Glen Canyon Park: One Year after Start of Tree Destruction

The Glen Canyon Playground and Tennis Court Project – as the city is calling this – is nearly completed. In February or March 2014 there will be great fanfare at the completion of this project.

Video update to the Glen Canyon Park tree demolition project

Is it an improvement? Well, there is a new playground at least, but it will not be the same as it was: a steep staircase to the slide and bushes that were at the top – gone. The kids loved those; they played games of imagination and adventure there. Instead of a quirky playground that used the advantages of the site, there’s a standard-issue place that could have been built anywhere.  And the wonderful climbing tree the children loved, behind the Rec Center – also gone. The new kids will not know what they missed.

The City Arborist report stated that only 1 tree was truly hazardous, yet 42 trees were destroyed. Equally troubling is the deliberate relocation of tennis courts that destroyed 11 healthy and majestic Eucalyptus guarding the Park’s entrance.

Question: Why was there no attempt to incorporate these trees into the overall design goal that could have been achieved without sacrificing space for the playground and ball field?

Answer: San Francisco taxpayers “purchased” a native plant garden as part of the project and ensured all those “poor suitability / non-native” trees were eliminated.

Functional, Beautiful Ecosystems Should Be Left Alone; the Parks need maintenance, not destruction.

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Glen Canyon Park: Nine Months after Tree Destruction

Video update to the Glen Canyon Park tree demolition project

San Francisco’s Wreck and Park Department is now calling this “The Glen Canyon Playground and Tennis Court Project“.  This is only a continuation of the mis-information that have been provided as the Glen Canyon Park Improvement Plan (note: they are spending $5,800,000 of the 2008 Park Bond Fund for Glen Canyon “renovations”).

You will be seeing in this new video a bit more than just preparations for a new playground and 2 new tennis courts. The damage to Glen Canyon Park by the city is significant; we thought the project was the “removal and pruning of select trees”, but it is much more than that. And the wonderful children’s climbing tree is now gone; it once stood behind the Rec Center.

Here is a reminder [Beginning of Glen Canyon Park tree destruction] of what was once there. On January 10, 2013 we reported on the start of this demolition project by the city. The grand eucalyptus trees at the Elk Rd entrance, over a century old, were quickly destroyed. Hundreds of other trees in the canyon, the ones the children love and climb in, the ones the birds nest in and bats hide in, the ones that feed the and protect the wildlife of this canyon – all will be gone by the time this project is completed next year.

all the trees in this picture will be gone in a few days

All these trees are gone

Tree 22 with kids

There’s bare ground where this wonderful climbing tree stood

Before tree removal

Before tree removal and so different now

 

Long Lost Manzanita Brings Newfound Problems (Westside Observer re-post)

Editor Notes:
This is a reposting of  an important story about the plan to reintroduce Franciscan manzanita into City park land – and now also private property along Marietta Drive in the Miraloma Park neighborhood. We also want to refer to important background information about the ambiguity of the taxonomy of manzanita.  Click here

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George Wooding

George Wooding

LONG LOST MANZANITA BRINGS NEWFOUND PROBLEMS
By George Wooding

Westside neighbors are concerned a rare manzanita plant will have a profound impact on neighborhood habitats and uses.

franciscan manzanita

Franciscan manzanita

In 2009, a 14-foot wide Arctostaphylos franciscana (Franciscan manzanita) — a plant thought to be extinct in the wild for the last 60 years — was discovered in the Presidio during the 2009 Doyle Drive rebuild. It was deemed to be the last wild Franciscan manzanita and immediately labeled a genetically-unique plant that needed to be saved.

“Does it make sense for over six percent — 318 acres — of City-managed park land to be permanently committed to planting an endangered species that can be readily purchased in nurseries?”

Flash forward to 2013. In just four years, 424 plants genetically identical to the Franciscan manzanita found in the Doyle Drive construction site have been propagated via cuttings, according to Betty Young, director of nurseries for the Golden Gate National Parks Conservancy, who is coordinating the effort.Manzanita habitat

On September 5, 2012 the U.S. Fish and Wildlife Service issued its proposed designation of 11 areas in San Francisco as critical habitat for the endangered manzanita plant. That proposed designation includes part of Mt. Davidson. Critical habitats are places where endangered plants are either known to have existed in the past, or are places that provide what a plant needs to survive.

By June 28, 2013 the Fish and Wildlife Service designated 318 acres in San Francisco as critical habitat for the plant.

Critical Habitat vs. Eminent Domain

One of the new critical area habitats for the manzanita plant includes the area along Marietta Drive facing O’Shaughnessy Hollow all the way down along O’Shaughnessy Boulevard, and includes all of the open space known as Reservoir Lands at Glen Park, which has trails currently accessible on Marietta Drive.

The designation of 3.2 acres of private property directly below Marietta Drive as critical habitat has been controversial. The backyards of 22 homes on Marietta Drive are now designated as critical habitat for the Franciscan manzanita. The government cannot use critical habitat designations to take over or control property rights.

However, at the September 23 West of Twin Peaks Central Council meeting, it was stated that the Fish and Wildlife Service may use “eminent domain” to control the 3.2 acres for possible reforestation. But according to Robert Moler, Assistant Field Supervisor for External Affairs for the Fish and Wildlife Service, “Activities on private lands that don’t require Federal permits or funding are not affected by a critical habitat designation.” In other words, private citizens will still be able to control 100% of their land regardless of a critical habitat determination.

manzanita brush

“Eminent Domain is completely different than a critical habitat designation. Eminent domain is the power of the state to seize private property without the owner’s consent. A critical habitat designation only delineates the best places an organism can survive.”

NAP Clams Up

All of this Mt. Davidson land is controlled by the SF Rec & Parks (RPD). The RPD’s Native Area Plants Department (NAP) will be overseeing the replanting of the Franciscan manzanita throughout this area. Unfortunately, NAP has not met with neighbors to discuss its plans to reestablish the manzanita. Nor has any government agency contacted the neighborhoods about the manzanita. Calls to NAP Director, Lisa Wayne, were not returned.

As with other NAP projects, public access to large areas may become off-limits so that the Francisco manzanita can become reestablished. Neighbors are worried that large sections of Mt. Davidson might be closed to the public for years while the wild Franciscan manzanita is getting established. NAP has been completely silent on whether it will designate open space areas as being off-limits, and for how long.

It cost San Francisco $205,075 to dig up and replant the last remaining wild Franciscan manzanita, including $100,000 to pay for the “hard removal,” $79,470 to pay for the “establishment, nurturing and monitoring” of the plant for a decade after its “hard removal,” and $25,605 to cover the “reporting requirements” for the decade after the “hard removal.”

The Franciscan manzanita is also a commercially cultivated species of shrub that can be purchased from nurseries for as little as $15.98 per plant, and have been available for purchase in nurseries for about 50 years. The plants are propagated by taking cuttings and, therefore, are presumed to be almost genetically-similar.

The last wild Franciscan manzanita may have been found, but it may be a hybrid of the manzanita plants found in nurseries. Recent taxonomic revisions have established Franciscan manzanita as a separate species, based primarily on genetic comparisons, including the fact that Franciscan manzanita has 13 pairs of chromosomes, while its closest relative (A. montana ravenii )  has 26 chromosome pairs.

Manzanita seeds are germinated by fire, but the exact relationship between germination and fire isn’t known. This is why the plant is constantly cloned. The plant also requires full sunlight. How many trees will NAP cut down to provide the Franciscan manzanita with full sunlight?

The Francisco manzanita is listed as an endangered species. The Endangered Species Act listing for the rare bush means anyone who removes or tampers with the plant could face criminal prosecution and fines. The designation also qualifies the plant for federal conservation funds.

Does it make sense for over six percent — 318 acres — of City-managed park land to be permanently committed to planting an endangered species that can be readily purchased in nurseries? How will the Franciscan manzanita be able to survive without fire?

Neighbors need to know what is happening with the 318 acres of San Francisco private and public land that will be used to replant the manzanita, and how the critical habitat determination will impact public open space. RPD outreach to neighborhoods continues to be poor and disingenuous. NAP has stonewalled the public far too long and must be required to meet with Westside neighbors.

by George Wooding, Midtown Terrace Homeowners Association

Update – “Unsuitable” tree removals on Creekside Trail, Glen Canyon Park

On October 24th we reported the planned tree removals along the Creekside Trial (west side of Islais Creek) in Glen Canyon. We are now submitting aftermath photos: the conditions now, after the Glen Canyon Trails project “tree work”.

Background: HORT Science, recipient of Park Bond funding, is used by the Rec and Park Park dept to assess the suitability of  trees located along the proposed trails. Their September 6, 20013 report for Glen Canyon Park is here. In summary they recommended that 30 trees be removed: 26 blue gums, 2 arroyo willows and one each of yellow willow and Monterey cypress. Ten (10) trees were identified as needing to be pruned including 6 arroyo willow, 2 blue gum, one Monterey cypress and one river red gum.

Trails are temporarily closed during the tree cutting

Trails are temporarily closed during the tree cutting

Park and Rec is calling this “…completing hazardous tree mitigation work”  but does not address how these trees could be saved by re-rerouting or narrowing trails, thinning the crowns, pruning and tipping, weight redistribution, limb removal, and cabling or bracing.

Cut stump along Creekside Trail

Cut stump along Creekside Trail

Even healthy eucalyptus trees are rated negatively by HORT and RPD as unsuitable for preservation merely because they are not native and therefore considered invasive.

tree workers cut limb by limb

tree workers cut limb by limb

cut limbs are tied and lowered to the ground

cut limbs are tied and lowered to the ground

Cut Stump along trail to Glenridge Co-Op Nursery School

Cut Stump along trail to Glenridge Co-Op Nursery School

Banana Slug Way - as this trail is known - will be transformed

Banana Slug Way – as this trail is known – will be transformed

A retaining wall is planned along here (steel posts,and wood planks)

A retaining wall is planned along here (steel posts,and wood planks)

A crane was used on Alms Road, (Tuesday, October 29) to take out a tree that had the misfortune of growing in the middle of Islais Creek.  A Blue gum, trunk diameter 50 inches, was deemed a potential hazard (said HORT: “Center of creek. Stands alone. Leaning & bowed E. over Alms Road.” ).

Replacing trees with concrete retaining walls to make a natural area more natural?

Eucalyptus Stump - middle of Islais Creek (did it impeded the flow of creek water? )

Eucalyptus Stump – middle of Islais Creek (did it impeded the flow of creek water? )

A 50 inch diameter Eucalyptus - likely one of the older trees in Glen Canyon Park

A 50 inch diameter Eucalyptus – likely one of the older trees in Glen Canyon Park

Mature trees absorb carbon and make our air cleaner. Dead ones release carbon and add to green house gases. 

Once trees, now logs (easy removal via Alms Road)

Once trees, now logs (easy removal via Alms Road)

Fallen Euchs near Silver Tree day camp

Fallen Euchs near Silver Tree day camp

Some of HORT’s reasons for the decisions to remove selected trees: “poor form & structure”;  “Sharp lean E. over trail”;  “upright but one-sided towards trail”;  “Leans over trail”;  “cracked branches”.

Let’s repair these trees rather than destroy them. It would cost less money and be better for the environment.

"poor form & structure"

“poor form & structure”

"Sharp lean E. over trail"

“Sharp lean E. over trail”

"upright but one-sided towards trail"

“upright but one-sided towards trail”

Ugly stumps left to remind us of how well are Park Bond dollars are being used to destroy our parks.

"Leans over trail"

“Leans over trail”

"cracked branches"

“cracked branches”

Per community requests, Rec and Park will allow the “Ticket Tree” to be a stump. This is a Monterey Cypress stump just west of the trail from the Rec Center to Silver Tree Day camp. They have cut it off higher than just a stump to accommodate popular children’s play with the slot in the tree; children use it as a mail box to deliver
letters to each other.

Are our children being taught by RPD that the best tree is a dead stump?

Ticket Tree before cutting

Ticket Tree before cutting

We did notice a larger than usual cutting of trees near the ball field.  This is how it looked before the recent cuts:

Prior view:  from small ball field

Prior view: from small ball field

And how it looks now.

Current view; from small ball field

Current view; from small ball field

View from Bosworth Street (cuts made for a paved walkway down to field)

View from Bosworth Street (cuts made for a paved walkway down to field)

The city’s Rec and Park Department is “excited to be starting this extensive capital improvement project, funded by the 2008 Clean and Safe Neighborhood Parks Bond and by multiple Habitat Conservation Program grants.”

We, however, are less excited when we observe the tree damage to what was a wonderful, quirky trail on west side of Islais Creek in Glen Canyon Park.

Note that the 2008 parks bond allocated $900,000 of the $5 million Parks Trails Improvement Program
for this Glen Canyon project.  That’s alot of money for ADA compliant pathways, ‘turnpike’ parkways, retaining walls, split rail fences – from Bosworth St, all the way up to Portloa Drive, past the School of the Arts (SOTA).

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Note: Photographs were taken recently, all are accredited to Ron Proctor.

Endangered Manzanita – Reopened Comments until July 29, 2013

six-dollar franciscan manzanita

Franciscan Manzanita – Nursery specimen, six dollars

US Fish and Wildlife Service (USFWS) has reopened the comment period  for its designation of “critical habitat” for an endangered manzanita.

[You can find the Notification HERE]

This designation will likely mean significant access restrictions and possibly other unfortunate effects such as tree-removal and prescribed burns.

The new notice adds new acreage – especially around McLaren Park and Glen Canyon Park (wrongly labeled Diamond Heights) – to bring the total in Natural Areas to 203 acres (of a total of ~1100 acres of Natural Area Program land)

If you wish to comment, you can do so online HERE (look for the “comment now” button on the top right) or mail them a letter. Comments will not be anonymous. If you already sent a comment last time round, you don’t have to re-send it. It’s on record. But if you have additional thoughts, you can certainly send an additional comment.

From US FWS website:

Written Comments: You may submit written comments by one of the following methods:

(1) Electronically: Go to the Federal eRulemaking Portal: http://www.regulations.gov. Search for Docket No. FWS-R8-ES-2012-0067, which is the docket number for this rulemaking.

(2) By hard copy: Submit by U.S. mail or hand-delivery to: Public Comments Processing, Attn: FWS-R8-ES-2012-0067; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, MS 2042-PDM; Arlington, VA 22203.

We request that you send comments only by the methods described above. We will post all comments on http://www.regulations.gov. This generally means that we will post any personal information you provide us (see the Public Comments section below for more information). [That’s at the same link.]

BACKGROUND

Some months ago, a specimen of manzanita (arctostaphylos franciscana)  – found during the Doyle Drive project in San Francisco – was declared a federal endangered species.

Though difficult to grow from seed, this manzanita is easy to clone.  You can buy plants originating from cuttings (from a different specimen of the same plant) for about $6.

The details are HERE

US Fish and Wildlife Service is in the process of designating critical habitat for this plant within San Francisco.

If this manzanita, which now has the legal status of a Federally endangered species, is planted in these areas, it will get the same protection as if it occurred there naturally. This will likely mean access restrictions; it could mean the felling of trees because this species needs full sun; and potentially might even require prescribed burns (to allow its seeds to germinate).

We wrote about that HERE.

COMMENT PERIOD REOPENED

US FWS has reopened its comment period. It discovered it was inadvertently using the wrong map, which overstated all the acreages. It’s corrected the acreage in its revised notification. It is currently asking for a total of  197 acres, of which 51 are Federal, 133 are city-owned, and 13 are private.

  • More importantly, the National Parks Service has asked for a reduction in the Federal areas, to protect its restoration efforts for other Native Plants, and also to preserve its historic forests.
  • Meanwhile, SFRPD staff have proposed an additional 73 acres to be designated as critical habitat: 56 acres in McLaren Park (which was not included earlier at all); and an additional 14 acres in “Diamond Heights” (actually, Glen Canyon and the area above O’Shaughnessy Boulevard). It’s also requested the designation of 3 acres of private land in the same area.
  • If this goes through as notified, nearly a fifth of the Natural Areas (203 acres of 1100) will be designated critical habitat for this plant – even though the plant was originally found only in four locations in San Francisco.

WHERE ARE THESE AREAS?

The colored map here broadly indicates all the areas that are to be designated as critical habitat.

Franciscan Manzanita map updated July 2013In more detail, here is the revised map for Glen Canyon. The two areas called “Subunit 9A” and “subunit 9B” are newly added to the proposed designation of critical habitat.

glen canyon updated 1

These are the two maps for McLaren Park. This park was not included in the earlier designation.

mclaren 1 sm mclaren 2 sm

WHAT DOES “CRITICAL HABITAT” MEAN?

By designating “critical habitat” the USFWS says, in essence, that these areas are so important to the conservation of the species that they must not be changed by the Federal government – or by any activity it funds or authorizes.

From the USFWS notification:

Section 3 of the Act defines critical habitat as the specific areas within the geographical area occupied by a species, at the time it is listed in accordance with the Act, on which are found those physical or biological features essential to the conservation of the species and that may require special management considerations or protection, and specific areas outside the geographical area occupied by a species at the time it is listed, upon a determination that such areas are essential for the conservation of the species.

“If the proposed rule is made final, section 7 of the Act will prohibit destruction or adverse modification of critical habitat by any activity funded, authorized, or carried out by any Federal agency. Federal agencies proposing actions affecting critical habitat must consult with us on the effects of their proposed actions, under section 7(a)(2) of the Act.”

If these “endangered” plants are introduced, we can expect that the Natural Areas Program will want to protect them. This may mean:

  • Restricting access (perhaps with fencing);
  • Cut down any trees shading the plants since they require full sun; and
  • Maybe even seek to get permission for prescribed burns, since it’s possible the Franciscan manzanita needs fire to germinate. (This is believed true of the closely-related Raven’s manzanita.)

It will also mean that the area cannot be planted with anything that clashes with the manzanita in its requirements – including large shrubs and bushes (even if native). It will probably mean more pesticide use, to keep other plants from encroaching on the area where they’re trying to grow this one.

WHAT IS THIS PLANT AND IS IT ENDANGERED?

We mentioned before that Franciscan manzanita plants, grown from cuttings of another specimen, have been available in plant nurseries for some 50 years.   This plant, the Doyle Drive manzanita, is presumed to be a different individual of the same species. If so, this is good because it would add a little genetic diversity. However, until someone does a DNA analysis, we cannot tell if it’s true.

  • It could be a nursery plant that someone introduced; the neighboring plants were non-native and very likely deliberately planted. In that case, it will be genetically identical to the others.

  • It could be a cross with another manzanita species. Manzanitas generally hybridize really easily, and some scientists think this is a cross between Franciscan manzanita and arctostaphylos uva-ursi.

It’s complicated with manzanitas. They adapt to any little change in their environment, and they are easily crossed with other manzanita species. As a result, scientists often have to re-define which are species, which are subspecies, and which are mistakenly considered a separate species when they’re not.

WHAT ARE ITS CHANCES?

There’s a closely-related  manzanita species, Raven’s manzanita, that is also as endangered. For over 30 years now – and an estimated $23 million – people have been trying to bring it back. The definition of success would be two generations of plants produced from seed (not cuttings) and some spontaneous populations in the wild. That’s not much of a target to achieve – but it isn’t happening.

So with all the time, trouble, and expenditure – what are the chances of the closely-related Franciscan manzanita succeeding?

Franciscan manzanita

Franciscan manzanita

Franciscan manzanita is now an endangered species

Last week US Fish & Wildlife announced that Franciscan manzanita is now an endangered species. In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive. It was transplanted to an undisclosed location in the Presidio in San Francisco at a cost of $175,000, (or, according to some accounts, $205,000) including an additional annual cost for maintenance. Is this a preview of potential cost of reintroducing this plant throughout San Francisco?

Franciscan manzanita

Although that plant is thought to be the only one of its species existing in the wild—if the Presidio can be said to be wild—it has always been for sale in nurseries.  Yes, the plant given endangered status is considered the same species as those for sale in nurseries, but it is presumed to be genetically unique.  Because genetic diversity is considered important to the survival of a species, the recently discovered plant has been given endangered status.  This makes for an interesting and puzzling lesson on the Endangered Species Act.

CRITICAL HABITATS FOR ENDANGERED SPECIES

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of public land in San Francisco as critical habitat for the Franciscan manzanita.    Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio.  (Details about all the critical habitats are available here.)  Forty of the 318 acres are on private land.  Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

POTENTIAL IMPACTS ON SAN FRANCISCO’S PUBLIC LANDS

The San Francisco Forest Alliance is studying the impact that planting this endangered species might have.  If the proposed critical habitat in these parks is in forested areas, we will undoubtedly object in our public comment because Franciscan manzanita requires full sun which implies that the trees would be destroyed to accommodate the plant.

Sharp Park, Pacifica, CA. Photo by Erica Reder, SF Public Press

We are also concerned about the potential for restrictions on recreational access such as more trail closures and fences needed to protect a fragile, legally protected plant.  The public has had a preview of such loss of recreational assets to protect endangered species at Sharp Park where native plant advocates and their allies have sued to close the golf course, using the Endangered Species Act.

If you are a visitor to or a neighbor of any of these parks, you might want to inform yourself of the potential impact of planting an endangered species with specific horticultural needs.  For example, this is a plant that requires full sun.  Since all of Bayview Hill has been designated as critical habitat and Bayview Hill is heavily forested, you might wonder if this particular park is a good fit for this plant.  Furthermore, this seems to be the only one of the proposed critical habitats in which this plant is not known to have existed historically.

US Fish & Wildlife tells us that the designation of critical habitat for plants does not commit non-federal land owners to reintroduce this endangered plant unless they receive federal funding.  Federal land owners and recipients of federal funding are obligated to consult with US Fish & Wildlife before making any commitments to changes in land use which would not be consistent with the successful reintroduction of the endangered plant.  We assume that the city of San Francisco receives federal funds, so it seems likely that these restrictions would apply to the critical habitats in city parks.  Legal requirements for critical habitat of endangered animals are more rigorous.

MORE INFORMATION AND PUBLIC COMMENT OPPORTUNITY

More information is available from the Sacramento Office of US Fish & Wildlife:

Robert Moler, robert_moler@fws.gov, (916) 414-6606
Sarah Swenty, sarah_swenty@fws.gov, (916) 414-6571

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at http://www.regulations.gov (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn:  FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.

West of Twin Peaks Central Council opposes Natural Areas Program, Part 3: Park Access, Habitat & Wildlife

This article is Part 3 of the West of Twin Peaks Central Council (WTPCC) letter opposing the Natural Areas Program (NAP). Emphasis has been added.

Part 1 is HERE (Opposing the Natural Areas Plan)
Part 2 in HERE (Trees and Pesticides)

Read on for Part 3.

PARK ACCESS

WTPCC opposes NAP plans to restrict access to parks. NAP plans to close 9.2 miles of trails that thread through its natural areas. At our May meeting, Dennis Kern noted that a citywide survey of what San Franciscans want in their parks identified trails and hiking as the number one need. Yet NAP plans to close nearly a quarter of the total length of trails in natural areas (about 40 miles). This would seem to fly directly in the face of what the public said they want in their parks.

In most natural areas, the only thing you can do is walk on a trail. You cannot leave the trail to explore the area, or follow a butterfly, or try to see the bird you hear tweeting. To control access, NAP builds fences. Indeed, in parks where trails in natural areas have been restored recently, fences have been built on either side of the trail to ensure people cannot leave the trail. Natural areas become places where you can “look but not touch.” How can children explore the wonders of nature if they are told repeatedly they must “Stay on the Trail”? This is not what we want for our parks.

When people are restricted to walking only on trails, they lose access to the entire non-trail part of the park. In over half of the parks with a natural area (17 of 31), NAP controls the entire park. That means people have lost access to all but the trails in those parks. In an additional 10 parks, NAP controls over 50% of the land. Put another way, only four of the 31 parks with natural areas have less than 50% of their land controlled by NAP. Access restrictions planned by NAP (“stay on the trail”, fences, and closure of trails) mean that entire neighborhoods will lose access to the vast majority of the parkland in their neighborhood parks. The Draft DEIR does not consider the impacts on neighbors and park users of this level of access restriction in the 27 parks where NAP controls more than half the land.

HABITAT AND WILDLIFE

WTPCC opposes the destruction of existing habitat needed by the wildlife and birds currently living in the parks. For example, NAP has removed underbrush in Glen Canyon that is used by coyotes to hide from people and dogs, and replaced it with grasslands. Unlike the underbrush, the grasslands provide little “cover” for the coyotes or other wildlife living in the natural area.

We are also concerned that some habitat conversion is being done during breeding and nesting season. For example, NAP applied for a “streambed alteration” permit from the California Fish and Game Dept for habitat conversion work to be done near Islais Creek in Glen Canyon. In the application, NAP clearly stated: “It is the policy of RPD’s Natural Areas Program that no new projects will begin during the breeding season (December to May).” Similar commitments were made in the SNRAMP.

However, NAP contractors used chainsaws and herbicides to destroy underbrush habitat in Glen Canyon in March and April, continuing work done sporadically since November 2011. This work took place throughout the breeding/nesting season, despite NAP’s legal commitment to CA Fish and Game and in the SNRAMP to not do habitat work during breeding season. When people informed RPD management about this, during a meeting at McLaren Lodge, Lisa Wayne, the head of NAP, said the work was being done during the breeding/nesting season because the grant for the project was set to expire. In other words, NAP’s decision on habitat conversion in Glen Canyon appeared to be motivated by financial considerations, not by any concerns about the wildlife and birds living there.

To be continued.