Natural Areas Plan: SFFA comments on the DEIR (Pt 5: Supporting the “Maintenance Alternative”)

In the Draft Environmental Impact Report (DEIR) on the Significant Natural Resource Areas Management Plan (SNRAMP), considered 4 alternatives to the SNRAMP:

(1) No Project – which would mean NAP would continue doing what they planned under an earlier plan, the 1995 plan;

(2) Maximum Restoration – which would mean converting the entire 1100 acres under the Natural Areas Program to scrub and grassland, and putting in access restrictions;

(3) Maximum Recreation – maximizing recreation except where it interferes with existing native plants and federally-protected species;

(4) Maintenance – Maintain the current distribution of native and non-native species in the Natural Areas; no habitat conversion.

The 4th alternative, The Maintenance Alternative,  is also the Environmentally Superior Alternative since it will have the least negative impact on the environment. This is the alternative that SFFA supports (though actually, closing down NAP would be even better).

In the body of the DEIR, it properly identifies the Maintenance alternative as environmentally superior.) However, the summary wrongly states that the Maximum Restoration alternative – which would be environmentally devastating – is the “environmentally superior alternative.”

Read on for the discussion of these issues.

The Draft Environmental Impact Report (DEIR) identifies the Maintenance Alternative as the Environmentally Superior Alternative.   This is consistent with CEQA law which requires that the alternative that will have the least negative impact on the environment be identified as the Environmentally Superior Alternative.

(This assumes that page 2 is corrected to be consistent with pages 525-526, as the Planning Department has said in writing that it will be corrected in the final EIR.)

Our support for the Maintenance Alternative is based on the fact that it is the least destructive of the alternatives presented by the DEIR:

  • The Maintenance Alternative will destroy the least number of trees and existing vegetation
  • The Maintenance Alternative will require the least amount of pesticide
  • The Maintenance Alternative will require the least restrictions on recreational access
  • In addition to being the Environmentally Superior Alternative, the Maintenance Alternative is also the only viable and sustainable alternative because:
  •   The Maintenance Alternative will not require that native plants which are no longer adapted to present conditions be planted where they will not grow
  • The Maintenance Alternative will not require that the City of San Francisco substantially increase the budget of the Natural Areas Program so that native plant gardens can be expanded


The Natural Areas Program (NAP) has destroyed hundreds of trees in the “natural areas” in the past 15 years.  The destruction of these trees has given NAP the opportunity to demonstrate that removing trees is beneficial to native plants.  In fact, there is little evidence that the destruction of trees has resulted in successful native plant gardens.

The Pine Lake “natural area” is an example of the destruction of trees which did not result in a successful native plant garden.  In 2004, about 25 trees were destroyed at the western end of Pine Lake.  This destruction is documented by the Hort Science report of December 2011 (“Stern Grove-Pine Lake Park, Parkside Square tree risk assessment”). This report was written as an update on Hort Science’s comprehensive assessment of all trees in Stern Grove-Pine Lake in 2003, in preparation for finally removing the hundreds of trees that had been evaluated as hazardous 8 years before.  Here is what Hort Science found at the “West end of the park, near Wawona and 33rd Ave:” “This area had a number of trees removed by the Natural Areas Program.

The area in which the trees were destroyed was then planted with native plants and surrounded by the limbs of the trees that were destroyed.  This is what that garden looked like in May 2008, four years later:

West end of Pine Lake, May 2008

And this is what that area looks like now:

West end of Pine Lake, July 2011

Little remains from that effort.   This is not an isolated example of the results of 15 years of attempting to restore native plants in places where they have not existed for over 100 years.  In addition to the 25 healthy trees that were destroyed at the western end of Pine Lake, 132 trees judged as hazardous were destroyed around the lake in 2006 (these tree removals are documented in SNRAMP). The southern and northern shores of Pine Lake have been planted repeatedly.  These areas are now dominated by foxtails and non-native nasturtiums which are thriving, despite being eradicated repeatedly.

Other parks have had similar experiences in their “natural areas.”  Sometimes toxic herbicides are used in the attempts to eradicate the non-native plants.  Here is a picture of a field of oxalis and mustard in Glen Canyon Park that has been sprayed with toxic Garlon numerous times.  There is no evidence that these non-native plants have been defeated by this chemical warfare.

Oxalis in Glen Canyon Park, February 2011

According to “UC [Davis] IPM Online” , Garlon only poisons the visible part of the plant; it doesn’t kill the root of the plant (in this case, the “bulbil”). So, the plant grows back the next year and is poisoned again.  Between March and October 2010, the Natural Areas Program and its contractors (Shelterbelt Builders) sprayed Glen Canyon with herbicides 10 times.  If this futile effort continues, it will be sprayed again every year, for as long as the public is willing to tolerate this poisoning of its public parks.  There is a creek at the bottom of this canyon that is probably being poisoned as well.  According to the federally mandated Material Safety Data Sheet for Garlon, it is “highly toxic” to aquatic life.  Alongside the creek is a day camp that is attended by children year around.   Do their parents realize that this toxic chemical is being sprayed repeatedly in proximity of their children?

More fortunate “natural areas” have essentially been abandoned by the Natural Areas Program.  Tank Hill has not been gardened by the NAP staff for several years.  It has been spared the spraying of herbicides.  However, it is visited by an unsupervised volunteer who hacks at the trees that remain.  In other words, so many acres of parkland have been designated as “natural areas” that the staff is unable to garden them and is unable to supervise the volunteers who are free to do whatever they want in them, including mutilate trees.


One of many questions that was asked during the public comment period for the Initial Study was:  is it still possible to sustain native plant gardens in San Francisco, given the radical changes in underlying conditions, e.g., higher levels of Carbon Dioxide, higher temperatures resulting from climate change and urban heat effect, changes in soil such as increased nitrogen levels and as a result of non-native vegetation, etc.?

This is one of many questions that were raised at the time of the Initial Study that are neither acknowledged nor answered by the DEIR.  We will therefore ask and answer this question because it is our last opportunity to do so.  The evidence that the ranges of native plants and animals have changed is overwhelming.  We should not be surprised that the Natural Areas Program has had little success in achieving their goals after 15 years of effort.  NAP and its supporters would like the public and the City’s policy makers to believe that its lack of success is because they are not adequately funded.

Even if the City had the resources to substantially increase the staff of the Natural Areas Program—and chose to use them for that purpose–we would not see a substantially different outcome from their efforts.  To demonstrate the futility of this effort, we turn to the living roof on the California Academy of Sciences.

When the California Academy of Sciences reopened in Golden Gate Park in August 2008, its “living roof” was considered its most unique feature.  Thirty species of native plants were candidates for planting on the roof.  They were planted in test plots with conditions similar to the planned roof and monitored closely.  Only nine species of native plants were selected for planting on the roof because they were the only plants that were capable of self-sowing from one season to the next, implying that they were “sustainable.”  A living demonstration of “sustainability” was said to be the purpose of the living roof.

So what have we learned from the living roof about the sustainability of native plants in San Francisco?  Two of three of the predominant species on the roof after 2-1/2 years were native.  The third—moss–is a “cosmopolitan” species that occurs everywhere.  It is not considered native or non-native.  It was not planted on the roof and therefore should be considered “invasive” in this context.  The Academy’s monitoring project has divided the roof into four quadrants.  By February 2011, non-natives outnumbered natives in two of the quadrants.  Although natives outnumbered non-natives in the other two quadrants which are actively gardened, non-natives were also growing in these quadrants.

The consultant hired by the Academy to plan the roof garden, Rana Nursery, advised the Academy to walk the streets of San Francisco and identify the plants growing from the cracks in the sidewalks.  These are the plants he advised the academy to plant because these are the plants that are adapted to current conditions in the city.  The academy rejected this advice because they were committed to planting exclusively natives on the roof.

The designer also advised the academy not to irrigate the roof, because the point of the roof is that it is a demonstration of sustainability.  Again, the academy refused because they knew that without irrigation most of the native plants would be brown during the dry season, roughly half the year.  (In fact, it is not clear that the plants would even survive without irrigation.)  They wanted the public to believe that the plants that are native to San Francisco are beautiful year around.
There is a lesson here for anyone who is willing to learn from it.  The living roof is not natural because it is irrigated and intensively gardened (e.g., weeded, fertilized, replanted, reseeded, etc. ), yet non-natives not only found their way there on their own, but were dominating it within only 2-1/2 years.  Native plants are not sustainable in San Francisco without intensive gardening effort.  The living roof on the Academy is a tiny fraction of the acres that have been designated as “natural areas.”  The Academy is one building in Golden Gate Park.  All of Golden Gate Park is about the same acreage as all of the 1,100 acres of “natural areas.”

Peter Del Tredici has been telling us this for several years.  He is a Senior Research Scientist at the Arnold Arboretum at Harvard University and a Lecturer in the Department of Landscape Architecture at the Harvard Graduate School of Design.

In a recent publication, he advises the managers of public lands in urban areas to abandon their fantasy that native plants are sustainable in urban settings:

The notion that self-sustaining, historically accurate plant associations can be restored to urban areas is an idea with little credibility in light of the facts that 1) the density of the human populations and the infrastructure necessary to support it have led to the removal of the original vegetation, 2) the abiotic growing conditions of urban areas are completely different from what they were originally; and 3) the large number of non-native species that have naturalized in cities provide intense competition for the native species that grew there prior to urbanization.”

(Ref: “Spontaneous Urban Vegetation:  Reflections of Change in a Globalized World,” Nature and Culture. Winter 2010, 209-315.)

Sure, he says, we can grow native plants, but they require at least the same amount of effort as growing any other plant and are therefore just another form of gardening:  “Certainly people can plant native species in the city, but few of them will thrive unless they are provided with the appropriate soil and are maintained to the same level as other intentionally cultivated plants.”

He concludes that native plant advocates are making a “cultural value judgment:”

“…people are looking at the plant through the subjective lens of a cultural value judgment which places a higher value on the nativity of a given plant than on its ecological function.  While this privileging of nativity may be appropriate and necessary for preserving large wilderness areas or rare native species it seems at odds with the realities of urban systems, where social and ecological functionality typically take priority over the restoration of historic ecosystems.”

So here is our conclusion:


Although the Maintenance Alternative is the least destructive of the alternatives considered by the DEIR, the closure of the Natural Areas Program would be less destructive than the Maintenance Alternative.

  • The Natural Areas Program has had 15 years to demonstrate that destroying trees and spraying our parks with herbicides will enable them to recreate sustainable native plant gardens.  They have failed.
  •   NAP has little to show for the destruction of hundreds of healthy trees, the use of gallons of toxic herbicides, and the investment of millions of dollars of taxpayers’ money.
  • At a time of extreme economic sacrifice, it is unseemly to suggest that further destruction of trees, poisons spread and money squandered would be worthwhile.
  •   Furthermore, greater sacrifice of money, trees, public safety, and recreational access will not result in sustainable native plant gardens.

The environmental impacts of the Proposed Project, No Project, and Maximum Restoration Alternatives are significant and the final EIR must judge them as such in these categories:  Aesthetics, Wind and Shadow, Recreation, Biological Resources, Hydrology and Water Quality, Hazards and Hazardous Materials, and Air Quality.

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5 Responses to Natural Areas Plan: SFFA comments on the DEIR (Pt 5: Supporting the “Maintenance Alternative”)

  1. Pingback: Natural Areas Plan: SFFA comments on the DEIR (Overview) « San Francisco Forest Alliance

  2. Tomasita Medál says:

    I support the “Maintenance Alternative” although I would prefer the elimination of the Natural Areas Program in our City parks wherever its implementation destroys existing eco-systems with the suggested alternative of a city-wide campaign encouraging a VOLUNTARY BACKYARDS NATURAL AREAS PROGRAM, wherein people citywide would be encouraged to water their backyards and nourish the native local flora that is already embedded in the soil.

  3. Tomasita Medál says:

    I entered the above comment at 4:36 p.m. June 11, 2012, not 11:36 p.m. as appears in blue.

    Webmaster: When this website was created it was set to an international time standard rather than to our local time. I agree that it’s confusing.

  4. Dolan Eargle says:

    Once again, I suggest that it is time to use legal action to remove the “Natural” Areas Program. If this exposé is sufficient, the Maintenance Alternative as presented appears a quite reasonable replacement.

  5. LJ Speakup says:

    Agree with legal action comment. Can you get on Michael krasneys morning program on KQED?

    Webmaster: Good suggestion. Why don’t you call Krasny’s Forum and ask?

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