A Rebuttal to UCSF’s Response to FEMA

This is an edited version of the letter sent to FEMA regarding UCSF’s response to their questions. Emphasis has been added.


[We were] quite surprised to read the details of UCSF’s response August 16 response to FEMA’s questions of July 21st. Most of it seemed to merely reiterate the assertions in its original application, and the new information was in fact rather confusing.

Please excuse the length of this letter. [We]would like to draw FEMA’s attention to a number of issues.


1. UCSF has provided an updated fire hazard map (July 2009), which shows an increased hazard on Mt Sutro.

The only major activity in the last 6 years in this century-old forest has been extensive trail-building by the Mount Sutro Stewards, which has had the effect of opening up the forest and thereby drying it out. It’s surprising that with this evidence, UCSF is arguing for more of the same.

The project areas of South Ridge and Edgewood are still not marked as hazard areas on the 2009 map – which is different from the 2003 map used in the FEMA application.

The 2009 map shows the West Ridge, the North Ridge, and an area below Johnstone Drive near the Chancellor’s residence – all areas where trails have been built in the last few years.

2. Meanwhile, the California Department of Forestry and Fire Protection, on its website, notes as recently as November 2008:

Update, 11/2008: CAL FIRE has determined that this county has no Very High Fire Hazard Severity Zones in LRA (Local Responsibility Areas).

3. The UCSF letter references fires between 1899 and 1948.

In 1899, the trees would have been mere saplings, and indeed the event was reported as a grass fire.

Later, logging in the forest, created exactly the kind of open conditions that UCSF seems to wish to recreate with the FEMA grant. Clearly, the thinned, dried-out forest is at greater risk from fire. Once logging stopped, so did the fires.

The letter references a mysterious fire recalled by a resident, requiring a 10-engine response. If a fire within the last 20 years required a 10-engine response, it is surprising that no newspaper report on the subject can be found. In any case, data should be available in the Fire Department’s records. UCSF should provide this documentation, together with any further details of the fire. Otherwise, the recollection may be faulty.

4. The letter mentions a fire in Marin “where there are large stands of eucalyptus.” This is presumably a reference to the Mt Vision fire. The letter also refers to the fire on Angel Island. In actual fact, neither of these fires involved eucalyptus. (As a further datum, even in the Oakland fires, the main cause was not eucalyptus or any trees.)

The Mount Vision area is primarily chaparral, with some forest of Douglas Fir and Pine. The Mount Vision Fire of October 1995 was a chapparal fire – a fire of the low scrub and grasses which actually would resemble the vegetation on Twin Peaks, not on Mount Sutro. In the dry season, the scrub and dry grass is extremely flammable – much more so than any tree. Caused by an illegal campfire, the Mt Vision fire involved no eucalyptus. http://www.sfsu.edu/~geog/bholzman/ptreyes/tripfire.htm

Angel Island, because of its location, has quite a different micro-climate than Mt Sutro, which is within San Francisco’s fog belt. According to the visitor information website, http://www.angelisland.org/faq2.htm “It is generally enjoys sunnier and warmer weather than San Francisco, which has many more days of fog.”

Same-hour photos - Twin Peaks and Angel Island

Same-hour photos – Twin Peaks and Angel Island

The Angel Island Fire was also grass and chaparral fire – Angel Island was denuded of nearly all its eucalyptus more than a decade ago. The residual 6 acreas of eucalyptus didn’t burn. Before the trees were cut down, the only fires seem to have been structural fires. After the eucalyptus was removed, there have been at least two fires, in August 2006 and October 2008, both of which burned grass and chaparral.


The forest lies squarely within San Francisco’s fog belt. Without going into technical terminology as to what constitutes a cloud forest, it is clear that Sutro Forest experiences fog drip through the summer especially, and gets perhaps 30-40% more moisture than the non-wooded areas. This keeps the moisture content high year-round.

UCSF refers to several weeks when “dry, hot winds blow from the northeast.” We would like to see documentation about this. Those of us who have lived in San Francisco – and Forest Knolls/ Cole Valley – for many years, have hardly encountered even a warm breeze, let alone hot dry winds, in the fall or at any other time. The winds are usually cold and damp, coming as they do from the ocean. This should not be a matter of opinion. Weather patterns are recorded. UCSF should produce evidence of hot dry north-easterly winds blowing past Mount Sutro.


UCSF claims that having fewer trees will reduce the risk of wildfire. Angel Island and San Bruno Mountain clearly demonstrate this is NOT the case. The dense tree cover, which traps the moisture in the forest, keeps it damp year round, and the dense shade discourages the growth of grasses and easily flammable vegetation. The blackberry and fern remains green and damp. Grasses, on the other hand, dry out – as is apparent in the Native Garden at the summit.

UCSF says it will not reseed the area. Unless it actively controls growth by extensive use of herbicides, weeds will take over whether or not it replants. The greater sunlight will allow the growth of flammable plants, and the drier conditions in a thinned forest will make them more vulnerable to fire. Besides, even if UCSF does not re-seed the area, Mt Sutro Steward Volunteers might well undertake to do so. Tree removal is the most difficult and expensive part of the native plant conversion, which the Mt Sutro Stewards have openly declared as their objective.

UCSF mentions preventing insect infestations, and providing easier access. There is no evidence of the insect infestations mentioned in the letter, and the two project areas are already the most accessible in the forest. South Ridge is accessible by a paved road to the summit, and Edgewood is bounded by Medical Center Way and a car park. In fact, the applications note that as a reason these areas were selected.

While all these trees were planted around the same time, eucalyptus is a tree that regenerates spontaneously from lignotubers. There is already age variety within the forest as new stems have sprouted over the last century. There is little risk of any mass die-off. The forest is currently healthy and damp. Some dead trees are natural to any forest, and are an important habitat for woodpeckers and other birds.


UCSF has only discussed clearly appalling alternatives such as clear-cutting or prescribed burns.

If there was a fire risk for some few weeks each year, one alternative would be to spray the forest with water once or twice a year. This is not as far-fetched as it sounds. The garden at the top of the mountain is already irrigated. Much of the mountain is already accessible by paved road. With the co-operation of the fire department, water could be sprayed over the two areas UCSF now plans to gut, and the forest preserved. It would be cheaper, and not an irreversible move as this one is.


The letter makes reference to a Long-term Plan and a demonstration plot of 2 acres. The small area was chosen specifically because of neighborhood objections. UCSF’s long-term plan had very little to do with fire-management. It was more a plan to gradually convert the forest to native species. Though UCSF says it was adopted with neighborhood input, their own plan makes it clear the neighbors were very skeptical.

In fact, the Plan said, ‘The primary reason this short-term strategy was adopted is because the community members involved in the planning process did not support a long-term management plan until some management actions had been implemented in small, relatively unseen demonstration areas of the forest.’

So the demonstration, which was initially about forest thinning for native plant conversion, was only supposed to be 2 acres, a size which would be a relatively small problem if it failed. Now, because UCSF believes it can obtain the FEMA grant, the “demonstration” area is upped by a factor of four. It’s the whole of the South Ridge, which is not exactly small and relatively unseen.

Wasn’t the FEMA money was to supposed to reduce fire hazards, not fund demonstrations of forest conversion?


The letter refers to the Mount Sutro Stewards, one of whom provided much of the “evidence” of fire-hazard.

Many of us believe that this organization provided the main impetus for the planned projects. The Mt Sutro Stewards are volunteers from ‘Nature in The City,’ which declare as the first of their Goals: “Restore the natural landscape, biodiversity, natural areas, watersheds and local ecological processes of the northern San Francisco peninsula, the Franciscan bioregion.”

Native Plant activists are anti-eucalyptus as an ideology.

Indeed, the May 18, 2009 public meeting on these proposed projects kicked off with a slide presentation on native plant restoration on Mt Sutro, made by one of the Stewards, [ETA: Craig Dawson, subsequently Executive Director of Sutro Stewards] which included pictures of plants in the Native Garden, and slides of mature oak trees which he presented as representing the future of this forest. The UCSF presenter deferred several audience questions to others in that organization.

Many of the neighbors are convinced that native plant supporters in general, and UCSF in particular, seek to use FEMA to fund removal of eucalyptus forests to make way for native plant conversions – which, ironically, increase the risk of fire.

The FEMA application also contained several factual errors. We pointed these out.

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