Two Cheers for NAP’s Herbicide Use in 2014

NAP Herbicide use by active ingredient 2014[Note: This article has been edited to add a secion on dead birds near Kezar Stadium.]

We’ve been following the use of hazardous herbicides by the Natural Areas Program (NAP) for some years now – and it’s been rising steadily. We recently compiled the data for 2014. For the first time since 2009, 2010, NAP’s use of Tier I and Tier II herbicides actually declined. (San Francisco’s Department of the Environment – SFDOE – sorts acceptable herbicides into three tiers. Tier III is Least Hazardous; Tier II, More Hazardous; and Tier I, Most Hazardous.) It’s even below 2010 levels, though considerably higher than 2009. We consider this an encouraging development.

The main herbicides NAP uses are:

  • Garlon 4 Ultra (triclopyr),
  • Stalker (imazapyr)
  • Aquamaster, also called Roundup Custom (Glyphosate)
  • Milestone VM (Aminopyralid)

Garlon is Tier I, and the other three are Tier II. NAP uses no Tier III herbicides. All these herbicides have downsides, but Garlon is the most problematic. SFDOE considers it a ‘high priority to find an alternative.’ Why?

  • Risks to humans – and the risk to women of child-bearing age is 20 times higher than to men
  • Risks to birds – relatively small amounts can reduce birds’ breeding success
  • Risk to animals – dogs may be especially sensitive to Garlon because their kidneys take longer to process the chemical.
  • Persistence – it can remain in the soil for years.

In 2008, Marin Municipal Water Department made a thorough review of several pesticides. The triclopyr chapter chapter from their draft report is linked here: Chap4_Triclopyr_8_27_08

A presentation from the California Invasive Plant Council (which supports the use of herbicides) has an interesting assessment of risk factors for various herbicides – including triclopyr. It’s linked here: Law_Johnson 2014 presentation toxicity

McLaren Park's Flowered Grassland and Forest

McLaren Park’s Flowered Grassland and Forest

The Natural Areas program is still the largest user of  Tier I herbicides in the SFRPD, (with one exception we’ll discuss below). It’s mainly Garlon used on oxalis, the yellow-flowering plant that covers San Francisco hillsides in spring, and which they consider an invasive non-native plant (together with about 35 species of plants, including fennel).

Oxalis flowers early and spectacularly in Spring, providing abundant nectar to bees, butterflies and other insects. It then dies back, making way for other plants. In any case, knocking back the oxalis merely opens the niche to the next most adapted plant, most likely also non-native, to expand into the vacated area.

OTHER MEASURES OF HERBICIDE USE

number of herbicide applications by NAP 2014The first graphs showed a comparison based in the volume of the active ingredient, which is the metric the Department of the Environment prefers. This second graph show NAP’s herbicide use in terms of number of applications (which is a proxy measure of breadth of exposure to the herbicides). The number of applications in 2014 rose slightly from 2013, but not close to the 7-year high in 2012.

NAP herbicide applications by volume 2014The third graph shows the volume of herbicides used (which includes both the active ingredient and the so-called ‘inert’ compounds that are not always in fact inert). Here too NAP has reduced its usage in 2014. By this measure, NAP still hasn’t dropped back to 2010 levels, mainly reflecting the changed product mix with less Garlon in 2014.

COMPARISON WITH OTHER SFRPD

In 2013, NAP used nearly as much herbicide as all of the rest of SFRPD put together. (We exclude Harding Golf Course, which is managed by the PGA Tour under contract and not by SFRPD.)

In 2014, NAP actually used a lot less herbicide than SFRPD. (Not as low as the 4% quoted by Mr Ginsberg, but only 26%. Since NAP has about a quarter of the total acreage owned by SFRPD within the city, this is more or less in line with the rest of the park.)

SFRPD overall (ex NAP and ex Harding) used a lot more herbicide than in 2014 than in 2013. Here’s why:

  • A mistake in Gleneagles.  In March 2014, Gleneagles golf course used a huge amount of triclopyr (512 fl ounces), while its normal usage is little or nothing. In fact, except for NAP, triclopyr is little used by SFRPD. Gleneagles also used 36 fl oz of Sapphire, a golf-specific product that is supposed only to be used when getting ready for a tournament. At the annual pesticide review meeting, SFRPD’s Integrated Pest Management Coordinator confirmed that it was a mistake by an outside contractor.
  • Kezar Stadium soccer field’s new herbicide. Kezar Stadium used Drive XLR8 (quinclorac) on the soccer field in November and December 2014.  This required an exception, because it’s not approved for use on city-owned property. The stadium was closed for three months, so SFDoE considered the risk acceptable. We wondered why, if the stadium was closed, they could not just plow the thing under and start anew, but apparently that would be a capital budget issue. We hope these kinds of questions do get asked somewhere in SFRPD. Coincidentally, Golden Gate Audubon reported a number of dead birds showing up in the area, but Drive XLR8 is not considered especially toxic to birds and there’s no indication the two things are related. [Edited to Add: Actually, they may be related. See section at the end.] Anyway, Chris Geiger of SFDOE confirmed Drive XLR8 was a Tier I pesticide that would not be moved on to the approved list; this usage was a one-off.

Adjusted for the two incidents above, SFRPD reduced its non-NAP herbicide use by about 20% from 2013 to 2014. In fact, its usage this year was below NAP’s herbicide usage for 2013, and it used only a tiny amount of Tier I herbicide. But for exceptional incidents like the ones described about, NAP remains the single largest user of Tier I herbicides in SFRPD.

NAP vs other SFRPD 2014 n 2013

We applaud NAP’s reduction of herbicide use in 2014, and call for it to eliminate use of all Tier I and Tier II herbicides.

DEAD ROBINS NEAR KEZAR

[This section was added 22 Feb 2015.]

As we mentioned above, there were reports of dead birds around Kezar Stadium. We learned that they were mostly robins (but Golden Gate Audubon also mentioned blackbirds and sparrows), and the person who found them spotted several dead birds where ordinarily even one is unusual. We assumed that the relationship with the Drive XLR8 used on the turf was unrelated, because our research indicated no especial threat to birds.

But further investigation suggest that the problem chemical could be not the active ingredient, but ethylene glycol used in the formulation. Ethylene glycol is better known as anti-freeze, and it’s toxic to mammals and birds. The Cornell University College of Veterinary Medicine says the following on its “Consultant” website:

“Ethylene glycol, antifreeze, toxicity is often fatal in birds. Oxalate crystals are found in renal tissue at necropsy.” It lists the signs, which include sudden death: “Anorexia, Ataxia, Diarrhea, Dullness, Dysmetria, Neck weakness, Seizures or syncope, Sudden death, Torticollis, Trembling, Tremor.”

Robins love digging in the grass for worms and such, and with the stadium closed they would have had undisturbed access. If the worms on the field were poisoned by ethylene glycol, so would the robins.  There’s no way to tell for sure, because as far as we know none of the dead birds was kept for a necropsy (like an autopsy for animals).

But anyway, the good news is that the Department of the Environment does not plan to use this product again.

 

 

 

Over 1700 Signatures to the Mayor!

Fairytale forest on Mt Davidson

Our supporters will recall that last year, we ran an online signature campaign specifically addressed to Mayor Lee, asking him to:

Stop NAP from destroying trees and thickets, spraying dangerous herbicides, disrupting healthy ecosystems that support hundreds of species, and restricting access to our city parks.

twin peaks - jan 2015 - imazapyr and garlon for poison oak cotoneaster oxalis

Stalker and Garlon on Twin Peaks – Jan 2015

NAP is the Natural Areas Program under San Francisco Recreation and Parks Department.  It is essentially a “native plant program.” It prioritizes native plant introduction (using the dog-whistle term “biodiversity”) over other values, whether environmental, ecosystem services, or recreational.

We had learned the Mayor’s office would respond to petitions directed to him via Change.org. That petition got over 1700 signatures, and is now closed.

However, our ongoing petition continues, and if you have not signed it, please do? (It currently has 1500 signatures as people shifted their focus to the newer petition.)

Stop NAP buttonWe need to keep sending the message that people want public parks preserved for the public, with trees, trails and no toxins.

Wishing You All a Good 2015!

The year end 2014 marked the third full year for this site, which was started in December of 2011. Now we’re well into the beginning of 2015 and the continuing fight to save our forests and natural spaces for the sake of the environment and for families who visit these places.

We’d like to wish all our readers a great year ahead by reprising these children’s drawings that we first posted in January 2014.

Save-the-Eucalyptus sm

Save the Eucalyptus by Desiree Minkler

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

The Morning Before the Loggers Came – Desiree Minkler

Whoos-For-Us

Whoos For Us? – Tacy Prins Woodlief

no-more-homeless-owls sm

No More Homeless Owls – Blake Bogert

poisoned-water

Poisoned Water – Ayumi Beeler

East Bay Trees to be Destroyed – How You Can Help

Our readers may recall that an extremely destructive project is planned for Berkeley and the East Bay Hills of the San Francisco Bay Area. It’s going to fell nearly half a million trees. 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, is not a significant improvement. It will still destroy hundreds of thousands of trees, increase fire hazard, destabilize slopes, and use huge amounts of herbicide.

The fight to save the trees and environment is not over. We ask you to support the Hills Conservation Network, which is spearheading the effort.

The article below is republished with permission and minor changes from Death of a Million Trees, which fights unnecessary tree-destruction.

FINAL EIS FOR FEMA PROJECTS IN THE EAST BAY IS NOT AN IMPROVEMENT!

On December 1, 2014, FEMA published the final Environmental Impact Statement (EIS) for the projects in the East Bay Hills which propose to destroy hundreds of thousands of non-native trees. FEMA’s email announcement of the publication of the EIS implied that the projects had been revised. Two of the agencies applying for FEMA grants—UC Berkeley and City of Oakland—had originally proposed to destroy all non-native trees on their properties. The third agency –East Bay Regional Parks District—had proposed to thin non-native trees in most areas and destroy all in a few areas. FEMA’s email announcement of the final EIS implied that both UC Berkeley and City of Oakland would be required to use the same “thinning” strategy as East Bay Regional Parks District.

After reading the final EIS, the Hills Conservation Network (HCN) is reporting that FEMA’s email announcement was rather misleading. In fact, both UC Berkeley and City of Oakland will be allowed to destroy all non-native trees on their properties. In a small sub-section (28.5 acres) of their total project acres (406.2 acres), UC Berkeley and City of Oakland are being asked by FEMA to destroy the trees more slowly than originally planned. However, they will all be destroyed by the end of the 10 year project period.

HCN has analyzed the EIS and consulted legal counsel. The following is HCN’s assessment of the EIS and their plans to respond to FEMA. We publish HCN’s assessment with their permission. Note that HCN is asking the public to send comments to FEMA and they are raising funds to prepare for a potential legal suit.

HCN LETTER

“After having reviewed the Final EIS in depth and having consulted with various stakeholders, HCN has concluded that the Final EIS, in spite of FEMA’s efforts to improve it from the Draft version, remains unacceptable.

“While FEMA has made some modifications to portions of the EIS in response to the enormous number of comments submitted last year [more than 13,000], the fact remains that if implemented in their current form, these projects would remove essentially all of the eucalyptus, pines, and acacias from the subject area. While for portions of the area FEMA is now proposing that there be a phased removal of these species, the fact remains that the objective is ultimately to convert the current moist and verdant ecosystem into one dominated by grasses, shrubs, and some smaller trees. This will forever alter the character of these hills that so many of us have grown up with, know and love.

“But worse than that, these projects would actually increase fire risk, destabilize hillsides, cause immense loss of habitat, release significant amounts of sequestered greenhouse gases, and require the use of extraordinary amounts of herbicides over a large area for at least a decade.

“Additionally, by preemptively clearcutting 7 acres of Frowning Ridge in August of this year, UC not only made a clear violation of FEMA rules but also essentially negated the accuracy and relevance of the EIS. While FEMA acknowledges this in the EIS, they still want to move forward with a document that may no longer accurately reflect the reality of the current environment, the cumulative impacts of these projects, and any of the other factors that underpin the EIS process.

“For these reasons, HCN will be submitting a comment letter to FEMA asking that the EIS be pulled back, reworked, and recirculated….at a minimum. Additionally, we are currently exploring legal options should the EIS be finally released on January 5, 2015 in its current form. One way or another, we are committed to ensuring that the will of a small number of influential people doesn’t result in the loss of a treasured resource to the vast majority of us (both human and other).

We ask your support in sending additional comment letters to FEMA [ebh-eis@fema.dhs.gov] and most importantly that you consider making a tax-deductible contribution to HCN. While we wish we did not have to do this, the fact is that the only way we can have a shot at preventing this irreparable harm from happening is by hiring lawyers, and that is what we will do. This takes money, so please do what you can either by sending a check to HCN at P.O. Box 5426, Berkeley, CA 94705 or by making a donation through our website at http://hillsconservationnetwork.org/HillsConservation3/Support_HCN.html.

“Thanks again for all your support,

“Hills Conservation Network”

We Stand With the African American Community

black lives matterThis website normally focuses on issues relating to the environment, and more specifically to the damage being done by “nativist” thinking that destroys trees and habitat to favor “native” plants. But this topic is too important for us to ignore.

With a growing sense of outrage and concern, we’ve watched what has happened to African American adults and children – that they cannot assume they will get the same rights and consideration that others do in this country. We’re dismayed that parents need to talk to their young children, particularly their sons, about the special submissive behaviors they must adopt to avoid getting killed.

The San Francisco Forest Alliance cannot be silent on this. We stand with many other environmental organizations in our support of the movement for change. (Here’s a picture from The Pesticide Action Network )

We stand against prejudice and embedded bias, and stand with communities of color in their struggle.

Black Lives Matter.

Vandal Destroys Castro Street Tree

Someone sent us this video yesterday. (It was made on Thursday, Dec 11, 2014.) We cannot understand why anyone would destroy a tree like that.

“At 5:34am yesterday (as the big storm was starting), someone broke off the top of the young tree that was planted on the sidewalk outside 489 Noe St in the Castro. Here is a video (less than 1min long):

[Webmaster: In case that doesn’t come up, here’s the URL:

“I’m sending this to you on the off chance it might help with efforts to find people doing things like this. I checked a few news articles about similar vandalism in parks in the city and saw your organization mentioned. This attack seemed similar to the systematic ones I read about in the parks.”

The sender has filed an online police report. We hope the culprit is caught before more trees are destroyed. We hope this helps.

New “Restoration” Goals Make Even Less Sense

This important article describes how the goals of “restoration” have shifted to an even less realistic objective than before. New data shows that Nature isn’t static. Instead of a “balance of nature”, ecologists recognize “a dynamic, often chaotic nature buffeted by constant disturbances.”  The old goal – attempting to re-create an idealized pre-European ecosystem – is therefore pointless. (In San Francisco, the ‘target date’ of nativists is 1769 or 1776.)

But the new goal edges into the realm of science fiction: It imagines an alternate reality in which the ecosystem evolved without humans, and seeks to “restore” to that trajectory.

This article is re-reprinted with permission and minor changes from Death of a Million Trees, an effort to stop unnecessary destruction of trees in the San Francisco Bay Area.

 

WHAT IS THE GOAL OF ECOLOGICAL “RESTORATIONS”?

In the not-so-distant past, the goal of ecological “restoration” was usually described as the re-creation of an historical landscape that was believed to have been undamaged by humans, presumed to be “in balance” and therefore sustainable after “restoration” without further human management. In North America, the pre-European landscape is usually selected as the ideal landscape to be replicated, based on the assumption it had not been radically altered by Native Americans. New knowledge has overturned this model:

Native Americans setting grass fire, painting by Frederic Remington, 1908

Native Americans setting grass fire, painting by Frederic Remington, 1908

Oddly, many invasion biologists accept these new understandings of ecological science without changing their deep commitment to eradicating all non-native plants and animals. Daniel Simberloff published an article about the current status of the concept of “balance of nature” simultaneously with the publication of his defense of invasion biology. He described the current thinking about this concept: “…a widespread rejection of the idea of balance of nature by academic ecologists, who focus rather on a dynamic, often chaotic nature buffeted by constant disturbances.”

Invasion biologists have therefore revised their goal for ecological “restorations” to accommodate their new understanding of the dynamic nature of ecosystems.

THE REVISED GOAL OF ECOLOGICAL “RESTORATIONS”

If the return to an equilibrium state is no longer the goal of ecological “restorations,” what is the new goal? This is how invasion biologists writing in defense of their discipline described their goal: “…we should seek to reestablish – or emulate, insofar as possible – the historical trajectory of ecosystems, before they were deflected by human activity, and to allow the restored system to continue responding to various environmental changes…” (1)

In this post we will deconstruct this new definition of the goal of ecological “restorations.” Our first problem with this new definition is that we don’t know the “historical trajectory” of a landscape because it is fundamentally unknowable. We would have to reconstruct all the events and changes in the environment in the Bay Area in the past 250 years in the imagined absence of any Europeans. Even if we knew what would have happened without our presence, we cannot then ensure the continuation of that imagined environment because, the fact is, WE ARE HERE AND WE AREN’T GOING AWAY!

Because we cannot reconstruct an imagined environment that has not been “deflected by human activity,” restorationists—who are the practitioners of invasion biology–focus on the one element in the environment of which there is sufficient historical knowledge, i.e., plants. Most local restoration projects eradicate all non-native plants and trees, usually using herbicides to accomplish that task. They rarely plant anything after this eradication attempt because they don’t have the resources to do so. Those few projects that re-plant after non-natives are eradicated usually irrigate the new landscape for several years. Here is an incomplete list of everything these projects do not do to replicate an historical landscape:

  • Soils are not restored for many reasons:
    • We have no way of knowing the composition of soil 250 years ago.
    • Soils have been altered by the plants that have been growing in them and by the herbicides used to kill those plants.
    • Urban soils have high nitrogen levels resulting from exposure to fossil fuel exhaust.
  • The atmosphere is not restored:
    • There are much higher levels of ozone and carbon dioxide than there were 250 years ago.
  • The climate is not restored:
    • The temperature is higher than it was 250 years ago.
    • The timing of seasons has therefore changed.
    • Precipitation and fog have changed in known and unknown ways.
  • The disturbance events that sustained historical landscapes or set them on another evolutionary course are not restored:
    • We cannot set fire to urban landscapes annually without polluting our air and endangering our lives.
    • We cannot allow our creeks and rivers to overflow in urban areas without damaging our properties.
  • Most occupants of the historical landscape are not reintroduced:
    • The grazing animals that helped to sustain grassland are gone and cannot be returned to urban landscapes.
    • The top predators such as bears and wolves that kept grazing and other animals in balance with available resources cannot be returned without threatening our safety in an urban setting.
    • Many insects that lived in these historical landscapes are unknown to us and some are extinct.
The El Cerrito Plaza with the Albany Hill in the background, centuries ago.  Oil painting by Laura Cunningham, with permission

Bears roamed the grasslands in the Bay Area, preventing over-population of grazing animals. The El Cerrito Plaza with the Albany Hill in the background, centuries ago. Oil painting by Laura Cunningham, with permission

In other words, destroying plants will not “restore” an historical landscape. Nor will it return that landscape to its “historical trajectory” even if that trajectory were known or knowable. Plants live in complex communities in which they are interacting with everything in the environment. Local “restoration” projects do not “restore” an historical landscape because they do not and cannot change anything other than the plants that occupy the space. Because most environmental variables have not been altered by these projects, the landscape will quickly return to its unrestored state unless it is intensively gardened. In that case, the landscape will be continuously “deflected by human activity,” which violates the original goal of invasion biologists.

MISANTHROPIC PREMISE OF INVASION BIOLOGY

The revised goal of invasion biology is unattainable because the absence of humans is a prerequisite for its attainment. We cannot know and we cannot replicate a theoretical historical trajectory for ecosystems in which humans were not present. And when we modify ecosystems in an attempt to do so, human activities will determine their future trajectory. The premise of invasion biology is that success of ecological “restorations” depends upon the absence of humans. Therefore, invasion biology has no practical application in the real world.


  1. Carolina Murcia, James Aronson, Gustavo Kattan, David Moreno-Mateos, Kingsley Dixon, Daniel Simberloff, “A critique of the ‘novel ecosystem’ concept,”Trends in Ecology and Evolution, October 2014, Vol. 29, No. 10
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