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Comment 330 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameLena
Last NameBrook
AffiliationNatural Resources Defense Council (NRDC)
SubjectBe more ambitious about organic agriculture in scoping plan!

Dear Chair Randolph and CARB Members:


Thank you for including goals for increasing organic agriculture in California and reducing synthetic pesticide use in the natural and working lands section of the 2022 Climate Scoping Plan. Given California’s outsize influence as a farm state, this is an important expansion in the state’s approach to climate strategy and a clear recognition that agriculture has a role to play in addressing our climate crisis. I now urge you to be far more ambitious around these climate solutions by (1) increasing the organic agriculture expansion goal to 30% by 2035; and (2) setting ambitious concrete reduction targets for pesticides, especially fumigants and other toxic air contaminants.


Transforming California’s agriculture sector away from extractive practices and toward climate-friendly strategies is essential as farmers struggle with drought, health and wildfire and once-reliable food supply chains become much less so. It is also imperative that as the state implements the climate mitigation and resilience strategies offered in the Scoping Plan, it also invests in healthier farming practices that protect farmworkers and their communities. Meeting both of these challenges means the wholesale adoption of farming practices that reduce reliance on fossil fuel-intensive inputs like synthetic fertilizers and pesticides; meaningfully and equitably addressing emissions from animal agriculture; and prioritizing soil health.


This Scoping Plan takes an important step forward in centering organic agriculture as a climate-smart strategy. Organic farmers and ranchers build healthy soil, do not rely on synthetic inputs, and protect biodiversity, all of which are essential to increasing resilience in the face of climate change. I urge you to heed the call of experts and advocates, including NRDC, who have called for more ambitious commitment and a faster timeline in order for California’s scoping plan to meet the urgency of the moment.


This final draft recommends converting 20% of California’s agricultural lands to organic agriculture by 2045. We are grateful for the inclusion of organic agriculture and consider this an important milestone. Unfortunately, in order to realize the significant climate benefits associated with organic farming practices, the state needs to reach this milestone much sooner than 2045. We can and should be far more ambitious given that California’s organic acreage grew by 44% on its own from 2014 to 2019 according to a report from the state’s Department of Agriculture. A goal of converting 30% of agricultural land to certified organic by 2035 is more aligned with the urgency of the moment.


There are similar missed opportunities regarding reducing pesticide use. While we are pleased to see an acknowledgement of the role that pesticides play in exacerbating climate change (while also harming public and ecosystem health), and a nod to sustainable pest management sprinkled throughout the Scoping Plan, it is essential for California to set firm reduction goals for these toxic chemicals in order to significantly reduce their climate harm.


I appreciate your consideration and leadership.



Lena Brook

Acting Director, Food and Agriculture Program

Natural Resources Defense Council

San Francisco, CA

Original File Name
Date and Time Comment Was Submitted 2022-12-15 10:55:47

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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