June 21,
2022
California Air
Resources Board (CARB)
1001 I
Street
Sacramento,
California, 95814
Submitted Online
at http://www.arb.ca.gov/lispub/comm/bclist.php
Re: The 2022
Scoping Plan must include more ambitious organic agriculture and
pesticide reduction targets
Dear Chair
Randolph:
On behalf of
Pesticide Action Network and Californians for Pesticide Reform, we
thank you for the opportunity to comment on the 2022 Draft Scoping
Plan. We are encouraged that organic agriculture and pesticide
reduction have been included in the draft Scoping Plan for the
first time, and that they have been recognized for their
contributions to a safer, more climate-friendly agricultural
system. The draft Scoping Plan refers to the importance of safer
and more sustainable pest management, integrated pest management,
pesticide use reduction, and organic agriculture in meeting
California’s climate goals while providing significant public
health benefits. These are critical points that should remain in
the Scoping Plan. We also appreciate the reference to the
importance of the Sustainable Pest Management Working group’s
recommendations in achieving California’s climate
goals.
However, the
level of ambition of the Scoping Plan must be increased to maximize
the climate, public health and equity benefits that diversified
organic agriculture and reduced pesticide use specifically provide.
For instance, the organic modeling target is low and unambitious -
lower than the level expected to be achieved through current market
trends alone without action from the state. Meanwhile, still
excluded from the draft plan is a synthetic pesticide reduction
target, which would help CARB staff measure progress towards the
intended outcome of reducing pesticide use mentioned in the draft
plan.
The 2022 Scoping
Plan must increase the rate of organic adoption, adopt a measurable
pesticide reduction target, and provide support to impacted
communities in order to reach the state’s climate goals while
addressing the environmental injustices of our agricultural
system.
We urge CARB
staff to adopt the following recommendations, which are described
in further detail below:
-
Include an accelerated and more ambitious organic
agriculture target of 30% of agricultural acreage being organically
farmed by 2030
-
Include a measurable target of reducing synthetic
pesticide use by 50% by 2030 and highly hazardous pesticide use by
90% by 2050
-
Exclude herbicide applications from the Scoping Plan as
a climate-friendly management strategy for all land
sectors
-
Include a commitment to conduct further research on
pesticides, while also committing to research the disparate impacts
of pesticide use and provide support to communities affected by
pesticides
-
Remove the implication that the climate smart
agriculture practices included in the model would inherently result
in synthetic pesticide reductions
-
Deploy direct incentives to farmers to reduce pesticide
use, similar to financial mechanisms for healthy soils practices
and organic agriculture
1. Include an
accelerated and more ambitious organic agriculture target of 30%
agricultural acreage being organically farmed by 2030
We and our
partner organizations have been submitting public comment letters
the past year consistently recommending a target of 30%
agricultural acreage being organically farmed by 2030, similar to
the EU’s Farm to Fork commitment. However, the draft Scoping
Plan only includes a commitment to 20% of agricultural land being
organically farmed by 2045. That would mean that conventional,
industrial agriculture would still make up 80% of agricultural land
by mid-century.
This target does
not even keep pace with the current market growth of organic
production in California, where organic acreage increased by 44%
from 2014 to 2019, a growth rate
of roughly 7.6% per year. From 2019-2020, California organic
acreage grew 6% while sales of organic products increased
14%. At these rates,
organic agriculture would exceed the modest goal of 20% by 2045
even in the absence of any state-supported incentives or
regulation. Therefore, the Scoping Plan must establish a target
that goes beyond this baseline, and accelerate and incentivize
adoption of organic agriculture to take full advantage of the
public health benefits from reducing synthetic pesticide and
fertilizer use, the feasibility of expanding organic agriculture
quickly, and the significant soil carbon sequestration benefits
demonstrated by CARB’s modeling. We encourage CARB staff to
review our previous comment letters for scientific references that
demonstrate these benefits.
These benefits
can be achieved without sacrifices to competitive yields or
profitability. California Certified Organic Farmers (CCOF) has
compiled multiple scientific articles demonstrating that organic
agriculture can be adopted while maintaining competitive crop
yields. Furthermore, a
recent review of about 17,500 articles demonstrates that organic
agriculture typically outperforms conventional agriculture
economically because of lower production costs and higher
premiums. Therefore,
transitioning to organic agriculture results in economic benefits
for farmers as well.
2. Include a
measurable target of reducing synthetic pesticide use by 50% by
2030 and highly hazardous pesticide use by 90% by 2050
We appreciate the
inclusion of pesticide use reduction as an intended outcome of
transitioning the state towards climate-smart agricultural
practices and organic farming (p. 65). However, in order for CARB
staff to evaluate whether this outcome is being achieved, both a
target and progress towards that target must be measured. We
continue to advocate that the Scoping Plan include the European
Union’s Farm to Fork’s target of a 50% reduction in chemical pesticide use by 2030.
We also support a target of a 90% reduction in highly hazardous
pesticide use by 2050.
These targets
would ensure that the intended outcome of reducing pesticide use is
met, while maximizing the climate, public health and environmental
justice benefits of transitioning away from toxic chemical
pesticide use. We encourage CARB staff to review our previous
comment letters for scientific references that demonstrate these
benefits.
3. Remove
herbicide applications as a climate-friendly management strategy
from Scoping Plan for all land sectors
We remain
concerned that herbicide applications and chemical management were
modeled in the forest, shrublands and grasslands sectors. CARB
staff’s recommendation to reduce pesticide use to achieve
climate change and public health benefits in the agricultural
sector should apply to other sectors as well. The dangers of
chemical pesticide use to the environment, human health and the
climate are significant for all land sectors. In the forestry
sector, glyphosate is the most commonly used pesticide according to
the UC Davis PUR data
tool. Glyphosate has well-documented negative health and
environmental consequences. Most
notably Bayer - the manufacturer of glyphosate - has recently been
ordered to pay three CA residents
more than $100
million collectively in
damages after they developed cancer after using glyphosate or
RoundUp, and was previously
ordered to pay Dewayne
“Lee” Johnson - a California groundskeeper - $20.5
million. Thousands of similar cases are currently making their way
through the US court system.
The good news is
many other safer and more ecologically-friendly management
strategies exist to reduce the spread of invasive species in the
forest, shrubland and grassland sectors. And wildfire risk can be mitigated through other
effective strategies, such as Indigenous
cultural burns. Therefore, we
recommend that CARB staff turn to these alternative, safer and more
sustainable management strategies for all land sectors to avoid
incentivizing increased pesticide use and their associated risks in
the Scoping Plan.
4. Include the
commitment to conduct further research on pesticides, while also
committing to research the disparate impacts of pesticide use and
provide support to communities affected by pesticides
We appreciate the
draft Scoping Plan’s commitment to “conduct research on the intersection of pesticides, soil
health, GHGs, and pest resiliency via a multiagency effort with
DPR, CDFA, and CARB.” We have long advocated for more
research to be conducted on pesticides and their impacts, and this
commitment is an important start to closing this research gap.
However, this research must also focus on the disparate impacts on
communities of pesticide use. The health
impacts of synthetic pesticide exposure continue to fall primarily
on residents of color in California. At a minimum, CARB staff as part of the 2022 Scoping
Plan must analyze health impacts of proposed strategies on
residents in California as recommended by the Environmental Justice
Advisory Committee, particularly on people of color that bear the
brunt of many negative air and water quality
impacts.
A Community
Support Fund directed by the Department of Pesticide Regulation
that provides direct prevention and protections from synthetic
pesticide use should also be included in the 2022 Scoping Plan.
Decisions on how the fund is spent should be left to community
members most impacted by synthetic pesticide use. Examples of
protections include enforceable buffer zones, indoor home air
purifiers/filters, tarping of all fumigations to prevent emissions,
personal protective equipment and other actions that minimize
synthetic pesticide exposure for residents of
California.
5. Remove the
implication that the climate smart agriculture practices included
in the model would inherently result in synthetic pesticide
reductions
The draft Scoping
Plan states that “climate smart
practices can improve public health; for example, by reducing
synthetic fertilizer and pesticide use” and “moving to
an agricultural system that improves soil health and water holding
capacity, reduces over-application of nitrogen, [and] reduces the
use of pesticides.”
However,
it’s critical to note that none of the climate smart
agriculture practices modeled in the Scoping Plan guarantee
pesticide reduction except organic farming. In fact, as mentioned,
certain agricultural practices modeled by CARB in the Scoping Plan,
such as no-till farming, are made possible in conventional,
industrial farming by synthetic herbicides. This point is made
clear by the USDA:
“Herbicides such as 2,4-D, atrazine and paraquat enable
farmers to manage weeds with less tillage... And in the absence of
tillage, farmers depend more heavily on herbicides to keep weeds at
bay… Cost aside, greater reliance on agrichemicals may
adversely affect nontarget species or contaminate air, water and
soil." While reducing tillage can have benefits, it must not result
in an increase in reliance on synthetic pesticide use, which would
have negative impacts on the climate, environment and public
health. Ecological pest management, pesticide reduction, and
organic farming must therefore be simultaneously incentivized and
adopted to ensure increase in reliance does not occur.
Therefore,
“climate smart practices'', especially when adopted
individually, do not necessarily result in pesticide use reduction,
and may even increase it. This is why we need strong organic
farming and pesticide reduction targets included in the Scoping
Plan along with direct incentives for farmers to adopt more
ecological pest management practices. Furthermore, while building
healthy soils is foundational to sustainable pest management,
reducing pesticide use directly results in myriad
soil health benefits. We think
it’s critical that this reciprocal relationship also be
acknowledged in the Scoping Plan.
6. Deploy direct
incentives to farmers to reduce pesticide use, similar to financial
mechanisms for healthy soils practices and organic
agriculture
We are excited to
see that the draft Scoping Plan highlights the importance of
financial mechanisms to support organic farming. Similarly, we need
financial support for farmers to experiment with and transition to
ecological pest management practices. We recommend that the draft
Scoping Plan include a commitment to also provide financial
mechanisms to farmers, particularly small producers and BIPOC
producers, to reduce pesticide use. Furthermore, many farmers
receive technical assistance on their pest management practices
from Pest Control Advisors (PCAs), many of whom are employed by
pesticide manufacturers or distributors. There is an overwhelming
need for more PCAs and other technical assistance providers with a
background in ecological pest management and organic farming.
Therefore, financial mechanisms must be provided to support
increased technical assistance to reduce pesticide use, as well as
direct incentives for farmers.
Thank you for
considering our recommendations. We would be happy to discuss them
with CARB staff.
Sincerely,
Asha Sharma,
Organizing Co-Director, Pesticide Action Network
Margaret Reeves,
Senior Scientists, Pesticide Action Network
Angel Garcia,
Co-Director, Californians for Pesticide Reform, EJAC
member
Jane Sellen,
Co-Director, Californians for Pesticide Reform