When Rainwater Becomes a Lawsuit: The Citizen Suit Campaign Targeting California Wineries

For more than a decade, industry publications and environmental consultants warned California wineries that stricter stormwater regulations were coming and that enforcement would follow. That enforcement is now well underway. Since 2020, environmental organizations have been waging a systematic campaign of Clean Water Act citizen suits against wineries across the state, alleging violations of California’s Industrial General Permit (Order No. 2018-0028-DWQ) (IGP). Dozens of wineries in Napa, Sonoma, the Central Coast, and other regions have received formal 60-Day Notices of Intent to Sue (NOIs), and the pace shows no sign of slowing. This marks a sharp departure from citizen suits’ traditional targets (scrap metal yards, auto dismantlers, and plating operations) and signals a new front in private environmental enforcement. 

This article explains the genesis of these lawsuits, why wineries are vulnerable, and what winery operators should do now.