Page 6 of 6
· Purpose of Audit
o To help determine the status of the Team Member in meeting the FamilyFarms’ Environmental Standard.
· Through FamilyFarms corporate, each FamilyFarms’ member will provide Validus:
o Total number of current operating units, names of “lost” operating units from the previous year, and names and location information (FSA maps or Crop Insurance Maps) for operating units added this crop year.
o Any changes in what is considered the “Home Place”
o The names of 10% of the steepest added operating units
o The names of 10% of the steepest from the original operating units that have not yet had a field visit.
o A list of those teams with FamilyFarms identity preserved sales contracts, and the items to be audited from each contract.
· Using these location maps, Validus will prepare aerial photographs, etc. that will all be at the same scale for a given farm, and have an appropriate legend. For all of the maps, it would be very helpful to know the date of the flight of the background aerial photo:
o Map 1: a recent aerial photo (if possible, in the spring to late May-June) of the area locating streams, roads, the operating unit boundary, field boundaries and the cropland acreage within each field boundary (CLU boundaries and acreage from FSA map)
o Map 2: a soil map of the area with field boundaries and a shading of the soil map units on the crop fields that make up approximately 10% of the steepest cropland acreage—in order to have the drainage lines, Validus may decide to provide the county soil survey, and the contractor would have to overlay the field boundaries and get the scale to match the other maps
o Map 3: a USGS map with field boundaries
· Validus staff evaluates and selects approximately 10% of the fields on each operating unit for review per the assessment guidelines:
o Slope steepness by soil map unit (Use map 2)
o Potential for Ephemeral sites (Use map 2 and 3)
o Potential for sensitive areas within or adjacent (Use map 3)
o Document in the Preparation Phase section of the Cropland Environmental Assessment Off-Site and On-Site Findings, the Ephemeral Gully Worksheet, and Sensitive Areas Worksheet
· For the current year selected fields, and fields with nutrient and/or pesticide non-conformances from previous years Validus provides Map 1 and a Water Quality (the “label rate” column is hidden) record collection worksheet to each FamilyFarms member. Request that they provide, within one week, the records needed for the field(s) to complete the off-site evaluation, and a copy of the FSA HEL/NHEL maps for the fields to be audited.
· Using the maps, client records provided, and the assessment tools (WEE, MMP or equivalent, State nutrient recommendations materials, P-index), assessors will complete the off-site portion of the assessment as follows.
· Off-site Portion of the Environmental Audit:
I Previous Action Plan(s)
· Validus evaluates nutrient and/or pesticide non-conformance actions scheduled for the current crop year
II. Soil Quality:
· Validus will complete a web check or phone call to see if there are any local regulations requiring treatment below “T”.
· The off-site contractor locates and provides county specific information in order for on-site contractor to run RUSLE2 and the alternative conservation system requirements if appropriate.
o Ephemeral Gully Erosion (Validus):
§ Using the soil map 2 (supplemented by the USGS map 3 if needed), identify and document potential ephemeral erosion control sites on the same field(s) as for the RUSLE2 or Wind Erosion evaluation
§ Review aerial photo for obvious treatment in place on the identified sites
§ Document results on the “Ephemeral Gully Erosion Treatment Worksheet”
o Wind Erosion Equation (WEE)
§ Validus will contact NRCS to determine Critical Erosion Period
§ Off-site Contractor:
· Use soil information from the County Soil Survey to determine if wind erosion is an issue (I x C of 20 or more)
· If there are fields with this type of wind erosion potential, using the NRCS information from the local field office technical guide, identify the crop fields that make up approximately 10% of the fields with the highest wind erosion potential.
· Documentation of results will be the Wind Erosion Report Worksheet.
o Organic Matter Depletion:
§ There is no off-site phase for this resource concern.
III. Water Quality
o Field application of Nutrients
§ Validus will complete a web check or phone call to see if there are any local regulations requiring application rates at less than agronomic recommendations in the NRCS 590 (Nutrient Management) Standard.
§ Off-site Contractor
· Using soil test results, manure test results, University recommendations, yield records, and nutrient application records, determine if application is within agronomic recommendations on all fields to be reviewed for RUSLE2 during the on-site process.
· Documentation will be on the Field Application of Nutrients Worksheet.
· From nutrient application dates provided by the client, determine if there were application dates on frozen ground. Be careful about geographic location!
· If the audit is finding a non-conformance for this piece of the Standard, be sure that the yield goal used is well documented, and that the specific state process for determining a “realistic yield goal” has been followed.
· Locate and provide State P-Index information (paper and electronic) in order for the on-site contractor to run the P-Index.
· Provide web link for NRCS setback and buffer requirements
o Field Application of Pesticides (Validus):
§ Completes a web check or phone call to see if there are any local regulations requiring application rates at less than label recommendations.
§ Complete a web check of labels for all pesticides identified by the client for the most recent year of each crop in the rotation, and complete the “label rate” column on the client Water Quality Record Collection Worksheet (This column is hidden when sent to the client)
§ During this web check, determine if there are any required setback areas for the pesticide.
o Treatment of Sensitive Areas (Validus):
§ Using aerial photography for all crop fields and adjacent land area:
· Identity and classify (stream, drainage ditch, pond, lake, classic gully head, wetland, well, sink hole, tile intake) potential sensitive areas
· Determine areas of overland flow
· Try to determine if a vegetative buffer is present on “overland” flow areas
· Document on the Sensitive Areas documentation sheet.
· IV. Plants:
o There is no off-site phase for this Resource concern
V. Wildlife:
o There is no off-site phase for this Resource concern.
VI . Energy:
o There is no off-site phase for this Resource concern.
VII. Irrigation Water
o There is no off-site phase for this Resource concern.
· Materials to be provided to the on-site contractor:
o Maps 1, 2, and 3 with map 1 having location information from the off-site process for ephemeral gullies and sensitive areas completed by Validus.
o Entity, Operating Unit, and Field Number information.
o County map with location of the operating unit
o 90 day action plan for non-conformances with current year actions to be audited “flagged”, and all Nutrient and Pest action items evaluated
o If the Team member has a contract through FamilyFarms identity preserved crop, a list of the items to be audited from each contract.
o Ephemeral Gully Erosion Treatment Worksheet completed by Validus.
o Wind Erosion Report Worksheet completed by the off-site contractor
§ If needed, location of wind erosion information from the off-site contractor
o Field Application of Nutrients Applied Worksheet:
§ Completed all but the P-Index for all fields selected for the on-site review as completed by the off-site contractor
Location of state P index and all required related information from the off-site contractor
o Water Quality data collection worksheet, or equivalent, provided by the team member and label rate amounts for pesticides completed by Validus
o Sensitive Area Worksheet completed by Validus
o Link to NRCS 590 Standard, including any University Publication referenced.
o If not in 590 Standard, the link to NRCS setback and buffer requirements,
o Link to County specific information for RUSLE2 and ACS requirements.
o Link to State P-Index
· On-site Portion of the Audit (Uses information provided from the off-site process, on-site data gathering, and on-site calculating)*:
· Call/email to schedule an appointment (two attempts per audit—document results. If no appointment after two attempts, notify Validus and provide documentation):
o Remind of purpose
o Remind of what operating units and fields will be reviewed
o Remind them that all materials needed to show that the standards are being met need to be available when you arrive—mailing to you later will not be accepted for an audit
· Conduct an opening session with the member to:
o Discuss purpose of the audit
o Review the Farm record system:
§ Assure that information sent for the off-site process on the Water Quality Record Collection Worksheets matches the information contained in the Farm Record system. If no off-site records were sent to Validus, gather them and complete the off-site process. Remember to turn in these extra hours on the invoice for the job.
§ Clarify any issues raised by the off-site process
§ Gather information required to complete RUSLE2 the Wind Erosion Equation (if applicable) and the P-Index, Plant, Wildlife, Energy, and Irrigation Water. If the necessary on-site records are not available at the time of the audit, find the item in non-compliance—do not wait while records are sought, and do not accept materials via the mail.
o Complete the appropriate columns in the Cropland Environmental Audit Tool
I. Action Plan
· Auditor reviews action plan(s) for non-conformance action items due this audit year.
a. For items with numerous checks required for an audit issue, the process is;
1. Review records (If no records, find in non-conformance)
2. If nothing applied, cease and find in non-conformance
3. If records indicate installation, select 10% for review
a. If found satisfactory in the fields, find in compliance
b. If not satisfactory in the field, select another 10% and proceed as above.
4. Remember that for 2.2 (ephemeral gullies), and 3.3 (treatment of Sensitive areas), a signed written statement from the local NRCS that there is no reasonable treatment in the FOTG is acceptable.
b. Complete section 1.4 of the audit tool as appropriate, including categorizing each non-completed item from an action plan ad “major” or “minor”.
II. Soil Quality:
§ For the RUSLE2 evaluation fields selected by Validus on each operating unit, “Walk the field”. For these fields, select the most critical area as if developing a conservation plan (the most erosive soil(s) that make up at least 10% of the field area)
§ Documentation of results for all fields will be:
· The RUSLE2 slope length and % slope measured and shown on aerial photograph map 1 plus a photograph (pinpointed using a GPS) to document the area(s), and a RUSLE2 Profile Erosion Calculation Record on fields selected by Validus.
· If a HEL field is not below “T”, evaluate whether it meets the ACS level requirements.
§ Document on the Soil Quality section of the Cropland Environmental Audit Tool. If the field exceeds the FamilyFarms Standard, be sure that the Team Members’ equipment and appropriate residue amounts (could mean a couple of measurements) appear on the RUSLE2 Report.
o For ephemeral gully erosion
§ Review off-site information and complete the Gully Erosion Treatment Worksheet for those sites in the same fields where RUSLE2 or Wind Erosion Equation was calculated.
§ Document any additional ephemeral gully control needs on the field—use GPS and map 1
§ Documentation will be the ephemeral Gully Erosion Treatment Worksheet and representative photographs of the treatment and/or treatment needs—pinpointed with the GPS and shown on map 1 as well as the Soil Quality section of the Cropland Environmental Audit Tool.
o If wind erosion was identified as an issue during the off-site process, determine from the RUSLE2 print out if at least 30% residue cover was present during the critical erosion period as defined by NRCS.
§ Documentation of results will be the Wind Erosion Worksheet and the Soil Quality section of the Cropland Environmental Audit Tool.
o For organic matter, use the SCI output from RUSLE2 Profile Erosion Calculation Record to determine SCI for each field and record in the Soil Quality section of the Cropland Environmental Audit Tool.
§ For HEL fields, the requirement is to meet the SCI level of the ACS requirement
NOTE: For evaluating FamilyFarms resource treatment requirements, if there has been a crop failure for the year being audited, it is to be treated as an anomaly. The auditor is to focus on the “normal” ongoing practices per the member’s records for the field(s) in question, rely on all information available including prior year aerial photography, and so note the year in question as an anomaly. An anomaly may include flooding, drought, hail, late frost, unusual rain prior to the audit, etc. and may apply to RUSLE 2, ephemeral gullies, nutrient application, etc. Likewise, sites in a field used as plots or demonstration areas with specific management requirements will not be subject to audit evaluation requirements.
Documentation:
· On audit tool
o Mark “yes or “no” as appropriate
o Place a note in the “notes” column to document the anomaly
· On Report
o On page 1, place a note in the “Meets Standard” column that an anomaly was used and explain
III. Water Quality:
o Using the “What Applied” and “Label Rate” columns on the client Water Quality Record Collection Worksheet for the same fields used in the RUSLE2 or WEE evaluation:
§ Assure information provided for the off-site assessment for “Field Application of Nutrients” is present in the farm record keeping system.
§ Compare pesticide application records and label requirements to data provided to Validus to assure the records reflect what was submitted.
§ If the audit is finding a non-conformance for this piece of the Standard, be sure that the yield goal used is well documented, and that the specific state process for determining a “realistic yield goal has been followed.