I would like to comment on the proposed changes to the federal regulations regarding the Criteria for Releasing Fields from Regulation proposed under Docket No. 04-134-1.
I believe there needs to be some additional clarification for section 301.89-3-f-1 which states that a field can be removed from regulation if it is no longer used for crop production. There are a number of regulated fields in California which I understand recently sold their water rights to the city of Los Angeles for an extensive period of time (over 10 years). From my perspective, this would allow them to be deregulated under the current criteria of "non-crop production". In confering recently with a number of Karnal bunt program managers I was stold that this criteria was defined as having construction build over the fields (eg houses, shopping center, eg). If this criteria could be extended to also include agricultural land taken out of production for a extended period of time, the area of regulation in California would be substantially reduced.
Comment from Gary Peterson
This is comment on Proposed Rule
Karnal Bunt; Criteria for Releasing Fields From Regulation
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