Chemical Sensitivity Disorders Association Comments on the Gypsy Moth Draft Environmental Impact Statement, Submitted 12-12-2008:

From: Chemical Sensitivity Disorders Association, 5717 Beech Avenue, Bethesda, MD 20817-2563

To: Bill Oldland, SEIS Team Leader, USDA Forest Service, 180 Canfield St., Morgantown, WV 26505, woldland@fs.fed.us

Dear Dr. Oldland,

The Chemical Sensitivity Disorders Association (CSDA), a Maryland non-profit, is commenting on the "Gypsy Moth Management in the United States: a cooperative approach Draft Environmental Impact Statement". We would appreciate your acknowledging receipt of our comments by return email.

I am attaching two pdf documents. The first consists of letters from CSDA members who have been impacted negatively by spraying for the gypsy moth. The second attachment is a referenced scientific review of pesticides used for gypsy moth control, written by Dennis Goode, PhD, and his research assistant, Judith Goode. It presents important information not previously known to us.

With respect to the gypsy moth spray program, the Forestry Service needs to address the issues raised in the California lawsuit of the North Coast Alliance vs. the U.S.E.P.A. before proceeding with pesticide spray applications.
http://www.volkerlaw.com/httpdocs/cases/COMPLAINT%20%5BFINAL%5D%2011-25-08.pdf These issues include, but are not limited to: 1) protecting at risk populations from the extensive pesticide drift which covers several miles; 2) the application of non-food "inerts" to areas where food is being grown in a private setting; 3) properly assessing the type and extent of dermal exposure which will occur in wide scale spraying of residential areas; 4) determining if any environmental alternative practices would provide adequate control ; 5) considering the impact on infants, children, chemically sensitive adults, or other populations, be they human or animal, likely to be at risk; 6) considering the impact on ecologically sensitive habitats such as the Chesapeake Bay; and 7) refraining from making determinations about pesticides when there is inadequate information available for making a reliable decision.

The Chemical Sensitivity Disorders Association recommends that the gypsy moth should be controlled using non-toxic methods.

Sincerely yours,

Lawrence A. Plumlee, M.D., President,
Chemical Sensitivity Disorders Association

Referenced Scientific Review