Expendable Endangered Species

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Monarch Butterfly in my backyard flowers, Claremont, California. Photo: Evaggelos Vallianatos

EPA regulation by court orders

The New York Times reported that a judge ordered the US Environmental Protection Agency to do something about its failure to protect the endangered species from the toxic and lethal touch of an unbelievable number of petrochemicals in the armory of farmers. These poisons have been falsely called pesticides. They are synthetic chemicals designed to kill all forms of life. They are biocides.

The New York Times interviewed a senior EPA official who, like a public relations expert, explained the role of pesticides:

“When you think about what a pesticide is, it’s supposed to kill pests,” said Michal Freedhoff, assistant administrator for the agency’s Office of Chemical Safety and Pollution Prevention. “It is difficult to design a process where it kills only the things it is supposed to kill.”

Of course, this is beside the point. It’s impossible to design the perfect weapon. All weapons misfire. And who said we need pesticides to control all “unwanted” insects or weeds? Yet the New York Times is taking pesticides seriously, as if we cannot have food without them. It reports:

“In the same area as crop-damaging insects, there may be threatened bumblebees and butterflies; among unwanted weeds, endangered plants. At the same time, pesticides help farmers produce enough food to meet the demands of a growing population. And they need a wide variety of pesticides to defend their crops, they say, as insects and weeds gain resistance to various chemicals.”

True, pesticides have been made useless. They create infestations. Insects and weeds are rapidly evolving to fight back. EPA is no better in justifying its unenvious role. In a 2022 report, the EPA Office of Pesticide Programs summarized its “vision” and “mitigation strategies” of “balancing wildlife protection and responsible pesticide use.” According to the report:

EPA vision in 2022

“EPA has both an opportunity and a responsibility to address the decades-old challenge of how its Pesticide Program meets its obligations under the Endangered Species Act (ESA). In past decades, the Agency has met those obligations for less than 5% of the thousands of pesticide actions it completes annually under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The reasons for this failure are multifold, including the unusual complexity of ESA pesticide reviews. The entire process, including consulting with federal wildlife agencies to adopt protections, can take at least 4 years for a single pesticide and up to 15 years in rare cases. FIFRA requires that EPA reevaluate every pesticide every 15 years, including the hundreds that affect species listed under the ESA. ESA obligations also exist for many registrations of new pesticides, new uses of existing pesticides, and amendments to pesticide labels. In total, thousands of FIFRA actions will require an ESA review over the next decade alone. EPA’s Pesticide Program has been unable to keep pace with its ESA workload, resulting not only in inadequate protections for listed species but also litigation against the Agency that has increased in frequency in recent years. EPA has faced over 20 lawsuits, covering over 1,000 pesticide products, challenging its failure to meet ESA obligations. As a result, EPA’s current ESA priorities are driven almost entirely by litigation settlements and other court-enforceable deadlines. Over the next six years, existing court-enforceable deadlines will require EPA to complete ESA reviews for 18 pesticides— the most the Agency estimates it can handle during this period based on its current capacity and processes. And ongoing litigation and settlement discussions for other lawsuits cover dozens of additional pesticides and will likely fill the Agency’s ESA workload beyond 2030.… This situation creates significant uncertainty for farmers, other pesticide users, and pesticide registrants…. Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases. EPA’s Pesticide Program is at a critical juncture and needs a new vision.”

Back in time: same indifference for endangered species

This EPA rhetoric was like a time machine for me. It moved me back in time, starting in 1979 to 2004 when I finished my dangerous Odyssey in the land of American Laestrigonians and Cyclopes. In the early 1980s, I remember listening to an Ecological Effects Branch chief saying very similar things the EPA report admitted in 2022. How time consuming were the “ESA pesticide reviews,” how complex the process had become. But he also bemoaned reviews his staff had not done, or incomplete reviews for thousands of “pesticide active ingredients,” by which he meant the primary “tested” chemical stuff of the product. This was the nucleus that kills insects and weeds. Then he whispered the difficulties he would face in bringing up the bad news to the division director, program director, and then to the political appointee. The bad news was – and continues to be — that approving neurotoxic and carcinogenic pesticides / biocides would kill the endangered species, thus ignoring the protection demanded by the Endangered Species Act. This agony was very private. Bureaucrats, even those who had studied ecology, knew the only way forward at the industry-captured EPA, was the industry demand to approve their “petitions” for more pesticides. After all, as the New York Times and the EPA argue, who would want to complicate the hard work of the farmers “producing enough food for Americans and the world.”

Petroleum origins of pesticides

Imagine this unchallenged dogma. Poisons make food possible. Humanity has raised wholesome food for countless millennia without a drop of petrochemicals. Even today two-thirds of the population of the planet produce food without agrotoxins. But in modern times, oil men discovered easy money from digging up petroleum in early twentieth century. Pesticides came up from that manipulation of oil. Science was drafted to add credibility to this thoroughly dishonest effort to cover up the danger engulfed in the pesticide molecules that kill wildlife and poison the food people eat.

Poison Spring

I was so stunned and angry by what I learned working within the Office of Pesticide Programs of the US EPA for 25 years that I wrote a book. This was no office gossip tale but a national and global deception story. I called the book Poison Spring: The Secret History of Pollution and the EPA.

My story opened the Pandora’s box. I took a step beyond Rachel Carson and her timely and important 1962 book, Silent Spring. She said pesticides kill birds, hence potential silent spring. I said pesticides do much more than killing birds. They disrupt ecosystems, kill endangered species, corrupt EPA, and unsettle rural America. They put out of business small family farmers and enthrone large farmers over the land and people. In addition, they destroy life in the soil, thus tying America to a permanent dependence on petroleum and large machines. Climate chaos, however, makes it imperative that petroleum be banned in a few years. But how are Americans going to return to farming with poisoned soils?

Organophosphates: Nerve poisons still in use

The US District Court Settlement dated September 12, 2023, brought to light another unbelievable fact. Organophosphates, modified World War I chemical warfare agents used as insecticides. Yes, it’s unbelievable but true. These neurotoxins are still in the EPA and agribusiness playbooks. Indeed, the settlement is preoccupied considerably with the use of these chemical warfare toxins. We read this in the legal settlements: “No later than March 31, 2027, EPA commits to issue a draft Organophosphates Biological Evaluation, as well as provide notice and a 60-day opportunity for public comment on the draft Biological Evaluation.”

What about the endangered species?

No doubt, having so many “pesticide active ingredients” and so many vulnerable species spread all over the land, rivers, creeks, forests, wetlands, and the seas complicate matters.

“A major challenge for the E.P.A. in complying with the Endangered Species Act,” said the New York Times, “has been the sheer work of determining how each of the vast number of active chemicals in pesticides affects each of almost 1,700 federally protected species threatened with extinction.”

That is another reason why the use of pesticides is self-defeating. The government, that is, the EPA, and vast agribusiness delude themselves these chemicals are appropriate in vulnerable ecosystems and climate chaos-driven world.

The Court Settlement did not solve the incompatibility of thousands of extremely toxic chemicals blanketing millions of acres of land and forests and extremely useful but gravely threaten species. These two forces of death and life cannot be brought together. The Settlement is no more than a lipstick service and paperwork for both the EPA and the chemical companies churning out these poisonous products. Moreover, the Settlement is bound to make it even more difficult to ban these noxious chemicals from the environment and our lives.

This need not be the future. Organic farmers raise food without these neurotoxins and carcinogens. They protect endangered species and lessen the climate footprint of farming. With support from the government, organic small family farmers can slowly replace the toxic ways of large agribusiness. Rural America with organic farmers will become a new alive and prosperous land of wholesome food and culture.




Evaggelos Vallianatos is a historian and environmental strategist, who worked at the US Environmental Protection Agency for 25 years. He is the author of seven books, including the latest book, The Antikythera Mechanism.