Governor Gary Locke
Legislative Building
PO Box 40002
Olympia, Washington 98504-0002

Dear Governor Locke:

After considerable review of the pros and cons of the Washington State Department of Agriculture's proposed gypsy moth spraying program, I am asking that you prohibit the department from proceeding with its plan to spray nearly 750 acres of Ballard and Magnolia in the coming weeks.

Governor Locke, I do not make this request lightly. I certainly believe we must protect the trees and forests of our state and I understand the dangers of a true Asian gypsy moth infestation. However, the Department of Agriculture has failed to prove that there is an infestation. One Asian gypsy moth was found and killed and one egg mass was found on a Russian trawler docked in Ballard in March 1999. The egg mass was subsequently destroyed. Moreover, the moth and egg mass were not genetically linked.

In my opinion, spraying nearly 750 acres of the densely populated communities of Ballard and Magnolia in response to finding one live gypsy moth more than eight months ago is overkill.

There are alternatives to spraying which I believe would be much more prudent to use at this time. The use of Btk, the spray selected by the Department, could boomerang since it can reduce natural predators such as the parasitic wasp. Moreover, as the Washington Toxics Coalition points out, the gypsy moth shows potential for developing resistance to Btk spray.

Although I do not believe the spray will pose a health hazard to most of my constituents in the spray zone, I am particularly concerned for individuals who have severe allergies or asthma, or who are immuno-compromised. For these individuals, the Department of Health has recommended staying indoors for at least 30 minutes after each of the three sprayings. They also recommend "waiting until moisture from the spray and dew has dried on the grass/shrubs before allowing the children to play outside." Governor, in our moist climate that could take quite awhile!

During one Washington spray program in Seattle, over 250 people reported health problems, according to recent information from the Washington Toxics Coalition. Perhaps this was simply caused by the pollen and dust stirred up by the helicopters conducting the spraying. No one really knows the reason for the apparent link between reported health problems and the spraying activity.

Finally, despite my repeated requests the Department of Agriculture has refused to identify the other ingredients in the Btk formulation it has chosen to use. The Department cites state and federal laws which prohibit it from disclosing the formulation of the spray. However, our Office of Program Research staff points out that these laws relate to the Department's regulatory role and not to its role as a purchaser of the spray. I believe that given the heightened public concern about the "secret" ingredients that compose 97% of the spray, the Department should require the manufacturer to release the names of the ingredients as a condition of purchase. This will allow independent, non-state analysis of the potential for public health concerns. Such disclosure would likely result in a lessening of tensions on this matter.

In conclusion, I believe the Department of Agriculture has failed to make a compelling case for spraying almost 750 acres of densely populated areas in Ballard and Magnolia and that you should refuse their request for an emergency order to allow them to spray. If you decide otherwise, I would ask that you require the Department to purchase the spray from a manufacturer willing to release the formulation and that more adequate notification be provided to the residents in the spray zone.

Sincerely,

Mary Lou Dickerson
State Representative