June 2013 Update
An update on activities of the East San Joaquin Water Quality Coalition
Coalition Membership Jumps to 706,336 Acres
The "membership holiday" that was part of the new Waste Discharge Requirements (WDR) ended on May 13 and the results are in: total ESJWQC membership increased from 2,226 to 3,950 members while total acreage increased from 535,724 to 706,336 acres. As the numbers show, many of the new members are small to medium-sized operations (77% increase in members but only a 32% increase in total coalition acres). The question remains: how many more growers have not signed up who may either decide to get an individual WDR or join the coalition in coming months? Based on a letter mailed by the Regional Water Board in January to 4,000 landowners in Madera, Merced and Stanislaus counties (non-coalition members), there is still about 146,000 irrigated acres and 2400 landowners who did not respond. The Regional Water Board informed ESJWQC in early June that it was beginning to mail out 13267 Technical Information Request Orders on June 24. Those letters ask growers to decide within 14 days which approach they will take to get in compliance with the WDR requirements. If the 13267 order is ignored and a Notice of Violation is subsequently sent out, the State can issue an Administrative Civil Liability citation which carries a possible $1000-a-day fine. Growers who decide to join after the Water Board notification will be charged a $5 per acre initiation fee by the ESJWQC in addition to the 2013 dues of $4 per acre and $50 per membership.
Judge Rules on ILRP Lawsuit; Others Pending
A superior court judge overturned a lawsuit against the Irrigated Lands Regulatory Program Environmental Impact Report (EIR) filed in May 2012 by several watershed coalitions and activist groups. The judge reversed an earlier tentative ruling and found the EIR to be adequate for continuing the current program. The same EIR underpins the new Water Board regulations adopted in December 2012 for the ESJWQC. With that decision in place, the Regional Board is resuming the development of WDRs for the remaining six water quality coalitions in the Central Valley. The next vote on a WDR is tentatively scheduled for September 14, when a hearing is set in Fresno for the South San Joaquin Valley Water Quality Coalition. No other dates for votes have been finalized, although Regional Board staff has said it expects to complete all the WDRs by mid 2014, six months later than it had originally planned for completion.
The judge did not change his position on the State Water Board anti-degradation policy and the non-point source (NPS) policy compliance as it applies to the Regional Water Board's short term renewal. The Regional Board must show compliance with anti-degradation and the NPS policies for the other coalition WDRs yet to be adopted. No word yet from the State Water Board on its decision for separate petitions filed in January after the ESJWQC WDR was adopted in December 2012. No State Board action is expected before July or August.
Help in Testing Your Wells for Nitrates
Testing your irrigation or drinking water well for nitrates is not a requirement of the new WDR. However, the ESJWQC Board of Directors recommends that all coalition members test their wells for nitrates. Two important reasons: 1) Sampling of groundwater by State and Federal agencies in our coalition region over the last 10 years found a high percentage of wells above the drinking water standard for nitrates (10 mg/l as N); and 2) If an irrigation well has nitrate levels above 2.5 mg/l, the nitrate in the water should be considered in your annual nitrogen fertilizer budget for a crop. For example, if a well test results show 12 mg/l nitrate, a grower who uses three acre/feet of water per acre each season is applying the equivalent of 100 units of nitrogen in that irrigation water each season. Even if plant uptake is only 50% efficient, that is 50 lbs/acre of nitrogen that does not need to be bought and applied.
The coalition recently requested information from dozens of Central Valley laboratories asking about the cost for well-testing and water analysis for our members. A list of vendors who provide this service is enclosed with this newsletter or can be found at http://www.esjcoalition.org/wellTesting.pdf. Tell them the ESJWQC sent you.
Coalition to Facilitate Water Sampling and Analysis
Over the next year, the ESJWQC is committed to assisting members interested in testing their own wells for nitrates or hiring firms to perform the sampling and analysis. As a first step, we contacted numerous laboratories to gather basic information about the firms (see enclosed list) and price ranges for various services. The firms come in various forms: consulting firms specializing in geology or engineering that offer additional groundwater mapping services; those specializing in agricultural consulting offering advice on nitrogen budgets, plant tissue testing and soil nutrient management services.
ESJWQC is looking into ways for members to save money by coordinating well-sampling. For both water-sampling and analysis, better rates can be negotiated with a laboratory if there are pre-set pick-up and drop-off points for the bottles. For instance, 50 or 100 coalition members in one area agreeing to cooperate could negotiate a much better deal than an individual operation. Watch for updates on this effort in the coming months. Let us know if you are interested in participating by sending us an email at http://www.esjcoalition.org/contact.asp.
Costs Vary for Sampling Services
How much does it cost to do a nitrate analysis on a water sample? Like everything, it depends. A basic analysis for nitrate can range from $6 to $65 per sample, depending on the lab. Independent consulting firms and full-service laboratories can charge from $45-$250 per well or have daily rates of $1000 per day; or $50 to $75 per hour including travel time. Many laboratories will provide bottles and sampling instructions so growers can easily sample their own wells and deliver the bottles themselves to the laboratory.
Template Development Continues
The Water Board recently responded to the first attempt by agricultural interests in the Central Valley to create templates for the farm evaluation, nitrogen management plan and sediment and erosion control plans. These three plans are part of the new program requirements. Templates for the plans were submitted to the Water Board on April 11 with comments received back on June 14. Discussions will continue this summer to refine the templates with the finalized version expected by early September. Later this Fall, all members will receive the template plans either via mail or through the coalition website. The deadline for returning the farm evaluation and the nitrogen plan will be 2014; the sediment erosion control plans will remain on the farm.
2013 Coalition Board of Directors
East San Joaquin Water Quality Coalition contacts: