• The primary ingredient to spray over San Francisco beginning this August hasn’t been determined yet – so no environmental studies can be done. But, the CDFA assures us, that’s not important: Whatever they choose, it will be safe and effective. Otherwise, why would they choose it?

• The secondary ingredients in previous sprayings (in Monterey and Santa Cruz counties) were not publicly disclosed in advance … and the state isn’t legally required to disclose them. Some of them got leaked after the fact, though, and were known carcinogens. BUT a CDFA official promises that will never, never, happen again. He promises.

• This will be the first time a spray treatment like this will ever have been used over an urban area. When Supervisor Gerardo Sandoval asked for a single scientific study demonstrating this would be safe, the CDFA’s director could not provide one. He did say there is a “consensus paper” of the appropriate government departments – but that’s not the same thing. Bottom line: They’ve never done this before, and don’t want to do a full study in advance.

• The CDFA has only determined that the spraying (whatever it is) will have a very small risk for the “general” population: they don’t know the risks for more vulnerable populations like the elderly, the asthmatic, or the HIV positive – some of whom might live around here.

• Numerous insect experts seem to think the spraying won’t work anyway: a UC Davis Entomologist testified there’s just no way the species will be eradicated from California.

Sandoval was on FIRE at this hearing: asking penetrating questions, picking up on small important details, and keeping the hearing moving smoothly. While Ross Mirkarimi was the only Supervisor who came out and said “I’m against this” right at the beginning, it was Sandoval’s questions that repeatedly highlighted just what was wrong with this picture.

The CDFA did have a few good moments. Director of Plant Health John Connell and other representatives were able to say definitively that everyone in affected areas will receive a notification, by first class mail, before every spraying; he was able to point out that it’s not the “kill the moth” part of the spray they’re still trying to determine – it’s chemical delivery system, which is a lot less threatening. And he brought a toxicologist along, Dr. Anna Feng, to testify that no, this really shouldn’t hurt anybody – at least not in the “general population.”

It was a good showing, but it was clear which way the chemical laden wind was blowing – the fact is that studies haven’t been done, and reasonable people can wonder “is this a public health hazard?”

So can unreasonable people, and as I write this the “public comment” section is dragging on, filled with weeping mothers holding their babies, people threatening to leave California if they’re sprayed, and comparing the CDFA’s spraying to the Nazi’s experimentation on unwilling human subjects.

Yeah, somebody actually said that. Is this really helpful? Because, not to put too fine a point on it, but the Nazis never showed up an environmental impact hearings. That’s not how they rolled.

Oh … there’s another Nazi comparison. I’ll bet you a Coke it’s 5 by the time the hearing winds down. Oh, and there’s a “Tuskegee experiment” comparison, too.

Wow – it’s vaguely comforting to know that there’s no public health problem so bad that San Francisco citizens can’t exaggerate it.

Three. Three Nazi comparisons. It’s what we do. Occasionally I try to steal a glance over at the CDFA representatives: They had no idea what they were getting into. Poor bastards. It’s going to get a lot worse before they agree to delay the spraying.