The Irrigated Lands Regulatory Program (ILRP) has undergone an important shift in how it regulates almond growers, with the program expanding to include groundwater protection. Because it is too expensive and not scientifically valid to monitor groundwater quality as a measure of growers’ efforts to protect groundwater, the program instead focuses on assessing what practices growers are using to protect ground and surface water.
What does that mean for growers? “Growers will be expected to write down what they are doing in terms of nitrogen management, assessing all the ways their operations could affect ground and surface waters, and what practices are in place to protect both,” says Gabriele Ludwig, associate director, Environmental Affairs, Almond Board of California.
Growers currently have an opportunity to provide written comments by Aug. 16 to the Central Valley Regional Water Quality Control Board on draft templates submitted by the East San Joaquin Water Quality Coalition. The templates include a Farm Evaluation, Nitrogen Management Plan, Nitrogen Management Plan Summary Report, and Sediment and Erosion Control Plan. The templates were developed through collaboration by various irrigated lands coalitions in the Central Valley with agricultural stakeholders.
While these templates were drafted for the East San Joaquin Valley Coalition, the Central Valley Regional Water Board has made it clear it expects to use the same templates for all the ILRP Coalitions in the Central Valley. The raw data will go to a local coalition, which has the task of collating the data before sending it to the Board. The data will be reviewable by the Central Valley Board, but raw data will not be sent to the Board. Growers will be expected to maintain copies on file for review on demand by the regulators.
“Growers will be regulated based on the practices they employ once there is a clearer sense of which practices are protective,” Ludwig notes. “So, it is critical that growers in the Central Valley review the draft templates for the Nitrogen Management Plans, the Farm Evaluation, and the Sediment and Erosion Control Plans.”
As they review the proposed templates, growers should consider key questions such as:
- What doesn’t make sense or is unclear?
- Do the questions make sense for annual crops that are rotated?
- How much time will it take to do these assessments — the first time and subsequent times?
- How will the plans work for larger operations; for smaller operations?
- Are there simpler ways to assess what measures growers are taking to reduce possible impacts on ground and surface water?
Comments on the draft templates must be submitted by Aug. 16 to be considered prior to the executive officer’s determination as to whether the templates meet applicable requirements. Comments may be submitted to Jelena Hartman by email or hard copy to: Attn: Dr. Jelena Hartman, Central Valley Regional Water Quality Control Board, 11020 Sun Center Drive, #200, Rancho Cordova, CA 95670-6114.