Nitrogen Management Plans to Meet Water Quality Standards

We are now just over halfway through the third term of the Conditional Waiver, adopted in April 2016 and set to expire in April 2021.  Each new term builds upon the last, and adds new requirements aimed at improving water quality and advancing progress towards meeting regulatory standards.

While many of the on-farm Best Management Practices (BMPs) have resulted in water quality improvements over the years, nitrate levels in irrigation and stormwater runoff continue to be an issue in many areas, particularly those dominated by row crops or berries.  

One of the most significant additions to the current Conditional Waiver is the requirement for growers in Responsibility Areas associated with nitrogen water quality exceedances to develop and implement site-specific Certified Nitrogen Management Plans for their farms. The purpose of these plans is to leverage best available research for crop-specific nitrogen demand, and apply the concepts of the 4Rs: right time, right place, right source, and right rate. The plan itself is a single-page worksheet, completed annually for each farm unit, which guides a grower through calculating total nitrogen needed for each crop. The process also identifies nitrogen contributions from sometimes overlooked sources, such as irrigation water or carryover in soil, and then prescribes an amount of supplemental fertilizer required to meet crop demands.

When implemented effectively, these plans will minimize the over application of nitrogen fertilizers and prevent leeching into groundwater or off-site mobilization of nitrogen in irrigation tailwater and stormwater flows. The research behind crop nitrogen demand continues to grow and evolve, but the primary objective in this early stage of the program is to familiarize growers with the process of developing a nitrogen budget and the available resources specific to their crop. 

To ensure that the plan is developed by a qualified individual, the Conditional Waiver requires certification through one of the three mechanisms listed below.  

1. Self-certified by a grower who attends a California Department of Food and Agriculture Fertilizer Research and Education Program (CDFA FREP) training program.
2. Self-certified by a grower to adhere to site-specific recommendations from the Natural Resource Conservation Center (NRCS).
3. Certified by a Certified Crop Advisor (CCA) or s Technical Service Provider certified in nutrient management by NRCS.

To provide growers with the opportunity to become self-certified, VCAILG has collaborated with CDFA FREP, the University of California Cooperative Extension (UCCE), and Fruit Growers Laboratory to develop a local curriculum based on an existing self-certification program developed for growers in California's Central Valley. The training itself includes a 3 1/2 hour  workshop focused on the basics of the nitrogen cycle, irrigation and nutrient management, and nitrogen budgeting, followed by a 30 question, multiple-choice exam. VCAILG has offered two of these training workshops to date (Oct. 2, 2018, and Jan. 24, 2019) and will continue  over the next few years. The next workshop is tentatively planned for late summer of this year. 

Once a grower completes the self-certification training program and passes the exam, he or she needs to complete seven hours of approved continuing education every three years to maintain the certification. The training program itself accounts for four hours of education credit, leaving  three additional credit hours required to be completed during the first three-year period. The Conditional Waiver's existing requirement for growers to attend two hours of continuing education per year does still apply, but an approved class or event can be leveraged to meet both requirements, so long as it has a nitrogen focus. Any continuing education courses that qualify for both VCAILG and nitrogen management plan self-certification requirements will be advertised as such.

Some of the most common questions asked by growers relate to whether these requirements apply to them, and if so, by which date they have to be implemented. The current Conditional Waiver specifies that growers located in Responsibility Areas with water quality exceedances of nitrogen standards are required to develop a Nitrogen Management Plan. In addition, a plan is also required in areas where watershed-specific TMDL regulations require implementation as a means to address waterbody impairments. Growers in Responsibility Areas that have neither benchmark exceedances for nitrogen nor TMDL-specific requirements will not be required to develop a plan within the current Conditional Waiver term.  

The requirement applies first to growers in the Ventura River Watershed (RAs 18 and 20), with an implementation date of January 2019.  This date is based on watershed-specific requirements listed in the Ventura River Algae TMDL, a regulatory plan adopted by the Regional Board to address excessive algae growth in the river by reducing nitrogen loads in runoff. Following this date, the implementation schedule for the remaining Responsibility Areas requiring plans will be phased in according to the degree of water quality benchmark exceedance. Areas with more significant nitrogen impairments will require plans earlier.

The map and table below summarize these dates by Responsibility Area. More detailed maps can be found on VCAILG's Water Quality web page and a list of assigned ResponsibilityArea by Assessor Parcel Number (APN) can be downloaded here. 

Finally, it's important to mention again that while the current implementation schedule only applies to specific Responsibility Areas, these requirements are expected to expand to all agricultural operations during the next Conditional Waiver term.  This is due to the State Water Resources Control Board's recent issuance of the East San Joaquin River Watershed Waste Discharge Requirements, which included precedential requirements applying to Irrigated Lands Regulatory Programs across the state. These precedential requirements, which include the development of irrigation and nitrogen management plans for all agricultural operations, are the State Board's mechanism for directing the nine regional boards to incorporate these requirements into their next regulatory orders.  

While these requirements are already being implemented to some degree in many water board regions, such as the Central Coast, Central Valley, and now Los Angeles regions, the State Board's directive will create statewide consistency throughout the various Irrigated Lands Regulatory Programs. What that means for growers in Ventura County is that we can expect the Los Angeles Regional Water Quality Control Board to expand nitrogen management plan requirements to apply to all growers when the Conditional Waiver is next renewed in 2021.  

As always, VCAILG will keep growers informed of any new regulatory developments as we get closer to the Conditional Waiver renewal date.  For more information about the Nitrogen Management Plan requirement and resources for developing a plan, please visit VCAILG's Water Quality web page.