The California Sportfishing Protection Alliance (CSPA) and the California Water Impact Network (CWIN) submitted joint comments to the Central Valley Regional Water Quality Control Board (Regional Board) on the proposed Waste Discharge Requirements (WDRs) for growers within the Eastern San Joaquin River Watershed that are members of a Third Party Group. The WDRs are the first of a series of specific general WDRs to replace the agricultural waivers. These WDRs simply transpose existing waiver requirements into WDRs, which don’t have to be renewed every five years.
Growers will now have to prepare simple management plans but aren’t required to submit them to the Regional Board. Virtually everything else remains the same. The program will continue to be directed by industry coalitions that shield individual dischargers. Individual farmers will not have to identify themselves, monitor discharges or disclose what efforts they were taking to reduce pollution. Consequently, the Regional Board will not know who is actually discharging, what pollutants are being discharged, the localized impacts to surface waters, whether management measures have been implemented to reduce pollution or if implemented measures are effective. Consequently, the WDRs will do little to protect water quality.