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

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It’s Not Too Late to Sponsor the Environmentalist of the Year Awards!

Dear Friend of the Environment:

The Environmental Council of Sacramento (ECOS) has been hosting the Environmentalist of the Year awards since 1973. The awards ceremony is a time to celebrate and recognize the past year’s regional champions and community sustainability successes. It is also a time to reflect on the work we still have in front of us in the year ahead.

Your sponsorship is an investment in the ongoing success of ECOS and provides you with significant recognition of your contribution and environmental stewardship. As you may know, ECOS is a 501(c)(3) nonprofit organization comprised of a broad range of organizations and individuals who unite to create a single voice for local environmental concerns. Our mission is to achieve regional and community sustainability and a healthy environment for existing and future residents. ECOS works proactively with our members, member organizations, local government, and community groups to energize and create positive change in the Sacramento region as we work to develop thriving communities.

2018 Awardees

Environmentalist of the Year – Jack Sales

Jack joined International Dark-Sky Association (IDA) in 1993 and started the first California Chapter in 1996. Jack and his wife Beverly have traveled the length of California with an information display which has introduced thousands of individuals to the issue of Light Pollution and impacts of Artificial Light at Night (ALAN). He is being awarded for his focus of the last few years on understanding the impacts of ALAN on predation of juvenile and adult salmon, the numerous talks he has given on the subject and his influence on reducing light pollution from a bridge in Roseville, California.

Environmentalist of the Year – Jennifer Donlon Wyant

Jennifer Donlon Wyant is the Transportation Planning Section Manager for the City of Sacramento. Jennifer manages the transportation planning team as well as a number of programs including the Vision Zero and the Active Transportation programs. She lives in Sacramento and walks and bikes to neighborhood businesses and parks and loves the community and relationship building that can happen by walking and bicycling. Jennifer is being awarded for her work to bring Protected Bike Lanes to Sacramento and on the implementation of the City of Sacramento’s Bicycle Master Plan.

Lifetime Achievement Award – Matthew Baker

Matt Baker began working for Habitat 2020 and the Environmental Council of Sacramento (ECOS) in 2008 and currently serves as our Land Use and Conservation Policy Director. He is being awarded for his work with the Sacramento Area Council of Governments (SACOG), specifically his valuable analysis of the Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS). Another achievement we want to honor is his work on the California Heartland Project, including cutting-edge work with UC Davis in the mapping and analysis of the region’s natural resources, habitat and ecosystem services.

Community Organizer Award – Dyane Osorio

Dyane is the Director of the Mother Lode Chapter of the Sierra Club. She has held the position since 2016. She co-founded the higher-education non-profit, ‘Dream. Develop. Do.’ in 2009. She has more than 9 years of non-profit sector experience and is passionate about social and environmental justice; she understands that we cannot have one without the other. She is being awarded for her work with DREAMers, promoting activism for immigrants’ rights, skillfully supporting the Sierra Club Mother Lode Chapter groups, fighting for environmental justice, forwarding climate action, and working to increase transportation access for all residents.

Public Servant Award – Assemblymember Kevin McCarty

Assemblymember Kevin McCarty is a member of the California Legislative Black Caucus. Prior to being elected to the Assembly in 2014, he was a Sacramento City Councilmember. Assemblymember McCarty was elected to the California State Assembly in 2014 to represent the 7th Assembly District, which includes Sacramento, West Sacramento and parts of unincorporated Sacramento County. He is being recognized for his long-standing dedication to our local environment throughout his time as an elected official; specifically, for his recent work in establishing the Lower American River Conservancy.

Sponsorship Levels

John Muir Sponsorship – $2,500
Benefits include all those of the Rachel Carson Sponsorship, plus:
– A listing in the event program at the highest level, including your logo (if you have a logo)
– An additional 4 tickets to the event (10 total)
– At least two social media shout-outs in recognition of your contribution

Rachel Carson Sponsorship – $1,000
Benefits include all those of the George Washington Carver Sponsorship, plus:
– A higher-level listing in the event program
– An additional 2 tickets to the event (6 total)

George Washington Carver Sponsorship – $500
Benefits include all those of the Ansel Adams Sponsorship, plus:
– A higher-level listing in the event program
– An additional 2 tickets to the event (4 total)

Ansel Adams Sponsorship – $250
Benefits include:
– Your name, logo and a link to your website (if applicable) on the ECOS website
– A special listing in the event program
– 2 tickets to the event
– Verbal recognition during the awards ceremony
– At least one social media shout-out in recognition of your contribution

How to Sponsor the Environmentalist of the Year Awards

To donate online, just click on the ‘Donate’ button in the left hand margin of this page, on our homepage, or in the menu bar at the top. Please indicate the intent of the check (Environmentalist of the Year award).

If you would prefer to mail a check, please make it out to, and send it to, Environmental Council of Sacramento, P.O. Box 1526, Sacramento, California 95812-1526. Please indicate the intent of the check (for example, “Environmentalist of the Year Awards”).

Since we are a 501(c)(3) nonprofit organization, your donation is tax-deductible to the extent permitted by law. Thank you very much for your consideration and please remember that your generous support makes a significant difference in our day to day operations. Please feel free to contact us with any questions at office [at] ecosacramento [dot] net.

Click here for this letter in PDF format.

Sincerely,

Ralph Propper, President of the Board | ECOS

The Environmental Council of Sacramento

P.O. Box 1526, Sacramento, CA, 95812

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Wild and Scenic Film Festival on Tour in Sac!

Don’t miss the Wild & Scenic Film Festival on Tour in Sacramento on Saturday, October 20th, 2018! We’re offering a diverse array of films that are all relevant to local environmental issues. We also have a raffle and silent auction that are an environmentalist’s dream!

Click here to learn more about the film festival.

Click here to buy tickets.

Check out our sponsors here.

Want to be a sponsor? Click here.

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