The California Department of Food and Agriculture recently released its annual report to the California State Legislature on its light brown apple moth eradication program. The report continues the agency’s pattern of relaying inaccuracies about LBAM and the eradication program to the Legislature, California farmers and the public.

The pattern of misrepresentation has been repeated in the draft environmental impact report for the LBAM eradication program. The draft EIR (paid for by CDFA) provides the basis for advancing the program and drawing public funds.

This letter corrects some of the basic inaccuracies in the CDFA’s 2008 annual report. The most egregious misrepresentation appears in the first words:

“Analysis of health complaints from aerial pheromone applications by the Office of Environmental Health Hazard Assessment, Department of Pesticide Regulation and Department of Public Health [found] no correlation to the aerial pheromone applications.”

This contradicts the conclusions of OEHHA, which stated in an April 2008 press release: “… the Agencies concluded in the report that they cannot conclusively determine whether or not there is a direct link between the reported symptoms and aerial spraying… We cannot exclude the possibility that one or more ingredients in the LBAM product could cause an allergic response in sensitive individuals.”

For CDFA to present OEHHA’s findings as having “no correlation” tells half the truth. According to OEHHA, it is equally likely the aerial pesticide used was responsible for the respiratory problems reported.

NO ONE FORMALLY INVESTIGATED THE ADVERSE HUMAN OR ANIMAL HEALTH EFFECTS.

CDFA’s statement also fails to address the 400-plus adverse health effects reported after the aerial spraying of LBAM-associated pesticides over Monterey and Santa Cruz counties in 2007, including the near-fatality of an 11-month-old boy who suffered a respiratory attack. Additionally, more than 650 seabirds died, pets were sickened and countless bees disappeared. No one formally investigated the adverse human or animal health effects.

The CDFA’s report also misrepresents the impact of LBAM on California. The report states that because LBAM is new to the continental United States, it has no natural predators. However in 2008, CDFA itself convened a scientific symposium on LBAM. There, Dr. Nick Mills, Professor of Insect Ecology at UC-Berkeley, provided evidence showing that California has multiple parasitoids that directly feed on LBAM.

At that time, Mills reported on three California parasitoids. But at an LBAM stakeholders meeting convened by UC Cooperative Extension in Watsonville, Mills reported that the number of known LBAM parasites is now up to 13 – giving LBAM more parasite predators than any other tortricid in California.

And, parasitoids are only one of the predators that feed on LBAM. According to international research, there are more than 70 different classes of LBAM predators, including spiders, ants, bats, birds, flies and beetles as well as a host of viruses. California already hosts a majority of these.

That tens of thousands of LBAM have been detected in Golden Gate Park in the past three years – all without causing any damage – is a testimony to this high level of natural parasitization and predation.

Since the inception of the LBAM eradication program, independent scientists in the United States and New Zealand have questioned the scientific basis for it. CDFA has been highly criticized for keeping alive a program that many believe is not necessary and cannot succeed.

The California Legislature is urged to:

• Question the findings of the draft EIR.

• Request that CDFA provide evidence that its assertions about LBAM’s destruction of our California food supply and native flora are true.

• Request from the University of California system a truly independent and comprehensive review of the scientific petition requesting the reclassification of LBAM from Class A (major pest) to Class C (of minor concern), as submitted to the United States Department of Agriculture in September 2008.

• Cut the funding for this program, which harms the farmers, growers, economy, health and environment of California.

ROY UPTON is the LBAM Liaison for the Soquel-based group Citizens for Health. An unedited version of the above commentary was presented as an open letter to the California Legislature. Draft EIR comments may be submitted by Sept. 28 to Jim Rains, Staff Environmental Scientist, California Department of Food and Agriculture, 1220 N Street, Sacramento, CA 95814; fax (916) 654-1018; or e-mail LBAM_EIR@cdfa.ca.gov.