Pesticide Use in San Francisco Natural Areas Creeping Up Again – Oct 2017

We’ve received the pesticide usage reports for the first ten months of 2017, and we’re concerned. After reducing herbicide usage in the last four years, it’s creeping up again in the natural areas. The Natural Areas (now called the Natural Resources Department) has already used more herbicides (measured by active ingredient) than in all of 2016. It hasn’t reached 2015 levels, but park users hoped for further reduction, not an expansion in herbicide use.

San Francisco’s Department of the Environment runs the Integrated Pest Management (IPM) program for city-owned properties in San Francisco. It publishes an annual list of permissible pesticides, and classifies them into Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous.)

The unnaturally-named Natural Resources division (NRD) of the San Francisco Recreation and Parks Department (SFRPD) used more Tier I  herbicides than the rest of SFRPD put together (excluding Harding Golf course, which is managed under a separate PGA contract – but including all the other city-owned golf courses). In fact, in the first ten months of 2017,  NRD used 69% of the Roundup and 100% of the Garlon used by SFRPD.

The parks mainly targeted thus far were:

  • Twin Peaks (sprayed 32 times);
  • Glen Canyon (sprayed 27 times);
  • McLaren Park (25 times);
  • Bayview Hill (14 times); and
  • Laguna Honda (PUC property – 13 times).

Other parks that got sprayed over five times in ten months were Mt Davidson (8 times); Marietta (a PUC property – 8 times); and Lake Merced, also 8 times.


We especially noted that its usage of glyphosate (Roundup/ Aquamaster) has nearly doubled from 2016 (i.e., in ten months, NRD used nearly twice as much glyphosate as in the whole of 2016).

This is particularly worrisome since Roundup probably causes cancer. We wrote about that in these articles: World Health Organization: Roundup “Probably Carcinogenic” and in this report from an EPA scientist before she died reported on problems with pesticide assessments: “It is Essentially Certain that Glyphosate Causes Cancer”

This is the first time since the report came out we’ve seen an increase in its use.


The other major Tier I pesticide being used is Garlon 4 Ultra (triclopyr). NRD is the only section of SFRPD that uses this chemical, which has been considered Most Hazardous and HIGH PRIORITY TO FIND ALTERNATIVE at least since 2009. It’s twenty times as harmful to women as to men. (Here’s our quick presentation on the subject: Garlon v. Oxalis in Ten Easy Slides.)

NRD uses this on oxalis, an early spring-flowering plant beloved of children, pollinators, and wildlife – and the general public, who enjoy its bright blooms as a sign of spring. It’s the only use of Garlon by NRD, and if they abandoned the vendetta against these Bermuda buttercups, they would not need to use this awful pesticide.


Meanwhile, there’s a new city-wide war on a naturalized species: against arctotheca, or Cape Marigold. It’s another yellow-flowering plant that grows all over our city’s parks, and it’s on the list of 40 species (and counting) that the NRD wants to poison.  Here’s a picture from McLaren Park (together with Great Blue Heron that’s probably hunting gophers).

Cape Marigold occurs in both a fertile and an infertile form; both are considered only Moderately invasive by the California Invasive Plant Council – as is oxalis.

Unless NRD changes its approach and objectives to naturalized species of plants – and recognizes the need for inclusiveness in natural areas – there is little likelihood of eliminating pesticides from our parks. Aggressive management will inexorably result in increased herbicide use.


By contrast, the rest of SFRPD (excluding Harding Golf Course) seems to be on track to reduce usage again from 2016. For which kudos!

[Edited to Add: The graph below was corrected to indicate the last column shows usage only through Oct 2017, not the full year.]

The only department besides Natural Resources to regularly use pesticides is the Golden Gate Nursery. They wish to make sure the nursery stock they supply is pest-free before propagating it. This is less of a concern than NRD for several reasons: It’s not a public space, usage is confined in a small area and not on parks and hillsides where chemicals could spread to other areas.

We are concerned, though, that they are experimenting with several herbicides that were not earlier on SF Environment’s list: Axxe, Suppress, Clearcast and Finale. They are all considered Tier II, according to Dr Chris Geiger of SF Environment’s IPM.

Of these Axxe and Suppress seem to be less harmful. Suppress is considered acceptable for organic farming.

Clearcast is more concerning, as is Finale. You can see the Clearcast Label here: clearcast_Label.pdf 2016

Here’s the Finale Label: finale_msds

Both these pesticides have cautions regarding potential harm from immediate exposure. We will further research them, but more than the specifics, we’re concerned at the direction. Rather than working to eliminate herbicides from our parks, SFRPD seems to be looking for substitutes for Roundup. Thus far, these two chemicals have been used only in Nursery areas – the GGP Nursery, and the nursery at the Botanic Gardens.

SFRPD now has five Integrated Pest Management Specialists (compared to one before). This is good news to the extent that they will be working on mosquito abatement and alternatives to rat poisons. It’s bad news if it encourages SFRPD to open new battle fronts (like the war on Cape Marigold), or increase use of herbicides in the water, rather than changing its approach to eliminate pesticides in our parks. Here’s the note about their activities from an October meeting of SF Environment’s Policy Committee:  102317_attachment_c_-_agency_ipm_updates_for_2017

SF Forest Alliance reiterates our commitment to working toward No Toxic Pesticides in our parks. We recognize that it will be an uphill battle, as all current interests are in continuing pesticide use. Nevertheless, we believe that it is possible and is a worthwhile and environmentally-friendly goal for San Francisco.




Pesticides in our Parks – Bernal Hill

The Natural Areas program (now called the Natural Resources Department) regularly uses herbicides in many of our parks. We’ve published pictures before of Glen Canyon and Mt Davidson.

This time, it’s Bernal Hill.

This hill apparently needs herbicides.

So they’re putting Polaris – that’s imazapyr – on the blackberry and cotoneaster.

It takes a five-person team.

[Edited to Add this section about the famous Bernal Hill Blackberry Patch.]


Hope they don’t take out the famous Bernal blackberry patch that’s brought so much joy to families.

It’s a thing, and has been for years. Here’s a 2008 article called Bernal Hill Blackberry Bonanza.  And here’s a quote from a 2009 article in the SF Chronicle, indentifying hidden treasures in San Francisco: ‘Bernal Hill Blackberry Patch. “The locals might hate us for sharing this, but there is a huge wild blackberry patch on the north side of Bernal Hill where we forage pounds and pounds of berries every summer for jam-making. So delicious.”‘ And the Bernalwood blog hailed the start of the blackberry season in 2012 in It’s Official: Blackberry Season Under Way in Bernal Heights

SFRPD – people love blackberries, and Bernal has the best crop in the city!

San Francisco Forest Alliance stands for no pesticides in our parks. We also hope that SFRPD will respect public resources that people love.

Coyote, Playing!

Sometimes, we want to bring our readers some of the joys of our parks, not just the threats to them. Besides being our green spaces and forests, they are the habitat for all kinds of wildlife.

Watch this happy coyote having fun with a ball and a stick! It’s a delightful 3 1/2-minute short film by Wildlife photographer and coyote champion, Janet Kessler, who has spent the last ten years observing and documenting coyote behavior in our parks. It was shown at the Bernal Heights Film Festival, and is linked here with permission.

When we asked if we could use it, Janet had a message for us: “These animals need their habitat left alone. They need the thickets — that are being removed and thinned by the Natural Areas Program — as safe-havens and harborage areas.”

[The Natural Areas Program has renamed itself the Natural Resources Department.]

Trees Cut Down in McLaren Park with No Warning

One of our readers has this news about trees being cut down in McLaren Park. The destruction has just begun. We’ve published letters in defense of McLaren’s trees before. See Trees Matter: McLaren Park and Environmental Justice.


— xxx—

Sept 14, 2017

San Francisco Recreation and Parks Department (SFRPD’s Natural Areas Program has started cutting trees in support of their trail plan for McLaren Park.  So far 15 Monterey cypress and eucalyptus trees have been chain sawed around Brendt’s Knoll (a.k.a. Philosopher’s Hill, a.k.a. Labyrinth Hill) to make way for their new trail.  This is despite the fact SFRPD has not even presented their final trail plan to the public.

Further, the Natural Areas Management Plan states that, “any removal of trees over 6 inches in diameter at breast height (dbh) requires coordination with, and evaluation by SFRPD’s Arborist.  In addition, prior to any tree removal, individual trees measuring 6 inches dbh or greater must be posted for 30 days (Section 1).”  Most of the trees cut down were larger than this and none of them were posted.

This just demonstrates, once more, SFRPD’s disdain for the public and disregard for the law.

The fact they cut down so many trees for just a short stretch of trail confirms our worst suspicions.  Their broad straight trails will not wind through the trees as today’s trails do, instead they will blaze a path of destruction through our forests.

Contact your supervisor and the Park Commission and let them know this is unacceptable.

— xxx—

Here’s the email of the Parks Commission:  and Telephone: 415-831-2750
Here’s a current list of the emails of the Mayor and the Board of Supervisors.,,,,,,,,,,,


San Francisco Pesticides and “Inaccessible Areas”

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

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

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


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

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

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

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

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

See the email exchange below for additional information..

Thank you for your attention to this matter.

Tom Borden


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

This is a Sunshine request.

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

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

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

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

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

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

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


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

Thanks, Tom

Anthony responded:

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

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

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

Anthony E. Valdez, MPA
Commission Secretary

That sounded encouraging. Just to confirm, though…

Thanks Anthony and Chris,

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

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




He followed up with another email.

Chris and Anthony,

In your July 12 email to me you say:

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

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

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

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

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

Looking forward to your reply,

Tom Borden
415 252 5902

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

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

What’s Wrong with the Natural Resources Management Plan

This letter by Anastasia Glikshtern was published in the Westside Observer. It’s a response to an article by Glen Rogers that lauded the certification of the Environmental Impact Report on the Natural Resource Management Plan. Ms Glikshtern’s letter, which points out the damage the Plan will do as well as factual errors in the original article, is republished here with her permission.

Glen Rogers hails the certification of the biased, inadequate, and inaccurate Environmental Impact Report for Natural Resource Management Plan and adoption of that Plan as “a victory for conservation.” (Love ‘Em Or Hate ‘Em, Eucalyptus Trees Still Remain At Center Of Controversy, Westside Observer, February 2017)

In fact, the Plan is to cut down 18,500 trees (plus uncounted smaller ones) at the cost of $5.4 million a year for 20 years (SF Legislative Analyst, 2007), most of them on steep slopes, many in windy areas, some near freeways – to convert “forested areas to native scrub and grass habitat…”

The plan is to treat the stumps of killed trees with most toxic herbicides – so the herbicide use would drastically increase. Some people have the nerve to call this “conservation.”

Mr. Rogers states that in Sharp Park “the non-native grass of the golf course requires pesticides, herbicides and fertilizers which are affecting wildlife and tainting nearby water, causing genetic mutations….There have been numerous incidents of endangered wildlife being killed by mowing the lawn or gopher control.”

In fact, no pesticides or herbicides have been used in Sharp Park since August 2010. The five fertilizers used there are OMRI (Organic Materials Review Institute) Listed. In response to a Sunshine Records Request, I learned that there are “no records of deaths of red-legged frogs or garter snakes, or their juvenile equivalents, or their eggs or egg-masses, as a result of the operations and maintenance of Sharp Park” in last 10 years.

Mr. Rogers writes that alleopathy is “the agent that poisons the ground” and “inhibits other plants from growing under eucalyptus.”

In fact, alleopathy is a biological phenomenon by which an organism produces one or more biochemicals that influence the germination, growth, survival, and reproduction of other organisms. These biochemicals can have beneficial or detrimental effects on the target organisms. As an illustration of “native” vegetation under eucalyptus I’m attaching a photo of “native” toyon under “non-native” eucalyptus (Albany Hill).

There are five little oak trees (little, although they are already 10 years old)  growing next to the 36 bus stop at Myra Way / Dalewood Way intersection. Most likely they are doing so well in this area because of protection provided by big eucalyptus trees under which they grow.

Mr. Rogers blames (spectacular) lack of success in “the reintroduction of native plants” on eucalyptus trees. He ignores the Pacific reed grass – a species that the Natural Resources Program wants to protect – that is indeed growing under eucalyptus, and which is frequently associated with these trees because of the moisture they provide.

In fact, the same lack of success in reintroducing native plants can be observed on the grassy part of Mt. Davidson and in other “natural” areas. It is most likely due to the changes in the environment since the time (about 250 years ago) when the “desirable” (by Natural Resource Division) vegetation had allegedly grown here.

(I’m attaching a photo of French Broom on a trail in East Bay after 10 years of eradication effort.)

French Broom thriving along a trail - after 10 years of eradication efforts

French Broom along a trail – after 10 years of eradication efforts

Mr. Rogers cites a study stating that 85% of the 18,500 trees slated for elimination are in poor health – and therefore might burn down within the next 100 years.

In fact, that (questionable) study looked at a very small number of trees on the edges of Mt. Davidson. The sweeping conclusions are erroneous, and there are experts’ statements to the contrary. Moreover, the 2015 presentation by SFFD stressed that vegetation fires are 12-13 times more likely to occur in grass and brush (to which many of our forested areas are to be converted, according to the plan) than in forests, and the real fire danger in San Francisco is from structure fires because of closely placed wooden houses.

Mr. Rogers asks readers to remember eucalyptus trees that fueled the fire in Oakland.
The readers might also remember that the Oakland fire started in dry grass, that there were many reasons why it became so destructive, or that the wildfires in California are fueled by “native” trees.

While Mr. Rogers’ main concern on Mt. Davidson is the “prevalence of non-native species,” for many Mt. Davidson neighbors the main concerns in connection with pending implementation of the plan are very different:

  • The threat of the mudslides on newly deforested part of the mountain. (Mudslides have already been happening on the grassy part during the rainy seasons);
  • The threat of flooding;
  • Increased wind and noise;
  • Drastically increased use of the most toxic herbicides (particularly in view of the groundwater blending into our tap water;)
  • Destruction of wildlife habitat.

One-third of the currently forested area on Mt. Davidson is destined to be converted to grass and scrub.

Anastasia Glikshtern lives near Mt. Davidson


Where Did The “Natural Areas Program” Come From?

The Natural Areas Program – now renamed the Natural Resources Areas Program – has been controversial almost from its initial stages. It’s been opposed on scientific and community grounds since then. But critics have generally been ignored.

Many of our supporters have only recently joined the fight to save our parks from the tree-felling, toxic herbicides, and access restrictions that the Natural Resources Division brings. For them – as well as those who would like to know more about this program – we republish (with permission and a few edits and updates) a detailed article from the sfdog website, first published in 2011.



The Natural Areas Program (NAP) of the San Francisco Recreation and Park Department (RPD) was originally intended to preserve the few remnants of San Francisco’s natural heritage that still existed in city parks. The plan has morphed, however, into an empire that controls one-quarter of all the parkland in San Francisco (one-third of all parkland managed by RPD if you include Sharp Park in Pacifica). Its management plans have become quite controversial, with proposals to cut down healthy trees, drench hillsides in herbicides, close trails and off-leash areas, relocate or kill feral cats, and restrict access for all people to large sections of our parks.

For nearly two decades, NAP has operated with no real oversight and little input from the public about its plans. Its modus operandi is akin to “I know better than you, so go away.” Despite years of attempts to get even small amounts of accountability from NAP, the program continues to do pretty much whatever it wants in our city parks. Because, in many cases, NAP claims control of entire neighborhood parks, San Franciscans are losing access to their common “backyards”, and most have no idea it’s happening until it’s done.


In 1991, Policy 13 was added to the Recreation and Open Space Element (ROSE), a document that gives general policy directions for open space in San Francisco. Policy 13 (actually Policy 2.13) sets forth a general policy goal to “preserve and protect significant natural resource areas.” Policy 13 sets the following criteria to determine what is a natural area:

1) The site is undeveloped and relatively undisturbed, and is a remnant of the original natural landscape and either supports a significant and diverse or unusual indigenous plant or wildlife habitat or contains rare geological formations or riparian zones.

2) The site contains rare, threatened, or endangered species, as identified by the U.S. Fish and Wildlife Service or California Department of Fish and Game, or contains habitat that has recently supported and is likely again to support rare, threatened, or endangered species.

3) The site is adjacent to another protected natural resource area and, if protected from development, the two areas together would support a larger or more diverse natural habitat.

The policy also says: “Native plant habitats should be preserved and efforts undertaken to remove exotic plant species from these areas.”

Policy 13 has been used by NAP advocates to imply a city mandate to preserve natural areas, a mandate that justifies all the restrictions, herbicides, closures, etc. However, the ROSE is actually an advisory document that sets out guidelines, not mandates. It does not have the force of law.

On January 19, 1995, the SF Recreation and Park Commission approved the first management plan for natural areas. This plan identified “candidate” natural areas, and established guidelines for management programs in the areas. The plan called for a consultant to develop the specifics of the implementation of the plan. It also made a commitment to include the public and community organizations in discussions as the plan evolved. The Natural Areas Program, however, did not honor this commitment.

In 1997, the Recreation and Park Department (RPD) signed a contract with EIP Associates as the consultant to develop the ways to implement the plan. According to the contract, EIP was to form a Scientific Advisory Board (SAB) that would meet two to three times per year for a period of three years. SAB members would be paid an honorarium for each meeting; the cost of the honorariums was included in the RPD budget. A 2001 draft of the consultant’s report stated: “A scientific advisory board, made up of experts in related fields, provided direction and advice during the project’s planning and preparation.”


In fact, Dr. Ed Connor, a member of the SAB, told the SF Board of Supervisors in August 2002, “… the members of the SAB had never seen or been asked to comment on a draft of such a plan in any state of its preparation.” They were not paid any honoraria. Drafts of the management plan developed by EIP Associates were supposed to be circulated to a citizen’s task force and local community groups. Instead, the first draft was seen only by NAP staff, who then returned it to EIP for revision without seeking any public input on it. NAP was steaming full speed ahead without any real community oversight or input.

In the parks, NAP and its supporters cut down and girdled hundreds of trees (in which the bark is cut completely around the tree, interrupting the flow of sap and nutrients and eventually killing the tree). Fences were erected, blocking access to large sections of parks. NAP staff did not bother to consult with (or even tell) park neighbors and users what they were doing in the natural areas. NAP operated in a secret and arrogant manner.

At the same time, the consultant’s draft management plan was finally made available to the public at only one location (the main library). For the first time, people saw the extent of NAP’s plans – removing and killing non-native animals, including feral cats; closing trails; putting up fences; and prohibiting fishing and boating where it had traditionally been allowed. The draft management plan made clear that NAP staff and advocates had intentionally planted species of endangered and threatened plants and animals in natural areas. Because of the special status of these species, federal law requires severe restrictions on access wherever they occur. NAP essentially presented the public with a fait accompliof access restrictions before people knew what was happening.

By 2002, people had noticed major changes in some natural areas that they did not like, and they began complaining. In response, RPD formed a Green Ribbon Panel to advise RPD and EIP about the NAP management plans under development. Critics were not happy with the composition of the Green Ribbon Panel, which they viewed as composed primarily of native plant advocates. The Park and Recreation Open Space Committee’s (PROSAC) representative to the Green Ribbon Panel, Dr. Joan Roughgarden, confirmed the Panel’s bias. In a report to PROSAC, Dr. Roughgarden wrote, “The Green Ribbon Panel was selected on the basis of political advocacy, not on technical credentials, so that discussion of the technical merits of the plan is immediately interpreted in an advocacy framework.” Roughgarden continued,

“The management plan advances a highly interventionist view of resource management that is not viable ecologically, economically, or culturally.”

In response, PROSAC passed a resolution calling for a scientific review of the management plan. The Recreation and Park Commission did not respond to the request.


NAP critics complained to the SF Board of Supervisors that the way the management plan was being implemented had not been properly vetted, and that NAP was not considering the public’s input, as promised by the Recreation and Park Commission in 1995. The Board held three hearings on NAP, beginning in July 2002, and, in response, on September 24, 2002, the Board created a Citizen’s Advisory Committee for the Natural Areas Program (NAPCAC). The Board of Supervisors gave NAPCAC a year to develop a management plan for natural areas and provide a summary report of its findings. NAPCAC would meet under Sunshine Ordinance rules, so the public would be able to see exactly what it was doing. The Board’s resolution disbanded the Green Ribbon Panel and replaced it with NAPCAC. The resolution allowed NAP staff to continue to maintain natural areas as long as their actions did not include: “the removal of healthy trees that pose no safety hazards; trail closures, or restrictions on access and recreation; trapping and removal of wild or feral animals currently inhabiting parks and lakes; and expansion of activities into areas that no longer support predominantly native flora and fauna.”

NAPCAC had 12 members, four who were knowledgeable in issues related to natural areas (e.g., restoration, ecology, environmental advocacy), four who were interested in access to and use of parks and open space (e.g., recreational users, neighborhood activists, youth and tree advocates), two at-large members recommended by the Board of Supervisors, and two at-large members recommended by RPD. The Board of Supervisors approved the twelve appointments to NAPCAC on December 18, 2002.

The Board’s resolution creating NAPCAC directed RPD to assist NAPCAC, including giving notice of meetings, providing meeting space and publishing minutes. However, RPD repeatedly denied NAPCAC members’ requests for meeting space. Finally, NAPCAC members took it upon themselves to find meeting space. NAPCAC met for the first time on February 13, 2003 in the Mission Police Station Community Room. Later meetings were held in a classroom at City College.

At its first meeting, NAPCAC vote unanimously to ask RPD for staff support to provide minutes and to copy and distribute materials to the Committee and member of the public. RPD declined to provide staff to take minutes, but offered to copy materials as long as they were submitted two weeks in advance. Since NAPCAC met every two weeks, this “offer” was largely meaningless.

NAPCAC members complained to the Board of Supervisors about the lack of RPD support. At a City Services Committee hearing on May 15, 2003, speakers showed pictures of fences in three different natural areas that had been built since the Board’s NAPCAC resolution had been passed, in direct violation of the resolution’s ban on controversial management actions while NAPCAC was meeting. At the hearing, RPD General Manager Elizabeth Goldstein claimed a verbal agreement with Supervisor Matt Gonzalez that RPD would not be required to provide any support to NAPCAC. After the hearing, an aide to Supervisor Gonzalez told the Chair of NAPCAC that the Supervisor had made no such agreement.

NAPCAC continued to meet. A member of the NAP staff attended every meeting, and their message to NAPCAC, given at the end of every meeting (during general public comment) was fairly consistent – you’re wasting your time and we will ignore you and your findings. For example, on May 8, 2003, Lisa Wayne, the head of NAP, told the Committee, “The Committee has misinformation and misperceptions. The Committee is spinning its wheels, creating controversy where there isn’t any. There is fear being perpetuated in this room. I’m the person that knows these parks better than anyone else in the City.” NAP supporters in the audience at meetings verbally attacked NAPCAC members, and disrupted the meetings by talking loudly among themselves during panel discussions.

NAPCAC met for nine months. At these meetings, NAPCAC members who were critics of NAP actively engaged in negotiations, introducing repeated iterations of plans that tried to address concerns raised by NAP advocates. NAP advocates did not introduce their own plan until the next to the last meeting, instead choosing to react to plans introduced by the “other” side and insisting on compromise from them. For example, NAP advocates insisted that NAPCAC accept all 31 of the natural areas that NAP had claimed for itself, even though many had no native plants in them and had been designated as natural areas without any public input.


Because of the repeated compromises by their side, NAPCAC’s final report was barely acceptable to those members who had opposed the way NAP was being administered. Yet they voted to accept the final report because it created a process of scientific and community oversight of the NAP. Unable to convince a majority of NAPCAC members to acquiesce to further demands, NAP advocates on the Committee refused to support the final report that contained the compromises that they had insisted upon. The NAPCAC final report was passed by a vote of 7-5 on November 14, 2003, meeting the one-year deadline imposed by the Board of Supervisors in the resolution that created NAPCAC.

The NAPCAC Final Report, co-authored by two ecology/conservation biologists on the Committee, Drs. Joan Roughgarden and Ed Connor, set up a Natural Areas Program Review Committee (NAPRC) that would review and consult with NAP about its plans to manage natural areas. NAPRC would be composed of 12 members, including four scientists with research credentials in relevant fields (ecology, botany, zoology, conservation, etc.), four representatives of citywide advocacy groups, and four representatives of local neighborhood and park advocacy groups. Committee meetings would be conducted under all Sunshine Ordinance requirements, to ensure no backroom deals were made.

[Click here to read the NAPCAC Final Report: NAPCAC – final document]

The Final Report called on NAP to develop a system-wide “portfolio” plan that would (section 5.1): “provide an overview of the entire system of Natural Areas, showing how each site contributes to the overall goal of the program. This portfolio plan should outline the overall Natural Areas Program conservation and educational goals, specify the priorities for implementation of conservation plans for individual parks, and outline how the acquisition of additional properties will enhance the ability of the NAP to meet its conservation and educational goals.” The Final Report recognized that every city park has different issues and doesn’t try to enforce a citywide, one-size-fits-all solution to those problems. The Final Report went on to say (section 5.3): “Detailed plans for the conservation measures to be implemented at each site and how public input will be integrated into each site plan will be developed simultaneously and in parallel by the two subcommittees of NAPRC…”

According to the Final Report, the NAPRC would have two subcommittees, a Scientific Subcommittee and a Community Relations Subcommittee, with six members each. The Scientific Subcommittee would review the management plan at each natural areas site to determine (section7.1):

1. Is it scientifically plausible that the proposed management activities will achieve the proposed outcome?
2. Are the proposed monitoring plans adequate to identify any unforeseen consequences that may arise during the implementation of the plan?
3. Have the secondary consequences of management activities been identified?
4. Is the proposed evaluation plan adequate to determine the success of the plan?
5. Are the educational materials scientifically accurate?

The Scientific Subcommittee would provide the scientific oversight of the management plans that the original consultant and later the Green Ribbon Panel were supposed to do but did not.

The Community Relations Subcommittee would review community outreach plans by the NAP to determine (section 9.1):

1. Does the local community favor the proposed management practices for the sites in their district?
2. Has a good faith effort been made to solicit and incorporate public comments on individual site plans?
3. Has the local community been adequately informed of both the potential benefits and secondary consequences of the proposed plan?
4. Have other relevant city Commissions (e.g., Animal Control and Welfare, Urban Forestry Council, etc.) been informed and consulted about any management practices proposed for the Natural Areas?
5. Does the community have any changes they wish to make to the proposed plan?

The Community Relations Subcommittee would ensure that adequate community workshops and meetings were held by NAP, and that professionally designed surveys were conducted to measure public support among park neighbors and users for NAP’s plans at each site.

The NAPCAC Final Report expressed strong support for the NAP, and encouraged increased funding and staff for it, especially to handle the added responsibilities of the NAPRC. With the release of its Final Report, NAPCAC was disbanded.


On January 7, 2004, the Board of Supervisor’s City Services Committee heard testimony on the NAPCAC final report. NAP staff and NAP supporters attacked the NAPCAC final report, producing a “minority report” that called for citywide mediation – not any oversight committee – to resolve NAP conflicts. This minority report was written over a month after NAPCAC had been disbanded, and is entirely different from the final plan NAP advocates had presented at the next-to-last NAPCAC meeting. Unlike the NAPCAC Final Report, neither any of the majority members of NAPCAC nor members of the public had an opportunity to comment on the Minority Report before it was introduced to the City Services Committee. Despite this lack of transparency, NAP advocates demanded that it be given equal weight to the Final Report.

NAP critics were concerned. Mediation can work, especially when dealing with a single issue. But NAP issues are many and varied, and affect a multitude of park users and neighbors. In addition, mediation typically takes place in secret, allowing NAP to continue to operate without public oversight. In practice, the people invited to mediation (especially a citywide mediation) represent advocacy groups, not average citizens, further diluting the ability of park users and neighbors to influence what happens in their neighborhood parks.

Ultimately, the City Services Committee took no action on the NAPCAC Final Report. As a result, NAP was allowed to continue on its merry way with little oversight or input from the public.

Later in 2004, an informal working group, with both NAP advocates and NAP critics was established to discuss changes in the way NAP managed the lands under its control. RPD staffer Dan McKenna mediated the negotiations. The idea of three different management zones, from MA-1 for the most sensitive parts of a natural area to MA-3 for the least sensitive, came out of these informal negotiations. The group met for about six months. The informal working group thought they had reached an agreement on what the NAP Management Plan would look like.

But when the NAP Draft Management Plan was released in June 2005, NAP critics who had taken part in the informal working group felt that promises made had been reneged upon, and they fought against its adoption.


In July 2006, the Recreation and Park Commission considered whether to approve the Draft NAP Management Plan or not. The hearing was attended by hundreds of people. So many people wanted to speak that, even though people were given just one minute to speak, the Commission ran out of time. The item was continued to the August 2006 Commission meeting. At both meetings, people expressed concerns about cutting down healthy trees, killing feral cats, closures of trails and off-leash areas, overuse of herbicides, and general concerns about the loss of access for people to large parts of their parks, the same concerns expressed from the beginning of the program.

The Commission unanimously approved the NAP Draft Management Plan, after adding two minor changes to the plan: 1) the least sensitive MA-3 parts of natural areas would be managed by the RPD Urban Forestry staff, and both native and non-native trees could be planted in MA-3 areas; 2) feral cat “relocation” (a nice euphemism for “killing”) would happen only after the Recreation and Park Commission determined that other means of population reduction had failed to adequately reduce the number of feral cats in a natural area. These two changes were the only changes made to the Draft Management Plan by the Commission in response to the torrent of criticism the NAP plan had received.

The Commission then ordered an Environmental Impact Review of the NAP Management Plan that it had approved. The Initial Study for the NAP EIR was published in April 2009. The comments submitted are included as Appendix A of the Draft Environmental Impact Review (EIR) for the NAP Management Plan that was released in August 2011.

Interestingly, many of the concerns about the NAP Management Plan raised in the Initial Study are still problems with the Draft EIR. Those who prepared the Draft EIR do not appear to incorporated very many of the criticisms. Indeed, they don’t seem to have listened to the critics at all.

[Update: The Draft EIR with very few changes was approved in March 2017 by the Board of Supervisors.]

This lack of concern for what people think by NAP has been a problem since its inception. NAP seems to only listen to its most zealous supporters, and ignores the rest of us.