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Pesticides

July 6, 2017

Brian R. Leahy
Director
California Department of Pesticide Regulation (DPR)
1001 I Street, P.O. Box 4015
Sacramento, CA 95812 – 4015

Dear Director Leahy:

As DPR moves to finalize its Risk Characterization Document on chlorpyrifos and makes decisions on any additional restrictions on use, farmers in California want to reinforce the importance of the continued, practical availability of this critical tool.

Today chlorpyrifos is used on more than 800,000 acres and more than 60 crops including tree nuts, vegetables, grapes, citrus, cotton and alfalfa. Collectively, these crops for which chlorpyrifos is an important pest control material account for $23 billion in production value for California.

Chlorpyrifos is a critical part of pest management programs for farmers. It is selected as the preferred tool for many reasons. Chlorpyrifos effectively controls insects and can be less disruptive of natural beneficial insects than other insecticides, allowing those beneficial insects to aid in further pest management and reduce the need for even greater numbers of insecticide applications.

In a 2014 analysis of critical uses of chlorpyrifos in alfalfa, almonds, citrus and cotton in California, a UC Statewide IPM Program report (http://ipm.ucanr.edu/IPMPROJECT/CDPR_Chlorpyrifos_critical_use_re port.pdf) stated:

Chlorpyrifos has been an important insecticide in the Integrated Pest Management (IPM) systems in each of these crops due to its efficacy, value as resistance management tool, established international registration status (MRLs), and as a tool against invasive pests and endemic pest outbreaks.

Chlorpyrifos has over 1,000 accepted Maximum Residue Level’s for crops in countries across the globe, removing a critical obstacle for the export of California grown crops.

It has come to our attention that there have been communications from activists to the Department and other members of the Administration calling for a ban of this insecticide. These calls for a ban are not grounded in sound science.

Further, unnecessary and unjustified restrictions limiting the utility of chlorpyrifos would disrupt pest management programs and could significantly change general insecticide use patterns and result in significant economic harm to California growers.

California farmers are already subject to the most stringent regulatory oversight in the country. We are committed to the proper stewardship and use of pesticides to insure the protection of the public, the environment and our families.

We remain prepared to work with the Department on constructive solutions where necessary, and we urge the Department to retain practical conditions of use of this important tool.

Sincerely,

California Farm Bureau Federation
Western Growers
California Fresh Fruit Association
California Citrus Mutual
Agricultural Council of California
Western Agricultural Processors Association
California Cotton Alliance
California Seed Association
Western Plant Health Association
Almond Alliance of California
California Cotton Ginners & Growers Association
California Alfalfa & Forage Association
CA Women for Agriculture
Sacramento Valley Landowners Association
Alameda County Farm Bureau
Amador County Farm Bureau
Butte County Farm Bureau
Contra Costa Farm Bureau
Del Norte County Farm Bureau
Glenn County Farm Bureau
Fresno County Farm Bureau
Imperial County Farm Bureau
Kern County Farm Bureau
Kings County Farm Bureau
Los Angeles County Farm Bureau
Madera County Farm Bureau
Merced County Farm Bureau
Monterey County Farm Bureau
Orange County Farm Bureau
Riverside County Farm Bureau
Sacramento County Farm Bureau
San Benito County Farm Bureau
San Diego County Farm Bureau
San Joaquin Farm Bureau Federation
San Luis Obispo County Farm Bureau
Santa Barbara County Farm Bureau
Solano County Farm Bureau
Stanislaus County Farm Bureau
Tehama County Farm Bureau
Tulare County Farm Bureau
Farm Bureau of Ventura County
Yolo County Farm Bureau
Yuba-Sutter Farm Bureau

cc:
Keely Bosler, Office of Governor Jerry Brown
Kim Craig, Office of Governor Jerry Brown
Secretary Matt Rodriguez
Undersecretary Gordon Burns
Deputy Secretary Gina Solomon

 

 

 

 

April 4, 2017

April 4, 2017

Via Electronic Submission to dpr16004@cdpr.ca.gov

Linda Irokawa-Otani
California Department of Pesticide Regulation
1001 I Street
Sacramento, California 95812

RE: DPR Regulation No. 16-004 “15-day” Comment Period

Dear Ms. Irokawa-Otani,

Agricultural Council of California (Ag Council) appreciates the opportunity to submit comments regarding the California Department of Pesticide Regulation’s (DPR) proposed regulations that would further restrict the use of crop protection tools around schools and daycare centers. The proposal would prohibit certain crop protection applications within a quarter mile of a school and would require annual reporting of products used.

Ag Council is a member-supported organization advocating for more than 15,000 farmers across California, ranging from small, farmer-owned businesses to some of the world’s best-known brands. Ag Council works tirelessly to keep its members productive and competitive, so that agriculture can continue to produce the highest quality food for the entire world.

Ag Council respectfully remains opposed to this proposed regulation. The proposal is not based on sound science or risk-based analysis and may cause unforeseen consequences for growers. Ag Council does appreciate the changes made to the proposal to remove the application notification, the clarification to the definition of schools and other minor changes that were made. However, we continue to believe current regulations already enforced by DPR provide a capable and appropriate insurance of safety, making this proposal unnecessary.

DPR has stated they based the need for this new regulation on a 2014 California Department of Public Health study. However, the study said its results “cannot be used to predict possible health impacts.”[1] Additionally, DPR’s own Initial Statement of Reasons does not indicate that there is any kind of compliance or enforcement problem whatsoever and fails to make a case as to why a statewide standard, such as the one offered by this proposal, is necessary. Existing rules already provide many layers of protection and have been carefully developed by DPR to provide safety. In addition to U.S. EPA review, DPR evaluates and registers all pesticides before they are sold or used in California. California is the only state that has a complete secondary procedure of pesticide review. The level of safety and review built into the DPR process before pesticides can be used in California is the highest standard in the country.

Insufficient Economic Analysis

In December 2016, Ag Council joined a group of agricultural stakeholders in submitting an independent peer-review by ERA Economics.[2] Jay Noel, Richard Howitt and Claire Newman conducted the peer-review and looked at three studies from the University of California, Davis. The three studies were included in a report from the Office of Pesticide Consultation and Analysis (OPCA) and were used to determine the proposed regulation’s economic impact on agricultural operations. The peer-review shows that the OPCA report underestimated the economic impact from the proposed regulations and is not representative of the statewide impacts that would occur. Key findings include:

  • The counties analyzed in detail are not representative of many of the regions of the state where this regulation would have economic impacts
  • The two crops used in the third UC Davis study, are important, but only encompass part of the economic impact likely to result from this regulation
  • The assumption of no economic cost to missing a single spray is not consistent with the response from a small survey of pest control advisors
  • There are costs in additional to notification and yield costs, namely: quarantine spray requirements, crop quality characteristics, and disease carryover impacts

DPR has thus far failed to respond to the peer-review by ERA Economics. A true economic impact has clearly not been done and needs to be completed before this regulation receives further consideration.

Consideration of Alternatives

In DPR’s discussions of alternatives to this proposal, DPR does not consider the possibility of relying on existing law that already recognizes pesticide use near schools as a local issue. County Agricultural Commissioners (CACs) are best suited to address any issues that arise at the local level through the authority provided under Food and Agricultural Code sections 11503 and 11503.5. DPR’s role on this issue should be to ensure that regulations and restrictions, put forward by CACs, on crop protection tools are adequate to protect the public while also recognizing the reality of working in the environment where conditions vary due to weather, climate and soil type.

Evidence shows that current reforms and tools given to CACs have been effective. For five straight years, DPR’s comprehensive air monitoring network has demonstrated that pesticides in high-risk communities, including schools, have been found to be well below levels that indicate a health concern or the need for further evaluation.[3] Current regulations and label restrictions are health protective and confirmed by DPR’s own data.

Under the current proposal, the operator of the property located within a quarter mile from a school or daycare center is restricted from making a pesticide application Monday through Friday, during the hours of 6:00 a.m. to 6:00 p.m. Section 6691(f) of the proposal allows for alternative application restrictions when an operator of the property, the principle or facility administrator and the CAC have a written agreement that provides the same or greater level of protection. It is unclear if this section provides a mechanism that would allow for these parties to deal with emergency situations due to extraordinary weather, pest or disease events. We urge DPR to provide the needed flexibility at the local level in order to allow for an adequate response in emergency situations.

Conclusion

Farmers have long-standing relationships with school administrators near their operations. Many of these relationships have been developed for decades. We support increased communication between farmers and schools and daycare centers, but believe this can be accomplished effectively through local outreach.

Thank you for your consideration of these comments. Ag Council still remains opposed to the quarter mile buffer zones around schools and daycare centers. We ask DPR to include the necessary flexibility to address the local issues and conduct the necessary economic analysis in order to responsibly administer this regulation. Should you have any questions or need anything further, please feel contact Rachael O’Brien at (916) 443-4887 or via email at Rachael@agcouncil.org.

Respectfully,
Emily Rooney
President

[1] http://cehtp.org/download/pesticides/pesticides-schools-report-april2014 (page viii)

[2] ERA Economics, November 17, 2016, Technical Memorandum: Review of the Economic Impact Analysis for    Department of Pesticide Regulation 16-004

[3] http://www.cdpr.ca.gov/docs/emon/airinit/amn_2015_report_final.pdf (page i)

 

December 9, 2016

Via Electronic Submission

Linda Irokawa-Otani
California Department of Pesticide Regulation
1001 I Street
Sacramento, California 95812

RE: “Pesticide Use Near Schools,” DPR Regulation No. 16-004

Dear Ms. Irokawa-Otani,

Agricultural Council of California (Ag Council) appreciates the opportunity to submit comments in response to the California Department of Pesticide Regulation’s (DPR) proposal to adopt regulations that would further restrict the use of crop protection tools around schools.

Ag Council is a member-supported organization advocating for more than 15,000 farmers across California, ranging from small, farmer-owned businesses to some of the world’s best-known brands. Ag Council works tirelessly to keep its members productive and competitive, so that agriculture can continue to produce the highest quality food for the entire world.

California has some of the strictest regulations in the nation governing crop protection tools. Farmers in California were complying with buffer zone requirements for applications years before such zones were established on national labels. Our farmers take pride in that and the safety of their workers, families, and the surrounding community is very important to them.

The proposed regulations would prohibit certain crop protection applications within a quarter mile of public K-12 schools and child day care facilities, and require growers to participate in an extensive notification process. The proposed notification process is impractical. Product selection may not be known by the deadline provided in the regulation. Unlike products applied to school grounds that require annual notification under the Healthy Schools Act, agricultural products often vary from year to year and cannot be determined in advance, leaving those responsible at risk of violations. DPR’s proposal is extremely restrictive and would delay or prohibit pesticide applications without improving safety.

Existing rules already provide many layers of protection, have been carefully developed by DPR to provide safety and have been used without incident for many years. For 5 straight years, DPR’s comprehensive air monitoring network has demonstrated that pesticides in high-risk communities including schools, have been found well below levels that indicate a health concern or the need for further evaluation.[1] Current regulations and label restrictions are health protective and confirmed by DPR’s own data. Ag Council recommends that DPR revise the proposed language to be consistent with current Food and Agriculture Code (FAC) section 11503 and 11503.5 to provide equal protection to school children, while giving growers, county agricultural commissioners (CAC), and school districts the ability to carry out duties without costly impacts.

DPR based the need for these new regulations on a 2010 California Department of Public Health study. The study said its results “cannot be used to predict possible health impacts.”[2] Ag Council is concerned that this newly proposed regulation is not based on sound science and may cause unforeseen consequences for both growers and schools.

DPR’s job is to make sure that regulations and restrictions on crop protection tools are adequate to protect the public while also recognizing the reality of working in the environment where there are conditions out of your control such as weather and soil conditions. FAC section 12531 gives the DPR director broad authority to adopt regulations that are reasonably necessary to carry out the Code. These regulations are not reasonable. Evidence shows that current reforms have been effective. Statewide standards in this case, are not equitable or fair, nor are they justified.

Growers have long-standing relationships with school administrators near their farming operations. Many of these relationships have been developed for decades. We support increased communication between growers and school/child day care facilities but believe this can be accomplished effectively through local outreach or other similar avenues as currently demonstrated, not a state mandate.

Ag Council opposes this regulatory proposal and asks that DPR reexamine the viability of this proposal. Should you have any questions or need anything further, please feel contact Rachael O’Brien at (916) 443-4887 or via email at Rachael@agcouncil.org.

Respectfully,
Emily Rooney
President
Agricultural Council of California

[1] http://www.cdpr.ca.gov/docs/emon/airinit/amn_2015_report_draft.pdf (page i)

[2] http://cehtp.org/file/pesticides_schools_report_april2014_pdf (page viii)

Ag Groups Request Comment Extension on Pesticides Near Schools Regulation

October 14, 2016

Brian Leahy, Director
Department of Pesticide Regulation
P.O. Box 4015
Sacramento, CA 95814-2828

Director Leahy,

We appreciate that you met with a number of us on October 4, 2016, to discuss the proposed changes to 3 CCR sections 6690, 6691, 6692 and 6693 related to restricted pesticide applications near schools. As our discussion reflected, we had many questions and concerns and have been diligently working since then to better understand the information that was used to develop this significant proposed regulatory change.

We have worked closely with the Department of Pesticide Regulation (DPR) and other agencies on the issue of pesticide use around schools starting in July 2012 when the California Department of Public Health began their initial outreach on their “Agricultural Pesticide use near Public Schools in California” report that was finally published in April 2014. This report is cited as key to your consideration in developing the proposed regulation. We participated in the conceptual workshops DPR conducted beginning May 2015 and provided extensive comments.

Given that DPR has been actively developing this proposal for a minimum of 17 months, we respectfully request that you extend the comment period to January 3, 2017, which would provide us just over 60 business days to adequately review and respond to a proposed regulatory change of this magnitude, as well as prepare for the forthcoming public hearings specified in your notice. To be clear, we are not requesting a change in the dates for the public hearings.

Thank you for your consideration and timely response.

Will Scott
African American Farmers of California

Emily Rooney
Agricultural Council of California

Kelly Covello
Almond Alliance of California

Richard Matoian
American Pistachio Growers

Terry Gage
California Agricultural Aircraft Association

Tyler Blackney
California Association of Winegrape Growers

Valerie Nera
California Chamber of Commerce

Joel A. Nelsen
California Citrus Mutual

Kasey Kronquist
California Cut Flower Commission

Roger Isom
California Cotton Ginners & Growers Assoc. & Western Agricultural Processors Association

George Radanovich
California Fresh Fruit Association

Marla Livengood
California Strawberry Commission

Ruthann Anderson
CAPCA

Mike Montna
California Tomato Growers Association

Steven G. Kost
Far West Equipment Dealers Association

Cynthia L. Cory
Farm Bureau Federation

Pete Downs
Family Winemakers of California

Manuel Cunha
Nisei Farmers League

Matthew Allen
Western Growers Association

Renee Pinel
Western Plant Health Association

 

Ag Groups Provide Comments to DPR on Pesticide Use Near Schools

July 31, 2015

George Farnsworth
Assistant Director
California Department of Pesticide Regulation
P.O. Box 4015
Sacramento, CA 95812-4015

Re: Comments on DPR’s Pesticide Use Near Schools Workshops

Dear Mr. Farnsworth,

It is the collective opinion of the signatories below that the Department of Pesticide Regulation’s (DPR) own database, scientific reports, risk evaluations and risk management measures argue convincingly against the adoption of additional regulations as suggested in DPR’s Concepts to Address Pesticide Use Near Schools.

Concerns regarding this issue have been related to a study published last year by the Department of Public Health (DPH) that used data from DPR’s Pesticide Use Report to estimate the amount of pesticide use within a certain distance of California schools. In summary, the study says “This study methodology does not attempt to measure schoolchildren’s exposures to pesticides and, therefore, study results cannot be used to predict possible health impacts.” Despite this caveat, advocates for additional regulation cited the study in their workshop comments.

Family farmers care deeply about safety. They carefully follow all regulations governing use of pesticides. Safety of workers, families and surrounding neighbors is critical.

When the facts are considered it is evident that clear, significant protections are in place to assure pesticides registered in California are used safely and effectively. DPR has historically deployed the best science to develop regulations governing pesticides in California. It is also clear from follow up monitoring and evaluation performed by DPR that regulations are successful in protecting public health and the environment.

Federal and State Registration

Pesticides can only be registered for use in California after an extensive scientific review process to confirm no unreasonable adverse effect will occur from their legal use; first by U.S. Environmental Protection Agency (U.S. EPA) and then by DPR. Both agencies also have a process for continuous evaluation of registered pesticides.

Federally, before registration all pesticides undergo a human health risk evaluation. Hazards are identified through animal testing, selecting the most sensitive endpoint and corresponding point of departure for relevant populations, taking into account duration and exposure routes. Hazards are identified through animal testing studies using two or three dosing levels.

Employing scientific methodologies, data from these studies are used to estimate exposure levels protective of populations that may be exposed to the compound in question. Agency scientists then consider application of various safety factors. Depending on safety factors applied, the dose with the lowest adverse effect could be reduced for children safety by 10,000-fold.

There are other methods for estimating safe human exposure levels that consider young children and sensitive subpopulations. These also take into account duration of the animal studies and its relation to life stages. For example, data might address a one-time exposure to juveniles or the potential for exposure over a lifetime.

Routes of exposure are assessed including dermal, oral, and inhalation. Potential health risks to children get special attention, such as turf products because of children’s tendency to lay or play on lawns. The likely repeated dermal exposure to residues on their skin as well as oral exposure through handto-mouth behaviors is thoroughly assessed.

In 1995, U.S. EPA adopted the Policy on Evaluating Health Risks to Children, which requires U.S. EPA to consider risks of infants and children as part of their risk assessments and decision making process. In addition, U.S. EPA established the Office of Children’s Health Protection (OCHP) in 1997 in response to an executive order issued by President Clinton. For twenty years, it has worked under both the policy and OCHP to ensure pesticide risk assessments are protective of children’s health.

In addition to federal registration, DPR conducts independent scientific evaluations of all pesticides registered in California and full risk assessments on various pesticides, focusing on those with the greatest risk potential. DPR may require pesticide registrants to conduct additional studies and submit additional data. These studies often assess exposure to people or the environment under unique California conditions.

The National Academy of Sciences recently confirmed in a report and subsequent book titled Review of California’s Risk-Assessment Process for Pesticides, U.S. EPA’s pesticide registration process as thorough and scientifically sound and commended DPR for its additional assessment of California specific issues.

Mitigation

During the federal registration process, U.S. EPA classifies each pesticide as “general use pesticide” or “restricted use pesticide” based on potential adverse effects on human health or the environment. Restricted use pesticides can only be used by a trained certified pesticide applicator or under the direct supervision of certified applicators. For all pesticides, restrictions and mitigation measures required by U.S. EPA are included on approved labels and must be followed.

DPR’s independent evaluation process may identify risks to health or the environment under California conditions that are not adequately mitigated by the federal labels and may refuse to register a pesticide or impose additional restrictions on its use. In addition, DPR continuously evaluates registered pesticides and adopts regulations as necessary to assure safe use. For example, California established buffer zones, restricted entry intervals, and other regulatory requirements before they were adopted at the federal level.

At the local level, all California counties have County Agricultural Commissioners (CAC) appointed by their respective Boards of Supervisors, who are responsible for overseeing use of pesticides in the county. CACs may require additional mitigation measures based on weather, topography and other specific local situations. Pesticides designated under California law as “Restricted Materials” can only be applied under a CAC permit and by licensed or certified applicators. California is the only state with a permitting system. Permits are time and site specific, allowing CACs to use their knowledge of local conditions to avoid potential adverse effects.

To address drift, federal and state laws require pesticides with drift potential to undergo further exposure assessments through spray drift testing. As far back as 1970, DPR developed spray drift management techniques for aerial and air carrier application methods and continues to collaborate with U.S. EPA, U.S. Department of Agriculture (USDA), U.S. Army, U.S. Forest Service and countless universities and private researchers. In 1990, U.S. EPA created a Spray Drift Task Force which led to USDA’s development of the AgDrift model to determine pesticide drift potential. Manufacturers may be required to change pesticide formulations or modify application methods to include drift reduction technologies.

Evidence Does Not Justify Regulatory Changes

DPR has elaborate surveillance programs in place to ensure pesticides are not causing adverse effects including groundwater and surface water programs, air monitoring program and illness surveillance program. Based on evidence collected by DPR, its regulations have proven effective.

Air Monitoring Network

An analysis of DPR’s multi-year statewide air monitoring network May 2015 draft report verifies that DPR’s regulations and the care of growers and pesticide applicators are successful in preventing off-field exposures.

Between 2011 and 2014, monitoring stations were established in three California regions that were selected to represent intensive agricultural areas. In each of the years, 32 to 34 pesticides and 5 pesticide breakdown products were sampled weekly at all locations for 24-hour periods. This resulted in a total of 23,677 individual analyses.

Pesticides or pesticide breakdown products were only detected in 7% of the analyses. Of these detections, 4% were at trace levels (too low to be quantified) and only 3% were high enough to be quantified. The vast majority of detections were low relative to Health Screening Levels established by DPR.

None of the detections exceeded screening levels for acute exposure and only one pesticide exceeded DPR’s sub-chronic health screening level in one location in one year. (Note: DPR defines health screening level as (paraphrase) a concentration above the screening level does not necessarily indicate a health concern but is a trigger for further and more refined evaluation of the pesticide’s use.)

One pesticide exceeded a DPR regulatory target level at one location in two years. Additional mitigation measures were established for that pesticide.

Pesticide Illness Surveillance Program

California doctors are required to report any known or suspected illness caused by pesticide exposure, and CAC must investigate and provide results to DPR for evaluation and classification. Based on DPR’s Pesticide Use Reports, between 2002 through 2012 California had approximately 24.4 million pesticide applications. During that same period DPR’s Pesticide Illness Surveillance Program database shows only 8 incidents related to agricultural pesticide use near schools. Of those 8, only 3 involved school children. These incidents were attributed to applicator violations and enforcement action was taken. Symptoms were non-life threatening.

School Pesticide Inquiries

The lack of incidents involving off-site applications was further confirmed by DPR through a survey of CACs for school pesticide inquiries received between September 2011 and September 2014. Of the 1,779 reported inquiries, only 3 percent resulted from pesticides applied outside of school campuses and none of the investigations discovered an exposure incident or illness.

Additional Notification Requirements to Schools Unnecessary

Notification of pesticides and scheduled applications should directly relate to potential risk of exposure and serve as a mitigating tool.

Mandating notices without considering their relationship to potential risk is a disservice to the science-based process that could mislead and unnecessarily alarm the public.

School Siting Needs More Review and Accountability

California law does not require school siting by local government to coordinate with local general plans nor does it protect zoning ordinances. The irony is that local jurisdictions, many of which are reliant on agriculture for jobs and their overall economy, authorize construction of schools in agricultural areas which in turn invites complaints that agricultural practices place students in jeopardy.

Farming, whether conventional or organic, includes pest management practices that are unfamiliar to urban dwellers. Establishment of schools in rural farming communities without proper attention to the realities of production agriculture sets the stage for tension and misunderstanding in these urban-rural interfaces. This problem has been recognized by not only the public and DPR, but by the Ventura County Supervisors during its June 16, 2015 meeting.

The solution to this problem is not more restrictions on pesticides but rather greater coordination between local governments, CACs and DPR.

Conclusion

Thank you for the opportunity to present our concerns about any changes to regulations governing applications of pesticides near schools. Our groups support DPR’s current science-based regulations which were developed using the best available science and continue to protect the public and the environment.

Sincerely,

Paul Wenger, President

California Farm Bureau Federation

Mark Martinez, Vice President, Public Policy

California Strawberry Commission

Matthew Allen, Director, CA Government Affairs

Western Growers Association

Bob Tipton, Chairperson

California Strawberry Nursery Association

Renee Pinel, President/CEO

Western Plant Health Association

Lynne Figone, President

California Women for Agriculture

Chukou Thao, Executive Director

National Hmong American Farmers

Claire Wineman, President

Grower-Shipper Association of Santa Barbara and San Luis Obispo Counties

Terry Gage, President

California Agricultural Aircraft Association

Emily Rooney, President

Agricultural Council of California

Joel Nelsen, President

California Citrus Mutual

Kelly Covello, President

Almond Hullers & Processors Association

Mike Stoker, Director of Government Affairs

UnitedAg

Roger Isom, President

California Cotton Ginners and Growers Associations

Roger Isom, President

Western Agricultural Processors Association

Chris Zanobini, President

California Association of Nurseries and Garden Centers

Manuel Cunha, President

Nisei Farmers League

Will Scott, President

African American Farmers of California

Mike Montna, President

California Tomato Growers Association

Richard Matoian, Executive Director

American Pistachio Growers

Kasey Cronquist, CEO

California Cut Flower Commission

Barry Bedwell, President

California Fresh Fruit Association

Rob Roy, President

Ventura County Agricultural Association

Debra Murdock, President

California Pear Growers Association

John Aguirre, President

California Association of Winegrape Growers

Victor Tognazzini, President

Santa Barbara County Farm Bureau

Norm Groot, Executive Director

Monterey County Farm Bureau

Richard Schmid. President

Riverside County Farm Bureau

Greg Wegis, President

Kern County Farm Bureau

Jeff Merwin, President

Yolo County Farm Bureau

Eric Larson, Executive Director

San Diego County Farm Bureau

Tricia Stever Blattler, Executive Director

Tulare County Farm Bureau

Wayne Reeves, President

Contra Costa County Farm Bureau

Frost Pauli, President

Mendocino County Farm Bureau

Robert Miller, President

Del Norte County Farm Bureau

Bob Giampaoli, President

Merced County Farm Bureau

Mark Lathrop, President

Shasta County Farm Bureau

Will Harrison, President

Orange County Farm Bureau

Darin Titus, President

Glenn County Farm Bureau

Jon Munger, President

Yuba-Sutter Farm Bureau

Shaun Crook, President

Tuolumne County Farm Bureau

Michael Vasey, President

Tehama County Farm Bureau

BJ Burns, President

San Mateo County Farm Bureau

Larry Cox, President

Imperial County Farm Bureau

Brendon Flynn, President

Sacramento Valley Landowners Association

Kenneth Elwood

Elizabeth Elwood Ponce, Owners

Lassen Canyon Nursery, Inc.