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Comment 355 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameSarah
Last NameAird
AffiliationCalifornians for Pesticide Reform
SubjectStronger targets for diversified organic farming & for pesticide reduction still needed

I’m State Policy Director for Californians for Pesticide Reform, a statewide coalition made up of more than 200 organizations around the state. We work directly with farmworkers and farmworker communities in seven of the largest agricultural regions of California who are the most impacted by agricultural pesticides.


First, I want to thank CARB Board members for their support for adding natural and working lands for the first time into any Scoping Plan, and for ensuring that organic farming and sustainable pest management are recognized as important working lands climate solutions in the plan. We consider these new inclusions to be precedent-setting and to be important models for other regions trying to identify and support climate solutions.


Having said that, we believe the Scoping Plan inappropriately includes industrial CCS, which is energy-intensive and unproven. In the meantime, the working lands sector has proven capacity for much greater carbon sequestration and equitable climate solutions than is recognized in the current Scoping Plan. Pesticides are petrochemicals, derived from oil and gas. They require inordinate amounts of energy to produce. And depending on the farming system, working lands can either help the soil sequester carbon and reduce other greenhouse gas emissions, or working lands can result in very little carbon sequestration and increased greenhouse gas emissions. These distinctions need to be better understood, but there’s already robust evidence, which we’ve submitted to the Board in previous comment letters (listed below), documenting that diversified organic farming, which does not rely on synthetic pesticides or fertilizers, sequesters far more carbon and results in significantly reduced greenhouse gas emissions when compared with industrial farming reliant on these chemicals.


As part of the AB 1757 implementation process being led by the California Natural Resources Agency, we strongly urge CARB members to press for even stronger targets for diversified organic farming as well as for inclusion of reduction targets for fumigant pesticides, which research already shows contribute significantly to greenhouse gas emissions and limit the ability of the soil to sequester carbon. We were pleased that CDFA held a presentation on this very issue earlier this week, confirming that certain, primarily fumigant pesticides - 20-30 million pounds of which are used on California fields each and every year - can contribute up to 100-fold increases in nitrous oxide emissions and reduced carbon sequestration.  At the same time these stronger targets need to be adopted, it’s critical that the state ensure farmers are provided financial and technical support to reduce their pesticide use, similar to financial mechanisms that already exist for healthy soils practices, but which currently exclude support for pesticide reduction.



Equally importantly, reduction of agricultural pesticides brings amongst the greatest benefits to EJ communities who disproportionately suffer the health impacts of pesticide use. If the state is truly interested in centering equity and in reducing the impact of toxins on communities of color, while also combatting climate change, addressing pesticide use is one of the most effective steps the state can take. Researchers from the California Environmental Protection Agency itself that found that pesticides were one of the top two pollutants in the state whose distribution was most correlated with race and ethnicity, with “60% of zip codes with the highest proportion of residents of color host[ing more than] 95% of agricultural pesticide use in the state.”[1].


Many of the pesticides that are the most harmful to human health are already banned by other nations and yet California allows their continued use. Please ensure their reduction in future working lands targets.


Pesticides Must Be Included in Scoping Plan and Climate Lands Strategy Letter to the Governor January 5, 2021 

Pesticides Must Be Included in the 2022 Scoping Plan Sign on letter to CARB July 9, 2021 

Pesticides Must Be Included in the 2022 Scoping Plan Update Detailed letter to CARB from CPR and PAN July 9, 2021 

Pesticides’ Contribution to Greenhouse Gas Emissions Must be Measured Comment letter to CARB July 16, 2021

Pesticides must be included in the 2022 Scoping Plan update Comment letter to CARB August 3, 2021

2022 Scoping Plan: Draft Natural and Working Lands Technical Workshop Sign on letter to CARB January 5, 2022

Scoping Plan: Initial Air Quality & Health Impacts Economic Analyses Results Workshop Comment letter to CARB May 3, 2022 

The 2022 Scoping Plan must include more ambitious targets for organic agriculture and pesticide reduction targets Comment letter to CARB June 21, 2022

The 2022 Scoping Plan must include more ambitious targets for organic agriculture and pesticide reduction targets Sign on letter to CARB June 24, 2022



[1] Cushing, L., Faust, J., August, L. M., Cendak, R., Wieland, W., & Alexeeff, G. (2015). Racial/ethnic disparities in cumulative environmental health impacts in California: evidence from a statewide environmental justice screening tool (CalEnviroScreen 1.1). American journal of public health, 105(11), 2341-2348.


Original File Name
Date and Time Comment Was Submitted 2022-12-15 15:42:40

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