TMDL Voluntary Compliance Program
Since implementation, the Farm Bureau’s TMDL program has prevented more than 33,000 tons of silt from entering the New and Alamo Rivers, achieving the goal for the New River within three years. The program has seen a significant reduction at the Alamo River well ahead of the 12-year implementation schedule.
The TMDL program is voluntary, however nearly all farmers in Imperial Valley participate in the program because it offers growers and landowners a straightforward path to compliance with the mandatory TMDL regulation. Farmers implement a variety of Best Management Practices (BMPs) to reduce silt and mineral runoff on their own farms, and maintain a record of their efforts, and attend annual meetings to keep up-to-date and share information relating to BMPs and TMDL management on their farms.
For more information about the TMDL program, contact Linsey Dale, Executive Director at Imperial County Farm Bureau – 760-352-3831or .
Facts about TMDLs
A Defense Against TMDLs
In 2000, the Regional Water Quality Board (RWQCB) developed a Total Maximum Daily Load (TMDL) for Imperial Valley Waterways. A TMDL is a regulation limiting the amount of a pollutant which can be released into a water body. This TMDL requires agricultural discharges to reduce the amount of substances such as silt and nutrients that leave their fields. TMDLs have had a huge impact on Imperial Valley agriculture and why the Imperial County Farm Bureau developed a voluntary compliance program to help defend growers from the onslaught of TMDLs.
The ICFB Voluntary TMDL Compliance Program is based on the California Farm Bureau Federation (CFBF) Non-Profit Source Initiative which was developed to provide guidance to county Farm Bureaus operating under the threat of non-point source (NPS) regulation. The CFBF initiative acknowledges agriculture responsibility as a NPS contributor and enlists the practical genius of each farmer to reduce the impacts that they have on water quality. The goal of the CFBF initiative is to maintain the flexibility of individual agriculture operations, avoid prescriptive regulation, and enable agricultural entities to meet the pollutant load allocations imposed by TMDLs.
How it Works
Participating growers will be organized into one of ten working group that will pool their farming experiences to develop feasible methods of controlling pollutant runoff. Each individual will then prepare a plan for their own farming operations, implements the plan, and monitors the results. Being organized into groups provides an organizational structure that enables ICFB to maintain the anonymity of individual growers through a region-wide monitoring and reporting program. Protecting individual operations from the scrutiny of the RWQCB is a major priority of the ICFB Program.
The RWQCB has agreed to grant temporary immunity to growers who participate in the ICFB Program. Growers who elect to participate will register with the ICFB Voluntary TMDL Compliance Program and have their name submitted to the RWQCB. They are then free from further enforcement action from the RWQCB. They will, however, be accountable to ICFB and required to follow through with their commitment to cooperate.
As distasteful as cooperating with another regulatory program may seem the alternative is even more grim. Growers who choose not to participate in the ICFB Program will be contacted by the RWQCB and required to submit a water quality management plan, an implementation scheduled proof of implementation, and monitoring results directly to the RWQCB. Another downside to individual compliance is the lack of privacy it provides- a primary objective of the ICFB Program. To top it off, growers who go it alone will be at the head of the list when it comes to RWQCB enforcement actions.
The Best Defense: A Good Offense
It is unrealistic to believe that TMDL regulations will disappear or that the Imperial Valley growers will become exempt from regulation due to the unique conditions that exist here. The ICFB Voluntary TMDL Compliance Program is the Imperial Valley grower's best offense against TMDLs.
For more information, please visit the TMDL website at: www.ivtmdl.com
or contact at 760.352.3831