--ACTION ALERT--

SEND YOUR WRITTEN COMMENTS BY MAIL OR EMAIL TO

Jim Rains, Staff Environmental Scientist, California Department of Food and Agriculture

1220 N Street
Sacramento CA 95814
fax (916) 654-1018
email: jrains@cdfa.ca.gov
cc:simiksikka@hotmail.com

SUGGESTIONS FOR COMMENTS TO SUBMIT ON THE NOTICE OF PREPARATION (NOP)
FOR A PROGRAMMATIC ENVIRONMENTAL IMPACT REPORT (PEIR) FOR THE LBAM PROGRAM:

  1. The LBAM program has changed. The geographic scope now covers most of the state. Aerial spray is no longer the focus for cities, and ground treatments are now the predominant approach there. Sterile moth releases have been added to the near-term treatments. Therefore, new scoping sessions should be held in the Bay Area and all potentially affected areas around the state. Adequate notice should be given for all scoping sessions.
  2. The NOP by law must describe, among other things, "the project’s probable environmental effects." This NOP does not do this, stating only that the project "is not expected to result in either cumulative or direct or indirect adverse effects to human health and the environment." (p. 4, last paragraph). We know that at least 643 people reported illness following LBAM aerial spraying last year and that hundreds of seabirds were found dead and an unusually large red tide followed spraying as well. We know the negative health and environmental effects of the pesticides Bt, spinosad, and permethrin that are listed above in the summary review of the treatments. Clearly there is potential for significant health and environmental impacts from this program. Comments should object to the inadequate description in the NOP of the probable environmental effects of the LBAM program, noting that that this violates California Environmental Quality Act Guideline section 15082(a)(1).
  3. A "programmatic" EIR is not sufficient review for a program with this geographic scope. To be sufficient it would have to address the issues and impacts to a degree that would form the basis for decisions about impacts and treatments at specific sites to be treated in teh program. If the state intends to use this programmatic EIR as the only EIR for the program, that is absolutely not sufficient environmental review of the program.
  4. Damage from last year’s spray has not adequately been investigated, and no further treatments should go forward before sufficient investigation has been done. The state’s report on the health effects is woefully inadequate, having analayzed fewer than 10 percent of the health complaints, and without contacting any individual or physician who filed a complaint. Investigations of seabird deaths did not examine whole birds (only feathers were examnined), and investigators did not test for all the ingredients of the pesticide, only the active ingredient when the likely culprit in both the bird deaths and red tide was one of the other ingredients (the surfactant). No investigation has been done of the effects of the spray on pollinators such as bees.
  5. The whole program not necessary as there is no documented damage from LBAM and there is ample evidence to suggest that it is being kept in check naturally by native predators.
  6. Scientists say the proposed treatments will not work to eradicate LBAM as its is too widespread in the state. CDFA’s expansion of the program to the whole state further underscores that LBAM’s presence is expected to be even more widespread, indicating even more clearly that it is established and cannot be eradicated.