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California Strawberry Commission submits comments on the Draft EIR and Ag Order 4.0.

July 07, 2020
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The Central Coast Regional Water Quality Control Board (CCRWQCB) prepared a Draft Environmental Impact Report (DEIR) and a Draft Agricultural Order 4.0 (Draft Order) for the regulation of waste discharge from irrigated lands throughout the central coast region. This proposed Ag Order 4.0 was first released in February 2018 and will ultimately replace the previous Order 3.0. The CCRWQCB accepted comments to the DEIR and Order until June 22, 2020.

The California Strawberry Commission (CSC) submitted comments on the proposed Draft Order to the CCRWQCB. CSC limited comments to issues that are particularly relevant to the California strawberry industry and joined the comments of the Ag Coalition who submitted more comprehensive comments.

The commission focused comments on four primary areas:

  1. Economic impacts: CSC explained that the Draft Order contains an inadequate analysis of economic impacts and the resulting environmental impacts. As proposed, the Nitrogen (N) discharge limits alone would reduce strawberry production significantly and the projected economic impacts are significant.
  2. Nitrogen Discharge Limits: The Draft Order includes both crop specific nitrogen (N) application limits and total N discharge limits. Most strawberry acres already comply with the proposed N application limit of 330 pounds per acre. CSC suggests that a specific N application limit is not necessary. However, the N limit it is not the most significant limiting factor for strawberry production; rather, it is the proposed total N discharge limit that will cause the most severe impact.
  3. Ranches with Impermeable Surfaces & Slopes: The Draft Order places strict limits on the amount and intensity of stormwater than can leave a ranch with impermeable surfaces. The Draft Order also requires all farmers with impermeable surfaces on slopes greater than 5% have a certified sediment and erosion plan. Both proposed requirements would be extremely costly for the strawberry industry and are more than is needed to protect water quality.
  4. Riparian Setbacks and Vegetation Requirements: The Draft Order requires “operational set-backs” of 1.5 times the width of the active channel on each side of the stream and “riparian setbacks” of between 50 and 175 feet or more, if the land is sloped. These setbacks do not correlate to water quality impacts from the irrigated land. The setbacks are required under the Draft Order based on the location of the property, not based on the discharge of waste from the farming operation on that property. CSC claims the setback requirements exceed the board’s authority and are a constitutional taking.

Next steps: the CCRWQCB indicated that they will hold Board meetings on September 10-11 and September 23-24 for discussion on the Order. The meetings will include stakeholder presentations, staff presentations, public discussion and public comments will be received.

Link to letter: https://link.calstrawberry.com/yjys

Contact: Eric Lauritzen, Director of Regulatory Affairs
Email:
elauritzen@calstrawberry.org
Phone:
916.719.7945

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