Public Comment

I am concerned that the East Bay hills environmental impact statement (EIS) for the fire mitigation project in the works has eliminated from consideration the following practical solutions from an integrated plan, thus compromising the health of people and the environment.  

First. There no plans to replant with native species, which is a big gap in this plan that purports to care for native plant species. Additionally EBRPD plans to take out natives too, including coyote bush, coastal scrub, poison oak, as well as cutting down oaks and bays where they are considered “overly dense,” according to the EIS. 

Second. The EIS has eliminated outright any study of how to manage resprouts without herbicides, dismissing an integrated plan that would include these options (such as use opaque plastic or natural tar applied to stumps) which would help reduce the considerable load of herbicides that will be used (in the tens of thousands of gallons). The herbicides Garlon 4, Garlon 3A, Stalker2, and/or Roundup3 (glyphosate) will be used initially on eucalyptus stumps, and for follow-up treatments twice a year for 10 years, IN ADDITION, herbicide spray will be applied to resprouted foliage between 3 and 6 feet in height. Spray will also be used on seedlings, and “noxious weeds,” such as native poison oak, according to the EIS. 

Though Garlon and Roundup are in cancer classification group D and E, (not enough evidence to say one way or the other that they are human carcinogens), there may well be epidemiological evidence that associates these herbicides with higher cancer rates. A growing number of well-designed epidemiological studies provide substantial evidence that the pesticides used in agricultural, commercial, and home and garden applications are associated with excess cancer risk http://onlinelibrary.wiley.com/doi/10.3322/caac.21170/abstract. 

According to EPA, half-lives (the amount of time it takes for half to break down) of triclopyr varied from 10 to 100 days; half-lives were longer on forestry sites than on agricultural land, http://www.pesticide.org/get-the-facts/pesticide-factsheets/factsheets/triclopyr. Additionally, one of the breakdown products, TCP (3,5,6-trichloro-2-pyridinol) is persistent in the environment, is mobile in water, and according to one EPA report, is just about as toxic as triclopyr, http://www.epa.gov/oppsrrd1/REDs/2710red.pdf. What this means is that these products will persist in the environment, and, since they will reapplied every 6 months, these chemicals are going to be around for 10 years. For those of you out there who try to eat organic foods when possible and try to maintain a lifestyle that reduces the risk of cancer for your family, this plan will not increase your quality of life. 

The bottom line is this folks: the plan to use herbicides and not replant is the easier and less costly way out, but it is not the healthiest plan for humans and the environment. Funds could be allocated, through FEMA or the state, to create jobs, which are desperately needed, to maintain the fire mitigation sites in a way that would be healthiest for people and the environment. Let us collectively take action to do the Right thing, instead of taking the quick and dirty way out.