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Comment 331 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First Namelendri
Last NamePurcell
AffiliationJonas Philanthropies
SubjectPesticide use must be a stronger consideration in this plan!
   My name is Lendri Purcell and I am a mother of a child with an environmental illness. I am also the co-president of Jonas philanthropies and the president of Families Advocating for Chemical and Toxics Safety. The deleterious impact that synthetic  pesticides have on the lungs and bodies of children has been well documented. There is well established scientific literature documenting that pesticide exposure during pregnancy may lead to an increased risk of birth defects, low birth weight, and fetal death. Exposure in childhood has been linked to attention and learning problems, as well as cancer. I fear that your good intentions in this process which are very laudable do not take into account the fact that pesticides contribute to greenhouse gas emissions. Pesticides impact climate change throughout their manufacture, transport and application. When pesticides are made, three main greenhouse gases are emitted: carbon dioxide, methane and nitrous oxideNot only do pesticides affect our health and the environment, but they also play a part, both directly and indirectly, in climate change: For example, fossil fuels are used in the production and transportation of pesticides; their use supports highly unsustainable food and farming systems; and they affect the soil’s ability to sequester carbon. Tackling climate change will require a widespread shift away from pesticide-dominated agriculture to agroecology. This will lead to resilient, regenerative farming systems that emit less greenhouse gases, improve biodiversity and produce good yields and fair rewards for farmers. Agroecological farming systems are more resilient and better able to withstand climate shocks like extreme flooding and drought. Thank you CARB for supporting the importance of communities to have organic farming but we need stronger measures adopted. This is a social justice issue as pesticide use has a disproportionate impact on low-income communities of color. There is enough research available now to justify stronger support for pesticide use reduction, agroecology and diversified organic agriculture as greenhouse gas reduction and climate change mitigation strategies, especially in light of the particularly harmful and well-documented health impacts of pesticides on communities of color in ag areas. 
What we need to do: 
1. Exclude pesticide use from the Scoping Plan as a climate-smart strategy 
- current language in the draft Scoping Plan is better than it was; it now encourages other forms (rather than herbicides) of dealing with invasive weeds but it still talks about herbicide use —> page 264: "Prescribed herbivory utilizes various livestock to consume vegetation to reduce fuel loads across an area. This fuel management practice can be used in forests, grasslands, and shrublands as an effective alternative to herbicide use, and should be considered wherever local conditions allow.Itd be great to have this be stronger language that says that rather than herbicides, other control methods should be used for controlling fuel loads and/or reducing invasive weeds, period.
2. Strengthen organic farming target -> increase to 30% of all acreage organically-farmed by 2030 (right now the target is 20% by 2045, while it’s great    to have organic farming in the Scoring Plan at all, the 20% target by 2045 doesn’t even keep up with current market trends)
- calling for a strong/stronger organic farming target is particularly important right now; even though we’re not likely to get an improvement in the target at this point big ag is currently pressuring Board members to remove organic farming from the Scoping Plan altogether
3. Remove implications in the Scoping Plan that the climate-smart agricultural practices (such as cover crops) included in the modeling would inherently result in synthetic pesticide reductions, and instead include pesticide reductions as an actual goal instead of as an incidental byproduct of other practices
4. Ensure that the further research on pesticides and climate change includes additional research into the disparate impacts of pesticide use 
5. Support deployment of direct incentives to farmers to reduce pesticide use, similar to financial mechanisms for healthy soils practices and organic agriculture 
- CARB could do this by asking the California Department of Food and Agriculture (CDFA) to consider incorporating the Natural Resources Conservation Service’s (NRCS’) Integrated Pest Management Practice 595, along with actual pesticide reduction goals, into CDFA’s Healthy Soils Program (CDFA's Healthy Soils program is almost entirely based on NRCS conservation standards, but CDFA hasn’t included the NRCS integrated pest management conservation standard (595) into the Healthy Soils Program yet)   
Why we need to do it: 
  • 99% of all synthetic chemicals—including pesticides—are derived from fossil fuels, and several oil and gas companies play major roles in developing pesticide ingredients, including Shell, Chevron and ExxonMobil.
  • Multiple pesticide corporations self-report high CO2 equivalent emissions (CO2e) related to their operations. For instance, Syngenta reports that 9.8 million tonnes of CO2e resulted from its operations in 2021. This is equivalent to the annual carbon dioxide emissions of more than 2 million passenger vehicles.
  • Other chemical inputs in agriculture, such as nitrogen fertilizer, have rightly received significant attention due to their contributions to greenhouse gas emissions. Yet research has shown that the manufacture of one kilogram of pesticide requires, on average, about 10 times more energy than one kilogram of nitrogen fertilizer.
  • Like nitrogen fertilizers, pesticides can also release greenhouse gas emissions after their application, with fumigant pesticides shown to increase nitrous oxide production in soils seven to eight-fold. This effect has been predicted to be caused by impacts to soil microbes post-fumigation.
  • Many pesticides also lead to the production of ground-level ozone, a greenhouse gas harmful to both humans and plants.
  • Some pesticides, such as sulfuryl fluoride, are themselves powerful greenhouse gases, having nearly 5,000 times the potency of carbon dioxide.
  • Pesticides have been shown to be harmful to soil microbes as well as soil invertebrates - both critical to building soil health
  • Long-term research studies have shown organic agriculture, which does not rely on synthetic pesticides, to build soil organic carbon significantly compared to conventional agriculture.

Original File Name
Date and Time Comment Was Submitted 2022-12-15 11:23:00

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