On November 20, 2019, UC Berkeley’s department of Physical and Environmental Planning issued a Notice of Preparation (NOP) of an Environmental Impact Report (EIR) for its Hill Campus Wildland Fuel Management Plan, with an Initial Study (IS) attached. The following response was submitted to UC’s planners by UC Professor Emeritus Joe McBride:
(See Professor McBride’s recommended plan here.)
1. (page 1-1, -paragraphs 2 and 3) The general lack of specificity in the plan. Vegetation management treatments are proposed (e.g., defensible space; shaded fuel breaks; roadside fuel breaks) without providing the details of these treatments. It is suggested that ‘five types of vegetation treatment activities are proposed for implementation, but no specific details are given as to how decisions will be made in the three vegetation treatment types to select one or more of the vegetation treatment activities. More specificity is needed to access the environmental impacts and the potential effectiveness of the vegetation treatment activities. More detailed mapping, especially to identify the vegetation types, in each of the three vegetation treatment types would increase the clarity of the plan.
2. (page 2-1 and Figures 2-1 and 2-1) A map of the vegetation types within the fuel break project would be useful in determining which of the ‘five types of vegetation treatment activities’ would be most effective in the reduction of fire hazard.
3. (page 2-3; Figure 2-2) I had access only to a black and white map of the Fire Hazard Reduction projects and had difficulty in determining the extent of each of the three Fire hazard projects. My interpretation of the map suggests that no project is proposed for the north facing slope of Strawberry Canyon west of the Frowning FHR Project. If that is correct, I am concerned with a fire being spread by Diablo winds through the Sherwood Forest area and into the adjoining residential area to the south. Figure 2-2 does not show the East West FB Project extending west to protect the residential area from such a fire.
4. (page 2-5) ‘Evacuation support treatments’ proposes the treatment of “a strip of land up to 100’ from either side of major evacuation routes”. This strip should be widened to include any tree that could potentially fall onto the evacuation routes in a fire event because of their height and lean toward the route. Some trees exceed 100’ in height along some of the evacuation routes.
5. (page 2-10; Treatment Maintenance). The objectives of maintenance should be spelled out in this section. Those objectives should be specific for each vegetation type that is initially treated.
6. (page 2-11; Table 2-2) Table 2-2 identifies 155 acres for treatment in the plan. I think the plan should for treatment of a larger area than (see #3 above).
7. (page 2-13, Hearst Gate Fuelbreak project) There is no specificity as to the spacing between tree crowns in this fuel break. I am concerned about the statement “many trees would remain”.
8. (page 3-3 and following sections) I am concerned that the environmental impact assessment cannot be adequately prepared with out more specificity in the plan. It seems that many of the discussion points have had to be generalized due to a lack of specificity in the plan as the vegetation treatment activity to be used, the lack of specificity as to vegetation types, and the lack of specificity as to the biological resources impacted. For example, no specific mention is made of Alameda whipsnake (Masticophis lateralis ssp.euryxanthus) habitat nor the environments where Leatherwood (Dirca occidentalis) could potentially be found on UC property. Nor have well know techniques (use in developing timber harvest plans under rules adopted by the California Board of Forestry) for determining landslide risk based on slope, soil type and vegetation treatment been applied.
