Big Spray - Btk Updates

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Government response to community concerns

August 29, 2012

The following letter was provided to MVS by Bee SAFE. It is from Peter Lishman, Director, Resource Authorizations - Ministry of Forests, Lands and Natural Resource Operations - Thompson Okanagan Region. The letter was written to respond to concerns presented to the Ministry by both Bee Safe and the Cherryville Water Stewards. Please note that some names have been removed from the letter for publication purposes.

Dear Bee SAFE Founders:

Thank you for your e-mails of June 20 and 29, 2012 outlining your opposition to spraying Upper Shuswap. We provide this information for you:

The email from Bee S.A.F.E. dated June 29, 2012, states the following, “The email below was sent to staff at the Ministry 9 days ago. No answers yet, except to say that Ms. Maclauchlan is out of the office. . .” The email that this group is referring to states the group and communities concern over the use of Foray 48B (B.t.k.) in the Upper Shuswap watershed. It was unfortunate that there was this delay in responding to the Bee S.A.F.E. email but our spray program began in the Okanagan on June 20th and I was away from my office for a number of days. In the time since this note was sent to Minister Thomson’s office I have been in contact numerous times, both by phone and email with numerous people. Particularly in the telephone conversations, we discussed in detail the issues surrounding the objectives of the proposed spray program, the values at risk, the pesticide (Foray 48B) and the issue of non-target organisms and watershed and human safety. I attempted to make myself available to the Cherryville community and individuals, and they have responded to that openness and made contact with me numerous times.

I will describe in the paragraphs below the science behind this spray program and the issues that were discussed at length with various Cherryville citizens.

Prior to our anticipated start-up of this spray program I did a final field assessment to determine the timing of the spray, the stage of larvae and abundance. This was conducted on Saturday June 30th, 2012. It was during this assessment that I became concerned over the condition of the Sugar Lake/Greenbush Lake access road leading into our staging site. Due to the heavy rain and snowmelt the river had eroded and/or washed out sections of the Sugar Lake Road although access in a pick-up truck was still possible. The western hemlock looper larvae were abundant in numbers and would be at the optimum stage to treat in about a week. The B.t.k. had already been delivered to our staging site but the fuel trucks and ground support crew for the spray helicopters still had to get out to this site and I was unsure how safe the road would be. The next few days brought additional heavy rain to the area so for safety reasons and I decided to cancel this particular part of the program which was only 1,250 hectares. The stands will suffer moderate to severe defoliation in patches throughout the drainage and we will re-evaluate the option of spraying in 2013 based on the loopers population trends and further discussion with Parks on Caribou habitat priorities.

Email sent June 18th, 2012:

I am responding to your June 15th letter to the BC FLNRO’s Forest Health Program regarding your concerns about the planned treatment program for the western hemlock looper. I will attempt to address your issues as they were presented in the letter.

1. Legal notice – According to the requirements by Ministry of Environment for Pest Management Plans under the Integrated Pest Management Act and Regulations, notification of aerial treatments of biological insecticides on crown forests is not required. The only public advertising requirement in the regulation is to advertise the Pest Management Plan itself when an application for a PMP is made. For reference, here is the link to the current Southern Interior PMP: http://www.for.gov.bc.ca/rsi/ForestHealth/2012%20spray%20program/pdfs/Revised%20SIR_PMP_2008-2013.pdf. As this is not considered to be good public relations, the MFLRNO’s Thompson/Okanagan Region decided to publically advertise all of its defoliator treatment programs and release numerous information bulletins in areas near proposed treatment sites.

Although the advertising stated that the treatment could occur after June 1st, the likely treatment date is later in the month but at the time of advertising it was unclear what this date would actually be. Due to the unseasonably cool and wet spring, I anticipate the treatment may not occur until the end of June or early July. Please refer to the MFLNRO’s western hemlock looper program web page for more information on proposed treatment dates when they become available:

http://www.for.gov.bc.ca/rsi/ForestHealth/Western_Hemlock_Looper_Spray_Program_2012.htm (note: no dates have been posted yet as the optimum treatment time has yet to be confirmed.) Note that the advertising is not for contributing information, only notification as a courtesy of an impending treatment.

The opportunity for appeals has long since passed and should have been done during the public review period for the PMP and directed at the Environmental Appeal Board. See http://www.env.gov.bc.ca/epd/main/ipma.htm

2. “...kill undisclosed amounts of non-targeted insects, ...” – The size of the proposed treatment blocks is relatively small compared to the total size of the watersheds. There will be mortality of some non-target lepidopteron larvae if they are in a vulnerable life stage (usually early stage caterpillars). Susceptibility to Btk is also variable by species. Studies have shown that re-population of niches vacated by the spray are quickly re-filled by populations outside of the spray area if those reservoir populations are healthy. Within two to three years, populations rebound to pre-treatment levels. Furthermore, a four year study of the effects on insectivorous birds associated with the 1999 Victoria gypsy moth spray showed no impacts on bird populations. Sampling will be done in the treated areas and outside the treated areas before and after spraying to determine population levels of hemlock looper and other Lepidoptera larvae.

3. “...the cumulative effects of different bacteria, chemicals and toxins being sprayed are not being monitored” – Our position, and one that is supported by PMRA and MoE, is that the impacts of Foray 48B should be negligible to the “last pristine watersheds in southern BC”. There are no harmful ingredients in Foray 48B. The product contains 2.1% Btk (spores and crystals) that are a naturally found soil borne organism already present in the ecosystem. 7.9% of the formulation contains a mixture of proprietary ingredients included to enhance the efficacy of the spray against the target organisms and it also contains some of the fermentation solids that were used to grow the bacteria (usually of some grain – wheat, oats, barley, or corn). The remaining ingredient is water (90%). All of the ingredients are considered safe for use on certified organic farms. All ingredients were reviewed by the regulator, the Pest Management Regulatory Agency, and by the Organic Materials Research Institute. The “other ingredients” are all considered to be “inert” by the PMRA and US EPA and many of them are commonly found as additives in foods we eat.

We contend there will be more harm to the integrity of the watershed’s ecosystem if we don’t treat. The whole purpose of the project is to protect critical winter range for endangered mountain caribou whose survival is dependent on the availability of arboreal lichens that only grow on live mature trees. We have witnessed the impacts of previous hemlock looper outbreaks that resulted in severe mortality of mature cedar and hemlock resulting in a significant alteration of the forest structure. Salvage logging operations that will likely follow widespread mortality will also impact watershed integrity. A similar treatment occurred in 2003 in the Revelstoke Lake watershed and this was at the request of BC Parks solely for the purpose of protecting mountain caribou habitat.

So, the question comes back for your group to consider, which is the more important resource value: maintaining an irreplaceable mature canopy or saving some unknown quantity of caterpillars whose populations may recover in 2-3 years?

4. “Could you, without a doubt, guarantee us that spraying Foray 48B ....won’t negatively alter the integrity of our watershed?” - See point 3 above. We can guarantee that NOT treating the area will result in significant changes in the forest structure and “alter the integrity of the watershed”. We also believe, based on the scientific evidence available, that the direct risks of Foray 48B to the rest of the ecosystem are minimal to negligible. There are risks in any endeavour. We have considered the risks against the benefits and have determined that this operation poses minimal risk to the environment and to human health while achieving our tree protection goal.

I hope I have addressed your concerns regarding the MFLRNO’s western hemlock looper program. Please feel free to contact me if you require any more information.

Email sent July 3rd, 2012:

I have considered your comments and concerns at length and respect the various views that people have on the use of biological insecticides. I had a very good discussion with you this morning and mentioned that the primary goal of the western hemlock looper spray program was to protect the mature hemlock forests as habitat for the local Caribou herds. The treatment of western hemlock looper by the Ministry of Forest, Lands and Natural Resource Operations is only done to protect wildlife habitat and is not conducted as a measure to protect more economic-focused timber harvesting values.

The product we had planned to use, Foray 48B, is registered for use against this insect, has organic designation (OMRI) and is safe for humans and other animals. B.t.k. only kills Lepidoptera that are in the early larval stage (small). Moths and butterflies that are in the egg, pupa or adult stage will not be adversely affected. In addition, the size of the proposed blocks around Sugar Lake-Greenbush Lake are relatively small compared to the total size of the watershed so those non-target Lepidoptera that are affected will be minimal and will be able to re-invade the treated area within a few years. Susceptibility to B.t.k. is also variable by species. Studies have shown that re-population of niches vacated by the spray are quickly re-filled by populations outside of the spray area if those reservoir populations are healthy. Within two to three years, populations rebound to pre-treatment levels. Furthermore, a four year study of the effects on insectivorous birds associated with the 1999 Victoria gypsy moth spray showed no impacts on bird populations.

The western hemlock looper has an “eruptive” outbreak cycle and has outbreaks about every 10 years. The outbreaks last from 2-4 years with the first two years of the outbreak cycle being the most severe. As an entomologist I monitor various insect populations using pheromone baited traps and population sampling of life stages. The western hemlock looper trap catches in the Greenbush Lake area have increased exponentially in the past couple of years indicating an outbreak is imminent. Egg sampling conducted last fall also show a growing looper population. The objective of this years treatment was to catch the looper population in its building stage (year 1) prior to severe damage and/or tree mortality occurring. The defoliation for 2012 was projected to be in the low to moderate range but we were hoping to prevent a full outbreak from occurring by treating this year. Should the defoliation become severe we may reconsider this treatment again at some time in future years.

Therefore, after consideration of your request to cancel the spray and the fact that it is a very small area, I have decided to cancel the proposed 2012 treatments in the Greenbush and Sugar Lake area. If you have further comments or concerns please do not hesitate to contact me. I have attached some links below for your information.

Thank you.

http://www.for.gov.bc.ca/rsi/ForestHealth/Western_Hemlock_Looper_Spray_Program_2012.htm

Background on the western hemlock looper program:

The primary objective of this spray program was to protect critical Caribou habitat from western hemlock looper (Lambdina fiscellaria lugubrosa) damage. The western hemlock looper is an eruptive defoliator with outbreaks occurring every 10 to 11 years in interior hemlock stands. The larva of the western hemlock looper feeds primarily on hemlock trees, but will feed on almost any foliage, including Douglas fir, amabilis fir, Sitka spruce and broad-leaved trees and shrubs. The larva feeds on new or old foliage, but usually starts at the crown of the tree. A western hemlock looper outbreak has the potential to seriously harm or kill trees over large areas and severely defoliated trees can die after only one year of feeding by the larvae. Successive years of defoliation in a forest will cause widespread mortality and may make trees more vulnerable to pathogens and attack by other insects.

Using predictive sampling methods (moth trapping with pheromones and egg sampling) the next outbreak was predicted to begin in 2012. The spray program was planned so as to target the looper in its building stage of an outbreak thus preventing damage and tree mortality. The pesticide used for this program, Foray 48B, is a biological insecticide that is widely used in B.C. and is registered with the Organic Materials Review Institute. The active ingredient is the naturally occurring bacterium Bacillus thuringiensis var. kurstaki (Btk). This spray only affects moth and butterfly larvae, because B.t.k. effectiveness is closely linked to the acidity of their digestive systems. Foray 48B is designed to specifically target moth and butterfly larvae at a particular stage in their life cycles. Larvae other than the western hemlock looper larva will only be minimally affected because the spray program is carefully timed to occur when the western hemlock looper larva is at that vulnerable stage. B.t.k. only affects the larval stage of susceptible insects. It cannot be used to kill eggs, pupae or adults.

Foray 48B is a biological insecticide and can be safely used around humans and other animals. It is used to control pest caterpillars in the production of many food crops. Organic food growers also use it. Birds, household pets, fish, beetles, spiders and beneficial insects (including honey bees) are not affected by it. People who have particularly sensitive respiratory ailments may wish to stay indoors on the mornings when spraying occurs, but humans are not affected by the B.t.k. bacteria. Small droplets (80-100 microns in size) of Foray 48B will be sprayed over the tree canopy. When the western hemlock looper larvae feed on foliage covered with the spray, they ingest the bacteria. Specific enzymes in the larvae’s digestive systems are required to activate the bacteria, which then multiply and release toxic substances. This causes the larvae to stop feeding and they die within days. B.t.k. breaks down quickly in the environment when exposed to sunlight or precipitation, and only lasts for three to seven days.

More information about the western hemlock looper is available online at:

http://www.for.gov.bc.ca/hfp/publications/00198/western_hemlock_looper.htm

Lorraine MacLauchlan, Forest Entomologist

Ministry of Forests, Lands and Natural Resource Operations

Thompson Okanagan Region

e-mail: Lorraine.maclauchlan@gov.bc.ca

Thank you again for your inquiry.

Peter Lishman, Director, Resource Authorizations

Ministry of Forests, Lands and Natural Resource Operations

Thompson Okanagan Region

e-mail: Peter.lishman@gov.bc.ca

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Aerial spraying of Bt in the Upper Shuswap

Letter to the Ministry of Forests, Lands, and Natural Resource Operations

Forest Health Program.

Below is the letter written to the Ministry of Forest by Bee SAFE and sent to Lorraine.Maclauchlan@gov.bc.ca

Tim.Ebata@gov.bc.ca

Bee S.A.F.E. is a movement that works to improve health, the environment and local economies by increasing access to food that is safe for the bees and for us. We operate a storefront office in downtown Lumby and our E-Newsletter reaches 340 supporters.

Bee SAFE is opposed to the Ministry's plan to spray 20,000 litres (4 litre per hectare over 5,000 hectares) of Foray 48B in the upper Shuswap Watershed for the following reasons:

1. Spraying is not an ecologically sound solution:

Infestations such as the Hemlock Looper, the Spruce budworm and the Pine Beetle are the result of out of control logging. When a forest becomes imbalanced, when certain insects or plants have lost their predators, targeting the insects usually results in more unpredictable chain reactions. As prize-winning author Andrew Nikiforuk states in his book Empire of the Beetle, “Misguided science, out-of-control logging, bad public policy, and a hundred years of fire suppression created a volatile geography that released the world's oldest forest manager from all natural constraints.”

The Journal of Pesticide Reform from McGill University states that “Large-scale applications of B.t. can have far reaching ecological impacts. B.t. can reduce dramatically the number and variety of moth and butterfly species, which in turn impacts birds and mammals that feed on caterpillars. In addition, a number of beneficial insects are adversely impacted by B.t.” Link to the Report

Infestations are the forest's way of coping with sick ecosystems and should be a warning to us. Sound solutions would aim at restoring the health of the forest by rebalancing the plant diversity and not having monoculture, which in turn would increase the numbers of predators such as birds and bats. Spraying substances that will further decimate their numbers is not a solution.

2. Foray 48B is not inoffensive to mammals, including humans:

As stated in the Journal of Pesticide Reform from McGill University referenced above: “Foray 48B is irritating to rabbit skin, and Foray 48B is moderately irritating to rabbits' eyes..... A memo from Novo Nordisk, the manufacturer of Foray 48B, states that "It is possible that someone that already has developed an allergy to one of the components of Foray 48B or has asthma . .. could be affected by exposure to small quantities of Foray 48B”.

The inert ingredients in BT products are potentially the most toxic components of the formulation. The little public information available about these trade-secret ingredients show that they can cause serious environmental and health problems such as severe corrosive damage to the eyes, skin, mucous membranes and digestive systems. Sulfuric acid, present in Foray 48B, can cause severe deep skin burns and permanent loss of vision.

Have the health effects and suffering that spraying Foray 48B will have on the birds, bats, bears and other mammals been considered by the Ministry? Has the Ministry considered replacing a pesticide spraying program by a health restoration program that would include increasing plant diversity as well as the numbers of birds and bats, and doing all that is necessary to increase their chance of survival?

We are concerned that plans to spray pesticides aerially instead of implementing a health restoration program may be motivated by economic factors rather than by ecological factors. Therefore we would like to know who are the individuals and companies that will benefit from this spray program. Please provide us with the names of the pesticide distributors, the pesticide makers, the consultants as well as helicopter pilots and any others who will receive payments from such a spray program.

We look forward to a prompt answer and hope to that the Ministry will consider replacing a pesticide spraying program by a forest health restoration program.

Bee SAFE founders:

Huguette Allen, Jane Emlyn, Carla Vierke.

bigspray

Much of the Btk spray program has been largely unnoticed by the public and media which has grown accustom to believing in the attributes of Btk as an organic solution for combating “pests”, however there are growing reservations associated with both the science and the logic used by government and forest companies to explain such treatments – and the lack of including “biodiversity” in their arguments.

My Valley Sun (MVS) will continue to provide updates on this issue. The latest is a letter from the government which responds to community concerns about Btk and their plans to combat the hemlock looper.

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