My suggestions for sustainability guidelines

As I warned yesterday, this post is long and boring, and it's only here to be on the record, Internet-wise.

I went through all 227 points covered by the California Sustainable Winegrowing Association's guidelines for certification.

I listed the name of each point, the CSWA's current requirement, requirement in future years (if any), and my suggestion for what SHOULD be the minimum standard.

In some cases, I have added a note, but this took a long, long time, and I'm getting paid for it exactly what the CSWA requires in 166 of the 227 categories -- "None." So in most cases I haven't written an explanation of my position, but would be glad to if you post a question in the comments.

Just a reminder:

Using the CSWA's own 227 points and descriptions, here's what I suggest is the minimum level necessary for certified sustainability:

Why bother with this?: 60
Level 1: 5
Level 2: 49
Level 3: 70
Level 4: 35
Higher than level 4: 8

The CSWA requires:
N/A: 32*
Level 1: 187
Level 2: 8
Level 3: 0
Level 4: 0
* includes 9 being rewritten for legal reasons

If you want to look at the program yourself, for some reason Blogger won't let me use a hotlink to a pdf document, but it's here: www.sustainablewinegrowing.org/docs/Certification%20Guidebook.pdf

Whew. I'm so glad to be done with beating up on this program. Time to move on.

And now, point-by-point.

3-1) Balanced Vines
Current requirement: 1
"None"
My suggestion: Why bother with this?

3-2) Shoot Density
Current requirement: N/A
My suggestion: Why bother with this?

3-3) Fruit Exposure
Current requirement: N/A
My suggestion: Why bother with this?

3-4) Crop-to-Pruning Weight Ratio
Current requirement: 1
"None"
My suggestion: Why bother with this?

3-5) Vineyard Design and Trellis
Current requirement: 1
"None"
My suggestion: Why bother with this?

3-6) Vineyard Uniformity
Current requirement: 1
"None"
My suggestion: Why bother with this?

3-7) Monitoring Canopy Microclimate
Current requirement: 1
"None"
My suggestion: Why bother with this?

3-8) Environmental Due Diligence for a New Vineyard Site
Current requirement: 1
"None"
My suggestion: 2
"Explanation of how and when environmental due diligence and research were carried out"

3-9) Soil Profile Inspection and Modification
Current requirement: 1
"Explanation of how soil profile was inspected and modified"
My suggestion: Why bother with this?
Note: All 4 categories say exactly the same thing

3-10) Soil Tested for Physical and Chemical Properties and Amended Pre-Planting
Current requirement: 1
"None"
My suggestion: 2
"Explanation of how soil properties were tested and amended"

3-11) Soil Sampled for Biological Problems Pre-Planting
Current requirement: 1
"None"
My suggestion: 3
"Explanation of how soil biology was tested"

3-12) Addressing Biological Problems
Current requirement: 1+ action plan; 2 in subsequent years
"Explanation of how biological problem was fumigated"
Note -- 2 is exactly the same as 1
My suggestion: 3
"Explanation of how biological problem was fumigated or solarized; and how roots were removed and field fallowed"
Note: Could argue for 4 "Explanation of how biological problem was addressed without fumigation; and how roots were removed and field fallowed"

3-13) Rootstocks
Current requirement: 1
"Explanation of rootstock selection approach"
Note: 1-3 are exactly the same; 4 is almost the same
My suggestion: Why bother with this?

3-14) Vineyard Layout
Current requirement: 1
"Explanation of vineyard layout approach"
Note: All 4 are exactly the same
My suggestion: Why bother with this?

3-15) Row and Vine Spacing
Current requirement: 1
"Explanation of row and vine spacing"
Note: All 4 are exactly the same
My suggestion: Why bother with this?

3-16) Scion/Cultivar
Current requirement: 2
"Explanation of scion/cultivar selection approach"
Note: 1-2 are the same; 3 is almost the same
My suggestion: Why bother with this?

3-17) Clone
Current requirement: 1
"Explanation of clone selection approach"
Note: 1-3 are the same; 4 is almost the same
My suggestion: Why bother with this?

3-18) Trellis & Vigor
Current requirement: 1
"Explanation of trellis selection approach"
Note: 1-4 are the same
My suggestion: Why bother with this?

3-19) Conservation of Habitat for Wildlife and Pest Natural Enemies
Current requirement: 1 + action plan; 2 in subsequent years
Note: 1-4 are the same
"Explanation of habitat conservation approach"
My suggestion: There is no level 5, but this point needs it

3-20) Creation of Habitat for Wildlife and Pest Natural Enemies
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of habitat creation approach"
My suggestion: 3
"Explanation of habitat creation approach, including listing of native species established"

4-1) Petiole Analysis
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: The analysis is required anyway in point 4-4, if you go category 2 or above, which I would

4-2) Soil Analysis
Current requirement: 1
"Explanation of how soil analysis is conducted"
My suggestion: 2
"Explanation of how soil analysis is conducted, with Record of soil analysis within last 7 years, or 5 years if amending soil."

4-3) Interpreting Results of Petiole and Soil Analyses
Current requirement: 1
"Explanation of how petiole and soil analyses are interpreted"
Note: 1-4 are the same
My suggestion: 1

4-4) Nutrient Management
Current requirement: 1
"Explanation of how nutrient management approach (no site-specificity)
My suggestion: 3
"Explanation of how nutrient management approach (based on detected deficiencies and vineyard observations/knowledge)

4-5) Nitrogen Management
Current requirement: 2
"Explanation of Nitrogen management approach, including frequency and timing of application"
Note: 1-4 are the same
My suggestion: 1

4-6) Amendments for Water Penetration
Current requirement: N/A
My suggestion: 3
"Explanation of water penetration issues, amendments and water pH testing"

4-7) Amendments for pH
Current requirement: N/A
My suggestion: 3
"Discussion of soil pH at vineyard. Explanation of soil amendments for pH adjustment"

4-8) Organic Matter
Current requirement: N/A
My suggestion: 1
"Explanation of organic matter management practices."

4-9) Soil Compaction
Current requirement: 1
"Explanation of soil compaction minimization practices"
My suggestion: 1

4-10) Knowledge of Soil Series, Water-Holding Capacity and Erosion Potential
Current requirement: 1 + action plan; 2 in subsequent years\
1: "None" 2: "Discussion on vineyard soil series"
My suggestion: 3
3"Discussion of vineyard soil series, waterholding capacity, and erosion potential"

4-11) Surface Water Diversions for Erodible Sites
Current requirement: 1 + action plan; 2 in subsequent years
1: "Discussion of erosion potential on site" 2: "Discussion of erosion potential on site. Explanation of all erosion control structures, systems and efforts on site."
Note: 2-4 are the same
My suggestion: Level 5 needed here
Erosion control needs to be effective. This doesn't require it.

4-12) Non-Point Source Pollution Prevention
Current requirement: 1
"None"
My suggestion: 4
"Visual record (photos), other visual record (map/layout), miscellaneous business record (receipt), analysis, internal testimonial, instruction (program documentation)"
Note: You gotta be kidding me. This is an important sustainability point, and the requirement is "None"?

4-13) Air Quality
Current requirement: N/A
Note: It says "Skip this point and complete Chapter 16 instead"
My suggestion: Why bother with this?

4-14) Cover Crops and Soil Quality
Current requirement: 1
"no cover crop planted or allowed to grow"
My suggestion: 2
"Annual resident (non-seeded) cover crop allowed to grow"
Note: Not "allowing" cover crops to grow means using herbicide, right?

4-15) Choice of Cover Crop
Current requirement: N/A
My suggestion: 3
Explanation of cover crop decision rationale (Site vigor and run-off concerns)

4-16) Erosion from Roads, Ditches, and Culverts
Current requirement: 2
"Explanation of road, ditch and culvert erosion control approach, including frequency of maintenance."
My suggestion: 4
Same as above, but includes "Comprehensive erosion control plan" and direct observation of "No signs of erosion related to roads, ditches and culverts."
Note: 2 is just talk. Only 4 is sustainable.

5-1) Water Management Strategy
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of water management strategy."
My suggestion: 4
"Explanation of water management strategy, including tools, information used and improvement plans."
Note: 2 is just talk. Only 4 is sustainable.

5-2) Monitoring and Amending Quality of Irrigation Water
Current requirement: 1 + action plan (no need to move higher)
1: "None" 2: "Record of water pH, salinity or total dissolved solids (electrical conductivity), and nitrate.
My suggestion: 2

5-3) Off-Site Water Movement
Current requirement: 1 + action plan (no need to move higher)
1: "None" 2: "Explanation of irrigation practices, rainfall events and associated runoff."
My suggestion: 4
"Explanation of irrigation practices, rainfall events, associated runoff, preventative techniques to reduce runoff, and methods to address soil permeability problems." Requires direct observation of "Drainage systems to manage high rainfall events."
Note: 2 is just talk

5-4) Irrigation System
Current requirement: N/A
Note 1-4 are the same, "Explanation of irrigation system"
My suggestion: Why bother with this?

5-5) Distribution Uniformity for Micro-Irrigation Systems
Current requirement: N/A
Note: 1-4 are the same, "Explanation of distribution uniformity approach, including frequency of testing."
My suggestion: Why bother with this?

5-6) Filters and Lines
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of filter and line maintenance approach, including frequency of once per Spring."
My suggestion: 2

5-7) Flow Meters
Current requirement: 1 + action plan (no need to move higher)
1: "None" 2: Direct observation of water flow meters.
My suggestion: 4. Includes "Record of flow meter readings."

5-8) Soil Water-Holding Capacity
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Description of soil water holding capacity and related management practices."
Note: 2-4 are the same
My suggestion: 2

5-9) Soil Moisture and Plant Water Status Monitoring Methods
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Description of process to monitor water status by visual tendril and shoot tip assessment," with "Squeeze test"
My suggestion: 3
Includes "Soil moisture reports and start dates for spring and summer irrigation," and "Indirect soil moisture monitoring devices in use"

5-10) Evapotranspiration
Current requirement: 1
"None"
My suggestion: Why bother with this? See 5-11

5-11) Water Budget
Current requirement: 1 + action plan; 2 in subsequent years
1: "Explanation of calendar based watering." 2: "Explanation of weather and plant appearance based watering."
My suggestion: 4
"Records of soil assessments, measured evapotranspiration, and plant moisture status." Includes "Irrigation logs based on soil assessments, ET measurements, and plant moisture status."

5-12) Planned Deficit Irrigation Through Regulated Deficit Irrigation or Partial Root Zone Drying
Current requirement: N/A
My suggestion: Why bother with this?

5-13) Fertigation
Current requirement: 2 + action plan; 3 in subsequent years
2: "Explanation of fertigation practices without checking soil nutrient or vine status." 3: "Analysis records, Internal testimonial, visual record (map/layout), other visual record (photos)."
My suggestion: 4+
4 is "Description of fertilizer application practices that are based on convenience," with "Soil and vine nutrient status reports" and "Back flow prevention device."
Note: I'm not sure fertigation -- which means dispensing fertilizer through an irrigation system -- should even be allowed at sustainable wineries. The mitigating factor is that it might lead to less runoff and wasteful use of fertilizer. But how much fertilizer should a sustainable winery use?

6-1) Vineyard Monitoring for Insects and Mite Pests
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of periodic insect and mite pest monitoring."
My suggestion: 4
"Explanation of weekly insect and mite pest monitoring" with "Electronic or written record of pest monitoring results" and "Documentation of how PCA uses pest monitoring in management decisions.

6-2) Economic Thresholds and Pest-Natural Enemy Ratios for Leafhoppers, Mites, and Thrips
Current requirement: 1 + action plan; 2 in subsequent years
1: "Description of calendar based pesticide spraying practices for leafhoppers, mites, and thrips." 2: "Description of pesticide spraying practices for leafhoppers, mite, and thrips based on the presence of pests in the vineyard."
My suggestion: 4+
"Description of economic threshold based pesticide spraying practices for leafhoppers, mites, and thrips. In addition, how control decisions are based on egg parasitism for leafhoppers." Includes "Calculations of egg parasitism levels for leafhoppers."
Note: This is still just talk, and it's the very heart of the idea of sustainability instead of organic or biodynamic. Growers should have to prove, with records, that they had a pest problem before spraying.

6-3) Use of Broad-Spectrum/Long-Residue Insecticides and Miticides
Current requirement: 1 + action plan; 2 in subsequent years
1: "Explanation of broad-spectrum insecticide/miticide application processes based on calendar cycle. In addition, a description of insecticide/miticide selection processes that do not consider impacts to non-target organisms."
2: "Explanation of broad-spectrum insecticide/miticide applications used at lower than labeled rates. In addition, a description of insecticide/miticide selection processes that do consider impacts to beneficial organisms."
My suggestion: A rewrite that's closest to 3.
3: "Explanation of how broad-spectrum insecticide/miticide applications are never used. In addition, a description of insecticide/miticide seletion processes that do consider impacts to beneficial organisms."
4: "Calculations of economic thresholds and cultural control levels to allow the vineyard not to use insecticides/miticides."
Note: 3 and 4 are oddly very different, with 4 actually easier than 3. But neither covers the most important point: "long-residue insecticides." I think sustainable wineries should NEVER use long-residue insecticides, but I don't know if every broad-spectrum insecticide is also long-residue.

6-4) Use of Reduced-Risk Insecticides and Miticides
Current requirement: 1 + action plan; 2 in subsequent years
1: "Explanation of processes that fail to use reduced‐risk insecticides/miticides for pest management." 2: Explanation of processes that use reduced‐risk insecticides/miticides for every other application."
My suggestion: 3, with a copy edit and documentation.
"Explanation of processes that use reduced‐risk insecticides/miticides
only when necessary."
Note: To me, this is the heart of sustainability vs. organics. Note that the requirement has the "only" in the wrong place; it should be before "reduced-risk." I wonder if that's accidental?

6-5) Cultural Practices for Insect and Mite Management
Current requirement: N/A
My suggestion: 3, or why bother with this?
3: "Description of leaf removal process to reduce leafhoppers and mites," with observation of vine vigor level.
Note: I don't know if leaf removal should be required as an insect-fighting technique, so maybe we're better off without this point.

6-6) Dust Abatement in and Around Vineyards for Mite Management
Current requirement: 1 + action plan; 2 in subsequent years
1: "No road signs or speed bumps in place to control vehicle speed on property." 2: "Road signs or speed bumps in place to control vehicle speed on property."
My suggestion: 2
Note: Just paint a sign that reads "Slow." How hard is that?

6-7) Use of Weather Data and Degree-Days for Managing Moth Pests
Current requirement: 1 + action plan; 2 in subsequent years
1: "Description of process that treats for moth pests only when it is convenient." 2: "Description of process that treats for moth pests based on time of year /vine development and past experience."
My suggestion: 3
It's 2 plus "Documentation of economic threshold use and infield monitoring."

6-8) Portion of Vineyard Treated for Mites or Leafhoppers
Current requirement: 1 + action plan; 2 in subsequent years
1: "Explanation of process that treats the entire vineyard when controlling mites or leafhoppers." 2: "Explanation of process that identifies pest hotspots only when a problem arises, and the process that treats the entire vineyard when controlling mites or leafhoppers."
My suggestion: 3
"Explanation of process that identifies hotspots and the pesticide application process to areas that are exceeding economic thresholds. In addition, description of the process that applies pesticides to extra buffer strips around the hotspots," with "Calculations that identify portions of the vineyard that exceed economic thresholds."
Note: I actually like this better than 4, which doesn't allow pesticides on buffer strips. If you're going to spray pesticides at all, you might as well use them in a way that will be effective.

6-9) Training of Employees
Current requirement: N/A
My suggestion: Why bother with this?
Note: Training employees to recognize insects is a good idea, but I don't think it needs to be mandatory.

6-10) Releasing Predatory Mites
Current requirement: N/A
My suggestion: Why bother with this?
Note: It's a good farming practice, but I don't think it needs to be mandatory.

6-11) Pseudococcus Mealybugs
Current requirement: N/A
My suggestion: Why bother with this?
Note: I don't see why these bugs deserve their own category.

6-12) Vineyard Monitoring for Disease
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of periodic vineyard disease monitoring process by PCA or manager."
My suggestion: 2

6-13) Powdery Mildew Management
Current requirement: 1
"Description of calendar based powdery mildew fungicides application process and rates at which fungicides are applied (always applied at highest rates for category 1). In addition, explanation of application process that fails to rotate different ‘modes of action’ within the season." Also, "Only sulfur products are used."
My suggestion: 3 with an edit
3: "Plan that uses cultural practices to limit powdery mildew development and improve application coverage," with "Description of process that determines applications based on weather applications. In addition, explanation of application process that rotates different ‘modes of action’ throughout the season," and "Only sulfur products are used."
Note: Other biodynamic mildew management products should be allowed.

6-14) Use of Reduced-Risk Fungicides for Powdery Mildew and Botrytis Control
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of process of rotation of reduced‐risk fungicides for powdery mildew and Botrytis control."
My suggestion: 2

6-15) Canker Management: A. Eutypa Dieback, B. Bot Canker
Current requirement: N/A
My suggestion: Why bother with this?

6-16) Botrytis Management
Current requirement: N/A
My suggestion: 3 plus documentation
"Explanation of application practices based on expected rainfall."

6-17) Identification of Causal Agent of Bunch Rot
Current requirement: 2 + action plan; 3 in subsequent years
2: "None" 3: "Report detailing lab results of Botrytis infection in bunch rot."
My suggestion: Why bother with this?
Note: What matters in sustainability is treatments -- fungicides. If they're used, then this point will fall under a different category anyway.

6-18) Pierce's Disease Management where Blue-Green Sharpshooter is Primary Vector
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Primary disease management plan that includes a component on insecticide applications for blue‐green sharpshooter."
My suggestion: 3
"Primary disease management plan that includes a component on disease detection and removal," with "Yellow sticky traps are used to monitor blue‐green sharpshooter populations in and along vineyards adjacent to riparian habitat," and "Discussion about auditee’s response to increases in traps counts for blue‐green sharpshooters."
Note: Pierce's Disease is probably the most serious threat to vineyards today, and if any threat calls for using non-organic pesticides, this is it.

6-19) Glassy-Winged Sharpshooter Monitoring
Current requirement: 1
"None"
My suggestion: 3
"GWSS traps placed every 20 acres," with "Employee training that informs them how to identify GWSS."
Note: Vineyard owners really need to cooperate on this because those that don't put their neighbors at risk.

6-20) Vineyard Monitoring for Weeds
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Discussion with auditee about weed monitoring," with "Log of written or electronic weed monitoring results."
My suggestion: Why bother with this?
Note: If you're not using herbicides, I don't care if you have weeds.

6-21) Weed Knowledge
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: Same as point 20

6-22) Herbicide Choice and Rate in Relation to Environmental Impacts
Current requirement: 1
"Receipts of purchased mixes of catch all herbicides to manage weeds in vineyard."
My suggestion: A completely new category, a little weaker than 4
Note: 1-3 require receipts for herbicides. 4 requires that no herbicides be used -- which is certainly acceptable as a standard. What I want to see is 1) no wide-spectrum herbicides, and 2) some process for justifying whether or not herbicide use can be permitted, and if so, what herbicide has the least environmental impact.

6-23) Herbicide Leaching Potential and Movement in Surface Water
Current requirement: 1 + action plan; 2 in subsequent years
1: "Receipts of purchased Simanize, diuron, norflurazon." 2: "Receipts of purchased Simanize, diuron, norflurazon, with "Discussion with auditee confirming that Simanize, diuron, norflurazon are used with discretion to locations of water tables."
My suggestion: 4
"Discussion with auditee confirming Simanize, diuron, norflurazon are not used."

6-24) Timing of Herbicide Treatments for Perennials
Current requirement: 2 + action plan; 3 in subsequent years
2: "Discussion with auditee about process to spray perennial weeds when they are big and full of seeds." 3: "Discussion with auditee about process to spray perennial weeds when they are big, but before they are full of seeds."
My suggestion: 4 with documentation
"Discussion with auditee about process to spray perennial weeds when they are most susceptible. In addition, if appropriate, mechanical weed management is utilized."

6-25) Area Treated with Herbicides
Current requirement: N/A
My suggestion: 4+
"A small, treated berm is maintained," with "Description of process to spot treat with foliar applied herbicides. In addition, auditee tolerates some weeds."
Note: There should be some justification process to see whether herbicides are really needed.

6-26) Vineyard Monitoring for Vertebrate Pests
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Quarterly monitoring of vertebrate pests."
My suggestion: 2

6-27) Vertebrate Pest Management
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Anticoagulant and/or strychnine baits to control vertebrate pests are used," or "Fumigants or explosive devices are used."
My suggestion: 4
"Discussion with auditee about non‐use of toxic bates," with "Problems for habitat modification are solved with eco‐management plan," and "Exclusion fencing is only directed at the target pest."
Note: I don't think strychnine can be part of a sustainable program.

6-28) Area of Vineyard Treated for Vertebrate Pests
Current requirement: 1 + action plan; no need to improve
1: "None"
My suggestion: Why bother with this?

6-29) Predation by Vertebrates
Current requirement: 1
"None"
My suggestion: 2
"Map detailing locations of owl boxes every 100 acres."
Note: Owl boxes are cheap.

6-30) Low-Volume Vine Canopy Sprayers
Current requirement: N/A
My suggestion: 4 with an edit
"Receipts for purchases of electrostatic or low volume sprayers."
Note: If you're going to spray pesticides and still be sustainable, you need to use the lowest-impact method. No penalty here for not spraying at all.

6-31) Sprayer Calibration and Maintenance
Current requirement: 1 + action plan; 2 in subsequent years
1: "Records of nozzle wear and variation checking at least every other year." 2: "Records of nozzle calibration at least every year. In addition, records of nozzle wear and variation checking at least every other year."
My suggestion: 4
"Records of nozzle calibration at throughout the season with water sensitive paper. In addition, records of nozzle wear and variation checking at least every other year," with "Receipt of purchased nozzles every year," and "Discussion with auditee about practice to check sprayer components yearly."
Note: See previous note.

6-32) Spray Coverage
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Discussion with auditee about the process to position nozzles."
My suggestion: 4
"Discussion about speed in which air blast sprayers drive. In addition, discussion with auditee about the process to position nozzles. Furthermore, discussion about maintaining tractor speed and spraying pressure before entering vineyard," with "Documents exhibiting verified spray coverage," and "Documentation of employee training on spray coverage."
Note: See note for point 30

6-33) Buffer Zone
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Discussion with auditee about establishing reasonable buffer zones near sensitive areas. ‐OR‐ Discussion with auditee about avoiding applications when wind is blowing towards sensitive areas."
My suggestion: 4
"Discussion with auditee about establishing reasonable buffer zones near sensitive areas. In addition, discussion with auditee about stopping applications when wind is blowing towards sensitive areas. Furthermore, applications are designed to ensure minimal human impact."
Note: See note point 30

6-34) Drift
Current requirement: 1
"Discussion with auditee about following legal requirements around pesticide application."
My suggestion: 4
"Discussion with auditee about avoiding pesticide applications when winds are less than 2 mph or more than 7 mph. In addition, a discussion with the auditee about practices to deliver largest droplets in uniform size," with "Sprayers and dusters are shut off at row ends near sensitive areas. In addition, low‐drift spray technology is used."
Note: See note point 30

6-35) Pesticide Storage
Current requirement: 1
"Discussion with auditee about following legal requirements around pesticide storage."
My suggestion: 2
"Discussion with auditee about pesticide storage in winter. In addition, discussion with auditee about safe pesticide storage practices."

6-36) Pesticide Mixing and Loading
Current requirement: 1
"Discussion with auditee about following legal requirements around providing PPE (personal protective equipment) to workers."
My suggestion: 3
"All workers are provided with PPE. In addition, double‐check valve is used when filling spray tanks or a six‐inch air gap is maintained between the spray tank and filling device. In addition, mixing/loading area is approximately 30 feet from the well to prevent contamination."

6-37) Pesticide Emergency Response Plan
Current requirement: 1
"None"
My suggestion: 4 (for vineyards that use pesticides)
"A pesticide emergency response plan is posted. In addition pesticide spill cleanup materials and first‐aid equipment are available," with "Documentation of employee training of emergency preparedness."

6-38) Restricted-Use Materials
Current requirement: 2
"Discussion with auditee confirming that category 1 pesticides are avoided."
My suggestion: 4
"Discussion with auditee confirming that category 1 pesticides are NEVER used."

7-1) Field Fruit Maturity
Current requirement: 1
"Description of how field fruit is considered mature (for category 1, this is when juice Brix reaches the level targeted for harvest)."
My suggestion: Why bother with this?
Note: This is a winemaking decision with no environmental consequences. Who does the CSWA think they are? What does this have to do with sustainability?

7-2) Tasting Grapes With Winery Representative of Winemaker
Current requirement: 1
"Confirmation from the winery that the winery representative or winemaker has not seen the vineyard since the contract was signed."
My suggestion: Why bother with this?
Note: Again, what does this have to do with sustainability?

7-3) Juice Chemistry
Current requirement: 1
"None"
My suggestion: Why bother with this?

7-4) Taste Wine Made from Your Grapes
Current requirement: 1
"Confirmation from the auditee about informal feedback from the winemaker about grape quality"
My suggestion: Why bother with this?

7-5) Knowledge of Wine Quality
Current requirement: 1
"Discussion with auditee about tasting local wines only."
My suggestion: Why bother with this? This isn't an MW.

7-6) Knowledge of Wine Industry
Current requirement: 1
"None"
My suggestion: Why bother with this? They'll find out; they have to. If they're more than 10 years old, they already know.

7-7) Viticultural Improvement
Current requirement: 1
"None"
My suggestion: Why bother with this? How do you define "improvement"?

7-8) Food Security: Planning, Monitoring, Goals and Results
Current requirement: 1 + action plan; no need to improve
1: "None"
My suggestion: 1

8-1) Defining the Resource Base to be Managed
Current requirement: 1
"Discussion with auditee to confirm their knowledge of physical boundaries of their property."
My suggestion: 4. This would seem to be the cornerstone of all ecological measures. How can you talk about specific measures if you don't know the general situation?
"Discussion with auditee to confirm their knowledge of physical boundaries and physical conditions of their property. Action Plan identifying the people within the organization and external to the organization that should be involved in ecosystem management. This plan should also identify available internal and external resources (financial, human, and equipment) that will be used to begin the initiative. Written description of the defined resource base and how it will be managed to continue the ecosystem initiative."

8-2) Developing a Sustainability Strategy in the Context of Ecosystem Management
Current requirement: 1 + action plan; no need to improve
"None"
My suggestion: 3 for first year; 4 for all subsequent years
3: "Policy statement: Documented sustainable business strategy that includes mission, vision, and values. Internal testimonial: Confirmation from auditee that this strategy has been shared with neighbors, community members, and others (external stakeholders). Confirmation from external stakeholders that this strategy has been shared with them (neighbors, community members, and others)."
4: "Policy statement: Documented sustainable business strategy that includes mission, vision, and values. Internal testimonial: Confirmation from auditee that this strategy has been shared with neighbors, community members, and others (external stakeholders). Confirmation from external stakeholders that this strategy has been shared with them (neighbors, community members, and others). Documented plan showing that the plan has been implemented for one year, and has been reviewed by management, staff, and other stakeholders."
Note: Isn't this the very core of sustainability? How can you get away with "None"?

8-3) Ecosystem Processes - Water Cycle
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Logs monitoring and measuring the amount of water that enters the auditee’s property from rainfall. In addition, logs documenting the amount of water the vineyard uses."
My suggestion: 4
"Logs: monitoring and measuring the amount of water that enters the auditee’s property from rainfall. In addition, logs documenting the amount of water the vineyard uses. Internal testimonial: Discussion with auditee about local groundwater and surface water resources in and around the vineyard or winery. Documented plan to optimize on‐site water resources by reducing run‐off, improving infiltration, increase soil holding capacity, and minimize offsite impacts. Direct observation: How operation utilizes water saving techniques."
Note: This is a key area, and doesn't cost money to follow. There's no reason to compromise here.

8-4) Ecosystem Processes - Nutrient or Mineral Cycles
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation from auditee about current efforts to develop a nutrient budget. Direct observation: Practices that involve composting, cover cropping, and using treated water to increase nutrient cycling."
My suggestion: 4
"Action plan: Comprehensive strategy that balances nutrient budgets and prevent offsite nutrient loss (this will include all of the following): Log: Documentation that monitors nutrient inputs and outputs for the nutrient budget. SOP instruction: Practices that involve composting, cover cropping, and using treated water to increase nutrient cycling as part of standard procedures. Direct observation: Practices that prevent the offsite loss of nutrients throughout the entire property (buffer strips, vegetation along roads and ditches, and engineered solutions to prevent erosion)."
Note: That word "offsite" means your neighbors. Only on 4 are you not allowed to damage their land. That's a requisite of sustainability.

8-5) Ecosystem Processes - Energy Flow
Current requirement: 1
"None"
My suggestion: Why bother with this? This isn't about power; it's new age "energy."

8-6) Ecosystem Processes - Community Dynamics
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Discussion with auditee about general community dynamics awareness. In addition, explanation about how auditee is working towards optimizing practices that take advantage of ecological services through community dynamics."
My suggestion: 2 + 3; they're completely different and equally necessary.
3: "Direct observation: Managing vineyard floor soil, fencing, and edges and buffer areas to optimize desired community ecological services. Log: Soil and pest management monitoring and recording."

8-7) Bioregions
Current requirement: 1
"Discussion with auditee about what bioregion the vineyard is in."
My suggestion: Why bother with this?

8-8) Watershed Management
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of the main watershed in which the vineyard/winery is located. Map of the watershed in which the vineyard is located."
My suggestion: 4
"Explanation of the main watershed in which the vineyard/winery is located. In addition, discussion with the auditee about where the main tributary connected to the vineyard/winery is located. Visual record: Map of the watershed in which the vineyard is located. In addition, a map of the main tributary connected to the vineyard/winery. Direct Observation: Cover cropping, buffer strips, and erosion control practices that preserve water and protect water quality. External testimonial: Confirmation of participating from water stewardship planning group."

8-9) Enhancing Habitat Through Vegetation Management in and Around the Vineyard
Current requirement: 1 + action plan; 2 in subsequent years
1: "Direct observation: vineyard is kept free and clean of any vegetation within and around its edges." 2: Direct observation: Cover crops are maintained appropriate to the vineyard site."
My suggestion: 2.

8-10) Habitat Enhancement - Nest Boxes for Wildlife that Prey on Vineyard Pests
Current requirement: 1
"None"
My suggestion: 2
"Direct observation: Nesting boxes for owls have been placed in and/or around the vineyard."

8-11) Habitat Enhancement - Nest Boxes for Birds other than Raptors and Provision of Plants for Food and Shelter
Current requirement: 1
"None"
My suggestion: Why bother with this? Many birds are pests for vineyards.

8-12) Ecosystem Management - Vernal Pools
Current requirement: N/A
My suggestion: 4, if applicable
"Direct observation: Vernal pools are preserved with adequate setbacks. In addition, buffer strips are present. Internal testimonial: Discussion with auditee about plant and animal diversity observations."

8-13) Ecosystem Management - Oak Woodlands
Current requirement: N/A
My suggestion: 4, if applicable
"Discussion with auditee about vineyard layout around oak tress, preventing their removal (farming is done under the canopy) ‐OR‐ Discussion with auditee about mitigation banking/other permanent mitigation of nearby oakland from previous tree removal. Confirmation from conservation groups about auditee’s participation in planning of oak woodland ecosystems in the region."

8-14) Ecosystem Management - Riparian Habitat
Current requirement: 1 + action plan; no need to improve
"Vineyard is planted up to the edge of the watercourse"
My suggestion: 3
"Banks of water courses have vegetated buffer strips adjacent to the water way."

8-15) Ecosystem Management - Aquatic Habitats: Streams, Rivers, and Wetlands
Current requirement: 1 + action plan; no need to improve
1: "Vineyard is planted up to the edge of the watercourse"
My suggestion: 3
"Banks of water courses have vegetated buffer strips adjacent to the water way."

8-16) Natural Resources Conservation Easements
Current requirement: 1
"None"
My suggestion: 2
"Explanation from auditee about awareness of conservation easements."

8-17) Agricultural Conservation Easements
Current requirement: 1
"None"
My suggestion: 2
"Explanation from auditee about awareness of conservation easements."

8-18) Use of Pesticides Toxic to Terrestrial and Aquatic Wildlife
Current requirement: 2
"Explanation from auditee about how pesticide toxicity is considered when choosing vineyard pesticides (must also discuss how auditee is considering timing applications to minimize impacts to wildlife."
My suggestion: 4
"Confirmation from auditee that pesticides toxic to wildlife are not used near habitats and nesting sites. In addition, confirmation from auditee that toxic pesticides are rarely or never used in vineyard operations."

8-19) Sensitive Species
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Discussion with auditee about general awareness of endangered species in the region."
My suggestion: 4
"Discussion with auditee about general awareness of endangered species in the region. In addition, confirmation with auditee about whether any of these endangered species occurs on the property. When applicable, Plan demonstrating how property is managed to protect/enhance habitat for endangered species.

8-20) Sensitive Species and Collaboration with Agencies
Current requirement: 1
"None"
My suggestion: if applicable, 3
"Confirmation from agency biologists about collaboration with auditee."

9-1) Energy Management: Planning, Monitoring, Goals and Results
Current requirement: 1 + action plan; no need to improve
"Explanation from auditee explaining general total energy use."
My suggestion: 4
"Plan to manage energy use (50% implemented). Action plan should include yearly goals for overall energy use, energy use per ton of grapes and/or gallon of wine produced, and energy use for gross sales based on baseline monitoring data. Logs of total energy use throughout the year."

9-2) Refrigeration System
Current requirement: 1
"None"
My suggestion: 3
"Documentation of a section in the energy conservation and monitoring plan that covers refrigeration efficiency. Miscellaneous business records: Receipts for technologies that improve refrigeration efficiency. Explanation from auditee about processes that reduce chiller loads.
‐OR‐
Direct observation: Energy efficient technologies used throughout the entire refrigeration system."

9-3) Tanks and Lines
Current requirement: 1
"None"
My suggestion: 3, without the insulated jacket requirement
"Tank cooling and heating energy use logs. Internal testimonial: Discussion with auditee about research to improve heating and cooling of tanks. Direct observation: 50% of tanks equipped with insulated jackets to reduce thermal stratification. In addition, glycol lines are insulated. Furthermore, 50% of tanks are strategically located to reduce energy (in the shade for cooling or sun for heating)."

9-4) Motors, Drives & Pumps
Current requirement: 1
"None"
My suggestion: 2 without the audit report
"Energy audit report conducted in the last three years that includes motors, drives, and pumps. Action plan: Document detailing how the operation supports efforts to improve the energy efficiency of motors, drives, and pumps. Log detailing when existing motors, drives, and pumps are maintained.

9-5) Heating, Ventilation and Air-Conditioning (HVAC)
Current requirement: 1
"None"
My suggestion: 3
"Documentation of a section in the energy conservation and monitoring plan that covers HVAC efficiency. HVAC maintenance log. Explanation from auditee about research of energy efficiency technologies to improve HVAC energy use.
‐OR‐
Direct observation: Energy efficient technologies are used throughout the all components of the operation that involve the HVAC system."

9-6) Lighting - Offices and Labs
Current requirement: 1
"None"
My suggestion: 3
"Documentation of a section in the energy conservation and monitoring plan that covers lighting efficiency. Explanation from auditee about research of energy efficiency technologies to improve lighting systems. Documentation that details how fixtures are included in cleaning procedures. Direct observation: Compact fluorescent lights are used in all areas of the operation. In addition, lighting is designed to illuminate only needed areas at the time. ‐OR‐
Direct observation: Energy efficient technologies are used throughout the all components of the operation that involve the lighting system.

9-7) Lighting - Shops and Facilities
Current requirement: 1
"None"
My suggestion: 3
"Documentation of a section in the energy conservation and monitoring plan that covers lighting efficiency. Explanation from auditee about research of energy efficiency technologies to improve lighting systems. In addition, discussion with auditee about consideration of sodium and/or sulfur lights for outdoor lighting. Documentation that details how fixtures are included in cleaning procedures. Direct observation: Mercury vapor lights are used in most areas of the operation. In addition, lighting is designed to illuminate only key security areas at all times and unnecessary lights are disconnected.

9-8) Lighting - Outdoor and Security
Current requirement: 1
"None"
My suggestion: 2
"Energy audit report conducted in the last three years that includes the lighting system. Document detailing how the operation supports efforts to improve the energy efficiency of the lighting system. Direct observation: Compact fluorescent lights are used in most areas of the operation.

9-9) Office Equipment
Current requirement: 1
"None"
My suggestion: 3
"Documentation of a section in the energy conservation and monitoring plan that covers office equipment. Internal testimony: Discussion with auditee about efforts to turn off office equipment when not in use. In addition, explanation from auditee about process to consider energy consumption when purchasing new office equipment. Furthermore, explanation from auditee about research of energy efficiency technologies to improve lighting systems."

9-10) Alternative Sources of Power
Current requirement: 1
"None"
My suggestion: 3
"Report from professional alternative energy firm addressing potential for PV and solar water heating systems. Financial plan addressing potential for solar projects. Internal testimonial: Discussion with auditee about site visits to other facilities implementing solar projects.
‐OR‐
Discussion with auditee about site visits to other facilities implementing wind, geothermal, fuel cells, etc."

9-11) Alternative Vineyard Fuels
Current requirement: 1
"None"
My suggestion: 2
"Log detailing the amount of fuel used in the vineyard. Discussion with auditee about researching alternative fuel sources."

10-1) Water Conservation Planning, Monitoring, Goals, and Results
Current requirement: 1 + action plan; no need to improve
"Discussion with auditee about estimated winery water use per year."
My suggestion: 2, though the audit could be older if it's not the first
"Records of a water audit performed in the last 2 years. Results from water audit are used in a plan to decide on maintenance, capital improvements, and employee training."

10-2) Water Quality Planning, Monitoring, Goals, and Results
Current requirement: 1 + action plan; no need to improve
"Discussion with auditee about potable water."
My suggestion: Why bother with this?
Note: It's a good-sounding category, but we're talking about wine coming into the winery, and the winery doesn't have control of that.

10-3) Wells
Current requirement: 1
"Discussion with auditee about potable water."
My suggestion: 3
"Direct observation: Meters are installed on wells. In addition, a separate meter for the winery is installed if wells are also used for irrigation and/or landscaping. Information from monitoring is used to calculate total water use per year. Log: Monitoring of water use throughout the year. Biannual reports of water quality used in winemaking operations."

10-4) Water to Wastewater Ponds
Current requirement: 1
"Direct observation: Flow meters are installed at ponds, but not monitored. pH testing documents. Explanation from auditee about where drains from the winery discharge. Visual record: Map identifying storm drains."
My suggestion: 3, though pH testing shouldn't have to be weekly
"Flow meters are installed at ponds, and monitored quarterly. Information from monitoring is used to track water quality and total use. Weekly pH testing documents. In addition, documentation from auditee about where drains from the winery discharge. Furthermore, sumps, interceptors, or traps are inspected annually. Map identifying storm drains."

10-5) Water from Wastewater Ponds
Current requirement: 1
"None"
My suggestion: 2
"Flow meters are installed and monitored. Internal testimonial: Explanation from auditee about discharging pond water. In addition, discussion with auditee about researching alternative disposal methods."

10-6) Septic Systems
Current requirement: N/A
My suggestion: 3, without the second option
"Records that detailing regular checking of the septic system. A grease trap is installed for restaurant and/or food service activities (if applicable). Maintenance and operation plan with an assigned staff person in place. Documented plan instructing management and staff about the “dos and don’ts” for septic tanks and leach fields. ‐OR‐ Direct observation: A second leach field is installed with a hand operated diversion valve."

10-7) Storm Water
Current requirement: 1
"Map identifying storm drains"
My suggestion: 2
"Explanation from auditee about storm water flows from uncovered pads into wastewater system. In addition, explanation from auditee about how processed wastewater network is subjected to minimal rainfall runoff. Map identifying storm drains. Direct observation: Diversion valves installed on critical storm drains. Documented section of water management plan that deals with storm water.

10-8) Crush Operations
Current requirement: 1
"A high volume nozzle with a shut off valve is used for cleaning equipment."
My suggestion: Why bother with this?

10-9) Press
Current requirement: 1
"A high volume nozzle with a shut off valve is used for cleaning equipment."
My suggestion: 2
"Discussion with auditee about estimated amounts of water used in tank and transfer lines. Water conservation plan that includes a section on tank cleaning. A high volume nozzle with a shut off valve is used for cleaning equipment. In addition, all wastewater goes to the drain. Report detailing research efforts to conserve water."

10-10) Fermentation Tanks
Current requirement: 1
"A high volume nozzle with a shut off valve is used for cleaning equipment."
My suggestion: 2
"Discussion with auditee about estimated amounts of water used in tank and transfer lines. Water conservation plan that includes a section on tank cleaning. A high volume nozzle with a shut off valve is used for cleaning equipment. In addition, all wastewater goes to the drain. Report detailing research efforts to conserve water."

10-11) Barrel Washing
Current requirement: 1
"Discussion with auditee about washing barrels with as much hot water as needed. A high volume nozzle with a shut off valve is used for cleaning equipment."
My suggestion: 2
"Discussion with auditee about washing barrels with hot water as needed. In addition, discussion with auditee about alternative sterilization technologies being investigated. A high volume nozzle with a shut off valve is used for cleaning equipment. Employees are trained in barrel cleaning procedures. The amount of water used is tracked as part of a water conservation program."

10-12) Barrel Soaking
Current requirement: 1
"Discussion with auditee about filling barrels. Only hot water is used in barrel washing."
My suggestion: 2 without the hot-water requirement
"Discussion with auditee about filling barrels. Direct observation: Only hot water is used in barrel washing. The amount of water used is tracked as part of a water conservation program."

10-13) Bottling
Current requirement: 1
"Discussion with auditee about water use when sterilizing fillers. A high volume nozzle with a shut off valve is used for cleaning equipment."
My suggestion: 3
"Discussion with auditee about water use when sterilizing fillers. In addition, discussion with auditee about visiting facilities implementing alternative cleaning and sterilization technologies. The amount of water used is accurately tracked as part of a water conservation program. A high volume nozzle with a shut off valve is used for cleaning equipment."
Note; You can put a lot of these categories together.

10-14) Cellars
Current requirement: 1
"A high volume nozzle with a shut off valve is used for cleaning floors."
My suggestion: Why bother with this?

10-15) Labs
Current requirement: 1
"None"
My suggestion: Why bother with this?

10-16) Landscaping
Current requirement: 1
"Discussion with auditee about hand watering landscaping with well or city water. Log detailing checks of irrigation lines."
My suggestion: 3
"Landscaping is irrigated using a drip system that is automated. This system should include moisture or rain sensors to automatically shut off. Log detailing quarterly checks of irrigation lines. Miscellaneous business records: Receipts of drought tolerant plants bought for landscaping (50% of property). Description of process to apply mulch or compost twice a year. The amount of water used for landscaping is part of a water conservation program.

11-1) Material Handling: Planning, Monitoring, Goals and Results
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Hazardous waste tracking logs. Discussion with auditee about process to establish hazardous waste goals for waste reduction. In addition, discussion with auditee about using regulatory issues for sources of information."
My suggestion: 3
"Hazardous waste tracking logs. Discussion with auditee about which departments use hazardous waste. Plan setting and monitoring yearly goals for hazardous waste reduction. Report detailing a less than 25% reduction in waste. Confirmation from local, state, and regulatory agencies about contact from auditee. P2 information is included in employee training."

11-2) Good Housekeeping - Dumpster Area
Current requirement: None (rewrite for legal issues)
My suggestion: 4
"Plan detailing a formal scheduling system for dumpster inspection. Log detailing regular inspection of dumpsters. Dumpsters are kept litter free. In addition, dumpster lids are closed to keep water out. Furthermore, bilingual signs are posted near dumpsters describing what materials can and cannot be dumped. Dumpsters are also placed on a cement pad to contain spills and placed in covered areas to keep water out. Employee training includes hazardous waste identification."

11-3) Hazardous Materials - Hazardous Material Storage
Current requirement: None (rewrite for legal issues)
My suggestion: 3
"Inventory kept of hazardous materials. Report detailing calculated reduction in hazardous materials use. Hazardous materials are stored away from drains. Receipts of material purchased to replace hazardous materials."

11-4) Hazardous Materials - Hazardous Waste Disposal
Current requirement: None (rewrite for legal issues)
My suggestion: 3
"Detailed log showing how much hazardous waste is generated. Should also include waste hauling manifest. Report detailing a calculated reduction in hazardous waste from per ton of grapes. Hazardous materials are stored away from drains. In addition, materials that generate hazardous waste are clearly identified. Furthermore, the hazardous waste storage area has double containment. Some hazardous waste is also stored separately to facilitate recycling. Employees are trained in hazardous waste handling and disposal."

11-5) Tires
Current requirement: 1
"None"
My suggestion: 3
"Receipts for purchased tires. In addition, invoices of tire disposals from a tire shop for trade in or recycling."

11-6) Batteries
Current requirement: None (rewrite for legal issues)
My suggestion: 2
"Receipts for purchased batteries. Inventory of devices that use batteries. In addition, an inventory noting what appliances use rechargeable batteries (must be 25%) All non‐rechargeable batteries are disposed in solid waste containers."

11-7) Lubricants, Oils, Coolants, and Solvents
Current requirement: None (rewrite for legal issues)
My suggestion: 3
"Detailed log showing how much hazardous waste is generated. Internal testimonial: Explanation form auditee about process to drain filters and containers before recycling. In addition, auditee should describe how old oil filters are used for scrap metal. Recycling invoice from a TSDF service company. Hazardous materials are stored in double containment. In addition, materials that generate hazardous waste are clearly identified. Furthermore, one recycled or refined product is used at the operation. Signs and posters about oil and lubricant disposal are posted. Employees are trained in hazardous waste handling and disposal."

11-8) Paint & Paint Thinners
Current requirement: None (rewrite for legal issues)
My suggestion: 2
"Detailed log showing how much hazardous waste is generated. Paints and thinners are stored in a centralized location. In addition, used paint containers and thinner are placed in a single container and disposed as hazardous waste. Discussion with auditee about methods to dispose of paints, thinners, paint waste. In addition, discussion with auditee describing process to settle pain solids. Receipts showing paints and thinners are purchased in minimum quantities. Employees are trained in hazardous waste handling and disposal."

11-9) Aerosol Cans
Current requirement: None (rewrite for legal issues)
My suggestion: 2
"Receipts for all aerosol cans used per year. Aerosol cans containing toxic or combustible substances are stored in a centralized location. In addition, aerosol cans containing toxic or combustible substances are separated for disposal in haz waste containers. Furthermore, other aerosol cans are disposed in solid waste containers."

11-10) Lighting
Current requirement: None (rewrite for legal issues)
My suggestion: 3
"Discussion with auditee about when ballasts were manufactured. Records from process to properly dispose of replaced ballasts by a licensed toxic waste company. In addition a Uniform Hazardous Waste Manifest has been completed to document a legal transfer of custody. Ballasts are identified by year manufactured."

11-11) Storm Water and Process Wastewater Protection
Current requirement: None (rewrite for legal issues)
My suggestion: 4
"Hazardous materials and waste are stored away from storm drains, and all storm drains are identified and labeled. Furthermore, major equipment and tools (excluding hand tools) are not cleaned outdoors or cleaning is done on a cement pad which drains to the wastewater pond. In addition, Diversion valves are installed in critical storm drains where there is significant risk of contamination to surface water. All liquid haz materials and waste are stored in secondary containment, inspected regularly, and documented. Monitoring of hazardous materials in secondary containment. Documented storm water pollution prevention plan is in place that includes training of management and staff."

11-12) Fuel Storage - Underground Storage Tanks (USTs)
Current requirement: 1
"Discussion with auditee about meeting legal requirements for UST's."
My suggestion: 3
"Locations of UST’s are shown on a map. In addition, locations of wells in relation to UST’s are shown on a map. Amount of fuel use is recorded and tracked in a log or tracking document. In addition, a checking log is kept of fuel area inspections. Spill clean up supplies are easily accessible. In addition, fueling area is cement‐ padded. Furthermore, signs about fueling safety procedures are posted. Documentation showing that employees are trained in spill prevention, control, and clean‐ up."

11-13) Fuel Storage - Aboveground Storage Tanks (ASTs)
Current requirement: 1
"Discussion with auditee about meeting legal requirements for AST’s."
My suggestion: 3
"Locations of AST’s are shown on a map. In addition, locations of wells in relation to UST’s are shown on a map. Amount of fuel use is recorded and tracked in a log or tracking document. In addition, a checking log is kept of fuel area inspections. Spill clean up supplies are easily accessible. In addition, fueling area is cement‐ padded. Furthermore, signs about fueling safety procedures are posted. Documentation showing that employees are trained in spill prevention, control, and clean‐ up."

11-14) Janitorial Supplies
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about considering janitorial suppliers toxic materials. In addition, discussion with auditee about reading product labels before products are purchased. MSDS sheets. Handling of janitorial supplies is documented as a part of employee training.
‐OR‐
Agreement with outside contractor to eliminate use of toxic janitorial supplies."

12-1) Solid Waste Reduction and Management: Planning, Monitoring, Goals and Results
Current requirement: 1 + action plan; no need to improve
"None"
My suggestion: 3
"Data showing that the winery has demonstrated a 25% reduction in solid waste. ‐OR‐ Yearly logs containing monitoring and recording of waste.
Documentation a plan to set goals to reduce solid waste. Documentation demonstrating that solid waste reduction information is part of employee training."

12-2) Pomace and Lees
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about the “medium value” of pomace and lees. Invoices from hauling of pomace and lees offsite. OR‐
Material is composted on‐site for direct application. Discussion with auditee about visiting facilities that have pomace and lee recycling technologies Detailed waste assessment to identify by products from pomace and lees."

12-3) Diatomaceous Earth
Current requirement: 1
"None"
My suggestion: 3
"Log showing the amount of DE used yearly. Discussion with auditee about researching alternative DE unloading and conveying. DE cakes are incorporated into compost operations. Travel records indicating that a facility extracting tartrate crystals from DE cakes has been visited."

12-4) Plate and Frame Filters
Current requirement: 1
"None"
My suggestion: 2
"Discussion with auditee about researching alternatives to plate and frame filter disposal. In addition, explanation from auditee about disposal of plate and frame filters in solid waste containers."

12-5) Cooperage
Current requirement: 1
"None"
My suggestion: Why bother with this?

12-6) Glass
Current requirement: 1
"None"
My suggestion: 2
"Broken glass is separated into recyclable glass and non‐recyclable lab glass (Pyrex). In addition, non‐recyclable lab glass is disposed in a solid waste container."
Note: 4 requires "Savings from reduced bottling waste are used to fund employee gardens, parties, and special events." Employee parties, a key facet of sustainability? Pass the lampshade.

12-7) Cardboard
Current requirement: 1
"None"
My suggestion: 2
"Cardboard is recycled in a designated recycling container. Calculation of the total amount of recycled cardboard in the winery."

12-8) Paper
Current requirement: 1
"None"
My suggestion: 2
"Paper is recycled in a designated recycling container. Calculation of the total amount of recycled paper in the winery."

12-9) Shrink Wrap and Plastic
Current requirement: 1
"None"
My suggestion: 3
"Documentation indicating that management and staff are trained on plastic identification codes. Plastic is recycled in designated recycling containers. Log detailing the amount of plastic recycled. Discussion with auditee about knowledge of major sources of plastic that come to the winery. In addition, discussion with auditee about investigating vendors that specialize in plastic recycling."

12-10) Packaging
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about testing alternative packaging materials. In addition, auditee is knowledgeable of source of packaging. Furthermore, discussion with auditee about investigating vendors that specialize in packaging recycling. Discussion with management and staff to test knowledge of packaging identification codes. Packaging is recycled in designated recycling containers. Log detailing the amount of recycled packaging used."

12-11) Metals
Current requirement: 1
"None"
My suggestion: 3
"Metals are separated into recyclable aluminum, steel drums*, and scrap metal. Recycling containers are placed close to points of material generation and discard for ease of recycling. In addition, only small pieces of scrap metal are disposed in solid waste containers. Employee training includes information on metals recycling"

12-12) Natural Cork
Current requirement: 1
"None"
My suggestion: 2
"Cork is separated out of the solid waste stream. Containers are made available in tasting room and bottling rooms to recycle corks. In addition, very little cork is disposed in solid waste containers. Discussion with auditee about investigated alternatives to cork disposal."

12-13) Pallets, Wood Packaging, Bins, etc.
Current requirement: 1
"None"
My suggestion: 2
"Unused pallets are stacked and stored for vendor pickup. In addition, remaining broken pallets are disposed in solid waste containers or recycled locally. Broken pallets are repaired and re‐used when possible."

12-14) Capsules
Current requirement: 1
"None"
My suggestion: Why bother with this?

12-15) Landscape Residuals
Current requirement: 1
"None"
My suggestion: 2, which is more strict than needed, but better than "none"
"Internal testimonial, visual record (photo), external testimonial, miscellaneous business record (receipt)"

12-16) Food and Beverages
Current requirement: N/A
My suggestion: Why bother with this?

13-1) Environmentally Preferred Purchasing: Planning, Monitoring, Goals and Results
Current requirement: 1
"None"
My suggestion: 3
"Internal testimonial: about purchasing decisions and research into alternative materials. In addition, auditee is researching alternative materials and products. Supplier assessments. Log detailing how many recycled products are used. Written purchasing policy. Action plan: Goals are established to increase EPP material purchasing."

13-2) Service Contracts
Current requirement: N/A
My suggestion: 3
"Internal testimonial: How service contracts are awarded. Policy: Standards for service providers."

13-3) Paper
Current requirement: 1
"None"
My suggestion: 2
"Discussion with auditee about how paper vendors are selected, and what environmental requirements should be met."

13-4) Packaging - From Suppliers
Current requirement: 1
"None"
My suggestion: 2
"Discussion with auditee about considering how much packaging is used in purchasing decisions. In addition, discussion with auditee about the questions asked to major packaging suppliers. Purchasing agreement with packaging supplier that includes some environmental requirements. Documentation of the total amount of packaging used in the waste stream."

13-5) Packaging - To Customers
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how packaging material suppliers are considered. In addition, discussion with auditee about the questions asked to major packaging suppliers. Furthermore, discussion with auditee about occasional reuse of packaging. Purchasing agreement with packaging supplier that includes environmental requirements they must meet."

13-6) Cleaning Supplies
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how cleaning material suppliers are considered. In addition, discussion with auditee about the questions asked to cleaning material vendors. Purchasing agreement with cleaning material suppliers that includes environmental requirements they must meet."

13-7) Plant Equipment
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how plant equipment suppliers are considered. In addition, discussion with auditee about the questions asked to plant equipment vendors. Purchasing agreement with plant equipment suppliers that include environmental requirements they must meet."

13-8) Boxes
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how box suppliers are considered. In addition, discussion with auditee about the questions asked to box suppliers. Purchasing agreement with box suppliers that include environmental requirements they must meet."

13-9) Glass
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how glass suppliers are considered. In addition, discussion with auditee about the questions asked to glass suppliers. Purchasing agreement with glass suppliers that include environmental requirements they must meet."

13-10) Capsules
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how capsule suppliers are considered. In addition, discussion with auditee about the questions asked to capsule suppliers. Purchasing agreement with capsule suppliers that include environmental requirements they must meet."

13-11) Corks
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how cork suppliers are considered. In addition, discussion with auditee about the questions asked to cork suppliers. Purchasing agreement with cork suppliers that include environmental requirements they must meet."

13-12) Office Equipment
Current requirement: 1
"None"
My suggestion: 3
Discussion with auditee about how office equipment suppliers are considered. In addition, discussion with auditee about the questions asked to office equipment suppliers. Purchasing agreement with office equipment suppliers that include environmental requirements they must meet."

13-13) Vehicle Maintenance Products
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how vehicle maintenance product suppliers are considered. In addition, discussion with auditee about the questions asked to vehicle maintenance product suppliers. Purchasing agreement with vehicle maintenance product suppliers that include environmental requirements they must meet."

13-14) Vehicles
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: The truck itself is way more important than the vendor.

13-15) Vineyard Supplies
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee about how vineyard supply vendors are considered. In addition, discussion with auditee about the questions asked to vineyard supply vendors. Purchasing agreement with vineyard supply vendors that include environmental requirements they must meet."

14-1) Human Resources: Sustainability Mission, Vision and Values
Current requirement: 1 + action plan; no need to improve
"None"
My suggestion: 2
"Document that describes mission statement including sustainability elements. Discussion with auditee about plans to add vision and values statements that focus on sustainability."

14-2) Human Resources: Planning, Monitoring, Goals, and Results
Current requirement: 1
"None"
My suggestion: 3
"Discussion with auditee/management about how management is aware of major human resources (HR) components. Action plan: Demonstrating how management has developed a comprehensive HR plan (which is currently being implemented) that includes staffing and recruitment, training and development, employee relations, compensation and benefits, and recordkeeping and legal. In addition, sustainability policies and practices are integrated throughout the HR plan. And also the plan includes HR goals (e.g., percent employees retained, training completed, contributions to implementing sustainable practices)."

14-3) Staffing and Recruiting Strategy
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-4) Standard Interviewing Format
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: Are we talking about Microsoft or vineyards?

14-5) Standard Job Descriptions
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-6) Employee Orientation
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-7) Safety Training
Current requirement: 1
"None"
My suggestion: 4
"Log: Employee safety and training meetings; safety audits and investigations; safety statistics. Job Safety Hazard Analysis (JSHA) for each key job/operation"
Note: Winemaking has dangers from rattlesnakes to CO2 poisoning. This category needs to be taken far more seriously.

14-8) Professional Training and Development
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-9) Staying Informed with Industry
Current requirement: 1
"None"
My suggestion: 2
"Explanation of participation. Subscription invoices, event documentation"

14-10) Industry Participation
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-11) Teambuilding for Sustainability
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: See me, touch me, feel me, eat me.

14-12) Employee Handbook
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-13) Employee Meetings
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: Just what we all need - more meetings.

14-14) Sustainability in Employee Performance, Grievance, Satisfaction and Recognition Practices
Current requirement: 1
"None"
My suggestion: 2
"Explanation of sustainability performance/recognition"

14-15) Salary Survey Participation
Current requirement: 1
"None"
My suggestion: Why bother with this?

14-16) Sustainability Bonus System
Current requirement: 1
"None"
My suggestion: Why bother with this?

15-1) Neighbors and Community: Planning, Monitoring, Goals and Results
Current requirement: 1 + action plan; 2 in subsequent years
1: "None" 2: "Explanation of neighbor/community issue pro‐activeness"
My suggestion: 2

15-2) Sustainability Values Statement
Current requirement: 1 + action plan; no need to improve
"None"
My suggestion: 2
"Explanation of sustainability values communication/statement"

15-3) Community Housing
Current requirement: 1
"None"
My suggestion: 2
"Explanation of community housing awareness"
Note: Huge issue in Napa Valley; not as much elsewhere

15-4) Transportation and Traffic
Current requirement: 1
"None"
My suggestion: 2
"Explanation of awareness of issues"

15-5) Community Educational Issues
Current requirement: 1
"None"
My suggestion: Why bother with this?

15-6) Community Health Care Issues
Current requirement: 1
"None"
My suggestion: 2
"Explanation of awareness of issues"
Note: A little touchy-feely, but a winery should at least know where the good emergency rooms are.

15-7) Community Water Quality and Supply
Current requirement: 1
"None"
My suggestion: 4
"Explanation of awareness of issues and participation in forums, re‐use programs, tours/examples. Miscellaneous business record: (program/forum/meeting documentation), employee testimonial"

15-8) Smart Growth
Current requirement: 1
"None"
My suggestion: 2
"Explanation of awareness of issues"
Note: This isn't enough for wineries that are expanding. Building should have its own section, but doesn't.

15-9) Agriculture and Winery Chemicals
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness of issues and forum participation. Published materials: awareness materials"

15-10) Community Noise Concerns
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness of issues and forum participation. Published materials: awareness materials. External testimonial: positive neighbor interactions"

15-11) Erosion Control
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness of issues and forum participation. Published materials: awareness materials and examples"

15-12) Air Quality
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness of issues and forum participation. Published materials: awareness materials and examples"

15-13) Visual Impacts
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness of issues, forum participation, and monitoring development/expansion plans. Published materials: awareness materials and examples"

15-14) Outreach and Communication with Neighbors, Community Members, and Other Stakeholders
Current requirement: 1
"None"
My suggestion: 2
"Explanation of awareness of issues and communication style"

16-1) Air Quality: Planning, Monitoring, Goals and Results
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness and strategy. Training documentation Action plan: goals, protection, estimated emission sources, strategy."

16-2) Vineyard Floors
Current requirement: 1
"None"
My suggestion: 2
"Explanation of awareness. Soil conservation plan documentation"

16-3) Unpaved Surfaces - Roadways and Traffic and Equipment Staging Areas
Current requirement: 1
"None"
My suggestion: 2
"Explanation of awareness and strategy. Soil conservation plan documentation"

16-4) Irrigation
Current requirement: 1
"None"
My suggestion: 4
"Explanation of awareness and strategy. Emission reduction plan documentation. Water use receipt. Visual record: improved irrigation equipment"

16-5) Pest Management Strategy
Current requirement: 1
"None"
My suggestion: 3
"Explanation of awareness and strategy Action plan: emission, fuel, pesticide reduction plan"

16-6) Pesticide Stewardship
Current requirement: 1
"None"
My suggestion: Something better than listed here
Note: What's needed is a commitment to NOT USE pesticides unless absolutely necessary. That's not an option here. 2-4 are almost the same, though 4 also calls for "Pesticide application training.

16-7) Agricultural and Winery Chemicals and Materials
Current requirement: 1
"None"
My suggestion: Something better than listed here
Note: It's the same as with pesticides. There needs to be an acknowledgement of using the lowest-impact chemicals whenever possible, but that's not one of the choices.

16-8) Energy Sources and Efficiency
Current requirement: 1
"None"
My suggestion: 4
"Awareness Analysis: Equipment efficiencies Log: fuel usage and emissions. Energy reduction plan Direct observation: Retrofits and renewable energy system"

16-9) Transportation
Current requirement: 1
"None"
My suggestion: Why bother with this?
Note: You can't call for forum participation and industry awareness and visits to green suppliers, and then turn around and demand a travel reduction plan. Something has to give, and it's this.

16-10) Agricultural Burning
Current requirement: 1
"None"
My suggestion: 4
"Burn practices and outreach/educational activities. Miscellaneous business record: Burn/prune work order. Training documentation"