January 29, 2020

TO: CA DPR Chlorpyrifos Alternatives Work Group

RE: Comment for Chlorpyrifos Alternatives Roundtable Discussions

We could not participate in the Roundtable workshops and would like to voice our strong discouragement of one-to-one alternative pesticides in favor of agroecology. We are a training institute working at the intersection of pesticide use reduction, ecosystem restoration, carbon sequestration and resilience to severe climate impacts.  Building resilience is vital. Approval of pesticides should also reflect more understanding of natural cycles necessary to achieve the most ambitious goals and targets for vegetation and carbon sequestration for positive impacts for social justice including cleaner air, water, food and improved quality of life. Science has not adequately determined how toxic inputs set us back in ecosystem and climate restoration.

The more compelling reason to avoid all potentially disruptive toxic inputs (OMRI approved or otherwise) is that they don’t work as well as biologically based pest management that

  • enhances diverse habitat to support the natural enemy complex, 

  • deploys non-toxic traps, baits and lures and classical and augmentative biocontrol programs as needed, 

  • employs cultural practices to minimize the environmental conditions that favor pests and diseases, and

  • applies cover crops, compost, mulch, nutrients, biostimulants, and other healthy soils practices to maximize plant immune system for resistance to pests and diseases. 

A paradigm shift is required beyond IPM. Why take risks for environmental protection and public safety and health if we don’t need to and if holistic non-toxic ecologically based practices are also likely to build resilience on farms and sequester more carbon? Why continue to delay using healthy soils and agroecological practices when they are the best hope for resilience to climate impacts along with providing long-term plant health and protection? 

The new paradigm recognizes that building climate resilience and soil carbon are essential for farming and for civilization as we know it, and must be part of the analysis. Such practices obviate the need for toxic pesticides. Stop looking for silver bullets. Focus on supporting plant health.

Sincerely, 

Jan Dietrick, MPH, Executive Director 

Dietrick Institute for Applied Insect Ecology 

108 Orchard Dr 

Ventura, CA 9300

805-746-5365