Anticipating the Light Brown Apple Moth Eradication Program

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By Jane Kelly and Lynn Elliott-Harding, RN

Any day now, the California Department of Food and Agriculture (CDFA) will release the final Environmental Impact Report (EIR) on how the CDFA proposes to deal with the Light Brown Apple Moth (LBAM).  

Concerned citizens who opposed the CDFA’s original plans to aerially spray the Bay Area counties with pesticides are assuming that the CDFA will attempt to expand its “eradication” program throughout the state and are gearing up to oppose it.

The CDFA aerially sprayed Santa Cruz and Monterey Counties in the Fall of 2007 with an untested pesticide (CheckMate) that was used under an emergency approval by the U.S. Environmental Protection Agency and that resulted in more than 600 reported health complaints. In an ensuing lawsuit, the courts determined that the CDFA had abused its authority in declaring LBAM an “emergency”. The CDFA then began to conduct a full EIR. 

An EIR must include an accurate description of the proposed project as well as a clear, written statement of the project’s objectives, including the underlying purpose of the project. The CDFA circulated a Draft EIR (DEIR) that hundreds of residents, including Stop the Spray East Bay, of which we are members, responded to by mail, e-mail, and at public hearings. We explained in detail why the DEIR did not meet these legal requirements and that it was based on flawed science. 

One of the many problems with the DEIR was the claim that the CDFA was working “to achieve the overall goal of LBAM eradication from California.”  We, and the CDFA, know that “eradication” is impossible. Retired U.S. Department of Agriculture (USDA) employee Derrell Chambers and other well-respected entomologists have stated frequently that the LBAM is so well established throughout the state that it cannot be eradicated.

These same entomologists believe that the LBAM has been here for decades given the geography over which it has now spread. Even CDFA Secretary Kawamura believes that LBAM has been here for at least 8 years (KKGN Radio interview with Angie Coiro, May 9, 2008), a position that was at odds with the CDFA’s public statements.

Making the CDFA’s arguments for a statewide eradication effort even less compelling is the fact that the CDFA itself acknowledges that the LBAM has done no harm to California crops or wild lands even though the CDFA and its supporters have claimed that the LBAM’s presence represents “Armageddon” and will result in hundreds of millions of dollars in damage to California agriculture. Here, however, is what the state’s own DEIR says (Chapter 3: Agricultural&Horticultural Resources and Economics):

"no direct crop damages have been experienced to date in areas subject to existing infestation"  
 
Link to above information: 

http://www.cdfa.ca.gov/phpps/LBAMeir/CH%203_Ag%20&%20Econ.pdf

The LBAM is similar to dozens of other leaf-roller moths that exist within the state, none of which is the subject of a state eradication program. LBAM is already a resident insect here, and the only people it bothers are the CDFA who receive funding from the USDA for pest eradication as well as the farmers and nurseries that must put up with the costly and often toxic eradication methods imposed by CDFA’s LBAM quarantine.  Is there a better way? You bet there is.

Reclassify the moth based on its actual biology, so that it falls into a more benign category of pest that is not subject to quarantine and does not require farmers and nursery owners to attempt to eradicate it from their fields. (Farmers in New Zealand, where LBAM is naturalized, do not have to have LBAM-free fields to ship their produce to California, only LBAM-free shipments – so the LBAM quarantine is in fact punishing California farmers). 

If LBAM were appropriately classified, the quarantines and justification for a state program of chemical control would end; farmers would be relieved of a costly, dangerous, and unnecessary regulatory requirement, and human health and the environment would face one less threat from a risky and unnecessary statewide pesticide program.

However, as we write, the CDFA has not completed the final EIR and is continuing to carry out LBAM treatments in communities around the state, in violation of state law requiring that an EIR be completed before a project goes forward. The goal of the law is to prevent harm before it is done.  CDFA’s incremental execution of LBAM treatments in communities from Manteca to Los Osos to Davis is a blatant attempt to avoid the required environmental review. 

Our environment – and everything that lives in it – is bathed in a toxic soup of chemicals. Pesticide exposure is responsible for acute poisonings and for chronic illnesses including asthma, cancer, neurological disorders, birth defects, miscarriages, and other reproductive effects.

The Environmental Working Group’s 2004 “10 Americans” study found 287 industrial chemicals in umbilical cord blood, including numerous pesticides, for example DDT, which was banned more than 30 years ago! Pesticides disproportionately affect children whose bodies, pound for pound, absorb chemicals in much higher concentrations than adults.

We may not be able to avoid every one of these chemicals, but those the CDFA is pushing to go after the LBAM are unnecessary and unjustifiable. We also live in a period when state and local governments are scrambling to find funding for basic needs; they should not be wasting precious resources on pointless campaigns that create more harm than good. Let’s put an end to the LBAM campaign now.  

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Jane Kelly, Berkeley, and Lynn Elliott-Harding, RN, Oakland, are Steering Committee Members of Stop the Spray East Bay