Advocacy in Action

Climate strategy

The California Farm Bureau provided public comments during a listening session last week on the state’s development of a climate resilience strategy for California agriculture. Richard Filgas, an assistant director of policy advocacy for the California Farm Bureau, called for a strategy that aligns with the state’s vision for a sustainable and equitable future while protecting farms and their ability to combat climate change. 

He stressed that development of the strategy should recognize the various factors that influence the scale and pace at which climate-smart practices are adopted by farms and ranches, including weather, markets and pests. Goals and policies set by the state must fit within the technological and business capacity of farming operations, he added. He also emphasized the importance of funding agricultural research. 

The California Department of Food and Agriculture will release the draft strategy this summer. For more information, visit www.cdfa.ca.gov/climate/.

Energy

The California Farm Bureau in January filed its opening testimony in the Southern California Edison 2025 General Rate Case Phase 2, which considers allocation of costs to customer groups and the design of rate schedules. 

Under Edison’s amended testimony, TOU-PA-2, which refers to small- to medium-sized agricultural and pumping customers with demands below 200 kilowatts, would receive a 6.7% decrease in current rates, while TOU-PA-3, which refers to large agricultural and pumping customers with demands from 200 to 500 kW, would receive a 10% increase. This results in a class-average increase of 0.4%. There were additional agricultural-specific rate design changes, including a 33.8% increase to the TOU-PA-3 monthly customer charge. 

Farm Bureau’s opening testimony focused on opposing the Public Advocates Office’s position on wildfire cost allocation and changes to Edison’s calculation of peak load risk factors. In addition, Farm Bureau noted the variance in impacts to TOU-PA-2 and TOU-PA-3 would need to be rectified, including rejecting the proposed TOU-PA-3 monthly customer charge increase. Finally, Farm Bureau proposed a well pump test credit modeled after the existing wind machine credit to provide some relief from demand charges in nonirrigating months when pump upgrades are planned or when flow testing is required under the Sustainable Groundwater Management Act. Parties began settlement discussions on Jan. 16 and will continue for the next two months in hopes of reaching partial or full settlements.

Water

The California Farm Bureau submitted comments on the California State Water Resources Control Board’s draft Phase 2 Sacramento-San Joaquin River Bay-Delta water quality control plan amendments. The board’s Phase 2 amendments consider two basic alternatives for required instream flows to protect native fish in the Sacramento River watershed and delta. One is a regulatory pathway and potential regulatory backstop, based on a proposed 45% to 65% January through June unimpaired flow requirement. 

The other is a comprehensive water user-backed mix of flow and nonflow commitments within a certain adaptive implementation framework, referred to as the Healthy Rivers and Landscape proposal. 

Farm Bureau’s comments focused on potential severe water supply and economic impacts and on various technical and practical difficulties associated with the board’s regulatory pathway proposal. The comments also focused on various comparative advantages of the proposed Healthy Rivers and Landscapes proposal. How to deal with parties not part of the proposed Healthy Rivers and Landscapes voluntary agreement and water quality and other concerns in the Sacramento-San Joaquin River Delta were additional areas of focus. Based on public input and ongoing work and discussions, the board is expected to consider a revised set of amendments for potential adoption sometime this year.

Farm Bureau also submitted comments on a water board proposal to renew a set of standing drought emergency regulations for the Scott and Shasta rivers, which are within the larger Klamath River Basin. Farm Bureau’s comments focused on the absence of requisite drought conditions for such an extension and included points on the proposed regulation’s continued misguided focus on late summer mainstem minimum flows that provide few benefits to target salmon populations while inflicting significant ongoing impacts on growers and ranchers who use water from the Scott and Shasta rivers. The emergency drought regulations are proposed as a placeholder until the board can complete nonemergency regulations for permanent baseline minimum flows across all water year types. A longer-term proposal and the subject of a pending petition by tribal and environmental interests in the area involves eventual permanent, higher, variable recovery flows specific to different water year types. 

Local cooperative solutions under the proposed emergency regulation are a key alternative and source of important flexibility for agricultural water users in these watersheds, said Justin Fredrickson, senior policy analyst for the California Farm Bureau. Such solutions would avoid some of the worst impacts of the board’s default flow requirements from widespread curtailments. 

“Problematic aspects of the board’s emergency and proposed permanent flow regulations in the Scott and Shasta rivers watershed are of significant note, as they set a disturbing precedent and could have potential adverse statewide implications,” Fredrickson added. 

In addition, Farm Bureau submitted comments on an upcoming scientific-basis report that the water board says it will use to eventually consider potential permanent instream flows to provide alleged protections to spring-run chinook and steelhead salmon on Mill, Deer and Antelope creeks, three undammed salmon-bearing upper Sacramento River tributaries. These proposed permanent flows parallel and in several respects resemble the permanent long-term flows proposed by the board in the Scott and Shasta rivers watershed, on which Farm Bureau also submitted recent public comments. 

Analyses show the California Fish and Wildlife Department-recommended flows—currently proposed as a point of departure for the board’s eventual scientific-basis report—would leave the waterbodies entirely without water for late-summer irrigation in many years and could still not be physically met, even with theoretical 100% curtailments. Farm Bureau’s comments focus on this aspect of the board’s proposed scientific-basis report, among other related issues, including the board’s legal authority to impose such flows.

Pesticides

The California Department of Pesticide Regulation is developing new regulations and is partnered with the Office of Environmental Health Hazard Assessment to potentially increase mitigation measures for 1,3-Dichloropropene, or Telone, a preplant fumigant. Public hearings were held in January in Visalia, Salinas and Chico. 

Farmworker activists overtook the Salinas hearing when several protesters staged a mock “die-in” by lying on the ground near the podium. Farm Bureau gave public comment at the Chico hearing, which was not attended by activist groups. Farm Bureau also submitted formal comments to highlight several elements of the proposed regulation that raise significant concerns, including increased costs and operational complexities for growers. The proposed setback distances range from 100 to 500 feet, depending on numerous factors, reduce the amount of usable land and could negatively impact crop yields, particularly for smaller growers.