Toward the end of each year, SF Department of the Environment (SF Environment), which runs the Integrated Pest Management Program (IPM) holds an important public meeting. This year, it’s on December 20, 5-7 p.m. in Room 400 at San Francisco’s City Hall.
This meeting is to discuss three things, and take public comments and input: Changes to the approved list of pesticides for city use; the guidelines for pesticides use and public notification; and explaining the exemptions granted in 2017 to the rules.
THREE THINGS ON THE PESTICIDE MEETING AGENDA
1. Changes to the approved list of pesticides for use on city properties. SF Environment publishes a list of pesticides that are okay to use on city-owned properties (our parks, lands owned by the Public Utilities Commission, Crystal Springs, the airport, Sharp Park and a few others). It divides these permitted pesticides into three tiers: Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous). This meeting discusses pesticides added, removed, or having their Tier classification changed.
The DRAFT for 2018 is here: b_draft_2018_reduced_risk_pesticide_list
2. Guidelines for pesticide use and public notification. Over the last year, IPM has been trying to develop guidelines for when and where these pesticides are prohibited; and also for how the public can be informed when pesticides are used. Here’s the current DRAFT of the guidelines: c_summary_of_major_changes_to_2017_restrictions_of_most-hazardous_herbicides
3. They also explain the exceptions they’ve granted in the previous year, i.e. 2017. They approved 21 exemptions in 2017. The list of exemptions is here: a_summary_of_pesticide_exemptions_for_2017
The one that particularly concerns us is permission to use Garlon 4 Ultra (probably the most toxic herbicide still permitted on City properties) on oxalis within fifteen feet of designated trails at Twin Peaks, Mount Davidson, McLaren Park, Bayview Hill and Corona Heights.
They argue: These parks have a diversity of native plants growing adjacent to trails including but not limited to: Grindelia hirsutula (gumplant), coast rock cress (Arabis blepharophylla), Pacific reed grass (Calamagrostis nutkaensis), stonecrop (Sedum spathulifolium), meadow white (Cerastium arvense), silver bush lupine (Lupinus albifrons), Mission bells (Fritilaria affinis), footsteps of spring (Sanicula arctopides), California buckwheat (Erigonium latifolium), soap plant (Chlorogalum pomeridianum), dichondra (Dichondra donelliana), varied lupine (Lupinus variicolor), California buttercup (Ranunculus californicus), checkerbloom (Sidalcea malvaeflora), campion flower (Silene scouleri) and coast red onion (Allium dichlamydeum). Many of these plants are considered sensitive species and some of them support important local wildlife, such as the lupine species that are host plants for the endangered Mission blue butterfly (Icaricia icariodes missionensis). SFRPD is obligated to manage the land at Twin Peaks for the Mission blue butterfly as part of the Recovery Plan with the U. S. Fish and Wildlife Service, including the management of oxalis. In recent years, Garlon 4 Ultra is being used to protect these sensitive areas from this invasive weed. The Oxalis pes-caprae is a major threat to the existing biodiversity of wildlife within the native grasslands. If left untreated these areas will greatly interfere with the progress already made in controlling this particular weed.
What it boils down to is the poorly-supported theory that oxalis will take over the world if they let it, an argument Nativist doyen Jake Sigg recently made in his newsletter while defending pesticide use. “Our most serious destroyer of biological diversity is the yellow oxalis, Oxalis pes-caprae. Because it is prolific, aggressive, and effectively practices chemical warfare, it is pushing out native species—the wildflowers that so delight us and which are needed as the base of the food chain for other creatures. Because it can’t be destroyed unless the bulb is killed, herbicides are mandatory.”
By contrast, actual research indicates oxalis is a poor competitor, and even the
California Native Plant Society California Invasive Plant Council considers it only moderately invasive (mainly in sand dunes). [Edited to correct the organization reference.]
We understand that some opinions are influential even when opposing evidence surfaces, but in this case the tradeoff is the continued use of the most toxic herbicide that the city allows on its land. We’ve argued before that this tradeoff is not good for people, wildlife, or the environment. (See our presentation-format post: Garlon v. Oxalis in 10 Easy Slides ) We certainly do not wish it to be used near any trail where people go out with their kids and pets.
WE STAND FOR NO TOXIC PESTICIDES IN OUR PARKS
San Francisco Forest Alliance stands for an end to toxic pesticides in our parks. This can be done; the Marin Municipal Water District stopped using herbicides altogether some years ago. It means having a more practical approach to managing the landscape, and not declaring war on various species of plant.
However, we do have some concerns. Here are notes from Tom Borden, a public access advocate:
There is only one exemption from the posting requirements. It is for PUC right of ways. I understood pesticides were used at the GGP plant nursery without posting. Where is the exemption? I suspect herbicides are applied above the reservoir at 7th and Clarendon without posting. Where is the exemption for that?
Restrictions on Herbicides for City Properties
A2 Why are applications done by methods other than spray exempted from the requirement to use blue dye? If a stump has been daubed rather than sprayed, how will people know it’s not safe to sit on?
A2 Why say, “or in cases where posting is not otherwise required under the law”? Posting is always required by law, unless an exemption from posting is granted by IPM. Right now there is only one posting exemption on the IPM Exemptions log. If and when IPM issues another posting exemption, the land manager can also request an exemption from the blue marker dye requirement if there is a good reason to avoid the dye. Who does not want to use blue dye? Is it really expensive? Isn’t it beneficial to the people applying herbicides to be able to see what they already treated? Why shouldn’t people be able to see what was treated?
A7 Why can’t herbicides be used on green walls and green roofs? Whatever that logic is, why doesn’t it apply more broadly?
B9 Why don’t the protections for the public and employees extend to areas outside city limits? Do we only care about people in San Francisco?
B9 What is the relevance of public accessibility? The Chapter 3 of the San Francisco environment code protects City employees as well as the public. If “publicly inaccessible parcels” are to have lesser requirements for posting and demarcation, the law requires that the land manager apply for an exemption. As of today, there is only one posting exemption on file, for PUC rights of way. There should also be one for the GGP nursery. Other than that, we are not aware of any other “publicly inaccessible parcels” in the City. The general exception for “publicly inaccessible parcels” should be removed. It just introduces unnecessary ambiguity. If there is a genuinely publicly inaccessible parcel, and City employees can be protected, then IPM can issue an exception for that.
B9 Why are golf courses and areas managed for habitat conservation afforded less public protection? Don’t golfers, kids and hikers deserve protection too? Maybe the behavior of golfers is predictable, but people enjoying our wild parkland could be having a picnic, playing hide and seek, exploring, rolling down a hill, doing almost anything. There should be no exception to the demarcation requirements for “areas managed for habitat conservation”.
B12 If a trail exists, especially one not “actively maintained by City operations”, it is because people use it frequently. If the intent of these rules is to protect the public, all trails should be afforded the same protection. If the intent of these rules is to make life easy for land managers and punish people who use un-designated trails, you are on the right track.
B13 Please remove spray boom “definition” for broadcast spraying. The last part of the second sentence gets to the point, broadcast spraying means indiscriminately spraying all plants in an area, as opposed to targeting specific plants. In 2016 you saw video and photographic evidence that three men with backpack sprayers can perform broadcast spraying. Please use the definition for broadcast spraying that the rest of the world uses.
New thinking on Tier I
The new Restrictions do away with the idea that Tier I herbicides are only to be used when there is a critical need. Now Tier I can be used for anything except for prohibitions 10,11 & 12. The old restrictions limited where Tier I herbicides could be used based on a “need” that was balanced against the risks of use. Where has that gone? This seems like a real step backward.
Now land managers just need a reason that goes beyond cosmetics and they can apply Tier I herbicides anywhere as long as it is more than 15 feet from an area frequented by children and more than 15 feet from the land manager’s designated trails.
While we work toward the “No toxic pesticides in our parks” goal, we try to attend these meetings and believe that we have been able to work with SF Environment over the years to get some improvements.
- SFRPD improved the signage for pesticide use, and is now encoding the use of colored dye to show where actual spraying has taken place.
- More practical restrictions on pesticide use.
- We’re encouraged by SF RPD’s reducing herbicide use in the last three years – excluding the Natural Areas (now the Natural Resources Division) and Harding Golf course, which is managed under contract by the PGA Tour. (The graphs below show pesticide usage by SFRPD ex NAP and Harding, and NAP/ NRD’s pesticide use. Please note that all measurements are in fluid ounces of active ingredient, but the scale on the two graphs are different.)