Sutro Forest Herbicide Projections: Bad News for San Francisco’s Natural Areas?

pesticide use number n vol 2008 to 2012Our regular readers will know that we’ve been following the Natural Areas Program’s (NAP) increasing use of pesticides with some dismay. When we got the 2012 data, it was clear that pesticide use had increased by every measure. That story is HERE: Natural Areas Program Uses Even More Pesticides.  Imagine our concern, then, when the Sutro Forest Draft Environmental Impact Report outlined the amounts of pesticides they contemplate using as part of their destructive plan for the forest on Mount Sutro Open Space Reserve. It’s between 5 and 15 times the amount that NAP is using on all its properties. (Sutro Forest has been essentially pesticide-free since 2008.)

NAP’s own DEIR on the Significant Natural Resource Areas Management Plan – SNRAMP or Sin-Ramp – doesn’t quantify the amounts of pesticides it would need to implement its plan. But the Sutro Forest numbers suggest that we’re looking at multiples of their existing levels of use.

Like many, we’re very concerned about this pesticide use. It’s bad for human beings, for pets, for the environment and for wildlife. We recently came upon this excellent article by David Stang. It’s reprinted here with permission. Of the pesticides reviewed, NAP is using Milestone VM, Roundup (or Aquamaster, with the same active ingredient – glyphosate), and Imazapyr.  (Note: All the illustrations are ours.)

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THE LAST ROUNDUP

By David Stang

pacific chorus frog - public domain image (NPS)Recently an agricultural services firm was retained to spray the herbicide Milestone VM on nearby pastures to kill clover and other broadleaf plants. After spraying, rains washed some of the herbicide downhill from the pastures into the ponds below. Before the spraying, the ponds were full of tadpoles. A few days after spraying, there were no tadpoles in the ponds examined.

Because none of the tadpoles had legs before the spraying, they could not have developed into adult frogs and walked off. Nor could any predator have managed to get every single one of them. And a “control group” — waterways not affected by pasture runoff — still had the tadpoles they had before this spraying. Adult frogs may have been killed as well – the evenings at the ponds after spraying were much quieter than just prior to the spraying.

We could suspect that pasture runoff of Milestone VM into our ponds is the culprit. A literature search confirms this hypothesis (see below).

Studies have shown that herbicides and pesticides may have both direct and indirect effects on tadpoles:

  • Very, very low concentrations of pesticides and herbicides have been found to be a major factor in high levels of deformities in frogs and tadpoles1, and studies have shown that herbicides such as Roundup cause DNA damage in tadpoles.2
  • Very low concentrations may kill tadpoles and frogs in just one day.3
  • Those that are not killed outright by herbicides may die of delayed effects. Malathion, for instance, in very low doses destroys zooplankton that eat algae that floats in the water. With the zooplankton gone, the algae grew rapidly and prevented sunlight from reaching the algae at the bottom of the pond, which tadpoles eat. Some tadpoles then starve to death.4
  • Tadpoles that do not starve will mature slowly, or grow so slowly that they may not reach maturity.5
  • If tadpoles reach maturity, and become adult frogs, herbicides may weaken their immune systems, leaving them susceptible to chytrid fungus infections.6

The known dangers of herbicides for frogs and toads is acknowledged by the National Park Service which, for Yosemite National Park, required that “Herbicides will not be applied within 750 meters (2,500 feet) of known breeding habitat for the Yosemite toad.”7

Where pasture runoff flows into streams, ponds, or even ditches, the use of herbicide or pesticide in our pastures should be suspended until the dangers of any proposed substance can be carefully evaluated.

Herbicides that are known to be toxic to wildlife include Milestone VM, Roundup, Powerline and Arsenal, and Tordon K. It seems likely that all herbicides are toxic to wildlife.

2013-03-14 (2)Milestone VM

Milestone VM contains the active ingredient aminopyralid.

Aminopyralid dissolves very easily and is persistent in water. It has high leachability and mobility. It is toxic to algae, oysters, aquatic plants8, fish, honeybees and earthworms9.Aminopyralid is also on PAN International’s List of Highly Hazardous Pesticides10.

Recently aminopyralid was at the center of public and media attention in the United Kingdom. Gardeners discovered that using manure from animals that grazed on or were fed hay from aminopyralid-sprayed roadsides caused their garden crops to fail or develop abnormally. In fact, the University of Minnesota Extension Service describes this problem in their fact sheet, “Use Caution When Harvesting and Feeding Ditch Hay.”11

Aminopyralid is of concern to vegetable growers as it can enter the food chain via manure which contains long lasting residues of the herbicide. It affects potatoes, tomatoes and beans, causing deformed plants, and poor or non-existent yields. Problems with manure contaminated with Aminopyralid residue surfaced in the UK in June and July 2008, and at the end of July 2008 Dow AgroSciences (the manufacturer of Milestone) implemented an immediate suspension of UK sales and use of herbicides containing Aminopyralid. A company statement explained: “Consistent with its long-standing commitments to product stewardship, and in cooperation with United Kingdom regulators, Dow AgroSciences has asked the Pesticide Safety Directorate (PSD) for a temporary suspension of sales and use of herbicides containing aminopyralid. The suspension shall remain in place until assurances can be given that the product and subsequent treated forage and resultant animal wastes will be handled correctly.”12

If it is unsafe to eat vegetables raised with manure from pastures treated with Milestone, how safe can it be to eat plants that themselves have been treated with Milestone? Are the horses in treated pastures safe?

Of concern to all is the 2005 claim by the EPA that “There are no acute or chronic risks to non-target endangered or non-endangered fish, birds, wild mammals, terrestrial and aquatic invertebrates, algae or aquatic plants”13, despite the fact that the EPA report cites studies such as “Acute Toxicity to Larval Amphibians Using the Northern Leopard Frog, Rana pipiens, as a Biological Model.”

Even if Milestone/aminopyralid were safe for tadpoles, it would only be when applied at recommended doses to non-sloping land. The recommended dose is just 7 fluid ounces per acre, according to the EPA.14

Roundup

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Other commonly used herbicides also put wildlife at risk. Roundup, for instance, kills birds, fish, tadpoles, bees, worms – at least 76 different species.

Roundup contains glyphosate as its active ingredient. Glyphosate dissolves readily and is very persistent in water. It is toxic to birds, fish, honeybees and earthworms15and is listed by PAN International as a highly hazardous pesticide16. Its maker, Monsanto, was convicted of false advertising in 2007 for its claim that Roundup was “practically non-toxic” to mammals, birds, and fish.17 Some of the scientific evidence for the safety of Roundup comes from studies with falsified results.18

The U.S. Environmental Protection Agency (EPA) has identified 76 species that may be endangered by glyphosate use19.An important study has shown that glyphosate kills tadpoles20. A University of Pittsburgh biologist has found that the herbicide caused an 86-percent decline in the total population of tadpoles.21A recent study found that even at concentrations one-third of the maximum concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.22

Out of concern for these issues as well as human health, European Union member states are warned that they “must pay particular attention to the protection of the groundwater in vulnerable areas, in particular with respect to non-crop uses,” when using glyphosate23.According to EPA, short-term exposure to elevated levels of glyphosate may cause lung congestion and increased breathing rates and, in long-term exposure, kidney damage, reproductive effects24. Glyphosate has also been associated with Parkinson’s disease.25Increased adverse neurologic and neurobehavioral effects have been found in children of applicators of glyphosate26.Female partners of workers who apply glyphosate are at higher risk of spontaneous abortion27.Some glyphosate-based formulations and metabolic products have been found to cause the death of human embryonic, placental, and umbilical cells in vitro even at low concentrations. The effects are not proportional to glyphosate concentrations but dependent on the nature of the adjuvants used in the formulation.28

Powerline and Arsenal

glen canyon imazapyr under treesPowerline and Arsenal contain the active ingredient imazapyr, which has been listed for withdrawal from the market in the European Union.29It is highly soluble and moderately persistent in water. It is also toxic to fish, honey bees and earthworms30. Imazapyr’s potential to leach to groundwater is high and surface runoff potential is high31.One field study found that between 40 and 70 percent of applied imazapyr leached down to the lowest depth tested32. If imazapyr leaches down below 18 inches (where microbial activity is limited) the chemical can be expected to persist for more than a year33.EPA cautions that imazapyr-based herbicides can place terrestrial and aquatic plant species in “jeopardy.”34

Tordon K

Tordon K has the active ingredient picloram. Picloram is a persistent herbicide that is highly leachable, very soluble in water and does not degrade readily in water. It is toxic to birds, fish, honeybees and earthworms. It has also been identified as an endocrine disruptor3536and is on PAN International’s List of Highly Hazardous Pesticides37.EPA’s evaluation of picloram states, “eventual contamination of groundwater is virtually certain in areas where residues persist in the overlying soil. Once in groundwater, the chemical is unlikely to degrade even over a period of several years.”38

Anyone who would advocate against herbicides will face the might of organized agriculture, the lawn care business, and even the EPA. A paper on the Environmental Safety of Forestry Herbicides39, for instance, argues that the herbicides named in the present article – imazypyr, glyphosate, and picloram, as well as many others – are “less toxic than caffeine”, “less toxic than aspirin” and “are safe for animals because the biochemical basis for toxicity does not exist.” The article goes on to claim “herbicides positively affect water quality by reducing sedimentation rates.”

I’d like to think that we could send herbicides to the last roundup. But it seems more likely that herbicides will continue to send wildlife to that roundup.

End Notes

1 Fellers G, Sparling D; Wafting Pesticides taint far-flung frogs, Environmental Toxicology and Chemistry, 2001; Science News, Dec 16,2000, Vol 158, p391; Science News, 9-5-98,p150.

3 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

4 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

10 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_090116.pdf

11 University of Minnosota Extension Service, “Use Caution When Harvesting and Feeding Ditch Hay.” http://www.extension.umn.edu/distribution/livestocksystems/components/M1197.pdf

15 Pesticide Properties DataBase http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

16 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_1101.pdf

18 On two occasions the United States Environmental Protection Agency has caught scientists deliberately falsifying test results at research laboratories hired by Monsanto to study glyphosate. [(US EPA Communications and Public Affairs 1991 “Note to correspondents” Washington DC Mar 1)] [(US EPA Communications and Public Affairs 1991 Press Advisory. “EPA lists crops associated with pesticides for which residue and environmental fate studies were allegedly manipulated”. Washington DC Mar 29)] [(U.S. Congress. House of Representatives. Com. on Gov. Oper. 1984. “Problems plague the EPA pesticide registration activities”. House Report 98-1147)] In the first incident involving Industrial Biotest Laboratories, an EPA reviewer stated after finding “routine falsification of data” that it was “hard to believe the scientific integrity of the studies when they said they took specimens of the uterus from male rabbits”. [(U.S. EPA 1978 Data validation. Memo from K Locke, Toxicology Branch, to R Taylor, Registration Branch. Washington DC Aug 9)] [(U.S. EPA Office of pesticides and Toxic Substances 1983, “Summary of the IBT review program”. Washington D.C. July)] [Schneider, K. 1983. Faking it: The case against Industrial Bio-Test Laboratories. The Amicus Journal (Spring):14-26. Reproduced at [http://planetwaves.net/contents/faking_it.html Planetwaves] ] In the second incident of falsifying test results in 1991, the owner of the lab (Craven Labs), and three employees were indicted on 20 felony counts, the owner was sentenced to 5 years in prison and fined 50,000 dollars, the lab was fined 15.5 million dollars and ordered to pay 3.7 million in restitution. [(US Dept. of Justice. United States Attorney. Western District of Texas 1992. “Texas laboratory, its president, 3 employees indicted on 20 felony counts in connection with pesticide testing”. Austin TX Sept 29) ] [(US EPA Communications, Education, And Public Affairs 1994 Press Advisory. “Craven Laboratories, owner, and 14 employees sentenced for falsifying pesticide tests”. Washington DC Mar 4)] [http://www.mindfully.org/Pesticide/Roundup-Glyphosate-Factsheet-Cox.htm Glyphosate Factsheet (part 1 of 2) Caroline Cox / Journal of Pesticide Reform v.108, n.3 Fall98 rev.Oct00 ] ] Craven laboratories performed studies for 262 pesticide companies including Monsanto. — http://dic.academic.ru/dic.nsf/enwiki/56554

19 U.S. Department of Agriculture, Forest Service, 1997. Herbicide Information Profile: Glyphosate

20 Hileman, B. (2005) Common herbicide kills tadpoles. Chemical & Engineering News. Washington 83(15):11

22 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Findshttp://www.sciencedaily.com/releases/2005/08/050804053212.htm

23 European Commission, Health & Consumer Protection Directorate-General. Directorate E – Food Safety: plant health, animal health and welfare, international questions. E1 – Plant health. Glyphosate. 6511/VI/99-final. 21 January 2002.

25 Barbosa et al., 2001. Parkinsonism after glycine-derivative exposure. Mov. Disorder. 16: 565-568.

26 Garry et al., 2002. Birth defects, season of conception and sex of children born to pesticide applicators living in the Red River Valley of Minnesota, USA. Environ. Health Perspect. 110: 441-449.

27 Arbuckle et al., 2001. An exploratory analysis of the effect of pesticide exposure on spontaneous abortion in Ontario farm population. Environ. Health Persp. 109: 851-857.

28 Benachour Nora; Gilles- Eric Séralini (December 23, 2008). “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells”. Chemical Research in Toxicology 22: 97. doi:10.1021/tx800218n. http://pubs.acs.org/doi/abs/10.1021/tx800218n%5D.

29 “Pesticides coming off EU market. Pesticide News No. 60, June 2003, pp. 8-10.

31 Washington State Department of Transportation. Imazapyr – Roadside Vegetation Management. Herbicide Fact Sheet. February 2006.

32 Vizantinopoulos, S. and P. Lolos. 1994. Persistence and leaching of the herbicide imazapyr in soil. Bull. Environ. Cont. Toxicol. 52:404-410.

33 “Ecological Risk Assessment of the Proposed Use of the Herbicide Imazapyr to Control Invasive Cordgrass (Spartina spp.) in Estuarine Habitat ofWashington State.” Department of Agriculture, Olympia, WA 98504. Prepared by ENTRIX Inc., Olympia, Washington. Project No. 3000901, October 30, 2003.

34 USEPA. Office of Pesticide Programs. 1987. EEB Review of 241-EEO. Washington, DC (April 21 & June 1)

35 Endocrine disruptors interfere with the endocrine glands that produce hormones that guide the development, growth and reproduction in people and animals. Disruption of hormones, which guide growth, development, intelligence, and reproduction, can result in irreversible harm, which is passed on to future generations.

36 Pesticide Properties Database http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

37 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/gbr.htm

38 U.S. EPA. Prevention, Pesticides, and Toxic Substances. 1995. Reregistration eligibility decision (RED): Picloram. Washington, D.C., Aug.

39McNabb, Ken. Environmental Safety of Forestry Herbicides http://www.aces.edu/pubs/docs/A/ANR-0846/

SF’s Natural Areas Program Uses Even More Pesticides

The 2012 final data are in, and it’s official: In 2012, the Natural Areas Program (NAP) used more pesticides than in any year from 2008 (the first year for which we have data provided by the City). This is true by any measure, as the graphs below indicate. [Note: Graph edited to indicate units]

[Edited to Add: NAP also used more Tier I pesticide – the most toxic – than the rest of SF RPD areas together. HERE]

pesticide use number n vol 2008 to 2012

Depending on the measure you choose, usage has increased anywhere from 12% to 40% from 2011. It’s between 3 and 4 times the usage in 2008.

THE FEARSOME FOUR AGAIN

What pesticides have they been using?

The same as before: Tier II and Tier I pesticides, defined as more hazardous and most hazardous. (For a detailed discussion of these chemicals, click HERE:  Natural Areas Program’s Pesticides: Toxic and Toxic-er.

  • Aquamaster/ Roundup (Glyphosate). (Tier II)  This is one of the world’s most widely used herbicides, but in vitro research has linked these chemicals to changes to human cells, some of which are of the kind that could cause birth-defects. The EPA is studying whether it is an endocrine disruptor. The fact that it’s widely used gives us little comfort; a different widely used herbicide has just been declared unacceptably toxic to bees.
  • Garlon (Triclopyr). (Tier I) To NAP’s credit, they have reduced the use of this extremely toxic herbicide since the peak in 2010. It’s a Tier I pesticide, and associated with numerous diseases in humans, and potential kidney impacts on dogs.
  • Polaris (Imazapyr). This Tier II herbicide is a problem because it spreads (it doesn’t stay where it’s applied) and it persists (it doesn’t break down easily). It’s a relatively new herbicide, and we don’t know quite what it does – though its breakdown product  is neuro-toxic. It’s banned in Europe, and neighbors are fighting against its use in privately owned forests in Northern California.
  • Milestone (Amino-pyralid). This Tier I toxic chemical sticks around even more persistently than imazapyr. It was banned for a time in the UK because if animals eat and excrete it, the excreta are still poisonous – as is the manure made from it. It’s banned in New York state because they aren’t sure it won’t poison the water. NAP’s used it in Lake Merced, Pine Lake, Glen Canyon, and Mount Davidson, all of which are areas where water contamination is possible. [Edited to Add: In 2013, Milestone was reclassified as a Tier II chemical.]

BAD FOR PEOPLE, BUTTERFLIES AND FROGS

Of course these chemicals are not good for people, and one would think that in a city that is so conscious of organic and green produce and products, wild lands would be one area that we’d try to keep organic. Not so. We even found evidence of blackberry bushes being sprayed – during the fruiting season when children and adults, birds and animals feast on the bonanza of berries.

Recent research indicates that both triclopyr and imazapyr are potentially toxic to butterflies – but NAP continues to use both Garlon and Polaris on Twin Peaks, where NAP are also struggling to re-introduce the endangered Mission Blue butterfly. Glyphosate is known to be dangerous to amphibians; but NAP uses Aquamaster around Lake Merced, Pine Lake, and in Glen Canyon – all near water-courses.

Finally, we have another problem with this use: it may be glorifying chemical solutions. A few months ago, a “volunteer” in Glen Canyon was found applying an unapproved pesticide to an area near a trail, without posting any notices or keeping any record of amounts or conditions. He believed he was doing a good thing for the environment. We have heard since of many other instances of random herbicide application in Natural Areas.

PLEASE STOP TIER I AND TIER II PESTICIDES IN NATURAL AREAS

Furthermore, the list of plants on which it’s used also keeps expanding. It’s currently around 30, up from under 2 dozen a year ago. Some of the plants being sprayed aren’t on the list of the California Invasive Plants Council or USDA noxious plants lists.

We ask SF Recreation and Parks Dept  to stop using Tier I and Tier II pesticides in the Natural Areas. An escalating use of herbicides is bad for the environment and the people, pets and wildlife using these parks;  sends a damaging message about priorities; and indicates a lack of success.

Blackberry and Pesticides

It’s blackberry season!

All over the city, people are picking the delicious berries off the Himalayan Blackberry bushes. At Twin Peaks, we saw someone intently gathering fruit in a small bowl from bushes below Twin Peaks Boulevard. In Glen Canyon yesterday, children were having a great old time snacking on blackberries along the trails.  The Bernalwood blog announced that Blackberry Season Underway in Bernal Heights. (It has some luscious photographs.) Even the Presidio’s Facebook page had a pictures of a berry bush and said, “It’s blackberry season. Did you know that park visitors are allowed to harvest very small quantities of the five-leaved Himalayan blackberry fruits?”

And we found this delightful video of four generations of San Franciscans making blackberry jam with blackberries picked right here in San Francisco. It’s  the little girl’s first year picking blackberries.

[CLICK on the jam-jar graphic to go to Making Jam with Grandma Kathy.]

It’s not just children who eat blackberries off the bushes. Birds and other wildlife do it too. [CLICK HERE for a link to an article with a great picture of a bird on a blackberry bush.]

So we were dismayed when people reported that pesticides are being used on Mt Davidson (again!) and this time, one of the targets is blackberry – right during the fruiting season. The pesticides being used are Aquamaster (glyphosate) and Polaris (imazapyr). [CLICK HERE for information on these herbicides.]

The notice says “The manufacturer’s notice says it is safe to enter area when the spray has dried. Staff will stay on site until spray has dried.”

We’re not sure that leaves the berries safe to eat.

And as for the area being safe once the spray has dried… we’re not sure about that either.

“Is it even possible for the spray to dry on Mt Davidson?” someone asked. Mt D lies within the fog belt, and it doesn’t dry out in the summer. “It is very, very wet in the green zone of Mt. D right now because of the fog. The paths are very muddy and the water is streaming down the road.” The photograph seems to prove the point. It was sopping wet.

How wet is Mt Davidson in summer?

Like this. This is all water from the cloud forest effect, the moisture precipitated from the fog.

The Natural Areas Program and Pesticides: Volumes and Numbers

We talked about pesticide use in the Natural Areas a number of times, and particular of the increasing volumes of the “Fearsome Four” pesticides they use most:

  • Glyphosate (Roundup or Aquamaster);
  • Triclopyr (Garlon or Garlon 4 Ultra);
  • Imazapyr (Polaris or Habitat); and
  • Amino-pyralid (Milestone).

[Read more about the effects of these herbicides HERE: SaveSutro’s article Toxic and Toxic-er.]

We got San Francisco’s Natural Areas Program pesticide use records under the Sunshine Act, and used them to create a graph of the number of applications by year. We’ve shown this graph at some of our presentations.

Recently someone spoke to us about the graph. “I asked NAP about it, and they said that possibly the number of applications has gone up, but the amount of pesticide use has gone down because they use less in each application.”

Possibly.  And possibly not.

VOLUMES ROSE MORE

What we found when we looked was that volumes have increased even more. (This is based again on the data provided us under the Sunshine Act.)

  • Between 2010 and 2011 the number of applications went up 21%. The volume of pesticide (in fluid ounces) used went up by 25%.
  • Between 2009 and 2010, the number of applications went up 184%. The volume of pesticide used went up by 365%.

So here’s that graph:

(Milestone doesn’t show up here because until now, the volume of applications has been small. Possibly, given its persistence, we should count it cumulatively?)

[Click HERE for more about ” Milestone” – aminopyralid.]

Edited to Add: For those interested in details of NAP’s pesticide use, calculated four different ways (number of applications; volume; active ingredient; and “acid equivalent”) here’s an article with details:

Click here for SaveSutro’s article: Measuring Pesticide Use by the Natural Areas Program

This graph that summarizes it by comparing pesticide use on various measures to 2008 levels. Pesticide use went down in 2009, then increased sharply in 2010 by all measures. In 2011, it rose in volume terms and number of applications, and declined very slightly when measured by active ingredient or acid equivalent.

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[Edited to replace with the more precise and detailed calculation, above.]

Edited to Add (for those with a technical bent): SF RPD used various formulations of glyphosate over the years. Technically, to compare them you need to calculate “Acid Equivalents” of the various formulations. We did this exercise,  converted them to Aquamaster equivalents, and adjusted the numbers. It made no significant difference. Between 2010 and 2011 the number of applications went up 21%. The adjusted volume of pesticide used went up 52%. Between 2009 and 2010, the number of applications went up 184%. The adjusted volume of pesticide used went up 264%.


Pesticides ‘Throughout the Park’

Recently, one of our readers sent us this picture of a pesticide notice from McLaren Park. It was breathtaking in its breadth, also rather confusing.

  • They were applying Aquamaster (this is glyphosate, the same chemical used in Roundup) for three different plants.
  • They had an initial window of 8 days, then added another 5-day window.
  • They were applying it “throughout the park.”
  • It would be safe to re-enter, it noted, “When Dry – at least a few hours after spray.”
  • And then, they did some spraying, there was a postponement of part of the spraying, and they did some more spraying on a different date.

A PARK-USER’S VIEWPOINT

We appreciate the efforts SF RPD is making to properly notify park-users… but look at this notice from a park-goer’s point of view. Then the following questions arise:

1.  When did they spray?

According to this notice, they did the fennel on April 24th. That part of the notice said “Before 10 a.m.” –  so presumably that’s when. Some time before 10 a.m. that morning. The second part, the extension of the dates, didn’t have any times on it. They apparently sprayed the fescue grass on May 4th. When exactly? We don’t know.

2. When will it be safe to go back in?  What’s “a few hours”?

No member of the public really wants to go among sprayed plants to check if they’re still wet, and especially they don’t want kids or pets doing it.  Lisa Wayne of Natural Areas Program has said that the people doing the spraying stay on-site until the pesticide is dry. Do they really remain in the vicinity for a few hours?

We also note they’re using vegetable oil as an adjuvant. As far as we know, vegetable oil takes a long time to dry, and remains sticky for hours or days.

If this is not true, we’d appreciate a clarification and some practical data.

3.  Where did they spray?

Nearly all of McLaren Park that isn’t actually dedicated to a specific activity like golf or playgrounds is Natural Area. (See the map; the yellow areas are NAP land.) Since the sign says “Throughout the Park,” it could be pretty much anywhere.

Not everyone can even identify fennel or bindweed or fescue, so they wouldn’t have any idea which plants to avoid – and besides, these are plants that mingle with others in mixed groups.

4.  What happens when people cannot read English?

Some of our parks are in majority Spanish-speaking neighborhoods. Shouldn’t the pesticide signs have some kind of graphic so people know to stay away and when it’s safe to re-enter?

If a park-goer with kids and dogs took this notice seriously – assuming they saw it, since some visitors on the same day did not – they would have to presume that they should stay out of the park altogether for at least 2-4 days.

Natural Areas Pesticides: The Fearsome Four

Three of the Four on Mt Davidson

The Natural Areas Program (NAP) uses four herbicides classified as “Most Hazardous” (Tier I) or “More Hazardous” (Tier II) by San Francisco’s Department of the Environment (DoE):

  • Garlon 4 Ultra (triclopyr)
  • Roundup or Aquamaster (glyphosate)
  • Polaris or Habitat (imazapyr)
  • Milestone (aminopyralid)

All these chemicals have serious problems: they’re associated with birth-defects and pregnancy failures; they’re endocrine disruptors; they poison animals, especially amphibians but also reduce bird-nesting success; and/or they’re persistent – they stick around.

For details of the risks associated with each one, read the article Natural Areas Program’s Pesticides: Toxic and Toxic-er.

We often get questions about this, especially from people who have heard about NAP from its supporters.

Source: SaveSutro.com (derived from from SF City records)

Q:  They hardly ever use pesticides, right? Just once every few years?

A:  NAP applied pesticides 86 times in 2011, up from 71 the year before. (We’re relying on City records here. There may be gaps.)

Q: But maybe they used less in each application?

A: The amounts used went up in proportion.

Q: Don’t they use very small amounts? Doesn’t the dose makes the poison?

A: In 2010, NAP used more Tier I herbicides than any comparable park department. (We don’t have compiled data for 2011 for other parks departments.)  Anyway, “the dose makes the poison” isn’t always true. Here’s what the American Chemical Society said in its Public Policy Statement, Testing for Endocrine Disruption:

Endocrine disruption is the alteration of the endocrine system that causes adverse health effects in an intact organism, or its progeny, or (sub)populations. Endocrine hormones naturally act at ultra-low concentrations and certain chemicals are suspected of altering endocrine function at similarly low concentrations, which sometime occur in the environment. A large and growing body of environmental health literature shows that endocrine disrupting substances have complicated dose-response curves that do not fit the central tenet of regulatory toxicology, namely, that the ‘dose makes the poison.’

Q: But aren’t they herbicides… don’t they act only on plants?

A:  They act differently on plants and on animals, but they still can – and do – impact animals (and people).  They may use different bio-chemical pathways in animals and in plants, and thus have different effects. None of these effects is good. The city of San Francisco subscribes to the “Precautionary Principle” – if you don’t know the effects, don’t use it. The natural areas are where children explore, people walk, and pets are exercised. This is not a risk they should take.

West Portal Monthly: Clearcut Case of Overkill at Mt Davidson Park

The West Portal Monthly today published an article by Jacquie Proctor explaining the problem of the NAP specifically at Mt Davidson and generally throughout the city.  The plan seeks to destroy at least 1600 trees on Mt Davidson alone. Read on: