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Call to Action: Speak out at Local Coastal Plan final vote

Updated: Jul 17, 2023

Please attend July 17th special Board of Supervisor's meeting to speak out against new additions to pesticide policy in the Local Coastal Plan that could allow for vineyards in sensitive coastal areas and uncontrolled insecticide use.


Sonoma County's Local Coastal Plan is set for a final vote at 9am this Monday, July 17th. Sonoma Safe Ag Safe Schools has been working with the County for many years to insure the LCP included language to prohibit pesticide use in the sensitive coastal zone. This type of prohibition is currently being used in other LCPs such as those in Malibu and Ventura.


The Planning Commission included language to prohibit pesticide use in the draft they voted to support. Now that the LCP is moving to final vote by the Board of Supervisor, the language has been changed at the last minute, and the changes are extremely concerning. The new language would allow for unrestricted insecticide use in the case of issues with a "state or federal quarantined pest" and open up a loophole that could allow agriculture (read vineyards) in sensitive coastal environments where they are currently not allowed.


Please write to your supervisors and, most importantly, SHOW UP at the Monday July 17th Board of Supervisors meeting to voice your concerns. Local environmental advocacy groups have been working for years with the county to create an environmentally responsible LCP. Industry influence has come in at the last minute and has been allowed to influence many substantial changes that threaten our coastline. The LCP will likely not be updated again for several decades. What is in this document will be guiding development decisions for the next generation.


Talking points:


  1. Thank you for your support to include language in Policy C-OSRC-7c that would prohibit pesticide use in the coastal zone. The language in this draft LCP is mirrors language that is in the Malibu, Ventura, and Los Angeles coastal plans. It is reasonable to comply with, legally defensible, supported by the Coastal Commission and provides important protections for our coastal zone.

  2. There are, however, 2 recent changes being proposed by Permit Sonoma that we respectfully ask you to reject. These amendments appear to open large loopholes.


**The first proposed revision adds provisions for using insecticides on "state or federal quarantined pest species” as a new exception along with changing the language from “herbicides” to “pesticides”. The herbicides exception was carefully crafted by Coastal Commission staff and is specific to invasive plant species and habitat restoration. It is generic language in other LCPs. It does not pertain to insecticides. Making this change could open the LCP up to litigation and it is unnecessary as the Sonoma County Coastal Zone does not have extensive vineyards or other large monocultural crops that are threatened by invasive insects.


**The second proposed revision would allow "excludable activities" within mapped sanctuary preservation and conservation areas. The language is extremely confusing and after careful consideration appears to open a loophole that could allow for vineyards in sensitive coastal environments that they are currently not allowed in. It was certainly not the intention of Policy C-OSRC-7c to allow for more conventional agriculture in our coastal zone.



What: Local Coastal Plan special Board of Supervisors meeting When: Monday, July 17 at 9 a.m. Where: Sonoma County Board of Supervisors Chambers 575 Administration Drive 102A, Santa Rosa or on Zoom:


JOIN THE ZOOM MEETING: Participate by computer, tablet, or smartphone application:

Enter meeting ID: 986 5709 5055

Enter Password: 919371

**Please note: the zoom link on the county's website for this hearing is incorrect! Please use the link and password above.



You can also email the Board of Supervisors at bos@sonoma-county.org but please show up to the meeting (or, in the least, join by zoom) if you can!






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References:


1. Full text of proposed changes by Permit Sonoma


In their policy paper to be considered at Monday’s hearing, Permit Sonoma recommends changing C-OSRC-7c policy from:


Policy C-OSRC-7c: Except as permitted pursuant to this provision or Policy C-OSRC-7e, development that involves the use of pesticides, including insecticides, herbicides, rodenticides or any other similar toxic chemical substances, shall be prohibited in cases where the application of such substances would have the potential to significantly degrade Sonoma County Local Coastal Plan Update Pesticide Regulation July 17, 2023 Page 2 Environmentally Sensitive Habitat Areas or coastal water quality or harm wildlife. Herbicides may be used for the eradication of invasive plant species or habitat restoration, but only if the use of non-chemical methods for prevention and management such as physical, mechanical, cultural, and biological controls are infeasible. Herbicides shall be restricted to the least toxic product and method, and to the maximum extent feasible, shall be biodegradable, derived from natural sources, and used for a limited time. When permitted, application of such herbicides shall not take place during the winter season, when rain is predicted within a week of application, or when wind is predicted above 5 mph. The County will identify non-toxic and earth-friendly management techniques for controlling pests and will conduct public outreach to promote the use of such techniques on property with the County

To:


Policy C-OSRC-7c (Alt 1): Except as permitted pursuant to this provision or Policy C-OSRC-7e, development that involves the use of pesticides, including insecticides, herbicides, rodenticides or any other similar toxic chemical substances, shall be prohibited in cases where the application of such substances would have the potential to significantly degrade Environmentally Sensitive Habitat Areas or coastal water quality or harm wildlife. Pesticides may be used for the eradication of invasive state or federal quarantined pest species or habitat restoration, but only if the use of non-chemical methods for prevention and management such as physical, mechanical, cultural, and biological controls are infeasible. Pesticides shall be restricted to the least toxic product and method, and to the maximum extent feasible, shall be biodegradable, derived from natural sources, and used for a limited time. When permitted and to Sonoma County Local Coastal Plan Update Pesticide Regulation July 17, 2023 Page 3 the extent feasible, application of such pesticides shall not take place during the winter season, when rain is predicted within 48 hours of application, or when wind is predicted above 5 mph. The County will identify non-toxic and earth-friendly management techniques for controlling pests and will conduct public outreach to promote the use of such techniques on property with the County.

Their justification is as follows:


The Agricultural Commissioner’s office reviewed the Policy C-OSRC-7c and requested revisions to the policy as recommended by the Planning Commission. Revisions to this policy include replacing “pesticides” with “herbicides” since the term “pesticides” as defined in both state and federal regulations, include insecticides, herbicides, and rodenticides, among other types. The revisions to Policy C-OSRC-7c includes reducing the application period prior to a precipitation event to 48 hours.

Permit Sonoma also recommends adding the following policy:


Add new policy C-OSRC-4l: Allow for excludable activities within mapped sanctuary preservation areas and conservation areas provided that the project area does not meet criteria for environmentally sensitive habitat areas


2. Open letter to the Sonoma County Board of Supervisors from Poison Free Malibu


Dear Board of Supervisors,

I represent Poison Free Malibu, a non-profit environmental group with the goal of protecting people, pets, and wildlife from toxic pesticides. I. Malibu LCP amendment We are very grateful that you have credited Malibu for inspiring the new Policy C-OSRC-7c in the LCP draft. It includes: “… development that involves the use of pesticides, including insecticides, herbicides, rodenticides or any other similar toxic chemical substances, shall be prohibited in cases where the application of such substances would have the potential to significantly degrade Environmentally Sensitive Habitat Areas or coastal water quality or harm wildlife …” Malibu’s LCP amendment is now in effect. Los Angeles and Ventura Counties have adopted similar language and we are working to spread it further up and down the coast.


II. Quarantined pest species option


A comment we would like to make concerns the addition of "state or federal quarantined pest species” as a new exception in the option to Policy C-OSRC-7c along with the change from “herbicides” to “pesticides” -


“Herbicides Pesticides may be used for the eradication of invasive state or federal quarantined pest species or habitat restoration, …"


The herbicides exception was carefully crafted by Coastal Commission staff and is specific to invasive plant species and habitat restoration. It is generic language in other LCPs. It does not pertain to insecticides.


We suggest that insecticide use introduced by the quarantined species exception be rejected. The Sonoma County Coastal Zone does not have extensive vineyards or fruit/citrus orchards or other large monocultural crops that are threatened by invasive insects. Spraying insecticides is extremely dangerous for beneficial insects such as pollinators including butterflies (Monarch and others) and bees. It also endangers nearby coastal water quality. The modest non-grazing farmland in the Coastal Zone deserves higher protection than typical large-scale inland agriculture. All-organic farming makes sense in this sensitive Coastal Zone.


III. Policy OSRC-4l - sanctuary preservation areas and conservation areas


We are concerned about the new allowance for “excludable activities” in non-ESHA "sanctuary preservation areas and conservation areas” provided by this option. Introducing agriculture into these areas would then bring with it the pesticides allowed by the invasive and quarantined pest species exception. We suggest again that any new agriculture have the strongest possible pesticide restrictions, with all-organic farming an appropriate alternative.


Thank you again for Policy C-OSRC-7c and please consider these suggestions.


Sincerely,


Joel Schulman

Poison Free Malibu

Malibu, CA

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