With NY City poised to mass-spray large areas of Brooklyn and Queens 
tonight, and with No Spray activists revving up into hi-gear to 
oppose it, here is my 3-minute testimony given to the Department of 
Sanitation in 2007, including a summary of 7 scientific studies on 
pesticides that are as relevant today as they were four years ago:


Pesticides and the Southwest Brooklyn Garbage Transfer Station
Testimony of Mitchel Cohen, to the Department of Sanitation

In its Final Environmental Impact Statement (FEIS), the City writes:

"Procedures to control vermin, such as rats and insects, would be or, 
in the case of existing facilities, are incorporated into the 
operating permit of each Proposed Plan Facility. Licensed 
exterminators would service each Converted MTS monthly. ... The 
exterminators would evaluate potential pest and vector problems and 
apply bait and/or spray throughout the refuse handling area, the 
tipping floor, the lunch and locker rooms and administrative areas. 
Standing water in barges not being used would be treated with 
larvicide and pesticide spray when necessary." (Chapter 33.5)

The proposed transfer station will be situated right on Gravesend 
Bay, which is the most environmentally sensitive water body in this 
area and perhaps in the entire State. Even tiny amounts of pesticides 
kill fish, horseshoe crabs (which, in addition to being the oldest 
creatures on the planet, are indispensable for scientific research), 
butterflies, bees, birds, dragonflies, etc., as well as mosquitoes 
and unwanted critters. The labels on Malathion, Pyrethroids, and 
piperonyl butoxide (a so-called synergist and a carcinogen) all warn 
against spraying over or near bodies of water.

Pesticides are especially dangerous for brain and nerve development 
in young children, and for elderly people. With the expectation that 
almost 5,000 trucks per month will be utilizing this facility, 
picking up pesticides on their wheels and rumbling past various local 
facilities for developmentally disabled children on their route, one 
would think that a proper Environmental Impact Study would address 
those concerns. Yet there is not a single line in the FEIS that does so.

Just last week, the City agreed to settle a 7-year-old lawsuit 
against its massive and indiscriminate spraying of toxic pesticides 
brought under the Clean Water Act by the No Spray Coalition, which I 
coordinate. In addition to winning $80,000 for a number of local 
grassroots environmental and wildlife protection groups, as part of 
the settlement agreement the City admitted (and I quote): "Pesticides 
may remain in the environment beyond their intended purpose, ... 
cause adverse health effects, ... kill mosquitoes' natural predators, 
... increase mosquito resistance to the sprays, ... and are not 
presently approved for direct application to waterways."

In fact, I submit the following seven groups of published studies 
that speak directly to this grave issue, which is one of 
extraordinary environmental INjustice.

i. Centers for Disease Control study that found that all residents of 
the United States, including residents of New York City and State, 
now carry dangerously high levels of pesticides and their residues in 
our bodies, which may have onerous effects on our health.
(Third National Report on Human Exposure to Environmental Chemicals, 
Centers for Disease
Control, 2005);

ii. U.S. Geological Study, which shows that a large percentage of 
waterways and streams throughout the United States, including those 
in New York City and State, has been found to contain environmentally 
destructive pesticides that may severely impact on animal and aquatic 
life. (U.S. Geological Survey: The Quality of Our Nation's Waters, 
Pesticides in the Nation's Streams and Ground Water, 1992-2001,;

iii. Studies confirming that pesticides are both a trigger for asthma 
attacks and a root cause of asthma (Salam, et al: Early-life 
environmental risk factors for asthma findings from the children's 
health study. Environmental Health Perspectives 112(6):760-765.), and 
that asthma is epidemic throughout New York City;

iv. Cicero Swamp Study, showing that pesticides killed off the 
natural predators of mosquitoes and that mosquitoes came back much 
stronger after the spraying, because all of their natural predators 
(which have a longer reproductive cycle) were dead. These studies 
were done in New York state for mosquitoes carrying Eastern Equine 
Encephalitis, and found a 15-fold increase in mosquitoes after 
repeated spraying, and that virtually all of the new generations of 
mosquitoes were pesticide-resistant. (Journal of the Am Mosquito 
Control Assoc, Dec; 13(4):315-25, 1997 Howard JJ, Oliver New York 
State Department of Health, SUNY-College ESF, Syracuse 13210, USA);

v. Studies that show that pesticides have cumulative, 
multigenerational, degenerative impacts on human health, especially 
on the development of children which may not be evident immediately 
and may only appear years or even decades later (The 
Multigenerational, Cumulative and Destructive Impacts of Pesticides 
on Human Health, Especially on the Physical, Emotional and Mental 
Development of Children and Future Generations. A Submission to The 
House of Commons Standing Committee on Environment and Sustainable 
Development by Physicians and Scientists for a Healthy World, 
February 2000; Guillette, Elizabeth, et al: Anthropological Approach 
to the Evaluation of Pre-school Children Exposed to Pesticides in 
Mexico. Environmental Health Perspective, Vol. 106, No.6, June 1998; 
Kaplan, Jonathan et al. Failing Health. Pesticides Use in California 
Schools. Report by Californians for Pesticide Reform, 2002, American 
Academy of Pediatrics, Committee on Environmental Health; Ambient Air 
Pollution: Respiratory Hazards to Children, Pediatrics 91, 1993);

vi. Studies that show that pesticides make it easier for mosquitoes 
and other organisms to get and transmit West Nile Virus due to damage 
to their stomach lining. (Haas, George. West Nile virus, spraying 
pesticides the wrong response. American Bird Conservancy, October 23, 
2000); and,

vii. Studies that show that pyrethroid spraying is ineffective in 
reducing the number of the next generation of mosquitoes. (Efficacy 
of Resmethrin Aerosols Applied from the Road for Suppressing Culex 
Vectors of West Nile Virus, Michael R. Reddy, Department of 
Immunology and Infectious Diseases, Harvard School of Public Health, 
Boston, Massachusetts, et. al., Vector-Borne and Zoonotic Diseases, 
Volume 6, Number 2, June 2006)

The use of toxic pesticides to control the vermin that will be 
attracted to the proposed Southwest Garbage Transfer Station is a 
significant Environmental Justice issue for which no impact study has 
been analyzed,  let alone any study of cumulative impacts. I was 
indeed surprised that none of this was discussed in the current proposal.

Mitchel Cohen, coordinator,
No Spray Coalition

Ring the bells that still can ring,  Forget your perfect offering.
There is a crack, a crack in everything, That's how the light gets in.
~ Leonard Cohen