Responses to Forum Questions/Answers

Concerned citizens submitted questions in writing at the forum at City Hall on August 23, 2005.  A “shortened version” of the questions and answers appeared in the Davis Enterprise on August 28.  A supposedly complete set of questions was posted on the City of Davis website and is available here, along with answers.  However, in that compilation some of our questions do not appear as we submitted them. 

We feel that it is important to respond to some of the posted answers, as we feel that many of these answers are misleading and that this issue should receive a full airing in the community.  If anyone believes that we are not properly informed about any of these points, please give us citations and we will investigate them carefully.

Q: Are there any persons with financial or professional interests in this process?

A: No.

Response:  No?  What happened to the million dollars the District earlier said it was spending?  Surely the people who filled the planes and sprayed the insecticide over Sacramento did not do it for free.  Surely MGK did not donate the Evergreen 60-6.  This is not a credible answer.

Q: Do you calculate “hot spots” separately or by the whole county?  What criteria do you use to designate a “hot spot?”

A:  “Hot spots” are designated separately.  A "hot spot," by definition, would be based on separate portions of a county, unless further trapping results identified a larger portion of the county with high number of WNV infected mosquitoes.  The Davis Cemetery and other sites for example, are “hot spots.”  Based on our trapping results we found infected mosquitoes at the cemetery, however we have not found significantly more infected mosquitoes with the Davis City boundaries.  Therefore we identified the Davis Cemetery site as a potential “hot spot."

Response: This question was not directly answered. The public needs a precise explanation that includes the numerical factors used in the decision rather than a simple statement that the decision is made based on one area being substantially worse than another.

Q:  Is there scientific evidence supporting the relative safety and effectiveness of this spraying technique?  If so, can it be posted on the District website?

A:  There is, and it will be posted on the District website.  Briefly, the biological reason behind this spraying technique is that the mosquitoes that transmit WNV (Culex pipiens and Culex quincifaciatus) primarily feed on birds and are considered primary vectors of WNV within the bird population, additionally acting as bridge vectors to humans or other mammals.  As adults, these mosquitoes spend much more time in tree canopies than on the ground, and are difficult to kill from ground with ultra low volume (ULV) application equipment.  Spraying from aircraft significantly increases the likelihood of substantially reducing their populations and disrupting the bird portion of the WNV transmission cycle.  References:  
http://www.cdc.gov/ncidod/dvbid/westnile/conf/pdf/nasci_6_04.pdf
http://www.cdc.gov/ncidod/dvbid/westnile/index.htm

Response:  The question we submitted was “Please indicate what the scientific evidence says about the relative safety and effectiveness of spraying vs. not spraying and taking other measures.  Please give full citations of peer-reviewed articles on your website that prove that spraying is safe and more effective than other measures.” 

First, we are informed that the two main mosquitoes of concern to transmit WNV in this area are Culex pipiens and Culex tarsalis, so we are puzzled both at no mention of Culex tarsalis and at the mention of Culex quincifaciatus.  Actually, we find no reference at all on the CDC website to Culex quincifaciatus; instead, we find many references to Culex quinquefasciatus.  One paper, Vector Competence of California Mosquitoes for West Nile virus, by researchers at UC Davis, characterizes this species as one of the two "least efficient laboratory vectors" in that study, whereas Culex tarsalis and Culex pipiens are characterized as two of the "most efficient laboratory vectors." 

Second, the question deals with more than technique, and the issue of relative safety of spraying was not addressed.  This is particularly troubling since this question is of the utmost concern to the public.  Vector Control should answer the question of safety immediately and provide evidence to substantiate the response.  Further, it should be placed on the record in unequivocal language whether or not spraying can be harmful to children and/or the elderly who have asthma or any other breathing difficulty.  Officials have said that Davis will be sprayed by ground, but this answer deals with aerial spraying.  One of the main conclusions to draw from this answer would seem to be that ground spraying is not effective.  The Nasci study has been seriously called into question, and no citations of relevant studies are apparent on the West Nile page of the CDC website.  We have waited for appropriate citations to be posted on fightthebite, but we still do not see any sign of this.  See our discussion about the non-existence of evidence, as well as our discussion about risk.  

Note:  Subsequent to this forum, vector-control officials here and in other regions have begun to cite a report by DHS officials as evidence.  This report has significant problems, however.  Please see a full critique here.

Q: What is the epidemiological basis for the District’s decision to spray?  How do you verify the long-term human health improvement?

A:  Based on the progression of the disease in western states, with ecological conditions similar to California (since 2003), there is no doubt that without intervention the disease will infect 100’s or 1,000’s of humans in the area.  The result will be dozens, if not hundreds, of cases of serious neuroinvasive disease that often result in permanent disability and can conclude in death. Although neuroinvasive cases are more likely in people with an immune-compromised condition, serious and life threatening cases of the disease are reported in individuals of every age and race, some in otherwise excellent health.

It is also important to remember that the mosquitoes that transmit the disease can, and do, enter homes readily, and once inside the home often bite individuals at night while they are asleep. This is why proper maintenance of screens and screen doors is essential

Response:  This answer is misleading by focusing on what will happen “without intervention,” as nobody is suggesting that there should not be “intervention.”  We strongly support integrated-pest-management programs without the use of adulticides.  No evidence for the effectiveness of the spraying of adulticides to reduce the incidence of WNV has been offered.  See our discussion of effectiveness.  Moreover, the assertions of what will happen without “intervention” are highly speculative, as disaster has not befallen the many communities that have chosen not to spray adulticides.  See our discussion of alternatives.  In addition, these numbers (e.g. hundreds of serious cases of neuroinvasive disease per thousands of infections) yield figures (roughly 1 in 10) that are much higher than the CDC estimate of 1 in 150. 

Nothing is offered here about verification of the long-term human health improvement, and advice about keeping screens repaired does not serve as an answer.

Q: Is the district considering the numerous communities on the East Coast that have banned spraying because it has proven to be ineffective?

A:  Spraying has not proven to be ineffective.  Many of the communities referred to on the east coast only used adulticiding as a means of mosquito control.  The SYMVCD uses an integrated approach, where multiple life stages of the mosquito (larva, pupa and adult) are targeted with a variety of different approaches including vegetation management, mosquito fish, bacteria, insect growth regulators, surface agents, and more than one family of chemical. The SYMVCD currently, and for many years has used an integrated approach which includes source reduction and water management, biological controls, larvicide control and adulticide control is a last resort based on surveillance.  

Response:  This question/answer has the issue backward.  When an official agency plans to spray people's homes with toxic chemicals against their will, the onus is on the agency to provide solid evidence that what it plans to do is safe and effective, as opposed to the other way around.  Yet officials have provided no evidence that spraying adulticides has been effective at reducing the transmission of WNV to humans.  Many communities east of California have employed integrated approaches without spraying adulticides and have done as well or better in terms of WNV infections in humans than surrounding communities that have sprayed adulticides.  See our discussion of alternatives.  

Q: What has been the democratic process to reach the decision to fumigate?

A:  Control of adult mosquitoes does not involve the use of fumes, but rather the directed application of chemical pesticide-based treatment on surveillance indicators.  SYMVCD has a Board of Trustees appointed by each city and County in the SYMVCD jurisdiction.  The Board adopted a plan in March of this year, which was distributed to every City and County Chief Administrator.  It was also shared with the local Health Officers and other similar public agencies.

Response:  There has been an absence of democratic process with respect to the decision to spray.  The decision to spray is delegated to the District's General Manager.  The General Manager answers to the Board of Trustees, who are appointed by the various cities and the two counties.  One trustee is appointed by each respective jurisdiction.  The trustees do not answer to or take direction from the cities and/or counties.  Thus, the Board as a whole, as well as each individual trustee, is not accountable to the electorate.  The General Manager is not accountable to the electorate, only to the Board of Trustees.  Additionally, the initiative process does not apply to the District, as the District's governing board is not elected.  The result is a special district that is completely insulated from the democratic process and answerable to no one.

As indicated by the District's answer, the plan to spray was shared with the local elected officials after the plan was adopted.  There is no indication that the District actively sought input from the elected officials or the community prior to adopting the plan to spray.

Q: What was the total number of deaths from West Nile virus statewide in 2004?  Is this a human epidemic?

A:  Twenty-eight deaths were reported last year. The general definition of an epidemic is when there are more than the usual numbers of cases over a specified time period.  California had the greatest number of human cases in the United States last year.  This is an epidemic of West Nile virus.

Response:  This is a bizarre answer that is reflective of how this issue has been sensationalized.  The general definition of epidemic revolves around the concept of many individuals in a population being infected by a disease over a certain time period.  28 WNV deaths in all of California last year hardly represent a large number.  Moreover, as of this date (9-22-05) there have been 14 deaths in all of California this year, well less than last year's total.  To gain some perspective, consider that Yolo County had 61 deaths from the flu in 2003, which is a far higher rate of occurrence.  Do we have a flu epidemic in our county?  Why do we not have newspaper reports of each of the individual deaths of the flu each winter?  Officials’ working definition of epidemic in this issue has revolved around the number of infected mosquitoes, as opposed to the number of serious human cases.  They consider more than 5 per 1000 an “epidemic,” but no justification of that figure has been offered.  That figure for WNV-infected mosquitoes certainly represents more instances than in past years in this area, as WNV is new to the area, but we believe that the use of this emotionally-charged word relative to mosquito and not human populations creates confusion and further sensationalizes the issue. 

California also has the greatest number of people in the United States, so one might expect the greatest number of many diseases here in absence of any epidemics at all.  The number of WNV cases has peaked in eastern states and is on the decline.  Indeed, one district has decided to treat WNV as it treats any other “common summer occurrence.”

Q: Are there any epidemiological models that support the use of mosquito spraying as an effective deterrent to West Nile virus?

A:  There are papers from the Centers for Disease Control, as well as from Louisiana Mosquito Control Districts that demonstrate the effectiveness of treatments for adult mosquitoes in the reduction of new human WNV cases.  References:  
http://www.cdc.gov/ncidod/dvbid/westnile/conf/pdf/nasci_6_04.pdf
http://www.cdc.gov/ncidod/dvbid/westnile/index.htm .

Response:  This is another reference to the Nasci paper, as well as a general reference to the West Nile page of the CDC site, with no immediate citations of papers (see our discussion of effectiveness).  We wanted to read the actual “Louisiana papers” and contacted Dr. Kramer, who faxed us a copy of one paper with the references omitted.  The title of the paper is “Impact of West Nile Virus Outbreak upon St. Tammany Parish Mosquito Abatement District,” and it appeared in the Journal of the American Mosquito Control Association, 21(1):33-38, 2005.

This question is about spraying, and the answer refers to treatments in general, which is not responsive.  This paper itself does not support an answer to the question either, as it does not concern a comparative study.  Indeed, it was not a study at all, as the intent of the paper was to show the financial impact on the district of all of their control methods.  Look here for a more-detailed analysis.  These two papers are the best that officials could come up with to justify the use of urban adulticides, which confirms that they have no evidence, models, or studies. 

Q: Is pyrethrin truly safe and non-toxic?

A:  Pyrethrum is the most widely used as a natural insecticide in the U.S. . . . In fact, it has more approved EPA (Environmental Protection Agency) uses than any other insecticide . . . Pyrethrum is registered for organic production, PBO (being a synthetic product) is not. . .

Clearly, the effects of pyrethrum (or for that matter, any pesticide) on human health and the environment depend on how much pyrethrum is present, and the length of exposure.  Effects also depend on the health of a person and/or certain environmental factors.  Pregnant women (and for that matter, all individuals) should follow the Districts guidelines and avoid contact with pyrethrum being used to control mosquitoes.

As stated above, pyrethrum is not applied by itself – rather it is applied with the synergist, piperonyl butoxicide (PBO). . .

The US EPA classifies PBO as a group C carcinogen.  . .  

Response:  Please see the City website for the full and long answer.  We wish to point out that the U.S. EPA is halfway through the process to reevaluate the registration of Pyrethrins and PBO for use in pesticides.  The preliminary risk assessment indicates new areas of concern.  There is significant evidence that the preliminary risk assessment must be revised, as it underestimates risk of harm.  See Risk and Pesticide Facts.

Furthermore, as anyone can tell, the health of all individuals in the district (or for that matter in any part of the country) is not equal – varying from healthy individuals to immune-compromised people.  If the effect of the spray depends on the health of the person, it should be clear that some percentage of the population will be affected by the spray.  The District then warns everyone to avoid contact with the chemical used in the spray – pyrethrum.  The only guaranteed way to avoid contact with this chemical is to not use it.  The district cannot force the spray in the back yard of every home and every playground and expect no one to come in contact with the chemical.

When the District was asked if there was any plan to clean or wash the public playgrounds, it replied that it had no such plan.  If the District’s strategy is to spray our children’s playgrounds, we can be absolutely certain our kids will come in contact with the chemicals in the spray.  This is an unacceptable risk to our children’s health and well being.

We believe that the correct name is piperonyl butoxide and not piperonyl butoxicide.

Q: How long does it take for this pesticide to decompose?  Does this include indoor decomposition rates?

A:  The products breakdown rapidly in the environment.  There is no evidence that enough of the product could either enter or be brought into the house for it to be of concern.

Response:  According to Doug Williams of Pesticide Alternatives, "piperonyl butoxide (PBO) does NOT break down in sunlight.  Period!  Pyrethrins do, but not PBO.  It is unclear if the pyrethrins break down in sunlight when mixed with PBO, but in any event, PBO is not photosensitive at all."

Moreover, Williams notes that "PBO has a Hydrolysis half-life of 250 days, an Aerobic Soil half-life of 79 days, and an Anaerobic Soil half-life of 927 days.  SYMVCD will try to quote the PBO General Fact Sheet which says breakdown is faster, but the study is bogus and non-specific."  See the sources in the report, from Pesticide Alternatives.

Finally, "An important question that has not been answered is: What does the PBO break down into?  The same question goes for the other chemicals as well.  Yes, they may break down, but we don't know what new chemicals are formed, and we have no assurance that the resulting chemicals are not just as toxic and carcinogenic as the originals (perhaps even more so)," notes Williams.

Q: What health effects do piperonyl butoxide have on developing fetuses and small children?  What about children with asthma and/or allergies?

A:  There is no evidence to suggest that PBO will have an effect on developing fetuses and small children.  At the low dosage rates there should not be any impacts for individuals with allergies or asthma.  However, it is recommended to stay indoors during applications to minimize any concern.

Response:  Are people, particularly those responsible for spraying pesticides, aware of the fact that the California Department Of Health Services estimated the number of people in 2003 in Yolo County with asthma at 23,000 (17,000 adults and 6,000 children)?  If even a small percentage of these people were negatively impacted by adulticides it would be a significant number.  For example, Washington D.C. , is one of many 'no spray' cities, and concern over people with asthma was one important reason officials gave for not spraying adulticides: "The District does not expect to spray for adult mosquito control for many reasons. Washington, DC  has the highest asthma rate in the country (2.5 times the national average). Aerosolized pesticides can trigger asthma and aggravate respiratory conditions."  See the final plan for 2004.  Another example is Fort Worth, Texas, which stopped spraying adulticides for many reasons, and noted that " . . . thousands of Fort Worth residents living with respiratory problems such as asthma would be in danger of an outset of symptoms. Asthma and Allergies are two of the top five health problems for Fort Worth residents, according the 1998 Community Needs Assessment. The potential inhalation hazard to the general population does not seem worth the risk of killing a few mosquitoes." See the position statement of that District.

Q: What effects will the pesticide have on beneficial insects?

A:  At the rates applied there should be minimal, if any, effects on beneficial insects.  The District applies the product when mosquitoes are most active and other insects are not, thus minimizing exposure to other insects.

Response:  The President (2004) of the American Mosquito Control Association, Roger Nasci, writes in a letter to the EPA, "Pyrethrins, though relatively safe compounds, bear the signal word 'Caution' on the label, and the precautionary statements indicate that they may be harmful if inhaled. Labels also advise that pets and birds be removed and aquaria covered before spraying."

Nasci also notes that "They [the spraying] will negatively impact beneficial insect populations and other non-target organisms on site and through uncontrolled off-site drift.  The indiscriminate application of pyrethrins will continually select for resistance to the whole pyrethroid class of mosquitocide, all of which utilize the same fundamental mode of action."

We believe that the District has misled the public into thinking that the chemicals used in WNV adulticides are perfectly safe, like DDT and malathion were touted to be in the past.

Q:  What are the effects of pyrethroids/pyrethrins to water quality?

A:  At the rates being used there should be no impact on water quality.  The District has hired a local environmental firm to perform water quality sampling of local streams and rivers, and will share the results as soon as they become available.

Response:  See the response to the question about the Clean Water Act below.

Q. What is the percentage of West Nile virus in the bird population?

A:  . . . "The district does not, and cannot, test every dead bird, and therefore cannot estimate the percentage of WNV in the bird population."

Response:  If that is the case, then the District should make it clear to the public and the media that not every dead bird has died from West Nile virus.  Citing and publicizing the total number of dead birds without this disclaimer is highly misleading. The District is using these statistics as one of the ways to convince the public of the "epidemic" spread of West Nile virus.  Here are the numbers that should be publicized: as of Sept. 6, 2005 the "Cumulative Dead Bird Infection by County" was 50 in Sacramento and 12 in Yolo (Source: U.S. Department of the Interior,  Link http://westnilemaps.usgs.gov/ca_bird.html ).

Q: How do you determine the effectiveness of spraying?  Do you calculate the change in transmission rates and not just decline in the adult mosquito population?

A:  Both methods are used to determine the effectiveness of spraying.

Response:  This is at best a small part of an answer.  Is there an algorithm that uses these factors, or does somebody eyeball some data and make a seat-of-the-pants determination?  If there is an algorithm, a formula, or anything else specific, what is it (are they)?  We have been unable to get this information from the District.  Further, how is the information about transmission rates and mosquito populations gathered?

Q: Has the District used models to project the effectiveness of spraying versus not spraying?  If so, is it available to the public?

A:  There are papers from the Centers for Disease Control, as well as from Louisiana Mosquito Control Districts that demonstrate the effectiveness of treatments for adult mosquitoes in the reduction of new human WNV cases.  Citations to these studies are available on the website: www.fightthebite.net.

Response:  This is similar to a previous question.  The cited paper from the Louisiana Mosquito Control Districts did not provide an answer before, and it does not now.  We have checked fightthebite.net repeatedly since these answers were posted, and there are no apparent citations of studies about effectiveness.  Indeed, Dr. Wallace LeStourgeon, a Vanderbilt University Molecular Biologist who teaches an advanced course on environmental toxins, says that "I think we need to . . . begin insisting to see convincing evidence that spraying reduces west Nile disease. It simply does not exist."

Q: Are there any alternatives to the pesticide spraying which could be used?

A:  There is no other way to quickly reduce an adult mosquito population

Response:  Perhaps that is true, but there are other ways to reduce adult mosquito populations, such as traps.  However, the critical question remains as to whether "quickly reducing the adult mosquito population," if possible, translates into reducing the transmission of WNV, and no evidence has been offered.  See Effectiveness.  And, does the spray quickly reduce adult mosquitoes?  Apparently the application of adulticides gives an immediate knockdown of some mosquitoes, but they quickly rebound to pre-spray levels and there is little effect on the transmission of WNV.  Claims of up to 40% knockdown of mosquitoes have been made, but these come from measurements of mosquitoes in cages in open fields, which is very different from situations in urban areas.  In the city mosquitoes hide in crevices, under leaves, and in various places.  The spray must make a direct hit to kill, and it is a repellent, which tends to drive mosquitoes away before a direct hit is made.  According to David Pimentel, Ph.D., an entomologist at Cornell University, close to 99.9 % of sprayed chemicals go off into the environment where they can have detrimental effects on public health and ecosystems, leaving 0.1% to actually hit the target pest (see fact sheet).  If a district must resort to reducing adult mosquito populations, it has failed in its control program.  Many communities have had success at reducing the rate of transmission of WNV without resorting to spraying adulticides.  See Alternatives.

Q: What are my rights as a citizen to refuse ground and aerial spraying?

A:  The actions of the District are governed by the California Health and Safety Code.

Response:  This is a non-answer.  Are we expected to search the volumes of code to see if we can find anything?  What about the opt-out provision?

Q: What outreach efforts have the District completed to inform citizens of their rights to opt out of ground spraying?

A:  There is no provision for opting out of ground spraying.  However, the District has created a “no-spray” list for those individuals with serious medical conditions that require this type of consideration. It is not intended nor should it be used as a civil disobedience tool.  When citizens contact us who have a serious medical condition, we will take whatever measures possible to address their concerns.

Response:  Civil disobedience?   If Vector Control officials think that signing up on a "no-spray" list they have established is civil disobedience, they seem to be largely unaware of important movements in our history and the great personal sacrifices of some individuals through genuine civil disobedience.  David Brown initially informed us that if we were concerned about spraying in our neighborhood we could try to get all of our neighbors to sign up on the opt-out list, and he said nothing about medical conditions.  Later, perhaps after many concerned people had signed up, we began to hear from the District that if too many people signed up they might be forced to spray aerially.  Supposedly the decisions are made through a democratic process, but the message comes through yet once again that concerned citizens have no say in this process.

Q: How many communities have rejected spraying in our region, state, and nationwide?

A:  The District is not aware of any jurisdiction that had rejected mosquito control efforts.  The District is, however, aware of communities that have been frustrated when adulticiding was the only response.  SYMVCD uses a comprehensive integrated pest management system to address mosquito populations which includes, water management, biological control, larviciding and education programs – and as a last resort – adulticiding.

Response: The question specifically refers to spraying and not “mosquito control efforts” generally.  The answer seems to suggest that officials are somewhat isolated and are missing important information, as many jurisdictions have rejected spraying adulticides.  See Alternatives.  As one example, at its July, 2003, meeting the City Council of Lyndhurst, Ohio, even passed an ordinance to ban the spraying of adulticides to control mosquitoes.  

Q: What would be projected to happen in the absence of a spraying campaign?

A:  A substantial increase in the number of WNV cases.

Response:  Where is the evidence for this assertion?  Again, many locales have decided not to spray adulticides and have done well, often better than surrounding locales that have sprayed, and have not suffered a "substantial increase in the number of WNV cases."  It is becoming apparent that the adulticiding program of SYMVCD is nothing but a genuine faith-based initiative, completely lacking any scientific or logical basis.  See Effectiveness and Alternatives.

Q: Why wasn’t the option to opt out of the spraying more widely advertised?  Is there a way to hold off spraying until people have a chance to opt out?

A:  Individuals identified with a serious medical condition are encouraged to use opt out of ground spraying.

Response:  This reply is non-responsive.

Q: How effective is the spraying if people are able to opt out?

A:  Opting out of ground spraying is offered for individuals that have serious medical conditions.  If this, instead, is used as a tool for civil disobedience, unfortunately, ground spraying will not be effective and aerial applications will have to be used.

Response:  David Brown initially encouraged anybody to opt out who wanted to avoid spraying.  Now we are threatened with a different method of spraying if people without medical conditions object to being sprayed against our will and opt out.  It would seem to us that a longer-term goal should be to change the structure of the District and make these individuals accountable to the people they are supposed to serve.

Q: How can citizens help contribute to a long-term plan to develop a permanent program?  How can citizens get involved in the review of existing plans?

A:  The District has an ongoing program to encourage the public to help "Fight the Bite".  The most important “permanent” actions that people can take are to eliminate mosquitoes around their homes by dumping water containers, making sure standing water does not produce mosquitoes, and by keeping mosquitoes from entering their home by making sure that windows are screened and that screens are in good repair.

Response:  This is non-responsive.  The question is not what people can do to help cut down the risk of transmission of WNV, it is how the people can become involved in reviewing existing plans and developing new ones for the future.  This is a policy-level question, and the reply is contradictory to the earlier claims about democratic process.  It is important to note that the CDC recommends the establishment of a community task force in each community to " . . .  develop community ownership for prevention activities."  See the CDC guidelines for surveillance, prevention, and control, page 39.

This community should not suffer for the District's failure to control mosquito populations at the larval stage, but in the spirit of compromise and the desire to stop urban pesticide spraying, a group of Davis residents met with Mayor Asmundson on the morning of August 23rd, to relay a proposal to the City and District that was conceived at a public meeting the night before. The proposal provided that volunteers, in cooperation with the City and the District, immediately undertake a massive public education campaign, survey the parks and greenbelts for standing water, and report mosquito habitat and larvicide.  In exchange for citizen involvement that would have provided extra eyes, ears and public educators for the District, the citizens asked that the District refrain from aerial or ground spraying in order to evaluate the citizen mobilization.  Unfortunately, we never received a response to our citizen-based proposal.

This could have been a win-win situation.  Infected mosquito counts had dropped, which would have given the plan a head start in warding off urban spraying as well as WNV infections, and it could have formed the basis for the establishment of a community task force.  It looks to us as if there is no democratic process and no citizen participation, in spite of assertions by the District and recommendations of the CDC.  In ways the District seems to be intransigent and have a somewhat of a shortsighted view; apparently what it decides is right for this community despite effective alternatives, regardless of the potential and risks, and most importantly without community input.  In Fort Worth, the District spoke about involvement on the part of the community that was much less than what we proposed as a “let’s do-it-together plan.”

Q: Has the district considered provisions of the Clean Water Act in their decision to spray?

A:  The District believes it is in full compliance with the Clean Water Act.

Response:  The District is being disingenuous with this statement.  Contrary to the District’s response, the use of adulticides over waterways violates the Clean Water Act. See a detailed analysis here.  The challenge to the District’s violation of the Clean Water Act will continue.


Final Notes.  Many of the District's answers to citizens' concerns are misleading, and we feel that the content and tone of some of the statements by officials and the media exaggerate the risk of WNV badly.  In addition, independent of possible risks of spraying adulticides, the overriding assumption on the part of the District, as reflected in these answers and other things, seems to be that spraying adulticides reduces the transmission rate of WNV.  However, the District has offered no credible evidence that this is true and instead repeats assumptions and false statements.  The District has no way of assessing the question, as it did not set up the spraying of Sacramento with any controls to measure effectiveness.  Indeed, some of the materials from the District even stated that spraying provides temporary relief.

Given the risks associated with the spray and given effective alternatives, we think that there should be a moratorium on spraying adulticides in urban areas.  If the effectiveness of such spraying is ever demonstrated, then the relative risk of WNV vs. spraying adulticides needs to be carefully assessed.  In the meantime, we ask the District to step up its integrated approach without adulticides, set up the community task force(s) recommended by the CDC, look carefully into the process and rationale behind the decisions not to spray adulticides in many other locales, and begin a democratic process to develop a new plan that incorporates public education and outreach and uses efforts by members of the public instead of adulticides.  Under any new plan the District must be accountable to the public.  It cannot remain insulated, with no public recourse to its decisions.  The District itself should be restructured.  It must also hold its meetings at times and locations accessible to the public.