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Action of the Week

Action of the week is intended to provide you, our supporters and network, with one concrete action that you can take each week to have your voice heard on governmental actions that are harmful to the environment and public and worker health, increase overall pesticide use, or undermine the advancement of organic, sustainable, and regenerative practices and policies. As an example, topics may include toxic chemical use, pollinator protection, organic agriculture and land use, global climate change, and regulatory or enforcement violations.

02/10/2020 — Save the National Environmental Policy Act (NEPA)

Through the publication of Rachel Carson’s Silent Spring, pesticide dangers became a major driver for the environmental movement. Perhaps the most effective piece of environmental legislation is the National Environmental Policy Act (NEPA). Because NEPA requires a wide-ranging evaluation of the potential environmental impacts of federal actions, as well as alternatives, it serves as a model for environmental decision making. Now key elements of NEPA are under attack by the Trump Administration.

Ask your Congressional Representatives to pressure the White House to retract the proposed changes. At the same time, add your signature to the Beyond Pesticides public comment to Council on Environmental Quality (CEQ).

NEPA established the Council on Environmental Quality (CEQ) as the agency within the White House that is responsible for carrying out the purposes of the act. The regulations established by the CEQ have persisted through changes in administrations for more than 30 years without major modification. Changes proposed by the Trump Administration’s CEQ threaten this model decision-making process.

NEPA is a procedural law. It sets no environmental standards, but sets a standard for evaluating environmental impacts of proposed federal actions. It requires that federal agencies consider the short-term, long-term, and cumulative impacts of actions and disclose them to the public. Courts have ruled, for example, that registration of a pesticide by EPA is not sufficient to address environmental concerns under NEPA.

The Trump CEQ proposal will weaken NEPA regulations in a number of ways:

  • It will limit the scope of required review to exclude from NEPA review non-federal projects with minimal federal funding or minimal federal involvement.
  • It will remove the requirement for cumulative impact analysis, an important component of NEPA review. This removes the examination of greenhouse gas emissions.
  • It advises agencies to evaluate the applicability of NEPA in a way that conflicts with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act.”
  • It defines the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant.”
  • It establishes tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments. While this may eliminate some wasted time, it also limits the depth of analysis.

Ask your Congressional Representatives to pressure the White House to retract the proposed changes. At the same time, add your signature to the Beyond Pesticides public comment to Council on Environmental Quality (CEQ).

Petition to CEQ

(Comment to CEQ that must be submitted to Regs.gov by March 10. https://www.regulations.gov docket number CEQ-2019-0003)

NEPA requires that federal agencies perform a comprehensive, cumulative, in-depth analysis of the environmental impacts of proposed federal actions and alternatives to them. NEPA establishes a standard of decision-making for all federal agencies. CEQ’s proposed changes to NEPA regulations are unacceptable and should be scrapped. They would:

*Unreasonably limit the scope of required review;

*Remove the requirement for cumulative impact analysis and the examination of greenhouse gas emissions;

*Conflict with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act;”

*Define the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant;” and

*Establish tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments, limiting the depth of analysis.

Thank you for your consideration.

Letter to Congress

I am writing to ask that you intervene with the Council on Environmental Quality to prevent the issuance of regulations that would weaken environmental decision making.

Through the publication of Rachel Carson’s Silent Spring, pesticide dangers became a major driver for the environmental movement. Perhaps the most effective piece of environmental legislation is the National Environmental Policy Act (NEPA). Because NEPA requires a wide-ranging evaluation of the potential environmental impacts of federal actions, as well as alternatives, it serves as a model for environmental decision making. Now key elements of NEPA are under attack by the Trump Administration.

NEPA established the Council on Environmental Quality (CEQ) as the agency within the White House that is responsible for carrying out the purposes of the act. The regulations established by the CEQ have persisted through changes in administrations for more than 30 years without major modification. Changes proposed by the Trump Administration’s CEQ threaten this model decision-making process.

NEPA is a procedural law. It sets no environmental standards, but sets a standard for evaluating environmental impacts of proposed federal actions. It requires that federal agencies consider the short-term, long-term, and cumulative impacts of actions and disclose them to the public. Courts have ruled, for example, that registration of a pesticide by EPA is not sufficient to address environmental concerns under NEPA.

The Trump CEQ proposal will weaken NEPA regulations in a number of ways:

*It will limit the scope of required review to exclude from NEPA review non-federal projects with minimal federal funding or minimal federal involvement.

*It will remove the requirement for cumulative impact analysis, an important component of NEPA review. This removes the examination of greenhouse gas emissions.

*It advises agencies to evaluate the applicability of NEPA in a way that conflicts with NEPA’s requirement that “the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act.”

*It defines the universe of “reasonable alternatives” that must be considered in a restrictive way, requiring “economic feasibility” and that they “meet the goals of the applicant.”

*It establishes tight time requirements for completing environmental assessments –time limits that are not currently met by most assessments. While this may eliminate some wasted time, it also limits the depth of analysis.

Please tell the CEQ to revoke these proposed regulations.

Thank you.

02/03/2020 — Save Mayflies and the Ecosystems that Depend on Them

In more bad news from the insect world, recent research published in the Proceedings of the National Academy of Sciences reveals a precipitous decline in numbers of mayflies where they have been historically abundant. The research finds that in the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly (genus Hexagenia) adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%. Neonicotinoid insecticides are a significant factor in this decline because mayflies are extremely vulnerable to their impacts, even at very low exposure levels.

Ask Congress to tell EPA, USDA, and the Department of Interior to develop a joint effort to ensure that its decisions and compliance with its authorizing statutes address the crisis of the threat to mayflies.

Ephemeroptera to entomologists—“mayflies” to the rest of us—is an insect order comprising keystone species, on which other species in an ecosystem are very dependent, and without which, the ecosystem would undergo drastic change. The plummeting mayfly “count” is especially alarming because mayflies are a critical, primary food source in aquatic and terrestrial ecosystems, and provide an important ecological service. As the research study notes, “Seasonal animal movement among disparate habitats is a fundamental mechanism by which energy, nutrients, and biomass are transported across ecotones. A dramatic example of such exchange is the annual emergence of mayfly swarms from freshwater benthic [lake or river bottom] habitats. . . . Annual . . . emergences represent the exchange of hundreds of tons of elemental nutrients, thousands of tons of biomass, billions of organisms, and trillions of calories worth of energy to the surrounding terrestrial habitat. . . . A single emergence event can produce 87.9 billion mayflies, releasing 3,078.6 tons of biomass into the airspace over several hours.” According to Purdue University ecologist Jason Hoverman, PhD, “Mayflies serve critical functions in both aquatic and terrestrial ecosystems. Because of their important role as prey, reductions in their abundance can have cascading effects on consumers throughout the food web.” Without this critical keystone species, an important food source and nutrient recycler would be lost.

Thus, although neonics are directly toxic to many insects, the role of pesticides in destabilization of ecosystems is not necessarily direct. Beyond direct toxicity, pesticides can significantly reduce, change the behavior of, or destroy populations of plants and animals. These effects can ripple up and down food chains, causing what is known as a trophic cascade. The loss or reduction of populations at any trophic level—including amphibians, insects, or plants—can result in changes that are difficult to perceive, but nonetheless equally damaging to the stability and long-term health of an ecosystem.

Three phenomena account for most of the decrease in mayfly populations: (1) dramatically increased use of neonicotinoid pesticides, to which mayflies are highly sensitive; (2) algal blooms, especially in Lake Erie, caused primarily by runoff of agricultural fertilizers and other nutrient-dense pollutants; and (3) the warming impacts of the climate crisis, which include higher water temperatures that can wreak havoc with the development of these tiny creatures.

Because the threats to mayflies cut across regulatory boundaries, it is important for federal agencies to cooperate in protecting them. Action must be taken to protect vulnerable waterways from neonicotinoid contamination. The frequency of detections in U.S. waterways cannot be overlooked. Such routine detections, even at low levels, indicate that our waterways are being overloaded with mobile and persistent chemicals at highly elevated concentrations.  Thus far, little action has been taken to restrict the use of these chemicals in response to the independent scientific literature and EPA risk data that identify direct threats to aquatic invertebrates, as well as indirect threats to higher trophic organisms. Federal benchmarks based on testing on insensitive species are not protective of more sensitive species. Similarly, action is needed to prevent runoff from agricultural fields and feedlots and adopt climate-friendly policies.

Ask Congress to tell EPA, USDA, and the Department of Interior to develop a joint effort to ensure that its decisions and compliance with its authorizing statutes address the crisis of the threat to mayflies.

Letter to Congress

I am writing to call your attention to a serious ecological problem that requires a coordinated effort across government agencies.

Recent research published in the Proceedings of the National Academy of Sciences reveals a precipitous decline in numbers of mayflies where they have been historically abundant. In the Northern Mississippi River Basin, seasonal emergence of burrowing mayfly adults declined by 52% from 2012 to 2019; in the Western Lake Erie Basin, from 2015 to 2019, the reduction was a shocking 84%.

The plummeting mayfly “count” is alarming because mayflies are a critical, primary food source in aquatic and terrestrial ecosystems, and provide an important ecological service. As the research study notes, “Seasonal animal movement among disparate habitats is a fundamental mechanism by which energy, nutrients, and biomass are transported across ecotones…A single emergence event can produce 87.9 billion mayflies, releasing 3,078.6 tons of biomass into the airspace over several hours.”

According to Purdue University ecologist Jason Hoverman, PhD, “Mayflies serve critical functions in both aquatic and terrestrial ecosystems. Because of their important role as prey, reductions in their abundance can have cascading effects on consumers throughout the food web.” Without these critical keystone species, important food sources and nutrient recyclers would be lost.

Three phenomena account for most of the decrease in mayfly populations: (1) dramatically increased use of neonicotinoid pesticides, to which mayflies are highly sensitive; (2) algal blooms, especially in Lake Erie, caused primarily by runoff of agricultural fertilizers and other nutrient-dense pollutants; and (3) the warming impacts of the climate crisis, which include higher water temperatures that can wreak havoc with the development of these tiny creatures.

Because threats cut across regulatory boundaries, it is important for federal agencies to cooperate in protecting mayflies. U.S. waterways are being overloaded with mobile and persistent chemicals at highly elevated concentrations.  Little action has been taken to restrict the use of toxic chemicals despite independent scientific literature and EPA risk data that identify direct threats to aquatic invertebrates, as well as indirect threats to higher trophic organisms. Similarly, action is needed to prevent runoff from agricultural fields and feedlots and adopt climate-friendly policies.

Thank you,

01/27/2020 — Insist that the Veterans Administration Cover Conditions Caused by Agent Orange

United States military veterans suffering from bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms after their exposure to Agent Orange will remain unprotected and uncompensated until at least late 2020, according to a letter sent by Veterans Affairs (VA) Secretary Robert Wilkie to U.S. Senator Jon Tester (D-MT).

Send a letter to Veterans Affairs (VA) Secretary Robert Wilkie insisting that bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms be added to the VA’s list of eligible conditions.

Congress included a provision in the must-pass December federal spending bill requiring VA to provide legislators “a detailed explanation” for the now multi-year delay in determining whether to list the diseases. The provision is intended to cut through the ongoing delays, but there is no indication VA is going to meet the 30-day deadline. “The longer VA continues to drag its feet on expanding the list of conditions associated with Agent Orange, the longer our veterans continue to suffer—and die—as a result of their exposure,” Senator Tester said in a statement to the news site Connecting Vets. He continued, “It’s time for VA to stop ignoring the overwhelming evidence put forth by scientists, medical experts and veterans and do right by those who served. Any prolonging of their suffering is unacceptable.” 

The delay is seen by advocates for veterans as a serious lack of support and compensation at a time when the current administration is mobilizing the military. In October 2019, U.S. Senator Sherrod Brown’s (D-OH) attempt to introduce a resolution requiring the Trump Administration’s VA to list the diseases was shot down by U.S. Senate Veterans Affairs Committee Chairman Johnny Isakson (R-GA), citing costs. Rick Weidman, legislative director of Vietnam Veterans for America, summed up his response to ProPublica, “If you can afford the goddamn war, you can afford to take care of the warriors.”

“Some might accuse this body that we are waiting for them to die, as hard as it is to say that,” Sen. Brown said on the Senate floor. He continued, “Veterans shouldn’t have to fight this one at a time … we did this to them. The American government decided to spray Agent Orange. We knew it was harmful.”

According to Military Times, 83,000 veterans suffer from bladder cancer, Parkinson’s-like symptoms or hypothyroidism, and an untold number have high blood pressure. It is imperative that soldiers who fight for their country know they will be compensated when they fall ill as a result of their service.

Agent Orange, given its name because it was stored in orange striped drums, contained the active ingredients 2,4-D and 2,4,5-T. This formulation was contaminated with the highly toxic 2,3,7,8-tetrachlorodibenzo-p-dioxin (also called TCDD or simply dioxin) and is now banned. Not only were soldiers exposed on the battlefield, but many veterans who flew in post-Vietnam UC-123 Agent Orange spray aircraft had their health devastated by residual contamination.  

The Vietnam government is part of an ongoing lawsuit against Bayer’s Monsanto as the manufacturer of the deadly herbicide during the war. Recent reports find that dioxin continues to contaminate Vietnam’s soils, water, sediment, fish, aquatic species, and food supply.

While Agent Orange is banned, 2,4-D, which comprised one half of its make-up, is still one of the most widely used herbicides on lawns, school grounds, and parks today. It is considered a possible human carcinogen, and has been linked to liver damage and endocrine disruption in humans, in addition to being toxic to wildlife, pets and beneficial insects. Previous research from the U.S. Environmental Protection Agency has detected dioxin contamination in a number of 2,4-D herbicide products produced for consumer sale.

Send a letter to Veterans Affairs (VA) Secretary Robert Wilkie insisting that bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms be added to the VA’s list of eligible conditions.

Letter to Secretary Robert Wilkie

Dear Secretary Wilkie:

I am writing in support of United States military veterans suffering from bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms after their exposure to Agent Orange—who remain unprotected and uncompensated.

The VA continues to drag its feet on expanding the list of conditions associated with Agent Orange, and our veterans continue to suffer—and die—as a result of their exposure. As Senator Tester said, “It’s time for VA to stop ignoring the overwhelming evidence put forth by scientists, medical experts and veterans and do right by those who served. Any prolonging of their suffering is unacceptable.”

Your delay is evidence of a serious lack of support and compensation for veterans at a time when the current administration is mobilizing the military. Opponents of compensation cite costs, while others, like Rick Weidman, legislative director of Vietnam Veterans for America, say, “If you can afford the goddamn war, you can afford to take care of the warriors.”

“Some might accuse this body that we are waiting for them to die, as hard as it is to say that,” U.S. Senator Sherrod Brown said on the Senate floor. He continued, “Veterans shouldn’t have to fight this one at a time … we did this to them. The American government decided to spray Agent Orange. We knew it was harmful.” According to Military Times, 83,000 veterans suffer from bladder cancer, Parkinson’s-like symptoms or hypothyroidism, and an untold number have high blood pressure.

It is imperative that soldiers who fight for their country know they will be compensated when they fall ill as a result of their service. Please add bladder cancer, hypothyroidism, hypertension, and Parkinson’s-like symptoms to the VA’s list of eligible conditions.

Thank you.

01/17/2020 — Send a Message to EPA: Do Your Job to Protect Health and the Environment

As news reports come in demonstrating the threats to major groups of organisms, such as insects and birds, and the stability of Earth's ecosystems, and scientists appeal for major policy changes, recent actions by the Environmental Protection Agency's Science Advisory Board highlight the need for public insistence that EPA do its job.

>>Tell EPA Administrator Andrew Wheeler to follow the advice of scientists and do his job. Tell your Congressional representatives to support scientific integrity at EPA and other agencies.

Although the influence of regulated corporations has historically silenced science that threatens profits–as shown by industry reaction to Rachel Carson's Silent Spring—attacks on science in federal agencies have increased in the Trump administration. EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. Now EPA's war on its own scientists has reached the point that its Science Advisory Board, which oversees the scientific integrity of the agency's regulation, posted letters on-line criticizing EPA's rollback of environmental protections. As reported in a front page story on January 1, 2020 by The New York Times, “A top panel of government-appointed scientists, many of them hand-selected by the Trump administration, said on Tuesday that three of President Trump's most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science.”

These most recent rollbacks involve protection of waterways, limitations on vehicle emissions, and use of scientific data to support health regulations. Without reliance on science, agency policies cannot fail to be arbitrary and capricious – the standard of irresponsibility in government. The Times quoted Patrick Parenteau, a professor of law with the Vermont Law School“The courts basically say if you're going to ignore the advice of your own experts you have to have really good reasons for that. And not just policy reasons but reasons that go to the merits of what the critiques are saying.”

>>Send a message to EPA Administrator Andrew Wheeler that he must do his job, as supported by the best available science.

Letter to EPA Administrator Wheeler:

As news reports come in demonstrating the threats to major groups of organisms, and the stability of Earth’s ecosystems, and as international scientists appeal for major policy changes, action by the Environmental Protection Agency (EPA) to protect biodiversity and ecosystem integrity has never been more critical. Recent actions by the EPA’s Science Advisory Board highlight the need for public insistence that the agency do its job.

Under your leadership, EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. Now EPA’s own Science Advisory Board, which oversees the scientific integrity of the agency’s regulation, has posted letters on-line criticizing EPA’s rollback of environmental protections. As reported by The New York Times, “A top panel of government-appointed scientists, many of them hand-selected by the Trump administration, said on Tuesday that three of President Trump’s most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science.”

These most recent rollbacks involve protection of waterways, limitations on vehicle emissions, and use of scientific data to support health regulations. Without reliance on science, agency policies cannot fail to be arbitrary and capricious–the standard of irresponsibility in government. The Times quoted Patrick Parenteau, a professor of law with the Vermont Law School, “The courts basically say if you’re going to ignore the advice of your own experts you have to have really good reasons for that. And not just policy reasons but reasons that go to the merits of what the critiques are saying.”

It is time for you, as the Administrator of EPA, to listen to your own advisors and the best available science and act to preserve life on Earth.

Thank you.

Letter to Congressional Representatives and Senators:

I am writing to ask you to request EPA Administrator to follow the advice of agency scientists and do his job to protect human health and the living environment.

As news reports come in demonstrating the threats to major groups of organisms, and the stability of Earth’s ecosystems, and as international scientists appeal for major policy changes, action by the Environmental Protection Agency to protect biodiversity and ecosystem integrity has never been more critical. Recent actions by the Environmental Protection Agency’s Science Advisory Board highlight the need for public insistence that EPA do its job.

Under the current administration, EPA has dismissed findings of scientists concerning chlorpyrifos, atrazine, and synthetic pyrethroids. Now EPA’s own Science Advisory Board, which oversees the scientific integrity of the agency’s regulation, has posted letters on-line criticizing EPA’s rollback of environmental protections. As reported in a front page story by The New York Times, “A top panel of government-appointed scientists, many of them hand-selected by the Trump administration, said on Tuesday that three of President Trump’s most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science.”

These most recent rollbacks involve protection of waterways, limitations on vehicle emissions, and use of scientific data to support health regulations. Without reliance on science, agency policies cannot fail to be arbitrary and capricious–the standard of irresponsibility in government. The Times quoted Patrick Parenteau, a professor of law with the Vermont Law School, “The courts basically say if you’re going to ignore the advice of your own experts you have to have really good reasons for that. And not just policy reasons but reasons that go to the merits of what the critiques are saying.”

It is time for the Administrator of EPA to listen to his own advisors and the best available science and act to preserve life on Earth.

Thank you.

 

01/13/2020 — Take Action: Help Restore Protections for Migratory Birds

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

Ask your U.S. Representative to support and cosponsor the Migratory Bird Protection Act. Thank those who are already cosponsors.

Songbirds Threatened. The poisonous farm fields that migratory birds forage reduce their weight, delay their travel, and ultimately jeopardize their survival, according to “A neonicotinoid insecticide reduces fueling and delays migration in songbirds,“ published in the journal Science. Like their effects on insect pollinator populations, neonicotinoid insecticides generally do not cause acute poisoning and immediate death, but instead precipitate a cascade of sublethal impacts reducing their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices.

Bird Habitat Threatened in ArkansasA citizen science monitoring project of Audubon Arkansas found evidence of contamination from the weed killer dicamba far from the genetically engineered soybean and cotton fields, documenting nearly 250 observations of dicamba symptomology across 17 Arkansas counties. Community scientists were trained by Audubon to detect dicamba symptoms. Dan Scheiman, PhD, bird conservation director for the organization, after launching the project this spring, said, “Spraying dicamba on millions of acres of soybean and cotton is an uncontrolled experiment that puts sensitive habitats at unacceptable risk. In a landscape full of genetically engineered crops, the atmospheric build-up of volatized dicamba may result in significant damage to our state natural areas, wildlife management areas, national wildlife refuges, family farms, and the wildlife they harbor.”

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit. The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials use the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines, and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.

Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

On January 8, U.S. Representative Alan Lowenthal and 18 bipartisan cosponsors introduced the Migratory Bird Protection Act (H.R. 5552) to restore the critical protections removed by the Trump Administration.

Ask your U.S. Representative to support and cosponsor the Migratory Bird Protection Act. Thank those who are already cosponsors.

Letter to request cosponsorship

I am writing to ask you to restore important protections for migratory birds by cosponsoring H.R. 5552, the Migratory Bird Protection Act.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

Songbirds Threatened: The poisonous farm fields that migratory birds forage reduce their weight, delay their travel, and ultimately jeopardize their survival, according to “A neonicotinoid insecticide reduces fueling and delays migration in songbirds,“ published in the journal Science. Like their effects on insect pollinator populations, neonicotinoid insecticides generally do not cause acute poisoning and immediate death, but instead precipitate a cascade of sublethal impacts reducing their fitness in the wild. As the authors told Environmental Health News, the study is a call not simply to ban neonics or one class of chemical, but to change the entire farming system toward more sustainable bird and bee-friendly practices.

Bird Habitat Threatened in Arkansas: A citizen science monitoring project of Audubon Arkansas found evidence of contamination from the weed killer dicamba far from the genetically engineered soybean and cotton fields, documenting nearly 250 observations of dicamba symptomology across 17 Arkansas counties. Community scientists were trained by Audubon to detect dicamba symptoms. Dan Scheiman, PhD, bird conservation director for the organization, after launching the project this spring, said, “Spraying dicamba on millions of acres of soybean and cotton is an uncontrolled experiment that puts sensitive habitats at unacceptable risk. In a landscape full of genetically engineered crops, the atmospheric build-up of volatized dicamba may result in significant damage to our state natural areas, wildlife management areas, national wildlife refuges, family farms, and the wildlife they harbor.”

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit. The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials used the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.
Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

Please cosponsor the Migratory Bird Protection Act (H.R. 5552) introduced by Representative Alan Lowenthal and 18 bipartisan cosponsors to restore the critical protections removed by the Trump Administration.

Letter to current cosponsors

I am writing to thank you for cosponsoring H.R. 5552, the Migratory Bird Protection Act.

Birds are facing an existential crisis. Three billion birds have disappeared since 1970. Two out of three birds are threatened by climate change. In spite of this crisis, our nation’s most important bird protection law, the Migratory Bird Treaty Act (MBTA) is being weakened by the Trump Administration’s Department of the Interior.

The Migratory Bird Treaty Act (MBTA) adds protection to migratory birds that are not protected under the Endangered Species Act. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture or kill any migratory bird without a permit.  The MBTA covers not only hunting, trapping and poaching activities, but extends to other activities that kill migratory birds. Beginning in the 1970s, federal officials used the act to prosecute and fine companies up to $15,000 per bird for accidental deaths on power lines, in oil pits, in wind turbines and by other industrial hazards. The MBTA has been applied to prosecute farmers who inadvertently poison migratory birds by use of pesticides.

Yet in 2017, the Department of the Interior issued a policy that relieved industries of the requirement to protect birds, and they will no longer be held accountable for bird deaths. In addition, the agency is expected to propose rules to make this policy change permanent.

Thank you for cosponsoring H.R. 5552, the Migratory Bird Protection Act.

01/06/2020 — End Factory Farms: Support the Farm System Reform Act

In the midst of recalls of romaine lettuce contaminated with a pathogenic strain of E. coli, states and counties across the country are calling for a moratorium on large confined animal feeding operations (CAFOs). Now Senator Cory Booker is seeking to pass similar legislation at the national level. These industrial-scale operations are commonly referred to as “factory farms.”

>>Tell your U.S. Senator to cosponsor the Farm System Reform Act.

In the last week of November 2019, the Centers for Disease Control and Prevention (CDC) issued a food safety alert concerning a multistate outbreak of E. coli linked to romaine lettuce harvested from Salinas, California. As of November 25, 67 cases had been reported across 19 states, 39 of which required hospitalization, including six who developed kidney failure. The E. coli strain causing the outbreak — O157:H7, also known as STEC — is genetically identical to that responsible for lettuce-related outbreaks in 2017 and 2018. STEC is a dangerous, Shiga toxin-producing type of E. coli. Other outbreaks occurred earlier in 2019 as well.

Dangerous strains of E. coli, including O157:H7, are typically associated with cattle in feedlot conditions. The first of the two outbreaks in 2018 was traced back to manure runoff from a CAFO in the vicinity of the lettuce farm, which polluted water that was used to irrigate the lettuce fields. CAFOs are a major source of water contamination throughout the U.S. As noted by the Arizona Department of Environmental Quality"Nationwide and in Arizona, the potential for surface and ground water pollution exists through livestock facility discharge of manure-contaminated run off to natural waterways and through wastewater leaching to aquifers. Water and air pollution lead the list of concerns that have led to a number of state and local initiatives to institute moratoria on new and expanded CAFOs. Iowa, which has experienced an explosion of CAFOs, is the example these people want to avoid. In South Dakota, Lyle Reimnitz, who lives a half-mile from a Davison County hog farm with a permit for 8,000 sows, says, “I don't want to see South Dakota become another Iowa,” he said. “We don't need all our rivers and streams polluted. I know everybody wants cheap meat, but that comes at a terrible price for people who live here.”

In Wisconsin, supporters of a statewide moratorium on CAFOs are urging concerned citizens to ask County Supervisors, Town Board Members, and City Councilors to pass resolutions supporting a state-wide CAFO moratorium. In California, a report on dairy CAFOs found that “major production externalities are still imposed upon the communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large part to lack of resources, information, enforcement capability and political will on the part of local and regional regulatory agencies.” And, in Indiana, a report by the Indiana Business Research Center found, “For town residential properties, having the closest RLO [regulated livestock operation, or CAFO] upwind of the residence reduced the sale price by $4,980.00 and if the closest RLO contained dairy cattle, the sale price was further reduced by $32,340.00 for every 100 mature head.” In addition to these concerned citizens, the American Public Health Association has also called for a moratorium on CAFOs.

A majority of Americans say they want more stringent oversight of large-scale livestock operations, according to a national poll by Johns Hopkins University's Center for a Livable Future released December 10, 2019.

Traditional family farmers, and groups like the National Farmers Union, favor judicious regulatory controls due to the overall deleterious impacts these industrial agricultural sites have on rural communities. Other impacts include odors and fugitive dust that might contain antibiotic-resistant organisms.

Senator Booker's bill, the Farm System Reform Act, would require that "corporate integrators" are "responsible for pollution and other harm caused by CAFOs,” which would be phased out by 2040.  

>>Tell your U.S. Senator to cosponsor the Farm System Reform Act.

Letter to Congress

I am writing to ask you to cosponsor the Farm System Reform Act, unveiled by Senator Cory Booker in December.

In the midst of recalls of romaine lettuce contaminated with a pathogenic strain of E. coli, states and counties across the country are calling for a moratorium on large confined animal feeding operations (CAFOs). Sen. Booker’s bill seeks a moratorium at the national level.

In the last week of November 2019, the Centers for Disease Control and Prevention (CDC) issued a food safety alert concerning a multistate outbreak of E. coli linked to romaine lettuce harvested from Salinas, California. As of November 25, 67 cases had been reported across 19 states, 39 of which required hospitalization, including six who developed kidney failure. The E. coli strain causing the outbreak — O157:H7, also known as STEC — is genetically identical to that responsible for lettuce-related outbreaks in 2017 and 2018. STEC is a dangerous, Shiga toxin-producing type of E. coli. Other outbreaks occurred earlier in 2019 as well.

E. coli O157:H7 is typically associated with cattle. The first of the two outbreaks in 2018 was traced back to manure runoff from a CAFO in the vicinity of the lettuce farm, which polluted water that was used to irrigate the lettuce fields. CAFOs are a major source of water contamination throughout the U.S. As noted by the Arizona Department of Environmental Quality, “Nationwide and in Arizona, the potential for surface and ground water pollution exists through livestock facility discharge of manure-contaminated run off to natural waterways and through wastewater leaching to aquifers.”

Water and air pollution lead the list of concerns that have led to a number of state and local initiatives to institute moratoria on new and expanded CAFOs. Iowa, which has experienced an explosion of CAFOs, is the example these people want to avoid. In South Dakota, Lyle Reimnitz, who lives a half-mile from a Davison County hog farm with a permit for 8,000 sows, says, “I don’t want to see South Dakota become another Iowa,” he said. “We don’t need all our rivers and streams polluted. I know everybody wants cheap meat, but that comes at a terrible price for people who live here.”

In Wisconsin, supporters of a statewide moratorium on CAFOs are urging concerned citizens to ask County Supervisors, Town Board Members, and City Councillors to pass resolutions supporting a state-wide CAFO moratorium. In California, a report on dairy CAFOs found that “major production externalities are still imposed upon the communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large part to lack of resources, information, enforcement capability and political will on the part of local and regional regulatory agencies.” In Indiana, a report by the Indiana Business Research Center found, “For town residential properties, having the closest RLO [regulated livestock operation, or CAFO] upwind of the residence reduced the sale price by $4,980.00 and if the closest RLO contained dairy cattle, the sale price was further reduced by $32,340.00 for every 100 mature head.” In addition to these concerned citizens, the American Public Health Association has also called for a moratorium on CAFOs.

A majority of Americans say they want more stringent oversight of large-scale livestock operations, according to a national poll by Johns Hopkins University’s Center for a Livable Future released December 10, 2019.

Please cosponsor Senator Booker’s bill, the Farm System Reform Act, which would require that “corporate integrators” are “responsible for pollution and other harm caused by CAFOs” and phase them out by 2040.

Thank you.

 

01/02/2020 — The National Organic Program Must Defend Biodiversity

Beyond Pesticides

An unintended consequence of the National Organic Standards, the rules that govern certified organic agricultural production, actually provides an incentive for the conversion of critical ecosystems to organic cropland, fueling deforestation and biodiversity loss.

>> Tell the National Organic Program to issue regulations that will prevent the conversion of native ecosystems to organic cropland.

One National Organic Program (NOP) requirement for organic certification—a three-year waiting period during which land must be free of disallowed substances—encourages the conversion of critical ecosystems, which do not require the three-year waiting period.

Conversions of native landscapes to working organic land to date include losses of: a California forest, Colorado prairies, a New Mexico wetland, and native sagebrush lands in Washington and Oregon. The Wild Farm Alliance, which provides critical leadership on the issue, points out, “These areas, that were once delivering critical ecosystem services and providing essential habitat for wildlife, are no longer performing the same functions and [it] would take hundreds of years to reverse the damage.”

The National Organic Standards Board (NOSB), which is responsible for advising the U.S. Department of Agriculture (USDA) on implementation of the Organic Foods Production Act (OFPA), has been studying this problem since 2009, ultimately resulting in a 2018 recommendation. Beyond Pesticides commented on the proposal, “Despite efforts of organic farmers to build and protect biodiversity, it is unlikely that the organic farm will achieve the same level of biodiversity and ecological resilience as the original ecosystem. On the other hand, the conversion of conventional, chemical-intensive agriculture to organic agriculture provides huge benefits to biodiversity through both the absence of toxic inputs and positive measures to increase biodiversity in soil-based systems that are required by OFPA or its regulations. Therefore, Beyond Pesticides supports efforts by the NOSB to eliminate incentives to convert high-value native land to organic production, as well as to increase incentives to convert chemical-intensive farmland to organic production.”

In May 2018, the NOSB approved (nearly unanimously) the revised, formal Eliminating the Incentive to Convert Native Ecosystems to Organic Production recommendation. Typically, once the NOSB has made a recommendation, NOP puts it on the rulemaking agenda, develops a rule proposal on the basis of the recommendation, solicits public comment, and then develops a final rule. Yet, NOP has taken no action to bring the recommendation into its rulemaking process. Public pressure on USDA is needed to persuade NOP to “do its duty” and bring the NOSB recommendation forward to the rulemaking agenda.

>> Tell the National Organic Program to issue regulations that will prevent the conversion of native ecosystems to organic cropland.

Letter to USDA

I am very concerned about the failure of the National Organic Program to protect native ecosystems by implementing the NOSB recommendation “Eliminating the Incentive to Convert Native Ecosystems to Organic Production.”

Conversions of native landscapes to working organic land to date include losses of: a California forest, Colorado prairies, a New Mexico wetland, and native sagebrush lands in Washington and Oregon. The Wild Farm Alliance points out, “These areas, that were once delivering critical ecosystem services and providing essential habitat for wildlife, are no longer performing the same functions and [it] would take hundreds of years to reverse the damage.”

Despite efforts of organic farmers to build and protect biodiversity, it is unlikely that the organic farm will achieve the same level of biodiversity and ecological resilience as the original ecosystem. On the other hand, the conversion of conventional, chemical-intensive agriculture to organic agriculture provides huge benefits to biodiversity through both the absence of toxic inputs and positive measures to increase biodiversity in soil-based systems that are required by the Organic Foods Production Act and its regulations.

The NOSB recommended nearly unanimously that NOP should adopt regulations to define “native ecosystems” more specifically and require a 10-year waiting period before such land can be converted into organic cropland. With the crisis in loss of biodiversity that we are experiencing, it is important that organic producers lead the way in protecting the diversity of life.

Please initiate regulations eliminating incentives to convert native ecosystems to organic production as soon as possible.

Thank you.