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April 1994
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Grassland Fix

There's a myth that you can't control nonpoint source pollution (because it comes from so many sources), and another myth that selenium is so all pervasive in San Joaquin Valley soils that it's beyond control. There are also myths that agricultural drainage can't be regulated, that voluntary BMP (best management practice) programs are the only way to go and that farmers will balk no matter what. But these myths are debunked by an Environmental Defense Fund study released this April (see Now in Print).

The study presents a package of nonpoint source pollution control options and economic incentives to curb selenium pollution from agricultural drainage. It uses the San Joaquin Valley's Grasslands area, with its infamous selenium runoff problems, as a case study. And it suggests that many of the perceived obstacles to nonpoint control can be overcome.

"When faced with a nonpoint problem, the automatic response shouldn't be 'let's adopt a BMP,' it should be 'let's look at all the tools available to do the job and pick the best ones,'" says the Environmental Defense Fund's Terry Young.

The best ones for Grasslands, according to the EDF study, are a system of tradable discharge permits among water districts, coupled with economic incentives for farm-level pollution control. Two tools EDF suggests for accomplishing this are the setting of a selenium TMDL (Total Maximum Daily Load) for the San Joaquin River and the establishment of a new regional drainage district.

The river currently exceeds the EPA's water quality standard of 5 parts per billion selenium in water. Farmers and water districts complain the standard's too tough and expensive to meet. Regulators, meanwhile, have little history of agricultural water pollution regulation and enforcement, according to Young. "They have cold feet about getting started," she says.

EDF thinks establishing a TMDL for the river would be a good first step for regulators. Developed with both technical advice from Joe Karkoski of the Central Valley Regional Board and some proven EPA methodology, EDF's proposed TMDL calculates what the discharge load would have to be each month - given seasonal flow changes in the river - to hit the 5 ppb standard.

"Our TMDL allows you to predict if you're going to have a glass or a pitcher of water to muck up," says Young. For modelling purposes, and since the 5 ppb standard is currently so far from being met, EDF chose an interim selenium reduction goal for the TMDL (see graph). "Even with the standard exceeded once every five months, you still get dramatic improvement," she says.

EDF's study goes on to propose giving a newly established regional drainage organization the permit for the whole TMDL. The regional agency would then divvy up the load among its half dozen water districts and numerous farmers.The tradable permit system would allow districts which exceed their allocations to buy from districts which have some left over. According to Young, this approach is a much more flexible and cost-effective than mandatory BMPs, as one district or farmer may have better on-the-ground tools for achieving selenium reductions than another.

Tradable permits are just one of the incentives EDF proposes to encourage drainage reductions. Effluent fees (the more you pollute the more you pay) and water input pricing (the more you use the more you pay) are two others.

Young says the next step is to get parts of the study implemented in the San Joaquin Valley. "This study has both local clean-up value and national precedent value," she says. "With Clean Water Act reauthorizers grappling with major questions about what to do about nonpoint source control, and with agriculture one of the most contentious of these sources, any study that suggests there might be a workable way around this is timely."

Contact:Terry Young (510)658-8008

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