Oyster Bay: Firehose of Funds means a Firehose of Herbicides

This article is reprinted from the website Death of a Million Trees with permission and minor changes.

 

OYSTER BAY: A FIREHOSE OF PUBLIC FUNDING SUPPLIES A FIREHOSE OF HERBICIDES

Oyster Bay is one of several East Bay Regional Parks along the east side of the bay that is a former garbage dump built on landfill. We visited Oyster Bay for the first time in 2011 after a former Deputy General Manager of the park district told us that it is a “beautiful native plant garden” and a model for a similar project at Albany Bulb, another former garbage dump being “restored” by the park district.

When we visited seven years ago, we found a park in the early stages of being destroyed in order to rebuild it as a native plant museum. Since there were never any native plants on this landfill, we can’t call it a “restoration.” We took many pictures of the park in 2011 that are available HERE.

We recently decided it was time to revisit the park when we noticed pictures of it in the recently published annual report of the park district’s Integrated Pest Management program, indicating recent changes in the development of the park. My article today is about what is happening now at Oyster Bay. It is still not a “beautiful native plant garden.”

“RESTORING” GRASSLAND  

Non-native annual grassland. Oyster Bay April 2011

Seven years ago, most of Oyster Bay was acres of non-native annual grasses. Since then, most of those acres of grassland have been plowed up and are in various stages of being planted with (one species?) of native bunch grass (purple needle grass?).

Stages of grassland conversion. Oyster Bay May 2018

On our May 1st visit, there were at least 8 pesticide application notices posted where the native bunch grass has been planted. Several different herbicides will be used in those sprayings: glyphosate, Garlon (triclopyr), and Milestone (aminopyralid).

Herbicide Application Notices, Oyster Bay May 2018

Grassland “restoration” in California is notoriously difficult. Million Trees has published several articles about futile attempts to convert non-native annual grassland to native grassland:

We wish EBRPD good luck in this effort to convert acres of non-native annual grass into native bunch grass. Frankly, it looks like a lot of public money down the drain to us. It also looks like an excuse to use a lot of herbicide.

Redwing blackbird in non-native mustard. Oyster Bay May 2018

Who benefits from this project? Not the taxpayer. Not the park visitor who is now exposed to a lot of herbicide that wasn’t required in the past. Not the wildlife, birds, and insects that lived in and ate the non-native vegetation. (We spotted a coyote running through the stumps of bunch grass. Was he/she looking for cover?)

DESTROYING TREES AND REPLACING THEM 

Pittosporum forest was an excellent visual screen, sound barrier, and wind break. It was healthy and well-suited to the conditions on this site. It was probably home to many animals.
Oyster Bay April 2011

When we visited Oyster Bay in 2011, many trees had already been destroyed, but there was still a dense forest of non-native pittosporum. That forest is gone and the park district has planted one small area with native trees as a “visual screen” of the Waste Management Facility next door. We identified these native trees and shrubs: ironwood (native to the Channel Islands), coast live oak, buckeye, toyon, juniper, mallow, holly leaf cherry, and redbud.

Native trees planted at Oyster Bay, May 2018

Ground around trees is green with dye used when herbicide is sprayed. Oyster Bay, May 2018

We also saw a notice of herbicide application near the trees. The ground around the trees was covered in green dye, which is added to herbicide when it is sprayed so that the applicator can tell what is done. There were men dressed in white hazard suits, driving park district trucks, apparently getting ready to continue the application of herbicides.

Will the trees survive this poisoning of the soil all around them? There are many examples of trees being killed by spraying herbicides under them. Herbicides are often mobile in the soil. Herbicides damage the soil by killing beneficial microbes and mycorrhizal fungi that facilitate the movement of water and nutrients from the soil to the tree roots.

Herbicide sprayed around newly planted trees. Oyster Bay May 2018

NOT A FUN DAY AT THE PARK

It wasn’t a fun day at the park and it isn’t fun to write about it. I decided to tell you about this visit after reading the most recent edition of the Journal of the California Native Plant Society, Fremontia (Vol. 46 No. 1). The introductory article of this “Special Issue on Urban Wildlands” is illustrated with a photo of Oyster Bay. I nearly choked on this statement in that article: “In order to control invasive plants, agencies and volunteers have sometimes resorted to using herbicides as a step in integrated pest control. While use of herbicides is contentious, the use for spot treatments has enabled small groups of volunteers to successfully eliminate invasive weeds in some areas where future herbicide use will not be needed.”

That is a PATENTLY FALSE statement. The California Invasive Plant Council conducted a survey of land managers in 2014. Ninety-four percent of land managers reported using herbicides to control plants they consider “invasive.” Sixty-two percent reported using herbicides frequently. The park district’s most recent IPM report for 2017 corroborates the use of herbicides to eradicate plants they consider “invasive.” The park district report also makes it clear that they have been spraying herbicide for a very long time. For example, they have been spraying non-native spartina marsh grass (in the bay and along creeks) with imazapyr for 15 years!

Attempting to eradicate non-native plants is NOT a short-term project. It is a forever commitment to using herbicides…LOTS of herbicide. To claim otherwise is to mislead, unless you are completely ignorant of what is actually being done.

YOU ARE PAYING FOR THIS

Another reason why I am publishing this article is to inform you that you are paying for these projects. The park district recently published a list of 492 active park improvement projects in 2018 (scroll down to page 71), many of which are native plant “restorations.” The majority of them are being paid for with grants of public money from federal, State, and local agencies as well as a few parcel taxes. Taxpayers had the opportunity to vote for the parcel taxes. They will have the opportunity to vote for new sources of funding for these projects:

  • Proposition 68 will provide $4.1 BILLION dollars for “park and water” improvements. It will be on your ballot on June 5, 2018. Roughly a third of the money will be allocated for “protection of natural habitats.” (1) Although the project at Oyster Bay does not look “natural” to us, that’s how the park district and other public agencies categorize these projects that (attempt to) convert non-native vegetation to native vegetation.
  • Measure CC renewal will be on the ballot in Alameda and Contra Costa counties on November 6, 2018. The park district has made a commitment to allocate 40% of the available funding to “natural resource projects.” Although the anticipated revenue (about $50 million) seems small, it is used as leverage to apply for big State grants, which require cost-sharing funding. Measure CC is essentially seed money for the much bigger federal and State funding sources.

I would like to vote for both of these measures because our parks are very important to me. If voting for these measures would actually improve the parks, I would do so. But that’s not what I see happening in our parks. What I see is a lot of damage: tree stumps, piles of wood chips, dead vegetation killed by herbicides, herbicide application notices, signs telling me not to step on fragile plants, etc.

Stay out of Oyster Bay to avoid unnecessary exposure to herbicides and keep your dogs out of Oyster Bay for the same reason. Unfortunately wildlife doesn’t have that option. They live there. Oyster Bay, May 2018


  1. “States big bond for little projects,” SF Chronicle, May 5, 2018
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Roundup: Probably Carcinogenic, and What Else?

It’s now widely known that Roundup has been found to be a probable carcinogen by the World Health Organization. (We wrote about that here: WHO – Roundup Probably Carcinogenic).

This is particularly disturbing, because it’s a very widely-used pesticide and the amounts found in humans have increased 5x since 1994 according to a UCSD study. Not only is it used in agriculture, it’s (still) used in our parks. Marin County has prohibited its use on public properties, but San Francisco’s Department of the Environment only reclassified it from Tier II (More Hazardous) to Tier I (Most Hazardous). The Natural Resources Department (NRD) of San Francisco Recreation and Parks Dept (SFRPD) continues to use it.

Photo of warning sign. Garlon, Aquamaster, Milestone on Mt Davidson. March 2018

Garlon, Aquamaster, Milestone on Mt Davidson. March 2018

But it’s not just a probable carcinogen. Research indicates a bunch of other issues:

VERY LIKELY AN ENDOCRINE DISRUPTOR

It’s very likely to also be an endocrine disrupter, which means it acts like a hormone in the human body, and can be a problem at very low doses.

Hormone disruption diagram - Source: NIH

Hormone disruption – Source: NIH

In a letter an EPA scientist Dr Marion Copley sent before she died, she not only said it was carcinogenic, she noted “glyphosate was originally designed as a chelating agent…” and lists the issues with chelating agents, including, “Chelaters are endocrine disrupters…” (That article is here: “It is essentially certain that glyphosate causes cancer.”)

If you want to read about how endocrine disruptors work, that’s a link to the National Institutes of Health website. It notes: “Research shows that endocrine disruptors may pose the greatest risk during prenatal and early postnatal development when organ and neural systems are forming.”

BIRTH DEFECTS IN VERTEBRATES

A paper published May 2010 in the journal, Chemical Research in Toxicology linked glyphosate to birth defects in vertebrates. We’d like people who have assumed that Roundup’s problems come mainly from its surfactant POEA to take a look. (This is not to say POEA is harmless. That has been implicated in embryonic cell death also, in a 2008 French study published in the same journal.)

In Argentina, glyphosate (the active ingredient of Roundup) is widely used on soybean. In soybean-growing areas, there were reports of increased birth defects of a particular type: malformed heads, eyes, and brains. A groups of researchers therefore decided to investigate whether glyphosate could indeed cause that type of birth defect.

The abstract of the article indicates that Roundup increased retinoic acid activity in vertebrate embryos, causing “neural defects and craniofacial malformations.”

Heart-breaking Birth Defects

Women of child-bearing age should be especially careful. The most vulnerable period, according to the paper, is in the first 2-8 weeks of pregnancy. Many people don’t even know they’re pregnant that early on. Furthermore, even the mature placenta is permeable to glyphosate. After 2.5 hours of perfusion, 15% of it crosses over.

The actual article, which we read elsewhere describes some of the birth defects: microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead, like the picture here); and neural tube defects. These are quite devastating. Many fetuses do not come to term, and many babies with these conditions die within hours or days.

INTERFERING WITH REPRODUCTION

There’s some evidence that glyphosate interferes with male reproduction, too. A 2014 article published in Science in Society in the UK, entitled “Glyphosate/ Roundup and Human Male Infertility” links glyphosate to falling sperm counts and lowered testosterone levels.

National Institutes of Health published a  paper in August 2000 that indicated Roundup interfered with reproductive hormones in rats.

DISRUPTION OF GUT BACTERIA

Other research has implicated glyphosate in other risk factors, particularly since it can disrupt gut bacteria in humans. We wrote about that here: Pesticides and Cancer, Glyphosate and Gut Bugs.

A 2013 article at RodalesOrganicLife.com suggests the growing evidence against glyphosate, possibly the world’s most widely used herbicide: ‘Once called “safer than aspirin,” glyphosate’s reputation for safety isn’t holding up to the scrutiny of independent research. More and more non-industry-funded scientists are finding links between the chemical and all sorts of problems, including cell death, birth defects, miscarriage, low sperm counts, DNA damage, and more recently, destruction of gut bacteria.’

Researchers found that glyphosate residues on food interfere with certain enzymes, with the result that  “…glyphosate enhances the damaging effects of other food borne chemical residues and environmental toxins. Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body.”

[That paper, published in 2013 the journal Entropy, is HERE.]
It suggests that glyphosate might be causing a lot of the health problems that have been associated with Western diets – including “obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease.”

BAD FOR THE ENVIRONMENT AND MOST LIVING THINGS

Glyphosate is bad for most living things. Research by way of a review of literature published in December 2017 by Springer Publishing concluded:

“Glyphosate poses serious threat to multicellular organisms as well. Its toxicological effects have been traced from lower invertebrates to higher vertebrates. Effects have been observed in annelids (earthworms), arthropods (crustaceans and insects), mollusks, echinoderms, fish, reptiles, amphibians and birds.”

It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

It damages the soil. How? It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil. Research also indicates it kills beneficial soil fungi while allowing dangerous ones to grow.  There’s a good article about that on the Million Trees website: Gyphosate (AKA Roundup) is damaging the soil  that discusses a New York Times article on the subject.

WHO’S USING GLYPHOSATE?

Most of SFRPD has continued to decrease use of glyphosate in 2017 – except for the Natural Resource Department (NRD, formerly Natural Areas Program – NAP). Here’s the comparison.

These graphs are in fluid ounces of active ingredient. The blue section is the use in 2016, and the orange section shows 2017.  NRD actually used slightly less glyphosate in 2016 than the rest of SFRPD (excluding Harding Golf Course, which is managed under an outside PGA contract). But in 2017, it used nearly 2 1/2 times as much.

Bear in mind that NRD accounts for a quarter of our park land in San Francisco.

Though we are glad SFRPD has been reducing use, we should be wary: Why Low Dose Pesticides are Still HazardsEndocrine disruptors can act at very low dilutions, and in their case, the old adage that the “dose makes the poison” is not true.

San Francisco “Natural Resources” Herbicide Usage Up 57% in 2017

We have recently analyzed the data for herbicide use in the full year 2017 for San Francisco’s so-called “Natural Resources Department” (NRD – formerly Natural Areas Program). It’s up 57% from the previous year.

NRD is a department of San Francisco Recreation and Parks Department (SFRPD). We were greatly encouraged when NRD started reducing herbicide use in 2014. Before that, pesticide use had increased sharply from 2009 onwards. (You can read an article about that here: SF’s Natural Areas Program – more pesticide in 2013.) Another sharp reduction in 2016 was even more encouraging – though it’s never come down to 2008 or 2009 levels. (The graph above shows annual NRD herbicide usage in fluid ounces of active ingredient.)

But this year, it’s up again, almost to 2015 levels. We have been hoping that SFRPD is working to eliminate all Tier I and Tier II herbicides, with leadership from the Department of the Environment (SF Environment).

For the rest of SFRPD (excluding Harding Golf Course, which is managed under a PGA contract), they have actually reduced usage. They use a greater variety of herbicides than NRD, of which more later. But they are using less – across all their parks and golf courses – than the NRD is. NRD forms a quarter of the area of SFRPD.

WHAT’S WRONG WITH THESE HERBICIDES?

NRD uses four herbicides: Two that SF Environment classifies as Tier I (“Most Hazardous”) and two classified as Tier II (“More Hazardous”). The Tier I herbicides are Roundup/ Aquamaster (glyphosate) and Garlon 4 Ultra (triclopyr); and Stalker/ Polaris/ Habitat (imazapyr) and Milestone VM (Aminopyralid) are Tier II. (In the first picture, with the white dog, the sign posted on Mount Davidson indicates they are using Aquamaster, Garlon, and Milestone in March 2018.)

These hazard rankings can change: Roundup/ Aquamaster (glyphosate) was reclassified from Tier II to Tier I when the World Health Organization found it was a probable human carcinogen. Milestone (Aminopyralid) was reclassified from Tier I to Tier II, despite the fact that it is extremely persistent and mobile in the environment.

THE FEARSOME FOUR

As you research these herbicides, you may find – as we did – that much of the research originates with the companies that produce them. It may be unbiased, but the evidence is that it often is not. So we looked for other sources, which are easier to find for well-established herbicides like glyphosate (Roundup or Aquamaster). It doesn’t mean the others are innocuous.

ROUNDUP or AQUAMASTER (Glyphosate)

  • Carcinogenic. In April 2015, the World Health Organization determined glyphosate was a “probably carcinogenic.”  EPA scientist Dr Marion Copley  sent a letter before her death saying it was essentially certain that glyphosate  causes cancer. She also said that as a chelater, it was likely an endocrine disruptor.
  • Associated with birth defects. It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).
  • Bad for the soil. Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
    It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • Bad for other living things. It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

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

The NRD uses Garlon extensively against oxalis. If it terminated its war on oxalis, it could stop using Garlon altogether.

POLARIS, HABITAT, STALKER  (Imazapyr)
This is a relatively new pesticide, and not much is known about it — except that it’s very persistent. In Sweden, it was found in the soil 8 years after a single application. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment.

It can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product  is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”
It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001 because of groundwater concerns.

MILESTONE (Aminopyralid)
Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as  a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.
Nevertheless, after an outcry and problems, Dow AgroSciences stopped selling Milestone in the UK for a number of years. It’s also prohibited for use in New York.

IT’S TIME TO STOP

There’s growing evidence that herbicides are more dangerous, more mobile, and more persistent than their manufacturers claim. Glyphosate, for instance, is widely found in all water sources, in the soil – and in people. A UCSF study of glyphosate in urine found: “Glyphosate residues were observed in 93% of urine samples in voluntary public testing in the U.S. general population; this is higher than the frequency observed in Europe using GC-MS (43.9%)”  and “exposure is likely due to dietary intake or environmental exposure.”

With endocrine disruptors, the old theory “the dose makes the poison” doesn’t work. They are potent at very low levels.

These are parks that we visit with our families, including kids and pets. Kids are particularly vulnerable to pesticides because of their low body weight and rapid growth. These are the watersheds that feed chemicals into our groundwater (which is also now being added to our domestic water supply).

The San Francisco Forest Alliance stands for No Pesticides in our Parks.

San Francisco Pesticides and “Inaccessible Areas”

One of our supporters has been pursuing a concerning issue regarding pesticide application in San Francisco. As our regular readers will know, proper notices are required when spraying toxic herbicides (designated Tier II, More Hazardous and Tier I, Most Hazardous) on city property – including our parks. Recently, SF Environment made changes to its application guidelines to provide better protection to the public, and to workers applying the pesticides. This requirement includes adding a blue dye to the mix so the public can see what has been sprayed with these chemicals.

However, there’s a loophole. Neither notices nor dye are required if the area is “inaccessible to the public.”  As the Natural Resources Department (renamed from NAP, the Natural Areas Program) works to limit public access to only a few “maintained trails” we’re concerned that this will give SF Recreation and Parks a free pass to use toxic herbicides like glyphosate (Roundup) without notices or dye.

So concerned citizen Tom Borden gathered information under the Sunshine Act. His research culminated in this letter to the Commissioners for the Environment.

Commissioners,

The department you oversee is willfully violating San Francisco’s Environment Code by offering City departments a loophole to avoid posting when pesticides are sprayed.  The Environment code Section 304 requires posting for all pesticide applications in all locations.  (One exception is noted, “right-of-way locations that the general public does not use for recreational purposes”.  This is intended to allow unposted treatments at places like roadway median strips, but certainly not in parks, adjacent to sidewalks and in watersheds.)

However, the IPM Compliance checklist says something very different, “Posting is not required for areas inaccessible to the public.”  This “publicly inaccessible” exception violates the Code and puts City workers and the public at risk.  According to IPM staff, they leave it up to individual departments to decide which areas are “publicly inaccessible”.  IPM staff have stated they do not make it their business to monitor these designations.

This clearly puts City employees at risk of unwitting exposure to pesticides.  It also puts the public at risk as land managers are left to their own devices to decide which areas qualify as “publicly inaccessible”.

On top of this, the Reduced Risk Pesticide List: Restrictions on “most hazardous”(Tier I) herbicides, was revised this March to remove the requirement that blue dye be added to Tier I herbicides if they are used in places where posting is not required.  In other words, if the land manager deems a location to be “publicly inaccessible”, there is no requirement to post and no requirement to use the indicator dye.  Anyone who goes through the area, City employee or member of the general public, will have no idea they are exposing themselves to Tier I herbicides.  (Why would you remove this cheap protection, even if it did only benefit the person applying the herbicide?  Also, the blue dye enables them to see where they sprayed, allowing them to apply the herbicide more efficiently.)

This posting loophole is not necessary under the precautionary principle and it violates the law.  It opens the City to lawsuits from employees who were not provided the protections the law promises.  I hope you will have the Department to rectify this.

See the email exchange below for additional information..

Thank you for your attention to this matter.

Tom Borden

EMAILS IN THE BACKSTORY

If you want to see the email trail yourself, here it is:

This is a Sunshine request.

San Francisco Environment Code Section 304.(e) allows the Department of Environment to grant permanent (ongoing as opposed to one time) exemptions to the notification requirements of the code.

(e)   The Department may grant exemptions to the notification requirements for one-time pesticide uses and may authorize “permanent” changes in the way City departments notify the public about pesticide use in specific circumstances, upon a “finding” that good cause exists to allow an exemption to the notification requirements. Prior to granting an exemption pursuant to this subsection, the City department requesting the exemption shall identify the specific situations in which it is not possible to comply with the notification requirements and propose alternative notification procedures. The Department shall review and approve the alternative notification procedures.

Please provide a list of all “permanent” exemptions that have been granted in the last 10 years.  If any have been granted to the Recreation and Parks Department or the SFPUC, please provide copies of those “findings” and a copy of the exemption request from the department.

He got a response – a phone call with Chris Geiger, responsible for San Francisco’s Integrated Pest Management program. Chris performs a delicate balancing act between reducing pesticide use and dealing with land managers who want to use these chemical weapons against “invasive” plants.  Tom asked for confirmation of the discussion in writing. He got it from Anthony Valdez, Commission Secretary.

On 7/5/2017 3:14 PM, Valdez, Anthony (ENV) wrote:

Tom:
As Chris Geiger discussed with you – the Department of the Environment has not granted any permanent exemptions to the posting requirements of Environment Code Section 304(a) for publicly accessible parcels. We do allow variances from the posting requirements for some publicly inaccessible parcels, most notably certain areas of San Francisco International Airport and closed utility rights-of-way managed by the Public Utilities Commission.
Thanks, Anthony
Anthony E. Valdez, MPA
Commission Secretary

Okay, good. So just to make sure, Tom asked:

Anthony,

Are any areas managed by the Recreation and Parks Department considered “publicly inaccessible parcels”?
If so, please provide a list of those areas and the associated variances from the posting requirements.

Thanks, Tom

Anthony responded:

On 7/12/2017 2:48 PM, Valdez, Anthony (ENV) wrote:
Tom –
Apologies for my delay in coordinating a response – we have two Commission on the Environment meetings this week. Please see the response below from Chris Geiger. Again, I encourage you to feel free to email or call Chris with any questions you may have:

The Department of the Environment does not review individual parcels to determine if they qualify as “publicly inaccessible.” That determination is left to the individual departments, including the Dept. of Recreation and Parks. We therefore do not have any specific variances or exemptions on file.  The reference document for this policy is the IPM Compliance Checklist.

You mentioned on the phone that you want to ascertain whether park areas adjacent to trails might be considered “publicly inaccessible” if there were signage requiring users to stay on the trail.  The answer is no. The posting exemption for publicly inaccessible areas is meant to apply to work areas, such as the Rec & Park Corporation Yard, not to public parks. We have never and would not ever grant any posting exemption for this kind of situation, and in my tenure we have never had any discussions or written exchanges with the Dept. of Recreation & Parks where this question has even come up. In my experience, Recreation & Parks has been quite careful and responsible in complying with posting requirements.

Anthony E. Valdez, MPA
Commission Secretary

That sounded encouraging. Just to confirm, though…

Thanks Anthony and Chris,

It’s good to know all herbicide applications in regular parkland and Natural Areas will be posted and that blue marking dye will be used.

On a related topic, Aquamaster was sprayed on Mt Davidson on July 5 [2017].  The treatment was to control poison oak growing onto a primary trail.  The herbicide was sprayed on PO and grass that was literally on the trail edge.  The trail was not closed off as required.  Attached are photos of the sign and the application area. More training and better supervision needed?

Tom

.

 

He followed up with another email.

Chris and Anthony,

In your July 12 email to me you say:

“The Department of the Environment does not review individual parcels to determine if they qualify as “publicly inaccessible.” That determination is left to the individual departments, including the Dept. of Recreation and Parks. We therefore do not have any specific variances or exemptions on file.  The reference document for this policy is the IPM Compliance Checklist.”

I see the Compliance Checklist does say, “Posting is not required for areas inaccessible to the public.”  However, the actual law,  SF Environment Code Chapter 3, does not make any such exception.  The posting exception in the Checklist violates the language of the Environment Code.  How does the Department of Environment justify making this exception?

Chapter 3 is meant to protect everyone in the City.  The IPM Compliance Checklist note removes this protection for City employees.  Doesn’t this leave the City open to lawsuits by willfully removing protections the law promises City employees?

As you know, I am concerned the RPD will use this as a loophole to avoid posting requirements in Natural Areas since their position is that the public is prohibited from straying off trail into those areas.  You state above that your department will not provide oversight of the “publicly inaccessible” designations made by City land managers.  This leaves in doubt what really qualifies as publicly inaccessible and as a result, leaves the public open to exposure to herbicide applications that are not posted or marked with blue dye.

I appreciate that your email also makes assurances that you have not granted RPD any additional posting exceptions, beyond this one granted to all City departments.

Looking forward to your reply,

Tom Borden
415 252 5902

After that, there was the letter to the Commissioners to express the same concerns.

Thanks, Tom, for trying to protect everyone from toxic herbicides in our parks!

Glyphosate in Glen Canyon

There’s increasing evidence that glyphosate – the herbicide Monsanto sells under the names Roundup and Aquamaster – is dangerous to human health, doesn’t degrade in the soil as the company claims, and is a dangerous probable carcinogen. Since SF Department of the Environment changed its classification from Tier II (More hazardous) to Tier I (Most hazardous), SF Rec and Parks has nearly stopped using it. Except in “Natural Areas.”

Recently, one of our supporters sent us these pictures:

It warned they would use Aquamaster (glyphosate) and Milestone (an astonishingly persistent herbicide) on the hillside above Islais Creek.

 

SF RPD should stop all use of Tier I chemicals. (Currently, the Natural Resouces Division uses Garlon and Roundup that are Tier I. ) The benefits are not worth the risk – to the public, their pets, and the people who apply herbicides.

We call on SF Rec and Park to stop using herbicides in our parks.

 

Roundup, Garlon, and Pesticide-Free Parks

New evidence has emerged that Monsanto influenced the Environmental Protection Agency  (EPA) to downplay the cancer-causing risk of Roundup. This pesticide, and others that may be even more hazardous, are used in our parks and watersheds. And now, since San Francisco is adding ground water to the Hetch Hetchy water we have been getting, our water may contain traces of these hazardous chemicals.

 

MONSANTO OFFERED TO GHOST-WRITE KEY REPORT SECTIONS ON ROUNDUP

Bloomberg and other news sources show that Monsanto offered to ghost-write sections of the EPA report on glyphosate, and sought the help of an EPA official to kill the reports that glyphosate is a probable carcinogen.

We reported earlier that a letter by an EPA employee Dr Marion Copley, written as she was dying, says: “It is essentially certain that glyphosate causes cancer.” She also said it is an endocrine disruptor, and alleged corruption within the EPA.

A California Superior Court judge has ruled that Roundup can be added to the Prop 65 list of known carcinogens, despite Monsanto’s attempts to block such a listing. “State regulators were waiting for the formal ruling before moving forward with the warnings, said Sam Delson, a spokesman for the state Office of Environmental Health Hazard Assessment.” 

Dr Copley’s letter only used glyphosate (Roundup, Aquamaster) as an example. The letter hinted that other chemicals might have fared similarly – that is, not been properly evaluated because of corporate influence on EPA employees. We the public cannot assume that toxicology tests performed by the companies producing the pesticides or scientists they may pressure are sufficient to prove the chemicals are harmless.

ROUNDUP AND GARLON IN OUR PARKS

Roundup has been used for years by SFRPD and other city entities. Only in  2015 was it designated a Tier I (most hazardous) pesticide. We tracked its use in San Francisco’s Natural Areas from 2008 to 2016. (It’s also used in other parks, and by the PUC, but we have not compiled those data.)

In the bar-graph here, the green section represents Roundup. The Natural Resources Department (NRD) increased its use of Roundup each year from 2009 to 2013, then decreased it in 2014, slightly increased it in 2015, and now has brought it down to below 2010 levels – though not as low as in 2009 or 2010.

The orange section is Garlon, a Tier I (Most Hazardous) herbicide that’s considered even more toxic than Roundup. Garlon is also supposed to be twenty times as toxic to women as to men. (See page 28 of this California Native Plant Society Presentation which discusses best management practices in herbicide use: Law_Johnson 2014 presentation toxicity )

Nowadays, Garlon in San Francisco is used only by the Natural Resources Department against Bermuda buttercups (oxalis).

PROGRESS – AND A NEW PROBLEM ABOUT TO HAPPEN

SF Environment has responded to community concerns (including a petition opposing pesticides in schools and parks that has more than 12,000 signatures) by introducing a list of restrictions on the use of Tier I (but not Tier II) chemicals. (Their Tier system classifies all allowable pesticides as Tier III – Least Hazardous, Tier II – More Hazardous, and Tier I – Most Hazardous.)

Though we believe the restrictions do not go far enough, they are a start. SF Environment has not published the final version, but there is a current draft. We are providing our comments to the Commission for the Environment and to SF Environment in the hope that they will modify the conditions under which use of Tier I herbicides are permitted. (We’ll post about this soon.)

But – starting 2017, SF Environment is going to approve the use of something new: Milestone VM Plus. It’s a mix of Garlon and Milestone VM (aminopyralid). This combination is being approved as a Tier II herbicide. Amino-pyralid is the pesticide so persistent that it lasts for years – and if an animal eats treated vegetation, its droppings become toxic too. It was considered a Tier I pesticide until SF Environment decided to reclassify it as Tier II in 2013. It’s banned in New York and effectively in a number of other states too.

We’ve protested. Here’s our letter:

Dear Commissioners, Director Raphael, and Dr Geiger,

We are dismayed that a new triclopyr-based pesticide is being added to the 2017 pesticide list, and in combination with aminopyralid – and that too as Tier II. This is at a time when we’re working to *remove* triclopyr (as Garlon) from the list. We refer to Milestone VM Plus, which is Aminopyralid, triisopropanolamine salt, 2%; Triclopyr, triethylamine salt, 16%. It’s for injection and for tree stumps. As we understand it, this is a mixture of Garlon 3 and Milestone.

This could be disastrous. Triclopyr is one of the most toxic herbicides still on the list. And Milestone VM (Aminopyralid) is uncannily persistent – it can last for years. If vegetation treated with it is eaten by animals and excreted, the excreta still contains enough herbicide to harm plants. Until 2013, Milestone was considered a Tier I chemical for its persistence – and then changed to Tier II (possibly at the request of the Natural Resources Department, since other SFRPD departments don’t use Milestone VM.)  If Milestone VM Plus is used on trees in a forest or stand of trees, it could weaken adjacent healthy trees through the intergrafted root network, thus destabilizing groups of trees.

We urge you to delete Milestone VM Plus from your restricted list. It’s no better than using Garlon with some added Milestone. If it must be retained, please classify it as Tier I.

Respectfully,
San Francisco Forest Alliance

[Edited to Add: Unfortunately, Milestone VM Plus was approved and classified as Tier II. The 2017 List is given here as a PDF: sfe-th-2017-reduced-risk-pesticide-list ]

HERBICIDES IN OUR WATER?

This year,  San Francisco started adding well water drawn from under the city to our tap water. Roundup or Aquamaster (glyphosate) and other pesticides such as Garlon (triclopyr), Milestone (aminopyralid), and Stalker (imazapyr) – and their breakdown products, some of which may be even more toxic – could well be contaminating our water supply.

Pesticide supporters argue it doesn’t matter, because the amounts are small. But:

  • Herbicides (and other chemicals) could interact in ways that are unpredictable. No one has researched them.
  • There’s no way of knowing how much the cumulative exposure is for any individual. This is particularly a concern for children, whose low body weight and fast growth make them especially vulnerable; and for people with illnesses or chemical sensitivities.
  • Importantly, if they are endocrine disruptors – which means they act like hormones in the human body – tiny amounts can have a disproportionate impact. It’s an exception to the “dose makes the poison” saying. Here’s an article that cites references to studies showing endocrine disruption from glyphosate: Why Low Dose Pesticides are Still Hazards.

PESTICIDE FREE PARKS

We have heard some parents don’t take their children to Glen Canyon any more, owing to pesticide concerns. One of the restrictions that SF Environment will impose is no use of Tier I pesticides in areas frequented by children. (Tier II herbicides will still be allowed.)

While the San Francisco Forest Alliance asks for no pesticides in our parks (and watersheds), San Francisco could make a start by converting parks with children’s play areas to Pesticide-Free Parks. Here’s an example from Seattle.

Opponents of restricting pesticide use in this way might fear that the park looks awful, so we went and had a look. It was a sunny afternoon, and the park was beautiful.


The park was full of kids of all ages, from babies and toddlers to teenagers. One man rocked his tiny pink-clad baby daughter.  Another dad brought his small son to kick a ball around in the grass. School age kids chased each other with squirt-guns. Some families brought their dogs, who are allowed in the park. It must be a relief to know that you can safely take your family to such a park, and not encounter Roundup or Garlon, Stalker or Milestone VM.

The park has a nice playground.

It also had an organic community garden…

… complete with a green roof.

And a rain garden.

And a multilingual welcome sign.

It was a lovely example of the kind of Inclusive Environmentalism that San Francisco Forest Alliance stands for.

“It is essentially certain that glyphosate causes cancer”

glen canyon glyphosate June 2016 - Shrubs encroaching on grassland video

Applying Glyphosate in Glen Canyon

Marion Copley was a scientist at the Environmental Protection Agency. She died of cancer in January 2014. Before she died, she sent the letter below to her former boss Jess Rowland, saying “It is essentially certain that glyphosate causes cancer.”

Now,  a lawsuit by people with cancer or who lost loved ones to cancer, asks to depose Mr. Rowland. They allege that Monsanto has influenced the EPA through its ties to people there. (The Huffington Post report on that is HERE: Questions about EPA-Monsanto collusion raised in cancer lawsuits )

copley-correspondence-jess-rowland