15-0826 v3.0/Exception Request-Petrochemical Requirement II


The intent of our original post on petrochemicals was to secure an exception for all fertilizers and pesticides used on our vineyards within the LBC boundary. However, we were only granted an exception for two products: elemental sulfur and mineral oil.

Based on this response, there is a need to discuss the issue further for specialized crops and again request an exception to the petrochemical requirement for our vineyards. Currently, many products used on the vineyards are  petro -based. These include pesticides, herbicides, insecticides and the rare fertilizer application. The current market for these chemicals  are  so heavily dependent on petrochemical inputs that it is exceedingly difficult to find products that meet LBC’s requirements and our own.

Not only are there limited compliant  options,  but as a producer of a highly specialized and valuable crop, we cannot commit to such a narrow list. For example, a milk and water spray may be an effective fungicide for some areas for a limited amount of time, but when it is no longer we must use a product that may not be LBC compliant. Our vineyards are simply too essential to our business to operate otherwise.   

As demonstrated in the previous post, Silver Oak is constantly testing new products and practices to reduce chemical toxicity, maintain the health of our crops and to meet the intent of this requirement. From this discussion, we have plans to test  non - petro  based inputs at AV 128. However, testing and adjusting chemicals/practices is a never-ending process. We must constantly adapt to new diseases and pests, as well as the varying efficacy of certain chemicals/practices over time.

Moreover, if there was an extensive list of compliant inputs that were proven to work in all foreseeable scenarios, Silver Oak would gladly adopt it. Unfortunately, current market constraints combined with the peculiarities of specialized agriculture like grape growing make this an impossible task. We would propose that you enlarge the exception previously granted to permit  use  of petrochemical products deemed acceptable by the California Sustainable Winegrowing Alliance and the Fish Friendly Farming certification. 


Given the challenges particular to specialized agricultural production, the Institute agrees to amend "v3.0 Exception I01-E14 Elemental Sulfur in Specialized Agriculture" to allow the use of additional  petrochemicalinputs for certain specific applications. The previously posted Exception v3.0 I01-E14 (7/2015) is no longer valid. 

(v2.1) I01-E14 Petrochemical Inputs in Specialized Agriculture + (v3.0) I01-E14 Petrochemical Inputs in Specialized Agriculture
Petrochemical derivatives that are approved for use both within the National Organic Program's National List of Allowed and Prohibited Substances (NOP 205.600 - 205.619) and by the California Land Stewardships Fish Friendly Farming Certification may be used in specialized agricultural production, such as commercial  viniculture,  because no viable alternatives are available.

Post ID 3112

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