Flaws in UCSF’s Sutro DEIR: Public Comments Due 19th March 2013

This post is about flaws in UCSF’s Draft Environmental Impact Report (DEIR) for Mount Sutro Open Space Reserve. It isn’t comprehensive, but hits some of the high points.

Here is the PDF of the DEIR: Mount_Sutro_EIR_1-16-13_with_Appendices


The DEIR avoids showing mock-ups of what the forest might look like after its Plan is implemented. Instead, it shows two sets of Before and After pictures eucalyptus trees elsewhere, provided by hired urban forester, Ray Moritz. (Page 4.1-15 and 4.1-16 of the DEIR, included here for purposes of discussion and criticism.)

Ray Moritz 13 curves pixThe pictures show a forest with understory removed, but the trees are clearly not spaced 30 (or 60) feet apart. They appear to be spaced 8-10 feet apart,  similar to the average spacing in Mount Sutro Forest now. (Given 740 trees per acre, it’s 8-9 feet apart.) Both “after” pictures include thin trees of the kind that would be eradicated under the Plan. So what the pictures actually represent is how the forest might look without its understory, vines, or epiphytes – but without any tree-felling.
ray moritz camino del canyon

Image credit: timchen / 123RF Stock Photo

Australian eucalyptus forest. Photo credit: Tim Chen, 123RF Stock Photo

sparse tree canopies says UCSF

This is a normal eucalyptus canopy but UCSF calls it sparse. Source: UCSF

The DEIR also includes pictures of the canopy which it characterizes as sparse and unhealthy. This reflects a misunderstanding of the forest and the species; it is actually the natural canopy of a eucalyptus forest, which is airy and not very dense, thus allowing for a subcanopy of smaller trees (acacia, plum in Sutro Forest), and a lush understory. [Edited to Add pictures. For comparison, we show a stock photo of an Australian eucalyptus forest as well as the “sparse tree canopies” from the DEIR. (Page 4.7-4 of the DEIR, included here for purposes of discussion and criticism.)]


The DEIR exaggerates the fire hazard – and its Plan will actually increase the risk by making the forest much drier and windier. (There’s a statement from a professional forest ecologist HERE.)

The arguments in the DEIR repeat those in the FEMA application: Eucalyptus is uniquely flammable owing to shed bark and oils within the leaves; dense forests are more flammable than open ones; that fires in the forest in 1899 and 1934 indicate its vulnerability; that the fires on Angel Island and Oakland are examples of fires that could occur in Mount Sutro Forest; that hot dry northeast winds in autumn cause a period of vulnerability for “several weeks.”  We thought we had already answered those arguments in this post: UCSF, Sutro Stewards, and the Fund-Raising Fire Hazard, and in this earlier post, Mt Sutro: The Fire Hazard That Wasn’t.

Sutro Forest is a de-facto Cloud Forest. It gets 30-40% more moisture than surrounding areas by catching moisture from the fog, which it then holds in its duff and understory. (We have an illustration of the process HERE.) This may be the wettest part of the city that isn’t actually under water.

According to CALFIRE, the hazard rating for Mount Sutro Forest is “moderate” – its lowest risk rating. The DEIR seeks to dismiss this by saying the map is a draft and could change. However, CALFIRE also noted: Update, 11/2008: CAL FIRE has determined that this county has no Very High Fire Hazard Severity Zones in LRA [Local Responsibility Area]. ” That covers Mount Sutro Forest. Clearly, in CALFIRE’s assessment, there is no Very High Fire Hazard.

FRAP map.38

San Francisco city does not get hot dry northeasterly winds (commonly called ‘Diablo’ winds); even when the East Bay has these conditions, the city remains cooler. According to the 2001 Plan, the vulnerability is for “up to ten days in the autumn.” In 2009, we maintained a daily FogLog during this so-called ‘period of vulnerability’ and recorded only 7 dry days – i.e. days when neither fog nor rain provided the forest with moisture. It will not dry out in 7-10 days in its natural state.

The fire hazard can be raised, however, by “thinning” the forest. This will dry out the “thinned” areas, and increase wind-speeds, thus increasing the likelihood that fires will spread if they start. So far, there have been – we are told – 3 small fires, the last in 1999. It was extinguished in 20 minutes. Had the forest had been drier and windier, and had it been a fire of grass and shrubs, it could have spread rapidly as the Angel Island fire did.

In fact, both Angel Island and the Oakland fire are counter-examples. Angel Island was covered with eucalyptus trees for decades. During that time, the only reference we could find to fire was a fire in a building. Since the trees were removed, there have been a number of fires, culminating in the October 2008 fire – which burned the grass and shrubs and stopped at the tree-line.

The Oakland fire also started with shrubs and grasses. It spread to trees and buildings, but the trees were victims of the fire, not the cause of it. The main fire spread from house to house. A report on that fire, from David Maloney who was on the investigative task force, is HERE. It also clarifies that eucalyptus is not particularly flammable.

The weather conditions in Oakland and on Angel Island are also completely different from Mount Sutro’s. Both those places have more extreme and drier weather.  Sutro Forest’s uniquely wet micro-climate is not comparable – though once the forest has been thinned and dried out, the comparisons might be closer.

You can already see evidence of this drying on the new trail from Stanyan, where 50 trees were cut along the trail, thus opening huge gaps in the canopy. A lot of understory was also removed. The forest is visibly drier there than in the more enclosed parts. Even the DEIR says it’s the South-facing slopes that are warmer and drier, in fact it’s the open areas on the east side that are dry now. A walk along the Historic Trail illustrates this as well – the path can change from dry dust to damp earth within a few inches, depending on the state of the forest.  If the whole forest is made as dry and dusty as these areas, by removing thousands of trees and nearly all the understory, the hazard could increase.

Incidentally, during the public meeting prior to that trail being built, Ray Moritz, who is UCSF’s hired arborist, also made a presentation as a fire ecologist and declared the fire hazard to be low.


With global warming, carbon storage is becoming an increasingly important issue. In fact, California has a specific law about it: AB32. UCSF also has a policy to reduce greenhouse gases.

Eucalyptus trees are excellent carbon sinks: They grow large and fast, the wood is dense, and they’re long-lived in wet conditions like Mount Sutro (around 400-500 years). The acacia understory makes the forest even better at sequestering carbon; acacia is a nitrogen-fixing tree, so both the eucalyptus and the acacia grow better together. They also store more carbon in the soil. Obviously, felling these trees will be a double whammy. They won’t be pulling more carbon out of the air. Instead, they’ll be chipped and mulched and decaying – and thus releasing carbon.

The DEIR makes several mistakes as it attempts to wiggle its way out of this dilemma: chopping down thousands of trees and leaving them to decay, vs the negative carbon impact. Here’s what it does:

First, it underestimates the carbon stored in the forest, and continued sequestration, in six ways:

  • It uses calculations based on six tiny cherry-picked plots (one-tenth of an acre each) that had fewer and smaller trees (averaging 175 trees per acre instead of 740 trees per acre for the whole forest!);
  • It calculates the tree-loss per acre based on the 175 trees/ acre and estimates 62 trees per acre will be left standing – so only 113 trees per acre are felled instead of 678
  • It excludes all trees under 5 inches in diameter;
  • It excludes understory vegetation because it’s only 5% of the total carbon storage;
  • It ignores soil storage (about 50% of a forest’s carbon storage) because it’s stable, even though the kind of activities planned for the Reserve would undoubtedly cause soil disturbance and release carbon; and
  • It uses a calculation based on 40% of the wood from felled trees being used for timber (like for furniture) – which of course means the carbon is stored for a much longer time than if the tree is in woodchips decaying on the ground. It reaches a conclusion that the short-term reduction in carbon storage would be 29% of the forest’s total storage – 11,286 tons (or 10,239 metric tons) of carbon dioxide.
  • It argues that mature trees have stopped sequestering carbon, while young trees would absorb carbon at higher rates. This is only true if trees stop growing; but there’s no evidence that these trees have. They are young for eucalyptus trees, which can live 400-500 years. In fact, since trees absorb carbon in proportion to the wood they add, the larger trees may be absorbing carbon at a lower rate than small trees, but actually taking in a larger amount.

We estimate their numbers are between 1/3 and 1/4 of the realistic amounts. The storage numbers are understated, and the removal numbers even more understated.

Second, it looks at a 30-year scenario (the projected life of the Plan), and divides the carbon storage loss by 30. We are not sure where the 30-year project life comes from.

Third, it argues that over 30 years, the carbon storage capacity will recover. The trees will be thinned the trees that remain will be healthier and grow larger, (despite the risk of wind throw killing remaining trees, and destruction be herbicides through the intergrafted root system).  Because the understory will be destroyed, they say, new trees will be able to grow (despite the thick layer of eucalyptus chip mulch and the plan to poison them or yank them to prevent them from growing.) It also claims reduction in tree mortality because there’ll be fewer pest infestations (which don’t actually exist now, but are speculated about).


The DEIR claims the forest is unhealthy, with overcrowding, dying trees, and an infestation of various insects including of snout beetles in some areas.

  • We wonder if UCSF had an entomologist look at the beetles, because snout beetles have mainly been seen in Southern California. In any case, they are readily controlled through release of a parasitic wasp. (This UC Davis publication has details.)
  • Except for major infestations, it’s normal for a forest to have insects – they’re part of the ecosystem, in fact, the foundation of it.
  • The DEIR states that the forest is crowded because eucalyptus is well-adapted to the site, it’s very prolific, and re-sprouts vigorously. This does not sound exactly like ill-health.
  • Some trees – especially the thin saplings that have not reached the canopy – are dead or dying. This is a natural process of self-thinning. It is better than the artificial thinning proposed in the Plan, because the forest varies greatly in terms of topography, wind, temperatures, and other growing conditions. The trees that flourish are best adapted for that particular space.
  • The DEIR mentions that new trees are not growing into the canopy. We cannot see why this is an issue, since the tree density is considered more than adequate already. We cannot see why felling 90%  of the trees per acre will improve the health of the forest.
  • The last detailed assessment of the forest was made in 1999, by Hort Science. Though the DEIR claims that two arborists hired subsequently reported a deterioration in conditions, they haven’t actually documented anything. Now, 13 years later, the DEIR still uses Hort’s estimate of tree density and tree numbers: 740 trees per acre, and 45,000 trees in total. This suggests that the deterioration is insignificant.
  • It also “spun” Hort’s report as follows: “the general condition of the Reserve’s trees is only fair to good, but the prevalent small trees throughout the forest are generally in worse condition than the large trees that dominate the forest canopy.” Here’s what Hort actually wrote: “In general, the trees that make up the canopy were in good condition. Trees in the understory had generally poor health.” Hort’s report sounds like a forest in the process of self-thinning. The trees that win the race for light flourish; the others survive or die depending on their specific circumstances.

If the forest is considered as a naturalized forest, it will be seen as healthy and self-regulating; it’s a population of trees in various conditions. Only if it’s considered a plantation – or still worse, an invasive species – does it make sense to intervene aggressively.


Trees and bushes fight pollution, especially small particulate matter that is bad for human lungs. They trap these particles on their leaves until they are rained down, thus removing them from the air, and absorb noxious gases. The DEIR does not address or quantify the loss of pollution control – which is likely to run to thousands of pounds of contaminants.


The assessment of wildlife is based on two (presumably daytime) site visits by the consultants, and guesswork based on the habitat conditions. There was no camera trapping, extended observation, or year-round observation to allow for seasonal changes.

  • Insects. The DEIR only speculates, and it’s wrong. “Native insect within the Reserve is expected to be low because of the dominance of non-native eucalyptus.” The insect fauna of the shady understory of the eucalyptus forest would include moths, flies, and beetles. (We have also observed butterflies.) Further, it’s not true that native insects use only native plants; many species adapt to non-native plants quite readily. It adds “two species of eucalyptus borer may occur… heavy infestation of these species may kill eucalyptus trees.” We are not clear why this section was even included, since it contains no actual information as to what species of insects actually occur (not “may” occur) in the forest.
  • Amphibians and reptiles. They didn’t see any on their two site visits. They’re guessing at what might live there, based on the habitat.
  • Birds. This section is the most descriptive, and they actually observed some birds, and actually recognizes its value to birds, both resident and migratory. It fails to describe the impact of removing 90% of the trees and understory on birdlife. The olive-sided flycatcher is a species of special concern that may nest in the forest. It’s a forest species, and was heard in the East Bowl, the area of Demonstration Project #4 – which, spaced at 12-15 trees per acre, will no longer be forest once the Plan is implemented. It also needs snags – dead trees – which will be the first to go when the thinning starts.
  • Mammals. They only saw a squirrel, but think the forest could house oppossum, deer mice, raccoons, skunks – and black-tailed deer. No, we have no deer. They also guess at what bats might use the forest.

On page 4.3-20, it claims the forest is not a wildlife corridor because it’s surrounded by urban development. In fact, if viewed from an animal’s viewpoint, it is part of a system that connects to a broader area –  Glen Canyon, Twin Peaks, Laguna Honda Reservoir, and Golden Gate Park. It says “the relatively limited amount of vegetation removal… would not interfere…” We’re not sure it defines the loss of 90% of the understory (which is what matters most to non-flying critters) as “relatively limited.”

The mitigation for birds nesting is also interesting – they’re going to try to work outside the nesting season, and retain a few snags for woodpeckers. If they’re working between Dec 15 and August 15, they’ll call in a biologist to do a nest survey and cordon off nests. But the DEIR ignores the effect of the reduced habitat for birds the following season, which certainly is not “less than significant.”


We think there are other flaws and lacunae in the DEIR, but we are now closing in on the public comments deadline: 19 March 2013. Please take a few minutes to send in your comments!

  • Submit a written public comment by 5 PM, March 19, 2013 to UCSF Environmental Coordinator Diane Wong at EIR@planning.ucsf.edu
  • Or, by mail to UCSF Campus Planning, Box 0286, San Francisco, CA 94143-0286.
  • Include your full name and address.
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12 Responses to Flaws in UCSF’s Sutro DEIR: Public Comments Due 19th March 2013

  1. Meg Rosenfeld says:

    The information available from UCSF is woefully inadequate regarding what they actually DO plan to do (it includes only what they do not, as in “It’s not true that we’re going to cut down 30,000 trees.” So how many are they going to cut: maybe a lot more?!) Given such sketchy information, plus ample evidence regarding how deleterious cutting the forest would be, I stand opposed to UCSF’s plan.

  2. Velma Kingsbury says:

    Why are we always fighting to keep the status quo? Why can’t things be left alone? Have lived in SF my whole long life and almost all I remember is fine the way it stands and will probably be fine for years to come. My children hiked in Sutro Forest… my brother lived next to it near the top of Stanyan. Leave it alone. What I do remember about the 70s and 80s is people breaking into the cages in back of UCSF to rescue the dogs who were being experimented on.

    Velma Kingsbury

  3. robin mac quarrie says:

    why????…just cut old,dead trees…if you do what you are planning the city will ”never” be the same,the kids will ”lose”..shame on you all!!..robin

  4. George H. says:

    UCSF practices allopathic medicine (cut, burn, poison) on people, so why should we expect them to do anything different on trees.

    [Webmaster: Whatever your views of allopathic medicine – the patients are self-selected. The trees, no so much.]

  5. Annamaria Manodori, PhD says:

    I don’t understand why UCSF, a university and hospital, is planning to destroy a forest. What does a medical school have to do with forestry? Did the proponents of this absurd and apparently unpopular plan read the rebutal by Dr Joseph Mascaro to their Draft Environmental Impact Report? Dr Mascaro’s detailed study of this report demonstrates an obvious conclusion that the University knows very little about forests and their benefits to wildlife and humanity. In addition, Dr Mascaro indicates that the draft is riddled with flaws, inconsistencies, and fabrications. Where is the University’s response to his points? Why is there not even a discussion?

    The biggest impact that the University’s proposal to cut down 90% of Mount Sutro forest would have is in increased global warming due to reduced carbon sequestration. Trees are the only living beings on earth that actually slow down the destruction caused by global warming by absorbing some of the carbon that, through our activities, is released into the atmosphere. Every tree destroyed results in more carbon in the atmosphere and faster global warming. The faster the warming, the faster the seas rise and the land disappears. The undeniable result of that will be human and animal crowding, land and water wars, increased starvation, disease and death, and intensifying weather related devastation. I would think that any intelligent person would understand the absolutely URGENT need to preserve every single tree (unless hazardous) any- and everywhere. We need to think about the results of this impending and irrefutable devastation, if we don’t do anything to stop it. That should be our number one priority, not cutting down trees!

    I would like to know what is planned to be done with the wood? Has a logging company been selected by competitive bidding to buy the wood? Are there University officials related to the owners of the logging company? Are these same administrators engaged in any way in the plan to cut the Mount Sutro trees? Is there thorough transparency? Has this been disclosed to the City, State, and Union? As the loss of the prime and important function of the trees, carbon sequestration and release of oxygen, affects all of us, the University’s plan should be made public in ALL of its details.

    [Webmaster: We think the most difficult question to answer is, Why? UCSF’s arguments have been unconvincing, but since they come primarily from the “Community Relations” team, we have no way of understanding who the decision makers are or why they plan this. It may be that it is a project started in 1999 that took on a life of its own, despite a clear change in the understanding of the forest, AB 32 (carbon sequestration), and the University’s own Green priorities. At that time, it appeared to be about Native Plant conversions – which still exist in the plans for Demonstration Projects #3 & #4. But we cannot understand what interest a medical institution has in Native Plant ideology.]

  6. Kerry Bostrom says:

    This area has been a treasure my entire (long) life. Please let it stand as it is. Something that has existed for over 100 years in San Francisco truly must be considered “Native.” I treasure the magical trails, the sounds of birds, the endless discoveries of new places to look. I worry about where the birds will go. There are surely hundreds and hundreds of animals living in the forest. I worry about the the even greater winds, which are already pretty strong. Most of the time this area is covered in fog, dripping moisture, reducing the fire danger greatly. Please, please do not take away this treasure.

    • wally mcsorley says:

      I have a home on Warren Dr. for the past 20 years and the man who delivered our mail, when we first moved in, was very involved with the Audubon Society. He told me that up on the top of Sutro Forest there were some endangered birds … not sure but I believe Condors; nesting year after year.
      His name was Mike and he retired around 1998.
      Endangered birds will shut this absurd project down faster than all our pleas for rational thinking!
      I sent a plea for help to the Audubon Society…but a call to the right person would be much more helpful.
      The last time I saw a neighbor decide (on Warren Dr.) to get rid of the “terrible” non native trees i.e.Pine and Eucalyptus, he caused his car to be covered in mud up to the windows on the passenger side.
      Yes, he cut down the trees, the soil dried out, his puny plantings could not survive without watering, and the end result was a huge mudslide in the winter.
      Blue plastic tarps covered the area for the next two years; after which a hideous retaining wall had to be built to keep the hill from sliding down into the street.
      Terrific! any questions please do not hesitate to email me.
      May good sense prevail,
      wally mcsorley.

      [Webmaster: We wish there were condors, but we don’t believe any have been seen in San Francisco. They’re so endangered that the government captured the last 22 wild birds in 1987 and started a captive breeding program. They’re being reintroduced near Big Sur. We think Great Horned Owls nest (or tried to nest) in Sutro Forest, and maybe red-tailed hawks. We do recall the landslide and the blue tarps on the hillside. Of course there’s a substantial risk for Christopher and Crestmont, but it’s been downplayed and minimized.]

  7. wally mcsorley says:

    A habitat w. owls, hawks, some condor sightings, black birds, and many more who will be endangered by the greed of UCSF medical center. This habitat is on Mt. Sutro in San Francisco and is about to be destroyed by the University. Obviously, if you can wreck it; then you can get permits to build on the last pristine habitat in San Francisco.
    Please see:

    The fact that the trees are not native to CA does not keep them from providing a home for thousands of birds…as well as protecting the last of the raccoons, possums, skunks, and other small animals that inhabit the area. They are the original settlers.
    Probably many children’s only chance to see these critters outside a zoo.
    Please Help!
    Respectfully submitted,
    wally mcsorley, local resident.

    [Webmaster: Thanks for caring about this forest, as do we. UCSF has said they intend to maintain it as an Open Space – only without thousands of its trees.]

  8. gina hall says:

    Please Leave the Sutro Cloud Forest alone and let nature take it’s course. This is Not a fire hazard. That is a fear tactic. Many people fell for the ‘weapons of mass destruction’ scam as well.

  9. Sharon Michalske says:

    These plans to deforest San Francisco are based on one faulty concept. And that is that Eucalyptus trees are “invasive” and not indigenous. The Eucalyptus trees have been here over 100 years and are thriving. Does that make them invasive? How long does something have to grow here before it is indigenous? Most of the people here weren’t born here. Should we get rid of them too? It has been my experience that the wealthy backers of such groups who propose to “correct” nature have enough clout in this city to push stupid plans through no matter how ridiculous. The public is given an opportunity to comment, but they fall on deaf ears. The plans usually go through anyway. We’ve been fighting stupid plans for Fort Funston for over ten years. No matter how many times we point our incorrect logic or complete misstatements, the plans go through. Hopefully, our Mayor or someone at the top will show some spine, not be corrupt and stop these plans to cut down trees that are perfectly healthy, have been here for years and provide us such beauty.

  10. Gillian Greensite says:

    Environmental Coordinator Diane Wong.

    Dear Ms. Wong:
    I have read the DEIR for the proposed project at Mount Sutro and would like to have the following comments included for consideration:

    I live in Santa Cruz, CA and am a 30 year employee of the UC system. UC’s professed role as a steward of the natural environment under its control is contradicted by this project. There appear to be no evidence-based reasons for the removal of so many trees in Mount Sutro. The DEIR contains errors of fact and misleading statements. Some examples are:

    1. The before and after pictures are examples from elsewhere with no trees removed. Only underbrush. This needs correcting for the EIR.

    2. The statement that the canopy is “sparse and unhealthy” is inaccurate and shows ignorance of the characteristics of this type of blue gum forest. I grew up in Australia and can confirm that this is what a healthy young blue gum forest looks like. Please correct this for the EIR.

    3. The fire hazard described in the DEIR is exaggerated and not supported by fact. Experts have already written to you supporting this statement. Please amend the EIR to more accurately summarize the role of blue gums in the Oakland fire and fire potential in general. It is well-documented that thinning a forest can increase the fire potential. Please have the EIR reflect this knowledge.

    4. The EIR should more accurately convey the impact of such thinning on the variety of wild-life that depend on the forest in its current state. It is a well-known fact, cited by expert birders such as Dr. Todd Newberry ( page 51 “The Ardent Birder” 2005) that native birds love non-native trees such as found at the UCSC Arboretum. This would also apply to Mount Sutro.

    In sum, I look forward to seeing an EIR that removes the speculation, opinion and mis-statement of fact contained in the DEIR.

    Thank you in advance for responding to my comments on the DEIR.

    Gillian Greensite

    ( I did add my address)

  11. Cynthia Chang says:

    Leave Sutro Forest alone…stop cutting down trees. I stand for a world that works for everyone.

Comments are closed.