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California Alfalfa & Forage Association

A March 13 meeting at the Central Valley Regional Water Quality Control Board brought back early recollections of a childhood spent in Iowa and the old farmhouse where we lived for a short time. Behind the house was a creek that eventually flowed into the Des Moines River.

Not a lot of thought was paid to water quality in those days and the pollutants that found their way into the creek, where we waded to escape the summer heat and humidity, are better left untold. We're obviously a lot better off today with the emphasis on cleaning up waterways and the technology that allows pollutants to be measured in parts per trillion.

The discussion at the Regional Board that prompted the flashback was a discussion of the Toxic Hot Spots Cleanup Plan and implementation of Total Maximum Daily Loads (TMDLs) for organophosphate insecticides. For alfalfa, of course, chlorpyrifos (Lorsban/Lock-On) is the focus of the Hot Spots Plan the Board is adopting. Levels are typically below standards for drinking water. But, they're high enough to impact the “water flea“, Cerodaphnia dubia, an aquatic invertebrate that's used as a test organism and predictor for resident invertebrates. The Delta, the San Joaquin River and several of its tributaries have been placed on the 303(d) list of impaired water bodies. Section 303(d) of the Federal Clean Water Act mandates that TMDLs be developed to improve water quality.

CAFA was at the March 13 meeting to follow the status of proposed amendments to the Hot Spots Plan for the Delta. A draft proposal contained language that strongly indicated growers could be charged an annual filing fee. According to the proposal: “If use of individual WDRs (waste discharge requirements) is the regulatory framework…staff estimates that annual filing fees would be approximately $2,025.” A $2,025 fee, of course would keep chlorpyrifos on the shelf and force growers to scramble for an alternative to the popular insecticide.

Much to the relief of CAFA and others at the meeting, the annual filing fee was described as “an estimate for cost of regulatory compliance” required by law and would not be implemented. The Regional Board also acknowledged that it doesn't have the statutory authority to collect a fee when waste discharge requirements are waived, a point made by the California Farm Bureau.

While the Hot Spots Plan is complex, the challenge for growers is to reduce surface water runoff after applying chlorpyrifos. A time schedule is being developed for the Regional Board to adopt TMDLs, the maximum amount of pollutant that can enter a waterway without having an adverse affect. The cleanup plan requires the Board to approve TMDLs by September for the San Joaquin River and by September 2004 for the Delta. Adopting practices that meet TMDL thresholds will prevent further restrictions and regulations.

CAFA is keeping its members informed and has developed a list of practical mitigation measures to curb pesticide runoff. If research funds are available, CAFA will be working with cooperating growers to further define the most efficient and effective ways to meet regulatory standards.

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