San Francisco’s Natural Areas: The Many Mistakes in the Draft EIR

We’ve posted several times recently about the San Francisco Natural Areas Program.

In this post, we’d like to talk about the Draft Environmental Impact Report (EIR), open for comments until October 17 31, 2011. [Note: The deadline has been extended, at the request of the Planning Commission.]  It’s meant to examine the Environmental Impact of the “Significant Natural Resources Areas Management Plan” (SNRAMP).


The SNRAMP is a plan for managing the 1100+ acres of  31 “Natural Areas” in San Fran and Sharp Park in Pacifica. Published in in 2006, it was based on an earlier version from 1995.  The Natural Areas are categorized into three levels of management priorities: MA-1, MA-2, and MA-3, which indicate, roughly, the degree to which they will tolerate the non-native trees and plants that comprise the habitat for wildlife, recreational activities by humans,  off-leash dog play, and in an inverse relation, pesticide use.

Splendid but doomed - trees in Bayview Park being killed by girdling (chopping out a band of bark)

Here’s what the Plan calls for

  • Felling trees. Cutting down nearly 18,500 trees: 3,500 trees in San Francisco — and another 15,000 in Sharp Park in Pacifica.
  • Closing trails. The Plan calls for closing (or “relocating”) around 10 miles of existing trails in use in these areas — and building less than a mile of new trail.
  • Closing dog play areas. The Plan would eliminate the Lake Merced dog play area; reduce the Bernal Hill area by 6 acres and the McLaren Park dog play area by over 8 acres. All told, it would reduce the dog play areas by over 19 acres, or more than 20%. (This comes on top of restrictions imposed in the Golden Gate National Recreation Area.)

It’s also a war against the non-native “invasive” species, by any means possible. (Most trees in San Francisco would fall into that category.) What that amounts to in practice is a goodly amount of pesticide, as we described earlier. And thousands, many thousands, of dead trees.

By law –specifically the California Environmental Quality Act (CEQA) — the SF RPD must examine the impact of that plan on the environment; that’s an Environmental Impact Report (EIR). The Draft EIR has recently been published and the public can comment on it until October 17 31, 2011. [Note:  The deadline has been extended at the request of the Planning Commission.]


CEQA requires them to consider alternatives to the proposed Plan. In this case, the Draft EIR lays out four of them. These are:

  • The “No Project” Alternative. This would default to the 1995 plan.
  • The “Maximum Restoration” alternative. This would seek to convert all 32 areas to native plants wherever possible (or at least attempt it, whatever the outcome).
  • The “Maximum Recreation” alternative. This would focus on recreation in these areas, to the extent the recreational activities didn’t clash with the “continued existence of native species” and “federally or state-listed sensitive species.”
  • The “Maintenance” Alternative. This would maintain the status quo; support and preserve the native species where they exist, leave the non-native habitat as it is, and preserve the other existing features of the Natural Areas.

It  then evaluates the effect of the Plan on many things, including:

  • land use and planning;
  • aesthetics;
  • cultural and paleontological resources;
  • wind and shadow;
  • recreation;
  • hydrology and water quality;
  • hazards and hazardous materials;
  • agriculture and forest resources;
  • air quality

Unfortunately, this 562-page document (not counting the appendices!) is peppered with mistakes. It’s natural to make mistakes, but when they all tend in one direction – toward minimizing the impact of the proposed Plan or alternatives favored by Native Plant Advocates, one cannot but suspect a bias. These are the ones we’ve discovered thus far; there may be others we haven’t yet found.


The biggest and most obvious one is on page 2, the summary — which is all that many people will read. It wrongly states that the “The Maximum Restoration Alternative is the Environmentally Superior Alternative.” This is a mistake (and the City has admitted this). The actual “Environmentally Superior Alternative” is the Maintenance alternative. From the Draft EIR:

The Maximum Recreation and Maintenance Alternatives are the environmentally superior alternatives because they have fewer unmitigated significant impacts than either the proposed project or the Maximum Restoration Alternative…. the Maintenance Alternative has fewer potential environmental effects than the Maximum Recreation Alternative.

First, the Maintenance Alternative would not create new trails, the construction of which could result in impacts to sensitive habitats and other biological resources.

Second, over time the Maximum Recreation Alternative would result in Natural Areas with less native plant and animal habitat and a greater amount of nonnative urban forest coverage. The Maintenance Alternative, on the other hand, would preserve the existing distribution and extent of biological resources, including sensitive habitats. For these reasons, the Maintenance Alternative is the environmentally superior alternative.


  • Read your cites and get them right!  The Draft EIR understates the impact of cutting down thousands of trees on carbon sequestration, and misuses two scientific studies to suggest that grasslands would actually help fight global warming better than forest. (See: Fabricating facts to support native plant restorations.)
  • It doesn’t snow in San Francisco. The first study quoted suggests that above 50 degrees North latitude, grasslands covered in snow for months reflect more sunlight in winter than forest does, and thus may offset the forests’ carbon sequestration. So which state in the US may be concerned? Only Alaska. Not California — or for that matter, any other state — all of which lie below 50 degrees North latitude.
  • Not adding fertilizer in Natural Areas. The EIR also cites a second study to conclude: “Research studies have concluded that grassland and scrub habitat could act as a significant carbon sink.” But when you go to the cited study — it’s actually about managing pastures and grasslands degraded by overuse to improve carbon sequestration, mainly by adding fertilizer. There’s no plan to add fertilizer (only pesticide!) to Natural Areas. Did the EIR authors even read the studies they cited?
  • Garlon doesn’t degrade quickly. In the discussion of pesticide use, the Draft EIR describes Garlon thusly: It degrades quickly in the environment and has low toxicity to aquatic species (Dow 2009). Umm, no. What Dow actually says in its sheet on Garlon 4 (the version in use) is: “Material is expected to degrade only very slowly (in the environment). Fails to pass OECD/EEC tests for ready biodegradeability.”
  • Garlon is highly toxic to fish and other aquatic species. And as for Garlon having “low toxicity” to fish and other water-critters? Here’s what the manufacturer Dow says in the same Material Safety Data Sheet: “…highly toxic to aquatic organisms…”
  • The Mission Blue Butterfly isn’t at Bayview Park. The Draft EIR mentions the grasslands of Bayview Park as habitat for the famous Mission Blue Butterfly. The butterfly didn’t get the memo: its only San Francisco location is Twin Peaks, where dozens of them have been transferred in from San Bruno mountain (where they occur naturally). ETA: It isn’t in Sharp Park either as mentioned.
  • Before and After are the same pictures. There’s a discussion of scenic resources, which of course are going to be impacted when they cut down thousands of trees. But the pictures of Mt Davidson and of McLaren Park that are supposedly a simulation of the changed conditions are — the very same pictures, with red ovals superimposed. So of course the changes are “unnoticeable.” (The 15,000 missing trees of Sharp Park are not pictured. They’d be noticeable.)
  • The feral geese aren’t “feral.” In the “no project” alternative, there’s a reference to “feral geese.” In fact, they’re wild Canada geese – a protected species — not feral, meaning domesticated animals living free.


That’s not all. The Draft EIR is full of “huh?” moments.

  • It describes trees (mainly eucalyptus) as “invasive” though there’s no evidence that these trees are invasive in San Francisco/ Pacifica (or anywhere). (See: Photographic evidence that eucalypts are not invasive.) Similarly, the scrubland above Laguna Honda is contiguous with eucalyptus forest – but has not been invaded in over a hundred years.
  • It also notes that felling these trees wouldn’t “result in a significant adverse change in the significance of historic landscapes or urban forests.” Really? The eucalyptus forests, particularly on Mount Davidson and the Interior Greenbelt (Mount Sutro) are the last remnants of an extensive forest planted by a significant historic figure, Adolph Sutro. These trees are over a century old.
  • It understates the number of trees to be killed. According to a USDA 2007 study, San Francisco has 669,000 trees — but over half of these are small(under 6 inches in diameter) and most would fall into the “under 15 feet” category that the SF RPD doesn’t count as trees at all and kills at will.
  • It also says the felling of these trees wouldn’t result in significant windthrow risks. This is simply unreasonable. Trees that are not wind-hardened – as is the case of trees growing in dense stands – are exposed to wind by the felling of their neighbors. Since they have grown in protected conditions, they get pushed over by the high winds that sweep the high grounds in many of the hill-top natural areas. The EIR says the increased windthrow would not endanger anyone because it will happen inside parks and forests — but it will mean many more trees will die than the 18,500 already planned.
  • It plans on “urban forests” having 60-200 trees per acre (our estimate based on their formula for basal area).  That’s not forest, that’s a garden with trees in it. (Mount Sutro Forest has some 740 trees per acre. Japan’s Meiji Shrine forest has over 955 trees per acre.)
  • The EIR claims that felled trees will be replace with an equal number of planted trees — even though this is clearly impossible, and this fact is clearly indicated in the DEIR itself – there’s no place where such trees could  be planted even if they intended to do so. (See: Destroying the Trees of San Francisco)
  • It mentions that the trees to be removed would be mainly those that were dead or dying. In fact, the appendices clearly indicate that the tree removal is not about dead or dying trees, it’s about clearing spaces for Native Plants. (See: The Healthy Trees of San Francisco.)
  • The Report dismisses the scenic impact of felling 15000 trees in Sharp Park because the scrubland that is to replace them is “more consistent with the local native landscape.” Scenic?
  • It claims implementing this project would not create a significant hazard through “use of pesticides for vegetation control.”  But it certainly will require increased use of toxic herbicides: Garlon, Milestone, Roundup, and Imazapyr. Especially since part of the plan is to use pesticides on the cut stumps of the felled trees – 18,500 of them. (In fact, it may well be more, since the Plan isn’t considering trees under 15 feet in height – but would still apply toxic herbicides to the trunk of all the small trees it chops down.)


“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.”

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1 Response to San Francisco’s Natural Areas: The Many Mistakes in the Draft EIR

  1. Pingback: Killing Healthy Trees in SF’s “Natural Areas” | Save Mount Sutro Forest

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