EPA Review of the FEMA Draft EIS

The EPA has reviewed the DEIS for the Hazardous Fire Risk Reduction Project and submitted it during the comment period.  They gave it an EC-2 rating. The EC stands Environmental Concerns and the 2 is insufficient information. That may sound terrible, but remember; this is a draft statement thousands of pages long. An 8 page punch list from the EPA is nothing for a project of this size and scope.

The EPA ratings are:

• LO Lack of Objections
• EC Environmental Concerns
• EO Environmental Objections
• EU Environmentally Unsatisfactory

The numbers represent:

1. Adequate
2. Insufficient Information
3. Inadequate

What this rating means is there are environmental concerns, not objections, and insufficient information has been provided in the DEIS to to mitigate those concerns.

2 (Insufficient Information). The draft EIS does not contain sufficient information to fully 
assess environmental impacts that should be avoided in order to fully protect the 
environment, or the reviewer has identified new reasonably available alternatives that are 
within the spectrum of alternatives analyzed in the draft EIS, which could reduce the 
environmental impacts of the proposal. The identified additional information, data, 
analyses, or discussion should be included in the final EIS. 


The EPA's primary concerns are;

• Some eradicated areas may need more intensive regeneration efforts than those proposed. 
• Lack of information about herbicide use.

I concur with the EPA on both accounts. While many areas have a well established, albeit stunted woodland beneath the canopy, many areas do not. Replanting in barren areas and manual weeding could mitigate these concerns. This is where neighborhood activism could make a difference. The Claremont Canyon Conservancy has shown what can be done when the community gets involved with the various agencies.

UCB and CCC have eradicated the eucalyptus and replanted more redwoods, seen below.

The eucalypti were recently eradicated here.

Building on this success is the path forward. Pressuring the agencies to make a greater restoration effort will also mitigate one of the EPA's primary concerns.

Little redwoods where the eucalyptus once stood

The EPA concerns about the herbicides can be addressed by simply editing the DEIS so that the FEIS addresses the EPA concerns. The FEIS will likely pass the EPA review with a LO-1

The strategy of stopping the HFRRP through the courts is counter-productive. All that will do is slow or stop the FEMA money. UC Berkeley doesn't care, it is their land, their risk, and their money. Targeting them on this issue will be as effective as living in the trees to stop the stadium renovation was.

The City of Oakland and EBRPD don't have the resources to proceed. Holding the money up in the courts will harm the community, not the University.

Our efforts are better spent identifying areas for more intensive restoration efforts and less toxic forms of weed control.

Strong community organizations, working closely with the agencies involved, have already proven that we can eradicate the eucalyptus and return the native habitat.

Let us build on that success. Not deny it's existence.