By Jane Sooby
The August 21, 2025, meeting of the Central Coast Regional Water Quality Control Board was devoted mostly to discussion on developing an Alternative Water Supply Program (AWS). The meeting, characterized as the first “public workshop” on the AWS, was held at the Central Coast Water Board office in San Luis Obispo and livestreamed via Zoom.
The meeting opened with information from regional board staff followed by presentations from the Ag Partners (who represent agricultural operations in the Central Coast region), then environmental justice representatives, and ended with public comments. Members of the regional water board also participated in the conversation.
Developing an AWS was a mandate that the State Water Board included in its 2023 “Remand Order” that nullified portions of the Central Coast region’s Irrigated Lands Regulatory Program (ILRP) 2021 Agricultural Order (Ag Order), sending it back to the regional water board for revisions to make it consistent with the State Water Board’s “precedential” nitrogen (N) reporting requirements.
The Remand Order directed the Central Coast Regional Board to incorporate a requirement or reach an agreement in which dischargers or their third-party representatives provide short-term and long-term alternative water supplies for residents relying on groundwater in areas where the maximum contaminant level (MCL) for nitrate is exceeded as a result of agricultural operations.
The Remand Order contained other directives and also stated the State Water Board’s intent to assemble a Second Expert Panel to evaluate and make recommendations on the statewide ILRP. (Read articles on the first and second days of the Expert Panel’s “Kick Off meeting.”)
Regional Water Board Staff Presentations
Central Coast Water Board Executive Officer Ryan Lodge opened the public workshop by noting that the regional board has been working on the issue of nitrate contamination of groundwater for nearly 20 years through regulations in the ILRP yet the impact of excessive nitrate discharges is still significant: 28% of wells in the region exceed the MCL for nitrate with up to 50% of households affected in some areas.
Lodge outlined the health risks posed by elevated nitrate levels in drinking water and the costs incurred by households that must purchase bottled water. He noted that it will take time to realize the benefits of reduced nitrate loading to groundwater through the ILRP.
Mary Hamilton, Central Coast Water Board’s Environmental Program Manager, outlined the public engagement process they will use to develop the program and introduced the two documents currently open for public comment: the assessment of interim drinking water needs and costs and the conceptual structure for the AWS. Both of these documents are open for public comment through Sept. 9. Click here for information on how to comment.
James Bishop, Central Coast Water Board Senior Engineering Geologist, explained that the Assessment of Interim Drinking Water Needs and Costs is needed to estimate the number of people and households affected by nitrate contamination of their well water as a result of agricultural activities and the cost needed to provide them with interim alternative water supplies. He noted that a long-term cost analysis is more complicated and will be presented at a later date.
Bishop described the limitations of the assessment and noted that it includes assumptions about water quality, treatments, and costs. He reviewed the methodology, which is a modified version of the methods used to develop the statewide California Drinking Water Needs Assessment.
Using a crop mapping data set, the Statewide Aquifer Risk Map, Public Land Survey System data, and State Water Board data on public water systems, they estimated there are 3,005 domestic wells, 117 state small water systems, and 17 public water systems in the Central Coast region that exceed the MCL for nitrate. Using the most recent U.S. Census data, they calculated the total impacted population to be 14,039 people, 61% of them on domestic wells and 15% being a member of a disadvantaged or severely disadvantaged community.
Bishop reported that the three interim water solutions considered were bottled water (BW), point-of-use at faucet using reverse osmosis (POU), and point-of-entry into the home via granular activated carbon (POE), a solution that is included if the water includes co-contaminants that can be inhaled or absorbed through the skin.
They modeled costs of BW only, BW + POU, and BW+POU+POE over three duration lengths: 3, 5, and 10 years. Though providing bottled water had lowest initial costs, the most economical solution over 10 years was BW + POU, totaling $6.4 million annually. POE has the highest cost because water treatments must be customized to the specific co-contaminants in the water, requiring additional costs to identify and then treat the co-contaminants.
BW = bottled water; POU = Point of Use | POE = Point of Entry
Additional costs–including program administration, outreach, long-term planning, and water quality sampling—are projected to total $400,000 annually.
Hamilton then presented an overview of the Conceptual Program Elements. She first reviewed the requirements for the AWS put forth in the State Water Board’s Remand Order, including that
- dischargers provide both short-term and long-term AWS to residents in the region who rely on groundwater that exceeds the MCL for nitrate as a result of agricultural operations
- the regional board take into account the experience gained through other alternative water supply programs
- the regional board invite impacted communities, environmental justice organizations, other stakeholders, and State Water Board staff to participate in developing the program
- the regional board identify a regulatory mechanism to implement the program
Regulatory options considered include Basin Plan amendments, Cleanup and Abatement Orders for the provision of AWS, and incorporating the requirements into the Waste Discharge Requirements, known as the Agricultural Order or Ag Order.
Central Coast Water Board staff recommend that the Ag Order be amended to include a phased approach to the AWS through two compliance pathways: one for participants in the AWS and one for those who don’t participate in the AWS. They are also considering an exemption from AWS for growers who are already providing alternative water supplies.
3P-ACP =Third Party Alternative Compliance Pathway | CAOs = Cleanup and Abatement Orders
Central Coast Water Board staff’s recommendation for the program’s funding mechanism includes at least partial funding by dischargers, with the remainder to be determined.
In selecting an AWS program administrator, staff recommend it be an independent organization that is eligible to apply for state water protection and other funds. They will require that the administrator report back to the regional board.
Hamilton also noted that because the State Water Board remanded use of the metric nitrogen applied minus nitrogen removed (A-R) as an enforceable metric from the Ag Order, the compliance timeline in the Ag Order was also invalidated, with the result that growers must immediately ensure their discharges don’t contribute to exceedances of water nitrate levels.
She once more called for public comment on the AWS conceptual structure and explained that it presents a series of questions on which they’d like feedback. She noted that preliminary comments had already been submitted by the Ag Partners and by environmental justice representatives. All written comments will be posted on the AWS Program website.
Ag Partners Presentation
Norm Groot, Executive Director of Monterey County Farm Bureau, and Abby Taylor-Silva with the law firm Kahn, Soares & Conway participated in person and Tess Dunham of Kahn, Soares & Conway joined via Zoom to present the Ag Partners’ AWS proposal.
Ag Partners propose a 10-year program focused on providing bottled water and in-home point-of-use systems to residents whose domestic drinking water well exceeds the MCL for nitrate as a result of agricultural operations. They distinguished their plan from that presented by staff as emphasizing incentives instead of disincentives for complying.
They also identified areas of alignment with regional water board staff including the two compliance pathways, securing an independent administrator, protection from new Cleanup and Abatement Orders for those already in the AWS program, and that dischargers fund the program with an “agreed upon scope.” They put forth the third party in the Central Coast region, Preservation, Inc., as a trusted administrator for the program.
Environmental Justice Representatives Presentation
Kjia Rivers, Senior Policy Advocate with the Community Water Center, urged the board to take special note of comments presented later by community leaders. She endorsed the Safe and Affordable Funding for Equity and Resilience program (SAFER) as the administrator for the AWS, stating that it is a known and trusted community partner with a record of improving water quality in impacted communities. She also recommended that the program be developed to align with SAFER.
Elias Rodriguez, Staff Attorney for California Rural Legal Assistance, supported the idea that dischargers who do not participate in the AWS program should be subject to clean-up and abatement orders but argued they not be given a 10-year timeline to comply with discharge targets, stating, “Anyone contributing to harm should be held responsible immediately.”
He expressed concern over fees imposed on disadvantaged growers and suggested that fees be linked to the amount of nitrate discharged from a grower’s fields.
Public Comment
Sarah Lopez, Executive Director of Preservation, Inc., the third-party entity in the Central Coast region that helps farmers comply with the Ag Order, described Preservation, Inc.’s monitoring, reporting, education, and outreach activities on behalf of growers enrolled in their program. She noted that they test more than 4,000 wells annually including around 2,000 on-farm domestic wells.
Other commenters included representatives of impacted communities who spoke about the negative health impacts of high-nitrate drinking water and their experiences receiving bottled water. Some were on a bottled water program that was discontinued by the Salinas Basin Agricultural Stewardship Group but then resumed by the Community Water Center.
Isabel Morales siad the Bottled Water Program removed the challenges of not always having the means to transport the water from the distribution point to homes in the last 2-3 years she has been a part of it. She stated that they don’t always receive enough water because they use it for cooking, washing, and drinking. Morales ended by saying that the bottled water program is not a long-term solution for them.
Most commenters expressed the need for immediate action and long-term solutions, and many of them expressed support for SAFER as the program administrator.
Next Steps
The Central Coast Water Board plans to hold a second public workshop and accept public comments in early 2026, then convene a third workshop or board hearing including public comment in fall 2026.
