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6 Recommendations In undertaking this report, the National Research Council's Commit- tee on Irrigation-Induced Water Quality Problems sought to provide a discussion of the insights gained from the San Joaquin Valley experience and to highlight some lessons that should not be overlooked when similar environmental problems arise in the future. The committee attempted to focus on questions of a long-term, interdisciplinary nature ones that address the national public interest and it wishes to remind scientists, resource managers, politicians, and citizens of the importance of this broad perspective. The drainage issue in California has been unresolved for decades, and the San Joaquin Valley Drainage Program (SJVDP) is only the latest in a series of attempts to study and solve this problem. It is an especially important effort right now, however, because of the realization that similar irrigation-related problems are occurring elsewhere and other problem solvers will look to the SJVDP as a model. The effort being led by the SJVDP is not perfect in fact, it suffers from numerous inefficiencies and conflicts. But the program has broadened the scientific knowledge base and has served to focus public discussion. There are lessons to be learned from the San Joaquin Valley experience that can help make future efforts to solve irrigation-induced water quality problems more successful. During the committee's oversight of the SJVDP, it became apparent that this committee defined the problem in the San Joaquin Valley differ- ently than did the staff at the SJVDP and many of the people involved 118

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RECOMMENDATIONS 119 in the dilemma. Throughout its discussions, the committee implicitly de- fined the problem this way: irrigation in the San ,Joaquin Valley without adequate drainage has negative effects on the environment and society. The committee's general statement of the goals that alternative responses should strive to achieve is as follows: take steps to avoid or minimize further environmental degradation caused by irrigation water in the valley and recognize that irrigation has negative as well as positive social values. The committee refrained from emphasizing or expanding its own definition of the problem because, as is stressed many times in this report, this step must be an integral part of a process that must involve all the affected parties. A committee of outsiders cannot accomplish this task. In the committee's view (see Appendix C), however, the participants in the San Joaquin Valley have not adequately defined the problem. The SJVDP articulated four goals-maintaining crop production, enhancing wildlife habitat, improving water quality, and ensuring public health but setting goals is not the same as defining problems. Furthermore, problem definition should occur before goal setting. Although the SJVDP has not expressly chosen one of those goals as a top priority, this committee believes it did so indirectly through choices of research emphasis, funding priorities, and in the language in SJVDP documents. Given the program's site-specific perspective and intense local political and social pressures, it is understandable that the program has struggled to bring a broad view to its efforts. As a result, however, the problem has been implicitly defined too narrowly. Many of the participants from California would argue that the problem was agriculturally focused: environmental damage associated with irrigation drainage is threatening the vitality of agriculture in the San Jonquin Valley. This committee sees the sometimes negative environmental impacts associated with irrigation in arid regions as a generic problem that the nation must be better prepared to address. Its recommendations are drawn from a wide range of technical expertise and are aimed at policymakers, project managers, and the public. The committee has not attempted a step-by-step assessment of culpability for the events at Kesterson National Wildlife Refuge (NWR). This was not its mandate and would not help advance the cause of good scientific or policy decisionmaking; nor has the committee provided a detailed critique of the SJVDP's success in finding solutions to the area's problems, because that process is still ongoing. Instead, the committee has focused on two related but independent classes of recommendations. The first set of recommendations focuses on planning issues and study design. These recommendations suggest methods that should be used when formulating effective responses to irrigation-related water quality problems wherever they may arise. The second set of recommendations

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120 IRRIGATION-INDUCED WATER QUALITY PROBLEMS addresses policy issues and the opportunities for national action. These are extrapolated from events in the San Joaquin Valley and outline actions that can be implemented by federal and/or state governments to minimize the negative impacts associated with irrigation. The committee presents these recommendations with the thought that they can help foster awareness of the problems caused by irrigation drainage and can guide decisionmakers in seeking equitable, effective solutions. It is virtually inevitable that additional irrigation-induced water quality problems will appear in the future, as will other environmental problems of a similar nature, and it would indeed be unfortunate if the experience gained from the work in the San Joaquin Valley went unrecognized and unheeded. PLANNING ISSUES RELATED TO IRRIGATION-INDUCED WATER QUALITY PROBLEMS Federal and state agencies should strive to use sound study design when flying to resolve irrigation-induced water quality problems. Sound study design should emphasize a formal systems approach, be responsive to change, and recognize the dynamic properties of the hydrologic system. Federal and state agencies responding to irrigation-related prob- lems should develop an action plan that carefully evaluates the alternative responses available and that reflects increasing scientific understanding of ecosystems. They must work to promote public participation, reconcile competing societal needs, balance economic and non-economic costs, and consider the possibility of institutional and legal changes. Federal and state agencies should choose a course of action only after all the identified alternatives have been examined and displayed openly. There must be a clear understanding that "win-win" solutions capable of satisfying all parties are rare and that options often need to be site- or region-specific. All options present economic trade-offs and value choices, so that judgments are necessary. Federal and state agencies involved in efforts to find solutions to irrigation-induced water quality problems should pay particular attention to the feasibility of implementation. A sound implementation strategy should assure adequate and stable funding, coordination among agencies and levels of government, effective enforcement, competent personnel with clear responsibilities, and well-defined channels for citizen input and review. Federal and state agencies, including the U.S. Department of Agri- culture and the U.S. Environmental Protection Agency, need to be actively involved in some type of interagency program to regularly monitor the impacts of irrigation on water quality at all major irrigation projects. This program should contain elements devoted to anticipating future problems and to monitoring water quality over the long term. The National Irrigation

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RECOMMENDATIONS 121 Water Quality Program, or some equivalent, could perform these functions indefinitely. Components of the San Joaquin Valley Drainage Program also will need to be continued. One clear lesson that can be drawn from the Kesterson experience and applied broadly to irrigation-related water quality problems is the impor- tance of good problem solving and study design. Fundamental to this is the use of a systems approach. Formal systems analysis is necessary to ensure integrity in data collection and interpretation, and it enhances the linkages between study components. Only by thoroughly addressing the biological, physical, economic, institutional, legal, and social issues and the relation- ships among these factors can the problem be reduced to manageable dimensions. Formal attention is also necessary to understand the different spatial and temporal scales present and to identify the hierarchical levels operating. Such an approach needs to be interdisciplinary (as differentiated from multidisciplinary) and needs to incorporate a breadth of relevant ex- pertise. The acquisition of the information required to respond to complex environmental problems such as these requires meticulous attention to data quality (quality assurance and quality control). A monitoring system should be established and maintained to assess changes in the system throughout the study period and beyond. The need for sound study design cannot be overstated. Perhaps the most commonly avoided element of the study process is the need to assess and display all the possible alternative responses, even those that may be publicly or politically unpalatable. The point is not to force an unwanted solution, but to ensure credibility for the alternative that ultimately is chosen. Successful problem resolution requires that the interests of all the parties be considered and the costs allocated in an equitable fashion. Only by openly discussing all the potential options, including their costs, benefits, and trade-offs, can the public have faith in the final decision. Development of a process to manage the inevitable conflicting demands that occur in interdisciplinary studies is a necessity. Policymakers must recognize that rarely are there any "win-win" solutions that will fully satisfy all parties. In the final consensus, all parties gain and lose some benefits. In the San Joaquin Valley, for instance, the option of ocean disposal of the selenium-contaminated drainage water has been essentially ignored, and the option of land retirement has been treated cautiously at best. Although these options may be impractical for economic, legal, political, or social reasons, they should not be eliminated a priori as alternatives. There are lessons to be learned from an analysis of all possible choices. Even if an option appears to be unacceptable, the physical, biological, and economic consequences should still be assessed and compared with other options. Perhaps some innovative solution would unexpectedly prove

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122 IRRIGATION-INDUCED WATER QUALITY PROBLEMS possible. More likely, the exercise would spell out clearly the disadvantages and help in the process of selecting a different choice. Unpopular options should receive fair attention and objective study, and the local, regional, and national consequences should be openly assessed. The fragmentation of interests of the different institutional players has been a major management problem in the San Joaquin Valley situation. These different institutions reflect the concerns and interests of various client groups. These specialized interest groups have limited perspectives, and each special interest by itself was not likely to develop an effective long- term management plan to address the complex problems faced. A lasting solution can emerge only by bringing all competing interests together to air their concerns openly and develop solutions. A public participation program should draw all affected interest groups into an exchange of views with the involved agencies and should move to- ward resolving the conflict through consensus building. Public participation builds confidence that the decision process was fair and complete. In the SJVDP, a citizens' advisory committee was not established until mid-1987, more than 2 years into the program. The committee might have been more effective (in terms of problem definition and study plan develop- ment) if it had been created sooner. The absence of this feature was somewhat frustrating to the public and may have given the impression that the problem-solving process was more "political" than it actually was. Environmental concerns are changing, and protective measures have become more acceptable because of our increasing understanding of ecosys- tems, changing societal values, and recurrent revelations of significant en- vironmental problems. Strategies to solve irrigation-induced water quality problems should acknowledge society's diverse interest groups and conflict- ing environmental viewpoints. They also should respond to the increasing pressures on the environment and include flexibility for responding to future change. Uniform solutions are seldom applicable over wide areas. Geologic and hydrologic properties can vary dramatically, even over short distances. Resource managers should recognize the unique characteristics of specific sites and devise management practices adapted to these local characteristics. This will help provide more effective and palatable packages of solutions. However, such local management practices also need to recognize regional and national needs. Successful problem resolution requires that the interests of all the parties be considered and the costs allocated in an equitable fashion. In assessing the equity issue, it is important that all costs and impacts be explicitly recognized. The interest groups affected by irrigated agriculture have diverse environmental values, different sociopolitical perspectives,

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RECOMMENDATIONS 123 and differing levels of capital investments that are threatened by irrigation- induced water quality problems. Legal and institutional changes will prove necessary to solve the wa- ter management problems of the future, although the specific nature of these changes will require careful study and planning. Irrigation systems have evolved with supporting institutions that provide a protective legal framework for water rights and land tenure. The inertia of these enti- ties sometimes severely constrains the approaches considered possible for dealing with irrigation-induced water quality problems. POLICY ISSUES RELATED TO IRRIGATION-INDUCED WATER QUALITY PROBLEMS If any major irrigation projects are planned in the future, at the onset federal and state agencies should calculate the costs of drainage for irrigation return flows and should commit funds to build and maintain the system. Federal and state agencies should design and implement manage- ment systems that minimize the adverse impacts of irrigation, especially those that occur when irrigating land in closed basins, and acknowledge the inevitable ecological trade-offs that accompany irrigation. Federal and state agencies should systematically monitor all major irrigation projects for substances that could cause water quality problems, including pesticides and fertilizers as well as trace elements. Federal and state agencies that facilitate or regulate irrigation should periodically calculate and publicize the environmental costs as well as the agricultural benefits associated with irrigation, and should work to accommodate the nation's increasing commitment to protecting environ- mental values. . . Irrigation return flows should not be exempt from federal and state water quality regulations, and such regulations should be enforced. Federal and state agencies should increase their efforts to provide water supplies for wildlife, enhance and enlarge wildlife habitats, and protect the biological and recreational values associated with in-stream flows and good water quality. Federal and state agencies should acknowledge all external costs including social and environmental costs when calculating the costs and benefits of agricultural subsidies. Federal and state agencies should identify irrigated lands that are degrading water quality significantly and should implement cost-effective, environmentally sound actions to correct or minimize the degradation. Such a program would incorporate a range of alternative approaches for pre- venting, mitigating, and treating irrigation drainage problems. This would

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124 IRRIGATION-INDUCED WATER QUALITY PROBLEMS include, if necessary, phasing out production on particularly problematic lands. Irrigated agriculture remains the largest water user in the West. But numerous other, competing interests are increasing pressure on a dimin- ishing and deteriorating water resource. With this competition comes an increasing need, real and perceived, to find solutions acceptable not only to the irrigation interests but to other parties as well. An obvious, but curiously ignored, lesson reinforced by the events at Kesterson NWR is that federal and state agencies should not plan or build an irrigation project unless they are prepared to finish it. Drainage systems are best designed and installed after the water table in the area has risen, when the modified local hydrology can be better understood. Even so, the cost of the drainage system should be estimated at project initiation, and a commitment for completion should be assured. The cost of maintenance also should be included in the original economic analyses and financial commitments. It is a long- and well-known fact that irrigation in arid lands tends to degrade the quality of the return-flow water by increasing its salinity or nutrient concentrations, or by increasing the concentrations of some substances to toxic levels. These problems are particularly severe in closed basins, where the lack of an outlet inevitably causes environmental degra- dation as dissolved substances accumulate in the soil, standing water, and ground water. The environmental damage at Kesterson NWR in the San Joaquin Valley, for example, happened as quickly as it did because the irrigation return flows were confined to a closed basin. Management that fails to address ultimate disposal is simply moving the problem from one place to another, or from one generation to the next. When planning projects where drainage flows will be confined in closed basins, federal and state agencies should be especially careful to design these systems to minimize the adverse effects of ever-increasing salt concentrations. They should recognize that the practice of irrigation will require the ultimate sacrifice of some water quality and ecological values. At present there are no known, practical, technological processes available to repair the damage caused by the buildup of toxic substances in closed basins. Historically, salinity standards have been seen more as a state and federal responsibility than as the responsibility of individual irrigators. Federal and state agencies should be prepared to provide an adequate level of monitoring at all major irrigation projects as a way of anticipating future problems. Selenium was the natural contaminant that brought the problems in the San Joaquin Valley to public attention, but given the geology of the West, it is only one element among many (e.g., arsenic, boron, cadmium,

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RECOMMENDATIONS 125 lead, mercury, and molybdenum) that may already be causing harm at wildlife refuges and in other environments. Attention to pesticide and fertilizer residues will also prove necessary. The government and irrigators should also be aware that current knowledge is incomplete and that the problem-causing elements known today may be joined by others in the future. Policymakers and program managers should design monitoring sys- tems capable of early identification of incipient environmental, social, and economic problems. They should provide support for the timely interpre- tation and evaluation of monitoring data. Federal and state agencies with mandates for managing water quality should support sustained research to assess whether management goals are being achieved, and they should provide adequate funding to ensure that corrections can be implemented when problems are identified. If additional problem areas are identified in the future, the nation will need to be prepared to act. The nature of the response will of course vary depending on the site and on numerous technical, economic, and social variables. However, all attempts to correct or minimize the degradation must be both economically and environmentally sound. Plans to phase out irrigated agriculture on the most problematic lands should be considered if it is not possible or practical to treat or dispose of drainage waters. Planners should keep both short-term and long-term goals in perspective. Existing water appropriation policy places too little value on the public and beneficial use of in-stream flow. Irrigation in the United States typically is not subject to regulatory control that would protect water quality for other uses. Federal agencies responsible for facilitating irrigation typically do not-but should consider water quality degradation as a cost of water use. Federal and state agencies responsible for protecting and enhancing wildlife must redouble their efforts to protect and increase the supply of quality habitats. Those agencies that regulate water use should dedicate sufficient water to in-stream use to protect biological and recreation resources. The U.S. Department of the Interior has facilitated numerous irrigation projects in the western United States that may produce environmental degradation similar to that observed at Kesterson NWR. The nation must be better prepared to deal with irrigation-induced water quality problems that will occur on both public and private lands. The U.S. Bureau of Reclamation (USER) provided water for about 12 million acres in 1986, which is only about 25 percent of the West's irrigation water. But problems are occurring or are likely to occur also on the remaining 75 percent of land irrigated through private or state funds. If the focus is solely on the USBR, potential and serious problems may be ignored elsewhere.

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126 IRRIGATION-INDUCED WATER QUALITY PROBLEMS RESPONDING TO IRRIGATION INDUCED WATER QUALITY PROBLEMS: A SHARED RESPONSIBILITY The events that occurred in California's San Joaquin Valley were caused by a combination of human and natural factors, and they proved to be an especially poignant reminder of the interrelationships between people and the land and water resources upon which they depend. They are also a harbinger of what the future holds for irrigated agriculture in other areas of the West and the world. In its attempts to provide guidance to the SJVDP, this committee has pointed out many Haws and problems with that group's effort to find a solu- tion to the irrigation-induced water quality degradation in the San Joaquin Valley. Rae criticisms, conveyed in letter reports (see Appendix C), were directed to help the SJVDP carry out its tasks. They also were intended to help establish a model to guide the effective conduct of similar study efforts in the future. The issues cited included problems with inadequate expertise, inappropriate study design, and quality assurance and quality control. Inadequate attention to critical legal, institutional, and economic issues early in the study was also a weakness. The committee would like to point out, however, that despite these varied criticisms, there is a need for an interagency approach like that embodied in the SJVDP. The SJVDP has been a serious attempt to seek solutions to a difficult problem, one that incorporated two particularly essential elements: interagency coordination and public participation. The SJVDP has generated new geological and biological data that broaden the scientific understanding of drainage issues. In addition, it has provided a forum to increase public understanding of the scope and severity of the problems associated with irrigation drainage. The SJVDP also has helped explain the importance of drainage for the future of irrigation in the San Joaquin Valley. Considering the difficulty of the situation and its history, the committee appreciated the efforts of California and the Department of the Interior to work together toward problem resolution. The efforts under way by the Department of the Interior's National Irrigation Water Quality Program are also important as part of the nation's overall response to these types of problems. This effort is a step already under way to meet one of the principal arguments that serves as a founda- tion for this report: other irrigation-induced water quality problems will be discovered in the future, and the nation must do a better job of identifying, understanding, and responding to these problems. One fact made clear during this committee's oversight of the San Joaquin Valley Drainage Program is that finding a solution to the valley's drainage problems, and to similar problems elsewhere in the West, is not merely a technical question. Indeed, the more difficult questions are

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RECOMMENDATIONS 127 often political, social, and economic. In all cases, however, the various components are intimately interrelated. Only by defining and addressing the system as a whole, and realistically assessing its complexity, can progress toward real and lasting solutions be made. The U.S. Bureau of Reclamation, which received considerable atten- tion in this report because of its primary role in the Kesterson NWR experience, is not alone in facing the significant challenges arising from irrigation-induced water quality problems. The problems are not all caused by federal and state agencies, nor can they necessarily be solved at those levels alone. The federal and state agencies involved in irrigation are man- dated to carry out the will of the public, and so the ultimate responsibility for solving these types of problems is one that the public shares.

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