Region-Wide Salt and Nitrate Management Planning Workshop June 12, 2012 1:00 to 4:00 PM Regional Water Quality Control Board Fresno Office

Pamela Creedon, Executive Officer Central Valley Water Board Purpose and Agenda Introduction Slides for Pamela

Purpose Inform Board of salinity background and CV-SALTS Effort Plan and Status Receive feedback and comments from Board on approach, workplan, schedule and milestones Receive feedback and comments from Board on Archetypes/Prototypes and Management Practice Toolbox

Workshop Agenda Workplan, Strategy and Framework Opening Statement and Introduction Pamela Creedon, Executive Officer RWQCB Background of Salinity and Nitrates in the Central Valley Jeanne Chilcott, Senior Environmental Scientist RWQCB CV-SALTS Overview and Organization David Cory, President, CV Salinity Coalition Workplan, Strategy and Framework Daniel Cozad, CV-SALTS Program Manager Current Implementation and Policy efforts Parry Klassen, Executive Committee Chair Addressing Difficult Questions/Charting a Path-Archetypes/Prototypes Tim Moore, CV-SALTS Policy Facilitator Public Comment Summary and Closing Jeff Willett, Executive Committee Vice-Chair Feedback Feedback Feedback

Jeanne Chilcott, Sr. Env. Scientist Central Valley Water Board Background of Salinity and Nitrates in Central Valley Issues Current Regulation Options

Salt Issues More salt enters the region than leaves Tulare Lake Delta Sacramento River San Joaquin River More salt enters the region than leaves Sacramento Basin has relatively few salt impaired areas but salt exported to the Delta can be picked up and redistributed by SWP and CVP San Joaquin River is the SJR Basin’s sole outlet. Salt imports exceed export capacity Two of our basins, the Sacramento and San Joaquin River Basins, both have a natural outlet to the ocean through the Sacramento-San Joaquin Delta Estuary and San Francisco Bay.

Salt Issues More salt enters the region than leaves Tulare Lake Delta Sacramento River San Joaquin River More salt enters the region than leaves Sacramento Basin has relatively few salt impaired areas but salt exported to the Delta can be picked up and redistributed by SWP and CVP San Joaquin River is the SJR Basin’s sole outlet. Salt imports exceed export capacity Two of our basins, the Sacramento and San Joaquin River Basins, both have a natural outlet to the ocean through the Sacramento-San Joaquin Delta Estuary and San Francisco Bay. Water development has changed the rate and routing of flow and salt from these basins, with the Bay-Delta now providing drinking water to two-thirds of the State’s population and water supply for agricultural areas both in the Delta and beyond. 5/2/2019

Salt Issues More salt enters the region than leaves Tulare Lake Delta Sacramento River San Joaquin River More salt enters the region than leaves Sacramento Basin has relatively few salt impaired areas but salt exported to the Delta can be picked up and redistributed by SWP and CVP San Joaquin River is the SJR Basin’s sole outlet. Salt imports exceed export capacity Tulare Lake Basin has no reliable outlet In contrast, the third basin in the Central Valley, the Tulare Lake Basin, no longer has a natural outlet to the ocean and all the salt remains within the basin. 5/2/2019

(Delta, Tulare Lake, Westside SJR Basin) Salt Issues Salt build-up threatens agricultural productivity (Delta, Tulare Lake, Westside SJR Basin) Need for Agricultural Drainage Recognized Since Late 1800’s CVP’s San Luis Unit Authorized in 1960 Not a new concept. 5/2/2019

Salt Issues Increasing salt concentrations (including NO3) in groundwater threaten drinking water Particularly areas with: Irrigated agriculture Dairies Septic systems 5/2/2019

Salt Issues Water used for dilution is (usually) water lost to other uses 5/2/2019

Diverse Sources Regional Water Use Exacerbated Locally Agricultural Urban Rural Environmental Industrial Water Providers Salinity increases in Central Valley surface water and groundwater can be attributed to many factors. Each of us contributes to the problem, and each of us is now or in the future will be impacted in some way by the problem of an increasingly saline water supply. Exacerbated Locally Municipal wastewater Septic tanks Oil field brines Confined animal facilities Food processors

Economic Costs If the Region does not change it’s approach to salt, by 2030… Direct annual costs anticipated to range between $1 to 1.5 BILLION Total annual income impacts statewide anticipated between $1.7 to 3 BILLION There is presently no means of distributing these costs equitably or assigning costs to all responsible parties. Based on UCD Economics Report, 2009.

Current Regulation Regulatory Basis: Basin Plans Identify how we protect water quality Regulatory document Establish beneficial uses Establish water quality objectives to protect BUs Prescribes an implementation plan Actions and timetables Our regulatory authority comes from the Basin Plans Our Region has two Basin Plans – one for the Sacramento and San Joaquin River Basins, and the other for the Tulare Lake Basin. There is also a Basin Plan for the Delta, but this is developed and implemented by the State Water Board. Basin Plans are our guiding documents that control the permits we write and many of the actions we take. They can be considered the bible of the Regional Board. The corner-stone of the Basin Plan are the designated beneficial uses of both surface and groundwater. The Board’s mandate is to protect those uses—whether for agricultural supply, drinking water, recreation, wildlife, or a host of other uses. Water quality objectives are the numeric or narrative standards established in our Basin Plans for protecting the beneficial uses of our State’s waters. These are used to help establish effluent limits and receiving water limits for our permits. The implementation component identifies the actions that will be taken to insure that the water quality objectives are met and the uses protected.

Current Regulation Regulatory Tools: Setting limitations in WDR and NPDES permits TMDLs Waste Discharge Requirements (WDRs) are our primary tool for regulating salt An important tool used to regulate is our permitting process. We issue two basic kinds of permits. The first is Waste Discharge Requirements or WDRs, for waste discharges made to land, such as to ponds or to crop land. The second is the NPDES permit, for waste discharges made to surface water bodies. Many municipal wastewater treatment plants have NPDES permits. Discharges to groundwater and dairies are and soon agricultural discharges under the ILRP will be covered under WDRs.

Most sections of the current Basin Plans addressing salt are over Current Regulation WDRs MUST comply with Basin Plans Most sections of the current Basin Plans addressing salt are over 30-years old Although based on the best science of the time, most of the sections of our basin plans that deal with salinity were developed in the 1970’s. 5/2/2019

Current Regulation Results: Limited data available for staff to interpret water quality objectives and implement the Basin Plans Over time, salt and nitrate has become a more prominent issue for Regional Board Outcry from dischargers and others for doing too much or too little When working under these limitations, it becomes difficult for staff to interpret how best to apply water quality objectives and implement in order to protect the designated beneficial uses. Since the 70’s, salt and nitrate has become a more prominent issue in many sectors of our Region, and the current process of regulating discharger by discharger has resulted in both concerns that we are being too stringent in some cases as well as being too relaxed in others. --In particular, the food processing and winery industries, and municipalities felt our regulation of salt was causing financial hardship while others saw their supplies being degraded. 

Current Regulation Examples: POTWs protecting MUN use in ag drains (Colusa, Willows, Live Oak, Biggs) Dischargers (including Ag) held to conservative salinity concentrations to protect AGR use Prohibiting discharges of nitrate does not in itself translate to safe drinking water for those impacted by high concentrations

Current Regulation Need: Update Regulatory Basis ie. Update Basin Plans Since we regulate based on the existing Basin Plans, any potential changes related to salt control must be reflected within the Basin Plan to be enforceable.

Options Traditional Regional Board approach Stakeholder approach Collaborative and integrated approach No Action is also an alternative If willing to accept economic cost To move forward with amending a basin plan, there are essentially two approaches: 1) the traditional approach where Regional Board staff take the lead; and 2) the collaborative approach where all stakeholders involved in the issue jointly participate with staff in creating a solution. Of course, there is the no action alternative if we are willing to accept the economic cost outlined earlier.

Stakeholder Based Solutions Stakeholder involvement and ownership Better addresses all needs and concerns Utilize everyone’s efforts & resources more efficiently and effectively Basin Plan - based on better data - more effective 27 March 2012

David Cory, CVSC President Overview of CV-SALTS History and Organization

CV-SALTS Status and Progress Slide 23 CV-SALTS is complicated CV-SALTS is organized CV-SALTS is important CV-SALTS is working CV-SALTS is undertaking a large complicated diverse area with a unique regulatory history and problems CV-SALST is now well organized to undertake this effort and succeed with dedicated stakeholders, leadership and contractors CV-SALTS mission is critical to the future of the Central Valley, economically, socially and environmentally CV-SALTS is well underway and has agreement on the direction and decisions on critical issues that are allowing us to move forward

CV-SALTS History 2006: Joint Workshop 2009: MOA Initial Products Economic study Metadata report Educational Video Strategy 2009: MOA State Water Board Central Valley Water Board Central Valley Salinity Coalition Stakeholder JPA

CV-SALTS Mission Develop a comprehensive regional salinity nitrate management plan that is robust enough to support basin plan amendments Plans to be amended: Sacramento/San Joaquin River Basin Plan Tulare Lake Basin Plan Delta Plan CV-SALTS initiated prior to the Recycled Water Policy and has compatible goals, therefore CV-SALTS became the vehicle to meet the requirements of the Policy. 27 March 2012

CV-SALTS Tackling Important Issues Slide 26 Stakeholder issues Water Board Issues Changes to the Basin plan to assist the Regional Board Mutual Decisions not Litigation

Recycled Water Policy Relationship CV-SALTS was initiated before the State Water Board Recycled Water Policy CV-SALTS was designed with the same basis Stakeholder driven Basin Salt and Nitrate Management Some Avenue for local agencies to produce SNMPs Will comply Recycled Water Policy Requirements Footer goes here if you want (can be turned off) 5/2/2019

CV-SALTS Organization Slide 28 Leadership Team (State/Federal Agencies and Stakeholders) Central Valley Salinity Coalition (Stakeholders) CV-SALTS Executive Committee (Subset Leadership Team and CVSC) Funding Subcomm. Technical Committee Education Outreach Lower San Joaquin BMP Evaluation Knowledge Gained

CV SALTS LEADERSHIP GROUP CV SALTS EXECUTIVE COMMITTEE Steering Committee Executive Membership Representing Salt and Nitrate Stakeholders CV Salinity Coalition (CVSC) Federal, State Agencies and NGOs CV SALTS EXECUTIVE COMMITTEE Initiative Leadership Maximum of 30 members CVSC Chair + members Up to 18 members Up to 6 members Committee Chairs Committees Members representing stakeholders (including State and Regional Board staff) Public Education and Outreach Economic and Social Cost Technical Public Policy Funding Regional Regional Subcommittees: Lower San Joaquin River Others Technical Subcommittees: BMP Assessment/Evaluation Communication Flow and Makeup

Stakeholders are Organized Central Valley Salinity Coalition, (CVSC) Stakeholder involvement and ownership Better addresses all needs and concerns Utilize everyone’s efforts & resources more efficiently and effectively Funding for elements of CV-SALTS Basin Plan - based on better data - more effective 27 March 2012

Central Valley Salinity Coalition Members Tulare Lake Drainage District County of San Joaquin City of Stockton Stockton East Water District The Wine Institute City of Tracy California Rice Commission City of Manteca City of Modesto San Joaquin River Group City of Vacaville City of Fresno Dairy CARES/Western United Dairymen California Association of Sanitation California League of Food Processors Tulare Lake Basin Water Storage District San Joaquin Valley Drainage Authority Iron House Sanitary District Discovery Bay Community Services Sacramento Regional County Sanitation Pacific Water Quality Association Los Angeles County San District Western Plant Health Association East San Joaquin Water Quality Coalition

Central Valley Salinity Coalition 24 Member Benefit Non-Profit Coalition of Central Valley Water users Contributed $1,007,000 to date Plus In-Kind Representing Water and wastewater Agricultural producers and processors Industry groups Others Developing and funding studies, planning and implementation efforts as match to other funding sources

Funding and Fundraising CVSC Member Funding State Water Board Cleanup and Abatement Project Contributions In-Kind Contributions

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Stakeholder Expenditures HANDOUT 27 March 2012

Cleanup and Abatement Funding Approximately $700,000 expended Approximately $1.5 M Contracted Approximately $1.2 M in awards over summer

Funding and Expenditures 27 March 2012

Financial Impacts of Salt & Nitrate Central Valley pays for Salt $544 million per year Impacts to Industry and communities Impacts to the local economies California pays for Salt If not for CV-SALTS work UC Davis estimates $1.5B in annual impacts statewide Loss of agricultural production Loss of tax revenue and increased unemployment We are contracting and spending a lot of money but, put it pales in comparison to the amount of economic cost. More than 1.5 million tons of salt are deposited in the Central Valley each year at an estimated annual cost of $544 million to residents and industry, according to a 2009 study by U.C. Davis, “Economic Impacts of Central Valley Salinity.” If nothing is done to address the situation, the study forecasts direct costs associated with salinity tripling to $1.5 billion a year statewide by 2030.

Daniel Cozad, CV-SALTS Program Manager Strategy/Framework and Approach Workplan and Milestones

Strategy and Framework Summary of Approach Approved Workplan Milestones SNMP Draft Delivered by May 2014 to Regional Board Basin Plan Amendment Completed in 2015

Strategy and Framework Revise Regulatory Structure Beneficial Uses; Water Quality Objectives; Policies Revise Basin Plan Develop Policies and Procedures to: Evaluate Compliance Provide Regulatory Flexibility Provide basis for short and long-term management of salts and nitrate at appropriate geographic scales

Key Work Areas Regulatory Planning CV-SNMP Master Plan Development Regulatory structure and policies to support basin-wide S/N management CV-SNMP Master Plan Development Creates framework for implementation SNMP Implementation Provides basis and process for future development of area-specific SNMPs *A Plan Within a Plan*

Work Plan 3 Goals 7 Major Work Elements Regulatory Planning SNMP Master Plan SNMP Implementation 7 Major Work Elements The State Recycled Water Policy requires the adoption of a Salt and Nutrient Management Plan (SNMP) for the Central Valley. To fulfill this requirement, CV-SALTS adopted a Strategy & Framework that (1) establishes a strategy for fulfilling this state requirement, and (2) a framework from within which work would be executed in the following three areas: 1. Regulatory Planning - Establishes the regulatory structure and policies within the Basin Plan to support basin-wide salt/nutrient management; 2. CV-SNMP Master Plan Development – Creates the framework, technical studies, planning and procedures for a basin-wide and regional approach to salt/nutrient management through the adoption of a CV-SNMP and implementation of required elements including monitoring and reporting; 3. SNMP Implementation – Provides basis and process for future development of regional or sitespecific salt/nutrient management plans or future modification of beneficial uses (BUs) or water quality objectives (WQOs) consistent with the adopted regulatory structure and policies.

Conceptual Model Policy Master Plan Implementation

Workplan Supports Policy Decisions

Detailed Critical Path Schedule Detailed Critical Path Scheduled prepared Parallel Tasks Early Critical Tasks Policy Decisions Conceptual Model Technical work Implementation Planning

CRITICAL TASK

Selected Critical Milestones

Costs $$ How Much Who/Where

CV-SALTS Workplan and Status Well Planned Work well underway Produce a Draft SNMP by May 2014 2015 Final Funding largely in place Stakeholder participating Implementation will need funding

Regional Board Questions/Discussion/Feedback Are we headed in the right direction? Are any important issues missing? Feedback Additional Questions:

Parry Klassen, Exec. Comm. Chair Current Implementation and Policy Efforts

Current Implementation Early Implementation Commitment Management Practice BMP Toolbox Management Practices approval Process for review and approval Approved Management Practices

Management Practice Toolbox Purpose Process Review of practices Utility of toolbox Footer goes here if you want (can be turned off) 5/2/2019

Practices Under Review Collections of Practices Wine Institute Manual of Practice for salt and nutrients California League of Food Processors Manual of Practice for salt and nutrients 4-R Plant Nutrition On-Farm Nitrogen Management Individual Practices Dairy Feed Management Practice Potassium for Sodium Hypochlorite substitution 5/2/2019

Practices Under Review Nitrate Issues Status in CV-SALTS Collaboration - Counties and communities - SOAC Identification, development and implementation Provide community support upon recommendation BPA to support compliance offset 5/2/2019

Tim Moore, CV-SALTS Policy Facilitator Addressing Difficult Questions Charting a path Archetypes and prototypes Decisions to date Decisions in progress

Policy Discussions I. What's so hard about writing a Salt and Nitrate Management Plan? A) Compare existing water quality to objectives B) Develop implementation plan to achieve objectives C) Conduct long‐term water quality monitoring D) Do it in a "locally‐driven and controlled collaborative process"

Policy Discussions II. Elements of the traditional water quality regulation model A) Waterbodies B) Uses C) Objectives D) Discharge limitations

Policy Discussions III. Groundwater is different A) Difficult to describe: 3‐dimensional layers of water quality B) Difficult to measure/model: uncertain fate and transport C) Difficult to control: defuse non‐point sources and legacy effects

Policy Discussions IV. Outcome‐oriented decisions A) Assuring the use B) Balancing competing uses; the zoning metaphor C) Recognizing reality (historic loading to the vadoze zone)

Policy Discussions V. Nitrates in groundwater A) Well‐defined water quality objective B) Regulatory alternatives: discharge prohibitions, remediation requirements C) Compliance options: offsets and alternative supply projects

Policy Discussions VII. Archetypes and Prototypes: Test Cases for Collaboration A) Ag Drains (Live Oak, Willows, Colusa, Biggs) B) Tulare Lake basin C) EDC project D) WDR monitoring program for rice E) Lower San Joaquin River

Policy Discussions Decisions in progress Policy Discussions How topics relate to ongoing Water Board programs Schedule of discussions Offsets MUN Tulare Lake Lower San Joaquin River II. Elements of the traditional water quality regulation model A) Waterbodies B) Uses C) Objectives D) Discharge limitations III. Groundwater is different A) Difficult to describe: 3‐dimensional layers of water quality B) Difficult to measure/model: uncertain fate and transport C) Difficult to control: defuse non‐point sources and legacy effects IV. Outcome‐oriented decisions A) Assuring the use B) Balancing competing uses; the zoning metaphor C) Recognizing reality (historic loading to the vadoze zone) V. Nitrates in groundwater A) Well‐defined water quality objective B) Regulatory alternatives: discharge prohibitions, remediation requirements C) Compliance options: offsets and alternative supply projects VI. Salinity in groundwater A) Narrative objective and site‐specific translators B) Economic impairment as a special case C) Defining "reasonable protection" VII. Archetypes and Prototypes: Test Cases for Collaboration A) Ag Drains (Live Oak, Willows, Colusa, Biggs) B) Tulare Lake basin C) EDC project D) WDR monitoring program for rice E) LSJR Dennis’s were Prior steps and actions Direction from State Board South Delta work Work to be done as part of CV-SALTS

Anticipated Outcome: Ability to fold in more area specific plans as needed Utilize Master CV-SNMP as default management approach Periodic updates to include area-specific SNMP in the future Utilize process templates from master plan Area-specific SNMPs Archetypes Prototypes 27 March 2012

Regional Board Questions/Discussion/Feedback Do these areas address important issues for the Board? Are any important issues missing? Feedback

Public Comment Questions/Discussion/Feedback

Jeff Willett, Exec. Comm. Vice Chair Summary and Closing

Summary and Closing Tim will Provide Revised slide! On the road to a successful process Significant progress Significant work underway How this comes together for a sustainable Central Valley future Path to follow for dealing with difficult issues and making difficult choices successfully Tradeoffs to gain best use of limited funds Long term benefits for the Central Valley