CSWA Region 2 Third-Party Program
Vineyard properties in the Napa River and Sonoma Creek watersheds with five or more acres planted to winegrapes are required to comply with a new water quality control regulation (‘the Order’), which was adopted in July 2017. There is a map created by the Water Board that is intended as a tool to help determine if a property is likely to be required to enroll in the Order. (Note: If a parcel is depicted on this map it does not necessarily mean enrollment in the Order is required; likewise, if a parcel is not depicted it does not necessarily mean that the property is not subject to the Order.) Any parcel within the applicable watersheds that has five acres or more planted in grapevines is required to enroll in the Order.
The Regional Water Board approved Third-Party Programs to assist growers in complying with the new regulation. The approved Third-Party Programs include the California Sustainable Winegrowing Alliance (CSWA), the Sonoma and Napa Resource Conservation Districts (RCD) LandSmart program and the California Land Stewardship Institute’s Fish Friendly Farming program. All Third-Party Programs will work with growers to help them meet the permit requirements to develop and verify a Farm Plan. Working with Third-Party Programs can reduce the fees growers pay to the Regional Board, lower the amount of monitoring and paperwork required, and provide helpful guidance through the compliance process. Growers already involved in any of these programs will be able to more easily comply with the permit requirements. However, it is important to note that current participation in one of these programs does not automatically equate to compliance with the permit. Please contact the relevant organization to understand what additional steps are needed.
A Fact Sheet that summarizes the Order requirements is also available. See the full Order and learn more about the Order process and sign up for email updates from the Water Board.
Brief Summary of Key Deadlines for Vineyards:
- By July 2020: Develop and Verify a Farm Plan and implement actions to address vineyard erosion, pesticide and nutrient risks.
- By July 2023: Address bed and bank erosion issues identified in Farm Plan (where applicable).
- By July 2027: Address unpaved road erosion issues identified in Farm Plan (where applicable).
*Note: All deadlines have been extended by one year for properties within the burn perimeter of the 2017 fires. View this letter and this map to see if a property qualifies.
Click HERE to view a helpful summary of deadlines for compliance table.
CSWA Farm Plan Process:
- Any grower in the Napa River and Sonoma Creek Watersheds may use the CSWA Farm Plan Template to develop a farm plan for their property.
- The Farm Plan Template is designed to be self-completed by the grower, with guidance and resources included throughout. If technical assistance is needed with Farm Plan development, growers can hire one of CSWA’s Qualified Professionals (see below) to help with map development and/or identification of necessary actions to address vineyard erosion, pesticide and nutrient risks, where applicable.
- Once the Farm Plan is complete, growers hire one of CSWA’s Qualified Professionals to conduct an on-site visit to verify the Farm Plan.
CSWA Farm Plan Template:
The CSWA Farm Plan Template is based on the California Code of Sustainable Winegrowing Workbook, Certified California Sustainable Winegrowing, and the LandSmart® for Vineyards Farm Plan, Version 4.0 developed by the Sonoma Resource Conservation District (RCD), Napa County RCD, Mendocino County RCD and Gold Ridge RCD in collaboration with the USDA Natural Resources Conservation Service (NRCS), land managers, and environmental agencies. The template has been developed to comply with the San Francisco Bay Regional Water Quality Control Board’s General Waste Discharge Requirements for Vineyard Properties in the Napa River and Sonoma Creek Watersheds – Order R2-2017-0033 (referred to as ‘the Order’).
The Order requires that growers prepare Farm Plans for their Vineyard Properties (in the Napa River and Sonoma Creek Watersheds), with the goals of:
- describing the Vineyard Property and delineating all of its relevant features,
- identifying current practices – both those that may be causing or contributing to erosion and those that may be helping prevent erosion, and
- creating a plan for future actions (Action Items), as needed, to prevent erosion, protect water quality, and control storm runoff increases – to achieve the Performance Standards.
The CSWA Farm Plan Template includes the following sections, required to comply with the Vineyard WDR:
Required Base Maps
- Property Boundary, Vineyard Blocks, Land Use and Roads
- Topography, Soil Types, Erosion Hazards, and Erosion Control Features
- Streams, Drainage System, Storm Runoff Inlets & Outlets
- Performance Standards Action Item Location(s)
California Code of Sustainable Winegrowing
- Nutrient and Pest Management Requirements
- Other Relevant Code Criteria
LandSmart® for Vineyards
- Managing Erosion in Vineyard Blocks and Avenues
- Managing Natural Waterways
- Ditches and Spillways
- Roads and Crossings
Note: It is important to use the associated INSTRUCTIONS document when completing the CSWA Farm Plan Template.
CSWA Qualified Professionals:
The CSWA Third-Party Program has trained Water Board approved Qualified Professionals available to verify CSWA Farm Plans and assist with farm plan development (as needed). All are California registered professionals in a discipline associated with erosion and sediment control, for example, a professional engineer, licensed geologist, or certified professional in erosion or sediment control. A list of approved CSWA Qualified Professionals, including bios with relevant experience is available HERE. Growers will contract independently with CSWA Qualified Professionals.
Farm Plan Verification:
A completed CSWA Farm Plan must be verified by a Qualified Professional. The verification process entails a desk review and an onsite visit. Once it has been verified that the Farm Plan, when all documented action items are fully implemented, would bring a vineyard property into compliance with the Order, then the Qualified Professional will submit a verification letter to the Water Board. The Farm Plan is not submitted to the water board and may remain on-farm.
- Click HERE to view a sample verification letter that a Qualified Professional may submit upon successful verification.
- Click HERE to view a verification checklist template that a Qualified Professional may use when verifying a Farm Plan.
CSWA Voucher Program:
As part of a California Department of Food and Agriculture (CDFA) Specialty Crop Block Grant, the California Sustainable Winegrowing Alliance is offering a $250 voucher to winegrape growers for development or verification of a Water Quality Farm Plan by a Qualified Professional (QP) to reduce sediment and erosion from vineyard properties and comply with the new San Francisco Bay Regional Water Quality Control Board (“Region 2”) regulations for the Napa River and Sonoma Creek watersheds. Technical assistance will be provided by CSWA’s Water Board-approved Qualified Professionals (QPs), who have expertise and experience in sediment and erosion control. If you are a grower and would like to receive a voucher, please request the $250 discount from your QP. To learn more, click HERE.
For More Information:
CSWA hosted a webinar to provide background about the Vineyard WDR and the Third-Party Program.
- You can view or download the webinar recording from Dropbox. (Note: It begins around minute 2:40 and details about the CSWA program begin around minute 29.)
- You can review or download the webinar slides at Dropbox.
- Contact Kate Venugopal at CSWA with any questions, firstname.lastname@example.org or 415-356-7548.
- In order to complete the permit enrollment form, will permittees need to indicate a specific Third-Party Program they plan to work with (to complete a verified farm plan) or can they just indicate that they plan to work with a Third-Party Program? The Notice of Intent to Comply (enrollment form), which was due in mid-2018, did not require you to specify which Third-Party Program you would like to work with. However, this information must be specified in order to complete the annual reporting form, which is due on December 15 of the year that the property is enrolled, and thereafter annually on the same date.
- Can permittees change their mind about which Third-Party Program they are going to work with after they file the notice of intent (e.g., the enrollment form)? If so, do they need to notify the Water Board immediately or can they work with a different Third-Party Program, and then provide an update during annual reporting? Vineyard operator/owners can make such a change at any time, and then report the change when submitting the annual compliance reporting form. For any property enrolled in Tier 1, if the owner/operator wishes to make a change regarding the Third-Party Program they are working with, the operator/owner would need to submit an updated verification letter prepared by the new Third-Party Program.
- If my vineyards are CERTIFIED SUSTAINABLE, does that mean that I am in compliance with the Region 2 General Permit for Vineyards? No, certification does NOT equate to compliance. Any grower may use the CSWA Farm Plan template to develop a farm plan for their property. The Farm Plan template is designed to be completed by the grower, with guidance and resources included throughout. A portion of the permit requirements addressed in the CSWA Farm Plan template are covered in the Code of Sustainable Winegrowing Workbook (nutrient and pest management sections). Once complete, the full Farm Plan must be verified by a CSWA Qualified Professional after an onsite visit to verify the farm plan.
- If I’m interested in using the CSWA Region 2 Third-Party Program option, do my vineyards need to be Certified California Sustainable Winegrowing (CERTIFIED SUSTAINABLE)? No, there is no requirement that your vineyards are CERTIFIED SUSTAINABLE. Any grower may use the CSWA Farm Plan template to develop a farm plan for their property.