In 2006, the Central Valley Regional Water Board launched the Central Valley Salinity Alternatives for Long-Term Sustainability (CV-SALTS) program to tackle the growing issue of nitrate and salt contamination in groundwater and wells across the region. This collaborative initiative brings together regulators, agricultural and industrial dischargers, municipal wastewater agencies, and environmental and environmental justice organizations to develop and implement sustainable solutions. The program’s overarching goals are to support the San Joaquin Valley’s agricultural economy, ensure access to safe drinking water, and protect the environment.
CV-SALTS focuses on two critical areas: long-term salinity management and nitrate management. A key emphasis is placed on providing safe drinking water to communities in high-priority areas of the San Joaquin Valley, where nitrate contamination poses significant health risks. On October 21, representatives from the Central Valley Regional Water Board and the Central Valley Salinity Coalition presented the sixth annual progress report to the State Water Board, offering updates on the program’s advancements and ongoing efforts.
SALT CONTROL PROGRAM
The Central Valley plays a critical role in producing food for California, the nation, and the world. However, over the past 150 years, agricultural, industrial, and municipal activities, combined with population growth, have significantly increased salt levels in soils, groundwater, and surface waters. Excessive salt levels can degrade water quality, reduce crop yields, impact drinking water supplies, and harm ecosystems. Currently, 250,000 acres have been removed from production, and 1.5 million acres are classified as salinity-impaired. Without action, the economic impact of salinity on the Central Valley could exceed $3 billion annually.
The Salt Control Program was established to address the long-term challenge of salt accumulation in the Central Valley. Its goal is to protect beneficial uses by maintaining water quality that meets applicable standards, allowing controlled salt accumulation in areas where it will not impair water uses, and, where feasible and practicable, restoring water quality through long-term management. Rachel Gray, Incoming Executive Director of the Central Valley Salinity Coalition, provided an update on the work that’s been conducted to date to implement the salt control program.
The program is in the first of three phases. Phase One focuses on the Prioritization & Optimization (P&O) Study, which aims to identify salt-sensitive areas, evaluate salt sources and impacts, explore management options, and develop long-term salt management strategies.
Findings from Phase One will guide Phases Two and Three. Phase Two will involve project development, including engineering design, environmental permitting, and potential regulatory actions, such as basin plan amendments or beneficial use dedesignations for future salt management areas. Phase Three will focus on implementing these projects, including the construction of selected physical solutions.
One outcome of the P&O study is the development of a salinity management plan for the Central Valley. The plan will identify where long-term solutions are needed to protect current and future beneficial uses, so it’s important to understand which sensitive beneficial uses are currently in place and which will be in place in the future. The most sensitive beneficial uses are salt-sensitive crops for agriculture and drinking water.
The program is taking a methodical approach, characterizing conditions as accurately as possible to identify cost-effective, implementable solutions. Integral to this plan is engaging with local stakeholders to obtain information to be included in the modeling tools.
Archetypes used to develop initial targets
The Delta Mendota Subbasin and the western portion of the Kings Subbasin were selected as archetypes due to their diverse conditions, including differing levels of reliance on surface water and groundwater. These archetypes were used to establish salinity targets for applied water quality, followed by modeling analyses to project how salinity levels might change over time and assess whether those targets could be achieved under future scenarios.
The analysis shows that salinity targets are generally expected to be met under current and future climate scenarios. However, in the Farmers Water District, a small groundwater-dependent area in the Delta Mendota subbasin, salinity issues are projected under future conditions. In contrast, the northern portion of the Western Kings Subbasin, with more surface water availability, is not expected to face salinity challenges.
“Our focus is applied water quality, because that’s what’s practically being applied to our crops, or that’s what is being used as our drinking water supply,“ said Ms. Gray. “So we’re focused on applied water quality and the conjunctive use of water, both surface and that combination of surface and groundwater. And with our tools, we’re able to predict future risks to current uses at a district level.“
Developing Central Valley-wide targets
A methodology was then developed to set salinity planning targets for the Central Valley, considering salt-sensitive crops, secondary drinking water standards (MCLs), and precipitation impacts.
Applied water quality was modeled for current conditions, 50 years, and 100 years on a GSA-scale level, and salinity planning targets were applied; the very preliminary results are shown on the slide. “If you look at the areas in the yellow, currently we’re okay,“ said Ms. Gray. “Current beneficial uses, we’re good. But in 50 years, we see some problem areas arise, and then in 100 years, even worse if we do nothing. This is our prioritized approach for identifying which areas projects would need to be implemented to deal with the salinity issues, so we can protect the current and future beneficial uses of water.“
She also noted that a technical study is underway to evaluate salinity treatment technologies, including both established and emerging options, to determine what technologies can be used in these specific areas that are both cost-effective and implementable. Findings will guide the next phase of the project.
Next steps
Next steps are to finalize the data and identify areas not projected to meet the salinity planning targets, have a technical review, and finalize the results. Once those areas are finalized, the next step will be determining the quantity of salt that needs to be removed from these areas to protect beneficial uses in the future. Additional pilot studies may be undertaken.
“We’re continuing to use existing information from all the different programs, and we’re coordinating with local stakeholders,“ said Ms. Gray. “We’re also focusing on brine disposal technologies, which is going to be a big issue for us, and then continuing development of the salinity management plan so that we can work to get into phase two of the implementation of the program, which is engineering design, feasibility, and funding, in hopes that we can then implement these projects.”
Patrick Palupa, Executive Officer of the Central Valley Water Board, said the data emerging from SGMA implementation and groundwater sustainability plans have been invaluable. “I don’t know how we would do this analysis without the data and information that’s collected under the groundwater sustainability agencies and their plans,“ he said. “The information that the technical teams have been able to pull out of the groundwater sustainability plans really is helping develop a united picture of what the challenges are for the next century.”
The pernicious problem of salinity in the San Joaquin Valley
Mr. Palupa noted that the water districts that are heavily groundwater-dependent face not only challenges under SGMA but also significant challenges from salinity. “Even if you have sufficient groundwater to ensure continuous crop production, I think the models, as they’ve been developed under CV-SALTs, show that that water is not going to be usable within a time horizon that is, in some cases, within our lifetimes, and certainly within the planning horizon of those farmers.”
He acknowledged that the work is sobering. A lot of folks had hoped that in-valley solutions would be enough to address salinity, since a brine export line comes with tremendous costs. “The work that’s been ongoing shows that it is going to be extraordinarily difficult to manage the salinity loading without an out-of-valley solution. The people who look at infrastructure in the Central Valley and the communities dependent on agriculture are starting to have the conversations that we will not have as productive of a valley if we do not figure out actual concrete infrastructure that will help us deal with this salinity problem. It is decades out before something like that gets built. It’s an urgent issue to communities, and it’s an urgent issue to the Central Valley as a whole.”
NITRATE CONTROL PROGRAM
Over the past 150 years, agricultural, industrial, and municipal activities have significantly increased nitrate levels in groundwater across the Central Valley. High levels of nitrate in drinking water can pose health risks. Nitrate is commonly found in fertilizers and waste discharges, which contribute to groundwater contamination. Many Central Valley residents rely on private wells for drinking water, and some of these wells contain unsafe levels of nitrate.
The Nitrate Control Program focuses on ensuring residents affected by nitrate contamination in their well water have access to safe, free drinking water. The program prioritizes areas based on the severity of the issue, with the most impacted areas addressed first (Priority 1), followed by less affected areas (Priority 2). Non-prioritized areas are managed on a case-by-case basis.
Wastewater dischargers in the Central Valley have two compliance options: adhere to traditional permitting requirements or join a management zone. A management zone is a defined geographic area where multiple nitrate dischargers, such as agricultural operations, dairies, and wastewater treatment facilities, work together to manage nitrate discharges and implement solutions to reduce contamination, while ensuring residents in the zone whose drinking water is impacted are provided with replacement water. This approach provides participants with additional time and flexibility to achieve nitrate reduction goals while prioritizing immediate access to safe drinking water.
The permittees who selected the individual permitting approach are currently being reviewed to determine whether they can meet the requirements of a traditional permit based on their nitrate discharge. A final determination on these facilities is forthcoming.
Priority Implementation
In 2020, the regional board issued notices to comply to the priority one management zones. Implementation of the program and early action plans, which include well testing and drinking water programs, began in 2021. In 2023, management zone implementation plans were submitted to the Central Valley Water Board. In November 2023, the Central Valley Water Board found the priority one Management Zone Implementation Plans (MZIPs) to be complete. The Board is now working on amendments to the permits to include enforceable requirements in consideration of the management zone implementation plans, or MZIPs.
Program implementation for Priority 2 areas began in December 2023, with notices to comply issued on February 26, 2024. Permittees in these areas were required to select a compliance pathway and submit a Notice of Intent. Early Action Plans were approved, and well testing and drinking water programs subsequently began. Final management zone proposals are due to the Board in February of 2026.
COMPLIANCE AND ENFORCEMENT
All permittees that discharge salt in the Central Valley must select either the traditional permitting approach or the alternative salinity permitting approach. Those who choose the alternative approach must pay a fee to support the P&O study. The most recent data indicate that approximately 11% of permittees subject to the program are noncompliant, meaning they either never selected a compliance pathway in response to the notice to comply or are not up to date on their P&O study fee payments.
The majority of the noncompliant permittees fall within the non-15 program and confined animal facilities program. The State Water Board’s non-15 program, also known as the Waste Discharge Requirements (WDR) Program, regulates point-source discharges of waste to land that don’t require full containment, aren’t confined animal facilities, and don’t involve discharges to U.S. surface waters under the NPDES program. This program issues Waste Discharge Requirements (WDRs) to protect both surface water and groundwater from pollution.
For the nitrate control program, approximately 14% of active permittees required to comply with the program are considered noncompliant. Of the 271 noncompliant facilities, the majority are confined animal facilities, followed by non-15 program facilities.
The confined animal facilities program identified permittees that haven’t responded to the initial notices to comply with both salt and nitrate control programs, and notices of violation (NOV) were sent to these permittees in November and December of last year, and again in February of this year. The number of NOVs sent for each program is presented in the table. The confined animal facilities program is currently coordinating with the Office of Enforcement on next steps.
Compliance and enforcement staff continue to address permittees that have not yet responded to the initial notices to comply with the programs. Enforcement support was provided for enrollment and compliance with the CV-SALTS program, including discussions of progressive enforcement for enrollees who were not making progress in compliance. Enforcement actions for the CV SALTS program are prioritized for this fiscal year, and written enforcement communications to noncompliant permittees are in development.
MANAGEMENT ZONE IMPLEMENTATION EFFORTS
Tess Dunham, representing the Central Valley Salinity Coalition, provided an update on the implementation efforts of management zones under the Nitrate Control Program. Management zones have been established in both Priority 1 and Priority 2 areas and operate under formal agreements among permittees. Their primary objectives are to provide immediate access to safe drinking water, reduce nitrate impacts on groundwater, and implement long-term strategies to restore groundwater quality.
To support these efforts, the management zones have developed a dashboard that provides real-time data on key program metrics, including the number of households receiving replacement water, well testing results, the volume of water delivered, and outreach activities. As of the end of September, nearly 2,200 households are receiving free bottled water through the program. Additionally, seven fill stations are operational, with at least two or three more in development, and these stations are actively used by the community.
“We keep track of the amount of water coming through the fill station, because we have to pay for it from the water purveyors, so we know how much the fill stations are being used,“ said Tess Dunham, representing the Central Valley Salinity Coalition. “Combined with the bottled water that’s being delivered, the management zones in this short time period have delivered almost 4 million gallons of water to households throughout the Central Valley. And we’re very proud of this.”
The table below shows the estimated number of domestic wells impacted by nitrate derived from the management zone implementation plans, the number of wells tested, and how many have exceeded the nitrate standard.
Outreach efforts focus on engaging a wide range of stakeholders, including LAFCOs, county environmental health departments, community services districts, public water systems, local government bodies, GSAs, and special districts, to navigate California’s complex network of agencies, Ms. Dunham said. Key strategies include partnering with trusted community resources such as WIC offices, schools, rural health clinics, food banks, and churches to distribute information via mailers, flyers, and to school-age children. In-person engagement at fairs, sporting events, and food distribution centers, along with TV, radio, social media, and direct conversations are also used.
Debra Dunn, Manager of Water Resources at the Kings Water Alliance (KWA), highlighted the organization’s efforts in the Kings and Tulare Lake Subbasins, which cover Fresno, Tulare, and Kings counties. As the management zone entity responsible for providing safe drinking water for these basins, KWA has tested 1,300 wells in the Kings Subbasin, with 41% exceeding safe nitrate levels, and 50 wells in the Tulare Lake Subbasin, with 10% exceeding standards. Over 800 locations receive bottled water, and three 24/7 fill stations provide safe drinking water, with the Kerman station delivering over 200 gallons daily.
KWA secured a $300,000 grant through the Sierra San Joaquin Jobs Initiative to fund the “Ripple Effect Initiative,“ a community-driven project focused on ensuring access to safe drinking water while fostering the development of a robust local water workforce. The initiative is designed to address current water challenges and build long-term capacity for sustainable water management in the region.
Charlotte Schuil, Water Program Manager at 4Creeks and representing the Kaweah Water Foundation and Tule Basin Water Foundation, outlined efforts to address nitrate contamination in Tulare County. The Kaweah Water Foundation provides bottled water to affected households in Lemon Cove and Yokel Mutual Water Company, while working on long-term water system upgrades. The Tule Basin Water Foundation is advancing a project to reduce reliance on groundwater by developing a central distribution system from the Friant-Kern Canal.
Maureen Thompson, Operations Director for Valley Water Collaborative, highlighted work in five Priority 2 basins, including Yolo and Merced. The organization supports a consolidation project in South Merced, funded by SAFER, and will test domestic wells and provide outreach as the project progresses.
Board member Laurel Firestone expressed her appreciation for the program. “There are 1000s of people who have safe drinking water now because of this program that didn’t before. And I think we should all feel really, really good about that. … If you factor in the irrigated land regulatory program, that scale is far beyond what we’ve been able to achieve from the other programs that the board has been doing. And I think it’s a reflection of the importance of regulatory programs and the cooperative work that’s gone on when having a clear, common goal.”
Environmental justice organizations agreed that the management zones have been working hard, but they pointed out that there are still many households with unsafe drinking water. The graphic below shows the State Water Board’s aquifer risk map for nitrate contamination based on groundwater quality data.
“This map is not intended to predict or estimate the water quality at any given location, but it does show you the potential risks of nitrates in the San Joaquin Valley and where the general hotspots are,“ said Tien Tran, Policy Manager at the Community Water Center. “It looks like in the priority one management zones, there are 13,000 impacted domestic wells. We have the opportunity here to use the best available data science and also regulatory tools to get those outcomes and solutions for impacted communities.“
The environmental justice groups are having ongoing conversations with management zones about how to improve outreach. “We are very aware of the unique challenges when it comes to reaching most of the vulnerable people,“ said Ms. Tran. “People are scared to answer their door right now. People are scared to provide information. People are scared to come to Sacramento and provide public comment, so we recognize we need creative solutions to reach folks who need bottled water or access to that kiosk. We’ve talked about how we can adapt those outreach strategies and work together with other community-based groups on outreach.“
“The importance of the kind of interim and long-term drinking water components of this program can’t be overstated,“ said Michael Claiborne, Directing Attorney at the Leadership Counsel for Justice and Accountability. “Replacement water efforts are never going to get to all the impacted households for a lot of reasons. There’s no requirement that any household participate, and some households will choose not to, so outreach is extraordinarily difficult. We hope to reach around 50% participation in this program, but I don’t think we’ll get much higher than that. I think we should try, but there are realities that this won’t reach everybody. So this is where compliance and restoration come in.”
MANAGEMENT ZONE IMPLEMENTATION PLANS
In November 2023, the Central Valley Water Board determined that the Priority 1 Management Zone Implementation Plans (MZIPs) were complete. These plans, however, are not self-implementing, so the Central Valley Water Board must approve an exception from the nitrate water quality objective. The MZIP serves as an application for an exception to meeting the nitrate water quality objective and is required by the Central Valley Water Board to authorize an exception.
Exceptions are typically granted for terms not exceeding 10 years, though the Board has the discretion to extend this period to up to 35 years if applicants can demonstrate that the extension is essential to achieving the goals of the CV SALTS program. The approval process for exceptions includes public notices, opportunities for comment, and public hearings. Approval will only be granted if an adequate supply of clean, safe, reliable, and affordable drinking water is available to those impacted by nitrate contamination.
The Modesto Management Zone is the first to undergo this process. A draft resolution is being prepared to approve an exception for all dischargers actively participating in the Modesto zone. The proposed terms range from 10 to 35 years, depending on the discharge sector. The resolution will amend all permits within the zone, incorporating enforceable requirements and milestones for nitrate reduction and drinking water program implementation. A public engagement process will allow for review of the resolution and permit amendments, with a Regional Board hearing and adoption anticipated in early 2026. Similar processes for other management zones are expected to follow.
Some management zone implementation plans are seeking 35-year time schedules, but Mr. Claiborne said there’s very little justification for an exception that long. “Time schedules need to be as short as practicable for each category of dischargers,“ he said. “We see it as a requirement for the management zones to really justify those time schedules, especially if they’re asking for the full 35 years in the management zone implementation plans. We really didn’t see justification that’s as detailed as we would like to see for that requested 35-year exception.”
There needs to be a focus on interim milestones, because no matter what the end compliance date is, progress needs to go as quickly as is feasible. “It needs to be front-loaded, because we think most of the progress is going to be not easily achievable, but more easily achievable than the last 10 to 15% of compliance, which we see as probably very challenging,“ Mr. Claiborne said.
THE END GOAL: RESTORATION
Management zones must reduce nitrate loading so that ongoing discharges no longer cause or contribute to exceedances of water quality objectives, and restore basins so they no longer exceed those objectives.
“First of all, we need to stop causing the problem, and then we have to fix the problem,“ said Jennifer Clary, California State Director for Clean Water Action. “We’ve been talking a lot about how to help people who are already impacted, and as hard as the management zones are working, they’ve so far really addressed less than 20% of potentially impacted wells. I agree – I think they’re doing a great job. I think it’s just really tough. So how do we actually fix this?”
Management Zone Implementation Plans do not provide a schedule or even a plan for basin restoration, she said. “Our big problem with the plans, which are now two years old, is that they all have one line under restoration saying, ‘we’re going to work with the GSA.‘ I think after two years, we can get a little more detail. What does that work with GSA mean?”
Ms. Clary said the management zones should identify projects and management actions that support nitrate remediation adjacent to communities, and create a workplan, schedule, and budget for management zones to accelerate these projects. She wants to see tangible action on restoration in the next five years.
“I know it seems very ambitious, but given the power and the amount of data that the State Water Board and regional water boards have and the regulatory toolkit that they have, we see how this can become a reality. This is why we engage in SGMA. This is why we engage in SAFER and all the other nitrate programs – because we want to make sure that all communities in the San Joaquin Valley have access to safe, clean, and affordable drinking water. And I really appreciate the board members for highlighting how critical and important this program is.”
