How the Mojave Groundwater Bank’s Section 1815 Review Is Advancing
The Mojave Groundwater Bank’s Section 1815 application submits 20 years of environmental approvals and technical studies for review by California State Lands Commission for finding process.
California Water Code Section 1815 requires a State Lands Commission finding that a covered water transfer will not adversely affect protected desert lands’ natural or cultural resources, including groundwater and habitat. The Mojave Groundwater Bank, a water supply and groundwater storage project being developed by Cadiz in partnership with public agencies and Native American Tribes, is seeking that finding for water delivery from the project as it finalizes a lease over one mile of state owned land for the Northern Pipeline. The application was deemed complete and the work of a staff-selected contractor assessing the project’s submitted environmental and technical record is being completed. Fenner Gap Mutual Water Company, the applicant for the lease, has provided the cost recovery funds requested by State Lands for the contractor.
Summary
- The Mojave Groundwater Bank’s environmental record includes court-upheld approvals, subsequent environmental addenda, and groundwater studies and technical reports for Section 1815 review.
- Fenner Gap Mutual Water Company, managed by Cadiz, applied for the Northern Pipeline lease for the state lands crossing in March 2026. The application was deemed complete in April 2026. In August, it funded the contractor’s review through the State Lands Commission.
- The Mojave Groundwater Bank’s environmental reviews address hydrogeological resources such as springs, biological resources, and cultural resources, with monitoring and mitigation provisions to protect desert resources.
- The project received state environmental approval in 2012, and was upheld in court in 2014 and 2016. Environmental addenda assessed project modifications in 2019 and 2025, including Northern Pipeline conversion.
- The Northern Pipeline conversion received federal authorization in July 2026.
- One mile of the pipeline crosses state owned land.
- Section 1815 requires a separate finding from the State Lands Commission on the proposed water transfer’s effects on protected desert lands’ natural and cultural resources.
The Project Has Court-Upheld Approvals and Federal Pipeline Authorization
Cadiz received the effective federal right of way grant on July 14, 2026, allowing the defined conversion work on lands managed by the U.S. Bureau of Land Management (BLM). The federal pipeline review explains that authorization and its conditions.
Environmental Approvals and Technical Reviews Have Advanced the Project
Date | Milestone | How It Advanced the Project |
2012 | Santa Margarita Water District certified the Environmental Impact Report; San Bernardino County approved the groundwater management plan. | Established the environmental review and groundwater-management framework. |
2014 | The trial court denied all claims in six lawsuits challenging the 2012 approvals and upheld those approvals. | Sustained the environmental review and agency approvals at trial. |
2016 | Six appellate decisions upheld the challenged state approvals. | Preserved the reviewed approvals for project development. |
2019 | Fenner Valley Water Authority adopted an environmental addendum for treatment facilities and Southern Pipeline route changes; it also discussed spring studies. | Evaluated project modifications and included spring research for informational purposes. |
2025 | Fenner Valley Water Authority approved the Northern Pipeline conversion addendum. | Completed state environmental review of the proposed conversion under the existing CEQA record. |
March 2026 | Fenner Gap Mutual Water Company applied for the Northern Pipeline state lease. | Began the application process for water conveyance across the state-leased segment. |
July 2026 | Fenner Gap Mutual Water Company received the effective federal Northern Pipeline grant. | Authorized defined conversion work on BLM-managed lands, subject to grant conditions. |
August 2026 | Cadiz confirmed funding for the work of the Commission staff-selected contractor. | Funded assessment of the environmental record as a required step in the state application process. |
The federal grant authorizes Northern Pipeline conversion on BLM-managed lands. The Section 1815 review draws on the project’s environmental record, including the 2012 Final EIR and subsequent addenda. The 2025 addendum assessed Northern Pipeline conversion and water conveyance within that record.
The Section 1815 Application Has Advanced to Technical Review
Approximately one mile of the Northern Pipeline crosses state-owned land leased through the State Lands Commission. Cadiz’s March 2026 application seeks to change the lease from idle-natural gas pipeline maintenance to water conveyance. Its 2025 Form 10-K identifies the state application as covering both pipeline change-of-use authorization and the Section 1815 finding.
As a required application step, Cadiz pays invoices from the State Lands Commission, which pays the contractor retained by its staff to review the project’s environmental and technical record. Its August 2026 shareholder letter reported funding the review and expressed confidence that the report would satisfy applicable state requirements.
The environmental record includes the 2012 Final EIR, the 2014 trial-court judgments and 2016 appellate decisions, subsequent EIR addenda, federal approvals, and publicly available scientific analyses, field studies and technical reports.
The application follows the Commission’s December 2024 caretaker decision, which authorized El Paso Natural Gas to maintain the idle pipeline. Cadiz’s application seeks authorization to use the pipeline for water conveyance.
Under Section 1815, the Commission reviews all available scientific information, including peer-reviewed and published studies, in consultation with the California Department of Fish and Wildlife and Department of Water Resources. The law calls for a public written finding within 15 months of receiving the application, with a justified extension possible to no later than 24 months from receipt.
Environmental Studies Support Protection of Springs and Wildlife
The project’s environmental studies address the resources considered under Section 1815. The Final EIR’s groundwater analysis evaluated drawdown effects on subsidence, water quality, air quality, vegetation, and springs. It concluded that managed drawdown under the safe-yield plan would not significantly affect those resources, with mitigation addressing effects on third-party wells.
The Northern Pipeline environmental addendum found that existing mitigation would reduce any potential for biological-resource effects to less than significant levels. These findings connect the pipeline’s design and operating requirements with protection of wildlife
A 2018 geologic assessment concluded that Bonanza Spring’s system was hydraulically separated from the regional aquifer. Luke Stevens and David Kreamer followed with more than a year of sampling at Bonanza Spring and Cadiz Ranch wells, comparing water chemistry and stable isotopes.
Their 2025 Hydrogeology Journal study, found differences that supported a lack of an underground connection between the spring and the groundwater supplying those wells. The field data address the spring-connectivity question relevant to assessing potential pumping effects on spring flow.
Expert Reviews Support the Groundwater Management Plan
The project’s expert reviews support the scientific basis for groundwater management. A 2019 peer-review panel found the management and monitoring measures appropriate and sufficient to identify undesirable results. Its recommendations added to the plan’s monitoring and protective measures. Three Valleys Municipal Water District and Jurupa Community Services District commissioned that review; both held options to acquire project water.
The monitoring plan requires observation of springs, groundwater levels, land subsidence, vegetation, and air quality. In February 2023, Cadiz announced that San Bernardino County and Santa Margarita Water District had initiated a Technical Review Panel. The panel provides expert technical oversight of groundwater management. Its first assignment is to establish baseline aquifer and watershed conditions before project operations.
Section 1815 Review Builds on Court-Upheld Approvals and New Research
The Mojave Groundwater Bank has secured state environmental approvals, sustained those approvals through trial and appellate review, and obtained federal authorization for Northern Pipeline conversion. The 2012 environmental review, 2019 and 2025 addenda, and expert studies provide a documented basis for assessing groundwater management and protection of desert resources.
Cadiz’s March 2026 application brings that record into the Section 1815 process. the application is in process.
Frequently Asked Questions
What Did the December 2024 Northern Pipeline Caretaker Lease Authorize?
The State Lands Commission granted El Paso Natural Gas a three-year lease to maintain the pipeline in idle status and prepare a decommissioning plan. Cadiz’s subsequent application seeks authorization to transfer that lease for water conveyance and includes a request for a Section 1815 finding.
How Long Does Section 1815 Review Take?
Section 1815 requires the State Lands Commission to issue a public written finding within 15 months of receiving the application. If it cannot make the finding within that period, it may extend the deadline to no later than 24 months from receipt. The Commission must publish its justification for more time and an approximate timeline for the extension.
What Oversight Does the State Lands Commission Retain After a Section 1815 Finding?
The company or agency transferring the water must report annually to the State Lands Commission on conditions in the groundwater basin. The Commission specifies the information required in those reports.
Related Articles
The Mojave Groundwater Bank is designed to provide clean, reliable and affordable water to underserved communities in the Southwest. Take a closer look at the science, safeguards, and community partnerships behind the project.