BCHA Recommendations on Boulder County Cropland Policy

BCHA RECOMMENDATIONS

2011 BCPOS CROPLAND POLICY

The Boulder County Horse Association (BCHA) has paid close attention to the lengthy discussions pertaining to Boulder County Parks & Open Space’s (BCPOS) Cropland Policy process.

For the most part we support the work of the CPAG (the Cropland Policy Advisory Group), which consisted of three conventional farmers, two organic farmers, an organic dairy farmer, and three members of the public.  These dedicated people met and deliberated for nine months, and produced a remarkably balanced document outlining future agricultural policies for BCPOS croplands, including irrigated pasture lands and irrigated hay ground for livestock.

We have now reviewed the final staff recommendations and we appreciate the sincere effort they have made to find common ground.  In most cases, we support the CPAG and staff recommendations, but we recommend several modifications as outlined below.

However, the Cropland Policy process and the resulting document have raised several troubling  questions about the perceived place of horses in Boulder County.

1)  Definition of Agriculture.  We draw your attention to the Boulder County Land Use Code, which correctly defines “agriculture” as “The cultivation of land, production of crops, raising, breeding, and keeping of livestock, and the buying and selling of crops, products or livestock associated with the agricultural operation” (LUC, Art 18-104).

Every major definition of agriculture worldwide includes cultivating the soil, growing and harvesting crops, and raising or keeping livestock.  Horses clearly fit into the definition of agriculture because horses are clearly livestock.

The current Cropland Policy Draft goes to great lengths to define “sustainable agriculture” including the elements of economic, environmental, and social sustainability (Background, Sec 3).  However, it never actually defines agriculture itself, except through frequent references to the “production of food and fiber for local human consumption” (e.g. Policy Administration, introduction, 7.9).   This narrow view leaves horses in limbo.  We’re agriculture.  Even this week’s Federal decision allowing horses to be slaughtered for human consumption supports this contention.

We recommend that BCPOS in general, and the Cropland Policy in particular, use Boulder County Land Use Department’s definition of Agriculture, instead of wandering around in food and fiber. Doing so would eliminate confusion between the Land Use and Parks & Open Space Departments, and would ensure that horses remain a vital part of the agriculture of Boulder County.

2)  Prioritization.  Until now, BCPOS has – appropriately — not prioritized the various agricultural operations that are conducted on its properties.  However,  the draft Cropland document is rife with new priorities, such as “Boulder County shall prioritize opportunities for organic operations on POS land” (1.8);  “Boulder County will prioritize the expansion of food crops on Open Space land for local markets” (1.10), and – of greatest concern to the horse community — “Open Space shall give preference to livestock operations for local food and fiber production” (7.9).

We believe that there is room for everyone on BCPOS land and that we can all coexist.  If taken to its extreme, “prioritizing” can represent the imposition of one special interest over, and at the expense of, broader or more diverse interests.

In particular, we are concerned that “prioritization of livestock and other agricultural operations for food and fiber for human consumption” could:

a)    require BCPOS hay producers to sell their hay first to everyone with any kind of livestock OTHER than horses – llamas, sheep, goats, pigs, cows, chickens, etc – and only after them all, to horses.

b)   require BCPOS farmers to give grazing priority to all other livestock, rather than horses

c)    require the County to lease future Open Space farms preferentially to people with all other livestock, or to raise food crops, rather than horses.

If this were to happen, both the horse community in Boulder County and the BCPOS farmers who support the horse community would suffer irreparable harm.  If this prioritization were taken to its extreme, there would be a dramatic decrease in the amount of forage and hay available for horses, raising prices and driving many people to part with their horses or move out of the County entirely.

We found the POSAC-inserted clause that “livestock operations for local food and fiber production shall be preferred over recreational equestrian facilities” to be particularly egregious, uncalled-for, gratuitous, and unnecessarily provocative.  We are glad that Staff struck it entirely, and we urge the BOCC to do the same.

We are still concerned about inequity and unintended consequences of prioritization, and we recommend that the language be changed throughout the document, from ”prioritization” or “preference” to “support.” 

3) One Size Fits All — NOT.  We observed with great concern the lengthy and heated discussions about no GMOs, no herbicides, no pesticides, and no fertilizers anywhere on BCPOS lands.

While the advocates of these broad, overarching principles doubtless have good intentions, the reality is that best management practices need flexibility and the ability to incorporate new techniques and technologies as the needs and opportunities arise.

BCHA takes no position on GMO’s.

However, we believe BCPOS’ integrated pest management program is working and farmers need to be able to use these products, including fertilizer, in moderate amounts to maintain the land’s productivity.  The demands for “organic” or “no chemicals” for all BCPOS properties are naïve and would strangle the entire agricultural community.  The invasion of weeds and pests from BCPOS’s properties to neighboring ones would cause unnecessary conflict and loss of public support for the program.

We recommend that the BOCC approve Staff’s recommendations for a balanced management program based on individual farms and their needs, incorporating chemicals in moderation when necessary, in collaboration between the farmer and staff  (sec 6).

 4)  Recreation on Cropland.  This section appears to have been injected almost as an afterthought, and appears to have received little discussion.

While we understand the desire of farmers to maximize efficiency and minimize inconvenience, they are nevertheless operating on public lands.  We submit that a blanket policy of “trails shall be (located only) on the edge of properties” (sec 8) will unnecessarily limit BCPOS’ options and will result in unattractive, unsafe trails – especially for equestrians.  There could be situations where existing farm roads, ditches, or fence lines would make great trails while minimizing their impacts on the farm operations or on the environment, and that trails forced to the perimeter might be impossible to build due to topographic or other constraints and would consume more land from agricultural production.  Trails built “on the edges” of an agricultural property under the windows of nearby homes usually lead to objections from the homeowners and a diminished visitor trail experience.

We point to Rock Creek Farm as an example of a successful trail system that utilizes natural features and pre-existing farm roads while minimizing inconvenience to the farm operations.  There are several other examples of trails through agricultural properties on Boulder Open Space & Mountain Parks, and many future opportunities for regional trails that should be preserved.

Finally, the Cropland Policy proclaims that “Staff shall develop methods for creating public awareness of the role of public open space in crop and local food production” (1.10 and Appendix 3: Education and Outreach).  What better way to bring the public up close and personal with agriculture than letting them actually experience it, along a trail through it?

We suggest, as properties transition from one lessee to another, or as leases are renewed, that trail alignments be considered in the individual and regional management plan.

We recommend that this Sec. 8.1 be amended to read “Trails shall be located to minimize impact on agricultural operations but other alignments shall also be considered if feasible or desirable for the public’s enjoyment and safety.”

Some Interesting Information on Horses in Boulder County.

Did you know that there are more horses than cows in Boulder County?

There are approximately 15,000 cows (H. Lovins / Nat Cap Solutions 2011).

There are approximately 15,330 horses (Deloitte Touche/American Horse Council, 2005;  and National Agriculture Statistics Service, 1999).

Boulder County ranks fourth in the total number of horses in Colorado, with 6% of the state’s horse population (NASS, 1999).

The horse community contributes approximately $94 million to the GDP of Boulder County every year (Deloitte Touche/AHC and NASS).

This annual economic contribution includes hay and grain purchases, tack and supplies,  trucks and trailers, tractors and equipment, veterinarians, farriers, horse trainers, breeding, horse sales, horse shows and clinics, therapeutic riding programs, and many other categories.

The market value of all farm products in  Boulder County is $34 million (Cropland Policy, p8).

The market value of horse hay in Boulder County is $8 million (Lovins’ estimate of 21,319 acres in forage x ave. yield of 3T/ac /2 (half to horses, half to cattle) x $8/bale average price.

Thus the market value of horse hay alone is 25% of the market value of all farm produce.

A large proportion of BCPOS farmers produce hay and other forage for horses, in addition to other crops.  Selling horse hay is a huge source of economic security for local farmers.

Horse people maintain undeveloped (“open”) land throughout Boulder County as grazing land and for hay production.

Many horse owners manage their horses on 40 acre or smaller parcels, whereas it is difficult to manage cattle on small acreages.

Most horse properties are well-cared-for and are agriculturally productive.

Horse people support Open Space purchases for agriculture, wildlife, and recreation.

Horses are important to the quality of life of thousands of Boulder County residents.

Summary.   The horse community is vital to the agricultural heritage, rural lifestyle, and economy of Boulder County.  Please support our recommendations and those provisions of the Cropland Policy which ensure that we will be able to remain here.

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