Implementing California’s Sustainable Groundwater Management Act (SGMA)

California’s Sustainable Groundwater Management Act (SGMA) continues to evolve, in practice, from a framework-setting statute into an actively implemented regulatory structure. Over the past few years, the State Water Resources Control Board (State Water Board) and the Department of Water Resources (DWR) have shifted into a pivotal period of policymaking. As Groundwater Sustainability Agencies (GSAs) move from their plan development phase into measurable outcomes, state oversight has intensified — both procedurally and politically.

Under SGMA, DWR is tasked with conducting technical evaluations of Groundwater Sustainability Plans, including ongoing assessments of plan adequacy and their incorporation of updated data. Recent probationary determinations indicate that State agencies expect demonstrable progress, particularly in critically over-drafted basins.

At the same time, the State Water Board, which is charged with determining and managing GSA’s probationary designations, has continued to expand its role as an enforcement backstop under SGMA. The Board’s SGMA probationary process and policies have been developed during this first round of probationary designations, signaling a move toward more assertive intervention. These actions may impose procedural consequences, including mandatory reporting requirements, potential extraction fees and the development of interim plans managed by Board staff. The Board’s most recent action, denying eight GSA requests for exclusion from probationary reporting and fees in the Tule Subbasin, has sparked discussion about consistency and coordination.

Politically, SGMA implementation continues to be a point of tension across California’s water sector. Key stakeholders in the agriculture community, members and representatives of disadvantaged communities and urban water users continue to express competing priorities, especially as sustainability measures are now being translated into concrete implementation requirements such as pumping restrictions and land fallowing. Legislative interest in SGMA oversight has also increased, with ongoing discussions regarding equity, funding mechanisms, subsidence and the long-term viability of groundwater-dependent regions.

As we look ahead, the tension between state enforcement authority and local control will remain a contentious part of SGMA implementation. As deadlines approach and scrutiny intensifies, GSAs will need to navigate an increasingly complicated regulatory environment while balancing local needs with statewide mandates.

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