RATIONALE OF THE CITIZENS’ CROPLAND POLICY
The controversy surrounding the use of Genetically Modified Organisms (GMOs) for crops grown on public Open Space lands is not a new one. Public hearings on the issue were conducted in June 2000 and January 2001, which included 15 hours of testimony. The Commissioners decided against a ban, and appointed a 10-member GMO-Technical Advisory Committee, which included 3 university scientists (likely to be pro-GMO), three farmers (of which two were conventional and one was conventional and organic), a policy analyst, a former biotechnology researcher, a citizen and an organic businessman. Protocols were developed to grow Bt corn that recommended communication among farmers, and specified buffers. Furthermore, GMO crops would only be allowed on a case-by-case basis. Given the makeup of the panel, the protocols were approved with 7 of 10 in support, 1 opposing, and 1 abstaining to allow Bt corn on Open Space land beginning in 2003.
In 2009, the local sugar beet growers requested that they be allowed to grow GMO sugar beets. The public response at that time was loud, and once again, long public hearings were held. Based on the public outcry, the farmers withdrew their request. Again, the County Commissioners agreed to bring an advisory council to the table to study the issue and develop an overall cropland policy for Open Space land use.
With a similar makeup to the earlier panel, this time 2 organic farmers, one organic industry member, 3 conventional farmers and 3 citizens were appointed. Thus, through a similar process, Boulder County Open Space is once again asking the Commissioners to approve more GMOs on Open Space land. The public has continually spoken out about the risks of GMO technology and the information has fallen on deaf ears. GMOs will not feed the world. They have caused weed and pest resistance, gene and chemical trespass, herbicides in our air, water and soils, and are a tremendous burden on organic farmers who desire to keep their crops free of GMOs. In fact, it is impossible to do so. GMOs have caused more overall use of pesticides, and they do not inherently increase yields. They have unknown health and safety risks. Yet, because they are more convenient for farmers, allowing them to grow commodity crops with less labor, the citizens are being asked to ignore all of these social and environmental risks associated with GMOs and consider only the direct economic benefits these cropping systems provide to the farmers who lease Open Space land and the lease income provided to the County through these leases.
Organic and sustainable production practices have many benefits. They have an overall lower carbon footprint, use less pesticides and herbicides, are more resilient to drought and adverse weather conditions, and support the image and ideals of citizens in Boulder County. Yet, the economic risks of organic and sustainable production have been overblown and the social and environmental benefits downplayed.
The POS Cropland Policy was to be designed to help Boulder County Parks and Open Space realize its vision to be a leader in sustainable agriculture, but the policy issued by POS/CPAG falls short of that goal in several areas.
Why a Citizens Policy
The Boulder County Citizens’ Cropland Policy (BCCC) is both a response to the Draft Policy issued by Parks and Open Space (POS) and the Cropland Policy Advisory Group (CPAG) and an effort to incorporate the citizens’ objectives and input for managing their Open Space lands. In includes input provided by several Boulder County documents and input from advisory groups and certain members of CPAG. The Citizens Cropland Policy has been designed to advocate productive use of publicly owned croplands for the benefit of all the citizens of Boulder County while preserving these lands for future generations of citizens.
The POS Draft Policy was developed over a nine month process in several stages as outlined by CPAG, and public comment was sought throughout the process. However, the background materials and scientific input has been biased by information provided by Colorado State University, other land grant institutions, and by the large seed and herbicide companies that are supporters of large scale commodity agriculture and the information provided by the citizenry has been largely ignored. Only with significant effort, were other scientific points of view regarding sustainable agriculture brought to the table in the process. Throughout the process, posting of public comment was not performed without constant reminders. The final document does not reflect information provided by the public and others on CPAG in the final POS policy. The supporting materials are not balanced, are strongly biased toward the use of GMOs and chemical inputs including the addition of technical data sheets from a large herbicide and seed supplier. More balanced views of sustainable agriculture, such as those from the USDA SARE Program (Sustainable Agriculture Research and Education) and NCAT-ATTRA (National Center for Appropriate Technology—Appropriate Technology Transfer to Rural Areas), were completely missing.
Mission Statements, County Plans, Advisory Policy Objectives, and Community Values
A long history of environmental stewardship has existed in Boulder County and is reflected in the Parks and Open Space mission statement, Boulder County Comprehensive Plan Sustainability Element (BCCCP Appendix 1a) and Food and Agricultural Policy Council’s cropland policy recommendations all focus on conservation of public resources that reflect the values of the citizenry.
The mission of Boulder County Parks and Open Space reads:
“The Mission of Boulder County Parks and Open Space is defined as “Toconservenatural,cultural andagriculturalresourcesandprovidepublicuses thatreflect soundresourcemanagementandcommunityvalues.”
The mission of Food and Agricultural Policy Council reads:
“Food and Agriculture Policy Council's (FAPC) mission statement is to promote a locally-based food and agricultural system that advances Boulder County's economic, environmental, and social well being through research, education, and public policy recommendations.”
The Goals of FAPC are listed as:
- Increase food production in Boulder County
- Improve access to locally produced food
- Improve economic viability of agriculture in Boulder
- Recognize and enhance the role of Boulder County's food and agriculture system in conserving and regenerating natural resources and the environment
- Improve health for all Boulder County residents
- Build community bridges
In addition FAPC developed a Strategic Plan (The FAPC Strategic plan can be found in the Support Document Section of The BCCCP binder) in 2009 whose operating principles are:
• Focusing on a sustainable food and agricultural system.
• Evaluating choices against potential unintended consequences.
• Working through transparency and collaboration.
• Fostering innovations toward sustainable agriculture and food systems.
• Basing our recommendations on sound research, existing efforts and assessment of needs and gaps.
Prior to the CPAG process, FAPC issued a memo to the Boulder County Department of Parks and Open Space (POS) outlining its initial recommendations for the Cropland Policy. (The complete memo can be found in the Support Document section of The BCCCP binder.)
Policy Goal 1: Increased amount of food grown on Boulder County Open Space lands for human consumption within the County.
Policy Goal 2: Sustainability of natural, agricultural and human systems on these lands.
Policy Goal 3: Cropland Policy for POS lands as a model for other agricultural lands in Boulder County and beyond.
The Boulder County Comprehensive Plan includes a “Sustainability Element” (BCCCP Appendix 1a) which states:
“Sustainability links the issues of environment, economy and social equity together. An action or decision in any one of these areas will have consequences on the others whether anticipated or not. A sustainable community is one where an agreement has been reached on the design and implementation of plans that replace competition between issues with collaboration and forethought about achieving desired outcomes in the present while preserving options for those that will follow.”
Two recent public surveys were conducted. The one performed by Open Space with marked biased language toward GMOs showed an even split amongst the public for and against GMOs. A more recent study written by a market research firm in a more balanced way indicated a clear majority of the public (62%) does not approve of using GMOs for farming on public Open Space land. An overwhelming majority of citizens support the use of public lands for local food production and for local food grown with organic practices in both surveys.
During the 9 months of the Cropland Policy development process, over a thousand pages of documents were forwarded to both CPAG and POS providing information, testimony and peer reviewed studies regarding the dangers of GMOs, glyphosate and neonicotinoid pesticides and expressing concern and outrage that these inputs should be allowed to be used on public land. In addition, over 60 people spoke at both the Parks and Open Space public comment evening and the joint session of FAPC and POSAC on November 15th presenting information about the negative consequences of these practices and their opposition to a policy that allowed their use.
A Cropland Policy for the management of Open Space croplands should reflect community values, which eschew GMOs on public land. Given that sustainability, including food sustainability and food security, are major values expressed in the Boulder County Comprehensive Plan (BCCP), the Boulder Valley Comprehensive Plan (BVCP), the County appointed Food and Agricultural Policy Council (FAPC) and the recent POS survey, it became very apparent that the Cropland Policy process and those involved with writing the policy including the majority of the members of the CPAG group advising in this process did not reflect the mission of the County or the will of the people.
The Citizens Cropland Policy has been developed to provide you, the Commissioners, with a more comprehensive and better researched and supported management document. The BCCCP incorporates many of the suggestions provided by FAPC that were missing from the Draft CPAG policy as well as many recommendations by members of the CPAG that were not incorporated in the BCOP draft Cropland Policy. These include an Inventorying Map, pollinator protection, banning GMOs and biosolids use, aligned definition for sustainability, specific measurements of soil health, and specific support of organic production. As well, there are many additional issues suggested by FAPC that need to be addressed more fully that were not in the policy. Given the timeframe between issuance of the draft policy and hearings before FAPC and POSAC, this Citizens’ Policy is submitted with many recommended changes, and continued work will need to be done to make the policy more robust.
It is clear that the POS Draft Policy developed by CPAG and the Boulder County Open Space staff does not adequately represent the desire for increased local sustainable food production.
There have been many ideas floated for transition away from commodity crops on Open Space, including growing dry beans and growing and milling small grains, pressing oilseeds, pasture-grazed chickens for local egg production and addition of food processing facilities for malting barley for local brewers and canning vegetables. As a citizenry, we support the work of the FAPC to move our County lands away from commodity crops with a transition process for the farmers.
The Boulder County Comprehensive Plan (BCCP) and the Boulder Valley Comprehensive Plan (BVCP) both have strong elements of sustainability as core principles. In addition, the BVCP speaks of strong cooperation among the City of Boulder and the County on many issues. One issue that has come to light in this process is that county-managed Open Space owned by the City of Boulder has GMOs grown on it even though the City of Boulder has banned growing GMOs on their land. For Open Space lands that are owned by more than one party, the management of such lands should be conducted using the most restrictive policies regarding environmental and public health aspects of any of the owners, irrespective of ownership percentage, or which party is the designated managing party. All future acquisitions of Open Space that are purchased in partnership with other parties should include specific provisions to implement the most restrictive policy criteria in the acquisition agreements. Any deviation from this management policy involving public entities shall require public hearings and due process by each public party.
The POS Draft Policy issued by the Open Space staff shifts the decision-making burden to the staff where the public will have little to no input on decisions. The BCOS Staff have demonstrated an obvious bias toward certain agricultural practices that need to be balanced with other input. Decisions on such issues as the approval of GMOs on public land and other significant issues of agricultural land use should always stay with the County Commissioners. In addition, we recommend the creation of a citizen oversight board that would be responsible for review and selecting lessees for BCPOS croplands as well as insuring that the adopted policy is being followed by BCPOS staff.
The recent Cropland Policy development processed has demonstrated that, without public oversight and input, the product of such processes cannot reflect the will of the people, community values or the democratic process. Much is to be learned from this recent history. The most important lesson is this: no one person or outside force should determine the future of a community or the fate of public assets. This should always be determined by the citizens themselves and great care needs to be used to protect citizens rights and to insure that process guarantees that the will of the people can be expressed, heard and implemented.