Native Coyote and Non-Native Kangaroo Apples

In these times of so much bad news, we republish here a delightful post from the CoyoteYipps blog of wildlife photographer and coyote advocate Janet Kessler (with permission).


I watched a coyote forage in one of these bushes. When the coyote left, we went up to examine the berries which I had never seen before. I took a tiny taste, and my friend gulped down a couple to help us determine what they were: the flavor was bitter with a tad of sweet.

When I got home, I couldn’t find the plant on the internet, so I turned to my Nextdoor site and posed the question there. They indeed came up with what it was: Kangaroo apple, as it’s called in Australia, or poroporo, as it is called in New Zealand are native to those areas, but have been naturalized into the Bay Area and can be found throughout San Francisco. AND, we should not have eaten them as they are poisonous — they belong to the nightshade family! Yikes!

Once I had the name of the plant, I looked up more about it. Interestingly, it’s flowers are hermaphroditic (having both male and female organs). They are blue-violet or white in color, and a little over an inch in size. Flowers are followed by berries of about the same size. The berries, it turns out, are poisonous only while green — they become edible once they turn orange.  Whew!

The next day I went back to see if the coyote would appear again: I wasn’t sure it was eating the fruit or possibly foraging for snails or slugs on the plant. I wondered why a coyote might eat toxic material. As I watched, I saw that the coyote eating only the orange colored fruit! Maybe the green ones were unsavory and bitter as well as toxic? Smart coyote!

One argument we often hear is that “native plants” are better as habitat. It’s very seldom true. Most animals, birds, and insects adapt to available resources – and that includes, often, non-native plants. The example above is one; another is the dramatic anise swallowtail butterfly that depends on non-native fennel. San Francisco Forest Alliance stands for Inclusive Environmentalism,  opposing xenophobia and welcoming the species that will save our changing world.

Bats About Glen Canyon Park

2012-02-23 at 18-08-20_1 batBats are insect-eating machines. According to the USGS, “Bats normally eat about half their weight in flying insects each night.”  So even for those who don’t find these night-flying mammals charming, it’s good to know there are bats among us.

San Francisco has at least four species of bats, all of which eat insects. According to research by Jennifer Krauel, which involved recording bat sounds to determine which species they were, Mexican Free-tailed bats are the most common. Parks with water – like Glen Canyon – also have Yuma Myotis bats. The other two species she found (more rarely) were Western Red Bats, and Little Brown Bats, and she found them in just a couple of places.

2012-04-07 at 19-41-44 batHer research indicated that “amount of forest edge and distance to water were the factors best explaining species richness and foraging activity.”  It also showed that bats in San Francisco remain active through the winter and don’t hibernate or move elsewhere.

If you’re interested in reading her paper, it’s here as a PDF: Jennifer Krauel thesis on bats in SF


Glen Canyon’s bats are often visible at dusk. They’re most evident in the Fall, though they’ve been seen at other times of the year.  (The pictures above are from February and April, those below from October.)

Here’s a note on bat-viewing from one visitor to Glen Canyon.

“It was late in the afternoon, and late in October. We were standing around the entrance to the park on Alms Rd.  As dusk fell, bats emerged from the tall eucalyptus trees. Quite suddenly they were  in the air right above us. I pulled out my camera, which is not really good in poor light but I tried to take some pictures anyway. Here’s one:

bats 1

“They’re difficult to spot in the picture, but all those black smudges are bats that were moving too fast for my pocket-camera. Here’s the same picture, cropped, with the bats circled in yellow:

bats 1a

“They dispersed over the canyon. Here’s another picture from a few minutes later (and the one below it shows where the bats are).

bats 2

bats 2a

“It was fantastic. I haven’t seen this many bats anywhere in San Francisco.”


We did a little research, and found a Stanford report that emphasized the importance of large trees to a particular species of bats, Yuma Myotis… bats that Krauel’s research had actually found in Glen Canyon Park. 

“Yuma bats that forage in the preserve travel several miles to roost in large trees in Portola Valley and Woodside, suburban communities on the San Francisco Peninsula. The average diameter of the bats’ chosen trees is about a yard across — more than three times wider than the average tree in those areas.”

(The link to the abstract of the actual Stanford research paper is HERE.)

That’s the size of the big eucalyptus trees in Glen Canyon Park – including those that SFRPD wants to chop down.


Bats are an important part of an eco-system, and fill a role few other creatures do: They hunt night-flying insects like mosquitoes that birds don’t catch because they’re sleeping. This is especially important now as West Nile virus, a mosquito-borne disease, has been spreading.

Having bats in a landscape contributes to its bio-diversity. All species of bats are protected in California.

(Some people are concerned that bats carry rabies – and it’s true no one should handle bats, especially grounded bats that may be sick, with their bare hands. But according to the California Department of Fish and Wildlife, less than 1% of bats are infected. [Click HERE to see their note.]  The risk of getting rabies from a bat is less than the risk of being struck by lightning.)


We’re concerned about the impact of the planned tree removals on Glen Canyon’s bats.

  • All species of bats are protected, and removing the trees will impact their habitat by reducing the number of safe roosting spots, especially for Yuma Myotis bats that need both large trees and nearness to water.
  • The contractor will be chopping down the trees in the daytime. Bats roosting there are likely to be killed – if not in the process of the tree-felling, by being forced to fly blinded and confused in the daytime and fall prey to hawks, crows and ravens.

How is SF RPD going to ensure the protection of these bats?

And in what ways will felling large trees near the stream alter the ecology of the canyon?

Red Shouldered Hawk in a Natural Area

Hawks need tall trees for roosting, watching, and nesting. This one is watching from a non-native cypress tree. (Photo credit: Janet Kessler)

Glen Canyon Park and the Circle of Life

This is another of our “park visitor” series – first person accounts of our parks, published with permission.

It was the first sunny day in a while, and I climbed down into Glen Canyon from the Safeway parking lot, past the half-burned oak tree and the fallen Monterey cypress.

That used to be a beautiful tree, casting a low dense shade on the path where  people could rest and shelter from the sun. Once I saw bunch of kids maybe 8 years old or so stop there with their teacher. Sadly, lightning hit it during a storm, someone said, and it collapsed.

It’s down but not dead. It still has green leaves, and birds still find it a great place to perch and hide.

Overhead, a large bird patrolled the canyon, swooping low and turning and flying in circles. I assumed it was one of the resident red-tailed hawks I’ve seen around before. They even breed here, I believe.  Then I saw someone in the distance – rather excited, by the body language – try to get a photo of it. So I looked more closely. It wasn’t a red-tail, it was a turkey vulture.

But what was a turkey vulture doing flying like that? I was more used to seeing them soaring or sitting. I tried getting a photograph too, with my small automatic camera.  (This isn’t the quality of pictures you’re used to seeing on this site from more expert photographers, but it’s a record of the moment.)

I could see its red head, but it doesn’t really show up in the picture. (Here’s an enlarged version of the bird.)

Still wondering why it was acting more like a hawk than a vulture, I continued with my walk.

Then I saw the reason. A skunk lay beside the path. It had been dead a while; part of the skin was gone, and flies were buzzing it. That’s what the vulture wanted, but it had a problem. This is a well-used path, with joggers and hikers and dog-walkers coming by. Unlike a hawk, which is more likely to get its food to go, vultures are more likely to dine in.  So, I hypothesized, it kept coming by, and kept waiting for the people to go away. (This picture is the least gory angle. Even skunks deserve their dignity.)

Eventually, the vulture gave up, and went off to perch in the eucalyptus trees below. (Those trees are so important as habitat for birds large and small, from tiny Brown Creepers to large Turkey Vultures.)

I wonder where the dead skunk came from. Perhaps one of the resident Great Horned Owls dropped it? They’re known to hunt skunk.

Fire at McLaren Park: Letter from a Park-Lover

We received this letter from a frequent visitor to McLaren Park. It’s published here with permission and minor edits.

Only a small part of the grassland that burned south of Mansell Drive

Dandelion and thistle seeds survived the fire – a feast for the birds

I was at McLaren a few days ago and the seasonally dry, “Natural Areas” grassland south of Mansell is burnt. I can’t find anything on the web about the fire but it looks like it started about 50 feet from a homeless encampment at the bottom of the hill close to lower Visitacion.  (It also could have been started by fireworks.)

Unlike the Stern Grove fire last week, which burned a small area in the ivy-covered forest, the McLaren grass fire burned a pretty large area – I’d guess 5 to 8 acres. Interestingly, a few coyote bushes burned but most didn’t. The non-native dandelions and bull thistle seeds did not burn, and were blowing across the burnt area. Loads of birds were eating the white fuzzy seeds. It will be interesting to see what the grassland looks like as it grows back.

Leaf litter didn’t burn

Burning certainly is a concern in the city but fire was a key part of the Native American ecosystem when Europeans arrived.

Fire, missing grazing, large predators, climate changes, and air pollution, are all reasons it is futile to pretend San Francisco Native Heritage can be restored.


In the forest south of Mansell,  I saw several young pines, which contradicts a Rec & Park forestry report that says pines and cypress are not naturally regenerating in San Francisco parks.  (I’ve also seen young cypresses deep in the forest at Mt Davidson.  Sadly, even when I showed a seasoned Native Plant Advocate the young cypresses and eucalyptus, he still insisted that trees can’t regenerate in the forests and the forests are unsustainable.)

Recently cut young trees

San Francisco is paying millions for “reforestation” projects at the same time they are cutting down healthy pine trees and self-sustaining forests?

Of course, even Rec & Park can’t deny that eucalyptus is self-sustaining because of the young sprouts throughout the park forests that they haven’t managed to cut down.  It is so sad to see the many poles of young pines and eucalyptus cut and lying on the ground in piles of dry leaves throughout the McLaren forests. Are the Natural Areas “volunteers” or staff surreptitiously implementing the Natural Areas tree-thinning program even before the environmental impact report is completed?

Strange that the city spends millions for a plan and draft environmental impact report but appear to be moving forward with their plans as if it is just an expensive formality.  What is sad is the proposed plan isn’t even the “environmentally superior plan” per the city’s own analysis.  It is bizarre that native plant advocates have hijacked the term “environmentalist” to mean native plants.  Other cities recognize the health and environmental benefits of a healthy forest, while “environmentally conscious” San Francisco is deliberately chopping healthy trees down as if they are garbage.


The road/trail at the bottom of the hill also has fennel sprayed with pesticides along the trail right above the homeless encampment, which is visible from that trail. I wish Rec & Park would clean up the garbage that they walk by instead of spending their time spraying pretty, green fennel.

Garbage left from a homeless encampment near the trail/road.

I really think it is disturbing that the Natural Areas are the only parks exempt from any maintenance standard, even the one that says no more than 15 pieces of litter visible in a 50′ by 50′ area.   This means Rec & Park has exempted one-fourth of the land managed by Rec & Park from the voter-passed Prop C requirements for park maintenance standards and monitoring.

A few months ago, I broke my habit of walking the trails between the reservoir and the tennis courts for the less-travelled trails of McLaren.  I particularly love the rolling hills with flocks of birds, trees, wildflowers, and meadows and that our walks are so much longer.  However, I’m not as thrilled about spending much of my walk trying to make a dent in the accumulated litter.

I’m surprised anyone was taking the trails, considering the uninviting litter accumulated at the Visitacion Avenue/Mansell Street entrance.  I cleaned about half, but the other half still looks like a dumping zone in an abandoned park.  It makes me appreciate the daily dog-walkers and others that clean up in the more-travelled park areas.  At least Rec & Park should routinely pick up at the entrances and parking areas and keep them relatively clean.

DESTRUCTION OF PLANT-LIFE: The “Natural” Areas Program

Personally I prefer the green left side to the “restored” right side with bare ground

On the other side of McLaren in the forest area, I found a volunteer working alone, pulling up the English ivy from the forest floor to leave bare ground. He has, he said, a “permit” from Rec & Park and has been trained to pull the ivy and that it is overrunning the park.  I’d personally rather see green ivy than bare ground covered in pine needles.  Especially since ivy, which flowers and bears berries early in the season, provides some wildlife food and shelter, absorbs carbon dioxide and air pollution, and makes the park feels more alive.

It is quite bizarre that Rec & Park and native plant advocates claim nothing grows under the non-native trees.  In reality that is true only because Natural Areas contingent is out there constantly pulling up the dense and diverse vegetation, which is prolific in eucalyptus, pine and cypress forests that are left natural or are lucky enough to be protected in Golden Gate Park.  (I still find it bizarre the maligned “invasive” plants and trees protected in one of San Francisco’s most precious gems, Golden Gate Park, are being sprayed, pulled and cut in neighborhood parks.)


When I mentioned that the Natural Areas plan has not been approved, he said it was okay to proceed because the plan was developed long ago. He implied dog people are the problem and that it wasn’t right that the dog people think the area is just for them. I said that people with dogs are about 40% of the population. Did having a dog mean that one shouldn’t have a voice in how the parks are used?

I wonder how many people are native plant gardening purists who want trees removed simply because they aren’t San Francisco Native Heritage?  Dog play areas are only about 100 acres, yet  native plant advocates call people with dogs greedy while The Natural Areas Program claims over 1000 acres. It’s concerning to take a dog or a child to an area that has been sprayed with herbicides.

Sadly, I saw at least 4 places with glass in the parking lots from broken car windows. (It’s the first time I’ve personally seen that at McLaren.) The broken glass and homeless encampment suggest that what McLaren Park really needs to make it safer is more visitors, not fewer trees, dogs or activities.

“Milestone” Pesticide in Glen Canyon (and Why New York Prohibits It)

This article is being reproduced, with permission and minor changes, from Death of a Million Trees.  “Milestone” (Aminopyralid) is one of the “Fearsome Four” pesticides the Natural Areas Program uses.

[Click HERE for an article on the “Fearsome Four” major pesticides and HERE for “Toxic and Toxic-er”  about each of these herbicides.]

The notice in this picture comes from Glen Canyon Park. As this article points out, this chemical is prohibited in New York; persists in the environment;  shouldn’t be used in watershed areas – and its use here may be violating the San Francisco’s Integrated Pest Management Policy.



Recently visitors to Glen Canyon Park in San Francisco spotted a Pesticide Application Notice in their park, which states that Milestone herbicide was used on “sweet pea.”  Sweet pea is not classified as an invasive plant by the California Invasive Plant Council.  Milestone herbicide is classified as Tier I “Most Hazardous” pesticide by San Francisco’s IPM program because it persists in the ground for a long time.  The City’s IPM policy states that it is approved for use on “invasive species.”  Since sweet pea is not an invasive plant, we assume this pesticide application violated San Francisco’s IPM policy.


The federally mandated Material Safety Data Sheet (MSDS) for Milestone advises users to, “Prevent [Milestone] from entering into soil, ditches, sewers, waterways and/or groundwater.”  The MSDS also says that Milestone “is not readily biodegradable according to OECD/EEC guidelines.”

Kid playing in Glen Canyon Park

For these reasons, the manufacturer of Milestone herbicide withdrew its application to sell Milestone in the State of New York, after the State of New York determined, “The [New York State] Department [of Environmental Conservation] could not ensure that the labeled use of aminopyralid [the active ingredient in Milestone] would not negatively impact groundwater resources in sensitive areas of New York State.” 

[Click HERE to read that finding.]

In other words, the sale of Milestone herbicide is banned in the State of New York.

Since Glen Canyon is a watershed to Islais Creek, we believe it is irresponsible to use Milestone in that park. [Islais Creek is the stream that runs through the bottom of Glen Canyon Park.]  And clearly there is no justification for using this persistent herbicide on a plant as benign as sweet peas.  Since Glen Canyon park is the home of a year-round day care center as well as a summer camp which leads children throughout the park, it is outrageous that these pointless risks were taken there.


As we celebrate the 50th anniversary of Rachel Carson’s ground-breaking book, Silent Spring, there is renewed media interest in this issue.  We welcome this reminder that Rachel Carson informed the public in 1962 that DDT was having a devastating impact on wildlife.  DDT had been used for about 20 years, but it took that long for us to notice that some species of birds had been poisoned nearly to extinction.  And it took another 10 years for DDT to finally be banned in 1972.

Rachel Carson was vilified for her revelations, just as critics of the so-called Natural Areas Program are being vilified by supporters of that program.  We have been called “chemophobes” and “anti-chemical crazies.”

Frank Graham, editor of Audubon Magazine, recently wrote an article for Yale University’s “environment 360” blog about the abuse that Rachel Carson endured after the publication of Silent Spring.

[Click HERE to read that article.]

He recounts several anecdotes about the attacks on her character.  For example, “An official with the federal Pest Control Review Board drew laughter from his audience when he remarked, ‘I thought she was a spinster.  What’s she so worried about genetics for?’”

Forty years after DDT was banned in the United States we have a local example of the persistence of this dangerous chemical in our environment.  From 1947 to 1966, several companies on the harbor in Richmond, California formulated, packaged, and shipped pesticides, including DDT.  The site was designated a State Superfund site in 1982, and in 1990 the EPA placed the site on a national priorities list for clean up.  “Remedial actions took place on the site from 1990 to 1999.”  Twelve years later, the EPA tells us, “Although actions were taken to reduce the risk from the pesticides found on site…sediments and the water [in that location] are still contaminated with pesticides, primarily DDT and dieldrin.

In other words, we fouled our water with dangerous pesticides; we then spent many years and probably a lot of money trying to clean up after ourselves, and 40 years later we are still living with the consequences of our foolishness.

What have we learned from that experience?  Now we are using a very persistent chemical (Milestone) on a benign plant (sweet pea) in our public parks.  We have learned nothing.  And those who have some economic gain from poisoning our parks—or are clueless about the risks they are taking—are defending the use of pesticides and trying to shut us up, just as they tried to shut Rachel Carson up 50 years ago.  We are proud to be in her company and we are inspired by her leadership.


Peaches at “Organic U-Pick” (Photo Credit: Arnita Bowman)

We prefer to end our stories on a positive note when we can, so we turn to a book we read recently about a fruit farmer in California’s Central Valley.  David Mas Masumoto wrote Epitaph for a Peach to tell us about his transition from the traditional farming methods used by his father to organic methods.  He has abandoned rigorous weed and pest control and he is learning to live in harmony with his orchards rather than fighting against nature.  He tells us about the difficult decision to quit using pesticides:

“I am reminded that in some valley wells they have found traces of a chemical called DBCP in ground water aquifers.  DBCP was linked to sterility in males and is now banned in the United States.  My dad used some DBCP years ago…No one knew it would contaminate drinking water.  Neighboring city folks are angry with farmers for damaging their water supply.  ‘How could you farmers poison the water?’ they ask.  My dad didn’t choose to pollute the water table.  He did nothing illegal.  He simply trusted the chemical company and the governmental regulatory agencies.

Mr. Masumoto has learned from bitter experience.  What we know about pesticides today is not necessarily what we will learn about them tomorrow.  We often look back on our use of pesticides with regret.  So, shouldn’t we at least avoid using them when we don’t need to—such as on flowers just because they aren’t native—or in places where the risks are great—such as public parks occupied by children?

Let’s turn that rhetorical question into the affirmative statement that it deserves to be:  We should not be using pesticides in our public parks or on plants that aren’t doing any harm.  We will live to regret it when we do.  And let’s express our gratitude to Rachel Carson for inspiring us to keep informing the public of the needless risks that are being taken in their parks.

Natural Areas Plan: SFFA comments on the DEIR (Pt 3: Wildlife)

Bewick’s wren at nest site

One of the reasons we oppose the Natural Areas Program is that it’s harmful to the birds and animals of this city. They destroy habitat — the trees and thickets that serve as cover and breeding grounds, exposing song-birds to predators; they do not respect the breeding season even though they claim to do so; and they use pesticides that can harm wildlife, whether insects, amphibians or other creatures.

Read on for the details.

In this public comment, we will provide evidence that the Natural Areas Program has had a significant negative impact on legally protected wildlife as well as all wildlife in San Francisco’s parks.

  1. The Natural Areas Program has violated California Fish & Game Code, Sections 1600-1616 regarding streambed alteration and the federal Migratory Bird Treaty Act by conducting the destructive phase of their project in Glen Canyon Park during breeding and nesting season.
  2. The Natural Areas Program is violating the Endangered Species Act by using pesticides known to be harmful to butterflies on Twin Peaks, where they have been reintroducing the endangered Mission Blue butterfly for several years.
  3. The Natural Areas Program harms all of the animals in the parks by poisoning and eradicating the thickets in which they den and nest and the food which they eat.


The Draft Environmental Impact Report (DEIR) states that SNRAMP is consistent with all federal and state laws governing the protection of biological resources.  One of those laws is California Fish & Game Code 1600-1616 regarding the protection of fish and wildlife within “bodies of water of any natural river, stream or lake.”  These codes obligate those who are engaged in any “streambed alteration” to apply for a permit and “to propose reasonable project changes to protect the resource.”  (DEIR, page 274)

Islais Creek in Glen Canyon Park is such a water body which is protected by this law.  Accordingly, the Natural Areas Program applied to California Fish & Game for a Streambed Alteration Permit in preparation for their project which began in November 2011.  The Natural Areas Program made the following commitment to mitigate harm to wildlife in Glen Canyon Park in its Streambed Alteration Permit:

“It is the policy of RPD’s Natural Areas Program that no new projects will begin during the breeding season (December to May).  Follow up work in previously cleared areas may be done during the breeding season, however, because areas will have been cleared previously. Wildlife will not likely be using these areas for breeding.  This protocol has been effective in reducing impacts to breeding wildlife.”

The Natural Areas Program began to destroy the non-native vegetation in Glen Canyon Park in San Francisco in November 2011.  In addition to destroying valuable habitat with chainsaws, they also sprayed herbicides.  This destructive activity continued through winter and spring 2012 and cannot be dismissed as “follow-up work” on previously cleared areas.  The San Francisco Forest Alliance (SFFA) protested this destructive project many times but it has continued unabated to as recently April 27, 2012, when they pruned trees and sprayed herbicides.

Earlier in April, SFFA learned from a public records request that this project violated a legal commitment to the California Department of Fish & Game.  SFFA immediately brought this violation of NAP’s commitment to the attention of the General Manager of the Recreation and Park Department.  The head of the Natural Areas Program said that the violation was necessary because the grant funding for the project was about to expire.  To avoid losing the funding for the project, the birds and animals of Glen Canyon Park were subjected to this destructive project during their breeding and nesting season.

SFFA brought this violation to the attention of the California Department of Fish & Game.  Their regulations commit them to enforce the terms of the Streambed Alteration Permit, including the mitigation of potential harm to wildlife.  Violations of the terms of the permit are subject to “civil penalties” according to the regulations:  “A person who violates this chapter is subject to a civil penalty of not more than twenty-five thousand dollars ($25,000) for each violation.”

One month after informing California Department of Fish & Game of this violation, nothing seems to be done about it.  In fact, several weeks after sending this information to Fish & Game, another episode of destruction occurred in Glen Canyon Park on April 27, 2012.

As the breeding/nesting season is also the season during which migratory birds are occupying their nests and the federal Migratory Bird Treaty Act “…also applies to the removal of nests occupied by migratory birds during the breeding season,” (DEIR, page 273) we assume this law was also violated.

In other words, the legal commitments made by the Natural Areas Program to conduct the destructive phase of their project outside of the breeding and nesting season were not observed.  Furthermore, no action was taken by California Fish & Game to stop this project when it was brought to their attention.  The law is apparently ignored with impunity.

In addition to the violation of federal and state laws, the Natural Areas Program has also violated the commitments made in both the SNRAMP and the DEIR:  “In compliance with the MBTA [Migratory Bird Treaty Act], the SFRPD would avoid harming or removing the nests of these species and any migratory bird species.  Measure GR-4b (page 109) in the SNRAMP requires that vegetation management activities be conducted outside the breeding season (February 1 to August 31), unless these activities had already begun before the breeding season and had already removed nesting habitat or if a breeding bird survey was conducted prior to vegetation removal activities and had determined that no nesting birds were present.” (DEIR, page 305)

The commitment to California Fish & Game in NAP’s Streambed Alteration Permit and the commitment made in Measure GR-4B of SNRAMP are contradictory.  These contradictions should be resolved by the final EIR:  When is the breeding season?  What evidence is there that a breeding bird survey was conducted prior to vegetation removal activities which took place continuously from November 2011 to April 27, 2012?  Is the mitigation required by the Streambed Alteration Permit consistent with the caveats of Measure GR-4b?


The Mission Blue butterfly is a federal endangered species which existed historically on Twin Peaks in San Francisco.  San Francisco’s Natural Areas Program has been trying to reintroduce the Mission Blue to Twin Peaks for several years, so far with limited success.  This reintroduction effort is reported by the DEIR. (DEIR, page 285)

Herbicides are being sprayed on Twin Peaks to control non-native vegetation.  Twin Peaks was sprayed with herbicides 16 times in 2010 and 19 times in 2011.

A recently published study reports  that the reproductive success of the Behr’s metalmark butterfly was significantly reduced (24-36%) by herbicides used to control non-native vegetation.  Two of those pesticides are used on Twin Peaks, imazapyr and triclopyr.  Triclopyr was used most often on Twin Peaks in 2010 and imazapyr in 2011.

The study does not explain how this harm occurs.  It observes that the three herbicides that were studied work in different ways.  It therefore speculates that the harm to the butterfly larva may be from the inactive ingredients of the pesticides which they have in common, or that the harm comes to the larva from its host plant which is altered in some way by the herbicide application.  Either theory is potentially applicable to the herbicides used on Twin Peaks and consequently harmful to the endangered Mission Blue.

The Endangered Species Act requires that the Natural Areas Program stop spraying these herbicides on Twin Peaks because they are known to be harmful to the reproductive success of butterflies.  Unless further scientific study exonerates these herbicides, the law obligates us to prohibit their use where the endangered Mission Blue butterfly is known to exist, i.e., on Twin Peaks.


The DEIR states repeatedly throughout the document that habitat will be improved by the eradication of non-native plants and the presumed replacement by native plants.  In fact this is offered as the basis for most claims in the DEIR that the “restoration” project will not harm the environment.  For example, although the DEIR acknowledges that the environment may be harmed by the methods used to eradicate non-native plants, this harm is theoretically mitigated by the claim that the eventual development of native habitat will compensate for that harm.  These claims are not supported by either the reality of restoration efforts in the past 15 years or by scientific evidence which does not substantiate a claim that native vegetation provides habitat for animals that is superior to non-native vegetation.

Although non-native vegetation has been removed repeatedly in many natural areas, the native plants that are planted in their place rarely persist for longer than a few months.  These newly planted areas are quickly over run by non-native weeds.  We will provide examples of such failed “restorations” in a subsequent section of this comment (Part V).

More importantly, neither SNRAMP nor the DEIR provide any scientific evidence to support the contention that native vegetation provides superior habitat to animals.  In fact, all available scientific evidence contradicts this claim.

Because eucalyptus trees are one of the primary targets for eradication, we will focus on the specific claim that the eucalyptus forest is a “biological desert.”   We are frequently told that “nothing grows” under the eucalypts and that they are not providing food or habitat to insects, birds, and other animals.

Professor Dov Sax (Brown University) tested these claims while a student at UC Berkeley.  He studied the eucalyptus forest in Berkeley, California, and compared it to native oak-bay woodland in the same location.  He found little difference in the species frequency and diversity in these two types of forest.

He studied six forests of about 1 hectare each, three of eucalypts and three of native oaks and bays in Berkeley, California.  The sites were not contiguous, but were selected so that they were of similar elevation, slope, slope orientation, and type of adjacent vegetation.  He conducted inventories of species in spring and autumn.  He counted the number of:

  • Species of plants in the understory
  • Species of invertebrates (insects) in samples of equal size and depth of the leaf litter
  • Species of amphibians
  • Species of birds
  • Species of rodents

He reported his findings in Global Ecology and Biogeography :

“Species richness was nearly identical for understory plants, leaf-litter invertebrates, amphibians and birds; only rodents had significantly fewer species in eucalypt sites.  Species diversity patterns…were qualitatively identical to those for species richness, except for leaf-litter invertebrates, which were significantly more diverse in eucalypt sites during the spring.”

Professor Sax also surveyed the literature comparing biodiversity in native vs non-native forest in his article.  He reports similar findings for comparisons between non-native forests and local native forests all over the world:

  • In Spain, species of invertebrates found in the leaf-litter of eucalyptus plantations were found to be similar to those found in native forests, while species richness of understory plants was found to be greater in the native forests.
  • In Ethiopia the richness of understory species was found to be as great in eucalyptus plantations as in the native forest.
  • In the Mexican state of Michoacán, species richness and abundance of birds were found to be similar in eucalyptus and native forests.
  • In Australia species richness of mammals and of soil microarthropods were found to be similar in native forests and in non-native forests of pine.

The only caveat to these general findings is that fewer species were found in new plantations of non-natives less than 5 years old.  This helps to illustrate a general principle that is often ignored by native plant advocates.  That is, that nature and its inhabitants are capable of changing and adapting to changed conditions.  In the case of non-native forests in the San Francisco Bay Area, they have existed here for over 100 years.  The plants and animals in our forests have “learned” to live in them long ago.

The scientific literature informs us that wildlife does not necessarily benefit from native plant restorations and sometimes they are harmed by them.  The assumption that native animals are dependent upon native plants underestimates the ability of animals to adapt to changing conditions.

Art Shapiro (UC Davis) has been studying California butterflies for over 35 years.  His own observations as well as the work of other scientists have informed him that “…the extensive adoption of introduced host plants has clearly been beneficial for a significant segment of the California butterfly fauna, including most of the familiar species of urban, suburban and agricultural environments.  Some of these species are now almost completely dependent on exotics and would disappear were weed control more effective than it currently is.”

He explains that this is particularly true on the coast of California because this is where the highest concentration of introduced species of plants is naturalized and the butterfly population is less diverse because of the cool, foggy climate.  There are apparently few non-native plants in the desert and alpine regions of California and so butterflies in those regions have not had the opportunity or need to adapt to new plants.

Professor Shapiro also speculates in this study that other insects have adapted to non-native plants as well:  “Introduced hosts, having a broader geographic range than native hosts, may permit the expansion of the insect population geographically.”

Birds have also adapted to non-native plants and trees.  Researchers at UC Davis surveyed over 1,000 ornithologists in 4 states, including California, about their observations of native birds and non-native plants.  Responses from 173 ornithologists reported 1,143 “interactions” of birds with introduced plants considered invasive.  Forty-seven percent (47%) of those interactions were birds eating the fruit or seeds of non-native plants and trees considered invasive.  Other interactions were nesting, perching, gleaning [eating insects], etc.

Interactions were frequently reported in non-native blackberry, which is found in most parks in San Francisco.  It is one of the most productive food sources for birds in San Francisco.  Unfortunately, it is being eradicated by the Natural Areas Program along with a long list of non-native shrubs which provide food and cover, such as cotoneaster, fennel, etc.  The loss of food and cover has a drastically negative impact on the animals that live in our parks.

The non-native blackberry also provides cover for wildlife.  It is an impenetrable bramble both physically and visually.  Birds and small mammals hide and make nests and dens in these thickets.  Coyotes are resident in San Francisco.  The thick undergrowth which has been removed in some parks by the Natural Areas Program now allows unleashed dogs to pursue them in areas where they were protected before.  If the safe havens of urban wildlife are destroyed, the animals may seek shelter elsewhere, a move that may be dangerous for them.  When animals move into residential neighborhoods they are considered a nuisance and are often killed.

Native plant restorations also require the use of herbicides to eradicate non-native trees and plants.   Herbicides are being sprayed in the blackberries and other berry-producing non-native plants which are a major food source for wildlife.  One study performed by the US Forest Service for the EPA reported that the use of Garlon significantly reduced the reproductive success of birds.    Garlon is also highly toxic to aquatic life.

Finally, we provide a current and local example of the scientific evidence that native plants do not provide habitat that is superior to that provided by non-native plants.  The California Academy of Sciences finds that several years after planting its roof with native plants, it is now dominated by non-native species of plants in the two quadrants that are not being weeded, replanted and reseeded with natives.  Their monitoring project recently reported that there were an equal number of insect species found in the quadrants dominated by native plants and those dominated by non-native plants.  Where equal numbers of insects are found, we can expect to find equal numbers of birds and other animals for which insects are food.


  • The final EIR is not in a position to reassure the public that the implementation of SNRAMP will not harm wildlife because the Natural Areas Program has violated the laws that theoretically protect wildlife.
  • The final EIR must prohibit the use of pesticides known to be harmful to butterflies on Twin Peaks where the endangered Mission Blue butterfly has been reintroduced by the Natural Areas Program.
  • The final EIR must provide scientific evidence that native plants provide superior habitat for wildlife.  If it is unable to provide such evidence, these claims must be removed from the final EIR.  Without such reassurances, the final EIR must conclude that the eradication of non-native plants will have a significant negative impact on the biological resources in San Francisco’s natural areas.