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A Meeting SUMMARY: Noxious Weed Free Forage Stakeholder
Meeting, June 25, 2002 I. ATTENDEES (*Indicates steering committee members)
II. PROGRAM REVIEW, ANNOUNCEMENTS, AND NWFFM INTERN INTRODUCTIONS Joanna Clines, the meeting facilitator, gave a brief review of the program. She stated that the program began when the Bureau of Land Management (BLM) and the US Forest Service approached Ag Commissioners in 1999. Karl Bishop formed a subcommittee of CACASA to draft certification guidelines in response to anticipated closure orders in California National Forest and BLM lands. Nate Dechoretz, Branch Chief of the Integrated Pest Control Branch in Plant Health and Pest Prevention Services, gave an overview of the California Department of Food and Agriculture (CDFA), summarizing the functions of various branches. CDFA probably has the most aggressive noxious weed programs in the West. CDFA relies heavily on various partners, especially the county agricultural commissioners and the land management agencies (e.g. USFS, State Parks, BLM, National Park Service). He stressed that all the federal land management agencies have national strategies that emphasize prevention and education in cooperation with the states. As such, CDFA has agreed to participate in the WFFM program in California, and has hired Bonnie Davis and Stephanie Balsdon to move forth with the educational component of the program supported with funds from the USFS and BLM. Nate emphasized the need for a transparent NWFFM program with clearly stated roles of all parties. Other CDFA branches have roles here (e.g. Pest Exclusion Branch). Compliance agreements and certification are under Nate's branch. In summary, there is a need to clarify how the CDFA is involved with the NWFFM Program. (To learn more about CDFA structure, go to http://www.cdfa.ca.gov/phpps br.htm) The education coordinators introduced themselves to the group, and provided the following information: Bonnie Davis is focusing on the education of equestrians and feed stores. She maintains and updates the website www.weedfreefeed.com. An important function of the web site is a continually updated list of outlets for NWFFM and other products, such as pellets or chaffhaye. Bonnie may be reached at (510) 657.5239 or horsecamping@attbi.com. Stephanie Balsdon will focus on growers' concerns and informing others about this program. She will be conducting background research as requested by the steering committee. To date, Stephanie has drafted a brochure entitled "The Noxious Weed Free Forage and Mulch Program in California," has researched an summarized how forage and mulch are known to contribute to the spread of noxious weeds, by both observations and scientific research, in addition to contacting publishing agencies to distribute program information. Stephanie can be reached at (916) 654.0768 or sbalsdon@cdfa.ca.gov.
III. ALFALFA HAY GROWERS' CONCERNS, CALIFORNIA ALFALFA AND FORAGE ASSOCIATION (CAFA) Tom Ellis, Chairman of the California Alfalfa and Forage Association (CAFA), stated the concerns the membership has with the Noxious Weed Free Forage and Mulch (NWFFM) Program. CAFA requests the following amendments to the certification guidelines as addressed in the points made in a recent letter to CDFA dated June 17, 2002.
*The steering committee agreed to work on this in the near future. CAFA market concerns: The functioning relationship between the NWFFM program and the markets in California and the region in terms of:
IV. ALFALFA HAY GROWERS' CONCERNS, SAN JOAQUIN VALLEY HAY GROWERS ASSOCIATION Rick Staas, General Manager, expressed concerns in a letter sent prior to the meeting. He proposed to remove the following from the guidelines: Field inspection from 5 days prior to harvest and field removal within 14 days of harvest due to marketing and possibility of increased herbicide use Concerns:
V. CONCERNS FROM THE GROWERS' PERSPECTIVE Several growers expressed their concerns for this program possibly having a premium and then become a quality standard. Also, environmental regulations should be a consideration with a program such as this due to standards that growers must meet on "both sides." It was suggested that information be obtained on the type of regulations that growers must meet and compare that to what requirements the program will demand. *Stephanie is researching these issues. The concern of how accessible inspectors will be in relation to how quickly a grower may need his field inspected in order to remove it from the field was expressed. Commissioners are already very busy. If inspectors are not available, growers could be detained or not certified. Additionally, there may be variances in how fields are inspected due to experience, time, etc. Tom Ellis and Dan Putnam mentioned their concern for both domestic and foreign markets, the Japanese market in particular. Again, concerned with this program creating a quality standard. The demand could spread throughout the marketplace, with little likelihood of the producer being able to pass the increased cost of production to the consumer.*Obtaining opinions of exporters in California on this subject. Feel that stack inspections should be reconsidered as an alternative inspection process to be included in the guidelines. *The steering committee has agreed to work on this in the near future. There is no reason changes cannot be made as long as the product meets the objective of preventing noxious weed spread.
VI. CONCERNS FROM THE EQUESTRIAN COMMUNITY Toby Horst stated that, several years ago, the Back Country Horsemen (BCH) of California surveyed other BCH members in other states where NWFFM programs have been in place, and the price increase for certified products was quite variable. Bonnie Davis said that all feed stores she has contacted would like to carry NWFF, and that she was charged at $15 per bale at one store that was selling non-NWFF for about $7 per bale. Marjorie Matthews would like to start a small, organic farm. She has been told by the Marin County Planning Department that she has to use NWFFM on her private land. Nate and others said the planning department has no legal basis for being able to make her use NWFF on her private property, but Connie and Marjorie said the planning department has a high authority in Marin County. She is concerned that NWFF will have been exposed to pesticides and that she would not be able to be certified organic, especially if Transline was used because of the problem with its' persistence in compost. *Stephanie will be researching whether NWFFM will be likely to have more pesticides than other hay or straw.
VII. DISCUSSIONS AND STATEMENTS CHEMICAL CONCERNS Norm Yenni had an inspector come out to certify approximately 200 acres of hay. The inspection was completed in 1-2 hours, but was uncertified because he had small patches of morning glory (field bindweed). He stated he would have to go from using a small amount of a Category III herbicide to greater quantities of a Category I chemical (more risk to health and the environment) in order to control the weed. The horse people made the point that there are several dairies within the Point Reyes National Seashore (National Park Service lands), so it may be appropriate to have a permanent exemption on the part of the NPS when they do their closure orders. Tom Ellis stated that chemicals are coming under closer scrutiny by Cal/EPA and some environmental groups. For example, Velpar and Carmex are key "tools" for established alfalfa stands. This is important because of implications for increased cost and ability to produce NWFF if chemicals are less available and/or more expensive. Also, there will be environmental implications if additional pesticides are required to maintain fields in a more noxious weed-free condition.
CONTACTING WESTERN NWFFM STATES Kiran Johl of the California Farm Bureau Federation (CFBF) said she contacted other states with NWFFM programs, such as Idaho and Montana; however, she was not able to obtain information about their programs at that time. Bonnie Fernandez of the California Wheat Commission made said it is a good idea to research NWFFM programs in other states; however, the knowledge needs to be interpreted carefully as our economy in California is unique. Tom cautioned Stephanie when contacting other states to learn about their programs, and realize that the opinions will be quite different depending on whether she is speaking to government officials or growers. Tom said some Montana growers are still not sure whether they will be able to recoup the increased cost of production for NWFF.
HORSES AND FEED There was a very brief discussion regarding pellets. To date, only Nature's Best pellets are processed in a mill certified by CDFA. Mark Quisenberry had done some research on this issue. *Mike Boitano said he would follow up on this. Connie Berto stated that in 1998, Envirohorse formed to address the need for scientific evidence in cases of claims that horses have a negative impact on the environment. See http://www.californiastatehorsemen.com/environhorse.htm for more information on Envirohorse.
VIII. TWINE Dawn Rafferty, Nevada's Noxious Weed Program Coordinator, described the progress of Nevada in implementing a NWFFM program. (see http://agri.state.nv.us/weed.pdf for more information on Nevada's program): She initiated the program last year by visiting as many growers as possible in order to educate them about the program. She stated that Nevada was a fairly easy state to implement a NWFF program in, and that it has been working well thus far for her. Last year, Nevada certified 2,800 acres. She hires independent contractors to inspect the fields; there are currently nine. She used an USDA grant to purchase the special, bi-colored twine, the same blue and orange twine used by Colorado and Montana. She brought a twine sample with her.
IMPLICATIONS WITH USING SAME TWINE AS OTHER NWFFM STATES The problem with using the twine in California, however, is that it only covers species on the weed list used by the Colorado association of states. Karl Bishop researched this issue in 1999, and their list has approximately half the number of noxious weed species that California does. The North American Weed Management Association (NAWMA) is working on a list that may be used by states' NWFFM programs throughout the West. This list would be unlikely to work for California, as our weed list is comprised of more than 130 species, reflecting California's high diversity of growing conditions and habitats. Karl pointed out that even if we as a steering committee agreed to the Colorado or NAWMA list, a person carrying certified hay could reach a California border station and have the hay confiscated for containing weeds on California's noxious weeds not on the NAWMA list.
CERTIFIED PRODUCT IDENTIFICATION Discussion continued on various ways bales could be identified as certified. A grower stated that the program should continue moving forward, regardless of whether or not twine is available, so that growers may prepare for the market demand. Tags were mentioned as an optional way of identifying certified NWFFM products. Toby Horst stated that equestrians prefer twine identification for simplicity. Federal agencies would also prefer twine so our law enforcement personnel could enforce the program fairly. Caltrans also prefers twine. There was a technical discussion of various twine strengths. Norm Yenni said to keep in mind that large bales need 300 knot strength, and most balers use a 240 knot strength. There are an estimated 60% of growers who hire custom balers. Duane said that when baling 12,000 bales per day, it is very difficult to change a different colored twine for certified products. Toby Horst stated that it would be easier for horsemen to be able to identify hay with a unique twine. The Caltrans representatives who were present agreed that this is the easiest method for them as well. There were responses that both supported and suggested scenarios where having a unique twine would be difficult. It would be difficult to use unique twine due to acquisition, transportation, and the fact that most hay growers have someone else bale their hay for them. However, a unique twine can easily be identified and would make it more difficult to replicate. It was decided that there would be a twine subcommittee.
LUNCH BREAK
IX. TIME LINE The timeline for the program has been revised. The new timeline is:
NEPA DOCUMENTS The NEPA documents were discussed and clarified Cheri Rohrer explained how a signature on a NEPA decision document differs from a signature on a closure order, e.g., the Environmental Assessment (NEPA document) could be signed in December of 2002, but the closure order signed in April of 2003. Dianna Brink, BLM, stated that she has written the Federal Register notice for their Closure order, but that the Department of the Interior is delaying all Federal Register Notices by several months as the result of a new review process. Documents have been in Washington, D.C., for several months now. The documents will hopefully be completed by the end of 2002, this year. Mietek Kolipinski noted that he will be hiring a person for 2 years, full-time, in order to work on the NPS NEPA documents.
SCOPING LETTER It was stated that several people and organizations did not receive the scoping letter, and that it had inadequate distribution. Cheri Rohrer felt that adequate scoping had been performed, as 50-60 responses had been generated by a letter. Also, she noted that there had been several public meetings, which are also considered scoping. Cheri Rohrer will not be re-sending the scoping letter, however, she will take additional letters and comments regarding the letter for another 4 weeks from the date of the meeting. The point was made that the program should be implemented for the permittee holders and other land users at the same time.
X. CONCLUSION Twine was briefly discussed again, and it was resolved that the subcommittee for twine will research possibilities. Alternatives to twine and twine options were discussed. It was decided that a proprietary twine is needed, and that growers will be able to obtain the twine from the inspector that certifies their field. |