The Minnesota Department of Agriculture “Proposed” Aerial Spraying of Ely for Gypsy Moths

The Minnesota Department of Agriculture, MDA, is proposing to spray for gypsy moths over most of downtown Ely and parts of wooded areas south of Ely. The proposed spray zone of 565 acres  is shown below.  The application rate for the agent Foray 48b, manufactured by Valent BioSciences, is 1/2 gallon per acre.  That will mean that 5 plus 55-gallon barrels of this agent will be evenly distributed over Ely (twice, 10 days apart).

Sign our Petition – Say No to Aerial Spraying of Ely!

        Sign our Petition – Say No to Aerial Spraying of Ely!                                            Sign our Petition – Say No to Aerial Spraying of Ely!

Ely G.M. Spray Zone

Let’s start with the most important information first, what you really should know to make an informed decision about the aerial spraying of Ely:

To learn more about Foray 48b and Btk:

In-depth report on health and environmental risks associated with Foray 48b and Btk:


The upside of getting rid of a few Gypsy Moths found in 2015 is, it is a plus for the timber industry outside Ely.

The downside of  blanketing the town with a pesticide designed to kill one very specific critter, but in actuallity kills hundreds of other species of moths and butterflies, is:

  1. Research indicates aerial spraying is NOT necessary with the small numbers of moths present; ground-based treatments will work.
  2. Other Lepidoptera will also be killed. Minnesota moth and butterfly experts estimate hundreds of species of important pollinators will be killed.
  3. The documented and significant health side effects have been systematically downplayed!
  4. The known side effects appear to primarily come from the 87.9 % “OTHER INGREDIENTS” and BTk production impurities–NONE of which we are permitted to know anything about.
  5. The timing couldn’t be worse, as the busiest time of year for Ely businesses approaches with a high presenceof tourists.  Are these costs reimbursable to the city, to its residents?
  6. The actual cost to the city and its residents is unknown, and hasn’t been considered so far.
  7. Who should alert residents, businesses, doctors, hospital, at-risk individuals?
  8. What should those warnings say about safety, preventing exposure, what to do if exposed?  How will this be coordinated with a variable spray date, how much warning?
  9. Who will pay for medical expenses related to medical services required by the residents of Ely if needed?
  10. What will the costs be to the city to clean public areas and equipment?

The result has been that ever-growing number of people are deciding the aerial spraying of Ely is unnecessary and will do more harm than good.  They want a more targeted approach to solving the small gypsy moth presence in Ely.

The MDA-recommended reference book on gypsy moth research is “The Gypsy Moth: Research Toward Integrated Pest Management, USDA, Forest Service Technical Bulletin 1584 from 1981″

You can read this book for free online at Google Books with a Google Account (you will hve to login after clicking on the link to this research book). This makes this reference material searchable by topic so that you can find the pages that interest you the most.  Direct links from this page only worked part of the time, so please copy this address into your browser to see the book
I also have a hard copy from the MDA that you may borrow if you prefer; contact

Other links the Minnesota Department of Agriculture would like you to view are listed at the bottom of this page.

Images of male and female gypsy moths and their easily distinguished caterpillar:




MDA map of Arrowhead Region of norhteastern Minnesota showing the distribution of gypsy moths in 2010. When asked, the MDA representative stated it would look about the same today.

G.M. Distribution Eastern Arrowhead 2010


Concerns Raised in the Ely Community:  

One of the first to raise concerns was April Roy.  She has alergies, and is concerned for her son and herself. She eloquently explains the research she has done, with references, and concludes that aerial spraying is the least optimum solution at this time.  See her article first published in the Ely Echo a week ago.

Wisconsin Cooperative Gypsy Moth Program wrote: “Due to rare cases of mild, short-lasting allergic reactions to humans, you may wish to stay indoors with the windows closed or leave the area during a spray if you have severe food allergies or chemical sensitivities.”

Even a reference supplied by MDA, Bacillus Thuringiensis General Fact Sheet stated  that “evidence suggests that toxicity to these non-targets may be related to impurities from the production of Bt.”

One of the main concerns is the 87.35% “Other Ingredients”; here is the product label:

Other Ingredients 87.35%



The product ingredients are proprietary and will not be divulged. The manufacturer was kind enough to send this label and the product SDS, Safety Data Sheet, and had a Bt expert call to answer my questions. He was very pleasant to talk with and filled in some of the blanks in my research, but he also left much unanswered or unanswerable.

He admitted that most of the Other Ingredients were water but would not admit to any other ingredients or even if there were any other ingredients.  He said that many companies out there would love to make a product like they do. He also said it is just fermentation. So, either there are proprietary “other ingredients” or there is a very special “other process” they will not even hint at. And, that in my opinion is the rub. If I don’t know what it is, regardless of the assurances of the EPA, MDA, DNR or the Ely City Council, I wouldn’t recommend ingesting, inhaling or touching it.

When asked a direct question about the significance of small numbers of moths and direct ground spraying vs. aerial spraying here is what he said: For small numbers, 18 or so, (and then he remembered I had mentioned the number 14 so he threw in, maybe 14) direct ground application with BTk and then follow-up with Disparlure might do the job.

Those most vulnerable in our community: The young, the old, those with compromised immune systems, those with a preexisting condition, and those with allergies and chemical sensitivities-which in Ely is a large percent of the population. The Ely Bloomenson Hospital has recorded 143 adults and 63 children under the age of 17 with asthma. And, they were quick to add those are just the documented cases.  The hospital currently does not have the ability to extract the data for those with other compromising aliments.  How about the most vulnerable age groups?  Below is a chart for population by age in the latest draft of the Ely Comprehensive Plan document:

Ely Population by age group 2010
















Health-Vulnerable Citizens in Ely (nearly half the population)

Under 15 years of age:  450

Over 65 years of age:  775

With asthma: 206, Ely Bloominson Hospital reported asthma cases in 143 adults and 63 children younger than 17

Take a guess of the numbers of other vulnerable citizens
Pregnant mothers
Respiratory problems
Cancer patients
Sleep disorders
Chemical sensitives
Those with pre-existing medical conditions

A rough estimate, but a very conservative one, is there are over 1431 residents in Ely with health concerns that should not be overlooked when assessing the risk of introducing ANY further stress to their systems.




Information from other communities that have had health problems after their communities were aerially sprayed for gypsy moths with Foray 48B and research found that was not listed by the MDA as something Ely should review or consider (research by April Roy).  This is a must read to get a balanced view of the very real effects communities and individuals have experienced after aerial spraying with Bt. Click Here


Another major concern is the killing of non-targeted species of moths and butterflies:

Pollinators are extremely valuable to all of us.   We can no longer treat our pollinators as expendable or we will be pollinating our crops by hand with small paint brushes the way the Chinese have to in many parts of China.

One butterfly/moth expert retired from Minnesota state employment as a scientist said there would be hundreds of other moth and butterfly species that would be killed with the spraying of Btk.  He also said some, like the cabbage moth would be found active very shortly after the spraying and that some species would never return.  In addition it would take five to 10 years for the “re-assembly” of the remaining species in our area.

Robert Dana, PhD with the Minnesota Department of Natural Resources, St. Paul, MN  prepared a list of the specific species of concern during other spraying events along the North Shore. CLICK HERE TO SEE HIS REPORT AND LIST OF BUTTERFLIES AND MOTHS EFFECTED:

And, this study was done prior to spraying in Grand Portage Monument.

Species potentially vulnerable to the use of Btk to slow the spread of the gypsy moth, Lymantria dispar

The primary objective of this investigation was to evaluate which species of macrolepidoptera present at GRPO would be adversely affected if Btk were used to control the gypsy moth. Species whose larval feeding stage coincided with the timing of aerial applications of Btk to control gypsy moth larvae were considered to be the most susceptible. As June is the primary month for Btk application, species of butterflies and moths whose larvae were actively feeding in June were judged to be the most susceptible. However, the residual effect of Btk in July could also place species whose larvae feed in July at risk. Susceptibility of butterflies and moths collected at GRPO to Btk was evaluated by a search of life history data in various references and literature. The primary sources of life history data for butterflies were Holmes et al. (1991) and Scott (1986). The recent field guide on the caterpillars of Eastern North America (Wagner 2005), Wagner et al. (2001), and data from the Canadian Forest Insect Survey (Prentice 1962) provided much of the life history data.

Seventeen species of butterflies observed or collected at GRPO in 2008 were judged to be potentially susceptible to the application of Btk (Table 3), including E. phaeton, a rare and local butterfly known to occur at only one other site in Cook County (MacLean 2006). All other “at risk” species, although important members of the butterfly fauna at GRPO, are widespread, common most years and apparently secure (Holmes et. al 1991). Additional butterflies and skippers recorded from Cook County that would be potentially harmed by Btk application include Carterocephalus palaemon (Pallas), Colias interior Scudder, Colias philodice Godart, Enodia anthedon A. H. Clark, Euphyes vestris (Boisduval), Nymphalis milberti (Godart), Vanessa virginiensis (Drury), and Wallengrenia egeremet (Scudder) (Holmes et al. 1991; MacLean 2006). These species were not collected or observed in 2008 but likely inhabit GRPO.


Summary of an Email from reports on a New U.N. study of the health of World Wide Pollinators: (If we aren’t careful, we’ll be pollinating our crops by hand with small paint brushes like the Chinese) See article: Decline of bees forces China’s apple farmers to pollinate by hand

The new study finds that bees, butterflies, and other pollinators are in even greater danger than we previously thought — and may even be at risk of extinction.

Conducted by a top team of 70 U.N. scientists, the report is the first-ever global study on the health of bees and other pollinators. And the results are much, much worse than many expected.

Without bees and other pollinators, the world will face a global food crisis.

Almost 90 percent of all flowering plants rely on pollinators — including 75 percent of the world’s food crops.

Of course, we’ve known for a long time that bee populations are in decline. But this study shows that the threat of global extinction has risen to a whole new level.



Sites with information the Minnesota Department of Agriculture would like for people to read:

They would like for us to look at the above 1995 Environmental Impact Statement “Gypsy Moth Management in the United States: A cooperative approach” and the Record of Decision by the USDA, FS.  I’ve requested a copy of the current and specific EIS for Ely and may have a copy by the end of this week, Friday March 11, 2016 with a deadline for comments being Tuesday March 15, 2016 to review and comment on the EIS.  So we will have one weekend and 2 days, something feels, as does the rest of this project, very fishy about the MDA tactics.


Other Sites with information you wil find informative (much of which was never mentioned by MDA and is contrary to their sales pitch): 

The History, Biology, Damage, and Control of the Gypsy Moth, Porthetria

To learn more about Foray 48b and Btk:

The U.S. EPA inerts list is available at

In-depth report on health & environmental risks associated with Foray 48b and Btk:


Alternatives to Aerial Spraying for Gypsy Moths:

Squelching gypsy moths: what’s hot and what’s not in the arsenal against leaf eaters.

Gypsy Moth Fungus





3 comments to The Minnesota Department of Agriculture “Proposed” Aerial Spraying of Ely for Gypsy Moths

  • admin

    Gypsy Moth Spraying Not as Harmless as Stated
    April Roy

    As you may have heard, Ely is set to be sprayed for Gypsy Moth this coming summer. The Minnesota Department of Agriculture would have us believe that this spray, (using Foray 48b – an insecticide with the active ingredient Btk) is harmless because it has been used for over 70 years. And others go on about how Foray 48b is certified to be used in organic farming…as if that somehow means there are no health risks.

    However, they have failed to mention that there ARE health risks to humans as well as to other beneficial insects and animals in the area.

    First I would like to appeal to your common sense. Just because a chemical has been around for 70 years doesn’t mean it is safe. Cigarettes have been smoked for a much longer time than Foray 48b has been around and only in our recent history have cigarettes been proven to cause cancer and STILL companies that manufacture smokes have not been forced to stop, nor do people stop smoking them. There was a time when cigarettes were “harmless”. But these companies are making tons of money and generate tons of tax revenue. Why in the world would our government put a stop to something that is making them money?

    And why in the world would our government put a stop to something as “benign” as Foray 48b when these Gypsy Moths threaten the very livelihood of agriculture? Is agriculture more important than human well-being? Is money more important than the accumulated health risks for us and our environment down the road?

    The scary thing about this Foray 48b, that they are planning to spray directly over parts of our city, is that there have not been ANY long term studies on the health risks to humans or animals. But there HAVE been short term studies done by independent research groups that show exactly the opposite of what we have been led to believe. This is what I am going to share with you.

    The people most at risk for health complications from the Foray 48b aerial spray are the elderly, children, folks with food or other allergies, those with asthma or other lung conditions, anyone with digestive or bowel conditions, those with weakened immune systems and anyone with general sensitivities. BUT – average persons who are in generally good health have been affected too.

    Aside from the undeniable health risks, there is also the question of “why”. On the MDA website and in the brochure they hand out it states that the spraying “slows the spread”. In other words only delays the inevitable costs and burdens of established moth migration. They can’t assure us that ANY amount of this spraying will kill all the caterpillars. If this treatment is only delaying and not preventing, what is the point spraying? Won’t the cost of the treatment be an added tax burden on the Ely/Minnesota residents on top of the inevitable burden of the moths themselves in the long run? And if this first year spray does nothing to curb the Gypsy Moth spread here, will we have to do it again next year…and the year after and for how many years? And for how many years will we all be subjected to these chemicals?

    The MDA and other agencies like it, would have us believe that the Foray 48b dissipates in a matter of 30 minutes and certainly in a matter of days. This is either complete ignorance on their part or a lie because there are studies that confirm viable Btk spores have been found airborne in and near a spray zone for up to a year. That means we could be breathing this stuff till 2017 in Ely.
    Not only that, but viable Btk spores have also been found 24 hours post spray INSIDE sealed buildings. That means inside houses and stores and schools and even the hospital.

    There is also a concern about these caterpillars/moths growing resistant (this is very common with any pesticide) to the Foray 48b which indicates the use of more and more and more, year after year. And of course costs more money, a burden the tax payers will have to bare.

    Maybe nothing will happen if they spray. Maybe everyone will be just fine…but maybe not. What if you or I are one of the select few that DO have adverse symptoms? Personally, I am concerned for people like myself and my son who DO have anaphylactic food allergies and other sensitivities that have made us prone to symptoms. What about you? Do you know FOR SURE that this won’t affect you? And what happens if even just one of us suffers from symptoms after the spray and we need to be treated medically? Who is going to take responsibility for us? Is the city going to pay for our medical treatment? Will the State? Will the MDA?

    This spray is something I do not consent to because I am more concerned for mine and others health rather than the business of agriculture. If something happens on MY property that affects MY health when I distinctly object, that is a violation of my rights as a citizen of this state. So WHO will take responsibility for it if it happens.

    Here is information about the interactions with humans as documented by other sources:

    – In 1991 French scientists called for a ban on Bt containing pesticides after finding that inhaled spores cause lung inflammation.
    – Direct quote from the Btk Safety Review – “Though much has been written regarding the active ingredient Btk, little is known about the short-term, long-term or synergistic effects of these potentially hazardous components of the Foray 48B in humans or in the environment.” End quote.
    – Permits in Canada were cancelled by the Environmental Appeal Board after serious health concerns arose, they said there was too great a risk posed to human health.
    – Asthma rates doubled in New Zealand between 2002 – 2004 for boys ages 0-4 in the spray area. Rates increased for girls ages 0-4 at 50% and ages 5-14 at 80%. Monthly hospitalizations rates among exposed group gradually increased during the duration of the spraying.
    – According to Washington State Department of Health in 2002, adverse effects were reported after a spray in 59 people. Cough, wheezing, headache, trouble breathing, sore throat, nasal congestion, irritated eyes, skin rashes, upper respiratory symptoms, flu-like or viral symptoms, worsening of asthma and allergic bronchitis were among the reports.
    – It is possible but unknown whether Foray 48B is a carcinogen because no long term studies have been done.
    – It is possible but unknown whether Foray 48B affects reproductive health, no long term studies have been done, however it has been known to produce fetotoxicity in animals.
    – During the Washington Gypsy Moth spray program, over 250 people reported health problems, 6 were treated in the emergency room for severe lung distress.
    – During one Vancouver spray program, over 200 people reported health problems, mostly flu like or allergy like symptoms.
    – While there are product inspections before a spray, it is possible for Btk products to be contaminated with other bacteria, thus compounding and worsening any possible affects if exposed.
    – Other symptoms reported from other areas are: bacterial gastroenteritis, abdominal cramps, vomiting, diarrhea, drop in blood pressure, infection of the eye and corneal ulcers, temporary but severe eye damage, neurological symptoms, musculoskeletal and endocrine symptoms, sleep problems, dizziness, difficulty concentrating, diarrhea, stomach discomfort and gas.

    Some information about the interactions with animals and insects:

    – Following the 1993 and 94 aerial spraying of Foray 48B over urban areas in British Columbia, reports came back on a variety of effects on a number of bird species including: bird feces turning black, bird feces with pieces of digestive tract tissue, dead fledgling birds, general lower bird populations , reduced wild bird song, dead domestic chickens, chickens with diarrhea.
    – In that same two year span after spraying in Canada, reports came in as follows: No honey bees from first spray to end of July, reduction in wasp population, ladybird population drastically depleted, wood bugs became speckled with unusual yellowish blotches, drastically reduced butterfly and skipper populations, population overgrowth of other caterpillar species outside the spray area, including tent caterpillars (otherwise known as army worms), mutated more aggressive tent caterpillars observed following year, first year spray did not eradicate gypsy moth population.
    – Numerous reports have been filed of adverse effects on aphid eating flies, ground beetles, certain mites and other beneficial insects.
    – Following the 1993 and 94 year of spraying, certain fish developed tumors and dead fish were found in susceptible populace.

    Information about Foray 48B and Btk, the active ingredient in Foray 48B:

    – Viable spores are known to exist for up to one year following application.
    – Insect resistance to Bt products have been well documented.
    – Water treatment does NOT destroy Btk spores and may persist in water supply for up to 200 days and in the water sediment for 270 days after application.
    – Btk spores can travel between 1- 12 miles outside the spray zone depending on weather.
    – 800 strains of naturally occurring Bt spores may be found in the soil, but aerial spraying of such spores and other chemicals NEVER happens naturally. Since there are no long term studies, we have no idea what kind of impact this kind of thing actually does to people or to the land and other life forms that live on it.
    – Because the 87% of supposedly inert ingredients in the Foray 48B is a secret, no one knows exactly what is in it except that it contains carbohydrates, preservatives, food additives, fermentation growth materials and anti-evaporants. Some of which are approved for use in food, but none of them for inhalation. And NONE of these chemicals have been tested for synergistic effects.
    – No one knows if they have sensitivity to this product until they are exposed. And even persons who were exposed once with no symptoms may become sensitive to it over time and develop symptoms the next time they are exposed.
    – Because Btk is used on farms that grow produce, if a person were to develop a sensitivity to it because of this spray, the next time they purchase produce that has been sprayed with Btk products it is possible for them to have a reaction to that produce and would never understand the correlation unless they were to hear and understand this information. It is entirely possible that there are far more health concerns relating to the Foray 48b because people and doctors do not draw the link between the spray and their health.

    Please, if you are in any way concerned about the spraying set to be done this summer, talk to our mayor or the city council. And I urge you to look into this yourself; don’t just take my word for it. I have provided just a FEW of the links that have compiled information about the foray 48b, take a look. Also, attend the public meeting on February 22 at 5:00 at city hall where you can ask questions.

    A short study published by PubMed – Lists that symptoms increases SIGNIFICANTLY following a spray

    Foray 48B Product label, Directions and Information:—usa

    Bacillus thuringiensis – Safety Review – This link provides resource listings at the end of the document.

    Journal Of Pesticide Reform – This link provides even more extensive resource listing at the end of the documentation.

  • jb

    My family moved from Agriculture and it’s spraying to get away from it so not happy that it’s here! jb

  • Edward Deacy

    DON’T Spray
    I was a USDA Gypsy Moth Trapper 42 years ago.
    It’s a waste of money, time, and poison !
    Edward Deacy

Leave a Reply

You can use these HTML tags

<a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <s> <strike> <strong>