Comment Log Display

On behalf of the 190+ member organizations of the statewide
coalition Californians for Pesticide Reform, I wish to express the
coalition's concern over the notable absence of any proposed
action
on the toxic fluorinated gas sulfuryl fluoride.

Specifically, we are troubled by the dismissive relegation of this
known GHG to a single paragraph on p.57 of the draft document. By
CARB's own admission, it has been well known for six years that
SO2F2 is a high GWP gas, and yet it has yet to be added to ARB's
GHG inventory.

SO2F2 is now in increasing use as a replacement for the
ozone-depleting pesticide methyl bromide, which is being phased
out
under the Montreal Protocol. California uses an astonishing 50% of
global consumption of this health-harming fumigant. As the draft
strategy document acknowledges, if it were correctly categorized
as
a GHG, it would singlehandedly increase California's total F-gas
inventory by 25%. 

It is simply not good enough to sweep this acknowledged GHG under
the rug.

CPR calls on ARB to revise their draft strategy to include a plan
to phase
out the use of this harmful pesticide, and to make a commitment to
a serious study of alternatives.

Sincerely,

Sarah Aird
Acting Executive Director, Californians for Pesticide Reform