This is a revision of an article that was published on May 5, 2013. In our haste to inform our readers of these projects during the public comment period, we published before we had read the entire Environmental Impact Study. We are forced to revise our estimates based on further reading of the document. We apologize for the confusion and thank you for your patience.

On May 29, 2013, we found an error in the number of trees that will be removed at Frowning Ridge. We show our corrections so as not to mislead our readers. Again, our apologies.

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The Federal Emergency Management Agency (FEMA) has been considering grant applications for “fire hazard mitigation” in the East Bay since 2005, when the first of these applications was submitted. After years of debate about whether or not the projects achieve the stated purpose and at what cost to the taxpayers and the environment, FEMA finally agreed to resolve the controversial issues by mandating an environmental impact review, which began in 2010. Although FEMA paid for the environmental review, the grant applicants conducted it and it represents their opinions of their projects.

These are the projects for which the Million Trees blog was created and for which it was named. Our opinion of these projects is unchanged by the environmental impact review. These projects will not achieve their stated objectives. Instead they will damage the environment and endanger the public.

The Draft Environmental Impact Statement (DEIS) for these projects was published by FEMA on April 25, 2013. It is available here. This is a brief description of the projects, our initial assessment of the DEIS, and information about how you can participate in the decision-making process which will ultimately determine the fate of these projects.

Description of the projects in the East Bay

Three different owners of public land have applied for these grants: University of California at Berkeley (UCB), City of Oakland, and East Bay Regional Park District (EBRPD). The projects of UCB and Oakland are similar and they are different from the projects of EBRPD, so we will describe them separately. These are the locations of the projects of UCB and Oakland, their acreage, and the estimated number of trees that will be removed by these projects:

Project Area Project Acreage Estimated Tree Removals* UCB Strawberry Canyon 56.3 22,000 Claremont 42.8 Frowning Ridge (in Oakland) 185.2 38,000 32,000 Sub-Total 284.3 60,000 54,000 Oakland North Hills Skyline 68.3 Caldecott Tunnel 53.6 Sub-Total 121.9 25,735 23,161 TOTAL 406.2 85,735 77,161

*UCB estimated tree removals are provided by the DEIS; Oakland estimated tree removals are extrapolated assuming the same number of trees per acre ( 60,000 54,000 ÷ 284.3 = 211 190 trees per acre X 121.9 acres = 25,735 23,161 trees removed by the projects of the City of Oakland)

UCB and Oakland plan to remove all non-native trees (eucalyptus, Monterey pine, acacia, etc.) and vegetation from the project area. All non-native trees up to approximately 24 inches in diameter at breast height (DBH) will be cut into wood chips and scattered on the ground of the project area. They estimate that 20% of the project area will be covered with wood chips to a depth of 24 inches. The DEIS estimates that the wood chips will take from 5 to 10 years to decompose. Larger trees will be cut up and scattered on the site.

Although UCB and Oakland do not intend to plant the project areas (unless erosion subsequent to tree removals demands seeding of native grasses and herbaceous plants), they predict that the project area will eventually become native grassland, scrub, and forest of coast live oak, California bay laurel, big-leaf maple, California buckeye, and California hazelnut. They predict that this conversion from non-native to native vegetation will be accomplished by “recruitment” from areas where these plants exist, into the areas where non-native plants and trees will be removed.

The stumps of eucalypts and acacia will be sprayed with an herbicide (Garlon with the active ingredient triclopyr) soon after the trees are cut down to prevent resprouting. An estimated 1 – 2 ounces of formulated herbicide will be required for each stump. Based on an experiment conducted by East Bay Regional Park District, an estimated 5% of the trees will require retreatment of subsequent resprouts. They are therefore predicting that between 703 633 and 1,407 1,266 gallons of herbicide will be required to prevent resprouting if only 5% of the stumps require retreatment as they claim. Monterey pines will not require herbicide treatment which reduces this estimate proportionately, although we are not provided with enough information to make this calculation. Herbicide (Roundup with active ingredient glyphosate) will also be sprayed to control non-native vegetation, but no estimates of quantities required for that purpose are provided by the DEIS.

The fire hazard mitigation projects of the East Bay Regional Park District were described in detail in its “Wildfire Hazard Reduction and Resource Management Plan” of 2009. EBRPD has applied for FEMA funding for about one-third of the “recommended treatment areas” in that plan. The FEMA DEIS considers all recommended treatment areas on EBRPD property, including those for which FEMA funding has not been requested. The recommended treatment areas for which FEMA funding has not been requested are called “Connected Action Acres.” The “Connected Action Acres” have undergone environmental review under California law (CEQA) and are therefore approved for implementation, which has already begun.

Project Area Project Acres Connected Action Acres Total Acres Estimated Tree Removals* EBRPD Sobrante Ridge 4.1 0 Wildcat Canyon 65.6 46.6 Tilden Park 132 194.2 Claremont Canyon 35.3 130.4 Sibley Volcanic 47.5 118.4 Huckleberry 17.8 .3 Redwood Park 58.4 92.8 Leona Canyon 4.6 0 Anthony Chabot 200 478.2 Lake Chabot 4.8 0 Miller-Knox 22.2 0 TOTAL 592.3 1,060.7 1,653 400,602 409,176

*Estimated Tree Removals: Neither the DEIS nor EBRPD’s “Wildfire Plan” provides an estimate of the number of trees they plan to destroy. Furthermore their plans for tree removals are complex and variable. All non-native trees (eucalypts, Monterey pines, acacia) will be removed in some recommended treatment areas, but in most they will be thinned to spacing of 25 to 30 feet. The final Environmental Impact Report for the “Wildfire Plan” provides an estimate of the existing tree density of existing eucalypts on EBRPD property (page 392). Acres of eucalypts in the entire project area are provided by the DEIS (page 4.2-6). Our estimate of tree removals is based on those figures (1).

This estimate does not include the Monterey pines and acacia that will be removed by EBRPD, for which inadequate information is available to provide an estimate.

EBPRD plans to cut the trees into wood chips which will be scattered to cover 20% of the project to maximum depth of 4-6 inches. The remainder of the wood will be burned in piles. Other non-native vegetation will be destroyed with herbicides and/or prescribed burns. These prescribed burns will not be funded by FEMA.

EBRPD’s plans to convert the project area to native vegetation are similar to the plans of both UCB and Oakland. EBRPD also does not plan to plant project areas with native vegetation. EBRPD also plans to use herbicides on the stumps of eucalypts and acacia which we estimate will require a mind-boggling 3,286 3,356 to 6,572 6,713 gallons of herbicide.

Million Trees’ assessment of these projects

We have surely exhausted your patience with the mind-numbing detail needed to describe these projects accurately. Therefore, we will provide only a brief outline of our assessment of these projects:

* These projects are more likely to increase the risk of wildfires than to reduce that risk.

By distributing tons of dead wood onto bare ground

By eliminating shade and fog drip which moistens the forest floor, making ignition more likely

By destroying the windbreak that is a barrier to wind driven fires typical of wildfires in California

By expanding the oak-bay woodland being killed by Sudden Oak Death, thereby adding more dead wood

* These projects will damage the environment by releasing hundreds of thousands of tons of carbon dioxide into the atmosphere from the destroyed trees, thereby contributing to climate change.

* These projects will endanger the public by dousing our public lands with thousands of gallons of toxic herbicides.

* Erosion is likely on steep slopes when the trees are destroyed and their roots are killed with herbicides.

* Non-native vegetation such as broom, thistle, and hemlock are more likely occupants of the unshaded, bared ground than native vegetation which will not be planted by these projects.

* Prescribed burns will pollute the air and contribute to the risk of wildfire, endangering lives and property.

* These projects are an inappropriate use of the limited resources of the Federal Emergency Management Agency which are for the expressed purpose of restoring communities destroyed by disasters such as floods and other catastrophic events and preparing communities for anticipated catastrophic events. Most of the proposed projects in the East Bay are miles away from any residences.

Update: Please visit THIS post for the current status of these projects. In summary: East Bay Regional Park District is implementing its original plans. City of Oakland is developing a new “Vegetation Management Plan.” UC Berkeley is suing to re-instate its FEMA grant funding so that it can implement its original plans.

How to participate in this decision-making process

The Hills Conservation Network has created a petition to oppose these projects. It is available HERE.

You can also participate in this decision. FEMA will host three public meetings in May 2013:

Tuesday, May 14, 2013, 2:00 p.m. – 4:00 p.m., Richard C. Trudeau Center, 11500 Skyline Boulevard Oakland, CA 94619

Tuesday, May 14, 2013, 6:00 p.m. – 8:00 p.m., Richard C. Trudeau Center, 11500 Skyline Boulevard Oakland, CA 94619

Saturday, May 18, 2013, 10:00 a.m. – 12:00 p.m., Claremont Middle School, 5750 College Avenue Oakland, CA 94618

Comments on this document must be submitted by June 17, 2013. You may submit written comments in several ways:

Via the project website: http://ebheis.cdmims.com At the public meetings listed above By email: EBH-EIS-FEMA-RIX@fema.dhs.gov By mail: P.O. Box 72379, Oakland, CA 94612-8579 By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars. So, please tell the people who work for you what you think of these projects.

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(1) Calculation of estimated tree removals by East Bay Regional Park District, Update: We understand the weakness of this estimate. Unfortunately, the DEIS does not provide sufficient information to improve its accuracy. Again, our apologies.

Existing average density of eucalypts 650 trees per acre minus Planned average density of eucalypts 60 trees per acre equals Number of eucalypts removed 590 trees per acre times Total acres of eucalypts in project areas 824.3 equals Total number of eucalypts removed 486,337 minus Trees removed by UCB & Oakland 85,735 77,161 equals Eucalypts removed by EBRPD 400,602 409,176