Mt Davidson: Tree Destruction Imminent?

There’s a lot of activity at the Juanita entrance of Mt Davidson, and neighbors fear the San Francisco Recreation and Parks Department (SFRPD) is rushing through its tree-felling program. At a time when we need trees more than ever to fight climate change, and mudslides in Southern California illustrate the devastating effects of destroyed trees and vegetation, this would be egregious.

Here’s a note from a forest-lover:

What I’ve seen so far as of last week is preparation and road, trail widening with landing areas for equipment, but no big cuttings or equipment in the interior yet. Just the one big landmark, living tree marked with dots, and all the prior destruction.”

Huge eucalyptus tree on Mt Davidson, San Francisco, marked with 3 green dots

Do these dots mark this iconic tree for killing?

TRAILS BEING WIDENED FOR HEAVY EQUIPMENT?


What equipment will go up here? Maybe a “Brontosaurus”?

TREES DESTROYED EARLIER

Tree have been destroyed on Mount Davidson some years ago, and this prior destruction gives some idea of what the desired end-condition is for the next round. The so-called “boneyard” has stumps of dead trees.

 

This tall mature tree was “girdled.” That’s a process of destroying cutting a deep ring around the tree, so that food and water cannot be transported and the tree starves to death.

A beautiful green and flourishing tree that provided food and habitat for birds, and brought joy to forest lovers, is a dead skeleton.

THE BEAUTIFUL FOREST WE ARE LOSING

The lovely forest we are losing is beautiful and historic, and provides habitat for a huge number of birds. But it’s not just beauty and habitat. These trees provide important eco-system services.  Some examples:

  • They stabilize the mountain, with their intergrafted roots forming a living geo-textile. The horrible mudslides in Southern California illustrate how important this is.
  • They fight pollution, especially pollution from particulate matter, by trapping the particles on their leaves until rain or fog drips them to the forest floor where they are not in the atmosphere – or our lungs.
  • They form a wind-break in what would be one of the windiest areas of the city, with the wind blowing in straight off the sea.
  • They regulate water flows, so that when it rains hard, the forest acts as a sponge, absorbing the water and letting it flow out gradually.
  • They catch moisture from the fog during summer, making the mountain damp and reducing fire hazard.

Please let City Hall and SFRPD know that you want this forest protected and saved, not gutted. The plan is to remove 1600 trees!

[Update 1/19/18:  We spoke with the contractor on site. Seven trees have been cut down, and that completes this contract. Hopefully we will have more public notice and explanation if other tree removals are planned.]

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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.)

Trees Cut Down in McLaren Park with No Warning

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

.

— xxx—

Sept 14, 2017

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

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

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

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

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

— xxx—

Here’s the email of the Parks Commission: recpark.commission@sfgov.org  and Telephone: 415-831-2750
Here’s a current list of the emails of the Mayor and the Board of Supervisors.

mayoredwinlee@sfgov.org,
Norman.Yee@sfgov.org,
sandra.fewer@sfgov.org,
Mark.Farrell@sfgov.org,
Aaron.Peskin@sfgov.org,
Katy.Tang@sfgov.org,
breedstaff@sfgov.org,
jane.kim@sfgov.org,
jeff.sheehy@sfgov.org,
Hillary.Ronen@sfgov.org,
Malia.Cohen@sfgov.org,
Ahsha.Safai@sfgov.org

 

Where Did The “Natural Areas Program” Come From?

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

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

 

THE NATURAL AREAS PROGRAM – BACKGROUND INFORMATION

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

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

BEGINNINGS

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

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

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

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

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

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

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

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

NO OVERSIGHT

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

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

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

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

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

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

NAPCAC

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

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

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

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

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

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

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

NAPCAC FINAL REPORT

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

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

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

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

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

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

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

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

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

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

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

MINORITY REPORT

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

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

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

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

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

MANAGEMENT PLAN APPROVAL AND EIR

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

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

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

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

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

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

Felling Trees Will Harm Rare Frogs in Sharp Park

The Natural Resources Department (NRD -formerly called the Natural Areas Program) is planning to cut down more than 15,000 trees in Pacifica’s Sharp Park, mostly on hillsides east of Highway 1. This is supposed to benefit the two species that live around there – the threatened red-legged frog and the endangered California garter snake. It will most likely threaten them still further.

THE LAKE OF THE RED-LEGGED FROG

4 Lake and trees in Sharp Parkcalifornia-red-legged-frog-the-frog-book1906

This lake is red-legged frog habitat. And it’s not just good for the endangered frog, and presumably the endangered snakes that preys on it. All kinds of other wildlife use it. Observers have seen everything from bobcats to quail to rabbits in the area.

The lake, which lies to the east of Highway 1 in Sharp Park, was made by damming a seasonal creek. On the left of the picture above, you can see the earthen dam covered with greenery. Now a naturalized pond, it was originally part of the irrigation system for the Sharp Park golf course, and was fed water through pipes and a cistern. Now the golf course gets its water elsewhere, the cistern has been filled in, and the pipes in disuse or gone.

Where the old tank was in Sharp Park Archery Range

This is where the old cistern was filled in. It’s invisible now under wildflowers and shrubs.

All the water in the lake now comes from the watershed created by the forested hills around.  Since this park lies within the fog belt, the tall trees catch the water and rain it down into the pond, even in summer. As a result, the pond has water through the year. (The photos here were taken in June last year. Everything was lush and green and there was no sign of any drought.)

7 Idyllic forest in Sharp Park archery range

So what happens when the trees are felled? We expect two adverse impacts on habitat.

  • First, and immediately, there will be an increase in erosion, bringing mud and debris into the lake and affecting its water quality.
  • Longer term, the lake will start to dry up in summer, since without the surrounding trees it will no longer get the water from the fog. What water it gets will evaporate more quickly without the tree shade cooling its surroundings. In dry years, it may not even get much water in winter. Its function as habitat would be severely degraded.
  • The area will become a lot dryer and warmer in summer, just the time when the red-legged frogs are changing from tadpoles to frogs. According to the National Wildlife Federation, the California red-legged “frogs do not like very hot temperatures and will seek shade within tall grasses and reeds.”

OTHER NEGATIVE ECOLOGICAL IMPACTS

Besides damaging the habitats of endangered species, the tree-cutting plan is environmentally damaging in many ways.

  • Carbon sequestration: Trees sequester carbon, and preserving trees and thus fight climate change. Once they are cut down, they release this carbon back to the atmosphere. With 15,000 trees, the impact will be significant.
  • Trees fight pollution, especially particulate pollution. With Highway 1 running through it, and the city of Pacifica nearby, these trees are fighting the pollution that would otherwise drift into populated areas.
  • Trees prevent erosion. The trees help to prevent erosion on these steep hillsides, and reduce the likelihood of landslides.
  • Trees help water regulation. These trees not only increase the water available by precipitating water from the fog, they also help to store in by slowing evaporation and encouraging the growth of plants that slow run-off. This provides a green environment year-round.

There’s more about the plan for Sharp Park HERE in an article we wrote last year. In the map below , the red percentages show the percentage of trees to be felled at each site. In most places, it’s 75% of the trees. (You can click on the map to make it larger.)

snramp - sharp park- plan A

Imagine this hillside as a bald mountain with a few scraggly trees, brown and dry in summer.

7 a forest on the hillside - sharp park

What we wrote then in conclusion:

Aside from the beauty of the place, and the undisturbed wildlife habitat that would both be destroyed, we think it is environmentally irresponsible. Eucalyptus, with its dense wood, its size, and its 400-500-year life-span, is particularly effective at sequestering carbon. In foggy areas, it captures moisture from the fog and drops it on the ground below, allowing for a dense damp understory that fights drought and resists fire. It cleans the air, especially fighting particulate pollution, by trapping particles on its leaves that eventually get washed onto the ground. It stabilizes hillsides with its intergrafted root system that functions like a living geotextile.  SNRAMP would require the use of large quantities of poisonous herbicides to prevent resprouting of the felled trees – herbicides that are likely get washed down the hillsides and into surface and ground water.

Pacifica actually has an ordinance prohibiting logging (removing more than 20 trees in a year). NRD’s answer to that is to see if the ordinance applies, and if it does, to try to get permission.

Better Parks for People Who Need Them: The Proposed “Anti-Equity” Metrics

Proposition B provides San Francisco Recreation and Parks Department (SFRPD) with set-aside funds for the next 30 years. It also requires them to ensure equity for the parks, by spending more on parks in under-served areas. Let’s call those the “Equity” tracts (they’re based on census tracts showing below-average income).

Now SFRPD proposes a calculation method (“metric”) that indicates it’s actually devoting more resources to those parks already. (You can see that calculation HERE: item-2-equity-metrics-staff-report-final-080416) How? By simply assuming that only the “Equity” tracts use the parks within a quarter-mile of their homes, so that they get ALL the resources spent on those parks. Of course, that’s simply not true. The Equity tract users use those parks, but so does everyone else who lives nearby. (Large parks may even attract people from across the city.) They share the resources, they don’t get all the resources.

Tom Borden shows graphically what’s wrong with SFRPD’s current Equity Metric. In the next article, he will provide a more detailed analysis of this hastily-designed measure.

THE ANTI-EQUITY METRIC

by Tom Borden

RPD’s Equity metrics show paradoxically that the disadvantaged neighborhoods of San Francisco enjoy more park resources than the average city resident, much more. On a per capita basis, the equity population is way ahead of the average resident. Below, the first number shows the resources for the “Equity” tracts (i.e., under-served populations, determined by census tracts), vs. City-wide resources.

  • Acres of park/1,000 people:  4.42 vs 4.00
  • Number of parks/1,000 people 0.49 vs 0.26
  • Capital Investment/1,000 people $64,003 vs $24,333
  • Recreational Resources/1,000 people 530 hours vs 284 hours

Do you believe it? They must be doing something wrong in their calculations. Let’s take a look.

The graphic below shows a 10 acre park where five census tracts are within 1/4 mile of the park.
Two of the tracts are equity tracts. For simplicity, let’s say 4 people live in each tract.

park-equity-graphic-1
When SFRPD calculates their metrics, they assign 100% of a park’s resources to equity zones if an equity zone is within 1/4 mile of the park. For our park above, let’s use the SFRPD method to calculate the acres of park per capita for the equity tracts. Here’s what that looks like:park-equity-graphic-2

Using the SFRPD method, the 8 equity neighbors share 10 acres, or 1.25 acres per capita. Do they really have all that space to themselves? No. All those other neighbors standing outside use the park too. They put wear and tear on the park, occupy the tennis courts and picnic tables, take spots in programmed activities, fill up the trash cans, and take lanes at the pool.

The SFRPD method shows the equity neighbors are getting much more than they actually are. The right way to calculate this is shown below.

park-equity-graphic-3

All twenty neighbors share the park, so each enjoys 10 acres / 20 people = 0.5 acre per capita. This is the same for equity and non-equity neighbors. The two equity tracts should be allocated acreage as follows:
8 people X 0.5 acre per person = 4 acres

The portion of any particular park resource to allocate to the adjoining equity tracts is based on the simple ratio of equity park users to total park users, in this case 8 / 20 = 40%.

If there 30 picnic tables, the equity tracts would be allocated 30 x 0.4 = 12 tables
If $1,000,000 of capital was spent in the park, $400,000 would be allocated to the equity tracts.

SFRPD needs to correct their accounting for parks shared by equity and non-equity tracts. The resources of each shared park should be calculated as illustrated above. If this is not done, the error makes it look like the equity tracts are being better served than they really are. Instead of having Equity Metrics we have Anti-Equity Metrics.

More Roundup for Glen Canyon

A couple of days ago, someone emailed us that they had seen Pesticide Warning notices in Glen Canyon. This park is one where neighbors have been sharply opposed to pesticide use, particularly to glyphosate, the active ingredient of Roundup. The World Health Organization has classified it as a probable human carcinogen. The areas being sprayed were on a slope, so it’s possible for the herbicide to move downhill.

petition picture against roundup

A petition they started against glyphosate use has now more than 12,000 signatures (and you can still sign it if you have not already done so).

The email said, “I saw this sign on the paved path next to O’Shaughnessy on the west side of Glen Canyon.   This was down the hill a short way from the Miraloma clubhouse.  It says they will be spraying roundup from 6/28 to 7/5 in the grasslands just east of the path.”

Sure enough, when observers followed up, they found a team of four applicators out there, spraying coyote brush (and possibly poison oak) for a couple of hours. Coyote brush is a native plant, and ironically the reason to spray it is to stop the natural succession to grassland – which consists for the most part of non-native grasses.

Said one observer: ‘I saw the workers going back and forth, spraying over areas where the other one just sprayed. It appears to me to be a “make work” effort to show that activity is being done.  It was frustrating for me to watch them going back and forth … just to kill time.’

Here’s the link to the 1:38 minute video, which shows the applicators and the location:

glen canyon glyphosate June 2016 - Shrubs encroaching on grassland video