Agriculture groups urge delay on numeric limits; say data insufficient and local economics at stake

Agricultural interests spoke forcefully at the Aug. 8 meeting of the State Water Resources Control Board’s agricultural expert panel, urging caution before the board adopts numeric limits on nitrogen applications or discharges.

“We think that calling the expert panel at this juncture of the program is premature,” Tess Dunham, a water quality attorney representing a statewide coalition of agricultural groups, told the panel. She and other farm representatives said that data collection and reporting remain uneven across regions and that the Central Valley — which has the largest, most mature dataset — should not be treated as representative of the whole state.

Why it matters: Several members of the agricultural sector argued that numerical discharge limits could eliminate multicropping systems and cause major economic disruption in regions with specialty, labor‑intensive crops such as the Central Coast. They urged the panel to recommend targets used as educational tools and to allow time for additional data collection, outreach and refinement of crop coefficients and removed‑nitrogen calculations.

Central Coast coalition consultant Abby Taylor Silva asked the panel to consider regional economics and the feasibility of targets. “Any discussion of limits is absolutely premature,” she said, adding that expanded farmer outreach, more curated third‑party support and additional field data are needed before targets or limits are used as regulatory tools.

Agriculture groups emphasized three technical points they want the panel to examine: 1) regional differences in cropping, soils and water sources, 2) the need for agronomically feasible multiyear targets for A/R or A–R metrics, and 3) whether irrigation‑water nitrogen should be credited based on plant uptake rather than raw concentration in a well.

Abby and other Central Coast representatives also asked the panel to consider “discount factors” or credits that acknowledge irrigation water nitrogen used by crops, and to allow cover‑crop scavenging, bioreactors and other removals to count as removed nitrogen where those practices are demonstrated and maintained.

Economic concerns: Presenters supplied examples of potential economic harm if limits were set as proposed in the Central Coast’s former order. Abby cited ERA Economics’ analysis prepared during the Central Coast rulemaking that modeled lettuce production in Monterey County. The study estimated annual regional revenue losses in the tens of millions of dollars under certain discharge limits and projected large job losses at strict limits. Abby told the panel those findings illustrate why the group asks for regional flexibility and additional analysis before limits are recommended.

Reporting burden and equity: Agricultural speakers said reporting approaches should be flexible so small and diversified farms and non‑English speakers are not disproportionately burdened by data requirements and calculation complexity. Several presenters and panelists urged stronger, stable funding for technical assistance and third‑party data management to improve compliance and the quality of datasets the panel will rely on.

What they asked the panel to do: Agricultural representatives asked the panel to (1) evaluate how to continuously refine agronomically feasible multiyear targets as more data arrive, (2) weigh A–R and A/R uses as indicators rather than automatically equating those metrics with enforceable limits, (3) incorporate irrigation‑water crediting that reflects crop uptake, and (4) recommend mechanisms to protect small and disadvantaged farms from disproportionate compliance burdens.

Ending: Agricultural stakeholders said they will continue to engage in panel work but urged the group to keep an open mind about alternatives to numeric limits, including programmatic tools, incentives and regionally tailored approaches.