[Fosc] OT: Light brown apple moth spraying program

Kathy Kramer kathy at kathykramerconsulting.net
Wed Mar 19 07:28:32 PDT 2008


Dear Friends,

You may have heard recently about plans to spray the Bay Area for the  
light brown apple moth (LBAM).  I don't plan to send out a lot of e- 
mails about this, but if you would like to be taken off this list,  
please let me know.  In case this is an issue that resonates with you,  
below is a summary of the treatment program.  A sample letter to the  
Calif. Dept. of Food and Agriculture follows:

Treatment Plan
The Cal. Dept. of Food and Agriculture (CDFA) plans to start aerially  
spraying a pheromone based pesticide Aug. 1, 2008,  in San Francisco,  
San Mateo, Marin, Alameda, and Contra Costa Counties to eradicate the  
Light Brown Apple Moth (LBAM).   (There is potential for drift into  
adjacent counties and cities.)  The CDFA began spraying Monterey and  
Santa Cruz Counties last fall using "Checkmate." They plan to use a  
similar, but as of yet undetermined, pesticide when they resume  
spraying June 1, 2008, in Monterey and Santa Cruz and August 1, 2008,  
in the Bay Area.

In Santa Cruz and Monterey,over 600 individuals reported ill effects  
(muscle aches, asthma, shortness of breath, skin rashes, stomach  
pains, menses problems, etc.) after the sprayings last fall. Hundreds  
of birds were also found dead within 3 days of the spray.  It was the  
first time this product had ever been applied aerially (by airplane)  
over populated urban areas in the U.S. or anywhere.  The chemical used  
contained additional chemical compounds (many known to be toxic) in  
addition to the synthetic pheromone.  The pheromone is time released  
into the environment over 30-90 days from microscopic plastic capsules  
which break down overtime, and some of which are small enough to be  
inhaled into the deep lung and not expelled.  Airplanes will spray the  
pheromone based pesticide regularly to ensure continuous release of  
the pheromone (to confuse the moths' mating behavior) over the course  
of 2-5 years or as long as takes.

Some scientists question whether the moth even prevents a significant  
threat to agriculture (apart from Quarantine laws on produce from  
areas which are known to have the moth present).  No crop damage has  
occurred in California.  In addition, the effectiveness of the aerial  
spray plan is unknown, and said by one expert to have "near zero"  
chance of success.  The CDFA also plans to start ground treatments  
that contain pesticides.

An Environmental Impact Report on the eradication program will be  
released this fall (after the  Bay Area spraying has begun.)  Comments  
on what the public would like to see addressed in the EIR are due  
tomorrow.  I apologize for this late notice.

Should you feel like weighing in, a draft letter to the CDFA is  
below.  It can be e-mailed to:

jrains at cdfa.ca.gov

and cc'd to: EIR at lbamspray.com




Best regards,



Kathy Kramer

(Peter's Mom)





Your address here

March 19, 2008



California Department of Food and Agriculture Plant Health & Pest  
Prevention Services

1220 N Street, Room A-316

Sacramento, CA 95814

ATTN: Jim Rains, Staff Environmental Scientist

jrains at cdfa.ca.gov

cc to: EIR at lbamspray.com



Dear Mr. Rains,



There are a number of questions I would like to see addressed in the  
light brown apple moth (LBAM) EIR.  These are listed below.

1) Why is the EIR being released after the spraying program has begun?




2) Dr. Daniel Harder (botanist and Executive Director of the U.C.  
Santa Cruz Arboretum) released a report March 6, 2008,  In it he  
indicates the LBAM is not a serious threat to agriculture in a  
biological way in New Zealand, which has a similar climate and  
ecosystem to California.  LBAM may be adapting to our local  
environment and need no intervention, or very little, such as much  
less toxic IPM methods. LBAM likely already has natural predators.



3) Dr. James Carey, UC Davis entomologist, says LBAM has been here  
decades, not one year as the CDFA claims, and has near zero chance of  
eradication. If it has been here decades and caused no crop damage  
(which the CDFA acknowledges) then why is this declared an  
agricultural emergency?  It appears that this is because of a  
quarantine---not because of actual potential for massive crop damage.   
If so, is quarantined produce a reason to spray pesticides on millions  
of people?



4) Health impacts on humans, animals, birds, and aquatic life have not  
been adequately considered.  700-2300 birds were found dead the day  
after spraying in Santa Cruz and Monterey and the CDFA and other State  
departments deny any connection.  Two previously healthy pets died the  
day after spraying. 643 reports of health effects in humans are being  
dismissed as hysteria, yet the complaints are consistent with what  
would be expected effects from numerous chemicals included in the  
spray.  In addition, the State and Federal agencies pushing the  
spraying program know nothing about potential long term impacts, and  
OSHA acknowledges that children, the elderly and those with  
respiratory ailments may be differentially impacted.



5) The chemical is NOT just a pheromone.  It includes "inert"  
ingredients that are known to be toxic (e.g. carcinogenic, mutagenic,  
liver toxic, dermal irritant, reproductive harm, birth defects), and  
that are not to be inhaled. The pheromone is encapsulated in plastic  
capsules, some of which are small enough to be inhaled into the deep  
lung.  With the smallest particles at 10 microns (U.C. Davis report on  
the product sprayed in Santa Cruz and Monterey last fall, and released  
in December 2007), these are considered harmful to human health, like  
other particulate matter.  In addition, will the capsules time-release  
their ingredients in our lungs? We have no information on how inhaling  
(and ingesting) the plastic itself will impact human and wildlife  
health.  The pheromone is a synthetic pheromone with unknown effects  
on humans and other animals.  The concoction includes a surfactant  
which could have caused the bird deaths. The synergistic effects of  
all the ingredients combined is completely unknown.



6) The CDFA claims that the pheromone-based pesticide to be used  
contains such low doses of chemicals that it will cause no harm.  Yet,  
the nature of the spray planned entails continuous exposure via time  
released capsules, sprayed three nights in a row every month (unless  
you find a new version which we will not have time to investigate  
before the spraying but will contain essentially the same components)  
for 2 -5 years or indefinitely.  The capsules release their  
ingredients over 30 to 90 days. In addition the particles can remain  
suspended in the air for 12 months. This ensures continuous exposure  
over the course of years.  There is no escape even if you leave town  
during the actual spraying.



7) The manufacturer of the chemical, Suterra, indicates on the  
packaging and communicated to farmers that Checkmate is not to be  
applied near irrigation canals as the pheromone could concentrate in  
runoff. What do you think happens when you aerial spray a substance?  
It ends up in all water--streams, gutters, the Bay, standing water in  
playgrounds, parks, etc.



8) What are the water quality impacts of the whole program (telephone  
pole painting and twist tie chemicals, as well as the spraying?



9) What impacts to other species besides the light brown apple moth,  
will there be?  For example to other moths, butterflies, or bees?



A hard copy of this letter will be sent by mail.



Sincerely,



Kathy Kramer
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