West of Twin Peaks Central Council opposes Natural Areas Program, Part 4: Poor Public Process

This article is Part 4 of the West of Twin Peaks Central Council (WTPCC) letter opposing the Natural Areas Program (NAP). Emphasis has been added.

Part 1 is HERE (Opposing the Natural Areas Plan)
Part 2 is HERE (Trees and Pesticides)
Part 3 is HERE (Park Access and Wildlife Habitat)

(For the whole letter in PDF form – and an addendum from board member Caroline Squeri- click on the link here:  2012.06.04 – WTPCC Letter Opposing NAP )

Read on for Part 4.


WTPCC opposes NAP in part because of the poor job NAP has done to inform park neighbors and neighborhood associations about its plans. Neighbors who live immediately adjacent to Mt. Davidson, for example, have said they were never given any official notice of NAP’s plans for the park, especially its plans to cut down 1,600 trees. Established neighborhood associations, including many WTPCC members, have not been contacted by NAP. Many have said they never heard anything about the DEIR. Indeed, the Planning Department offered a tacit acknowledgement of this lack of public outreach when it re-opened public comment on the Draft DEIR last month.

NAP did not contact park neighbors and users or neighborhood associations to find out what they wanted in the natural areas in their neighborhood parks when NAP staff were developing their plans. During the plan development process, citywide NAP advocacy groups were contacted for input on what NAP should do in the parks, yet the people who live adjacent to or who regularly use the parks (that is, those who will be most impacted by any NAP restrictions) were ignored. The only input most people had was whatever they could say during a one-minute public comment at a Recreation and Park Commission meeting after the plans were already developed. The parks belong to the people of San Francisco, not to NAP staff. All park neighbors and users (not just those known to support NAP) must be involved in discussions about what to do in natural areas. Without this level of public outreach and engagement, NAP’s plans lose support and credibility.

Even when people have explained their concerns to NAP staff, it seems to fall on deaf ears. At a 2002 meeting of the Golden Gate Heights Neighborhood Association (GGHNA), members complained about NAP’s removal of iceplant at the neighborhood’s Grandview Park. Grandview is the only remaining sand dune in San Francisco (other than at the beaches), but it is completely surrounded by homes, some of which have backyards that abut the park. Over the years, neighbors and park staff had planted iceplant at Grandview because it was the only plant that seemed able to hold the sand in place. When NAP took control of the park, it began to remove the iceplant because it was non-native. At the GGHNA meeting, several park neighbors complained that the iceplant removal had caused sand to drift into and cover their backyards, damaging their property. Lisa Wayne, the head of NAP who had been invited to respond to the neighbors’ concerns, responded that NAP had no responsibility for property damage outside park boundaries caused by its removal of erosion-controlling plants. When the SNRAMP was released several years later, it called for “scattered, open sand” at Grandview Park. Over the years, GGHNA has repeatedly submitted public comments asking NAP to remove the goal of “scattered, open sand” at Grandview, yet it remains in NAP’s plans.


WTPCC opposes the expansion of NAP’s mandate beyond the protection and preservation of existing remnants of San Francisco’s natural heritage. The original Management Plan for NAP, written in 1995, was 12 pages long.

Over the years, however, NAP has claimed more and more city parkland, to the point that most of the land under NAP control does not have existing remnant habitat. Rather NAP has claimed land that it wants to change from the existing habitat that currently has few native plants to one that more closely resembles the habitat before Europeans settled in the area. Because of this expansion, the final SNRAMP is 711 pages long.


WTPCC supports the idea of preserving existing remnants of the historical habitat. We do not support the idea of wholesale habitat conversion that requires cutting down thousands of healthy trees, extensive and repeated applications of herbicides, closure of access to large areas of our parks, and destruction of existing habitat needed by the animals and birds living there now. As a result, WTPCC opposes NAP and its current plans for our parks.

The fundamental goals of NAP are misaligned with what San Franciscans want in their parks. To date, NAP has focused on restoring open space in San Francisco to “native” status. The SNRAMP was written to interpret “Natural” to mean “Native.” That’s not what San Franciscans want their natural areas to be.

We want Natural Areas to be:

  • Accessible to the public
  • Safe
  • Well-Maintained
  • Green and filled with growing things (trees and plants)

Nowhere on that list does it say “native only.”

People love Golden Gate Park (which is filled with non-native species), but it’s not always easy to get to – so they want miniature versions of Golden Gate Park in their neighborhoods. They want a variety of plants that look nice, and space that gives them a chance to escape where they can walk, run & play with their family, friends and pets. Purely native areas do not provide the same visual and recreational opportunities that our non-native areas do. That’s why people living in San Francisco more than 100 years ago introduced non-native species in the first place. Lush and green is what we want, and we’re not picky about whether it’s native or not.

The Natural Areas Plan should reflect that desire, and work to accommodate it. NAP can certainly preserve a small portion of the total parks space for native plants (much like the botanical gardens include sections that are native only), but only if these native areas can meet the requirements above (i.e. accessible, walkable, safe, well maintained and green and lush). In a densely populated urban area like San Francisco, native-only should be a “nice to have” that takes a back seat to priorities like accessible, safe and lush.

WTPCC asks the Planning Department to address the issues we identified with the Draft DEIR. We ask the Recreation and Park Commission to rethink its support for NAP.

Thank you for your consideration.


Matt Chamberlain,

President WTPCC

cc: Mayor Ed Lee; Board of Supervisors; Planning Commission; RPD General Manager Phil Ginsburg; Natural Areas Program Director Lisa Wayne; RPD Chief of Operations Dennis Kern; Bill Wycko, Environmental Review Officer, Planning Dept.

West of Twin Peaks Central Council opposes Natural Areas Program, Part 3: Park Access, Habitat & Wildlife

This article is Part 3 of the West of Twin Peaks Central Council (WTPCC) letter opposing the Natural Areas Program (NAP). Emphasis has been added.

Part 1 is HERE (Opposing the Natural Areas Plan)
Part 2 in HERE (Trees and Pesticides)

Read on for Part 3.


WTPCC opposes NAP plans to restrict access to parks. NAP plans to close 9.2 miles of trails that thread through its natural areas. At our May meeting, Dennis Kern noted that a citywide survey of what San Franciscans want in their parks identified trails and hiking as the number one need. Yet NAP plans to close nearly a quarter of the total length of trails in natural areas (about 40 miles). This would seem to fly directly in the face of what the public said they want in their parks.

In most natural areas, the only thing you can do is walk on a trail. You cannot leave the trail to explore the area, or follow a butterfly, or try to see the bird you hear tweeting. To control access, NAP builds fences. Indeed, in parks where trails in natural areas have been restored recently, fences have been built on either side of the trail to ensure people cannot leave the trail. Natural areas become places where you can “look but not touch.” How can children explore the wonders of nature if they are told repeatedly they must “Stay on the Trail”? This is not what we want for our parks.

When people are restricted to walking only on trails, they lose access to the entire non-trail part of the park. In over half of the parks with a natural area (17 of 31), NAP controls the entire park. That means people have lost access to all but the trails in those parks. In an additional 10 parks, NAP controls over 50% of the land. Put another way, only four of the 31 parks with natural areas have less than 50% of their land controlled by NAP. Access restrictions planned by NAP (“stay on the trail”, fences, and closure of trails) mean that entire neighborhoods will lose access to the vast majority of the parkland in their neighborhood parks. The Draft DEIR does not consider the impacts on neighbors and park users of this level of access restriction in the 27 parks where NAP controls more than half the land.


WTPCC opposes the destruction of existing habitat needed by the wildlife and birds currently living in the parks. For example, NAP has removed underbrush in Glen Canyon that is used by coyotes to hide from people and dogs, and replaced it with grasslands. Unlike the underbrush, the grasslands provide little “cover” for the coyotes or other wildlife living in the natural area.

We are also concerned that some habitat conversion is being done during breeding and nesting season. For example, NAP applied for a “streambed alteration” permit from the California Fish and Game Dept for habitat conversion work to be done near Islais Creek in Glen Canyon. In the application, NAP clearly stated: “It is the policy of RPD’s Natural Areas Program that no new projects will begin during the breeding season (December to May).” Similar commitments were made in the SNRAMP.

However, NAP contractors used chainsaws and herbicides to destroy underbrush habitat in Glen Canyon in March and April, continuing work done sporadically since November 2011. This work took place throughout the breeding/nesting season, despite NAP’s legal commitment to CA Fish and Game and in the SNRAMP to not do habitat work during breeding season. When people informed RPD management about this, during a meeting at McLaren Lodge, Lisa Wayne, the head of NAP, said the work was being done during the breeding/nesting season because the grant for the project was set to expire. In other words, NAP’s decision on habitat conversion in Glen Canyon appeared to be motivated by financial considerations, not by any concerns about the wildlife and birds living there.

To be continued.

“Rethink Support for Natural Areas Program” – West of Twin Peaks Central Council letter Part 1

In May 2012, the West of Twin Peaks Central Council (WTPCC) passed a resolution to write a letter opposing the Natural Areas Program (NAP).

We will (with permission) be serializing that letter, which was sent last month to the San Francisco Recreation and Parks Commission, with copies to

  • Mayor Ed Lee,
  • the Board of Supervisors,
  • the Planning Commission,
  • RPD General Manager Phil Ginsburg, Natural Areas Program Director Lisa Wayne, RPD Chief of Operations Dennis Kern and
  • Bill Wycko, Environmental Review Officer, Planning Dept.

The WTPCC is an umbrella organization comprising twenty neighborhood associations that are situated “west of Twin Peaks.” Many of the member organizations had expressed concerns about the Natural Areas Program, especially plans to cut down 1600 trees on Mount Davidson. For the May meeting, delegates were requested to look at the actual information about the Significant Natural Resource Areas Management Plan (SNRAMP). In addition, they had presentations from Dennis Kern and Lisa Wayne (for San Francisco’s Recreation and Parks Department); and by Eric Miller and Jacquie Proctor (of San Francisco Forest Alliance).

At the end of the presentations, 12 of 16 member organizations present voted to oppose the Natural Areas Program. (Others abstained, some because delegates were not authorized to make that call without referring it back to their associations. None opposed the resolution.)

This is Part 1 (of 4 parts) of the letter.

Here are links to Part 2 (Trees and Pesticides); Part 3 (Park Access and Wildlife Habitat); and Part 4 (Public Process, and Conclusion).

The whole letter, as a PDF, is available here: 2012.06.04 – WTPCC Letter Opposing NAP


June 4, 2012
West of Twin Peaks Central Council
PO Box 27112
San Francisco, CA 94127

To: San Francisco Recreation and Park Commission
McLaren Lodge
501 Stanyan St
San Francisco, CA 94117

Dear Commissioners,

At its May 21, 2012 meeting, The West of Twin Peaks Central Council (WTPCC) voted to write a letter opposing RPD’s Natural Areas Program (NAP) and to submit a comment opposing NAP as part of the NAP DEIR public comment process. WTPCC, formed in 1937, is an umbrella group of 20 neighborhood associations that share the common geographic designation “west of twin peaks.” WTPCC member associations share common demographics as well– primarily owner-occupied, single-family homes. Our members choose to live here because it is a medium-density area that provides space for yards and  children, as well as local commercial shopping districts, recreation options, and parks. Cumulatively, we have a shared history of protecting and improving the common characteristics and character of our neighborhoods.

WTPCC member organizations had expressed concerns about NAP at previous meetings, especially concerns about NAP’s plans to cut 1,600 trees on Mt. Davidson. Prior to its May 2012 meeting, WTPCC member delegates were given “homework,” links to the NAP General Management Plan (SNRAMP) section on Mt. Davidson along with the SNRAMP Executive Summary, information on NAP from the NAP website, and information from critics of NAP. At the May meeting, WTPCC heard a presentation in support of NAP from RPD Chief of Operations Dennis Kern and NAP Director Lisa Wayne, and a presentation in opposition to NAP by Eric Miller and Jacquie Procter from the SF Forest Alliance. Judging by the quality of the questions, our delegates had indeed studied the suggested material “assigned” beforehand. After the presentations and questions, WTPCC voted immediately to send this letter and comment.

WTPCC concerns with the Natural Areas Program (NAP) are as follows:

  • NAP’s plans to cut 18,500 trees in parks controlled by SF RPD, including plans to cut 1,600 trees on Mt. Davidson
  • NAP’s use of herbicides, including repeated applications at the same site, poor signage, improper applications, and concerns about children and pets playing in areas where toxic herbicides have been applied
  • NAP’s plans to close access to areas under its management, including closing 9.2 miles of trails, and turning the park experience into one full of “Stay on the Trails” and “Keep Out” signs
  • NAP’s plans to remove existing habitat (especially bushes and trees) and replace it with grassland will destroy habitat needed by wildlife and birds currently living in our parks
  •  NAP has done an extremely poor job of informing people, including park neighbors, of its plans;  those plans were created without seeking input from park neighbors and park users

NAP has expanded far beyond its original mandate to protect and preserve remnants of San Francisco’s natural heritage, into large-scale conversion of existing habitat into something completely different, conversions that will change the character and uses of the park for decades to come.

Because of these concerns, WTPCC opposes the proposed NAP Management Plan (SNRAMP) currently undergoing environmental review. We ask the Planning Department to address our issues and concerns with the Draft NAP DEIR (details below). We urge the Recreation and Park Commission to rethink its support of NAP’s plans. The parks belong to the citizens of San Francisco, not to Natural Areas Program staff.

(To be continued:  CLICK HERE for Part 2, Trees and Pesticides)