Irapuato Water Stewardship Assessment

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1 2012 Irapuato Water Stewardship Assessment Prepared for General Mills Inc. By The Nature Conservancy 12/14/2012 0

2 TABLE OF CONTENTS Executive Summary.2 General Mills Water Sustainability 4 Setting the Stage 5 Water Resource Challenges and Risks in the Region.7 Water Sustainability at General Mills Irapuato.17 Creating a Water Stewardship Plan 24 Conclusions.33 References..34 FIGURES AND TABLES Figure 1. Map of Lerma-Chapala Basin 6 Figure 2. Number of wells in Guanajuato over time.8 Figure 3. Population versus relative water availability in Guanajuato.9 Figure 4. Water use by General Mills in the Irapuato area.18 Figure 5. Example of a water a stewardship strategy 27 Table 1. Area of irrigated agriculture in the Lerma-Chapala Basin..7 Table 2. Average Annual Decline of Water Levels in Guanajuato Aquifers.10 Table 3. General Mills water supply wells.19 Table 4. Potential Water Stewardship Activities..25 1

3 Executive Summary Water is a critical component of General Mills value chain in central Mexico. Without a sufficient supply, Green Giant and Old El Paso production in Irapuato would cease to exist. Unfortunately, there exists a real water scarcity risk in the region which must be taken seriously and addressed before serious long-term consequences occur. The water scarcity risk is threefold: 1. The levels in the aquifers on which General Mills and the community relies are being depleted faster than they can be replenished. We estimate an annual deficit of approximately 255 million cubic meters in the aquifer on which the General Mills facilities rely, and believe many of the aquifers will reach unacceptably low levels within the next several decades. 2. The surface water situation is similar. Water consumption in the Lerma-Chapala River Basin exceeds replenishment in all but the wettest years and estimates suggest that on average, the deficit between water demand and water availability is between 1.6 and 1.8 billion cubic meters per year. In addition, most of the region s waste water is untreated, resulting in 52% of the surface waters considered highly contaminated and only 9% of acceptable water quality. 3. Future pressure will come from growth and climate change. Agriculture currently accounts for 84% of water use in the Guanajuato portion of the Basin and is expected to grow by 5 10% by At the same time, average annual temperatures are expected to increase and precipitation is expected to decrease by 5 10% from normal levels. Investments in water conservation and attempts to regulate pumping in the region have met with some success, but a much greater effort is required to bring the growing region to sustainable water use. General Mills has taken the initiative to reduce water use at their facilities through water efficiency improvements and water reuse, and in the field through a drip irrigation program. The company also invests in a tree planting program and is exploring a variety of other conservation strategies with the potential to expand to area growers. General Mills now has the opportunity to create greater impact by leading water stewardship planning throughout the region and encouraging other large water users to take action. In particular we see two key opportunities: Water Conservation: General Mills successful drip irrigation program should be expanded. Currently 40% of General Mills growers employ drip irrigation saving water and improving productivity. The successful interest-free financing program should be 2

4 expanded to include a significant majority of General Mills growers. And, since only 3-5% of total growers use drip irrigation, a similar program should be developed and expanded throughout the region. The company (and community) should continue to explore other water conservation techniques, but we believe the expansion of improved irrigation technologies offers the greatest immediate water conservation opportunity. Governance: General Mills and other large water users should encourage the efforts of state and federal agencies in regulating well expansion and water use. Ultimately, effective monitoring and enforcement will be key to protecting the region s freshwater resources for future generations. Through its leadership, and with on the ground experience that demonstrates success, General Mills can convene a new effort to move the region towards sustainable water use. The longterm success of the company, and all other large water users in the region, depends on making it happen. 3

5 General Mills Water Sustainability: Irapuato Pilot Site The Nature Conservancy (TNC) and General Mills (GMI) began working together in January 2012 to better understand the condition of the freshwater resources the company depends on for its operations and major growing regions and to develop a plan of action to improve the sustainability of water use throughout the General Mills value chain. Growing pressures on water supplies are posing dynamic risks for global operations and supply chains; the commitment by General Mills to take action now to address water issues and prepare forecasts of future challenges demonstrates the company s high level of commitment to sustainable water use. Assessment of water use impacts and water-related risk is critical for any corporation that relies on water to operate. Water-related risk comes in many different forms, but corporations that use water face two primary types of risk: - Risk of insufficient clean water to operate - Risk of losing a license to operate due to regulatory actions or negative public opinion about a facility s perceived or actual detrimental impact on the water system As water demands continue to rise within watersheds and aquifers, business risks associated with water can be expected to increase. By assessing water-related impacts and associated risks now, General Mills can stay ahead of potential problems and address them before they become a limiting factor in their operations. The Nature Conservancy is committed to finding solutions that will ensure that there is a sustainable source of water for both nature and people. Helping corporations such as General Mills reduce their water-related risk through improved water use and watershed-based restoration activities is an essential step towards sustainable use of our water resources. The objectives of the this joint initiative are 1) to understand the condition of the freshwater resources the company depends on for its major plants and in its most important growing regions around the world, and 2) to take appropriate action where needed to improve the health of watersheds found to be at risk. The general approach of this initiative is as follows: Provide a preliminary assessment of all watersheds that the company depends on for a) its operations and b) major growing regions. Analyze identified high risk watersheds more deeply. Develop appropriate mitigation strategies for each high risk watershed. Lead by convening large water users in high risk watersheds to take conservation action. As part of this initiative Irapuato, Mexico was selected as a pilot site where a deep dive assessment would be applied and a local water stewardship plan could be developed. The pilot 4

6 site would provide an opportunity for working through the process of assessment and local strategy development, and serve as an example for subsequent General Mills deep-dive sites. Irapuato was selected in part due to its importance as a production site for Green Giant products and the direct connection between the production site and contract growers in the region from which the plant receives agricultural products. The site was also selected due to potential water scarcity issues and the existing sustainability initiatives that the local General Mills employees have undertaken. This report provides an overview of the water resource challenges that General Mills production and supply chain face in the Irapuato area and describes proposed strategies to address these challenges. The report begins with background information on the area, with a focus on General Mills and their presence in Irapuato. The challenges of water management are discussed, including the outlook for the future. The report continues with a description of current General Mills water sustainability efforts, including a rough estimate of the benefits of these efforts. Finally, a local water stewardship plan is presented, including on the ground activities, engagement of other water users, and how General Mills can magnify its water stewardship actions to expand its impact. Setting the Stage Irapuato is a city of approximately 5.5 million people located in the central Mexico state of Guanajuato. Green Giant has operated in Irapuato since 1983, with Old El Paso initiating operations on the same property in Green Giant processes broccoli, cauliflower, carrots, celery, bell peppers, asparagus and brussel sprouts by cleaning, cutting, cooking, freezing and packaging for international markets. Old El Paso makes a variety of food products such as salsa, taco shells and seasonings for foreign markets. Green Giant contracts out to dozens of farmers for the vegetables that it processes at the plant. The relationship with the contract farmers includes providing farmers with vegetable starts, working with the farmers to improve efficiency and quality of the crops, and buying the crops directly from the farmers. General Mills and its growers rely on groundwater wells to provide water for the operations of its plants and for irrigation of the vegetable crops. The growers that Green Giant contracts with are located around Irapuato in the greater Bajío growing region, which stretches across much of Guanajuato, and includes small pieces of the neighboring states of Michoacán and Querétaro. El Bajío is a key agricultural and industrial hub in Mexico and one of the fastest growing areas in the country. Its central location, with easy transportation access to both coasts, north to the U.S. and south to Central America, healthy soils and year-round growing climate make it a very attractive location for national and international investment. El Bajío boasts more than 400,000 hectares of prime quality, irrigated agricultural land that produces a wide variety of agricultural products, including grains, 5

7 vegetables and fruit (Marñón 2006). The region is Mexico s top producer for canned and frozen produce and is responsible for 90% of Mexico s exports in frozen produce. Figure 1. Map of Lerma-Chapala Basin (Wester 2008) The climate of this region is semi-arid, with evapotranspiration exceeding precipitation in all months except July and August. In fact, almost all (90%) of the annual precipitation (705 mm) tends to fall from May to October (Wester 2008). Irrigation is a key factor in the success of agriculture in this area to compensate for the deficit in water available through precipitation. El Bajío region is served by both surface water and groundwater sources, although generally groundwater is the main water supply for the region s urban areas and vegetable farmers, while surface water is the main source for grain crop irrigation. There are more than a dozen identified groundwater aquifers in the state of Guanajuato, and more than 40 identified in the Lerma-Chepala Basin. The Green Giant and Old El Paso facilities draw their water from the Irapuato-Valle de Santiago Aquifer, while Green Giant growers draw their water from this and several neighboring aquifers. 6

8 The Lerma-Chapala Basin is an important surface water region for Mexico (Figure 1). Although the basin accounts for only 1% of the total surface water flow in Mexico, the basin provides water to 15% of Mexico s population and accounts for 13% of the country s irrigated area and 9% of Mexico s GDP (Wester 2008). The Basin drains a 55,000 km 2 area across five states, including a large portion of Guanajuato, gathering water that flows west through the Lerma River and eventually into Lake Chapala. Five tributaries feed the main stem of the Lerma River along its 705 kilometers, including Rio Laja, Rio Guanajuato and Rio Turbio in the state of Guanajuato. Under natural conditions, Lake Chapala spills into Rio Santiago, which flows northwest 520 kilometers to the Pacific Ocean. Water Resource Challenges and Risks in the Region There are several water resource challenges and risks in the greater Irapuato area and the surrounding region. A more detailed assessment of the situation is provided in the updated Water Resources Risk Assessment Report, but a broad overview of the challenges will be provided here. The most evident water-related challenge facing the region is simply a matter of overuse. Agricultural and industrial development have increased rapidly over the last several decades (Table 1) and the available water resources cannot keep up with demand. Efforts have been made to improve regulation of water use, but enforcement is insufficient and annual surface water and groundwater use is greater than can be replenished. Creating a balanced water budget in the region will require a concerted collaborative effort by large water users and government agencies to increase water use efficiencies, improve monitoring of the water resources, and strengthen government and self-regulation of water use. Table 1. Area of irrigated agriculture in the Lerma-Chapala Basin (SEMARNAT 2001 in Hoogesteger 2004) Prior to the 1940s, irrigation in Guanajuato state was primarily served by surface water. With the introduction of tube well technology, however, groundwater irrigation began on a large scale in the 1940s. In the 1950s groundwater pumping in Guanajuato accelerated, in a large part due to the emergence of commercial agriculture in the region, as well as urban development and industrial growth (Hoogesteger 2004), and aided by new pumping technologies. Throughout the 1950s and 1960s the Mexican government supported rapid agricultural growth, including funding for increased groundwater pumping. For example from 7

9 1970 to 1976 the area under irrigation in Guanajuato increased by over 13,000 hectares (Hoogesteger 2004). By the end of the 1970s, the impacts of groundwater pumping began to be realized as groundwater tables declined. This decline initiated the first state-wide regulation of groundwater in Guanajuato, as the entire state was places under veda in 1983, restricting any new groundwater wells unless they were registered by the state. This veda was not enforced, however, and the number of wells and volume of pumping continued to increase (Figure 2). The National Water Commission (CNA) has attempted to regulate groundwater withdrawals since it was founded in 1989, with some success. As a result of the decline of water tables, and associated impacts such as decline in water quality, the rate of new groundwater wells has decreased as compared to previous decades. Figure 2. Number of wells in Guanajuato over time as compared to well drilling prohibition orders (Foster et al 2004) Although agriculture accounts for most (~85%) of water use in the region, growth in industry and urban water use have also increased the strain on available resources. Population in the Lerma-Chepala Basin doubled from 2.1 million in 1930 to 4.5 million in 1970, and more than doubled again to 11 million in If the current population rate continues, the population will double again during the next 20 years (Hoogesteger 2004). As agricultural and industrial production increases, and population continues to rise, the water available per capita rapidly decreases. Figure 3 demonstrates this availability, which as of the early 2000s was approximately 749 m 3 /person/year, compared to the national average of 4,067 m 3 /person/year (CEAG 2001). 8

10 Figure 3. Population versus relative water availability in Guanajuato (CEAG 2003p in Hoogesteger 2004) Groundwater Resources: The Aquifers of El Bajío The pressure of irrigated agriculture, population growth and development of industry in the region has an increasing impact on the aquifers from which groundwater is withdrawn. The extent of this impact can be best understood by considering the balance of water use versus available water. In the Lerma-Chepala Basin, CNA data show that during the 1990s the average annual groundwater recharge was 3,980 hm 3 /a, while average annual withdrawals were 4,621 hm 3 /a, resulting in a deficit of 641 hm 3 /a on average across the basin. More recent data, from 2002, estimates the groundwater use deficit at 1,336 hm 3 /a (Wester 2008). In the Irapuato-Valle de Santiago Aquifer, from which the Green Giant and Old El Paso plants draw water, inflows to the aquifer include vertical recharge through precipitation, surface water or irrigation return flows and lateral subsurface flows from other aquifers. Outflows from the aquifer are due to groundwater pumping for agriculture (82%), urban water supply (10%), and industry (8%) (COTAS Irapuato 2012). There are 2,348 wells into this aquifer, 1,969 of which are currently active. From those active wells, approximately 255 million cubic meters more water per year is withdrawn from the aquifer than is being replenished by inflow into the aquifer. The result of this annual aquifer deficit is the decline in groundwater levels over time. The average decline in aquifer water levels in Guanajuato is 2 meters per year (see Table 2), with 9

11 some local areas experiencing a drop of up to 5 meters per year (Scott, et al. 2004). Even more severe cones of depression for aquifer drawdown can be seen around urban areas due to concentrated pumping (CEAG 2000). For example, the cumulative effect of groundwater pumping over the last half century has resulted in a drop in aquifer levels of meters in the city of Celaya (CEAG 2003pl in Hoogesteger 2004). Table 2. Average Annual Decline of Water Levels in Guanajuato Aquifers (Hoogesteger 2004) The impacts of groundwater pumping and related aquifer decline vary depending largely upon the extent of decline and the local composition of the aquifer, but they include compaction of alluvial deposits, increased pumping costs and decline in water quality (Hoogesteger 2004). Compaction of alluvial deposits is caused by the absence of water in the pores that comprise the aquifer. Alluvial deposits move to fill in these pores, causing loss of porosity and compaction of the deposits. This compaction reduces the ability of the aquifer to store water and increases the risk for subsidence and groundwater contamination due to potential development of fissures. As water levels drop in the aquifer it takes more electricity to pump water over a greater head. New wells need to be drilled lower and more power is needed to bring the water to the surface. As water is pumped from deeper depths, the water tends to be of lower quality, as evidenced by the increase in soluble salts, sodium, bicarbonates, SAR and ph in groundwater pumped in Guanajuato (Castellanos, et al. 2002). Over time, the real challenge for aquifers in Guanajuato is not simply a matter of one day running out of water. More than likely, as these impacts from overuse compound, with an increase in cost, decrease in water quality and higher risks of subsidence and pollution, the costs of groundwater pumping will at some point outweigh the benefits for many users. CEAG estimates that the limit of economically feasible pumping for many crops is likely at a depth of approximately 120 meters (Lesser 2000). At the current rate 10

12 of groundwater pumping, this is likely to be reached in many of Guanajuato s aquifers in the next several decades. Surface Water Resources: The Lerma-Chapala Basin Under natural conditions, Lake Chapala overflows into Rio Santiago, forming the Lerma- Chapala-Santiago Basin. However, since the 1980 s almost no water has overflowed into Rio Santiago due to low lake levels and the Lerma-Chapala Basin has become, for the most part, hydrologically separate. Low lake levels are mainly due to decreased inflows as a result of overuse of water in the Basin, although low precipitation contributes to the lowest lake levels during dry years. Precipitation was 6% below average during the 1990 to 2001 period, but the volume of water used in the basin exceeded the natural replenishment of water by 9% on average during this period (Wester 2008), without taking into account environmental flows. Water consumption in the Basin exceeds replenishment in all but the wettest years and it is estimated that on average, the deficit between water demand and water availability is between 1.6 and 1.8 billion cubic meters per year (Marañón 2006). Agriculture accounts for 84% of water use in the Guanajuato portion of the Basin. According to the National Water Commission (CNA), the Lerma-Chepala Basin is the largest recipient of municipal wastewater in Mexico, with only about 30% of this wastewater treated before discharge (Marañón 2006). The basin experiences an annual BOD (biochemical oxygen demand) load of approximately 48,000 tons a year. The result is a CNA classification of highly contaminated for 52% of the surface waters in the basin, 39% of waters labeled as moderately contaminated and only 9% that are of acceptable water quality. Pollution is of most concern in the upper and middle Lerma-Chapala Basin, where industry plays a large role in contamination of the system. Future Pressures: Climate Change and Growth The future outlook for the water resources in El Bajío will most likely depend on agricultural water requirements, growth of industry and urban population, and future climate conditions, in parallel with changes to current water management policies. Guanajuato s State Climate Change Program provides insights into what the expected growth and climate conditions will be in Guanajuato (Gobierno de Guanajuato 2011). In terms of demands, the latest Climate Change Program report estimates that, between now and 2030, in most areas of the state the agricultural water requirements for all climate scenarios will increase by 5-10%, industry water demand will increase by 4-6% and potable water demand will increase by 5%. For a range of emission scenarios (A1B, A2 and B1), the Climate Change program predicts that on average across the state the temperature will increase by C by 2039, C by 11

13 2069 and C by For all emission scenarios over the next 80 years, average annual precipitation is expected to decrease by 5 10% from normal, with increases in precipitation expected during the wet season. The impacts of these changes in climate conditions include increased water scarcity due to an increase in demand, greater risk and severity of extreme weather events such as floods and droughts that can impact crop production and infrastructure, and potential decrease in crop yield. The state has developed a plan for action to better adapt to climate change (Gobierno de Guanajuato 2011), which includes activities such as: Promote rainwater harvesting Improve climate and hydrologic monitoring Reduce leakage from water infrastructure Promote use of treated wastewater for irrigation and other non-potable uses Reforest riparian areas to reduce evaporation from water bodies Promote drought-resistant crops Implement more efficient irrigation technologies Alternate cropping systems to deal with drought Implement reforestation Improve water resource policy and management Water Resource Governance One of the biggest challenges to sustainable management of water resources in Guanajuato and El Bajío growing region has been the inability to properly regulate withdrawals to ensure balanced water use in the Lerma-Chapala Basin and groundwater aquifers. Efforts to improve water use efficiencies in the last two decades have been promising. For example, approximately $120 million total, or $180 per irrigated hectare, invested by state and federal agencies and water users in improving irrigation efficiency between 1996 and 2003 (Hoogesteger 2004). The benefits of these programs have reached over 250,000 hectares and over 55,000 water users. Despite these efforts, aquifer levels continue to drop and the outlook for the future of water resources in the region is not positive. Reaching sustainable water use in this region will require stronger enforcement of water use concessions, continued investment in improving efficiencies and creative approaches such as progressive energy pricing and water concession markets. Federal Governance The focus of early federal water management agencies was on full development of water resources to the greatest economic benefit, without regard to the environmental impacts or the sustainability of the operations (Wester 2008). Groundwater management went from a 12

14 hands-off approach to government backed development and exploitation, to finally, in the last two decades, an attempt to control pumping. From The National Irrigation Commission (CNI) in the early 1900s through the Ministry of Hydraulic Resource, established in the 1940s, the focus was on central management of water resources, development of irrigation and water storage schemes and limited involvement of water users in local water resource management (Hoogesteger 2004). As early as 1948 there was recognition of the need to curtail groundwater pumping, with the implementation of the first veda decree, requiring approval of all new wells. However, the veda decrees were never really applied in the field and, as illustrated in Figure 1, installation of groundwater wells continued at a rapid rate. In 1989 the National Water Commission was established and the National Development Plan created for Mexico, which called for a return of power for management of water resources back to the irrigation districts and more participation of the social and private sector in water management (Wester 2008). By the 1990s Water User Associations (WUAs) had been created across the country, collecting water user fees and operating self-sufficiently. In 1992 a national water law called for integrated surface and groundwater management, increased stakeholder participation, improved control of water withdrawals and discharges and management at the river basin level. At the same time the National Water Commission (CNA) was created, which remains the primary federal water resource management agency in Mexico. The CNA is responsible for creating national water policies, granting water rights, setting standards for water use and water quality, and integrating regional and national water management plans. The CNA operates offices at the federal, state and irrigation district level. Since its establishment, the CNA has been responsible for all surface and ground water concessions. Concessions are granted based on a specific volume of water to be pumped annually over a given number of years. The National Water Law of 1992 requires that all groundwater users install flow meters and report volumes to the CNA twice a year, but only a small percentage of water users follow this rule. CNA does not have the capacity to enforce the concessions, and new illegal pumps are installed every year. Oorthuizen (1995, in Hoogesteger 2004) and Hoogesteger van Dijk (2004) together offer several reasons why CNA management of groundwater pumping has proved less than optimally effective: Insufficient staffing at the field level. With the number of staff available, it is estimated that it would take CNA inspection teams 44 years to check on all of the wells in Guanajuato. There is political pressure to focus on other priorities. For example, there is a heavy burden for government to address poverty alleviation, economic growth, development and other political interests before prioritizing issues of water sustainability. 13

15 CNA has lacked legal power to control extractions. In the past CNA enforcement of well pumping regulations has lagged behind regulations. This is improving and enforcement has increased in the last several years. However, some challenges to enforcement continue. The majority of wells do not have well meters, even though they are legally required to install them. Also fines imposed due to overuse of groundwater are often less than the benefit that water users receive from pumping. The federal government has attempted to control groundwater pumping in the last decade or so through changes in energy pricing and purchasing of water concessions. Agriculture is the only sector that does not have to pay for use of water, but water users pay for the energy that it takes to pump water from the aquifer to the surface. Essentially, the cost of water use is the cost of energy use, and this energy use is highly subsidized by the government. One way to encourage more efficient water use is through increasing energy costs, either through reduction of the government subsidy or graduated energy costs. Scott and Garces-Restrepo (2001, in Hoogesteger 2004) predict that at some point energy costs will become so high, due to greater energy demands of available energy that, of all the crops irrigated by groundwater, only the highest value crops will remain profitable. In fact, in 2003 the government decreased the electricity subsidy while several farmers in north Guanajuato were forced to abandon some deep wells that became cost-prohibitive to use. The federal government has exercised its ability to buy up groundwater rights through a water rights acquisition program as a way to curtail use, but this program is limited. Guanajuato has also had a private water market for some time, but so far this market has done little to reduce water use, and in some cases it has simply increased use (Hoogesteger 2004). For example, a water concession owner may sell a partial concession, resulting in a split concession for two users. As pumping volumes are not heavily enforced, both users may in the end use much more than the original concession and pumping is increased. Regional Governance In 1993 the Lerma-Chapala River Basin Council was formed as part of a new effort to manage water at the basin scale. The Council is comprised of a governing council, a monitoring and evaluation group, a basin level user assembly and special working groups, with the CNA regional office serving as the Council s secretariat. The Council applies surface water allocation rules based on a 1991 agreement, but an imbalance between water use and water availability continues to occur in many years due to several factors: the 1991 agreement overestimated the annual water availability in the Basin (as it was based on a generally wet period from 1950 to 1979), CNA enforcement of water use in irrigation districts is limited, there is inadequate control over direct pumping from Rio Lerma and Lake Chapala, and increased groundwater use continues to reduce baseflows (Wester 2008). Due partially to historic low levels in Lake 14

16 Chapala in the late 1990s and early 2000s, updating of the 1991 allocations based on data from more representative years has occurred so that allocations reflect a more realistic water availability situation. The River Basin Council has been relatively successful in regulating surface water use in the Basin, but there is still a need to integrate conjunctive management of surface and groundwater use in the region. State Governance State government has taken a large role in water resource management since the mid-1990s through the creation of the Guanajuato State Water Commission (CEAG) and programs run by the Secretary of Agro-pecuary Development (SDA). CEAG was created to gain a deeper understand of the water resource situation and water balance in the state and to promote a stronger water management culture. Today the commission sees its mission as ensuring that the people of Guanajuato have good quality water available for their well-being through investment of hydraulic infrastructure and proper water management (CEAG 2012). The agency aims include creation of an integrated water resource monitoring system, balance of water use in the state s aquifers, improvement of the legal framework for water management, greater involvement of the social sector in improved management of water resources, promotion of water efficiencies through structural investments and technical assistance, and investments in water and sanitation infrastructure. SDA runs several programs, with support from CEAG and CNA, which aim to increase irrigation efficiencies (Hoogesteger 2004). A few of these programs are: The Technification of Irrigation program started in Guanajuato in 1996 as a joint program of the federal and state government, with management lead by SDA and support provided by SAGARPA. The goal of the program is to increase productivity, make water use and management more efficient and reduce costs of energy and fertilizers. This program accounts for at least half of all irrigation efficiency improvements in Guanajuato, with installation of mainly low-pressure conveyance, and some sprinkler and drip irrigation systems. In 1997 a plot leveling program was initiated and funded solely by the state government, with SDA at the lead. Plot leveling can improve irrigation efficiencies by 40-60% and has been said to improve yields by 10%. In 1997 SDA initiated a program to improve small surface irrigation works, including organizing users into Water Users Associations and improving existing infrastructure. This program has helped water use and distribution become more efficient, but has been limited by surface water infrastructure restrictions from CNA. 15

17 The National Water Commission (CNA) promoted the establishment of aquifer management committees, called COTAS (Consejo Tecnico Aguas), through the Mexican Water Law of At the same time, Guanajuato state initiated a large effort to address groundwater management challenges through technical studies of its aquifers and the formation of fourteen groundwater user s associations, which eventually evolved into COTAS. Since 1998 Guanajuato state government has supported these COTAS through a trust fund, with the COTAS receiving technical support from CEAG (Guanajuato State Water Commission) and universities, and legal support from CNA. The COTAS are groundwater user associations that aim to reach agreement between the water user sectors on proper management in an aquifer. Each COTAS is very different in its priorities and level of success, but CEAG s vision of potential activities for a COTAS includes: Capacity building in support of the implementation of groundwater management plans. Promotion of resource management-related projects, appropriate to solving specific local problems. Support to the federal government in groundwater rights administration. Improving awareness of groundwater management needs, by means of public communication campaigns and via the child education system. A range of groundwater user service provision from representing user interests in state negotiations to assisting individual users in dealing with groundwater permit. applications and efficient technical and financial well operation Achieving financial sustainability through seeking member subscriptions and by linkages with appropriate public and private partners (Foster, et al. 2004). Despite these successful programs, many COTAS have had limited success in curtailing overuse of groundwater due to limited budgets, lack of full participation by water users and lack of legal authority to control groundwater use. Most on the ground projects have been small and remained in pilot stages. However, the COTAS have come to serve as an intermediary between water users and various agencies (Hoogesteger 2004 ). An overview of the activities of the Irapuato-Valle de Santiago COTAS is provided later in this report. Improvement of Governance There are several ways governance could be improved to better address sustainable water management in Guanajuato state. No path is easy, and all require time and investment, but these efforts could help better regulate water use and provide opportunities for more efficient use on the ground. Some suggested improvements from Hoogesteger (2004) and others: 16

18 Decentralization of water resource control to the state, river basin and local level. This has essentially happened in part for surface water with the Lerma-Chapala River Basin Council, but local management of groundwater is still struggling. Additional investment and a strong commitment to enforcement of water use concessions. Conjunctive management of surface and groundwater. The Lerma Chapala River Basin Council has been relatively successful in management of surface water on a basin level, but groundwater management is still lacking. Changes in energy pricing to curtail use. At this point there is no strong financial incentive for water users to pump less water, especially with energy subsidies in place. Government agencies should continue to think about how a creative energy pricing scheme can incentivize efficient water use without restricting poorer water users from obtaining the water they need. Support of a functioning water concession market. A water concession market can be an effective way of promoting good water management, but until concessions are enforced a water concession market may do more harm than good. Continued buying up of water concessions by the CNA. Water Sustainability at General Mills Irapuato General Mills Water Use 1 Water is a critical component for General Mills operation in Irapuato, from watering vegetable starts in the greenhouse to freezing finished product at the Green Giant plant. For water accounting purposes, water use by General Mills can generally be categorized into water use at the processing facilities; water use at the greenhouse, washing station and research farm; and water use by contract growers. Figure 4 shows the breakdown of water use for all greenhouse and food processing activities based on estimates collected during The Nature Conservancy site visit in April, The water use at the processing plants is based on well data, while the greenhouse water use is an estimated value provided by General Mills employees. Most of the water (60-70%) used at the production site is for prewashing, cutting, cooking, defrosting and freezing of the product. The remaining water use is for cleaning, flushing toilets, washing hands, and other day to day operation of the facilities. 1 All of the water use information was collected via in-person interviews with Irapuato General Mills staff and from available plant data 17

19 Figure 4. Water use by General Mills in the Irapuato area, General Mills relies on groundwater pumped directly on site for its water supply. There are four groundwater wells located on the Green Giant / Old El Paso property, with two currently in operation, and one additional well at the greenhouse location (see Table 3). Well 1 was installed in 1987 at 150 meters depth, with static water level measured at about 67 meters deep. There was a drop of approximately 30 to 40 meters in the dynamic water level over the 24 years it was operated. Since its closure to pumping last year, this well has become a groundwater monitoring well as part of a larger effort by the Irapuato-Valle de Santiago COTAS to monitor changes in aquifer levels. General Mills pays a fee to the National Water Commission per abstraction at the processing plant of approximately 9.65 pesos per cubic meters. Fees are waived for abstraction at the greenhouse because it is considered agricultural water use. 18

20 Table 3. General Mills water supply wells Name Location Depth Status Well 0 Green Giant 60 m Closed in 1987 Well 1 Green Giant 150 m Closed in 2011, now used for monitoring Well 2 Green Giant 350 m Supplemental emergency Well 3 Old El Paso 450 m Opened in 2010 GH Well Greenhouse m Opened in 2011 Wastewater from the processing plants is treated for BOD, COD, solids, oils, and chemicals through an onsite aerobic wastewater treatment plant. General Mills then discharges the treated wastewater to the Irapuato municipal wastewater system. The municipality treats approximately 90% of its wastewater at three wastewater plants and discharges the outflow to the Chapala River system. General Mills pays a fee per cubic meter of wastewater discharged to the municipal wastewater system. Water Use in the Field Green Giant processes several types of vegetables at its plant, but for simplification this section will focus on water use applied to two crops, broccoli and carrots, as they comprise almost 80% of the total weight processed at the plant. Green Giant contracts with farmers for 19

21 approximately 2,400 hectares of broccoli and approximately 120 hectares of carrots. For farmers using flood irrigation, about 7,000 cubic meters of water are applied per hectare of broccoli, while drip irrigation fields require an application of about 3,850 cubic meters. Not all of this water is consumed by the crop through evapotranspiration, however, as some returns to the hydrologic system through return flows or infiltration. For example, water lost during conveyance in a flood, or gravity, irrigation system to infiltration most likely returns to the aquifer below. The Water Footprint Network provides values for average water consumption for crops in each state, using regional and global values for climate, soils and other required data (Mekonnen & Hoekstra 2010). The Network calculates that for broccoli grown in Guanajuato, an average of 275 cubic meters of water is consumed per ton of broccoli produced, while carrots consume 133 cubic meters per ton. With drip irrigation Green Giant employees estimate that they see about a 10% increase in yield per hectare. Current General Mills Irapuato Sustainability Efforts Facility Sustainability Goals The Green Giant and Old El Paso facilities realize the importance of integrating sustainability into their production and have set sustainability goals for the plants in the areas of water, energy and solid waste. All engineering proposals for expansions or changes to the plant are required to consider the expected savings in each of these areas. In terms of water, the plants aim to reduce water use, recycle water and change internal culture about water conservation. The facilities hope to achieve a reduction in total water use by 50% in five years. Some current on-site water-saving activities include: Recapture of cooling water for reuse Use of rejected reverse osmosis water (which is how incoming water is treated) at the Old El Paso plant for non-food production uses. This produces a savings of 2,500 cubic meters a year, and serves as a pilot for other General Mills facilities. Re-engineering of cooling system to save energy and reduce water use by about 20% Through its efforts, General Mills has decreased its water use per ton of vegetable processed, but as the facility has increased production the water use levels have remained approximately the same since water saving efforts began. Drip Irrigation Program In an effort to respond to water resource challenges facing El Bajío growing region, General Mills initiated a program to encourage their contract growers to reduce their water use through 20

22 conversion from flood, or gravity, irrigation to drip irrigation. Flood irrigation is the movement of water through earthen canals or furrows, with water delivery occurring in between rows of crops. Drip irrigation is precise application of water through tubes or irrigation tape, with water applied through small holes directly at the root of the crops. Every hectare that a farmer converts to drip irrigation costs on average $3,000 due to heavy start-up costs. Most systems require a storage pond, a relatively fine water filter and an automated system that adds required fertilizers to the irrigation water before it is sent out to the fields. However, the benefits of drip irrigation outweigh the costs over time. Drip irrigation requires less water per hectare and increases productivity per acre by up to 10%. Pumping less water also reduces energy costs, and more precise application of fertilizer reduces the total volume of fertilizer required. The crux of General Mills drip irrigation program are interest-free loans that General Mills offers to its contract farmers to offset costs of installing drip irrigation systems. General Mills also provides technical assistance, and connects farmers new to drip irrigation with farmers who have had experience and can speak to its benefits and help guide selection of system components and address problems as they arise. Farmers usually start small, with just a few hectares under drip irrigation, and then expand after realizing the benefits of the system. Currently 40% of General Mills contract growers in the region use drip irrigation systems, which is in stark contrast to the 3-5% of all Guanajuato farmers who use drip irrigation. The savings that have been realized from this drip irrigation program so far can be estimated based on percent of growers enrolled, total land under contract by General Mills, and the savings estimated per hectare of conversion from furrow to drip irrigation. Considering only broccoli, which makes up about 60% of Green Giant s contracted vegetables by weight, farmers withdraw approximately 3 million cubic meters less water per year due to conversion to drip irrigation. If 100% of Green Giant s broccoli growers were to implement drip irrigation on their farms, they would withdraw 7.6 million cubic meters of water less per year than before the program began. It is important to remember, however, that the actual savings to the aquifer would be less than this volume as some of the losses of flood irrigation actually return to the aquifer via infiltration. Reforestation For the last several years, General Mills has taken advantage of their greenhouse facilities and expertise to provide tree seedlings for planting in the local area. The program began out of the interest of one employee, but has grown each year in size and impact. In its first years, trees were distributed to employees to plant at their homes and on General Mills properties. Over the years General Mills has partnered with local community groups, the University of 21

23 Guanajuato, the municipality, schools, and other companies to plant trees in the region, as well as continued to provide trees to employees. Concentrated plantings of hundreds or thousands of trees have been implemented around a local reservoir (10 acres), on the University of Guanajuato campus (6 acres), and on a preserve where deforestation had previously occurred (50.5 acres). Currently partners and planting locations are selected based on personal relationships and, in some cases, with a letter of application. There may be some opportunity for General Mills to become more strategic about where plantings occur to better align with its environmental sustainability goals, including those focused on water. In ,000 seedlings were planted through the General Mills reforestation program, 60% of which survived the year. The number of plantings is expected to grow in 2012, including 2,000-3,000 trees planted during one single employee volunteer day in June. Green Giant employees and their partners collect native tree seeds, which are tended and grown into seedlings at the Green Giant greenhouse. Employees estimate that they have the potential to produce up to one million trees a year at the greenhouse to be distributed to its partners. There are many environmental benefits from reforestation, including carbon sequestration and restoration of natural habitat. Estimates of carbon sequestration due to reforestation are between 2.2 and 9.5 metric tons of CO 2 per acre per year (Gorte 2009). Estimates of carbon sequestration for complete reforestation of the preserve (~50 acres) are between 110 and 475 metric tons of CO 2 a year. In terms of water resource benefits, reforesting with native trees helps return the watershed to a more natural hydrology. Trees help to hold soils in place, reducing sheet erosion, which is a 22

24 large contributor to suspended solids in rivers and streams. Vegetation slows down surface runoff, helping to infiltrate more water into the soil and shallow aquifer, reducing flood peaks and releasing water longer into the dry season. Using a simplified method for calculating the benefits, once reforestation is complete at the preserve site, the vegetation will slow down 35% more precipitation, allowing more to infiltrate into the soil as compared to a nonvegetated scenario 2. (Reed and Larson 2010). Evapotranspiration rates for forested land cover is higher than for bare land cover, but the hydrologic benefits of the forested landcover generally outweigh these evapotranspiration losses. Crop Research On the same site as the greenhouse where Green Giant employees grow vegetables starts, Green Giant operates an agricultural research plot. This research field allows Green Giant to test a variety of factors that can affect yields and quality of vegetables produced. When Green Giant is introducing a new vegetable to its processing plant, Green Giant agronomists test for the best breed and application rates of water, fertilizers, and other inputs to the vegetable plot. The field also allows Green Giant to test methods for reducing water application to crops and application of organic fertilizers. With this information, Green Giant helps their contract farmers maintain or increase their yields and to become more sustainable in their farming techniques. 2 This assumes an average precipitation of 705mm/yr from (Wester 2008). 23

25 One example of a technique that Green Giant has tested on its research plot is application of chicken compost on the fields as an alternative to traditional chemical fertilizer. This technique has been shown to increase yields by about 3-4%, in addition to yield increases due to drip irrigation installation, increase the soil holding water holding capacity, and decrease the volume of chemicals that is applied to, and runs off, the fields. Another example of Green Giant research is the use of a gel additive to the soil in order to increase the soil water holding capacity. This allows the soil to hold water longer, before it drains to lower strata, giving more time for the roots to take up the water that is applied. The result is that less water needs to be applied per hectare, reducing withdrawals for irrigation. Participation in the COTAS As part of its commitment to improving water management of the water resources on which it depends, General Mills actively participates in the Irapuato-Valle de Santiago COTAS (Consejo Tecnico Aguas), with a Green Giant employee serving as a water user representative for the industrial sector. The Irapuato-Valle de Santiago COTAS is very active, with several programs currently in motion. The approach of the Irapuato-Valle de Santiago COTAS consists of four sub-strategies: 1) Integrated management of the water with major water users 2) Capacity building to improve water use efficiencies 3) Working towards a balance between water use and aquifer recharge 4) Creating a culture of water awareness (COTAS Irapuato 2012) One of the activities of the COTAS is to improve monitoring of the aquifer by installing automatic water depth monitoring wells. General Mills has converted a pumping well at its Green Giant site to a monitoring well as part of this effort. Other efforts include mapping of water levels, building an understanding of how to improve water management, coordination between water users and CNA, and hosting environmental education events. The COTAS likely provides the best opportunity for connecting with other groundwater users and for finding better ways to help better manage the aquifer and build capacity to improve the sustainability of water use. Creating a Water Stewardship Plan This assessment of water resource challenges in the region can help General Mills develop a plan to address water-related risks and impacts in the Irapuato area. This plan should consider a variety of potential response strategies, with selection of strategies based on the potential for greatest impact, feasibility of implementation, and suitability to the values and objectives of the local General Mills facilities. In this section a menu of response strategies is presented (Table 4), 24

26 and set in the context of on the ground application at the facility site, in the supply chain, or in the greater watershed / aquifer recharge area, and strategies that are implemented at the governance level. Table 4. Potential Water Stewardship Activities for General Mills Operations in Irapuato Activity Actions Potential Partners Reduce water use Continue to invest in improving water efficiencies, at processing faclities water reuse, creative application of non-potable waer N/A Drip irrigation Breed for water efficient crops Switch to less water intensive crops Use real-time data to more efficiently irrigate crops Increase water holding capacity of soil Reduce soil moisture evaporation (ex. Mulch) Reduce evaporative loss from water storage Aquifer recharge projects Capture rain water for irrigation use Continue to support implementation with contract farmers, share program with other agro companies Breed at the greenhouse, use water efficient breeds on the farms Include water efficiency in business decision making on which crops to produce Use soil moisture probes and other similar technology to more precisely irrigate crops Continue to research methods to increase water holding capacity and implement in all contract farms Encourage traditional and non-traditional methods of reduced soil moisture evaporation Encourage coverage of any on site water storage to reduce evaporation Research potential for aquifer recharge; if feasible implement several aquifer recharge sites around the basin Encourage capture and storage of rain water to help supplement irrigation Contract and non-contract farmers; other agro companies Greenhouse, contract farmers Greenhouse, contract farmers Contract and non-contract farmers; other agro companies Greenhouse, contract farmers Contract and non-contract farmers; other agro companies Contract farmers Contract farmers, other large land owners Greenhouse, contract farmers Consider VRI or Learning exchange with Flint GA farmers, non-contract 25

27 other water saving irrigation techniques Store surface water during high flow times Reforestation Alliance for Water Stewardship certification Improve water governance Water fund or similar cooperative water stewardship effort River; research and implement VRI if appropriate in the Irapuato region Research feasibility of capturing high flows to store for use during the dry season; implement if possible Targeted reforestation based on recharge areas and highest risk of erosion Pursue AWS certification of Green Giant facility Continue lead role in aquifer group; advocate water stewardship policies; support monitoring and enforcement programs Research feasibility of a water fund in the area; connect with other large water users to gauge potential for water fund participation grain farmers State water agency, contract and non-contract farmers, municipalities Ejidos, local NGOs AWS State water agency, other large water users and agricultural companies, municipalities, NGOs Other large water users, agricultural companies, municipalities, NGOs An important initial step in developing a water stewardship plan is to set goals based on an agreed definition of sustainable water management. In this region one of the key components of sustainable water use should be a balance between groundwater pumping and aquifer replenishment, with an average net zero change in aquifer levels. Without this balance, the aquifers in this region will eventually reach a point at which they can no longer serve as a reliable water supply for cities, industry or agriculture. If pumping continues as it has in the past, this turning point is likely to occur in the coming decades, and potentially sooner for many wells. One way to set sustainable water management goals for this region is to consider the current deficit between aquifer pumping and replenishment. For example, in the Irapuato-Valle de Santiago Aquifer there is an average annual deficit of approximately 255 million cubic meters. As illustrated in Figure 5, there is no way one solution will be able to meet this deficit. Although the region can likely make the largest single gain by increasing agricultural efficiencies, irrigation efficiencies would need to increase by 56% if it were the only strategy employed, which is nearly impossible to accomplish. It is clear that it will take a combination of improved water use efficiencies by municipalities, industry and agriculture, investment in watershed based solutions, and improvement in governance of water use to meet this goal. 26

28 Figure 5. Example of a water stewardship strategy for the region 3 Water Use Reduction at the Processing Facilities A practical initial focal point for a company s water stewardship efforts is in their own facilities. There are often many places in and around the facilities where water efficiency and water quality improvements can be made and the company is able to directly affect water use at the facility level. General Mills has made good progress in reducing its water use at its Irapuato production sites through water efficiency improvements, water reuse, and use of non-potable water for cleaning and other appropriate applications. The facility has an existing plan for reducing water use more in the coming years and The Nature Conservancy applauds the efforts of General Mills engineers and associated employees in designing and implementing these activities. General Mills should continue to seek out opportunities for reducing their water use at the Green Giant and Old El Paso plants, as well as at the greenhouse and carrot washing facility. As the water supply demand decreases at the facility, risks and impacts of water use are slightly reduced and other benefits, such as reduced energy costs, may result. General Mills should 3 Costs and relative potential deficit offset for each strategy are purely illustrative. More in-depth investigations are needed to determine these values. 27

29 consider sharing their experiences in reducing their facilities water use with other industrial water users in the region as an example of a successful program, as well as looking for lessons from other local facilities. Water Use Reduction in the Supply Chain Although water savings at the processing facilities are important, the key focal point for improving the sustainability of water use should be in growing of agricultural ingredients, where the majority of a product s water footprint lies. Although a company s influence may not be as strong, by reducing impacts of water use in the agricultural supply chain a company can make the biggest leap in improving the sustainability of producing a particular product. General Mills has a unique opportunity in the Irapuato region in that the company contracts directly with the growers that provide the produce processed at the Green Giant facility. Contracting allows Green Giant to set standards for its growers, including environmental sustainability standards. In many cases General Mills contracts with the same growers over many years and is able to build a sense of trust with the farmers, which allows them to introduce new techniques to improve sustainability. Drip Irrigation General Mills has already begun reducing water use in the supply chain with its drip irrigation program. By switching to drip irrigation, 40% of Green Giant growers in the region have reduced their water application per hectare of broccoli by approximately 45%. Green Giant should continue to engage growers with the goal of 100% of contract growers using drip irrigation. However, even with 40% of Green Giant growers using drip irrigation, only 3-5% of all growers in the region rely on drip irrigation for their crops. Therefore, in order to make a larger impact on water use in the region, Green Giant should aim to increase the number of growers in the region, even those not under contract with the company, that utilize drip irrigation. The best way to achieve this should be explored by General Mills, but some initial suggestions include: Offer no-interest drip irrigation loans to non-contract farmers Partner with other large agricultural companies that have contract growers in the region to implement their own drip irrigation program Provide technical expertise and the opportunity for Green Giant contract farmers to share their experiences with other non-contract farmers Collaborate with CEAG and / or CNA, or within the COTAS, to increase the support for drip irrigation implementation for non-contract farmers 28

30 Caution should be taken when switching from traditional irrigation methods to drip irrigation in that sometimes the change results in no actual reduction in water use due to an increase in land irrigated since it requires less water per hectare. Green Giant should ensure that their drip irrigation program actually results in a reduction in water use in the region and does not simply allow for an increase in crop production, otherwise this effort will make not help move the basin towards a balance between withdrawals and recharge. Alternative Water Efficiency Efforts Several other opportunities to improve the efficiency of agricultural water use are available to Green Giant in the Irapuato region. Many of these involve continued investigation at the General Mills research plot, and dissemination of these techniques to Green Giant farmers. Others require connecting Green Giant farmers to technologies and methods already proven elsewhere in the world, and supporting the implementation through capacity building and financial investment. Many of these potential efforts are listed in Table 4. Some efforts may only apply to non-contract growers, such as implementation of variable rate irrigation on grain crops. This technology in particular provides huge annual water savings and could help address irrigation inefficiencies for the grain crops grown in the region (Biello 2012). Even though Green Giant does not purchase grain crops in this region, by connecting grain growers with farmers in other regions, for example in the Flint River area in Georgia (where The Nature Conservancy is partnering with farmers to save million cubic meters a year), Green Giant can help improve the overall efficiency of agricultural water use in El Bajío growing region. Investing in the Greater Aquifer/Watershed In addition to water efficiency improvements at the point where water is being used in the region, there are a variety of options for investment in on the ground activities across the watershed that can help improve how water is managed (see Table 4). These proposed activities can be categorized as either grey or green infrastructure solutions, based on whether they rely on built or natural solutions. It is likely that solving the water sustainability challenge of this region will require implementation of both grey and green infrastructure solutions. The selection of activities needs to take into account cost, ability to make a difference at scale, and potential unintended consequences of the solutions. A full cost-benefit calculation should be undertaken to determine the best potential combination of watershed based solutions to address the water resource needs and challenges of the region. Grey Infrastructure As presented in Table 4, potential grey infrastructure solutions include aquifer recharge systems and rainwater catchment projects. These solutions allow water to be captured at 29

31 specific points in the hydrologic cycle to be applied where and when they are needed most. As with any alteration of the hydrologic cycle, the full impact of the solutions must be considered. For example, rain water catchment allows water to be stored for use during the drier season, but rain water is one of the sources of aquifer replenishment such that, if it is captured, aquifer recharge is reduced. However, these structural solutions can provide great benefit locally for farmers and households and can help measurably reduce groundwater pumping if applied at an appropriate scale. Green Infrastructure Green infrastructure relies on the ability of the natural environment to provide ecosystem services that grey, or built, infrastructure could provide. This includes filtration of pollutants, reduction of erosion, and limiting the impacts of floods and droughts. When deforestation and destruction of other natural vegetated areas occur, many of these natural services are lost. By investing in restoration of these habitats, the landscape can regain its ability to naturally regulate flows and soil erosion, at the same time providing other benefits such as restoring ecosystems and increasing carbon sequestration. General Mills has begun to invest in this green infrastructure through its reforestation program. The trees planted in the Lerma-Chapala watershed can help retain soils, increase infiltration of precipitation into the soil and aquifers below, and help return the local hydrology back to a more natural cycle. Although the General Mills reforestation program has provided huge benefits to the local environment, it could achieve even more by targeting its reforestation in areas that would benefit the most. For example, by mapping topography, land use and soil types, areas could be 30

32 selected where reforestation would provide the most soil retention and aquifer recharge benefits. This may require General Mills to create new partnerships based on the priority locations, but the additional effort would be worth the benefits it would reap. An example is the area of land adjacent to the preserve where General Mills has partnered to plant trees over the last three years. The contrast between the reforested section on the reserve and the bare land owned by a local ejido is visibly evident in terms of soil erosion. By partnering with the ejido, General Mills could expand its reforestation to this highly degraded area, reducing soil erosion and potentially increasing infiltration of water in this area. Convening Other Water Users Although General Mills can continue to take steps to improve its own water use efficiencies and invest in watershed projects, the real opportunity lies in taking this effort to scale by engaging other large water users in the region. One actor can only do so much, and if General Mills wants to reduce the water-related risks in this area, the company will need to partner and to lead others to action. General Mills is in a strong position to act as a leader in this capacity due to its reputation, size of operations, international reach, and its ability to offer up examples of successful implementation of water stewardship action already in place in the region. General Mills has existing connections with universities, government agencies, industry, irrigation districts, aquifer management groups and other important actors in the region that can help the company convene the appropriate group for large-scale water stewardship efforts. There is already a precedent for collaborative action around water resources in the region, with the COTAS focused on groundwater and the Lerma-Chapala River Basin Council focused on 31

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