No Pesticides in Our Parks and Watersheds

Below is the text of a letter San Francisco Forest Alliance sent yesterday to the Environment Commission and the SF Department for the Environment. We stand for no toxic pesticides in our parks and watersheds.

 

To: Director Deborah Raphael, Dr Chris Geiger, and the Commission for the Environment
From: San Francisco Forest Alliance

Dear Dr. Geiger,
Dear Director Raphael,
Dear Members of the Environment Commission

Your Notice of Annual Public Hearing Regarding Pest Management Activities on City Properties incorrectly states that “San Francisco city staff have been national leaders in integrated pest management (IPM) since the City passed its Integrated Pest Management Ordinance in 1996.”

In fact, 1996 Ordinance was gutted in 1997.
While San Francisco has made some progress, we are far from being national leaders. Our current system enshrines the routine use of herbicides.
At present, the city can use whatever pesticide it wishes, wherever it wishes, as much as it wishes – as long as the pesticide is on “Reduced Risk Pesticide List” (Reduced compared to what?). If it wishes to go outside the list, it can seek an exemption. Such exemptions are seldom refused, particularly in “Natural Areas.”

The Marin Municipal Water District has been herbicide free since 2005.
Meanwhile San Francisco continuously uses hazardous herbicides in our watersheds.

In a 2017 pilot project, Marin successfully demonstrated that traffic medians could be maintained without glyphosate (the only synthetic herbicide previously used on medians). Marin County will continue to move forward without herbicides on all medians and roadside landscapes.

The City of Richmond had completely banned use of all herbicides by the city in 2016.
The use of all synthetic pesticides in parks, open space parcels and public rights of way and buildings owned and maintained by the Town of Fairfax is prohibited and a neighbor notification is required prior to the use of pesticides on private property.

In 2000 the Arcata City Council approved by unanimous vote the ordinance which bans the use of pesticides on all properties owned or managed by the city.

In France the pesticides are banned from public forests, parks and gardens since the end of 2016.

The city of San Francisco, on another hand, cannot even commit to use reduction targets for herbicides. In 2017, herbicide usage by the Natural Resources Department rose 57%.

The city claims that the high hazard herbicides are used only as a last resort. In fact, they are used regularly throughout the year, and have been used regularly for many years.

The city claims that the high hazard herbicides are necessary to help “sensitive species,” while in accordance with the court order their use is prohibited in Sharp Park precisely because of the presence there of the endangered California garter snake and threatened red-legged frog. A 2002 paper from UC Davis pointed out that over 40% of Californian butterfly species depend on non-native plants in urban-suburban areas, and notes, “Were certain alien weeds to be eradicated or their abundance greatly reduced, the urban-suburban butterfly fauna would disappear.”

Last week the trial of DeWayne Johnson v. Monsanto Company – the first of over 4,500 such cases – got underway in San Francisco Superior Court.
Meanwhile, glyphosate remains on the SF “Reduced Risk Pesticide List” and is being used by the city – three years after it has been classified as a “probable carcinogen” by the International Agency for Research on Cancer of the World Health Organization.

San Francisco Forest Alliance brings to your attention that:

• herbicidal chemicals are more toxic, more dangerous, more persistent, and more mobile than their manufacturers disclose;
• the “danger” from “weeds” is aesthetic or ideological rather than to health and welfare;
• scientific studies associate exposure to herbicides with cancer, developmental and learning disabilities, nerve and immune system damage, liver or kidney damage, reproductive impairment, birth defects, and disruption of the endocrine system;
• there is no safe dose of exposure to those chemicals because they persists in soil, water, and animal tissue for prolonged periods of time, so even low levels of exposure could still be harmful to humans, animals, and the environment;
• infants, children, pregnant women, the elderly, people with compromised immune systems and chemical sensitivities are especially vulnerable to herbicide effects and exposure;
• herbicides are harmful to pets, wildlife including threatened and endangered species, soil microbiology, plants, and natural ecosystems;
• toxic runoff from herbicides pollute streams and groundwater, and therefore the drinking water sources;
• people have a right not to be involuntarily exposed to herbicides in the air, water or soil that inevitably result from chemical drift and contaminated runoff.

Because of above considerations we ask that all synthetic herbicides classified as Tier I and all non-organic herbicides classified as Tier II by the San Francisco Hazard Tier Rating System shall be banned on all City property and the lands managed by the city, with the only exemption for Harding Park Golf Course which is under PGA contract.

We also ask that:
– no other herbicide exemption shall be granted for any other City Property or the land managed by the city,
– such herbicides would be immediately removed from the Reduced Risk Pesticide List with the special exception for use on Harding Park Golf Course only,
– the City stop purchasing hazardous herbicides, and disposes of any remaining stock immediately, following the city’s hazardous waste disposal protocols; again exempting the herbicides intended for use on Harding Park Golf Course only.

We ask SF Environment to lead San Francisco toward the goal of No Pesticides in our Parks and Watersheds.

Sincerely,

San Francisco Forest Alliance

 

– END –

Advertisements

Why We Oppose Prop 68 (June 2018 Election)

Proposition 68 is on ballot in the upcoming elections. It would authorize the State in California to sell $4.1 billion in bonds for “park and water” improvements. Unfortunately, roughly a third of the money will be allocated for “protection of natural habitats.”

 

MONEY TO FELL TREES AND SPRAY TOXIC HERBICIDES

Over time, we’ve learned what that means, and it’s not protection of anything. In public agencies’ vocabulary “protection of natural habitats,” “native restorations,” “protection of endangered species” usually mean attempts to convert “non-native ” vegetation to “native” by killing trees and using high hazard herbicides.  The actual actions are: (1) Cutting down trees, often thousands of trees (2) Spraying toxic herbicides – including probable carcinogens – in an attempt to prevent the “non-native” plants from growing. When money becomes available, the pace and extent of these activities increases. See: Oyster Bay: Firehose of Funds Means a Firehose of Pesticides

We oppose the felling of trees especially in this time of climate change. Trees sequester carbon, clean the air, stabilize the ground, and provide habitat.

We also oppose the use of toxic herbicides in so-called “Natural” habitats and in these destructive “restorations.” Over time, we’ve understood that herbicides are often more toxic and more persistent than the manufacturers originally claimed. Using them in this way contaminates soil and water, creating unknown dangers for the future.

 

We expect that San Francisco will obtain some of this money to finance implementation of Natural Resource Management Plan.

How many trees can be killed, and how much toxic herbicide can be poured into the Earth for $1.35 BILLION dollars? We recommend a “NO” vote on proposition 68.

FISCAL IMPACTS

We cannot see any pressing fiscal need either.

From the League of Women Voters website: “During the past 17 years voters approved almost $27 billion in general obligation bonds for various natural resources projects, of which the State still has almost $9 billion available. Repaying the bonds is expected to cost an estimated $200 million each year for 40 years, resulting in a total cost of $7.8 billion. There may be savings to local governments in tens of millions of dollars because the bond money available will relieve the local governments from paying for all of a project. There are unknown costs and savings associated with the actual operation and impacts of the projects produced.”

Important Pesticide Meeting at City Hall, 20 Dec 2017

Toward the end of each year, SF Department of the Environment (SF Environment), which runs the Integrated Pest Management Program (IPM) holds an important public meeting. This year, it’s on December 20, 5-7 p.m. in Room 400 at San Francisco’s City Hall.

This meeting is to discuss three things, and take public comments and input: Changes to the approved list of pesticides for city use; the guidelines for pesticides use and public notification; and explaining the exemptions granted in 2017 to the rules.

Notice showing Pesticides to be used on blackberry on Mt Davidson, San Francisco - Nov 2017

Pesticides used on blackberry on Mt Davidson – Nov 2017

THREE THINGS ON THE PESTICIDE MEETING AGENDA

1. Changes to the approved list of pesticides for use on city properties. SF Environment publishes a list of pesticides that are okay to use on city-owned properties (our parks, lands owned by the Public Utilities Commission, Crystal Springs, the airport, Sharp Park and a few others). It divides these permitted pesticides into three tiers: Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous). This meeting discusses pesticides added, removed, or having their Tier classification changed.

The DRAFT for 2018 is here: b_draft_2018_reduced_risk_pesticide_list

2. Guidelines for pesticide use and public notification. Over the last year, IPM has been trying to develop guidelines for when and where these pesticides are prohibited; and also for how the public can be informed when pesticides are used. Here’s the current DRAFT of the guidelines: c_summary_of_major_changes_to_2017_restrictions_of_most-hazardous_herbicides

3. They also explain the exceptions they’ve granted in the previous year, i.e. 2017. They approved 21 exemptions in 2017. The list of exemptions is here: a_summary_of_pesticide_exemptions_for_2017

The one that particularly concerns us is permission to use Garlon 4 Ultra (probably the most toxic herbicide still permitted on City properties) on oxalis within fifteen feet of designated trails at Twin Peaks, Mount Davidson, McLaren Park, Bayview Hill and Corona Heights.

They argue: These parks have a diversity of native plants growing adjacent to trails including but not limited to: Grindelia hirsutula (gumplant), coast rock cress (Arabis blepharophylla), Pacific reed grass (Calamagrostis nutkaensis), stonecrop (Sedum spathulifolium), meadow white (Cerastium arvense), silver bush lupine (Lupinus albifrons), Mission bells (Fritilaria affinis), footsteps of spring (Sanicula arctopides), California buckwheat (Erigonium latifolium), soap plant (Chlorogalum pomeridianum), dichondra (Dichondra donelliana), varied lupine (Lupinus variicolor), California buttercup (Ranunculus californicus), checkerbloom (Sidalcea malvaeflora), campion flower (Silene scouleri) and coast red onion (Allium dichlamydeum). Many of these plants are considered sensitive species and some of them support important local wildlife, such as the lupine species that are host plants for the endangered Mission blue butterfly (Icaricia icariodes missionensis). SFRPD is obligated to manage the land at Twin Peaks for the Mission blue butterfly as part of the Recovery Plan with the U. S. Fish and Wildlife Service, including the management of oxalis. In recent years, Garlon 4 Ultra is being used to protect these sensitive areas from this invasive weed. The Oxalis pes-caprae is a major threat to the existing biodiversity of wildlife within the native grasslands. If left untreated these areas will greatly interfere with the progress already made in controlling this particular weed.

What it boils down to is the poorly-supported theory that oxalis will take over the world if they let it, an argument Nativist doyen Jake Sigg recently made in his newsletter while defending pesticide use. “Our most serious destroyer of biological diversity is the yellow oxalis, Oxalis pes-caprae. Because it is prolific, aggressive, and effectively practices chemical warfare, it is pushing out native species—the wildflowers that so delight us and which are needed as the base of the food chain for other creatures. Because it can’t be destroyed unless the bulb is killed, herbicides are mandatory.”

By contrast, actual research indicates oxalis is a poor competitor, and even the California Native Plant Society California Invasive Plant Council considers it only moderately invasive (mainly in sand dunes). [Edited to correct the organization reference.]

We understand that some opinions are influential even when opposing evidence surfaces, but in this case the tradeoff is the continued use of the most toxic herbicide that the city allows on its land. We’ve argued before that this tradeoff is not good for people, wildlife, or the environment. (See our presentation-format post: Garlon v. Oxalis in 10 Easy Slides ) We certainly do not wish it to be used near any trail where people go out with their kids and pets.

WE STAND FOR NO TOXIC PESTICIDES IN OUR PARKS

San Francisco Forest Alliance stands for an end to toxic pesticides in our parks. This can be done; the Marin Municipal Water District stopped using herbicides altogether some years ago. It means having a more practical approach to managing the landscape, and not declaring war on various species of plant.

However, we do have some concerns. Here are notes from Tom Borden, a public access advocate:

2017 exemptions
There is only one exemption from the posting requirements. It is for PUC right of ways. I understood pesticides were used at the GGP plant nursery without posting. Where is the exemption? I suspect herbicides are applied above the reservoir at 7th and Clarendon without posting. Where is the exemption for that?

Restrictions on Herbicides for City Properties
A2  Why are applications done by methods other than spray exempted from the requirement to use blue dye? If a stump has been daubed rather than sprayed, how will people know it’s not safe to sit on?

A2  Why say, “or in cases where posting is not otherwise required under the law”? Posting is always required by law, unless an exemption from posting is granted by IPM. Right now there is only one posting exemption on the IPM Exemptions log. If and when IPM issues another posting exemption, the land manager can also request an exemption from the blue marker dye requirement if there is a good reason to avoid the dye. Who does not want to use blue dye? Is it really expensive? Isn’t it beneficial to the people applying herbicides to be able to see what they already treated? Why shouldn’t people be able to see what was treated?

A7  Why can’t herbicides be used on green walls and green roofs? Whatever that logic is, why doesn’t it apply more broadly?

B9  Why don’t the protections for the public and employees extend to areas outside city limits? Do we only care about people in San Francisco?

B9  What is the relevance of public accessibility? The Chapter 3 of the San Francisco environment code protects City employees as well as the public. If “publicly inaccessible parcels” are to have lesser requirements for posting and demarcation, the law requires that the land manager apply for an exemption. As of today, there is only one posting exemption on file, for PUC rights of way. There should also be one for the GGP nursery. Other than that, we are not aware of any other “publicly inaccessible parcels” in the City. The general exception for “publicly inaccessible parcels” should be removed. It just introduces unnecessary ambiguity. If there is a genuinely publicly inaccessible parcel, and City employees can be protected, then IPM can issue an exception for that.

B9  Why are golf courses and areas managed for habitat conservation afforded less public protection? Don’t golfers, kids and hikers deserve protection too? Maybe the behavior of golfers is predictable, but people enjoying our wild parkland could be having a picnic, playing hide and seek, exploring, rolling down a hill, doing almost anything. There should be no exception to the demarcation requirements for “areas managed for habitat conservation”.

B12  If a trail exists, especially one not “actively maintained by City operations”, it is because people use it frequently. If the intent of these rules is to protect the public, all trails should be afforded the same protection. If the intent of these rules is to make life easy for land managers and punish people who use un-designated trails, you are on the right track.

B13  Please remove spray boom “definition” for broadcast spraying. The last part of the second sentence gets to the point, broadcast spraying means indiscriminately spraying all plants in an area, as opposed to targeting specific plants. In 2016 you saw video and photographic evidence that three men with backpack sprayers can perform broadcast spraying. Please use the definition for broadcast spraying that the rest of the world uses.

New thinking on Tier I
The new Restrictions do away with the idea that Tier I herbicides are only to be used when there is a critical need. Now Tier I can be used for anything except for prohibitions 10,11 & 12. The old restrictions limited where Tier I herbicides could be used based on a “need” that was balanced against the risks of use. Where has that gone? This seems like a real step backward.

Now land managers just need a reason that goes beyond cosmetics and they can apply Tier I herbicides anywhere as long as it is more than 15 feet from an area frequented by children and more than 15 feet from the land manager’s designated trails.

While we work toward the “No toxic pesticides in our parks” goal, we try to attend these meetings and believe that we have been able to work with SF Environment over the years to get some improvements.

  • SFRPD improved the signage for pesticide use, and is now encoding the use of colored dye to show where actual spraying has taken place.
  • More practical restrictions on pesticide use.
  • We’re encouraged by SF RPD’s reducing herbicide use in the last three years – excluding the Natural Areas (now the Natural Resources Division) and Harding Golf course, which is managed under contract by the PGA Tour. (The graphs below show pesticide usage by SFRPD ex NAP and Harding, and NAP/ NRD’s pesticide use. Please note that all measurements are in fluid ounces of active ingredient, but the scale on the two graphs are different.)

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.

NRD INCREASES USE OF CANCER-CAUSING ROUNDUP 

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.

GARLON IS WORSE

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.

NEW WAR TARGETING CAPE MARIGOLD

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.

WHAT ABOUT THE REST OF SFRPD?

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 on Blackberry in Fruiting Season

Recently, one of our neighbors was walking on Mt Davidson. It’s the time of the year when the blackberry bushes bear fruit, to the delight of children and the public in general (and not a few animals and birds). She was unpleasantly surprised to find that the bushes were to be sprayed with herbicide.

“It’s the fruiting season!” she noted, wondering if this was legal.

Unfortunately, it is.  In 2016, SF Environment imposed restrictions on spraying blackberry bushes during the fruiting season. But the way the restrictions are written, they apply only to Tier I (“Most Hazardous”) pesticides and not to the Tier II (“More hazardous”) pesticides that the Natural Resources Division (NRD – formerly Natural Areas Program) also uses quite frequently. The NRD commonly uses “the fearsome four” pesticides: Garlon, Roundup, Milestone VM and Polaris (also called Habitat). All of them are toxic in some degree.

The herbicides used in this case are Milestone VM (aminopyralid) and Polaris (Imazapyr). Both are toxic and are classified as “More Hazardous” (Tier II). Imazapyr can damage eyes, and its breakdown product is a neurotoxin, which means it causes nerve damage. Aminopyralid is a newer chemical, but is known to be astonishingly persistent. It’s banned in some places because of that.

 

SF ENVIRONMENT’S PESTICIDE USE RESTRICTIONS

In 2016, the SF Department of the Environment engaged in a lengthy process of trying to improve its restrictions on  some of the most problematic use of pesticides in our parks.

(You can read the entire compliance guidelines here as a PDF. It’s from the SF Environment website. sfe_th_ipm_compliance_checklist – Copy )

Among them, they developed these restrictions:

 Pesticide use

✓ A written recommendation from a licensed Agricultural Pest Control Advisor (PCA) is required for any pesticide use. Departments that do not have PCAs on staff should contact the SF Environment IPM Manager.

✓ Only pesticides on the current SF Reduced Risk Pesticide List may be used. Usage must fall within the “limitations” listed for each product, along with label requirements.

✓ ‘Most hazardous’ (Tier I) herbicides have special limitations:

  • Use is prohibited for purely cosmetic purposes.
  • Use is prohibited within 15 feet of designated paths. If a park map exists, designated paths are those found on the maps. Otherwise, designated paths are those actively maintained by staff.
  • Use is prohibited within 15 feet of schools, preschools, playgrounds, or other areas frequented by children.
  • Use on blackberry bushes is prohibited when fruit are present 
  • If within the City limits, use requires onsite supervision by a licensed person (PCA, QAL/QAC) o No broadcast spraying with a boom is permitted except for golf courses (targeted spraying only)
  • Certain pesticide use is restricted in designated Red-Legged Frog habitat, which includes Golden Gate Park, Lake Merced, and several other areas in San Mateo and Alameda County.

Notification

Posting for pesticide use must be done 3 days before treatment, and remain up for 4 days after treatment, except for least-hazardous (Tier III) products, which require posting only on the day of treatment.

✓ Postings must clearly identify the area to be treated. Signs should be placed at locations most likely to be seen by members of the public using the treated area.

✓ Posting is not required for median strips or rights-of-way when these areas are not intended for public use.

✓ Posting is not required for areas inaccessible to the public. [See our recent article on this: San Francisco Pesticides and Inaccessible Areas]

✓ ‘Most hazardous’ (Tier I) herbicides have special notification requirements:

  • Blue dye must be used, and this must be noted on the posting sign. Blue dye is not required in areas where 1) posting is not required, and 2) staining may occur, such as ornamental stone median strips.
  • When treatment sites that cannot be readily identified by the posting sign alone, a map showing the general location of expected treatment area(s) must be attached to the posting sign.

MORE ACTION REQUIRED

Though the added restrictions in 2016 were a step forward, much more is needed. NRD seems willing to go by the letter of the rules, not the spirit of it. Blackberry should not be treated with persistent herbicides at all, especially not in the fruiting season. It’s going to affect children, wildlife, and anyone who loves picking the berries in season… most parkgoers.

San Francisco Forest Alliance stands for Pesticide-Free Parks – including natural areas.

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

 

Herbicides in San Francisco’s ‘Natural Areas’: 2016 Report

We finally received all the 2016 pesticide use reports from San Francisco Recreation and Parks Department (SFRPD), including of course the Natural Resources Department (formerly the Natural Areas Program). Coincidentally, it’s oxalis season, and by the logic of the NRD – it’s Garlon time. Of which more below.

In April 2016, SF Department of the Environment rolled out its new guidelines for pesticide use. Since then, the other parks sections nearly eliminated pesticides – but not NRD. They reduced their use of Roundup quite drastically (thankfully, since it’s a probable carcinogen). But they increased their usage of Garlon and Imazapyr.

OTHER SFRPD CUT HERBICIDE USE MUCH MORE THAN NRD

San Francisco Recreation and Parks Department (ex Harding Golf Course, which is under a management contract with the PGA Tour) has all but stopped using herbicides – except for the so-called Natural Resources Department.

 

nrd-vs-sfrpd-herbicide-application-2016-smLooking at the whole of 2016, SFRPD used pesticides 159 times. Of those, 143 applications were by the NRD.

NRD used more of nearly all Tier I and Tier II herbicides. It used 48% of the total Roundup SFRPD applied; 100% of the Garlon; 100% of the Imazapyr (Stalker, Polaris); and 99% of the Milestone VM.

Excluding for Greenmatch, a herbicide that is considered organic (but still classified as Tier II), NRD used more Tier I and Tier II herbicides than the rest of SFRPD put together. (As usual, we exclude Harding Golf Course, which is under a management contract to the PGA Tour and uses pesticides to maintain tournament readiness.)

The good news is that NRD has succeeded in reducing herbicide use, mainly by cutting back sharply on Roundup. Even if not as much as other SFRPD departments, it’s progress. It is still not down to 2009  or even 2008 levels, but has reduced substantially from 2013, which was peak pesticide for NRD (then NAP).

nrd-herbicide-volume-ai-2008-2016-sm2

PUC LAND UNDER NRD HERBICIDE REGIMEN

This year, NRD also started managing – i.e. spraying with herbicides – certain parks belonging to SF PUC:

  • Lake Merced,
  • Laguna Honda, and
  • part of Twin Peaks.

Since they are following the same regimen and using NRD staff, we include the PUC data along with NRD information.

WHICH PARKS?

We thought we’d take a look at which parks they treated most often with herbicides in 2016. Bayview Hill was the clear “winner” with 34 applications. McLaren Park was hit 27 times, and Twin Peaks 25 times. Glen Canyon had 10 applications of herbicides, and Mt Davidson was herbicided 8 times.

GARLON, THE MOST TOXIC HERBICIDE PERMITTED BY SF ENVIRONMENT

To return to Garlon, the most toxic herbicide SF Environment allows for use in SFRPD. It’s classified as Tier I (Most Hazardous) and the notation on the list says: Subject to “Limitations on most restricted
herbicides”. Use only for targeted treatments of high profile or highly invasive exotics via dabbing or injection. May use for targeted spraying only when dabbing or injection are not feasible.
HIGH PRIORITY TO FIND ALTERNATIVE

It’s been “High Priority to Find Alternative” in all the years we’ve been studying this issue. Here’s the solution: Stop obsessing over oxalis.

The only current use for Garlon in SFRPD is battling oxalis in “Natural Areas.” It’s been used 23 times in 2016 by NRD – and zero times by all the other departments.

The obsession with oxalis makes no logical sense. Our article Five Reasons it’s Okay to Love Oxalis and Stop Poisoning it points out that:

Honeybee in oxalis flower

Honeybee in oxalis flower

1) It’s already part of the ecological food web in our city, providing nectar to honey-bees, bumblebees, butterflies and other pollinators. Ironically, the pollination doesn’t benefit the oxalis, which doesn’t set seed in San Francisco.

2) It’s good for wildlife, providing food for gophers, a foundation species that in turn feed predators from hawks and owls and herons to coyotes and foxes.

3) The myth is that oxalis leaves the ground bare after it dies down in summer. Actually, it enriches the soil with phosphorus, which benefits the grasslands in which it grows.

4) Oxalis has little impact on native plants. NRD argues that oxalis takes over grasslands and destroys them, particularly the native grasses. However, grasslands in most of California including San Francisco are dominated non-native grasses. The change occurred over 100 years ago, when these grasses were planted for pasture. So the grassland that NAP is defending with herbicides are primarily non-native anyway.

According to a study: “Oxalis is a poor competitor. This is consistent with the preferential distribution of Oxalis in disturbed areas such as ruderal habitats, and might explain its low influence on the cover of native species in invaded sites.
The California Invasive Plant Council rates its invasiveness as “moderate,” considering it as somewhat invasive in sand dunes and less so in coastal bluff areas.
oxalis and california poppies sm
In San Francisco, every place where oxalis grows is already a disturbed environment, a mix of non-native grasses and plants with native plants (some of which have been artificially planted).  Here,  oxalis appears to grow happily with other plants – including, for instance, the native California poppy in the picture above.

5) Kids love it, and it’s edible. Parents know that children will often nibble on “sourgrass” – indeed, so do parents sometimes! Adding toxic herbicides is a poor idea, especially since it is usually applied during the flowering season.

Photo credit: Badjonni (Creative Commons - Flickr)

Photo credit: Badjonni (Creative Commons – Flickr)

So, to summarize:

“There’s no sign that oxalis has a negative impact on wildlife, and plenty of evidence it’s already part of the ecological food web of our city.  The evidence also suggests it’s not having a negative effect on other plants in San Francisco either. Lots of people find this flower attractive; one writer described it as the city smiling with Bermuda buttercups.

In any case, even Doug Johnson of the California Invasive Plant Council doesn’t think it’s worth attacking at a landscape level: the payoff isn’t worth the expense. Removing it from the hundreds of acres in Natural Areas isn’t as simple as eradicating it from a small yard where it’s clashing with the garden design. It requires a lot of work, a lot of powerful herbicides, a multi-year effort – and for what?

The justification for using strong pesticides like Garlon to control it is weak. We call on NAP to stop using Tier I and Tier II herbicides altogether.”

NEW SURFACTANT UNDER-STUDIED

NRD has been trying to reduce the amount of Garlon in each application used by changing to a new surfactant for Garlon: CMR Silicone Surfactant. (A surfactant is a chemical used with a pesticide to make it spread better.)

This is also a dubious chemical.A 2016 NIH paper, Toxicological Risks of Agrochemical Spray Adjuvants: Organosilicone Surfactants May Not Be Safe, suggests that these surfactants have a deleterious effect on bees (which we know visit oxalis), and point out that they are under-regulated:

“Agrochemical risk assessment that takes into account only pesticide active ingredients without the spray adjuvants commonly used in their application will miss important toxicity outcomes detrimental to non-target species, including humans.”

(You can download the whole paper as a PDF here: fpubh-04-00092

Citation:
Mullin CA, Fine JD, Reynolds RD and Frazier MT (2016)

Toxicological Risks of Agrochemical Spray Adjuvants: Organosilicone Surfactants May Not Be Safe.
Front. Public Health 4:92.
doi: 10.3389/fpubh.2016.00092