NAP RAP - TELLING IT LIKE IT IS
Home | FAQs | Dirty Little Secrets | The Rap | Propaganda Patrol | Yomi the Money! | Your Park | NAP Map | Wayne's World | Comment
The Rap: What the experts have to say...
scholar.gif

October 6, 2011

Mr. Bill Wycko

San Francisco Planning Department

Re: DRAFT EIR, NATURAL AREAS PROGRAM

Dear Mr. Wycko:

Consistent with the policy of the University of California, I wish to state at the outset that the opinions stated in this letter are my own and should not be construed as being those of the Regents, the University of California, or any administrative entity thereof. My affiliation is presented for purposes of identification only. However, my academic qualifications are relevant to what I am about to say. I am a professional ecologist (B.A. University of Pennsylvania, Ph.D. Cornell University) and have been on the faculty of U.C. Davis since 1971, where I have taught General Ecology, Evolutionary Ecology, Community Ecology, Philosophy of Biology, Biogeography, Tropical Ecology, Paleoecology, Global Change, Chemical Ecology, and Principles of Systematics. I have trained some 15 Ph.D.s, many of whom are now tenured faculty at institutions including the University of Massachusetts, University of Tennessee, University of Nevada-Reno, Texas State University, and Long Beach State University, and some of whom are now in government agencies or in private consulting or industry. I am an or the author of some 350 scientific publications and reviews. The point is that I do have the bona fides to say what I am about to say.

At a time when public funds are exceedingly scarce and strict prioritization is mandatory, I am frankly appalled that San Francisco is considering major expenditures directed toward so-called “restoration ecology.” “Restoration ecology” is a euphemism for a kind of gardening informed by an almost cultish veneration of the “native” and abhorrence of the naturalized, which is commonly characterized as “invasive.” Let me make this clear: neither “restoration” nor conservation can be mandated by science—only informed by it. The decision of what actions to take may be motivated by many things, including politics, esthetics, economics and even religion, but it cannot be science-driven.

In the case of “restoration ecology,” the goal is the creation of a simulacrum of what is believed to have been present at some (essentially arbitrary) point in the past. I say a simulacrum, because almost always there are no studies of what was actually there from a functional standpoint; usually there are no studies at all beyond the merely (and superficially) descriptive. Whatever the reason for desiring to create such a simulacrum, it must be recognized that it is just as much a garden as any home rock garden and will almost never be capable of being self-sustaining without constant maintenance; it is not going to be a “natural,” self-regulating ecosystem. The reason for that is that the ground rules today are not those that obtained when the prototype is thought to have existed. The context has changed; the climate has changed; the pool of potential colonizing species has changed, often drastically. Attempts to “restore” prairie in the upper Midwest in the face of European Blackthorn invasion have proven Sisyphean. And they are the norm, not the exception.

The creation of small, easily managed, and educational simulacra of presumed pre-European vegetation on San Francisco public lands is a thoroughly worthwhile and, to me, desirable project. Wholesale habitat conversion is not.

A significant reaction against the excesses of the “native plant movement” is setting up within the profession of ecology, and there has been a recent spate of articles arguing that hostility to “invasives” has gone too far—that many exotic species are providing valuable ecological services and that, as in cases I have studied and published on, in the altered context of our so-called “Anthropocene Epoch” such services are not merely valuable but essential. This is a letter, not a monograph, but I would be glad to expand on this point if asked to do so.

I am an evolutionary ecologist, housed in a Department of Evolution and Ecology. The two should be joined at the proverbial hip. Existing ecological communities are freeze-frames from a very long movie. They have not existed for eternity, and many have existed only a few thousand years. There is nothing intrinsically sacred about interspecific associations. Ecological change is the norm, not the exception. Species and communities come and go. The ideology (or is it faith?) that informs “restoration ecology” basically seeks to deny evolution and prohibit change. But change will happen in any case, and it is foolish to squander scarce resources in pursuit of what are ideological, not scientific, goals with no practical benefit to anyone and only psychological “benefits” to their adherents.

If that were the only argument, perhaps it could be rebutted effectively. But the proposed wholesale habitat conversion advocated here does serious harm, both locally (in terms of community enjoyment of public resources) and globally (in terms of carbon balance-urban forests sequester lots of carbon; artificial grasslands do not). At both levels, wholesale tree removal, except for reasons of public safety, is sheer folly. Aging, decrepit, unstable Monterey Pines and Monterey Cypresses are unquestionably a potential hazard. Removing them for that reason is a very different matter from removing them to actualize someone’s dream of a pristine San Francisco (that probably never existed).

Sociologists and social psychologists talk about the “idealization of the underclass,” the “noble savage” concept, and other terms referring to the guilt-driven self-hatred that infects many members of society. Feeling the moral onus of consumption and luxury, people idolize that which they conceive as pure and untainted. That may be a helpful personal catharsis. It is not a basis for public policy.

Many years ago I co-hosted John Harper, a distinguished British plant ecologist, on his visit to Davis. We took him on a field trip up I-80. On the way up several students began apologizing for the extent to which the Valley and foothill landscapes were dominated by naturalized exotic weeds, mainly Mediterranean annual grasses. Finally Harper couldn’t take it any more. “Why do you insist on treating this as a calamity, rather than a vast evolutionary opportunity?” he asked. Those of us who know the detailed history of vegetation for the past few million years—particularly since the end of Pleistocene glaciation—understand this. “Restoration ecology” is plowing the sea.

Get real.

Sincerely,

Arthur M. Shapiro

Distinguished Professor of Evolution and Ecology

UNIVERSITY OF CALIFORNIA, DAVIS

Division of Biological Sciences
Section of Evolution and Ecology
Fax (530) 752-1449 

7 May 2002

The Hon. Gavin Newsom
Chairman, Neighborhood Services Committee
San Francisco County Broad of Supervisors
City Hall, 1 Carlton B. Goodlett Place
San Francisco, CA 94102

Dear Supervisor Newsom:

Re: Natural Areas Program (Rec. & Parks)

Because of both personal friendship and professional contacts in The City, I have been following the controversy over native plants and natural areas management and the removal of exotic tree species from public lands in San Francisco.  I am a professional ecologist and have been teaching at U.C. Davis for over 30 years.  During that time I have trained many professional environmental scientists and consultants.  My former students are scattered over a variety of government agencies at several levels, firms in the private sector, and colleges and universities form Massachusetts to Texas to Florida, as well as California.  I began teaching a course on the community concept in ecology at UCD in 1972, which has always contained a section on introduced, exotic and naturalized species in community context, with examples drawn form California - long before it became fashionable.  I was on the phthises committee of James Carlton, the foremost US authority on weedy marine invertebrates.  I have led California Native Plant Society and Sierra Club field trips in the Sierra Nevada and Central Valley for many years and do frequent presentation on butterfly gardening.  I am telling you all this to try to establish credibility, because what I am about to say will be controversial - to say the least.

There is a widespread perception that the Natural Areas Program is spinning out of control: that it has overreached far beyond its goal of preserving the remnants of natural vegetation still extant in SF parklands and is now engaged in a compaign of restoration ecology in which overwhelmingly human-modified or - created landscapes are being removed to allow for the recreation of natural ones, or - more accurately - a simulacrum thereof.

The management of public open space necessarily involves a variety of tradeoffs.  In a spatially highly constrained area like San Francisco, public open space is precious, and many members of the public are very strongly committed to its well - being.  My emeritus colleague Seymour Gold at Davis, as well as other researchers, long ago demonstrate that urban open-spaces users have distinct psychological needs and preferences in landscapes - and that mature trees in specific spatial configurations tend to dominate those preferences.  The anthropogenic landscapes we associate with SF parklands are in fact very close to the ideal.  It is not surprising that they are so loved by their users.

As a teacher of conservation biology, I know it is important.  I also know that it can be carried to extremes. In an urban setting - and San Francisco is such a setting! - it has its place, but it cannot be the dominant value in open-space management.  It has to be integrated into a broader context that will be not only politically palatable but in fact pleasing to the public.  With a graduate student, I have recently conducted and published a study showing that regulatory styles perceived as arbitrary and authoritarian can and have pushed groups of people normally friendly to environmentalism and conservation - in our study, butterfly collectors - into anti-government positions within the so-called "Wise Use" movement.  I see the same process at work in San Francisco, where a highly educated, sophisticated, politically liberal urban population is being needlessly turned against what it perceives as "environmentalism" run amok.  Sierra Club members and butterfly gardeners are beginning to talk like the ranchers I interact with in Siskiyou and Lassen Counties.

The Natural Areas Program has its place, and it needs to be kept in that place.  It cannot be allowed to trump the clear preferences of the vast majority of parkland users in San Francisco.  The hatred of "exotic" trees, some of which are California natives anyway, is not only ideological but sometimes verges on the pathological, and has strong overtones of xenophobia and racism (look at the anti-"exotic" rhetoric yourself!).  Senile, decadent, hazardous trees are numerous and pose a public-safety and fire problem that needs to be addressed.  Healthy trees in pleasing, integrated landscapes are another story.  "Native" nature can be preserved and augmented without damaging the peace of mind of San Franciscans.  And should be.

Sincerely,


 Arthur M. Shapiro
 Professor of Evolution, Ecology and Entomology
 Center for Population Biology, UC Davis

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 introduced species.

 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.

 Recommendations 

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.

 Sincerely,

 Joan Roughgarden
 PROSAC Representative

Supervisoral District 6

San Francisco CA

Pine tree