ventura ventura, August 9, 2020

350 VC Climate Hub, Citizens’ Climate Lobby-Ventura and friends submit Recommendations for VC2040 GPU Modifications, and

New Policies and Programs for the VC2040 General Plan Update

 The following members and more advisors developed these recommendations:

  • Jan Dietrick, MPH, 350 VC Climate Hub, Dietrick Institute for Applied Insect Ecology
  • Kristen Kestler, Ventura Citizens’ Climate Lobby
  • Kathleen Wheeler, Ventura Citizens’ Climate Lobby
  • Rose Ann Witt, Conejo Valley Citizens’ Climate Lobby
  • Faith Grant, Conejo Valley Citizens’ Climate Lobby
  • Merrill Berge, CFROG Board Member,
  • Dr. Steven Colomé, PhD, CFROG Advisor
  • Adam Vega, VC Coalition Advocating Pesticide Safety (VCCAPS)
  • Elzbet Diaz de Leon, Environmental Scientist and Educator
  • Christopher Tull, 350 VC Climate Hub, Data Analyst
  • Todd Collart, Ventura County Arts Council, President
  • Steve Nash, Community Advisory Committee Member, Clean Power Alliance
  • Elizabeth Lamar, Sierra Club
  • Leah Dehmohseni , MS, Environmental and Occupational Health
  • Leticia Gutierrez, Social Justice Warrior
  • Allison Warner, MBA, Program Manager-Event Specialist
  • Kitty Merrill, 350 VC Climate Hub, 7th Principle Environmental Action Team
  • Tomás Rebecchi, Vice President, Central Coast League of Conservation Voters, CFROG Board of Directors

We consulted with Gary Gero, LA County Chief of the Office of Sustainability; and Jan Dietrick consulted with Daniel Kreeger, President of the Association of Climate Change Officers; Matt Gough, Sierra Club MyGen Senior Campaign Representative, and Ashleigh Spurgeon, Building Decarbonization Coalition; and about the Ag Element withPhil McGrath, McGrath Family Farms; Steve Sprinkle, Rancho Del Pueblo; Tessa Salzman, VC Food Bank; Ally Gialketsis, Board Chair, Dietrick Institute for Applied Insect Ecology; Gisa Seeholzer, writer for Edible Ojai & Ventura County; and, Kathleen Nolan, Studio Landscape & Ojai Planning Commissioner


Recommendations are presented here with extended explanations and citations and in the attached table with short rationale. Deletions have a strikethrough. Our Additions to the County’s Draft are underlined 

Table of Contents

1 PFS NEW Policy 7.8 Single Use Plastics and Plastic Bags
2 PFS NEW Program Study Phase Out Single Use Plastics and Plastic Bags
  COS Policies
3         1.15 – Tree Planting
4         1.16 – Anticoagulant Rodenticides and Herbicides
5         1.4 – Wildlife Movement
6         6.6 – In-River Mining
7         7.2 – Oil Well Distance
8         8.1 – Reliance on Fossil Fuels
  COS Programs
9         C -Tree Protection
10         H -Tree Planting
11         M – Oil and Gas Tax
12         AA – GHG Inventory
13         CC – Climate Action Council
14         DD – Office of Climate Action and Sustainability (OCAS)
  COS NEW Programs:
15         EE – OCAS Director
16         GG – Work with Cities
17         HH – HFCs
18         II – Pesticide Risk Communication re: Environment
19         JJ – Decarbonize Existing Buildings
20         MM – Local Energy Development and Community Microgrids
  HAZ NEW Policies
21         5.9 – Pesticide Risk Communication-Public Health
22         7.2 – Oil Producer Bonds
23         7.3 – Oil Facilities Inspections
  HAZ NEW Programs
24         Y – Pesticide Risk Communication re: Public Health
25         Z – Farmworker Protection
26         AA – Flood Plain Management
  AG NEW Policies
27         1.8 – Small-Scale Farmer Land Access
28         1.9 – Urban and Peri-Urban Agriculture
29         2.5 – Food Processing on Industrial Land
30         4.1 – Local Products
31         5.6 – IPM
  AG Programs
32         C – County Buys Local Products
33         G – Farm to Front Door and Other Business Models
34         L –  Carbon Farming and Regenerative Agriculture
  AG NEW Programs
35         R – Regenerative Agriculture
36         S – Socially Disadvantaged Farmers
37         T – Food Processing on Industrial Land
38 WR  NEW Policy 5.3 – Stormwater Management Accountability
39 EV 4.2 – Green Economy
40 EV  NEW Program EV-H – Remote Working

1  NEW Policy PFS 7.8 NEW. Single Use Plastics and Plastic Bags. The County shall phase out single use plastics and plastic bags by January 1, 2023, for County facilities and contracts, and by January 1, 2024, for all businesses and organizations. CAP

 SHORT RATIONALE:  Added to address an overlooked source of atmospheric and environmental pollution on a fast timeline. 


2 NEW Program PFS 7X Phasing Out Single Use Plastics and Plastic Bags. The County shall develop and implement an equitable strategy to phase out products made from polystyrene and single-use plastics, including plates, bowls, cups, utensils, straws, foam containers, and other foodware items and plastic bags and to ensure that materials used for disposable products are recyclable or compostable. CAP

 SHORT RATIONALE:  Added to determine the costs, benefits, and details for a phase-out along with green business opportunities for reuse, recycling or composting.

 REASONS FOR POLICY PHASING OUT SINGLE USE PLASTICS:  Single-use plastic products and packaging, which are increasingly made from fracked natural gas, are a significant market for fossil fuel products whose extraction is associated with fugitive methane, a  potent GHG. The trash is piling up everywhere, including in county creeks, streams, estuaries, and ocean waters, negatively impacting county finances as well as air and water quality, public health, wildlife, climate, and fishing industries.  Local governments spend millions on litter cleanup and abatement. Rates of asthma and other respiratory illnesses are greater in communities near production facilities, highways used for shipping, and incinerators or landfills. A surge of single-use products is resulting from the pandemic including in grocery stores where refill stations and reusable bags are disallowed. Such products must be regulated in such a way as to be wholly reused, recycled or composted.

A two to three year timeline is urgent to reverse the accumulation of plastic trash in the environment and is being enacted in some municipalities with high tourist business. Because of the impact on food service costs and petroleum industry push-back, a study is the best route to fully understand the barriers to recycling, comparative impacts of alternatives including different resin types and compostable materials, challenges and opportunities related to consumer use of reusable containers, and economic impacts to businesses.  It may be possible to partner with LA County and our cities to contract with UCLA’s Luskin Center for such a study. A plan to phase out of these products can happen quickly. It requires county leadership.

3 Policy COS-1.15 Countywide Tree Planting The County shall establish and support a countywide target for the County, cities in Ventura County, agencies, organizations, businesses, and citizens to plant two million trees throughout the county by 2040 to include species selection informed by best available science, a mapping and tracking program to report tree survival, and increasing local commercial and volunteer capacity for tree propagation by locally harvested seeds and cuttings. (SO, JP, IGC) [Source: New Policy] CAP

SHORT RATIONALE: Added to ensure science-based decisions about species selection, accountability for tree survival, and building local jobs and volunteer capacity for propagation. 

4 NEW Policy COS-1.16 Discourage sale and use of anticoagulant rodenticides and toxic herbicides on private property. The County shall discourage businesses from using or selling anticoagulant rodenticides, toxic herbicides, and neonicotinoid insecticides and discourage property owners from purchasing or using these chemicals on their properties.  CAP, EJ, HC

SHORT RATIONALE:  Added to ensure dissemination of scientific information about synergistic and cumulative effects on biodiversity, ecosystem function, and climate change beyond what is covered on pesticide labels.

5 Policy COS-1.4 Consideration of Impacts to Wildlife Movement be modified as follows: When considering proposed discretionary development, County decision-makers shall consider the development’s potential project-specific and cumulative impacts on the movement of wildlife at a range of spatial scales including local scales (e.g., hundreds of feet) and regional scales (e.g., tens of miles), including impacts on the movement of federal and state-designated endangered, threatened, rare, or candidate species. 

SHORT RATIONALE: Added to ensure consideration of endangered, threatened, rare, or candidate species.

6 Policy COS-6.6 In-River Mining be modified as follows: The County shall require discretionary development for in-river mining to incorporate all feasible measures to mitigate water, biological resources, flooding, and erosion impacts. Discretionary development that would have a significant impact on water quality or biological resources shall be prohibited unless mitigation measures are approved that would reduce the impact to a less than significant level.

SHORT RATIONALE: Added to ensure less than significant impact on water quality and biological resources.

7 Policy COS-7.2 Oil Well Distance Criteria The County shall require new discretionary oil wells to be located a minimum of 1,500 feet from residential dwellings and 2,500 from any school or residential dwelling.   CAP & EJ

SHORT RATIONALE: Modified to ensure protection of children when they are studying at home as well as many older people, elderly and pregnant mothers with compromised health and at risk of serious infections.

RATIONALE FOR 2,500 FT SETBACKS FROM HOMES AS WELL AS SCHOOLS: The wide range of susceptibility to Covid-19 suggests compromised immune systems in all age groups living near polluted air. Children at risk at school are more at risk at home, especially when they cannot go to school. Elders and immune-compromised people of all ages must be protected from the documented negative health impacts from living within 2,500 feet of oil wells. Studies are lining up and all pointing in the same direction toward first and second trimester exposure to oil and gas production resulting in significantly increased numbers of preterm births. 


8 COS-8.1 Reduce Reliance on Fossil Fuels The County shall promote the development and use of renewable energy resources (e.g., solar, thermal, wind, tidal, bioenergy, hydroelectricity) to and shall reduce dependency on petroleum-based energy sources by various programs including an excise tax on all oil and gas production. CAP

 SHORT RATIONALE: Added to include reference to excise tax on oil and gas production in policy as well as in a new program. 


9 PROGRAM COS-C Update Tree Protection Ordinance The County shall update existing Tree Protection Regulations in the Non-Coastal Zoning Ordinance to further enhance conservation of our trees, urban forests, and trees in nearby riparian resources.  and the preservation of the County’s oak woodland resources. Updates shall include incorporation of Board-adopted recommendations from the Ventura County Oak Woodlands Management Plan (2007), which include tree replacement offsets for ministerial development projects that remove protected trees, revisiting mitigation ratios for tree removal and oak woodland impacts for discretionary development projects. There must be adequate staffing for code compliance and law enforcement for unpermitted tree removal, enforcement of timely offset replacements with mapping and tracking the effectiveness of tree planting, a standard tree valuation rubric to generate revenue for support of programs that may include volunteer “Tree Watch” and public education about planting, care, protection of trees and reporting of tree abuse. There must be a reciprocal agreement with cities for code compliance and law enforcement to ensure that when a violation is reported it is stopped quickly and standard fines are levied. The update shall make use of the best available science existing protections regarding for invasive native plant selection and non-native trees and the degree to which select non-natives may provide benefits for Existing Communities.  habitat for a species during critical life stages (e.g., colonial roost sites, breeding sites, etc.), In addition, the evaluation shall also include anticipated effects of climate change on the urban forest environment. [Source: New Program]  CAP,

SHORT RATIONALE: Added to broaden the scope and considerations for updated tree protection ordinance based on science, and including reciprocity agreements with the cities for standard, effective code compliance and law enforcement, fines, tree valuation, and assurance of accountability.


10 Program COS-H County Tree Planting Program The County shall plant at least one thousand trees annually with formation of an ad hoc Advisory Committee to guide species selection informed by best available science, adoption of a mapping and tracking program for tree survival, and supporting capacity for Ventura County grown commercial and volunteer tree propagation by seeds and cuttings. [Source: New Program] CAP

SHORT RATIONALE: Added to ensure science-based species selection, accountability using the latest GIS smart phone technology to track tree survival, and support for local nursery companies and volunteers for propagation.


11 COS-M Oil and Gas Tax  The County shall evaluate the feasibility of establishing a local tax on new oil and gas operations located in the unincorporated county to be used to help fund GHG reduction and climate adaptation measures. CAP

 SHORT RATIONALE: Added “new” oil and gas programs to make the policy and proposed program meaningful as a Pigouvian tax and a revenue source for climate programs.

 RATIONALE:  Revision based on insertion of “new” not inserted in FEIR pg 3-71: Analysis of Implementation Program COS-M on page 4.8-44 of Draft EIR is correct. This only makes sense if all oil and gas is taxed to partially fund the County’s response to climate change, in addition to fees already collected for these activities. Economists advise taxing carbon to help mitigate the root cause of climate change by leveling the energy playing field and ensuring that the social costs of burning fossil fuels are internalized in the price. This county tax on oil and gas production is very important to help correct the cheap price distortion of products destabilizing the atmosphere and to send a signal throughout the community that the transition must be accelerated. 


12 COS – AA Greenhouse Gas (GHG) Inventory. The County shall contract with VCAPCD to produce an up-dated GHG inventory for the County and the cities that can be the basis for future inventories every five years.The County shall update the County’s GHG emissions inventory at least every five years. The inventory shall include bottom-up accounting of the significant fixed sources of anthropogenic methane plumes, a more accurate account of emissions from fertilizer use, the County’s share of hydrofluorocarbons, and use of the latest science for the Global Warming Potential (GWP) for methane rounded to 100.  [Source: New Program]  CAP

 SHORT RATIONALE: Added because a comprehensive accurate inventory is essential for prioritizing actions; VCAPCD is experienced in inventorying air pollution for the county and cities.

LONG RATIONALE: We have asked that the inventory include all sources of GHGs,  particularly methane, which we argue was under- and not over-reported in the FEIR. CFROG is correct to assert that the proper calculation of GWP of methane must be the latest IPCC calculation of GWP because it represents the actual warming impact of methane over the 10 to 20 year period that it is in the atmosphere. It is incorrect that our methane inventory is best determined by the values that the CA Air Resources Board (CARB) uses to account for methane. CARB uses those values for consistency and does not recommend using them in policy-making.  All real experts agree that a local CAP must reflect science and the truth. Not counting emissions we are responsible for is just kicking the can even further down the road.

Methane has a total radiative forcing of one third that of CO2 emissions. Most of the methane driving global warming is from other than burning fossil fuels.  But, we must reduce natural gas use to reduce fugitive fossil fuel methane emissions to stop global warming in the short term. The warming already measured today of 1.0 C has initiated significant climate tipping. This is the real climate emergency. The path back to climate stability requires immediate action to cut the emissions to halt the rise in global temperature. To reverse global warming and reduce damaging consequences, every possible action toward net zero carbon is a priority. However, methane emissions reduction is paramount right now.

  • Decarbonize the energy supply. “Clean natural gas” is cooking the planet. 
  • Get rid of natural gas in buildings and for transportation. 
  • Restore the wetlands. 
  • Greatly reduce meat and dairy consumption.
  • Do not put biodegradable or compostable items in the trash! 

Another powerful GHG is the refrigerants that the consultants refused to include in the inventory saying it is the state’s responsibility. So, the inventory does not include our share of hydrofluorocarbon emissions. People need to know how their use of refrigerators and air conditioners and potential release of refrigerant gases is related to climate change. 

The VCAPCD has experience doing inventories. Gary Gero with LA County confirmed that our countywide Air Pollution District is ideally suited to inventory and track GHG emissions for all the county and all the cities so that line items are comparable.


13 COS CC Ex. 2.5a p. 6-27 Climate Action Council The County shall establish a Climate Action Emergency Council (CAC)  to advise the Board of Supervisors on climate action planning and implementation of the Climate Action Plan (CAP) goals, policies, and programs.The CAC will provide recommendations to the Board of Supervisors on methods to implement the policies and programs identified in the General Plan, present funding opportunities, and update the BOS periodically on the latest findings in scientific research related to climate change.  The CEO and the Director of the Office of Climate Action and Sustainability (OCAS) shall ensure that the CAC is It shall be composed comprised  of interested stakeholders from communities within the county with time and desire to volunteer and who are willing to submit conflict of interest statements and other disclosure obligations of appointees, and who represent sectors that are anticipated to be impacted by climate change, as well as individuals with backgrounds in social and/or natural science that include the following:  

Disadvantaged communities representing geographically distinct communities in top 25%-35% score/segment CalEnviroScreen

Coastal environments at risk due to rising sea levels

Climate change

Climate adaptation

Biology and natural sciences 

Regenerative farming practices 

One Youth appointee under 24 years of age and one alternate under 21 years of age

A representative of the Barbareño/Ventureño Band of Mission Indians representing the native Chumash people

Distributed renewable energy generation and storage project development 

Green Building Council Representative


Producer of GHG emissions mandated to be reduced

Public policy  

[Source: New Program] CAP

SHORT RATIONALE: Added to characterize the diversity of stakeholders whose input should be sought in successful implementation of the CAP.

14 COS-DD Ex. 2.5a p. 6-28 (NEW language) Office of Climate Action and Sustainability (OCAS) – Within four months from plan adoption the Chief Executive Officer (CEO) shall create a budget and staffing plan for an Office of Climate Action and Sustainability (OCAS) to oversee the implementation of the Climate Action Plan (CAP).  The OCAS shall operate within the CEO’s office and be staffed with a Director and necessary staff to work with all applicable parties, within and outside County Government, to encourage and monitor the implementation of the CAP goals, policies, and programs.  This office shall support the CAC, provide recommendations to the Board of Supervisors about implementation approaches and update them periodically on the latest science about climate change; present funding opportunities and an annual progress report by the various responsible and supporting agencies. The OCAS may be funded through interdepartmental budget transfers to ensure prompt, robust staffing, and may convene where useful ad hoc committees of County departments, experts and impacted individuals or groups.

 SHORT RATIONALE: Added to ensure the specified focus on Climate Action goal-setting by every responsible and supporting agency identified in the CAP under oversight of the CEO’s office, recognizing the existence of a Sustainability Officer and the need to pursue CAP strategies within a sustainability paradigm. 


  • The serious nature of Climate Change necessitates a formally designated Office in the CEO’s office to oversee the implementation of the CAP
  • Naming the office Climate “Action” and Sustainability parallels our suggestion of replacing the word emergency with action, focusing on CAP implementation
  • Combining CAP implementation with existing Sustainability activity recognizes that: 1) there is an existing Sustainability Officer, and 2) the goals, policies and programs in the General Plan and the embedded CAP share the same common three elements of Sustainability – a Healthy Environment, an Equitable Society, a Sound Economy.
  • Prioritizing and reconciling potentially competing policies requires viewing CAP policies and programs through the lens of sustainability (and its three separate elements) to ensure that implementation actions promote more than one objective in a sustainability paradigm and encourages responsible and supporting agencies to  pursue strategies that can simultaneously advance all three Sustainability elements.
  • Including the Sustainability aspect to the office may broaden possible funding from various state and other funding sources.
  • Funding of climate action offices in other jurisdictions have been achieved by such means as cigarette taxes, interdepartmental budget transfers for the central coordinating function of the OCAS, and taxes on GHG emissions. 

 15 NEW PROGRAM COS-EE. Director of the Office of Climate Action and Sustainability (OCAS).  The County shall employ a Director for the Office of Climate Action and Sustainability with the mandate, qualifications. and authority to lead, coordinate and rigorously monitor progress by all responsible and supporting agencies and departments toward the CAP goals.  The Director shall provide encouragement and coaching for those responsible for implementing CAP measures.  The Director shall communicate regularly to the public, the Cities, and  Joint Powers Agencies, such as the VCREA (Ventura County Regional Energy Alliance) and VCAPCD (Ventura County Air Pollution Control District) about the responsibilities of every sector to mitigate and prepare for climate change.

15 NEW PROGRAM COS-EE. Director of the Office of Climate Action and Sustainability (OCAS).  The County shall employ a Director for the Office of Climate Action and Sustainability with the mandate, qualifications. and authority to lead, coordinate and rigorously monitor progress by all responsible and supporting agencies and departments toward the CAP goals.  The Director shall provide encouragement and coaching for those responsible for implementing CAP measures.  The Director shall communicate regularly to the public, the Cities, and  Joint Powers Agencies, such as the VCREA (Ventura County Regional Energy Alliance) and VCAPCD (Ventura County Air Pollution Control District) about the responsibilities of every sector to mitigate and prepare for climate change.

SHORT RATIONALE: Added to specify qualified leadership and capability regarding speedy implementation of the full scope of the CAP, continuously highlighting the most impactful goals, and having the authority inherent in working directly for the CEO.

 RATIONALE: The essential feature for climate action within a local government is a qualified climate action officer in the CEOs office.The Director of the Office of Climate Action under various names in other jurisdictions directs an office that has the capacity to apply science to the setting of benchmarks toward the continued development and progress of the CAP through a cooperative network of relationships within and outside of the County government. The director must have ample authority inherent through direct chain of command to the CEO to be able to do what is necessary. 

A highly capable Director of the OCAS will monitor all climate action and focus responsibility and supporting roles throughout the county government and outside. It is essential for our future that every entity and level government develop a good CAP and begin implementation as quickly as possible. Ventura County can be a leader in development and speedy achievement of its CAP. The BOS should send this message by creating appropriate specifications for the staffing plan for the Office of Climate Action and Sustainability, establishing clear lines of responsibility and authority. 


16 NEW Program COS – GG The County will pursue cooperation and coordination with the cities within the county as they prepare their Climate Action Plans to harmonize the plans to the greatest degree possible and to use common background data bases, such as, but not limited to GHG inventories, VMT (Vehicle Miles Traveled) and surveys of the public.

 RATIONALE  Added to assure a coordinated response to Climate Change.


17 NEW Program COS – HH Program (New) Reduce emissions of refrigerant and air conditioner gases. The County shall develop a program to educate the community about  responsible repair and replacement of refrigeration and air conditioning equipment with low-GWP alternatives, including the importance of calling certified technicians to capture the gases in old equipment, and measures to reduce or eliminate the need for air conditioners.  CAP

SHORT RATIONALE: Added to raise public awareness about the negative impact of high-GWP HFCs, how to ensure gases are captured by technicians, and to buy low-GWP alternatives that can improve energy efficiency and save on energy bills.

RATIONALE: Most people at some point make a decision about the disposal of old refrigeration equipment or the purchase of new equipment and have no idea that HFCs in refrigeration and air conditioning equipment are potent greenhouse gases that can be hundreds to thousands of times more potent than carbon dioxide (CO2) in contributing to global warming. Replacing high-GWP HFCs with low-GWP alternatives through a phase down of their production and consumption along with individual climate-conscious disposal and purchasing decisions can also improve energy efficiency and save on energy bills.

18  NEW Program COS-II Environmental risk communications and availability of alternatives to pesticides labeled Hazard and Caution. The County shall develop a risk communication program about the potential harmful impacts from DANGER and WARNING label pesticides on ecosystems including impacts from synergistic and cumulative effects. CAP, EJ, HC

SHORT RATIONALE: Added to provide scoping for environmental risk communication to the public about effects on biodiversity, ecosystem function, and climate change beyond what is covered on pesticide labels.


Risk communication to the public with shifting societal perceptions are moving people to a greater awareness and desire to not use toxic chemicals. Consumers want to protect themselves, may be concerned about farmworkers and other pesticide handlers (discussed in the Rationale for a proposed related New Policy and Program in the Hazard and Safety Element), but also for concerns about ecosystem restoration and climate mitigation discussed below. 

Risks from to the environment from anticoagulant rodenticides (ARs): (Adapted from comment June 2020 by Center for Biological Diversity) The County’s utilization of Integrated Pest Management for long term sustainable strategies to address rodent infestations provides the model for municipal and public use.1 Effective, affordable alternatives to rat poison include rodent-proofing homes and farms by sealing cracks and crevices and eliminating food sources; providing owl boxes in rural areas to encourage natural predation; and using traps that don’t involve these highly toxic chemicals.2 Municipalities in Ventura County, such as Thousand Oaks, have developed resources to provide individuals in their communities with resources for sustainable rodent control.The County has proven IPM alternatives and, for the same important reasons, the use of these materials must be phased out throughout the county.  

The feed through effect of anticoagulant rodenticides on higher predators not only harms the raptors, mountain lions, bobcats and other predators, it destroys the ecosystem functioning that draws down and stores carbon dioxide from the atmosphere. For example, rodents are a source of food for raptors and larger predators that eat and poop surplus biological material–part of a protective carbon cycle in the landscape. 

Risks to the environment from  neonicotinoid pesticides including Clothianidin (Bayer’s successor product to imidacloprid) are a family of systemic pesticides, which are taken up by a plant’s vascular system and expressed through pollen, nectar and gutation droplets from which bees then forage and drink. Neonicotinoids kill sucking and chewing insects by disrupting their nervous systems. 

These insecticides have taken over the seed treatment market, are toxic to insect pollinators and are lead suspects as causal factors in Colony Collapse Disorder that threatens honeybees. A recent study shows negative effects on grassland and insectivorous bird biodiversity probably due to direct consumption of coated crop seeds and indirectly from disruptions of the food supply for birds that cannot find the insects that they have evolved to reproduce on. This research provides compelling support for the re-evaluation of policies of the US EPA to allow use of neonicotinoids, particularly around bird habitats. We should not wait for the US EPA and then CAL EPA to conduct more studies before banning these pesticides; the least we can do is educate the community about their risks and alternatives.

Risks to the environment from organochlorine pesticides. These compounds bioaccumulate in the environment and remain stable in fat tissue of all species resulting in increasing exposure in longer-lived, higher trophic level predators. 

Risks to the environment from Roundup and glyphosate. Contrary to myth, glyphosate is persistent in the environment (persistence depends on soil type), blows in the wind and bioaccumulates in larger mammals, and it is widely present in surface water, rainfall, or groundwater. 

“Chemical cocktail” effect – or synergistic and cumulative pesticide exposures of multiple interacting chemicals combine to have greater or synergistic effects than would be predicted by traditional toxicological models. Pesticides can have a cumulative “toxic loading” effect both in the immediate and long term. Neonicotinoids are known to persist in the soil for years and to have a cumulative effect on neurotransmitters over time. 

Stormwater carries mixtures of bioactive contaminants (pesticides and pharmaceuticals) and other organic chemicals with known or suspected risk. Studies show dozens of chemicals per testing site with individual concentrations exceeding 10,000 ng/L, and cumulative concentrations up to 263,000 ng/L raising concerns about potential environmental effects during runoff events.  Studies of negative impacts from cumulative effects of pesticide runoff on coho salmon raise particular concern about restoration of steelhead trout in Ventura County rivers. U.S. environmental regulation remains behind current toxicological science in accounting for synergistic and cumulative chemical effects in food chains.

 Climate change impacts from pesticide and herbicide use  Climate mitigation and resilience depend on healthy above and below-ground ecosystems. We must communicate about how pest control choices affect climate change as well as the environment. 

 Carbon farming or sequestration (made possible by healthy soils) is entirely the work of soil microbes interacting with soil, roots and water. Soil microbes and plant roots are harmed by pesticides. A healthy, biodiverse above ground foodweb with an abundance and diversity of insects has a role in carbon sequestration, because both soil-dwelling and above-ground Insects are the food for birds, bats, fish and even large mammals all depositing carbon at the soil interface in their frass and body parts. All forms of dead and alive microbial, plant, invertebrate and vertebrate biomass contribute to a functioning ecosystem that maximizes carbon sequestration.

 Ecosystem restoration that values high native plant biodiversity can support a many-fold increase in abundance of the above-ground invertebrate and vertebrate food web at high degrees of biological function. Vegetation contributes even more when there are at least eight species in a plant community. Non-noxious ‘weeds’ may contribute cost-effectively to farm, garden or landscape biodiversity and ecosystem function. In fact, so-called ‘weeds’ better referred to as ‘volunteer plants’, are powerful actors for restoring degraded, polluted soil. Weeds indicate what the soil needs to become more healthy. 

 When there are herbicides killing cultivated and volunteer plants above ground and no toxic pesticides harming microbes below ground, sufficient diversity supports the phenomenon of a community tipping point of microbes that increases functionality by “quorum sensing”. At the  tipping point there is a significant increase in the performance of that soil for holding carbon, soil aggregation, infiltrating water, nitrogen fixation, and nutrient cycling. With enough biodiversity in the plant community, there is no need for added natural or artificial fertilizer.  

 Roundup is the biggest selling pesticide in the U.S. and is seriously implicated in habitat and whole ecosystem destruction. Roundup being an antibiotic and systemic poison used on seeds prevents functions of carbon sequestration, water retention and water-holding capacity to withstand prolonged drought and flooding. It kills protective microbes that protect plants against disease. By using non-toxic and more selective wee management, we support healthy plants that contribute significantly to pesticide use reduction and climate resilience for economic survival for benefits such as mitigating flooding and heat island effect 

Finally, the production and transport of pesticides also have a high fossil fuel carbon footprint. Continuing to reduce GHG emissions will become increasingly costly and difficult during the transition away from fossil fuels. Communicating about risks from pesticides will have a multiplier effect through education on reducing the demand for toxic pesticides and a steady increase of capacity for biological carbon sequestration.

Counties have a legal option to restrict or ban pesticides (including rodenticides) as established in case law. Ventura County has long deferred all regulatory decision-making to the California Department of Pesticide Regulation, but this is a decision based not on legal precedent, but on a lack of political will to ensure protection for the people of the county. At least, the County should tell people the truth about pesticide risks.

One of a number of examples of political courage is by the City of Malibu that passed amendments to its Local Coastal Program (LCP) to prohibit the use of pesticides, including ARs, throughout the city, and to require that new development permits have a condition of approval that includes “a prohibition on the use of pesticides, including insecticides, herbicides, rodenticides or any toxic chemical substance which has the potential to significantly degrade biological resources.” City of Malibu, Resolution 19-54.

Case law to restrict pesticide and rodenticide use can be found in the adoption of a LCP by the Coastal Commission which has been supported by the California Attorney General’s office and upheld in court. The Attorney General’s office explains that the Food and Agriculture code explicitly allows for the Coastal Commission to exercise its authority “under the Coastal Act to regulate land use in the coastal zone” as it does when it affirms LCPs to restrict pesticide use. The legality of regulating pesticides via the Coastal Act’s adoption of an LCP was also upheld by the Los Angeles Superior Court. 

 the [Coastal] Commission is requiring a pesticide ban for the County’s LCP, to be administered by the County, because the Commission has the authority to do so as part of its administration of the Coastal Act. F&A Code section 11501.1(c) permits the commission to require [Los Angeles County] to conform to this ban in administering the LCP. 

 Mountainlands Conservancy LLC v. California Coastal Commission, Case No. BS 149063, decision on petition for writ of mandate: denied (Sept. 5, 2017) at 20. Ventura County should take strong steps to limit unintended impacts to biological resources from ARs by prohibiting their use within the Coastal Zone by amending the LCP. 

Footnotes and citations about environmental risks from pesticides and herbicides

  • Zeng, G., Chen, M. & Zeng, Z. Risks of neonicotinoid pesticides. Science 340, 1403 (2013).
  • Li, Y., Miao, R. & Khanna, M. Neonicotinoids and decline in bird biodiversity in the United States. Nat Sustain (2020);
  • Heller, M. Bill aims to ban pesticides harmful to bees. E&E News (21 February 2019); stories/1060121799\ 
  • Masoner, Jason, R. et al Urban stormwater: An overlooked pathway of extensive mixed contaminants to surface and groundwaters in the United States Environ. Sci. Technol. 2019, 53, 17, 10070–10081
  • Laetz, Cathy A., et al The Synergistic Toxicity of Pesticide Mixtures: Implications for Risk Assessment and the Conservation of Endangered Pacific Salmon Environmental Health Perspectives 2009 117, 3, 348-353.
  • Ventura County 2017, Raptor Pilot Study for Levee Protection: Integrated Pest Management Program, Ventura County Public Works Agency – Watershed Protection District,; Ventura County, Utilizing Raptors to Control Rodents on a Levee – VCWPD’s Pilot Program, Ventura County Public Works Agency – Watershed Protection District Operations and Maintenance Division, 
  • Safe Rodent Control Resource Center, Rodent Control Strategies, 
  • Agenda Item 4.A.
  • Glyphosate Monograph” by Pesticide Action Network

19 NEW PROGRAM COS-JJ Decarbonization of Existing Buildings  The County shall establish performance-based standards that incentivize decarbonization of existing buildings with consideration to the following guidelines:

  • align with state goal of 50% of commercial buildings retrofit to zero net energy (ZNE) by 2030;
  • focus on programs that are equitable, forward-thinking, consistent, data-driven, innovative and grid friendly;
  • set a minimum efficiency standard for buildings and apartments when they are sold and when the cost can be recouped in lower utility costs over a specified timeframe; 
  • incentivize changes from natural gas to all-electric energy through possible programs, such as tax abatements, low-interest loans, reduced fees, rebates, “cash for clunkers”, and fast-track permitting, with a priority on replacement of gas stoves in low-income homes;
  • encourage and facilitate voluntary energy use reports with a priority for buildings or parcels with multiple units that total more than 50,000 sq ft; and, consider a mandatory reporting and reduction of annual energy or GHG intensity if incentives are aligned;
  • allow rent to be raised under conditions of rent controls, but not to exceed modeled savings on utility bills. CAP, EJ, HC

SHORT RATIONALE: Adding a program to focus necessary action to achieve the state goal of 50% retrofit of  existing commercial buildings by 2030 and to alleviate inside air pollution from gas stoves in homes.

LONG RATIONALE FOR ADDITION OF A PATH TO DECARBONIZING EXISTING BUILDINGS The largest sources of emissions within existing buildings are space and water heaters which last between 8 and 20 years.

Indoor air pollution is a serious problem from gas cooking stoves making this an Environmental Justice issue to assist low-income families in DACs to at least expand electric panel capacity enough to replace gas stoves. However, full electrification must be accomplished to achieve the desired goals of emissions reduction and air quality with the desired cost savings. The Building Decarbonization Institute provides principles to guide jurisdictions in writing ordinances that can overcome the barriers to achieving this complex goal with equity.

Energy efficiency, affordability, customer awareness of better options and getting programs going quickly are all important. The California Energy Commission found that “to decarbonize heating demands in buildings through a transition to electric heat pumps, without requiring early retirements of functional equipment, this transition must start by 2020 and achieve significant market share by 2030… new heat pump sales must represent no less than approximately 50% of new sales of HVAC and water heating equipment by 2030.” California is moving fast and the County must keep up to achieve the imperative full decarbonization goal by 2045.

20 NEW Program COS-MM : Remove Barriers to Distributed Energy Resources and Community Microgrid Development  The County shall make agreements for and remove barriers to development of local Distributed Energy Resources, especially community microgrids, including but not limited to the following measures:

  • Require the Clean Power Alliance and Southern California Edison to implement a robust Feed-In Tariff (FIT) with a Dispatchability Adder
  • Advocate that the Clean Power Alliance promote renewables-driven microgrids, through behind-the-meter (BTM) and front-of-meter (FOM) incentive programs. 
  • Allow the construction of solar on rooftops, parking lots, and parking structures without a Coastal Development Permit (CDP). 
  • Expedite permitting for solar+storage projects on built environments. 
  • Require County properties to prioritize renewable resilient backup power. 
  • Conduct a Solar Siting Survey for the County CAP

RATIONALE FOR PRIORITIZING AGREEMENTS FOR AND REMOVAL OF BARRIERS TO LOCAL DER: Developers require renewables-driven behind-the-meter (BTM) and front-of-meter (FOM) cooperation in order to be cost-competitive in development of local solar, solar+storage and community microgrids that we need for long-term energy cost-effectiveness and resilience.

21 NEW Policy HAZ-5.9 Discourage sale and use of registered materials with signal words DANGER and WARNING. The County shall discourage businesses from using or selling toxic herbicides, organochlorine, carbamate, and neonicotinoid insecticides and discourage property owners from purchasing or using these chemicals on their properties. CAP, EJ, HC

SHORT RATIONALE: Added to ensure dissemination of scientific information about synergistic and cumulative effects on human health and worker safety beyond what is covered on pesticide labels.

22 New Policy HAZ 7.2  Increased Bonding Requirement and Remediation Plans. The County shall require decommissioning and abandonment standards for oil extraction and exploration projects as a condition of approval, to include a cost estimate for decommissioning and site restoration following the cessation of extraction activities, and the posting of a bond for the estimated amount, inspection after decommissioning and site restoration to ensure dismantling of all structures that cannot be effectively reused and disposal of all hazardous waste, including electronics or toxic materials, in accordance with applicable health and environmental safety standards.  CAP

SHORT RATIONALE: Added to help with the cost of decommissioning wells and site restoration that is likely to largely fall on taxpayers.

23 New Policy  HAZ 7.3  Inspection and Monitoring of Oil and Gas Facilities. The County shall require that new discretionary oil and gas development and any proposed expansion of or changes to existing oil and gas operations be monitored through installation of continuous emission monitoring systems (CEMS) for air quality emissions and continuous effluent quality monitoring system (CEQMS) for water pollution, or equivalent monitoring measures (including but not limited to thermal imaging cameras) capable of detecting and recording emissions and plumes in real time.  CAP

SHORT RATIONALE: Added to ensure that equipment and pipelines are checked to help prevent aging and vulnerable infrastructure from leaking and rupture especially where chemicals might pollute aquifers.

LONG RATIONALE FOR PREVENTION OF NEGATIVE ENVIRONMENTAL IMPACTS FROM OIL PRODUCTION. Applications for new wells that will be on discretionary permits with CEQA review of negative impacts must consider air, water and climate impacts from fracking, cyclic steam injection and other extreme extraction methods, as well as injection wells through aquifers, unsafe storage of produced wastewater, and assurance that produced oil and gas wastewater will not be used on farmland. Chemicals involved in oil production can pollute water resources if fluids are allowed to migrate through underground pathways opened by the extraction process. In Santa Barbara County a survey of the Orcutt Oil Field found evidence of mixing between oil-field fluids and groundwater in four of the 16 wells sampled. Similar contamination has since been found in the Fruitvale, Lost Hills, and South Belridge oil fields in Kern County.

24 NEW Program HAZ-Y Public health risk communications and availability of alternatives to pesticides labeled Danger and Warning. The County shall develop a risk communication program about worker safety and consumer risks from exposure to DANGER and WARNING label pesticides. CAP, EJ, HC

SHORT RATIONALE: Added to describe the needed scope for risk communication and pest control alternatives for worker safety and public health concerning pesticide exposure beyond what is covered on pesticide labels.

RATIONALE:  There is increasing awareness and concern among scientists and the public that chemical pollutants can suppress immune processes and thus cause increased development of neoplastic and infectious diseases in the food chain. Studies are likely to show that compromised human responses, such as to Covid-19, are correlated with the amount of pesticides in someone’s body and/or urine. 

There is  proven causality of Roundup and Non-Hodgkin’s lymphoma. Legal cases related to glyphosate will continue to increase. The label is far from adequate to ensure that people are trained to protect themselves. The public has no idea when they may be exposed to a carcinogen when they lie down to relax on the grass, pick up a ball or play frisbee with their dog. Any entity that buys and oversees the use of pesticides has potential liability and should be proactive educating pesticide handlers and unsuspecting members of the public by communicating risks.

Risks to humans from glyphosate intake via skin or in food: Glyphosate affects basic biochemical pathways of cells of all vertebrate organisms that can include hepatorenal damage, effects on nutrient balance through chelating action, and endocrine disruption. It harms functioning in gut linings of all organisms by affecting the “tight junctions” that open and close in the single cell layer separating the gut from the bloodstream. When exposed to glyphosate, the tight junctions become abnormally large and open. Oversized gut openings allow foreign molecules, e.g. partially digested food, to enter the body setting off immune system alarms.  

People react differently to immune system alarms. Some lose defenses against emerging tumors. In some people, based in part on genetics, immune systems may go into permanent overdrive as evidenced by the alarming increase in autoimmune diseases including autism and pre-diabetes. Nervous and reproductive systems are affected. Some medical doctors suspect glyphosate in the epidemic of poly cystic ovarian syndrome. Glyphosate has exceeded the allowed levels for drinking water in 3 of 10 samples of mother’s milk.  

Despite evidence since the 1980’s that glyphosate causes damage to human physiology, iit was approved, and manufacturers have successfully pressured the EPA to periodically raise the allowable concentration  in drinking water.  Glyphosate was reclassified as a probable carcinogen by the World Health Organization in 2015. Glyphosate has never been tested during foetal development at environmental levels of exposure and its commercial formulations have never been tested for more than one month in rats. 

Many scientific reports about Roundup, taken as a whole, raise doubt about the validity of the current ADI “acceptable daily intake” and suggest that the levels we are exposed to may not be safe over the long term. 

o    Meyers, et al. “Concerns over use of glyphosate-based herbicides and risks associated with exposures: a consensus statement,”, Environ Health. 2016; 15: 19. 

Risks to humans from pesticides: Exposure science is clear about the negative impacts from pesticides to public health and the environment, such that local governments should at minimum educate the community about the risks that are currently not being addressed by responsible science-based federal and state government regulation.

Risks to humans from organophosphates and carbamates are commonly used synthetic insecticides with the same mechanism of action for toxicity. These groups of pesticides are “potent inhibitors of acetylcholinesterase, which can result in parasympathetic and sympathetic overstimulation, skeletal muscle paralysis, and sometimes respiratory failure”. Three studies indicate that exposure causes lower IQ in human offspring. 

  • Gupta, R. C., Mukherjee, I. R. M., Doss, R. B., Malik, J. K., & Milatovic, D. (2017). Organophosphates and carbamates. In Reproductive and Developmental Toxicology (pp. 609-631). Academic Press.

Organochlorines  Reduction and elimination of this class of pesticides would prevent the disastrous long term effects we saw after the proliferation of PCBs and DDT. 

  • Borgå, K., Fisk, A. T., Hoekstra, P. F., & Muir, D. C. (2004). Biological and chemical factors of importance in the bioaccumulation and trophic transfer of persistent organochlorine contaminants in arctic marine food webs. Environmental Toxicology and Chemistry: An International Journal, 23(10), 2367-2385.

25 NEW Program HAZ-Z Farmworker Protection Standards. The County shall employ a Certified Industrial Hygienist to communicate work hazards to farmworkers according to OSHA worker protection standards, and seek funding and research for opt-in biomonitoring when farmworkers are exposed to hazard and caution label pesticides, and to characterize lifetime exposure to conditions in the field, ranging from dust particulates to inhalation of pesticides. EJ, HC

SHORT RATIONALE: Added to focus OSHA-level worker protection standards for farmworkers including data gathering to ensure protections.

RATIONALE:  Farmworker protection standards are set by the US EPA Worker Protection Standard (WPS) requiring:

  • A designated representative to be made available to communicate risks and hazards inherent to one’s job. This representative should be well versed in OSHA worker protection standards to elevate the quality of the WPS. 
  • An OSHA-level Ergonomic expertise is also needed to mitigate the risk for work-related musculoskeletal disorders. 
  • Funding and research for opt-in biomonitoring of workers should be offered when hazard and caution label pesticides are used. 
  • Gathering quantitative data will enhance our understanding of pesticides for public health goals. 
  • Concerns about harmful pesticide exposure are growing as evidenced by a bicameral pesticide regulation bill to be introduced in Congress that would ban certain pesticides based on an extensive body of science. Senator Udall and Congressman Negusi seek to update laws in response to warnings about critical links in our food chain and the need to protect children and farmworkers from brain damage and other health risks of dangerous pesticides. The following public health protections are covered in this bill and should should immediately be incorporated in risk communications by the County as part of a program to discourage their sale and use on public and private property and accompany an OSHA-level Worker Safety Protection program for farmworkers: 
  • Certain pesticides will be banned.
    • Organophosphate insecticide.
    • Neonicotinoid insecticide.
    • Paraquat herbicide.
  • Regulatory process will be changed.
    • Citizens will be able to petition EPA to identify dangerous pesticides so they will not be indefinitely permitted to remain on the market.
    • It will stop EPA from issuing emergency exemptions and conditional registrations to use pesticides before they have gone through full health and safety reviews.
    • Communities will be able to enact protective legislation and other policies without fear of veto of preemption by state law.
    • It will suspend the use of pesticides the European Union or Canada says are unsafe until reviewed by EPA.
  • Protections will be provided for pesticide users.
    • Farmworker employees will be required to report all pesticide-related injuries to EPA; penalties for failure to report or retaliation.
    • EPA will have to review pesticide injury reports and work with pesticide manufacturers to develop ‘better’ labeling to prevent 

26 NEW PROGRAM HAZ-AA Amend Ventura County Floodplain Management Ordinance The County shall amend the Floodplain Management Ordinance No. 4521 (dated 3/27/2018) to define and prioritize floodplain preservation measures using the latest watershed-based science for water resiliency and integrated ecological benefits, and to cease approval of inappropriate development. 

SHORT RATIONALE: Added to amend the ordinance using the latest watershed-based science in consideration of projected drought and flooding, loss of property, loss of floodplain acreage, water, ecological and resiliency benefits. 

RATIONALE: The current Floodplain Management Ordinance does not adequately assure water resiliency, protection of water quality, averting harm to existing development, and maximizing biodiversity protection and carbon sequestration. The ordinance must use of the latest watershed-based science in the face of climate models showing increasingly severe rain events, flood risks, longer periods of drought, as well as consideration of new criteria for a collaborative watershed perspective across county political boundaries and watershed jurisdictions, essential to end continued loss floodplain acreage and all the associated water and ecological benefits. There is an advisory team from the Army Corps of Engineers and the California Department of Water Resources that can help in the amendment process. 

27 Policy AG-1.8 Land Access for Beginning Small-Scale Farmers  The County shall support increasing land access for small-scale commercial farming on blocks from one to ten acres that avoid tillage by using minimally disruptive tools, such as a broadfork, and maximize crop diversity and productivity.

SHORT RATIONALE: Current zoning ordinances do not support and may be an unnecessary barrier to access for young, beginning, and socially disadvantaged farmers who can make a livelihood on one to ten acres of land.   

28 Policy AG-1.9 Urban and Peri-Urban Agriculture near Existing Communities  The County shall support small scale urban and peri-urban farming when the practices are compatible with any land use in and near Existing Communities. CAP

SHORT RATIONALE : Current zoning ordinances may be an unnecessary barrier to access for farming on small blocks of one to ten acres of land near Existing Communities 

LONG RATIONALE:  There is a global trend recognizing the precarious lack of access to food supplies in or near most populated centers. The long distance that 80% of the food consumed in Ventura County travels puts residents at serious risk of not having food during a crisis.  People working in commercial and industrial facilities value nearby access to fresh products grown with regenerative practices.   

Access to land is a barrier in Ventura County, especially for young and socially disadvantaged farmers. There has been a perception of incompatible land use between farms and where people live, work and play, because industrial or conventional large-scale farming has been characterized as a source of air pollution, noise, and vulnerability to theft because of the typical use of toxic inputs and large equipment.  

These negative impacts are not characteristic of small-scale urban and peri-urban farms that use organic and regenerative methods that offer social, ecological, and economic value to the neighboring community, such as the many benefits shown in the diagram below, but also including reducing food miles and food packaging, reducing urban poverty,promoting social inclusion, reducing heat island effects, reuse of urban wastes, and in the case of orchards, reducing particulate air pollution, especially near roads.

                                                           Food, environmental, economic, and ecosystem service benefits of home gardens and urban agriculture (R. Lal, 2020)


Examples of some regional and municipal programs to increase land access for small urban farmers

 How-to guide Land Here! Assuring Land Access for New England’s Beginning Farmers (The Land Access Project) was funded by the USDA National Institute of Food and Agriculture through its Beginning Farmer and Rancher Development Program. 

Food Solutions New England is a regional multi-sector food systems network aiming to produce half the region’s food within the six New England states. Creating land access is essential to allow a diversity of farming enterprises and renting of small blocks–often the best or the only way for a farmer to start or grow an operation. 

Wallingford, CT leases 385 acres on 35 fields through a Lease Committee under a Conservation Commission managing leasing; certain farming practices required. 

Glastonbury’s Office of Parks and Recreation leases 180 acres on six fields. 

Providence, RI “Lots of Hope transforms unused city property into urban farms for use by socially disadvantaged urban farmers. The city’s goal is to  improve access to locally grown produce, expand the City’s green space, and contribute to improving air quality, public health, and local property values.”


    • Oberholtzer, L., Dimitri, C., Pressman, A. Urban agriculture in the United States: Characteristics, challenges, and technical assistance needs. Journal of Extension 52/6, 2014, No. 6FEA
    • Egerer, M., H. Liere, A. Lucatero, and S. M. Philpott. 2020. Plant damage in urban agroecosystems varies with local and landscape factors. Ecosphere 11(3):e03074. 10.1002/ecs2.3074
    •  Lal, R. Home gardening and urban agriculture for advancing food and nutritional security in response to the COVID-19 pandemic. Food Sec. 12, 871–876 (2020).
    • USDA Alternative Farming Systems Information Center-Urban Agriculture Resources


29 Policy NEW AG 2.5 Food Processing on Industrial Land The County shall encourage and support food processing that may include development of a food processing hub for increased food security through amended zoning and incentives.CAP

SHORT RATIONALE: Added due to barriers to establishing food processing facilities that force producers to ship out of the county for processing.

30 Goal AG-4.1 Connections to Local Products (replace Produce)The County shall strive to enhance access to and consumption of fresh, local produce and other locally grown products produced by encouraging direct connections between local farmers/ranchers and markets, restaurants, institutions, schools, hospitals, food banks, and other businesses. CAP, EJ, HC

SHORT RATIONALE: Modified to include all farm products, not just “fresh produce”.

RATIONALE: Regenerative, resilient farms grow more than just fresh produce. Consumers who want to support regenerative, resilient farmers want more. A diversified crop plan is ideal, particularly when livestock are integrated to produce animal manures. Access to a diversity of local products–animal, herbs, fiber, flowers and nursery plants–as well as fresh produce is a community value. 

Program B Ventura-County Grown Regionally-Grown Products Sales Incentives The County shall develop a program that encourages sales and distribution of regionally-grown (in Ventura County Grown or neighboring counties of Los Angeles, Santa Barbara, or Kern) produce products to local retailers, restaurants, and markets, and encourage chain stores to develop local distribution centers that includes amendments in zoning ordinances to expand available sites for food processing, such as on in. The program will encourage residents to select locally grown food products for freshness, local economic development benefits, and reduced greenhouse gas (GHG) emissions. [Source: New Program  CAP, HC

SHORT RATIONALE: Modified to suggest building a buy-local VC brand for economic growth and localizing the food supply.

31 Policy AG-5.6 Integrated Pest Management Practices The County shall encourage and support the use of Integrated Pest Management practices to reduce pesticide use and human health risks. CAP

Move IPM from 3.2 Innovative and Specialty Agriculture to Goal 5.6 Sustainable and Regenerative Farming and Ranching

Reference: Page 8-5&6 Integrated Pest Management is an ecosystem-based strategy that focuses on long-term prevention of pests through a combination of techniques such as biological control, habitat manipulation, modification of cultural practices, and use of resistant crop varieties. Pesticides are used only after monitoring indicates they are needed according to established guidelines, and treatments are made with the goal of removing only the target organism. Pest control materials are selected and applied in a manner that minimizes risks to human health, beneficial and non-target organisms, and the environment. IPM programs increase the sustainability of an agricultural system.

SHORT RATIONALE: Move to Sustainable Agriculture goal as integral to sustainable practices to align with Roadmap for IPM from state and University. 

RATIONALE FOR MOVING IPM POLICY TO THE SUSTAINABLE FARMING GOAL: IPM is not a ‘specialty’ or ‘innovative option’ or a choice for managing pests.  IPM is a critical component of sustainability that is the goal of Cal EPA, CDFA, and the University of California for all farmers and ranchers to enhance environmental quality and the natural resource base….” and integrating, where appropriate, natural biological cycles and controls.” 

IPM assures protection of public and ecosystem health. IPM assures that alternatives to Danger and Warning signal word registered materials have been considered in compliance with CEQA. IPM aims to prevent pests and diseases. Certifications that might be included in Goal 3 Innovative Specialty Agriculture, such as organic, regenerative organic, biodynamic, carbon farming accreditations and crop selection, are choices based on a marketing plan. IPM is a driver of sustainability, not a marketing choice.   

The broad relevance of IPM to all Californians is the subject of Roadmap for Integrated Pest Management — Systems Thinking to Build Better IPM for All Californians by the University of California and California Department of Food and Agriculture. It describes a shift of mindset about risks and incentives to favor effective long-range systemic management alternatives for every kind of agriculture. Furthermore, regenerative practices that make IPM successful are proving to increase farm profit which is a core aspect of sustainability.

32 Program AG-C County Procurement The County shall develop a program with quantitative benchmarks to identify opportunities to continue to provide organic and locally grown foods into cafeteria services, the jail, Ventura County Medical Center, and other County sponsored services and events that provide food service, to the extent feasible. CAP, HC

SHORT RATIONALE: Modified to ensure accelerated development of local markets for local food production that are essential for increasing food security.

RATIONALE FOR INCREASING COUNTY PURCHASE OF LOCALLY GROWN FOOD. Currently most of the production in the county is exported and most of what is consumed is imported. Food security must be a top priority goal that can be accelerated if the county invests increasingly in local farmers growing a diversity of products needed by county institutions. The county must put its money where its goals are by stimulating a much-needed market signal toward localizing our food supply. The goal will not be achieved by solely aiming to “identify opportunities…to the extent feasible”.

33 Program AG-G Farm-to-Front Door The County shall facilitate the study with local farmers of the feasibility of encouraging “Farm-to-Front Door” and other business models and their its potential benefits to businesses and residents in Ventura County.  CAP, HC

SHORT RATIONALE: Modified to expand the scope of study to all business models that can accelerate development of local markets. 

RATIONALE FOR COLLABORATIVE STUDY OF ALL MODELS FOR LOCAL MARKETING OF AGRICULTURAL PRODUCTS  The pandemic has shown the fragility of the national food distribution system and opened opportunities for local small farmers to try successful variations on their business models. The county agencies are key to developing a robust and resilient system to reliably meet the demand for healthy, locally grown food, herbs and flowers.

34 AG-L Encourage and Facilitate Carbon Farming in a Regenerative Agriculture Framework The County shall collaborate with University of California Cooperative Extension to develop a program to encourage and facilitate carbon farming projects, including development of demonstration projects and site-specific carbon farm plans,  promote carbon farming accreditation, and guide implementation of carbon farming practices in a regenerative agriculture framework throughout the county, when feasible. Unless otherwise precluded by State law, the County will consider carbon sequestration farming operations to be eligible for an Open Space Easements or Land Conservation Act contracts with 25 per cent set aside for socially disadvantaged farmers or ranchers, as defined in Section 512 of AB-2377 (See new program AG-X) CAP, EJ

SHORT RATIONALE: Modified to ensure that carbon farming develops as part of a holistic regenerative farming benefits framework, that may qualify for favored tax treatment, addressing tenancy barriers, and not just about farmers selling carbon credits.

RATIONALE:  To help owners of farmland benefit from Land Conservation Act contracts by themselves or their tenants earning income from carbon farming accreditation, and from other benefits of regenerative agriculture for land owners and tenants, such as climate and economic resilience and profitability.  

35 NEW PROGRAM AG-R: Incentivize farmers to adopt regenerative agriculture practices that sequester carbon and  reduce pesticides and artificial nitrogen. The County shall study how to help farmers adopt regenerative farming practices that sequester carbon and infiltrate water, reduce toxic pesticide and artificial nitrogen fertilizer use, and increase equity and profitability in a continuum of learning about living soils, natural fertility and healthy plants that resist pests and disease. Incentives may include but not be limited to helping obtain Organic, Regenerative Organic, and/or Biodynamic certification, discounting taxes, backing for favorable loans, and supporting training and/or cooperative access to services and markets. CAP

 SHORT RATIONALE: Added to make clear that regenerative agriculture is the best description of sustainable policies and programs that include climate, environmental, economic and resilience value for all farmers.

RATIONALE  FOR INCENTIVIZING FARMERS TO TRANSITION TO REGENERATIVE PRACTICES. Farmers need financial support to build living soil, pay certification fees, especially during the first three years of transition. The community benefits from the success of local farmers who learn regenerative practices that increase climate and economic resilience and profitability. Acquiring certifications recognizes their regenerative stewardship practices to minimize negative environmental impacts on the land. 

36 NEW Program AG-S: Promote demonstration and training for socially disadvantaged farmers and ranchers to use organic and regenerative practices. The County shall encourage collaboration for grant applications to provide demonstrations and training for socially disadvantaged farmers on research and demonstration projects that meet the farmers’ needs and economic interests, including use of organic and regenerative agriculture practices.CAP, EJ

SHORT RATIONALE: Socially disadvantaged farmers on small holdings are ideal contributors to all of the goals of the Agriculture Element and Environmental Justice goals. 

LONG RATIONALE FOR ENCOURAGING REGENERATIVE FARMING PRACTICES FOR SOCIALLY DISADVANTAGED FARMERS: The goals for food security must be expanded by diversification and demonstration of models to localize the food supply. Socially disadvantaged farmers on small holdings have the desire, the energy, the curiosity to adopt the kinds of practices and relationships for successful local marketing. They will be most successful to the degree that their farming practices are regenerative. 

Existing Communities likewise benefit from beneficial services, especially increased food security. Regenerative practices reduce or eliminate polluting and noise impacts that are perceived as constituting incompatible land uses between conventional farms and Existing Communities. 

This issue is highlighted in AB-2377 introduced by Assemblymember Jacqui Irwin that seeks to establish a technical assistance grant program for socially disadvantaged farmers and ranchers applying for California’s Climate Smart Agriculture programs to address barriers to participation. 

The bill identifies the need for technical assistance for small and moderately-scaled farms and ranches, farmers and ranchers of color, and female farmers and ranchers while coordinating with the USDA Natural Resources Conservation Service (NRCS). The USDA and many organizations report the benefits of organic and regenerative agriculture not only for climate resilience and mitigation of greenhouse gas and dust impacts resulting from tillage, but also of pests and disease. Regenerative farming methods are pathways for social and economic justice by providing greater farm profitability and lifting up the economy of the whole community. 

A study of 225 U. S. counties that have “organic hotspots” — high levels of organic agricultural activity with neighboring counties with high organic activity — revealed how these organic hotspots impact key county-level economic indicators.

Economic Benefits of Organic Hotspots:

  • Boost household incomes and reduce poverty levels — and at greater rates than general agriculture activity, and even more than major anti-poverty programs.
  • Being an Organic Hotspot increases median household income by over $2,000
  • Being an Organic Hotspot lowers a county’s poverty rate by as much as 1.35 percentage points

37 NEW Program AG-T Food Processing on Industrial Land The County shall study models and make a plan for the development of a food processing hub that may include including a “Buy VC” program, tax discounts, incentives, and amendment of the zoning ordinance .

SHORT RATIONALE: Added to support economic growth, jobs creation, a Buy VC brand, and food security. 

38 NEW Policy WR-5.3 Stormwater Management Accountability The County shall ensure that development adheres to best practices for stormwater treatment, use, infiltration to groundwater, and storage, that may include making stored stormwater available for use as a reward for water conservation practices. CAP

SHORT  RATIONALE: Added to ensure attention to best use of stormwater including metrics and methods for capture and its possible use as an incentive for farmers; to ensure compliance with laws, codes and permit conditions. 

39 EV-4.2 Green Economy The County shall support the development of industries businesses and organizations that promote and enhance environmental sustainability, greenhouse gas reductions, decarbonization, climate change adaptation, resiliency and renewable energy generation, storage, and transmission, including solar power, wind power, wave energy and other appropriate renewable sources, and transition to remote working. The County shall promote the efforts of existing businesses that meet green business criteria; job training in green building techniques and regenerative farming; and strive to build green technologies into and decarbonize government buildings and facilities. (MPSP, JP) [Source: New Policy]  CAP

SHORT RATIONALE: Modified to include not just industries, building decarbonization, remote working, and training in jobs that cannot be off-shored.


40 NEW PROGRAM EV-H REMOTE WORKING The County shall investigate the needs of employees and the opportunities to encourage and incentivize businesses and organizations to transition to remote work that may include skills training, increasing access to broadband, loans for equipment, and neighborhood shared workspaces in disadvantaged communities.   CAP & EJ

SHORT RATIONALE: Added to ensure equitable access to resources for remote working to reduce VMT.

RATIONALE FOR EXPANDING THE GREEN ECONOMY TO ALL EMPLOYERS AND TO ENCOURAGE REMOTE WORK:  GHGs are declining due to the pandemic and transition to remote working. The county should ensure that socially disadvantaged employees have the needed resources to be able to work remotely and help reduce GHGs from employee transportation.


350 Ventura County Calls for Strong Climate Action Plan

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