[Education] CCGA Signatory on AUA

[Lorraine Kells]

Hello all,

This is just to inform you all that without your objections CCGA will sign
on to a letter drafted by AUA below.  The communications team hopes there
will only be affirmation to our signing on and that you will each
personally sign on when we send you the link in our upcoming newsletter.

Here is the letter:

In recent years, the City of Chicago has recognized the positive
contributions of urban agriculture, including job creation, healthy food
access, green space beautification, and environmental benefits. As a result
of the COVID-19 pandemic, food supply chains have been heavily disrupted,
highlighting the growing importance of urban farms and gardens as essential
operations that combat health inequity, strengthen our local food system,
and foster more resilient communities. To keep urban agriculture and the
local food system thriving in Chicago, access to affordable water is
critical.

Despite these realities, Chicago’s growers continue to face a series of
financial and legal barriers preventing them from accessing the water
needed to grow food for their communities. Most growing operations do not
have the land security or capital to install a permanent water line, which
can cost as much as $40,000. Due to the cost prohibitive nature of this
option, the majority of farms and gardens access water through a City of
Chicago hydrant. In February, the Department of Water Management (DWM)
released an updated hydrant permit policy
<https://auachicago.org/wp-content/uploads/2020/04/Copy-of-DWM-Memo-2_1_20.pdf>,
which made it harder than ever for growers to access water and produce
fresh, healthy food for their communities.

The impact of this policy has been stark in Black and Brown communities,
who are already experiencing higher rates of hunger and consequential
health disparities. This type of health inequity caused by food insecurity
exacerbates underlying chronic conditions and leads to higher rates of
COVID-19.  Black and Brown people are now forced to bear the weight of this
expensive and cumbersome water policy.

In response to these issues, AUA has worked in coalition with farmers,
gardeners, and food system partners to advocate for a set of immediate and
long term solutions aimed at reducing the cost of and increasing access to
water for Chicago’s growers. After months of communication with the Mayor’s
Office, Department of Water Management, Department of Planning and
Development, and the Department of Legal Services, the City of Chicago has
implemented a new temporary hydrant permit policy
<https://auachicago.org/wp-content/uploads/2020/06/HYDRANT-POLICY-final-to-NeighborSpace-and-AUA-Chicago-group-060520-2.pdf>
for
the remainder of the 2020 growing season.  Check out AUA's Grower's Guide
<https://auachicago.org/wp-content/uploads/2020/07/AUA-Updated-Chicago-Growers-Guide-.pdf>
for
more information on navigating the new policy.

The updated water policy:

   - Establishes a new rate of $117.81/year that is applicable to both
   farms and gardens. That rate is applicable to operations under 3,000 square
   feet. It is an added $50.68 for each additional 3,000 square feet
   - Prohibits the use of vacuum breakers and requires the use of a Reduced
   Pressure Zone (RPZ) unit as a water backflow prevention device. This device
   must be re-certified annually.
   - Removes the requirement that a farm or garden must be a nonprofit
   organization.
   - Aligns the City’s zoning and water policies — community gardens can be
   as large as 25,000 square feet and can make ‘incidental sales.’

The updated water policy does not:

   - Recognize that the new application process puts additional financial
   and administrative burdens on farms/gardens — Temporary Hydrant Use
   Agreement, legal fees, insurance requirements, and a complex application
   system.
   - Provide any support for the costs associated with RPZ acquisition,
   installation, and certification, or the acquisition of hydrant fittings and
   keys. The average cost of this is around $1800.
   - Acknowledge that several large gardens and farms normally use a 2" RPZ
   valve to ensure adequate water pressure. The new policy only allows for the
   use of a ¾” RPZ valve.

Moving forward, we propose the following solutions to ensure a more
equitable water policy in 2020 and beyond:

   - Immediately approve existing permit applications that meet City
   requirements.
   - Create a clear and streamlined application process for accessing a
   hydrant permit.
   - Determine the annual water rate based on square footage under
   cultivation, not total square footage of the farm/garden.
   - No longer require the use of the Temporary Hydrant Agreement- a newly
   required legal contract between the landowner, farm/garden and City of
   Chicago.
   - Enable the Department of Water Management to provide growers with
   hydrant equipment — RPZ units, hydrant fittings, and keys
   - Allow for the use of larger RPZ units to ensure adequate water
   pressure for larger farms/gardens.
   - Apply rules equitably to all organizations regardless of land
   ownership.

We, the undersigned urban farmers, community gardeners, workforce
development programs, local food and health equity advocates, community
organizations, emergency food responders and Chicago residents strongly
support these solutions as a means to provide Chicago food producers with
access to affordable water. This will ensure, both now and in the future,
that these essential operations can continue to grow healthy, nutritious
food for their communities and collectively contribute to the sustainable
development of Chicago.

Sincerely,

Advocates for Urban Agriculture
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