April 30, 2008

Moratorium on Statewide Spray Passed Unanimously: Long-Term Studies Remain to Be Seen

The following article may be reprinted for informational purposes only with full author attribution and a link back to this site.

Members of the Senate passed a resolution introduced by Sen. Carole Migden (D-CA) on Monday, unanimously voting to halt all aerial spraying in California until the CDFA "can demonstrate that the pheromone compound it intends to use is both safe to humans and effective at eradicating the light brown apple moth." The 7-0 vote by the California Senate Environmental Quality Committee goes beyond Gov. Schwarzenegger's recent decision to halt spraying statewide until around August 17, when the results of limited testing on acute health impacts are expected. This latest legislation sends the clear, albeit unusual, message that logic trumps politics when it comes to public safety.

The strength of the resolution lies in its requirement that the CDFA prove two things:
  1. That the spray is safe to humans.
  2. That the spray is an effective way to eradicate the light brown apple moth.
The CDFA may have their work cut out for them. According to a recent panel of bug experts including Jim Carey, an etymologist who has worked with CDFA in the past, aerial spraying of pheromone-based chemicals is "ineffective even as a control tool." The method has never been used to successfully eradicate the moth, and current testing to identify the formula's potential to do so is still incomplete.

This latest Senate resolution, along with a judge's recent halting of the spraying in Santa Cruz county, would seem to put the burden of safety and efficacy back in the lap of the CDFA, which is exactly where it belongs. There remains, however, some skepticism about whether or not CDFA can provide such reassurances.

Exactly how the government intends to test for the as-yet-undisclosed chemical's safety, and what health impacts they'll test for, is still unknown. According to a San Francisco Chronicle report, the state will conduct "
a series of tests on possible eye, inhalation, respiratory and other potential irritants." Research Director Caroline Cox, of the Center for Environmental Health, expressed reservations about the lack of attention to potential long-term health effects, noting that the proposed tests "do not include any testing for important long-term health problems like cancer, birth defects, or genetic damage."

The testing will be done by a USDA contractor, according to the Chronicle report, which may also raise questions about a potential conflict of interest. The USDA, after all, has been working hand-in-hand with the CDFA to develop the current eradication plan. Given the fact that the government agencies advocating the spray and the citizen groups opposing the spray both have a clear agenda, it may be difficult to find an unbiased middle ground. But that's exactly what needs to happen if any real solutions to the LBAM infestation are to be found.

Additional References:
Full text of the passed resolution.
Press release about the legislation.
Recap of expert panel presentation.
Judge, Schwarzenegger Stop Apple Moth Spraying (CBS5)

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April 24, 2008

Judge Suspends Santa Cruz Spray: What Happened to the "Emergency?"

The aerial spray controversy as played out in the media and among citizen groups has so far been framed as a health and environmental debate, and a California Supreme Court judge has brought a sliver of common sense to this framework today:
"A judge today ordered aerial spraying in Santa Cruz County against the light brown apple moth be halted until the state conducts a comprehensive environmental review of the impacts. The ruling came as Gov. Arnold Schwarzenegger separately announced in Sacramento that the state would postpone planned spraying to eradicate the moth in the 12 counties where it has been found until a series of safety tests could be completed...'It brings into question their whole campaign that this is an emergency situation,' [said county spokeswoman Dinah Phillips.]" [Full Story]
But while identifying the potential health and environmental impacts of the spray is extremely important, I can't help but feel that we're still arguing over a red herring. Because no one has conclusively demonstrated:
  • That LBAM is an immediate threat to anything;
  • That LBAM can even be eradicated by aerial spraying;
  • What kind of damage is likely to actually occur if alternative treatments are pursued.
Strategic planning 101 (along with good old common sense) tells us that before we jump ahead to implementing questionable methodology, we need to first identify the exact problem we're trying to solve, and then identify the most logical approach to solving this problem. Only then can we begin to suggest specific tactics. The chronology looks like this:
  1. Identify the problem.
    The problem is not necessarily the existence of LBAM. The problem - according to CDFA and Suterra - is preserving California's agricultural economy. But the State, with prompting from the feds, has jumped to the simplistic conclusion that eradicating LBAM is the only way to save California's agricultural economy.
  2. Identify the most effective approach.
    But does complete eradication even make sense? Or is controlling the LBAM population a more effective approach to solving the problem?
  3. Identify all tactical options.
    This is where policy makers tend to screw up royally, whether they're at the government, business or community level. They go for the familiar first, not the most logical or the most effective. Because of that, it becomes essential when making important decisions (ones that impact the health of people and planet) to look at all options before picking one.
  4. Weigh the options according to multiple factors.
    Once you open the process up to possibilities, you can weigh those possibilities according to various factors (cost, logistical implementation, effectiveness at solving the identified problem, public opinion, environmental and health impacts, etc). The CDFA, unfortunately, has allowed their own agenda to weigh more heavily than, say, the public health agenda. Ultimately, though, any quality decision-making process must measure all of these factors, giving fair weight to each.
So there you have it: a logical process that leads to good solutions. Of course, this isn't the process the State is using. They declared an "emergency," enabling them to bypass the few regulations that actually protect the public, and immediately picked a solution that would benefit them and their Big Ag business partners.

CDFA has already said they'll appeal the judges stay, of course. But now they've got more at stake, because if the delay does not result in LBAM causing significant and immediate damage, there goes their case. Maybe that's why they were in such a hurry to spray us down in the first place.

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April 22, 2008

Latest News Coverage on the Spray

Well, the word is certainly getting around, which is great. As with any media story, some folks are better than others at getting the facts straight, but the general consensus seems to be that as public outcry continues to grow, the State may find itself forced to take a different approach to an aerial spray.

  • State Fears Economic Impact of Moth Spray. A.P. via Capital Press, Apr. 18
    Key Quote: "Still, public uncertainty alone could be enough to slow summer tourism, drive residents to leave town and cause real estate agents to initiate conversations with their clients about whether they want to buy property in the proposed spray zone, local government officials say."
  • Officials Hit Obstacles in Apple Moth Battle. ThePacker.com, Apr. 21
    Key Quote: "The joint effort by the California Department of Agriculture and the U.S. Department of Agriculture to fight an infestation of the light brown apple moth continues to encounter roadblocks. The result could be the use of stronger, more conventional tools to eradicate the pest, said Steve Lyle, director of public affairs for the state agency."
  • USDA Under Fire Over Apple Moth. California Farmer, Apr. 21
    Key Quote: "'The bureaucracy that led to the moth being labeled a dangerous pest is unclear,' Rep. Farr said following the hearing. 'If we don't even know why the moth is listed as a dangerous pest, it's impossible to determine how far we must go to control it or whether the current emergency eradication tactics are justified.'"
  • Moms Mobilize to Stop Moth Spraying. SF Chronicle, Apr. 15
    Key Quote: "
    'Nothing gets people more irate than a government institution spraying their kids from a plane,' said Jared Blumenfeld, director of the San Francisco Department of the Environment. 'It's a bad movie. And nobody wants to be in that movie.'"
  • Marin Fears Economic Damage from Apple Moth. Marin Independent Journal via Inside Bay Area, Apr. 18
    Key Quote: "
    Helge Hellberg, executive director of Marin Organic, agrees a ground attack is the way to go. 'We are very concerned about the economic damage that this may cause. Of course we see the need to combat pests, but we are in full support of a ground-based means,' he said."

Articles on official resolutions opposing the spray:

  • EB Parks Opposes Aerial Spraying for Moth. Silicon Valley Mercury News, Apr. 16
    Key Quote: "In a resolution adopted on a 6-0 vote with one abstention, the park board said it won't consider supporting the spraying until a full-blown environmental impact report assesses the chemicals the state plans to spray in parts of western Contra Costa and Alameda counties."
  • Alameda: City Council Approves Resolution to Oppose Apple Moth Spraying. CBS5.com, Apr. 15
    Key Quote: "
    In addition to opposing the spraying planned to begin Aug. 1 in parts of San Francisco, Marin, Alameda, Contra Costa and San Mateo counties, the City Council voted to support proposed state legislation that would restrict eradication efforts and require an environmental impact report to be conducted before spraying begins."


  • Look Past Sacramento for Moth Mess. Monterey County Herald, Apr. 21
    Key Quote: "No matter how safe the spray is, there needs to be more official research — and, eventually, some real answers — on whether the moth is really capable of causing significant crop damage or if it is a threat only because its mere existence can lead to trade restrictions for reasons that may be as political as they are scientific."
  • Non-Aerial Solution to Moth Requires Quick Action in Marin. Marin Independent Journal, Apr. 21
    Key Quote: "We believe that an intensified ground-based effort now will prohibit or greatly reduce the spread of light brown apple moth populations, reduce the potential need for quarantine of Bay Area produce and the related increased use of pesticides, and may ultimately avoid the need for any aerial treatment in the future. The Marin Agriculture Commissioner's office is prepared to implement a "train the trainer" program if we can get the go-ahead and money from the state."
  • Teen Calls for Truth, Common Sense. Marin Independent Journal, Apr. 18
    Key Quote: "
    I went to work organizing a panel in my hometown of Mill Valley to discuss the spray. The meeting drew 150 people, but not everyone has to organize a town meeting to make a difference. All of these actions represent the qualms Marin residents feel, yet none of them will singlehandedly force those higher up to listen. Collectively, we all must do our part and call the governor and tell him: Do not spray."



"Do Not Spray" Article From PlanetSave

From PlanetSave:
"...California officials fear LBAM poses a potential threat to the state’s agriculture, but their own projections state the greatest environmental impact as:

'Establishment of this moth could cause direct environmental damage via increased pesticide use statewide by commercial and residential growers and via adverse feeding impacts on native plants.'

That’s right, the pesticide used to control LBAM pose a risk that may be greater than the moth itself..."
[Read the full article.]