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Panel debates targets versus enforceable limits, feasibility and review timelines
Summary
Panelists debated whether the draft should present targets or enforceable limits, how to phrase initial thresholds ("should/must/feasible"), and whether to use percentiles or majority-based criteria; members favored feasible initial limits, regional flexibility and an iterative review process.
Panel chair Dr. Daniel Gistler led a detailed review of draft language about targets, benchmarks and enforceable limits. Panelists pressed for clearer definitions and consistent phrasing; several recommended using "target/limits" together to avoid implying a single regulatory approach. Richard Smith and others argued initial limits should be framed as feasible levels most growers can meet within a reasonable time frame rather than prescriptive mandates.
A central point of debate was whether to recommend numeric examples (e.g., 80th or 90th percentiles) or to leave percentiles out and rely on majority-based or regionally determined criteria. The group did not adopt specific statewide percentiles, instead preferring an iterative review in which regional boards evaluate progress (one panelist described a 3-to-5-year example as illustrative rather than prescriptive) and advance targets/limits when a majority of growers can comply or regional conditions warrant tighter thresholds.
Panelists also discussed the correct regulatory verbs to use. Wording moved toward describing "initial limits that are feasible for growers to meet within a reasonable time frame," with explicit acknowledgement that regional boards will set timelines and consider local data when determining what is realistic.
Panelists emphasized clarity about the intended enforcement posture: the draft should distinguish discussion (options and guidance), direction (staff tasks), and formal action (limits adopted by regional boards). The panel left the language intentionally non-prescriptive about exact numeric thresholds while endorsing a framework that supports regional boards in establishing and iterating limits based on monitoring and feasibility assessments.
