Five Reasons it’s Okay to Love Oxalis – and Stop Poisoning It

The oxalis season is over, and the perky yellow flowers have vanished for another year. These Bermuda buttercups will be back next year to herald the spring, bringing joy to those who love them, irritation to those who hate them, and Tier I herbicides targeted at them in San Francisco’s so-called “Natural” Areas.

oxalis in glen canyon feb 2011

THOSE WHO HATE OXALIS AND WANT TO POISON IT  WITH GARLON

These flowers are so visible in spring that Bay Nature magazine did an article about them in March 2015: A Natural History of the Little Yellow Flower that’s Everywhere Right Now. It quoted Jake Sigg, the retired SF Recreation and Parks gardener who is considered the doyen of San Francisco’s native plant movement. He hates oxalis pes caprae, which he considers extremely invasive. The article quotes him as saying that, without intervention, “in X many years Twin Peaks would just be one solid mass of yellow, and there wouldn’t be any other plants there…” The article suggested that an oxalis-dominated landscape “drives away coyotes, hawks and owls that feed on grassland foragers, and the situation is especially dire for endangered Mission blue butterflies, which depend heavily on native wildflowers.” Most of those ‘facts’ about oxalis are mistaken as we’ll explain below.

Mr Sigg’s theories align with those of the Natural Areas Program (NAP) of the San Francisco Recreation and Parks Department (SFRPD), which uses the herbicide, Garlon (triclopyr) to battle oxalis  despite its dubious efficacy for the purpose.  San Francisco’s Department of the Environment San Francisco’s Department of the Environment classifies Garlon 4 Ultra as Tier I: Most Hazardous. It’s listed as HIGH PRIORITY TO FIND AN ALTERNATIVE (their caps). Since oxalis is the main reason NAP uses Garlon, the alternative we propose is – don’t use Garlon or anything else on oxalis.

An article on SaveSutro.com, based on a detailed study by the Marin Municipal Water Department, describes some of the issues with Garlon:

  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  •   Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  •   About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs  may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans.  Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  •  It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  •  It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  •  Garlon can persist in dead vegetation for up to two years.
twin peaks - jan 2015 - imazapyr and garlon for poison oak cotoneaster oxalis

Natural Areas Program uses Garlon on oxalis

First, a little about the actual natural history of oxalis. This plant doesn’t set seed in California, and spreads entirely by sending out roots and forming little bulbils (like tiny potatoes) underground. It’s usually found where the soil has been disturbed by activities such as road-building, gardening, or trail-building. In some cases, the disturbance come from landslides or something similar. It can’t stand frost. If we do nothing,  it would tend to die down rather than spreading uncontrollably.

In disturbed landscapes, it can spread fast. For this reason it can be a nuisance in gardens. People don’t want to leave their gardens alone for years to let nature take its course with the oxalis, and not every garden design includes brilliant yellow as the dominant color for a few weeks. The only way to eradicate it in the short term is to dig it out carefully every time you see it, and make sure you get most of the bulbils. Or use strong herbicides, which may not work.

In a natural landscape, though, it’s a different story and here’s why.

1) OXALIS IS GOOD FOR BEES AND BUTTERFLIES

Oxalis is actually an excellent plant for bees and butterflies.  When blooming, it provides “copious nectar.” In fact, it generously gives away its nectar. Since it doesn’t set seed, it doesn’t benefit from pollinators – but it’s a food source for honey bees, bumblebees and butterflies. (You can read a rather technical description of the plant HERE in a 2-page PDF note from UCLA’s Barry A. Prigge and Arthur C. Gibson.)

In fact, a recent 2014 study shows that plant communities with exotic plants had more plant species as well as more pollinators, that pollinators didn’t prefer native plants, and that even some specialist pollinators depended on introduced plant species.

It’s true the Mission Blue butterfly needs (native) lupine as its nursery plant. (It doesn’t depend on any other native wildflowers – only three varieties of lupine.  Incidentally, one of the key nectar sources for the Mission Blue butterfly is an invasive non-native Italian thistle: Carduus pycnocephalus).

Lupine has been planted on Twin Peaks as NAP attempts to reintroduce the Mission Blue butterfly there. But lupine is also a plant of disturbed areas, which means that NAP must maintain it or it will die out as the area stabilizes. They have to keep planting it, weeding, and trimming the grass around the lupine patches to make it attractive to the butterfly. An SFRPD report on the reintroduction project said “unmanaged habitat deteriorates quickly.” Presumably, they don’t use Garlon near the lupine patches, since it would likely kill that too. Despite what is implied in the Bay Nature article, it’s not oxalis that’s the issue. The real problem is another native plant, the coyote bush which takes over grasslands in a natural succession.

2) OXALIS IS GOOD FOR WILDLIFE

Oxalis bulbils are a food source for wildlife. Gophers and other rodents eat them. In fact, the Bay Nature article says, “Their spread is abetted by pocket gophers and scrub jays, which have been spotted carrying the bulbs and caching them in the ground—effectively planting them in new areas.”

Since gophers are a foundation species in the food web, being dinner for predators from hawks to coyotes to great blue herons, these plants actually provide habitat benefits whether or not they’re flowering, because the bulbils are there all year.

gopher-twin-peaksWhere there are gophers, the predators follow. Like the coyotes in these pictures, which clearly haven’t been driven away by a landscape dominated by oxalis.

coyote pouncing in oxalis field - copyright Janet Kessler

coyote pouncing in oxalis field – copyright Janet Kessler

coyote in oxalis field - copyright Janet Kessler

coyote in oxalis field – copyright Janet Kessler

3)  OXALIS DOESN’T LEAVE THE GROUND BARE

The article says that oxalis leaves “bare ground during the six months of the year oxalis doesn’t flower.” That’s not true either.

oxalis interspersed with grasses and other plants

oxalis in glen canyon feb 2011The spectacular yellow bloom of the oxalis – valuable because it the mass of color attracts honey bees and bumblebees – gives the impression that it’s the only plant there.  But though it visually takes over the landscape when it’s in bloom, it naturally grows interspersed with grasses and other plants. Like in the picture above.

In fact, oxalis tends to enrich the soil with phosphorus, which is good for grass.

So when it finishes blooming, as it has by now – you don’t get bare ground. The picture below shows the same area as the first picture in this article – but it’s after the oxalis bloom is over. It’s a grassland.

glen canyon after the oxalis season

4)  OXALIS HAS LITTLE IMPACT ON “NATIVE” PLANTS

One argument – related  to the ‘bare ground’ argument – is that oxalis takes over grasslands and destroys them, particularly the native grasses. However, grasslands in most of California including San Francisco are dominated non-native grasses. The change occurred over 100 years ago, when these grasses were planted for pasture. So the grassland that NAP is defending with herbicides are primarily non-native anyway.

oxalis and california poppies sm But anyway, what’s the evidence that oxalis is actually damaging native plants?

It’s true some European studies do suggest that an increase in oxalis is associated with a decrease in native plants diversity -though whether it’s a cause is unclear. It may just be benefiting from human activities that disrupt the landscape. Another study put oxalis head-to-head with a native annual grass, lolium rigidum. The native grass tended to dominate. Their conclusion: “Oxalis is a poor competitor. This is consistent with the preferential distribution of Oxalis in disturbed areas such as ruderal habitats, and might explain its low influence on the cover of native species in invaded sites.

The California Invasive Plant Council rates its invasiveness as “moderate,” considering it as somewhat invasive in sand dunes and less so in coastal bluff areas.

In San Francisco, every place where oxalis grows is already a disturbed environment, a mix of non-native grasses and plants with native plants (some of which have been artificially planted).  Here,  oxalis appears to grow happily with other plants – including, for instance, the native California poppy in the picture above.

5) KIDS LOVE IT AND IT’S EDIBLE

Children love oxalis, both for its pretty flower and for the sour taste of its edible stems.

Even small children love gathering posies of Bermuda buttercups (though picking flowers is technically prohibited in Natural Areas). The flowers are surprisingly hardy for wildflowers, and in a glass of water last quite well as cut-flowers.

The plant is edible, and its tart leaves make a nice addition to salad. People enjoy snacking on its sour stems. Besides Bermuda buttercup, it’s also called ‘sourgrass’ and ‘soursob.’ It does contain oxalic acid (as does spinach, for instance), and so you probably wouldn’t want to make a meal of it. Though in South Africa it’s made into soup.

Adding Garlon to it is probably a bad thing.

Photo credit: Badjonni (Creative Commons - Flickr)

Photo credit: Badjonni (Creative Commons – Flickr)

CONCLUSION

From our current evidence, there’s no sign that oxalis has a negative impact on wildlife, and plenty of evidence it’s already part of the ecological food web of our city.  The evidence also suggests it’s not having a negative effect on other plants in San Francisco either. Lots of people find this flower attractive; one writer described it as the city smiling with Bermuda buttercups.

In any case, even Doug Johnson of the California Invasive Plant Council doesn’t think it’s worth attacking at a landscape level: the payoff isn’t worth the expense. Removing it from the hundreds of acres in Natural Areas isn’t as simple as eradicating it from a small yard where it’s clashing with the garden design. It requires a lot of work, a lot of powerful herbicides, a multi-year effort – and for what?

The justification for using strong pesticides like Garlon to control it is weak. We call on NAP to stop using Tier I and Tier II herbicides altogether.

Fighting the East Bay Clear-Cutting of 450,000 Trees

Nearly half a million trees are likely to be felled in Berkeley and the East Bay Hills of the San Francisco Bay Area. There’s an extremely destructive project planned. The land managers sought Federal Emergency Management Agency (FEMA) funding for this project, and a Draft Environmental Impact Statement (EIS) was published. We wrote about this project HERE. The good news is that people responded: There were around 13,000 comments on the draft EIS. The bad news is that the Final EIS, released recently, still plans to destroy hundreds of thousands of trees, increase fire hazard, destabilize slopes, and use huge amounts of herbicide. It will be a disaster for the environment and for wildlife habitat.

People are fighting back to save the trees and the environment. As TreeSpirit says on their website, “Can you even imagine 450,000 trees being cut down?”

THREE WAYS TO FIGHT BACK

We are aware of three separate initiatives, and we urge you to give them your support.

HCN Save the East Bay Hills Trees sm1) The Hills Conservation Network (HCN) is raising funds to take legal action. They are a registered charity, a 501(c)3 organization, and have been fighting this battle from the start. They have a GoFundMe page where you can help by contributing toward the legal fund. Here’s the link: http://www.gofundme.com/SaveEastBayTrees

2) SaveEastBayHills has a website about this project saveeastbayhills.org where you can go to the ‘Take Action’ page to which details about what you can do to write to the decision makers to protest this project.  SaveEastBayHills is led by Nathan Winograd, who also cares about animals and has been a force in working for no-kill shelters.

Treespirit fundraiser to save east bay trees sm3) TreeSpirit Project is working to get the word out, because most people still don’t know what’s about to happen. An informed public is going to be crucial to stopping this horrible project. They’re raising funds for publicity. Here’s a link to the page describing what’s happening, and a planned photo shoot. http://treespiritproject.com/sfbayclearcut/

They also have a GoFundMe fundraiser going on: http://www.gofundme.com/SFBayClearcut

TreeSpirit Project is the work of photographer Jack Gescheidt, who creates beautiful pictures of unclothed people (all volunteers) in forests to draw attention to the vulnerability of trees. (HERE’s an example from Sutro Forest.)

TreeSpirit Project has the support of Kevin Danaher of Global Exchange, who wrote on his Facebook page: “If people knew the huge numbers of trees to be killed, they’d not stand for it, and so the numbers are not revealed, nor discussed. Several citizens groups, including my friend Jack Gescheidt’s TreeSpirit Project, have uncovered and now disseminate these mind-boggling numbers. We kindly urge you to, also!”

WHAT YOU CAN DO

There isn’t much time to save these trees; felling is planned to start this fall. It’s a disaster in the making, and all based on an unreasonable prejudice against eucalyptus and a large number of myths that have been propagated.  Please do what you can:
1) Make a contribution as you can to the HCN legal fund and the TreeSpirit Project publicity fund;
2) Write to the decision-makers listed HERE, protesting the project: http://www.saveeastbayhills.org/take-action.html
Thank you to all our readers for their involvement. Without your help, thousands of trees would already be felled.
[Webmaster: This article has been updated to correct some information.]

Owl Drama Up High In The Forest (and Some of it Low in the Forest)

[Photos and story by Janet Kessler]

front row seat by the wise guy who didn't try to fly the coop today - copyright Janet Kessler

Front row seat by the wise guy who didn’t try to fly the coop today

Today two of three Great Horned Owlets attempted fledging from their Eucalyptus tree nest. It was time. The third has not left the nest. Owl eggs are laid asynchronously, so the youngsters actually mature at different rates and this one was not ready. So he had a front row seat for the drama that followed!

second fledgeling lands on the ground (photo courtesy Kerry Bostrom)

Second fledgeling lands on the ground (photo courtesy Kerry Bostrom)

Animal Care and Control comes to the rescue! (photo courtesy Kerry Bostrom)

Animal Care and Control comes to the rescue! (photo courtesy Kerry Bostrom)

The first fledgeling successfully departed, swooping over to a flimsy pine tree close by.  A second one, with high hopes of succeeding like his sibling, also took off, but immediately fell straight to the ground below his tree where it remained sitting under a bush.

Animal Rescue came and tried tossing the grounded bird back up its tree, but after two attempts and after the chick flew across a field, the parents called to it and it clambered up a hill which was not accessible to people or dogs. It would be safe here where its parents would encourage it to a tree branch without danger of a dog going after it.

Mom and Dad work to save the grounded fella after Animal Control’s attempts didn’t work

The first fledgeling made it to a flimsy limb close by

The first fledgeling made it to a flimsy limb close by

The first fledgling who had made it to a tree close by, discovered that its perch was mighty flimsy and precarious. So it attempted to move. It bent its neck — owls can’t swivel their eyes so their entire head must move when they focus on something — looking carefully at the piece of Eucalyptus bark close by which probably looked sturdier than the limb he was on. The Eucalyptus bark was a familiar item since he had spent all his time until now in a Eucalyptus tree filled with pieces of bark like this. He grabbed the bark ever so carefully with his talons. Oh, no!

Carefully watching where to put his feet for the move

Carefully watching where to put his feet for the move

He slipped! As he strained to gain a footing, we could see that he was held up by only a feather on his wing. It was touch and go for a minute, but the fellow successfully and skillfully extricated himself from that possible dangerous situation. Now he is sitting on that branch without moving. By the evening he’ll probably have the strength to move to a safer spot. Mom and Dad will keep an eye on him and they will continue to feed him, even on that flimsy limb. With all this drama, the littlest owlet probably felt safe remaining in its nest in the fork of the Eucalyptus, where it will remain a few more days until it is ready to fledge.

Oh, no! He lost his footing!

Oh, no! He lost his footing!

2015-05-05 (8)

Footing is regained! Whew! It was probably more dramatic for the spectators than the young owlet

Footing is regained! Whew! It was probably more dramatic for the spectators than the young owlet

 

Finally, Good News for the Glen Canyon Owls

The last two years weren’t good to the famous Glen Canyon Great Horned Owls. All the  work that was going on, the removal of trees near the nesting tree, the changes to the canyon – they disturbed the owls enough that there were no babies. Even though there’d been other successful nests in San Francisco.

That’s changed this year. The owls are back with a trio of baby owls. Here are some shots taken by wildlife photographer Janet Kessler. [This post was edited, as promised, to add in more owl pictures.]

[Edited to add: We normally would wait on publishing this until the owlets were fledged and flown, to avoid disclosing where the youngsters are. In this case, the story had already been published in the local online newsletter, so we decided to share the news with our readers.]

glen canyon owlet 2015 copyright janet kessler

Three baby owls!

Three baby owls!

Mama owl standing guard

Mama owl standing guard

Two baby owls together

Two baby owls together

Mama sitting proudly in back of two of her chicks

Mama sitting proudly in back of two of her chicks

Mama grooms her youngsters after feeding them

Mama grooms her youngsters after feeding them

Meanwhile, here’s another Glen Canyon bird – a Steller’s jay. This picture is also courtesy Janet Kessler.

steller jay glen canyon - copyright Janet Kessler

World Health Organization: Roundup “Probably Carcinogenic”

The World Health Organization (WHO) recently declared that glyphosate is “probably carcinogenic” to humans. Specifically, it links the herbicide to non-Hodgkin lymphoma. (You can read their press release here: WHO glyphosate MonographVolume112)

Though SFRPD Natural Areas Program’s use of herbicides declined in 2014, it rose quite sharply before that. Roundup and Aquamaster, with active ingredient glyphosate, is one of the most frequently used herbicides in their arsenal. (The others are Garlon 4 Ultra, i.e. triclopyr; Polaris, Stalker or Habitat,  i.e. imazapyr, and Milestone VM – aminopyralid.)

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

We’re glad that WHO has come out with this statement, but we’re not surprised. We’ve been following the literature for some years. In 2013, Dr Morley Singer alerted us to an article in the highly-respected peer-reviewed and journal, CA: A Cancer Journal for Clinicians. The article said that people who applied pesticides – or were around pesticides – were more likely to get cancer. [HERE’s the link to the article:  Increased cancer burden among pesticide applicators and others due to pesticide exposure.] We wrote about it here: Pesticides and Cancer, Glyphosate and Gut Bugs. NAP Herbicide use by active ingredient 2014

HERBICIDAL PROBLEMS

We hope that the WHO’s determination will make the Natural Areas Program (NAP) re-think its use of herbicides. Glyphosate, i.e. Roundup/ Aquamaster is possibly carcinogenic, and is on the list of herbicides to be evaluated as an endocrine disruptor. Besides the risk to the public and their pets, their own staff are in the front lines here.

The San Francisco Department of the Environment (SFDoE) assigns a ‘Tier” ranking to all the pesticides that are legal for use on City-owned property. Tier III is Least Hazardous, Tier II is More Hazardous, and Tier I is Most Hazardous. Roundup/ Aquamaster is Tier II. We again ask SFDoE to consider reclassifying it as Tier I. But we would be disappointed if NAP merely substituted other herbicides instead.

We have concerns about all the herbicides they use. (See this summary article: Toxic and Toxic-er )

  • Triclopyr (Garlon) is possibly more hazardous than Roundup; it’s already classified as Tier I, and for years has been listed as “High Priority to find a substitute.” NAP is a major user of Garlon, mainly to fight Bermuda Buttercups – yellow oxalis. (We’ll discuss that trade-off another time.)
  • Imazapyr (Polaris), classified as Tier II, is problematic because it doesn’t go away. It can continue to poison plants and impact the environment for a long time after it’s applied. Also, it moves around – it’s mobile in the soil. Some plants actually push it out through their roots. Its breakdown product is a neurotoxin.
  • Milestone VM – aminopyralid – is also classified as Tier II, and it’s even more persistent than Imazapyr. It’s so persistent that animals can eat it, and their poop is poisonous to plants. It’s banned in several places because of its threat to groundwater.

Besides the risk to humans and their pets, pesticide use doesn’t benefit native wildlife – whether insects including butterflies, birds, or animals. It doesn’t benefit native plants, either. All that happens is that other plants best-suited to the area take over, and those are usually other ‘invasives.’ Or worst of all – nothing grows there, leaving bare poisoned slopes. We call on the Natural Areas Program to stop using herbicides.

McLaren Park's Flowered Grassland and Forest

McLaren Park’s Flowered Grassland and Forest

Glen Canyon with Stairs and Coyote

This is one of our “park visitor” series – first person accounts of our parks, published with permission.

Escher's_Relativity

Source: Wikipedia (fair use)

It was dusk when I climbed down into Glen Canyon from the Christopher Playground. It’s been some months since I visited it last, and I was saddened by the changes stemming from SF Recreation and Parks “trails” project.

All the hillside trails have been made into staircases.  It reminded me of a drawing by Escher: they’re nearly as as difficult to walk. The risers of the box steps are high and the pitch not suited to everyone. Tiring and hard on the knees, and so it will effectively restrict access to many people.

COYOTE…

But then a coyote came out of the bushes. I was delighted, though not surprised.  Coyotes inhabit most of the city now, and the park has coyote-spotting signs up at the Christopher playground. But what followed was a surprise (to me, anyway!)

The park is surrounded by urban areas, and an emergency vehicle was racing by on the street above, siren wailing. “Watch,” said my companion. “He’s going to howl with the siren.” And sure enough – the little coyote raised his muzzle to the sky, gave a few barks, and then howled along with the siren.

I managed to get a blurry photograph. coyote howlingA few dogs from nearby homes responded with a woof or two, but they weren’t serious. The siren-coyote duet continued until the vehicle raced away and the sound faded. The coyote sat down, convinced, I thought, that it had told off the intruder into its territory and announced who really occupied this space.

The dusk deepened, and this magical moment was broken by  flights of mosquitoes. I’ve been to Glen Canyon many times over many years, and these are a new thing for me. Wonder if it’s anything to do with the Islais Creek – and the felling of the bat trees.

Lawsuit to Block Funding for East Bay Deforestation

lake-chabot cropped Photo credit MillionTrees dot meThe new Plan to cut down hundreds of thousands of trees in the East Bay hills of the San Francisco Bay Area  is as bad as the previous one. (See: East Bay Trees to be Destroyed.) Trees fight climate change, and removing these trees will negative environmental impacts. It will also increase fire hazard.

Now, the Hills Conservation Network is suing to stop the funding for this destruction of the trees. The article below is republished with permission and minor changes from Death of a Million Trees, which fights unnecessary tree-destruction.

———————

HILLS CONSERVATION NETWORK FILES SUIT TO STOP FEMA GRANTS IN EAST BAY HILLS

Ten years after UC Berkeley, City of Oakland, and East Bay Regional Park District applied for FEMA grants to fund the destruction of hundreds of thousands of non-native trees on 1,000 acres of public open space, FEMA announced its final decision on Thursday, March 5, 2015.

FEMA’s announcement of that final decision, which was sent to those who commented on the draft plans, implied that the projects had been revised to be less destructive. In fact, those who take the time to read the final version of the plans will learn that the original plans are fundamentally unchanged in the final version. East Bay Regional Park District (EBRPD) will destroy about 90% of the trees in its project area, as originally planned. “Thinning” is not an accurate description of EBRPD’s project. UC Berkeley (UCB) and City of Oakland will destroy 100% of all non-native trees on their project properties.

On a small portion of UCB and Oakland property (29 of 460 acres), tree removals will be phased over the 10-year project period. In other words, the final version of these projects will destroy as many trees as originally proposed by the grant applicants. However, FEMA has refused to fund tree removals on Frowning Ridge (185 acres) because UC Berkeley removed hundreds of trees there before the Environmental Impact Statement was complete, in violation of FEMA policy.

UC Berkeley destroyed hundreds of trees on Frowning Ridge in August 2014, before the Environmental Impact Statement was complete.

UC Berkeley destroyed hundreds of trees on Frowning Ridge in August 2014, before the Environmental Impact Statement was complete.

The Hills Conservation Network (HCN) filed suit to prevent the funding and implementation of these projects on March 6, 2015. Below is the press release announcing HCN’s suit. Please contact the Hills Conservation Network if you wish to contribute to the cost of this suit: http://www.hillsconservationnetwork.org/HillsConservation3/Blog/Blog.html or email inquiries@hillsconservationnetwork.org


Hills Conservation Network

Preserving the East Bay Hills

March 6, 2015

For Immediate Release

HCN announces lawsuit against FEMA EIS

Today the Hills Conservation Network, an Oakland, CA based environmental non-­‐profit, filed suit against the Federal Emergency Management Agency, also naming the Regents of the University of California, the City of Oakland, and East Bay Regional Park District in the suit.

The suit was filed in opposition to the Record of Decision released March 5, 2015 finalizing FEMA’s decision to award approximately $7.5 million in fire risk mitigation grants. The suit contends that the Environmental Impact Study used as part of the grant process was significantly flawed, and as such cannot be used to justify awarding these funds.

The lawsuit argues that FEMA did not consider a reasonable range of alternatives and reached unsupportable conclusions in deciding to allow the three agencies named in the suit to remove large numbers of healthy trees, with the goal of eradicating certain species of non-­‐native trees (acacia, Monterey pine, eucalyptus) by the end of ten years. HCN proposed a more nuanced approach that would have resulted in higher levels of fire risk mitigation at a much lower cost and with far less environmental damage than the current plan that calls for the removal of well in excess of 100,000 healthy trees that provide shade canopy (preventing the growth of highly flammable weeds) as well as storing tons of carbon that contribute to the greenhouse gases warming our planet.

This step marks the latest chapter in this process that began in 2005. During the Draft EIS review in 2013 approximately 13,000 comment letters were received by FEMA, 90% of them opposed to the proposed projects. In response to this public outcry FEMA reworked the EIS, and while the Final EIS is somewhat less destructive than the Draft EIS, it essentially calls for the same level of environmental damage, but over a longer time period.

The Hills Conservation Network is an Oakland, California based 501c3 comprised of residents of the Oakland hills that were directly affected by the 1991 fire. Several members of the group lost their homes in this conflagration and have committed themselves to driving change in Oakland to ensure that similar events never happen again. Members of HCN have been involved in the Grand Jury investigation of the ’91 fire and in developing enhanced emergency response capabilities in Oakland. Please direct inquiries to Dan Grassetti at 510-­‐849-­‐2601.

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