Comment from Lish, Christopher

Sunday, July 19, 2026 Docket No. APHIS-2026-0628 Regulatory Analysis and Development PPD APHIS 5601 Sunnyside Avenue, #AP760 Beltsville, MD 20705 Subject: APHIS must overhaul its rangeland spraying program -- Environmental Impact Statements; Availability, etc.: Grasshopper and Mormon Cricket Suppression Program (Document ID: APHIS-2026-0628-0001) To Secretary of Agriculture Brooke Rollins and Animal and Plant Health Inspection Service Administrator Kelly Moore: Right now, the Animal and Plant Health Inspection Service (APHIS) has the opportunity to overhaul its highly controversial and antiquated Grasshopper and Mormon Cricket Suppression Program to reflect current ecological realities, comply with the law, meet the needs of the public, and protect our public lands. I urge you not to squander this opportunity by falling back on the old methods of relying on insecticides, inviting more controversy and litigation. "It is horrifying that we have to fight our own government to save the environment." -- Ansel Adams APHIS's program ignores the reality that grasshoppers and Mormon crickets are a vital part of the food chain and are essential for imperiled species like sage grouse. APHIS's program also fails to recognize that we're in the midst of an insect apocalypse. Once-common species like monarch butterflies and western bumblebees are now candidates for listing under the Endangered Species Act. Spraying insecticides causes direct and indirect harmful effects to many species, including ESA-listed species. Every federal agency has a duty to conserve ESA-listed species, but this program does the opposite. The law could not be clearer: APHIS is required to adopt an integrated pest-management approach where insecticides are a tool of last resort, and rather than spraying, it must focus its efforts on managing for a healthy, resilient, and diverse native ecosystem. APHIS's current proposal continues to unlawfully rely heavily on the old methods, mostly using insecticides and ignoring or dismissing other opportunities to creatively tackle complex land-management issues. "A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise." -- Aldo Leopold Impacts to people must also be properly addressed by APHIS. APHIS has been spraying on public lands that are deeply important to the public and popular with recreationists, including national wildlife refuges, wildernesses, wilderness study areas, national monuments, and busy recreation corridors. This must end. To date, most people have had no way of knowing whether an area has been (or will be) sprayed, causing great anxiety for local residents and recreationists. Americans are increasingly concerned about their chemical exposure, and the reality is that the Environmental Protection Agency, when registering pesticides, never does risk assessments for exposure to recreationists and the many non-target species impacted by APHIS's spraying. The EPA primarily looks at risks in agricultural settings. APHIS must commit to radical transparency about its actions, and stop being so secretive. If it has nothing to hide, then it must tell the public about its plans, even if that's inconvenient to the agency, and give the public opportunity to weigh in. Diverse stakeholders must be engaged, including Tribes, local residents, farmers, conservationists, recreationists, and members of the general public. APHIS must modernize its program to recognize that its way of doing business is just not working. I implore APHIS to seize this opportunity to overhaul its program, stop relying on insecticides and do better by the people and wildlife that rely on it. "The ultimate test of a moral society is the kind of world that it leaves to its children." -- Dietrich Bonhoeffer Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources. Sincerely, Christopher Lish San Rafael, CA