On 17 January 2014, CSPA submitted extensive comments to the Central Valley Regional Water Quality Control Board regarding proposed waste discharge requirements (WDRs) for discharges of waste from farmers within San Joaquin County and Delta area. The WDRs will replace the present “agricultural waivers” for the San Joaquin County and Delta Irrigated Lands Coalition and regulate pollutants discharged from 5,865 farms covering 582,000 acres.
CSPA recently prevailed in a lawsuit against the Regional Board when the court found that the old waivers failed to comply with state antidegradation and nonpoint source control requirements. The proposed WDRs essentially transfer the inadequate requirements of the waivers to permits that don’t have to be renewed every five years.
Under the new WDRs, the Regional Board and public will still not know who is actually discharging pollutants, what quantities of what pollutants are being discharged, localized impacts to receiving waters, whether management practices are being implemented or if implemented management practices are effective. Consequently, the proposed WDRs are not protective of water quality and also fail to comply with antidegradation and nonpoint source control requirements.