This article has been reprinted with permission from Death of a Million Trees, a blog dedicated to preventing unnecessary tree-felling.  (The emphasis is ours, as are minor edits.) [Edited to Add: MillionTrees updated this post. We have copied over the same note into the article.] [ETA 2: The Deadline for comments has been extended to October 31, 2011.]

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Fifteen years after San Francisco’s Natural Areas Program (NAP) began operation and 5 years after its management plan was approved, the Draft Environmental Impact Review (EIR) has finally been published [the details of the Management Plan are available on the sfgov website here].  We will briefly summarize the history of NAP, describe the plans as they were approved in 2006, and conclude with a comparison between those plans and the proposal in the EIR to aggressively expand NAP.

NATURAL AREAS PROGRAM – THE MANAGEMENT PLAN

In 1995 the Recreation and Park Commission approved the designation of 31“natural areas” in parks managed by the city of San Francisco. This designation committed 25% of the city’s park acreage in San Francisco, 33% including the city of Pacifica to the Natural Areas Program.

Most park visitors were unaware of this designation until 5 years later when they finally had access to a draft of the management plan after a lengthy battle to make it available.  At that point, many park visitors could see where the Natural Areas Program was headed and many of them reacted negatively to the prospect of the destruction of non-native trees and restrictions on recreational access in popular, heavily visited parks.

The result of the long debate with the public was a revised management plan that separated the natural areas into three “management areas.”  These management areas (MAs) set priorities for the restoration of parkland to native plants:  MA-1 was the highest priority, MA-2 the second priority, and MA-3 the lowest priority.  The appeal of these priorities to critics of NAP was the commitment that there would be no tree removals in the MA-3 areas and that no legally protected species would be planted or reintroduced there, which might require further access restrictions in the future.  Forty-two percent of the total 1,080 acres of natural areas was designated as MA-3.

The management plan was approved in 2006, after two days of public hearings at which about 200 public comments were heard by the Recreation and Park Commission.  [The whole thing is available as a huge 367 MB ZIP file here, or as links to individual parks.] Supporters of NAP outnumbered critics of the program.  The main message of the critics of the program was that the acreage committed to natural areas should be reduced to places in which native plants existed, which would not include acreage designated MA-3.

There were two trivial caveats to the approval of the program:  defining the circumstances under which cats could be removed from the natural areas and specifying that tree removals must be done by the Urban Forestry Division of the Recreation and Park Department (RPD).  These are some of the main features of the approved management plan:

•  Tree removals:   18,500 trees over 15 feet tall were designated for removal in MA-1  and   MA-2 areas. In addition, non-native trees under 15 feet tall would be removed in these areas, but were not quantified because the plan did not define them as “trees”
•  Trails.  10.3 miles of trails were designated for closure in these areas.  That represented 26% of all trails in the natural areas.
•  Dog Play Areas are those areas in parks that have been officially designated for off-leash recreation.  The NAP management plan identified several dog play areas that would be monitored for possible closure in the future if necessary to protect native plants.  Those dog play areas were in Bernal Hill, McLaren and Lake Merced parks.
• Golf Course at Sharp Park will be reconfigured to accommodate populations of two endangered species.

ENVIRONMENTAL IMPACT REVIEW: WHAT’S CHANGED

Five years after the approval of the management plan, the Environmental Impact Review (EIR) has finally been published.  The EIR identifies 4 alternatives to move forward with the implementation of the plan. The EIR identifies the “Maximum Restoration Alternative” as the “Environmentally Superior Alternative” described as follows:

“This alternative seeks to restore native habitat and convert nonnative habitat to native habitat wherever possible throughout the Natural Areas, including all management areas.”

[ETA:  This article has been updated by a more recent post which reports that a mistake has been found in the Draft Environmental Impact Report (DEIR):  The “Maximum Restoration Alternative” is not the “Environmentally Superior Alternative” as the DEIR claims on page 2.  The “Maintenance Alternative” is the “Environmentally Superior Alternative” as the DEIR says on page 526.  The mistake on page 2 has been reported to the Planning Department.  The Planning Department has acknowledged the error on page 2 and has made a written commitment to correct the error in the Final Environmental Impact Report.  Unfortunately, this correction will not be made until the public comment period is over.]

In other words, the preferred alternative would do away with the priorities identified in the management plan and treat all three management areas the same.  These are the specific implications of this proposal as described by the EIR:

•  Trees.  Non-native trees would also be removed in the MA-3 areas.  The number of trees over 15 feet tall that will be removed will exceed 18,500, but the EIR does not quantify how many trees will be removed.
• Trails.  More trails would be closed in the MA-1 and MA-2 areas, but the EIR is not specific about how many miles of trail will be closed.
• Dog Play Areas.  All dog play areas in MA-1 and MA-2 areas would be closed.  This will close the dog play areas in Buena Vista and Golden Gate (Southeast) parks and what little remained of McLaren (Shelley Loop) and Bernal Hill after the closures mandated by the management plan.  Dog play areas in MA-3 areas will be monitored and closed in the future if necessary to protect native plants.  The EIR predicts that all of these closures in addition to the anticipated closures of GGNRA properties to off-leash dogs will result in heavier usage of the dog play areas that remain.
• Golf Course at Sharp Park would be further reduced by expanded habitat for endangered species.
• Other access restrictions.  Legally protected species will be introduced in MA-3 areas, which may require further restrictions on access in the future.

The other alternatives identified in the EIR are:

1.   “No Project Alternative – Under this alternative, the SFRPD would continue with the management activities authorized under the 1995 management plan.”  This alternative will close the dog play areas that were monitored since the management plan was approved in 2006: the Mesa at Lake Merced, portions of Bernal Hill and McLaren (Shelley Loop).
2. “Maximum Recreation Alternative – This alternative seeks to restore and improve recreational access to the Natural Areas wherever it does not interfere with the continued existence of native species and federally or state-listed sensitive species.”
3. “Maintenance Alternative – This alternative seeks to maintain the current distribution of native and nonnative habitat and species throughout the Natural Areas.  Under this alternative there would be no conversion of nonnative habitat to native habitat; other features of the Natural Areas would be retained.”

REWARDING FAILURE

Park visitors who have been watching the restoration efforts of the Natural Areas Program for the past 15 years might be surprised that NAP apparently wishes to expand its restoration efforts.  Repeated clearing of non-native plants and planting of native plants have been spectacularly unsuccessful.  Here’s a photo history of the effort at Pine Lake in Stern Grove:

One of several clearing and plantings of south shore of Pine Lake, 2003

Pine Lake, South Shore, 2011

North shore of Pine Lake, 2003

The results, north shore of Pine Lake, 2011

If NAP has been unable to successfully restore 58% of acres of natural areas (MA-1 and MA-2) they have been actively working on for the past 15 years, why would they want to expand their empire by adding MA-3 acreage to their agenda, committing them to actively restoring all 1,080 acres of natural areas?  Aren’t they biting off more than they can chew?

Where will the money come from to fund this expanded effort?

Although NAP and its many supporters believe that this lack of success is because they haven’t been adequately funded, the NAP staff is one of the only divisions in the Recreation and Park Department that hasn’t been cut in the past 10 years.  While other gardeners have been laid off, the NAP staff has remained the same size.  How many gardeners will it take to expand their restoration efforts to the MA-3 areas as the EIR proposes?  Remember that the MA-3 areas are 42% of the total NAP acreage.  Will NAP be given a 42% increase in their staff?  One wonders where the money for such an increase in staff would be taken from.

How much more herbicide will be used in this expanded effort?

Will a 42% increase in actively management NAP acreage require more herbicide use?  The Natural Areas Program applied herbicides to the so-called “natural areas” 69 times in 2010. Most of those applications were of the most toxic herbicide (Garlon) for which the Natural Areas Program was granted exceptional permission to use by the Department of the Environment.  How much more herbicide must be used by NAP if they actively manage the MA-3 areas?  The EIR is curiously silent on this question.

PUBLIC COMMENTS

The public will have two opportunities to comment on the EIR and its “preferred alternative” which will:

• Aggressively expand the restoration efforts of the Natural Areas Program,
• Require more tree removals,
• More recreational access restrictions,
• Probably cost much more,
• And probably increase the use of herbicides.

“A public hearing on this Draft EIR and other matters has been scheduled by the City Planning Commission for October 6, 2011, in Room 400, City Hall, 1 Dr. Carlton B. Goodlett Place, beginning at 1:30 p.m. or later. (Call 558‐6422 the week of the hearing for a recorded message giving a more specific time.)”

“Public comments will be accepted from August 31, 2011 to 5:00 p.m. on October 17, 31, 2011. [Note:  The deadline has been extended at the request of the Planning Commission.] Written comments should be addressed to Bill Wycko, Environmental Review Officer, San Francisco Planning Department, 1650 Mission Street, Suite 400, San Francisco, CA 94103. Comments received at the public hearing and in writing will be responded to in a Summary of Comments and Responses document.”

“If you have any questions about the environmental review of the proposed project, please call Jessica Range at 415‐575‐9018.”

Readers: If you have an opinion about the expansion of the Natural Areas Program proposed by the Environmental Impact Review you would be wise to speak/write now.  It is your last opportunity to do so.