San Francisco Parks and Pesticides, Jan-Oct 2016

December 17, 2016 3 Comments

2016-11-02_mtd-imazapyr-blackberryOur regular readers may know that we have been following the use of herbicides in our city parks, and particularly in our so-called Natural Areas. Contrary to their name, they are a major user of herbicides. We collect the monthly pesticide use reports under the Sunshine Act, and compile and analyze them.

For the first 10 months of the year:

  • The good news is that the volume of Tier I and Tier II herbicides used in our parks has dropped considerably.
  • The bad news is that it’s dropped less in Natural Areas.

(The “Tier” classification is the SF Department of the Environment – SF Environment – designation for hazard. Tier III is Least Hazardous, Tier II is More Hazardous, and Tier I is Most Hazardous.)

HERBICIDAL FREQUENT FLYERS

The Natural Areas Program, which has rebranded itself the Natural Resources Department (as though it was responsible for leasing out mineral rights) was hands down the most frequent user of herbicides in the San Francisco Recreation and Parks Department (SFRPD). It was remarkable. We get the pesticide usage reports in the form of individual reports from around 30 departments within SFRPD. Each month, the vast majority of them said “No Pesticides Used.”

From January through October, SFRPD (excluding Harding Golf Course) used herbicides 126 times. Of those, 107 applications were in Natural Areas. And if we include the NAP-managed areas under SFPUC control (Laguna Honda, Lake Merced), the NAP application number rises to 111 of the 126 applications. NAP made 85% of SFRPD’s herbicide applications.

(These numbers exclude Harding Park golf course, which is under a management contract to the PGA Tour, and thus not under SFRPD control as such. Unlike the other SFRPD golf courses, Harding does use a lot of pesticide. However, it’s mostly in areas where the general public are unaffected.)

CREDIT WHERE CREDIT IS DUE

After a sharp increase in herbicide use from 2010 through 2013, the Natural Areas Program finally started reducing their volume of herbicide use in 2014. That continued in 2015, and it seems to be on track to continue through 2016. Total usage is finally going back toward 2008 level (but has not yet reached 2009 levels, the lowest since we started tracking NAP’s herbicide use).  NAP’s greatest success has been to reduce Roundup (glyphosate) use. In the first ten months of 2016, it had already increased its use of Garlon (tricyclopir), imazapyr, and Milestone VM (aminopyralid) over 2015 levels. However, they are down from 2013, which was peak pesticide for NAP.

herbicide-use-2008-2016

We’ve had people asking, so why didn’t they do it before? That’s a good question, but at least they are doing it now. However, the sharp rise between 2009 and 2010 shows that it behooves us to be watchful, since there’s a precedent for an unexpected increase.

GARLON FOR SOURGRASS

oxalis and california poppies smIn the first ten months of 2016, NRD (formerly NAP) has already exceeded the amount of Garlon they used in all of 2015. They applied it 19 times, for a total of 95 fl ounces, as compared with 63 fluid ounces used in 13 applications for all of 2015. We expect this number will increase by year end.

The main reason NRD uses Garlon is against oxalis. With very little evidence other than some assertions by Jake Sigg, they insist that oxalis will destroy all other plants in a landscape. Empirical evidence suggests this is not true.

Garlon is a particularly hazardous chemical. San Francisco’s Department of the Environment classifies Garlon 4 Ultra as Tier I: Most Hazardous. It’s been listed as HIGH PRIORITY TO FIND AN ALTERNATIVE (their caps) at least since we started following the issue. It’s also supposed to be twenty times as toxic to women as to men. (See page 28 of this California Native Plant Society Presentation which discusses best management practices in herbicide use: Law_Johnson 2014 presentation toxicity )

The easy way to stop using using this chemical would be for NAP to stop obsessing about oxalis. They are currently the only users of Garlon in our parks. This would be an easy win for NAP and for SFRPD.

The “fearsome four” herbicides that NAP uses are: Garlon and Roundup, currently both Tier I; and imazapyr and Milestone VM, both Tier II. (SF Environment sometimes changes the classification: Milestone was earlier Tier I, because of its astonishing persistence, but is now Tier II; and Roundup was Tier II but has been reclassified as Tier I since the finding that it is a probable carcinogen.)

They are all concerning. Garlon and Roundup are both hazardous to human health, and imazapyr and Milestone are both mobile in the soil, meaning they don’t stay put, as well as very persistent. The frequent use of imazapyr in forested areas is especially problematic, since it can damage tree roots over time even if it’s targeted at something else, like blackberry.

OTHER SFRPD DEPARTMENTS DID BETTER

As we mentioned above, while NAP (or NRD) did reduce herbicide use in 2016, the rest of SFRPD did much better.

After April 2016, when SF Dept of the Environment had some training sessions for SFRPD, the use of herbicides dropped sharply. Between May and October, only two departments of SFRPD used herbicides besides the Natural Areas – the Golden Gate Nursery and the Balboa Sports Complex. Most of those were Tier II, not Tier I herbicides.  One of the Tier II herbicides that the Nursery used is Greenmatch, actually approved for organic gardening use. It’s only classified as Tier II because of a handling risk with the concentrate, but it is harmless to the public once applied.

In the first ten months of 2016, NAP, which controls 1/3 of the parkland in San Francisco, used nearly 2/3 of the Tier 1 herbicides.

nap-herbicide-use-vs-sfrpd-other-jan-oct-2016NAP (or NRD) used 44% of the Roundup used in our parks, 100% of the Garlon, and around 99% of the imazapyr and Milestone VM.

This pattern of frequent use, together with the fact that NAP still applies more herbicides than any comparable parks area, makes for a great deal of public uncertainty. With over 100 applications a year, park users are quite likely to encounter herbicide spraying. Furthermore, as people have started observing and reporting, it’s also becoming apparent that the notices – and possibly the reports – are not always accurate, and that guidelines are not always followed. At the recent hearing, the public expressed concern about herbicides in runoff and ground water. We renew our call to SFRPD to stop using herbicides in Natural Areas altogether.

2016-11-02_mtd-cutting-eucalyptus-herbicide

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San Francisco’s RPD is Closing 31% of Our Parkland in “Natural Areas”

July 16, 2016 3 Comments

[This article has been updated 7/21/2016 to include more recent pictures. The text has been slightly edited.]

The San Francisco Forest Alliance opposes the San Francisco Recreation and Parks Department (SFRPD)’s Natural Areas Program (NAP) for several reasons: Destruction of trees and other habitat for birds and animals; the use of toxic herbicides; and widespread access restrictions for residents and their families including their kids and pets.

NAP is restricting parks to on-trail use only – which shrinks the parks to a fraction of their original usable size.

Grandview-with-Fog-Bank1-600x400

Grandview Park with Fenced Trail

This article is about access – specifically, NAP is closing even more trails than disclosed in the Significant Resource Areas Management Plan (SNRAMP). In the SNRAMP, they said they were planning to close or relocate around ten miles of trail, which was bad enough. But recent actions by NAP show that they are actually closing even more trail than they disclosed in that plan, and that they have already started implementation – despite the Plan not being certified. The SNRAMP is not yet certified, and as such, should not be implemented until the certification is completed. This appears to be a violation of at least three regulations.

Furthermore, this is all being done quietly. We were able to get actual maps of  “designated trails” – but only for a few parks. This article by Tom Borden spells out the details.

mclaren park 2 sign 2015

SFRPD “Welcomes” you

CRIMINALIZING PARK USE

RPD’s Natural Areas Program put up signs in its parklands early last year that say, “Stay on designated trails.”

The signs cite Park Code 3.02, which states, “No person shall willfully disobey the notices, prohibitions or directions on any sign posted by the Recreation and Park Commission or the Recreation and Park Department.” Violations are punishable by fines of $100 and up. This means we can be fined for going off-trail or for using un-designated trails. However, “designated trails” aren’t necessarily marked. How can we tell which trails are Designated and which trails are not? Does the Park Patrol know?

AVOIDING TOXIC CHEMICALS

There is another reason we care which trails are Designated. If we stick to them we can avoid exposure to toxic pesticides like Roundup and Garlon 4 Ultra, which NAP regularly uses in our parks. The Department of Environment has issued rules that govern the NAP’s pesticide spraying, “Restrictions on “most hazardous” (Tier I) herbicides” (Read the rules here: 032216_restrictions_on_herbicides). It prohibits land managers from spraying these chemicals within 15 feet of a “designated, actively maintained public path”. (As the Department of Environment worked on that restriction with RPD, that phrase went from “public path” to “designated public path” to “designated actively maintained public path“. Good thing they are looking out for us!)

WHICH TRAILS ARE “DESIGNATED”?

Of course, the rule is pointless if nobody knows which trails are Designated and Actively Maintained. How would the NAP staff and contractors know where they are allowed to spray? How would the public know where it is safe to walk?

SF Forest Alliance wrote a letter to Phil Ginsburg asking that maps of Designated Trails in all Natural Areas be posted on the RPD website. Mr. Ginsburg refused to respond. (Here’s our letter of 15 June 2016)

sffa letter to Phil Ginsburg june 2016

SF Forest Alliance also submitted a Sunshine request to RPD and was referred to the RPD website where maps for a few Natural Areas are posted. However, there are maps for only 8 of the 32 Natural Areas and two of those posted do not seem to be correct (McLaren and Lake Merced).

WHAT ARE THEY HIDING?

Why won’t RPD’s Natural Areas Program provide maps of their Designated Trails? What are they hiding? The elephant in the room is the effective closure of 31% of our parkland to public access. NAP’s intent, and the meaning of the signs, is that our use of NAP-controlled parkland is limited to their Designated Trails. We may not leave those trails.

TRAILS LIKE CATTLE CHUTES

The NAPs plans to close trails and limit the public to on-trail access only is disclosed in their 2006 Significant Natural Resource Areas Management Plan or SNRAMP. The SNRAMP proposes “enforcement” to keep people from wandering off-trail and as a “last resort”, the installation of fences. So far, they have skipped over enforcement and gone straight to fences. Grandview Park and Corona Heights have so many fences you feel like you are in a maze of cattle chutes. Implementation of the SNRAMP has serious environmental consequences and so the plan is subject to CEQA. An EIR for the plan has been in process since 2005 and has yet to be released to the Planning Commission for certification.

Corona Heights

Corona Heights fenced trail

In the next section are maps of the NAP areas where Designated Trails have been identified. For parks that have gotten the full NAP treatment, a tally of sharp cornered, splinter enriched, split rail, access control fencing is included. Notice how some of these trail closures cut off entire neighborhoods from their parks. The only public use of NAP parkland is along those green lines. The rest is off-limits.

Corona splinters

TRAIL MAPS BEFORE AND AFTER

On the maps, trails are marked in three colors. The green trails are the Designated Trails where we are still allowed to walk. The red trails are ones identified in the SNRAMP as unwanted and planned for closure when the SNRAMP is implemented. It is now illegal to use those trails. The purple trails are identified in the SNRAMP as Designated Trails to remain open. However, the NAP has chosen to close those as well. In some parks like Grandview, Glen Canyon and Corona Heights, the red and purple trails have been physically closed with fencing and piles of tree limbs. This has yet to be done extensively in the other parks mapped. For now the trails are closed by virtue of the signs, Park Code 3.02 and the maps posted on the RPD website. Don’t worry, the fences are coming. Each park map is followed by a skeleton map highlighting the tiny amount of parkland now open to the public. the colored areas show the usable space in the park. In all the “after” pictures, it’s just the actual – limited – trail.

billy goat hill before and after

corona hieghts before and afterglen canyon before and after1

 

 

grandview before and after

twin peaks trails before and after

hawk hill before and after

The SNRAMP states that 26% of the existing trails would be closed, leaving us with 30.8 miles of trail. Based on the information unearthed to date, the NAP is actually closing 51% of the trails in Natural Areas. If we extrapolate the actual closure rate to all of the Natural Areas, the 41 miles of existing and planned trails documented in the SNRAMP will be reduced to 20.9 miles.

SHRINKING OUR PARKS

The loss in trails is nothing compared to the loss in actual parkland available to the public. Assuming the average trail is 10 feet wide and the NAP only closes the trails disclosed in the SNRAMP (both very generous assumptions based on what we have seen so far), we can calculate how much parkland remains for the public. 30.8 miles of 10 foot wide trail only amounts to 37 acres. This is 3.4% of the 1100 acres available to the public before the new access restrictions. That is unacceptable. At the actual trail closure rate we will only be left with 25 acres. That is even more unacceptable, especially if your neighborhood park is a Natural Area.

IS SFRPD ABOVE THE LAW?

The signage, trail closures and fences implemented to date appear to violate the following:

  • BOS resolution 653-024 which prohibits the NAP from imposing, “Trail closures, or restrictions on access and recreation” until the Board of Supervisors (BOS) has approved the natural areas management plan (SNRAMP). They have not approved the management plan.
  • CEQA, PLANNING DEPARTMENT CASE NO. 2005.1912E.  The SNRAMP Environmental Impact Report has not been certified by the Planning Commission, yet the NAP is implementing its plan. All of the trail closures, fences and signage are part of the SNRAMP. RPD is brazenly violating CEQA.
  • City Charter Article IV section 4.113 RECREATION AND PARK COMMISSION:  “No park land may be sold or leased for non-recreational purposes, nor shall any structure on park property be built, maintained or used for nonrecreational purposes, unless approved by a vote of the electors.” The signs and fences violate the intent of this, dramatically reducing the amount of parkland available for recreational uses. The parkland is not covered by a parking lot or a gift shop, but it takes away recreational space all the same.

The Recreation and Parks Department seems to be operating outside the rule of law. It does not answer to the public or the Board of Supervisors. It appears more concerned with pleasing special interests than the public at large. Something needs to be done.

Filed under "Natural" Areas Program, Blocks Access Tagged with , ,

Truck-size Loopholes in San Francisco’s Pesticide Plan

December 8, 2015 1 Comment

If you oppose the use of toxic herbicides in our parks, you may wish to attend a San Francisco Department of the Environment (SFDoE) hearing on  Wednesday, December 16, 2015, 4:30-7:00 pm in the Downstairs Conference Room, 1455 Market St. (near 11th St.; Van Ness MUNI stop)

glen canyon glyphosate imazapyr 2012 barack doggie

Did Roundup Kill this Dog?

SFDoE manages the Integrated Pest Management program, which decides which pesticides may be used on city property.  It classifies the permitted pesticides into three tiers: Tier III is the Least Hazardous; Tier II is More Hazardous; and Tier I, Most Hazardous. It recently reclassified Roundup /Aquamaster (active ingredient glyphosate) as Tier I after the World Health Organization declared glyphosate a probable carcinogen.

SFDoE is going to discuss some new rules restricting Tier I pesticides. We were hopeful, because we believe SFDoE does try to reduce pesticide use, and we thought the recent public outcry  would strengthen their resolve to prohibit pesticides unless public health and safety were affected.

(There’s a good article on the public opposition here: Public Opposition to Pesticide Use in Our Public Parks.)

For the record, and as our supporters already know: San Francisco Forest Alliance stands for No Pesticides in our Parks.

So we were hopeful, in fact, until we read the draft rules. They contain truck-sized loopholes, and will not substantially reduce pesticide exposure for San Francisco’s park-using families, including small children and pets.

SF Draft Restrictions on Tier I Herbicides Nov 2015

(You can download the PDF here: San Francisco Draft Restrictions on Tier I herbicides )

“NATURAL AREAS” GET A FREE PASS TO USE TIER I HERBICIDES

Exception number 11 says that these herbicides may be used on “Invasive species posing a threat to species or ecosystems of value to the community.” Since that’s the entire justification that the SFRPD’s Natural Areas Program (NAP) gives is that it’s using these toxic herbicides on invasive species, they won’t need to change anything they do.

toddler holding oxalisWhat this means: NAP claims large areas of our parks as so-called “natural areas”  – over 1000 acres in 32 parks. It includes most places people like to hike with kids and dogs like Mt Davidson, McLaren Park, Glen Canyon, Bernal Hill, and Pine Lake. They spray Tier I and Tier II herbicides on over 30 different species of plant. Some are close to the ground, like oxalis. Others are bushes, like blackberry, where they don’t stop spraying even in the fruiting season when everyone including kids are eating berries off the bushes.

This video showing glyphosate and imazapyr being sprayed on blackberry was taken on Mt Davidson only a few weeks ago.

https://www.youtube.com/watch?v=7X4A3JKZVgc

WHAT ABOUT THE CHILDREN?

parent and child with oxalisProposed rule number 4 prohibits use of Tier I pesticides on “the grounds of schools, preschools, or children’s playgrounds.” This is certainly an improvement, but it’s hardly enough. Playgrounds and preschools in particular are often inside parks, and if the parks can use these pesticides, then the children may well be exposed on their way into or out of the area, especially if they stop to hike or play in natural areas. Glen Canyon is an example – a preschool abuts the natural areas, which, as we noted above, gets a free pass. In McLaren Park, much of the park is a natural area, including areas close to playgrounds. (All the colored areas on the map below are claimed by NAP.

mclaren NAP Map 1

LANDSCAPE RENOVATIONS AND OTHER EXCEPTIONS

Another permitted use is in landscape renovations (Exception 10). We presume this applies to such projects as Kezar Stadium and Marina Green, both of which used substantial quantities of Tier I herbicides. It requires the public to be excluded for 4 days after the spraying. However, there’s growing evidence that some of these pesticides are persistent for a lot longer than 4 days.  Again, these are landscapes where our kids and pets play, often for hours at a time.

Two other exceptions also increase risk of exposure: Tier I herbicides may be used on poison oak near paths, and on trees or weeds posing a public safety, public health or fire hazard. Since pretty much any shrubs or trees can be deemed a hazard, this again means that herbicides can be freely used. And as more trees are removed near paths and trails, poison oak thrives in the sunnier areas – and justifies more Tier I herbicides.

In fact, another document for the meeting suggests a more aggressive attitude to trees. If any department wants to use pesticides not on the approved list, it can ask for an exception. The SFPUC wanted an exception for “Bonide Sucker Punch.” The problem, as they set it out was as follows:

When only some of the stems of eucalyptus and acacia of a multi-trunk tree are cut, the response of
the tree is to produce a vigorous re-growth of stump sprouts and suckers. The usual treatment of stumps is to paint the cut surface with a translocating herbicide, such as glyphosate or triclopyr. However this treatment kills the root system of the tree, killing the standing live stems of the tree. These present a hazard if they subsequently fall over. NAA is a synthetic plant hormone that suppresses re-growth  of suckers without killing the roots.

The exception was rejected, with this solution proposed instead – cut down the entire tree, not just the bits that are intruding into the right-of-way! And then paint the stumps with a Tier I herbicide (Roundup or Garlon), which will destroy the entire tree and, if other trees are nearby, potentially damage their roots as well. So instead of a solution that preserved the tree while limiting the damage, SFDoE approved a method that would be much worse.

We also note that in recent months, SFRPD NAP staff have apparently been deployed to apply herbicide on SF PUC property. This suggests that SFPUC is also buying into the destructive NAP approach.

THE ANNUAL PUBLIC HEARING

Each year, SFDoE holds a hearing where they review changes to the list of approved pesticides, listen to the justifications for exceptions during the year, and take comments from the public. It’s usually held in a round table format in City Hall, with free discussion. This year, they will also discuss the new rules. With the recent outcry against pesticide use, they expect a much larger turnout and have changed the venue. Please be prepared with a comment of no more than 2-3 minutes long.

Annual Public Hearing on Pest Management Activities on City Properties  and San Francisco’s Draft 2016 Reduced-Risk Pesticide List

4:30-7:00 pm Wednesday, December 16, 2015
Downstairs Conference Room, 1455 Market St. (near 11th St.; Van Ness MUNI stop)

kid and pesticides2

Filed under "Natural" Areas Program, Applies Pesticides Tagged with , , , ,

The Natural Areas Program and Pesticide Use

April 5, 2014 6 Comments

Pesticide Application Notice - Mt Davidson (Nov 14 and 15th, 2013)

Pesticide Application Notice – Mt Davidson (Nov 14 and 15th, 2013)

We recently received a response from Phil Ginsburg, General Manager of the San Francisco Recreation and Parks Department (SFRPD) , to our concerns regarding the “Natural Areas Program”  (NAP). We thank him for the detailed response, but we still have a number of points of disagreement.

One of them is herbicide use. His letter states, “As a percentage of our overall total, herbicide usage in the Natural Areas comprises only 4%.”

As readers of this website know, that’s very different from our own analysis. We find that NAP uses nearly as much of the ‘Most Hazardous’ and ‘More Hazardous’ herbicide as the rest of SFRPD (ex Harding Golf Course).

And the discrepancy is the more surprising since the source documents are the same – the Monthly Pesticide Use Reports each section submits.

The graph below compares NAP and other SFRPD (ex Harding Golf Course). Not only is NAP clearly using much more than 4%, it also is the largest user of the Most Hazardous (Tier I) chemicals. (The San Francisco Department of the Environment – SFDoE – produces a  “Reduced Risk Pesticide” list each year. This lists pesticides that may be used on city-owned lands, and gives them Tier ratings.)

NAP vs SFRPD Other 2013 by Active Ingredient

WHY THE DISCREPANCY?

Since we don’t know how Mr Ginsburg’s percentage is derived, we can only speculate. Some possible reasons:

1)  Our numbers leave out Harding Golf Course, but they include it.

Here’s why we exclude it: Harding Park Golf Course is under contract to be maintained to tournament-ready standards. This means it uses a lot of pesticides; but it really is outside SFRPD control if San Francisco is to have a PGA-standard golf course. (The city’s other golf courses, where SFRPD actually can determine pesticide use, actually use very little.  Sharp Park, for instance, has used none since August 2010.)

2)  Our numbers are for the most recent year, 2013.

Though the phrasing of the sentence suggests that are considering current usage, they may actually have used historic numbers.  It’s possible that other sections of SFRPD reduced their herbicide usage, even while NAP’s herbicide usage went up. NAP herbicide use rose annually from 2009 through 2013.

B&W Herbicide Use - Natural Areas Program

3) We have only considered the chemicals that are most concerning – the “more hazardous” and “most hazardous” herbicides (those the San Francisco Department of the Environment classifies as Tier II and Tier I) and omitted the “least hazardous” ones (Tier III).   Possibly SFRPD has included Tier III herbicides. We think this would distort the comparison; it would be like comparing pineapples and hand-grenades.

4)  If it’s based on the SF DoE’s new database, it may have data-entry errors, especially for data since 2010 when the new database was instituted. We compiled the Monthly Pesticide Usage reports ourselves, and re-checked them.

HOW WE GOT OUR NUMBERS

For anyone who wants to replicate our calculations, here’s how we made them:

  • We obtained Monthly Pesticide Usage reports from SFRPD under the Sunshine Act. If any of them were unclear, we got clarifications.
  • We compiled this data into a spreadsheet. Then we calculated Tier I and Tier II herbicide usage separately for NAP and for all other SFRPD (excluding Harding Golf Course), using SF DoE’s ratings.
  • We show “Greenmatch” separately – it’s rated Tier II, but it’s an organic herbicide that is less harmful than most Tier II products. Until 2013, it was rated Tier III, least hazardous.
  • [ETA:  We calculated the “Active Ingredient” quantity by using conversion factors provided by the manufacturer of each chemical. (These are available online.)]

In the first two months of 2014, NAP was still the major user of Tier I herbicides, using 8 times as much as all the rest of SFRPD ex Harding.

 

 

 

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Glen Canyon Park: One Year after Start of Tree Destruction

February 6, 2014 1 Comment

The Glen Canyon Playground and Tennis Court Project – as the city is calling this – is nearly completed. In February or March 2014 there will be great fanfare at the completion of this project.

Video update to the Glen Canyon Park tree demolition project

Is it an improvement? Well, there is a new playground at least, but it will not be the same as it was: a steep staircase to the slide and bushes that were at the top – gone. The kids loved those; they played games of imagination and adventure there. Instead of a quirky playground that used the advantages of the site, there’s a standard-issue place that could have been built anywhere.  And the wonderful climbing tree the children loved, behind the Rec Center – also gone. The new kids will not know what they missed.

The City Arborist report stated that only 1 tree was truly hazardous, yet 42 trees were destroyed. Equally troubling is the deliberate relocation of tennis courts that destroyed 11 healthy and majestic Eucalyptus guarding the Park’s entrance.

Question: Why was there no attempt to incorporate these trees into the overall design goal that could have been achieved without sacrificing space for the playground and ball field?

Answer: San Francisco taxpayers “purchased” a native plant garden as part of the project and ensured all those “poor suitability / non-native” trees were eliminated.

Functional, Beautiful Ecosystems Should Be Left Alone; the Parks need maintenance, not destruction.

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Filed under "Natural" Areas Program, Blocks Access, Fells Trees, Ruins Habitat, Wastes Money Tagged with , , , , , ,