APPENDIX II-V: Comprehensive Mosquito-Borne Disease
Surveillance and Control Plan
Douglas G. Aspros, D.V.M.
President
8thFloor
Re: Comprehensive
Mosquito-Borne Disease Surveillance and Control Plan
Dear Dr. Aspros:
Riverkeeper, as a signatory to the 1997 New York City
Watershed Memorandum
of Agreement, routinely comments
and participates in
Review Act (SEQRA) process for development proposal~ and
policy decisions that may
impact the
Riverkeeper offers the following
comments on
Mosquito-Borne Disease Surveil1ance and Control Plan Draft
Generic Environmental
Impact Statement (DGEIS).
Project Purpose and Need
While Riverkeeper believes that
the education and surveillance components of the
Comprehensive Plan are essential to protecting the public's
health and welfare, we are in
no way convinced that the threat
posed by the
mosquito control via larvicides and adulticides poses
to the health and well-being of both
the citizens and the environment of
1999 serosurvey estimated the
incidence of
to be 2.6%.(1) This
means that out of the City's population of approximately 8 million,
208,000 were infected with the
reported nationwide and only 7
deaths of "e1derly citizens" resulted. Therefore the risk
of falling ill with
0.000035%, which is less than I in a minion of the people
infected.(2) In
addition, death
was limited to the sensitive
elderly members of the population.
Despite
only 35 cases of
million (3), Westchester County predicts 21, or 60% of the
number of reported human cases in the entire United States, hospitalized cases
a year in the No Action Scenario (4). This would require
Furthermore,
the DGEIS compares the public health impacts of the projected disease outbreaks
with the health impacts of insecticide application under the Comprehensive 'Plan
using tile unrealistic assumption of zero incidence or disease under the
Comprehensive Plan. In fact, there is no
positive correlation between spraying of
adulticides
and the incidence of
Department of Health applied adulticides
in
the
These
numbers demonstrate that the risk
County proposes to use present a host of known human and
environmental health threats, as well as an undocumented number of additional,
as of yet unknown, threats. "The primary
purpose of the- proposed Westchester County Comprehensive Mosquito-Borne Disease
Surveillance and Control Plan is to protect the public from outbreaks of
mosquito-borne diseases
[principally
health.” (8) However, the County's own risk assessment of
the proposed pesticides clearly demonstrates that the application of said chemicals
poses a greater threat to public health than the mosquito-borne
EPA's
acceptable target risk range for carcinogenic pesticides is one in a million (9),
which is greater than the risk of death from the
Adulticiding.
The DGEIS
is deficient because it fails to set forth any meaningful parameters for
what types of events would trigger
the use of adulticides. The DGEIS proposes that the
adulticiding
component of the plan would be triggered in the event of an "imminent
threat to public health"(13),
but does not set forth any guidance criteria as to what type of
events would constitute an imminent
threat to public health. Would an imminent threat
be a single confirmed case of
United States, or ten non-fatal
cases in
and risks of adulticiding
in
accurate measure of what type of
health threat will trigger such adulticiding..
Assuming the adulticiding
component of the plan is triggered, the DGEIS sets
forth neither the type and amount
of adulticide that would be used, nor the method of
application.. Pesticide impacts are
type-specific and may vary with the application
method. In order to make informed comments and
decisions, the County must make the
public fully aware of its proposed
actions. The DGEIS should provide a ranking system
that sets forth the County's
preferred adulticides and application methods for
particular
areas of the County.
Migratory
birds, especially American crows (Corvus brachyrhynchos), are known
vectors of
acquire it from birds.14 The United
States Geological Survey (USGS) is currently
working with the United States
Department of Agriculture (USDA) to collect blood
samples from crows and other bird
species for virus detection along the Atlantic coast.
The research focuses on the; collection of information and
samples to help determine the
Extent of wildlife species involved, the distribution of the
virus in bird populations, and
whether the range of the virus is
expanding beyond the currently reported regions.(15)
Rather than propose widespread blanket application of
pesticides,
shou1d avail itself of information
gathered by USGS and USDA in the avian surveillance
program to identify focus areas in
protocol to limit or prevent human contact with the virus.
Larvicide
and Adulticide Composition
The DGEIS
fails to adequately discuss the health hazards associated with both the
active and inert ingredients of the
proposed larvicides and adu1ticides. The Material
Safety Data Sheets (MSDS) available for these products cite
health hazards of active
ingredients:
Malathion:
Acute and chronic health hazards include: excessive
sweating, headache, weakness,
giddiness, nausea, vomiting stomach
pains, blurred vision, blurred
speech, diarrhea, and cholinesterase
inhibition.
Naled: Acute and chronic
health hazards include irreversible eye
damage; b1indness; redness, swelling
and pain of the skin; irreversible
tissue damage; toxicity to internal
organs if absorbed through skin;
respiratory depression; cardiac
arrest; nausea; vomiting; and diarrhea.
Na1ed is probably carcinogenic to humans based on studies in
animals.
and symptoms of overexposure
inc1ude: excessive sweating, nasal
discharge, diarrhea, vomiting,
convulsions, aspiration into lungs,
unconsciousness. and death.
Sumithrin:
High concentrations may cause headaches, dizziness, be
anesthetic. and have other central nervous system effects.
Permethrin:
Doses of this product administered to 1ab animals have
produced central nervous system
effects with symptoms that include
hypersensitivity to touch and
sound, tremors, .and convulsions, rattling
and irregular breathing, and ataxia.
Temephos: Acute health hazards include eye irritation,
respiratory
irritation, chemical pneumonitis, and chronic health hazards are
unknown.
Piperonyl
Butoxide: May be fatal if inhaled, swallowed, or
absorbed
through the skin. Most disturbingly, the MSDS states that the
chemical,
physical, and toxicological
properties have not been thoroughly
investigated.
These human
health risks alone, without any consideration of the impacts these
pesticides have on the natural
environment, clearly outweigh the risk that
Virus poses to the popu1ation of
Inert Ingredients
The DGEIS also fai1s to adequately assess the health and
environmental impacts
of the inert ingredients contained
in the pesticides because their composition is
unknown (16) Inert ingredients may compose up to 90% or
more of a pesticide product.
This means that the County is willing to spray a product,
the composition of which over
90% is unknown, over our yards, parks, houses, playgrounds,
swimming pools, and
schools. School children, infants,
asthmatics, the elderly, and pregnant women will be
exposed. eventually
these pesticides will contaminate our waterways via stormwater
runoff. This high level of unknown risk is simply
unacceptable given the so-called risks
of
Many of these “inert" ingredients are petroleum
distillates and share some of the
same chemical constituents as
gasoline. The public would never
tolerate the spraying of
gasoline over our communities,
allowing that form of petroleum to run off into our water
supplies. Yet when other petroleum
distillates are mixed with highly hazardous active
ingredients and dispersed over our
communities, the County maintains that it is an action
to protect public health. Petroleum products in our surface water supply
can result in a
host of environmental problems
including fish kills and contamination of groundwater
and drinking water supplies.
The simple
fact remains that known health risks associated with the use of
larvicides
and adulticidcs outweigh the health risks posed by
combined risk of the known and
unknown hazards of pesticides dramatically overwhelms
the minute risk to the general
population associated with
Aquatic Life
The adulticides the county proposes to use are widely toxic to
aquatic life.
Figure 3.D-25 demonstrates that the proposed adulticides are highly toxic to a wide
variety of aquatic life in a
variety of aquatic habitats. The DGEIS lacks sufficient
information to ensure that aquatic
environments will not be adversely affected by
adulticide
use. The DGEIS does not set forth a
concrete p1an or a list of specific
precautions that will be
implemented to prevent, or at the very least mitigate to the
maximum extent practicable. the introduction of adulticides into aquatic environments.
Although
pesticide labels may prohibit use on or within a certain distance from a
water body, such prohibitions are simply
inadequate to protect the sensitive waterways of
located in
terminal reservoir for the entire
West-or-Hudson Catskill and
the New Croton and Hil1view
Reservoirs, which are the terminal reservoirs for the entire
East-of-Hudson Croton watershed, are located in
quality. Additional impacts to watershed macroinvertebrate communities by the
widespread application of pesticides
will only result in the further degradation of water
quality. These Croton Watershed reservoirs are fed by
streams and tributaries that may
not be visible to sprayers at
night. How will these waterways be protected, or will they
be protected at all? These are issues that must be addressed and go unanswered in the DGEIS.
Furthermore,
the County presumes that the use of the proposed larvicides
will not
impact aquatic life because
discharged concentrations in catch basins "would not be
greater than what would result from
a single application of the regular formulation, which
has been found to have minimal
effects to [sic] non-target organisms [and] impacts to
non-target organisms would be further
reduced by dilution….”(17) The cumulative
concentration of larvicides applied to a subwatershed
and transported in runoff will
collect in the catch basins and
will be discharged in a concentrated form to receiving
waters. The argument that dilution
is the solution to pollution has long since been
rejected.
Additionally,
parts of the DGEIS represent an alarming compilation of faulty and
unfounded assumptions. The County
assumes the sequestration of freshwater in lenses in
saltwater; (18) the universal
dilution of contaminated discharges to estuaries;(19) the
burrowing of benthic organisms to
escape exposure;(20) and the assumption that the
bonding of insecticides to
suspended sediment and settling results in no pollution in the
water column.(21) These broad generalizations are not quantified anywhere in the DGEIS and therefore fail to support the County's conclusion that "adverse impacts on natural resources are not expected from the application of larvicides.(22)
Aquatic Receptors in Wetlands
Exposed to Runoff
The DGEIS suggests that approximately 0.2% of applied permethrin is contained in
runoff during any given rain event.(23)
If this is correct, then the annual rate
of 1 %
assumes only 5 rain events per
season of app1ication.(24) This assumption
appears to be
arbitrary and conservative and the
County fails to cite any authoritative source to support
it.
The DGEIS
reports that stormwater discharge elevates levels of malathion in
streams(25) and that benthic communities
exposed to malathion in
In
conclusion, the DGEIS is insufficient and uses faulty assumptions to
exaggerate the risk of
insignificant risk posed by
health and ecological risks associated
with the widespread dissemination of toxic
pestcides
into the environment. Thank you for the opportunity to comment on this
matter.
Sincerely.
Danielle Abate, Project Analyst
Jeffrey Odefey, Project Attorney
1. See Comprehensive
Mosquito-Borne Disease Surveillance and Control Plan Draft Generic Environmental
Impact Statement, November 2001 (hereinafter DGEIS) at S-8-
2. See id at
S-3.
3. See id. at S.9.
4. See id. at S-26.
5. See id. at 5-26.
6. See
http://www.ny.us/html/wnv/wnv01sray.html 2001.
7. See
http://www.ci.nyc.ny.us/html/doh/html/wnv/wnvr1.html 2001.
8. DGElS. at S-23.
9. See id. at S-37.
10. See id. at S-41.
11. See id. at S-43.
12.
13. DGEIS at S-10.
14. United Sates
Geological Survey Fact Sheet. http://www.usgs.gov/wnvfactsheet.html
. 2001.
15.
16. See DGEIS at S-66.
17. ld. at 53.
18.
19.
20.
21. 1d. at 65.
22.
23. See DGElS at 63
24. See
25. See id. at 64.
26. See id.
27. See id.
This appendix is copied from:
http://www.westchestergov.com/hdbooklets/StingEIS/FGEISfiles/riverkeeper.pdf