Our written testimony to the EPA on Glyphosate

In 2016, our non-profit organization The Immediate Life, Inc. sent 210 Freedom of Information Act (FOIA) requests to school districts, state, county and city parks departments across the country. We requested all public records describing the use of glyphosate on public spaces, parks and playgrounds.

We submit our “U.S. Map of Poisoned Parks and Playgrounds” as evidence of the overwhelming ubiquity of this poison in our nation’s public spaces. The map reveals more than 22,567 toxic sprays financed by tax dollars. View the map at www.revbilly.com/nationalmap. The data set is available to the public upon written request to marnie@revbilly.com.

We are compiling spraying data proximal to areas frequented by children- parks, playgrounds, and schoolyards.   Even as scientific studies accumulate to the level of consensus associated with the condemnation of asbestos or lead in paint, there has been steady use or increases in spraying frequency and dosage in this sample parks and schools.

This map is only the tip of iceberg. In some ways what is not on this map is far more disturbing than what is on it. This map shows data from only 27 agencies out of a minimum 18,000 incorporated jurisdictions in the United States that we believe use glyphosates.  This map does not include consumer use, public utilities, highway departments, transportation, golf courses, cemeteries and private recreation areas, not to mention the vast acreage planted with GMO and conventional crops. 

We also confirmed that the States of Alabama, Arkansas, California, Colorado, Delaware, Iowa, Michigan, Minnesota, New York, Ohio, Oregon and Texas spray glyphosate on their state park lands. Bear in mind that every state park system for which we have requested data so far has evidence of spraying. We would reasonably expect to receive park data from every state.   With one exception every single city and town has confirmed that they spray glyphosates on public places. Hampton Township, MN, population 689, and 10 school districts reported that they DO NOT spray glyphosates.

Additionally research conducted by University of Montana researchers Viktoria Wagner and Cara Nelson, along with ecologists Pedro Antunes of Algoma University and Michael Irvine of Ontario Ministry of Natural Resources confirms glyphosate applications by the National Park Service, Bureau of Land Management and Bureau of Indian Affairs. They discovered that more than 1.2 million acres of U.S. federal and tribal wildlands were sprayed with about 200 tons of herbicide in 2010. The study found glyphosate was the most commonly used pesticide.

“The numbers are much less than those for croplands, but they are astonishing,” said Wagner, a former UM postdoctoral researcher who led the study. “Imagine: The wildland area sprayed by herbicides in that year is comparable to 930,630 football fields, and the amount of herbicides used equals the weight of 13 school buses.”

Glyphosate has not been studied at these levels of exposure, nor has it been studied as it is actually used in the field, in combination with carrier chemicals and surfactants.   Given the controversies surrounding glyphosates “safe use”, indeed the very ones that have prompted this critical hearing, and having ourselves encountered the almost absurd variety in record keeping by local agents we feel it is important that the EPA design and swiftly implement a comprehensive data collection system for glyphosate.

Reverend Billy and The Stop Shopping Choir support a ban on the use of glyphosate in the United States until glyphosate proponents scientifically prove that it is safe for human health and the environment with studies not funded by the chemical industry. In accordance with the Precautionary Principle, we demand the EPA and the FIFRA Scientific Advisory Panel examine the full range of alternatives to glyphosate including certified organic alternatives and complete elimination of the use of glyphosate.

Until this virulent poison is banned, parks and school systems should record spraying data in a comprehensible, uniform way that public health officials, scientists and citizens can make use of. Many of the data sets on this map come from handwritten documents with confusing geographical information.  Some record dilution, some do not; some list cross streets, some do not.


None of this would matter if glyphosate were not the toxic substance it is known to be.  Citizens have a right to know how and where their tax dollars are being spent.  How and where the government applies these chemicals could also eventually be a matter of economic importance to these same local governments should the ample evidence linking glyphosates to many diseases be given its full hearing.

Additionally this information will be useful in determining the true impact of glyphosate on soil and water and its negative effect on biodiversity.

Thank you for your consideration.

Submitted on October 4, 2016 by Reverend Billy Talen and The Stop Shopping Choir, PO Box 1556, New York, NY 10013, www.revbilly.com.