15-0629 v3.0/Exception Request-Petrochemical Requirement


I am writing to request an exception for the chemical requirements on our vineyards currently within our boundary.

We intend to fully comply with the ban on petrochemical fertilizers and pesticides for all of our landscaping, however, due to market constraints and the highly specialized nature of winegrowing practices, we are unable to currently comply with this requirement for our vineyards.

The following are two examples that demonstrate how market constraints and the specialized nature of winegrowing do not currently allow us to comply fully with this requirement. Grapes used in  winemaking  are very susceptible to powdery mildew. Elemental sulfur, a critical fungicide in winegrowing and indeed many other crops, is derived from petroleum or natural gas refineries and is therefore not allowed under this requirement. The alternative- mined sulfur- is not readily available and often contains heavy metals. I have spoken with several manufacturers of elemental sulfur (both approved for use on certified Organic farms and not) and their products are all derived from petroleum and/or natural gas refineries. Additionally, the trade-off from a product that is 99.99% pure to one with heavy metal contaminants does not seem to be within the intent of this challenge and would not be considered an acceptable alternative for Silver Oak.

Silver Oak continually seeks to minimize the use of highly toxic chemicals. Over the past few years, we have transitioned away from fungicides and insecticides to mineral oil. Although mineral oil is a product of petroleum, it is an inert, non-toxic substance that effectively suffocates the targeted eggs without unreasonably threatening the health of other species, soil or water. Similar to the trade-off between PVC and polyethylene/polyolefin, we have prioritized reduced toxicity with the options available to us.

In lieu of banning pesticides and fertilizers that contain petrochemicals on our vineyards, we offer the following certifications and practices to demonstrate that the vineyards at AV 128 are responsibly managed with regards to chemical inputs, water use, habitat management, and groundwater and soil health.

Silver Oak has made enormous strides towards sustainable farming and continues to improve their practices through careful research and by pursuing certification. All of our vineyards and wineries are certified under the California Sustainable Winegrowing Alliance, which requires the implementation of industry best practices and a commitment towards continuous improvement. It includes a thorough inventory of 227 criteria including soil, water  and  chemical management. To be eligible for the program, 58 prerequisites within these categories must be met. AV 128 not only met all prerequisites but achieved high scores in many categories. Some of our strategies to reduce chemical inputs include: plant tissue analysis, water quality assessments, cover cropping, leaf removal, shoot thinning and bird boxes.

All of our vineyards are also Fish Friendly Farming certified. This requires a Farm Conservation Plan, which includes strategies to improve soil and creek health, maximize water conservation and minimize chemical use. The method of application,  frequency  of use and toxicity of each chemical is assessed under the plan. Only chemicals with low-toxicity are allowed and are only applied as a last resort.

In all, we ask that you take this information into consideration and provide an exception to our project, understanding that we have taken a whole-systems and hands-on approach to sustainable farming management. We agree that reducing the use of petrochemicals in farming is an important step in the right direction, but that current limitations do not allow us to eliminate them altogether. Going forward, we will prioritize equivalent products that are not petrochemical based.


THE EXCEPTION BELOW HAS BEEN REPLACED by "I01-E14 Petrochemicals in Specialized Agriculture" posted in response to the post "Exception Request Petrochemicals Requirement II", as of October 5, 2015. 

ORIGINAL RESPONSE: Based on this case the Institute is creating an exception to allow the use of elemental sulfur and mineral oil to combat powdery mildew in vineyards. 

(v3.0) I01-E14 Elemental Sulfur in Specialized Agriculture
Elemental sulfur and mineral oil, both petrochemical derivatives, may be used to combat powdery mildew in vineyards because both are demonstrably essential to the crop and there are no viable alternatives available.

I01-4 Landscape Narrative - The narrative must include a brief description of how the project team has minimized the use of elemental sulfur and chemicals in the vineyard.   

Post ID 3009

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