Oct 15 Comments on CDFA and CalEPA’s Regulatory Alignment Study

October 15, 2025

Secretary Karen Ross
California Department of Food and Agriculture
1220 N St
Sacramento, CA 95814

Re:  Comments on CDFA and CalEPA’s Regulatory Alignment Study – Draft Final Recommendations and Implementation Steps

Dear Secretary Ross,

On behalf of the Marin County Board of Supervisors, we appreciate the opportunity to comment on the California Department of Food and Agriculture’s (CDFA) Regulatory Alignment Study – Draft Final Recommendations and Implementation Steps (September 2025). The Board strongly supports the Study’s intent to create a more transparent, efficient, and equitable regulatory framework for California’s producers; particularly for the small-scale operations that are the backbone of Marin’s agricultural economy.

Marin’s 121,800 acres of active farmland – nearly one-fifth of the County – generate $257.2 million for the local economy, and support more than 1,000 local jobs. The most recent Crop & Livestock report values Marin’s agriculture production itself at $85 million annually. Our farms and dairies are proudly among the first in the nation to adopt organic certification, carbon-sequestration practices, and regenerative land stewardship. Yet we know that this long-standing leadership is increasingly at risk.

Over the past decade, Marin has lost 25 small farms, including 8 dairies, due to rising operational costs, housing shortages, and regulatory complexity. Most were organic operations –counter to the State’s goal for 20% of farmland to be organic by 2045. The 2025 Point Reyes National Seashore settlement will also mean 12 additional small agricultural operations will close this year. Each closure destabilizes the remaining network of small producers whose financial viability depends on shared infrastructure and regional economies of scale.

Last year, our Board sent a letter to the Governor and our legislative delegation highlighting these concerns. We are heartened to see that CDFA and CalEPA’s Regulatory Alignment Study touches on many of the concerns we raised, and aims to address particularly some of the greatest challenges for small operations.

Recommendation #1 – Establish a Small Farm Regulatory Support Liaison at CDFA
Marin strongly supports this recommendation. In our letter sent to our delegation last year, we actually proposed a similar concept; a five-year pilot within CDFA focused on regulatory reform and assistance for small-scale North Coast agriculture, funded at $5 million over five years.

We also urge CDFA to locate this Liaison regionally. The role should also coordinate among CDFA, CalEPA, the Water Boards, and the California Coastal Commission to eliminate duplicative permitting, provide low- or no-cost technical assistance, and ensure that small farms are not left behind as regulations become increasingly complex. 

Coastal small farms and dairies operate within one of the most complex regulatory landscapes in the state. Marin’s producers must routinely navigate overlapping approvals from more than a dozen local, state, and federal agencies—including the State Water Resources Control Board, the Bay Area and North Coast Regional Water Quality Control Boards, the Coastal Commission, the Department of Fish and Wildlife, the Department of Pesticide Regulation, the Air District, the Army Corps of Engineers, and the U.S. EPA under the Clean Water Act.

For small, family-run operations with narrow margins, these requirements translate into significant time, cost, and technical barriers:

• Permitting delays and costs: Even modest projects – such as restoring or dredging a livestock pond, expanding its use to irrigate crops, or replacing an aging septic system – can trigger a multi-agency permitting process requiring engineering reports, environmental consultants, and months or years of review. Farms may forego essential maintenance or improvements because they cannot afford the professional assistance or permit fees.
• Water storage and use constraints: In West Marin, where groundwater is scarce, surface water storage is vital. Yet farmers seeking to update or repurpose small reservoirs face a rigid water-rights licensing system that lacks flexibility for mixed agricultural uses.
• Housing barriers: Adding or rehabilitating on-farm worker housing is often infeasible due to the cost of required water, septic, and Coastal Zone upgrades – costs that can easily exceed the project itself.
• Administrative Complexity: Compliance with multiple, overlapping reporting systems (e.g., GeoTracker, ILRP portals, organic certification audits, and PSP records) forces producers to enter similar data repeatedly, consuming time that small operators simply do not have.

These regulatory costs cannot be spread across large production scales as they can for industrial operations, making compliance disproportionately expensive for small-scale and organic farms. The cumulative effect has contributed to the closure of Marin’s small farms over the past decade.

A regionally based Small Farm Regulatory Support Liaison could help address these inequities by coordinating agency reviews, identifying redundant processes, and delivering direct technical assistance to help producers navigate requirements efficiently. This recommendation also directly advances our priority to “cut the green tape” for environmentally beneficial practices such as carbon sequestration, pond restoration, rainwater capture, and on-farm worker housing.

Recommendation #2 – Expand Coordinated Outreach and Education through Inspectors and Partners
We agree that coordinated, multilingual outreach through trusted local partners – Resource Conservation Districts (RCDs), University of California Cooperative Extension (UCCE), and County Agricultural Commissioners – is key to effective compliance and equity.

Marin’s agricultural community already relies on collaborative education models that emphasize partnership over enforcement. Integrating consistent, plain-language materials across CDFA and Water Boards programs will build trust and ensure that regulatory expectations are clear and accessible to all producers, including those with limited English proficiency or broadband access.

Recommendation #5 – Support Ongoing Efforts to Become an Authorized Local Agency Oversight Program
We encourage CDFA and the Water Boards to authorize pilot partnerships with counties like Marin that already coordinate multiple regulatory functions – water use, housing, conservation, and environmental permitting. Counties are uniquely positioned to integrate and streamline approvals at the local level, while maintaining accountability and environmental protection. We offer that a North Coast pilot that delegates limited oversight authority to counties could serve as a model for more efficient multi-agency coordination.

Recommendation #8 – Support Industry Efforts to Establish Water Board-Accepted Sustainability Programs
We support this as it echoes our call for a regionally driven regulatory framework that recognizes the North Coast’s long history of voluntary sustainability leadership. Many Marin and Sonoma producers already participate in climate-smart and carbon-sequestration programs through MALT and local RCDs. Formal recognition of such programs would streamline compliance and incentivize broader adoption.

Recommendation #10 – Simplify the Irrigation and Nitrogen Management Plan for Small, Diversified Farms
Simplifying nitrogen management reporting will benefit Marin’s small, diversified organic producers, whose operations do not fit the uniform templates used for larger monocrop systems. Reducing redundant reporting and allowing flexibility for organic practices would help small farms meet water-quality goals without incurring prohibitive consultant or data-management costs.

This recommendation supports our broader call for a regulatory structure that recognizes the diversity of coastal agriculture and rewards sustainable land stewardship.

Recommendation #13–15 – Digital Modernization and Permit Navigation Tools
Marin supports CDFA’s vision to modernize agricultural data systems and create a digital permit-navigation tool to reduce duplicative reporting. However, implementation must consider: 1) digital literacy barriers faced by many small-scale farmers, where the farmers do the paperwork themselves; and 2) full integration across systems to ensure that reporting into multiple systems does not continue to be required.

We recommend phased roll-out and user testing with small farms. Digital modernization should be paired with in-person assistance through the Small Farm Liaison and RCD partners.

Recommendation #18 also touches on this. While we support data integration that improves environmental outcomes, the State should avoid duplicative reporting burdens for small operations already submitting data through multiple portals (GeoTracker, PSP Portal, etc.). Centralization should prioritize data compatibility and security, with streamlined submission via a single trusted platform accessible to small producers with limited connectivity.

Conclusion
The Marin County Board of Supervisors commends CDFA for its Regulatory Alignment Study and strongly supports its foundational recommendations. Small-scale agriculture in our community is at an important crossroads – and we see a clear alignment between CDFA’s vision and our Board’s call for state regulatory reform for small-scale producers.

In partnership,

Mary Sackett, President
Marin County Board of Supervisors

CC:       Marin County Board of Supervisors 
Senator Mike McGuire 
Assemblymember Damon Connolly