PIERCE'S DISEASE LETTER TO CDFA SECRETARY LYONS

[EWerb at aol.com]

this is not another stupid email petition or a story about president reject 
bush -
this is a plea for reduced toxicity in the war on the environment - plus we 
can argue that it is a kyoto credit...

Californians for Pesticide Reform

Action Alert

SIGN ON TO PIERCE'S DISEASE LETTER TO CDFA SECRETARY LYONS (REVISED 
POLICY STATEMENT)
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Action: Please read and endorse the following letter to CDFA Secretary Bill
Lyons by 5:00 pm on Friday, December 8. The letter
will be used to call on the California Department of Food and Agriculture
to prioritize public health and environmental protection, ensure adequate
public notification and participation in decision making and promote organic
and sustainable approaches to controlling Pierce's disease. The 
letter is a revision of the
policy statement you may have signed on to earlier.  Changes reflect 
comments we
received following the release of the original version.
Thank you to those of you who provided input. We will deliver the letter to
CDFA Secretary Bill Lyons on December 12.

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SIGN-ON FORM

Please email back this sign-on form to pests at igc.org.

__ Yes, Add my organization to the list of groups endorsing the
following letter.
Name:
Title:
Organization:
Address:
Phone:
Fax:
Email:

For more information, contact Jessica Hamburger at Pesticide Action
Network, jah at panna.org, 415-981-1771.
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William J. Lyons, Jr.
Secretary, California Department of Food and Agriculture
1220 N Street, Suite 409
Sacramento, CA 95814

Dear Secretary Lyons:

We, the undersigned public interest groups, call on the California 
Department of Food and Agriculture to enact the following proposals. 
Implementation of our recommendations will prioritize public health 
and environmental protection, ensure adequate public notification and 
participation in decisionmaking and promote organic and sustainable 
approaches to controlling Pierce's disease.

I. Background

Pierce's disease, caused by the bacterium Xylella fastidiosa, has 
affected grapes in California for over 100 years. Insect vectors 
spread the disease from one plant to another. A more effective vector 
for the disease, the glassy-winged sharpshooter (GWSS), has become 
well established in Southern California and is spreading throughout 
the state. There is no widely recognized cure for Pierce's disease. 
Scientists familiar with the GWSS have testified before the state 
legislature that the spread of the insect to new areas of the state 
could cause major economic losses to the grape and wine industries. 
The federal and state governments have declared a state of emergency, 
and have allocated over $35 million to the California Department of 
Food and Agriculture (CDFA) to create the Pierce's Disease Control 
Program.

CDFA's current program to control the GWSS needlessly endangers the 
public, does not involve those most impacted in the decisionmaking 
process, and is likely to fail to prevent or cure Pierce's disease. 
The primary problems with the program are:
x Local agencies are endangering public health by spraying pesticides 
around homes and by aerial spraying agricultural land, a practice 
that can result in pesticides drifting into neighboring communities.
x Current efforts rely heavily on the use of highly hazardous 
pesticides, including the nerve poisons Lorsban and Sevin.
x The decisionmaking process does not include adequate public participation.
x Use of broad-spectrum insecticides is killing off beneficial 
insects that keep other pests in check.
x There is no long-term plan for the prevention or cure of Pierce's disease.
The program's current focus on spraying pesticides is unacceptable. 
We call on CDFA to end the state of emergency and conduct a full 
environment impact report (EIR) under the California Environmental 
Quality Act (CEQA). The program must shift its emphasis to developing 
organic and sustainable disease prevention measures and non-chemical 
and least-toxic methods of pest control. These investments will 
benefit agriculture by minimizing crop losses due to Pierce's disease 
and will protect public health and the environment by reducing 
reliance on hazardous pesticides. Investing in organic and 
sustainable agriculture is good for the economy and good for the 
environment.

II. Recommendations

1. Protect Public Health, the Environment and Organic Farms
x Protection of public health and the environment should be a primary 
factor in selecting options for controlling and preventing Pierce's 
disease.
x All CDFA program components must comply with applicable public 
health and environmental laws, including the California Environmental 
Quality Act, the National Environmental Policy Act, the Clean Water 
Act, the Clean Air Act, the Endangered Species Act, the Federal 
Insecticide, Fungicide and Rodenticide Act and any other applicable 
laws.
x Completion of a full EIR under CEQA shall be a precondition for the 
disbursement of funds. An EIR is essential because it will ensure 
public disclosure of the public health and environmental effects of 
the program and evaluation of alternative approaches that have fewer 
health and environmental impacts.
x No Pierce's Disease Control Program funds should finance the use of 
synthetic pesticides, including EPA Category I and II acute poisons, 
nerve toxins (including Lorsban and Sevin), known or probable 
carcinogens, reproductive or developmental toxicants, or are known to 
have contaminated California groundwater.
x Broadcast (including aerial) applications of pesticides to combat 
Pierce's disease must never be used.
x Organic farms, urban mini-farms, gardens and landscapes must not be 
contaminated by forced pesticide spraying. Maintaining these organic 
islands will ensure the availability of release sites for natural 
enemies of the GWSS, and will prevent financial losses to growers and 
damage to backyard conservation efforts.

2. Ensure Adequate Public Notification and Input
x CDFA must inform residents of their right to refuse to allow 
spraying of pesticides and their right to use alternative methods on 
property that they own or rent. Pierce's Disease Control Program 
funds should be made available to hire experts to provide 
non-chemical control of GWSS around homes, schools, hospitals, 
nursing homes and other sensitive areas.
x If pesticides are used, the public must be notified in advance of 
any applications. Neighbors within a one-mile radius of the proposed 
spraying must receive notice at least two weeks in advance, with a 
second 24-hour notice of the details of the plan. Residents must be 
provided with information about the health and ecological impacts of 
the chemicals to be used.
x All decisions about Pierce's disease control should be transparent 
and include adequate public input. This includes decisions at the 
federal, state, county and local levels. Specifically, the process 
should include the following provisions:
a) State regulations and plans and county workplans must be subject 
to health and environmental review with public involvement through 
the preparation of a full EIR under CEQA.
b) Any county that is developing a Pierce's disease control workplan 
and/or designating a "local public entity" to implement the workplan 
must hold a public hearing, making the draft workplan publicly 
available at least ten days in advance. The purpose of these hearings 
should be to involve the public in real decisionmaking, not to simply 
inform them about what action is going to be taken.
c) The local public entity should be a task force chaired by the 
county board of supervisors.
d) County GWSS/Pierce's disease task forces and CDFA's Pierce's 
Disease Advisory Task Force and Glassy-Winged Sharpshooter Science 
Advisory Panel must include diverse representation. All three groups 
should have at least one representative from each of the following 
stakeholder constituencies: public health organization; environmental 
organization; organic farmer; and a community representative from an 
area that is impacted by Pierce's disease policy. Meetings should be 
sufficiently posted in advance and should be open to the public.

3. Promote Organic and Sustainable Approaches
x Growers must take preventive measures to control Pierce's disease. 
Preventive steps should include the following:
a) Avoid planting grapes in areas that are known to be Pierce's 
disease hotspots;
b) Avoid planting grapes next to crops known to harbor large 
populations of GWSS, such as citrus;
c) Avoid planting grape varieties known to be susceptible to Pierce's 
disease; and
d) Immediately remove plants exhibiting symptoms of Pierce's disease.
x Pierce's disease control program funds should be used to assist 
growers in adopting organic and sustainable practices through on-farm 
research, technical support and cost sharing. The program should 
emphasize improving soil fertility and plant health, planting 
resistant varieties and reducing soil erosion. Growers should be 
assisted in using buffer zones, mechanical controls and non-toxic 
confusion and diversion strategies to keep GWSS from feeding in 
vineyards and orchards. The program should support agricultural 
practices that reduce pest problems by providing for a diversity of 
predatory insects, diverse cropping patterns and habitat diversity.
x Genetically modified organisms (e.g., bacteria, insects and plants) 
should not be used to combat Pierce's disease and no public funding 
should be allocated to such approaches.
x The introduction of non-native beneficial insects to control the 
GWSS should be avoided unless research shows that native beneficials 
cannot provide adequate control. Non-native species may be introduced 
only if research shows that they would not cause collateral damage to 
local ecosystems.
x If analysis of the threat posed by GWSS justifies it, CDFA should 
implement quarantine on the shipment on all nursery stock, vines, and 
grapes from counties where GWSS infestations have been discovered. 
Using pesticides on nursery stock and grape shipments that are 
suspected of containing GWSS adults, nymphs or egg masses will be 
ineffective and will cause unnecessary health and ecological impacts.
x CDFA must ensure that grape plants offered for sale are free of 
Xylella fastidiosa, the bacterium that causes Pierce's disease. The 
effectiveness of CDFA's current nursery certification program 
designed for this purpose should be evaluated and improved as 
necessary.
x Selection of control measures must take into account impacts on 
beneficial insects that pollinate plants and keep other pests in 
check.

The undersigned organizations call on the California Department of 
Food and Agriculture to enact our recommendations.

Pesticide Action Network
Californians for Pesticide Reform
California Public Interest Research Group
Organic Farming Research Foundation
Sierra Club
(your group)

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--------------------
-- 
Californians for Pesticide Reform
49 Powell Street, Suite 530
San Francisco, CA 94102
Phone 415-981-3939 ext. 6
Fax 415-981-2727
pests at igc.apc.org
www.igc.org/cpr


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