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Judge Jenkins and Commissioners, We the undersigned wish to express our concerns regarding the over reliance on adulticide pesticides to curtail the West Nile virus when there are safer, more effective approaches, particularly the use of Bacillus thuringiensis israelensis (Bti) larvicide, derived from a naturally occurring bacteria that can be applied aerially as well as by truck spraying. As citizens, community stakeholders, business owners, environmental leaders and local health experts, we call on our officials to continue to work with us in prioritizing larviciding, limiting adulticiding, investigating less toxic alternative adulticides and implementing the safest, most effective strategies that will protect public and environmental health rather than put them more at risk. We appreciate the city and county’s commitment to consensus building on this issue and the willingness to collaborate with concerned citizens, experts and community stakeholders in curtailing this serious public threat. Prioritizing Larviciding Other communities have moved toward prioritizing the use of larvicides over adulticides because of their lower risk to the public health and to the environment as well as a greater effectiveness at interrupting the mosquito life cycle and preventing disease transmission. In particular, Bti larvicide targets the larvae in the immature stage of the mosquito life cycle, which entomologists agree is the best stage to target, thus preventing the adult mosquitoes from ever forming. 1 Larvicide can also be sprayed by the same trucks that are used to spray adulticides, requiring only a change in spray nozzles. Inefficacy of Adulticiding Adulticides have no effect on immature mosquitoes and also rarely reach adult mosquitoes. According to Cornell University entomologist David Pimentel, a leading national expert on this subject, less than .0001 percent of aerial and truck sprayed adulticides ever hit their intended target. Dr. Pimentel recently participated in an expert panel that was facilitated by Concerned Citizens for Safer Control, hosted by County Judge Clay Jenkins, and attended by representatives from the City of Dallas, Dallas
Although it has been suggested that larviciding has to be carefully timed to be effective, this is only true of flood water mosquitoes, and not of the West-Nile carrying Culex quinquefasciatus mosquito, which will always have emerging larval stages anytime there are emerging adult stages, thus making larvicide a viable intervention whenever there is increased mosquito proliferation.
County, the State Health Department and the Centers for Disease Control. According to Dr. Pimentel, a 90% kill rate from spraying must be achieved for effective mosquito control. This kill rate is an unlikely outcome when trying to penetrate dense tree coverage and hit a moving target that has the capacity to hide under foliage and other places inaccessible to the spray. In fact, according to the research literature, documented outcomes from reviewed spraying efforts have demonstrated that such a kill rate is rarely achieved. Increases in Mosquitoes following Aerial Spraying The CDC report on last summer's spraying in Dallas found that instead of a high kill rate, the aerial spraying actually resulted in increases in adult mosquitoes in all zones that were aerially treated. This is not surprising, since adulticides have no impact on the immature mosquitoes waiting to hatch into the next round of adults. One of the only long term studies of aerial spraying of adulticides in New York's Cicero Swamp found that 11 years of spraying there led to a 15-fold overall increase in mosquitoes. Health Risks of Chemical Adulticides, Low Risks of Bti Larvicide Unlike adulticides, Bti larvicide is not only more effective at breaking the mosquito life cycle, but it also has shown no signs of insect resistance, poses negligible human health risks, does not harm beneficial insects and is so low impact it can be placed in its dunk form in a dog water bowl. In contrast to the low risk of non-chemical larvicide, a growing body of evidence continues to demonstrate the neurotoxic effects of adulticide pesticides—particularly to children. Dr. David Bellinger of the Harvard School of Public Health and Boston Children's Hospital, who also participated with Dr. Pimentel in this local expert panel, noted in his presentation that there are no studies he knows of that have specifically looked at the long-term health effects of municipal adulticide spraying of mosquitoes. The studies we do have on adulticide pesticides, according to Dr. Bellinger, are population studies on everyday use that have shown links between very low dose pesticide exposure and increase in risk for childhood cancer, ADHD, autism, lower IQ and impaired development. Why would we take a possible health risk with our next generation when there are safer, more effective alternatives such as Bti larvicide that also can be applied by truck and plane? Dallas could be leading the way with innovative approaches, like the State of Massachusetts, which has instituted a state-wide initiative that focuses on limiting adulticides and increasing preventative measures, including the aerial application of larvicide. Other innovative approaches include the use of safer, alternative adulticides like EPA-approved essential oil products that can be sprayed by truck as well as boric acid bait stations that can be placed in storm sewers.
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Long-term Concerns: Insect Resistance, Pesticide Persistence, & Ecological Effects We are calling on you, as our representatives, to protect our public health with the best and safest mosquito abatement strategies. We ask you to consider the long term impact of neurotoxic adulticides on public health (particularly children's health); the growing problem of insect resistance and its effect on our ability to fight West Nile virus in the future; and the overall impact on the ecosystem as a whole—including pesticide runoff into our waterways, pesticide build-up in stream sediments, and the alarming decimation of the bee population that pollinates one third of our food supply. These are serious long-term effects that should be thoroughly weighed and acknowledged. In closing, we ask you to support a fully-funded, comprehensive, integrated mosquito abatement program that emphasizes source reduction, public education and the expanded application of Bti larvicide, not neurotoxic adulticides. Sincerely,
Janice Provost, President, Greater Dallas Restaurant Association; Executive Chef/Owner PARIGI-Dallas Restaurant; CoFounder, Cafe Momentum Graham Dodds, Executive Chef, Central 214 at the Palomar Hotel Matt McCallister, Executive Chef, FT33 Iris McCallister, Chefs for Farmers Chad Houser, Executive Director and Chef, Café Momentum Patrick Stark, Executive Chef, Sundown at Granada; Head of Mohawk Malitia against GMO’s Texas Campaign for the Environment Dallas Sierra Club Downwinders at Risk Mark Wootton, Chef and Manager, Garden Cafe Cassie Green and Gary Stephens, Owners, Green Grocer, LLC Howard Garrett, Chairman, Texas Organic Research Center Andrea Bithell, Oak Cliff Organics Texas Discovery Gardens @ Fair Park Randy Johnson, President, Native Plant Society of Texas, Dallas Chapter Dale Clark, Owner, Butterflies Unlimited Butterfly Farm Trish Percy, Feed Texas First Trey Denton, Co-owner, Blue Lotus Gardens & Water Features Angie Flesch, Aqua Angles Stephen Bailey, Owner, Urban Acres Jason Winningham, Green Tip Guy Ernest Belmore, Owner, BuzzBrews, Inc. Liz Goulding, Leader, Slow Food Dallas, Alysia M. Williams, Ron’s Organics, Inc. Marie Tedei, Eden’s Garden CSA Farm Texas Organic Farmers and Gardeners Association Susie Marshall, Grow North Texas, Gleaning Network Heather Rinaldi, Texas Worm Ranch Blake Shook, Owner, Desert Creek Honey Texas Beekeepers Association Texas Honeybee Guild Trinity Valley Beekeepers -- more –
Dallas County Lepidopterist Society Jina Ball, Store Manager, Creative Water Gardens Patty Bates-Ballard, Owner, WordSmooth Charlotte Risinger, Ph.D., Education Consultant Larry S. Boyd, Ph.D., Entomologist Gene Helmick-Richardson, Ph.D., Entomologist Kelly Nash, P.G., Environmental Consultant Mel White, GB&M Research, Ph.D Candidate, Informational Sciences, UNT Lawrence A. Plumlee, M.D. Margaret Christensen, MD, FACOG, Christensen Center; Assoc. Faculty, Institute for Functional Medicine William J. Rea, M.D., Environmental Health Center – Dallas Amy Martin, Publisher, Moonlady News; President Emeritus, Earth Rhythms Marla McDonald, President and CEO, Bug-Bouncer Concerned Citizens for Safer Mosquito Control James Jeffers and Steve Smith, Owners, Eat the Yard
CC: Zachary S. Thompson, Director, Dallas County Health Department Mayor Mike Rawlings and Dallas City Council Members Joey Zapata, Assistant City Manager, City of Dallas Jimmy Martin, Director of Code Compliance, City of Dallas
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