VENTURA COUNTY AGRICULTURAL POLICY ADVISORY COMMITTEE

P.O. Box 889, Santa Paula, CA 93061
Telephone: (805) 933-2095
Fax: (805) 525-8922

July 24, 2002

Board of Directors
Sustainability Council of Ventura County
P.O. Box 7817
Ventura, CA 93004-7817

SUBJECT: Limits to Growth and Quality of Life in Oxnard, California—Sustainability Indicators

Dear Board Members:

The Ventura County Agricultural Policy Advisory Committee (APAC) reviewed the Fall 2001 summary of the sustainability indicators presented in Limits to Growth and Quality of Life in Oxnard, California. The APAC is comprised of 5 growers appointed by the County Board of Supervisors to advise them, the County Planning Commission, Local Agency Formation Commission (LAFCO), and other decision makers regarding all matters affecting the county’s agricultural resources and the local agricultural industry. The APAC discussed the sustainability indicators at their February 13, 2002 meeting, and raised a number of concerns, particularly with the pesticides indicator.

Pesticides Indicator

The discussion of the pesticides indicator presents a number of misleading statements regarding the use of pesticides in the county. The pesticide use reported to the State Department of Pesticide Regulation (DPR) includes the amount of pesticides applied to public rights-of-way, structural applications, and landscape maintenance, in addition to agricultural applications. Those pesticides used in non-agricultural applications can be identified from the index of pesticides used by chemical or by commodity included for each county on the DPR web site; unfortunately, the listings do not indicate the toxicity of each chemical so that it can be easily determined by the public whether the use of toxic chemicals is increasing or decreasing.

According to DPR, the amount of pesticides applied in Ventura County increased from approximately 6.6 million tons in 1999 to 7.2 million tons in 2000, or an increase of 8.6 percent. The Agricultural Commissioner’s Office determined that this increase is largely attributable to the use of larger amounts of heavier oils on citrus and avocado orchards. Petroleum and mineral oil products that are diluted with water are increasingly being used by orchard growers as pest-control alternatives to more toxic chemical sprays. Oils must be applied more often to be as effective as the more toxic products. The DPR data for the top five chemicals used in Ventura County show that while about 3 million pounds of petroleum and mineral oil were applied in the county in 2000; during the same period, 1.7 million pounds of methyl bromide were applied. In 1999, 2.42 million pounds of oil and 2.07 million pounds of methyl bromide were used. The use of methyl bromide decreased by 16 percent from 1999 to 2000, due primarily to the phase-out of the production and importation of the chemical by 2005, as mandated by the Montreal Protocol.

The pesticide sustainability indicator discussion presents the argument that since the amount by weight of pesticides applied to Ventura County agriculture is increasing, the use of toxic chemicals also is increasing. However, a comparison of the 1999 and 2000 DPR pesticide use data shows that the application of less toxic but heavier materials such as oils has actually increased. The pesticide indicator should be revised to clarify that the use of more pesticides (by weight) is not the same as the increased use of toxic chemicals. Further, it should also be pointed out that growers use certain pesticides due to a variety of factors, including the lack of less toxic alternatives that are as effective, the cost of pesticides, and that all pesticides (including less toxic ones) are not allowed to be used on all commodities. In addition, the potential health risks associated with the application of toxic pesticides can be avoided if they are applied in accordance with the label requirements and State and federal pesticide regulations. We commend the pesticide indicator author for recognizing that the amounts of pesticides used in residential or other private, non-agricultural applications, although not reported to the DPR, are of concern due to the excessive amounts used and the lack of knowledge of potential risks of the persons applying the pesticide.

The pesticide indicator also refers to a non-toxic material called Clandosan, and states that statewide, the use of non-toxic pesticides is approximately 0.02 percent. Pesticide use enforcement staff at the County Agricultural Commissioner’s Office is not familiar with Clandosan, and requests that the source of this statement be cited. Does the “0.02 percent statewide” mean that of all the pesticides used statewide (including non-agricultural applications), only 0.02 percent are non-toxic materials? Please clarify.

No Discussion of Value Judgements in Summary

The APAC noted that indicators cannot be developed unless one makes value judgements about what is important to one’s quality of life. The summary of sustainability indicators does not describe the value judgements that the indicators are based on. The full report, however, does identify goals that are desired by the authors, and then proposes the indicators to measure whether the goals have been achieved. The APAC is concerned that the summary, which was more widely distributed to the public than the full study, does not identify the goals (value judgements), and therefore the public is generally unaware of the basis for the sustainability indicators. It should also be noted that peoples’ value judgements differ, based on their experiences and information that has been provided to them, among other factors. Different value judgements are acceptable, provided that they are identified so that the public may decide whether they agree with them.

Ratio of Total Farmland Acreage to Population Indicator

What is this indicator really measuring? The goal of this indicator is to establish “ . . . equilibrium between land uses and the number of County residents, and to maintain an appropriate balance between the amount of farmland and the County population.” However, the discussion does not identify what is an “equilibrium” (does that mean ratio?) between land uses (all land uses, not only agriculture?) and the County’s population. Further, what is meant by an “appropriate balance” between the amount of farmland in the county and the County population? Even if the amount of farmland per resident continues to decease in the future, how can it be determined that this is not an “appropriate balance”? Additional population can be accommodated in the county without losing equivalent farm acreage by increasing the density of development that occurs on non-agricultural land. This would be consistent with “smart growth” concepts and the goals of the multi-family housing units, population density, and high density zone changes/permits indicators discussed in the Sustainability Indicators report. Therefore, a ratio of farmland acreage per County resident that decreases over time is not necessarily an adverse occurrence reflecting a trend away from sustainability, as stated in the Sustainability Indicators summary.

Farmland can include a variety of different types of agricultural soils. Is the intent of this indicator to measure the acreage of “prime” farmland that is annually converted to other uses or all types of land identified as farmland by the State Department of Conservation, Farmland Mapping and Monitoring Program?

According to the Executive Summary, the purpose of the study effort was to develop indicators to measure quality of life issues affecting the City of Oxnard. Therefore, it would have been more appropriate for this indicator to address the ratio of total farmland acreage (irrigated agricultural land including prime, statewide importance and unique farmland identified by the Farmland Mapping and Monitoring Program) per population within the City’s Area of Interest. Even with this change, the purpose of this indicator remains unclear.

Ratio of Total Farmland Acreage to Urbanized Land Indicator

Similar to the ratio of total farmland acreage to population indicator discussed above, the text does not explain what this indicator is really measuring. Again, the term “farmland” is not defined. Based on the data provided, it is obvious that more development in the county is occurring on non-agricultural land than on farmland. As a result, a ratio of total farmland acreage to urbanized land that decreases over time is not necessarily an adverse trend away from sustainability, as stated in the Sustainability Indicators summary. It should be noted that the discussion of the value of lemons and all County commodities in 1998 is not relevant to determining whether the identified goal is met. Further, this indicator could be revised to address the ratio of total farmland acreage to urbanized land within the City of Oxnard Area of Interest, as discussed above.

A more appropriate way to measure whether the stated goal of retaining “. . . sufficient farmland to allow the agricultural industry to prosper . . . ” is achieved is to address the correlation between the amount of land in agricultural production and agricultural support industries. As noted in The Value of Agriculture to Ventura County: An Economic Analysis (Ventura County Agricultural Land Trust and California Coastal Conservancy, 1996), support businesses such as packinghouses or agricultural management firms thrive and expand when agricultural production prospers. If agricultural lands are reduced or productivity declines, support businesses may have no other option than to close their doors or relocate to another agricultural area. The APAC recommends that the Value of Agriculture study be used as a starting point to develop an indicator that addresses this correlation and therefore actually measures the identified goal.

Civic Engagement Indicators

The full Sustainability Indicators report explains that the indicators were developed to measure quality of life issues in the context of the County’s and Oxnard’s Save Open Space and Agricultural Resources (SOAR) initiatives (now ordinances). While the SOAR ordinances may be relevant to the development indicators, they are not relevant to the environmental and community health indicators, and therefore the study effort does not appear to limit the latter by tying them to SOAR. However, the civic engagement indicators are very artificial and restrictive because, as indicated on page 15, “they had to have a SOAR connection”. If the environmental and community health indicators were not limited in this manner, why were the civic engagement indicators? Certainly there are many (and more proactive and effective) ways that individuals participate in civic activities other than reviewing environmental impact reports and commenting on SOAR issues at City Council meetings. Further, the measurement identified for the indicator concerning persons reviewing EIRs does not match the goal of the indicator. The text on page 25 states that the goal is “to increase public participation in decision making with regard to projects that may significantly impact the local environment.” This goal is to be measured by the “annual number of comments, responses, letters or other communications from residents at public hearings or recorded in [EIRs] prepared for projects in the City of Oxnard and its sphere of influence that were SOAR related.” There are a number of projects that could be proposed in or within the sphere of influence of the City of Oxnard that are consistent with the City’s SOAR Ordinance (and therefore there is no need to mention SOAR in comment letters), or there could be substantial numbers of comments submitted that address a project’s significant environmental impacts that have nothing to do with SOAR (consistency with SOAR is not necessarily a project’s most significant issue). Further, there are ways to measure public participation in the development review process other than the number of EIR comments submitted. Just because there are no development projects that would generate SOAR-related public comments (or ones that don’t require EIRs) doesn’t mean that the community is not engaged in civic activities.

Similarly, the indicator regarding public comments at Oxnard City Council meetings is limited by an artificial connection to the City’s SOAR Ordinance. Citizen participation could be measured by the number of individuals attending and/or commenting at City Council meetings, and the number of letters, e-mails and other communications received by individual councilmembers and City staff regarding items considered by the Council, which the discussion of the indicator appears to address. The connection of the indicator to SOAR is unnecessary and irrelevant.

* * * * *

The Sustainability Indicators report emphasizes the need to continually monitor and revise the identified indicators, develop new ones as appropriate, and seek feedback from the community. The evolving nature of indicators is even reflected in the title of the report. To this end, the APAC appreciates the opportunity to provide the above comments so that the indicators can be refined and expanded to better measure quality of life goals.

Sincerely,

Charles Schwabauer
Chairman
Ventura County Agricultural Policy Advisory Committee
Committee Members:
Don Reeder
Ellen Brokaw
George Boskovich, Jr.
Tom Pecht

CS:jb
C:         Marsha Rea, Ventura County Community Foundation
            Todd Collart, Ventura County Planning Division
                Tim Dagodag, California State University, Northridge—Urban Studies and Planning Program

The Sustainability Council of Ventura County
Equitable Society, Sound Economy, Healthy Environment
P. O. Box 7817 Ventura, CA 93006-7817

August 30, 2002

Charles Schwabauer, Chairman
Ventura County Agricultural Policy Advisory Committee
P.O. Box 889
Santa Paula, CA 93061

Subject: Response to Comments on Sustainability Indicators Report of Fall 2001

Dear Mr. Schwabauer,

We appreciate the thoughtful analysis and commentary on the Indicators Study and believe that such efforts will be necessary if meaningful indicators are to be developed. To this end we will be placing your comments on our website for public reviewing, along with this response. When a response is available from the Cal State University Northridge (CSUN) researchers, we will post it on the Council’s website as well.

Because APAC’s comments focus on the work conducted by the students and faculty of CSUN, we have asked Dr. Dagodag to respond your comments in hopes of clarifying the nature of the researchers’ work. He has indicated that he will do so. The Council’s role in the project was to assist in the initial grant writing that funded the project; provide contacts for the researchers, help design the project; organize public meetings; periodically review and comment on the work done; and publish and disseminate the final report. We had little direct involvement with the actual research or indicator development. Therefore, our response to APAC’s comments will be somewhat general. The Council’s comments follow by topic raised in your letter.

Pesticide Indicator

This indicator and you comments are illustrative of the nuances that must be accounted for when establishing an indicator, particularly one on such a controversial subject. Clearly, toxicity is the concern and weight by acre is a misleading indicator when benign oils are being measured by pounds per acre. I believe your concerns over this indicator also raise the need for data collecting and disseminating agencies such as the DPR (Department of Pesticide Regulation) to formulate publicly available data that clearly tells the true story. As you note in your letter, “…unfortunately, the listings (of pesticides) do not indicate the toxicity of each chemical so that it can be easily determined by the public whether the use of toxic chemicals is increasing or decreasing.”

A great disservice is done to the agricultural industry when a more accurate depiction of its use of toxic chemicals is not readily available for all to see. This is, after all, the purpose of indicators: to inform people of trends so that informed decisions can be made that influence these trends toward desired goals. The Sustainability Council believes that a more sustainable future is one that has as few toxic chemicals in our environment as possible. A pesticide indicator should accurately inform the public and the agricultural industry whether a trend exists toward or away from this objective. The Council will assist where possible to create the most feasible and informative indicator on the subject. Initially, however, we suggest the Agricultural Futures Alliance is a logical group to address this issue.

Discussion of Value Judgements (Goals) in the Summary Report

The Summary Report, as structured, could not accommodate a discussion of values/goals for each indicator. In the cover letter to the Summary Report we direct readers to our website where the full report is located and where the “missing” goals are laid out. The Summary Report does discuss the broad goal that underlies all others: creating and maintaining a sustainable system. Such a system “…can be defined as its ability to meet the needs of present generations in areas of social, economic, and environmental well-being without compromising the ability of future generations to meet theirs.”

Ratio of Total Farmland Acreage to Population Indicator

The Council believes the intent of this indicator was to assess how successfully additional population was accommodated while still maintaining a viable agricultural industry. While the relationship between land and population was the genesis of the indicator, it could be argued that some other measure besides land could be represent the economic health of the industry. Land was nevertheless the key component. As structured, the indicator could be interpreted in conflicting ways. It was concluded that the rising ratio was “unsustainable”, and yet it could also be argued in the inverse: if the agricultural industry remained sound (or the amount of land remained relatively constant) while the population grew, that we were growing “smartly” and therefore probably sustainably. A successful indicator should not be so easily interpreted in such conflicting ways.

Ratio of Total Farmland Acreage to Urbanized Land Indicator

As a basic measure of a limited resource, farmland, this indicator is more on point than the indicator discussed previously. While a set of indicators for the City of Oxnard might rightfully look at this indicator from the perspective of the City’s Area of Interest, such an approach would not inform readers of the overall availability of farmland and viability of the industry. The ideal approach would examine what is happening in each city’s Sphere of Influence and in the unincorporated areas. Thus an aggregate picture would emerge as well as the effects of decisions of a given jurisdiction. I agree that the Value of Agriculture study would be a good source of ideas for agriculturally related indicators, but even that study could not precisely pin down the specific acres of land and numbers of support businesses necessary for a viable agricultural industry. As the industry evolves it is hard to get a fix on these variables. Therefore, raw land to farm would still seem to be a fundamental measure of the industry’s potential viability.

Civic Engagement Indicators

The Council struggled with these indicators being so closely coupled to SOAR matters, but this was seemingly dictated by the requirements of the grant that funded the work. If one were measuring general civic engagement there would be many other possible indicators, but with a mandatory link to SOAR issues the options narrow quickly. Additionally, whatever indicator is selected it must rely on relatively accessible data. Thus the record of speakers in the minutes of council meetings was used rather than other measures. It is true that there could be other significant projects that might be suitable measures of civic engagement. However, one could then argue over which projects should be measured. The very limited criteria of SOAR projects eliminated this guess-work, but at the expense of leaving relatively few projects to use as measures of civic engagement. At the Council’s first public forum on indicators, civic engagement was viewed by the attendees as a very important factor to measure. Clearly more work should be done in this area.

Conclusion

The Council believes the debate engendered by our Indicators Study is healthy, because it forces all of us to carefully think about what it takes to create a useful measure of progress toward a goal. More importantly the discussion points up the challenge of monitoring progress towards a more sustainable future which requires indicators that address interrelated social, economic and environmental factors. As challenging as this may be the Council believes it is absolutely necessary. Thank you for APAC’s input. I hope the preceding comments have been helpful.