Recently, the Franciscan Manzanita has been declared an endangered species. Though readily available in plant nurseries, it does not exist in the wild. One specimen was found on Doyle Drive during the reconstruction work there, and has now been declared endangered. There are plans to designate certain areas as “critical habitat” for this plant, including Glen Canyon, Mount Davidson, Bayview Hill, and Bernal Heights. SFForest provided general information earlier when the proposed rule was first issued:  HERE

After additional review, we noted the Federal Registry says “We have not proposed to exclude any areas from critical habitat, but the Secretary is considering exercising his discretion to exclude areas within the Presidio and City or County Park Lands from final critical habitat designation.”  We need to tell the Federal government that city park land and forests are already scarce and are critical to the health and well-being of the second densest city in the country as well as the wildlife within the parks.

IS IT EVEN VIABLE IN THE WILD?

We have concerns about introducing the “2009 Doyle Drive” Franciscan Manzanita in the “wild” (actually, city parks):

• The Franciscan Manzanita is not propagating naturally from seed and even if it did it would likely hybridize with other non-Franciscan Manzanita, nullifying the hybrid off-springs as Franciscan Manzanita.  (Crazy and unnatural to only value species variations from 300 years ago.)
• A clone of the “Doyle Drive” Manzanita found in the “wild” (i.e., the Highway 101 shoulder) in 2009 is labeled as being a hybrid at Tilden Botanical Gardens.   This Manzanita is highly protected and controlled and this 2009 roadside plant discovery is what is in the process of being designated as an endangered species.
• Exact clones, not hybrids, of the Franciscan Manzanita relocated from Laurel Hill Cemetery in the 1930s are readily available for sale and are grown in home gardens.  Tilden has a nursery sale every Thursday. We were able to acquire a specimen for $6.
• The Franciscan Manzanita is only known to have ever existed at four locations: Laurel Hill Cemetery, Mount Davidson, Masonic Cemetery, and Doyle Drive.  According to Wikipedia, “there are 106 species of Manzanita, 95 of which are found in the Mediterranean climate and colder mountainous regions of California, ranging from ground-hugging coastal and mountain species to small trees up to 20 feet (6m) tall.”  The Manzanita adapts to unique locations and the San Francisco environment today is quite different than 300 years ago making it unlikely the species can actually survive in the “wild” of urban San Francisco.

If limited Fish and Wildlife Service funds and resources are shifted from other vulnerable and higher priority endangered species this will be detrimental to other species at risk.   The Franciscan Manzanita has probably always been a weak competitor and never a keystone species.  We wonder why it should be introduced to 318 acres where it is not known to ever have existed and where it is not known to have a significant ecosystem function?  The efforts to introduce the species could in fact be detrimental to the existing healthy ecosystems.

IMPACTS ON THE CITY PARKS

City parks are for the residents of the city, especially in San Francisco, which has the second densest population in the country. We don’t have enough open space for all the recreation needs of city residents as it is. We cannot afford to lose huge swaths of this precious resource to become a Manzanita garden.  Rec & Park in the process of decommissioning about 66% of the Twin Peaks hiking trails to protect the endangered Mission Blue Butterfly critical habitat even though there is no evidence that the trails are significantly harmful to the butterfly’s recovery.

Extreme activists could sue if the city does not completely close off the critical habitat to all park visitors to “protect” the Manzanita once they are planted there.  Activists are already suing the city over non-critical habitat for the California Red-Legged Frog and attempting to shutdown Sharp Park even though the frog population is healthy at Sharp Park.  History is a guide to future behavior.

This has been described as in essence a federal land grab of city parkland — the federal government demanding that SF take its parkland away from use by the people who live here (and in some cases, like Bernal Hill, heavy use by the people) and turn it over to a single purpose — a Manzanita garden. There is NO reason to plant endangered species in city parks.

WHAT YOU CAN DO

It’s important for people who care to write in to stop scarce city parks from becoming protected Manzanita gardens. Public Comments are being accepted until November 5, and we’ve drafted a general public comment to get you started.

Postmark or send electronically by November 5, 2012. 

It is best to submit your own personal public comment but if that is not possible then please submit our standard comment opposing designating city parks as “critical habitat” for the Franciscan Manzanita. (Below the map.) Please also consider encouraging others to sign and submit a comment.

Federal Register with Proposed Rule:  http://tinyurl.com/FWSFranciscanManzanita

To send electronically:

1. Go to the Federal eRulemaking Portal: http://www.regulations.gov.
2. In the Search box, enter Docket No. FWS-R8-ES-2012-0067, which is the docket number for this rulemaking.
3. Then, click on the Search button to locate this document.
4. You may submit a comment by clicking on “Comment Now!”

DRAFT COMMENT FOR CONSIDERATION

You can either attach a letter file with your comment or type a short comment (<=2000 characters).  Here is a short draft public comment that can be quickly posted in their “Type Comment” box:   Here is a draft public comment for consideration:

I am specifically requesting that popular recreation areas and forests be excluded from the critical habitat designation for the Franciscan Manzanita.   The proposed critical habitat identified at Bernal Hill, Glen Canyon Park (labeled Diamond Heights), Mount Davidson, Corona Heights, and Bayview Hill is not “unoccupied” as stated in the proposal. These sites have popular hiking trails that are important for the health and well-being of local residents that use these parks on a daily basis. These areas have also been identified by Rec & Park as important bird habitat and conversion to a Manzanita critical habitat could be detrimental to wildlife that depends on these areas. The designation may also lead to unnecessary conflict with the local communities that have used these popular nature areas for generations.