Released March 4, 2011 - Long Term Irrigated Lands Regulatory Program Framework

This proposal is going before the Regional Water Quality Control Board on April 7, 2011

San Joaquin County and Delta Water Quality Coalition's Comments on LTILRP Framework

The Central Valley Regional Water Quality Control Board has a Draft Program Environmental Impact Report for the Irrigated Land Regulatory Program.  Within this document the Regional Board evaluates different alternatives for a Irrigated Lands Regulatory Program (ILRP) and make a recommendation for a new long term program to be implemented in 2011.

Background

The current ILRP was initiated in 2003 with the adoption of Conditional Waiver of Waste Discharge Requirements for Discharges from Irrigated Lands within the Central Valley Region. A revised Conditional Waiver was adopted in July 2006, and a work group assembled to develop alternatives to the ILRP for environmental analysis.

Many interpret the word "waiver" as not having a regulatory program or not having to comply with water quality regulations, however this is incorrect.  A Conditional Waiver is a regulatory document that regulates what an entity can discharge into the waterways of California.  Waivers must be reviewed and adopted every 5 years.

After working with the current Irrigated Lands program over the past years, the Regional Board has determined changes need to be made in the program and the certain regulatory elements need to be added, including regulating groundwater.

Regional Board Staff Proposed New Program.

Within the Draft Environmental Impact Report, the Regional Board staff has a staff proposal which takes elements of the different alternatives and develops a new Irrigated Lands Regulatory Program.  This proposal includes the continuation of the current surface water program with some changes and a groundwater regulatory requirement. 

New Groundwater Program

The staff proposal includes a groundwater component where farmers must monitor the groundwater and determine if farming practices have an effect on groundwater quality.  Farmers would then have to implement management practices to prevent groundwater degradation and improve groundwater quality. 

Since groundwater monitoring and modeling is completely different than surface water monitoring, the San Joaquin County and Delta Water Quality Coalition has concerns about how this program will be implemented and the effect it will have on agriculture in the region. 

Overview of the Proposed Regulations

Issues of Concern with the proposed program

 The Draft EIR and Proposed program can be found on the Central Valley Regional Water Quality Control Board's website by following this link LTILRP.

The Regional Board's staff proposal for a new program is actually in Appendix A - Staff Report.  The main recommended program begins on page 142 of Appendix A.