Implementing California’s Groundwater Sustainability Plan in Sacramento County

November 11, 2019

ECOS and Habitat 2020 have submitted the following letter to the Sacramento Central Groundwater Authority regarding their application to the Sustainable Groundwater Management Grant Program. ECOS/Habitat 2020 look forward to participating with the Sacramento Central Groundwater Authority in the implementation of the Grant Proposal and the ongoing efforts to develop a Groundwater Sustainability Plan for the South American Subbasin in Sacramento County.

Ramon Roybal
Assistant Engineer
Sacramento Central Groundwater Authority
827 7th Street Room 301
Sacramento CA, 95814
Subject: South American Subbasin Prop 68 Round 3 Grant Proposal for Evaluating GDEs and Surface Water Depletions (Grant Proposal)
Dear Mr. Roybal,
The Environmental Council of Sacramento (ECOS) is a 501(c)(3) nonprofit organization working to achieve regional and community sustainability and a healthy environment for existing and future residents. ECOS member organizations include: 350 Sacramento, Breathe California Sacramento Region, Friends of Stone Lakes National Wildlife Refuge, International Dark-Sky Association, Physicians for Social Responsibility Sacramento Chapter, Sacramento Citizens’ Climate Lobby, Sacramento Electric Vehicle Association, Environmental Democrats of Sacramento County, Sacramento Housing Alliance, Sacramento Natural Foods Coop, Sacramento Audubon Society, Sacramento Valley Chapter of the California Native Plant Society, Sacramento Vegetarian Society, Save Our Sandhill Cranes, Save the American River Association, Service Employees International Union (SEIU) Local 1000 and the Sierra Club Sacramento Group.
Members of Habitat 2020, a committee of ECOS, include: Friends of Stone Lakes National Wildlife Refuge, Friends of Swainson’s Hawk, International Dark-Sky Association Sacramento Chapter, Sacramento Area Creeks Council, Sacramento Audubon Society, Sacramento Valley Chapter California Native Plant Society, Save Our Sandhill Cranes, Save the American River Association, Sierra Club Sacramento Group and Sacramento Heron and Egret Rescue.
We want to express our thanks for the opportunity to review and comment on the Sacramento Central Groundwater Authority’s (SCGA) Grant Proposal. We are very concerned about how the South American Subbasin’s (Subbasin) Groundwater Dependent Ecosystems (GDE) and Groundwater/Surface Water Interfaces (GWI) are identified, evaluated, and managed as part of SCGA’s development and administration of a Groundwater Sustainability Plan (GSP) for the Subbasin. We commend SCGA for opening its grant development process to include public comment. We are encouraged by this action and look forward to working with SCGA and the other Subbasin GSAs in implementing the grant’s workplan. In addition, in the coming months we look forward to working with all parties to develop a GSP for the South American Subbasin (SAS).
We support the overall workplan proposed in the Grant Proposal. Specifically we endorse the workplan’s support for the completion of the numerical integrated groundwater surface water CoSANA model. We support the technical approach proposed for the identification and analysis of GDEs and GWIs. Finally, we support and commend SCGA for the identified efforts to include public input throughout the project. SCGA has included the potential formation of a Cosumnes Surface Water Group if such a group is found useful by those concerned and affected by decisions in the region. We see this group playing an important role in the analysis of the river basin and riparian forested areas and agricultural lands. We also endorse the workplan’s inclusion of and call for cross-basin coordination between each of the subbasins that share a river boundary
Finally, we urge both the South American Subbasin and the Cosumnes Subbassin GSAs to work with their common stakeholders to establish the lower Cosumnes River basin as a “Management Area” under SGMA in each Subbasin’s GSP. This designation will allow the lower Cosumnes River basin’s critical resources to be managed effectively.
ECOS/Habitat 2020 look forward to participating with SCGA in the implementation of the Grant Proposal and the ongoing efforts to develop a GSP for the Subbasin.
Sincerely,
Rob Burness and Sean Wirth, Co-chairs of Habitat 2020

Click here to view the letter in PDF.

Jackson Township DEIR Comments

On October 31, 2019, Environmental Council of Sacramento (ECOS), Habitat 2020, 350 Sacramento, and Sierra Club provided comments on the Jackson Township Draft Environmental Impact Report (EIR). Below are some excerpts from the letter, followed by a link to the letter in full.

Agricultural Resources

There is insufficient mitigation for farmland lost in the Jackson Township Specific Plan DEIR [Draft Environmental Impact Report]. By converting all this farmland to urban/suburban uses, the GHG emissions will increase due to the increased number of motor vehicle trips (more vehicle miles traveled). Moreover, loss of agricultural resources will reduce the potential for carbon sequestration in the soil by application of compost or regenerative agriculture methods, in addition to the natural processes of plant growth and soil microbial action from farming. There needs to be better mitigation measures to ensure carbon soil sequestration occurs at least as much as it would if the agricultural resources were preserved.

Biological Resources

Use of the South Sacramento Habitat Conservation Plan (SSHCP) was offered as one of the options for dealing with California Endangered Species Act (CESA) and Federal Endangered Species Act (FESA) impacts, and it was clearly stated that the hardline preserves identified in the SSHCP conservation strategy would be provided. Since the SSHCP now has its permits and is in the implementation phase, we are assuming that the Jackson Township will be affected by and compliant with the SSHCP.

Climate Change

We appreciate the opportunity to comment on Chapter 9, “Climate Change”, of the County’s Jackson Township Specific Plan Draft Environmental Impact Report (DEIR). Our greenhouse gas (GHG)-related comments are presented in the following seven sections. We first discuss the County’s past GHG-reduction commitments, because the DEIR:
I. does not accurately describe County climate planning;
II. uses inappropriate baseline data based on past planning;
III. applies inappropriate thresholds of significance; and
IV. is inconsistent with the County’s 2011 General Plan Update, associated Final Environmental Report (GP/FEIR), and Phase 1 CAP.
We also present,
V. other DEIR-related concerns.
We conclude:
VI. the DEIR is legally insufficient
VII. the County’s failure to provide promised mitigation is contrary to the General Plan.

Click here to read the letter in full
Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5

SMUD Roseville Water Transfer comments

On September 10, 2019, the Environmental Council of Sacramento and Habitat 2020 sent a letter to Sacramento Metropolitan Utilities District (SMUD) a letter regarding a proposed water transfer between the City of Roseville and SMUD. Below are some excerpts from the letter, followed by a link to the letter in full.

Recently the Environmental Council of Sacramento and Habitat 2020 became aware of the pending temporary water transfer between the City of Roseville and SMUD. Our review of the environmental assessment and decision document prepared by the Bureau of Reclamation found specific deficiencies in the analysis and a casual dismissal of the transfer’s cumulative significance. We believe that the proposed transfer of water does not contain the necessary safeguards to protect Lower American River fisheries. We request that the SMUD Board direct its staff to include provisions in the contract that will address these concerns.
…
We believe the transfers must be governed by the standards and requirements contained in the Modified Flow Management Standard. These standards and requirements would much better ensure that the transfer would not negatively impact the American River flow and temperature standards.

Click here to read the full letter.

Photo by George Nyberg of the American River

Problems with Galt Climate Action Plan

On September 30, 2019, the Environmental Council of Sacramento, 350 Sacramento and the Sierra Club submitted a letter compiling comments on the Climate Action Plan proposed by the City of Galt.

Below are some excerpts from the letter.

Local climate action is important because the largest sources of greenhouse gas emissions (GHG), in the City of Galt as well as statewide, are building energy [use] and on-road vehicle travel.
Both are best and most directly controlled locally, by adopting energy-efficient building codes and requiring efficient development that reduces the need for auto “vehicle miles traveled” (VMT).

There is no longer any rational doubt that climate change is adversely affecting the livability of our planet now; that physical environmental effects will grow increasingly serious in coming decades; and that without major, timely GHG-reductions, they will cause grave public health impacts and severe economic and social disruptions in the lifetimes of children alive today.
We appreciate the difficulties transitioning from the long-accustomed land use and building models that have contributed to climate change to sustainable ones, and doing it quickly. But the exigencies of climate change, as reflected in State law, require broad and decisive change in how we use and think about energy. The required adjustments will bring many co-benefits, and we no longer have the luxury of delayed or token efforts.
Our organizations are committed to working with Galt in every productive way we can. We look forward to ongoing engagement in the City’s administrative process and may provide specific suggestions in future comments

Click here to read the comment letter in full.

Image credit: https://www.ecolife.zone/

Sacramento Two Rivers Trail Bike Trail

On September 12, 2019, ECOS and Habitat 2020 submitted a comment letter on the Sacramento Two Rivers Trail (Phase II) DEIR.

The Two Rivers Trail Phase II project will provide a 2.4 mile long multi-use path between Sutter’s Landing Park and H Street, by Sacramento State. The trail will provide residents of River Park and East Sacramento a safe, convenient, and protected path into downtown Sacramento. The overall vision is to eventually have the trail connect to the Sacramento River Parkway and create a continuous trail system along both sides of the Sacramento and American Rivers. In addition, the project will environmentally clear the next phase of the trail between Sutter’s Landing Park and the Sacramento Northern Bike Trail.
https://www.cityofsacramento.org/Public-Works/Engineering-Services/Projects/Current-Projects/Two-Rivers-Trail-Phase-II

There are many habitat issues that remain unaddressed in the Draft Environmental Impact Report.

The bottom line is that a bike trail on a levee is not only feasible, but it is the best option for the Two Rivers Trail if we want to protect the American River Parkway and its ecosystems. There are numerous other benefits to putting the trail on top of the levee as well, such as better access during winter floods.

Click here to read the letter in full.

Placer County Sustainability Plan Comments

On September 05, 2019, ECOS and 350 Sacramento wrote a comment letter to the Placer County Community Development Resources Agency in regards to the Placer County Sustainability Plan.

Below are a couple of excerpts from the letter, click the link below to read the full letter.

We encourage all efforts to expedite the transition to a carbon-free economy and are gratified by the County’s aspiration to be a leader in reducing greenhouse gas (GHG) emissions. We offer these comments in the hope they will help the County reach that goal.
…
It is evident from the draft Plan’s strong monitoring and update commitments that it is meant to be a “living” document, subject to ongoing community dialogue and further refinement. We look forward to working with the County to advance the Plan’s important role in mitigating climate change.

Click here to view the comment letter in full.