Agriculture is a vibrant industry in California. Over 80,500 farms and ranches in the state grow over 400 crops, see revenues totaling $44.7 billion a year and collectively generate upwards of $100 billion in related businesses. Many crops are exported; almonds are the top commodity, followed by dairy products, wine, walnuts, rice, pistachios, table grapes, oranges, processed tomatoes and cotton.
Plant pests—mainly insects, fungi, and diseases—can represent a very real threat to this industry. Once established, they can decimate regions or crops. And the threat is always changing: new pests can unwittingly be imported from other parts of the world, and existing pests may suddenly become more problematic as they respond to changes in climate or habitat.
A program that would make it easier to use pesticides on crop pests throughout the state is currently being considered by the California Department of Food and Agriculture. A public comment period on the draft proposal, known as a Program Environmental Impact Report, ended last week. Under this program, the agency would be free to respond quickly to new pests under certain conditions, using any one of 79 different chemicals—some of which are pesticides—in locations that could include residential areas, water district lands and even organic farms.
The draft P.E.I.R. drew the concern from some of West Marin’s stakeholders, including Marin Organic and the Bolinas Community Public Utility District, which joined others like the Organic Consumers Association, Moms Advocating Sustainability and the Center for Biologic Diversity. These groups fear the program will give the agency too much authority.
“This report ignores the damage to organic farms—it just brushes them off really,” said Don Smith, a member of the B.C.P.U.D. board. “It’s a disaster for farming in Marin County.”
Because the P.E.I.R. is a 500-page-technical document, the scope of its legal and practical implications has been hard to assess. In a clipped reply to a Light query, state Department of Food and Agriculture spokesman Steve Lyle, who declined a request for interview, defended the document, saying the “authority to do this work already exists in statute.” “The draft PEIR provides scientifically-valid, program-specific human health and environmental impact analysis if and when treatment is deemed necessary,” he wrote.
Of particular concern to many businesses and consumers in Marin is that the program specifically permits pesticides to be used on organic farms, without additional review or approval.
“This is a statewide approach to address some deficits in pest control for unseen or unknown insects or diseases,” said Stacy Carlsen, Marin County’s agricultural commissioner. “But what’s missing is discussion around regional kinds of agriculture.” Mr. Carlsen submitted an official comment letter on the report asking that the program respect organic treatments for organic lands.
The C.D.F.A. claims the use of chemicals would only be done as a last resort. “Generally, treatment programs do not include commercial producers, including organic producers. However, in rare cases, it may be necessary for the Department to require compliance with quarantine measures from producers, which could include treatment,” Mr. Lyle wrote.
Certain pests—including the glassy-winged sharpshooter, the Asian citrus psyllid, certain fruit flies and the Japanese beetle—can’t be eradicated using organic methods, according to the report. So if an infestation of these or similarly resistant pests were to take place, local organic growers of their host crops would be required to use conventional pesticides if they wanted to transport those crops outside of a quarantined area.
(By contrast, in 2010, when the Light Brown Apple Moth was attacking crops, the agency’s environmental impact report called for minimizing impacts to organic farms, and prohibited the application of materials containing the insecticide permethrin on or adjacent to those farms.)
Under the P.E.I.R., if certified organic lands are treated with pesticides, producers would not lose their organic status—a guarantee that has been written into federal law, according to Mr. Lyle.
Though designed to offer reassurance to organic growers, that guarantee raises an entirely new set of questions about the strength of organic standards and consumer protections. Although the report specifies that crops directly treated with chemicals could not be sold as organic, crops grown on the same land later in the same year could be labeled as organic.
The report also specifies that these crops could only be sold as organic “as long as they had no contact with the prohibited substance.” (However, the C.D.F.A. did not respond to requests for clarification as to whether there are additional guidelines determining what crops may or may not be labeled as organic despite exposure to recent pesticide applications.)
This appears to be in conflict with national organic standards that prohibit the use of chemical pesticides for a minimum of three years before certification is granted, and as an ongoing condition.
Thus, while the program does not threaten growers with the loss of their hard-earned organic standards, it is unclear what guarantee, if any, consumers would have regarding when pesticides were last applied to crops grown on organic land within a pest treatment area.
“Everyone has worked really hard over the years to have a program that they can stand behind,” said Kerry McGrath, the producer member manager for Marin Organic. “The concern with this in general is that there are a lot of unknowns. It could potentially weaken the standards of organic.”
Opponents also believe the program dismisses potential financial impacts to organic producers. Because farmers would not lose their certification, the report assumes they would be able to sell the affected produce as conventional. That is not so easy in a place like Marin, where costs are high, profit margins are low and a brand identity has been built around organic.
“We are unique in that we have basically no conventional agriculture, especially with our produce,” Mr. Carlsen said. “It’s all organic and the market demand is for organic, so to treat us as if we have an avenue for conventional is a misnomer.”
The county has over 40,000 acres of certified organic farmland that is worth over $45 million in gross value per year, according to Ms. McGrath. Even temporarily being forced to market their products as conventional would be a major blow to producers, potentially forcing them out of business, she said. “Conventional farming wouldn’t be economically sustainable in Marin County,” she added. “We’re strongly advocating for them to rethink the entire program.”
But the report reached the opposite conclusion, saying that despite the economic impact of selling their products under a conventional label, “the analysis concluded that this did not have the reasonably foreseeable potential to result in conversion of farmland to non-agricultural use.” (The Light was unable to locate a description of what methods of analysis were used to reach this conclusion.)
The report also asserts that by enabling the C.D.F.A. to more effectively combat problem pests, agriculture in the state will benefit overall. And it emphasizes that certain controversial techniques—such as aerial spraying over residential areas—are not being considered.
“This is meant to cover the entire known body of invasive species that have and/or could be detected in California, as well as the range of treatment programs that could be used,” Mr. Lyle wrote. “However, the mere mention of a treatment in the draft P.E.I.R. doesn’t necessarily mean it would be used.”