Light Brown Apple Moth

DON'T BELIEVE THE HYPE:
Light Brown Apple Moths are NO THREAT!
But PESTICIDES ARE!!!

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According to the U.S. and California Departments of Agriculture (USDA, CDFA), the light brown apple moth (LBAM) is a threat to agriculture, our ecosystem, and the economy, even though it has caused no actual damage. Independent scientists have indicated that the LBAM has likely been here for decades, not just a couple of years as claimed by the Ag Department, during which it has become part of our local ecosystem, and is kept in check by natural predators, just as the many native species of similar leafrolling moths.

The USDA and CDFA nevertheless went into battle against the LBAM, setting traps throughout California, and in 2007 hosed down neighborhoods in Oakley and Napa with pesticides, followed by toxic twist ties in several more neighborhoods, and aerial spraying over Monterey and Santa Cruz. Even though hundreds of people reported getting ill from the spraying, and hundreds of birds died immediately afterwards, the CDFA declared that the illnesses and deaths were coincidental, and that the trapping, twist ties and aerial spraying, and other pesticide methods would continue and be expanded to the larger Bay Area and any other area where an LBAM is found.

Earlier in 2008 the areas to be targeted for pesticide applications of all sorts against the LBAM totalled 571,259 acres, 892 square miles. That area has since been expanded to most of the state:

What Would Larry, Moe and Curly Do?
"SPLAT, confetti, goop, wasps-the state's new weapons against the apple moth sound like a joke, but they're not."

Treatment Program for Light Brown Apple Moth in California (pdf)
Outlines the different methods planned according to the USDA

LBAM Eradication Program: Potential Effects on Pollinators and Implications for California Agriculture (pdf)

All of these pesticides contain "inert" ingredients, which are kept undisclosed, protected as "proprietary" by trade secret laws, are frequently even more toxic than the "active" ingredients listed on the label, and are specifically designed to interact synergistically to achieve greater toxicity than each chemical by itself.

Unidentified Inert Ingredients in Pesticides: Implications for Human and Environmental Health - Cox and Surgan (pdf)

Even though all of the pesticides contain synthetic ingredients, several of them are "approved" by the U.S. Department of Agriculture, National Organics Program, and the Organic Materials Review Institute for use in organic agriculture, further diluting organic standards.

It's a new, unregistered, synthetic chemical, and classified as a pesticide:

USDA quarantine exemption request (pdf)
Request to use a new chemical -- (E,E)-9,11-Tetradecadien 1-yl Acetate --which has not been registered by the EPA. A declared emergency precludes the usual environmental impact reporting and public comment. This is the "pheromone", the "active" ingredient in LBAM traps, twist ties, SPLAT, and aerial spray.

On the Apparent Persistence of Disparlure In the Human Body E. Alan Cameron
17 years after working with a similar chemical, disparlure, the synthetic "pheromone" aimed at the gypsy moth, a man continued to attract moths.

Even though traps are not considered part of the eradication program, but part of a monitoring program, the lures inside them contain the "pheromone" pesticide. Traps determine which areas are quarantined and targeted for more pesticide applications, which in the 1980's during the medfly program in Los Angeles resulted in people disappearing traps. The same can currently be witnessed with mosquito traps in Virginia, in a county already being sprayed aerially for the gypsy moth, and where the health department promises that "mosquito surveillance data" may result in the spraying of "adulticides".

Some opponents of the CDFA's LBAM project are proposing "pheromone" traps as an alternative to the aerial spray program. The traps, however, which are currently used to find LBAM, also contain the same synthetic "pheromone" as the twist ties, SPLAT, and aerial spray, as well as secret ingredients, and put at risk other beneficial insects, especially honeybees, who are attracted to various colored traps, and who are in a real global emergency due to "Colony Collapse Disorder", in which pesticides have been implicated. It is clear that neither the "pheromone" nor these traps are "targeted", as moths have to be tested to see if it's really an LBAM and not a local look-alike.

Scenturion Lures LBAM - Manufacturer's MSDS (pdf)
These Traps are made by Suterra, the same manufacturer as of CheckMate, the aerial spray used over Monterey and Santa Cruz in the Fall of 2007.

Notice that there are no ingredients listed on this MSDS at all. When asked about the ingredients, even just the "active" ingredients, Suterra's representative refused to provide them, and referred us back to the CDFA, confirming that their traps are in fact the ones being used in this program at this time.

Email exchange between Maxina Ventura and Suterra

Bids for a new LBAM Lure are being solicited by USDA-APHIS, with the following chemical requirements:

"Each Light Brown Apple Moth lure will consist of a synthetic rubber (halobutyl) septum loaded with 3mg of a 20:1 to 24:1 mixture of E11-tetradecen-1-ol acetate (= trans-11-tetradecenyl acetate) to E9, E11-tetradecadienyl acetate. These compounds should be applied to the septum in a solution of a solvent such as hexane (e.g., 3mg in a 100 ul of solvent) which is allowed to evaporate from the septum. … The materials should be applied in a solvent rather then "neat" as this may affect their absorption into, and subsequent release from the halobutyl rubber."

This requirement was later amended to also allow a "PVC matrix type dispenser in lieu of a synthetic rubber septum".

Hexane is a neurotoxin and causes central nervous system depression. It is a narcotic agent, and an eye, respiratory, and skin irritant. "Symptoms observed include dizziness, giddiness, slight nausea, and headache. Chronic inhalation exposure to hexane is associated with polyneuropathy in humans, with numbness in the extremities, muscular weakness, blurred vision, headache, and fatigue."

Hexane profile

Pheromone Trap Colour Determines Catch of Non-target Insects - New Zealand Plant Protection Society

Pheromone Search - 942 Monterey County Moths - Lancelot Houston (526 KB pdf)
"Non-target" moth species in Monterey County, affected by the CDFA's supposedly "targeted pheromone"

An LBAM trap in Cherryland, adjacent to the City of Hayward, with a non-target insect stuck inside:


Found & photographed by Dan Egolf

Artist depiction of possible exposure to children:

Example of likely route of exposure in real life: A government insect trap, torn open, likely by children who frequent the area in Oakland where this photo was taken. The photo on the left is of an intact insect trap of the same kind as the torn one on the right. These traps are for the Asian Gypsy Moth.

The black line in the top third of the broken trap is a rope, similar to the twist ties, which contains the synthetic "pheromone" disparlure, which has been found to persist in people's bodies for years.

Found and photographed by Maxina Ventura

Twist ties with the LBAM "pheromone" have been going up in many towns throughout the quarantine area since 2007.

Isomate LBAM Plus, "pheromone infused" twist ties are being hung on trees, plants and fences, 250 per acre, 30-40 per property, throughout entire neighborhoods, to be replaced every 3-6 months. While these "pheromones" sound natural, they are not naturally acquired. They are synthetic chemicals designed to imitate natural pheromones. In order for these chemicals to affect moths, they have to drift through the air we breathe, so the insects can perceive them. This Material Safety Data Sheet (MSDS) is of course produced by the manufacturer, and does not disclose "inert" ingredients, which are protected by trade secret laws. It is unlikely to tell the whole story, but admits it is an eye irritant and "Harmful if absorbed through skin":

Isomate LBAM Plus Twist Ties - MSDS (pdf)

And the label warns "Hazards to Humans and Domestic Animals":

Isomate LBAM Plus Twist Ties - Label (pdf)

Many are placed quite low, in easy reach of climbing and curious children and animals, as can be seen in these pictures from a CDFA report.

And these artist depictions of possible contamination of pets and wildlife:

New twist tie clip, first publicly revealed at Sonoma Board of Supervisors meeting with CDFA on July 8, 2008:

Permethrin, mixed with the synthetic "pheromone" and other secret ingredients, was planned as a "pre-treatment" for, or concurrently with, aerial spraying, to be applied in a "clay matrix", every 30-60 days, 8 feet off the ground, just overhead of passers by and in easy reach of climbing children and animals, to a minimum of 3000 utility poles and trees per square mile. The CDFA has described this method as a process of "painting", though upon questioning, no one at the CDFA hotline had any information about the details. The USDA treatment plan for the LBAM describes it as mixed into either a "paraffin wax material" or Min-U-Gel, also known as Fullers earth or Attapulgite clay, and applied "as a very coarse squirt from a metered hand-held wand." According to the Santa Cruz Sentinel, after interviewing Steve Lyle, CDFA Director of Public Affairs, "The goo would be squirted by a person in a van onto power poles and trees 8 feet high - on public and private property."

The USDA admits that the crystalline "silica quartz component of the clay is listed as a possible human carcinogen under California Proposition 65 for inhalation exposure; however, since the material is mixed with liquid diluent, it will not be available for inhalation." But potters know that clay dries fast in the air, and crumbles in little time.

The document claims that the "direct application of this material to trees and poles eliminates the possibility of drift". It also describes the pheromone as "highly volatile", and anyone who's ever smelled head lice shampoo, flea collars, or Raid, knows that permethrin mixes offgas fiercely. The description that the chemicals are formulated in such a way as to provide for a "slow release to the atmosphere", says it all. If the moth can perceive it, then we are exposed to it too.

According to the Mercury News' interview with Lyle, the pesticide "should dry within a week" after application. The USDA claims that "the ability of both formulations to become rainfast once the material is applied reduces any potential for run-off." Simultaneously they want us to think of the clay as the same as what's in that horrid pink stuff for diarrhea. Imagine all that Pepto-Bismol stuck to people's insides, that a good guzzling of water couldn't flush down. Imagine what might happen to wax on a hot, inner city California day, stuck to a pole. Imagine what the full "potential" of their toxic run-off might be, if it wasn't "reduced"...

Permethrin is a neurotoxic, carcinogenic, endocrine disrupting, chromosome damaging insecticide, that is especially deadly to cats.

Dangers of Permethrin Fact Sheet by Caroline Cox

Most recent toxicological profile for Permethrin (or download pdf here)

Ground Spraying Coming in March 2008 - CASS Fact Sheet (MS Word)
More toxicology of Permethrin and Btk compiled by California Alliance to Stop the Spray

SPLAT (Specialized Pheromone & Lure Application Technology)

This is what it might look like, though the CDFA has not released any pictures of the surface area, color, or density of this pesticide application.

Perhaps one of these is the method of application. Both "metered" wand (left) and caulk gun (right) have been mentioned as possibilities for their drive-by squirting. And Max Suckling, a member of the Technical Working Group, and his agency HortResearch, which is partnering with the CDFA and USDA in LBAM-related research in New Zealand, are described as attempting to develop a method involving a "paintball gun" to shoot the "pheromone" onto tree trunks.

This is how a different formulation of a SPLAT-like product is applied in another CDFA pesticide program:

And here that same pesticide program, caught in action and upclose in Los Angeles by urban homesteaders (see their blog for all pictures in large size):

CheckMate, a mix of synthetic "pheromones" with undisclosed "inert" ingredients, was planned to rain down on California's San Francisco Bay Area and the Monterey and Santa Cruz Peninsula, applied by airplanes. These chemicals have never been tested for safety. After much pressure from residents whose neighborhoods were already sprayed, and who were sickened, the "inert" ingredients of only one of the two chemical formulations used in 2007, CheckMate LBAM-F was disclosed. It remains unclear if the list of ingredients is complete, as State officials ordered the list of ingredients released "to the maximum extent possible under U.S. trademark law". While a few ingredients of the other formulation, CheckMate OLR-F, were leaked to the public, the full list of ingredients remains a secret.

The EPA since rescinded their approval of CheckMate, though has approved another new "pheromone" product (Hercon's Disrupt Bioflake LBAM, see below) for future aerial applications, which is still planned for communities in so-called "non-urban" areas.

Overview of all known ingredients of CheckMate

Most recent indepth toxicological profile for CheckMate (or download 40 page pdf here)

Declaration of Richard Philp, toxicology professor, on CheckMate (quick and easy to print out overview)

Analysis of CheckMate by Dr. Lawrence Rose, M.D., M.P.H., recently retired senior Public Medical Officer for Cal-OSHA, and Occupational/Environmental Medicine practitioner at UCSF:

"These short term complaint symptoms are consistent with known toxicology scientific information of the ingredients of Checkmate... These ingredients include irritants, sensitizers, nervous system disrupters, endocrine disruption, allergens, and hypersensitivity induction. Long term health effects are also of concern due to the known induced mutations and suspected cancer risks of constituent chemicals."

More about Polymethylene polyphenyl isocyanate, the secret ingredient in CheckMate OLR-F

Analysis of the Encapsulation Process and Encapsulated Products, such as CheckMate capsules

Dr. Ting, Office of Environmental Health Hazards Assessment (OEHHA) toxicologist, on coughing up microcapsules
(MS Word)

LBAM Spray, PM10, and 630,000 Deaths The impact of particle pollution

Study of effectiveness of pollen traps in reducing poisoning of bee hives by microencapsulated pesticides
Microcapsules used in pesticide manufacturing are the size of pollen grains, and are collected with pollen by foraging bees, and carried back to the hive. The pesticides within the microcapsules were later found in dead bees, and even though they were also found in pollen traps, their presence "did not significantly reduce bee deaths or pesticide residues".

The new product the EPA approved as of January 2009 for the aerial portion of the LBAM program after CheckMate was pulled is Hercon's Disrupt Bioflake LBAM.

The Manufacturer mentions no product named Disrupt "Bio"flake LBAM. They only list this one:

Disrupt Micro-Flake LBAM Manufacturer's "fact sheet" (pdf)
"This is an unregistered product approved under Section 18 of FIFRA. For Use in State of California Only" - "Disrupt Micro-Flake LBAM is manufactured using four main components; the pheromone (active ingredient), an inert polymer film, an inert polymer resi, and an inert biodegradable plasticizer. The product is manufactured in the form of a three-layered laminate of 'sandwich' consisting of two outside barrier films, and a middle reservoir layer consisting of the phermone, resin, and plasticizer. This laminate structure protect the contained phermone from environmental degradation and rapid evaporation, permitting its useful controlled release over extended periods. When the laminate is cut into flakes, the pheromone slowly migrates through to the outside edges of the barrier films and is released from the surface of the flake over 80-90 days."

Disrupt Micro-Flake Manufacturer's MSDS (pdf)
Note that none of the 89% "inert" ingredients are listed. And while they don't expect "significant toxicity", they warn to use "appropriate procedures to prevent direct contact with skin or eyes and prevent inhalation."

Disrupt Micro-Flake Manufacturer's (Draft) Label (pdf)

The chemical mixture is embedded in polyvinyl chloride (PVC, vinyl) flakes, which is also not non-toxic, not in its manufacture, nor disposal, and not when ignited. In a list of accidental fires involving PVC, Greenpeace finds that it contributed to the start and/or spread of each fire, and "emitted life-threatening gases and chemicals":

"Besides the acidic hydrogen chloride, a wide variety of chlorinated and non-chlorinated organic chemicals evolve from PVC during high temperature pyrolysis and combustion: benzene, toluene, formaldehyde, chloroform, chlorinated biphenyls, dioxins and dibenzofurans, and many others. The emission during fires of benzene, chlorinated dioxins, and dibenzofurans - known carcinogens - appears to explain the high frenquencies of leukemia, laryngeal and colon cancer, and of the rare soft tissue cancers found in many firefighters at relatively young ages."

PVC flakes spread everywhere promise to cause toxic fumes during possible fires, be they wildfires, house fires, or campfires in the near future. Even the manufacturer's MSDS admits that when Disrupt flakes are burned "the hazardous decomposition products that will result because of incomplete combustion include carbon monoxide, other unidentified products of hydrocarbon degradation, No_x, low level cyanides and hydrogen chloride".

Hercon claims that the plasticizer used in Disrupt is biodegradable, but no other details are disclosed. The most common PVC plasticizers are phthalates, which can be classified as biodegradable, but which have been linked to endocrine disruption and are possible carcinogens.

"A 'Sticker Agent' will be mixed with Disrupt Bioflake LBAM for adherence of the flakes to foliage":

X3221 Micro-Tac II Sticker Agent
Manufactured by Lock N Pop (Key Tech Corporation)

Lock N Pop do not make their specialty adhesives publicly available on their website, and the manufacturer's Material Safety Data Sheet, sent to us upon request, lists no ingredients at all, so the ingredients of the adhesive are as of yet unknown.

Lock N' Pop X3221 MSDS

The adhesive commonly used by the USDA Forest Service in another formulation of Hercon's Disrupt, used in their Stop the Spread (STS) gypsy moth program:

Gelva Multipolymer Emulsion 2333 MSDS (pdf)

The MSDS reveals that it contains vinyl acetate, a suspected carcinogen.

Vinyl Acetate Chemical Profile on Scorecard

The rest of the ingredients are vaguely named acrylic copolymer, and it is noted that the "specific chemical identity (including CAS No.) and/or concentration is being withheld because it is trade secret".

In addition to testing the twist ties and one of the Checkmate formulations used already (LBAM-F), the USDA partnered with two state owned biotech companies in New Zealand to test various chemical formulations of the "pheromone" as aerial applications, including SPLAT, the "pheromone" and permethrin mix we're told will be applied to utility poles and trees, and the "pheromone" flakes now approved for future use. Testing was regarding "efficacy" not safety. There is little if any information easily accessible on these formulations. All percentages of "active" ingredients refer to the "pheromone". It is said to be manufactured by Bedoukian.

The import application states:
"The light brown apple moth pheromone has never been registered in the United States due to the fact that there has never been a need for it until now. USDA APHIS is currently seeking approval for the use of the Hercon Product (LBAM Bioflake) and the ISCA Tech Product (SPLAT LBAM) and expects authorization shortly. USDA APHIS will seek authorization to use the Scentry product, depending upon the results of the comparative efficacy trials in New Zealand."

Description of the Test Program (pdf)
from the Application for approval to Import a Hazardous Substance to New Zealand

"BIODEGRADABLE SOLID FLAKE"

"MICRO-ENCAPSULATED PARTICLE SUSPENSION"

The U.K. has also just jumped on the LBAM gravy train. On May 14, 2009 Exosect "announced that it has received a 120 day emergency approval and consent to market ExosexLBAMTab for the control of Light Brown Apple Moth", even though the moth is not doing any damage there either. We can only wonder how soon this product will find its way into the toxic tool boxes of the CDFA and USDA.

The product is already being marketed with the bizarre claim that the LBAM is "particularly difficult to control with traditional pesticide sprays as the larvae constructs a harbourage by rolling together leaves, buds or fruit with webbing", as though this moth is in some way unique among the many species of leafrollers already long established in our ecosystems.

And as always this product too contains proprietary ingredients, including a powder the exposed moths will help spread as they make their rounds:

"ExosexLBAMTab contains synthetic female Light Brown Apple moth pheromone, which is formulated with Exosect's patented Entostat powder. The system works by attracting males to the tablet where the electrostatic Entostat powder adheres to the antennae and body of the males."

Another disturbing aspect of this program is the possibility that fruit flies could be doused with the "pheromone", then released by air, by the millions, as "Mobile Mating Disruption (MMD)", as another application method of the pesticide. Such methods have been proposed by Max Suckling, who is the "pheromone" expert on the LBAM Technical Working Group, and dubs this method a cross species "Menage-a-trois". Releases of thousands of such "perfumed fruit flies" already occurred in Australia. At the Sacramento EIR Scoping Meeting (YouTube) in August 2008, CDFA's Dr. Bob Dowell explained: "We are looking at other ways of developing and delivering the pheromone, including the use of third party insects, so to speak." Research in this area is indeed underway by the USDA:

USDA Agricultural Research Service LBAM Research Project
"Research Project: Mobile Mating Disruption, the Sterile Insect Technique and Attract and Kill for Areawide Control of Light Brown Apple Moth"
Start Date: Dec 01, 2007
End Date: Nov 30, 2009

Nurseries are being forced to spray any plants suspected "infested" with chlorpyrifos, destroy plants, or close down. Chlorpyrifos is a broad spectrum organophosphate insecticide that damages the immune and central nervous systems, is associated with birth defects, and genetic damage. It contains other hazardous "inerts". One commonly found is xylene, which can cause hearing and memory loss, and leukemia. Chlorpyrifos is also toxic to beneficial insects, such as bees, ladybugs, and parasitic wasps, as well as fish, a wide variety of other aquatic organisms, and birds. Cats and other mammals have been poisoned, and even plants have been damaged by it. Chlorpyrifos is manufactured by Dow AgroSciences.

Toxicological Profile of Chlorpyrifos (pdf) by Northwest Coalition for Alternatives to Pesticides (NCAP)

Chlorpyrifos Fact Sheet (pdf) by Chemical Watch and Beyond Pesticides

Farmworkers sue over Chlorpyrifos danger San Jose, July 2007
"Farm workers and advocate groups today filed a lawsuit in federal district court today against the Environmental Protection Agency to stop the continued use of a deadly pesticide called chlorpyrifos. Chlorpyrifos is a highly neurotoxic insecticide developed from World War II-era nerve gas. Exposure can cause dizziness, vomiting, convulsions, numbness in the limbs, loss of intellectual functioning, and death."

Bacillus thuringiensis kurstaki, a bacteria mixed with secret "inert" chemical ingredients, has been, and may continue to be, sprayed by hand on vegetation, including on private property. During the 2007 LBAM program Btk was sprayed repeatedly on 146 properties in Oakley and 90 in Napa. It is implicated in gastro-intestinal illness and damage to the immune system. It has sickened thousands of people in New Zealand, prompting resistance which led to a People's Inquiry when their government was unresponsive. The formulation used in this program is manufactured by Valent.

Toxicological Profile for Bt by Northwest Coalition for Alternatives to Pesticides (NCAP) (pdf)

Toxicological Profile for Btk by Northwest Coalition for Alternatives to Pesticides (NCAP) (pdf)

No Spray Zone Overview of Btk (pdf)

(Unfortunately until recently No Spray Zone supported the use of disparlure as a "natural" alternative to Btk, and their webpage on the subject remains somewhat contradictory, and the NCAP tox profile for Btk takes a somewhat neutral position on synthetic "pheromones".)

The Btk product used by the CDFA in the LBAM program, is being sprayed from high pressure hoses. It is called DiPel Pro DF, and contains Bacillus thuringiensis var. kurstaki (Btk), in a 46% mix of undisclosed, proprietary chemicals. Pesticide information from the manufacturer, which is obviously not as reliable information as independent science, downplays the risk of harm of their product. But even their Material Safety Data Sheet, label, and Organic Certificate from the Organic Materials Review Institute, don't deny that there are serious risks:

According to the manufacturer's MSDS: "MEDICAL CONDITION AGGRAVATED BY EXPOSURE: Impaired respiratory function."

DiPel Pro DF Material Safety Data Sheet (MSDS)

In 2005, the U.S. Surgeon General reported that in the U.S. 1 in every 8 children has asthma, and the number of asthma sufferers had tripled to 20 million over the 25 years prior, that every day 12 people die and 5,000 emergency room visits are due to asthma.

Asthma is just one of many conditions that impair respiratory function.

According to the label's First Aid instructions, on inhalation of the product, "if person is not breathing", call an ambulance and "give artificial respiration", and skin contact requires rinsing "immediately with plenty of water for 15-20 minutes".

DiPel Pro DF Label

The label clearly states:
"Do not apply this product in a way that will contact workers or other persons, either directly or through drift."

For chilling video footage of pesticide applicators disregarding manufacturer's warnings during the recent CDFA gypsy moth spraying in the Ojai Valley, which was forced on residents by police, please see our Ojai Gypsy Moth page.

Pictures of CDFA hosing down a neighborhood with Btk during the LBAM program in 2007
In these pictures the pesticide is not dispensed from common backpack sprayers, but from trucks with long hoses dragged through the neighborhood

Spinosad is another product to be used in this manner. It is "approved" for organics, representing further dilution of organics standards. It is considered non-synthetic, but also contains undisclosed synthetic "inerts". Spinosad is implicated in the killing of non-target species. In a world with modern agriculture facing vanishing pollinators, we must not take lightly the possibility of further impacting crippled species. Spinosad is very toxic to honeybees, oysters and other marine mollusks, and somewhat toxic to birds, fish, and aquatic invertebrates. Ironically it is also harmful to the Trichogramma wasp, another part of the LBAM eradication program. The Organic Materials Review Institute (OMRI) describes that "the mode of action is unique and incompletely understood. Continuous activation of motor neurons causes insects to die of exhaustion… May be some effects on the GABA and other nervous systems". Even the USDA admits that it has insecticidal activity against some butterflies, moths, thrips, flies, termites, wasps, ants, bees, and beetles, and determines that in order to "reduce" the potential for resistance to the insecticide, no more than three applications may be done over a 30 day period, and no more than six applications per year.

Spinosad requires microbial activity for breakdown, so if used where toxic herbicides have been used, build-up in soil is expected. In any neighborhood where residents, gardeners, landscapers, municipal agency-users apply such herbicides, persistence in soil is a by-product and would be expected to become a danger to humans and honeybees through contact with residues left on site, and drift of residues, in addition to any drift at the time of application. So while it is "approved" for some use in organic production, it is only done so with strict warnings about toxicity to some species, and with strict clarification that it is only considered because of the rich microbial activity found on organic farms. It is not intended for use in city parks where herbicides have been used, nor is it intended for wholesale distribution into neighborhoods where usage of herbicides is not known. OMRI states that "Spinosad, while an improvement over some materials, is still fairly broad spectrum and not representative of an ecological approach." Spinosad is also manufactured by Dow.

Review of Spinosad by Organic Materials Review Institute (pdf)
"These review comments should not be taken to be an evaluation of the patented formulation of Spinosad containing inert compounds."

And just how are the millions of tiny trichogramma wasps, which the CDFA plans to use in several areas of San Francisco and Santa Cruz counties, going to be "released"? Common methods include distributing eggs manually, on cards, or sprayed by hand or mechanically, including by air, in some cases suspended in a chemical polyacrylate (plastics) thickener mixed with water, likely from equipment previously contaminated with pesticide residues. The USDA LBAM treatment plan only describes the release as "parasitized moth eggs (other than LBAM) containing Trichogramma pupae", but does not elaborate on the method of application.

Summary of application methods of Trichogramma wasps

Actual size of wasps is no more than half a milimeter (0.02 inches) long

On June 19, 2008, the CDFA announced that aerial spraying over "urban" areas would be suspended, though would continue in areas considered not "urban", and the rest of the program would continue. Though CDFA representatives have claimed repeatedly that another tool in their eradication plans, "Sterile Insect Technique (SIT)", would be in development for some years to come, it suddenly became available, and ready to be implemented as early as Winter 2008 or Spring 2009. Sterile moths are anticipated to be released by air planes and possibly by ground, on a frequent and regular basis, as often as weekly or bi-weekly, by the millions.

In response to a question asked by the public at the Sonoma County Board of Supervisors in July, whether any substance will be applied to the sterile moths, the CDFA answered:

"The moths will be marked so that they can be distinguished from non-sterile moths. A fluorescent dye powder is applied to the moths before release."

We have not been able to ascertain what precise dye CDFA plans to use for the moths, but have learned that one such dye used in tracking insects, part of the AX-Series manufactured by DayGlo, contains formaldehyde, a known carcinogen, and subject to Proposition 65.

The first moths were made in Albany:

Western Regional Research Center
USDA, ARS, WRRC
800 Buchanan Street
Albany, California 94710
James N. Seiber, Center Director (510) 559-5600 james.seiber@ars.usda.gov

In February 2009 CDFA/USDA began moving their LBAM Headquarters from Watsonville to Moss Landing, in preparation of transporting the first LBAM pupae from Albany to be irradiated there.

Meanwhile Wine Country Ag representatives "volunteer" their counties for the trial release of sterile LBAM. Research plots are apparently being set up in the Carneros region.

The health complaints experienced by Monterey and Santa Cruz county residents, who were exposed to CheckMate in Fall 2007, were consistent with the expected effects of the ingredients that were revealed to the public. Hundreds of people were reported to have been made ill by the aerial spraying, including an 11 months old baby who went into respiratory arrest, and several pets got ill, and some died, of identical symptoms as experienced by affected people. While the CDFA publicized that many of these reports are duplicates, the actual number of people injured is likely much larger, as many people have since explained that they did not make a formal report of their symptoms for various reasons, including lack of access to medical care.

List of health complaints - Fall 2007

Full report of 2007 health complaints (8 MB pdf)
Many reports representing several people living under one roof. Also including survey of impact on homeless residents of Monterey and Santa Cruz.

Analysis of CheckMate by Dr. Lawrence Rose, M.D., M.P.H., recently retired senior Public Medical Officer for Cal-OSHA, and Occupational/Environmental Medicine practitioner at UCSF:

Dr. Rose also points out that "Physicians are legally required to report diagnosed pesticide diagnosis; but in the two sprayed counties there was no systematic notification that included probably short term health reactions sent to health providers, first responders, emergency rooms, or all residents before the September, October, and November 2007 sprayings. This is a shocking disregard of human rights in any democracy."

Letter to Joan Denton (OEHHA) and Mary-Ann Warmerdam (CDPR) (pdf)
by Michael Lynberg, a member of the public, who has taken it upon himself to collect the health complaints, notifying the Office of Environmental Health Hazards Assessment (OEHHA) and the California Department of Pesticide Regulation that as of March 2008 the illness complaint count from 2007 has risen from 643 to 801, with many more likely left unreported

Interview with Michael Lynberg about the health reports (YouTube video)

The Day the Doctors Finally Read Toxicological Profiles of Pesticides (a dream)
Maxina Ventura's response to OEHHA's 2008 disrespectful report which suggests that all the sickness after Monterey and Santa Cruz sprayings was not pesticide poisoning, even though they never spoke with anyone who was injured, nor their physicians.

While OEHHA and CDFA downplay the results, the limited acute testing of some LBAM products, which was ordered by Governor Schwarzenegger, revealed serious safety concerns, including discolored organs in exposed test animals, and effects on the immune system. The LBAM products tested were CheckMate, SPLAT, NoMate, and Disrupt. The most commonly used application methods, the twist ties and traps, were not included in the testing.

OEHHA 6-Pack Acute Testing Review

Dr. Ann Haiden's Commentary about 6-Pack Tests
"There were worrisome findings that require explanation and investigation, such as abnormal organs, one death and consistent evidence of skin sensitization related lymph node activation in the test animals. ... The consensus has downplayed the positive lymph node tests (LLNA), which evaluate early phase lymph system activation by measuring lymphocyte proliferation. The positivity of this test, rather than being questionable or of marginal importance, is more likely a landmark finding for how environmental chemicals effect and set the immune system on its future course. These findings may give profound insights into how and why there is a persistent increase in immune, neurological and inflammatory related illness in the population."

Statement regarding 6-Pack Tests by Stop the Spray, followed by detailed comments by John Thielking

The Department of Pesticide Regulations has admitted that environmental monitoring during the pesticide applications over Monterey and Santa Cruz counties confirms substantial pesticide drift at least as far as 3.3 miles outside of the target areas. The DPR's deposition study also reveals that communities were exposed to inconsistent doses of the chemicals, because the capsules containing the pesticide "tend to separate out of the mixture quickly and require constant mixing":

Deposition study by the Department of Pesticide Regulations

Health problems reported after aerial spraying interview with Timothy Wilcox,
father of the 11 months old baby

Declaration of Timothy Wilcox (pdf)
Father of the 11 months old baby

Declaration of Steven Bruno (pdf)
who repeatedly developed symptoms when exposed to CheckMate persisting in environment for 30 days after spraying

Declaration of Gina Renee (pdf)
Acupuncturist who treated many injured people after CheckMate was sprayed over Monterey

Homeless people were left unsheltered during the spraying, and even more impacted than their housed neighbors.

Santa Cruz Mayor ignored pleas from homeless advocates prior to the aerial spraying

Santa Cruz Councilmember evaded questions about how to protect the homeless from further spraying

Also not being addressed by officials is how future spraying and other pesticide use will impact prisoners at San Quentin and other jails in the spray zones, as well as juvi lockups and psychiatric wards, let alone the treesitters at the University of California, and other vulnerable members of the community, such as children, pregnant women, the elderly, the already chemically injured, and others with compromised immune systems, all already under much physical distress.

The twist ties and traps have also impacted people's health, and we've been told by several people that they got ill from exposures by traps and twist ties, which contain the same synthetic "pheromone" as the aerial spray. Some of these exposures occurred at public meetings, to which government officials from CDFA and OEHHA brought these pesticide products, which is surely not an approved use of a chemical that has been declared permitted only in the context of the so-called LBAM "emergency" in the State of California, not for show-and-tell at public hearings.

Symptom Report Form from Maxina Ventura after sickened by LBAM "pheromone" traps and twist ties at office of the head of the Alameda County LBAM trapping program in April 2008

Another Symptom Report Form from Maxina Ventura after sickened by LBAM "pheromone" twist ties and other moth traps at a public hearing with CDFA and OEHHA in the chambers of the Sonoma County Board of Supervisors on July 8, 2008

Symptom Report Form from Isis Feral after sickened at the same meeting in Sonoma.

Prior to the meeting, Maxina Ventura contacted the CDFA and the Sonoma Board of Supervisors, requesting that the public not be exposed to pesticide products, such as twist ties or traps at the public hearing. Her mailing was confirmed received by public records requests by the Sonoma Board of Supervisors, as well as by OEHHA, where it was forwarded by the CDFA. The CDFA, in violation of the Public Records Act has yet to respond to our request for these same records.

Confirmation of Receipt of Access Request from the Sonoma Board of Supervisors with all attachments sent by Maxina Ventura

Confirmation of Forwarded Access Request from the Office of Environmental Health Hazard Assessment showing extensive forwarding within CDFA and OEHHA

In spite of the liberal forwarding of this request, and phone messages to LBAM Environmental Advisory Task Force member Ann Maurice, a large table with a variety of pesticide products, various traps with chemical lures, was set up outside the doors to the meeting by Ann Maurice, and Moira Sullivan, OEHHA representative, brought twist ties and a trap inside the crowded meeting chambers.

Moira Sullivan holding up twist ties in a flimsy ziploc bag, and a moth trap, at the meeting with the Sonoma County Board of Supervisors, July 8, 2008.

When Maxina Ventura attempted to represent East Bay Pesticide Alert/Don't Spray California, combining speaking time also from Isis Feral, as recommended by Robert Leavitt of the CDFA when he refused us an opposing panel at the hearing, Mike Kerns, Chair of the Sonoma County Board of Supervisors, cut her off early. Even though he had said "Okay, Thank You" when Isis Feral ceded her time to Maxina Ventura, Kerns suddenly insisted such combining of time is not permitted, even though we have been told by members of the public who frequent these meetings, and by other Sonoma County staff, that such pooling of time is not uncommon.

Transcript of Maxina Ventura's Testimony Sonoma July 8, 2008

Adding insult to injury, Mike Kerns admonished Maxina Ventura, saying:

"I suggest that if you feel your health is at risk, whether it be real or imagined, you may leave these chambers."

So much for public access...!

In addition to the health complaints, considerable emotional trauma was expressed by residents, who were kept awake by the planes flying low, back and forth over their homes:

It's Like the Fog, but More Toxic - Comments During and After the Spray

Psychological Stress Caused By LBAM Spraying - How Are You Doing?

Declaration of Konnie Mast (pdf)
whose cat suffered respiratory distress and was rushed to hospital and recovered only slowly after treated with antibiotics

Kathleen Manoff's description of her dog dying

Summary Report: Post-Spray Effects on Animals and Pets (pdf)

In the days following the 2007 sprayings, residents reported that gardens previously full of birdsong and buzzing bees, were silent, as birds and bees avoided the sprayed areas long after. In the immediate aftermath, hundreds of dead birds were "mysteriously" washed ashore, including the endangered Brown Pelican. The Department of Fish and Game denies that there is anything in CheckMate that could possibly have stripped their weatherproofing off of the birds, or contributed to the worst red tide in decades, which was later blamed for the deaths of the birds. The red tide in turn was blamed on surfactants in the water. CheckMate contains several surfactants.

Moss Landing Mystery Spill - Discussion

Light Brown Apple Moth Spray Causes Severe Red Tide (YouTube video)

Surfers in The Red
Red tide after spray made surfers in those waters sick, some with long lasting respiratory effects.

Research shows: Red tide forming algal blooms prefer to feed on urea from urban runoff
CheckMate also contains urea. It rained after the aerial spraying, and the storm drains lead straight to the bay.

Pilot Error over homes, and Water Exclusion Zones (YouTube video)
Not all watersheds were excluded from the spray zones. The San Lorenzo River was not an exclusion site. Pilots made known errors on four separate days. The GPS system that was supposed to guarantee precision, instead confirmed their errors.

Pilots Mistakenly Spray Outside Zones

CDFA letter to property owners of areas sprayed accidentally (pdf)

Though the impacts are precisely what would be expected from exposure to the chemicals that were dumped on Monterey and Santa Cruz, the CDFA explains away these impacts as coincidental, that the quantity of the chemicals was too small to possibly have caused them. But the CDFA doesn't appear to have a handle on the measurements of our exposure. Is it 33 microcapsules per square foot, or is it 114, or maybe 809,...? Such widely divergent inconsistencies are not confidence inspiring.

Their goal, in any case, was 600-900 microcapsules per square foot. And while the CDFA argues strenuously that the capsules are not the size of particle pollution, which the American Lung Association considers any air borne matter between 2.5 and 10 microns, the manufacturer's own analysis admits that 1.2 % of the capsules are smaller than 10 micrometers (which is equal to microns). A square foot is not such a large area, and 1.2% of 33-900 can add up quickly.

Exposure levels according to the CDFA (YouTube video)

What ARE your rights?

Your constitutional rights about nearby pesticide use (pdf)

The Constitutional Rights That Exist To Protect You From LBAM Aerial Spraying

Nuremberg Code - Directives for Human Experimentation
Relevant to CheckMate, the synthetic "pheromone" containing pesticide, which has been untested on humans, and therefore its use over human populations constitutes experimentation without consent.

So what about refusing access to private property for any of these applications?

According to the CDFA's Potential Questions & Answers (pdf) about the LBAM project:

"If I don't want applications applied to my property, how do I get out of it? Can the owner prevent application on private property?

No. In order to have a biologically sound program, CDFA/USDA cannot have a series of untreated refuges in which the moth can breed and re-infest treated areas, therefore the State of California can require access to private property in order to deal with a threat to the public."

However, the USDA's own Emergency Programs Manual (pdf) makes a good case for joint actions and a united front with our neighbors: One of several conditions under which an emergency program can be terminated is when "Sociopolitical opposition prevents emergency action" (page 91). As an example, during the CDFA's Glassy-winged Sharpshooter project, in the early 2000's the people of Northern California's wine country prepared to risk arrest to protect their families and homes from the government's threat of pesticide use against them.

Contact us if you are interested in organizing non-violent civil disobedience and direct action training, and we will get you in touch with trainers in your area, or provide our own:
beneficialbug@netzero.net

What Would Gandhi Do?

If this pesticide program continues, what can you do to protect yourself, your family, your pets, and your gardens from the pesticide applications?

Safety Precautions related to aerial spraying of CheckMate

Description of difficulties of cleaning up a garden after the spray, and safety precautions taken (YouTube)

Familiarize yourself prior to the spraying and other exposures with the various protocols you may wish to take in case you are poisoned. Print out the forms below and have them readily available, also look through the tips and suggestions for recovery and research the preventative steps also listed there that may be appropriate for you. None of the remedies here are meant as medical advice nor endorsed by East Bay Pesticide Alert/Don't Spray California, but are provided in the spirit of sharing resources.

If you are sickened by any of the CDFA's pesticide applications - bring the following form to a doctor, hospital, or clinic. Medical professionals are required by law to fill out and submit this EPA form within 24 hours if an illness is known or suspected to have been caused by pesticides:

Pesticide-Related Illness Report (pdf)

Additionally, you have up to 6 months to fill out a claim form for injuries or property damages against the CDFA:
CDFA Claim Form (pdf)

To ensure your reactions to the pesticides are reported, also send a symptom report to ReactionToSpraying@yahoo.com , or POB 1612, Pebble Beach, CA 93953, where the same grassroots efforts, which brought to light the injuries in 2007, will continue to collect health complaints:

Symptom Report Form (pdf) (MSWord)
updated from original used in Monterey in October 2007 to include all areas and all parts of the LBAM trapping and eradication program.

Some suggestions to help with preparing for and recovering from the chemical assault, focused especially on nutritional and herbal support of the liver and immune system to boost its ability to help the body to detox:

Summary of Detoxification Tips from Layna Berman - LBAM show on Your Own Health and Fitness, KPFA (pdf)
Nutritional support to support liver functioning of detoxification (Listen here)

Suggestions from Karyn Sanders on Herbal Highway, KPFA (pdf)
A few useful herbs to help detox (Listen here)

Prevention and Recovery Tips from Dr Randy Baker - Quick Reference (pdf)
A variety of tips from a doctor who treats many patients with chemical injuries

What Does Pesticide Poisoning Feel Like? LBAM Spray Preparedness

Natural Health Tips from Hope for Truth - Quick Reference (pdf)
A variety of tips from an activist

Get support and share resources with other chemically injured and our allies on the local Yahoo group:
Bay Canary Grapevine

As a result of much public pressure the schedules and strategies of the LBAM program have been altered repeatedly, sometimes giving the illusion that the worst is over. But the program has in fact been expanded to ever larger parts of California, and quarantine boundaries are constantly widening. For the latest updates, please always double-check with the CDFA, unreliable though they are, and demand they keep the public informed of their actions.

Quarantine Manual as of April 29, 2009, with precise boundaries and maps

Their precise action plan will be unclear until the Programmatic Environmental Impact Report is released, which is expected to be ready for public comment in June 2009. The following information was compiled over the previous year, and reflects some of the changes in CDFA's plans:

On June 19, 2008, the CDFA announced that it would halt the aerial spraying of urban communities. In a conference call Ag Secretary Kawamura clarified that the aerial spraying is only halted over "urban" areas, and only for this program, but may well become a tool in future eradication programs of other organisms. And CDFA Public Affairs Director Steve Lyle qualified the announcement by saying "At this point we will not be aerially spraying with moth pheromone in urban areas in the infestation zone".

But what does "urban" or "populated" or "accessible by road" really mean? Bay Area and Peninsula cities and towns are surrounded by vast forests and parks, and if they are sprayed, drift is inevitable. And what about rural communities, whose agricultural neighbors expose them to a large array of chemical cocktails daily? Is it a victory if another chemical mix is added to their already heavy toxic body burden? As of July 24, 2008 there has been no clarification of the area still in the CDFA's spray zone. Comparing the map of the CDFA's prior plans with a satellite map, which areas look like "non-urban" and "forested" to you?

The following was the plan of the CDFA prior to June 19, 2008. The ground applications are moving forward, as are likely some of the aerial applications:

The plan, once implemented, was scheduled to occur every 30 or 90 days for 9 months of every year, for at least 3-5 years. That adds up to being doused in chemicals a minimum of between 9 to 45 times over the next few years, from planes flying overhead at 500-800 feet, or reportedly lower, with chemical mixtures designed to be time released, and to persist in the environment in between spraying, to be dragged home on our shoes, clothes, our pets, and in our lungs, year round.

According to the CDFA map of proposed pesticide applications for 2008, the communities to be SPRAYED BY AIR, which may also involve PERMETHRIN PAINTED on utility poles and trees, though the details of this part of the program have not been clarified, include the following

Beginning August 17, 2008 (postponed from June 1, 2008) continues to be the date of aerial spraying to begin, though which of the following areas remain in the spray zone is unclear, as is which of them and others will be in the drift zone:

(postponed from August 1, 2008):

CONTRA COSTA COUNTY:
Hercules, El Sobrante, Orinda, Pinole, San Pablo, Rollingwood, East Richmond Heights, North Richmond, Richmond, El Cerrito, Kensington, Canyon (and very close to spray zone: Lafayette and Rodeo).

ALAMEDA COUNTY:
Albany, Berkeley, Emeryville, Piedmont, Oakland, and the City of Alameda.

MARIN COUNTY:
Sausalito, Belvedere,Tiburon, Marin City, Strawberry, Mill Valley, Greenbrae, San Quentin (and close to spray zone: Larkspur).

SAN FRANCISCO City and County.

SAN MATEO COUNTY: South San Francisco, Colma, Broadmoor, Brisbane, San Bruno, Daly City, Pacifica (and close to spray zone: Millbrae).

It should be noted that as frequent as it sounds to be sprayed and exposed to drift once every 30-90 days, the reality is much worse: In the Fall 2007, those 3 aerial applications were executed over the course of 12 days: According to the CDFA report to the Legislature Monterey was sprayed September 9-13, and again with a different formulation on October 24-26. In Santa Cruz, they went back to the first formulation for November 8-9, in Prunedale on November 9, 11 and 12, and in Salinas on November 9 and 11.

The areas sprayed by planes in 2007 were a total of 88,613 acres. Of the 571,259 acres, 892 square miles, established as the areas to be pesticided back in February 2008, the areas to be sprayed by planes total 444,060 acres, 693.8 square miles.

For more details of what happened where, please see the deposition study of the Department of Pesticide Regulations, which describes environmental monitoring during the pesticide applications over Monterey and Santa Cruz counties. It confirms substantial pesticide drift at least as far as 3.3 miles outside of the target areas, as well as reveals that communities were exposed to inconsistent doses of the chemicals, because the capsules containing the pesticide "tend to separate out of the mixture quickly and require constant mixing".

Deposition study by the Department of Pesticide Regulations

Hand spraying of Bt in Oakley and Napa in the summer of 2007 was replaced by twist ties, which were placed there and in Danville, San Jose, Sherman Oaks, and continue to be in Dublin, Pleasanton, Vallejo, and Mare Island. They are also being "deployed" in various counties in 2008.

TWIST TIES, beginning in March 2008, are underway or planned for:

The following are vaguely called "ERADICATION AREAS", and are currently listed as targeted for twist ties:

See the twist tie treatment maps for more detailed and updated information

The CDFA's initial plan was to also paint "MALE ATTRACTANT TREATMENT" on utility poles and trees in the following areas, but according to their official map of February 2008 those plans have been dropped, at least for now. Strangely, the previous map has since surfaced again, when it was presented to the City of Piedmont, and posted on the city's website as part of the CDFA power point presentation.

The CDFA has also found moths in San Luis Obispo and Sonoma Counties, as well as Los Angeles and Napa Counties, where the moths have supposedly been eradicated. If more are found in those areas, or other areas being monitored, pesticide applications may be expanded to include them.

In fact parts of Sonoma County are already under quarantine, and was slated to be treated with twist ties in June 2008, but neighborhood unity held off the applications, as many refused to have them placed on their properties.

In 2009 several more areas in Sonoma and Napa Counties were added to the quarantine, as well as in Yolo County. Some Napa growers are ready to volunteer to be the testing ground for the first irradiated LBAM releases. San Benito County has also been added to the quarantine.

An updated map is to be released before further aerial pesticide applications are made.

In July 2008, the CDFA announced the intention to expand the LBAM program to most of California:

The United States Department of Agriculture, Animal and Plant Health Inspection Service (USDA-APHIS) is also conducting a National Survey, in 2007 still voluntary from state to state, in search of the LBAM. They estimate likely areas for future LBAM infestation across 80% of the continental U.S.

USDA schedules national survey to track invasive moth April 1, 2008

USDA-APHIS National Survey Guidelines (pdf)

larger map

Until March 2009, the USDA and CDFA were gathered at a compound outside of Watsonville, harassing farmers, and preparing their next step.

In February 2009 CDFA/USDA began moving their LBAM Headquarters from Watsonville to Moss Landing, in preparation of transporting the first LBAM pupae from Albany to be irradiated there.

Sign up for email updates from the CDFA
but don't depend on them, or their postal announcements, as your only source of information, as the CDFA has proved to be quite unreliable in their communications.

Also check weekly CDFA Situation Reports for changes

And CDFA Press Releases for public announcements

Contact the CDFA - Ask for clarifications, demand answers, let them know how you feel about this program

For an example of how such a conversation might go, read the account of Don't Spray California's Chronic Effects Researcher: Maxina Ventura's talk with a clueless CDFA rep 2/08/08 (pdf)

Or her email exchange with Steve Lyle, who determined that the cost of informing her about use of LBAM pesticides in areas, which she and her children frequent, would be $3000

In Fall 2007 even city officials were largely taken by surprise by the aerial spraying, so calls to your own government's representatives may not be much more informative, but some municipalities are mobilizing against parts of the CDFA's program. Please contact them, find out what they've been told by the CDFA, what measures they're taking to protect the public, particularly our homeless neighbors, and ask them to take united legal and direct action against forced pesticiding by any method.

List of areas to be pesticided and contacts for local representatives

email addresses from above list of contacts - for easy pasting
(most email programs allow you to send only a limited number at one time)

Sign up for Google News Alerts
Enter "apple moth," "lbam", "aerial spraying," "twist ties" or any other relevant key words, plus your email

Search sites of groups opposed to LBAM program to do more indepth research of your own

Sign up on the Stop Overhead Spraying Yahoo Group
Community Listserve for discussing, sharing resources and research, and to organize collectively against the LBAM program, evolved into more than just about aerial spraying.

So what could be so bad that the CDFA would take such a risk with the lives of California residents and visitors? They've declared an emergency to battle the light brown apple moth, a tiny Australian bug, which is claimed to inevitably eat us out of house and home, but has done no significant crop damage, nor is it likely that it will. In fact the LBAM's damage to crops is largely cosmetic. It is one of many manufactured crises that benefits the multi-billion dollar chemical industry, because it traps municipalities on a neverending toxic treadmill. The LBAM is certainly not an emergency, potential or otherwise.

LBAM Takes San Francisco (YouTube video)
Starring: Oakland-based performance crew headRush (Rosa Esperanza Gonzáles, Xago Juárez and Simón Hanukai) Written/directed/edited by: Patrick Wilkinson (Special thanks to: La Peña Cultural Center, Destiny Arts Center, and Centro Legal de la Raza)

(actual size of light brown apple moth)

Unlike the CDFA would lead us to believe, the LBAM is not considered a significant threat in New Zealand, where it has been well established for over a century, but pesticides are, as is shown by plant experts Dr. Daniel Harder and Jeff Rosendale, who recently returned from New Zealand where they researched the issue in depth. Dr. Harder is the Executive Director of the UC Santa Cruz Arboretum, which includes plants from New Zealand and Australia, and is Adjunct Professor in the Ecology and Evolutionary Biology Department. Jeff Rosendale is a grower and horticultural consultant in the Monterey and San Francisco Bay Areas who specializes in plants from California, Australia, New Zealand, South Africa and Mediterranean Europe. They found that there "is no evidence of biological or environmental threat from LBAM in New Zealand":

"Reports of damage to crops prior to 2001 in Australia or New Zealand are from the era when organophosphate pesticides were heavily used to control LBAM (to comply with USDA requirements that no trace of LBAM be found). These pesticides eliminated LBAM's natural predators. Once organophosphate use stopped in 2001 and natural predator populations rebounded, New Zealand's LBAM problem was greatly reduced to its current, insignificant level."

"Under the organophosphate spray regime, LBAM was a problem of greater significance than it is today, and all pests were more difficult to control and became increasingly hard to keep in check. Populations of insects, including LBAM, developed resistance to the organophosphate formulation." - "...experts also question the efficacy of bacillus thuringiensis (Bt) against LBAM. Bt can also have a detrimental effect on beneficial insects."

"The requirement that California nurseries use chlorpyrifos [sic] sets California up for failure of long-term LBAM management and management of future pests that would otherwise be controlled by natural predator species that will be compromised or eliminated by chlorpyrifos [sic] use. This and other highly toxic treatments need to be discouraged or prohibited in commercial nurseries."

LBAM Status report from New Zealand by Dr. Daniel Harder and Jeff Rosendale (pdf) March 6, 2008

Harder and Rosendale respond to CDFA's criticism of New Zealand report (pdf) April 2, 2008

The report further notes, that "According to New Zealand Ministry of Agriculture and Food (MAF) and Department of Conservation (DOC) experts, LBAM does not build up in any one host in the wild and has never posed a threat to native forests. Natural predators keep LBAM in check, and it is so rare in the wild that it requires a true expert and meticulous searching to even find any sign of it."

Yet U.S. tax dollars, set aside for this pesticide program, are being wasted to test their toxic chemical mixtures on this elusive LBAM population in New Zealand. On February 17, 2008, The New Zealand Press Association reports that "Two state-owned science companies in New Zealand are extracting some of that cash in return for expertise Hortresearch has in use of pheromones -- sex attractants -- to disrupt mating behaviours by pest insects, and expertise forestry research company Scion has in precision aerial spraying."

NZ forest provides laboratory for pheromone trials NZPA 2/17/08

Application to Environmental Risk Management Authority New Zealand to import various chemical formulations of the "pheromone" for field trials

In Hawaii, where LBAM has also been established for more than a hundred years, it not only is not considered a significant pest, but may even be considered beneficial, as a control measure for invasive gorse and blackberry, according to the Hawaii Department of Agriculture.

Hawaii Department of Agriculture Press Release in response to USDA Quarantine May 2007

According to UC Davis entomologist James R. Carey, the moth has probably been in California as well for "a very long time prior to its discovery and it's probably far more widespread than currently delineated".

And just how did the CDFA determine the number of LBAM in California? The CDFA's 2007 Report to the Legislature (pdf) states that part of their research objective that year was to "Develop an effective DNA fingerprint and identification technology for LBAM":

"In California there are native moths in the same family as the LBAM. Since LBAM is not known to occur in California, a comprehensive key for identifying the larvae does not exist. Therefore, if larvae suspected of being LBAM were collected from commodities from within the quarantined area, they could not be sold until the commodities were treated with an approved treatment. To remedy this problem, the protocols for the molecular diagnosis of LBAM larvae were developed by the USDA, Pest Detection, Diagnostics and Management laboratory, in consultation with the Department's Plant Pest Diagnostics laboratory. By June 18, 2007, the Department was able to identify LBAM larvae using DNA sequencing."

The CDFA's claims that no LBAM were found in 2005, and their claims of infestation in 2007, followed by the quarantines, were all established before this "effective identification technology" was developed...

The LBAM Program - A Fraudulent Program by Glen Chase, Professor of Systems Management, specializing in Environmental Economics and Statistics

LBAM in California - The True Story: Summary & References through June 19, 2008
Prepared For the People by Professor Glen Chase

Fraud and Deception: The CDFA LBAM Eradication Program
A Detailed Description of Management Strategy Fraud, by Glen Chase

LBAM - Implications for California Agriculture (pdf)
Dan Harder, Jeff Rosendale, Roy Upton, Teresa Aquino, and Kenneth Kimes, plant experts and nursery owners show that the eradication efforts and quarantine have far greater implications for Agriculture than the moth.

As paraphrased by the Monterey Herald, Carey has indicated that "the state has to show it is making efforts to eradicate the pest, even if the efforts aren't effective", that "the primary economic impact of the moth is likely to be the result of trade restrictions from imposed quarantines, and not crop damage caused by the moth." Carey said that "to acknowledge that they're established is to unleash economic consequences that are even more devastating than the spread would cause,…to acknowledge the truth is to trigger these embargoes and quarantines that are absolutely devastating, so they're always playing this game that it's 'eradicable' "

Dr. Carey's Presentation to the State Senate Environmental Quality Committee (pdf) March 2008

UC Davis Experts Letter to the USDA (pdf) May 2008
Putting the eradication program in question as not based in science.

The USDA/CDFA LBAM pesticide project has nothing whatsoever to do with securing our food supply, nor with environmental protection, nor with public health and safety, but everything to do with the politics of trade between profit hungry multi-national corporations, at the expense of the public. What the government agencies are defending here is not our food supply nor our ecosystems but capitalist interests in international trade. The LBAM is no threat to us, but it is a threat to a complex system of agro-business trade agreements, formed not to safeguard human or environmental health, but rather to guarantee supremacy in the marketplace for the U.S., specifically to crowd out competition. The LBAM quarantine is a tool of big agro-business to achieve this supremacy.

UC Berkeley Agroecology Professor Miguel Altieri explains:
"Free trade,…most of the western countries are involved, basically functions on restrictions to trade, and one of the restrictions to trade is quarantine pests."

"$75 million, the USDA is gonna devote for…the eradication, which is actually an ecological illusion: It's totally unsound to do that, because you cannot eradicate organisms. …$75 million is actually 20 times more than the budget that the University of California devotes to organic farming. If we had $75 million to do research on organic farming alternatives, we wouldn't have to worry about this pest or any other pest."

"So who is afraid of the pest? It's basically…two groups: One is agri-business and the other is the University of California, which serves agri-business."

Larry Bragman, member of the Fairfax town council points out that Mexico's quarantine demand is subject to change, depending on the very sort of scientific study Harder and Rosendale conducted in New Zealand. "If the NAFTA quarantine demands are withdrawn, California farmers will not face significant economic losses from this moth. The health and safety of residents should not be subordinated to U.S. trade policy."

Larry Bragman: Will U.S. trade policy again trump public health?

In a public vow to "work vigorously to stop" the spray program, Robert Lieber, Mayor of the City of Albany, one of the cities on the list to be sprayed aerially, and Registered Nurse with extensive experience in respiratory care, who provided emergency triage and healthcare after many toxic chemical accidents and releases, including the Chevron spill, declared that "we cannot risk public health to protect business interests." Beyond merely this one, of an endless series of pesticide programs, he pointed out that "eradication is no longer a realistic pest management goal in view of world trade and global warming, which will continue to introduce new pests to California. We cannot continue to risk human and environmental health by spraying for every new bug".

Statement against CDFA's LBAM program by City of Albany Mayor Robert Lieber, RN (MS Word)

Organic farmers are bearing the brunt of the burden of the CDFA's pesticide campaign. As Steven Munno, an organic farmer from UC Santa Cruz, described at our community brainstorm in San Leandro in February 2008, the LBAM, which is present at the farm on which he works, is not doing significant damage to the crop, but the government's wasting time with paperwork better spent farming, and the demands to constantly handle crops in search for the LBAM, is doing the real damage, especially to strawberries.

Federal and state inspectors to descend on Santa Cruz County in search of moths May 11, 2007

What happens if nursery owners refuse to comply with spraying pesticides on their plants?

Blue Bamboo nursery forced to close June 27, 2007

Invasive Procedures March 18, 2008

As another farmer states on Michael Olson's MetroFarm forum:
"It's the possible spraying of my organic farm with the so-called "inert ingredients" that I object to. Those chemicals don't belong in the FOOD CHAIN … If my farm's products are no longer "organic", certifiably or otherwise, then my livelihood is damaged! WHO DO DAMAGED FARMERS SUE FOR DAMAGES? What person or agency? ... As for Organic Certification, that is beside the point. I could not sell contaminated animal products in good conscience, especially to those who want or need unadulterated food for preexisting reasons."

The California Food and Agriculture Department is clearly not concerned about organic farmers, as organic standards are in the process of being diluted further, and many of us will be enforcing our own embargo once the spraying starts, on all our own locally grown foods, which we know will no longer be organic, no matter what the label may be allowed to claim. Sure, imagine the economy with a negligable risk of loss of those obscene conventional agriculture profits... But imagine also the impact of people who previously bought local now buying elsewhere.

Organic's Organic Metro Active on the natural food industry seeking organics grown outside the spray zones.

Even sharing and bartering of homegrown food has been made illegal by the quarantine, as can be seen in this recent example of the Veggie Trader website prohibiting quarantined neighbors to post their harvests:

"San Francisco Bay Area Residents, please note:
Because of a comprehensive produce quarantine in place for most of your region due to the light brown apple moth, we unfortunately can't allow items under quarantine to be posted on Veggie Trader. For more specific information on the quarantine and the areas affected, please refer to the California state department of agriculture website."

The Light Brown Apple Moth vs. Veggie Trader

VISITORS & RESIDENTS

Imagine people dreaming of moving here for the clean air, thinking the better of it, and seeking real estate elsewhere. Imagine current residents packing up and leaving the area.

Moving Because of LBAM Spray - California's Refugee Problem

Ishana's Farewell to Santa Cruz

Imagine travel advisories that the San Francisco Bay Area and Monterey Peninsula are no longer safe vacation spots. People from every continent have signed the petition against the spraying! Imagine athletes adding California to the list of places, like some olympians in Beijing, where they refuse to compete because of pollution. Discussions and Eco-alerts have already been posted on Fodor's community forum about the safety of visiting the spray zones.

Our Own Pesticide Alert Travel Advisory - Letter to LinuxWorld Conference (pdf)
Melinda Kendall, is the Vice President and General Manager for the LinuxWorld conference, which is scheduled at Moscone Conference Center in downtown San Francisco August 4-8, 2008, the week that the spraying was likely to begin there, before the recent postponement of the aerial applications.

Our Especially Urgent Pesticide Alert Travel Advisory - AIDS/LifeCycle Ride Campers (pdf)
On June 1, 2008, the night the spraying was to begin again over the Peninsula, several hundred HIV+ bicyclists of the AIDS/LifeCycle Ride, a large fundraising events for AIDS services, will be camping in Santa Cruz that night, along with a few thousand other riders and volunteers. There was grave concern for the safety of the many participants who are particularly at risk because of their compromised immune systems, as can be seen on the petition to Stop the Spray (page <14,100).

LBAM Aerial Spraying on California's 315 Million Tourists

Spraying to fight moth in California could have economic impacts

LBAM: Economic Impacts and Solutions (pdf) a CASS Research Summary

The Real Cost of LBAM Aerial Spray (YouTube video)
Estimates that the impact on tourism, real estate, and other industries in the spray zones, is in the billions of dollars, far outweighing even the most hysterical estimates of possible LBAM damage by the USDA and CDFA. This video was also seen on a tourism website.


Red dots represent approximate areas in which the CDFA claims LBAM trapped from Sonoma to Santa Barbara. See CDFA's own quarantine maps for updates and specifics.	On July 21, 2008, the CDFA announced the intention to expand the LBAM program to most of California, which is represented by the grey area.