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