Here’s the Sutro Forest DEIR (issued July 2017)

For those readers who would like to get started on reading the Draft Environmental Impact Report for  Mount Sutro Open Space Reserve, we have it here as a PDF:


Sutro Forest DEIR Announced

UCSF has released a humongous 1087-page Draft Environmental Impact Report on the Plan to cut down thousands of trees in Sutro Forest. The deadline for public comment has been extended in response to our request, to Sept 22, 2017. This two-week extension from Sept 8th is a lot less than the 60 days we asked for, but it’s better than nothing.

Here’s an excerpt from UCSF’s letter:

“In response to your request, UCSF is extending the public comment period for the Draft Environmental Impact Report (DEIR) for the proposed UCSF Mount Sutro Open Space Reserve Vegetation Management Plan.  The comment period will be extended by two weeks for total of 60 days: public comments on the DEIR are now due on Friday, September 22.  All comments must be received by 5:00 p.m. on Friday, September 22, 2017.  CEQA guidelines have established that the public review period for a DEIR should not be longer than 60 days (Section 15105).

“Send written comments to the attention of Ms. Diane Wong, UCSF Campus Planning, Box 0286, San Francisco, CA 94143 or email to

It’s interesting that they invoke the 60-day maximum under CEQA guidelines, but ignore the guideline that says the DEIR text should be 150 pages or at a maximum, 300 pages….


UCSF will hold a public meeting on August 24, 2017

“There will be a public hearing to receive oral comments on the DEIR on August 24 at 6:30 p.m. at Millberry Union, 500 Parnassus Avenue, on UCSF’s Parnassus campus.

UCSF’s “Urgent Fire Safety” on Mt Sutro – How True?

Our readers have been following the story of Sutro Forest, the beautiful Cloud Forest that lies in San Francisco’s fog belt. It captures moisture from the marine layer fog, and is thus wet all through the summer and into the Fall, which protects it from fire-hazard. In January 2013, UCSF issued a Draft Environmental Impact Report (DEIR) on a Plan threatening to cut down 90% of the trees on 3/4 of the Mt Sutro Open Space Reserve.

Until recently, we understood that the tree-felling had been postponed to 2014, as UCSF needed more time to respond to the detailed and voluminous public comments on the DEIR.

Mt Sutro Forest, Sept 2013 (Photo:

Then UCSF sent out a notice that it would be performing “urgent fire safety work,” felling over 1000 trees and mowing down understory on Mount Sutro in response to San Francisco Fire Department (SFFD) having provided an “independent assessment of the Reserve.” (We reported on that HERE.)  On its own website announcing it had completed work, UCSF says, “The measures, which began Aug. 26, are in response to an assessment this summer by the San Francisco Fire Department that found “extra hazardous fire conditions” in the urban forest.”

All of this creates the impression that SFFD came in, took a close look at the forest, and found “extra hazardous conditions” – and that UCSF’s actions were in response.  But is that what really happened?


The determination that fire conditions are “extra-hazardous” is important. If they’re just the normal fire-risk, then the required clearance to structures is 30 feet. If it’s “extra-hazardous” then it’s 100 feet.

At 30 feet of clearance, UCSF would need to do very little: This amount of clearance already existed in most places.  But by declaring it “extra-hazardous” UCSF decided to clear understory and slender trees on around 20-25% of the Mt Sutro Open Space Reserve.

The discussions about Sutro Forest have been going on since about 1995. Right now, there’s a Draft EIR on a Management Plan being processed. This sudden August 15th UCSF notice planned to start work within 10 days, without any public meeting or discussion, or reference to the California Environmental Quality Act (CEQA) because it addressed “immediate fire safety and emergency concerns.”

So of course we were very interested in just how the extra hazard – and emergency – had suddenly been decided.


UCSF claimed an “independent assessment” by the SF Fire Department (SFFD).  But was it?

Under the Sunshine Act, we obtained documents from SFFD, covering the correspondence between UCSF and the San Francisco Fire Department. It demonstrates no independent assessment nor any evidence of “extra-hazardous” fire conditions at that time.  It appears that UCSF, finding its efforts to start gutting the forest this year had been stymied by the overwhelming public opposition to its Draft EIR, decided to do an end run around CEQA.

  • SFFD had not independently expressed any concerns about fire hazards on Mount Sutro.  UCSF tried to get them to come to Mt. Sutro and tell UCSF to cut down trees.  That apparently didn’t happen.
  • Then UCSF drafted a letter for SFFD saying there were extra-hazardous conditions requiring the 100-foot clearance.
  • Only after our Public Records Act request revealed that SFFD had been used to get around CEQA, after the public had been told that SFFD had made an independent assessment, on the very day that cutting started, did SFFD perform an after-the-fact walk-through of Mount Sutro to justify what was being done.


Here’s the timeline:

  • 13 June – 10 July 2013:    UCSF tried to get the San Francisco Fire Department (“SFFD”) to come to UCSF to do a fire hazard inspection on July 11th. There’s no record that the meeting ever happened.

(This is a PDF of email correspondence apparently trying to set up such a meeting – but no evidence or acknowledgement that it occurred. Please note UCSF labeled them ‘Attorney-Client Privileged’ – even though they are not. This looks like they’re trying to prevent the public from seeing them. Email messages July 2013 (UCSF-SFFD) )

  • 23 July 2013:   UCSF drafted a letter for SFFD’s signature stating that “SFFD has determined that 100 feet of fuel clearance for structures is required due to extra hazardous fire conditions.” (There was no substantiation of these “extra-hazardous conditions. Without them, a clearance of 30 feet – which already existed in most places – would have been sufficient.)

(Here’s the PDF of correspondence between UCSF and SFFD indicating that UCSF provided the draft letter: UCSF – SFFD emails July 2013 )

  • 27 July 2013:   Due to overwhelming number of comments on the Draft Environmental Impact Report opposing felling trees on Mount Sutro, UCSF announced that it would not be able to complete responses and hold the hearing approving the EIR in time for work to begin in 2013, and this would be postponed to 2014 after the bird-nesting season (around mid-August).
  • 14 August 2013:  UCSF sent out a public notice that it would begin tree removals on August 26, and attached the SFFD letter (which had been drafted by UCSF) as justification.
  • 20 August 2013:  San Francisco Forest Alliance sent SFFD a letter demanding immediate disclosure of all records pertaining to fire hazards or assessments of fire hazards on Mt. Sutro.
  • 23 August 2013:  SFFD provided no records of any fire assessment on Mt. Sutro, and only produced one document showing that UCSF had scheduled a tentative Mt. Sutro site visit on July 11th  (and no evidence or assurance that this site visit had occurred).
  • 26 August 2013:  (1) “Urgent fire safety” work started. (2) On the same day, the day tree-felling began, SFFD actually did a site inspection of Mt. Sutro. This was reported in a letter to UCSF dated August 29th, when the work was well under way. Clearly, it was after the fact, and not independent. The inspecting contingent included several UCSF staff.  From SFFD, it apparently included Fire Chief Joanne Hayes-White together with several other SFFD staff. Most of the letter details the work that is being done – all of which is apparently based on UCSF-provided information. The “independent assessment” is one paragraph of generalities, describing conditions that have been unchanged in at least the last ten years, and don’t therefore substantiate any “emergency.” That letter is HERE. SFFD Aug 29 letter to UCSF

Is it possible that this letter, too, was drafted by UCSF? We don’t know. If we find out one way or the other, we’ll publish it here.

In any case, SFFD has clearly provided this support as a courtesy to UCSF, and there has still been no independent substantiation of the ‘extra-hazardous’ conditions throughout the areas where the “work” was performed. Or of any emergency.

BEFORE picture in Sutro Forest. (Photo:

AFTER picture in Sutro Forest. (Photo:

UCSF To Fell 1250 Mt Sutro Trees for “Urgent Fire Safety” – Aug 2013

This article is reprinted with permission from


We had thought that UCSF was not going to cut down trees this fall when we wrote One More Year for Sutro Forest. We were wrong.

Yesterday, we received a surprise notification from UCSF. It plans to start felling trees for a “Urgent Fire Safety” project from August 26th. This is separate from (and possibly in addition to) the Plan discussed in the Draft Environmental Impact Report.

Mt Sutro 'fire safety work' mapMORE THAN A THOUSAND TREES

They plan to do the following:

  • Cut down and chip 1,250 trees under 6 inches in diameter in the colored areas on the map. (This comes to over 15 acres, about one-quarter of the forest.)
  • Remove much of the understory bushes in those areas.
  • Remove an unspecified number of “hazardous” trees of any size through the forest. (Presumably those would be the orange-tagged trees.)
  • They will not use pesticides.

In addition, they note that PG&E will prune/remove trees on Clarendon Avenue, and the city will do so in the Interior Green Belt. So we can expect quite a lot of tree-felling in this area this Fall.


UCSF has indicated that work will start on August 26th and take 2 weeks.

ucsf letter abt 'fire safety' work

They also say that because this is “Emergency” work, it is not subject to the California Environmental Quality Act (CEQA) and so is separate from the Plan in the Draft Environmental Impact Report and independent of it. Of course, from an actual environmental viewpoint, this would be an addition to everything in that Plan.

They have obtained a letter from San Francisco Fire Department supporting their proposed actions.

defensible spaceThis is a recent picture from Sutro Forest.

fog in the forest 4

Some see trees and understory; others see fuel.

UCSF plans to fell 30,000 trees in Mount Sutro Forest

This post has been copied with minor edits from, which is a website set up to inform people about Mount Sutro Cloud Forest and to defend it.


1. Write to the Board of Regents, who will ultimately decide whether to approve this project. Ask them why they are undertaking this controversial, expensive, and ecologically destructive project, and gutting a San Francisco treasure to achieve a “parklike” environment. You can contact the Regents at their website HERE. (Their email address is: )

2. Write a comment on the Draft Environmental Impact Report. The report is HERE. (It will take some time to load.) The person to write to is Diane Wong, and her email address is at:

[Edited to Add: The comments are now closed. UCSF expects to respond some time in May 2013.]

3. Sign the petition to Save Sutro Forest (at the end of this article). PLEASE SIGN (if you have not already). The petition stays alive as long as the threat exists.

Mount Sutro Forest has approximately 45,000 trees in the 61 acres belonging to University of California, San Francisco (UCSF), and designated as an open space reserve. This dense forest, with an estimated 740 trees per acre, a sub-canopy of acacia, an understory of blackberry and nearly a hundred other plant species, is functionally a cloud forest. All summer long, it gets its moisture from the fog, and the dense greenery holds it in. Where it isn’t disturbed, it’s a lush beautiful forest, providing habitat for birds and animals, and a wonderful sense of seclusion from urban sounds and sights.

(CLICK HERE to see the Google Map of the forest.)

Mount sutro forest greenery


UCSF now has published a Draft Environmental Impact Report (DEIR) on a project to remove over 90% of the trees on three-quarters of the area. Only 15 acres – on the steep western edge of the forest – will remain as they are. Tree-felling could start as early as Fall 2013.

[Edited to Add:

Here is the PDF of the DEIR. Mount_Sutro_EIR_1-16-13_with_Appendices

Comments were due on March 4th, but because of the length and complexity of the document, neighbors asked for, and got, an extension. Comments are now due before March 19, 2013.]

On most of the forest (44 acres), UCSF plans to cut down trees to achieve a spacing of 30 feet between trees – the width of a small road – and mow down nearly all the understory habitat. On another 2 acres, they will space the trees 60 feet apart. The stumps of the trees will be covered in black plastic, or else poisoned with Garlon to prevent re-sprouting. Eventually, this will kill the roots, which will start to decay. We’ll address some of these issues in more detail in later posts.

Right now, we want to talk about the number of trees that will be felled. A spacing of 30 feet between trees gives about 50-60 trees per acre. A spacing of 60 feet gives 12-15 trees per acre.

(The easiest way to think about it is that each tree occupies a 30 x 30 foot space, or 900 sq ft. An acre is 43,560 sq ft, so this would give 48.4 trees to an acre. The DEIR calculates it as 61 trees per acre, assuming each tree occupies a circle that’s 30 feet in diameter, 707 sq ft. But there’s no way to arrange circles without wasted spaces between them, so this doesn’t exactly work.)

So on 44 acres, they will retain maybe 50 trees per acre (or maybe fewer). On two more acres with a 60-ft spacing, they will retain 12-15 trees per acre. All the rest will be cut down. Even using the DEIR’s overly optimistic calculation, they will be felling some 31,000 trees. Our calculations are closer to 32,000. Either way, it’s a huge number.

That means that in the 46 acres where UCSF will be felling trees, they will remove more than 90% of the standing trees.

The DEIR says that they will start by cutting down trees that are dead or dying. Aside from their value as habitat (some birds like woodpeckers depend on them), there are not all that many of them in Sutro Forest, which despite everything that has been claimed to to opposite, is a thriving forest. Next in line will be trees with diameters under 12 inches, or roughly 3 feet around – as thick as an adult’s waist. Then they’ll start on the larger trees. Since it’s going to be 90% of the trees, we expect thousands of large trees to be removed.


However, this is not all. We expect further tree losses for four reasons:

  1. Wind throw. Since these trees have grown up in a dense forest where they shelter each other, removing 90% of the trees exposes the remaining 10% to winds to which they’re not adapted. This can be expected to knock down a significant number of the trees not felled. Since the Plan only calls for monitoring the trees and felling any that seem vulnerable to wind-throw, it’s unlikely any vulnerable trees will be saved.
  2. Physical damage. Damage done to the remaining trees in the process of removing the ones they intend to fell. With such large-scale felling, damage to the other trees is inevitable, from machinery, erosion, and falling timbers.
  3. Something like AvatarPesticide damage. This forest has an intertwined, intergrafted root system. When pesticides are used to prevent resprouting on tree-stumps and cut shrubs and ivy, it is quite possible for it to enter the root system and damage remaining trees.
  4. Loss of support. Compounding the effects of the wind-throw, the remaining trees will suffer from a lack of support as the root network dies with 90% of the trees being removed. This could destabilize them, and make them more likely to fail.

What remains will be a seriously weakened forest with a greater risk of failure and tree-loss, not the healthier forest that the DEIR claims. It is likely that the long-term impact of the Project will be the elimination of the forest altogether, and instead will be something like Tank Hill or Twin Peaks plus a few trees.


The project is to be implemented in two phases. In the first phase, trees will be felled and the understory removed in four “demonstration areas” totaling 7.5 acres. They are shown on the map below in yellow, as areas #1-#4. (One of these, #4 “East Bowl”, is the two-acre area slated to have only 12-15 trees per acre.)

hand-drawn map not to scale

One area (#5 on the map) is supposed to be a “hands off” area to demonstrate the untouched forest. However, a trail has already been punched through it in November 2011, even before the DEIR had been published.

During this phase, they would experiment with the 3 acres on the South Ridge, just above the Forest Knolls neighborhood. On 1 acre, they would use tarping to prevent regrowth of felled trees; on 1 acre, they would use pesticides, particularly Garlon; and 1 acre they would trim off sprouts by hand. They could also use pesticides on the understory “consistent with city standards” – presumably those of the Natural Areas Program (See article on NAP’s Pesticide Use.)

In the second year, the plan would be extended to the remaining forest, with the proviso that not more than a quarter of the forest would be “thinned” at “any given time.”


Sign a petition to ask the Regents not to approve this plan.

Sign for Sutro Forest button