24
Feb
Trump Administration’s Dismantling of Federal Environmental and Public Health Programs Shifts Focus to the States
(Beyond Pesticides, February 24, 2025) The sweeping firing of federal workers, including an estimated at 200,000 probationary employees (under one to two years of employment), will have broad impact on programs to protect health and safety as well as the environment, leaving a critical need for local and state government ito fill some of the gaps in critical programs, where possible. A headline in Science magazine warns, “Mass firings decimate U.S. science agencies,” and the dean of the College of Agricultural Sciences at Oregon State University told Oregon Public Broadcasting, “We’ve lost half of our teams, and all of these up-and-coming young scientists. . .so it’s like we’ve lost the next generation of scientists in agriculture and natural resources.” The same applies to important positions across the federal government, affecting every aspect of work necessary to protect public health and biodiversity, and address the climate crisis. In response to President Trump’s executive orders and actions, there has been, as The New York Times reports, “new lawsuits and fresh rulings emerging day and night,” raising what experts fear may become a constitutional crisis.
With the upheaval in the federal government, attention turns to the importance of state and local policies and programs that protect health and the environment. State legislatures have historically stepped in at various times to act to ban or restrict pesticides when the federal government fails to act. Pesticides, including DDT, chlordane, EDB, and DBCP, were first banned by a state or states before EPA took regulatory action. According to Jay Feldman, executive director of Beyond Pesticides, “We now need states and local government to respond to the seriousness of the current existential health, biodiversity, and climate crises and take holistic action that fills the tremendous gap caused by a critical disruption of federal environmental and public health programs.”
Over the past several years, state legislatures have led the charge on public safety and neonicotinoid regulations. The State of New York adopted the Birds & Bees Protection Act in January 2024 to ban the use of neonicotinoid insecticides by 2029; Vermont followed suit with a nearly identical bill. New Jersey and Maine are additional East Coast states that have the strongest laws on the books to eliminate all outdoor (nonagricultural) uses of bee-toxic neonicotinoid insecticides. In addition, many local governments have adopted ordinances protecting pollinators within their jurisdictions and governing pesticide use in parks, public places, and both public and private property.
As Connecticut considers similar legislation, Beyond Pesticides submitted comments to the legislature urging a “more robust response to an ecological crisis that is defined by a large body of peer-reviewed scientific findings,” instead of taking a “whac-a-mole” approach to addressing hazardous pesticides. The testimony states: “It is important that the proposed legislation prioritize ecological pest management practices, best defined in federal law as ‘organic,’ as the alternative that must be assessed as an alternative to the use of neonicotinoids and related compounds because of the numerous deficiencies in the evaluation of pesticides by EPA on which the State of Connecticut relies for determinations of safety… Continued dependence on pesticides, as the current bill language allows, fails to respond to the pesticide treadmill effect that elevates pest populations by depressing ecological balance while increasing pest resistance to pesticide applications and reducing plant resiliency to pest populations.”
In addressing specific chemicals or classes of chemicals—such as neonicotinoids, glyphosate, and dicamba—legislators must point to many other reasons for addressing pesticides at a state and local level, beginning with the failure of the U.S. Environmental Protection Agency (EPA) to carry out its mission to protect human health and the environment. In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), whether those harms are “unreasonable” depends on a weighing of costs and benefits. EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. In its Draft Herbicide Strategy Framework update, EPA says, “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” However, organic farmers are not reliant on these pesticides, challenging the necessity or “benefits” of pesticides and chemical-intensive farming.
The only way to truly protect pollinators, insects, birds, and other species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Converting the world’s agricultural systems to organic would have a tremendous positive impact on threatened populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which is necessary for the recovery of threatened and endangered species.
Organic agriculture can mitigate climate change. Agriculture is a major contributor to climate change. In a recent article in Science, Clark et al. show that even if fossil fuel emissions were eliminated immediately, emissions from the global food system alone would make it impossible to limit warming to 1.5°C and difficult even to realize the 2°C target. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced greenhouse gas (GHG) emissions. The contribution of animal agriculture has been estimated at 14.5% to 87% or more of total GHG emissions. These estimates include emissions of carbon dioxide, methane, nitrous oxide, and ammonia. The carbon dioxide contribution largely comes from converting land from natural forest to pasture or cropland.
“Regenerative” agriculture is widely considered to be a solution for reducing or even reversing these impacts. Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic “regenerative” agriculture. While recognizing practices that sequester carbon in the soil—practices that are central to organic agriculture—the so-called “regenerative agriculture” promoted by these groups ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients as well as for the heat and energy driving chemical reactions. It is important to see through this deception.
Organic practices preserve natural lands and biodiversity. Natural forests are more effective than tree plantations in sequestering carbon. Preserving natural land increases biodiversity, which also reduces dependence on petroleum-based pesticides. Organic farms are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife, as required by §205.200 of the regulations and per the §205.2 definition of Natural resources of the operation.”
Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture.
The National Organic Program provides for clarity and enforceability, while providing processes that are open and transparent to growers, consumers, and the public at large. As an established program, it also has its own funding mechanism. Any definition of “regenerative” must—at a minimum—meet organic standards.
As aptly stated by Jeff Moyer of the Rodale Institute, “We believe that in order to be regenerative, you have to start by being organic. It’s a little disingenuous to say you can regenerate soil health and sequester carbon and still use nitrogen fertilizers and synthetic pesticides. What you’re really saying is equivalent to saying ‘I want to be healthy as a person, but I still want to smoke cigarettes.'”
The climate crisis and the devastating decline in biodiversity are escalating because of uncontrolled and unnecessary reliance on toxic chemicals. These threats to life require a meaningful holistic strategy to end fossil fuel dependence and use of materials that release harmful levels of noxious gases (including greenhouse gases).
Agriculture must—across the board and on an expedited five-year schedule—shift to organic practices. Organic practices both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. Importantly, the data show that organic agriculture now operates without sacrificing productivity or profitability. While the vested economic interests in the petroleum and chemical industry cling to the status quo, there are good jobs and money to be made in a green economy.
Undefined “regenerative” agriculture falls short by ignoring the direct climate impacts of nitrogen fertilizers, the damage to soil health and ecosystem services caused by pesticides and chemical fertilizers, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and for the heat and energy-driving chemical reactions.
We need a national land management plan. Preserving natural land increases biodiversity, reducing dependence on petroleum-based pesticides, and is more effective in sequestering carbon. Biodiversity buffers against damage from climate change by allowing systems to evolve with changing conditions. Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change.
While all these changes are needed at a national—indeed, international—level, the current political climate makes it unlikely that these changes will be adopted by Congress and federal agencies. It is therefore crucial for state and local legislatures to step into the vacuum they have created. States can be a proving ground for changes that are urgently needed. In advancing legislation to eliminate individual bad-actor chemicals that have caught public attention, the language can include (or amendments can be attached) that:
- Defines “delineated allowable substances” as a part of the state pesticide registration process.” as a part of the state pesticide registration process. These allowed substances may include:
(a) Natural, organic or “non-synthetic.” A substance that is derived from mineral, plant, or animal matter and does not undergo a “synthetic” process as defined in the Organic Foods Production Act, 7 U.S.C. § 6502(21), as the same may be amended from time to time.
(b) Pesticides determined to be “minimum risk pesticides” pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and listed in 40 C.F.R. § 152.25(f)(1) or (2), as may be amended from time to time. - Eliminates chemical fertilizers that adversely affect soil health and the natural cycling of nutrients necessary for plant resiliency, thus decreasing vulnerability to plant diseases, infestation, and drought conditions;
- Establishes clear and enforceable definitions;
- Requires a systems plan (establishes baseline for management practices intended to create resiliency and prevent pests);
- Creates a rigorous standard for allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list, which should follow the process laid out in the Organic Foods Production Act;
- Incorporates a certification and enforcement system (third party enforcement);
- Maintains a process for public participation to ensure a feedback loop for continuous improvement; and
- Allocates adequate funding to ensure elements are carried out in a robust way.
Tell state legislators to focus on ecosystem protection, not just individual pesticides.
Message to Governor and state legislators
As the public looks for opportunities to advance policies and programs that protect health and the environment in the absence of federal programs, state legislatures are considering bills that zero in on individual pesticides. While these efforts help to educate the public on the systemic hazards of pesticides—and show individual pesticides to be the poster children for regulation that is inadequately protective—they offer an opportunity to address crises in human disease and biodiversity collapse and more broadly effect change at the state level facilitating a transition to regenerative organic practices that are healthy for ecosystems and people.
In addressing specific chemicals or classes of chemicals legislators must point to many other reasons for addressing pesticides at a state and local level, beginning with the failure of the U.S. Environmental Protection Agency (EPA) to carry out its mission to protect human health and the environment. In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), whether those harms are “unreasonable” depends on a weighing of costs and benefits. EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. Not true. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.
Organic agriculture can mitigate climate change. Agriculture is a major contributor to climate change. According to the International Panel of Climate Change, agriculture and forestry account for as much as 25% of human-induced greenhouse gas (GHG) emissions.
Organic farms are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.”
Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers. In addition, studies have found organically grown plant foods and milk to be nutritionally superior to those produced by chemical-intensive agriculture.
The National Organic Program provides for clarity and enforceability, while remaining open and transparent to growers, consumers, and the public at large.
The climate crisis and the devastating decline in biodiversity are escalating because of uncontrolled and unnecessary reliance on toxic chemicals. These threats to life require a meaningful holistic strategy to end our fossil fuel dependence and use of harmful materials.
We need to shift to 100% organic farming immediately. Please advance legislation that both eliminates individual bad-actor chemicals that have caught public attention and includes the following language:
- Define “delineated allowable substances” as a part of the state pesticide registration process that may include:
(a) Natural, organic or “non-synthetic” as defined in the Organic Foods Production Act, 7 U.S.C. § 6502(21).
(b) Pesticides determined to be “minimum risk pesticides” and listed in 40 C.F.R. § 152.25(f)(1) or (2).
- Eliminate chemical fertilizers that adversely affect soil health and the natural cycling of nutrients;
- Establishes clear and enforceable definitions;
- Require a systems plan as a baseline for management;
- Create a rigorous standard for allowed/prohibited substances list, which should follow the process laid out in the Organic Foods Production Act;
- Incorporate third party enforcement;
- Maintain a process for public participation to ensure a feedback loop for continuous improvement; and
- Allocate adequate funding.
Thank you.
