CSPA and San Francisco Baykeeper file scoping comments on the Long Term Irrigated Lands Program

By Jerry Neuburger

May 30, 2008. The California Sportfishing Protection Alliance and San Francisco Baykeeper (CSPA/Baykeeper) filed scoping comments today with the Central Valley Region of the California Regional Water Quality Control Board regarding the Long-term Irrigated Lands Regulatory Program and Associated Programmatic Environmental Impact Report.

In examining earlier CSPA comments filed in 2006, the State Board found the program so deficient that a ten-point list was included in their response. The staff review found that: 1) discharges from irrigated lands have violated water quality standards, 2) coalitions have failed to comply with conditions 2 of the waiver, 3) the Regional Board cannot or will not enforce fundamental waiver conditions, 4) The monitoring and reporting program is deficient, 5) the waivers lack specific time schedules for key elements of the program, 6) waiver conditions do not ensure pollution reductions by individual farms, 7) the size of coalitions is unmanageable, 8) the waiver should address groundwater protection, 9) the waiver is not consistent with the state’s Non-point Source Program and 10) the waiver should be remanded to the Regional Board to include specific recommendations made by staff.

In addition to remedying the above problems, the two organizations recommendations to the board included that the Environmental Impact Report (EIR) for the program include irrigation, crops, discharge runoff and pollutants from farms, identify discharge points, identify endangered and other pelagic species. In addition, the plan must protect groundwater sources from pollution and monitor it regularly.

Bill Jennings, Executive Director of the CSPA summed up, “In closing, the Regional Board cannot document any quantifiable improvement in water quality that has occurred as a result of the irrigated lands program. It cannot point to a single specific BMP that has been implemented or any resulting reduction in localized pollutant loading or improvement in water quality. It cannot identify the locations of critical habitat or sensitive biological life, the proximity of discharges, the specific type or volume of pollutants being discharged or the potential adverse effects of those discharges on sensitive habitat and species. Without this basic information, there is no way an EIR or Program purporting to regulate discharges from irrigated agriculture can establish an adequate baseline to evaluate any regulatory program."