New Program Adopted December 2021

For the past two decades, the Imperial County Farm Bureau Voluntary TMDL Compliance Program has served Imperial Valley farmers and landowners as a way to comply with the Colorado River Basin Regional Water Quality Control Board (RWQCB) silt and sediment TMDL requirements. Since 2015, the RWQCB has taken steps to transition the TMDL into general waste discharge requirements.

 

As of December 2021, irrigated agriculture in the Imperial Valley is now under the new General Order. The IID-ICFB Coalition which has managed the program since 2015 will continue 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 on 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. Subject to any new notices, existing TMDL members will be automatically enrolled in the new program in 2022. 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 in the future will be on the new website, which will be rolled out in the fall of 2022. The September 1st TMDL reporting will not be required for 2022. Your next farm plan update will be due January 1, 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 $1.29 per acre of land for the 2021-2022 year. Please note the fee schedule for 2022-2023 has not yet been released and is likely to increase.

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 2022 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 alicyn@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

• Current Imperial County Farm Bureau Agricultural Membership

 

All commercial irrigated agriculture in the Imperial Valley is subject to the new 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.

 

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.

 

Program Education and Outreach

The Imperial Valley Irrigated Lands Coalition will hold a series of grower outreach meetings to cover the new irrigated lands program. The meetings will cover the new reporting requirements, changes to the program, the new IVILC reporting website, and more. We are also always available for phone assistance as well. Please do not hesitate to contact us with any questions.

 

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 if you have any questions or concerns about the transition from the TMDL Program to the Imperial Valley Irrigated Lands Coalition.

 

1000 Broadway

El Centro, Ca 92243

Office (760) 352-3831

ivilc@icfb.net