23
Jan
EPA, USDA and Interior Challenged to Incorporate in All Decisions Impact on Climate Crisis, from Soil to Pesticides
(Beyond Pesticides, January 23, 2023) There is no doubt that the climate crisis is upon us. And the consequences are undeniably grave. So, we must incorporate our understanding of the grave health and environmental effects into the deliberations on all policy decisions regarding petrochemical pesticide registrations and synthetic fertilizer use in agriculture and nonagricultural land management. Of critical importance, in this context, is the effect of policy decisions on soil health—in particular, soil organic carbon, which sequesters atmospheric carbon and reduces its damaging atmospheric effects.
Although the soil is commonly recognized as a sink for atmospheric carbon, there is a false narrative that says carbon can be sequestered in the soil through chemical-intensive no-till agriculture. Now the Rodale Institute’s 40-Year Report on their “Farming Systems Trial” should end the myth of the toxic, petrochemical-based, GMO-herbicide, no-till systems. Rodale’s scientific trials clearly show that these degenerative no-till systems are inferior to Regenerative Organic Agriculture on every key criterion.
The highest yields of corn in the tilled organic manure system and the best increases in soil organic carbon were produced with an organic manure system and limited tillage (tilled every other year). Of importance to climate resilience, organic corn yields have been 31 percent higher than conventional/industrial farming systems in drought years.
The trials show that herbicide no-till systems do not produce higher levels of soil organic carbon (SOC) than tillage systems. This result is consistent with reviews of 194 studies comparing no-till and tilled fields.
According to Andre Leu, international director at Regeneration International, “The main reason for the loss of soil carbon in farming systems is not tillage; it is synthetic nitrogen fertilizers. Research shows that there is a direct link between the application of synthetic nitrogenous fertilizers and a decline in soil carbon.” In addition, those same nitrogenous fertilizers act as potent greenhouse gases when volatilized to the atmosphere.
Thus, chemical-intensive agriculture and nonagricultural land management contribute to climate change in multiple ways. If we are to be serious about combating climate change and mitigating its impacts, all agencies must consider climate impacts when making decisions. This means that the U.S. Environmental Protection Agency (EPA) must not approve registrations of pesticides that harm the soil or facilitate agricultural practices that interfere with carbon sequestration. It means that the U.S. Department of Agriculture (USDA), in a much more aggressive way, must lead the transition to organic agriculture as a replacement for chemical-intensive practices and should cease all support for chemical-intensive agriculture immediately. It means that the Department of Interior (DOI) must manage all public lands with organic practices that ensure soil health and all that means for a livable future.
Letter to EPA:
The broad perspective embodied in President Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office, creates a mandate across all federal agencies for future-oriented public health and safety protections. As well as environmental stewardship, more protections are urgently needed to abate the climate crisis. A separate executive order, Tackling the Climate Crisis at Home and Abroad, states, ”The United States will also move quickly to build resilience, both at home and abroad, against the impacts of climate change that are already manifest and will continue to intensify according to current trajectories.”
A comprehensive resiliency policy requires EPA to cease allowing the continued degradation of soil and ecosystems that are so critical to abating the climate crisis when alternatives are available and could be promoted. Missing from EPA’s registration program are the steps necessary to reduce and eliminate the contribution of petrochemical pesticides and fertilizers to the climate, recognizing the viability of the $63 billion organic industry that is growing, despite EPA’s continuing commitment to the status-quo allowance of chemicals unnecessary to achieve agricultural productivity and land management goals. EPA’s failure in this regard constitutes a public health threat, a reneging of the agency’s responsibility to environmental stewardship, and a missed opportunity and mandate to ensure a livable future.
A key missing element of EPA’s review is the impact of pesticide registration decisions on soil health—in particular, soil organic carbon, which sequesters atmospheric carbon away from damaging atmospheric effects. Although the soil is commonly recognized as a sink for atmospheric carbon, there is a false narrative that says carbon can be sequestered in the soil through chemical-intensive no-till agriculture, which depends heavily on EPA-registered herbicides. Now the Rodale Institute’s 40-Year Report on their “Farming Systems Trial” should end the myth of the toxic, petrochemical, GMO-herbicide, no-till systems. Rodale’s scientific trials clearly show that these degenerative no-till systems are inferior to Regenerative Organic Agriculture on every key criterion.
The highest yields of corn in the tilled organic manure system and the best increases in soil organic carbon were produced with an organic manure system and limited tillage (tilled every other year). Of importance to climate resilience, organic corn yields have been 31 percent higher than conventional/industrial farming systems in drought years.
The trials show that herbicide no-till systems do not produce higher levels of soil organic carbon than tillage systems. This result is consistent with reviews of 194 studies comparing no-till and tilled fields.
According to Andre Leu, international director at Regeneration International, “The main reason for the loss of soil carbon in farming systems is not tillage; it is synthetic nitrogen fertilizers. Research shows that there is a direct link between the application of synthetic nitrogenous fertilizers and a decline in soil carbon.” In addition, those same nitrogenous fertilizers act as potent greenhouse gases when volatilized to the atmosphere.
Chemical-intensive agriculture contributes to climate change in multiple ways. If we are to be serious about combating climate change and mitigating its impacts, all agencies must consider climate impacts when making decisions. This means that EPA must not approve registrations of pesticides that harm the soil or facilitate agricultural practices that interfere with carbon sequestration. In fact, under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), continued registration of pesticides contributing to the climate crisis or not effectively abating the crisis, when possible, causes “unreasonable” adverse effects.
Please adopt this changed direction. Thank you.
Letter to USDA:
The broad perspective embodied in President Biden’s Executive Memorandum (EM) Modernizing Regulatory Review issued on his first day in office creates a mandate across all federal agencies for future-oriented public health and safety protections, as well as environmental stewardship. More must urgently be done to incorporate protections that abate the climate crisis. A separate executive order, Tackling the Climate Crisis at Home and Abroad, states,” The United States will also move quickly to build resilience, both at home and abroad, against the impacts of climate change that are already manifest and will continue to intensify according to current trajectories.”
There Is no doubt that climate change is upon us. And the consequences are undeniably grave. We should seriously consider all policy decisions in light of those grave consequences. Among those are decisions that affect soil health—in particular, soil organic carbon, which sequesters atmospheric carbon away from damaging atmospheric effects.
A comprehensive resiliency policy requires USDA in all its programs to reverse the continued degradation of soil and ecosystems that is so critical to abating the climate crisis. Missing from USDA’s analysis, work, and programs generally are the steps necessary to replace dependence on petrochemical pesticides and fertilizers contributing to the climate emergency with a new direction recognizing the viability of the $63 billion organic enterprise. While strides are being made in the National Organic Program, the growth of organic is not keeping pace with the need to confront the climate crisis, given that status-quo use of chemicals is no longer needed to achieve agricultural productivity and land management goals. USDA’s failure in this regard constitutes a public health threat, a reneging of the agency’s responsibility to environmental stewardship, and a missed opportunity and mandate to ensure a livable future.
Although the soil is commonly recognized as a sink for atmospheric carbon, there is a false narrative that says carbon can be sequestered in the soil through chemical-intensive no-till agriculture. Now the Rodale Institute’s 40-Year Report on their “Farming Systems Trial” should end the myth of the toxic, petrochemical, GMO-herbicide, no-till systems. Rodale’s scientific trials clearly show that these degenerative no-till systems are inferior to Regenerative Organic Agriculture on every key criterion.
The highest yields of corn in the tilled organic manure system and the best increases in soil organic carbon were produced with an organic manure system and limited tillage (tilled every other year). Of importance to climate resilience, organic corn yields have been 31 percent higher than conventional/industrial farming systems in drought years.
The trials show that herbicide no-till systems do not produce higher levels of soil organic carbon (SOC) than tillage systems. This result is consistent with reviews of 194 studies comparing no-till and tilled fields.
According to Andre Leu, international director at Regeneration International, “The main reason for the loss of soil carbon in farming systems is not tillage; it is synthetic nitrogen fertilizers. Research shows that there is a direct link between the application of synthetic nitrogenous fertilizers and a decline in soil carbon.” In addition, those same nitrogenous fertilizers act as potent greenhouse gases when volatilized to the atmosphere.
Chemical-intensive agriculture contributes to climate change in multiple ways. If we are to be serious about combating climate change and mitigating its impacts, all agencies must consider climate impacts when making decisions. This means that USDA must lead in a much more aggressive way the transition to organic agriculture as a replacement for chemical-intensive practices and should cease all support for chemical-intensive agriculture immediately.
Please adopt this changed direction. Thank you.
Letter to U.S. Representative and Senators:
President Biden’s Executive Memorandum Modernizing Regulatory Review issued on his first day in office creates a mandate across all federal agencies for future-oriented public health and safety protections. More is urgently needed to incorporate protections to abate the climate crisis. A separate executive order, Tackling the Climate Crisis at Home and Abroad, states, ”The United States will also move quickly to build resilience, both at home and abroad, against the impacts of climate change that are already manifest and will continue to intensify according to current trajectories.”
There is no doubt that climate change is upon us. The consequences are undeniably grave. We must seriously consider all policy decisions in light of those grave consequences. Among those are decisions that affect soil health—in particular, soil organic carbon, which sequesters atmospheric carbon away from damaging atmospheric effects.
A comprehensive resiliency policy requires USDA, EPA, and DOI in all of their programs to eliminate the continued degradation of soil and ecosystems and adopt known alternatives. Missing from the agencies’ analysis, work, and programs generally is a recognition of the viability of $63 billion organic industry. Despite strides made with the National Organic Program, the growth of organic is not keeping pace with the need to confront the climate crisis. Key to the required analysis is the impact of pesticide use on soil health. The agencies’ failure in this regard constitutes a public health threat, a reneging of their responsibility to environmental stewardship, and a missed opportunity to ensure a livable future.
Although the soil is commonly recognized as a sink for atmospheric carbon, a false narrative says carbon can be sequestered in the soil through chemical-intensive no-till agriculture. Now the Rodale Institute’s 40-Year Report on their “Farming Systems Trial” should end the myth of the toxic, GMO-herbicide, no-till systems. Scientific trials clearly show that these degenerative no-till systems are inferior to Regenerative Organic Agriculture in every respect.
The highest yields of corn in the tilled organic manure system and the best increases in soil organic carbon were produced with an organic manure system and limited tillage (tilled every other year). Of importance to climate resilience, organic corn yields have been 31 percent higher than conventional/industrial farming systems in drought years.
The trials show that herbicide no-till systems do not produce higher levels of soil organic carbon (SOC) than tillage systems. This result is consistent with reviews of 194 studies comparing no-till and tilled fields.
According to Andre Leu, international director at Regeneration International, “The main reason for the loss of soil carbon in farming systems is not tillage; it is synthetic nitrogen fertilizers. Research shows that there is a direct link between the application of synthetic nitrogenous fertilizers and a decline in soil carbon.” In addition, those same nitrogenous fertilizers act as potent greenhouse gases when volatilized to the atmosphere.
Thus, chemical-intensive agriculture and land management contribute to climate change in multiple ways. If we are to be serious about combating climate change and mitigating its impacts, all agencies must consider climate impacts when making decisions. This means EPA must not approve registrations of pesticides that harm the soil or facilitate agricultural practices that interfere with carbon sequestration. It means USDA must forcefully lead the transition to organic agriculture as a replacement for chemical-intensive practices and cease all support for chemical-intensive agriculture immediately. It means DOI must manage all public lands with organic practices that ensure soil health and a livable future.
Please ensure that our federal agencies adopt this changed direction. Thank you.