This legislative silence does not mean spot bills could not still be introduced, Pinel added.

The groundwater nitrate problem was heaped upon the regulatory backs of farmers who are in the throes of the first half of what is being called the irrigated lands programs. Several years ago, agriculture’s exemption from water quality laws was revoked. That set off a chain of events that prompted extensive monitoring of runoff from ag lands and the drafting of regulations to mitigate that.

While agriculture was going through that process, the UC Davis report on nitrates and groundwater just added another regulatory layer to California farming.

The CCA has taken a front row seat on both issues. Unlike the state licensed Pest Control Adviser (PCA), the CCA consults primarily on water, nutrients and soil issue. The CCA program is voluntary, administered through the American Society of Agronomy and local chapters like the California CCA chapter. There are about 700 CCAs in California. That compares to 3,000 licensed PCAs.

The CCA has emerged as the third party in aiding farmers in writing nutrient management plans, but that is not without controversy. Some believe a farmer is capable of writing his own nutrient management and requiring a grower to pay for it is an unnecessary added expense.

And some CCAs apparently are reluctant to dive into this new arena. At the recent CCA annual meeting in Visalia, one CCA brought up the liability issue in development of nutrient plan for a farmer who may be cited for improper fertilizer management.


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Pinel acknowledged that the liability issue has surfaced, but it is not a “major issue,” she says.
The CCA “is not making a use recommendation” in a nutrient management plan as would a PCA in writing a pesticide use recommendation. Rather a CCA will offer “agronomically sound advice” to a grower on fertilizer use.

There is too much variability in the soils, organic matter and crops to make specific recommendations, she added.

Pinel agrees with Ross about fertilizer reporting. “Fertilizer use is not as black and white as pesticide use reporting. It involves different commodities, different soils, plant health and many other factors,”

Pinel admits that if a grower became out of compliance in the irrigated lands program and he paid for CCA nutrient management advice, there could be an issue of how much responsibility gets pushed back to the CCA who developed the plan.