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.

 

 

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Roundup, Garlon, and Pesticide-Free Parks

New evidence has emerged that Monsanto influenced the Environmental Protection Agency  (EPA) to downplay the cancer-causing risk of Roundup. This pesticide, and others that may be even more hazardous, are used in our parks and watersheds. And now, since San Francisco is adding ground water to the Hetch Hetchy water we have been getting, our water may contain traces of these hazardous chemicals.

 

MONSANTO OFFERED TO GHOST-WRITE KEY REPORT SECTIONS ON ROUNDUP

Bloomberg and other news sources show that Monsanto offered to ghost-write sections of the EPA report on glyphosate, and sought the help of an EPA official to kill the reports that glyphosate is a probable carcinogen.

We reported earlier that a letter by an EPA employee Dr Marion Copley, written as she was dying, says: “It is essentially certain that glyphosate causes cancer.” She also said it is an endocrine disruptor, and alleged corruption within the EPA.

A California Superior Court judge has ruled that Roundup can be added to the Prop 65 list of known carcinogens, despite Monsanto’s attempts to block such a listing. “State regulators were waiting for the formal ruling before moving forward with the warnings, said Sam Delson, a spokesman for the state Office of Environmental Health Hazard Assessment.” 

Dr Copley’s letter only used glyphosate (Roundup, Aquamaster) as an example. The letter hinted that other chemicals might have fared similarly – that is, not been properly evaluated because of corporate influence on EPA employees. We the public cannot assume that toxicology tests performed by the companies producing the pesticides or scientists they may pressure are sufficient to prove the chemicals are harmless.

ROUNDUP AND GARLON IN OUR PARKS

Roundup has been used for years by SFRPD and other city entities. Only in  2015 was it designated a Tier I (most hazardous) pesticide. We tracked its use in San Francisco’s Natural Areas from 2008 to 2016. (It’s also used in other parks, and by the PUC, but we have not compiled those data.)

In the bar-graph here, the green section represents Roundup. The Natural Resources Department (NRD) increased its use of Roundup each year from 2009 to 2013, then decreased it in 2014, slightly increased it in 2015, and now has brought it down to below 2010 levels – though not as low as in 2009 or 2010.

The orange section is Garlon, a Tier I (Most Hazardous) herbicide that’s considered even more toxic than Roundup. Garlon is 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 )

Nowadays, Garlon in San Francisco is used only by the Natural Resources Department against Bermuda buttercups (oxalis).

PROGRESS – AND A NEW PROBLEM ABOUT TO HAPPEN

SF Environment has responded to community concerns (including a petition opposing pesticides in schools and parks that has more than 12,000 signatures) by introducing a list of restrictions on the use of Tier I (but not Tier II) chemicals. (Their Tier system classifies all allowable pesticides as Tier III – Least Hazardous, Tier II – More Hazardous, and Tier I – Most Hazardous.)

Though we believe the restrictions do not go far enough, they are a start. SF Environment has not published the final version, but there is a current draft. We are providing our comments to the Commission for the Environment and to SF Environment in the hope that they will modify the conditions under which use of Tier I herbicides are permitted. (We’ll post about this soon.)

But – starting 2017, SF Environment is going to approve the use of something new: Milestone VM Plus. It’s a mix of Garlon and Milestone VM (aminopyralid). This combination is being approved as a Tier II herbicide. Amino-pyralid is the pesticide so persistent that it lasts for years – and if an animal eats treated vegetation, its droppings become toxic too. It was considered a Tier I pesticide until SF Environment decided to reclassify it as Tier II in 2013. It’s banned in New York and effectively in a number of other states too.

We’ve protested. Here’s our letter:

Dear Commissioners, Director Raphael, and Dr Geiger,

We are dismayed that a new triclopyr-based pesticide is being added to the 2017 pesticide list, and in combination with aminopyralid – and that too as Tier II. This is at a time when we’re working to *remove* triclopyr (as Garlon) from the list. We refer to Milestone VM Plus, which is Aminopyralid, triisopropanolamine salt, 2%; Triclopyr, triethylamine salt, 16%. It’s for injection and for tree stumps. As we understand it, this is a mixture of Garlon 3 and Milestone.

This could be disastrous. Triclopyr is one of the most toxic herbicides still on the list. And Milestone VM (Aminopyralid) is uncannily persistent – it can last for years. If vegetation treated with it is eaten by animals and excreted, the excreta still contains enough herbicide to harm plants. Until 2013, Milestone was considered a Tier I chemical for its persistence – and then changed to Tier II (possibly at the request of the Natural Resources Department, since other SFRPD departments don’t use Milestone VM.)  If Milestone VM Plus is used on trees in a forest or stand of trees, it could weaken adjacent healthy trees through the intergrafted root network, thus destabilizing groups of trees.

We urge you to delete Milestone VM Plus from your restricted list. It’s no better than using Garlon with some added Milestone. If it must be retained, please classify it as Tier I.

Respectfully,
San Francisco Forest Alliance

[Edited to Add: Unfortunately, Milestone VM Plus was approved and classified as Tier II. The 2017 List is given here as a PDF: sfe-th-2017-reduced-risk-pesticide-list ]

HERBICIDES IN OUR WATER?

This year,  San Francisco started adding well water drawn from under the city to our tap water. Roundup or Aquamaster (glyphosate) and other pesticides such as Garlon (triclopyr), Milestone (aminopyralid), and Stalker (imazapyr) – and their breakdown products, some of which may be even more toxic – could well be contaminating our water supply.

Pesticide supporters argue it doesn’t matter, because the amounts are small. But:

  • Herbicides (and other chemicals) could interact in ways that are unpredictable. No one has researched them.
  • There’s no way of knowing how much the cumulative exposure is for any individual. This is particularly a concern for children, whose low body weight and fast growth make them especially vulnerable; and for people with illnesses or chemical sensitivities.
  • Importantly, if they are endocrine disruptors – which means they act like hormones in the human body – tiny amounts can have a disproportionate impact. It’s an exception to the “dose makes the poison” saying. Here’s an article that cites references to studies showing endocrine disruption from glyphosate: Why Low Dose Pesticides are Still Hazards.

PESTICIDE FREE PARKS

We have heard some parents don’t take their children to Glen Canyon any more, owing to pesticide concerns. One of the restrictions that SF Environment will impose is no use of Tier I pesticides in areas frequented by children. (Tier II herbicides will still be allowed.)

While the San Francisco Forest Alliance asks for no pesticides in our parks (and watersheds), San Francisco could make a start by converting parks with children’s play areas to Pesticide-Free Parks. Here’s an example from Seattle.

Opponents of restricting pesticide use in this way might fear that the park looks awful, so we went and had a look. It was a sunny afternoon, and the park was beautiful.


The park was full of kids of all ages, from babies and toddlers to teenagers. One man rocked his tiny pink-clad baby daughter.  Another dad brought his small son to kick a ball around in the grass. School age kids chased each other with squirt-guns. Some families brought their dogs, who are allowed in the park. It must be a relief to know that you can safely take your family to such a park, and not encounter Roundup or Garlon, Stalker or Milestone VM.

The park has a nice playground.

It also had an organic community garden…

… complete with a green roof.

And a rain garden.

And a multilingual welcome sign.

It was a lovely example of the kind of Inclusive Environmentalism that San Francisco Forest Alliance stands for.

Roundup Herbicide and Liver Disease – a New Study

petition picture against roundup

A recent study published by Nature.com shows evidence of liver disease from long-term low-dose exposure to Roundup. Predictably, Monsanto has been dismissive. Rats that consumed a very little Roundup in their water developed liver problems. [Here’s the study: Mesnage, R. et al. Multiomics reveal non-alcoholic fatty liver disease in rats following chronic exposure to an ultra-low dose of Roundup herbicide. Sci. Rep. 7, 39328; doi: 10.1038/srep39328 (2017)]

TWO YEARS, LOW DOSES OF ROUNDUP

The study, performed by scientists from King’s College in the UK and University of Caen, France, took two years. They designed it to evaluate a realistic situation where exposure is to the formulated product, not the active ingredient (glyphosate) alone. They gave a group of rats water contaminated with a small amount of Roundup, while the control group was given clean water.

“… a 2-year study was conducted where rats were administered with a Roundup GBH via drinking water at a concentration of 0.1 ppb (0.05 μg/L glyphosate; daily intake 4 ng/kg bw/day), which is an admissible concentration within the European Union (0.1 μg/L) and USA (700 μg/L)18. The results showed that Roundup caused an increased incidence in signs of anatomical pathologies, as well as changes in urine and blood biochemical parameters suggestive of liver and kidney functional insufficiency.”

THE RESULTS

The researchers found that when the rats were young, the effects were not significant, but as the rats aged, the ones consuming Roundup developed liver disease much more than the control group that drank clean water.

“The results of the study presented here imply that chronic consumption of extremely low levels of a GBH formulation (Roundup), at admissible glyphosate-equivalent concentrations, are associated with marked alterations of the liver proteome and metabolome. These changes in molecular profile overlap substantially with biomarkers of [Non-alcoholic Fatty Liver Disease] NAFLD and its progression to NASH [non-alcoholic steatohepatosis].”

We should caution that the sample size was small (10 rats in each group), and the researchers themselves point out that they cannot be certain that the effect carries over to humans. Nevertheless, it’s certainly another reason for caution, and a lot of sites concerned with chemicals are picking up the news. For example: The Organic Consumers Association.

 

 

A “Roundup” Map of San Francisco Parks and Playgrounds

A New Map Reveals Carcinogenic Glyphosate in San Francisco Parks and Playgrounds

In collaboration with the activist group Rev. Billy and the Stop Shopping Choir,  the San Francisco Forest Alliance has published an online interactive map to show San Francisco citizens how carcinogenic glyphosate (commonly sold as RoundUp) is used in parks and playgrounds. It shows where glyphosate has been sprayed in our parks in 2014 and 2015.

Glyphosate Spraying - online interactive map

Glyphosate Spraying in San Francisco Parks (Click to go to interactive version)

Monsanto’s RoundUp and its key ingredient glyphosate, are major weapons in the San Francisco Parks Department’s arsenal of herbicides. Meanwhile, scientific evidence that glyphosate is toxic is approaching the level of scientific consensus.

The International Agency for Research on Cancer (IARC), the specialized cancer agency of the World Health Organization said (March 2015) says glyphosate is a probable carcinogen to humans. Scientific studies have found glyphosate to cause non-Hodgkin’s lymphoma and other cancers, birth defects, and celiac disease, allergies, asthma, chronic fatigue syndrome.  Glyphosate is persistent in body tissue, blood and breast milk in humans.  The non-profit organization, Moms Across America, claims exposure to RoundUp has cause pregnancy problems, including stillbirths.

We are asking the SF Dept. of Environment to remove Tier I and Tier II herbicides (especially Roundup/ Aquamaster and Garlon 4 Ultra) from the 2016 Reduced Risk Pesticide List, without exceptions.

ABOUT THE MAP

The map data is based on information for 2014 and 2015 that we obtained from San Francisco Recreation and Parks Department (SFRPD) under the Sunshine Ordinance.  It  covers all lands managed by the SFRPD, including parks, playgrounds, and Natural Areas. (It excludes Harding Golf Course, which does use glyphosate regularly, because it’s managed under contract by the PGA Tour and is required to maintain tournament-readiness at all times.) The locations are as accurate as we could make them based on the data SFRPD provides; they identify the parks but may not indicate the precise spot where the pesticide was applied.

ABOUT REV. BILLY AND THE STOP SHOPPING CHOIR

We collaborated in the making of the map with Rev. Billy and the Stop Shopping Choir, an organization of satirical activist performers protesting the evils of consumerism.  They first created a glyphosate use map for New York. This map of San Francisco is their second, and they plan to extend it to other Bay area counties.

Rev. Billy will be in San Francisco in April 2016, doing a reading from his new book, The Earth Wants YOU! on April 20, 2016 at 7pm – 9pm at the City Lights bookstore, 261 Columbus Ave, San Francisco, CA 94133.

From their press release:

“During the week of April 18th, Reverend Billy, who resided in the Bay area for more than twenty years, will levitate the DeYoung Museum, one of the sites of where the San Francisco Parks Department applies deadly glyphosate. He will exorcise the world-renowned bastion of high culture and give it a good spiritual scrubbing with local activists.

“Reverend Billy’s new book, The Earth Wants YOU!, will be published by City Lights Publishers on Earth Day, April 22, 2016. He will read from his new book at eight independent bookstores in Northern California and at UC Santa Cruz in April. More information about the book and tour HERE. “

Their media contact: Marnie Glickman, 415-259-7121, marnie.glickman@gmail.com

San Francisco Herbicides 2015: Why Better Isn’t Good Enough

SF Natural Areas Pesticide by Active Ingredient 2008-2015 sm

NAP’s pesticide usage is down again in 2015

We have some nearly good news. After years of increasing pesticide until 2014, the 2015 data shows Natural Areas Program (NAP) again used less herbicides than in the year before – though they applied it more often. The volume of herbicide used was the smallest amount since 2010, but the number of applications the highest since 2008 (the earliest data we have).

So why isn’t this good enough?

  • The main reason is the growing consensus that herbicides are more toxic than the manufacturers claim. Roundup (glyphosate), long regarded as a “safe” pesticide (though not by us – we wrote about the worrisome scientific data HERE and HERE) has been declared a probable carcinogen. Herbicides don’t have a place in our parks where they could impact people – especially those who have reasons to worry about their toxic load – children, who are more sensitive because of their size and fast growth, and pets. People just don’t want any herbicides in our parks, especially in “Natural Areas.”
  • SF Natural Areas Program Number of pesticide applicns 2008-2015 sm

    But the number of applications is up.

    The second is that though NAP has reduced the amount of herbicides they use, they have considerably increased the number of applications. This means that park-goers have a higher probability of encountering pesticide use.

  • Some of these pesticides remain in the soil and environment for months, even years, after application. Imazapyr’s breakdown product is a neurotoxin. Many of the Natural Areas are on high ground, or in watersheds, and poisons applied there can spread unpredictably.
  • NAP used a dispropotionately large amount of the most toxic herbicides compared with all of SF Recreation and Parks Department (SFRPD):
    • 35% of the Roundup (glyphosate);
    • 80% of the Garlon (triclopyr) and
    • nearly 100% of the Stalker (imazapyr) and Milestone (aminopyralid).

GARLON USAGE: TOXIC AND UNNECESSARY

A case in point is Garlon (triclopyr). This is one of the most toxic herbicides permitted on city-owned properties, with a Tier I (Most Hazardous) rating.

Photo credit: Badjonni (Creative Commons - Flickr)

Photo credit: Badjonni (Creative Commons – Flickr)

NAP is the most regular user of Garlon, mainly to poison yellow oxalis.  In 2015, it accounted for 80% of the Garlon used by SFRPD.They are trying to reduce usage with a new surfactant (the stuff used to dilute the herbicide and let it spread better), CMR Silicone Surfactant. We are unsure whether this is an improvement but will research it further. The Label is here: Cmr_Silicone_Surfactant_(0198050402)_Label

If NAP stopped trying to poison oxalis each spring, Garlon could be removed from the approved list of pesticides. Instead, they used Garlon five times in December, on Twin Peaks, Glen Canyon, Mount Davidson, and McLaren Park. These are places where children and pets could easily encounter the herbicide.

coyote pouncing in oxalis field - copyright Janet Kessler

There’s no need to battle oxalis. It’s beloved by children, attractive to bees and butterflies, useful to other wildlife in the food chain, and a valuable plant that improves the soil for grasses. Moreover, it disappears after its flowering period is over. There is no evidence that it adversely affects other plants in what is essentially a non-native grassland.

ROUNDUP, THE PROBABLE CARCINOGEN

Roundup is the most commonly used pesticide in our parks, and NAP uses a disproportionate amount. It applied Roundup over 70 times in 2015, and the volume used was more than in 2014. We would have expected that after the World Health Organization finding, NAP would stop using this herbicide. It appears not.

The problem is that NAP targets a lot of plant species it considers invasive – at the last count, around three dozen different species. Unless it changes its objectives, it will always need herbicides – Roundup, Stalker/ Polaris, Milestone VM, Garlon 4 Ultra. If it reduces one, there’s a temptation to increase another.

GETTING RID OF HERBICIDES IN NATURAL AREAS

San Francisco can get rid of herbicides in natural areas. It will mean a change in the mindset of land managers. Non-native plants are valuable in wild places for their ecological benefits – carbon capture, wildlife habitat and food, soil enrichment and erosion prevention among others. If we must create native plant gardens, they should be small enough that they can be managed by manual gardening. Though we have issues with what UCSF is doing in Sutro Forest, in one matter they have a clear win: No pesticides have been used there since 2008, and UCSF have committed not to use any herbicides in Sutro Forest. That includes the native plant garden on the summit.

SFRPD REDUCES HERBICIDE USAGE IN 2015

SFRPD Pesticides (ex Harding and NAP) 2013-15SFRPD reduced its herbicide usage in 2015 as well. The numbers for 2014 were exceptionally high because of large amounts of Tier I pesticides used in the Kezar Stadium renovation, and mistakenly in Gleneagles Golf Course. Without those two factors, usage would have declined in 2014 and been nearly flat in 2015.

A word about Greenmatch and Avenger. These are based on lemongrass oil, or what is called a “botanical.” It’s actually considered acceptable for organic gardening. However, it’s classified as Tier II because it can cause allergic reactions in its undiluted form.

KEZAR STADIUM TIER I USE CONTINUES

The renovation of Kezar Stadium has used a lot of Tier I herbicide.

  • In November and December 2014, they used 208 fluid ounces of Drive XLR8 for turf renovation. This was a one-off Tier I pesticide use, and may have been associated with bird deaths in the area.
  • In February 2015, they used 320 fluid ounces of Fiesta, also classified as Tier I, followed by 24 ounces of Aquamaster (which was subsequently classified as Tier I).
  • In June 2015, they used 16 ounces of Turflon (triclopyr), also Tier I and one of the few times any SFRPD department but NAP used triclopyr.

They have also used some Tier III herbicides – actinovate and fosphite – which we presume are a lot less toxic. (Edited to Add: They are not included in the graph above for that reason.)

Public Opposition to Pesticide Use in our Public Parks

This article has been republished with permission from ‘Death of a Million Trees,’ a blog that fights unnecessary tree felling in the San Francisco Bay Area. If you wish to sign the petition opposing the use of Roundup (glyphosate) in our parks, please sign here:

SIgn to Oppose Toxic Herbicides

PUBLIC OPPOSITION TO PESTICIDE USE IN OUR PUBLIC PARKS

On November 19, 2015, a visitor to Mount Davidson park in San Francisco video recorded a pesticide application that is available here:

glyphosate spraying on Mt Davidson - nov 19, 2015

One of the people who saw that video reported several concerns regarding that pesticide application to the city employees who are responsible for the regulation of pesticide use in San Francisco. Here is the email he sent to Kevin Woolen in the Recreation and Park Department and Chris Geiger in the Department of the Environment:

To: Kevin Woolen kevin.woolen@sfgov.org

Dear Mr. Woolen,

I understand that you are responsible for the records of pesticide applications on properties managed by San Francisco’s Recreation and Park Department. I have heard you speak at public meetings, so I am aware that you have some expertise in that area. Therefore, I am writing to you about a pesticide application on Mt. Davidson on November 19, 2015. That pesticide application was recorded by this video: https://www.facebook.com/ForestAlliance/videos/934479473312166/?fref=nf

I have several concerns about this pesticide application:

  • One of the herbicides that was sprayed was Stalker with the active ingredient imazapyr. I notice that most of the spraying was done around a tree, which was not a target of the application according to the posted Pesticide Application Notice. As you may know, imazapyr is not supposed to be sprayed under and around non-target trees according to the manufacturer’s label: http://www.cdms.net/ldat/ld01R013.pdf: “Injury or loss of desirable trees or other plants may result if Stalker is applied on or near desirable trees or other plants, on areas where their roots extend, or in locations where the treated soil may be washed or moved into contact with their roots”

Here is a newspaper article about unintentional damage done to trees by spraying an imazapyr herbicide beneath them: http://www.mlive.com/news/grand-rapids/index.ssf/2012/09/no_quick_fix_for_herbicide_dam.html

  • The Pesticide Application Notice says that the application method will be “spot treatment/daub cut stem.” This does not seem to be an accurate description of the application method on November 19th. It seems that “backpack sprayer” would be a more accurate description of this particular pesticide application.
  • The Pesticide Application Notice says that Himalayan blackberries were one of the targets of this Pesticide Application. As you know, birds and other wildlife cannot read the signs that are posted to warn the public about these applications. Can you assure me that the Himalayan blackberries were no longer fruiting? Does the Recreation and Park Department have a policy against spraying vegetation when there are fruits eaten by birds and other wildlife? If not, would the Recreation and Park Department consider adopting such a policy?
  • Although Garlon was not used in this particular pesticide application, it is often used in San Francisco’s so-called “natural areas.” Therefore, it is worth mentioning that Garlon is also known to be mobile in the soil and there are documented incidents of it damaging non-target trees when it has been sprayed on the stumps of nearby trees after they were destroyed.

Thank you for your consideration. I hope you will share my concerns with the staff and contractors who are engaged in these pesticide applications.

Cc: Chris Geiger chris.geiger@sfgov.org

This is not an isolated incident. Park visitors in San Francisco have been complaining for years about pesticide use in parks that were designated as “natural areas” over 15 years ago. Ironically, those areas were never sprayed with pesticides before being designated as “natural areas.” In fact, they really were natural areas prior to being officially designated as such. Plants and animals lived in peace in those places before being “managed” by people who are committed to eradicating all non-native plants in many of San Francisco’s parks.

What can you do about it?

If you are opposed to pesticide use in San Francisco, or you object to the pointless destruction of harmless plants that are useful to wildlife, here are a few things you can do to express your opinion and influence the public policy that allows pesticide use in the public parks of San Francisco:

  • You can join over 11,000 people who have signed a petition to prohibit the use of pesticides in public parks. The petition is HERE. The San Francisco Chronicle reported on pesticide use in San Francisco’s parks and the petition against that use. (Available HERE)
  • You can sign up HERE to be notified of the annual meeting in which pesticide policy in San Francisco is discussed for subsequent approval by the Environment Commission. That meeting has been scheduled in December in past years. Update: The annual meeting has been announced. “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)” The meeting agenda is available HERE.
  • You can apply for one of the two vacant seats on the Environment Commission. These seats have been vacant for nearly a year. In the past, the Environment Commission has actively promoted pesticide use in San Francisco’s “natural areas.” Qualifications and duties of commissioners are available HERE.
  • Appointments to the Environment Commission are made by Mayor Ed Lee. If you don’t want to serve on the Environment Commission, you can write to Mayor Lee (mayoredwinlee@sfgov.org) and ask him to appoint people to the Commission who do not support the use of pesticides in San Francisco’s public parks.

The parks of San Francisco belong to the people of San Francisco. They have paid to acquire those properties for public use and they are paying the salaries of those who are “managing” the parks. If you don’t like how parks are being managed, you have the right to express your opinion. Our democracy works best when we participate in the public policy decisions that affect us.

What does this have to do with the East Bay?

Our readers in the East Bay might wonder what this incident has to do with you. Parks in the East Bay are also being sprayed with herbicides for the same reasons. HERE are reports of pesticide use by the East Bay Regional Park District.

Many of the pesticide applications on the properties of EBRPD are done by the same company that sprayed herbicides on Mount Davidson on November 19, 2015. That company is Shelterbelt Builders. You can see their trucks in the above video. Pesticide use reports of San Francisco’s Recreation and Park Department often report that pesticide applications were done by Shelterbelt.

Shelterbelt began the eradication of non-natve vegetation in Glen Canyon in November 2011

Shelterbelt began the eradication of non-natve vegetation in Glen Canyon in November 2011

Shelterbelt Builders is based in the East Bay. One of its owners is Bill McClung who is a member of the Claremont Canyon Conservancy and a former officer of that organization. The Claremont Canyon Conservancy is the organization that is demanding the eradication of all non-native trees on public land in the East Bay Hills. Here is a description of Mr. McClung’s responsibilities on Shelterbelt’s website:

“Bill McClung joined Shelterbelt in 1997 to help refocus Shelterbelt on native plant restoration and open land management/fire safety. After his house burnt down in the 1991 Oakland Fire, this former book publisher became interested in how wildland and fire are managed in the East Bay Hills. He became a member of the Berkeley Fire Commission in 1994 and has a strong interest in the vegetation prescriptions of the Fire Hazard Program & Fuel Reduction Management Plan for the East Bay Hills issued in 1995 by the East Bay Hills Vegetation Management Consortium and the East Bay Regional Park District Wildfire Hazard Reduction and Resource Management Plan Environmental Impact Report of 2009/10. He has managed many properties in the East Bay where wildfire safety and native habitat preservation are twin goals, and continues to work on interesting and biologically rich lands in the Oakland Hills.”

Claremont Canyon Conservancy

The Claremont Canyon Conservancy held their annual meeting on November 15, 2015. Oakland’s Mayor, Libby Schaaf, was one of the speakers. Although she took questions at the end of her presentation, one of the officers of the Conservancy called on the questioners. There were many people in the audience who are opposed to the FEMA projects that will destroy over 400,000 trees in the East Bay Hills and many of us tried to ask questions. With one exception, the person controlling the questions only called on known, strong supporters of the FEMA project. Therefore, those who wished to express their opposition to the FEMA projects to the Mayor were denied that opportunity. Fortunately, there were many demonstrators outside the meeting who could not be denied that opportunity.

Demonstration at meeting of Claremont Canyon Conservancy, November 15, 2015

Demonstration at meeting of Claremont Canyon Conservancy, November 15, 2015

Norman LaForce was the other main speaker at the meeting. He is an elected officer of the Sierra Club and he identified himself as one of the primary authors of the project to destroy all non-native trees in the East Bay Hills. (An audio recording of his complete presentation is available here: https://milliontrees.files.wordpress.com/2015/11/norman-laforce-sierra-club-11-15-15.m4a ) This is the paraphrased portion of his presentation specifically about the herbicides that will be used by the FEMA project:

“Part of the FEMA program will be to use herbicides in a concentrated, careful program of painting or spraying herbicides to prevent the trees from resprouting. It may need to be done more than once but ultimately the suckers give up. There is no other way to do that cost effectively.

People are saying that glyphosate causes cancer. Radiation causes cancer but when people get cancer they are often treated with radiation. Nobody tells them they can’t have radiation because it causes cancer.

There are a lot of people of a certain age in this room who are probably taking Coumadin as a blood thinner for a heart condition. Coumadin is rat poison. Nobody tells them they can’t take Coumadin.*

You must take dosage and exposure into consideration in evaluating the risks of pesticides.

Nature Conservancy used glyphosate on the Jepson Prairie.

State Parks used Garlon on Angel Island when they removed eucalyptus.

The European Union says that glyphosate does not cause cancer, so I don’t know if it does. I’m not going to take a position on that.

Now they are saying that red meat causes cancer.

We need to put aside the question of pesticides. They will be used properly. We must proceed in a scientific manner.”

We leave it to our readers to interpret Mr. LaForce’s justification for pesticide use. He seems to be suggesting that pesticides are good for our health. There are instances in which pesticides do more good than harm, but using them to kill harmless plants in public parks isn’t one of them, in our opinion. Since many chemicals accumulate in our bodies throughout our lives, it is in our interests to avoid exposure when we can. If we must take Coumadin for our health, that’s all the more reason why we should avoid unnecessary exposure to rat poison when we can.

Connecting the dots

We have tried to connect the dots for our readers. Here are the implications of what we are reporting today:

  • Pesticide applications in San Francisco are probably damaging the trees that are not the target of those applications. The food of wildlife may be poisoned by those pesticide applications.
  • You can influence the public policy that is permitting pesticide use in San Francisco.
  • The same company that is spraying pesticides in San Francisco is also doing so in the East Bay.
  • That company is also actively engaged in the attempt to transform the landscape in the San Francisco Bay Area to native plants. They have an economic interest in native plant “restorations.”
  • The Sierra Club is actively promoting the use of pesticides on our public lands.

*Coumadin is prescribed for people who are at risk of heart attack or stroke caused by blood clots. Coumadin thins the blood and suppresses blood coagulation. Rat poison kills animals by bleeding them to death. There is a fine line between preventing blood clots and bleeding to death. Therefore, people who take Coumadin have frequent blood tests to check that the dosage is at the optimal level. Rat poisons are killing many animals that are not the target of the poison. Animals such as owls, hawks, vultures are often killed by eating dead rodents that have been poisoned. We should not conclude that rat poison is harmless because humans are using it in carefully controlled doses. Herbicides being sprayed in our public lands are not being closely monitored as Coumadin use is.

 

Truck-size Loopholes in San Francisco’s Pesticide Plan

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