28
May
To Make Regenerative Meaningful, It Must Require Organic Certification as a Starting Point, according to Advocates
(Beyond Pesticides, May 28, 2024) Public comments are due May 29, 2024. With 40 percent of all vegetables grown in the U.S. coming from the state of California, the current state level process to define “regenerative agriculture†could have major impact on land management practices that address the current climate, biodiversity, and health crises. That is, according to advocates, if the process, directed by the California Department of Food and Agriculture (CDFA) departs from a history of poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture. Virtually all consumers of food have a stake in the outcome of the definition of “regenerative,†so the current public comment period, which closes tomorrow, May 29, 2024, can help influence the outcome.
As Beyond Pesticides has reported previously, the term “regenerative†is now increasingly being advanced as a loosely defined alternative to the organic standard and label, which is transparent, defined, certified, enforced, and subject to public input. The  publication AgFunderNews (AFN) in February published its updated “2024 list of agrifood corporates making regenerative agriculture commitments,†a who’s who of the largest food and agribusiness corporations worldwide. The list includes companies such as ADM, Cargill, Danone, General Mills, Tyson, Unilever, Walmart, and more with commitments to millions of acres in their supply chain practicing “regenerative†agriculture with target dates ranging from 2024 to 2050. AFN reporting on the “regenerative†trend states, “[O]ne big challenge is that ‘regenerative agriculture’ still has no set definition. While that still holds true, the bigger observation in 2024 is the number of companies leaning heavily on sustainability jargon to describe goals. With greenwashing pretty rampant nowadays, it will be important to check beneath the PR-friendly language at the actual acres, dates, practices and prescriptions.â€
CDFA’s Environmental Farming Act Science Advisory Panel (SAP) proposes a framework for developing a definition:
- Being applicable, relevant, and useful for California Agriculture.
- Leading to positive impacts on California’s environmental, social, human health, and economic goals, including climate goals.
- Providing measurable and verifiable outcomes, keeping in mind variability throughout the state, and – emphasizing outcomes farmers and ranchers can easily measure and that are not economically burdensome to measure.
- Allowing for context specific outcomes (in terms of scale, geographic location, diverse and/or innovative agricultural systems, goals, etc.)
- Include the idea that building soil health, including elements of physical quality, carbon sequestered, soil biodiversity, and alleviation of climate change (e.g., practices funded by the CDFA Healthy Soils Program) as a foundational element.
However, Beyond Pesticides states in comments that this framework will be not effective if definitions, policies, and rules fail to meet the following criteria:
- Definition clarity and enforceability;
- Systems plan (establishes baseline for management practices intended to create resiliency and prevent pests);
- Rigorous standard for allowed/prohibited substances list with mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
- Certification and enforcement system (third party enforcement);
- Process for public participation to ensure a feedback loop for continuous improvement; and
- Funding to ensure elements are carried out in a robust way.
Regenerative agriculture must be organic.
Organic agriculture, which has been widely adopted in California, fits the framework proposed by the SAP as well as the criteria above.
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.â€
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. CDFA should start by defining “regenerative†as—at a minimum—meeting organic standards.
It is crucial, as we move forward with a plan to harness agriculture in the fight against climate change, biodiversity collapse, and health problems, that we not be misled into promoting the same practices that have created the problem. 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.'”
Letter to California Department of Food and Agriculture’s Environmental Farming Act Science Advisory PanelÂ
We support the urgent need to adopt regenerative agricultural practices that mitigate climate change, improve soil health, restore biodiversity, enhance ecosystems, and contribute to human health. Past experience with poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture raises serious problems that well-intentioned efforts to define regenerative could repeat and, in the process, stifle the growth and continuous improvement of certified organic practices. Organic is a necessary baseline or foundation of a new regenerative standard because it eliminates the use of petrochemical pesticides and fertilizers in meeting the existential environmental and health crises of our time. A standard for “regenerative†must do this as well if it is to be helpful and not harmful in advancing the critical changes needed in this time of crises.
CDFA’s Environmental Farming Act Science Advisory Panel (SAP) proposes a framework for developing a definition. However, that framework will be ineffective if definitions, policies, and rules fail to meet these criteria:
- Definition clarity and enforceability;
- Systems plan (establishes baseline for management practices intended to create resiliency and prevent pests);
- Rigorous standard for allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
- Certification and enforcement system (third party enforcement);
- Process for public participation to ensure a feedback loop for continuous improvement; and
- Funding to ensure elements are carried out in a robust way.
Regenerative agriculture must be organic.
Organic agriculture, which has been widely adopted in California, fits the issues in the framework proposed by the SAP as well as the criteria above.
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 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.
While recognizing practices that sequester carbon in the soil “regenerative agriculture†employing toxic chemicals ignores the direct climate impacts of synthetic 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.
Organic agriculture benefits human health. By avoiding the use of antibiotics and toxic pesticides, organic agriculture protects farmworkers and consumers.
The USDA organic seal is backed by an enforceable inspection system. CDFA should start by defining “regenerative†as—at a minimum—meeting organic standards.
Thank you.
Letter to U.S. Secretary of Agriculture Tom Vilsack
I am concerned that “regenerative†agriculture, which is widely considered to be a solution for reducing or even reversing climate change, will have negative impacts if not properly defined. Unfortunately, a movement by promoters of chemical-intensive agriculture has fooled some environmentalists into supporting toxic “regenerative†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.
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 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.
We need a national plan to shift to 100% organic farming. Organic land management is more effective at reducing emissions and sequesters carbon in the soil. There is already a national program for certifying farms that meet organic standards. Organic operations must “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.â€
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.Â
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—for example, by protecting shorelines from storm damage.
Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change.
Thank you.
West save the farms!
May 29th, 2024 at 10:03 pm