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DESCRIPTION:Stop the Spray San Francisco\nAugust 28, 2009\nJoin Our Mailing 
 List\n	\nGreetings!\n\nWe need to rally large numbers of people to attend 
 and speak at the state's Bay Area meeting \n\nThe LBAM program is as 
 unsafe, unnecessary, and ineffective as it ever was, and the EIR is a 
 remarkably flawed document that does not address the program's actual 
 health and environmental impact or any of the fundamental questions about 
 the program that we and many others raised during the EIR preparation 
 ("scoping") process last year.\n\nTHIS IS THE ONLY PUBLIC MEETING ABOUT THE 
 DRAFT EIR IN THE BAY AREA and the last meeting in the series that the state 
 has held in the past 2 weeks, so we need to fill the room with people who 
 will speak to the questions and concerns about this EIR.  Comments we make 
 now will be crucial for challenging the program as the environmental 
 assessment process continues. \n \nBelow are some general comments about 
 the EIR's flaws and some questions that we might pose about the LBAM 
 program. Feel free to use these suggestions the basis for your testimony 
 and written comments.  Instructions below also for sending in written 
 comments on the Draft EIR.\n\nThanks for your ongoing support. If you 
 testify at the meeting next week or send in written comments on the EIR by 
 the Sept. 28 deadline, please forward a copy to this email so we can track 
 whether the final EIR addresses our 
 comments.\n\nNan\n_____________________________________________________________\n\nStop 
 the Spray East Bay & Pesticide Watch\nKey Concerns:  Draft Light Brown 
 Apple Moth (LBAM) Eradication Programmatic Environmental Impact Report 
 (EIR)\n\nSeveral people have asked about how the EIR process works. Here is 
 a very brief summary: any agency or private entity that wants to carry out 
 a project that might have an environmental or health impact has to, under 
 the California Environmental Quality Act, prepare an EIR.  The steps are: 
 scoping (collecting concerns and questions from the public), draft EIR 
 (this is where we are now), final EIR (more comment accepted on the final). 
  When an EIR covers a large program (as this one does), it is k nown as  
 "programmatic" EIR, and smaller specific follow-up EIRs are usually 
 required for the specific elements of the program.\n\nThe California Senate 
 Agriculture committee held a hearing on the EIR earlier this week at which 
 many LBAM experts as well as spokespeople for Stop the Spray East Bay 
 raised these and many more issues; we need to keep pressing these issues so 
 that there is no doubt that these concerns are widespread and that if the 
 final draft of the EIR ignores them, it will be open to challenge for not 
 having addressed the public's concerns.\n\nThe state is currently taking 
 comments on the draft LBAM EIR at public meetings and in writing.  This 
 summary is designed to assist those who wish to comment on the EIR.\n\nThe 
 draft EIR is based on flawed assumptions and incomplete, invalid science 
 and does not adequately assess the LBAM program and its impacts.  
 Specifically, the draft EIR:\n \n1. Fails to address any of the flawed 
 assumptions on which the LBAM program has been based. It does not address 
 substantial evidence that LBAM is well established in California and poses 
 no threat, so no quarantines or treatments are needed.  The EIR assumes 
 eradication as the program's goal even though there is substantial evidence 
 that eradication is neither feasible nor achievable. As a result, the EIR 
 dismisses non-toxic control strategies such as integrated pest 
 management.\n\n2. Does not assess the impacts of the LBAM program as a 
 whole. The EIR evaluates each proposed LBAM eradication treatment* 
 separately without accounting for the fact that these treatments would be 
 used in combination; thus, the EIR does not adequately assess the actual 
 health and environmental impacts of the program as a whole.\n\n3. Draws 
 unsubstantiated, not credible conclusions about the risks of the proposed 
 treatments. For example, the EIR, astonishingly, finds no negative health 
 or environmental impacts from ground or aerial pesticide spraying even 
 though aerial spraying sickened hundreds of people on the Central Coast in 
 2007.  Ironically, the EIR concludes that the only negative impact of 
 aerial spray would be airplane noise.\n\n4. Defines the treatment area too 
 broadly. The EIR identifies almost the entire state, with its widely 
 variable geographic and ecological zones, as the potential LBAM treatment 
 area without specifying what treatments would be used where, when, or how 
 or what the environmental impacts in a given area would be.\n\n5. 
 Misrepresents "no action" alternative. The EIR defines the "do nothing" 
 alternative (which EIRs are required to include) as a scenario in which 
 private landowners would use large amounts of dangerous pesticides to try 
 to control the moth even though there is no factual evidence to support 
 this assumption; as a result, the EIR finds that the "no action" 
 alternative has more severe environmental consequences than the multiple 
 mass chemical and other\ntreatments the state proposes to use for LBAM. 
 \n\n* twist ties, ground and aerial applications of pheromone based 
 pesticides, permethrin "SPLAT," Bt, Spinosad, predator wasp release, 
 sterile moth\nrelease; the aerial applications are assumed to use a form of 
 the pesticide that is encased in 1/8" square flakes.\n\n___\n\nSome Light 
 Brown Apple Moth Draft Environmental Impact Report IR (DEIR) Questions\n 
 \nOne thing missing from the draft EIR is discussion of the justification 
 for implementing the apple moth program in the first place.  One of the 
 main comments of my constituents during the scoping process was the need to 
 for a comprehensive review of the literature and evidence regarding the 
 threat posed by the apple moth, the need for eradication, and the 
 likelihood that eradication can succeed.\n \n1) why does the EIR does not 
 comprehensively review the scientific evidence for these basic premises on 
 which the whole program is based: i.e., that eradication is necessary and 
 can succeed?\n \n2) what specific studies and data does the California 
 Department of Food and Agriculture (CDFA)  have to support the claim that 
 eradication is possible? can you give specific examples where other moth 
 species established over thousands of square miles that have many host 
 plants have been successfully eradicated?\n \n3) what is CDFA's definition 
 of what would constitute successful eradication of the apple moth?  what 
 are the time frame and criteria for deciding whether eradication can be 
 achieved and, if it cannot be achieved, for terminating the program?\n \n4) 
 why are we discussing eradication in California when it is not being 
 considered in Hawaii where the apple moth has been established for 100 
 years?\n \n5) if eradication were taken off the table, how would CDFA 
 recommend controlling the apple moth in California?\n \nThe DEIR states in 
 several places that the apple moth is spreading in California.\n \n1) why 
 would this spread be occurring despite the two years of quarantines and 
 restrictions imposed by your department?\n \n2) to what extent have you 
 expanded the numbers, locations, and efficiency of trapping during these 
 two years, and how can you determine whether the increased finds of moths 
 are due to these improvements in your protocol versus an actual increase in 
 the geographic range of the moth?  in other words, how do we know we are 
 not simply delineating the established range of the moth rather than 
 finding new "infestations?"\n \nThe DEIR says that both California 
 agriculture and native forests are at risk if the moth is not eradicated.\n 
 \n1)  What definitively confirmed damage has the apple moth done in the 
 state?  Is there any damage over the last two years beyond 1 unconfirmed 
 instance of damage in a blackberry field?\n \n2) What specific scientific 
 evidence is there, from California or anywhere in the world, that native 
 forests are at risk from the apple moth?\n \n3) Given the lack of damage 
 over the past 2 years what specific evidence can CDFA cite that damage from 
 the apple moth will increase?\n \nCDFA's annual LBAM report to the 
 legislature says that a better, more definitive DNA test for the moth is 
 needed along with information about the DNA of related moths, to ensure 
 accurate identification.\n \n1) If the current testing is not sufficiently 
 accurate, how can CDFA be sure that the apple moth is present in a given 
 location and/or responsible for damage in any particular location?\n \nThe 
 "No Program" alternative in the EIR is based on the premise that private 
 landowners will increase their use of pesticides because of the apple moth, 
 causing more damage than would be done by the proposed chemical treatment 
 alternatives.  This determination was apparently made based on two internal 
 memos by CDFA Project Director Robert Dowell who is also a main preparer of 
 the EIR.  Survey show that a very large percentage of the residents of my 
 district use no pesticides at all in their homes and gardens.\n \n1) Is 
 there any hard evidence to support the allegation that program private 
 landowner pesticide use will increase for the moth?\n     [if you yourself 
 do not use pesticides in your home or yard, you could add a personal note 
 here about your thoughts regarding the state's assumption that private 
 landowners will voluntarily spray, particularly for a moth that does no 
 damage]\n \n2) If the moth does not do damage, why would homeowners use 
 pesticides for it?\n \n3) To what extent do private landowners use 
 pesticides for other closely related leaf-roller moths now?\n \n4) What is 
 the standard protocol that farmers currently use for other native 
 leaf-roller moths, and why would that protocol not control the apple moth 
 as well, if control were in fact needed?\n \nThe EIR does not quantify the 
 health and environmental impacts of the program as a whole; it only looks 
 at individual treatments.\n \n1) When does the state intend to quantify the 
 environmental impacts of the program as a whole?\n \n2) Prior state reports 
 looked at only 10% of the health complaints submitted following aerial 
 spraying for the moth in 2007. Are there any plans for a complete review of 
 all the health complaints submitted?\n \nThe draft is a Programmatic EIR 
 and addresses the program location very generally.\n \n1) Does CDFA plan to 
 prepare specific EIRs for each area of the state and the treatments to be 
 used in that area?\n \nWritten comments on the LBAM EIR must be sent not 
 later than close of business on Monday, September 28, 2009 to:  \nJim 
 Rains, Staff Environmental Scientist\nCalifornia Department of Food and 
 Agriculture\n1220 N Street\nSacramento, CA 95814\nfax (916) 654-1018\nemail 
 jrains@cdfa.ca.gov\n\n\nThis summary of current events and issue status is 
 from Nan Wishner of StoptheSpray - East Bay. Thank you Nan!\n\nIn 
 Solidarity,\n\nMichelle Darby\nCoordinator, Stop the Spray - San 
 Francisco\nForward email\n\nPUT UP 
 BY\n\nhttp://network.greenchange.org/me\n\nhttp://digitaldaq.deviantart.com/\n\nhttp://twitter.com/davidaquinley/\n\nhttp://www.facebook.com/home.php?#/david.quinley/\n\n\nhttp://www.facebook.com/home.php?ref=home#...\n 
 https://www.indybay.org/newsitems/2009/08/30/18620164.php
SUMMARY:Ca.Bay Area Meet:L.Brown Apple Moth(LBAM)Draft Enviro. Impact Report:1515 Clay St. Oakland
LOCATION:Light Brown Apple Moth (LBAM) Draft Environmental Impact Report (EIR) Tues. 
 Sept. 1, 5:30-7:30 PM, Elihu Harris Building auditorium, 1515 Clay St., 
 Oakland.\n\n\nhttp://www.stopthespraysf.org/
URL:https://www.indybay.org/newsitems/2009/08/30/18620164.php
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