Thumbnail photo courtesy of Buchio Takano via Wikimedia Commons. Creative Commons License.
State water quality scientists unveiled a proposed order they say will lead to a more robust means of monitoring and curtailing pesticide and copper contamination from Easter lily operations in the Smith River plain.
Currently in draft form, the Lily Bulb Order adds to a voluntary framework that growers have participated in since 2021 — which, scientists say, has led to a decrease in pollutants in the area.
But for conservationists who spoke at a North Coast Regional Water Quality Control Board public workshop on Wednesday, the proposed general waste discharge requirements weren’t strong enough.
Meanwhile, the one lily bulb producer who spoke, Rob Miller, of Dahlstrom & Watt, said the requirement to test surface waters near their fields will lead to costs producers in other commodity groups don’t have to bear. He reiterated a statement scientists made that, while there were pesticide detections in groundwater and residential wells in the Smith River area, they weren’t at toxic levels.
Miller also said the 45-day comment period that began on Jan. 30 was too short and asked if the Board would consider extending it.
“The three lily growers need more time to digest (the proposed order) and comment to the Board,” he said. “Other regions that have adopted irrigated land programs deal with totally different cropping systems compared to the Smith River. We do not fit in any template that has been used in any other area in California and it’s rather obvious that this permit is very tempered towards the specific things in Del Norte County and Easter lily growing.”
After hearing from a handful of other people that they’d like more time to comment, the Water Quality Control Board asked staff to extend the deadline an additional 15 days to March 30. The final order is expected to come to the Board for consideration in August.
Easter lily bulbs are currently cultivated on less than 1,000 acres near the Smith River estuary and on the coastal terraces north of the river, Senior Water Resource Engineer Daivd Kuszmar said. He noted that he supervises the Water Quality Control Board’s Southern Agricultural Unit, which covers existing and emerging regulatory programs on the North Coast, which includes cannabis, dairies, vineyards and, now, Easter lilies.
Efforts to address water quality concerns associated with the local Easter lily bulb industry date back to 2000, Kuszmar said, with state water quality scientists working with growers since 2019.
In that time, the cultivation footprint has dwindled to less than 1,000 acres with only about 200 acres or less planted to lily bulbs, Kuszmar said. Lily bulbs are seasonal, typically grown on a three-to-five year rotation. This involves tilling and grading existing pasture land, applying pesticides and fumigants before planting immature bulbs.
Once the bulbs sprout, the leaves are treated with copper to ward off fungus and mold. In the autumn, the tops of the plants are removed and the mature bulbs are harvested, cleaned, sorted and shipped to commercial buyers.
The fields are then seeded for pastureland again, Kuszmar said.
This cycle can span about 18 months, said water board engineering geologist Brenna Sullivan, the lead on the development of the Lily Bulb Order.
The industry relies on a broad suite of chemical products to produce Easter lily bulbs, but those of particular concern include the synthetic pesticides diuron, ethoprop and imidacloprid as well as copper, Kuszmar said.
“We tend to see higher concentrations in surface waters during the wet season and immediately following storm events,” he said.
The draft Lily Bulb Order calls for continued monitoring of surface waters for those synthetic pesticides and copper, Kuszmar. Groundwater monitoring for pesticides and nitrate contamination will also continue. Water Board staff have been working with the California Department of Pesticide Regulation to offer free domestic well sampling.
“Results provided to well owners to-date show some detections of pesticides in some wells, but no concentration in excess of applicable health criteria,” he said. “The latest sampling included supply wells used by the Smith River Community Services District. It’s our understanding that the district provides drinking water to over 900 connections in their service area.”
Those test results are expected in a matter of weeks, Kuszmar said.
Under the draft Lily Bulb Order, the North Coast Water Board would urge growers to participate in coalitions or programs that would facilitate and document their compliance. They can also enroll in the Lily Bulb Order individually, Sullivan said.
The draft Lily Bulb Order sets benchmarks for the three synthetic pesticides and copper, Sullivan said. It proposes eight surface monitoring locations chosen because they are generally downstream of lily bulb fields and are accessible. Growers can propose alternate locations as well, she said.
The timing and frequency of monitoring would occur when concentrations are most likely elevated, during storm events and the wet season, Sullivan said. It assumes a three-year crop rotation and outlines management requirements if pollutant benchmarks are exceeded, she said.
One adaptive management strategy could include creating a setback from a stream using vegetation that can provide shade and other benefits, Sullivan said.
“Actions required under the draft order is first they can enroll individually or they can form a coalition and pay an annual fee, and that fee is set by the state water board,” she said. “Next would be to implement practices, we talked about minimum management practices in Attachment B — those came to us from the Smith River Water Quality Management Plan — next is monitoring and reporting.”
Sullivan said she and her team at the water board met with lily growers and understand that it’s a unique farming activity.
“The draft order needs to be tailored to that uniqueness,” she said. “There are a number of growers and limited resources in the Smith River Plain and we need to make efficient use of those limited resources to achieve water quality outcomes we’re looking for.”
The draft Lily Bulb Order also outlines several enforcement actions for non compliance, including with notices of violation and assistance to the grower so they can comply, according to Water Board Assistant Executive Director Claudia Villacorta. If the violations are egregious there could be fines involved as well as cease and desist and abatement orders, she said.
When commenting on the Draft Lily Bulb Order and the accompanying environmental impact report, Water Board member Greg Giusti noted that constructing a vegetated treatment buffer zone between a field and a stream seemed exorbitant.
“We’re talking about moving a lot of dirt, not just letting stuff grow,” he said. “That’s why it’s $10,000-$12,000 per acre.”
Miller also discussed cost with the water board, noting that testing a drainage for copper is about $100 roughly three times a year. Testing for imidacloprid, diuron and ethoprop is $300 each per test three times per season, he said.
“That’s $3,000 per location per year. Seven or eight locations, that’s $21,000-$24,000 per year,” Miller said. “And if you calculate that over the individual acres that are grown — not the grass, which has no impact whatsoever in the rotation — the $21,000 at 200 acres, that’s $105 per acre. I can guarantee you that there is no other agricultural coalition group or commodity group whatever that pays $100 per acre for testing.”
Though water board scientists said pollutants have decreased since 2021, to the Tolowa Dee-ni’ Nation there is no acceptable level of pesticide application within the Lower Smith River, Natural Resource Department Director Rachel McCain said. The area is a food desert, she said, and Easter lilies are not a food source.
Easter lily cultivation is also detrimental to cultural resources within the Smith River with the river itself being a cultural resource, McCain said.
“The Nation defines a tribal cultural resource as everything — the land we live on, the water, the air we breathe — everything that’s within our system of being,” she said. “… the ability for people to safely drink or wade within the water, harvest within the waterway, fish, obviously… all of that is impacted by this very intensive and concentrated application of pesticides in this very small area.”
McCain’s colleague, Tolowa Dee-ni’ Nation Environmental Division Manager Monica Hiner, a fisheries biologist, said that one tributary, Delilah Creek, has had exceedances for copper, which doesn’t break down.
“It affects salmon’s olfactory ability to get back home,” she said. “It’s highly toxic to all aquatic organisms.”
Marine biologist and Friends of Del Norte member Craig Strong cited The Tolowa Natural Resources Department, which counted 36,000 salmonids moving upstream in the Smith River last fall — 6,000 more than in 2024.
Strong noted that the salmonid numbers correspond with a harvest reduction in commercial and sport fishing as well as the reduction in pesticides due to the voluntary framework lily bulb growers had been participating in since 2021.
“As tribal knowledge and old timers can tell you, there should be hundreds of thousands of salmon, not 36,000,” he said, adding that while water quality scientists have not touched on the cumulative effects from multiple toxins at below benchmark levels, they exist in endangered species. “In this light, every year the lily bulb farming releases toxins to the waterways it is likely a take of endangered species under the (Endangered Species Act) definition.”
Even if the order is adopted and farmers continue growing lily bulbs, “we” may be in violation of the Endangered Species Act, Strong said.
For more information about the draft Lily Bulb Order and the draft environmental impact report, click here. According to Sullivan, water board scientists will respond to written public comments submitted by the March 30 deadline.
