1. Original Vision, Purpose and Mission
7/2/2019

2. 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

3. 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

4. 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

5. (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

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

7. 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

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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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

24. 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

25. 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

26. 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

27. 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

28. 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

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

30. 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

31. 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

32. 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

33. 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

34. 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

35. 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

36. 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

37. g END h
7/2/2019

38. 7/2/2019

39. 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

40. 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

41. 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

42. 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 (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

43. 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

44. INSERT CHART
7/2/2019

45. 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

46. 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

47. 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

48. 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 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

49. Role of the Central Valley Salinity Policy Group
Management –
Extensive use will be made of conference calls and
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 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

50. 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

51. 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

52. 7/2/2019