Environmental justice and conservation groups urge interim numeric limits, stronger reporting and audits to protect drinking water

A coalition of environmental justice and conservation organizations urged the Agricultural Expert Panel to recommend enforceable interim and final nitrogen limits, improved data transparency and increased regulatory oversight to protect communities with high nitrate contamination.

Crane Gibson (Leadership Counsel) told the panel that sufficient scientific research exists to adopt crop‑specific nitrogen limits protective of groundwater and recommended targeting the highest dischargers first with progressive time schedules. He invoked the program’s purpose to achieve water quality objectives and the legal duty of regional boards to adopt time schedules that are "no longer than reasonably necessary."

Speakers emphasized disproportionate impacts on low‑income and Latinx communities. Elias Rodriguez (California Rural Legal Assistance) cited Santa Clara University analyses showing Latinx‑majority census tracts in the Central Coast are several times more likely to have groundwater exceeding the 10 mg/L nitrate MCL. Rosa Correa Orozco, representing San Gerardo (Salinas), described wells lost to nitrate contamination and urged prompt action to protect residents’ drinking water.

The coalition’s technical presenters (Jake D'Alessandro, Iris Stewart Frey) highlighted data gaps: INMP summary tables often lack field‑scale acreage, specific location and soil data needed to evaluate A and R, inconsistent year‑to‑year acreage reporting undermines trend analysis, and less than half of irrigated acres report A‑minus‑R values. They recommended requiring acreage and location reporting (Central Coast practice produces higher data quality), increasing audit frequency and scope, adjusting permit fees to fund verification, and hiring dedicated staff to evaluate INMP data quality.

Nat Cain (Environmental Law Foundation) argued for numeric interim limits (e.g., starting at mean 2025 A‑minus‑R by area, or at a 70–75th percentile interim threshold) with incentives for proven BMPs and fair, progressive enforcement as a backstop. He also urged consideration of application limits as a simple, enforceable tool to curb extreme discharges.

Coalition speakers cited legal and policy authorities (the 2018 environmental justice (ESJ) order, Water Code provisions, and case law) and stressed that anonymity of grower data is not legally required and can be revisited to support program transparency and enforcement. The coalition called for the panel to recommend interim limits while continuing work toward final numeric limits to meet groundwater objectives.