Source: Beyond Pesticides | June 22, 2024 |
As Pollinator Week draws to a close, it is important to note that all species—and ecosystems—are threatened by the failure of the U.S. Environmental Protection Agency (EPA) to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA).
Under FIFRA, EPA is required to register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.” Under ESA, EPA must, like all federal agencies, “seek to conserve endangered species and threatened species and shall utilize their authorities in furtherance of the purposes” of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions” through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.”
In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to FIFRA, whether those harms are “unreasonable” depends on a weighing of the costs and benefits. Under a related law, the Federal Food, Drug, and Cosmetic Act, EPA sets allowable residue limits of pesticides in food (tolerances) utilizing risk assessments that have embedded in them the assumption that toxic pesticides are necessary for crop production.
In fact, EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. In its Draft Herbicide Strategy Frameworkupdate, EPA says, “Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases.” Not true. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits” of pesticides are measured.
The only way to truly protect pollinators, insects, birds, and other species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Converting the world’s agricultural systems to organic would have a tremendously positive impact on threatened populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which are necessary for the recovery of threatened and endangered species.
By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. Organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world. Organic farming methods increase carbon sequestration in soils, reducing atmospheric carbon dioxide levels through practices that enhance soil organic carbon, such as using cover crops and organic soil amendments. Furthermore, organic farming reduces the reliance on fossil fuels by eliminating synthetic fertilizers and pesticides, which are energy-intensive to produce.
As part of its update to EPA’s ESA Workplan, EPA has created a “Mitigation Menu Website” for “reducing pesticide exposure to nontarget species from agricultural crop uses.” After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace” with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.” In this spirit, a range of people, including grower groups, gathered earlier in the year for a series of workshops in the Pacific Northwest to discuss possible mitigation measures. According to a report written by commercial beekeeper Steve Ellis (more background), concrete decisions were not reached at the workshops as participants recognized the complexities in crafting pesticide product label restrictions to protect endangered species. Mr. Ellis concluded: “If it’s so complex that it’s impossible, then no one wins.”
Even if EPA can fix some of the technological problems with its website, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are entirely voluntary. There is no enforcement mechanism and no way to ensure that the pesticides are used as directed or that mitigation measures are implemented properly. In addition, EPA is making allowances for use of a pesticide when impacts cannot be avoided. Specifically, EPA plans to allow the use of toxic chemicals that kill endangered species when the user provides “offsets” such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species.” How EPA will ensure that such offsets happen or that they successfully contribute to the conservation of a species of concern has not been described. It also does nothing to protect the habitat necessary for the long-term survival of the species in its ecosystem.
As stated above, the only way to truly protect endangered species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Instead of creating a complicated work-around that will not address the urgent health, biodiversity, and climate crises, EPA must cancel registrations of pesticides that harm endangered species and facilitate a widescale conversion to organic practices.
>>Tell EPA that to meet its obligations under FIFRA and ESA, it must facilitate a transition to organic practices. Tell Congress to ensure that EPA meets its statutory obligations.
The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.
Originally published on Beyond Pesticides, please click here to read more.