What UCSF’s EIR will Evaluate – and What it Won’t

Edited to Add: If you want to comment, the deadline is January 18 2011. Here’s the address to contact:The comment period ends January 18th. (Comments can be sent in writing to PHEIR@planning.ucsf.edu or to Diane Wong, UCSF Campus Planning, Box 0286, San Francisco, CA 94143-0288)

The Environmental Impact Report is supposed to evaluate potential impacts of the actions planned for Mount Sutro Forest. According to the Initial Study (this links to a PDF version on the UCSF website),

The project primarily involves thinning of the Reserve, removal of understory vegetation, conversion planting, native plant enhancement, and creation of new trails.

They will be considering the impact of the project on a number of things, including the aesthetics as seen from around the forest, carbon sequestration and air quality, impact on animals and plants, on cultural resources, landslides, hazards from herbicides and naturally-released asbestos. And wildland fires (where it notes: “The express purpose of the project is to improve the health of the forest and to reduce the exposure of persons and property to a forest fire. The impacts of proposed management activities with regard to the potential for a forest fire will be analyzed in the EIR.” Since we expect this project to increase the fire-hazard, we’re glad they’re raising it — though give the history of the project, we’d be surprised if they reach that conclusion.)

But the assessment also avoids some topics, deciding that they’re insignificant.


Those of us living by the forest recognize that the trees form a flexible living windbreak that adds some 10-20% to the height of the mountain. The assessment argues that trees with a 30-foot spacing will have the same effect, or a better one:

Winds in San Francisco predominantly come from the west and northwest. In general, increases in wind speeds may occur when winds are intercepted by a large plane, such as a dense stand of trees, and are redirected. Thus, a permeable stand of trees may be more effective in functioning as a wind break than a dense stand of trees. With a proposed average spacing of about 30 feet between trees for much of the Reserve, proposed management activities would not be sufficient to greatly affect the pedestrian‐level wind environment. Over time, as tree canopies expand, wind speeds would tend to be reduced. Thus, the proposed project would not expose persons or adjacent properties to substantially increased wind speeds. Thinning a narrow stand of trees may result in increased exposure to existing winds that may be noticeable to some people, but such effects would not be considered significant. For the reasons noted, wind impacts would be less than significant and will not be analyzed in the EIR.

We are skeptical. UCSF should recognize that wind is an important factor in this area, and may impact different neighborhoods differently. The effects may not be apparent until the second part of the project is well under way. Wind studies are definitely called for.


Though the assessment notes the value of the tree-screen in the Edgewood area in protecting those homes from the light and glare of the UCSF campus, it concludes the impact will be insignificant and therefore not needing evaluation:

A portion of the project site, the Edgewood area, is located between a row of residences to the east fronting Edgewood Avenue and campus buildings to the west, including Moffitt/Long hospitals and the central utility plant. Currently, vegetation and trees within the Edgewood area provide some visual screening of campus buildings from the rear yards of these residences, including possibly screening of light sources from the campus at night. Proposed vegetation management activities have the potential to reduce this visual screen. However, such impacts on adjacent private residences would not constitute a significant impact on day or nighttime views in the area. Therefore, light and glare impacts resulting from the proposed project will not be analyzed in the EIR.


The assessment is going to avoid the issue of runoff and of water-quality, even though this forest is clearly processing huge amounts of water. It precipitates water from the fog, catches it in the spongy duff (the layer of decaying plant matter beneath the undergrowth) and allows it to trickle out and into the soil. There’s a seasonal creek on the eastern side of the forest. Thinning trees and undergrowth is going to massively interfere with this — and it’s something that may not be visible with the demonstration projects. Anyone visiting Twin Peaks during or after a rainstorm can see run-off like gushing rivers, while the flows around Mount Sutro are relatively low; this clearly demonstrates the difference in water-drainage patterns.

This is what the initial study says:

Proposed management activities would not alter hydrology or water quality at the site. There are no surface waterbodies or public water supplies in close proximity to Parnassus Heights, and no aquifers or groundwater recharge areas have been specifically identified at this campus site. No known soil or groundwater contamination issues are present. Sewage and stormwater runoff from Parnassus Heights are treated at the Southeast and Oceanside Water Pollution Control Plants.

During wet weather, storage capacity at the Southeast Water Pollution Control Plant is sometimes exceeded, resulting in combined sewer overflows (CSOs). Although minor grading would occur for proposed trails, and some ground disturbance would occur in some locations from heavy equipment, trees to be removed would be cut above ground surface and root systems would be left in place. The project does not propose to modify the topography of the site or pave or modify the imperviousness of surface soils. Thus drainage patterns of the site and the amount or speed of surface runoff would not change with the proposed project. No alteration to the course of a stream or river would occur due to the project. These checklist topics will not be analyzed further in the EIR.


Construction (or presumably, destruction) noise is a factor, and will be mitigated by not starting work until 7 a.m. on weekdays. We hope everyone in the vicinity is an early riser and no one’s doing shift work at the hospital or someplace else.

Mitigation Measure #2: Construction Noise: Use of heavy equipment for management activities would, on a temporary basis, elevate noise levels in and around the project site, and particularly at nearby sensitive receptors. UCSF shall require contractors to minimize unavoidable construction noise impacts by use of proper equipment and work scheduling. Construction hours shall be limited to the following schedule:
• Monday through Friday, 7 a.m. to 5 p.m. for not noisy work (80 decibels or less at 100 feet)
• Monday through Friday, 8 a.m. to 5 p.m. for noisy work (more than 80 decibels at 100 feet)
• Extended hours only with advanced notice from the UCSF project manager (Monday through Friday, 5 p.m. to 8 p.m.; Saturday 7 a.m. to 8 p.m.; and Sunday 8 a.m. to 4:30 p.m.)
• No noisy work on Saturdays and Sundays.

That’s it for now. We’ll follow with more comments if needed.

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5 Responses to What UCSF’s EIR will Evaluate – and What it Won’t

  1. milliontrees says:

    UCSF’s initial assessment of the potential for changes in the effect of the wind resulting from the removal of thousands of trees is definitely inadequate because it does not consider the effect on the trees that remain. Trees develop their defenses against the wind as they grow. They develop root systems, angles of repose, bark density, etc., that is appropriate to the amount of wind to which they are exposed as they grow. If, after they have grown in a specific location, they are suddenly exposed to more wind, they are more vulnerable to failure. In this case, the removal of thousands of their neighboring trees will expose the trees that remain to more wind than they have developed the defenses for. Failure of the trees that remain are a likely result.

    We have seen a similar scenario at Stern Grove. Hundreds of trees were determined to be hazardous in 2003 by a certified arborist, but only the trees at the western end of the park were removed. The wind enters that park from the western end; therefore the trees that remained were suddenly exposed to more wind because the windbreak was substantially reduced by the removal of hundreds of trees. Trees now fall down in Stern Grove routinely. One killed a park visitor in 2008 (it was a REDWOOD branch). The city paid her parents $635,000 for their negligence. If this occurred on Mt. Sutro as a result of UCSF’s deforestation, they would (and should) be liable.

    A certified arborist explains the unintended consequences of destroying trees in the latest post on the Million Trees blog. Tree failure is only one of the unintended consequences.
    [Note: we have republished that post here, with permission.]

  2. Dirk says:

    Clearly, determinations of what was “not significant” in the initial study were about as delusionally subjective as UCSF’s expressed feeling that it conducted a fair public consultation process which determined that affected neighborhoods were thrilled to be loosing their forest.
    We don’t seem to be dealing with rational people…
    Yes, it is true that the world is run by people who stay to the end of meetings, but I’m not excited to be going to tonight’s scoping meeting.

  3. Pingback: Report: EIR Scoping Meeting, Jan 2011 | Save Mount Sutro Forest

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