Pesticide Prioritization Process Workshop: 4/8/2025 - Taller de Priorización de Pesticidas del DPR 4/8/2025

Comment From: Neil Nagata

5/08/25 @ 7:46 PM

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Comment From: Sarah Aird

5/08/25 @ 6:34 PM

Please find attached comments from the statewide coalition Californians for Pesticide Reform on DPR's proposed SPM pesticide prioritization process.

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Comment From: Suzanne Hume

5/08/25 @ 5:34 PM

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Comment From: Mike Stanghellini

5/08/25 @ 4:12 PM

On behalf of the TriCal Group of Companies, please see the attached comment letter.

Thank you.

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Comment From: Renee Pinel

5/08/25 @ 4:07 PM

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Comment From: Kathleen Kilpatrick

5/08/25 @ 3:35 PM

pesticide prioritization process

Thanks for the opportunity to provide input into the development of the SPM's prioritization process. This key goal of the SPM Roadmap sets a goal of elimination, not continuous reassessment, not mitigation, not feas...↓ibility, not substitution with another inadequately-tested product. Those of us living in agricultural communities will need some convincing that the process will be fair, timely, and effective.

Now, when our federal government is attempting to dismantle DEI, California must hold the line on social and environmental justice. The recently launched notification project is a step in the right direction, but the list of chemicals is way too short, and from the viewpoint of workers and residents in agricultural communities, the steps around revisions and enhancements are much too slow.

For the transition to more sustainable agriculture, prioritization of chemicals to eliminate is a key step. Because of how widely and heavily they're used, it makes sense to put fumigants like1,3-D and chloropicrin at the top of the list, but there are other highly toxic pesticides not currently restricted.

You say you want the prioritization task to be data driven, yet you are relying on very limited monitoring data (as well as apparently imprecise methodology). The current process for assessment and mitigation is painfully slow. DPR has relied on priority lists that shift in order and number, and is already years behind schedule in reassessments and mitigations. Meanwhile, the science of pesticides and disease causation is rapidly changing, or has been prior to funding now being pulled by the current federal administration. And assessing one active ingredient at a time does not reproduce how doses of chemicals are delivered in the real world.

Here's the sequence and expedited timeline I'd like to see:
> Identify a list of at least 20 pesticides, or, preferably, group by pesticides with similar mechanisms of action and/or uses. (You could start with 10 if 20 is too many.)
> Let PCAs, growers, and manufactures know that these 10/20/groups will be under surveillance with plans for phase out.
> Add the chemicals/ groups of chemicals deemed highly hazardous and slated for elimination to the Restricted Chemicals list requiring SprayDays notifications.
> Support work on alternate practice practices and innovative products, non-toxic products with a focus on replacement of listed products.
> The goal: May the best management win! Use a sustainability matrix with the lowest toxicity weighted at least equally with the best costs and yields.
> Keep track using PURs and expanded and enhanced monitoring.
> Is use decreasing? Aim for zero ASAP, not by 2050. Since you'll be using AB 2113, you will need to show your progress to the legislature.
> And of course, the system should be set up with incentives for decreased use, and for development and promotion of least toxic best practices, real IPM, not product substitution.

While setting targets for elimination is important, this process MUST occur in the context of the holistic transition referenced in the SPM. Prime example: fumigants are toxic to humans, but they're also toxic to our soil. Prevention of pests and plant diseases is based on healthy soil, and ag chemicals and practices bad for our for soil and ecosystem health should be phased out ASAP. Farmers need support for the transition, and farmworkers and ag communities deserve to live, work, and go to school without fear of being poisoned.

That's the goal of SPM: decreased use of toxic chemicals overall, increased resilience and equity in our ag and pest control systems, as well as elimination of priority pesticides. All actions taken should be in furtherance of that goal.

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Comment From: Allison Johnson

5/08/25 @ 3:33 PM

Please see comments of the Natural Resources Defense Council attached. These comments are submitted by the organization, but only "Individual" is available in the "Submitted By" drop-down menu.

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Comment From: Abby Taylor-Silva (behalf of group)

5/08/25 @ 3:14 PM

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Comment From: Jenny Broome

5/08/25 @ 3:10 PM

Scientific advisory committee should have someone with a medical (MD) and epidemiology (MPH) advanced degrees, not just someone working in public health as it seems is currently stated.

Additionally, a researcher with experience developing real wor...↓

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Comment From: Tim McPherson

5/08/25 @ 2:37 PM

See attached correspondence.

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Comment From: Lorien Fono

5/08/25 @ 2:32 PM

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Comment From: Roberta Firoved

5/08/25 @ 2:30 PM

Comments from the California Rice Commission.

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Comment From: Joe Coelho

5/08/25 @ 1:54 PM

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Comment From: Hillary Thomas

5/08/25 @ 1:46 PM

California Department of Pesticide Regulation
May 8, 2025

RE: Pesticide Prioritization Process & Scientific Advisory Committee

I am writing this letter on behalf of Naturipe Berry Growers (NBG), we thank you for the opportunity to submit commentary...↓ on CDPR's Pesticide Prioritization Process. NBG is a California headquartered company founded in 1917, the oldest and one of the largest strawberry grower-shippers in North America. I am also a professional entomologist and IPM specialist who cares deeply about the protection of biodiversity, human health, and agriculture's critical role in food security.

The California Strawberry industry supplies ~90% of the nations fresh strawberry fruit on less than 1% of California's farmland with some of the highest household penetration levels of any produce – in short we are feeding the nation healthy nutritious food through a highly efficient supply chain. Strawberry and other specialty crops in this region have very narrow soil and climatic requirements, limiting acreage to the central coast California counties of Monterey, San Luis Obispo, Santa Barbara, Santa Cruz, and Ventura. Every year strawberry is reported as the most important crop for these county's local economies. Prime production regions face encroachment from urban expansion, threats from existing compliance regulations, and exorbitant rising costs of production.

At the same time, we recognize that strawberries are a crop with heightened susceptibility to disease and insect pest issues that can be devastating to our crop, which necessitates the use of a broad range of tools. Therefore, the industry is an important stakeholder in next steps for pesticide prioritization towards our shared sustainable future. In my 16+ years of conducting research in the trenches with the industry towards the adoption of next generation tools for pest management, it is clear that the industry shares and invests in CDPRs mission and vision to conduct pest management that is safe, effective, and sustainable for all Californians, despite any outside perception otherwise.

It is critical that we collectively land on a process that is evidence-based, scientifically supported, results in the intended impacts through measurable outcomes, and is feasible for all stakeholders to implement. A fair constitution of the Scientific Advisory Committee members will be imperative for us to come to an outcome that is collaborative, meaningful and impactful for all California stakeholders. I respectfully ask that CDPR consider including a member on the Advisory Committee who is well versed in the intricacies of commercial strawberry production beyond just pathology or entomology, and who has a comprehensive understanding of the industry's needs without bias in either direction. That is, candidates who have a conflict of interest in promoting new pest management tools through investment or other business endeavors should not be considered, as no candidate who has investment in the strawberry business would likely be considered either. Bias goes in both directions.

Thank you for your consideration of these additional comments. We support CDPRs efforts towards a holistic, whole-system approached believe that there are viable pathways towards an optimized outcome with efficient use of limited resources. The program will be successful if not greenwashed, and if industry allies can be at the table and work collaboratively on next steps in the development of this policy.

Sincerely,

Hillary Q. Thomas-Sanchez, Ph.D.
Research & Technical Director
Naturipe Berry Growers

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Comment From: Michael Mellano

5/08/25 @ 1:33 PM

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Comment From: Theresa Dunham

5/08/25 @ 12:10 PM

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Comment From: Dillon Gabbert

5/08/25 @ 10:26 AM

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Comment From: Catherine Dodd PhD RN

5/07/25 @ 11:53 PM

Please see attached comments from FACTS Families Advocating for Chemical And Toxics Safety

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Comment From: Karen Newton

5/07/25 @ 4:17 PM

On behalf of the Sacramento River Source Water Protection Program (SRSWPP), thank you for the opportunity to review and comment on DPR's proposed Pesticide Prioritization Process, as presented in DPR's workshop held on April 8, 2025. The City of Sacr...↓

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Comment From: Karen Cowan

5/07/25 @ 1:06 PM

Please see attached comments from the California Stormwater Quality Association.

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Comment From: Anna Maria Roy

5/07/25 @ 12:09 PM

Please do your part to try to outlaw pesticides like RoundUp. They cause cancer and are bad for the earth. Please regulate more and not less. While our state is a leader with agriculture, let us also be a leader with less toxic methods of going after...↓

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Comment From: Amrith Gunasekara

5/06/25 @ 8:59 AM

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Comment From: Sacramento Stormwater Quality Partnership Anonymous

5/02/25 @ 12:00 AM

Submitted by Lisa Moretti

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Comment From: Anonymous Anonymous

4/21/25 @ 7:03 AM

Your mission and vision statements are quite false. I rewrote them for you to reflect the truth, which you either know or are not accepting due to educational programming and/or job benefits.

Revised statements:
MISSION: We HARM human health and ...↓

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Comment From: Todd Fukuda

4/08/25 @ 6:01 PM

The committee should have a member from UC Agricultural Research, hopefully from the Kearney Ag Center

I hope commodity groups affected, chemical companies, Ag Commissioners be alerted to any changes. Something more substantial than the failed roll ...↓

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Comment From: Anonymous Anonymous

4/08/25 @ 5:45 PM

I attended this "workshop" by zoom today. My comments and questions were totally ignored that I submitted thru the Q&A chat. So we have to wonder how many other questions or comments were ignored. Also, if our feedback here is not public, it should ...↓

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Comment From: Lorenzo Rota

4/08/25 @ 3:42 PM

I would like the CA DPR to consider removing the application of beneficial insect by unmanned drones from the regulations for Unmanned Pest Control Applicatoin Pilot.
The US federal part 137 Agricultural Operations regulatoins specifically exempt the...↓

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Comment From: Bob Mackie

4/08/25 @ 3:15 PM

Will there be prioritization based on the potential harm of the targeted pest? Would certain chemistries that may not be applicable in sensitive sites be permitted as part of Early Detection Rapid Response programs where the potential harmful impact ...↓

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Comment From: SHAUN BROWN

4/08/25 @ 2:11 PM

Thank you! I read the work you're processing and going forward with, and I believe you will succeed in keeping us healthy. Being proactive, makes me really proud to be a Californian!

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Comment From: Judith Arroyo

4/08/25 @ 10:55 AM

Sodium Hypochlorite (antimicrobial) is a pesticide, widely available to all consumers in California and based on my field of work the most pervasive cause of childhood exposure particularly to non-English homes. If we are indeed Evaluating Risk X Exp...↓

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