Making a Defensible Decision Under Conflict
SELECTED WORK 04
A court-ordered deadline, seven million acres, and no agreement on the rules
Central Valley Regional Water Quality Control Board · Supervising Water Resources Control Engineer · 2007 - 2014 · Roughly 7 million acres of irrigated agriculture
Situation
I assumed responsibility for the Irrigated Lands Regulatory Program in 2007, the same year two environmental organizations filed suit over the Central Valley Water Board’s interim approach. A settlement ultimately required the Board to certify a final program environmental impact report by April 8, 2011.
Constraint
The permanent program would apply across roughly seven million acres and extend regulation to groundwater as well as surface water. Estimated annual compliance costs ranged from $216 million to $1.3 billion. Growers saw major operational and financial consequences; community and environmental interests saw years of delay. Any final action was likely to be challenged, and the court deadline could not move.
Leadership approach
Designed for disagreement rather than consensus. I led a team spanning three offices, legal counsel, and outside contractors. Instead of presenting stakeholders with a nearly finished recommendation, I recommended bringing competing interests into the framing, analysis, and evaluation of alternatives from the outset.
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Kept competing evidence visible. The environmental review and public record reflected differing evidence and perspectives. We evaluated six alternatives and their associated costs rather than defending a single predetermined option.
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Put staff accountability in public view. We held workshops across the region and met repeatedly with affected interests. I served as the primary staff spokesperson, presented recommendations to the Board, and answered questions while maintaining alignment with executive management on the decisions before it.
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Balanced protection with a workable delivery structure. Our recommendation extended the program to groundwater while retaining a coalition model so most growers could work through third parties rather than interact directly with the Board. The Board adopted that approach. I also learned a capacity lesson: while serving in an interim executive assignment, I protected this highest-priority project but did not protect enough attention for the other programs I supervised.
Result
The Board certified the final environmental impact report on April 7, 2011, one day before the court deadline, and adopted related Basin Plan amendments that October. Between 2012 and 2014, it adopted eight general waste discharge requirements covering growers across the Central Valley. I oversaw development of all eight. Together, the actions extended the program to all Central Valley growers and, for the first time, to groundwater. The basic framework remains in place.
When agreement is unlikely, make the tradeoffs visible and build a record decision-makers can defend.
EXECUTIVE INSIGHT
What this means for a client
A fixed deadline can end the debate over whether to act; it cannot decide what the action should be. When interests are deeply divided, the executive task is not to manufacture consensus. It is to create a process that can hold competing evidence, expose the real tradeoffs, maintain clear accountability, and give decision-makers a defensible basis for action. That combination of participation and decision discipline matters most when challenge is inevitable.
Information current as of October 2026.
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This case study describes work performed by Joe Karkoski in his official capacity as a California state employee. It reflects his personal account and analysis, not the views or endorsement of the State Water Resources Control Board, any Regional Water Quality Control Board, or the State of California. Agency actions described were taken through collective staff, management, executive, and governing-board processes.