Original Vision, Purpose and Mission 7/2/2019

Overview Regional Salt Issues Role of Regulation Options CV-SALTS Vision Purpose Mission Note that this presentation is from the perspective of the Regional Board and based in a large part on the issues and decisions that resulted in the initiation of CV-SALTS in 2006. 7/2/2019

Salt Issues 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 Sacramento River San Joaquin River Delta Two of our basins, the Sacramento and San Joaquin River Basins, are covered under one Water Quality Control Plan as both have a natural outlet to the ocean through the Sacramento-San Joaquin Delta Estuary and San Francisco Bay. Water development however has changed the rate and routing of flow and salt from these basins.   Tulare Lake 7/2/2019

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. Because of this, it is covered under a separate Water Quality Control Plan. Finally, because of the importance of the Sacramento-San Joaquin Delta Estuary to the natural environment and economy of California, The Bay-Delta is governed by its own Water Quality Control Plan. The Bay-Delta provides drinking water to two-thirds of the State’s population and water supply for agricultural areas both in the Delta and beyond. 7/2/2019

(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. 7/2/2019

Salt Issues Increasing salt concentrations (including NO3) in groundwater threaten drinking water Particularly areas with: Irrigated agriculture Dairies Septic systems 7/2/2019

Salt Issues USGS Eastern San Joaquin and Sacramento Valley Studies: Groundwater TDS concentrations increased significantly since the 1950’s throughout most of the Sacramento Valley Nitrate concentrations significantly increased in well water sampled between 1986 and 1995 Nitrate concentrations in about one fourth of the domestic water-supply wells sampled in the eastern San Joaquin Valley exceeded the USEPA drinking-water standard. 7/2/2019

Salt Issues Water used for dilution is (usually) water lost to other uses 7/2/2019

Activities Contributing to the Salinity Problem Agricultural Water Users Urban Water Users Rural Water Users Environmental Water Uses Industrial Users 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. These factors are: Agricultural crop production can potentially be impacted any time supply water salinity exceeds optimal concentrations. Agricultural use of surface water contributes to salinity increases by consumptively using water that could otherwise provide dilution, and leaving the salt behind. Also, irrigation can mobilize salts in saline soils. And, fertilizer application whether used in agriculture or by urbanites also contributes to the overall salinity problem, since fertilizers contain salts. Most urban water users in California do not typically receive water with salinity levels that could cause a health concern. Salinity generally impacts this group in the form of increasing costs for treatment. High salinity can accelerate corrosion in plumbing and water-using appliances. In addition to the discharge of human wastes, urban water users contribute to salinity problems by adding salt by operating water softeners, fertilizing lawns, using soaps and detergents, etc; and consuming water, which reduces the amount of water available for downstream dilution. The water supply for most rural areas in the Central Valley is groundwater. These users are particularly vulnerable to changes in groundwater quality. Rural water users, like urban and agricultural users, contribute to Valley salinity problems by adding salt and consuming water. The environmental uses of water vary in their sensitivity to salinity, but the actual impact of salinity on Central Valley fish and wildlife or aesthetic and recreational use is generally not well defined. The need for adequate non-toxic freshwater flows of suitable temperature at the right time of the year has dominated the research in this area. Environmental water use also contributes to salinity increases by consumptively using water that could otherwise provide dilution, and leaving the salt behind. Industrial water users face increased pretreatment costs when salinity in the water they use is high. Potentially, the salinity of the water supply could be a factor in a company’s decision to invest in or continue operations of a Central Valley facility. Industrial discharges are primarily point source contributions and point sources can be regulated to control salinity impacts. However, compliance with salinity regulations is seldom cheap or technically easy to achieve. Water providers include the irrigation districts and water authorities that route water to all the aforementioned groups. Salinity impacts show up in the costs these entities incur and pass on to their customers to protect their systems from corrosion and provide the quality of water needed by their customers. Water providers in some cases contribute to salinity problems through water transfers that benefit one area at the expense of dilution flows in another. This is a complex subject in which impacts are very specific to the transfer since some transfers can improve water quality. 7/2/2019

Salinity Impairments in Surface and Groundwaters Exacerbated locally from many sources including: Discharges to land associated with municipal wastewater disposal Septic tanks Oil field brines Confined animal facilities Food processors Salinity impairments in surface and ground water are also exacerbated locally from other sources including the sources shown of the slide: discharges to land associated with municipal wastewater disposal (from about Madera south the final disposal of almost all municipal wastewater is land), septic tanks (found throughout the Central Valley good examples exist where significant impacts occur because of long-term use of septic tanks), oil field brines (mostly found in the oil producing regions of Fresno and Kern Counties), confined animal facilities (dairies are the most prevalent example throughout the Central Valley but the concentrations of milk cows are in Kern, Tulare, Kings, Merced, and Stanislaus Counties), and food processors (located mostly on the east side of the Central Valley). 7/2/2019

Salt Issues 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 Based on Economics Report 7/2/2019

Salt Issues If the Region does not change it’s approach to salt, by 2030… Direct annual costs anticipated to range between $1to 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 Economics Report 7/2/2019

Role of 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. 7/2/2019

Role of 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. 7/2/2019

Role of Regulation WDRs: Authorize Waste Discharge Can Include: - Limits on salt concentrations - Limits on salt loads (amount of salt) - Total prohibition of discharge Can also Require: - Studies and reports - Implementation of salt control practices 7/2/2019

Most sections of the current Role of 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. 7/2/2019

Role of Regulation Results: Limited data available for staff to interpret water quality objectives and implement the Basin Plans Over time, salt 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 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.  7/2/2019

Role of 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. 7/2/2019

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. 7/2/2019

Elements in Salinity Planning and Management Traditional Staff Driven Final design Construction Operation (must comply With Basin Plan) Draft Basin Plan Amendment Adoption & approval Implementation Review- -Beneficial Uses -Water Quality Objectives -Implementation program Define scope Of project Identify alternatives Evaluate alternatives -technical analysis -economic analysis -environmental analysis Assess Regulatory Framework Staff uses available data Requires significant assumptions Staff conducts scoping meetings Staff develops amended plan and staff report These documents subject to public review & comment Dischargers implement resulting program Water Board Effort Discharger Responsibility **Note public comment periods during Basin Planning Process** 7/2/2019

Elements in Salinity Planning and Management Collaborative Effort Final design Construction Operation (must comply With Basin Plan) Draft Basin Plan Amendment Adoption & approval Implementation Review- -Beneficial Uses -Water Quality Objectives -Implementation program Define scope Of project Identify alternatives Evaluate alternatives -technical analysis -economic analysis -environmental analysis Assess Regulatory Framework Stakeholders work collaborative between groups and Regional Board Help frame, guide and manage project Conduct studies and provide resources Before amendment drafted Collaborative Effort Water Board Responsibility Discharger Responsibility **Note public comment periods during Basin Planning Process** 7/2/2019

Advantages to Collaborative Approach Basin Plan - based on better data - more effective Stakeholder involvement and ownership Better addresses all needs and concerns Protects water quality Utilize everyone’s efforts & resources more efficiently and effectively 7/2/2019

CV-SALTS: Beginnings January 2006: Joint SB/RB5 meeting Food processor permit concerns Westside ag drainage History lesson from Center for Water Resources NRCS toolbox 7/2/2019

CV-SALTS: Beginnings January 2006: Joint SB/RB5 meeting Food processor permit concerns Westside ag drainage History lesson from Center for Water Resources NRCS toolbox March 2006: Request for state funding 7/2/2019

CV-SALTS: Beginnings January 2006: Joint SB/RB5 meeting Food processor permit concerns Westside ag drainage History lesson from Center for Water Resources NRCS toolbox March 2006: Request for state funding May 2006: Release of staff report and creation of a salt task force and working committees Central Valley Salinity Policy Group (2007), now known as the Central Valley Salinity Leadership Group 7/2/2019

CV-SALTS Launch $1 Million from State Board to our Board Economic study Metadata report Educational Video Strategy Committees formed Exec, TAC, Econ/Soc Impact, Public Ed & Outreach Initial tasks were to provide input on implementation of contracts 7/2/2019

Original Vision Collaboratively develop and implement a viable Salinity Management Plan for California’s Central Valley to: sustain the Valley’s lifestyle, support regional economic growth, retain a world-class agricultural economy, maintain a reliable, high-quality urban water supply; and protect and enhance our local environment. Developed and proposed to State Board in 2006 7/2/2019

Original Vision Salinity Management Plan Components: A comprehensive evaluation of water quality data, water and wastewater management options and policies Potential measures that can be implemented to better manage salinity Fully developed and evaluated interim and long-range salinity management plans 7/2/2019

Original Purpose Primary Outcome of Planning Phase: Update of the Basin Plans Beneficial Uses Water Quality Objectives Implementation Actions and Timelines 7/2/2019

The Original Mission Develop a comprehensive regional salinity 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 7/2/2019

Work to be Accomplished Review of existing conditions through data collection & analysis Identification of data gaps Development of new information required to conduct assessment of alternatives Review of salinity treatment, management and disposal options Work that must be accomplished includes: review of existing conditions through data collection and analysis, identification of data gaps, development of new information, as necessary, to conduct assessment of alternatives, review of salinity treatment, management and disposal options, review of existing policies and programs, 7/2/2019

Work to be Accomplished Review of existing policies and programs Review of alternative local and regional management options, including economic and environmental assessments Development of revisions for the basin plans Adherence to the many requirements of the CEQA and Water Code process, including public outreach and stakeholder involvement Work that must be accomplished includes: review of alternative local and regional management options, including economic and environmental assessments, development of revisions for the basin plans, adherence to the many requirements of the CEQA and Water Code process, including public outreach and stakeholder involvement, 7/2/2019

Work to be Accomplished Consideration for approval of the eventual proposed Basin Plan revisions by the CVRWQCB & the SWRCB Processing of the proposed Basin Plan revisions approved by the CVRWQCB and the SWRCB through the Office of Administrative Law Work that must be accomplished includes: consideration for approval of the eventual proposed Basin Plan revisions by the Central Valley Regional Water Quality Control Board (CVRWQCB), and the consideration of the proposed Basin Plans approved by the CVRWQCB by the State Water Resources Control Board (SWRCB), and The processing of the proposed Basin Plan revisions approved by the CVRWQCB and the SWRCB through the Office of Administrative Law. 7/2/2019

Included Assignments Address the requirements of the State Recycled Water Policy Develop salt objective(s) for the San Joaquin River between Sack Dam and Vernalis Address irrigation-related salt issues 7/2/2019

Included Assignments Be responsive to salt management concerns of the region’s economically disadvantaged communities Develop a methodology for evaluating salt management practices Review SEP proposals when asked Pamela—somewhere in here should it be noted that CV-SALTS is to be the umbrella coordination effort for all our salt and nitrate issues? Or is that discussed in the afternoon session when we want to talk about “successful outcomes”. I’m not clear is that concept was part of the original vision or evolved at a later date. (The concept was not in Karl’s original 2006 presentation.) 7/2/2019

Review, update, confirm vision/purpose/mission Today. . . . Review, update, confirm vision/purpose/mission Identify the activities needed to accomplish the mission and the process that will be utilized to insure the activities are completed. 7/2/2019

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Role of Regulation Current efforts regulating salt: Water Quality Plans Salt/Boron TMDL for Lower SJ River Irrigated Agriculture Waiver Existing Dairy General Order Implementation of stricter limits and requirements in permits Moving toward RO in some areas The basic tools we have used in the past to regulate salt are shown here. The first of these tools is the Basin Plan. 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. As I said earlier, the primary tool the Regional Board has for addressing problems such as salinity is the Basin Plan. 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. Another tool used for regulating salinity is the water quality objective. Water quality objectives are the numeric 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. A third 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. 7/2/2019

Issues The salt problem is getting worse Central Valley communities are not well organized and many are economically disadvantaged If the problem is addressed solely through regulatory controls, Central Valley dischargers may be tasked with resolving salt problems they are only partially responsible for The salt problem is getting worse 7/2/2019

Early CV-SALTS Projects The first $1 million Strategy report View from 30,000 ft Educational Video Raise general public awareness Metadata report Begin to identify salt data resources Economic Study Life in 2030 without regulatory change (No Project alternative from a regional economic perspective) 7/2/2019

Schedule concerns Tick, tick, tick… Upstream Objective Already late Recycled Water Policy Feb 2013 / 2015 stakeholder plan Feb 2014 / 2016 Board adoption Other Review cycles Irreversible damage OTHER: Board orders are updated periodically. Current BP objectives will drive salt limits in permits, so even if the BP is amended with new objectives in Feb 2014, a permit written in Jan 2014 will rely on the older objectives until it comes up for renewal, probably not before 2019. (if the group is going to be informed that CVCWA/Betty are looking into getting a variance from EPA, you may also want to mention that variances are limited duration) Salt damage prevention will likely be easier and cheaper than salt damage remediation. 7/2/2019

Recently Completed and Current Projects Salt Source Survey [study completed, analysis underway] 3 study areas (Yolo, Tule Lake & Modesto areas) Funded by CVSC Beneficial Use and Objectives Study Phase I [near completion] funded by state CAA funds Phase II to be funded by CAA with CVSC match 7/2/2019

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CV-SALTS Participants Leadership Group (CVSLG) Decision-makers from Fed, state and local government (including SB, RB5, RB2 & RB8) Water purveyors (districts and district groups) Water associations Industry and ag organizations Social and environmental justice groups Research institutions 7/2/2019

CV-SALTS Participants State Water Resources Control Board Board members (CVSLG) Management (Executive Committee) Central Valley Regional Water Quality Control Board Board members (CVSLG, Executive and other committees) Management (Exec and other committees) Staff (Committees) Diagram describes voting and non-voting members 7/2/2019

CV-SALTS Participants Central Valley Salinity Coalition (CVSC) 501c6 organization formed in 2008 to fund and facilitate the CV-SALTS effort Other interested Parties CV-SALTS meetings are open to the public 7/2/2019

Role of the Central Valley Salinity Policy Group Members represent cross-section of stakeholders having interest in mitigating salinity impacts to Central Valley waters Critical role in providing advice & direction on – the development and conduct of studies, the development of revisions to the basin plans, and the CEQA process Role of the Central Valley Salinity Policy Group: The Central Valley Salinity Policy Group (CVSPG) members represent a cross-section of the stakeholders who have an interest in mitigating salinity impacts to Central Valley waters. The CVSPG has a critical role in providing advice and direction on the development and conduct of studies, the development of revisions to the basin plans, and the CEQA process. The CVSPG, as now envisioned, will meet no more than twice per year. Extensive use will be made of conference calls and e-mail for communications, especially as committees are formed and the work progresses to address focused issues. Diverse examples of these issues might be (1) data collection quality assurance and (2) management oversight for implementation of a salinity management plan. 7/2/2019

Role of the Central Valley Salinity Policy Group Management – Extensive use will be made of conference calls and e-mail Committees will be formed as work progresses to address focused issues Role of the Central Valley Salinity Policy Group: The Central Valley Salinity Policy Group (CVSPG) members represent a cross-section of the stakeholders who have an interest in mitigating salinity impacts to Central Valley waters. The CVSPG has a critical role in providing advice and direction on the development and conduct of studies, the development of revisions to the basin plans, and the CEQA process. The CVSPG, as now envisioned, will meet no more than twice per year. Extensive use will be made of conference calls and e-mail for communications, especially as committees are formed and the work progresses to address focused issues. Diverse examples of these issues might be (1) data collection quality assurance and (2) management oversight for implementation of a salinity management plan. 7/2/2019

Role of the Central Valley Regional Water Quality Control Board In accordance with the statutes and regulations governing its actions, continue to take the actions necessary to protect beneficial uses of the waters within the Central Valley Region Actively enforce policy-based criteria directed towards protection of beneficial uses of receiving waters from further degradation due to increasing salinity concentrations Role of the Central Valley Regional Water Quality Control Board: The Central Valley Regional Water Quality Control Board (Board) is actively enforcing policy-based criteria directed towards the protection of beneficial uses of receiving waters from further degradation due to increasing salinity concentrations.   While the Salinity Management Plan and the requisite CEQA process are pursued, an effort that will require nearly a decade, the Board must, in accordance with the statutes and regulations governing its actions, continue to take the actions necessary to protect beneficial uses of the waters within the Central Valley Region. Dischargers are expected to take the necessary interim measures required for the significant reduction of salinity discharges from their facilities into the ground and surface waters of the Central Valley. The Board encourages all dischargers to work cooperatively with the Board towards the development of a Salinity Management Plan that implements those measures that will both protect beneficial uses of Central Valley waters and provide economically feasible means for salinity control. 7/2/2019

Expectation of Dischargers Take the necessary interim measures required for the significant reduction of salinity discharges from their facilities into the ground and surface waters of the Central Valley Support the development of long-term solutions Role of the Central Valley Regional Water Quality Control Board: The Central Valley Regional Water Quality Control Board (Board) is actively enforcing policy-based criteria directed towards the protection of beneficial uses of receiving waters from further degradation due to increasing salinity concentrations.   While the Salinity Management Plan and the requisite CEQA process are pursued, an effort that will require nearly a decade, the Board must, in accordance with the statutes and regulations governing its actions, continue to take the actions necessary to protect beneficial uses of the waters within the Central Valley Region. Dischargers are expected to take the necessary interim measures required for the significant reduction of salinity discharges from their facilities into the ground and surface waters of the Central Valley. The Board encourages all dischargers to work cooperatively with the Board towards the development of a Salinity Management Plan that implements those measures that will both protect beneficial uses of Central Valley waters and provide economically feasible means for salinity control. 7/2/2019

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