanita needs fire to germinate. (This is believed true of the closely-related Raven’s manzanita.)

It will also mean that the area cannot be planted with anything that clashes with the manzanita in its requirements – including large shrubs and bushes (even if native). It will probably mean more pesticide use, to keep other plants from encroaching on the area where they’re trying to grow this one.

WHAT IS THIS PLANT AND IS IT ENDANGERED?

We mentioned before that Franciscan manzanita plants, grown from cuttings of another specimen, have been available in plant nurseries for some 50 years.   This plant, the Doyle Drive manzanita, is presumed to be a different individual of the same species. If so, this is good because it would add a little genetic diversity. However, until someone does a DNA analysis, we cannot tell if it’s true.

  • It could be a nursery plant that someone introduced; the neighboring plants were non-native and very likely deliberately planted. In that case, it will be genetically identical to the others.

  • It could be a cross with another manzanita species. Manzanitas generally hybridize really easily, and some scientists think this is a cross between Franciscan manzanita and arctostaphylos uva-ursi.

It’s complicated with manzanitas. They adapt to any little change in their environment, and they are easily crossed with other manzanita species. As a result, scientists often have to re-define which are species, which are subspecies, and which are mistakenly considered a separate species when they’re not.

WHAT ARE ITS CHANCES?

There’s a closely-related  manzanita species, Raven’s manzanita, that is also as endangered. For over 30 years now – and an estimated $23 million – people have been trying to bring it back. The definition of success would be two generations of plants produced from seed (not cuttings) and some spontaneous populations in the wild. That’s not much of a target to achieve – but it isn’t happening.

So with all the time, trouble, and expenditure – what are the chances of the closely-related Franciscan manzanita succeeding?

Franciscan manzanita

Franciscan manzanita

Franciscan manzanita is now an endangered species

Last week US Fish & Wildlife announced that Franciscan manzanita is now an endangered species. In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive. It was transplanted to an undisclosed location in the Presidio in San Francisco at a cost of $175,000, (or, according to some accounts, $205,000) including an additional annual cost for maintenance. Is this a preview of potential cost of reintroducing this plant throughout San Francisco?

Franciscan manzanita

Although that plant is thought to be the only one of its species existing in the wild—if the Presidio can be said to be wild—it has always been for sale in nurseries.  Yes, the plant given endangered status is considered the same species as those for sale in nurseries, but it is presumed to be genetically unique.  Because genetic diversity is considered important to the survival of a species, the recently discovered plant has been given endangered status.  This makes for an interesting and puzzling lesson on the Endangered Species Act.

CRITICAL HABITATS FOR ENDANGERED SPECIES

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of public land in San Francisco as critical habitat for the Franciscan manzanita.    Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio.  (Details about all the critical habitats are available here.)  Forty of the 318 acres are on private land.  Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

POTENTIAL IMPACTS ON SAN FRANCISCO’S PUBLIC LANDS

The San Francisco Forest Alliance is studying the impact that planting this endangered species might have.  If the proposed critical habitat in these parks is in forested areas, we will undoubtedly object in our public comment because Franciscan manzanita requires full sun which implies that the trees would be destroyed to accommodate the plant.

Sharp Park, Pacifica, CA. Photo by Erica Reder, SF Public Press

We are also concerned about the potential for restrictions on recreational access such as more trail closures and fences needed to protect a fragile, legally protected plant.  The public has had a preview of such loss of recreational assets to protect endangered species at Sharp Park where native plant advocates and their allies have sued to close the golf course, using the Endangered Species Act.

If you are a visitor to or a neighbor of any of these parks, you might want to inform yourself of the potential impact of planting an endangered species with specific horticultural needs.  For example, this is a plant that requires full sun.  Since all of Bayview Hill has been designated as critical habitat and Bayview Hill is heavily forested, you might wonder if this particular park is a good fit for this plant.  Furthermore, this seems to be the only one of the proposed critical habitats in which this plant is not known to have existed historically.

US Fish & Wildlife tells us that the designation of critical habitat for plants does not commit non-federal land owners to reintroduce this endangered plant unless they receive federal funding.  Federal land owners and recipients of federal funding are obligated to consult with US Fish & Wildlife before making any commitments to changes in land use which would not be consistent with the successful reintroduction of the endangered plant.  We assume that the city of San Francisco receives federal funds, so it seems likely that these restrictions would apply to the critical habitats in city parks.  Legal requirements for critical habitat of endangered animals are more rigorous.

MORE INFORMATION AND PUBLIC COMMENT OPPORTUNITY

More information is available from the Sacramento Office of US Fish & Wildlife:

Robert Moler, robert_moler@fws.gov, (916) 414-6606
Sarah Swenty, sarah_swenty@fws.gov, (916) 414-6571

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at http://www.regulations.gov (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn:  FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.

West of Twin Peaks Central Council opposes Natural Areas Program, Part 3: Park Access, Habitat & Wildlife

This article is Part 3 of the West of Twin Peaks Central Council (WTPCC) letter opposing the Natural Areas Program (NAP). Emphasis has been added.

Part 1 is HERE (Opposing the Natural Areas Plan)
Part 2 in HERE (Trees and Pesticides)

Read on for Part 3.

PARK ACCESS

WTPCC opposes NAP plans to restrict access to parks. NAP plans to close 9.2 miles of trails that thread through its natural areas. At our May meeting, Dennis Kern noted that a citywide survey of what San Franciscans want in their parks identified trails and hiking as the number one need. Yet NAP plans to close nearly a quarter of the total length of trails in natural areas (about 40 miles). This would seem to fly directly in the face of what the public said they want in their parks.

In most natural areas, the only thing you can do is walk on a trail. You cannot leave the trail to explore the area, or follow a butterfly, or try to see the bird you hear tweeting. To control access, NAP builds fences. Indeed, in parks where trails in natural areas have been restored recently, fences have been built on either side of the trail to ensure people cannot leave the trail. Natural areas become places where you can “look but not touch.” How can children explore the wonders of nature if they are told repeatedly they must “Stay on the Trail”? This is not what we want for our parks.

When people are restricted to walking only on trails, they lose access to the entire non-trail part of the park. In over half of the parks with a natural area (17 of 31), NAP controls the entire park. That means people have lost access to all but the trails in those parks. In an additional 10 parks, NAP controls over 50% of the land. Put another way, only four of the 31 parks with natural areas have less than 50% of their land controlled by NAP. Access restrictions planned by NAP (“stay on the trail”, fences, and closure of trails) mean that entire neighborhoods will lose access to the vast majority of the parkland in their neighborhood parks. The Draft DEIR does not consider the impacts on neighbors and park users of this level of access restriction in the 27 parks where NAP controls more than half the land.

HABITAT AND WILDLIFE

WTPCC opposes the destruction of existing habitat needed by the wildlife and birds currently living in the parks. For example, NAP has removed underbrush in Glen Canyon that is used by coyotes to hide from people and dogs, and replaced it with grasslands. Unlike the underbrush, the grasslands provide little “cover” for the coyotes or other wildlife living in the natural area.

We are also concerned that some habitat conversion is being done during breeding and nesting season. For example, NAP applied for a “streambed alteration” permit from the California Fish and Game Dept for habitat conversion work to be done near Islais Creek in Glen Canyon. In the application, NAP clearly stated: “It is the policy of RPD’s Natural Areas Program that no new projects will begin during the breeding season (December to May).” Similar commitments were made in the SNRAMP.

However, NAP contractors used chainsaws and herbicides to destroy underbrush habitat in Glen Canyon in March and April, continuing work done sporadically since November 2011. This work took place throughout the breeding/nesting season, despite NAP’s legal commitment to CA Fish and Game and in the SNRAMP to not do habitat work during breeding season. When people informed RPD management about this, during a meeting at McLaren Lodge, Lisa Wayne, the head of NAP, said the work was being done during the breeding/nesting season because the grant for the project was set to expire. In other words, NAP’s decision on habitat conversion in Glen Canyon appeared to be motivated by financial considerations, not by any concerns about the wildlife and birds living there.

To be continued.

Natural Areas Plan: SFFA comments on the DEIR (Pt 4: Restricting Recreation)

One of the failings of the SNRAMP is that it blocks recreational access to the Natural Areas.

Visitors are required to stay on the trails, and just about the only thing you can do is walk along the prescribed trails. No wandering off to look at a flower or bird or butterfly or to perch on a rock in the sun.  In some cases, actual fences are being installed to keep people on the trail. Many miles of “social trails” – the trails that exist only because people use them – are being closed or “relocated.” This increases potential conflict among park users; kids, joggers, walkers, naturalists, dogs, are all squished into the same 5-15 foot path while the acres of “Natural Area” remain unusable.

At the same time, they’re closing off-leash dog-play areas, denying access to popular park features like climbing rocks,  and removing benches because people actually sit on them. The bench beside the Murdered Tree on Mt Davidson  was removed because it was “an attractive nuisance” – it had a great view so people liked to go there.

Read on for more details.

The Significant Natural Resource Areas Management Plan (SNRAMP), which is evaluated by the Draft Environmental Impact Report (DEIR), announces these restrictions on recreational access in the natural areas:

  • SNRAMP “…calls for closing 54,411 feet (10.31 miles) of social trails and creating 5,897 feet (1.1 miles) of new trails, resulting in a new decrease of 48,514 feet (9.2 miles) or 23% of trails in natural areas.”  (DEIR, page 256)
  • SNRAMP restricts all public use in the natural areas to the trails that will remain:  “Public use in all Natural Areas, unless otherwise specified should encourage on-trail use…interpretative and park signs should be installed …to ‘Please Stay on the Trail.’  If off-trail use continues…permanent fencing shall be considered…”  (SNRAMP, page 5-14).   This policy is not mentioned in the DEIR.
  • The DEIR also announces plans to close 19.3 acres (20.3%) of the legal off-leash space in the natural areas, i.e. 16.4% of all legal off-leash space available in all city parkland.  (DEIR, page 257)

Despite these plans to severely restrict all forms of recreation in the natural areas, which are 25% of all city managed parkland in San Francisco, the DEIR concludes that the impact on recreation will be “less than significant.”  The DEIR’s analysis of impacts on recreation was inadequate for the following reasons:

  1. The DEIR did not adequately consider the impacts on recreation and visitor experience caused by the closure of 10.31 miles of trails, including many social trails.
  2. The DEIR did not consider negative impacts on recreation and visitor experience from the Natural Areas Program’s extensive use of fences to force people to stay on trails, nor did it consider impacts from the removal of benches in natural areas.
  3. The DEIR did not consider the negative impact on recreation for park neighbors and users because NAP controls over 50% of the park in 27 out of 31 parks with natural areas (only four parks with natural areas have less than 50% of their total area controlled by NAP).
  4. The DEIR did not adequately consider the negative impact on recreation from the intentional planting of threatened or endangered plant species and reintroduction of legally protected animal species in natural areas where they do not currently exist.
  5. The DEIR did not adequately address the impact on recreation of the closure of off-leash Dog Play Areas, especially the potential closures of up to 80% of all legal off-leash areas on city parkland which the DEIR informs us could be the result of “monitoring” of the remaining off-leash areas.
  6. The DEIR did not adequately address the impact on recreation, aesthetics, and visitor experience of poor maintenance in natural areas.

1. TRAIL CLOSURES

As acknowledged in the DEIR, a 2004 Recreation Assessment conducted for the Recreation and Park Department reported that the number one recreational facility need was more trails. Of the residents surveyed, 67% reported participating in walking or running, the highest percentage for any of the 26 activities listed in the Assessment. People want more trails, not less.

According to RPD General Manager Phil Ginsburg, the majority of trails in San Francisco city parks are located in the natural areas controlled by NAP (private conversation, June 1, 2012; he said this when asked to explain why the “trail restoration” part of the 2008 Clean and Safe Neighborhood Parks Bond was restricted to trails in natural areas). Thus, the SNRAMP’s proposed closure of 23% of the total length of trails in natural areas marks a significant decrease in the length of trails available to the public systemwide, not just in the natural areas. There is simply not enough trail mileage in non-NAP parks to adequately replace the mileage lost in the natural areas. Thus the trail closures will have a more significant negative impact on the majority of San Franciscans who want more trails on which to walk or run.  This aspect of the trail closures was not mentioned in the DEIR.

By closing off the areas currently accessed by the trails that will be closed, the SNRAMP will reduce the variety of experiences park users can have (fewer different areas to see). With less mileage available to walk, the closures will also discourage people from taking longer walks. Neither of these impacts was considered in the DEIR.

Many, if not most, of the trails scheduled for closure are “social trails,” trails created by park users, not by park staff. There is usually a reason people create social trails; they prefer to take a more direct, faster, or more scenic path from Point A to Point B than the path RPD staff have told them they should take.  Frequent visitors are the ones who create social trails by walking off an official trail time and time again. People new to a park will likely stay on official trails; they don’t know where else to go. The closure of social trails will therefore have a greater impact on people who walk frequently in the parks, degrading their experience of the park by forcing them to walk in places they clearly would rather not.

When the University of California at Santa Cruz opened in the 1960s, administrators paved few paths between the colleges. They chose to wait to see what paths the students “naturally” created on their own to get from one place to another, and then paved the social trails that resulted. The social trails became the official trails. NAP has taken the opposite approach, deciding where people will be allowed to walk with little, if any, public input.  And when the public has expressed a desire for something different than what NAP wants (by voting with their feet and creating a social trail), the response is to destroy the social trail. NAP is working at cross-purposes to the majority of San Franciscans who want more trails, and who try to show NAP where they want those trails to be when they create social trails.

Social trails also spring up when people want to enter or leave a park at a location where there is no “official” trail that will allow them do so. For example, over the years, people created a social trail at the northwestern corner of Grandview Park. The only “official” park access comes from trails on the eastern and southern sides of the park. To get to the official trails, people living on the north and western sides of the park are forced to walk in the street that surrounds the park, an option they clearly didn’t like since they created a trail to the top of Grandview that began in the park’s northwest corner. The recent closure of the social trail at Grandview by NAP has made it harder for the people who live north and west of the park to access it. The DEIR did not address the loss of accessibility to parks by the closures of some social trails.

Erosion can be a problem with social trails, but the response should be to mitigate erosion where it occurs, not to close the trail. The DEIR did not consider mitigations to these erosion problems other than closure.

2. MORE FENCES AND FEWER BENCHES

“Stay on Designated Trail” Billy Goat Hill

The DEIR does not address the impacts on recreation and visitor experience of being restricted to the trails in the natural areas.  Being restricted to trails prevents many different types of recreation.  Visitors can’t spread a blanket on the ground and have a picnic or sunbathe while reading a book.  Families can’t play ball or Frisbee, fly a kite or a model airplane on a trail.  Being confined to a trail essentially prohibits many other forms of recreation.  Signs have been erected in the natural areas to inform the public that they are confined to the trails.  The DEIR makes no mention of this policy or the restrictions it imposes on the recreational preferences of park visitors.

Fences have been erected by NAP alongside trails to enforce this restriction.  With fences in place on either side of a trail, a child is physically prevented from exploring plants and bugs on the ground just off of the trail, or following a butterfly or moving to see the bird she can hear calling.  Fences, no matter how attractive they are, create a “look, Don’t Touch” museum-like feel to the park.  That is not what most people want in their neighborhood parks.

Where trails have recently been “restored” in natural areas, NAP has erected fences on both sides of the trail, to force people to stay on the trails.  These recently completed projects are a preview of the fences that the public can expect to be installed in all the natural areas as SNRAMP is implemented over its 20-year lifespan.

Grandview, May 2012

Corona Heights, May 2012

These are not temporary fences. They will remain in place to keep people from straying off the trail for years to come. Putting a fence on both sides of a trail creates a “cattle chute” feeling that many people find unappealing. Their park experience is seriously degraded by the presence of these fences. The DEIR does not address the issue of impacts of permanent or semi-permanent fences on recreation, nor does it address the impact on visitor experience of creating “cattle chute” trails in neighborhood parks.

When all recreational users are confirmed to a trail, it creates unnecessary conflicts between different user groups.  When joggers, dogs being walked on 6’ leashes (as allowed by law), bicycles, birders seeking quiet, are all confirmed to the small space of a fenced trail, conflicts are inevitable.  These conflicts are mitigated, if not avoided altogether, by giving people the option of stepping off the trail to accommodate other park visitors.  Of all the negative impacts of the Natural Areas Program, perhaps the most devastating has been the increased conflicts it has caused in our parks.  Park visitors who have co-existed in peace for generations are now pointing fingers at one another, blaming one another for the loss of their recreational liberty.

NAP has a history of removing benches from areas under its control. For example, a bench on an overlook at Mt. Davidson, one of only two benches in the park, was recently removed by NAP. There was nothing wrong with this bench.  It was apparently removed because it was perceived by NAP staff to be detrimental to the native plants that grow in that area.  There is now no place to sit (except on the ground) to either rest or reflect while looking at the view. This is a particular hardship for seniors and others with more limited mobility, who now have no place to sit after a strenuous uphill hike.  Despite park neighbors’ and users’ pleas to replace the bench, NAP has so far refused to do so. The lack of benches or places for people to rest without having to sit on the ground impacts all recreational users of the parks, even those who only want to walk on trails.

The final EIR must acknowledge the SNRAMP policy to confine all recreational access in the natural areas to fenced trails.  This restriction has a significant impact on recreation in the parks of San Francisco and it should be recognized as such by the final EIR.

3. NAP CONTROLS ENTIRE PARKS

In over half of the parks with natural areas (17 of 31 listed in Table 5 of the DEIR), NAP controls the entire park. Entire parks have become essentially single-use parks – natural areas only. In an additional 10 parks, NAP controls over 50% of the park. In only four parks does NAP control less than half of the park.

For those parks in which NAP controls the entire park, there are no recreational uses allowed in the entire park other than walking on a trail (Bernal Hill is the one exception, with off-leash dog walking allowed in the nearly half of the park that is designated as MA-3). Parents hoping to play catch with their child must find another park in which to do so. People wanting to sit on a blanket in the sun must go somewhere else. When you add in the parks with more than half of their land controlled by NAP, 87.5% of parks with natural areas in them will have significant restrictions on access and recreation. The final EIR must consider this impact on recreation and access.

Within all the natural areas, more than half of the land (57%) is designated as MA-1 or MA-2. These are the management zones with the most severe restrictions on recreation. In 7 parks, all of the land in the natural area is designated as MA-1 or MA-2. These parks will see even more significant impacts on access and recreation than parks with at least some of their land designated as MA-3. Recreation restrictions from different management zones, and how much of a park is made up of each zone, must be considered in the final EIR.

In some cases, the parks completely controlled by NAP do not have non-NAP parks close by. Thus people who want a non-NAP park experience (for example, to play catch with their children, friends or pets) will be forced to go to another park outside of their neighborhood. This will force many into their cars to drive to a non-NAP park. This increase in automobile usage and its attendant increases in pollution and global warming effects are not addressed in the DEIR.

4. PLANTING AND/OR REINTRODUCING THREATENED OR ENDANGERED SPECIES

In the SNRAMP, NAP expresses its intent to plant threatened or endangered species throughout the natural areas, including many places where they are not currently found. The mere presence of these species triggers a number of additional protections and access restrictions required by the federal Endangered Species Act and similar state and local laws  The intentional planting of legally protected species where they are not currently found makes restrictions on recreational access (indeed all access) a fait accompli. Once the plant is in the ground or the animal is known to exist, it MUST be protected and recreational access MUST be restricted.

We have two specific examples of the consequences of reintroducing endangered species to our parks.  In the case of Sharp Park, two endangered species of animal are known to exist.  To our knowledge, these animals were not reintroduced by humans.  The DEIR proposes to reconfigure the golf course to accommodate those legally protected species.  The scale of that project is described in detail by the DEIR.  We can’t imagine how much this project will cost to implement.  However, despite the scale of this monumental effort, San Francisco is being sued by organizations which do not believe that the proposed accommodations are adequate and therefore violate the Endangered Species Act.  These organizations demand that the golf course be closed entirely and that all recreational access be confined to “viewing zones” behind fences.  Essentially, they want the entire 411 acre park turned over to the two endangered species.

The effort of the Natural Areas Program to reintroduce the endangered Mission Blue butterfly to Twin Peaks is a more clear-cut example of the potential for the implementation of SNRAMP to eliminate recreational use of San Francisco’s parks, because the butterfly did not exist there prior to the efforts of the Natural Areas Program to reintroduce it.  In other words, the reintroduction was a discretionary act.  The Natural Areas Program is willfully subjecting Twin Peaks to the potential to be closed to the public.  The federal recovery plan for the Mission Blue previews these restrictions:

“Recreational impacts pose a substantial threat to mission blue butterfly habitat…One of the contributing factors to the apparent extirpation of this butterfly on Twin Peaks is heavy recreational use by off-trail hikers, and motor-bike activity all of which are prohibited.”

SNRAMP informs us that the Natural Areas Program intends to reintroduce the endangered Mission Blue butterfly in McLaren Park and Bayview Hill.  It is, however, silent about what recreational access restrictions may be required to support the population of a legally protected species.

In its section on Recreation (p. 252), the DEIR says that the Notice of Preparation Scoping process identified several concerns about recreation, including: “Effects of the introduction of endangered/threatened species on recreational opportunities, public access, and the administration of local public lands.” Despite this acknowledgment, there is no discussion of impacts on recreation caused by intentional planting of sensitive species where they are not currently found.

The final EIR must acknowledge that the Natural Areas Program intends to reintroduce legally protected species of plants and animals to the Natural Areas.  It must inform the public of what recreational access restrictions will be required to accommodate those species.  When the loss of recreational access is anticipated, the final EIR must mitigate for those impacts by providing commensurate recreational opportunities in San Francisco.

5. DOG PLAY AREA (DPA) CLOSURES

The DEIR does not adequately consider impacts on off-leash recreation from the SNRAMP. The DEIR addresses only the impacts on remaining DPAs, and on recreation, of the immediate closure of 16.4% of the total legal off-leash space in city parks once the SNRAMP goes into effect.  However, the DEIR concludes that impacts of these closures on remaining DPAs, recreation, people driving to other DPAs, etc., will be minimal.

The SNRAMP makes clear that NAP will monitor DPAs in four parks – McLaren, Buena Vista, Bernal Hill, and the Golden Gate Park Oak Woodlands – where DPAs are located either within or adjacent to natural areas. These DPAs, combined with the one scheduled for closure at Lake Merced, constitute roughly 80% of the legal off-leash space in all city parks. SNRAMP also makes clear that if NAP claims the monitoring shows impacts on theses natural areas from the dogs, the DPAs will be closed.

In other words, initial closures of dog play areas will be 16.4% of all dog play areas in San Francisco, but SNRAMP announces the potential for 80% of all dog play areas to be closed in the future.  Since no evidence is provided by the DEIR that any damage has been done by dogs in the dog play areas that are being closed immediately, no evidence is likely to be provided to close most of the dog play area that would remain after the immediate closures.

In fact, in the one dog play area which will be closed entirely and immediately, both SNRAMP and the DEIR say that use of this area by visitors with dogs is minimal:  “…the DPA at Lake Merced is not heavily used…” (DEIR, page 258)  One wonders what the justification is for closing this DPA if it is not heavily used and no evidence is available that damage has been done by dogs.

The DEIR states that it cannot analyze the impacts of possible GGNRA closures because they have yet to be finalized. However, we know the amount of off-leash areas in the GGNRA proposed for closure in January 2011:  90% of existing off-leash space on GGNRA lands have been proposed for closure. The final EIR should analyze the cumulative impacts of the maximum amount of closure proposed by both SNRAMP and the GGNRA. We saw on “Tsunami Friday” what those impacts could be. The GGNRA closed both Fort Funston and Ocean Beach to all visitors on the morning of Friday, March 11, 2011 because of concerns that a tsunami triggered by a major earthquake in Japan would strike the coast. On Tsunami Friday, a Recreation and Park Department staff member counted over 200 dogs at once in the Pine Lake DPA at 10 am, ten times more dogs than on a normal weekday (usually about 20 dogs at any one time), and more than three times the maximum number of dogs normally seen on busy weekends (about 60 dogs). This example graphically illustrates the potential impact on remaining DPAs of significant closures of off-leash space. Forcing so many more dogs into remaining DPAs day after day will undoubtedly lead to serious degradation of those remaining DPAs thereby creating the conditions that would justify closure in the future.

Without providing any analysis, the DEIR concludes the cumulative impacts of closure of off-leash areas by the GGNRA and those proposed by SNRAMP are “significant and unavoidable.”  So, in this rare instance in which the DEIR acknowledges significant impact on the environment and on recreational opportunities in San Francisco, it gives itself a free pass:  “It’s unavoidable.”  We beg to differ.  The final EIR has options that must be considered.  The obvious and responsible thing to do is to NOT close any dog play area if there is no evidence that dogs are harming those areas.

The DEIR repeatedly justifies the exclusion of off-leash recreation because it says dogs have a significant negative impact on plants and wildlife. Yet it offers no evidence to support the claims of impacts. The DEIR repeatedly says dogs MAY be impacting protected plant species or wildlife (ppgs, 298, 305, 306, 472, 502, 517), yet offers no evidence these impacts are actually occurring or ever have occurred. After each of these claims, the DEIR goes on to say: Dogs MAY continue to impact plants or wildlife. If there is no proof of an impact, then that impact cannot “continue.” EIRs must be based on observed, documented impacts, not speculation about things that “may” happen at some point in the future. The final EIR must alter its analysis to address this and base any restrictions on recreation involving dogs on actual observed impacts.

6. POOR MAINTENANCE

The 2012 work plans for the Natural Areas Program (see Attachment IV-A, obtained by public records request) help us to understand why the natural areas are such a mess.  The work plans inform us that NAP and its volunteers and contractors plan to spend a total of 358.5 days taking care of 1,075 acres of natural areas in 2012.  Each acre of natural area will therefore receive one-third of one day of maintenance for the entire year.  Some natural areas have not been scheduled for any maintenance and several as few as one day for the entire year.

There are countless stories of volunteers who spent long hours planting in NAP areas, only to see absolutely no maintenance performed once the plants were in the ground. Not surprisingly, many of these plants die, creating unsightly vistas of dead or dying plants. People are much less likely to want to walk in natural areas that are poorly maintained, a negative impact on recreation that is not addressed in the DEIR.

Poor maintenance is important because NAP is exempt from the Maintenance Standards mandated by Proposition C passed by San Francisco voters in 2003. Prop C required the Recreation and Park Department, with help from the Controller’s Office, park advocates and the general public, to develop maintenance standards for parks.  The standards define the desired conditions of park features such as lawns, trees, and trails, and are used to assess and evaluate conditions in San Francisco parks each year. In the San Francisco Park Maintenance Standards Manual (August 2006), there is a single maintenance standard for open space – cleanliness, defined as: “From a 10 feet distance (i.e., from the nearest path), open space is free of litter and debris.” The manual goes on to say that the standard is met if no more than 15 pieces of litter are visible in a 50’ by 50’ area or along a 200’ line, and that the standard is not met if needles, condoms, broken glass, and/or feces are present.

Certainly people in natural areas, including those walking on trails, have a right to expect the natural areas to meet such a simple cleanliness standard. However, the Manual goes on to say: “Open space-natural areas are not included in this standards manual, and therefore, are not inspected.” The DEIR should consider the impact on aesthetics and recreation of the woeful lack of maintenance in natural areas.

The final EIR should also consider the mitigation of scaling NAP back to a few areas that it can adequately maintain with its existing staff and budget, compared to the current plan to spread maintenance hours so thin because they are trying to cover too many natural areas.   One of many reasons why the Natural Areas Program is controversial is that it is too big.  It has claimed hundreds of acres in which there were no native plants whatsoever.  It has bit off more than it can chew.  Much of what is now on its plate should be taken back and returned to its “natural state,” i.e., without pesticides, without fences, without moonscapes created by eradicating existing vegetation.

Conclusion

The final Environmental Impact Report for the SNRAMP must:

  • Analyze the impacts on recreation of confining all recreation to trails, as well as the closure of trails in natural areas
  • Analyze the impact of restricting all recreational access to trails enforced by fences on recreation and aesthetics, especially erecting fences on both sides of trails, as well as impacts from the removal of benches in natural areas
  • Analyze impacts on recreation and access resulting from the designation of entire parks as natural areas with consequent impacts on recreation and aesthetics.
  • Analyze the impacts on recreation and access resulting from the intentional planting or reintroduction of legally protected species of plants and animals in natural areas where they do not currently exist
  • Analyze the maximum possible closures of all DPAs in natural areas (80%), not just the minimum possible (16.4%), and provide evidence of impacts claimed to be caused by dogs
  • Analyze impacts on aesthetics and recreation of poor maintenance of natural areas.

If this information is provided in the final Environmental Impact Report, it will undoubtedly conclude that the impact of SNRAMP on recreation is significant and requires mitigation.   The obvious mitigation is to decrease the size of the natural areas to a size that can be maintained adequately and which does not restrict recreational opportunities.

“Natural Areas Program” Restricts Access

When people hear “Natural Areas” they often have visions of wild areas where trails wind their way through rampant plants, and you can bushwhack your way into interesting nooks and discoveries. Maybe there are wild berries or flowers to be plucked, maybe a tree or a rock formation a kid can climb,  a clearing where a fallen tree makes a balance-beam or a rope can be tied to a branch for a swing. When people hear about “Trail restoration” they think maybe some fallen trees will be moved aside, some bushes trimmed back, eroded areas filled in and stabilized.

That’s not the plan laid out by SF Recreation and Parks Department’s Natural Areas Program.  Instead, they plan to restrict access in a number of ways.

TRAILS OUT

The plan calls for removing or “relocating” ten miles of trails, and adding only one mile of new trail – not necessarily in the same park where trails are closed. (The table at the bottom of this post has the list by park.) The trails being closed are “social trails” – the ones that exist because people use them.

Trail restrictions are also being used to deny access to park features people love, like rocks they climb on. For example, from the Plan for Glen Canyon calls for:

“…closing social trails to the northwestern rock outcrop in Glen Canyon Park, discontinuing rock climbing, and closing social trails in O’Shaughnessy Hollow.”

STAY ON THE TRAILS

For most adults who are jogging or walking through a park, it seems like a reasonable request: Stay on the trails. For a child, it’s meaningless. A trail offers no real chance of exploration or engaging with the environment. (And it’s not just kids. When we presented this to a group of people, several said, Wait, I like to wander off the trail sometimes…)

So what happens when a natural area becomes a “Natural Area” ?

A whole bunch of rules, starting with “Stay on Designated Trails.”

On Mount Davidson, someone told us, there used to be a big sign saying “Welcome to Mount Davidson Park.” It made you feel that it was an area for recreation, that belonged to everyone. That sign is gone, victim to time and vandals. “When the Natural Areas Program came in and put up a sign,” she said, “I thought maybe they’d put up the Welcome sign again. Instead, there’s this strict list of rules.”

By restricting access only to trails, a 10-acre park can be reduced effectively to a 0.25-acre park – the narrow area of the actual trail.

CLOSING DOG ACCESS

Perhaps the most frequent users of natural areas are people with dogs. After all, a dog needs to get out of the house at least a couple of times a day, and their people go with them. Ideally, they need some time off their leashes, when they can play and explore.

But once these areas aren’t natural but instead “Natural” – they start to close dog-play areas. The Plan calls for removing 20% of the areas immediately, and putting another 60% on a watch-list for possible closure (that’s the column of “Maybe’d” areas in the table below).

Of course this is important to dog-owners, and particularly to people who feel more secure walking along if they have a dog with them – older people, for instance, or a mom with small children.

But this doesn’t affect only dog-owners. For other users of parks, especially those who use them on weekdays and during the daytime, it’s important to know that the park won’t be deserted when you get there. Having other people around adds to the feeling of safety in the park. Typically, especially at off-peak times, the people who are out there are walking their dogs. The dog-walkers are also the people who are most familiar with the parks, who can see if there’s something unusual happening.  Dogs in our parks means eyes in our parks.

PLANNED ACCESS RESTRICTIONS, BY PARK

[Edited to Add (15 Mar 2012): The table above has been corrected to remove a typo.]

West Portal Monthly: Clearcut Case of Overkill at Mt Davidson Park

The West Portal Monthly today published an article by Jacquie Proctor explaining the problem of the NAP specifically at Mt Davidson and generally throughout the city.  The plan seeks to destroy at least 1600 trees on Mt Davidson alone. Read on:

Refuting Allegations – and a Candidate who “Gets It.”

One of the organizations that support the Natural Areas Program is called, ironically, “Nature in the City” (NIC). In a recent newsletter, they accused opponents of the NAP  “a handful of people” who were “still propagating misinformation.” Before we could respond, we saw this excellent riposte in “Death of a Million Trees.”  It’s reprinted below by permission, with minor changes.

Certainly, we’re finding a groundswell of opinion against NAP‘s so-called “ecological restoration”, which has actually meant a loss of trees and habitat, a growing use of the strongest pesticides San Francisco permits on city-owned land, and restrictions on public access and useat a cost of millions of dollars and thousands of volunteer hours that could have better been used elsewhere.  This is the “celebrated” program NIC refers to.

One candidate for supervisor, Joel Engardio, considers this an important enough issue that he’s running on it: See his video here:

If you’re interested in NIC’s allegations and the reality – read on!

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Response to “Nature in the City”

from Death of a Million Trees

Nature in the City (NIC) is one of many organizations that support native plant “restorations” in San Francisco as well as the principle entity which engages in them, the Natural Areas Program (NAP) of the Recreation and Park Department.

NIC is consistently critical of anyone who questions the value of these restorations, but in their most recent newsletter they confront our objections directly.  Although we don’t presume to represent the many constituencies which are critical of the Natural Areas Program, we are responding in this post to NIC based on our knowledge of the issues. (The NIC newsletter is in quotes and is italicized.  Our response is not italicized.)

“Natural Areas in 2012

Last fall saw the Planning Commission public meeting for the Draft Environmental Impact Report (DEIR) for the Significant Natural Resource Areas Management Plan.  Some time later this year, the City will issue a Final Environmental Impact Report, which may be appealed by opponents of the Natural Areas Program.

Unfortunately, a handful of people are still propagating misinformation about the rationale, values, and intention of ecological restoration, management and stewardship, and of the City’s celebrated Natural Areas Program.”

Webmaster:  Critics of the Natural Areas Program cannot be described accurately as a “handful of people.”  We now have four websites[i] representing our views and there have been tens of thousands of visits to our websites.  Comments on our websites are overwhelmingly supportive of our views. Our most recently created website, San Francisco Forest Alliance, lists 12 founding members.  That organization alone exceeds a “handful of people.”

Our objections to the Natural Areas Program have also been reported by three major newspapers in the past month or so (San Francisco Examiner, Wall Street Journal,  Sacramento Bee).

Many critics of NAP have been engaged in the effort to reduce its destructive and restrictive impacts on our parks for over 10 years.  Scores of public meetings and hearings have been held to consider our complaints.  We consistently outnumbered public speakers in support of NAP until 2006, when the NAP management plan was finally approved by the Recreation and Park Commission.  Although we were outnumbered for the first time, there were over 80 speakers who asked the Recreation and Park Commission to revise NAP’s management plan to reduce its negative impact on our parks.

The public comments on the NAP DEIR are the most recent indicator of the relative size of the groups on opposite sides of this issue.  These comments were submitted in September and October 2011.  We obtained them with a public records request.  The Planning Department reported receiving about 400 comments.  In analyzing these comments, we chose to disregard about half of them because they were submitted as form letters, even though they were from dog owners who were protesting the loss of their off-leash privileges in the natural areas.  We also leave aside the comments from golfers whose only interest is in retaining the golf course at Sharp Park.  In other words, we set aside the majority of the comments critical of the NAP management plan in order to focus on those comments that demonstrate a comprehensive understanding of the impact of NAP on the city’s parks.  Of the comments remaining, those critical of NAP and its deeply flawed DEIR outnumbered comments in support of the NAP DEIR about 3 to 1.  We urge NAP supporters to read these public comments to learn about the wide range of criticisms of NAP, including pesticide use, destruction of trees, recreational access restrictions, loss of wildlife habitat and more. 

We will challenge NIC’s accusation that we are “propagating misinformation” within the context of their specific allegations:

“Contrary to the many myths that continue to percolate, the Natural Areas Plan and Program seek to do the following (among other worthwhile endeavors):

1.       Protect and conserve our City’s natural heritage for its native wildlife and indigenous plant habitats and for the overall health of our local ecosystem;”

Webmaster:  Since the majority of acreage claimed as natural areas by NAP 15 years ago had no native plants in them, there is little truth to the claim that NAP is protecting our “natural heritage.”  The so-called “natural area” at Balboa and the Great Highway is typical of the “natural areas.”  There is photographic evidence that it was built upon for about 150 years.  It was the site of Playland by the Beach before it was designated a “natural area.”  Sand had to be trucked onto the property and disked down 18” into the construction rubble, then shaped into dunes by bulldozers before native plants could be planted on it.

Natural Area at Balboa & Great Highway under construction

We don’t make any distinction between “native wildlife” and any other wildlife currently living in our city.  We value them all.  Most are making use of existing vegetation, whether it is native or non-native.  They do not benefit from the loss of the blackberries that are their primary food source or the loss of the thickets or trees that are their homes.  We do not believe that wildlife in San Francisco benefits from the destructive projects of the Natural Areas Program.  See photos of insects, birds, and other wildlife using non-native plants in the natural areas here.

Damselflies mating on ivy, Glen Canyon Park

We do not think an ecosystem that has been sprayed with herbicides qualifies as a “healthy ecosystem.”  NAP sprayed herbicides at least 86 times in 2011.  Their use of herbicides has increased over 330% in the last 4 years.  NAP uses herbicides that are classified as more toxic than those most used by other city departments.  Last spring, 1,000 visitors to Glen Canyon Park signed a petition, asking the Natural Areas Program to stop using pesticides in their park.  This petition was given to Scott Wiener, the Supervisor representing the district in which Glen Canyon Park is located.

These are statements of fact that can be easily verified by the public record.

2.       “Educate our culturally diverse city about the benefits of local nature and about helping with natural areas stewardship in your neighborhood;”

Webmaster:  Although we value education, we do not consider the staff of NAP and/or its supporters qualified to provide it.  We hear them make statements that are demonstrably not true, such as “grassland stores more carbon than trees.”  We see them spray herbicides in the dead of winter that are supposed to be sprayed in the spring when the plants are actively growing.  We watch them plant things where they won’t grow, such as sun-loving plants in deep shade and plants in watersheds where they will soon be drowned by seasonal rains.

And we also have had bad experiences with the volunteers who are called “stewards” by NAP, but sometimes act more like vandals.  We see them spraying herbicides that they aren’t authorized to use.  We see them hacking away at trees that haven’t been designated for removal.  NAP is not providing the necessary guidance and supervision to the volunteers many of whom seem to consider themselves the de facto owners of the parks.

3.       “Manage the City’s wildlands for public access, safety and the health of the “urban forest.””

Webmaster:  We do not oppose the removal of hazardous trees.  However, we also know that most of the trees that have been designated for removal by the NAP management plan are NOT hazardous.  They have been selected for removal solely because they are not native and are perceived to be obstacles to the reintroduction of native plants.  Claims to the contrary are inconsistent with the management plan as well as our experience in the past 15 years.  (Watch video about the destruction of 1,600 trees over 15 feet tall planned for Mt. Davidson.)

“We hear occasional complaints about public access and tree removal. Three simple facts are thus:

1. Every single natural area in the City has at least one trail through it, where one can walk a dog on a leash;”

Webmaster:  The loss of recreational access in the natural areas is real, not imagined.  The following are verbatim quotes from the NAP management plan:

  • “Approximately 80 percent of the SFRPD off-leash acreage is located within Natural Areas.” (page 5-8).  The NAP DEIR proposes to close or reduce the size of several off-leash areas.  The DEIR provides no evidence that these areas have been negatively impacted by dogs.  It also states that all off-leash areas in the natural areas are subject to closure in the future if it is considered necessary to protect native plants.  Since NAP has offered no evidence that the proposed immediate closures are necessary, one reasonably assumes it will offer no evidence if it chooses to close the remainder of the 80% of all off-leash areas in San Francisco located in natural areas.  We know from the DEIR public comments that NAP supporters demand their closure.
  • Public use in all Natural Areas, unless otherwise specified, should encourage on-trail use… Additionally, interpretive and park signs should be installed or modified as appropriate to include “Please Stay on Trails” with information about why on-trail use is required.”  (page 5-14)   In other words, the only form of recreation allowed in the natural areas is walking on a trail.  Throwing a ball or frisbee, having a picnic on the grass, flying a kite, climbing the rocks are all prohibited activities in the natural areas.  And in some parks, bicycles have been prohibited on the trails by NAP.
  • “Finally, this plan recommends re-routing or closing 10.3 miles of trail (approximately 26 percent of total existing trails).” (page 5-14)  So, the only thing visitors are allowed to do in a natural area is walk on the trails and 26% of all the trails in the natural areas will be closed to the public.

2. “The act of removing (a small subset of) non-native trees, e.g., eucalyptus, that are in natural areas has the following benefits:
a. Restores native habitat for indigenous plants and wildlife;
b. Restores health, light and space to the “urban forest,” since the trees are all crowded together and being choked by ivy;
c. Contributes to the prevention of catastrophic fire in our communities.”

Webmaster:  Destroying non-native plants and trees does not restore indigenous plants and wildlife. Native plants do not magically emerge when non-native plants and trees are destroyed. Planting indigenous plants might restore them to a location if they are intensively gardened to sustain them.  However, in the past 15 years we have seen little evidence that NAP is able to create and sustain successful native plant gardens.  Native plants have been repeatedly planted and they have repeatedly failed.

NAP has not “restored” the health of the urban forest.  They remove trees in big groups as they expand their native plant gardens.  They are not thinning trees.  They are creating large openings for the grassland and dune scrub that they plant in the place of the urban forest.  Every tree designated for removal by the NAP management plan is clearly selected for its proximity to native plants.  It is disingenuous to suggest that NAP’s tree removal plans are intended to benefit the urban forest.

Of all the fictions fabricated by native plant advocates to justify the destruction of our urban forest, the claim that its destruction will “prevent catastrophic fire” is the most ridiculous.  The native ecology of California is highly flammable.  Most fires in California are in native chaparral.  According to San Francisco’s hazard mitigation plan, there has never been a wildfire in San Francisco[ii] and one is unlikely in the future because the climate is mild and moist.  When it is hot in the interior, it is foggy in San Francisco.  The hot winds that drive most fires in California never reach San Francisco because it is separated from the hot interior by the bay.  San Francisco is surrounded by water, which moderates its climate and virtually eliminates the chances of wildfire. The tall non-native trees precipitate moisture from the summer fog, which moistens the forest floor and reduces the chances of ignition.  In the unlikely event of a wind-driven fire, the trees provide the windbreak which would stop the advance of the fire.

3. “The overall visual landscape of the natural areas will not change since only a small subset of trees are planned to be removed over a 20-year period.”

Webmaster:  In addition to the 18,500 trees over 15 feet tall which NAP proposes to destroy, the NAP management plan also states its intention to destroy non-native trees less than 15 feet tall.  In other words, the future of the forest will also be killed.  The intention is to eliminate the urban forest in San Francisco’s parks over the long term.  Yes, this will take some time, but the long-term intention to eliminate the forest is clear.

“Please feel free to email steward@natureinthecity.org if you would like more clarification about the intention, values and rationale of natural resources management.”

Webmaster:  We urge our readers to take NIC up on this offer to provide  ”more clarification” of its spirited defense of the Natural Areas Program. 

  • Do you think NIC is deluded about there being only a “handful of people” that are critical of the Natural Areas Program?
  • Did you notice that NIC does not acknowledge the use of herbicides by NAP?  Do you think that a fair representation of criticism of NAP can omit this issue?
  • If you visit a park that is a natural area, do you think NAP has demonstrated in the past 15 years what NIC claims it is accomplishing?
  • Do you think NIC has accurately described recreational access restrictions in the natural areas?
  • Do you think that San Francisco’s urban forest will be improved by the destruction of 18,500 mature trees and countless young trees?

[i] Save Sutro Forest, Urban Wildness, San Francisco Forest Alliance, Death of a Million Trees

[ii] “The California Department of Forestry and Fire Protection (CAL FIRE) has no record of any wildfire in San Francisco.” San Francisco Hazard Mitigation Plan, 2008, page 5-18.

How Unnatural can San Francisco’s “Natural” Areas get?

This post is republished with some modifications and permission from Save Sutro Forest.

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Why San Francisco’s Natural Areas are – Unnatural

by Save Sutro Forest

WHEN I first heard about San Francisco’s Natural Areas Program (SF NAP) some years ago, I was charmed. Over 1000 acres of city-owned land would be left to Nature, more wild and free than the orderly, gardened lawns and playgrounds (which I also appreciated, in a different way). Kudos to the San Francisco Recreation and Parks Department (SFRPD) — which owns the SF NAP — was my reaction.

These would be spaces, I thought, where plants and animals and people could interact naturally. Birds and animals could safely breed in tangled thickets; so could bees and butterflies and other insects. They’d provide enough cover for birds and animals to hide from dogs, cats, hawks, coyotes, raccoons — and people. These spaces would be free of the toxic chemicals used in managing parks. Dogs could be allowed to romp through areas wild enough to tolerate disturbance. The only intervention, I assumed, would be to maintain some degree of safety on trails that animals and people would blaze through these areas.

If like me, you thought that Natural Areas were going to be, well, natural… then like me, you were mistaken.

NATURAL VS “NATIVE”

San Francisco’s “Natural Areas” program is really about is Native Plants, most of which no longer grow in these places naturally. These plants grew (or may have grown) in these 46.9 square miles some 300 years ago. Some are still there. Others, even though common elsewhere, aren’t found in the city any more. Instead, other plants grow there, adding to the biodiversity of the area. According to Peter Kareiva of the Nature Conservancy, there are 25% more species in California than there were before “non-native” plants got here.

What we’re actually getting, then, is Native Plant Gardens, 32 of them. Trying to push these spaces back in time means they must be managed and maintained, because San Francisco now is a different place and a different ecology from the windblown hills and sand-dunes of its pre-colonial past.

What does this management and maintenance imply?

POURING ON PESTICIDES

Since there’s a lot of area, and a lot of plants, this means a lot of pesticides. According to the records, Natural Areas had 69 applications of pesticides in 2010, most of them Tier I and Tier II pesticides like Garlon and Roundup. (San Francisco groups permissible pesticides into three tiers, with Tier I being the most dangerous and Tier III the least. The SF NAP hasn’t used Tier III pesticides, they’re all Tier I or II.)

Some — including Native Plant doyen Jake Sigg — have argued that one or two applications in a decade are all that’s needed, and are thus justified. That hasn’t been our experience. Two nearby Native Areas — Twin Peaks and Glen Canyon — have been sprayed many times annually for many years. According to their communications with some concerned neighbors, the SF NAP does not expect to stop.

MUSEUM-IFICATION

Some years ago, Save Sutro Forest ran an article on museum-ification. This is the fate of many of these “natural” areas: they come with more, not fewer, restrictions than gardens and parks. Many of the paths animals and people made naturally, called “social trails” are blocked. (They current plan closes or relocates over 9 miles of trails.) There are formal trails, and people must stay on them. They are discouraged from actually interacting with these environments, except as gardening or trail-building volunteers.

Some 86% of the city’s dog-play off-leash areas are in areas controlled by the SF NAP. They plan to close up to 80% of these. (This comes on the heels of a plan to ban all dogs from the Golden Gate National Recreation Area.)

TREES BEING CUT AND HABITAT DESTROYED

Trees are being chopped down. San Francisco had some wonderful eucalyptus forests, many of them over a century old with a complex habitat and dense understory. Most of these are already gone.

The eucalyptus trees — defined as “invasive trees” despite the evidence that they are not invading anything — are non grata. So too the Monterey pine and the Monterey cypress; those are native to distant Monterey, all the way down the peninsula. Many trees have already been felled, and many thousands more are doomed. (That’s only counting those over 15 feet tall; the SFNAP counts smaller trees as “saplings” or “seedlings” and cuts them at will.)

The plan, for “urban forests” is to cut down trees until they’re down to a “basal area” of 200-600 feet per acre. This gives an estimated 60-200 trees per acre. (By comparison, Sutro Forest averages 740 trees per acre.)

In addition, the plan calls for removing blackberry thickets, one of the richest and safest habitats for birds and animals. It calls for removing fennel, another tall and dense habitat plant which, just incidentally, is the nursery plant for the native Anise Swallowtail butterfly. It calls for removing vines from the trees, all of which provide some of the complex habitat small birds need.

In fact, it seems to call for removing anything that grows lush and dense and useful to birds and animals. The result wouldn’t be a forest (urban or otherwise); it would be a garden with some trees in it.

WHAT WE SUPPORT…

We’d like to clarify what SaveSutro supports:

We are for preservation of existing habitats and ecosystems. We think places like the coastal scrub area on the slope above Laguna Honda Reservoir, (which has not been invaded by the contiguous eucalyptus forest!) deserve protection. This area is, incidentally, owned by the SF Water Department, not the SF Recreation and Parks Department. It’s visible from the road, but is not publicly accessible.

We’re fine with planting scrappy semi-industrialized areas like Heron’s Head Park into Native Plant gardens; that area had a recent win when Clapper Rails nested there and successfully produced chicks.

…AND WHAT WE DON’T

  • We object to converting parks devoted to other uses into such Native Gardens by imposing numerous restrictions.
  • We object to habitat destruction; birds, insects and animals all use these “non-native’ habitats.
  • We object to felling thousands of trees.
  • Most of all, we object to the use of toxic pesticides in areas that should, naturally, be free of chemicals.

Mt. Davidson Park – An Open Space Preserved for Recreation or Native Plants?

Native plant interests threaten trees throughout the city, and in particular, in one of San Francisco’s significant century-old forests: Mt Davidson. A favorite area for the residents of Miraloma Park, the Significant Natural Areas Management Plan calls for felling over 1600 trees.

Photo credit: Peter Earl McCollough

In the map below, the brown areas would be… well, brown. At least in summer. They are to be turned over to native plants.

This diagram is reproduced from public documents of the city of San Francisco, and used here for the purpose of discussion and education.

The article below by Jacqueline Proctor was published in Miraloma Life in November 2011, and is republished here with permission and added emphasis. [ETA: The publication followed up with an even longer article by Dan Liberthson.]

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Mt. Davidson Park – An Open Space Preserved for Recreation or Native Plants?
By Jacqueline Proctor

In 1995, the City transferred Mt. Davidson Park to the Natural Areas Program with the result that protection and restoration of native plants—rather than public recreation, aesthetics, or forest maintenance—has become the first priority of the few City staff assigned to maintain the park. A recently completed Draft EIR has determined that the Natural Areas Program Plan will have a significant impact on the environment. Indeed, the Plan envisions the negative consequences to public enjoyment of the Park to be beneficial.

While the City is busy planting 1000s of street and median trees to “clean the air,” it is giving the OK to spend limited Recreation and Park funds to cut down 1000s of the historic trees along the trail and road areas of Mt. Davidson, restrict public access through native plants areas by installing barriers, prohibiting benches in the best view areas, and fostering the growth of poison oak (a native plant now thriving where non-native shrubs and trees have already been removed).

The Miraloma Park Improvement Club Board plans a letter to the City advocating for the Final EIR to recommend preservation of the forest as an historic, natural, recreational, and aesthetic resource, as well as advocating for full access to the native plant area and installation of benches in the view areas.

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(The Board did write such a letter in comments to the Draft Environmental Impact Report on the SNRAMP.)

Recently, the Wall Street Journal covered this in its December 15th 2011 issue; and the San Francisco Examiner had an article about it on the same day. The San Francisco Forest Alliance (SFFA) has links to both articles on its Facebook page. Click here for WSJ, and here for the article in the Examiner.

The picture at the top of this post is the one used in the Wall Street Journal article. It’s reproduced here with permission from photographer Peter Earl McCollough, who also provided the the picture in the article by Jacqueline Proctor.  (His photography website is at www.petermccollough.com )

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