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.

Sincerely,

Eric Miller
President
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.