IVILC Program Background

As of December 2021, irrigated agriculture in the Imperial Valley is now under a General Order. The IID-ICFB Coalition which has managed the program since 2015 has continued to do so and will work to assist growers with reporting in order to remain in compliance. You will notice that we have renamed the coalition to Imperial Valley Irrigated Lands Coalition (IVILC) to make it more fitting to the current program.

 

The new General Order expands its reach beyond drain and surface water sampling and reporting of BMPs to reduce silt and sediment to include groundwater protection and monitoring, and reporting of nitrogen fertilizer applications.

 

Transitioning from TMDL to the New General Waste Discharge Requirements

Membership in the Imperial Valley Irrigated Lands Coalition enables growers and landowners to be in compliance with the new General Order requirements. IVILC has also contracted with MLJ Consulting in order to provide a seamless transition for Imperial Valley farmers. MLJ Consulting has extensive experience in working with irrigated land coalitions including in a technical and environmental capacity, through the regulatory process, as well as designing and managing member portals. All reporting, as of last year, will be completed on the new website, ivilcportal.com, which was rolled out in the fall of 2022. The September 1st TMDL reporting deadline is no longer in place. Farm Plan and Nitrogen Management Plans will be due January 31st of each year. Your next reporting deadline will be January 31, 2024 for all crops harvested in 2023.

In an effort to keep costs to farmers and landowners to a minimum, ICFB will continue working with Imperial Irrigation District (IID) staff on collection activities to qualify under the Tier I pricing. As noted in the California Code of Regulations, Tier I states if a discharger is a member of a group that has been approved by the state board to manage fee collection and payment, then the fee shall be $100 per group plus $1.42 per acre of land for the 2023-2024 year.

 

IID has agreed to continue to collect the annually state-mandated fee on our behalf. The current rate per acre is based on IID Water Availability acreage. Once the established payment deadline is reached, IID will forward one collective payment on behalf of the landowners to the State. The fee collection schedule will remain the same and you will be receiving a bill for 2023 in early December which will be due December 31st.

 

An ICFB Agricultural Membership is also required for participation in the coalition. If you do not have a current ICFB membership, please visit our website at www.icfb.net, call our office at 760- 352-3831, or email gisselle@icfb.net  for further details on becoming a member.

 

To summarize, the following is required to be a participant of the coalition:

• Payment of the annual state-mandated fee

• Annual submission of Regional Water Quality Control Board reporting requirements at ivilcportal.com

• Current Imperial County Farm Bureau Agricultural Membership

 

All commercial irrigated agriculture in the Imperial Valley is subject to these requirements. There is not minimum acreage. Unlike the previous TMDL Program that required non-commercial irrigated agriculture land to be in the program, the new program is for commercial irrigated agriculture only. Commercial irrigated agriculture is defined in the General Order as owners/operators of irrigated land who:

 

• Have a pesticide permit

• File IRS Schedule 1040 F or,

• Sell directly i.e., farmer markets or direct-to-consumer

 

Nitrogen Fertilizer Reporting

The requirement to report nitrogen fertilizers applied to crops originated in the Central Valley. The General Waste Discharge Requirements adopted in the San Joaquin Valley included application reporting requirements for parcels in basins described as high vulnerability to groundwater contamination. Certain requirements, including this one, were considered to be precedential. This is now required in all General Waste Discharge Requirements moving forward for the entire state. ICFB advocated heavily against this and other components of the Order, with no success.

 

The first INMP Summary Reports will be due with the upcoming 2023 reporting. In addition to the irrigation and nitrogen management practices that are already reported on the Farm Plan, the INMP Summary Report will include the amount of nitrogen applied and yield harvested for each Management Unit. Nitrogen amounts will include any dry or liquid fertilizer applications, as well as any nitrogen applied through irrigation water, organic amendments, or foliar treatments. The Coalition will use the yield reported to estimate the amount of nitrogen removed from the field at harvest.

 

Groundwater Trend Monitoring

Although the Imperial Valley does not use groundwater for farming purposes, we are being held to these reporting requirements because, as previously mentioned, they are considered precedential by the State Water Resources Control Board. A network of wells will need to be established throughout the Valley to track water quality and comply with the requirements. We are hopeful that we can establish a well network using existing wells or identify potential partners if we are required to construct new wells. We have been given an extension for groundwater trend monitoring and will not be having to report that for this year.

 

Program Education and Outreach

The Imperial Valley Irrigated Lands Coalition will hold a series of grower outreach meetings to cover the irrigated lands program. The meetings will cover the additional requirements for this year, information on nitrogen reporting, updates to the IVILC reporting website, and more. We are also always available for phone assistance as well.

Dates for the grower outreach meetings are:

 

November 6, 2024

9:00 am at Stockmen’s Club in Brawley

2:00 pm at Farm Credit West in Imperial

 

November 7, 2024

Virtually via Zoom

Registration links will be sent via email

 

Who should attend?

Growers, CCAs, and Office staff who will be assisting with reporting

 

Imperial Irrigated Lands Coalition Non-Members

If a grower is not a member of the Imperial County Farm Bureau and thus not a member of IVILC, they have another option: file for an individual operation permit that includes setting up farm-specific monitoring plans and preparing detailed technical reports on potential discharges to surface water and groundwater specific to each field. Nitrogen fertilizer application reporting is also required with field identification and other permit information, all of which is public information after filing.

 

IVILC reporting of member information on fertilizer applications uses anonymous identification. In addition, by being a member of the coalition, trend monitoring can also rely on representative monitoring versus individual sampling reporting. Growers who do not file will be subject to enforcement action by the RWQCB. Ultimately, landowners are responsible for penalties.

 

Contact Us

Feel free to contact the Farm Bureau office at 760-352-3831 or email gisselle@icfb.net if you have any questions or concerns about the Imperial Valley Irrigated Lands Coalition.

 

Imperial County Farm Bureau has been advocating for local farmers and landowners in order to provide support in navigating the irrigated lands program. Should you feel inclined to share your experience with these requirements, we encourage you to contact members of your Regional Water Quality Control Board.

 

Regional Water Quality Control Board Members:

Edward Muzik                edward.muzik@waterboards.ca.gov

Peter Satin                       satin.peter@waterboards.ca.gov

Jayne Powell                   jayne.powell@waterboards.ca.gov

Nancy Wright                  nancy.wright@waterboards.ca.gov

Beatriz Gonzalez           beatriz.gonzalez@waterboards.ca.gov

Vivian Perez                    vivian.perez@waterboards.ca.gov