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

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

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

Members of the public have commented with deep and justified concerns that the possible benefits of this project are unclear or unlikely, while the effects are significant. What is now a peaceful, historical refuge from City life threatens to become a multi-decadal vegetation removal project that would drastically alter the biological landscape of the forest, its quietness, degrade its air quality, increase greenhouse gas emissions, construction traffic and congested city parking . . . the list goes on. Yet the basic purpose and actual scope of the proposed project are not clearly conveyed, and are not compelling at all. The forest has survived countless drought cycles on its own, without this type of intrusive intervention. As a result, the lead agency may be unable to support a statement of overriding considerations to approve the project. The proposed project should be denied, and the No Project Alternative accepted.

Sutro Forest

A. CEQA Overview

An EIR is an “informational document” meant to “provide public agencies and the public in general with detailed information about the effect which a proposed project is likely to have on the environment” and “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered” the environmental impacts of a project. As an informational document, CEQA “requires full environmental disclosure.”  Although “technical perfection” is not required, an EIR must be “adequa[te], complete[], and a good-faith effort at full disclosure,” with “informed and balanced” decisionmaking. (CEQA Guidelines, § 15003, subds. (i)-(j).) “[A]n agency must use its best effects to find out and disclose all that it reasonably can.”

For each of the reasons discussed, below, the DEIR falls short of CEQA’s informational and substantive requirements, and should be revised and recirculated. In the alternative, the proposed project should be denied, as the No Project Alternative would meet the project goals while reducing or avoiding significant and unavoidable effects of the proposed project.

B. The DEIR Conflates the Proposed Project with its Attempt to Describe Existing Conditions – and so Fails to Provide Either a Legally-Sufficient Project Description or Baseline.

An accurate project description and a baseline are two legally crucial elements of the CEQA process. Furthermore, an agency can accurately describe a project’s impacts only if it accurately describes the existing environmental baseline, measuring the project’s impacts against “real conditions on the ground.”

1. The DEIR’s Stated Project Objectives are Unclear and Inadequate.

A proposed project’s statement of objectives must include the underlying purpose of the project, and be clearly written to guide the selection of mitigation measures and alternatives to be evaluated in the EIR.

Alternatives that cannot achieve the project’s underlying purpose need not be considered; “a lead agency may not give a project’s purpose an artificially narrow definition, a lead agency may structure its EIR alternatives analysis around a reasonable definition of underlying purpose and need not study alternatives that cannot achieve that basic goal.”

The DEIR summarizes the four plan objectives as follows:

1. Protect the safety of Reserve users and adjacent campus and residential properties
2. Improve and enhance the health and stability of the ecosystem
3. Enhance the visual design and aesthetic experience in the Reserve
4. Maintain and ensure public access to the Reserve

(DEIR at 1-2 [pg. 20].) Regarding the first objective, the DEIR explains that aim is to reduce “the risk of tree failure and fire through vegetation management.” (DEIR at 3-13 [pg. 77].)

However, the DEIR fails to provide meaningful information by which to understand these goals. For example, are existing forest conditions unsafe? By what measure? Similarly, are public access limitations currently a problem? The DEIR is not specific, and fails to consider whether years of significant “vegetative management” in the Forest would impede public access more so than not pursuing this project at all. Only through better-articulated project goals can the DEIR and the public meaningfully assess whether alternatives to the project would also meet project goals with fewer significant environmental impacts.

The DEIR also acknowledges that UCSF is already doing work to mitigate these risks – and will continue to do so whether or not the project is approved. The DEIR states that under the proposed project, “UCSF would continue to manage the risk of trees that may fall and injure Reserve users or damage property, and vegetation management would be focused in areas where people and buildings may be affected.” (DEIR at 2-12 [pg. 36], emphasis added.) The DEIR adds that the forest is already “actively managed” for safety. (DEIR at 4.5-1.) And crucially, it explains that:

If the proposed plan is not approved by the Regents, it is reasonable to assume that UCSF would continue to conduct ongoing maintenance in the Reserve to reduce fire hazards and hazards to people and structures from falling trees. Ongoing maintenance would include, but would not necessarily be limited to, pruning trees and bushes, removing hazardous trees, removing debris, and maintaining trails.

(DEIR at 2-14 [pg. 38]; see also DEIR 5-6 [pg 406] (under the No Project alternative, UCSF would “continue to conduct ongoing maintenance in the Reserve”).) So how can the first and foremost objective of the proposed project be to reduce “the risk of tree failure and fire through vegetation management” if the DEIR asserts that such management will happen whether or not the plan is approved? In light of the fact that the proposed project would result in significant and unavoidable impacts, and since the No Project Alternative satisfies the first and foremost objective of the proposed project, the No Project Alternative should be selected.

Unfortunately, the DEIR barely describes this pre-existing / active management program.  At one point, the DEIR describes safety assessment of trees up to 25 feet on either side of trails (DEIR 3-18 [pg. 82]), but does not describe to what extent trees have been removed based on the assessments. In those few places where the pre-existing program is described, it tends to mirror the proposed project precisely. For example, under the proposed plan, vegetation would be trimmed “within 5 to 10 feet of trails” to “allow trail users to see further into the forest.” (DEIR at 4.1-23.) But the DEIR indicates that UCSF already trims “vegetation within 5 to 10 feet on either side of trails to maintain sight lines through the forest.” (DEIR at 4.6-11.) As a result, because the DEIR barely describes the existing program of active forest management, it has failed to establish an adequate baseline.  And because core elements of the proposed project (the vegetation and tree management plan) will continue under this existing program of forest management, whether or not the proposed project approved by the Regents, the DEIR has also failed to establish an accurate project description.

2. The DEIR Fails to Provide an Accurate Stable Description of the Number of Trees Existing or to be Removed.

The DEIR’s description of the baseline conditions that are integral to the proposed project activities are inaccurate and unstable, giving rise to an inaccurate and unstable project description. A description of important environmental resources that will be adversely affected by the project is critical to a legally adequate discussion of the environmental setting. And specific information about particular characteristics of the environmental setting are be required when necessary to determine the significance of an impact.

First, a huge discrepancy exists between estimated tree numbers from previous years and the current estimates. In 2013, UCSF “estimated that there are approximately 45,000 or more trees in the Reserve.” (UCSF Mount Sutro Management DEIR (Jan. 2013) at 3-5.) The DEIR estimates there are approximately 12, 135 trees in the Reserve. (DEIR at 3-9, tbl. 3.4-1.) The DEIR fails to realistically account for this vast difference in its own calculations, whether consultants’ prior calculations were wildly inaccurate, or there were an inordinate number of trees between 1 and 2 DBH at that time. The DEIR gives short shrift to these implausible explanations, and the discrepancy casts significant doubt on the accuracy of the DEIR’s estimations and the public’s ability to rely on its description.

Second, the DEIR proposes to remove “approximately 6,000 trees predominately dead and/or dying trees” during Phase I. (DEIR at 3-24.) Yet the DEIR fails to even estimate how many “dying” trees exist in the Plan area. Unsurprisingly, the DEIR lacks a clear definition of the words “dead” and “dying” when describing trees. It merely characterizes trees with a live crown ratio of 25% or less as “dying” without recognizing that crown die-back is a normal adaptation to drought for eucalypts and many of the trees have a good chance of recovery.

The Live Crown Ratio is the ratio of the crown to the total height of the tree, simply a measure of how high the crown is. For similar reasons, this measure is of questionable value with considering eucalyptus which goes through cycles of extension and dieback. This is especially true when the eucalyptus is growing in a forest environment, where a long trunk and high crown is the natural growth habit of Tasmanian blue gum. A Live Crown Ratio of 33% would be standard, and so 25% seems well within the normal range of variability, especially during a drought. (See, “Forest
Trees of Australia” by Douglas Boland, Maurice William McDonald.)

The DEIR presents two varying estimates of the number of live trees in Forest Type 4. In Table 3.4-1, it estimates there are 50 live trees per acre and 50 dead trees per acre in Forest Type 4, for a total of 100 trees per acre. (Id. at 3-9, tbl. 3.4-1.) But in Table 3.5-2, it estimates there are 128 live trees per acre and a total of 178 trees per acre in Forest Type 4. (Id. at 3-27, tbl. 3.5-2.) The Vegetation Management Plan published in February 2017 provides the 128 live trees per acre figure. (Vegetation Management Plan (Feb. 2017) at 24, tbl. 6.) This is a significant difference. Table 3.4-1 lists 8,665 live trees in total for the entire forest. If applying the 128 live trees per acre number for Forest Type 4, the total number of live trees increases to 10,069. This is an increase of 16% and is significant with respect to the ecosystem value of the forest and impacts from removal. Given that the number of live trees impacts all of the analyses and conclusions, these discrepancies render the DEIR insufficient as an informational document.

Additionally, the “Net Trees Removed or Planted per Acre” thresholds in Table 3.5-3 are significantly higher than needed to achieve the Desired Final Stand Density in Forest Types 1, 3 and 4. If UCSF implements these maximum thresholds, then only 243 original trees would remain by Year 10. Examining Appendix 4.2 shows that at least 12,101 trees (99.8% of the current total) would be removed by Year 11 alone. This near-complete-deforestation is internally contradictory with the Plan’s stated objective to improve the health and stability of the Mt. Sutro open space reserve.

The DEIR proposes to remove over half of the live trees on the Reserve in the first year of the Plan, estimating that there are 8,665 trees in the Reserve (DEIR at 3-9, tbl. 3.4-1), but proposing to cut down a maximum of 4,640 lives trees (DEIR at 3-27, tbls. 3.5-2 & 3.5-3)—a staggering 53.5% of the live trees at the Reserve. This is a significantly high percentage and poses threats to public safety and wildlife, yet the DEIR concludes the impacts will be less than significant with mitigation. The DEIR must be amended to accurately depict the impact of its forest clearing plan.

The DEIR also fails to provide an accurate baseline description of existing tree health, relying on drought year data that ignores the extent to which the wet 2016/2017 winter may have revived trees on Mt. Sutro. According to the U.S. Forest Service, “During times of defoliation, crown dieback may be overestimated. This can be due to the difficulty of distinguishing dead twigs from defoliated ones.” On December 4, 2016, the Chief Forester of the Presidio, Peter Ehrlich, described the eucalyptus forests in San Francisco as follows: “The trees are recovering from a three-year drought. Those trees that were of moderate vigor showed recovering canopies that no longer had evidence of epicormic growth that was produced in a drought-response. This crown retrenchment was a survival strategy for some of the trees in order to cut water loss during drought. The trees are recovering due to the increased rainfall last year and early this year.” Even the DEIR admits that “the drought conditions have ended in 2017” and “future conditions are unknown.” (DEIR 3-11.) Since this is a forest with over 100 years of adaptation through numerous drought cycles, it should be permitted to recover prior to making any new and drastic vegetation management decisions. Eucalyptus in the tropical and arid areas of Northern Australia tend to get killed by termites and fire before they’re 200 years old. In temperate, rainy Southern Australia they live 400-500 years. San Francisco’s Sutro Forest is much closer to Southern Australia in climate, since it lacks wildfires and cyclones and receives rain as well as summer fog drip.

Accordingly, both the existing conditions and the project need and scope are fatally undermined without relying on more accurate data.

Finally, the DEIR wrongly claims that vegetation in the forest is “even-aged.” (DEIR at 4.1-25.) But any visitor to the forest can see—and even the photos in the DEIR show—a wide range of tree sizes and ages. (See, e.g., id. at 4.1-4, 4.1.5, 4.1-12 to 4.1-21.) This occurs in part because eucalyptus globulus can regenerate readily from lignotubers, younger trees will sprout from trees that are cut down or broken off. Over the 125-year life of the forest, it is evident that many of the trees now standing are younger.

These errors, inconsistencies, and failures to disclose important facts result in an inaccurate and confusing Plan description and baseline by which to compare the Plan’s impacts. As a result, the DEIR fails as an informational document the public and decisionmakers can rely on.

C. The No Project Alternative Should be Selected, but the DEIR Skews Decision-making by Failing to Adequately Assess the No Project Alternative.

The CEQA Guidelines require that:

The specific alternative of “no project” shall also be evaluated along with its impact. . . The “no project” analysis shall discuss the existing conditions at the time the notice of preparation is published, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.

The No Project alternative is distinct from the environmental baseline, from which the impacts of a project are evaluated.  The no-project alternative is a fact-based forecast of the environmental effects of maintaining the status quo.  When a project involves a proposed change to an existing land use plan, regulatory plan, policy, or ongoing operation, a decision to reject the project would leave the existing plan, policy, or operation in place. In such a situation, the no-project alternative should be defined as a continuation of the existing plan, policy, or operation. The EIR’s discussion of the no-project alternative then compares the impacts of the change that would result from approval of the proposed project with the impacts that would occur if the existing plan, policy, or operation remained unchanged.

The Sutro Forest DEIR addresses a No Project alternative in which the proposed plan would not be implemented, but UCSF would “continue to conduct ongoing maintenance in the Reserve.” (DEIR 5-6 [pg 406].) As a result, the DEIR expects that eucalyptus would thin and “either understory vegetation or blackwood acacia [would] colonize areas of eucalyptus dieback.” (DEIR 5-7 [pg 407].)

There are serious problems with the DEIR’s treatment of this alternative. Although it presents a No Project alternative, the DEIR describes that alternative in conclusory and pejorative terms, with little explanation.

1. With Nearly No Explanation, the DEIR Concludes That the No Project Alternative Would Lead to Significant Impacts on Visual Quality.

California courts have struck down EIRs that reject project alternatives on aesthetic grounds without providing sufficient explanation of why one alternative is visually less desirable than another. (See Save Round Valley Alliance v. County of Inyo (Ct. App. 4th 2007) 70 Cal. Rptr. 3d 59 (“If the BLM parcel is indeed an unsuitable site for the project due to whatever the County referred to as ‘aesthetic/view issues,’ much more must be said to adequately inform the public and decision makers.”))

Here, the DEIR describes the No Project alternative’s hypothetical transition from eucalyptus to understory vegetation or blackwood acacia as having significant “impacts on visual quality.” (DEIR 5-6 [pg 406].) But the DEIR does not explain anywhere why it views eucalyptus as of higher visual quality than acacia blackwood. (Neither species represents an indigenous California visual landscape; both species are transplants from Australia.1) Are eucalyptus prettier than acacia? The DEIR does not say.

In contrast, some Bay Area residents extol the visual appeal of blackwood acacia. For example, one local science writer and environmental consultant wrote that:

“I first noticed [Blackwood acacia] for its flamboyant seeds. When the pealike seed pods split open later in the year, they will reveal a shiny black seed surrounded by a wild curlicue of orange ribbon. I hate to love an invasive, but I think they are just beautiful.”

Others describe the tree as “beautiful and dependable,” possessing seeds “wrapped in an unmistakable coral-colored ribbon.” It may be the case that eucalyptus is prettier than the blackwood acacia. But it is certainly not self-evident, and the DEIR provides no justification for this conclusion.

The DEIR is also inconsistent about whether gaps in the forest canopy are appealing or not.
When it is describing the proposed project, the DEIR says that “gaps in the canopy that create patterns of sun and shade and offer views of the ocean and Golden Gate Park” are visually appealing. (DEIR at 2-2 [pg. 26].) But when it is talking about the No Project alternative, the DEIR says that “as the canopy becomes patchier” the “visual quality of the Reserve would decline.” (DEIR at 5-6 [pg 406].) It sounds the DEIR has a heads-I-win-tails-you-lose approach to aesthetics – openings in the canopy represent appealing gaps when the DEIR is describing the proposed project, but unappealing patches when it is describing an alternative.

Finally, and bizarrely, the aesthetic analysis of the DEIR’s describes the forest resulting from a No Project alternative as potentially “less alive.” (DEIR 5-6 [pg 406].) (It does not explain what it means by this.) But elsewhere the DEIR admits that “[a]lthough the dominant species in the forest may change, the Reserve would likely continue to be forest land under the No Project Alternative.” (DEIR 5-7 [pg 407].)

2. With Nearly No Explanation, the DEIR Pejoratively Characterizes a Transition from Eucalyptus to Acacia as “Forest Decline”.

Similarly, in terms of Biological Resources, the DEIR pejoratively characterizes “understory vegetation or blackwood acacia” colonizing potential areas of eucalyptus dieback under a No Project alternative as “forest decline.” (DEIR 5-7 [pg 407].)

The DEIR does not explain why a transition from mostly one species to mostly another species constitutes “decline,” but it may be based on a misreading of another section of the DEIR. In Section 3, the DEIR points out that the “condition of the blue gum eucalyptus trees has declined over the past decade” and that “[w]ithout management, it is likely that the existing eucalyptus will continue to decline and die, and other types of trees and vegetation will take over.” (DEIR 3-6 [pg 70].)

Thus, the DEIR appears to have conflated the decline of one species in the forest – eucalyptus – with the health of the overall forest. (More generally, the DEIR repeatedly employs language like this to create the image of a forest that is aged, ill, dying, and infirm. The aim may be to create the idea that the forest is not worthy of the land itself.)

In fact, California arborists praise the blackwood acacia’s role in a forest, calling it “a good choice where a large, fast-growing tree is desired.”5 Elsewhere it is described as a “durable tree for quick growth, screening and erosion control.”6 The acacia’s seed pod is “rich in protein, which makes the seed package rather appealing to ants, which consume the aril and discard the seed, in a fertile rubbish heap, or in the nest.”7

It is particularly misleading for the DEIR to describe the No Project alternative as “forest decline,” because that term is often understood to refer to the removal of trees. It is the DEIR’s proposed project – not the No Project alternative – that involves cutting down lots of Mount Sutro’s trees. (DEIR at 219, 4.1-26, etc.) As a result, if the DEIR wishes to characterize the transition from eucalyptus to acacia as “decline,” it will have to show its work. (See City of Arcadia v. State Board:  “a public agency must explain the reasons for its actions to afford the public and other agencies a meaningful opportunity to participate in the environmental review process.”) As noted, above, a Eucalyptus forest can be expected to live up to 400-500 years without human disturbances such as the proposed project.

3. Without Meaningful Explanation, the DEIR Concludes that Leaving the Forest Alone Would Have Greater Impacts Than Cutting Down Many of Its Trees.

The DEIR concludes that “the No Project Alternative would result in greater environmental impacts than the proposed plan.” (DEIR 5-10 [pg 410].) While this could be true, it is certainly counterintuitive that cutting down many or most of a forest’s trees would have less of an impact than leaving the forest alone.

The only explanation that the DEIR provides for this conclusion is to point to the seven categories in which it assesses the No Project alternative’s impacts to be higher than the proposed project – “aesthetics, biological resources, cultural resources, landslides and topsoil loss, fire hazards, emergency access, and windthrow.” (DEIR 5-10 [pg 410].)

But the DEIR acknowledges that the impacts from a No Project alternative would be comparable or less than the impacts from the proposed project in eight categories – air quality, forestry resources, greenhouse gas emissions, hazardous materials, hydrology and water quality, noise, recreation, transportation and traffic. (DEIR at 5-6 to 5-10.)

For that reason, CEQA requires more explanation regarding the DEIR’s counterintuitive conclusion that the No Project alternative would have greater environmental impacts than the proposed project. (See Guidelines: “The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project.”)

[For Part II of this article, click HERE: SF Forest Alliance: Problems in the Sutro Forest DEIR – Part II]

 

Mount Sutro Plan = Landslide Risk

The article below is reprinted with permission from the SutroForest.org website. It’s important because it discusses the issue of increased landslide risk from tree destruction on steep slopes. UCSF outlines the hazard – with a Mount Sutro map – but the mitigations are extremely inadequate.

This is relevant for Sutro Forest, but also for Mount Davidson and other areas where trees are being cut down on or above slopes.

Landslide under blue tarp. South Ridge at top left.

We’re reading the Draft Environmental Impact Report (DEIR) for the 2017 Sutro Forest Plan, and got to the section on landslide risk. This has been one of our concerns, especially since the tragedy at Oso, Washington, where the felling of trees in previous years was a factor in destabilizing the slope. (We wrote about that HERE: Cut Trees, Add Landslide Risk) We know this area is subject to landslides – we had a blue tarp covering unstable areas in Forest Knolls for a year when cutting trees destabilized a slope, and another just above UCSF’s Aldea housing area.

SHOCKING LANDSLIDE INFORMATION

We were shocked at what we found in the DEIR:
“Increased instability could cause a landslide that would impact Crestmont Drive, Christopher Drive, and Johnstone Drive. An existing landslide scarp is visible above Christopher Drive. Some homes along Christopher Drive could be placed at additional risk from localized landslides due to plan implementation. Phase I activities would result in a potentially significant impact…”

The map above is taken from the DEIR. All the dark green areas are potentially unstable. All the gold areas are potentially unstable. All the cream areas are potentially unstable. The little red blobs and stars are already unstable. The black arrows show the direction of potential landslides – right into our communities. Here’s the key to the map. The light yellow and light green areas are where they are cutting down trees in Phase I (five years, starting this fall – 2017):

Legend to Landslide Hazard Map Sutro Forest 2017

What’s the proposed “mitigation”? Avoiding work in the forest for 2 days when the soil is wet after rain. This completely ignores the fact that landslides are a MULTI-YEAR hazard after tree removal.

Here’s the proposed mitigation in their own words:
“After a significant storm event (defined as 0.5 inches of rain within a 48-hour or greater period), the following conditions shall be met prior to any vegetation management activities:

  • The maps detailing areas of historic slope instability or rock fall in the Final Geotechnical and Geological Evaluation Report for UCSF Mount Sutro shall be reviewed (Rutherford + Chekene 2013) 
  • If ground-disturbing or vegetation removal activities are proposed within or adjacent to areas of historic slope instability or rock fall, the saturation of the soils shall be estimated in the field; if muddy water drips from a handful of soil, the soil is considered saturated (Brouwer, Goffeau and Heibloem 1985) 
  • The areas of historic slope instability or rock fall shall be flagged if the moisture content of the soils is determined to be high (i.e., muddy) and ground-disturbing or vegetation removal activities shall be avoided for a minimum of 48-hours after a significant storm event to permit soil drying…”

In other words, we won’t chop down trees in the rain or when the soil is wet.

Other mitigations are palliative. They’re planning to build roads into the forest for trucks and heavy equipment, and those roads will follow the contour of the slope. The quarter-acre staging plazas – where they’ll remove trees so trucks can turn around and heavy equipment be parked – will be flattish, with a slight slope for drainage. None of this is as effective as not building these roads or bringing in heavy equipment in the first place.

WHY THE MITIGATION IS MEANINGLESS

The problem is, the effect of cutting down trees is a LONG TERM problem. The effect of tree removal takes years – not days, not months – to fix. In Oso, Washington, the slope gave way three years after the last tree-destruction. Here’s the story (from the article we published at the time). The tragedy was foreseen… but the regulators thought they had enough mitigations in place.

On March 22, 2014, a huge landslide destroyed the small Washington community of Oso. Rain was of course a factor, as was erosion at the base of the slope. But it’s probable that tree-cutting above the slide area was an important factor too. An article in the Seattle Times that quotes a report from Lee Benda, a University of Washington geologist. It said tree removal could increase soil water “on the order of 20 to 35 percent” — and that the impact could last 16-27 years, until new trees matured. Benda looked at past slides on the hill and found they occurred within five to 10 years of harvests [i.e. felling trees for timber].

There had been red flags before. The area was second growth forest, grown back from logging in the 1920s/30s. Over 300 acres were again logged in the late 1980s.

The first time regulators tried to stop logging on the hill was in 1988. But the owner of the timber successfully argued that measures could be taken to mitigate the risk. Eventually, the state only blocked it from logging some 48 acres, and the owners  gave in on that.

In 2004, new owners applied to cut 15 acres; when the Department of Natural Resources (DNR) objected, they halved the area and re-located the cut. DNR gave approval, subject to no work during heavy rain and for a day afterward. The tree-cutting finished in August 2005.

In January 2006, there was a major landslide 600 feet from the cut zone. The state built a log wall to shore up the slope.

The owners continued logging. In 2009, they removed 20% of the trees. In 2011, they removed another 15%. In 2014, the hillside collapsed.

The regulators were aware of the risk; they thought they were mitigating it with their restrictions and reaching a compromise with the owners. But it wasn’t enough. Destabilizing the mountainside is a long-term thing; the effects can show up in months, but it’s more likely to take years.

THE LESSON FOR MOUNT SUTRO

Our mountains not only are potentially unstable, they actually have landslides. The picture at the end of this article shows one on Twin Peaks, where rocks tumble after nearly every heavy rainy season.

The roots of the trees are helping to hold the unstable soil in place and that as the roots rot, landslide risk will increase.  It is going to be more unstable 2-3 years after the trees are removed than 2 days after it rains.  The information that instability increases over time is a little counter-intuitive.

Moreover, removing the trees takes away their ability to suck water out of the soil. If the tree-cutting is done in dry years, it may take a wet winter to trigger landslides… which would not have happened if the trees had been regulating the water and functioning as a living geotextile.

Since UCSF are not going to use herbicides on the stumps to prevent them from resprouting, they say they will grind the stumps.  That is an effective way to prevent resprouting, but it will greatly increase the instability of the soil because the heavy equipment digs down several feet into the stump to destroy the roots.  That’s another reason why they should not destroy trees where slide risk has been identified.

Anyone seriously considering the map above can only hope that UCSF will draw a better conclusion than the Washington State loggers and regulators. The planned destruction of thousands of trees – many within the first five years – could cause landslides in surrounding communities not days or months later, but years after the event.

UCSF: First, do no harm!

Here’s the Sutro Forest DEIR (issued July 2017)

For those readers who would like to get started on reading the Draft Environmental Impact Report for  Mount Sutro Open Space Reserve, we have it here as a PDF:

UCSF_Mt_Sutro_DEIR_wAppendices

SF Fire Department Busts Some Myths

Deputy Fire Chief Mark Gonzales smRecently, Supervisor Norman Yee called a hearing of the Government Audit and Oversight Committee to find out how prepared San Francisco was to deal with fires in brush and forest. The San Francisco Fire Department busted some myths we’ve heard all too often.

MYTH #1:  The forests of San Francisco – in particular those on Mount Sutro and Mount Davidson – are a fire hazard.  Vegetation fires are 12-13 times more likely to occur in grass and brush than in forests. And importantly –  in the north and west of the city, the fog protects it by adding moisture. The south-east is more vulnerable to vegetation fires, particularly around the freeways. (But the real fire danger in San Francisco is from structure fires because of closely-placed wooden houses, not so much from vegetation fires.)

MYTH #2: As city fire-fighters, SFFD wouldn’t know how to respond to a forest fire. Actually, SFFD have 200 fire-fighters trained to fight vegetation fires. This myth is a quarter-century out of date.

MYTH #3: SFFD doesn’t have the equipment or information to fight vegetation fires. Actually,  SFFD has special resources including four maneuverable “mini-pumpers” for fighting outside fires. And it has a mutual aid agreement with other cities and can call on their resources if needed.

MYTH #4: San Francisco’s Wildland Urban Interface is a very high fire hazard severity zone. No, it’s not. It’s not technically a Wildland Urban Interface (though there are some pockets) and the whole of San Francisco has a “moderate” fire hazard severity rating (that’s CALFIRE’s lowest rating).

We attended the hearing, and were impressed by SFFD’s well-planned arrangements. After an introduction from Supervisor Norman Yee who convened the hearing and Fire Chief Joanna Hayes-White who stressed that SFFD was prepared for vegetation fires, Deputy Chief Mark Gonzales gave a detailed presentation on where they happened and how SFFD handled it. This was followed by a talk about  prevention from Lieutenant Mary Shea, (mainly weed-abatement in vacant lots and similar). The Department of Emergency Services’ Bijan Karimi  described preparedness,  to help affected families stay safe and return to normalcy in the event of any disaster. Then Curtis Itson, UCSF’s fire marshal, spoke specifically about Sutro Forest, and finally there were some comments from the public – including a singer!

WHERE THE OUTSIDE FIRES ARE

San Francisco’s main concern is actually more with structure fires, because as Deputy Chief Gonzales said,  “…we have wood buildings in the districts, and they’re all next to each other.”

However, there are some calls for outside fires. They tend to be concentrated around the south and east of the city. Because of the fog, the north and west of the city (i.e., areas that include Mount Sutro Forest and Mount Davidson) are generally moist and not a concern. The focus for outside fires is in the drier South east part of San Francisco: Hunter’s Point, McLaren Park.

grass and outside fire calls - SFFD

From the presentation by Deputy Chief Mark Gonzales:

“… we have fog and even during the drought the rest of the city, the west and the northwest gets the fog. The best weather is in Hunters Point, southeast, so that’s where it’s driest.  One of the concerns is Mclaren park.  So the four mini-pumpers are in that area. We have front line stations in the city.  A lot of those companies have been trained in wild land operations, and the chief mentioned that we have over 200 firefighters that do that.”

The open weedy area around freeways are also a concern. Thrown cigarettes and occasional campfires may account for ignition. He said: “…actually there is a big correlation if you noticed near the freeways… all along and open patches of lands that we respond to, to knock those out.”

When there are vegetation fires, they are mostly in grass and brush. The data the Deputy Fire Chief showed indicated that in the last three years,  fires in grassland and/or brush were 12-13 times more likely than fires in forested areas/ wild lands.

He also pointed out that SFFD did have the resources to fight vegetation fires:

  • Four “mini-pumpers” – small maneuverable trucks for fighting outside fires (as well as operating in crowded conditions). They can go off-road and carry special equipment for fighting vegetation fires.
  • Two hundred firefighters with training in fighting vegetation fires, unlike 20-25 years ago when it had few if any. In fact, 30 of SFFD’s people were deployed to help fight the Butte fire and the Valley fire in other parts of California.
  • There’s a mutual aid arrangement in place that would allow SFFD to call for help if it faced an outside fire it could not control with its own resources. The people it would call on would be at least as well-trained as SFFD’s own fire-fighters – possibly more so because they are from hotter less built-up areas where they experience more outside fires.

NOT A WILDLAND URBAN INTERFACE, AND ONLY MODERATE HAZARD

Lieutenant Mary Shea, who is responsible for Prevention, started by pointing out that San Francisco was not technically considered a Wildland-Urban interface, though there were pockets that appeared so.  She also said that based on topography and fuel, CALFIRE considered San Francisco a moderate fire hazard area, not a high fire hazard zone. [“Moderate” is actually CALFIRE’s lowest rating.]

 not WUI fire area
Her prevention efforts therefore  focused on overgrowth of weeds, grass and vines,  30-foot defensible spaces, tree-limbs within 10 feet of chimney outlet, buildup of leaves or pine needles on roofs.

SFFD weed abatement program

They mainly responded to complaints from neighbors, perhaps half of which were justified and the remainder were people disgruntled with the next-door tree overhanging their house or yard. They usually sent out abatement notices two weeks before 4th of July. Owners usually complied and most yards were well-maintained – the owners didn’t want fires, either. The main problem was in abandoned properties where the neighbor could not be found, or people unable for some reason to maintain their homes. SFFD worked with such cases to ensure safety. Most notices came from Hunters Point/ Bayview around the freeways, and Bernal, places like that.

UCSF MAY DO ANOTHER ROUND OF “FIRE HAZARD REDUCTION”
Chief Joanna Hayes-White praised UCSF for the “fire safety” work 2 years ago, and they said they would be reviewing it this fall. She talked about defensible space and fuel reduction.

UCSF’s  fire marshall, Curtis Itson, emphasized that UCSF has a commitment to keep buildings, visitors, and nearby neighborhoods safe.

In comments, we pointed out that given the fog and the way the vegetation trapped moisture, we needed to be careful that we did not increase fire hazard by reducing the forest’s ability to retain moisture.

More important public comments:

  • In the parks and Golden Gate National Recreation Area, native plant interests are felling trees and substituting more-flammable native plants for fire-resistant non-natives like trees and ice-plant. These landscape transformations increase fire hazard.
  • Trees are a lot less flammable than the myths say. In the parks,  trees are felled and left on the ground as fuel, while toxic herbicides are in use. SFRPD’s forest management needs improvement.
  • Someone  talked about dying trees as fire hazards along O’Shaughnessy, and a singer sang that it would be alright.

If you want to view the hour-long hearing, here’s the LINK.

Mount Sutro Forest Isn’t Diseased or Dying – It’s Natural

This post is reproduced, with permission and minor changes, from SutroForest.com

sutro forest canopy June 2014 sm

CRYING WOLF WITH BEETLES

In the Sutro Stewards blog last month, Craig Dawson (who is its Executive Director) wrote a post claiming that the forest was in dire straits, infected with funguses and beetles: specifically, Anthracnose, armillaria, phytopthora, wood decay fungi, the snout beetle and the tortoise beetle. It concluded: “The bottom line is that we cannot expect much of the declining forest to recover from the condition it is currently found in, rather we can expect further widespread die-off. The dying trees will quickly pose a significant hazard within a year or two as we have already witnessed.”

It sounded alarming.

We sent the link to the article to a number of experts. None of them thought it was particularly serious. (One academic ecologist called it “…pure twaddle…” ) Nor did they agree with its conclusion that the forest would therefore decline.

  • “The diseases and insects mentioned in the Sutro report could be found in any forest…” (from a certified arborist and plant pathologist)
  • “The description of common conditions of eucalypt trees on the part of Mr Dawson’s piece seems to me solid as such—a description—but unconvincing as an argument that pretends to show some state of pathological emergency in Sutro…” (from an environmental science professor)
  • “This is amateur plant pathology at its best….” (from an urban forester)
  • “…faith-based botany…” (from an urban forester)
  • “This is certainly not the first time I have seen someone want to use a disease threat as a roundabout way to get some politically inconvenient trees removed.” (from an academic plant pathologist)

THE SPECIFICS

Some commented specifically on the individual fungi/ beetles. We also investigated ourselves, using the UC Davis website.

  • Anthracnose: “anthracnose is found on the leaves of many plants…” [In San Francisco] “sycamore leaves are filled with anthracnose…” (We would also note the UC Davis website says, “In California, anthracnose rarely causes permanent damage to plants except for elm trees.”)
  • Armillaria: “…definitely all over the place in the coast ranges and is even rampant in Golden Gate Park.” (This does not indicate a dire disease requiring intervention, especially tree-felling.)
  • Phytopthora: We could find no references to phytophthora in eucalyptus in California.
  • Wood decay fungi: “..these are mostly associated with older trees. The pictures represent Trametes versicolor – mostly found on dead wood, very rarely on living trees; Laetiporus gilbertsolnii – common on living Eucalyptus and oaks…” (Again, there’s no indication that these are reason for alarm.)
  • Eucalyptus snout beetle: These beetles feed on eucalyptus leaves. According to UC Davis’s website, “Eucalyptus snout beetle is controlled biologically by Anaphes nitens, an introduced parasitic wasp. No further control is necessary.”
  • Eucalyptus tortoise beetle: Also a leaf feeder, these beetles don’t usually kill trees. From the UC Davis website: “Unsightly, tattered leaves are usually just an annoyance that does not appear to threaten eucalyptus survival or health.” Since some tattered leaves in a forest setting are quite natural, we don’t think this is a problem.

Following a recent walk through Sutro Forest, Dr McBride (Professor Emeritus, UC Berkeley) noted that the forest looked healthy and thriving, with no evidence of the feared decline. He pointed out that in a naturalized setting like this one, we should expect some number of trees to do poorly or even die, as the forest “self-thins.” Furthermore, he said, without fungi and other creatures as part of the forest ecosystem, we’d be up to our eyeballs in dead logs.

fungus on a stump - sutro forest - june 2014

We have to say that in our years of frequent walks in the forest, in all weather and at all times of the year, most of these fungi and beetles are rare. Rare enough, in fact, that when we see fungi or mushrooms (the fruiting body of some fungi) we take pictures. We found a few leaves with evidence of tortoise beetles (semi-circular “bites” from the leaves), but they were few and far between. So far, we have not been able to find leaves showing the elongated perforations made by snout beetles.

few leaves have beetle holes

We asked about hollow trees. Dr McBride said that unless the remaining wood is less than 30% of the diameter, hollows in trees did not weaken them. “A tube is structurally one of the strongest forms,” he said. The life of a tree is in its outer layers. The center of a tree essentially provides structure. (And – hollow trees are great wildlife habitat.)

WHAT ABOUT THAT CANOPY?

The Sutro Stewards article also includes a picture of a stand of trees with a defoliated canopy, implying that is typical of the forest. It is not. This picture at the start of this article, taken in June 2014, is actually much more representative of the conditions in Sutro Forest. (Here’s a picture of the forest taken from Twin Peaks.)

sutro forest from twin peaks - June 2014

The stand portrayed in the article does exist. It is on the lower part of the East Ridge – right above an area where UCSF has removed a lot of trees and understory as part of their “fire hazard” action in August 2013. This has made the forest there much drier and less able to retain moisture – particularly since this is on a steep slope near the edge of the forest. Dr McBride considers that the trees’ intergrafted root system may also have been damaged during the work, making the stand much more vulnerable. However, the trees do seem to be recovering, currently with epicormic growth.

gradually recovering defoliated eucalyptus on east ridge of sutro forest

CAUTION: DON’T MESS WITH THE FOREST

But rather than indicating that the forest is diseased and trees should be removed, it suggests much more caution. The removal of smaller trees and understory and damage to root systems can stress trees, reducing the moisture available and increasing wind damage. Instead of making the remaining trees more healthy by “releasing” them, it can make them less healthy – as we see on the lower part of the East Ridge. Similar impacts are visible in Glen Canyon, where a lot of clearing has been going on – exacerbated by pesticide use.

Furthermore, with the normal fungi present, and with the usual damp conditions in this cloud forest environment, chopping down trees doesn’t help reduce fungi, it only spreads it around.

Mt Sutro Hike by Tony Holiday

Tony Holiday, a San Francisco hiker and blogger, recently hiked Mt Sutro from the Stanyan steps to the summit and back down to Parnassus. (Go to his blog, Stairways are Heaven, for more hikes and photographs.) This photo-essay is one of our Park Visitor series – first-person accounts of visits to our San Francisco Natural Areas and wild lands. It’s abridged (and published with permission) from the original post,  Stanyan Trailhead to Summit, on Stairways Are Heaven. (We’ve made some minor edits to the captions to clarify them for those unfamiliar with the forest.)

Started off this very pleasant Mount Sutro hike first uphilling from Parnassus  to Stanyan & 17th for the trail head of the lower Historic Trail…

Trailhead with steps up to Sutro Forest from Stanyan

Entrance to the “lower Historic Trail,” which starts in the Interior Green Belt – city-owned property that comes under the Natural Areas Program of SF Rec & Parks.

Interior Greenbelt’s lower Historic Trail

Continuing on the Lower Historic Trail in Mount Sutro Forest

At some point, the trail crosses from the Interior Green Belt into UCSF’s “Mount Sutro Open Space Reserve.”

… then from the lower Historic Trail, up to Medical Center Way, crossing over to the East Ridge Trail …

Medical Center Way, the paved road that runs through the forest and connects the Aldea Student Housing with Parnassus

…  and up to the summit (where I saw this flower).

Flower on the summit of Mt Sutro

Going down from the summit I went down the North Ridge Trail.

Starting down from the summit on the North Ridge Trail

North Ridge Trail, nearly down to Medical Center Way

I’ve used this convenient short stairway many times from Medical Center Way to the parking lot so as to descend the wood-railed stairway to its foot, then out to Parnassus. (But you can easily just walk downhill to the lot too.)

Shortcut stairway down to parking lot

There are around 136 steps from the parking lot down to Medical Center Way behind the hospital buildings.

Steps down from Parking Lot

Stairway overlooking UCSF buildings

Stairway connecting parking lot and UCSF

Stairway seen from the bottom (with acacia trees that that form the subcanopy of the forest)

You’ll probably see medical personnel ascending and descending this stairway, but it’s okay for hikers to use also. I’ve been doing so for years.

ABOUT THE AUTHOR

Tony Holiday likes meandering around on San Francisco’s park trails and public stairways, sometimes taking photos, and enjoying nature and the outdoors.

UCSF’s “Urgent Fire Safety” on Mt Sutro – How True?

Our readers have been following the story of Sutro Forest, the beautiful Cloud Forest that lies in San Francisco’s fog belt. It captures moisture from the marine layer fog, and is thus wet all through the summer and into the Fall, which protects it from fire-hazard. In January 2013, UCSF issued a Draft Environmental Impact Report (DEIR) on a Plan threatening to cut down 90% of the trees on 3/4 of the Mt Sutro Open Space Reserve.

Until recently, we understood that the tree-felling had been postponed to 2014, as UCSF needed more time to respond to the detailed and voluminous public comments on the DEIR.

Mt Sutro Forest, Sept 2013 (Photo: SutroForest.com)

Then UCSF sent out a notice that it would be performing “urgent fire safety work,” felling over 1000 trees and mowing down understory on Mount Sutro in response to San Francisco Fire Department (SFFD) having provided an “independent assessment of the Reserve.” (We reported on that HERE.)  On its own website announcing it had completed work, UCSF says, “The measures, which began Aug. 26, are in response to an assessment this summer by the San Francisco Fire Department that found “extra hazardous fire conditions” in the urban forest.”

All of this creates the impression that SFFD came in, took a close look at the forest, and found “extra hazardous conditions” – and that UCSF’s actions were in response.  But is that what really happened?

EXTRA-HAZARDOUS = 100 FEET

The determination that fire conditions are “extra-hazardous” is important. If they’re just the normal fire-risk, then the required clearance to structures is 30 feet. If it’s “extra-hazardous” then it’s 100 feet.

At 30 feet of clearance, UCSF would need to do very little: This amount of clearance already existed in most places.  But by declaring it “extra-hazardous” UCSF decided to clear understory and slender trees on around 20-25% of the Mt Sutro Open Space Reserve.

The discussions about Sutro Forest have been going on since about 1995. Right now, there’s a Draft EIR on a Management Plan being processed. This sudden August 15th UCSF notice planned to start work within 10 days, without any public meeting or discussion, or reference to the California Environmental Quality Act (CEQA) because it addressed “immediate fire safety and emergency concerns.”

So of course we were very interested in just how the extra hazard – and emergency – had suddenly been decided.

INDEPENDENT ASSESSMENT?

UCSF claimed an “independent assessment” by the SF Fire Department (SFFD).  But was it?

Under the Sunshine Act, we obtained documents from SFFD, covering the correspondence between UCSF and the San Francisco Fire Department. It demonstrates no independent assessment nor any evidence of “extra-hazardous” fire conditions at that time.  It appears that UCSF, finding its efforts to start gutting the forest this year had been stymied by the overwhelming public opposition to its Draft EIR, decided to do an end run around CEQA.

  • SFFD had not independently expressed any concerns about fire hazards on Mount Sutro.  UCSF tried to get them to come to Mt. Sutro and tell UCSF to cut down trees.  That apparently didn’t happen.
  • Then UCSF drafted a letter for SFFD saying there were extra-hazardous conditions requiring the 100-foot clearance.
  • Only after our Public Records Act request revealed that SFFD had been used to get around CEQA, after the public had been told that SFFD had made an independent assessment, on the very day that cutting started, did SFFD perform an after-the-fact walk-through of Mount Sutro to justify what was being done.

TIME-LINE

Here’s the timeline:

  • 13 June – 10 July 2013:    UCSF tried to get the San Francisco Fire Department (“SFFD”) to come to UCSF to do a fire hazard inspection on July 11th. There’s no record that the meeting ever happened.

(This is a PDF of email correspondence apparently trying to set up such a meeting – but no evidence or acknowledgement that it occurred. Please note UCSF labeled them ‘Attorney-Client Privileged’ – even though they are not. This looks like they’re trying to prevent the public from seeing them. Email messages July 2013 (UCSF-SFFD) )

  • 23 July 2013:   UCSF drafted a letter for SFFD’s signature stating that “SFFD has determined that 100 feet of fuel clearance for structures is required due to extra hazardous fire conditions.” (There was no substantiation of these “extra-hazardous conditions. Without them, a clearance of 30 feet – which already existed in most places – would have been sufficient.)

(Here’s the PDF of correspondence between UCSF and SFFD indicating that UCSF provided the draft letter: UCSF – SFFD emails July 2013 )

  • 27 July 2013:   Due to overwhelming number of comments on the Draft Environmental Impact Report opposing felling trees on Mount Sutro, UCSF announced that it would not be able to complete responses and hold the hearing approving the EIR in time for work to begin in 2013, and this would be postponed to 2014 after the bird-nesting season (around mid-August).
  • 14 August 2013:  UCSF sent out a public notice that it would begin tree removals on August 26, and attached the SFFD letter (which had been drafted by UCSF) as justification.
  • 20 August 2013:  San Francisco Forest Alliance sent SFFD a letter demanding immediate disclosure of all records pertaining to fire hazards or assessments of fire hazards on Mt. Sutro.
  • 23 August 2013:  SFFD provided no records of any fire assessment on Mt. Sutro, and only produced one document showing that UCSF had scheduled a tentative Mt. Sutro site visit on July 11th  (and no evidence or assurance that this site visit had occurred).
  • 26 August 2013:  (1) “Urgent fire safety” work started. (2) On the same day, the day tree-felling began, SFFD actually did a site inspection of Mt. Sutro. This was reported in a letter to UCSF dated August 29th, when the work was well under way. Clearly, it was after the fact, and not independent. The inspecting contingent included several UCSF staff.  From SFFD, it apparently included Fire Chief Joanne Hayes-White together with several other SFFD staff. Most of the letter details the work that is being done – all of which is apparently based on UCSF-provided information. The “independent assessment” is one paragraph of generalities, describing conditions that have been unchanged in at least the last ten years, and don’t therefore substantiate any “emergency.” That letter is HERE. SFFD Aug 29 letter to UCSF

Is it possible that this letter, too, was drafted by UCSF? We don’t know. If we find out one way or the other, we’ll publish it here.

In any case, SFFD has clearly provided this support as a courtesy to UCSF, and there has still been no independent substantiation of the ‘extra-hazardous’ conditions throughout the areas where the “work” was performed. Or of any emergency.

BEFORE picture in Sutro Forest. (Photo: SutroForest.com)

AFTER picture in Sutro Forest. (Photo: SutroForest.com)