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Comment 341 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameCatherine
Last NameDodd RN PhD
AffiliationFACTS & SASS
SubjectItem 22-16-1 Scoping Plan

December 15, 2022

Catherine Dodd, I’m a retired Maternal Child Health nurse and I represent FACTS, Families Advocating for Chemical and Toxics Safety and Sonoma Safe Agriculture/Safe Schools.  I’d like to associate our remarks with the EJAC comments and recommendations including making EJAC a permanent structure. I’d like acknowledge with respect the transparent process and opportunity for the public to provide input in the development of this plan even though it seems that many scientific recommendations especially about Agriculture and Carbon Capture have been overlooked.

 For the first time CARB has acknowledged the importance to communities of having organic farming/pesticide reductions included in the Scoping Plan. We are pleased that Secretary Yana Garcia has acknowledged the importance of pesticide use in Climate Change and public health protection. –

While we are pleased with the inclusion of pesticide reduction, the goal is hardly an “acceleration of action on ag lands” as cited in the presentation introduction of directions for CARB. A 20% increase in organic agriculture does not “accelerate” the increase, it does not even keep up with the current market projections.  Organic farming not only directly reduces GHGs, but it also sequesters carbon over the long run, it cleans the air found in the most polluted, low income and largely LatinX counties in the state.

The plan suggests decreasing GHG emissions from 2.5 million NWL acres and refers only to methane reduction in Agriculture.  20% organic farming by 2045 will not ensure public health and to establish permanent CO2 sequestration.

Please set a meaningful target of 30% - the plan only projects 22 years to implement the 20% target in the state with the largest acreage of agriculture in the US.

The Plan’s goals for decreasing oil extraction are laudable but do not consider the supply side issue that fossil fuel is required to make pesticides and transport them here in our state. CA oil and gas companies play major roles in developing pesticide ingredients, including Shell, Chevron and ExxonMobil. These companies produce CO2 in their manufacturing processes. Syngenta a large international pesticide manufacturer reports that 9.8 million tons of CO2  resulting from its operations in 2021. This is equivalent to the annual carbon dioxide emissions of more than 2 million passenger vehicles.  The manufacturing of one kilogram of pesticide requires, on average, about 10 times more energy than one kilogram of nitrogen fertilizer.

Decreasing pesticide use has the additional benefit of decreasing supply side demand for fossil fuels. In addition, fumigants such as Telone a poisonous/carcinogenic fumigant currently under regulatory review (been banned in 29 countries) require being covered with plastic tarps (to prevent fumigants from drifting to local communities). These plastic tarps are made from fossil fuels.

Some pesticides, such as sulfuryl fluoride, are themselves powerful greenhouse gases, having nearly 5,000 times the potency of carbon dioxide. The staff report talks about decreasing methane from Agriculture but overlooks that pesticide and fumigant use contribute more than methane – fumigants are GHGs and pesticides are VOCs. Some pesticides, such as sulfuryl fluoride, are themselves powerful greenhouse gases, having nearly 5,000 times the potency of carbon dioxide.

More needs to be done to decrease pesticide use. This week CDFA held a scientific conference which acknowledged both facts and demonstrated that healthy soils sequester carbon.  It’s time that CARB looked at the science other CA departments are presenting.

 Ag should not be included in “technical/mechanical CO2 removal.”

In addition, Carbon Capture and Storage is unproven and dangerous and should not be pursued. CO2 removal through sequestration from organic farming is the cleanest solution, healthy organic farming is safe and long term.

In the plan, page 264 refers of the planto climate smart vegetation management using herbicides to control the fire fuel load. This is counter to decreasing pesticide use, it is not a safe solution and should not be called “climate smart.” In addition, the myth of “cover cropping” increases the use of pesticides because the cover crops use large amounts of pesticides when they are grown. Please invest in proven indigenous methods and grazing is safer for all.

CARB staff consistently called for more research, 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 considering the particularly harmful and well-documented health impacts of pesticides on communities of color in agricultural areas.

Increasing organic farming will improve public health, provide safety for agricultural communities exposed frequently to pesticide drift, it will provide healthier food (many pesticides are absorbed into the plants e.g. glyphosate), it will decease pesticide residue found on fruits and vegetables (by DPR inspectors) and then eaten by Californians and it will sequester carbon! Why is the target so low when the positive results are so significant.

 Lastly, the economic cost of health presented in the staff summary, does not include the time lost from work and even jobs lost by workers when family members must leave work to care for sick children nor does it include the stress and mental health costs of long-term chronic illness caused by air pollution and exposure to dangerous pollution including pesticides – now proven to be linked to asthma, preterm birth, fetal death and brain cancer in children when moms are exposed during pregnancy.  Decreasing pesticide use and increasing organic farming targets will improve public health especially the health of marginalized communities of color.

We thank you for your efforts and hope the board will consider increasing the organic target in this 5 year plan which has 22 year targets.

Catherine Dodd RN PhD


Original File Name
Date and Time Comment Was Submitted 2022-12-15 11:58:05

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

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