Integrated Pest Management is a sham!!

Many thanks to Marg Hall for this guest post about the pesticides being used by the supplier of our drinking water in the East Bay and for the research she did to inform the public that there is a BIG gap between written policies and the reality of pesticide use on our public lands.


One day last winter, I came upon a crew cutting down about 50 eucalyptus trees on what appeared to be EBMUD lands in the East Bay hills. (East Bay Municipal Utility District, EBMUD, manages the local drinking water lands and infrastructure.) Knowing that rain was predicted, and that the standard procedure is to apply the nasty herbicide Garlon to the cut tree stumps to prevent re-sprouting, I stopped to ask the workers about the job.  The contractor (Expert Tree Service) refused to answer my questions, even the most basic one: who hired them?

Tree removals done by EBMUD on Grizzly Peak Blvd
Tree removals done by EBMUD on Grizzly Peak Blvd (prior to the incident reported by Marg Hall)

I thought it an especially bad idea to apply Garlon in the drinking water watershed during the rainy season, so I stopped them by simply refusing to leave the work area until I got some answers. It was easy. I was polite but firm. The police were called. After being threatened by the contractor with per-minute fines for delaying the work, and a trip to jail from the police, I left them to their destruction. This is how I became interested in the management of EBMUD lands.

On a personal note, I had just been diagnosed with breast cancer. Ironically, I’d been looking for hiking trails where I didn’t have to confront the risk of cancer-causing pesticide applications. The whole situation made me very grumpy.

Following up, I was assured by EBMUD staff that they do NOT allow contractors to apply herbicides to cut eucalyptus stumps, and that very few, in fact almost no, herbicides are used in the drinking watershed lands. OK, that sounded pretty good. Wanting to verify this claim, I filed a public records request to EBMUD.

Aerial spraying pesticides on public parks

Meanwhile, we (FAB, The Forest Action Brigade, a grass roots group with which I am affiliated) heard of a plan by East Bay Regional Park District (EBRPD) to aerial spray from a helicopter (yes, you read that correctly!) an herbicide named Milestone (which is prohibited for use in New York State because it is very persistent and mobile in the soil). This was to be done in Briones Park, an area that directly supplies two creeks that feed into the Briones water reservoir.

Mobilizing public support, we were able to stop that spraying, but among our growing concerns we now added the safety of our drinking water. Even though this spray was planned by the East Bay Regional Parks District (EBRPD), the staff from the Water District (EBMUD) knew about it, and didn’t try to stop it…until we raised the issue.

Management of wastershed land by supplier of our drinking water

Last summer, EBMUD invited public comment on a draft update of their Watershed Management Master Plan. In this document, an Integrated Pest Management (IPM) program was referenced (available here: ebmud-ipm-program). Curious, we obtained copies of this document.

On paper it looks pretty solid. Like most IPM programs, this one contained written assurances that only minimal pesticides will be used, and then only as a last resort. Quarterly meetings of the IPM committee would provide oversight, meet and compile reports of pesticide usage. Among committee goals are: approve pesticide use requests, ensure consistency among work groups regarding pest management, and advise on pest management strategies. The guidelines require that pesticides be used only after certain damage thresholds are reached, with follow-up evaluations of effectiveness, and documentation of adverse side effects on non-targeted organisms.

Reading this leads one to the conclusion that the land management practices are just a step below organic gardening practices. With such controls and alternatives, what could possibly go wrong?

Control of pesticide use is more theoretical than real

As I soon learned when I started asking for public records, the IPM program as outlined in the EBMUD Watershed Management draft plan is a “paper only” plan. The oversight committee has not met in 15 years, and in fact only actually met for several years (the program started in 1996). There has been no oversight, no annual report, and wildly inconsistent use has developed over the various work units at EBMUD. They do follow minimal state reporting and training requirements, but that’s it.

I found no comprehensive evaluation of pesticide use, no analysis of levels of use, or experiments with alternatives, as one would expect in an “integrated” approach. Instead I received pages and pages of daily logs by individual workers documenting pesticide use. There appear to be no restrictions on use as long as the applicators documented applications, and the pesticides used were on the approved list of pesticides. The list of approved pesticides is long and includes known carcinogens.

Since nobody at EBMUD was keeping track, several of us embarked on a labor-intensive project to sort through records ourselves and tally an annual pesticide total. We focused on EBMUD properties in Alameda and Contra Costa Counties and usage for the year 2015. We were disheartened by our findings. In these areas, EBMUD made 647 applications by truck, backpack or by hand of herbicides totaling over 700 gallons and 205 pounds.

We compared the use of pesticides by EBMUD with those used by EBRPD.  EBRPD used significantly less herbicide than EBMUD in 2015. EBRPD used 193 gallons of herbicide (glyphosate, Garlon, Oryzalin) in 2015 (and smaller quantities of specialty herbicide for specific projects).  EBRPD has 120,536 acres of property compared to only 28,000 acres of EBMUD property.

Many environmentalists concerned about pesticide use had thought EBMUD carried out a more environmentally respectful philosophy of land management. This is not true. While the Watershed and Recreation work unit reported using only 8 gallons of pesticides that year, they constitute only one of several work units. EBMUD staff in the Watershed and Recreational work unit believe that is the sum total of pesticides used in “the watershed” and that pesticide usage is low. While some of the maintenance operations are outside of the drinking water watershed lands, some are not. Nevertheless this distinction is meaningless since all land is a “watershed” whether it drains to Briones reservoir or the San Francisco Bay. Furthermore, applications of pesticide are routinely done in areas open to the public.

One such application was documented last fall by someone walking on a public road in her neighborhood who took this video (If the video won’t play for you, try clicking on this link to the video HERE:

In it you see vast quantities of Roundup (glyphosate), applied from a truck-mounted tank using a garden hose. That method of application explains why the volume of EBMUD’s pesticide use is so high.  Competent and responsible pesticide applicators use a spray nozzle to reduce the flow and spread the herbicide more evenly.

Inexplicably, the worker was soaking bare ground along the side of a road. It is pointless to apply Roundup to bare ground.  It is a foliar spray that must be applied to actively growing plants.  It has no effect on seeds, roots, or tubers in the ground.  This is explained clearly on the manufacturer’s label for the product.

This spraying was done in a residential neighborhood (Carisbrook Road, Montclair area of Oakland). No pesticide application notices were posted before, during or after the application in violation of EBMUD’s IPM guidelines, which say, “If there is likely to be public contact with the area to be sprayed with pesticide, adequate notification or posting should be conducted.”

Carisbrook Reservois on Carisbrook Road in Montclair, Oakland, where pesticides were sprayed by East Bay Municipal Utilities District
Carisbrook Reservoir on Carisbrook Road in Montclair, Oakland, where pesticides were sprayed by East Bay Municipal Utilities District

The video was sent to EBMUD board members. EBMUD’s response was a defense of this application as consistent with existing policy and regulation. They also claimed that the herbicide was not sprayed on a pedestrian path.  In fact, the spraying occurred on a public road in a residential neighborhood that was used as a path by those who live in the neighborhood, such as the woman who recorded the video.

How to achieve REAL control over pesticide use on public land

That raises the obvious question: if this pesticide application is acceptable, what good is an IPM program except as a means to mislead the public into thinking we are being protected?

There’s an easier, simpler way to obtain the kind of protection we need: Forget IPM. Institute a total ban. No pesticides.  PERIOD.  It can be done.

Marin Municipal Water District has banned all pesticide use on their properties.  Organic farmers do it. Why not demand this from our local land managers?

Public Policy is in OUR hands

In recent decades, public land managers have been using public tax money to apply more and more pesticides in public spaces. In the years ahead, as the Republicans dismantle the Environmental Protection Agency, destroying what little (pathetic) regulation that we now have, we local activists will need to do our own protecting.

It starts here, in our own backyards. We know there is tremendous popular support for this. People really don’t like to be exposed to pesticides when they visit public parks. Robust local activism is our only hope. Yes, we can!!

Marg Hall