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Imperial Valley TMDL

Imperial County Farm Bureau

California Irrigated Lands Regulatory Program

Water discharges from agricultural operations in California include irrigation runoff, flows from tile drains, and storm water runoff. These discharges can affect water quality by transporting pollutants, including pesticides, sediment, nutrients, salts, pathogens, and heavy metals from cultivated fields into surface waters.

To prevent agricultural discharges from impairing the waters that receive these discharges, the Irrigated Lands Regulatory Program (ILRP) regulates discharges from irrigated agricultural lands. This is done by issuing waste discharge requirements (WDRs) or conditional waivers of WDRs (Orders) to growers. These orders contain conditions requiring water quality monitoring and receiving waters and corrective actions when impairments are found. The number of agricultural land enrolled in the ILRP is about six million acres. The number of growers enrolled is approximately 40,000.

Further information on the California ILRP may be found at

Path to Compliance

In 2000, the Regional Water Quality Control Board (RWQCB) developed a Conditional Prohibition - Total Maximum Daily Load (TMDL) for Imperial Valley Waterways. A TMDL is a regulation limiting the amount of pollutants that can be released into a water body. This TMDL required agricultural discharges to reduce the amount of substances such as silt and nutrients that leave their fields. TMDLs have a huge impact on Imperial Valley agriculture and why ICFB developed a voluntary compliance program to help defend growers from the onslaught of TMDLs.

The ICFB Voluntary Compliance Program is based on the California Farm Bureau Federation (CFBF) Non-Point Source Initiative that was developed to provide guidance to county Farm Bureaus operating under the threat of non-point source (NPS) regulation. The CFBF initiative acknowledges agriculture responsibility as a NPS contributor and enlists the practical genius of each farmer to reduce the impacts that they have on water quality. The goal of the CFBF initiative is to maintain the flexibility of individual agriculture operations, avoid prescriptive regulation, and enable agricultural entities to meet the pollutant load allocations imposed by TMDLs.

In 2011, the State Water Resources Control Board mandated our Conditional Prohibition be transitioned into a Conditional Waiver. Although most aspects of the program will remain the same, the one significant change to the program includes a fee attached to participation. Working together with the Imperial Irrigation District, ICFB created a coalition to administer the new Conditional Waiver, as a result the program qualifies for Tier I pricing currently set at $0.75 per acre. A list of the current fee schedule may be viewed at

How it Works

Participating growers are organized into one of ten working groups that combine their farming experiences to develop feasible methods of controlling pollutant runoff. Each participant will then prepare a plan for their farming operations and implement the plan. Being organized into groups provides an organizational structure that enables ICFB to maintain the anonymity of individual growers through a region-wide monitoring and reporting program. Protecting individual operations from the scrutiny of the RWQCB is a major priority of the ICFB Program.

Determining Compliance

The RWQCB has agreed to grant temporary immunity to growers who participate in the ICFB Program. Growers who elect to participate register with the ICFB Voluntary Compliance Program and have their name submitted to the RWQCB. They are then free from further enforcement action from the RWQCB. They will, however, be accountable to ICFB and require to follow through with their commitment to cooperate.

The Alternative

As distasteful as cooperating with another regulatory program may seem, the alternative is even more grim. Growers who choose not to participate in the ICFB Program will be contacted by the RWQCB and required to submit a water quality management plan, proof of implementation, and monitoring results directly to the RWQCB. In addition, individuals registering directly with the RWQCB fall under Tier III on the fee schedule (, a price significantly higher than working with the coalition. Another downside to individual compliance is the lack of privacy it provides; a primary objective of the ICFB Program. To top it off, growers who go it alone will be at the head of the list when it comes to RWQCB enforcement actions.

Linsey J. Dale
Imperial County Farm Bureau
Executive Director / Compliance Program Manager
1000 Broadway, El Centro, CA 92243
(760) 352-3831 – Office
(760) 427-5868 – Mobile