Eastern San Joaquin River Watershed Draft Agricultural Order Open for Comment

The California State Water Board is accepting comment on a second draft of the agricultural order for the Eastern San Joaquin River Watershed through Friday, December 22, 2017, at noon. 
CCOF strongly encourages organic growers from all regions of California to comment because this order will likely be replicated throughout the state. The requirements in the order could have significant costs and impacts for all growers because they will be required to report a large amount of detailed information annually, including data on nitrogen applications and crop yields.
What Is an Agricultural Order?
California’s Irrigated Lands Regulatory Program (ILRP) regulates discharges from irrigated agricultural lands statewide. Each of the state’s nine regional water quality control boards are responsible for implementing Waste Discharge Requirements for their regions. These requirements are issued as Agricultural Orders that must be followed by commercial irrigated agricultural producers, under threat of fines and other penalties. Most commercially farmed irrigated land falls under an agricultural order unless the land is covered under the Dairy Program.
Growers have a choice to enroll in the ILRP as an individual grower or to join a coalition group that performs the required monitoring and technical reporting to the regional water board. Whether as an individual or a coalition member, growers must pay fees to enroll in the program.
Additional information is posted on the California Water Board’s website. This page includes links to region-specific information on ILRP.
Requirements in the Draft Eastern San Joaquin River Watershed Agricultural Order
This draft order requires commercial irrigated farms to prepare an annual certified Irrigation and Nitrogen Management Plan that includes description of all irrigation and nitrogen (N) management practices; levels of residual N in the soil and in irrigation water; acreage of each field; projected yields from each field; actual primary and secondary crop harvest yield; N applied through irrigation water and amendments; and other details.
The coalition group will be required to use the N application and harvest data to calculate a multi-year A/R ratio—N applied (A) over N removed (R) —for each field. These ratios will be used to detect farms that are not applying N efficiently, which may result in regulatory action.
Additionally, all farms will likely be required to annually sample all on-farm drinking water wells for nitrate levels. 
Submit a Comment
CCOF encourages organic growers to submit comments on the draft order explaining how the reporting requirements will impact their operations. Specifically, organic growers should explain why reporting nitrogen and yield for each crop grown will be overly burdensome for highly diversified farms, especially farmers who grow multiple plantings for timely farmers’ market and CSA share harvests. 
Comments are due by noon on Friday, December 22, 2017. Submit comments via email or postal mail addressed to:  
Ms. Jeanine Townsend 
Clerk to the Board State Water Resources Control Board 
P.O. Box 100 
Sacramento, CA 95812-0100
For more information or help submitting a comment, contact policy@ccof.org.