Central Coast Water Board Needs to Hear From You by January 22

The Central Coast Regional Water Quality Control Board is updating the agricultural order that regulates discharges from irrigated farmland. A comment period is now open with comments due by 8 a.m. on January 22, 2019.  
 
Submit comments to AgNOI@waterboards.ca.gov and indicate in the subject line “Comments to Ag Order 4.0 Options Tables.” Read the notice of public comment period.
 
The regional water board will accept comments on any topic related to the new version of the ag order. The board specifically requests comments on an “options table” that lays out existing and proposed options for phasing/prioritization, numeric limits, time schedule to achieve numeric limits, monitoring and reporting requirements, and incentives for five separate objectives.
 
Now is the time to help shape the discussion by placing organic on the radar of regional water board members. We expect that other opportunities for grower input will be offered as the process moves forward.
 
Because certified organic farms build soils high in organic matter that hold excess nutrients and must use biological sources of crop nutrients that are released slowly into soils, CCOF advocates that organic farms be included in a lower tier of regulation. The challenge is to develop rationale that is acceptable to the regional water board and language in the ag order that regulates organic farms only to the degree that they are sources of nitrate, nutrient, or sediment discharges.
 
CCOF will submit a comment to the water board and encourages certified organic farmers in the region to submit comments as well. Basic points to consider including in your comment are:
  • As certified organic producers, we are regulated under federal law and must document all our input applications including input type, application date, location, and rate.
  • We use fertilizers that break down slowly in soil and use no synthetic pesticides.
  • We grow a winter cover crop to absorb excess nitrogen (or list other management practices you use to minimize nitrate leaching and sediment loss).
  • We are inspected annually to verify we are following the rigorous federal organic standards.
  • Organic certification is a ranch characteristic that should place an operation at a lower tier of regulation because it poses a lower threat to ground and surface water contamination.
  • We encourage the regional water board to assemble an agricultural advisory group while developing Ag Order 4.0 that includes organic and conventional growers, Cooperative Extension and other specialists, and representatives of environmental groups.
 
To find out which water quality control region you are located in, refer to the Regional Water Boards Map.
 
For additional information, contact Jane Sooby, CCOF Senior Outreach & Policy Specialist, at jsooby@ccof.org or (831) 346-6239.

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