Sept. 1, 2002
Dear Fellow Members of PROSAC,
I'm sorry to be out of town
on Tuesday and not able to participate personally in the discussion of the Natural Areas Program (NAP) scheduled on the agenda
for Sept. 3. Perhaps I can be of help by offering some comments in this note.
As your representative to
the Green Ribbon panel, I have attended the two meetings since I was appointed, have read through the entire draft plan, and
have participated in the process. Several conclusions and recommendations can be drawn at this point.
Content of Management Plan
The management plan advances
a highly interventionist view of resource management that is not viable ecologically, economically, or culturally.
The plan was developed by
a consulting firm, EIP Associates, specializing in environmental impact reports.
a. About half of the specific recommendations
have some variant of the words, kill, clear, cut, or control. To illustrate, consider Lake Merced, chosen here simply because
Lake Merced is the first of the parks mentioned in the report. Recommendations for the other parks follow in the same vein.
On p. 6.1-12--6.1-20, the phrases, “remove eucalyptus, pine, acacia... remove cape ivy ice plant, English ivy, ehrharta,
Bermuda buttercup, pampas grass, and sheep sorrel... clear pest species, monitor annually for new invasions... create open
grassland through vegetation management and control of invasive plants... trap and remove non-native turtle species... remove
all bullfrogs... stock with largemouth bass and catfish... signs, fences and increased enforcement to discourage free-running
dogs in unauthorized areas” illustrate the flavor of the specific recommendations made for each park. Yet, in dry parks,
water fountains are planned to benefit some favored species.
b. General recommendations that apply to all
parks include, “areas of native-dominated vegetation shall be weeded on a routine basis to preserve the integrity of
the native plant species and reduce the infestation of non-native species (p. 5-2)... as stands age small groups of trees
could be removed within the forest and replanted with the appropriate native species (p. 5-2)... control feral cat populations
through a trapping and removal program (p. 5-6).” Furthermore, the “vegetation management decision process”
includes two decision points that lead to the use of herbicides: “Is Plant Safe to Handle? No->Is Animal Control
Feasible and Efficient? No->Apply Herbicides” and “Is Hand Removal Feasible and Efficient? No->Apply Herbicides”
(p. 4-13). The herbicide used is Roundup Pro (p. 4.4).
c. These recommendations are not ecologically
viable. Introduced species cannot be eliminated by weeding because of dispersal and presence in the soil's seed bank, bullfrogs
cannot be eliminated by volunteers with pitchforks tromping through the marsh at night spearing frogs when thousands of tadpoles
swim in the waters (also, usually only a subset of the males call at night, and the non-calling males and females are not
locatable), feral cats cannot be trapped out against a stream of influx from neighboring sources, herbicide use is anathema
to natural ecosystem function, and so forth. Furthermore, the entire suite of recommendations is not gauged against an index
of the conservation potential of each site, as would be revealed in total species-area and nested-subset species area graphs
and tables. I have called for this information, but these elementary statistics used in conservation and restoration ecology
have not been provided. All in all, the recommendations are ad hoc. The recommendations are simply listed without justification,
or reference to any justifying literature.
d. The recommendations are not economically viable.
The ecosystem envisioned is a human subsidized system, not a self-sustaining ecosystem. The envisioned ecosystem amounts to
a grand exercise in horticulture, not to the restoration of a natural ecosystem.
e. Of particular importance to PROSAC, the continuing
expenses these recommendations require would apparently be debited from the capital improvement account, and be tantamount
to coding maintenance expense as capital expense.
f. The recommendations are not culturally viable.
As many have noted, the language used for introduced species is racist and sexist. Introduced plants and animals are not people
of course, and cannot object to how they are described. Still, the language in the management plan is insensitive, inviting
a carry-over to human affairs, and opening the possibility of naturalizing racist rhetoric in the name of science. In fact,
ecology does not privilege the native over the introduced. Every species is native somewhere. The N in NAP has been appropriated
to mean native. The goal of the NAP should be to create natural self-sustaining ecosystems that serve the citizens of San
Francisco. The NAP should include native species to conserve our biological heritage, as a “natural museum,” just
as human museums conserve and exhibit our maritime traditions. Even maritime buffs don't suggest that North Beach be restored
to a fishing village. Our moral obligation to prevent the extinction of native species does not license the persecution of
Public Process for
Review of Management Plan
The process being implemented
for review of the management plan is not viable politically.
a. No protocol is available to ensure that comments
raised by the Green Ribbon Panel are incorporated into the management plan. Although written comments about each of the specific
recommendations have been solicited from panel members, EIP has stated publicly that they will make their own subjective and
private evaluation about which comments to take into account in any revisions. This absence of any guarantee that comments
will be considered is a disincentive to offering feedback, and has provoked frustration and anger among parties who wish to
influence the result.
b. The Green Ribbon Panel was selected on the
basis of political advocacy, not on technical credentials, so that discussion of the technical merits of the plan is immediately
interpreted in an advocacy framework. With public attention and opposition building to the NAP, a circle-the-wagons atmosphere
has formed, with any criticism of the plan seen as the onslaught of barbarians. This polarization has subverted the capability
of the Green Ribbon Panel to offer substantive feedback.
c. By keeping the public at arms length, the
consultants doomed the management plan to controversy from the start. The modern approach to ecosystem management uses the
concept of ecosystem services, and asks how an ecosystem should be configured to deliver the services people desire. By knowing
what people want from their NAP's to begin with, a plan that melds these needs, including the need for conservation, can be
achieved. Even more recently, ecosystem management is being cast in an economic framework using the approach of ecological
economics to help sort the allocation of ecosystem resources among competing demands.
A two-tier process for developing
a NAP management plan should be substituted for the current process, and EIP Associates should be terminated as the contractor
responsible for developing the plan.
a. The first tier of review should be a small
working group of six people, four of whom are appointed for technical expertise and two of whom represent community constituencies.
The group's meetings should be public, but focused on a technical review of the management plan. This body should be charged
with making recommendations for revisions to the plan, and the contractor should be required to accept the recommendations,
or to state publicly why not. This group should meet for six months, and interact with the tier-2 group below.
b. The second tier should be a larger review
body of twelve people, eight of whom represent community constituencies, and four selected for technical expertise. This group
should be charged with evaluating the extent to which the community's needs are being served by the management plan, to suggest
revisions, and ultimately, to endorse the plan before release for general public comment. This group should meet for four
months, overlapping the last four months of the tier-1 group, and providing opportunity for interaction.
c. The reports of both tiers of review should
be referred to the Recreation and Park Commission or Board of Supervisors, for forwarding to the Department, to ensure that
the recommendations are taken seriously.
d. EIP should be terminated because:
1. EIP has not developed a credible resource management plan for the NAP.
2. EIP has not
effectively facilitated a public review of the management plan for the NAP.
3. EIP does not
have the personnel to develop a management plan for the NAP. EIP's strengths lie in hydrology and geographic information systems
(GIS). Yet, the controversial aspects of the NAP pertain primarily to biological restoration and conservation aspects of the
parks, not to geologic and geographic issues. Instead, a different firm should be retained that can build on the foundation
of GIS maps and the species data-base that EIP has generated.
Supervisoral District 6