As the agricultural industry, and many other industries, look down the pipeline of regulations to come from the California Air Resources Board (CARB) it may be quite daunting. We have the Large Spark Ignition rule (aka Forklift Rule), Transportation Refrigeration Unit (TRU) rule in early rule making discussions, the Farm Equipment Rule (aka Tractor Rule) and the truck and bus rule which continually phases out older trucks. But this does not seem to be enough. This past week the CARB held a public workshop in Sacramento to begin discussions of seeking out additional pathways for freight facilities (airports, seaports, railyards, and warehouse/distribution centers) to further reduce emissions. While it was not specifically discussed, CARB staff were instructed at a March 2017 board meeting to return to the board with concepts for an indirect source rule. This simply cannot happen. Before we are able to see the reductions from the programs that are currently in place or being developed CARB is evaluating additional areas to regulate emission reductions. The California Cotton Ginners and Growers Association was represented by Director of Regulatory Affairs Jodi Raley at the workshop. Raley probed CARB staff on what the qualifications and criteria were being outlined to define a “warehouse and distribution center”. CARB currently is identifying nearly 50,000 facilities in the state that could fit this definition, it is the Association’s push to exclude agricultural facilities from this definition. CARB’s plan is to conduct yet another survey effort for any of the applicable facilities. Additionally, Raley made it clear to the staff that our Association remains opposed to applying additional regulations or mitigation measures before we even begin to see the reductions that industry is already having to comply with. Our Association was the only agricultural association to testify at this week’s meeting.