Chester County Environment Alliance meeting Sept. 14

Last month, Don’t Spray Me! met productively for 2.5 hours with our environmental friends in the Chester County Environment Alliance (CCEA), an umbrella organization formed with almost 30 of Chester County’s local environmental organizations–and still growing!

“Like” the CCEA public Facebook page to stay up to date on local meetings, other groups you might find of interest, and upcoming events like the Clean Energy Open House Tour on October 19.

The Chester County Environment Alliance brings the representatives of its groups together three times a year to discuss the issues affecting our environment, help each other amplify our messages, coordinate events and campaigns, and use our resources jointly to help our shared mission to preserve and protect our environment and encourage sustainable choices in everyday life.

Please spread the word about this growing initiative as we work together with our friends and neighbors to preserve our environment on so many worthy fronts.

Find out more about the CCEA and its member groups and fellow environmentalists here, including the Chester County environmental calendar.

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Where’s the Chesco Health Dept. when people really need it?

According to Chester County Coroner Dr. Christina VandePol (download the Aug. 2 press release here),

The Chester County Coroner’s Office is releasing data on drug overdose deaths in Chester County from January 1, 2019 through June 30, 2019. A total of 65 people have been confirmed to have died of a drug overdose during this period, with 62 deaths determined to be accidental and 3 due to suicide. …

Something seems amiss in how the County organizes its services! The Health Department does not deal with this major health epidemic, but when you look at the Health Department home page you find under “Environmental Services”:

New Fees for Food and other Establishments (Effective May 1st, 2019)
Housing, Insect, and Vector Concerns
Spotted Lanternfly Information
Public Bathing Places
Emergency Action Plan for Food Establishments
Healthy Stream Recreation
Farmers’ Market Guidelines
Temporary Event Application
Food Establishments
Sewage and Water
Request Existing Sewage/Well Permit

What does the spotted lanternfly have to do with human health? Why does the Health Department spend $200,000+ a year on mosquito control when the chief mosquito-related health problem it cites, West Nile Virus, has never caused one fatal case acquired in Chester County, compared to thousands of fatal opioid overdoses?

In the Health Department’s “A-Z Health Topic List,” you can find bats and dog licenses, and even Zika Virus (which is not transmitted by insects this far north), but no link to information about an epidemic that is killing an average of 2.5 people a week in Chester County! (You’d think Drug and Alcohol Services would feature itt, but good luck finding even one reference to fentanyl there.)

Why doesn’t the County have an Environment Department, with trained experts in environment and sustainability, to deal with concerns like over-proliferation of some species and existential threats to others, climate change, excessive water runoff, stream erosion, air and water pollution, environmental degradation from trash and especially single-use plastics, renewable energy, and so much more?

Then the Health Department could focus on its job: health.

DSM and CCEA

DSM had a productive weekend with of our environmental friends in the Chester County Environment Alliance. CCEA is an alliance of 29 locally active environmental organizations.

CCEA meets at least quarterly to discuss issues affecting our environment, help each other’s groups amplify our messages, coordinate events and campaigns, and use our resources jointly to help our shared mission to preserve and protect our environment.

At our May 4 meeting, we recapped the successful Earth Day Festival at Kerr Park in Downingtown and talked about next steps moving forward.

We’re excited to keep working together, and we look forward to connecting with local Chester County Environmental and Sustainability Advisory Councils in the coming months.

Find out more about the Chester County Environment Alliance and its member groups at www.chescoenvt.org/.

What’s the big public health crisis here? (update)

Number of deaths in Chester County, 2015-18 to date:

from West Nile Virus: 0.

from flu (data for those years from PA Department of Health and Philly Voice): 34 (extrapolating from 221 + 64 + 149 + 156 + 256 in PA X 520,000 approx. County population / 12,825,000 approx. PA population) (more than 80,000 Americans died from flu in the 2017-18 season; flu deaths tend to start in October)

from homicides and suicides: 7 + 52 = 59, per Chesco Coroner

from drug overdoses according to OverdoseFreePA: 415. (In the US: more than 72,000 deaths in 2017.)

Opioid deaths in Chesco and PA are rising dramatically while WNV deaths have averaged under 2 a year in the entire state, according to CDC (one so far in 2018).

Could the Health Department use its mosquito control funding more beneficially to reduce actual causes of death in the County?

Could the Chesco Department of Drug and Alcohol Services, which deals with opioid issues, put to good use the public resources that the Health Department is using to track and spray for mosquitoes?

The latest drug scourge, the herbal supplement kratom, has killed two Chesco residents this year, in April and June. Searching the County web site turns up only a 8/20/18 press release from the Coroner’s Office (which provoked attention in the media) and a couple of presentations for professionals.

Why does the County give little public attention to a drug that has killed 2 this year, compared to a flurry of spraying and press releases concerning West Nile Virus, which has killed just one person in Chester County in 2001-18? (And that one fatal WNV infection since WNV was first recorded here, in an elderly man, was acquired out of state.)

Is the County allocating taxpayers’ resources in the optimal way to support human health, safety, and well-being?

Not to mention warning Chester County residents about the dangers of pesticides and herbicides….

The “contractual guidelines/agreement with the Pennsylvania Department of Environmental Protection”

That is the phrase used for the first time we can recall in the County release about the spraying of West Chester schedule for this 9/11 evening (unless rain intervenes). For the full document, see “Happy Patriots’ Day, West Chester, from the Chesco Health Department.”

Now we are in possession of the document that must be at the origin of that phrase. Download it here: DEP DH contract for 2018. It’s basically an application to the PA DEP for a maximum of $102,680.40 to aid in anti-mosquito spraying in 2018. (That’s just a portion of the total expense, of course.)

Pages 1-22 are standard bureaucratic stuff. The interesting part comes on pp. 23-25 of the pdf: “2018 Addenda – Scope of Work.” The underlined paragraphs are the actual County submission for the state money.

So the Health Dept wrote its own ticket, telling the State what it wanted to do, the State said OK, and now the County is saying it has to abide by its contract with the state… which it wrote! Circular reasoning, anyone? And still, nothing there says when the County has to spray.

We need to dig deeper, but at this point it is hard to find evidence that the County has lived up to its stated intentions regarding public education, outreach to municipalities, and larviciding. We need to go the Right To Know route, since the information flow to the public has been cut off.

The only positive in the document is that the County commits to 48 hours notice (previously 24). They do not commit to skipping homes of hypersensitive individuals but in the last couple of years they have provided a small buffer around registered hypersensitives and registered apiarists.

Is there another “contractual guidelines/agreement”? We’ll find out.

What is supposed to happen? Has it been happening?

Some questions derived from CDC mosquito control guidelines:

1. Where has the County engaged in source reduction, as recommended?

The only source reduction we know of has been undertaken by West Chester Borough to prevent water from standing in storm drains. Does anyone know of other examples?

2. Where has the County engaged in larval mosquito control, as recommended?

They have told us that they do so, but so far have said they do not have records for 2015-17 and do not have time to tell us where for 2018; our Right to Know request on this with the PA Department of Environmental Protection is pending.

3. Has the County maintained a database of aquatic habitats to identify the sources of vector mosquitoes and a record of larval control measures applied to each (last paragraph below)?

From point 2 above, it would seem doubtful; but the public has a right to know, and we will.

Source material: Centers for Disease Control and Prevention, Division of Vector-Borne Diseases, “West Nile Virus in the United States: Guidelines for Surveillance, Prevention, and Control,” 2016, p. 33. (See the points we have put in boldface below. Download the full publication here).

Integrated Vector Management

Mosquito abatement programs successfully employ integrated pest management (IPM) principles to reduce mosquito abundance, providing important community services to protect quality of life and public health (Rose 2001). Prevention and control of WNV and other zoonotic arboviral diseases is accomplished most effectively through a comprehensive, integrated vector management (IVM) program applying the principles of IPM. IVM is based on an understanding of the underlying biology of the arbovirus transmission system, and utilizes regular monitoring of vector mosquito populations and WNV activity levels to determine if, when, and where interventions are needed to keep mosquito numbers below levels which produce risk of human disease, and to respond appropriately to reduce risk when it exceeds acceptable levels.

Operationally, IVM is anchored by a monitoring program providing data that describe:
• Conditions and habitats that produce vector mosquitoes.
• Abundance of those mosquitoes over the course of a season.
• WNV transmission activity levels expressed as WNV infection rate in mosquito vectors.
• Parameters that influence local mosquito populations and WNV transmission.

These data inform decisions about implementing mosquito control activities appropriate to the situation, such as:
Source reduction through habitat modification.
• Larval mosquito control using the appropriate methods for the habitat.

• Adult mosquito control using pesticides applied from trucks or aircraft when established thresholds have been exceeded.
Community education efforts related to WNV risk levels and intervention activities.

Monitoring also provides quality control for the program, allowing evaluation of:
• Effectiveness of larval control efforts.
• Effectiveness of adult control efforts.
• Causes of control failures (e.g., undetected larval sources, pesticide resistance, equipment failure)….

and p. 34:

Larval Mosquito Surveillance

“Larval surveillance involves identifying and sampling a wide range of aquatic habitats to identify the sources of vector mosquitoes, maintaining a database of these locations, and a record of larval control measures applied to each. This requires trained inspectors to identify larval production sites, collect larval specimens on a regular basis from known larval habitats, and to perform systematic surveillance for new sources. This information is used to determine where and when source reduction or larval control efforts should be implemented….

Happy Patriots’ Day, West Chester, from the Chesco Health Department

[Subsequent note: spraying did occur in West Chester at the scheduled time, but not at WCU, not on S. High St., and because of rain not in the NE part of the Borough.]

Anyone reading this knows that when the County planned to spray West Chester last month, Borough Council unanimously passed a resolution opposing that spraying.

After some verbal and legal back-and-forths, the County has now scheduled spraying again, now for Tuesday evening 9/11, 7:30-11:30 p.m. The affected areas are in the South and Northeast of the Borough (see maps below), impinging on the downtown area where visitors will, as usual, be circulating and enjoying the Borough’s many amenities such as outdoor dining.

This is late in the season to be spraying, and the hot weather on which mosquitoes thrive has now broken (as of Sept. 8), thus presumably reducing mosquito populations soon in any case.

Download the full press release here: 17_2018_WNV_West Chester Spray. See our post “In case of spraying: Help us / Help yourself” here.

We note some interesting changes of wording in the County press release, which begins:

Mosquito control treatment scheduled for West Chester Borough to prevent West Nile Virus

“Following the contractual guidelines/agreement with the Pennsylvania Department of Environmental Protection, the Chester County Health Department will conduct a mosquito control treatment spray in portions of West Chester Borough on Tuesday, September 11th from 7:30 to 11:30 p.m. The rain date for this event is Wednesday, September 12th from 7:30 pm to 11:30pm. The treatment is occurring because of the extremely high level of mosquito samples in areas of the Borough that have tested positive for West Nile Virus. Maps of the area being sprayed are below.

“The Chester County Health Department monitors the presence of mosquitos infected with West Nile Virus and utilizes strategies to prevent and control mosquito larvae. Despite such measures being undertaken in West Chester Borough, numerous mosquito samples have tested positive for West Nile Virus which require mosquito control treatment spray to reduce the risk of transmission. …”

What’s new there from previous wordings (compare to the wording for the release regarding the Sept. 5 spraying of Phoenixville)?

For the first time, the text starts with the phrase “Following the contractual guidelines/agreement with the Pennsylvania Department of Environmental Protection…

This wording is clearly designed to silence the Borough. We have never heard of or seen such a “contractual guidelines/agreement” before. What does, in fact, “contractual guidelines/agreement” mean? Is it a legal contract between the County and the State? Signed by whom and when?

Also note that the expression “which require mosquito control treatment spray” has also crept in. Nothing “requires” spraying; it is a decision made by human beings.

Nothing we have ever heard before suggests that the State obliges the County to spray. We have always understood that the State merely supplies information and guidance but the County makes the decision whether and when to spray. Many counties do not spray and have no mosquito control program at all. No one “requires” them to spray.

And Vector Index levels — to which the public no longer has timely access, since the site that used to have them has not been updated since July 30, and which appear to us scientifically dubious — vary so widely when used to justify spraying that it is clear that spraying is a matter of discretion, not science. Whose discretion? — that is the question.

Now, suddenly we are confronted with a new example of “state preemption,” recalling the claim that municipalities (and presumably the County as well) have no right to put any conditions on the siting, construction, or operation of gas and other pipelines.

In our view, this new example of state preemption runs totally counter to West Chester Borough’s Home Rule Charter as amended with the Community Bill of Rights (section 904) approved by Borough voters in 2015, and notably (A6):

“Right to Clean Air. All residents, natural communities and ecosystems in West Chester Borough possess a fundamental and inalienable right to breathe air untainted by toxins, carcinogens, particulates, and other substances known to cause harm to health.”

Also for the first time, the County press release does not claim to spray only “After exhausting all other available mosquito control strategies….” There we certainly agree: the County has indeed not been “exhausting all other available mosquito control strategies.” In fact, they can’t even tell us where they have larvicided to kill larvae, the chief non-toxic and most effective means of mosquito control.

Instead, the release says: “The Chester County Health Department monitors the presence of mosquitos infected with West Nile Virus and utilizes strategies to prevent and control mosquito larvae.” Of course, we’d like to see more of those strategies. “Kill mosquitos in the water, not in the air!”

The release does not make another change that we have often suggested, in its claim that spraying can “prevent West Nile Virus.” One cannot “prevent” a virus or (in the paragraph just above) “prevent” larvae. One can set out to reduce the number of mosquito or larvae or to reduce the likelihood of disease, but one cannot “prevent” them.

As usual, the release uses euphemisms like “treatment” and avoids the terms “insecticide” and (until the boilerplate language at the end of the release about the Pesticide Environmental Stewardship Program ) “pesticide.”

These are not semantic quibbles. Like the scientific and procedural claims that often come from the pesticide industry itself and that we have often criticized, these choices of words tend to mislead the public and office-holders into thinking that spraying is a helpful and healthful “treatment.”

See maps of planned spray areas below. These are the same as planned last month, as it happens. We can’t compare to any evolution in “Vector Index” scores, because those are not longer available to the public. To line up the maps (which are on different scales), look for High St. running N and S (tilting some to the left) in both maps or for Fugett Park, the spot of green below the top map and above the bottom map. In the downtown area, Gay St. and much of Market are not on the direct spray route, but the 200 block of E. Market is. And, naturally, spray drifts; if it didn’t drift, it would stay on the streets where the spray truck passes, and the whole point of the exercise is to spread the pesticide around in people’s yards.

NE West Chester:

Southern West Chester:

Phoenixville and Schuylkill the next to be sprayed

Chester County press release:

West Chester, PA – The Chester County Health Department will conduct a mosquito control treatment spray in portions of Phoenixville Borough and Schuylkill Township (see maps below). The treatment is scheduled for Wednesday, September 5th from 7:30 pm to 11:00 pm. The rain date for this event is Thursday, September 6th from 7:30 pm to 11:00 pm….

Read the full release at the above site.

This planned spraying with the pesticide deltamethrin involves big chunks (see maps online) of densely populated neighborhoods. (Isn’t it odd how the press release text finds euphemisms so as not to use the term “pesticide,” which occurs only in the EPA-related statement at the very end?)

As mentioned in “Mosquito spraying and public information,” the public and their elected representatives can’t find the underlying data online because the usual sites have not been updated recently. “Just trust us”?

On the futility of this kind of spraying, see “Why don’t they just spray and kill all the mosquitoes?

If you are in one of the spray areas, please see “In case of spraying: Help us / Help yourself.” You should protect yourself and y our family, but also your observations can help us catalogue the conditions and effects of spraying.