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Information Sheet IS-18 Reissued Waste Discharge Requirements General Order R5-2013-0122 Existing Milk Cow Dairies Regs., tit. 27, § 20340) between the two liners. Review for retention ponds designed to this standard will be conducted in less than 30 days of receipt of a complete design plan package submitted to the Board. Tier 2 includes a retention pond designed in accordance with California Natural Resource Conservation Service (NRCS) Conservation Practice Standard 313 or equivalent and which the Discharger must demonstrate through submittal of technical reports that the alternative design is protective of groundwater quality. Best Practicable Treatment or Control Measures for Existing Dairy Ponds Existing dairy ponds were built to contain and store the large quantities of dairy cow wastes prior to discharge to land application areas. These ponds present a difficult challenge for the dairies that may be causing unacceptable groundwater impacts. This is because requiring the immediate retrofitting of existing ponds to meet Tier 1 or Tier 2 requirements (the Dairy General Order's requirements for new or expanded ponds) would be beyond practicable economic limits for most dairies (See Memorandum from John Schaap and Steve Bommelje, Provost & Pritchard to Theresa A. Dunham, Somach Simmons & Dunn (August 5, 2013), Costs to Retrofit Existing Dairies That Do Not Have Tier 1 or Tier 2 Lagoons (Provost & Pritchard 2013); see also Memorandum from Annie AcMoody, Western United Dairymen to Theresa A. Dunham, Somach Simmons & Dunn (August 6, 2013), Financial Impact to Retrofit Existing Dairies That Do Not Have Tier 1 or Tier 2 Lagoons (AcMoody 2013).) Specifically, the range of costs to retrofit lagoons range from an estimated low of$180,000 for a single liner at a 300 milk cow dairy to almost$1.4 million for a double liner at a 3000 milk cow dairy. (See Provost & Pritchard 2013, p. 3.) Considering the net loss in dairy operation revenues over the past five years and the likelihood of an inability to obtain financing, it would be near impossible for most dairy operations retrofit dairy lagoons and remain in operation. (AcMoody 2013, p. 4.) If forced to retrofit such lagoons, many dairy operations would likely go out of business. The widespread closure of dairies in the Central Valley would have regional and state economic impacts. Considering the wide-spread economic impacts that would occur with respect to requiring application of Tier 1 or Tier 2 requirements to existing ponds, the Central Valley Water Board finds that BPTC for existing ponds constitutes an iterative process of evaluation that includes groundwater monitoring individually or through the RMP, assessment of data collected, evaluation of Existing Pond conditions and their impact on groundwater quality, and case studies that evaluate potential changes in management practices and/or activities that may be necessary to further protect groundwater quality from existing ponds. The Board will use the SRMR (for dairies represented in the RMP) or individual Summary Monitoring Reports (SMRs), for dairies that are in an individual monitoring program, to determine whether upgrades to existing ponds will be required. Facilities where data demonstrate that an existing pond is resulting in degradation beyond what is authorized under this order will be required to upgrade facilities on a time schedule that is as short as practicable. Substituting alternative management practices for the existing ponds (such as reducing the water level in the ponds, dry-scrape, or other methods) would also be acceptable, provided those management practices are found to be protective of groundwater quality for the conditions present where they would be implemented. Regulated dairies that are found not to be protective