Ag Order 4.0

Open for Comment | Ag Order 4.0 

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

This is an IMPORTANT time for growers to submit written comments to the staff and board for consideration in the next phase of the Order.

Comments Due: January 18, 2019 by NOON

Comments Submitted to: AgNOI@waterboards.ca.gov  {use "Comments to Ag Order 4.0 Options Table" in subject line}

Current Process:

  • Comment period on framework is open until January 18
  • Staff will provide recommendations to Board and Board will direct staff at March Board meeting (Mar 21, 22)
  • This will inform the development of a Draft Order to be completed by summer 2019

View the Current Proposed Framework from the Regional Board Website
 

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 that you incorporate as they relate to water quality - remember to include information on how you limit both INPUTS and TRANSPORT of various constituencies.

Groundwater

  • Include information on your typical nitrogen and irrigation applied to help staff and board ground truth your potential risk to groundwater
  • Include practices that relate to efficient application of nitrogen and water (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)
  • Charactize your practices that relate to efficient and targeted application of pesticide: IPM, monitoring, record keeping, cultural practices, biodiversity)
  • Characterize your safety practices that reduce off site movement of pesticides (calibration, containment, other safety measures)
  • Characterize your 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 what you do as it pertains to your SIP Certification and Water Quality
  • Merits and integrity of SIP
  • SIP requires and VERIFIES practices that protect water quality
  • Assurance that growers have practices in place that protect water quality
  • Regulatory relief is an incentive to participate in SIP Certified
  • Growers will be rewarded for their practices and investment in certification
  • Relief can come in the form of reduced reporting, perhaps integrating reporting with SIP Certified database
  • Reduces time required by RWQCB staff 
  • Reduces duplicative/overlapping reporting and regulatory requirements

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