Public Comment

In a May 16 editorial on his department’s plan to eradicate the light brown apple moth (LBAM) by aerial spray and other means, California Agriculture Secretary A. G. Kawamura ac-cuses those who oppose the LBAM program of spreading “misinformation” and urges us all to rely on “sound science” and to “draw the line” on “exaggerated and unsubstantiated claims” that cause “unwarranted fear.” (www.california progressreport.com/2008/05/california_secr_6.html.) 

Mr. Secretary, it is time to look in the mirror. You and your department are the primary source of misinformation and fear tactics. 

You claim the pesticides you sprayed last fall and want to spray this summer over our communities are “just pheromones,” neglecting to mention that the products in question are designated by the United States Environmental Protection Agency (EPA) as pesticides and contain not only untested, synthetic pheromones but also a host of other toxic ingredients, dispersed in minute plastic capsules. 

You claim that LBAM is a “ravenous” pest that will destroy California agriculture and eat everything from redwoods to Scotch broom, when in fact this benign moth has caused no damage in California and almost no damage in the other states and countries where it is established.  

You claim that the spray is safe and has been tested, when your own department’s documents say otherwise. You claim that the state’s superficial review of the 643 illness reports after last year’s spray proves there is no link between the spray and the sicknesses, when in fact that report reviewed only 10 percent of the reports and concluded it could not determine whether or not there was a link. 

Who is relying on unsound science and unsubstantiated and exaggerated claims? 

At least two courts in the state of California have agreed during the past month that your science is not sound, halting the spray program in Monterey and Santa Cruz counties and ruling that you and your department abused your discretion in exempting the program from any environmental review. 

Local governments all around the Central Coast and Bay Area where spraying is slated to start this summer also agree that your claims do not stand up to scrutiny. Almost every city and county—more than 25 at last count—where you and your department have made presentations about the LBAM program has now voted to officially oppose the program. 

You say you choose to rely on facts. So let’s look at some facts. 

Your own publications contradict your claims that the spray is safe. You say it is untrue that the pesticide used last fall has not been tested. In fact, the assessment published by the California Departments of Health and Pesticide Regulation and the California EPA’s Office of Environmental Health Hazard Assessment clearly says the active ingredient in those pesticides, a synthetic moth pheromone, has never been tested for human exposure. The “thorough review” that you claim those agencies gave the pesticide relied on short-term exposure data for other pheromones, assumed they would be applied only over unpopulated agricultural areas rather than the populous urban areas that will be affected by the LBAM spray, and ignored the other ingredients that made up more than 80% of the pesticide. Those other ingredients include carcinogens, mutagens, and chemicals associated with birth defects and miscarriages, and toxic to aquatic life. Your department repeatedly claims it is “unaware” of those health risks even though they are documented in the toxicology database of the United States Institute for Occupational Health and Safety and on Material Safety Data Sheets prepared by the chemical manufacturers. 

Now you are touting the “six-pack” toxicology tests being done on the pesticides proposed to be sprayed over our communities this summer. But you fail to mention that these are short-term exposure tests that determine how much of a pesticide or individual ingredient will be fatal to an animal in a very short period of time. These tests will tell us nothing about the actual risks faced by human populations to ongoing exposure from a pesticide that time-releases during the 30-day periods between sprays or about the risks of long-term health problems such as cancer. 

At a recent presentation in the Central Valley where CDFA is now trying to shore up its case for spraying Bay Area and Central Coast residents, a farmer who had researched the moth and found it is not a threat asked: “Why are you bringing alarm into the Central Valley?” 

The only fear being spread is by CDFA, claiming that LBAM is a “voracious” pest that will eat “anything green,” destroy California agriculture, and overrun the Central Valley. You have produced no science, substantial or otherwise, to support these claims. In fact, your own department has said the moth has done no damage to crops or plants in California. Respected scientists have shown that LBAM is just another of the many leaf-roller moths that do no harm in California and that it does almost no damage in other countries and states where it is established and which do little or nothing to control it. The USDA’s own research shows that LBAM will not reproduce in the extreme temperatures of the Central Valley. 

For months you told us that the reason there was no crop damage due to LBAM was that it had just arrived last year. But on a recent radio show you admitted that it has been here at least six or seven years. Meanwhile, entomologists across the UC system have been saying all along that it has been here 10-50 years. How many other claims have you made that will be revised when the moth of mass destruction turns out to be just another mild-mannered leaf roller? And, meanwhile, how many more people will have to get sick before your sham science and unsubstantiated denials crumble and the truth is revealed that the LBAM program is dangerous and unnecessary? 

We have read a lot in the news recently about interference with the work of government scientists charged with evaluating the safety of chemicals to protect public health. A Government Accountability Office report found that the White House and other agencies had “delayed or blocked efforts by the Environmental Protection Agency to list chemicals as carcinogens,” (San Francisco Chronicle, Apr. 30) and that the U.S. EPA has bypassed the results of its own scientists’ research to instead rely on recommendations of an industry-funded group. Rules changes by the Bush administration have made deliberations about chemical risk secret so that there is no oversight or open scientific debate. An April 30 Washington Post article notes that this “makes it impossible to see whether agencies are acting in the interest of science or for less noble reasons.” It seems clear similar problems have trickled down to CDFA as you and your staff present cherry-picked and misrepresented science to the citizens of California in an effort to rationalize a dangerous program for which there is no justification. 

You claim that you are conducting the LBAM program “in an open, transparent manner.” In fact, East Bay residents have for some time been requesting CDFA’s schedule of LBAM presentations and asking that those presentations be balanced to include the scientists whose research counters the state’s unsubstantiated claims. Those residents have received no response. 

With all these lies, omissions, abuses of discretion, and failures in transparency to your credit, Mr. Secretary, and with the burden that has been placed on the independent scientists and citizens of California to bring the facts about the LBAM spray to light, the charge of misrepresentation clearly lands at your own doorstep.