Valdez, Anthony E (ENV)
From:
Sent:
To:
Cc:
Subject:
Svetlana Savchuk
Monday, August 08, 2016 9:27 AM
Valdez, Anthony E (ENV)
Geiger, Chris (ENV); Raphael, Deborah (ENV)
Public comment on item 5 on the agenda of Policy Committee of the Commission on the
Environment.
Dear Commissioners,
San Francisco is supposed to be a "green city" - only it isn't - using the most toxic herbicides in parks
for many years.
According to the San Francisco Forest Alliance research - based on compiled individual application
data obtained via sunshine requests - the use of Toxicity Category I & II herbicides in "natural"
areas measured by active ingredient increased by more than 400% from 2009 to 2013. It went
slightly down in 2014 and in 2015, but is still about 200% more than it was in 2009:
http://sfforest.org/category/applies-pesticides/
San Francisco claims to adhere to the precautionary principle - only this is a lie.
The herbicides used in San Francisco parks - "natural" areas in particular - have been linked to many
health problems, including cancer, birth defects, infertility, neurological issues.
But they are still being used.
On July 21st three areas of Mt. Davidson were sprayed with Milestone (aminopyralid) used against
French broom, and Polaris (imazapyr) used against cape ivy.
Cape ivy is VERY easy to pull out.
Milestone stays in the environment forever.
It is so persistent that if it’s sprayed on plants, and animals eat those plants, it doesn’t break down.
Animals excrete the stuff in their droppings - if those are composted — it still doesn’t break down the
chemical - the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the
compost, it kills them.
The chemical will be on Mt Davidson for years to come.
On June 28th Roundup (glyphosate) was sprayed in Glen Canyon:
https://vimeo.com/172661568
The plants sprayed in Glen Canyon this time are called "native." One of them, Sticky monkey flower,
is a protected "native" plant.
Glyphosate was classified as "probable carcinogen" by the WHO last year.
Poisoning of our parks should stop. Use of toxicity category I & II herbicides on city properties should
be banned.
1
Sincerely,
Svetlana Savchuk & Valentin Ignatovski
2
From:
To:
Cc:
Subject:
Date:
Attachments:
Dee Seligman
Valdez, Anthony E (ENV)
Raphael, Deborah (ENV); Geiger, Chris (ENV); Deepak, Lavanya (ENV)
please distribute to Commissioners
Monday, August 08, 2016 1:56:22 PM
letter from SFFA_pesticide definitions_4_22_16.pdf
Hi Anthony,
If you could get this letter to the three members of the Policy Committee today, and to the
remaining Commissioners, I would certainly appreciate it.
Sincerely,
Dee Seligman
To:
CC:
SF Environment Commission
c/o Anthony Valdez [email protected]
Chris Geiger [email protected]
Deborah Raphael [email protected]
4/22/16
From: Dee Seligman, Interim President SF Forest Alliance
Subject: 2016 Reduced Risk Pesticide List
Commissioners,
While we are disappointed the 2016 List still allows the use of Tier 1 and Tier 2 pesticides in our
parks, we do think the List and its related documents are a big step forward. During the
development of the List we tried to draw attention to ambiguous language contained in it and the
Restrictions document. Some issues were addressed, but much of the language in the final
documents remains open to interpretation.
When you voted to adopt the new List, you had an understanding of its intent. The problem is,
land managers, pesticide contractors and the public can come away with very different
interpretations after reading the documents. We would ask that a supplementary document be
created that defines terms, further explains the intent of individual restrictions and brings
together all of the rules in one working document.
Below are the areas where we feel the value of the documents are compromised by uncertainty
in the language.
Conditions of use for “most hazardous” herbicides
General requirements
1.
All treated areas must be clearly noticed, marked and identifiable for four days after the
treatment. Blue indicator dyes must be used for spray treatments.
Page 3 of “Compliance Checklist for City Properties” of which this document is a part, calls for
posting “at least 3 days before application and for at least 4 days after.” The clause above says
nothing about the 3 day preposting requirement. All of these requirements should be gathered
into one location. The Checklist is posted here:
http://sfenvironment.org/sites/default/files/fliers/files/sfe_th_ipm_checklist_2016_rrpl_2016-0328.pdf
Page 3 of “Compliance Checklist for City Properties” requires the posting to be:
Enclosed area: Post at every entry point of application
Open area: Post in highly visible locations around the perimeter.
Again, all of the requirements should be gathered into one place.
With respect to parks, we believe the intent is to alert people as they enter a park that a hazard
is present and further to prominently identify the specific area the pesticide has been applied.
As an example, current practice on Mt Davidson is to post signage at the park entrances. This
achieves the first objective. However, the specific areas where the pesticide is applied can not
be discerned by the public.
The posting signage should include a color sample of the blue dye so people will know what to
look for. The dye must not be so persistent that it is still visible weeks later. Otherwise it will
lose meaning.
5.
No use within 15 feet of designated, actively maintained public paths.
In order for this restriction to have any meaning, the pesticide applicators and the public this
restriction is intended to protect, need to know which paths and trails are “designated, actively
maintained public paths”. For paved paths this is not an issue but earthen trails are
problematic.
The only way for applicators to know where they can spray and for the public to know how to
avoid exposure, is if maps of the protected paths are published by the land manager and readily
available to the public. We would ask that you require RPD to publish such trail maps.
It is disappointing this protection is only extended to “designated” trails. If a trail exists, it is
because people use it regularly. It seems punitive to exclude social trails from this protection.
Those trails may see just as much use as the “designated” trails.
6.
No broadcast spraying is permitted, except for targeted treatments at Harding Park golf
course in preparation for tournament play.
What is “broadcast spraying”? An internet search returns definitions like “to distribute evenly
over a given area”, or “distribution of an agricultural chemical product uniformly over the entire
area to be treated and not just to portions of an area” or “broadcast applications consist of
applying a spray solution uniformly over the entire treated area”. At the April 7 IPM TAC meeting
we were told that broadcast spraying was not defined by the end result, but rather than by the
type of equipment used to achieve it. It is only broadcast spraying if it is delivered by a vehicle
with a large volume tank and multi-nozzle booms.
If the end result is blanketing an area of land with X ounces per acre of a Tier 1 pesticide, the
risk to the public is the same whether that is achieved using a truck with spray booms or
multiple individuals with backpack sprayers. The risk to the applicators is much greater if done
with backpack sprayers.
What is the intent here?
By the way, Australia has a great supplement to their regulations, an extensive definition of
terms:
http://apvma.gov.au/definition-of-terms/
There they address the definition of broadcast spraying quite explicitly.
7.
No use on the grounds of schools, preschools, children’s playgrounds, or other areas
frequented by children.
It would be good to start building an explicit list of “areas frequented by children” to prevent
mistakes from being made. Why force applicators to make a judgment call when many such
areas can be identified in advance? We would suggest including the following in addition to
those already listed:
Baseball, football, soccer and other play fields
Picnic areas
Community gardens
Areas around day camps, like Silver Tree in Glen Canyon
Areas frequently visited by school field trips like Heron’s Head Park
Allowed uses(only as method of last resort):
11.
Utility rights of way and watershed lands falling under state or federal vegetation
management requirements.
Is this intended to mean “utility rights of way and watershed lands where state or federal
regulations require that the vegetation targeted for pesticide application be controlled”?
For the 2017 iteration of the list we should ask, why are Tier 1 pesticides being used in the
watersheds that provide our drinking water?
13.
Landscape renovations, provided that weed prevention measures are put in place and
the treated area is fenced off for four days after treatment.
What is a landscape renovation? Does re-seeding a playing field constitute one? How about
replanting a flower bed? How about clear cutting a few acres of forest? As written, this
“allowed use” allows any use.
What are weed prevention measures? At the IPM TAC, examples were stated such as laying
down sheets of cardboard or applying mulch cover. This term should be defined.
Again, this restriction makes no reference to the 3 day pre-application posting requirement.
14.
Invasive species that pose a threat to local, native, rare, threatened or endangered
species or ecosystems, and which cannot be controlled by other means, except as
prohibited under the General Prohibitions section above.
The terms used above need to be defined in order to have meaning:
Invasive species – Is this from the list published by the California Invasive Plant Council? Does
it include all listed plants, or just those with a “high” invasiveness rating? We believe the original
intent was to prohibit the use of Tier 1 chemicals against plants of moderate and limited
invasiveness. At the IPM TAC there was a reluctance to explicitly define this.
Local – existing within 100 miles in the year 1769?
Native – existing within 1 mile in the year 1769?
Rare – why is this word here? What does it mean in this context?
Threatened – from what list?
Endangered -from what list?
If all one needs to justify use of Tier 1 pesticides is local, why do we also need native, rare,
threatened and endangered?
From the Reduced Risk Pesticide List as found on the Compliance Checklist for City Properties
at:
http://sfenvironment.org/sites/default/files/fliers/files/sfe_th_ipm_checklist_2016_rrpl_2016-0328.pdf
Page 10 Garlon 4 Ultra
Use only for targeted treatments of high profile or highly invasive exotics via dabbing or
injection. May use for targeted spraying only when dabbing or injection are not feasible.
What does “high profile” mean? That seems to be a “cosmetic“ term. Please define.
The California Invasive Plant Council ranks invasiveness of exotics as high, moderate or limited.
It should be defined that “highly invasive exotics” refers to plants catergorized by the Cal IPC as
high.
Does this language mean Garlon 4 may not be broadcast sprayed?
Page 9 Aquamaster
Shouldn’t this be limited to “highly invasive exotics” as Garlon is?
Page 11 Roundup Promax Herbicide
Shouldn’t this be limited to “highly invasive exotics” as Garlon is?
It seems the language for glyphosate has not been updated to account for it being moved from
Tier 2 to Tier 1.
Conclusion
A working document should be created to supplement the Reduced Risk Pesticide List, the
Compliance Checklist for City Properties and the Conditions of use for “most hazardous”
herbicides. This documentation is needed so pesticide applicators can perform their work
correctly and so the public can understand what protections are being afforded them. RPD
should be required to publish maps of designated actively maintained paths.
Question for SF Dept of Environment
Who approved, by what Committee and process, the Dept of
Environment recommendation to the SF DPW Refuse Rate
Baord, the use of $1 2-15 million for the Hay Road refuse
site?
SF DPW submitted a report to SF DPW Refuse Board on
June 24, 2016. There will be a public hearing on August 17
before SF Rate Board
SF Dept of Environment held a meeting at Hay Road
but there is no mention of the recommendation of
June 24 or its approval. Before approving
minutes of Hay Road meeting, I would like
to know whether that recommendation
was discussed at the Hay Road meeting,
or approved there, or if not, where it was
approved.
Edwin rvi Lee
SF Environment
Our home. Our city. Our planet.
Deborah 0. Raphael
Director
A Department of the Cty and County of Son Froncisco
MEMORANDUM
TO:
FROM:
RE:
DATE:
Refuse Collection and Disposal Rate Board
Jack Macy, Zero Waste Program, Department of the Environment
Status of Claims on Special Reserve
June 24, 2016
As requested by the Refuse Collection and Disposal Rate Board (Rate Board) at its December 16, 2015
hearing, the Department of the Environment (Department) is providing a report on any claims made against the
Special Reserve Fund (Fund) related to the Altamont Landfill Agreement. The Rate Board may reconvene in
the summer of 2016 to review this report and consider whether to make additional allocations from the Fund.
On October 30, 2015, the Department submitted a report to the Rate Board on the Fund created under the
1987 Waste Disposal Agreement for disposal of San Francisco refuse at the Altamont Landfill. At that time,
the Department anticipated that the City would reach the contract limit of 15 million tons in January 2016. The
Department’s report recommended that $3.75 million from the Fund be transferred to a new Landfill Disposal
Agreement Reserve Fund (New Fund) required under a new agreement to dispose of the City’s refuse at the
Hay Road landfill in Solano County. The $3.75 million represents the amount of funding needed over an 18month period to build the New Fund up to $10 million within four years, as required under the new agreement.
The Department also recommended transferring $12 million into the New Fund to cover the incremental cost of
transporting and disposing refuse at the new landfill for the same 18-month period, until July 1, 2017, when it is
anticipated new refuse collection and disposal rates would go into effect.
In December 2015, the Rate Board agreed in part with the Department’s recommendations. The Rate Board
approved: (1) transferring $1.25 million from the Fund to provide initial funding of the New Fund; (2)
transferring $12 million from the Fund into the New Fund to cover the incremental cost of transportation and
disposal under the new Landfill Disposal Agreement; and (3) retaining $16.35 million until the Rate Board
determines there is no need for the Fund. The Rate Board requested that the Department report on any
further claims against the Fund before approving additional funding for the New Fund.
On March 16, 2016, the Department sent a letter to Waste Management of Alameda County (WMAC)
confirming the termination of the 1987 Disposal Agreement between San Francisco, Recology and WMAC, as
the maximum disposed tonnage in that agreement was reached on January 15, 2016. The letter stated the
Department’s and Recology’s understanding that WMAC and its affiliates had no further rights or claims
against the City or Recology in regards to that agreement or against the Fund. The Department requested that
WMAC promptly advise the Department and Recology of any claims. The Department and Recology did not
receive any response to the letter or claims against the Fund since those shown in the Department’s October
30, 2015 report. The Department and Recology conclude that there are no more needs for the Fund under the
terminated 1987 Disposal Agreement.
The Department now recommends the transfer of an additional $2.5 million from the Fund into the New Fund,
which would bring the fund balance to $3.75 million as previously recommended. This would ensure that the
New Fund is on track to reach the required $10 million funding level within the first four years of the new
Landfill Disposal Agreement. Additional funding for the New Fund would be included in the next rate
application, which is anticipated in January 2017 for new rates to go into effect in July 2017.
San Francisco Department of the Environment
1455 Market Street, Suite 1200, San Francisco, CA 94103
Telephone: (415) 355-3700 • Fax: (415) 554-6393
Email: [email protected] • SFEnvironment.org
“ Printed onlOO% post-consumer recycled paper.
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K
As for the remaining balance in the Fund (an estimated $13.85 million after the proposed transfer of $2.5
million), the Department recommends no action at this time. Instead, these monies would remain in the Fund
until there is a new rate application from Recology. That application would include proposed uses of the
remaining balance for the benefit of current and future ratepayers, as specified in the Waste Disposal
Agreement.
Department staff will be available to answer questions of the Rate Board when it is reconvened, If you have
any questions, please do not hesitate to contact me at (415) 355-3751. Thank you for your consideration.
Resolutions for San Francisco Department of Environment
Environmental Policy Regarding use of pesticides
to minimize use and environmental risk
Recommendation 1.
It shall be the policy of the San Francisco Department of Environment
that environmentally hazardous pesticides such as Garlon shall not be used or
applied to control minor plants such as Oxalis.
Recommendation 2.
It shall be the policy of the San Francisco Department of Environment
that pesticides such as Garlon which may be more hazardous
during wet or moist conditions shall not be applied during a
period when rain or potential fog is likely in the area of
San Francisco.
Recommendation 3.
It shall be the policy of the San Francisco Department of Environment
that when potentially hazardous pesticides, including pesticides
more hazardous during wet or moist conditions, a San Francisco
employee shall post a contemporaneous notice showing a) date and time
when the pesticide was applied; b) date and time when the
San Francisco employee arrived on site of application; c) date and
time when the San Francisco employee left the site of
application. The City of San Francisco Dept of Environment
shall keep a copy and log of all such notices, showing
application and employee monitoring as above.
PESTICIDE
APPLICATION
NONCHEMICAI. METHODS
NEXT
Oxalis
LEAST-HAZARDOUS PESTICIDES
AS A LAST RESORT
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San Francisco has reduced its pes
ticide use by almost 80% since our Integrated Pes
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(IPM’I Program began. Our 1PM Ordinan
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weeds,
rodents, or insects on City properties
be solved using lowest risk methods. Where
pesticides must
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PREVENTION
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Garlon 4 Ultra
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Other Actions Attempted:
Area Treated:
Pesticide Name(s):
Active Ingredient
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Signal Word:
CAUTION
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Applicator:
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Spray Postponed Until:
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Info:
Date/Time of Applicaon.
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For more 0
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the SF Integrated Pest
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of
pes
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use, See:
www.sfenvironment.org/jpm
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