RE:Comments of Cheriel Jensen on the Public Review Draft of the EBRPD Wildfire Hazard Reduction and Resource Management EIR.
State Clearing House No. #2008042099
The entire premise of the EIR, to control wildfire, is defeated by the plan to apply herbicides with the assumption that this will help reduce vegetation and thus will reduce wildfire. But there is no controlled study that shows such an outcome to be true.
Our experiments and hands on workshops show that the herbicide Roundup actually degrades vegetation in a way that creates a much more flammable matrix. Our experiments in the San Francisco Bay Area climates show that branches cut from trees in areas where low level vegetation (grasses and/or shrubs) have been treated with Roundup, when lit by a torch, instantly flame up, whereas tree branches cut from trees in areas to which no herbicides have been used are actually difficult to light.
To demonstrate this to state and east bay local land managers and fire districts we held a well-attended, midsummer East Bay hands-on seminar at the Claremont Hotel. When the various branches were torched, this herbicide/fire acceleration effect was clear.
An EIR is supposed to enlighten actions. To enlighten this EIR, the East Bay Parks District should conduct their own actual on-ground test. On a day when there is no wind, get ready on a wide, paved area with a hose. Cut 2 or 3 long branches from trees where no herbicides or pesticides have been used within 200 feet. Within the same time frame (2 hours) cut similar sized branches from trees of the same type where herbicides have been used in the ground areas nearby. Using a torch, light the branch tips and video tape the resulting fires so you have a record. It will be clear that herbicide, not even directly applied, but used in the vicinity, has an effect on vegetation that will accelerate the burn rate of trees significantly. The vegetation looks the same to the naked eye, but the herbicide-exposed vegetation, however is very different in it‘s characteristics.
In addition to this experiment the following conclusions in the Draft should be revised as follows:
Public Review Draft, IV. Setting, Impacts and Mitigation, E. Hazards and Hazardous Materials, page 284, Impacts and Mitigation Measures, "2. a., Significance Criteria"
Missing from the criteria is that "A significant impact from hazardous materials would occur if the project would:"
"2.b. Less-than-Significant Hazardous Materials Impacts."
The conclusion of this section are mistaken. There is no reference supporting the conclusion that the use of herbicides would have less than significant impact and in fact the use of herbicides would go a long way to defeat the plan’s primary goal and thus have a significant impact. Devastating wildfire would become a virtual certainty.
I have not responded to the health impacts of herbicides. This is not just a matter of spillage as the EIR implies. There is a huge body of research showing these impacts, way too much material to include here, but if you are not familiar with this research I can get you started. The impacts will show up throughout the east bay and beyond, the waters of the east bay, and the San Francisco Bay. The health of the people of the east bay will be severely impacted by the use of herbicides and widespread contamination, an issue virtually ignored by this EIR.
As some notices of the deadline for inclusion say October 30, 2009 and others say October 31, 2009, these comments should be accepted.