Ag Order 4.0

Open for Comment | Ag Order 4.0 

View the Current Proposal from the Regional Board Website

Staff released a Conceptual Framework for Ag Order 4.0. This framework has material differences from the current order and will affect vineyards.

  • It is IMPORTANT for growers to submit written comments to the staff and board for consideration in the next phase of the Order.
    • Comments Due: Tuesday, January 22, 2019 by 8:00 am
    • Comments Submitted to: AgNOI@waterboards.ca.gov  {use "Comments to Ag Order 4.0 Options Table" in subject line}

Current Timeline:

  • Comment period on framework is open until January 22, 2019
  • Staff will provide recommendations to Board and Board will direct staff at March 21-22 Board meeting 
  • Recommendations will inform the development of a Draft Order to be completed by summer 2019
     

Overview Key Points of the Current Framework:

Order addreses five water quality issues (see options table in staff report):

  1. Irrigation & Nutrient Management for Groundwater Protection
  2. Irrigation & Nutrient Management for Surface Water Protection
  3. Pesticide Management for Surface Water and Groundwater Protection
  4. Sediment and Erosion Management for Surface Water Protection
  5. Riparian Habitat Management for Water Quality Protection

Other key points:

  • Staff asserts that some elements of the proposal are required to be consistent with the East San Joaquin Order and Non Point Source Policy.  
  • Staff suggests there could be potential to delay monitoring and reporting based on the risk to water quality of an operation and/or proximity to impaired waterbodies. The specifics of if/how this would work has not been identified and is open for input.
  • Staff suggests that there are opportunities to include certifications to deprioritize operations and reduce regulatory reporting for certified operators. The specifics of if/how this would work has not been identified and is open for input.

Possible Talking Points for Comment Letters

Overview

Location, size, nature of your operation, and your experience.

Water Quality Related Practices

Practices you incorporate to protect water quality - remember to include information on how you limit both INPUTS and TRANSPORT of various constituencies. 

Groundwater

  • Typical nitrogen and irrigation applied to help staff and board ground truth your potential risk to groundwater
  • Efficient application of nitrogen and water practices (ex. nutrient budgeting, soil & petiole testing to minimize nitrogen application and improve efficiency by targeted timing, efficient irrigation applications to minimize movement of water beyond rootzone, deficit irrigations)

Surface Water (Runoff of Sediment, Pesticides, Nutrients)

  • Characterize the nature of surface water runoff (ex. stormwater)
  • Efficient and targeted application of pesticide practices (IPM, monitoring, record keeping, cultural practices, biodiversity)
  • Safety practices that reduce off site movement of pesticides (calibration, containment, other safety measures)
  • Soil and erosion control practices to reduce off site movement of soil and water from stormwater (cover crops, road management, buffer strips, etc)

SIP Certified (if applicable)

Be specific about how being SIP Certified protects water quality.

  • SIP Certified requires and VERIFIES implemented practices that protect water quality - this is superior to unverified self-reporting
  • Merits and integrity of SIP Certified (independent inspection, technical review, science based)
  • Regulatory relief is an incentive to participate in certification - growers will be rewarded for their practices and investment in certification
  • Certification reduces time required by RWQCB staff to verify practices
  • Certification reduces duplicative/overlapping reporting and regulatory requirements
  • Relief can come in the form of reduced reporting, perhaps integrating reporting with SIP Certified database

If you have any questions, please contact beth@vineyardteam.org.