Maui Environmental Assessment
Sample Comment
I am OPPOSED to this “Mosquito Suppression Environmental Assessment – December 2022” for the island of Maui. I demand that the State of Hawaii and its multi-agency partnership Birds, Not Mosquitoes complete a detailed, full scope Environmental Impact Statement (EIS) documenting the impacts to our native birds, environment, and public health.
This planned project is a dangerous experiment on the land, birds, wildlife, and people of these islands. The biopesticide mosquitoes come with many risks, including horizontal transmission of the introduced bacteria strain, increased pathogen infection in mosquitoes, irreversible evolutionary events, population replacement, accidental release of lab-reared females, creation of lab-strain females in the wild, horizontal gene transfer, biopesticide drift, and mosquitoes becoming a better vector of avian malaria and/or West Nile Virus (human and bird). Peer-reviewed studies document these concerns.
The Maui Environmental Assessment (EA) lists numerous potential impacts, including wildland fire, noise effects on wildlife, disturbances to nesting and roosting of special status wildlife species, adverse impacts on critical habitat, threats to endangered nene and Hawaiian waterbirds, risks to forest birds and bats, native plant disturbances and erosion, transport of invasive weeds and diseases/pathogens, and threats to human health and safety. The effects of the release of mosquito packaging on the environment have not been addressed.
Environmental Justice is a concern, and potential disturbances of traditional cultural practices are noted in the EA. Seven Native Hawaiian lineal descendants and cultural experts interviewed all expressed concerns about the impacts and effects this project could have on cultural resources and traditions, native birds, public health, wildlife, and our fragile ecosystems. As a result of their location, cultural practices, and other factors, Native Hawaiians may have atypical or disproportionately high and adverse human health impacts and environmental effects from exposure to the biopesticide.
The Maui project area covers 64,666 acres. The state intends to release between 50 and 6,000 mosquitoes per acre per treatment (up to twice per week), amounting to up to 775,992,000 mosquitoes per week – over 40 BILLION per year just on the island of Maui!
Per the U.S. Department of the Interior Strategy, “Wolbachia IIT is a novel tool for conservation purposes and its degree of efficacy in remote forest landscapes is unknown.” This project is an experiment on Hawaii’s people, wildlife, and ‘aina. The outcome is admittedly unknown. Human disease vectors are involved, and the informed consent of the public is required. Testimony has been over 75% opposed. Recent public comments on the HDOA’s EPA Application for Emergency Exemption are over 95% against the use of this biopesticide. We do not consent.
Who will take responsibility if something goes wrong – the federal government, the State of Hawaii, agency partners, private landowners? The scope, risks, and experimental nature of this plan require a detailed EIS. Safer alternatives haven’t been considered. Conflicts of interest haven’t been addressed.
I do not accept the Anticipated Finding of No Significant Impact (DEA-AFONSI) for the “Suppression of Non-native Wild Mosquito Populations to Reduce Transmission of Avian Malaria to Threatened and Endangered Forest Birds on East Maui” Environmental Assessment. I demand an Environmental Impact Statement.