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The California Department of Food and Agriculture (CDFA) has a draft plan that would give them authority to spray pesticides anywhere in California, with no input from communities affected, into the indefinite future. The Statewide Plant Pest Prevention and Management Programmatic Environmental Impact Report, or Pest PEIR, lists nearly 80 pesticides that include toxins that are hazardous to humans, pollinators, and aquatic life. This puts at risk infants, pregnant women, and other sensitive populations, drinking water sources, and organic farmers and farmworkers, who would not be able to stop spraying on crops. Comments on this plan are due TODAY, October 31, 2014.

The plan also does not include opportunities for public review before pesticides are applied, and allows the agency to approve new pesticides or expansion of its program with no environmental or health analysis. This means current and future Californians who may be concerned about their health and environment, have no process to prevent spraying or exposure to pesticides.

This mean this is Californians’ best chance to weigh in on their concerns about unknown, indefinite, future pesticide use is TODAY. We’ve included a sample comment email below, supplied by MOMS Advocating Sustainability, one of the organizations who has identified concerns with this plan, along with Earth Justice, Center for Biological Diversity, and Center for Environmental Health.

Sample Comment Letter
Put the following in the subject line of your email: “Comments on Statewide Plant Pest Prevention and Management Programmatic Environmental Impact Report”

Email to: PEIR.info@cdfa.ca.gov

Laura Petro, Senior Environmental Scientist
California Department of Food and Agriculture
1220 N Street, Suite 221
Sacramento CA 95814

Dear Ms. Petro:

I am writing to object to several elements of the Department of Food and Agriculture’s draft plant pest prevention and management programmatic environmental impact report, including:

• The pest prevention and management program continues the Department’s decades-old, pesticide-centered management practices. California should not continue to use a failed, toxic approach but should instead use the report as an opportunity to develop a truly modern, scientific, sustainable approach that will make California’s food supply more resilient to pests and protect human, pollinator, and farmworker health as well as our water and the environment.
• I am extremely concerned that the program relies on nearly 80 chemicals linked to cancer, birth defects, miscarriages reproductive harm, deaths of bees and other pollinators, etc., with more chemicals potentially approved in the future behind closed doors.
• The program gives the agency too much power to spray pesticides, without public input. The program allows the Department to carry out most program activities, and even approve certain changes and expansions of the pest program, without future public review or input. As a result, residents all over the state who today are unaware of how this proposed program might in the future result in pesticide or other treatments in their communities will have no recourse to affect or stop those future treatments.
• The report’s extremely broad scope is unacceptable, and the program poses potentially serious site-specific risks to health and the environment that have not been analyzed or disclosed in the vague and cursory health and environmental impact analysis in the document. For example, in the document:
  • Infants are assumed never to be exposed to pesticide drift.
  • Young children are assumed not to play in gardens where there is residue from spraying carried out under the program.
  • The effects of the program’s pesticides on pregnant women, the elderly, and those with chronic illness and multiple chemical sensitivity are not evaluated.
  • Endocrine-disrupting effects of program pesticide exposure are not evaluated.
  • The plan states that pesticide spraying can take place at or near schools, yet no analysis is performed of the effect of this spraying on schoolchildren.
  • No location-specific analysis is presented of the impacts of program pesticides on surface, ground, or drinking water.

This inadequate analysis is in direct conflict with the intent of the state’s environmental law, which is designed to analyze impacts before they happen so that they can be prevented and to inform the public of what those impacts will be.

I ask the Department to set aside this document as written and turn its attention to developing a program that focuses on pest prevention and does not rely on chemicals for pest management but instead supports a transition to farming methods that prevent pest infestations by building healthy soil and avoiding the use of pesticides that weaken plant and soil health; and that produce nutritious healthy food uncontaminated by toxic residues, thereby protecting the health of all Californians and of the environment, including bees and other sensitive species.

Sincerely,
YOUR NAME AND ADDRESS

[Photo by Don McCullough on Flickr]