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As a resident of Boulder County, the county’s proposed integrated weed management proposal is appalling due to its emphasis on using, over-using and unchecked use of chemicals that pose a significant threat to human health, pollinators, water quality, aquatic life, soil and overall health of the environment. The lack of proactive notification to the community regarding this plan, lack of emphasis on indigenous/regenerative agriculture for weed control, lack of consideration of modern science and lack of scientific monitoring when chemicals are used make this proposed plan highly unacceptable.
I understand that the county wants the easy button when it comes to weed control. The county wants to be able to suppress the undesirable weeds as easily and efficiently as possible. However, the effects that the chemicals have on everything else in the environment are blatantly ignored in this proposed plan.
While a lot of these chemicals do effectively kill the targeted species and some are certainly more harmful than others, the majority of these chemicals have drastic and unknown consequences on the rest of the environment as a whole. These are extremely important considerations since these chemicals can have negative effects on desirable plant species, pollinators, soil health, water quality, aquatic health, endangered species, and us humans.
Governing agencies and society as a whole generally consider these chemicals to be safe until proven otherwise. Even after the chemicals have been proven to not be safe, the new peer-reviewed scientific papers done by independent scientists with independent funding get rejected and ignored by governing agencies within the U.S., such as the Environmental Protection Agency (EPA). The only “science” that the EPA currently evaluates is what is submitted by the company that manufactures the chemical when they first submit an application to the EPA. These companies stand to make billions of dollars in profit if their applications are approved by the EPA which is an obvious and clear conflict of interest.
Most governing bodies outside of the US peer review submitted research to either verify or dismiss the submitted research which makes governing bodies outside of the U.S. currently much more reliable for determining harm levels of chemicals. These negative effects of chemicals are normally not discovered until well after the wide use of the chemicals, making the damage already done.
Based on the factual findings of actual modern scientific research done by independent scientists and the lack of adequate research into the potential negative environmental effects noted by the majority of the scientific papers I would like to propose the county adopt and implement the following into their proposed weed management plan.
The county emphasizes and prioritizes indigenous/regenerative agriculture practices above everything else. This would include but would not be limited to: livestock grazing, reseeding native plants and controlled burns.
The county hires and collaborates with local indigenous communities, ranchers, farmers and local businesses who have vast and extensive knowledge in regenerative agriculture to come up with the best solutions possible with a priority and emphasis on community and environmental health.
The county does not implement the use of any chemical until the chemical is scientifically proven safe for every aspect of the environment, aside from the targeted species, by peer-reviewed, independently funded research and scientists. Notify the community via proactive outreach at least 90 days before a new chemical is scheduled to be used by the county.
The county establishes a way for community members to submit new research that has been done on chemicals that are currently in use by the county and the county halts all use of the chemical in question until the concerns have been evaluated by an independent, third-party scientist who is an expert in their field. Aerial application is not allowed due to the uncontrolled and broad nature of aerial applications along with the large carbon footprint that aerial applications have.
Before any chemical use or application of any kind, the county takes comprehensive soil, water, and air samples of the direct and surrounding area that chemicals will be applied to. After chemical application, routine soil, water and air samples of the direct and surrounding areas are routinely taken and changes monitored by an independent, third party that is not affiliated with the chemical manufacturer. All samples, results, and analysis are property of the public and made public as soon as the sample results are available and public release is not to be delayed for any reason.
The county very clearly implements measures laid out in the Colorado Pesticides Act to ensure that state regulations on pesticide use are being followed by county employees and that proper labeling of the application area is occurring so the public is aware of what chemicals have been applied and when and in what dosage along with the complete history of chemical use by the county being an easily accessible public record.
The county establishes a new position or office of Ombudsman – the purpose of which is to receive, evaluate, and investigate complaints from the general public regarding county practices, procedures, implementation, etc.
In addition to implementing the measures listed above directly into the Integrated Weed Management plan the county needs to implement additional measures to protect the community. Matters, proposals or issues that are deemed potential public health threats/issues should trigger the county to send proactive outreach to every known citizen of the county to notify them of the potential public health issue and to elicit feedback.
The county should then hold several open houses at varying days and times, including weekends, do not require an RSVP and do not have attendance limitations for the purpose of having community conversations regarding the public health issue.
Additionally, matters affecting public health should be required to be put to a public vote so the voice of each and every resident can be heard regarding the issue.
These measures would put an emphasis on protecting the health of the community and the environment which is of the utmost importance. If we do not have our health or if the environment is not healthy from unintended consequences, then we as a community have nothing.
