Ruth Dalquist Willard presented draft recommendations addressing Question 8: whether small or diversified farms operate so differently that they have reduced water-quality impacts on a per-acre basis and thus could qualify for alternative reporting.

The draft separated farms into three categories: (A) small acreage producing major commodities and managed similarly to larger farms; (B) niche, emerging crops lacking removal coefficients; and (C) small, diversified farms often selling direct-to-market where multiple practices (cover cropping, diversified rotations, low external inputs) may reduce nitrate leaching risk.

Panelists discussed possible objective criteria for a reduced-risk or simplified reporting category, including crop diversity (e.g., more than two crops per acre), maximum acreage thresholds (e.g., 80 acres as used in other programs), documented management practices (cover crops, low end-of-season soil nitrate), and evidence such as end-of-season profile testing. Several speakers urged that any reduced-reporting status be evidence-based (e.g., showing low end-of-season soil nitrate) rather than an administrative concession for small operations.

Panelists also flagged regulatory burden as a separate but related concern: smaller farms often lack staff or consultants to perform complex INMP calculations and may face outsized opportunity costs from extensive reporting. The panel suggested alternate reporting options (A-only summaries, simplified forms) be made available and linked to clear criteria for reduced-risk classification.

The drafting team will incorporate specific criteria and potential evidence requirements into the panel's draft report and recommend that the State Water Board consider technical assistance and regulatory alignment to limit disproportionate burden on small farms.