Submitting Comments on the Draft EIS

Written comments must be submitted or postmarked by midnight on June 17, 2013. Oral and written comments may be made at any of the three public meetings. Written comments may also be submitted through:

•     via email at EBH-EIS-FEMA-RIX@fema.dhs.gov,
•     via fax at FAX: (510) 627-7147, or
•     via mail to P.O. Box 72379, Oakland, CA 94612-8579.

If you’re considering submitting a comment, please do so now.  The Draft EIS is available HERE; it’s a long document. The Executive Summary is quite short – and telling. It’s here as a 16-page PDF: Executive+Summary-East Bay

Please ask FEMA not to fund a futile Native Plant restoration project that will only increase the fire hazard by:

• Destroying the wind-break;
• Converting living trees into dead fuel on the ground;
• Reducing landscape moisture from fog drip during the summer; and
• Encouraging the growth of  more-flammable plants.

It will also use  thousands of gallons of toxic pesticides on steep hillsides where they can get into the watershed.  It will  release carbon emissions on a huge scale. This project is not only environmentally destructive, it is a huge waste of funds that should be used to actually reduce hazards, not increase them.

Ask them to approve the No Project alternative.

Photo credit: http://www.milliontrees.me

THE PROJECTS

The East Bay Hills projects include three related projects by UC Berkeley, the City of Oakland, and the East Bay Regional Park District (EBRPD). They all seek money from FEMA to cut down trees as a “fire hazard.”

The first two projects (UC Berkeley/ Oakland Hills) will essentially clear-cut all the non-native trees in the projects areas: eucalyptus, Monterey Pine (yes, it’s “non-native”!) and acacia. This would be around 77,000 trees. They will chip the smaller trees and branches, leaving a mulch up to 2 feet deep on the ground. The larger branches and logs will be left unchipped. Pesticides – Roundup, Garlon, and Imazapyr – will be used to prevent re-sprouting and to kill non-native shrubs. They hope that native plants and trees will move into the treated areas, creating an oak-bay woodland.

The third project (EBRPD) is slightly different, in that it proposes to “thin” the forest and cut down some 409,000 trees  but leave around 60 trees per acre standing. It proposes chip the felled trees, spread the wood chips as mulch to a depth of 4-6 inches and burn the rest. It also plans to use prescribed burns to control the understory.

You can read about this plan and the tree removal calculations HERE.

Even though this has been positioned as a fire hazard reduction project, it is clearly targeted at native plant restoration – using Federal Emergency Management funds.  All the management actions are likely to increase fire hazard. Those pushing this plan have emphasized the flammability of eucalyptus (which isn’t actually more flammable than most trees) but avoided the more important comparison: Will the landscape that will replace a felled eucalyptus forest be even more flammable?

East Bay Express article. Photo credit East Bay Express

There’s a good article about this in the East Bay Express, HERE

A LOSE-LOSE-LOSE PROPOSITION

In fact, this is a Lose-Lose (actually a Lose-Lose-Lose-Lose-Lose!) Plan. Here’s why:

• Those seeking a reduction in fire hazard – which is, really everybody – will find that instead the fire hazard has increased, as we’ll explain below.
• The Native Plant enthusiasts who hope that Native Plants and trees will recolonize the treated areas will be disappointed. There’s no plan to replant or to garden those areas; the only tools are a deep mulch of eucalyptus chips and non-selective pesticides. This article suggests that the most likely plant to move into such areas would be broom – which is non-native and considered invasive because it can actually deal with the kind of conditions that will result.
• Anyone who loves trees and the environment, which will suffer from the loss of carbon storage and pollution control, not to mention the beauty of the trees. Actually, most of the residents of the Bay Area.
• FEMA, which could have used the funds for competing projects that reduce, not increase, hazards.
• The taxpayer who will be paying for this anti-environmental mess.

The worst of it is that it is essentially irreversible.  If the planners realize that most of what the opponents say is true, they cannot grow back trees that took decades to become what they are now. They cannot sequester the carbon they’ve released. They cannot cure the people whose health has been adversely affected by pesticides.  All they can do is declare victory and move on.

Is there a potential win for anyone? Well, maybe. It will empower the people who will be giving out the contracts, and benefit the contractors who actually do the work and the pesticides suppliers.

And UC Berkeley’s Long Range Development Plan calls for building 100,000 square feet of additional space in the hills. It would undoubtedly be convenient to have the tree removal funded by FEMA.

PROBLEMS WITH THE PROJECT AND THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

• This plan will convert living trees full of moisture into fuel – dead wood and wood chips on the ground. These are much more flammable than any living tree. In fact, even one of the research papers the EIS quotes says as much: “Sites where the activity fuels piles had not been burned or where they had been masticated (mechanically chipped into small pieces and spread over the treatment area) were excluded from the study because research suggests these additional fuels increase fire severity.” (Malcolm North and Matthew Hurteau, “High-severity wildfire effects on carbon stocks and emissions in fuels treated and untreated forest,” Forest Ecology and Management 261 (2011)) 
• The wood chips could take up to 20 years to decompose. According to the EIS, they have a “half-life” of 5 years, meaning that half of it will be gone in five years.  A pile that’s 2 feet high would be 12 inches deep in 5 years, and 6 inches deep in 10 years – leaving a fire hazard there for decades. And there’s also the potential for subsurface smouldering fires that can burst out under the right conditions.
• Wind speeds will rise since the wind breaks provided by the trees would be gone. Fires in the East Bay are wind-driven fires, and eucalyptus and other tall trees actually fight fire by breaking the wind-flow. Even the EPA recommended preserving large and tall trees in place (according to Appendix K2 of the EIS).
• The replacement landscape will be more flammable. Removing trees will encourage grasses and shrubs, making for a more flammable landscape of faster-moving fires that can reach structures more quickly. The forest shade tends to inhibit the growth of these plants. The plans intend to encourage the growth of native plants – but doesn’t provide for planting or tending them. They assume that the existing seed banks and seeds from adjacent areas will grow there. Actually, it’s more likely that  broom and other fast-growing non-native species will take over. When these dry out, they are much more flammable than the trees. In any case, the native chapparal is also very flammable.
• The loss of shade and the moisture harvested from the fog will make for a drier, more fire-prone landscape. The EIS suggests that the harvested moisture is compensated by the trees using moisture from rain, so the net amount of water is the same. This is just silly: the fog comes in California’s dry season, and provides additional moisture at a time when the landscape is dry and thus lessens flammability.  During the rains, the landscape is green and not flammable.
• If some of this acreage does actually become oak-bay woodlands, as the land managers hope, there’s another problem: Sudden oak death, which is spreading through California and could provide dead trees as fuel. The EIS ignores this threat entirely.

• The Draft EIS significantly understates the effect on carbon sequestration. The trees will no longer store carbon; instead, they will be releasing thousands of tons of it into the atmosphere. But the EIS ignores the carbon stored in the branches, leaves, and roots of the felled trees, and in the soil. They also miscalculate the amount of carbon that will be released in the EBRPD section of the plan. They may have ignored 80% of the actual carbon emissions caused by the project.
• Thousands of gallons of toxic herbicides will be spread over the East Bay.
• Prescribed burns will further affect air quality, and could get away and cause wildfires and serious damage.
• Erosion and landslides could occur on steep slopes when the tree roots no longer stabilize the slopes.
• Increased wind speeds with the loss of wind-breaks will affect quality of life, and likely cause the wind-throw of non-targeted trees.

WHAT ELSE YOU CAN DO

Sign a Petition

If you have not yet done so, sign the Hills Conservation Network petition. It has over 5500 signatures already.

Contribute. Hills Conservation Network are also raising funds for potential legal action. If you would like to contribute, their website is HERE and includes a Paypal button.

Why is the mountain’s Eastern side bare of trees?

If you took historian Jacquie Proctor’s hiking tour of Mt. Davidson for SFForest last year, these questions were answered.

But whether or not you did: you are invited to her ALL NEW slideshow this summer about the history of the City Beautiful Movement-inspired neighborhoods on the slopes of San Francisco’s highest hill––Mt. Davidson––as well as the story of the unique City park and monument at its peak, as featured in her book, San Francisco’s West of Twin Peaks. See the following San Francisco Public Library locations and dates:

Tues., June 18 at 7 PM – Parkside Branch (1200 Taraval St at 22nd)
Tues., July 2 at 6:30PM – Anza Branch (550 37th Ave.)
Wed., July 10 at 7 PM – Merced Branch (155 Winston Dr.)
Sat., July 13 at 2 PM – Ingleside Branch (1298 Ocean Ave. at Plymouth)
Mon., July 29 at 7:00 PM – Sunset Branch (1305 18th Ave.)

(If you attended the walk – Jacquie has updated information and pictures.)

Trees clean the air in two important ways:

1. They absorb polluting gases from the air, including carbon monoxide, nitrogen oxide, and sulfur dioxide. Some trees also emit “volatile organic compounds,” but overall, a grove of trees has a net positive effect.
2. Perhaps even more important in a city environment, trees capture particulate pollution on their leaves, especially tiny particles under 10 microns. These otherwise can stay suspended in the air, and people breathe them in. The particles trapped on the leaves can become airborne again, but more often they are washed to the ground in rain or fog-drip, and become part of the soil.

Fought pollution for over 100 years, until felled in January 2013

As you might expect, large trees fight urban pollution more than do smaller trees. The chart below is based on a data in the USDA 2007 publication, “San Francisco’s Urban Forest.”   It shows the average amount of pollution (in ounces) removed by small, medium and large trees each year.

This is just one more reason that felling mature trees is bad for the urban environment. The small replacement saplings – even if they are planted in the same areas -  will not have the same effect on air pollution.

(You can download the entire publication here as a 26-page PDF: SF Urban Forest fs fed US)

EUCALYPTUS IS IMPORTANT AS HABITAT

Eucalyptus trees are hugely important as habitat trees. They provide cover and nest sites for birds as large as Great Blue Herons and Double-Crested Cormorants and hawks and Great Horned Owls – and as small as Pygmy Nuthatches.

[Edited to Add: For more pictures of heron and cormorant nests - and the story that goes with them - please see the latest article on the Coyote Yipps blog. ]

Great Blue Heron Nests in Eucalyptus – Photo: Janet Kessler

Double-crested cormorants nest – Photo: Janet Kessler

Rookery tree – Photo: Janet Kessler

Young Great Horned Owls being raised in Eucalyptus tree. Photo: Janet Kessler

Their branches and trunks provide a hunting ground for small birds like kinglets and Brown Creepers.

Brown creeper forages on eucalyptus. Photo: Janet Kessler

Since they flower in winter when few other food sources are available, they provide nectar for insects – and the birds that feed on the nectar, the insects, or both. Honeybees in particular depend on winter-flowering eucalyptus. Cavities provide nesting spot for some birds – and even bees, like Glen Canyon’s last remaining bee hive tree.

Beehive in eucalyptus tree (bees circled in red) – Photo: Janet Kessler

DEAD TREES ARE IMPORTANT

Dead or dying trees – of every species – are valuable habitat, for two reasons. They’re more likely to have cavities that are suitable for nesting (and are easier to excavate for woodpeckers and other cavity-building species). They also have bugs that come to feast on the decaying wood, and that’s bird-food.

Hairy woodpecker in Glen Canyon Park. Photo: Janet Kessler

Unfortunately, the San Francisco Recreation and Parks Department – and now UCSF in its management of Sutro Forest – looks to remove ‘snags’ and dying trees.  They’ve been removed in Glen Canyon Park, and in Golden Gate Park, and this fall, massive removals could start in Sutro Forest.

Glen Canyon Park, Hairy Woodpecker. Photo: Janet Kessler

If that happens, it will have a negative impact on all the woodpeckers and cavity-nesting species of birds and even bats. It’s extremely important to leave these ‘in-decline’ trees as habitat, unless they are actually hazards.

THE VALUE OF IVY AND THICKETS

Smaller birds and animals in particular need the cover provided by ivy and understory plants to hide from predators – and to nest.

Here’s a picture of a tiny Bewick’s Wren outside its Glen Canyon nest, taken in 2012. The tree it’s nesting in is so ivy-covered you can’t actually see it. The nest is completely hidden.

Bewick’s wren outside nest. Photo: Janet Kessler

Here’s the same tree this year. The ivy is gone, the understory mowed down. Is the wren coming back? Not too likely.

This year there’s no nesting spot for the wren. Photo: Janet Kessler

To recap: Three owners/ land managers are involved:

• University of California at Berkeley (60,000 trees on 284 acres)
• City of Oakland (26,000 trees on 126 acres);
• East Bay Regional Parks District (400,000 trees on 1,650 acres).

They would use Garlon to prevent resprouting (which would require thousands of gallons of this very toxic herbicide), and glyphosate (Aquamaster or Roundup) to discourage the growth of non-native plants. The first two projects plan to remove all the non-native trees in the project areas. The third plans to “thin” the trees to about 60 trees per acre, removing around 90% of the trees on the project area, and using prescribed burns in addition to pesticide.

You can read about this plan and the tree removal calculations HERE.

MEETING REPORT

An estimated 160-175 people attended, and the meeting, scheduled for 2 hours, ran nearly twice that long. There was standing room only, with people crowding the sides of the room and sitting on the floor. Of the 56 people who spoke, 48 opposed the Plans to fell these trees. That’s over 85% of the speakers.

The themes:

1. They didn’t know about these plans, even though they live nearby. They heard about them from friends and from social media. The outreach was poor.
2. People were very concerned about the use of pesticides. Roundup in particular was criticized. (Most people are not familiar with Garlon, which is probably even more toxic than Roundup – and also included in the Plans.)
3. They were also concerned about greenhouse gases, which are causing climate change. Trees store carbon; not only will they stop doing that, but felling and “mulching” so many trees will release carbon dioxide into the air.
4. If the intention is to reduce the fire hazard, other alternatives should have been considered.
5. Most people wanted to preserve the ecosystem and trees that are already there; it would be  unconscionable to wreck it.
6. All the areas are on hillsides; speakers were concerned about soil erosion.
7. They were also worried about contamination of streams/watershed.
8. Some commenters felt Hills people were arrogant, more concerned about property than people.
9. Some speakers declared we should stop interfering with nature, and keep as many trees as possible to protect us from the pollution we have created.
10. Clear-cutting and spraying the ground with chemicals will create a wasteland.

There’s a report from The Berkeley Patch HERE: Plan to Cut 85,000 Trees in Berkeley and Oakland Hills Draws Crowd. In the photograph with that article, two people hold signs:

“FOLLOW THE MONEY“  and “WILLFUL DESTRUCTION OF AN ENTIRE ECOSYSTEM IS A CRIME AGAINST NATURE.”

Others reported signs saying things like “KILL THE PROJECT, NOT THE TREES” and “NO CHEMICALS IN OUR PARKS.”

STILL TIME TO COMMENT

Though all the public meetings are now over, you can still comment on the Plan in writing up to June 17th.

FEMA has published the Draft Environmental Impact Report for these projects, and will accept comments until June 17th, 2013. That is available HERE; it’s a long document. The Executive Summary is quite short – and telling. It’s here as a 16-page PDF: Executive+Summary-East Bay You may submit written comments in several ways:

1. Via the project website: http://ebheis.cdmims.com
2. By email to EBH-EIS-FEMA-RIX@fema.dhs.gov
3. By mail: P.O. Box 72379, Oakland, CA 94612-8579
4. By fax: 510-627-7147

The Hills Conservation Network’s petition is gaining momentum; it has over 1875 signatures as we write this. If you haven’t signed and would like to do so, this button will take you to the petition.

Hills Conservation Network are also raising funds for potential legal action. If you would like to contribute, their website is  HERE  and includes a Paypal button.

WHAT’S WRONG WITH THESE PROJECTS

We bring you some of the criticism of these projects (this is based on a critique from the Hills Conservation Network). These projects would:

1. Shift the ecosystem from trees to flammable dry brush. These projects would permanently alter the Berkeley/Oakland hills ecosystem, and make it much more – not less – flammable.  UC and Oakland plan to clear-cut mature, healthy trees, including huge 100-year-old trees taller than ten-storey buildings. You won’t see tall trees in the hills any more. What you will see, as soon as the rain stops, will be weeds and highly flammable brush, brown, dry, and ready to burst into flame. This easily ignitable chaparral (including scrub oaks), weeds, grass, hemlock, thistle and broom will burn more easily than trees. It’s lower, finer, and dry as kindling. Thick trunks don’t burn easily, and fire does not reach the crowns of trees unless there are ladder fuels (like weeds, grass, etc. under them).
2. Waste our money. If you include the matching funds, this is going to be a $7 million plan to destroy forests miles from homes. Instead, that money could be used as originally intended: actually reducing fire hazards by, for instance, creating defensible space around houses and other structures.
3. Slather the hills in herbicides. To prevent trees from resprouting, the hills would be drenched with massive amounts (30,000 + gallons) of toxic pesticides.  In addition, pesticides will be sprayed throughout the watershed to knock down the weeds, hemlock, poison oak, thistle and broom  that will emerge with the loss of canopy. Toxic sediments will seep into our creeks and could permanently alter the watershed. Garlon causes cancer and so does glyphosate (Roundup) when sprayed broadcast over large areas. Tons of pesticides will be needed to maintain the site—to kill the weeds—after the trees are removed.  Making matters worse, UCB has not posted signs when pesticides are sprayed.
4. Use a two-foot mulch doesn’t work and raises ignition risk. They’re planning to chip the trees on site, leaving up to 24 inches of chip litter on the ground.  There’s danger of subterranean fire under the chips, as well as spontaneous ignition in the hot sun – as in a hay stack. Anyway, areas where it’s been tried have been invaded by hemlock, thistle, broom and poison oak.
5. Release stored carbon and change the microclimate. As the chips decompose, they release carbon, adding to global warming. Nothing stores carbon like big trees; we’ll permanently lose the carbon storage these trees gave us. Tree loss will also cause local climate changes: more wind, more dry air, less fog, more air pollution.
6. Cause Habitat loss and ecological imbalance. The plans would destroy an enormous amount of habitat; the tall trees favored by raptors such as owls and hawks would be lost forever. Without raptors to keep them in check,  the rodent population will undoubtedly increase. We saw this after the 1991 fire. And what about the federally protected Alameda whipsnake?  It’s unrealistic to believe they can be trapped and translocated until after completion.
7. Cause erosion and landslides. Without tree roots to hold the soil in place, erosion and landslides will increase.
8. Make for visual blight, daily road closures, and constant chainsaw noise for 3 years.

WHAT’S WRONG WITH THE DRAFT EIS

Comments that are specific about the flaws in the EIS will be most effective:

1. The fire model is wrong. It compares the fire danger of standing forests with the fire danger (zero) after the trees are cut down to stumps. It does not consider the fire risk danger—much worse—of what will replace the trees.
2. This is Native Plant gardening, not fire mitigation.  Fostering the growth of native plants such as bay trees, chaparral and oaks is native plant restoration.  It has nothing to do with fire risk mitigationFEMA funds were not intended to promote a particular plant ideology.
3. It doesn’t adequately address impacts on Greenhouse Gases. It uses an inappropriate baseline, and also does not properly estimate the loss of ongoing carbon sequestration. The EIS needs to be reworked.
4. It doesn’t properly address the costs and risks from the huge increase in toxic herbicide use.
5. It does not adequately analyze reasonable alternatives proposed for fire risk mitigation. Far less costly, far less environmentally damaging, and far more effective methods have been proposed, but the EIS fails to consider them. The EIS needs to be reworked to analyze reasonable alternatives rather than simply dismissing them without any analysis.

Climate change is upon us. Recently, we crossed the threshold of 400 parts per million of carbon dioxide in the Earth’s atmosphere – higher than at any time since humans populated our planet.

Aside from reducing carbon emissions, trees are the only way to fight climate change. They pull carbon dioxide from the air and store the carbon in their wood, roots, and the soil around them. But instead of planting trees, Native Plant interests are trying to fell trees to recreate a different ecosystem of shrubs and grasses. Multiple projects now threaten our Bay Area trees, with different rationales but the same underlying objective – native plants.

San Francisco’s Natural Areas program may fell 18,500 trees; the Sutro Forest project – 30,000 trees; the East Bay Hills projects – 500,000 trees. In addition, SFRPD is felling hundreds of trees in Golden Gate Park as ‘urban forestry’ and there’s the ‘normal’ destruction of trees for construction and similar purposes.

For this reason, we think the article below – reprinted with permission from Death of a Million Trees – is extremely important.

CARBON STORAGE IN OUR URBAN FOREST

We believe that addressing climate change should be our highest environmental priority because it is the cause of many environmental problems. For example, a recent study found that changes in climate accounted for over half of the significant changes in vegetation all over the world in the past 30 years: “The climate governs the seasonal activity of vegetation…In humid mid-latitudes temperature is the largest influencing factor in plant growth. In predominantly dry areas, however, it is the availability of water and in the high altitudes incident solar radiation.” (1) Animals are affected by both changes in vegetation and climate, as exemplified by the shrinking home of the polar bear as Arctic ice melts.

The consensus amongst scientists is that increases in greenhouse gas emissions are the primary cause of climate change and carbon dioxide is the predominant greenhouse gas. Although the burning of fossil fuels is often considered the biggest source of greenhouse gas emissions, in fact transportation is responsible for only 10% of emissions. In contrast, deforestation is contributing 20% of greenhouse gas emissions because trees store carbon as they grow and release it into the atmosphere as carbon dioxide when the tree is destroyed. For that reason—and many others– we are opposed to the destruction of our urban forest.

Mount Sutro Forest is threatened with destruction because it is not native. Courtesy Save Sutro Forest.

Because our urban forest is predominantly non-native, native plant advocates are committed to defending the projects that are destroying the urban forest, which puts them in the awkward position of claiming that its destruction will not contribute to climate change. Here are a few of the arguments used by native plant advocates and the scientific evidence that those arguments are fallacious:

• Since the native landscape in the Bay Area is grassland and scrub, native plant advocates often claim that these landscapes store more carbon than trees. In fact, trees store far more carbon than the native landscape because carbon storage is largely proportional to biomass. In other words, the bigger the plant, the more carbon it is capable of storing. (Carbon storage in plants and soils is explained in detail here.)
• In the Draft Environmental Impact Report for San Francisco’s Natural Areas Program, native plant advocates claimed that destroying the forest and restoring grassland would lower ground temperatures based on a scientific study about the arctic north at latitudes above 50°. In fact, the point of that study was that snow reflects more light than trees. The Bay Area is far below 50° latitude and it doesn’t snow here, so that study is irrelevant to the Bay Area. (That study and its misuse by native plant advocates are reported here.)
• Since most of the urban forest in the Bay Area was planted over 100 years ago, native plant advocates often claim that only young trees store carbon. Since carbon storage is largely proportional to biomass, mature trees store more carbon than small young trees. That is illustrated by this graph from the US Forest Service survey of San Francisco’s urban forest.

Larger trees store more carbon at a faster rate

• The claim that young trees store more carbon is often made in connection with the equally bogus claim that “restoration” projects in the Bay Area will replace non-native trees with native trees. None of the plans for these projects propose to plant native trees where non-native trees are destroyed because that wasn’t the native landscape. In any case, native trees don’t tolerate the windy, dry conditions in which non-native trees are growing. For example, a study of historic vegetation in Oakland, California reported that only 2% of pre-settlement Oakland was forested with trees. (2)

A NEW STUDY ABOUT CARBON STORAGE IN FOREST

Now that science has established the reality of climate change, most scientific inquiry has turned to how to stop it and/or mitigate it. For example, a recent study reports that planting forests where they did not exist in the past, quickly stores far more carbon in the soil than the treeless landscape. Scientists “…looked at lands previously used for surface mining and other industrial uses, former agricultural lands, and native grasslands where forests have encroached….[they] found that, in general, growing trees on formerly non-forested land increases soil carbon.” (3)

Here are their specific findings on each type of previously non-forested land:

• “On a post-mining landscape, the amount of soil carbon generally doubled within 20 years and continued to double after that every decade or so.”
• “The changes after cultivation of farm fields was abandoned and trees became established are much subtler, but still significant…at the end of a century’s time, the amount of soil carbon averages 15 percent higher than when the land was under cultivation…”
• “In places where trees and shrubs have encroached into native grassland, soil carbon increased 31 percent after several decades…”

Mainstream environmental organizations such as the Sierra Club claim to be concerned about climate change, yet they are the driving force behind the destruction of the urban forest in the San Francisco Bay Area. When will they wake up to the fact that advocating for the destruction of the urban forest is irresponsible for an environmental organization in the age of climate change?

*******************************

(1) “A Look at the World Explains 90 Percent of Changes in Vegetation,” Science Daily, April 22, 2013.

(2) Nowak, David, “Historical vegetation change in Oakland and its implications for urban forest management,” Journal of Arboriculture, 19(5): September 1993

(3) “Soils in Newly Forested Areas Store Substantial Carbon That Could Help Offset Climate Change,” Science Daily, April 4, 2013.

In the East Bay, there are three inter-related plans to cut down nearly 500 thousand eucalyptus and other trees on 2,000 nearly 1500 acres of land.

Forest at Lake Chabot – Photo credit: MillionTrees.me

Three owners/ land managers are involved:

• University of California at Berkeley (60,000 54,000 trees on 284 acres)
• City of Oakland (26,000 23,000 trees on 126 acres);
• East Bay Regional Parks District (400,000 409,000 trees on 1,650 1,060 acres).

They would use Garlon to prevent resprouting (which would require thousands of gallons of this very toxic herbicide), and glyphosate (Aquamaster or Roundup) to discourage the growth of non-native plants. The first two projects plan to remove all the non-native trees in the project areas. The third plans to “thin” the trees to about 60 trees per acre, removing around 90% of the trees on the project area, and using prescribed burns in addition to pesticide.

You can read about this plan and the tree removal calculations HERE.

WHAT THEY HOPE AND WHY IT WILL FAIL

The plan is described as ‘fuel reduction’ to lessen the fire hazard. In fact, is likely to have the opposite effect.

• Wind speeds will rise since the wind breaks provided by the trees would be gone.
• With the trees and shade gone,  finer fuels like grasses and shrubs will grow instead.
• The loss of shade and the moisture harvested from the fog will make for a drier, more fire-prone landscape.
• The felled trees will be left in place, contributing dead wood to the fuel load.

The plans intend to encourage the growth of native plants -  but doesn’t provide for planting or tending them. They assume that the existing seed banks and seeds from adjacent areas will grow there. Actually, it’s more likely that blackberry and broom and other fast-growing non-native species will take over. If some of this acreage  does become oak-bay woodlands, as the land managers hope, there’s another problem: Sudden oak death, which is spreading through California and could provide dead trees as fuel.

ENVIRONMENTAL BLIGHT AND WASTED MONEY

The Plan will be a blight on the environment.

• The trees will no longer store carbon; instead, they will be releasing thousands of tons of it into the atmosphere.
• Thousands of gallons of toxic herbicides will be spread over the East Bay.
• Prescribed burns will further affect air quality, and could get away and cause wildfires and serious damage.
• Erosion and landslides could occur on steep slopes when the tree roots no longer stabilize the slopes.

The plan is to fund the first two projects, and about a third of the East Bay RPD project, from FEMA grants. This takes money that’s needed to respond to or avert actual serious disasters and uses it for a doomed Native Plant conversion project.

WHAT YOU CAN DO

• Sign a Petition. The Hills Conservation Network has a petition up; the button will take you to the petition.
• Contribute. Hills Conservation Network are also raising funds for potential legal action. If you would like to contribute, their website is HERE and includes a Paypal button.
• Speak at public meetings. FEMA will host three public meetings in Oakland, and  taking public comments. Two are on May 14, 2013 (at 2 p.m. and 6 p.m.) at the Richard C. Trudeau Center, 11500 Skyline Boulevard  Oakland, CA  94619.  One is on May 18, 2013 (at 10 a.m.) at Claremont Middle School, 5750 College Avenue  Oakland, CA  94618.
• Comment on the DEIR. FEMA has published the Draft Environmental Impact Report for these projects, and will accept comments until June 17th, 2013. That is available HERE;  it’s a long document. The Executive Summary is quite short – and telling. It’s here as a 16-page PDF: Executive+Summary-East Bay   You may submit written comments in several ways:

1. Via the project website: http://ebheis.cdmims.com
2. At the public meetings listed above
3. By email to EBH-EIS-FEMA-RIX@fema.dhs.gov
4. By mail: P.O. Box 72379, Oakland, CA 94612-8579
5. By fax: 510-627-7147

[Edited to Add: Further analysis showed the number of threatened trees to be "only" about half a million instead of the 900,000 reported earlier. This article has been updated where needed to show the revised calculations.]

San Francisco’s hidden urban treasure is at risk. The Sutro Forest is the single largest urban forest in San Francisco. Three-quarters (61 acres) of it is owned by UCSF, which officially calls it the Open Space Reserve. The contiguous 19-acre Interior Green Belt area to the east of it is city-owned.

Now, UCSF is planning to remove 90% of the trees and vegetation on 5 acres of forest – around 3,000 trees. Then its considering extending the same idea – removing 90% of trees and 90% of understory habitat, and potentially using large amounts of herbicides glyphosate (Aquamaster/ Roundup) and Garlon (triclopyr) to prevent it from coming back.

This video summarizes the risk to Mount Sutro Cloud Forest from UCSF’s “Management Plan” – in just 8 minutes. Please watch it, and if you like it, pass it on!

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

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

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

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

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

Which areas did they target?

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

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

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

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

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

A HIGHER RISK OF CANCER

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

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

Three of the Four on Mt Davidson

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

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

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

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

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

GLYPHOSATE (ROUNDUP, AQUAMASTER) AND HEALTH EFFECTS

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

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

GLYPHOSATE AND GUT PROBLEMS

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

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

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

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

NATURAL AREAS AND PESTICIDES

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

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

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

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

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