No Spray Zone Presentation, April 18, 2000 Forum in Ballard

Introduction
First let me say that, although I represent a group of people called No Spray Zone, we are not a formal group. We are just a few people who have day jobs who are concerned that we will be unneccessarily be sprayed with pesticides. So in effect I, and maybe Laurie Valeriano from Washington Toxics Coalition here, are the voice of the people in this forum.
There is a long history of discounting as "emotional" or as "anxiety" people's valid concerns about their health and safety. I hope that I don't hear any tired arguments tonight that a fact or observation is less valid because it came from an "emotional" person. One of the problems with learning about the issues surrounding the aerial spraying of Foray48B and BTk and Asian Gypsy Moths is that there isn't all that much information available. Period. So these experts here really don't have any more raw material to work with than I and a few other people have had. The issues, though, are very clear.
No Infestation
One male moth was found. There is no scientifically determined rule or protocol that exists that says one Asian gypsy moth is an infestation. I challenge anyone to dispute that. We do not have an infestation in Ballard.
The Federal Environmental Impact Statement that covers all BTk aerial spraying states that "tourist attractions are known sites for accidental introductions." It is quite likely that 48 hours before it died, the newly-hatched Asian gypsy moth was resting on a handkerchief drying on a clothesline in Kyoto. It suddenly found itself in a coat pocket. The Japanese tourist visited the Locks, pulled out the handkerchief, the moth flew out and was trapped. This is, according to the USDA, a likely scenario.
We have heard about the devastation caused by the European variety of gypsy moth, and how the Asian critters will eat all our trees in Ballard and then proceed onward to devour our Doug Fir forests. But nowhere has any population of Asian gypsy moths established themselves in North America. There is not a lot of evidence to suggest this could happen. Let me explain that, accord- ing to WSDA entomologists, the first Asian gypsy moths appeared in our state in 1991. It's a little odd that this event occurred soon after the development of methods to tell the difference between adult male Asian gypsy moths and European gypsy moths (the traps only catch males). Are we to believe that no moths came in before 1991?; that is to say that no vessels and no containers from Korea, Japan, and Russia were processed here prior to that date? Or is it that no one ever looked for Asian gypsy moths here before? There were no pheromone traps before the mid 1970's. There is evidence as early as 1913 that gypsy moths from Japan were being accidently released in Vancouver, BC, yet they did not establish themselves.
No one has presented any evidence about devastation in Siberian forests from Asian gypsy moths. This is because natural predators keep the population in check. WSDA has said there are no known natural predators here. That is partly true. It's because they they haven't looked for any. But there must be some reason why an Asian gypsy moth infestation has not happened here, because no one was spraying before 1991, and as I have said, they almost certainly have been coming in.
This leads to a question - why is it more efficient to spray cities full of people with arguably toxic substances rather than spending a little more time checking the boats and containers as they come in?
Medical Issues
Now that I have made the case that there is no reason to spray, what does WSDA want to spray us with? It's a pesticide called Foray48B, which contains active and inert ingredients. Foray48B has never been tested for carcinogencity, mutagenicity, or in general for anything relating to safety at all other than noting that if you put it on rabbits it irritates their eyes and skin. It is not licensed for use on food crops.
Foray48B contains an active ingredient called BTk, a bacteria that is not found in nature (unlike the one called just BT) but has been selectively bred in the lab to have hundreds of times the insect-killing activity of its natural cousin. Foray48B also contains inert ingredients that might or might not be safe, except that we can't know that because we can't actually see the list of ingredients. We could have seen the ingredients if WSDA had asked the federal EPA to get them released from the manufacturer, but they didn't think we would care about what was sprayed on us. And by the way, there have been a number of anecdotal reports about past aerial sprayings of BTk fomulations in King County that describe damage to automobile finishes. This leads me to suspect that other, more toxic, agents could be mixed with Foray48B to make it stick longer to foliage.
One does not have to be a doctor to draw the following conclusions from the few available studies done on BTk and Foray48B:

BTk is almost identical and is sometimes mistaken in clinical laboratories for Bacillus cereus, a pathogenic organism that causes food poisoning and meningitis in humans.
BTk and Foray48B causes skin, eye, and lung tissue irritation, and in high enough concentration rats die from inhaling it or having it injected.
BTk and Foray48B sprayings aggravate asthma and can cause allergy-like symptoms, and may affect people more severely who have weakened immune systems - sick people, the elderly, young children.
A few people have had more severe reactions, developing fevers, rashes, or in a couple of cases, life-threatening infections.
No one knows what the symptoms (or the etiology) of a BTk infection are, since very few people have been tested for BTk when they get sick. The state DOH has even stated this. They also have said that "there is a particular need for developing the capacity to identify whether there are individuals with sensitivity reactions to the inert materials in the formulation." (I guess one way to do that is to spray everyone and see who gets sick.) People outside the spray zones who get ill are often discounted as having a disease not caused by the spray - even though we know significant amounts of BTk drift for miles from the target area.
Since no one knows what diseases BTk could cause, how do we know that twenty or thirty years from now, if some people in Seattle develop, say, lupus or cancer or some other disease at a higher rate than the general population, that it wasn't caused by exposures to BTk? No research has been done on this. But researchers are worried enough about this to write, in the conclusion of a study used by the state DOH to promote the safety of BTk, that caution should be exercised when releasing any Bacillus organism on such a wide scale in the environment, because it's not possible to predict exactly what will happen.

The physicians and entomologists from the DOH and WSDA will assure us that none of these health effects are of great concern , and that BTk and Foray48B are safe. Unfortunately, there is no hard data to really support that. That is their interpretation of the data. Let us recall how, until the mid 1970's, the predecessors of these same officials assured us that DDT was a completely safe substance - and that it took Rachel Carson to sound the alarm that something was terribly wrong. Let us remember that 9 years ago our soldiers were given an anthrax vaccine they were told was very safe - and only now is Gulf War Syndrome being connected with that "safe" vaccine. The list goes on and on.
Environmental Issues
One of the most serious aspects of aerial spraying with BTk is that it also depresses or wipes out other insects. In the spray zone and immediately around it, we can expect that 90% of all butterflies and moths will be killed. This effect may last more than one year. Beneficial insects such as ladybugs (that eat 5000 aphids apiece), predator wasps and syrphids, which eat other insects, and earthworms will all be affected. Bird populations will decrease because insect food sources will be absent. Bee lifetimes will be forshortened. And most tellingly, the natural predators of Asian gypsy moths will also be hurt. This is a well known phenomenon - studies have demonstrated over the years, back east, that spraying insecticides that affect the predators actually lengthens the time to stabilize gypsy moth populations.
Finally, by repeated applications of BTk where it is not really needed, WSDA will be contributing to a crisis, in that Asian gypsy moths will eventually become resistant to BTk. This has already happened in the wild with eleven known species of insects. Once resistance happens, if we ever did have a real outbreak, the only sprays that would work would be extremely toxic substances like diflurbenzuron, a known mutagen and suspected carcinogen that is not licensed for consumer use.
Alternatives to Spraying
The WSDA dismissed out of hand any alternatives to spraying. Yet, there are alternatives that do work. The federal environmental impact statement says that using large numbers of pheromone traps can be very effective in eradicating - and I use their word - eradicating low-level infestations of gypsy moths. This makes statistical sense - if there are only a few females to mate with a few males, the males are much more likely to encounter a trap first before they find a female. Of course, the WSDA has a problem with statistics, having previously stated that there is a "high non-statistical probability" of an infestation in Ballard, a nonscientific nonsense statement. The cost of such a trapping program would surely not be more than the (at least) $300K figure I've heard for spraying.
WSDA has made arguments that we must spray now because the female moths fly 20 miles each season - maybe you've seen those maps of western Washington the have published with the circles showing the moths almost at Snoqualmie pass in two years. But WSDA does not believe the moths will spread that fast. If they did, they would be spraying Bainbridge to Duval, Lynnwood to Burien. They have stated they assume the moths will not spread hardly at all at first because they will be attracted to the lights in the city. So why the scare tactics? There is no emergency.
A Rogue Agency
A disturbing pattern that has emerged is the way the WSDA is handling the entire issue of spraying. The WSDA decided that something would have to be done about the one moth that was trapped by October 1999, yet they did not notify the public at all until February, leaving little time for public comment. The WSDA was required to prepare an environmental checklist called a SEPA list that detailed why they thought no environmental review of spraying was necessary. They had already submitted this on February 2nd, and it was approved February 11th - yet when citizens called to ask about the list on February 12th, they were told by an official of WSDA who knew better that the list was not ready. It was not publicly available until the 16th of February. So by January, at least, the WSDA had decided they were going to spray and not use alternative methods. This decision was made in a vacuum, with no public notice or comment.
WSDA refused to hold a public hearing on the issue of spraying, and instead used a community council meeting in Ballard to present their show, but not accept any comments. These meetings were not publicized at all - how many heard about them here? - and at these meetings they did not even have any of the proper documents, such as the National Environmental Policy Act checklist, available for the public. They presented spraying as the only option.
There was a comment period open on the spraying proposal, but there was no information in the WSDA documents where comments could be sent to to be reviewed. Want to make a comment? Sorry, the comment period ended today, so it's too late for any of you who haven't commented to do so. As I said, they decided months ago to spray, so comments to the contrary are, I'm sure, being politely filed in a back drawer somewhere.
When I called the WSDA on April 4 to find out what type of spraying equipment they would be using, so I could make an estimate of the spray drift, they said they didn't specify that equipment in their bids to spraying companies, even though the type of sprayers used can greatly affect the drift. They refused to tell me who was going to do the spraying this year - they even refused to tell me who did it last year so that I could at least find out what had been used.
This all adds up to a pattern of secrecy, outright lying, and even breaking the law. It has been so bad NoSprayZone has filed a notice of intent to sue WSDA for violations of several Federal and State statutes. What is WSDA's response to all this? They have asked the governor for an emergency exemption to many of these rules, so that they can simply ignore proper procedures and public input, and do whatever they want. If the governor signs this emergency declaration, he will have abdicated his responsibility to the people of Washington, and shown he does not care enough about the people and the environment to educate himself on this issue.
The WSDA seems to have forgotten who its employer is. It is us, the people of the state. There is no need for secrecy or lying if they have honest intentions.
Conclusion
If I really felt that the one Asian gypsy moth found in Ballard posed an imminent threat to the forests and woodlands of Washington, and that there were no other options but spraying, I might consider taking a risk with Foray48B. The sad truth is, there is no reason we need to be part of a big experiment in public health. I, for one, do not want to wind up as another statistic.

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