{"id":4942,"date":"2023-12-05T08:00:00","date_gmt":"2023-12-05T16:00:00","guid":{"rendered":"https:\/\/www.puravidaaquatic.com\/wordpress\/?p=4942"},"modified":"2023-12-27T09:22:43","modified_gmt":"2023-12-27T17:22:43","slug":"sloppy-almost-criminally-poor-approval-of-pesticide-use-by-our-national-parks","status":"publish","type":"post","link":"https:\/\/www.puravidaaquatic.com\/wordpress\/sloppy-almost-criminally-poor-approval-of-pesticide-use-by-our-national-parks\/","title":{"rendered":"Sloppy, almost criminally poor approval of pesticide use by our national parks."},"content":{"rendered":"


\nAfter 2 months of the National Park (Service???) refusing to give me any of their Integrated Pest Management data at all, I have acquired some through an alternate route.<\/span><\/p>\n

<\/span><\/span<\/span><\/code><\/p>\n

Summary of a PUPS data entry that is quoted further below:
\nThe Integrated Pest Management (IPM) division approved aerial spraying of 10,000 leased acres with as much as 10 tons of a product that is known to be toxic and negatively affect native bees, native butterflies and the native wetland communities at and near the site, including an endangered fish species.
\n<Br<\/p>\n

<\/span><\/p>\n

The material safety data sheet (MSDS) on the approved pesticides clearly states not to get it in waterways which certainly happened. This would affect food resources, if not have direct toxicity to the fry of the endangered fish in the area. The National Park Service is killing off the very base of the food chain for baby fish, baby dragonflies and many other beneficial aquatic organisms.<\/p>\n

<\/span><\/p>\n

I believe this is just the tip of the iceberg as to why so many of our endangered species are struggling. It is highly likely that developing young animals are much more affected by the toxins being sprayed then adults.<\/p>\n

The best to everyone here. I love you all, and your children and grandchildren too. I believe that poorly regulated pesticide use is the most hazardous thing to their future happiness and health. Beyond even climate change and that’s saying an awful lot.<\/span><\/p>\n


\nI think this is literally the third data entry I looked at under a small fragment of the PUPS database I acquired. It is on leased land just like the issue with the fire under the 10 freeway in LA<\/span><\/p>\n


\nI also wonder why the integrated Pest Management (IPM) department approved a request in February 2014 based on an IPM plan from 1998?
\n<\/span><\/p>\n

Start PUPS database excerpt.<\/span>
\n
\n______________________________
\nU.S. Fish and Wildlife Service
\nPesticide Use Proposal Date: 02\/28\/2014<\/span>
\nPage: 3
\nXenTari 2 lbs\/acre Aerial Helicopter
\nSize of Treatment Area: 10,000.00 acres<\/span>
\nREI (Restricted Entry Interval): None
\nApplicator Information: Contractor, Cooperator
\nApproved IPM Plan (Y\/N): Y
\nIPM Plan Year: 1998<\/span>
\nNon-Chemical Controls Considered (Y\/N): Y
\nIPM Strategy:
\nRefer to “Integrated Pest Management Plan for Leased Lands at Lower Klamath and Tule Lake National Wildlife
\nRefuges Oregon\/California (1998).
\nBest Management Practices:
\nApplication at wind speeds less than 10 mph (but not inversion conditions) – must follow label.
\nCalibrate application equipment.
\nField scouting\/monitoring before pesticide application.
\nPesticide application buffers around sensitive areas.
\nUse lowest effective application rate.
\nAdditional Best Management Practices:
\nBuffer Zone:
\nGround Application: 150′ from Tule Lake Sumps 1A,1B and the
\nEnglish Channel; 25′ from wetlands, drains and canals when surface
\nwater is present.
\nAerial Application: 300′ from Tule Lake Sumps 1A, 1B and the
\nEnglish Channel; 50′ from wetlands, drains and canals when
\nsurface water is present.<\/span>
\nOrganic Production:
\nDipel DF and XenTari DF qualify as Allowed status for use in
\norganic cropping systems in accordance with USDA National Organic
\nProgram regulations found in 7 CFR 205 and subsequent
\namendments. Use patterns in in organic production systems may be
\ndifferent than that listed on the products label. It is the sole
\nresponsibility of the producer or their contracted commercial
\npesticide applicator to use products in accordance with National
\nOrganic Standards.
\nDrift Management:
\nFollow general requirements for ground and aerial applications,
\nNext Page.
\nU.S. Fish and Wildlife Service
\nPesticide Use Proposal Date: 02\/28\/2014
\nPage: 4
\napplicable for all pesticides on lease lands, and follow all
\nlabel recommendations and requirements including those of any
\napplicable supplemental label.
\nTreatment Site Conditions:
\nTopography (Degree Slope): Flat
\nSoil Texture: Silty Loam, Silty Clay Loam
\nSoil pH: 6.6-8.4
\nSoil Organic Matter: 5-15
\nSurface Water Type(s): Drain, Canal
\nDistance to nearest: 26<\/span> – 50 ft
\nDepth to Groundwater: 2+ to 5 ft
\nDistance to nearest potable water: 1+ to 2 Miles
\nIf Spot Treatment, Estimated % Cover to be Treated:
\nIs the Treated Area Naturally Flooded or Irrigated (Y\/N): Y
\nIf Yes, How Many Acres are Affected: .00
\nIrrigation Method: Flood, Sprinkler
\nNon-Target Species At\/Near Treatment Area during or immediately after treatment (taxonomic groups):
\nAmphibians, Crustaceans, Fish, Fish-eating birds, Mammals, Native Lepidopterans, Native Pollinating Insects,<\/span>
\nPasserines, Reptiles, Shorebirds, Waterfowl
\nAre Impacts to Non-Target Species Expected? (Y\/N): N<\/span>
\nFederally Listed Species and Critical Habitat(s):
\nKey:
\nNE = No Effect
\nNLAA = Not Likely to Adversely Affect<\/span>
\nLAA = Likely to Adversely Affect
\nJAM = Jeopardy\/Adverse Modification
\nNJNAM = No Jeopardy\/No Adverse Modification
\nNote: ESA Documentation is required for NE, NLAA, LAA, JAM and NJNAM Effects Determinations. Please
\nensure you are in compliance with the current Endangered Species consultation procedures.
\nSpecies Common Name\/Critical Habitat Effects Optional: Provide ESA text here or attach documents
\nLost River sucker NLAA<\/span> Biological Opinion (81450-07-F-0056 KBNWR PUP
\nBO) Regarding the Effects on Listed Species from
\nImplementation of the Pesticide Use Program on
\nFederal Leased Lands, Tule Lake and Lower Klamath
\n______________________________
\n<\/span>
\n
\nEnd of database excerpt.
\n<\/span><\/p>\n


\nMy head exploded. Did the IPM department really give their blessings to spray 2 lbs per acre on 10,000 acres (10 tons of pesticide) in close proximity to wetlands? Whether or not this amount actually was sprayed, the IPM Department gave them permission to do so.
\n<\/span><\/p>\n


\n_Quote from Integrated Pest Management’s careful analysis and approval_
\n<\/span><\/p>\n


\nProduction:
\nDipel DF and XenTari DF qualify as Allowed status for use in
\norganic cropping systems in accordance with USDA National Organic
\n_end quote_
\n<\/span><\/p>\n


\nJust because something’s organic doesn’t mean it’s not toxic to our endangered species or their food sources. And for _any_ biologist to think or say that it does is just mind numbingly (I will not say incompetent.)
\n<\/span><\/p>\n


\nAlso in the data above, the IPMs own “Additional Best Management Practices: Buffer Zone:” requires 50 ft but the actual site analysis says that as little as 26 ft is present to drainage canals.
\n<\/span><\/p>\n


\n_Quote from Integrated Pest Management’s careful analysis and approval_
\n<\/span><\/p>\n


\nNon-Target Species At\/Near Treatment Area during or immediately after treatment (taxonomic groups):
\nAmphibians, Crustaceans, Fish, Fish-eating birds, Mammals, Native Lepidopterans, Native Pollinating Insects,
\nPasserines, Reptiles, Shorebirds, Waterfowl
\nAre Impacts to Non-Target Species Expected? (Y\/N): N
\n_End of quote_
\n<\/span><\/p>\n


\nI’m stunned. Just stunned. This was only about the third review I looked at, probably 2 minutes after I actually got IPM data. I imagine that since they are spraying a chemical that kills caterpillars they _assumed_ it would not hurt the wetlands. Many many people assume things like that. But in addition; don’t our monarchs and bees (especially our native bees) have enough trouble already?
\n<\/span><\/p>\n


\nI had my fears because of my experience in native California wetland ecology, but it actually took me another entire minute to verify them by Googling the pesticides approved to be used: Dipel DF and XenTari DF.
\n<\/span><\/p>\n


\nMSDS (material data safety sheet) for Dipel DF
\n_Quote_
\n6.2. Environmental precautions
\nEnvironmental precautions Do not allow escape into sewage system or watercourses. Do not wash residues
\ninto drains or other waterways.<\/span>
\n6.3. Methods and material for containment and cleaning up
\nContainment of a spill Do not allow escape into sewage system or watercourses.<\/span>
\nMethods for cleaning up Clean up spills immediately. Sweep up and place into sealable containers. Dig up
\nheavily contaminated soil and place into drums. Use a damp cloth to clean floors and
\nother objects, and also place in sealable container. Dispose of all waste and
\ncontaminated clothing in the same manner as waste chemicals (i.e. via an authorized
\ndisposal facility). Do not wash residues into drains or other waterways.<\/span>
\n_End MSDS quote_
\n<\/span><\/p>\n


\nMore from the MSDS Dipel DF.
\n_quote_
\nToxicity – aquatic invertebrates EC50, 21 days: 14 mg\/l, adult mortality\/immobility, Daphnia magna<\/span>
\nNOEC <5 mg\/l (FIFRA 154-20) EC50, 21 days: 13 mg\/l, adult mortality\/immobility, Daphnia magna EC50, 21 days: 7.8 mg\/l, reproduction, Daphnia magna<\/span>
\nNOEC = 2.5 mg\/l (OECD 211)
\n_End MSDS quote_
\n<\/span><\/p>\n


\nMSDS for XenTari (DF)
\n_Quote_
\n2.1 Classification of the Substance or Mixture
\nEye Irritant, Category 2A
\nHazardous to the Aquatic Environment, Acute<\/span> Category III (Daphnia)
\n_End MSDS quote_
\n<\/span><\/p>\n


\nDaphnia magna are just a typical test organism. Their use in toxicity studies represents a lot of tiny aquatic invertebrates that are a prime source of food for developing fish larvae. Daphnia magna are not native and it seems to me that it would be logical in California to be using _native_ biological test organisms. But that doesn’t eliminate the fact that the IPM’s approved pesticide treatment _kills the primary aquatic test organism._ And would certainly kill native daphnids present at the site too, possibly even quicker. Oh, and by the way Daphnia _are_ crustaceans. I am familiar with Daphnia but for the rest of my audience; Wikipedia: “Daphnia is a genus of small planktonic crustaceans”. We are killing off the very base of the food chain for: baby fish, baby dragonflies, baby frogs (tadpoles) and many other beneficial aquatic organisms.
\n<\/span><\/p>\n


\nSo, this incredibly careful integrated Pest Management review asked:
\n“Are Impacts to Non-Target Species Expected? (Y\/N): N”
\nAnd found that the effect to non-target species? What was it? Amphibians, Crustaceans, Fish, Fish-eating birds was…
\n“N”
\n<\/span><\/p>\n


\nAnd to the endangered fish (the Lost River sucker) was …. NLAA (Not Likely to Adversely Affect).
\nThat pretty much sums up the damage to our environment from 10 tons of pesticides… N and NLAA buried a mound of hidden data.
\n<\/span><\/p>\n


\nWhat do _you_ think a Lost River Sucker larva\/baby (less than the length of your little finger) eats? I believe this is the tip of the iceberg with so many of our endangered species. I believe it is highly likely that the developing young are much more affected by the toxins we are spraying then adults. 10 tons in just this one permit.
\n<\/span><\/p>\n


\nThe integrated Pest Management division of our national parks is doing sloppy, almost criminally poor approval of pesticide use in _our_ national parks.. It took me just a minute to Google MSDS information that raises serious questions regarding the appropriateness of this pesticide application. Our top environmental organizations have fallen flat on their face. It is inexcusable that they have not been paying attention for years, if not decades.
\n<\/span><\/p>\n


\nIn 3 months sierra club’s national front office has not contacted me back in response to my questions to them regarding oversight of pesticide use in our national parks. Some might wonder whether they are more interested in our endangered native animals … or selling a furry owl toy from China.
\n<\/span><\/p>\n


\nI am very, very grateful for some serious help from some members of local chapters. We should not throw out the baby with the bathwater. The majority of the Sierra Clubs leaders are awesome, and incredibly talented, knowledgeable, and dedicated. However; Sierra Club members need to seriously review the dedication, and decision making process of their national administrators. And we shouldn’t just blame the sierra club, the audubon society and world wildlife fund are also picking gravel out of their lips, noses, and eyebrows.
\n<\/span><\/p>\n


\nThe best to everyone here. I love you all and your children and grandchildren too. I believe that poorly regulated pesticide use is the most hazardous thing to their future happiness and health.
\nBob
\n<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

After 2 months of the National Park (Service???) refusing to give me any of their Integrated Pest Management data at all, I have acquired some through an alternate route. <\/span Summary of a PUPS data entry that is quoted further … Continue reading →<\/span><\/a><\/p>\n

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