Jan. 3, 2018 – -The Almond Alliance, with the guidance of the Almond Board of California though our Memorandum Of Agreement (MOA), filed comments with the State Water Board on the Second Proposed Order Revising the Eastern San Joaquin Agricultural General Waste Discharge Requirements. The Alliance recognized the aspects of support for the proposal, such as anonymity in reporting, keeping participation and reporting as simple as possible, and reducing the frequency of revisions to Farm Evaluations. Concerns filed included:
* Allowing sufficient time for changes to be adopted
* Assumptions of negative water quality consequences from recharge should be balanced with an understanding of commitments under SGMA to balance supply
* Benefits should outweigh costs in expansion to low vulnerability areas
* To maintain a realistic expectation of irrigated agriculture and its benefit- new monitoring requirements should provide an approach that allows for accurate sampling without substantial cost.
The State Water Board is expected to make a final decision on the Proposed Order at its Jan. 23, 2018, board meeting.