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Central Coast, growers and coalition leaders tell panel numeric nitrate limits are premature
Summary
Grower representatives and some coalition presenters urged the expert panel not to recommend enforceable numeric limits now, citing limited regional data, agronomic feasibility and potential economic harm; they asked the panel to treat A minus R as an educational target while data collection and outreach continue.
Representatives of Central Coast growers and coalition groups told the State Water Resources Control Board's expert panel that adopting enforceable numeric application or discharge limits now would be premature and likely to cause regional economic harm.
Abby Taylor, speaking for a group of Central Coast agricultural organizations, said the coast's irrigated acres and crop mix differ from the Central Valley and argued the data record is too short to support regulatory numeric limits. She said the Central Coast has only recently scaled up reporting and that many growers remain in transition; she described the region's reporting rollout as a multi-year learning process and urged time to refine agronomic coefficients and reporting methods.
Ches Duman, a water-quality attorney representing agricultural interests, said some calculation approaches proposed in the questions presented to the panel carry implicit policy assumptions and that the panel should not presuppose numeric limits as the only regulatory tool.
Why it matters: Several presenters argued that numeric limits tied to application rates or A minus R could function as de facto compliance limits with large regional economic impacts. Abby Taylor cited an economic analysis provided to the Central Coast board (ERA Economics) showing potential regional losses if strict discharge limits were applied to some high-value crops; that analysis was submitted to the board as part of the order development process.
Key concerns raised by grower and coalition presenters: - Data maturity: Central Coast presenters said their reporting program is newer (fewer years of complete A minus R data) than Central Valley programs and needs additional seasons and outreach before numeric thresholds are applied statewide. - Implementation burden: Smaller and non-English-speaking operations may lack recordkeeping systems; central coalitions play a role in aggregating data and providing technical support. - Economic impacts: Presenters asked that the panel consider agronomic feasibility and regional economic consequences before recommending bindable numeric limits.
Presenters asked the panel to recommend a phased approach: treat A minus R targets as educational and improvement benchmarks while the state and coalitions refine crop coefficients, anonymized data aggregation, and monitoring protocols. They recommended that the panel provide technical guidance on calculating A minus R, on how irrigation-source nitrogen should be counted for particular crops, and on how to structure exceptions where nitrate does not migrate to groundwater.
Board staff and some panelists pushed back that while economic analysis belongs at the policy stage, the panel should clearly identify whether existing data support numeric objectives and, if not, explicitly describe what additional data or analyses are needed.
