City of Oakland
Agenda Report

To: Public Works Committee
Public Safety Committee
From: Councilmember Jean Quan
Date: February 22, 2005



The City Council is requested to approve a limited exemption to the Integrated Pest Management (IPM) policy to allow use of specific herbicides to abate certain non-native, highly flammable trees and shrubs that create a fuel load for potential fires on City -owned property in the Wildfire Prevention Assessment District and other city properties identified by the Fire Marshall as areas of high fire hazard. If approved, vegetation management staff in the City of Oakland and contractors hired to work on vegetation management projects on City-owned property within the Wildfire Prevention Assessment District and the few City-owned properties outside of the Wildfire Prevention Assessment District with similar topography and fuel load risks, will be allowed the limited use of the herbicides glyphosate and triclopyr on certain highly flammable non-native plants.

The proposed policy further requires that:

* Preference will be given to available non-pesticide alternatives, where feasible, before considering the use of herbicides on city property. Glysophate and triclopyr will only be used when conditions and best management practices (BMPs) demonstrate that a chemical treatment would be the most effective approach;
* Herbicides must be directly hand applied or painted on to the cambium layer (actively growing surface) of freshly cut stumps;
* Staff must comply with requirements established in the City's IPM policy such as public notification, dye markers, buffer zones, monthly reporting, etc.;
* Staff must comply with state and federal requirements for dispensing herbicides and permitting requirements for herbicide use;
* OFD must produce a yearly report on herbicide use as part of a strategic vegetation management plan;
* The current ban on the use of herbicides in the City's playgrounds, picnic, ball fields, and other high public use areas will remain in effect.


Successful implementation of this policy will require the recruitment of a consultant with technical expertise in Integrated Pest Management (specifically the use of herbicides) and vegetation management in the urban/wild land interface so that the requirements for planning and monitoring the use of herbicides as part of an overall vegetation management plan may be implemented. Initial research shows that a consultant would run approximately $124,000 the first year, and less in subsequent years. For comparison, the cost of hiring a full-time employee at the level of a Public Works Supervisor Level II would run $123,548 including benefits. It is anticipated that the position would be funded through the Wildfire Prevention Assessment District.

The long-term fiscal impact is unknown at this time. However, the limited use of herbicides to efficiently control the proliferation of highly flammable tree and shrub materials will save labor costs over time for the Wildfire Prevention Assessment District that could be utilized for increased fire education and prevention efforts. The experience of neighboring entities has shown that when herbicides are appropriately used, the population of the invasive plants is reduced substantially over a two- to three-year period, reducing not only the continuing need for herbicide applications in the target area, but also the necessity of having labor forces do major maintenance in the area.


Integrated Pest Management (IPM) is a recognized pest management strategy that focuses on long term prevention of pests with minimum impact on human health, the environment and non--target organisms. A pest management strategy may include one or more of the following elements: no controls; physical/mechanical controls (e.g. hand labor, soil tilling, mowing); biological controls (animal grazing); chemical controls (preferably low toxicity materials such as soaps and oils) and other controls (e.g. mulching, alternative vegetation). Preference is typically given to available non-pesticide alternatives, where feasible, before considering the use of pesticides.

In May 1995, the City Council approved the implementation of a comprehensive Integrated Pest Management policy that updated the City's initial IPM policy adopted in 1981. The new policy reduced pesticide use, required public notification of pesticide use application, established coordination between departments responsible for pest management and required an annual report on usage and implementation of the policy. In December 1997, the City Council further reduced the use of pesticides through Resolution 73968 which banned the use of pesticides on City property with only a few specific exemptions.

Following various reports to the Council from the Office of Parks and Recreation expressing concern about limited staff resources and the blighted condition of landscaped street medians, an exemption was approved in January of 2001 to allow limited herbicide use on landscaped medians to control weeds and other undesirable plants.


The Fire Department is responsible for vegetation management on City-owned property in the Wildfire Prevention Assessment District. The District is a high fire hazard urban/wild land interface that stretches from the Contra Costa County line on the East, the Berkeley border on the North, the San Leandro border on the South, and slightly beyond Highway 13 and 580 on the West, dipping down into the Dimond Park/Dimond Canyon area. In 1991, this area experienced one of the worst urban fires in California history. Its continued vulnerability requires ongoing preventive measures to protect life and property. In 2004, a special assessment district was established to fund vegetation management and education activities in the Wildfire Prevention Assessment District.

In November 2004, the Wildfire Prevention Assessment District Advisory Council approved a Ten Year Goal to establish and implement a fuel management plan that is strategic, cost-effective, sustainable and environmentally sensitive. It also identified six criteria for identifying priorities for actions within the Wildfire Prevention Assessment District:
* Reduce the sources of ignition
* Maintain access (fire suppression) and egress (evacuation) routes
* Develop fire prevention friendly policies
* Reduce the spread of fires from wild lands
* Support/leverage efforts by home/property owners
* Develop a year-round seasonal strategy

Allowing the limited use of herbicides as one of an array of approaches under IPM best management practices (BMPs) is specifically identified as a necessity for the Wildfire Prevention Assessment District to achieve these objectives.

On January 27, 2005, the Wildfire Prevention Assessment District Advisory Council unanimously voted to endorse the proposed policy for limited use of herbicides within the Wildfire Prevention Assessment District and similarly identified city-owned properties.

Non-Native Plant and Tree Species

The following list of non-native, highly-flammable plant species are the targeted focus of the Oakland Fire Department's vegetation management efforts within the Wildfire Prevention District:

ï all species of Eucalyptus (E. globulus (blue gum), red gum, and others)
ï all species of Acacia (A.dealbata (silver wattle) and A. melanoxylon (blackwood acacia) and others); all non-native species of Prunus (plum and cherry)
ï all species of Ulmus (elm)
ï Ilex aquifolium (Holly)
ï Maytenus boaria (Mayten)
ï all species of Cotoneaster (C. franchetii, C. lacteus, C. pannosa)
ï all species of broom and gorse: Cytisus scoparius (Scotch broom), Genista monspessulana (French broom), Spartium junceum (Spanish broom) and Ulex europea (gorse)
ï Crataegus monogyna (Italian hawthorn)
ï non-native species of blackberry: Rubus discolor (Himalayan blackberry) and R. ulmifolius (thornless blackberry)
ï Cortaderia selloana and C. jubata (pampas grass, jubata grass),

These plants were brought here from all over the world and have few natural enemies to deter their growth in this environment. Eucalyptus, in particular, is highly flammable and proved to be the primary fuel load for the 1991 Oakland Hills fire. Acacias create dense thickets with deep fuel beds of seed pods and downed wood. Other plants represent less immediate fire danger, but resprout vigorously when cut, creating repeated management expenses in fuel breaks and on roadsides. Vegetation management staff in the Wildfire Prevention Assessment District work to control fuel beds and ladder fuels created by these non-native, invasive plants throughout approximately 1000 acres of city-owned open space, canyon hill parcels, roadsides, public streets, paths, firebreaks and escape routes. Left unchecked, non-native trees and shrubs threaten native plant species and wildlife habitat, and create a continuous fuel bed for potential fires that could cause the loss of life and significant property damage.

The exemption for limited herbicide use will be exclusively focused on the plant and tree species listed above. The plants on this list have been identified by OFD vegetation management staff working in the District. The list of non-native plants may expand as new species threatening wildfire prevention efforts are identified. Any new species found problematic in the District will be reported in an annual report to the Wildfire Prevention Assessment District Advisory Board and the City Council.

Grazing, Hand Pulling and Mechanical Cutting Methods

Under the current IPM policy, staff must control and eradicate the growth of non-native plants solely through the use of grazing, hand pulling and mechanical cutting methods. Integrated Pest Management specialists, particularly among the public agencies working within the Wildfire Prevention Assessment District and adjacent to it, have successfully integrated limited herbicide use into their vegetation management practices. All of them follow the IPM guideline of using herbicides only when necessary. Consequently,
herbicides are a small component of their IPM program (from 2 to 6 gallons of concentrate per year), and they have seen decreases in the amounts they have used over time.

Grazing, hand pulling and mechanical means of weed control are not always effective in controlling the spread of invasive non-native vegetation. Each method has limitations in the rugged topography in much of the Wildfire Prevention Assessment District.

Eradicating eucalyptus trees has been particularly challenging for OFD and City staff. When mechanically cut, the eucalyptus tree resprouts quickly and profusely, requiring cutting several times a year to fully abate growth or simply control. Repeatedly returning to a particular canyon to re-cut new growth is costly and inefficient. Likewise, a repeated trip into an area where native plant growth may be disturbed is not a good practice.

Goat grazing is most effective at removing grass and at reducing the overall fuel load in shrublands. Most of the woody invasive shrubs resprout after goat grazing, including broom. Hand pulling is usually required for long-term control. This method is labor intensive and very costly. Hand pulling may also contribute to erosion as dislodging roots from a large area may cause the soil to become unstable and slide.

The most efficient approach to managing nuisance plants is a combination of methods, based upon plant species, location, topography, employee safety and economic considerations. This analysis is the key component of a working Integrated Pest Management program.

IPM Requirements

Herbicides would only be used when necessary, as a part of the annual WPAD vegetation management plan, and according to strict requirements as outlined in the City's Integrated Pest Management procedures manual, other local, state and federal regulations and this resolution.

The limited use of herbicides would be identified within the Wildfire Prevention Assessment District's annual plan for use on identified plants in specific locations, using BMPs garnered from other public agencies with vegetation management responsibilities. These include the East Bay Regional Park District, the University of California, and East Bay Municipal Utility District, and other public agencies in the greater Bay Area. The California Invasive Plant Council and The Nature Conservancy, and other conservation groups provide valuable research on their web sites BMPs from the State Department of Fish and Game and the U.S. Fish and Wildlife Service will be adopted for areas containing endangered species. City staff will consult with and obtain necessary permits from agencies such as the Alameda County Clean Water Program or the City's Environmental Services Creek Protection Program, prior to applying pesticides in endangered species habitats.

Standards already established in the City's current IPM policy will remain in force. These include requirements for:
* Public notification;
* Signage;
* Dye markers to indicate exactly where herbicide was applied;
* Monthly reporting;
* Buffer zones;
* Compliance with all state and federal regulations for applying and dispensing herbicides, including training or certification of all city staff and contractors who handle herbicides;
* Monitoring areas where herbicides have been applied.

The most important component of the IPM policy is the annual reporting requirement that details when and where herbicides have been applied in the past year and will be applied in the coming year, what herbicide was used, quantities used, and the success rate of the application, if possible. In addition to the mandated reporting requirements, the proposed exemption for the Wildfire Prevention Assessment District calls for the Fire Department to develop a vegetation management plan each year that is reviewed and approved by the Wildfire Prevention Assessment District Board and the City Council. The Wildfire Prevention Assessment District Board is a citizen advisory body responsible for developing a ten-year strategic plan for fuel reduction in the District. The vegetation management plan will allow staff to yearly map out the work required to meet the goals of the strategic plan. The plan will also contain a report detailing the use of herbicide over the past year, it's impact on fuel reduction efforts and report new, non-native plants threatening the District The success of the proposed policy can be measured by a reduction in the use of herbicides each year and the resurgence of native plant species that are more fire resistant and provide forage and habitat for wildlife.

Herbicide Formulations and Application

The exemption will be limited to the use of two herbicides -- glysophate (in formulations such as Roundup or Rodeo) and triclopyr (in formulations such as Garlon and Pathfinder). These are federally- and California-registered pesticides for the control of woody plant species and broad leaf plants in right of ways, forests, open space parks, ditch banks and maintenance of wildlife corridors. The U.S. Environmental Protection Agency categorically ranks herbicide toxicity on a scale of one to four as follows: Category One

highly toxic; Category Two -- moderately toxic; Category Three -- Slightly Toxic; Category Four -- Not Acutely Toxic. Both glysophate and triclopyr have received the lowest ranking for toxicity or a Category Four. In accordance with the city's IPM policy and BMPs, the choice of formulation for each type of application will be determined based on environmental factors as well as the product's capabilities.

When herbicides are needed for vegetation control, best management practices call for direct application to the plant or tree either by hand painting or hand applying the herbicide directly on to the cambium of the freshly cut tree or plant stump. When glysophate and triclopyr are applied in this manner, the herbicide is absorbed within the plant or tree's system and does not migrate into the surrounding soil.

Glysophate and triclopyr will only be used when conditions and BMPs demonstrate that a chemical treatment would be the most effective approach and will only be applied to the list of plants previously identified in this report and those new non-native plants that may be identified in the Wildfire Prevention Assessment District's yearly report.

Environmental Impact


Economic: Giving the Oakland Fire Department a cost effective tool to control flammable non-native vegetation will prevent the destruction of homes and property.

Environmental: The goal of the proposed policy is to enhance fire prevention efforts and encourage the growth of native vegetation. Fires create severe toxic pollution damaging local streams and wildlife. Native trees and plants are more fire resistant and provide forage and habitat for wildlife.

Social Equity: Fire prevention equally benefits every member of the community. The ongoing effort to reduce the fuel load within the Wildfire Prevention Assessment District reduces the risk of a major fire spreading throughout the city following another firestorm such as the City experienced in 1991 or after a major earthquake on the Hayward Fault, which runs through the length of the Wildfire Prevention Assessment District.


Much of the city-owned land focused in this report consists of non-landscaped, undeveloped properties that are not wheelchair accessible.


That the City Council approve the attached resolution authorizing a limited exemption to the Integrated Pest Management Policy to use herbicides on City-owned land in the Wildfire Prevention Assessment District and other City properties identified by the Fire Marshal as areas of high fire hazard.

Respectfully submitted,

Jean Quan
Councilmember, District 4