Oakland’s Vegetation Management Plan – Our Comment (Deadline 11 June 2018)

Oakland’s Vegetation Management Plan is to cut down thousands of trees and use toxic pesticides to prevent resprouting. If you wish to comment, the deadline is June 11, 2018. Send your email to VMPcomments@oaklandvegmanagement.org

We’ve published a brief comment here (see below).

Here’s our comment:

The San Francisco Forest Alliance is a non-profit (501 (c)4) organization that was created in 2012 to advocate for the preservation of our urban forest and eliminate the use of pesticides in our public parks. Our mission is Inclusive Environmentalism.

We are familiar with the strategy of justifying the destruction of non-native trees based on the claim that they are more flammable than native trees, because it has been used in San Francisco – although there is no history of and little risk of wildfire here.

Oakland’s Draft Vegetation Management Plan appears to be using the same rationale for destroying healthy trees and using pesticides to prevent them from resprouting. We are therefore writing to request that the draft be revised to limit all tree destruction to the creation of defensible space around structures, as defined by California law. We also request that Oakland not use pesticides to implement its vegetation management plan.

At a time of climate change, destroying healthy trees is irresponsible. Climate change is a global environmental issue that effects everyone, including the residents of San Francisco. Therefore, we ask that unnecessary tree removals be avoided.

Likewise, the use of pesticides in our watershed is an unnecessary health hazard that affects all residents around the San Francisco Bay, including wildlife.

Most People Oppose the East Bay Tree-felling Plan

We’ve received some reports about the last public hearing (on May 18th at 10 a.m.) on the Draft Environmental Impact Statement (DEIS) of the East Bay plan to fell up to 500,000 trees – 86,000 in Berkeley and Oakland, and another 400,000 in East Bay parks.  There was overwhelming opposition to the Plans.

lake-chabot cropped Photo credit MillionTrees dot meTo recap: Three owners/ land managers are involved:

  • University of California at Berkeley (60,000 trees on 284 acres)
  • City of Oakland (26,000 trees on 126 acres);
  • East Bay Regional Parks District (400,000 trees on 1,650 acres).

They would use Garlon to prevent resprouting (which would require thousands of gallons of this very toxic herbicide), and glyphosate (Aquamaster or Roundup) to discourage the growth of non-native plants. The first two projects plan to remove all the non-native trees in the project areas. The third plans to “thin” the trees to about 60 trees per acre, removing around 90% of the trees on the project area, and using prescribed burns in addition to pesticide.

You can read about this plan and the tree removal calculations HERE.


An estimated 160-175 people attended, and the meeting, scheduled for 2 hours, ran nearly twice that long. There was standing room only, with people crowding the sides of the room and sitting on the floor. Of the 56 people who spoke, 48 opposed the Plans to fell these trees. That’s over 85% of the speakers.

The themes:

  1. They didn’t know about these plans, even though they live nearby. They heard about them from friends and from social media. The outreach was poor.
  2. People were very concerned about the use of pesticides. Roundup in particular was criticized. (Most people are not familiar with Garlon, which is probably even more toxic than Roundup – and also included in the Plans.)
  3. They were also concerned about greenhouse gases, which are causing climate change. Trees store carbon; not only will they stop doing that, but felling and “mulching” so many trees will release carbon dioxide into the air.
  4. If the intention is to reduce the fire hazard, other alternatives should have been considered.
  5. Most people wanted to preserve the ecosystem and trees that are already there; it would be  unconscionable to wreck it.
  6. All the areas are on hillsides; speakers were concerned about soil erosion.
  7. They were also worried about contamination of streams/watershed.
  8. Some commenters felt Hills people were arrogant, more concerned about property than people.
  9. Some speakers declared we should stop interfering with nature, and keep as many trees as possible to protect us from the pollution we have created.
  10. Clear-cutting and spraying the ground with chemicals will create a wasteland.

There’s a report from The Berkeley Patch HERE: Plan to Cut 85,000 Trees in Berkeley and Oakland Hills Draws Crowd. In the photograph with that article, two people hold signs:


Others reported signs saying things like “KILL THE PROJECT, NOT THE TREES” and “NO CHEMICALS IN OUR PARKS.”


Though all the public meetings are now over, you can still comment on the Plan in writing up to June 17th.

FEMA has published the Draft Environmental Impact Report for these projects, and will accept comments until June 17th, 2013. That is available HERE; it’s a long document. The Executive Summary is quite short – and telling. It’s here as a 16-page PDF: Executive+Summary-East Bay You may submit written comments in several ways:

  1. Via the project website: http://ebheis.cdmims.com
  2. By email to EBH-EIS-FEMA-RIX@fema.dhs.gov
  3. By mail: P.O. Box 72379, Oakland, CA 94612-8579
  4. By fax: 510-627-7147

sign for East Bay HillsThe Hills Conservation Network’s petition is gaining momentum; it has over 1875 signatures as we write this. If you haven’t signed and would like to do so, this button will take you to the petition.

Hills Conservation Network are also raising funds for potential legal action. If you would like to contribute, their website is  HERE  and includes a Paypal button.


We bring you some of the criticism of these projects (this is based on a critique from the Hills Conservation Network). These projects would:

  1. Shift the ecosystem from trees to flammable dry brush. These projects would permanently alter the Berkeley/Oakland hills ecosystem, and make it much more – not less – flammable.  UC and Oakland plan to clear-cut mature, healthy trees, including huge 100-year-old trees taller than ten-storey buildings. You won’t see tall trees in the hills any more. What you will see, as soon as the rain stops, will be weeds and highly flammable brush, brown, dry, and ready to burst into flame. This easily ignitable chaparral (including scrub oaks), weeds, grass, hemlock, thistle and broom will burn more easily than trees. It’s lower, finer, and dry as kindling. Thick trunks don’t burn easily, and fire does not reach the crowns of trees unless there are ladder fuels (like weeds, grass, etc. under them).
  2. Waste our money. If you include the matching funds, this is going to be a $7 million plan to destroy forests miles from homes. Instead, that money could be used as originally intended: actually reducing fire hazards by, for instance, creating defensible space around houses and other structures.
  3. Slather the hills in herbicides. To prevent trees from resprouting, the hills would be drenched with massive amounts (30,000 + gallons) of toxic pesticides.  In addition, pesticides will be sprayed throughout the watershed to knock down the weeds, hemlock, poison oak, thistle and broom  that will emerge with the loss of canopy. Toxic sediments will seep into our creeks and could permanently alter the watershed. Garlon causes cancer and so does glyphosate (Roundup) when sprayed broadcast over large areas. Tons of pesticides will be needed to maintain the site—to kill the weeds—after the trees are removed.  Making matters worse, UCB has not posted signs when pesticides are sprayed.
  4. Use a two-foot mulch doesn’t work and raises ignition risk. They’re planning to chip the trees on site, leaving up to 24 inches of chip litter on the ground.  There’s danger of subterranean fire under the chips, as well as spontaneous ignition in the hot sun – as in a hay stack. Anyway, areas where it’s been tried have been invaded by hemlock, thistle, broom and poison oak.
  5. Release stored carbon and change the microclimate. As the chips decompose, they release carbon, adding to global warming. Nothing stores carbon like big trees; we’ll permanently lose the carbon storage these trees gave us. Tree loss will also cause local climate changes: more wind, more dry air, less fog, more air pollution.
  6. Cause Habitat loss and ecological imbalance. The plans would destroy an enormous amount of habitat; the tall trees favored by raptors such as owls and hawks would be lost forever. Without raptors to keep them in check,  the rodent population will undoubtedly increase. We saw this after the 1991 fire. And what about the federally protected Alameda whipsnake?  It’s unrealistic to believe they can be trapped and translocated until after completion.
  7. Cause erosion and landslides. Without tree roots to hold the soil in place, erosion and landslides will increase.
  8. Make for visual blight, daily road closures, and constant chainsaw noise for 3 years.


Comments that are specific about the flaws in the EIS will be most effective:

  1. The fire model is wrong. It compares the fire danger of standing forests with the fire danger (zero) after the trees are cut down to stumps. It does not consider the fire risk danger—much worse—of what will replace the trees.
  2. This is Native Plant gardening, not fire mitigation.  Fostering the growth of native plants such as bay trees, chaparral and oaks is native plant restoration.  It has nothing to do with fire risk mitigationFEMA funds were not intended to promote a particular plant ideology.
  3. It doesn’t adequately address impacts on Greenhouse Gases. It uses an inappropriate baseline, and also does not properly estimate the loss of ongoing carbon sequestration. The EIS needs to be reworked.
  4. It doesn’t properly address the costs and risks from the huge increase in toxic herbicide use.
  5. It does not adequately analyze reasonable alternatives proposed for fire risk mitigation. Far less costly, far less environmentally damaging, and far more effective methods have been proposed, but the EIS fails to consider them. The EIS needs to be reworked to analyze reasonable alternatives rather than simply dismissing them without any analysis.