07-31-20 ATTN: Colorado Conservation Districts: Colorado Monitoring Framework and the Ag Task Force Needs YOUR Input ASAP!

Attention: Colorado Conservation Districts…

Over the past few years, on behalf of the Colorado Monitoring Framework and the Ag Task Force, I have had the opportunity to speak with many of you on the issues surrounding the nutrient regulations adopted by the Colorado Water Quality Control Commission and the potential impacts these regulations may have on agriculture. I appreciate many of you inviting me out to speak during your membership meetings and have enjoyed being able to bring information to you about the nutrient regulations and to learn about what sort of best management practices for nutrients are being implemented as well as some of the challenges associated with nutrient management. I wanted to take this opportunity to update everyone on the upcoming Water Quality Control Commission review of the nutrient regulations and to ask you for your help.

As you probably know, in 2012 the Commission adopted Regulation 85 which prescribed limitations for nitrogen and phosphorus for wastewater treatment facilities across Colorado. Included in this regulation was a request for voluntary reductions in nutrient loading from nonpoint sources such as agriculture. The tie to agriculture is that the Commission may decide to regulate nutrients for agricultural operations if sufficient progress on nutrient control is not being made. The Commission will be reviewing Regulation 85 in October 2020 to determine what sort of progress is being made. Although we do not expect a decision to be made at this hearing in regards to the need to regulate agriculture, this is the opportunity to provide information and inform the Commission as to what agriculture is doing to help make the case that agriculture does not need to be regulated.

Several entities will be presenting information on what agriculture is doing on best management practices for reducing nutrient runoff, various studies that are ongoing, and on the benefits of these actions. These entities include the Ag Task Force (including Colorado Wheat Growers, Colorado Corn, and Colorado Livestock), Colorado State University, an Ag Consultant, and State Agencies including the Department of Agriculture and the Water Quality Control Division. Each of these groups will be presenting information on some of the above mentioned topics. What we are missing, and what is probably the most important voice that needs to be heard, is that of actual producers.

For the hearing, comments may be submitted by anyone either via written comment in late September or verbally at the hearing itself. What I am hoping for is that many of you would be willing to do one or the other. I understand that many will be reluctant to identify themselves or bring attention to your operations, however, you can remain fairly anonymous. For example, if you were to submit a written comment (something describing your operation, BMPs, nutrient reduction efforts and/or challenges with nutrient reduction implementation) you could simply identify yourself by region (ex: southeast Colorado), county, or watershed. These comments could be submitted directly to the Commission via email or could be submitted to me for inclusion in the Ag TF comments. Verbal comments at the hearing (conducted by video conference over Zoom) on October 12, would be of the same sort of information and likely limited to 3 minutes.

It would be great to have a large number of comments (written and/or verbal) to provide the Commission with information that the agriculture community is doing what they can to reduce nutrients and that regulation of agriculture is unnecessary. Our hope is that the Commission continues to support the voluntary path for nonpoint sources, as opposed to the regulatory path. Again, your assistance could be critical for this showing.

Thank you for reading and considering participation in the hearing process. If you have any questions or want to know more please feel free to reach out to me either individually, through the Conservation District, or through another tradegroup.

Thanks

Andrew Neuhart, CMF Coordinator

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