27
Feb
Take Action: Sustainable “Roadmap” Falls Short of What Is Needed To Solve Existential Crises
(Beyond Pesticides, February 27, 2023) California’s Department of Pesticide Regulation (DPR) is asking for comments on its “Sustainable Pest Management (SPM) Roadmap” by 5 pm (PST) March 13, 2023. While recognizing problems inherent in traditional integrated pest management (IPM), DPR’s roadmap is directing us to a destination that includes another generation of exposure to the worst of the worst pesticides—while failing to embrace the elimination of farm inputs harmful to ecosystems and the capacity of soil biology to cycle nutrients and draw down the maximum amount of atmospheric carbon. The Roadmap’s off-handed rejection of organic practices, rather than building on organic systems, creates a lost opportunity for adopting a holistic and serious solution to the current crises of health threats from pesticides, biodiversity collapse, and the climate emergency.
DPR’s Roadmap states these goals:
- By 2050, eliminate the use of Priority Pesticides by transitioning to SPM.
- By 2050, SPM will be adopted as the de facto pest management system in California.
DPR says “The criteria for classifying pesticides as “Priority Pesticides” include, but are not limited to, hazard and risk classifications, availability of effective alternative products or practices, and special consideration of pest management situations that potentially cause severe or widespread adverse impacts. . .. Priority Pesticides are a subset of high-risk pesticides. We define ‘high risk’ pesticides as active ingredients that are highly hazardous and/or formulations or uses that pose a likelihood of, or are known to cause, significant or widespread human and/or ecological impacts from their use.” [Grammar and spelling are corrected.]
To set as a goal elimination of these pesticides—by definition the worst of the worst—by 2050 is to accept another generation of their use. This is another generation of using “groundwater contaminants, toxic air contaminants, and restricted products as well as carcinogens, endocrine disruptors, reproductive and developmental toxicants, and environmental toxicants, such as those toxic to pollinators, mammals, birds, and fish.” A roadmap to this destination is clearly inadequate because the destination does not fully address the existential threats we are facing, in significant part created by petrochemical pesticide and fertilizer use.
The second goal is the adoption of SPM as the de facto pest management system in California. Integrated Pest Management (IPM) is a 60-year-old approach to agricultural practice that, when first conceived and implemented, had among its goals a significant reduction of synthetic pesticide use, and the health, environmental, and ecosystemic benefits that would flow from that. However, as a study published in 2021 concluded, IPM has overall been unsuccessful in achieving those goals. DPR recognizes shortcomings of IPM, but its substitute, SPM, does not address the crucial deficiencies of IPM.
DPR describes SPM as “a holistic, whole-system approach applicable in agricultural and other managed ecosystems and urban and rural communities that builds on the concept of integrated pest management (IPM) to include the wider context of the three sustainability pillars: human health and social equity, environmental protection, and economic vitality.” This “evolution of the IPM concept,” however, does not address the key deficiency of IPM—defining the conditions under which pesticide use is “necessary” or warranted.
In addition, SPM shows no signs of being rooted in the health of soil and people. Organic agriculture, on the other hand, is a systems approach to building healthy soils, plants, and animals, in which “pests” become minor factors. The result is healthy people and a healthy ecosystem. Similarly, strong IPM in urban systems focuses on building healthy systems that prevent pest problems. Both organic agriculture and strong, defined IPM seek to eliminate all toxic chemicals, while working with and respecting nature.
The Organic Trade Association reports that organic sales now exceed $63 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food on 4.9 million acres in 2021. California has long been a leader in organic production. DPR must immediately undertake a comprehensive effort to transition California agriculture to organic. Similarly, the explosive growth in organic parks and least-toxic building management shows that a slow, piecemeal transition will unnecessarily expose a whole generation of Californians to highly toxic chemicals.
Letter to DPR:
While recognizing problems inherent in traditional integrated pest management (IPM), DPR’s roadmap is directing us to a destination that includes another generation of exposure to the worst of the worst pesticides. While recognizing problems inherent in traditional integrated pest management (IPM), DPR’s roadmap is directing us to a destination that includes another generation of exposure to the worst of the worst pesticides—while failing to embrace the elimination of farm inputs harmful to ecosystems and the capacity of soil biology to cycle nutrients and draw down the maximum amount of atmospheric carbon. The Roadmap’s off-handed rejection of organic practices creates a lost opportunity for adopting a holistic and serious solution to the current crises of health threats from pesticides, biodiversity collapse, and the climate emergency.
DPR’s Roadmap states these goals:
By 2050, eliminate the use of Priority Pesticides by transitioning to SPM.
By 2050, SPM will be adopted as the de facto pest management system in California.
To set as a goal elimination of these pesticides—by definition the worst of the worst—by 2050 is to accept another generation of their use. This is another generation of using “groundwater contaminants, toxic air contaminants, and restricted products as well as carcinogens, endocrine disruptors, reproductive and developmental toxicants, and environmental toxicants, such as those toxic to pollinators, mammals, birds, and fish.” A roadmap to this destination is clearly inadequate because the destination does not fully address the existential threats we are facing, in significant part created by petrochemical pesticide and fertilizer use.
The second goal is the adoption of SPM as the de facto pest management system in California by 2050. Integrated Pest Management (IPM) is a 60-year-old approach to agricultural practice that, when first conceived and implemented, had among its goals a significant reduction of synthetic pesticide use, and the health, environmental, and ecosystemic benefits that would flow from that. However, IPM has overall been unsuccessful in achieving those goals. DPR recognizes shortcomings of IPM, but its substitute, SPM, does not address the crucial deficiencies of IPM.
DPR’s “evolution of the IPM concept,” does not address the key deficiency of IPM—defining the conditions under which pesticide use is “necessary” or warranted.
In addition, SPM shows no signs of being rooted in the health of soil and people. Organic agriculture, on the other hand, is a systems approach to building healthy soils, plants, and animals, in which “pests” become minor factors. The result is healthy people and a healthy ecosystem. Similarly, strong IPM in urban systems focuses on building healthy systems that prevent pest problems. Both organic agriculture and strong, defined IPM seek to eliminate all toxic chemicals, while working with and respecting nature.
The Organic Trade Association reports that organic sales now exceed $63 billion per year, and the U.S. Department of Agriculture (USDA) finds that organic producers in the U.S. produced $11.2 billion worth of organic food on 4.9 million acres in 2021. California has long been a leader in organic production. DPR must immediately undertake a comprehensive effort to transition California agriculture to organic. Similarly, the explosive growth in organic parks and least toxic building management shows that a slow, piecemeal transition will unnecessarily expose a whole generation of Californians to highly toxic chemicals.
DPR’s roadmap is inadequate. Please revise the destination to immediately eliminate the worst pesticides and implement wide scale transition to organic practices.
Thank you.
