RVI Comments on Local Climate Action Plan and Agriculture and Water Chapters of the General Plan

January 18, 2018

Supervisor Steve Bennett, District 1

CC Supervisor Linda Parks, District 2; Phil White, Planning Commissioner, District 1; Susan Curtis, General Plan Update Manager

Dear Supervisor Bennett,

Generally our concern is that the current documents for the General Plan Update make insufficient reference to the centrality of and connections to climate change, and specifically to the parallel role of carbon sequestration along with emissions reduction and the requisite related policy to keep rain water on the land to support re-vegetation and carbon sequestration.

Also, in the Agriculture Chapter the resource of farmers and farm workers is missing as well as the myriad and growing linkages between agriculture and the whole community. In this letter we will suggest ideas and improved language in these areas. We have other suggestions and we know there are many more good examples of these features that might be added to the background documents, but these are the most important, are illustrative, and all we have time to get down.

  • Vision statement: CFROG’s language is superior in every way to that approved by the Planning Commission. Aside from your appointee who did his best under the circumstances, we believe the Commission was unreasonable and staff was not very helpful in the discussion about what CFROG proposed on behalf of dozens of organizations. Highlighted in CFROG’s proposed language below is most needed additional wording to make it true to science, state legislation, and the existential threat of climate change:

Vision Statement:  Ventura County is a remarkable place to live, with clean water and air for all residents and visitors. Our exceptional quality of life and economic vibrancy are rooted in regenerative, inclusive, non-toxic stewardship of all aspects of the place we call home. The protection and conservation of our soil, air, water, cultural heritage, natural resources, open spaces, human spirit and creativity are foundations of local policy and governance and together create the framework required for healthy people and a healthy economy.

In the vein of true stewardship, the Ventura County General Plan reflects the county’s ongoing commitment to doing our part within a global society facing the impacts of Climate Change, by continually collaborating with local residents, businesses, agencies, organizations and cities to reduce our greenhouse gas emissions and draw down the overall amount of carbon in the atmosphere. 

  • Guiding principle for Climate Action Plan: Include “sequester (or draw down) carbon” as codified by SB 1386.

Climate Change and Resilience Guiding Principle:  Reduce greenhouse gas emissions [insert: and sequester carbon] to achieve all adopted targets, proactively anticipate and mitigate the impacts of climate change, promote employment opportunities in alternative energy and reducing greenhouse gases, and increase resilience to the effects of climate change.

  • The Background Document for the Agriculture Chapter is missing reference to human resources and to community linkages. The Background Documents for the Agriculture and Climate Chapters need to include Ventura County’s exceptional history and achievement with biologically based pest management, carbon sequestration practices, and roles of agricultural and storm water management practices in climate change mitigation.

Section 9.1 Agricultural Resources would be improved by a section about farmers, farm labor, consultants and suppliers. The Farm Bureau of Ventura County (FBVC), reports that the county employs 20,000 farm workers annually. The number of farm workers ranges seasonally from a low of 15,000 to a high of 25,000 during the peak spring and summer harvest of strawberries, lemons and avocados. The average age is 32. 95% were born in Mexico with an average of 53% who speak Spanish only and many speaking only Mixtec. The average duration in the US is 11 years. The average income of those workers is about $22,000 a year while the average rent for a two-bedroom apartment is $62,200.

House Farm Workers!  was founded in 2004 to influence policy and do public outreach about the need for safe, decent and affordable farm worker housing. Several other organizations have stepped up to improve the conditions of farm workers in the county. The United Farm Workers aims to engage immigrants, works to reform the immigration system, and networks to influence policies and expand services.  A survey of farm workers conducted by Central Coast Alliance United for a Sustainable Economy (CAUSE) conducted a survey in 2015 of farm workers.  7 in 10 farm workers said their working conditions were dangerous or harmful to their health.  42% said they never take time off work for any reason.  Three in 5 farm workers in Ventura County said they’ve experienced at least one form of wage theft. Ventura County formed a Farm Worker Resource Program Advisory Committee in 2017 to set up an office and trained staff to address farm worker issues.

Farmers total ? in the county. The Ventura County Farm Bureau, founded in 1914, represents grower interests, fosters community action, and manages the Ventura County Agricultural Irrigated Lands Group, which was established in 2006 to help growers and agricultural landowners comply with state water quality regulations.

Organic Farming:  On page 9-32 the definition of organic farming is incorrect. Here is the USDA National Organic Program definition that should be used on page 9-32 (here is a description of practices: https://www.ams.usda.gov/sites/default/files/media/Organic%20Practices%20Factsheet.pdf)

DELETE:  as farming practices that rely on natural fertilizers such as compost, manure, green manure, and bone meal in lieu of chemical pesticides.

INSERT: The USDA organic regulations describe organic agriculture as the application of a set of cultural, biological, and mechanical practices that support the cycling of on-farm resources, promote ecological balance, and conserve biodiversity. These include maintaining or enhancing soil and water quality; conserving wetlands, woodlands, and wildlife; and avoiding use of synthetic fertilizers, sewage sludge, irradiation, and genetic engineering.

The next paragraph can then include among organic practices the use of compost, mulch, cover crops, hedgerows, and diversified borders and interplantings.

Invasive Pests and Diseases on page 9-35 should be renamed Pest and Disease Management to accurately reflect the full scope of highest priority farming practices that prevent pests and disease. We would like to see that section begin by acknowledging the exceptional history and achievement of Ventura County farmers, landscape managers and gardeners with preventive practices that diversify farm ecosystems, build soil and plant resistance to pests and disease and thus proactively avoid use of pesticides.

Biologically Based Pest Management in Ventura County: Ventura County has been the historical home to seven beneficial insect production companies including three grower-owned cooperatives whose members were or are economically successful thanks to their investment in biologically-based pest management services. Least-toxic pest control products are manufactured and sold in the county and sold by many agricultural suppliers. The precautionary principle guides pest management decisions for many growers who do not use high-risk pesticides except as a last resort when there is no alternative to save a crop. There is a legacy and current investment in cutting edge knowledge about alternatives to the use of toxic pesticides. Despite the access to biologically based pest and disease management resources, pest management information from the county’s cooperative extension and Master Gardener Program are provided in a framework of Integrated Pest Management in which toxic pesticides are more commonly recommended than preventive and biologically based solutions.

The UC Cooperative Extension, Center for Regenerative Agriculture (CRA) and the Dietrick Institute for Applied Insect Ecology (DI) are among the institutions that extend those Best Management Practices. Dr Ben Faber at the UC Cooperative Extension has, for example, been promoting the use of mulch in orchards for over twenty years, a practice that conserves water and holds carbon.  David White has led CRA to host four courses in Ojai by the world-reknown soil ecologist Elaine Ingham resulting in approximately 150 graduate soil foodweb practitioners in the region. DI’s recommendations for enhancing beneficial insect habitat using non-crop borders, interplantings and hedgerows remain a common practice seen beautifying farms and attracting and providing food for naturally occurring beneficial insects.

Bill Camarillo of Agromin may provide over 90 percent of the compost and mulch applied on working lands in the county; those quantities should be part of the record. Jamie Whitecomb at the Ventura County Resource Conservation District and Dawn Afman, USDA-NRCS Soil Conservationist are familiar with soil conservation practices, achievements and needs through promotion of the Organic Environmental Quality Incentives Program (EQIP). Transition to Organics Ojai maps lands that are managed biologically to avoid toxic pesticides and sequester carbon.

The CALANDS model being developed by CARB for tracking statewide goals and targets for carbon sequestration now offers a reliable regional framework. The COMET-Farm Voluntary Carbon Reporting Tool allows farmers/ranchers to estimate carbon values for various management practices in order to apply for California Healthy Soils Initiative payments from the Greenhouse Gas Reduction Fund. There is know-how and funding to quantify baseline and changes in carbon and emissions for all land categories by type, ownership and management practices or by degradation due to drought, fire, flood, or agronomic inputs.

Farm and Community Linkages

We strongly recommend that a section on this topic be added, perhaps on Farming Operations on page 9-35 to celebrate the good news story about Ventura agriculture’s growing high-quality interactions with the community at large. This relationship has been fostered for decades through the UC Hansen Trust whose mission is to sustain agriculture in Ventura County through research and education to benefit the community as a whole.

The Students for Eco-Education and Agriculture (SEEAG) founded in 2008 by Mary Maranville has held a Farm Day every fall since 2012 with self-guided tours to 20 unique agri-tourism destinations that can be found in Ventura County to connect people with their agricultural roots.

SEEAG also made a remarkable achievement in 2017 hosting every third grader in Ventura County to Petty Ranch for Farm Lab. The lesson includes “The Journey of our Food”, “The Biology of Healthy Farm Soil”, “Bugs: Pollinators, Pests and Beneficials”, and “The Life Cycle and Science of Plants” and the next class of third graders will enjoy these learning experiences.

SEEAG and other organizations also provide lessons about agriculture for middle and high school students in the S.T.E.M. program. High school students attend the Annual Agriculture Career Fair held at the Museum of Agriculture in Santa Paula that also hosts tours with stations focused on plant growth, farm to table labor dynamics, seasonal produce, beneficial insects, farm practices past and present, water issues, and more. Santa Paula High School is the site of a new school farm as well as a thriving Future Farmers of America program and a new self-funding horticulture therapy training program, Growing Works, is launching in 2018 in Camarillo. There are three Grange programs with youth livestock programs in the county in addition to 4H.

The Ventura Unified School District (VUSD) is the site of one of southern California’s premier Farm to School programs. The program’s goals are to provide local students with healthy lunches and nutrition education and connect schools to local farmers. Ojai’s Food for Thought program is also a collaboration with Farm to School. Many other schools have school gardens, often with small grants from Captain Planet Foundation where lessons are tied to common core curriculum standards and encourage inquiry-based and hands-on experiential learning. Among them are E.P. Foster Elementary, Mound and Sheridan Way Elementary schools in Ventura; Rio Del Norte Elementary School and Tierra Vista Elementary in Oxnard; and San Antonio Elementary School in Ojai.

Finally there are 12 Farmer’s Markets, 14 Community Gardens and the Abundant Table Farm was awarded a multi-year USDA grant to found a Food Hub to improve market access for producers along with their potential for expanding the availability of healthy, fresh food, especially in underserved communities.

3. Water Chapter: 

What appears missing in the Water Chapter is a focus on what happens to rain in the hills above each of the county’s three watersheds. There have been decades of erosion in upland gullies, flooding and denuding the land as stormwater floods into the three main rivers and to the sea. Some hydrologists see the intensified drought, wildfire and floods that are coming with climate change as symptoms of a global pattern of failure to safeguard the ability of the uplands to slow and sink rain water into the ground. Also, in developed areas, impervious pavement is further causing not just with heat island effects but, due to channeling of rain water into storm drains and out to sea, is dehydrating developed lands.

These conditions need to be included in the background document to provide a framework for goal-setting to reverse these trends through small earthworks, such as catchments, swales with diversions, microbasins, and many other measures that capture stormwater to prevent flooding and its contribution to sea level rise, make the streams and rivers stable and fed by underground water movement that best supports fish populations, support a succession of perennial vegetation to restore degraded lands and reduce heat islands while sequestering carbon and through increased evapo-transpiration restoring small cooling water cycles or microclimates. Where rain water flows is closely tied to the Climate Action Plan because you cannot sequester more carbon when the soil does not hold water, nor can you effectively mitigate the conditions for wildfires or flooding when the soil has lost water-holding capacity. It was clearly observed that irrigated land served as a firebreak in the Thomas Fire, except when palms and arundo were present. Even well-watered eucalyptus trees did not burn.

The hydrologists with a new organization called Rain for Climate explain the process of degradation and restoration of small water cycles. The principal hydrologist Michal Kravcik worked with me and wrote the attached proposal last May for how to apply these principles to the Ventura River Watershed Initiative.

Michal Kravcik is now putting his attention on the upper tributaries of the Santa Clara River. We learned from the county hydrologist that the high probability of flooding at the levee at River Park is forecast to be 60% fed by Sespe Creek. Small measures to re-hydrate and vegetate the uplands of Sespe Wilderness Area could remove the need for the proposed $41 million levee repair that engineers said may still not stand up to the big flood predicted even before the fires.

We recommend that the background document for the Water Chapter describe not just the hydrology of the streams, riverbeds and water stored above and below ground, but to put attention on the opportunities coming with the rapidly shifting paradigm about the advantages and methods for keeping rain where it falls, especially in the hills above our towns. The techniques are proven, very inexpensive, capable of being done by volunteers with hand tools, and the benefits go far beyond local storm water management. At risk of troubling wildlife professionals who have had some bad experiences with beaver, we would like it on record that evidence has been found that beaver once inhabited the Sespe wilderness. We have recently been persuaded that reintroduction of beaver in the uplands of the Sespe would bring potential services for flood prevention that far outweigh their annoying, but manageable behaviors.

On page 10-2 are found the general practices associated with land development of vegetation removal and channeling water to the ocean. It states, “Some development can significantly alter land topography. Removal of natural vegetation and manmade structures such as levees, dams, and diversion structures disrupt natural hydrologic processes (i.e. sediment transport and deposition, groundwater recharge). These changes alter water velocity, river substrate, water shading, soil moisture, and other ecosystem characteristics needed by fish and wildlife.” 

What is missing from that list of impacts is flooding, heat island effects and desertification that are drivers of  climate change. These impacts are contributing to global warming and sea level rise. Reversing these negative impacts of development will cool and stabilize microclimates because natural hydrologic processes involving latent heat of evapotranspiration from vegetation are restored and the mulch layer on soil and the root systems receive and hold rain water. The sum of many such mostly small, simple local actions can stabilize the climate over whole continents.

Thanks for the opportunity to share our perspectives.


Jan Dietrick, MPH, President, and Ron Whitehurst, PCA, Co-Owners

Rincon-Vitova Insectaries, Inc, 108 Orchard Dr, Ventura, CA 93001



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