What's Wrong with the NAP



The Natural Areas Program (NAP), part of the SF Recreation and Park Department, claims one-quarter of the City’s parks as its own (one-third if you include Pacifica’s Sharp Park). Originally intended to preserve remnants of San Francisco’s natural heritage, it has become a citywide empire that takes large swaths of existing habitat and changes it to match a perceived “better” San Francisco from several hundred years ago. Existing plants, trees and habitat for wild animals such as coyotes, raccoons, and possums will be destroyed in the City’s 32 natural areas, to be replanted with “native” plants whether the park users, neighbors or the displaced wildlife want it or not. Keep in mind that San Francisco several centuries ago was largely sand dunes with some dune scrub and few trees. That is the NAP vision of what large portions of our neighborhood parks should look like.

A few of the major concerns about the way NAP is being implemented include:

1)    NAP plants threatened and endangered species throughout our parks

Once planted, the “endangered” status of these species triggers automatic and drastic protections, with major restrictions on where people can go in the park and what they can do once there. This is not preserving existing species, since few endangered species are in our city parks now, nor have they been for decades if not hundreds of years. This is taking large swaths of city parkland away from any recreational use and turning them into static plant museums that show what habitat looked like in a single snapshot of time several hundred years ago.

The climate has changed in the hundreds of years since many of these species were in San Francisco. With coming global warming, it’s going to change even more (and likely at a faster pace). It’s not at all clear that these newly planted endangered species will be able to survive in the changed climate of today or in the changing climate of the future.

Biologists have noted that planting a few sensitive species of plants does little to preserve the species. It is not an ecological decision; it is a landscaping decision. There are plenty of native plants that are not endangered or threatened that could be planted, if the goal is to show what San Francisco’s habitat looked like several hundred years ago.

2)    The scale of NAP is too ambitious
NAP has bitten off more than it can chew. It claims control of the entire park in over half of the parks with natural areas in them (18 of 32 parks). No other recreational use is possible in those parks. In an additional 10 parks, NAP controls over 50% of the land. Only four of the 32 parks with natural areas have less than 50% of their land controlled by NAP. This means that people will lose easy access to 18 neighborhood parks. They cannot play catch with their kids or fetch with their dog in those neighborhood parks, or put out a blanket for a picnic. They can only walk on a few trails and admire the plants.

Within the natural areas, a majority of the land (57%) will have significant restrictions to access by all people (not just those with dogs) since that is the amount of natural areas that is designated as MA-1 and MA-2, the most “sensitive” designations in natural areas. In eight parks, all of the land in the natural area is designated as MA-1 and MA-2.

NAP would not be anywhere near as controversial if it had not overreached and claimed one-quarter of all the RPD-managed parkland within San Francisco city limits (if you include the natural area in Sharp Park in Pacifica, the amount of parkland claimed by NAP goes up to one-third of the total RPD-managed parkland). Put another way, the total size of NAP-controlled land is as big as Golden Gate Park, albeit divided into 32 different parks.

3)    NAP cannot adequately maintain all of the land it claims to control
In most parks, the NAP Management Plan allocates fewer than 20 day/year for planting/maintenance of the natural area in those parks. In 16 of 32 natural areas, the total maintenance planned is 10 or fewer days each year. There are countless stories of volunteers who have spent long hours planting native plants in NAP areas, only to see absolutely no maintenance performed once the plants are there. Without maintenance, the plants die, creating unsightly vistas of dead and dying plants. A few days a year is not enough to adequately maintain these areas.

NAP supporters use the fact that NAP cannot maintain all the area it has claimed as a reason to demand that it be given more money and hire more staff (NAP currently has 10 gardeners for its sole use). Of course, if NAP controlled less area, this would be less of a problem.

4)    NAP could close up to 80% of the legal off-leash space in SF city parks
NAP plans call for the immediate closure of about 15% of the legal off-leash space (Dog Play Areas, or DPAs) in San Francisco city parks – the complete closure of the DPA at Lake Merced and reductions in the DPAs at McLaren Park and Bernal Hill. NAP says that dogs “may” impact the plants in natural areas, and therefore the closures are needed. The NAP refers to dogs as “nuisances”. NAP offers no proof, however, that any impacts actually occur or ever have occurred. Hard, scientifically rigorous proof must be provided if NAP is to kick people out of areas they have enjoyed for years. The way it’s set up now, NAP can take areas that have been legally off-leash for decades and, with the stroke of a NAP staffer’s pen (and no real proof), the off-leash is gone.

What makes this most concerning is that 80% of the total legal off-leash space in San Francisco city parks is located either within or adjacent to natural areas. The NAP plan divides natural areas into three “zones” – MA-1, MA-2, and MA-3. MA-1 areas contain the most sensitive habitat, MA-2 less so, and MA-3 areas are largely buffer zones between the natural area and the rest of the park. Because of the claimed sensitivity of MA-1 areas, off-leash dogs are not allowed in those parts of natural areas; in most, dogs would be banned entirely, even on-leash. MA-2 areas likely will allow leashed dogs, but not off-leash. Off-leash dogs are allowed in MA-3 areas. The 15% immediate closures of off-leash space once the NAP plan is implemented occurs because NAP claims parts of the DPAs in three parks are in areas it has zoned as MA-1 or MA-2.

The NAP Management Plan, approved by the Recreation and Park Commission in 2006, calls for expanding MA-1 areas within each natural area. That means areas that are initially zoned as MA-2 can become MA-1, and MA-3 areas may become MA-2 or MA-1. The NAP plan also calls for “monitoring” remaining DPAs in four parks – McLaren, Buena Vista, Bernal Hill, and the Golden Gate Park Oak Woodlands. If NAP claims dogs are impacting the natural areas in these parks, they will call for the closure of those DPAs. Should NAP claim that off-leash dogs in DPAs adjacent to (but not within) natural areas (Pine Lake and Corona Heights) are having any impact on those natural areas, NAP will call for the closure of all or part of those DPAs. The NAP plan, therefore, puts at risk of future closure 80% of the total off-leash space in San Francisco city parks. This is especially concerning because the Golden Gate National Recreation Area (GGNRA) released a proposed Dog Management Plan in early 2011 that would close 90% of the currently legal off-leash areas on its lands, including at Fort Funston, Ocean Beach, and Crissy Field. The loss of off-leash access in both the GGNRA and in city parks because of the NAP would be catastrophic for people with dogs.

5)    NAP uses a lot of herbicides, putting other park users and wildlife at risk
It’s important to keep in mind that NAP’s natural areas are not really “natural”. They require extensive human interference to continue. Nasty herbicides are often used to “kill” existing plants so “natives” can be planted, and to keep non-native plants from re-establishing themselves. These areas require extensive continued maintenance, with repeated weeding and planting, yet NAP plans allot only a few days of maintenance in most areas in a year. Without the needed maintenance, the native plants die and the natural areas look more like trashy wastelands than a thriving habitat.

The amount of herbicides NAP uses appears to be increasing. In 2009, NAP applied Roundup (or Aquamaster, or glyphosate) only 7 times. One year later, in 2010, they applied it 42 times. In 2009, NAP applied Garlon 16 times. In 2010, NAP applied Garlon 36 times. These chemicals, which can cause health problems, are repeatedly applied in places where children, seniors, and dogs walk, as in Glen Canyon. Indeed, Garlon may be more toxic for dogs than people because dogs’ kidneys cannot excrete the chemicals of which it is composed. Will the Garlon have a similar negative effect on coyotes who call Glen Canyon and other natural areas home? No one really knows the impact of the herbicides on the wildlife (raccoons, coyotes, possums, etc.) that are currently living in the natural areas.
In addition, there are indications NAP’s application of herbicides may violate the SF Department of the Environment’s rules regulating toxic pesticides (note that herbicides are considered a pesticide, so the two words will be used interchangeably in this paragraph). Posted notices that NAP is applying pesticides are frequently missing the required date and time of application. People seeing the notice don’t know whether the poisons were used and whether it’s safe to re-enter. NAP has applied pesticides that the Dept. of the Environment has not approved. For example, NAP applied Imazapyr at Pine Lake in 2009; it was not approved for use by the Dept. of the Environment until 2011. NAP has applied pesticides incorrectly. In November 2010, NAP posted that they were spraying Aquamaster near the shoreline of Lake Merced to kill ludwigia, an aquatic weed. However, Lake Merced is red-legged frog habitat, and Aquamaster is not supposed to be used within 60 feet of water bodies in red-legged frog habitat. NAP staff have been observed spraying Garlon without a respirator, as required by the Dept. of Environment.

For more on NAP’s misuse of pesticides see:
Save Mount Sutro Forest website

NAP’s reliance on herbicides is indicative of the fact that they don’t have enough staff to maintain the areas through weeding, so they rely on toxic herbicides. Because natural areas are surrounded by non-native plants that may be better adapted to today’s climate, the natural areas are not sustainable without intensive maintenance. Since that is not practical, they use chemicals to kill invasive plants.

6)    NAP plans to cut down 18,500 healthy trees because they are not “native”
The NAP Management Plan calls for the removal of 18,500 trees, with about 15,000 of those in Sharp Park in Pacifica. The rest will be cut down in other natural areas. For example, NAP plans to cut down 1,600 trees on Mt. Davidson. The number of trees cut down will actually be much more than this because the NAP Management Plan does not count trees less than 15 feet tall in its totals of tree removals. The US Forest Service survey of San Francisco’s urban forest reported that just over half (51.4%) of trees may not meet the 15-feet-tall requirement. NAP can cut as many of these trees as it wants.

The NAP Management Plan states that trees (at least those taller than 15 feet) removed will be replaced on a nearly one-to-one basis, although it acknowledges that the replacements may not be planted in the same area, or even in the same park. However, there are reasons to doubt this claim.

According to the Urban Forest Plan, officially adopted by the SF Urban Forestry Council in 2006, no forest existed in San Francisco prior to the European settlement of the city. There are still few native trees in SF. The US Forest Service survey of San Francisco’s urban forest found only two species of native trees in numbers large enough to be counted, and they made up only 2.2% of the total trees in SF (Coast live oak was 0.1%, California bay laurel was 2.1%).

The City maintains an official list of recommended species of trees for use by the Friends of the Urban Forest and the Department of Public Works. The most recent list categorizes 27 species of trees as “Species that perform well in many locations in San Francisco.” There is not a single native species on this list. Thirty-six tree species are categorized as “Species that perform well in certain locations with special considerations as noted.” Only one of these 36 species is considered a native tree – Coast live oak. Native trees don’t seem to do well in San Francisco.

In a few parks, NAP has planted native plants to replace non-natives that it cut down. Most of the trees did not survive. For example, NAP and its supporters cut down 25 young trees at Tank Hill about a decade ago. The few trees that NAP left standing had their limbs severely cut back to allow more sunlight to reach a newly planted native plant garden. Only four of the more than two dozen live oaks that were planted as replacements have survived. NAP may claim they will plant native trees to replace the healthy non-natives cut down, but most won’t survive and the character of the parks that once had healthy forests will change.

One main reason NAP wants to cut down trees is to facilitate the conversion of large portions of our parks from forests (which, as we saw earlier, were not present before the Europeans) to the kinds of scrub and grassland habitat that did exist in SF several hundred years ago. The US Forest Service Survey of San Francisco’s urban forest found that, in SF, trees cover only 11/9% of the land. Of the 14 major cities studied by the Forest Service, only Newark, New Jersey has a smaller tree canopy. The highest densities of trees are found in open spaces, such as parks. NAP’s plans will have significant impacts on urban forests in SF.

No one argues that diseased, dying, or dead trees should be cut down. These are public safety problems. However NAP’s plans will cut down thousands of healthy trees simply because they are not native.

For more on NAP’s plans for tree removal, go to:
Death of a Million Trees website

7)    NAP will close nearly one-quarter of all trails in natural areas
NAP plans to shut down 10.31 miles of trails in natural areas, while creating 1.1 miles of new trails to replace those closed. That means a net loss of 9.2 miles of trails in natural areas, a closure of nearly a quarter of all the trails in natural areas (23%). Most of the trails closed will be “social trails”, those created by people not RPD staff. People create social trails primarily because the “official” trails are not adequate for their needs. Either the official trails don’t go where people want to go, or they’re too steep, they’re too exposed, or there’s no “official” way to get from point A to point B and there’s a lot of people who want to do that. NAP wants to force people to move through natural areas in ways that people have made clear they do not want to move.

NAP claims that social trails cause erosion. While this may be true in some cases, the concern is that many of the trails will be closed primarily to limit the numbers of people who can walk through the natural area. When the University of California at Santa Cruz was first built, they put up buildings but didn’t pave any trails between them. They waited to see where people naturally went to get from one building to the next. When the social trails created by students became obvious, UCSC paved those trails, making them “official.” This approach – acknowledge that people will naturally choose certain ways to get from one point to another – would work in natural areas and would result in much less controversy. But NAP will not even consider it.

8)    The idea that natives are good and non-natives are bad is changing
The ideology behind the NAP says that native plants are inherently better than non-native plants. NAP supporters believe this with an almost religious zeal. For a time, ecological journals published articles consistent with this. There have always been critics however. Recently, those same journals have begun to publish more articles questioning the premise. Some examples:

”Opinion: The Invasive Ideology: Biologists and conservationists are too eager to demonize non-native species” by Matthew K. Chew and Scott P. Carroll, September 7, 2011, The Scientist

“A Friend to Aliens: Are Invasive Species Really a Big Threat?” Mark Davis, January 24, 2011, Scientific American(note: you need to subscribe to read the entire article). Davis published an article with the same viewpoint “Don’t Judge Species by Their Origins”, signed by 18 other scientists from around the country, that was published in the June 9, 2011 issue of Naturemagazine. It is not available for free online, but can be bought through various online sources.

The idea that non-native plants are bad and must be removed ignores evidence that the animals, birds, and bees in our parks today have adapted to the non-native plants that exist there. For example, Art Shapiro, a UC Davis butterfly expert, has said, “… the extensive adoption of introduced host plants has clearly been beneficial for a significant segment of the California butterfly fauna, including most of the familiar species of urban, suburban, and agricultural environments. Some of these species are now almost completely dependent on exotics and would disappear were weed control more effective than it currently is." (S.D. Graves and A.M. Shapiro, “Exotics as host plants of the California butterfly fauna,” Biological Conservation, 110 (2003), pp. 413-433) A classic example of this is the migrating Monarch butterflies who overwinter in eucalyptus trees in several locations on the coast of California.

Birds have also adapted to non-native trees and plants, nesting, perching, gleaning, and eating fruit and seeds from the non-natives. (C.E. Aslan and E. Rejmanek, “Avian use of introduced plants: Ornithologist records illustrate interspecific associations and research needs,” Ecological Applications, 20(4), 2010, pp, 1005-1020)

Non-native blackberry is found throughout San Francisco parks. It is a productive food source for birds and provides cover for wildlife including coyotes. NAP plans in parks such as Glen Canyon are to remove the thick non-native undergrowth, and replace it with more open areas where native plants (that need sunlight) can grow. When NAP removes the thick undergrowth in parks, however, the coyotes and other animals living there lose the protection it gives them. NAP doesn’t appear to care about its impact on these animals. Perhaps you have to be an endangered snake or frog for NAP to care whether you live or die because of its actions.

The native ideology that assumes native animals need native plants to survive underestimates both the ability of animals to adapt to changing conditions and the harm caused when non-native plants are eradicated.

Art Shapiro recently submitted a letter as public comment on the NAP EIR, in which he says: “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.

[Click here to read Art Shapiro’s critique of the NAP.] 

It’s not that the idea of preserving existing remnants of San Francisco’s natural heritage is a bad idea. It’s not. Our quibble is with the scale of the NAP and the planting of endangered species of plants in the middle of urban city parks. Our quibble is with NAP plans to cut down 18,500 healthy trees just because they are called “non-native.” Our quibble is with the overuse of herbicides in “natural” areas. Our quibble is with the loss of access for people to over one-quarter of the parkland in our densely packed city. Our quibble is with NAP plans to close roughly 15% of the legal off-leash space in city parks immediately, and to put at risk for closure 80% of the total legal off-leash space in city parks in the near future. Our quibble is NAP plans to close and not replace one-quarter of the total length of trails in natural areas. Our quibble is with the arrogant and secretive way NAP has been implemented over the years.

If you would like more information on problems and concerns with the Natural Areas Program, the following websites have a lot of good information:


This website has a lot of historical information, including photos and videos, about NAP and its problems.

Death of a Million Treeshttp://sutroforest.com/

This blog looks at the rationale for tree removal in projects throughout the Bay Area, questioning when trees are removed just for being non-native.

Save Mount Sutro Foresthttp://sutroforest.com/

This website is concerned with plans to cut down the eucalyptus forest on SF’s Mount Sutro. It has a lot of information about NAP use of herbicides and pesticides.