RCC Report Card 2008

Rachel Carson Council

An Association for the Integrity of the Environment

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Report Card for 2008

Speaking Out on Environmental Issues:

 

1. Rachel Carson Council (RCC) provided public comment on six important environmental issues during 2008:

  • In March, RCC sent a letter to the Maryland Senate Committee on Education, Health and Environmental Affairs, addressing Senate Bill 920: “Governor’s Task force on Gypsy Moth Control.” This bill supported aerial applications of Dimilin (diflubenzuron) and Bacillus thuringiensis (Bt) for Gypsy Moth control. RCC presented information about the adverse effects associated with exposure to these pesticides, including exposure to diflubenzuron’s transformation products: 4-chlorophenohydroxylamine and 4-chloroaniline. In addition to detailing these adverse effects, RCC strongly recommended that medical specialists with experience in pesticide toxicology participate in the decision-making process regarding use of these chemicals.

  • In May, RCC signed on to a letter sent to the U.S. Department of Agriculture’s National Agricultural Statistics Service. The letter spoke out against proposed budget cuts that would limit the collection and publication of agricultural chemical usage data. Such data are crucial to EPA’s ability to monitor pesticide usage.

  • In August, RCC joined with many other concerned citizens and environmental organizations and provided testimony to the EPA urging them to permanently ban the highly toxic pesticide carbofuran.

  • In September, RCC sent a ten-page response to the EPA’s, Office of Pesticide Programs regarding the agency’s request for public comments for the re-registration review of tetrachlorvinphos. One key RCC focus in this document prepared by Dr. Post and Dr. Michael Liddel was to correct the EPA’s statement (made in their Preliminary Problem Formulation for the Ecological Risk Assessment) that the EPA had received only one incident report linked to tetrachlorvinphos. In the EPA’s response to an earlier RCC request for incident reports on tetracholorvinphos, under the Freedom of Information Act (FOIA), RCC had received a response from the EPA which listed information on their receipt of approximately 2,000 incident reports on tetracholorvinphos between 1992 and 2002. We included that response, asking for its inclusion in the present re-registration material. RCC also expressed concern about the apparent lack of any risk assessment done for this chemical regarding its effect on pets (one of its important usages) and/or of the ecological effects of its pet-veterinary pesticide products.

  • Protecting the Endangered Species Act (ESA): In September, RCC sent comments to the U.S. Department of the Interior, speaking against changes to the ESA proposed by the Bush administration. These changes, if enacted, would seriously undermine the Act’s ability to protect 2,000 of the nation’s rarest plants and animals, thereby exposing them to the threat of extinction. They would: (1) Eliminate the fundamental requirement contained in the ESA, for independent review by the Fish and Wildlife Service (FWS) and/or the National Marine Fisheries Service (NMFS) of any project proposed by a Federal Agency, if under the conditions provided, such project may have an adverse impact on endangered animals or plants. (2) Impose shorter time frames for any review conducted by FWS and/or NMFS, and (3) Have failure to meet the new, shorter, time frames proposed for the consulting review, serve as grounds for automatically granting approval of the proposed project.

Although the Bush administration documents described these proposed changes as minor procedural changes, RCC viewed them to be a major revision of the ESA, since they would seriously weaken the standards and rigorousness under which the ESA provides protection for species that the Act was created to safeguard. In our opinion, all of the currently proposed revisions seem contrary to the original intent of the framers of the Endangered Species Act. For this reason alone we strongly urged that the proposed regulations be defeated. A separate comment from Dr. Stanley A. Temple was included in our submission. Dr. Temple is a Beers-Bascom Professor Emeritus in Conservation, Dept. of Forest & Wildlife Ecology, and Gaylord Nelson Institute for Environmental Studies, University of Wisconsin-Madison.

 
  • In November, RCC wrote to the EPA to alert them to a serious problem reported by British gardeners regarding the use of the herbicidal, active ingredient, aminopyralid. Compost from fields that had been treated with an aminopyralid product or composted manure from animals that ate vegetation previously treated with an aminopyralid product was found to kill broad leaf garden crops it was meant to fertilize. EPA responded that it would look into this matter.

2. RCC Publications 2008:

  • Golf at a Crossroads, is a 36-page, full-color brochure that explores in depth the hazards associated with chemical pesticide use on golf courses, as well as the means of establishing and maintaining a chemical free golf course. Well researched and thoroughly referenced, “Golf at a Crossroads” is a scientifically accurate publication, written for both technical and non-technical audiences, golfers, course management, and concerned citizens.

  • A Gardener Alert – Avoid Killer Compost focuses on the systemic herbicide, aminopyralid, which in Great Britain had been found to persist in compost and/or manure from animals that grazed on treated sites. The result was a “killer compost” that destroyed plants meant to benefit from its use. This article was addressed to American gardeners, because the active ingredient is registered for essentially the same usage here as in the UK. Our concerns also applied to the similarly formulated herbicide, clopyralid and other systemic herbicides. Aminopyralid was banned from the UK market because of these adverse effects.

  • Commentary on Rusted Roots focuses on an article, “Rusted Roots,” by James E. McWilliams, which claimed that organic farming methods increased the amount of heavy metals found in produce. RCC arrived at different conclusions based on a more careful analysis of data from the article originally referenced by McWilliams.

  • Snoopy only Lands on Toxic-Free Lawns has been redesigned into a full color, brochure format, visually much more appealing than the original version. We have had the text translated into Spanish, and are planning a publication of “Snoopy…” in that language.

Other Rachel Carson Council Accomplishments in 2008:

1. Web Site:

RCC began the process of redesigning and streamlining our website. The revised website will be available at www.rachelcarsoncouncil.org. A link to the present website now exists from that URL.

2. Pesticide Data Base:

RCC has established a searchable database of chemical pesticides. The start-up phase of this project involved 20 active ingredients not presently found in our Basic Guide to Pesticides (1992). Based on our significant progress thus far, we hope to expand the scope of this on-going project by enlarging the database to include the pesticides covered in the Basic Guide.

Rachel Carson Council Events in 2008:

1. RCC participated in the following Festivals in the past year:

  • Raptor Day at the Philadelphia Zoo (September 2008)

  • Mother Earth Harvest Fair in Pennsylvania (October 2008)

  • Green Festival in Washington, DC (November 2008)

2. RCC hosted numerous visitors at the Rachel Carson House:

  • The Rachel Carson Open House saw more than 200 guests.

  • Field trips were taken to the Rachel Carson House by various school groups including the staff of near-by Paint Branch High School and a group from Silver Spring Boys and Girls Club.

  • Over this year, we received visitors from as far away as Japan.

3. RCC also helped other organizations with their efforts to honor Rachel Carson:

  • Literature and posters were sent to the Environmental Writer’s Conference and Workshop in Maine.

  • Literature was also sent to the Rachel Carson Greenway Hike.

  • Rachel Carson Council chose to join with EPA in the Sense of Wonder Intergenerational Poetry, Essay and Photography Contest, which was conducted on line.

RCC’s Contacts with the Public during this past year:

1. Outreach:

Rachel Carson Council staff met with hundreds of people at numerous events throughout the year. The Rachel Carson House has welcomed local school children as well as international visitors. This year’s Rachel Carson Open House was attended by over 200 people. In addition, RCC sent two mailings during the year to over 1,200 households, and intermittent “current event alerts” to those on our e-mail communication list.

2. Responses to Inquiries:

Rachel Carson Council had well over a thousand contacts with the public from October, 2007 through September, 2008. These included phone calls, letters, and e-mail. In addition RCC had considerable contacts with the public via our website, which continues attracting a goodly number of visitors.

3. A sampling of the requests RCC answered during the past year:

  • Numerous students requested and received information about Rachel Carson for the National History Day competitions. One young girl, with whom we corresponded, placed second in her state competition and went on to represent her state in the national finals in Washington, D.C.

  • A captain in the U. S. Navy contacted us with concerns about the effect that spraying for mosquitoes could have on the Chesapeake Bay and its oysters. We were able to put him in contact with a graduate student who was involved in research on this very issue.

  • We sent background information to a lawyer in Tennessee, per her request, as she prepared for a case involving permethrin and pyriproxifen.

  • We sent by overnight mail information to a doctor in California who needed questions answered about pesticides used on lawns and golf courses. She also requested our publication, 36 Insecticides Used on or Around Dogs and Cats.

  • A young girl in South Dakota wrote asking for information on her hero, Rachel Carson. We were happy to send her a student packet and the Rachel Carson Centennial brochure.

  • From the Philippine Islands, we received a request from a graduate student for research articles on the effect that pesticides have on non-target species, in both aquatic and terrestrial ecosystems. We were able to copy and send her a number of current articles.