California’s Department of Pesticide Regulation (DPR) has published a draft of a policy that would replace its Integrated Pest Management policy with a Sustainable Pest Management (SPM) policy that is different in name only. SPM makes a commitment to continue using pesticides in California until 2050, and by implication, beyond. It makes NO commitment to reduce pesticide use or reconsider the current targets of pesticide applications. It claims that the health hazards and damage to the environment will be reduced by identifying “Priority Pesticides” for possible substitution or “eventual elimination.” It doesn’t commit to identifying any specific number of dangerous pesticides nor does it provide specific criteria for selecting these dangerous products. It claims that increased testing and development of new products will result in safer products and puts these judgments into the hands of “stakeholders” with “experiential and observational knowledge” rather than scientists with expertise in soil science, endocrinology, toxicology, epidemiology, biology, botany, horticulture, etc. The “stakeholder” committee that wrote the SPM proposal for urban areas included the manufacturer of pesticides and other users and promoters of pesticides.
That’s not an exhaustive list of the many faults of SPM and the dangers that lurk in it. I hope you will read it yourself and consider writing your own public comment by the deadline on Monday, March 13, 2023, at 5 pm. The document is available HERE. It’s less than 100 pages long and it is a quick read because it is basically a collection of bullet-points.
This is how to comment: “DPR is accepting public comments to inform the prioritization and implementation of the Roadmap’s recommendations through March 13, 2023 at 5 p.m. Comments can be shared in writing to alternatives@cdpr.ca.gov or by mail to the department at 1001 I Street, P.O. Box 4015, Sacramento, CA 95812-4015.” Please note that Department of Pesticide Regulations is not offering revisions, only “prioritization and implementation.”
My public comment on California’s “Sustainable Pest Management Roadmap”
A summary of my public comment is below. A link to the entire comment is provided at the end of the summary:
Public Comment on
“Sustainable Pest Management Roadmap”
(AKA “Pathway to poisoning the environment for another 25 years”)
My public comment is focused on pesticide use in urban areas because of my personal experience and knowledge of pesticide use where I live. These are the broad topics I will cover in detail with specific examples later in my comment:
- Since glyphosate was classified as a probable carcinogen by the World Health Organization in 2015 and the manufacturer of glyphosate settled 100,000 product liability lawsuits by awarding $11 billion to those who were harmed by glyphosate, public land managers have been engaged in the process of substituting other, usually equally or more dangerous herbicides for glyphosate to deflect the public’s concerns. The Sustainable Pest Management Roadmap (SPM) formalizes this process of substitution without addressing the fundamental problems caused by pesticides.
- SPM endorses the status quo that exists now. Affixing the word “Accelerating” to SPM is an extreme case of double-speak that deliberately obscures, disguises, distorts, or reverses the meaning of words. SPM ensures that toxic pesticides will be used in California for more than 25 years, to 2050, and likely beyond. SPM therefore accelerates the damage to the environment that is occurring now. Given that climate change will enable the movement of more pests into areas where they are now suppressed by weather, greater use of pesticides should be anticipated so long as the underlying issue is not addressed.
- The underlying issue is that pests have been identified for eradication that in some cases cannot be eradicated and in other cases should not have been identified as pests either because they are innocuous or because of the valuable ecological functions they perform. The key question that SPM does not address is whether pesticide use is truly necessary in the first place. Unless we focus on whether a pesticide is actually necessary, all other issues are merely window dressing for perpetual pesticide use.
- SPM proposes to identify “Priority Pesticides” for possible substitution without any clear definition of “Priority Pesticides,” a process that is ripe for manipulation. Given the substitutions that are occurring now, we cannot assume that further substitutions would be less toxic. SPM puts the classification of “Priority Pesticides” into the hands of “stakeholders” without clearly identifying who stakeholders are. SPM says “stakeholders” were involved in the development of the proposed policy. Those stakeholders included only users and promoters of pesticide use. There was no representation on the Urban Sub-Group of organizations such as Californians for Pesticide Reform, California Environmental Health Initiative, Beyond Pesticides, Center for Environmental Health, Environmental Working Group, etc. Nor was there any visible expertise in the fields of science that are capable of analyzing and evaluating the impact of pesticides, such as soil science, endocrinology, toxicology, entomology, botany, biology, or horticulture. SPM ensures that this exclusion will continue during the implementation phase by suggesting that “experiential and observational” knowledge should be represented on an equal footing with undefined “science.” The word “science” is being used and abused by advocates for pesticide use who dangle it as a magic talisman, conferring fraudulent credibility.
My entire public comment is available here:
Conservation Sense and Nonsense 
Thank you so much for this. Sharing….
Your response to this horror is brilliant, on so many levels. I so wish they would listen to you and stop their games and stop destroying our environment for profit. You’ve observed this mess for so many years and your comments are so accurate, as were your predictions. It’s all so simple, if they care, if those in power remove the profit motive and “stakeholders” who are producing the poisons destroying our environment were not allowed to participate, the solution would be easy: Stop using all poisons, stop trying to kill precious plants that wildlife needs and also that we love (including loving seeing the birds and other animals eating the very berries, etc. that these maniacs are destroying.) All that effort, work, and money saved that’s now being wasted, but worse than wasted, by harming the environment, earth, air, and water.
When something is as overwhelming and manipulative as their “Sustainable Pest Management Roadmap,” I often just try to find something that jumps out and is simple that says clearly to me if they know what they are doing or not. From their phrase, “invasive pests of all types, including weeds, insects, diseases, animals,” it’s clear that they don’t know what they are doing. They should not be in charge of anything having such an horrific effect on our environment if they don’t even know that insects are animals. So simple. If insects aren’t animals, what are they? — Just something to kill. Of course this ploy is playing on the typical nature-hating reaction to certain words and certain animals, like “insects,” ignoring that there would be no agricultural industry at all without insects. Besides pollinating, insects feed so many other animals, who then feed so many others.
But meanwhile, you answer everything else they are saying brilliantly. “Sleight of hand” indeed: Less pesticides, but no, what they are using instead is way more toxic and increased amounts….
The cancer and chronic illness rate is increasing like a plague. When my best friend got a very rare and invasive (likely iatrogenic/medically caused) cancer thirty years ago, it was still a shock to most friends. Nine years later, she got a second, more rare and even more invasive, but already there was less surprise. By the time she got a third separate cancer six years ago, so many others we know also had had separate multiple cancers. (She had surgery, but said no to all else they recommended, including radioactive scans and she is now 81). So many animals who never used to get cancer now do also. Other illnesses that used to be rare now also seem epidemic, and, while I know there are many possible causes, the poisons we are exposed to against our wills have to be part of this. And too many people are accepting this as inevitable.
None of this has to be so complicated and we should not be condemned to decades more of being poisoned by profit. Just stop it. Now.
Thank you again.
Thank you for standing up for our environment. The current so-called “pest management” is an environmental disaster…If only we’d listened better to Rachel Carson so many years ago we’d b living in a far better world today.