12
Aug
Elevating the Urgent Need To Act on Biodiversity, Drawing on the EPA’s Emergency Ban of Dacthal Weed Killer
(Beyond Pesticides, August 12, 2024) When the U.S. Environmental Protection Agency (EPA) issued an emergency ban of the weed killer Dacthal (DCPA) last week, it said that there are no “practicable mitigation measures” to protect against identified hazards—a clear and honest assessment of the limits of pesticide product label changes and use restrictions. Now, the question is whether the same thinking can be applied across the EPA’s pesticide program, addressing the urgent need to protect biodiversity.
In the Dacthal proclamation, EPA said it consulted with the U.S. Department of Agriculture (USDA) on “alternatives to this pesticide,” and presumably determined that there were “alternative chemicals” that could be used in chemical-intensive agriculture—while not considering “alternatives to chemicals.” This is the framework that is understood to be EPA’s process that keeps pest management on a pesticide treadmill except in extremely rare cases (this being the second in nearly 40 years). It is also the framework that has led to catastrophic events or existential crises on biodiversity collapse, health threats, and the climate emergency.
On biodiversity, the mix of diverse and intricate relationships of organisms in nature that are essential to the sustaining of life, EPA’s pesticide program, the Office of Pesticide Programs, has led the U.S. down a road that can only be described, according to many health and environmental advocates, as apocalyptic, starting with the “insect apocalypse” and extending to all life. This is happening despite the availability of “alternatives to chemicals” that EPA does not factor into its decisions to allow, day-after-day and year-after-year, the use of deadly pesticides that are neither necessary nor the most effective way to achieve quality of life, public health protection, efficacy of pest management, productivity and profitability of agriculture, aesthetics for lawns and landscapes, and a livable future.
Listen (read these words aloud) to what EPA has to say (see page 4 of linked document) about its current ability to conduct regulatory reviews to “protect” endangered species: “Even if EPA completed this work for all of the pesticides that are currently subject to court decisions and/or ongoing litigation, that work would take until the 2040s, and even then, would represent only 5% of EPA’s ESA [Species Act] obligations.” This has given cause for too many in the U.S. Congress to call for a weakening of ESA, rather than charting a course for the transition to organic land management.
As a result, EPA has come up with a draft strategy, not to transition to alternative systems without reliance on toxic pesticides, but “to provide flexibility to growers to choose mitigations that work best for their situation.” Presumably, if that “situation” in a chemical-intensive agricultural operation requires continued use of a chemical known to destroy endangered species, that may be permitted. The strict standards required to meet the crisis head-on is not a part of this EPA proposal. Because, this is the frame that EPA is using, in the agency’s own words: “Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases.”
Recognizing the real threat with an honest assessment is the first step in adopting a transformational approach to change. Biodiversity, like the threat to human health (and they are intertwined) is an important place to begin to elevate the urgent need for transformational action.
The biodiversity crisis is one of multiple crises that are compounding one another. While human actions are contributing to an ongoing Holocene or sixth mass extinction, we are also facing crises in human disease and climate change. The Endangered Species Act focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend.
Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first at the ways it has contributed to the crisis in the first place.
The near extinction of a species of vulture brings into focus the importance of maintaining biodiversity for protecting human health. The loss of these underappreciated carrion eaters in India led to pollution of waterways by effluent from rotting carcasses and a burgeoning population of feral dogs, many of whom carried rabies. Similarly, in Wisconsin, researchers found that the presence of wolves reduced vehicle collisions with deer by 24%—an economic benefit 63 times greater than the cost of wolves killing livestock.
The World Health Organization (WHO) summarizes the connections between biodiversity and human health:
- Biodiversity provides many goods and services essential to life on Earth. The management of natural resources can determine the baseline health status of a community.
- Biodiversity supports human and societal needs, including food and nutrition security, energy, development of medicines and pharmaceuticals and freshwater, which together underpin good health. It also supports economic opportunities, and leisure activities that contribute to overall well-being. [For example, 70% of all cancer drugs today are natural or based on nature. Other potential benefits include a fungus that can eat plastic.]
- Land use change, pollution, poor water quality, chemical and waste contamination, climate change and other causes of ecosystem degradation all contribute to biodiversity loss and can pose considerable threats to human health. [“You rely on nature if you want to survive: It gives you food, it gives you water, it gives you trees that will protect the quality of the air you breathe,” says Maria Neira, MD, director of the Department of Environment, Climate Change, and Health for WHO. “It’s common sense: You need to protect what is protecting you. If we don’t, we are the losers, not the planet.”]
- Human health and well-being are influenced by the health of local plant and animal communities, and the integrity of the local ecosystems that they form. [We depend on an ecological balance that regulates our planet’s oxygen, water, and nutrient cycles to pollinate, nourish, and support all the organisms we consume.]
- Infectious diseases cause over one billion human infections per year, with millions of deaths each year globally. [Approximately two-thirds of known human infectious diseases are shared with animals, and most recently emerging diseases are associated with wildlife. Habitat destruction brings humans and wildlife into closer contact, dramatically increasing the risk of diseases caused by pathogens jumping to humans from wild animals.]
Biodiversity loss is harming our health and threatening the basic ecological cycles that keep us alive. “We are out of harmony with nature,” United Nations (UN) Secretary-General António Guterres told world leaders at the 2022 Biodiversity COP 15 (Conference of the Parties). “Humanity has become a weapon of mass extinction. … And ultimately, we are committing suicide by proxy.”
A series of reports from the United Nations Environment Program (UNEP) highlights how human activities threaten the healthy functioning of ecosystems that produce food and water, as well as one million species now at risk of extinction. The UNEP report, Food System Impacts on Biodiversity Loss, identifies the global food system as the primary driver of biodiversity loss. The report points to the conversion of natural ecosystems to crop production and pasture, with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases.
In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow use of chemicals that it recognizes will contribute to the problems.
The United Nations Convention on Biological Diversity (CBD) is the international legal instrument for “the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources.” It has been ratified by 196 nations—all the members of the United Nations except the United States and the Vatican. The CBD includes 21 action targets to be achieved by 2030, including reducing pesticide use by two-thirds, eliminating plastic waste, and “fully integrating biodiversity values into policies, regulations, planning, development processes, poverty reduction strategies, accounts, and assessments of environmental impacts at all levels of government and across all sectors of the economy, ensuring that all activities and financial flows are aligned with biodiversity values.”
While it is well known that climate change affects biodiversity, the reverse is not so well appreciated. Biodiversity is essential for limiting climate change. As summarized by the United Nations,
- When human activities produce greenhouse gases, around half of the emissions remain in the atmosphere, while the other half is absorbed by the land and ocean. These ecosystems—and the biodiversity they contain—are natural carbon sinks, providing so-called nature-based solutions to climate change.
- Protecting, managing, and restoring forests, for example, offers roughly two-thirds of the total mitigation potential of all nature-based solutions. Despite massive and ongoing losses, forests still cover more than 30 percent of the planet’s land.
- Peatlands—wetlands such as marshes and swamps—cover only 3 percent of the world’s land, but they store twice as much carbon as all the forests. Preserving and restoring peatlands means keeping them wet so the carbon doesn’t oxidize and float off into the atmosphere.
- Ocean habitats such as seagrasses and mangroves can also sequester carbon dioxide from the atmosphere at rates up to four times higher than terrestrial forests can. Their ability to capture and store carbon make mangroves highly valuable in the fight against climate change.
- Conserving and restoring natural spaces, both on land and in the water, is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving nature’s ability to absorb emissions.
Action is urgently needed to conserve—protect and enhance—biodiversity. Among the targets for 2030 set by the nations at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, this will require intensive actions that protect species and their habitats from toxic and other destructive threats, while restoring degraded ecosystems. The Kunming-Montreal Global Biodiversity Framework (GBF) adopted by COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”
Studies upon studies upon studies show that pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always—from DDT to neonicotinoids—endangered insects on a global level. Similarly, pesticides threaten food webs in aquatic and marine environments.
Pesticides threaten frogs and other amphibians in a way that demonstrates the potential to warp the growth and reproduction of all animals. Agricultural intensification, in particular pesticide and fertilizer use, is the leading factor driving declines in bird populations.
At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. In much of the U.S., agricultural fields are bare for half the year and support a single plant species for the other half. The difference between industrial agriculture and organic agriculture is that through their organic systems plans, organic producers are required to conserve—protect and increase—biodiversity.
In other words, a major reason that species are endangered is that EPA has registered pesticides that harm them. If EPA is to really protect endangered species, it must eliminate the use of toxic pesticides and encourage organic production. The agency’s recent proposals to “protect” endangered species from herbicides and insecticides are totally inadequate.
Congress is also considering measures that would weaken endangered species—and hence, biodiversity—protection. Five joint resolutions—S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86—have been introduced to roll back ESA regulations adopted in the Biden administration to those enacted in the Trump administration. S. 4753, “A bill to reform leasing, permitting, and judicial review for certain energy and minerals projects, and for other purposes,” has been passed out of the Senate Committee on Energy and Natural Resources. It weakens ESA protections by creating much shorter timelines for judicial review, additional categorical exclusions from the National Environmental Policy Act (NEPA) that could result in less science and planning for projects, tighter deadlines for agencies to complete the permitting process without increased capacity or funds. The Department of the Interior and its land management agencies have been consistently underfunded and understaffed. Shortening their deadlines without fixing those issues would lead to a rushed permitting process and limited public engagement.
>> Tell EPA and Congress to support measures that protect endangered species and their habitats and to reject measures that weaken that protection.
The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.
Letter to EPA
Pesticide use is a major cause of declining biodiversity, which is manifested in extinctions, endangered species, and species vulnerable to environmental disturbances—including climate change, habitat fragmentation, and toxic chemicals. If EPA is serious about protecting biodiversity, it must look first at the ways it has contributed to the crisis in the first place.
Biodiversity is critical for human health. It provides many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that keep us alive.
Biodiversity is essential for limiting climate change. It provides land and sea ecosystems that are natural carbon sinks, forests with two-thirds of the total mitigation potential of all nature-based solutions, wetlands covering 3 percent of the world’s land and storing twice as much carbon as all the forests, and seagrasses and mangroves that can sequester carbon dioxide at rates up to four times higher than terrestrial forests.
Conserving and restoring biodiversity is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving Earth’s ability to absorb emissions.
Among the targets for 2030 set by The UN Convention on Biological Diversity (CBD) at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since only 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, actions that protect species and their habitats from toxic and other destructive threats are critical, while restoring degraded ecosystems. COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”
Pesticides are a major contributor to the loss of insect biomass and diversity known as the “insect apocalypse,” particularly in combination with climate change. Insects are important as pollinators and as part of the food web that supports all life, so the loss of insects is a threat to life on Earth. EPA’s registration of insecticides has always endangered insects on a global level. Pesticides threaten food webs in aquatic and marine environments, warp the growth and reproduction of all animals, and are a leading factor driving declines in bird populations.
In view of the many steps that have been identified to stop both biodiversity loss and global climate change, it is beyond disappointing to see our “Environmental Protection Agency” continuing to allow the use of chemicals that it recognizes will contribute to the problems.
At a more foundational level, EPA approves pesticides that, in supporting industrial agriculture, eliminate habitat—either through outright destruction or through toxic contamination. The UN Environment Program (UNEP) identifies the global food system as the primary driver of biodiversity loss, pointing to the conversion of natural ecosystems to crop production and pasture with concomitant use of toxic chemicals, monoculture, and production of greenhouse gases. In contrast, organic producers are required to conserve biodiversity.
Thus, a major reason that species are endangered is that EPA has registered pesticides that harm them. EPA must protect endangered species by eliminating the use of toxic pesticides and encouraging organic production.
Thank you.
Letter of Congress
The biodiversity crisis is one of multiple crises that compound one another. While human actions are contributing to a sixth mass extinction, we are also facing crises in human disease and climate change.
Biodiversity is critical for human health. It provides many goods and services essential to life on earth, supports human and societal needs, influences human health and well-being, and protects against exposure to zoonotic diseases. Biodiversity loss harms our health and threatens the ecological cycles that keep us alive.
Biodiversity is essential for limiting climate change. It provides land and sea ecosystems that are natural carbon sinks, forests with two-thirds of the total mitigation potential of all nature-based solutions, wetlands covering 3 percent of the world’s land and storing twice as much carbon as all the forests, and seagrasses and mangroves that can sequester carbon dioxide at rates up to four times higher than terrestrial forests.
Conserving and restoring biodiversity is essential for limiting carbon emissions and adapting to an already changing climate. About one-third of the greenhouse gas emissions reductions needed in the next decade could be achieved by improving Earth’s ability to absorb emissions.
Among the targets for 2030 set by The UN Convention on Biological Diversity (CBD) at COP 15 is “30X30”—“Effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services.” Since only 17% and 10% of the world’s terrestrial and marine areas respectively are now protected, actions that protect species and their habitats from toxic and other destructive threats are critical, while restoring degraded ecosystems. COP 15 warns: “Without such action, there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.”
The Endangered Species Act (ESA) focuses on the species and habitats most at risk of extinction. However, the statement of purpose also recognizes the importance of conserving the ecosystem on which they depend. Biodiversity loss is harming our health and threatening the basic ecological cycles that keep us alive. “We are out of harmony with nature,” UN Secretary-General António Guterres told the 2022 Biodiversity COP 15 (Conference of the Parties). “Humanity has become a weapon of mass extinction. … And ultimately, we are committing suicide by proxy.”
Congress is considering measures that would weaken endangered species—and hence, biodiversity—protection. Five joint resolutions—S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86—have been introduced to roll back ESA regulations adopted in the Biden administration to those enacted in the Trump administration. S. 4753, “A bill to reform leasing, permitting, and judicial review for certain energy and minerals projects, and for other purposes,” has been passed out of the Senate Committee on Energy and Natural Resources. It weakens ESA protections by creating much shorter timelines for judicial review, additional categorical exclusions from the National Environmental Policy Act (NEPA) that could result in less science and planning for projects, tighter deadlines for agencies to complete the permitting process without increased capacity or funds. The Department of the Interior and its land management agencies have been consistently underfunded and understaffed. Shortening their deadlines without fixing those issues would lead to a rushed permitting process and limited public engagement.
Please support 30X30 and other goals of COP 15. Please oppose S.J. Res 80, S.J. Res 81, S.J. Res 84, S.J. Res 85, and S.J. Res 86 and S. 4753.
Thank you.
