The following information is provided as a service to VCAILG members.

VCAILG launches quarterly newsletter 
As a member of the agricultural community, you are all too familiar with the ever-changing and increasingly complex nature of regulatory programs, with the Irrigated Lands Regulatory Program being no different. To help growers stay connected with ongoing compliance activities that VCAILG is implementing on behalf of members, as well as new or upcoming regulatory developments, VCAILG is introducing a quarterly e-newsletter.

We will continue announcing education event opportunities and Conditional Waiver updates via email, but hope that this newsletter helps members stay informed about water quality issues and activities throughout the year.  As always, ensuring that member contact information is up-to-date with VCAILG is critical.  If you know someone who is not receiving VCAILG emails, or would like to add additional members of your team to our list, please reach out to us at vcailg@farmbureauvc.com.  
Wrapping up 2018 - a review of VCAILG activities
Each year since the beginning of the water quality monitoring program in 2007, VCAILG has collected and analyzed water samples from numerous agricultural sampling locations throughout Ventura County. The 2017-2018 monitoring program activities included sampling during two wet and two dry weather events, in addition to watershed specific Total Maximum Daily Load (TMDL) sampling activities. Due to the drought, as well as irrigation efficiency measures implemented by growers, there were no flows during dry weather in many of the agricultural drainages, resulting in fewer samples to be collected.  

In many drainage areas, water quality conditions remain similar to previous years, or are slowly improving. However, a few lower Calleguas Creek locations show increasing trends in nitrate, copper, and toxaphene, and will require special source investigation studies to determine the cause of these increasing pollutant loads, as mandated by the Conditional Waiver. A work plan for these source investigations was submitted to the Los Angeles Regional Water Quality Control Board (Regional Board) in October 2018, and will be implemented beginning in spring of this year.
In addition to surface water quality monitoring, new requirements included in the current Conditional Waiver require discharger groups to monitor and evaluate potential agricultural impacts to groundwater quality. To minimize cost to VCAILG members, and avoid duplicating work already being done by others, the assessment methodology developed to address this requirement utilizes existing monitoring data already being collected by other agencies, and identifies data points representative of groundwater conditions. The results of this assessment are detailed in VCAILG's  second Groundwater Quality Trends Annual Monitoring Report, submitted in December 2018.    Other compliance reports submitted in December 2018 include the 2017-2018 Annual Monitoring Report and Water Quality Management Plan.  Drafts of  these reports and plans are awaiting approval from the Regional Board, and will be available on VCAILG's website once they are approved.
Nitrogen management plans roll out
W e are now just over halfway through the third term of the Conditional Waiver, adopted in April 2016 and set to expire in April 2021.   Each new term builds upon the last, and adds new requirements aimed at improving water quality and advancing progress towards meeting regulatory standards.

While many of the on-farm Best Management Practices (BMPs) have resulted in water quality improvements over the years, nitrate levels in irrigation and stormwater runoff continue to be an issue in many areas, particularly those dominated by row crops or berries.   

One of the most significant additions to the current Conditional Waiver is the requirement for growers in Responsibility Areas associated with nitrogen water quality exceedances to develop and implement site-specific Certified Nitrogen Management Plans for their farms.  The purpose of these plans is to leverage best available research for crop-specific nitrogen demand, and apply the concepts of the 4Rs: right time, right place, right source, and right rate.   The plan itself is a single-page worksheet, completed annually for each farm unit, which guides a grower through calculating total nitrogen needed for each crop.   The process also identifies nitrogen contributions from sometimes overlooked sources, such as irrigation water or carryover in soil, and then prescribes an amount of supplemental fertilizer required to meet crop demands.

When implemented effectively, these plans will minimize the over application of nitrogen fertilizers and prevent leeching into groundwater or off-site mobilization of nitrogen in irrigation tailwater and stormwater flows.  The research behind crop nitrogen demand continues to grow and evolve, but the primary objective in this early stage of the program is to familiarize growers with the process of developing a nitrogen budget and the available resources specific to their crop.

To ensure that the plan is developed by a qualified individual, the Conditional Waiver requires certification through one of the three mechanisms listed below.  
  1. Self-certified by a grower who attends a California Department of Food and Agriculture Fertilizer Research and Education Program (CDFA FREP) training program.
  2. Self-certified by a grower to adhere to site-specific recommendations from the Natural Resource Conservation Center (NRCS).
  3. Certified by a Certified Crop Advisor (CCA) or s Technical Service Provider certified in nutrient management by NRCS.
To provide growers with the opportunity to become self-certified, VCAILG has collaborated with CDFA FREP, the University of California Cooperative Extension (UCCE), and Fruit Growers Laboratory to develop a local curriculum based on an existing self-certification program developed for growers in California's Central Valley.  The training itself includes a 3 1/2 hour  workshop focused on the basics of the nitrogen cycle, irrigation and nutrient management, and nitrogen budgeting, followed by a 30 question, multiple-choice exam. VCAILG has offered two of these training workshops to date (Oct. 2, 2018, and Jan. 24, 2019) and will continue  over the next few years. The next workshop is tentatively planned for late summer of this year. 

Once a grower completes the self-certification training program and passes the exam, he or she needs to complete seven hours of approved continuing education every three years to maintain the certification. The training program itself accounts for four hours of education credit, leaving  three additional credit hours required to be completed during the first three-year period. The Conditional Waiver's  existing requirement for growers to attend two hours of continuing education per year does still apply, but an approved class or event can be leveraged to meet both requirements, so long as it has a nitrogen focus. Any continuing education courses that qualify for both VCAILG and nitrogen management plan self-certification requirements will be advertised as such.

Some of the most common questions asked by growers relate to whether these requirements apply to them, and if so, by which date they have to be implemented.  The current Conditional Waiver specifies that growers located in Responsibility Areas with water quality exceedances of nitrogen standards are required to develop a Nitrogen Management Plan. In addition, a plan is also required in areas where watershed-specific TMDL regulations require implementation as a means to address waterbody impairments. Growers in Responsibility Areas that have neither benchmark exceedances for nitrogen nor TMDL-specific requirements will not be required to develop a plan within the current Conditional Waiver term.  

The requirement applies first to growers in the Ventura River Watershed (RAs 18 and 20), with an implementation date of January 2019.   This date is based on watershed-specific requirements listed in the Ventura River Algae TMDL, a regulatory plan adopted by the Regional Board to address excessive algae growth in the river by reducing nitrogen loads in runoff. Following this date, the implementation schedule for the remaining Responsibility Areas requiring plans will be phased in according to the degree of water quality benchmark exceedance. Areas with more significant nitrogen impairments will require plans earlier.

The map and table below summarize these dates by Responsibility Area. More detailed maps can be found on VCAILG's Water Quality web page and a list of assigned ResponsibilityArea by Assessor Parcel Number (APN) can be downloaded here



Responsibility Area
Nitrogen Management Plan Completion Date
18,20
January 2019
1, 2, 3, 5, 10
September 2019
4, 6
January 2020
12, 13
April 2020
7, 8, 9, 11, 14, 15, 16, 17, 19
Not required at this time  
(will be required in next Conditional Waiver term)

Finally, it's important to mention again that while the current implementation schedule only applies to specific Responsibility Areas, these requirements are expected to expand to all agricultural operations during the next Conditional Waiver term.   This is due to the State Water Resources Control Board's recent issuance of the East San Joaquin River Watershed Waste Discharge Requirements, which included precedential requirements applying to Irrigated Lands Regulatory Programs across the state.  These precedential requirements, which include the development of irrigation and nitrogen management plans for all agricultural operations, are the State Board's mechanism for directing the nine regional boards to incorporate these requirements into their next regulatory orders.   

While these requirements are already being implemented to some degree in many water board regions, such as the Central Coast, Central Valley, and now Los Angeles regions, the State Board's directive will create statewide consistency throughout the various Irrigated Lands Regulatory Programs.  What that means for growers in Ventura County is that we can expect the Los Angeles Regional Water Quality Control Board to expand nitrogen management plan requirements to apply to all growers when the Conditional Waiver is next renewed in 2021.  

As always, VCAILG will keep growers informed of any new regulatory developments as we get closer to the Conditional Waiver renewal date.   For more information about the Nitrogen Management Plan requirement and resources for developing a plan, please visit VCAILG's Water Quality web page.

Watch for VCAILG e-mails and visit the Education page to stay informed as education opportunities are scheduled, confirmed and/or updated. 

Contact information
If you have questions, contact: 
 
Jodi Switzer or  Griselda Barrera (habla EspaƱol)
Email: vcailg@farmbureauvc.com 
Phone: (805) 289-0155
Background on the Conditional Waiver
In April 2016, the Los Angeles Regional Water Quality Control Board adopted a  Conditional Waiver of Waste Discharge Requirements for Irrigated Agricultural Lands, which will be in effect until April 14, 2021.  Education is a cornerstone of the Ag Waiver program. All owners or operators of irrigated agricultural lands are required to attend at least 2 hours of water quality education annually. One of VCAILG's primary responsibilities is to connect our members with educational opportunities and to report member attendance to the Los Angeles Regional Water Quality Control Board. 

To better coordinate and offer a wider range of classes/trainings/workshops/events, an Education page on the Farm Bureau website lists all approved and planned education opportunities. The  Education page will be updated regularly when registrations open, new classes become available, and locations, dates and times are confirmed. Please use this one-stop tool to plan which classes best meet your and your staff's educational needs. As listed on the page, you will find that a number of regular workshops hosted by University of California Cooperative Extension and other partners will now provide VCAILG education credit. 
 
Although joining VCAILG is voluntary for Ventura County commercial farmers, compliance with the Conditional Waiver is mandated by the state, which can fine property owners who don't comply.  If you do not join VCAILG, you may alternately choose to file as an individual and work directly with the Regional Board (contact Snejana Toneva at (213) 576-7159 or snejana.toneva@waterboards.ca.gov ) to fulfill the Conditional Waiver requirements. 
 
In 2006, VCAILG was established to help you and your fellow growers and/or landowners comply with this regulatory program in the most cost-effective way. Managed by Farm Bureau of Ventura County, VCAILG helps you comply with the regulations by conducting water-quality monitoring on your behalf, contracting with labs and field crews, and preparing and submitting all required documents and reports. Your compliance cost is reduced by sharing program expenses with other members. Although your annual program assessment still represents a significant business expense, we have calculated that it would cost you more than 60 times as much to comply as an individual.

If you appreciate the cost-saving service Farm Bureau provides you through its management of the VCAILG program, we encourage you to become a dues-paying member of the organization. You can learn more about our many other programs, services and activities on our website. To learn more about joining Farm Bureau, contact membership coordinator Cheri Iadevaia at (805) 289-0155 or cheri@farmbureauvc.com
VCAILG Steering Committee
Edgar Terry, Chairman I Jason Vis I Jonathan Chase I Robert Crudup 
Paul DeBusschere I Mike Friel I Jurgen Gramckow I Gus Gunderson
John Mathews I Doug O'Hara I Kelle Pistone I Rob Roy I Jared Bouchard 
Craig Underwood I John Krist
Staff
Griselda Barrera I Jodi Switzer I Ashli Desai I Amy Storm
VCAILG | (805) 289-0155 | 5156 McGrath St., Ste. 102 | Ventura | CA | 93003
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