Public Comment

This paper has been prepared by the San Francisco Bay Chapter of the Sierra Club (Sierra Club), East Bay Chapter of the California Native Plant Society (CNPS) and the Golden Gate Audubon Society (Audubon) to document our point of view about how best to meet the twin goals of managing the urban wildland interface to enhance and preserve habitat for native plants and wildlife species while reducing the threat of catastrophic fire at the interface. 

This topic is of timely importance because of the pending release of the environmental review documents being prepared by the East Bay Regional Park District, FEMA grants for vegetation management, and other agency documents that are to follow. This paper contains the major guiding principles, which are further elaborated on in the attached background paper and appendix. 

It is important to note at the outset that we embrace an Integrated Fire Management (IFM) approach to this issue. An IFM approach addresses the total scope of fire hazard both from problems with the human infrastructure and those from wildland vegetation. 

We apply this theme at both the landscape level as well as at individual sites, whether they are homes at the interface or public parks and open space. While the human infrastructure including roads, water supply, defensible neighborhoods, etc., is expensive to maintain or improve, only well-planned infrastructure can assure safety from catastrophic fire. Without that fundamental understanding, vegetation management projects are doomed to fail in meeting the twin goals of fire safety and conservation of native habitat. 

GUIDING PRINCIPLES 

Background 

We recognize that there is a frightening wildfire potential each fall for some residents living in the East Bay Hills. This potential exists because of the combination of extreme weather events (Diablo winds), the pattern of residential development in the hills, the proximity of flammable homes to fire-prone vegetation, and the lack of adequate preparation to the urban infrastructure, including defensible space. 

Natural wildfire in wildland areas can be viewed as an event without serious consequences to humans, but at the wildland/urban interface where man has altered natural conditions, it can lead to a disaster. There are natural cycles that are unavoidable that we must pay attention to, prepare for, and be ready to respond to appropriately and sometimes quickly. As an example, during the 21st century the East Bay Hills will not be lucky enough, even with exceptional fire fighting, to get by with zero uncontrollable wildfires and zero extremes in weather. Diablo winds in the fall months are the key environmental factor for extreme fire behavior, and it will be impossible to know the exact location, source, and timing of an ignition that will transform high winds into a raging wildfire. 

During some Diablo Wind wildfires there will not be enough firefighters, fire trucks, helicopters, or aircraft to save every house or even control the fire until the winds slow. Unlike “normal” fires that can be fought, to a certain extent on the ground, Diablo Wind fires prevent the placement of firefighters on steep slopes or other hazardous locations due to the speed of wind-driven fire. Under these circumstances, quick evacuation and homeowners insurance will be the only protection for residents who have lost property. 

Recent reports compiled by firefighters and researchers in “lessons learned” from other catastrophic wildland/urban interface fires in California have shown that the most important factor in preventing homes from burning in wildland fires is hardening of structures and the creation of defensible space. Conversely, unprepared residential areas will likely not be saved during a wind-driven wildfire and will contribute to the rapid spread of wildfire into adjacent residential areas as happened during the 1991 Oakland/Berkeley Tunnel Fire. 

The 1995 Hills Emergency Forum Plan did not receive full acceptance from the environmental community because it contained insufficient field collected data to support the designations of fuel characteristics of our local vegetation, did not take into account the importance of conserving native habitat, and did not include a legally required environmental document along with the Plan. 

The 1995 HEF Plan recommended that public agencies and large acreage landowners create and maintain two different types of areas managed for fuel reduction in the East Bay Hills. The first are the ridgetop fuelbreaks that were begun after the freeze of 1972 by removing freeze damaged eucalyptus to achieve a 300’ wide zone of managed vegetation where firefighters could attempt to stop a fire that started in wildland areas to the east, before it could race over the ridge into residential areas. The second type of management was created after the 1982 Blue Ribbon Report and the 1995 HEF Plan. The 1982 Report recommended fuelbreaks designed to provide a minimum of 100 feet of managed vegetation (including what the homeowner is required to do for defensible space) at the wildland/urban edge. The 1995 HEF Plan recommended fuelbreaks within a 500 foot study area, that in itself became controversial and confusing, designed to provide an area of managed vegetation with less than eight-foot flame lengths at the wildland/urban edge where firefighters could safely work to protect homes. 

The Sierra Club, CNPS, and Audubon have not been satisfied with the Park District’s approach for maintaining its fuel-managed areas. We know that fuelbreaks constitute a combined area of more than 20 miles and 500 acres, often covered by weedy species, mowed below 4” of height, or over-grazed by goats, with little concern about species or habitat values. Also several eucalyptus management, thinning, or conversion projects exist that need attention. We are concerned that the Park District’s consultants and its staff have yet to articulate a clear vision about how they intend to maintain these areas while favoring and increasing the percentage of native plants over weedy, fuel-rich non-natives. 

The debate about wildfire risks attributed to non-native eucalyptus trees has been a controversial topic for years. In our opinion, there is ample evidence to show that eucalyptus and pine trees in dense unmanaged groves are both a wildfire threat and an environmental dilemma that requires attention. Non-native eucalyptus and pine groves can exceed 120’ in height and can be prone to dramatic fire behavior. When wind- driven wildfire reaches tree crowns, flames above 150’ can be expected with burning embers blowing downwind well beyond one half mile. The capacity to spot new fires that overwhelm firefighting forces during Diablo Wind conditions means these species must receive high priority for treatment. Selected and representative quotes, articles, and reports that provide additional information and perspective about the fire hazards and the environmental dilemmas posed by eucalyptus and pine plantations in the East Bay Hills can be found in the Background to the Environmental Green Paper. 

Recommendations and Solutions 

In our opinion, decisions about how best to manage our east bay hill vegetation on the wildland side should be based on the twin goals of reducing the risk of catastrophic fire and maintaining the fragile native habitat found in the wildland/urban interface. To accomplish these goals, agencies should formulate well-conceived plans that integrate natural resource sciences and fire science. 

All plans to reduce vegetation on the wildland side must be site specific, taking into account a range of critical variables that result in an individual profile for each site. We do not endorse generic fuel prescriptions because they do not take into account the unique threats and values of each site. In order to accomplish the twin goals of reducing the risk of catastrophic fires and of maintaining sustainable native habitat, agencies must recognize that effective management of live fuels is a subset of sound land management (and not the other way around) primarily because of the high degree of variability of living landscapes. 

We urge the Hills Emergency Forum (HEF) and its member agencies to prepare updated mapping systems for the East Bay hills that identify wildland plant communities in site-specific detail as well as the type and density of vegetation intermixed with home landscapes. 

Native vegetation communities, including our native woodlands, are generally below 40’ in height, and are less prone to unmanageable fire behavior. These communities are comprised predominantly of plants that are native to the East Bay and form more than 80% of today’s wildland vegetation in the hills. The recommended strategy for protecting residential areas from wildfire coming from native vegetation is to establish an understanding of the ecology and fire-behavior of the fuels site-specific to each individual wildland/residential edge, and then manage these edges to provide safe access for firefighters defending structures that are able to resist burning embers and to hopefully stop fire before it enters residential areas. 

As each agency prepares their individual plans and environmental documents, they will be required to address the cumulative impacts of wildland fire hazard reduction projects by all agencies. This will require active cooperation and long range planning by HEF member agencies. We will reserve our final opinion about how each agency handles these matters as we review their plans and environmental documents. 

Enhancing and Preserving our Natural Environment 

While Reducing the Risk of Catastrophic Fire 

Background to the Environmental Green Paper 

This Background Paper has been prepared by the Sierra Club (Sierra Club), East Bay Chapter of the California Native Plant Society (CNPS) and the Golden Gate Audubon Society (Audubon) to document our positions on several of the issues that are important to us as we explore options for meeting the twin goals of enhancing and preserving native plants and wildlife while reducing the threat of catastrophic fire at the Wildland Urban Interface in the East Bay Hills.  

This topic is of timely importance because of the pending release of the environmental review documents being prepared by the East Bay Regional Park District, FEMA grants for vegetation management, and other agency documents that are to follow. 

We would have preferred working with and commenting on a single draft wildfire hazard reduction plan and environmental document for the East Bay Hills with a free exchange of ideas, concepts, and details presented to and discussed with experts and stakeholders who have been involved in these matters for the past 15-years. This would have provided for an Integrated Fire Management approach at all levels, both in content and process, and among all-important stakeholders. This was the type of process that we expected after the Park District’s Temescal workshops of 2000, and is consistent with our understanding of how the Park District Plan/EIR/EIS should have been developed. With that understanding, we supported Measure CC in 2004 including the $10 million for District projects and a joint fire hazard mitigation plan that was to involve Hills Emergency Forum (HEF) agencies. 

Thus, we were disappointed that the HEF decided three years ago that each agency should proceed with individual plans and environmental documents. The East Bay Municipal Utility District and the University of California had already completed their Land Use Master Plans, with Berkeley, Kensington, and El Cerrito not contemplating plans for their residential areas. The next to emerge will be the Park District’s Plan/EIR that has been under development during the past two years. The consultant’s draft Plan is currently being reviewed by Park District staff that will recommend several changes in the draft, followed by a public review document that is nearing completion. We also understand that Oakland intends to prepare its plan and environmental document following completion of the Park District Plan/EIR. 

In our opinion, staff and consultants have developed the Draft Park District Plan in relative isolation instead of taking more time to "get specific" with recognized experts and stakeholders. True, there were four informational meetings at the Trudeau Center with consultant and staff presentations, and time for public comment. However, the District’s Plan/EIR process to date, has offered little detail, so it’s anyone’s guess about what will be in the draft documents soon to be released for public review. We have seen very little in the way of detailed resource information, and have not been informed about which federal agency the District will use to obtain required biological opinions necessary to make its Plan/EIR complete. In the event the draft, which we have not seen, requires substantial changes or additions, we support the use of additional Measure CC funds, District funds, or use of grant funds to complete a Plan/EIR document that will be useful and supported by the environmental community and other stakeholders. 

In the meantime, the District has proceeded with fuels management based on very little oversight by its own stewardship department and with a FEMA EA that covered only federally listed plant and animal species. The result has been fuels management executed without the benefit of clearly derived policy. 

Meanwhile the actual vegetation management projects taking place in some areas have been fraught with controversy. We also are aware that three Federal Emergency Management Agency (FEMA) competitive grants have been awarded to the University (Strawberry and Claremont Canyons), to the City of Oakland (Frowning Ridge), and to the Park District (East Bay Hills Area) for fire hazard reduction projects. These grants will require three different project level FEMA Environmental Assessments. As with EBRPD one of the consequences of this kind of haphazard approach has been the creation of de facto policy on the part of UC, the City of Oakland, and various stewardship groups in terms of on-the-ground management of vegetation. These policies have not had the benefit of public, scientific vetting and in some cases have now found their way into federal policy. Without proper vetting, these activities have resulted in mixed results. 

It is important to note at the outset that an Integrated Fire Management approach means that the total scope of fire hazard (both from human infrastructure and from vegetation) will be considered as a first step, both in the wide scope of the East Bay Hills Wildland Urban Interface and in individual sites that are identified for some form of action. While vegetation management is surely an important part of the total picture, it must not be the tail that wags the dog as it has been in the past, particularly after the ’91 fire. While the human infrastructure including roads, water supply, defensible neighborhoods, etc., is expensive to maintain or improve, only well-planned infrastructure can assure safety from catastrophic fire. The National Firewise Communities program has made that clear. By its very nature, the living landscape involves far more variability and therefore attempting to manage it means a certain lack of predictability. Without that fundamental understanding, vegetation management projects are doomed to fail in meeting the twin goals of fire safety and conservation of native habitat. 

It is clear to us that the approach taken by HEF agencies will result in duplication of effort as well as an understandable level of confusion as agencies work through fire hazard and resource management plans that address their unique situations. However, in the spirit of moving forward, we offer the following guiding principles for consideration by agencies and others interested in these issues. 

GUIDING PRINCIPLES 

1. We recognize that there is a frightening wildfire potential each fall for some residents living in the East Bay Hills. Our local wildfire history suggests that there are different levels of risk faced by hill residents depending on their location. Of the approximately 30,000 homes in the hills, the actual number of homes that have been lost or families personally threatened by a wildfire has been relatively small. However, agencies and residents should not be apathetic because wildland/urban interface wildfires are becoming all to common during the past two decades, and global warming with its extremes of weather will make this century even more risky. 

a) Too many homes were lost during the Berkeley Fire of 1923, the Fish Ranch Road Fire of 1970, and the Oakland/Berkeley Tunnel Fire of 1991. These three Diablo Wind Fires destroyed homes, took lives, and caused substantial property and economic damage, and played a role in massive weed invasion of East Bay Hill native habitat. Seven other Diablo Wind Fires and many West Wind Fires have also occurred in the past along the 30-mile hill corridor without significant property loss, many before residential developments were fully extended into the hills. The above three Diablo Wind mega-fires destroyed a total of 3,600 homes during less than seven hours of rapid expansion for each fire. Wind driven fires can be impossible to control at the fire head, leaving firefighters to only work on a fires flanks until the winds slow. The 1991 fire destroyed 700 homes in one hour, a total of 3,000 homes in seven hours, and 26 lives were lost, mostly during the first hour of the fire. 

b) Predictions about what might happen in the way of wildfire, weather extremes, and climate change during the 21st century should be part of the public discussions leading to agency planning processes that will ensure appropriate preparation for wildfire and appropriate planning for wise management of natural resources. As an example, during this century the East Bay Hills will not be lucky enough to get by with zero mega-fires and zero extremes in weather. Diablo Winds in the fall months are the key environmental factor, and it will be impossible to know the exact location and timing of an ignition that will transform high winds into a frightening wildfire. The events of the 20th Century suggest that it would not be unreasonable to forecast something like three Diablo Wind mega-fires, seven “normal” Diablo Wind fires, possibly as many as 150 “normal” West Wind fires, four El Nino events, four extended freezes, and four drought cycles that will all impact wildland vegetation and residential areas during the 21st century. Agency and homeowner preparation or lack of preparation will be directly related to the amount and extent of damage that these events can cause. 

2. Natural wildfire in wildland areas can be viewed as an event without serious consequences to humans, but at the wildland/urban interface where man has altered natural conditions, it can lead to a disaster. When wildfire is in control, all involved vegetation and residential areas that lie in its path can be taken back to an earlier stage, to start all over again. Wildfires are different in scope and impact than controlled burns, but their potential for weed invasion can be the same. Given the level of weed invasion that is directly related to disturbance--whether it’s fire or vegetation removal--, it is unlikely that native vegetation will re-set to “an earlier stage.” Rather, we are likely to see an increase in weed invasion and a disruption of our East Bay Hill native habitat unless appropriate steps are taken to control invasive weeds. 

In the hills, wind driven wildfire will not distinguish between vegetation and unprepared residential structures. Virtually all development in the East Bay Hills occurred during a 100-year period when agencies and homeowners did not understand or respect the potential wildfire danger created by Diablo Winds. The patterns of residential development combined with the hills unique natural features have increased the potential for home loss during wind driven wildfire. 

a) Roads are on steep hillsides, narrow, and usually congested. 

b) Homes are in dense residential areas, mostly constructed of wood, and often surrounded by other potentially flammable homes and vegetation. 

c) Homes are on steep hillsides with limited access for fire fighters. 

d) Public agencies and large acreage landowners have allowed non-native vegetation to develop “unnaturally” with little maintenance, and with increasing levels of flammability. 

e) Above ground power lines are common in the hills and water supply for firefighting is less than desirable. 

These are all recognized aspects of unsophisticated residential development in the hills, in comparison with today’s standards. Public officials and fire safety activists, all to often, want to focus on fixing the “vegetation problem” without fixing the “residential problem”. Both need short and long term attention and fixing. 

3. During some Diablo Wind wildfires there will not be enough firefighters, fire trucks, helicopters, or aircraft to save every house or even control the fire until the winds slow. Unlike “normal” fires that can be fought, to a certain extent on the ground, Diablo Wind fires prevent the placement of firefighters on steep slopes or other hazardous locations due to the speed of wind-driven fire. Under these circumstances, quick evacuation and homeowners insurance will be the only protection for residents who have lost property. 

a) We believe that cities and area fire departments must develop more reliable fire-fighting strategies for combating Diablo Wind wildfire with more attention paid to identifying and expanding predetermined areas in both wildland and residential areas where wildfire might be stopped. 

b) Cities through their police departments must develop neighborhood evacuation plans, known to all residents and agencies, that recognize the potential for rapid spread of wildfire moving through hill residential areas with narrow and congested streets. 

c) Insurance is also necessary and critical for homeowners choosing to live in high-risk settings; however, having insurance should not be a reason for not appreciating and preparing for the actual risks being faced. 

It is surprising to hear some resident’s say they like the hills and their homes just the way they are, and that they accept the risk of wildfires. This sentiment is not usually shared by most, but remains one of the more important concerns if it threatens future stability of fire hazard reduction efforts. If true and persuasive, further efforts in wildland vegetation management may not be supported during tough economic times, and less substantial efforts will result in marginal wildfire risk reduction benefit. If the status quo condition for the hills were followed, future fire losses for both large and small wildfires would be a matter for insurance coverage if it can be obtained. 

Fortunately, residents have recently voted to support two significant measures that will improve their fire safety. Oakland’s Wildfire Prevention District and the Park District’s Measure CC have provided funding to address fire risks by two of the largest landowning public agencies in the hills. During these funding measures, the Sierra Club, CNPS and Audubon have supported strategic vegetation management programs in our neighborhoods, regional, and local parklands that reduce wildfire risks while conserving, recovering, and sustaining native habitats. 

4. Recent reports compiled by firefighters and researchers in “lessons learned” from other catastrophic wildland/urban interface fires in California have shown that the most important factor in preventing homes from burning in wildland fires is hardening of structures and the creation of defensible space. We concur that the best way to protect homes from wildfire is for cities to make sure that all homes and all structures have 100’ of defensible space, and that homes can resist burning embers. We strongly encourage and support programs by agencies and homeowners on local and private lands that will protect homes from wildfire. The recently revised State Standards for defensible space and home construction can be relatively easy to inspect and achieve in rural areas, but not so easy in our densely occupied hill residential areas. Cities should determine how best to apply these standards for both individual homes and groups of homes, especially at the wildland/urban interface where property ownership is complex. 

Too often, homes are permitted and constructed within 15’ or less of the property line without enough space to comply with the intent of state law that homeowners should create and maintain their own defensible space. Cities must continue to ramp up their inspections to get compliance and continue their inspections even in times of economic difficulty. 

Further, building codes must be updated to cover the construction and maintenance of fire safe structures that can resist burning embers. Waiting 50 years for remodels to bring new codes into force is unacceptable. Unprepared residential areas will likely not be saved during a wind-driven wildfire, and will contribute to the rapid spread of wildfire into adjacent residential areas. 

As a very important matter of public policy, cities and counties should make sure that homes and other structures are not built within an indefensible distance from public-park and open space without appropriate mitigation, nor from the open space borders of other public lands. Cities should also prioritize for inspection and compliance those structures already located within an indefensible distance from public parklands. Public agencies should not have to use their limited funds and staff resources to create and maintain defensible space for new homes constructed too close to park boundaries or other public lands. 

5. In our opinion, decisions about how best to manage our east bay hill vegetation should be based on the twin goals of reducing the risk of catastrophic fire and maintaining the fragile native habitat found in the wildland/urban interface. To accomplish these goals agencies should formulate well-conceived plans that integrate natural resource sciences and fire science. Very little of today’s East Bay Hill wildland vegetation is truly pristine because of the dramatic landscape changes that have occurred during the past 200 years. Returning to the vegetation of 1800 or 1900 is not realistic or even remotely possible with today’s population of 2.5 million east bay residents and the extensive hill residential areas that were developed during the past 100 years. 

Existing native plants and habitat are the result of the unique and complex history of plant species and habitat evolution in this geographical area. Most of today’s East Bay Hill public land vegetation (by counting numbers of species represented in that vegetation) is composed of “truly native” species. However, most of the plant communities, in their current locations and size, are relatively young and will continue to change. As change occurs, we believe that today’s natively-evolved local species and their tendencies to aggregate into recognized “native habitats” can persist very well if allowed and assisted by dedicated land managers. These persistent, recognized habitats will indeed not remain static, and will go through stages of succession, development and rebirth during the next 200 years. 

We know that “exotic” vegetation in the hills has experienced four major freezes that have killed or damaged eucalyptus trees, and that many fires have killed pine trees. Since the spread of both blue-gum eucalyptus and Monterey pines is assisted by fire, the presence of these trees pose a growing threat. We also know that global warming will result in further extremes in weather that will make the 21st century even more risky. The best we can say at this point is that we do not really know how native-like wildland plant communities will respond in detail to future climate change. However, we prefer to limit the possibilities to changes brought about by our natively evolved regional flora, and to not intermix or include species of distant exotic origins that will complicate the process and remain as potential fire hazards. 

6. Any and all fuels management plans must be site specific, not simply vegetation and fire risk specific. In order to accomplish the twin goals of reducing the risk of catastrophic fires and of maintaining sustainable native habitat, agencies must recognize that effective management of live fuels is a subset of sound land management (and not the other way around) primarily because of the high degree of variability of living landscapes. Each site is unique and is constantly undergoing multiple processes of change and evolution. Agency plans must be based on sound environmental concepts and not just the developing science of wildfire behavior in wildland/urban interface settings. This is the issue that caused us the most concern during the discussions following the 1995 HEF plan. We are not so sure about how much useful fire science there is that will really apply to our unique wildland/urban setting since to date very little science has been based on field collected data. Instead, there has been heavy reliance on modeling which is subject to error based on sometimes-incorrect assumptions. 

We suspect that the Plan will be based on a combination of relevant local and statewide experiences with wildland/urban fire, and with some adapted fire science. However, we doubt that it will take into account detailed field-collected data on the unique characteristics of our local vegetation types. The application of sound environmental concepts will be especially important for any vegetation management program undertaken by the Regional Park District where informed knowledge about the environment must guide what it can and should do to reduce fire risks. 

Since 1995 we have consistently urged the Park District to seek solutions that will be effective with minimum impacts on the park environment in managed areas that are designed to sustain native habitat. We have also urged that a comprehensive Resource Management and Fire Hazard Reduction Plan be prepared, along with its legally required environmental document. 

7. We urge the HEF and its member agencies to prepare updated mapping systems for the East Bay hills that identifies wildland plant communities as well as the type and density of vegetation intermixed with home landscapes. Since vegetation is a key factor in wildfire behavior, we should have accurate information about the type of vegetation that exists in both wildland and residential areas. We do not currently have a good mapping system with data on the fire-prone vegetation that is intermixed with home landscapes. If we are expected to reduce the risks associated with wildland vegetation, we should definitely be reducing the risks of vegetation to be found in residential areas. 

The 1995 HEF Plan is the only mapping system (other than the Park District vegetation maps of 2006 that only cover Regional Parks) available today that attempted to describe the type of wildland vegetation found throughout the 18,500 acres of undeveloped property in the Oakland/Berkeley hills (the 1995 acreage numbers do not include wildland vegetation in Kensington to Richmond residential areas or Wildcat Canyon Regional Park). The Behave computer wildfire modeling of the 18,500 acres of wildland vegetation predicted that 43% would burn with flame lengths of 8’ or less that could theoretically be fought and controlled by firefighters on the ground. The other 57% of wildland vegetation would burn with flame lengths between 9’ and 60’, with fire fighters unable to control wind driven wildfires in these areas until the winds abate. Polygons were developed for each plant community, and the summary acreage of each type of plant community is organized in this paper as follows: 

Acres Native-like Plant Communities (mostly natives by species count)  

4,100 Oak/Bay Forest- Mixed 

3,847 Grassland (mostly areas that are grazed) 

3,309 Dry North Coastal Shrubland 

1,418 Redwood Forest 

918 Successional Shrubland 

855 Oak/Bay Woodland- Mixed 

332 Wet North Coastal Shrubland 

79 Chaparral- Mixed 

71 Riparian Forest 

10 Oak Savannah 

14,940 Subtotal (81% of wildland vegetation) 

Acres Non-Native Plant Communities (dominated by trees with few species) 

1,379 Eucalyptus- 20-year old stump sprouts (now 30-years old) 

859 Pine Forest- Mature 

836 Eucalyptus Woodland- Mature 

233 Pine/Eucalyptus Mature, Mix 

222 Eucalyptus- 5-year old seedlings (now 15-years old) 

47 Pine Forest- Plantation 

6 Acacia 

6 Cypress 

1 Other 

3,590 Subtotal (19% of wildland vegetation) 

This initial attempt to map and classify vegetation in the East Bay Hills has proved to be inadequate for the task because it did not accurately describe our diverse local vegetation types in site-specific detail, as well as for their individual and community fuel characteristics. There are newer mapping and classification protocols developed by the 

State Vegetation Program of the California Native Plant Society and adopted by the National Park Service and other government agencies that can be utilized to map and describe the vegetation in these areas accurately. 

However, this is only one of several important factors to be taken into account when developing a management strategy for any given polygon. Location within a watershed, slope, aspect, wind mapping (under “normal” and Diablo conditions), live fuel moisture field sampling, description of understory (not only of woodlands but of shrublands as well), soil type, soil moisture, utilization by wildlife, type and degree of weed invasion, and proximity to structures. These are the important factors that go into understanding how best to manage a given area. 

We are aware that the Park District’s mapping project for Hill parks between Lake Chabot and Wildcat Canyon (and all Measure CC Parks) was finished in 2006, and that fire modeling has been completed for these parks. We will be particularly interested in reviewing the data, mapping results, assumptions used, and the fire attributes for park vegetation. We understand that the District’s 13,818 acres of hill park vegetation have been grouped into the following park plant communities, and we have organized these groups into two major classes as follows: 

Acres Native-like Plant Communities (mostly natives by species count)  

3,675 Oak/Bay Woodland 

2,439 Woodland Succession 

1,688 Grassland (mostly areas that are grazed) 

1,505 Shrubland 

1,022 Shrub Succession 

474 Redwood 

110 Willow 

30 Riparian/Wetland  

11,034 Subtotal (80% of park vegetation) 

Acres Non-Native Plant Communities (dominated by trees with few species) 

1,862 Eucalyptus 

363 Developed Park Areas and Turf 

341 Pine 

30 Mowed Annual Grass 

5 Acacia 

2,784 Subtotal (20% of park vegetation) 

It appears that the fuels management done by the HEF agencies and EBRPD to date has been conducted in accordance with the old Behave (flammap) fuel models that are untested at the wildland/urban interface. If so, it has driven management decisions in ways that cannot support the goals of either achieving safer fuel loads or maintaining native habitat. If the old classification of maintaining an 8-foot flame length in all vegetation is adhered to, very little but mowed or grazed annual grassland can qualify as “safe” to maintain. The empirical result of following that prescription has often meant that the type conversion of native shrublands, such as Baccharis-dominated north coastal scrub, has created their replacement with fuel-rich French broom and light flashy fuels such as thistle, which also have poor habitat value. 

On the other hand, field-collected data, including sampling for live fuel moisture, might indicate that, in some instances it’s wiser to leave vegetation in place rather than to remove it. One example would be to contemplate leaving Baccharis, which contains relatively high levels of moisture, in some sites where it acts as a green sponge, holding moisture within the plant as well as within the soil. 

It is critical that if fuel modeling is to be used, it contain accurate inputs from our local vegetation under differing conditions. We do not know what the current models are that are being used to inform the conclusions of the EIR or what information is being used as input to the models. 

8. The 1995 HEF Plan did not receive full acceptance from the environmental community because it contained insufficient field collected data to support the designations of fuel characteristics of our local vegetation, did not take into account the importance of conserving native habitat, and did not include an environmental impact report as required by state law. However, the 1995 HEF Plan identified the specific wildfire threats faced by homeowners in the hills, and recommended a mitigation program for agencies and private property owners based on the following concepts. 

a) The Plan recommended that homeowners fully comply with state law that currently requires a minimum of 100 feet of defensible space surrounding structures, and that all homes in high risk areas should be constructed or renovated and maintained to resist burning embers. 

b) The Plan recommended that public agencies continue maintenance of ridgetop fuelbreaks, and create a new type of managed area at the residential edge, that will involve both public and private lands. The width for residential edge buffer zones has been a topic of ongoing controversy for the past 15 years. Currently, most research suggest that a maintained zone of vegetation 100’ to 200’ from structures (including homeowner defensible space) is appropriate, depending on slope, type of vegetation, and site conditions. These maintained areas will not necessarily stop all wildfires, but will be essential for providing safe locations for firefighters defending homes at the wildland/urban interface. 

c) The Plan recommended that public agencies and large acreage land owners manage or convert their eucalyptus and pine groves to reduce the chance of burning embers being blown into residential areas. 

9. The 1995 HEF Plan recommended that public agencies and large acreage landowners create and maintain two different types of areas managed for fuel reduction in the East Bay Hills. The first are the ridgetop fuelbreaks that were begun after the freeze of 1972. These fuelbreaks were created along the west boundary of regional parks with some sections along Skyline and Grizzly Peak Boulevards on city or other agency lands. Ridgetop fuelbreaks were created by removing freeze damaged eucalyptus to achieve a 300’ wide zone of managed vegetation where firefighters could attempt to stop a fire that started in wildland areas to the east, before it could race over the ridge into residential areas. Public agencies that currently manage ridgetop breaks are now creating even wider resource management areas that are intended to look “natural on the ridge” without strict adherence to width criteria, usually with a roadway as the primary anchor line. 

The second type of management was created after the 1982 Blue Ribbon Report and the 1995 HEF Plan. The 1982 Report recommended fuelbreaks designed to provide a minimum of 100 feet of managed vegetation (including what the homeowner is required to do for defensible space) at the wildland/urban edge. The 1995 HEF Plan recommended fuelbreaks within a 500 foot study area, that in itself became controversial and confusing, designed to provide an area of managed vegetation with less than eight-foot flame lengths at the wildland/urban edge where firefighters could safely work to protect homes. 

While there is no mystery about the reason for reducing live fuels when residential areas are located at the edge of large public parks or other areas of dense natural-like vegetation, there is as yet no clear understanding of what management should be on specific sites since prescriptions have been generic or non-existing. Nonetheless, most park agencies are using some form of vegetation management on public lands at their residential edge to reduce the chance of wildfire moving from public lands into residential areas. 

10. The Sierra Club, CNPS, and Audubon have not been satisfied with the Park District’s approach for maintaining its fuel-managed areas. We know that fuelbreaks constitute a combined area of more than 20 miles and 500 acres, often covered by weedy species, mowed below 4” of height, or over-grazed by goats. Also several eucalyptus management, thinning, or conversion projects exist that need attention. We are concerned that the Park District’s consultants and its staff have yet to articulate a clear vision about how they intend to maintain this interface while favoring and increasing the percentage of native plants over weedy, fuel-rich non-natives. This topic will be a subject for further comment and focus by our members and experts during agency Plan/EIR processes. 

From the Park District’s perspective, focusing vegetation management efforts in the immediate area adjacent to homes means that larger areas of native-like park vegetation can remain unaffected. Most of the required District fuelbreaks are already in place with missing sections to be identified in the Plan/EIR. However, because very little attention has been paid to maintaining healthy native habitat, these sections will need to be reviewed for site-specific sustainable practices as part of the vegetation management plan. 

a) New fuelbreaks recommended for park grassland areas are either currently grazed or are on sites where brush succession has yet to occur. Continued grazing or mowing should be sufficient to maintain relatively narrow areas of grassland as fuelbreaks. Maintenance to reduce exotics and to increase native flora that will be sustainable should be the prime objective, so close attention must be paid when using goats or personnel unfamiliar with both exotic and native vegetation. 

b) Shrublands are another matter requiring intensive management of wider fuelbreak widths when shrub species are retained because of their potential flame heights and rate of spread. Prescriptions usually call for shrub “islands” with about 30% of shrub cover (with retained shrubs pruned at four feet in height and cleared of flammable wood debris), with 70% open areas that are usually mowed. An alternative option for existing shrubland areas is to convert to a narrower fuelbreak width of grassland with regular mowing in the spring and summer. 

c) Oak/bay woodlands are a relatively fire-safe plant community, with periodic clearing of ladder fuels being the only maintenance near homes. 

d) In areas of non-native vegetation, conversion to the adjacent native-like plant community can be the best solution with over seeding of local ecotypes of native grasses and associated flora when soils are disturbed or left bare during conversion. 

e) However, many of the District’s earlier fuelbreaks involved a more destructive conversion during logging of eucalyptus and pine groves in the 1970s, followed by 30-years of mowing or goat grazing resulting in weed problems and broom invasion. These areas will require a different approach to re-establish natives, and a maintenance program that will pay attention to the removal of weedy plants and to increase the overall percentage of natives. 

11. Non-native eucalyptus and pine groves can exceed 120’ in height and can be prone to dramatic fire behavior. When wind drive wildfire reaches their crown, flames above 150’ can be expected with burning embers blowing downwind well beyond one half mile. The capacity to spot new fires that overwhelm firefighting forces during Diablo Wind conditions means these species must receive high priority for treatment. Non-native plant communities in the hills are today’s remnants of the tree planting efforts of two Oakland businessmen who forested the hills for future residential development and for hardwood lumber production. Frank Havens and Borax Smith formed the Realty Syndicate in 1895 to sell lots and homes to new residents who would also buy tickets to ride their trains. They launched a massive tree-planting program to beautify their 13,000 acres of hill land, and a few years later Havens formed the Mahogany Eucalyptus and Land Company to plant gigantic plantations of blue gum eucalyptus on his privately owned water company lands to meet the state’s growing demand for hardwood lumber. Both enterprises could not be repeated today, but have created increasingly significant environmental impacts that residents and agencies must now address that will be increasingly expensive in the future. 

We have used “non-native” as the appropriate term for describing Havens bluegum (and redgum) eucalyptus trees from the Island of Tasmania Australia, and for describing pines and cypress from the coastal regions of central California. It is not only the “appropriate term” to use, but it carries broadly significant meaning in terms of the impacts these non-native species created and continue to present to the locally-evolved native biodiversity. It is not sufficient to consider these several non-native species as isolated occupants of the land. They each have large contextual, negative impacts that must be factored into any equation regarding protection and preservation of native resources in areas of locally diminished open space acreage. 

Non-native eucalyptus and pine are some of the most dense and flammable plant communities in the hills. Un-maintained eucalyptus groves can have 400 to 900 trees per acre with fuel ladders into the canopy and 30 to 100 tons of flammable fuel on the ground. Wind driven wildfire in these groves can be expected to produce flame lengths and ember throws that will quickly overcome firefighters and significantly reduce evacuation time for homeowners. 

Unmaintained pine groves are also extremely flammable with deep needle duff on the ground and dense pine seedling growth within and around the grove. The presence of Monterey pines intermixed with native coastal scrub also provides a source of tinder that contributes to crown fires since the needle duff can be ignited by embers and can burn off the live fuel moistures of species like Baccharis. 

The recommended strategy for eucalyptus and pine groves is to manage or remove trees and groves that are close to residential areas that could throw burning embers long distances (including over fuelbreaks, natural barriers, and manmade barriers) into residential areas. 

12. Native-like vegetation and our native woodlands are generally below 40’ in height, and are less prone to unmanageable fire behavior. Native-like plant communities form 81% of today’s wildland vegetation in the hills comprised of mostly plants that are truly native to the East Bay. The recommended strategy for protecting residential areas from wildfire coming from native-like vegetation is to establish an understanding of the ecology and fire-behavior of the live fuels site-specific to each individual wildland/residential edge, and then manage these edges to provide safe access for firefighters defending structures to hopefully stop fire before it enters residential areas. 

Most areas offer a range of small to large acreage (sometimes in a mosaic and sometimes as a single type community) of grassland, shrubland, oak/bay woodland, or redwood forest. These plant communities are rather young, achieving their current location, size, and form as a result of both human impacts and plant succession over the past 200-years. Photos at the turn of the 20th century show the hills dominated by grasslands (many of which were maintained by cattle grazing) with smaller areas of shrubs, oaks, redwoods, and riparian vegetation. 

Recent research involving the analysis of phytoliths concluded that the historic plant community for well over 1000 years was baccharis-dominated coastal scrub. Thus, the jury is still out in terms of extent and distribution of the true historical vegetation types. 

The density and distribution of today’s native-like plant communities in the hills are unique to the 20th century and provide excellent habitat for wildlife and other species that make up today’s diverse ecosystems. At many locations there are also endemic animals, birds, or plants that have legal standing. These listed species require individual monitoring, protection, and careful management. 

Each native-like plant community behaves differently in wind-driven fire. Grassland fires are flashy and move quickly, but are relatively controllable. However, they provide a faster means of ignition and spread of fire into other vegetation, particularly upslope. Shrubland fires can also move quickly and some shrubs can produce flame lengths above 30 feet and, once ignited, are more difficult to control. Unfortunately, there has been little research into the important factors that affect ignition in the unique and various East Bay Hill shrub communities and they are thus far poorly understood. Because of the lack of specific field-conducted studies that would help elucidate both the ecological and fuel-related behaviors of individual species and shrub communities, they have been collapsed into the generic category of “brush,” assigned fuel characteristics from other more fire-prone species, and been targeted for aggressive fuels management. Fire in native woodlands produces lower flame lengths but can also crown and produce burning embers under extreme conditions. 

13. The debate about wildfire risks attributed to non-native eucalyptus trees has been a controversial topic for years. In our opinion, there is ample evidence to show that eucalyptus and pine trees, in dense unmanaged groves, are both a wildfire threat and an environmental dilemma that requires attention. Individuals who love eucalyptus trees aggressively defend the tree, arguing that it has been naturalized to this area, it provides habitat for wildlife, and it is not an unusual fire threat. Narratives about both the threat and the environmental dilemma can be found in the statements, articles, papers and reports contained in Appendix A. 

14. We are most concerned with the process by which decisions will be made about the most flammable and potentially controversial plant communities in today’s parklands. We don't endorse generic options but favor site-specific analysis that is grounded in the best possible science. In practice, that means that any one given eucalyptus or pine grove will be managed for its unique characteristics to achieve fire safety, conversion to native plant habitat, or made safe for public use. However, the threat factor is now relatively clear and can’t be denied. 

15. The subject of eucalyptus and pine grove management remains controversial among people of good will. In the interim, the Sierra Club, CNPS, and Audubon offer the following statements for consideration when reviewing agency plans and environmental documents. 

a) Agencies and private landowners should focus their efforts on removing eucalyptus and pine groves on or near the high ridges and on leeward slopes (West facing) above homes to allow these spaces to convert to native-like vegetation that is less prone to spectacular wildfire behavior. 

b) Eucalyptus areas that were logged between 1972 and 1974 should be revisited to remove all 30-year old stump sprouts and seedlings that will not form good park woodlands, and to allow these areas to convert to native-like vegetation. 

c) Groves that are thinned to retain mature eucalyptus trees should keep 30 to 50 trees per acre with shrubs removed and ground fuel maintained at less than two tons per acre. However, everyone should understand that single-age stands do not usually make good permanent park forests because the stand will eventually reach its natural stage of decline and become a hazard that should be removed. At that time conversion to native-like vegetation should take place. 

d) When eucalyptus and pine trees are removed, the areas they occupy should be managed to convert without planting new trees and shrubs to a fire-safe native-like vegetation that blends with and expands adjacent plant communities. The type of replacement vegetation and any required maintenance depends on site conditions and the type of plant community desired. 

When a healthy understory of oaks, bays, and associated trees are present under the eucalyptus or pine canopy, they should be saved during logging and allowed (without additional tree planting) to become the replacement tree canopy. 

When an understory of native trees is not present (especially on ridge tops and dry slopes), grassland and shrubland plant communities should be allowed to re-establish and succeed by appropriately controlling broom, thistle, and other invasive, fuel-rich species. Native shrubland will sometimes reestablish after the eucalyptus canopy is gone if invasive weed species are held in check.  

When there is sufficient native grass cover and/or seedbank in areas to allow for establishment of good quality grasslands, these can be carefully restored and managed by grazing or mowing to prevent re-succession of shrublands. However, in the absence of a native grass seedbank, weeds will dominate the resulting “grassland”. In this case, re-succession by native shrubs can help restore quality habitat. 

e) Thinning young eucalyptus woodlands of suckers and sprouts to create a temporary managed grove is less desirable and may be untrustworthy on our steep and windy hillsides when the goal should be to convert to native vegetation. Thinning eucalyptus and waiting 30-years for native plant establishment under the canopy will allow ladder fuels to become established, and repeated costly logging projects will double environmental impacts. 

f) We support efforts to keep mature eucalyptus trees in groves that can be thinned and maintained as a mature tree canopy for existing and future recreational activities, or as a historic tree grove to be retained pursuant to a park’s adopted Land Use Plan. 

g) We will be particularly interested in the policies that guide when to thin and retain a grove, and when to achieve a conversion to native-like plant communities that are appropriate to the site. As an example, for a grove with 300 trees per acre, it might be short sighted to take out 250 trees per acre to keep a grove when conversion to native vegetation could achieve multiple goals. This would be especially true for areas in parks where native vegetation should the objective. 

h) In all cases, logged eucalyptus stumps must be treated and killed to prevent sucker growth. 

i) Control of weed species such as broom, euphorbia, and eucalyptus seedlings is essential during all maintenance and conversion projects. 

j) Non-native trees (such as eucalyptus and pine) that are small but will become large and are not part of the designed park landscape should be removed at the earliest time possible to keep costs low, minimize resource damage, and allow native-like vegetation to develop as soon as possible. 

k) Tree removals (logging) can be very controversial, and the immediate appearance of logged areas can be dramatic, triggering public protest from people who have not responded during the planning process but are motivated to speak out once logging begins. Often the public is unaware of the costs and tradeoffs of large-scale projects such as logging. As a result, tree-logging projects must be made to be very visible during the entire public process. Before logging projects are presented to the Board for approval to seek bids, staff should ensure that the tree project has specific Plan/EIR clearance with a notice posted in the park before the Board meeting and “left posted” until project completion. After the Board approves a contract, District managers and Board members must be ready to support the tree removal project through to the end. After the contract is awarded and the work begins (sometime months later), experience has shown there will always be a member of the public who sees what’s happening, pleads to save trees, and will lobby to stop all work. 

16. As each of the East Bay Hills Emergency Forum agencies prepares their individual plans and environmental documents, they will be required to address the cumulative impacts of wildland fire hazard reduction projects by all agencies. This will require active cooperation and long range planning by HEF member agencies. The HEF will need to provide sufficient coordination to make sure that potential cumulative impacts are clearly described, and that significant cumulative impacts can be avoided. We urge all agencies to consult with their legal advisors for guidance in developing plans that will address the cumulative impact issue. Of course, we will reserve our final opinion about how each agency handles these matters as we review their plans and environmental documents. 

a) Agencies should commit that cumulative impacts will be avoided while converting high-risk eucalyptus and pine groves to native vegetation, and that they will consider their projects to be self-mitigating projects that complete the work begun in 1973/74. Most of the involved public agency acreage was logged after the 1972 freeze. The removal of multiple stump sprouts and dense seedlings in already logged areas is ongoing work that needs to be completed. Sprouts and single age stands of seedlings are unsuitable for forming safe and healthy woodlands. 

b) Agencies should commit that cumulative impacts will be addressed and avoided by their projects, when considered separately or together, and that they will involve relatively small acreage dispersed along a 30-mile long wildland corridor that totals more than 18,500 acres of similar vegetation 

c) Agencies should commit that cumulative impacts will be avoided by their projects that are coordinated on lands separated by time and space from other agency projects. Coordination will be used to ensure that work will be scheduled over a reasonable period of time, and that there will be no cumulative impacts from overlapping work on the same or adjacent lands. 

d) Agencies should commit that cumulative impacts will be avoided when their projects are coordinated to have sufficient distance between projects by others in location and time, and ensure that there will not be significant cumulative unmitigated impacts on common resources such as wildlife and keystone habitat. 

e) Agencies should agree that they will not allow vegetation management projects to have a significant cumulative impact on sensitive species or habitat because of existing environmental regulations that will be followed, and because of the biological opinions and mitigations that will be required by state and federal resource agencies. 

Appendix A 

The following quotes, articles, and reports provide additional information and perspective about the fire hazards and the environmental dilemma posed by eucalyptus and pine plantations in the East Bay Hills. 

a) In March of 1973, H.H. Biswell, Professor of Forestry and Conservation at the University of California, Berkeley made this prophetic statement. “When eucalyptus waste catches fire, an updraft is created and strong winds may blow flaming bark for a great distance. I think the eucalyptus is the worst tree anywhere as far as fire hazard is concerned. If some of that flaming bark should be blown on to shake roofs in the hills we might have a firestorm that would literally suck the roofs off the houses. People might be trapped”. 

b) James Roof, Director of the Tilden Botanic Garden, in his detailed paper of February 1973, made observations about the areas wildfire risks, about eucalyptus tree risks and impacts on native flora, and offered his recommendations following the freeze of 1972. 

c) Professor Robert Stebbins, Professor of Zoology at UC Berkeley and the curator of the UC Museum of Vertebrate Zoology has been a long-time advocate for retaining eucalyptus groves because of the habitat they provide for local wildlife especially amphibians and birds, and prepared several papers on this subject during the 1995 HEF plan review period. 

d) The Temescal EIR Advisory Group in 2000, listed the following guidelines for eucalyptus and pine forests: “Eucalyptus Forest – This introduced forest community is highly controversial because of the extreme fire behavior that it can generate and because a significant number of native species that have adapted to it. It is a high priority for management, particularly in areas where it has the potential for involvement in wildland fires. Management plans must also take into account impacts on those species that have adapted to Eucalyptus. A number of native raptor species including the Turkey Vulture, Red-tailed Hawk and Great Horned Owl seem to prefer Eucalyptus to native forests in a variety of circumstances. Nest and roost trees should be identified and accommodated with appropriate buffers, where feasible, in fuel-break planning. Monterey/Bishop Pine Forests – This transplanted California native plant community occurs in dense stands and as individual specimens in several areas within the study area. Although less widespread than Eucalyptus, these coniferous forest species are also preferentially used by native raptors including the Golden Eagle. As with Eucalyptus, nest and roost trees should be identified and accommodated with appropriate buffers, where feasible, in fuel break planning.” 

e) The Vegetative Management Plan for the Eucalyptus Freeze Affected Areas in the Berkeley-Oakland Hills was prepared to guide the efforts of agencies working to reduce the potential for wildfire after the freeze of 1972. The Plan was prepared after the hills were declared a disaster area by the State’s Governor, and was adopted before the California Environmental Quality Act was amended to include public agencies. 

f) The Ubiquitous Eucalyptus article, by Bill O’Brien in the fall 2005 BayNature magazine describes the history of eucalyptus trees in the East Bay as well as statements and opinions by local “experts” about both positive and negative aspects of eucalyptus trees. 

g) Respect for the flammability of our hill’s dense eucalyptus groves is common knowledge among local fire chiefs. Fire departments have not been willing to use prescribed fire (with prescriptions set for when fire control is theoretically possible) to reduce the flammability of groves by clearing the 50 to 100 tons of ground fuel that can be found under unmaintained eucalyptus groves. Fires in native-like vegetation will not burn well in the hills during most of the year, but fires under eucalyptus with its shredding bark and oily leaves can move to the treetops during almost any season. Professor Biswell tried unsuccessfully, in the 1970’s to establish prescribed fire as a local maintenance practice in eucalyptus, as is done in Australia. Regional Park Fire Chiefs have wavered, and remain unwilling to use this technique even today because of the risk of escaped fire, and because of smoke impacts on the air basin. 

h) The 1995 HEF Plan (in its final Report and Technical Appendices) determined that eucalyptus and pine trees and the burning embers that they can produce in a wind driven wildfire are an important factor in the wildfire risks faced by hill residents. 

i) Javier Trelles, and Patrick J. Pagni UC Berkeley Professors analyzing the role of wind patterns during the 1991 fire, described the Sunday morning fire start as follows. On October 20, at 6:00 a.m., the normal weather pattern was interrupted as winds in excess on 10/ms arose from N 35 degrees E and the relative humidity dropped below 10%. This strong, dry convective current began to dramatically lower the moisture level of the previously soaked burn area of the Saturday fire. The ambient temperature climbed to 90 degrees. The few embers that remained buried overnight were by 10:45 a.m. spotting to new areas of dry fuel. Between 11:15 and 11:30 a.m., extremely rapid fire spread in windward di