Pesticides and the Southwest Brooklyn Garbage Transfer Station Testimony of Mitchel Cohen, to the Department of Sanitation
In its Final Environmental Impact Statement (FEIS), the City writes:
"Procedures to control vermin, such as rats and insects, would be or, in the case of existing facilities, are incorporated into the operating permit of each Proposed Plan Facility. Licensed exterminators would service each Converted MTS monthly. ... The exterminators would evaluate potential pest and vector problems and apply bait and/or spray throughout the refuse handling area, the tipping floor, the lunch and locker rooms and administrative areas. Standing water in barges not being used would be treated with larvicide and pesticide spray when necessary." (Chapter 33.5)
The proposed transfer station will be situated right on Gravesend Bay, which is the most environmentally sensitive water body in this area and perhaps in the entire State. Even tiny amounts of pesticides kill fish, horseshoe crabs (which, in addition to being the oldest creatures on the planet, are indispensable for scientific research), butterflies, bees, birds, dragonflies, etc., as well as mosquitoes and unwanted critters. The labels on Malathion, Pyrethroids, and piperonyl butoxide (a so-called synergist and a carcinogen) all warn against spraying over or near bodies of water.
Pesticides are especially dangerous for brain and nerve development in young children, and for elderly people. With the expectation that almost 5,000 trucks per month will be utilizing this facility, picking up pesticides on their wheels and rumbling past various local facilities for developmentally disabled children on their route, one would think that a proper Environmental Impact Study would address those concerns. Yet there is not a single line in the FEIS that does so.
Just last week, the City agreed to settle a 7-year-old lawsuit against its massive and indiscriminate spraying of toxic pesticides brought under the Clean Water Act by the No Spray Coalition, which I coordinate. In addition to winning $80,000 for a number of local grassroots environmental and wildlife protection groups, as part of the settlement agreement the City admitted (and I quote): "Pesticides may remain in the environment beyond their intended purpose, ... cause adverse health effects, ... kill mosquitoes' natural predators, ... increase mosquito resistance to the sprays, ... and are not presently approved for direct application to waterways."
In fact, I submit the following seven groups of published studies that speak directly to this grave issue, which is one of extraordinary environmental INjustice.
i. Centers for Disease Control study that found that all residents of the United States, including residents of New York City and State, now carry dangerously high levels of pesticides and their residues in our bodies, which may have onerous effects on our health. (Third National Report on Human Exposure to Environmental Chemicals, Centers for Disease Control, 2005);
ii. U.S. Geological Study, which shows that a large percentage of waterways and streams throughout the United States, including those in New York City and State, has been found to contain environmentally destructive pesticides that may severely impact on animal and aquatic life. (U.S. Geological Survey: The Quality of Our Nation's Waters, Pesticides in the Nation's Streams and Ground Water, 1992-2001, http://pubs.usgs.gov/circ/2005/1291/);
iii. Studies confirming that pesticides are both a trigger for asthma attacks and a root cause of asthma (Salam, et al: Early-life environmental risk factors for asthma findings from the children's health study. Environmental Health Perspectives 112(6):760-765.), and that asthma is epidemic throughout New York City;
iv. Cicero Swamp Study, showing that pesticides killed off the natural predators of mosquitoes and that mosquitoes came back much stronger after the spraying, because all of their natural predators (which have a longer reproductive cycle) were dead. These studies were done in New York state for mosquitoes carrying Eastern Equine Encephalitis, and found a 15-fold increase in mosquitoes after repeated spraying, and that virtually all of the new generations of mosquitoes were pesticide-resistant. (Journal of the Am Mosquito Control Assoc, Dec; 13(4):315-25, 1997 Howard JJ, Oliver New York State Department of Health, SUNY-College ESF, Syracuse 13210, USA);
v. Studies that show that pesticides have cumulative, multigenerational, degenerative impacts on human health, especially on the development of children which may not be evident immediately and may only appear years or even decades later (The Multigenerational, Cumulative and Destructive Impacts of Pesticides on Human Health, Especially on the Physical, Emotional and Mental Development of Children and Future Generations. A Submission to The House of Commons Standing Committee on Environment and Sustainable Development by Physicians and Scientists for a Healthy World, February 2000; Guillette, Elizabeth, et al: Anthropological Approach to the Evaluation of Pre-school Children Exposed to Pesticides in Mexico. Environmental Health Perspective, Vol. 106, No.6, June 1998; Kaplan, Jonathan et al. Failing Health. Pesticides Use in California Schools. Report by Californians for Pesticide Reform, 2002, American Academy of Pediatrics, Committee on Environmental Health; Ambient Air Pollution: Respiratory Hazards to Children, Pediatrics 91, 1993);
vi. Studies that show that pesticides make it easier for mosquitoes and other organisms to get and transmit West Nile Virus due to damage to their stomach lining. (Haas, George. West Nile virus, spraying pesticides the wrong response. American Bird Conservancy, October 23, 2000); and,
vii. Studies that show that pyrethroid spraying is ineffective in reducing the number of the next generation of mosquitoes. (Efficacy of Resmethrin Aerosols Applied from the Road for Suppressing Culex Vectors of West Nile Virus, Michael R. Reddy, Department of Immunology and Infectious Diseases, Harvard School of Public Health, Boston, Massachusetts, et. al., Vector-Borne and Zoonotic Diseases, Volume 6, Number 2, June 2006)
The use of toxic pesticides to control the vermin that will be attracted to the proposed Southwest Garbage Transfer Station is a significant Environmental Justice issue for which no impact study has been analyzed, let alone any study of cumulative impacts. I was indeed surprised that none of this was discussed in the current proposal.
Mitchel Cohen, coordinator, No Spray Coalition www.nospray.org
Ring the bells that still can ring, Forget your perfect offering. There is a crack, a crack in everything, That's how the light gets in. ~ Leonard Cohen