Panelists spent a substantial portion of the Nov. 19 meeting discussing the INMP summary tables and who should calculate the removal component (R) used in A−R reporting.

Daniel Geisler displayed the East San Joaquin coalition summary tables that list parcel IDs, crop, acres, irrigation method and other field inputs used to compute A−R. He explained that growers typically report yields and applied nitrogen, while coalitions apply R coefficients to reported yields and, for perennials, add sequestered nitrogen values.

Ali Montazar and others raised practical limits: some regions (for example, Region 7) are still developing crop coefficients and may not cover many specialty or desert crops for years. "By 2027 [Region 7 coefficients] should be available," Montazar said, while cautioning that small or niche crops may still lack coefficients for the foreseeable future.

Panelists discussed options to reduce grower burden: (1) coalitions compute R from reported yields using published coefficients and flag outliers; (2) use representative average coefficients for groups of similar crops; or (3) where R cannot be calculated, rely on reporting of A only with research to develop reasonable R estimates. Michael Khan emphasized the importance of documenting how growers derived A (application) so audits can trace calculations.

On auditing and QA/QC, the panel recommended a phased approach: allow the first two to three reporting years for coalitions and growers to learn and improve before imposing stringent audits; thereafter, implement QA/QC procedures and sample audits informed by data quality. Daniel Geisler said coalitions already flag unusual values and contact growers to clarify apparent errors.

Panelists also debated public disclosure: several participants urged caution about releasing parcel‑level data, recommending region‑scale public summaries rather than field‑level public disclosure to protect operations while maintaining transparency.

Staff will incorporate these considerations into the draft responses, and panel members were asked to send written comments to staff for consolidation ahead of the Dec. 5 meeting.