In addition to complying with pesticide regulations under FIFRA, which governs labeling and assessment for human health and environmental protection, U.S. EPA must also comply with provisions of the U.S. Endangered Species Act (ESA). The ESA requires any federal agency to consider the potential impact of its decisions on endangered species protection, and for EPA this means that pesticide registration and reregistration decisions are to be considered also for these impacts. Since ESA assessments for pesticides may involve not only EPA but also the US Fish and Wildlife Service (FWS) or National Marine Fisheries Service (NMFS) (together, the Services), scientific and policy approaches have not been fully agreed among these federal agencies. Environmental advocates have been dissatisfied with the progress made to date, and therefore have brought lawsuits against EPA and NMFS. In one of the most contentious of these litigation-based actions, involving protection of Pacific salmon, the NMFS developed an assessment requiring EPA to consider significant restrictions on use of chlorpyrifos and dozens of other pest management products. The Services’ preferred new restrictions as they relate to bodies of water – actually or potentially feeding into salmon habitats – would essentially prohibit the use of chlorpyrifos in large portions (176,000 square miles) of the states of California, Idaho, Oregon, and Washington.
Affected Crops and Economies
California produces nearly half of U.S.-grown fruits, nuts, and vegetables. Citrus would take a particularly hard hit, since 33% of the nation’s citrus – most of it in the form of fresh fruit – is produced in California, as is 77% of the country’s lemon crop.
Approximately 90% of all of the U.S.’s tree nuts – including virtually all of our almonds and walnuts – are produced in California, with an approximate value of close to $4 billion.
The affected areas in California also include the Sonoma Valley vineyards, which produces 90% of the nation’s wine grapes and virtually all of its raisin grapes, with a value of close to $162 billion.
California is also second in sweet corn production, after Florida.
Washington and Oregon
Washington is the U.S. leading apple producer and is second in pear production. Oregon produces most of the nation’s pears as well. In fact, apples and pears are the largest crops for each of those states, respectively. Both states also contribute significantly to wine grape production.
Finally, Idaho is among those states likely to be adversely affected by the proposed restrictions on chlorpyrifos use. Agricultural products contribute more than $3.9 billion to Idaho’s annual economy, many of which – although diverse – are nationally important. Sugarbeets, lentils, wheat, sweet cherries, and apples are among the crops for which Idaho is one of the top ten producers in the U.S.
Potential Challenges and Issues
Chlorpyrifos is part of several delicately-balanced, carefully-planned Integrated Pest Management (IPM) programs. In some cases alternatives to chlorpyrifos have been tried – and found severely lacking:
There is no comparable product available to farmers as a substitute for chlorpyrifos. If this product is not available, crop losses would be up to 50 percent from reduced yields. Specific example: A local grower submitted results of his attempt not to use the product on onions in the spring of this year. “Out of 1,500 acres planted,” [he wrote], “I lost 215.3 acres to bulb mite or soil maggots — I can’t stay in business with losses like that.” Replanting the lost acres cost this grower an additional $60,929.00.
Even where alternatives might be successful, the proposed plan and timeframe for adoption would not give growers enough time to adapt those alternatives into their IPM practices.
Unfortunately, the proposed restrictions could further result in over-reliance on more toxic substances, such as pyrethroids, which may have a greater negative impact on beneficial insects that are also part of IPM programs.