Attorney Dennis Herrera provided comment earlier this week concerning an Environmental Impact Report about a moth eradication program affecting several California counties. (PublicCEO: No Simple Pest: Eradicating Moths Stirs Controversy in California Regions)
The program was stopped a year ago, until a full investigation on the environmental effects could be performed by the California Department of Food and Drug.
Herrera stated in a press release, “This is particularly troublesome in the case of aerial spraying with pheromones. The Draft Environmental Impact Report (DEIR) states simply that aerial application of pheromones may occur in ‘agricultural or undeveloped areas where ground applications of the pheromone are not feasible.’”
The DEIR stated that the spraying of sterile males into “remote” or “unpopulated” areas would disrupt the mating population and eradicate the Light Brown Apple Moth.
Herrera was not satisfied with the DEIR stating, “It does not explain what regions are considered forested, agricultural, remote or undeveloped, to allow for aerial application of pheromones. Nor does it explain what criteria will be used to make these determinations. Indeed, these statements are not only vague; they appear contradictory.”
The city is concerned that the DEIR fails to satisfy the goals of the California Environmental Quality Act (“CEQA”) to facilitate informed decision-making and to provide public disclosure of the potential environmental effects of governmental decisions.
The report fails to provide the public an opportunity to evaluate whether the “California Department of Food and Agriculture is considering the appropriate criteria when deciding whether to aerially spray, or whether the CDFA has adequately considered the public health impacts when making this decision.”
Herrera stated, “When preparing an Environmental Impact Report, “technical perfection is not required [but] adequacy, completeness and a good-faith effort at full disclosure.”
Herrera claimed the California Department of Food and Agriculture “failed on all counts and has deprived the public of a meaningful opportunity to evaluate the Program.”
Louis Dettorre can be reached at firstname.lastname@example.org