June 12, 2008

Plans to Spray California Still In Place

Despite the fact that over 30 cities and counties, the bulk of California's senators and representatives, the state Assembly, and over 28,000 citizens oppose the aerial spraying (according to the SF Chronicle), the state still intends to commence spraying beginning August 17...and to continue spraying indefinitely.

This comes from Governor Schwarzenegger:
"Thank you for your previous correspondence on the California Department of Food and Agriculture's (CDFA) Light Brown Apple Moth Project.

The light brown apple moth - if uncontrolled - poses a great threat to California's diverse range of agricultural and natural plant life, as well as native and endangered species. If it becomes established statewide, the moth would have a devastating impact on our state's environment and economy.

Throughout the treatment program, the public's safety is the primary concern. Any product used must meet rigorous standards for health and safety. However, to thoroughly ensure everyone's safety, the aerial spraying has been postponed while CDFA completes what's known as "six-pack" toxicology tests in addition to the normal extensive tests on the pheromone products. These tests thoroughly test toxicity for eye, inhalation, respiratory and other potential irritants.

I am confident that these additional tests will reassure Californians that we are taking the safest, most progressive approach to ridding our state of this very real threat to our agriculture, environment and economy. Again, thank you for contacting me and adding your voice to this important issue.

Sincerely,
Arnold Schwarzenegger"
As usual, the State's communications about their plans are extremely misleading, and ignore or misrepresent the facts. Let's break this down a little:
"The light brown apple moth - if uncontrolled - poses a great threat to California's diverse range of agricultural and natural plant life, as well as native and endangered species. If it becomes established statewide, the moth would have a devastating impact on our state's environment and economy."
Fact: No one actually knows what kind of threat the LBAM really poses.
So far, about 3,500 moths have been trapped. Unfortunately, the LBAM is very difficult to identify without actual dissection, and the CDFA numbers don't indicate if this 3,500 includes dissected moths, or just suspected LBAMs. Additionally, it's not clear what the CDFA considers and "infestation." They claim that counties like Alameda and Contra Costa are "infested," (PDF brochure) but their own concentration maps (PDF map) indicate that these counties have no more than 2-10 moths per square mile. Finally, etymological experts far and wide have agreed that eradicating the moth is close to impossible (they gave up trying in New Zealand, where the moth is now everywhere), and the pheremone they intend to use has not been proven to be effective in doing so.

"However, to thoroughly ensure everyone's safety, the aerial spraying has been postponed while CDFA completes what's known as "six-pack" toxicology tests in addition to the normal extensive tests on the pheromone products. These tests thoroughly test toxicity for eye, inhalation, respiratory and other potential irritants."

Fact: Health testing is being limited to short-term, "acute" effects.
Tests for irritants do little to ensure that the chemical spray to be used is safe in the long term. Given that exposure to the chemical will be multiple times per month, for most months of the year, for an indefinite number of years, there will be no way to know if such increased exposure is safe over time. Unless we postpone spraying to conduct long-term safety tests - which the State isn't doing - it's quite possible that chronic health issues could arise months and years after exposure. This concern is serious - the pheromone is delivered via microscopic "capsules" that, if small enough, can lodge themselves in the lungs and stay there, posing a serious health risk over time. The State claims these capsules are too big to pose a threat, but studies have shown that the previous spraying contained capsules that were small enough (read more info about the health reviews here).

Ultimately, the State's assertions about the moth, its treatment, and public safety are disingenuous at best and outright reckless at worst. And yet, plans to begin spraying beginning August 17 don't seem to be changing.

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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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