Dear Auckland Council,

Request to Auckland City Council, for information or advice shared between parks, roadside and vegetation management, senior management and elected members, including but not limited to the Healthy Waters department from June 2017-June 2020.

This includes information or advice coming from the Environmental Protection Authority to staff or elected members in ACC.

Please you supply emails, reports, memos or submissions discussing:
a). The soil half-life (the time taken for half of the herbicide to degrade), of glyphosate and its metabolite AMPA which is estimated by European Food Safety Authority to be Low to very high (DT50 = 2.8 – 500.3 d)
b). Laboratory results of testing in public parks, roadsides and drains of soil for glyphosate or AMPA to establish half-life under New Zealand conditions in public areas. Laboratory tests would include screening results for companion herbicides commonly applied with glyphosate to manage weed resistance.
c). Greater health risk to pregnant mothers, babies and children from low level exposures.
d). The length of time that signage is left out to inform the public and the discrepancy between the soil half-life and the time signage is left out. Or instances where there is no signage and the glyphosate formulation is sprayed.
e). The half-life of glyphosate in water which varies from 4 – 180 days, and the potential for the metabolite AMPA to accumulate in estuary sediment.
f). Cost-benefit analyses or economic or financial reports to understand cost/risk benefit for Auckland resident health loss and potential financial and budgetary gains from glyphosate use.

Supporting notes to the request:
Torretta et al 2018. Critical Review of the Effects of Glyphosate Exposure to the Environment and Humans through the Food Supply Chain https://www.mdpi.com/2071-1050/10/4/950
EFSA. (2015). Conclusion on the peer review of the pesticide risk assessment of the active substance glyphosate. EFSA Journal 2015;13(11):4302. https://www.efsa.europa.eu/en/efsajourna...

Yours faithfully,

J Bruning

Dear Official Information,

The response to this LGOIMA request suggests that Auckland Council has not taken adequate steps ensure public officials have access to the latest data on the glyphosate and its cancer risk, and the significant uncertainties that prevail, in order for sound and considered decision-making to occur.

a. Council makes no effort to reconcile the persistence in the soil (half life); and toxicity in soil following spraying. Nor do we see discussion on the significant body of literature demonstrating that glyphosate is not just cancer causing, but appears to be neurotoxic and endocrine disrupting. This deficient approach places the public at risk and is to all appearances at odd with officials obligations in law to protect public health.

Council has an obligation under the Health Act 1956 (S23.) It is the duty of every local authority to improve, promote, and protect public health.

b. Council could conduct soil tests in public areas where glyphosate is sprayed regularly, but has not done so. Label claims rarely hold up in a court of law, particularly when the published literature diverges significantly.

c. Unless Council is in the dark ages, Council will be aware of the greater vulnerability of the developing child. This is well established in science. See: Barouki, Gluckman et al 2012 Developmental origins of non-communicable disease: Implications for research and public health. The apparent inability, as Council has demonstrated from the response here, to conduct a cost benefit analsis that takes into account the potential cost of harm to the developing child should then be reflected in a precautionary stance that does not place a pregnant mother, infant or child at risk.

d. The science that has been supplied above harmonises with NZEPA literature which is predominantly supplied by the industry sector. It is significantly out of date. The continuing disinclination of the NZEPA to acknowledge the greater toxicity of pesticide formulations that the public are exposed to, in addition to the decades old knowledge that pesticides are likely to have low-level non-linear effects where they are more toxic at hormonally relevant level, reveals a regulatory agency that is unable or unwilling to keep up with science. Aquatic vertebrates are similarly vulnerable to glyphosate at hormone levels. Many of these are endangered species.

I strongly recommend that the Auckland Council and the NZEPA base their decision-making on European Commission decisions.
a. That chemicals banned in Europe are not permitted in New Zealand.
b. The use of plant protection products containing glyphosate are minimised or prohibited in areas such as public parks and gardens, sports and recreation grounds, school grounds and children's playgrounds and in the close vicinity of healthcare facilities.

Three court cases in the US have revealed the enormous body of evidence that indicates glyphosate-based herbicides are far more harmful than the restrictive literature held by the NZEPA indicates, particularly at hormonally relevant levels not considered by regulatory agencies. Paracelcus does not necessarily apply to toxic chemicals that act at hormone levels. Ensuring that pregnant mothers, infants and children are not exposed, can and should be the most important factor in decision-making.

The OECD points to our terrible cancer record. The recent decision of Council reacting to an badly-informed idea to harmonise glyphosate use should be celebrated, but more can be done to protect public health. Auckland families are the most important assets.

Yours sincerely,

J Bruning