Twenty-seven health, water, and environmental groups have commented on the California Department of Food and Agriculture’s multimillion dollar plan which calls for unfettered statewide spraying for pests.

The groups are condemning the agency for:

• failing to disclose the true health and ecological impacts of spraying;
• dismissing modern sustainable and scientifically sound approaches to farming;
• foreclosing nearly all opportunities for affected communities to have a voice in or prevent future pesticide applications; and
• developing a plan that allows the state to spray an array of pesticides into the indefinite future, while avoiding almost all additional environmental review and public scrutiny.

The groups, listed below, criticized the state for spending $4.5 million to prepare an environmental review document that ignores growing demand for organic food and mounting scientific evidence about the risks pesticides pose to human health, honeybees and the environment. Each contend that the plan ignores proven biological and ecological farming approaches for managing pests in California and casually rejects without evidence modern growing techniques that are protective of pollinators, waterways, and human and environmental health. The public’s awareness and engagement around these issues is also at an all-time high.

In a 100-page comment letter submitted to the state last week, the groups criticize the plan because, instead of modernizing the state’s agricultural system, it outlines and defends a toxic, decades-old, chemically intensive pest management approach that includes aerial, truck, and hand spraying and “pre-approves” a list of nearly 80 chemicals.

“Failing to disclose the true health and environmental impacts of this plan and at the same time giving the state the authority to carry out the plan into the indefinite future while avoiding almost all additional environmental review or public scrutiny runs afoul of the state’s environmental laws,” said Earthjustice Attorney Elizabeth Forsyth.

If approved, the state’s plan could force spraying of schools, organic farms with non-organic pesticides, in residential areas, watersheds, and sensitive habitats across the state. The comment letter includes the California Environmental Health Initiative, Center for Biological Diversity, the Central California Environmental Justice Network, Environmental Working Group, Friends of the Earth and MOMS Advocating Sustainability.

“This environmental review offers the state a tremendous opportunity to chart a course toward sustainable, ecologically and scientifically sound pest management,” said Nan Wishner of the California Environmental Health Initiative. “There is a wealth of both academic research and field evidence that an ecological-agriculture approach, which incorporates many proven organic methods, would meet the state’s objectives of preventing pest damage while providing safe, healthy food—and would avoid the serious health and environmental impacts of the tens of thousands of pounds of pesticides that would be used in our shared environment if the state’s plan were approved.”

“The state’s proposed program is a step backwards, and could have deep, irreversible impacts in local communities,” said Lyndon Comstock, member of the Board of Directors for Bolinas Community Public Utility District. “Chemicals sprayed anywhere within our watersheds by the state could be washed into our creek and reservoirs by rain and fog-drip. Also, the impact of the state’s program could ruin the economic livelihood of our organic farming community. If farmers are forced to spray non-organic pesticides and convert their farmland to conventional crops as the state envisions, farming would not be economically sustainable in our community. Marketing crops as organic allows our hard working farmers to survive, and provides healthy food to a discerning public.”

“The state’s environmental review misrepresents the health hazards of its plan by, among other things, ignoring those who are most vulnerable to harm from pesticide exposure—pregnant women, the elderly, the chronically ill, and in many cases infants,” said Caroline Cox of the Center for Environmental Health.

“This environmental review is attempting the impossible, to provide place-specific detail for a list of 79 pesticides used in any location in the state many years into the future, and it cuts communities out of the decision-making process. Local residents who have place-specific knowledge must always be afforded the opportunity to weigh in,” said Jason Flanders of ATA Law Group.

“It is shocking that the state would not only propose to continue using, in residential areas and at schools as well as on our food, a laundry list of 79 pesticides, many of them known to cause birth defects and neurological harm to children, but would assert that there are no human health impacts from using these chemicals,” said Debbie Friedman of MOMS Advocating Sustainability (MOMAS).

Download a copy of the groups’ comment letter.

The groups uniting against the spray plan include: California Environmental Health Initiative, Moms Advocating Sustainability, Center for Biological Diversity, Beyond Pesticides, Butte Environmental Council, Californians for Alternatives to Toxics, Californians for Pesticide Reform, California State Grange, Center for Environmental Health, Central California Environmental Justice Network, Citizens Committee to Complete the Refuge, the City of Berkeley, City of Richmond Mayor Gayle McLaughlin, Clean Water Action, Environmental Action Committee of West Marin, Environmental Justice Coalition for Water, Environmental Working Group, Friends of the Earth, Organic Consumers Association, Pesticide Action Network North America, Pesticide Free Zone, Raptors are the Solution, Safe Alternatives for Our Forest Environment, San Francisco Baykeeper, SAVE THE FROGS!, Slow Food California, and Topanga Creek Watershed Committee.