Re: 2009 California Climate Adaptation Strategy Discussion Draft at CNRA Public Consultation meeting in Sacramento on Thursday, August 13th
(Note: Formal Comments will be submitted later this month).EWG would like to offer several suggestions for strengthening and prioritizing adaptation strategies presented for the agricultural sector. Given the significant costs and impact of climate change on agriculture, we believe that higher priority should be given to implementing near-term, cost-effective strategies to minimize that impact and reduce greenhouse gas emissions—starting with a stand alone priority recommendation for agriculture in the executive summary.
1. First, and most importantly, we believe the adaptation strategy should give higher priority to adaptation measures that will also reduce greenhouse gas emissions. Specifically, we would like to see greater emphasis on the promotion of proven, cost-effective soil management strategies, such as cover cropping, conservation tillage, mulching, nutrient management and organic agriculture. These practices will make soils healthier and more productive and farms more resilient. They will also reduce greenhouse gases, improve water quality and conserve soil and biodiversity.
2. While the report makes some excellent recommendations for addressing water quality and conservation, it fails to mention the value of these kinds of soil management practices (mentioned above) for improving water capture, infiltration, and storage. For example, increasing soil organic matter by one percent can enhance water storage in the soil by 16,000 gallons per acre-foot.
The document neglects another key strategy for conserving water: discouraging thirsty crops like alfalfa and cotton that just don’t make sense for arid climates. Alfalfa growers use as much water as all the cities in California put together. The strategy should recommend the use of incentives to encourage farmers to plant water-efficient crops.
3. As the climate warms, pests and weeds are expected to multiply more rapidly. The strategy should promote more strongly management techniques such as advanced integrated pest management, fertilizer efficiency and organic agriculture, to help farmers minimize the use of chemical fertilizers and pesticides.
4. To be effective in targeting programs and information, California state agencies need a better understanding of the most urgent needs and opportunities for addressing climate change impacts on agriculture. The state currently lacks essential information about soil and water management practices on California farms as well as an understanding of the barriers that farmers face in implementing these practices. We strongly recommend that CDFA undertake a broad- based survey of the agricultural community to obtain this information, as well as to learn about farmers’s attitudes and knowledge about potential climate change impacts. The European Commission conducted such a survey, with important results. We will file that survey and results as part of our written submission.
5. Political decision-makers, the agricultural community and scientists do not have a robust mechanism for exchanging information on climate change. The adaptation strategy should give higher priority to sharing information with the farm community and to those working closely with farmers. It should create a mechanism for information exchange among the wide range of entities concerned with agriculture and climate change in California.
6. Ultimately, strategies are effective only if they are actually implemented. In this regard, we are very concerned about the lack of resources, institutional capacity and leadership in the state on agriculture and climate change issues.
- The California Department of Food and Agriculture (CDFA) has no staff or resources dedicated to agriculture and climate change.
- The California Air Resources Board (CARB) also has a very limited focus on agriculture and climate change.
- The Agriculture Climate Action Team, initially established to give CARB input on agriculture and climate change, has been disbanded.
Given the strong links between adaptation and greenhouse gas emission reduction, EWG strongly recommends that the California Natural Resources Agency, CDFA and other relevant state and federal agencies, collaborate with CARB to form an inter-agency working group on agriculture and climate change that addresses both adaptation and reduced greenhouse emissions from agricultural activities.This inter-agency group could provide a much-needed forum for intensive stakeholder engagement and outreach on these issues—and a means to folluw up on many of the worthy recommendations in the report—as well as other recommendations offered by farmers, scientists and others with a stake in the outcome.
7. In this time of scarce resources, the state must husband its time and money carefully. EWG believes that effective implementation requires a reallocation of resources within CDFA and/or the Resources Agency to establish at least one full time staff dedicated to the issue of ag and climate change. We would also like to work with you and other stakeholders to ensure that California takes advantage of United States Department of Agriculture conservation programs to integrate and prioritize support for ag adaptation strategies as it allocates funds.
We also believe allowance revenue generated by the cap and trade program, either at the state or federal level, should be used to support adaptation measures--with specific resources for agriculture.
Thank you for the opportunity to offer our comments. We look forward to working with you and other agencies and stakeholders to ensure implementation of many of the actions outlined in your report as well as additional actions that we and other organizations have suggested.