Beaver Creek Spray: Public Comment made on Ferns to ODF by Carol Van Strum

Dear Mr Rieghly,  
I joined 1700+ people who have signed a petition opposing the aerial application of herbicides on private forest lands adjacent to South Beaver Creek and its tributaries (i.e., ANE-South Beaver Creek Aerial Spray, as described in Notification 2023-553-09307). 
Thanks to laws written by chemical industry interests, this spraying may be legal but it is by no means appropriate or safe.  Herbicides, like homicides and all pesticides, are intended to kill, and contrary to industry propaganda, are indiscriminate in their effects on all living things, not just a few “target” plants.  They are poisons that can be transported from the sprayed areas into nearby surface waters, poisoning wetland and stream plants and animals or people via drinking water. Herbicide-caused Impacts to any of those organisms could adversely affect the outstanding natural areas and game resources associated with South Beaver Creek and, downstream, in Beaver Creek. Additionally, the drinking water provided by Seal Rock Water District, is sourced from Beaver Creek. 
Can you with any degree of honesty say that independent, peer-reviewed studies have found the products to be sprayed to be safe and not carcinogenic, teratogenic, mutagenic, or hormone-altering?  Can you with any degree of honesty say that such testing has been done not only on the active ingredients of each product but also on the total components including so-called “inert ingredients”?  
Can you with any semblance of honesty say that such testing has been done on the combination of all products to be sprayed?
I doubt you can answer any of those questions honestly without admitting that none of that independent testing has ever been done.  EPA may register those products, but as the U.S. Forest Service was told emphatically by the U.S. Appeals Court long ago, EPA registration is so lacking in valid testing that the Forest Service could not rely on registration as any indication of safety and has managed our national forests very successfully without their use since 1984. (Save Our Ecosystems v. Clark Nos. 83-3908 et al. (9th Cir. January 27, 1984)
For ODF to rely on EPA registration is as unacceptable as it was for the Forest Service.
Therefore, Oregon Department of Forestry should at the very least admit its wilful ignorance of the effects of herbicides on all life forms, and grant the people of our county the right to grant or withhold their fully informed consent to being exposed to untested poisons.
Submitted by:
Carol Van Strum

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