On 2 December 2013, CSPA submitted extensive comments to the Central Valley Regional Water Quality Control Board regarding the proposed waste discharge requirements (WDRs) for pollutant discharges from the Westside San Joaquin River Irrigated Lands Coalition. The WDRs will replace the present “agricultural waivers” and are intended to regulate pollutant discharges from some 500,000 acres of irrigated lands.
CSPA recently prevailed in a lawsuit against the Regional Board when the court found that the waivers failed to comply with state antidegradation and nonpoint source control requirements. The proposed WDRs essentially transfer the inadequate requirements of the old waivers to permits, which don’t have to be renewed every five years.
Under the new WDRs, Regional Board will still not know who is actually discharging pollutants, what quantities of what pollutants are being discharged, localized impacts to receiving waters, whether management measures are being implemented or if implemented management measures are effective. Consequently, the proposed WDRs are not protective of water quality and will also fail to comply with state antidegradation and nonpoint source control requirements. Limited downstream montoring has revealed major violations of water quality standards for a large suite of pollutants.