State Agricultural Water
Quality Programs
Recommendations for Arizona

foodsystems.asu.edu

Swette Center for Sustainable Food Systems, Arizona State University
September 2022
This publication is a Capstone Report by the Graduate Certificate in Food Policy and Sustainability Leadership
class of 2021-2022.
Suggested Citation:
Swette Center for Sustainable Food Systems. State Agricultural Water Quality Programs: Recommendations
for Arizona. September, 2022. (Swette Center, 2022)

Authors
Zac DeJovine
Student/Tutor
DJVNTutoring.com
Jillian Dy
Policy Specialist
FoodCorps
Ami Freeberg
Metro Farms & Food Systems Program Manager
Cultivate Kansas City
Shelby Kaplan
Graduate Student
Arizona State University
Deborah Sadler
Food Hub Operations Manager
Food Connects
Nithesh Wazenn
Graduate Student
Arizona State University

Acknowledgements
Esteve Giraud
Research Associate
Swette Center for Sustainable Food Systems
Colleen Hanley
Senior Food Systems Specialist
Swette Center for Sustainable Food Systems
Kathleen Merrigan
Executive Director
Swette Center for Sustainable Food Systems
Suzanne Palmieri
Director of Strategic Initiatives
Swette Center for Sustainable Food Systems

Table of Contents
Executive Summary
Introduction ..................................................................................................................... 1
Research Methods .......................................................................................................... 7
Literature Review ............................................................................................................ 9
US Agricultural Water Regulation: Federal vs. State Responsibilities ......................... 9
Water Coalition Building ............................................................................................ 12
Agricultural Water: Relationship of Quantity and Quality Issues ................................ 14
Economics and Environmental Markets: Lessons from Water-Quality Trading ......... 20
Incentives for Water Quality in Agriculture ................................................................. 25
Results – State Plan Case Studies ............................................................................... 33
Arizona ...................................................................................................................... 35
Minnesota .................................................................................................................. 61
Colorado .................................................................................................................... 68
Kansas....................................................................................................................... 69
Michigan .................................................................................................................... 72
Missouri ..................................................................................................................... 73
Nebraska ................................................................................................................... 74
New Mexico ............................................................................................................... 76
Vermont ..................................................................................................................... 77
Discussion and Recommendations ............................................................................... 80
Coded Responses from Interviews ............................................................................ 80
Improve Agricultural Water Quality ............................................................................ 83
Reinvent Current Structures, Systems, and Ways of Thinking .................................. 91
Ending Unsustainable Farming .................................................................................. 94
Conclusion .................................................................................................................... 97
Summary of Findings ................................................................................................. 97
Concluding Thoughts ................................................................................................. 97
Further Research Needed ........................................................................................... 101
References .................................................................................................................. 102
Appendix ..................................................................................................................... 114
Appendix 1: Interview Questions ............................................................................. 114
Appendix 2: Glossary of Abbreviations and Acronyms ............................................ 115
About the Authors ....................................................................................................... 118

Executive Summary
As record-breaking drought conditions continue year after year in Arizona, the state
needs to act now to fully protect its limited water resources. While current dialogue
focuses on issues of water quantity in Arizona, with limited quantity of water resources
water quality becomes even more important. Farmers are a major user of water, and
there remains a lot of room for improvement in agricultural water usage. This report
researched existing water quality programs and voluntary state agricultural water quality
initiatives both in Arizona and throughout the United States to propose policy and
program recommendations for agricultural water management in Arizona. Research on
state water quality initiatives included a literature review, reviewing past and current
water policies and regulations, and over forty interviews with water quality experts. The
results of the research are presented in this report.
To understand the issues around agriculture and water usage, this report first looks at
both federal and state policies around water usage, water quality standards, and how
different states have varying—and in some cases conflicting—regulations on water
rights. From here this report looks to acknowledge current concerns about water
quantity, but to also explore the unique challenges that poor water quality can pose to
farmers in Arizona. Various regulatory solutions have been proposed to address water
quality, from measuring ambient pollution levels to offering Water Quality Trading credit
programs. This report analyzes several of these programs to see how these regulatory
tactics address water quality challenges and in what areas these tax and incentive
programs fall short. Beyond these government programs, we also explore what
motivates the end uses themselves: farmers who either own or lease irrigated land.
We then explore the different state agencies that work to regulate water quality and
usage, as well as past and current state initiatives. Our research team then interviewed
44 individuals from ten different states to understand how these different policies and
initiatives are impacting water usage. From these interviews and research,
recommendations are made around improving, reinventing, and ending aspects of
Arizona agriculture’s water usage. Best practices learned from different climates are
taken and applied to Arizona’s arid climate and need for sustainable water resources.
Among these proposed recommendations, we see a strong need for increasing both
public engagement and awareness of water quality issues, as well as the need for
greater government agency coordination. We propose the development of the “Arizona
Water Protection Plan,” a voluntary water quality certification program for Arizona
farmers, using best practices from other state programs. Additionally, in areas where
incremental improvements will not avoid potential environmental collapse, Arizona

agriculture must reinvent itself to stay viable and maintain healthy Arizona water—both
groundwater and aquifers. Finally, the report proposes ending water intensive farming
where it is no longer feasible, with technical support and incentive payments to assist
farmers.

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Introduction
It is no coincidence that throughout human history, many important civilizations rose
and fell to the ebb and flow of one or more major rivers within their domain. The Tigris
and the Euphrates, the Indus and the Nile, all rivers instantly associated with the ancient
societies that once flourished upon their shores. As the lifeblood of these natural
ecosystems, rivers provided the water and supported the growth and expansion that
would have otherwise never taken place. While less famous than the Pharaohs and
their pyramids along the Nile, this same scenario can be said of Phoenix and the Valley
of the Sun: Phoenix was not the first major settlement to spring up along the now dry
banks of the Gila River, as the Hohokam people once utilized the flow of both the Gila
and Salt Rivers to fill their intricate canal system and bring a planned desert oasis of
plant growth to life. The Hohokam canal system was affected by the geological event
known as the "Great Drought":
The region affected by the Great Drought encompassed the area that extended
from what is now Oregon to southern California and east to what is now eastern
Texas; dendrochronology, or tree-ring studies, indicate that it began in AD 1276
and continued through 1299 (Britannica, 2012, para. 1).
Several hundred years later, modern Phoenix faces similar problems as the ancient
Egyptians and the Hohokam people. Founded where it is in part due to the existence of
these canals and the early settler agricultural efforts they aided, Phoenix is now dealing
with drought conditions that, much like the "Great Drought," are similarly impacting
agricultural production methods in the state. A burgeoning megalopolis that has seen
massive growth, with no signs of slowing down, and a thirst for fresh water to match,
Arizona has gone from Wild West to Desert Destination, growing from about 750,000
residents in 1950 to almost 7.5 million in 2022. Most of this growth has and will continue
to take place in the Valley as new residents flock to Phoenix and the far-out fringes
dispersed throughout the desert. Queen Creek, Buckeye, Casa Grande, Maricopa and
Goodyear were five of the top eleven fastest growing American cities last year, and
Phoenix added the second most people in the nation with 13,224 new residents (US
Census, 2022). This meteoric growth coincides with the most drastic water conditions
the state has ever seen. For the first time in history, the U.S. Department of the Interior
declared a water shortage for the Colorado River, a decision that has sent ripples
across the state water supply, leading to struggling farmers and fallowed fields.
As serious supply questions surround the issue of how to sustainably source water for
so many new sun-dwellers, it helps to survey the past to determine what steps have
been taken to get us here. While many have tried to mitigate this issue, they have
merely delayed the water shortage that Arizona now faces. Water conservation,

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supplanting agricultural land in favor of residential development, and landmark
legislation like the Groundwater Management Act of 1980 have all contributed to
lengthening the lifespan of the dwindling water supply, but the pressures brought to
bear by population growth and climate change have come to a head. Perhaps the most
significant water legislation in state history, the Groundwater Management Act of 1980
represents the attempts and ultimate failures to stave off this water crisis. The Act
established Active Management Areas (AMAs), centered around the major population
centers, in which the expansion of agriculture was limited, and where the most
ambitious goals for water conservation were set (ADWR, 2016b). Safe yield, the
concept of ensuring that the same (if not greater) amount of water is replenished to the
groundwater sources from which it is drawn, had a goal of being attained by 2025 for
the Phoenix, Prescott and Tucson AMAs when the concept was created. Nearly 45
years later, the results are not promising: of those three AMAs, only Tucson is close to
hydraulic homeostasis, with Phoenix and Prescott essentially deemed lost causes
(ADWR, 2016a).
The situation outside of the AMAs is no less dire. From communities like PineStrawberry, to the record low levels of Lake Mead, signs of water distress are on display
across the state. New water hookups for homes are no longer permitted in PineStrawberry, a mountainous town whose climate is so distinct from Phoenix that it would
seem to be better suited to stave off drought conditions (Aleshire, 2022). Lake Mead,
the reservoir on the Nevada-Arizona border responsible for generating large amounts of
hydroelectric power and providing emergency water reserves, is at the lowest level ever
recorded. As of May 2022, 26.8% of Mead is full, besting the previous recorded low of
33.8% in July 2016. This risks not only water for millions of residents, but the power
supply generated by the dam as well. This dearth of water has developed due to
decreased snowpack as well as demand for development outpacing the climate change
challenges of decreased precipitation in all forms along the Colorado River basin
(Carlowicz, 2022).
To understand the challenges Arizona faces, it helps to understand the stark nature of
the desert climate. The National Weather Service recorded a total annual rainfall in
2021 of 7.1 inches in Phoenix, and just 2.44 in Yuma, highlighting the contrast between
these busy agricultural centers and the rainfall they receive (National Weather Service,
2023). Only Los Angeles and Las Vegas are comparable American cities in terms of
desert population, and those two states rank above Arizona in terms of liquid assets.
While Arizona is the 6th largest state, checking in at 113,990 square miles, it is just 49th
by total liquid landmass, with only 0.3% (396.22 square miles, 48th by total area) of the
state consisting of water, placing it just ahead of New Mexico, last at 0.2%. While it's
clear that under normal circumstances water would be scarce, the ongoing drought has

Page |3

occurred at a time when the Valley needed even more water to support the expanding
growth, not less. To add to these challenges, agriculture uses roughly two-thirds of the
water in Arizona, and most of this activity takes place in Maricopa and Pinal counties,
regions of the state that also happen to house the most extreme climate Arizona has to
offer. Comparing a map of Arizona agricultural activity with the Köppen climate
classifications for the state visually drives this point home:

Figure 1: Agricultural areas in Arizona. Source: USGS, 2015.

Page |4

The Köppen-Geiger climate classification was originally designed in 1936 and is still
used as a helpful way to visualize different climate classes based on their seasonal
changes in temperature and precipitation (Beck et al., 2018)

Figure 2: Köppen climate map of Arizona. Data from Prism Climate Group, Oregon State
University, http://prism.oregonstate.edu; Outline map from US Census Bureau. Image used
under CCBY-SA 4.0.

Page |5

As the drastic shortage of water rightfully yields sensational headlines, worsening water
quality becomes an even greater concern. Issues of naturally high salinity combined
with desertification and pollution put a strain on the flexibility the agricultural community
has in dealing with water shortages (Bureau of Reclamation, 2006; Nabhan et al.,
2023). Increasing salinity in local fields and downstream on the Colorado River impacts
water quality and puts demands on more water to flush out fields and fulfill
commitments on water quotas to Mexico. This
situation highlights one of the unique
In a state with dwindling
challenges to Arizona: in a state with so
quantity, worsening quality
little water, the issues of quality and
and a non-stop influx of new
quantity become closely intertwined.
residents to feed and water,
Whether it be the standard practice of flooding
how can agriculture help
fields to flush out excess salinity accrued due
prevent and protect against
to agriculture, or the decreased quality water
the further fallowing of fields
that taxes the quantity of water useful for
and worsening of water
agriculture, the issue of salinity in Arizona is a
conditions?
quality problem that ends up negatively
impacting quantity as well.
While conventional runoff issues associated with agriculture, such as high levels of
nitrates and phosphorus, are less of an issue in Arizona compared to states with more
precipitation, protecting against these quality degradations is even more pressing in a
desert environment. To that end, the Arizona Department of Environmental Quality
(ADEQ) has been negligent in accurately assessing the extent to which Arizona faces
water contamination issues. According to a 2021 audit conducted by the state Auditor
General’s office:
The Department has not conducted key ambient groundwater monitoring
responsibilities since 2017, such as detecting the presence and evaluating the
effect of contaminants in groundwater. The Department has not conducted
required monitoring of agricultural pesticides in groundwater and surrounding soil
since 2013, as required by statute. Although it has established a goal to do so,
the Department has not reduced the total number of impaired surface waters in
the State that do not meet federal surface water quality standards to address
pollutants that affect the safe use of these waters and potentially negatively
impact the environment. (Perry, 2021, p. 4)
At a time of worsening drought, stringent surveillance of the limited state supply is
extremely important. This situation risks Arizona’s already limited quantity, which then
further strains the state’s quantity.

Page |6

So, what can be done? In a state with dwindling quantity, worsening quality and a nonstop influx of new residents to feed and water, how can agriculture help prevent and
protect against the further fallowing of fields and worsening of water conditions?
Voluntary water initiatives have strong precedent in other states as a useful tool to
forego legislative action. In this report, several different state water initiatives are
presented. While some plans, such as the Minnesota Agricultural Water Quality
Certification Program, operate in much wetter climates, many lessons for building a new
water program became apparent in the course of our research. A potential Arizona plan
must consider the stark difference in water quantity and water concerns of other states.
Yet despite the differences, many lessons can be learned from the plans implemented
in other states, namely improvements to soil health that impact both ends of the
quantity/quality spectrum.

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Research Methods
Water quality issues are complex, wide-ranging, and varied across the country. The
research team took a broad view in gathering information and best practices from the
field to understand various components, issues, and stakeholders in state water quality
programs and policy. We conducted an initial literature review to report on current
federal and state regulations that govern water quality to understand the broadest scope
of funding and regulation impacting state water quality programs. We also researched
water coalition building to understand how stakeholders come together and build
political will as a key component of policy change. Because the thrust of our project was
to make recommendations for Arizona, we needed to report on the intrinsic relationship
between water quality and water quantity issues in agriculture. Finally, market-based
approaches to water quality and water trading and economic incentives to pollution
mitigation in agriculture are part and parcel to burgeoning and existing water quality
initiatives. In addition, extensive research was conducted on Arizona’s current water
quality initiatives and funding sources, as well as review of other state water quality
programs.
The research team developed a list of questions (see Appendix 1) to guide the
discovery process via 60-minute interviews with water quality experts to gain an
overarching view of water quality plans in the United States and best practices for
implementation, with special attention toward application to the state of Arizona. Over
the course of several weeks, 41 interviews with a total of 44 individuals were conducted
with stakeholders across ten states, offering perspectives from water quality experts
and practitioners representing state agencies, academic researchers, nonprofits, and
farmers. The research team gathered qualitative data from these interviews, which were
recorded via Zoom software platform. Each question was coded with themes
determined through the literature review and through the interviews themselves. A list of
common themes found in the coding data, which were used to make recommendations
for Arizona:
• State or federal initiatives, incentives, funding sources
• E. coli, nutrient impairment, sediment, salinity, soil health
• Modeling, water testing/monitoring
• Surface water
• Local solutions, coalition building for political willpower, trust
• Program goals
• Quantity vs Quality, water conservation
• Communication/coordination, education/outreach

Page |8

•
•

Water quality technical recommendations, motivations for participation, voluntary,
policy recommendations for program building
Difficulty in measuring

This research project was granted exemption from the Institutional Review Board
(referenced at STUDY00016081) with support from Arizona State University’s IRB
office.

Page |9

Literature Review
This section provides a research-based overview of certain important aspects for water
programs. First, an overview of federal laws and regulations and Arizona water laws
and regulations is important to understand the legal framework around water and the
scope of potential state programs. Next, building a coalition or network to work together
around water issues is discussed, as this is necessary in successfully launching a new
program. Given the context of farming in Arizona, the relationship between water
quantity and quality is explored. And finally, when looking at non-regulatory initiatives, it
becomes important to understand incentives to participate in voluntary programs.
Therefore, an overview of market-based approaches and incentives for water quality
participation is reviewed.

US Agricultural Water Regulation: Federal vs. State
Responsibilities
When looking at state-level programs for water quality, it is first necessary to
understand the regulatory history and legal framework. Water quality is legislated at
both a national and state level, with significant interplay between jurisdictions. This
section will first give an overview of U.S. water regulation and current issues in federal
and state water quality laws. Then, it will look at stakeholders within water systems and
how coalitions are built between different stakeholders and government groups to
create water management systems.

A Brief History of Federal Water Policy
There is no comprehensive federal water management law in the United States. In their
chapter “Legal and Institutional Framework of Water Management” of the book A
Twenty-First Century U.S. Water Policy, Juliet Christian-Smith and Lucy Allen break
down the different legal frameworks and agencies involved in U.S. water policy law and
administration. They write that:
The United States continues to use a complex legal and administration
framework, based on a wide diversity of federal laws, regulations, and historical
court rulings, to distribute authority over water between federal, tribal, state, and
local governments. This framework has been built up over two centuries and is
based on the US Constitution, federal and state legislation, judicial decisions,
common law, and even international treaties. (Christian-Smith & Allen, 2012, p.
23)

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In addition to disperse authorities, federal funding for water is split across 30
agencies and programs. (Christian-Smith & Allen, 2012, p. 24)
Federal agencies involved in water management include the Environmental Protection
Agency (EPA), the Army Corps of Engineers, the Forest Service, the US Geological
Survey (USGS), the Department of Agriculture, and the National Oceanic and
Atmospheric Administration (NOAA). Each agency has a separate budget, some of
which must be reauthorized every budget cycle and are vulnerable to changes to
political priorities over time (Christian-Smith & Allen, 2012, p. 24).
The border between federal and state water authority on water is often difficult to
navigate.
The federal government has primacy in matters concerning navigation,
international treaty negotiations, federal water development projects, and water
uses associated with federal lands and other property, and it has a stake in the
national regulation of pollution and protection of natural resources (ChristianSmith & Allen, 2012, p. 37).
Any water not explicitly regulated by the federal government is left to state and local
lawmakers. And while the federal government may have the authority to act, it can be
politically curtailed through limiting funding or enforcement (Christian-Smith & Allen,
2012, p. 35). Therefore, some local waterways are only state regulated, and oftentimes
in Arizona there is a lack of regulation at the state level.

1972 Clean Water Act
The first of two main federal laws governing water quality is the 1972 Clean Water Act
(CWA). As explained in Copeland’s “Clean Water Act: A Summary,” this was a big
overhaul of the previous 1948 Federal Water Pollution Control Act and its subsequent
versions. The CWA seeks to address water pollution, particularly around wastewater
treatment and point-source pollution. With the 1987 amendment, the CWA looked to
address non-point source pollution as well. The Clean Water Act is overseen by the
EPA, but in partnership with state agencies. States can set their own Total Maximum
Daily Loads (TMDL) of pollutants and establish how those TMDL standards are met.
States have the right to permit water discharges and to address many concerns on a
local level.
Certain responsibilities can be assumed by qualified states, in lieu of EPA, and
this act, like other environmental laws, embodies a philosophy of federal-state
partnership in which the federal government sets the agenda and standards for
pollution abatement, while states carry out day-to-day activities of implementation
and enforcement (Copeland, 2010, p. 4).

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In certain cases, though, the EPA steps in and sets a TMDL level for the water body,
which the state must meet. Thus, the CWA created a federal-state partnership in
regulating clean surface water.

Waters of the United States
The CWA applies to all “navigable waters,” also referred to as Waters of the United
States (WOTUS). The Clean Water Act therefore applies to surface water, not
groundwater, but over time the exact definition of WOTUS has changed many times.
Prior to 2015, WOTUS included all interstate bodies of water, the oceans, and any
streams or wetlands that may feed into interstate bodies of water. Wetlands not tied into
interstate water were not included. In 2015, under the Obama administration, the
definition of WOTUS was clarified to include an expanded vision of wetlands and
headwaters. This was replaced under the Trump Administration in 2020 with a new
definition of WOTUS that did not include many wetlands and streams previously
covered, eliminating these waterways from EPA regulation. However, a 2021 ruling in
the US District Court for the State of Arizona voided the 2020 rule, and the WOTUS
definition reverted to the pre-2015 criteria (US EPA, 2018).
In the Science article “Deciphering Dueling Analyses of Clean Water Regulations,”
authors Boyle et al. contrast the way that WOTUS and the CWA was understood and
regulated in 2015 and 2017. Under the Trump Administration in 2017, the EPA
proposed a new rule and a new regulatory impact analysis (RIA) on the CWA that did
not include wetlands. The authors find that the 2017 RIA is inconsistent with empirical
evidence and past policy. They call for a more scientific and objective approach to
conducting RIAs. Furthermore, they stress the need for water regulation to have a
scientific basis, be clear, consistent, and easily understood so that regulations can be
adequately understood and enforced over time (Boyle et al., 2017, p. 49-50).

Safe Drinking Water Act
The second of the two main federal water quality legislations is the 1974 Safe Drinking
Water Act (SDWA). The SDWA established minimum standards to protect the quality of
public drinking water systems. Whereas the CWA did not apply to underground water,
the SDWA protected underground sources of drinking water from sources of pollution.
Amendments in 1996 required that the EPA set and enforce scientifically backed
standards for water quality and levels of pollutants. According to Michael Zarkin’s article
“Policy Learning Mechanisms and the Regulation of US Drinking Water,” the SDWA and
the regulation of US drinking water supplies is an example of a regulatory agency
becoming a learning organization. Over time the SDWA was legally amended in 1996

P a g e | 12

and changed many times throughout the nearly 50-year history to remain current with
changing scientific information. In effect, the EPA learned how to better protect drinking
water, and was able to change regulations and water quality standards over decades to
reflect that knowledge (Zarkin, 2016).

A Brief Note on Arizona’s Regulatory Framework
In Arizona, surface water law follows a pure prior appropriation approach. In Eastern
states’ riparian law, property owners are allowed to use water adjacent to their property,
if it doesn’t impede on other property owners’ downstream ability to use water. In
Arizona and certain other Western states, however, water is allocated based on the first
users to put surface water to a beneficial use, and these rights are not necessarily tied
to land ownership. When there is limited water to be allocated, the initial water users
have the right to the water before later users, hence the term “prior appropriation”
(Christian-Smith & Allen, 2012, p. 38). One limitation on prior appropriation is that:
Because not fully using a water right can be grounds for losing the right to the
unused portion, these rules encourage use at historic levels and, thus,
discourage water conservation. In addition, few states allow the transfer of
conserved water to other users or change of its use to other purposes, limiting
what can be done with the conserved water to avoid forfeiture and abandonment.
(Christian-Smith & Allen, 2012, p. 43)
Again, these surface water laws will vary by state and are not the same as groundwater
rights.

Water Coalition Building
Because U.S. water policies are administered across several agencies, it requires a
great deal of coordination and cooperation to administer water policies and programs.
Christian-Smith and Allen describe several non-profit organizations’ requests for more
specific and integrated national water policies. They
find that looking ahead, “Water policy will have to
Because U.S. water
adapt quickly to changing climatic conditions and do
policies are administered so in a coordinated fashion, reflecting the
across several agencies, hydrologic connectivity of our nation’s water
it requires a great deal of resources” (Christian-Smith & Allen, 2012, p. 25).
coordination and
According to Christian-Smith and Allen, while many
cooperation to
water issues can be solved at the state or local
administer water policies level, federal involvement and leadership is often
and programs.
needed when local issues intersect with federal
water jurisdictions.

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In the Science article “Collaborative environmental governance: Achieving collective
action in social-ecological systems,” author Orjan Bodin analyzes the ways in which
collaborative environmental governance can be successful in solving environmental
problems. According to Bodin, environmental governance relies on a collaborative
network of individual actors, which need to have a horizontal and vertical fit across
collaborators, to include multiple actors of interconnected ecological components, as
well as mediating actors, such as government administration. Central actors who are
well-placed within the network and also have strong leadership skills are key in creating
a productive social-ecological network and collaboration. To better understand complex
problems, these central actors should have experience in multiple communities (Bodin,
2017).
These central actor roles are often filled in by so-called boundary spanning
organizations or actors. Boundary spanners are members of multiple communities who
communicate across group boundaries. According to Petr Matous and Peng Wang’s
research with rural farmers, members of the community who take part in additional
training outside their community can then become boundary spanners. Boundary
spanners are then given prestige for their knowledge and can become opinion leaders.
Their conclusion shows that to effect change in a community, it is not necessary to
reach current opinion leaders because with additional information, new boundary
spanners can arise as opinion leaders in the network (Matous & Wang, 2019). However,
Delozier and Burbach’s study of integrated water resource management communities in
Nebraska put the focus back on individual boundary spanners. Their research found
that networks who ranked individual boundary spanners as high on trustworthiness and
authentic leadership were the most effective in communicating across communities.
(Delozier & Burbach, 2021). However, the role of a boundary spanner can be performed
by an agent or an organization.
Munoz-Erickson et. al (2010) investigate the role of collaboration in the Verde River
Basin Partnership (VRBP) in Arizona. The VRBP is a federally mandated program,
created to address concerns of water in the underground headwaters in the Verde River
Basin, upstream of the Prescott Valley. The partnership aimed to educate involved
actors to try to stem off conflict between the parties. The authors interviewed several
individuals involved in the partnership to see the role of the partnership in creating
bridges between diverse perspectives and stemming off conflict. They found that the
group’s inability to find common ground was in part related to actors differing viewpoints
on whether to accept the scientific consensus of scientific findings around water. They
found that experts were not necessarily able to provide assistance to actors who came
in already adverse to scientific analyses. They found that actors' deep-seated disregard

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towards science can prove a stumbling block towards collaboration for a watershed that
looks to be managed according to scientific principles (Munoz-Erickson et al., 2010).

Agricultural Water: Relationship of Quantity and Quality
Issues
In the United States, approximately 25 percent of cropland is irrigated, which is higher
than the global estimate of 18 percent of irrigated cropland. While only accounting for 18
percent of cropland, irrigated areas produce 40 percent of the world’s food (NASS 2018;
Scanlon et al., 2007). According to a 2017 U.S Geological Survey report, in the U.S.
crop irrigation accounts for 42 percent of freshwater withdrawals, and 62 percent of total
water use including withdrawals and reclaimed wastewater (Dieter et al., 2017). Henry
Bouwer outlines that a growing population requires more irrigation water to ensure that
increasing demands for food are met. Bouwer also notes that further water protection
will be needed to address issues of aquatic life, wildlife habitat, recreation, scenic
values, and riparian habitats, and that increased competition for scarce water resources
should be expected. Bouwer writes,
This will require intensive management and international cooperation. Since
almost all liquid fresh water on the planet occurs underground, groundwater will
be used increasingly and, hence, must be protected against depletion and
contamination, especially from non-point sources like intensive agriculture
(Bouwer, 2000, p. 218).
As a major user of water, agriculture is under threat as water shortages intensify in arid
regions of the country and precipitation patterns become less predictable with a
changing climate. Dennis Wichelns and J.D. Oster explore the viability of irrigated
agriculture in their article “Sustainable irrigation is necessary and achievable, but direct
costs and environmental impacts can be substantial.” They write:
In some areas, the private and social costs of sustaining irrigation will exceed the
benefits and irrigation will cease. Such areas will include regions in which
persistent groundwater overdraft leads to unaffordable pumping costs or
depletion of fossil groundwater supplies (Wichelns & Oster, 2006, p. 125).
At the same time, more frequent intense storms in humid regions are leading to
challenges with increased flooding and erosion, both of which negatively impact
agricultural productivity and water quality. Again, Wichelns and Oster write, “Irrigation
might also be discontinued in regions where society chooses not to accept the off-farm
impacts of agriculture, or the environmental harm caused by discharging drainage water
into rivers and other waterbodies” (2006, p. 125). Both water scarcity and abundance
play a role in agriculture’s impacts on water quality and shortages.

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Types of impairment
The environmental costs of agricultural water use and management show up to varying
degrees depending on a region’s climate, soil type, land use, agricultural practices, and
implementation of best management practices. Throughout the country, agriculture is a
leading source of nonpoint source pollution, in which fertilizers, pesticides, manure, salt,
and soil sediment enter both surface waters and groundwater from dispersed sources
such as farms, roads, parking lots, and lawns. In contrast to point source pollution, such
as discharge from a factory or power plant, nonpoint source pollution is significantly
harder to identify, measure, and regulate (EPA, 2017). The primary ways that
agriculture contributes to impaired water quality are outlined below.
Nutrient impairment in waters
Agriculture of many scales and types introduces nutrients that make their way into water
sources. In the Upper Midwest and humid regions, conventional crop management of
corn and soybeans leave soil exposed through the winter. Wind and water cause
significant erosion of the exposed soil, which carries phosphorus and nitrogen with it
into waterways. In turn, the depleted soils require more fertilizer use in the spring for
productive yields, which further exacerbates nutrient impairment in water (Weyers et al.
2021). Carpenter et al. estimate that nonpoint source impairments of Nitrogen and
Phosphorus, primarily from agricultural operations, account for 82-84% of all discharge
into water bodies (Carpenter et al., 1998). In the arid region of the Western states, the
risk of nutrient impairments in watersheds is
Naturally occurring salts in
lower than in the Midwest and Eastern states,
the irrigation water, both
due to less cropland and minimal
groundwater and surface
precipitation to carry the nutrients away. In
water, paired with a lack of
particular, watersheds in and around Arizona
effective drainage systems,
typically are home to more rangeland and
leads to increasing levels of
federal lands. Brown and Froemke note that
salt in the soil, which
these land uses have a lower risk of nutrient
diminishes agricultural
impairment because they limit development
productivity.
and animal feeding operations (Brown &
Froemke, 2012).
Salinization of soil and water
Both groundwater and surface water can be salinized through irrigated agricultural
practices. Scanlon et al. explain the conversion of natural ecosystems to agricultural
production as the mobilization of natural salts that have accumulated in the subsurface
in many semiarid and arid regions (Scanlon et al., 2007). Naturally occurring salts in the

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irrigation water, both groundwater and surface water, paired with a lack of effective
drainage systems, leads to increasing levels of salt in the soil, which diminishes
agricultural productivity. In 2011, Jeffrey Homburg and Jonathan Sandor published
research on human impacts on soil quality of the American Southwest, noting, “Cases
of detrimental levels of salt and sodium accumulation caused by irrigation are wellknown in modern agriculture, though scientific documentation is surprisingly rare”
(Homburg & Sandor, 2011, p.152) Their analysis of soil throughout the Southwest
indicates that now uncultivated landscapes were once ancient agricultural fields, and
the differences between soils that were irrigated or dryland in ancient agricultural
systems persist today. It is likely that excessive salt and sodium accumulation in
irrigated landscapes led to abandonment of those fields by pre-Hispanic cultures, or at
least severe limitations on use and choice of crops (Homburg & Sandor, 2011). Scanlon
et al. estimate that globally, loss of irrigated farmland due to salinization is 1.5 Mega
hectares/year (Mha/yr), totaling 45 Mha across the globe. This estimate represents 16%
of total irrigated agricultural land, which is especially significant considering that irrigated
land is the most productive agricultural land (Scanlon et al., 2006).
Excessive naturally occurring micronutrients
Another impact agricultural production has on water quality is dissolving and mobilizing
naturally occurring trace elements and micronutrients. In many cases, elements such as
selenium, gypsum, arsenic, and boron are beneficial to plant health in very small
amounts but can become harmful or toxic in high concentrations. Dennis Lemly
discusses the impact of excessive selenium in surface waters as highly toxic to fish and
wildlife, disruptive to life cycles of aquatic life, and harmful to human health if seleniumcontaminated fish are consumed (Lemly, 1996). Similarly, boron is necessary for
healthy plant growth and development in small amounts, but if slightly more
concentrated than required, boron becomes toxic and damaging to both plants and
humans. There is no simple process to remove boron from water (Hilal et al., 2011). As
water quantity diminishes, the concentration of some naturally occurring elements may
increase to unsafe levels and become a water quality concern.
Raising water tables or waterlogging
Waterlogging occurs when the soil is saturated with water so there is insufficient oxygen
for plant roots. Irrigated cropland contributes to waterlogged areas, by raising the level
of water tables over time. In addition to inhibiting plant growth, waterlogging contributes
to the degradation of water quality by enabling fertilizer leaching and salt mobilization
(Scanlon et al., 2006).

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Livestock waste management
Modern agricultural practices have moved livestock management off pastureland and
into Concentrated Animal Feeding Operations (CAFOs). The intensification of livestock
production impacts water quality in a number of ways, from manure management to
increased demand for fodder that relies on chemical fertilizers. In “A review of water
quality concerns in livestock farming,” P.S. Hooda et al. write that manure produced in
concentrated livestock farms is often applied to cropland as fertilizer in excess of
agronomic requirements and application is not timed for maximum benefit to soil and
crop health. Imprecise field application, as well as poor management of waste slurry,
leads to leaching of nitrogen, phosphorus, organic wastes, and bacterial pathogens
such as E. coli into surface and groundwater sources (Hooda et al., 2000). In addition to
intensive livestock operations, ranching on public lands in the Western U.S. has created
water quality issues such as bacterial pathogens and degradation of streambanks
(Kauffman et al., 2022).

Impact on different water sources
The agricultural impairments to water quality outlined above cause different impacts on
each type of water source with regards to water quality and water quantity. Additionally,
impairments to each water source have different impacts on agriculture and the
environment, detailed below.
Surface waters
Surface waters are primarily impaired by nitrates and phosphates which runoff from
cropland and concentrated livestock operations. The humid region of the Midwest and
Eastern U.S. are at greatest risk for water quality impairments from agricultural runoff.
Arid regions also suffer water quality impairment from salinization, minerals, and
bacterial pathogens. Impairments to surface waters lead to hypoxia, loss of habitat, and
public health risks.
Surface water is also at risk of overuse for agricultural irrigation, particularly in arid
states. According to the Arizona Department of Water Resources, 54% of water comes
from the Colorado River or in-state rivers (ADWR, n.d.b). The Colorado River is
governed by several sets of laws and regulations, known collectively as the Law of the
River, which instead of restricting water use has actually overallocated the river’s water.
Agricultural irrigation accounts for 72% of water use by sector in Arizona, so it is an
obvious target for reducing water use.

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In one example of the relationship between water quality and quantity, Jan van
Schilfgaard points out that until the early 70s, all of the work and controversy along the
Colorado River focused exclusively on allocations of water quantity and ignored its
quality. She notes that the Colorado River Basin Salinity Control Act of 1974 shifted the
conversation to addressing issues with salinity as the impacts of irrigation flowed
downstream and municipal users suffered the consequences. Van Schilfgaard writes,
“Water quality and water quantity, it turns out, are intricately linked. As the pressure for
water quantity grows, the concern with water quality increases” (1993, p. 214).
Impaired surface waters are a threat to public health by way of contaminated drinking
water, bacterial outbreaks on vegetable crops, and contamination in fish and seafood.
Additionally, impaired surface waters are not accessible for recreational and tourism
purposes which can negatively impact the economy of a state and diminish habitats for
wildlife.
Groundwater
Agricultural use of groundwater is the primary cause of rapidly depleting aquifers at a
greater rate than they can recharge. As the water table lowers, shallow wells are drying
up, leaving those who have historically had access to groundwater without water. In
some parts of Arizona, groundwater withdrawal is not regulated, which is where
agricultural operations with greater resources are able to drill deeper wells and extract
groundwater without constraints (ADWR, n.d.b).
Similar to surface water, groundwater becomes impaired by agricultural uses which
leach salt, nitrates, phosphates, and minerals into aquifers. According to Stephen
Foster et al.:
In recent years water security concerns have centered on groundwater depletion
by withdrawals for irrigated agriculture, and only limited attention has been paid
to the more insidious (and more chronic) problem of progressive aquifer
salinization of groundwater recharge by irrigation return-flows, which is occurring
in many semi-arid regions (2018, p. 2781).
Groundwater accounts for 41% of water use in Arizona. When water extraction is
greater than recharge, groundwater is not a renewable resource. Any impairment to
groundwater quality further limits the safe use of the scarce and valuable resource.
Every effort should be made to protect both the quantity and quality of groundwater in
arid regions.

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Recycled water

Recycled water

At this time, recycled water accounts for 5% of Arizona’s
accounts for 5% of
water resources, so it is a minor source of water in the
Arizona’s water
state (ADWR, 2020). However, as groundwater and
resources, so it is a
surface water become increasingly scarce in arid regions,
minor source of
recycled water could become increasingly important for
water in the state.
agriculture in the West. In 2018, Dery et al. published
research on growers’ perceptions and attitudes regarding nontraditional water sources
such as recycled water. The survey found that, despite evidence of safety, growers
continue to have reservations about using recycled water. The survey notes the top
concerns are food safety, cost of infrastructure, consistency, availability, chemical
contamination, public perception, and water rights. The research team hopes their work
will help, “aid decision makers in understanding the perceived risks, willingness to use,
drivers and constraints to grower adoption, and preferred methods of education
regarding water reuse in agriculture” (Dery et al., 2018 p. 508). As water continues to
become increasingly scarce with the changing climate, recycled water has the potential
to secure agricultural production in arid and semi-arid regions for the foreseeable
future.
While water quantity shortage is the primary issue in Arizona, it is important to consider
water quality impacts as well - both how agriculture impacts water quality and how
impaired waters can impact agriculture. Carpenter writes, “Water shortage and poor
water quality are linked, because contamination reduces the supply of water and
increases the costs of treating water for use. Preventing pollution is among the most
cost-effective means of increasing water supplies” (Carpenter et al., 1998, p. 560).

Conclusion
This quote by Dennis Wichelns and J.D. Oster summarizes the heart of this issue:
Farmers and public officials must determine acceptable levels of the direct and
indirect costs involved in sustaining irrigated agriculture. Farm-level and policy
decisions will vary among regions with differences in economic development,
resource endowments, and public preferences regarding the inevitable impacts
of irrigation on the environment. Hence, the notion of irrigation sustainability will
vary among regions and over time with differences in public preferences.
(Wichelns & Oster, 2006, p. 114)
In a place like Arizona, where concerns over scarcity of water quantity dramatically
outweigh concerns over water quality, how do policy makers and state agencies build
the political will to address agricultural water management to improve water quality? Are

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the environmental costs of agriculture too high, especially in the face of climate change?
As this research explores these questions, it is important to keep in mind that while they
are certainly separate issues, water quality and quantity are deeply intertwined and that
agricultural practices that address water conservation, likely protect water quality as
well, and vice versa.

Economics and Environmental Markets: Lessons from WaterQuality Trading
Environmental markets are a major conceptual innovation for environmental policy that
came from research in environmental economics. As the concept moves from pages of
books and journals to instruments available to policymakers, outcomes will depend on
how the market programs are designed and implemented and the contexts in which
they occur. (Shortle, 2013). This section will give an overview of U.S. Water Quality
Trading (WQT) programs and then, it will look at how coalitions are built and some
examples of successful WQT programs.

Background
Market mechanisms have gained much interest and increasing acceptance in
environmental circles. Indeed, the case for markets seems to be made at least as much
from advocates outside of the discipline as from within. Advocates include consulting
firms involved in varying aspects of the environmental trading business, associations
representing such businesses, environmental think tanks, legislators, and government
agencies (Rock, 2019)
The benefits of markets include potential efficiency gains and innovation incentives.
Markets, it seems, can better and more quickly deliver environmental improvements that
cost less than other policy instruments.
To date, markets for environmental quality have figured most prominently in fisheries
management and air pollution control, and successes in those areas have influenced
expectations of what markets can accomplish for other resources. In recent years,
attention has turned to markets for water. John Dales (1968) first proposed using
markets to protect water quality in 1968, and experimental and demonstration waterquality-trading (WQT) mechanisms were established in the United States in the 1980s.
Interest in the United States increased in the mid-1990s as state water-quality
authorities explored new mechanisms by which to achieve TMDL levels for pollutants

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established by EPA. In 2003, EPA announced policies intended to facilitate trading and
began providing financial support and technical assistance for WQT.

Mechanism
In water quality trading (WQT), a buyer purchases credits to comply with their waterquality-based permit limits. Credits represent a quantified, verified reduction in pollutant
load. Credits might be generated at other permitted facilities or by reducing nonpoint
pollutant loading, such as through installation of conservation best management
practices (BMPs) on upstream agricultural land (US EPA, 2022). Trades used to meet
the limits within a National Pollutant Discharge Elimination System (NPDES) permit are
subject to the U.S. EPA trading policy (Willamette Partnership, Forest Trends, & the
National Network on Water Quality Trading, 2018).
Credits may also be purchased by non-governmental organizations (NGO) or through
corporate social responsibility programs. There are three possible market-based
strategies for water quality improvement:
• Nutrient reduction exchange
• Wetland mitigation banking
• Environmental impact bonds
Comparable to a cap and trade program, the nutrient reduction exchange ties
downstream municipalities to upstream partners through voluntary efforts. This
approach focuses on reducing nitrogen and phosphorus by leveraging cost-effective
projects that would be more affordable than removing nutrients at a water treatment
plant.
With wetland mitigation banking, flood risks can be minimized by holding and slowing
the flow of water—also allowing nutrients and sediment to filter out. In addition,
wetlands can provide a natural habitat for birds and waterfowl. The idea behind this
approach is to encourage new investments in water quality and flood mitigation by
restoring wetlands (Rock, 2019).
Environmental impact bonds have been used recently by major cities to finance
infrastructure projects to improve water quality, particularly from stormwater runoff.
Washington, D.C. first used this tool in 2016, followed by Baltimore and Atlanta. What
makes environmental impact bonds different from other green bonds is that they use a
“pay for success” model focused on achieving environmental outcomes, which requires
them to have a measuring and monitoring component for investors (Rock, 2019).

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Any of these three market-based strategies could play a key role in building a cleaner,
healthier, and more productive future.

Figure 3: Water Quality Trading in practice. Source: Willamette Partnership, Forest Trends, &
the National Network on Water Quality Trading, 2018.

Sample Water Quality Trading Programs
Hunter River Salinity Trading Scheme, Australia
The Hunter River Salinity Trading Scheme in New South Wales, Australia, is an
important example of successful methods and of the merits of WQT between point
sources and is considered the most successful WQT program in the world. This pointpoint salinity trading program applies to coal mines and power plants. It was initiated as
a pilot in 1995 and was made fully operational in 2002. The New South Wales Office of
Environment and Heritage (formerly the Department of Environment, Climate Change,
and Water) administers the program under the guidance of an operations committee
that includes representatives from the state government, industry, and the community.
Monitoring points along the river measure whether the amount of water is low flow, high
flow, or flood flow. When the river is in low flow, no discharges are allowed. During high

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flow, limited discharges are allowed, and they are subject to restrictions based on a
licensee's supply of tradable salt credits. An online trading platform was developed for
exchanging credits with prices and credit transactions negotiated by buyers and sellers.
Assessments indicate that the program has achieved established targets for water
quality at a lower cost than the prior regulatory scheme would have and allowed
expansion of economic activity that otherwise might not have occurred (Shortle, 2013).
Connecticut Nitrogen Credit Exchange Program, United States
The Connecticut Nitrogen Credit Exchange Program (CNCEP) was established in 2002
to allocate reduced nitrogen loads among 79 wastewater treatment plants that
discharged into the Connecticut River. The reductions were required by a TMDL limit
that was designed to protect Long Island Sound with the limit to be achieved in 2014.
Wastewater plants are annually assigned individual discharge limits to achieve the
increasingly stringent cap on nitrogen loads to the sound. Facilities generate credits
when they reduce nitrogen discharges below an assigned limit. If a plant fails to meet its
limit, it must acquire credits to cover the shortfall. The credit price is set by the Nutrient
Credit Advisory Board (NCAB), a body appointed by the state legislature. Buyers and
sellers do not interact in the market. At the close of each year, the state environmental
agency determines each plant's actual discharges and credits earned or required to be
in compliance. The agency also purchases more credits than are needed to achieve the
aggregate emission cap. Economic
Water quality trading can provide
incentives are clearly present in the
greater flexibility on the timing and
CNCEP, but the exchange is not truly a
level of technology a facility might
marketplace in which buyers and
install, reduce overall compliance
sellers compete. Instead, the exchange
costs, and encourage voluntary
essentially involves fixed administrative
participation of nonpoint sources
penalties for undercompliance and
within the watershed.
payments for overcompliance with
effluent standards (Shortle, 2013).
Key issues in Water Quality Trading
How do permittees identify projects that they can implement and claim credits to trade?
This is a limitation due to identifying problem locations in land, and concern about taking
land out of agriculture production for trading. Projects need to make sure they don’t take
land out of agriculture production to help with stabilization (National Resource
Conservation Service, 2011).

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Another challenge is with matchmaking and how to get the buyers and sellers to trade
effectively. Permits will have demand for reductions in very specific locations. If you
have a practice that is closer to the water body that needs protection, it will yield many
more credits than a practice at a remote location.
Water quality trading can provide greater flexibility on the timing and level of technology
a facility might install, reduce overall compliance costs, and encourage voluntary
participation of nonpoint sources within the watershed. Nonpoint source projects (e.g.,
streamside buffers, conservation tillage) installed as part of a water quality trade can
provide other environmental benefits, such as reducing carbon emissions, reducing
flood potential, stabilizing streambanks and providing wildlife habitat. (National
Resource Conservation Service, 2011)
Policy Excerpt 1: Challenges to WQT Programs. Source: Willamette Partnership,
World Resources Institute, and the National Network on Water Quality Trading, 2015.
However, moving a WQT program forward can be challenging for several reasons
The Clean Water Act does not apply evenly to all sources of pollution within a
watershed, generating debate about who is responsible for reducing what
pollution
Where watershed science is incomplete, it can be difficult to build an effective,
efficient WQT program. It can be more challenging to set clear water quality
goals and determine the contribution of individual projects toward those goals
A successful trading program involves multiple stakeholders who bring
different perspectives and vocabularies. The lack of a common vocabulary
can hinder communication and development of shared understanding
Different stakeholders have different tolerances for risk and uncertainty. There
needs to be a holistic look at risk management in WQT. If every program
design decision is the lowest risk option from an ecological perspective, WQT
may not be cost effective. Conversely, if every decision entails ecological risk,
WQT may not achieve water quality objectives
It can be easy to lose sight of the bigger water quality vision when talking
about the details of a WQT program, but talking about WQT at a high level
without going into detail may limit confidence in a program’s ability to succeed;
and
There are no easy ways to share the lessons learned from two decades of
experience with new trading programs, so opportunities for reducing start-up
costs and effort may be lost.

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These challenges can lead to long discussions or disputes around:
The pollution reductions expected from market participants prior to buying and
selling credits (i.e., baseline requirements)
How to manage uncertain science or other risks (e.g., selecting credit
quantification methods or setting the right trading ratio)
How to engage the public to provide comments and shape how trades will work
Lack of numeric discharge limits
High transaction costs
Regulatory environment with significant costs for noncompliance, which has led
permittees to implement risk-averse compliance strategies
Lack of empirical analysis of existing programs

Incentives for Water Quality in Agriculture
Introduction
This section seeks to outline research and theory behind economic incentives in
agricultural water policies, as well as challenges and potential opportunities for future
policy implementation. It will provide background in the types of incentives, or economic
instruments, and three alternative models by environmental economists including: a tax
(subsidy) to penalize (reward) based upon measurements of ambient pollution, a
proposed transition from “Pay the Polluter” to “Polluter Pay Principle” (Shortle et al.,
2012) and a point-based “Abatement Action Permit System” (Kling, 2011). In addition,
we will explore farmer motivations and risk assessments to participation in voluntary
programs to promote environmental quality.

Background
Environmental economists have made the case for incentives since the 1960s, but their
usage remains mostly theoretical due to policy design flaws and a lack of uptake in the
schemes for water quality pollution (Shortle et al., 2012). Shortle et al. claims that these
“highly inefficient” policies are responsible for an increasingly lower return on investment
of federal funding toward water quality schemes over time. While the CWA regulates
point source pollution attributable to wastewater plants and CAFOs at great cost,
nonpoint source pollution (NPS)—largely attributed to agricultural nutrient runoff into
rivers, wetlands, and other bodies of water—remains largely unregulated and “NPS
pollution is by far the greater form of agriculture's water quality impacts” (Shortle et al.,

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2012). Instead, nonpoint source pollution is governed by state-led voluntary initiatives
and federally funded conservation programs that are adjacent or complementary to
other conservation initiatives rather than actively achieving targeted goals specific to
improving water quality (Shortle et al., 2012).
The USDA has supported soil conservation since the inception of the Natural Resource
Conservation Service during the Dust Bowl. But over time, with increasing pressure of
climate change and drought conditions creating challenges for farmers, water quality
and water conservation issues have taken up a larger share of the federal funds through
these programs (Shortle et al., 2012). The USDA programs that financially support best
management practices (BMPs) toward conservation initiatives inclusive of water quality
include the Environmental Quality Improvement Program (EQIP), the Conservation
Reserve Program (CRP), and the Conservation Security Program (CSP). Each of these
programs provides a combination of financial and technical assistance for land
management but Shortle et al. describes several drawbacks: (1) the programs have
multiple goals, so the funding itself is not targeted to water quality; (2) funding for
technical assistance has lagged behind financial support; (3) farmer self-interest (e.g.
production income) can be at odds with water quality goals associated with the public
good (Shortle et al., 2012).
In addition, NPS pollution is notoriously difficult to measure, track, and identify the
source due to the physical nature of how nutrients are transported via land and
waterways, individual farm and watershed topography, the movement of surface water,
and weather patterns - all of this makes policies based on a given farm’s water pollution
emissions “difficult or impossible to implement” (Kling, 2011). Shortle notes that
contributions from individual farms are subject to a large amount of uncertainty,
therefore “regulatory cost-savings and overall efficiency will come from targeting
subsets of the population of potential polluters that are higher probability sources”
(Shortle, 2017).

Uncertainty and Incentives
In 1988, Kathleen Segerson proposed a regulatory scheme that would dictate
punishment (tax) or reward (subsidy) based on what was measurable within nonpoint
pollution: what she refers to as ambient pollutant level, which is a direct measure of
environmental quality. The advantage of this method is it does not require costly
individual monitoring of farm emissions or on farm BMPs. Instead, it groups assumed
polluters within a given watershed or region, holding them accountable (or rewarding
them) together. Her economic incentive scheme is as follows: a regulatory agency sets
the water quality standard to be measured against for a given body of water, much like

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with the current regime of TMDLs. They determine the variable rate of a tax and subsidy
level to either a penalty or reward to each farm. The tax or subsidy correlates to the
pollutant level detected in the watershed level measurement (Segerson, 1988).
Therefore, the higher the level of pollutants detected when measured against the goal,
the higher the tax payment. The lower the pollutant level below the standard, the more
the reward. This mechanism directly connects collective producer actions to the
measured environmental impacts on the watershed, either punishing or rewarding a
group of farmers as a whole.
An advantage of this tactic is it allows the farm to determine the most appropriate
mitigation strategies for their operation at lowest possible cost, enabling them to
maintain a sense of ownership over their land management practices while still being
held accountable to the environmental outcomes (Segerson, 1988). The costly process
of monitoring individual farm emissions and practices can be avoided, and more focus
paid to watershed “hot spots” where pollution levels can be measured at critical times,
such as after a large rainfall. Segerson (1988) also proposes a short-term cost-share
program so that there is no unreasonable financial burden on the sector to comply, as
long as it does not operate counter to the financial incentives structure itself.
As with other regulatory devices that must balance individual and public benefits and
costs, a challenge to this incentive scheme is how to determine appropriate parameters
for the tax (subsidy) level that takes into account the damages incurred by pollution and
the cost of abatement strategies that will be deployed by farms (Segerson, 1988). In
addition, it does not reward individual farmers who have historically used conservation
practices, thus disincentivizing “good” actors in the system and it does not take into
account the variability of the farm, for example in proximity to the watershed. With any
incentive scheme, farmer buy-in would need to be explored to determine feasibility.

Polluter Pays Principle vs. Pay the Polluter
Like Segerson, Shortle et al. believe there is more success to be had with incentive
schemes when monitored at the watershed level, rather than the individual farm level.
They contest that paying the polluter “can only attain water quality goals if governments
are willing and able to tax citizens or reallocate public funds to purchase sufficient water
quality improvements,” criticizing the decades-long track record that has not resulted in
desirable environmental outcomes (Shortle et al, 2012, p. 1319). Meanwhile, asking the
polluter to pay within the paradigm of nonpoint source pollution removes the public’s
liability from the equation.

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They propose an incentive scheme that follows two main criteria: (1) economic
incentives that “produce the desired water quality impacts” and (2) promote costeffectiveness - both for the individual farm and at the watershed level, what he calls
“allocative efficiency” - encompassing the practices of multiple farms within a given
region, which mimics the regional distribution of polluter accountability (Shortle et al.,
2012, p. 1319). Shortle et al. goes on to explain that successful policies are
performance-based, meaning they are tied not only to on-farm abatement practices
being deployed, but to measurements of environmental stress, what Segerson referred
to as ambient pollutant level. Shortle et al. and Segerson are also in agreement about a
policy mechanism that allows for flexibility and farmer choice in how to address their
emissions based on the individual characteristics, management practices, and
topography of their farm. Producers should be targeted individually based on “their
ability to address environmental problems” which will promote cost effectiveness at the
watershed level, since what is cost-effective at abatement on one farm will not be the
same for the farm next door (Shortle et al., 2012, p. 1319).
Acknowledging that the Polluter Pays Principle is a difficult sell in the short term, Shortle
et al. proposes some transition schemes that governments can deploy, which include
(1) the aforementioned rewarding performance-based payments instead of practicebased payments, (2) more targeted payment mechanisms, and (3) integrating
conservation payments with pre-existing commodity program compliance measures. We
will examine each one in turn.
A recurring criticism of existing nonpoint source pollution incentive schemes is the
reward of best management practices (BMPs), as seen in USDA programs named
above that are performance-related, rather than tying incentives to explicit, measurable
goals that are performance-based (Shortle et al., 2012). Taken at face value, it seems
obvious that in order to achieve any goal, one needs to identify a goal and metrics, then
take steps toward achieving it. But in policy where the public good is sometimes at odds
with individual choice, things get more complicated. Shortle et al. explains that states
already have TMDL plans, which effectively operate as government-set goals for
emission reductions, and account for pollution from both point and nonpoint sources
(Shortle et al., 2012). Perhaps this notion can be extended to incorporate current
(mostly voluntary) non-point source emissions explicitly?
To more effectively target payments, Shortle et al. describes the advantages of
performance subsidies and performance contracts. He defines a performance subsidy
as “a payment per unit of improved performance” that is set by the implementing
agency, which sets a subsidy rate that farmers can apply for and implement. This again
allows for flexibility and individual choice for each farm, and incentivizes greater rewards

P a g e | 29

for practices that provide greater returns on environmental impact with differentiation of
each farm’s baseline. On the other hand, performance contracts allow farmers to set a
price and bid to provide environmental improvements to a watershed on their own
terms, while allowing the government to choose a suite of awards within their given
budget. Shortle et al. points out that several USDA conservation programs already
operate this way, and it avoids the complexity of government-established differential
subsidy levels and enables farmers who provide more environmental benefits to receive
higher payments (Shortle, et al., 2012).
Another incentive scheme Shortle et al. proposes aims to eliminate perverse incentives
by integrating multiple farm programs. They explain “commodity programs [are
responsible for] increasing the cost and reducing the effectiveness of conservation and
water quality protection programs” (Shortle et al., 2012, p. 1322). They propose that
compliance provisions in existing programs, such as production flexibility contracts,
disaster assistance, and other USDA conservation programs could be expanded to
encompass nutrient runoff and leaching, which would incentivize farmers to adjust their
practices accordingly (Claassen et al., 2000). Another idea is to offer “Green Payments”
instead of commodity payments, which would provide direct farm income for
environmental services that farmers provide and eliminate the conflict between
production and watershed protection.

Point-based Abatement Action Permit System
Catherine L. Kling provides yet another model for reducing nonpoint emissions, by
identifying proxies for the farm’s emissions and creating incentives based upon them.
She describes:
One way these requirements could be operationalized is via a point-based
system where conservation practices are assigned a point value based on their
effectiveness at reducing emissions from a field. The points associated with each
practice could vary by characteristics of the field, location in the watershed, or
other variable. Each producer would be required to have an average number of
points per acre to satisfy their requirement. (Kling, 2011, p. 301)
Similar to Shortle and Segerson, this model allows for the producer to choose which
fields, which conservation practices, and to what extent they will be deployed. This level
of flexibility enhances the overall effectiveness of the program by additionally allowing
farmers to trade points earned, thus maximizing the lowest cost, most effective
abatement actions (Kling, 2011).
She describes how it would work in her 2011 paper Economic Incentives to Improve
Water Quality in Agricultural Landscapes: Some New Variations on Old Ideas. First, an

P a g e | 30

implementing agency determines how many points are awarded per observable
conservation or land use practice, with allowed variability depending on certain
characteristics such as slope or soil type. The agency determines the total points per
watershed, with the option to assign fewer points to actors with a history of conservation
practices, thereby rewarding farmers with historical abatement activities. The
enforcement mechanism could be tied to compliance via farm commodity payment
programs, as suggested by Shortle and others. Lastly, it will be important for the
implementing agency to enable room for flexibility and to reward on-farm innovation as
well as continually adaptive measures (Kling, 2011).
So, what about measurement in this model? How can one tell if there is nutrient
reduction? For this, Kling describes the use of a new technology called evolutionary
algorithms, which can provide an adaptive model that determines the lowest cost
intervention for achieving the most reductions (Kling, 2011). And counter to prior
authors who focus on measuring change in environmental quality, she posits that
continually improved on farm technology, such as remote sensing, will support the
ability of farmers to calculate their field emissions and their proxies moving forward
(Kling, 2011). Likewise, Shortle describes the option of measuring “performance
indicators that are constructed from farm- or field-specific data” that then allow for
trading of nutrient credits, which we discuss elsewhere in this report (Shortle et al.,
2012).

Farmer Motivation and Barriers to Participation
Above and beyond the structure of incentive schemes themselves, what are the factors
that drive farmer participation knowing that their buy-in is fundamental to achieving the
policy outcomes? A paper from Beedell and Rehman (2000) out of the United Kingdom
suggests that future research needs to involve more than just BMPs or change in
environmental quality, expanding to include the role of farmer attitudes and motivational
behaviors.
Another U.K. paper from Morris and Potter argues that high enrollment in an
environmental program is also not enough, and that
What are the factors
“one of the most important, if least tangible,
that drive farmer
objectives of AEP [agri-environmental programs]
participation knowing
schemes should be to bring about a shift in the
that their buy-in is
attitudes of farmers towards countryside
fundamental to
management which will outlast the schemes
achieving the policy
themselves” (1995, p. 61). They suggest that
outcomes?
farmers who are more “passively enrolled” in

P a g e | 31

programs - those who participate with the least amount of effort to garner the most
economic benefit - can be “encouraged through a more imaginative use of advice and
training and by learning from those actively engaged to move farmers along the
spectrum of engagement” (1995, p. 62). Yet another paper from Ruto and Garrod
agreed that there were a large number of farmers who are “low-resistance adopters”
who tended to be younger, have more education, more positive attitudes toward the
environment when compared to “high resistance adopters” who tended to rely on the
farm revenue for more of their household income, and less likely to be landowners
(2009, p. 645). Although there are still significant research gaps to determine farmer
choice to enroll in incentive schemes, Ruto and Garrod concluded, perhaps intuitively,
that “farmers require greater financial incentives to join schemes with longer contract
lengths, or that offer less flexibility or higher levels of paperwork” (2009, p. 645).
Another barrier to entry can occur when the landowner is not the one farming the land.
“Land tenure systems influence management practices. Farmers without secure land
tenure lack incentive to manage soil fertility and salinity with the same care that a longterm landowner would provide” (Wichelns & Oster, 2006, p. 117). The farmer without
ownership or long-term interest in the property is less likely to participate in programs
that take several years to realize gains. And an owner who does not manage the land
themselves may lack the ability or incentive to implement such measures. Programs
must decide whether to engage the landowner, property manager, or both, and how to
structure a program to best include a range of land tenure arrangements.

Conclusion
In this section we have explored the current challenges of designing policy solutions
that effectively mitigate nonpoint source pollution, where collective emissions are not
traceable to each source and where public good is potentially at odds with the private
welfare of individual farm emitters. Given the incentive schemes described above, an
effective economic instrument should:
• Target environmental “hot spots,” as determined by stakeholders of the local
watershed, for example where emissions are particularly high or an area is
environmentally sensitive.
• Allow sufficient flexibility to equitably reward producers who have historically
deployed conservation practices (and not disincentivize “good actors”) and to
provide greater ability to fully leverage each farmer’s individual capacity to
contribute to water quality improvements in the most cost-effective manner.
• Incentivize toward specific, measurable goals that quantify the environmental
impacts at the watershed level, monitoring change and holding collective emitters
accountable to reach a given standard reduction.

P a g e | 32

•

There is consensus that measuring progress against BMPs (practice-based) is
insufficient to reach water quality goals, however there is potential opportunity to
monitor farm-level emissions data as technology improves, and to allow for farms
to trade “nutrient credits.”

Shortle concludes that “economic incentives for pollution control are not inherently
beneficial - design matters crucially to effectiveness and efficiency” (2017). In some
cases, mandates are the most cost-effective strategy, especially for environmentally
sensitive locations with significant water quality issues, therefore a mix of incentives and
regulatory schemes will be necessary (Shortle, 2017).

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Results – State Plan Case Studies
This research focuses on the state of Minnesota, particularly the Minnesota Agriculture
Water Quality Certification Program, but also looks at state level policies and programs
from around the country that address agricultural water quality. Table 1 below
summarizes key findings from research and interviews in ten states, with the intention of
showcasing policies and practices that could benefit Arizona. All of the states monitor
and list impaired waters in compliance with federal laws, but each state approaches
agricultural water quality challenges with unique frameworks, programs, policies, and
funds. Below is a brief summary of different ways states work to address agricultural
water quality, followed by a table showing which of the ten states use each strategy.
Agricultural water quality certification programs
Water quality certification programs offer a framework to assess and address water
quality risks on the farm, which gives public credibility to the work that a producer is
doing for environmental benefit. Ideally, certification programs offer layers of support
including assessment, technical assistance, cost share funding, and marketing of the
certification significance.
Certification endorsements
Some water quality certification programs offer additional endorsements or
assessments for different types of practices or environmental impacts. For example, in
Minnesota, a producer can add a Wildlife Habitat or Soil Health endorsement to their
water quality certification if they implement sufficient qualifying practices. Endorsements
serve to further incentivize farmers to consider the broad ecosystem impacts of stacked
BMPs.
State funding sources
The most impactful state water quality programs have developed a state funding stream
specific to addressing water and related issues. In some cases, this is a designated
statewide sales tax, in others there are specific state appropriations for agricultural
water quality or conservation programs.
Water quality trading programs
Some states have developed frameworks and programs for water quality trading that
can involve nonpoint source trades. This strategy brings in additional funding

P a g e | 34

opportunities for farmers or landowners to implement BMPs to reduce harmful impacts
on water quality.
Board to address state water policy
Most states have a board or council appointed by the Governor to address water policy,
programs, and allocate funding.
Conservation Districts as active partners
All states have Conservation Districts (some Soil and Water Conservation Districts,
some Natural Resource Conservation Districts) that address conservation issues on a
county or local level. Each state structures the role and resources of their Conservation
Districts differently - some are entirely volunteer-led and run, others have staff and
implement state funded cost-share programs and technical assistance.
Department of Agriculture talks about water quality
In most states, agriculture uses the largest percentage of water and contributes the
most to water quality impairments. For this reason, it makes sense for state
Departments of Agriculture to play a role in addressing water quality and conservation,
but there is a wide range of how water is discussed and incorporated in the departments
of the ten states we researched.
Active Management Areas
Many states have designated management areas with more regulations around water
quality and conservation. There are often more resources designated to achieving
water-related goals in these targeted areas.
Watershed plans
Several states have reorganized their water quality planning efforts to focus on
watersheds rather than political boundaries such as counties or districts. This allows for
more coordinated efforts to address impaired waters more effectively.
Public messaging
Some states have created messaging campaigns to build public awareness and political
will in support of clean water.

P a g e | 35

Table 1: Summary of the practices and policies across ten states. Data sourced from
individual case studies outlined in the section below.

State State Board
Cost- to Address Active
Share Water Policy SWCDs

Dept. of
Ag
Active
Discusses Management Watershed Public
Water
Areas
Plans
Messaging

State

Cert.
Prog.

State
Endorsements Funding WQT

AZ

No

No

Yes

Pilot No

Yes

Volunteer

No

Yes

Yes

No

CO

No

Yes

Yes

Pilot Yes

Yes

Mix

Yes

Yes

Some

Yes

KS

No

No

Yes

Pilot Yes

Yes

Staff

Yes

Yes

Yes

Yes

MI

Yes

Yes

Yes

Pilot Yes

No

Staff

Yes

Yes

Yes

Yes

MN

Yes

Yes

Yes

Yes

Yes

Yes

Staff

Yes

Yes

Yes

Yes

MO

No

No

Yes

Yes

Yes

Yes

Staff

Yes

No

Some

No

NE

No

No

Yes

No

Yes

Yes

Staff

Yes

Yes

Yes

No

NM

No

Yes

Yes

No

No

Yes

Mix

Yes

Yes

Yes

Yes

VT

Yes

Yes

Yes

No

Yes

Yes

Staff

Yes

Yes

Yes

Yes

The state case studies below highlight state-level agricultural water quality schemes
based on our research and interviews.

Arizona
Arizona, and the western United States, has been in a long-term drought for 27 years.
This impacts the availability of water throughout
Arizona, and the western United
Arizona, which receives most water from Lake
Mead from the Colorado River Basin. Lake Mead
States, has been in a long-term
serves the lower Colorado river state users and
drought for 27 years. This
is dropping at exponential levels. To combat
impacts the availability of water
drought, Arizona has attempted to maintain
throughout Arizona, which
water quantity within the state. The Groundwater
receives most water from Lake
Management Act of 1980 allowed for limiting
Mead from the Colorado River
water use within Active Management Areas
Basin.

P a g e | 36

(AMAs) where agriculture was not permitted to expand past 1980. AMAs currently have
programs to maintain water quality and quantity through regulation or voluntary
practices implemented on the farm.
It is important to understand that with water quantity issues, there are bound to be water
quality issues as well. Arizona does not currently have a nonpoint source (NPS)
program within the Arizona Department of Environmental Quality (ADEQ), which is
required by federal statute. This exemplifies Arizona’s lack of attention to water quality
problems within the state, especially relating to agriculture and NPS pollution. Although
many say Arizona does not have water quality problems relating to NPS in the state, the
Ambient Groundwater Monitoring Program proves this to be incorrect. In addition, there
are a number of Arizona water quantity initiatives and some conservation programs and
efforts throughout the state, but most do not have any mention of water quality.

AMA History
Arizona devised a long-term management plan for water conservation through the
Groundwater Management Code, enacted in 1980. The Groundwater Management
Code set up a management framework and established the Arizona Department of
Water Resources (ADWR) to administer and enforce the Groundwater Management
Code (ADWR, 2021). The goal was to eliminate severe groundwater overdraft in
populous regions. There were six main provisions:
1. Establishment of a program of groundwater rights and permits
2. A provision prohibiting irrigation of new agricultural lands within AMAs
3. Preparation every 10 years of a water management plan for each AMA, designed
to create a comprehensive system of conservation targets and other water
management criteria
4. A framework for requiring developers and water providers to demonstrate a 100year assured water supply for new growth
5. A requirement to meter/measure water pumped from all non-exempt wells.
6. A program for reporting annual water withdrawal and use
The Groundwater Management Code established AMAs. AMAs are areas within the
state with heavy reliance on groundwater and have the highest degree of groundwater
regulation within the State. Regulations include a prohibition on new irrigation acres,
mandatory water conservation programs and annual water use reporting requirements.
AMAs are responsible for administering the 1980 Groundwater Management Code and
the enforcement of those requirements within AMAs and Irrigation Non-Expansion
Areas (INAs). INAs were created in some rural farming areas to preserve existing

P a g e | 37

irrigation of cultivated lands, but at a lower level of regulation than the AMAs.
Management Plans are put forth for every AMA during each Management Period.
Currently, all AMAs are in the third Management Period (3MP). Each AMA has a goal to
reach, most having to do with reaching a safe yield (except for the Pinal AMA, which is
focused on preserving the agricultural economy at present). 82% of Arizona’s
population is within these AMAs, so it is important to consider water management
particularly within the AMAs. The main goals were to reach a safe yield of water within
the AMAs by 2025. The safe yield is a long-term balance between groundwater
withdrawals and recharge, but since this yield is not specifically quantified this definition
leaves room for interpretation from different stakeholders.
The Arizona Water Settlements Act in 2004 established CAP cuts across the Pinal
AMA. The issue remains that the DCP has reduced CAP water availability for
agriculture, thus an expected increase in groundwater pumping is expected.
The main goals for each AMA can be found below, along with challenges and
successes in each.
Table 2: Overview of AMAs and their unique attributes. Data sourced from ADWR,
2022c.
AMA

Management
Goal

Challenges

Successes

Importance

Pinal

To allow
development of
non-irrigation
use and to
preserve
existing
agricultural
economies for
as long as
possible,
consistent with
preserving
future water
supplies for
non-irrigation
use

Length of time to
preserve
agricultural
economy not
specified, nor are
non-irrigation uses
defined. 90% of
water demand is
agriculture based
(tribal and nontribal). Irrigation
efficiency could be
redundant if double
cropping

Irrigation
efficiency has
been
achieved

Second largest
AMA by water use.
The only unique
AMA to preserve
agricultural
economies. The
reduction in farms
did not occur as
planned or
expected.

P a g e | 38

Santa
Cruz

To maintain
safe-yield and
to prevent local
water tables
form long term
declines (the
double goal is
due to the
unique
hydrology within
the AMA,
surface water
and
underground
water are
intertwined)

Aquifers are narrow Has reversed
and shallow,
decline
making them more partially.
sensitive to
precipitation
changes and
streamflows.
Another water
demand lies in
riparian habitat,
providing important
ecosystem
services. Aquifer
capacity is limited.
Many general
stream
adjudications
ongoing. No direct
access to imported
water supplies
(natural recharge
via Santa Cruz
River).

Southern border is
the US-Mexico
border (aquifer in
Sonora impacts
water conditions in
AMA). Water from
both sides of the
border is treated
and will eventually
recharge the
aquifer. The
northern boundary
is with Pima
County.
Groundwater flows
out of Santa Cruz
into the Tucson
AMA (and
eventually
impacting all
AMAs)

Tucson

To reach a
safe-yield by
2025

If CO River
supplies are cut, it
would be difficult to
maintain safe-yield
in the long term.

TAMA is much
larger than
SCAMA, so it is
likely SCAMA
would be impacted
by the underflow
from the TAMA.

Prescott

To reach safeyield by 2025

Heavily reliant on
groundwater and
surface water
inconsistently
available. No
imported water

Has made
progress
towards safeyield, using
imported CO
River water to
offset
groundwater
pumping.

Practical and legal
impediments to
maintaining a safe
yield and
importation (i.e.
infrastructure

P a g e | 39

Phoenix

To reach safeyield by 2025

supplies. Many
legal impediments
(prior
appropriations,
adjudications, prior
agreements, etc)

would take time
and resources that
are generally
unavailable).

20% of water
supply comes from
the CO River, so
shortages impact
the AMA greatly.
Surface water
variable depending
on drought
conditions

Largest AMA in
terms of
population, square
mileage and total
water use. ⅓ of
annual water
supply is in state
surface water

No AMA besides the Tucson AMA is expected to reach a safe yield or management
goals by 2025. Within the AMAs, there are areas designated as Irrigation Districts.
Irrigation Districts are subdivisions that were established as a special taxing district for
agricultural improvement or irrigation and conservation. The Irrigation Districts have a
service area in which they can receive, pump and distribute water to irrigated land.
Currently, there are 59 Irrigation Districts within the AMAs (ADWR, 2022c).
As of 2019, all AMAs were in a state of overdraft besides the Tucson AMA. The Tucson
AMA has been in a long-term state of balance but faces many challenges to maintain
that balance. Overdraft is a condition in which the volume of groundwater coming out of
the aquifer is greater than the volume of recharge going in, over an annual or long-term
period. Overdraft is a quantitative measure that is used to assess safe-yield within the
AMAs, since safe-yield only relates to groundwater (and only those waters legally
defined as groundwater, not underground Colorado River water). This quantitative legal
concept is applied at an AMA wide scale, being one way to measure aquifer health,
although it does not guarantee levels will remain stable. Continued overdraft can
diminish future Assured Water Supply (AWS) determinations (explored in detail below).
Deeper water can decrease in water quality, which can create treatment costs and the
need to deepen wells. Subsidence can also be an issue if continuing overdraft occurs.
This creates potential reduction in surface flows connected to groundwater sources, and
possible issues with water availability for wild flora and fauna, or recreational purposes
(ADWR, 2022c).

P a g e | 40

Water Quantity Trading in Arizona
The state of Arizona has four main water supplies and six water regulation regimes.
Four main supplies:
• Colorado River water
• Instate river water
• Ground water
• Recycled water
Colorado river water makes up 40% of Arizona water supply and is governed by the
Colorado Compact, which is a multi-state compact and a whole body of federal statutes,
national treaties, and other rules and regulations. To trade Colorado River water from
one person to another requires approval of the Secretary of the Interior of the United
States.
Groundwater, (pumped through wells in the ground) has two different legal regimes and
five different designated AMAs: Phoenix, Pinal county, Santa Cruz river basin, Tucson,
and Prescott basin. Within those active management areas, groundwater is subject to a
cap and trade system, and it is heavily regulated. When Arizona passed the Water
Management Act, by agreement there was a prohibition on the development of new
irrigated agriculture because of concern for overdrafting groundwater at a huge rate
(two and a half million acre feet per year). Arizona has a complex set of rules around
the use of groundwater within these active management areas. In those areas, entities
like farmers, cities, and irrigation districts can store water in the ground to get credits,
and actively trade those credits. This is where Arizona has water markets, within the
AMAs.
Outside of the AMAs there is no regulation around the use of groundwater.
Instate surface water rules dictate that the first entity that comes along and diverts water
from the stream has the senior right to use that water, and the next person who comes
along can get their share only after the first person uses their whole share. This is
governed by the legal doctrine of prior appropriation. You cannot simply trade water. If
you want to transfer legal rights, you have to follow a process that protects all of the
other users in the systems. There is no market for trading under this regime.
Finally, recycled water is water that’s treated by a city or an industrial user. It is
Colorado River water, in-state river water or groundwater that gets used, and then the
particular entity treats the used water for reuse. The rule for the reclaimed water is that
the entity that treats the used water can do whatever it wants with it. Arizona does have

P a g e | 41

a market for reclaimed water. For example, if the city of Tempe has reclaimed water, the
city can sell it to a buyer or claim credits.

Active Management Plan Limitations
Management Plans are limited in their abilities to move AMAs towards their
management goals because often they can be outside the plan’s influence. For
example, the management plans are limited by the statutory focus on groundwater for
conservation. Although management plans only refer to groundwater, water is
interconnected. With this in mind, a change in total water use, or in the use of another
type of water source, can influence the utilization of groundwater. For example, an
increase in surface water availability and use could offset groundwater use, or vice
versa. In addition to the water source, transfers of water within the state have the
potential to impact goals (ADWR, 2022c).
Another obstacle for AMAs to reach their goals is the allowable pumping under the
Groundwater Management Code. A key assumption to the Groundwater Code was that
less intensive uses of groundwater would gradually replace agricultural and other
intensive uses of groundwater and that renewable supplies would be used to replace or
offset groundwater demand. So, the Groundwater Code was created without a concrete
plan to develop agricultural land into less water intensive uses (i.e. residential or
industrial uses), and this did not allow significant reductions in groundwater withdrawals.
Under this assumption, significant groundwater demand was allowed to continue, and
certain new demands were also permitted. In many cases, non-irrigation development
occurred without anticipated offset of reduced irrigated acreage (development leaned to
occur on raw desert land instead of historically agricultural land). This resulted in overall
increases in total water use and has allowed the same overall increase in groundwater
use.
Interactions with implementation of other water conservation programs is also an
obstacle in addressing AMA goals. These management goals can be used or
referenced in other regulatory programs but can be interpreted or applied differently for
different purposes. To receive an AWS designation, one must be consistent with the
management goal within that AMA. The AWS Program operates within the AMAs to
maintain the economic health of the area by preserving groundwater resources and
promoting long term water supply planning. Even by meeting the criteria laid out in the
management goals, overdraft may still occur in the AMA. This reduces physical
availability and leads to more challenges for AWS applicants (Safe Yield Report, 2022).

P a g e | 42

According to the Safe-Yield Report, the last obstacle to overcome to achieve the
management goals laid out is the scope of existing authorities under the management
plan itself. Arizona is transitioning into a hotter and drier future, which will impact the
availability of Colorado River supplies (comprising about 40% of AZ water supplies). In
addition, regulations will be more impacted by economic considerations. Economic
considerations are often outside the influence of management plans, like markets and
incentives. For agriculture specifically, crop prices have a large impact on the amount of
land irrigated and the crop type planted, since both impact water use. The conservation
potential for the conservation programs already in place may be limited as well, due to
the regulated community being unable to pay for those requirements. Since all water
supplies are going to be more constrained in the future, management goals will only be
met with a combination of augmenting supplies and managing/reducing demand in all
sectors. Demand management seems unlikely with current regulatory tools in place,
current provisions exist for allowable groundwater mining, increased non-irrigation
development and concerns relating to economic viability of regulated communities (Safe
Yield Report, 2022).
All AMAs are in the 3rd Management Period (3rd Management Plan implemented in
1999) and currently in process of formulating and adopting 4MP (period: 2010-2020)
•
•
•

4MP was delayed due to the 2008 recession
The AMA Groundwater Users Advisory Council meetings are the forum for public
comment
The provisions of the 4MP will be in effect until the Fifth Management Plan is
effective, for the period 2020-2025 (ADWR, n.d.a).

Arizona Agriculture
Arizona has very limited crop production but remains intense in some areas. Yuma, for
example, is the leading supplier of winter vegetables across the country. This is due to
the lack of frost and availability of sunlight and water throughout the year. Most
pollutants from crop production are sediment, pesticides, total dissolved solids (TDS;
specifically salinity), selenium, nitrogen and phosphorus. Excess applications of
nutrients can result in eutrophication of shallow lakes used for irrigation, as well as wind
carrying soil particles from a field to surface waters.
Irrigation is often used to protect against freezing/wilting and supplement natural rainfall.
If this is done inefficiently, it can cause water quality problems. Rainwater in wetter
states can carry residues from applied chemicals deep into the soil. Excess irrigation
can concentrate those residues in the top of the soil. So, irrigation return flows can also

P a g e | 43

contain these concentrated residues. Canals used on farms usually provide water for
irrigated crops and a channel for polluted runoff being returned to surface waters.
Ranching in Arizona is common, and grazing can cause water quality problems within
the state. More than 1,000 grazing allotments are present on public and tribal land.
Livestock are drawn to water and the surrounding riparian habitat in such a hot and dry
environment, sometimes a perennial stream is the only source of water nearby. Grazing
can create water quality problems by contributing sediment and animal wastes
containing nutrients and disease-causing organisms to surface waters. Soil disruption
and natural vegetative cover reduction can increase erosion and destabilize stream
channels, which can be done by grazing. Currently, the US Forest Service adopted an
Adaptive Management Approach, requiring a change in number of grazing animals on
the land or BMP implementation before the permit is renewed for grazing. This has
been improving some conditions in Arizona (ADEQ, 2014).
In addition to grazing, timber harvesting has impacted water quality. Arizona has
harvestable forests all the way from the Colorado Plateau to the Mogollon Plateau. Most
of the water quality issues arise from habitat destruction. This can also impact wildfire
occurrence and pollution.
The Office of Border Environmental Protection (OBEP) is a branch of the ADEQ
Director’s Office that focuses on the border region of Arizona and Sonora, Mexico. This
is located in Tucson's Southern Regional Office. This area is defined as a 100km buffer
zone on either side of the international boundary. The 1983 La Paz Agreement details
this border treaty. It is important to consider water quality and regulation will impact not
only Arizona within state borders, but surrounding areas within the shared watershed.
The Santa Cruz AMA specifically will need international consideration for water
management (ADEQ, 2014).

Arizona’s Primary Water Quality Problems and Ambient Groundwater
Monitoring Program
According to a 20-year study on Water Quality in Arizona by the ADEQ Ambient
Groundwater Monitoring program, arsenic was the most common exceedance under the
Primary Maximum Contaminant Levels (Primary MCLs) having been found in
exceedance in 22% of the 1766 sites tested for water quality. Arsenic occurs when
natural geochemical conditions allow for dissolution of arsenic from aquifer materials.
Specific to agriculture, irrigation can increase arsenic levels by recharging aquifers and
those aquifers encountering sediments present with arsenic. In addition, low rates of
natural recharge can increase arsenic levels in groundwater, thus tying together the

P a g e | 44

impacts of water quantity and quality. This occurs from long groundwater residence
times, which allows for increased interaction with aquifer sediments and a higher pH.
High pH levels promote detachment of arsenic from sediments and, therefore, increase
its concentration in groundwater (Towne & Jones, 2016).

Arsenic was the most common exceedance under the
Primary Maximum Contaminant Levels, having been found in
exceedance in 22% of the 1766 sites tested for water quality.
Most Primary MCL exceedances were found in the Southwestern part of the state, with
a frequency of over 50%. This poor groundwater quality is impacted by shallow aquifers,
irrigated farming, and older groundwater that tends to have a high pH and sodium
chemistry (producing higher levels of arsenic and fluoride present). Yuma is an
exception to this pattern because Colorado River water is a source of irrigation. The
fresh water flushes the aquifers and groundwater moves out of the basin, with the
assistance of drainage wells.
Along with arsenic, nitrate contamination can also occur from agricultural production
(specifically the use of fertilizer). Another nonpoint source is from wastewater
discharges from failing septic systems. Irrigated farmland is the largest source of nitrate
exceedances. There were five tested basins that had nitrate exceedance frequencies
higher than 20%: Gila Bend, Harquahala, McMullen Valley, the Rangeras Plain and the
Pinal AMA. All of these locations have significant amounts of irrigated cropland. In
addition, shallow, domestic wells that are located among these irrigated fields are likely
to have high nitrate concentrations. For example, nitrate concentrations are significantly
higher in the shallow perched aquifer, which is recharged via irrigation, than six other
aquifers tested in the McMullen Valley. In the Gila Bend basin, nitrate is much higher in
younger groundwater that was recently recharged than that of older groundwater
(Towne & Jones, 2016).
These contaminants exemplify the need for water quality management in Arizona,
specifically in areas with agricultural development. Groundwater in Arizona accounts for
43% of annual water use in the state, according to the ADEQ Ambient Groundwater
Monitoring program. The Ambient Groundwater Monitoring program is essential to
address the gap of characterizing groundwater quality, but this program does not look at
tribal lands. ADEQ is not responsible for nonpoint source monitoring and does not
regulate agricultural and septic wastewater disposal systems, which tend to be major
nonpoint sources of pollution in Arizona’s waters. In addition, Arizona uses the CWA as
its primary tool to protect and regulate surface waters. The ADEQ Ambient Groundwater
Monitoring Program is mostly done by one person over 20 years within a single

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department, so the data is standardized and can be compared state-wide. The
monitoring program fills that data gap and characterizes water quality conditions in the
state’s groundwater (Towne & Jones, 2016).
The vast majority of the groundwater is used to irrigate crops, as well as for public water
supply. Groundwater quality is important to consider because the groundwater
discharge creates the base flow for streams, wetlands and lakes in the state. This
directly impacts the water quality of surface waters. In particular, agricultural activities
have increased the amount of TDS in many waters. TDS will usually refer to salts
dissolved in the water. TDS is important to address potable water in the state,
considered a Secondary Maximum Contaminant Levels (Secondary MCLs). TDS
concentrations occur from a number of natural processes, like mineral dissolution. As
groundwater moves downgradient—into low-lying areas—the water chemistry shifts to
higher concentrations of sodium, chloride, and sulfate. This results in higher levels of
arsenic and fluoride moving downgradient as well. In closed basins, evaporative
concentration can cause significant TDS accumulations over time. The use of fertilizers
and treated wastewater for irrigation increased concentration of TDS in shallow
groundwater. The highest exceedances for TDS are present in Southwestern basins,
which are surrounded by extensive irrigated agricultural production. In every sample
tested in Gila Bend and Yuma basins, the exceedances of TDS remained above 75%.
The lowest TDS levels were found in the Southeastern part of the state.
In Arizona, it is estimated that over 330,000 residents, 5% of the state, use private wells
for drinking water. One third of these wells produce water that is contaminated and are
often unregulated. Private wells are not subject to EPA’s SDWA and are not required to
be tested, which is rarely done throughout the state. Analysis is a prohibitive cost for
most private well owners, testing for the main constituents (arsenic, fluoride, uranium,
gross alpha, nitrates) can cost upwards of $300, while bacteria testing (E. coli) can cost
up to $570. Water quality should be considered in all parts of the state, and private well
testing should be conducted regularly to maintain healthy communities.
What follows is a list of current government entities dealing with water quality and
quantity.

Arizona Water Protection Fund
The Arizona Water Protection Fund (AWPF), along with the Arizona Water Protection
Fund Commission, was created in 1994 to provide an annual source of funds for the
development and implementation of water quality and water quantity measures, and to
maintain, enhance and restore bodies of waters throughout the state, all while being

P a g e | 46

consistent with current water rights and laws. The AWPF Commission is responsible for
administering the fund, along with assistance from ADWR (Arizona Water Protection
Fund, n.d.).
The AWPF Commission consists of 13 members and is the main policymaking body for
the fund. This includes nine voting members that must be residents of Arizona and
represent a variety of different stakeholders (i.e. variety of land and water use, as well
as socioeconomic perspectives). In addition, there are two non-voting members: the
director of ADWR and the commissioner of the Arizona State Land Department. There
are also two non-voting advisory members: one from the House of Representatives and
another from the Arizona State Senate. The AWPF administration provides technical,
legal, and administrative staff to the AWPF Commission, and is managed by its
Executive Director. Staff includes ADWR legal counsel and support from ADWR legal
division (ADWR, 2021).
To date, 12 AWPF grant projects are being implemented in Arizona. In addition, AWPF
has supported 243 projects, awarding close to $48 million toward restoration, protection
and enhancement of water and riparian resources in Arizona.
These are the current AWPF grant projects for FY22, including six that have been
funded in this grant cycle:
Table 3: Current Arizona Water Protection Fund grants. Data source: ADWR, 2021.
Project

Gila Valley
Irrigation District
System
Optimization
Phase I

Winkelman
Natural
Resource
Conservation

Purpose

Funding
Amount

To improve Gila Valley
$623,702
Irrigation District’s
efficiency and available
flow at turnouts for onfarm deliveries, increase
efficiency of individual
irrigators and conserve
water downstream
Create a Tamarisk
Management Plan, as
well as remove tamarisk
from the Gila River and

$205,844

Accomplishments

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District Riparian
restoration

revegetate the riparian
corridor

Upper, Middle,
and Lower Fossil
Creek Invasive
Plant Removal

Eliminate Russian olive
and giant reed and
manage tamarisk and
Tree of Heaven to 10%
of the riparian corridor

$98,662

Harrenburg
Wash
Enhancement

Implement stream
$129,190 Work to address the
channel improvements,
headcuts was completed
remove invasive weeds,
November 2021, and in
revegetate area with
December placed wetland
native species, clean up
plant seed and fabric over
and removed of debris
the headcuts. In February
from the site (previous
2022, seeded some of the
channel excavations
upland areas and laid down
that created head cuts
straw fabric to prevent
lead to areas of excess
erosion. In April 2022,
flood fill), and the
wetland seeding completed
construction of a parking
and cottonwood/willow
area boundary
planted/fenced. This July,
there are two weed pull
volunteer events at the site

Paria Beach
Riparian
Restoration

Tamarisk control and
$187,699 Prescribed fires took place
native species
for tamarisk removal
revegetation along the
Colorado River, the
purpose is to further
inform riparian
vegetation in other SW
states involving tamarisk
removal (impacted by
the tamarisk beetle)

Fort McDowell
Yavapai Nation
Lower Verde

To control invasive plant $237,246
species along the Verde

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River Riparian
Restoration

River and restoring
native vegetation

Verde River
Riparian
Restoration
(Highway 89A to
Bignotti Picnic
Site)

To control invasive
plants and create
landowner outreach to
educate and engage
people on the threats of
invasive riparian plants

Little Green
Valley Fen
Restoration
Feasibility Study

Create a restoration
$77,003
plan for the wet meadow
function of the Little
Green Valley Fen, and
propose a budget for
those restoration
activities

The Path to
Protection at
Oak Creek:
Social Trail
Rehabilitation for
Watershed
Health

Increased visitation
$238,980
caused soil and erosion
and transporters
sediment/E.coli into Oak
Creek, the project will
accomplish a high
priority project approved
in the Oak Creek
Watershed Restoration
Action Plan and aims to
improve riparian habitat
for wildlife and stream
water quality

Dye Ranch
Erosion Control
and Wetland
Improvement

To improve habitats
along the ephemeral
stream and meadow on
Dye Ranch, the project
aims to reduce erosion,
improve water quality
and aid in floodplain
development (by

$247,350

$76,945

P a g e | 49

allowing floodwaters to
spread out)
Habitat
Restoration in
the Gila River
Riparian
Corridor

To promote nativeplant
establishment and
survival despite
tamarisk decline,
shifting focus towards
active management of
previously treated sites

$97,455

Ravenna and
Pampas Grass
Control along
the Colorado
River from Glen
Canyon Dam to
Diamond Creek

Mapping and manually
removing Ravenna
grass and pampas
grass from the area

$43,178

Almost all of these projects are related to habitat restoration of native species. Although
the AWPF aims to restore water quality and quantity, the quality aspect is not relevant
or measured in these projects. Out of 12 projects, only three mention water quality
specifically: Gila Valley Irrigation District System Optimization Phase I, The Path to
Protection at Oak Creek: Social Trail Rehabilitation for Watershed Health, and the Dye
Ranch Control and Wetland Improvement. In addition, the only farm specific project is
the Gila Valley Irrigation District System Optimization Phase I Project. Most grants fund
invasive species removal, specifically tamarisk (ADWR, 2021).
Tamarisk concentrates salt in its leaves, making the soil saltier and less favorable for
native plants. It also grows quickly and in dense stands, overcrowding the area.
Tamarisk has a deep tap root, which means it can often outcompete native plants in
drought conditions. In addition, tamarisk can change water flow patterns, its stems trap
sediment and cause shallower channels and increased flooding. The Brazos River in
central Texas is an example of how detrimental tamarisk can be, becoming 8ft
shallower and 300ft narrower in about 38 years (1941-1979). It can also create a hurdle
for livestock to reach water. Tamarisk is depleting the groundwater supplies, specifically
in areas with farm irrigation. Even if the tamarisk removal is successful, the soil remains
salty and it can be harder to reestablish native plants. Since tamarisk changes water
patterns, quality can be impacted greatly. It is important to consider water quality with
quantity projects, especially with dwindling groundwater supplies being impacted by

P a g e | 50

invasive species (Beitler, 2007). Salinity of the
soil is a major problem in Arizona, an example
of impacts on water quality and quantity. Some
crops can leach salts from the ground, while
others actually add to the salt present. When
speaking about vegetable production in Yuma,
several interviewees mentioned that crop irrigation is so efficient today that it leaves a
lot of salts behind that build up in the root zone. This shows how important crop type
and irrigation is to reducing water overdraft, in addition to keeping the water quality
(Allen, 2019).

Crop irrigation is so efficient
today that it leaves a lot of
salts behind that build up in
the root zone.

Arizona Reconsultation Committee
The Arizona Lower Basin Drought Contingency Plan Steering Committee, known as the
2007 guidelines, was recreated to form the Arizona Reconsultation Committee (ARC).
ADWR, along with the Central Arizona Project (CAP) will develop an Arizona consensus
on the reconsultation of the Colorado River 2007 Guidelines, which will be renegotiated
in 2026. The Drought Contingency Plan (DCP) is being used as a template for ARC.
This committee met for the first time in June 2020. The process is expected to take
several years to complete (Central Arizona Project, 2022).
As of 2021, Arizona still maintains tier zero status, contributing 192,000 acre-feet of
Arizona’s 2.8 million acre-foot annual entitlement to Lake Mead. This contribution is
solely through the CAP. Recently, shortages for tier 1 reductions were announced.
(ADWR, 2021).

Arizona Department of Water Resources
The Arizona Department of Water Resources (ADWR) administers the Arizona water
laws, except those that are related to water quality. ADWR also explores augmenting
water supplies to meet water demand, as well as develop and implement policies to
promote water conservation. ADWR is responsible for jurisdictional dams and reservoirs
in the State to protect the public. The primary task of ADWR is to implement and
manage the 1980 Groundwater Management Code. This legislation requires ADWR to
create a series of five management plans, each unique to that particular AMA. The
assumed result of these management plans is to complete each requirement by the end
of the management period year. These plans include mandatory conservation
requirements for all industries. ADWR is not responsible for water quality management,
but rather ADEQ enforces these regulations. ADWR supervises and controls

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jurisdictional dams/reservoirs in Arizona, to protect life and property. The department
monitors Colorado River water entitlements in the mainstream region, and water
deliveries through the CAP to irrigation districts, agricultural producers, and cities. The
Colorado River water is contributed solely through CAP (ADWR, 2021).
The DCP in Arizona is a set of agreements to protect the Colorado River resources
through voluntary reductions and increased conservation. These agreements included
Mexico, along with multiple states within the US. The ADWR and CAP were participants
from Arizona. Within the DCP, there is an Upper Basin DCP (including CO, NM, UT,
WY) and the Lower Basin DCP (including AZ, CA, NV). A companion agreement
connects these programs and connects to Mexico through a US-Mexico Agreement.
The purpose of the agreements are to share risks and opportunities relating to water in
the Colorado River basin. For Arizona specifically, the DCP provides greater certainty
for reliable and secure water supplies. The current predicted risk of Lake Mead going
below 1025’ by 2026 with DCP implementation is about 8%. It is assumed that without
DCP, there is a 43% chance of Lake Mead going below that level. The DCP
Authorization Act was signed in 2019, starting Arizona Colorado River basin reductions
in 2020. These agreements will also be renegotiated in 2026.
DCP continues to be implemented across the state with new agreements underway,
such as the Colorado River Indian Tribes System Conservation Agreement and the
Groundwater and Irrigation Efficiency Fund Agreement. Grants from the Groundwater
and Irrigation Efficiency Fund sets the framework for ADWR funding projects, by
qualified irrigation districts to construct/rehab wells and related infrastructure for the
efficient use of groundwater. The assumption is that these projects are to facilitate the
transition from surface water to groundwater. In FY21, ADWR gave over $4 million to
four irrigation districts. Without the DCP and other Arizona efforts, Lake Mead would be
almost 50ft lower.
Arizona and the CAP have the most to lose from DCP agreements because Arizona has
junior priority to the Colorado River supplies. This means its supply will be cut first when
reductions occur. The most important aspect of the DCP is that it does not prevent a
Colorado River shortage, which is an increasingly prevalent issue in Arizona (with Lake
Mead being the Lower Basin’s primary reservoir). The goal is to address changing
hydrology within the Colorado River.
ADWR is also responsible for representing Arizona in adjudications of surface water
rights with tribal nations. These adjudications occur in two main portions of Arizona, the
Gila River System and the Little Colorado River System. These adjudications determine
the nature, extent and priority of water rights.

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Specific to the Colorado River, there is a Colorado River Basin Salinity Control Program
that is focused on improving water quality by attempting to reduce salinity levels in the
Colorado River. Within the Program, there is a Salinity Control Program Forum and an
ADWR representative, appointed by the Governor, represents Arizona in the Forum
(along with two other Arizona representatives). The purpose of this interstate program is
to provide technical expertise and policy guidance to future and current Salinity Control
Programs in order to reduce costs of salinity, specifically from TDS in the Colorado
River Basin. This is especially important for main-stem users at the end of the Colorado
River, where salts often collect from the head of the River.

Current Arizona Initiatives
The current Arizona water initiative, as determined by Governor Ducey, is the creation
of the Governor’s Water Augmentation, Innovation and Conservation Council for
discussing water problems in the state. Forty-three members were appointed to the
council, including a collection of diverse stakeholders and members of the legislature.
The goal of the council is to identify and recommend opportunities for water
augmentation, innovation or conservation. The most recent conversations were focused
around the Desalination Committee that summarized the legal and regulatory limitations
to brackish groundwater. In addition, the Non-AMAs Groundwater Committee proposed
the establishment of Rural Management Areas (Arizona Governor's Water
Augmentation, Innovation, and Conservation Council, 2021).
Within the council there are several programs to note the importance of water
conservation and quality:
The Drought Program provides resources to the public and committees within the
program include the Drought Monitoring Technical Committee, the Interagency
Coordinating Group, and the Local Drought Impact Groups. These were all developed
through the Arizona Drought Preparedness Plan that was adopted in 2004. Since 1999,
a Drought Emergency Declaration has been in effect in the state of Arizona.
The Conservation Program offers conservation assistance, outreach and education on
conservation resources and regulations. It encourages the efficient use of water through
conservation practices. The Program provides water conservation assistance in
collaboration with regional and national conservation partners. The most recent
publication of the Conservation Program is the Pinal and Santa Cruz AMA Low-WaterUse/Drought Tolerant Plant Lists for the Fourth Management Plans (ADWR, n.d.a).

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For rural communities outside of the AMAs, the Rural Planning Program provides
resources to those communities. The 1999 Rural Watershed Initiative provides technical
information, administrative support and advice on water issues. The Rural Planning
section carries on this work. The Program collects data and technical studies of specific
rural areas in the state. The studies are conducted in collaboration between ADWR and
USGS (through contractual agreements). Since 2000, the Arizona Legislature has
provided annual funds to ADWR for Rural Water Studies. These funds are generally
used to monitor hydrogeologic changes in rural areas.
As mentioned previously, the 1980 Groundwater Management Act may be the single
most important piece of legislation to conserve water within AMAs. The AMA section is
responsible for administering and enforcing the Groundwater Management Act. Within
AMAs, strict regulations were imposed through the Act. These include prohibition on
irrigating new acres, mandatory water conservation programs and reporting
requirements on water use. Irrigation Non-Expansion Areas (INAs) were established in
some rural farming areas to be regulated at a lesser degree than AMAs. In November
2020, Governor Ducey signed an executive order to continue the Agricultural Water
Conservation BMP Advisory Committee (which is chaired by a Pinal AMA farmer). This
order will allow better stakeholder discussions and development of the Agricultural BMP
Program. In early 2019, the State General Fund appropriated $2 million to ADWR
through DCP provided grants, known as the Groundwater Conservation grants, to
support groundwater conservation and reduce withdrawals within the AMAs. The most
money was awarded to the Phoenix AMA ($1,245,000). Tribal water users are not
subject to Groundwater Management Act requirements, as well as management plan
requirements. They are also not required to submit annual water use reports to ADWR
(Governor’s Water Augmentation, Innovation, and Conservation Council Annual Report,
2021).
The Surface Water Program is through ADWR as well. This Program provides permits,
certificates and claims for the use of surface water in Arizona. This is for waters other
than mainstem Colorado River basin users.
Governor Ducey recently signed Senate Bill 1740, giving the Water Infrastructure Fund
Authority more funding and authority to “empower the state to be proactive in bringing in
new water sources” (Hill, 2022; State of Arizona Senate, 2022). Although this is aimed
to conserve water, it seems limited to finding new sources rather than conserving
present sources of water. The goal is to conserve water for all aspects of the state,
including agriculture, but it does not state if the price of water will go up or if there will be
additional conservation requirements placed on farmers. Farmers are impacted most
dramatically by these shortages in the center of the state, since farmers near the Yuma
area have more water availability from the CO River basin.

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In addition, ADWR has six main priorities to accomplish:
•

Protect the Colorado river system: by implementing AZ Reconsultation Process
and by executing DCP implementation plan

•

Support general streams adjudication: by completing multiple major technical
reports

•

Protect life and property of AZ: by helping dam owners address their safety
deficiencies, auditing floodplain management plans and responding to requests
for flood assistance

•

Improve accessibility and accuracy of AZ water data: by advancing data quality
initiative by publishing new dashboards online

•

Advance water planning priorities: by completing and publishing drafts of 5th
Management plans in the AMAs

•

Recruit, retain and develop highly skilled personnel: by implementing postCOVID telework, reducing reliance on employee-owned equipment and
reclassifying Hydrologist and Water Resources positions

•

Support ongoing drought mitigation measures: by collaborating with Drought
Mitigation Board to establish policy detailing ADWR’s responsibility in supporting
the newly formed committee (established 2021)

It is important to note that none of these priorities speak about water quality and the
protection of water quality in AMAs (Buschatzke et al., 2022).
According to Arizona Revised Statute (ARS) 45-465, “only land associated with a
certificate of Irrigation Grandfathered Right (IGFR) can be legally irrigated with
groundwater within an AMA” (ADWR, 2022a). IGFRs are issued by ADWR based on
irrigated acreage during 1975-1980. This statute includes calculations for water use.
ADWR is also required to develop and administer an Agricultural Conservation Program
in each AMA for all management periods. There are three programs in which IGFRs are
enrolled (ADWR, 2022a).
Base Program: Each IGFR owner, along with any entitled groundwater user, is
regulated under the Base Program. IGFRs are assigned water duties and allotments
based on crops grown during the 1975-1980 period. A water duty is the total volume of
water needed throughout the season to grow that crop to maturity. ADWR allows for
flexibility credit accounts for each IGFR in the Base Program, which allows IGFRs to

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borrow or bank groundwater in varying climates and market conditions. These credits
can be used at any time in the future on the same farm, or it can be used to offset
debts. Under specific conditions, IGFRs can transfer, convey or acquire credits to or
from other IGFR owners (ADWR, 2022a).
Best Management Practices Program (BMP): The BMP Program is an alternative
conservation program to be as effective at water conservation as the Base Program,
with more flexibility in achieving these goals. This is a voluntary program that has IGFR
owners implement conservation practices that involve irrigation improvements and
better water management. Farms that are enrolled do not have their annual
conservation allotment and flex credit accounts are frozen. So, instead of a maximum
groundwater allotment the IGFR owner will voluntarily commit to implementing said
practices. ADWR worked with the agricultural community to develop a list of BMPs
within the management plans for each AMA. In doing so, farms can choose which
practices to implement to have the best efficiency and water savings. To maintain
enrollment in the program, the farm must meet minimum requirements. Once the farm is
enrolled, the farm is committed to the BMP program for the remainder of the
management plan period (some exceptions may exist, which can be found in each
management plan). The BMP program assigns a point value to practices within
categories, the farm practices have to add to a total of 12 points across categories to be
considered for the program. Practices implemented prior to the application do not count
into the point system (ADWR, 2022b).
Historic Cropping Program: This another alternative conservation program and was
developed by ADWR. Within the program, accrued flex account credits are limited to
75% of the farm’s annual allotment. A negative balance that exceeds 25% of the annual
allotment means a violation of the requirement. Credits gained through the program can
be used in the future and to offset debts, but cannot be conveyed, sold or transferred
(ADWR, 2022a)
Around 35% of statewide water is under mandatory conservation program requirements
in the agricultural sector (ADWR, 2022a).

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Figure 4: Percent of Irrigation Methods by AMA. Image Source: ADWR, 2020.

In Central Arizona, which includes the Phoenix, Pinal and Tucson AMAs, there are three
main water authorities.
Arizona Water Banking Authority (AWBA): Established 1996 to increase the
utilization of Colorado River water entitlements and develop long term storage credits
for the state. Essentially, AWBA stores water from the Colorado River water for future
use in times of shortages (ADWR, 2016b).
Central Arizona Project (CAP): Construction for CAP began in 1973 and was
completed in 1993, it is managed and operated by the Central Arizona Water
Conservation District (CAWCD). The Colorado River Basin Project Act, implemented in
1968, gave way to the construction of CAP, a 336 mile long system that brings Colorado
River water to Central and Southern Arizona. CAP delivers an average of 1.5 million
acre feet of Colorado River water per year to Maricopa, Pima and Pinal counties. This is
the single largest resource of renewable water supplies in the state (ADWR, 2016b).
Central Arizona Groundwater Replenishment District (CAGRD): Established in
1993 to provide a method of meeting the Assured Water Supply (AWS) requirements for
Maricopa, Pima and Pinal counties. Water is stored underground, which will replenish

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groundwater that is being pumped out. The CAGRD is governed by CAWCD (ADWR,
2016b).

Arizona Department of Environmental Quality
ADEQ manages nonpoint source pollution by creating a management plan every 5
years through the Water Quality Division. The State’s Nonpoint Source Management
Program was originally developed under the CWA. The research and plan is done
through a Performance Partnership Grant with the US EPA. The goal is to identify and
prioritize nonpoint source threats and impairments. This is done through the
implementation and planning of actions to reduce nonpoint source pollution discharges.
In addition, the program will assess state programs, rules and authorities to protect and
restore water quality.
Nonpoint sources create most water quality impairments from pollutant loadings present
in the water. The most common nonpoint sources in Arizona are:
•

Soil erosion caused by stormwater

•

Runoff from abandoned mines

•

Wastes from pets and livestock

•

Road crossings

•

Poorly maintained septic systems

•

Runoff from impervious surfaces

The current program (2020-2025 period) had changes made to improve water quality in
the state. This includes, enhancing technical assistance, direct funding of high priority
projects, seeking additional funding for future projects, implementation of a new
prioritization strategy, focused monitoring to identify sources, and shifting focus from a
watershed scale to specific projects to improve water quality. The ultimate goal is
always to delist impaired waters. As projects are identified, they are ranked and
prioritized based on their perceived impacts on water quality. These projects can then
be implemented in watersheds with an approved 9-Element Watershed Plan by ADEQ
capable watershed groups, state agencies and Native American Tribes. The CWA 319
funding is limited in scope and quantity, so staff will seek out more funding, but these
will then be identified by internal and external customers. The highest priority projects
were focused on metal contamination, followed by E. coli. E. coli is associated with

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watershed wide activities, like grazing. Metals are much more discrete and can be found
in waters from tailing pipes in abandoned mine sites. Due to this, ADEQ approaches E.
coli impairments on a watershed-scale to realize delists of waters over the long term.
The approach to metal contamination is much more driven by priority project
implementation for more short term delists. The overall mission of the NPS Program is
to, “To achieve and maintain water quality standards through the reduction of nonpoint
source pollutant contributions to Arizona’s surface and groundwater” (ADEQ, 2014).
ADEQ does not currently have an active NPS Program, which is required by CWA
section 319. In order to receive funds, Arizona will need an NPS Program.
Within the Water Quality Division, there are several programs pertaining to NPS.
Standards Development creates standards for water quality and proposes standards to
maintain water quality in designated areas. Water quality monitoring programs for both
surface water and groundwater exist, as required by ARS 49-225 in the state
legislature. These programs include studies completed with other programs, if possible,
as well as measuring macroinvertebrates in surface water (which will show impact over
a longer period). The water quality monitoring programs also monitor the effectiveness
of BMPs. A water quality assessment is done every two years to explain the status of
Arizona’s waters (both surface water and groundwater). The Water Quality Division also
creates TMDLs for each surface water listed as impaired and watershed planning.
There is a water quality improvement grant program to allow watershed partnerships (in
addition to landowners, state agencies, local governments, universities, etc) to use
resources on projects to quantify a reduction in NPS pollution in Arizona waters. This is
funded through CWA section 319. Through this federal legislation, nine-element
watershed-based plans (WBPs) are required to be developed prior to funding future
projects through CWA 319. In addition, states must provide a 40 percent non-federal
match in order to receive federal NPS funds. Since a significant portion of the grantees
are individual landowners, nonprofits or federal agencies, this proved extremely difficult.
This resulted in a lack of funding for some high priority projects. Previously, the projects
aimed at water quality improvement have not been successful. To combat this, ADEQ
has shifted to a direct funding of high priority projects, which have a quantifiable
reduction proposed before implementation.
ADEQ also issues Aquifer Protection Permits (APPs). APPs are required for anyone
owning or operating a facility that discharges a pollutant directly to an aquifer (or the
surrounding area) in such a way that the pollutant will likely reach the aquifer. This is
mostly found in farming areas (from CAFOs, Nitrogen fertilizer, grazing, wastewater
discharges or lagoons).
Within ADEQ, there is a Pesticide Groundwater Quality Protection Program that
protects groundwater from NPS pollution. This is done by preventing/eliminating

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pollution of groundwater aquifers from routine pesticide use. This program evaluates
groundwater data and determines pollutants. It also generates the Groundwater
Protection List.
ADEQ also serves as the Biosolids/Sewage Sludge Management Program and
enforcement authority, which the EPA oversees. This Program implements section 503
of CWA, requiring registration with the department of any person applying, generating or
transporting biosolids/sewage sludge within the state.
ADEQ has the authority to establish a Nitrogen Management Area if conditions in
nitrogen loading contribute to an exceedance of aquifer water quality standards for
nitrate. If surface water becomes impaired by nutrients, ADEQ can investigate whether
the standards are being met and if the establishment of a Nitrogen Management Area is
necessary.
The Clean Water Act is currently the primary tool for protecting and regulating surface
water within Arizona. 89% of surface waters in Arizona are ephemeral streams,
meaning they only flow in response to runoff events. Many lakes often dry out and
become meadows or mudflats. Due to this, Arizona had to create their own Surface
Water Protection Act 2021 to protect the water within the state that may not be included
in WOTUS. This is one of the most important surface water protection legislations in the
state, with only CWA to protect waters in general. Most of these lakes were created as
reservoirs for irrigation purposes, only a handful of these lakes are natural. Many of
these lakes are eutrophic, due to being shallow and near farm operations. Ephemeral
streams also tend to have more sediment transport, this can occur from human
disruption in the environment that increases erosion. In addition, monsoon rains can
carry large amounts of sediment and pollutants across the landscape. While surface
water may be more available in some areas, groundwater is naturally replenished at
slow rates in most places in the state. This can be from lack of rainfall, high evaporation
losses and the depth the water needs to travel to actually recharge deep aquifers.
Clearly the landscape of the state needs to be considered when implementing a water
quality plan. Arizona extends over 114,000 square miles, with mountain ranges that
often absorb rainfall before it hits flatlands, and elevation differences across the state
(changing the types of plants, animals, and soil present). All of these factors make a
single restoration plan difficult (ADEQ, 2014).
Arizona is also home to 21 federally-recognized Native American Nations and tribal
reservations. This occupies 28% of the land in the state. Water Quality statutes do not
apply to tribal land, but EPA collaboration allows for a development by tribes of their
own plan. Currently, most have not integrated with ADEQ programs (Arizona
Department of Environmental Quality, 2022).

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Figure 5: Active Management Areas and Irrigation Non-Expansion Areas

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Minnesota
The state of Minnesota has created innovative, extensive, and coordinated water quality
programs related to agriculture. This section will give an overview of water quality
issues in Minnesota and discuss how the statewide policies and program aim to
address current challenges and opportunities for agricultural land to improve water
quality.
Minnesota is known for its abundance of surface water - lakes, wetlands, streams, and
rivers - and today the state takes great pride in protecting and promoting these assets
for recreation, environmental justice, and health. The state has a long history of working
to protect its water, using legislation and regulations to address both contamination and
conservation. In the late 1800s and early 1900s, it was routine for sewage, garbage,
and industrial waste to be dumped directly into rivers and lakes as a means of disposal.
In 1885, Minnesota passed its first legislation to prevent pollution in rivers and drinking
water. In 1897, the state law first adopted the term public waters and established state
authority over these lakes, rivers, and streams that had a use or benefit to people. In the
1930s, severe droughts pushed the state to step up protection of both surface and
groundwater, and the state began exercising more permitting authority to protect the
amount of water available for public use. In 1945, the Legislature created the Water
Pollution Control Commission to encourage communities to build wastewater treatment
plants to address unsafe drinking water from raw sewage dumped in lakes and rivers. In
1962, Minnesota experienced two catastrophic oil spills from a pipeline breaking on the
Mississippi River and a soy oil storage tank bursting on the Minnesota River. These two
oil spills were catastrophic for wildlife and water quality and led to the creation of the
Minnesota Pollution Control Agency (MPCA) in 1967, which replaced the Water
Pollution Control Commission with increased authority over air pollution and solid waste
disposal (Minnesota Pollution Control Agency, 2017b).
As water quality and quantity challenges shifted over time, so did the state’s approach
to addressing the issues. Over the last 50 years, Minnesota has enacted many
programs and policies, relying on strong cooperation among state and local agencies,
public and private organizations, as well as individuals, to address the quality of
Minnesota’s groundwater and surface waters. One of the most important pieces of
legislation in recent years is the Clean Water, Land and Legacy Amendment, known as
the Legacy Amendment, which was passed by Minnesota voters in 2008. The Legacy
Amendment to the Minnesota Constitution increases the state sales tax by three-eighths
of one percent to protect drinking water sources, restore natural ecosystems, enhance
wildlife habitat, preserve arts and cultural heritage, and support parks and trails. The
sales tax began in 2009 and will continue until 2034, with the revenue divided into four

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funds: 33 percent to the clean water fund, 33 percent to the outdoor heritage fund,
19.75 to the arts and culture fund, and 14.25 percent to the parks and trails fund
(Minnesota Legislative Coordinating Commission, n.d.). In particular, the Clean Water
Fund is of interest to this research project because it is the primary source of funding for
many of the agricultural water quality programs and policies in Minnesota. This
dedicated, long-term source of funding has allowed for strategic investment in
innovative program design and staffing to support new initiatives.
Minnesota agricultural water quality issues
Minnesota’s agricultural industry covers 25.4 million acres, right around 50 percent of
the state’s land (NASS 2021 State Agriculture Overview, Minnesota). Like most
Midwestern states, agriculture is the source of high levels of nutrients from fertilizers
and animal waste in Minnesota’s waters. Phosphorus is a leading contaminant, along
with nitrogen, sediment, and chloride (Water Pollutants and Stressors, MPCA). As
agricultural practices have altered the natural landscape through tillage and tile
installation, the amount of water moving from fields into streams, rivers, and lakes has
increased significantly. Combined with increasing usage of fertilizers, pesticides,
herbicides and the concentration of livestock into feeding operations, the negative
impact of agriculture on water quality has become extremely difficult to manage.
In Minnesota, there is strong public investment and interest in improving water quality.
The public seems to understand that clean water means protecting human health,
animal well-being, thriving ecosystems, recreational opportunities, and Minnesota’s
economy. There is also recognition that, as a headwater state, the burden Minnesota
places on surface water sources flows downstream (Why you should care about water
quality, MPCA).
Below is a snapshot summary of Minnesota’s state agencies, programs, and partners
that are involved with agricultural water quality and conservation.
Board of Water and Soil Resources (BWSR) is a 20-member board that acts as the
state’s administrative agency for 90 Soil and Water Conservation Districts (SWCD), 46
watershed districts, 23 metropolitan watershed management organizations, and 80
county water managers. Board members serve four-year terms and are appointed by
the governor to set a policy agenda. Related to agriculture, BWSR’s staff administer
grants for the Clean Water Fund and other grants, oversee planning and conservation
programs, and provide training and technical resources (Minnesota Board of Water and
Soil Resources, n.d.).

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The Buffer Law was a controversial regulatory action passed in 2016 requiring
perennial vegetative buffers of up to 50 feet along lakes, rivers and streams, as well as
buffers of 16.5 feet along ditches. The purpose of this law is to protect state water
resources from erosion and runoff pollution, stabilize soils, shores, and banks, and
protect or provide riparian corridors by filtering out phosphorus, nitrogen, and sediment
(Minnesota Legislature, 2022). The deadline for implementation for buffers along public
waters was November 1, 2017, and for public ditches was November 1, 2018. BWSR, in
collaboration with Soil and Water Conservation Districts across the state, oversees
compliance with the Buffer Law. As of July 2019, they reported that 98 percent of
parcels adjacent to public waterways were in compliance with the law (Minnesota Board
of Water and Soil Resources, 2019).
Many stakeholders that we interviewed in Minnesota noted the political challenges and
economic impact to farmers of implementing mandatory regulations to address water
quality issues. At the same time, additional technical support and financial resources
were available to help producers comply with the law. Five years later, it is clear that
regulatory strategies continue to be unpopular and unlikely to be used again in the
state, however the law has been effective in achieving targeted protections adjacent to
water bodies.
Clean Water Council was created through the 2006 Clean Water Legacy Act and is a
28-member council directed to advise the Legislature and the Governor on the
administration and implementation of the Clean Water Fund. Members are appointed by
the Governor or another appointing authority and serve until another appointment
replaces them (Clean Water Council, 2009).
Clean Water & Land Legacy Amendment was passed by voters in 2008 to increase
the statewide sales and use tax rate by three-eighths of one percent for 25 years, from
2009 through 2034. Each year, Legacy Amendment dollars are dedicated to four funds:
Outdoor Heritage Fund, Clean Water Fund, Parks and Trails Fund, and Arts and
Cultural Heritage Fund. Several stakeholders mentioned in interviews the importance of
the coalition building across different interest groups that came together to pass the
Legacy Amendment.
The Clean Water Fund has been appropriated $256.792 million during fiscal year 20222023, divided between seven agencies working on water resources. The largest share
goes to BWSR (55 percent), followed by MPCA (16 percent) and MDA (8 percent),
among others. These funds support the agencies and partner organizations to address
water quality with a wide variety of programs and strategies, including grants to farmers
to implement BMPs, technical assistance and training, compliance with regulations,

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permanent conservation easements, and more (Minnesota Department of Agriculture,
2022). This voter-approved funding source has created ample opportunities for
collaborative and innovative approaches towards clean water in Minnesota. We heard
from several stakeholders that the visible nature of this taxpayer supported fund creates
some additional pressure to communicate the impact of the investments, especially as it
gets closer to time to vote on the amendment again in 2034.
Forever Green Initiative (FGI) is run by University of Minnesota’s College of Food,
Agricultural and Natural Resource Sciences research platform within the Department of
Agronomy and Plant Genetics. FGI is working to develop and improve perennial crops
and winter-hardy cover crops for Minnesota’s climate, that allow soil and water health to
be protected through all seasons, while simultaneously creating new economic
opportunities (Forever Green Initiative | Forever Green, n.d.). Several stakeholders
discussed cover crops as integral to their programs or as best practices on their farms
and pointed to FGI as an important effort.
Healthy Soils Bill passed the Minnesota Legislature in March of 2022 establishing
goals to improve soil health, appropriating money to support improved agricultural
practices for soil health and creating a soil health action plan.
Minnesota Department of Agriculture (MDA) administers the Minnesota Agriculture
Water Quality Certification Program (MAWQCP), a voluntary certification program for
farmers to lead the way in adopting conservation practices on their farm to protect water
quality. MAWQCP producers receive regulatory certainty to be deemed in compliance
with any new water quality regulations for ten years after certification. MDA works
closely with SWCDs to implement the program throughout the state (Minnesota
Department of Agriculture, n.d.).
Minnesota Pollution Control Agency (MPCA) is responsible for permitting point
source pollution and has been the primary agency working on water quality trading
between point source and nonpoint source actors (Minnesota Pollution Control Agency,
2017b).
One Watershed, One Plan is a Minnesota statute passed in 2015, requiring a
coordinated and comprehensive management plan for each watershed. BWSR
oversees One Watershed, One Plan, and offers grants each year to support planning
efforts (Minnesota Board of Water and Soil Resources, 2022).
Soil and Water Conservation Districts exist throughout the country, often operating at
the county-level in support of healthy soil, clean water, and natural resource

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conservation. SWCDs were founded in the 1930s and 40s in response to the Dust Bowl
and exist today under a variety of names and structures (National Association of
Conservation Districts, 2023).
Tribal nations are important to consider when discussing water quality in Minnesota.
There are eleven federally recognized tribes in Minnesota, each with sovereign tribal
governments that are responsible for the water quality on tribal land. This research does
not include discussion of water quality programs or policies on tribal land due to IRB
restrictions.
Additionally, it is important to note that there are many nonprofit organizations working
on these issues as well. There are state affiliates of national organizations working on
the local level in Minnesota or in the region, as well as local organizations.

Minnesota Agriculture Water Quality Certification Program
The Minnesota Department of Agriculture took a leadership role in developing and
implementing a voluntary water quality certification program that incentivizes farmers
and agricultural landowners to implement conservation practices to protect water
quality. The program began with a Memorandum of Understanding between
Minnesota’s previous Governor, Mark Dayton, USDA Secretary, Tom Vilsack, and then
EPA Administrator, Lisa Jackson, during the Obama Administration. The MOU directed
the state of Minnesota to tackle ongoing agricultural water quality issues in a new way,
using the tool of regulatory certainty as an incentive for farmers to adopt water quality
BMPs and adjust management practices to reduce water quality impairments.
Regulatory certainty is a relatively new model that uses the certification process to give
farmers and ranchers who voluntarily adopt approved practices a guarantee that their
operation will be deemed in compliance with
any new water quality regulations that come
Regulatory certainty is a
down during the ten years following
relatively new model that uses
certification.
the certification process to give
Brad Jordahl Redlin joined MDA in 2012 to
design and launch the program, and he
remains the program manager of MAWQCP
to this day. From the beginning, stakeholder
stakeholder engagement was an important
part of the MOU. MDA formed an advisory
committee as part of the program to ensure
the voices of farmers were at the table as

farmers and ranchers who
voluntarily adopt approved
practices a guarantee that their
operation will be deemed in
compliance with any new water
quality regulations that come
down during the ten years
following certification.

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the program was developed. In June of 2014, MDA issued their first certification and in
June of 2022, 1,234 producers had been certified representing 890,581 acres enrolled
in the certification program (Jordahl Redlin, 2022). While this is a large number of
producers and acres, it still only represents about 3.5 percent of agricultural acres in the
state.
The MAWCQP is primarily funded through the Clean Water Fund with an annual
appropriation of three million dollars. This funds five full-time staff at MDA to operate the
program, as well as pass through dollars to SWCD regions. Each region covers 10-12
counties and has funds to hire at least one full-time employee to implement MAWQCP
on the ground in their area. Certifiers are trained and housed within SWCDs and are
key to working directly with farmers to complete a risk assessment using specialized
software to identify land and operations management changes to most significantly
reduce the impact of the farm on water quality. The assessment software and process is
designed to work for all types of agricultural production, from small specialty crop
farmers to large commodity crops to livestock operations. Once a farmer or landowner
completes the changes, they can become certified under the program. The program
also offers an internal grant of up to $5,000 with a quick application and turnaround to
help farmers with the initial cost of new practices to complete their certification process.
MAWCQP uses models to estimate the impact of the BMPs used on certified farmland,
and as of June 24, 2022, Brad Jordahl Redlin shared the following numbers. 2,474 new
practices adopted to obtain certification, resulting in:
•
•
•
•
•

42,974 tons of sediment prevented per year
124,621 tons of soil loss prevented per year
54,061 lbs of Phosphorus loss prevented per year
Up to 49% reduction in Nitrogen loss per year
47,947 (COMET C02-e metric tons per year)

According to surveys of certified farmers, regulatory certainty ranks third in their
motivations to participate in the MAWQCP, behind “Demonstrate to others my water
ethic” and “Review of my farm management practices.” The vast majority of producers
hear about the program from their local Soil & Water Conservation District or NRCS
staff (71 percent), followed by a referral from neighbors, family, or friends (16 percent),
and media (14 percent). (MAWQCP 1,000 Certified Producers Survey, 2021).
Additionally, a study by Minnesota State Agricultural Centers of Excellence shows that
MAWQCP certified farms show a 6 percent higher profitability than farms that are not
certified under the program. This marks the third year in a row that the study found
improved financial outcomes from the practices implemented through this program

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(Annual Study Again Confirms Higher Profits for Ag Water Quality Certified Farms,
2022).
An additional component of the certification process is for farmers to add endorsements
or additional certification levels based on the impact of specific practices they
implement. As of June 2022, the following endorsements had been added to certified
farms:
• 69 Soil Health Endorsements
• 56 Integrated Pest Management Endorsements
• 40 Wildlife Endorsements
• 42 Climate Smart Endorsements (recently secured new with grant funding from
McKnight Foundation to include a $1,000 grant for 5 consecutive years to
support implementing conservation practices and technical assistance to identify
best practices for carbon markets in the future under this endorsement)
• 4 Irrigation Endorsements
The endorsements model acts to further give credit and incentive to farmers and
landowners who go above the minimum criteria for water quality certification.
Research indicates that this program would be replicable in other states and that the
risk assessment framework could be applied to different types of agricultural water
issues - water quality, quantity, or other management challenges. The software that has
been developed for this program is a critical component and could be adapted to meet
the needs of another state. Another important component to replicating this program is
the boots on the ground partnerships with trusted relationships in the agricultural field.
In Minnesota, the SWCDs fill this role, but this partnership might look different in other
states. Additionally, the MAWQCP includes federal, state and local partnerships
collaborating to make the program possible, including: Clean Water Land & Legacy
Amendment, Minnesota Board of Water and Soil Resource, Minnesota Department of
Natural Resources, Minnesota Pollution Control Agency, and the USDA Natural
Resources Conservation Service (Minnesota Department of Agriculture, 2022). The final
component for replicability is a sufficient and reliable funding source. In Minnesota this
comes through the statewide sales tax in the Clean Water, Land & Legacy Amendment,
but other states have used federal funds or leveraged private partnerships to address
agricultural water quality.
Minnesota water quality trading program
Trading is a permitting exercise, so demand for purchasing credits must be driven by
growth. For example, an entity may need to offset part of its pollutant load due to
expansion or new regulations on a pollutant. In some cases, it may be more cost

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effective for the entity to pay a farm to implement practices to reduce their pollution to
offset continued pollution from the facility, essentially trading water quality credits within
the same watershed to lower overall pollution-control costs.
The Minnesota Pollution Control Agency (MPCA) has led efforts in the state to create
pilot programs and systems for water quality trading. Most notably, in 2021 the MPCA
worked with MDA and BWSR on a water quality trading pilot project in the North Fork
Crow River Watershed (Minnesota Department of Agriculture, Minnesota Pollution
Control Agency, and Minnesota Board of Soil and Water Resources, 2021). The group
of collaborators released an informative report and recommendations following
stakeholder meetings, which includes the need for more clarity on key logistical aspects
of water quality trading, more examples of collaborative partnerships coming together
and what role each entity plays in the effort, and dedicated resources of staff and tools
to manage this and future water quality trading projects (Minnesota Department of
Agriculture, 2021). Water quality trading is a flexible tool, so the first step to initiating a
trade in Minnesota is to contact the MPCA to discuss the details and possibilities of a
trade (Minnesota Pollution Control Agency, 2017a).

Colorado
Every river in Colorado originates within the state. The water is clean coming from the
melted snowpack in the mountains, flowing through the major metropolitan areas before
reaching rural areas which are impacted by water quality issues. Like other states in the
region, 319 funding from EPA has been channeled toward mitigation from mining
activities for the past 30 years or so. But in the last 15 years, more funding has gone
toward mitigation from agricultural activities with increasing interest in irrigation
management practices which saves fertilizer, pesticides, and water. For better or worse,
the regional drought has necessitated some of these and other conservation practices,
which ultimately impact water quality. Producers who can afford to convert their
irrigation methods are doing so now.
The Agricultural Chemical and Groundwater Protection Act was passed in 1990 to
create the Groundwater Protection Program. “The goal is to prevent groundwater
contamination before it occurs by improving agricultural chemical management” (CDA,
2013). The plan includes three primary functions: regulation, groundwater monitoring,
and education and training. The Colorado Department of Agriculture leads the program
in collaboration with the Colorado Department of Public Health and Environment
(CDPHE) and Colorado State Extension. In addition, CDPHE houses the Colorado
Water Quality Control Commission and the Water Quality Control Division which protect
ground and surface waters of the state. Regulation 85 was passed in 2012 to support

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voluntary actions from farmers and ranchers to control nutrients such as nitrogen and
phosphorus, ahead of potential regulation in 2022. With the help of extension, Colorado
has spent a lot of effort to engage agricultural producers and ranchers around water
quality initiatives in the state.
Colorado is currently in an open public comment period to update the Colorado Water
Plan for 2023. It is created and managed by the Colorado Water Conservation Board
(CWCB) located within the Department of Natural Resources. CWCB funds the program
and provides technical assistance for its implementation. This plan builds off the original
2015 framework and is “a grassroots effort, and relies on the Colorado water community
to identify and implement basin-specific and/or statewide water projects that provide
multiple benefits to the state’s diverse water users.” (CWCB, 2023) The plan
encourages collaboration among stakeholders including 100 specific examples of
actions for citizen partners and state agencies, as well as four major action areas
including vibrant communities, thriving watersheds, robust agriculture, and resilient
planning. It also includes five water plan grant categories that complement existing
water quality funding opportunities: conservation and land use, water storage and
supply, engagement and innovation, agriculture, watershed health and recreation.
In addition to the state plan, there are eight Basin Implementation Plans (BIPs), tailored
for every major river basin in the state: Arkansas, Colorado, North Platte, Rio Grande,
Gunnison, Yamp-White-Green, South Platte, and Southwest. These plans were
developed in collaboration with a wide range of citizen stakeholders via “basin
roundtables” first established in 2005 by the Colorado Water for the 21st Century Act,
and reconvened in 2015 to create updated BIPs for 2022.

Kansas
Kansas is an interesting case study because it is divided between humid and arid
regions. The Eastern part of the state is humid and primarily cropland, whereas the
Western side of the state is arid and more ranchland, which gives rise to very different
water challenges throughout the state. In response to severe flooding followed by years
of drought, in 1955, Kansas established the Kansas Water Resources Board (KWRB) to
address water issues in the state. Their work led to the State Water Plan Act of 1963
which gave statutory authority and guidance for the KWRB to cooperate with other state
agencies to create the Kansas Water Plan. In 1989, the State Water Plan Fund was
created to fund programs and practices recommended in the State Water Plan (Kansas
Water Office). In 2021, nearly 19 million dollars was appropriated to the Kansas
Department of Agriculture (KDA), Kansas Water Office (KWO), and Kansas Department
of Health and Environment (KDHE) from the Kansas State Water Plan Fund. Each

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agency plays a distinct role in addressing water issues, and it is evident that the Kansas
Water Plan and designated funding creates opportunity for agency collaboration,
innovation, and opportunities to leverage additional funding (Kansas State Water Fund
Appropriations).
The Kansas Department of Agriculture is home to the Division of Water Resources,
which administers 30 laws and responsibilities including the Kansas Water
Appropriation Act; regulates the construction of dams, levees and other changes to
streams; oversees four interstate river compacts; and coordinates the national flood
insurance program. One tool that KDA uses is the designation of a Local Enhanced
Management Area (LEMAs) within a Groundwater Management District (GMDs).
LEMAs are approved by the chief engineer at KDA to give GMDs the authority to set
specific goals and measures to improve water conservation. Another tool at KDA is
Water Conservation Areas (WCAs), which create a framework for individual or groups of
water right owners to develop plans to reduce water withdrawals, with the aim of
extending the life of the Ogallala-High Plains Aquifer. Both of these tools give
agricultural producers and landowners a flexible structure to conserve water use over a
five-year timeframe without losing their water rights.
The Kansas Department of Health and Environment oversees the Kansas Watershed
Restoration Protection Strategy (WRAPS), which offers a comprehensive framework for
citizens, farmers, and landowners to engage with watershed management. The WRAPS
process involves key stakeholders working together to identify key restoration needs
within the watershed, setting goals for protection and restoration, creating an action plan
to achieve the goals, and implementing the plans. This program is funded through EPA
Section 319 funding and the Kansas Water Plan Fund. Each project is implemented in
partnership with a facilitating organization on the ground in the community - some are
nonprofit organizations, some are Extension, others are conservation districts - because
the state agencies recognize that trusted relationships in agricultural communities are a
key to effecting change among farmers and ranchers, who are the largest users of
water and contributors to water quality issues. Today, there are 36 WRAPS projects that
have completed at least three steps of the process. WRAPS’ citizen-led approach
creates a sense of ownership over the plans. The plans often take a holistic look at farm
management, for instance a plan may start with one practice such as educating and
incentivizing farmers to use cover crops on their field, but that one change makes an
impact on many aspects of the farm ecosystem and economic resilience.
Finally, the Kansas Water Office (KWO) oversees the Kansas Water Plan and is
primarily responsible for water planning, policy, coordination, and marketing. Founded in
1981, KWO is directed by Kansas Statute 74-2608 to collect data and information about

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climate, water, and soil; develop a state plan to
manage water resources; develop guidelines for
water conservation plans and practices; and
establish guidelines for drought conditions. It
appears that the KWO is dedicated to strong
partnerships throughout the state, hosting
regular meetings with 14 Regional Advisory
Committees and listing 60 organizations and
agencies on the “Our Partners” page of their
website. The level of opportunity for citizen engagement is encouraging. In addition to
the Kansas Water Plan that gets updated every five years, in 2013 Governor
Brownback called for the development of a 50-Year Vision for the Future of Water in
Kansas, stating, “Water and the Kansas economy are directly linked. Water is a finite
resource and without further planning and action we will no longer be able to meet our
state’s current needs, let alone growth” (Water Vision, Kansas Water Office). The Water
Vision Team, composed of representatives from KWO, KDA, and KWA, worked
together to engage stakeholders throughout the state and create a comprehensive and
regionally-specific vision and plan. This lofty goal to create a 50-year vision and the
coordinated effort to achieve it is an important step in the process towards creating a
more sustainable water future.

Tensions are high between
agricultural practitioners
who hold water rights and
don’t want to lose them,
and those who are thinking
about the future of the
region’s water supply.

The Natural Resource Conservation Service and Soil and Water Conservation Districts
are key partners for on the ground implementation of best practices and coordinate
closely with state agencies to leverage technical expertise and funding from different
sources. The NRCS and state agencies shared similar messages in interviews,
including that addressing water quality and quantity challenges is directly linked to
holistic management for soil health.
While efforts around managing water are well coordinated in Kansas, the Western part
of the state still faces serious challenges with the rapid depletion of the Ogallala Aquifer.
Tensions are high between agricultural practitioners who hold water rights and don’t
want to lose them, and those who are thinking about the future of the region’s water
supply. In an article published in Kansas Reflector in May of 2022, Representative Ron
Highland reported from a visit to Garden City, KS, saying, “Several of the farmers that
irrigate said, ‘I’m going to pump it dry, and then move away.’ But … the other side of the
coin is those that want to keep something for their grandchildren and great
grandchildren” (Kite et al., 2022). In the face of scarcity, this division and resistance to
adopting new agricultural practices is similar to Arizona’s culture around water.

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Michigan
Michigan’s Agricultural Environmental Assurance Program (MAEAP) is a voluntary
certification program run through the Michigan Department of Agriculture and Rural
Department (MDARD). MEAEP was established in 1998, “by a coalition of agricultural,
environmental and conservation groups to assist farmers in taking a voluntary, proactive
approach to reducing agricultural pollution while keeping their business operations
sustainable (MAEAP 2022).” MAEAP was codified into Michigan law by legislation in
March of 2011. It receives a combination of state and federal funds. MAEAP originally
established three different types of verification programs, for Livestock, Farmstead, and
Cropping enterprises, and later added a fourth recognition for Forest, Wetlands &
Habitat.
MAEAP verification requires three main components. First, farmers are required to
attend a MAEAP educational session. Then, farm operations are evaluated through an
on-farm risk assessment, wherein a local technician tours the farm and assesses needs
to address the farm’s specific environmental impacts, with the recognition that each
farm system is unique. After the recommendations from the risk assessment have been
implemented, there is a third-party verification into the program, which lasts for five
years until a farm must be reverified. The program is free for farmers to participate, and
MAEAP verification can lead to access to grants and additional funding opportunities.
(MAEAP, 2022)
MAEAP addresses several environmental components, besides water resource use
(quantity and quality). It also includes pesticide and fertilizer use, fuel storage, well
safety, soil erosion control, and general compliance with environmental laws. While the
state of Michigan touts the success of the MAEAP program in several aspects, including
reducing phosphorus and nitrate runoff into drinking water, one academic research
study disagreed. Stuart, Benveniste, & Harris interviewed Michigan corn farmers
regarding their participation in MAEAP and reduction of nutrient runoff. They found that
most farmers opted to participate to avoid additional regulation and enforcement, and
made few environmental changes. Their study showed little benefit both to Michigan’s
environmental standards and to the farmers who participated in the program. They
cautioned that:
While proponents of neoliberal approaches claim that MAEAP represents a more
cost-effective program that enhances flexibility in achieving environmental goals,
replacing government conservation programs with such programs would
represent a significant step backwards. Despite pressure to identify low-cost
approaches to environmental governance, those involved in efforts to address
farm pollution from cropping systems should be aware of the limitations of

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environmental assurance programs like MAEAP. A combination of policy tools,
including government incentive programs and regulation, is more likely to result
in positive environmental outcomes. (Stuart et al., 2014).
In this study, they found that more regulatory tools were needed, over a simple
environmental certification program.
According to one expert interviewed, MAEAP has been successful in recruiting farmers
both due to the social recognition aspect and the grants available. Some farmers see
the MAEAP certification as a way to show their neighbors that they’re taking care of
their land and water resources and doing things the right way. This is especially
apparent in Southeast Michigan, where high phosphorus loads into Lake Erie have
caused high-profile destructive algal blooms. MAEAP has focused on reaching farmers
in this Western Lake Erie Priority Area (MAEAP, 2014), with some success. According
to a respondent, while the MAEAP standards aren’t written explicitly for phosphorus
runoff as it would be cost-prohibitive to monitor, the focus has been on reducing
tolerable soil loss, according to a model. This approach really focuses on overall soil
health as being a predictor of runoff, as the respondent said that “good soil health
solves 95% of our problems” including nutrient runoff, erosion, groundwater infiltration,
and better rates of aquifer recharge. The MAEAP program remains a model of a
statewide environmental certification that has had some successes, particularly
compared to the smaller amount of funding.

Missouri
Missouri faces similar water quality challenges to other Midwestern states, where
nutrient runoff and soil erosion top the list of water-related challenges in the state. In
fact, in the 1980s, Missouri faced some of the worst soil erosion in the country, and the
legislature decided to take action. In 1982, Rep. Jerry Burch introduced a bill to divert
half of the 1/8 cent sales tax funds for conservation to support soil erosion. After failed
attempts to pass this in the Legislature, a Citizens Committee for Soil, Water and State
Parks formed to work on passing a new one-tenth-of-one percent sales tax to address
soil erosion, water quality, and protect state parks. By bringing together farmers, parks
supporters, conservation groups, and concerned citizens, the coalition was able to pass
the statewide sales tax as a Constitutional amendment on the ballot in 1984. The tax
must be reapproved by voters every ten years, which it has been with overwhelming
support for the last 38 years (Missouri Department of Natural Resources, n.d.).
The Parks, Water, and Soil tax is administered by Missouri’s Department of Natural
Resources, which oversees the Missouri Soil and Water Conservation Program with
guidance from the Soil and Water Districts Commission. The Soil and Water

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Conservation Program provides administrative support and oversight of Missouri’s local
Soil and Water Conservation Districts in each county throughout the state. The program
primarily uses funds from the sales tax to offer cost-share funding to Missouri farmers to
voluntarily implement conservation practices. The Soil and Water Conservation CostShare Practices includes 55 different practices and addresses seven resource
concerns: Sheet, Rill and Gully Erosion; Grazing Management; Irrigation Management;
Animal Waste Management; Nutrient Pest Management; Sensitive Areas; and
Woodland Erosion. The most popular practices include adding terraces to sloped land
and using cover crops (Soil and Water Conservation Cost-Share Practices | Missouri
Department of Natural Resources, n.d.).
Each year the cost-share program matches about $40 million in conservation practices
at 75 percent of the standard cost for the area, using a reimbursement model. Soil and
Water Conservation District staff are responsible for implementing the cost-share
program in each county of the state. Most cost-share practices are only eligible to pay to
the landowner, although the use of cover crops, improved pest management, and
strategic nutrient management may be implemented and reimbursed to the lessee of
cropland.
Missouri clearly has strong public support for soil and water conservation practices and
has invested heavily in creating a model to implement conservation practices in support
of soil health and water quality on agricultural land. As with most states, Missouri uses
modeling to estimate the impact of this investment on the environment and community.
Missouri’s measurements focus on soil savings, estimating the soil saved over five to
ten years depending on the practice, because that was the motivating force behind the
sales tax. It is estimated that more than 177 million tons of soil have been saved since
the start of the sales tax (Casper, 2016).
It is notable that there are many shared characteristics between Missouri’s soil
conservation and water quality efforts and the Minnesota Agricultural Water Quality
Certification Program. It seems that Missouri farmers and ranchers could benefit from a
certification program to earn more public recognition for the soil and water health
practices they implement, and it wouldn’t be a significant stretch to create from the costshare program that is already in place.

Nebraska
Nebraska has some of the best water resources in the nation and the world.
Groundwater (located beneath the state’s surface in porous regions known as aquifers)
could cover the state with nearly 40 feet of water if it were all pumped to the surface.

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Because groundwater is so plentiful and reliable, 85% of the state’s population uses
groundwater as drinking water.
The Nebraska Department of Environment and Energy (NDEE) develops water quality
standards that designate the beneficial uses to be made of surface waters and the
water quality criteria to protect the assigned uses. Title 117 - Nebraska Surface Water
Quality Standards form the basis of water quality protection for all surface water quality
programs conducted by the department. These standards were revised and approved in
2012. In addition to developing the standards, the Planning Unit develops and
implements procedures for applying the standards to surface water quality programs.
Many challenges face Nebraskans when trying to protect this valuable resource. Like
many states, runoff from rain and irrigation can carry chemicals and topsoil into streams
in both urban and rural areas, causing surface water contamination. More than 50 years
of crop production has allowed fertilizers and ag chemicals to reach groundwater in
parts of the state, causing contamination.
The following programs are addressed in the Water Quality Division:
Groundwater: The Groundwater programs include the Groundwater Management area
Program, Underground Injection Control, Mineral Exploration and Wellhead Protection.
The program also issues an annual report to the Legislature concerning groundwater
quality in Nebraska and is responsible for hydrogeologic review of various Department
programs.
Petroleum Remediation: The Petroleum Remediation Program involves two interrelated program areas: overseeing the investigation and cleanup of petroleum
contamination resulting from leaking above-ground and underground storage tanks; and
administering financial assistance for persons responsible for investigation and cleanup
costs due to petroleum releases from tanks.
Surface Water: The Surface Water Monitoring and Assessment programs collect
physical, chemical, and biological water quality samples from streams and lakes,
implement surface water improvement projects, and prepare surface water quality
reports.
Planning: The Water Quality Planning Unit is involved with multiple programs,
including:
• Impaired Waters and Total Maximum Daily Loads
• Nonpoint Source Management Program

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•
•
•

Nonpoint Source Water Quality Grants
Section 401 Certification
Source Water Protection Grants

The following are programs in the Water Permits Division:
Agriculture: The Agriculture Section’s programs consist of the Livestock Waste Control
Program, the Chemigation Program and the Agricultural Chemical Containment
Program.
State Revolving Fund (SRF) Section: NDEE, in coordination with the Nebraska
Department of Health and Human Services Division of Public Health, distributes funds
from two major revolving loan fund programs. These two programs – the Clean Water
State Revolving Loan Fund (for wastewater treatment facilities) and the Drinking Water
State Revolving Loan Fund. (Nebraska Department of Environment and Energy, 2019)
Wastewater: The Wastewater Section administers the construction permit program for
new and modified wastewater treatment facilities and collection systems built in the
state.
Permitting: All persons discharging or proposing to discharge pollutants from a point
source into any waters of the state are required to apply for and have a permit under the
National Pollutant Discharge Elimination System (NPDES) to discharge including all
significant industrial users discharging to a publicly owned treatment works. (Nebraska
Department of Environment and Energy, n.d.)

New Mexico
The New Mexico Water Quality Act of 1967 gives authority to the state’s Water Quality
Control Commission (WQCC), whose charge is to adopt standards for the state and
direct programs that align with the Clean Water Act. It consists of diverse stakeholders
across state government including the Environment Department, Department of Game
and Fish, Office of the State Engineer, State Parks Division, Department of Agriculture,
Soil and Water Conservation, Health Department, as well as local government agents
and citizens, appointed by the governor (Utton Transboundary Resources Center,
2015). The programs are enacted through the New Mexico Environment Department,
broken into several subdivisions responsible for varying water quality issues: drinking
water, surface water, ground water. In addition to the role of the state government,
tribes may have differing standards in New Mexico since they are treated as sovereign
nations and operate their own water quality programs when and where they have

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capacity to do so. Each agency is responsible for having a tribal communications policy
to ensure as effective communication as possible with tribal liaisons as water quality
and monitoring issues arise that impact sovereign nations.
The New Mexico Surface Water Quality Bureau alone has individual staff positions to do
monitoring and assessment against the water quality standards, implement water
regulations and permits for point source pollution, and oversee watershed improvement
projects (New Mexico Environment Department, 2022). New Mexico is one of two states
whose surface water discharge permits go through EPA in the neighboring state of
Texas. This is especially applicable for their state dairies along the Rio Grande, which is
impaired with E. coli. Their programming is federally funded through 319, and does not
have additional state funding to support the work. One of the biggest challenges they
face is resource shortage as the fifth largest state, many remote areas to monitor, and
not enough staff capacity. Despite this, they are regularly praised for their public
outreach and engagement, and the robustness of their program given these constraints.
New Mexico’s water quality standards for surface water include a section on
“Outstanding National Resource Waters” where anyone can nominate a state surface
water for designation. The agencies also utilize a public newsletter to communicate
about RFAs and project progress across their programming.

Vermont
The state of Vermont has a wet climate with high levels of precipitation - both rain and
snow - and fresh water. Vermont’s agricultural water quality initiatives have
predominantly focused on nutrient runoff, particularly phosphorus and nitrates, into the
major waters of Lake Champlain, Lake Memphremagog, and the Connecticut River.
(Dickerson & Richter, 2021)

Vermont Clean Water Fund
In 2015, the Vermont legislature passed the Clean Water Act, which created a Clean
Water Board and the Clean Water Fund (CWF). The Clean Water Fund, together with
substantial federal monies, make up most of the funding for state programs. The Clean
Water Fund was initially funded through a 0.2% tax as part of the Vermont Property
Transfer Tax on property sales. In 2020, additional tax sources were allocated to the
CWF in the form of 6% of the Meals and Rooms Tax revenue, as well as unclaimed
beverage container deposits (when cans aren’t returned for the deposit). In 2021, the
Clean Water Fund had a total of $22 million. Federal funds for clean water initiatives
(through USDA, EPA and Federal Highway Administration) totaled around $61 million in

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2021. In addition, nearly $225 million in federal American
Recovery Plan Act funding will go toward clean water over a
three-year period. (Dickerson & Richter, 2021).

Agricultural Clean Water Initiative Program
(AgCWIP)

Nearly $225 million
in federal American
Recovery Plan Act
funding will go
toward clean water
over a three-year
period.

One way that Vermont state funds for clean water are
distributed to help with agricultural non-point source pollution is through the Agriculture
Clean Water Initiative Program (AgCWIP). Individuals and organizations can submit
proposals that help both “regulatory compliance and agricultural non-point source
pollution reduction” and “economic and environmental viability on Vermont farms”.
Areas of focus include organizational capacity development, education & outreach,
technical assistance, and conservation practice surveys. In 2022, there was a total of $3
million available in grant funding (Vermont Agency of Agriculture, 2021).

Required Agricultural Practices (RAPs)
Also in 2015, the Vermont legislature passed the Required Agricultural Practices Rule
for the Agricultural Nonpoint Source Pollution Control Program. This ruling classifies all
farms with over $2,000 of income or over 4 acres into one of four categories: Small
Farming Operation, Certified Small Farm Operation, Medium Farm Operation, and
Large Farm Operation. All farms must be certified annually, and the size of the farm
indicates the level of regulation. Aspects of the RAP include required water quality
training, nutrient management planning, discharges, soil health, manure and nutrient
storage, manure and nutrient application, buffers, mortalities, livestock exclusions,
ground water, and farm structures. Financial and technical assistance is available to
help farms comply with the RAPs. (Vermont Agency of Agriculture, 2016).

Vermont Environmental Stewardship Program (VESP)
The Vermont Environmental Stewardship Program (VESP) was a pilot program aimed at
encouraging a variety of environmentally sound practices amongst different farms.
According to one expert we interviewed, the VESP program was conceptualized in 2013
to provide a holistic farm assessment. One motivating factor was that farmer working
groups said they wanted a program like this, to provide a farm assessment and social
recognition for good environmental practices. Goals included water quality improvements,
as well as issues of soil erosion, soil organic matter, air quality, nitrogen loss to air, habitat
health, terrestrial and aquatic species protection, and carbon sequestration. An NRCS

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model for assessing farms was tested to fit Vermont farms and practices. According to
the interviewed expert, there were no financial incentives, but interest in the program was
still very strong amongst farmers. A dozen farms participated in the pilot program. The
program was put on hold and not continued after the initial pilot.

Payment for Ecosystem Services and Soil Health Working Group
In 2019, the Vermont legislature passed an act directing the Agency of Agriculture,
Food and Markets to create the Payment for Ecosystem Services and Soil Health
Working Group. The group meets twice a month in a public forum (or virtually). The
group’s purpose is to “implement agricultural practices that improve soil health, enhance
crop resilience, increase carbon storage and stormwater storage capacity, and reduce
agricultural runoff to waters” (Vermont State Legislature, 2019). They look to find ways
to create financial incentives and financial compensation programs so that both farmers
and the environment can benefit. The Vermont Pay for Phosphorus Program is related
to discussions from this working group.

Vermont Pay for Phosphorus Program (VPFP)
One major concern has been that Vermont’s Lake Champlain’s phosphorus TMDL was
disapproved in 2011, leading to several initiatives focused on Lake Champlain
(Dickerson & Richter, 2021). Vermont has historically had a problem with phosphorus
runoff, particularly from dairy farms into Lake Champlain, which is surrounded by fertile
agricultural land. This has led to toxic algae blooms in Lake Champlain, and widespread
water quality issues throughout the region. In 2021, Vermont introduced a new program,
the Vermont Pay for Phosphorus Program (VPFP) to address the issue. The program is
funded by a $7 million grant from the USDA Natural Resources Conservation Service
through the Regional Conservation Partnership Program Alternative Funding
Arrangement. The program enrolls farmers that meet the state’s required Nutrient
Management Plan, and farmers are eligible for $15 per acre enrolled in the program, up
to a total of $4,000 per farm. Then, the VPFP measures the farm’s base phosphorus
load and provides technical assistance for field management practices that can lower
phosphorus levels. Upon verifying the data on the farm’s phosphorus reductions,
farmers are paid $100 per pound of eligible phosphorus reductions per year, up to
$50,000. The program aims to provide enough financial incentive to induce farmers to
participate. Because the program is in its infancy, there are no reports yet on the
success of the program in reducing Vermont phosphorus runoffs. (Vermont Agency of
Agriculture, 2022)

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Discussion and Recommendations
Coded Responses from Interviews
Table 4 below summarizes the population of the interviewees. Each person interviewed
fell into one or two of the listed working categories (government, non-profit, academia,
farmer or a private business), thus the total people is less than the sum of the
categories of actors. These are totaled per state and per working group. Most
responses were from governmental employees and came from Arizona or Minnesota.
Table 4: Coded Responses from Interviews
State

Government Non-Profit

Academia Farmer

Private
Business

Total

Arizona

7

3

2

16

3

Colorado

1

1

1

Kansas

2

2

Michigan

1

2

Minnesota

9

3

Missouri

1

1

New Mexico

3

3

Pennsylvania

3
2

12

1

Utah

1

Vermont

3

Total

27

1

2

1

2
3

10

5

3

3

44

When respondents were asked about the main problems with current water quality
programs, most relayed that funding was an issue and most of these programs were
state initiatives. Interviewees were asked about changes they may make to current
water quality programs. One suggestion that came up many times was the lack of
funding sources. There are several federal initiatives, like the CWA 319 funds, that can
cover some costs depending on what is implemented, but there is not enough funding to

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For a water quality program to be
successful, the farmers’ needs
must be met and maintained. This
could be in the form of a single
program for water quality, in order
to reduce paperwork, or more
funding opportunities to reward
implementation of water quality
enhancing practices.

follow up after these practices are
implemented or outreach for the
program does not exist. For example,
there is no funding for promotion staff
within AZDA. In addition, lack of staffing
can create delays in labs and testing in
the field. Most funding for these water
quality programs comes from federal
CWA funds, which can limit the amount
and type of work done.

In almost all the interviews, respondents had changes they wanted to make to current
programs. Some water quality programs have motivated farmers to have discussions
about soil health and water quality; in Arizona, most do not concern themselves with
water quality, but rather with water quantity. Soil health factors can contribute to poor
water quality and improving the soil can be a step forward to improve water quality, as
well as quantity. A significant number of responses had to do with nutrient impairment
programs, like preventing nitrogen and phosphorus runoff from creating eutrophic
waters. These respondents tended to be from midwestern states, especially those in
Minnesota. Arizona respondents tended to speak more about salinity than nutrient
impairment in waters and soil.
One issue that came up many times was efficiency with time and money, while also
being equitable to farmers. This is a complicated issue that needs to be addressed
through state programs. For a water quality program to be successful, the farmers’
needs must be met and maintained. This could be in the form of a single program for
water quality, in order to reduce paperwork, or more funding opportunities to reward
implementation of water quality enhancing practices.
Local solutions are key to understanding issues present in each area within Arizona,
especially considering cultural and hydrologic differences across the state. It was
mentioned by several people that programs could be more successful if driven by a
single issue, like sediment or salinity, but not by addressing both in the same program.
Minnesota’s program uses a risk assessment that differs per field, allowing for this
localized approach, which could be useful in Arizona.
Difficulty in measuring outcomes is a major hurdle for water quality programs. The
programs discussed with interviewees showed modeling is the most dominant way to
advise policy forward on quality issues. In Arizona, barely any monitoring or testing is
done, but there is software used to evaluate impaired waters. Overall, there is a need

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for more communication with the public, educating not only on water quality issues, but
also how government policies are created and implemented.
Discussions about key stakeholders also came up in interviews. Most responded with
universities, agricultural departments in the state, and nonprofits. Some mentioned the
need for farmers’ presence in these conversations. There is a lack of communication
across government agencies, especially in Arizona. Many interviewees confirmed this
and suggested this change in order to combat water quality issues better.
Questions about best practices for desert agriculture were asked to those relating to this
work. Several practices are currently used by Arizona farmers that result in better soil
health and, in turn, hopefully cleaner water. Flood irrigation is the dominant type of
irrigation used in Arizona, specifically in Yuma. This is done to alleviate salts found in
the top layer of the soil, by forcing them lower into the ground. Since Yuma laser cuts
fields for a flatter landscape, this is more efficient than flood irrigation in other areas by
allowing an even distribution of water across the entire field. In addition, farmers have a
focus on soil health, to improve moisture in the soil and therefore yields. Due to the
continued water shortage, universities and research labs will be forced to consider
better technology for agriculture. In addition, it is important to consider Yuma farms
differently than central Arizona. In Yuma, specialty crops are grown that are sold for a
significant amount of money (especially compared to cotton or dairy). This allows
farmers to experiment more with different technologies that may be expensive. For
example, farmers in Yuma often use furrow packing wheeled tractors to increase
efficiency of water to crops on the field, as water cannot readily infiltrate within the
furrow from soil compaction. In addition, since agriculture has been so successful and
productive in Yuma, it is unlikely agriculture will cease to exist with water shortages.
Yuma has available labor, water and a frost-free growing season.
When speaking about equity in water quality programs, funding was a common theme
that came up. Almost all interviewees admitted that equity is not really accounted for in
these programs, although some conversations among government employees have
come up. It is important to understand what the issue is and who it is impacting the
most. Overall, more needs to be done to include unheard voices in these conversations,
especially with the dramatic impact climate change is having on these communities.
More access to funding and outreach could improve the equity conversation in Arizona.
In research interviews, respondents’ suggestions for improving state water quality were
categorized into three main topics: improve, reinvent, and end. Improvements included
recommendations for changing specific farming practices, policies, regulations, and
programs to improve agricultural water quality. Improvements will be discussed below in

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the framework of a proposed voluntary water quality initiative as the best option.
Respondents’ calls to reinvent and innovate new farming practices called into question
the current agricultural system and seek to change the landscape of Arizona farming as
we know it. Finally, some respondents called for the need to end specific agricultural
practices or crops in areas of Arizona, as being entirely unsustainable. Each of these
three categories of recommendations is discussed below.

Improve Agricultural Water Quality
Several specific recommendations are provided below for improving agricultural water
quality within the existing agricultural system. In particular, a program must be
developed with public engagement within the relevant cultural context. Government
agency involvement must be coordinated to expand existing capacities and funding
mechanisms. A program must take into account tribal representation and interagency
coordination. Practices must be encouraged that build overall soil health as both a water
quantity and quality strategy. A holistic approach is necessary that takes into account
technical assistance and cultural shifts. And finally, programs must be developed in a
manner that supports specific targeted outcomes.

1. Public engagement and awareness building
A recurring theme in the development of successful water quality initiatives in several
states was public engagement, both of the general public and of farmers specifically.
This can be either grassroots engagement or via specific government entities. In
Arizona, the lack of general public engagement around agricultural water will require
targeted outreach and peer-to-peer learning at watershed levels.
Public awareness around water quality was cited by several respondents as an
important motivator behind the development of government programs. General public
engagement was the driving force behind the Minnesota Clean Water, Land, and
Legacy Amendment, a constitutional amendment that created a sales tax specifically for
clean water, which then led to agriculture-specific initiatives. In Minnesota, respondents
described a coalition of hunters, fishers, hikers, farmers, local governments, and
metropolitan communities that worked together to pass the amendment. In Michigan,
respondents described environmentalists, tourist business owners, and lakefront
property owners coming together to increase the visibility of water quality issues, such
as lake algal blooms. In Vermont, public awareness was spread through news articles
around the environmental damage of phosphorus overload of Lake Champlain. In
Missouri, the impact of soil erosion on water quality drove citizens to take collective

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action on the issue of water quality and soil health. In Utah, environmentalists have
expressly educated the public on issues of water contamination from tar sands. In each
of these cases, pre-existing public awareness is helping to spur water quality initiatives.
In Arizona, there is a lack of public engagement around non-point source pollution in
general and a lack of public knowledge around agricultural water specifically. None of
our Arizona interviewees referenced widespread public knowledge, but instead more
specific issues relevant to them as a water stakeholder. For example, Yuma farmers are
very concerned about E. coli levels in incoming irrigation water. Environmentalists
expressed concern about the effects of salinity in drought conditions, where evaporation
in reservoirs like Lake Mead and Lake Powell increase the water’s salt content. Anglers
are concerned about water contamination of previous upstream uranium mining.
However, none of these issues currently has widespread public traction to build a
political base for encouraging government action around water quality.
Public awareness can also be encouraged by specific government entities or nonprofit
organizations through public groups or forums, several of which were described by
interviewees and discovered through our research. For example, the Babbitt Center for
Land and Water Policy serves as a boundary-spanning organization that coordinates
Colorado River stakeholder meetings. The Moab Area Watershed Partnership in Utah is
another successful group that has brought together different actors into ongoing water
discussions and set policy priorities. The Georgia State Water Plan created Regional
Water Planning Councils, watershed-level management groups which convenes a
diverse group of stakeholders and voices to recommend watershed management
practices. In states such as Kansas, the local NRCS coordinates water stakeholder
meetings. In Minnesota, the Clean Water Council brings together a group of different
stakeholders. In Vermont, the Payment for Ecosystem Services and Soil Health
Working Group brings together voices around encouraging and supporting positive
environmental practices through payment programs. In Colorado, individual groups
representing citizens living in and around the nine river basins convene in Colorado
Basin Roundtable events to develop a plan to preserve and protect their specific
watershed. Each of these initiatives helps foster public engagement and awareness of
water issues and programs.
For farmer-specific water quality engagement, respondents recommended building
relationships through established trusted networks and peer-to-peer learning. The
Vermont Agency of Agriculture funds self-organized farmer watershed groups that meet
monthly to discuss issues. Where these are not self-organized, awareness and
engagement is best through existing networks. In Michigan, it was described how
participating farmers in the Michigan Agricultural Environmental Assurance Program

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(MAEAP) program put out signs and started talking and encouraging their neighbors to
join, to show the public that farmers were responsible land stewards working towards
clean water. One farmer participating in the Minnesota Agricultural Water Quality
Certification Program described how before participating, he learned about the program
through a variety of farmer groups and trade organizations before deciding to
participate. In Colorado, CSU Extension played a key role in doing outreach to farmers
within their existing network to build awareness of the government water quality
programming, collaborating closely with the Department of Agriculture and the
Department of Public Health and Environment. Repeated targeted outreach through
trusted networks is therefore very important. Arizona lacks promotion staff within AZDA,
which is important to establishing public awareness and outreach within the department.
Funding for a promotion section in AZDA seems crucial in creating a water quality
program within the AZDA structure.
For Arizona, we would recommend that any proposed program be first built with
farmers’ input, and that repeated outreach be done through trusted farmer partners.
Farmer water quality working groups could be convened at a regional level through
conservation districts and the partnerships described below. From interviewees’
responses, farmer trade organizations and cooperatives from a diverse array of sectors
should be included in such discussions, such as the Arizona Cattlemen’s Association,
United Dairymen of Arizona, Agribusiness and Water Council of Arizona, Arizona
Association of Conservation Districts, Yuma Fresh Vegetable Association, grain
cooperatives, and the Organic Farmers Association. These organizations have more
capacity than individual farmers to engage with new initiatives, and a broad range of
experience and knowledge. If they have buy-in and support the initiatives, they have the
network to reach their farm members through existing relationships and communication
channels. These water quality working groups would include a variety of agricultural
stakeholders and seek to both learn from farmers to inform the programs, as well as
disseminate information and encourage participation.

2. Voluntary Initiatives
Our research has led us to recommend a voluntary initiative when crafting new water
quality initiatives for Arizona. One interviewee described how regulations are necessary
to keep everyone above a certain very low threshold. But above that, voluntary
participation can often be more meaningful and effective. This is particularly true given
that basic regulations already exist that prevent or address the most egregious water
quality violations, particularly for point source pollution. For example, programs already
exist to certify Arizona CAFOs and regulate manure storage, disposal, and runoff.
Programs exist to test for E. coli in surface water irrigation. The Pesticide Safety Trainer

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Program prevents farmers from introducing pesticides into water. While pesticide runoff
in water is not currently adequately tested, current results show that the regulations are
working. What is needed is less a one-size fits all regulatory approach, and instead a
more nuanced, whole systems approach for encouraging farming practices that improve
water quality through a focus on soil health, as discussed in the upcoming section.
The other main reason for a voluntary initiative is a lack of current political willpower in
Arizona to pass regulatory changes. In 2021, Governor Doug Ducey signed the Arizona
Surface Water Protection Program, to regulate surface water that does not fall under
federal jurisdiction. While this is a very important step in giving Arizona DEQ the
authority for regulating surface water quality, one respondent worried whether DEQ
would be given the funding, testing capacity and the political will to adequately follow
through. In addition, the current hands-off approach of Arizona’s legislature to
environmental concerns makes it unlikely that stricter regulations will follow. For
example, one interviewee referenced that as long as Arizona Representative Gail Griffin
remains Chair of the House Natural Resources, Energy, and Water Committee, she has
expressed that she will not allow any legislation increasing state regulation of
groundwater, or allowing municipalities increased control over groundwater quality, out
of the committee. Politically, it is always difficult to target farmers with additional
regulation since farmers are recognized for their necessity in feeding the population.
With minimal profit margins in many agricultural sectors nationwide, it becomes difficult
for farmers to comply with costly state regulations.

3. Government agency coordination
In developing a voluntary state water initiative, the question arises of agency control and
interagency coordination. In other states, such agricultural water quality programs are
generally under the state Department of Agriculture or similar state agricultural division,
even while water is generally regulated through a Department of Environment and
Natural Resources, or similar division. A few interviewees mentioned farmers have a
more trusted, existing relationship with the Department of Agriculture, which is an
important reason why successful programs originate with that department. However, the
Arizona Department of Agriculture (AZDA) does not have a history of working with
farmers around water issues, beyond a few specific programs. While AZDA officials
expressed a willingness to partner with other agencies around water initiatives, there
was not a desire to create agriculture-focused water quality initiatives through the
department, and participants expressed that water was beyond the scope of the
department’s purview. Therefore, we recommend that a voluntary water certification
program be housed in the Arizona Department of Environmental Quality, which already
works around agricultural water usage and water quality.

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For a strong and successful program, it would be necessary for ADEQ to build strong
interagency partnerships with other government agencies and trusted resources.
Representatives from the Department of Agriculture should be included on a steering
committee, as should NRCS and conservation districts. In states with established
agricultural water quality programs, interviewees talked about having worked crossagency for decades and having long-established interagency relationships. In Arizona
interviews, there were few references to existing interagency cooperation. While some
officials have a passing knowledge of other state employees, there were large gaps in
knowing what agricultural water issues organizations and agencies were currently
working on. Therefore, there is a long way to go in establishing those interagency
relationships, but no better time than the present. The program should include regular,
monthly meetings with different departments to coordinate programing, in addition to
regular monthly meetings with farmers and farm organizations for feedback and
outreach.
It is worth noting that any new state program would not directly apply to tribal lands, but
could benefit from consultation with tribal representatives to determine partnerships and
joint capacity building. Tribal water regulations and programs lay outside the scope of
our research, and are a notable gap in this research that should be further explored.

4. Soil health as a water quantity and quality strategy
Throughout interviews across several states, as well as in our literature review, there
were many references to a strong relationship between soil health, water conservation,
and water quality. Many BMPs for water management are rooted in improving the soil’s
organic matter, structure, and biological activity. As soil health improves through the
adoption of practices such as no-till farming, year-round cover through cover crop use,
and others, the resilience of a farm and surrounding ecosystem improves. When asked
about best practices for water quality, seven interviewees highlighted soil health as a
key aspect of improving the relationship between agriculture and water.
One interviewee relayed that while their agricultural water quality programs may start
with supporting producers to change a few practices, they often lead to changing a
whole farm management system to better protect soil health and water quality. For
instance, a farmer may implement cover crop use, which enables them to move towards
rotational grazing of livestock and pull cattle out of riparian areas. Another example was
planting a fall cover crop, which leads to longer forage availability through the season,
which allows a farmer to keep cattle off of a feedlot for a few more months reducing
concentrated waste concerns. The short-term investment in cover crops and portable

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fencing through a water quality program pays off in a long-term farm management
strategy that supports healthy soil and in turn, improves water quality and ecosystem
health.
In Arizona, improved soil health can reduce the quantity of water needed to sufficiently
irrigate crops by building soil structure that more effectively retains water, whether from
minimal rain or from irrigation. While soil health strategies will look different in Arizona
than they do in Minnesota and other humid states, the same principles apply. Keeping
soil covered as much as possible, minimizing disturbance of the soil, maximizing
biodiversity, and enhancing the presence of living roots will be a critical strategy for
Arizona’s farm and ranchland to persist in a changing climate (NRCS Soil Health) with
less water available. The goal of water conservation certainly outweighs concern over
water quality in Arizona, but focusing on soil health would allow one program to address
both issues.

5. Holistic approach including cost share, TA, culture shift
Several stakeholders discussed that solely providing cost-share funding to implement
BMPs for agricultural water quality concerns is not sufficient to encourage widespread
adoption. The most successful programs outlined in this report take a holistic approach
including risk assessment, cost-share funding to implement practices, technical
assistance and training to understand why and how to implement BMPs, and coaching
or mentoring from trusted sources. The financial incentive is critical to encourage
adoption of practices that may impact the bottom line of a farm business initially.
However, stakeholders from many states talked about training and technical support as
equally important to help farmers transition to new ways of managing their land.
Another theme across many states is that farmers and ranchers are most likely to adopt
new practices or technologies if it is recommended to them by a neighbor, relative, or
respected resource in their community. They are unlikely to make changes based on a
government agency telling them they should or must do something differently. At this
time, very few states have the political will to regulate changes in agricultural practices,
so the power of strong local relationships is critical to the success of voluntary
programs.
As Arizona works with farmers and ranchers to address water concerns, the right
partners must be in place on the ground to help deliver messages and support
implementation. In many states, conservation districts or extension fills this role, often in
close collaboration with state agencies. Over Arizona’s diverse agricultural landscape,
different types of partners may be more effective at achieving a culture shift towards

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adopting water quality practices. Whether the partner is a Natural Resource
Conservation District, an extension office, an agricultural association, or other type of
organization, a program must provide adequate funding for the partner to hire local staff
to implement the program. These staff should be able to provide comprehensive risk
assessment, technical assistance, facilitate education and networking opportunities, and
distribute cost-share funding to farmers to implement approved practices.

6. Ensure that funding supports targeted outcomes
Even within existing agricultural water quality initiatives, both the literature review and
interviews revealed that the measurable environmental impacts of these programs were
unclear. While farmer engagement has been critical in adjusting production practices to
implement more BMPs, some interviewees spoke to the tension between measuring
short term indicators like these versus the ultimate desirable outcomes of improved
environmental quality within the watersheds. In Arizona, one interviewee stated that
measuring BMPs has not resulted in an improvement in water quality to date. The
structure of many voluntary programs prevents innovation and farm-level cost
effectiveness, therefore many producers are incentivized to perpetuate the same
practices with unclear or nominal results, instead of focusing on continuous
improvement over time tied to measurable outcomes. In addition, extensive state and
federal resources have been spent on clean water initiatives across the country in the
past several decades. Even with this investment, by many accounts there is not enough
funding - from any source - to effectively mitigate all known pollutants in American
waterways.
All this points to the recommendation of targeting funding where it can have the most
impact. Namely, toward the watersheds identified as critical source zones or particularly
environmentally sensitive regions. By applying the Pareto principle, also known as the
80/20 rule, in any state, there are certain watershed areas producing the most pollution.
The key is to identify these areas and allocate funds toward achieving specific, preidentified goals that quantify the changes where it can have the most impact. In
addition, build rewards and incentives toward the achievement of those goals.

7. Funding
In interviews and research conducted across ten states, the funding mechanisms for
agricultural water quality programs varied widely. Minnesota and Missouri passed a
statewide sales tax with a portion of the money dedicated to funding water quality
initiatives. Several states use CWA Section 319 Grant funding to implement agricultural
water quality programs. According to the 319 Grant website, the grant money “supports

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a wide variety of activities including
One of the key findings
technical assistance, financial assistance,
throughout this research is that
education, training, technology transfer,
water quality and quantity
demonstration projects and monitoring to
should not be separate
assess the success of specific nonpoint
conversations in Arizona.
source implementation project” (US EPA,
2015). The flexibility of this funding has
enabled some states to create innovative programs and partnerships to support farmers
and producers in adopting better management practices for water quality. ADEQ
already uses 319 funding for water quality programs, so a new program may need to
consider alternative sources, or at least matching funds to leverage 319 funding.
Nebraska uses a portion of fees levied by the Nebraska Department of Agriculture for
pesticide registration and applicator licenses to fund their Natural Resource Districts
through the Natural Resources Water Quality Fund (Nebraska Natural Resources
Commission, n.d.).
In June of 2022, The Center for the Future of Arizona (CFA) published new data as part
of the Arizona Voters Agenda, which included water as an important political issue in
the state. The report noted, “Very few things in politics achieve unanimous support, but
in Arizona, the issues of addressing Arizona’s water future and tackling drought come
very close” (Center for the Future of Arizona, n.d.). Polling data shows that 90-96% of
Arizona voters support four different water-related policy items from securing the state’s
water future to preserving and protecting Arizona’s rivers, natural areas, and wildlife.
Given this context, it may be an opportune time for a citizen-driven initiative to put a
sales tax to fund innovative water conservation and water quality initiatives on the ballot
(Center for the Future of Arizona, n.d.)

8. Integrate Additional Water Quality and Quantity Policies where
Applicable
One of the key findings throughout this research is that water quality and quantity
should not be separate conversations in Arizona. It isn’t uncommon for agricultural
issues to siloed, whereas the evidence that we have uncovered points to the need for
systems thinking in managing the overall water challenges Arizona faces. Soil health is
the most pertinent of these approaches to deal with both ends of the quality/quantity
spectrum, but there are additional specific quantity tactics that could be implemented in
the spirit of the aforementioned state quality plans. Under the purview of this same
potential water quality plan, it could make sense to have additional incentives for
improving water quantity through techniques such as laser field leveling, improved
concrete sluice lining and conversion to lower water usage forms of agriculture. Rather

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than further compartmentalizing these challenges in a state where increased
collaboration has been identified as an ideal to strive for, putting together these two
issues would be a way to address that concern with this plan.

Reinvent Current Structures, Systems, and Ways of Thinking
An overarching theme from many of our interviews was a need for culture shift in how
Arizona approaches water quality as a whole, and questions of political will to enact the
funding and programming necessary to make the big changes needed in the coming
decade. One culture shift related to economics is how Arizona approaches water
pricing. This idea was not the focus of our research, but one interviewee mentioned this
as the most important takeaway for long term water protection in a desert climate as a
result of simple economics of supply and demand. When a resource is free - or farmers
are incentivized to utilize their water resources at risk of losing them - there’s an
inherent tension in the value we claim it holds and how it is being expended. This is
especially true in the dynamics playing out in Arizona between rapidly developing urban
areas and water-intensive agricultural usage. Yet another perspective on this topic
cautioned against the strategy of pricing water since it would leave rural and farming
communities without water. Any potential pricing strategy for Arizona water must hold
the needs of all communities to work together toward a sustainable future.
Several interviewees raised the idea of markets paying a premium price for crops that
are certified for water quality. Similar to the USDA’s Organic Certification, could there be
a national certification model for agricultural production that reduces water pollution and
improves water conservation practices? A culture shift in consumers would be
necessary to demonstrate a willingness to pay more for this food to fill in the funding
that is currently coming from state and federal tax dollars.
Alternatively, change the model so that agricultural polluters must pay for the damage
they do to water quality, and use those fees to replace current public funding to support
better management practices. While it is clear regulatory measures on agriculture are
extremely unpopular politically, perhaps a market-driven disincentive to negatively
impact water quality and scarcity would drive voluntary adoption of BMPs and create
new funding sources to support the efforts.
Another consideration for Arizona is capital investment as a major component and
incentive for voluntary water quality initiatives. Given the “land-rich, cash-poor” nature of
many Arizona farmers and their operations, promising large amounts of capital for
climate-smart and water-minded investments could incentivize and prompt producers to
enact changes in Arizona’s agricultural production. The precedent for large amounts of

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capital investment earmarked for climate innovations already exists in Arizona through
solar panels on residential roofs, which have been subsidized by numerous programs
throughout the years. Why not apply similar incentives to farmers looking to make water
and climate-smart changes to their farm? Two emerging forms of sustainable agriculture
deserve consideration: agrivoltaic farming and vertical farms. Both utilize
unconventional techniques to increase land and water use efficiency.
Agrivoltaic farming entails the use of solar panels placed over crops to capture sunlight
as renewable energy and fuel for plants. While there are drawbacks to this approach namely a decrease in crop yield due to decreased direct sunlight - there are
considerable benefits, especially in the arid Arizona desert. According to studies on AV
from 2018 and 2019, respectively:
Model simulations have been able to reproduce the expected benefits from
agrivoltaic installations, for example showing that it is possible to improve land
use efficiency and water productivity at once, by reducing irrigation amounts by
20%, when tolerating a decrease of 10% in yield or, alternatively, a slight
extension of the cropping cycle […] (1) crop cultivation underneath APV can lead
to declining crop yields as solar radiation is expected to be reduced by about one
third underneath the panels. However, microclimatic heterogeneities and their
impact on crop yields are missing reference and thus, remain uncertain. (2)
Through combined energy and crop production, APV can increase land
productivity by up to 70%. (3) Given the impacts of climate change and
conditions in arid climates, potential benefits are likely for crop production
through additional shading and observed improvements of water productivity. (4)
In addition, APV enhances the economic value of farming and can contribute to
decentralized, off-grid electrification in developing and rural areas, thus further
improving agricultural productivity (Cheviron et al., 2018)
While the loss of crop yield efficiency may lead some to dismiss AV farming, the
aspects of increased water efficiency and overall increased land efficiency should give
detractors pause. While there are challenges that exist, such as those surrounding ideal
crop selection, water runoff management, and potentially expensive infrastructure, the
benefits seem well suited for the challenges that the Arizonan climate presents. Due to
the increased retention of moisture, microclimate conditions and soil health would both
improve. By tapping into more abundant yet underutilized sunlight resources, the
disproportionate savings in water of twice the supply for the amount of crop yield lost
would serve to remind us of one simple, yet key, principle: shade helps prevent
evaporation. In an agricultural climate in which fallowed fields are becoming more and
more the norm, a willing loss in production in the name of increased water and
economic efficiency could offer a way to transition into climate-adapted agricultural
systems, enhancing both quantity and quality.

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Similar in terms of increased efficiency, vertical farming is a burgeoning, albeit capital
intensive, form of agriculture. Vertical farming is a style of plant production that forgoes
soil in favor of producing either hydroponically or with limited beds of soil stacked
vertically. While the challenges of this style of growing are daunting (initial capital,
cleanliness and a relative limit on what types of plants can be grown), one of the key
benefits is too valuable for Arizona to ignore: water usage reduction rates of 90-95%
can be expected due to the highly controlled indoor environment and limited
evaporation. It also avoids runoff, preventing inadvertent downstream contamination.
Additionally, the increased electrical demands with this avenue of growth are well-suited
to be sustainably supplied by solar panels in the scorching desert, turning the at-times
oppressive heat into an advantage rather than a disadvantage.
Due to this potential to save water and protect quality, vertical farming has fans in the
state of Arizona. If vertical farms are to replace field-grown greens, this could free up
currently utilized cropland for purposes or plants more suited to our desert environment.
Choosing to grow VF crops indoors, in conjunction with choosing native perennials best
suited to flourish in a desert environment in the former crop space, could allow farms to
remain financially successful and have more options in terms of good stewardship of the
land. Whether it be crops chosen for the production of food, the sequestration of carbon,
the improvement of soil health, or some combination thereof, the improved space and
water efficiency afforded by vertical set-ups could enable a less demanding, and more
desert adapted direction for conventional Arizona agriculture to take, thanks to the
space, water and financial benefits freed up by growing indoors.
Furthermore, vertical farming would not be brand-new to the Valley. Vertical farms like
True Garden in Mesa and Citifarms in Central Phoenix are already up and running, and
OnePointOne, an agtech startup from Silicon Valley, invested in a 50,000 sq ft vertical
farm in Avondale in 2021. These companies have shown the feasibility of vertical
farming in the Valley, while hinting at the potential it could attain in the future.
Universities have also been active players on the VF front, with both ASU and the
University of Arizona having vertical farms on their campuses. Additionally, the vertical
farm at ASU utilizes the energy production and fertilizer generated by a food waste
breakdown tank. The potential for generating this methane and humus is especially high
in Arizona, as we unfortunately rank amongst the worst states in the nation for food
waste:
Arizona is the No. 1 state that wastes the most food for a cornucopia of reasons.
Among the 50 states, the Grand Canyon State registered the highest share of
food wasted and the lowest share recycled. It also ranked No. 3 for the lowest
share of food donated to people in need. (Ardoin, 2021)

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Widespread implementation of systems like this could have a great impact upon how
Arizona grows and conserves food, and the underlying connection with conserving
water. The organic matter generated by this process would be especially beneficial in
aiding soil health initiatives that could improve state water quality and quantity. Methane
could be an additional energy resource that would free up farmers’ funds for future farm
improvements, or manage increased overhead costs elsewhere, especially if the future
price of water becomes exorbitantly high. Mitigating some of the food waste (and water
waste) would represent a way for farmers to recoup some value from this resource
being wasted.
Another area where universities could have an impact on state water quality and
quantity is in the potential to set up scholarship funds and create curated curriculum to
guide students looking to contribute their career efforts to combating these and other
challenges connected to farming amid climate change. The potential to guide the
process and then connect students with prospective employers, or ways to become
agricultural entrepreneurs, could help fill a very valuable and in-demand niche. This was
a need that was vocalized at Arizona’s Conservation Districts Annual Conference in
August, 2022. The demand for a workforce to help manage water quality and quantity
efforts in the fields is outpacing the supply of college educated individuals equipped to
lead on these issues - either as policymakers or as producers - to evolve the
conversation in Arizona.
Another area discussed is the relative disrespect cast on agriculture as a form of highlevel study. At this same conference it was pointed out by several attendees that
agriculture should be considered an integral part of STEM, as the scientific,
technological, engineering and mathematical challenges of figuring out better water
plans, infrastructure and agricultural policies are no less valid or important than the
industries more commonly associated with STEM study. Introducing students to these
concepts early could be a way to incentivize them into farming and solving the state’s
most pressing challenges. The skillset of an individual schooled in a 4-year program on
water efficiency and environmental quality could become highly desirable given the
ongoing water crisis that is reshaping Arizonan agriculture and demanding the
development of such pools of talent.

Ending Unsustainable Farming
The most drastic recommendation we heard in a few interviews was that to protect
Arizona water, agriculture should be phased out entirely in specific agricultural activities
and sectors in specific geographic areas of the state. The issue boils down to whether,

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as Arizona continues to experience a drier climate, it can support and continue to
sustain both the current level of water-intensive agriculture and a growing population.
One interviewee strongly believed that there is no future at all in farming in Central
Arizona due to its reliance on groundwater. Due to the lack of surface water supply, they
posited that farming should end before continuing to use groundwater and deplete
aquifers. The problem of land subsidence, including sinkholes, has resulted from aquifer
collapses due to historic agriculture de-watering aquifers well below the natural
recharge rate. With the finite amount of groundwater, it should not be used to grow
crops such as cotton and alfalfa which are not direct food sources. And in fact, as
farming has begun to decrease in central Arizona due to urban sprawl, urban home
water use has replaced agricultural uses. Another interviewee noted that farmers’ water
rights in the prior appropriation legal framework have become their retirement package,
as they sell off those rights and the water is pumped from one aquifer to another to
support new subdivisions, which are required to have a 100-year supply of water. As
one respondent put it, “We don’t really have a water shortage problem, we have a
planning and zoning problem.” Another interviewee noted that the orange groves they
had planted decades earlier in Maricopa County had since been ripped out by backhoes
to build condos. While a few respondents mentioned long-distance pipeline projects and
aquifer pumping as a solution to water shortage, other respondents decried these
measures for not addressing the lack of sustainable water use.
Realistically, of course, farmers are not going to simply walk away from their business
and way of life. As one Arizona respondent said, some farmers who have farmed for
years, or even generations, now use less water than ever before as increased
populations in urban areas use more and more water. There are not a lot of ways to
keep decreasing the quantity of water used. Decreasing rural and agricultural allotments
for the needs of urban communities becomes an equity issue when rural farmers are
disadvantaged to use water or priced out
Decreasing rural and agricultural
compared to wealthy urban areas. The
allotments for the needs of urban
respondent pointed out that farming is not
communities becomes an equity
a thing of the past, and we will always
issue when rural farmers are
need to grow food - an obvious statement,
disadvantaged to use water or
but nevertheless often overlooked by
priced out compared to wealthy
urban policymakers. According to another
urban areas.
Arizona respondent, the increasing global
population necessitates increasing global
food supply, so decreasing agricultural production is not a solution.
Given the complexities around the controversial idea of ending farming, a targeted
program should be recommended to help compensate central Arizona farmers for

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desisting from agriculture that is reliant on groundwater. This program could be through
payments for water rights, or for technical assistance programs that help farmers
transition to agricultural production methods informed by Native American farming
techniques and early historical methods that grow drought-resilient food without
requiring groundwater. Colorado state’s program, Colorado River Drought Contingency
Plan, which paid farmers to stop farming amidst drought, could be modified in which the
state pays Arizona farmers to permanently stop farming. The state of Arizona would
effectively buy those farmers’ water rights and could then hold onto those rights to
decrease overall pumping from aquifers in danger of failing.

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Conclusion
Summary of Findings
This report looks to shine a light on issues of Arizona agricultural water quality, which
are consistently overshadowed by conversations around water quantity. However, with
a limited quantity of water, maintaining water of high quality for farmers, cities, and
ecosystems becomes that much more important. Through research of other state water
quality programs, the scientific literature, and interviews with 44 water experts
throughout Arizona and across the United States, this report has gathered insights and
recommendations for future Arizona policies and programs at the state level. Notably,
many of the recommendations for mitigating nonpoint source agricultural pollution
center around soil health, which is also frequently cited as a method for decreasing
water usage.
The recommendations discussed in this report center around measures to improve
water quality, innovate new technical solutions, and eliminate groundwater irrigation. To
improve water quality, a program is laid out for a voluntary state certification program for
producers, which can provide technical assistance and grant funds to help farmers in
meeting water goals on their farm. Recommendations for new technology and research
to truly reinvent the current structure of Arizona agriculture is laid out. And finally, a
recommendation is made for a program to assist in eliminating groundwater withdrawals
for irrigation in areas with depleted aquifers.
With surface water, such as Lake Powell and Lake Mead, at record low levels and
ongoing groundwater depletion, Arizona needs farmers to come to the forefront and
participate in discussions to find long term water solutions, and not simply protect the
status quo. These programs can be a solid steppingstone to engage farmers and to
create a learning network for continuing to adapt in the coming decades. Real coalitions
and coordinated action take years to build, but there is no better time to start than now.
It is not yet too late to act.

Concluding Thoughts
The wind whips through the canyons of the American Southwest, and there is no
one to hear it but us - a reminder of the 40,000 generations of thinking men and
women who preceded us, about whom we know almost nothing, upon whom our
civilization is based. - Carl Sagan
It is often said that history repeats itself. In the end, Mother Nature always outlasts

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humanity, and no matter our best intentions, the desert and current drought conditions
threaten to undo the water safety and security of the state of Arizona. Mega-drought
conditions undermine the long-term development of an otherwise ideal space for
expansion and growth, and as climate change demands adaptations from us all,
agriculture in Arizona, too, must answer that call. If the lessons of the past, other states
and even those examples from within, can be synthesized and utilized by the state of
Arizona to overcome these daunting water challenges, the state could not only prosper,
but set a precedent for other states and communities to follow. The Hohokam irrigation
system helped birth the early agricultural attempts of settlers, and their latticework lines
the landscape to this day, like wrinkles in time reminding us that in the desert water is
life. This is a sentiment that modern-day residents would be wise to heed.
The Arizona agricultural paradigm has always been to take advantage of the natural
resources Arizona has in abundance, land and sun, and to bring in when needed that
which it lacks, chiefly, water. However, the changing climates, both literal and societal,
are putting more pressure than ever on this production paradigm, demanding
compromise and change to keep the careful balance of Arizonan agriculture and nonagricultural development afloat. The time has come to question the paradigm in order to
determine the most logical steps moving forward. Throughout the course of our
research and dozens of interviews, the wide variety of opinions and recommendations
for how Arizona can protect its agricultural water quality and quantity have left us with
three general categories: calls to improve, reinvent or eliminate the agricultural scene in
Arizona all have their own merits, and a comprehensive Arizona plan will likely need to
integrate elements of all three.
Reinventing the agricultural industry in Arizona might prove to be the most costly, yet
most beneficial of the three avenues of approach. Long-term thinking demands longterm investment, and the upfront costs of subsidizing agrivoltaic farming, vertical
farming, scholarship funds for future farmers and other innovative techniques might
yield astounding long-term yields for the economic conditions of water in our state.
Leading the way through both desire and necessity, Arizona could become a hotbed of
agricultural innovation.
For crops that can’t be grown hydroponically, why not take advantage of the intensity of
the sun and save some water while you’re at it? Agrivoltaics might not have quite the
same yield, but what good is matching the yield of a system that needs to change? The
tradeoff of increased moisture and free solar power might be enough to make some
farmers sign up to make the change.

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If water, your scarce, expensive, and life-giving resource is so valuable, why use it
outside and exposed to some of the harshest elements in the country if it can be
avoided? Vertical farming could be an answer here. Transitioning to indoor, clean-room
style vertical farms would be a way to safeguard against evaporation, runoff and the
myriad of problems that comes with in-ground agriculture. It would make more sense to
grow produce in a way that maximizes water in a state desperate to find more
sources.
Innovation and state of the art technology are areas in which Arizona has experience,
from the history of industries like computer chips to the groundbreaking contributions of
the state universities in a variety of fields. Training the agricultural workforce of the
future through scholarships and creating cutting-edge curriculum plans could ensure the
continued role of agriculture industries in Arizona for years to come.
Ending the agricultural industry in Arizona is the most drastic approach. More than
anything, hopefully this dire suggestion serves as a reminder of the need to implement
improvements and innovation to avoid such an end. Ending Arizonan agriculture entirely
would do more than cripple an industry and end the livelihood of thousands, it would
also spell the end of an important tenet of Arizonan culture. However, that is not to say
that selective retirement of land for neither agricultural or developmental purposes
wouldn’t have its merits.
The political climate in the state of Arizona has proven to be a factor needing
consideration as well. Due to political pressure, plans should incentivize improvement
rather than force legislation that put producers into a box in which they have no options
but to comply with mandates from above. Decisions should be made on the level where
the decision will be felt, so initiatives that allow farmers to voluntarily improve their
operations are ideal. This has been one of the key lessons that Kathleen Merrigan, the
Executive Director of the Swette Center, has emphasized in our program curriculum: the
need to understand what farmers themselves desire as a key component of any policymaking decision. The decision-making process should include input from the people
whom the decision will impact, and if the voluntary plan operates with this approach, the
odds of acceptance and adoption by Arizona farmers would likely be far greater than a
plan bereft of collaboration.
At a time when political contention is more intense in Arizona than in years past, it has
become clear that water action is a key area where conservatives and liberals are able
to potentially see eye to eye. The issue of water in Arizona has a unifying effect
amongst many people of the state that might be otherwise politically divided. From
research, interviews and conferences such as the Arizona Association of Conservation

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Districts, the impression gained is that people in Arizona who may not be able to agree
on much else, agree that taking action on water is a top priority. Working together on
initiatives, starting ballot measures and collecting signatures for petitions could be ways
in which the political divide is bridged over the common cause of water protection. An
increase in public awareness and outreach through the establishment of these
recommendations could help do just that.

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Further Research Needed
Due to the IRB approval procedure as Arizona State University students, which requires
extensive review of any research involving tribes, there were no interviews conducted
with members representing Native or tribal nations. Therefore, the research team was
not able to learn and understand perspectives and needs of this population. More
research is needed to understand the unique context and regulatory considerations of
sovereign nations.
In the literature review, there were no studies on regulatory certainty as an incentive for
farmers and ranchers, which is a key component of the Minnesota Agriculture Water
Quality Certification Program, so this is another recommended topic for future research.
Many stakeholder interviews discussed the challenges of measuring the actual impact
of BMPs on water quality and conservation. The measurements and outcomes of
implementing these practices are based on models, which are difficult to follow
downstream. Future research could address how to better quantify the impact of
implementing different practices on agricultural land, particularly as practices are
stacked.
Lastly, a few interviewees mentioned the importance of leveraging the deep knowledge
and innovative solutions that can be developed through extension research and land
grant universities. More research is needed around new ways of growing crops in desert
climate including improved genetics for drought tolerant crops. One example from
Minnesota was the Forever Green Initiative which has developed new genetic seeds
and new markets for farms to make it financially feasible for farmers to implement yearround cover cropping that protects soil and reduces the need for nitrogen applications.
More research is needed to adapt this type of model for Arizona.

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Appendix
Appendix 1: Interview Questions
Questions for state water quality experts, non-profit organizations, and other
stakeholders:
• Describe your participation/involvement with your state’s water quality program.
• What are the key issues with current water quality programs and policies in your
state, particularly as related to agriculture?
• What are some examples of water quality programs or policies seeking to
address these issues? (e.g. regulatory vs. voluntary, impacts on farmers’ ability
or interest to participate?)
• What has been the impact resulting from these water quality programs or
policies? (e.g. water quality improvement, water conservation, etc.)
• How is the impact of the water quality programs or policies tracked or measured?
(e.g. data, communication, etc.)
• What are current “best in class” practices associated with water quality
programs? And how can other states like Arizona replicate them?
• What changes in programs or policies could positively impact future water quality
and quantity?
• Who are the key stakeholders in water quality decisions?
• What are the risks/costs associated with treating contaminated well water for
drinking?
• What best practices are recommended for desert style agriculture?
• How is equity accounted for in water quality schemes? (e.g. farmer access,
Indigenous water rights, community impact, etc.)
Questions for farmers participating in state water quality programs:
• Describe your participation/involvement with your state’s water quality program:
• When did you start?
• How did you learn about the program?
• What water quality practices are you using?
• What does the process look like from a farmer's perspective?
• If the program is voluntary, why did you choose to participate?
• What impacts have you seen from participating in the program?
• What do you like best about the program/policy?
• What would you change about the program/policy?
• What resources would make it easier for you to better address water quality on
your farm?
• Are there any other farmers or people working in agricultural water quality that
we should talk to for this research project?

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Appendix 2: Glossary of Abbreviations and Acronyms
3MP

Third Management Period

AMA

Active Management Areas

ADEQ

Arizona Department of Environmental Quality (ADEQ)

ADWR

Arizona Department of Water Resources

AgCWIP

Agricultural Clean Water Initiative Program

APP

Aquifer Protection Permits

ARC

Arizona Reconsultation Committee

ARS

Arizona Revised Statute

AWPF

Arizona Water Protection Fund

AWS

Assured Water Supply

AZDA

Arizona Department of Agriculture

BIP

Basin Implementation Plans

BMP

Best Management Practices

CAFO

Concentrated Animal Feeding Operations

CAGRD

Central Arizona Groundwater Replenishment District

CAP

Central Arizona Project

CDPHE

Colorado Department of Public Health and Environment

CNCEP

Connecticut Nitrogen Credit Exchange Program

CRP

Conservation Reserve Program

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CSP

Conservation Security Program

CWA

Clean Water Act

CWCB

Colorado Water Conservation Board

CWF

Clean Water Fund

DCP

Drought Contingency Plan

EPA

Environmental Protection Agency

EQIP

Environmental Quality Improvement Program

GMD

Groundwater Management District

IGFR

Irrigation Grandfathered Right

INA

Irrigation Non-Expansion Areas

KDA

Kansas Department of Agriculture

KDHE

Kansas Department of Health and Environment

KWO

Kansas Water Office

LEMA

Local Enhanced Management Area

MAEAP

Michigan Agricultural Environmental Assurance Program

MCL

Maximum Contaminant Levels

MDARD

Michigan Department of Agriculture and Rural Department

MPCA

Minnesota Pollution Control Agency

NCAB

Nutrient Credit Advisory Board

NDEE

Nebraska Department of Environment and Energy

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NGO

Non-Governmental Organizations

NOAA

National Oceanic and Atmospheric

NPDES

National Pollutant Discharge Elimination System

NPS

Nonpoint Source

OBEP

Office of Border Environmental Protection

RAP

Required Agricultural Practices

RIA

Regulatory Impact Analysis

SDWA

Safe Drinking Water Act

TDS

Total Dissolved Solids

TMDL

Total Maximum Daily Loads

USGS

US Geological Survey

VESP

Vermont Environmental Stewardship Program

VPFP

Vermont Pay for Phosphorus Program

VRBP

Verde River Basin Partnership

WBP

Watershed-Based Plans

WCA

Water Conservation Areas

WOTUS

Waters of the United States

WQCC

Water Quality Control Commission

WQT

Water Quality Trading (WQT

WRAPS

Watershed Restoration Protection Strategy (WRAPS)

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About the Authors
Zac DeJovine
Zac is a local graduate of ASU, having studied Political Science during his time there as
an undergraduate. In addition to this conventional university education, Zac was also
diagnosed as diabetic his freshman year at school. In some ways this personal health
experience was as educational as his classroom experience, and helped to lead him
down the path he is now currently interested in, that of the connection between politics,
sustainable economics and the impact of food and housing on these systems. He
believes that in a system where people inadvertently vote with their dollar for their own
environmental destruction, economic choices that are truly sustainable must give people
a way out of contributing to climate change. He currently works as a math and Spanish
tutor, y está completando su certificación para ser maestro de español. When not
reading about dirt, he enjoys running in his EarthRunner sandals and befriending every
dog he meets.
Jillian Dy
Jillian is a former vegetable farmer and sustainable food advocate working to reorient
the food system toward transparency and equity. As Policy Specialist at FoodCorps,
Jillian supports partners and leads projects to build the case for federal policy reform
that will strengthen local and regional food systems, support farm to school
procurement, and create more equity in child nutrition programs. Prior to FoodCorps,
Jillian was Deputy Director at The Common Market Mid-Atlantic, a nonprofit food hub
that creates wholesale market opportunities for sustainable family farms while
increasing healthy food access through institutional procurement. Her efforts leading the
Mid-Atlantic outreach team resulted in $15.5 million of local food sales from over 100
small and mid-scale farms. Jillian is a Senior Fellow of the Environmental Leadership
Program, and was a 2020 finalist for NYC Food Policy’s 40 under 40.
Ami Freeberg
Ami Freeberg works for Cultivate Kansas City, a nonprofit working to grow food, farms,
and community in support of a sustainable and healthy local food system for all. She
began her career with Cultivate Kansas City in 2010, working for seven years in
communications, outreach, and community engagement. After four years away, Ami
rejoined the team as the Program Manager for Metro Farms & Food Systems, working
with Kansas City’s urban farmers through technical assistance, networking,
grantmaking, and collaborative advocacy. She serves on the steering committee of the
Greater Kansas City Food Policy Coalition. Ami has also worked in community
development and environmental nonprofit organizations. As a passion project, Ami
founded and runs Longfellow Farm, an urban farm where neighbors work together to

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grow food and build community. Ami graduated from Grinnell College with a degree in
Sociology and Global Development Studies.
Shelby Kaplan
Shelby recently graduated from the University of Wisconsin Madison with a degree in
plant pathology and a minor in food systems. She is originally from New York, but did
not have a background in agriculture. Wisconsin introduced her to organic agriculture
and its importance. Shelby’s interest continued as she worked in research labs focusing
on plant diseases in major crops. In her classes she kept coming back to agricultural
policy issues. To her, this is how to make the largest difference. After graduating she
was able to support the Organic Farming Research Foundation as an intern and hopes
to continue working to improve our food systems.
Deborah Sadler
Deborah is the Operations Manager at the Food Connects Food Hub in Brattleboro,
Vermont, where she has coordinated the distribution of local food throughout New
England throughout a period of high growth. She is excited about providing real-world
practical solutions to deliver food from producers to consumers and leveling the playing
field to provide access for smaller producers and customers. She wants to help build
strong local networks that help the profits stay with the producers. While studying
anthropology and international relations at Eckerd College, she became passionate
about the culture of food. She went on to research the effects of government policies on
farmers’ ability to adapt to drought. She previously worked at farms and creameries in
Massachusetts, Vermont, and Washington state, including managing a goat dairy and
farmstead creamery.
Nithesh Wazenn
Wazenn, Nithesh is a US liaison to the research wing of a multinational company, who
turned to be homeless, lived in the streets of New Jersey, was kidnapped, lost
immigration status, became illegal, got debarred from entering the United States for ten
years, and lost footing in society. Eventually challenged his difficulties and established
life in the United States.
Wazenn worked with the Labor Racketeering Division in a fraud investigation that
helped over 146 immigrant students regain their valid immigration status and back
wages from a fraudulent employer. He is also the first individual to be granted a direct
permanent residency in the USA by the Labor Racketeering Division, Voorhees, NJ for
helping end IT sweatshop trafficking. He has operational expertise across discrete
manufacturing, oil & gas, and telecommunication companies in United States, Europe,
and Asia-Pacific regions and practiced as a paralegal specializing in business laws and
Immigration. Wazenn's entrepreneurship journey started as a climate change

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entrepreneur and failed due to governmental regulations. The lessons learned from
failure eventually led to an interest in food policy & governance and sustainable food
systems.

Contact for more information:
Swette Center for Sustainable Food Systems
Email foodsystems@asu.edu | Website foodsystems.asu.edu

Swette Center for Sustainable Food Systems is a unit of ASU School of Sustainability