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Comment 665 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameJan
Last NameDietrick
AffiliationDietrick Inst for Applied Insect Ecology
SubjectAim for 30% organic acreage; 50% pesticide reduction by 2030

Dear Chair Randolph:

We signed the joint letter by Pesticide Action Network-North America and Californians for Pesticide Reform with the Sierra Club and numerous climate, environmental, EJ and public health organizations calling for more ambition to maximize the benefits from diversified organic agriculture and reduced pesticide use.

Below is our summary those six recommendations. The attached letter contains further explanation and recommendations. We encourage CARB to do the following: 

  1. Accelerate the organic agriculture target of 30% of acreage being organically-farmed by 2030, not 2045. Trends favor meeting that goal by 2030 without added incentives. We can and must achieve at least 80% acreage farmed organically by 2045.  
  2. Include a numeric 50% reduction in synthetic agricultural pesticide use by 2030. Knowledge and experience exists to do this and we must address equity for farmworkers and economic resilience for farmers.  
  3. Stop referring to the use of herbicides as “climate smart” strategies for natural lands. A systemic approach to prevention of invasive weeds is safer as well as more durable.  
  4. Further research on pesticides and provide for direct, community-led protections from synthetic pesticide use. 
  5. Stop allowing GHG payments to farmers that use synthetic pesticides. We add a prohibition on the use of excessive artificial nitrogen fertilizers in excess of plant needs. Smart practitioners are building Soil Organic Matter at a scale that is not even in the ballpark of the models. That is the power of a systems approach.
  6. Pay organic and transitioning farmers who are adopting organic pest management in addition to giving Healthy Soils Program payments. Skilled, experienced consultants are needed. Workforce development can only happen when growers can pay for expert ecological pest management and organic farming advice that requires more knowledge, training and years of experience and the assumption of more risks than for those advising chemical farmers. In three to four years both the farmer and the practitioner have the learning and experience to often manage more profitably than before the transition. 

Targeting 2045 to achieve 30% increase in organic acreage lacks ambition

Economic incentives are gathering momentum, in part because transition to organic and regenerative systems increase resilience and can be managed to improve profitability, particularly in future years as the knowledge to verify EcoCredits in the Regen Ledger expands. With reasonable and justifiable investments it should be easy to achieve 30% organic acreage before 2030 through incentives that farmers welcome.  Everyone now understands that building Soil Organic Matter mitigates risk of flood and drought. It is essential to extend as far as possible the potential for biological carbon sequestration on working lands and incentives for transition to organic.

Technical/Geological Carbon Capture and Storage cannot draw down enough carbon in time

The recent Joint Information Hearing on Carbon Capture and Storage chaired by Assemblymember Muratsuchi showed that CCS has no potential in the timely rescue of earth’s living systems.


There are ecosystem restoration leaders with trustworthy data and experience to help design policies that will reduce ecosystem disruption in farming regions going forward. The foundation for higher goals and targets for carbon sequestration on working lands is the use of the existing correlative metrics: 

  1. Increase percent acreage farmed organically,

  2. Reduce or eliminate use of synthetic, broad-spectrum pesticides, and 

  3. Reduce or eliminate artificial fertilizers in excess of plant needs.

Additional information and recommendations to help CARB release the potential of natural systems on farmland is in the longer attached comment letter.

Sincerely yours,

Jan Dietrick, MPH, Executive Director

Dietrick Institute for Applied Insect Ecology, Ventura, CA 93001


Ron Whitehurst, Owner and Licensed Pest Control Advisor

Rincon-Vitova Insectaries, Inc., Ventura, CA 93001



Original File NameDietrick Inst. & RVI recommend Scoping Plan aim for 30% organic acreage; 50% toxic pesticide reduction by 2030.pdf
Date and Time Comment Was Submitted 2022-06-24 22:36:29

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