California - Glassey Winged Sharpshooter

Regarding the CDFA Glassy-winged Sharpshooter (GWSS) eradication/Pierce's Disease Control program:

Background, Comments and Suggestions from Ann Maurice, Member Environmental/Public Health Task Force

Ad Hoc Committee for Clean Water
P.O.Box 484 Occidental, Ca. 95465 707 874-3855 phone/FAX

Regarding the CDFA Glassy-winged Sharpshooter (GWSS) eradication/Pierce's Disease Control program:

In general, I believe the GWSS program should be halted and no additional funds allocated. There should be an immediate end to spraying the public with pesticides or release of bio-engineered materials. There does not appear to be an "emergency", at the very least, information is conflicting and contradictory, for example:

Grapegrowers are planting grapes in heavily "infested" areas, adjacent to known high concentrations of glassy-winged sharpshooters (GWSS) and not necessarily experiencing losses. Grape production is UP all over the state, in southern and central California including Temecula and Riverside County, ground zero for projections of impending financial losses that have not materialized.

"Infested" Kern County has NO program to spray the public. The county has both a thriving grape and citrus industry and extremely high numbers of Glassy-winged sharpshooters! The CDFA and the Kern County Agricultural Commissioner's office do NOT expect that lack of a pesticide spray program of the public will devastate grape production in Kern County.

Especially considering the above factors, it is inexcusable and unreasonable to spray public and private properties elsewhere in the state with pesticides or bio-engineered materials. Bear in mind that government funds are NOT being allocated to spray vineyards upon finding GWSS. THE PUBLIC IS BEING SPRAYED. And, areas are defined as "infested" if ONE adult and ONE nymph or egg sac are found within a mile! That means the government can abate the "pest" in the "infested" area and members of the public who do not even have GWSS on their property, just within a mile of one bug and eggs, can be exposed to toxic pesticides and have their backyard gardens, furniture, pets, landscaping and native plants contaminated with toxins or release of bio-engineered bacteria and insects.

The sections of the Food and Agriculture code (3650-3660) that set up those conditions should be rescinded immediately before any further damage is done to the unsuspecting public by experiments with pesticides or bio-engineered bacteria releases.

The following are excerpts of my submission to the Environmental/Public Health Task Force. For the full text, contact the CDFA, Sacramento. My report is the result of extensive interviews and research regarding the GWSS Pierce's Disease program. I hope that the information presented will be useful to all concerned with creation of fair and reasonable public policies, accountability on the part of governmental agencies and industry, rational land use and above all decency and respect for one another.

(4) Photographs of Temecula vineyards in various stages of development planted next to citrus groves with no evident manifestation of disease.

(5) Controversial Map of Glassy-winged Sharpshooter “Infested Areas” “Infested Area’ is defined by the CDFA as an area within one mile of a vector infestation (5 adult insects, or multiple life stages), or an area which has not been surveyed.

(6) Excerpts from “Regulation Vs Practice: A Review of the California Department of Food and Agriculture Pesticide Registration Process” prepared by the California Senate Office of Research, 1990

(7) “A Farmer’s Life Dream Ends in Disaster”, “Pesticides and You”, Vol 17 no. 3, pp 17-19 published by the National coalition Against the Misuse of Pesticides; An account of how years of chemical intensive farming practices resulted in adverse health and ecomomic effects on him and his family.

(8) CNN story on how exposure to environmental toxins might contribute to Parkinson’s Disease; specifically named is “Rotenone”, an “organic” or “botanical” pesticide, used in organic farming and by the Department of Fish and Game in Lake Davis, California.

(11) Photo of citizens objecting to CDFA spray program demanding a Public Hearing in Sonoma County

(12) Letters and petitions against spraying or release of Bio-engineered materials and demanding environmental and public health accountabilityTo the Glassy-Winged Sharpshooter Environmental/Public Health Task Force

Recommendations regarding the CDFA Glassy-Winged Sharpshooter/Pierce’s Disease program:

I recommend the Task Force call upon the Department and/or the Legislature to enact the following:

1. Terminate the “emergency” status. Growers are planting highly susceptible varietals in known high vector concentration areas, with no buffer zones. This activity casts a shroud of doubt over the credibility of the emergency. Surely, if this were truly an emergency, one would think that grapegrowers would be avoiding Pierce’s Disease prone areas, without any prompting. Presumably their concern for their own financial well-being and their lenders would require it.

2. Suspend or amend Sections 3650-3660 of the California Code pending full review and disclosure of potential adverse impacts of the regulations and vineyard practices per CEQA, NEPA, nuisance laws, the state “Right to Farm” laws, unfair business practices, civil rights laws, public disclosure laws, Americans with Disabilities Act, the Endangered Species Act, and other applicable laws. The definitions of “infestation” and “infested area” are too broad, allowing for genetic engineering or pesticide abatement on properties that actually harbor no “pests”, just a potential “pest” population, shifting the burden of risk of exposure to the public, away from the wine industry.

3. End any CDFA GWSS/PD programs of aerial spray, “backyard home invasion” ground spray, or soil soaking pesticide application of public, private properties, parks or wildlands since those applications put our citizens, especially the chemically sensitive, livestock, pets and property, the environment, including wild and domestic pollinators, endangered species including salmon and steelhead, aquatic invertebrates and amphibians, birds, bats and insects, at an unreasonable and unacceptable risk.

4. No new funds to the program, [about $35 million in State and Federal funds already allocated];

5. No release of bio-engineered bacteria, insects or plant materials, or release of exotic bacteria or insects for purposes of Pierce’s Disease control under any circumstances due to potentially disastrous unintended consequences;

6. No further release of funds or implementation of programs for Pierce’s Disease or Glassy-Winged Sharpshooter control prior to full disclosure, review and evaluation of the program, alternatives, and mitigation of potential adverse impacts per the California Environmental Quality Act (CEQA) and other applicable laws, including but not limited to the National Environmental Policy Act (NEPA), the Clean Water Act, Endangered Species Act, Food Quality Protection Act (FQPA), and the Federal Insecticide, Fungicide, Rodenticide Act (FIFRA), American Disability Act.

7. If the fund is not terminated, continue the Environmental/Public Health Task Force and add Public Health and Environmental representatives/advocates to the Pierce’s Disease Advisory Task Force and Scientific Advisory Panel.

8. Mandate the following common sense practices for the wine industry: a. Buffer zones to areas of known insect or bacteria infestation;

Findings regarding the CDFA Glassy-Winged Sharpshooter/Pierce’s Disease program:

I am currently participating in the California Department of Food and Agriculture (CDFA) Environmental/Public Health Task Force charged with making recommendations to the Legislature. The program includes aerial and ground pesticide spray of non-farm, non vineyard and non-infected public and private properties with pesticides, research and potential release of bio-engineered insects, bacteria and plant materials, and release of exotic, imported insects. This program has the potential for grave adverse impacts to civil liberties, public health and safety, other businesses and our natural resources.

I reviewed the program as presented by the Department of Food and Agriculture, conducted extensive independent research, interviewed citizens, especially known and potentially chemically sensitive persons, growers, Farm Bureau representatives and Agricultural Commissioners throughout the State, attended seminars, forums, Public Hearings and stakeholder meetings, and have developed a coalition of diverse persons and groups with a common interest in fair policies, consideration for public health and welfare of all our citizens and diverse sectors of the economy, other wild and domestic life forms and natural resources.

Grape production is UP! The declaration of “emergency” and “war” on the the Glassy-Winged Sharpshooter was based on belief in “impending doom” to the State’s wine industry because of fears of “devastation” to the growers in Temecula (1). However, the feared “devastation” has not materialized. Grape production is UP in Temecula and UP all over the State (2).

Vineyards near high populations of the Glassy-Winged Sharpshooter do not necessarily have Pierce’s Disease (3). Vineyards in “infested areas” are alive and well, while, on the other hand, there are Pierce’s Disease losses in areas with no Glassy-Winged Sharpshooters (4).

Growers in Temecula, supposedly ground zero for GWSS, have been planting within a few feet of their own citrus groves with known high populations of sharpshooters, yet, those vines are not necessarily impacted (5). Instead, there are areas called “hot spots” of disease scattered throughout Temecula vineyards (6). [See photos in TABLE OF CONTENTS 4]. Therefore, the Glassy-Winged Sharpshooter cannot logically be the determining factor for outbreak of Pierce’s Disease. If the GWSS were the determining factor, there would be the highest incidence of Pierce’s Disease closest to the citrus with their “clouds” of leafhoppers, and progressively less and less, the further you get from the insects. That is not the case. Therefore, other variables must be determining manifestation of the disease. What are those other variables? Possibilities are: purchase and planting of already-contaminated vines, poor nutrition, soil erosion, weak or susceptible rootstock or varietals, presence of other diseases, abrupt shut-off of irrigation July 1st, bacteria-contaminated water or soils and other unknowns. Pierce’s Disease can be easily confused with other problems (7).

The Department has not produced evidence of the extent (in acreage or vines) of the so-called “devastation” in Temecula and other counties with GWSS infestation, compared with the extent of losses to Pierce’s Disease in “uninfested” counties. We have been shown no evidence as to how variables other than the Glassy-Winged Sharpshooter were ruled out.

There is no evidence that the Glassy-Winged Sharpshooter is “new”, or just “beginning to spread”. What is new and just beginning is the Department’s recent decision to look for it. There is a logical correlation between looking for something and finding what might have been there all along. There is documentation that the GWSS has been known to have been present in high numbers in citrus groves for at least 10 years. The bacteria, xylella fastidiosa, that can cause Pierce’s Disease is definitely not new. The bacteria was known to have precipitated an outbreak of Pierce’s disease a hundred years ago (8). The GWSS may have been present, for a long time, in small numbers throughout the state, but may have been unable to get established in high or significant numbers outside citrus-growing regions due to climatic, habitat, altitude (9), ultra-violet light or other variables unknown and unidentifiable to human researchers.

IV: Faulty definition of “Infestation” The Department’s definition of “Infestation” is the detection of “five adults” within a “five day period” within a 300-yard radius, or “the detection of multiple life stages” (10).

The Department’s definition of “Infested area” is an area “within one mile” of an infestation, or “an area which has not been surveyed in a manner approved by the Department to detect vectors” (11).

Therefore, the maps showing extent of “Infestation” are misleading and may exaggerate the extent of GWSS population by including vast shaded areas with very few sharpshooters or none at all because not surveyed per the Departments definitions as outlined above (12).

V. “Treatment area” includes properties with no GWSS CDFA pesticide application includes spraying private properties even though they have no GWSS found on them. Treatment with Carbaryl and Imidacloprid have been made on properties in the vicinity of GWSS finds. Such “broad-spectrum” pesticides may actually, in the long run be ineffective (do not kill eggs) or might even make matters worse by killing natural predators or by stimulating the leafhoppers, and, property owners may have no opportunity to “abate” the insect their own way because there are not necessarily any insects on their property!(13).

There is no evidence of widespread “panic” in the wine industry. If there were “panic”, the industry itself would already be adopting, or demanding adoption of certain common sense procedures or practices, which we recommend, such as:

Pesticide Eradication Plan in “Infested Areas”, no resulting collapse of the grape industry

The Department is not attempting to eradicate the GWSS in “infested areas”. In other words, GWSS has already built up high concentrations in certain counties, yet, “infested” Kern County, for example, is leaving it up to individual property owners, businesses and farmers to deal with the insects as they see fit and has no mandatory pesticide spray program (19).

Kern County believes, and the CDFA apparently concurs, that it would be impossible to eradicate the sharpshooter.

However, in spite of their being no short term, pesticide-based, mandatory spray “Rapid Response Plan in Kern County, we see no evidence of “panic” on the part of grapegrowers in Kern County or in neighboring counties due to this CDFA policy. No evidence of imminent collapse of the Kern County grape/wine industry. No evidence of adoption or discussion of the above common sense and practical precautions.

VIII. Pesticides proposed and being used for “Rapid Response” may endanger public health and safety, endangered species and pollinators:

In general, pesticides are not thoroughly tested in the Registration process and the quality of the testing was challenged by Legislative Committee [see TABLE OF CONTENTS 6]. Some of the pesticides proposed or used for Pierce’s Disease control were registered for use in the State of California years ago, prior to the re-organization of the Department of Food and Agriculture that occurred as a result of the Senate Office of Research review. Were those pesticides (carbaryl or malathion) re-analyzed, re-studied or re-registered?

Furthermore, the full product is not necessarily analyzed for significant adverse impacts. “Inerts” and “secret ingredients”, while possibly 85% of the product, are unidentified and adverse impacts of those “inerts” on humans and other species largely unknown (20).

Some of those secret ingredients may even be responsible for “hormoligosis” (pesticide stimulation of insect reproduction)(21), may be highly toxic carcinogens, or cause unidentified disturbances to human and other species’ reproductive systems, cause neurological impairment, learning disorders, aggression, violence or death. Humans and other species have variable reactions to toxins.[See TABLE OF CONTENTS 6 and 7]. The adverse impacts to individuals may be deadly, especially to known chemically sensitive persons. Other persons may be rendered chemically sensitive after this application, or develop increased sensitivity. There is abundant information regarding these toxins that increased sensitivity is created with repeated exposure (22).

Specifically with regard to salmonids, research shows that pesticides may adversely impact anadromous fishes’ ability to transition from fresh to salt water habitat. The active ingredients in the pesticides used and proposed for use are known to be highly toxic to aquatic life and pollinators (23). Carbaryl, and Lorsban have been sprayed and are not ruled out either by aerial or ground application. Imidacloprid, I believe, was sprayed in Brentwood. (My investigation continues). Section 18 exemptions were obtained for Admire (24), an imidacloprid product, exempting the product from existing labeling instructions and allowing an ‘experimental’, or non-registered use. This allows for unanticipated adverse impacts not flagged in the registration process, and experimenting on the public. Pesticide spray drift is known to travel for miles, temperature inversion and winds allow for transport of volatiles. Runoff can take pesticide residues into swales, creeks and streams. Furthermore, the USDA advises that “broad-spectrum” pesticides like carbaryl and Lorsban may “exacerbate a leafhopper problem” (25).

I conclude that human and other species are at an unacceptable risk due to pesticide application of public and private properties in this Pierce’s Disease program considering the above findings and findings I - VII.

IX: Genetic engineering projects pose grave risks to the environment and the public This program includes controversial genetic engineering aspects that have not been disclosed or evaluated per CEQA and NEPA due to the “emergency exemption”. Research has been funded and is underway to bio-engineer the xylella bacteria, insects and plant material (26). The new bio-engineering industry is little regulated and there is a potential for unintended catastrophic consequences to human health, agriculture and the environment.

(1) Testimony before the US House of Representative Committee on Agriculture, February 22, 2000 by Craig Weaver of Callaway Vineyards anticipating multimillion dollar losses.

(2) Communication with CDFA staff, Temecula vineyards, including Calloway and Mount Palomar.

(3) Kern County has little Pierce’s Disease even though “high populations [of glassy-winged sharpshooters] on citrus and adjacent vineyards were seen in southern Kern county [since 1998 and 1999].” see www.cnr.berkeley.edu/xylella/central-valley-guidelines p.1.

(4) Napa has high losses due to Pierce’s Disease, yet Napa has no known glassy-winged sharpshooter populations.

(5) See photos in attachment (4) showing newly planted vines within approximately 15 feet of citrus orchards, 2-year old vines and ten to twenty year old vines next to citrus.

(6) Communication with Riverside Agricultural Commissioner’s office and the Riverside Farm Bureau regarding “hot spots”. Also, see quotes from Temecula growers in “Tale of Two Valleys; growers in Temecula and San Joaquin Valleys...”, by Jim Steinberg, The Fresno Bee, May 28, 2000: “...some blocks [of vines] suffer 80% damage, a virtual wipeout, and others just 1%”; and “Some growers report improved vines and decreased infestation this year in Temecula Valley compared to last”, and a grower “had expected to see worse damage this spring...[and]...was pleasantly surprised that his vines look healthier than expected. He couldn’t explain why...”

(7) See above, and communication with central valley organic growers regarding health of soils and strength of natural immune system and irrigation practices, namely abrupt shutoff of irrigation causing severe stress to vines. See Pierce’s Disease in the North Coast, www.cnr.berkeley.edu/xylella.: “The symptoms of PD [Pierce’s Disease] can easily be confused with other diseases or phenomena that cause water stress, such as insufficient soil moisture or excessive salt concentrations” Agents causing similar symptoms as PD are: Eutypa; Oak root fungus; Measles; Phylloxera; Drought-induced early Spring boron deficiency; Late Spring boron deficiency; Salt in soil; Zinc deficiency, op cit.

(8) “It [the glassy-winged sharpshooter] has been seen in high numbers in citrus along the coast of southern California since the early 1990’s” see www.cnr.berkeley.edu/xylella/central-valley- guidelines p.1

(9) See “Pierce’s Disease in the North Coast” www.cnr.berkeley.edu/xylella/pd97, p.4: “In general, the disease is rarer and less severe in areas that are further north, more inland from the ocean or at higher altitudes. The geographical distribution of PD [Pierce’s disease] on grapevines appears to be related to the ability of the bacteria to survive winter temperatures. The effects of low winter temperatures on bacterial survival are not well understood.”

(13) See USDA Office of Pest Management Policy Crop Profiles, citrus and grapes. “Several natural enemies of the grape leafhopper are considered important in biological control strategies.Use of broad-spectrum insecticides can negatively affect these natural enemies and may exacerbate a leafhopper problem”. “Hormoligosis” refers to stimulation of the reproductive system that accompanies exposure to low levels of toxic substances. CDFA staff verbal report regarding spray program indicating that homes were sprayed in the vicinity of glassy-winged sharpshooter finds scattered over a half-mile area.

(14) It is known that “vineyards within ½ to 1 mile of citrus and avocado groves are at greatest risk”, Central Valley guidelines, op.cit. p.1. Why then plantings next to citrus groves? See photos attachment (4).

(15) Positive identification of the bacteria can be made by three tests: culturing the bacteria in selective media; enzyme linked immunosorbent assays; or polymerase chain reaction. Commercial labs can make the determination.

(16) To the best of our knowledge, there is no strict or comprehensive program to certify that vines are free of bacteria prior to sale. Communication with commercial nurseries selling grapevines revealed that the “blue tag” certification by the Department of Agriculture certifies the vine free from the vector (sharpshooter), but does not guarantee that the plant is not already infected. Advice from UC Berkeley: “If fall budding is done with fresh budwood make sure the buds come from a non-infected vine. Late-season infections in vines are symptomless. To ensure that a vine is free of bacteria, collect wood samples and test for the presence of bacteria.” www.cnr.berkeley.edu/xylella.

(17) Advice by Dr. Alexander (Sandy Purcell) to growers at meeting in the fall of 1999 at the Sonoma County Agricultural Commissioner’s office not to plant in Pierce’s disease prone areas. Nevertheless, in Sonoma County, the wine industry and the local Farm Bureau fought vigorously the imposition of buffer zones to riparian vegetation and neighboring residential landscaping, even though those areas can harbor sharpshooter vectors that can carry the xylella bacteria. The controversial Sonoma County Hillside Ordinance passed in 1999/2000, has only 25-50 foot buffer zones between vineyards and creeks, and no buffers between vineyards and residences. The issue remains, growers are planting in high risk areas, then lamenting their “losses” and supporting imposition or shifting the burden, exposure and risk on the public.

Furthermore, Vinifera cultivars “vary markedly in level of field resistance and tolerance”... “Some vines infected during the season appear to recover from PD the first winter following infection. Recovery from PD depends on variety. In Cabernet recovery is high while in Barbera, Chardonnay and Pinot Noir it is low. In more tolerant cultivars, the bacterium spreads more slowly within the plant than in more susceptible cultivars.”... “Rootstock species and hybrids vary greatly in susceptibility. Testing of rootstock plants show that V. riparia is rather susceptible, V. rupestris (St. George) and 420A are very tolerant.”... www.cnr.berkeley.edu/xylella

Most Susceptible	Less Susceptible	Most Tolerant
Barbera	Cabernet Sauvignon	Chenin Blanc
Gray Riesling	Gray Riesling	Sylvaner
Mission	Merlot	Ruby Cabernet
Pinot Noir	Napa Gamay	White Riesling

(18) According to a Nursery Industry representative, nurseries are required to have sharpshooter traps every half acre whereas vineyards have traps only every 250 or so acres.

(19) CDFA staff report confirmed by Kern County Agricultural Commissioner’s office.

(20) See Material Safety Data Sheet for Carbaryl, page 1, “Other ingredients (Trade Secret)”. DPR representative to the Environmental/Public Health Task Force agreed that the “full product” is tested in only a portion of the tests. The bulk of the testing is on the active ingredient only, which ignores the potential hazard of the secret unknowns.

(22) Contact Northwest Coalition for Alternatives to Pesticides for confirmation.

(23) See Material Safety Data sheet for Carbaryl; also Diminishing Returns: Salmonid Decline and Pesticides, Oregon Pesticide Network, For pollinator problems see the USDA report we are facing an “impending pollination crisis”, and see the Forgotten Pollinators Program at the Arizona-Sonora Desert Museum.

(24) See DPR records for Section 18 exemption from labelling requirements. I believe Admire was not approved for systemic application on citrus, hence the need for the Section 18 exemption for the experiment with imidacloprid on citrus groves in Temecula.

(26) See Dr. B Kirkpatrick, UC Davis, Dep’t of Plant Pathology, Bidder’s Response Form, American Vineyard Foundation (AVF) Long Term Proposal, “Transformation and Molecular Analysis of Xf [xylella fastidiosa], pp11-13.