Growers push back on carryover decay and penalty increases as GSA explores targeted demand management
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Summary
The committee reviewed allocation, penalty and carryover options. Growers and associations strongly opposed a proposed carryover decay policy and urged markets or replacement‑water costs instead; staff signaled targeted sub‑zones and DWR guidance could prompt additional restrictions.
Madera County GSA staff presented a package of demand‑management policy options that included potential increases to stair‑step penalties, a proposed carryover‑decay policy that would reduce the value of unused carryover water over time, and the possibility of developing surgical, area‑specific management zones to address subsidence.
Staff noted the current penalty schedule has incrementally increased (from $100/acre‑foot to $300/acre‑foot to date) and that other agencies use higher penalties (up to $500/acre‑foot). The GSA does not currently impose an expiration on carryover and is the only allocation agency in the staff review without a carryover limit. Staff also showed mapping of groundwater extraction and subsidence trends and said the state’s forthcoming subsidence guidance could require additional targeted restrictions.
Public comment was extensive and largely opposed to carryover decay. Growers argued that carryover functions as a long‑term planning “bank” and that changing rules midstream would harm perennial crop planning and erode goodwill. Sharon Cedarquist called carryover decay unfair and said it would punish growers who have conserved water; Mark Peters and others said carryover limits could force growers to plant rather than conserve unless a market or county buy‑back program exists. The Madera Ag Water Association urged consistency and recommended that any decaying of carryover be preceded by an operational market to allow growers to sell credits.
Speakers raised measurement and mapping concerns (Larkin and Michelle Lascoydie said slides mischaracterized irrigation in some parcels) and flagged practical issues such as abandoned fields still showing up as irrigated in satellite data. Several commenters proposed alternatives to decay, including replacement‑water costs or targeted financial disincentives for overuse rather than penalizing conserved growers.
Staff recommended further analysis, more detailed maps to identify high‑use areas, and taking more time to refine options; they suggested returning the item to a committee meeting in February to allow extended public engagement and to review state subsidence guidance.
What’s next: staff will analyze the state subsidence guidance, prepare refined zoning maps and return demand‑management options for committee consideration in early 2026. No formal policy change was adopted at this meeting.
