A Review of --
The new report from the Henry A. Wallace Institute for Alternative Agriculture by Edward Jaenicke begins with the passage --
While some people like and others loathe the compromises struck in the FQPA, the fact is that the FQPA settles a fifteen year debate over the standard applicable to setting pesticide residue tolerance limits. Its basic provisions are outlined elsewhere on this page, on the EPA's website and elsewhere. EPA faces an enormous task in implementing the FQPA's new "reasonable certainty of no harm" standard to some 9,000 tolerances. Complex new risk assessment issues also have to be confronted in order to implement the FQPA's common mechanism of action and cumulative exposure provisions. The devil will be in the details and most will be hard-fought and disputed by one side or the other, but the likely outcome is clear -- markedly lower tolerance levels for many food uses of most conventional insecticides and fungicides, and those herbicides that appear commonly in drinking water (which is part of the diet, and hence subject to FQPA review).
Despite the fact that the FQPA reduces the importance of benefits in pesticide regulatory decision-making, Jaenicke is right in anticipating that much of the public debate over FQPA implementation is likely to focus on the costs of the new act. His useful new report provides the reader a clear explanation of common methodological shortcomings in most past benefits assessments, shortcomings bound to be replicated in many future studies. Hence the importance of encouraging widespread attention to Jaenicke's report.
The report points out that most past benefits assessments under-estimate the adaptive capacity of the American farmer. They are based solely on projections of the loss of "benefits" as farmers switch from pesticide X under regulatory review, to next best registered pesticide alternative Y. The "costs" of regulation equal the projected change in crop yields, times price per unit of crop harvested, plus any change in pesticide purchase and application costs.
Jaenicke properly points out the many missing ingredients in the equation -- most prominently the capacity of farmers to innovate through adoption of biologically based IPM systems. His point will be even more important in the future, since scientific breakthroughs continue to pave the way for progress along the IPM continuum, in part facilitated by the many new biopesticides that are now gaining registration. Farmers have new knowledge, tools and experience to draw upon in weaning themselves from excessively pesticide dependent systems, and that is just what a growing number are doing. As they gain confidence in new tools and approaches, and share insights gained, the pace of innovation will accelerate and the "costs" of removing high-risk pesticides from the market will quickly fall to less than zero.
A new pesticide "benefits" assessment challenge is on the horizon -- developing the analytical tools and knowledge-base needed to project the economic benefits that will follow regulatory restrictions on pesticides that are now seriously impairing the health and diversity of soil microbial communities and above-ground biodiversity. Several recent studies have demonstrated the potential to enhance farm productivity and profitability through building soil health -- an inherently biological process that requires, among other things, a reprieve from recurrent treatment with pesticides highly toxic to most life forms within soil biotic communities.
As farmers back off hot OP and carbamate insecticides and fumigants, their soils will begin to recover and food webs and chains will grow more complex, both setting the stage for more efficient nutrient cycling, more healthy root development and growth, and suppression of many common diseases. In time, these positive externalities from reducing pesticide use will far exceed the temporary costs of the transition away from pesticide-dependent systems. Agricultural economists need to start building into their pesticide benefits assessments parameters that capture these changes in soil quality and productivity, and are well advised to read Jaenicke's new report for a solid set of suggestions on how to move toward more accurate and meaningful measurement and assessment tools.