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Central Coast water regulation raises concerns

Issue Date: February 3, 2021
By Christine Souza

Farm groups say a proposed regulatory permit known as the Irrigated Lands Regulatory Program for Central Coast agriculture, which regulates waste discharge from irrigated lands throughout the Central Coast, would make it more difficult for farmers to achieve the desired results, while harming the region's agricultural economy.

The Central Coast Regional Water Quality Control Board posted revisions to the draft program last week. Known informally as Ag Order 4.0, it expands monitoring and reporting requirements and also sets a limit on the amount of nitrogen farmers can apply to crops.

Agricultural groups expressed disappointment regarding the revisions to the draft Ag Order 4.0, because it no longer contains incentives for individual farmers who take a collective or third-party approach to meeting the regulations.

California Farm Bureau Senior Counsel Kari Fisher said farm groups spent months putting together "a robust, third-party alternative" that would protect surface water and groundwater quality.

"However, disappointingly, the revised Ag Order 4.0 does not include the agricultural organizations' full alternative proposal," Fisher said.

Use of third-party groups would be beneficial, she said, "because collectively, they can digest what needs to be done on the ground and then provide education and outreach to the farmers."

"The revised draft released last week is very complicated," Fisher said. "An individual farmer couldn't read it once and know everything you need to do to comply."

Monterey County Farm Bureau Executive Director Norm Groot said farm organizations came together to develop an alternative, viable water-quality program that was achievable and offered real solutions without putting farmers out of business.

The alternative proposed by agricultural groups suggested farmers work collectively on groundwater basins and watersheds, and take extra measures to protect water quality. Rather than being regulated as individuals, farmers would be regulated collectively by completing the additional measures.

"The regional water board has taken a pathway to compliance that is punitive, costly and agronomically unachievable, and moreover, removes incentives for the collective compliance options that offer the best chance for water-quality improvements," Groot said.

Agricultural organizations that came together to develop the alternative included the Monterey County Farm Bureau, California Farm Bureau, Grower-Shipper Association of Central California, Central Coast Groundwater Coalition, Grower-Shipper Association of San Luis Obispo and Santa Barbara Counties, and Western Growers.

Farmer Dirk Giannini, a Monterey County Farm Bureau director, described the revised order as "so detailed and there is so much reporting, we would spend too much time reporting and not enough time doing actual beneficial practices to improve water quality."

In addition, he said, the regional board's decision to remove incentives for farmers who use a third-party approach is disappointing.

"Farmers like to coalition together and roll up our sleeves and get it done as a group," Giannini said.

The 2018 adoption of the East San Joaquin Order by the State Water Resources Control Board, which added layers of reporting requirements, set precedents for other irrigated-lands water-quality programs in the state, including the Central Coast region.

But the Central Coast order includes new requirements beyond those in the East San Joaquin Order, including a method of accounting for the amount of nitrogen applied and nitrogen discharged into watersheds. In Ag Order 4.0, the regional board has set a discharge cap of 50 pounds of nitrogen per acre, per year, which farm groups say is low for the number of crops grown in the region.

The regional board target of 50 pounds of discharged nitrogen per acre, Groot said, is problematic from an agronomic standpoint and would affect yield and quality.

"As the regulatory limits ratchet down over each successive year, there will be impacts to yield and quality that will be detrimental to market pricing for the product and renewal of sales contracts, so that many current crops produced may not be agronomically viable in future years," he said. "This would waste one of the best growing regions in the world for leafy greens, vegetables and berry crops."

The coalition of farm groups is currently assembling an alternative plan to present to the board.

In addition to agronomic impacts, Groot said, there would also be a financial toll on farmers from the new regulations.

"Compliance is becoming much more of a budgetary line item that impacts the already tight bottom line," he said, "particularly for the small farming operations that need to hire technical experts to complete their annual compliance reporting and nitrogen calculations. The economics of farming along the Central Coast will be seriously damaged by the adoption of these unrealistic regulatory requirements."

The regional board, Fisher said, has the ability to revise the order based on the comments it receives.

"This is the last opportunity for farmers and ranchers to submit comments on a permit that has fundamentally different requirements than other permits throughout the state," she said. "Central Coast growers are used to a five-year permit, and this permit would be in effect indefinitely."

Written comments on the draft Ag Order 4.0 are due Feb. 25, and may be submitted via email to with either "Comments on Draft EIR" or "Comments on Draft Ag Order" in the subject line.

The regional board has a court-imposed deadline to adopt the regulation by April 16.

(Christine Souza is an assistant editor of Ag Alert. She may be contacted at

Permission for use is granted, however, credit must be made to the California Farm Bureau Federation when reprinting this item.

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