Agriculture
in the Pacific Southwest Region

Region 9 Agriculture Strategic Plan

FY2003 through FY2008

Updated January 2006


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Contents

Executive Summary	

Context	

Agriculture in the Pacific Southwest 	

Global Ecological Context	

Ecosystem Services and Carrying Capacity	

Ecological Overshoot	

Sociological Context	

Technology	

Economy	

Policy	

Organizational Context	

Congressional Mandates	

Agency Policy	

The Agriculture Strategy	

Mission and Objectives	

Organizational Structure	

Implementation	

Strategies for Achieving Results	

Performance Measurement	

Region 9 Agriculture Contacts	

Appendix: Project Selection	

Environmental Issues with Significant Agricultural Sources

Air	

Water	

Pesticides	

Intensity of Agriculture by Geographic Area	

Intensity of Agriculture by Commodity	

Stakeholder Ability	

Result: Region 9's Focus on Agriculture	

Notes	


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Region 9 Agriculture Strategic Plan, FY2003FY2008

Executive
Summary

Agriculture is a major industry in the Pacific
Southwest, providing food and fiber for the
nation and for export to the world. Good
stewardship of agricultural working lands
can provide benefits to the environment such
as sustaining clean water and habitat for
wildlife. The U.S. Environmental Protection
Agency's Pacific Southwest Region support
the agriculture industry in becoming better
stewards of the land by fostering
collaborative, innovative actions to comply
with regulations and move beyond them
toward a more sustainable future. The
Region also uses regulation and enforcement
as a tool to ensure that agricultural practices
are not damaging the environment and
threatening public health, that those who
follow the law are not placed at an unfair
advantage and that those that violate the law
face consequences. This strategic plan for
the Region's work on agriculture describes:

•	the agricultural economy in the Pacific
Southwest region

•	the ecological and sociological context
of agriculture issues

•	the policy and organizational context of
the Region's work on agriculture

•	the Region's strategies for addressing
environmental issues in agriculture

Global Context

The first step in solving a complex problem
is to understand the context and the factors
which affect it. Globally, humanity is
degrading ecosystem services including
regulation of climate, screening of solar
radiation, availability and fertility of topsoil,
the cycling of fresh water and nutrients, and
the pollination of flowering plants, to name
a few that affect agriculture. Agriculture
depends on many of these ecosystem
services. Many sociological factors affect
agriculture today, including our reliance on

technology, markets, and trade to solve
problems in agriculture. This planning
document describes these factors because
economically and environmentally viable
agriculture requires active, well-informed
consideration of these issues.

Policy Context

A holistic perspective that reflects the
intrinsic multi-media nature of agriculture
informs the Region's work, and
Congressional mandate and EPA policy
direct it. Broadly speaking, Congress
authorizes EPA to implement or oversee
programs that address specific media - air
and water - and specified wastes and
chemicals such as pesticides. And the
agency and regional strategic plans set the
environmental goals and priorities for
programs. The Region chooses projects and
creates policies and partnerships where
agri-environmental issues and its authority
to act coincide.

Agriculture Strategy

The Region's strategy for agriculture
includes four approaches:

•	collaborate with and fund stakeholders
who are able and willing to work toward
the same vision of ecologically sound
agriculture;

•	develop and/or implement regulations,
strategies, incentives and policies
designed to achieve progress toward
ecologically sound agriculture.

•	communicate and provide information
to internal and external stakeholders and

•	foster environmental stewardship to
improve and restore the environment.

The Region applies these approaches to
EPA's goals and objectives for protecting
the quality of air and water and the health of
communities and ecosystems.

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Agriculture in the Pacific Southwest Region

Context

Government agencies design and implement
programs to solve problems and benefit the
public and the first step in solving a
complex problem is to understand the
context. In this case, the problem is the
effect of agriculture on human health and
the environment in the Pacific Southwest
region, within the context of global
ecological and sociological factors that
affect and are affected by agriculture. An
economically and environmentally viable
agriculture requires active, well-informed
consideration of these factors.

Agriculture in the
Pacific Southwest

After air to breathe and water to drink, food
is the most basic requirement of human life.
A sufficient, affordable, and healthful food
supply is essential to our quality of life, and
agriculture provides it. Agriculture is
fundamental to our society in other ways
also. In the United States, we use two fifths
of our land for agriculture,1 and the way we
use it affects our air and water, the diversity
of life on earth, and our enjoyment of it. It
can also affect quality of life our posterity
will enjoy.

A full quarter of the land area in the
Environmental Protection Agency=s Pacific
Southwest Region supports the most
productive agricultural economy in the
United States.2 California alone is home to
$30 billion agricultural industry;3 its San
Joaquin Valley is the single richest
agricultural region in the world.4 California
employs 27 percent of U.S. farm workers,5
operates a third of the nation=s largest
dairies,6 and produces 64 percent of our
vegetables and melons.7 California is the
nation=s sole producer of a dozen crops and
the leading producer of five dozen more.8
Arizona, despite its desert climate, ranks
second nationally in production of ten
commodities, and in the top ten for eleven

more.9 Hawaii, with its year-round growing
season and isolation, supports a variety of
agricultural products. Long known for
sugarcane and pineapple, Hawaii=s farm
economy is in transition to a much more
diversified product mix 10 with many smaller
operations. Hawaii now leads the nation in
sales of several tropical commodities. It is
also an ideal location for developing new
seed crops, including some that are
genetically modified to resist certain pests
and pesticides.11 Nevada, with rangelands
over 82% of its area, has a productive
agricultural sector dominated by beef and
hay production.12

While plentiful and diverse foods provide
the raw materials of a healthy diet, such
intensive agricultural production over such
vast areas affects the region=s environment
and, in turn, its people=s health. In the
Pacific Southwest region, air pollution from
agricultural sources includes particulate
matter from farm machinery, road dust,
burning, plowing, and harvesting; ground
level ozone from volatile organic
compounds (VOCs) and nitrogen oxides
emitted by farm machinery; more VOCs
from pesticides;13 VOCs, ammonia,
particulates, and methane (a global warming
gas and ozone precursor) from animal feed
lots;14 and stratospheric ozone depletion
from the soil fiimigant methyl bromide.15
Nationwide, agricultural pesticides,
fertilizers, silt, and salts in irrigation
drainage and other agricultural runoff are the
leading source of water pollution.16 In
California, the use of the most toxic
pesticides per acre of farmland increased by
54 percent between 1991 and 199817 and the
total volume of pesticide use in California
agriculture rose by 66 percent, though by
2003 the volume had receded by 20
percent.18 Still, in 2001 California alone
used almost a third of all pesticides used in
U.S. agriculture.19 Moreover, agriculture
consumes about 80 percent of California=s
water supply.20 These are some of the
conditions that the Region's work on
agriculture is designed to address.

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Region 9 Agriculture Strategic Plan, FY2003FY2008

Global Ecological
Context

Ecological factors surrounding agriculture
include earth's limited capacity to provide
the ecosystem services that support human
society and, indeed, life on earth.

Ecosystem services and
carrying capacity

"The environment" is the set of conditions
and processes on earth that support life,
including human life. So when we speak of
environmental issues, we are speaking about
human health and welfare. A few examples
of these life-giving processes, often called
"ecosystem services," include nutrient and
carbon cycling, soil creation, pollination,
and water cycling and purification.
Ecosystem services include natural
resources that humans (and other species)
depend on - precipitation, fresh water,
fertile topsoil, flowering and fruiting plants,
grasslands, forests, and more. Ecosystem
services provide their benefits at finite rates
and in finite quantities, though they may
have seemed infinite when earth's
population was smaller. The upper limit of
the population that the earth's ecosystem
services can support is sometimes called
"carrying capacity." 21

Ecological overshoot

The fundamental environmental issue today
is humanity's appropriation of ecosystem
services and resources in excess of the
earth's long-term carrying capacity.22 This
condition, which can exist in the short-term
at the cost of future carrying capacity, is
often called "ecological overshoot."23 Most
if not all of the environmental problems we
hear about today - global warming, loss of
habitat and biodiversity, endangered species,
deforestation, declining fisheries, urban
sprawl, pollution of air, water, and land, and

loss of topsoil and soil fertility, to name
some - are manifestations of overshoot.
Many of the social problems we hear about
today - hunger, war, refugees, migration -
stem from the same root: too many people
striving for an unsustainable share of limited
resources. Globally and domestically,
agriculture both contributes to and suffers
from ecological overshoot.

Sociological Context

Ecological overshoot is the result of the
evolution of human social organization over
millennia, culminating in a society that
exhibits a number of factors that affect
agriculture.

Technology

So far, our society has been unable to
address the increase in human population
and expectations for material standards of
living that have led to excess appropriations
of ecosystem services. Society has found it
easier to focus on another factor in the
equation, the efficiency of our use of
resources. Many people including some
sustainability advocates hope to address
overshoot through technological advances
that increase resource-use efficiency.24

Throughout the 19th and 20th centuries,
agriculture relied on the introduction of
mechanical and biological technologies to
address its challenges. Improved crop
varieties, easily available pesticides, cheap
artificial fertilizer, and oil-powered
mechanization made possible large-scale
mono-cropping and increased yields, but
also resulted in unexpected problems. One
example, famously documented in Rachel
Carson's Silent Spring, is the use of
organochlorine pesticides like DDT, initially
seen as a fail-safe solution to insect
pressures on crop yields but with disastrous
effects on bird populations. Scientists and
citizens skeptical of technological solutions
often cite these as lessons on the limitations
of risk assessment methodologies and the
potential for technological innovation to

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Agriculture in the Pacific Southwest Region

outpace our capacity to assess and mitigate
potential harm, particularly at the ecosystem
scale. More recent oft-cited examples are
the use of genetically modified organisms
and the development of nano-scale
materials. The potential danger here is not
just in the visible effects of technology on
non-target species, but in the invisible
effects on the whole ecosystem.

Economy

Our society relies on certain social
technologies as well: the market and trade
for allocating resources, including labor,
legal constructs for organizing business
operations, government funding to influence
decision-making, and regulation to maintain
and supplement market functions. All of
these factors affect agriculture.

The market

The market is the social technology that
allocates scarce resources to many
competing demands. Today's decentralized
market distributes the modern economy's
inputs and outputs more efficiently than the
most powerful computer possibly could.
However, the market has several well-
known weaknesses. The market, per se, is
unable:

•	to provide producers and consumers
with the perfect information necessary
for theoretically correct decision-
making,

•	to account for unpriced public goods,
such as clean air and open space, and
externalities, such as pesticide runoff
into surface water, and for the finite
nature of ecosystem services;

•	to contain the scale and self-interest of
firms, which can undermine competition
and community;

•	to ensure an equitable - as opposed to
efficient - distribution of resources,
income, and wealth.25

These weaknesses, all of which affect
agriculture, might require actions outside of
the market to correct the market's

functioning, so that it performs closer to the
theoretical ideal.

Business form and size

The form, size, and number of business units
in agriculture also affect agriculture's
environmental and social performance.

Sole proprietorships and family partnerships
once predominated as the legal form for
agricultural business. These businesses
tended to be smaller in acreage and income,
and their owners generally lived on or very
close to their operations and actively
managed them with a close eye to the health
of their land.

Technological innovation to increase
efficiency in agricultural production
prompted an increase in the size of
operations and an accompanying shift in the
legal organization of agricultural firms.
Today, the agribusiness corporation
dominates the agriculture sector of the
economy, including the production,
processing, and distribution industries.

A corporation is a legal entity for organizing
work, channeling investment, and managing
financial risk, all of which can be good for
agribusiness. Large corporations often have
resources to invest in innovation and
management systems that incorporate
environmental and social considerations that
small firms lack. However, directors of
large agricultural corporations answer to far-
flung investors and may have slight
connection to the land and local economy.
Pursuing efficiency and profitability, large
agribusiness corporations replace labor and
local knowledge with technology, and
substitute size and standardization for
ecological integration.

Large corporations' wealth, access to credit,
tax advantages, technological resources, and
political influence make them more than fair
competition for family farms, which have
declined in numbers by over 40,000 per year
over the last 40 years. In 1994, the farm
income of 94 percent of farm households
would have placed them at or below the

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Region 9 Agriculture Strategic Plan, FY2003FY2008

poverty line. Income disparity has only
increased in the years since then.26

Labor

Labor is one of the most costly resources in
agriculture, and this cost has driven the
application of technology to agriculture.
However, viewing labor as only a high-cost
input misses its larger role in agricultural
and rural economies, as a source of market
demand and of human and social capital in
rural communities. Recently, market-
incentive programs have begun to
incorporate labor standards to correct this
short-coming of the market.

Policy

Subsidies and incentives

Historically, government price supports and
other payments have shaped agricultural
production in the US and abroad. While
such subsidies helped stabilize commodity
prices for some producers and provide for
plentiful and cheap staple foods for
consumers, they also distorted market
signals and encouraged overproduction of
certain commodities and the consolidation
of agricultural operations. Further, subsidy
policies have become a large part of global
trade debates, forcing nations with a history
of subsidizing their agricultural industries to
revisit these policies. In the US, with
another Farm Bill reauthorization
approaching, the dialogue focuses on the
possibility of shifting from direct crop
payments, price supports, and energy
subsides, toward a new framework that
compensates the conservation of ecological
values on agricultural lands.

international trade

International trade can increase the welfare
of trading countries under certain
conditions. But the principle of
"comparative advantage" that governs trade
in classical economic theory assumes that
national borders constrain the movement of
money and labor. In today's world, where
capital crosses borders as easily as goods but

labor does not, the economics of free trade
means that investment will flow towards
profitability wherever it is, reducing
employment opportunities and wages in the
country where investment is less profitable,
possibly due to higher standards of human
and environmental health.27 Further, the
international trade regime embodied in
institutions like the World Bank and
International Monetary Fund and in
organizations such as the World Trade
Organization (WTO) and North American
Free Trade Area (NAFTA) supersedes the
environmental and labor laws of formerly
sovereign nations when they restrain trade.28

Regulation

Finally, government intervention, including
environmental regulation, affects the
agricultural sector. Regulatory agencies,
including EPA, are increasingly seeking to
use collaborative approaches and incentives
to complement and enhance regulatory
compliance and enforcement.

Environmental stewardship can offer
opportunities for improving efficiency,
engaging in problem solving, and sustaining
clean water, air and natural resources.

Market interventions such as support for
environmentally preferable production in
agriculture or payments for conservation
practices may make the difference between a
farm's staying in business or not.

Organizational Context

The ecological and sociological context of
modern agriculture informs the Region's
work on agriculture. Within that context,
the Region works as Congressional intent
and Agency policy mandate.

Congressional mandates

Congress has authorized EPA through
several statutes to protect and restore the
environment and to preserve the human
health which depends on it. These statutes
include the Clean Air Act, Clean Water Act,

Safe Drinking Water Act, and an alphabet

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Agriculture in the Pacific Southwest Region

soup of others: FQPA, FFDCA, FIFRA,
RCRA, CERCLA, TSCA, and more (see
box on next page).

The Clean Air Act, Clean Water Act, and
Safe Drinking Water Act regulate the effects
of human activities on two environmental
Amedia,@ air and water. Other statutes
provide for the management of various
waste products of household and
commercial activities. The scientific
expertise and professional skills required in
environmental protection work are, to a
certain extent, different for each medium.
As a result, the organization of the EPA
largely reflects the media orientation of the
statutes. In contrast, the Food Quality
Protection Act and its companion statutes
regulate the effects of pesticides and other
categories of chemicals, regardless of the
environmental media affected. The
agency=s organization also reflects these
broader, Across-media@ issues.

While this may seem a large delegation of
authority to a federal agency, the EPA is
limited in what it can do in the global
context. Generally, Congress has authorized
EPA to implement or oversee specific
regulatory programs to address

environmental problems in specific media -
air, water, and waste - and for specific
chemicals - pesticides and specified toxic
substances. Congress has generally reserved
the authority to effect broad socio-economic
policy to other agencies - trade policy to the
departments of Commerce and State, energy
policy to the Department of Energy, farm
policy to the Department of Agriculture - or
reserved it largely to itself, as in the case of
tax policy. EPA's authorities generally do
not extend to these broader socio-economic
issues.

Agency policy

Agency policy is formalized and applied to
programs in several ways. One of the most
direct is through the budget and resource
allocations. Another is through the Agency
and Regional strategic plans, which set
priorities and lay out general goals and
objectives that programs must implement.
Another is through the promulgation of
regulations and dissemination of guidance to
implement the statutes. The staff and
managers working on agricultural issues
participate in developing these policy
documents and are ultimately subject to their

Selected Congressional Mandates Affecting Agriculture

Clean Air Act: authorizes states and tribes to develop and implement plans to regulate
emissions to air of various pollutants from various sources, under EPA oversight.

Clean Water Act: authorizes EPA. states, and tribes to regulate the discharge into water
bodies of pollutants from specific sources, like industrial discharge pipes, and diffuse
sources, like storm water runoff, and limit the amounts of pollutants allowed in a water
body. Specific to agriculture: sections 402(p) NPDES permits for concentrated animal
feeding operations and stoim water runoff. 404 permits (wetlands), and 319 nonpoint
source pollution programs.

Safe Drinking Water Act: protects the quality and sources of drinking water served
through public water supply systems

Food Quality Protection Act: enhances two earlier statutes, the Federal Insecticide.
Fungicide, and Rodenticide Act and the Federal Food. Drug, and Cosmetics Act. to
regulate the use of pesticides and their effects on human health and the environment

Federal Food, Drug, and Cosmetics Act: authorizes EPA to set maximum permissible
levels of of pesticide residues in foods and animal feed

Federal Insecticide, Fungicide, and Rodenticide Act: authorizes EPA to regulate the
sale, distribution, and use of pesticides through registration of pesticides for specific uses

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Region 9 Agriculture Strategic Plan, FY2003FY2008

constraints.

U.S. EPA=s Strategic Plan

Congress has required all federal agencies,
under the Government Performance and
Results Act (GPRA), to develop strategic
plans with broad goals and objectives for
agency performance, and to measure and
report on agency performance on these
objectives. Agency programs must
contribute to achieving the agency=s
strategic goals.

Strategic goals

The agency=s goals are organized according
to the three primary environmental media,
air, water, and land, with the addition of a
goal for over-arching; Across-media@ efforts
and one for ensuring compliance with EPA
regulations (see sidebar).

Objectives

The Strategic Plan establishes objectives for
agency actions under each goal. Several of
these goals apply to agriculture. Under Goal
1, they include cleaning the air that people
breathe, protecting the stratospheric ozone
layer, and reducing greenhouse gases that
cause climate change. Emissions from
agriculture can affect all of these goals.

Objectives under Goal 2 include protecting
human health (through drinking water
protection) and protecting water quality
across entire watersheds.

Under Goal 4, objectives include managing
the risks to workers and consumers from
pesticides, as well as overarching objectives
for protecting community and ecosystem
health which can apply to agricultural
communities and to ecosystems that interact
with agriculture.

Under Goal 5, objectives include providing
both assistance with and incentives for
compliance with environmental regulation,
as well as monitoring and enforcement of
compliance. These objectives continue to be
key parts of the Region's agriculture

strategy.

Targets

GPRA requires federal agencies to set
specific numerical targets for their strategic
objectives. Agency strategic targets relevant
to agriculture include reductions in many of
the emissions to air from agriculture,
including nitrogen oxides, volatile organic
compounds, and ozone depleting and
greenhouse gases. Targets for watershed
protection specifically address levels of
phosphorus contamination in farmland
streams. Targets for managing pesticide
risks include reductions in pesticide residues
on foods eaten by children and an increase
in acreage treated with lower-risk pesticides.

Annual performance goals and
measures

GPRA also requires federal agencies to
develop, as part of the annual budget
development process, annual plans for
implementing the strategic plan. The annual
plans contain annual performance goals and
specific measures for assessing progress
toward those goals. Several are relevant for
agriculture. Examples for air include the
cumulative percentage increase in the
number of people who live in areas with
ambient concentrations of ozone or fine
particulates below the national standard.
For water, an example would be water
bodies identified in 2000 as not meeting
water quality standards that now meet them.
Examples for communities include two
pesticides measures: the percentage of acre-
treatments of reduced-risk pesticides, and
detections of pesticide residues on a core set
of nineteen foods eaten by children.

Pacific Southwest Region
Strategic Plan

The Pacific Southwest Region's strategic
plan parallels the agency-wide plan. For air
pollution efforts, the Regional strategy
specifies the San Joaquin Valley as a

U.S. EPA's
Strategic Goals

Goal 1

Clean Air and Global
Climate Change

Goal 2

Clean and Safe Water
Goal 3

Land Preservation and
Restoration

Goal 4

Healthy Communities
and Ecosystems

Goal 5

Compliance and
Stewardship

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Agriculture in the Pacific Southwest Region

geographic priority and agriculture in the
San Joaquin Valley as a major challenge.
Key work includes working with the state
and local government and other stake
holders to reduce emissions of VOCs, NOx
and particulates. For water pollution efforts,
the plan specifies California dairies,
especially those in the San Joaquin Valley,
as a priority. For community and ecosystem
health efforts, a priority is to work with
universities, commodity groups, and other
stakeholders to promote adoption of new
agricultural and marketing practices that
reduce the use of pesticides and improve the
quality of soil as well as water and air in
farming areas.

The Agriculture
Strategy

EPA's Pacific Southwest Region established
its agriculture strategy to address
environmental and public health concerns as
mandated by Congress, and to implement
the goals and objectives of the Agency-wide
Strategic Plan and of the Regional strategic
plan as they apply to agriculture in the
Pacific Southwest.

Mission and
Objectives

The Region=s mission on agriculture is to
collaborate with and coordinate efforts of
federal, state, tribal, and private partners to
implement the federal regulations related to
agriculture and to attain measurable
improvements in the environmental and
public health effects of agricultural
activities, through outreach and education,
supporting environmental stewardship
efforts, funding, compliance assistance,
inspections, and enforcement. In keeping
with the Pacific Southwest Region=s
strategic plan, the Region will focus its
agriculture efforts on the significant

environmental problems in the San Joaquin
Valley, while supporting our state and local
regulatory partners in Arizona, Hawaii,
Nevada as well as tribal and Pacific island
governments as they manage agriculture-
related programs.

The Region has defined several strategic
objectives for its operations, consistent with
the Agency and Pacific Southwest Region
strategic plans.

Clean Air: To reduce agriculture=s
contribution to non-attainment of Clean Air
Act standards for particulate matter and for
volatile organic compounds and nitrogen
oxides that are precursors to ground-level
ozone pollution.

Clean Water: To reduce the impairment of
water bodies due to agriculture.

Healthy Communities: To reduce the
impacts of pesticides on farm workers and
farm communities and to assure that farm
workers have access to adequate drinking
water.

Healthy Ecosystems: To reduce the
environmental side-effects of pesticide use.

Organizational
Structure

The Regional agriculture team comprises
managers and staff from the three divisions
B Air, Water, and Communities and
Ecosystems (CED) B whose responsibilities
include issues affecting agriculture. The
Associate Director for Agriculture of the
Communities and Ecosystems Division
manages the program and serves as Advisor
to the Regional Administrator on agriculture
issues.

Associate directors from each of the three
divisions provide critical leadership. A
small Agriculture Program staff within CED
monitors, facilitates, and reports on efforts
on agriculture issues within all three
divisions, and coordinates efforts with other
Regions and headquarters offices within

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Region 9 Agriculture Strategic Plan, FY2003FY2008

EPA and among federal, state, tribal, and
local agencies, agricultural stakeholders, and
non-governmental organizations.

Implementation

The Agriculture Program's coordinating
staff works with the Regional agriculture
team to plan, fund, implement, and evaluate
projects. Other activities include developing
and implementing strategies to improve
collaboration and communication with
agriculture and involved agencies as well as
providing technical, financial and research
assistance. The next section briefly describes
the Region's strategies for achieving its
goals and objectives. The Region 9
Agriculture Operating Plan describes the
strategies in more detail as well as the
specific projects under each strategic goal.

Strategies for achieving
results

The Region employs four basic strategies
intended to promote an environmentally
sustainable agricultural industry:

1.	Collaboration and funding

2.	Regulation and policy development

3.	Communication and information
management

4.	Environmental stewardship

Collaboration and funding

Region 9 recognizes that agriculture
provides significant economic benefit to the
region and that sustainable agriculture can
provide significant environmental benefit as
well.29 The Region also realizes that the
industry faces economic as well as
environmental challenges. For this reason,
the Region uses collaborative and incentive-
based approaches to reach environmental
goals wherever feasible. The Region
collaborates on information sharing, priority

setting, funding, and joint projects with a
range of stakeholders, including:

•	USDA agencies including the Natural
Resources Conservation Service, the
Farm Services Administration, Rural
Development, Cooperative State
Research Education and Extension
Service;

•	State, local and tribal environmental and
agricultural agencies including the CA
State Water Resources Control Board
and its nine regional water quality
control boards, Department of Food and
Agriculture, Air Resources Board, local
Air Districts, Department of Pesticides
Regulation, and others;

•	California Association of Resource
Conservation Districts and its 103
resource conservation districts;

•	Non-governmental organizations with
environmental and agricultural missions,
including the Community Alliance with
Family Farmers, the Natural Resources
Defense Council, Sustainable
Conservation, Pesticide Action
Network, Environmental Defense and
others;

•	Commodity and producer support
organizations including the California
Farm Bureau Federation, Nisei Farmers
League, California Cotton Ginners and
Growers, California Minor Crops
Council, Western United Dairymen, the
Almond Board of California, and the
California Tree Fruit Agreement

•	Universities and other academic
institutions

Regulation and policy

The Region will also pursue regulatory
approaches to achieve compliance. In the
coming years, these efforts could include:

Air Programs

•	Develop emission reduction credit
protocols for agricultural sources in
order to provide appropriate incentives
for growers to reduce emissions;

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Agriculture in the Pacific Southwest Region

•	Work with stakeholders to characterize
and reduce emissions of VOCs, NOx,
and particulate from crop and animal
agriculture by incorporating appropriate
practices into the Ozone and particulate
SIPs and into implementation rules; and

•	Implement flexible conservation
management practices for control of
particulate.

Water Programs

•	Provide technical, financial and
programmatic guidance and support to
states as they develop and implement
Total Maximum Daily Loads (TMDLs)
related to agricultural activities (e.g.,
San Joaquin River diazinon and
chlorpyrifos);

•	Work closely with states to implement
the revised CAFO rule (2007) and
provide technical assistance, as needed,
to the Central Valley Regional Water
Quality Control Board as they move
toward adoption of its CAFO WDR
general permit for dairies in 2006; and

•	Provide assistance to the Central Valley
Regional Board as it implements the

Irrigated Lands Conditional Waiver
Program.

•	Assist the State Water Resources
Control Board as it revises the statewide
Rangelands Water Quality Management
Plan for consistency with the agriculture
waiver program.

Pesticides Program

•	Support a strong, fair, predictable,
consistent state enforcement presence;

•	Work with our state regulatory partners
to strengthen the protection of
agricultural workers; and

•	As appropriate based on national efforts,
ensure the protection of endangered
species from the effect of pesticides.

Agriculture Program

The Agriculture Program contributes its
knowledge of stakeholders and its
experience on the ground to the
development and implementation of agency
policy on current issues as they arise,
including:

•	Pesticide drift

Potential Performance Measures Applicable to Pacific Southwest Agriculture

Clean Air

Ambient concentrations of ozone (1-hour and 8-hour standards) (e.g.. in the San Joaquin Valley)

Ambient levels of particulate matter (e.g.. in the San Joaquin Valley)

Asthma morbidity and mortality (e.g.. in the San Joaquin Valley)

Clean Water

Surface waters impaired by agriculture (stream miles and lake acres) (e.g.. in San Joaquin/Tulare watershed)

Levels of nitrogen, phosphorus, and pesticides in streams impacted by agriculture (e.g.. in San Joaquin/Tulare
watershed)

Healthy Communities

Ambient levels of pesticides in air

Number of cases of farm worker illness due to pesticide incidents
Number of off-farm pesticide drift incidents

Healthy Ecosystems

Percentage of acre-treatments with reduced-risk pesticides for the following commodities: stone fruits, wine grapes,
almonds, and walnuts

Number of acres of stone fruits, wine grapes, almonds, and walnuts with reduced-risk pesticides or other more
sustainable, environmentally sound practices in use

Invertebrate and fish indices of biotic integrity in streams in the San Joaquin / Tulare watershed


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Region 9 Agriculture Strategic Plan, FY2003FY2008

•	NPDES permit for pesticides

•	Biotechnology

•	Fumigants and VOCs

Performance measurement

Like any governmental or private-sector
entity, U.S. EPA collects information for
program management decision-making and
reports program accomplishments to ensure
that agency personnel are implementing
management direction and priorities.
Historically, program management has
focused on tracking program activities and
milestone events. In recent years, however,
federal agency management efforts have
shifted from tracking activities, or outputs,
toward measuring results, or outcomes, of
program activities. The Region is
researching measures, including those
identified in the national and regional
strategic plans (see box on page 12), to track
the effectiveness of efforts on the
environmental effects of agriculture,
especially in the San Joaquin Valley of
California.

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Agriculture in the Pacific Southwest Region

Region 9 Agriculture Contacts

Advisor to the Administrator Kathy Taylor	415-947-4201

for Agriculture

Communities and Ecosystems Division

Agriculture Program

Associate Director	Kathy Taylor	415-947-4201

Staff	Karen Heisler	415-947-4240

James Liebman	415-947-4241

Cindy Wire	415-947-4242

Don Hodge	415-972-3240

Pesticides Program

Manager	Pam Cooper	415-947-4217

Air Division

Associate Director	Kerry Drake	415-947-4157

Water Division

Associate Director	Jovita Pajarillo	415-972-3491

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Region 9 Agriculture Strategic Plan, FY2003FY2008

Appendix: Project Selection

Informed by knowledge of global socio-environmental issues, the Region works where its
authorities and its concerns coincide, in the area of agri-environmental issues. To choose
specific projects to address these issues, the Region evaluates several factors, including:

•	the contribution of agricultural practices to urgent human health and environmental
issues

•	the intensity of agricultural activity by geographic area

•	the intensity of agricultural activity by crop

•	the receptivity of stakeholders to change, and hence the likelihood of success

(NOTE: Projects funded through the Clean Water Act are primarily the decision of the State
Water Resources Control Board which has the delegated authority for grants under the 319
nonpoint source pollution control program. Funding decisions are guided by priorities such
as waters listed as impaired (i.e., 303(d), watershed-based plans, and TMDL
implementation.)

Environmental Issues with Significant
Agricultural Sources

Agriculture contributes to a number of significant environmental problems. The key
issues identified by the Region 9 programs include:

Air

•	Particulate matter: Most of California's San Joaquin Valley is a non-attainment area for
particulate matter under the Clean Air Act. Similarly, the South Coast of California and
the Maricopa Valley outside Phoenix, Arizona, both have serious problems with
particulate matter. Agricultural burning, bare fallowing, plowing, harvesting, and diesel
engines are major contributors to dust formation in rural areas.

•	Ground-level ozone: Volatile organic compounds (VOCs) from agricultural pesticides
and dairies, and nitrogen oxides (NOx) from farm machinery exhaust, are major
contributors to ozone formation. In the San Joaquin Valley, pesticides account for 9
percent and dairies 16 percent of the reactive organic gases that contribute to ozone
formation, while agricultural burning adds another 3 percent.30

•	Stratospheric ozone depletion: The soil fiimigant pesticide methyl bromide is responsible
for 5 to 10% of the reduction in Earth's stratospheric ozone, and California agriculture is
the world's largest user of methyl bromide.31 Most nations of the world, including the
United States, have agreed to phase out this chemical, but "critical use" exemptions have
kept it in use on strawberries and other crops.

Water

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Agriculture in the Pacific Southwest Region

•	Surface water pollution: Agriculture is the nation's leading source of pollution for
ground, surface, and coastal waters.32 Pollutants include pesticides, nutrients, fertilizers,
silt, and salts in irrigation drainage and livestock production. In California, agriculture is
responsible for the impairment of 69% of the river miles due to nonpoint source
pollution. Agriculture is the leading contributor to non-point source pollution in four of
the state's nine hydrologic basins33 and a major contributor in four of the remaining five
basins. Concentrations of pesticides, especially diazinon, regularly exceed water quality
standards in all major rivers of California's Central Valley.34

•	Water supply allocation: The Bay-Delta is in decline from decades of competing
demands, no longer functioning as a healthy ecosystem or as a reliable water supply. EPA
is part of a collaborative effort known as the CALFED Bay-Delta Program with 23 other
state and federal agencies to improve water supplies in California and the health of the
Delta watershed.

•	Wetlands: Vineyard conversion and ag lands being converted to urban development is
resulting in a major loss of wetlands.

Pesticides

•	Total pesticide use: California is the leading state for pesticide use and uses 20% of the
nation's pesticides.35 More than 200 million pounds of active ingredient36 are applied
each year. Fresno County alone receives 40 million pounds - 40 pounds per capita -
each year.

•	Use of high-risk pesticides: Use of the most toxic materials is also rising. Between 1991
and 1998, the total volume of pesticide use rose 40%, intensity of pesticide use (pounds
applied/acre) rose 51%, use of the most toxic materials rose by 27%, and use of
carcinogens rose 127%. And agriculture releases three times as many reproductive and
developmental toxins as industry.37

•	Farm worker health: Such heavy use of highly toxic materials creates significant human
health concerns. Pesticides cause acute illness in an estimated 7.5% of the agricultural
labor force each year.38

•	Farm community health: Numerous communities, including MacFarland, Lompoc, and
Watsonville, have raised concerns to the Regional office about pesticide drift into
communities and schools. Environmental assessments of these communities indicate
high incidences of illness and the potential for chronic exposure to pesticides. Existing
regulatory programs do not effectively address community impacts nor do they provide
adequate incentives for growers to move beyond compliance to a more proactive
stewardship role.

•	Pesticide drift into surface water, which has the potential to harm aquatic ecosystems,
including endangered species

Intensity of Agriculture by Geographic Area

California is the leading farm state, with $25 billion in farm gate sales accounting for 12% of
the nation's total farm economy. Eight of the US's top 10 agricultural counties are in
California, each producing over $1 billion annually in farm gate receipts. California produces
more than one-half of the nation's fruits and vegetables; leads the nation in production of 85
commodities, including dairy, produce, eggs, and nursery crops; and is the world's most

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Region 9 Agriculture Strategic Plan, FY2003FY2008

diverse agricultural economy, with over 350 crop and livestock commodities, many not
grown elsewhere. California's Central Valley is the most ethnically diverse rural area in the
world, and California employs 25% of the total US hired agricultural labor force, far more
than any other state.39 California alone accounts for 20% of all US farm exports.40

Within California, the San Joaquin Valley leads the state in economic value of agriculture, in
farm acreage, and in employment of farmworkers. The eight counties of the San Joaquin
Valley include six of the seven leading agricultural counties in the state (Table 1). As a
result, the Region concentrates its efforts on the San Joaquin Valley.

Table 1: California's Counties with the Most Valuable Agricultural Production

(counties in the San Joaquin Valley are shown in bold)

Con n( v

\ aluc of
Agricultural
Production
(1000s)

Fresno

4,052,767

Tulare

3,294,660

Monterey

3,288,468

Kern

2,477,526

Merced

1,918,230

San Joaquin

1,494,693

Stanislaus

1,454,928

San Diego

1,351,059

Kings

1,136,966

Ventura

1,117,567

Imperial

1,073,472

Riverside

1,067,367

Santa Barbara

858,071

Madera

760,246

San Bernardino

645,885

Source: California Agricultural Statistics 2003. California Department of Food and
Agriculture. Sacramento, CA, October 2004,
ftp://www.nass.usda.gov/pub/nass/ca/AgStats/2003cas-all.pdf

Intensity of Agriculture by Commodity

Commercial agricultural production, research, processing, distribution, marketing, and
politics are organized by crop. More than 350 crops are grown in Region 9. Since it is not
possible to work simultaneously on such a large number, we identified priority crops based
on economic value (Table 2) and acreage (Table 3). In recent years the Region has worked
on and funded projects in eleven of the twenty most valuable agricultural commodities in the
state, covering plants and animals; tree and row crops; and food, feed, and fiber crops.

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Agriculture in the Pacific Southwest Region

Table 2: California's Most Valuable Agricultural Crops and Commodities (crops
the Region has worked on in recent years are indicated in bold)

Rank

Crop / C ommodity

Kconomic
\ aluo
(SI.000.000)

1

milk and cream

4,029

2

nursery

2,437

3

grapes, all

2,298

4

lettuce, all

1,734

5

almonds

1,600

6

cattle and calves

1,556

7

strawberries

1,119

8

flowers

985

9

tomatoes, all

901

10

hay, all

842

11

cotton, all (lint and seed)

761

12

broccoli

603

13

chickens, all

537

14

oranges, all

483

15

carrots, all

468

16

stone fruits (peach, plum,
nectarine)

455

17

rice

373

18

avocadoes

316

19

walnuts

342

20

eggs, chicken

282

Source: California Agricultural Statistics, 2003. California Department of Food and
Agriculture. Sacramento, CA, October 2004,
ftp://www.nass.usda.gov/pub/nass/ca/AgStats/2003cas-all.pdf

Table 3: California Crops Grown Over the Largest Acreage (crops the Region has
worked on in recent years are indicated in bold)

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Region 9 Agriculture Strategic Plan, FY2003FY2008

Rank

Crop / Commodity

Acreage
(1.000
acres)

1

Hay, alfalfa

1,570



2

Grapes, all

819





raisin



255



table



85



wine



479

3

Cotton

694



4

Almonds

550



5

Rice

507



6

Wheat, all

485



7

Tomatoes, all

311





Processing



274



Fresh market



37

8

Lettuce, all

232



9

Walnuts

213



10

Oranges, all

195



11

Corn, grain

170



12

Stone fruits

140





Peaches



68



Plums



36



nectarines



36

13

Broccoli

125



14

Oil crops

107



15

Pistachio

88



16

Beans, dry

75



17

Carrots

71



18

Melons, cantaloupe and

70





honeydew





19

Avocados

60



20

Barley

58



Note: For certain agricultural commodities (e.g., milk and cream, nursery crops, cattle and
calves, cut flowers, chickens, and eggs), acreage is not a useful measure. Therefore, these
agricultural commodities do not appear in this table.

Source: California Agricultural Statistics 2003. California Department of Food and
Agriculture. Sacramento, CA, October 2004,
ftp://www.nass.usda.gov/pub/nass/ca/AgStats/2003cas-all.pdf

Stakeholder ability

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Agriculture in the Pacific Southwest Region

Two additional criteria are critical in deciding how the will spend its resources. The
Program's non-regulatory activities to promote a more sustainable future for agriculture must
rely on the abilities and willingness of our partners.

Producers of many crops in CA are organized into industry, trade, and marketing
associations. Many of these associations have state charters and strong ties to University of
California Cooperative Extension (http://www.cdfa.ca.gov/mkt/mkt/mktbrds.html). Through
these commodity organizations, growers are more able to participate as partners in EPA
Region 9 efforts. The Region works with the Almond Board of California, the Nisei Farmers
League, the California Farm Bureau Federation, and the Lodi-Woodbridge Winegrape
Commission, for example. Growers of commodities that are less well organized are harder to
reach. In addition, growers and their representative organizations must be willing to work
with the Region. Working with willing and able partners, the Region creates models whose
success encourages others to follow.

Result: Region 9's Focus on Agriculture

Agriculture, broadly defined, includes production of food, feed, and fiber using both plants
and animals. The many and various environmental effects of this entire field require some
focusing of program efforts. Continual, iterative planning has narrowed the focus of the
Region's on-the-ground and grant-making work on agriculture to:

•	land-based farming activities that contribute to environmental and regulatory issues,

•	the San Joaquin Valley where these issues are especially acute,

•	crops with the highest value and acreage, and

•	stakeholders who are willing to engage with us.

Notable results of this focus are projects on reducing the use of organophosphate pesticides
on dormant almond orchards, and on assessing available technologies for managing dairy
manure. Also notable are the results from grants under the West Coast Diesel Collaborative.
Due to resource constraints, the Regional agriculture team has not addressed, and currently
has no plans to address, the environmental effects of forestry, grazing (note: re grazing,

Water Division is working w/ the SWRCB as work gets underway to revise its Rangelands
Water Quality Management Plan), and aquaculture, though these industries are significant in
Region 9.

The Region also works to address market imperfections and to shape policy on and regulation
of agricultural technologies. This includes efforts to use a Regional grants program to direct
Food Quality Protection Act funds towards helping growers transition away from high-risk
pesticides toward more sustainable agricultural practices. It also includes efforts to support
market-based incentives for sustainable production through third-party certification, and to
influence national policy on funding for integrated pest management, on the interface
between pesticides and air and water regulations, and on agricultural biotechnology.

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Region 9 Agriculture Strategic Plan, FY2003FY2008

Notes

1	Total land area: Central Intelligence Agency World Factbook:

http://www.cia.gOv/cia/publications/factbook/geos/us.html#Intro; Land in agriculture: USDA
National Agricultural Statistics Service 2002 Census of Agriculture:
http://www.nass.usda.gov/census/census02/volumel/us/st99_l_009_010.pdf

2	USDA Economic Research Service, State fact sheets, http://www.ers.usda.gov/StateFacts/.
data from USDA National Agricultural Statistics Service 2002 Census of Agriculture

3	USDA Economic Research Service, Agricultural Outlook: Statistical Indicators, table 34,

Cash Receipts from Farm Marketing, by State,

www.ers.usda.gov/publications/agoutlook/aotables. updated May 6, 2005

4	The Great Valley Center, The State of the Great Central Valley of California: Assessing the
Region Via Indicators: The Economy, 1999-2004, p. 28, states that the San Joaquin Valley
accounts for 88% of the Central Valley=s 57% of California production, or about half of the
California total of $30 billion. If the San Joaquin Valley were a state, it would rank second
behind Texas and just ahead of Iowa and the rest of California in value of agricultural
production, http://www.greatvallev.org/publications/general program area.aspx?
pId=State+of+the+Great+Central+Vallev+Indicators+Series

5	USDA National Agricultural Statistics Service, Farm Labor, February 2005, hired workers
as of October 10-16, 2004 (p. 7) plus agricultural service workers as of October 2004 (p. 14)

6	USDA National Agricultural Statistics Service, AQuick Stats@ Agricultural Statistics
Database, U.S. and State Data, Dairy, Milk Cows by Size Groups: Operations, 2004, for
California (1100 operations with more than 500 head) and USA (3010 operations with more
than 500 head)

7	California Agricultural Statistics Service, California Agricultural Statistics 2003. USDA
National Agricultural Statistics Service and California Department of Food and Agriculture,

Sacramento, CA (October 2004), p. 77. In addition, California produced 43% of the nation=s
fruit (p. 37) and nuts and 21% of its milk (p. 61).

8	California Agricultural Statistics Service, California Agricultural Statistics 2003, p. 2.

9	USDA National Agricultural Statistics Service, Arizona Statistics Office, Annual Statistics
Bulletin, 2003, ACommodities Rank by State: General, Field crops, Fruit@,
http://www.nass.usda.gov/az/03bul/pdf/pg89.pdf and ACommodities Rank by State:

Vegetables, Livestockฎ, http://www.nass.usda.gov/az/03bul/pdf/pg90.pdf

10	USDA National Agricultural Statistics Service and Hawaii Agricultural Statistics, Statistics
of Hawaii Agriculture web site, http://www.nass.usda.gOv/hi/stats/t of c.htm as of 6/7/05,
pages 1-18, Hawaii Agriculture 2003, p. 2

11	Seed crops are now third after pineapple and sugar cane in value of production (2003).

USDA National Agricultural Statistics Service and Hawaii Agricultural Statistics, Statistics
of Hawaii Agriculture web site, Diversified Agriculture Ranking table,
http://www.nass.usda.gov/hi/stats/stat-13.htm as of 6/7/05

12	USDA National Agricultural Statistics Service and Nevada Agricultural Statistics Service,

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Agriculture in the Pacific Southwest Region

Reports, Nevada Agricultural Statistics 2003-2004, General, p. 10 (Utilization of Land in
Farms and Ranches, Nevada 2002) and p. 13 (Cash Receipts from Farm Marketings, Nevada
2003), http://www.nass.usda.gov/nv/General.pdf

13 San Joaquin Valley Unified Air Pollution Control Board, 2003 PMwPlan, Table 4-8, lists
several of these as Asignificant source categories within the district=s regulatory authorityฎ;
agricultural equipment and agricultural pesticides are listed in Table 4-7 of sources not under
the district=s authority. Table 3-12 indicates that dairy farming is the largest source (60
percent of the total) of ammonia, a PM2 5 precursor, with poultry and beef also significant
sources.

14U.S. EPA Methane web site, ASources and Emissionsฎ page, AHuman-related Sources@
section, http://www.epa.gOv/methane/sources.html#anthropogenic as of 6/1/05, and National
Research Council, Air Emissions from Animal Feeding Operations: Current Knowledge,
Future Needs, p. 45-6, which describes several mechanisms through which animal feeding
operations contribute ammonia and other nitrogen compounds, VOCs, hydrogen sulfide, and
particulate matter to air pollution.

15	U.S. EPA Ozone Depletion Rules and Regulations web site, AMethyl Bromide Questions
and Answers@ page, http://www.epa.gov/spdpublc/mbr/qa.html. especially the section AWhy
has EPA taken action on a pesticide under the Clean Air Act,@ as of 6/1/05

16	Ralph Heimlich, Agricultural and Environmental Indicators, 2003, USDA Economic
Research Service, Agricultural Handbook No. AH722, February 2003,
http://www.ers.usda.gov/publications/arei/ah722/ as of 6/1/05. Section 2.3, AWater Quality
Impacts of Agriculture,ฎ cites findings from three seminal sources:

•	U.S. Geological Survey, The Quality of Our Nation=s Waters B Nutrients and Pesticides:
U.S. Geological Survey Circular 1225. This is a report from USGS= National Water
Quality Assessment (NAWQA) Program, which includes the San Joaquin/Tulare
watershed as one of twenty selected nationwide for the first round of monitoring. Current
status on the web: http://water.usgs.gov/nawqa/ .

•	U.S. EPA=s Office of Water, 2000, Atlas of America =s Polluted Waters, EPA 840-B-00-
002, an official list of impaired waterways required under the Clean Water Act section
303(d). 2002 data is on the web at: http ://www.epa. gov/owow/tmdl/

•	U.S. EPA=s Office of Water, 1998, National Water Quality Inventory: 1996 Report to
Congress. The current database of 2002 water quality assessment information provided
by the states under Clean Water Act section 305(b) is on the web at:

http ://www.epa. gov/waters/3 05b/

Also, U.S. Department of Agriculture, Natural Resource Conservation Service, Water
Quality and Agriculture: Status, Conditions, and Trends, NRCS Working Paper #16, July
1997, links soil quality conditions to water quality conditions, though the data is dated

17	Susan Kegley, et al., Hooked on Poison: Pesticide Use in California 1991-1998, Pesticide
Action Network and Citizens for Pesticide Reform, 2000,
http://www.panna.org/resources/documents/hookedAvail.dv.html as of 6/605

18	California EPA, Department of Pesticide Regulation, Summary of Pesticide Use Report
Data 2003: http://www.cdpr.ca.gov/docs/pur/pur03rep/03com.htm; and Summary of Pesticide
Use Report Data 1998 (for data back to 1991):
http://www.cdpr.ca.gov/docs/pur/pur03rep/03chem.htm

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Region 9 Agriculture Strategic Plan, FY2003FY2008

19	California data: California EPA, Department of Pesticide Regulation, Summary of Pesticide
Use Report Data 2003: http://www.cdpr.ca.gov/docs/pur/pur03rep/03com.htm as of 6/4/05;
national data: Timothy Kiely, et al., Pesticide Industry Sales and Usage: 2000 and 2001
Market Estimates, Biological and Economic Analysis Division, Office of Pesticide Programs,

Office of Prevention, Pesticides, and Toxic Substances, U.S. Environmental Protection
Agency, Washington, D.C. 20460, May 2004,

http://www.epa.gov/oppbeadl/pestsales/01pestsales/market estimates2001.pdf as of 6/4/05

20	California Department of Water Resources web site, Agricultural Water Use page:
http://www.owue.water.ca.gov/agdev/ as of 6/605

21	The International Institute for Sustainable Development provides concise, non-technical
definitions of several of the terms used here: http://www.iisd.org/susprod/principles.htm (as
of 9/21/2005)

22	The consensus of over 1360 scientists and experts working under the auspices of the
United Nations on the Millennium Ecosystem Assessment, in Living Beyond Our Means:

Natural Assets and Human Weil-Being,

http: //www .millenniumassessment.org/en/products. aspx

23	Mathis Wackernagel, et al., "Tracking the ecological overshoot of the human economy,"

Proc. Natl. Acad. Sci. USA, Vol. 99, Issue 14, pp. 9266-9271, July 9, 2002; also, DonellaH.

Meadows, et. al., Beyond the Limits: Confronting Global Collapse, Envisioning a Sustainable
Future, Chelsea Green, 1992

24	Paul Hawkins, et. al., Natural Capitalism: Creating the Next Industrial Revolution, 1999.

See also the Rocky Mountain Institute at http://www.rmi.org. In Europe, the Factor Four and
Factor Ten movements promise four- and ten-fold increases in resource use efficiency.

25	Herman Daly and John R. Cobb, Jr., For the common good: redirecting the economy
toward community, the environment, and a sustainable future, Beacon Press, 1994, pp. 44 ff

26	This section is largely taken from A.V. Krebs, "Corporate Takeover of Agriculture," in
Andrew Kimbrell, ed., Fatal Harvest: The Tragedy of Industrial Agriculture, Foundation for
Deep Ecology, 2002, p. 307

27	Daly and Cobb, op. cit., pp. 209 ff

28	Debi Barker, "Globalization and Industrial Agriculture," in Andrew Kimbrell, ed., Fatal
Harvest: The Tragedy of Industrial Agriculture, Foundation for Deep Ecology, 2002, p. 314,

29	In addition to the aesthetic value of pastoral and cultivated lands, certain farming practices
can improve biodiversity in agricultural areas. See Jeanne Clark and Glenn Rollins, eds.,

Farming for Wildlife'.Voluntary Practices for Attracting Wildlife to Your Farm, California
Department of Fish and Game, 1996. See also Dan Imhoff and Roberto Carra, Farming with
the Wild, Sierra Club Books, 2003, and Dana L. Jackson and Laura L. Jackson, The Farm as
Natural Habitat: Reconnecting Food Systems with Ecosystems, Island Press, 2002.

30	California Air Resources Board, Almanac Emissions Projection Data (published in 2005),

Estimated Annual Average Emissions, San Joaquin Valley Air Basin,
http://www.arb.ca.gov/ei/maps/basins/absjvmap.htm

31	US EPA Office of Air and Radiation (http://www.epa.gov/docs/ozone/mbr/mbrqa.html);

World Meteorological Organization, Global Ozone Research and Monitoring Project -
Report No. 37: Scientific Assessment of Ozone Depletion: 1994, Geneva, Switzerland.

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Agriculture in the Pacific Southwest Region

32	According to the USDA-Natural Resource Conservation Service, "The 1996 National
Water Quality Inventory, which summarizes state surveys of water quality in the United
States, indicates that about 40 percent of surveyed U.S. waterbodies are impaired by
pollution, with the leading source being polluted runoff. About 70 percent of impaired rivers
and streams and 49 percent of lakes are impaired by runoff or discharges from agriculture."
Source: web site (http://rigis2.nhci.nrcs.iisda.go\ :S0/clcan\\atcr/action/c2c.html). Actions to
Strengthen Core Clean Water Programs - Strong Polluted Runoff Controls.

33	Sacramento River, San Joaquin River, Tulare Lake, and Central Coast watersheds

34	US Geologic Survey, Central Valley Regional Water Quality Control Board, and the CA
Department of Pesticide Regulation

35	Figures on pesticides use come from United States Department of Agriculture, Agricultural
Statistics (http://www.usda.gov/nass/pubs/agstats.htm); Aspelin, A.L. and A.H. Grube. 1999.
Pesticides Industry Sales and Usage: 1996 and 1997Market Estimates. US EPA Office of
Pesticide Programs, Biological and Economic Analysis Division, Washington, DC; Wilhoit,
L. et al. 1999. Pesticide Use Analysis and Trends from 1991 to 1996. California Department
of Pesticide Regulation, Sacramento, CA; and Kegley, S. et al, Hooked on Poison: Pesticide
Use in California, 1991-1998. Pesticide Action Network, San Francisco, 2000.

36	"Active Ingredient" refers to the registered portion of the pesticide product. The "inert" or
"other" ingredients include carriers, spreader-stickers, and other agents to aid in formulation.
Many of these other ingredients are quite toxic, and contribute an additional 150 million
pounds per year. See: Marquardt, S. et al. 1998. Toxic Secrets: "Inert"Ingredients in
Pesticides. Northwest Coalition for Alternatives to Pesticides, Eugene, OR.

37	Data for agriculture is reported under the CA Pesticide Use Reporting (PUR) system; data
for industry is reported under the Toxics Release Inventory (TRI). An analysis is published
in: Generations at Risk: How Environmental Toxicants May Affect Reproductive Health in
California. Physicians for Social Responsibility and California Public Interest Research
Group, San Francisco, 1999..

38	Coye, M.J. 1985. The health effects of agricultural production: I. Health of agricultural
workers. Journal of Public Health Policy 6:349-370. U.S. Congress, Office of Technology
Assessment, Neurotoxicity: Identifying and Controlling Poisons of the Nervous System,
OTA-BA-436 (Washington, DC: U.S. Government Printing Office, April 1990), p. 283.

39	National Agricultural Statistics Service, Agricultural Statistics Board. 2000. Farm Labor.
US Department of Agriculture, Washington, DC

(http://usda.mannlib.cornell.edu/reports/nassr/other/pfl-bb/2000/fmlall00.pdf).

40	California Department of Food and Agriculture. 2003. California Agricultural Resource
Directory 2002. California Department of Food and Agriculture, Sacramento, CA. 176 pp.

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