Writing Cal Fish & Game about Glen Canyon’s Breeding Season

Two of the three Great Horned Owl triplets, taken on April 28, 2012

As readers may know, we have been concerned about the aggressive bush and tree work at Glen Canyon, during the spring breeding season for birds and animals.

(Relevant material: Glen Canyon Park – Chainsaws in the Nesting Season  also,  NAP Lops off Tree Limbs)

The Natural Areas Program is operating under a Streambed Alteration Permit from California Department of Fish & Game. The permit clearly states that work should be avoided during the breeding season.

When our verbal protests to the NAP and to SFRPD got no result, we wrote to Cal Fish & Game. Here is the letter (to which we have had no response thus far):

April 11, 2012

Sandy Brunson
California Department of Fish and Game, District 3
PO Box 47
Yountville, CA 94599

RE:    Violation of Streambed Alteration Permit
Islais Creek, San Francisco, California

Dear Ms. Brunson:

The San Francisco Forest Alliance (SFFA) is a coalition of San Franciscans dedicated to the preservation of the municipal parks of San Francisco for the benefit of people and wildlife.  Please visit our website for information about our mission.  (http://sfforest.net)

In keeping with our mission, we are writing to inform you of the violation of a Streambed Alteration Permit issued by California Department of Fish and Game (see attached application).  This application commits the Natural Areas Program of the San Francisco Recreation and Park Department to “perform the work between late summer and early fall (approximately July to November).”  The application makes the following commitment to avoid work during the breeding season:

“It is the policy of RPD’s Natural Areas Program that no new projects will begin during the breeding season (December to May).  Follow up work in previously cleared areas may be done during the breeding season, however, because areas will have been cleared previously. Wildlife will not likely be using these areas for breeding.  This protocol has been effective in reducing impacts to breeding wildlife.”

In fact, the Natural Areas Program began the destructive phase of this project in November and the work has continued as recently as April 2, 2012.  We have documented the progress of this destruction in the attached photos which are dated.   As you can see, chainsaws are being used to severely cut trees and destroy shrubs (many of which are native) and pesticides are being used to kill vegetation.  We have also enclosed photos of animals that were taken in Glen Canyon Park.

We have repeatedly protested the destruction of the vegetation used by the wildlife that lives in Glen Canyon Park since the project began.  We wrote to Lisa Wayne, the Natural Areas Program Manager, when the project began.  She refused to stop the project.  We also met twice with her immediate supervisor, Ana Alvarez, Superintendent of Parks and Open Spaces.  Our requests for subsequent meetings were denied.

We learned of the violation of the Streambed Alteration Permit on April 5, 2012, as a result of a public records request. On Friday, April 6, 2012, we brought that information to the attention of Phil Ginsberg, the General Manager of the Recreation and Park Department.  Lisa Wayne was present at that meeting.

Ms. Wayne’s explanation for conducting this work during breeding and nesting season was that the grant that is funding this project is about to expire.  The work is therefore being done, in violation of the Streambed Alteration Permit, in order to avoid the loss of expiring funds.  We do not find this an acceptable justification for conducting this destructive project during breeding season.

We respectfully request that the California Department of Fish and Game instruct the Natural Areas Program and the Recreation and Park Department to stop this project immediately.  We also request that the California Department of Fish and Game use whatever legal sanctions are at its disposal to take appropriate punitive action and to prevent such violations of legal commitments in the future.

Please inform me of the actions taken by California Department of Fish and Game in response to this violation of the Streambed Alteration Permit of the Natural Areas Program of the San Francisco Recreation and Parks Department.


Eric Miller
San Francisco Forest Alliance

Cc:    Mayor of San Francisco, Edwin Lee
California Assemblywoman Fiona Ma, District 12
San Francisco Supervisor Scott Wiener, District 8

Enclosures:    Streambed Alteration Permit Application
Photos of project
Photos of animals taken in Glen Canyon Park

And here are the attachments (Clicking on the pictures will give larger versions):

Glen Canyon “Restoration”

And here are a small selection of the numbers of species of wildlife that live and breed in Glen Canyon Park.

This entry was posted in "Natural" Areas Program, Ruins Habitat and tagged , , , , , . Bookmark the permalink.

2 Responses to Writing Cal Fish & Game about Glen Canyon’s Breeding Season

  1. HoursPerMile says:

    Thanks for lodging the complaint about conditions that we expect (and pay) Audubon and the Sierra Club to monitor. This case is not unique but it does demonstrate the extent to which these “nativist” organizations devalue the animal wildlife living in our parks.

    Although its should be clear by now that “nativists” value plants over the lives of intelligent animals it is important to document the destructive projects they undertake to reach their primary goal of destroying non-native life.

    On May 6th volunteers of LEJ (Literacy for Environmental Justice) frustrated by the ever returning grasses at Heron’s Head park, used a propane torch in an attempt eliminate them once and for all.

  2. Patricia Lovelock says:

    SF Rec&Park is starting Lafayette Park renovations now during nesting season. They have plans to remove 80 trees, some very large and most used by birds for nesting, protection and food. The project has erected a perimeter fence around most of the park. The project manager has stated that they have no work phase plans at this time and as of Wed. had yet to consult with any bird specialists. Do you have any ideas to help us protect these breeding birds? Lafayette Park has red-tailed hawks, owls, hummingbirds, etc.

    Webmaster: Thank you for your interest in the protection of nesting birds. You are quite correct that this is the middle of nesting season and tree work should be postponed until August.

    I suggest you contact the Golden Gate Audubon Society and ask if they will help you to convince the Recreation and Park Dept to postpone the removal of bird habitat, especially trees.

    You might also try contacting California Fish % Game. The federal Migratory Bird Treat prohibits the destruction of the nests of migrating birds. Fish & Game might be able to advise you about enforcement of that act.

    Good luck to you and the birds of Lafayette Park. Although Lafayette is not one of the properties of the so-called Natural Areas Program, we can be sure that the birds are inhabitating that park and they deserve our protection.

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