What’s Wrong with the Natural Resources Management Plan

This letter by Anastasia Glikshtern was published in the Westside Observer. It’s a response to an article by Glen Rogers that lauded the certification of the Environmental Impact Report on the Natural Resource Management Plan. Ms Glikshtern’s letter, which points out the damage the Plan will do as well as factual errors in the original article, is republished here with her permission.

Glen Rogers hails the certification of the biased, inadequate, and inaccurate Environmental Impact Report for Natural Resource Management Plan and adoption of that Plan as “a victory for conservation.” (Love ‘Em Or Hate ‘Em, Eucalyptus Trees Still Remain At Center Of Controversy, Westside Observer, February 2017)

In fact, the Plan is to cut down 18,500 trees (plus uncounted smaller ones) at the cost of $5.4 million a year for 20 years (SF Legislative Analyst, 2007), most of them on steep slopes, many in windy areas, some near freeways – to convert “forested areas to native scrub and grass habitat…”

The plan is to treat the stumps of killed trees with most toxic herbicides – so the herbicide use would drastically increase. Some people have the nerve to call this “conservation.”

Mr. Rogers states that in Sharp Park “the non-native grass of the golf course requires pesticides, herbicides and fertilizers which are affecting wildlife and tainting nearby water, causing genetic mutations….There have been numerous incidents of endangered wildlife being killed by mowing the lawn or gopher control.”

In fact, no pesticides or herbicides have been used in Sharp Park since August 2010. The five fertilizers used there are OMRI (Organic Materials Review Institute) Listed. In response to a Sunshine Records Request, I learned that there are “no records of deaths of red-legged frogs or garter snakes, or their juvenile equivalents, or their eggs or egg-masses, as a result of the operations and maintenance of Sharp Park” in last 10 years.

Mr. Rogers writes that alleopathy is “the agent that poisons the ground” and “inhibits other plants from growing under eucalyptus.”

In fact, alleopathy is a biological phenomenon by which an organism produces one or more biochemicals that influence the germination, growth, survival, and reproduction of other organisms. These biochemicals can have beneficial or detrimental effects on the target organisms. As an illustration of “native” vegetation under eucalyptus I’m attaching a photo of “native” toyon under “non-native” eucalyptus (Albany Hill).

There are five little oak trees (little, although they are already 10 years old)  growing next to the 36 bus stop at Myra Way / Dalewood Way intersection. Most likely they are doing so well in this area because of protection provided by big eucalyptus trees under which they grow.

Mr. Rogers blames (spectacular) lack of success in “the reintroduction of native plants” on eucalyptus trees. He ignores the Pacific reed grass – a species that the Natural Resources Program wants to protect – that is indeed growing under eucalyptus, and which is frequently associated with these trees because of the moisture they provide.

In fact, the same lack of success in reintroducing native plants can be observed on the grassy part of Mt. Davidson and in other “natural” areas. It is most likely due to the changes in the environment since the time (about 250 years ago) when the “desirable” (by Natural Resource Division) vegetation had allegedly grown here.

(I’m attaching a photo of French Broom on a trail in East Bay after 10 years of eradication effort.)

French Broom thriving along a trail - after 10 years of eradication efforts

French Broom along a trail – after 10 years of eradication efforts

Mr. Rogers cites a study stating that 85% of the 18,500 trees slated for elimination are in poor health – and therefore might burn down within the next 100 years.

In fact, that (questionable) study looked at a very small number of trees on the edges of Mt. Davidson. The sweeping conclusions are erroneous, and there are experts’ statements to the contrary. Moreover, the 2015 presentation by SFFD stressed that vegetation fires are 12-13 times more likely to occur in grass and brush (to which many of our forested areas are to be converted, according to the plan) than in forests, and the real fire danger in San Francisco is from structure fires because of closely placed wooden houses.

Mr. Rogers asks readers to remember eucalyptus trees that fueled the fire in Oakland.
The readers might also remember that the Oakland fire started in dry grass, that there were many reasons why it became so destructive, or that the wildfires in California are fueled by “native” trees.

While Mr. Rogers’ main concern on Mt. Davidson is the “prevalence of non-native species,” for many Mt. Davidson neighbors the main concerns in connection with pending implementation of the plan are very different:

  • The threat of the mudslides on newly deforested part of the mountain. (Mudslides have already been happening on the grassy part during the rainy seasons);
  • The threat of flooding;
  • Increased wind and noise;
  • Drastically increased use of the most toxic herbicides (particularly in view of the groundwater blending into our tap water;)
  • Destruction of wildlife habitat.

One-third of the currently forested area on Mt. Davidson is destined to be converted to grass and scrub.

Anastasia Glikshtern lives near Mt. Davidson


Mixed Results for Mission Blue Butterfly in San Francisco: Here’s Why

This article is reprinted with permission from SutroForest.com, a website that has been reporting on the Mission Blue project for some years.

Mission Blue Butterfly - Public Domain Image

Mission Blue Butterfly – Public Domain Image

It’s now Year 9 of the the Mission Blue butterfly project on Twin Peaks, San Francisco. In 2008, SF Recreation and Parks Department (SFRPD) started trying to reintroduce the Mission Blue Butterfly to Twin Peaks, by planting lupine and transferring in breeding butterflies from their largest existing population on San Bruno Mountain. The results so far have been mixed:

  • The lupine needs continual care;
  • The butterflies are breeding on Twin Peaks;
  • Most years, imports of Mission Blue butterflies from San Bruno continue to be needed to boost the population and its genetic diversity.

In 2017, SFRPD observers spotted 30 butterflies that were actually born on Twin Peaks. They didn’t import any butterflies from San Bruno. But the lupine, the nursery plant of the butterfly, was badly hit by funguses and hungry voles.


The Mission Blue butterfly (Aricia icarioides missionensis) is a rare subspecies of the much more widespread Boisduval’s Blue (Aricia icarioides).  The species is not endangered, but the subspecies is found only from San Bruno to Marin and is federally-listed as endangered. The largest population is on San Bruno Mountain.

Lupine is the nursery plant of the Mission Blue. It’s the only plant on which it’s known to lay its eggs and which the caterpillars eat. Mission blue eggs hatch into caterpillars which eat the lupine, shedding their skins as they grow. The larger caterpillars are tended by native ant species, who protect them from predators while benefiting from “honeydew” – sugary caterpillar pee.

Mission Blue larva tended by ant - NPS photograph

Mission Blue caterpillar tended by ant – NPS photograph

When they’ve grown to their full size, they form their pupae near the base of the plants, or even on the soil beneath, and remain there for months (in diapause). They hatch into butterflies in spring, sip nectar from a range of flowers (including the “invasive” non-native Italian thistle: Carduus pycnocephalus), mate, and lay eggs on lupines.

Aricia Icarioides Missionensis, Photo Copyright Joe O’Connor

These butterflies have only one generation a year and an 8-10 week flight season, becoming visible in April and May. The males live an average of 7 days, and females for 8 days. The males usually hatch before the females do, so they are ready to mate when the females appear.


Mission Blue butterflies used to inhabit Twin Peaks in San Francisco, but in 1998 a wet winter encouraged a fungal pathogen that destroyed most of the lupine plants – and the Mission Blue butterfly will not breed on anything else. The population, already small, fell until it was essentially gone. Eventually, SFRPD decided to attempt a reintroduction by planting lupine and then bringing butterflies from San Bruno Mountain.

The first batch, 22 females, was brought over in 2009. Optimistically, they hoped that this would be sufficient. But in 2010, only 17 butterflies were spotted, and imports resumed in 2011 – and in 2012, 2013, 2015, and 2016. In the graph below (covering the years 2009-2017) the dark bars show the “native-born” butterflies on Twin Peaks – i.e. ones that were spotted before transfers from San Bruno, or in years when there were no transfers. The light bars show the butterflies imported to Twin Peaks.  In 2017,  they’ve spotted 30 native-born butterflies.


[We’ve been reporting on this project for years; our most recent report is here: Mission Blue Butterfly 2016 Update: Imports from San Bruno Continue]

A report from SFRPD and its consultants on the year 2016 was issued in April 2017. It said they would not import any in 2017, but if the numbers fall in 2018, they’ll restart. The US Fish and Wildlife permit to transfer up to 20 male and 40 female butterflies each year is valid through 2020. They imported 44 butterflies from San Bruno in 2016: 15 males and 29 females.  You can read the report here: TwinPeaksProgressReportApr2017

According to that report, they were going to stop counting adult butterflies.  They planned instead to count the eggs, and calculate backward to figure how many females were implied by the number of eggs.  However, in 2017 they did in fact count butterflies, and found 15 males and 15 females in April and May.

This is the most of any year since 2009 – and definitely the most females. (However, there’s a bias because for each season we only use observations from before the transfers from San Bruno. But the transfers, too, must be made during the flight season. So in years with transfers, the local observation time is lessened and is biased to males, which emerge earlier than females.)  Despite the improvement, it suggests the population is still small enough that it cannot be considered stable or self-sustaining.

(The graph below is similar to the purple one above, but breaks out the observations – and imports – by the sex of the butterflies. The darker bars show imports, the lighter bars indicate butterflies that were born on Twin Peaks.)


It’s been a brutal year for lupine  in 2017 owing to the wet winter. There’s been a population explosion of voles, which have eaten some of the largest plants down to the ground. A fungus has killed many of the lupine plants. (Field notes describe it as anthracnose, but we’re not sure if a positive identification was made.)

In any case, this is never going to be a self-sustaining situation. They will need to keep gardening for lupine, because lupine is a plant of disturbed areas and Twin peaks isn’t disturbed.  As the report points out “unmanaged habitat degrades quickly.”

And while they can set up Mission Blue butterfly populations that are temporarily self-sustaining, in the long term they will still need to boost the population with imports.


We have a suggestion. Since lupine will have to be gardened anyway, why not grow it in containers? This should offer some protection from both voles and funguses, and provide the opportunity to optimize the soil conditions including drainage for the plant. SFRPD plants three species of lupine at Twin Peaks: Lupinus albifrons, lupinus varicolor, and lupinus formosus.

The favorite of the Mission Blue caterpillar is apparently Lupinus albifrons, or silver lupine; according to the April 2017 report, that was the only one the caterpillars were eating. And that one grows nicely in containers. The photograph below is from the website of specialist plant supplier Annie’s Annuals, specializing in rare and unusual annual & perennial plants, including cottage garden heirlooms & hard to find California native wildflowers.”

As a bonus, since container-grown plants won’t face competition from other wild plants, SFRPD can stop using toxic herbicides on Twin peaks. In 2016, they used toxic herbicides 25 times on Twin Peaks – behind only the much-larger McLaren Park (27 times) and Bayview Hill (34 times).  This included 7 applications of Garlon, possibly the most toxic herbicide the city permits.

It’s unknown whether these herbicides impact the reproductive success of the butterflies, either directly or via their ant tenders. In any case, organic lupines might be a healthier option.


These are the main issues with Garlon, in brief:

  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  •   Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  •   About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs  may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans.  Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  •  It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  •  It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  •  Garlon can persist in dead vegetation for up to two years.

If SFRPD grew the lupine in containers, it wouldn’t need to worry about the oxalis or use Garlon. At least on Twin Peaks.


We are often asked how much the Mission Blue project is costing the tax payer, so we tried to find out. This project is funded by the city, and with a three-year grant from US Fish and Wildlife Services for “habitat management” that just ended.  Data for 2008-2017 indicate the SF Rec and Parks Commission spent around $82,000. We looked at Professional Services payments to Coast Ridge Ecology, to Creekside Center for Earth Sciences, and to Liam O’Brien. There’s another consultant involved, Golden Hour Restoration Institute, but we think they were paid directly from the US FWS grant.

This of course excludes the salaries/ time of the SFRPD staff. Natural Resource Department staff are involved at every stage, from lupine planting to butterfly counting. It also excludes the cost of laying down pesticides on Twin Peaks 25 times annually.

[Note: We also attempted to search for the USFWS grant information, but so far have no numbers.]

Where Did The “Natural Areas Program” Come From?

The Natural Areas Program – now renamed the Natural Resources Areas Program – has been controversial almost from its initial stages. It’s been opposed on scientific and community grounds since then. But critics have generally been ignored.

Many of our supporters have only recently joined the fight to save our parks from the tree-felling, toxic herbicides, and access restrictions that the Natural Resources Division brings. For them – as well as those who would like to know more about this program – we republish (with permission and a few edits and updates) a detailed article from the sfdog website, first published in 2011.



The Natural Areas Program (NAP) of the San Francisco Recreation and Park Department (RPD) was originally intended to preserve the few remnants of San Francisco’s natural heritage that still existed in city parks. The plan has morphed, however, into an empire that controls one-quarter of all the parkland in San Francisco (one-third of all parkland managed by RPD if you include Sharp Park in Pacifica). Its management plans have become quite controversial, with proposals to cut down healthy trees, drench hillsides in herbicides, close trails and off-leash areas, relocate or kill feral cats, and restrict access for all people to large sections of our parks.

For nearly two decades, NAP has operated with no real oversight and little input from the public about its plans. Its modus operandi is akin to “I know better than you, so go away.” Despite years of attempts to get even small amounts of accountability from NAP, the program continues to do pretty much whatever it wants in our city parks. Because, in many cases, NAP claims control of entire neighborhood parks, San Franciscans are losing access to their common “backyards”, and most have no idea it’s happening until it’s done.


In 1991, Policy 13 was added to the Recreation and Open Space Element (ROSE), a document that gives general policy directions for open space in San Francisco. Policy 13 (actually Policy 2.13) sets forth a general policy goal to “preserve and protect significant natural resource areas.” Policy 13 sets the following criteria to determine what is a natural area:

1) The site is undeveloped and relatively undisturbed, and is a remnant of the original natural landscape and either supports a significant and diverse or unusual indigenous plant or wildlife habitat or contains rare geological formations or riparian zones.

2) The site contains rare, threatened, or endangered species, as identified by the U.S. Fish and Wildlife Service or California Department of Fish and Game, or contains habitat that has recently supported and is likely again to support rare, threatened, or endangered species.

3) The site is adjacent to another protected natural resource area and, if protected from development, the two areas together would support a larger or more diverse natural habitat.

The policy also says: “Native plant habitats should be preserved and efforts undertaken to remove exotic plant species from these areas.”

Policy 13 has been used by NAP advocates to imply a city mandate to preserve natural areas, a mandate that justifies all the restrictions, herbicides, closures, etc. However, the ROSE is actually an advisory document that sets out guidelines, not mandates. It does not have the force of law.

On January 19, 1995, the SF Recreation and Park Commission approved the first management plan for natural areas. This plan identified “candidate” natural areas, and established guidelines for management programs in the areas. The plan called for a consultant to develop the specifics of the implementation of the plan. It also made a commitment to include the public and community organizations in discussions as the plan evolved. The Natural Areas Program, however, did not honor this commitment.

In 1997, the Recreation and Park Department (RPD) signed a contract with EIP Associates as the consultant to develop the ways to implement the plan. According to the contract, EIP was to form a Scientific Advisory Board (SAB) that would meet two to three times per year for a period of three years. SAB members would be paid an honorarium for each meeting; the cost of the honorariums was included in the RPD budget. A 2001 draft of the consultant’s report stated: “A scientific advisory board, made up of experts in related fields, provided direction and advice during the project’s planning and preparation.”


In fact, Dr. Ed Connor, a member of the SAB, told the SF Board of Supervisors in August 2002, “… the members of the SAB had never seen or been asked to comment on a draft of such a plan in any state of its preparation.” They were not paid any honoraria. Drafts of the management plan developed by EIP Associates were supposed to be circulated to a citizen’s task force and local community groups. Instead, the first draft was seen only by NAP staff, who then returned it to EIP for revision without seeking any public input on it. NAP was steaming full speed ahead without any real community oversight or input.

In the parks, NAP and its supporters cut down and girdled hundreds of trees (in which the bark is cut completely around the tree, interrupting the flow of sap and nutrients and eventually killing the tree). Fences were erected, blocking access to large sections of parks. NAP staff did not bother to consult with (or even tell) park neighbors and users what they were doing in the natural areas. NAP operated in a secret and arrogant manner.

At the same time, the consultant’s draft management plan was finally made available to the public at only one location (the main library). For the first time, people saw the extent of NAP’s plans – removing and killing non-native animals, including feral cats; closing trails; putting up fences; and prohibiting fishing and boating where it had traditionally been allowed. The draft management plan made clear that NAP staff and advocates had intentionally planted species of endangered and threatened plants and animals in natural areas. Because of the special status of these species, federal law requires severe restrictions on access wherever they occur. NAP essentially presented the public with a fait accompliof access restrictions before people knew what was happening.

By 2002, people had noticed major changes in some natural areas that they did not like, and they began complaining. In response, RPD formed a Green Ribbon Panel to advise RPD and EIP about the NAP management plans under development. Critics were not happy with the composition of the Green Ribbon Panel, which they viewed as composed primarily of native plant advocates. The Park and Recreation Open Space Committee’s (PROSAC) representative to the Green Ribbon Panel, Dr. Joan Roughgarden, confirmed the Panel’s bias. In a report to PROSAC, Dr. Roughgarden wrote, “The Green Ribbon Panel was selected on the basis of political advocacy, not on technical credentials, so that discussion of the technical merits of the plan is immediately interpreted in an advocacy framework.” Roughgarden continued,

“The management plan advances a highly interventionist view of resource management that is not viable ecologically, economically, or culturally.”

In response, PROSAC passed a resolution calling for a scientific review of the management plan. The Recreation and Park Commission did not respond to the request.


NAP critics complained to the SF Board of Supervisors that the way the management plan was being implemented had not been properly vetted, and that NAP was not considering the public’s input, as promised by the Recreation and Park Commission in 1995. The Board held three hearings on NAP, beginning in July 2002, and, in response, on September 24, 2002, the Board created a Citizen’s Advisory Committee for the Natural Areas Program (NAPCAC). The Board of Supervisors gave NAPCAC a year to develop a management plan for natural areas and provide a summary report of its findings. NAPCAC would meet under Sunshine Ordinance rules, so the public would be able to see exactly what it was doing. The Board’s resolution disbanded the Green Ribbon Panel and replaced it with NAPCAC. The resolution allowed NAP staff to continue to maintain natural areas as long as their actions did not include: “the removal of healthy trees that pose no safety hazards; trail closures, or restrictions on access and recreation; trapping and removal of wild or feral animals currently inhabiting parks and lakes; and expansion of activities into areas that no longer support predominantly native flora and fauna.”

NAPCAC had 12 members, four who were knowledgeable in issues related to natural areas (e.g., restoration, ecology, environmental advocacy), four who were interested in access to and use of parks and open space (e.g., recreational users, neighborhood activists, youth and tree advocates), two at-large members recommended by the Board of Supervisors, and two at-large members recommended by RPD. The Board of Supervisors approved the twelve appointments to NAPCAC on December 18, 2002.

The Board’s resolution creating NAPCAC directed RPD to assist NAPCAC, including giving notice of meetings, providing meeting space and publishing minutes. However, RPD repeatedly denied NAPCAC members’ requests for meeting space. Finally, NAPCAC members took it upon themselves to find meeting space. NAPCAC met for the first time on February 13, 2003 in the Mission Police Station Community Room. Later meetings were held in a classroom at City College.

At its first meeting, NAPCAC vote unanimously to ask RPD for staff support to provide minutes and to copy and distribute materials to the Committee and member of the public. RPD declined to provide staff to take minutes, but offered to copy materials as long as they were submitted two weeks in advance. Since NAPCAC met every two weeks, this “offer” was largely meaningless.

NAPCAC members complained to the Board of Supervisors about the lack of RPD support. At a City Services Committee hearing on May 15, 2003, speakers showed pictures of fences in three different natural areas that had been built since the Board’s NAPCAC resolution had been passed, in direct violation of the resolution’s ban on controversial management actions while NAPCAC was meeting. At the hearing, RPD General Manager Elizabeth Goldstein claimed a verbal agreement with Supervisor Matt Gonzalez that RPD would not be required to provide any support to NAPCAC. After the hearing, an aide to Supervisor Gonzalez told the Chair of NAPCAC that the Supervisor had made no such agreement.

NAPCAC continued to meet. A member of the NAP staff attended every meeting, and their message to NAPCAC, given at the end of every meeting (during general public comment) was fairly consistent – you’re wasting your time and we will ignore you and your findings. For example, on May 8, 2003, Lisa Wayne, the head of NAP, told the Committee, “The Committee has misinformation and misperceptions. The Committee is spinning its wheels, creating controversy where there isn’t any. There is fear being perpetuated in this room. I’m the person that knows these parks better than anyone else in the City.” NAP supporters in the audience at meetings verbally attacked NAPCAC members, and disrupted the meetings by talking loudly among themselves during panel discussions.

NAPCAC met for nine months. At these meetings, NAPCAC members who were critics of NAP actively engaged in negotiations, introducing repeated iterations of plans that tried to address concerns raised by NAP advocates. NAP advocates did not introduce their own plan until the next to the last meeting, instead choosing to react to plans introduced by the “other” side and insisting on compromise from them. For example, NAP advocates insisted that NAPCAC accept all 31 of the natural areas that NAP had claimed for itself, even though many had no native plants in them and had been designated as natural areas without any public input.


Because of the repeated compromises by their side, NAPCAC’s final report was barely acceptable to those members who had opposed the way NAP was being administered. Yet they voted to accept the final report because it created a process of scientific and community oversight of the NAP. Unable to convince a majority of NAPCAC members to acquiesce to further demands, NAP advocates on the Committee refused to support the final report that contained the compromises that they had insisted upon. The NAPCAC final report was passed by a vote of 7-5 on November 14, 2003, meeting the one-year deadline imposed by the Board of Supervisors in the resolution that created NAPCAC.

The NAPCAC Final Report, co-authored by two ecology/conservation biologists on the Committee, Drs. Joan Roughgarden and Ed Connor, set up a Natural Areas Program Review Committee (NAPRC) that would review and consult with NAP about its plans to manage natural areas. NAPRC would be composed of 12 members, including four scientists with research credentials in relevant fields (ecology, botany, zoology, conservation, etc.), four representatives of citywide advocacy groups, and four representatives of local neighborhood and park advocacy groups. Committee meetings would be conducted under all Sunshine Ordinance requirements, to ensure no backroom deals were made.

[Click here to read the NAPCAC Final Report: NAPCAC – final document]

The Final Report called on NAP to develop a system-wide “portfolio” plan that would (section 5.1): “provide an overview of the entire system of Natural Areas, showing how each site contributes to the overall goal of the program. This portfolio plan should outline the overall Natural Areas Program conservation and educational goals, specify the priorities for implementation of conservation plans for individual parks, and outline how the acquisition of additional properties will enhance the ability of the NAP to meet its conservation and educational goals.” The Final Report recognized that every city park has different issues and doesn’t try to enforce a citywide, one-size-fits-all solution to those problems. The Final Report went on to say (section 5.3): “Detailed plans for the conservation measures to be implemented at each site and how public input will be integrated into each site plan will be developed simultaneously and in parallel by the two subcommittees of NAPRC…”

According to the Final Report, the NAPRC would have two subcommittees, a Scientific Subcommittee and a Community Relations Subcommittee, with six members each. The Scientific Subcommittee would review the management plan at each natural areas site to determine (section7.1):

1. Is it scientifically plausible that the proposed management activities will achieve the proposed outcome?
2. Are the proposed monitoring plans adequate to identify any unforeseen consequences that may arise during the implementation of the plan?
3. Have the secondary consequences of management activities been identified?
4. Is the proposed evaluation plan adequate to determine the success of the plan?
5. Are the educational materials scientifically accurate?

The Scientific Subcommittee would provide the scientific oversight of the management plans that the original consultant and later the Green Ribbon Panel were supposed to do but did not.

The Community Relations Subcommittee would review community outreach plans by the NAP to determine (section 9.1):

1. Does the local community favor the proposed management practices for the sites in their district?
2. Has a good faith effort been made to solicit and incorporate public comments on individual site plans?
3. Has the local community been adequately informed of both the potential benefits and secondary consequences of the proposed plan?
4. Have other relevant city Commissions (e.g., Animal Control and Welfare, Urban Forestry Council, etc.) been informed and consulted about any management practices proposed for the Natural Areas?
5. Does the community have any changes they wish to make to the proposed plan?

The Community Relations Subcommittee would ensure that adequate community workshops and meetings were held by NAP, and that professionally designed surveys were conducted to measure public support among park neighbors and users for NAP’s plans at each site.

The NAPCAC Final Report expressed strong support for the NAP, and encouraged increased funding and staff for it, especially to handle the added responsibilities of the NAPRC. With the release of its Final Report, NAPCAC was disbanded.


On January 7, 2004, the Board of Supervisor’s City Services Committee heard testimony on the NAPCAC final report. NAP staff and NAP supporters attacked the NAPCAC final report, producing a “minority report” that called for citywide mediation – not any oversight committee – to resolve NAP conflicts. This minority report was written over a month after NAPCAC had been disbanded, and is entirely different from the final plan NAP advocates had presented at the next-to-last NAPCAC meeting. Unlike the NAPCAC Final Report, neither any of the majority members of NAPCAC nor members of the public had an opportunity to comment on the Minority Report before it was introduced to the City Services Committee. Despite this lack of transparency, NAP advocates demanded that it be given equal weight to the Final Report.

NAP critics were concerned. Mediation can work, especially when dealing with a single issue. But NAP issues are many and varied, and affect a multitude of park users and neighbors. In addition, mediation typically takes place in secret, allowing NAP to continue to operate without public oversight. In practice, the people invited to mediation (especially a citywide mediation) represent advocacy groups, not average citizens, further diluting the ability of park users and neighbors to influence what happens in their neighborhood parks.

Ultimately, the City Services Committee took no action on the NAPCAC Final Report. As a result, NAP was allowed to continue on its merry way with little oversight or input from the public.

Later in 2004, an informal working group, with both NAP advocates and NAP critics was established to discuss changes in the way NAP managed the lands under its control. RPD staffer Dan McKenna mediated the negotiations. The idea of three different management zones, from MA-1 for the most sensitive parts of a natural area to MA-3 for the least sensitive, came out of these informal negotiations. The group met for about six months. The informal working group thought they had reached an agreement on what the NAP Management Plan would look like.

But when the NAP Draft Management Plan was released in June 2005, NAP critics who had taken part in the informal working group felt that promises made had been reneged upon, and they fought against its adoption.


In July 2006, the Recreation and Park Commission considered whether to approve the Draft NAP Management Plan or not. The hearing was attended by hundreds of people. So many people wanted to speak that, even though people were given just one minute to speak, the Commission ran out of time. The item was continued to the August 2006 Commission meeting. At both meetings, people expressed concerns about cutting down healthy trees, killing feral cats, closures of trails and off-leash areas, overuse of herbicides, and general concerns about the loss of access for people to large parts of their parks, the same concerns expressed from the beginning of the program.

The Commission unanimously approved the NAP Draft Management Plan, after adding two minor changes to the plan: 1) the least sensitive MA-3 parts of natural areas would be managed by the RPD Urban Forestry staff, and both native and non-native trees could be planted in MA-3 areas; 2) feral cat “relocation” (a nice euphemism for “killing”) would happen only after the Recreation and Park Commission determined that other means of population reduction had failed to adequately reduce the number of feral cats in a natural area. These two changes were the only changes made to the Draft Management Plan by the Commission in response to the torrent of criticism the NAP plan had received.

The Commission then ordered an Environmental Impact Review of the NAP Management Plan that it had approved. The Initial Study for the NAP EIR was published in April 2009. The comments submitted are included as Appendix A of the Draft Environmental Impact Review (EIR) for the NAP Management Plan that was released in August 2011.

Interestingly, many of the concerns about the NAP Management Plan raised in the Initial Study are still problems with the Draft EIR. Those who prepared the Draft EIR do not appear to incorporated very many of the criticisms. Indeed, they don’t seem to have listened to the critics at all.

[Update: The Draft EIR with very few changes was approved in March 2017 by the Board of Supervisors.]

This lack of concern for what people think by NAP has been a problem since its inception. NAP seems to only listen to its most zealous supporters, and ignores the rest of us.

Problems with Invasion Biology

This article was first published in Death of a Million Trees, which opposes unnecessary tree destruction in the San Francisco Bay Area. It’s republished here with permission.

Mark Davis, Macalester College

Mark Davis is Professor of Biology at Macalester College in St. Paul, Minnesota.  He is one of the first academic ecologists to publicly express skepticism of invasion biology.  His book, Invasion Biology, was published by Oxford University Press in 2009.  It was the first critique of invasion biology written by an academic scientist. Professor Davis cites the many empirical studies that find little evidence supportive of the hypotheses of invasion biology. 

In 2011, Nature magazine published an essay written by Professor Davis and 18 coauthors entitled, “Don’t Judge Species on their Origins.”  This essay suggested that conservationists evaluate species based on their ecological impact, rather than whether or not they are natives.  The essay initiated an intense debate in the academic community of ecologists that continues today. 

Professor Davis spoke at the Beyond Pesticides conference in Minneapolis at the end of April 2017. (Video available HERE) He described invasion biology as an irrational ideology that is based on nostalgia for the past and a belief that wildlands are being damaged by “alien invaders.”  In fact, the perceived damage is largely in the eye of the beholder, depending largely on one’s membership in a group benefiting from the nativism paradigm, such as chemical manufacturers, conservation organizations, government agencies, and employees.  Some academic careers are also at stake.  Futile attempts to re-create historical landscapes always have the potential to make things worse.  In many instances, it is more sensible to change one’s attitude about the changing landscape than trying to change nature.

Mark Davis speaking at Beyond Pesticides conference, April 2017

We invited Professor Davis to write a guest post for publication on Million Trees.  We asked him to express his opinion on these questions: 

  • Has the status of invasion biology changed much since Nature published your essay 2011?
  • Has increased knowledge of climate change had an impact on the status of invasion biology in academia?
  • What do you think is the future of invasion biology both as an academic discipline and as public policy?

Professor Davis’s guest post addresses these questions.  We are grateful to Professor Davis for his many contributions to our understanding of the fallacies of invasion biology and for his thoughtful guest post.

Million Trees

Competition to define nature

In the past few years, a new perspective has been taking hold in the field of ecology.  Referred to as ‘ecological novelty’ it emphasizes that many factors are producing ecologically novel environments.  Climate change (which includes changes in temperatures and patterns of precipitation), increased atmospheric carbon dioxide, which affects photosynthetic rates, increased atmospheric deposition of nitrogen (the whole earth is being fertilized due to the increased nitrogen we are pouring into the atmosphere), and the introduction of new species are all rapidly changing our environments.

A strength of the term ecological novelty is that unlike the invasion vocabulary it is simply descriptive.  It simply states that ecosystems are changing and are different than they were in the past, even the recent past.  It says nothing about whether this change is good or bad.  In this paradigm, species can be referred to as novel species, new arrivals, or long-term residents.

The less biased ecological novelty paradigm differs dramatically from the more ideological nativism paradigm.  It differs in the language it uses and it differs in the implied direction that land management should proceed.  More generally, it forsakes the normative atmosphere that permeates restoration ecology, conservation biology, and invasion biology, all of which have been substantially guided by the nativism paradigm.

The Sutro Forest in San Francisco is a good example of a novel ecosystem. It is a thriving mix of native and non-native species. Much of it will be destroyed by the irrational belief that native species are superior to non-native species.  Million Trees

Currently, invasion biologists are trying to discredit ecological novelty as a valid or valuable perspective.  This is hardly surprising since the ecological perspective would displace the nativism paradigm, and many stakeholders have much to lose if the nativism paradigm were abandoned, e.g. chemical companies, restoration and management companies, local, state, and national agencies, to name just a few.  Not surprisingly, articles trying to shore up invasion ecology and to keep it relevant have been common in recent years.

While the public may not be aware of it, there exists a heated competition to define natureWhich side wins will significantly determine how nature is managed.  Given that the redistribution of species is only going to increase in upcoming decades, it is hard to imagine that people will still be so preoccupied with origins by the middle of the century.  Like the notion of wilderness, the nativism paradigm is more of a twentieth century concept, while the construct of ecological novelty is more fitting for the twenty first century.

Undoubtedly, nativist groups will still exist and will still be preoccupied with trying to restore their vision of the past.  But, due to the number of species being moved to new regions, much more attention likely will be given to the function of species than their origins, if only for pragmatic reasons.  For people coming of age now, cosmopolitanization is the new normal, both with respect to people and other species.  We will still carry our predispositions to divide the world into us and them, but it should be clear to most that the nativism perspective will be obsolete and that beyond the creation of museums, restoring the past will not be possible, whether a city or a forest.

Currently Earth is the only planet we know of where life exists.  In this context, the desire and practice of declaring some species as aliens, exotics, or invaders seems sadly provincial and even unseemly.  Roman playwrite Publius Terentius Afer (aka Terence) wrote in his play Heauton Timorumenos, “Homo sum, humani nihil a me alienum puto”, or “I am human, and nothing of that which is human is alien to me.” To those who still see such value in distinguishing native from alien species, I say, “I am of the planet Earth and nothing of that which is earthly is alien to me.”

Mark Davis

Killing Our Street Trees in San Francisco

The tree which moves some to tears of joy is in the eyes of others only a green thing that stands in the way.”
William Blake, The Letters, 1799

Most of these Jefferson Street trees were saved due to neighbors’ efforts! Fisherman’s Wharf, San Francisco

San Francisco has a lot of projects going on. SFMTA seems to be flush with wealth, and is “improving” a lot of roads. Developers are planning fancy new buildings.

Unfortunately, every project seems to start with destroying trees – and neighbors never know about it until it’s a done deal and the trees have 30-days-to-death notices on them. Then they object… but the odds are against them. Though they sometimes succeed in saving the trees, more often it’s too late.  Meanwhile, the City seems to be entirely accepting of tree destruction for any and all reasons.

San Francisco has a tree canopy of only 13.7%, the lowest of any major city, and nearly half the appropriate canopy cover of 25%.

(From SF Data: In preparation for the San Francisco Urban Forest Plan (2013), the Planning Department performed an Urban Tree Canopy (UTC) Analysis using aerial imagery and additional data sets to determine a canopy estimate for the City & County of San Francisco. This analysis estimated San Francisco’s tree canopy at 13.7%)

Graph showing urban tree canopy cover in major US cities

San Francisco Has the Least Canopy Cover of any Major US City

This is an embarrassment for a “green” city, quite aside from the ecological, environmental and health reasons for saving our trees. Unfortunately, between Nativists, developers, and project managers, there seems to be a wave of tree cutting hitting San Francisco. We’re not augmenting our canopy, we’re shrinking it.


  1. Trees fight pollution, especially particulate pollution that is dangerous to human lungs.
  2. Trees improve air quality
  3. Trees are good for physical and psychological health; to get the same benefit as living on a tree-lined street, you would have to be ten years younger.
  4. Trees provide habitat for wildlife, especially birds and butterflies.
  5. Trees help regulate water by absorbing it into their roots and gradually releasing it through their leaves.
  6. Trees reduce crime and improve business.

For a detailed list of benefits, read Twenty Reasons Why Urban Trees are Important to Us All


Two years ago, neighbors fought to save this lovely grove of trees at Geary and Masonic. They were cut down because of plans that merely considered them as “green things that are in the way” and were not designed to preserve them.

These trees are now gone. Here’s what that grove looks like now:


This charming line of street trees, fighting pollution and climate change, and breathing out oxygen in downtown San Francisco, is also gone. In its place there will be a tower block with a footprint out to the sidewalk.

Where once there were trees.


Plum trees the neighbors loved were removed at Fort Mason, leaving the neighbors in shock.

Fort Mason Flowering Plum Trees - Before

Fort Mason Flowering Plum Trees – Before

Shocked neighbor views the missing trees


The tree destruction continues, but in some cases at least it may be possible for neighbors to prevail.

The Rincon Point Neighbors are fighting to save ten trees at Howard and Steuart streets. The hearing is May 31 at 5 pm in room 416, City Hall.  Comments should be submitted on the Thursday prior to the Hearing, May 25th, 2017 (Today!) according to Board of Appeals rules. You can email them at: Boardofappeals@sfgov.org

Neighbors are seeking to save this tree, one of the few large shade and habitat trees remaining on Haight Street. It’s disrupting the sidewalk, but an arborist has determined that the tree can be saved simply by enlarging the tree basin to accommodate its roots, fixing the sidewalk, and pruning some of the branches.

If you want to help save this tree, you can sign the Change.org petition here, and also email the Bureau of Urban Forestry  at urbanforestry@sfdpw.org and tell them you protest the removal of the tree at 826 Haight. — deadline June 21, 2017)

Threatened tree at 826 Haight Street San Francisco

The San Francisco Forest Alliance is acutely aware of the value of Green Infrastructure, and we support the efforts of neighbors and neighborhood groups to preserve non-hazardous trees.

Memorial for Peter Ehrlich, 1948-2017

The Presidio had a community work day and memorial for Peter Ehrlich today. Here’s a report from a friend who attended.

Peter Ehrlich’s memorial at the Presidio was very well done. There were at least 150 people there and they did a lot of work. Pete had planted many Monterey cypresses around the Spire and they needed to be weeded and mulched. So, the work directly benefited the trees Pete had planted.

The location of the memorial at the Spire was an appropriate location. The massive sculpture of cypress logs by Andy Goldsworthy was important to Pete because he had the pleasure of helping Goldsworthy find the wood for the sculpture.

He really enjoyed talking with Goldsworthy. The Spire was decorated with pictures of Pete and flowers all around the Spire. There was also a book of pictures of Pete that will be given to his daughter, Lily. People were invited to write in that book. There were eucalyptus leaves on which people were invited to write tributes to Pete that were hung on the trees. My message was, “We will watch the Presidio forest for Pete.”

Dee Seligman [former Interim President of SFFA] spoke explicitly for San Francisco Forest Alliance by reading a portion of her tribute that was posted to the SFFA website. When she read the last paragraph about the help he gave us regarding the plans of the Natural Areas Program, people applauded.

SFFA was well represented and Pete would have been proud of how he was remembered.

We would like to thank the author of this account, and thank Dee Seligman for the touching and appropriate remembrance.

Pesticides in our Parks, Jan-March 2017

Herbicide Spraying in Glen Canyon May 2017

Someone recently sent us this picture (above) of herbicide being sprayed at Glen Canyon.

Saw a guy spraying pesticides in Glen Canyon today. I didn’t want to get close enough to read the sign because he’s spraying right now and I’m pregnant.  I’m assuming its one of the same old for the same old reasons.  It’s right near a child’s classroom and right near someone’s backyard.  Somewhat related, did you hear that a coyote in Glen Canyon was killed by rat poison?

Clicking on the picture will bring you to a very short video of the spraying.

In other news, the petition opposing pesticides finally closed with 12,113 signatures!


We recently received and compiled the San Francisco Recreation and Parks Department (SFRPD) pesticide usage reports for the first quarter of 2017. There’s good news and bad news.

Bad news first: The first quarter continues to be Garlon time in the Natural Areas, which comprise the areas under the Natural Resources Division of SFRPD and the SFPUC areas that are managed by the same land managers.

In 2017, they applied Garlon 25 times, up from 23 in 2016. The volume applied is nearly the same; on an “active ingredient” calculation, it’s 61.2 fluid ounces in 2017 slightly down from 61.5 fl oz in 2016. Garlon is used only against Bermuda buttercups (oxalis, sourgrass, soursob, oxalis pes caprae).

The main parks where it was applied were Twin Peaks, McLaren Park, and Mt Davidson, though they did use it at other locations too.

This is especially bad news because Garlon is one the most toxic herbicides the city is allowed to use. Ever since we’ve been following it, not only has it been designated Tier I (Most hazardous), there’s been a notation against it: HIGH PRIORITY TO FIND AN ALTERNATIVE.

Garlon is also supposed to be twenty times as toxic to women as to men. (See page 28 of this California Native Plant Society Presentation which discusses best management practices in herbicide use: Law_Johnson 2014 presentation toxicity )

Oxalis is not considered terribly invasive. Its brilliant yellow color and early spring flowering make it very visible, but it needs disturbance to spread. If it is ignored, it will over time give way to other plants. In any case, after its explosion of spring color, it dies down and other plants take over. There is considerable doubt about the effectiveness of herbicides on oxalis, because it grows from bulbils (tiny bulbs) that are well protected, and will resprout the following season.

Here’s our quick presentation about Garlon and oxalis: Garlon vs Oxalis in Ten Easy Slides. In summary: San Francisco could get rid of this very toxic “HIGH PRIORITY TO FIND ALTERNATIVE” herbicide merely by calling a truce on its war with oxalis. (Here’s a longer article, with some lovely photographs: Five Reasons why it’s okay to love oxalis and stop poisoning it )

Now for the good news:

  • SFRPD has cut back a lot on its use of Roundup (also called Aquamaster), i.e. Glyphosate. This is the chemical that the WHO declared a probable carcinogen.  In 2017, Natural Areas used it three times, twice at Twin Peaks and once at Laguna Honda.
  • The main user of Glyphosate: Golden Gate Park Nursery, which Chris Geiger (the Integrated Pest Management person at SF Environment) explained is not a public area. They used either 25 fl oz or 40 fl oz of glyphosate (active ingredient basis), depending on whether one of the entries is a duplication. We have a question in about that to SFRPD and SF Environment, and will update this when we have an answer.
  • No Tier I herbicides were used in Glen Canyon from Jan-March 2017. Though Natural Areas elsewhere were sprayed with Garlon for oxalis, none was used in Glen Canyon – where neighbors are concerned because of the many small children who play there, as well as potential water contamination.


We still have concerns, though we do acknowledge the efforts of SF Environment and SFRPD to control the use of toxic herbicides. We will go into those in detail another time, but here are a few, in brief:

  • Allowing the use of Tier I herbicides even in non-public areas does not prevent them from contaminating the environment.
  • This is especially true now that San Francisco will be adding its own ground water to the public water supply. No one wants pesticides coming from our taps.
  • The Natural Areas already severely restrict access by requiring people to stay on the limited number of “designated trails” – mainly broad paths that have been improved in some cases into stairways and mini-roads. Using Tier I herbicides will give them an incentive to block off much of the park, so it is accessible only to SFRPD staff or volunteers.
  • Instead of eschewing herbicides altogether, new combinations are being considered for addition to the list of permitted pesticides.

San Francisco Forest Alliance’s stance: No Pesticides in our Parks.

We continue to work toward this goal, and support the efforts of SF Environment and thousands of people to get there.