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From: abraomorenimwen@everyactionadvocacy.com <abraomorenimwen@everyactionadvocacy.com> <br />Sent: Thursday, November 16, 2023 6:53 AM <br />To: 2Mayor <2MAYOR@riversideca.gov> <br />Subject: [EXTERNAL] Please protect our health and environment by adopting policies that support organic land <br />management! <br />Dear Mayor Patricia Lock Dawson, <br />As shown by the recent court decision overturning EPA's attempt to cancel agricultural uses of chlorpyrifos, the <br />pesticide regulatory process is broken and cannot protect people or the environment from the dangers of their <br />use. As a result, we need policies at the state and local level that move towards organic land management in <br />agriculture, communities, and homes. <br />EPA's action to cancel all agricultural uses of chlorpyrifos was a rare instance when the agency took protective <br />action. Required by a 9th Circuit Court of Appeals decision in April 2021 to take action, EPA issued a final rule <br />in August, 2021—in full effect February 28, 2022—after an earlier 9th Circuit decision, concluding that, "EPA is <br />unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety <br />standard of the Federal Food, Drug, and Cosmetic Act (FFDCA). Accordingly, EPA is revoking all tolerances <br />for chlorpyrifos." On November 3, the 8th Circuit U.S. Court of Appeals decided to vacate EPA's 2021 decision <br />to cancel all food tolerances for chlorpyrifos and sent it back to the agency. <br />In other cases, EPA has avoided such litigation by taking more limited action. When the industry challenges <br />EPA, the agency almost invariably capitulates, as in the case of paraquat, when EPA allowed an industry <br />umbrella group dubbed the Agricultural Handler Exposure Task Force to correct its data risks posed to <br />workers, resulting in the agency changing its position in months. <br />The examples of this pattern are numerous, and even when EPA suspends the registration of a pesticide, <br />removal from use is very slow because existing stocks are generally allowed to be sold. For example, EPA <br />suspended the registration of the herbicide dimethyl tetrachloroterephthalate (DCPA) (also widely known as <br />Dacthal), effective August 22, 2023, leaving existing stocks (products containing DCPA manufactured before <br />August 22) available on the market. <br />History shows the failure of the "whack -a -mole" approach to pesticide regulation. <br />Many communities are already adopting organic land management in parks, playing fields, and other public <br />lands. Beyond Pesticides parners with major retailers like Natural Grocers and Stonyfield Organic, and dozens <br />of communities in all regions of the country to see this vision come to life. Natural land care is becoming <br />increasingly popular at the local level, with more and more communities looking to employ practices that <br />protect workers, public health, pets, pollinators, and unique local environments that can be harmed by <br />unnecessary pesticide use. At the same time, community leaders are increasingly challenged with staffing <br />constraints and tight budgets. Beyond Pesticides' Parks for a Sustainable Future program aims to bridge these <br />gaps, allowing communities to pilot the transition to organic land care on two public sites. <br />Program pilot sites provide local land care officials the time needed to dial in new practices and work out any <br />unexpected factors that may impede the move from conventional to organic land care. They send a message <br />to residents that the community is taking meaningful action to protect their health and environment, at a lower <br />1 <br />