Herbicides: The Tools of the Trade
On April 20, 2010, at the meeting of the Board of Directors of the East Bay Regional Park District (EBRPD), the District’s “Wildfire Hazard Reduction and Resource Management Plan” was approved. Nearly half of the speakers were critical of the Plan and asked for a variety of revisions to address their concerns. The most frequent criticism was that the implementation of the Plan would require increased use of herbicides to prevent the regeneration of the eucalypts proposed for removal. This criticism prompted supporters of the Plan to say that eucalypts cannot be killed without using herbicides.
We believe it is true that many non-native plants and trees cannot be eradicated without the use of herbicides. The use of herbicides in projects called “restorations” strikes us as ironic. In what sense is the land “restored” which has been doused with herbicides? How does a project that is dependent upon herbicides manage to bill itself as being beneficial to the environment?
The Indestructible Eucalyptus
Eucalypts resprout from their roots when they are destroyed for any reason. If they burn in a fire, die back in a freeze, or are cut down, they will resprout unless they are poisoned. The stumps must be sprayed within minutes of being cut so that the poison is absorbed into the roots of the tree. The herbicide being used presently for this purpose is Garlon with the active ingredient triclopyr.
Those who are responsible for application of the herbicide claim it is “painted” on the stumps, implying that this method of application eliminates drift of the herbicide into air and soil. This description of the application method is contradicted by the manufacturer of the herbicide, DowAgra. The manufacturer describes the method of application: “Treat the exposed cambium area and the root collar (exposed bark on the side of the stump) down to the soil line. Be sure to treat the entire circumference of the tree. To ensure effective control on large trees, also treat any exposed roots (knees) that surround the stump.” This method is illustrated on the manufacturer’s website by a person holding a spray applicator.
More recently, East Bay Regional Park District has claimed that an initial application of Garlon immediately after tree removal is “95% effective” to kill the tree and prevent its regeneration. This claim is contradicted by other sources of information, including EBRPD’s own Wildfire Plan which says, “Follow-up treatments of respouts with foliar applications of triclopyr or glyphosate [Roundup] in 2% solutions are usually necessary for complete control.” (Appendix G, page 16) And “…implementing additional treatments are critical to prevent stump sprouting.” (page 167)
Definitive evidence of the need for repeated applications of herbicides for many years is contained in a letter submitted in support of an application for a FEMA pre-disaster mitigation grant (obtained by FOIA request; therefore in the public domain). This grant application was submitted jointly by UC Berkeley, EBRPD, and the City of Oakland. The letter regarding requirements for herbicide applications was written by the Associate Director of UCB’s Physical Plant to UCB’s manager of the “vegetation management project.” The letter describes the requirements for herbicide follow-up as follows:
“This project will involve the removal of the eucalyptus…Ongoing maintenance for the next ten years is to ensure that the eucalyptus does not re-sprout (coppice) from cut stumps and to ensure that any seedlings from the latent seed stock are removed on a continuing basis, until the latent seed stock is exhausted. I would recommend that two chemical treatments be made to both sites each year for 10 years, with the objective of treating sprouts with herbicide. A basal bark treatment is recommended for the resprouts and a low volume foliar spray is recommended for seedlings.” (emphasis added)
The author of this letter estimates that the cost of these repeated applications of herbicide will be $273,410 to prevent regeneration of eucalypts on only 111 acres. However, cost is not our primary concern on Million Trees. Our concern is that the eradication of nearly a half million eucalypts on the properties of UC Berkeley, East Bay Regional Park District, and City of Oakland will require a great deal of toxic herbicide to accomplish.
What do we know about Garlon (triclopyr)?
Few studies have been conducted on triclopyr, but what is known about it is alarming. The federal government requires the manufacturers of chemicals to report the toxicity of the chemicals they produce in a standard format called Material Safety Data Sheet (MSDS). The MSDS for Garlon 4 Ultra states that it is a health hazard:
- “This product is a “Hazardous Chemical” as defined by the OSHA Hazard Communication Standard 29 CFR 1910.1200.”
- “Superfund Amendments and Reauthorization Act of 1986 Title III (Emergency Planning and Community Right-to-Know Act of 1986) Sections 311 and 312: Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard”
- “Triclopyr poses the highest risk to workers, the general public and most aquatic and terrestrial wildlife. The primary factor contributing to high human risk is dermal exposure from handling the chemical during applications or from vegetation contact.”
- “Triclopyr…[is] inherently more toxic to mammals. Triclopyr is particularly toxic to pregnant animals, causing severe birth defects in the fetus if the mother is exposed during pregnancy…Triplopyr…[is] an order of magnitude more toxic to birds than the other herbicides, and triclopyr is the most toxic of the five herbicides to bees…”
- “Although most of the field studies designed to measure triclopyr water contamination indicate that triclopyr will not run off in substantial amounts, actual monitoring data indicate that triclopyr contamination of waterways is occurring…In California, where triclopyr is used…11.5% of 227 samples contained detectable triclopyr.”
Nearly two years after this risk assessment was completed, Marin Municipal Water District has confirmed in writing that they are not presently using herbicides on MMWD properties.
The East Bay Regional Park District used 191 gallons of herbicides in 2008 according to its official Integrated Pest Management Report (IPM). Its use of Garlon has increased 325% from 2003 to 2008. Now EBRPD proposes to remove nearly one million eucalypts, which will require a huge increase in its use of Garlon.
Read more about Herbicides in other posts: