CCM submitted comments on the Criteria Pollutant and Air Toxics Reporting Draft Regulations this past August.  We urge CARB to respond to those comments and welcome further dialogue on the Draft Regulations.

There are several areas in the Criteria Pollutant and Air Toxics Reporting Draft Regulations that we have concerns with.  First, we are concerned that without clarification, farms and ranches could be subject to the reporting requirements based solely on their fugitive emissions. Farms and ranches are already regulated to control fugitive criteria pollutants and dust. We believe that by not specifically clarifying that only those stationary sources that have a permit to emit more than 250 tons of non-fugitive emissions or are located in an area selected by CARB based on the release of non-fugitive emissions, the draft regulation will cause confusion and result in unintended impacts whose economic consequences have not been thoroughly evaluated.

Our primary concern is one of duplication or redundancy or layered regulation when it comes to pesticide reporting.  Our growers share a concern for public safety and the safe use of pesticides.  In fact, it was agriculture that promoted the legislation that created 100% pesticide use reporting and the mil assessment to support the Department.  In doing so, data is submitted regarding their pesticide use to the County Agricultural Commissioners. We ask that CARB seek the pesticide use reports from DPR that is acquired from all in order to prevent unnecessarily wasted resources going towards an entirely new, costly, and redundant reporting system.

CCM recently sponsored a report by Bruce Babcock of UC Riverside to look as just some of the regulatory costs faced by citrus growers in the state of California.  Higher labor costs and their associated costs of compliance, ACP and HLB control costs, costs for maintaining water quality and quantity.  Not included in this report is the latest ask by CARB for growers in the Central Valley to replace 12,000 tractors by 2024.

When you look at all these costs, it is easy to see why the California Department of Finance stated that “All economic sectors except agriculture contributed to California’s higher GDP.”

It is imperative to reduce competitive disparity of this historic California crop, and agriculture as a whole; we must use all the tools at our disposal in the most efficient way possible.  This draft regulation is duplicative, is redundant, is vague, creates costs, wastes resources and supports the perception of government inefficiencies.