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Coqui
Hawaiian Integration and Reeducation Program
P.O.
Box 1880, Pahoa, HI 96778
www.HawaiianCoqui.org
808-935-5563
Dan
Rosenblatt
USEPA
Pesticide
Office
1200
Pennsylvania Ave. NW
Washington,
DC 20460
Re:
File 01-HI-03
Dear
Mr. Rosenblatt:
Thank
you again for your time on the phone today.
I would like to reiterate our opposition to the
proposed use of caffeine to control coqui and greenhouse
frog populations in Hawaii.
Please also see the enclosed material.
There
are really two issues to be addressed: (A) whether or
not there is an environmental and human health emergency
in Hawaii as a result of the introduction of the coqui
tree frogs; and (B) whether or not caffeine is the best
way to control the frog numbers.
Let me summarize our positions regarding each
point.
(A)
Is there an emergency in Hawaii because of the frogs?
(1)
All conclusions regarding the impact of the frogs
on the Hawaiian environment are speculative.
For example, it has been suggested that the frogs
will eat too many insects, depriving endangered native
insectivorous birds of food.
However, there has been no study demonstrating a
shortage of insect life in Hawaii.
In fact, one of the greatest threats to
endangered native birds in Hawaii is avian malaria,
transmitted by mosquitoes.
The frogs eat mosquitoes, including those
carrying avian malaria, and could therefore aid the bird
populations. They
also could aid the human population by eating mosquitoes
that carry dengue fever.
Additionally, frogs are considered beneficial to
agriculture since they eat insects. Several nurserymen have commented that they need fewer or no
chemical insect control since having coqui frogs.
(2)
It has been suggested that there are no predators
for the frogs in Hawaii.
However it is then suggested that mongooses and
rats will eat the frogs, which means that there are
predators for the frogs.
It is then suggested that the rat and mongoose
populations will burgeon as a result of the additional
food supply of frogs.
However, this assumes that the population of
these predators is currently held in check by a limited
food supply, which has not been scientifically
demonstrated. Common
observation suggests that there is more than enough food
already for these predators, and that the frogs will
simply make their diet more diverse.
This will not increase mongoose or rat numbers.
(3)
The sound of the frogs has been called a loud
“shriek” and “shrill” and has been compared to a
lawn mower and table saw by frog antagonists.
It has been claimed that people cannot sleep with
the sound of the frogs.
However, many people enjoy the sound here in
Hawaii. And
people in Puerto Rico, where the coqui frogs are native
and considered the national symbol, loved and revered by
all, the frogs’ song helps people sleep.
Puerto Ricans often take a recording of the song
of the coquis on trips to allow them to sleep better.
Therefore, the sound is a matter of taste.
It may be an acquired taste, and some people in
Hawaii may need to get used to it.
But it is not intrinsically offensive.
In fact, the sound of the coqui is a mating song,
not an offensive weapon, as with the sound of geese.
When people first hear the sound of the coqui,
they usually think it is an exotic nighttime bird.
(4)
No medical studies have ever shown the sound of
the coqui to be a health hazard, despite the
distribution of the frogs throughout the Caribbean,
Central America and
in parts of Florida, Alabama, and Louisiana.
(5)
There are many species of invasive insect pests
in Hawaii, and the frogs eat anything smaller than
themselves, so long as it is not caustic, including
other frogs. To
argue that the frogs will throw out of balance the
Hawaiian ecosystem is to assume that the Hawaiian
ecosystem is in balance already, which is not the case.
It could be argued that the Hawaiian environment
is in need of insect predators, since it has so many
alien insects. The
gecko, which is also an alien species in Hawaii, does
eat insects, and is appreciated here.
The same appreciation may someday be shown to the
frogs, as is the case in Puerto Rico.
(6)
Nowhere else in the world are tree frogs
considered “pests”. In fact, tree frogs are endangered in many places worldwide.
(7)
The plant industry is not limited in exporting
plants from Hawaii as a result of the frogs.
The only limitation has been on intra-island
transport because of Department of Agriculture
quarantine regulations.
Therefore, the economic trouble has been caused
by the DOA’s policies.
Interestingly, the DOA had do go through some
legal maneuvers to consider the frogs a pest, since the
frogs are not a pest for agriculture.
They are not a threat to plants.
Indeed, they are friendly to agriculture because
they eat bugs.
In
short, the arguments against the frogs are speculative,
arguable, and non-scientific.
They certainly do not support the contention that
an emergency exists as a result of the presence of frogs
in Hawaii.
(B)
Is caffeine a good choice to control frogs?
(1)
According to the DOA and Department of Land and
Natural Resources, the frogs cannot be eradicated on
Hawaii or Maui. This
means that the frogs are here to stay, and any measures
to control their numbers will be ongoing.
This means that caffeine will be continually used
for frog control, requiring long-term studies as well as
short-term studies to see the effect of caffeine on the
environment, water supply, marine life, human health,
bacterial populations, and other non-target species.
(2)
Caffeine residues are a known human health threat
of unknown proportions.
The persistence of residues can threaten
endangered birds and bats, as well as humans and other
non-target species.
Indeed, the fact that the caffeine is nonspecific
makes it a threat to everything in the environment.
(3)
The EPA has admitted that the effect of this use
of caffeine on non-target species, including mammals and
humans, is unknown and needs to be assessed as part of
this experiment. Spraying
has been allowed in residential, resort and park areas,
which exposes humans to the spray and its residues.
Humans would be allowed to enter sprayed areas
after a 24-hour quarantine, and this period of time has
never been proven safe by any study.
Indeed, this is the first experiment with the
application of concentrated caffeine as a pesticide.
This constitutes human experimentation, and
should require informed consent from the people applying
the spray and from the public exposed to its residues,
along with the oversight of an Institutional Review
Board.
(4)
Caffeine is known to be a mutagen, carcinogen,
and teratogen in bacteria, plants, animals, and human
tissue culture, as well as in some epidemiological
studies. It
is known to easily percolate through the ground and can
enter the groundwater.
It thus poses a threat to water supplies, the
ocean reefs and marine life.
(5)
The EPA has identified several groups as
particularly susceptible to caffeine poisoning,
including pregnant women, toddlers, children on asthma
or ADHD medication, and anyone with high blood pressure
or other circulatory disease.
This constitutes a large segment of the
population. In
addition, the already high consumption of caffeine in
beverages, chocolate, and medications by many people
makes the additional caffeine load from spray residues
even more potentially toxic, since these people may
already be near their caffeine toxicity threshold.
Caffeinism is a real problem suffered by many.
And there is no antidote for caffeine poisoning.
(Ironically, one symptom of caffeinism is
sleeplessness.)
(6)
The experimental data submitted about the skin
permeability of caffeine was not performed with
concentrations of caffeine at the high levels that will
be used for this spraying.
At these high concentrations, caffeine irritates
the skin, increasing permeability.
Additionally, as the caffeine residues dry, the
caffeine could concentrate and crystals could reform.
Such skin exposure has never before been tested,
another reason why this is a form of human
experimentation.
(7)
Exposure to caffeine residues may be through skin
contact, or through hand to mouth contact.
For example, a dog can run through an area that
has been sprayed within the last 48 hours and get
caffeine residues on its fur.
A child can then pet the animal and get the
caffeine on her hand. Later hand to mouth contact can cause the child to
inadvertently consume the caffeine.
(This ignores the effect of the caffeine on the
dog. In
addition to birds, caffeine is also toxic to dogs and
cats.)
(8)
Proponents of frog eradication and caffeine use
have stated that they need to apply some frog pesticide
on a “landscape scale”.
EPA guidelines for this caffeine application
forbids aerial spraying, and requires the spray to be
applied on the ground. This makes caffeine inappropriate for landscape application.
In addition, since the frogs hide in crevices
between rocks and under logs, etc., the DOA has
recommended the use of defoliants to clear the ground
cover, making the frogs more exposed.
This means that the caffeine may be used in
conjunction with other poisons, and the synergistic
action of caffeine with such poisons needs to be first
studied. Caffeine
is known to potentiate the activity of other drugs when
given to humans and animals.
This means that the effect of using, for example,
Round Up with caffeine may be different than using
either separately.
(9)
Finally, the overall effect of the caffeine spray
on the frog population is unknown.
The frogs may spread as a result of the
disturbance of their immediate environment, particularly
if defoliants are used.
And unless the kill rate is 100%, including all
eggs, it will fail to eliminate the frogs.
The DOA and DLNR are already talking control and
not eradication.
In
summary, we do not believe that the frogs are invasive,
i.e., are a threat to the environment, economy or human
health. We
do, however, believe that using caffeine to kill the
frogs does pose a threat to human and environmental
health.
We
believe that the real agenda is to get caffeine approved
as a pesticide, which will increase its market value and
make profitable the production of genetically engineered
caffeine. The
University of Hawaii owns the patent for the caffeine
gene, which it has exclusively licensed to Integrated
Coffee Technologies, Inc.
(See the enclosed article, “Frog War or Frog
Fraud”.)
There
is thus a conflict of interest in the promotion of
caffeine to kill the frogs.
Indeed, we believe that the so-called “frog
war” is really about getting caffeine approved as a
pesticide at the public’s expense, increasing the
value of the patent and its license by increasing the
market value for caffeine.
Hawaii
has many invasive species, such as fire ants,
mosquitoes, and stinging caterpillars.
Nobody would argue against attempts to control
these pests. However,
many people in Hawaii do not consider the frogs pests,
and appreciate their nighttime song and the fact that
the frogs eat invasive pests such as mosquitoes.
Clearly, the alleged risks that the frogs pose
are speculative, biased, and tainted with conflict of
interest. On
the other hand, caffeine poses real risks.
Those
stating the frogs are a threat to Hawaii have the burden
of proof for their allegations, and should offer proven
safe methods for frog control.
The public should not bear the expense and risk
of developing caffeine as a pesticide, nor be forced to
accept the biased, unscientific, and often hysterical
statements of those invested in frog control.
We
urge the EPA to not extend its Section 18 exemption for
caffeine.
Thank
you for your attention.
Sincerely,
Sydney
Ross Singer, Medical Anthropologist
Director,
CHIRP
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