Vermont Legislature SmartTranscripts:

[Rep. David Durfee (Chair)]: Alright. We're good to go.

[Laura Kiesl]: Hello. So my name is Laura Kiesl. I actually am a former Vermont resident and a UVM alum. I received my master's from the Rubenstein School of Environment and Natural Resources back in 2010. So my background is in natural resources management and conservation biology. Currently, live in the Boston Metro Area and I work in environmental, in conservation work and as an environmental writer. And I actually have a book forthcoming next year on the impact of anticoagulant rat poisons in The US. So I've been down the rabbit hole of research on this issue for the past several years. So I'm just going to talk, I might talk ahead of the slides, but I just wanted to have them in the background to illustrate some of what I'm talking about. So in 2021, Eschar, the second generation anticoagulants, killed the first bald eagle to hatch in my town, which is Arlington, Massachusetts. It was the first bald eagle to hatch in a century since DDT had eradicated the species from the state. And it was the second eagle to die in the Boston Metro Area from escar just within a six month period. The first eagle died on top of her unhatched eggs. That is the picture in the slide. She was also gravid. That means carrying additional eggs, and that had caused her to have an internal hemorrhage that killed her. And that is the eaglet that died, that's when she was a nestling and the bottom right is when she was a fledgling only a couple of weeks before she died. C25's nest was surrounded by buildings containing dozens of bait stations applied by pest control companies that contained escar. I regularly witnessed C25's parents bringing her dispatched rats. At one point, I could even see the splattered bait from her disemboweling a rat on C25's feathers. And I don't know if you can see it, but in that picture, might notice there are some, like what looks like green paint splattered on her wing tips and legs, and that is from the bait. She's eating a rat in that photo. In spring twenty twenty two, my town also lost nearly an entire family of great horned owls, a mother and her two fledglings, to these same rodenticides. This led to And those are the That's the mother and her two fledglings. This led my town to becoming the first municipality to pass a public lands ban on escars in the state of Massachusetts and to file a petition with the state requesting permission to ban it on private properties as well. Since then, dozens of other municipalities in Massachusetts have followed suit. Arlington has reported no adverse impacts to the economy, or in any other way since implementing this policy. In early twenty twenty three, C25's mother, MK the Bald Eagle, also died in part due to complications of eschar's poisoning when one of her lungs spontaneously hemorrhaged and she aspirated on her own blood. In addition to the loss of these eagles, my nonprofit organization, Save Mass Wildlife, helped fund the liver panel testing of 40 dead animals found in the Boston MetroWest area between 2024 and 2025. And these were just the ones we got to before their bodies disappeared, either were disposed of or scavenged. Virtually all of these animals had been exposed to anticoagulants, and all but a few tested in the lethal range of exposure and exhibited severe internal or external bleeding. The animals impacted by these lethal levels in the dataset included red tailed hawks, barred owls, but also Cooper's hawks, great horned owls, an eastern screech owl, a fledgling saw whet owl, several skunks, a rare gray fox, which is a species of greatest conservation need in our state, an Eastern coyote, a coyote puppy, an Eastern chipmunk, an Eastern gray squirrel, and a great blue heron and snapping turtle, the latter two of which are the first fatalities to be correlated to these poisons. While not in the lethal range of exposure, we also found exposure rates in songbirds and shrews showing how widespread these poisons can be. Like DDT, anticoagulants bioaccumulate in the bodies of both prey and predator and bio magnify as they work up the food chain, pervasively infiltrating the wild food web. These poisons primarily kill predator species by secondary exposure, meaning the rodent is the poison source. As such, there is no appropriate way that these poisons can be applied that will eliminate or meaningfully reduce secondary exposure. I heard the testimony about improper consumer use and improper application, meaning more animals poisoned, but that's not really the case. The whole way that these bait stations work is the rodent goes into the box and exits into the outdoor environment where it is almost always eaten or scavenged eventually by a predator. And that is how the poison source impacts the wildlife. Whether placed by a general consumer or a pest control company, anticoagulants will continue to kill wildlife as long as they are in use. Available data indicates that the largest global purchaser and applicator by far is the pest control sector. While private households are the smallest share of users, agriculture is the second largest user and applicator of these poisons after pest control companies. So it is not private consumers from the data that I can find, and I can cite my sources. I have found no data that found that consumer use is a leading cause or applicator of these poisons. As a conservation biologist by academic training, I can tell you that decimating predators can work to increase their prey by inciting what is known as a top down trophic cascade. One grade horned owl can kill and consume over 4,000 mice and well over 1,000 rats a year. If such an owl dies by secondary poisoning, that means many of those rats the owl would have lived on to eat, now reproduce and create more rats. There is not a single study, and I was actually very surprised about this when I first ventured into this project, but there is not a single study that shows that these poisons have at all reduced rats in any contiguous landscapes, like the Lower 48 or Continental United States, or reduced the diseases associated with rodents. While rats and mice do pose some valid public health threats, these threats are often well overblown by the pest control industry. So for instance, I heard the word plague used several times so far. Plague is virtually nonexistent in New England, and hantavirus is extremely rare in our region. There are actually only two to seven cases in the entire country of plague per year, and they're all out West. And often they aren't even from rats, but the source is from other rodents, wild rodents like prairie dogs. In fact, what data exists also shows that rat populations have only risen with the increase in these use of rodenticides and especially eschar. And that rats exposed are more instead of less likely to have and transmit certain diseases. For instance, a 2021 study found that rats with anticoagulants in their system were much more likely to both have and transmit leptosp irosis. Also for studies of exposure rates here in Massachusetts, we're kind of like ground zero. Tufts Wildlife Clinic is like the leader of research on rodent exposures in raptors. And in 2017, they found a ninety six percent exposure rate among the dead raptors they necropsyed and liver panel tested. This went up ten percent from just five to six years before. So it went up from eighty six to ninety six percent. And then a couple of years later, they duplicated the study again, this time only in red tailed hawks, they found one hundred percent exposure rate in those dead animals that they surveyed. Meanwhile, Tufts also looked at the use reports from pest control companies and found that in 2015, so the same year that EPA restricted use on escarz, that three of the four escars went up 50% each in terms of their use by pest control professionals. Many rats and mice are often biologically resistant to these anticoagulants. The whole reason we have second generation anticoagulants is because they develop such robust resistance to the first generation. But resistance has now been documented in almost all populations tested of rats and mice in the second generations as well. This means that these mice and rats can eat the bait for prolonged periods, sometimes even indefinitely, and not be impacted. But their predators, have much lower birth rates, cannot develop this kind of resistance. So what you're creating is this mismatch where you have these super resistant rodents, but you're killing off their predators. In this photo right here, this is from New England Wildlife Center. They get between one and two hundred patients a year with anticoagulant poisoning. And this is just one wildlife rehab center in one section of the state. And they were noting that whereas ten years ago, it might take a few weeks to get the poison out systems of these animals, it's now taking months, and that's of the animals that survive. In this photo, this is a baby great horned owl. His two parents and one of his siblings all died. They've tried desperately to save him. He was bleeding from every orifice. They even gave him an emergency blood transfusion from another owl at the facility. He still died. The only survivor was the third sibling. It took nine months of intensive vitamin K supplementation every day until this owl's blood would clot on its own again, and it could be released into the wild. This issue is why I am part of a legal petition in our state of Massachusetts with Harvard is actually our pro bono legal representation to try to get the state to suspend registration of these anticoagulant rodenticides. For my book, I interviewed the country's leading rodent control expert, Bobby Corrigan, and he has stated on the record that escars are, quote, the DDT of our generation, end quote, and that they need to be banned across the board. Meanwhile, first generation anticoagulants are also pretty insidious in how they work up the food chain. Studies have found that FGARs can lead to compromised immune systems in mammals, leading some of them to be susceptible to fatal cases of mange. In some cases, they were causing plummeting of entire populations of bobcats over in California. And that they also can adversely impact the thermoregulation in raptors. The fox that died in my town, a gray fox, it was Eschar's actually that killed it, not escarz. So despite the fact that these anticoagulants have been poisoning thousands to tens of thousands of children annually in The US, the EPA did not consider pulling escars from most consumer shelves until they were sued by environmental justice organizations. So I'm just going to backtrack and go through the slides. So these are just some of the photos of the animals we picked up in our study. And again, all of them virtually had eschar's exposure and lethal rate. It's not just raptors, though raptors do bear the brunt of poisoning. We've had many other animals that die. The mesocarnivores like opossums, raccoons, skunks are very susceptible. Out in California, this is felling cougars. Fishers are very susceptible. Our wild canids like foxes and coyotes, that picture in the top left hand corner, that's the coyote puppy that died. It had the highest escorts rates in our dataset. And as you can see, very severe cases of mange. And even we're getting more non typical species, like the great blue herons, like the snapping turtles as well. Pets are also very susceptible to rodenticide poisoning. Basically, all rat poisons are highly toxic to pets, but the anticoagulants are the leading cases that veterinarians see. MSPCA gets between forty and sixty cases. Again, this is just one hospital a year of rodenticide poisoning, and almost all of them are anticoagulants. And if the animal survives, and many of them don't, costs usually exceed $5,000 and weeks of supportive care. This is one dog that survived, but it did cost $6,000 and it was like a month of intensive care until her blood could clot on its own again. That is actually the graph by Grand View Research from 2023 that shows that pest control companies are the leading applicator and consumer of all rodenticides, but the anticoagulants are almost 80% of that share, with agriculture coming in second. And as you can see in that lime green bar, that is private households. So they're the smallest share. And as I mentioned with the EPA, I know a lot of times folks mention, well, the EPA allows these, but the EPA has come under a lot of scrutiny for allowing a lot of chemicals they probably shouldn't that have caused cancer, that cause all these sort of environmental impacts. There are a bunch of problems with whistleblowers saying that they were fired or threatened if they go public with the findings of their toxicity assessments. So I would take any kind of argument that the EPA allows these with a grain of salt, especially in the current administration, which is actually waiving toxicity testing by the hundreds for the chemicals that they're studying. And these are just some photos around town of broken open bait stations. The two ones on the left are ones that I've taken pictures of, and these are ones that have been distributed by pest control companies. They can very easily be broken open by raccoons, by possums, by squirrels like the bottom one. Those were squirrels that broke open those bait stations, and they'll distribute the poison. The right hand picture is by a wildlife rehabber that found a possum that had gorged itself on the poison inside. And just to sort of end, I just want to mention California has had a moratorium now for several years, first on the escaras, but they added the escars in last year. And I know some pest control companies have said that they're having some kind of unprecedented ratmageddon there in California, but the data does not actually show this. This is from actual public records requests that show that as of last year, rodent sightings, which is the proxy by which rodent populations are determined, were at a ten year low. That doesn't necessarily mean that's correlated to the moratorium. Rodent populations ebb and flow naturally, but it does at the least show that there is not an active ratmageddon in the immediate aftermath of restricting these poisons in many sectors. So just to close-up, and I'm glad to answer questions, I just want to also point out that the same industries that are actively lobbying against a meaningful prohibition on anticoagulants are the same that spent the equivalent of $1,400,000 smearing Rachel Carson back in the 1960s and attempting to discredit Silent Spring, using many of the identical arguments about, we're going to be overridden with disease and we're going to be overwhelmed with vermin. Really, as some others have pointed out, sanitation and exclusion are the best ways to reduce rodents. I don't think you really want rat poisons in or near restaurants. Mice, for instance, house mice are known to actually pick off parts of those pallets and bring it with them wherever they're burrowing. And unlike E. Coli or salmonella, which can be killed by disinfectant cleaning or heat, you can't kill rodenticides if that gets in someone's food. And there have been outbreaks like that before. Those people are winding up in the hospital with bleeding issues and it could be very dangerous. So I just would end there. Thank you for listening and I'm glad to answer any questions.

[Rep. David Durfee (Chair)]: All right, good. Thank you, Laura. If you want to unshare or if you want, maybe leave it up in case there

[Laura Kiesl]: are questions I'm you want to go fine with either.

[Rep. David Durfee (Chair)]: Okay. Let's see. Representative O'Brien had a question, I think. Yeah.

[Rep. John O'Brien]: Laura, could you just speak to how something like songbirds pick up rodenticides?

[Laura Kiesl]: Well, there's a few different ways they can. Some studies have found that some songbirds will actually go inside these bait stations and they'll nibble on the bait, especially like the invasive house sparrows. They've done studies where they've observed them both in labs and in certain pilot areas where they've looked, and they will go inside the bait stations and eat this bait directly. But also insects eat the bait, and then birds eat insects, and that's how it's getting into them. And some of the larger songbirds like grackles, blue jays, and crows do eat mice. So it gets into the larger ones that way, like the corvids.

[Rep. John O'Brien]: But also, if there was a dead rat or mouse with maggots, etc. In them, and then those things get eaten.

[Laura Kiesl]: Yeah, they found that sometimes the carrion beetles, the maggots, the animals that go inside the animals that have died from these, that other animals are picking them out. So it can get into the food chain that way as well, yes.

[Rep. John O'Brien]: All right. Thank you. During

[Rep. Richard Nelson (Ranking Member)]: your testimony, you talk about escaras a lot. I have no idea what you're talking about. What is that?

[Laura Kiesl]: So those are the anticoagulant rodenticides. Sorry if mentioned it quickly, I think, as I was breezing through. So second generation anticoagulant rodenticides, or SCARs is their short All

[Rep. Richard Nelson (Ranking Member)]: right. I just wasn't following the script because you're switching back and forth between, and I wanted to make sure you've

[Rep. David Durfee (Chair)]: done Representative Nelson.

[Unidentified Committee Member]: Yeah. You you mentioned that California hasn't had this rat explosion. I'm wondering if you could speak to what are the strategies that you're aware of that California is using to control the rat population with the rodenticide ban that they have instituted.

[Laura Kiesl]: Sure. And I do wanna offer the caveat that there are several sectors that are exempt from that moratorium. Agriculture is a big one. I know that some environmental advocates are concerned about that exemption because agricultural lands are often used as corridors by wildlife. But for those places where the sector where the moratorium is active, again, there's been a lot of work on sanitation and exclusion. There's been actually a huge increase in pest control companies and exclusion focused companies doing a lot of that work, shoring up the infrastructure, a lot of improved waste management. There are a lot of fertility control pilots going on in California. I know someone was testifying earlier about the rodent birth control. There are smart boxes, which are those high capacity electronic traps. Those are being piloted a lot in California. They are here in Massachusetts too, with a lot of the towns that are putting in the public lands bans. And so I think that's a big part of it. Another thing is they're doing more. Some of the farms that are not using the rodenticides are putting in a lot of nest boxes for owls and perches. And there was a big study in California that found They compared two sites, one that used the anticoagulant rodenticides and one that didn't use any poisons, but put in a lot of nest boxes for owls and perches for hawks. And they found that the one, the latter site that encouraged the predators had far superior rodent control by more than 50% than the one that used the poisons. So I know that a lot of, especially like the agricultural places that are not using the poisons are using that as well as part of their IPM.

[Unidentified Committee Member]: Thank you. That's very helpful.

[Rep. David Durfee (Chair)]: Laura, missed that you've that your town of Arlington, Massachusetts has a ban?

[Laura Kiesl]: Well, public lands ban, because similar to most states, including Vermont, we are not allowed to ban it on private property without state permission that we have to get by legislation. Pest control companies lobbied for that thirty years ago after the Supreme Court said that local communities could have some kind of agency. They panicked, they went around to all the states and lobbied the states to take that away from communities. So we banned it on our public lands, and I know some 40 other communities in Massachusetts have as well banned it on their public lands. And about 15 municipalities, including our own, have current legislation pending in the state house asking for permission to also ban it on private properties, since obviously that is also where a bulk of its use is right now.

[Rep. David Durfee (Chair)]: Right. Okay. Representative Burtt.

[Rep. Gregory 'Greg' Burtt]: Just curious how the fertility method works and how that can, be effective on the rats and mice, but not unlike a poison, it doesn't

[Laura Kiesl]: transform So into it has a much shorter half life. It is metabolized within minutes in the body. So just not to conflate, but you know how a person is taking birth control pills, they have to take the pill every day because their body excretes it by the next day. And so that is why with this fertility control, it usually is a bait you leave out and the rats continue to eat it because they do excrete it. So it's one of those things where it knocks down their fertility. It doesn't render them completely infertile, but it knocks down their fertility rate significantly. And that can still over time help knock down their numbers because they can have hundreds of babies in a year and now they're maybe having dozens instead of hundreds or scores instead of hundreds. And over time, it's really more of a complementary thing to do in addition to sanitation and exclusion, or maybe some supplemental trapping. I wouldn't have something just be about birth control. I would have it as part of that bigger package. But it helps knock down that population so these other things are more effective. But yeah, so it metabolizes within minutes. Whereas the anticoagulant rodenticides, they get stored in the body. They get stored in the liver, they get stored in the fatty tissue, and then they just stay there for many, many months, over a year, inside the liver. And that is why they infiltrate the food chain so heavily, because they don't really go away once they get inside your body without a lot of work. That's why the wildlife rehabbers are struggling to get these animals to excrete it and flush it from their body. Did that answer your question?

[Rep. Gregory 'Greg' Burtt]: Yes. Thank you.

[Rep. David Durfee (Chair)]: Yep. Question. Laura, thank you very much. We're about at time. So I think we'll wrap it up here. And just I'll say again that you've got the slides and I think everything that we saw today on the screen, and even that was handed out, is also on our websites.

[Laura Kiesl]: Okay. Thank you very much. I appreciate your time.

[Rep. David Durfee (Chair)]: Thank you. Take care.

[Laura Kiesl]: Bye.