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.)
The 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.
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.)]
EXAGGERATED FIRE HAZARD – AND HIGH-RISK “SOLUTION”
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.
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).
HEALTH OF THE FOREST
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.”
TIME TO SEND IN PUBLIC COMMENTS
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.