HomeMy WebLinkAbout01.04.21 BOS Correspondence - Email from SVWQC RE Groundwater MPIR Template Public & Stakeholder Comment Period Until 2_4_2021
From:Schuman, Amy
To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;Kimmelshue, Tod;Lambert, Steve;
Lucero, Debra;McCracken, Shari;Paulsen, Shaina;Pickett, Andy;Ring, Brian;Ritter, Tami;Rodas, Amalia;
Sweeney, Kathleen;Teeter, Doug
Cc:Hatcher, Casey;Gosselin, Paul
Subject:BOS Correspondence - Email from SVWQC RE Groundwater MPIR Template Public & Stakeholder Comment
Period Until 2/4/2021
Date:Tuesday, January 5, 2021 10:05:30 AM
Attachments:SVWQC Groundwater Quality MPIR Strategy Template.pdf
Good morning,
Please see the email correspondence below and attachment from the Central Valley Regional Water
Quality Control Board inviting the public and other stakeholders to submit written comments
through February 4, 2021 on the Sacramento Valley Water Quality Coalition’s Groundwater
Management Practice Implementation Report (GW MPIR) Template.
Sincerely,
Amy Schuman
Associate Clerk of the Board
Butte County Administration
25 County Center Drive, Suite 200, Oroville, CA 95965
O: 530.552.3300 |D: 530.552.3308 | F: 530.538.7120
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From: Bennett, Robin
Sent: Monday, January 4, 2021 11:03 AM
To: Pickett, Andy <APickett@buttecounty.net>
Cc: Teeter, Doug <DTeeter@buttecounty.net>; Snyder, Ashley <ansnyder@buttecounty.net>;
Schuman, Amy <ASchuman@buttecounty.net>; Ring, Brian <bring@buttecounty.net>
Subject: FW: Available for Public Comment - SVWQC MPIR Template
Please see the attached below, a BOS email correspondence from the State Water Boards re
the Central Valley Water Quality Board’s Sacramento Valley Water Quality Coalition’s
Groundwater Management Practice Implementation Report (MPIR). Public Comments are
due by February 5, 2021 at 5 p.m.
Executive Assistant
Office: 530-762-2186 Cell:
Supervisor Doug Teeter, District 5
Butte County Board of Supervisors
6585 Clark Rd, Suite 200
Paradise, CA 95969 Email: rbennett@buttecounty.net
From: lyris@swrcb18.waterboards.ca.gov <lyris@swrcb18.waterboards.ca.gov>
Sent: Monday, January 4, 2021 9:59 AM
To: Bennett, Robin <RBennett@buttecounty.net>
Subject: Available for Public Comment - SVWQC MPIR Template
ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening
..
attachments, clicking on links, or replying.
This is a message from the California Regional Water Quality Control
Board, Central Valley (5).
Dear Stakeholders and Interested Parties,
The Central Valley Regional Water Quality Control Board is inviting the public and other stakeholders
to submit written comments on the Sacramento Valley Water Quality Coalition’s Groundwater
Management Practice Implementation Report (GW MPIR) Template. An MPIR is required under
Waste Discharge Requirements General Order R5-2014-0030-07 to document management
practices implemented by Coalition members to comply with the approved Groundwater Quality
Management Plan (GQMP).
Please find the GW MPIR Template attached for your review. Comments must be received by 5:00
pm on 4 February 2021 to be considered in the Executive Officer’s assessment of the document.
Please submit written comments to Susan Fregien at Susan.Fregien@waterboards.ca.gov. If a
commenter does not have email access, written comments may be sent to the Central Valley Water
Board’s address to the attention of Susan Fregien.
Please email questions to Susan Fregien at Susan.Fregien@waterboards.ca.gov
_________________________________________________
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TECHNICAL MEMORANDUM
SVWQC MPIR A PPROACH AND T EMPLATE
TO: Bruce Houdesheldt/Sacramento Valley Water Quality Coalition
FROM: Stephanie Tillman, Cody Fink/Land IQ
DATE: November 16, 2020
I NTRODUCTION
As part of the Irrigated Lands Regulatory Program (ILRP) General Order, the Sacramento Valley Water
Quality Coalition (Coalition) is required to submit a Management Practice Implementation Report
(MPIR) for the first time in November 2021, and annually thereafter. The MPIR is a summary of data
from members that will be collected for the first time in 2021 on the 2020 crop year. The MPIR includes
information on N and irrigation management, some of which is already included in the Irrigation and
Nitrogen Management Plan (INMP) reports and includes more specific management practices than
those in the INMP.
Because of the timing of various ILRP reporting components, including revisions to the calculation of
outlier status and the Coalition’s GAR being updated in 2021, Regional Board staff suggested and
approved that the first year of reporting for the Coalition in 2021 would use information from the INMP
for the 2020 crop year. This will not require any extra reporting from Coalition members. With this
letter, the Coalition is submitting a template for future MPIR member reporting and proposing an
approach for MPIR data collection. This approach includes frequency of reporting and how MPIR
reporting will be phased in.
To prioritize phasing of MPIR, the Coalition’s Comprehensive Groundwater Quality Management Plan
(CGQMP) that describes a prioritization strategy for addressing groundwater quality management was
considered. The Coalition’s CGQMP includes prioritization of High Vulnerability Areas (HVAs), which are
considered groundwater protection areas. The prioritization was based on geographic areas and their
relative urgency of groundwater management, proximity to surface water, and proximity to
disadvantaged communities (DACs).
The MPIR template uses objective questions designed to provide specific information that can be
tracked over time and related to changes in nitrogen use efficiency (NUE), using the applied N/removed
N (A/R) ratio.
P HASED A PPROACH
The Coalition encompasses a very large geographic area and 13 subwatersheds, each with their own
local level of coordination and governance. The subwatersheds range from the foothills where
agriculture is limited to primarily hay and pasture, to the valley-floor where intensive agriculture is
practiced with a diversity of crops. The status of each subwatershed varies in terms of their experience
1
with reporting and their number of members. While the valley-floor subwatersheds submit INMP data
using a web-based data management tool (DMT), the foothill subwatersheds use manual reporting.
A spatial analysis was done to determine how subwatershed boundaries intersect with HVAs. Table 1
shows that Butte-Yuba-Sutter (BYS) has the highest acreage of HVA in total (146,373), followed by
Colusa-Glenn (CGSP) (107,798). BYS and CGSP also have the highest combined acreage of Priority 1 and
2 HVAs. The remaining four subwatersheds have less than 100,000 total HVA acres; however, Dixon-
Solano has the highest acres of Priority 1 HVAs (35,324), followed by Yolo (27,723). All other
subwatersheds have under 10,000 acres of Priority 1 HVAs.
TABLE 1. PRIORITIZED HVA ACRES BY SUBWATERSHED
HVA Butte-Colusa-Dixon-Sacramento-Shasta-Yolo (using Total
Yuba-Glenn Solano AmadorTehama 2018 DWR
Suttercrop map)
Priority 1 9,635 5,261 35,324 2,151 0 27,723 80,094
Priority 2 57,56131,261 1,684 22,207 5,594 7,110 125,416
Priority 3 79,17771,276 21,659 19,929 13,899 34,510 233,450
Total 146,373 107,798 58,667 44,287 19,493 69,343 438,960
In all cases, all subwatersheds would be included in the 2021 MPIR report, which will focus on INMP
data. Coalition member education about new MPIR reporting will also occur during 2021, and will be
followed by a four-year reporting cycle for each subwatershed. A four-year cycle will allow for new
management practices to be implemented for at least two years, and for three more years of A/R to be
calculated. The Coalition will phase in subwatersheds according to their acreage of Priority 1 HVAs
(Table 1). Dixon-Solano, which has the highest priority 1 HVA acreage, would report first in 2022,
followed by outreach the following year, and two years for implementation before practices are
evaluated again. Other Subwatersheds would follow according to their Priority 1 HVA acreages as shown
in Table 2. All members in the prioritized Subwatershed(s) will report in their reporting year; however,
only information reported by members with parcels in HVAs will be included in the annual MPIR.
TABLE 2. MPIR AND OUTREACH SCHEDULE PRIORITIZED BY HVA ACREAGE
Cycle Year Butte-Colusa-Dixon-Sacramento-Shasta-Yolo (using Crop Year
Yuba-Glenn Solano AmadorTehama 2018 DWR
Sutter crop map)
2021 – All subwatersheds report in 2021 using INMP data 2020
Cycle 1
1 - 2022 Report 2021
2 - 2023 Outreach Report 2022
3 - 2024 Report Implement Outreach 2023
4 - 2025 OutreachReport Implement Report Report Implement 2024
2
T EMPLATE
The MPIR template was developed in collaboration with and reviewed by several irrigation and
agricultural specialists representing different regions in the Sacramento Valley including:
Allan Fulton (Irrigation and Water Resources Advisor, UCCE Tehama County, retired)
Wendy Rash (District Conservationist, USDA-NRCS, Napa/Solano, CA)
Kevin Greer (Irrigation Technician, Tehama County Resources Conservationist District)
Paul Lum (Irrigation Specialist, Solano Irrigation District, retired)
Additional information from Cal Poly was used to inform the MPIR survey. Questions are focused on
irrigation and N use efficiency, which have been shown to largely influence N leaching potential. Only
questions pertaining to management practices used in the Sacramento Valley are included.
The MPIR focuses on irrigation distribution uniformity (DU) practices for several reasons:
Both N and irrigation efficiency heavily influence N leaching potential.
Irrigation DU is not addressed in the INMP.
N use efficiency is largely addressed in the INMP.
N only leaches with water, either from rainfall or irrigation. Rainfall is plentiful in the
Sacramento Valley, but can’t be controlled. Irrigation water control and management is
therefore critically important to N use efficiency and preventing leaching.
The “4 Rs” of N application (right place, right rate, right form, right time) have been the focus of
much outreach in the ILRP program; however they are difficult to implement optimally without
addressing DU. Irrigation DU specifically addresses right rate and right place.
Management practices related to the 4 Rs and efficient N application are continually evolving,
and MPEP results related to N use efficiency will not be available for another 2 to 3 years.
Coalition members can address and implement DU practices now without further research. The
principles of good DU are fundamental and will not change.
The template has 10 questions that are very specific to irrigation and N fertilization management
practices. They avoid qualitative language such as “adjust”, “account for”, “allow for”, etc. with the
intent of being as objective as possible. Therefore, when growers change their practices to improve,
these survey questions will capture that improvement. Because the template is relatively short,
members can easily answer the template questions multiple times if necessary. The questions are
intended to be educational in themselves, indicating to growers specifically what management practices
they should be implementing and how often.
The MPIR template will be included in the DMT and will be filled out for the member’s whole farm (not
for individual fields). Changes in their answers can be tracked in the DMT without asking additional
questions. These changes can then be compared to performance metrics such as A/R, to be determined
by the Coalition. Changes in the member’s responses to INMP questions about irrigation and nitrogen
efficiency practices, which are reported by field, can also be compared.
3
MPIR Q UESTIONNAIRE T EMPLATE
1 How often do you complete an irrigation distribution uniformity evaluation to identify
maintenance needs? (select 1)
At least once every 3 years
Every 3 to 5 years
Never – unknown distribution uniformity
2 How often do you assess water quality for changes in chemistry or biological materials
(bacteria, fungi, algae and sediment)? (select 1)
Every 1 to 3 years, or when water supply is known to have changed
Every 3 to5 years
Never - Unknown water quality
3 How often do you select and inject acids, chlorine, or polymers for irrigation system
maintenance? (select 1)
As often as necessary, based on known water quality changes
At least once each irrigation season
Never
4
How often do you clean filters and flush hose lines? (select 1)
At least every other month during irrigation season
At least once each season
Never,or less than once each season
5 How often do you do drive through checks on your irrigation system to scout for system
breaks and needed plumbing repairs? (select 1)
At each start-up
Every 1-4weeks
Seldom (less oftenthan every 4 weeks)
6 How often do you use ETo, ETc, soil, or plant water status monitoring to guide irrigation
scheduling? (select 1)
Regularly(several times throughout the growing season)
Sometimes (on some crops or at some points during the growing season)
Never
4
7
Flood irrigation efficiency practices (select all that apply)
NA - Do not flood or furrow irrigate
Grade for constant slope or taper slope for bottom 1/3rd of field
Short furrow or check length (under 1/4 mile)
The acres, flow rate, and duration are consistent for each set across a field
Pull torpedoes behind cultivator to smooth furrows (row crops)
Alternate furrow irrigation
Water advances to end of furrow in about half (or less) of the total irrigation time
Cutback flow in furrow or border-check irrigation when water reaches end (row crops)
Collect and reuse tailwater run-off
Use polyacrylamide (PAM) water additives to reduce sediment in water
8
Fertigation practices used on pressurized systems (select all that apply)
NA – do not use fertigation on pressurized systems
Check valve/back flow prevention device
Precision injection metering device
Annual crops – inject fertilizer during last ¼ of irrigation set for at least two hours, followed by
at least two hours of flushing with fresh water
Orchard crops – inject fertilizer during last ¼ of irrigation set for at least one hour, followed by
at least one hour of flushing with fresh water
9
Fertigation practices used on non-pressurized systems (select 1)
NA – do not use fertigation on non-pressurized systems
Inject fertilizer during the last ¼ to ½ of the irrigation set
10
Do you use a meter to measure irrigation water flow to your field? (select 1)
Yes
No
COMMENTS/NOTES:
5