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Drought Media Coverage: Balanced News Now Appears Regularly

Balanced stories about California Almonds and the drought now appear more consistently in news coverage. The Almond Board of California (ABC) continues to see negative views and misinformation daily, but the influence and reach of the balanced publications is now approximately matching that of the negative on a day-to-day basis. The economic and dietary value of almonds is now a recurring theme in balanced coverage. Water intensity of almonds and groundwater usage are two of the most discussed topics. ABC is rapidly responding to negative stories and correcting misinformation.  At ABC’s Board of Directors' meeting on April 21, the role of leadership for almonds in the ongoing dialogue about the future of water use in California was prominent.  ABC has become the first point of contact for outlets ranging from the Sacramento Bee to the Huffington Post and New York Times. We continue to generate positive media coverage, while delivering industry messages on bee health, water efficiency, family farming and the economic value of almonds. We’d like to share Almond Board research-based information with you so you have all the facts at your fingertips on the Almond Board blog. We hope you use them when you bump into a questioning friend at the grocery store or an inquiring mind at the office. Please call Carissa Sauer at (209) 343-3284 or send her an email with your input on the water discussion within our industry and among all Californians. We want to hear from you as we collectively continue to resolve the public relations challenge.
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// About the Almond Board

Soil- and Plant-Based Monitoring Refine Irrigation Decisions

Irrigation Considerations During Drought Part IV Monitoring for moisture in the soil and stress levels in the leaves can help almond growers determine the proper interval and duration of water applications for more efficient irrigation in variable environments. Soil monitoring and plant-based monitoring are complementary to each other and also to weather-based monitoring methods. Plant-based methods indicate when to irrigate, but not how much; the weather-based method indicates how much but not when; and soil-based methods indicate how much moisture is in different areas of the root zone and orchard, and therefore how much to irrigate. David Doll, UC farm advisor in Merced County, said soil-based monitoring through methods such as neutron probes, tensiometers, capacitance and TDR sensors — or even the feel method — can help almond growers understand the depth of water in the soil, which can help determine how long to run irrigation sets to fill the soil profile. Plant-based methods, such as pressure chambers and the “touch and feel” method, can help growers manage plant stress levels regardless of soil conditions. This can be used to troubleshoot irrigation problems and to time moderate stress when using strategic deficit irrigation (SDI). Soil Moisture Monitoring Under low soil moisture conditions, water is held at a greater tension, and less water is available for tree roots, resulting in greater stress. Monitoring and maintaining soil moisture within acceptable limits that do not adversely affect plant growth is critical. A number of soil moisture monitoring tools are available, including tensiometers, dielectric sensors, electrical resistance, neutron probes and the “feel” method. Each has different calibration and maintenance requirements, and many can be incorporated into automated irrigation systems. Plant Moisture Monitoring Current plant-based monitoring tools include pressure chambers, sap flow sensors and dendrometers. Each of these methods measures a different aspect of the plant to indicate realtime stress levels, regardless of soil conditions. These measurements are useful in troubleshooting irrigation schedules and managing SDI. Each tool has strengths and weaknesses: The pressure chamber requires time, as it is not automated, while automated systems (e.g., sap flow sensors and dendrometers) require calibration. Soil Variability With all moisture-monitoring techniques, Doll noted, it is important to account for soil variability in taking samples and interpreting readings. Ideally, you should take a cross-section of plant-based readings from different soil types. For soil-based readings on large plots, place multiple sensors throughout the plot. For small plots, place sensors on coarse soils in the lowest-holding-capacity soil and choose short, frequent irrigations. In heavier soils, put sensors in the area with the lowest infiltration rate and irrigate longer with lower volume sets. Special care is needed when installing soil moisture sensors in coarse-textured soils to maintain good contact with the soil and to ensure readings truly represent soil water content. Conversely, some sensors in heavier-textured clay soils do not give accurate readings at higher soil water content levels. The next issue of California Almonds Outlook will look at the next generation of irrigation monitoring techniques, including aerial imaging and variable-rate irrigation, that are on the horizon for almond growers. More information on monitoring techniques to manage irrigation can be found online: “Drought Tips: Drought Management ,” UC ANR publication 8515.  “Using the Pressure Chamber for Irrigation Management in Walnut, Almond and Prune”  UC Drought Management website Monitoring Soil Moisture for Irrigation Water Management, UC ANR Publication 21635
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// Orchard Management

Groundwater Management Meeting to Be Held in Modesto

Signed into law last year, the Sustainable Groundwater Management Act (SGMA) represents a fundamental change in how California will manage its groundwater supply. SGMA requires the formation of local Groundwater Sustainability Agencies (GSAs) and development of new Groundwater Sustainability Plans (GSPs) in an effort to bring California groundwater basins into sustainability. For those interested in an in-depth look at the intricacies of the Act and the GSPs that will be developed to locally manage each basin, the Groundwater Resources Association of California will host a symposium devoted to this topic on Wednesday, Sept. 2, at the DoubleTree hotel in Modesto. A series of four panel discussions will feature experts from the National Groundwater Association, California Department of Water Resources, California State Water Resources Control Board, U.S. Geological Survey, University of California, Davis, and more. Topics for discussion will include: sustainability of groundwater — definition and yield, science and technology of sustainable yield, portfolio of management options for physical solutions, dynamic water and fee allocations, and developing successful GSPs. The event will take place from 8:00 a.m. to 4:00 p.m.; a detailed agenda can be found here. Register before Aug. 19 to take advantage of early registration discounts. Additionally, discounted hotel rates are available through Aug. 17. For those unable to attend the event, below are important deadlines for the implementation of the Act. California Almond growers are encouraged to engage locally, as these important agencies and sustainability plans are developed throughout the growing region. June 30, 2017: Formation of Groundwater Sustainability Agencies (GSAs). Jan. 31, 2020: Completion of Groundwater Sustainability Plans (GSPs) in critically overdrafted basins. Jan. 31, 2022: Completion of GSPs in all other basins. 20-year implementation period: Implementation of GSPs under local management.  
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// Government Affairs

Back to School with “An Almond Story”

The Almond Board of California (ABC), along with California’s Agriculture in the Classroom program, would like to see all six million children in the state’s elementary schools grow up understanding where their food comes from, and to expand these students’ knowledge of agriculture, the environment and natural resources. With that goal in mind, ABC produced “An Almond Story,” which gives students a glimpse of the journey almonds take from orchard to table. The experience starts with a six-minute animated movie about the almond life cycle, covering bloom, pollination, hullsplit, harvest and dormancy, and how important almonds are to California and the economy. Next, the students participate in a hands-on activity simulating pollination. And finally, every student receives “An Almond Story” activity book. The activity book reviews the concepts from the video, including the life cycle of almonds, pollination, jobs in agriculture, nutrition basics and delicious recipes with almonds as the special ingredient. At the end of the presentation, students understand where almonds come from, and how those almonds get into their hands. The presentation is very interactive and covers core curriculum concepts in science and nutrition. Throughout the summer, ABC presented “An Almond Story” to local youth groups and summer camps, including the Maddox Youth Center in Modesto. “I highly recommend your Almond Board of California presentation to everyone,” says Bruce Lockard, the recreation supervisor at Maddux Youth Center. “It was very educational and a memorable experience for our youth and staff.” “An Almond Story” activity books are available to all educators for classroom use, and the accompanying video can be accessed online. For copies of the activity book, contact Rebecca Bailey at rbailey@almondboard.com. A classroom presentation with guest speaker may be available for some schools. Coming soon is a set of lesson plans for use with these educational tools. Since 2009, ABC has shared more than 60,000 copies of “An Almond Story” activity book to students across the Central Valley and will continue to expand the program into schools statewide.  
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// About the Almond Industry

FSMA Files: Straight Talk from the Experts

Welcome to the first edition of our new FSMA Files column! We’ll use this column to provide you with easy-to-understand answers to your Food Safety Modernization Act (FSMA) questions. With so much FSMA chatter these days, sometimes it’s hard to know where to turn to get clear, accurate information. Our goal is to make FSMA understandable and cut through all of the noise. This column is prepared by attorneys Maile Hermida and Elizabeth Fawell, who are consultants to Almond Board of California (ABC) on FSMA issues. Based in Washington, D.C., with the global law firm Hogan Lovells, Hermida and Fawell are “food lawyers” who have worked on FSMA since the very beginning. In fact, Fawell was involved back when the legislation was being drafted on Capitol Hill. Both consultants were extensively engaged with FDA during the multi-year rulemaking process and prepared more than 100 comments to the agency. A large large part of Hermida and Fawell’s work now involves advising companies on what FSMA means for their businesses, helping them to develop compliance strategies, and providing strategic advice on public policy issues. To that end, ABC has retained them to help navigate the complex maze of FSMA compliance for the California Almond industry. Some of you may already know them, as they have been working with ABC for a few years, have visited almond operations throughout the supply chain, and presented at both the Almond Quality and Food Safety Symposium and The Almond Conference. The two lawyers understand the industry and FSMA first-hand. In this FSMA column, they will apply that knowledge to help answer questions or concerns you may have around which rules may apply to your operation, and offer tips on how to comply. FSMA Q&A by Maile Hermida and Elizabeth Fawell  When you ask us FSMA questions, our goal is both to provide you with an answer in plain language and to give you the supporting explanation, in case you need to dive deeper. You’ll see our unique approach in the questions and answers below. We strive to provide more direct and timely responses than you’ll receive if you submit questions to FDA through its Technical Assistance Network (TAN) advice portal. Since this column is written by lawyers, we can’t get by without a few important disclaimers.  First and foremost, this column is provided for informational purposes only and does not constitute legal advice. We are not acting as your lawyers in preparing this column. If you have legal questions, we encourage you to work with us directly or with your legal counsel. We hope you’ll find this column to be a useful resource. Feel free to send your questions to Tim Birmingham at tbirmingham@almondboard.com with “FSMA Files” in the subject line. Check future issues of The Handle to see our responses. Now for our first questions! Question: Do almonds processed for export need to comply with the Preventive Controls rule? Straight Talk: No. The Preventive Controls rule only applies to food intended for consumption in the United States. This is different from how the Produce Safety rule works, as discussed in the next question below. Explanation: The Preventive Controls rule only applies to “registered facilities.” A facility is not required to register with FDA if it does not manufacture, process, pack or hold food for consumption in the U.S. Following that framework, if a facility has some operations that relate to food for U.S. consumption and some operations that relate to food for foreign consumption, the Preventive Controls requirements only apply to the food for U.S. consumption. That being said, if a facility produces food for both domestic and foreign consumption, the aspects of the operation related to foreign consumption could become relevant to Preventive Controls compliance if they could affect the safety of the U.S. food. For example, if treated almonds for U.S. consumption are on an adjacent line to untreated almonds for export, this could affect the safety of the treated nuts; therefore FDA would likely want to see controls in place that relate to the exported nuts to protect the safety of the U.S. food. Also, even though the Preventive Controls rule doesn’t apply, note that there are other FDA regulations governing food for export that would apply, such as requirements concerning labeling the food and ensuring it meets the requirements of the country for which it is intended. Question: Do almonds grown for export need to comply with the Produce Safety rule? Straight Talk: Yes. All produce grown in the U.S. needs to comply with the Produce Safety rule (unless it falls under an exemption, such as if it will be subjected to commercial processing downstream or it’s grown by a farm with under $25,000 in average annual produce sales — See “Silver Lining” below for exemption information). This is different from the way the Preventive Controls rule works, as discussed in the above question. Explanation: The Produce Safety rule explicitly states that it applies to all produce grown domestically, regardless of whether it is for domestic or foreign consumption. The regulation states:  “Unless it is excluded from this [regulation], food that is produce ... and that is a raw agricultural commodity (RAC) is covered by this [regulation]. This includes a produce RAC that is grown domestically and a produce RAC that will be imported or offered for import in any state or territory of the United States, the District of Columbia or the Commonwealth of Puerto Rico.” 21 C.F.R. § 112.1(a). (See also 80 Fed. Reg. at 74386.) This means that, in order for the produce to qualify as exempt from the rule, the written disclosure and written customer assurance provisions for produce that will receive commercial processing downstream apply to exports as well. Silver Lining: ABC has been engaged with FDA on what a grower exemption would look like.  Based on ABC understanding (and recognizing we do not have written confirmation from FDA on this approach), an exemption may be possible if: Growers provide written disclosure that almonds are not processed to adequately reduce the presence of micro-organisms of public health significance, and; Handlers provide a written assurance to the grower that almonds will be treated in accordance with the requirements under the mandatory program for Salmonella reduction on almonds, or otherwise will be exported with a disclosure that they are not processed to adequately reduce the presence of microorganisms of public health significance and should be treated in accordance with the regulatory requirements of that country, with such written assurances provided by the customer. Question: Can companies set up separate facility registrations for the different types of operations performed on the same campus, so that they can take advantage of the compliance date extension for facilities “solely engaged” in packing or holding nut hulls and shells? Straight Talk: No. FDA has made it clear all operations owned by the same party and performed at the same general location fall under the same facility registration. Explanation: It would not be possible to obtain separate facility registrations for these different operations unless the ownership was different. That is because of the way FDA has defined “facility” for purposes of facility registration, which is:  “Facility means any establishment, structure or structures under one ownership at one general physical location, or, in the case of a mobile facility, traveling to multiple locations, that manufactures/processes, packs or holds food for consumption in the United States. A facility may consist of one or more contiguous structures, and a single building may house more than one distinct facility if the facilities are under separate ownership.” Even if this business has different structures engaging in different activities, it would still be considered one facility if the ownership is the same. Therefore, it could not register the operations separately to take advantage of the extended compliance date, based on the present ownership scenario. Please keep the questions coming!   
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// Quality and Food Safety
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