Ten Reasons Why the Environmental Impact Report for Natural Areas is Flawed

After many years, millions of dollars, and a changing cast of consultants, the final Environmental Impact Report for the Natural Areas Management Plan has emerged. It’s deeply flawed.  (This is the Plan known as the Significant Natural Resource Areas Management Plan or SNRAMP or N-Ramp.)

Whenever there’s a major project, the California Environmental Quality Act (CEQA, pronounced seek-wa) requires the project’s sponsor to make an Environmental Impact Report (EIR). The San Francisco Recreation and Parks Department wants to implement a plan in the “Natural Areas” which will require cutting down thousands of trees, closing trails, and using toxic herbicides. However, we’ve written about the Plan (which in the EIR is called the Project) separately. The focus of this article is the flaws in the EIR.

(This article is a summary. Here’s a more detailed note by Tom Borden: arguments-against-certification-of-snramp-eir and his amendment: arguments-against-snramp-eir-correction )

The situation now is that the Planning Commission will be looking to certify the EIR. They have to evaluate only three things: Is it adequate? Is it accurate? Is it objective?

This EIR does not meet these criteria and should not be certified.


The EIR is inaccurate because the carbon sequestration numbers are wrong. They have been based on false assumptions, and the actual calculations are wrong. According to the correct calculations, there will be a net release of carbon of over 70,000 metric tons – and that’s a conservative figure.

The EIR’s authors purport to use the calculation methodology incorporated into CalEEMod. However, they actually don’t. Instead, the authors have made up their own method – one that fails to account for the carbon released from the trees destroyed!

View looking west; Miraloma Park

Mt Davidson – where is more carbon being stored?

The carbon sequestration calculations in the EIR reach the conclusion that grasses and shrubs will sequester more carbon than trees. This is obviously untrue. And there’s data. For example,  A research study in Australia concludes that forests store about 10 times more carbon than perennial grasslands.

It also does not account for the carbon released from disturbing the ground and from the actual machinery and vehicles used in this implementation.


Furthermore, even the industry standard is outdated. It assumes that trees stop sequestering additional carbon after 20 years. This is a false assumption. Research now shows that to the contrary, bigger trees sequester more additional carbon than young trees. Reference from Time Magazine Of January 2014:

“But according to a new study published in Nature, it turns out that the oldest trees are actually still growing rapidly, and storing increasing amounts of carbon as they age. An international research group led by Nate Stephenson of the U.S. Geological Survey Western Ecological Research Center reviewed records from forest studies on six continents, involving 673,046 individual trees and more than 400 species, going back as far as 80 years ago. For 97% of the species surveyed, the mass growth rate—literally, the amount of tree in the tree—kept increasing even as the individual tree got older and taller.”

Glen Canyon Doomed Trees 2

Hundred-year old trees continue to sequester more carbon than young ones – until you cut them down


The EIR is inadequate because it does not consider the effect of cutting down the so-called “saplings” – young trees that are less than 15 feet tall. According to the Plan, they can be cut down without any notice, at will. However, small trees account for some 15-30% of San Francisco’s trees. There are an estimated 11,000 such trees in “Natural Areas”, already established and growing. Left alone, these are the ones that will regenerate our forests and become the carbon-sinks of the next decades. Instead, the plan is to just cut them down without any notice or consideration, and instead plant at great expense other saplings which will require care for the first few years, have a fairly high mortality rate, and never grow as large as the removed saplings would have.

Picture 005 downed oak on Mt Davidson

Downed oak sapling


Based on the data for the first 10 months of 2016, The Natural Resources Department (NRD, formerly known as Natural Areas Program or NAP) used more herbicides than any comparable area of SF Recreation and Parks Department (SFRPD). Other SFRPD departments applied herbicides 19 times, while the NRD used them over 100 times! They use only Tier I and Tier II herbicides (most hazardous and more hazardous) including Roundup, which is a likely carcinogen. Since April 2016, SFRPD (without Harding Park) has all but eliminated its herbicide use – except for the “Natural” areas!  This does not include undocumented usage where the use of herbicides is not reported.


Herbicide application on eucalyptus stump – Mt Davidson

The EIR says there will be no increase in herbicide use. This is impossible, since the Plan calls for cutting down over 18,000 trees and treating the stumps with herbicides. The NRD has clearly shown a considerable willingness to use toxic herbicides, including for eucalyptus stump treatments. If the Project is implemented, thousands of trees are cut down, the stumps will all be treated with herbicide – probably several times. This includes the saplings, as in the picture above. A massive increase in herbicide use is inevitable.


The Plan call for closing 95% of the parks in Natural Areas to public access, by limiting people to using only the trails and also by closing many miles of trail. This makes most of the park “look don’t touch” areas.

mclaren park 2 sign 2015

You can’t go off the trail to explore, to play a game with your child or pet, to view a bird or pick a flower. These parks are not remote inaccessible areas – they are the place where we walk, where we take our families to be in nature, where we picnic or take our pets. They are our backyards and we are being shut out of them.


The “Response to Comments” section of the EIR, it states all removed trees will be replaced. EIR says roughly on a 1 to 1 basis and not necessarily at the same location or within the same Natural Area. The actual Project – the SNRAMP or NRAMP – does not talk about replacement other than by native plants or scrub. The actual language: “…the trees in the San Francisco Natural Areas would be replaced with either native trees or other native vegetation, such as native scrub or grassland species…”

In any case, when a tree is removed from a specific location, it impacts that area. In McLaren Park, the trees lie between the freeway and dense residential areas, and help improve air quality for the residents. If over 800 trees are removed and – for argument’s sake – replanted in Golden Gate Park, the impact would be significant.

Furthermore, a sapling does not have the same effect, whether aesthetically or in its ecological benefits, as a 100-year-old mature tree. Going by the experience of Glen Canyon, only a few large native trees would be planted in Natural Areas; it would mostly be shrubs or small trees, which do not have the same aesthetic and environmental benefits.


By inserting the word “native” into the definition of biodiversity – which actually does not exist in the reference on which it is based, the very definition of the term is changed. All trees and plants, whether native or non-native are part of our local biodiversity, just like people from everywhere are part of our city’s population diversity. Adding the word “native” to “biodiversity”, demonizes any non-native species. In fact, our urban forests are historically a part of the totality of variation in San Francisco and have been so for almost 150 years.

We traced the paper trail of the definition of biodiversity. It originates in a 1997 paper called The Sustainability Plan that references a definition from E.O. Wilson. Only, here’s that definition: “…the totality of all variation in life forms of Earth” –  Planet Earth, The Future (2006), p. 27

“Native” was inserted into the Sustainability Plan, into SNRAMP and into the EIR by local native plant advocates who have an agenda to push. This indicates lack of objectivity.


The EIR claims native plants with being more drought-tolerant, more adaptable to climate change and require less irrigation than other plants. No evidence is provided. These attributes can be found in both native and in non-native plants. The very fact that over three dozen species of non-native plants are so successful in our Natural Areas that the NRD has repeatedly been using Tier I and Tier II pesticides against them for years shows that native plants have no particular claim on sustainability. It’s just a gardening preference – and one that is the opposite of sustainable because it requires constant application of herbicides and manual labor to maintain them.


The EIR is inaccurate it its many references to eucalyptus being “invasive.” In fact, the California Native Plant Society classifies it as having only “Limited” invasiveness. Blue gum eucalyptus trees are not causing economic, environmental, or human health harm, which is the standard for invasiveness.

mt D comparison 1927 -2010

The eucalyptus didn’t invade east side


The Response to Comments indicates thinning will help encourage growth and the health of the forest. But thinning would not help because thinning is only beneficial when trees are young (in the pole stage) and vigorous enough to take advantage of the reduced competition. Otherwise, the benefits obtained from thinning mature trees will be negligible.

The possible damage likely to result from the thinning, including exposure to windthrow and damaging their intergrafted roots of surrounding eucalyptus, will very likely outweigh any benefits from reduced competition. (source: Florence, R.G. 2004, Ecology and silviculture of eucalypt forests and Silvicultural Guidelines published by State of NSW and Department of Environment, Climate Change and Water )


Though the EIR has not been certified, the SFRPD has already started implementing the project under the guise of trail restoration, park improvements, and other capital projects.


  • SFRPD had a trail slated for closure under the SNRAMP Project. But it’s already been closed. People protested that it had been done ahead of the EIR being certified and the Project being approved. In the Response to Comments, The EIR claimed SFRPD had closed the trail prior to the start of the EIR, in a sort of “it was grandfathered” argument. Except, it wasn’t true. The EIR started in 2005 – and the trail was still on SFRPD’s official project maps in 2006 and 2011. (And in fact the trail was used by an observer in 2013.)
  • In Glen Canyon, a project that purported to be only a Recreation Center renovation confined to  playing areas of the park actually impinged substantially into the Natural areas, and was “regularized” after the fact. A large number of trees were cut down and replaced with native shrubs.

In addition, the EIR is inadequate because it does not consider the impact of the actual extent of trail closures – now 53% of trails in “Natural Areas,” as opposed to the 22% closures described in the Project. This has a significant impact on recreation that the EIR ignores. Similarly, the EIR ignores fences and their effect on aesthetics. The Project says “fencing shall be considered as a last resort…” But that’s not what’s happening (already, despite the EIR not being certified). Fences have gone up in many Natural Areas, in some places giving it all the charm of a cattle chute.

grandview park fenced trail


The EIR should not be certified. It needs to be replaced with one that more accurately reflects what the Project actually intends, what is going on already (despite CEQA), and uses correct information.

If the Project proceeds, one important mitigation needs to be in place regarding trees. SFRPD must undertake to keep accurate records of all trees removed, and of all trees plants, including size, type, location and date of removal or planting. Planted trees should be inspected annually and failed trees replaced. Without this mitigation measure, there is no way of knowing whether there is sufficient replacement – or any replacement. It’s the least they can do.

The eucalyptus-tree nest hole of the red-shafted flicker - San Francisco. Janet Kessler

The eucalyptus-tree nest hole of the red-shafted flicker – San Francisco. Janet Kessler

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3 Responses to Ten Reasons Why the Environmental Impact Report for Natural Areas is Flawed

  1. Pingback: Ten Reasons to Oppose the Natural Areas “Project” | San Francisco Forest Alliance

  2. Pingback: Dec 15th: Joint Meeting of Planning Commission and Rec&Parks Commission | San Francisco Forest Alliance

  3. Pingback: Crucial Meeting for San Francisco Trees – Dec 15, 2016 – TOMORROW | Save Mount Sutro Forest

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