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Dairy industry urges streamlining of revised dairy order, warns pond testing and retrofit schedules risk closures
Summary
Representatives from Dairy Cares, the Central Valley Dairy RMP and dairy operators praised some revisions but warned mandatory seepage testing, prescriptive 13267 orders and tight pond retrofit timelines are impractical for many farms without financing; they asked the board to defer certain tasks to regional implementation and to align with CV Salts.
A panel representing dairy producers and allied organizations told the State Water Resources Control Board on July 8 that the revised draft dairy order includes helpful clarifications but remains administratively heavy and economically risky for smaller operations.
Theresa Dunham, counsel for Dairy Cares, said the order is "long and weak" in places where it should be streamlined and urged the State Board to rely on the Central Valley Regional Water Board's local expertise for implementation. JP Cadavia, executive director of the Central Valley Dairy Representative Monitoring Program, described industry investments in monitoring and innovation and said a new data management system is intended to provide the consistent, analyzable reporting the board needs; he said the RMP expects to have that system ready for testing by March 31, 2027.
Dairy operator Justin Gillette described investments on his 3,700-cow farm and said drastic pond retrofits would be disruptive and costly: "Any future mandate that will require additional pond lining would be difficult for us to meet... the cost of realigning upon could be in excess of $2,000,000, and financing for this would be necessary and difficult to obtain." Industry speakers emphasized that cropland (land application) accounts for the bulk of dairy nitrogen loading and urged the board to prioritize controls and data collection that address that source first.
Paul Souza and other industry technical speakers urged the State Board to scale back mandatory 13267 orders requiring pond-depth estimates and seepage tests unless regional desktop analyses show a need. They argued seepage testing services are currently unavailable at scale, often impractical on working farms, and would yield limited reduction in overall nitrogen loading compared with investments in land-application practices.
Economist Duncan McEwen warned of ongoing consolidation and attrition in the dairy sector and urged the board to consider the industry's fragile economic conditions when setting timelines. Industry groups said they support the goal of protecting groundwater but asked for realistic sequencing, targeted technical direction, and financing support to avoid unintended business closures.
Industry will submit written comments by July 30 identifying specific areas where the order can be streamlined, including proposals for narrowing 13267 directives, deferring some technical development to the Central Valley Board in coordination with state staff, and aligning monitoring/reporting requirements with the RMP's forthcoming data management system.
