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Evaluation of Environmental Assessment Submitted by the WSDA |
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Evaluation of Environmental Assessment Submitted by the WSDA |
April 17, 2000
TO: Director, Washington State Department of Agriculture
FROM: Percy M. Washington, Ph.D.
SUBJECT: DRAFT RESPONSE TO: ENVIRONMENTAL ASSESSMENT COOPERATIVE
GYPSY MOTH ERADICATION PROJECT SNOHOMISH AND KING COUNTIES, WASHINGTON
SUBMITTED: 17MAR2000
Dear Sir:
In the following paragraphs please find my comments in reference to the
subject Draft Environmental Assessment (DEA). To keep my comments in
context, I have used the outline and appropriate text from your DEA.
In general, the response to your DEA is negative, because I am impressed that the process used has essentially avoided public input, develops conclusions without adhering to any known scientific methodology, and ignores the political realities of trying to steam roller a politically aware and active community.
At some point in the future it may be necessary to broach the subject of aircraft spraying bacterial agents on dense urban populations to control insects. In a democratic society, I think you'll agree it is important the proponents of such actions gain the concurrence of community to be affected. The USDA did not get input from the Ballard and Magnolia communities regarding their FEIS. WSDA should not use it as the basis for this project.
I suggest you consider an additional year of monitoring, mobilization of the community to search out and destroy any nests, a public process that fits the needs of urban citizens, and a new control program and process that incorporates citizen input. All of these will achieve the desired insect control and citizen response.
Thank you for your consideration.
Decisions to be Made and Scope of Analysis
Introduction
The Washington State Dept of Agriculture (WSDA), in cooperation with the U.S. Dept. Of Agriculture is proposing an eradication program with the goal of eliminating isolated infestations of the non-native Gypsy Moth, Lymantria dispar (Linnaeus), in Snohomish and King Counties, Washington in the spring of 2000.
Environmental Analysis and Documentation
In 1995, USDA Forest Service and APHIS (Animal, and Plant Health Inspection Service) prepared a final environmental impact statement, Gypsy Moth Management in the United States: a cooperative approach, that described and analyzed methods of control available for use in USDA cooperative programs.
It is asserted that nothing new is being proposed, therefore no new environmental impact statement programmatic analysis is necessary.
Comment: Programmatic planning and methods were designed for rural areas and urban citizens were never involved in the EIS process. Perhaps, better late than never? Now may be a good a time to incorporate a public discussion of the issues and to involve the communities to be affected in this ill-advised project. That this project is characterized as required by NEPA makes an opportunity for public input that much more important. Apparently our elected representatives did not represent our will, and clearly our Local and State Bureaucrats feel the strong community anti-spray attitudes are of Non-significance.
History and Scope of Project
The USDA and WSDA assert that the Asian Gypsy Moth was first found in the Northwest (Oregon, Washington and British Columbia) in 1991. WSDA asserts that eradication projects have been successful in treating introductions to date.
Comment: Assertions of programmatic successes bring into question the wisdom and need for using broad spectrum bacterial warfare that will kill not only an introduced species that has to date been controllable, but also will kill beneficial species required to keep our environment functional. This is typical of the USDA past programs to control spruce budworms with DDT. The environmental threats expressed by project proponents are no less overstated and will result in the same level of over kill. (Defoliated plants will not die.) In this case, the response of spraying from aircraft is in a high (human) density urban area as opposed to an Alaska forest. Instead of finding out some years later about impacting Eagle reproduction, the community must deal with dynamic chronic and toxic impacts among insect, bird, and even human populations that could be avoided by a better process.
Decisions to be Made
The first decision to be made is whether or not to have a Gypsy Moth control project (no action alternative). The second decision is whether or not tying this environmental assessment to the USDA 1995 FEIS is appropriate. The third decision is whether to proceed with the preferred alternative as described in the FEIS.
Proposed Action
Strategies described in the FEIS depend upon the infestation status of the area: generally infested, transition or uninfested. The three strategies of suppression eradication, and slow the spread ( or their absence ) make up the six alternatives described in the FEIS. The sixth alternative is the preferred alternative presented in the FEIS. The Sixth alternative is comprised of all three strategies. The strategy utilized is determined by infestation status. Because of Washington State's infestation status, the strategy implemented will be eradication.
Comment: Assumedly, the determination of infestation status was a scientific determination and not based on politics, economics and/or extraneous inputs having little to do with facts, public health and safety, environmental health and safety, and public opinion. This so, perhaps the agencies involved should share the process, data, methods and materials with an interested and involved citizenry. As an environmental scientist, I have difficulty with the premise of how one male moth captured in Ballard constitutes an infestation. As an ecologist and applied mathematician schooled and experienced in population dynamics, statistics, and experimental design, I must protest that your staff refuses to share information on methods, materials and assumptions that would allow intelligent decisions. Your assumptions, experimental methods, and data may not support your conclusions. Even using non-parametric methods your conclusions do not track. The long term environmental and human related impacts of your decision to characterize your non-science based determination of infestation must be viewed in terms of:
Need for Action
Economic, Social, and Ecological Impacts
The stated reasons for taking action are...to avoid undesirable economic, social, and ecological impacts to individuals, communities, and business in Washington State... WSDA in cooperation with USDA is proposing to eradicate isolated infestations of the Gypsy Moth in...Ballard and Magnolia.
Comment: The several paragraphs used to rationalize draconian WSDA decisions and actions do injustice to the intelligence of the residents of Ballard, Magnolia and surrounding communities that will be affected. Not only has WSDA over stated the severity of the alleged moth population size problem, we are now to trust that your vast experience with this pest conveys the ability to assess damages in advance. As an Ecologist, I am fully aware of the ability of insect larvae to denude trees. I am also aware that in general the trees recover. Your assertion of damage and death is not only over statement, but a term like falsehood could well apply.
The local environment has had to adjust to unbridled logging/vegetation removals. Most rainfall in the region occurs during the late fall, winter, and early spring period. The limited amount of precipitation during the period of an alleged bug infestation will hardly be as damaging as the impacts of logging.
The areas selected for spraying represent high density/multiple occupancy dwelling neighborhoods, commercial, and industrial zoning with minimal vegetation and maximal hardened surface. Erosion and tree loss are hardly the problem. Rapid runoff into local waters will occur normally, but will, after spraying, include 60-90 % of your active organisms and inert substances. The percent spray reaching the vegetation in the proposed spray zone will of course be governed by wind direction and velocity. Giving your methods the benefit of the doubt, and canopy cover in the spray zone is 10%, please account for the other 90%. Add to the equation wind drift for 7 to 12 miles probably to the north or south dependent on direction and velocity and you've got a mess.
This is an urban environment that voters are intent on making livable. You mention human health effects as though you knew something of the impacts on the young and elderly. Ballard has extremely high percentages of both. Both are known to be intolerant of contact with the proposed spray developing severe to dangerous symptoms including skin, eye, and lung disorders. Studies of human impacts that only speak to the impacts of contact with moths are hardly meaningful when no one is likely to encounter one. It is certain, however, that public health clinics, hospitals and other health providers will have increased visits as a direct or indirect result of your efforts.
Project Goals and Objectives
Authorizing Laws and/or Policies
State Authorizing Laws
Federal Authorizing Laws
Environmental Laws and Other Regulations
Public Involvement and Issues
Public Notification and Involvement
Comment: While you have obviously adhered to the letter of the law regarding public involvement, in fact you have avoided dealing with any real kind of public involvement, notification or input for this project and the myriad issues spawned. The public deserves better. Your process may stand the legal light of day but what of public opinion?
2000 Site Descriptions
Threatened, Endangered, and Sensitive Species
Other Environmental Consultations
Comment: Where's the moth!!? There remain far too many unresolved issues. Perhaps a political solution is necessary. Certainly you've come to the right community.
Treatment Alternatives
Preferred Treatment Alternative
Treatment alternatives Not Selected
Comment: Since the community had no input into the FEIS, it is necessary to develop more public input and other alternatives that will provide you with the protections you feel you need and the protections the environment and public demand. Nothing less is acceptable.
Human Health and Safety
Non-Target Organisms
Comment: Please involve the community in the resolution before it is too late.
Comment: At least one more year of monitoring should be done before any decision is made. The most draconian solution is the one you've decided on and is one that should never be used in urban settings and perhaps its use should be questioned in any setting.
Comment: Your simplistic and inappropriate solution to this issue is not in keeping with current understanding and thinking. Your agency's environmental management by fiat exhibits a gross lack of concern for the environment you are to protect.
The Washington State Dept of Agriculture (WSDA), in cooperation with the U.S. Dept. Of Agriculture is proposing an eradication program with the goal of eliminating isolated infestations of the non-native Gypsy Moth, Lymantria dispar (Linnaeus), in Snohomish and King Counties, Washington in the spring of 2000.
Environmental Analysis and Documentation
In 1995, USDA Forest Service and APHIS (Animal, and Plant Health Inspection Service) prepared a final environmental impact statement, Gypsy Moth Management in the United States: a cooperative approach, that described and analyzed methods of control available for use in USDA cooperative programs. It is asserted that nothing new is being proposed, therefore no new environmental impact statement programmatic analysis is necessary.
The USDA and WSDA assert that the Asian Gypsy Moth was first found in the Northwest (Oregon, Washington and British Columbia) in 1991. WSDA asserts that eradication projects have been successful in treating introductions to date.
Decisions to be Made
The first decision to be made is whether or not to have a Gypsy Moth control project (no action alternative). The second decision is whether or not tying this environmental assessment to the USDA 1995 FEIS is appropriate. The third decision is whether to proceed with the preferred alternative as described in the FEIS.
Strategies described in the FEIS depend upon the infestation status of the area: generally infested, transition or uninfested. The three strategies of suppression eradication, and slow the spread (or their absence) make up the six alternatives described in the FEIS. The sixth alternative is the preferred alternative presented in the FEIS. The Sixth alternative is comprised of all three strategies. The strategy utilized is determined by infestation status. Because of Washington State's infestation status, the strategy implemented will be eradication. The stated reasons for taking action are...to avoid undesirable economic, social, and ecological impacts to individuals, communities, and business in Washington State...WSDA in cooperation with USDA is proposing to eradicate isolated infestations of the Gypsy Moth in...Ballard and Magnolia.
This is sloppy work in the woods and on the farm. and your work is not considered helpful or desirable. You have failed to present even one good reason why people at risk should be allowed to be sprayed with germ warfare by their government when the issue of the numbers of introduced moths is in question.
Authorizing Laws and/or Policies
Comment: You have hidden behind these rules made by other bureaucrats of limited vision like yourselves. As the authorities making these decisions, the harm you are planning cannot be shifted. My faith in government is shaken. This is the worst example of misuse of trust. As a scientist and an environmental professional, I am ashamed of the way your agencies have misused the term science. I hope I can help to undo some of the damage you propose to do by volunteering my services to stop you or help prosecute you when the extent of your misdeeds become evident.
Public Notification and Involvement
2000 Site Descriptions
Threatened, Endangered, and Sensitive Species
Other Environmental Consultations
Treatment Alternatives
Preferred Treatment Alternative
Treatment alternatives Not Selected
USDA and WSDA have unerringly moved toward the most environmentally intrusive and harmful solutions possible.
Human Health and Safety
Non-Target Organisms
WSDA, Again, you have managed to obfuscate issues, fumble the point,
and remain blinded to your culpability in damaging the environment and
public health.USDA and WSDA please employ someone with at least a
masters degree in ecology. Lack of knowledge, while not
uncommon, exposes vast ignorance and LIST OF AGENCIES AND PERSONS
CONSULTED.