APPENDIX II-V: Comprehensive Mosquito-Borne Disease Surveillance and Control Plan
Douglas G. Aspros, D.V.M.
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
Riverkeeper offers the following
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
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.
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
and the incidence of
Department of Health applied adulticides
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
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
acceptable target risk range for carcinogenic pesticides is one in a million (9),
which is greater than the risk of death from the
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
and risks of adulticiding
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
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
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
Malathion: Acute and chronic health hazards include: excessive
sweating, headache, weakness, giddiness, nausea, vomiting stomach
pains, blurred vision, blurred speech, diarrhea, and cholinesterase
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
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
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
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
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
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
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
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
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
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
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.
8. DGElS. at S-23.
9. See id. at S-37.
10. See id. at S-41.
11. See id. at S-43.
13. DGEIS at S-10.
14. United Sates Geological Survey Fact Sheet. http://www.usgs.gov/wnvfactsheet.html . 2001.
16. See DGEIS at S-66.
17. ld. at 53.
21. 1d. at 65.
23. See DGElS at 63
25. See id. at 64.
26. See id.
27. See id.
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