NYCkayaker Pralls island deforestation (long)

[rob buchanan]

Of possible interest to those of you familiar with the Arthur Kill and the
Staten Island Greenway:

Two weeks ago an infestation of the asian longhorned beetle (ALB) was
discovered on pralls island, just off staten island on the east side of the
arthur kill. Though it seems to be a relatively small outbreak (just 36
trees were found to be affected), starting today a team of foresters from
city parks, which administers the island, and the usda's animal and plant
health inspection service (APHIS) will attempt to cut down, chip, and burn
all 3000 of the eastern gray birch and red maples on the island, which
together form some 85 percent of the island's tree cover. Parks and APHIS
say the intervention, which commissioner Benepe likened to a 'mini-D-Day,'
is necessary to prevent the spread of the pest to Staten Island and the rest
of the city. But not everyone agrees. A Staten Island botanist and activist,
Richard Lynch, from the Sweetbay Magnolia Conservancy, kayaked to the island
this morning, climbed a red maple, and chained himself to its trunk to
protest the action. He says it's a drastic overreaction that was undertaken
without any public process at all, is contrary to APHIS' own regulations,
and is certain to cause environmental devestation to a one of the estuary's
most unique and least understood natural habitats.

For those who are interested to learn more, there was an article on the
eradication campaign in Friday's Staten Island Advance
(http://www.silive.com/siadvance/stories/index.ssf?/base/news/11746521221911
40.xml&coll=1). I've also posted a copy of Lynch's letter to Commissioner
Benepe below. It's long, but makes a number of interesting points. His
cellphone number is at the bottom. If you feel like giving him a call up in
the tree, I'm sure he'd be happy to tell you more.

Rob


> Hon. Adrian Benepe, Commissioner,
>  
> NYC Department of Parks and Recreation
>  
> The Arsenal, Central Park
>  
> New York, New York
>  
>  
>  
>  
>  
> Dear Commissioner Benepe,
>  
>  
>  
> It was enormously distressing to those of us working in the environmental
> protection/restoration "wilderness" of the West Shore of Staten Island and
> Arthur Kill portion of the estuary, to hear how up-beat you seem to be that
> nearly 3000 native forest trees are being cut-down, chipped, and burned on
> Prall's Island (mostly by DPRs own NRG Forest "Restoration" crew). Your
> reaction to the discovery of the ALB on NYC Parkland on Staten Island seemed
> insensitive, that going-in with an "all gun barrels blazing" attitude that was
> anathema to your predecessor at DPR (see Advance article, attached).
>  
>  
>  
> I wonder how Commissioner Stern would have responded to this crisis on a
> City-owned island whose forests serve as critical habitat for, not only
> colonial wading birds, but many species of wildlife from White-tail Deer to
> Red Fox to Coyote. Would he be applauding the myopic regulators from APHIS for
> this (literal) slash and burn policy toward the parklands he (and you) had
> been charged by the public trust to protect? I think the answer is pretty much
> rhetorical (as you remember, Henry prosecuted a guy for only chaining his bike
> to a tree; He didn't cut down, chip, and burn three thousand, 3000, of them).
>  
>  
>  
> So, if we are going to defer to the so-called "experts" at APHIS, let's see
> what the plan is and what the policy for eradicating ALB really is. As the ALB
> was discovered in two native tree species, Eastern Gray Birch (Betula
> populifolia) and Red Maple (Acer rubrum), the decision has been made to
> destroy the 36 trees in which ALB has been found, as well as all identified
> host species on Prall's (though the new quarantine extends well into Staten
> Island, covering an additional many hundreds of acres of City Parkland). So to
> the meager 36 affected trees have a multiplying effect of 100 times that
> actual occurrence.
>  
>  
>  
> APHIS can not explain why their stated policy (which can be found on their
> website and which is re-iterated again and again in their public relations
> documents), which is to destroy affected trees and subsequently dose host
> species in the quarantine areas with injectible Imidacloprid (a long-acting
> insecticide). USDA/APHIS has occasionally produced Environmental Assessments
> (EAs) that compare different experimental approaches (injection dosing versus
> bark-spray dosing, etc.), but has not (to my knowledge) produced an EA that
> compares Injection Dosing to 100% removal of all host trees within the
> quarantine. The EAs prepared by APHIS are the LEGAL basis for all of the work
> they perform in trying to eradicate ALB, so it appears that they have neither
> the technical proof of the procedures preference over Injection Dosing, nor
> the legal authority to be conducting this field work in the first place.
>  
>  
>  
> According to APHIS' own press release regarding the Prall's Island occurrence
> "all of the INFESTED tress will be cut down and wood-chipped to destroy all
> beetle larvae" (please see, attached). The press release also delineates the
> members of the New York State ALB Cooperative Eradication Program (NYS
> Department of Agriculture and Markets, NYC DPR, NYS DEC, and the USDA Forest
> Service). The expertise and regulatory requirements of many city, state, and
> federal agencies (which is required under law, as Prall's Island would be
> under the review of US Fish and Wildlife, NYS Department of State, NOAA, the
> Army Corp, and NYC DEP) are not included. Given the great numbers of
> state-listed (and regulated) species that are known to occur on Prall's, the
> state Natural Heritage Program and Division of Forestry should have been
> involved as well.
>  
>  
>  
> Since the discovery of the outbreak on Prall's on March 12 (hard to believe,
> only two weeks ago!), the"Cooperative Eradication Program" members have been
> meeting (in cognito, apparently). Even when they held a meeting ON Staten
> Island, they refused to include any members of the public, including
> representatives from the environmental community. My understanding is that the
> meeting was so clandestine, that members of your own (DPR) staff were told,
> when they arrived, to go home. This is pretty "cloak and dagger" stuff.
>  
>  
>  
> So, a hasty plan was conceived and rationales and justifications made for why
> such temporally-rash decisions had been made. For example, the position of
> APHIS is that they want to take all the trees down now so as to not make the
> island attractive to returning colonial wading birds as nesting sites and not
> disturb these (regulated) species during the breeding season. Okay, so the
> argument here seems to be that we care about the colonial wading birds SO much
> that we are going to destroy 3000 of the very trees that they use for nesting!
> If there were a better way to define the word HUBRIS, I'd like to know.
>  
>  
>  
> The other primary argument that is being made is that we have to get the 3000
> trees down now, so as to prevent the ALB adults from emerging and potentially
> reaching the shores of Staten Island. The APHIS entomologists have said that
> the 36 affected trees on Prall's do not represent a "new" infestation, that it
> may be more than a year (and up to three years) old. So, in possibly three
> years, the beetles have only been able to infect (as far as we know) 36 trees
> out of a pool of 3000 host trees. As far as the beetle's potential dispersal
> to the shores of Staten Island proper, the science tells us that ALB is not a
> particularly strong flier and that adults tend to stay around the same trees
> that they emerge from (this, in literature provided by APHIS, as well as
> information on their website).
>  
>  
>  
> By accident, I met-up with the APHIS team in Saw Mill Creek Park on March
> 23rd, so had the opportunity to query them about my concerns directly. I
> explained to them that the Sweetbay Magnolia Conservancy has been studying the
> vegetation and certain wildlife species on the Arthur Kill portion of Staten
> Island for many years and that we were dismayed that APHIS has failed to reach
> out to the public and the local (non-government) research community for input.
> It was pretty clear from our (very heated) discussion that APHIS knows little
> to nothing about the local plant communities of the Arthur Kill and what rare
> and endangered species are either known to occur there either currently or in
> the past.
>  
>  
>  
> The primary upland forest cover type that has been identified by the SMC (as
> well as NYS NHP) along the Northwest Shore of Staten Island is the Blackjack
> Oak/Post Oak Maritime Oak Forest, a formally-described plant community for
> which only a tiny handful of occurrences have been documented. Given it's
> demonstrable rarity, this forest type has been designated as
> critically-imperiled (G1/S1 rank, less than 5 occurrences globally).
>  
>  
>  
>  From the research I have been conducting, the Maritime Oak Forest (MOF) is a
> late successional series that generally requires an earlier "ruderal" plant
> community in order to become established. The early successional Gray Birch
> Thicket (GBT) community on Prall's is currently in a perfect state of
> "readiness" to become invaded by the Maritime Oak species (which would easily
> be carried by Blue Jays and others from the opposite shoe in Saw Mill Creek
> Park). In fact, DPR has been actively involved in trying to create MOF
> habitats on Prall's Island, though (I think) the methodology for how one might
> go about accomplishing such a task is not clearly understood).
>  
>  
>  
> One very ironic example of this lack of information/data collection on the
> part of APHIS revolves around the American Burying Beetle (Nicrophorus
> americanum), a federally-listed endangered species known to have occurred in
> and around Staten Island (and for which specimens exist in the entomological
> collections of the Staten Island Museum). The early successional communities
> found along the Arthur Kill and on Prall's Island specifically, are very
> similar to the plant communities on Block Island (where the last remaining
> eastern population of American Burying Beetle is known to exist).
>  
>  
>  
> The Sweetbay Magnolia Conservancy has been studying the occurrence of
> Nicrophorus beetles in this area for the past three years and has discovered a
> viable population of Nicrophorus orbicollis, the species mostly closely
> related to American Burying Beetle (ABB). This species requires the same size
> range of carrion (100-200g avian or mammal carcasses) as ABB to breed. No
> reconnaissance work has been conducted for ABB or its close relatives on
> Prall's, so it is impossible to say with any certain that ABB does not exist
> in this remote location. So we have a "battle of the beetles" on our hands
>  
>  
>  
> This is the level of discussion and oversight that would have occur ed if US
> Fish and Wildlife were involved. They are not involved and it is my belief
> that this deference to USDA/APHIS is based on nothing other than APHIS'
> insistence to remove the forest on Prall's rather than treat with systemic
> insecticides. Whenever we allow this kind of inter-agency politeness to result
> in regulators not intervening in the work of other regulators, we shouldn't be
> surprised that existing laws are not enforced. Ultimately, in this case,
> Nature and DPR property is the only one to be made to suffer.
>  
>  
>  
> When I asked APHIS staff to explain why the remove affected trees/treat host
> trees in the quarantine areas was not a possibility at Prall's, I was told
> that the density of Gray Birch stems made it impossible to dose the trees with
> enough insecticide, but not exceed the federal standards for its open use in a
> sight such as Prall's. When I suggested that APHIS undertake a selective cut
> practice that would carefully reduce the number of stems/acre that would
> subsequently be treated without exceeding USDA standards, it was clear that
> they hadn't even considered this scenario, though I think they thought it was
> interesting.
>  
>  
>  
> So, this is the heart of the problem. By not involving local scientific
> researchers, APHIS lost the possibility of a novel approach being suggested. I
> should say IT'S NOT TOO LATE for DPR to consider this as a real option, one
> that could possibly save thousands of native trees, yet effectively contain
> the outbreak on Prall's Island. Of course, the Sweetbay Magnolia Conservancy
> is willing to offer any and all service to help develop a timely compromise
> with the core regulators. SMC is NOT against the effective quarantine and
> eradication of ALB. I think it's just a matter of creating a somewhat greater
> level of environmental sensitivity than we (clearly) have seen from the group
> so far.
>  
>  
>  
> The analogy I think needs to be made here is that, if APHIS were to discover
> 36 trees affected by ALB in Central Park, you would not (nor would anyone
> living in New York City) allow the state and federal government to clear cut
> the entire park (certainly, not without tremendous oversight and from every
> possible perspective). I hope you will think about this, that there needs to
> be a consistent policy for ALB eradication throughout the City. Existing ALB
> outbreaks in Manhattan, Queens, and Brooklyn follow the published APHIS
> guidelines for removal of affected trees and treatment of host species within
> the designated quarantine.
>  
>  
>  
> In this AWFUL case, it's easy to see why Staten Island still bears the
> monicker of the "forgotten borough". I have seen on television programs on
> which you were interviewed, that you have stated that Staten Island contained
> many of your most favorite natural parks in the City. In the case of the
> Arthur Kill portion of the estuary, DPR has added significantly the number of
> acres of parkland on Staten Island. By not having the kind of enabling
> legislation (such as the "forever wild" concept promulgated by Commissioner
> Stern) that would clarify how such projects would be regulated within these
> entirely natural areas, we are allowing the state and federal government to
> ride us right into the marsh mud with what is clearly a "rough-shod" approach
> to the project.
>  
>  
>  
> Ultimately, I believe that APHIS may have made some serious mistakes in not
> being more diligent containing the Carteret outbreak of ALB (the presence of
> ALB is, in itself, proof of the program's failure), so why wouldn't we expect
> them to come into Staten Island with the "guns blazing" approach we see here.
> By over-reacting to the outbreak on Prall's, it appears that APHIS has the
> problem well in hand. APHIS DOES NOT have this outbreak well in hand.
>  
>  
>  
> I am BEGGING YOU TO INTERCEDE ON THE PART OF THE NATIVE FORESTS ON PRALL'S
> ISLAND!! This plan is very poorly thought out both from the position of ALB
> eradication and natural areas management. As you can imagine, the
> environmental community on Staten Island is gearing-up to fight this very
> un-just action by Parks against Nature. I hope there is a compromise here as I
> believe that there is a reasonable approach, if we could only try to reach out
> for it. Barring that, all other bets are off the table. I think that is
> explaining the scenario as best I can.
>  
>  
>  
> Personally, I feel there was a great hope and expectation that arrived with
> your tenure as the leader of our park system. Where Parks was once the leader
> in the charge to protect natural areas on Staten Island and throughout the
> City, I don't see the level of committment to these goals that we once had.
> There are not too many times when one is given the opportunity to really make
> a difference in a tangible and specific way. By forcing APHIS and NYS DEC to
> look at this plan as environmentally-sensitive (while at the same time helping
> to eradicate ALB), you could rightly be given the title of "saviour" for these
> 3000 trees (and all the associated wildlife) on Prall's Island. I believe
> there is a reason I have always like you; I hope this incident is an
> opportunity to prove me to be right on this point.
>  
>  
>  
> As always, I am dedicated to parklands and to you. I certainly hope we can
> work together on this critical issue.
>  
>  
>  
> Richard T. Lynch, Botanist
>  
> Sweetbay Magnolia Conservancy
>  
> 17 Monroe Avenue
>  
> Staten Island, New York 10301
>  
> 718.273.3740 or 347.526.5507
>  
> rtlynch at verizon.net
>