San Francisco Forest Alliance: Preserving Our Urban Forests & Wildlife Habitat

I hope everyone is as concerned about our wildlife habitat as I am. Please check out, and join, the new San Francisco Forest Alliance at SFForest.Net. Their goal is to preserve the forests, trees and thickets, all of which serve as wildlife animal habitat. Slated for removal in the new Natural Areas Program, NAP, plan are 18,000 trees, most of them mature and majestic specimens. They provide ecological benefits and species habitat which are still little understood by NAP. Here is the background:

Trees, forests, and dense thickets of underbrush — thickets which are impenetrable to dogs and humans — serve as wildlife habitat: they offer physical protection and food to wild animals. Almost all trees in San Francisco are non-native — there were only four native species of trees in the area when the Europeans arrived. Non-native berries such as Himalayan blackberry, cotoneaster, pyracantha, holly and others serve as food sources for birds and furry creatures. These are being ripped out in our parks for the shortsighted intention of  ”restoring” the San Francisco area to what it might have been like in 1776 — mostly sand-dune grasses and understory species with little if any habitat value.

But the environment has totally changed since that time. The biggest change which altered the landscape forever has been the growth of a dense human population. This impacted the environment tremendously.  But when humans came, they also planted trees and shrubbery to help them deal with the harsh environment — mostly to hold in the loose sands which blew around everywhere, and as wind barriers. The plantings did more than this, they added greenery and beauty to the area. And they created a wildlife habitat which is now home to almost all of our wildlife. Because of these and other changes, even the original soil structure along with the microorganisms that were part of the sand dune ecosystem have been altered forever.

The new plantings grew and evolved. Ours, now, is a totally balanced ecosystem that has evolved over the last 250 years, and it is a healthy ecosystem. An indicator of the health of an ecosystem is it’s top predator. There are coyotes in San Francisco — our ecosystem is very healthy.  Now, along with our dense human population, we have paved roads, lots of automobiles, plenty of pollution  – we need our trees to combat the environmental effects of our dense population and the way we live.  San Francisco has the second smallest tree canopy of any dense urban center in the United States. Our urban forests are essential in terms of carbon sequestration and water sequestration — they help the environment and combat the effects of global warming. Every single tree counts. Yet more of our healthy, hard working naturalized trees are being ripped out and replaced with grasses and shrubs that are not sustainable in the present environment, all in the name of a clearly misguided environmentalism and false science.

Sustainability is something we all aspire to. However, in the time since the Native Plant program began in San Francisco, we have discovered that, in fact, native plants are not very self-sustainable. These native plants require a vast number of volunteer work hours to maintain them. In addition, our Recreation and Park Department is, literally, splashing poisonous pesticides on our parks’ non-native species regularly in order to accomplish their nativist goals. We have tried fighting this policy, but the use of poisons in the Park Department’s so-called “natural areas program”/NAP has actually increased 265% in one year alone, from 2009 to 2010. They are using these pesticides in parks where children play, where there is wildlife, where we walk our pets, and where there is a creek — the manufacturer of these chemicals warn strongly against this. The “natural areas program” is clearly not “natural” at all.

Critics of NAP question not only the program’s expenditures in budget-tight times but also the native plant advocates’ rhetoric, ”  ’Restoration ecology’ is a euphemism for a kind of gardening informed by an almost cultish veneration of the ‘native’ and abhorrence of the naturalized, which is commonly characterized as ‘invasive,’ ” Arthur Shapiro, a distinguished professor of evolution and ecology at UC Davis, wrote city planning officials last October. (Sacramento Bee, 1/16/12). People are finally waking up to what is occuring in their parks — and they are desperately alarmed.

Images are worth a thousand words:

great horned owlets raised in non-native eucalyptus

brown creeper hunts on non-native eucalyptus

barn owl and mate nest in non-native palm tree

Swallow tail butterfly relies on non-native fennel for survival

snake hides in non-native eucalyptus leaves

nuthatch feed on bugs in eucalyptus, and has its nest in a hole in its trunk

honeybees build their hive in a non-native eucalyptus

Hawks love the eucalyptus trees and nest in them

Raccoons live and depend on non-native trees

opossums live in and depend on non-native trees

The bunny habitat has been eradicated by NAP from Twin Peaks — the bunnies are gone

coyotes depend on dense thickets and underbrush for their safety

A drawing of San Francisco before photography

photo showing the native plants in 1885 — there were few — there’s little to “restore” to

our forests are slated to be removed — these, 1600 trees, will be razed

non-native cotoneaster feeds birds and other wildlife

poisons are sprayed every four months on Twin Peaks which serves as an experimental butterfly habitat for 17 butterflies

poisons signs are often mislabeled, so you don’t know what is going on

poison signs are a regular sight in many of our so called “natural areas” in SF

vast fields of clover are sprayed with poisonous pesticides — fields our kids and dogs romp in

understory has been cleared from under the eucalyptus — it’s now bare — nothing but non-natives will grow there

chain saws are used to cut down animal habitat because it is not native

non-native understory has been removed from these eucalyptus — nothing else will grow here, so now there is no useful habitat below the trees

A native plant garden looks like this: fences and brown weeds

1. Comments by Professor Arthur Shapiro

These comments by Professor Arthur M. Shapiro, are posted with his permission, and re-posted from two other websites: Death of a Million Trees, and Save Mount Sutro Forest. These two websites are loaded with pertinent information on this subject. Shapiro is Distinguished Professor of Evolution and Ecology at UC Davis and a renowned expert on the butterflies of California.  Please be aware of his credentials as you read this.  Hopefully, these comments will inspire you to write your own comment by the deadline, which has been extended to October 31, 2011.  Details about how to submit your comment are available from the Death of a Million Trees website here. I am republishing this because of my concern for existing animal habitat which is being replaced in our so-called “natural areas” with native grasses which have no protective habitat value for the wildlife existing in our parks.

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October 6, 2011
Mr. Bill Wycko:
San Francisco Planning Department
Re: DRAFT EIR, NATURAL AREAS PROGRAM

Dear Mr. Wycko:

Consistent with the policy of the University of California, I wish to state at the outset that the opinions stated in this letter are my own and should not be construed as being those of the Regents, the University of California, or any administrative entity thereof. My affiliation is presented for purposes of identification only. However, my academic qualifications are relevant to what I am about to say. I am a professional ecologist (B.A. University of Pennsylvania, Ph.D. Cornell University) and have been on the faculty of U.C. Davis since 1971, where I have taught General Ecology, Evolutionary Ecology, Community Ecology, Philosophy of Biology, Biogeography, Tropical Ecology, Paleoecology, Global Change, Chemical Ecology, and Principles of Systematics. I have trained some 15 Ph.D.s, many of whom are now tenured faculty at institutions including the University of Massachusetts, University of Tennessee, University of Nevada-Reno, Texas State University, and Long Beach State University, and some of whom are now in government agencies or in private consulting or industry. I am an or the author of some 350 scientific publications and reviews. The point is that I do have the bona fides to say what I am about to say.

At a time when public funds are exceedingly scarce and strict prioritization is mandatory, I am frankly appalled that San Francisco is considering major expenditures directed toward so-called “restoration ecology.” “Restoration ecology” is a euphemism for a kind of gardening informed by an almost cultish veneration of the “native” and abhorrence of the naturalized, which is commonly characterized as “invasive.” Let me make this clear: neither “restoration” nor conservation can be mandated by science—only informed by it. The decision of what actions to take may be motivated by many things, including politics, esthetics, economics and even religion, but it cannot be science-driven.

In the case of “restoration ecology,” the goal is the creation of a simulacrum of what is believed to have been present at some (essentially arbitrary) point in the past. I say a simulacrum, because almost always there are no studies of what was actually there from a functional standpoint; usually there are no studies at all beyond the merely (and superficially) descriptive. Whatever the reason for desiring to create such a simulacrum, it must be recognized that it is just as much a garden as any home rock garden and will almost never be capable of being self-sustaining without constant maintenance; it is not going to be a “natural,” self-regulating ecosystem. The reason for that is that the ground rules today are not those that obtained when the prototype is thought to have existed. The context has changed; the climate has changed; the pool of potential colonizing species has changed, often drastically. Attempts to “restore” prairie in the upper Midwest in the face of European Blackthorn invasion have proven Sisyphean. And they are the norm, not the exception.

The creation of small, easily managed, and educational simulacra of presumed pre-European vegetation on San Francisco public lands is a thoroughly worthwhile and, to me, desirable project. Wholesale habitat conversion is not.

A significant reaction against the excesses of the “native plant movement” is setting up within the profession of ecology, and there has been a recent spate of articles arguing that hostility to “invasives” has gone too far—that many exotic species are providing valuable ecological services and that, as in cases I have studied and published on, in the altered context of our so-called “Anthropocene Epoch” such services are not merely valuable but essential. This is a letter, not a monograph, but I would be glad to expand on this point if asked to do so.

I am an evolutionary ecologist, housed in a Department of Evolution and Ecology. The two should be joined at the proverbial hip. Existing ecological communities are freeze-frames from a very long movie. They have not existed for eternity, and many have existed only a few thousand years. There is nothing intrinsically sacred about interspecific associations. Ecological change is the norm, not the exception. Species and communities come and go. The ideology (or is it faith?) that informs “restoration ecology” basically seeks to deny evolution and prohibit change. But change will happen in any case, and it is foolish to squander scarce resources in pursuit of what are ideological, not scientific, goals with no practical benefit to anyone and only psychological “benefits” to their adherents.

If that were the only argument, perhaps it could be rebutted effectively. But the proposed wholesale habitat conversion advocated here does serious harm, both locally (in terms of community enjoyment of public resources) and globally (in terms of carbon balance-urban forests sequester lots of carbon; artificial grasslands do not). At both levels, wholesale tree removal, except for reasons of public safety, is sheer folly. Aging, decrepit, unstable Monterey Pines and Monterey Cypresses are unquestionably a potential hazard. Removing them for that reason is a very different matter from removing them to actualize someone’s dream of a pristine San Francisco (that probably never existed).

Sociologists and social psychologists talk about the “idealization of the underclass,” the “noble savage” concept, and other terms referring to the guilt-driven self-hatred that infects many members of society. Feeling the moral onus of consumption and luxury, people idolize that which they conceive as pure and untainted. That may be a helpful personal catharsis. It is not a basis for public policy.

Many years ago I co-hosted John Harper, a distinguished British plant ecologist, on his visit to Davis. We took him on a field trip up I-80. On the way up several students began apologizing for the extent to which the Valley and foothill landscapes were dominated by naturalized exotic weeds, mainly Mediterranean annual grasses. Finally Harper couldn’t take it any more. “Why do you insist on treating this as a calamity, rather than a vast evolutionary opportunity?” he asked. Those of us who know the detailed history of vegetation for the past few million years—particularly since the end of Pleistocene glaciation—understand this. “Restoration ecology” is plowing the sea.

Get real.

Sincerely,
Arthur M. Shapiro
Distinguished Professor of Evolution and Ecology

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2. Comments by Nancy Otto

October 17, 2011

 

 Mr. Bill Wycko, Environmental Review Officer

San Francisco Planning Department

1650 Mission Street, Suite 400

San Francisco, CA 94103

Re:  Draft EIR, Natural Areas Program

 

Dear Mr. Wycko:

 

I have lived in San Francisco since 1988 and bought my first home in Glen Park in 1992.  Since then I have been a devoted Glen Canyon Park visitor.  In fact, I walk in Glen Park almost every morning.

 

I have never given public comment before about anything in San Francisco.  I am a consultant and extremely busy.  However, I am so bothered by the use of pesticides by the Natural Areas Program of Park and Recreation that I had to get involved.  I have been actively trying for the past year to stop the Natural Areas Program from using Tier 1 and Tier 2 pesticides to “kill” non-native plants.

 

In San Francisco, the Board of Supervisors legislated that all San Francisco officers, boards, commissions, and departments of the City and County implement the Precautionary Principle in conducting the City and County’s affairs.   The Precautionary Principle states, “where threats of serious or irreversible damage to people or nature exist, lack of full scientific certainty about cause and effect shall not be viewed as sufficient reason for the City to postpone cost effective measures to prevent the degradation of the environment or protect the health of its citizens.”

 

And yet, the Department of the Environment and the Natural Areas Program justify using Tier 1 and Tier 2 pesticides even though they lack full scientific certainty about how safe they are to use.  For Garlon 4 Ultra, a Tier 1 pesticide, the Department of the Environment has told me directly that while there is a study that has been conducted that raises serious concern, the methods of the study are not strong enough to justify outright banning of Garlon 4 Ultra.

 

I know of so many people, very close friends, who have been diagnosed with cancer in San Francisco.  We are all too familiar with corporate claims that there is not strong enough proof that the products they make can be directly linked to cancer.  That was the similar case with tobacco.  How many people had to get sick and die before the government put restrictions on the sale of tobacco because there wasn’t enough proof?  There simply is not enough money to test every pesticide thoroughly, and every new variation of a pesticide, to stay ahead of the harm that might be caused.

 

As citizens, all we can rely on is the information that the San Francisco Department of the Environment and the manufacturer of the pesticides tell us.  For Garlon 4 Ultra, the Department of the Environment limits its use “only for targeted treatments of high profile or highly invasive exotics via dabbing or injections.  May use for targeted spraying only when dabbing or injection are not feasible and only with use of a respirator.”  

 

The Natural Areas Program sprays the whole hillside of Glen Park Canyon with Garlon 4 Ultra to get rid of oxalis, commonly known as clover.  

 

The manufacturer of Garlon 4 Ultra publishes in their Material Safety Data Sheet that it degrades slowly in the environment, fails tests for ready biodegradability, is “highly toxic” to aquatic life and “slightly toxic” to birds.

 

In Glen Park Canyon, along the stream, there are signs heralding this riparian community and how it serves as a resting spot for migratory birds.  How ironic that the Natural Areas Program then uses pesticides that are “highly toxic” to aquatic life and “slightly toxic” to birds.

 

The Precautionary Principle is supposed to be there to protect all of us.  I worry about the wildlife that live in Glen Canyon Park and rely on the vegetation to survive. I worry about the pre-school children who come and play in the park everyday.  I worry about all the dogs who run on the trails and eat the grasses.  And I worry about my city that I love so much ignoring the repeated concerns of its citizens and refusing to alter course.

 

This doesn’t feel like a truly democratic process to me.

 

I am vehemently opposed to the recommendations of the draft Environmental Impact Report for the Natural Areas Program. The Natural Areas Program has not effectively demonstrated its ability to:

1.    kill the non-native invasive species it poisons each year – it grows back each spring

2.    comply with regulations on how to administer the poisons – they are frequently caught applying the poisons without adequate notice or using appropriate respirators

3.    create a sustainable native plant garden without relying on toxic pesticides.

I cannot understand how we would then turn around and give the Natural Areas Program more authority over more land to continue with these same practices.

 

Sincerely,

 

 

Nancy Otto

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3. My Comments

Mr. Bill Wycko

Environmental Review Officer

San Francisco Planning Department

1650 Mission Street, Suite 400

San Francisco, CA 94103

bill.wycko@sfgov.org

Subject:  Public Comment on Draft Environmental Impact Report for Natural Areas Management Plan

Dear Mr. Wycko,

I am a resident of San Francisco, and am keenly interested in its wildlife,  truly natural areas, and habitat. My prime occupation is taking photographs, and I study the behavior of urban wildlife – I spend three or more hours daily doing this.  I have had exhibits at The Seed Gallery of The Tides Foundation in the Presidio, at the Josephine Randall Junior Museum, and at the main branch of the San Francisco Public Library. I have written articles and self-published a booklet to inspire acceptance of our coyotes and wildlife. I am specifically interested in our wildlife which is not protected because it is not on any “endangered” lists.

The current Draft Environmental Report appears to be slanted toward “Native Plant” management, at the expense of other interests.

The removal of so called “invasive” plants destroys habitat.

1. The report repeatedly mentions “invasive trees”,  usually in reference to eucalyptus. This tree has not been shown to be invasive. The trees that are here were planted, many of them a century or more ago. The main issue appears to be that they are occupying land that Native Plant advocates want to convert to Native Plant areas.

2. The trees, as well as other plants targeted for removal (including blackberry brambles and vines) form valuable habitat for birds, animals and insects. By focusing on a handful of species, the needs of all the others are neglected. The areas of Native Plants do not appear to be superior habitat in general. With a few exceptions, they do not provide the cover or the food resources birds and animals need. Thousands of eucalyptus trees and thousands of cubic feet of bushy habitat are being destroyed.

Strong toxic pesticides are increasingly necessary.

3. Because Native Plants are no longer suited to this eco-system – and because of the need for NAP to stop Natural Succession, when different plants in turn dominate a particular area – the “Natural” Areas Program requires a great deal more pesticides than would be needed if these areas were truly natural. The Report underplays both the amounts and the toxicity of the pesticides that will be used. In fact, it does not even say how much will be used.

4. Garlon (triclopyr), Roundup (glyphosate), and Imazapyr are mentioned as the most likely chemicals to be used. Garlon is a Tier I (Most Hazardous) chemical. Roundup and Imazapyr are Tier II. No Tier III herbicides are even mentioned.

5. The report contains errors that minimize the impact of these chemicals.

1. •On p 365, it says Garlon degrades quickly and has low toxicity to aquatic species. However, the Material Safety Data Sheet (MSDS)  (http://www.fs.fed.us/r5/eldorado/documents/freds/WEB%20Only/garlon_4_msds_rev_030909.pdf) says “Material is highly toxic to aquatic organisms” and also that it is “slightly toxic to birds.” The MSDS also says the material is “expected to biodegrade only very slowly in the environment” and “Fails to pass OECD/EEC tests” (for ready biodegradability). The report says Garlon is being phased out; but if the NAP’s tree-felling program goes through, a lot more will need to be used to prevent resprouting since it is the only herbicide known to prevent the resprouts of eucalypts.
   

2. •Imazapyr – which was approved for NAP’s use in 2011 – is not approved for use in Europe. It moves readily in the soil, and is excreted by some plants through their root systems. It does not biodegrade quickly. Its end-product, quinolic acide, is a neurotoxin. The report does not mention these issues where it mentions using Imazapyr.
   

3. •Roundup (glyphosate) is the second most commonly used chemical in NAP (used 31 times in 2010 compared to Garlon’s having been used 36 times). This has been linked to birth defects (including brain damage and neural tube damage) in humans and in animals. (Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling; Carrasco et al. http://pubs.acs.org/doi/abs/10.1021/tx1001749)   It is also highly lethal to amphibians, according to a University of Pittsburgh study. This is a concern because many of the areas where it is used have water nearby. Glen Canyon, for instance, has a stream running through it. Roundup is also associated with changes to the soil and fungal root disease. http://www.reuters.com/article/2011/08/12/us-glyphosate-idUSTRE77B58A20110812
   

4. •The main argument used by the Draft EIR to justify the use of pesticides in the natural areas is that NAP is following the rules, that therefore by definition there is no environmental impact from its use. (This reminds me of a recent US Supreme Court decision in which patients harmed by medical devices are now prohibited from suing the manufacturers of those devices if they were approved by the FDA.)  There are two reasons why this argument is not an adequate defense:  (1) NAP’s uses of both Garlon and Imazapyr have been granted by exception by the Department of the Environment and they are not used by other agencies in the city.  (2) NAP does not always follow the rules, such as posting a date of the application of the pesticide as required by policy.
   

The report says that only 10% of SF RPD’s pesticide use is in Natural Areas, which are 25% of the total area. However, certain places, such as sports fields and golf courses, use a disproportionate amount of herbicides. If the natural areas were truly natural, they would need no herbicides at all. The SFNAP should use no Tier II or Tier I herbicides.

NAP was originally intended to preserve the few remnants of San Francisco’s historical habitat, but the program has morphed into an empire that controls over one-quarter of all the city-managed parkland — land for which access is being limited by the NAP program in a city coping with more and more people. We have wonderful natural areas — forests, thickets and overgrown areas, which everyone loves as they are — they are truly natural — but they are being removed for NAP’s program.

NAP is actually harming the environment by destroying trees, established habitat, and established ecosystems which include our existing wildlife. NAP wants to recreate our environment as one of native grasses which might have existed in the area in 1776 — in very delimited spaces this seems fine, but they should not be taking over our parks which have evolved on all levels since that time. The grasses were native to a sand-dune ecology, but that is no longer the case within the city, and the grasses provide no protective habitat to the animals which now occupy these spaces — animals which are not on NAP’s “specified” or “endangered” lists. There has been an alarmingly high rate of failure when “endangered” species have been introduced — this is because they are no longer suited to this environment which has evolved and changed since 1776. NAP is a political program, not a program based on science, and one which is hampering people’s enjoyment and use of their parks.

And what about birds, raptors and furry animal life that are not on the endangered lists — wildlife which already lives in these areas now? There is no mention of these in the EIR. To put in their grasses, NAP is destroying healthy trees — trees which, besides offering animal habitat, offer shade, wind barriers, beauty and psychological relief.  The trees are part of ecosystems which were established over 100 years ago. They are a part of a balanced, healthy animal habitat. What ever happened to saving the trees?

We have now discovered that, for native plants, there is a huge issue of “sustainability” which has been totally overlooked by the NAP program: the Native Plants in fact cannot survive without artificial means of keeping them going, including huge amounts of human management and poisons to keep other growth down: this project is an absolute waste of resources. And the result is artificial museum gardens which preclude other uses of the parks — access to more and more areas is being restricted because of the NAP program. The very phrase “natural areas” is totally deceptive to the public — these are artificial creations.

If you need to look at areas which have been left totally bare because NAP ripped out what was there, look at the periphery of Pine Lake — the NAP program first began there 15 years ago and it is a mess. And now the lush growth in Glen Canyon is slowly and systematically being removed, NAP is turning a gem of a wilderness park — something that everyone wants retained — into a native grassland area, even removing and thinning truly-native willows and coyote brush. No one wants these parks turned into these artificial museum gardens except the NAP people themselves. Twin Peaks is sprayed with poisons every four months so that native plants can grow. More people that I speak to are for ending the NAP domination of our so-called “natural areas.”

For all these reasons, the Proposed Project as well as the “Maximum Restoration Alternative” are bad for wildlife, habitat and environment.  The “Maintenance Alternative”, as stated in the Draft Environmental Impact Report on page 526, states that this is the Environmentally Superior Alternative because it has the least negative impact on the environment of all alternatives. Of these alternatives, I am advocating the “Maintenance Alternative.” However, I and many others would like to see the NAP program actually cut back. Page 2 of your summary needs to be corrected to reflect what page 526 of the Draft says: that the “Environmentally Superior Alternative” is the “Maintenance Alternative.”

Please let’s preserve nature -- true nature and wildlife -- not these artificially created museum gardens for which NAP is destroying the forests, thickets and underbrush we have, that are non-sustainable needing constant human intervention and poisons, that are limiting access to those of us who use the parks.

Sincerely,
Janet Kessler
www.urbanwildness.com
www.coyoteyipps.com

All of these photos were taken in San Francisco parks and open spaces — these show the so-called “invasive” and “non-native” habitat used by our existing wildlife. This habitat: trees, thickets and dense undergrowth,  is being removed for native grasses. These animals are not listed in the EIR report -- why aren’t they?

 

 

Red-winged Blackbird in non-native Cherry tree

Honeybee hive in non-native Eucalyptus

Honeybee works in non-native wild mustard

Great Blue Heron family in non-native Monterey Pine

Nuthatch feeds and nests in non-native Eucalyptus

Great Horned Owlets born and raised in non-native Eucalyptus

Black-headed Grosbeak in non-native Eucalyptus

Honeybee finds pollen in non-native wild radish

Red-tailed Hawk finds mouse in non-native Iceplant

Gopher lives in non-native grasses

Baby Red-tail Hawks in their non-native Eucalyptus tree nest

Night Heron hunts in non-native Scotch Pine

Butterfly on non-native wild radish

Brown Creeper hunts for food in non-native Eucalyptus

Barn Owl nests in non-native palm tree

Song Sparrow in non-native wild radish

Garter snake feeds and hides in non-native Eucalyptus leaves

House Finch in non-native plant

Yellow Swallow-tail Butterfly feeds in non-native Fennel

Red-tailed Hawk makes nest of, and in non-native Eucalyptus tree

Brown Squirrel escapes in non-native Eucalyptus

Painted Lady Butterfly on non-native Wiegela

Great Horned Owl sleeps in Eucalyptus

Possum hunts around in a non-native Pittosporum (Victoria Box)

coyote hunts in non-native iceplant

Great White Heron in non-native grasses

Red Legged Frog in non-native pond plants

raccoon family nest in non-native pine

Twin Peaks is sprayed with Garlon4Ultra — note the required respirator is not being worn

San Francisco and its native plants in 1806

Mount Davidson and its native plants 1885

Beehive deliberately destroyed by NAP people on October 14, 2011

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4. Comments by Jamie Ray

October 31, 2011 

Dear Mr. Wycko,

My name is Jamie Ray, I am the founder and director of San Francisco's first and only wildlife hospital, San Francisco Rescued Orphan Mammal Program (SFROMP.org) 

SF ROMP was founded in 2001 with the following mission statement: Dedicated to preserving and enhancing San Francisco's rich biodiversity and increasing public appreciation of our native wildlife. 

SF ROMP rehabilitates injured and orphaned wildlife under license of the California Department of Fish and Game, works on state and local issues that effect wildlife, and provide educational programs about the wildlife we share our environment with, including a helpline that helps residents peacefully coexist with wildlife. SF ROMP  has worked with Recreation and Parks Capital Improvements Division on wildlife management plans, mitigation measures for wildlife effected by projects, and planted thousands of plants that provide habitat for wildlife in our local parks. I define habitat plants as those plants that provide the best food and/or shelter value for wildlife. With very few pockets of park space  that has not been trail blazed by people and dogs, it is my view that the best policy is to promote the planting of plants that provide the best habitat for wildlife, and in particular, dense and/or thorny plants that provide wildlife with protection from people and dogs, and safe nesting and denning sites. When habitat plants are also aesthetically pleasing, as they often are, this is a win-win for everyone. We're so fortunate in San Francisco to be able to grow drought tolerant plants from Mediterranean regions, Australia, New Zealand, South Africa and even the cloud forest regions of Central and South America! The list of SF native plants is a short one to be sure. The list of native trees contains four species, including two that need to grow in or near water. (willow and buckeye)  Oak and a native plum tree are the only other trees native to San Francisco.  To limit planting to these few plants is a net loss for wildlife and the enjoyment of park goers. 

Thank you for supporting the No Project Alternative.  

I support the No Project Alternative. NAP jurisdiction should not be expanded beyond the areas of their detrimental activities. Most plants require at least one or two summer waterings to establish. The NAP policy to not water any of the plants they install is instrumental in the monumental failure of many of their planted areas. 

The Natural Areas Program defines "natural areas" as areas planted only with plants that grew here when San Francisco was all sand and sand dunes. Before our city was built. Before our lush parks were created. 

This narrow definition of what is "natural" is absurd.  A natural area should be defined by the amount of wildlife it supports. By this definition, our parks are natural areas.

Why on earth would we want to return our parks to sand with tiny sand dune plants and coastal scrub when our parks have such incredible natural beauty and support such an incredible diversity of wildlife?

San Francisco is a bird watcher's paradise. The hawks and owls that nest in monterey cypress and pine trees cannot nest in any of the four (tediously slow growing) San Francisco "native" trees. 

Pines and Cypress are the backbone trees of our parks. They're not only beautiful, but provide habitat for countless species of wildlife. Removing these trees because they're "not native" would  be criminal.

Removing the plants that generations of gardeners have planted and tended to return these areas to sand, planted only with "native" coastal dune plants would decrease wildlife biodiversity. NOT increase wildlife biodiversity. 

We should not remove any existing vegetation (never mind 1100 acres, 1/3 of our parklands) to return these acres back into sand, with only coastal scrub plants. 

I love the lush vegetation in our parks and do not want ANY of it removed for any reason - but particularly for the ridiculous reason that a radical group (funded with my tax dollars) defines "natural" as only what was here before the city of San Francisco was built, and before our beautiful parks were created. 

As SF's population continues to grow and more large housing developments are planned, demand for recreation and relaxing in our parks increases. 

The Natural Areas Program fences off the areas that they first denude then plant with insignificant / tiny dune plants to create their plant museums. 

Spending tax dollars to take away recreation areas from residents is  outrageous.  

I would like more Rec and Park gardeners to be hired and less staff positions paid to the Natural Areas Program, who are intent on removing the lush vegetation that I enjoy in our parks. 

Thank You 

Sincerely, 

Jamie Ray, Director 

SF ROMP wildlife rehabilitation

Comments To The Environmental Impact Report for the New Draft of the Significant Natural Areas Program in San Francisco - October 2011