Advocacy in Action: State Affairs, Federal Policy and Legal Services

Water

The California Farm Bureau submitted comments last month to the California State Water Resources Control Board’s Water Quality Certification Program at the Division of Water Rights, saying that diversion of unimpaired flows on the Merced River is not an appropriate condition of approval for federal dam relicensing by the Merced Irrigation District. Farm Bureau also urged the state to work with MID to reactivate a voluntary settlement agreement as an alternative to a flows-only approach. 

MID General Manager John Sweigard called on residents to support a voluntary agreement and submit comments before the state water board potentially issues a 401 water-quality certification before April 15 related to the district’s federal relicensing of its Lake McClure hydroelectric facilities. Residents may support MID’s proposed voluntary agreement and oppose the Bay-Delta Plan and 401 certification at www.mercedid.org/raise-your-voice.

On water rights fees, Farm Bureau submitted written comments on the water board’s 2025-26 process for setting water rights fees. The comments focus on several issues left unaddressed by the board’s 2024-25 process. Concerns include a significant increase in water rights applications fees, including fees for temporary groundwater recharge permits. Additional concerns include the board’s prior commitments to review, better support and potentially
reduce its probationary fees of $300 per well and $20 per acre-foot pumped.

Farm Bureau also reviewed two water board alternative probationary designations for the Kern Subbasin related to the Sustainable Groundwater Management Act. The board decided to defer action until September on a potential probationary designation for the subbasin. The decision was based on significant progress on seven separate groundwater sustainability plans by 20 different local groundwater sustainability agencies, or GSAs, in the subbasin. 

The Chowchilla Subbasin in northwestern Madera County and Delta-Mendota Subbasin on the west side of the northern valley remain pending and do not yet have draft staff reports or scheduled probationary hearings. 

Once the board has designated a subbasin as probationary, fees and metering requirements go into effect as the GSAs in a basin revise their groundwater sustainability plans. A basin has a minimum of one year to avoid a state-imposed plan. Challenging issues in several San Joaquin Valley basins include domestic well impacts, coordination issues, monitoring and accounting issues, chronic overdraft and potential impacts to critical infrastructure from ongoing land subsidence. 

Endangered species

The California Farm Bureau submitted comments this month on a proposal by the U.S. Fish and Wildlife Service to list the monarch butterfly as threatened under the Endangered Species Act, with species-specific protections and flexibilities to encourage conservation. The proposal, which was published in the Federal Register in December, also designates critical habitat along the Central Coast. It is likely that the public comment period will be reopened to accept additional comments.

Transmission planning

The California Farm Bureau, along with other conservation groups, submitted an application for rehearing to the California Public Utilities Commission about its final decision on implementation of a general order that controls its oversight of the process for approval of electric infrastructure, including transmission lines. 

The legislation that initiated the proceeding—Senate Bill 529—did not authorize the commission to all but eliminate Certificates of Public Convenience and Necessity for electrical projects. Yet the commission’s decision, issued last month, adopts definitions so broad and ambiguous that utilities and transmission line developers could characterize almost all new electrical projects as requiring only permits to construct—which do not require analysis for cost or need—or no permits at all, said Karen Mills, vice president of legal advocacy for the California Farm Bureau.