03
Feb
With Environmental Collapse on the Horizon, California’s Sustainable Pest Management “Roadmap” Misses Mark
(Beyond Pesticides, February 3, 2023) On January 26, California’s Environmental Protection Agency (CalEPA), Department of Pesticide Regulation (CDPR), and Department of Food and Agriculture (CDFA) announced a new “roadmap” for sustainable pest management (SPM). The plan is promoted by the agencies as an accelerator of the state’s commitment to transitioning away from “high-risk pesticides” and toward “adoption of safer, sustainable pest control practices,” and to eliminating “priority [high-risk] pesticides” by 2050. Although Sustainable Pest Management: A Roadmap for California obviously recognizes the state (and federal) failure of current pesticide policies and land management practices to restrict pesticides sufficiently, advocates say that even this plan does not “meet the moment.” Its relative ambition (compared to what most states are doing), still does not, according to those advancing transformative change, adequately address the current existential health, biodiversity, and climate crises. With these crises being especially urgent, advocates identify meaningful change as the adoption of approaches predicated on ensuring healthy soil biology. This calls for the deployment of a plan for the wholesale transition to organic systems that eliminate all materials/inputs that are harmful to soil health, ecosystems, natural resources, and the health of humans and all living organisms.
The California roadmap was developed by a team of 33 people — 25 members of the Sustainable Pest Management Work Group and eight comprising the Urban Subgroup. The designation of the Urban Subgroup was a wise move, according to Beyond Pesticides, because although public perception is that “pesticides” are related to agriculture — and certainly agriculture is the central focus of much discussion about pesticides — the reality is that pesticide use in urban areas is real and not insignificant. In fact, studies have documented that the poundage of pesticide use per acre is often higher in nonagricultural areas, such as golf courses and lawns. These urban uses happen in residences, businesses, and institutions, and have been evidenced through studies that focus on wastewater, surface waters, and stormwater.
The plan defines SPM as an “evolution” of the IPM (Integrated Pest Management) concept — defined by the University of California Statewide Integrated Pest Management Program (UCIPM) as an ecosystem-based strategy that focuses on long-term prevention of pests or their damage, using strategies such as habitat manipulation, biological controls, resistant plant varieties, and modified horticultural practices. But UCIPM goes on to add, “Pesticides are used only after monitoring indicates they are needed according to established guidelines, and treatments are made with the goal of removing only the target organism. Pest control materials are selected and applied in a manner that minimizes risks to human health, beneficial and nontarget organisms, and the environment.”
Beyond Pesticides has been critical of IPM as it has generally been executed in agriculture because IPM has largely failed to achieve the goals of its original conceit — significant reduction of synthetic pesticide use. Researchers on IPM have noted that over the decades since the inception of the IPM concept some 60 years ago, deployment of strategies has focused far more on reducing negative environmental impacts than on using ecological processes to replace chemical pesticides — an approach that would advance sustainability. Other factors mitigating against the original ideal have included: poor education of practitioners on the concept, multiple and competing definitions of IPM, lack of understanding of ecological concepts that were to underlie IPM, inadequate research and funding, and agrochemical industry lobbying against IPM programs.
The roadmap document describes SPM as a “a process of continual improvement that integrates an array of practices and products aimed at creating healthy, resilient ecosystems, farms, communities, cities, landscapes, homes, and gardens. SPM examines the interconnectedness of pest pressures, ecosystem health, and human wellbeing.” It identifies its goals as (1) eliminating the use of Priority Pesticides by transitioning to sustainable pest management practices, and (2) adopting SPM as the de facto pest management system in California, all by 2050. Beyond Pesticides considers 2050 far, far too late in the game for meaningful changes in the faces of the above-referenced crises.
Those Priority Pesticides are defined as “pesticide products, active ingredients, and groups of related products within the context of specific product uses or pest/location use combinations that have been deemed to be of greatest concern and warrant heightened attention, planning, and support to expedite their replacement and eventual elimination. The criteria for classifying pesticides as ‘Priority Pesticides’ includes . . . 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.”
The keystone actions the plan sets out are these:
- prioritize prevention of pest problems: prevent the establishment of new invasive pest species, and proactively eliminate pest-conducive conditions both in agricultural and urban settings
- coordinate state-level leadership: create an accountable and connected leadership structure to champion SPM in the field, effectively embed SPM principles across agencies, and improve coordination
- invest in building SPM knowledge through research and outreach, for both agricultural and urban sectors: invest in SPM-focused research and outreach so that all pest management practitioners have equal and adequate access to the support and resources necessary to develop and implement their own SPM system
- enhance health and environmental monitoring and data collection: expand and fully fund health and environmental monitoring infrastructure, data collection, and interpretation
- improve the state’s pesticide registration and continuous evaluation processes, and bring alternative products to market: create mechanisms to improve DPR’s registration review process and to prioritize and expedite safer, more sustainable alternative products to high-risk pesticides, and improve processes for evaluating currently registered pesticides
Those actions all sound great . . . until that last one, according to Beyond Pesticides. Improving a pesticide registration process is, in the view of Beyond Pesticides, somewhat akin to the storied rearrangement of the deck chairs on the Titanic as it sinks. As Executive Director Jay Feldman commented, “We are no longer in a period of environmental and health challenges, associated with chemical-intensive agriculture and land management, that permits us simply to ‘minimize reliance on the use of toxic pesticides.’ We must eliminate all petrochemical pesticides and fertilizers in the context of agricultural systems.”
He continued, “An example of good intentions gone awry is that the SPM document contains the word ‘fertilizer’ exactly once, and then only in reference to consolidation in the chemical input (synthetic pesticide and fertilizer) sector. And ‘soil fertility’ is mentioned just once — in a sidebar on expanding non-pesticidal methods. An SPM program that is a genuinely holistic response to multiple crises — health, climate, and biodiversity — must proscribe the currently ubiquitous use of synthetic fertilizers, as well as pesticides, in dominant, chemically intensive land management systems.” Use of petrochemical pesticides and fertilizers represents the antithesis of sound efforts to build biologically healthy soil — the basis of any truly sustainable agricultural pest management system.
To its credit, the SPM plan includes important aspects of a truly sustainable approach. It asserts (p. 16), “In agricultural settings, SPM is rooted in an agroecological approach that considers the whole farm as well as the wider landscape in which it sits. . . . The practices and products together aim to build healthy, pest-resilient agroecosystems that reduce the need for external inputs. Agricultural SPM takes a systems approach to pest prevention and management, while considering environmental health, social equity, and economic viability each step of the way. Therefore, SPM facilitates, where possible, an enhancement of the following co-benefits:
- improving soil health, water quality, use efficiency, and supply; air quality; and biodiversity
- advancing climate mitigation and adaptation
- increasing nutrient density in crops while maintaining yields
- improving land management practices
- improving farmer and farmworker working conditions
- increasing community health and well-being”
The roadmap also includes proposed robust efforts to bring alternative (presumably, non–synthetic chemical) pest control products to market. But the plan continues to rest on an underlying assumption that “pesticides are here to stay,” at least in the short and medium term. The SPM document includes a section on “SPM and Pesticides” (see p. 79) that asserts, “There will no doubt be times when all other pest management options have been exhausted, and still a significant pest pressure remains. . . . In these cases, pesticides may still be employed, so long as the intention is to apply these products in a targeted way, as needed in order to eradicate the pest(s) and continue with a holistic, integrated pest management approach that aims to build overall system health. Pesticides and pesticide-related uses include but are not limited to a. fumigants, b. repellents, c. use of seeds that have been treated with pesticides, d. antibiotics, e. herbicides, f. fungicides, g. insecticides.” That is a very large “escape hatch” to a pesticide path of least resistance for producers.
Additionally, the proposed SPM action, Improve California’s Pesticide Registration and Continuous Evaluation (p. 19), begins with a focus on a transition to lower-risk chemicals — which presumably include perhaps less-risky, but nonetheless, synthetic compounds for which there is insufficient evaluation by the state or the U.S. Environmental Protection Agency (EPA). The roadmap asserts, “DPR must . . . improve its processes for evaluating currently registered pesticides.”
But if the historical record offers any instruction, this would be, at best, a long-term process, and would be fought against aggressively by the agrochemical industry. A plan that would respond to the urgency of the moment would forward the principles of organic, regenerative, agroecological approaches, rather than the SPM approach of tweaking a broken pesticide regulatory system in which chemicals are not adequately evaluated for efficacy or essentiality. A public comment period on the roadmap document is open until March 13; comments can be sent to [email protected].
It should be noted that reform of California’s pesticide registration system (as well as the national EPA registration system) would appropriately require an analysis of nontoxic alternatives. Yet, to address the current crises, reform must also — given the limitations of the current state of pesticide risk assessment, which fails to integrate the range of vulnerabilities in the human population, data gaps, untested health outcomes, exposures to pesticide mixtures and potential synergistic effects, and a range of other complexities that go unaddressed through testing protocols — require adoption of the Precautionary Principle, with its built-in protective ethos.
Beyond Pesticides asserts that there is an urgent imperative to re-create agricultural policy and practices on the scaffolding of organic systems, as defined in the 1990 U.S. Organic Foods Production Act (OFPA). Organic is a framework with a ban on synthetic fertilizers and a National List of Allowed and Prohibited Substances that is required to be established and updated on a five-year cycle with a cradle-to-grave analysis of allowed substances. This system should be continually improved, and expanded to become the dominant approach to agricultural and other land management in the U.S.
Beyond Pesticides Executive Director Jay Feldman concludes, “Decades ago, I would have said that the SPM plan was a good start. But with today’s realities, I would have to call this a false start that does not embrace the true changes that are required for our times and the crises we face. Now is the time to transform our approach to agricultural and nonagricultural land management. We can stop using synthetic pesticides and fertilizers; we need a plan — based on precautionary, organic, and regenerative principles — to move us forward to that goal, and we need it ASAP.”
Sources: https://www.cdpr.ca.gov/docs/sustainable_pest_management_roadmap/spm_roadmap.pdf and https://www.cdpr.ca.gov/docs/sustainable_pest_management_roadmap/spm_executive_summary_web.pdf
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
