The Very Long Life of Eucalyptus Trees

This article is republished with permission and minor changes from Death of a Million Trees, a website that fights unnecessary tree killing in the San Francisco Bay Area.

 

 

PUTTING ANOTHER MYTH TO REST: LIFESPAN OF BLUE GUM EUCALYPTUS

When the native plant movement began in earnest, about 25 years ago, its proponents weren’t expecting blowback from those who value the existing landscape.  As far as they were concerned, the trees had to be destroyed solely because they “don’t belong here.”

When they started destroying our predominantly non-native urban forest, they learned that it wasn’t going to be as easy as they thought.  They began to defend their destructive projects with cover stories to convince the public who didn’t share their devotion to native plants that it is necessary to destroy non-native trees because they are a threat to public safety and to wildlife.

One by one, we have debunked the myths that were used to justify the destruction of our urban forest:

Great horned owl in eucalyptus. Courtesy urbanwildness.org

  • About 20 years ago, one of the first myths was that eucalyptus trees kill birds. It is an absurd claim that is completely unsupported by reality.  With a lot of careful research, we were eventually successful in convincing the public that birds are not harmed by eucalyptus.  In fact, many bird species are dependent upon the trees for safe nesting and winter nectar.   That myth is dead.
  • The claim that eucalyptus and other non-native trees are more flammable than native trees was a powerful narrative that was more difficult to kill. As wildfires have increased in frequency and intensity in California, that claim is no longer credible because every wildfire occurs in native vegetation.  Again, this myth was eventually disproved by reality.
  • More recently, we have finally put to rest the claim that “nothing grows under eucalyptus.” This myth was based on a theory that eucalyptus emits allelopathic chemicals that prevent the growth of plants in the eucalyptus forest.  Thanks to a recent, rigorous study done at Cal Poly, we know with confidence that the allelopathy story is another myth.

It was not surprising that the nativists, having run out of bogus justifications, created a new narrative.  In parks that the East Bay Regional Parks District had been planning to thin, we began to see clear cuts.  When we inquired about why it was necessary to destroy ALL of the trees, we were told they were hazardous.  Then, in the minutes of a meeting of East Bay Regional Park District Park Advisory Committee , we saw the claim that eucalyptus lives only 50-60 years.  Simultaneously, this claim was made in San Francisco by proponents of destroying all eucalyptus trees there.

We eventually tracked down the source of that lifespan estimate to a website called SelecTree, which originally said that the longevity of blue gums is only 50-150 years.  We knew that isn’t an accurate estimate because of how long blue gums live in Australia and how long they have already lived in California.  We provided that information to the authors of SelecTree and were able to get the estimate corrected to “greater than 150 years.”  That’s not nearly long enough, but it is the longest lifespan estimate available on that website and it corresponds with many other trees, including native Coast Live Oak.

In the process of researching the lifespan of eucalyptus, we learned several interesting stories about blue gums that have lived in California for 150 years and are still going strong.  We would like to share some of this information with our readers today.

BLUE GUM EUCALYPTUS IN AUSTRALIA LIVES 200-400 YEARS

Blue gum eucalyptus and all other species of eucalyptus are native to Australia.  They were brought to California shortly after the Gold Rush of 1849.  Since they haven’t been in California 200 years, we don’t know how long they will live here.  But how long they live in Australia is obviously relevant to answer that question because longevity is specific to tree species.  We can expect some variation by climate, but not much, and the climate of Australia is similar to the climate in California with wet, mild winters and hot, dry summers.

We know that blue gums live in Australia about 200-400 years because Australian scientists tell us that:

Growth Habits of the Eucalypts by M.R. Jacobs, (Institute of Foresters of Australia, 1955, 1986): Blue Gum eucalyptus lives in Australia from 200-400 years, depending upon the climate.” In milder climates, such as San Francisco, the Blue Gum lives toward the longer end of this range.

That reference was corroborated by John Helms, Professor Emeritus of Forestry at UC Berkeley and an Australian who said in response to our question about blue gums in California, “Blue gums would commonly live for 200 – 400 years, although I presume that some might live longer.”

We also asked the Australian National Botanic Gardens.  They said, “It’s possible that the average lifespan of a native species growing in the wild in Australia would differ to the average lifespan of the same species introduced in northern California, since introduced plants can often “escape” their natural predators when such introductions occur.”

In other words, since eucalyptus trees have more predators in Australia than they do in California, we should expect them to live longer here.  This is called the “predator release” hypothesis.  Ironically, that hypothesis is used by nativists to support their claim that eucalyptus is invasive in California.  (California Invasive Plant Council rates the “invasiveness” of blue gum as “limited.)  It’s only logical to apply that hypothesis to the question of how long blue gums will live in California.

MANY HEALTHY BLUE GUMS IN CALIFORNIA ARE 150 YEARS OLD

However, using actual experience in Australia to predict the future of blue gums in California requires some speculation.  Therefore, we turned to the question of how long they have lived in California for guidance.  We found several interesting local stories about blue gums that were planted in California 150 years ago and remain healthy and vigorous today.

There are many examples of blue gums being planted as street trees in California about 150 years ago.  One of the most well-known examples is the city of Burlingame on the San Francisco peninsula. When the City was founded in the 1870s, John McLaren was hired to plant trees to provide a much needed windbreak because the City was nearly treeless, as was the entire San Francisco peninsula.  McLaren planted over 500 eucalyptus (blue gum and manna) along the main highway through Burlingame, along with a row of English elms.  John McLaren was subsequently hired by the city of San Francisco, where he planted many more eucalypts while serving as superintendent of the parks department for 53 years.

The eucalypts in Burlingame are still thriving, but the elms have been dead for about 60 years.  SelecTree says the longevity of English elms is “greater than 150 years,” the longest category of longevity published by SelecTree and completely open-ended.

El Camino Real bordered by Eucalyptus trees. Burlingame, SF Bay area, California, USA

The people of Burlingame greatly value their eucalypts and designated them as “heritage trees” in 1975 under a local ordinance.  That local legal status did not protect them from several attempts by Caltrans to destroy the trees.  The people of Burlingame came to the defense of the trees and were eventually successful in getting permanent legal status to protect 2.2 miles of the trees.  That section of El Camino Real in Burlingame lined with eucalyptus was listed on the National Register of Historic Places in 2012.

Caltrans is now working cooperatively with the people of Burlingame to address safety concerns while “also keeping an eye to the prized grove of eucalyptus trees along the street.”  A task force was formed in 2018 to discuss these issues.  The City of Burlingame remains committed to the preservation of these trees, which suggests that they have a future there. (1)

The life span of street trees is generally much shorter than trees planted as forests because they are subjected to more wind and polluted air of heavily traveled roads, such as El Camino Real.  Although blue gums have passed the test of those challenging conditions with flying colors, they have not been planted as street trees for decades.  Their out-sized scale makes them unsuitable for that purpose.  If blue gums can survive as street trees on heavily traveled roads, they can surely survive longer in the protection of their neighbors in forests.

BLUE GUMS AT STANFORD UNIVERSITY

The blue gums on the campus of Stanford University are another example of 150 year-old blue gums that are very much alive.  Although blue gums were included in the campus landscape design of Frederick Law Olmsted in the 1880s, many of the blue gums actually predate his design:  “Several hundred mighty giants on the campus date back prior to 1870 when Leland Stanford acquired several farm properties, one of which already had avenues of gum trees.  They are mostly Tasmanian blue gums and red gums with a sprinkling of manna trees.”

Eucalyptus on Stanford campus

That description of the old blue gums was written in 1971.  The trees are still alive and well.  I worked on the Stanford campus for 10 years and walked among those trees at every opportunity.

AN EVEN OLDER OLMSTED DESIGN IN OAKLAND

Mountain View Cemetery in Oakland, California was designed by Frederick Law Olmsted in the 1860s.  Like most of the East Bay, the site was treeless.  Olmsted’s design was an eclectic collection of mostly non-native trees, including blue gums.  The cemetery is on steep, windward facing hills, where the windbreak provided by blue gums is particularly valued.

Eucalyptus in Mountain View Cemetery, planted on an unirrigated windward facing hill. 2017

Olmsted designed a straight avenue through the cemetery lined with magnolia trees.  Many of the magnolia trees have died and those that remain are in poor condition.  SelecTree claims that the life span of Southern magnolia is “greater than 150 years,” which is contradicted by our local experience.

The current owner of the cemetery destroyed many of the blue gums about 5 years ago, in the middle of the extreme drought.  He replaced many of the blue gums with redwoods.  The redwoods are irrigated and are still surviving.  I did not object to the removal of the blue gums because they are on private property.  I confine my advocacy to healthy trees on public land.

LONG LIVE THE BLUE GUMS!

SelecTree has revised its listing of blue gum longevity based on the information we provided.  The myth that our blue gums are dying of old age will not die as easily.  We will have to repeat this information many times and in many different venues, just as we did for every other myth.  If and when that particular myth dies, we can be sure there will be another waiting in the wings.  Ideologies stubbornly persist, despite contradictory evidence.  And yet, we just as stubbornly persist in defense of our urban forest.


(1) Here is the public record, on which my report about the trees in Burlingame is based:

https://burlingameproperties.com/articles/1607-burlingame-s-heritage-trees

https://www.smdailyjournal.com/news/local/future-plotted-for-burlingame-s-el-camino-real/article_a27c43c4-1dd1-11e8-8a5d-b31dfaa94144.html

http://www.burlingamevoice.com/2012/03/nationally-historic-100-years-of-protection-rewarded.html

https://tclf.org/landscapes/howard-ralston-eucalyptus-rows

http://articles.latimes.com/2003/aug/10/local/me-sbriefs10.1

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Why a NO vote on AB 2470 (June 2018 election)

AB 2470, “Invasive Species” is a bill to “establish the Invasive Species Council of California, composed as prescribed, to help coordinate a comprehensive effort to exclude invasive species already established in the state. The bill would establish a California Invasive Species Advisory Committee to advise the council on a broad array of issues related to preventing the introduction of invasive species and providing for their control or eradication, as well as minimizing the economic, ecological, and human health impacts that invasive species cause…”

Fortunately, the Bill has been amended so no funds are being allocated to this effort. We still think it’s a dangerous bill that will result in a massive increase in pesticide use and environmental destruction.

LETTER FROM SAN FRANCISCO FOREST ALLIANCE

Here’s our letter on the subject:

——————-

Our members attended a recent budget town hall conducted by Assembly Member Phil Ting. It sharpened our appreciation of California’s needs in the fields of housing, education and health care.

With many thanks for removing funding for Weed Management Areas and Invasive Species Fund from AB 2470, we question the necessity of establishing both an Invasive Species Council of California and a California Invasive Species Advisory Committee proposed in the Bill.

When councils/committees are established – the requests for funding will follow.
We have observed that the current California Invasive Plant Council (Cal IPC) is an organization dedicated to eliminating plants which they deem undesirable, by the use of highly hazardous herbicides. We find this unacceptable.

Spraying of calla lilies here, in San Francisco, with a high hazard herbicide is but one example of these damaging practices. While calla lilies don’t endanger the health of the residents, there is plenty of evidence that the chemicals used to kill these lilies do. Just last year the Cal IPC added over 50 “potentially invasive” plants to the list of those where they claim herbicide spraying is justified.

Some of the plants designated as “undesirable” are “non-native” trees, many of which have been here for over 100 years and had long since became naturalized and habitats for insects, birds and animals both “native” and “non-native.”

Tree removals cause array of problems.

According to Scientific American: “from logging, agricultural production and other economic activities, deforestation adds more atmospheric CO2 than the sum total of cars and trucks on the world’s roads.” “Native” restorations/removal of “undesirable” trees are activities destroying forests, although they present themselves as environmental endeavors.
When trees are felled they release the carbon they are storing into the atmosphere, the future carbon sequestration is lost, so is the air pollution reduction. There are issues of potential landslides in hilly areas, increase in wind and noise, loss of wildlife habitat.

And, of course, the stumps of killed trees are treated with high hazard herbicides.

According to the Bill, the Invasive Species Council of California and the California Invasive Species Advisory Committee would be established “to help coordinate a comprehensive effort to exclude invasive species already established in the state…” We contend that the means of such “exclusions” are far more damaging and cause far more severe economic, ecological and human health impacts than the “invasive” species possibly can.

We urge the NO vote on AB 2470.

Thank you,

San Francisco Forest Alliance


We have been disturbed by the tendency in the established environmental movement to villainize “non-native” “invasive” species as a basis for declaring a “war” on them. It provides an opportunity to raise or deploy funding, to use a great deal of pesticides, and to “take action” by cutting down trees and tearing out habitat – even when it is environmentally destructive. We oppose the establishment of further institutions that will have a vested interest in these activities.

Two Myths of Nativism: Mutually Exclusive Relationships, and Eucalyptus Allelopathy

We re-publish with permission (and added emphasis) an article from  MillionTrees.me, a website that fights the unnecessary felling of trees in the Bay Area. The article, a report from someone who attended the February 2018 meeting of the California Native Plant Society (CNPS), is important for two reasons:
Read more of this post

Season’s Greetings!

With this holiday season rolling around again, we’re pausing to realize that the San Francisco Forest Alliance is six years old! Our first post – about pesticide use on Twin Peaks – was on Dec 19, 2011.

It’s been six years of advocating for our trees, our trails, our wildlife habitats. Six years of fighting against toxic herbicides used in our parks.  This year we’re gearing up to bring our message of inclusive environmentalism to a broader audience.

To all our supporters and readers – SEASON’S GREETINGS!
We hope you’ll continue to stand with us and spread the word.

 

 

Lessons From the Terrible North Bay Wildfires of 2017

This careful analysis of the terrible wildfires in the San Francisco Bay Area is republished with permission from MillionTrees, a website that fights to prevent unnecessary tree removal in the Bay Area.

 

Lessons learned from fires in the North Bay

Recent wildfires in the North Bay were devastating.  At least 42 people were killed by the fires and over 8,000 structures were destroyed, including homes and businesses.  We don’t want to portray that fire as anything other than a tragedy.  However, for those with a sincere interest in fire safety, there are many lessons to be learned from that fire.  If people will open their eyes and their minds to the reality of those fires, there are opportunities to reduce fire hazards revealed by those fires.

What burned?

Watching videos of the fires is the best way to answer the question, “What burned?”  Here are two videos of the fires that we found on the internet by doing a search for “videos of wildfires in Napa and Sonoma counties.”

If you weren’t watching the news during the fires, you might start by looking at these videos.  There are many more videos on the internet of those fires.

Here’s what we can see in these videos:

  • The fire front moved rapidly through native conifers and oaks as well as through grassland and chaparral. After watching hours of these videos, we did not see any eucalyptus trees on fire.
  • Many homes burned without igniting the trees and vegetation around them. If the photo was taken while the home was still burning, the vegetation is rarely engaged in the fires.  If the photo was taken after the home burned, much of the vegetation is burned as well.  In other words, the burning homes ignited the vegetation, not vice versa.
  • In videos of actively burning homes, the air is filled with burning embers. The source of those embers cannot be determined from the videos.

Nothing in these videos suggests that native vegetation is less flammable than non-native vegetation.  Nothing in these videos suggests that the vegetation is more flammable than the structures that burned. 

CalFire has identified the specific locations where four of the fires originated.  Two are in groves of oak trees and two are in grassland and chaparral.  Photos of those specific locations are available HERE.

What role did the weather play in the fire?

All sources of information about the fire reported that strong winds were the biggest factor in the rapid advance of the fire.  The wind was associated with very high temperatures and it came from the east.  This type of wind is called a Diablo Wind in Northern California.  In Southern California it is called Santa Ana Winds.  In the Mediterranean, it is called Mistral Winds.

In coastal Mediterranean climates such as California and the Mediterranean regions of France and Spain, the wind ordinarily comes off of the ocean.  Because the ocean is cooler than the land, the wind is usually a source of moisture and cooler temperatures.  During periods of high summer temperatures, the wind sometimes shifts direction and starts to blow off the hot interior, drying the vegetation and increasing temperatures.

Such winds were also the main cause of the wildfire in the Oakland/Berkeley hills in 1991Jan Null was the lead forecaster for the National Weather Service in the Bay Area in 1991.  He recently said of the 1991 fire:  “At the time a fire starts, the really relevant conditions are the wind speeds, the temperature and the humidity. Again, the humidity goes to the dryness of the fuel. The temperatures also go to the dryness of the fuels and the wind speeds go to what the spread of the fire is. If we’d had that same Oakland Hills fire without any wind, we wouldn’t be talking about it now.”

Most wildfires in California are caused by strong, dry, hot winds.  Everything burns in a wind-driven fire.  Both native and non-native vegetation burns in a wind-driven fire.  Homes in the path of a wind-driven fire are more likely to burn than the vegetation that surrounds the homes because the vegetation contains more moisture.

Why are wildfires becoming more frequent and more intense?

Wildfires are becoming more frequent and more intense all over the world because of climate change.  Temperatures are higher, drought is more frequent, strong winds are more frequent.

Wildfires in the west have become more severe because of increased temperatures and lower humidity at night.  When it doesn’t cool off at night, the trees don’t have an opportunity to regain the moisture they have lost during the high daytime temperatures.  In the past, firefighters could count on wildfires to die down at night.  Now they can’t count on colder nights to make the fires less severe. (2)  Since the fires in the North Bay started in the middle of the night and did the most damage that first night, this observation about warmer nights is particularly relevant to those fires.

Deforestation is the second greatest source of the greenhouse gases causing climate change Every healthy tree we destroy releases its stored carbon as it decomposes.  Every tree that dies of drought releases its carbon as it decomposes.  Every tree that burns in a wildfire releases its carbon as it burns.

What role did power lines play in the fire?

The investigation of the recent wildfires in the North Bay is not complete, but early indications suggest that power lines probably ignited some of the fires.  Some power poles fell over in the strong winds, causing the power lines to break and spark ignitions.  Some trees were blown into the power lines, causing them to break or spark.

California State law requires that trees be pruned at least 4 feet from the power lines.  Although PG&E says they are inspecting thousands of miles of power lines to identify potential interference with trees, these inspections are apparently not adequate.  After the fires started, PG&E claimed they had removed 236,000 “dead and dying” trees and “destroyed or pruned” 1.2 million healthy trees in 2016.  These destroyed trees contribute to climate change.

California State law also requires that power poles are capable of withstanding winds of a certain velocity.  However, power poles fell over during the recent fires when wind speeds were below that standard set by State law.

Apparently PG&E’s efforts to inspect and maintain power lines were inadequate and State laws intended to ensure the safety of power lines are not being enforced.

Did Sudden Oak Death contribute to the fire?

Sudden Oak Death (SOD) killed 5 million oak trees in California from 1994 to 2016, when that number was reported by a study.  The study also said that the SOD epidemic could not be stopped and would eventually kill all oaks in California.  More recent estimates are that 5 to 10 million oaks have been killed by SOD. (2)

SOD is caused by a pathogen that is spread by rain and wind.  We had a great deal of rain in 2016 and 2017, which has greatly increased the spread of SOD.  In the past, SOD has been mostly confined to wildlands.  Now it is found in many urban areas, including San Francisco and the East Bay.  In the most recent SOD survey done in spring 2017, new infections were found on the UC Berkeley campus, the UC arboretum, and the San Francisco Presidio. (2)

The scientist at UC Berkeley who conducts the annual survey of SOD infections reports that “A dramatic increase this year in the number of oaks, manzanita and native plants infected by the tree-killing disease known as sudden oak death likely helped spread the massive fires that raged through the North Bay…” (3)

Dead trees are more flammable than living trees because living trees contain more moisture.  In addition to more than 5 million dead oak trees in California, 102 million native conifer trees in the Sierra Nevada foothills were killed by drought, warming temperatures and native beetle infestations during the drought years. All of these trees are native to California.  This is another indication that native trees are not less flammable than living non-native trees.

The ranges of native plants and animals are changing because of climate change.  They must move to find the climate conditions to which they are adapted.  Native plant “restorations” that attempt to reintroduce plants where they existed 250 years ago, prior to the arrival of Europeans, do not take into consideration that the plants may no longer be adapted to those locations.  That’s why many “restorations” are not successful.

If you haven’t seen the Sutro Forest, you should do so soon. The plans are to destroy about 50% of the trees and most of the understory.

Native plant advocates have their heads in the sand about Sudden Oak Death.  The recently published Environmental Impact Report for San Francisco’s Sutro Forest announced UCSF’s intention to destroy about 50% of the non-native trees on Mount Sutro and replace some of them with native trees, including oaks and bays.  Bays are the vector of the pathogen causing SOD.  The EIR said NOTHING about Sudden Oak Death, nor did it acknowledge the existence of the disease in Golden Gate Park and the arboretum, less than a mile away from Mount Sutro.  What’s the point of destroying healthy trees and replacing them with trees that are likely to die in the near future?

Where to go from here?

We are not powerless against bad decisions of public utilities and the forces of nature.  There are things we can do to address these causes of wildfires in California:

  • We must address the causes of climate change. We must stop destroying healthy trees and we must plant more trees.  We must choose species of trees that have a future in the changed climate.  The trees must be adapted to current and anticipated climate conditions.  We must quit destroying trees simply because they are not native.  Non-native trees are not more flammable than native trees and many are better adapted to current climate conditions.
  • We must regulate our public utilities and demand that regulations be enforced. The Public Utilities Commission initiated an effort to improve the safety of power lines in 2007, after destructive wildfires. The utility companies have been actively dragging their feet to prevent new regulations because they would increase costs, despite the fact that they would improve safety.
  • Improved regulation of utilities should minimize the need to destroy healthy trees, by undergrounding power lines in the most high-risk areas, improving insulation of the wires, replacing wooden power poles with metal and/or concrete poles, installing sensors that identify breaks in the power lines, etc.

Demonizing non-native trees is preventing us from addressing the causes of climate change and the closely related issue of increasing frequency and intensity of wildfires.  Let’s open our eyes and our minds to the reality of wildfires in California and develop the policies that will reduce fire hazards.


(1) The Detwiler Fire is active at night, and a scientist says that’s relatively new,” Fresno Bee, July 22, 2017

(2) “Disease killing oaks spreads,” East Bay Times, October 24, 2017

(3) “Disease in trees pointed at in fires,” San Francisco Chronicle, October 20, 2017

National Park Service Trees Meet Chainsaws in Montara

The National Park Service is cutting down trees in Montara, south of San Francisco. San Francisco Forest Alliance opposes this action. We’re disappointed. In this era of global warming, every tree counts. Instead of destroying trees, they should be planting them. Instead, they appear to have succumbed to the same “native” vs “non-native” xenophobic approach to plants that we’re battling in the Bay Area.

This article, with the accompanying pictures is from one of our supporters, and is used with permission.

NATIONAL PARK SERVICE CHAINSAWS KILLING PENINSULA TREE

by D. Emanuel

Here we go again. This time it’s the National Park Service destroying trees in the Bay Area. They just cut down perfectly healthy Monterey cypress and pines – some 100 years old — at Rancho Corral de Tierra, which is located at the tip of Half Moon Bay. If you’ve ever hiked or ridden a horse or bike at Rancho you know there are few trees that provide shady resting spots along popular trails.

These trail-side trees are isolated and one in particular, on the Farallone trail, has been an iconic stop, where hikers take a break to enjoy scenery, grab a drink of water, and shoot the breeze. It’s been a favorite among residents of Montara, many of whom walk outdoors just steps from home as part of their daily routine. No more. Park Service chainsaw crews leveled the tree last week.

By the end of next week the Park Service will be on track to kill 40 trees because they categorize them as non-native. It doesn’t seem to matter that their birthplace is only 100 miles down the road in Monterey. Apparently that’s not local enough.

COASTSIDE RESIDENTS BLINDSIDED

The Park Service gave no warning and did not engage the community for input at Rancho. They are so strident in carrying out a preferred landscape ideology that a handful of favorite trees could not remain.

Rancho is the newest land added to the 80,000-acre Golden Gate National Recreation Area. The Park Service acquired it in 2011. You may remember that just one month after taking over as land manager a Park Service ranger used her taser gun to shoot a 50-year-old man in the back after he gave a false name. The ranger had stopped him for walking one of his two small terriers off-leash. He won a $50,000 judgment against the Park Service for unreasonable use of force.

Now the Park Service is now using unreasonable force against trees under the guise of biodiversity. They claim it will save a rare flower, Hickman’s potentilla, against an invading force  even though the trees have remained far apart for years, showing no sign of taking over the landscape.

The fact that the flower has peacefully co-existed with the trees for decades doesn’t matter to the Park Service. The project is part of a multi-million dollar grasslands restoration and replanting program bankrolled by the Golden Gate National Parks Conservancy.

The Park Service did not conduct an environmental assessment to justify the dramatic changes being made to the landscape and it’s refusing to disclose how much glyphosate is being sprayed.  Glyphosate, better known by the Monsanto trade name Roundup, has been declared a probable human carcinogen. California, which in July declared glyphosate to be a carcinogen, is considering requiring cancer warnings on Roundup brand labels.

The community is shocked and angry. You should be too. California lost 100 million trees due to the recent four-year drought. We can’t afford to be killing trees. Yet that’s exactly what the Park Service is doing at Rancho Corral de Tierra.

UPDATE:

Here’s a statement from GGNRA received today:

“NPS is pausing tree removal work at Rancho and is planning to offer an additional public hike in the coming weeks to discuss our planning process and the overall recovery plan for the Rancho grasslands and Hickman’s potentilla. We plan to send out an announcement to our Rancho mailing list once this date is set.”

This is a pause – not a promise to stop the cutting. We will stay in touch with you all as we move through this process to keep our voices heard.

Please enjoy the moment – your voices and help from Congresswoman Jackie Speier’s office were very important to get this temporary pause – thank you!

SF Forest Alliance: Problems in the Sutro Forest DEIR – Part II

On September 22, 2017,  the Aqua Terra Aeris Law Group, on behalf of its client, San Francisco Forest Alliance, submitted the following comments and questions to the University of California, San Francisco (“UCSF”) regarding the Draft Environmental Impact Report (“DEIR”) for the UCSF Mount Sutro Open Space Reserve Vegetation Management Plan (“Plan”).

[We are publishing it in two parts, owing to its length. This is Part II.
For Part I, Click HERE: SF Forest Alliance: Problems in the Sutro Forest DEIR – Part I
The pictures in these articles are illustrative only, and were not submitted to UCSF. Most legal references and citations in the original have been removed for easier reading.]

D. The DEIR Fails to Adequately Assess or Mitigate Erosion Impacts.

The DEIR fails to include meaningful analysis or mitigation measures for erosion controls. Again, to some extent, this deficiency flows from the fact that neither existing conditions nor the exact scope of the project is defined. Nevertheless, numerous members of the public have submitted comments based on scientific review and personal experience highlighting that widespread tree removal in the forest will expose soils and degrade soil integrity in an area with steep slopes and high moisture accumulation. Many of these effects may not be immediately evident—for example, only years after a tree is removed may the root structure left behind totally rot—yet the DEIR describes and attempts to mitigate only impacts short-term impact such as access road construction and landing area. (DEIR 2-22 to 2-24.) Thus, the DEIR fails to completely analyze the project’s significant adverse impacts, and fails to support its conclusions with substantial evidence.

Blue tarp following a landslide in Forest Knolls San Francisco

E. The DEIR Fails to Adequately Assess Greenhouse Gas Emissions.

The DEIR fails to disclose fundamental information for an accurate greenhouse gas (“GHG”) emissions analysis. The DEIR acknowledges that tree removal will cause GHG emissions, but fails to meaningfully analyze the numbers and types of trees to be removed and replaced. For example, the summary on page 3-27 does not sum up how many trees will actually be removed. Table 3.5-2, column 6 provides the net reduction or increase in trees, but this does not indicate how many living trees will be removed. That is because the numbers presented are net removals, i.e., living trees removed, plus dead trees removed, minus new trees planted.

The DEIR’s treatment of old trees as equivalent to new saplings is also incorrect. Based on best current scientific information, large, old trees do not act simply as aging carbon reservoirs but rather continuously fix large amounts of carbon compared to smaller trees. (N.L. Stephenson et al., Rate of Tree Carbon Accumulation Increases Continuously with Tree Size (2014) 507 Nature 90.) This study determined that the oldest trees gained the most mass each year and subsequently, accumulating more carbon, capitalizing on their additional leaves. (Id. at 91-92.) The DEIR fails to account for this information when it claims that “[y]oung, healthy forests absorb carbon more rapidly than older, dense forests (Wayburn 2010).” (DEIR at 4.6-18.)

It is also false to assume that carbon sequestration in a forest ceases at a certain point. The DEIR presumes “the Reserve’s mature eucalyptus are well past peak growth, and are no longer sequestering much if any additional carbon.” (DEIR at 4.6-19.) Per the Stephenson paper, supra, and Peter Ehrlich’s updated forest assessment of eucalyptus trees in San Francisco post-drought described below, this is incorrect, insufficient, and inadequate. Additionally, these assumptions result in an inadequate baseline. Given the end of the drought, a significant number of trees deeming “dying” by the DEIR have likely recovered their canopies and are sequestering more carbon than in April 2016. Conversely and without evidence, the DEIR assumes 100% survival rates for new saplings planted, incorrectly ignoring the mortality rate for these new trees, especially given the lack of irrigation. When removing mature trees, the U.S. Forest Service recommends a 3:1 replanting ratio to account for the loss of carbon sequestration and expected sapling death.

The DEIR also lacks calculations regarding the projected biomass and CO2 of the replacement trees in future years. To fully understand the impacts of the Plan, information about carbon sequestration at incremental years, such as 2020, 2030 and 2050, would more fully disclose the Plan’s impacts. Executive Order S-3-05 and Executive Order B-30-15, have targets that need to be reached by 2020, 2030 and 2050, but without presenting GHG impacts at these critical years, the public cannot know whether the Plan will conflict with applicable plans, policies, or regulations as required by CEQA. (Guidelines, § 15064.4, subd. (b)(3) [“A lead agency should consider . . . [t]he extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions.”].)

The DEIR is lacking information on other critical GHG measurements. The DEIR does not provide estimates for changes in soil carbon, though the changes to the surface throughout the Reserve will disturb the soil. (DEIR at 4.6-15.) This is especially true because the plan for understory removal is to dig out the understory plants by the roots. Additionally, the DEIR fails to provide estimates have for carbon contained in the woody shrubs and understory that will be extensively removed and destroyed. (Id.)

Finally, the DEIR fails to account for the Plan’s cumulative impacts on climate change, stating that “a single project is very unlikely to measurably contribute to a noticeable incremental change in the global average temperature, or to the global, local, or microclimate.” (DEIR at 4.7-16.) When making this determination, however, an EIR may not conclude that a cumulative impact is insignificant solely because the project’s contribution to an unacceptable existing environmental condition is relatively small.  “[T]he impact of greenhouse gas emissions on climate change is precisely the kind of cumulative impacts analysis” that agencies must conduct. (Center for Biological Diversity v. Nat’l Highway Traffic Safety Admin (2008) .) One project may not appear to have a significant effect on climate change, but the combined impacts of many sources can damage California’s climate as a whole.

Therefore, CEQA requires that an agency consider both direct and indirect impacts of a project and fully disclose those impacts to adequately inform the public and decisionmakers. (Guidelines, § 15064.) The DEIR, because “[c]arbon sequestration in the forest would exceed GHG emissions generated from equipment and loss of carbon stock/uptake from tree removal,” concludes the Plan’s impacts will be less than cumulatively considerable. (DEIR at 4.7-17.) This failure to consider the Plan’s impacts in conjunction with other plans and projects flouts CEQA’s mandate.

Ultimately, the DEIR’s Greenhouse Gas analysis is deficient. UCSF’s conclusion that the Plan will not have a significant impact on the environment is unsupported without a full disclosure and analysis of the Plan’s greenhouse gas impacts. CEQA “requires full environmental disclosure.” (Communities for a Better Environment, supra, 184 Cal.App.4th at 88; see also Guidelines, § 15121, subd. (a).) Although “technical perfection” is not required, an EIR must be “adequa[te], complete[], and a good-faith effort at full disclosure.” Because the DEIR fails to include and consider recent scientific information, fully describe the Plan, analyze compliance with relevant regulations and policies, account for significant sources of carbon, and analyze cumulative impacts, it fails as an informational document and does not present an accurate picture of the Plan’s impacts to the public or decisionmakers. UCSF must correct these areas and recirculate the EIR.

F. The DEIR Fails to Adequately Assess and Mitigate Wind and Local Climate Effects.
Commenters have pointed out that Sutro Forest was originally created in part to help calm winds from the Pacific Ocean into the City. The effect has considerable influence on the microclimate of the immediate vicinity, as well as nearby areas, such as Noe Valley, Dolores Heights, Castro, Bernal Heights, or the Mission, allowing more fog and wind to pass through the forest into nearby areas. Commenters have noted that Sutro Forest has the highest moisture content of any location in the City, and massive vegetation removal may logically have the effect of changing this moisture collecting condition and changing weather patterns in the City. San Francisco is well-known for its micro-climates, and this project effect cannot be simply ignored. Without collection and evaluation of micro-climate data in the City, the DEIR fails to assess this project effect.  A revised and recirculated DEIR should include detailed observation about the microclimate and forest conditions.

G. The DEIR Fails to Adequately Assess and Mitigate Impacts to Biological Resources.

First, the DEIR fails to provide a meaningful assessment of impacts to avian species and their habitat. Principally, the removal of thousands of standing dying trees deprives protected bird species of next, perch, and boring spaces. (See: Eucalyptus tree hosts a flicker family)

A loss of understory also impairs habitat and foraging opportunity. (See: Mount Sutro Forest Ecosystem and Wildlife Habitat)  These project effects must be analyzed.

Second, the DEIR fails to adequately mitigate impacts to Monarch Butterflies. BIO-PH-1 is inadequate because it enables UCSF still to cut down the trees on which the monarchs were found after the butterflies have left. This is destroying essential monarch butterfly habitat and the exact trees that the butterflies are likely to try to return to the following year. Aggregation on trees themselves are hard to spot. Monarch butterflies are often seen flying around San Francisco’s eucalyptus forests, but where are their home trees? How will the biologist determine whether the aggregation has dispersed or not, and what is the time frame? This is unclear in the DEIR. A 200-foot buffer is inadequate for species protection given the significant disturbance that the Plan’s deforestation will create around the aggregation trees including heavy equipment, the construction of landing areas, and clear cuts of 1 acre or more.

The DEIR concedes that “Implementation of forest treatments including eucalyptus removal could cause a significant impact on monarch butterfly by removing trees that monarch butterfly may use as roosts during winter months” and “Impacts would remain significant.” (DEIR 4.3-22) Given recent studies’ finding the species to be severely imperiled throughout the West, the lead agency may be unable to justify a statement of overriding considerations to approve this project, and the No Project Alternative should be selected, and/or the project denied.

Commenters have noted that Eucalyptus oils act as natural deterrents to pests such as mosquitos and fleas, while the area is known as a frequent destination for dog walkers. The DEIR should assess project effects to reduce this natural defense. In addition, because the Eucalyptus blooms in winter, it is an off-season food source for bees, which have also suffered alarming population declines. The DEIR should investigate and analyze this effect.
Again, the DEIR fails to completely analyze the project’s significant adverse impacts, and fails to support its conclusions with substantial evidence.

E. Conclusion

For each of the foregoing reasons, we urge that the project be denied, that the No Project Alternative be adopted, or that the DEIR be substantially revised and recirculated for public and agency review and comment.