CountyWidePlan - AG Comment on CWP @GB 4-1-04%SC-CWP -AGAtt…

John Nygren

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“Agricultural Atachment” to Sierra Club-Marin Group commentson CWP’04Uses allowed by the proposed Countywide Plan (CWP) in the StreamConservation Areas (SCAs) include that noted on page 2-29: “Agricultural uses that do not require the removal of woody riparian vegetation and do not involve animalconfinement within the SCA.” The Sierra Club–Marin Group wishes to begin ourcomment on this section of the CWP with a quote regarding grazing impact to riparianareas from RIPARIAN AREAS: Functions and Strategies for Management © 2002 bythe National Academy of Sciences, pages 168-169:Primary grazing effects include the removal of vegetation, trampling of vegetation,destruction of biological soil crusts, compaction of underlying soils, redistribution ofnutrients, and dispersal of exotic plants species and pathogens. Secondary effectsinclude altered disturbance regimes associated with hydrology (runoff and infiltrationrates and water holding capacity) and fires (frequency and severity), acceleratederosion, altered competitive relationships among organisms, and changes in plant andanimal reproductive success and/or establishment of plants. The disproportionateimpact of livestock on riparian areas is a product of both management and animalbehavior….catle in particular congregate in riparian areas and other wet areas because of the water, shade, and more succulent forage, spending from 5 to 30 moretimes in these cool, productive zones than would be predicted from ...

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“Agricultural Attachment”to Sierra ClubMarin Group commentson CWP’04

Uses allowed by the proposed Countywide Plan (CWP) in the Stream Conservation Areas (SCAs) include that noted on page 229: “Agricultural uses that do not require the removal of woody riparian vegetation and do not involve animal confinement within the SCA.”The Sierra Club–Marin Group wishes to begin our comment on this section of the CWP with a quote regarding grazing impact to riparian areas fromRIPARIAN AREAS:© 2002 byFunctions and Strategies for Management the National Academy of Sciences, pages 168169:

Primary grazing effects include the removal of vegetation, trampling of vegetation, destruction of biological soil crusts, compaction of underlying soils, redistributionof nutrients, and dispersal of exotic plants species and pathogens. Secondary effects include altered disturbance regimes associated with hydrology (runoff and infiltration rates and water holding capacity) and fires (frequency and severity), accelerated erosion, altered competitive relationships among organisms, and changes in plant and animal reproductive success and/or establishment of plants.The disproportionate impact of livestock on riparian areas is a product of both management and animal behavior….cattle in particular congregate in riparian areas and other wet areas because of the water, shade, and more succulent forage, spending from 5 to 30 more times in these cool, productive zones than would be predicted from surface area alone.

The grazing of riparian areas by domestic livestock involves the periodic removal of native streamside vegetationparticularly herbaceous plants, shrubs, or young trees. Over 95 percent of the studies reviewed by Platts (1991) showed ‘stream and riparian habitats had been degraded by livestock grazing, and that these habitats improved when grazing was prohibited’In Ohmart’s (1996) view ‘unless grazing management changes are made soon, it is predictable that many more species, especially neotropical birds, will be placed on the endangered species list.’Of the 76 federally listed plant and animal species on the Bureau of Land Management (BLM) lands for which livestock grazing was a significant factor in their decline, approximately 80 percent were dependent on or associated with riparian habitats (Horning, 1994)

Both the current and this proposed CWP allow continued grazing in the SCA. The current CWP includes a mitigation of a fencing fund to help pay for fencing on private land, the idea being that to put substantial SCA fencing costs on current ranchers would unfairly and unduly burden the viability of working ranches (and thus lead to their conversion to residential use).There has, however, been no measure made of how effective this mitigation has been.

In addition to this existing unmeasured impact, the new CWP encourages diversification to entirely new agricultural uses (rowcropping).Unlike grazing, there is little cost to keep rowcropping out of SCAs. To keep livestock outside the SCA requires the rancher to fence; to keep rowcropping out of the SCA simply requires the rancher simply to turn the wheel of the tractor at the appropriate spot.Substituting ("diversifying") row cropping in a SCA in the place of grazing in a SCA is not just a continuation of agriculture; it is a fundamentally different activity with environmental impacts significantly increased over the already significant impacts of grazing in SCAs.The

following is another quote fromRIPARIAN AREAS Functions and Strategies for Management © 2002 by the National Academy of Sciences Pg 161163:

Nationwide, agriculture is probably the largest contributor to the decline of riparian area quality and functioning (Dillaha et al, 1989).Because some of the most fertile soils are often located in riparian areas, there is an economic incentive for their conversion to cropland. Theseareas are also convenient sources of water for irrigation of adjacent cropland and, as previously discussed, excessive water withdrawal from streams lowers water tables and causes significant change to riparian area structure and functioning. Innonforested areas, there can be a tendency to encroach into the riparian area each time the field is plowed in an attempt to gain more cropland.Natural riparian areas are sometimes viewed as a potential source of plant and animal pests, as source of shade that may reduce crop yields, and competition for scarce water resources. Under natural settings, riparian vegetation protects the soil surface, and soil fauna and flora are constantly creating macropores, which maintain high infiltration and percolation rates.

When land is converted to agricultureparticularly row crops vegetative cover is reduced, which exposes soil to raindrop impact and surface sealing, thereby decreasing infiltration.Although agricultural tilling does help to maintain porosity in soil, which promotes infiltration and percolation, it does not do so to the extent achieved by undisturbed populations of soil flora and fauna.The machinery used in tilling can also compact soils. Together, these practices alter hydrology by increasing overland flow volumes, peak runoff rates, and potential pollutant delivery to riparian area… The increased overland flow over agricultural lands promotes relatively high erosion rates…agricultural chemicals (both pesticides and fertilizers) in overland flow can also negatively impact fauna and flora located in riparian areas and downstream receiving waters [and] can cause nutrient losses from the land to nearby streams to increase by an order of magnitude or more.

This draft CWP, by repeatedly encouraging diversification, rowcropping, protection of good soils, and water development for agriculture is opening the door to a potentially huge environmental impact.Under the draft CWP, fences put in as mitigation for allowing grazing in the SCA’s could be pulled out to gain access to the good soils and water resources adjacent to streams.No cultivation setbacks are proposed yet; Marin County Ag lands contain some of the most highly erodible soils in the world.Tomales Bay, the receiving water at the base of the watershed that constitutes over 50% of Marin County's land, has been declared impaired for sediment by RWQCB.The Town of Tomales used to be a seaport until the potato farming of a prior generation filled in its access.

For comparison, both Napa and Sonoma Counties have ordinances that mandate cultivation setbacks based on slope.The Napa County cultivation setback for slopes less than 1% is 35 feet; at a1%5% slope, the setback moves to45 feet; at a 5%15% slope, the setback is 55 feet; at a 15%30% slope, the setback is 65 feet; at a 30%40% slope, the setback is 85 feet; at a 40%50% slope, the setback is 105 feet.Sonoma County setbacks for slopes less than 15% are 25 feet; the cultivation setback for slopes 15%50% is 50 feet. InSonoma, cultivation is prohibited on slopes over 50%; highly erodible soils with slopes over 10% must submit an erosion control plan; and other soils

with slopes over 15% must submit an erosion control plan. These erosion plans are enforced.Sonoma County has prosecuted several growers for illegal cultivation that caused erosion, specifically the owner of "Grandi" building in Pt Reyes Station.

The notion that organic farming somehow avoids all of these impacts is completely unwarranted.Many of the riparian function impacted are physical functions that would be the same regardless of organic certification.The County study for the Warren Weber property indicated that the conversion from grazing to rowcropping could increase sediment delivery to Bolinas Lagoon by a factor of 400%.Many of the “organic” applications, while protecting human health, can, if used close to streams without adequate riparian buffers cause significant negative impacts.Synthetic substances allowed for use in organic crop production per National organic Law § 205.601 include:Alcohols, Ethanol, Isopropanol, Calciumhypochlorite, Chlorine dioxide, Sodium hypochlorite, Hydrogen peroxide, Peracetic acid.Even plain old soapy water runoff into salmonid stream kills endangers species.Organic fertilizers can also have impacts. Inthe Redwood Creek watershed, for example, a major concern in designing the Big Lagoon restoration is possible hypoxic conditions (“dead zone” conditions as in the Gulf of Mexico at the outflow of the Mississippi) caused by the large nutrient load (albeit from organic fertilizers) flushing into the Green Gulch streams and then into the Lagoon area.

The proposed CWP's advocacy of diversification without commensurate protection of riparian areas and wetlands on ag lands is a recipe for environmental disaster.On the other hand, there is an environmentally benign approach to agricultural that is represented by the Wild Farm Alliance (www.wildfarmalliance.org). Theplatform of the Wild Farm Alliance is titled:

Agriculture & the Biodiversity Crisis: Reconnecting our Food Systems and Ecosystems

Recognizing that: ► the current rate of species extinction signifies an unprecedented biodiversity crisis. ► industrial agriculture is a primary cause of species losses and a devastating threat to sustainable familyscale farms and ranches. ► protected and interconnected wildlands are essential to assuring biological diversity and sustaining healthy rural landscapes. We believe: ► agriculture must be conducted in ways that are compatible with preservation of native plants and animals. ► sustainable family farms and ranches nourish healthy human communities and help safeguard natural communities. ► the current biodiversity crisis calls for a new conservation ethic that promotes ecological recovery within agricultural lands and across the entire landscape. We acknowledge: ►healthy ecosystems provide us with many lifegiving services, including pollination, insect pest control, nutrient cycling, clean water, and

control. ►the need of farmers to succeed economically while farming ecologically. ►the right of farmers and indigenous peoples to maintain control over sustainable food production. ►the right of consumers to know how and where their food is grown, and ►the responsibility of consumers to support ecologically sound agriculture. We support: ►farming practices that accommodate wild habitat and native species, including large carnivores and wild fish. ►local and regional food and fiber systems that boost rural economies. ►agricultural practices that strive to eliminate the use of environmentally toxic chemicals and contamination of soil and water resources. ►locally adapted crops and animals that are not genetically engineered. ►existing communitybased efforts to create a continental wildlands network in which large protected areas are connected by wildlife movement and complemented by ecologically managed farms and forests.

We urge the County to rethink the appropriate balance between agriculture and protection of sensitive habitats represented by this draft CWP.The Sierra Club Marin Group supports the efforts to improve grazing practices in Marin.We will also support diversification as a method to enhance farm incomes and sustain agricultural operations…nothowever at with its unlimited threat to sensitive habitats. Weneed to make sure the grazing fencing programs are working and we need cultivation setbacks for row cropping.For specific recommendations, please see our main comment document.

For your information, the following organizations have endorsed the Wild Farm Alliance Platform

Sustainable Agriculture Organizations: California Certified Organic Farmers Foundation www.ccof.org Center for Urban Agriculture at Fairview Gardens www.fairviewgardens.org Collective Heritage Institute/Bioneers Conference www.bioneers.org Community Alliance with Family Farmers www.caff.org Ecological Farming Association www.ecofarm.org Institute for Agriculture and Trade Policy www.iatp.org Land Institute www.landinstitute.org Land Stewardship Project www.landstewardshipproject.org Native Seeds/SEARCH www.nativeseeds.org Nebraska Sustainable Agriculture Society www.nebsusag.org Organic Consumers Association www.organicconsumers.org Organic Trade Association www.ota.com Practical Farmers of Iowa www.pfi.iastate.edu SalmonSafe www.salmonsafe.org Western Sustainable Agriculture Working Group www.westernsawg.org Women, Food & Agriculture Network www.wfan.org

Conservation Organizations Audubon California www.audubon.ca.org Bat Conservation International www.batcon.org California Wilderness Coalition www.calwild.org

Center for Biological Diversity www.swcenter.org Conservation Biology Institute www.consbio.org Deep Ecology Resource Center Defenders of Wildlife www.defenders.org Kettle Range Conservation Group www.kettlerange.org Methow Conservancy www.methowconservancy.org Mountain Lion Foundation www.mountainlion.org Natural Resources Defense Council www.nrdc.org Open Space Alliance of Santa Cruz www.santacruzosa.org Predator Defense www.predatordefense.org RESTORE: The North Woods www.restore.org Sierra Clubwww.sierraclub.org Sky Island Alliance www.skyislandalliance.org The Wildlands Project www.twp.org United Plant Savers www.unitedplantsavers.org Utah Environmental Congress www.uecutah.org Ventana Wilderness Alliance www.ventanawild.org Xerces Society www.xerces.org

Education and Advocacy Organizations ALBA (Agricultural & LandBased Training Association) www.albafarmers.org Center for Ethics and Toxics www.cetos.org Center for Food Safety www.centerforfoodsafety.org Council for Responsible Genetics www.genewatch.org Dietrick Institute for Applied Insect Ecology www.dietrick.org Diocese of Jefferson City, Missouri, Social Concerns www.diojeffcity.org Earth Pledge www.earthpledge.org and www.farmtotable.org EarthSave International www.earthsave.org Friends of the Earth www.foe.org Global Exchange www.globalexchange.org International Society for Ecology and Culture, USA www.isec.org.uk Keeping Track www.keepingtrackinc.org Long Branch Environmental Education Center main.nc.us/LBEEC Northwest Coalition for Alternatives to Pesticides www.pesticide.org Occidental Arts and Ecology Center www.oaec.org Pesticide Action Network North America www.panna.org Union of Concerned Scientists www.ucsusa.org White Earth Land Recovery Project www.welrp.org

Selected Farms, Ranches & Businesses Buchanan Family Century Farm www.tyeewine.com Greensward Nurseries www.newnatives.com Keep Tryst Farm Hedgerow Farms www.hedgerowfarms.com New Leaf Community Markets www.newleaf.com Thirteen Mile Lamb & Wool Co. www.lambandwool.com T.O. Cattle Company www.morrisgrassfed.com Literature, Media and Publications Clapperstick Institute www.heydaybooks.com Food and Farming Forum Watershed Media www.watershedmedia.org