mission

It is in vain to dream of wildness distant from ourselves. There is none such. It is the bog in our brain and bowels, the primitive vigor of Native in us, that inspires that dream. Thoreau

Statement of Purpose

This paper is written in response to Part C, “Conservation and Restoration of Dunes” of the National Park Service's "Proposed Habitat Protection Closure." We examine the Park Service's premise that Fort Funston contains "significant native plant communities," as well as the historical record for the pre-European existence of such communities. We also examine the plans for "restoration" within the context of the other stated goals for the closure at Fort Funston and raise questions about the consistency of these goals.

We must turn to a part of San Francisco for which historical records exist -- Golden Gate Park -- to answer the question of what vegetation existed at Fort Funston prior to the planting of ice plant. It is well known that Golden Gate Park was a wasteland of sand dunes, largely devoid of vegetation (Photos 1, 2, and 3, attached) in 1865, when the Park was established. The landscape we see today was achieved in stages, starting with the planting of barley and lupine seed. Only beach grass, however, could survive the salty conditions near the ocean.[1] An elaborate and costly windbreak was built which also retarded the drifting sand over new plantings.[2] The new plantings were irrigated and fertilized. These were not natural, but manmade processes.

One might ask if these steps were needed to create the Park, but unnecessary to maintain it once established. This theory has been tested several times. In 1881, about 10 years after the beginning of the Park, there was a financial crisis in the City. Many trees died because they weren't being irrigated or thinned. More recently, in the 1970s and 80s, the cypress trees that provided a windbreak on the western edge of the park were dying their natural death, exposing the Park to the harsh ocean winds. Once again, the City's financial problems threatened the death of the park. The plantings in Golden Gate, even though well established, will continue to require irrigation and protection from the wind if they are to survive.

How do these observations apply to Fort Funston? Less is known about the vegetation at Fort Funston prior to the planting of ice plant by the military in the 1930s. Records of early Spanish explorers have survived. William Clark who analyzed these documents for his geography dissertation concludes, "In western San Francisco the grass-covered area near Laguna de la Merced merged on the north with low, barren sand hills, which reached almost to Point Lobos."[3] David Mayfield[4] created the map attached to this report (Map 1) of pre-European vegetation in the San Francisco area based on these documents. This map portrays the area of Fort Funston as "beach and dune," identical to the area now occupied by Golden Gate Park.

The author of this paper concludes that the existence of a "significant native plant community" at Fort Funston prior the planting of ice plant is questionable. Photos of the Fort prior to the 1930s do not exist. Pete Holloran, President of the local chapter of the California Native Plant Society, and an active collaborator with the Park Service, has acknowledged to the author that such photos do not exist. If such photos existed, he undoubtedly would have used them in his presentation to the local chapter of the California Native Plant Society about sand dune flora in San Francisco on July 6, 2000, which the author attended.

The Present: Native Plants at Fort Funston

The Park Service proposal for additional closures at Fort Funston states that there are "significant native plant communities," referring we suppose to the plantings in the 1991-1995 closures at the north end of the park. One might quibble with the description of less than 25 acres of plantings as "significant". They are undoubtedly significant to those volunteers who spent many hours planting them.

The visitor to Fort Funston is restricted to the trails through this "restored" area and is therefore unable to evaluate its success as a restoration. However, if one considers only those plantings that are visible from the trail, one must concede that the plants have survived a few years and have made a fairly complete ground cover. If these are the goals of the project, they appear to have been met, but only in the short run.

One cannot extrapolate, however, from this experience to the area of the new closure because the conditions are dissimilar. The plantings in the first closed area are largely on the southeast side of sand dunes -- the leeward side of the dunes -- which is protected from the prevailing northwest wind. Furthermore, there are large non-native trees (cypress and acacia) on the western edge of the plantings, which form a windbreak for the plantings. (Please recall the Park Service’s stated objective of ridding the Fort of its non-native trees, thereby eliminating those windbreaks.) Finally, these plantings have benefited from several consecutive years of above-average rainfall. Thus, the conditions for creating a new landscape were ideal in the earlier closures due to their protection from the wind and the unusually heavy rainfall.

Furthermore, the success of "revegetation" cannot be judged in such a short period of time. Pickart in a study of coastal dune restoration published by the California Native Plant Society observes that some planted species disappeared after five years, others after six years. Some planted species even survived ten years before dying out.[5]

[T]he time frame in which we formally evaluate success must be more than the one or two years frequently applied. All of the projects documented above underwent significant changes within a 5- to 10-year period.[6]

There are many reasons for the ultimate failure -- or "blowout" -- of a sand dune temporarily stabilized by vegetation, some of which probably are unknown. The most important reason is that sand dunes are inherently unstable: "Even if a dune has been fairly thoroughly colonized by plants, a strong wind may uproot enough of the sand-binding plants to cause breakdown of the whole dune."[7] Barbour in another California Native Plant Society publication states that the "high beach" plant cover -- out of reach of the waves -- is typically 20 to 50 percent or conversely 80 to 50 percent sand.[8]

The size of a restored area is another important factor in its long-term success: "The most effective conservation for species and habitats comes from protection of large areas, such as whole watersheds or ecosystems…because they are more self-sustaining than smaller preserves, which are easily disturbed."[9] Surely the most ardent advocate for "restoring" native plants at Fort Funston must concede that even the entire Fort would not meet this criterion, much less the relatively small closure at the north end of Fort Funston.

Small areas are subject to invasion by the exotic plants that surround them: "Even when these processes are protected, the very nature of dunes, which are prone to disturbance and characterized by openings in the vegetation, renders them constantly susceptible to invasion by non-native species."[10]

Buffer areas therefore are recommended[11] to protect "restored" areas from repeated invasion by non-native species, hence the plan to increase the size of the closure at Fort Funston. Buffer areas, by definition, are devoid of both exotic and native plants and are therefore bare, moving sand dunes. However, buffer areas do not ensure the success of "restoration." The naked sand, of which the buffer areas are composed, is in constant motion and always has the potential to bury the new plantings.

What the Park Service is not acknowledging is that, in a large, densely packed city, it is very difficult, if not impossible, to establish healthy, self-maintaining, “native” biological systems. The natural processes that created San Francisco’s native habitats have been so altered that what remains of these habitats is restricted to tiny “islands,” incapable of maintaining adequate genetic diversity to survive in the long-term. The attempts to establish “native” habitats in an urban environment are vulnerable to pollution, invasion of exotic species, and a myriad of other environmental problems, including changes in hydrology and fragmentation in the urban native habitat.

Restoration vs. Preservation

The author does not accept the premise that the plants that have been planted at Fort Funston are indeed native to that area. However, in order to consider the advantages and disadvantages of restoration, we will now accept for the sake of argument the premise that these plants are native to Fort Funston.

[Many] definitions of ecological restoration…invoke…ambiguous concepts of natural, pre-settlement, or pre-disturbance conditions. The use of these terms poses the immediate problem of defining what constitutes natural systems, given their continual change, the ubiquity of human intervention, and the historical ambiguity of community and ecosystem concepts. Even when goals can be agreed upon, the desired conditions may be unattainable because of limitations of scale, prior extinctions, ineradicable exotic species, or high cost.[12]

In an article by Gordy Slack, he quotes Joe Cannon, the project manager for a "native plant" restoration at the Presidio, in which Mr. Cannon acknowledges the guesswork involved in dune restoration here in San Francisco. Mr. Cannon even admitted that a “new” community is being “created,” not reproducing a “natural” one:

We're trying to approximate nature as best we can, but our hands are all over this piece of property. . . . We'll be creating a new community, not exactly reproducing a natural one. But given the constraints we work under, that's all we can do here.[13] (emphasis added)

The big challenge is to get a dynamic system . . . where you have not only these perennials that will become shrubs, but also all the annuals that need openings, where there are no shrubs. The processes in the past that created that--Aeolian sand movement and sand deposition form other unstabilized dunes--are no longer present here.[14] (emphasis added)

Ironically, Gordy Slack concludes in this article that the primary objective of this restoration in San Francisco was the opportunity for volunteer participation, which provides a "personal link to the community."[15] Restoration has not had this beneficial affect at Fort Funston where it has pitted several segments of the community against one another.

Pickart also evaluates three major coastal dune restorations in California: "…none could be called an unqualified success. None closely reflects the species composition or cover values found at nearby dunes."[16]

Pickart provides us with the following example of the risks of the guesswork involved in dune restoration: "At MacKerricher, the species of lupine planted … is not native to the region, and is now being controlled."[17] Horticulture, like all human endeavors, evolves, leaving past decisions in a backwater. European beach grass was introduced to California in 1869 to stabilize sand dunes in San Francisco.[18] One hundred years later it is considered an invasive exotic plant. One may wonder what is being planted now that will be considered a "bad" plant twenty years later. Certainly, one must agree that the proposed dune “restoration” is in violation of Congress’ mandate to preserve this recreation area in its “natural” setting.

Native Plants at Fort Funston: The Future

The Park Service’s "revegetation" plan for the new closure[19] states that: "buried ice plant will need to be bulldozed as it is too deep to be pulled by hand." The use of heavy equipment on the top of the bluffs seems to contradict other stated objectives for the closure, i.e., the stabilization of the cliffs from further erosion to protect bank swallow nests and the "geological resource" which the bluffs represent. The GGNRA proposal states that foot traffic destabilizes the bluffs. Clearly bulldozers are more destructive than people!

The military commissioned a study of the load capacity of the sand at Fort Funston in 1938. This study supports the assertion that disturbing, e.g., bulldozing, the sand will reduce its capacity to support weight:

First, the terrain at the site is fine dune sand, capable of supporting, in its undisturbed state, loads of up to 4 tons per square foot. However, after being disturbed, the sand loses most of its supporting strength and even after being compacted and allowed to stand for nearly a year, as in this instance, it does not regain much of its original capacity for supporting loads. [20]

The revegetation plan also states that, "Once the ice plant is removed, sand will transport more freely throughout the site. The sand transport patterns should be monitored to determine where key species and associated assemblages could establish." Thus, the plan is to encourage the movement of sand at Fort Funston. Once again, this goal seems to contradict the objective of stabilizing the bluffs. The moving dunes will change drainage patterns and will therefore contribute to erosion. Pickart corroborates:

"The susceptibility of a site to erosion, and the degree of impact resulting from erosion, will affect the choice of control method…Mechanical removal, resulting in large exposed areas, can trigger major sand movement."[21]

The continual movement of sand will also require the periodic use of heavy equipment to clear roads within the park, continuing the cycle of stress on the fragile bluffs. The convenience and comfort of the users of this urban park seem to be irrelevant to the Park Service. However, blowing sand is also an irritant to those who use the Fort daily regardless of the weather. When sand begins to drift across Skyline Boulevard, requiring its continual removal (as it does in sections of the Great Highway), the City of San Francisco may begin to express an interest in the actions of the Park Service.

The revegetation plan also states that the new area will be restored at the rate of one-half acre per year. Given the 12-acre proposed closure, this process would be complete within 24 years. The GGNRA proposal for closure states that "the rate of natural bluff erosion [is] one foot per year." Do the math! Much of this area will have collapsed onto the beach before it is "restored." Meanwhile, one generation of park users will be deprived of the use of this area. These do not seem cost-effective choices to the author.

There are significant areas of preserved and/or restored dunes in Northern California:[22]

It does not seem to be in our collective best interests to take the risks inherent in dune restoration at Fort Funston, given that much larger dune communities exist elsewhere, thereby ensuring the preservation of this type of habitat. The disadvantages of dune restoration at Fort Funston far exceed the advantages.

The Park Service refers us to the mission of the Park Service to justify the proposed closures:

[W]hich purpose is to conserve the scenery and natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations."[23]

· promoting the erosion and therefore the destruction of the cliffs in which bank swallows nest

Furthermore, the proposed closure completely ignores another important statutory mandate in the Organic Act that the enabling legislation for each park must be followed.

In horticulture, as in other realms of human activity, beauty is in the eye of the beholder. Ice plant, while presently unpopular with the horticulture community, was recently considered by the US Postal Service to be an appropriate plant to represent California's coastal habitat. Although the California Native Plant Society objected to this choice, the United States Postal Service said that "[S]o far, most people are thrilled' by the new stamp. 'They like the ice plant.'" (Figure 1, attached.)

Barbour, Micheal, Bruce Pavlik, Frank Drysdale, and Susan Lindstrom, California's changing Landscapes, Diversity and Conservation of California Vegetation, Sacramento: California Native Plant Society, 1993.

Clark, William Carey, "Vegetation Cover of the San Francisco Bay Region in the Early Spanish Period", Geography Master's thesis (UCB), 1952.

Clary, Raymond H., The Making of Golden Gate Park, The Early Years: 1865-1906, San Francisco: California Living Books, 1980.

Faber, Phyllis M., California's Wild Gardens, A Living Legacy, Sacramento: California Native Plant Society, 1997.

GGNRA, "Bank Swallow Permanent Closure Revegetation Assemblages," #4259, February 1999.

Haner, Norman W. (Associate Engineer), "Development of the Casemate Foundations by Cement-Stabilization Method at Battery Richmond P David, Ft. Funston, California," December 6, 1938.

Howell, John Thomas, Peter H. Raven, Peter Rubtzoff, A Flora of San Francisco California, San Francisco: University of San Francisco, 1958.

Kozloff, Eugene and Linda Beidleman, Plants of San Francisco Bay Region, Mendocino to Monterey, Sagen Press, 1995.

Mayfield, David W., "Ecology of a Discovered Land", Pacific Discovery, V33 (1980), no 5.

Pickart, Andrea and John Sawyer, Ecology and Restoration of Northern California Coastal Dunes, Sacramento: California Native Plant Society, 1998.

Slack, Gordy, "Restoring (Dune) Community Values", Pacific Discovery, Spring 1997

[1] Raymond H. Clary, The Making of Golden Gate Park, The Early Years: 1865-1906 (San Francisco: California Living Books, 1980), p. 14.

[2] Ibid., p. 19.

[3] William Carey Clark, "Vegetation Cover of the San Francisco Bay Region in the Early Spanish Period", Geography Master's thesis (UCB), 1952, p. 125.

[4]David W. Mayfield, "Ecology of a Discovered Land", Pacific Discovery, V33 (1980), no 5.

[5] Andrea Pickart and John Sawyer, Ecology and Restoration of Northern California Coastal Dunes (Sacramento: California Native Plant Society, 1998), p. 106.

[6] Ibid., p. 120.

[7] Eugene Kozloff and Linda Beidleman, Plants of San Francisco Bay Region, Mendocino to Monterey (Sagen Press, 1995). P. 19.

[8] Micheal Barbour, Bruce Pavlik, Frank Drysdale, and Susan Lindstrom, California's changing Landscapes, Diversity and Conservation of California Vegetation (Sacramento: California Native Plant Society, 1993), p. 29.

[9] Phyllis M. Faber, California's Wild Gardens, A Living Legacy (Sacramento: California Native Plant Society, 1997), p. 35.

[10] Pickart, p. 122.

[11] Ibid., p. 92.

[12] Pickart, p. 55.

[13] Gordy Slack, "Restoring (Dune) Community Values", Pacific Discovery, Spring 1997, p. 7.

[14] Ibid.

[15] Ibid., p. 6.

[16] Pickart, p. 120.

[17] Ibid.

[18] Faber, p. 24.

[19] Assemblages GGNRA, "Bank Swallow permanent Closure Revegetation," #4259, February 1999.

[20] Norman W. Haner (Associate Engineer), "Development of the Casemate Foundations by Cement-Stabilization Method at Battery Richmond P David, Ft. Funston, California," December 6, 1938, p. 1.

[21] Pickart, p. 92.

[22] Faber.

[23] Organic Act, Section 1. (emphasis added)