After twenty years of working directly with California regulatory agencies, one thing is consistent: an inspection is won or lost by the files you can produce on site.

Michael Wegner advises growers, landowners, and agricultural managers across Northern California on compliance with the California State Water Resources Control Board (SWRCB) and the Regional Water Quality Control Boards. The following is a practical, field-tested guide to preparing for an SWRCB inspection under the Irrigated Lands Regulatory Program (ILRP) and for obligations tied to Waste Discharge Requirements (WDRs).

Understand the legal framework

Inspections related to agricultural runoff and irrigated lands are conducted under the authority of the California State Water Resources Control Board (SWRCB) and its nine Regional Water Quality Control Boards (Regional Water Boards). The primary regulatory framework for irrigated agriculture is the Irrigated Lands Regulatory Program (ILRP), which typically requires dischargers of agricultural runoff to enroll in a conditional waiver or to obtain Waste Discharge Requirements (WDRs). Inspectors enforce compliance using tools such as Notices of Violation (NOV), Cleanup and Abatement Orders, and Administrative Civil Liability (ACL).

What inspectors will typically look for

Inspectors from the SWRCB or a Regional Water Board — or staff working with third-party coalition groups under the ILRP — will generally focus on three areas: the presence of unauthorized discharges, the implementation of best management practices (BMPs), and recordkeeping required by enrollment or WDRs.

• Evidence of discharge to surface waters or conveyances (tailwater, drainage ditches, culverts).
• Implementation and maintenance of erosion control, irrigation management, and containment measures.
• Availability and completeness of required records: enrollment, monitoring and reporting, farm plans, pesticide and fertilizer application logs, and training documentation.

On-site activities to expect

• Presentation of credentials and explanation of inspection scope.
• Document review in the office, vehicle, or at a designated site office.
• Field tour of parcels, discharge points, irrigation systems, storage areas, and BMPs.
• Interviews with the responsible manager or operator and staff present during the inspection.
• Photographs, GPS records, and possibly sample collection (surface water, sediment, or runoff).

Documents and records to have ready

Documentation is the single most important element to prepare. Inspectors typically expect records to be current, organized, and immediately available. A lack of records may be construed as a compliance failure.

• Enrollment documentation: proof of enrollment in the ILRP, coalition membership (if applicable), or copies of WDRs/conditional waivers.
• Monitoring and reporting records: surface water monitoring results, lab reports, chain-of-custody documentation, and monitoring location maps.
• Farm or nutrient management plans: maps showing field boundaries, drainage, irrigation sources, and BMP locations.
• Pesticide and fertilizer application records: Pesticide Use Reports (PURs), application dates, rates, and calibration logs for irrigation/fertigation equipment.
• Maintenance and inspection logs: pump maintenance, filter cleanings, containment inspections, and irrigation repairs.
• Spill response and corrective action records: spill reports, cleanup activities, and notifications to agencies if applicable.
• Staff training records: documentation that staff understand spill response, calibration procedures, and irrigation management.

Practical steps to prepare before an inspection

Preparation reduces stress and exposure to enforcement. Michael Wegner recommends the following pre-inspection actions that consistently improve inspection outcomes.

• Conduct an internal audit. Use a written checklist to verify enrollment status, WDR conditions, monitoring records, and BMP maintenance. Mock inspections allow staff to practice interaction with inspectors.
• Assemble a compliance binder. Keep one physical and one digital binder with the documents listed above. Organize by topic and date so items are easy to find during an on-site review.
• Map and mark sampling and discharge points. Clearly labeled maps with GPS coordinates and photos will speed an inspection and reduce questions about sample locations.
• Confirm laboratory records. Ensure labs used for surface water sampling are accredited and that chain-of-custody forms and final reports are filed with the monitoring record.
• Train a designated point of contact. The person who greets inspectors should know where documents are stored, be able to explain routine practices, and know when to defer technical answers to the manager or consultant.

How to handle the inspection on-site

On the day of inspection, professionalism and a cooperative attitude matter. The goal is to demonstrate transparency while protecting the operation from unnecessary admissions.

• Ask to see credentials and the scope of the inspection. Note the inspector’s name, agency, and contact information.
• Designate the knowledgeable point person to accompany the inspector. Avoid uncontrolled movement of the inspector onto unrelated private property.
• Provide requested documents but avoid volunteering extra, speculative information. If the inspector asks a technical question beyond the staff’s knowledge, offer to provide an answer in writing after consulting records or a consultant.
• Document the inspection. Take your own photos and notes. Record which documents were provided and any statements made by inspectors.
• If samples are collected, request copies of chain-of-custody forms and a record of where and when samples were taken.

If violations are identified

Minor findings can often be corrected quickly; more serious findings can lead to Notices of Violation (NOV), Cleanup and Abatement Orders, or Administrative Civil Liability (ACL). If a violation is identified:

• Request the inspector’s written findings and the timeline for required corrective actions.
• Develop and document a corrective action plan with clear deadlines, responsible parties, and verification steps.
• Consider retaining counsel or a compliance consultant for response negotiations or to prepare technical reports that demonstrate remediation.

Final recommendations

Regular, documented compliance is the best defense against enforcement. Operators should consider keeping enrollment and monitoring obligations under the ILRP and any WDRs current and verifiable. Routine internal audits, organized records, and a trained point of contact reduce inspection time and exposure to enforcement actions.

Wegner Consulting helps clients perform mock inspections, assemble compliance binders, and prepare corrective action plans tailored to requirements from the California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards. Inspections are operational events — good documentation makes them routine.

Contact Wegner Consulting for a confidential consultation.