At the risk of sounding like a broken record, we were recently reminded that you can't have enough eyes and ears in a state as big as California. It's difficult to keep on top of developments that should be addressed as early as possible, especially if government agencies are involved. Once the issue gets momentum, it's much more difficult to make changes that should have been included in the beginning.

Thanks to a CAFA grower member, we were surprised to learn that the weed-free forage program was on the front burner again. Unlike the initial push about six years ago there was no notice or public comment period.

We learned there was a signed Memorandum of Understanding (MOU) in 2007 between the U.S. Forest Service (Region 5), Bureau of Land Management, U.S. Park Service, and the California Department of Food & Agriculture (CDFA). It's an issue CAFA and the California Farm Bureau previously worked on to address concerns that included how County Agricultural Commissioners would conduct inspections for weed free certification.

CAFA supports the goal of reducing noxious weeds in parks, recreation areas and other government land. But the term weed free is misleading since the program is intended to eliminate propagative plant parts and viable seed in hay and straw. The concept raises a red flag for several reasons, including market disruption and increased herbicide use.

A CAFA member recently provided an interesting observation. His fields that were rejected only had “traces” of field bindweed and he said, “My ag commissioner has interpreted this to mean 100% weed free. One weed can disqualify a whole field. In this day of our government promoting responsible use of pesticides and IPM, it is difficult to justify a measure that would advocate establishing a market for a product that would require more pesticide use.”

He makes a good point, especially in view of the California Department of Pesticide Regulation's recent emphasis on groundwater protection. Therefore, there could be unintended consequences of the weed-free program.

A major concern is the potential for disrupting hay and straw markets. For example, buyers could unfairly penalize producers for failing to achieve an impossible standard. Exporters could mandate weed-free certification, making it even harder to meet strict requirements of Pacific Rim buyers.

Lower grades of hay that have some weeds are often utilized by cattlemen or dairies for dry cows. If it's blocked from entering government land, it will cause economic hardship for buyers and growers, and increase native grazing pressure.

The weed-free program is often described as a niche market that can offer growers a premium price. When CAFA first researched this subject, however, we learned there was no benefit for growers in Montana where the weed-free program had been in force for 20 years.

Growers have expressed other concerns, such as inspection timing and whether stack inspections will be an option. More information is needed to see what protocols are being adopted. In the meantime, CAFA has asked that stakeholders be given an opportunity to have a voice in the process to make the program as practical as possible for all parties. Protecting pristine areas is a goal everyone should endorse, but there are legitimate concerns that good intentions could go awry.