Submit Comments to Central Coast Regional Water Board on ILRP Ag Order 4.0 Development
We encourage our San Luis Obispo County Farm Bureau members to provide written comments prior to the deadline of
8:00 a.m., Tuesday, January 22, 2019.
- James Green, Government Affairs Specialist
November 19, 2018, the Central Coast Regional Water Quality Control Board issued a Notice of Written Public Comment Period For Ag Order 4.0 Conceptual Regulatory Requirement Options. As part of this Notice, the Central Coast Water Board included 5 Tables that outline options that Water Board staff will be proposing to Central Coast Water Board members for their consideration at the upcoming March 21 and 22, 2019 public hearing.
The requirements outlined in the options tables address five agricultural-related water quality issues: 1) nitrate loading to groundwater, 2) nutrient loading to surface water, 3) pesticide discharges to surface water and groundwater, 4) sediment discharges to surface water, and 5) the protection of riparian habitat.
The conceptual regulatory requirement options would impose significant burdensome and improper requirements, including: numeric (discharge and application) limits for nitrogen applications, nitrogen discharges to groundwater, nutrient discharges to surface water, pesticide discharges to surface water, sediment discharges to surface water, and riparian setback width and percent vegetative cover, as well as individual discharge groundwater monitoring if a ranch exceeds a numeric discharge limit. All farms, including organic farms and Sustainability in Practice Certified farms, must comply with these new regulatory requirement options regardless of risk to surface or groundwater.
Given the impact of the concepts proposed by staff, it is important to have a strong agricultural response. We strongly encourage you to provide written comments prior to the deadline of 8:00 a.m., Tuesday, January 22, 2019. Please send written comments to AgNOI@waterboards.ca.gov and indicate in the subject line, “Comments to Ag Order 4.0 Options Tables.” For full details of the Central Coast Water Board’s proposed options, as well as submission information, click here.
Comments that are personalized with your specific issues rather than the template letter will be given greater consideration. To aid in drafting your personal letter, consider the following questions and add your answers to the letter:
1) The options tables propose numeric discharge limits for nitrate, ammonia, orthophosphate, turbidity, pesticides, and riparian buffer setbacks/native vegetative cover. How difficult would it be to comply with the numeric limits?
2) How would compliance with numeric limitations impact the economic viability of your operation? Would adoption of numeric limits impact your ability to continue farming in the Central Coast region?
3) The options tables improperly propose prohibitions on the use of fertilizers and pesticides As a Grower, what would it mean to the viability of your operation if the Central Coast Water Board limited the amount of fertilizer or pesticides that you could apply, regardless of weather and other factors? What are you doing now to manage fertilizer and pesticide use efficiently? How do you already factor in potential impacts to water quality in your decision-making process as it relates to fertilizer and pesticide applications?
4) Coefficients for Removed Nitrogen are not available for many Central Coast crops. Growers should consider commenting on the need for more resources to invest in necessary research for developing Central Coast specific coefficients.
5) To implement the individual surface water and groundwater discharge monitoring requirements, what would this mean to you? How challenging would this be? How much would it cost?
Please see the attached document to review the proposed regulatory options and for more information on how the draft options will impact farmers and ranchers.
Link to Public Notice and Regulatory Options Table:
