GSA committee outlines farm-unit carryover and penalty policy, agrees to return with worksheet and clearer math

Leticia Tapia, Water Resources Specialist, presented a recommended “farm unit annual changes” policy to the GSA committee that formalizes how carryover credits and penalties are allocated after farm-unit sales, leases or other changes in configuration.

Tapia told the committee that the farm unit — a group of parcels managed by a single entity within the same farm-unit zone — remains the primary unit for allocations. Under current practice, penalties are shared by all APNs (Assessor’s Parcel Numbers) in a farm unit and apportioned using a volumetric method tied to each parcel’s attributable groundwater use; unpaid penalties are assessed through the county Treasurer-Tax Collector’s office by APN.

The proposed policy would formally allow growers flexibility: where a sale, lease or written agreement specifies a different split of carryover credits or penalties, staff would follow those contractual terms. In the absence of a written agreement, Tapia explained, the GSA would continue using the volumetric apportionment approach already in use: carryover is divided by parcels’ relative contribution to the farm unit’s unused allocation; penalties are apportioned to parcels based on relative contribution to overuse.

Several growers raised concerns during public comment about the policy’s effects on renters and managers who consolidate parcels into a single farm unit. One grower said the volumetric approach can disincentivize managers who reassign irrigation to shallow wells and thereby save carryover credits; under the proposed approach those saved credits could revert to underlying landowners or other parcels rather than the manager who invested to reduce pumping.

Michelle Lascoyde and Noah Lopez also urged safeguards. Lopez (Madera Ag Water Association) recommended the county avoid acting as an arbitrator of private lease disputes; instead he proposed a standardized “carryover/penalty worksheet” that contracting parties would fill out and sign and that the GSA would accept as the governing allocation instruction. He also suggested the GSA mail notice to affected parties whenever carryover or penalties are redistributed.

Staff said they will prepare and return with a clearer worksheet and a longer presentation showing the volumetric math and possible safeguards. The committee did not take a vote on a resolution; staff characterized the item as a recommendation to the full board and said staff will bring a revised packet back for clearer presentation and potential board action.