Fire Reduction? Humans At Risk!
Comments to FEMA from CUIDO on the East Bay Hills Hazardous Fire Risk Reduction Environmental Impact Statement, submitted on June 14, 2013
We are a grassroots community organization of people with disabilities, many of whom became disabled as a result of exposure to pesticides.
The project for which the three applicants—UC Berkeley, East Bay Regional Park District, and the City of Oakland—seek FEMA funding is profoundly disturbing, and the draft EIS is inadequate and deeply flawed.
One of the criteria for funding is net benefit to the community. But the project calls for widespread and prolonged use of herbicides over a vast area of public lands, a plan which will inevitably have negative impacts on humans. The draft EIS fails to adequately assess these impacts.
Herbicides are especially damaging to vulnerable populations. While the report does recognize, in passing, the concerns of “sensitive” groups such as children, pregnant women and the elderly, however, people with chemical sensitivity, compromised immune systems and respiratory complications are not mentioned. Large numbers of people are experiencing adverse health effects from even very low levels of chemical exposure.¹ A substantial body of evidence now demonstrates that the standards currently in place for evaluating the risk to human health posed by pesticides are inadequate.² Furthermore, the draft EIS contains no evaluation of the impact on humans of so-called “inert” ingredients in the herbicides intended for use, despite the fact that many compounds which have been classified as “inert” have been shown to be as toxic as the “active” ingredients.
Chemical sensitivity is recognized as a disability in American jurisprudence. All of the acreage which is targeted under this plan is public land, intended for the enjoyment of all the people, not merely those with healthy respiratory systems. The widespread application of pesticides in these public spaces would erect a barrier to use of these spaces by people with disabilities, and would therefore constitute a violation of the Americans with Disabilities Act.
But we in CUIDO are concerned not merely with the well-being of humans, but with the entire multitude of creatures which dwell in the targeted habitats. Because they cannot speak for themselves and are thus powerless to restrain this juggernaut of development and greed, we feel obligated to speak for them by pointing out, as forcefully as possible, the fact that this plan will cause displacement, death, and disability to countless species of animals and plants. This is outrageous.
The justification for this massive destruction of an established ecosystem is “fire hazard mitigation.” However, the extent to which this dramatic change in landscape will actually reduce fire is in dispute. Instead of living eucalyptus with limited ground foliage, we will see vast expanses of dry grasslands, deep eucalyptus mulch, brush and dead or dying oak trees. We will have simply exchanged one type of fire hazard for another, in the process destroying a carefully- balanced ecosystem. The EIS dismisses, with very little consideration, alternative solutions to fire hazard mitigation.
We urge you to reject this funding proposal.
Communities United in Defense of Olmstead (CUIDO)
CUIDO is a Bay Area grassroots disability rights organization committed to defending the human and civil rights of people with disabilities. Olmstead is a 1999 Supreme Court ruling which declared that people with disabilities have a right to live in the community.
1927 Fairview St.
Berkeley, CA 94703
¹ “Chemical Intolerance in Primary Care Settings: Prevalence, Comorbidity, and Outcomes”; The Annals of Family Medicine; July/August 2012; vol. 10 no. 4, 357-365.
² To cite one example: “Pesticide Exposure in Children,” American Academy of Pediatrics Policy Statement; Pediatrics vol. 130 no. C, December 1, 2012 http://pediatrics.aappublications.org/content/130/6/e1757
Picture by Tom Brown, http://tombrownfineart.blogspot.com/
Categorised as: Statements