FMMP is a nonregulatory program that produces the Important Farmland maps and GIS data. These maps provide a consistent and impartial analysis of agricultural land and land use changes throughout California. FMMP's study area aligns with modern soil surveys developed by the United States Department of Agriculture's Natural Resources Conservation Service (USDA-NRCS). The classification system used by FMMP to produce the Important Farmland maps combines technical soil ratings from the USDA-NRSC soil surveys and current land uses. Most public land areas, such as National Forests and Bureau of Land Management holdings, are not mapped. Over time, regulatory programs have used the Important Farmland data for a variety of purposes, including CEQA guidelines and county mitigation ordinances. In addition, some Federal, State, and local grant programs guidelines have also referred to the Important Farmland maps to determine if a project would impact agriculture.
Important Farmland Mapping
Map Categories
Important Farmland maps were originally a product of the USDA Soil Conservation Service (SCS), which was renamed the NRCS in 1994. The California Important Farmland map categories were established through a Memorandum of Agreement (MOU) with the USDA-SCS and modified by California beginning in 1982. The following map categories are covered in the MOU: Prime Farmland, Farmland of Statewide Importance, Unique Farmland, Farmland of Local Importance, and Urban and Built-Up Land. The Grazing Land, Other Land, and Water categories were developed by the Department of Conservation to accommodate land that didn't qualify for any of the Important Farmland categories or Urban and Built-Up Land. The Important Farmland categories and Grazing Land are also found in Government Code section 65560(c).
Map Scale
The Important Farmland maps are typically published at a scale of 1:100,000 and are held to a national map accuracy standard for that scale. Some select county maps are published at 1:120,000. FMMP applies a minimum map unit of 10 acres to map land use because 10 acres is the smallest unit visible at the 1:100,000 scale. Similarly, FMMP has a policy of only mapping linear features wider than 1/10th of a mile (161 meters) because linear features less than that are not visible at the 1:100,000 scale. FMMP is striving to improve the spatial accuracy of the Important Farmland maps and has begun mapping “significant linear features" such as interstate highways and water delivery canals. It is not possible to map smaller roads and features and meet the statutory requirement of publishing maps every two years.
Map Production Timing
The Important Farmland maps are always in arrears of the current date and current land use. FMMP generates updated Important Farmland maps for 50.6 million acres. It takes two years to map this area.
FMMP currently relies on USDA National Agriculture Imagery Program (NAIP) imagery to determine land uses when updating the Important Farmland maps. This imagery is usually captured during the late summer months of even numbered years. The imagery is then post-processed by the federal government for quality and to create countywide mosaics and color-matching image tiles. The imagery is typically available for use by FMMP six months after capture. The FMMP then spends up to two years mapping each county in the survey area, releasing county-specific information as it is ready. Counties may be mapped at any point during the update cycle. These timelines and constraints may result in months or years-long differences between the map date (the date the land use imagery was obtained) and the current date.
California Environmental Quality Act (CEQA) and Important Farmland Maps
CEQA compliance is evaluated at a project level. When determining a project's potential impacts to agriculture for CEQA compliance, lead agencies refer to the CEQA Statutes and Regulations located at Public Resources Code section 21000
et seq. and California Code of Regulations (CCR), Title 14, Division 6, Chapter 3. Appendix G of these Regulations provides an Environmental Checklist Form (Checklist) that can be “used to meet the requirements for an initial study when the criteria set forth in CEQA Guidelines have been met." (14 CCR Div. 6, Ch.3, App. G.)
Section II of the Checklist focuses on agriculture and forestry resources and refers to the Important Farmland categories mapped by the FMMP:
“[w]ould the project: Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?" (14 CCR Div. 6, Ch.3, App. G, §II(a).)
Because the Important Farmland maps are created for viewing at a 1:100,000 scale, they may not be detailed enough to support a site-level evaluation of a project's impacts on agriculture, depending on the characteristics of the individual site. Further, while the Checklist and its questions can be an effective tool for local agencies to use to determine a project's impacts to agriculture, it is not a mandated form or set of questions. It is a sample and can be used as is or tailored for an individual agencies' needs and project circumstances. (San Francisco Baykeeper, Inc. v. State Lands Com. (2015) 242 Cal.App.4th 202, 227.) As stated in the introduction to the Checklist:
“NOTE: The following is a sample form that may be tailored to satisfy individual agencies' needs and project circumstances. ... Substantial evidence of potential impacts that are not listed on this form must also be considered. The sample questions in this form are intended to encourage thoughtful assessment of impacts, and do not necessarily represent thresholds of significance." (14 CCR Div. 6, Ch.3, App. G)
When small or narrow features such as roads or canals are present on the landscape but are mapped as Important Farmland on the most recent Important Farmland map, local agencies can consider those conditions in addition to the Important Farmland data when evaluating impacts to agricultural land.
Alternately, the
Land Evaluation and Site Assessment (LESA) model, listed in Section II of the Checklist, is an option for quantitatively assessing impacts on agriculture and farmland that doesn't rely on the Important Farmland maps.
Lead agencies have “substantial discretion in determining the appropriate threshold of significance to evaluate the severity of a particular impact, and overriding considerations can also be used by local governments to approve projects based on their merit, despite the unavoidable adverse impacts to agriculture determined through the CEQA process. (Mission Bay Alliance v. Office of Community Investment & Infrastructure (2016) 6 Cal.App.5th 160, 192; 14 CCR §15093)
Grant Programs and FMMP Map Categories
Federal, State, and local grant programs may also rely on the Important Farmland maps when determining whether a project is eligible or should be prioritized for funding. The following Important Farmland map categories constitute agricultural land according to California Government Code section 65560(c): Prime Farmland, Farmland of Statewide Importance, Unique Farmland, Farmland of Local Importance, and Grazing Land. These five categories encompass 31.3 million acres, or 63 % of the statewide survey area as reported in FMMP's 2016-2018 Farmland Conversion Report. Some grant programs may use these categories to qualify or disqualify project(s) for funding, as described in those programs' grant guidelines. Choosing to use the Important Farmland maps and categories in this way is the prerogative of the grant administrator. FMMP will not accommodate requests to update maps based on this use.
Agrivoltaics
Agrivoltaics integrates solar photovoltaic panels and agriculture on the same parcel and is becoming of greater interest to farmers, the solar industry, and utilities.
FMMP has established a policy of mapping solar photovoltaic panels as Urban and Built-Up Land despite any presence of agriculture among the panels. Because FMMP interprets land uses from aerial imagery, solar panels limit the ability of FMMP to monitor the irrigation status or the discontinuation of agriculture onsite. Panels also constitute permanent urban infrastructure, which FMMP maps as Urban and Built-Up Land. FMMP acknowledges that some agrivoltaics projects have conditional use permits mandating the removal of the photovoltaic panels upon qualifying events. If those events happen and the panels are removed, the land will once again be mapped as Important Farmland.
When an agrivoltaics project is mapped as a conversion of agriculture on an Important Farmland map, a lead agency may determine that mitigation measures are required under a local ordinance or policy. Alternatives under CEQA for determining the impacts to agriculture could be considered by the lead agency, as discussed above.
