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Coqui
Hawaiian Integration and Reeducation Program
P.O.
Box 1880, Pahoa, HI 96778
www.HawaiianCoqui.org
808-935-5563
October
15, 2001
James
J. Jones
Deputy
Director for Pesticide Programs
Office
of Pesticide Programs, USEPA
Ariel
Rios Bldg.
1200
Penn. Ave. NW
Wash.,
D.C. 20460
Re:
File 01-HI-03
Dear
Mr. Jones:
I
am the Director of C.H.I.R.P., a non-profit organization
that was formed to rationally deal with the coqui tree
frogs that have been introduced to Hawaii.
Our membership consists of environmentalists,
nurserymen, and concerned citizens who see the threat of
frog eradication as worse than the threat of frogs to
the environment, the economy, and public health.
While
some State and Federal agencies have argued that the
coqui is an invasive species in Hawaii, their claims are
non-scientific, propagandistic, and self-serving.
These agencies are in need of funding for their
invasive species work, and Federal money would be
available for frog eradication only if the frogs could
be defined as invasive.
However, a non-biased assessment of the frog
situation shows the alleged threat of the frogs is
speculative and tainted with conflict of interest.
These are not an invasive species, and no
emergency exists concerning their presence in Hawaii.
Please let me explain.
As
you know, to be invasive, an alien species must be shown
to be, or considered likely to be, a threat to the
environment, the economy, or human health.
Are the frogs an environmental threat in Hawaii?
The
tree frogs consume insects, including mosquitoes and
other invasive insects that threaten agriculture and
human health. The
Hawaii Department of Agriculture, in fact, considers
frogs to be beneficial to agriculture for this very
reason. The
argument against the frogs suggests that they might
threaten endangered native insects.
This speculation ignores the fact that the frogs
are currently located where there are no such insects.
Further, the frogs’ consumption of
non-endangered, invasive insects, it can be argued, may
relieve competitive pressures between endangered insects
and invasive ones.
It
is also erroneously stated that the frogs have no
natural predators in Hawaii, while at the same time it
is hypothesized that the frogs will be eaten by rats and
mongooses, thereby increasing the populations of these
invasive mammals. As
you can see, if these mammals eat the frogs, then there
are indeed predators for the frogs.
Further, for the frogs to increase rat and
mongoose populations by adding to these predators’
food supply, there would have to be a shortage of food
for the rats and mongooses.
By this theory, adding to the predator food
supply would increase predator numbers.
However, there is currently an abundance of food
for rats and mongooses in Hawaii, making it unlikely
that adding frogs to their diet will increase their
numbers.
The
final environmental argument is that the frogs will eat
too many insects, stealing food from other bug-eaters,
such as endangered birds.
However, it has never been proven that there is
an insect shortage in Hawaii.
Further, the same argument could be made against
any insect eating bird or reptile on the Island, such as
the alien cardinal or gecko.
Why only pick on the frogs?
As
for the economic impact of the frogs, the only adverse
effect of the frogs has been on intra-island shipping,
since the Hawaii Department of Agriculture is trying to
limit the spread of the frogs.
Shipping to the mainland has not been adversely
affected, because the frogs cannot survive in the
mainland environment.
If there were no concern in Hawaii about the
frogs, there would be no effect on the economy.
Indeed, the concern about the frogs and the need
for nurseries to control frogs has created an economic
crisis, since frog control is costly and impractical.
As
for the health claims against the frogs, there is no
scientific study in existence that links the coqui with
health problems. Perhaps
the only problem some people have with the frogs is with
their sound, which some people also enjoy.
The problem is not the frogs, but the attitude
some people have developed against the frogs.
This negative attitude has been fostered by local
eradicator propaganda, including that from the
Department of Agriculture, which has created a frog
mania here. The
bird-like sound of the frogs has been equated with the
sound of a lawn mower and table saw.
While decibel readings of the frogs are high, the
same is true for many birds and crickets.
People throughout the Caribbean are happily
lulled to sleep by the nighttime song of these frogs.
Many in Hawaii have also come to appreciate their
song. However,
the propaganda against the frogs has made many fearful
of the sound, causing unnecessary sleepless nights and
stress. In
short, if the public is told to expect sleepless nights
due to frog noise, it will be a self-fulfilling
prophecy.
I
hope this brief analysis of the situation has shown that
the definition of the frogs as invasive pests is opinion
and not necessarily fact.
While some extremist environmentalists in Hawaii
see any introduced alien as bad for Hawaii, this, too,
is a value judgment, and not one universally shared by
all interested in the environment and quality of life in
Hawaii.
The
approval of caffeine for eradicating the frogs threatens
the environment more than the frogs ever could.
The EPA already acknowledges the risks of
caffeine to human health, and has required assessments
of the impact the spraying would have on non-target
species, including humans.
This constitutes human experimentation, and
without informed consent, since the spraying could be
performed without public notice or approval.
Further, the spraying will not eradicate the
frogs, but may only control their numbers temporarily.
It may also increase the spread of the frogs, as
some leave the spray site. This means that the caffeine “experiment” could make the
“problem” worse, could never solve the
“problem”, and could potentially damage the
environment, economy, and human health.
Interestingly,
despite the alleged “emergency” status of the
situation, as of this date, fully 9 months since the EPA
gave its approval for caffeine trials, caffeine has not
been used against the frogs.
I suggest the emergency is false, the frogs are
here to stay, and we in Hawaii have to get accustomed to
their nighttime song.
The limited funds of local invasive species
interests should be used to fight truly invasive
organisms, including stinging caterpillars, fire ants,
and mosquitoes carrying dengue fever and malaria.
Ironically, these pests may be food for the coqui
frogs, which are known to eat mosquitoes, tree borers,
leaf hoppers, centipedes, termites, and virtually
anything smaller than themselves, including other frogs.
It
all comes down to personal taste regarding the sound of
the frogs, and the financial interests of eradicators
that want Federal money.
The EPA should not grant an extension on the use
of caffeine against the frogs, which creates more of a
threat to Hawaii than any frogs could ever cause.
Thank
you for your consideration.
Please contact me for further information.
Sincerely,
Sydney
Ross Singer
Medical
Anthropologist and Biochemist
Director,
C.H.I.R.P.
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