ILRP Proposed Alternative Issues of Concern

1.  The tracking of nutrient applications and development of nutrient management plans. 

The new program would require farmers to keep detailed records of nutrient applications and provide that information to the Coalition.  It would also require nutrient management plans and the documentation of fertilization practices to prove excess nutrients are not being applied to the crops and thus leaching into the groundwater.

2.  The assumption that all irrigation causes the degradation of groundwater. 

The assumption in the new program that the act of irrigating a crop is considered a discharge to groundwater thus causing the degradation of groundwater is not provable or plausible in many areas of the State.  Many areas throughout the state are irrigated and do not discharge to groundwater or degrade groundwater.  

3.  Agriculture is assumed to cause degradation in both surface and groundwater regardless of soil or climatic conditions.

Growers must prove to the Regional Board that their operation does not degrade the groundwater to avoid these regulations.  It institutes a guilty until proven innocent in the regulation.  Doing studies to prove a farm does not discharge to the groundwater can be in the hundreds of thousands of dollars.

4.  Definition of groundwater to be protected.

Groundwater is defined as the first encountered groundwater.  The water will need to be protected even though there are areas where first encountered ground water is not and has never been usable water for drinking or agriculture use.  In the delta first encounter is at 12 inches in places.

5.  Duplication of Regulations.

The Regional Board proposes a new program to regulate groundwater when many programs already exist.  Many areas already have or are developing groundwater management plans that address water supply and quality at the local level.  Alternative 2 within the DPEIR was a more common sense approach using local agencies to address groundwater issues.  The Regional Board’s proposal does not address the complexity of groundwater.

6.  Review of management plans

Other interested parties would review and comment on all management plans developed by the coalition or growers