May 17, 2002

Ms. Susan Stratton, Ph.D.
pdcpinfo@cdfa.ca.gov
Department of General Services
Real Estate Services Division
P.O. Box 989052
West Sacramento, CA 95798-9052

Re: Comments: Draft Environmental Impact Report for Pierce's Disease Control Program, California Department of Agriculture (SCH# 2001032084).

Dear Ms. Stratton:

This letter is written on behalf of the Environmental Health Network (EHN) by Barbara Wilkie, current board president.

EHN thanks California Department of Food & Agriculture for the opportunity to comment on the Draft Environmental Report (DEIR) for the Pierce's Disease Control Program -- otherwise known by the vector's name, the Glassy-Winged Sharpshooter (GWSS). As I have just received a copy of the DEIR, I will not be giving a point by point comment regarding it. I will, however, ask that the state of California look to the safer means for GWSS control that have been provided by various reliable sources.

About EHN

EHN is an organization which was established in the early 1980s to lend support to and to advocate on behalf of people who are living with chemically injury. Chemical injury, or Multiple Chemical Sensitivity, is manifested by a series of chronic illnesses that can be reflected in serious debilitating and disabling effects such as -- but not limited to -- brain damage, cancers, asthma, and various diseases associated with central nervous system disorders. MCS affects people of all ages and of all races. MCS, like the synthetic chemicals that bring it on, knows no boundaries.

Premiss

U.S. EPA Administrator, Christine Todd Whitman, when governor of New Jersey stated in a speech in October 2000 before the National Academy of Sciences in Washington, D.C.:

"[P]olicymakers need to take a precautionary approach to environmental protection.... We must acknowledge that uncertainty is inherent in managing natural resources, recognize it is usually easier to prevent environmental damage than to repair it later, and shift the burden of proof away from those advocating protection toward those proposing an action that may be harmful." (Source: Californians for Pesticide Reform (CPR))

GWSS Control

EHN is encouraged to learn that there is no planned aerial spraying over urban areas, but that leaves urban areas still subjected to the use of pesticides. (A-10) Indeed, county Agricultural Commissioners, my own (Alameda County) included, have gone on record to state that if given the order to pesticide they shall. Also, the statement that there will be no aerial spraying over urban areas brings little comfort when we take a moment to reflect upon today's meeting of urban and rural communities. Often we are talking about a narrow road separating the two worlds. As "aerial spraying" and "pesticide drift" are seemingly synonymous, the two worlds become one. Additionally, pesticides often are not sprayed properly "in accordance with existing regulations and permits." Nor is it reassuring to read that pesticides "would be used according to registration and label directions." (A-10) All to often that is not the case.

But even when pesticides are applied according to label directions by professional, well-trained applicators with proper oversight by authorities, these synthetic chemical products still carry out their mission. They are toxic. They do what toxins do. Synthetic chemical pesticides are designed to cause injury and death. That's just what toxins do . . . it's the nature of the beast.

But let's step back a moment to look at those supposedly reassuring words: "used according to registration and label directions."

Synthetic chemical pesticide products are released to market without adequate testing. Pesticides have a history of being phased out of use after several years on the market. This tells the astute individual that there is not enough long-term and systemic evidence supporting the supposed safety of these chemicals before marketing. And there's yet another problem, which is inherent in that term "phased out." For products may be continued to be used that have already been declared harmful . . . but to support industry -- obviously not public health -- those toxic products are allowed to be used for a set period of time into the future. A question comes quickly to mind: How long will it be before we perhaps learn that Carbaryl and other GWSS-designer pesticides will be phased out?

Another problem comes to the fore when we realize that even in reading a label, one never learns of all of the toxins existing in a pesticide due to the fact that many toxins are hidden by the misnomer: INERT. Using the word "inert" is the pesticide industry's method of protecting from public information all of the toxins (proprietary ingredients) it uses in the manufacture of that particular 'cide (kill).

Another problem arises if we consider that aerial spraying is not appropriate for urban areas, but fine for rural areas. This leaves something to be desired . . . Are we really reading that rural populations are as expendable as our beneficial bugs and wildlife that are not on the endangered species list? This certainly seems to be the case if we take the time to read -- or even skim -- the prodigious reports by various pesticide reform agencies on the health of our farm workers. Time and again we learn that our farm workers are suffering debilitating and disabling diseases, they lack appropriate healthcare, and suffer premature death. And sadly, we are learning all too often that families forming the urban sectors of our society are also living with debilitating and disabling diseases, they lack appropriate healthcare, and suffer premature death. Two worlds are one. Correction, let's make that: Three worlds are one! For daily we learn of our fish and wildlife suffering death, disfigurement, adverse effects of hormonal disruption, . . .

There is a pattern here: PESTICIDES. Pesticides are poisons, they are nerve agents. One of the pesticides suggested for use against the GWSS is Carbaryl. Carbaryl is a wide-spectrum carbamate insecticide which is lethal to many beneficial insects, including bees. But it is also harmful to human beings. The No Spray Action Network informs us about Carbaryl:

Health Effects: moderately to very toxic to humans; nerve toxin and suspected endocrine disrupter; direct contact with skin or eyes with moderate levels of this pesticide can cause burns; inhalation or ingestion of very large amounts can be toxic to nervous or respiratory systems, resulting in nausea, stomach cramps, diarrhea and excessive salivation; other symptoms at high dose include sweating, blurring of vision, loss of coordination and convulsions.

Ecological Effects: highly toxic to crustaceans and insects; moderately toxic to fish, zooplankton and earthworms; kills beneficial insects such as bees, as well as pests. (http://www.freestone.com/nospray/pesthealtheffects.html)

Safe application?

There is little comfort to learn that pesticides will be applied "in accordance with all laws and regulation of the State of California." Pesticides are toxins. Until we know the answers to why human beings of all ages and races are suffering "unexplained" skyrocketing rates of various chronic illnesses, including but not limited to, Asthma, Attention Deficit Disorder, Autism, various cancers, MCS, Parkinson's, Alzheimer's, etc., we should be looking for safer means of controlling the GWSS, vector of Pierce's Disease.

Alas, I have found no effective provisions in this DEIR for fragile populations of humans. Just as beekeepers cannot easily move out their bees to save those lives, there is no mechanism in place to move out people. But then larger questions loom. What if you did wish to move those who are acutely ill, very young or very old, or pregnant? Where would they go that was safe and how long would you have to keep them sheltered? And how safe would that shelter be?

For the already chemically injured, shelters have proven to be a decided health risk as synthetic chemical products are used for cleaning, and the already chemically injured individual's body cannot tolerate those chemicals. Consequently, we may be told to "shelter in place." Would it were we were on a "threatened/endangered species" list such as a precious few of our fish and wildlife, for then there could be agreement between agencies for "appropriate mitigation measures to be taken in these sensitive areas." (A-13) As that is not the case, we human beings, along with beneficial bugs, and fish and wildlife not covered by the endangered species act are considered expendable. "Acceptable risk."

Possible "appropriate mitigation measures to be taken"

From No Spray Action Network's "Health and Ecological Effects of Pesticides Used to Combat the Glassy-Winged Sharpshooter" at http://www.freestone.com/nospray/pesthealtheffects.html

Non-chemical and least-toxic approaches are safer and more effective.

Short-term solutions:

• Control of glassy-winged sharpshooter using quarantine measures; beneficial insects, e.g. parasitic wasps; physical barriers and trap crops; anti-feedant and repellent strategies, such as kaolin clay; and confusion strategies, such as reflective tape.

• Control of Pierce's Disease by pruning, using micronutrient treatments to boost plant resistance to infection, and identifying naturally-occurring bacteria that inhibit spread of the bacteria that cause Pierce's Disease. Long-term solutions:
  • Increase plant health by building healthy soil through composting, cover cropping and other organic and biologically-based practices.

  • Identify naturally resistant cultivars of not just grapes, but also almonds, stone fruits, and other plants potentially affected by related diseases.

  • Research and develop effective intercropping, crop rotation and other strategies to break pest and disease life cycles.

  • Reduce risk by increasing crop diversity and naturally-occurring genetic diversity within crops.

Information Sources:
Report of the Pierce's Disease Research and Emergency Response Task Force, University of California, Department of Agriculture and Natural Resources, http://danr.ucop.edu/news/

Pest Management at the Crossroads, Consumers Union, 1996, www.nrdc.org

Harvest of Hope, Natural Resources Defense Council , 1991, www.nrdc.org

The glassy-winged sharpshooter Homalodisca coagulata is in the leaf-hopper family of insects (Cicadellidae) that are largely known to fly during the night and these insects are known from the diets of bats. Although I am unaware of any studies that specifically document this insect as a bat prey item, I would say that it is highly likely that bats eat them. Bats like many animals are opportunists and can and will make use of any food items that are abundant. A simple study of placing bats in an enclosure with a known number of these insects would conclusively demonstrate that they are eaten.

Even chemicals are not a cure all for insect pests and there are many instances where they do more harm than good either by removing predatory insects or by introducing poisons into our lives. The wise use of integrated insect control techniques is a concept that is more easily overcome [accomplished] through education.

I hope this helps.

Brian Keeley
Bat Conservation International http://www.batcon.org/

Conclusion

EHN certainly appreciates CDFA's efforts to bring to the public's attention the Pierce's Disease Control Program. We feel we all must learn more about the biology of GWSS and CDFA's website takes us a step in that direction.

Alas, CDFA has spent a great deal of time, effort and money in the public relations campaign around the concept of poisoning the GWSS into submission. EHN believes an equal amount of time, effort and money should be invested in investigating and implementing environmentally responsible methods of controlling the spread of Pierce's disease.

In the interest of the public's right to know, it would be a step in the right direction of presenting a more balanced view if CDFA could build links to organizations that provide information on the negative impacts of reliance upon synthetic pesticides. Following are just a few of the many excellent sources:

Beyond Pesticides/NCAMP and their:
" What To Do In A Pesticide Emergency"
http://www.ncamp.org/todo1.html

"What's In a Pesticide?"
http://www.beyondpesticides.org/main.html

B.I.R.C.
http://www.keyed.com/birc/index.html

Californians for Pesticide Reform (CPR)
http://www.pesticidereform.org

Canaries - NO ACCEPTABLE RISK - Campaign
http://www.noacceptablerisk.com/

East Bay Pesticide Alert
http://www.dontspraycalifornia.org

Environmental Health Network (EHN)
http://www.ehnca.org

Get Set, Inc. (AKA, Get IPM)
http://www.getipm.com/

No Spray Action Network
http://www.freestone.com/nospray/

Pesticide Action Network North America (PANNA)
http://www.panna.org

And last but not least, please make easily available California's own:
Pesticide Illness Reporting Form - PDF format
http://www.oehha.ca.gov/pesticides/pdf/PIR_99.pdf

Return to EHN's Action Letters Index
http://ehnca.org/www/actnletr/acletin.htm

EHN at http://www.ehnca.org