Light Brown Apple Moth in California

Light Brown Apple Moth

Urban aerial spraying cancelled, future uncertain
Background on LBAM - the Light Brown Apple Moth issue
PANNA's position
Selected news and updates
Pesticides in Light Brown Apple Moth management
Pheromones and least hazardous pest management
Aerial release of pheromones
Community involvement in Light Brown Apple Moth management
Assessing the alternatives
Eradication vs. EPM
Action and more information
Resources

Urban aerial spraying cancelled, future uncertain

On June 19, 2008, California announced that it will abandon aerial spraying over urban areas in its program to eradicate the light brown apple moth (LBAM). In its place, a program of sterile moth release will be launched in early 2009.

Pesticide Action Network is pleased that the State heard our concerns and the voices of so many Californians. PAN and many other groups have been meeting with California Department of Food and Agriculture (CDFA) and other officials for months, urging them to replace unnecessary spraying with ecologically-sound and safer ground-level biocontrol programs. Sterile moths are a very good idea for long-term management of a pest like the LBAM.

We join CDFA in calling on the U.S. Department of Homeland Security to substantially increase investment in preventing future entry of invasive species into the country, to fill the extensive vacancies in Agricultural Inspection Stations. And we urge the State to invest in rebuilding California's once-robust biocontrol program. We also call on USDA to reclassify LBAM so as to remove the requirement for emergency "eradication," and on the federal government to reconsider trade policies that have contributed to this pest "crisis".

While the canceling of plans to spray the greater Bay Area is cause for celebration, PAN remains concerned about continuing elements of CDFA's LBAM Action Plan, including use of the nerve toxin pesticide, chlorpyrifos, in nursaries, and the lack of a more general abandonment of aerial application of pesticides in rural areas. To date, CDFA has not released its updated Action Plan to the public, and has not responded to requests submitted by a coalition of public interest groups and Bay Area cities, submitted by EarthJustice in June, July and most recently on August 20, for disclosure of adequate information concerning the revised eradication program.

We invite those residents and organizations who have worked so effectively to convince the State to stop the LBAM spray program to join in the larger campaign to replace hazardous pesticide use with ecologically sound, socially just pest management and to support sustainable agriculture. And PAN urges the state Legislature to adopt Assemblywoman Fiona Ma's bill, AB977, to overturn California's "preemption law" that prevents towns, cities and counties from regulating pesticides. Were it not for state preemption, local jurisdictions could have stopped the LBAM spray program and forced the state to consider more prudent approaches to control this latest invasive pest.

Background

According to CDFA, the LBAM is an exotic pest that was positively identified in portions of the San Francisco Bay Area and Los Angeles in 2006. It is a native pest to Australia and has been extablished in New Zealand for a century, as well as in New Caledonia, Hawaii, the United Kingdom and Ireland. This moth can affect a wide variety of plants, flowers, fruits and vegetables. By July 2007, traps set by agricultural officials had collected some 5,000 moths, mostly in Santa Cruz and Monterey along the Central Coast. Under pressure from the US Department of Agriculture (USDA), 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; in April a judge blocked spraying in Santa Cruz county pending an Environmental Impact Report, and the governor announced spraying would not be resumed anywhere until at least August 17, 2008. On June 19, the urban aerial spraying program was cancelled in favor of an approach based on releasing sterile moths in early 2008, combined with ongoing ground-level control measures. The state has withdrawn its appeals of the court judgments blocking spraying; and on Sept. 30 and Oct. 1, the governor signed into law two measures to strengthen prevention of invasive species. The bills also require the state to hold hearings on alternatives, list all ingredients of products before any future aerial spray program is launched, and give greater attention to protecting public health in responding to new pests.

Pesticide Action Network's position on LBAM management

PAN North America believes that communities, farmers and agencies must come together to control invasive pests like the light brown apple moth. We believe that the LBAM appears to have established such a substantial presence in California in recent years that eradication is not practical or possible. Yet if not controlled, LBAM has the potential to do significant economic and environmental damage in California and other parts of North America. We further recognize that LBAM and similar pests, if not controlled, could require quarantines beyond the current short-term county-level restrictions imposed by CDFA, affecting the economic viability of organic and conventional farms, small and large.

Pesticide Action Network supports CDFA in choosing least-toxic pest control responses to LBAM, including sterile moths and ground-level use of pheromones, as far preferable to and ultimately more effective than use of dangerous organophosphates such as chlorpyrifos. PAN strongly opposes use of highly hazardous pesticides, whether to treat nursery plants as envisioned in CDFA's 2008-2009 LBAM Action Plan, or to control LBAM populations in the long term. Such uses put farmers, nursery staff and farm workers at great health risk, and as such are unjust.

We support increased resources for the agency for monitoring and prevention of invasive species, before extraordinary measures such as those proposed for LBAM become necessary, and for intensified research in and increased capacity to implement ecological pest management (EPM) approaches. We call for full disclosure — in open discussion with affected communities — of the extent of the LBAM infestation; of realistic estimates of damage to date and predicted damage; of all ingredients (active and inert) of pest control products in use or under consideration; of health risks associated with a variety of control measures; and of efficacy of these measures.

PAN has challenged the efficacy and safety of aerial spraying of pesticides generally, and we applaud cancellation of continued aerial spraying of the pheromone-based product CheckMate™ or similar products. We are pleased that CDFA has acknowledge the availability of ground-level alternatives, and is now committed to prioritizing development of a sterile moth release program. Evidence that aerial application over urban areas would effectively control LBAM is lacking, and aerial spraying poses unknown potential for health damage.

We continue to urge CDF and the Department of Pesticide Regulation to seek independent scientific advice and complete and publish an environmental impact review before resorting to further spraying, even in remote or rural areas. We appreciate that the Office of Environmental Health Hazard Assessment (OEHHA) has published a health impact study of the spraying conducted in the Monterrey and Santa Cruz areas, but we continue to urge CDFA to convene an independent scientific advisory group to verify agency assessments; to release full information about all ingredients in CheckMate or other pesticide products before use in aerial or ground applications; expand its public information campaign about LBAM to increase transparency and generate two-way communication; and heed the will of local jurisdictions in regard to pest control methods.

We urge CDFA to continue to prioritize development of least-toxic ecological pest management approaches to control LBAM and other invasive as well as native pest species, in addition to sterile moths, and to reallocate the substantial funding secured for aerial application into expanded utilization of ground-level EPM methods.

Updates

Nov. 6, 2008 - "A long-awaited review of a pesticide that was sprayed on 83,500 acres near Santa Cruz and Monterey last year to fight a pest moth concludes there is not enough information to tell if there is a link between the spray and health problems reported by residents," the San Francisco Chronical reports. The reviews noted, though, that the spray drifted up to four miles from the target sites. The state studies focused on short-term health effect. Margaret Reeves, a senior scientist at PAN, commented that "'Potential exposure to individuals would also occur over an extended period of time, making it absolutely necessary that the evaluation of health effects must take into consideration chronic, or long-term, exposure.'"

Oct. 6 - The City Counsel of Albany, CA, in the East Bay, unanimously adopted a resolution supporting "re-establishment of the right of local governments to adopt pesticide regulations that are stricter than state laws;" and resolving to "work with other California cities, counties and the League of California Cities to reform state pesticide practices to limit or eliminate use of pesticides and to overturn state preemption of local pesticide regulations".

Oct. 1 - The governor has signed two laws to address public concern about California’s plan to use aerial spraying to control the light brown apple moth: AB 2763 (PDF) and AB 2765 require the Department of Food and Agriculture to hold meetings to assure community input on any plans to deal with "high priority" insect, plant or animal pests, to consider alternatives and evaluate the public health risks, and reveal each ingredient in the pesticide to be sprayed. PAN and allies supported all three measures. The Invasive Pest Coalition (a California growers trade group) joined health and environment activists in supporting the bills to ensure that effective measures are used for future invasive pest control while protecting public health.

Sept. 26 - "The state has dropped its appeal of Santa Cruz Superior Court Judge Paul Burdick's ruling to stop aerial spraying for the light brown apple moth until an environmental review is complete," the San Jose Mercury News reports (PDF). CDFA spokesperson Steve Lyle said the move comes as the agency "'shifts direction'" from aerial spraying of residential areas to releasing sterile moths. "Lyle said the deputy attorney general submitted the necessary paperwork on Wednesday."

August 22 - The California Senate has approved legislation that "would require the state or county agency considering spraying to hold at least one public hearing to consider alternatives" and also to "evaluate the public health risks and reveal each ingredient in the pesticide to be sprayed" before spraying. Assembly member Jared Huffman (D-San Rafael) introduced the bill that now goes back to the Assembly with amendments.

August 14 - The Associated Press reports that CDFA has "gotten Mediterranean fruit flies to bug out of three counties where infestations led to a year-long quarantine of local produce." Those who support biocontrol approaches to invasive pests like the LBAM can take heart that CDFA was able to control the Medfly in Los Angeles, Santa Clara and Solano counties without the use of chemical pesticides, by blanketing the affected areas with sterile male flies.

August 6 - During the uprising against aerial application of CheckMate for control of LBAM, many more Californians became aware that a state “preemption” law, adopted in 1984, says that “no ordinance or regulation of local government… may prohibit or in any way attempt to regulate any matter relating to the registration, sale, transportation, or use of pesticides.” In response, Assemblywoman Fiona Ma introduced AB977 to reclaim local control. Read an Aug. 6 editorial, "Pesiticide use is a local issue," in the Marin Independent Journal.

July 1 - "Proliferation of the light brown apple moth across San Mateo County in recent months has prompted state officials to put most of the Bayside in a continuous moth quarantine area, and the county is asking residents to take measures to stop the insect from spreading even further." See the Mercury News for the complete story.

June 20 - Activists and politicians applauded the State's decision on June 19 to abandon aerial application of pheromone-based products over urban areas. "The research, Web sites, community outreach, lawsuits and lobbying done by thousands of citizens from Pacific Grove to Sonoma created the pressure that made this possible," declared John Russo, founder of StopTheSpray.org, one of the early leaders of opposition to the State's LBAM eradication plan. "This is an extraordinary example how people can come together, get involved and make a difference," he said, according to CBS5.com. "Aerial spraying will still be used in rural agricultural areas that are inaccessible by road and the twist ties containing the pheromone will still be installed on plants and fences to eradicate the moth," said USDA spokesman Larry Hawkins.

June 6 - "Activist organizations have accused the California Department of Food and Agriculture of mounting 'an aggressive outreach campaign' to encourage Central Valley cities and counties to pass resolutions supporting its efforts to eradicate the light brown apple moth." Following a CDFA presentation in the Fresno County town of Reedley, the City Council acted to support the agency's spray program in the Bay Area. Ten Central Valley local governments have done the same, while some 30 in Bay Area are on record opposing the spraying. The Fresno Bee has the story.

June 5 - In Sonoma County CDFA is responding to trapping two moths (in mid-February and late April) by attaching pheromone-infused twist ties to fences and trees, instead of aerial spraying. A 15 square mile local quarantine zone is also in place, and more than 900 traps are set to monitor for the LBAM. On May 7, the Sonoma City Council passed an anti-spray resolution.

June 1 - Three prominent entomologists from the University of California, Davis wrote that the pheromone eradication program simply won't work. KNTV quoted Dr. James Carey that, "there's some insects that can't be eradicated and this is simply one of them". UCD toxicologist Bruce Hammond added that, while the pheromone spray used by CDFA poses only a minor health risk, it is worrying people sick over an intrusive pest control approach that will not work.

May 12 - A judge in Monterey County joined the Santa Cruz court's similar rulling that "aerial spraying to eradicate an invasive moth in Monterey County may not go forward in populated areas without a full environmental review," reports the San Jose Mercury News. CDFA expects to complete the review by Jan. 2009, and plans to appeal both rulings.

May 8 - A San Francisco "town hall meeting" convenes at 7pm in the Hall of Flowers at Strybing Arboretum in Golden Gate Park, with organic farmers, scientists, physicians, activists and politicians discussing LBAM spray plan. Meanwhile, two engineers have challenged the state's claim that the microcapsules in Checkmate were too small to pose a health hazard, claiming that there are "potentially many more inhalable particles in the spray". CDFA has announced it will reopen the issue.

April 24 - The Santa Cruze Sentinel reports that "The state will not be allowed to spray pesticide over Santa Cruz County in June after a ruling in Santa Cruz County Superior Court today ordered California leaders to finish an environmental review first. Judge Paul Burdick said the state did not prove that the invasive light brown apple moth poses an immediate threat to life or property. As a result, he said, an emergency exception to finish the review while the spraying continues was not justified." Meanwhile, the Governor assured officials in Marin that spraying would not resume until at least August 17, following competion of state analysis of spray product toxicity.

April 21 - The California Farmer reports that Carmel Representative Sam Farr is pressing USDA for details on how the LBAM was classified as a pest requiring extraordinatry response, and whether that decision might be revised. The Monterey Herald asks, "Would it come as a surprise if we were to learn eventually that the apple moth was declared a pest mainly as a strategic move on the chess board of global trade, not because it eats many apple trees or grape vines?" The paper called on spray opponents and state legislators to join Rep. Farr in "pushing Washington for clear and meaningful answers, and for the evidence to support those answers."

April 15 - In a legal brief responsding to the lawsuit filed by Santa Cruz County and City to block further aerial spraying, CDFA warned that if a pheromone product is delated, the state might turn to spraying bacillus thuringiensus (Bt), "which the brief describes as 'an insecticide that is a lethal agent and is not species specific,'" reports the San Jose Mercury News. Santa Cruz Councilmember Tony Madrigal accused state leaders of scare tactics: "'They're proposing a choice to the people between bad and worse.'"

April 10 -- State agencies released their long-awaited report (PDF) on possible links between CheckMate spraying and illnesses reported in Monterey and Santa Cruz after fall 2007 applications. “We examined all of the complaints and it was not possible to link the reported symptoms to the aerial spraying,” says Office of Environmental Health Hazard Assessment (OEHHA) Director Joan Denton. PAN's Margaret Reeves commented that opposition to aerial spraying will continue due to "the stress and concern that it will inevitably cause among a population that they're being sprayed by something beyond their control."

Meanwhile, state legislative measures to block further spraying, including one that would require local consent, are fairing well in the state legislature. And, the San Jose Mercury News reports, "...in an effort to stop the spraying, Rep. Sam Farr, D-Carmel, on Wednesday took the fight to Washington, D.C., as he grilled U.S. Department of Agriculture officials on why the aerial spraying is necessary."

April 7 -- Several organizations submitted letters to the CA legislature supporting resolutions to halt aerial spraying for LBAM until health and environmental assessments are completed. Pesticide Action Network and Communities for a Better Environment are supporting resolutions by Bay Area Assemblymembers Huffman, Laird and Leno.

Mar. 20 -- PAN submitted detailed comments critiquing CDFA's 2008 spray program and challenging the USDA/CDFA eradication goal as impractical and unscientific.

Mar. 12 -- Amidst increasing public opposition to CDFA's plan to resume aerial application with a new formulation of CheckMate, on Mar. 10 the directors of California Certified Organic Farmers withdrew its support of aerial spraying. On Mar. 6, the SF Chronical reported that prominent scientists do not believe the LBAM is as substantial a threat to agriculture as CDFA and USDA maintain, and that the eradication plan is unlikely to succeed. "'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," the Chronicle reported.

Feb. 15 -- The CDFA has released its revised "2008-2009 LBAM 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 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 reported that CDFA had invested $500,000 in a Washington, D.C. PR firm to deal with growing opposition to spraying.

Jan. 10, 2008 -- "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. After the first aerial spraying, residents began to complain of shortness of breath and sharp stomach pains. On Jan. 5, local groups alledged that more than 600 health complaints had been filed. CDFA spokesman Steve Lyle said his agency had received 330 complaints of spray-related illness...insisting that "the agencies with the jurisdiction to review the product have told us it's safe to use.... [and] 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, 2007 -- 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. The report includes recommendations to CDFA that local health care providers be prepared to recognize possible symptoms and to know how to report illnesses, and that a a formal health study and tracking program be set up to monitor and assess long- and short-term health outcomes associated with exposure to Checkmate.

EPA Region 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." On Oct. 20, Gov. Schwarzenegger asked CDFA 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.

Hazardous pesticides in LBAM control

Early on in the discovery of the widening LBAM outbreak in California, chlorpyrifos and malathion -- both highly hazardous organophosphate 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.

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).

One study summarizes why pheromones may be particularly useful for keeping populations of invasive moths under control: "A key benefit of pheromone-based programs is that they are highly selective. Typically, only the primary target species responds to the pheromone, and nontarget effects on biological control agents within a field or outside of a cropping system are not observed. The use of pheromones against key pests does not result in outbreaks of secondary pests or pest resurgence, creating opportunities for the biological control of other pest species."

PAN supports the least invasive methods of application of these organic remedies, 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 thuringensis (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 Español). 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 [in the state so far]," the Los Angeles 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 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.

PAN does not endorse the aerial application of pheromone-based or other products due to questions we have regarding possible adverse health impacts of the various products proposed, including the inert ingredients, the efficacy of aerial application in general and over mixed-use habitats 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 independent 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. Further, we call on USDA to reveal the history and rationale for listing the LBAM as a critical pest, including any connections to trade issues, and why, if this is an important invasive pest, efforts at monitoring and early intervention were either not made or were not effective.

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 or other products (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:

scientific evidence demonstrating the efficacy of aerial pheromone release in LBAM control (including evidence relevant to application in central coast ecosystems);
independent review of epidemiological or occupational health studies of the effects of aerial pheromone release;
continued monitoring of environmental impacts;
monitoring and independent assessment of the illness reports following aerial applications of pest control products;
comprehensive analysis of the economic and social costs/benefits of alternatives under different scenarios, including quarantines and trade agreements that require them. 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. Ecological Pest Management

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 pest management (EPM - a term PAN prefers to IPM [Integrated Pest Management] becasue IPM has often been expropriated by the pesticide industry to mean just substitution of one less toxic pesticide for another) is the appropriate response. We encourage CDFA to continue focusing on least-toxic approaches, not only sterile moths, but also ground-level applications of pheromones, preditor wasps and other biological control and to work with EPM 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.