A Bold Initiative: East Bay Regional Park District should stop using pesticide

In preparation for writing the ballot measure that will renew Measure CC (the parcel tax that has funded park improvements since 2005), East Bay Regional Park District has invited the public to suggest projects for the parcel tax renewal that will be on the ballot in November 2018.  The park district must receive the public’s suggestions by the end of the December to be considered when they write the ballot measure at the beginning of 2018. 

The Sierra Club has submitted its requests to the park district for Measure CC projects, which are broadly described in this recently published column in the San Francisco Examiner.  The Sierra Club’s letter making these requests is available HERE:  Measure CC – from Sierra Club 2  

Million Trees is publishing the suggestion of Marg Hall and Jean Stewart for major investments in the park district’s Integrated Pest Management Program to achieve the ultimate goal of using no pesticides in the parks.

Million Trees

December 8, 2017

To:      publicinformation@ebparks.org

CC:      EBRPD Directors (blane@ebparks.org; wdotson@ebparks.org; drosario@ebparks.org; dwaespi@ebparks.org; ecorbett@ebparks.org; awieskamp@ebparks.org; ccoffey@ebparks.org)

Re:  Measure CC Comments/Proposals

Back in 2004, we both voted for Measure CC out of a desire to support the East Bay Regional Parks. At the time, we couldn’t have imagined that the euphemism “resource-related projects” meant funding the destruction of thousands of healthy eucalyptus trees and the subsequent application of pesticides. (1)  Had this fact been clearly stated, we never would have supported CC. We’ll present herein proposals for Measure CC expenditures which are designed to shift EBRPD to a no-pesticide policy.


A large segment of the local community opposes the use of public money to fund pesticide applications in our parks.  Jane Goodall has observed that humans are the only animal species that insists on spoiling its own nest.  It is self-destructive and unethical of us to poison our own nest, not to mention the homes of countless other species.  Historically, environmentalists have opposed pesticide use; however, the local Sierra Club chapter, in a departure from this tradition, insists that poison be used in East Bay parks to remove “invasive non-native plants.”  They invoke the benign-sounding term “restoration” to garner support for this ecological insanity.  Note that the San Francisco Bay Chapter has never permitted a vote by members on the question of pesticide policies.  In the face of their refusal to poll their own members, community activists conducted a survey of Sierra Club members.  Over 1,876 local members mailed in their response, of whom 1,851 expressed disagreement with their own leadership!  (25 expressed agreement.)  For perspective, that’s more respondents than vote in the chapter elections!  (In 2015, the candidate for Chapter Executive Committee with the greatest number of votes received only 1,139 votes.)


Pesticide regulation in the US is weak, compromised by a cozy relationship with manufacturers.  Pesticides have not been proven to be safe, despite approval of certain chemicals by the EPA.  Bear in mind that in the US, the benefit of the doubt is given to the pesticide maker–no precautionary approach here–so we really don’t know the full extent of damage.  Active ingredients are, of course, poisons, since they’re specifically designed to kill plants and animals.  But so-called “inert” ingredients are poisonous as well.

Among the EPA’s many regulatory failures is the fact that, for the most part, “inert ingredients” get a pass.  Pesticide formulations (e.g. Roundup) contain chemicals intended to increase potency.  Agricultural pesticides contain more than 50% inert ingredients.  Independent scientists investigating the safety of inert ingredients have uncovered evidence of harm that should be of great concern, including many hundreds of hazardous chemicals, carcinogens, and even chemicals considered to be active ingredients when used in a different product. (2)

DDT provides an illustrative cautionary tale. While it was banned in the US in 1972, DDT continued to be used in pesticides as an “inert” (!) ingredient, in a product named Kelthane. (3) This continued for TEN years! Even though DDT (and DDE, its metabolite) is a potent endocrine disruptor, the causal link to breast cancer has been hard to establish.  Among the reasons for this is that breast cancer’s long latency period made such research challenging. Just two years ago the results of a large study conducted by Kaiser Oakland were released. (9,300 women with a 54-year follow-up.) Blood levels of pregnant women were tested between the years 1959 and 1962. Female offspring of those who tested with high DDT levels were 4 times likelier to develop breast cancer by age 52, compared with controls. (4) Women are still paying the price for the regulatory failures of the past. Don’t you owe it to future generations to ask yourselves what other time bombs lurk in the chemical poisons you spread?


EBRPD often uses glyphosate (aka Roundup), long touted as extremely safe by manufacturers.  In 2015, the World Health Organization declared glyphosate to be a “probable human carcinogen.”  However, merely focusing on Roundup can lull us into believing that the solution lies in banning glyphosate.  This naive thinking fails to take into account the legions of newer and less-scrutinized pesticides lining up to take Roundup’s place in a game of poison whack-a-mole.

Pesticide Application Notice, Heron’s Head, 2012

Two projects which were funded by Measure CC “required” pesticides: triclopyr (Garlon) to prevent the re-sprouting of eucalyptus trees, and imazapyr (Polaris) to remove the “non-native” grass Spartina along San Francisco’s Bay shoreline.   EBRPD’s own literature counts among successful CC projects: “Marsh cleanup at Martin Luther King Jr. Regional Shoreline, including Clapper Rail habitat enhancement and Spartina control” as well as “restoration of grasslands…at Pt. Pinole Regional Park”. (5) Based on your own reports, Spartina control projects have required the application of hundreds of gallons of imazapyr, some by aerial spray.

Imazapyr is toxic to fish, aquatic organisms and bees. Water soluble, it’s highly mobile and persistent; in one Swedish study, it was detectible in ground water eight years after application. (6)

As for triclopyr, much of the information has not been publicly shared. Thus scientists’ ability to conduct a well-informed evaluation of its safety is limited. We do know, however, that it significantly increases the frequency of breast cancer in both rats and mice. Despite this finding, the EPA has violated its own guidelines by refusing to classify this chemical as a carcinogen. We also know it has an adverse effect on frogs at very low exposures, and it causes documented harm to birds, fish, beneficial insects, and non-targeted plants. (7)

We can’t afford to wait 50 years to know a pesticide’s full effect. Especially now, under the current administration, corporations and politicians not only bully scientists but are systematically destroying the EPA.  Now more than ever, local communities urgently need to rise to the occasion. This is where you come in.


Though she was writing about agricultural pesticides, Sandra Steingraber throws down a highly relevant challenge:

“I believe it is time for a new human experiment. The old experiment…is that we have sprayed pesticides which are inherent poisons…throughout our shared environment. They are now in amniotic fluid. They’re in our blood. They’re in our urine. They’re in our exhaled breath. They are in mothers’ milk….What is the burden of cancer that we can attribute to this use of poisons in our agricultural system?…We won’t really know the answer until we do the other experiment, which is to take the poisons out of our food chain, embrace a different kind of agriculture, and see what happens.” (8)

We propose a bold initiative. You’ve created an admirable IPM program; why not build on it by taking up Steingraber’s challenge? Use CC funding to make a commitment to a “no pesticide” policy. This would provide national leadership at a time when it is desperately needed. 

Here are some practical suggestions to that end:

Expand IPM funding: Give staff the resources they need to innovate.

Go Deep: “Invasive” plants are not a problem to be eradicated but a symptom of an underlying dysfunction. Hire experts who can help you develop holistic solutions to ecosystem imbalances. Two who come to mind are Tao Orion (author of Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration) and Caroline Cox (Center for Environmental Health). (9) Send your IPM staff to the yearly Beyond Pesticides conference.

Adopt the Precautionary Principle, which is based on the understanding that decision-makers have a social responsibility to protect the public from harm. The burden of proof of the harmlessness of a proposed action shifts from poison-manufacturers to…you.

Red-tailed hawk nesting in eucalyptus. Courtesy urbanwildness.org

Plant tall trees: Having already cut thousands of living tall trees, you’re now faced with the reality of climate change. Reforestation becomes an urgent ethical imperative. Tall trees are not only carbon sinks; they also capture fog, provide raptor habitat (thus eliminating the need for rodenticides), and provide natural, nonchemical undergrowth suppression, especially in those same areas where you’ve been reapplying pesticides over and over, in a futile attempt to kill “weeds”. And of course, it goes without saying: no more cutting of healthy trees, young or old!

Experiment: Expand your existing programs of experimental plots testing various pesticide-free approaches to management of “invasive” or “opportunistic” plants.

Avoid “Restoration”: These projects almost always involve pesticides which damage the soil and many non-targeted plants and animals. If a goal can’t be achieved without them, it’s not worth doing. Restoration projects should be based in science rather than prejudice. Tao Orion’s chapter on Spartina eradication compellingly makes this case. (10)

Embrace change: Rigid nativism has no place on this planet, whether applied to humans, plants, or animals. Once you begin to appreciate those resilient plants and animals that have managed to adapt to each other in a new environment, you’ll stop fretting over their immigration status, and you won’t be so tempted to employ pesticides.

Jean Stewart, El Sobrante, CA
Marg Hall, Berkeley, CA

NOTE: Both authors have had cancer. Jean Stewart, a botanist, acquired cancer as a result of exposure to herbicides while handling them in a lab. Her tumor required several surgeries, leaving her disabled. Marg Hall reports: “I was diagnosed with invasive breast cancer in 2015. While I don’t know my mom’s blood levels of DDT when I was in her womb, there are still detectable levels of DDT in my household dust—45 years after it was banned from use!”


  1. Full text of Measure CC (July 20, 2004) and Approval of Spending Plan (Aug 3, 2004), Section 5, “Use of Tax Proceeds.” http://www.ebparks.org/Assets/Features/Measure+CC/fulltextmeasurecc.pdf
  2. Orion, T., Beyond the War on Invasive Species: A Permaculture Approach to Ecosystem Restoration (Chelsea Green Publishing, 2015), p.26. Also, Cox and Surgan, “Unidentified Inert Ingredients in Pesticides: Implications for Human and Environmental Health,” Environmental Health Perspectives (2006): 1803-1806. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1764160/
  3. Vallianatos, E.G. & Jenkins, M., Poison Spring: The Secret History of Pollution and the EPA (Bloomsbury Press, 2014), ch.4.
  4. Cohn, B. et al, “DDT Exposure in Utero and Breast Cancer,” The Journal of Clinical Endocrinology and Metabolism, August 2015, vol. 100, Issue 8. “DDT Exposure in Utero and Breast Cancer.”
  5. http://www.ebparks.org/Assets/Agendas+Packets+Minutes/3.+Park+Advisory+-+Committee+Meetings/06-26-2017/06-26-2017++-+Park+Advisory+Packet.pdf (see Attachment 2, p. 2)
  6. Correspondence from Beyond Pesticides (a nonprofit in Washington, DC, founded in 1981) to Massachusetts Dept. of Agricultural Resources, Feb. 18, 2014, pp. 7-8
    http://www.beyondpesticides.org/assets/media/documents/NSTAR 2014 YOP Comments 2-18-2014.pdf
  7. For a detailed independent review of triclopyr, see Cox, C., “Herbicide Factsheet: Triclopyr”, Journal of Pesticide Reform, Winter 2000, Vol. 20, No. 4
    And here’s a helpful pesticide directory:
  8. Steingraber, S. quoted in President’s Cancer Panel Report: Reducing Environmental Cancer Risk: What We Can Do Now; April 2010, Section 2, page 45. Read the President’s Cancer Panel’s Report.
  9. Cox, C. “Band-Aids Are Not Enough,” Journal of Pesticide Reform, Spring 1997, Vol. 17, No.1
  10. Orion, T., Ibid, Ch. 2

American law prevents Canadians from reducing pesticide use

Here is a letter to the editor of the New York Review of Books, February 7, 2013:

“Dear Editor,

Tim Flannery in his review of the Biography of Rachel Carson makes one mistake and that concerns pesticide use reductions in Canada [“A Heroine in Defense of Nature,” NYR, November 22, 2012].  The first Canadian province to ban the ‘cosmetic’ use of specified pesticides and herbicides—i.e., for gardens and flowers, and not for commercial crops—was not Ontario (2009) but Quebec (2006).

This was the result of grassroots activity at the local, municipal level and it was backed by a national organization, the Campaign for Pesticide Reductions (CPR!), of which a leading sponsor (surprisingly perhaps) was the Canadian Labour Congress.  The ban was backed by the Canadian Cancer Society, the first of many moves in the direction of cancer prevention, versus cancer treatment and research.  Quebec’s move to ban the sale as well as the use of these products was a violation of the federal authority over commerce and it resulted in a challenge under the North American Trade Agreement (NAFTA, Chapter 13).

Some of Rachel Carson’s aims over pesticide use reduction could be achieved by a statute requiring the practice of Integrated Pest Management (IPM), which properly interpreted results in the avoidance, or use reduction, of synthetic organic chemical pesticides wherever possible.  Canada, like most countries has not done this:  pesticide registration or licensing is easy to get and once a pesticide is on the market, it is very difficult to prevent its proliferation or remove it from the environment.  But unlike many Canadian environmental measures, the bans so far on the cosmetic use of pesticides are truly progressive.”

David Bennett

Former Director

Health, Safety and Environment

Canadian Labour Congress

Ottawa, Canada

The North American Trade Agreement is a free trade agreement between the United States, Canada, and Mexico.  If you want to do business with the United States, you apparently are not allowed to ban the sale and use of pesticides. 

San Francisco’s misnamed Integrated Pest Management policy

This seems a timely reminder of the difficulty of changing public policy regarding pesticide use.  For the third year in a row, San Franciscans recently attended the annual hearing at which the city’s pesticide policy is renewed by the Environment Commission.  Citizens reported the escalating use of toxic pesticides in San Francisco’s public parks by the so-called  Natural Areas Program.  They also repeated their annual request that pesticides considered “Most Hazardous” (Tier I) and “More Hazardous” (Tier II), not be sprayed in public parks.

Volume of pesticide use by San Francisco's "Natural Areas Program."  Courtesy San Francisco Forest Alliance
Volume of pesticide use by San Francisco’s “Natural Areas Program.” Courtesy San Francisco Forest Alliance

Once again, the public’s request fell on deaf ears.  In fact, the only changes to the city’s pesticide policy liberalized the use of pesticides by the Natural Areas Program.  Milestone which had been rated “Most Hazardous” in the past has now been downgraded to Tier II.  This is the pesticide that is mobile in the soil and persists in the soil for a long time.  It is banned by the state of New York for sale or use because of concerns about the potential of poisoning ground water.  Yet it is used in San Francisco in the watershed to Islais Creek.

Also, Garlon (Tier I) can now be sprayed without the applicator wearing a respirator, which will make it easier and more likely to be used in the future.

However, these two revisions of the city’s pesticide policy pale in comparison to the recent decision of the Recreation and Park Department with respect to promoting the use of pesticides in the city’s parks.  The Recreation and Park Department recently announced that the person in charge of the Natural Areas Program is now also in charge of the Department’s pesticide use.  This inappropriate decision effectively removes all pretenses that the Natural Areas Program’s use of pesticides is being monitored or supervised.  The Natural Areas Program is now free to use pesticides wherever and whenever they wish.

Mr. Bennett makes a mistake in his letter to the editor.  He assumes that an Integrated Pest Management policy would avoid or at least reduce pesticide use.  San Francisco calls its pesticide policy an Integrated Pest Management program.  That policy has obviously not reduced pesticide use in San Francisco’s parks.  In fact, it seems to facilitate the use of pesticides.  Pesticide use by any name is still pesticide use.