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This agricultural land loss mitigation toolkitprovides residents, policymakers, andenvironmental justice organizations with well-sourced research and template language toinform agriculture land conservation efforts in theInland Empire Region (IER) and beyond.Compiled by student fellows from Pitzer College’sRobert Redford Conservancy for SouthernCalifornia Sustainability, the research in thistoolkit can help in sustainable developmentinitiatives that prioritize agricultural lands asclimate solutions. The toolkit begins byintroducing the issue of agricultural land loss. Byfirst highlighting the history of California’sagricultural lands and ending with potentialforms of mitigation, this toolkit highlights thebenefits of preserving farmland and provides context for community stakeholders. HISTORY OF AGRICULTURE AND LOGISTICS IN SOUTHERN CAHow to Use the Toolkit FARMLAND LOSSDevelopment is nowconsuming an average of 40,000 acres ofagricultural land per year.Toolkit OrganizationHistory & ContextBackground history of logistics industrydevelopment and farmland decline in theIER.Overview of California EnvironmentalQuality Act (CEQA) and EnvironmentalImpact Reports.Comment Letter SamplesApplicable template language on thesignificance of agriculture in the contexts ofeconomics, food security, and climatechange. Alternative Forms of MitigationOffers alternative mitigation strategies toconsider when facing agricultural land loss.Several Los Angeles Times articles summarize themanagement of agricultural land in the InlandEmpire. A key 1985 piece entitled “By Comparison,Land in the Inland Empire is Dirt Cheap,” providesevidence that the affordability of land allowed forgrowth of its citrus, row crop, and animal agricultureindustries. However, by the late 1980s the area of landused for agriculture began to decrease. The sameland, which allowed for the proliferation of anagricultural industry, was seized upon by anotherindustry with more capital and short-term revenuepotential; the IER began transitioned into a hub forthe global logistics industry. Agriculture has been a staple industry of the InlandEmpire Region (IER) since the proliferation of citrusgroves in the 1870s. At the time, the profitability of thisindustry propelled Riverside, CA to be one of thewealthiest cities in the nation. Although this wealthwas never well distributed amongst its immigrant farmworking populations, IER’s history is rooted inagriculture and so is its continued sustainabledevelopment. 1870-1990ROBERT REDFORD CONSERVANCY FELLOWSSPRING 2023 TOOLKIT FORFARMLAND CONSERVATION

Rapid loss of farmland is a significant issue not onlyfor the Inland Empire region but for all of California.The main drivers for the loss of farmland in Californiaare rapid population growth, urbanization, andinefficient use of land. In 2010, California hosted morethan 43 million acres of arable land being used foragriculture; however, by 2016 nearly 22% of this landwas lost due to development. A continued issuewithin policy efforts to protect farmland has beenthat their legislators fail to consult local farmers andcommunity members affected by these developmentprojects. We must be conscious of the roots ofCalifornia's and specifically the IER’s transition awayfrom agriculture in order to build meaningful andinformed protections for our agricultural lands.By 2015, the times reported that “people living near 60Freeway in Ontario breathe the worst air in theSouthland.” Recent California Enviroscreen data placesmany Inland Empire communities above acceptableair pollution levels. As a result, today’s Inland Empireresidents suffer from chronic health issues such asasthma, cancer, obesity, and heart disease. As airpollution increased alongside the loss of local farmsthe food landscape of the Inland Empire region (IER)began to change; roadside produce stands werereplaced by big box food outlets lacking in qualityfood. Additionally, despite 2015 predictions that the“Inland Empire was poised to be a ‘big dog’ in theCalifornia economy,” by 2018, the LA Times reportedthat fewer than half the jobs in the region paid a livingwage. Environmental justice groups and IERcommunity members have since spoken againstwarehouse and logistics industry development,however, their concerns often come into conflict withpolitical and corporate interests. High levels of poverty,air pollution, and low-quality foods has led toincreased rates of chronic illness and lower quality oflife for IER communities despite the promise ofdevelopment.CEQA PROCESSCEQA stands for the California EnvironmentalQuality Act. This act was signed into law byGovernor Regan in 1970. The purpose of CEQA,as dictated on the CA government website isto “inform government decision makers andthe public about the potential environmentaleffects of proposed activities and to preventsignificant, avoidable environmental damage.”Essentially, the CEQA process examines how aproposed activity will change environmentalconditions, compared to the baseline withoutthe activity. Some of the key actors involved in the CEQAprocess are the applicant, who represents theproposed activity, the public, the lead agency, whichis both responsible for deciding if an activity issubject to CEQA and for approving a project, and aplanning commission, which contributes towardsdecision making on the future of the proposedproject. An activity is subject to CEQA if the leadagency determines that there may be anenvironmental impact of pursuing it. When a project is being evaluated under CEQA, there arethree levels of environmental review that it can besubjected to: exempt, negative declaration or mitigatednegative declaration, and environmental impact report(EIR). A project can be exempt from further CEQA review if itmeets one of the three outlined categories of exemption: statutorycategoricalgeneralAdditional information about CEQA exemptions can beaccessed here.If a project’s impacts on the environment are not significantor can be clearly mitigated to less than significant, anegative or mitigated (if mitigation is needed) negativedeclaration should be prepared. If the project may result ina significant effect on the environment, even if mitigated,an EIR should be prepared. CEQA defines ImportantFarmland and its loss is typically treated as a significantimpact requiring an EIR.” (See CEQA Section 21095 andcross reference to Appendix G, II(A)).The final level of environmental review is an EIR. It isdecided that a project is subject to the preparation of anEIR when it can be argued, based on substantial evidence,that a project may have a significant environmental impact.

In summary, the lead agency will produce a Notice of Preparation, which indicates that they are ready to receive publiccomment on what a given EIR should address. After this, an EIR will be drafted and submitted. Once this draft EIR is released,there is a 30-45 day long comment period in which comment letters are accepted. After this, there is a public hearing in whichmembers of the public are welcome to testify. The final EIR is then produced, and further considered and certified by the leadagency. Once this is done, the project is either approved or denied. If approved, the agency will release a notice ofdetermination. Public comment is an important component of the EIR process, as is demonstrated by the fact that Final EIRsmust include responses to public comments. Public comments and public testimony are important ways for communitymembers to weigh in on decisions that they will ultimately face the burden of. EIR PROCESSGiven that an EIR is the most in-depth level ofassessing the environmental impact of a project,those pursuing projects will attempt to avoidthem. The EIR process is important and typicallysuggests that a project will have significantunavoidable impacts.. The requirements of an EIRare project description, environmental setting,significant environmental effects, unavoidablesignificant adverse effects, growth inducingimpacts, cumulative impacts, mitigation measures,alternatives, and responses to comments. Thesteps of the EIR process are as follows:Distribution of a Notice of Preparation, whichdiscusses the proposed activity and some ofthe potential impacts, requests publiccomments over a 30-day period on what theEIR should address1.Preparation of a Draft EIR, which disclosesextensively, environmental damage, mitigationefforts, and alternatives 2.Submission of the Draft EIR3.30-45 day public review period in whichcomment letters are received from the public(find tips for writing effective comment lettershere)4.Public hearing on the Draft EIR, publictestimony received5.Preparation of Final EIR, which is intended toincorporate public responses 6.Filing of a Notice of Determination if theproject is approved7.TEMPLATE LANGUAGE FOR COMMENT LETTERSThe following section offers template language for comment letters on the importance offarmlands, farmland and climate change, farmland and food security. Use these to help youargue for agricultural mitigation, which is usually not mandatory. Carbon Sequestration Capacity of Agricultural LandThe preservation of agricultural land within the IER and further California is crucial for securing asustainable, habitable future. Climate change mitigation is one of the essential benefits offarmland preservation because of the potential to capture carbon in agricultural soils andfurther to decrease greenhouse gas quantity in the atmosphere through effective landmanagement. The capacity for carbon capture through agriculture is a product of the process ofcarbon sequestration in soils. Soil carbon sequestration is defined as the process through whichatmospheric CO2 is transferred into the soil through the breakdown of plant mass and plantresidue and is stored in the soil as a component of the soil organic matter. The soil withinagricultural practices can sequester carbon. Climate-smart agricultural practices are beginningto be implemented to sequester carbon emissions, such as conservation tillage, cover crops,rotational grazing, and bio charcoal applications. In this sense, the preservation and intentionalmanagement of agricultural lands is a crucial piece of broader carbon drawdown solutions.

Economics of Farmland Preservation Farmland and its agricultural productivity helps the economy and provides food security forindividuals. In 2021, the farm industry alone accounted for $44.7 billion, making California the leadingagricultural state in the United States. Agricultural contributions to the economy are also subject to themultiplier effect, which means that contributions to the economy from agriculture actually impact thestate’s economy more than the original contribution. Agriculture in California is also uniquelyimportant in supporting the nutritional needs of a growing global population. In California, specialtycrops are grown throughout the state, which are crucial for human nutrition. Additionally, in low-density regions, such as those with high quantities of farmland, fewer greenhouse gasses aretransmitted per person. If California preserved farmland instead of encouraging the development ofindustry, the state would more actively participate in climate change mitigation. Importance of Working Lands in Building Climate ResilienceWorking lands are vital for producing food, as well as through conservation benefits such as cleanwater, wildlife habitat, biodiversity, and climate change resilience. Socioeconomic trends have beenused as an argument for preserving working lands. Rural communities might advocate forpreserving working lands and open space, hoping that the available land space will bring capital tothe area without the development of the lands. The benefits of the preservation of the working landsand public green spaces include increased air and water quality. Working lands also have thepotential to sequester carbon, reduce GHG emissions, and increase the capacity for California toadapt to the impacts of climate change. From a policy standpoint, California Governor GavinNewsom stated, “California’s natural and working lands – our forests, rangelands, farms, wetlands,coast, deserts, and urban green spaces – sustain our economy, support our unique biodiversity,contribute to the global food supply, support outdoor heritage and provide clean water and air.” Theultimate goal of the executive order is to build climate resilience within California by developing aNatural and Working Lands Climate Smart Strategy. Newsom is also dedicated to protecting roughly30% of the state’s water and land resources to preserve biodiversity. Farmland is recognized explicitly in the Executive Order, stating, “America’s farmers, ranchers, andforest landowners have an important role to play in combating the climate crisis and reducinggreenhouse gas emissions by sequestering carbon in soils, grasses, trees, and other vegetation andsourcing sustainable bioproducts and fuels.” In addition, the order emphasizes the importance oflocal control and input. Specifically, the Secretary of Agriculture should seek input from “Tribes,farmers, ranchers, forest owners, conservation groups, firefighters, and other stakeholders on how tobest use Department of Agriculture programs, funding, and financing capacities, and otherauthorities, and how to encourage the voluntary adoption of climate-smart agricultural and forestrypractices that decrease wildfire risk fueled by climate change and result in additional, measurable,and verifiable carbon reductions and sequestration and that source sustainable bioproducts andfuels.”Most EIRs indicate that agricultural land cannot be mitigated to a less-than-significant level, but CEQArequires that impacts are mitigated to the extent it is feasible (including economically) to do so. In thelast few years the Courts, responding to EIR challenges, have generally taken the position that somelevel of mitigation is feasible. Some counties and municipalities have created voluntary agriculturalland loss mitigation policies for the direct replacement of lost farmland, which is our recommendation.Mitigation should include funding for the purchase of land for direct conservation. Working withorganizations who are able to hold land in trust, mitigation monies can be banked for direct landpurchase--ideally within the municipality. If cities are not willing to adopt ordinances, litigation cansometimes lead to mitigation, and it is best to partner early on with an organization that isexperienced and able to litigate on your behalf. This can cost money, but oftentimes firms work at areduced rate or pro-bono, depending on the circumstances. Mitigation funds can be given to urbanagriculture organizations in the form of endowments or other contributions as described below. DIRECT LAND CONSERVATION: THE MOST IMPORTANT FORM OF MITIGATION

ALTERNATIVE FORMS OF MITIGATION: URBAN AGRICULTUREDevelopment projects often include what is calleda statement of "overriding consideration," meaningthat the impacts are considered "significant andunavoidable." No matter the language used, beassured that something can always be done. Iflarge-scale land replacement is deemedimpossible, exploring creative alternatives forurban agriculture support usually is feasible. Outside-the-box thinking can help to establishrealistic mitigation plans that grow alongsideunsustainable land uses. Some ideas include: Money for endowments to support local urbanagriculture nonprofits like those in the InlandEmpire region listed below. Access to municipally owned smaller landplots in which ownership is transferred orwhere long-term leases or land useagreements are brokered. Adoption of an ordinance asking for farmlandmitigation and/or allowing urban agriculture totake place throughout a city.Well organized alternative forms of mitigationhave the potential to provide employmentopportunities, new revenue streams, andcommunity involvement. UNCOMMON GOOD COMMUNITYFARMING:GrowRIVERSIDE is a community initiative thatinterests multiple stakeholders in food andagricultural efforts across the Southern CaliforniaInland Empire Region. They are organized to equipcommunity groups with tools and knowledge forstronger local food systems that generateopportunities for community and economicdevelopment. Through food waste programs andfarmer training programs, they help to further andmaintain agricultural land preservation efforts. Inaddition to their community involvementmeasures that are also dedicated to advancingagricultural policy throughout the Inland EmpireRegion, as evidenced by their Food Policy ActionPlan. Efforts like these lay the groundwork for noveland resilient food systems readied for climatechange and future industrial growth.GrowRIVERSIDE:The non-profit organization Uncommon Good hasdeveloped a model under the name CommunityAlliance for Urban Sustainable Agriculture, in whichfood is collected from urban farm plots aroundClaremont, Pomona, and Ontario. The food isgrown at public schools, places of worship, sisterorganizations, and private homes and is thendistributed to the local community, supplyingcommunity members with high-quality fruits andvegetables that they wouldn’t otherwise be able toafford. This model is especially exciting in that itprovides an avenue for homeowners to put theirunused produce to use. While this program may bechallenging to start or facilitate, it provides a modelfor the inclusion of households in urban foodsystems. If agricultural lands are being lost due toan increase in development, communities andindividual households can take initiative to createshared networks of growing food that utilize theirown urban spaces, likely their backyards. HUERTA DEL VALLEHuerta del Valle is a grassroots, non-profit organizationbuilding a network of urban farms and communitygardens throughout the Inland Empire Region ofSouthern California. In doing so they aim to create anaccessible and equitable food system and providehealthy, organic produce for everyone in the InlandValley region. Their model provides tangible means to support thedevelopment of a food system in which residents ofthe IER are able to access affordable food that is ofhigh quality and sustainably grown. Efforts such asthese are prime examples of replicable means of foodproduction and economic and environmental justice.In establishing a garden or farm for every square mileof residential space, food systems becomemechanisms through which ordinary people can learnabout problems related to food access, nutrition, andsustainability while actively practicing their solutionsand growing their own food.

AGRICULTURE LOTS AND HYDROPONICS: Vacant plots of land provide opportunities to redistribute and revitalize land according to community need. Any areawhich has yet to undergo or is left derelict from development is an opportunity to establish food growing locations.The EPA offers grants to groups making efforts to clean up “brown fields,” property previously marred by the presenceof hazardous substances, pollutants, or contaminants. A number of communities have successfully used these grantsto establish urban agriculture projects, building food systems that provide sustainable means to feed localcommunities. Additionally, empty parking lots and warehouses provide opportunities for growing without soil through hydroponics.Despite valid criticism for high start-up costs and lack of natural nutrients given the absence of soil, hydroponicsprovides a viable form of alternative land use in areas that cannot be quickly remediated. Hydroponics have beenshown to yield produce in higher volumes and greater size. Thus, alternatives such as these are ideal options by whichpolluted or paved spaces can be turned into growing areas. GREEN ROOFING: Green roofs are an alternative when no ground space exists in the form of vacant lots, for example, as they work atopexisting infrastructure. Case studies throughout the U.S. demonstrate that they provide an effective way to increasegreen space within an urban environment and can even help to mitigate issues of food scarcity and obesity withinsurrounding communities. Planting rooftop vegetable gardens, for example, increase the supply of healthy food andencourages community members to become more involved with the source of what they eat, which has been shownto decrease obesity in urban areas. Furthermore, projects like these encourage community engagement byincorporating local ideas. One community garden in South Side, Chicago, located atop the Gary Comer Youth Center,is a good case study to examine in looking to replicate this program in the Inland Empire. The rooftop farm covers ⅓acres and produces up to 1,000 pounds of produce, including potatoes, sweet potatoes, veggies, herbs, and flowers,which are distributed at a youth-led farmers’ market and through an entrepreneurial project. In San BernardinoCounty, 42.6% of students were considered overweight or obese in 2019, compared with 39.7% statewide and up from41.1% in the county in 2018. Given the success of many existing community garden programs located strategically onroofs and lots, it is evident that Inland Empire communities could reap their benefits, especially for youngergenerations. However, it is important to note that in order for green roofs to be net beneficial, their positive effectsmust exceed losses from construction, irrigation, resource management, and maintenance labor. That said, green roofsshould be seen as a last-resort solution for lost agricultural land, only to be used in extreme cases when no open spaceexists on the ground.EDIBLE LANDSCAPES:Food-producing wall mounts, called “edible landscapes” by the LA Initiative Urban Farming Food Chain Project, offer asimilar creative solution. These wall systems, typically made of aluminum or stainless-steel panels, are designed togrow fruits, vegetables, and herbs vertically and have been used in downtown LA to help feed low-income andhomeless people. New policies adopted in the Inland Empire could require the planting of green roofs and ediblelandscapes on new and existing buildings as an alternative to strict preservation. Mitigation strategies like these alsoprovide opportunities for partnerships with local organizations; collaboration with groups like Huerta del Valle couldinvolve affiliated farmers in planting green roofs and edible landscapes.

BIBLIOGRAPHYBai, Xiongxiong, Yawen Huang, Wei Ren, Mark Coyne, Pierre‐Andre Jacinthe, Bo Tao, Dafeng Hui, Jian Yang, and Chris Matocha. “Responses of SoilCarbon Sequestration to Climate‐smart Agriculture Practices: A Meta‐analysis.” Global Change Biology 25, no. 8 (August 2019): 2591–2606.https://doi.org/10.1111/gcb.14658.Barboza, Tony. “People Living near 60 Freeway in Ontario Breathe the Worst Air in the Southland.” Los Angeles Times, September 9, 2015.https://www.latimes.com/science/la-me-freeway-soot-20150909-story.html.“Benefits of Farmland Conservation in California .” California Department of Food and Agriculture , 2015. Boel, Jan , and Terry Roberts. “MitigatedNegative Declarations .” Governor’s Office of Planning and Research , December 2004.“California 2030 Natural and Working Lands Climate Change Implementation Plan,” n.d. “CEQA: The California Environmental Quality Act - Office ofPlanning and Research,” n.d. Accessed November 20, 2022.Downey, Hannah . “The Role of Working Lands in Providing Public Conservation Benefits .” Property and Environment Research Center , October 2017.“Executive Order on Tackling the Climate Crisis at Home and Abroad.” White House , January 27, 2021.Edward Thompson. “Agricultural Land Loss & Conservation.” American Farmland Trust, 2009.https://www.cdfa.ca.gov/agvision/docs/agricultural_loss_and_conservation.pdf.FIC. “California Data and Statistics.” Accessed November 18, 2022. https://farmlandinfo.org/statistics/california-statistics/.George , Shannon, and Mark Teague. “Ceqa from the Beginning.” League of California Cities Planning Commissioner’s Academy, March 4, 2020.Gashgari, Raneem, Khawlah Alharbi, Khadija Mughrbil, Ajwan Jan, and Abeer Glolam. “Comparison between Growing Plants in Hydroponic System andSoil Based System.” Department of Industrial Engineering, King Abdulaziz University, August 18, 2018.http://avestia.com/MCM2018_Proceedings/files/paper/ICMIE/ICMIE_131.pdf.Goldstein, Nora. “BioCycle.” COMPOST CONNECTIONS, October 2009. https://www.biocycle.net/images/art/0910/bc0910_24_30.pdf.“Home – GrowRIVERSIDE.” Accessed November 20, 2022. http://growriv.com/.Hsu, Tiffany. “Inland Empire: Poised to Be a ‘big Dog’ in California Economy?” Los Angeles Times, March 20, 2015. https://www.latimes.com/business/la-fi-inland-empire-economy-20150319-story.html.Huerta del Valle. “Huerta Del Valle.” Accessed November 20, 2022. https://www.huertadelvalle.org.Isler , Phoenix Lawhorn. “Overview of CEQA and the EIR Process – and How You Can Participate.” Mount Shasta Ecology Center , n.d.Kane, Daniel . “Carbon Sequestration Potential on Agricultural Lands: A Review of Current Science and Available Practices.” National SustainableAgriculture Coalition Breakthrough Strategies and Solutions, LLC, November 2015.Kline, Jeffrey D. “Public Demand for Preserving Local Open Space.” Society & Natural Resources 19, no. 7 (August 2006): 645–59.https://doi.org/10.1080/08941920600742419.Lal, Rattan, Wakene Negassa, and Klaus Lorenz. “Carbon Sequestration in Soil.” Current Opinion in Environmental Sustainability 15 (August 1, 2015): 79–86.Lehrer, Mia, and Maya Dunne. “Urban Agriculture: Practices to Improve Cities.” Urban Land Magazine , November 18, 2015.Masters, Nathan. “When Oranges Ruled the Inland Empire.” KCET, March 12, 2016. https://www.kcet.org/shows/lost-la/when-oranges-ruled-the-inland-empire.Newsom, Gavin . “EXECUTIVE ORDER N-82-20 ,” 2020.Perrin, Coline, Camille Clément, Romain Melot, and Brigitte Nougarèdes. “Preserving Farmland on the Urban Fringe: A Literature Review on LandPolicies in Developed Countries.” Land 9, no. 7 (July 2020): 223. https://doi.org/10.3390/land9070223.San Bernardino County Community Indicators. “Overweight & Obesity.” Accessed November 20, 2022.https://indicators.sbcounty.gov/wellness/overweight-obesity/.San Bernardino County Community Indicators. “Chronic Disease,” 2022. https://indicators.sbcounty.gov/wellness/chronic-disease/.Simons, Eric. “California Commits to 30% by 2030 -- What Does That Mean?” Bay Nature, December 2, 2020. https://baynature.org/2020/12/02/california-commits-to-conserving-30-percent-of-its-land-and-water-by-2030-what-does-that-mean/.“Programs – Home.” Accessed November 20, 2022. http://growriv.com/programs/.“Urban Agriculture | Uncommon Good,” January 30, 2022. https://uncommongood.org/farm/.Greenroofs.com. “Urban Farming Food Chain - Los Angeles Regional Food Bank Green Wall.” Accessed November 20, 2022.https://www.greenroofs.com/projects/urban-farming-food-chain-los-angeles-regional-food-bank-green-wall/.CalRecycle Home Page. “What Is a Lead Agency?” Accessed November 20, 2022.https://calrecycle.ca.gov/swfacilities/permitting/ceqa/overview/leadagency/.TO VIEW TOOL KIT WITH INTEXT CITATIONS GO TO THE FOLLOWING LINK:HTTPS://DOCS.GOOGLE.COM/DOCUMENT/D/1E3KPSWBHTL9WXDXNTIHE4RXUTNRTX6HMTNBZTU88JMM/EDIT?USP=SHARING