dawn
Please circulate this widely.
We did get an extension through the end of June on the comment period for the
herbicide draft environmental impact statement for cannabis eradication on
federal, non-federal and Indian lands. While we do not have anything in
writing, the word from congressional offices that have helped us on this is
that DEA will incorporate all comments received through the end of June into
the hearing record and, therefore, address them in the final EIS. Offices that
have been involved heavily are Rep. David Skaggs (D-CO), who sits on DEA
Appropriations subcommittee, and Rep. Peter DeFazio (D-OR) who has a
longstanding concern with pesticide use and is a fan of NCAP. Thanks NCAP.
Rep. Henry Waxmans (D-CA) office worked with us and is looking into things and
we are talking with Senator Patrick Leahys office. Folks in California
(Joannie Clayburgh with Californians for Pesticide Reform) have gotten Senator
Barbara Boxers office involved. And, Nancy McFadden in Tennesee has been
kicking up a lot of dust in her neck of the woods. Terry Shistar has been
feeding all this to the Sierra Club.
Now, we need to get comments in on the EIS, and push for the use of
alternatives to herbicides in the DEAs program. The EIS is available on line
at http://www.usdoj/dea/programs/cannibis/pubmeet/fednoti.htm. (Please note
that cannibis is the spelling that they use for cannabis address. Must be some
sort of secret code). If you contact USDA, Jack Edmundson (301-734-8274) or
Vicky Wickheiser (301-734-4844) and they will send you a copy of the DSEIS.
Thanks for your work on this. Please let us know what you are able to do on
this. More later.
Best Regards,
Jay Feldman
NCAMP
-
May 29, 1998
Jack Edmundson
Environmental Protection Officer
USDA/APHIS
Unit 149
4700 River Road
Riverdale, MD 20737-1228
Re: Draft Supplement to the Environmental Impact Statements for Cannabis Eradication
Dear Mr. Edmundson:
The Drug Enforcement Administrations (DEA) proposed massive herbicide spray
program across the United States for eradication of cannabis raises serious
questions regarding widespread public and environmental exposure that would
take place and therefore requires greater public involvement than has so far
been received by DEA during the 45-day comment period. We respectfully request
that the DEA extend the public comment period by 45 days.
It is not our intent to stop state and federal manual clearance efforts of
cultivated cannabis. However, in light of new legislation and environmental
concerns associated with pesticide, including herbicide, use, we believe that
the Draft Supplement to the Environmental Impact Statements for Cannabis
Eradication in the Contiguous United States and Hawaii (DSEIS) requires more
public input than has received during the short comment period.
The 45-day comment should be extended to 90 days and public outreach improved
The established 45-day comment period is too short, especially since the
program, as proposed, affects every state, federal, non-federal and Indian
lands. It is unusual, given the controversy associated with this approach to
eradication in the past, that the public comment period would be less than 90
days. Although staff at USDA/APHIS and DEA have been helpful in answering
questions, the DSEIS notification and distribution procedure utilized by the
government has had the effect of generating limited public involvement to
date. According to the DEA, Notice of Public Meetings, the 45-day comment
period began with the U.S. Environmental Protection Agencys formal Notice of
Availability. Copies of the DSEIS were sent to all respondents to a Federal
Register Notice of Intent that the DEA says was published on August 13, 1996,
those who returned a mailing list query from USDA and those who called and
requested the document. As a result of this process, it appears that the
National Coalition Against the Misuse of Pesticides (NCAMP) as well as other
groups were dropped from the USDA mailing list to the receive the DSEIS. This
is despite NCAMPs active involvement in this issue going back to 1983,
including as a plaintiff in litigation on this matter with the Sierra Club and
Friends of the Earth (Sierra Club, National Coalition Against the Misuse of
Pesticides, Friends of the Earth v. DEA) when the DEA was using paraquat as
the herbicide of choice in its eradication efforts. NCAMP receives many DEIS
documents in its office without going through this convoluted process.
DEA and USDA should be working with groups to conduct outreach in seeking
public comment on a program of this magnitude and nature. The government, as
far as we can tell, conducted no real outreach efforts, but simply announced
in the Federal Register five public meetings to receive public comments.
>
The herbicides being proposed for use are toxic materials with adverse
effects that have not been fully analyzed in compliance with federal pesticide
law. The risk assessment methodology which the DEIS uses (Risk Assessment in
the Federal Government, Managing the Process, NAS,
1983) does not fully conform with the statutory requirements to look at the
total load of dietary and non-dietary exposure associated with the use of
the chemicals proposed.
Since the passage of the Food Quality Protection Act (FQPA) in 1996,
Congress incorporated in pesticide law a requirement that EPA evaluate
dietary and non-dietary exposures to pesticides together. Congress adopted
this recommendation at the suggestion of the National Research Council (NRC)
of the National Academy of Sciences (NAS) in its report Pesticides in the
Diets of Infants and Children. Because of the large potential pesticide
exposure associated with the DEA proposal, the additional exposure of these
chemicals on top of exposure that occurs through conventional crop and
non-crop uses must be calculated.
>
The other consideration that is not fully addressed under the proposal is the
impact of the proposed spray program on children. Here, too, FQPA
requires that the impact of the pesticides proposed for use be evaluated for
their impact on children. The point here is that the addition of the
proposed herbicide uses changes childrens overall exposure to these
chemicals and therefore the consequent risk to children must be calculated.
If reliable data is not available, additional safety factors must be adopted.
>
DEAs Chemicals of Choice Are Hazardous
>
All the chemicals that DEA has proposed using, trichlopyr, 2,4-D and
glyphosate, are hazardous to human health and the environment. Given the
conditions in which these herbicides can be used, there are serious concerns
that the DSEIS has disregarded key label information on the products proposed.
>
Trichlopyr. The label on Garlon 3A (trichlopyr) states:
Do not apply on ditches used to transport irrigation water. Do not apply
where runoff or irrigation water may flow onto agricultural land as injury
to crops may result. Do not graze lactating dairy animals or harvest hay
from treated areas for one year following treatment. Do not graze areas
treated with more than 2 quarts GARLON 3A per acre for one year following
treatment. Withdraw livestock from forage treated with 2 quarts GARLON 3A
herbicide per acre or less at least 3 days before slaughter during the year of treatment.
>
Garlon 4 is extremely toxic to fish. Triclopyr resembles 2,4,5-T
structurally, and like the phenoxy herbicide, mimics plant growth hormones
called auxins, interfering with the normal plant growth response. A large
issue of concern regarding 2,4-D and possibly triclopyr is the endocrine
disrupting effects of the chemical. Exposure to estrogen mimics, like
2,4-D, for example, can disrupt the delicate balance that regulate growth,
development, sexual traits, and many other functions.
>
Glyphosate. The primary metabolite of glyphosate on plants is
aminomethylphosphonic acid (AMPA), which is further converted to
formaldehyde. Glyphosate exposure in humans has caused respiratory effects,
and skin and eye irritation. There has been a high degree of concern
associated with the surfactant often mixed with glyphosate. EPA
acknowledges that the glyphosate has the potential to contaminate
surface waters and result in oxygen loss from decomposition of dead plants,
leading to fish kills.
>
2,4-D. As cited above, the grave concern about endocrine disrupting
effects of 2,4-D raises questions as to whether this toxic material should
be a part of any weed control program. 2,4-D is associated with a long list
of chronic adverse health effects from neurological effects to liver and
kidney function changes to reproductive effects to cancer. Epidemiological
studies of farmers have tied the chemical to elevated rates of non-Hodgkins
lymphoma. Under certain conditions the chemical may persist in the soil for
several months.
DEAs Resources Should not Be Used To Control Ditchweed
It is inappropriate for DEA to engage in a ditchweed eradication effort,
especially with a chemical intensive approach. The focus of the agency
should be cultivated cannabis crops. To become a more generalized weed
control agency would be to go beyond the scope of the agency. There are
alternative weed control measures on rangeland and pastures that should be
employed.
>
Alternatives Are Too Easily Dismissed
The publics annual exposure to pesticides is at 4.5 billion pounds.
Overall, it is too high. Specifically, the vast majority of use is
unnecessary, given the availability of alternative methods that are not
reliant on toxic chemicals. While this situation is going on, the
population of the United States lives with a rate of one in four people
getting cancer annually. One in 600 children get cancer before the age ten.
One in eight women get breast cancer. One in five men get prostate cancer.
Childhood asthma is increasing. We know that pesticide, including herbicide,
use contributes to these diseases. As a result, pesticides with the health
and environmental effects cited above can contribute to the already
unacceptable disease rates. Therefore, this makes it critical that manual
clearance be adopted as the standard practice.
>
Given our concerns about the chemicals proposed in the DSEIS and the
availability of alternative approaches, it is critical that the public has
an opportunity to more fully consider the issues associated with the DEA
cannabis eradication proposal. Spraying these chemicals on plots of cannabis
in uncontrolled conditions on public or private lands raises serious
questions of public health and environmental safety that must be more fully
considered. On public lands that have been set aside for natural uses and are
established for wildlife protection and recreational use, the
chemical-intensive approach undermines this purpose.
Thank you for your attention to our request for an extension. We look
forward to your response.
Sincerely,
Jay Feldman
Executive Director
NCAMP
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