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Action of the Week Archive

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.

04/12/2021 — Plan Now to Attend the National Pesticide Forum

Are you a regular National Pesticide Forum attendee? Have you always wanted to attend, but couldn’t afford the time and money? Are you new to the pesticide issue and want the best introduction, from Pesticides 101 to deep science? Do you want to meet with others who are taking their communities to natural organic land management? Do you want to meet with people doing amazing work across the country who are fighting the climate crisis, biodiversity collapse, and environmental injustice. This is your chance!

This year’s Forum is taking place virtually and will be held over four weeks, one day a week, May 25, June 1, 8, and 15. Plus, there’s a special pre-conference session Pesticide Literacy 101: Truth & Advertising on May 24. What’s more, we have registration options for all budgets.

Take Action: Sign-Up for the Forum and join with others across the country and around the world for a toxic-free future – confronting health threats, climate disasters, and biodiversity collapse. See you there!

What’s it all about? Scientific understanding. Collective action. Systemic change. A toxic-free future. Organic transition. The serious and existential environmental and health challenges that we face bring an urgency to the focus of this Forum and the work that is going on in communities around the U.S. and the world. Central to the solution is the elimination of petroleum-based pesticides and fertilizers in exchange for regenerative organic land management and nontoxic materials that stop the harm from toxic chemical production, use, and disposal. We recognize that this is the only way to protect our children and families, those in workplaces, pets, pollinators, and the rich diversity of organisms essential to life.

Who attends? The Forum brings together scientists, policymakers, practitioners, advocates, and activists to elevate with greater clarity the threats associated with environmental decline and collapse and the urgency with which we need to adopt solutions that are within our grasp. We hope you will participate! 

While we are celebrating Beyond Pesticides’ 40th anniversary this year, we still have much work to do and you are critical to the successful transition to organic solutions. That’s why we hope you will join us for this important conference! Please take a look at the Forum website, including the stellar list of confirmed speakers (more being added), for more details.

Thanks for being part of the network and for your continued support. We hope to “see” you in May. 

Take Action: Sign-Up for the Forum and join with others across the country and around the world for a toxic-free future – confronting health threats, climate disasters, and biodiversity collapse. See you there!

SPONSORSHIP OPPORTUNITIES! Showcase what you’re doing (as a nonprofit, volunteer, or business organization) through our “poster” or “exhibitor” opportunities. Take a look at our sponsorship packages, there’s a cost-effective option for all budgets. If you’d like to discuss a sponsorship, please call 202-543-5450 or send us an email

04/06/2021 — Ban Endocrine Disrupting Pesticides Now to Protect People and Wildlife

The failure of EPA to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine disrupting chemicals must end. Over recent decades, evidence has mounted showing that many pesticides interfere with hormones—and are therefore endocrine-disrupting chemicals (EDCs). In 1996, the promise of screening pesticides for endocrine disruption generated support from environmentalists and public health advocates for the Food Quality Protection Act (FQPA), which traded the absolute prohibition of carcinogens in food of the Delaney Clause for a risk assessment standard that is subject to manipulation and an underestimation of real-life hazards. And now, 25 years later, we have yet to see EPA use endocrine disruption findings in pesticide registration decisions.

>>Tell EPA that pesticide use cannot continue without findings of no endocrine disruption.

The endocrine system consists of a set of glands (thyroid, gonads, adrenal and pituitary) and the hormones they produce (thyroxine, estrogen, testosterone and adrenaline), which help guide the development, growth, reproduction, and behavior of animals, including humans. Hormones are signaling molecules, which travel through the bloodstream and elicit responses in other parts of the body. 

More than 50 pesticide active ingredients have been identified as endocrine disruptors by the European Union and the late endocrine disruptor expert Theo Colborn, PhD. Endocrine disruption is the mechanism for several health effect endpoints. Endocrine disruptors function by: (i) Mimicking the action of a naturally produced hormone, such as estrogen or testosterone, thereby setting off similar chemical reactions in the body; (ii) Blocking hormone receptors in cells, thereby preventing the action of normal hormones; or (iii) Affecting the synthesis, transport, metabolism, and excretion of hormones, thus altering the concentrations of natural hormones. Endocrine disruptors have been linked to attention deficit hyperactivity disorder (ADHD)Parkinson's and Alzheimer's diseasesdiabetes, cardiovascular disease, obesity, early puberty, infertility and other reproductive disorderschildhood and adult cancers, and other metabolic disorders. 

It is not only humans who are affected. Hermaphroditic frogs, polar bears with penis-like stumps, panthers with atrophied testicles and intersex fish with immature eggs in their testicles have all been linked to endocrine disruption. The popular herbicide atrazine chemically castrates and feminizes exposed male tadpoles. The mosquito-killing S-methoprene larvicide alters early frog embryo development. Distorted sex organ development and function in alligators is linked to the organochlorine insecticide dicofol. The ubiquitous antibacterial chemical triclosan alters thyroid function in frogs, while its chemical cousin triclocarban enhances sex hormones in rats and in human cells. In her book, Our Stolen Future, Dr. Colborn states that the decline of animal species can no longer be simply explained by habitat destruction and human disturbance, but also by reproductive failures within populations brought on by the influence of endocrine disrupting chemicals.

According to FQPA, the agency must screen all pesticide chemicals for potential endocrine activity. To ensure timely follow-through, EPA was given a timeline by Congress to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. It started a screening program (Tier 1) and reported results in 2009. Since, according to EPA, Tier 1 Screening (which looks at high exposure chemicals) is not sufficient to implicate a chemical as an endocrine disrupting chemical, but acts as a tool for defining which chemicals must undergo Tier 2 testing, the only stage that can influence regulatory decision-making. Indeed, it is unclear when or how EPA will move forward with Tier 2 testing, and how, if at all, any Tier 2 findings will be used to inform actual regulation.

EPA now issues Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption.

>>Demand that EPA test for and act on endocrine disruptors as required by law.

Letter to EPA Administator

I am writing to ask you to act now to meeting a statutory mandated to protect people and wildlife from dire health consequences.

In 1998, following a mandate in the Food Quality Protection Act (FQPA) of 1996, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 23 years, the Endocrine Disruptor Screening Program (EDSP), established to carry out the act, has made little progress in reviewing and regulating endocrine-disrupting pesticides.

To ensure timely follow-through, EPA was given a timeline by Congress to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. EPA has issued Proposed Interim Decisions (PIDs) on pesticide registrations making no human health or environmental safety findings associated with the potential for endocrine disruption, or identifying additional data needs to satisfy Endocrine Disruptor Screening Program requirements in the PIDs. EPA cannot make findings of no unreasonable adverse effects without findings concerning endocrine disruption. In the absence of such findings, EPA must cancel and suspend the registration of each pesticide lacking data or findings.

Please ensure that your agency meets its responsibility to protect the health of people and wildlife.

Thank you.

Letter to Congress

I am writing to ask you elevate a critical public and environmental health issue –the regulation of endocrine disrupting pesticides. The failure of EPA to meet its statutory responsibility to protect people and wildlife from the dire consequences of exposure to endocrine disrupting chemicals must end. For over a decade, EPA ignored the vast wealth of information on endocrine disruption from independent academic researchers funded by the U.S. and other governments in Europe and Asia. And, EPA has simply not carried out its statutory mandate to regulate endocrine disrupting pesticides.

Endocrine disruptors are linked to infertility and other reproductive disorders, diabetes, cardiovascular disease, obesity, and early puberty, as well as to attention deficit hyperactivity disorder (ADHD), Parkinson’s, Alzheimer’s, and childhood and adult cancers. This is a public health tragedy that cannot be ignored.

Since EPA announced it was ready to begin testing both active and “inert” (usually the majority of the undisclosed product ingredients that make the solution, dust, or granule) pesticide ingredients for potential endocrine disrupting effects in 2009, the protocols EPA proposed to use have become significantly outdated, having been first recommended in 1998. In the interim, science has progressed such that it offered more sophisticated assumptions than those that informed the EPA test designs. Further, as Beyond Pesticides noted in 2009, “Each of EPA’s tests and assays was designed under the surveillance of corporate lawyers who had bottom lines to protect, and assorted toxicologists who were not trained in endocrinology and developmental biology. For over a decade, EPA ignored the vast wealth of information on endocrine disruption from independent academic researchers funded by the U.S. and other governments in Europe and Asia.”

In 1998, following a mandate in the Food Quality Protection Act (FQPA) of 1996, EPA established a program to screen and test pesticides and other widespread chemical substances for endocrine disrupting effects. Despite operating for 21 years, the Endocrine Disruptor Screening Program (EDSP), established to carry out the act, has made little progress in reviewing and regulating endocrine-disrupting pesticides. As of 2019, the program has stalled entirely.

To ensure timely follow-through, EPA was given a timeline by Congress to: develop a peer-reviewed screening and testing plan with public input not later than two years after enactment (August 1998); implement screening and testing not later than three years after enactment (August 1999); and report to Congress on the findings of the screening and recommendations for additional testing and actions not later than four years after enactment (August 2000).

Despite these deadlines, EPA is stalled and ignoring its responsibility. That has real costs. Please use the power of your office to push EPA to meet its statutory responsibility to protect the health of people and wildlife.

Thank you.

03/29/2021 — Tell EPA and Congress to Save the Hummingbirds

...by Suspending Use of Neonicotinoid Insecticides and Supporting the Transition to Organic Practices

New data on the hazards of neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal.

>>Tell EPA and Congress to save the hummingbirds. 

While hovering, a hummingbird consumes calories faster than any other bird or mammal. That's why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar. 

Findings on the danger neonicotinoids pose to hummingbirds decades after the chemicals were first permitted to be used in the environment, and by independent scientists, not regulatory agencies, is indicative of a regulatory approach that fails to embrace precaution from the outset. Overwhelming data has already been established on the threat neonicotinoids pose to the health of ecosystems worldwide. The list of animals found to be adversely affected by neonicotinoids is extensive, ranging from humans and other mammals, to insect pollinators, songbirds, amphibians, and other aquatic species.

Of the 338 species of hummingbirds—all found in the Western hemisphere—34 are already endangered. We need to remove this threat to these amazing little birds by replacing chemical-intensive agriculture and horticulture with organic practices.

To help hummingbirds:

>>Tell EPA and Congress to save the hummingbirds by suspending use of neonicotinoid insecticides and supporting the transition to organic practices.

 

Letter to EPA Administrator

New data on the hazards of neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal.

While hovering, a hummingbird consumes calories faster than any other bird or mammal. That’s why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar.

The failure of EPA to act on Independent scientific findings on the danger that neonicotinoids pose to hummingbirds is indicative of clearly inadequate protection of ecosystems critical to our future. Overwhelming data has already been established on the threat neonicotinoids pose to the health of ecosystems worldwide. The list of animals found to be adversely affected by neonicotinoids is extensive, ranging from humans and other mammals, to insect pollinators, songbirds, amphibians, and other aquatic species.

Of the 338 species of hummingbirds—all found in the Western hemisphere—34 are already endangered. We need to remove this threat to these amazing little birds by supporting and incentivizing the transition from chemical-intensive agriculture and horticulture to organic practices.

Please address these threats to hummingbirds by suspending neonicotinoid insecticides. Eliminate pesticides that endanger pollinators and their habitat.

Thank you.

Letter to Congress

New data on neonicotinoid insecticides calls for urgent regulatory action. The same pesticides that are linked to the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Widely known for their nectar-fueled hovering flight powered by wings beating up to 80 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal.

While hovering, a hummingbird consumes calories faster than any other bird or mammal. That’s why the finding that exposure to the neonicotinoid insecticide imidacloprid slows metabolism up to 25% is so disturbing. Systemic pesticides like imidacloprid and other neonics are transported throughout the plant, including nectar.

The failure of EPA to act on Independent scientific findings on the danger that neonicotinoids pose to hummingbirds is indicative of clearly inadequate protection of ecosystems critical to our future. Overwhelming data has already been established on the threat neonicotinoids pose to the health of ecosystems worldwide. The list of animals found to be adversely affected by neonicotinoids is extensive, ranging from humans and other mammals, to insect pollinators, songbirds, amphibians, and other aquatic species.

Of the 338 species of hummingbirds—all found in the Western hemisphere—34 are already endangered. We need to remove this threat to these amazing little birds by supporting and incentivizing the transition from chemical-intensive agriculture and horticulture to organic practices.

Please ask EPA to address these threats to hummingbirds by suspending neonicotinoid insecticides. Eliminate pesticides that endanger pollinators and their habitat.

Thank you.

03/22/2021 — Tell the NOSB to Keep Antibiotics Out of Organic!

The National Organic Standards Board (NOSB) is receiving written comments from the public through April 5. This precedes the upcoming public hearing on April 20 and 22—concerning how organic food is produced. Also, by April 5, sign up to speak (3 minutes) at the virtual NOSB hearing. Written comments must be submitted through Regulations.gov.

As always, there are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2021 issues page.

Comment 1: The National Organic Standards Board (NOSB) is considering a petition to allow the antibiotic kasugamycin to be used in organic apple and pear production. Earlier NOSB members struggled long and hard to erase the stigma of antibiotic use in organic fruit production—something that was left over from the transition of so many chemical-intensive fruit orchards after the Alar “scare” in which apple and apple products were contaminated with the cancer-causing plant growth regulator daminozide. Do we now want to step on that treadmill again? The reasons for rejecting the kasugamycin petition are the same as the reasons for eliminating the antibiotics streptomycin and tetracycline in crop production.

Now that we have learned what a pandemic looks and feels like, with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon—this one tied to bacterial resistance to antibiotics. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”

When streptomycin and tetracycline were presented for their final votes by the Crops Subcommittee, the committee was unanimous that the antibiotics needed to go—the question was how fast. How fast could growers of these crops get over their dependence on these antibiotics that pose threats to human health and the environment and are unpopular with organic consumers? Streptomycin and tetracycline are gone, and we do not need another antibiotic.

Tell the NOSB to keep organic strong and keep antibiotics out of organic.

As always, the NOSB is considering many issues that affect the integrity of organic products. Other important issues are the use of ion exchange technology in processing organic food and the use of so-called “biodegradable biobased mulch film.”

Comment 2: Biodegradable Biobased Mulch Film (BBMF) was approved by the NOSB for use in organic production in October 2012, and the listing was finalized September 30, 2014 as “Biodegradable biobased mulch film as defined in §205.2. Must be produced without organisms or feedstock derived from excluded methods.” The definition required that BBMF meet specific requirements for compostability, biodegradation, and biobased content. Subsequently, the Organic Material Research Institute (OMRI) found that there are no products meeting all of the requirements set by the board. The NOSB is now considering a proposal to change the definition to allow BBMF that is not 100% biobased. BBMF is not removed from the field by the grower, but is tilled into the soil. The tillage process purposefully creates microplastics, with the intention that the action of soil organisms will degrade these small particles. However, as reported in OMRI’s 2016 Supplemental Technical Review, many growers report that fragments persist in the soil. OMRI reports research showing that the BBMFs do not completely degrade and may degrade more slowly when tilled under the surface, that they contain components that may be hazardous, and particles may adsorb persistent toxins. Microplastics may be incorporated into plant and animal tissues. Organic mulches have always been a central aspect of organic production, and reliance on synthetic mulches for functions that can be performed by organic mulch is not compatible with organic production. The NOSB should not redefine BBMF in a way that encourages microplastic contamination of the soil.

Comment 3: Ion exchange is a reaction in which an element from the treated substance is removed and replaced by a different element. Although the most familiar example of ion exchange is water softening, in which the “hard” minerals calcium and magnesium are replaced with sodium, the technology is widely used in food processing. Food processors run liquids, such as sugar cane juice, through a column of plastic beads charged with a substance that replaces an undesirable substance in the liquid with a different chemical. Ion exchange produces a chemical change in the food, which can subsequently only be regarded as synthetic under organic rules—and, therefore, be limited to less than 5% in food labeled “organic.” Products treated with ion exchange must be treated as synthetic substances. Resins and recharge chemicals must be on the product label.

Submit comments now.

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the three comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)

Thank you for keeping organic strong!

03/16/2021 — Tell FDA and USDA to Get Heavy Metals Out of Baby Food

staff report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives has documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods. The researchers examined organic as well as nonorganic brands, finding contamination of both. They found that heavy metals were present in both crop-based ingredients and additives. However, many unknowns remain regarding the precise origin of the metals.

Two U.S. Senators (Amy Klobuchar, D-MN and Tammy Duckworth, D-IL) and two U.S. Representatives (Raja Krishnamoorthi, D-IL and Tony Cardenas, D-CA) have drafted legislation to strengthen regulations for infant food safety, but meanwhile want the Food and Drug Administration (FDA) to use existing authority to take immediate action. The National Organic Program should also take action to ensure that parents can depend on organic baby food to be the best possible.

>>TAKE ACTION: Tell FDA and USDA to get heavy metals out of baby food!

Heavy metals can have serious health impacts, especially on young children. As stated in the report: 

  • Children's exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk of future criminal and antisocial behavior.​​​​​

  • Babies' developing brains are “exceptionally sensitive to injury caused by toxic chemicals, and several developmental processes have been shown to be highly vulnerable to chemical toxicity.” The fact that babies are small, have other developing organ systems, and absorb more of the heavy metals than adults, exacerbates their risk from exposure to heavy metals. 

  • Exposure to heavy metals at this developmental stage can lead to “untreatable and frequently permanent” brain damage, which may result in “reduced intelligence, as expressed in terms of lost IQ points, or disruption in behavior.” For example, a recent study estimates that exposure to environmental chemicals, including lead, are associated with 40,131,518 total IQ points loss in 25.5 million children (or roughly 1.57 lost IQ points per child)—more than thetotal IQ losses associated with preterm birth (34,031,025), brain tumors (37,288), and traumatic brain injury (5,827,300) combined. For every single IQ point lost, it is estimated that a child's lifetime earning capacity will be decreased by $18,000.

Because heavy metal contamination occurs in organic as well as nonorganic baby foods and in food ingredients as well as additives such as vitamin mixtures, it is important to discover the sources from which heavy metals enter the food. Some sources are known—it is known that some vitamin mixes are contaminated. It is known that rice—especially brown rice—contains arsenic as a result of historical use of arsenic pesticides and the fact that rice concentrates arsenic. Other sources are more speculative, but there are three main possible sources—pesticide residues in agricultural products, food contact with processing machinery and containers, and food additives. Growing food organically eliminates additions to the heavy metal burden of soils but does not eliminate existing residues in the soil and environment generally. Organic processing standards must be strengthened to address problems associated with food contact contaminants and contaminated additives. While background levels and action levels set by FDA standards are one measure, under the Organic Foods Production Act, the National Organic Standards Board must set its own standards for contaminants of added substances in organic food production and processing, taking into account background levels in the environment.

After decades of polluting practices in agricultural production under risk assessment standards that allowed contamination at “acceptable levels,” we have a legacy problem with background contamination of farmland. As a result, manufacturers of processed food may not be able to source ingredients without these unacceptable contaminants. Therefore, we need to first define the scope of the problem and then consider remediation measures that may be needed on the agricultural land used to grow crops that are ingredients in baby food and the food supply generally. 

With the problem fully defined, we can launch a national clean-up program—from farmers to processors and packagers—to eliminate the contamination from the food supply. As a part of this national program, FDA must set strict regulations on heavy metal concentrations in finished products. As a goal, Consumer Reports (CR) has suggested that FDA:

Establish aggressive targets: Set a goal of having no measurable amounts of cadmium, inorganic arsenic, or lead in baby and children's food.

Create and enforce benchmarks: To reach its goals in baby and children's food, FDA should set incremental targets for industry to meet along the way.

Finalize existing proposed guidelines: FDA should limit inorganic arsenic in apple juice to 10 ppb and revise existing guidance for lead in fruit juice to reduce the limit from 50 to 5 ppb.

>>TAKE ACTION: Tell FDA and USDA to get heavy metals out of baby food!

Letter to FDA

A staff report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives has documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods. The researchers examined organic as well as nonorganic brands, finding contamination of both. They found that heavy metals were present in both crop-based ingredients and additives. However, many unknowns remain regarding the precise origin of the metals.

Heavy metals can have serious health impacts, especially on young children. As stated in the report,

- Children’s exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk of future criminal and antisocial behavior.

- Babies’ developing brains are “exceptionally sensitive to injury caused by toxic chemicals, and several developmental processes have been shown to be highly vulnerable to chemical toxicity.” The fact that babies are small, have other developing organ systems, and absorb more of the heavy metals than adults, exacerbates their risk from exposure to heavy metals.

- Exposure to heavy metals at this developmental stage can lead to “untreatable and frequently permanent” brain damage, which may result in “reduced intelligence, as expressed in terms of lost IQ points, or disruption in behavior.” For example, a recent study estimates that exposure to environmental chemicals, including lead, are associated with 40,131,518 total IQ points loss in 25.5 million children (or roughly 1.57 lost IQ points per child)—more than the total IQ losses associated with preterm birth (34,031,025), brain tumors (37,288), and traumatic brain injury (5,827,300) combined. For every one IQ point lost, it is estimated that a child’s lifetime earning capacity will be decreased by $18,000.

Because heavy metal contamination occurs in organic as well as nonorganic baby foods and in food ingredients as well as additives such as vitamin mixtures, it is important to discover the sources from which heavy metals enter the food. Some sources are known—it is known that some vitamin mixes are contaminated. It is known that rice—especially brown rice—contains arsenic as a result of historical use of arsenic pesticides and the fact that rice concentrates arsenic. Other sources are more speculative, but there are three main possible sources—pesticide residues in agricultural products, food contact with processing machinery and containers, and food additives. Growing food organically eliminates additions to the heavy metal burden of soils but does not eliminate existing residues. Organic processing standards have not yet caught up with the problems of food contact contaminants and contaminated additives and rely to some extent on FDA standards.

It is important to motivate those involved in baby food manufacture—from farmers to processors and packagers—to eliminate known sources of contamination. This can be accomplished with strict FDA regulations on heavy metal concentrations in finished products. I urge you to take these steps to protect children from hazardous heavy metals:

1) Establish aggressive targets: Set a goal of having no measurable amounts of cadmium, inorganic arsenic, or lead in baby and children’s food.
2) Create and enforce benchmarks: To reach its goals in baby and children’s food, FDA should insist that manufacturers follow recognized best practices and set incremental targets for industry to meet along the way.
3) Finalize existing proposed guidelines: FDA should limit inorganic arsenic in apple juice to 10 ppb and revise existing guidance for lead in fruit juice to reduce the limit from 50 to 5 ppb.

Thank you for your consideration.

Letter to USDA

I am writing because I am concerned about the report produced for the Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform of the U.S. House of Representatives that documented substantial levels of the heavy metals arsenic, lead, cadmium, and mercury in infant foods, including organic products. Heavy metals can have serious health impacts, especially on young children. As stated in the report,

- Children’s exposure to toxic heavy metals causes permanent decreases in IQ, diminished future economic productivity, and increased risk of future criminal and antisocial behavior.

- Babies’ developing brains are “exceptionally sensitive to injury caused by toxic chemicals, and several developmental processes have been shown to be highly vulnerable to chemical toxicity.” The fact that babies are small, have other developing organ systems, and absorb more of the heavy metals than adults, exacerbates their risk from exposure to heavy metals.

- Exposure to heavy metals at this developmental stage can lead to “untreatable and frequently permanent” brain damage, which may result in “reduced intelligence, as expressed in terms of lost IQ points, or disruption in behavior.” For example, a recent study estimates that exposure to environmental chemicals, including lead, are associated with 40,131,518 total IQ points loss in 25.5 million children (or roughly 1.57 lost IQ points per child)—more than the total IQ losses associated with preterm birth (34,031,025), brain tumors (37,288), and traumatic brain injury (5,827,300) combined. For every one IQ point lost, it is estimated that a child’s lifetime earning capacity will be decreased by $18,000.

The heavy metal contamination occurs regardless of organic production and processing methods. Organic standards are based on practices rather than purity, but consumers do expect that organic foods will be free of hazardous contaminants. Therefore, regardless of actions that may be taken by Congress or the Food and Drug Administration (FDA) affecting foods in general or baby foods in general, the National Organic Program (NOP) should, to the extent possible, ensure that organic food, especially infant food, is free from heavy metal contamination.

To this end, NOP must work with the National Organic Standards Board to eliminate, as much as possible heavy metal contamination arising from:

1. Organic crop and livestock production practices and the land;
2. National List ingredients;
3. Processing and handling processes; and
4. Packaging materials.

Thank you for your consideration.

03/05/2021 — Tell EPA to Stop the Sale of Deadly Seresto Flea Collars

In the face of 1,700 pet deaths linked to Seresto's flea and tick collar—as reported March 2, 2021, by USA Today, based on EPA records—EPA has taken no action. This unconscionable inaction is defended by an EPA spokesperson who told the media that, despite these incidents, the agency has deemed Seresto collars “'eligible for continued registration' based on best available science, including incident data....No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Seresto is developed by Bayer and sold by Elanco.

>>Tell EPA and Members of Congress to take responsible and immediate action to stop the death of dogs and cats by stopping the sale of Seresto flea collars. 

Beyond Pesticides is calling on EPA to recognize, finally, that the label on flea collars is not adequately protective, as evidenced by the number of deaths and 75,000 incidents. “EPA has the authority to act now, and it should use its powers to protect the health and lives of pets,” said Jay Feldman, executive director of Beyond Pesticides. “EPA should act on the deaths immediately, not wait for further study, just as it did with the herbicide Imprelis when trees were killed after the product's use.” said Mr. Feldman. In 2011, EPA issued an order to E.I. DuPont de Nemours (DuPont) directing the company to immediately cease the distribution, sale, use or removal of Imprelis Herbicide products under its ownership, control, or custody. The agency found that, “The directions for use and/or warning or caution statements on DuPont's Imprelis labeling are inadequate.”

USA Today reports, “A 2012 Bayer study found [flumethrin and imidacloprid] have a 'synergistic effect,' meaning they are more toxic together on fleas....“ However, a 2016 EPA bulletin concluded, “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.” This failure to evaluate synergistic effects of pesticides is standard practice of EPA. As Beyond Pesticides has pointed out repeatedly, EPA does not do an adequate job of evaluating the risks and harms of exposures to multiple pesticide compounds, as well as those of so-called  “inert” or “other” pesticide ingredients.

The Seresto flea collar is meant to stay on dogs or cats for months at a time to kill fleas and ticks. Apart from deaths, pets suffer from rashes, seizures, motor dysfunction, fatigue, diarrhea, vomiting, and excessive drooling. The product label on the collar specifically states that it is for external use only; but that direction does not account for the fact that dogs and cats clean themselves (by licking their fur) frequently, and can ingest the collar's pesticides because it is designed to release and disperse them onto fur and skin steadily over the course of months.

The same concern is true for children's exposure to the chemical residues on their pets and their direct contact with the flea collar. EPA's 2016 bulletin includes the label warning: “DO NOT LET CHILDREN PLAY WITH THIS COLLAR OR REFLECTORS; KEEP OUT OF REACH OF CHILDREN.” The bulletin further states, “Flumethrin exposures to people placing collars on pets, and to adults and children interacting with pets (including incidental ingestion because of children's hand-to-mouth activities), are below levels of concern. The assessment of imidacloprid identified no risks to humans placing the collars on pets or interacting with pets wearing the collars.” And it reiterates, “As stated in the precautions on the label, do not allow children to play with the collars. In addition, try to keep the pet away from young children for a day after putting on the collar to minimize exposure.” EPA's use of ALL CAPS and repeated warnings about children suggests a high level of agency concern.

EPA has logged these “Seresto” incidents in its database for years but has not seen fit to warn the public. Karen McCormack, a retired EPA scientist and communications officer, notes that these collars have garnered the greatest number of incident reports of any pesticide product in her long experience. She says, “EPA appears to be turning a blind eye to this problem, and after seven years of an increasing number of incidents, they are telling the public that they are continuing to monitor the situation. But I think this is a significant problem that needs to be addressed sooner rather than later.”

>>Tell EPA and Members of Congress to take responsible and immediate action to stop the death of dogs and cats by stopping the sale of Seresto flea collars.

Letter to EPA and Congress

In the face of 1,700 pet deaths linked to Seresto’s flea and tick collar—as reported March 2, 2021 by USA Today, based on EPA records—EPA has taken no action. This unconscionable inaction is defended by an EPA spokesperson who told the media that, despite these incidents, the agency has deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data. . . . No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.” Seresto is developed by Bayer and sold by Elanco.

I am calling on EPA to recognize, finally, that the label on flea collars is not adequately protective, as evidenced by the number of deaths and 75,000 incidents. EPA has the authority to act now, and it should use its powers to protect the health and lives of pets by stopping the sale of Seresto flea collars. EPA should act on the deaths immediately, not wait for further study—just as it did with the herbicide Imprelis (2011) by issuing an order to E.I. DuPont de Nemours (DuPont) directing the company to immediately cease the distribution, sale, use or removal. In that case, EPA said, “The directions for use and/or warning or caution statements on DuPont's Imprelis labeling are inadequate [to prevent the death of trees]”.

USA Today reports, “A 2012 Bayer study found [flumethrin and imidacloprid] have a ‘synergistic effect,’ meaning they are more toxic together on fleas. . . “ However, a 2016 EPA bulletin concluded, “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.” This failure to evaluate synergistic effects of pesticides is standard practice of EPA. The agency does an inadequate job of evaluating the risks and harms of exposures to multiple pesticide compounds, as well as those of so-called “inert” or “other” pesticide ingredients.

The Seresto flea collar is meant to kill fleas and ticks, while on dogs or cats for months at a time. Apart from deaths, pets suffer rashes, seizures, motor dysfunction, fatigue, diarrhea, vomiting, and excessive drooling. Although the product label on the collar specifically states that it is for external use only, it fails to account for grooming behavior of dogs and cats through which the pet can ingest the pesticides that the collar releases and disperses onto fur and skin steadily over the course of months.

The same concern is true for children’s exposure to the chemical residues on their pets and their direct contact with the flea collar. The collar’s label warns: “DO NOT LET CHILDREN PLAY WITH THIS COLLAR OR REFLECTORS; KEEP OUT OF REACH OF CHILDREN.” Although EPA acknowledges synergistic effects on fleas and ticks, the agency finds separate risks of flumethrin and imidacloprid to be below levels of concern and did not assess their combined risk.

EPA has logged “Seresto” incidents in its database for years, but has not seen fit to warn the public. Karen McCormack, a retired EPA scientist and communications officer, notes that these collars have garnered the greatest number of incident reports of any pesticide product in her long experience. She says, “EPA appears to be turning a blind eye to this problem, and after seven years of an increasing number of incidents, they are telling the public that they are continuing to monitor the situation. But I think this is a significant problem that needs to be addressed sooner rather than later.”

Thank you for your urgent consideration.

03/01/2021 — Support National Reckoning to Bridge Racial Divides with Meaningful Actions

The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” Black, Indigenous, and other people of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership. With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. This discussion has taken on greater general public understanding since the killing of George Floyd, as there is more national awareness of systemic racial injustice and the deep adverse impact that it has on all aspects of life. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership. 

>>Tell your U.S. Senators and U.S. Representative to support increased equity for Black, Indigenous, and other people of color in farming.

Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. The three pieces of legislation in this action relate to disenfranchisement of African Americans and other people of color as the struggle continues for Native American and tribal rights to land taken from them by the U.S. government. There are several bills in Congress, which are not included in this action, to put certain lands into trust or transfer land for the benefit of various Native American tribes.

The undermining of land ownership in the Black community has not been widely recognized by the general public. In 1910, one in seven farmers were African Americans, who held titles to approximately 16 to 19 million acres of farmland. Over the next century, 98% of Black farmers were dispossessed through discriminatory practices at the U.S. Department of Agriculture (USDA) and various federal programs.

The current existential threats arise from continued policies of colonization, including “resource extraction,” “economic development,” and agriculture. But large-scale logging, mining, petroleum extraction, and dispersal of poisons is opposed by efforts to restore lands and waters to Indigenous guardianship and/or Indigenous stewardship—to begin the process of reparations, healing, and recovery. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land." Land-care practices based on specific land-based cultural practices are as diverse as the more than 500 tribal nations of Turtle Island.

Two bills have been introduced in the Senate (but do not have numbers as of this writing) aimed at boosting the growing push for equity and diversity within food and agriculture policy and politics. Sen. Cory Booker (D-N.J.) reintroduced the Justice for Black Farmers Act to address a history of USDA discrimination and injustice to Black farmers. Sen. Raphael Warnock (D-Ga.) introduced the Emergency Relief for Farmers of Color Act that would provide $5 billion to farmers of color. Sen. Warnock said he is urging that the bill be included in the $1.9 trillion pandemic relief package moving through Congress.

The Justice for Black Farmers Act will fund agriculture programs at historically Black colleges and universities and create new training programs for new farmers of color. It will also create a civil rights oversight board at USDA to investigate reports of discrimination both within the department and its Farm Service Agency county committees. Most notably, the bill includes a provision that would provide up to 160 acres to existing and aspiring Black farmers and provides debt forgiveness for those who filed claims under the landmark 1999 Pigford v. Glickman class action discrimination suit that Black farmers filed against USDA.

Sen. Warnock's bill provides $5 billion to Black, Indigenous, Hispanic and other farmers of color, including $4 billion in direct relief payments to help farmers of color pay outstanding USDA farm loan debts and related taxes, and help them respond to the economic impacts of the pandemic; and $1 billion to support activities at USDA to "root out systemic racism, provide technical and legal assistance to agricultural communities of color and fund under-resourced programs that will shape the future for farmers and communities of color." 

Missing from this package is a provision to return land to Indigenous nations. The authors of these bills should include provisions that return ownership of public and trust lands to the tribes from whom they were taken. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

And, on the issue of reparations, H.R.40, Commission to Study 5 and Develop Reparation Proposals for African Americans Act, was introduced by Rep. Sheila Jackson Lee (D-TX) and 116 co-sponsors. The legislation, which the ACLU has called “restorative justice,” had been introduced by Rep. John Conyers (D-MI) for three decades. According to Rep. Jackson Lee, “Though many thought it a lost cause, he believed that a day would come when our nation would need to account for the brutal mistreatment of African Americans during chattel slavery, Jim Crow segregation, and the enduring structural racism endemic to our society.” The bill is H.R. 40 for a reason: “The designation of this legislation as H.R. 40 is intended to memorialize the promise made by Gen. William T. Sherman, in his 1865 Special Field Order No. 15, to redistribute 400,000 acres of formerly Confederate-owned coastal land in South Carolina and Florida, subdivided into 40-acre plots.” With broad support in Congress and the private sector, Rep. Jackson Lee said, “By passing H.R. 40, Congress can start a movement toward the national reckoning we need to bridge racial divides. Reparations are ultimately about respect and reconciliation — and the hope that one day, all Americans can walk together toward a more just future. The bill establishes a Commission to Study and Develop Reparation Proposals for African Americans to research the issues involved and make reparation recommendations.

>>Tell your U.S. Senators and U.S. Representative to support for increased equity for Black, Indigenous, and other people of color in farming.

Letter to U.S. Representatives

I am writing to ask your support for increased equity for Black, Indigenous, and other people of color in farming. The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” Black, Indigenous, and other people of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership. With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership.

H.R.40, Commission to Study 5 and Develop Reparation Proposals for African Americans Act, was introduced by Rep. Sheila Jackson Lee (D-TX) and 116 co-sponsors. The legislation, which the ACLU has called “restorative justice,” had been introduced by Rep. John Conyers (D-MI) for three decades. According to Rep. Jackson Lee, “Though many thought it a lost cause, he believed that a day would come when our nation would need to account for the brutal mistreatment of African Americans during chattel slavery, Jim Crow segregation, and the enduring structural racism endemic to our society.” The bill is H.R. 40 for a reason: “The designation of this legislation as H.R. 40 is intended to memorialize the promise made by Gen. William T. Sherman, in his 1865 Special Field Order No. 15, to redistribute 400,000 acres of formerly Confederate-owned coastal land in South Carolina and Florida, subdivided into 40-acre plots.” With broad support in Congress and the private sector, Rep. Jackson Lee said, “By passing H.R. 40, Congress can start a movement toward the national reckoning we need to bridge racial divides. Reparations are ultimately about respect and reconciliation — and the hope that one day, all Americans can walk together toward a more just future. The bill establishes a Commission to Study and Develop Reparation Proposals for African Americans to research the issues involved and make reparation recommendations.

Missing from this bill is a provision to return land to Indigenous nations. We also need provisions that return ownership of public and trust lands to the tribes from whom they were taken. Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

Thank you for your support.

Letter to U.S. Senators

I am writing to ask your support for increased equity for Black, Indigenous, and other people of color in farming. To that end, I ask you to co-sponsor two bills (which have been introduced but do not have numbers as of this writing) in the Senate aimed at boosting the growing push for equity and diversity within food and agriculture policy and politics. Sen. Cory Booker (D-N.J.) reintroduced the Justice for Black Farmers Act to address a history of USDA discrimination and injustice to Black farmers. Sen. Raphael Warnock (D-Ga.) introduced the Emergency Relief for Farmers of Color Act that would provide $5 billion to farmers of color. Sen. Warnock said he is urging that the bill be included in the $1.9 trillion pandemic relief package moving through Congress.

The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” Black, Indigenous and other people of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership.
With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership.

Two pieces of legislation relate to disenfranchisement of African Americans as the struggle continues for Native American and tribal rights to land taken from them by the U.S. government. There are several additional bills in Congress to put certain lands into trust or transfer land for the benefit of various Native American tribes.

The undermining of land ownership in the Black community has not be widely recognized by the general public. In 1910, one in seven farmers were African Americans, and African Americans held titles to approximately 16 to 19 million acres of farmland. Over the next century, 98% of Black farmers were dispossessed through discriminatory practices at the U.S. Department of Agriculture (USDA) and various federal programs.

Missing from this package is a provision to return land to Indigenous nations. The authors of these bills should include provisions that return ownership of public and trust lands to the tribes from whom they were taken. Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

Thank you for your support.

Thank You Letters to Senators Booker and Warnock

I am writing to thank you for your support for increased equity for Black, Indigenous, and other people of color in farming. To that end, I support your leadership on two bills aimed at boosting the growing push for equity and diversity within food and agriculture policy and politics—Black Farmers Act to address a history of USDA discrimination and injustice to Black farmers, and the Emergency Relief for Farmers of Color Act that would provide $5 billion to farmers of color.

The greatest impediment to entering organic farming is access to land. Since organic farming requires a long-term commitment to avoiding prohibited substances, building soil, and conserving biodiversity, it is difficult to manage on rented land or land farmed on “shares.” People of color are especially disadvantaged because of institutionalized racism embodied in U.S. policies, which has either prevented access or has undermined land ownership. With deep reflection into the injustice associated with past policies, from pioneers to slaveholders, members of Congress are elevating the national discussion of policy changes and reparations to address a past of racial injustice. One of those institutional effects to Indigenous, Black, and other people of color is the taking away or denying access to land ownership.

I appreciate that these two pieces of legislation relate to disenfranchisement of African Americans as the struggle continues for Native American and tribal rights to land taken from them by the U.S. government. There are several additional bills in Congress to put certain lands into trust or transfer land for the benefit of various Native American tribes.

The undermining of land ownership in the Black community has been subtle and hidden from the general public. In 1910, one in seven farmers were African Americans, and African Americans held titles to approximately 16 to 19 million acres of farmland. Over the next century, 98% of Black farmers were dispossessed through discriminatory practices at the U.S. Department of Agriculture (USDA) and various federal programs.

Missing from this package is a provision to return land to Indigenous nations. I urge that these bills include provisions that return ownership of public and trust lands to the tribes from whom they were taken. Holistic systemic change is needed to restore relationships between members of society and with the Earth. The greatest source of wisdom about living sustainably (with decisions based on their impacts on seven generations to come) on this continent—Turtle Island (as named by some Native Americans and First Nations People)—has been all but eradicated through past policies of land theft and genocide. From the birth of our country to today, the United States government seized 1.5 billion acres of native land. The loss of tribal lands and mixed ownership patterns within reservation boundaries pose serious challenges to the sovereignty and self-determination of Native American nations. As the Anishinaabe activist and author Winona LaDuke says, "The only compensation for land is land."

Thank you for your leadership.

02/22/2021 — Help Get Congress to Support National Biodiversity Strategy Legislation

Congressional Rep. Joe Neguse, Rep. Alan Lowenthal and Chair of the Natural Resources Subcommittee on Water, Oceans and Wildlife Rep. Jared Huffman have reintroduced their resolution (H.Res. 69: Expressing the need for the federal government to establish a national biodiversity strategy for protecting biodiversity for current and future) to create a national biodiversity strategy. Everywhere we turn, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. Never was a holistic strategy on biodiversity more urgent. 

>>Tell your U.S. Representative to cosponsor Rep. Neguse's National Biodiversity Strategy Resolution, H.Res. 69.

The resolution calls for a national commitment to addressing the biodiversity crisis by establishing a strategy to be developed through an interagency process announced by the president in an Executive Order. The strategy process will encourage agencies to identify and pursue a full range of actions within existing laws and policies and encourage consideration of new ones. It would also promote accountability and progress in addressing the biodiversity crisis through a new quadrennial assessment.

“The decline of biodiversity presents a direct threat to the security, health and well-being of our communities and our planet. Human-caused activity has led to the damage of ecosystems, the exploitation of wildlife, increased pollution and the acceleration of climate change,” said Representative Joe Neguse. “It is our hope that the Biden Administration would use our resolution as a roadmap for establishing a robust, whole-of-government approach to protect our ecosystems, our wildlife and tackle the biodiversity crisis. The United States ought to be playing a global leadership role on these issues.”

The resolution lays out a holistic national biodiversity strategy, including: 

  • Setting a national goal of protecting at least 30% of United States lands and water to conserve biodiversity and address climate change by 2030; 
  • Affirming the need to protect threatened, endangered, and at-risk species from further extinction; 
  • Developing climate adaptation and mitigation strategies for biodiversity; 
  • Joining and leading international agreements to combat climate change, such as the Paris Agreement
  • Establishing climate corridors for conservation of species affected by climate change; 
  • Rapidly building renewable energy; 
  • Reviewing existing laws and programs that are relevant to addressing threats of biodiversity; 
  • Advancing conservation in coordination with State and Tribal governments; 
  • Incorporating indigenous knowledge; 
  • Providing means to ensure equitable access to nature; and 

Establishing regular monitoring, reporting, research and development and adequate funding for conservation efforts. 

>>Tell your U.S. Representative to cosponsor Rep. Neguse's National Biodiversity Strategy Resolution, H.Res. 69.

Letter to Congress

I am writing to urge your support for H.Res. 69: Expressing the need for the federal government to establish a national biodiversity strategy for protecting biodiversity for current and future, reintroduced by Rep. Joe Neguse, Rep. Alan Lowenthal and Chair of the Natural Resources Subcommittee on Water, Oceans and Wildlife Jared Huffman. Everywhere we turn, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. Never was a holistic strategy on biodiversity more urgent.

The resolution calls for a national commitment to addressing the biodiversity crisis by establishing a strategy to be developed through an interagency process announced by the president in an Executive Order. The strategy process will encourage agencies to identify and pursue a full range of actions within existing laws and policies and encourage consideration of new ones. It would also promote accountability and progress in addressing the biodiversity crisis through a new quadrennial assessment.

“The decline of biodiversity presents a direct threat to the security, health and well-being of our communities and our planet. Human-caused activity has led to the damage of ecosystems, the exploitation of wildlife, increased pollution and the acceleration of climate change,” said Congressman Joe Neguse. “It is our hope that the Biden Administration would use our resolution as a roadmap for establishing a robust, whole-of-government approach to protect our ecosystems, our wildlife and tackle the biodiversity crisis. The United States ought to be playing a global leadership role on these issues.”

The resolution lays out a holistic national biodiversity strategy, including:

- Setting a national goal of protecting at least 30% of United States lands and water to conserve biodiversity and address climate change by 2030;
- Affirming the need to protect threatened, endangered, and at-risk species from further extinction;
- Developing climate adaptation and mitigation strategies for biodiversity;
-Joining and leading international agreements to combat climate change, such as the Paris Agreement;
- Establishing climate corridors for conservation of species affected by climate change;
- Rapidly building renewable energy capacity;
- Reviewing existing laws and programs that are relevant to addressing threats of biodiversity;
- Advancing conservation in coordination with State and Tribal governments;
- Incorporating indigenous knowledge;
- Providing means to ensure equitable access to nature; and
- Establishing regular monitoring, reporting, research and development and adequate funding for conservation efforts.

Please cosponsor H.Res. 69, Rep. Neguse’s national biodiversity strategy resolution.

Thank you.

02/16/2021 — Shift to Organic Farming, Not Carbon Trading, Is Critical to Thwart the Climate Crisis and Biodiversity Collapse

The climate crisis, with unprecedented temperature shifts, storms, and wildfires, and the devastating decline in biodiversity are escalating as a result of uncontrolled and unnecessary reliance on toxic chemicals. These existential crises that threaten life, to be successfully thwarted, require a meaningful holistic strategy that commits our nation to ending our fossil fuel-based economy and use of petroleum-based materials that release harmful levels of carbon and noxious gases (including greenhouse gases/GHG) into the environment. The proposals now in Congress and the administration require close attention and scrutiny if we are to meet the urgency of the moment.

The carbon market approach embodied in the Growing Climate Solutions Act and President Biden's Climate 21 Project does not adequately and comprehensively respond to the current and looming interconnected threats to public health and the environment. The focus on carbon to the exclusion of a holistic approach that addresses complex life-supporting biological communities allows the continuation of disproportionate hazards to people of color and communities living adjacent to toxic sites. The mechanisms of carbon trading or the purchasing of carbon offsets under consideration do not establish an end date for admittedly unacceptable materials and practices, nor do they ensure a transition to life-sustaining practices. Just as there are proposals to end production of the combustion engine and move to electric vehicles, we must demand that agriculture—across the board and on an expedited five-year schedule—shift to organic practices, whose standards are already codified in federal law. Organic production and handling practices have a proven, commercially viable, track record and both sequester carbon and eliminate petroleum-based pesticides and synthetic fertilizers. And, importantly, the data shows that this sector of agriculture is now operating without sacrificing productivity or profitability. The only problem: the vested economic interests in the petroleum and chemical industry are holding on to the status-quo. The good news: there are good jobs and money to be made in a green economy.

>>Tell your Congressional Representatives and Senators to support a holistic approach to the existential threats of the climate crisis and biodiversity collapse.

Carbon trading schemes won't work because:

In addition,

Why we need a national plan to shift to 100% organic farming. Organic land management is more effective at reducing emissions and increasing carbon sequestration. Organic farming practices have been shown to sequester carbon in the soil. There is in place a national program for certifying farms that meet organic standards. In addition, organic operations are required to “comprehensively conserve biodiversity by maintaining or improving all natural resources, including soil, water, wetlands, woodlands, and wildlife.” 

Why undefined “regenerative” agriculture falls short. The so-called “regenerative agriculture” promoted by proposals like the Growing Climate Solutions Act and President Biden's Climate 21 Project ignores the direct climate impacts of nitrogen fertilizers, the damage to soil health and ecosystem services caused by pesticides and chemical fertilizers, the adverse impact of chemical no-till practices that rely on glyphosate (Roundup) and other equally hazardous herbicides, and the fact that pesticide and fertilizer manufacturing is dependent on fossil fuels—as key ingredients and also for the heat and energy-driving chemical reactions. It is important to see through this deception. 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.'"

Beyond farming, we need a land management plan as a part of a national plan. Preserving natural land increases biodiversity, which also reduces dependence on petroleum-based pesticides. Natural forests are more effective than tree plantations in sequestering carbon. Biodiversity in forest ecosystems adds to their effectiveness in sequestering carbon. In addition, biodiversity buffers against damage from climate change—for example, by protecting shorelines from storm damage. Protecting forests, mangroves, peatlands, and other natural habitats helps to store more carbon in soil and vegetation.
Preserving natural lands and transitioning farms to organic production should be the cornerstones to combating climate change. Instead of promoting carbon trading, Congress and the Biden Administration must incorporate into a holistic approach, at the very least, the provisions included in the following:

  • Climate Stewardship Act of 2019, introduced in the House by then-Representative Haaland and in the Senate by Senator Booker.
  • The Agriculture Resilience Act, introduced in 2020 by Representative Pingree.
  • Former Senator Udall's pledge to conserve at least 30% of U.S. land and ocean by 2030 and 50% by 2050.
  • Representative Neguse's Resolution on a National Biodiversity Strategy.
  • A $30 billion fund dedicated solely to fund the transition to organic agriculture, with a goal of achieving 100% organic farms by 2026.

>>Tell your Congressional Representatives and Senators to support a holistic approach to the existential threats of the climate crisis and biodiversity collapse.

Letter to Congress

I am concerned that the carbon market approach embodied in the Growing Climate Solutions Act and President Biden’s Climate 21 Project does not adequately and comprehensively respond to interconnected threats to public health and the environment. The climate crisis and the devastating decline in biodiversity are escalating as a result 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/GHG). The current carbon market proposals fall short.

The focus on carbon outside of a holistic approach allows continued disproportionate hazards to people of color and communities living near toxic sites. Carbon trading/offsets under consideration do not establish an end date for admittedly unacceptable practices or ensure a transition to life-sustaining practices. Alongside proposals to replace the combustion engine with electric vehicles, 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.

Carbon trading schemes are flawed because they:

*Ignore the impact of more potent GHGs, including the 300 times as potent nitrous oxide emitted by chemical fertilizer.

*Allow big polluters to continue business as usual by purchasing carbon credits.

*Can incentivize practices, like chemical no-till, that rely on inputs based on petroleum, poison soil, and release more potent GHGs.

*Do not protect natural land, which is even more effective in sequestering carbon.

*Has negative impacts on communities on the frontlines of fossil fuel destruction, including indigenous communities and other people of color on the fencelines of the fossil fuel industry.

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.”

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. It is important to see through this deception.

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. Instead of promoting carbon trading, Congress and the Administration must incorporate into a holistic approach, at the very least, the provisions included in the:

*Climate Stewardship Act of 2019.

*The Agriculture Resilience Act of 2020.

*A pledge to conserve at least 30% of U.S. land and ocean by 2030 and 50% by 2050.

*The Resolution on a National Biodiversity Strategy.

*A $30 billion fund dedicated solely to fund the transition to organic agriculture, with a goal of achieving 100% organic farms by 2026.

Thank you.

02/08/2021 — Tell Agencies New Executive Order Requires Bold Regulatory Action

Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order, if effective, will  reverse the historical trend of status quo regulatory reviews that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers), required by the White House Office of Management and Budget (OMB). Instead, the President's EO, Modernizing Regulatory Review, sets the stage for the adoption of agency policy across government to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism). 

Key agencies that can have a systemic effect in meeting these existential challenges are the Environmental Protection Agency (EPA), Department of Interior (DOI), Department of Agriculture (USDA), and Department of Labor/Occupational Safety and Health Administration (DOL/OSHA). But, the EO will remain words on a page unless we all across the country exercise our voice and advocate for the changes necessary to end our reliance on hazardous chemicals and immediately embrace the viability of nonpolluting alternatives, like organic agriculture and land management.  No one expects the polluting corporations to shrink in the face of a shift to a green economy—which makes our voice and oversight all that more important.

>>Tell the heads of EPA, DOI, USDA, and DOL/OSHA to review decisions allowing toxic chemical use based on available alternatives—technologies, practices, and products—that reduce or eliminate hazards.

Ever since the Reagan administration, regulatory review by the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and the Budget (OMB) has prevented agencies from promulgating new regulations based on new science and technologies that are more protective of health and the environment. OIRA acts as a gatekeeper to new regulations and has generally resisted changes to the status quo—even in regulations designed to adapt to new science and technology. An example of such regulations is the sunset process created in the Organic Foods Production Act (OFPA), which was is designed to review synthetic materials allowed in organic production every five years and remove them if they no longer meet OFPA criteria.

There are many examples of such regulations, and OIRA no longer needs to explicitly deny changes in regulations because agencies restrict their own actions based on the fear of OIRA review. President Biden's Executive Order offers an opportunity for OIRA/OMB and federal agencies to place new criteria on changes in regulations. Instead of protecting the status quo, the review should be based on the President's priorities as stated in the Modernizing Regulatory Review EO.

To be meaningful, regulatory reviews, in accordance with the EO, must analyze existing regulatory decisions on registration, allowance, and/or use of toxic pesticides and synthetic fertilizers in the context of available alternatives—technologies, practices and products—that reduce or eliminate hazards. We urge that all agencies immediately conduct an alternatives assessment that evaluates available organic practices in accordance with 7 CFR 205.600, the National List of Allowed and Prohibited Substances under the National Organic Program. This is especially important in the context of protecting health and the environment and ensuring racial equity in the application of regulations that currently allow for disproportionate and elevated risk for farmworkers and landscapers, as well as fenceline communities and people of color. These communities currently suffer disproportionate risk due to toxic chemical exposure, comorbidities, and elevated vulnerabilities to diseases and COVID-19 that are ignored under current regulatory reviews.

The tools are available now to end the use of toxic chemicals in current land management practices nationwide, including the management of agricultural land and landscapes, yet regulations allow disproportionate harm to black, brown, and indigenous people that is associated with a chain of poisoning and contamination from production to transportation, application, and disposal. The EO, if it is to be implemented in the spirit that is intended, requires that each agency conduct a full assessment of actions that it can take immediately to eliminate or reduce the current harms being inflicted that are unnecessary, given the availability of organic (as defined in federal law) alternatives.

>>Tell the heads of EPA, DOI, USDA, and DOL/OSHA to review decisions allowing toxic chemical use based on available alternatives—technologies, practices, and products—that reduce or eliminate hazards.

Letter to the (new) heads of EPA, DOI, USDA, and DOL/OSHA

Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order, Modernizing Regulatory Review, sets the stage for the adoption of agency policy to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism).

I ask your agency to conduct a review, in accordance with the Modernizing Regulatory Review EO, to analyze existing regulatory decisions on registration, allowance, and/or use of toxic pesticides and synthetic fertilizers in the context of available alternatives—technologies, practices and products— that reduce or eliminate hazards. I urge you to immediately conduct an alternatives assessment—associated with all your regulatory and administrative decisions— that evaluates available organic practices in accordance with 7 CFR 205.600, the National List of Allowed and Prohibited Substances under the National Organic Program. This is especially important in the context of protecting health and the environment and ensuring racial equity in the application of regulations that currently allow for disproportionate and elevated risk for farmworkers and landscapers, as well as fenceline and people of color communities. These communities currently suffer disproportionate risk due to toxic chemical exposure, comorbidities, and elevated vulnerabilities to diseases and COVID-19 that are ignored under your current regulatory reviews.

The tools are now available to end the use of toxic chemicals in current land management practices, including the management of agricultural land and landscapes, yet the regulations of your agency allow disproportionate harm to black, brown, and indigenous people that is associated with a chain of poisoning and contamination from production to transportation, application, and disposal. The EO, if it is to be implemented in the spirit that is intended, requires that your agency conduct a full assessment of actions that it can take immediately to eliminate or reduce the current harms being inflicted that are unnecessary, given the availability of organic (as defined in federal law) alternatives.

Please know that there is a wealth of information on the efficacy, economic viability, and profitability of organic management practices that replace your agency’s current assumption about the need for, or reasonableness of, toxic chemical dependency. We urge that this information be utilized in all your regulatory and administrative decision-making in order to eliminate the current unnecessary reliance on toxic materials.

I look forward to your agency’s alternative organic analysis full implementation of the Modernizing Regulatory Review EO.

Thank you.

02/01/2021 — Save Monarch Butterflies from Extinction

The yearly winter monarch count along the California coast, overseen each year by the conservation group Xerces Society, was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate that many on the planet today are, within their lifetimes, likely to experience a world where western monarchs are extinct.

>>Tell the U.S. Fish and Wildlife Service to list monarch butterflies on the list of threatened and endangered species. Tell the Environmental Protection Agency to eliminate pollinator poisons.

Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count. In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, that number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers crashed below 30,000.

This year's count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred. “These sites normally host thousands of butterflies, and their absence this year was heartbreaking for volunteers and visitors flocking to these locales hoping to catch a glimpse of the awe-inspiring clusters of monarch butterflies,” said Sarina Jepsen, director of endangered species at the Xerces Society.

Decline is driven by human activity. Climate change, habitat destruction, and the use of toxic pesticides are causing “death by a thousand cuts,” says Xerces Society executive director Scott Black.

A changing climate impacts environmental cues that trigger breeding, migration, and hibernation in monarchs. Climate-induced extreme weather events such as wildfires, severe storms, and droughts further stress populations. Habitat destruction has occurred through the displacement of natural land with industrial development, and logging and other damage to monarch overwintering sites. Milkweed plants that monarchs require as larval food have been found to contain pesticides at levels that can kill them—one study found toxic pesticides in every milkweed plant tested. Herbicides, like glyphosate (Roundup), that do not kill monarchs directly are killing milkweed, exacerbating concerns around habitat destruction. Each of these stressors are harmful on its own, but stress is compounded by their combination.

A study published in the journal Biological Conservation in 2017 (while numbers were still ~300,000) determined that western monarchs faced a 72% chance of extinction in 20 years and an 86% chance of extinction within the next 50 years. “This study doesn't just show that there are fewer monarchs now than 35 years ago,” said study coauthor Cheryl Schultz, PhD, at Washington State University. “It also tells us that, if things stay the same, western monarchs probably won't be around as we know them in another 35 years.”

Eastern monarchs are also suffering. This population migrates from the U.S. East and Midwest to overwintering grounds in Mexico each year. A 2018 study published by a research team at University of Florida found that this population has declined by 80% since 2005. Two years after that study was published, the 2019/2020 eastern monarch count conducted by citizen scientists found another 53% reduction. Eastern monarchs are counted by the number of acres they occupy. In 2019/20, this number was 7 acres, down from 15 acres the prior year. Scientists have determined that 15 acres is the minimum threshold necessary to prevent total migratory collapse. A report from the World Wildlife Fund estimates that at the current rate of decline, the eastern monarch migration could collapse within 20 years.

Wildlife and conservation groups urged the U.S. Fish and Wildlife Service to list monarchs under the Endangered Species Act. Late last December, the Trump Administration announced it was a candidate for listing, but that listing is “precluded by work on higher-priority listing actions.” The Biden administration must follow through with listing and protective actions.

Monarchs may be the most charismatic pollinator to fall in the age of the insect apocalypse. But unless meaningful changes are made, it will not be the last. Recent research published in Biological Conservation show that 41% of insect species are declining and 30% are endangered, with an overall rate of insect decline at 2.5% each year.

>>Tell the U.S. Fish and Wildlife Service to list monarch butterflies on the list of threatened and endangered species. Tell the Environmental Protection Agency to eliminate pollinator poisons.

 

Letter to Martha Williams, Principal Deputy Director, U.S. Fish and Wildlife Service

The yearly winter monarch count along the California coast was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate the imminent extinction of western monarchs. Urgent action is required to implement a plan to protect monarchs as an endangered species!

Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count.  In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, the number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers had crashed below 30,000.

This year’s count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred.

Decline is driven by human activity. Climate change, habitat destruction, and the use of toxic pesticides are combining to threaten the species. The way to initiate action to protect monarchs is to include them on the list of threatened and endangered species.

A changing climate alters environmental cues that trigger monarchs to breed, migrate, and hibernate. Climate-induced extreme weather events such as wildfires, severe storms, and droughts further stress populations. Habitat destruction includes logging, the displacement of natural land by industrial development, and other damage to monarch breeding and overwintering sites. Milkweed plants that monarchs require as larval food have been found to contain pesticides at levels that can kill them– one study found toxic pesticides in every milkweed plant tested. Herbicides, like glyphosate (Roundup), that do not kill monarchs directly kill milkweed, exacerbating habitat destruction. Each of these stressors is harmful on its own, but their combination compounds the damage.

A study published in the journal Biological Conservation in 2017 (while numbers were still ~300,000) determined that western monarchs faced a 72% chance of extinction in 20 years and an 86% chance of extinction within the next 50 years.

Eastern monarchs are also suffering. This population migrates from the US East and Midwest to overwintering grounds in Mexico each year. A 2018 study by researchers at University of Florida found that this population has declined by 80% since 2005. Two years later, the 2019/2020 eastern monarch count conducted by citizen scientists found another 53% reduction. Eastern monarchs are counted by the number of acres they occupy. In 2019/20, this number was 7 acres, down from 15 acres the prior year. Scientists have determined that 15 acres is the minimum threshold necessary to prevent total migratory collapse. A report from the World Wildlife Fund estimates that at the current rate of decline, the eastern monarch migration could collapse within 20 years.

Wildlife and conservation groups urged the U.S. Fish and Wildlife Service to list the monarch under the Endangered Species Act (ESA). Late last December, the Trump Administration announced it was a candidate for listing, but that listing is “precluded by work on higher-priority listing actions.” The presence of other high-priority issues is further evidence of the existence of severe threats to biodiversity, not a reason to avoid action. Protecting biodiversity is the purpose of the ESA. The Biden administration must follow through with listing and protective actions.

Monarchs may be the most charismatic pollinator to fall in the age of the insect apocalypse. But unless meaningful changes are made, it will not be the last. Recent research published in Biological Conservation show that 41% of insect species are declining and 30% are endangered, with an overall rate of insect decline at 2.5% each year.

Please put monarch butterflies on the threatened and endangered species list and require protective actions by other agencies.

Thank you.

 

Letter to Jane Nishida, Acting Administrator, EPA

The yearly winter monarch count along the California coast was the lowest ever. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate the imminent extinction of western monarchs. Urgent action is required to protect monarchs as an endangered species!

Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count.  In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, the number fell to 1.2 million. Five years ago, counts were at roughly 300,000. By 2019, numbers had crashed below 30,000. This year’s count saw no monarchs at well-known overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park, saw only a few hundred.

Decline is driven by human activity. Climate change, habitat destruction, and the use of toxic pesticides are combining to threaten the species.

A changing climate alters environmental cues that trigger monarchs to breed, migrate, and hibernate. Climate-induced extreme weather events such as wildfires, severe storms, and droughts further stress populations. Habitat destruction includes logging, the displacement of natural land by industrial development, and other damage to monarch breeding and overwintering sites.

Milkweed plants that monarchs require as larval food have been found to contain pesticides at levels that can kill them– one study found toxic pesticides in every milkweed plant tested. Herbicides, like glyphosate (Roundup), that do not kill monarchs directly kill milkweed, exacerbating habitat destruction. Each of these stressors is harmful on its own, but their combination compounds the damage.

A study published in the journal Biological Conservation in 2017 (while numbers were still ~300,000) determined that western monarchs faced a 72% chance of extinction in 20 years and an 86% chance of extinction within the next 50 years.

Eastern monarchs are also suffering. This population migrates from the U.S. East and Midwest to overwintering grounds in Mexico each year. A 2018 study by researchers at University of Florida found that this population has declined by 80% since 2005. Two years later, the 2019/2020 eastern monarch count conducted by citizen scientists found another 53% reduction. Eastern monarchs are counted by the number of acres they occupy. In 2019/20, this number was 7 acres, down from 15 acres the prior year. Scientists have determined that 15 acres is the minimum threshold necessary to prevent total migratory collapse. A report from the World Wildlife Fund estimates that at the current rate of decline, the eastern monarch migration could collapse within 20 years.

Wildlife and conservation groups urged the U.S. Fish and Wildlife Service to list the monarch under the Endangered Species Act (ESA). Late last December, the Trump Administration announced it was a candidate for listing, but that listing is “precluded by work on higher-priority listing actions.” The presence of so many high-priority issues is further evidence of the existence of severe threats to biodiversity, not a reason to avoid action. It is time for EPA to protect biodiversity from toxic chemical threats.

Monarchs may be the most charismatic pollinator to fall in the age of the insect apocalypse. But unless meaningful changes are made, it will not be the last. Recent research published in Biological Conservation show that 41% of insect species are declining and 30% are endangered, with an overall rate of insect decline at 2.5% each year.

Please include these threats to insect biodiversity in EPA’s pesticide registration decisions. Eliminate pesticides that endanger pollinators and their habitat.

Thank you.

01/25/2021 — Tell EPA to Reverse Approval of Highly Toxic Insecticide Aldicarb on Oranges

First registered in 1970 and voluntarily cancelled in 2010, aldicarb (Temik™) was being manufactured in Bhopal, India in 1984 when a leak of a precursor—methyl isocyanate (MIC)—spread over the city, ultimately killing more than 25,000 people and leaving more than 120,000 people who still suffer from severe health problems as a result of their exposure. In 1989, Union Carbide Corporation—the manufacturer of aldicarb at the time—paid $470 million (equivalent to $860 million in 2019) to settle litigation stemming from the disaster. Aldicarb, now made by Bayer, has been allowed by the outgoing Trump EPA for use on oranges.

>>Tell EPA to Reverse Approval of Highly Toxic Insecticide Aldicarb!

No pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. The disaster in Bhopal was followed by others, including a leak in Institute, WV in 1985 that injured at least 135 people and a 2008 explosion in Institute, WV that killed two and injured at least eight. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don't stop there—aldicarb is also notorious for contaminating groundwater.

EPA has approved aldicarb (an insecticide) in combination with streptomycin (an antibiotic used to fight human disease) to control citrus greening, a disease transmitted by the Asian citrus psyllid. As Nathan Donley, PhD of the Center for Biological Diversity says, “Only the Trump EPA would approve use of a medically important antibiotic and a pesticide banned in over 100 countries on citrus crops.”

Aldicarb is a highly toxic, systemic carbamate insecticide that is a fast-acting cholinesterase inhibitor that permanently binds to the active site of an essential enzyme for normal nerve impulse transmission, acetylcholinesterase (AChE), deactivating the enzyme. In doing this, the chemical causes damage to the central and peripheral nervous systems, interrupting neurological activity. Aldicarb is subject to regulation under the Rotterdam Convention, an international treaty established to reduce the trade of the most globally hazardous chemicals, with over 100 countries—excluding the U.S.—banning its use. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category. However, the U.S. is one of only a few countries around the world that does not regulate aldicarb via the treaty, but merely strictly restricts its uses.

Aldicarb may persist in groundwater for decades due to its long half-life between 200 to 2000 days and ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Furthermore, aldicarb is a systemic pesticide that plant roots and leaves readily uptake, leading to toxic chemical residues in pollen and sap-like droplets (guttation) easily accessible to vulnerable pollinators, like bees.

In 2010, Bayer CropScience agreed with EPA to voluntarily cancel the production of Temik 15G, the sole aldicarb pesticide on the market, ending distribution by 2017. The chemical poses an unnecessary dietary risk to infants and children, causing neurological harm at very low doses. However, less than a decade after its discontinuation, a new aldicarb product by AgLogic—AgLogic 15G—surfaced, with limited use on a small subset of U.S. crops.

Presently, AgLogic is the only manufacturer of aldicarb pesticide products, and approving it for use on citrus fruit highlights faults within the pesticide regulatory system. Evidence demonstrates that past use of Temik 15G on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. Furthermore, the Florida Department of Agriculture denied AgLogic's request to gain “Special Local Needs” approval under Section 24(c) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) for use on Florida citrus in 2017 and 2018. AgLogic was unable to demonstrate that aldicarb is safer at controlling pests than other alternatives. This new AgLogic registration does not “require the submission of comparative efficacy studies,” which accelerated regular Section 3 registration on citrus.

Organic growers know that soil biology and soil health is important to protection from diseases like citrus greening. The use of aldicarb and streptomycin, on the other hand, destroy healthy soil biota.

The approval of AgLogic15G for use on citrus crops (e.g., grapefruit, lemon, orange, lime trees) allows an additional 400,000 acres of crop treatments in areas where pesticides already pose a threat to human, animal, and environmental health. Karen McCormack, a retired employee of the EPA's pesticide office, states her concern over aldicarb approval: “It's deeply disappointing to watch the current EPA renege on its agreement to ban this highly toxic and persistent pesticide. After receiving numerous complaints of aldicarb leaching into groundwater and contaminating drinking water supplies in Florida and elsewhere, my colleagues worked tirelessly to reach a voluntary agreement with the aldicarb manufacturer to stop producing this hazardous pesticide. Now it appears all this work may have been in vain.”

The approval of the aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.

It is essential that when EPA weighs the risks and benefits of extending pesticide uses, the agency acknowledges previous harms associated with those chemicals. Harms ultimately associated with contaminant exposure should end through policy reform and the adoption of practices that eliminate toxic pesticide use. With far too many diseases in the U.S. associated with pesticide exposure, prohibiting the use of pesticides with known toxic effects is crucial for safeguarding public health.

>>Tell EPA to reverse approval of highly toxic insecticide aldicarb.

Letter to EPA

It is crucial that the Biden administration add to its list of urgent actions the reversal of EPA’s approval of the highly toxic insecticide aldicarb for use on citrus.

First registered in 1970 and voluntarily cancelled in 2010, aldicarb (Temik™) was being manufactured in Bhopal, India in 1984 when a leak of a precursor—methyl isocyanate (MIC)—spread over the city, ultimately killing more than 25,000 people and leaving more than 120,000 people who still suffer from severe health problems as a result of their exposure. In 1989, Union Carbide Corporation—the manufacturer of aldicarb at the time—paid $470 million (equivalent to $860 million in 2019) to settle litigation stemming from the disaster. Aldicarb, now made by Bayer, has been allowed by the outgoing Trump EPA for use on oranges.

No pesticide epitomizes the “cradle-to-grave” dangers of pesticides better than aldicarb. The disaster in Bhopal was followed by others, including a leak in Institute, WV in 1985 that injured at least 135 people and a 2008 explosion in Institute, WV that killed two and injured at least eight. In use, it has been implicated in poisoning of workers and their children, poisoning deer and other game consuming contaminated seeds, and notably, poisoning food grown in soil treated with the chemical. The effects don’t stop there—aldicarb is also notorious for contaminating groundwater.

EPA has approved aldicarb (an insecticide) in combination with streptomycin (an antibiotic used to fight tuberculosis) to control citrus greening, a disease transmitted by the Asian citrus psyllid. As Nathan Donley, PhD of the Center for Biological Diversity says, “Only the Trump EPA would approve use of a medically important antibiotic and a pesticide banned in over 100 countries on citrus crops.”

Aldicarb is a highly toxic, systemic carbamate insecticide banned by over 100 countries under the Rotterdam Convention. Both EPA and the World Health Organization (WHO) classify the chemical in the highest toxicity category.

Aldicarb may persist in groundwater for decades due to its long half-life between 200 to 2000 days, and ingestion of aldicarb-contaminated groundwater by residents adversely affects immune system function. Furthermore, aldicarb is a systemic pesticide that plant roots and leaves readily uptake, leading to toxic chemical residues in pollen and guttation droplets, poisoning pollinators like bees.

In 2010, Bayer CropScience agreed with EPA to voluntarily cancel the production of Temik 15G, the sole aldicarb pesticide on the market, ending distribution by 2017. However, less than a decade after its discontinuation, a new aldicarb product by AgLogic—AgLogic 15G—surfaced, with limited use on a small subset of U.S. crops.

Evidence demonstrates that past use of Temik 15G on citrus fruit crops exclusively posed the highest risk to children and infants, ultimately leading to its 2010 cancellation. Furthermore, the Florida Department of Agriculture denied AgLogic’s request to gain “Special Local Needs” approval under Section 24(c) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) for use on Florida citrus in 2017 and 2018 because AgLogic was unable to demonstrate that aldicarb is safer at controlling pests than other alternatives.

Organic growers know that soil biology and soil health is important to protection from diseases like citrus greening. The use of aldicarb and streptomycin, on the other hand, destroy healthy soil biota.

The approval of the aldicarb use demonstrates the danger of regulating pesticides through negotiated voluntary cancellations, which do not produce a record on which EPA or the public can depend for future decisions.

Please reverse EPA’s approval of the highly toxic insecticide aldicarb for use on citrus.

01/21/2021 — Tell the Biden USDA and Congress to Protect COVID relief for Black, Indigenous, People of Color, and Military Veteran Farmers!

(Beyond Pesticides, January 19, 2021) Inadequate funding proposed by the U.S. Department of Agriculture (USDA) for the Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program (also known as the “Section 2501” program) fails to address historic discrimination and inadequate assistance for farmers of color and military veteran farmers. Funding for the Section 2501 program, which for three decades, has been the only farm bill program specifically addressing needs of these underserved populations in agriculture is smaller this year, placing undue stress on already stretched-thin community organizations working to respond to farmers during this unprecedented period of prolonged economic hardship.

Tell the Biden USDA to ensure that the full Section 2501 funding reaches farmers of color and military veteran farmers.

Since 1990, the goal of the Section 2501 program has been to increase historically underserved farmers’ awareness of and access to USDA resources—addressing the historic inequities that farmers of color, or socially disadvantaged farmers, faced in accessing USDA programs, including Farm Service Agency (FSA) loans. Congress added military veterans to the program in 2014 as an additional underserved audience. Section 2501 grants provide funding to community-based organizations and minority-serving academic institutions to conduct critical outreach and technical assistance to communities of color and veterans. 

Unfortunately, USDA has redirected $2 million of this funding, along with $2 million redirected from Natural Resources Conservation Service (NRCS) conservation technical assistance funds to a separate, administratively created initiative. USDA’s a new Centers for Community Prosperity initiative seeks to address economic development in persistent poverty communities, with a focus on faith-based initiatives. This new program is less focused on socially disadvantaged farmers and much more prescriptive in project design than the Section 2501 program. In total, USDA diverted $4.2 million into this new initiative. 

Congress recently provided an additional $40 million for the Section 2501 grant program in its latest COVID relief bill passed in December 2020. Please urge USDA to ensure this funding goes directly to Section 2501 grantees and reaches socially disadvantaged farmers, and not be used for any other initiative—such as the Centers for Community Prosperity.

Tell the Biden USDA to ensure that the full Section 2501 funding reaches farmers of color and military veteran farmers.

Letter to Congress

As the COVID-19 pandemic drags on, farmers across the country are struggling to keep their farms afloat and plan for the uncertainty that the coming year holds. While farmers have suffered from several years of depressed prices, uncertainty in trade markets, and the increasingly severe impacts of climate change, the already tenuous livelihoods of our nation’s most chronically underserved farmers—particularly Black, Indigenous, and people of color farmers–were made worse this year as a result of the pandemic. I am increasingly concerned about the sustainability of our nation’s most underserved farmers who often not only have the fewest resources to draw on but also are most in need of emergency relief and long-term support in these challenging times—as well as the nation’s food security that depends on them.

As you know, Congress recently passed its fourth round of emergency relief to help farmers, small businesses, health care professionals, households and communities across the country combat the worsening impacts of the coronavirus pandemic. As directed in the farm bill, the $80 million in additional  USDA funding is to be divided equally between USDA’s Beginning Farmer and Rancher Development Program and the Outreach and Technical Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program, also known as the Section 2501 Program.

I urge you to make sure that USDA moves expeditiously to grant these additional Section 2501 funds to eligible entities with the skills and experience to reach socially disadvantaged and veteran farmers and ranchers, including those most impacted by the ongoing coronavirus pandemic. It is my expectation, as is shared by Congress, that the additional $40 million in funding to be directed to the Section 2501 grant program will support projects as authorized under the farm bill and will not be diverted to any other administrative initiative or purpose, such as the Centers for Community Prosperity.

In the fact of the future uncertainty of the ultimate impacts of the pandemic on our food system and communities of color, please pressure USDA to distribute the additional Section 2501 grants in a way that ensures organizations have resources over the coming years to respond to their community’s needs. USDA should also use the additional funding to increase the total grant award amount to its statutory level of $250,000 per year. Finally, I share the expectation of Congress that USDA will ensure that any project funded with these additional funds complies with the statutory requirements laid out in the farm bill—that it:

  • Has demonstrated experience in providing agricultural education or other agriculturally related services to socially disadvantaged farmers and ranchers and veteran farmers and ranchers;
  • Provides documentary evidence of work with, and on behalf of, socially disadvantaged farmers or ranchers and veteran farmers and ranchers during the 3-year period preceding the submission of their 2501 application;
  • Will use any 2501 funding to provide outreach and technical assistance exclusively to socially disadvantaged and veteran farmers in order to improve their participation in USDA agricultural program; and
  • Will represent a regional balance of projects that are geographically diverse and serve farmers in all states and regions

Thank you for supporting this critical program—especially during a time of such critical need for Black, Indigenous and people of color communities across the country.

Letter to Biden Transition Team on Agriculture

As the COVID-19 pandemic drags on, farmers across the country are struggling to keep their farms afloat and plan for the uncertainty that the coming year holds. While farmers have suffered from several years of depressed prices, uncertainty in trade markets, and the increasingly severe impacts of climate change, the already tenuous livelihoods of our nation’s most chronically underserved farmers—particularly Black, Indigenous, and people of color farmers—were made worse this year as a result of the pandemic. I am increasingly concerned about the sustainability of our nation’s most underserved farmers who often not only have the fewest resources to draw on but also are most in need of emergency relief and long-term support in these challenging times—as well as the nation’s food security that depends on them.

Congress recently passed its fourth round of emergency relief to help farmers, small businesses, health care professionals, households and communities across the country combat the worsening impacts of the coronavirus pandemic. As directed in the farm bill, the $80 million in additional  USDA funding is to be divided equally between USDA’s Beginning Farmer and Rancher Development Program and the Outreach and Technical Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers Program, also known as the Section 2501 Program.

I urge the Department to move expeditiously to grant these additional Section 2501 funds to eligible entities with the skills and experience to reach socially disadvantaged and veteran farmers and ranchers, including those most impacted by the ongoing coronavirus pandemic. It is my expectation, as is shared by Congress, that the additional $40 million in funding to be directed to the Section 2501 grant program will support projects as authorized under the farm bill and will not be diverted to any other administrative initiative or purpose, such as the Centers for Community Prosperity.

In the face of the future uncertainty of the ultimate impacts of the pandemic on our food system and communities of color, I ask USDA to distribute the additional Section 2501 grants in a way that ensures organizations have resources over the coming years to respond to their community’s needs. USDA should also use the additional funding to increase the total grant award amount to its statutory level of $250,000 per year. Finally, I share the expectation of Congress that USDA will ensure that any project funded with these additional funds complies with the statutory requirements laid out in the farm bill—that it:

  • Has demonstrated experience in providing agricultural education or other agriculturally related services to socially disadvantaged farmers and ranchers and veteran farmers and ranchers;
  • Provides documentary evidence of work with, and on behalf of, socially disadvantaged farmers or ranchers and veteran farmers and ranchers during the 3-year period preceding the submission of their 2501 application;
  • Will use any 2501 funding to provide outreach and technical assistance exclusively to socially disadvantaged and veteran farmers in order to improve their participation in USDA agricultural program; and
  • Will represent a regional balance of projects that are geographically diverse and serve farmers in all states and regions

Thank you for considering these recommendations and for supporting this critical program—especially during a time of such critical need for Black, Indigenous and people of color communities across the country.

01/11/2021 — Tell President-Elect Biden and Congress to Clean Up at EPA—End the Era of Corporate Deception

Tell President-Elect Biden and Congress to Clean Up at EPA—End the Era of Corporate Deception

01/04/2021 — Secure Your Food and the Future of Local Organic Farmers

As we begin the new year, one of the most pervasive problems that our country faces, which has been particularly painful especially during the holiday season, is food insecurity—now affecting 54 million people. Food insecurity in the U.S. is real. As we continue through the dark winter months with the threat of even greater surges in COVID-19, it is important to strengthen those connections that support food security and those who produce our food.

>>Ask your U.S. Senators and Representatives to make permanent support for small and medium sized local farmers, building on the Emergency Coronavirus Relief Package.

Worldwide, the threats of impending famine have been met by extraordinary responses from countries and private donors. These events are evidence that food shortages are caused by inequities in distribution rather than underproduction, consistent with continuing population growth and contrary to claims by the pesticide industry. Peasant activists Jeongyeol Kim and Pramesh Pokharel argue that the solution to food insecurity is food sovereignty—that a food system depending on big agribusiness and corporations does not support local food production. That food system contributes to food insecurity for both the countries depending on food imports that may not be present is a pandemic and for countries exporting food—whose food supplies may be exported and whose farmers are dependent on income from exports.

“The COVID-19 pandemic has had a profound impact on our nation's food supply,” said Senator Corey Booker, who sponsored the Local FARM Act. “Food banks are grappling with greater demand while subsequently facing steep reductions in donations. Farmers have been forced to dump products due to supply-chain disruptions and a resulting lack of access to traditional markets. And corporate agribusiness is proving incapable of maintaining operations in a way that is safe for both workers and our food supply.”

“In response, this legislation strengthens local and regional food systems in order to avoid the harmful supply-chain disruptions stemming from a consolidated market and provides greater choice to those purchasing food to feed their families during this difficult time,” said Senator Booker. “Billions of dollars in farm aid have been made available in response to the current health crisis, but current programs fail to not only fairly compensate farmers from across the economic spectrum, they fail to invest in resilient food systems that could protect the nation's food supply both now and in a future pandemic. It's time for that to change.”

"The ongoing coronavirus pandemic has left many small, beginning, and historically underserved producers, including Black, Indigenous, and farmers of color; in a precarious financial situation - especially farmers who have traditionally relied on selling into local and regional markets such schools, institutions, restaurants and farmers markets,” said Wes King, Senior Policy Specialist of the National Sustainable Agriculture Coalition (NSAC).

We need to make permanent support for small and medium sized local farmers, building on the Emergency Coronavirus Relief Package. Elements of Local Food Assistance and Resilient Markets Act (the Local FARM Act) must become permanent:

(i) Create specialty crop block grants; (ii) Expand online supplemental nutrition assistance program; (iii) Expand the Local Agriculture Market Program (LAMP); and (iv) Expand farm microloans.

According to Eric Deeble, NSAC policy director, “[The Emergency Coronavirus Relief Package] does not do enough to target aid to those producers and families who have been most impacted, and sunsets too soon: all but ensuring advocates will have to return to fight for families again in January.”  Mr. Deeble continued, “Even still, it is an important starting point as the new Administration and Congress begin to look beyond emergency response to the longer term work of rebuilding our food and farm system to be more sustainable, must, and equitable for every family.” 

In addition to the need for policy reform and in accordance with “Think globally and act locally,” we can help ourselves, our local farmers, and the resilience of the global food system by buying locally-grown organic food directly from the farmer—or with as few intervening steps as possible. Below are some resources that can help.

LocalHarvest provides a connection to community supported agriculture (subscription services), farms, farmers markets, and other local food sources. Eatwild provides a clearinghouse for information about pasture-based farming, with a directory of local farmers in the U.S. and Canada who sell their pastured farm and ranch products directly to consumers. The U.S. Department of Agriculture (USDA) maintains a database of local farmers markets. Another step away, there is a listing of cooperative grocery stores at the Cooperative Grocers Network. Winter may not be a good time to grow vegetables in most states, but sprouts and microgreens can be grown anywhere. 

>>Ask your U.S. Senators and Representatives to make permanent support small and medium sized local farmers, building on the Emergency Coronavirus Relief Package.

Letter to Congress

As we begin the new year, one of the most pervasive problems that our country faces, which has been particularly painful especially during the holiday season, is food insecurity—now affecting 54 million people. Food insecurity in the U.S. is real. As we continue through the dark winter months with the threat of even greater surges in COVID-19, it is important to strengthen those connections that support food security and those who produce our food.

I am writing to ask you to make permanent support for small and medium sized local farmers, building on the Coronavirus Relief Package. Elements of Local Food Assistance and Resilient Markets Act (the Local FARM Act) must become permanent:

(i) Create specialty crop block grants;
(ii) Expand online supplemental nutrition assistance program;
(iii) Expand the Local Agriculture Market Program (LAMP); and
(iv) Expand farm microloans.

Worldwide, the threats of impending famine have been met by extraordinary responses from countries and private donors. These events are evidence that food shortages are caused by inequities in distribution rather than underproduction, consistent with continuing population growth and contrary to claims by the pesticide industry. Peasant activists Jeongyeol Kim and Pramesh Pokharel argue that the solution to food insecurity is food sovereignty—that a food system depending on big agribusiness and corporations does not support local food production. That food system contributes to food insecurity for both the countries depending on food imports that may not be present is a pandemic and for countries exporting food—whose food supplies may be exported and whose farmers are dependent on income from exports.

"The ongoing coronavirus pandemic has left many small, beginning, and historically underserved producers, including Black, Indigenous, and farmers of color; in a precarious financial situation - especially farmers who have traditionally relied on selling into local and regional markets such schools, institutions, restaurants and farmers markets,” said Wes King, Senior Policy Specialist of the National Sustainable Agriculture Coalition.

Please help our local farmers to ensure the availability of food in our communities.

Thank you.