Comments re American River Basin Integrated Regional Water Management Plan Update

On January 11, 2019, the Environmental Council of Sacramento and Habitat 2020, sent comments regarding the 2018 update of the American River Basin Integrated Regional Water Management Plan.

Below is the content of our letter in full.

Richard M. Johnson (Sent via email to johnsonr[at]saccounty[dot]net)
Executive Director of Sacramento Area Flood Control Agency
1007 7th St, 7th floor
Sacramento 95814

Subject: 2018 update of the American River Basin Integrated Regional Water Management Plan

Dear Mr. Johnson,

The Environmental Council of Sacramento (ECOS), a 501c3 organization, and Habitat 2020, the Conservation Committee of ECOS, are partner coalitions dedicated to protecting the natural resources of the greater Sacramento region while building healthier, more equitable, economically thriving communities. ECOS-Habitat 2020 member organizations include: 350 Sacramento, AARP, Breathe California-Sacramento Emigrant Trails, Friends of Stone Lakes National Wildlife Refuge, International Dark-Sky Association, Los Rios College Federation of Teachers, Mutual Housing California, Physicians for Social Responsibility Sacramento Chapter, Sacramento Citizens’ Climate Lobby, Sacramento Electric Vehicle Association, Sacramento Green Democrats, 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, Sierra Club Sacramento Group, Friends of the Swainson’s Hawk, and the Sacramento Area Creeks Council.

We are heartened by the extensive work the Sacramento Area Flood Control Authority (SAFCA) and the Regional Water Authority (RWA) are doing to improve the Sacramento Region’s water reliability, security, and flood protection. The 2018 update of the American River Basin Integrated Regional Water Management Plan (“Plan”) includes SAFCA’s efforts to improve Regional flood control, provide for storm water management, and develop excess storm water recharge opportunities all in the face of increasing storm intensity and frequency due to the impacts of climate change. We are especially interested in SAFCA’s efforts to develop and promote the potential beneficial uses of excess storm water that moves down both the American and Cosumnes Rivers. Like SAFCA, we would like to see some of this water captured to restore aquifer levels and stored in the Region’s Subbasins for future use during periods of drought. SAFCA is commended for its success in securing the financial resources required to carry out its programs and projects in this vitally important area of flood protection.

We understand that one of the next steps to acquiring this excess storm water recharge resource is to complete a thorough analysis of where within the Region the prime recharge and extraction zones are located. This analysis should include the area(s) compatibility with existing land usage and water management/conveyance constraints. We understand that Dr. Graham Fogg of UC Davis is preparing a project plan to carry out this analysis and that SAFCA has already held discussions with the Cosumnes Subbasin GSAs on this same topic. A project or projects to carry out this work in both the South American and the Cosumnes Subbasins should be a high priority for inclusion within the Plan, and again, we hope that SAFCA will take a leadership role in working with the UC Davis Water Group and the appropriate GSAs to fund this important work.

We understand that RWA is preparing to engage in a public awareness campaign to convey to elected officials, agency decision makers, opinion leaders, and the public, the importance of the projects and activities identified in the Plan and how they lay out a prudent path for the region’s water future. SAFCA’s efforts will certainly be prominently featured in this public outreach effort. We hope to participate with SAFCA and RWA in this campaign. ECOS/Habitat 2020 represents most of the environmental and community-based groups in the Region and has strong ties with conservation and other public interest groups as well.

We note with keen interest the efforts SAFCA and others are making to work with the Sacramento Central Groundwater Authority (SCGA) and the Cosumnes Subbasin Groundwater Sustainability Agencies (GSAs) to join with the North American Subbasin GSAs to develop and adopt a comprehensive American River Basin descriptive modeling system (SacIWRM). The region wide adoption of SacIWRM will ensure accurate accounting and impact assessment of both recharge and pumping operations and accurately describe the flows and elevations of groundwater through and between each Subbasin. The SacIWRM will enable each Subbasin’s GSAs to adopt Subbasin management plans that are capable of responding to delayed changes within the Subbasin due to pumping and recharge operations, and respond to GDE and other triggers requiring GSA actions. We understand that SAFCA has volunteered to pay the additional costs the Cosumnes Subbasin GSAs will incur to ensure SacIWRM meets the Cosumnes Subbasin needs. We strongly hope that that the Cosumnes Subbasin GSAs will adopt the SacIWRM model and, if needed, accept SAFCA’s generous financial offer. We will engage with SAFCA and RWA in any way practical to assist in accomplishing this objective.

ECOS/Habitat 2020 stand ready to work collaboratively with SAFCA to communicate the importance of regional water security including appropriate storm water management, recharge, and flood protection; and the plans and projects that best lead the region toward this goal. We stand ready to meet with you and your staff to further explore these points and how we may assist in your Agency’s efforts to effect a comprehensive water security investment that can actually benefit the environment. If need be, please contact Robert Burness at rmburness[at]comcast[dot]net or 916-956-0365.
Sincerely,

Robert C. Burness
Co-chair of Habitat 2020

Ralph Propper
Board President of ECOS

CC via email: Tim Washburn, Director of Planning, SAFCA, washburnr[at]saccounty[dot]net

Read the letter in PDF by clicking here.

ECOS/Habitat 2020 Comments on the Two Rivers Trail Phase II project

On November 30, 2018, the Habitat Committee of the Environmental Council of Sacramento submitted a letter to Tom Buford, Principal Planner, and Adam Randolph, Project Manager, with the Community Development Department of the City of Sacramento.

Habitat 2020 is a citizen coalition that works to protect the lands, waters, wildlife and native plants in the Sacramento region. It also serves as the Environmental Council of Sacramento’s Habitat & Conservation committee. The great Central Valley of California has been identified by the World Wildlife Fund as one of North America’s most endangered eco-regions. Preserving its remaining open space and agricultural land is essential for sustaining native plants and wildlife, and ensuring a high quality of life for ourselves and future generations. Members of Habitat 2020 include the Sacramento Audubon Society, California Native Plant Society, Friends of Swainson’s Hawk, Save the American River Association, Save Our Sandhill Cranes, Sierra Club Mother Lode Chapter – Sacramento Group, Friends of Stone Lakes National Wildlife Refuge, the International Dark-Sky Association and the Sacramento Area Creeks Council.
The American River Parkway is a unique and singularly important riparian habitat corridor in the County of Sacramento and is a rare remaining remnant of what was once a much more extensive riparian ecosystem in northern California. Any project to construct facilities within the Parkway and to increase human activities in the Parkway has impacts on the wildlife, habitat and plants of this corridor. This project would create 3.4 miles of new Class 1 bicycle and pedestrian trail primarily along the waterside levee toe west from Sutter’s Landing Regional Park to the Sacramento Northern Bikeway Trail at North 18th Street, and east from the eastern terminus of Sutter’s Landing Regional Park to the H Street Bridge. The trail would be 14-16 feet wide. As stated in the MND/IS, page 5, the project is proposed to be constructed largely in an area designated as “Protected Area” under the American River Parkway Plan, with habitat preservation and recreation-related activities being the primary uses. As stated on page 9, it is one of the objectives of the project to “Complete the project in a manner that minimizes environmental impacts to the Parkway, given the proposed project’s location within the environmentally sensitive Parkway.”
Our comments on the MND/IS focus on the conservation of the Parkway as natural habitat. Moreover, we support the mission of the Save the American River Association (SARA) and endorse (and incorporate by reference into our comments) all comments made by SARA on this MND/IS. Likewise, we endorse and incorporate comments made by the Friends of the River Banks and the Friends of Sutter Landing Park.
…

We request that the City draft and circulate a full EIR, considering alternatives to the project width and alignment, and significantly improving the mitigation measures for the project.

View the full letter by clicking here (PDF).

View more information about the project on the City’s website by clicking here.

Community Perspectives on Local Transportation Needs & Funding

On September 13, 2018, ECOS and other groups submitted a joint letter to the Sacramento Transit Authority regarding transportation needs & funding in the Sacramento region. Below is an excerpt from the letter.

Breathe California Sacramento Region (BCSR), Cien Amigos, Environmental Council of Sacramento (ECOS), Sacramento Area Bicycle Advocates (SABA), Sacramento Housing Alliance (SHA), Sacramento Transit Advocates and Riders (STAR), Sierra Club Mother Lode Chapter and WALKSacramento are pleased to jointly share our perspectives on local transportation needs and funding.
Collectively, our missions stand for the advancement of health, access, equity, justice and environmental stewardship through investments in the built environment. We work closely in partnership with agencies and communities throughout the Sacramento region on issues related to transportation, land use, housing, and the environment, representing a wide-reaching constituency of some of Sacramento’s most engaged voters.
As the Sacramento Transportation Authority (STA) begins to consider how to fund countywide transportation priorities, we’re pleased to know that Measure M approved by Los Angeles County voters in 2016 is a consensus model for a successful funding measure for Sacramento County. Our organizations comprise a working group committed to ensuring that Sacramento County’s next transportation sales tax measure benefits from the lessons learned from Measure M. We commend STA for recognizing the value of Measure M as a model and commit to working with STA to follow the successful approach used by the Los Angeles County Metropolitan Transportation Authority (Metro) in crafting and winning passage of Measure M.
(Continued)

Click here to read the full letter (PDF).

Approval of the Alternative Plan to the Groundwater Sustainability Plan

On October 23, 2018, ECOS sent a letter to the California Department of Water Resources regarding the Approval of the Alternative Plan to the Groundwater Sustainability Plan. Below is the text of our letter. Click here to view the letter in PDF.

October 23, 2018
Karla Nemeth, Director
Department of Water Resources
1416 Ninth Street
Sacramento, CA 95814
Email: Janiene[dot]Friend[at]water[dot]ca[dot]gov
Re: Approval of the Alternative Plan to the Groundwater Sustainability Plan
The Environmental Council of Sacramento (ECOS) had previously expressed our concerns regarding the request to the Department of Water Resources (DWR) by Sacramento Central Groundwater Authority (SCGA) to approve an Alternative Plan to the Groundwater Sustainability Plan (GSP) required under the Sustainable Groundwater Management Act (SGMA) (See attachments 1 and 2). SCGA’s continued, largely passive, approach to groundwater management over the past several years has strengthened our view that SCGA’s GMP and current governance and finance structure do not constitute a legally adequate “alternative” to preparation of a GSP. The purpose of this letter is to further reinforce our opposition to SCGA’s request, and to urge DWR to quickly find that SCGA is not in compliance with SGMA, and, therefore should immediately begin preparing a GSP.
The County of Sacramento recently approved the South Sacramento Habitat Conservation Plan (HCP) which streamlines Federal and State permitting for covered developments and infrastructure projects while protecting habitat, open space, and agricultural lands. The HCP encompasses 317,655 acres of Sacramento County. Of this amount, 36,282 acres will become part of an interconnected preserve system and include important Groundwater Dependent Ecosystems (GDEs). Twenty eight plant and wildlife species and their natural habitats have been targeted for conservation. The Sacramento Central Subbasin (Subbasin) is largely within the HCP’s boundary. Unfortunately SCGA did not actively participate in the development of the HCP. Nor has SCGA documented the Groundwater Dependent Ecosystems within the Subbasin that are a critical part of SGMA and the GSP planning process. SCGA needs to establish a comprehensive monitoring program that will serve as a foundation for effective groundwater management and recharge programs. This program must be an accounting based water level and water quality framework that supports SCGA taking appropriate action when trigger points are reached. It is our belief that SCGA will only accomplish these important SGMA requirements when DWR directs it to develop and implement a GSP. Absent a GSP, the groundwater dependent ecosystems of the SSHCP preserve system will be at risk, which will place the entire SSHCP conservation strategy at risk.
SCGA’s continuing passive approach to groundwater management results means that it is not only neglecting problems but missing opportunities. ECOS has recently learned of the full import of the Sacramento Central Subbasin’s significance as a potential major storm water recharge area and groundwater resource for the water security of the Region. According to Dr. Graham Fogg of UC Water, the Subbasin is one of only two basins in the entire Sacramento Valley with currently identified geology which can readily accept large amounts of excess storm water as recharge. Dr. Fogg is developing a program of research to determine the optimal locations of the Subbasin’s recharge areas. Unfortunately, SCGA has not exerted any leadership in this critically important area of Subbasin management and is not currently working with Dr. Fogg on the research design. If SCGA were actively developing a GSP, the plan requirements necessitate that SCGA do the foundational work that will assist the Region’s water purveyors and other’s with key stakes in the Region’s water future, to move forward to develop and implement a major program of storm water recharge in the Subbasin.
Specifically, the GSP framework requires SCGA to fully document GDEs. This action will ensure Subbasin management decisions are not in conflict with GDEs and the HCP, including the siting and management of recharge and extraction facilities. The GSP framework requires that SCGA design and implement a Subbasin monitoring network that meets state standards and includes inter/intra basin coordination. The development of this monitoring system coupled with coordination between SCGA and neighboring subbasins is integral to the development of a Subbasin recharge program. Additionally the GSP requires management zones for GDEs. This planning effort will serve as the integration point between recharge and extraction zones, and the HCP and GDEs. SCGA’s development of a GSP will bring about proactive water quality and groundwater level monitoring and management (including GDEs and areas in the basin undergoing remediation). SCGA has not embraced a management role in these important areas but as part of the GSP process it will need to do so if significant recharge is to occur in the Subbasin. Finally, the GSP framework calls for the documentation of important land use considerations. Clearly, if SCGA were following the GSP process it would be actively identifying high priority storm water recharge areas within the Subbasin and working with local land use authorities to assure their preservation.
ECOS is aware of the importance of establishing one or more water banks as part of a comprehensive Subbasin groundwater recharge program. Dr. Robert Gailey of UC Water recently presented a discussion of the Regional groundwater recharge storage opportunities afforded by water banking as well as the issues the Region faces in bringing one or more banks into fruition. SCGA’s completion of a GSP will provide the monitoring and accountability framework and the Subbasin management structure necessary for the establishment of an excess storm water recharge program and water bank(s). Subbasin management, groundwater recharge, and water banking are new concepts and general public awareness of them is low. DWR’s GSP requirements compel SCGA to engage in community and stakeholder outreach and engagement. SCGA has not engaged in outreach and has not implemented an effective communication strategy. Both of these GSP requirements are essential to gaining community support for effective basin management.
We believe the above issues, coupled with earlier concerns we and others have raised, provide compelling reasons why DWR should reject SCGA’s Alternative Plan. We urge you to expeditiously take this action.

Sincerely,
Ralph Proper
President, ECOS
Rob Burness
Co-Chair of Habitat 2020
cc: Don Nottoli, Sacramento Board of Supervisors
Darrell Eck, Staff Engineer, Sacramento Central Groundwater Authority
Forrest Williams Jr., Chairman, Sacramento Central Groundwater Authority

Monitoring Groundwater in Sacramento County

October 12, 2018

The South American Subbasin is located in the central portion of Sacramento County. It is primarily managed by the Sacramento Central Groundwater Authority (SCGA).

ECOS believes that Sacramento Central Groundwater Authority’s understanding of the hydrology of the Subbasin should be measurably improved, and we have written a letter suggesting some ways to achieve that. Below is an excerpt of our letter.

The Environmental Council of Sacramento (ECOS) notes with interest the Sacramento Central Groundwater Authority (SCGA) Board’s September 12, 2018 direction to Staff to evaluate the State of California’s C2VSimFG model input data for the South American Subbasin (Subbasin) and update the State’s model data as necessary. We believe that SCGA’s understanding of the hydrology of the Subbasin should be measurably improved. SCGA should look to the modeling and monitory efforts underway by the Regional Water Authority and the Sacramento Groundwater Authority (SGA), and adopt and put in place a comprehensive and compatible monitoring program for the Subbasin.
We also believe the Board acted with imprudence when it recently adopted its operating budget for the upcoming year, in that, among other issues, the Board did not provide enough funding for groundwater monitoring and modeling. SCGA’s existing set of monitoring wells is insufficient to provide a full understanding of the flows of groundwater into, through and out of the Subbasin. Semiannual data points are not sufficient to understand and effectively manage the Subbasin. While we commend SCGA’s recent effort to provide real time monitoring in a small, select group of wells, we believe you should do far more in this important area.

Click here to read the full letter (PDF).

Sacramento Region Highway CapCity Projects

On October 3, 2018, the Environmental Council of Sacramento (ECOS) sent the following letter to the California Department of Transportation regarding the Sacramento Region Highway CapCity Projects.

Dear Director Benipal:
The Environmental Council of Sacramento (ECOS) is concerned that planned freeway expansions in the Sacramento region will induce major increases in vehicle volumes, contravening the spirit and intent of state legislation such as SB 375. We are most concerned about the CapCity (SR 51) expansion (including possible widening of the American River bridge), and also concerned about the planned I-5 HOV lanes between Sacramento and Elk Grove, and the proposed widening of I-80 between Sacramento and Davis.
We appreciate the CapCity project team’s continued engagement with ECOS and its willingness to discuss the project’s progression. However, ECOS would like to expand this conversation into a broader discussion about regional transportation challenges and priorities. We are willing to work with Caltrans staff to coordinate discussions with other regional agencies and stakeholders with the aim of considering potential alternatives to address these challenges.
Following are some reasons why this conversation is timely: CARB’s greenhouse gas scoping plan shows that we must reduce VMT by 15% to meet 2050 goals for GHG emissions. Guidelines for SB 743 specify that the principal criterion in evaluating transportation projects is now VMT reduction, as opposed to congestion relief. Based on these Guidelines, Caltrans will need to consider induced travel demand from future expansion projects, such as caused by land use impacts. The Sacramento Transportation Authority is planning a tax measure for the 2020 ballot. SACOG is developing its draft preferred scenario the 2020 MTP/SCS. Finally, the fate of SB 1 hinges on the outcome of Proposition 6 in November.
The proposed CapCity expansion is emblematic of multiple other prospective projects in the region, and raises questions about historic approaches to longstanding problems as well as approaches to future challenges the region faces. We acknowledge that the challenges involved are significant, and that a rethinking of potential solutions also has great hurdles. We believe that the convergence of challenges and opportunities we face warrants an exploration of additional tools to increase travel-mode options, support infill housing and economic needs, and reduce VMT with increased transit operations and emerging strategies such as congestion pricing and shared mobility.
We would all benefit from a broadly based conversation regarding alternative solutions for regional mobility before major public funds are committed to significant increases in highway capacity. We hope that you will consider cooperating in such a discussion with ECOS, and we are sharing this letter with other organizations and government bodies that we hope to include in this conversation as well. We look forward to discussing possible meeting times and locations.
Sincerely,
Ralph Propper
ECOS President

Click here to read the full letter in PDF.