October 18, 1998
To the Editor (Ukiah Daily Journal and other area newspapers):
People in our community have expressed concern over Mendocino Redwood Company's use of herbicides in general, and its proposed use of herbicides in the Upper Barton Gulch Creek area of the Navarro Ridge in particular. We call back and talk to every person who leaves a return phone number. For those we didn't reach, or those who have concerns but didn't call, we can share the following:
We suspended plans for application of herbicides in Upper Barton Gulch Creek following our public meeting in Crown Hall in Mendocino on September 21, 1998. During this meeting one neighbor expressed concern about certain areas that were being treated. We said that we would like to walk the area together. This area will not be treated until we meet with neighbors there.
We want the people of Mendocino to know and be comfortable with how we carefully apply herbicides.
Mendocino Redwood Company (MRC) utilizes herbicides primarily in support of its silvi-culture strategy to restore and then maintain the conifer balance of its historically conifer-dominated lands, lands that now have a large amount of hardwoods present. Our overall harvesting activities are designed to reduce hardwoods while aggressively planting redwood and Douglas fir seedlings.
Herbicides slow the re-growth of hardwoods. The hardwoods on our lands are vigorous stump-sprouting species that can easily out-compete a redwood or douglas fir seedling in the early years.
Even though MRC's use of herbicides is regulated by the Federal Environmental Protection Association, the Department of Pesticide Regulation (California Environmental Protection Agency), Mendocino County Agricultural Commissioner, and Regional Water Quality Control Board, MRC is more careful than regulations require in its application of herbicides:
- MRC notifies adjacent landowners when applying herbicides within 300 feet of their property (except for industrial timberland neighbors).
- MRC does not apply any herbicides within stream zone buffers. Specifically, MRC does not apply herbicides within 100 feet of a Class I watercourse and 75 feet of a Class II watercourse. MRC does not apply herbicides within 25 feet of either side of a Class III watercourse if there is any moisture present.
- MRC tests watercourses adjacent to significant areas of herbicide application to ensure there is no presence of herbicide in the watercourses.
- MRC conducts periodic spot inspections of its licensed application contractors.
- MRC encourages the County Agriculture Commissioner to conduct at least one spot inspection of each of MRC's licensed application contractors.
MRC applies herbicides by hand on a bush by bush or tree by tree basis. There is no aerial application of herbicides anywhere on our property. Let me repeat, there is no aerial application of herbicides anywhere on our property.
The herbicide that is most often used on our property is Garlon. Garlon was first registered by the EPA in 1976 and has been used in a wide range of applications since then, including: forestry; roadside management; rights-of-way, range and pasture lands; habitat management of invasive exotic species such as gorse and broom; as well as rice production in the Sacramento Valley (under another label).
The active ingredient in Garlon is triclopyr. Garlon breaks down in water very quickly when sunlight is present, and breaks down in soil in as little as 45 to 90 days or as much as six months. When Garlon degrades the resulting materials are carbon dioxide, water and organic acids. In addition, Garlon is not considered to be very mobile, as it is generally unable to move more than 12 inches into soil.
Effects on Wildlife:
People have expressed concern about Garlon's impact on birds, fish, and other wildlife. Since we are generally applying Garlon to hardwoods, which are not the favorite food of birds or animals, and we are staying away from watercourses, the prospect of significant exposure is extremely low. Notwithstanding the low likelihood of exposure, studies have been done on animals to determine the effect of triclopyr on their systems. These studies show that triclopyr is excreted in the urine of animals within about 24 hours, and triclopyr does not have a tendency to accumulate inside an animal's body. On a pure toxicity basis, Garlon is measured to be less toxic than some common household items. Lastly, triclopyr is registered by the EPA for use on pasture and rangeland areas that are being grazed by livestock.
Erroneous, fear-filled comparisons have been made between Garlon and Agent Orange. While the chemical structures have significant similarities, there is no competent scientific evidence to suggest that Garlon can transform into Agent Orange or any other toxic substance. Whether in soil or water, Garlon breaks down fairly rapidly into carbon dioxide, water, and organic acids. Similarities in chemical structure do not always indicate similarities of toxicity.
Triclopyr has gone through over 120 different studies required by the EPA for registration including a series of studies on various wildlife species addressing acute and long-term effects.
Notwithstanding prior testing, all herbicides that were first registered prior to 1984 are required to go through reregistration. This ensures that all studies that were performed in the initial registration process meet today's scientific standards. Triclopyr (the active ingredient in Garlon) is currently in this process and all studies necessary to support reregistration of triclopyr have been submitted to EPA with reregistration expected within several months. This is not an effort by the EPA to revoke the registration of triclopyr, it is simply an effort for continual review and upgrade of the registration package taking advantage of current technology.
We will be conducting a review of credible alternatives to herbicide use an operating business can successfully utilize. We will set aside some acreage to assess alternative approaches. We expect to develop some kind of community participation as this work continues.
We will be communicating more about this in the coming weeks. To keep you abreast of progress in this area and aware of additional developments, we have established a new Web site, www.mendocinoredwoodco.com. Visitors to the site can leave questions, comments, and concerns.