12-Acre
Closure Book
1:FFDW Org
2:Enabling
3:Survey
6:Erosion
Editor: fortfunston@hotmail.com
Webmaster: Wedosites@mail.com
A Point-By-Point Rebuttal of the Bank Swallow Protection Justification
for the Proposed Permanent Twelve-Acre
Closure At Fort Funston
Assertion:
One
of the many unique features of Fort Funston is that it supports one of the last
two remaining coastal cliff-dwelling colonies in California for the bank swallow
(Riparia riparia).
Rebuttal:
As its scientific name">
12-Acre Closure
Book 1:FFDW
Org 2:Enabling 3:Survey 6:Erosion Editor:
fortfunston@hotmail.com Webmaster:
Wedosites@mail.com
A Point-By-Point Rebuttal of the Bank
Swallow Protection Justification for the Proposed Permanent Twelve-Acre
Closure At Fort Funston Assertion: One
of the many unique features of Fort Funston is that it supports one of the last
two remaining coastal cliff-dwelling colonies in California for the bank swallow
(Riparia riparia). Rebuttal: As its scientific name, Riparia
riparia, implies, the Bank Swallow is largely found in riparian ecosystems,
particularly rivers in the larger lowland valleys of northern California. The
major breeding population is confined to the Sacramento and Feather rivers and
their major tributaries north of their confluence where an estimated 75% of
California’s breeding population was found in 1987 (Laymon et al. 1988). (Barrett
A. Garrison, California Partners in Flight Riparian Bird Conservation Plan) Assertion: Once
more abundant throughout the state, their numbers have declined so dramatically
that in 1989 the State of California listed the bank swallow as threatened under
the California Endangered Species Act. Rebuttal: Statewide,
bank swallow populations are again on a dramatic climb. Bank swallow populations in
the Sacramento River area: 1998 - 4,990 1999 - 8,210 2000 - 9210 (Robert
C. Hight, Department of Fish & Game’s Annual Report on the Status of the
Threatened Bank Swallow; Ronald W. Schlorff, 2000 Bank Swallow Population
Survey, Sacramento River) The
population decline in the Fort Funston colony may be the result of any number of
factors, including a recent trend to inland areas seen among coastal colonies on
the East Coast: Maryland, Bank Swallow
populations appear stable, but the breeding distribution has shifted from the
Chesapeake Bay shoreline to gravel pits and riverbanks in the interior part of
the state (Saunders and Saunders 1996). Shifting distribution away from coastal
locations to inland breeding sites has also been noted in New York (Andrle and
Carroll 1988) and Connecticut (Bevier 1994). (Barrett
A. Garrison, California Partners in Flight Riparian Bird Conservation Plan) No
banding has been done of swallows in the Fort Funston colony, so it is unknown
whether any of them have shifted inland to their preferred habitat along river
banks. Assertion: Its
preferred habitat --sheer sandy cliffs or banks --has been altered throughout
its range by development, eliminated by river channel stabilization, and
disrupted by increased recreational pressures. Rebuttal: California
Department of Fish & Game publications repeatedly and emphatically state: The most significant
fragmentation threat is the direct loss of suitable colony sites through bank
protection and flood control projects. (Barrett
A. Garrison, California Partners in Flight Riparian Bird Conservation Plan) The most significant
management issue affecting the Bank Swallow in California is the direct loss of
suitable colony sites through bank protection and flood control projects,
particularly on the Sacramento River (Garrison et al. 1987). (Ibid) ... Remsen (1978) stated that
the channelization of rivers is the most ”insidious” long-term threat to the
bank swallows... (Ronald
W. Schlorff, Monitoring Bank Swallow Populations on the Sacramento River: A
Decade of Decline) “Recreational
pressures” are not mentioned in Fish & Game reports on the bank swallow,
with the exception of the following: Bank undercutting from boat
wakes or fluctuating water levels has the potential to cause collapse of nesting
banks. (Barrett
A. Garrison, California Partners in Flight Riparian Bird Conservation Plan) Recreational
land use by dog-walkers and other pedestrians is not mentioned at all.
In fact, the experts state: Bank Swallows appear
relatively insensitive to moderate levels of human-induced disturbance. In
California, colonies occur on banks under actively farmed irrigated row crops
and orchards. Several colonies occur in coastal locations at public seashores
where human activity can be substantial. (Ibid;
emphasis added) and, A wide variety of land uses
occur around Bank Swallow colonies including hydroelectric power generation,
irrigation water conveyance, recreational boating, commercial agriculture, vehicular
and pedestrian traffic, and domestic livestock grazing. These land uses
appear relatively benign as long as the integrity of the nesting bank remains. (Ibid;
emphasis added) Ron Schlorff, the Fish & Game biologist who
specializes in bank swallows, was asked by Park Service staff to give an opinion
that recreational pressures were causing harm to the bank swallow colony at Fort
Funston. He would not do so. Assertion: The
Fort Funston colony is particularly unique in that it is one of only two
remaining colonies in coastal bluffs in California, the other being at Año
Nuevo State Park in San Mateo County. Bank swallow habitat at Año Nuevo remains
closed to visitor access. Rebuttal: Fort
Funston is a 220-acre parcel of land ceded to the federal government in
1975 -- after several decades of modification and use by the military and
another fourteen years as a San Francisco city park -- for the express purpose
of providing recreational open space to citizens of San Francisco. Ano
Nuevo is 4,000-acre parcel, purchased by the state government in 1958--in
relatively pristine condition--with the express intent of establishing a Nature
Reserve. Policies
of a State Reserve are defined as follows: The protection of ecological,
scientific, natural, and cultural values is of primary importance in areas
identified as State Reserves and Natural and Cultural Preserves. The general
plan developed for such areas shall recognize the importance of the resource and
the necessity for protection. The Director may provide limitations on management
and use to safeguard the identified resources.... Restrictions of public access
for periods longer than one year shall be established only upon approval of the
commission. (State
Park & Recreation Commission Statements of Policy, 1994) The
enabling legislation, which is addressed in greater detail in another section of
this Opposition, governing the establishment of the GGNRA mandates that the park
shall: 1.
Provide for maintenance of needed recreational open space, 2.
Utilize resources in a manner which will provide for recreation and
educational opportunities, in a manner consistent with sound principles of land
use planning and management, 3.
Preserve the recreation area, as far as possible, in its natural setting, 4.
Protect the recreation area from development and uses which would destroy
the scenic beauty and natural character of the area. One
of the bank swallow nesting sites at Ano Nuevo is located within the elephant
seal area that has varying restriction policies over the course of the year to
protect seals and visitors during mating and molting seasons.
According to rangers contacted there, the restriction of the area is
not for the swallows’ benefit. The
other nesting site is in the face of a high cliff which is not, and never has
been, accessible to the public, according to the park rangers. No special
restrictions are in effect in this area. Assertion: Mortality
of bank swallows results from a number of causes including disease, parasites
and predation. Destruction of nest sites, including collapsed burrows due to
natural or human-caused sloughing of banks, appears to be the most significant
direct cause of mortality (Recovery Plan, Bank Swallow (Riparia riparia), State
of California Department of Fish and Game 1992). Rebuttal: Walking
on the bluff-tops is not identified by Ronald Schlorff, the author of the
Recovery Plan, as a cause of sloughing: Although it appears to be a
natural event, sloughing can result from high stream flows in summer caused by
regulated water flows from Shasta Dam, and occasionally by recreational boaters
whose wakes cause wave action that weakens banks and causes them to fall into
the river. (Ronald
W. Schlorff, Monitoring Bank Swallow Populations on the Sacramento River: A
Decade of Decline) Schlorff
also states in this report, published in 1997, that: Remsen (1978) reported that
reasons for the species’ decline are unknown for coastal populations where
breeding cliffs appear to be intact. He
also cautions: Any significant level of
continued rip-rapping of stream bank in conjunction with flood and erosion
control projects may represent the greatest human-caused threat to banks swallow
populations... Assertion: The
Recovery Plan recommends a habitat preservation strategy through protection of
lands known to support active colonies or with suitable habitat features for
future colony establishment. It
also acknowledges that isolated colonies, like Fort Funston, are at particularly
high risk of extinction or severe population decline. Additionally, the State of
California Historic and Current Status of the Bank Swallow in California report
(1988) recommended that nesting colonies be protected from harassment and human
disturbance. Rebuttal:
The
Recovery Plan recommends protecting and enhancing vertical banks and bluffs and
limiting human disturbance during the nesting season. We have no quarrel
with those recommendations. The
plan does not recommend, or even suggest, cordoning off large areas near the
nesting site to plant native plants. In fact, Fish & Game experts state
that: Bank Swallow nests, because of
their placement in vertical faces of banks and bluffs, are generally devoid of
vegetation around the nest burrow. Vegetation on the top of the bank or bluff,
however, is extremely variable depending on colony location. This variation
occurs in almost all measures including vegetative cover, height, and species
composition. There appears to be no selection for specific vegetation
communities at most nest sites as selection is directed at the nesting bank or
bluff itself where soil type, height, and slope are the primary factors
determining whether the site will be used for nesting. (Barrett
A. Garrison, California Partners in Flight Riparian Bird Conservation Plan) The
assertion (not listed here but often used to justify the closure) that native
plants will provide more suitable diet of insects to the birds has no scientific
basis. In fact, experts say: The diverse dietary habits of
the Bank Swallow do not appear to influence its occurrence or viability. Bank
Swallows tend to forage in areas that support large amounts of insect biomass,
and reproductive success does not appear to be food limited because colonies are
generally located in areas with sufficient insect resources. (Ibid) Ron Schlorff, the Fish & Game biologist, has stated
that only the portion of the cliff in which the bank swallows dig their burrows,
needs to be protected while the birds are nesting.
Closing adjacent cliffs and inward land is not necessary to protect the
nesting birds. A swallow biologist
at Syracuse University has confirmed Mr. Schlorff’s opinion. Assertion: The
Fort Funston colony has been recorded since at least 1905. Records indicate that the colony fluctuated in size and
location overtime. A 1961 study of
the Fort Funston colony documented a total of 84 burrows in 1954, 114 in 1955,
157 in 1956, and 196 in 1960. GGNRA staff counted at least 229 burrows in 1982
and more than 550 in 1989. In 1987
the California Department of Fish and Game documented 417 burrows at Fort
Funston. Approximately 40 to 60 percent of burrows are actively used for nesting
in a given year. Between
1992 and 1995, NPS implemented other protection and restoration measures for the
Fort Funston colony, including a year-round closure of approximately 23-acres in
the northern most portion of Fort Funston to off-trail recreational use. Rebuttal: These
historic numbers are, for the most part, far lower than the population numbers
recorded in the more recent years (see attached chart) prior to the closure and
revegetation of the original 23-acre bank swallow protection zone. This
indicates that the birds thrived from the time the park was opened to public
recreational use up to the point where the NPS intervened, even though riparian
populations in the state were dropping dramatically over that time. The
colony’s precipitous decline since protections were put in place and its shift
to the new site in an area of vigorous recreational use has not been adequately
studied or explained. Assertion: In
1993, GGNRA established an annual monitoring program to track the abundance and
distribution of bank swallows at Fort Funston. Trained personnel conduct weekly
surveys during nesting season (from mid-April through early August). From 1993
to 1996, burrow numbers were over 500 each year. The number declined
dramatically to only 140 in 1998 and 148 in 1999 when the colony shifted to the
current proposed closure area (then unprotected). This event coincided with the
storms during the winter of 1997 that caused significant cliff retreat and
slumping. Rebuttal: This
“cliff retreat and slumping,” was among the phenomena the ice plant was put
in place to prevent, along with scouring, blowing sand. In any case, these
events, which the NPS says occurred over the winter, would not likely have
affected the birds, because: Generally, new burrows are
generally dug each year especially if the bank or cliff face used the previous
year collapsed from erosion or man’s workings and no old burrows remain
(Petersen 1955, Hickman 1979, Cramp 1988). (Barrett
A. Garrison, California Partners in Flight Riparian Bird Conservation Plan) The
experts only note sloughing and slumping as a problem for bank swallow
populations if it occurs during the nesting season. Otherwise, say the
experts: Without some erosion, human-caused
or otherwise, the vertical faces quickly collapse and break down thereby
becoming unsuitable for nesting. (Ibid) In
fact: Local breeding populations benefit
greatly from annual erosion and maintenance of the suitability of banks, cliffs,
bluffs, and quarries where nesting colonies occur. Human activities creating
sand and gravel quarries, road cuts, and other vertical banks in friable soils
have directly benefited the Bank Swallow by increasing its distribution in
Canada (Erskine 1979). … Maintenance of suitable habitat is ensured if actions
creating vertical faces such as moving water or sand and gravel extraction
activities continue. (Ibid) Assertion: In
an attempt to protect the colony from recreational disturbance of nesting
habitat, protective fencing was installed along the bluff top in 1998 with
interpretive signs to encourage visitors to reduce impacts on the nesting
colony. These efforts proved unsuccessful in preventing recreational disturbance
to the colony. Rebuttal: No
significant outreach was conducted among park users regarding these protective
measures. The help of dog owners and other park user groups in getting the word
out and encouraging compliance was not solicited. Despite the alleged
“recreational disturbance,” the colony’s population increased slightly the
following year. Ron Schlorff, the Fish & Game biologist, has faulted
the Park Service for not adequately or sufficiently attempting to educate the
public about the bank swallows. There
is no support for the claim that the bluff-top fences were unsuccessful in
preventing disturbance. What type
of disturbance was allowed to occur? When?
From above the cliff or below? What
documentation supports these alleged disturbances?
This is a vague and general allegation, with no known factual basis. Assertion: NPS
observed increased erosion due to visitor use adjacent to the fence line.
Moreover, the rate of natural bluff erosion, approximately one foot per year,
and the constant deposition and erosion of sand material caused the fence to
collapse and fail within just a few months. Fence posts near the bluff face also
provided advantages to swallow predators that perch on the posts with a view to
the swallow nests. Rebuttal: Moving
the fence line a short distance in from the bluff edge would rectify all of
these issues. The fences could be maintained every March after the worst of the
storms and before the bank swallows return.
None of these issues constitutes justification for the proposed
twelve-acre closure. Assertion: A
wide array of disturbances to the swallows at Fort Funston have been observed
and recorded during monitoring, and/or photo-documented. While bank swallows are
known to be quite tolerant to some disturbance, few colonies are subjected to
the intense recreational pressure at Fort Funston.
Documented disturbance events at Fort Funston include: cliff-climbing by
people and dogs; rescue operations of people and dogs stuck on the cliff face;
people and dogs on the bluff edge or in close proximity to active burrows;
graffiti carving in the cliff face; aircraft and hang-glider over-flights; and
discharge of fireworks within the colony. Rebuttal:
Of
these six disturbances, four will not be addressed at all by the proposed
closure. The other two--people and dogs near the bluff edge or being rescued
from the cliff face--argue only for a fence along the bluff line. As set forth in other sections of this Opposition, only two
rescues have occurred in the area of the proposed closure, and it is not known
if this rescue was in the area of the burrows. Assertion: The
potential impacts from such disturbances include: interruption of normal
breeding activity, such as feeding of young; crushing of burrows near the top of
the cliff face (nests can be located within a foot of the bluff top); casting
shadows that may be perceived as predators; accelerating human-caused bluff
erosion; and active sloughing and land-slides that may block or crush burrows
and the young inside. Rebuttal: No
actual, recorded impacts are noted--only “potential” impacts. The assertion
that humans cast shadows that “may be perceived as predators” is unsupported
and actually defies the laws of physics: When the morning sun is in the
eastern sky, a person on the cliff casts a shadow westward over the ocean, but
not on the cliff face. When the afternoon sun is in the west, the shadow cast by
a person on the bluff tops goes east, away from the cliffs. At no time can a
person cast a shadow on the nests. (Linda
Shore, physicist and doctor of science education, in a speech to the Citizens
Advisory Commission of the GGNRA, August 29, 2000) All
other stated potential impacts can be prevented with a single fence along the
bluff line. Assertion: The
NPS has determined that the designated trails at Fort Funston provide adequate
access to the park area and that continued use of unauthorized
"social" trails within the project footprint has adverse impacts on
park resources, including the bank swallow. Rebuttal: This
assertion ignores the primary recreational uses of the area, those being
off-leash dog walking, dune-play, and viewing of the ocean and sunsets from near
the bluff-edge, none of which are adequately accommodated by the designated
trails. In addition, the proposed
closure area cuts off a major beach access route and forces users to reach the
beach via a less accessible route that is impassable during high tide. The
claim that use of so-called “social” trails damages park resources is vague
and unsupported. What resources? How are they being damaged? How do they affect
the bank swallow? As stated earlier, we know from the published reports by Fish
& Game experts that the presence of native flora and fauna offers no benefit
to the bank swallow and that the presence of human beings, livestock, and even
vehicles bothers the birds very little, so long as their actual burrows are not
disturbed. Due to extensive alteration by the military, which occupied the Fort
for decades, there is very little in the way of “natural resources” extant
there. In fact man had significantly altered the ecology of the Fort Funston
area long before the bank swallows arrived in 1905. Conclusion: