Herrera Submits Comments on State's Plans to Eradicate Light Brown Apple Moth
City's response to Draft Environmental Impact Report calls analysis 'not good enough' to protect public health, the environment
SAN FRANCISCO (Sept. 28, 2009) -- City Attorney Dennis Herrera today filed comments on a draft report by the California Department of Food and Agriculture that endeavors to analyze potential environmental and public health effects of the state's Light Brown Apple Moth Eradication Program. The controversial program was modified last year in the face of mounting public health concerns over aerial spraying until an environmental impact study could more thoroughly assess the effects of -- and possible alternatives to -- plans to eradicate the invasive pest in more than a dozen counties in California.
The five-page letter from Herrera's office to the staff environmental scientist at CDFA details a range of concerns about the inadequacy of the draft report in satisfying the legal requirements of the California Environmental Quality Act, or CEQA, to facilitate fully informed decision-making, and to provide public disclosure of potential environmental effects of governmental decisions.
In releasing the letter late this afternoon, Herrera issued the following statement:
"While I was encouraged by the state's decision last year to halt aerial spraying for the light brown apple moth until it could complete a more thorough analysis, I'm concerned that this draft report is far from thorough. California law guarantees residents that they will have an opportunity to fully understand projects such as these, to evaluate their consequences on our environment and public health, and to consider alternatives wherever possible. So far, this draft report falls short on all counts. I'm particularly concerned by the inadequate disclosure of chemical formulas of pesticides to be used in the program, and by vague statements about state bureaucrats who will appropriately determine when and where aerial spraying is necessary. That's not good enough to protect the public health, and it's not good enough for CEQA."
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