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HomeMy WebLinkAboutMINUTES - 03112008 - D.2 i D.2 THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Adopted this Order on March 11, 2008 by the following vote: AYES: Supervisors Gioia,Uilkema, Piepho, Bonilla and Glover NOES: None ABSENT: None ABSTAIN: None On this day, the Board of Supervisors accepted an informational presentation by the California Department of Food and Agriculture and the United States Department of Agriculture on the light brown apple moth. I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the Board of Supervisors on the date shown. Attested: March 11, 2008 John Cullen, Clerk of the Board of Supervisors and County Administrator By: Lena O' Neal, Deputy Clerk Please see attached addendum. Addendum to D.2 March 11, 2008 On this day the Board considered.accepting an informational presentation by the California Department of Food&Agriculture and the U. S. Department of Agriculture on the light brown apple moth eradication project in the Bay Area. Ed Meyer, Contra Costa Agriculture Commissioner, introduced Mr. A.G. Kawamura, Secretary of Agriculture for the State of California, and Dr. Robert Dowellell.,Director of the Light Brown Apple Moth(LBAM) Eradication Program. Dr Dowellell gave a PowerPoint slide presentation [attached]. He said the apple moth was first found in 2007, and said this moth poses a significant risk to agriculture and the potential for uncontrolled spread and environmental and economic impacts. He said he believes if no action is taken this moth will spread to the point where we would be forced to live with it, as they are forced to live with it in Australia and New Zealand. He said a statewide trapping program has been implemented,but noted there is not a one-size-fits-all approach, and noted that treatments are expected to occur in heavily infested areas in Monterey, Santa Cruz, San Francisco, San Mateo, Alameda, Contra Costa and Marin County. He said expanded outreach efforts would be scheduled before treatment, and the Office of Environmental Health Hazard Assessment Cal EPA . and Department of Public Health are working together to develop procedures to watch the health of citizens in the treatment areas and to educate health care professionals about the program and how to report suspected cases of pesticide poisoning. He added that information is available to the public on the following web sites: www.cdfa.ca.gov and www.aphis.usda.gov. For complete information on the power point presentation please contact the Clerk of the Board's office at 925- 335-1900. Supervisor Gioia asked time frame and areas proposed,to be sprayed. Mr. Dowellell responded the start date for aerial application of pheromone would be over all the heavier infested areas of Monterey and Santa Cruz counties in June 1,2008. He said applications for San Francisco, San Mateo, Alameda and Contra Costa counties would start in August 1, 2008. Supervisor Gioia asked if spraying would start before the Environmental Impact Report is completed, under an exemption to California Environmental Quality Act(CEQA). Mr. Kawamura responded the state has met the emergency terms under CEQA. Supervisor Gioia asked, as added information comes in through the EM process,how the state would decide to make changes. Dr Dowellell said all materials used would be reviewed continuously with California Environmental Protection Agency,United States Climate Partnership Association DPR and once they know what formula of material would be used that information would be given to Department of Public Health and the Office of Environmental Health Hazard Assessment for their review. He said in addition it would be reviewed and environmental assessments produced by the United States Department of Agriculture(USDA). He said should any of these reviews show chance of adverse human health affects the process would be stopped. He explained all this will be done before use of any materials. Supervisor Gioia asked what the risks would be if no pesticide applications are done, and also asked if this would be includcd in the.E1R. 1 Mr. Kawamura noted populations of threatened and endangered plant species could be severely impacted, increased pesticide use could occur later, and the moths could spread to other areas. Dr. Brunners,Director, Public Health, Health Services Department, said the risk of the spray is small but more needs to be known about the chemicals with which it will be mixed. He requested the California Department of Public Health with the Office of Environmental Health Hazard Assessment completea risk assessment Supervisor Gioia asked Dr Dowellell and Dr.Bremner the process needed for a risk assessment to be done soon. Dr. Brunner said if the Board recommends a letter could be prepared to the California Department of Public Health and the Office of the Environmental Health Hazard Assessment. Mr. Kawamura said state found that pheromones are extremely safe. Dr Dowellell said once they pick the exact mix of chemicals to be blended with the pheromones, public health and environmental safety agencies would review its safety. He stated this would be done before using the aerial application. Chair Glover said this.information would help the Board as well as the.constituents. Chair Glover asked the public for their testimony and the following people spoke: ■ Don McQueston, El Sobrante' resident, told the Board he has a son and said his biggest concern is for kids with respiratory disease. He said the spraying is a direct threat to kids and handed the Board a clipping on Stewart Resnick, CEO of Roll International, ■ Carmen Breen, Crockett resident, expressed her concerns about health issues for her grandchildren and said big corporations are concerned'about money; ■ Angelina Breen, Crockett resident, told Board that citizens' right to breathe has been taken away and said she was no ok with that. She told the Board until the state gives them their right to vote on the matter the aerial.spraying should not take place; ■ Dr. Lisa Tracy, Oakland resident with two children in San Pablo schools, called the spraying plan a dangerous human experiment; ■ Laurey Foulkes,El Cerrito resident, said she agrees with the other speakers and has the exact concerns; ■ Mike Vukelvich, El Sobrante resident, said fears about spraying pheromones were vastly overblown. He suggested that pheromones would not hurt anything; ■ Kathy Kramer, San Pablo resident, an expert in native'plants, said she was appalled by the spraying plan because of the potential risk to children and adults. She noted that some scientists have suggested that California can live with.the moth if efforts are made to suppress its numbers. She provided the Board with.a Declaration of Richard Phillip in support of ex parte application for temporary restraining order against Department of Food and Agriculture: A.G. Kawamura, in his capacity as Secretary of the CDFA., a Resolution No.NS-27, 783 dated February 12, 2008 opposing the aerial spray program to eradicate the LBAM; County of Santa Cruz,'California; ■ Susan JunFish,Moraga resident,.provided the Board with an abstract from Dr. Daniel Harder, Director,University of California, Santa Cruz Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary Biology at UC Santa Cruz, who did a study in New Zealand where the moth was introduced:; ■ Bethallyn Black, Pleasant Hill resident, told the Board she is a gardener and expressed her concern; ■ Lori Anders, Moraga resident, said she echoes the concerns of other speakers and asked the Board to take more time before the spraying is done; ■ Judy Adler,Walnut Creek resident, said she is a gardener and an environmental educator and said she supports the efforts to discourage pesticide use by individual home owners; ■ Ken Freeze,Martinez resident, said he is concerned that if the spraying not take place,the ramification could be a lot more pesticide sprayed into the environment.later. He said from what he has read this is a safe way to eradicate the LBAM; The following individuals presented their concerns in writing: ■ Rita Gaber, El Cerrito resident;presented a speaker card but did not speak; • . Nan Wishner,Albany resident, expressed her dissatisfaction regarding the aerial spraying of pheromones; • Mayor Robert Lieber, RN, Albany resident wrote to the Board opposing spraying of pheromones; and • Residents of Richmond: Michael S. Esposito, Carolyn Graves, Stephen Linsley,Andrew Mayes, Sherry B:Padgett, Joseph Robinson and.lean Rabovsky requested the Board for a moratorium on Spraying with Checkmate LBAM-F until its health effects have been completely assessed. Supervisor Gioia said the community has raised legitimate issues about the proposed spraying, as there could be potential for health effects if nothing is done. He stressed the County is looking for the best plan that balances public health with the goal of eradicating the apple moth. He made a motion to requested the Chair to.write a letter to the state to request there be a broader health risk analysis done quickly and thoroughly and suggested the Health Services Department follow up and work with the state before the spraying begins. He suggested quantifying the risk in a clear manner to give the public more comfort. He stressed it would be useful to get that out before the spraying begins. Supervisor Piepho voiced her concern over the eradication efforts being safe and necessary.and said she respects the state's responsibilities and authority on this issue,but stressed the County's primary responsibility is to the citizens and local communities. Supervisor Bonilla included in the motion that the Board draft letters to Senator Dianne Feinstein and Senator Barbara Borer requesting to tighten borders so as not to allow pests to enter into the state. Supervisor Gioia agreed to.include Supervisor Bonilla's suggestion in the main motion. By an unanimous vote,.with none absent, the Board of Supervisors took the following action: 3 • ACCEPTED informational presentation by the.California Department of Food and Agriculture and the United States Department of Agriculture on the light brown apple moth; • REQUESTED state regulators assess the safety of the material before spraying this summer in parts of western Contra Costa and Alameda counties; and • REQUESTED the Chair to write a letter to the state to.request there be,a broader health risk analysis done quickly and thoroughly,before any spraying is done; DIRECTED the Health Services Department to follow up with the state on this matter; and REQUESTED staff to send letters to Senator Dianne Feinstein and Senator Barbara Boxer with a request to tighten borders not to allow pests to enter into the state. 4 ?moo 2008 — 2009 Light Brown Apple Moth Action Plan ODt This action plan has been developed by the California Department of Food and Agriculture (Department) and the United States Department of Agriculture (USDA) in consultation with representatives of the Light Brown Apple Moth Technical Working Group. This action plan is a guide to the major elements and strategies of the eradication program. Specific program actions will be modified based on the Circumstances of new local infestations and operational constraints. The following treatment plan will be implemented by the Department and the USDA in cooperation with the county agricultural commissioners., These actions will apply to all infested counties within California. . 1. Eradication strategy: Overall strategy: Eradication is the goal. 1.1. Eradication of the light brown apple moth (LBAM) populations will likely take several years to accomplish using several treatment tools. Some of the tools that may be used are currently under development. 1.2. Eradication of LBAM will require an integrated systems approach using Multiple tools, including applications of pheromone for mating disruption, use of insecticide treatments, male moth attractant treatment technology (ground treatment), and implementation of biological control and releases of sterile insects (if needed and when available). ° 1.3. The primary tool for eradication will be.the aerial application of pheromone for mating disruption. 1.4. Decisions regarding eradication activities will.be based on the geographic size and population densities as follows: .1.4.1. Treating the outlier infestations; 1.4.2. . Treating the small and isolated infestations; and, 1.4.3. Treating the heaviest populations beginning with Monterey and Santa Cruz counties, then moving to the San Francisco Bay Area. 1.5. The Department will consult with the California Department of Pesticide Regulation (DPR) concerning pesticide use in the LBAM eradication program. 1.6. Buffer areas will continue to be used to protect any threatened or endangered species or other environmentally sensitive areas. 2. Ground treatments: A focused ground treatment component for small and isolated areas (1.5 miles from another infested area) as described below will be used as a stand alone treatment and/or to complement mating disruption treatments against the heaviest populations. 2.1. Pheromone twist tie placement for mating disruption: 2.1.1. Anticipated start date for twist ties is February 25, 2008. 2.1.2. Areas designated for twist tie placement: - Posted 2;15/2008 Light Brown Apple Moth 2008-09 Action Plan . February 15, 2008 isolated sites; • areas that are further than 1.5 miles from a generally infested area; and, • areas with low level populations. 2.1.3. Twist ties are placed at the rate of 250 twist ties per acre in a 200 meter radius around each infested site. 2.1.4. Twist ties remain in place for two life cycles and are replaced every three to six months as needed to maintain pheromone at disruption levels. 2.1.5. Trap density for small isolated outlier sites will be 100 traps in the core and 25 traps per square mile in the surrounding eight square miles. 2.1.6.. After two life cycles without any LBAM detections, the twist ties are removed. Delimitation traps will remain in place for one additional life cycle. If no additional LBAM are detected, this area will be declared free from LBAM and trapping levels will return to detection levels. 2.2. Pheromone male moth attractant treatment: 2.2.1. Anticipated start date is spring 2008, targeting the following areas: Areas that cannot be treated aerially (such as proximity to environmentally sensitive areas, buffer zones); Contiguous areas with a low level of LBAM detections; Contiguous areas with heavy populations (more than 50 LBAM detections) conducted in advance of the aerial mating disruption to enhance the efficacy of the aerial mating disruption pheromone applications. 2.2.2. The treatment area consists of a 1.5 mile radius around any detection site. 2.2.3. Treatments may occur on trees and utility poles on public and private property. Male attractant treatment sites will be out of reach of the general public. 2.2.4. Treatments will occur at 30 to 60 day intervals. 2.2.5. Treatments will be applied at a minimum rate of 3,000 male' attractant treatment sites per square mile. 2.2.6. Trap density will be nine traps per square mile throughout the treatment area. 2.2.7. After two life cycles of treatment without any LBAM detections, treatments will cease. Delimitation traps will be deployed and they will remain in place for one additional life cycle. If no additional LBAM are detected, this area will be declared free from LBAM and trapping levels will return to detection levels. - 2 - Posted 2;15;2&08 Light Brown Apple Moth 2008-09 Action Plan February 15, 2008 2:3. Inundative Trichogramma species stingless parasite wasp releases: 2.3.1. Anticipated start date is spring 2008. 2.3.2. These releases may be made in advance of aerial mating disruption pheromone applications"in'the following areas (more than 50 LBAM detections): • Santa Cruz County (Santa Cruz, Soquel); • San Francisco County (Golden Gate Park); Monterey County (Carmel, Seaside/Marina). 2.3.3. Estimated number to be released is 1,000,000 per square mile (based on previous history with these or other species). 2.4. Foliar ground treatments with Spinosad or Bacillus thuringiensis kurstaki may be made where heavier larval populations are detected. 3. Aerial Applications: Aerial applications of pheromone for mating disruption will be used to treat denser populations (2008 LBAM Plan PDF Map). 3.1. New formulations of the mating disruption pheromone are now available. These formulations will be tested to determine which formulation is the most efficacious at eradicating LBAM. The California Office of , Environmental Health Hazards Assessment (OEHHA) will evaluate the anticipated human health impacts of the formulation used over urban areas and transmit these to physicians in the treatment areas. Thearea for aerial applications is a 1.5 mile radius around each location where a LBAM is detected. Application areas maybe adjusted to include LBAM detections in proximity to the 1.5 mile radius and to provide the public with identifiable treatment boundaries. 3.2. Anticipated start date for aerial application of pheromone for mating disruption over all of the heavier infested areas of Monterey and Santa Cruz Counties including: Aptos, Aromas, Ben Lomond, Boulder Creek, Castroville, Corralitos, Del Rey Oaks, Felton, Freedom, Live Oak, Los Lomas, Marina, Monterey, Pacific Grove, Pajaro, Pebble Beach, Prunedale, Rio Del Mar, Salinas, Santa Cruz, Soquel, Scotts Valley, Seaside and Watsonville (currently 282,699 acres) is June 1, 2008; with a 30 to 90 day spray interval, depending on the formulation used, and will continue through the reproductive flight periods of the LBAM (approximately nine months) as pheromone is available. 3.3. Applications targeting the following areas (currently not prioritized) are anticipated to begin starting about August 1, 2008: • San Francisco County (54,610 acres); - 3 - ,. ; ,..Ol:ir'ti 2;'15.20'18 Light Brown Apple Moth 2008-09 Action Plan February.15, 2008 San Mateo County areas including: Broadmoor, Brisbane, Colma, Daly City, Pacifica, San Bruno, and South San Francisco (included San Francisco County acreage above); Alameda County areas including: Alameda, Albany, Berkeley, Emeryville, Oakland, and Piedmont (90,430 acres); Contra Costa County areas including: EI Cerrito, EI Sobrante, Hercules, Kensington, Pinole, Richmond, and San Pablo (included in Alameda County acreage above); and, Marin County areas including: Belvedere, Corte Madera, Larkspur, Sausalito, and Tiburon (16,420 acres). 3.4. After two life cycles of mating disruption applications without any LBAM detections, these applications will cease. Once the pheromone has dropped to levels that will not interfere with trap efficacy, post-treatment monitoring traps will remain in place for one additional life cycle. If no additional LBAM are detected, this area will be declared free from LBAM and trapping levels will return to detection levels. 4. Trapping Actions: The following trapping plan will be implemented by the Department and the USDA. The county agricultural commissioners will be informed of trapping actions in their respective counties. 4.1. Extension of detection trapping at a density of five traps per square mile into previously untrapped areas inside the regulated counties, such as rural and industrial areas, will be implemented as needed. 4.2. Delimitation trapping arrays will be put in place where LBAM has been detected for those sites that are three miles from other detection sites at 100 traps per square mile in the core square mile and 25 traps per square mile in the adjacent eight square miles. 4.3. An additional detection within any delimitation area and within three miles and one life cycle will trigger an eradication project. 4.4. Traps in eradication areas will be stationary, placed at nine traps per square mile, inspected weekly, and baited with 100 microgram lure., 4.5. Mass trapping will be discontinued per the recommendation of the technical working group. 5. Environmental Monitoring: Aerial pheromone applications will be monitored for quality control. The program will consult with DPR. 6. Environmental Consultations: - 4 Pos a 2�1 ,200<5 Light Brown Apple Moth 2008-09 Action Plan February 15, 2008 6.1. The program will provide OEHHA with information concerning the pesticides to be used in the eradication of LBAM for their.use in any public outreach activities, educating physicians, and tracking/evaluating illness complaints in the eradication areas. 6.3. The program will consult with any other appropriate governmental agencies concerning threatened and endangered species and sensitive environmental sites and it will obtain all of the required permits. 7. Public Health Concerns: .7.1 Prior to treatments; OEHHA will work with local health officers to ensure that physicians and other health care providers are provided with information on the application; what, if any, symptoms are likely to be seen; reporting requirements; and direction on other concerns. In general, the physicians and health care providers will be informed of the illness reporting requirements and will receive training on pesticide poisoning recognition and management. 7.2 OEHHA will team with other public health organizations to develop and oversee a program for the reporting, tracking and scientific evaluation of reported illness incidents. 8. Regulatory Activities: All federal 'and state quarantine orders and regulations will remain in place for the duration of this program. 9. Communications: 9.1. The program, county agricultural commissioners and, as appropriate, OEHHA, will conduct outreach to elected officials and other interested parties prior to the start of treatment activities. 9.2. Informational open houses and/or public meetings will be held in each county where eradication activities occur, as needed. Residents whose property will be treated will receive written notification prior to treatment. 9.3. Residents may sign up for an e-mail notification for updates on the treatment schedules and areas scheduled to be treated or call an informational phone line to have questions answered. 9.4. The Department's website will be updated with any pertinent information following each male moth attractant treatment and aerial mating disruption application. 9.5. Additional project information will be available on the website. Press releases will be issued for new events. - 5 - E .:m"'......�' .. .................. .� .. C CALIFORNIA DEPARTMENT OF a � FOOD & `AGRICULTURE :i........^': 2008 Light Brown Apple Moth (LBAM) Program Questions and Answers What are you doing differently than you were doing last time? And why? With the advent of new tools, the California Department of Food and Agriculture (CDFA) and the United State Department of Agriculture (USDA) have developed treatment programs for three categories of infestations and are ready to move forward and treat: 1. Physically small, isolated infestations with a few moths trapped, 2. Physically larger infestations with several contiguous square miles infested and more moths trapped, and 3. The physically largest infestations covering many contiguous square miles and the greatest number of moths trapped. This approach allows CDFA/USDA to operationally select a set of tools that will reach all the target LBAM life stages within each treatment area. Are you using the same substance as aerial spraying? The active material is the same—LBAM pheromone. The carrier may be different based on tests being conducted in New Zealand. These products are being evaluated for efficacy, longevity and ease of applications. Why are you changing the treatment material now? Does it mean last time it was not effective? There are three additional pheromone formulated products now available that were not available last year. CDFA/USDA are evaluating them, along with last year's formulation, to determine which is the best carrier to lengthen the interval between treatments. The active material in the aerial treatment is the same LBAM pheromone used in 2007. So is the new aerial product an insecticide/pesticide? The new product will be a pesticide,but like last time, it does not kill the moth. The products under consideration for aerial treatment contain the same pheromone but use different bio-degradable carriers. :Because the use of this product is intended to eliminate a population, the United States Environmental Protection Agency requires the product to be registered as a pesticide, however technically the product will not kill the LBAM. In contrast, CDFA/USDA uses the same product as hires in the traps, but because the intended use is to attract the rnoth to the trap, it does not, under these circumstances, need to be fegistered as a pesticide. l Posted 1/25/2008 Should the public be.concerned about their health and.safety? Public safety is our primary.concern. Pheromones are cxtremcly safe and if persons believe they have experienced sickness as a result of the pending treatments, they are advised to see their doctor. State agencies (DPR, OE.HHA) with.jurisdiction for public health produced a Consensus Statement that evaluated the complaints and found "it is likely that exposure occurred at levels below those that would be expected to result in health effects." All the research shows the moth pheromone is non-toxic tb plants, animals and insects. It doesn't even hurt the moth. Any new products must meet rigorous standards for public A health and safety. The pheromone materials CDFA/USDuse have been'registered and approved for aerial treatment by the federal Environmental Protection Agency (EPA) and the state Department ole Pesticide Regulation (DPR). Before registration, all.product uses must pass a rigorous safety review to protect human health, wildlife, and the environment. This pheromone and many others like it are present in our environment every day as many insects use them to attract mating partners or signal other behaviors. Humans and other mammals do not use these insect pheromones and cannot detect them. Does this new program pose any risks? Public safety is the primary concern. Any new products must meet the same rigorous standards for public health and safety as the old product did. White paper consensus statement on human health aspects of the aerial application of pheromones to combat'the LRAM (Oct. 31, 2007, DPR/OEI-II-IA/DPI I): "While the toxicological information on the Checlanate product indicates that exposure to high levels of the applied material would be consistent with many of the reported symptoms,the application rate was extremely low, and .it is likely that exposure occurred at levels below those that would be expected to result in health effects." There were reports of illness even when you were using the "benign" program, What about now`' All health complaints are reviewed and monitored by the appropriate agencies to determine if there is a'risk to public health. If a resident believes they are ill, they should see their health care provider. What do you plan.to'do differently to communicate to the general public regarding health concerns, pets, property, etc? We will focus our efforts to provide the public with the in'forrnation needed to understand this program clearly, including open communication with public officials, the media and individual Californians through meetings, mailings, hotlines, the CDFA web site and other means. 2 Posted 112512008 Is it important enough to take funding away from other state programs when our state is already strapped, for example, education? No different than previous years, the program must compete for funding. Why don't you use ground application all the time? Given the size of the treatment area, ground application is not logistically feasible in terms of biological effectiveness in all situations. Ground application will be used in situations where CDFA/USDA can get the material to the targeted moth life stage. This is not possible in the heaviest and physically largest infestations where only aerial treatments of the pheromone will be biologically effective. People obviously don't want this program, why do you continue to push it when we don't see any of the negative effects? One would not expect to see negative effects in the early stages of a new pest introduction. The bottom line is that the establishment of LBAM threatens the life systems of California and the United States. The goal of the program is to be proactive and eradicate the problem before it becomes too large to eradicate and extensive damage occurs. Where is the emergency and urgency to this? If the insect is not eradicated while the infestation is still small, CDFA/USDA will be forced to deal with increased pesticide use, plant and environmental damage and potentially, quarantines forever. This insect will become a permanent unwanted resident in California and the rest of the United States. Can we see any visible damage? Damage is hard to find, though some can be detected on foliage in the infested area. CDFA/USDA is being proactive to eradicate the pest before extensive damage occurs. Why are you coming back and spraying again? The first aerial treatments were never expected to eradicate the .l_BAM from the state and eradication of the pest has not been completed. The mating disruption approach will not kill the moth as would be expected if CDFA/USDA would have used heavy pesticides. Since the aerial treatments do not kill the moth, it will take multiple treatments to gradually eradicate the pest. How long will it take to eradicate LRAM? The program will probably take at least 3-5 years. Remember, the program is based on mating disruption using a pheromone. It will take longer to eradicate the moth by this means. A traditional pesticide might have been a quicker approach, but the environmental and public health concerns would have been much greater. 3 Posted 1/25/2008 How do you guarantee accurate application of the products when there have been mishaps before? Public safety is the pririiaiy concern. CDFA/USDA continually monitors'each and every treatment to ensure that all program requirements are met. The airplanes are equipped with a GPS system to'keep treatments on target. CDFA/USDA also deploy an environmental monitoring system to make sure the treatment only occurs during appropriate weather conditions and is effectively deliver within the treatment zone. Why are you looking to New "Zealand to help solve the:problem when it's not eradicated there'. Researchers in New Zealand and Australia have the most expertise with dealing with.the i-noth and they are developing the tools that CDPA/USDA will use here. The moth is native to AListralia'and it invaded New 'Zealand years ago. In both countries the moth is too widespread to eradicate and they now use pesticide sprays to live with it. CDFA/USDA wants to prevent this from happening here. How do twist ties and aerial treatments work? ; The twist ties and aerial pheromone treatments disrupt the communication between the n.�oths, preventing the males from finding females. How does male moth attractant technique work? The male moth attractant technique will be applied at approximate 8 feet high on utility boles and trees in the treatment area. The male moths are attracted to the spot where they crawl over a contact insecticide and perish. How do the siingless wasps work? The stingless Trichogramma wasps look [or and lay their eggs in LBAM eggs. The wasp larvae hatch and cat the LBAM egg from the inside. These wasps will not bother the over-wintering monarch butterflies and they will not be released near threatened or endangered plants or butterflies and n..1.oths. The wasps are among the smallest mernbers of the insect world—smaller than a grain of rice. Trichogranania wasps occur naturally in almost every terrestrial habitat and some aquatic habitats as well. Soine of the most important caterpillar pests of field crops, forests, and fruit and nut trees are attacked by Trichograinnia wasps. Ilowever, m most crop production systems, the number of caterpillar eggs destroyed by native populations of Trichogranrma is not sufficient to prevent the pest from reaching damaging levels.. That is why the wasps mist be used in conjunction with other approaches in order to achieve eradication of LBAM. 4 Posted 1/25/2008 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.refiiges 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. Isn't bird die-off connected to the pheromone treatment? No..The Department of Fish and Game investigated the die-off and stated "It turns out it's not a fish oil or vegetable oil product, as well as not being a petrolewn oil or the light brown tipple moth .Sprgv. " The pheromone products CDFA/USDA uses are of very low toxicity to birds and wild life. We've heard that the increase in "Red 'ride" algae growth in the Monterey Bay is attributed to the pheromone. There is no evidence that the product caused these naturally occurring algal growths. Depailment of Fish and Game stated that "red tide" is a naturally occurring regular event. Do you plan to do water monitoring in 2008? The CDFA Secretary's Environmental Advisory Task Force recommended a pilot water monitoring study which the department will implement. " Why should I/the public care about eradication of the moth? Why can't we just spray agriculture and not urban dwellers? We all live in a life system. if we don't fight the moth now, its population could explode with time resulting'in increased pesticide load, not only in agriculture, but urban areas. CDFA/USDA knows this from past experience with pest infestations and the public's use Of unrestricted insecticides. Further, more insecticide use,later will.result in unhealthy residuals on fruits and vegetables that the consumer ultimately eats. Have moth pheromones been used before? Where? Moth pheromones designed to create mating disruption have been applied aerially in the US for about 10 years against invasive moth infestations fn Florida, Texas, Arizona., Orcgon, Washington, New York, Pennsylvania, Illinois, Wisconsin and Michigan. Moth pheromone has also been applied aerially in South Africa; Argentina, Chile,Italy and Spain. Pheromone treatments in general have an excellent track record against moths and other insect pests. Pheromones are a reliable method of treatinen.t to control LBAM in New Zealand and Australia". LBAM is also present in Hawaii, but treatments have not been Attempted there because of a number of factors, including'the fact that the infestation is relatively small and restricted to higher elevations, and also because crop exports there are highly restricted and regulated due to a number`of other invasive pest infestations. 5 Posted 1/25/2003 Are the planes;treatment equipment and flight plans safe? The contractor Dynamic Aviation, their planes and the individual pilots are required to be reviewed and licensed/approved by the Federal Aviation Administration(FAA). CDFA has contracted with-this company for many years for aerial release of sterile Mediterranean fruit flies in the Los Angeles basin, and their safety record is unblemished. Detailed blight plans are submitted to local aviation authorities for review in advance. To ensure that no contamination of the pheromone product occurs, the mixing, loading and treatment equipment is required to be new and dedicated to this project. We will conduct sampling of the pheromone mixtures and follow a strict chain-of-custody procedure in the delivery of these materials for testing. Strict protocols are also in place for the purchase, transport, storage, mixture and loading of the material to be used in the treatment. Why is this eradication project an emergency? Data from our statewide'insect trapping efforts shows that this infestation is a recent arrival to California. The populations of LBAM are still relatively small and are considered by an international panel of expert scientists to be eradicable if significant action is taken promptly. These moth populations can grow exponentially, going through approximately five generations per year with each female moth laying hundreds of eggs. Failure to act quickly could result in uncontrolled spread and substantial environmental and economic impacts. Who decides whether or not aerial applications are necessary? How is that decision made? At the direction of federal and state law, agricultural officials with the USDA and CDFA are responsible for eradicating invasive pests that threaten agriculture as well as the environment and natural habitat. Agency policy requires that we choose the most environnentally sensitive approach that will be effective against the infestation. For a project such as the eradication of the light brown apple moth, the agency secretaries are the primary decision-makers who rely on the scientific knowledge of staff as well as on consultations with their counterparts in health and enviromnental agencies and other experts. For the LBAM eradication project, CDFA and USDA appointed a technical working group of expert scientists to establish whether eradication is possible and, if so, to recommend the most environmentally friendly means of eradication. Aerial treatments are a central element in that plan. How do you protect against drift? The airplanes use pre-programmed GPS guidance systems to ensure even application of the treatment. The programming includes automatically turning the treatment off over bodies of water. The protocols call for treatment to'occur only if wind and other weather conditions are within established limits. Why is the light brown apple moth considered a threat to the environment? Because the LBAM feeds on hundreds of different kinds of plants, it presents a threat to trees and plants in the natural environment as well as in crops and landscaping. Cypress and redwood trees,Monterey pine, oaks, lupines and many other native species are included on the extensive "host list" for this pest. 6 Posted 1/25/2008 If the infestation is not eradicated, another important environmental effect would likely be an increase in the use of conventional insecticides by many residents, businesses and public entities acting to protect the plants in their gardens, landscaping, parks and other areas. Will the pheromone harm the monarch butterfly? Are other moths affected by the pheromone? Pheromones, as opposed to conventional pesticides, have the distinct advantage of affecting only a very limited number of closely related insects while leaving beneficial insects and endan(Tered species unaffected. Although moths and butterflies are similar insects, the pheromones used by separate species are different. Monarch butterflies are not attracted to the light brown apple moth pheromone and will not be confused or otherwise affected by it. The pheromone treatment contains no oils or other materials that would pose a threat to the Monarch population. In the pheroinone=based traps that we use to detect LBAM, we have trapped only limited numbers of a few closely related moth species, further indicating the highly specific . nature of this pheromone. Some of these other moth species are also invasive,unwanted pests, although they do not pose the same level of threat a's the LBAM. Because these other moths are permanently established in the surrounding region beyond the limits of the LBAM treatment area, any reduction in these populations would be expected to rebound after LBAM eradication treatments subside. How would/does the light brown apple moth affect the,economy? The current LBAM infestation has already caused the nations of Canada and Mexico to impose onerous restrictions on exports of crops and plants from the infested areas of California. China also has begun the kind of information-gathering that frequently leads to such trade restrictions. As businesses are forced-to delay, reduce or abandon exports to these nations, employment, investment and tax levels are all adversely impacted. Internally, restrictions are also imposed by CDFA and USDA on businesses such as plant nurseries in the infested areas so that their counterparts outside of the area can be protected from the infestation. These businesses must comply with strict regulations that limit or delay the companies' ability to export their plants.outside the area. .If the infestation is not eradicated, these regulations and trade restrictions would continue indefinitely and other countries would likely adopt similar measures. How willI be notified about the treatment? As required by state law, CDFA notifies all known residents of a treatment area by first- class mail in advance of an emergency treatment. We also offer an e-mail notification service (details at www.cdla.ca.uov/lbam) and a toll-free hotline (800-491-1899) during treatment periods to keep residents up to date. We will also work with local news media and elected officials A: d staff'at the city and county levels to get the message out about the treatment schedule and other elements of the project. We take additional steps to share information about the treatments in advance with local homeless shelters, farm Poster 1125/2008 worker organizations and other groups that have been brought to our attention by local officials or Have requested information. How have you communicated with environmental regulators? What have you communicated? We have provided details of our proposed treatment to a number of local, regional, state and federal groups such as the United States Fish and Wildlife Service, the California Coastal Commission, the National Marine and Fisheries Service, the Monterey Bay National Marine Sanctuary and the Central Coast Regional Water Quality Control Board. Communications have included meetings, e-mail, telephone and mail. We also work. with local news media and elected officials and staff at the city and county levels to get the message outabout the treatment schedule and other elements of the project. The information includes details about the program components, treatment schedule, the affected arca, the pheromone, and the availability of a toll-free number and an e-mail notification system for further information. When will you do an Environmental impact Report (EIR)? The EIR is underway and a draft should be available for review this summer(2008). Because the LBAN1 has the biological ability to multiply 'quickly, eradication efforts could only be successful with immediate efforts to contain and suppress the inoth population. That is.why CDFA declared an emergency to allow the eradication to begin tinder a temporary exemption from environmental analysis, with the understanding that a full environmental assessment of the project, including these emergency treatments, is required. The emergency declaration does not excuse the program Irom performing an EiR. Why not just let the apple moth be? If we do not eradicate this infestation, the moth would eventually multiply and spread to other areas of California, the United States and beyond. Farmers, residents, municipalities and other entities would repeatedly use pheromones and other, more toxic pesticides to suppress,the infestation and protect their crops, landscaping and habitat. Populations of threatened and endangered species could be severely impacted should this moth adapt to feeding on them or competing with them for food or habitat. The impact on agricultural production of crops that are hosts of the LBANI could reach $160 to $640 million annually in the currently infested counties in California(source: USDA). Additionally, California would likely be placed under perpetual quarantine by neighboring states and trading partners around the world, restricting our ability to export crops and plants. Canada and Mexico have already imposed such restrictions, resulting in delays, added expenses and reduced export business for local growers. Will the paint on my car be damaged? Should outdoor play equipment be hosed down after applications? Testing performed by the United States Department of Agriculture and decades of experience with aerial pheromone treatments in the 11.S. and other nations has resulted in no reports o('damage to automotive paint, outdoorTurn.iturc or other axnmon outdoor surfaces. Based on this information, no action is suggested to protect these items. 8 Posted ii25'2UC}8' What.about outdoor public gatherings on the night of applications? CDFA is in contact with local officials, school districts, etc. and has been made aware of evening and night events in the treatment area. The treatments on these nights are scheduled so that the specific sites in question are to be treated in the morning hours toward the end of the shift, after the activities have ended. Who is paying for,this? The USDA has provided the bulls of the funding for treatment as well as for the other activities in this program, including plant and crop inspecfions, traps, outreach and other elements. CDFA and local agricultural officials have also contributed to the project. What if the pheromone treatment doesn't work? The pheromone treatments ate a central part of a multi-year project that will require multiple tools to be successful. We have already contained the infestation by imposing quarantine restrictions and inspections on plant and crop shipments, and we suppressed the 'ri estation in 2007 by performing the initial aerial treatments in Central Coast communities and by deploying pheromone twist-ties in several locations around the fringes of the larger infested region. The planned aerial treatments in 2008 are the next step in the eradication process. Based on the history of pheromone treatments for this pest in Australia and New Zealand and for similar pests here in the U.S., we have confidence in the siuccess of the planned treatments. However, if the overall eradication project is not successful, we would have to reconsider whether eradication of the pest is possible under the circumstances. If not, the goal would then become suppression and containment of the'infestation over the long term in order'to minimize its environmental and economic impacts. cdfa C'A.LI'FORNIA DEPARTMENT OF FOOD. & AGRICULTURE JANUARY 2008 Prepared by the California Department of Food and Agriciulture. For the most current version of this-document, please visit the department's LBAM web site at www.cdl`a.ca._()ov/lban1 9 Posted 1%2512008 "OM1 prda s afNNs Arnold Schwarzenegger Governor November 16, 2007 Ms. Linda Adarns, Secretary California Environmental Protection Agency Ms. Kim Belshe, Secretary California Health and Hunan Services Agency Mr. A.G. Kawamura, Secretary California .Department of Food and Agriculture Dear Secretaries: In September 2007, the"California Department of Food and Agriculture (CDFA) initiated a program to eradicate an infestation of the Light Brown Apple Moth(LBAM) in Monterey County which involved the aerial application of a pheromone, Checkmate. A number of health complaints from people in the treatment area were brought to the attention of the California Environmental Protection Agency (Cal/EPA), CDFA, and the Department of Public Health(DPH). We directed our staffs, in cooperation with DPH, to conduct an evaluation of the complaints and the potential health effects that might be associated with the pheromone. The attached document represents a scientific consensus of the Department of Pesticide Regulation (DPR) and the Office of Environmental Health Hazard Assessment (OEHHA) on the available health and safety data of the pheromone products associated with the LBAM eradication program. This is one of the first instances of an aerial application of this material over a highly populated area. DPR and OEI- HA scientists reviewed the available information and prepared this document with DPH input. It is not intended to be a detailed human-health risk assessment, an epidemiological study of exposed individuals, or an evaluation of occupational exposure. Its purpose is to provide information on the toxicity of microencapsulated pheromones and the potential for exposure, and to provide recommendations. In summary, the toxicity data on the pheromone active ingredients, as well as on microencapsulated pheromone product formulations, suggest that exposure to a high dose of airborne Checkmate microcapsule particles could cause eye, skin, or respiratory irritation. The application rates were extremely low, and it is likely that exposure occurred at levels below those that would be expected to.result in health effects. Measured deposition rates fell below the proposed rate of 20 grams active ingredient per acre. �� Departments of the California Environmental Protection Agency VMt Printed on recycled paper,100%post-consurner--processed chlorine-free. Ms. Linda Adarns Ms. Kim Belshc Mr. A.G. Kawamura November 16, 2007 Page 2 Public concern has centered on the previously undisclosed inert ingredients, which have now been disclosed. Water is the bulk of the inert ingredients, as the microencapsulated polyurea particles consist primarily:of the pheromone active ingredients. The polyurea shell exists only as a component of the particles, and makes up only a small percentage of the particle weight. While the toxicological information on the Checkmate product indicates that exposure to high levels of the applied material would be consistent with many of the reported symptoms, the application rate was extremely low, and it is likely that exposure occurred at levels below those that would be expected to result in health effects. Based on their review, staff have included recommendations to address the health complaints received from this program. A series of actions to ensure proper collection, review, and coordination of health complaints is also recommended. Air sampling should be considered to investigate the contribution of the aerially released microcapsule particles to the overall ambient air particulate load. A well-designed, formalized study and tracking program that looks at a number of factors including, but not limited to, both long- and short-terin health outcomes, exposed and unexposed persons, the potential effects of stress, and outreach methods on illness complaints would be needed to begin to properly address the question of causality. Many of these recommendations have been implemented or are under development. The remainder will involve the coordination among the three agencies. If you have further questions, please do not hesitate to contact us. Sincerely, original signed bl' original signed by Mary-Ann Warmerdam, Director Joan .Denton, Director Department of Pesticide Regulation Office of Environmental (916) 445-4000 Health Hazard Assessment (916) 322-6325 Attachment cc: Mr. Allan Hirsch, OEHHA Chief Deputy Director(w/Attaclunent) Mr. Chris Reardon, DPR Legislative Director(w/Attachment) Consensus Statement on Human Health Aspects of the Aerial Application of M.icroencapsulated Pheromones to Combat the Light Brown Apple Moth October 31, 2007 This document represents a scientific consensus of the Department of Pesticide Regulation (D.PR) and the Office of Environmental Health Hazard Assessment (OEHHA) on the available health and safety data of the pheromone products associated with the Light Brown Apple Moth (LRAM) eradication program. This is one of the first instances of the aerial application of this material over a highly populated area. Scientists from DPR and OE[[HA reviewed the available information and prepared this document with input from the Department of Public Health. This document is not intended to be a detailed human health risk assessment, an epidemiological study of exposed individuals, or an evaluation of occupational exposure. The purpose of this document is to provide information on the toxicity of microencapsulated pheromones, the potential for exposure, and to provide reconimendations. General Information Pheromones are naturally occurring volatile chemicals and have been loosely described as "pheromone perfumes." Certain insect species produce them, in very small amounts, to influence the behavior.of other individuals of the same species. Many lepidopteran species (butterflies and moths) use pheromones to attract mates. These pheromones consist of mixtures of similar chemicals, and the relative amounts of several pheromone chemicals determine which specific moths are attracted. Synthetically produced pheromones can be used to control insect pests. All the lepidopteran pheromones approved for pest control use are chemicals produced by female moths to attract mates. By releasing a specific pheromone mixture into the air, it is possible to disorient males looking for females. The pheromone alters behavior, not the insects' health or reproductive competence; but it results in many females' failure to mate and lay eggs. Pheromone pesticide products may be applied using slow-release dispensers (often attached to trees) or applied by ground or aerial spray equipment. Toxicity Information on the Pheromone Active Ingredients in the Products Used to Combat LBAM Tlie U. S. Environmental Protection Agency (U.S. EPA) defines lepidopteran pheromones chemically as unbranched aliphatic chains (9 to 18 carbon atoms) ending in an alcohol, aldehyde, or acetate functional group and containing up to 3 double bonds in the chain. U.S. EPA has also made two relevant determinations about these chemicals: 1) that they are sufficiently similar toxicologically to be considered as a group, that is, toxicology data on one pheromone is applicable to the other pheromones; and 2) that their toxicity is so minor that they are exempt from the requirement of a tolerance (Federal Register 60, No. 168, pp 45060 to 45062, August 30, 1995). These pheromones are often referred to as Straight Chained Lepidopteran Pheromones (SCLPs). 1 Active ingredients (A.I.$) are the chemicals in a pesticide product that are effective against the targeted pest. The various products being proposed for use on LBAM contain similar active ingredients in different combinations and ratios. Checkmate OLR-F contains the pheromones (E)-11-tetradecen-1-yl acetate and (Z)-11-tetradecen-1-yl acetate. Checkmate LBAM-F contains the pheromones (E)-1 I-tetradecen-l-yl acetate and . (E, E)-9,1 I-tetradecen-l-yl acetate. It is the choice of these chemicals and their ratios that results in the specific mating disruption activity for LBAM. Checkmate OLR-F targets the Omnivorous .Leaf Roller but also has activity with the LBAM and was used in the first aerial applications in Monterey. Checkmate LBAM-F more specifically targets the LBAM and the California Department of Food and Agriculture (CDFA)has indicated that it will be used in fixture aerial applications. DPR and OEHHA scientists have not reviewed toxicity studies on all the specific active ingredients in LBAM pheromone products; however, they have reviewed acute toxicity studies on other lepidopteran pheromones, and according to the USEPA determination, these studies can be considered to apply to any lepidopteran pheromone. These studies show very low acute oral and dermal toxicity. As an initial screen, toxicologists describe acute toxicity by the LD50, the dose that kills half the test animals. The pheromone studies used extremely high dosages, but did not kill any animals. Consequently, scientists cannot determine the LD50, but can conclude that it is larger than the doses used. An oral toxicity study in rats produced no mortality and no toxic signs at a dosage of 5,000 mg/kg. Thus, the oral LD50 is > 5,000 mg/kg, placing it in Category IV for oral, toxicity. (.These U.S. EPA-derived toxicity categories are used to select the appropriate signal words to alert users to specific hazards and can also be used to compare the acute toxicity of different chemicals. The categories include Category I- High Toxicity, Category I1- Moderate Toxicity,Category Ill- Low Toxicity, and. Category IV- Very Low Toxicity). In a'rabbit dermal toxicity study using a single dose of 2,000 mg/kg, there was some diarrhea but no mortality. Thus the dermal LD50 is >2,000 mg/kg, placing it in Category I11 for dermal toxicity. Eye and skin irritation studies indicated the potential for mild to moderate skin and eye irritation (Category [i[). A study on a chemical similar to one of the active ingredients in the LBAM pheromone docs indicate some potential for limited dermal sensitization (Category111), while other studies reviewed by USEPA did not indicate den-nal sensitization. The maximum application rates for lepidopteran pheromone products range from 15 to 37.5 grams (about 0.5 to 1.3 ounces) of A.I. per acre per application and a total of 150 grams (about 5 ounces) of A.I. per acre per year. These are very low application rates compared with the dose levels used in the above studies. Chronic toxicity is not addressed in this document because there will not be long- term exposure to the pheromone product. After reviewing the toxicological data of SCLPs, scientists at the USEPA concluded that "Based on low toxic•itr• in animal testing, and expected low exposures to humans, no risk to human health is expected frorn.the use of these phcrornoraes. During more than 10 rears of atse of lepidopteran pheromones, no adverse effects have been reported. ... The safety record.for lepidopteran pheromones has allowed the Agency to conclude that consumption offood containing residues of the pheromones presents no risk. ... Adverse effects on non target organisms (mammals, birds, and aquatic organisms) are not expected because these pherotnones are released in very small amounts to the environment and act on a select group of insects." This statement refers primarily to the pheromone.active ingredients generally used in emitter devices or aerial application over agricultural areas rather than aerial application over populated areas (such as in the present situation). Toxicity Information on the Product Formulations Used to Combat LBAM Besides the A.I.s, a product formulation consists of"inert ingredients"that are in the formulation to improve performance, as a manufacturing byproduct, as a diluent, or as a reactant from the manufacturing process. The LBAM pheromone products are available in three formulation types. Each formulation combines the pheromones with materials that release it into the atmosphere slowly, so that the products remain active for a period of time. The dispenser formulation (also referred to as twist-tie) consists of a plastic tube containing the active ingredients. The plastic tube is attached to the target plants, slowly emitting the pheromones. This product has been used extensively in Australia and New Zealand to combat LBAM. Another formulation is a flake (Disrupt Micro-Flake) made up primarily of the A.I.s, a rigid plastic film, and resins. Micro-Tac or Micro-Tac II (adjuvants) may be used with the Micro-Flake to aid in adhesion to foliage. Checkmate OLR-F and Checkmate LBAM-F are microencapsulated forms. Both Micro-Flake and Checkmate products are approved for either ground or aerial application. Much attention and controversy has centered on the identification and potential toxicity of the individual inert ingredients in the Checkmate OLR-F and LBAM-F products; however, the identity of the inert ingredients has recently been made public. In a recent letter to Assemblymember John Laird from CDFA Secretary A. G. Kawamura, all the ingredients in Checkmate LBAM-F are identified as: 1) Water, the main ingredient. 2) (E)-11 tetradecen-1-yl acetate-the pheromone. 3) (E, E)-9,11 tetradecadien-l-yl acetate- the pheromone. 4) Ammonium phosphate- commonly used in "crystal growing" kits for children and as a plant nutrient. 5) 1,2-benzisothiazol=3-one- used as antibacterial and antifungal agents in a variety of products. 6) 2-hydroxy-4-n-octyloxybenzophenone- used in sunscreen and in lots of products made of plastics, including food containers; useful for its UV-blocking propel-ties. 7) Cross linked polyurea polymer- commonly used in manufacturing of plastics such as polyurethane foam production, waterproofing, insulation, and micro encapsulation agent for pesticides. 8) Butylated Hydroxytoluene- common food preservative. 3 9) Polyvinyl alcohol-polymer commonly used in shampoos and cosmetics, feminine hygiene and incontinence products, children's play putty, glue, lubrication drops for hard contact lens wearers and other products. 10)Tricaprylyl methyl ammonium chloride- commonly used in the manufacture of various pesticides and pliarmaceuticals; contributes to product purity. 11)Sodium Phosphate- naturally occurring substance. Sodium phosphate is also an additive in.egg products and is a prescribed laxative prior to procedures such as colonoscopy. The percentages of these ingredients are still confidential business information. This document does.not review the toxicity of these compounds individually, but addresses the forinulated product. While this infuriation is important, DPR.noted that inert ingredients other than water are present in very small amounts and exist primarily as the polyurea shell enclosing the pheroinones. These particles consist mostly of pheromones. After application of the particles, the pheromones are slowly emitted over a 30-to 90-day period, and the polyurea shell will biodegrade into urea, a low toxicity compound normally found as a result of the breakdown of proteins in the human body. Another important point is that DPR scientists have reviewed the most relevant data: toxicity studies on the formulated product as a whole. DPR scientists reviewed an acute dermal toxicity study using Checkmate PBW-F, which uses the same microencapsulation as Checkmate OLR-F and LRAM-F. The primary difference is in the selection of pheromones contained within the microencapsulated particles. In the study of Checkmate PBW=F, 2,000 mg/kg was applied to the skin of rabbits and resulted in no mortality, but some diarrhea:The results led to a Category III rating for dermal toxicity. Similarly, an eye irritation study in rabbits, in which 100 mg doses were instilled in the eyes, led to a Category II:i.rating for eye irritation, which means the product was moderately irritating. Materials that cause eye and skin irritation could reasonably be expected to cause some respiratory irritation if'a sufficient amount were inhaled. The animal study results are consistent with the Suterra Checkmate OLR-F and LBAM-F labels that state that the products cause moderate eye and skin irritation. This label designation is for the undiluted product rather than for the significantly diluted water suspension that is actually applied. The microcapsule particles are very large by inhalation standards (25 micrometers in diameter or'larger) and unable to reach the deep lung. As a result, an inhalation toxicity study, which is designed to examine systemic effects resulting from inhalation into the lung, would not be useful and was not conducted. If inhaled, because of the large size, these microcapsules are not likely to reach the pulmonary (air exchange) region of the lung. However, such large particles are likely to be,deposited in the nasal passages, pharynx, larynx, and tracheo-bronchial region and are either absorbed or moved to the larynx and swallowed. If a sufficient amount of large particles (regardless of 4 composition) is inhaled, it is plausible that it could cause irritation of the throat, coughing, sneezing, and excess mucus production in the upper respiratory system. Taken together,the toxicity data on the pheromones and on microencapsulated products suggest the possibility that exposure to a sufficient amount of airborne Checkmate microcapsule particles could result in some level of eye, skin, or respiratory irritation. However, as the product is diluted and applied over a large area, the degree of exposure as well as the potential for irritation should decrease significantly. Application and Deposition The maximum application rates allowed by the label are 20 grams of A.I. per acre per application, corresponding to 83 grams per acre of the Checkmate product. These application rates are very low, both in absolute terms and when compared with the ground or aerial application rates of almost any other pesticide. To put this amount in perspective, a tablespoon of sugar weighs almost 20 grams. The product consists primarily of the polyurea-microencapsulated pheromone suspended in water. The material applied is a diluted mixture that contains 2.1% A.I. (pheromone). Tank samples collected during the first week of application showed concentrations of the A.I. varied from 0.69% to 3.0%, indicating settling might have occurred in the mixture. Some visual observations also indicated a problem with the product staying well mixed in the application equipment. Changes are being made to the mixing and loading equipment to address this problem in future applications. At the highest proposed application rate, the theoretical concentration of the product hitting the ground should be 0.460 milligrams A.I./square foot. During the first week of application, deposition measurements showed deposition rates below this calculated theoretical maximum. (These data will be available later.) This indicates there were not"pockets" of higher than intended deposition resulting from the tank concentration variations. Illness Complaints Before the current LBAM eradication effort, DPR had received few complaints involving pheromones, and has no persuasive cases on file attributed to pheromone exposure in the . absence of additional pesticides. DPR evaluated two cases, one in 1982 and one in 1989, as "unlikely" to be related to exposure to pheromone alone or to pheromone with an adjuvant. Another 1.982 case provided insufficient information to evaluate. These cases did not involve Checkmate products. California law requires physicians to report known or suspected pesticide-related illnesses to their local health department within 24 hours after seeing a patient. The health department forwards these reports to the State. Only one pesticide illness report(PIR) was received from the Monterey County Health Department during or soon after the Checkmate spraying September 9-12, 2007. A 57-year old man was diagnosed with pharyngeal irritation after visiting a doctor on September 16. The exposure date was listed as September 16, which was after the Checkmate spraying had been completed. 5 However, additional data clarified that the exposure occurred on September 11. DPR's surveillance systeiil, like others, under detects pesticide illnesses for various reasons, including that pesticide illnesses may mimic other illnesses and that physicians and patients may not ascribe symptoms to pesticide exposure. The California Environmental Protection Agency (Cal/EPA) received a compilation of e-. mails fi-om area citizens with complaints of adverse reactions to the aerial spraying of Checkmate from September 9 to 12, 2007. Although it is likely that we do not have complete reporting.of all health complaints attributed to spraying, certain patterns do emerge fi-om the information we have. Upper respiratory symptoms, including cough' sore throat, runny dose, and congestion were the predominant complaints. Also frequently repoi-ted were headaches, itchy eyes, nose, and throat; shortness of breath; muscle aches; diarrhea; and fatigue. Most reported symptoms are consistent with inhalation of a nonspecific irritant material, but because they are also consistent with other possible causes, it is not possible to confirm the symptoms are or are not due to the application of Checkmate. For example, some of the symptoms are consistent with infectious or allergic conditions or other health effects not caused by exposure to Checkmate. Based on the available toxicological information on the Checkmate product, some of the reported health effects such as eye, skin, or respiratory irritation could be consistent with inhalation of a sufficient amount of the applied material. But because the measurements confirm the application rate was extremely low, it is likely that exposure occurred at levels below those that would be expected to result in health effects. However, because not all health effects can be predicted and because the general population includes susceptible populations, such as children, the elderly, and those with chronic diseases, we cannot provide a definitive cause for their symptosis. A well designed formalized study and tracking program that looks,at several factors including, but not limited to both long- and short-terl health outcomes, exposed and unexposed persons, the potential effects of stress and outreach methods on illness complaints would be needed to begin to properly address the question of causality. Conclusions • Time toxicity data on the pheromone active ingredients as well as on microencapsulated pheromone product formulations suggest that exposure to a high dose of airborne Checkmate microcapsule particles could cause eye, skin, or respiratory irritation. • The application rates were extremely low. Measured deposition rates fell below the proposed rate of 20 grams A.I. per acre. • Public concern has centered on the previously undisclosed inert ingredients, which have now been disclosed. The bulk of the inerts is water, as the microencapsulated polyurea particles consist primarily of the pheromone active ingredients. The 6 polyurea shell exists only as a component of the particles, and makes up only a small percentage of the particle weight. • The toxicological information on the Checkmate product indicates that exposure to high levels of the applied material would be consistent with many of the reported symptoms. However, because tlic application rate was:extremely low, it is likely that exposure occurred at levels below those that would be expected to result in health effects. Recommendations to.CDFA (Note: Some of these recommendations may already have been implemented) • in describing the long history of safe use of lepidopteran pheromone products, care should be to indicate clearly that most of this use involved pheromone dispensers (for example, twist ties) and aerial application over agricultural areas. :. • The outreach program should better explain the rationale behind the choice of specific eradication methods. • A credible and trusted mechanism for collecting symptom complaints from people in the eradication zone should be established. • The eradication program should'have a public notification and education component that encourages residents to consult doctors about symptoms that they attribute to pesticide exposure and to remind their doctors that California law requires doctors to report pesticide illnesses. These official records can be used in follow-up investigations by local and State health and agricultural staff to identify adverse health reactions from particular pesticide formulations or application techniques. • Prior to spraying, the State should work with local health officers to ensure that physicians and other health care providers are given information on the application; what, if any, symptoms are likely to be seen; and how to report, among others. In general, the physicians and health care providers should be informed of the illness reporting requirements and should receive training on pesticide poisoning recognition and management. • Air sampling should be considered to investigate the contribution of the aerially released microcapsule particles to the overall ambient air particulate load. • A formalized plan to address the above recommendations should be in place prior to spraying. • A well designed formalized study and tracking program that looks at a number of factors including, but not limited to both long-. and short-term health outcomes, exposed and unexposed persons, the potential effects of stress and outreach methods I on illness complaints would be needed to begin to properly address the question of causality. 8 REQUEST TO SPEAK FORM (3 Minute Limit) I wish to speak on Agenda Item 0: :� •2 Complete this,form and place it in the upright box near the Date: 73 — speaker's —speaker's podium, and wait to be called by the Chair. 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Address: Q�' USIP�I cit ROY 01- L - L 131�/Vl Phone: 1 am speaking for: Myself }���5 ❑ Ido not want to speak but would like to L Organization: leave coimnents for the Board to consider Q' S a41 U�i v i rt7VY1"EP4 (Use the back of this forret) L�rnn o,- i ►�.d..� VMI^m� G�-� . Office of the Clerk of the Board of Supervisors CONTRA COSTA COUNTY 651 Pine Street, Room 106 Martinez, CA 94553 Phone: 925.335.1900 Fax: 925.335.1913' NOTICE OF CORRECTION TO RECORD Board Agenda Item No.: D.2 Date: March 11, 2008 Please note that the following correction was made to the record for this item: Please see page 3— INCLUDED : Mayor Robert Lieber and Residents of Richmond's documents. .. :PLEASE DESTROY $; ANY PREVIOUS COPIES OF THIS RECORD :pY AND REPLACE THEM WITH THE ATTACHED February 26, 2008 Oakland City Council Public Safety Meeting--CDFA Aerial Pesticide Spray Statement: My name is Lisa Tracy. I am an Oakland resident of 10 years, mother of three children, with a PhD from UC Berkeley School of Social Welfare. I represent Stop the Spray--East Bay. I will address Pest Management Issues: 1) The CDFA states there has been NO crop damage due to LBAM thus far. 2) World renowned UC Davis entomologist Dr. James Carey says there is near zero chance of eradication of the moth. He and other scientists say the moth has likely spread beyond.the 9 counties being sprayed. 3) Independent entomologists say the moth has likely been here for at least 10 years. Given no crop damage, it is likely the moth is being controlled in the natural environment. 4) Dr. Daniel Harder, Executive Director of the UC Santa Cruz Arboretum, says LBAM is considered a minor pest in New Zealand and Hawaii where it was introduced over 100 years ago. New Zealand's climate and ecosystem are similar to ours. 5) There are least toxic ground based solutions for controlling the moth including release of natural predators and sterile male moths, sticky traps, and more. 6) The effects of the pesticide on non-target species is unknown. However, toxicologist Dr. Richard Philp says very similar pheromones are known to be toxic to aquatic life. 7) Dr. Harder points out the pesticide manufacturer cautions against its use on irrigated crops to avoid concentration of the pheromone in runoff. With aerial spraying it will definitely end up in our water systems and in the Bay. 8) In conclusion, the state has not demonstrated the need for or effectiveness of the spray, and the mostly unstudied but potentially serious long term risks it poses to human health and the environment makes it, in my opinion, unconscionable for the State to spray populated areas. We urge your Committee to join the City of Albany and others in taking a strong stand against the spray and demanding in- depth long-term study of any potential health effects. 9) With my background in social work research and practice with the homeless, immigrants and refugees and other low income populations, I am very concerned about adverse impacts on these groups due to lack of awareness of the spray and needed protective measures, and pre-existing health conditions. As a mother of children ages 2 to 9, given the potential health impacts on children, I would seriously consider moving out of the Bay Area permanently if the spraying occurs. I know I am not alone in this sentiment. 10)Thank you to the Councilmembers Brunner and Reid for putting forth the resolution and to all the Committee members for your serious consideration of and action on this issue. Lisa C. Tracy, M.S.W., Ph.D. 4706 Manila Ave. Oakland, CA 94609 (510) 595-7224 l isa.tracyre.Dsbcglobal.net Con 61 March 10. 2008 Dear Members of the Contra Costa County Board of Supervisors: 1 am writing to ask you to pass a resolution opposing the State of California's plan to spray aerial pesticide over densely populated counties in California in the vain hope of eradicating the Light Brown Apple Moth (LBAM). I ask that you use your influence, informed by the research of respected scientists and citizens in California who have raised concerns about the effects of aerial pesticide sprayinb on human and environmental health, to initiate legal action against the State if necessary. I also ask that you work with the State of California and Secretary Kawamura to develop a comprehensive statewide plan for implementing. pest control measures that have been tested prior to application, and have been deemed safe for people and the environment based on the tenets of the Precautionary Principle. It is essential for the Contra Costa County Board of Supervisors to work with other local governments to oppose this spray program in order to protect the health of Bay Area residents, especially the most vulnerable populations including the very young, the elderly, and those with respiratory conditions and allergies. As the mother of two very young children, I am very . concerned that the California Department of Food and Agriculture (CDFA) is spending public funds on a massive and deceptive public relations effort to promote this aerial spray program despite: • lack of'long-term human toxicity testing of the chemicals being used • the known toxicity to aquatic life of ingredients in.the pesticides • the unknown human health risks of the microscopic plastic capsules and `inert' ingredients that carry the pesticide • the unknown risks to pets, honeybees, and beneficial.predators that naturally keep pests— including LRAM—in check • more than 600 health comllaints following spraying in fall 2007 in Santa Cruz and. Monterey Counties. • the fact that LBAM has not caused crop damage in California in the (at least) 1.0 years it has been documented here 4 the fact that LRAM, also an exotic species in New Zealand, is a minor pest there •,. biologists' expert testimony that eradication has almost no chance of success • the availability of minimally, toxic, environmentally-friendly control measures used for . other similar"leaf-roller" pests that are already present in California • massive public opposition to the spray program The City of�Pacific Grove; the City and County of Santa Cruz, the Cities of Albany, Berkeley, and Oakland. and the Sierra Club have already passed resolutions opposing aerial spraying of Californians and calling for a safer approach to controlling LBAM. Please join these leaders in communicating Contra Costa County's opposition to aerial spraying to state and federal. officials. 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HF,A41.I, State Bar No. 180501 3 Assistant County Counsel CHRISTOPIIER It, CHELEDEN, State Bar No. 1.81185 a Assistant County Counsel 701 Ocean Street, Room 505 Santa Cruz, California 95060-4068 6 Telephone: (831) 454-2040 Fax: (831) 454-2115 7 Attorneys for Plaintiff/Petitioner County of Santa Cruz i 9 SUPERIOR COURT OF CALIFORNIA 10 1i COUNTY OF SANTA CRUZ 13 COUNTY OF SANTA CRUZ Case No. 158516 13 Plaintiff/Petitioner, DECLARATION OF RICHARD PHILP 14 V. IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY 1' CALIFORNIA DEPARTMENT OF FOOD RESTRAINING ORDER 16 AND AGRICULTURE, A.G. KAWAMURA, in his off:tcial capacity as Secretary of the Date: October 3.1, 2007 17 California Department of Food and Agriculture; Time: 1:00 p.m: 1K and DOES 1 through 100, inclusive, Dept: 8 19 Defendants/Respondents. 20 21 I, Richard Philp, hereby declare: 22 1. I am an Emeritus Professor of Pharmacology and Toxicology with the University of . ?3 Western Ontario in London. Canada. I have a .Ph.D. in Pharmacology from the University of 24 Western Ontario and have spent my career as a professor of Pharmacology and Toxicology. 1 have published over 90 peer-reviewed manuscripts in the area of pharmacolooy and toxicology and I am 26 an experienced researcher on pharmacology and toxicoloo7 issues. A co of m curriculum vitae is P' p by by PY Y ' 27 attached hereto as Exhibit A.. I have personal knowledge of the facts set forth below, and if called 28 upon to testify thereto I could and would do so competently. I- i 1 2. After Monterey County was aerially sprayed with the pesticide Checkmate OLR-F in 2 September 2007, 1 was asked to review the health hazards associated with this aerial spraying. In 3 conducting my review, I reviewed available literature and government documents concerning 4 Checkmate and I drafted a preliminary report on this issue, a true and correct copy of which is 5 attached hereto as Exhibit B. My general conclusions and recommendations are set forth at page 8 6 of my final report. 7 3. in sum, 1 have concluded that no chronic toxicity study of Checkmate has been 8 conducted in a mammalian species by any route of administration and certainly not involving 9 exposures-to the product to be employed by the intended method of application (aerosol spray of 10 microcapsules). Any claims of the safety of Checkmate.are based on extrapolation from acute 1 1 toxicity studies and one sub-acute, 90-day study that employed the oral route of administration of 12 certain chemicals related, but not identical, to those used in Checkmate. One cannot conclude from 13 these studies that Checkmate is a safe product to aerial spray over an urban population, nor can one 14 guarantee that longer-term, repeated exposures of humans are without risk. A chronic toxicity study 15 of at least 90 days and preferably six months duration, employing daily exposure to aerosol or 16 Checkmate at a high exposure level would be required before a conclusion of safety could be 17 legitimately drawn. It is customary in such studies to use a much higher exposure level in order not 18 to miss adverse reactions that might occur;too infrequently to be detected at .lower exposures. 19 4. In none of the documents I reviewed, including the USDA environmental assessment, 20 is there any mention of previous experience with aerial spraying of populated, urban areas. Previous 21 efforts to control LBAM in the proposed 'treatment area employed ground application techniques. 2222 Pheromone baited traps were placed throughout the State of California to monitor the moth 223 population and distribution. isolated populations in Napa and Oakley were treated using ground 2224 equipment with Bacillus /huringiensis kin-sluki (Btk) (USDA Environmental Assessment, 2007, p21 25 para 2). This is a bacterial product that attacks the early larval stages of most lepidopterans. 26 5. There is ample evidence that many pheromones and semiochernicals (the. synthetic 27 counterparts of pheromones) possess significant toxicity for aquatic species. This suggests that aerial 28 "Y spraying carries an increased environmental risk given the difficulty in confining the spray to the '- target area. 3 6. In summary, and as more Gully explained in my attached report, the USDA and EPA r documents I reviewed are Milled with contradictory statements regarding the toxicity testing of pheromones, inappropriate extrapolations .from irrelevant toxicity studies, and are suggestive of a 6 poor understanding of basic pharmacological and toxicological principles. 7 7. In my opinion, since the decision to use aerial spraying as the method of application 8 appears to have been made entirely on economic grounds, the decision should be revisited given the 9 lack of adequate evidence for its safety in the long term. Either ground-based methods of application should be employed or an adequate chronic toxicity study should be conducted. .Ground- based technology has the added advantage of posing less risk to the environment. 12 8. Finally, I have recently reviewed the toxicology of the "inert" ingredients provided to 13 me and found that: i) some have been shown to be skin irritants in animal studies, ii) no information 14 regarding respiratory toxicity or absorption is generally available, iii)no carcinogenicity studies 15 have been performed on some; and iv) I was unable to find inhalation toxicity studies for any of the 16 inert ingredients. This further supports my conclusion that this product should not be aerially 17 sprayed as intended at this time. 18 1 declare under penalty of perjury under the laws of the State of California the foregoing is 19 true and correct and that this Declaration was executed on this 29th day of October 2007 at 20 London, Canada. , 21 DR. RICHARD PHILP 22 23 2:t 'S 26 27 28 3_ � . 2 3111I � 1 1, .lames R. Carey, hereby declare: 3 1. I am a Professor of i:ntomology at the University of California, Davis with 4 entomology degrees from Iowa State University (BS in 1973; MS in']975) and the 5 University of California, Berkeley (PhD in 1980). 1 specialize in both insect demography 6 and invasion biology. 1 have particular interest in understanding the nature of pest 7 invasions and the feasibility of eradication. i am not an advocate for any environmental 8 and/or citizen group. I support eradication efforts in situations where I believe it is 9 feasible. This position is reflected in a symposium that i organized in 1999 and the paper 10 that I co-authored from this symposium the following year (Myers JH, Simberloff D, 11 Kuris A, Carey JR (2000). Eradication revisited--dealing with.exotic species'"Trends in 12 Ecology and Evolution. 15, 515-516). It is also reflected in my service on the Medfly 13 Scientific Advisory Committee for the California Department of FoIod and Agriculture 14 from .1987 to 1994. Although I continue to question whether the medfly was ever truly 15 eradicated in the state, i none-the-less have always supported eradication efforts against 16 this important agricultural pest. 17 2. Some key relevant information from my biography: -I served on the 18 California Department of Food and Agriculture's Medfly Scientific Advisory Panel from 19 1987-1994, testified to the California Legislature "Committee of the Whole" in 1990 on 20 the Medfly Crisis in California, authored the paper :'Establishment of the Mediterranean 21 Fruit Fly in California" (1992, Science 258, 457), and have studied tephritid fruit flies in 22 Greece. Hawaii, Pakistan, China, and Mexico. I was one of the main..organizers of an 23 international workshop on invasion biology held at UC Davis in 1995 and the senior I Guest Editor of the Proceedings of this workshop published as a Special Issue of 2 Biological Conservation (1997). 1 was elected a AAAS Fellow in 2000, was a co- 3 organizer of the workshop "Life Span: Evolutionary, Ecological and Demographic 4 Perspectives" held in May, 2001 (in SantOrini, Greece) sponsored by the National 5 Institute on Aging, and author of the book "Demography for Biologists (1993;Oxford 6 Univ. Press) and the monograph "Longevity" (2003, Princeton University Press). i am 7 currently director of an NIH-funded program project on the demography and 8 evolutionary biology of life span. i have taught both undergraduate and graduate courses 9 in insect ecology and a graduate course in insect demography (source of the Oxford book 10 material). 1 have also served on and/or chaired several major university committees at 11 UC Davis including the College of Agriculture and Environmental Sciences Executive 12 Committee, and the UCD University Council (to the Chancellor) and was vice-chair of 13 the Department of Entomology at UC Davis from 1997-99. .I am currently vice-chair 14 (2007-08) and chair-elect (2008-09) of the UC Systemwide University Committee on 15 Research Policy which, when chair, will place me on the UC Systemwide Academic 16 Council. I am the author of over 150 scientific papers most of which are on either the 17 biology, demography, and ecology of fruit flies (e.g. Mediterranean fruit fly) or principles 18 of invasion biology. 19 3. Successful eradication of any invasive species is an enormous challenge, 20 even under the best of circumstances (e.g.. small, well-delineated population; effective 21. eradication 'tool'.- highly-effective monitoring techniques; supportof multi-year 22 programs). Eradication of populations of exotic insect species is especially difficult for 23 the same reason that metastatic cancer is so difficult to cure--anything short of 100% r% I elimination is control (management) and not eradication (cure). Thuseven a 99% success in the elimination of metastases is ultimately a failure in the sense that small residual 3 pockets of insects can regenerate the entire population. This is the situation with the light 4 brown apple moth (LBAM) with thousands or even tens of thousands of small 5 populations spread over a multi-county region in California. 6 4. . There are several specific aspects of the LBAN4 invasion that reduce to 7 near zero the likelihood of successful eradication. 8 (a). 'Che invasion of the LBAM is so widespread that eradication is not feasible 9 regardless of the eradication tool used. Although it is now confirmed.-to be present in 9 10 counties, it is highly likely to also be present in many more counties. 1 1 (b). To my knowledge the use of a pheromone to disrupt mating has never been 12 used in any insect eradication attempt. And, I am virtually certain that there has never 13 been a successful program oferadication based on mating disruption.via pheromone. The 14 likely reason for this is that there are shortcomings with the use of this technology in 15 insect control. Thus it follows that the use of this mating disruption strategy is an 16 inadequate tool to use in insect eradication. 17 (c). Detection of insects at low population levels is exceedingly difficult and the 18 LBAM is no exception. This.is important at the outset of an eradication program since 19 detection allows entomologists to delineate the population. But good detection is equally 20 important at advanced stages of eradication since it is needed to identify the location of 21 pockets or residual populations. An additional complication is that the pheromone used to 22 disrupt mating is also used as the attractant in traps for monitoring. Pheromones cannot I be used simultaneously for both population control and population monitoring since each 21 cancels out the effectiveness of the other. 3 6. In my view these three factors--extent of spread, faulty eradication tool 4 (use of pheromone for mating disruption), and difficulty ol'detection--make it virtually 5 impossible to eradicate the LQAM in California- 6 i.declare under penalty of perjury under the laws of the State of California the 7 foregoing is true and correct and that this Declaration was executed on this 14`x' day 8 November 2007 at Davis. California. 9 10 11 JAMES R. CAREY Experts question plan to spray to fight moths J 2—, 3 1' V, 3 1 CO6 6:13 PM A SFCate "con, Print This'Article Back to Article ......:.... SFGate.cor Expert s question plan to spray to fightht moths - �4. .: Jane Kay, Chronicle Environment Writer "" ,.,.: •,;- .,: a:x i n Thursday, March 6, 2008 .......... „.....:.............. ..... ...:. y.:: F. The light brown apple moth may not be the voracious g PP .: ................:. ............ :. crop threat portrayed by state and federal agricultural officials, according to some scientists who also warn that the aerial spraying ofa pesticide over California's cities may turn out to be an expensive, unnecessary public relations nightmare doomed to fail. U.S. and state agricultural departments support a $74.5 million program to spray the pesticide over hundreds of square miles from Monterey County north to Solano County as early as this summer, but several of the state's top insect and plant scientists say the decision to do so should be reconsidered. "It's not such a nasty pest. You're not going to see a plant succumbing to the light brown apple moth," said botanist Daniel Harder, executive director of the Arboretum at UC Santa Cruz. Harder visited New Zealand to research the moth's behavior there. In the face of criticism, U.S. Department of Agriculture and California Department of Food and Agricultural scientists stand firm that there must be quick aerial spraying to eliminate the moth, which they say is newly arrived and whose larvae threaten more than.too crops in the state worth multimillions of dollars. Nursery plants and native trees are also at risk, they say. Thousands of Bay Area residents have signed petitions to stop the spraying, legislators have introduced five bills to control aerial application over urban areas, and four city councils have passed resolutions against it. Hundreds of residents in Monterey and Santa Cruz counties, where pheromone pesticides were aerially applied late last year, have reported health symptoms, including shortness of breath, muscle aches and sore throats. Citizen groups are asserting that the government failed to disclose all of the contents of the two pesticides and that safety testing has been inadequate. This is the first time the pheromone-based pesticide is being sprayed over cities. To suppress or eliminate http://www.sfgate.comIcgi-binIarticle.cgi?file=/c(a/2008(03l06(MN69VD309.DTL&type=printable Page 1 of 5 Experts question plan tospray to fight moths 3/10/08 6:13 PM Among entomologists, the debate is more subtle. They are weighing the value of trying to "eradicate," which means complete elimination, against the less invasive technique of trying to "contain" a pest, which means suppressing or controlling it. Some scientists from the University of California and other independent experts say the pest should be contained in urban areas, but the full-scale airplane onslaught should be saved for California's breadbasket, the Central Valley, which the agricultural departments are trying to protect. Furthermore, they say, the moth probably has been in California for decades - not just in the-last few years - and is too well-established in at least a dozen countries to be completely wiped out by aerial spraying of a pheromone that attracts male moths and disrupts the breeding process. The bug is considered a minor pest in New Zealand, where it arrived from Australia, they say. The tens of millions of dollars given to California for the aerial spraying and related activities should be used instead to contain the moth and "slow the spread as much as possible to the Central Valley, if it's not already there," said James Carey, UC Davis entomology professor. The light brown apple moth is in a class of insects called leaf rollers whose larvae, or worms, cocoon inside leaves, potentially pitting ornamentals and reducing vigor of a.wzde range of plants, including fruit trees and grapes. Gro-,vers already spray for other leaf-roller pests in California. Warning that the moth could devastate the state's crops, agriculture officials have announced that they intend aerial spraying of a pheromone pesticide called Checkmate, or other yet undetermined products, over most of the Bay Area starting in August. The pheromones aren't toxic to moths, animals or people, they say, but curtail moth populations by disrupting mating. Spraying is scheduled for Monterey and Santa Cruz counties in June. The plan is to completely eradicate the moth in the 12 counties statewide where it has been trapped. Carey says the plan won't work. The state and federal agricultural departments need to acknowledge that "the pest has been here so long and is so widespread" that they don't have the tools o:r the monitoring technologies that are up to the task of eradication, he said. Critics advise different plan "It's virtually impossible to eradicate them," said Carey, who spent seven years on the state Department of Food and Agriculture's medfly scientific advisory panel and has published articles in scientific journals examining the effectiveness of the malathion spraying over cities in 1981 and 1982. Carey estimates that the light brown apple moth has been in California at least 30 years and perhaps 50 or more. For containing the moth, he recommends a program similar to one used to slow the gypsy moth on http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTLkitype=printable Page 2 of 5 Experts g�!estion plan to spray to fight moths 3/10/08 6:13 PM the East Coast and in the Midwest. He'd use more intense treatment, including some insecticides, to protect the Central Valley. Another UC Davis entomologist, Frank Zalom, an integrated pest management specialist who researches tree crops, fruits, vegetables and invasive species, says it's better to try to suppress - and not eradicate - the moth in urban areas. "Using pheromones over urban areas runs into expense and conflict," he said. "I think they should be considering other options." Overtime, natural predators will develop. "It wouldn't be too surprising that they jump over and start working on the light brown apple moth," though not necessarily controlling them, he said. UC Berkeley associate professor Miguel Altieri, who teaches agroecology in the department of environmental science, policy and management, agrees that "the fact that the moth is here doesn't mean devastation." In a global economy, there are going to be invasive pests, he said. Every one of them cannot be eradicated with a spray program. Pheromone called benign Larry Hawkins, a USDA spokesman, takes issue with entomologists who say that the light brown apple moth has been around for decades and that it can't be eradicated with a pheromone. Critics are willing to give up without trying, he said. "We're not grilling to give up. That's the difference. There has never been an opportunity like'this one to use a product as benign as a pheromone to eradicate a pest." The USDA's technical working group, composed of state and federal officials as well as scientists from other countries, made the decision to eradicate, saying the pest is a grievous threat and must be eliminated. The decision opened the way for federal funding. The state agricultural department has gone along with the decision. However, the working group may be willing to meet with entomologists who have useful data, Hawkins said. The light brown apple moth took up residence in New Zealand perhaps a century ago and is not considered a pest there, said entomologist Philippa Stevens, leader of the plant disease and insect group of HortResearch, a governmental science group in New Zealand. They find an occasional light brown apple moth on avocados, kiwis, apples, persimmons and citrus, among http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL&type=printable Page 3 of 5 Experts question plan to spray to fic)ht moths 3/10/08 6:13 PM other plants, she said in an interview. "Although it has been recorded on the crops, it is not a significant pest," said Stevens. No eradication measures have been taken against the moth, she said. A pheromone is used only to bait traps to monitor the presence of the insect, she said. In New Zealand, the moth is kept under control using natural enemies, insecticides and other measures, she said. "There's no reason to believe it's going,to be more of,a problem in California than any other native moth in the Tortricidae family," said the UC Santa Cruz Arboretum's Harder, who went to New Zealand to research the moth after he learned it was trapped in California.last year. Earwigs, birds and spiders will eat the pest, Harder said. The moth larvae "look like another tube of meat to them." To get involved Documents: Read California Department of Food and Agriculture documents on the proposed pesticide- spraying program at links.sfgate. com/ZCLW. Comments: Until March 20, send written comments to: Jim Rains, staff environmental scientist, California Department of Food and Agriculture Plant Health and Pest Prevention Services, 122o N St., Room A-316, Sacramento, CA 95814• The problem and meetings to go to Problem: The tiny moth has been trapped in the Bay Area, and its larvae have the potential of harming more than 200 types of fruit and vegetable crops. Eradication: Officials plan to spray a:pesticide over Bay Area cities to eradicate the moth by disturbing its mating. Spraying is expected to start Aug. 1. Spraying: A map of the proposed spraying in 2008: litzks.stgate.com/GCQI Public meetings -- Saturday, 10 a.m. to noon, office of La Voz Latina, TL Housing Clinic, 253 Hyde St., San Francisco -- Monday, 10 a.m., west steps of the Capitol in Sacramento for lobbying efforts sponsored by the nonprofits, among them Pesticide Watch and California Alliance to Stop the Spray. E-mail Jane Kay atjkayC{,stchz•o7iicle.coz7z. http://sfgate.com/cgi-bin/article.cgi?f=/c/a/2008/03/06/MN69VD309.DTL http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL6,type=printable Page 4 of 5 Experts question plan to spray to fight moths 3/10/08 6:13 PM 1. This article appeared on page A - 1 of the San Francisco Chronicle San Francisco Chronicle Sections Go ' Vic) 2008 Hearst Communications Inc. Privacy Policy Feedback I RSS Feeds 1 FAQ I Site Index Contact http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL&type=printable Page 5 of 5 s' RESOLUTION NO. NS-27,783 RESOLUTION OF THE CITY COUNCIL OF TiiE_, CITY OF SANTA CRUZ OPPOSING THE CALIFORNIA DEPARTMENT OF FOOD AND AGRICULTURE AERIAL, SPRAY PROGRAM TO ERADICATE THE i.,IGHT BROWN APPLE MOTH WHEREAS, the bight Brown Apple Moth (LBAM) is.a pest subject to Federal and State quarantine and eradication orders; and WHEREAS, there is a confirmed presence of Light Brown Apple Moths in Santa Cruz County; and WHEREAS, the California Department of Food and Agriculture (CDFA) plans to resume an LBAM aerial spraying program in Santa Cruz County and surrounding areas in spring of 2008; and WHEREAS, modern Integrated Pest Management (IPM) relies on least-toxic, environmentally sensitive control methods; and WHEREAS, the City of Santa Cruz IPM Policy, adopted in November of 1998, commits the City to "eliminate or reduce pesticide applications on City property to the maximum extent feasible"; and WHEREAS, least-toxic control options are available for LBAM, including physical and cultural practices such as clean-up of plant debris where moth larvae winter, use of natural predators, parasites, and insect diseases, introduction of sterile male moths, and use of pheromone sticky traps; and WHEREAS, aerial and other blanket pesticide applications repeatedly have been shown to upset natural ecosystem balance in unpredictable and often catastrophic ways; and WHEREAS, aerial and other blanket pesticide applications have been shown to cause unintended, unpredictable, and often serious human health effects; and WHEREAS, blanket spraying of chemicals is expensive and inefficient; and WHEREAS, the State has claimed an emergency exemption under the California Environmental Quality Act (CEQA) in order to begin the LBAM aerial spraying program without conducting environmental review because of this emergency exemption; and WHEREAS, the State has confirmed that it will begin preparation of an Environmental Impact Report after the aerial spraying program has begun; and WHEREAS, in the Edna Williams, et al. v. California Department of'Food and Agriculture case, biologists James Carey and Daniel Harder testified that aerial pesticide spraying.is extremely unlikely to eradicate LBAM; and RESOLUTION NO. NS-27,783 WHEREAS, biologists have testified that the range over which LBAM has been detected in California indicates that LBAM has been established in the state for some time; and WHEREAS, CDFA has stated that no physical crop damage has been attributed to LBAM; and WHEREAS, the risk of economic damage alone does not justify the health and environmental risks of aerial pesticide applications; and WHEREAS, the State has relied almost entirely on its own scientists to address public concerns about the LBAM spray program and has not employed independent outside experts to evaluate and support the program or address issues in a direct and impartial manner; and WHEREAS, the CDFA LBAM spraying program has used pesticides that an independent toxicologist's review stated have not been tested for long-terns human toxicity; and Wi-IEREAS, the CDFA LBAM spraying program is relying on pesticides that contain ingredients that are highly toxic to aquatic life; and WHEREAS, the CDFA LBAM program sprays pesticides in microscopic plastic capsules that pose unknown inhalation risks; and WHEREAS, the United State Department of Agriculture (USDA) maintains that the pheromone pesticide poses only "minimal risk to human health," but acknowledges that it is considered a"slight to moderate dermal irritant" and does present "some very low toxicity"; and WHEREAS; the USDA states that its risk: assessment assumes that the rate of exposure will be insignificant, with no dietary exposure from food and just a minimal amount of incidental exposure from drinking water or swimming; and WHEREAS, aerial spraying disproportionately affects vulnerable populations such as those who work and play outdoors, those with the recognized disability of multiple chemical sensitivity, and those in the homeless population who may have no option for protection from the spray or receipt of written notification of spray dates; and WHEREAS, LBAM aerial spraying in the Santa Cruz and Monterey areas resulted in the spraying of numerous residents and pets; and WHEREAS, hundreds of reports of health effects were reported following the LBAM aerial spraying in Santa Cruz and Monterey Counties; and WHEREAS, other environmental impacts were reported following the LBAM aerial spraying in the Monterey and Santa Cruz areas. RESOLUTION NO. NS-27,783 NOW, THEREFORE, BE ITRESOLVED by the City Council of the City of'Santa Cruz that it hereby opposes the CDFA aerial spray program to eradicate LBAM. BE IT FURTHER RESOLVED that the City Council requests that the CDFA protect the health and welfare of the residents and natural environment of Santa Cruz County by immediately shifting its LBAM control methods to least-toxic Integrated Pest Management methods such as those listed above, and shift its focus to educating the USDA regarding the lack of crop damage done by I,BAM, the need to use least-toxic control methods that do not expose Populated areas to aerial spraying, and the need to appropriately downgrade the pest classification of LBAM to reflect the lack of risk it poses. BE IT FURTIiER RESOLVED that the City Council requests that the State conduct a long- term study of the health and environmental effects resulting from the aerial spraying project that has been conducted to date in Monterey and Santa Cruz Counties, taking into account reports collected by citizens in the absence of an easily accessible method of reporting to the State. BE IT FURTHER RESOLVED that the City Council supports the introduction and passage of State legislation requiring: 1. explicit consent of affected residents before any aerial spraying program can be implemented; and 2. that only the Governor of the State of California will have the power to declare an emergency requiring the aerial spraying of any substance over populated areas and that any such declaration contain certain mandatory findings. Those findings must include, but not be limited to, a statement that the situation is a sudden and unexpected occurrence which is an immediate threat to life and property. PASSED AND ADOPTED this 12t" day of February, 2008, by the following vote: AYES: Councilmembers; Porter, Reilly, Rotkin, Madrigal, Vice Mayor Mathews; Mayor Coonerty. NOES: Councilmember Robinson. ABSENT: None. DISQUALIFIED: None. APPROVED: Mayor ATTEST: Acting City Clerk 3 L . Stewart Resnick, CEO Roll International ` • Listed on Forbes.com as one of the 300 largest private companies in the United States y • Los Angeles based conglomerate with ' companies in agribusiness, floral services and pesticide control products • Major political contributor with contributions to various candidates and political action groups including Arnold Schwarzenegger `i The leadEr it hiorattDr.�I `ust c.-mi rl: rc<�uct� n;a[urai P:�R.AN'1OQ.. l �. 11'.,�RVI t p.. .. P �...::.- t Mr. Resnick has developed and Suterra is a limited liability company that owns a number of successful manufactures pest control products one of which is companies including Paramount Checkmate to be used the proposed spraying for the .Agribusiness, the largest farming LBAM operation of treecrops in the world. i Wig N A1 ` . Y. Oil IL i . March 10,2008 -------------------- Dear Members of the Contra Costa County Board of Supervisors: I am writing to ask you to pass a resolution opposing the State of California's plan to spray aerial pesticide over densely populated counties in California in the vain hope of eradicating the Light Brown Apple Moth (LBAM).. I ask that you use your influence, informed by the research of respected scientists and citizens in California who have raised concerns about the effects of aerial pesticide spraying on human and environmental health. to initiate legal action against the State if necessary. i also ask that you work with the State of California and Secretary Kawamura to develop a comprehensive statewide plan for implementing pest control measures that have been tested prior to application, and have been deemed safe for people and the enviroii-ment based on the tenets of the Precautionary Principle. It is essential for the Contra Costa County Board of Supervisors to work with other local governments to oppose this spray program in order to protect the health of Bay Area residents, especially the most vulnerable populations including the very young, the elderly, and those with respiratory conditions and allergies. As the mother of two very young children, I am very concerned that the California Department of Food and Agriculture (CDFA) is spending public funds on a massive and deceptive public relations effort to promote this aerial spray program despite: • lack of long-term human toxicity testing of the chemicals being used • the known toxicity to aquatic life of ingredients in the pesticides • the unk=nown human health risks of the microscopic plastic capsules and `inert' ingredients that carry the pesticide • the unknown risks.to pets. honeybees, and beneficial predators that naturally keep pests— including LBAM — in check • more than 600 health complaints following spraying in fall 2007 in Santa Cruz and Monterey Counties • the fact that LRAM has not caused crop damage in California in the (at least) 10 years it has been documented here • the fact that LRAM, also an exotic species in New Zealand. is a minor pest there • biolooists' expert testimony that eradication has almost no chance of success • the availability of minimally toxic, environmentally-friendly control measures used for other similar"leaf roller"pests that are already present in California • massive public opposition to the spray program The City of Pacific Grove; the City and County of Santa Cruz; the Cities of Albany, Berkeley, and Oakland; and the Sierra Club have already passed resolutions opposing aerial spraying of Californians and calling-for a safer approach to controlling LBAM. Please join these leaders in communicating Contra Costa County's opposition to aerial spraying to state and federal officials. I Sincerely, Rita Gaber 200 Ramona Avenue El Cerrito, CA 94530 Parents for a Safer Environment. Steering Committee Member U.C. Berkeley PhD Candidate, Dept of Geography 0 r I� (n r, p cw m w o w co 00 00 00 o m Co co V m. Ul A A W N m O o ^ m z m m m m m p m p O p o p O p 2 0 p O 00 O D c O O Z M m e m m m m - m m - m m m � C X � m � � D m f � m m n � � ZGC7XnZXXZp � nOGZDZZO< nZm > 5Z � z - x 3 � a D D D R T D D = D D D D Z D = D D D D m = D m o m D D m D m m m Tr m r T m T r m m r T m T j r n r r n r Z m T r [ r G n Z o X � Zx zc_ xzZxc_ zc_ � XCxXC)_ � -n0co X m -i n C -n T C r m C•C.T r C r -n r -n -n r m -n T -n ..{ '� -n �' r[ rf -rG -i < _� =i < -< -< < < {. m < < � O cn r r r O v m D n Z v Z m > r W N N W r N N N W r N s r <D > m N r A r M r r N CO -s r m 100 -C. n 0 m c c z m NN r r r r r r r r M (� 0 o coo coo coo coo co co co coo I D 1 O CD 00 V 0) cn A W N m m m m m m m O O O O 0 O o O O O o o g O O o D DmXx > ffi mXDmm -Xx > mMM — X � ODmOm xm ,ZmlyD ;uL<> mm ,Zmj x C7 = D z z D D D D Z D Z D Z Z = D Z Z Cl) D D m D Z D Z D D Z Z = D D Z O c ZT] z c �1 c -n] c c �] A Z C m A z c A �J X A Z c c Z � c U A z Z �7 m m 0 -"� -n m m ,-!TJ T —I O -n � O � .0 r T ,"p m -I -i X r -n �7 C r m r m m r r m C r m T C r -n m T -n C r r C T� r -n -n C O + •[ r r -< r -< r r -< -< r r - fi r r -C r r r r � � - r e r r - L _` m � Z N N r r Ln N A ...• W N r r U7 A -+ CO r r r -� N N W N -+ -P. r te 0) N r 00 N W O C m 0to m cn 0 0 0 0 0 o ID O � O O O O O p r p N DDp 2 0 C-- --0 C- O - Z D O O C- O z m W m X c m > y X m C.A C O D m m x C -0 m x C m W mDDDmDmm = DDDDDOG7DDDDmD DD Q O O T'0 m c Z 0 c O m c c c z c c ;d :U c c co t C c '0 � m -n � � � � m nr _c -- W O n nm � r Tr -�I 1 O m � < � � mmm � -[ < � -{ gym = < r{ G � m < < � < O ,� < -n m m z m CD m z 4 r r M N W - r — r r r r A .p r --� W A W r -� Cn W N O IO °' Cmi -n m cn March 7, 2008 City of Richmond —CheckMate Spray for Light Brown Apple Moth Dr. Elisa Song of Belmont, CA, a pediatrician and expert on the deleterious effects of environmental toxins upon children believes that children will be harmed by the chemical components of the spray just described. Dr. Song bases this concern on the fact that the livers of children are underdeveloped and less capable than those of adults of detoxifying toxic chemicals that enter their bodies. Given the higher risk to children and the 640 sentinel incidences of disease following spraying in the Santa Cruz area, we conclude that spraying-with Checkmate LBAM—F should be abandoned in favor of a procedure that is more protective of human health. We have also considered the putative enhanced vulnerability of the citizens of Richmond to further chemical exposure when compared to inhabitants of cleaner urban environments. Our thinking is guided by two fundamental precepts, the precautionary principle and the need to implement environmental justice. The City of Richmond, historically known as the "industrial city", is burdened with toxic industrial chemicals released to the environment over the course of a century. It is imprudent to add more chemical components to the mix since we have no idea how they may interact to.heighten illness and environmental damage. Richmond residents are also exposed to environmental toxins on an ongoing basis and may therefore be more vulnerable to the health effects of components of CheckMateLBAM-P than residents of cleaner urban environments. Exposing Richmond residents to additional putative toxins is a violation of environmental justice. Many of our residents, including communities of color and others, cannot afford routine medical care and have untreated illnesses that may increase their vulnerability to toxic environmental agents. In conclusion we favor a moratorium on Spraying with CheckMatcLBAM-F until its health effects have been completely assessed, and the use of other moth control methods have been compared and evaluated. Sincerely yours, Michael S. Esposito, Ph.D. Carolyn Graves Stephen Linsley Andrew Mayes Sherry B. Padgett Joseph Robinson Jean Rabovsky, Ph.D. Copy: Richmond City Council Members Richmond Southeast Shoreline Area Community Advisory Group Members Page 2 of 2 March 7, 2008 Mayor Gayle McLaughlin Temporary City Hall 1401 Marina Way South Richmond, CA 94804 Dear Mayor McLaughlin: In response to your request, members of the Richmond Southeast Shoreline Area(RSSA) Community Advisory Group (CAG) Toxics Committee (Tox Com) have studied the issue of spraying with CheckMateLBAM-F to control the spread of the light brown apple moth. We recognize that this matter is not solely relevant to the RSSA but involves the entire City of Richmond and its inhabitants. Moreover, in order to clarify our perceived role in responding to your request we are acting as a group of concerned private citizens with relevant expertise, not in our capacity as members of the RSSA CAG 'Fox Com. To emphasize this distinction our report is printed on common bond and no RSSA CAG funds were expended in its preparation. Our literature review revealed that there are at least five methods to control the spread of moths: 1) Release of sterile males that impregnate females resulting in dead embryos 2) Release of stingless wasps that prey upon moths 3) Use of bacteria that infect moth eggs, 4) Baiting of traps with moth pheromone 5) Aerial spraying with CheckMateLBAM-F containing moth pheromone encapsulated in microscopic plastic capsules. Spraying with Checkmate was done in the Santa Cruz area last year. Approximately 640 residents became ill, apparently due to exposure to the spray. This has drawn the attention of the public to the putative health hazard of CheckMateLBAM-F. The spray contains the pheromone in small plastic particles that can be inhaled and which are implicated in respiratory difficulties. The plastic particles are suspended in a mixture of butylated hydroxytoluene, tricaprytmethyl ammonium chloride, polyvinyl alcohol, sodium phosphate and 1,2-benzisothiazolin-3-one. The latter is a bactericide that is harmful to mammals including humans. The CheckMate formulation is in the form of microcapsules, and aerial spraying may result in the inhalation of these particles by human and ecologic receptors in the path of the spray. Microcapsules less than 10 microns can enter the deep lung and may cause damage to the gas exchange area and also systemic toxicity. Particles greater than 10 microns should not enter the deep lung but can remain in the upper respiratory tract where nose and throat irritation may occur. Such large particles may also be coughed up and forced into the gastrointestinal tract. In the absence of information about the size distribution of the microcapsules as well as their stability in biological fluids, a precautionary approach would be advisable to prevent unnecessary exposure to the airborne microcapsules. i i on illness complaints would be needed to begin to properly address the.question of causality. 8 polyurea shell exists only as a component of the particles, and makes up only a small percentage of the particle weight. • The toxicological information on the Checkmate product indicates that exposure to high levels of the applied material would be consistent with many of the reported symptoms. However, because the application rate was extremely low, it is likely that exposure occurred at levels below those that would be expected to result in health effects. Recommendations to CDFA (Note: Some of these recommendations may already have been implemented.) • In describing the long history of safe use of lepidopteran pheromone products, care should be taken to indicate clearly that most of this use involved pheromone dispensers (for example, twist ties) and aerial application over agricultural areas. • The outreach program should better explain the rationale behind the choice of specific eradication methods. • A credible and trusted mechanism for collecting symptom complaints from people in the eradication zone should be established. • The eradication program should have a public notification and education component that encourages residents to consult doctors about symptoms that they attribute to pesticide exposure and to remind their doctors that California law requires doctors to report pesticide illnesses. These official records can be used.in follow-up investigations by local and State health and agricultural staff to identify adverse health reactions from particular pesticide formulations or application techniques. • Prior to spraying,the State should work with local health officersto ensure that physicians and other health care providers are given information on the application; what, if any, symptoms are likely to be seen; and how to report, among others. In general, the physicians and health care providers should be informed of the illness reporting requirements and should receive training on pesticide poisoning recognition and management. • Air sampling should be considered to investigate the contribution of the aerially released microcapsule particles to the overall ambient air particulate load. • A formalized plan to address the above recommendations should be in place prior to spraying. • A well designed formalized study and tracking program that looks at a number of factors including, but not limited to both long- and short-term health outcomes, exposed and unexposed persons,the potential effects of stress and outreach methods 7 Y However, additional data clarified that the exposure occurred on September 11. DPR's surveillance system, like others, under detects pesticide illnesses for various reasons, including that pesticide illnesses may mimic other illnesses and that physicians and patients may not ascribe symptoms to pesticide exposure. The California Environmental Protection Agency (Cal/EPA) received a compilation of e- mails from area citizens with complaints of adverse reactions to the aerial spraying of Checkmate from September 9 to 12, 2007. Although it is likely that we do'not have complete reporting of all health complaints attributed to spraying, certain patterns do emerge from the information we have. Upper respiratory symptoms, including cough, sore throat, runny nose, and congestion were the predominant complaints. Also frequently reported were headaches, itchy eyes, nose, and throat; shortness of breath; muscle aches; diarrhea; and fatigue. Most reported symptoms are consistent with inhalation of a nonspecific irritant material, but because they are also consistent with other possible causes, it is not possible to confirm the symptoms are or are not due to the application of Checkmate. For example, some of the symptoms are consistent with infectious or allergic conditions or other health effects not caused by exposure to Checkmate. Based on the available toxicological information on the Checkmate product, some of the reported health effects such as eye, skin, or respiratory irritation-could be consistent with inhalation of a sufficient amount of the applied material. But because the measurements confirm the application rate was extremely low, it is likely that exposure occurred at levels below those that would be expected to result in health effects. However, because not all health effects'can be predicted and because the general population includes susceptible populations, such as children,the elderly, and those with chronic diseases, we cannot provide a definitive cause for their symptoms. A well designed formalized study and tracking program that looks at several factors including, but not limited to both long- and short-term health outcomes, exposed and unexposed persons, the potential effects of stress and outreach methods on illness complaints would be needed to begin to properly address the question,.of causality. Conclusions • The toxicity data on the pheromone active ingredients as well as on microencapsulated pheromone product formulations suggest that exposure to a high dose of airborne Checkmate microcapsule particles could cause eye, skin, or respiratory irritation. • The application rates were extremely low. Measured deposition rates fell below the proposed rate of 20 grams A.I. per acre. • . Public concern has centered on the previously undisclosed inert ingredients, which have now been disclosed. The bulk of the inerts is water,as the microencapsulated polyurea particles consist primarily of the pheromone active ingredients. The 6 composition) is inhaled, it is plausible that it,;ould cause irritation of the throat, coughing, sneezing, and excess mucus production in the upper respiratory system. Taken together, the toxicity data on the pheromones and on microencapsulated products suggest the possibility that exposure to a sufficient amount of airborne Checkmate microcapsule particles could result in some level of eye, skin, or respiratory irritation. However, as the product is diluted and applied over a large area, the degree of exposure as well as the potential for irritation should decrease significantly. Application and Deposition The maximum application rates allowed by the label are 20 grams of A.I. per acre per application, corresponding to 83 grams per acre of the Checkmate product. These application rates are very low, both in absolute terms and when compared with the ground or aerial application rates of almost any other pesticide. To put this amount in perspective, a tablespoon of sugar weighs almost 20 grams. The product consists primarily of the polyurea-microencapsulated pheromone suspended in water. The material applied is a diluted mixture thaticontains 2.1%A.I. (pheromone). Tank samples collected during the first week of application showed concentrations of the A.I. varied from 0.69%to 3.0%, indicating settlin might have occurred in the mixture. Some visual observations also indicated a problem with the product staying well mixed in the application equipment. Changes are being made to the mixing and loading equipment to address this problem in future applications. At the highest proposed application rate, the theoretical concentration of the product hitting the ground should be 0.460 milligrams A.I./square foot. During the first week of application, deposition measurements showed deposition rates below this calculated theoretical maximum. (These data will be available later.) This indicates there were not"pockets"of higher than intended deposition resulting from the tank concentration variations. Illness Complaints Before the current LBAM eradication effort, ]'SPR had received few complaints involving pheromones, and has no persuasive cases on rile attributed to pheromone exposure in the absence of additional pesticides. DPR evaluated two cases, one in 1982 and one in 1989, as"unlikely"to be related to exposure to pheromone alone or to pheromone with an adjuvant. Another 1982 case provided insufficient information to evaluate. These cases did not involve Checkmate products. California law requires physicians to report known or suspected pesticide-related illnesses to their local health department within 24 hours after seeing a patient. The health department forwards these.reports to the State:: Only one pesticide illness report (PIR) was received from the Monterey County Health Department during or soon after the Checkmate spraying September 9-12, 2007. A, 57-year old man was diagnosed with pharyngeal irritation after visiting a doctor onr September 16. The.exposure date was listed as September 16, which was after the Checkmate spraying had been completed. 5 i 1' 9) Polyvinyl alcohol- polymer commonly used in shampoos and cosmetics, feminine hygiene and incontinence products, children's play putty, glue, lubrication drops for hard contact lens wearers and other products. 10)Tricaprylyl methyl ammonium chloride- commonly used in the manufacture of various pesticides and pharmaceuticals; contributes to product purity. 1 1)Sodium Phosphate- naturally occurring substance. Sodium phosphate is also an additive in egg products and is a prescribed laxative prior to procedures such as colonoscopy. The percentages of these ingredients are still confidential business information. This document does not review the toxicity of these compounds individually, but addresses the formulated product. While this.information is important, DPR noted that inert ingredients other than water are present in very small amounts and exist primarily as the polyurea shell enclosing the pheromones. These particles consist mostly of pheromones. After application of the particles,the pheromones are slowly emitted over a 30-to 90-day period, and the polyurea shell will biodegrade into urea, a low toxicity compound normally found as a result of the breakdown of proteins in the human body. Another important point is that DPR scientists have reviewed the most relevant data: toxicity studies on the formulated product as a whole. DPR scientists reviewed an acute dermal toxicity study using Checkmate PBW-F, which uses the same microencapsulation as Checkmate OLR-F and LBAM-F. The primary difference is in the selection of pheromones contained within the microencapsulated particles. In the study of Checkmate PBW-F, 2,000 mg/kg was applied to the skin of rabbits and resulted in no mortality, but some diarrhea. The results led to a Category III rating for dermal toxicity. Similarly, an eye irritation study in rabbits, in which 100 mg doses were instilled in the eyes, led to a Category III rating for eye irritation,.which means the product was moderately irritating. Materials that cause eye and skin invitation could reasonably be expected to cause some respiratory irritation if a sufficient amount were inhaled. The animal study results are consistent with the Suterra Checkmate OLR-F and LBAM-F labels that state that the products cause moderate eye and skin irritation. This label designation is for the undiluted product rather than for the significantly diluted water suspension that is actually applied. The microcapsule particles are very large by inhalation standards (25 micrometers in diameter or larger) and unable to reach the deep lung. As a result, an inhalation toxicity study, which is designed to examine systemic effects resulting from inhalation into the lung, would not be useful and was not conducted. If inhaled, because of the large size, these microcapsules are not likely to reach the pulmonary (air exchange) region of the lung. However, such large particles are likely to be deposited in the nasal passages, pharynx, larynx, and tracheo-bronchial region and are either absorbed or moved to the larynx and swallowed. If a sufficient amount of large particles (regardless'of 4 safety record for lepidopteran pheromones has allowed the Agency to conclude that consumption of food containing residues of the pheromones presents no risk. ... Adverse effects on non target organisms (mammals, birds, and aquatic organisms) are not expected because these pheromones are released in very small amounts to the environment and act on a select group of inse.cts." This statement refers primarily to the pheromone active ingredients generally used in emitter devices or aerial application over agricultural areas rather than aerial application over populated areas (such as in the present situation). Toxicity Information on the Product Formulations Used to Combat LBAM Besides the A.I.s, a product formulation consists of"inert ingredients" that are in the formulation to improve performance, as a manufacturing byproduct, as a diluent, or as a reactant from the manufacturing process. The LBAM pheromone products are available in three formulation types. Each formulation combines the pheromones with materials that release it into the atmosphere slowly, so that the products remain active for a period of time. The dispenser formulation (also referred to as twist-tie) consists of a plastic tube containing the active ingredients. The plastic tube is attached to the target plants, slowly emitting the pheromones. This product has been used extensively in Australia and New Zealand to combat LBAM. Another formulation is a flake (Disrupt Micro-Flake) made up primarily of the A.I.s, a rigid plastic film, and resins. Micro-Tac or Micro-Tac II (adjuvants) may be used with the Micro-Flake to aid in adhesion to foliage. Checkmate OLR-F and Checkmate LBAM-F are microencapsulated forms. Both Micro-Flake and Checkmate products are approved for either ground or aerial application. Much attention and controversy has centered on the identification and potential toxicity of the individual inert ingredients in the Checkmate OLR-F and LBAM-F products; however, the identity of the inert ingredients has recently been made public. In a recent letter to Assemblymember John Laird from CDFA Secretary A. G. Kawamura, all the ingredients in Checkmate LBAM-F are identified as: 1) Water, the main ingredient. 2) (E)-1 I tetradecen-1-yl acetate- the pheromone. 3) (E, E)-9,11 tetradecadien-I-yl acetate- the pheromone. 4) Ammonium phosphate- commonly used in "crystal growing" kits for children and as a plant nutrient. 5) 1,2-benzisothiazol-3-one- used as antibacl;erial and antifungal agents in a variety of products. 6) 2-hydroxy-4-n-octyloxybenzophenone- used in sunscreen and in lots of products made of plastics, including food containers; useful for its UV-blocking properties. 7) Cross linked polyurea polymer- commonly used in manufacturing of plastics such as polyurethane foam production, waterproo ling, insulation, and micro encapsulation agent for pesticides. 8) Butylated Hydroxytoluene- common food preservative. 3 Active ingredients (A.I.$) are the chemicals in a pesticide product that are effective against the targeted pest. The various products being proposed for use on LBAM contain similar active ingredients in different combinations and ratios. Checkmate OLR-F contains the pheromones (E)-11-tetradecen-1-yl acetate and (Z)-I 1-tetradecen-I-yl acetate. Checkmate LBAM-F contains the pheromones (E)-11-tetradecen-I-yl acetate and (E, E)-9,11-tetradecen-1-yl acetate. It is the choice of these chemicals and their ratios that results in the specific mating disruption activity for LBAM. Checkmate OLR-F targets the Omnivorous Leaf Roller but also has activity with the LBAM and was used in the first aerial applications in Monterey. Checkmate LBAM-F more specifically targets the LBAM and the California Department of Food and Agriculture (CDFA) has indicated that it will be used in future aerial applications. DPR and OEHHA scientists have not reviewed toxicity studies on all the specific active ingredients in LBAM pheromone products; however,they have reviewed acute toxicity studies on other lepidopteran pheromones, and according to the USEPA determination, these studies can be considered to apply to any lepidopteran pheromone. These studies show very low acute oral and dermal toxicity. As an initial screen, toxicologists describe acute toxicity by the LD50, the dose that kills half the test animals. The pheromone studies used extremely high dosages, but did not kill any animals. Consequently, scientists cannot determine the LD50, but can conclude that it is larger thanthe doses used. An oral toxicity study in rats produced no mortality and no toxic signs at a-dosage of 5,000 mg/kg. Thus,the oral LD50 is> 5,000 mg/kg,placing it in Category IV for oral toxicity. (These U.S. EPA-derived toxicity categories are used to select the appropriate signal words to alert users to specific hazards and can also be used to compare the acute toxicity of different chemicals. The categories include Category I- High Toxicity, Category II- Moderate Toxicity, Category III- Low Toxicity, and Category. IV- Very Low Toxicity). In a rabbit dermal toxicity study using a single dose of 2,000 mg/kg, there was some diarrhea but no mortality. Thus the dermal LD50 is>2,000 mg/kg, placing it in Category III for dermal toxicity. Eye and skin irritation studies indicated the potential for mild to moderate skin and eye irritation (Category III). A study on a chemical similar to one of the active ingredients in the LBAM pheromone does indicate some potential for limited dermal sensitization (Category III), while other studies reviewed by USEPA did not indicate dermal sensitization. The maximum application rates for lepidopteran pheromone products range from 15 to 37.5 grams (about 0.5 to 1.3 ounces) of A.I. per acre per application and a total of 150 grams(about 5 ounces) of A.I. per acre per year. These are very low application rates compared with the dose levels used in the above studies. Chronic toxicity is not addressed in this document because there will not be long- term exposure to the pheromone product. After reviewing the toxicological data of SCLPs, scientists at the USEPA concluded that "Based on low toxicity in animal testing, and expected low exposures to humans, no risk to human health is expected from the use of these pheromones. During more than 10 years of use of lepidopteran pheromones, no adverse effects have been reported. ... The 2 Consensus Statement on Human Health Aspects of the Aerial Application of Microencapsulated Pheromones to Combat the Light Brown Apple Moth October:31, 2007 This document represents a scientific consensus of the Department of Pesticide Regulation (DPR) and the Office of Environmental Health Hazard Assessment (OEHHA) on the available health and safety data of the pheromone products associated with the Light Brown Apple Moth (LBAM) eradication;program. This is one of the first instances of the aerial application of this material over a highly populated area. Scientists from DPR and OEHHA reviewed the available information and prepared this document with input from the Department of Public Health. This document is not intended to be a detailed human health risk assessment, an epidemiological study of exposed individuals, or an evaluation of occupational exposure.The purpose of this document is to provide information on the toxicity of microencapsukited pheromones, the potential for exposure, and to provide recommendations. General Information Pheromones are naturally occurring volatile chemicals and have been loosely described as"pheromone perfumes." Certain insect species produce them, in very small amounts, to influence the behavior of other individuals of the same species. Many lepidopteran species (butterflies and moths) use pheromones to attract mates. These pheromones consist of mixtures of similar chemicals, and the relative amounts of several pheromone chemicals determine which specific moths are attracted. Synthetically produced pheromones can be used to control insect pests. All the lepidopteran pheromones approved for pest control use are chemicals produced by female moths to attract mates. By releasing a specific pheromone mixture into the air, it is possible to disorient males looking for females. The pheromone alters behavior, not the insects' health or reproductive competence; but it results in many females' failure to mate and lay eggs. Pheromone pesticide products may be applied using slow-release dispensers (often attached to trees) or applied by ground or aerial spray equipment. Toxicity Information on the Pheromone Active Ingredients in the Products Used to Combat LBAM The U. S. Environmental Protection Agency (U.S. EPA) defines lepidopteran pheromones chemically as unbranched aliphatic chains (9 to 18 carbon atoms) ending in an alcohol, aldehyde, or acetate functional group and containing up to 3 double bonds in the chain. U.S. EPA has also made two relevant determinations about these chemicals: 1) that they are sufficiently similar toxicologically to be considered as a group, that is, toxicology data on one pheromone is applicable to the other pheromones; and 2)that their toxicity is so minor that they are exempt from the requirement of a tolerance (Federal Register 60, No. 168, pp 45060 to 45062, August 30, 1995). These pheromones are often referred to as Straight Chained Lepidopteran Pheromones (SCLPs). 1 dpr ....... ... . . . . ... . Arnold Schwarzenegger Govemor November 16,2007 Ms.Linda Adams, Secretary Cal ifornia.Environmental Protection.-Agency Ms. Kim Belshe;Secretary California Health and Human Services Agency. Mr. A.G. Kawamura, Secretary California Department of Food and Agriculture Dear Secretaries: In September 2007,the California Department of Food and Agriculture(CDFA) initiated a program to eradicate an infestation of the Light Brown Apple Moth(LRAM) in Monterey County which involved the aerial application of a pheromone, Checkmate. A number of health complaints from people in the treatment area were brought to the attention of the California Environmental Protection Agency(Cal/EPA), CDFA, and the Department of Public Health (DPH). We directed our staffs, in cooperation with DPH,to conduct an evaluation of the complaints and the potential health effects that might be associated with the pheromone. The attached document represents a scientific consensus of the Department of Pesticide Regulation(DPR) and the Office of Environmental Health Hazard Assessment(OEHHA)on the available health and safety data of the pheromone products associated with the LBAM eradication program. This is one of the first instances of an aerial application of this material over a highly populated area. DPR and OEHHA scientists reviewed the available information and prepared this document with DPH input.It is not intended to be a detailed human-health risk assessment,an epidemiological study of exposed individuals, or an evaluation of occupational exposure. Its purpose is to provide information on the toxicity of microencapsulated pheromones and the potential for exposure, and to provide recommendations. In summary, the toxicity data on the pheromone active ingredients, as well as on microencapsulated pheromone product formulations, suggest that exposure to a high dose of airborne Checkmate microcapsuleparticles could cause eye, skin, or respiratory irritation. The application rates were extremely low, and it is likely that exposure occurred at levels below those that would be expected to result in health effects. Measured deposition rates fell below the proposed rate of 20 grams active ingredient per acre. ss Departments of the California Environmental Protection Agency WPnnted on recycled paper,100%post-consumer—processed chlodne-hee. Ms. Linda Adams Ms. Kim Belshe Mr. A.G.Kawamura November 16, 2007 Page 2 Public concern has centered on the previously undisclosed inert ingredients,which have now been disclosed. Water is the bulk of the inert ingredients, as the microencapsulated polyurea particles consist primarily of:the pheromone'ac:;tive ingredients. The polyurea shell exists only as a component of the particles,and makes up only a small percentage of the particle weight. While the toxicological information on the Checkmate product indicates that exposure to high levels of the applied material would be consistent with many of the reported symptoms,the application rate was extremely low, and it is likely that exposure occurred at levels below those that would be expected to result in health effects. Based on their review, staff have included recommendations to address the health complaints received from this program. A series of actions to ensure proper collection, review, and coordination of health complaints is also recommended. Air sampling should be considered to investigate the contribution of the aerially released microcapsule particles to the overall ambient air particulate load.Af well-designed, formalized study and tracking program that looks at a number of factors including, but not limited to,both long-and short-term health outcomes, exposed and unexposed persons,the potential effects of stress, and outreach methods on illness complaints would be needed to begin to properily address the question of causality. Many of these recommendations have been implemented or are under development. The remainder will involve the coordination among the three agencies. If you have further questions,please do not hesitate to contact us. Sincerely, original signed by original signed by Mary-Ann Warmerdam,Director Joan Denton, Director Department of Pesticide Regulation Office of Environmental (916)445-4000 Health Hazard Assessment (916) 322-6325 Attachment cc: Mr. Allan Hirsch, OEHHA Chief Deputy Director(w/Attachment) Mr. Chris Reardon, DPR Legislative Director(w/Attachment) y _ dapr Arnold Schwarzenegger Govemor November 16, 2007 Ms. Linda Adams, Secretary California Environmental Protection.Agency. Ms. Kim Belshe, Secretary California Health and Human Services Agency Mr. A.G. Kawamura, Secretary California Department of Food and Agriculture Dear Secretaries: In September 2007, the California Department of Food and Agriculture(CDFA) initiated a . program to eradicate an infestation of the Light Brown Apple Moth(LBAM)in Monterey County which involved the aerial application of a pheromone, Checkmate. A number of health complaints from people in the treatment area were brought to the attention of the California Environmental Protection Agency(Cal/EPA), CDFA, and the Department of Public Health (DPH). We directed our staffs, in cooperation with DPH,to conduct an evaluation of the complaints and the potential health effects that might be associated with the pheromone. The attached document represents a scientific consensus of the Department of Pesticide Regulation (DPR) and the Office of Environmental Health Hazard Assessment(OEHHA) on the available health and safety data of the pheromone products associated with the LBAM eradication program. This is one of the first instances of an aerial application of this material over a highly populated area. DPR and OEHHA scientists reviewed the available information and prepared this document with DPH input. It is not intended to be a detailed human=health risk assessment,an epidemiological study of exposed individuals, or an evaluation of occupational exposure. Its purpose is to provide information on the toxicity of microencapsulated pheromones and the potential for exposure, and to provide recommendations. In summary, the toxicity data on the pheromone active ingredients;;as well as bn microencapsulated pheromone product formulations, suggest that exposure to.a high dose of airborne Checkmate microcapsule particles could cause eye, skin, or respiratory irritation. The application rates were extremely low, and it is likely that exposure occurred at levels below those that would be expected to result in health effects. Measured deposition rates fell below the proposed rate of 20 grams active ingredient per acre. Departments of the California Environmental Protection Agency IV Ainled on recycled paper,1001%post-consumer—processed chlorine-free. Ms. Linda Adams Ms. Kim Belshe Mr. A.G. Kawamura November 16, 2007 Page 2 Public concern has centered on the previously undisclosed inert ingredients,which have now been disclosed. Water is the bulk of the inert ingredients, as the microencapsulated polyurea particles consist primarily of the pheromone'active ingredients.The polyurea shell exists only as a component of the particles, and makes up only a small percentage of the particle weight. While the toxicological information on the Checkmate product indicates that exposure to high levels of the applied material would be consistent with rnany of the reported symptoms, the application rate was extremely low, and it is likely that exposure occurred at levels below those that would be expected to result in health effects. Based on their review, staff have included recommendations to address the health complaints received from this program.A series of actions to ensure proper collection, review, and coordination of health complaints is also recornmended. Air sampling should be considered to investigate the contribution of the aerially released microcapsule particles to the overall ambient air particulate load.A well-designed, formalized study and tracking program that looks at a number of factors including,but not limited to,both long-and short-term health outcomes, exposed and unexposed persons,the potential effects of stress, and outreach methods on illness complaints would be needed to begin to properly address the question of causality. Many of these recommendations have been implemented or are under development. The remainder will involve the coordination among the three agencies. If you have further questions, please do not hesitate to contact us. Sincerely, original signed by original signed by Mary-Ann Warmerdam,Director Joan Denton, Director Department of Pesticide Regulation Office of Environmental (916)445-4000 Health Hazard Assessment (916) 322-6325 Attachment cc: Mr. Allan Hirsch, OEHHA Chief Deputy Director(w/Attachment) Mr. Chris Reardon, DPR Legislative Director(w/Attachment) cdt'] CALIFORNIA DEPARImENT O' u x �. FUUU E AGRICULTURE 2008 Light Brown Apple Moth (LBAM) Program Questions aiid A rr s wers What are you doing differently than you were doing last time? And n hv? W'di the advent of neve tools. the California Department of food and Agriculture (CDFA) and the United State Department of*Agriculture (USDA) have developed treatment prograrns for three categories of infestations and are ready to move torNvard and treat: I. Physically small. isolated infestations with a few moths trapped, ?. Physically larger infestations with several contiQ.uous square miles infested and more moths trapped, and 3. The physically largest infestations covering many contiVuous square miles and the greatest number of�rnoths trapped. This approach allows C'DFA.,IUSDA to operationally select a set oftools that will reach all the taroet LRAM life sta�.;es within each treatment area. Are you using the same substance as aerial spraying? The active material is the same--LBAM pheromone. The carrier may be different based on tests being.: conducted in New Zealand. "these products are being evaluated for i:fficac}'. lon�,,evity and ease of applications. Why are you changing the treatment material; noNv? Dons it mean last time it was not effective? There are three additional pheromone formulated products now available that were not available last year. C'DFAr"USDA etre evaluating them. along with last year's formulation. to determine which is the best carrier to lengthen the interval between treatments. The active material in the aerial treatment is the same LBAM pheromone used in 2007. So is the new aerial product an insecticide/pesticide? The new product will be a pesticide, but like last time, it does not kill the moth. The products under consideration for aerial treatment contain the same pheromone but use dillere:nt bio-deeradable.carriers. Because the use of this product is intended to eliminate a population, the United States Environmental Protection Agency requires the product to be registered as a pesticide, however technically the product will not kill the LRAM. In contrast. C DFA/USDA uses the same product as lures in the traps. but because the intended use is to attract the moth to the trap, it does not, under these circumstances, need to be registered as a pesticide. Should the public be concerned about their health and safety? Public safety is our primary concern. Pheromones are extremely safe and if persons believe they have experienced sickness as a result of the pending treatments, they are advised to see their doctor. State agencies (L)PR, OEHHA) with jurisdiction for public health produced a Consensus Statement that evaluated the complaints and found "it is likely that exposure occurred at levels below those that would be expected to result in health effects." All the research shows the moth pheromone ;is non-toxic to plants, animals and insects. It doesn't even hurt the moth. Any new products must meet rigorous standards for public health and safety. The pheromone materials CDFA/USDA use have been registered and approved for aerial treatment by the federal Environmental Protection Agency (EPA) and the state Department of Pesticide Regulation (DPR). Before registration, all product uses must pass a rigorous safety review to protect human health, wildlife, and the environment. This pheromone and many others like it are present in our environment every day as many insects use them to attract mating partners or signal other behaviors. Humans and other mammals do not use these: insect pheromones and cannot detect them. Does this new program pose any risks? Public safety is the primary concern. Any new products must meet the same rigorous standards for public health and safety as the old product did. White paper consensus statement on human health aspects of the aerial application of pheromones to combat the LBAM (Oct. 31, 2007, DPR/OEHHA/DPH): "While the toxicological information on the Checkmate product indicates that exposu,ce to high levels of the applied material would be consistent with many of the reported symptoms, the application rate was extremely low, and it is likely that exposure occurred at levels below those that would be expected to result in health effects." There were reports of illness even when yc,u were using the "benign" program,what about now? All health complaints are reviewed and monitored by the appropriate agencies to determine if there is a risk to public health. If a resident believes they are ill, they should see their health care provider. What do you plan to do differently to communicate to the general public regarding health concerns, pets, property,etc? We will focus our efforts to provide the public with the information needed to understand this program clearly, including open communication with public officials, the media and individual Californians through meetings, mailings, hotlines, the CDFA web site and other means. 2 Posted 1/25/2008 J Is it important enough to take funding away from other state programs when our state is already strapped, for example, education? No different than previous years, the program must compete for funding. Why don't you use ground application all the time? Given the size of the treatment area, ground application is not logistically feasible in terms of biological effectiveness in all situations. Ground application will be used in situations where CDFA/USDA can get the material to the targeted moth life stage. This is not possible in the heaviest and physically largest infestations where only aerial treatments of the pheromone will be biologically effective. People obviously don't want this program,why do you continue to push it when we don't see any of the negative effects? One would not expect to see negative effects in the early stages of a new pest introduction. The bottom line is that the establishment of LBAM threatens the life systems of California and the United States. The goal of the program is to be proactive and eradicate the problem before it becomes too large to eradicate and extensive damage occurs. Where is the emergency and urgency to this? If the insect is not eradicated while the infestation is still small, CDFA/USDA will be forced to deal with increased pesticide use, plant and environmental damage and potentially, quarantines forever. This insect will become a permanent unwanted resident , in California and the rest of the United States. Can we see any visible damage? Damage is hard to find, though some can be detected on foliage in the infested area. CDFA/USDA is being proactive to eradicate the pest before extensive damage occurs. Why are you coming back and spraying again? The first aerial treatments were never expected to eradicate the LBAM from the state and eradication of the pest has not been completed. The mating disruption approach will not kill the moth as would be expected if CDFA/USDA would have used heavy pesticides. Since the aerial treatments do not kill the moth, it will take multiple treatments to gradually eradicate the pest. How long will it take to eradicate LBAM? The program will probably take at least 3-5 years. Remember, the program is based on mating disruption using a pheromone. It will take longer to eradicate the moth by this means. A traditional pesticide might have been a quicker approach, but the environmental and public health concerns would have been much greater. 3 Posted 1/25/2008 How do you guarantee accurate application of the products when there have been mishaps before? Public safety is the primary concern. CDFA.fLJSDA continually monitors each and every treatment to ensure that all program requirements are met. The airplanes are equipped with a GPS system to keep treatments on tar;;et. CDFA/USDA also deploy an environmental monitoring system to make sure the treatment only occurs during appropriate weather conditions and is effectively deliver within the treatment zone. Why are you looking to New Zealand to help solve the problem when it's not eradicated there? Researchers in New Zealand and Australia have the most expertise with dealing with the moth and they are developing the.tools that (';DFA/USDA will use here. The moth is native to Australia and it invaded New Zealand years ago. In both countries the moth is too widespread to eradicate and they now use;pesticide sprays to live with it. CDFA/USDA wants to prevent this from happening here. How do twist ties and aerial treatments work? The twist ties and aerial pheromone treatments disrupt the communication between the moths, preventing the males from finding females. How does male moth attractant technique work? The male moth attractant technique will be applied at approximate 8 feet high on utility poles and trees in the treatment area. The male moths are attracted to the spot where they crawl over a contact insecticide and perish. How do the stingless wasps work? The stingless Trichogramma wasps look for and lay their eggs in LBAM eggs. The wasp larvae hatch and eat the LBAM egg from the inside. These wasps will not bother the over-wintering monarch butterflies and they will not be released near threatened or endangered plants or butterflies and moths. The wasps are among the smallest members of the insect world—smaller than a grain of rice. Trichogramma wasps occur naturally in almost every terrestrial habitat and some aquatic habitats as well. Some of the most important caterpillar pests of field crops, forests, and fruit and nut trees are attacked by Trichogramma wasps. However, in most crop production systems, the number of caterpillar eggs destroyed by native populations of Trichogramma is not sufficient to prevent the pest from reaching damaging levels. That is why the wasps must be used in conjunction with other approaches in order to achieve eradication of LBAM. 4 Posted 1/25/2008 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. Isn't bird die-off connected to the pheromone treatment? No. The Department of Fish and Game investigated the die-off and stated "It turns out it's not a fish oil or vegetable oil product, as well as not being a petroleum oil or the light brown apple moth spray. " The pheromone products CDFA/USDA uses are of very low toxicity to birds and wild life. We've heard that the increase in "Red Tide" algae growth in the Monterey Bay is attributed to the pheromone. There is no evidence that the product caused these naturally occurring algal growths. Department of Fish and Game stated that "red tide" is a naturally occurring regular event. Do you plan to do water monitoring in 2008? The CDFA Secretary's Environmental Advisory Task Force recommended a pilot water monitoring study which the department will implement. Why should 1/the public care about eradication of the moth? Why can't we just spray agriculture and not urban dwellers? We all live in a life system. If we don't fight the moth now, its'population could explode with time resulting in increased pesticide load, not only in agriculture, but urban areas. CDFA/USDA knows this from past experience with pest infestations and the public's use of unrestricted insecticides. Further, more insecticide use later will result in unhealthy residuals on fruits and vegetables that the consumer ultimately eats. Have moth pheromones been used before? Where? Moth pheromones designed to create mating disruption have been applied aerially in the US for about 10 years against invasive moth infestations in Florida, Texas, Arizona, Oregon, Washington,New York, Pennsylvania, Illinois, Wisconsin and Michigan. Moth pheromone has also been applied aerially in South Africa, Argentina, Chile,Italy and Spain. Pheromone treatments in general have an excellent track record against moths and other insect pests. Pheromones are a reliable method of treatment to control LBAM in New Zealand and Australia. .LBAM is also present in Hawaii, but treatments have not been attempted there because of a number of factors, including the fact that the infestation is relatively small and restricted to higher elevations, and also because crop exports there are highly restricted and regulated due to a number of other invasive pest infestations. 5 Posted 1/25/2008 d Are the planes, treatment equipment and flight plans safe? The contractor Dynamic Aviation, their planes and the individual pilots are required to be reviewed and licensed/approved by the Federal Aviation Administration (FAA). CDFA has contracted with this company for many Fears for aerial release of sterile Mediterranean fruit flies in the Los Angeles basin, and their safety record is unblemished. Detailed flight plans are submitted to local aviation authorities for review in advance. To ensure that no contamination of the pheromone product occurs,the mixing, loading and treatment equipment is required to be new and dedicated to this project. We will conduct sampling of the pheromone mixtures and follow a-strict chain-of-custody procedure in the delivery of these materials for testing. Strict protocols are also in place for the purchase, transport, storage, mixture and loading of the; material to be used in the treatment. Why is this eradication project an emergency? Data from our statewide insect trapping efforts shows that this infestation is a recent arrival to California. The populations of LBAM are still relatively small and are considered by an international panel of expei.-t scientists to be eradicable if significant action is taken promptly. These moth populations can grow exponentially, going through approximately five generations per year with. each female moth laying hundreds of eggs. Failure to act quickly could result in uncontrolled spread and substantial environmental and economic impacts. Who decides whether or not aerial applications are necessary? How is that decision made? At the direction of federal and state law, agricultural officials with the USDA and CDFA are responsible for eradicating invasive pests that threaten agriculture as well as the environment and natural habitat. Agency policy requires that we choose the most environmentally sensitive approach that will be effective against the infestation. For a project such as the eradication of the light brown apple moth, the agency secretaries are the primary decision-makers who rely on the scientific knowledge of staff as well as on consultations with their counterparts in healtih and environmental agencies and other experts. For the LBAM eradication project, CDFA and USDA appointed a technical working group of expert scientists to establish whether eradication is possible and, if so, to recommend the most environmentally friendly means of eradication. Aerial treatments are a central element in that plan. How do you protect against drift? The airplanes use pre-programmed GPS guidance systems to ensure even application of the treatment. The programming includes automatically turning the treatment off over bodies of water. The protocols call for treatment to occur only if wind and other weather conditions are within established limits. Why is the light brown apple moth considered a threat to the environment? Because the LBAM feeds on hundreds of different kinds of plants, it presents a threat to trees and plants in the natural environment as well as in crops and landscaping. Cypress and redwood trees, Monterey pine, oaks, lupi.nes and many other native species are included on the extensive"host list" for this pest. 6 Posted 1/25/2008 If the infestation is not eradicated, another important environmental effect would likely be an increase in the use of conventional insecticides by many residents, businesses and public entities acting to protect the plants in their gardens, landscaping, parks and other areas. Will the pheromone.harm the monarch butterfly? Are other moths affected by the pheromone? Pheromones, as opposed to conventional pesticides, have the distinct advantage of affecting only a very limited number of closely related insects while leaving beneficial insects and endangered species unaffected. Although moths and butterflies are similar insects; the pheromones used by separate species are different. Monarch butterflies are not attracted to the light brown apple moth pheromone and will not be confused or otherwise affected by it. The pheromone treatment contains no oils or other materials that would pose a threat to the Monarch population. In the pheromone-based traps that we use to detect LBAM, we have trapped only limited numbers of a few closely related moth species, further indicating.the highly specific nature of this pheromone. Some of these other moth species are also invasive, unwanted pests, although they do not pose the same level of threat as the LBAM. Because these other moths are permanently established in the surrounding region beyond the limits of the LBAM treatment area, any reduction in these populations would be expected to rebound after LBAM eradication treatments subside. How would/does the light brown apple moth affect the economy? The current LBAM infestation has already caused the nations of Canada and Mexico to impose onerous restrictions on exports of crops and plants from the infested. areas of California. China also has begun the kind of information-gathering that frequently leads to such trade restrictions. As businesses are forced to delay, reduce or abandon exports to these nations, employment, investment and tax levels are all adversely impacted. Internally, restrictions are also imposed by CDFA and USDA on businesses.such as plant nurseries in the infested areas so that their counterparts outside of the area can be protected from the infestation. These businesses must comply with strict regulations that limit or delay the companies' ability to export their plants outside the area. 'If the infestation is not eradicated, these regulations and trade restrictions would continue indefinitely and other countries would likely adopt similar measures. How will I be notified about the treatment? As required by state law, CDFA notifies all known residents of a treatment area by first- class mail in advance of an emergency treatment. We also offer an e-mail notification service (details at www.cdl'a.ca. ov/lbam) and a toll-free hotline (800-491-1899) during treatment periods to keep residents up to date. We will also work with local news media and elected officials and staff at the city and county levels to get the message out about the treatment schedule and other elements of the project. We take additional steps to share information about the treatments in advance with local homeless shelters, farm; 7 Posted 1/25/2008 a worker organizations and other groups that have been brought to our attention by local officials or have requested information. How have you communicated with environmental regulators? What have you communicated? We have provided details of our proposed treatment to a number of local, regional, state and federal groups such as the United States Fish and Wildlife Service, the California Coastal Commission, the National Marine and Fisheries Service, the Monterey Bay National Marine Sanctuary and the Central Coast Regional Water Quality Control Board. Communications have included meetings, e-mail, telephone and mail. We also work with local news media and elected officials and staff at the city and county levels to get the message out about the treatment schedule and other elements of the project. The information includes details about the program components, treatment schedule, the affected area, the pheromone, and the availability of a toll-free number and an e-mail notification system for further information. When will you do an Environmental Impact Report(EIR)? The EIR is underway and a draft should be available for review this summer(2008). Because the LBAM has the biological ability to multiply quickly, eradication efforts could only be successful with immediate efforts to contain and suppress the moth population. That is why CDFA declared an emergency to allow the eradication to begin under a temporary exemption from environmental analysis, with the understanding that a full environmental assessment of the project, including these emergency treatments, is required. The emergency declaration does not excuse the program from performing an EIR. Why not just let the apple moth be? If we do not eradicate this infestation, the moth would eventually multiply and spread to other areas of California, the United States and beyond. Farmers, residents, municipalities and other entities would repeatedly use pheromones and other, more toxic pesticides to suppress the infestation and protect their crops, landscaping and habitat. Populations of threatened and endangered species could be severely impacted should this moth adapt to feeding on them or competing with them for food or habitat. The impact on agricultural production of crops that are hosts of the LBAM could reach $160 to $640 million annually in the currently infested counties in California (source: USDA). Additionally, California would likely be placed under perpetual quarantine by neighboring states and trading partners around the world, restricting our ability to export crops and plants. Canada and Mexico have already imposed such restrictions, resulting in delays, added expenses and reduced export business for local growers. Will the paint on my car be damaged? Should outdoor play equipment be hosed down after applications? Testing performed by the United States Department of Agriculture and decades of experience with aerial pheromone treatments in the U.S. and other nations has resulted in no reports of damage to automotive paint, outdoor furniture or other common outdoor surfaces. Based on this information, no action is suggested to protect these items. Posted 1/25/2008 Y What about outdoor public gatherings on the night of applications? CDFA is in contact with local officials, school districts, etc. and has been made aware of evening and night events in the treatment area. The treatments on these nights are scheduled so that the specific sites in question are to be treated in the morning hours toward the end of the shift, after the activities have ended. . Who is paying for this? The USDA has provided the bulk of the funding for treatment as well as for the other activities in this program, including plant and crop inspections, traps, outreach and other elements. CDFA and local agricultural officials have also contributed to the project. What if the pheromone treatment doesn't work? The pheromone treatments are a central part of a multi-year.project that will require multiple tools to be successful. We have already contained the infestation by imposing quarantine restrictions and inspections on plant and crop shipments, and we suppressed the infestation in 2007 by performing the initial aerial treatments in Central Coast communities and by deploying pheromone twist-ties in several locations around the fringes of the larger infested region. The planned aerial treatments in 2008 are the next step in the eradication process. Based on the history of pheromone treatments for this pest in Australia and New Zealand and for similar pests here in the U.S., we have confidence in the success of the planned treatments. However, if the overall eradication project is not successful, we would have to reconsider whether eradication of the pest is possible under the circumstances. If not, the goal would then become suppression and containment of the in over the long term in order to minimize its environmental and economic impacts. cdfaCALIFORNIA DEPARTMENT OF FOOD & AGRICULTURE JANUARY 2008 Prepared by the California Department of Food and Agriculture. For the most current version of this document,please visit the department's LBAM web site at www.cdfa.ca.gov/lbam 9 Posted 1/25/2008 Light Brown Apple Moth in California .2 3 ��� 1 /10/08/7:48 PM l Light Brown Apple Moth in California . On This Page: z :y is • Back sround • PANNA's position • U Pdates = • Pesticides in I.,iglit Brown Apple Moth management • Pheromones and least hazardous pest management • Aerial release of pheromones W. • Community involvement in I_jight Brown Apple Moth management f • Assessing the alternatives • Eradication vs. IPM • Action and more. information <<` • ResuUI-Ces Background According to the California Department of Food and Agriculture (CDFA),the Light Brown Apple Moth (LBAM) "is an exotic pest that has recently been discovered in portions of the San Francisco Bay Area and Los Angeles. LBAM is a native pest to Australia and has been introduced into New Zealand, New Caledonia, Hawaii, the United Kingdom and Ireland. This moth can affect a wide variety of plants, flowers,fruits and vegetables." It was first identified in Berkeley,California in late 2006; by July 2007, traps set by agricultural officials had collected some 5,000 moths, mostly in Santa Cruz and Monterey along the Central Coast. In reaction, CDFA began by proposing use of chlorpyrifos and malathion -- two highly hazardous organophosphate pesticides -- to "eradicate" the moth. In September 2007, CDFA launched an additional measure: aerial application of pheromone-based products (two formulations of "Checkmate") over urban as well as rural areas of Monterey and Santa Cruz Counties, in all attempt to control the moth by disrupting mating patterns. In January 2008, CDFA announced plans to try several alternative control approaches, as well as to resume aerial applications of a new formulation of CheckMate over the Central Coast in June and north into the San Francisco Bay Area in August. In February, several state legislators submitted bills to block the spraying. Pesticide Action Network's position PAN North America is calling for an open, transparent and comprehensive review of all least toxic alternatives and for expedited research, development and implementation of less invasive approaches such as biological control and integrated pest management (IPM) that exclude use of.organophosphate pesticides. PAN supports the use of pheromones (in,for example, ground applications) and other ecologically sound organic IPM approaches as far preferable to and ultimately more effective than use of dangerous organophosphates such as chlorpyrifos. However, PAN does not endorse further aerial applications of Checkmate products due to questions regarding inert ingredients in these products (their actual concentrations and possible adverse health impacts). We also question the efficacy of aerial http://www.panna.org/book/export/html/57 Page 1 of 8 Light Brown Apple Moth in.California 3/10/08 7:48 PM spraying in general, the eradication goal itself, and the lack of complete transparency from CDFA. We - call for precautionary steps by CDFA and analysis by an independent science panel before any further spraying. Full disclosure of the extent of the LBAM infestation, management strategies and health risks must be shared in open discussion with the affected communities before further wide-scale spraying resumes. Updates Feb. 23 -- Several bills have been introduced to the California legislature to block CDFA's plan to resume aerial application of CheckMate, the pheromone-based pesticide, in the months ahead. Senator Carole Migden, San Francisco, has introduced a resolution that "would delay the application of a synthetic pheromone.... The moratorium would stay in place until officials could show that any pesticide sprayed by air is both safe and effective," she said. In the State Assembly, Rep. John Laird, Monterey, submitted a bill "that would force the department to create a list of potential invasive species and how they can be eradicated. The department would have to explain what pesticide would be used and how it would be applied." Other bills introduced Feb. 20 include Rep. Loni Hancock's '(Berkeley), that "would prohibit the agriculture department from approving pesticide use in urban areas unless the governor has declared a state of emergency," and one from Jared Huffman (San Rafael) "would restrict the department's emergency powers." Assemblymember Mark Leno, San Francisco, "would require an environmental impact report before pesticides targeting the light brown apple moth are used in an urban area." Associated Press has the story. Feb. 1.5 -- The CDFA has released its revised "2008-2009 I_BAM Action Plan" that continues to claim that "eradication is the goal" of the program, including a combination of aerial application of pheromone products around the SF Bay region. An expanded program of ground-level IPM programs will accompany the aerial spraying, prior to aerial spraying and continuing through several moth growth cycles, including pheromone "twist ties" and introduction of the Tricogramma parasitic wasp in Golden Gate Park, Santa Cruz, Soquel, Carmel and the Seaside/Marina area of Monterey. Aereal applications of a new formulation of CheckMate over areas of heaviest investation will begin June I in Monterrey and Santa Cruz counties, and about August 1 in areas of Alameda, Contra Costa, Marin, San Francisco and San Mateo Counties. .Tan. 27 -- On January 22, the city council in the San Francisco East Bay city of Albany voted 5-0 to oppose aerial spraying to combat LBAM. The vote came despite appeals from a team of CFDA officials who testified that the microcapsules of synthetic pheromones designed to disrupt male moth- mating patterns posed no health hazard. But the capsules also can contain "inert" ingredients like formaldehydes and isocynates, leading Albany Mayor Robert Lieber (who is also a registered nurse) to call the CFDA plan "a public health issue." The state had planned to.begin spraying around the San Francisco Bay Area in the spring but, earlier the same day CDFA, released a statement announcing a delay. Its Jan. 22 press release revealed that CDFA now was considering a host of alternative LBAM strategies, including traps, "twist-ties," and ground applications of Bt (a naturally occurring bacterium). But the statement emphasized that these options were only "intended to complement and not replace aerial pheromone treatment." On Jan. 27, the Monterey Herald published an investigative piece about CDFA's hiring of a Washington, D.C. PR firm to deal with growing opposition to spraying. i http://www.panna.org/book/export/html/57 Page 2 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM Jan. 10 -- "Citizen groups and governmental agencies have received hundreds of complaints from people who said they had adverse physical reactions following the state's three recent rounds of aerial pesticide spraying in Monterey and Santa Cruz counties," reports Pesticide Watch. From Sept. through Nov., CDFA repeatedly covered densely populated areas of Santa Cruz and Monterey counties with aerial applications of CheckMate. MSNBC reported that, after the first aerial 'spraying, residents began { to complain of shortness of breath and sharp stomach pains. On Jan. 5,the Santa. Cry,. Setiti` et cited an allegation that 643 complaints had been filed. CDFA spokesman Steve Lyle said his agency had I received 330 complaints of spray-related illness but he downplayed the news, insisting that "the agencies with the jurisdiction to review the product have told us it's safe to use.... lands the Checkmate products were unlikely the cause of the illnesses reported." (See Nov. 22 update, below.) A coalition of state and local groups called on the governor and legislature to block further aerial spraying. Santa Cruz City Councilmember Emily Reilly declared, "I believe further,spraying.must be halted until we can-be certain it is safe." Nov 22 -- The California Department of Pesticide Regulation (DPR) and Office of Environmental Health Hazard Assessment (OEHHA).released a scientific consensus statement on the human health aspects of aerial application of phermone products to combat LBAM. The report notes that exposure to high levels of airborne Checkmate particles could cause skin, eye and respiratory irritation. It states that these effects would be consistent with the reported symptoms from sprayed areas, but notes that it is likely that actual exposure occurred at levels below what would be expected to cause health effects. lo The report includes recommendations to CDFA of steps that should be undertaken prior to spraying. These include preparing local health care providers to recognize possible symptoms and to know how to report illnesses, and establishing a formal health study and tracking program to monitor and assess lon(,- and short-term health outcomes associated with exposure to Checkmate. oo EPA Re<oic)n 9 had reported that CheckMate contained a potentially hazardous inert ingredient, but clarified that information later. Despite legal wrangling over the public's right to know about inert ingredients, an Oct. 18 hearing revealed that the inert ingredient in the LBAM-F formulation of Checkmate is "butylated hydroxytoluene, or BHT. The additive is a common anti-oxidant used in food products to stop fat from going rancid." See The AIontet-car Comm.- 11erakl. On Oct. 20,Gov. I Schwarzenegger "askedCDFA to release the list of ingredients in the pheromone product to be sprayed on Santa Cruz and Monterey counties. The CDFA website has a list provided by the manufacturer, Suterra. This list reflects Suterra's interpretation of what it is required to divulge according to trademark law. i __.... . .. _........ _._..._..... ....... __. ._......_ __ _..._ _ _._.. ..................... i . Hazardous pesticides in LBAM control Early on in the discovery of the widening LBAM outbreak in California, chlorpyrifos and malathion -- both highly hazardous or,,;anophosphate pesticides — have been proposed to "eradicate" the moth. Already, many nursery growers have been required to apply chlorpyrifos if they want quick clearance to sell their plants following discovery of LBAM on one or more of their products. This is a practice that is threatening the organic nursery industry. Broadening use of chlorpyrifos or other chemical insecticides would significantly increase potential harm to the environment and to community health. Fortunately, safer alternatives exist that have already been approved for use in organic farming. http://www.panna.org/book/export/html/57 Page 3 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM Least hazardous approaches to LBAM control Pheromones (sexual perfumes for insects) have been used in integrated pest management (IPM) mating disruption technologies and are believed to pose no substantial environmental or human health threats. Pheromones are among the least hazardous of remedies and their use is far preferable to the use of toxic synthetic chemical pesticides. Pheromone products have been approved for use in organic farming by the National Organic Program. (Tile pheromone is not itself a pesticide -- it does not actually kill or even harm the moth. Female moths produce pheromone scents to attract males; additional release of pheromones into the environment confuses male moths seeking mates; by disrupting their mate-finding ability, it reduces their reproduction and thus ultimately moth population levels). PAN supports the least invasive methods of application of these organic remedies, such as pheromone traps, twist-ties (Isomate LBAM Plus), introduction �f parasitic wasps and sterile moths, and localized ground-level spraying of the organic insecticide, Bacillus thuringensis (Bt). Most locations on C DFA's website have response plans that rely on these less-invasive methods (e.g., Vallejo, Sherman Oaks, San Jose, Dublin, Danville, Napa and Oakley), and as of February 2008, CDFA is trying some of these alternatives in Marin and along the coast of the San Francisco Penninsula. Aerial release of pheromones On Sept. 9-11 , CDFA launched an aerial application of "Checkmate," -- a pheromone-based product approved for organic farming to control LBAM -- over agricultural and populated areas of Monterey Count (Checkmate Espanol). CDFA's stated goal was to control a rapidly growing infestation of the LBAM in Monterey to "box in" a larger infestation in Santa Cruz County, immediately to the north. "In most other places lin the state so fart," the Los Angei'es Times reports, "the battle is waged with pheromone-soaked twist-ties looped around plants and branches. But the numbers are too high and the area too great for that to work on the Monterey Peninsula, said state officials." CDFA undertook additional sprays in the Monterey and Santa Cruz areas through October, concluding for the season in early November. Plans announced in January 2008 target resumed sparying in the same area in June, and expansion to central San Francisco Bay communities by August. While various formulations of Checkmate have been used widely on crops, this is, as far as PAN knows, the first time they have been applied over heavily populated areas. There has also been some concern from local conservationists about potential damage to sensitive marine life off the Monterey coast. Environmental toxicologists at.USDA state that because the pheromone is insoluble, it would not be available to aquatic organisms. They add that all of the toxicity data available for mammals indicates that no human toxicological response would be expected :From using the pheromone at the rate intended. Recent local monitoring by UC Davis aquatic toxicologists of impacts on marine and freshwater. organisms found no significant effects on the organisms' survivorship or development (the National Marine Sanctuary collaborated on the marine study). CDFA initially reported that the inert ingredients in the Checkmate formulation used in Monterey in September -- CheckMate OLR-F -- consisted of a capsule, a device to delay release of the pheromones over 30 days or more, made of water and urea. Later, apparently erroneous information from EPA indicated that the "inerts" in at least one formulation might include other, possibly toxic, ingredients. EPA Region 9 later withdrew that information as erroneous. A court hearing on Oct. 18 produced state laboratory analysis establishing that the inert in question in Checkmate LBAM-F (the formulation to be littp://www.panna.org/book/export/html/57 Page 4 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM ,used in subsequent applications), is a common food additive and not the rumored toxic substance. Gov. Schwarzenegger requested that the list be divulged, "subject to trademark law".The manufacturer, Suterra Chemical company, subsequently provided a list of ingredients, according to their interpretation of that law. However, this list is not necessarily a complete list and the precise amount of each of the inert ingredients in the formulation remains unknown. The inerts contained in CheckMate OLR-F also remains to be clarified, as do all ingredients in the.new pheromone products being tested for use in 2008. CDFA now acknowledges that it is impossible to completely rule out all potential health risks of use of these products, though state assessment ranks the risks as very low. PAN considers the lack of complete and transparent disclosure regarding all the inerts and their concentrations in both Checkmate products to be a serious constraint to informed debate and sound policy formation. See also the Momet—ey County Het-a1. PAN does not endorse the aerial application of the pheromone product, Checkmate, due to remaining questions we have regarding possible adverse health impacts of the inerts, the efficacy of aerial application in general and over mixed-use habitats of the Central Coast in particular, and larger doubts regarding the eradication goal itself. PAN has urged CDFA to work more closely with local community members, conservationists, growers (organic and conventional) and independent experts in entomology, toxicology and public health to find acceptable least toxic and less invasive solutions to the challenge of LBAM control. Community involvement in Light Brown Apple Moth management Pesticide Action Network firmly supports community involvement, notification, monitoring and precaution as new technologies are tried. More information needs to be made available (including intlepetident assessments of health and environmental impacts and the effectiveness of aerial application of any product) before aerial applications are considered or other management strategies are employed. PAN believes that on-going dialogue with community members is essential to the effective development of Light Brown Apple Moth management plans and suggests the formation of committees of local residents to formally work in collaboration with CDFA and local growers and conservationists as approaches are tried throughout the state. PAN suggests that in all steps of the management plan process, including development, implementation and evaluation, CDFA ensures workers and the affected public full right-to-know and participation. While CDFA has increased its information and public relations efforts in 2008, these communications remain essentially one-way rather than participatory. Assessing the alternatives PAN supports CDFA's decision to focus on least-toxic and non-chemical approaches to LBAM control, rather than organophosphate insecticides. However, we do not endorse the aerial application of Checkmate (see preceding section). In order to facilitate the informed public debate that we consider essential to resolving the LBAM challenge in a democratic manner, PAN calls on state agencies to provide a clear presentation and obtain independent, thorough, comparative assessment of the range of least-toxic alternatives available. This includes: 1 . scientific evidence demonstrating the efficacy of aerial pheromone release in LBAM control (including evidence relevant to application in central coast ecosystems); 2. independent review of epidemiological or occupational health studies of the effects of aerial pheromone release; 3. continued monitoring of environmental impacts; http://www.panna.org/book/export/html/57 Page 5 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM 4. monitoring and independent assessment of the illness reports following aerial applications of Checkmate in the central coast; 5. comprehensive analysis of.the economic and s,�cial costs/benefits of alternatives under different scenarios. This would include assessment of the estimated costs of (for example) potential quarantine protocols at individual farm, county and state levels and a clear presentation of how the costs and benefits associated with various LBAM control measures would likely be distributed across different actors (small to large scale growers, organic farmers,farmworkers, nurseries, residents, etc.). Scenarios should include creative combination of tactics that could emerge from discussions with local community members. We urge expedited research into biological control, sterile moth release, ground application of pheromone compounds and other environmentally sound approaches. Again, CDFA has increased its experiments with ground-level alternatives, though it remains committed to aerial applications as part of its LBAM eradication goal. Eradication vs. IPM PAN and mainstream entomologists do not believe that eradication of this moth or other pests is a realistic pest management approach, particularly given the likelihood of successive re-introductions of the moth in the months and years ahead. Sustainable, least-toxic ecological IPM (Integrated Pest Management) is the appropriate response. We encourage CDFA to continue focusing on least-toxic approaches such as pheromones, preditor wasps, sterile moth release and other biological control and to work with IPM experts and community members in developing a long-term sustainable pest management plan for LBAM. PAN urges CDFA to establish an advisory committee-,, consisting of growers, local community members, local conservationists, environmental groups and independent experts in entomology, toxicology and public health, to collaborate in finding efficacious and ecologically and socially acceptable solutions to LBAM management. Action and more information For more background on pheromone mating disruption, there is a useful article from University of California, Davis, "Pheromone mating disruption offers selective management options for key pests". CDFA has also issued a "2008 Q&A Update". Community groups, farming, environmental and health organizations are developing their own fact sheets and resolutions. Resources Statements and Memos • CDFA 2008-2009 LBAM Action Plan (revised, 02/15/08) • CDFA L.,ight Brown Apple Math Eradication Program for 2008 (01/22/08) • Pesticide Watch news release on spray illness reports (01/04/08) • NRDC Position Statement on Spraying, For the Light Brown Apple Moth in California (11/14/07) • CDFA reply to Assm. Laird (10/04/07) • Assm. Laird letter to CDFA (10/16/07) http://www.panna.org/book/export/html/57 Page 6 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM • C:'DFA reply to Assm. I-gird (10/26/07) • C'hemist's concerns re: inerts (1041/07) • Chemist's concerns re: inerts (10/15/07) • PANNA statement on LBAM control (09/26/07) • PANNA memo to CDFA (09/28/07) • PANNA letter to Assm. I-gird (09/27/07) • Assm. Laird letter to State Sec. A«. Kawamura Media • Moth shravin , likely to harm more than help, "Ask the Bugman," Richard Fagerlund, Feb. 23,2008 • Moth--eaten plans, editorial, San Francisco Chronicle, Feb. 22,2008 • Migden battles aerial moth spraying, San Francisco Chronicle, Feb. 20,2008 • State plans Bay Area pesticide spraying, San Francisco Chronicle, Feb. 15, 2008 • Marketing, af Math Spraying - .Jan. 27, 2008, Monterey Herald • Group alleges hundreds got sick after moth spraying - Jan. 5, 2008, Santa Crit. Sentinel a • Godzilla versus Mothra - Mo►)umental estimates of impacts threatening SF wvith spraying - Jan. 2008 • Li.ght browvn apple moth mound at SC garden center - Dec. 20 2007 • Monterrey Cou►ity Weekly' Light Brown Apple Moth Covera, e • Spraying '100 percent done' in Santa Cruz County for now, state reports, Santa Crir;. Sentinel • Judge suspend~ program aimed at Curbing moth's spread in Monterey', San.Jose MercurY News • Crowwel voices concern over spraying,Santa Cruz Sentinel • Link to Monterey Herald. Sept 27, 2007 article on LBAM and spraying: http://www.niontei-evherald.com/ci 7012289 • PANNA Sept 26. 2007 Letter to the Editor of Santa CRIZ Sentinel Research and Technical Papers • Human Health Aspects oto Aerial Application of Pheromone Products, by CA DPR and OEHHA (10/31/07) • Analvsis of LBAM "I'micology Studies, by D. Philip, 2007 • Aerial Application of "Cliecknlate" Fact Sheet • Biodegradable Polymer Methods • DPR Environmental Monitoring Recommendation for Synthetic Pheromone Treatments • Finding; of' No Significant Impact Treatment of 1-ight Brown Apple Moth in the Seaside Area in California Environmental Assessment • Findina, of No Significant Impact I-reatment Appendix • ProlonL:,ed Slow Release of Microcapsules • Re *uI�►t0ry Issues in the Commercial Development of Pheromones and Other Se►niochemicals • LJSDA Environmental Assesment for LBAM Treatment Map http://www.panna.6rg/book/export/html/57 Page 7 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM —0. s... io Y. • � ,tea � �c� ae:: ' -.a �'�:. ��� vaa>. �:.' r"Y Y�s�� ' Via..�.• j. F pra'.F . . g .. �, • �,... J!`.+ ,to'� , Ri un. :::.rx:.:.:•. y : w r.� yeR. ............. N.. not R ....:..::V:.".. •5N Loge I'd i : Download a Larger Map (PDF) http://www.panna.org/book/export/html/57 Page'8 of 8 31 \k 0 Hello, Below is a press release. for a report released today by a UC Santa Cruz botanist describing findings of research in New Zealand on the light brown apple moth. The report finds that the moth does no significant damage to NZ crops or wild lands and is largely controlled by natural predators there. The implications for California are that the same will likely be true here as we have the name natural predators for moths of this type. The report recommends suspension of aerial spray and ground treatments for the moth. The full report is attached. Nan Wishner, Chair City of Albany Integrated Pest Management Task Force 510-524-5185 PRESS RELEASE Contacts available for TV and radio interviews) Daniel Harder (83 1) 427-2998 .teff Rosendale (831) 818-6972 James R. Carey (530) 752-6217, (530) 400-8998 March 7, 2008 Scientists Report Shows Light Brown Apple Moth Controlled by Natural Predators Evidence ftom Netia- Zealand Contradicts State Claims that Liguht Brotinal Al)hle Moth is a Risk to California Agricullure and Wildlands• Santa Cruz A report released today says the Light Brown Apple Moth (LBAM), which is the target of a controversial aerial pesticide spray program California Department of Food and Agriculture (CDFA), is a relatively minor pest in New Zealand where it does not do economically significant crop damage or detrimentally affect native flora. The reports findings contradict CDFAs rationale for a pheromone-based pesticide spray program for LRAM that is planned for the Central Coast and San Francisco Bay Arca this summer. CDFA has described the moth as a voracious pest that threatens California agriculture. The report, however, .finds that LRAM in New Zealand today is effectively controlled mainly by natural predators in both agricultural and wildlands and that there is no evidence of biological or environmental threat from LRAM in New Zealand. The moth, an Australia native, was introduced more than 100 years ago to New Zealand, whose flora and climate are similar to that of coastal California where the moth has been found. The report,•by Dr. Daniel Harder, botanist and Executive Director of the,University of California at Santa Cruz Arboretum, and ,Teff Rosendale, a Watsonville grower and horticulturalist, concludes that, in California. the moth will likely be kept in check by the same natural predators of the more than 85 species of similar tortricid moths present-in the state. In addition, the report states that the pheromone-based eradication treatment currently planned by CDFA will likely not eliminate or control LBAM. because none of the essential conditions for successful pheromone use can be met. The report recommends suspending the planned aerial and ground treatments for LBAM and monitoring to determine the degree to which the moth is already being parasitized. Based on their findinigs, the authors conclude that the United States Department of Agriculture (USDA) classification of LBAM as a quarantinable pest should be reviewed and downgraded based on current, relevant, ;;cicnce-based information, and that current requirements for broad-spectrum organophosphate pesticide controls for LBAM in nurseries and elsewhere in the U.S. should be abandoned because they harm the beneficial species that prey on LBAM and other pests. During a three-week, 3,000-kilometer fact-finding study in New Zealand, the authors learned that 80 to 90 percent of LBAM larvae are destroyed by natural predators and never mature. The authors spoke with current research experts on LBAM in New Zealands government agricultural agency, HortResearch. The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices, that can be readily adopted in California to control I,BAM. The authors report that LBAM is a superficial feeder that typically causes only cosmetic damage to the surface of leaves and fruit and rarely penetrates a host fruit. LBAM does not defoliate plants, as CDFA has alleged. Defoliation is contrary to leaf rollers biological need for leaves that, with the help of thread material, the larvae roll around themselves for protection, the report states and adds that, in New Zealand, LBAM has never posed a threat to native forests. In New Zealand, beneficial insects are considered the first and best line of defense and insect growth regulators (IGRs), which are based on derivatives from natural sources, are the primary least-toxic control used in agriculture for controlling leaf roller moths. Growth regulators do not negatively affect beneficial insects to any significant degree. The report notes that pyrethroids and organophosphates should not be used because they are detrimental to beneRcial.insects and pollinators. Pyrethroids are especially detrimental to native and introduced bee populations essential for pollination and to mammals. New Zealand stopped using organophosphates in 2001, according to the report, so data on LBAM in New Zealand prior to 2001 do not accurately reflect LBAMs behavior in agricultural and natural environments with healthy populations of beneficial predators. The reports also calls into question the states pheromone aerial spray program with its finding that pheromone controls applied by any means cannot be effectively used across large diverse areas with varying canopy heights, mixed species composition, and varying terrain areas. The authors note that, Until tests reportedly carried out under a U.S. government contract in 2008 in southern New Zealand forests, pheromones had never been aerially applied in New Zealand. This report shows that the apple moth is not iihe voracious pest the state has tried to say it is and contradicts CDFAs basis for the LBAM aerial spray and control program, says Harder. Regarding the implications of the report for the proposed eradication project, Dr. James Carey, professor of entomology at UniversitJ7 of California at Davis, says "The current distribution of LBAM in California covering 10 counties with a combined area of over 7,000 square miles(the size of Connecticut) suggests that this pest is not a recent introduction but has been in,the state for many years, perhaps as many as 30 to 50 or . more years. The history of eradication programs in which an exotic insect is as widespread as is this pest in California suggests that we have little if any chance of success." Integrated Pest Management Practices for the Light Brown Apple Moth in New Zealand: Implications for California Daniel Harder, Ph.D. Executive Director The Arboretum, University of California at Santa Cruz .Jeff Rosendale, Grower, Horticultural Consultant Watsonville CA March 6, 2008 ABSTRACT The Light Brown Apple Moth, El ilAvcas posivittana (LBAM) has been an established exotic species in New Zealand for more than 100 years. The authors conducted a three-week..3,000-kilometer fact-finding study in New Zealand's two major agricultural regions to assess integrated pest management (IPM j of LBAM and applicable strategies for California. LBAM was considered a problem pest in New Zealand orchards during the 1980s when regular, calendar applications of broad- spectrum organophosphate pesticides had eliminated the beneficial insects that prey on LBAM. However, since elimination of organophosphate treatments in 2001 and subsequent restoration of populations of beneficial insects and other organisms. LBAM is considered a minor pest that does not cause economically significant crop damage or have detrimental effect on native flora. Today, LBAM is effectively controlled almost exclusively by natural predators in both agricultural settings and wild lands in New Zealand. There is no evidence of biological or environmental threat from LBAM in New Zealand. Because of United States" zero-tolerance quarantine requirements for I.,BAM, New Zealand horticultural/agricultural professionals use pheromone sticky traps to monitor LBAM populations and, based on monitoring data, timed ground applications of insect growth regulators (IGRs) are used in select agricultural settings to prevent shipments from being rejected for export to the U.S. The success of New Zealand agriculture and horticulture professionals in controlling I.BAIVI and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best I I'M practices that can be readily adopted in California to control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. Adopting IPM best practices would include suspending planned aerial and ground treatments for LBAM in California and monitoring to determine extent to which LBAM populations are being parasitized or destroyed by predators. United States Department of Agriculture (USDA) classification of LBAM as an actionable quarantine pest should be reviewed and revised based on current, relevant, science- .based information. 'rhe negative impact of organophosphate use on beneficial predator species in New Zealand, along with the known health and environmental dangers of these chemicals, suggests that current requirements for organophosphate controls for LBAM in nurseries and elsewhere in the U.S. should be abandoned. Introduction This report describes results of a January 2008 fact-finding study on integrated pest management of the Light Brown Apple Moth (LBAM) in New Zealand. The study was undertaken to understand the extent of LBAPO's effect on New Zealand's agriculture and natural environment and the-methods of managing LBAM, with the goal of understanding potential impacts of and best management practices for LBAM in Cali[ornia. The authors focused on understanding best management practices for control of LBAM and how these strategies impact the cultivation of plants in botanical collections in gardens and arboreta as well as in commercial nursery and agricultural cropping systems. New Zealand was chosen for this research because its climate and crops are similar to California's coastal farming areas and because LBAM was introduced to New Zealand from Tasmania and first reported in New Zealand in 1891 (Thomas, 1987, HortNet http://wvNw.hortnet.co.nz/key/keys/info/distrib/lba-dist.litni) and thus has been an established exotic in New Zealand for more ishan 100 years. The remainder of this report describes the steady's research methods and presents findings and discussion on i,BAM biology and behavior, hosts, populations, damage, and control in New Zealand, as well as LBAM's role in global trade of New Zealand agricultural products. Methodology The authors traveled and conducted interviews with government, agricultural. and horticultural entomologists and researchers of LBAM and insect pests as well as wholesale and retail agricultural and horticultural producers and plant conservationists. They also conducted field searches Im LBA10 presence and damage in commercial agricultural fields, orchards, native habitats including Abel Tasman National Park, and along roadsides. The research was carried out over a period of three weeks, January 4 - 29, 2008, which is rnid-summer in New Zealand when LBAM would be expected to be active in all lilc stages and readily observable. The goals of the research were to learn from agriculture, integrated pest management (IPM), entomology, and conservation experts about LBAM in New Zealand and to identify iPM strategies that would be effective against LBAM in California. The authors focused on the two main agricultural production areas of New Zealand: on the North Island, the i lawke's Bay region, known as the "fruit basket " of New Zealand where the major produce is apples, nectarines, kiwis, wine-grapes and assorted row- crops, and on the South Island. the Nelson ar;ricultural region, which is a major production area for apples, currants, hops and wine-grapes. See figure 1. 2 .......... .._.:.. ,.q a.. a a.. .. h^a. y i .. ' ! ..' (IT KtF rin" K: z < ..p :.. L=o QQ-4 . ii Y� e. k c: ;T rc•��:*.. W_ ,. •'Ni.. ..r }'.1 • F F r .:':•y ..is Figure I. New Zealand map Both the Hawke's Bay (Napier) and Nelson areas are similar in terrain and mixed forest areas to California"s Monterey Bay and Santa Cruz areas where the California LBAM presence is most dense. The Hawke's Bay region is a bit warmer and moister than Monterey Bay, making it an ideal climate and study area for LBAM. These agricultural regions also have a long history of studying and controlling LBAM and have developed technologies to best protect crops. As shown in Table 1, Nelson and Napier have climates very similar to Calilornia's Central Coast. Comparison of Temperature Ranges,Average Mean Temperatues and Precipitation in Monterey,California and Napier,New Zealand in 2007. Months have been aligned to season. . 2007 lanuary February March April May June July August September October November December Santa Cruz,California Ten peretuie Wine(F) 39/61 41/63 42/65 43/68 4G/71 49/74 51/76 52/76 50/// 47/74 43/66 39/63 Average Te rperat,—(F) 40 5-- 54 53 55 56 62 62 63 59 51 N—P:', (inches) G. 5.5 4.5 2.2 0.7 0.2 0.1 0.1 0.3 5.4 June July August September October November December January February March April May Napier,New Zealand T—pe-aturc Range(F) 31/60 36/65 35/66 33/67 34/77 43/93 48/63 45/89 47/86 46/95 38//5 30/72 Average.te'rperature(F) 49 50 50 52 59 50 64 66 64 65 'j4 55 Drec'ip:tation(.rchrs) 3.6 3.3 3.2 2.1 2.2 1.G 2.9 1.9 2.2 2.7 2.5 7.7 Sgt:;re::'tip://wvnv.'.v..^:'er9�ound.cem, http://worldcl ria:e.com Table 1. Comparison'of Santa Cruz, CA and Napier, NZ Temperatures and Rainfall The southernmost area of New Zealand was not visited because its colder,harsher climate is both less hospitable to i,BAM than the warmer climate farther north and dissimilar to the climate of areas where LBAM is presently found in California. In addition, New Zealand cultivates hundreds of thousands of hectares of Monterey pine (Pinus radiata) and has planted many Californian species including vintage Monterey cypresses (Cupressus macrocarpa), giant sequoias (Sequoiadendron gigantezun), coastal redwoods (.Sequoia seinpervlrens), as well as native New Zealand conifers. Results and Discussion The subsections below present findings related to LRAM, its biology, behavior, enemies (beneficial control agents), populations, damage, control in New Zealand, and role in New Zealand agricultural trade. Biology and Behavior of LBAtl1 LBAM is a tortricid (Tortricidae) moth and a member of the leaf-roller moth family in the order Lepidoptera. Each LBAM individual exhibits three life stages: larva, pupa, adult (moth). LBAM is polyphagous, meaning that it is not host specific but rather feeds on a variety of plant species. A superficial feeder as.a larva(see Figure 2), LBAM typically causes cosmetic damage to the surface of leaves and fruit and only rarely penetrates a host fruit. LBAM does not defoliate plants. Defoliation is contrary to leaf rollers' biological need for leaves that, with the help of thread material, the larvae roll around themselves for protection. The rolled leaves provide protection from predators and the ideal conditions for growth and development. bike all leaf rollers, LBAM is subject to natural predation and parasitism. Major predators and parasites in New Zealand include: birds, spiders, wasps, flies, beetles, lacewings, and earwigs to name only a few. A full listing of enemies to LBAM can be found at: ht p://www.hortnet.co.nz/key/stone/info/enejnies/lba-enem.htni LBAM may mate up to three times during its 1- to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per erg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (I IortNet Website at http://www.hortnet.co.nz/publications/proce(:dings/i f6am/if6am69.htm) Adult LBAM travel an average of approximately 100 meters from their hatching sites during their lifetimes and are not necessarily particular about where oviposition (egg- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. 4 y. i i , s' a' _....: . r 7 ;�.is�: �....•• is x ` _ , A .: .. ; , x.. r r{ T , t; i• x ' Figure 2.• Superficial leaf damage from LBAM larva i,BAM may mate up to three times during its 1- to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per egg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (HortNet Website at http://www.hortnet.co.nz/publications/proceedings/ifoam/ifoan169.htni) Adult LBAM travel an average ol'approtimately 100 meters from their hatching sites during their lifetimes and are not necessarily particular about where oviposition (egg laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. LB.4,l'f Hosts anti Populations in New Zealand Although LBAM is considered by New Zealand HortResearch, the government' agricultural and horticultural research agency, to be "common" in orchards throughout New Zealand and -less common, rare, or even absent" in areas of New Zealand still 5 covered in native forest (HortResearch 2008 http://",Nww.hortnet.co.nzikey/keys;info/distrib lba-dist.htm), LBAM is, in fact, difficult to find in New Zealand. Eighty to ninety percent of LRAM larvae are parasitized by natural predators before maturation (Shaw, 2008). 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. For.meeting U.S. quarantine requirements„LBAM populations in New Zealand are estimated and monitored using pheromone traps. LBAM is not an insect of significance in Monterey pine plantations in New Zealand. LBAM is a:leaf-roller moth that requires flat-surfaced leaves to protect larvae while they mature. Clearwater(2008) notes that LBAM clearly does not have a preference for gymnosperms and is not considered a pest ofthese plants in New Zealand. Shaw (2008) reports that gorse is a preferred LBAM host plant in New Zealand; however, the authors found no LBAM larva(- on gorse in a wide variety of regions in the North Island and the main agricultural regions of the South Island. In fact, the authors' extensive search for LBAM in native New Zealand habitats during the three-week, 3,000- km extent of this research trip revealed only a few larvae, one on an exotic planting in a hotel garden, as well as a few tortricid moths flying around porch lights in the evening. No evidence of LBAM eggs, larvae or adults was found in the 22,530-hectare Abel Tasman National Park on New Zealand's South Island. This national park has a mixture of native and non-native plant species with a multi-story diverse habitat of broadleaves, ferns and conifers. Agricultural/horticultural researchers in New Zealand noted that, because LBAM larvae are often parasitized, finding a larva docs not mean that a viable adult LBAM will hatch. If a parasite has laid eggs in the larva, the parasite's adults, e.g., wasps. flies will hatch rather than LBAM. Due to the need to understand natural controls for iMAM in California and the similarity of types of organisms keeping LBAM under control in New Zealand with those already present in California, monitoring of levels of parasitism of all life stages should begin immediately for LBAM in California. As noted below in the LB.4MC7ontrol in Nero- 'Zealand section, researchers in New Zealand have developed a monitoring protocol that allows there to determine the extent of parasitism of LBAM populations to prevent unnecessary and costly control efforts based on observation of larvae only. Similar parasitism of LBAM is 1 ikely occurring in the.regions of California where it is present. The Arboretum at the University of California, Santa Cruz has initiated a survey of beneficial insects that may control LBAM. In eight larvae raised to adults, two have been parasitized by natural predators. LBAM DarrraA,re in Neiv Zealand LBAM is currently considered a minor biological pest in New Zealand agriculture, including apple, peach/nectarine, citrus, and vineyard crops. Codling moth ("the worm in the apple," also a tortricid) and woolly apple aphids are much more significant pests in 6 apples, and thrips and mites are the pests of significance in New Zcaland citrus (Vidcan 2008) I lawkes Bay horticultural researchers report that, with no monitoring or treatments and if LBAM were uncontrolled other than by naturally occurring trichogramma or other beneficial insects and organisms, the maximum damage caused by LBAM would be one percent or less ol'crops (Walker 2008). 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. New Zealand horticulture and agriculture professionals so successfully use IPM strategies to manage LBAM that in more than 3,000 U.S. shipments of pomc (pip) fruit in 2006, only six were rejected. One positive LBAM find can cause rejection of a single 15-ton Fruit order (Walker 2008). Thanks to exceptional, modern New Zealand I.PM practices, leaf rollers have limited economic impact on fruit or crop production other than occasional shipments rejected by U.S. only because of zero tolerance for'LBAM. LBAil,f C'onlrol in Neve Zealand Beneficial insects are considered the first and best line of defense against leaf rollers, and insect growth regulators (iGRs), which are based on derivatives from natural sources, are the primary insecticide used for leaf roller and codling moth control in New Zealand. Growth regulators do not negatively af[ect beneficial insects to any significant degree. Rather, IGRs are relatively target-specific and cause target larvae to mature faster than normal before the larvae are physiologically ready and so die. To control LBAM effectively with IGRs, it is important to target overwintering LBAM Populations. As cooler weather progresses, adult populations of LBAM drop; adults die oft., and larvae do not morph into adults. The lowest adult numbers occur in late winter. IGRs are most effective when applied as eggs hatch and larvae begin to feed in warmer summer weather. In California, IGRs should probably be applied in May, but the timing needs to be verified by phenological monitoring using pheromone traps for adult males (Shaw 2008). Treatments with least-toxic IGRs for most other pests, particularly codlin'g moth, which is one ol'the top apple pests in New Zealand, generally act, along with beneficial insects, as adequate LBAM controls. Bio controls are effective against all I.,BAM life stages: eggs, larvae, pupa, and adults. Biocontrols include native and introduced wasps and native tachinid (Tachinidae) flies. The key to effective control with predators and parasites is to encourage a•range of insects attacking all life stages. 7 In the Nelson area, roughly four to 10 percent oil producers are organic. Because organic systems encourage beneficial insect populations and do not negatively affect beneficial organisms and insects with the use of harsh chemical controls, pests (including LBAM) are not significant problems for localized organic producers. The leaf-roller complex, including LBAM and other native New Zealand species, is readily monitored in the early to mid-spring with a pheromone sticky trap and regular visual inspection. Based on monitoring results, a single IGR spray regime can be effective for season-long control. Growers i;a the Hawkes Bay and Nelson regions do not use mating disruption pheromones to control LBAM. They monitor in late spring with pheromone traps specific to LBAM and. codling moth. If the trap counts warrant, an IGR is applied (e.g. intrepid, Confirm: methoxyfenozide, tebutenozide). This timed treatment adequately suppresses LBAM and codling moth populations for the year (Walker 2008, Shaw 2008). Pyrethroids (natural or synthetic) arc effective controls for LBAM but also arc detrimental to beneficial insects and pollinat,:)rs, making these products undesirable for long-term IPM of LBAM. Pyrethroids are especially detrimental to native and introduced (honeybee) bee populations essential for.pollination and to mammals. History of Organophosphate Control During the late 1980s and 1990s, organophosphates were applied regularly in New Zealand orchards with no monitoring for insect populations. The effort was to create a "sterile nursery" situation where there were no pests and no beneficial insects. Organophosphates were used because of the zero tolerance for LBAM in produce to be exported to the U.S. The chemicals were applied on a schedule rather than in response to pest populations. 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. Use of organophosphates was eliminated in New Zealand in 2001. 1 IortResearch experts report that once the use of broad-spectrum organophosphates was stopped and agricultural professionals began monitoring -For LBAM and timing IGR sprays, all of which allowed beneficial insects to affect LBAM populations, the LBAM problem reduced dramatically so that the moth is nom: considered.a minor pest (except for the challenge posed by the U.S. Department of/agriculture quarantine) http://www.hortnet.co.nz/key/stone/info/con[rol/lbacon.tr/lr-chem.htm. Organophosphates were destroying beneficial insects and creating resistant insects, and orchards and vineyards were becoming LBAM breeding grounds. Shaw (2008) reports that, at Nelson/Motueka, "control trees with no insect or chemical controls used have not recorded any damage from LBAM or other leaf rollers for more than 10 years." HortResearch staff attempted to force LBAM infestation of these trees by introducing LBAM eggs and larvae into the gees to no avail. Any infestation of these trees by LBAM was quickly controlled by native predators without the need for IGRs. 8 "Once organophosphates were removed li•om the system and populations ol•beneficials were left to develop naturally, complete control of LRAM was realized in less than 5 years" (Shaw 2008). When or were compared to natural;controls in consistent blocks of apples, control of LBAM was achieved with natural controls in less than two years. Organophosphates never allowed effective control, and LBAM developed resistance to them. It is worth noting that in New Zealand, intercropping has been shown to promote beneficial insect populations, resulting in near-complete LBAM population suppression to below.thresholds for use of control measures (Irvin et al. 2006, Begum et al. 2006) Monitoring Spring populations of LBAM in monitoring traps in total numbers per month is key to deciding whether to use IGRs to control the population. Local,monitoring of population levels allows tracking of seasonal fluctuations (Shaw 2008). Monitoring programs should assess levels of LBAM phenologically (at various life stages and, by rearing larvae and eggs lrom host plants, the degree olepredation and parasitism of LBAM. Parasites and beneficial controls may not be seen in early-stage occupation of habitats by LBAM or other invading pests but will develop as the predators respond to the presence of LBAM as a possible host. A monitoring protocol has been developed that allows determination of the rate of parasitism of LBAM larvae. Auckland HortResearch Insect Rearing Lab uses a general- purpose diet to rear LRAM larvae so that they can be observed to see if they are parasitized. Larvae are placed in a capped tube with cotton, allowed to develop at room temperatures, and observed to determine whether LBAM develops normally, parasites hatch, or development is adversely allected by other potential control means. The specifics of monitoring and thresholds for treatment are provided on the New Zealand HortResearch website: http://www.liortnet.co.nz/key/.• Eradication and Pheromone Use Widespread LBAM eradication efforts have never been attempted in New Zealand. A very limited eradication program took place during the 1980s affecting two orchards (200 hectares total) in the Nelson region where an insecticide-resistant LBAM strain had appeared. 'Twist-tie pheromone strips (1000 per hectare) and ground-applied insecticides were used to eradicate this resistant and localized LBAM population. Eradication is very difficult unless a population is quite limited and well defined. New Zealand researchers report that effective mating disruption using pheromones will only work under the followingspecific conditions: Extensive, even, and complete coverage of the pheromone Uniform blocks o1•a single crop (single canopy height) Uniform topography (no slopes, hills or valleys) Low population density of target pest (not too concentrated) 9 Under the above conditions, twist ties can be used for control under extensive coverage. However, pheromones applied by any means, cannot be effectively used across large diverse areas with varying canopy heights, mixed species composition, and varying terrain areas. New Zealand researchers also note that aerial pheromone spraying interferes with monitoring using pheromone traps, and monitoring is critical to successful control. Moreover, use of broadcast pheromone spray to eradicate or control the nnoth is not effective because female moths issue a more concentrated scent plume than the dispersed pheromone scent of an aerial spray application, so male moths are able to find the females (Shaw 2008). Until tests reportedly carried out under a U.S. government contract in 2008 in southern New Zealand forests ("NZ Forest Provides Laboratory for Pheromone "trials" 2008 http://nz.iiews.yahoo.com/080217/-'I/p/40zs.litiiii), pheromones had never been aerially applied in New Zealand. These trials are been undertaken within a Monterey Pine plantation and does not involve applying the pheromone over urban areas. Pheromones have never been used for widespread eradication anywhere in the world. HortResearch stations oil both islands agree that eradicating LBAM in California and anywhere would require extensive, widespread use of IGRs with repeated applications to address elusive, selected populations. These: experts also question the efficacy of bacillus thin-ingiensi.s (Bt) against LBAM. Bt can also have a detrimental effect on beneficial insects. They report that IGRs do not harm populations of beneficial insects and that IGRs persist on foliage much more effectively than organophosphates did. Larvae emerging from eggs begin to perish as soon as they start feeding on the growth .regulators. Tests show IGRs are ovicidal as `yell as larvicidal and not toxic to predatory/beneficial insects. The beneficial effects of the application of growth regulators can be seen one to two days after application (Walker 2008, Shaw 2008). LB.1Mantl Global D-cide of.New Pl'ocluas LBAM is not of biological concern oil either island in New Zealand but rernains a pest of concern only because it is a quarantine pest for exports. USDA considers LBAM an "actionable quarantine pest" and has zero tolerance for LBAM finds in pre-inspection of U.S.-bound fruit shipments. Consignments rejected because of any LBAM life stages are sent to non-U.S. markets, e.g., Europe, which does not have phytosanitary restrictions for LBAM. Today very few New Zealand (reit shipments are rejected by the U.S. (Walker 2008), which further suggests that New Zealand growers' LBAM controls relying on natural predators and I13M strategies are successful. HortResearch experts say that when USDA announced during the late 1990s that the U.S. would no longer accept fruit treated with organophosphates because of concerns for the salety of fruit handlers and consumers, this was the catalyst for abandonment of organophosphates and the move to reliance on natural predators and IPM methods. 10 Iny)licutions for- California The information on LBAM and IPM in New Zealand reported in this report has significant implications for addressing LBAM in California. First, it is worth noting that, according to the National Museum of Natural History Catalog of Type Specimens of Tortricidae (www.sel.barc.usda.gov/lep/tort_types_list.html), California has 85 native and localized North American species of tortricid moths; none are problematic as a pest. All are kept in check by natural biological controls, so there is confidence to believe that LBAM will also be controlled by native natural predators or parasites. Preliminary studies by the California Department of Food and Agriculture report a high level of parasitization of LBAM larvae by native California trichogramma wasps. Entomologists speculate that LBAM may have been in California for as long as a decade already (Garvey 2007), so it is possible that LBAM is already being controlled by natural predators. Many LBAM predator species in New 'Zealand are the same or closely related to California species (birds, earwigs, viruses, trichogramma and other wasps, tachinid flies, spiders, beetles, etc.). According to New Zealand information, the pheromone treatment currently proposed for LBAM will most likely not eliminate nor control LBAM because none of the essential conditions for successful pheromone use can be met. Use of the pheromone cannot be complete (e.g., it cannot be applied over sanctuary butter zones and along streams/waterways), the pheromone will not be applied over a.uniform block but rather over mixed forests and'native vegetation, houses, schools, roadways, crops, and ornamental gardens. Moreover, topography ofthe California coast is highly varied and diverse, and LBAM populations in these areas are dispersed and, in areas of high trapping numbers, are too concentrated for effective use of mating disruption pheromones. In addition, application of mating disruption pheromone alone without the addition of IGRs would not allow for success. Current CDFA recjuirements that commercial nurseries in California use the organophosphate insecticide chlorpyrifos if LBAM larvae are found are in direct contradiction to New 'Zealand bindings that organophosphates destroy LBAM's natural predators, resulting in resistance developing in LBAM populations. New Zealand experts recommend use of IGRs in the control of LBAM in agricultural systems'as much safer and more effective. Monitoring should be performed to assess level of predation on LBAM larvae, which could reveal data indicating that less (or no) intervention is required to control LBAM in California. Conclusions The success of New Zealand agriculture and horticulture professionals iii controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to 11 control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. The finding that there is no evidence of biological or environmental threat from LBAM in New Zealand, which has climate and crops much like California and where LBAM has been an established exotic for more than a century, bodes well for the ability of California agriculture and ecosystems to accommodate to LBAM.'s presence and suggests that USDA classification of LBAM as an actionable quarantine pest should be reviewed and revised. USDA's pest quarantine list needs to be re-evaluated based on current, relevant, science-based information. New Zealand researchers say that it will be very problematic to attempt to eradicate this insect as it has now been firmly established over an extensive and diverse area. In California, LBAM is found across more than 7000 square miles.of varied terrain and conditions, including within protected buffer zones and sensitive riparian corridors. The negative impact of organophosphate use on beneficial predator species in New Zealand, along with the known short- and lorag-term health and envirorunental dangers of these chemicals, suggests that requirements for organophosphate controls for LBAM in the U.S. should be abandoned. The requirement that California nurseries use chlorpyriphos 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 chlorpyriphos use. This and other highly toxic treatments need to be discouraged or prohibited in commercial nurseries. The short- and long-term risks to exposure of organophosphates and the long-term persistence of organophosphates in the environment make their continued use for control of LBAM inadvisable. A realistic assessment of LBAM populations and potential damage based on New Zealand data must rely on recent studies published after the use oforganophosphates stopped. Organophosphate use causes an unnatural situation to develop in which natural predator populations are unable to function. There may not be any need to introduce a noxi-native control for LBAM in California; natural controls may already exist in the native fauna given the robust numbers of native Tortricidae in California. Summary of Recommendations Based on the findings above,.the key recommendations of this report are to: • Suspend planned aerial and ground treatments for i:ight Brown Apple Moth (LBAM) in California and monitor to determine extent to which LBAM populations are being parasitized or destroyed by predators. • Adopt IPM best practices from New Zealand to control LBAM if necessary. 12 • Review USDA classification of LBAM as an actionable quarantine pest based on current, relevant, science-based information. • Eliminate requirements for organophosphate controls for LBAM in the U.S to product natural predator species that feed on LBAM and other Pests. • Realistically.assess the potential impact of LBAM in California using New Zealand data published since the use of organophosphates in New Zealand stopped. Sources The information in this report comes from the authors' consultation with the following researchers and agricultural experts in New Zealand: Jim Walker, PhD, Technical Research Scientist, New "Zealand HortResearch Mike Butcher PhD, Technical Manager, New Zealand PipFruit Association Peter Shaw, PhD, Research Entomologist, Insect Science; New Zealand HortResearch Paul Turner, Liner Plants New "Zealand Geoff Davidson, Oratia Native Plant Nursery, Oratia Phil Smith, Owner, Taupo Native Plant Nufsery, Taupo Mark Dean, Owner, Naturally Native, Tauranga Chris Green, "Technical Support Officer, Biodiversity (Invertebrates and Biosecurity) Department of Conservation Phil Knightbridge, Department of Conservation, Botanist John Clearwater PhD, Research and Consulting, Pheromone Technology, Organic Growing Systems, Auckland Ian Videan, Eskdale Orchard, Napier REFERENCES Begum et al. 2006. Using selective food plants to maximize biological control of vineyard pests. Journal of Applied Ecology,43: 547-554. 13 Garvey, K. K. 2007. "Entomologists Targeting Light Brown Apple Moth." University of California News. http://www.universityofcalifornia.edu/news/article/9323 Irvin, N.A., S.L. Scarrett, S.D. Wratten, C.M. Frampton, R. B. Chapman, and J.M. Tylianakis 2006. The Effects of Moral understoreys on parasitism of leafrollers (Lepidoptera:.T'ortricidae) on apples in New Zealand. Agricultural and Forest Enlonrolok,y 8, 25-34. "N7, forest provides laboratory for pheromor.Xe trials" 2/17/08; http://nz.news.yalioo.com//080217/3/40zs.htiiii Thomas, W.P. 1987. A Review of Biological Control ofInverlebrate Pestsand Weeds in Neil,Zealand 1.974 to 1987. Emerson, P.J., R.J. Hill, J. Bain, and W.P. Thomas. Wollingford: CAB International. i.. per•; •' :. . r x. p:V s: .:.., ..:.. W. , , r. ^ a. . , . ' s:. 04 nl p . Figure 2. Superficial leaf damage from LBAM larva About the Authors Dr. Daniel Harder is the Director of the University of California at Santa Cruz Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary Biology at UC Santa Cruz. The Arboretum maintains an extensive collection of 14 Australia, New Zealand, Calil:ornia natives, and southern hemisphere species within a 100 acre botanical garden on the UCSC campus. Dr. Harder is an expert on plants of Asia and the Pacific Region, and Africa and has published papers on his research on the floras of Central Africa and Viet Nam including works on the pharmaceutical properties of plants, taxonomy, ethnobotany, and new species discoveries. teff'Rosendale is a grower and horticultural consultant in the Monterey and San Francisco Bay Areas who specializes in the cultivation and uses of plants from California, Australia, South Africa, New Zealand and Mediterranean Europe. 15 Bay Area Legislators Introduce Bills to Tackle Light Brown Apple Moth SACRAMENTO Assemblvnnembers John Laird (D-Santa Cruz), Loni Hancock (D-Berkeley/Oakland Mark Leno (D-San Francisco) and Jared Huffman (D-San Rafael) today introduced a 4-bill.legislative package to address the eradication effort for the Light Brown Apple Moth and other invasive species. in addition, Assemblymember Laird released draft language for an Assembly Concurrent Resolution to be introduced next week. Bill descriptions unci comments,Porn Assemblymember-s: AB 276 i would enact the Invasive Pest Planning Act of 2008, by r�ssemblvmember John Laird. The bill would requifo the Department of Food and Agriculture to create a list ofjnvasive animals, plants, and insects that have a reasonable likelihood of entering California for which an eradication program might b appropriate. For each invasive on the list, the department would prepare a written assessment on the mos appropriate method of eradication. If pesticides were to be used, the assessment would have to discuss application methods, the chemistry of the pesticide and its inert ingredients, impacts on public health and the environment. The department would have to coordinate with the State Department of Public Health, the Department of Fish and Game, and other state health agencies. The department would have to hold public hearings. If a pest was found, the department would have to notify various local agencies, hold public hearings, and comply with other requirements. ""The state was not adequately prepared for the Light Brown Apple Moth,". said Assemblymember Laird. "This won't be our last experience with an invasive pest. But in light of climate change, international travel patterns and chronically underfunded federal inspection programs, we ought to put in place a pest planning process that prevents the kind of public fear and confusion we've experienced to date with the Light Brown Apple Moth." AB 2764, by Assenlbly".oman Lon Ilancock., will prohibit the Secretary of Food and Agriculture from approving the application of a pesticide in an urban area, unless the Governor has proclaimed a state of emergency. Current law allows the Secretary of Food and Agriculture, to proclaim any area in the state eradication area with respect to a pest, prescribe the boundaries of the area, and name the pest or host of pests that are known to exist within the area, together with the means and methods that are to be used to eradicate or control the pest. Assemblymember I lancock's legislation will increase the level of responsibility the administration has to take and will provide more transparency. In addition, the Governor will be able to solicit input from all of his state agencies including Department of Health and relevant environmental agencies. "We are trying to bring some transparency to a process that seems.to favor economic interest over public health. The fact that the Department is now doing an EIR that won't be complete until sometime alter tht spraying has commenced brings into question the openness of this process. We believe that there are significant questions that remain unanswered and we are trying to get answers for our constituents before the spraying occurs," said Assemblywoman Loni Hancock. j AB 2765, by .lssemblvmember I lulIman, sets new limits on the emergency powers of the Department of Agriculture. It requires a public hearing to receive testimony and examine alternatives to aerial spraying prior to any decision to spray. It further bars emergency spraying in an urban area unless there is full disclosure,of all elements in any pesticide product, and a certification of the safety of the product by state health officials. "I want to make sure that people in communities affected by a proposed eradication strategy for LBAM c any other pest have better information and a meaningful opportunity to engage in the process before decisions about aerial spraying are made," said Assemblymember Huffman. "At a minimum, we need ar open and transparent public process, full disclosure of spray ingredients, and safety assurances based on sound science." AB 2760, by Assemblyman L en.o would require that an Environmental Impact Report be completed before the state Department of Food and Agriculture can apply pesticide in an urban area for the eradication'of the light brown apple moth. "We cannot even begin a discussion about the current plans of eradicating the light brown apple moth before we understand the impacts of the chemicals the state is proposing to spray in urban areas," stated Assemblyman Mark Leno. "My measure will require that before any spraying can begin, the state must complete an.Environmental Impact Report that will tell us what impacts the specific mix of pheromone and other chemicals will have on our children, families and communities. The report will arm us with thi information we-need to help the state and communities make an informed decision. Too much is at stake to enter into the discussion without all of the facts." Leno said. Draft Assemblv Concurrent Resolution by Assemblymember Laird The following is the draft concluding langua;-,e for an Assembly Concurrent Resolution to be introduced next week focused on CDhA's response witki regard to conducting its LBAM eradication effort: "Resolved. it is the responsibility of the government to demonstrate that its actions are necessary, appropriate, and do not compromise health or the environment. It is not the responsibility of citizens to demonstrate the reverse. Resolved, the various state departments and agencies involved in the LBAM eradication effort need to address the-unresolved health, scientific, and efficacy issues concerning the 2007 eradication effort. Resolved, that these departments and agencies need to take the steps necessary to ensure, in any future actions, that human health and environmental impact issues are appropriately evaluated and addressed." "Robert Lieber" To: comments@cob.cccounty.us. ` <lieber.home@yahoos cc: om> Subject: BOS Agenda Comments from Website 03/10/2008 06:05 PM Please respond to "Robert Lieber" This message was sent from: http://www.co.contra-costa.ca.us/depart/cao/agendacomments_form.htm ------------------------------------------------------------ Name of sender: Robert Lieber Address of sender: 734 Kains Ave. Albany 94706 Phone of sender: 510-558-9054 Email:of sender: lieber.home@yahoo.com Agenda Date: 03/11/08 Agenda Iteml: D.2 Agenda Item2 : ------------------------- COMMENTS ------------------------- Mayor Robert Lieber RN 734 Kains Ave. Albany, Ca. 94706 510-703-1876 California Department of Food and Agriculture (CDFA) .Secretary Kawamura's recent dog and pony show that he has been trotting out before many City Councils and Commissions promoting the Light Brown Apple Moth (LBAM) aerial pesticide spraying of the Bay Area relies on blatant misrepresentations of the truth, fear-mongering and outright lies. The spray program he defends imperils California's families, children, pets, and the environment, based on no real science and no solid facts. The real facts are simple. CDFA sprayed Monterey and Santa Cruz counties, and at least 643 people got sick. They reported their illnesses although the State . made no infrastructure available. The State only accepted health complaints on offical EPA forms signed by a physician, but physicians were not trained to assess the toxic exposure associated with the spray. Anyone without insurance or access to a physician could not "officially" report health problems. Secretary Kawamura's assertion that there were no,adverse reactions to the spray is an outrageous bureaucratic determination, not a true health assessment. And that is only the beginning of the Secretary's swift boating. He has the audacity to imply wide support for the spraying from environmental organizations. In fact, the Sierra Club is on record, along with 25 other health and environmental groups, opposing the aerial spraying. . +u Make no mistake about it, the chemical .used last year, Checkmate, is a pesticide despite Secretary Kawamura's white-washing talk of harmless pheromones. The facts: Checkmate is made up of three components that have either not been tested or are known to be dangerous: 1) the synthetic moth pheromone: not tested for long-term human exposure risk. The State's own health Consensus Document includes a disclaimer that it is based on studies that assume the pesticide will be sprayed over unpopulated agricultural areas. 2) the so-called inert ingredients (not inert meaning inactive; "inert" only means they do not target the pest) :contain carcinogens, mutagens, reproductive effectors, .liver toxins, skin irritants, and are unsafe to inhale. 3) The microscopic plastic capsules in which the pesticide is sprayed, which time-release over 30 days: Inhalation risk is unknown, but U.C. Davis scientists found some particles are small enough to be inhaled into the deep lung where they cannot be expelled. It :doesn't take a scientist to know that can' t be good. Secretary Kawamura focuses only on the LBAM aerial spraying, ignoring the program's other toxic and questionable practices, including requiring wholesale nurseries to use the organophosphate pesticide chlorpyrifos, employing state personnel to install traps and use pesticides in private yards that are toxic, especially to cats, honeybees, and the beneficial predators that naturally keep pests in the environment - including LBAM -- in check. Secretary Kawamura's fear-mongering comments that, if left unchecked, LBAM will destroy every green plant in the state and possibly the country is contradicted by facts: Even CDFA says there has been no crop damage attributable to LBAM in California. Professional biologists testify that LBAM is a minor pest in New Zealand where it is also an introduced exotic species. New Zealand's biggest LBAM problems are from a U.S. Department of Agriculture (USDA) quarantine, not from actual damage. In addition, entomologists agree that LBAM has likely been in California for 10 years, so if there was going to be crop damage, wouldn't we have seen it by now? So now we come to the Big Lie about the "pest that was never a pest. " Decades ago, LBAM made it onto a USDA list of supposedly voracious invasive species. To date, I have been unable to find this original. designation. The main goal was, I believe, to protect powerful U.S. agriculture interests from competition from..crops from New Zealand and similar areas. As a result, today we have the "Light Brown Apple Moth Emergency. " Secretary Kawamura expresses concern that. other states' and countries might ban California produce because of LBAM - even though, those countries' quarantine restrictions were adopted to mimic the U.S. 's. Note that Europe does not quarantine for LBAM. So the plot sickens. It's all about money. .Big money. Rather than admit that LBAM is not the. threat that's been claimed and request that LBAM's USDA classification be revised based on up-to-date science, Secretary Kawamura is willing to poison us and our environment. And to spend $500, 000 on a public relations firm to help "sell" this charade to us. . I am ashamed .of Secretary Kawamura's disgraceful public deception campaign to sell a hopeless, dangerous and likely unneeded "eradication" program to the people. He should immediately call an end to the plans'. to give us time to make rational decisions based on sustainable, Integrated Pest Management principles. 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CO 'ccs •i� (� ul ca cv co • f Stewart Resnick, CEO Roll International tANNA • Listed on Forbes.com as one of the 300 largest MW private companies in the United States ` . ' - " . ,"° • Los An eles based conglomerate with RIF- companies in agribusiness, floral services and pesticide control products • Major political contributor with contributions ' to various candidates and political action groups including Arnold Schwarzenegger M0 jr15 -.. W-1 i.. C .r'�L.`�r'� D Q I l`v"�' ,FP,� I}F..:k ! The leader.in bioratio.jl gest control prc ducts, naturally. Mr. Resnick has developed and Suterra is a limited liability company that owns a number of successful manufactures pest control products one of which is companies including Paramount Checkmate to be used the proposed spraying for the Agribusiness, the largest farming LBAM operation of treecrops in the world. (.r—F1 Imo. r: _� o,: i -_=_ -- _ - 7 February 26, 2008 Oakland City Council Public Safety Meeting--CDFA Aerial Pesticide Spray Statement: My name is Lisa Tracy. I am an Oakland resident of 10 years, mother of three children, with a PhD from UC Berkeley School of Social Welfare. I represent Stop the Spray--East Bay. I will address Pest Management Issues: 1) The CDFA states there has been NO crop damage due to LBAM thus far. 2) World renowned UC Davis entomologist Dr. James Carey says there is near zero chance of eradication of the moth. He and other scientists say the moth has likely spread beyond the 9 counties being sprayed. 3) Independent entomologists say the moth has likely been here for at least 10 years. Given no crop damage, it is likely the moth is being controlled in the natural environment. 4) Dr. Daniel Harder, Executive Director of the UC Santa Cruz Arboretum, says LBAM is considered a minor pest in New Zealand and Hawaii where it was introduced over 100 years ago. New Zealand's climate and ecosystem are similar to ours. 5) There are least toxic ground based solutions for controlling the moth including release of natural predators and sterile male moths, sticky traps, and more. 6) The effects of the pesticide on non-target species is unknown. However, toxicologist Dr. Richard Philp says very similar pheromones are known to be toxic to aquatic life. 7) Dr. Harder points out the pesticide manufacturer cautions against its use on irrigated crops to avoid concentration of the pheromone in runoff. With aerial spraying it will definitely end up in our water systems and in the Bay. 8) In conclusion, the state has not demonstrated the need for or effectiveness of the spray, and the mostly unstudied but potentially serious long term risks it poses to human health and the environment makes it, in my opinion, unconscionable for the State to spray populated areas. We urge your Committee to join the City of Albany and others in taking a strong stand against the spray and demanding in- depth long-term study of any potential health effects. 9) With my background in social work research and practice with the homeless, immigrants and refugees and other low income populations, I am very concerned about adverse impacts on these groups due to lack of awareness of the spray and needed protective measures, and pre-existing health conditions. As a mother of children ages 2 to 9, given the potential health impacts on children, I would seriously consider moving out of the Bay Area permanently if the spraying occurs. I know I am not alone in this sentiment. 10)'I'hank you to the Councilmembers Brunner and Reid for putting forth the resolution and to all the Committee members for your serious consideration of and action on this issue. Lisa C. Tracy, M.S.W., Ph.D. 4706 Manila Ave. Oakland, CA 94609 (510) 595-7224 lisa.tracy@sbcglobal.net Please Put Citizen's Health and Environmental Concerns First- Postpone the Arial Spraying for the Light Brown Apple Moth in Contra Costa County March, 11, 2008 Lori J. Anders Resident of Moraga, CA Active Member, Parent's for a Safer Environment Active Member, Lamorinda Moms Club With aerial spraying scheduled to begin this August in Contra Costa County, we urge the county to postpone the plans until we have further research on the possible health risks and environmental impacts as well as evidence that spraying actually works and time to consider other possible effective ways. After reviewing much of the research, the main concerns are: 1. Not enough research on pheromones and humans (assuming insect and human pheromones are very different, but there is still very little research on how pheromone systems work in humans, and the research on insects is very new as well (last 5 years) 2. Not enough research on environmental impacts yet 3. Not enough proof yet to show .LBAM is causing widespread damage, looking at New Zealand's history, they have not had the crop damage that experts are warning of, despite a long history with the LBAM 4. Unknown health risks from inerts, and inhalation risks This is a perfect opportunity for the county to show precaution before action and avoid causing unnecessary harm. Focus needs to be on protecting our most vulnerable citizens (the fetus, children, Elderly, and immune system compromized). As we are moving towards an Integrated Pest Management Program and working to minimize the use of harmful pesticides, we should have more time to review the evidence and access the risks and efficacy before investing so much money on spraying. We appreciate your efforts to making our county a safer place to live. Sincerely, Lori J. Anders March 10, 2008 Dear- Members of the Contra Costa County Board of Supervisors: I am writing to ask you to pass a resolution opposing the State of California's plan to spray aerial pesticide over densely populated counties in California in the vain hope of eradicating the Light Brown Apple Moth (LBAM). l ask that you use your influence, informed by the research of respected scientists and citizens in California who have raised concerns about the effects of aerial pesticide spraying on human and environmental health. to initiate legal action against the State if necessary. I also ask that you work with the State of California and Secretary Kawamura to develop a comprehensive statewide plan for implementing pest control measures that have been tested prior to application, and have been deemed safe for people and the enviromnent based on the tenets of the Precautionary Principle. It is essential for the Contra Costa County Board of Supervisors to work with other local governments to oppose this spray program in order to protect the health of Bay Area residents. especially the most vulnerable populations including the very young, the elderly, and those with respiratory conditions and allergies. As the mother of two very young children, I am very concerned that the California Department of Food and Agriculture (CDFA) is spending public funds on a massive and deceptive public relations effort to promote this aerial spray program despite: • lack of long-term human toxicity testing of the chemicals being used • the known toxicity to aquatic life of ingredients in the pesticides • the unknown human health risks of the microscopic plastic capsules and 'inert' ingredients that carry the pesticide • the unknown risks to pets, honeybees, and beneficial predators that naturally keep pests — including LRAM — in check • more than 600 health cornplaints following spraying in fall 2007 in Santa Cruz and Monterev Counties • the fact that LBAM has not caused crop damage in California in the (at least) 10 years it has been documented here • the fact that LBAM, also an exotic species in New Zealand. is a minor pest there • biolooists' expert testimony that eradication has almost no chance of success • the availability of minimally toxic, environmentally-friendly control measures used for other similar"leaf-roller" pests that are already present in California • massive public opposition to the spray program The City of Pacific Grove: the City and County of Santa Cruz; the Cities of Albany, Berkeley, and Oakland; and the Sierra Club have already passed resolutions opposing aerial spraying of 1 Californians and calling for a safer approach to controlling LBAM. Please join these leaders in communicating Contra Costa County's opposition to aerial spraying to state and federal officials. i Sincerely, Rita Ga.ber 200 Ramona Avenue El Cerrito. CA 94530 Parents for a Safer Environment, Steering Committee Member U.C. Berkeley PhD Candidate. 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W a 2af2E 0Y W M2LL � � 2 LY LY � tY � 5Z � � ZZtY � ZLY � � ZLY g H LL LL LL W LL a' LL LL x LL ¢ a' LL Q ¢ LL (r ¢ LL LL Q LL LL i6 Z O U } J } J (n } Z J LL } J J LL J } LL W LL J LL w J LL W >' J W J U ww ~ a < a ¢ ¢ Luaw ¢ = a ¢ ¢ ¢ ¢ � = zz ¢ zz ¢ zzcr> ¢ z < < v g OX } z } z U Q } m z U } z z > z } U O z M z v v >LL z z v m Q W w O O � < O Q a 0 C7 O a W 2 af W w E a w LU O w w aZ O O VO 00 O o 0000 0 000 k4■ 0 CL O 2 2 2 Z Q U z W + > Q 0 N M W V LO co N 00 m O 0 W 00co00m 00 co 00 co (M m Q W U a � uv "Robert Lieber" To: comments @cob.cccounty.us A%i. <lieber.home@yahoo.c cc: (` om> Subject: BOS Agenda Comments from Website 03/10/2008 06:05 PM Please respond to "Robert Lieber" This message was sent from: http://www.cc.contra-costa.ca.us/depart/cao/agendacomments_form.htm ------------------------------------------------------------ Name of sender: Robert Lieber Address of sender: 734 Pains Ave. Albany 94706 Phone of sender: 510-558-9054 Email of sender: lieber.home@yahoo.com Agenda Date: 03/11/08 Agenda Iteml : D.2 Agenda Item2: ------------------------- COMMENTS ----- Mayor Robert Lieber RN 734 Kains Ave. Albany, Ca. 94706 510-703-1876 California Department of Food and Agriculture (CDFA) Secretary Kawamura's recent dog and pony show that he has been trotting out before many City Councils and Commissions promoting the Light Brown Apple Moth (LBAM) aerial pesticide spraying of the Bay Area relies on blatant misrepresentations of the truth, fear-mongering and outright lies. The spray program he defends imperils California's families, children, pets, and the environment, based on no real science and no solid facts. The real facts are simple. CDFA sprayed Monterey and Santa Cruz counties, and at least 643 people got sick. They reported their illnesses although the State made no infrastructure available. The State only accepted health complaints on offical EPA forms signed by a physician, but physicians were not trained to assess the toxic exposure associated with the spray. Anyone without insurance or access to a physician could not "officially" report health problems. Secretary Kawamura's assertion that there were no adverse reactions to the spray is an outrageous bureaucratic determination, not a true health assessment. And that is only the beginning of the Secretary's swift boating. He has the audacity to imply wide support for the spraying from environmental organizations. In fact, the Sierra Club is on record, along with 25 other health and environmental groups, opposing the aerial spraying. Make no mistake about it, the chemical used last year, Checkmate, is a pesticide despite Secretary Kawamura's white-washing talk of harmless pheromones. The facts: Checkmate is made up of three components that have either not been tested or are known to be dangerous: 1) the synthetic moth pheromone: not tested for long-term human exposure risk. The State's own health Consensus Document includes a disclaimer that it is based on studies that assume the pesticide will be sprayed over unpopulated agricultural areas. 2) the so-called inert ingredients (not inert meaning inactive; "inert" only means they do not target the pest) :contain carcinogens, mutagens, reproductive effectors, liver toxins, skin irritants, and are unsafe to inhale. 3) The microscopic plastic capsules in which the pesticide is sprayed, which time-release over 30 days: Inhalation risk is unknown, but U.C. Davis scientists found some particles are small enough to be inhaled into the deep lung where they cannot be expelled. It doesn' t take a scientist to know that can' t be good. Secretary Kawamura focuses only on the LBAM aerial spraying, ignoring the program's other toric and questionable practicer, including requiring wholesale nurseries to use the organophosphate pesticide chlorpyrifos, employing state personnel to install traps and use pesticides in private yards that are toxic, especially to cats, honeybees, and the beneficial predators that naturally keep pests in the environment - including LBAM -- in check. Secretary Kawamura's fear-mongering comments that, if left unchecked, LRAM will destroy every green plant in the state and possibly the country is contradicted by facts: Even CDFA says there has been no crop damage attributable to LBAM in California. Professional biologists testify that LRAM is a minor pest in New Zealand where it is also an introduced exotic species. New Zealand's biggest LBAM problems are from a U.S. Department of Agriculture (USDA) quarantine, not from actual damage. In addition, entomologists agree that LBAM has likely been in California for 10 years, so if there was going to be crop damage, wouldn't we have seen it by now? So now we come to the Big Lie about the "pest that was never a pest. " Decades ago, LBAM made it onto a USDA list of supposedly voracious invasive species. To date, I have been unable to find this original designation. The main goal was, I believe, to protect powerful U.S. agriculture interests from competition from crops from New Zealand and similar areas. As a result, today we have the "Light Brown Apple Moth Emergency. " Secretary Kawamura expresses concern that other states and countries might ban California produce because of LBAM - even though those countries' quarantine restrictions were adopted to mimic the U.S. 's. Note that Europe does not quarantine for LBAM. So the plot sickens. It's all about money. Big money. Rather than admit that LBAM is not the threat that's been claimed and .request that LBAM's USDA classification be revised based on up-to-date science, Secretary Kawamura is willing to poison us and our environment. And to spend $500, 000 on a public relations firm to help "sell" this charade to us. I am ashamed of Secretary Kawamura's disgraceful public deception campaign to sell a hopeless, dangerous and likely unneeded "eradication" program to the people. He should immediately call an end to the plans to give us time to make rational decisions based on sustainable, Integrated Pest Management principles. Mayor Robert Lieber, RN City of Albany ------------------------------------------------------------ I,BAM Control Statement of Concern Parents for a Safer Environment Director Honorable Contra Costa County Board of Supervisor members: I have spoken to over 50 community members regarding the moth aerial spraying issue in Contra Costa County and had the opportunity to speak with a number of directors from advocacy groups such as the Breast Cancer Fund and Communities for a Better Environment, Assembly member Fiona Ma and staff from Assembly member Carol Migden's office during a recent Breast Cancer conference. I have yet to meet one person who is not very concerned about the LBAM aerial spraying. The following are some of the reasons for using safer alternatives to the aerial spraying for LBAM. ® CDFA expects the spraying will continue monthly l:or 3-5 years or indefinitely until the moth is eradicated. ® The pesticides beim* used consist of three components: a moth pheromone (sex hormone) designed to confuse mating. several inert ingredients. and microscopic plastic capsules in which the pesticide formula is encased. The capsules break down over about 30 days, releasing the pesticide. N The active ingredient (the pheromone) has not been tested for long-term human exposure risk; the inerts include suspected carcinogens, and substances most of us wouldn't choose to inhale or have exposure:. the inhalation risk of the plastic capsules is untested and unknown. ® More than 600 people reported health complaints after residents of Monterey and Santa Cruz counties were sprayed. These are only acute symptoms. We know nothing about chronic, or lone-term health effects. ■ CDFA acknowledges that the moth has done no crop clamage in CA and independent entomologists say it has likely been in the U.S. at least a decade. ® According to Dr. i larder of U.C. Santa Cruz, the moth is a minor pest in New "Zealand where it has been an introduced exotic for more than 100 years and where climate, crops, and natural predators are similar to California's. I quote Dr. Harder from his "IPM Practices for the LBAM in New Zealand: Implications for CA:-Today, LBAM is effectively controlled almost exclusively by natural predators in both agricultural settings and wild lands in New Zealand. There is no evidence of biological or environmental threat from LBAM in New Zealand.... "The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf- roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also Found in California. Adopting IPM best practices would include suspending planned aerial and ground treatments for LBAM in California and monitoring to determine extent to which LBAM populations are being parasitized or destroyed by predators. United States Department of Agriculture (USDA) classification of LBAM as an actionable quarantine pest should be reviewed and revised based on current, relevant, science based information.." Dr. Iiarding delineates that New Zealand researchers report that pheromones will only work under specific conditions that include: extensive, even and complete coverage for the pheromone, in uniform blocks of a single crop (single canopy height), uniform topography (no slopes, hills or valleys), and low population density of target pest. In another words, pheromones applied by any means cannot be effectively used across large diverse areas with varying canopy heights, mixed species composition, and varying terrain areas. In addition"New Zealand researchers have found that aerial pheromone spraying interferes with monitoring using pheromone traps, interfering with the critical tool to control the moths. Furthermore, Entomologist Dr. Shaw of New Zealand found that female moths emit a stronger scent than the aerial pheromone application, so male moths are able to find the females anyway. i.e. the effectiveness of the pheromone via aerial application is unlikely. I'd like to alert the Board ol'Supervisors and Dr. Wendell Brunner who is probably well- aware that there are deadlines on March 18`t' and 20°i for State and Federal LBAM associated comments for the EiR (environmental impact report) and public comments. I encourage you to consider all the scientific evidence and not speculations and theories that are being proposed and practice caution on this issue. As the daily inspirational thought for today infers. the seeds we plant today will determine our future and this is what will be the measure of our achievements. Most concern is for the exposure to the fetus, children under 8 whose immune systems have not matured, those w/ pulmonary problems and those immunosuppressed, such as those w/ immune problems and undergoing chemotherapy. My cursory review concludes that USDA is not_justitied to spray aerially and a recent study show that it may not even be necessary, as seen in New Zealand. The Community is opposed to aerial spraying and supportive of cooperating to use the safer alternative of bait stations for control of the moth, not necessarily eradication, which appears infeasible. State politicians such as Carol Midgen has opposed spraying over San Francisco and Marin Counties. Oakland, Albany, Berkeley and Fairfax city councils formally opposed the aerial spraying over their communities. Last Bay Regional Park union workers opposed the spraying. California Certified Organic Farmers (CCOF) announced today that CCOF is now opposing the aerial spraying for LBAM. Thank you for seriously considering the concerns by your commtulity and providing us with an opportunity to express our views on the LBAM issue. wAvw.p.fsc.net 925-283-4609 Integrated Pest Management Practices for the Light Brown Apple Moth in New Zealand: Implications for California Daniel Harder, Ph.D. Executive Director The Arboretum, University of California at Santa Cruz Jeff Rosendale, C;rower, Horticultural Consultant Watsonville CA March (, 2008 ABSTRACT The Light Brown Apple Moth, F.pipl7i.ws posrnittirncr (LBAM) has been in established exotic species in New Zealand for more than 100 years. The authors conducted a three-week, 3,000-kilometer fact-finding study in New Zealand's two major agricultural regions to assess integrated pest management (IPM) of LBAM and applicable strategies for California. LBAM was considered a problem pest in New Zealand orchards during the 1.980s when regular, calendar applications of broad- spectrum organophosphate pesticides had eliminated the beneficial insects that prey on LBAM. However, since elimination of organophosphate treatments in 2001. and subsequent restoration of populations of benelicial insects and other organisms, LBAM is considered a minor pest that does not cause economically significant crop damage or have detrimental effect on native flora. Today, LBAM is effectively ` controlled almost exclusively by natural predators in both agricultural settings and wild lands in New Zealand. There is no evidence of biological or environmental threat from LBAM in New Zealand. Because of United States' zero-tolerance quarantine requirements for LBAM, New Zealand horticultural/agricultural professionals use pheromone sticky traps to monitor LBAM populations and, based on monitoring data, timed ground applications of insect growth regulators (IGRs) are used in select agricultural settings to prevent shipments from being rejected for export to the U.S. The success of New Zealand agriculture and horticulture professionals in controlling .LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. Adopting IPM best practices would include suspending planned aerial and ground treatments for LBAM in California and monitoring to determine extent to which LBAM Populations are being parasitized or destroyed by predators. United States Department of Agriculture (USDA.) classification of LBAM as an actionable quarantine. pest should be reviewed and revised based on current, relevant, science- based information. "rhe negative impact of organophosphate use on beneticial predator species in New Zealand, along with the known health and environmental dangers of these chemicals, suggests that current requirements for organophosphate controls for- LBAM in nurseries and elsewhere in the U.S. should be abandoned. Introduction This report describes results of a January 2005 fact-finding study on integrated pest management of the Light Brown Apple Moth (.LRAM) in New Zealand. The study was undertaken to understand the extent of LBANI's effect on New Zealand's agriculture and natural environment and the methods of managing LBAIVI, with the goal of understanding potential impacts of and best management practices for LBAM in California. The authors focused on understanding best management practices for control of LBAM and how these strategies impact the cultivation of plants in botanical collections in gardens and arboreta as well as in commercial nursery and agricultural cropping systems. New Zealand was chosen for this research because its climate and crops are similar to California's coastal farming areas and because LBAM was introduced to New Zealand from Tasmania and first reported in New Zealand in 1591 (Thomas, 1957, HortNet http://www.lioi-tnet.co.nz/key/keys/info/distrib/lba-dist.htm) and thus has been an established exotic in New Zealand for more than 100 years The remainder of this report describes the study's research methods and presents .findings and discussion on LBAM biology and behavior, hosts, populations,damage, and control in New 'Zealand, as well as LBAM's role in global trade of New Zealand agricultural products. Methodology The authors traveled and conducted interviews with government, agricultural, and horticultural entomologists and researchers of LBAM and insect pests as well as wholesale and retail agricultural and horticultural producers and plant conservationists. They also conducted field searches for LBAM presence and damage in commercial agricultural fields, orchards. native habitats including Abel Tasman National Park, and along roadsides. The research was carried out over a period of three weeks, January 4 - 29, 2005, which is mid-summer in New Zealand when LBAM would be expected to be active in all life stages and readily observable. The goals of the research were to learn from agriculture, intefgrated pest management(IPM). entomology, and conservation experts about LRAM in New Zealand and to identify IPM strategies that would be effective against LBAM in California. The authors focused on the two main agricultural production areas of New 'Zealand: on the North Island, the I lawke's Bay region, known as the "fruit basket " of New "Zealand where the major produce is apples, nectarines, kiwis, wine-;,rapes and assorted row- crops; and on the South Island, the Nelson agricultural region, which is a major production area for apples, currants, hops and wine-grapes. See Figure 1. s. . ..::..;':a':fie.w•:��' r. s.� A a. i ,. v ;s:• _ ;. rt':,p�,;.:•:'::.:.��;.T'.5. .:;.est":' $:< ... Figure 1. .New Zealand neap Both the i lawke's Bay (Napier) and Nelson areas are similar in terrain and mixed forest areas to California's Monterey Bay and Santa Cruz areas where the California LBAM presence is most dense. The Hawke's Bay region is a bit warmer and moister than Monterey Bay, making it an ideal climate and study arca for LBAM. These agricultural regions also have a long history of studying and controlling LBAM and have developed technologies to best protect crops. As shown in Table 1, Nelson and Napier have climates very similar to California's Central Coast. Comparison of Temperature Ranges,Average Mean Temperatues and Precipitation in Monterey,California and Napier,New Zealand in 2007. Months have been aligned to season. 2007 January February March April May June July August September October November December Santa Cruz,California, ern—at-a l:ar Via;-! 1 39/6' 41/67 42j G5 4.3/69. 4.x./71 49/'i4 `:1/76 52/:9 i0/7] ii%4 42/66 30(63 le'! :F; 44 52 53 55 58 62 62 63 SJ 56 51 r eupita:icr.(.r_nes) t.4 S.S 0.7 •3.2 0.1 0.= 0.3 1.3 3.5 5.4 June July August September October November December January February March April May Napier,New Zealand r:•nip�.at ir,R:;nyr(F) '31/61� :6/65 35/66 33/67 31/77/ 4.3/83 4ti/E3 45/83 47/EX, 46/`:S 30/75 30 i 72 eyr.:e peat fF; 49 50 50 s.. SS 50 64 66 64 6" .+ SS I'—pt,ti:1(i•lchcs) 3.G ,... _._ e._ 1.6 2.9 1.e 2.2 2.'/ 2.5 2.7 Sc•j2'ec rd.corr. htl;•//r:: Table 1. Comparison of-Santa Cruz...CA and Napier,NZ Temperatures and Rainfall 3 The southernmost area of New Zealand was not visited because its colder,harsher climate is both less hospitable to LBAM than the warner climate farther north and dissimilar to the climate of areas where LRAM.is presently found in California. in addition, New Zealand cultivates hundreds ofthousands of hectares of Monterey pine (Pinus radiata) and has planted many Californian species including vintage Monterey cypresses (Cuprressus tnacrroear-13a), glint sequoias (Sequoi(16107611-017,i(,"rnNewn), coastal redwoods (Scgiioicr.yetrrpervn-en.$), as well as native New Zealand conifers. Results and Discussion The subsections below present findings related to LBAM, its biology, behavior, enemies (beneficial control agents), populations, damage, control in New Zealand, and role in New "Zealand agricultural trade. Biology and Behavior of LBAM LBAM. is a tortricid (Tortricidae) moth and a member of the leaf-roller moth family in the order Lepidoptera. Each LBAM individual exhibits three life stages: larva, pupa, adult (moth). LBAM is polyphagous, meaning that it is not host specific but rather feeds on a variety of plant species. A superficial feeder as a larva (see Figure 2), LBAM typically causes cosmetic damage to the surface of leaves and fruit and only rarely penetrates a host fi•uit. LBAM does not defoliate plants. Defoliation is contrary to leaf rollers' biological need for leaves that, with the help of thread material, the larvae roll around themselves for protection. The rolled leaves provide protection from predators and the ideal conditions for growth and development. Like all leaf rollers, LBAM is subject to natural predation and parasitism. Major predators and parasites in New Zealand include: birds, spiders, wasps, flies, beetles, lacewings, and earwigs to name only a few. A full listing of enemies to LBAM can be found at: littp://www.liortnet.c.o.nz/key/stone/info/enemies/lba-enem.litm LBAM may mate up to three times during its I- to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per egg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (Hort.Net Website at littp://www.hortnct.co.nz/pubIicat ions/proceedings/ifoam/ilbamEi9.htm) Adult LBAM travel an average of approximately 100 meters from their hatching sites during their lifetimes and are not necessarily particular about where ovipositioll (egg- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of'survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous... LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. 4 m`. > SnF.'•. IOIL . .. .xC ...: .•�: .:..:..:: ,'r ..ver ..... .. .,. ...t:.. 'x.> '... �` x�.$.': , 0 is•. s` �a•� �� �I I III�F s Y.. 4 .Figure 2. Superficial leaf damage from LBAM larva LBAM may mate up to three times during its 1- to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per egg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (HortNet Website at http://www.liortnet.co.nz/pub 1 ications%proceedings/i foam/ifoam69.htni) Adult LBAM travel an average of approximately 1.00 meters from their hatching sites during their lifetimes and are not necessarily particular about where oviposition(egg- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. LBAM Hosts aild Populwions in ,Veit,Zea/arid Although LBAM is considered by New Zealand LlortResearch, the government agricultural and horticultural research agency, to be "common" in orchards throughout New Zealand and "less common, rare, or even absent" in areas of New Zealand still 5 covered in native lorest (1 iortReseareh 2008 ..... LBAM is, in tact, difficult to find in New Zealand. Eighty to ninety percent of LBAM larvae are parasitized by natural predators before maturation (Shaw, 2008). According to New Zealand Ministry of Agriculture and Food (MAF) and Dcpartlllent 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. For meeting U.S. quarantine requirements, LBAM populations in New Zealand are estimated and monitored using pheromone traps. LBAM is not an insect ol�signiticance in Monterey pine plantations in New Zealand. LBAM is a leaf-roller moth that requires flat-surfaced leaves to protect larvae while they mature. Clearwater(2008) notes that LBAM clearly does not have a preference for gymilospernls and is not considered a pest of these plants in New Zealand. Shaw(2008) reports that gorse is a preferred LBAM. host plant in.New "Zealand; however, the authors found no LBAM larvae on gorse in a wide variety of regions in the North.Island and the main agricultural regions of the South Island. In fact, the authors' extensive search for LBAM in native New Zealand habitats during the three-week, 3,000- kill extent of this research trip revealed only a few larvae, one on an exotic planting in a hotel garden, as well as a few tortricid moths flying around porch lights in the evening. No evidence of LBAM eggs, larvae or adults was found in the 22,530-hectare Abet Tasman National Park on New "Zealand's South Island. This national park has a mixture of native and non-native plant species with a multi-story diverse habitat of broadleaves, ferns and conifers. Agriculturalihorticultural researchers in New Zealand noted that,because LBAM larvae are often parasitized, finding a larva does not mean that a viable adult LBAM will hatch. .If a parasite has laid eggs in the larva, the parasite's adults, c.g., wasps, flies will hatch rather than LBAM. Due to the need to understand natural controls for LBAM in California and the similarity oftypes of organisms keeping LBAM under control in New Zealand with those already present in California, monitoring of levels of parasitism of all life stages should begin immediately for LBAM in California. As noted below in the LBAil1 Contt•ol h7 New Zecilund section, researchers in New "Zealand have developed a monitoring protocol that allows them to determine the extent of parasitism of LBAM Populations to prevent unnecessary and costly control efforts based on observation of larvae only. Similar parasitism of LBAM is likely occurring in the regions of California where it is present. 'The Arboretum at the University of California, Santa Cruz has initiated a survey of beneficial insects that may control LBAM. in eight larvae raised to adults, two have been parasitized by natural predators. LBAM Damage in New Zealcind LBAM is currently considered a minor biological pest in New Zealand agriculture, including apple, peach/nectarine, citrus, and vineyard crops. Codling moth ("the worm in the apple,"also a tortricid) and woolly apple aphids are much more significant pests in 6 apples, and thrips and mites are the pests of significance in .New Zealand citrus (Videan 2008) Hawkes Bay horticultural researchers report that, with no monitoring or treatments and if LBAM were uncontrolled other than by naturally occurring trichogranuna or other beneficial insects and organisms, the maximum damage caused by LBAM would be one percent or less of crops (Walker 2008). Reports of damage to crops prior to 2001 in Australia or New Zealand are fi-om the cra 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, insigniticant level. New "Zealand horticulture and agriculture professionals so successfully use IPM strategies to manage LBAM that in more than 3,000 U.S. sllipmCnts of ponle (pip) fruit in 2006, only six were rejected. One positive LBAM find can Cause rejection of a .single 15-ton fruit order(Walker 2008). Thanks to exceptional, modern New Zealand IPM practices, leaf rollers have limited economic impact on fruit or crop production other than occasional shipments rejected by U.S. only because of zero tolerance for LBAM. LB,4il1 Contml in Nell. Zeulmml Beneficial insects are considered the first and best line of defense against leaf rollers, and insect growth regulators (IGRs),which are based on derivatives from natural sources, are the primary insecticide used for leaf roller and codling moth control in New "Zealand. Growth regulators do not negatively affect beneficial insects to any significant degree. Rather, iGRs are relatively target-specific and cause target larvae to mature faster than normal before the larvae are physiologically ready and so die. 'To control LBAM effectively with IGRs, .it is important to target overw.intcring LBAM populations. As cooler weather progresses, adult populations of LBAM drop; adults die off, and larvae do ilot inorph Into adults. The lowest adult ilunlbers occur in late winter. iGRs are most effective when applied as eggs hatch and larvae begin to feed in warmer summer weather. In California, IGRs should probably be applied in May, but the timing heeds to be verified by phenological monitoring using pheromone traps for adult inales (Shaw 2008). Treatments with Icast-toxic IGRs for most other pests, particularly codling moth, which is one of the top apple pests in New Zealand, generally act, along with beneficial insects, as adequate LBAM controls. Biocontrols are effective against all LBAM life stages: eggs, larvae, pupa. and adults. Biocon.trols include native and introduced wasps and native tachinid(Tachinidae) flies. The key to effective control with predators and parasites is to encourage a range of insects attacking all lite stages. 7 In the.Nelson area, roughly four to 10 percent of producers are organic. Because organic systems encourage beneficial insect populations and do not negatively affect beneficial organisms and insects with the use of harsh chemical controls, pests (including LBAM) are not significant problems for localized organic producers. The leaf-roller complex, including L.BA.M and other native New "Zealand species, is readily monitored in the early to mid-spring with a pheromone sticky trap and regular visual inspection. Based on monitoring results, a single IGR spray regime can be effective for season-long control. Growers in the Hawke's Bay and Nelson regions do not use mating disruption pheromones to control LBAM. They monitor in late spring with pheromone traps specific to LBAM and codling moth. If the trap counts warrant, an IGR is applied (e.g. Intrepid, Confirm: methoxyfenozide, tebufenozide). 7:Ihis timed treatment adequately suppresses LBAM and codling moth populations for the year (Walker 2005, Shaw 2008). Pyrethroids (natural or synthetic) are effective controls for LBAM but also are detrimental to beneficial insects and pollinators, making these products undesirable for long-term IPM of LBAM. Pyrethroids are especially detrimental to native and introduced (honeybee) bee populations essential for pollination and to mammals. History of Organo phosphate Control During the late 1980s and 1990s, organophosphates were applied regularly in New Zealand orchards with no monitoring for insect populations. The effort was to create a "sterile nursery" situation where there were no pests and no beneficial insects. Organophosphates were used because of the zero tolerance for LBAM .in produce to be exported to the U.S. The chemicals were applied on a schedule rather than in response to pest populations. 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 fornullation. Use of organophosphates was eliminated in New Zealand in 2001. 1lortRescarch experts report that once the use oi'broad-spectrum organophosphates was stopped and agricultural professionals began monitoring for L.BAAi and timing IGR sprays, all of which allowed beneficial insects to affect LBAM populations, the LBAM problem reduced dramatically so that the moth is now considered a minor pest (except for the challenge posed by the U.S. Department of Agriculture quarantine) littp://www.hortiiet.co.iiz/key/stone/info/control,ibacoiitr/Ir-cliem.litm. Organophosphates were destroying beneficial insects and creating resistant insects, and orchards and vineyards were becoming LBAM breeding grounds. Shaw(2008) reports that, at Nelson/M.otueka, "control trees with no insect or chemical controls used have not recorded any damage from LBAM or other leaf rollers for more than 10 years." HortResearch staff attempted to force LBAM infestation of these trees by introducing LBAM eggs and larvae into the trees to no avail. Any infestation of these trees by LBAM was quickly controlled by native predators without the need for iGRs. 8 "Once organophosphates were removed from the system and populations of benelicials were left to develop naturally, complete control of LBAM was realized in less than years" (Shaw 2008). When organophosphates were compared to natural controls in consistent blocks of apples, control of LBAM was achieved with natural controls in less than two years. Organophosphates never allowed effective control, and LBAM developed resistance to them. It is worth noting that in New Zealand, intercropping has been shown to promote beneficial insect populations, resulting in near-complete LBAM population suppression to below thresholds for use of control measures (Irvin et al. 2006, Begum et al. 2006) Monitoring Spring populations of LBAM in monitoring traps in total numbers per month is key to deciding whether to use IGRs to control the population. Local monitoring of population levels allows tracking of seasonal fluctuations (Shaw 2008). Monitoring programs should assess levels of LBAM. phenologically (at various life stages and, by rearing larvae and eggs from host plants, the degree of predation and parasitism of LBAM. Parasites and beneficial controls may not be seen in early-stage occupation of habitats by LBAM or other invading pests but will develop as the predators respond to the presence of LBAM as a possible host. A monitoring protocol has been developed that allows determination of the rate of parasitism of LBAM larvae. Auckland HortResearch Insect Rearing Lab uses a general- purpose diet to rear LBAM larvae so that they can be observed to see if they are parasitized. Larvae are placed in a capped tube with cotton, allowed to develop at room temperatures, and observed to determine whether LBAM develops normally, parasites hatch, or development is adversely affected by other potential control means. The specifics of monitoring and thresholds for treatment are provided on the New Zealand I i.ortResearch website: http://\vww.hortnet.co..n.z%key/. Eradication and Pheromone Use Widespread LBAM eradication efforts have never been attempted in New "Zealand. A very limited eradication program took place during the 1980s affecting two orchards (200 hectares total) in the Nelson region where an insecticide-resistant LBAM strain had appeared. Twist-tie pheromone strips (1000 per hectare) and ground-applied insecticides were used to eradicate this resistant and localized LBAM population. Eradication is very difficult unless a population is quite limited and well defined. New Zealand researchers report that effective mating disruption using pheromones will only work under the followingspecific conditions: Extensive, even, and complete coverage of the pheromone Uniform blocks of a single crop (single canopy height) Uniform topography (no slopes, hills or valleys) Low population density of taryoret pest(not too concentrated) 9 Under the above conditions, twist ties can be used for control under extensive coverage. 1 lowever, pheromones applied by any means cannot be effectively used across large diverse areas with varying canopy heights, mixed species composition, and varying terrain areas. New "Zealand researchers also note that aerial pheromone spraying interferes with monitoring using pheromone traps, and monitoring is critical to successful control. .Moreover, use of broadcast pheromone spray to eradicate or control the moth is not effective because female moths issue a more concentrated scent plume than the dispersed pheromone scent of an aerial spray application, so male moths are able to find the females (Shaw 2008). Until tests reportedly carried out under a U.S. government contract in 2008 in southern New Zealand forests ("NZ.Forest Provides Laboratory for Pheromone Trials"2008 http://nz.news.yahoo.com/080217/3/p/40zs.html),pheromones had never been aerially applied in New Zealand. These trials are been undertaken within a Monterey Pine plantation and docs not involve applying the pheromone over urban areas. Pheromones have never been used for widespread eradication anywhere in the world. Hort.Research stations on both islands agree that eradicating LBAM in California and anywhere would require extensive, widespread use of 1GRs with repeated applications to address elusive, selected populations. These experts also question the efficacy of bucillus thm-ingiensis(Bt) against LBAM. Bt can also have a detrimental effect on beneficial insects. They report that iGRs do not harm populations of beneficial insects and that IGRs persist on foliage much more effectively than organophosphates did. Larvae emerging from c<,,gs begin to perish as soon as they start feeding on the growth regulators. Tests show IG.Rs are ovicidal as well as larvicidal and not toxic to predatory/bene.ficial insects. The beneficial effects of the application of growth regulators can be seen one to two days atter application (Walker 2008, Shaw 2008). LBAMe7nd Global Trade of'Nerw 7.ealand Agriculttrr•crl PI.Och.las LBAM is not of biological concern on either island in New Zealand but remains a pest of concern only because it is a quarantine pest for exports. USDA considers LBAM an "actionable quarantine pest" and has zero tolerance for LBAM finds in pre-inspection of U.S.-bound fruit shipments. Consignments rejected because of any LBAM life stages are sent to non-U.S. markets, e.g., Europe, which does not have phytosanitary restrictions for LBAM.. Today very few New Zealand fruit shipments are rejected by the U.S. (Walker 2008), which further suggests that New Zealand growers' LBAM controls relying on natural predators and .IRM strategies are successful. 1 lortResearch experts say that when USDA announced during the late 1990s that the U.S. would no longer accept fruit treated with organophosphates because of concerns for th.e safety of fruit handlers and consumers, this was the catalyst for abandomnent of organophosphates and the move to reliance on natural predators and IPM methods. 10 The infonnation on LBAM and IPM in New Zealand reported in this report has significant implications for addressing LBAM in California. First, it is worth noting that, according to the National .Museum of Natural i.tistory Catalog of Type Specimens of Tortricidae (www.sel.barc.Llsda.gov/lep/tort—types list.html), California has 85 native and localized North American species of tortricid moths, none are problematic as a pest. All are kept in check by natural biological controls, so there is confidence to believe that LBAM will also be controlled by native natural predators or parasites. Preliminary studies by the California Department of Food and Agriculture report a high level of parasitization of LBAM larvae by native California trichogranuna wasps. Entomologists speculate that LBAM.may have been in California for as long as a decade already (Garvey 2007), so it is possible that LBAM is already being controlled by natural predators. Many LBAM. predator species in New Zealand are the same or closely related to California species (birds, earwigs, viruses, trichogramma and other wasps, tachinid flies, spiders, beetles, etc.). According to New Zealand information,the pheromone treatment currently proposed for LBAM. will most likely not eliminate nor control LBAM because none of the essential conditions for successful pheromone use can be met. Use of the pheromone cannot be complete (e.g., it cannot be applied over sanctuary buffer zones and along streams/waterways), the pheromone will not be applied over a uniform block but rather over mixed forests and native vegetation, houses, schools, roadways, crops, and ornamental gardens. Moreover, topography of the California coast is highly varied and diverse, and LBAM populations in these areas are dispersed and, in areas of high trapping numbers, are too concentrated for effective use of mating disruption pheromones. in addition, application of mating disruption pheromone alone without the addition of IGRs would not allow for success. Current CDFA requirements that commercial nurseries in California use the organophosphate insecticide chlorpyrifos if LBAM larvae are found are in direct contradiction to New Zealand Findings that organophosphates destroy LBAM's natural predators, resulting in resistance developing in LBAM populations. New Zealand experts recommend use of IGRs in the control of LBAM in agricultural systems as much safer and more efT:ective. Monitoring should be performed to assess level of predation on LBAM larvae, which could reveal data indicating that less (or no) intervention is required to control LBAM in California. Conclusions The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best iPM practices that can be readily adopted in California to 11 control LBAM, particularly because many of the natural LBAM predators that are present in New "Zealand are also found in California. The finding that there is no evidence of biological or environmental tlueat frons LBAM in New Zealand, which has climate and crops much. like California and where LBAM has been an established exotic for more than a century, bodes well for the ability of California agriculture and ecosystems to accommodate to LBAM's presence and suggests that USDA classification of LBAM as an actionable quarantine pest should be reviewed and revised. USDA's pest quarantine list needs to be re-evaluated based on current, relevant, science-based information. New Zealand researchers say that it will be very problematic to attempt to eradicate this insect as it has now been firmly established over an extensive and diverse area. In California, LBAM is found across more than 7000 square miles of varied terrain and conditions, including within protected buffer zones and sensitive riparian corridors. The net-ative impact of organophosphate use on beneficial predator species in New Zealand, along with the known short- and longi term health and environmental dangers of these chemicals, suggests that requirements for organophosphate controls for LBAM in the U.S. should be abandoned. The requirement that California nurseries use chlorpyriphos 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 chlorpyriphos use. This and other highly toxic treatments need to be discouraged or prohibited in commercial nurseries. The short-and long-term risks to exposure of organophosphates and the long-term persistence of organophosphates in the environment make their continued use for control of LBAM inadvisable. A realistic assessment of LBAM populations and potential dalllage based on New Zealand data nnust.rely on recent studies published after the use of organophosphates stopped. Organophosphate use causes an unnatural situation to develop in which natural predator populations are unable to function. There may not be any need to introduce a non-native control for.LBAM in Calil:ornia, natural controls may already exist in the native fauna given the robust numbers of native Tortricidae in Calif:ornia. Summary of Recommendations Based on the findings above, the key recommendations of this report are to: • Suspend planned aerial and ground treatments Cor Light Brown Apple Moth (LBAM) in California and monitor-to detennine extent to which LBAM populations are being parasitized or destroyed by predators. • Adopt IPM best practices from New Zealand to control LBAM if necessary. 12 • Review USDA classification of LBAM. as an actionable quarantine pest based on current, .relevant, science-based information. • Eliminate requirements for organophosphate controls for LBAM in the U.S to product natural predator species that feed on LBAM and other pests. • Realistically assess the potential impact of LBAM .in California using New Zealand data published since the use of organophosphates in New Zealand stopped. Sources ' The information in this report comes from the authors' consultation with the following researchers and agricultural experts in New Zealand: Jim Walker, PhD, Technical Research Scientist, New Zealand HortResea.rch Mike Botcher PhD, Technical .Manager, New Zealand PipFruit Association Peter Shaw, PhD. Research Entomologist, Insect Science, New Zealand HortResearch Paul Turner, .Liner Plants New Zealand Geoff Davidson, Oratia Native Plant Nursery, Oratia Phil Smith, Owner, Taupo Native Plant Nursery, Taupo Mark Dean, Omer, Naturally Native, Tauranga Chris Green, Technical Support Officer, Biodiversity (l.nvertebrates and Biosecurity) Department of Conservation Phil Knightbridge, Department of Conservation, Botanist John Clearwater PhD, Research and Consulting,Pheromone Technology, Organic Growing Systems, Auckland Ian Videan, Eskdale Orchard, Napier REFERENCES Begum et al. 2006. Using selective food plants to maximize.biological control of vineyard pests. Journal of Applied Ecology,43: 547-554. 13 Garvey, K. K. 2007. "Entomologists Targeting Light Brown Apple Moth." University of California News. http://www.univcrsityofcalifonila.edu/news/article/9323 Irvin, N.A., S.L. Scarrett, S.D. Wratten, C.M. Frampton, R. B. Chapman, and J.M. Tylianakis 2006. The Effects of floral understoreys on parasitism of leafrollers (Lepidoptera: Tortricidae) on apples in New Zealand. Agricultural cind Forest L;nlomology 8, 25-34. "NZ forest provides laboratory for pheromone trials" 2/17/08; http://nz.news.yahoo.com//080217/3/40zs.litml Thomas, W.P. 1.987. A Review of Biologiecil Control ofhnvertebrale Pests and Weeds in Neat 7ealand 1974 to 1987. Emerson, P.J., R.J. hill, J. Bain, and W.P. Thomas. Wollingford: CAB International. a s . e.. ems; p r:• 4. 3 T.: ^a.4" .n �... •. „� III Figure 2. Superficial leaf damage from LBAM larva About the Awhors Dr. Daniel Hcu-cler is the Director of the University of California at Santa Cruz Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary Biology at UC Santa Cruz. The Arboretum maintains an extensive collection of 14 Australia, New "Zealand, California natives, and southein hemisphere species within a 100 acre botanical garden on the UCSC campus. Dr. Harder is an expert on plants of Asia and the.Pacific Region, and Africa and has published papers on his .research on the floras of Central Africa and Viet Nam including works on the pharmaceutical properties of plants, taxonomy, ethnobotany, and new species discoveries. Jell'Rosenclnle is a grower and horticultural consultant in the Monterey and San Francisco Bay Areas who specializes in the cultivation and uses of plants from California, Australia, South Africa., New Zealand and Mediterranean Europe. 15 • Nan Wishner, Albany resident, expressed her dissatisfaction regarding the aerial spraying of pheromones. Supervisor Gioia said the community has raised legitimate issues about the proposed spraying as there could be potential for health effects if nothing is done. He stressed the County is looking for the best plan that balances public health with the goal of eradicating the apple moth. He made a motion to requested the Chair to write a letter to the state to request there be a broader health risk analysis done quickly and thoroughly and suggested the Health Services Department follow up and work with the state before the spraying begins. He suggested quantifying the risk in a clear manner to give the public more comfort. He stressed it would be useful to get that out before the spraying begins. Supervisor Piepho voiced her concern over the eradication efforts being safe and necessary and said she respects the state's responsibilities and authority on this issue, but stressed the County's primary responsibility is to the citizens and local communities. Supervisor Bonilla included in the motion that the Board draft letters to Senator Dianne Feinstein and Senator Barbara Boxer requesting to tighten borders so as not to allow pests to enter into the state. Supervisor Gioia agreed to include Supervisor Bonilla's suggestion in the main motion. By an unanimous vote, with.none absent, the Board of Supervisors took the following action: • ACCEPTED informational presentation by the California Department of Food and Agriculture and the United States Department of Agriculture on the light brown apple moth; • REQUESTED state regulators assess the safety of the material before spraying this summer in parts of western Contra Costa and Alameda counties; and • REQUESTED the Chair to write a letter to the state to request there be a broader health risk analysis done quickly and thoroughly, before any spraying is done; DIRECTED the Health Services Department to follow up with the state on this matter; and REQUESTED staff to send letters to Senator Dianne Feinstein and Senator Barbara Boxer with a request to tighten borders not to allow pests to enter into the state. 4 with the moth if efforts are made to suppress its numbers. She handed the Board a Declaration of Richard Phillip in support of ex parte application for temporary restraining order against Department of Food and Agriculture: A.G. Kawamura, in his capacity as Secretary of the CDFA., a Resolution No. NS-27, 783 dated February 12, 2008 opposing the aerial spray program to eradicate the LBAM;County of Santa Cruz, California ■ Susan JunFish, Moraga resident, said found out about the (LBAM) only two weeks ago. She handed the Board a abstracts from Dr. Daniel Harder, Director, University of California, Santa Cruz Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary Biology at UC Santa Cruz, who did a study in New Zealand where the moth was introduced.; ■ Bethallyn Black, Pleasant Hill resident, told the Board she is a gardener and expressed her concern about the LBAM; ■ Lori Anders, Moraga resident, said she echoes the concerns of other speakers and is concerned about finding ways to target the situation without having to resort to other pesticides. She told the Board she is concerned about the research on pheromones being minimal and the research on how human pheromones work is also minimal and asked the Board to take more time before the spraying is done; ■ Judy Adler, Walnut Creek resident, said she is a gardener and an environmental educator. She said she believes the eradication program operates on the wrong premise, and noted a huge risk is being taken which would create a life emergency rather than emergency in one particular organism. She said she supports the efforts to discourage the other risk of pesticide use by individual home owners; ■ Ken Freeze, Martinez resident, said lie is concerned about the spraying not taking place and noted if the spraying does not take place the ramifications are such that a lot more pesticides would be sprayed into the environment. He said frorn what he has read it is a safe way to eradicate the LBAM; The following individuals presented their concerns in writing: ■ Rita Gaber, El Cerrito resident, presented a speaker card but did not show; • Nan Wishner, Albany resident expressing her dissatisfaction regarding the aerial spraying of pheromones; Supervisor Gioia said the community has raised legitimate issues about the proposed spraying as there could be potential for health effects if nothing is done. He stressed the County is looking for the best plan that balances public health with the goal of eradicating the apple moth. He made a motion to requested the Chair to write a letter to the state to request there be a broader health risk analysis done as quickly and thoroughly 4 Dr. Brunners said there is a consensus statement from the (DPR) and(OEHHA). He pointed out there is enough time to bring in the CDPH to work with the (OEHHA) and do an extensive risk assessment of the implications and the formula proposed to be sprayed. He reasoned pheromone is safe but the concern is of the vehicle that this is delivered in. Dr Dowellell said once they pick the exact mix of chemicals to be blended with the pheromones, public health and environmental safety agencies would review its safety. He stated this would be done before using the aerial application. Chair Glover said this information would help the Board as well as the constituents. Chair Glover asked the public for their testimony and the following people spoke: ■ Don McQueston, El Sobrante resident, told the Board he has a son and said his biggest concern is for California kids with respiratory disease. He had concerns about the areas to be sprayed. He said the spraying is a direct threat to kids and handed the Board a clipping on Stewart Resnick, CEO Roll International; ■ Carmen Breen, Crockett resident expressed her concerns about health issues for her grandchildren and said big corporations are concerned about money. She informed the Board she would like to age in good health. ■ Angelina Breen, Crockett resident, told the Board citizens have not been given a choice whether they want to be sprayed or not. She told the Board their right to breath has been taken away and said she was no ok with that. She told the Board until the state gives them their right to vote on the matter the aerial spraying should not take place; ■ Dr. Lisa Tracy, Oakland resident with two children in San Pablo schools, called the spraying plan a dangerous human experiment. ■ Laurey Foulkes, El Cerrito resident, said she agrees with the other speakers and has the exact concerns. She said the spray could be cancelled due to inclement weather and the people who get 72 hours notice will not know when they would get sprayed; ■ Mike Vukelvich, El Sobrante resident, said fears about spraying pheromones were vastly overblown. He informed the Board the pheromones would not hurt anything. ■ Kathy Kramer, San Pablo resident, an expert in native plants, said she was appalled by the spraying plan because of the potential risk to children and adults. She told the Board it's so unacceptable she can't even believe it's being considered. She noted that some scientists have suggested that California can live 3 Addendum to D.2 March 11, 2008 Ori this day the Board CONSIDERED accepting informational presentation by the California Department of Food & Agriculture and U. S. Department of Agriculture on the light brown apple moth eradication project in the Bay Area. Ed Meyer introduced Mr. A.G. Kawamura, Secretary of Agriculture for the State of California, and Dr. Robert Dowellell, Director of the Light Brown Apple Moth(LBAM) Eradication Program. Dr Dowellell presented a power point to eradicate the light brown apple moth. He said in 2007 apple moth was first found and noted the traps used have a pheromone of perfume like material. Dr Dowellell said this moth poses a significant risk to agriculture and a potential for uncontrolled spread and environmental and economic impacts. He said the rnoth is eradicatable and believes if no action is taken this moth will spread to the point where one would be forced to live with the moth, as they are forced to live with it in Australia and New Zealand. He said a statewide trapping program has been implemented. Dr Dowellell explained strategies to remove the moths is base decisions on sound science and technology; programs designed using effective tools by providing accurate public information and effectively using integrated methods. Dr Dowellell noted there is not a one-size-fits-all approach as tools are tailored to be used to each population level. He noted twist-tie applications are impregnated with pheromone. Dr Dowellell went on to say ground application for male moth consists have (LBAM) pheromone to attract male moths; an insecticide, Permethrin, to kill the finales and, a clay- based matrix to hold the mix. He further explained releases of Parasitic Wasps are released for ground application, which would not hurt people or pets. Dr Dowellell noted formulas of mating disruption pheromone are being tested to decide which formulas would be efficacious for the LBAM eradication program. He continued saying treatments are expected to occur in heavily infested areas in Monterey, Santa Cruz, San Francisco, San Mateo, Alameda, Contra Costa and Marin County. He said expanded outreach efforts would be scheduled before treatment, and the Office of Environmental Health Hazard Assessment CalEPA and Department of Public Health are working together to develop procedures to watch the health of citizens in the treatment areas and to educate health care professionals about the program, any health affects of the tools and ]low to report suspected cases of pesticide poisoning. Information is available to the public by the following web sites: www.cdfa.ca.gov_ and www.aphis.usda.r;ov. For complete information on the power point presentation please contact the Clerk of the Board's office at 925-335-1900. Supervisor Gioia asked time frame and areas proposed to be sprayed. Mr. Dowellell responded the start date for aerial application of pheromone would be over all the heavier infested areas of Monterey and Santa Cruz counties in June 1, 2008. He said applications for San Francisco, San Mateo, Alameda and Contra Costa counties wouuld start in August 1, 2008. He explained if moth catches decreases in some of these areas they would use other tools, and if moth catches increase they would not know what would happen till the moths get caught in traps. 1 Supervisor Gioia questioned if spraying would start before the Environmental Impact Report would be completed under an exemption to California Environmental Quality Act (CEQA). Mr. Kawamura responded the state has met the emergency terms under(CEQA). Supervisor Gioia reasoned, as added information comes in through the EIR process, how would the state decide on making changes. Dr Dowellell said all materials used would be reviewed continuously with California Environmental Protection Agency(CALEPA) , United States Climate Partnership Association(USCPA), DPR and once they know what formula of material would be used that information would be given to Department of Public Health (DPH) and the Office of Environmental Health Hazard Assessment (OEHHA) for their review. He said in addition it would be reviewed and environmental assessments produced by the United States Department of Agriculture (USDA). He said should any of these reviews show chance of adverse human health affects the process would be stopped. He explained all this will be done before use of any materials. Supervisor Gioia asked what the risks would be if nothing was done, and also questioned how this would be included in the EIR process. Mr. Kawamura noted populations of threatened and endangered plant specifies could be severely impacted; increased pesticide use would occur; the moths would spread to other areas and the impact of a 1 to 5 percent crop loss. Dr. Brunners, Director, Public Health, Health Services Department, said the risk of the spray is small but more needs to be known about the chemicals it will be mixed with. .He requested the California.Department of Public Health (CDPH) with the Office of Environmental Health Hazard Assessment (OEHHA) complete a risk assessment. He believes this agency has the best expertise to do this risk assessment that would be credible. Supervisor Gioia asked Dr Dowellell and Dr. Brunners the process needed for a risk assessment to be done soon. Dr. Brunners said if the Board recommends a letter could be prepared to the California Department of Public Health and the Office of the Environmental Health Hazard Assessment. Mr. Kawamura said state (DPR), OE.H_HA) with jurisdictional for public health produced a consensus statement that evaluated the complaints and found pheromones are extremely safe. Chair Glover asked with the risk assessment already put in place, would a more extensive risk assessment be needed. Laura Case To: Lena O'Neal/COB/CCC@CCC MrAt03/13/2008 11:03 AM cc: fkell@bos.cccounty.us Subject: Adjournment on 3/18 Lena, The information for the adjournment for Tuesday, March 18 is: Army Sgt. Gabriel Guzman DOB: October 17, 1982 DOD: March 8, 2008 Thank you. Laura Case, Scheduler Supervisor Susan Bonilla Contra Costa County, District Four 2151 Salvio Street, Suite R Concord, CA 94520 (925)521-7105 FAX(925)646-5202 31H (n LBAM Control Statement of Concern Parents for a Safer Environment Director Honorable Contra Costa County Board of Supervisor members: I have spoken to over 50 community members regarding the moth aerial spraying issue in Contra Costa County and had the opportunity to speak with a number of directors from advocacy groups such as the Breast Cancer Fund and Communities for a Better Environment, Assembly member Fiona Ma and staff from Assembly member Carol Migden's office durino a recent Breast Cancer conference. I have yet to meet one person who is not very concerned about the LRAM aerial sprayiiIg. The following are some of the reasons for using safer alternatives to the aerial spraying for LRAM. • CDFA expects the spraying will continue monthly for 3-5 years or indefinitely until the moth is eradicated. ■ The pesticides being used consist of three components: a moth pheromone (sex hormone) designed to confuse mating. several inert ingredients. and microscopic plastic capsules in which the pesticide formula is encased. The capsules break down over about i0 days, releasing the pesticide. ■ The active ingredient (the pheromone) has not been tested for long-term human exposure risk:. the inerts include suspected carcinogens. and substances most of us wouldn't choose to inhale or have exposure: the inhalation risk of the plastic capsules is untested and unknown. ■ More than 600 people reported health complaints after residents of Monterey and Santa Cruz counties were sprayed. These are only acute symptoms. We know nothing about chronic, or long-term health effects. ■ CDFA acknowledges that the moth has done no crop damage in CA and independent entomologists say it has likely been in the U.S. at least a decade. ■ Accordino to Dr. Harder of U.C. Santa Cruz, the moth is a minor pest in New Zealand where it has been an introduced exotic for more than 100 years and where climate, crops. and natural predators are similar to California's. I quote Dr. 1larder from his "IPM Practices for the LRAM in New Zealand: Implications for CA:"Today. I..,BAM is effectively controlled almost exclusively by natural predators in both agricultural settings and wild lands in New Zealand. There is no evidence of biological or environmental threat from LBAM in New Zealand.... "The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf- roller pests tising LPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to control LBAM. particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. Adopti.n�g, i13M best practices would include suspending planned aerial and ground treatments for LBAM in California and monitoring to determine extent to which LBAM populations are being parasitized or destroved by predators. United States Department of Agriculture (USDA) classification of I-BAM as an actionable quarantine pest should be reviewed and revised based on current,relevant; science based information." Dr. Harding delineates that New Zealand researchers report that pheromones will only work under specific conditions that include: extensive.. even and complete coverage for the pheromone, in uniform blocks of a single crop (single canopy height). uniform topography (no slopes, hills or valleys), and low population density of target pest. In another words, pheromones applied by any means cannot be effectively used across large diverse areas with varyino canopy heights, mixed species composition, and varying terrain areas. In addition, New Zealand researchers have found that aerial pheromone spraying interferes with monitoring using pheromone traps, interfering with the critical too] to control the moths. Furthermore, Entomologist Dr. Shaw of New Zealand found that female moths emit a stronger scent than the aerial pheromone application, so male moths are able to find the females anyway. i.e. the effectiveness of the pheromone via aerial application is unlikely. I'd like to alert the Board of Supervisors and Dr. Wendell Brunner who is probably well- aware that there are deadlines on March 18`h and 20`' for State and Federal LBAM associated comments for the EIR (environmental impact report) and public comments. I encoura(ae you to consider all the scientific evidence and not speculations and theories that are being proposed and practice caution on this issue. As the daily inspirational thought for today infers, the seeds we plant today will determine our future and this is what will be the measure of our achievements. Most concern is for the exposure to the fetus. children under 8 whose immune systems have not matured. those w/ pulmonary problems and those immunosuppressed, such as those w/ immune problems and undergoing chemotherapy. My cursory review concludes that USDA is not.justified to spray aerially and a recent study show that it may not even be necessary, as seen in New Zealand. The Community is opposed to aerial spraying and supportive of cooperating to use the safer alternative of bait stations for control of the moth, not necessarily eradication, which appears infeasible. State politicians such as Carol Midgen has opposed spraying over San Francisco and Marin Counties. Oakland, Albany, Berkeley and Fairfax city councils formally opposed the aerial spraying over their communities. Last Bay Regional Park union workers opposed the spraying. California Certified Organic Farmers (CCOF) announced today that CCOF is now opposing the aerial spraying for LBAM. Thank you for seriously considering the concerns by your community and providing us with an opportunity to express our views on the LBAM issue. \vxA,NA-.pfse.net 92;-283-4609 Integrated Pest Management Practices for the Light Brown Apple '.Moth in New Zealand: Implications for California Daniel Harder,.Ph.D. Executive Director The Arboretum, University of California at Santa Cruz Jeff Rosendale, Grower,Horticultural Consultant Watsonville CA March 6,2008 ABSTRACT The Light Brown Apple Moth, Epipht�as postvittar7a (LBAM) has been an established exotic species in New Zealand for more than 100 years. The authors conducted a three.-week, 3,000-kilometer fact-finding study in New Zealand's two major agricultural regions to assess integrated pest management (IPM) of LBAM and applicable strategies for California. LBAM was considered a problem pest in New Zealand orchards during the 1980s when regular, calendar applications of broad- spectrUM organophosphate pesticides had eliminated the beneficial insects that prey on LBAM. However, since elimination of organophosphate treatments in 2001 and subsequent restoration of populations of beneficial insects and other organisms, LBAM is considered a minor pest that does not cause economically significant crop damage or have detrimental effect on native flora. 'Today. LBAM is effectively controlled almost exclusively by natural predators in both agricultural settings and wild lands in New Zealand. There is no evidence of biological or environmental threat from :LBAM in New Zealand. Because of United States' zero-tolerance quarantine requirements for LBAM, New Zealand horticultural/agricultural professionals use pheromone sticky traps to monitor LBAM populations and, based on monitoring data, timed ground applications of insect growth regulators (IGRs) are used in select agricultural settings to prevent shipments from being rejected for export to the U.S. The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. Adopting IPM best practices would include suspending planned aerial and ground treatments for LBAM in California and monitoring to determine extent to which LBAM populations are being parasitized or destroyed by predators. United States Department of Agriculture (USDA) classification of LBAM as an actionable quarantine pest should be reviewed and revised based on current, relevant, science- based information. The negative impact of organophosphate use on beneficial predator species in New Zealand, along with the known health and environmental dangers of these chemicals, sm—est.s that current requirements for organophosphate controls for LBAM in nurseries and elsewhere in the U.S. should be abandoned. Introduction This report describes results of a January 2005 fact-finding study on integrated pest management of the Light Brown Apple Moth (LBAM) in New Zealand. The study was undertaken to understand the extent of LBAM's effect on New Zealand's agriculture and natural environment and the methods of managing LBAM, with the goal of understanding potential impacts of and best management practices for LBAM. in California. The authors focused on understanding best management practices for control of LBAM and how these stratecries impact the cultivation of plants in botanical collections in gardens and arboreta as well as in commercial nursery and agricultural cropping systems. New Zealand was chosen for this research because its climate and crops are similar to California's coastal fanning areas and because LBAM was introduced to New Zealand from Tasmania and first reported in New Zealand in 159.1 (Thomas, 1957, IlortNet http://www.hortnet.co.nz/key/Keys/into/distrib/lba-dist.htm) and thus has been an established exotic in New Zealand for more than 100 years. The remainder of this report describes the study's research methods and presents findin��s and discussion on LBAM biology and behavior, hosts,populations, damage, and control in New Zealand, as well as L.BAM's role in global trade of New Zealand agricultural products. Methodology The authors traveled and conducted interviews with government, agricultural, and horticultural entomologists and researchers of LBAM and insect pests as well as wholesale and retail a-ricultural and horticultural producers and plant conservationists. They also conducted field searches for LBAM presence and damage in commercial a-ricultural Gelds, orchards, native habitats including Abel Tasman National Park, and along roadsides. The research was carried out over a period of three weeks, January 4- 29, 2005, which is mid-summer in New Zealand when LBAM would be expected to be active in all life stages and readily observable. The goals of the research were to learn from agriculture. integrated pest management (iPM), entomology, and conservation experts about LBAM in New Zealand and to identify IPM strategies that would be effective. against LBAM in California. The authors focused on the two main agricultural production areas of New Zealand: on the North Island.the Hawke's Bay region, known as the "fruit basket " of New Zealand where the major produce is apples, nectarines, kiwis, wine-grapes and assorted row- crops; and on the South Island, the Nelson agricultural region, which is a major production area for apples, currants, hops and wine-grapes. See Figure 1. 2 .. g .. :. _�,'.'f t 1 l:t �w. z. d M: a �.A ... - ..4... .. ... «.:::0. ._:.::•.•:..fir 5; Figure 1. New Zealand map Both the.Hawke's Bay (Napier) and Nelson areas are similar in terrain and mixed forest areas to California's Monterey Bay and Santa Cruz areas where the California LBAM presence is most dense. The Hawk.e's Bay re0ion is a bit wanner and moister than Monterey Bay, making it an ideal climate and study area foi-LBAM. These agricultural regions also have a long history of studying and controlling LBAM and have developed technologies to best protect crops. As shown in Table 1, Nelson and Napier have climates very similar to California's Central Coast. Comparison of Temperature Ranges,Average Mean Temperatues and Precipitation in Monterey,California and Napier,New Zealand in 2007. Months have been aligned to season. 2007 January February March April May June July August September October November December Santa Cruz,California ..n,,crzlurc i:z^e((F) 39/61 41/63 42165 43/6h 46/71 44/74 :,l/76 52 i 76 SO/77 47/!4 43/66 39,1 6 A, .,ge I p,.rztu•e;F) 40 52 54 53 55 5E 62 62 63 50 56 i, 6.4 5.5 4.s 2.7 0.7 0.2 0.1 0.1 0.3 1.3 •.� S.< June July Auoust September October November December January February March April May Napier,New Zealand -_.�De�zturc 2znge ir) 31/69 .6/6^ 35 GC 33/6% it/]% 43/:i., 4 /63 45/ 3 47/66 46/d5 36/]6 .;U/2. A.ve�a�^tenrnei z[urc(F) F, SO -u S2 _5 58 64 65 64 65 54 ,. freciF�lzno»(4:cY e.) 3.6 3.3 3.7 2.1 2,. ,.-5 1.E :.]. 2.7 ..., 2., Table 1. Comparison of Santa Cruz,CA and Napier,NZ Temperatures and Rainfall 3 The southernmost area of New Zealand was not visited because its colder,harsher climate is both less hospitable to LBAM.than the wamner climate farther north and dissimilar to the climate of areas where LBAM is presently found in California. In addition,New Zealand cultivates hundreds of thousands of hectares of Monterey pine (Pinus radiata) and has planted many Californian species including vintage Monterey cypresses (Cupressus macrocarpa), giant sequoias (Sequoiadendron gigantewnn), coastal redwoods (Sequoia seinpenlirens), as well as native New Zealand conifers. Results and Discussion The subsections below present findings related to LBAM, its biology,behavior, enemies (beneficial control agents),populations, damage, control in New Zealand;-and role in New Zealand agricultural trade. Biolog)'and Behavior of LBAM LBAM is a tortricid (Tortricidae)moth and a member of the leaf-roller moth family in the order Lepidoptera. Each LBAM individual exhibits three life stages: larva,pupa, adult (moth). LBAM is polyphagous, meaning that it is not host specific but rather feeds on a variety of plant species. A superficial feeder as a larva (see Figure 2), LBAM typically causes cosmetic damage to the surface of leaves and fruit and only rarely penetrates a host fruit. LBAM does not defoliate plants. Defoliation is contrary to leaf rollers' biological need for leaves that, with the help of thread material, the larvae roll around themselves for protection. The rolled leaves provide protection from predators and the ideal conditions for growth and development. Like all leaf rollers, LBAM is subject to natural predation and parasitism. Major predators and parasites in New Zealand include: birds, spiders, wasps, flies, beetles, lacewings, and earwigs to name only a few. A frill listing of enemies to LBAM can be found at: littp://www.hortnet.co.nz/kev/stone/info/enemies/lba-encm.litm LBAM may mate up to three times during its 1- to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per egg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature(HortNet Website at littp://www.hortnet.co.nz/publications/proceedings/ifoam/ifoam69.htm) Adult LBAM travel an average of approximately 100 meters fi-om their hatching sites during their lifetimes and are not necessarily particular about where oviposition (eg(-,- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. 4 •,� Y 6� F� III�I '�•� 3 i F is 4wN�' a - s' z^Q P, M Y: g .. ... 5 s. .S S.. . .. .. ... s: n x i m � {n '�•�`x.�'.,�' K �;::, .t;h,,•,. IIS, � Figure 2. Superficial leaf damage from LBAM larva LBAM may mate up to three times during its t-to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per egg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (I lortNet Website at http://www.hortnet.co.nzi'pub]icati ons/proceedings/i foam/i foam69.htm) Adult LBAM travel an average of approximately 100 meters frorn their hatching sites during their liletitnes and are not necessarily particular about where oviposition (egg- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so tlic larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural .field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. LBAM Hosts and PopulatiDns in Neil Zealand Although LBAM is considered by New Zealand .HortResearch, the government agricultural and horticultural research agency, to be `'common'" in orchards throughout New Zealand and "less convnon, rare, or even absent" in areas of New Zealand still 5 covered in native forest(I-IortResearch 2008 �v�v_hortr�ei�co.nz/l:.ey-'less inf6'dist_rib_1ba-uj.,.oj�tir), LBAM is, in fact, difficult to find in New Zealand. Eighty to ninety percent of LBAM larvae are parasitized by natural predators before maturation (Shaw, 2008). 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. For meeting U.S. quarantine requirements, LBAM populations in New Zealand are estimated and monitored using pheromone traps. LBAM is not an insect of significance in Monterey pine plantations in New Zealand. LBAM is a leaf-roller moth that requires flat-surfaced leaves to protect larvae while they mature. Clearwater(2008) notes that I...BAM clearly does not have a preference for gymnosperms and is not considered a pest of these plants in New Zealand. Shaw (2008) reports that gorse is a preferred LBAM host plant in New Zealand; however, the authors found no LBAM larvae on gorse in a wide variety of regions in the North Island and the main agricultural regions of the South. Island. In fact, the authors' extensive search for LBAM in native New Zealand habitats during the three-week, 3,000- lun extent of this research trip revealed only a few larvae, one on an exotic planting in a hotel garden, as well as a few tortricid moths flying around porch lights in the evening. No evidence of LBAM eggs, larvae or adults was found in the.22,530-heetare Abel Tasman National Park on New Zealand's South Island. This national park }.las a mixture of native and non-native plant species with a multi-story diverse habitat of broadleaves, ferns and conifers. Aaricultural/horticultural researchers in New Zealand noted that, because LBAM larvae are often parasitized, finding a larva does not mean that a viable adult LBAM will hatch. If a parasite has laid eggs in the larva, the parasite's adults, e.g., wasps, flies will hatch rather than LBAM. Due to the need to understand natural controls for LBAM in California and the similarity of types of organisms keeping LBAM under control in New Zealand with those already present in California, monitoring of levels of parasitism ol•all life staoes should begin immediately for LBAM in California. As noted below in the /_BAAlf Control in New Zealand section, researchers in New Zealand have developed a monitoring protocol that allows them to determine the extent of parasitism of LBAM populations to prevent unnecessary and costly control efforts based on observation of larvae only. Similar parasitism of LBAM is likely occurring in the regions of California where it is present. The Arboretum at the University of California, Santa Cruz has initiated a survey of beneficial insects that may control LBAM. In eight larvae raised to adults, two have been parasitized by natural predators. LBAM Dainage is New Zealand LBAM is currently considered a minor biological pest in New Zealand agriculture, including apple,peach/nectarine, citrus, and vineyard crops. Codling moth ("the worm in the apple,"also a tortricid) and woolly apple aphids are much more significant pests in 6 apples, and thrips and mites are the pests of significance in New Zealand citrus (Videan 2008) Hawkes Bay horticultural .researchers report that, with no monitoring or treatments and if LBAM were uncontrolled other than by naturally occurring trichogramma or other beneficial insects and organisms, the maximum damage caused by LBAM would be one percent or less of crops (Walker 2008). 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 LRAM'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. New Zealand horticulture and agriculture professionals so successfully use IPM. strategies to manage LBAM that in more than 3,000 U.S. shipments ofpome (pip) fruit in 2006, only six were rejected. One positive LBAM find can cause rejection of a single 15-ton fruit order(Walker 2008). Thanks to exceptional, modern New Zealand IPM practices, leaf rollers have limited economic impact on fruit or crop production other than occasional shipments rejected by U.S. only because of zero tolerance for LBAM. LBAM Control in New Zealand Beneficial insects are considered the first and best line of defense against leaf rollers, and insect growth regulators (IGRs), which are based on derivatives from natural sources, are the primary insecticide used for leaf roller and codling moth control in New Zealand. Growth regulators do not ne-atively affect beneficial insects to any significant degree. Rather, IGRs are relatively target-specific and cause target larvae to mature faster than normal before the lanae are physiologically ready and so die. To control LBAM effectively with iGRs, it is important to target overwintering LBAM populations. As cooler weather progresses, adult populations of LBAM drop.. adults die off. and larvae do not morph into adults. The lowest adult numbers occur in late winter. IGRs are most effective when applied as eggs hatch and larvae begin to feed in wanner summer weather. in California, IGRs should probably be applied in May, but the timing needs to be verified by phenological monitoring using pheromone traps for adult males (Shaw 2008). Treatments with least-toxic IGRs for most other pests. particularly codling moth, which is one of the top apple pests in New Zealand, generally act, along with beneficial insects,as adequate LBAM controls. Biocontrols are effective against all LBAM life stages: cggs, larvae,pupa, and adults. Biocontrols include native and introduced wasps and native tachinid (Tachinidae) flies. The key to effective control with predators and parasites is to encourage a range of insects attacking all life stages. 7 In the Nelson area, roughly four to 10 percent of producers are organic. Because organic systems encourage beneficial insect populations and do not negatively affect beneficial or-anisms and insects with the use of harsh chemical controls,pests (including LBAM) are not significant problems for localized organic producers. The leaf-roller complex, including LBAM and other native New Zealand species, is readily monitored in the early to mid-spring with a pheromone sticky trap and regular visual inspection. Based on monitoring results, a single IGR spray regime can be effective for season-long control. Growers in the Hawke's Bay and Nelson regions do not use elating disruption pheromones to control LBAM. They monitor in late spring with pheromone traps specific to LBAM and codling moth. I.f the trap counts warrant, an IGR is applied (e.(,-. Intrepid, Confirm: methoxyfen.ozide, tebufenozide). This timed treatment adequately suppresses LBAM and codling moth populations for the year (Walker 2008, Shaw 2008). Pyrethroids (natural or synthetic) are effective controls for LBAM but also are detrimental to beneficial insects and pollinators, making these products undesirable for long-terns IPM of LBAM. Pyrethroids are especially detrimental to native and introduced (honeybee) bee populations essential for pollination and to manunals. History of Organophosphate Control During the late 1980s and 1990s, organophospliates were applied regularly in New Zealand orchards with no monitoring for insect populations. The effort was to create a "sterile nursery" situation where there were no pests and no beneficial insects. Organophosphates were used because of the zero tolerance for LBAM in produce to be exported to the U.S. The chemicals were applied on a schedule rather than in response to pest populations. Under the organophosphate spray regime, .LBAM was a problem of -reater 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. Use of organophosphates was eliminated in New Zealand in 2001. HortResearch experts report that once the use of broad-spectrum organophosphates was stopped and agricultural professionals began monitoring for LBAM and timing IGR sprays, all of which allowed beneficial insects to affect LBAM populations, the LBAM problem reduced dramatically so that the moth is now considered a minor pest(except for the challenge posed by the U.S. Department of Agriculture quarantine) littp://www.horLiiet.co.nz/key/stone//iii fo/control/lbacontr/lr-chcm.htm. Organophosphates were destroying beneficial insects and creating resistant insects, and orchards and vineyards were becoming LBAM breeding grounds. Shaw (2008) reports that, at Nelson/Motucka, "control trees with no insect or chemical controls used have not recorded any damage from LBAM or other leaf rollers for more than 10 years." HortResearch staff attempted to force LBAM infestation of these trees by introducing LBAM eggs and larvae into the trees to no avail. Any infestation.of these trees by LBAM was quickly controlled by native predators without the need for IGRs. 8 "Once organophosphates were removed from the system and populations of beneficials were left to develop naturally, complete control of LBAM was realized in less than 5 years" (Shaw 2008). When organophosphates were compared to natural controls in consistent blocks of apples, control of LBAM was achieved with natural controls in less than two years. Organophosphates never allowed effective control, and LBAM developed resistance to them. it is worth noting that in New Zealand, intercropping has been shown to promote beneficial insect populations, resulting in near-complete LBAM population suppression to below thresholds for use of control measures (Irvin et al. 2006, Begum et al. 2006) Monitoring Spring populations of LBAM in monitoring traps in total numbers per month is key to deciding whether to use iGRs to control the population. Local monitoring of population levels allows tracking* of seasonal fluctuations (Shaw 2008). Monitoring programs should assess levels of LBAM phenologically (at various life sta­cs and,by rearing lar��ae and.egggs from host plants, the degree of predation and parasitism of LBAM. .Parasites and beneficial controls may not be seen in early-stage occupation of habitats by LBAM or other invading pests but will develop as the predators respond to the presence of LBAM.as a possible host. A monitoring*protocol has been developed that allows determination of the rate of parasitism of'LBAM larvae. Auckland I-IortResearch Insect Rearing Lab uses a general- purpose diet to rear LBAM larvae so that they can be observed to see if they are parasitized. Larvae are placed in a capped tube with cotton, allowed to develop at room temperatures, and observed to determine whether LBAM develops normally, parasites hatch, or development is adversely affected by other potential control means. The specifics of monitoring and thresholds for treatment are provided on the New Zealand HortRescarch website: http://www.hortnet.co.nz/key/. Eradication and Pheromone Use Widespread LBAM eradication efforts have never been attempted in New Zealand. A very limited eradication program took place during the 1980s affecting two orchards (200 hectares total) in the Nelson region where an insecticide-resistant LBAM strain had appeared. Twist-tie pheromone strips (1000 per hectare) and ground-applied insecticides were used to eradicate this resistant and localized LBAM population. Eradication is very difficult unless a population is.quite limited and well defined. New Zealand researchers report that effective mating disruption using pheromones will only work under the followings specific conditions: Extensive, even, and complete coverage of the pheromone Uniform blocks of a single crop (single canopy height) Uniform topography (no slopes, hills or valleys) Low population density of target pest (not too concentrated) 9 Under the above conditions,twist ties can be used for control under extensive coverage. However, pheromones applied by any means cannot be effectively used across large diverse areas with varying canopy heights, mixed species composition, and varying terrain areas. New Zealand researchers also note that aerial pheromone spraying interferes with monitoring using pheromone traps, and monitoring is critical to successful control. Moreover,use of broadcast pheromone spray to eradicate or control the moth is not effective because female moths issue a more concentrated scent plume than the dispersed pheromone scent of an aerial spray application, so finale moths are able to find the females (Shaw 2008). Until tests reportedly carried out under a U.S. government contract in 2008 in southern New Zealand forests ("NZ Forest Provides Laboratory for Pheromone Trials"2008 http://nz.news.yahoo.com/080217/3/p/40zs.html),pheromones had never been aerially applied in New Zealand. These trials are been undertaken within a Monterey Pine plantation and does not involve applying the pheromone over urban areas. Pheromones have never been used for widespread eradication anywhere in the world. HortResearch stations on both islands agree that eradicating LBAM in California and anywhere would require extensive, widespread use of iGRs with repeated applications to ;address elusive, selected populations. These experts also question the efficacy of bacillus thuringiensis (Bt) against LBAM. Bt can also have a detrimental effect on beneficial insects. They report that IGRs do not h.aiin populations of beneficial insects and that IGRs persist on foliage much more effectively than organophosphates did. Larvae emerging from eggs begin to perish as soon as they start feeding on the growth regulators. Tests show IGRs are ovicidal as well as larvicidal and not toxic to predatory/beneficial insects. The beneficial effects of the application of growth regulators can be seen one to Iwo days after application (Walker 2008, Shaw 2008). LBAXf and Global 71•ade of Neiv Zealand Agricultural Products LBAM is not of biological concern on either island in New Zealand but remains a pest of concern only because it is a quarantine pest for exports. USDA considers LBAM an "actionable quarantine pest" and has zero tolerance for LBAM. finds in pre-inspection of U.S.-bound fruit shipments. Consignments rejected because of any LBAM life stages are sent to non-U.S. markets, e.g., Europe, which does not have phytosanitary restrictions for LBAM. Today very few New Zealand fruit shipments are rejected by the U.S. (Walker 2008), which further suggests that New Zealand growers' LBAM controls relying" on natural predators and IPM strategics are successful. HortResearch experts say that when USDA announced during the late 1990s that the U.S. would no longer accept fruit treated with organophosphates because of concerns for the safety of fruit handlers and consumers,this was the catalyst for abandonment of organophosphates and the move to reliance on natural predators and IPM methods. 10 Implications for California The information on LBAM and IPM in New Zealand reported in this report has significant implications for addressing LBAM in California. First, it is worth noting that, according to the National Museum of Natural History Catalog of Type Specimens of Tortricidae (www.sel.barc.usda.gov/lep,/tort_types_list.html), California has 85 native and localized North American species of tortricid moths; none are problematic as a pest. All are kept in check by natural biological controls, so there is confidence to believe that LBAM will also be controlled by native natural predators or parasites. Preliminary studies by the California Department of Food and Agriculture report a high level of parasitization of LBAM.larvae by native California trichograrmna wasps. Entomologists speculate that LBAM may have been in California for as long as a decade already (Garvey 2007), so it is possible that LBAM is already being controlled by natural predators. Many LBAM predator species in New Zealand are the same or closely related to California species (birds, earwigs, viruses, trichogramma and other wasps, tachin.id flies, spiders, beetles, etc.). According to New Zealand information,the pheromone treatment currently proposed for LBAM will most likely not eliminate nor control LBAM because none of the essential conditions for successful pheromone use can be met. Use of the pheromone cannot be complete (e.g., it cannot be applied over sanctuary buffer zones and along streams/waterways), the pheromone will not be applied over a unifonm block but rather over mixed forests and native vegetation, houses, schools, roadways, crops, and ornamental gardens. Moreover,topography of the California coast is highly varied and diverse, and LBAM populations in these areas are dispersed and, in areas of high trapping numbers, are too concentrated for effective use of mating disruption pheromones. in addition, application of mating disruption pheromone alone without the addition of IG.Rs would not allow for success. Current CDFA requirements that commercial nurseries in California use the organophosphate insecticide chlorpyrifos if LBAM larvae are found are in direct contradiction to New Zealand findings that organophosphates destroy LBAWs natural predators, resulting in resistance developing in LBAM populations. New Zealand experts recommend use of IGRs in the control of LBAM in agricultural systems as much safer and more effective. Monitoring should be performed to assess level of predation on LBAM larvae, which could reveal data indicating that less (or no) intervention is required to control LBAM in California. Conclusions The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf-roller pests using iPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to l.1 control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. The finding that there is no evidence of biological or environmental threat from LBAM in New Zealand, which has climate and crops much like California and where LBAM. has been an established exotic for more than a century, bodes well for the ability of California agriculture and ecosystems to accommodate to LBAM's presence and suggests that USDA classification of LBAM as an actionable quarantine pest should be reviewed and revised. USDA's pest quarantine list needs to be re-evaluated based on current, relevant, science-based information. New Zealand researchers say that it will be very problematic to attempt to eradicate this insect as it has now been firmly established over an extensive and diverse area. In California, LBAM is found across more than 7000 square miles of varied terrain and conditions, including within protected buffer zones and sensitive riparian corridors. The negative impact of organophosphate use on beneficial predator species in New Zealand, along with the known short-and long-term health and environmental dangers of these chernical.s, suggests that requirements for organophosphate controls for LBAM in the U.S.should be abandoned. The requirement that California nurseries use chlorpyriphos 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 chlorpyriphos use. This and other highly toxic treatments need to be discouraged or prohibited in commercial nurseries. The short- and long-term risks to exposure of organophosphates and the long-term persistence of organophosphates in the environment make their continued use for control of LBAM inadvisable. A realistic assessment of LBAM populations and potential damage based on New Zealand data must rely on recent studies published after the use of organophosphates stopped. Organophosphate use causes an unnatural situation to develop in which natural predator populations are unable to function. There may not be any need to introduce a non-native control for LBAM in California; natural controls may already exist in the native fauna given the robust numbers of native Tortricidae in California. Summary of Recommendations Based on the findings above, the key recommendations of this report are to: • Suspend planned aerial and ground treatments for Light Brown Apple .Moth (LBAM) in California and monitor to determine extent to which LBAM populations are being parasitized or destroyed by predators. • Adopt IPM best practices from New "Zealand to control LBAM if necessary. 12 • Review USDA classification of LBAM as an actionable quarantine pest based on current, relevant, science-based information. • Eliminate requirements for organophosphate controls for LBAM in the U.S to product natural predator species that feed on LBAM and other pests. • Realistically assess the potential impact of LBAM in California using New Zealand data published since the use of organophosphates in New Zealand stopped. Sources The information in this report comes from the authors' consultation with the following researchers and agricultural experts in New Zealand: Jim Walker, PhD, Technical Research Scientist, New Zealand HortResearch Mike Butcher PhD, Technical Manager, New Zealand PipFruit Association Peter Shaw, PhD, Research Entomologist, Insect Science, New Zealand HortResearch Paul Turner, Liner Plants New Zealand Geoff Davidson, Oratia Native Plant Nursery, Oratia Phil Smith, Owner, Taupo Native Plant Nursery, Taupo Mark Dean,Owner,Naturally Native,Tauranga Chris Green, Technical Support Officer, Biodiversity (Invertebrates and Biosecurity) Department of Conservation Phil K.nightbridge, Department of Conservation, Botanist John Clearwater PhD, Research and Consulting, Pheromone Technology, Organic Growing Systems, Auckland Ian Videan, Eskdale Orchard, Napier REFERENCES Begum et al. 2006. Using selective food plants to maximize biological control of vineyard pests. Journal of Applied Ecology,43: 547-554. 13 Garvey, K. K. 2007. "EntoTnologists Targeting Light Brown Apple Moth." University of California News. http://www.universityofcallfomia.edu/news/article/9323 Irvin, N.A., S.L. Scarrett, S.D. Wratten, C.M. Frampton, R. B. Chapman, and J.M. Tylianakis 2006. The Effects of floral understoreys on parasitism of leafrollers (Lepidoptera: Tortricidae) on apples in New Zealand. Agricultural and Forest Entomology 8, 25-34. "NZ forest provides laboratory for pheromone trials" 2/17/08; http://nz.news.yahoo.coi-n//080217/3/40zs.html Thomas, W.P. 1987. A Revie-K-of Biological Control of Invertebrate Pests and Weeds in Neiv Zealand 1974 to 1987. Emerson, P.J., R.J. Hill, J. Bain, and W.P. Thomas. Wollingford: CAB International. T' I, A"` ..int.. k�6 Y F' , y s • ,, max:::_�:'. r. r' rg - y p{. ce F Figure 2. Superficial leaf damage from LBAM. larva About the Authory Dr. Daniel Harder is the Director of the University of California at Santa Cruz Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary Biology at UC Santa Cruz. The Arboretum maintains an extensive collection of 14 Australia,New Zealand, California natives, and southern hemisphere species within a 100 acre botanical garden on the UCSC campus. Dr. Harder is an expert on plants of Asia and the Pacific Region, and Africa and has published papers on his research on the floras of Central Africa and Viet Nam including works on the pharnlaceutical properties of plants, taxonomy, ethnobotany, and new species discoveries. Ic.I'Rosendale is a grower and horticultural consultant in the Monterey and San Francisco Bay Areas who specializes in the cultivation and uses of plants from California,Australia, South Africa, New Zealand and Mediterranean Europe. 15 March 7, 2008 City of Richmond. —CheckMate Spray for Light Brown Apple Moth Dr. Elisa Song-.of MM CA, a pediafrteian':and'expert on the deleterious effects of environmental toxins upon children believes that children will be harmed by the chemicAr—` components of the spray just described. Dr. Song bases this concern on the fact that the livers of children are underdeveloped and less capable than those of adults of detoxifying toxic chemicals that enter their bodies. Given the higher risk to children and the 640 sentinel incidences of disease following spraying.in the Santa Cruz area, we conclude that spraying with Checkmate L" AM' F should be abandonediri gavor of" procedure that'ismore protective of human health. We have also considered the putative enhanced vulnerability of the citizens of Richmond to further chemical exposure when compared to inhabitants of cleaner urban environments. Our thinking is guided by two fundamental precepts, the precautionary principle and the need to implement environmental justice. The City of Richmond; historically known as the "industrial city", is burdened with toxic industrial chemicals released to the environment over the course of a century. It is imprudent to add more chemical components to the mix since we have no idea how they may interact to heighten illness and environmental damage. Richmond residents are also exposed to environmental toxins on an ongoing basis and may therefore be more vulnerable to the health effects of components of CheckMateLBAM-F than residents of cleaner urban environments. Exposing Richmond residents to additional putative toxins is a violation of environmental justice. Many of our residents, including communities of color and others, cannot afford routine medical care and have untreated illnesses that may increase their vulnerability to toxic environmental agents. In conclusion we favor a moratorium on Spraying with CheckMateLBAM-F until its health effects have been completely assessed. and the use of other moth control methods have been compared and evaluated. Sincerely yours, Michael S. Esposito, Ph.D. Carolyn Graves Stephen Linsley Andrew Mayes Sherry B. Padgett Joseph Robinson Jean Rabovsky, Ph.D. Copy: Richmond City Council Members Richmond Southeast Shoreline Area Community Advisory Group Members Page 2 of 2 March 7, 2008 Mayor Gayle McLaughlin Temporary City Hall 1401 Marina Way South Richmond, CA 94804 Dear Mayor McLaughlin: In response to your request, members of the Richmond Southeast Shoreline Area (RSSA) Community Advisory Group (CAG) Toxics Committee (Tox Com) have studied the issue of spraying with CheckMateLBAM-F to control the spread of the light brown apple moth. We recognize that this matter is not solely relevant to the RSSA but involves the entire City of Richmond and its inhabitants. Moreover, in order to clarify our perceived role in responding to your request we are acting as a group of concerned private citizens with relevant expertise, not in our capacity as members of the RSSA CAG Tox Com. To emphasize this distinction our report is printed on common bond and no RSSA CAG funds were expended in its preparation. Our literature review revealed that there are at least five methods to control the spread of moths: 1) Release of sterile males that impregnate females resulting in dead embryos 2) Release of stingless wasps that prey upon, moths 3) Use of bacteria that infect moth eggs, 4) Baiting of traps with moth pheromone >) Aerial spraying with CheckMateLBAM-F containing moth pheromone encapsulated in microscopic plastic capsules. Spraying with Checkmate was done in the Santa Cruz area last year. Approximately 640 residents became ill, apparently due to exposure to the spray. This has drawn the attention of the public to the putative health hazard of CheckMateLBAM-F. The spray contains the pheromone in sinall plastic particles that can be inhaled and which are implicated in respiratory difficulties. The plastic particles are suspended in a mixture,-,)f butylated hydroxytoluene, tricaprylmethyl ammonium chloride. polyvinyl alcohol, sodium phosphate and 1,2-benzisothiazolin-3-one. The latter is a bactericide that is harmful to mammals including humans. The CheckMate formulation is in the form of microcapsules, and aerial spraying may result in the inhalation of these particles by human and ecologic receptors in the path of the spray. Microcapsules less than 10 microns can enter the deep lung and may cause damage to the gas exchange area and also systemic toxicity. Particles greater than 10 microns should not enter the deep lung but can remain in the upper respiratory tract where nose and throat irritation may occur. Such large particles may also be coughed up and forced into the gastrointestinal tract. In the absence of information about the size distribution of the microcapsules as well as their stability in biological fluids, a precautionary approach would be advisable to prevent unnecessary exposure to the airborne microcapsules. Bay Area Legislators Introduce Bills to Tackle Light Brown Apple Moth SACRAMENTO—Assemblym embers John Laird (D-Santa Cruz), Loni Hancock (D-Berkeley/Oakland Mark Leno (D-San Francisco) and Jared Huffman (D-San Rafael)today introduced a 4-bill le(Tislative package to address the eradication effort for the Light Brown Apple Moth and other invasive species. In addition, Assemblymember Laird released draft language for an Assembly Concurrent Resolution to be introduced next week. Bill descriptions and comments,from Assemblynaembers: AB 2763 would enact the Invasive Pest Planning Act of 2008, by Assemblymember John Laird. The bill would require the Department of Food and Agriculture to create a list of invasive animals, plants, and insects that have a reasonable likelihood of entering California for which an eradication program might b appropriate. For each invasive on the list, the department would prepare a written assessment on the mos appropriate method of eradication. If pesticides were to be used, the assessment would have to discuss application methods, the chemistry of the pesticide and its inert ingredients, impacts on public health and the environment. The department would have to coordinate with the State Department of Public Health, the Department of Fish and Game; and other state health agencies. The department would have to hold public hearings. if a pest was found, the department would have to notify various local agencies, hold public hearings, and comply with other requirements. "The state was not adequately prepared for the Light Brown Apple Moth," said Assemblymember Laird. "This won't be our last experience with an invasive pest. But in light of climate change, international travel patterns and chronically underfunded federal inspection programs, we ought to put in place a pest planning process that prevents the kind of public fear and confusion we've experienced to date with the I..ight Brown Apple Moth." AB 2764, by Assemblywoman I-oni Hancock, will prohibit the Secretary of Food and Agriculture from approving the application of a pesticide in an urban area, unless the Governor has proclaimed a state of emergency. Current law allows the Secretary of Food and Agriculture, to proclaim any area in the state eradication area with respect to a pest, prescribe the boundaries of the area, and name the pest or host of pests that are known to exist within the area, together with the means and methods that are to be used to eradicate or control the pest. Assemblymember Hancock's legislation will increase the level of responsibility the administration has to take and will provide more transparency. In addition, the Governor will be able to solicit input from all of his state agencies including Department of Health and relevant environmental agencies. "We are trying to bring some transparency to a process that seems to favor economic interest over public health. The fact that the Department is now doing an IEIR that won't be complete until sometime after thf spraying has commenced brings into question the openness of this process. We believe that there are significant questions that remain unanswered and we are trying to get answers for our constituents before the spraying occurs;" said Assemblywoman Loni Hancock. I AB 2765, by Assem.blymember I-luffinan, sets new limits on the emergency powers of the Department of Agriculture. It requires a public hearing to receive testimony and examine alternatives to aerial spraying prior to any decision to spray. It further bars emergency spraying in an urban area unless there is full disclosure of all elements in any pesticide product, and a certification of the safety of the product by state health officials. "I want to make sure that people in communities affected by a proposed eradication strategy for LBAM c any other pest have better information and a meaningful opportunity to engage in the process before decisions about aerial spraying are made," said Assemblymember Huffman. ''At a minimum, we need ar open and transparent public process, full disclosure of spray ingredients, and safety assurances based on sound science." AB 2760, by Assemblyman L.eno would require that an Environmental Impact Report be completed before the state Department of Food and Agriculture can. apply pesticide in an urban area for the eradication of the light brown apple moth. "We cannot even begin a discussion about the: current plans of eradicating the light brown apple moth before we understand the impacts of the chemicals the state is proposing to spray in urban areas." stated Assemblyman Mark Leno. "My measure will require that before any spraying can begin, the state must complete an Environmental Impact Report that will tell us what impacts the specific mix of pheromone and other chemicals will have on our children, families and communities. The report will arm us with the information we need to help the state and corrununities make an informed decision. Too much is at stake to enter into the discussion without all of the facts," Leno said. Draft Assembly Concurrent Resolution by Assemblyrnember Laird The following is the draft concluding languas-,;e for an Assembly Concurrent Resolution to be introduced next week focused on CDFA's response with regard to conducting its LBAM eradication effort: "Resolved, it is the responsibility of the government to demonstrate that its actions are necessary, appropriate, and do not compromise health or the environment. It is not the responsibility of'citizens to demonstrate the reverse. Resolved, the various state departments and agencies involved in the LBAM eradication effort need to address the unresolved health, scientific, and efficacy issues concerning the 2007 eradication effort. Resolved, that these departments and agencies need to take the steps necessary to ensure, in any future actions, that human health and environmental impact issues are appropriately evaluated and addressed." 9.94 1 DANA McRAE, State Bar No. 142331 County Counsel, County of Santa Cruz JASON M. HEATH, State Bar No. 180501 3 Assistant County Counsel CHRISTOPHER R. CHELEDEN, State Bar No. 181185 a Assistant Countv Counsel 701 Ocean Street, Room. 505 ' Santa Cruz, California 95060-4068 6 Telephone:(83)1) 454-2040 Fax: (83 1) 454-2115 7 8 Attorneys for Plaintiff/Petitioner County of Santa Cruz 9 SUPERIOR COURT OF CALIFORNIA lU COUNTY OF SANTA CRUZ 11 12 COUNTY OF SANTA CRUZ Case No. 158516 13 Plaintiff/Petitioner, DECLARATION OF RICHARD PHILP 14 V. IN SUPPORT OF EX PARTE, APPLICATION FOR TEMPORARY 1' CALIFORNIA DEPARTMENT OF FOOD RESTRAINING ORDER 16 AND AGRICULTURE; A.G. KAWAMURA.. in his official capacity as Secretary of the Date: October 31, 2007 17 California Department of Food and A`.!riculture; Time: 1:00 p.m. I's DOES l through 100, inclusive, Dept: 8 19 Defendants/Respondents. 1 1, Richard Philp, hereby declare: 22 1. I am an Emeritus Professor of Pharmacologv and Toxicology with the University of 23 Western Ontario in London. Canada. I have a Ph.D. in Pharmacology from the University of 24 Western Ontario and have spent my career- as a professor of Phannacology and Toxicology. I have ?' published over 90 peer-reviewed manuscripts in the area of pharmacology and toxicology and 1 am 26 an experienced researcher on pharmacology and toxicology issues. A copy of my curriculum vitae is 27 attached hereto as Exhibit A. I have personal knowledge of the facts set Borth below, and if called 28 upon to testify thereto I could and would do so competently. I- . I i 2. After Monterey County was aerially sprayed with the pesticide Checkmate OLR-1' in 2- September 2007, I was asked to review the health hazards associated with this aerial spraying. In 3 conducting my review, i reviewed available literature and government documents concerning a Checkmate and I drafted a preliminary rel)ort on this issue, a true and correct copy of which is attached hereto as Exhibit B. My general conclusions and recommendations are set forth at paoc 8 6 of my final report. 3. In sum. I have concluded that no chronic toxicity study of Checkmate has been I R conducted in a mammalian species by any route of administration and certainly not involving I 9 exposures to the product to be employed by the intended method of application (aerosol spray of 10 microcapsules). Any claims of the safety of Checkmate are based on extrapolation from acute 11 toxicity studies and one sub-acute, 90-day study that employed the oral route of administration of 12 certain chemicals related, but not identical, to those used in Checkmate. One cannot conclude from 13 these studies that Checkmate is a safe product to aerial spray over an urban population, nor can one id guarantee that longer-term, repeated exposures of humans are without risk. A chronic toxicity study 15 of at least 90 days and preferably six months duration, employing daily exposure to aerosol of 16 Checkmate at a high exposure level would be required before a conclusion of'safety could be . 17 legitimately drawn. It is customary in such studies to use a much higher exposure level in order not is to miss adverse reactions that might occur too infrequently to be detected at lower exposures. 19 4. In none ofthe documents I reviewed, including the USDA environmental assessment.; 220 is there any mention ot•previous experience with aerial spraying of populated, urban areas. Previous' 21 efforts to control LBAM in the proposed treatment area employed ground application techniques. 2222 Pheromone baited traps were placed throughout the State of California to monitor the moth 2'3 population and distribution. Isolated populations in Napa and Oakley were treated using (.;round 24 equipment with Bacillus thuringiensis kt.n•.Slaki (13tk) (USDA Environmental Assessment. 2007. p2. 25 para 2). This is a bacterial product that attacks the early larval stages of most lepidopterans. 226 5. There is ample evidence that many pheromones and semi ochemical s (the synthetic I 2'7 counterparts of pheromones) possess significant toxicity for aquatic species. This suggests that aerial! 28 I 2_ spraying carries an increased environmental risk given the difficulty in confining the spray to the 2 target area. 6. In summary, and as more fully explained in my attached report, the USDA and EPA a documents I reviewed are filled with contradictory statements regarding the toxicity testino of pheromones, inappropriate extrapolations from irrelevant toxicity studies, and are suggestive of a 6 poor understanding of basic pharmacological and toxicological principles. 7 7. In my opinion, since the decision to use aerial spraying as the method of application 8 appears to have been made entirely on economic grounds, the decision should be revisited given the 9 lack of adequate evidence for its safety in the long term. Either ground-based methods of application should be employed or an adequate chronic toxicity study should be conducted. Ground- based technology has the added advantage of posing less risk to the environment. 12 8. Finally, I have recently reviewed the toxicology of the ``inert" ingredients provided to 13 me and found that: 1) some have been shown to be skin irritants in animal studies; ii) no information 14 regarding respiratory toxicity or absorption is generally available; iii) no carcinogenicity studies j; have been perfonned on some; and iv) I was unable to rind inhalation toxicity studies for any of the 16 inert inaredients. This further supports my conclusion that this product should not be aerially 17 sprayed as intended at this time. 18 1 declare under penalty of perjury under the laws of the State of California the foregoin(l is 19 true and correct and that this Declaration was executed on this 29th day of October 2007 at 20 London, Canada. 21 DR. RICHARD PI-III.P 22 2+ 2)4 2; 26 27 29 ;_ 2 3 / tt I � 1 1, James R. Carey, hereby declare: 1. I am a Professor of Entomology at the University of California, Davis xvith 4 entomology degrees from Iowa State University (BS in 1973; MS in 1975) and the 5 University of California, Berkeley (PhD in 1980). I specialize in both insect demography 6 and invasion biology. I have particular interest in understanding the nature of pest 7 invasions and the feasibility of eradication. I am not an advocate for any environmental 8 and/or citizen group. I support eradication efforts in situations where I believe it is 9 feasible. This position is reflected in a symposium that i organized in 1999 and the paper 10 that I co-authored from this symposium the following year(Myers .11-1, Simberloff D, 1 1 Kuris A, Carey JR (2000). Eradication revisited--dealing, with exotic species. Trends in 12 Ecology and Evolution. 15, 515-516). It is also reflected in my service on the Medfly 13 Scientific Advisory Committee for the California Department of Food and Agriculture 14 from 1987 to 1994. Although I continue to question whether the medfly was ever truly 15 eradicated in the state. I none-the-less have always supported eradication efforts against 16 this important agricultural pest. 17 2. Some key relevant information from my biography: i served on the 18 California Department of Food and Aoriculture's Medfly Scientific Advisory Panel from 19 1987-1994, testified to the California Legislature "Committee of the Whole" in 1990 on 20 the Mcdfly Crisis in California, authored the paper "Establishment of the Mediterranean 21 Fruit Flv in California" (1992, Science 258, 457), and have studied tephritid fruit flies in 22 Greece, Hawaii, Pakistan, China, and Mexico. I was one of the main organizers of an 2 international workshop on invasion biology held at LJC Davis in 1995 and the senior I Guest Editor of the Proceedings of this workshop published as a Special Issue of Biological Conservation (1997). 1 was elected a AAAS Fellow in 2000. was a co- 3 organizer of the workshop "Life Span: Evolutionary. Ecological and Demographic 4 Perspectives" held in May, 2001 (in Santorini, Greece) sponsored by the National Institute on Aging, and author of the book "Demography for Biologists (1993; Oxford 6 Univ. Press) and the monograph `'Longevity" (2003, Princeton University Press). I am 7 currently director of an NIH-funded program project on the demography and 8 evolutionary biology of life span. I have taught both undergraduate and graduate courses 9 in insect ecology and a graduate course in insect demooraphy (source of the Oxford book 10 material). I have also served on and/or chaired several major university committees at I l UC Davis including the College of Agriculture and Environunental Sciences Executive 1.2 Committec, and the UCD University Council (to the Chancellor) and was vice-chair of' 13 the Department of Entomology at UC Davis from 1997-99. 1 am currently vice-chair 14 (2007-08) and chair-elect (2008-09) of the UC Systemwide University Committee on 15 Research Policy which, when chair, will place me on the UC Systemwide Academic 16 Council. I am the author of over 150 scientific papers most of which are on either the 17 biology, demography, and ecology of fruit flies (e.(,. Mediterranean fruit fly) or principles 18 of invasion biology. 19 3. Successful eradication of anv invasive species is an enormous challenge, 20 even under the best.of circumstances (.e.g. small, well-delineated population; effective 21 eradication 'tool'; highly-effective monitoring techniques; support of multi-year 22 programs). Eradication of populations of exotic insect species is especially difficult for 23 the same reason that metastatic cancer is so difficult to cure--anything short of 1000NO I elimination is control (management) and not eradication (cure). Thus even a 990/0 success 2 in the elimination of metastases is ultimately a failure in the sense that small residual 3 pockets of insects can regenerate the entire population. This is the situation with the light 4 brown apple moth (I,BAM) with thousands or even tens of thousands of small 5 populations spread over a multi-county region in California. 6 4. There are several specific aspects of the LBAM invasion that reduce to 7 near zero the likelihood of successful eradication. 8 (a). The invasion of the LBAM is so widespread that eradication is not feasible 9 regardless of the eradication tool used. Although it is now confirmed to be present in 9 10 counties, it is highly likely to also be present in many more counties. I 1 (b). To my knowled0re the use of a pheromone to disrupt mating has never been 12 used in any insect eradication attempt. And, 1 am virtually certain that there has never 13 been a successful program of eradication based on mating disruption via pheromone. The 14 likely reason for this is that there are shortcomings with the use of this technology in 15 insect control. Thus it follows that the use of this mating disruption strategy is an . 16 inadequate tool to use in insect eradication. 17 (c). Detection of insects at love population levels is exceedingly difficult and the . 18 LBAM is no exception. This is important at the outset of an eradication program since 19 detection allows entomologists to delineate the population. But good detection is equally 20 important at advanced stages of eradication since it is needed to identify the location of Z. pockets or residual populations. An additional complication is that the pheromone used to 22 disrupt mating is also used as the attractant in traps for monitoring. Pheromones cannot I be used simultaneously for both population control and population monitoring since each 2 cancels out the effectiveness of the other. 3 6. In my view these three factors--extent of spread, faulty eradication tool 4 (use of pheromone for mating disruption), and difficulty of detection--make it virtually impossible to eradicate the LBAM in California.. 6 I declare under penalty of perjury under the laws of the State of California the 7 foreboino is true and correct and that this Declaration was executed on this 14`x' day 8 November 2007 at Davis, California. 9 10 I l JAMES R. CARLY Experts question plan to spray to fight moths ,�l Z_ 3 3/100 6:13 PM Print This Article ' Back to Ai-ti cle ............ .::: Experts question plan to spray to fight moths .......... : µ. )ane Kay, Chronicle Environment Writer Thursday, March 6 2008 � :•.:::..:..;, ,, .x ..:,..., ,.:..: J. is rh ;y The light brown apple moth may not be the voracious .?x'x•}.:`'.,. ,.. 5 crop threat portrayed by state and federal agricultural :" :::µ..: ., .; . officials, according to some scientists who also warn that the aerial spraying of a pesticide over California's cities may turn out to be an expensive, unnecessary public relations nightmare doomed to fail. U.S. and state agricultural departments support a $74.5 million program to spray the pesticide over hundreds of square miles from Monterey County north to Solano County as early as this summer, but several of the state's top insect and plant scientists say the decision to do so should be reconsidered. "It's not such a nasty pest. You're not going to see a plant succumbing to the light brown apple moth," said botanist Daniel Harder, executive director of the Arboretum at UC Santa Cruz. Harder visited New Zealand to research the moth's behavior there. In the face of criticism, U.S. Department of Agriculture and California Department of Food and Agricultural scientists stand firm that there must be quick aerial spraying to eliminate the moth, which they say is newly arrived and whose larvae threaten more than Zoo crops in the state worth multimillions of dollars. Nursery- plants and native trees are also at risk, they say. Thousands of Bay Area residents have signed petitions to stop the spraying, legislators have introduced .five bills to control aerial application over urban areas, and four city councils have passed resolutions against it. Hundreds of residents in Monterey and Santa Cruz counties, where pheromone pesticides were aerially applied late last year, have reported health symptoms, including shortness of breath, muscle aches and sore throats. Citizen groups are asserting that the government failed to disclose all of the contents of the two pesticides and that safety testing has been inadequate. This is the first time the pheromone-based pesticide is being sprayed over cities. To suppress or eliminate http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL&type=printable Page 1 of 5 Experts question plan to spray to fight moths 3/10/08 6:13 PM Among entomologists, the debate is more subtle. They are weighing the value of trying to "eradicate," ,,which means complete elimination, against the less invasive technique of trying to "contain" a pest, which means suppressing or controlling it. Some scientists from the University of California and other independent experts say the pest should be contained in urban areas, but the full-scale airplane onslaught should be saved for California's breadbasket, the Central Valley, which the agricultural departments are trying to protect. Furthermore, they say, the moth probably has been in California for decades - not just in the last few years - and is too well-established in at least a dozen counties to be completely wiped out by aerial spraying of a pheromone that attracts male moths and disrupts the breeding process. The bug is considered a minor pest in New Zealand, where it arrived from Australia, they say. The tens of millions of dollars given to California for the aerial spraying and related activities should be used instead to contain the moth and "slow the spread as much as possible to the Central Valley, if it's not already there," said James Carey, UC Davis entomology professor. The light brown apple moth is in a class of insects called leaf rollers whose larvae, or worms, cocoon inside leaves, potentially pitting ornamentals and reducing rigor of a wide range of plants, including fruit trees and grapes. Growers already spray for other leaf-roller pests in California. Warning that the moth could devastate the state's crops, agriculture officials have announced that they intend aerial spraying of a pheromone pesticide called Checkmate, or other yet undetermined products, over most of the Bay Area starting in August. The pheromones aren't toxic to moths, animals or people, they say, but curtail moth populations by disrupting mating. Spraying is scheduled for Monterey and Santa Cruz counties in June. The plan is to completely eradicate the moth in the 12 counties statewide where it has been trapped. Carey says the plan won't work. The state and federal agricultural departments need to actino,,-vledge that "the pest has been here so long and is so widespread" that they don't have the tools or the monitoring technologies that are up to the task of eradication, he said. Critics advise different plan "It's virtually impossible to eradicate them," said Carey, who spent seven years on the state Department of Food and Agriculture's medfly scientific advisory panel and has published articles in scientific journals examining the effectiveness of the malathion spraying over cities in 1981 and 1982. Carey estimates that the light brown apple moth has been in California at least 30 years and perhaps 50 or more. For containing the moth, he recommends a program similar to one used to slow the gypsy moth on http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL&type=printable Page 2 of 5 Experts clUestion plan to spray to fight moths 3/10/08 6:13 PM the East Coast and in the Midwest. He'd use more intense treatment, including some insecticides,to protect the Central Valley. Another UC Davis entomologist, Frank Zalom, an integrated pest management specialist who researches tree crops, fruits, vegetables and invasive species, says it's better to try to suppress - and not eradicate - the moth in urban areas. "Using pheromones over urban areas runs into expense and conflict," he said. "I think they should be considering other options." Over time, natural predators will develop. "It wouldn't be too surprising that they jump over and start working on the light brown apple moth," though not necessarily controlling them, he said.. UC Berkeley associate professor Miguel Altieri, who teaches agroecology in the department of environmental science, policy and management, agrees that "the fact that the moth is here doesn't mean devastation." In a global economy, there are going to be invasive pests, he said. Every one of them cannot be eradicated ^pith a spray program. Pheromone called benign Larry Hawkins, a USDA spokesman, takes issue with entomologists who say that the light brown apple moth has been around for decades and that it can't be eradicated with a pheromone. Critics are willing to give up without trying, he said. "We're not willing to give up. That's the difference. There has never been an opportunity like this one to use a product as benign as a pheromone to eradicate a pest." The USDA's technical working group, composed of state and federal officials as well as scientists from other countries, made the decision to eradicate, saying the pest is a grievous threat and must be eliminated. The decision opened the way for federal funding. The state agricultural department has gone along with the decision. However, the working group may be willing to meet with entomologists who have useful data, Hawkins said. The light brown apple moth took up residence in New Zealand perhaps a century ago and is not considered a pest there, said entomologist Philippa Stevens, leader of the plant disease and insect group of HortResearch, a governmental science group in New Zealand. They find an occasional light brown apple moth on avocados, kiwis, apples, persimmons and citrus, among http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL&type=printable Page 3 of 5 Experts question plan to spray to fight moths 3/10/08 6:13 PM other plants, she said in an interview. "Although it has been recorded on the crops, it is not a significant pest," said Stevens. No eradication measures have been taken against the moth, she said. A pheromone is used only to bait traps to monitor the presence of the insect, she said. In New Zealand, the moth is kept under control using natural enemies, insecticides and other measures, she said. "There's no reason to believe it's going to be more of a problem in California than any other native moth in the Tortricidae family," said the UC Santa Cruz Arboretum's Harder, who went to New Zealand to research the moth after he learned it was trapped in California last year. EanN igs, birds and spiders gill eat the pest, Harder said. The moth larvae "look like another tube of meat to them." To get involved Documents: Read California Department of Food and Agriculture documents on the proposed pesticide- spraying program at links.sfgate. com/ZCLW. Comments: Until March 20, send written comments to: Jim Rains, staff environmental scientist, California Department of Food and Agriculture Plant Health and Pest Prevention Services, 122o N St., Room A-316, Sacramento, CA 95$14• The problem and meetings to go to Problem: The tiny moth has been trapped in the Bay Area, and its larvae have the potential of harming more than 200 types of fruit and. vegetable crops. Eradication: Officials plan to spray a pesticide over Bad- Area cities to eradicate the moth by disturbing its mating. Spraying is expected to start Aug. 1. Spraying: A map of the proposed spraying in 2008: litiks.stilctte.c.'(,)rrt/ZCQ.I; Public meetings -- Saturday, 10 a.m. to noon, office of La Voz Latina, TL Housing Clinic, 253 Hyde St., San Francisco -- Monday, 10 a.m., west steps of the Capitol in Sacramento for lobbying efforts sponsored by the nonprofits, among them Pesticide Watch and California Alliance to Stop the Spray. E-mail Jane Kay at jkuy t sf clrr inlicle.corTt. http://sfgate.com/cgi-bin/article.cgi?f=/c/a/2008/03/06/MN69VD309.DTL http://www.sfgate.com/cgi—bin/article.cgi?file=/c/a/2008/03/06/MN69VD309.DTL&Type=printable Page 4 of 5 Experts question plan to spray to fight moths 3/10/08 6:13 PM This article appeared on page A - 1 of the San Francisco Chronicle ........................................ .............. .. San Francisco Chronicle Sections . `: Go !c 2008 Hearst Communications Inc. Privacy Policy Feedback I RSS Feeds I FAQ I Site Index Contact littp://www.sfgate.comlcgi—bin/article.cgi?fiie=/c/a/2008/03/06/MN69VD309.DTL&type=printable Page 5 of 5 RESOLUTION NO. NS-27,783 RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ OPPOSING THE CALIFORNIA DEPARTMENT OF FOOD ANI) AGRICULTURE AERIAL SPRAY PROGRAM TO ERADICATE THE LIGHT BROWN APPLE MOTH WHEREAS, the Light Brown Apple Moth (LBAM) is a pest subject to Federal and State quarantine and eradication orders; and WHEREAS, there is a confirmed presence of Light Brown Apple Moths in Santa Cruz County; and WHEREAS, the California Department of Food and Agriculture (CDFA) plans to resume an LBAM aerial spraying program in Santa Cruz County and surrounding areas in spring of 2008; and WHEREAS; modern Integrated Pest Management (IPM) relics on least-toxic, environmentally sensitive control methods; and WHEREAS, the City of Santa Cruz IPM Policy, adopted in November of 1998, commits the City to "eliminate or reduce pesticide applications on City property to the maximum extent feasible"; and WHEREAS, least-toxic control options are available for LBAM, including physical and cultural practices such as clean-up of plant debris where moth larvae winter, use of natural predators, parasites, and insect diseases, introduction of sterile male moths, and use of pheromone sticky traps; and WHEREAS, aerial and other blanket pesticide applications repeatedly have been shown to upset natural ecosystem balance in unpredictable and often catastrophic ways; and WHEREAS, aerial and other blanket pesticide applications have been shown to cause unintended, unpredictable, and often serious human health effects; and WHEREAS, blanket spraying of chemicals is expensive and inefficient; and WHEREAS, the State has claimed an emergency exemption under the California Environmental Quality Act (CEQA) in order to begin the LBAM aerial spraving program without conducting enviromnental review because of this emergency exemption; and WHEREAS, the State has confinned that it will begin preparation of an Environmental Impact Report after the aerial spraying program has begun; and WHEREAS, in the Edna Williams, et al. v. California Deparlmenl of Food and Agriculture case, biologists James Carey and Daniel Harder testified that aerial pesticide spraying is extremely unlikely to eradicate LBAM; and RESOLUTION NO. NS-27.783 WHERE-AS, biologists have testified that the range over which LBAM has been detected in California indicates that LBAM has been established in the state for some time; and WHEREAS, CDFA has stated that no physical crop damage has been attributed to LBAM; and WHEREAS, the risk of economic damage; alone does not justify the health and environmental risks of aerial pesticide applications; and WHEREAS, the State has relied almost entirely on its own scientists to address public concerns about the LBAM. spray program and has not employed independent outside experts to evaluate and support the program or address issues in a direct and impartial manner; and WHEREAS, the CDFA LBAM spraying program has used pesticides that an independent toxicologist's review stated have not been tested for long-term human toxicity; and WHEREAS, the CDFA LBAM spraying program is relying on pesticides that contain ingredients that are highly toxic to aquatic life; and WHEREAS, the CDFA LBAM program sprays pesticides in microscopic plastic capsules that pose unknown inhalation risks; and WHEREAS, the United State Department of Agriculture (USDA) maintains that the pheromone pesticide poses only "minimal risk to human health," but acknowledges that it is considered a"slight to moderate dermal irritant" and does present "some very low toxicity"; and WHEREAS, the USDA states that its risk assessment assumes that the rate of exposure will be insignificant, with no dietary exposure from food and just a minimal amount of incidental exposure from drinking water or swimming; and WHEREAS, aerial spraying disproportionately affects vulnerable populations such as those who work and play outdoors, those with the recognized disability oi'multiple chemical sensitivity, and those in the homeless population who may have no option for protection from the spray or receipt of written notification of spray dates: and WHEREAS, LBAM aerial spraying in the Santa Cruz and Monterey areas resulted in the spraying of numerous residents and pets; and WHEREAS, hundreds of reports of health effects were reported following the LBAM aerial spraying in Santa Cruz and Monterey Counties; and WHEREAS, other environmental impacts were reported following the LBAM aerial spraying in the Monterey and Santa Cruz areas. RESOLUTION NO. N'S-27,78; NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Cruz that it hereby opposes the CDFA aerial spray program to eradicate LRAM. BE IT FURTHER RESOLVED that the City Council requests that the CDFA protect the health and welfare of the residents and natural environment of Santa Cruz County by immediately shifting its LBAM control methods to least-toxic Integrated Pest Management methods such as those listed above, and shift its focus to educating the USDA regarding the lack of crop damage done by LBAM. the need to use least-toxic control methods that do not expose populated areas to aerial spraying, and the need to appropriately downgrade the pest classification of LBAM to reflect the lack of risk it poses. BE IT FURTHER RESOLVED that the City Council requests that the State conduct a long- term study of the health and environmental effects resulting from the aerial spraying project that has been conducted to date in Monterey and Santa Cruz Counties, taking into account reports collected by citizens in the absence of an easily accessible method of reporting to the State. 13E IT FURTHER RESOLVED that the City Council supports the introduction and passage of State legislation requiring: 1. explicit consent of affected residents before any aerial spraying program can be implemented; and ?. that only the Governor of the State of California will have the power to declare an emer(,ency requiring the aerial spraying of any substance over populated areas and that any such declaration contain certain mandatory findings. Those findings must include, but not be limited to, a statement that the situation is a sudden and unexpected occurrence which is an immediate threat to life and property. PASSED AND ADOPTED this 12'x' day of February, 2008, by the following vote: AYES: Councilmembers, Porter, Reilly, Rotkin, Madrigal, Vice Mayor Mathews; Mayor Coonerty. NOES: Councilmember Robinson. ABSF;N`l': None. DISQUALIFIED: None. APPROVED: Mayor ATTEST: Acting City Clerk Light Brown Apple Moth in California ; 2 3 (1 /]0/08 7:48 PM Light Brown Apple Moth in California On This Page: • B,►ckground • PANNA's position • t) dates • Pesticides in Light Brown Apple Moth management .x4� • Pheromones and least hazardous pest management • Aerial release of pheromones • (:'ommunitV involvement in Lid_=ht Broxwn Apple Moth manat(enient • Assessine the alternatives • Eradication vs. IPM • Action and more information • Resource~ Background According to the California Department of Food and Agriculture (CDFA), the Light Brown Apple Moth (LBAM) "is an exotic pest that has recently been discovered in portions of the San Francisco Bay Area and Los Angeles. LBAM is a native pest to Australia and has been introduced into New Zealand, New Caledonia, Hawaii, the United Kingdom and Ireland. This moth can affect a wide variety of plants, flowers,fruits and vegetables." It was first identified in Berkeley, California in late 2006; by July 2007, traps set by agricultural officials had collected some 5,000 moths, mostly in Santa Cruz and Monterey along the Central Coast. In reaction, CDFA began by proposing use of chlorpyrifos and malathion -- two highly hazardous organophosphate pesticides -- to "eradicate" the moth. In September 2007,CDFA launched an additional measure: aerial application of pheromone-based products (two formulations of "Checkmate") over urban as well as rural areas of Monterey and Santa Cruz Counties, in an attempt to control the moth by disrupting mating patterns. In January 2008, CDFA announced plans to try several alternative control approaches, as well as to resume aerial applications of a new formulation of CheckMate over the Central Coast in June and north into the San Francisco Bay Area in August. In February, several state legislators submitted bills to block the spraying. Pesticide Action Network's position PAN North America is calling for an open, transparent and comprehensive review of all least toxic alternatives and for expedited research, development and implementation of less invasive approaches such as biolo-ical control and integrated pest management (IPM) that exclude use of organophosphate pesticides. PAN supports the use of pheromones (in,for example, ground applications) and other ecologically sound organic IPM approaches as far preferable to and ultimately more effective than use of dangerous organophosphates such as chlorpyrifos. However, PAN does not endorse further aerial applications of Checkmate products due to questions regarding inert ingredients in these products (their actual concentrations and possible adverse health impacts). We also question the efficacy of aerial http://www.panna.org/book/export/html/57 Page 1 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM spraying in general, the eradication goal itself, and the lack of complete transparency from CDFA. We call for precautionary steps by CDFA and analysis by an independent science panel before any further spraying. Full disclosure of the extent of the LBAM infestation, management strategies and health risks must be shared in open discussion with the affected communities before further wide-scale spraying resumes. Updates Feb. 23 Several bills have been introduced to the California legislature to block CDFA's plan to resume aerial application of CheckMate, the pheromone-based pesticide, in the months ahead. Senator Carole Migden, San Francisco, has introduced a resolution that "would delay the application of a synthetic pheromone.... The moratorium would stay in place until officials could show that any pesticide sprayed by air is both safe and effective," she said. In the State Assembly, Rep. John Laird; Monterey, submitted a bill "that would force the department to create a list of potential invasive species and how they can be eradicated. The department would have to explain what pesticide would be used and how it would be applied." Other bills introduced Feb. 20 include Rep. Loni Hancock's (Berkeley), that "would prohibit the agriculture department from approving pesticide use in urban areas unless the governor has declared a state of emergency," and one from Jared Huffman (San Rafael) "would restrict the department's emergency powers." Assemblymember Mark Leno, San Francisco, "would require an environmental impact report before pesticides targeting the light brown apple moth are used in an urban area." Associated Press has the stot -. i Feb. 15 The CDFA has released its revised "2008-2000 IBAM Action Plan" that continues to claim that "eradication is the goal" of the program, including a combination of aerial application of pheromone products around the SF Bay region. An expanded program of ground-level IPM programs will accompany the aerial spraying, prior to aerial spraying and continuing through several moth growth cycles, including pheromone "twist ties" and introduction of the Tricogramma parasitic wasp in Golden Gate Park, Santa Cruz, Soquel, Carmel and the Seaside/Marina area of Monterey. Aereal applications of a new formulation of CheckMate over areas of heaviest investation will begin June 1 in Monterrey and Santa Cruz counties, and about August 1 in areas of Alameda, Contra Costa, Marin, San Francisco and San Mateo Counties. Jan. 27 On January 22, the city council in the Sari Francisco East Bay city of Albany voted 5-0 to oppose aerial spraying to combat LBAM. The vote came despite appeals from a team of CFDA officials who testified that the microcapsules of synthetic pheromones designed to disrupt male moth- mating patterns posed no health hazard. But the capsules also can contain "inert" ingredients like formaldehydes and isocynates, leading Albany Mayor Robert Lieber (who is also a registered nurse) to call the CFDA plan "a public health issue." The state had planned to begin spraying around the San Francisco Bay Area in the spring but, earlier the same day CDFA, released a statement announcing a delay. Its Jan. 22 press release revealed that CDFA now was considering a host of alternative LBAM strategies, including traps, "twist-ties," and ground applications of Bt (a naturally occurring bacterium). But the statement emphasized that these options were only "intended to complement and not replace aerial pheromone treatment." On Jan. 27, the Monterey Herald published an investit-lative. 2iece about CDFA's hiring of a Washington, D.C. PR firm to deal with growing opposition to spraying. 1 i http://www.panna.org/book/export/html/57 Page 2 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM Jan. 10 -- "Citizen groups and governmental agencies have received hundreds of complaints from people who said they had adverse physical reactions following the state's three recent rounds of aerial } pesticide spraying in Monterey and Santa Cruz counties," reports Pesticide Watch. From Sept. through Nov., CDFA repeatedly covered densely populated areas of Santa Cruz and Monterey counties with aerial applications of CheckMate. MSNBC' reported that, after the first aerial spraying, residents began to complain of shortness of breath and sharp stomach pains. On Jan. 5,the :Santa Cry Senlinc-°l cited an allegation that 643 complaints had been filed. CDFA spokesman Steve Lyle said his agency had received 330 complaints of spray-related illness but he downplayed the news, insisting that "the agencies with the jurisdiction to review the product have told us it's safe to use.... lands the Checkmate products were unlikely the cause of the illnesses reported." (See Nov. 22 update, below.) A coalition of state and local groups called on the governor and legislature to block further aerial spraying. Santa Cruz City Councilmember Emily Reilly declared, "I believe further spraying must be halted until we i can be certain it is safe." i Nov 22 -- The California Department of Pesticide Regulation (DPR) and Office of Environmental Health Hazard Assessment (OEHHA) released a scientific consensus statelnent on the human health aspects of aerial application of phermone products to combat LBAM. The report notes that exposure to `. high levels of airborne Checkmate particles could cause skin, eye and respiratory irritation. It states that these effects would be consistent with the reported symptoms from sprayed areas, but notes that it is likely that actual exposure occurred at levels below what would be expected to cause health effects. The report includes recommendations to CDFA of steps that should be undertaken prior to spraying. These include preparing local health care providers to recognize possible symptoms and to know how to report illnesses, and establishing a formal health study and tracking program to monitor and assess long- and short-term health outcomes associated with exposure to Checkmate. EPA Region y had reported that CheckMate contained a potentially hazardous inert ingredient, but I clarified that information later. Despite legal wrangling over the public's right to know about inert ingredients, an Oct. 18 hearing revealed that the inert ingredient in the LBAM-F formulation of Checkmate is "butylated hydroxytoluene, or BHT. The additive is a common anti-oxidant used in food products to stip fat from going rancid." See The Monterey Couniy Herat/. On Oct. 20, Gov. Schwarzene—er "asked CDFA to release the list of ingredients in the pheromone product to be sprayed on Santa Cruz and Monterey counties. The CI FA website has a list provided by the manufacturer, Suterra. This list reflects Suterra's interpretation of what it is required to divulge according to trademark law. Hazardous pesticides in LBAM control Early on in the discovery of the widening LBAM outbreak in California,chlorpyrifos and malathion -- both highly hazardous organophoslihat.e pesticides – have been proposed to "eradicate" the moth. Already, many nursery growers have been required to apply chlorpyrifos if they want quick clearance to sell their plants following discovery of LBAM on one or more of their products. This is a practice that is threatening the organic nursery industry. Broadening use of chlorpyrifos or other chemical insecticides would significantly increase potential harm to the environment and to community health. Fortunately, safer alternatives exist that have already been approved for use in organic farming. littp://www.panna.org/book/export/html/57 Page 3 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM Least hazardous approaches to LBAM control Pheromones (sexual perfumes for insects) have been used in integrated pest management (IPM) mating disruption technologies and are believed to pose no substantial environmental or human health threats. Pheromones are among the least hazardous of remedies and their use is far preferable to the use of toxic synthetic chemical pesticides. Pheromone products have been approved for use in organic farming by the National Organic Program. (The pheromone is not itself a pesticide -- it does not actually kill or even harm the moth. Female moths produce pheromone scents to attract males; additional release of pheromones into the environment confuses male moths seeking mates; by disrupting their mate-finding ability, it reduces their reproduction and thus ultimately moth population levels). PAN supports the least invasive methods of application of these organic rernedies, such as pheromone traps, twist-ties (Isomate LBAM Plus), introduction of parasitic wasps and sterile moths, and localized ground-level spraying of the organic insecticide, Bacillus lhuringensis (Bt). Most locations on CDFA's website have response plans that rely on these less-invasive methods (e.g., Vallejo, Sherman Oaks, San Jose, Dublin, Danville, Napa and Oakley), and as of February 2008, CDFA is trying some of these alternatives in Marin and along the coast of the San Francisco Penninsula. Aerial release of pheromones On Sept. 9-11 , CDFA launched an aerial application of "Checkmate," -- a pheromone-based product approved for organic farming to control LBAM -- over agricultural and populated areas of Monterey County(Checkmate Espanol). CDFA's stated goal was; to control a rapidly growing infestation oi- the LBAM in Monterey to "box in" a larger infestation in Santa Cruz County, immediately to the north. "In most other places [in the state so fart," the Los Anaeles Times reports, "the battle is waged with pheromone-soaked twist-ties looped around plants and branches. But the numbers are too high and the area too great for that to work on the Monterey Peninsula, said state officials." CDFA undertook additional sprays in the Monterey and Santa Cruz areas through October, concluding for the season in early November. Plans announced in January 2008 target resumed sparying in the same area in June, and expansion to central San Francisco Bay communities by August. While various formulations of Checkmate have been used widely on crops, this is, as far as PAN knows., the first time they have been applied over heavily populated areas. There has also been some concern from local conservationists about potential damage to sensitive marine life off the Monterey coast. Environmental toxicologists at USDA state that because the pheromone is insoluble, it would not be available to aquatic organisms. They add that all of the toxicity data available for mammals indicates that no human toxicological response would be expected fi-om using the pheromone at the rate intended. Recent local monitoring by UC Davis aquatic toxicologists of impacts on marine and freshwater organisms found no significant effects on the organisms' survivorship or development (the National Marine Sanctuary collaborated on the marine study). CDFA initially reported that the inert ingredients in the Checkmate formulation used in Monterey in September -- CheckMate OLR-F -- consisted of a capsule,a device to delay release of the pheromones over 30 days or more, made of water and urea. Later, apparently erroneous information from EPA indicated that the "inerts" in at least one formulation might include other,possibly toxic, ingredients. EPA Region 9 later withdrew that information as erroneous. A court hearing on Oct. 18 produced state laboratory analysis establishing that the inert in question in Checkmate LRAM-F (the formulation to be http://www.panna.org/book/export/html/57 Page 4 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM used in subsequent applications), is a common food additive and not the rumored toxic substance. Gov. Schwarzenegger- requested that the list be divulged, "subject to trademark law". The manufacturer, Suterra Chemical company, subsequently provided a list of ingredients, according to their interpretation of that law. However, this list is not necessarily a complete list and the precise amount of each of the inert ingredients in the formulation remains unknown. The inerts contained in Checkmate OLR-F also remains to be clarified, as do all ingredients in the new pheromone products being tested for use in 2008. CDFA now acknowledges that it is impossible to completely rule out all potential health risks of use of these products, though state assessment ranks the risks as very low. PAN considers the lack of complete and transparent disclosure regarding all the inerts and their concentrations in both Checkmate products to be a serious constraint to informed debate and sound policy formation. See also The A9otaerev Count-y Herald. PAN does not endorse the aerial application of the pheromone product,Checkmate, due to remaining questions we have regarding possible adverse health impacts of the inerts, the efficacy of aerial application in general and over mixed-use habitats of the Central Coast in particular, and larger doubts regarding the eradication goal itself. PAN has urged CDFA to work more closely with local community members, conservationists, growers (organic and conventional) and independent experts in entomology, toxicology and public health to find acceptable least toxic and less invasive solutions to the challenge of LBAM control. Community involvement in Light Brown Apple Moth management Pesticide Action Network firmly supports community involvement, notification, monitoring and precaution as new technologies are tried. More information needs to be made available (including indepene-lent assessments of health and environmental impacts and the effectiveness of aerial application of any product) before aerial applications are considered or other management strategies are employed. PAN believes that on-going dialogue with community members is essential to the effective development of Light Brown Apple Moth management plans and suggests the formation of committees of local residents to formally work in collaboration with CDFA and local growers and conservationists as approaches are tried throughout the state. PAN suggests that in all steps of the management plan process, including development, implementation and evaluation, CDFA ensures workers and the affected public full right-to-know and participation. While CDFA has increased its information and public relations efforts in 2008, these communications remain essentially one-way rather than participatory. Assessing the alternatives PAN supports CDFA's decision to focus on least-toxic and non-chernical approaches to LBAM control, rather than organophosphate insecticides. However, we do not endorse the aerial application of Checkmate (see preceding section). In order to facilitate the informed public debate that we consider essential to resolving the LBAM challen-e in a democratic manner, PAN calls on state agencies to provide a clear presentation and obtain independent, thorough, comparative assessment of the range of least-toxic alternatives available. This includes: 1 . scientific evidence dernonstrating the efficacy of aerial pheromone release in LBAM control (including evidence relevant to application in central coast ecosystems); 2. independent review of epidemiological or occupational health studies of the effects of aerial pheromone release; 3. continued monitoring of environmental impacts; http://www.panna.org/book/export/html/57 Page 5 of 8 Light Brown Apple Moth in California 3/10,108 7:48 PM 4. monitoring and independent assessment of the illness reports following aerial applications of Checkmate in the central coast; 5. comprehensive analysis of the economic and social costs/benefits of alternatives under different scenarios. This would include assessment of the estimated costs of (for example) potential quarantine protocols at individual farm, county and state levels and a clear presentation of how the costs and benefits associated with various LBAM control measures would likely be distributed across different actors (small to large scale growers, organic farmers,farmworkers, nurseries, residents, etc.). Scenarios should include creative combination of tactics that could emerge from discussions with local community members. We urge expedited research into biological control, sterile moth release, ground application of pheromone compounds and other environmentally sound approaches. Again, CDFA has increased its experiments with around-level alternatives, though it remains committed to aerial applications as part of its LBAM eradication Goal. Eradication vs. IPM PAN and mainstream entomologists do not believe that eradication of this moth or other pests is a realistic pest management approach, particularly given the likelihood of successive re-introductions of the moth in the months and years ahead. Sustainable, least-toxic ecological IPM (Integrated Pest Management) is the appropriate response. We encourage CDFA to continue focusing on least-toxic approaches such as pheromones, preditor wasps, sterile moth release and other biological control and to work with IPM experts and community members in developing a long-term sustainable pest management plan for LBAM. PAN urges CDFA to establish an advisory committee, consisting of growers, local community members, local conservationists, environmental groups and independent experts in entomology, toxicology and public health, to collaborate in finding efficacious and ecologically and socially acceptable solutions to LBAM management. Action and more information For more background on pheromone mating disruption, there is a usel.'ul article from University of California. Davis, "Pheromone mating disruption offers selective management options for key pests". CDFA has also issued a °2008 Q&A Update". Community groups,farming, environmental and health organizations are developing their own fact sheets and resolutions. Resources Statements and Memos • CDFA 2008-2009 LBAM Action Plan (revised, 02/15/08) • CDFA L.iLht Brown Apple Moth Eradication Program for 2008 (01/22/08) • Pesticide Watch news release on spray illness reports (01/04/08) • NRDC Position Statement on Sprayint_� For the Light Brown Nipple Moth in California (11/14/07) • CDFA reply- to Assm. Laird (10/04/07) • Assm. Laird letter to CDFA (10/16/07) http://www.panna.org/book/export/html/57 Page 6 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM • (I)FA reply to Assm. Laird (10/26/07) • (7hemist.'s concerns re: inerts (10/11/07) • Chemist's concerns re: inerts (10/15/07) • PANNA statement on 1_I3AM control (09/26/07) • PANNA memo) to CDFA (09/28/07) • PANNA letter to Assm. Laird (09/27/07) • Assm. laird letter to State Sec. Ag. Kawamura Media • Moth sp1ay-ing likely to har1Y) more than help, "Ask the Bugman," Richard Fagerlund, Feb. 23,2008 • Math-eaten Flans, editorial, San Francisco Chronicle, Feb. 22,2008 • Mis,.den battles aerial moth spravin�, San Francisco Chronicle, Feb. 20,2008 • Stage plans Bad Area pesticide spraying, San Francisco Chronicle, Feb. 15, 2008 • Marlieting of' Moth Spraying) - Jan. 27.2008,Monterey Herald • (►roan allz{es hundreds got sick after moth spravin > - Ian 5 2008, Santa Cruz Sentinel • Godzilla versus Mothra - Monumental estimates of�impacts threatening, SF with spravin, - .Ian. 2, ?008 • Light brown apple moth found at S(' garden center - Dec. 20, 2007 • Monterre.y County Weekly Light Brown Apple Moth Coverage • Spniying '100 percent done' in Santa. Cruz County for now, state reports,Santa Cruz Sentinel • Judge suspends prograin aimed at curbingmoth's spread in Monterey, San.Jose Mercury News • Crowd voices concern over spniyint(, Santa Cru.7 Sentinel • Link to Monterey Herald Sept 27,2007 article on LBAM and spraying: http://w\N"W.nx)ntere\lherald.com/ci 7012289 • PANNA Sept 26. 2007 L..etter to the Editor of Santa Cruz Sentinel Research and Technical Papers • Hl.unan Health Aspects of Aerial Application of Pheromone Products, by CA DPR and OEHHA (10/31/07) • Analysis of t-BAM Toxicolotw Studies, by D. Philip, 2007 • Aerial Application of "Checkmate" Fact Sheet • Biode�;radahle Poli mer Methods • DI-IR Environn)ental Monitoring, 12ecomme.ndatioil for Synthetic Pheromone Treatments • Finding, r>f No Significant Impact Treatment of I i( ht Brown Apple Moth in the Seaside Area in California e Environmental Assessment • FincJML of No Significant Impact Treatment Appendix • Prolonsed Slow Release of Microcapsules • I�eg>ulatory Issues in the Commercial Development of Pheromones and Other Semlochemlcals • USDA Environmental A:ssesment for LBAM Treatment Map http://www.panna.org/book/export/html/57 Page 7 of 8 Light Brown Apple Moth in California 3/10/08 7:48 PM IMIIIIAl1Ar11 illpvoii0py119911X11Y:Ai®iiMlAlYy III�fiYX si3lQii'15 p�ilpYiN `t `sz . ••taYA. In ...... ..>.. yid .. -A- 41 ..A-.+ Via 77 .... � ... .?�a°��.''� lr� tee'"• .. .,_._.._ ........ `. .. _ Legend AWD R' •. {gip Vis. :V, . IIApwAIr.�-:aAIAI�Aw�wAc-:::.. Download a Larger Map (PDF) http://www.panna.org/book/export/html/57 Page 8 of 8 31 ,� � � . Hello, Below is a press release for a report released today by a UC Santa Cruz botanist describing findings ofrescarch in New Zealand on the light brown apple moth. The report .finds that the moth does no significant damage to NZ crops or wild lands and is largely controlled by natural predators there. The implications for California are that the same will likely be true here as we have the name natural predators for moths of this type. The report recommends suspension of aerial spray and ground treatments for the moth. The full report is attached. Nan Wishner, Chair City of Albany Integrated Pest Management Task Force 510-524-5185 PRESS RELEASE Contacts available for TV and radio interviews) Daniel Harder (83 1) 427-2998 .teff Rosendale (83 1) 818-6972 James R. Carey (530) 752-6217., (530) 400-8998 March 7, 2008 Scientists Report Shows Light Brown Apple Moth Controlled by Natural Predators &idence from Neh� "Zealand Contradicts State Claims that Light Brown Apple it-loth is a Risk to California Agricuhure at?d 11,71dlandv Santa Cruz A report released today says the Light Brown Apple Moth (LRAM), which is the target of a controversial aerial pesticide spray program California Department of Food and Agriculture (CDFA), is a relatively minor pest in New Zealand where it does not do economically significant crop damage or detrimentally affect native flora. The reports findings contradict CDFAs rationale for a pheromone-based pesticide spray program for LBAM that is planned for the Central Coast and San Francisco Bay Area this summer. CDFA has described the moth as a voracious pest that threatens California agriculture. The report, however, finds that LBAM in New Zealand today is effectively controlled mainly by natural predators in both agricultural and wildlands and that there is no evidence of biological or environmental threat from L,BAM in New Zealand. The moth, an Australia native, was introduced more than 100 years ago to New Zealand, whose flora and climate are similar to that of coastal California where the moth has been found. The report, by Dr. Daniel Harder, botanist and Executive Director of the University of California at Santa Cruz Arboretum, and Jeff Rosendale, a Watsonville grower and 1101-ticulturalist, concludes that, in California, the moth will likely be kept in check by the same natural predators of the more than 85 species of similar tortricid moths present in the state. In addition, the report states that the pheromone-based eradication treatment currently planned by CDFA will likely not eliminate or control LBAM because none of the essential conditions for successful pheromone use can be met. The report recommends suspending the planned aerial and ground treatments for LBAM and monitoring to determine the degree to which the moth is already being parasitized. Based on their findings, the authors conclude that the United States Department of Agriculture (USDA) classification of LBAM as a quarantinable pest should be reviewed and downgraded based on current, relevant, science-based information, and that current requirements for broad-spectrum organophosphate pesticide controls for LBAM in nurseries and elsewhere in the U.S. should be abandoned because they harm the beneficial species that prey on LBAM and other pests. During a three-week, 3,000-kilometer :fact-finding study in New Zealand, the authors learned that 80 to 90 percent of LBAM larvae are destroyed by natural predators and never mature. The authors spoke with current research experts on LBAM in New Zealands government agricultural agency, HortResearch. The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to control LBAM. The authors report that LBAM is a superficial feeder that typically causes only cosmetic damage to the surface of leaves and fruit and rarely penetrates a host fruit. LBAM does not defoliate plants, as CDFA has alleged. Defoliation is contrary to leaf rollers biological need for leaves that, with the help of thread material, the larvae roll around themselves for protection, the report states and adds that, in New Zealand, LBAM has never posed a threat to native forests. In New Zealand, beneficial insects are considered the first and best line of defense and insect growth regulators (1GRs), which are based on derivatives from natural sources, are the primary least-toxic control used in agriculture for controlling leaf roller moths. Growth regulators do not negatively affect beneficial insects to any significant degree. The report notes that pyrethroids and organophosphates should not be used because they are detrimental to beneficial insects and pollinators. Pyrethroids are especially detrimental to native and introduced bee populations essential for pollination and to mammals. New Zealand stopped using organophosphate:; in 2001, according to the report, so data on LBAM in New Zealand prior to 2001 do not accurately reflect LBAMs behavior in agricultural and natural environments with healthy populations of beneficial predators. The reports also calls into question the states pheromone aerial spray program with its finding that pheromone controls applied by any means cannot be effectively used across large diverse areas with varying canopy heights, mixed species composition, and varying terrain areas. The authors note that, Until tests reportedly carried out under a U.S. government contract in 2008 in southern New Zealand forests, pheromones had never been aerially applied in New Zealand. This report shows that the apple moth is not the voracious pest the state has tried to say it is and contradicts CDFAs basis for the LBAM. aerial spray and control program, says Ilarder. Re0arding the implications of the report for the proposed eradication project, Dr. James Carey, professor of entomology at University of California at Davis. says "The current distribution of LBAM in California covering 1.0 counties with a combined area of over 7,000 square miles (the size of Connecticut) suggests that this pest is not a recent introduction but has been in the state for many years. perhaps as many as 30 to 50 or more years. The history of eradication prograrns in which an exotic insect is as widespread as is this pest in California suggests that we have little if any chance of success." integrated Pest Management Practices for the Light Brown Apple Moth in New Zealand: Implications for California Daniel Harder, Ph.D. Executive Director The Arboretum, University of California at Santa Cruz Jeff Rosendale, Grower, Horticultural Consultant Watsonville CA March 6, 2008 ABSTRACT The Light Brown Apple Moth, Epij)hyas postvillana (LBAM) has been an established exotic species in New Zealand for more than 100 years. The authors conducted a three-week, 3,000-kilometer fact-finding study in New Zealand's two major agricultural regions to assess integrated pest management (IPM) of LBAM and applicable strategies for California. LBAM was considered a problem pest in New Zealand orchards during the 1980s when regular, calendar applications of broad- spectrum organophosphate pesticides had eliminated the beneficial insects that prey on LBAM. .However, since elimination of organophosphate treatments in 2001 and subsequent restoration of populations of beneficial insects and other organisms.. LBAM is considered a minor pest that does not cause economically significant crop damage or have detrimental effect on native flora. Today, LBAM is effectively controlled almost exclusively by natural predators in both agricultural settings and wild lands in New Zealand. There is no evidence of biological or environmental threat from LBAM in New Zealand. Because of United States' zero-tolerance quarantine requirements for LBAM,New Zealand horticultural/agricultural professionals use pheromone sticky traps to monitor LBAM populations and, based on monitoring data, timed ground applications of insect growth regulators (IGRs) are used in select agricultural settings to prevent shipments from being rejected for export to the U.S. The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best IPM practices that can be readily adopted in California to control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. Adopting IPM best practices would include suspending planned aerial and ground treatments for LBAM in California and monitoring to determine extent to which LBAM populations are being parasitized or destroyed by predators. United States Department of Agriculture (USDA) classification of LBAM as an actionable- quarantine pest should be reviewed and revised based on current, relevant, science- based information. The negative impact of organophosphate use on beneficial predator species in New Zealand. along with the known health and environmental dangers of these chemicals. suggests that current requirements for organophosphate controls for LBAM in nurseries and elsewhere in the U.S. should be abandoned. Introduction This report describes results of a January 200,3 fact-finding study on integrated pest management of the Light Brown Apple Moth (LBAM) in New Zealand. The study was undertaken to understand the extent of LBAIvI's effect on New Zealand's agriculture and natural environment and the methods of managing LBAM, with the goal of understanding potential impacts of and best management practices for LBAM in California. The authors focused on understanding best management practices for control of I,BAM and how these strategies impact the: cultivation of plants in botanical collections in gardens and arboreta as well as in commercial nursery and agricultural cropping systems. New Zealand was chosen for this research because its climate and crops are similar to California's coastal farming areas and because LBAM.was introduced to New Zealand from Tasmania and first reported in New Zealand in 1891 (Thomas, 1987, I-IortNet http://vA,w?w.hortnet.co.iiz/key/keys/info/distril)/Iba-dist.htin) and thus has been an established exotic in New Zealand for more than 100 years. Tile remainder of this report describes the study's research iiiethods and presents findings and discussion on LBAM biology and behavior, hosts, populations, damage, and control in New Zealand. as well as LBAM's role in global trade of New Zealand agricultural products. Methodology The authors traveled and conducted interviews with government, agricultural, and horticultural entomologists and researchers of LBAM and insect pests as well as wholesale and retail agricultural and horticultural producers and plant conservationists. They also conducted field searches for LBAM presence and damage in commercial agricultural fields, orchards, native habitats including Abel Tasman National Park, and along roadsides. The research was carried out over a period of three weeks, January 4 - 29, 2008. which is mid-summer in New Zealand when LBAM would be expected to be active in all life stages and readily observable. The goals of the research were to learn from agriculture, integrated pest management (IPM), entomology, and conservation experts about LBAM in New Zealand and to identify IPM strategies that would be effective against LBAM in California. The authors focused on the two main agricultural production areas of New Zealand: on the North Island, the Hawke's Bay region, known as the "fruit basket " of New Zealand where the major produce is apples, nectarines., kiwis, wine-grapes and assorted row- crops; and on the South Island, the Nelson agricultural region, which is a major production area for apples, currants, hops and wine-grapes. See Figure 1. TT .. : q :9:y x-'w�a':i:..'ya..•a J&..:a>'mb+ >cF <: ... F K r x x..:....�,.�...:,: `�' ;:Vit'. >,�•:'.'a� y .,4 .. y 71 'wti i q{r , :.> An V. 7. M. 0. > Figure 1. New Zealand map Both the Hawke's Bay (Napier) and Nelson areas are similar in terrain and mixed forest areas to California's Monterey Bay and Santa Cruz areas where the California LBAM presence is most dense. The Hawke's Bay region is a bit warmer and moister than Monterey Bay, making it an ideal climate and study area for LBAM. These agricultural regions also have a long history of studying and controlling LBAM and have developed technolo-ies to best protect crops. As shown in Table 1,Nelson and Napier have climates very similar to California's Central Coast. Comparison of Temperature Ranges,Average Mean Temperatures and Precipitation in Monterey,California and Napier,New Zealand in 2007. Months have been aligned to season. 2007 January February March April May lune July August September October November December Santa Cruz,California I emPe'azure lunge IP; 39/61 41/63 42/65 43/68 46/7; 49/74 51/76 52/76 50/77 4 7/74 -13166 39/62 Avera-Tt•mPeratur-(F) 48 52 54 ..5., 55 02 67 63 59 36 5. PreuP Lat-(,ncne,; 6.4 5.5 4.5 2.2 0.7 0.2 0.1 0.1 0.3 1.3 3.5 :•.4 June July August September October November December January February March April May Napier,New Zealand Tcn-rp-tu"•fringe(F) 31/69 36/65 35/66 33/67 3.1/'77 43/83 48/83 45/89 47/86 46/85 38/75 30/7 Average t,•n•Perature(F) 49 50 50 52 58 58 64 66 64 65 54 55 Prcepitd!.u:i(inch-) 3.6 3.3 3.2 2.1 2.2 1.6 2.9 1.8 2.2 2.7 2.5 2.7 .,uu-ce:ntLF:/iww'v:.w-antler y:ounc.co:n, Y:1P://woi:ticlima[e.cem Table 1. Comparison of Santa Cruz, CA and Napier,NZ Temperatures and Rainfall The southernmost area of New Zealand was not visited because its colder,harsher climate is both less hospitable to LBAM than the warmer climate farther north and dissimilar to the climate of areas where LRAM is presently found in California. In addition,New Zealand cultivates hundreds of thousands of hectares of Monterey pine (Pinus radiata) and has planted many Californian species including vintage Monterey cypresses (Cupressus rnac•roccnpa), giant sequoias (Sequoiadendron giganteum), coastal redwoods (Sequoia.sempervirenS'), as well as :native New Zealand conifers. Results and Discussion The subsections below present findings related to LBAM, its biology, behavior, enemies (beneficial control agents), populations, damage, control in New Zealand, and role in New Zealand agricultural trade. -- Biology and Behavior of'L13,1M LBAM is a tortricid (Tortricidae) moth and a member of the leaf-roller moth family in the order Lepidoptera. Each I-BAM individual exhibits three life stages: larva, pupa. adult (moth). LBAM is polyphagous, meaning that it is not host specific but rather feeds on a variety of plant species. A superficial feeder as a larva(see Figure 2), LBAM typically causes cosmetic dainage to the surface of leaves and fruit and only rarely penetrates a host fruit. LBAM does not defoliate plants. Defoliation is contrary to leaf rollers' biological need for leaves that. with the help of thread material, the larvae roll around themselves for protection. The rolled leaves provide protection from predators and the ideal conditions for growth and development. Like all leaf rollers, LBAM is subject to natural predation and parasitism. Nlajor predators and parasites in New Zealand include: birds, spiders, wasps, flies, beetles, lacewings, and earwigs to name only a few. A full listing of enemies to LBAM can be found at: http://wNA,w.hortnet.co.nz/kev/stone/info/eneti;Lies/lba-eneni.litm LBAM may mate up to three times during its I- to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per eg? mass. The majority of the eggs are suhjcct to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (I lortNet Website at http://w\Arw.hortnet.co.nz/publications/procee(lings/ifoam/i foam69.htm) Adult LBAM travel an average of�approximately 100 meters from their hatching sites during their lifetimes and are not necessarily particular about where oviposition (ego- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. 4 1 ` : s ,x. I w i ' F may. ., .... u� _ P'. vn; r•. , ... Y'. ....... v _ 'i a ;; ;..,;:••:: _ r.` ::,. s } yl Figure 2. Superficial leaf damage from LBAM larva LBAM may mate up to three times during its 1-to 1.5-week lifespan in New Zealand. Female moths typically lay 30-50 eggs per egg mass. The majority of the eggs are subject to environmental pressures including predation or parasitism before reaching adulthood and thus do not mature (HortNet Website at http://www.hortnet.co.nz/publications/proceedings/ifoam/ifoam69.htm) Adult LBAM travel an average of approximately 100 meters from their hatching sites during their lifetimes and are not necessarily particular about where oviposition(egg- laying) occurs. The larvae can travel mostly downward by silken threads. Any larva that falls or loses contact with its food source/host plant have little chance of survival, so the larvae stay connected to the plant by the silken thread. Adults move the greatest distances (for dispersal of the populations). LBAM does not form a central colony that can spread and cause detrimental effects in an agricultural field. Because it is polyphagous, LBAM can disperse and survive without concentrating and adversely affecting all plants in a concentrated area. l B,4 AI Hosts and Pol-ndlatioYns in Nest' Zealand Although LBAM is considered by New Zealand HortRescarch, the government agricultural and horticultural research agency, to be "common" in orchards throughout New Zealand and "less common, rare, or even absent" in areas of New Zealand still 5 covered in native forest (HortResearch 2008 http://www.hoanet.co.nz/key/keys/info/distrih/lba-d.ist.htm), LBAM is, in fact, difficult to find in New Zealand. Eighty to ninety percent of LRAM larvae are parasitized by natural predators before maturation (Shaw, 2008). According to New Zealand Ministry of Agriculture and Food (MAF) and Department of Conservation (DOC) experts, LBAM docs 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. For meeting U.S. quarantine requirements, LBAM populations in New Zealand are estimated and monitored using pheromone traps. LBAM is not an insect of significance in Monterey pine plantations in New Zealand. LBAM is a leaf-roller moth that requires flat-surfaced leaves to protect larvae while they mature. Clearwater (2008) notes that LBAM clearly does not have a preference for gymnosperms and is not considered a pest of these plants in New Zealand. Shaw (2008) reports that gorse is a preferred LBAM. host plant in New Zealand; however, the authors found no LBAM larvae on gorse in a wide variety of regions in the North Island and the main agricultural regions of the South Island. In fact, the authors' extensive search for LBAM in native New Zealand habitats during the three-week, 3,000- km extent of this research trip revealed only a few larvae, one on an exotic planting in a hotel garden, as well as a few tortricid moths flying around porch lights in the evening. No evidence of LBAM eggs, larvae or adults was found in the 22, 30-hectare Abel Tasman National Park on New Zealand's South Island. This national park has a mixture of native and non-native plant species with a multi-story diverse habitat of broadleaves. ferns and conifers. Agricultural/horticultural researchers in New Zealand noted that, because LBAM larvae are often parasitized, finding a larva does not mean that a viable adult LBAM will hatch. If a parasite has laid eggs in the larva, the parasite's adults, e.g., wasps, flies will hatch rather than I.,BAM. Due to the need to understand natural controls for LBAM in California and the similarity of types of organisms keepino LBAM under control in New Zealand with those already present in Califorr;.ia, monitoring of levels of parasitism of all life stages should begin immediately for LBAM in California. As noted below in the LBAM Control in New Zealand section, researchers in New Zealand have developed a monitoring protocol that allows them to determine the extent of parasitism of LBAM populations to prevent unnecessary and costly control efforts based on observation of larvae only. Similar parasitism of LBAM is likely occurring in the regions of California where it is present. The Arboretum at the University of California, Santa Cruz has initiated a survey of beneficial insects that may control LBAM. In eight larvae raised to adults, two have been parasitized by natural predators. LBAM Dainaue in New- Zealand 11 LBAM is currently considered a minor biological pest in New Zealand agriculture, including apple, peach/nectarine, citrus, and vineyard crops. Codling moth (``the worm in the apple," also a tortricid) and woolly apple aphids are much more significant pests in 6 apples, and thrips and mites are the pests of significance in New Zealand citrus (Videan 2008) Hawkes Bay horticultural researchers report that, with no monitoring; or treatments and if LBAM were uncontrolled other than by naturally occurring trichogramma or other beneficial insects and organisms, the maximum damage caused by LBAM would be one percent or less of crops (Walker 2008). Reports of damage to crops prior to 1.001 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, insianificant level. New Zealand horticulture and agriculture professionals so successfully use IPM strategies to manage LBAM that in more than 3,000 U.S. shipments of pome (pip) fruit in 2006, only six were rejected. One positive LBAM find can cause rejection of a single 15-ton fruit order (Walker 2008). Thanks to exceptional, modern New Zealand IPM practices, leaf rollers have limited economic impact on fruit or crop production other than occasional shipments rejected by U.S. only because of zero tolerance for LBAM. LB,4R4Control in New Zealand Beneficial insects are considered the first and best line of defense against leaf rollers, and insect growth regulators (IGRO, which are based on derivatives from natural sources, are the primary insecticide used for leaf roller and codling moth control in New Zealand. Growth regulators do not negatively affect beneficial insects to any significant degree. Rather. IGRs are relatively target-specific and cause target larvae to mature faster than normal before the larvae are physiologically ready and so die. To control LBAM effectively with IGRs, it is important to target overwintering LBAM populations. As cooler weather proygresses, adult populations of LBAM drop: adults die off. and larvae do not morph into adults. Tl-ie lowest adult numbers occur in late winter. IGRs are most effective when applied as eggs hatch and larvae begin to feed in warmer summer weather. In California, IGRs should probably be applied in May, but the timing needs to be verified by phenological monitoring using pheromone traps for adult males (Shaw 2008). Treatments with least-toxic IGRs for most other pests, particularly codling moth, which is one of the top apple pests in New Zealand, generally act, along with beneficial insects, as adequate LBAM controls. Biocontrols are effective against all LBAM life stages: eggs, larvae,pupa, and adults. Biocontrols include native and introduced wasps and native tachinid (Tachinidae) flies. The key to effective control with predators and parasites is to encourage a ranee of insects attacking all life stages. 7 In the Nelson area, roughly four to 10 percent of producers are or-panic. Because organic systems encourage beneficial insect populations and do not negatively affect beneficial organisms and insects with the use of harsh chemical controls, pests (including LBAM) are not significant problems .for localized organic producers. The leaf-roller complex, including LBAM and other native New Zealand species, is readily monitored in the early to mid-spring with a pheromone sticky trap and regular visual inspection. Based on monitoring results, a single IGR spray regime can be effective for season-long control. Growers in the Hawke's Bay and Nelson regions do not use mating disruption pheromones to control LBAM. They monitor in late spring with pheromone traps specific to LBAM and codling moth. If the trap counts warrant, an IGR is applied (e.g. Intrepid, Confirm: methoxyfenozide, tebufcnozide). This timed treatment adequately suppresses LBAM and codling moth populations for the year (Walker 2008, Shaw 2008). Pyrethroids (natural or synthetic) are effective controls for LBAM but also are detrimental to beneficial insects and pollinators, making these products undesirable for long-term IPM of LBAM.. Pyrethroids are especially detrimental to native and introduced (honeybee) bee populations essential for pollination and to mammals. History of Organophosphate Control During the late 1980s and 1990s, organophosphates were applied regularly in New Zealand orchards with no monitoring for insect populations. The effort was to create a "sterile nursery" situation where there were no pests and no beneficial insects. Organophosphates were used because of the zero tolerance for LBAM in produce to be exported to the U.S. The chemicals were applied on a schedule rather than in response to pest populations. Under the organophosphate spray regime, LBAM was a problern 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. i:ormulation. Use of organophosphates was eliminated in New Zealand in 2001. HortRescarch experts report that once the use of broad-spectrum organophosphates was stopped and agricultural professionals began monitoring for LBAM and timing IGR sprays, all of which allowed beneficial insects to affect LBAM populations, the LBAM problern reduced dramatically so that the moth is now considered a minor pest (except for the challenge posed by the U.S. Department of Agriculture quarantine) http://w,ww.hortnet.co.nz/key/stone/info/control/lbacontr/lr-chem.htm. Organophosphates were destroying beneficial insects and creating resistant insects, and orchards and vineyards were becoming LBAM breedinVg grounds. Shaw (2008) reports that, at Nelson/ Motueka, "control trees with no insect or chemical controls used have not recorded any damage from LBAM or other leaf rollers for more than 10 years." HortRcsearch staff attempted to force LBAM infestation of these trees by introducing LBAM eggs and larvae into the trees to no avail. Any infestation of these trees by LBAM was quickly controlled by native predators without the need for IGRs. 8 "Once organophosphates were removed from the system and populations of beneficials were left to develop naturally, complete control of LBAM was realized in less than 5 years" (Shaw 2008). When organophosphates were compared to natural controls in consistent blocks of apples, control of LBAM was achieved with natural controls in less than two years. Organophosphates never allowed effective control, and LBAM developed resistance to them. It is worth noting that in New Zealand, intercropping has been shown to promote beneficial insect populations, resultino in near-complete LBAM population suppression to below thresholds for use of control measures (Irvin et al. 2006, Begum et al. 2006) Monitoring Spring populations of LBAM in monitoring traps in total numbers per month is key to deciding whether to use IGRs to control the population. Local monitoring of population levels allows tracking of seasonal fluctuations (Shaw 2008). Monitoring programs should assess levels of LBAM phenologically (at various life stages and, by rearing larvae and eggs from host plants, the degree of predation and parasitism of LBAM. Parasites and beneficial controls may not be seen in early-stage occupation of habitats by LBAM or-other.invading pests but will develop as the predators respond to the presence of LBAM as a possible host. A monitoring protocol has been developed that allows determination of the rate of parasitism of LBAM larvae. Auckland HortResearch Insect Rearing Lab uses a general- purpose diet to rear LBAM larvae so that they can be observed to see if they are parasitized. Larvae are placed in a capped tube with cotton, allowed to develop at room temperatures, and observed to determine whether LBAM develops normally, parasites hatch, or development is adversely affected by other potential control means. The specifics of monitoring and thresholds for treatment are provided on the New Zealand HortResearch website: http://www.liortnet.co.nz/kev/. Eradication and Pheromone Use Widespread LBAM eradication efforts have never been attempted in New Zealand. A very limited eradication program took place during the 1980s affecting two orchards (200 hectares total) in the Nelson region where an insecticide-resistant LBAM strain had appeared. Twist-tie pheromone strips (1000 per hectare) and ground-applied insecticides were used to eradicate this resistant and localized LBAM population. Eradication is very difficult unless a population is quite limited and well defined. New Zealand researchers report that effective mating disruption using pheromones will onlv work under the following specific conditions: Extensive, even, and complete coverage of the pheromone Uniform blocks of a single crop (single canopy height) Uniform topography (no slopes, hills or valleys) Low population density of target pest (not too concentrated) 9 Under the above conditions, twist tics can be used for control under extensive coverage. However, pheromones applied by any means cannot be effectively used across large diverse areas with varying canopy heights. mixed species composition, and varying terrain areas. New Zealand researchers also note that aerial pheromone spraying interferes with monitoring using pheromone traps, and monitoring is critical to successful control. Moreover, use of broadcast pheromone spray to eradicate or control the moth is not effective because female moths issue a more concentrated scent plume than the dispersed pheromone scent of an aerial spray application, so male moths are able to find the females (Shaw 2008). Until tests reportedly carried out under a U.S. government contract in 2008 in southern New Zealand forests ("NZ Forest .Provides I: Lboratory for Pheromone Trials" 2008 http://nz.nevvs.yahoo.(;om/090217/)/p/40zs.htmi), pheromones had never been aerially applied in New Zealand. These trials are been undertaken within a Monterey Pine plantation and does not involve applying the pheromone over urban areas. Pheromones have never been used for widespread eradication anywhere in the world. I IortResearch stations on both islands agree that eradicating LBAM in California and anywhere would require extensive, widespread use of IGRs with repeated applications to address elusive, selected populations. These experts also question the efficacy of bacillus thuringiensis (Bt) against LBAM. Bi: can also have a detrimental effect on beneficial. insects. They report that iGRs do rot harm populations of beneficial insects and that IGRs persist on foliage much more effectively than. organophosphates did. I_,arvae emerging from eggs begin to perish as soon as they start feeding on the grownh regulators. Tests show IGRs are ovicidal as well as larvicidal and not toxic to predatory/beneficial insects. The beneficial effects of the application of growth regulators can be seen one to two days after application (Walker 2008, Shaw 2008). LI.4Mazul Global Trude of. etiv Zealand Agricultural Producls I.,BAM is not of biological concern on either island in New Zealand but remains a pest of concern only because it is a quarantine pest for exports. USDA considers LBAM an "actionable quarantine pest" and has zero tolerance for LBAM finds in pre-inspection of U.S.-bound fruit shipments. Consignments rejected because of any LBAM life stages are sent to non-U.S. markets.. e.g., Europe, which does not have phytosanitary restrictions for LBAM. Today very few New Zealand fruit shipments are rejected by the U.S. (Walker 2008). which further sug`.;ests that New Zealand growers' LBAM controls relying on natural predators and IPM strategies are successful. HortResearch experts say that when USDA announced during the late 1990s that the U.S. would no longer accept fruit treated with or0anophosphates because of concerns for the safety of fruit handlers and consumers, this was the catalyst for abandonment of organophosphates and the move to reliance on natural predators and IPM methods. 10 Implications,ibr California 'Fhe information on LBAM and IPM in New Zealand reported in this report has significant implications for addressing LBAM in California. First, it is worth noting that, according to the National Museum of Natural History Catalog of Type Specimens of Tortricidae (.www.sel.barc.usda.gov/lep/tort_types_list.html), California has 85 native and localized North American species of tortricid moths; none are problematic as a pest. All are kept in check by natural biological controls, so there is confidence to believe that LBAM will also be controlled by native natural predators or parasites. Preliminary studies by the California Department of Food and Agriculture report a high level of parasitization of LBAM larvae by native California trichogramma wasps. Entomologists speculate that LBAM may have been in California for as long as a decade already (Garvey 2007), so it is possible that LBAM is already being controlled by natural predators. Many LBAM predator species in New Zealand are the same or closely related to California species (birds, earwigs, viruses, trichogramma and other wasps, tachinid flies, spiders, beetles., etc.). According to New Zealand information, the pheromone treatment currently proposed for LBAM will most likely not eliminate nor control i,BAM because none of the essential conditions for successful pheromone use can be met. Use of the pheromone cannot be complete (e.g., it cannot be applied over sanctuary buffer zones and along streams/waterways), the pheromone will not be applied over a uniform block but rather over mixed forests and native vegetation, houses, schools, roadways, crops, and ornamental gardens. Moreover, topography of the California coast is highly varied and diverse, and LBAM populations in these areas are dispersed and, in areas of high trapping numbers, are too concentrated for effective use of mating disruption pheromones. In addition, application of mating disruption pheromone alone without the addition of IGRs would not allow for success. Current CDFA requirements that commercial nurseries in California use the orpnophosphate insecticide chlorpyrifos if LBAM larvae are found are in direct contradiction to New Zealand findings that organophosphates destroy LRAM's natural predators, resulting in resistance developing in LBAM populations. New Zealand experts recommend use of IGRs in the control of LBAM in agricultural systems as much safer and more effective. Monitoring should be performed to assess level of predation on LBAM larvae, which could reveal data indicating that less (or no) intervention is required to control LBAM in California. Conclusions The success of New Zealand a�0riculture and horticulture professionals in controlling LBAM and other leaf-roller pests using IPM techniques and few or no chemical applications is a model of best 11'M practices that can be readily adopted in California to 11 control LBAM, particularly because many of the natural LBAM predators that are present in New Zealand are also found in California. The finding that there is no evidence of biological or environmental threat from LBAM in New Zealand, which has climate and crops much like California and where LBAM has been an established exotic for more than a century, bodes well .for the ability of California agriculture and ecosystems to accommodate to LBAM.'s presence and suggests that USDA classification of LBAM as an actionable quarantine pest should be reviewed and revised. USDA's pest quarantine list needs to be re-evaluated based on current, relevant, science-based information. New Zealand researchers say that it will be very problematic to attempt to eradicate this insect as it has now been firmly established over an extensive and diverse area. In California,LBAM is found across more than 7000 square miles of varied terrain and conditions, including within protected buffer zones and sensitive riparian corridors. The negative impact of organophosphate use on beneficial predator species in New "Zealand, along with the known short- and Ion.­term health and environmental dangers of these chemicals, suggests that requirements for organophosphate controls for LBAM in the U.S. should be abandoned. The requirement that California nurseries use chlorpyriphos sets California up for failure of long-tern I..BAM management and management of future pests that would otherwise be controlled by natural predator species that will be compromised or eliminated by ch.lorpyriphos use. This and other highly toxic treatments need to be discouraged or prohibited in commercial nurseries. The short- and long-term risks to exposure of organophosphates and the long-term persistence of organophosphates in the environment make their continued use for control of LBAM inadvisable. A realistic assessment of LBAM populations and potential damage based on New Zealand data must rely on recent studies published after t1le use of organophosphates stopped. Organophosphate use causes an unnatural situation to develop in which natural predator populations are unable to function. There may not be any need to introduce a non-Tiative control for LBAM in California; natural controls may already exist in the native fauna given the robust numbers of native Tortricidae in California. Summary of Recommendations Based on the findings above, the key recommendations of this report are to: • Suspend planned aerial and ground treatments for Light Brown Apple Moth (LBAM) in California and monitor to determine extent to which LBAM populations are being parasitized or destroyed by predators. • Adopt IPM best practices from New Zealand to control LBAM if necessary. 1"' • Review USDA classification of LBAM as an actionable quarantine pest based on current, relevant, science-based information. • Eliminate requirements for organophosphate controls for LBAM in the U.S to product natural predator species that feed oil LBAM and other pests. • Realistically assess the potential impact of LBAM in California using New. Zealand data published since the use of organophosphates in New Zealand stopped. Sources The information in this report comes from the authors' consultation with the followino researchers and agricultural experts in New Zealand: Jim Walker, PhD, Technical Research Scientist, New Zealand IIortResearch Mike Butcher PhD, Technical Manager, New Zealand PipFruit Association Peter Shaw, PhD, Research Entomologist, Insect Science, New Zealand HortResearch Paul Turner, Liner Plants New Zealand Geoff Davidson, Oratia Native Plant Nursery, Oratia Phil Smith, Owner, Taupo Native Plant Nursery, Taupo Mark Dean, Owner, Naturally Native, Tauranga Chris Green, Technical Support Officer, Biodiversity (Invertebrates and Biosecurity) Department of Conservation Phil Knightbridge, Department of Conservation, Botanist John Clearwater PhD, Research and Consulting, Pheromone Technology, Organic Growing Systems, Auckland Ian Videan, Eskdale Orchard,Napier REFERENCES Begum et al. 2006. Using selective food plants to maximize biological control of vineyard pests. Journal of Applied Ecology,43: 547-554. l3 Garvey, K. K. 2007. "Entomologists Targeting Light Brown Apple Moth." University of California News. http://www.universityofcalifornia.edu/news/article/9323 Irvin, N.A., S.L. Scarrett, S.D. Wratten, C.M. Frampton, R. B. Chapman, and J.M. Tylianakis 2006. The Effects of floral understoreys on parasitism of leafrollers (Lepidoptera: Tortricidae) on apples in New Zealand. Agricultural and For'eSt Entorrrology 8, 25-34. "NZ forest provides laboratory for pheromone trials" 2/17/08; http://nz.news.yahoo.com//080217/3/40zs.htnil Thomas. W.P. 1987. A Revieiv of Biological Control of'Inver'tebrate Pests and {Deeds in New Zealand 1974 to 1987. Emerson, P.J., R.J. hill, J. Bain, and w.P. Thomas. Wollingford: CAB International. r. f ,,Ph Vie,....•. w s� s. :.y I �o4 I Figure 2. Superficial leaf damage from LBAM larva About the Authors Di-. Daniel Harder-is the Director of the University of California at Santa Cruz Arboretum and Adjunct Professor in the Department of Ecology and Evolutionary Biology at UC Santa Cruz. The Arboretum maintains an extensive collection of' 14 Australia,New Zealand, California natives, and southern hemisphere species within a 100 acre botanical garden on the UCSC campus. Dr. Harder is an expert on plants of Asia and the Pacific Region, and Africa and has published papers on his research on tl-le floras of Central Africa and Viet Nam including works on the pharmaceutical properties of plants, taxonomy, ethnobotany, and new species discoveries. Ieff Rosendale is a grower and horticultural consultant in the Monterey and San Francisco Bay Areas who specializes in the cultivation and uses of plants from California, Australia, South Africa, New Zealand and Mediterranean Europe. 15