Small, diversified farms and nurseries seek alternative compliance paths and tailored A–R guidance
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Summary
Multiple technical‑assistance providers, farmers and trade groups warned the panel that small diversified farms and nursery operations face disproportionate burdens under current A–R reporting rules and asked for alternative compliance pathways, field‑ or farm‑level reporting options and nursery‑specific coefficients or best‑practice guidance.
farmers, technical advisors and trade groups told the statewide agricultural expert panel that current A–R reporting templates and coefficients do not fit small, diversified operations and containerized nursery production and that alternative compliance pathways are needed.
What commenters said - Small, diversified growers: Resource Conservation District staff and technical‑assistance providers described many small operations (1–20 acres) that track fertilizer at the field level, not by crop, and sell mixed bundles that lack standardized units for A–R removal calculations. These growers often apply modest fertilizer volumes, are low‑tech and may lack regular internet access. RCD staff urged an alternate pathway allowing field‑ or whole‑farm reporting rather than crop‑by‑crop breakdowns. - Nurseries: Nursery trade representatives (Plant California Alliance) and growers said containerized stock lacks accepted crop coefficients for nitrogen removed because plants are sold in pots, sometimes kept on site or transferred between lots. They asked for nursery‑specific methodologies or best‑management practices that reflect actual nursery operations and recommended development of practical BMPs rather than forcing inappropriate crop‑harvest coefficients. - Existing alternate pathways: presenters noted the East San Joaquin order explicitly allows regional boards discretion to adopt alternate pathways for small diversified growers. Region 5 has implemented such an alternative; presenters asked other regions to evaluate and share lessons learned.
Why it matters: Small farms and nurseries represent a large number of operators and many are socially disadvantaged; ill‑fitting reporting requirements can impose disproportionate administrative burden and raise equity concerns.
Ending: The panel was asked to recommend clear, feasible alternate compliance options for qualifying small diversified farms and nurseries, to publish nursery guidance and coefficients where possible, and to support training and low‑technology reporting options (mobile apps, assistance through RCDs or coalitions).
