VASCM: Fwd: COMMENTS DUE MONDAY | Ag Order 4.0

[Bill Cooper]

Thanks,
Bill

Begin forwarded message:

From: "Kris Beal, Vineyard Team" <kris at vineyardteam.org>
Date: June 19, 2020 at 10:22:23 AM PDT
To: Bill Cooper <bill at cgv.com>
Subject: COMMENTS DUE MONDAY | Ag Order 4.0
Reply-To: kris at vineyardteam.org


[http://r20.rs6.net/on.jsp?ca=930a210d-5bf5-43fe-8554-72771b08e906&a=1101092730768&c=0d424e20-dd9d-11e3-9e79-d4ae5275509e&ch=0dd120a0-dd9d-11e3-9eb5-d4ae5275509e]





Written comments are due MONDAY, June 22, 2020 by 11:59 PM

This draft is NOT business as usual and will require costly and burdensome reporting requirements for vineyard operators, including SIP Certified operations.

NOW is the time for you to act. We need as MANY INDIVIDUAL letters as possible to influence this document.

Below are guidelines to help with your letters.

Written comments are due MONDAY, June 22, 2020 by 11:59 PM

Submit: AgNOI at waterboards.ca.gov<mailto:AgNOI at waterboards.ca.gov>
Subject Line: “Comments on Draft Ag Order”
BCC: kris at vineyardteam.org (so I can track progress)


Thanks in advance,

Kris Beal, Executive Director

Consider these points a starting point for your comments - use the ones that matter to you the most. Add additional comments if you’d like. CUSTOMIZE as much as possible. Your letter does not have to be long - any comment is better than no comment. Reorganize if appropriate - if you’re SIP Certified, feel free to move that section towards the top, for example.

AG ORDER 4.0

WRITTEN COMMENTS DUE
June 22, 2020 by 11:59 PM

EMAIL:  AgNOI at waterboards.ca.gov<mailto:AgNOI at waterboards.ca.gov>

SUBJECT LINE: “Comments on Draft Ag Order”

BCC: kris at vineyardteam.org<mailto:kris at vineyardteam.org>

NOTE: Your comments can be in a letter format (attached to the email) or in the email body. Please include your name and contact information is included in either format.

June XX, 2020

Matthew T. Keeling, Executive Officer
Central Coast Regional Water Quality Control Board
895 Aerovista Place, Suite 101
San Luis Obispo, CA 94301

Delivered via electronic mail to AgNOI at waterboards.ca.gov<mailto:AgNOI at waterboards.ca.gov>

Dear Executive Officer Keeling:

Information on Your Operation:

  *   Location, Acres
  *   Farming practices that protect water quality (low applied irrigation, low applied nutrients, nutrient budgets to determine efficient nutrient rates, pest management, keeping pesticides on site, reducing/minimizing storm water runoff, cover cropping, erosion control)
  *   Participation in sustainability programs (SIP, VT membership, tailgates, research projects)
  *   Communicate commitment to protect surface and water quality - you live in the region, have family in the region, and rely on water for your farming operation

Current Draft is Complex & Burdensome without Providing a Benefit to Water Quality

  *   The current Draft, EIR, and Attachments are long (900 pages), complicated, and confusing with different reporting and timelines for different constituencies.
  *   While the staff outreach webinars did a good job of explaining the priority areas in their outreach webinars, details on the annual reporting were insufficient. If the annual reporting can not be described in a 2 hour webinar, then the content of those requirements should be seriously reconsidered.
  *   The reporting is overly burdensome, expensive for growers and staff, and will not improve water quality.
  *   Furthermore, the extent and scope of information required is so great, that it is doubtful that staff could analyze and act on the information in a meaningful and timely way to feedback to growers to improve water quality.
  *   In addition, the Draft’s economic analysis is fully insufficient and does not account for land fallowing, hiring professionals, loss of production, and several other costs associated with the grower requirements of this Draft.
  *   <OFFER SPECIFIC INFORMATION ON THE COSTS TO YOU TO COMPLETE ANNUAL REPORTING, IMPLEMENT PRACTICES, HIRE PROFESSIONALS TO DEVELOP PLANS, CREATE BUFFER AREAS>

Current Draft Priorities and Phases Ignores Low Risk Operations

  *   Draft only considers geographic location and not operational risk to water quality. All growers are required to complete all reporting (eventually, and in compressed phasing timelines) regardless of operational risk.
  *   Vineyards are a low risk to water quality and should be handled separately regarding monitoring and reporting.
  *   Vineyards currently meet the 2050 Nitrogen Loading threshold and should be exempted from monitoring and reporting related to groundwater. (offer specific information for your operation)
  *   Vineyards do not have tailwater and maintain winter cover, therefore their monitoring and reporting should reflect that operational risk (offer specific information for your operation)
  *   Vineyards have existing buffer zones to allow for equipment passage and turnaround. Removing vineyards to expand the buffer will disrupt the soils and provide an increased risk to water quality. (offer specific information for your operation, including any loss of productive land due to increased buffers around riparian areas). (For information on setbacks and locate your vineyard on the maps >> https://gispublic.waterboards.ca.gov/portal/apps/View/index.html?appid=02ac0fe36a544511b498783a8a9a585c<http://r20.rs6.net/tn.jsp?f=001qo5En9kwNy9gQzlP17eyYMEVw5HMS3qjPk3QnHvhNmW2JY_bol0tE2cWvcpqr0P7tJcLdsYi3Y0JFBSYLNMeyoDbScEwbhfokOMn_psG3LeczULYpAEmkpiRTUyXyHQHl-LNsjvz3YlJ5eoKST74CSfJyvnzx1IBMgRdfmyXzl150CrDTGJ5wBdzsqSKvF8j6CF5n7XxGPAiObU85rkFW3vehCGFkbQ584E_WH3dezDV6hNdrIvD7gIWJcNxOPZM-VCTnbYWFRA=&c=qcTeRVrUq1GYpd-cZ5sWZ9alq4nx-P0OYgc9pDW9U4LUxnQRfSB0fg==&ch=vr4bGHs2FZwUK7XD8jSS-I6bptdSDIiMtZBE2PTamhvG5qv7mrOuqQ==> )

SIP Certified Should be Recognized as an Alternative Compliance Pathway and Current SIP Documentation Should be Recognized in Lieu of Farm Planning Requirements

  *   <Insert your experience with certification - practices, documentation, costs associated with SIP Certified>
  *   As currently written, SIP Certified would not qualify as 3rd party. The framework of the requirements for a 3rd party imply a program that itself monitors water quality, rather than a program that certifies implementation of practices, water/nutrient budgeting, etc.
  *   If staff intends for a certification program to quality, these requirements must be edited.
  *   SIP Certified operators should have an alternative Annual Compliance process to avoid duplicative documentation.
  *   SIP Certified operators are required to implement practices that protect water quality and are verified by an independent inspector.
  *   SIP Certification Documentation (Irrigation, Nutrients, Erosion, Pest, Riparian) should be recognized in lieu of Farm Plans.
  *   SIP Certified operators, who are required to complete GW testing, should be allowed for this to be recognized without requiring additional analyses.
  *   SIP Certified operators, who are required to complete irrigation and nutrient reporting, should be allowed for this to be recognized without additional reporting.
  *   SIP Certified operators are required to have a set back from blue-line streams and should be exempted from additional riparian requirements
  *   SIP Certified operators are required to have an erosion plan and implement several winter erosion practices, this should be recognized without additional work.

Closing
I encourage staff to consider modifying this draft to consider alternative compliance for low risk vineyards, leveraging current successful efforts, such as SIP Certified, and creating a framework that incentivizes adoption of practices that protect water quality by reducing the regulatory requirements. These changes would reflect the direction from the Board over the last several years in addition to vineyard stakeholders who are affected by this Order.

Sincerely,

Name
Affiliation
Contact Information















Vineyard Team | 5915 El Camino Real, Atascadero, CA 93422
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