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: 

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.  
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.  
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.  
Further research on pesticides and provide for direct,
community-led protections from synthetic pesticide
use. 
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.
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. 
Conclusion
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: 



Increase percent
acreage farmed organically,


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


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
and
Ron Whitehurst, Owner and Licensed Pest Control
Advisor
Rincon-Vitova Insectaries, Inc., Ventura, CA
93001