[APPENDICES]

_______________________________________________________________________________________

Appendix A: FEDERALLY LISTED, PROPOSED, AND CANDIDATE SPECIES WITH POTENTIAL TO OCCUR
IN THE STRAWBERRY CANYON VICINITY

AMPHIBIANS

Scientific Name: Ambystoma californiense

Common Name: California tiger salamander

Federal Status: Threatened

Preferred Habitat: 
Annual grasslands and grassy understory of valley-foothill hardwood habitats, need 
underground refuges, need vernal pools, stock ponds, or other seasonal water sources 
for breeding. The species persists in disjunct remnant vernal pool complexes in Sonoma 
and Santa Barbara counties, in vernal pool complexes and isolated ponds scattered 
mainly along narrow strips of rangeland on each side of the Central Valley from 
southern Colusa County south to northern Kern County, and in sag ponds and human-
maintained stock ponds in the coast ranges from Suisun Bay south to the Temblor 
Range.

Likelihood of Occurrence: 
Not likely to occur because the project area does not provide suitable breeding or 
aestivation habitat for this species. The closest occurrence to the project area is 
approximately 6.9 miles south and is located in Alameda.

Scientific Name: Rana aurora draytonii

Common Name: California red-legged frog

Federal Status: Threatened

Preferred Habitat: 
Dense, shrubby riparian vegetation associated with deep (> 0.7 meter), still or 
slow-moving water. Lowlands and foothills in or near permanent sources of deep water 
with dense, shrubby, or emergency riparian vegetation. Requires 11-20 weeks of 
permanent water for larval development, must have access to aestivation habitat.

Likelihood of Occurrence: 
Potential to occur. Ephemeral drainages in project area could provide suitable habitat. 
The closest occurrence to the project area is approximately 3.1 miles southeast and is 
located at Thornhill Pond, near Berkeley.

REPTILES

Scientific Name: Masticophis lateralis euryxantus

Common Name: Alameda whipsnake

Federal Status: Threatened

Preferred Habitat: 
Rock outcrops in association with chaparral and coastal sage scrub. Inhabits south-facing 
slopes and ravines where shrubs form a vegetative mosaic with oak trees and 
grasses. Restricted to valley-foothill hardwood habitat of the coast ranges 
between the Monterey vicinity and north of San Francisco Bay.

Likelihood of Occurrence:
Potential to occur. The closest known records of the Alameda whipsnake to the 
project area include captures of 6 Alameda whipsnakes in Claremont Canyon (which is 
located 1 mile southeast of the project area). These individuals were captured between 
2002 and 2004 as part of an East Bay Regional Park District monitoring program 
(Klatt 2006).

BIRDS

Scientific Name: Charadrius alexandrinus nivosus

Common Name: Western snowy plover

Federal Status: Threatened

Preferred Habitat: 
Habitats used by nesting and nonnesting birds include sandy coastal beaches, salt 
pans, coastal dredged spoils sites, dry salt ponds, salt pond levees, and gravel bars.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide sandy coastal beaches, salt 
pans, etc. The closest occurrence to the project area is approximately 9 miles south 
and is located at bay farmland, San Francisco Bay adjacent to Oakland.

Scientific Name: Haliaeetus leucocephalus

Common Name: Bald eagle

Federal Status: Threatened

Preferred Habitat: 
Winters throughout most of California at lakes, reservoirs, river systems, and some 
rangelands and coastal wetlands on protected cliffs and ledges. Also nests on 
bridges and buildings in urban areas. Nests are normally built in the upper canopy of 
large trees, usually conifers.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide any lakes, reservoirs, large 
river systems, and/or cliffs and ledges.

Scientific Name: Pelecanus occidentalis californicus

Common Name: California brown pelican

Federal Status: Endangered

Preferred Habitat:
Found in estuarine, marine subtidal, and marine pelagic waters along the California 
coast. In Northern California, fairly common to uncommon June to November. Usually 
rests on water or inaccessible rocks (either offshore or on mainland), but also uses 
mudflats, sandy beaches, wharfs, and jetties.

Likelihood of Occurrence:
Not likely to occur because the project area is not located near estuarine, marine 
subtidal, and pelagic waters.

Scientific Name: Rallus longirostris obsoletus

Common Name: California clapper rail

Federal Status: Endangered

Preferred Habitat:

Tidal salt marshes near tidal sloughs; perennial inhabitant of tidal salt marshes of 
the greater San Francisco Bay.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide tidal salt marshes. The 
closest occurrence to the project area is approximately 3.9 miles west and is located 
at Richmond inner harbor, between the University of California engineering field 
station and the breakwater, Richmond.

Scientific Name: Sterna antillarum browni

Common Name: California least tern

Federal Status: Endangered

Preferred Habitat: 
Nests on beaches and estuaries near waters that produce small fish. Prefers open areas 
where visibility is good. Substrate choice is generally sand or fine gravel and can be 
mixed with shell fragments.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide beaches and estuaries. The 
closest occurrence to the project area is approximately 7.7 miles southwest and is 
located at Alameda County Air Station, southwest of Oakland.

MAMMALS

Scientific Name: Reithrodontomys raviventris

Common Name: Salt marsh harvest mouse

Federal Status: Endangered

Preferred Habitat: 
Pickleweed is the primary habitat. Inhabits only saline emergent wetlands of San 
Francisco Bay and its tributaries. Requires higher areas for flood escape.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide pickleweed habitat. The 
closest occurrence to the project area is approximately 4.0 miles southwest and is 
located at Emeryville Crescent Marsh, adjacent to a storm drain and Bay Bridge 
approach.

INVERTERBRATES

Scientific Name: Branchinecta lynchi

Common Name: Vernal pool fairy shrimp

Federal Status: Threatened

Preferred Habitat: Vernal pools; small swales, earth slumps, or basalt-flow 
depression basins with grassy or occasionally muddy bottom, in unplowed grassland. 

Likelihood of Occurrence:
Not likely to occur because the project area does not provide any vernal pools or 
seasonal swales appropriate for this species.

Scientific Name: Euphydryas editha bayensis

Common Name: Bay checkerspot butterfly

Federal Status: Threatened

Preferred Habitat: 
Found in serpentine grasslands around San Francisco Bay. The host plant is dwarf 
plantain (Plantago erecta); also uses owls-clover (Castilleja spp.).

Likelihood of Occurrence:
Not likely to occur because the project area does not provide serpentine grasslands. The 
closest occurrence to the project area is approximately 4.4 miles southeast and is 
located at Joaquin Miller Park northeast of Oakland.

Scientific Name: Speyeria callippe callippe

Common Name: Callippe silverspot butterfly

Federal Status: Endangered

Preferred Habitat:
Historically this butterfly-inhabited grasslands ranges over much of the northern 
San Francisco Bay region. On the San Francisco peninsula, this butterfly is now 
only known from San Bruno Mountain (approximately 10 miles south of San 
Francisco). In the East Bay, it was known from Richmond in the north to the Castro 
Valley in Alameda County. The only remaining population of this butterfly in 
Alameda County occurs in an undisclosed city park. The host plant is violet (Viola 
pedunculata).

Likelihood of Occurrence:
Not likely to occur because the project area does not provide grasslands suitable for this 
butterfly species. No California Natural Diversity Database records exist of this 
species in the project vicinity.

FISH

Scientific Name: Acipenser medirostris

Common Name: Green sturgeon

Federal Status: Proposed for listing status

Preferred Habitat:
A demersal (bottom-dwelling) species, mostly seen from inshore waters to 60 
meters (197 feet). Spawns in the mainstem of large river systems in relatively fast water 
flows and probably in depths greater than 3 meters. Preferred spawning substrate is large 
cobble, but can range from clean sand to bedrock. The only recently documented 
green sturgeon spawning locations are in the Klamath, Sacramento, and Rogue rivers 
along the west coast of North America. However, green sturgeon are known to 
range in nearshore marine waters from Mexico to the Bering Sea and are commonly 
observed in bays and estuaries along the coast with particularly large concentrations 
entering the Columbia River estuary, Willapa Bay, and Grays Harbor during the 
late summer.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Eucyclogobius newberryi

Common Name: Tidewater goby

Federal Status: Endangered

Preferred Habitat:
Tidewater gobies are uniquely adapted to coastal lagoons and the uppermost brackish 
zone of larger estuaries, rarely invading marine or freshwater habitats. The species is 
typically found in water less than 1 meter (3.3 feet) deep and salinities of less than 
12 parts per thousand. 

Likelihood of Occurrence:
No potential because the project area is not located near any coastal lagoons, nor does it 
have any aquatic habitat. The closest occurrence to the project area is 
approximately 3.94 miles west and is located at Berkeley Aquatic Park, west edge of 
Berkeley adjacent to San Francisco Bay.

Scientific Name: Hypomesus transpacificus

Common Name: Delta smelt

Federal Status: Threatened

Preferred Habitat:
Found only in the Sacramento-San Joaquin Estuary, from the Suisun Bay upstream 
through the Delta in Contra Costa, Sacramento, San Joaquin, Solano, and Yolo 
counties. Euryhaline species, but for a large part of its life span, is associated with the 
freshwater edge of the mixing zone (saltwater-freshwater interface). Spawning 
habitats are side channels and sloughs in the middle reaches of the Delta. Spawns in 
shallow freshwater from December through July. Pelagic feeder.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Oncorhynchus kisutch

Common Name: Central California coast Coho salmon

Federal Status: Endangered

Preferred Habitat: 
Pacific Ocean, spawns in coastal streams and rivers, over gravel beds. Pool depth, 
volume, amount of cover, and proximity to gravel for spawning play key roles.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Oncorhynchus mykiss 

Common Name: Central California coastal steelhead

Federal Status: Threatened

Preferred Habitat:
Pacific Ocean, spawns in coastal streams and rivers, over gravel beds. Pool depth, 
volume, amount of cover, and proximity to gravel for spawning play key roles.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Oncorhynchus mykiss 

Common Name: Central Valley steelhead

Federal Status: Threatened

Preferred Habitat: 
Pacific Ocean, spawns in coastal streams and rivers, over gravel beds. Pool depth, 
volume, amount of cover, and proximity to gravel for spawning play key roles.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Oncorhynchus tshawytscha

Common Name: Central Valley fall/late fall-run Chinook salmon

Federal Status: Candidate for listing status

Preferred Habitat: 
Pacific Ocean, spawns in coastal streams and rivers, over gravel beds. Pool depth, 
volume, amount of cover, and proximity to gravel for spawning play key roles.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Oncorhynchus tshawytscha 

Common Name: Central Valley spring-run Chinook salmon

Federal Status: Threatened

Preferred Habitat:

Pacific Ocean, spawns in coastal streams and rivers, over gravel beds. Pool depth, 
volume, amount of cover, and proximity to gravel for spawning play key roles.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

Scientific Name: Oncorhynchus tshawytscha

Common Name: Sacramento River winter-run Chinook salmon

Federal Status: Endangered

Preferred Habitat:
Pacific Ocean, spawns in coastal streams and rivers, over gravel beds. Pool depth, 
volume, amount of cover, and proximity to gravel for spawning play key roles.

Likelihood of Occurrence:
No potential because the project area is not located near the ocean, nor does it have any 
aquatic habitat.

PLANTS

Scientific Name: Arctostaphylos pallida

Common Name: Pallid manzanita

Federal Status: Threatened

Preferred Habitat:

Found in chaparral. Found only in the northern Diablo Range of California. Range 
into several distinct units: Contra Costa Hills, Mt. Diablo, Mt. Hamilton Range, 
Panoche Hills, San Carlos Range, and Estrella Hills. Prefers to grow in limited 
locations of the East Bay Hills on north- and east-facing slopes where bare, siliceous, 
mesic soils with low fertility exist.

Likelihood of Occurrence:
Not likely to occur because the project area is located within species known range and 
does not provide suitable habitat for this species. The closest occurrence to the 
project area is approximately 0.5 mile north and is located on Dark Hill and Shasta 
roads, northeastern corner of Tilden Regional Park.

Scientific Name: Chorizanthe robusta var. robusta

Common Name: Robust spineflower

Federal Status: Endangered

Preferred Habitat:

Cismontane woodland, coastal dunes, coastal scrub. Sandy terraces and bluffs or in 
loose sand; elevation from 3120 meters.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide suitable habitat for this 
species. The closest occurrence to the project area is approximately 6.9 miles south 
and is located in Alameda.

Scientific Name: Clarkia franciscana

Common Name: Presidio clarkia

Federal Status: Endangered

Preferred Habitat:

Restricted to grassland communities on serpentine soils in San Francisco and 
Alameda counties. Two populations are known from San Francisco Presidio. Three 
are known from the Oakland Hills in Alameda County, all from within 0.5 mile of 
each other. Total plant numbers fluctuate greatly; the upper limit reported in recent 
years is approximately 8,000 plants. Serpentine soils are formed from weathered 
volcanic (ultramafic) rocks such as serpentinite, dunite, and peridotite.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide grassland communities. 
The closest occurrence to the project area is approximately 6 miles southeast and is 
located at Redwood Regional Park, below East Bay Regional Park headquarters, 
northeast of Skyline Blvd.

Scientific Name: Holocarpha macradenia

Common Name: Santa Cruz tarplant

Federal Status: Threatened

Preferred Habitat:
Grasslands and prairies found on coastal terraces below 100 meters (330 feet) in 
elevation, from Monterey County north to Marin County. In the Santa Cruz area, the 
gently sloping terrace platforms are separated by steep-sided "gulches," 
whereas in the Watsonville area (Monterey County) and on the eastern side of San 
Francisco Bay, the terraces are more extensively dissected, and Holocarpha 
macradenia populations occur on alluvium derived from the terrace deposits (Palmer 
1986).

Likelihood of Occurrence:
Not likely to occur because the project area does not provide grasslands and prairies.  
The closest occurrence to the project area is approximately 2.7 miles north and is located 
in lower Sather Canyon, between San Pablo and Briones reservoirs 2.7 miles due north 
of Vollmer Peak.

Scientific Name: Lasthenia conjugens

Common Name: Contra Costa goldfields

Federal Status: Endangered

Preferred Habitat:
Valley and foothill grassland, vernal pools, cismontane woodland. Extirpated from most 
of its range. Found in vernal pools, swales, and low depressions in open grassy areas; 
elevation from 1455 meters.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide suitable habitat for this 
species. The closest occurrence to the project area is approximately 17.1 miles 
south and is located at about 0.25 mile north of western end of Depot Road; adjacent to 
(just east of) the American Salt Company, along shore of San Francisco Bay.

Scientific Name: Layia carnosa

Common Name: Beach layia

Federal Status: Endangered

Preferred Habitat:
The species is restricted to openings in coastal sand dunes ranging in elevation from 
0-30 meters (0-100 feet), where it colonizes sparsely vegetated, partially stabilized dunes 
or relatively bare blowouts in secondary succession. In Northern California, it occurs 
in the northern fore dune community; in Monterey County, the species occurs in the 
central fore dune community described as the sand-verbena. It generally occupies 
sparsely vegetated open areas on semi-stabilized dunes. The fore dune community 
experiences some drifting sand and has low-growing herbaceous and perennial native 
species. The species also occurs in open areas, such as along trails and roads.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide suitable habitat for this 
species. The closest occurrence to the project area is approximately 9.0 miles 
southwest and is located at San Francisco Sand Dunes, San Francisco.

Scientific Name: Suaeda californica

Common Name: California seablite

Federal Status: Endangered

Preferred Habitat:

Marshes and swamps. Margins of coastal salt marshes; elevation from 05 meters.

Likelihood of Occurrence:
Not likely to occur because the project area does not provide marshes and swamps. The 
closest occurrence to the project area is approximately 3.3 miles west and is located 
near Fleming along Southern Pacific Railroad.

Federal Endangered Species Act
E - Endangered
T - Threatened
C - Candidate for listing status
P - Proposed for listing status

Source: USFWS species list and California Natural Diversity Database search for five quadrangles surrounding the project area

_______________________________________________________________________________________

Appendix B: BIOLOGICAL OPINION FROM THE U.S. FISH AND WILDLIFE SERVICE

[Appendix B is not available as a .txt file. Please consult the .pdf file or contact Mr. Alessandro Amaglio, 
Environmental Officer, U.S. Department of Homeland Security, Federal Emergency Management Agency, 
1111 Broadway, Suite 1200, Oakland, California 94607, (510) 627-7284.]

_______________________________________________________________________________________

Appendix C: RESPONSE FROM THE STATE HISTORIC PRESERVATION OFFICER

U.S. Department of Homeland Security 1111 Broadway, Suite 1200
Oakland, CA 94607-4052
FEMA

March 8, 2006

Mr. Milford Wayne Donaldson 
State Historic Preservation Officer 
Office of Historic Preservation 
1416 9th Street, Room 1442-7 
Sacramento, California 95814

Re: Regents of the University of California, Fire Mitigation Projects 
    at Claremont Canyon and Strawberry Canyon, PDMC-PJ-09-CA-2005-003 and -011

Dear Mr. Donaldson:

The purpose of this letter is to transmit the enclosed technical report and 
summarize the results of an archaeological field review of lands potentially 
affected by two projects proposed in Alameda County, California. The Regents 
of the University of California (UC) have applied to the Federal Emergency 
Management Agency (FEMA) through the California Governor's Office of 
Emergency Services (OES) for Pre-Disaster Mitigation (PDM) Program grants 
to implement two vegetation management projects in Claremont and Strawberry 
Canyons (PDMC-PJ-09-CA-2005-003 and PDMC-PJ-09-CA-2005-011, respectively). 
The proposed effort is designed to mitigate future impacts associated with 
wildfires by reducing the available fuel load through a combination of hand 
clearing and mechanized removal of potential fuels from the project area. 
The attached report presents the results of a literature and archival 
review and an archaeological field survey of lands potentially affected by 
the proposed projects. This report was prepared by URS Corporation (URS), 
as a consultant to FEMA, to comply with Section 106 of the National 
Historic Preservation Act (NHPA) of 1966, as amended, and the Programmatic 
Agreement (PA) among FEMA, the State Historic Preservation Officer, OES, 
and the Advisory Council on Historic Preservation.

In summary, a field review of the project area was supplemented by a 
cultural resources records review conducted at the Northwest Information 
Center (NWIC) of the California Historical Resources Information 
System. In addition to the literature review, the California Native 
American Heritage Commission (NAHC) was contacted for a review of 
its Sacred Lands File as well as a list of Native American groups and 
individuals it believes should be contacted. The Sacred Lands File 
search was negative. FEMA sent letters to those groups and individuals 
listed by the NAHC. To date no responses have been received. An 
archaeological survey of the APE was undertaken on December 6 and 9, 
2005, by URS. The results of the survey were negative.

Project Description

Within the wildlands, exotic vegetation will be selectively removed 
from approximately 45 acres of Claremont Canyon and 66 acres of Strawberry 
Canyon. The exotic vegetation would be cut by hand fellers (using 
chainsaws and wedges) and the mechanized feller-buncher (a tracked 
vehicle). Felled trees (up to approximately 24 inches in diameter) 
would be hauled along paths ("skid trails") to landings within the 
project areas. At the landings, trees would be chipped using a grapple 
fed chipper. The staging of vehicles would occur at landings within the 
project area. Additional landings may be created mid-slope within the 
project area as needed.

Area of Potential Effects (APE) Determination

The proposed APE consists of all areas (within the individual project 
boundaries) where vegetation will be removed, and are depicted in Figures 
2 and 3 in the attached technical report (in Appendix A). Pursuant to 
Stipulation VILA. of the PA, FEMA seeks your concurrence with its 
determination of the APE.

Literature Review

Pursuant to Stipulation VII.B. of the PA, the project area was subject 
to a cultural resources literature review. The enclosed report provides 
a complete description of the literature review.

Natural Setting

The enclosed report provides a complete description of the natural setting.

Prehistory, Ethnohistory, and History

The enclosed report provides a complete description of the prehistory, 
ethnohistory, and history of the project area.

Cultural Resources Inventory Methods and Results

Mr. Brian W. Hatoff, M.A., RPA, of URS, qualified as an archaeologist 
under the Secretary of the Interior's Professional Qualification 
Standards, served as Principal Investigator for the cultural resources 
survey conducted in December 2005. The enclosed report provides a 
complete description of survey methods and results.

Findings and Conclusions

The results of the archaeological survey were negative for cultural 
resources within all areas surveyed. This letter and enclosed report 
provides a description of the undertaking, an APE determination, 
relevant maps, and a description of the steps FEMA has taken pursuant 
to Stipulation VII.C. of the PA to identify historic properties. 
As described above, no properties eligible for the National Register 
of Historic Places (NRHP) were identified through a literature 
review or pedestrian survey of the project area. Therefore, the 
proposed projects are not expected to have any on historic properties.

There is always the possibility that previously recorded or previously 
unidentified archaeological resources could be discovered during 
project construction. In accordance with Stipulation X of the PA, 
FEMA will require UC to stop work in the event of an unexpected 
discovery and will comply with the steps outlined in Stipulation X.

In accordance with Stipulation VII of the PA, FEMA has conducted 
the Standard Project Review. FEMA made a determination of "no historic 
properties affected" and, in accordance with the PA, is submitting 
for review the enclosed report supporting that determination. In 
accordance with Stipulation VII, FEMA may authorize funding for the 
project unless you object to this determination within 21 days
of your receipt of this documentation.

If you have any questions, you can contact me at (510) 627-7284 or 
Mr. Hatoff at (510) 874-3195.

Sincerely,

[Signed]

Alessandro Amaglio, AIA
Environmental Officer

Enclosure

cc:  Dennis Castrillo, OES
     Marcia Rentschler, OES
     Tom Klatt, Regents of the University of California
     Greg Kenning, Biggs Cardosa Associates, Inc. (enclosure omitted)
     Mahvash Harms, Biggs Cardosa Associates, Inc. (enclosure omitted)
     John Hesler, David J. Powers and Associates, Inc. (enclosure omitted)

_______________________________________________________________________________________

Appendix D: PUBLIC COMMENTS AND FEMA'S RESPONSES

Hills Conservation Network
1305 Alvarado Road
Berkeley, CA 94705
510-849-2601

6/30/07

Ms. Nancy Ward 
Regional Administrator 
FEMA Region 9
1111 Broadway, Suite 1200
Oakland, CA 94607 

Ref: PDM05-PJ19,20 
Cc: Robert McCord

Dear Ms. Ward,

We are residents of the Claremont Canyon area who are concerned over the vegetation 
removal projects in this area. Addressing our concerns, we have had extensive interactions 
with East Bay Regional Parks District and the University of California. UC has been 
tentatively awarded about $700k to complete two additional projects in Claremont and 
Strawberry Canyons. Our purpose in writing this letter is to ask that FEMA reconsider 
the approval of these projects.

Our concern over UC Berkeley's vegetation management programs, and specifically with 
the planned projects for [approximately] 40 acres in Claremont Canyon and [approximately] 
65 acres in Strawberry Canyon, is based on the following:

1. Does the removal of an additional 15,000 tall trees, added to the more than 10,000 
that have already been removed make sense, given the trees' favorable effect on global 
warming? Since the areas being proposed for cutting have no history of wildfire, 
targeting these areas seems questionable.

2. The fire risk mitigation for homes and property resulting from these projects 
appears to be minimal, because any structures are well in excess of 1/4 mile away.

3. UC's specific methods are a significant issue. Unlike EBRPD and EBMUD, UC does 
not remove felled trees, instead grinds them on site, leaving up to 24" of chips on the 
ground. This practice, while inexpensive to implement, results in an area that will be 
unlikely to sustain any significant re-vegetation (either native or non-native) for 
many years. In addition, it is known that leaving that amount of chips on the ground 
creates a significant fire hazard, not only due to potential ignition, but also due 
to the difficulty in extinguishing smoldering below surface. EBRPD considers chipping 
on site an unacceptable practice due to the creation of a "dead zone" and the 
increased risk of fire.

4. UC failed to comply with EIR-stipulated mitigations these projects. In the recently 
completed Claremont Canyon project, the following concerns came to light:

a. Until confronted by residents UC, had no written project plans in place

b. Once pushed by local residents, UC elected to use the contractor bid request 
as the formal project plan

c. Although UC committed to use 3rd party personnel to ensure

d. The actual project was in flagrant violation of the "project plan" document 
in the following areas:

i. The work proceeded in the rainy season while doing so was specifically prohibited

ii. Tree stumps were to be cut to 6" or less above grade. In fact, the majority 
of the stumps are several feet above grade

iii. Erosion control measures were supposed to have be erected immediately 
following cuts; none were erected

e. Herbicides were applied directly to trees in a creek running through the property

5. UC, unlike EBRPD has made no effort to encourage public involvement and transparency 
in the implementation of their projects. In addition to refusing to provide public grant 
documents, UC has made claims in those documents that they were able to achieve the greatest 
amount of tree removal per dollar spent of any public agency as a result of "streamlined approval 
processes apart from municipal oversight and undue political meddling". The request that 
UC adopt EBRPDs practice of open community review of preliminary EIR documents has been met with silence.

6. While the designated purpose for the use of FEMA funding was for fire safety and mitigation, 
given that the vegetation removal projects in Claremont and Strawberry canyons are far away 
from structures, and given the fact that UC, unlike EBRPD employs a process whereby a dead zone 
is created at the site, one might question what the real motivation for these projects is. 
It has been suggested that what UC is really doing is using federal funding (FEMA pre-disaster 
mitigation funds in this case) to remove forested areas as a precursor to future development 
projects. While it would be politically difficult to justify cutting down a forest to build 
new structures, once the trees are gone (for "fire safety" reasons) and replaced by dead zones, 
it would be relatively easy to take the next step with minimal opposition.

In summary, we believe that UCs use of FEMA vegetation management funds is a fraudulent 
use of federal funds. We see substantial evidence that UC is being disingenuous in their 
rationale for these projects. Finally, these projects have essentially no favorable impact 
in reducing fire danger. With these factors in mind, we ask that you reconsider the 
approval of these projects.

Sincerely,

Hills Conservation Network Directors 
Dan Grassetti
Jerry Baer
Mikki Baer
Robbie Romano
Madeleine Hovland
Peter Gray Scott
Teresa Ferguson
Bob Sand

[Attachment: Four site photos]

U.S. Department of Homeland Security 
1111 Broadway, Suite 1200
Oakland, CA 94607-4052
FEMA

July 26, 2007

Hills Conservation Network Directors 
1305 Alvarado Road
Berkeley, California 94705

Re: Claremont and Strawberry Canyons Fuel Reduction Projects, University of California 
at Berkeley, PDMC-PJ-09-CA-2005-003 and -011

This is in response to your letter dated June 30, 2007, to our agency's Regional 
Administrator, Ms. Nancy Ward. Your organization expressed concerns about proposed 
vegetation removal projects for which the University of California, Berkeley, has applied 
for funding under the Federal Emergency Management Agency's (FEMA) Pre Disaster Mitigation 
(PDM) Program, through the State of California Governor's Office of Emergency Services.

These projects are currently under environmental review; FEMA is consulting with the 
appropriate agencies for compliance with several statutes, as required, including Section 7 
of the Endangered Species Act (ESA), Concurrently, we are performing these projects' 
review under the National Environmental Policy Act (NEPA), the decision making process 
that ultimately will allow FEMA to determine the validity of the project. This review is 
inclusive of public participation and comments.

I want to thank you for sharing your concerns, some of which have been already taken 
under due consideration during the review and consultation processes. Additionally, 
FEMA will provide you, and any other interested party, the opportunity to review and 
comment on the Draft Environmental Assessment (DEA) when completed. I look forward to 
hearing your feedback.

Sincerely,

[Signed]

Mr. Alessandro Amaglio
Environmental Officer

cc:
Marcia Rentschler, California Governor's Office of Emergency Services 
Dennis Castrillo, California Governor's Office of Emergency Services

Hills Conservation Network
1305 Alvarado Rd.
Berkeley, CA 94705
								
8/10/07

Mr. Alessandro Amaglio
Environmental Officer
FEMA Region 9
1111 Broadway, Suite 1200
Oakland, CA 94607
Cc: Marcia Rentschler, Dennis Castrillo, Hills Conservation Network 
Directors Ref: PDM05-P.119,20

Dear Mr. Amaglio,

Thanks for your recent letter responding to our concerns over the awarding of these 
pre-disaster mitigation grants to UC Berkeley. While we greatly appreciate your consideration 
of the questions raised and information provided, and we plan to work on these issues as 
part of the formal NEPA and CEQA reviews, we do not believe this is a sufficient response 
to the concerns we raised.

We are confident that the formal environmental reviews will cause the environmental issues 
to be considered, however, neither a NEPA nor CEQA review is intended to address our 
primary concern, that these grant proposals are fundamentally fraudulent.

We ask that you consider the attached list of specific instances noted in our review 
of the PJ20 grant proposal. (the issues are identical in PJ19). We have highlighted 
some of the more egregious examples. There are undoubtedly many more. We also note that 
UC refused to provide us with copies of these public documents when requested. After 
reading these applications it became clear why they were reluctant to have this information 
made public.

While we fully support the NEPA and CEQA process and plan to participate, the two grant 
proposals under question should not be seriously considered for funding. Not only do these 
projects have little to do with pre-disaster mitigation, UC, by using fraudulent statements 
throughout these documents, has diminished it's credibility and our statements need to 
be researched prior to allowing these proposed projects to move forward.

As requested before, we would like to meet with your staff on this matter as soon as possible.

Sincerely,

[Signed]

Peter Gray Scott, 1991 Fire Survivor,
on behalf of the Directors of the Hills Conservation Network

[Following list of significant errors and fraudulent claims is part of the 
above letter from Peter Gray Scott]

Significant errors and fraudulent claims made in PJ20 (and PJ19) 

Page 8. The coordinates for the proposed project appear to be incorrect.

Page 13. UC did not follow CEQA in the implementation of its prior projects. 
These projects were allegedly cleared for environmental reviews pursuant to a 
campus-wide EIR published in 2004 (2020 LRDP EIR) that barely touches on the subject 
of vegetation management. Per CEQA, tiered EIRs were to have been completed, but they were not, 
and mitigations were to have been followed, which were not.

The statement that "based on previous reviews and consultations, no significant and/or 
cumulative negative impacts to aesthetics....." is patently false and completely unsubstantiated. 
The further statement that "UC has coordinated its efforts... with East Bay Regional Park 
District" is also a falsehood. The reality is that EBRPD has given up on attempting to work 
with UC due to UC's complete unwillingness to participate in a regional project. In fact, 
EBRPD, in planning for its measure CC projects is doing so without UC's participation, not 
because this is their desire, but as a result of UC's intractability. Finally, in the 
Claremont Canyon area where UC wants to use FEMA funds for more clear cutting, EBRPD 
(the largest landowner in Claremont Canyon) has determined that the fire potential in 
this area is so low that they will not use measure CC funds for any project in Claremont 
Canyon. EBRPD can demonstrate a scientifically rigorous process used to arrive at 
this conclusion while UC cannot.

UC goes on to say that they are eradicating only eucalyptus forests when the reality is 
that they are removing not only eucalyptus trees, but pines, acacias, essentially all 
trees other than oaks and bays.

The statement that this strategy has "won broad acceptance from the community" is a 
falsehood and unsubstantiated. There is a large segment of the community that finds 
UC's projects to be unnecessarily destructive and would prefer the approach taken by 
EBRPD. Over 200 signatures to this effect were delivered to UC and have been ignored.

Page 17. While we will address the cost/benefit analysis in the NEPA review process, 
the economic analysis presented in this grant proposal is nonsense. Their basic 
assertion appears to be that clear cutting in Claremont and Strawberry canyons is 
justified as wildfire mitigation, in spite of the fact that virtually no 
wildfires of any significance have ever occurred in these canyons. UC should 
follow the lead of EBRPD in conducting professional fire risk analyses prior 
to implementing projects such as these...but they have not done so and show no 
plan of performing such analyses. The results would not justify the expenditure 
of these funds for this purpose. While EBRPD can provide scientifically defensible 
data as to why certain areas should be cut, UC cannot.

Finally, in the official review of the '91 firestorm (available via a link at 
http://hillsconservationnetwork.org/Resources.html), there is no evidence that 
eucalyptus trees played any role in that disaster, yet UC continues to assert 
eucalyptus trees were a major cause of the fire.

Page 18. UC's statements as to their qualifications and expertise are highly 
questionable in light of the fact the tactics employed by UC are specifically 
prohibited by other professional land managers at EBRPD. The further assertion that 
all projects are completed on time, on budget, and are compliant with environmental 
considerations is a complete falsehood.

As an example, please consider the most recent project completed by UC on the 
South slope of Claremont Canyon.

On time? The project was put out for bid in early July of 2006 with a targeted 
completion date PRIOR TO THE RAINY SEASON. The project slipped into the rainy 
season and was not completed until early February. The specific prohibition 
against implementing this project during the rainy season was completely 
ignored, as were the requirements for erosion control measures.

On budget? While UC undoubtedly spent the money that they had for this project, 
the hallmark of UC's project was removing the maximum number of trees per 
dollar spent, irrespective of the environmental damage done. At one point in 
this project, felled trees were falling into the roadway while traffic was flowing 
with no traffic control... is this evidence of a well-managed project? If it was 
on budget it was only because the project ignored safety concerns and environmental 
mitigations specifically mandated, but which would have resulted in additional expense.

In compliance with environmental law? The EIR used to justify this project 
contained almost nothing about this or similar projects, there was no tiered 
EIR, the work plan (which contained the EIR mandated mitigations) was not 
followed, and the project is still not in compliance with these mitigations 
six months after completion:

- all stumps were to be no more than 4' above grade, yet the majority are in 
excess of 2 feet above grade

- erosion control measures were never implemented

Page 21. UC asserts their methods "have shown no environmental problems 
or community complaints". While the first part of this statement is a 
completely unfounded assertion, the second is an outright falsehood. UC has 
not reported the fact that there has been considerable local opposition to 
what they have been doing. In fact there have been specific, documented 
complaints since prior to the writing of these grants, yet these inputs 
were unreported.

Page 27. UC goes on to assert that "no issues have arisen, and the work 
has been widely met with positive.....even by people who have an axe to grind 
with UC". Needless to say, this statement is simply not true. Various groups 
have expressed their opposition to what UC has been doing, and our group has 
provided UC with over 200 petition signatures demanding that they stop, yet 
they continue to make statements such as these in grant applications.

CLAREMONT CANYON CONSERVANCY
A COMMUNITY BASED ORGANIZATION FORMED IN 2001
TO SUPPORT LONG TERM STEWARDSHIP OF CLAREMONT CANYON
www.ClaremontCanyon.Org 
					
August 24, 2007					
					
Mr. Alessandro Amaglio 					
Environmental Officer					
FEMA Region 9					
1111 Broadway, Suite 1200 					
Oakland, CA 94607					
					
Re: Support for FEMA grants PDMO5-PJ 19 and 20					
					
Dear Mr. Amaglio,					

I am writing to you as President of the Claremont Canyon Conservancy, in 
support of the University of California's FEMA grants PDMO5-PJ 19 and 20. 
We are a nonprofit community-based membership organization, representing 
over 400 households in the immediate area of Claremont Canyon. The 
Conservancy works in close cooperation with all of the regional landholders, 
including the Cities of Oakland and Berkeley; the East 
Bay Regional Parks District (EBRPD); and the University of California. 
Our organization was formed to facilitate communication between these 
various agencies and municipalities, to provide volunteer support, 
and to contribute additional funding for vegetation management and 
restoration projects as necessary.

This critical segment of Bay Area's wildland-urban interface is an 
important and diverse ecological corridor, but it is threatened by an 
ever-growing and unstable population of fire-prone, blue- and red-gum 
eucalyptus trees. The Pre-Disaster Mitigation Grant approved awarded 
by FEMA to the University and its partners at the City of Oakland and 
EBRPD is a critical link in protecting the East Bay from yet another 
devastating Diablo Wind-driven firestorm, for which these trees are 
an otherwise inevitable fuel source. The work that this grant will 
facilitate is essential, responsible, and potentially represents a 
model for local community-Federal agency partnership.

We feel that the University has been an exemplary steward of its portion 
of Claremont Canyon. Over the past six years, innovative approaches to 
wildfire fuel reduction, invasive weed control and habitat restoration 
have been implemented under the leadership of Tom Klatt of the Office of 
Emergency Preparedness. The Conservancy has been proud to partner with 
the University in this work, which has been widely publicized the local 
print and television media, as well as in our regular neighborhood 
meetings, quarterly newsletters, and website. We maintain a Memorandum 
of Understanding with the University to provide community volunteers on 
a monthly basis to assist in post-logging remediation and restoration projects.

For its part, the University has supported complimentary work of the 
Conservancy on adjacent lands, including the removal of hundreds of 
blue gum eucalyptus and Monterey pines on EBRPD land in 2006. This 
work was funded by generous grants from the U.S. Fish and Wildlife 
Service (Grant numbers 04FWS0001, 04FWS0002, and 04FWS0003), funds 
from City of Oakland, and over $25,000 in private funds contributed 
by neighbors  a telling measure of community support for eucalyptus 
removal. Furthermore, the Conservancy polled its membership about 
this (and other topics) in 2006; over 90% firmly supported eucalyptus removal.

In summary, I would encourage you to respond to the pressing needs of the 
East Bay community, and the expertise and experience of the wildland fire 
professionals who unanimously support the scope of work outlined in FEMA 
grants PDMO5-PJ 19 and 20. It is an excellent plan, and enjoys enormous 
community support. Please feel free to contact me for any elaboration or 
clarification of the issues raised in this letter.

Kind regards,

[Signed]

Martin Holden, President
The Claremont Canyon Conservancy

August 26, 2007

Mr. Alessandro Amaglio 
Environmental Officer
FEMA Region 9
1111 Broadway, Suite 1200 
Oakland, CA 94607

Re: FEMA grants PDMO5-PJ 19 and 20 

Dear Mr. Amaglio,

I have written to you previously in support of FEMA grants 
PDMO5-PJ 19 and 20, detailing other successful fuel-reduction 
projects in Claremont Canyon, and the overwhelming support that 
this kind of work enjoys in our community. This letter comes 
from myself as a concerned private citizen, and is intended to 
address some misconceptions that have recently been circulated 
by a group calling itself the "Hills Conservation Network".

To the best of my knowledge, this group consists of less than a 
dozen individuals. You should be aware that it is not registered 
as a nonprofit with the California Attorney General's Office. 
Although it often refers to "directors" in its correspondence, 
it is not required to maintain a board of directors, appoint 
other officers, or post any financial reports with the state. 
It is also not subject to the Nonprofit Integrity Act of 2004, 
which prohibits "committing unfair or deceptive acts, or engaging 
in fraudulent conduct." Since its formation last year, this group 
has devoted itself to opposing projects involving hazardous tree 
removal in our region  a position counter to the stated policies 
and goals of all local fire departments, land agencies, and conservation groups.

One assertion often made by this group is that no significant 
wildfires have occurred in Claremont Canyon. In fact, the canyon 
has suffered several serious fires in recent decades. A partial list follows:

* The 1946 Buckingham/Norfolk Fire burned approximately 1,000 acres.

* According to the East bay Regional Parks District, two other 
large fires also occurred in Claremont Canyon between 1946 and 1956.

* The 1970 Buckingham/Norfolk Fire burned 204 acres and 37 homes.

* The 1991 Tunnel Fire or "Oakland-Berkeley Firestorm" burned 14 acres 
of wildlands in the Claremont Canyon Regional Preserve and dozens of 
homes along the southern ridge of the canyon. (In total, 1600 
acres in the East Bay Hills were burned in this fire, 25 lives were lost, 
3354 homes and 456 apartments destroyed, at an estimated cost of $1.5 billion.)

* The 1995 Claremont Avenue Fire burned several acres
 in the mid-canyon area, seriously injuring a firefighter.

* The 1999 Stonewall Fire burned approximately 10 acres on the western 
edge of the canyon, adjacent to the University's Clark Kerr campus 
and the historic Claremont Hotel. Fortunately, this fire was successfully 
brought under control before Diablo wind conditions began the following day.

You may also hear the claim that the East Bay Regional Parks District 
does not consider Claremont Canyon to pose a fire danger, and that 
it does not intend to use voter-approved (Measure CC) fuels-reduction 
funding there. In fact, the EBRPD has made Claremont Canyon a priority 
in the allocation of wildfire-prevention funding, based in part on the 
fire history outlined above. Though the EBRPD may also use some of its 
own anticipated FEMA funding in the canyon, I have been assured by 
EBRPD Chief of Planning & Stewardship Brian Wiese that "There are 
fuels (and eucalyptus) concerns in the Canyon which will be addressed 
in the [Measure CC] wildfire plan and EIR, and in resulting fuels 
management projects." (Personal communication, August 17, 2007.) 
Furthermore, I can attest that EBRPD and University staff work 
together cooperatively and respectfully in the management of their 
adjacent wildland properties.

Finally, some claim that there is no evidence that eucalyptus trees 
contributed to the devastating 1991 Tunnel Fire. In fact, there is 
voluminous testimony from both firefighters and fire survivors 
about the role that eucalyptus played in increasing the flame height, 
intensity and spotting range of that fire. Australian researchers 
have authoritatively documented the role of eucalyptus in wildland 
fires there, and it has become increasingly clear to forestry 
scientists and public-safety professionals that eucalyptus plays a 
similar role in many California wildfires. According to the U.S. 
Fire Administration Report on the "East Bay Hills Fire" (Report 060 
of the FEMA Major Fires Investigation Project), "the introduction 
of vegetative species which are not native to the area has dramatically 
impacted fuel loading. This is particularly true of the introduction 
of eucalyptus. Fuel accumulations in some areas under eucalyptus 
plantations have been estimated between 30 and 40 tons per acre." 
This is exactly the type of fuel loading that contributed to the 
Tunnel Fire, and exists today in Claremont Canyon.

In summary, I would strongly encourage you to "consider the source" 
when reviewing public comments on this matter, and to give more 
weight to the considered opinions of firefighting and public-safety 
professionals than to those of impassioned amateurs, however 
well-intentioned they may be.

Sincerely,

[Signed]

Martin Holden

September 7, 2007
Mr. Alessandro Amaglio 		
Environmental Officer		
FEMA Region 9		
1111 Broadway, Suite 1200 		
Oakland, CA 94607		

Dear Alessandro,

This letter is submitted by me as a private citizen in support 
of the University of California, Berkeley's FEMA grant PDMO5-PJ 19, & 20.

Today's Claremont and Strawberry Canyon eucalyptus fire concerns are 
directly related to the type of tree planted in dense failed timber 
plantations at the beginning of the last century. For a number of 
reasons, the trees were not thinned when the privately owned plantations 
were young, and the current eucalyptus groves are now more like 
dense thickets than healthy, safe woodlands. These groves like 
may others in the hills have not been maintained for almost 100-years, 
and are increasingly being viewed by fire officials and homeowners 
as a major factor in the wildfire risks faced today by nearby residents.

In March of 1973, H.H. Biswell, Professor of Forestry and Conservation 
at the University of California, Berkeley made this prophetic statement. 
"When eucalyptus waste catches fire, an updraft is created and strong 
winds may blow-flaming bark for a great distance. I think the eucalyptus 
is the worst tree anywhere as far as fire hazard is concerned. If 
some of that flaming bark should be blown on to shake roofs in the 
hills we might have a firestorm that would literally suck the roofs 
off the houses. People might be trapped".

To be fair, the 1991 Tunnel Fire was not primarily a eucalyptus fire 
in origin. The destructiveness of the Tunnel Fire can be attributed 
to a number of conditions including extreme Diablo winds blowing over 
high ridge tops and down steep leeward slopes into residential areas, 
pine groves igniting, eucalyptus groves igniting, brush igniting, 
densely spaced unprepared homes igniting, narrow streets, and unsuccessful 
fire fighting efforts, etc. However, the issue that I would like to 
focus on in this letter is how the Universities eucalyptus trees along 
the ridge and hillsides of Claremont and Strawberry Canyons might 
contribute to a major fire today, and not just the role of trees 
during the 1991 Tunnel Fire or during the many other East Bay Hill 
fires where eucalyptus or pine were implicated.

The debate about the value, appropriateness, and potential risks of 
having eucalyptus trees in dense groves has long been a hot topic. 
The 1995 Hills Emergency Forum (HEF) Fire Hazard Mitigation and Fuel 
Management Plan (which I worked on with UCB and other agency staff 
and consultant teams during the four years following the 1991 Tunnel Fire) 
determined that eucalyptus trees and the burning embers that they can 
produce in a wind driven wildfire are an important factor in the 
fire risks faced by Oakland and Berkeley Hill residents. The 1995 
HEF Plan classified the Universities Groves in Claremont and 
Strawberry Canyons as 20-year old eucalyptus. The 20-year old label 
had nothing to do with age, but did relate to the structure of groves 
with too many trees per acre, too much flammable fuel, and a shrub 
understory with fuel ladders up to the crown. The Universities groves 
were also determined to have the potential for crown fire. The 
treatment recommendations for "20-year old" eucalyptus on page 16 
of the HEF Plan's Technical Appendices covering Treatment Prescription 
Descriptions by Vegetation Type included a menu of options for land 
owners to consider including "Convert to more fire safe vegetation type, 
and Avoid moving towards second growth eucalyptus". These are the options 
that the University has wisely selected for its ridge top and hillside 
properties.

It would be a serious mistake for those who want to keep eucalyptus and 
pine groves in the upper reaches of either canyon to conclude that minimum 
work needs to be done because trees are not the only potential source 
for burning embers. And, that it would be more efficient for homeowners 
on Panoramic Ridge and Claremont Canyon to retrofit their homes and 
maintain landscapes that would resist embers and firebrands coming 
from all sources in a major wildfire including eucalyptus and structures.

Unfortunately, we have a history of assuming one level of wildfire 
behavior in places like Claremont and Strawberry Canyons, and then 
professing surprise when something much more spectacular and disastrous 
happens. After experiencing how pine, eucalyptus, brush, and homes 
burned during high winds in the 1991 Tunnel fire, the disastrous 
fires of 2003 in San Diego, and even the Tahoe Angora fire in 2007, 
we should expect flames during a Diablo wind fire in the hills well 
above 150' in eucalyptus and pine trees, and ember showers blowing 
far ahead of the moving flame front onto lower canyon brush lands 
and unprepared residential areas. This type of extreme fire behavior 
happened in all three of the fires mentioned above, leaving firefighters 
and homeowners in retreat until the winds died, and only then were 
traditional firefighting measures successful. Too much wind, too 
much fuel, lack of defensible space, unprepared homes, and heroic 
but unsuccessful fire fighting efforts have all been factors in 
home loss.

Recent research into the major causes of structure loss during wind 
driven wildfire document the fact that many homes are lost because 
of burning embers and not just from the fires flaming front. Trying 
to predict the distance that burning embers and firebrands would 
travel and where will they land is like predicting where and how 
strong the wind will blow. In Australia, strips of burning eucalyptus 
bark and leaves have been reported to travel several miles ahead of a 
quick moving wind driven wildfire. Burning embers (some have speculated 
from the eucalyptus groves along the ridge) in the 1991 Tunnel Fire blew a
cross highway 24 to ignite spot fires at Temescal Park, and then onto 
upper Rockridge Neighborhoods. Therefore, the distance between a 
eucalyptus or pine grove and its closest residential neighborhood 
will not be the limiting factor in home exposure to embers and 
firebrands. However, ember flight distance may be a very critical 
factor in how and were firefighting will occur as well as the evacuation 
time for homeowners.

Extreme fire behavior is largely unpredictable. So, resident and 
landowner efforts in areas where exposure is predictable should be 
focused on reasoned and well thought out measures for wildland 
management, for strategically located fuelbreaks, and for homes 
and landscapes that are designed and maintained to meet state and 
city codes for residences in the Urban/Wildland Interface. The 1991 
Tunnel wildfire demonstrated the futility of trying to stop a major 
wind-driven wildfire on windy ridge tops and steep hillsides covered 
by dense vegetation with unprepared homes in dense hillside 
residential areas. Public agencies (especially the University) 
and hill residents have made major improvements over the 
last 16 years, but there is still much to do.

Over the past five years, I have observed the University working 
with the Claremont Conservancy in Claremont Canyon, the Regional 
Park District along Frowning Ridge, and with other HEF member 
agencies owning property along Grizzly Peak Boulevard. I have also 
met in the field with Tom Klatt many times, before and after 
retirement, to provide advice, comment on, and support the work of 
the University during their eucalyptus and pine conversion projects.

I would be very reluctant to ask the University, as the recently 
formed Hills Conservancy Network has done, to manage its dense 
eucalyptus groves on ridge top and steep leeward slopes above 
residences. There is absolutely nothing wrong with fire safe, 
and maintained eucalyptus woodlands that do not represent a 
potential threat to adjacent residential areas. There will be 
many such groves located away from homes on public and private 
lands east of the main ridge where fire risks are reduced and 
management is more feasible, and even in some locations where 
management is not required. However, after working with 
eucalyptus for more than 40-years, my personal opinion is 
that dense hillside blue gum eucalyptus plantations virtually 
defy reasonable management. Trees will sucker, resprout, and 
reseed at a rate that can't be contained without significant 
expenditures and repeated chemical, hand, and mechanical 
treatments making these groves maintenance and fire liabilities 
long into the future.

If fire safety, reasonable economics, and native vegetation are 
important goals for University property, then the Universities 
ridge top and mid-slope eucalyptus groves in Claremont and 
Strawberry Canyons should be converted to more fire safe 
native vegetation that will do very well when the eucalyptus 
trees are removed. The University has made excellent progress 
in converting its eucalyptus dominated areas in the upper end 
of both canyons to native trees and shrubs, and I would expect 
they would be able to do the same with their remaining FEMA 
projects. I support the Universities on going conversion 
projects, and hope you will approve the use of the FEMA 
funding as requested.

Sincerely,

[Signed]

Jerry U. Kent
Retired August 31, 2003- East Bay Regional Park 
District Assistant General Manager

_______________________________________________________________________________________

Appendix E: LIST OF INTERESTED PARTIES

Marcia Rentschler
Manager, Hazard Mitigation Program
California Governors Office of Emergency Services
3650 Schriever Avenue
Mather, CA 95655

Dennis Castrillo
Environmental Officer
California Governors Office of Emergency Services
3650 Schriever Avenue
Mather, CA 95655

Tom Klatt
Manager, Office of Emergency Preparedness
University of California at Berkeley
Room 1, Sproul Hall
Berkeley, CA 94720-1199

Directors
Hills Conservation Network
1305 Alvarado Road
Berkeley, CA 94705

Martin Holden
President, The Claremont Canyon Conservancy
P.O. Box 5551
Berkeley, CA 94705

Mr. David Kessler
President, North Hills Phoenix Association
116 Vincente Road
Berkeley, CA 94705-1606

Mr. Jerry Kent
3359 No. Lucille Lane
Lafayette, CA 94510

Councilmember Jane Brunner
Oakland City Council District 1
1 Frank Ogawa Plaza, 2nd floor
Oakland, CA 94612

Fire Chief Dan Farrell
Oakland Fire Department
150 Frank Ogawa Plaza, 3rd floor
Oakland, CA 94612

Councilmember Jean Quan
Oakland City Council District 4
1 Frank Ogawa Plaza, 2nd floor
Oakland, CA 94612

Fire Commissioner Gordon Piper
33 Hiller Drive
Oakland, CA 94618

Councilmember Gordon Wozniak
Berkeley City Council District 8
2180 Milvia Street
Berkeley, CA 94704

Councilmember Betty Olds
Berkeley City Council District 6
2180 Milvia Street
Berkeley, CA 94704

Berkeley Fire and Disaster Commission
President
2180 Milvia Street
Berkeley, CA 94704

Cheryl Miller
Amphion Environmental
1404 Franklin, Ste. 300
Oakland, CA 94612

_______________________________________________________________________________________