August 16, 2021
Ventura County Planning Commission
RE: Phase 2C amendments to the Ventura County Local Coastal Program (LCP)
The Dietrick Institute for Applied Insect Ecology supports the amendments to the LCP, which includes Amendments to the Coastal Area Plan and Coastal Zoning Ordinance for Environmentally Sensitive Habitat Area…(PL17-0083)
We commend the focus on pesticides and second-generation rodenticides. It is a General Plan goal to encourage sustainable and regenerative farming and ranching practices that promote resource conservation and reduce greenhouse gases and policy to encourage and support the use of Integrated Pest Management practices to reduce pesticide use and human health risks, and to collaborate with the agricultural community to provide information on Integrated Pest Management and agricultural products and practices. We want to ensure consideration of alternatives as part of best management practice as well as compliance with CEQA and state code Title 3 (CCR), section 6426.
We especially applaud the plan for a public education program about the negative environmental consequences of pesticide use. People are not aware that widely used pesticides harm organisms that are critical to healthy soil, biodiversity, soil carbon sequestration and water-holding capacity for resilience to climate change. Pesticides and especially herbicides change local ecology, reducing important food sources threatening insects, birds, reptiles, and mammals 1
A new study: https://www.frontiersin.org/articles/10.3389/fenvs.2021.643847/full Pesticides and Soil Invertebrates: A Hazard Assessment, 2021, found that in 71% of cases studied, pesticides across all classes studied, kill or harm soil invertebrates including earthworms, ants, beetles and ground nesting bees. The review shows “extensive evidence that pesticides pose a serious threat to soil invertebrates and the essential ecosystem services that they provide” and supports “ inclusion of a soil health analysis in the US pesticide risk assessment process.” 2
The county’s educational program should include the positive effect of organic farming around ESHA areas. 3, 4 Simply conserving protected natural areas has been shown to be insufficient for protecting species and biodiversity when industrial agriculture is nearby 5, 6 Organic farming near natural areas can significantly contribute to creating biodiversity islands and streams, improving species numbers. 7
More land managers are beginning to learn to build healthy soils and regenerative systems for water retention and resilience as well as to earn potential revenues in the soil carbon market. Farming based on organic and regenerative systems near valuable ESHA areas can significantly contribute to creating biodiversity islands and streams, improving species numbers. Your educational program can help speed that transformation to more ecologically based land management everywhere in the county.
Sincerely,
Jan Dietrick, MPH
Dietrick Institute for Applied Insect Ecology
Ventura, CA 93001
805-746-5365
1 Gunstone Tari, Cornelisse Tara, Klein Kendra, Dubey Aditi, Donley Nathan, Pesticides and Soil Invertebrates: A Hazard Assessment, Frontiers in Environmental Science, Volume 9, 2021, ISSN 2296-665X, https://www.frontiersin.org/article/10.3389/fenvs.2021.643847
2 Doreen Gabriel, Indra Roschewitz, Teja Tscharntke, Carsten Thies, 2006. Beta diversity at different spatial scales: Plant communities in organic and conventional agriculture, Eco App.
3 Doreen Gabriel, Steven M. Sait, Jenny A. Hodgson, Ulrich Schmutz, William E. Kunin, Tim G. Benton, 2010. Scale matters: the impact of organic farming on biodiversity at different spatial scales, Ecology Letters. https://doi.org/10.1111/j.1461-0248.2010.01481.x
4 https://www.frontiersin.org/articles/10.3389/fenvs.2021.643847/full Pesticides and Soil Invertebrates: A Hazard Assessment, 2021
5 One German study found that in both protected meadows and forests, the number of insect species decreased by about one third during the 10-year study period. Their total mass also decreased, especially in grasslands, by 67 percent. In the forests it shrank by about 40 percent. According to the researchers, the decline is presumably related to agriculture. Author Seibold emphasized that it was not enough just to maintain individual areas and retreats to combat insect decline. "To stop the decline, we need [...] greater coordination and coordination at regional and national levels," he said. "The study shows us that agriculture must be part of the solution," Joachim Rukwied, President of the Farmers' Association, argued.
6 One study in Canada showed losses among 62 imperiled species were significantly more closely related to rates of pesticide use than to agricultural area in a region. Species loss was highest in areas with intensive agriculture (aerial spraying).The authors concluded that either pesticides, or other features of intensive agriculture linked to pesticide use in Canada, played a major part in the decline of imperiled species (Gibbs et al 2009).
7 Pfiffner, L., Luka, H., 2003. Effects of low-input farming systems on carabids and epigeal spiders – a paired farm approach. Basic and Applied Ecology 4: 117-127.