Our request relates to the…

Our request relates to the designation of Specialty Crops has been outlined and has been propagated through the past few iterations of the PPS.

Our ask is to include consideration in the newly proposed PPS (2023) to provide guidance to allow for a better understanding of how Specialty Crop lands are designated, specifically with how criteria is used to formulate the designation. Also, to provide an allowance to make changes to the designation should they be appropriate.

The description of our full comment is contained within the attached MS-Word document 'Consultation Comment for ERO 019-6813 Proposed PPS Update'. There are also (3) supporting documents attached.

In our opinion and in the judgement of the professional agrologists documented in the comprehensive supporting documentation attached, the current method (for selection of land designated as Specialty Crop) is vague and it appears that in some cases lands were improperly designated as Specialty Crop Lands.

We would like an update included in the PPS language to provide stronger guidelines that would provide tests and weighting factors for the defined criteria to allow for a clear and proper determination for Specialty Crop lands.