Unique Opportunity to Invest in Some Fine Art and Help Save the Environment

Long-time regional environmental champions Mike Eaton and Charity Kenyon have moved from their Delta home and organic farm to the Bay Area. Mike was President of the Environmental Council of Sacramento (ECOS in 1985-86) and went on to serve as Director of the Cosumnes River Preserve for over a decade. As a parting gift to the region, they have donated to ECOS three original Roman Loranc photographs of the Cosumnes River Preserve with the express understanding that we would sell them and use the money to fund the active lawsuits against Elk Grove (see expanded description of lawsuits at the end). Mike and Charity also gave ECOS three Roman Loranc photographic posters with the same understanding.

Consultation with a gallery in the Delta that sells Roman Loranc’s work indicates that the photos are worth between $1500 and $2000 each, the framed poster is worth $500, and the unframed posters are worth $200 each. The gallery would charge a fairly high premium to sell them. We are hoping to make a direct sale to a buyer without having to dilute the return by using a gallery’s services.

If you are willing to pay $1000.00 or more for one of these original photographs, please contact Alexandra Reagan at office[at]ecosacramento[dot]net. We would also be interested in offers on the posters. The photos and the posters will be at the ECOS office if you want to make an appointment to see them.

These photos were taken with a large format (4 x 5) film camera and were developed by hand by the artist himself. They would be a beautiful addition to anyone’s living space, and they are likely a savvy investment in fine art.


Biography of Roman Loranc

Roman Loranc is a living, modern-day master of fine art black and white photography. He was born in the city of Bielsko-Biala, southwestern Poland, in 1956 during the communist era. In 1982, at 26 years of age, he immigrated to Madison, Wisconsin, and in 1984 he moved from the Midwest to Modesto, California. Much of his early, better-known photographic work was created in California’s Central Valley. He moved to Northern California near Mt. Shasta in 2006 where he currently resides.

Before arriving in the United States he did not have access to the high-quality photographic books that are found so readily in America. What he remembers most about the work he saw in Poland was that it had a general dullness to the prints; so when he first saw original works by the great photographers Ansel Adams, the Westons and Morley Baer, he was in awe of the richness of tone, the depth of the blacks and the glowing light that seemed to come from the prints. He immediately knew that this is what he wanted to produce technically with his own work.

Loranc’s first inspiration as a visual artist came from the paintings of Chelmonski, Stanislawski and Pankiewiz. He was drawn to the richness of their work, their sense of drama and use of light and dark. A painter interprets his subject before it is painted, filtering the scene using his skill and artistic sensibility. This was something that he wanted to achieve with his photography.”

He enjoys photographing meditative things, like tule reeds, when the light is soft and just right for such photography. Such smaller intimate subjects, which are often overlooked because of their commonplace nature, he finds to be quietly expressive. He believes that minimizing what is included in the frame not only helps focus the viewer’s attention, but more clearly conveys the message of the photograph.

“I appreciate that light is a messenger,” he says, “revealing the world at every instant.” “The magic of photography is its ability to slice a moment out of time, which you can later hold as a print in your hands. There are special moments when I know that I have connected with something bigger than myself, when I have focused the camera on the essence of my subject. At that moment I feel a fullness that I cannot describe in words. It is a visual experience, and I can only refer you to my finished print to explain the fascination and connection I feel for the place I have photographed.”

Loranc first began photographing river tules at the Nature Conservancy (Consumnes River Preserve) in Galt, part of the Great Central Valley of California. His aim was to show the subtle beauty of the disappearing wetlands. Many people overlook this beauty because it is not easily accessible, but Loranc likes the idea that this area is being preserved more for wildlife than for people. He hopes that when people see his photographs they will want to help protect and preserve these fragile lands. This is the crucial impetus behind his efforts with the camera.

Today, Roman says he faces different challenges than he did many years ago when he first decided to make fine art photography his vocation. Originally, when he began to work solely on photography, he was challenged by not having a secure source of income. Now his biggest challenge is time. It is the essence of everything in life and how we spend it determines our happiness and personal fulfillment.

The work of Roman Loranc is not digital in any respect. Everything is done by his own hand and the toned, silver-gelatin prints he crafts are the final result. A computer display cannot convey everything that he is able to capture in his prints – not the depth or richness of blacks, the sparkle of the highlights, the subtlety of the tonality. There is a presence one feels when standing in front of a hand-printed photograph, it’s as if one can bear witness to the soul of the photographer. The computer display and the hand-printed silver-gelatin print are not equivalents!

Loranc doesn’t follow the traditional theory that one must have all the shades of gray plus complete black and complete white in order to have a great photograph. Each photograph demands a unique print interpretation in order for it to have voice and be compelling. The only thing all great art, including photographs, has in common is the intense passion of the artist for his or her work. Technical skills must be secondary to the overall impression of the photograph because they are craft and great art is more than technical skill. A great photograph is one that is infused with the artist’s passion.

Roman Loranc photographs with a Linhof 4×5 field camera. A good deal of his work is done with a 210mm Nikkor lens. He only uses Kodak Tri-X film, which he stockpiles in a freezer because he feels uncertain what the availability of film may be in the not-to-distant future. He develops his negatives with the Gordon Hutchings PMK formula from Photographer’s Formulary using a Jobo processor and then prints with Ilford glossy paper which is archivally washed, selenium and sepia toned and then archivally dry mounted. All work is done by the artist.


What Are The Two Lawsuits About?

The first is an effort to overturn a Local Area Formation Commission (LAFCo) decision to allow an expanded sphere of influence (SOI) that is the first step for Elk Grove to expand south of its current borders into an area that is invaluable to many of the species that call the Cosumnes River Preserve home. The lower reach of the Cosumnes River floods every seven to ten years inundating large swaths of the Preserve and surrounding areas. Migrants like Sandhill Cranes rely on the important upland habitats south of Elk Grove during these stochastic events, and with climate change and predicted sea level rise the need may be constant. LAFCo made this decision despite the fact that it was clearly evident that there was no demonstrated need for an expanded SOI at this time, and probably not for the next 30 years. LAFCo also completely ignored substantial evidence about the lack of available water.

The second lawsuit challenges Elk Grove’s decision to ignore its Swainson’s Hawk ordinance and allow for mitigation of their Southeast Planning Area to be twenty miles away in an area known to be at the very fringe of the hawk’s usable range in the Central Valley. Essentially Elk Grove wants to allow the destruction of an area that boasts usage by ten pairs of hawks for an area that has only one pair using it. If Elk Grove successfully makes an end run around its Swainson’s hawk ordinance we can expect that they will continue to do so on a regular basis because these mitigation lands are half the price of appropriate lands.
Gallery


Part 1: The Photos


Original photograph number 1 – SOLD
Description: Photo of a forest at the Cosumnes River Preserve
Frame size: 29” x 23”
Photo size: 19” x 14 ½”



Original photograph number 2 – SOLD
Description: Photo of a foggy forest at the Cosumnes River Preserve
Frame size: 22” x 38”
Photo size: 16” x 20”


Original photo number 3
Description: Photo of oak trees in water at the Cosumnes River Preserve
Frame size: 16” x 20”
Photo size: 9 ¼” x 11 ¼”


Part 2: The Posters



Framed poster (unsigned)
Frame size: 30” x 24”
Image size: 21” 16”



Poster number 1 (signed)
Description: Wetland
Poster size: 31 ½” x 27”



Poster number 2 (unsigned)
Description: Lithuanian church
Poster size: 27” x 34”

For this information in PDF, please click here.

Light Pollution Effects on Wildlife and Ecosystems

Source: International Dark-Sky Association

For billions of years, all life has relied on Earth’s predictable rhythm of day and night. It’s encoded in the DNA of all plants and animals. Humans have radically disrupted this cycle by lighting up the night.

Plants and animals depend on Earth’s daily cycle of light and dark rhythm to govern life-sustaining behaviors such as reproduction, nourishment, sleep and protection from predators.

Scientific evidence suggests that artificial light at night has negative and deadly effects on many creatures including amphibians, birds, mammals, insects and plants.

Artificial Lights Disrupt the World’s Ecosystems

Nocturnal animals sleep during the day and are active at night. Light pollution radically alters their nighttime environment by turning night into day.

According to research scientist Christopher Kyba, for nocturnal animals, “the introduction of artificial light probably represents the most drastic change human beings have made to their environment.”

“Predators use light to hunt, and prey species use darkness as cover,” Kyba explains “Near cities, cloudy skies are now hundreds, or even thousands of times brighter than they were 200 years ago. We are only beginning to learn what a drastic effect this has had on nocturnal ecology.”

Glare from artificial lights can also impact wetland habitats that are home to amphibians such as frogs and toads, whose nighttime croaking is part of the breeding ritual. Artificial lights disrupt this nocturnal activity, interfering with reproduction and reducing populations.

Click here to continue reading this on the International Dark-Sky Association’s website.


Outdoor Lighting Basics

Modern society requires outdoor lighting for a variety of needs, including safety and commerce. IDA recognizes this but advocates that any required lighting be used wisely. To minimize the harmful effects of light pollution, lighting should

  • Only be on when needed
  • Only light the area that needs it
  • Be no brighter than necessary
  • Minimize blue light emissions
  • Be fully shielded (pointing downward)

Learn more at www.darksky.org.

10,000 homes – and lots of shopping – planned for new neighborhood near Sacramento airport, by Tony Bizjak, Mar 1, 2019, The Sacramento Bee

The project…would be built in an environmentally sensitive and floodable area of Natomas, and already is the subject of numerous concerns.

…environmentalists argue that such a large development means paving prime wildlife habitat and farmland. The project, they say, could undermine existing habitat conservation agreements that limit the amount of acreage to be developed in the Natomas basin.

The site also is outside of the county’s existing urban development boundary. In order to allow development, county officials would have to amend the county’s growth plan and extend the boundary west toward the river.

Click here to read the full article.

Click here to read the Environmental Council of Sacramento’s formal comments on this proposal.

ECOS and Partners Letter re Upper Westside of North Natomas, Feb 22, 2019


Area of “The Boot,” aka the Upper Westside Specific Plan site

February 24, 2019 [UPDATE]

On Tuesday, February 26, 2019 at 2:15 pm, the County of Sacramento Board of Supervisors will consider starting a master plan process to urbanize 2,000 acres of prime agricultural land in Natomas (covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake). If possible, please attend the hearing. Please send a note to the Board (emails below) opposing this expansion on Farmland. Suggested language follows.

Click here to view the letter from ECOS, Habitat 2020, Sierra Club and Friends of Swainson’s Hawk, delivered February 22, 2019.

Email string for Supervisors (copy and paste)
SupervisorSerna[at]saccounty[dot]net, nottolid[at]saccounty[dot]net, susanpeters[at]saccounty[dot]net, kennedyp[at]saccounty[dot]net, supervisorfrost[at]saccounty[dot]net, BoardClerk[at]saccounty[dot]net, LundgrenJ[at]saccounty[dot]net.

Suggested text:

I oppose development of farmland in Sacramento County and ask you to deny the request to create an Upper Westside Master Plan for 2000 acres in the Natomas “Boot.” My reasons are:

  1. This proposal violates County General Plan policies, including the Urban Services Boundary and agricultural preservation policies, to preserve agricultural and open space lands in the County.
  2. There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized. There is no economic need to provide for more zoning for urban uses.
  3. There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin and these projects have a Habitat Conservation Plan in place to mitigate for their impacts on wildlife and are included in regional air quality and transportation plans. There is no economic rationale for advancing development in the portion of the basin that lacks infrastructure and mitigation programs.
  4. I support the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan and directly conflict with the preserves located in and adjacent to the plan area.

Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.

Thank you,

Friends of the Swainson’s Hawk
swainsonshawk[at]sbcglobal[dot]net
Judith Lamare
James Pachl
916 769 2857 c


February 11, 2019

Please read the latest call to action below, from Habitat 2020 Member Organization, Friends of the Swainson’s Hawk:

Landowners in the Boot area of North Natomas have asked the Sacramento County Board of Supervisors to start the legal process needed for approval of a development plan for 2000 acres of urban development in the County covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake.

The proposal directly contradicts and would undermine the Natomas Basin Habitat Conservation Plan (NBHCP) which covers the entire Natomas Basin. This plan — a binding contract between the city of Sacramento and County of Sutter and the state and federal wildlife agencies — relies in part on the Boot continuing to remain in agriculture and open space. It protects the Swainson’s Hawk population which nests along the Sacramento River and forages for rodents in the Basin, including the Boot area. The 2001 Natomas Basin Habitat Plan designates the mile-wide strip of land, in County jurisdiction, next to the Sacramento River levee as the Swainson’s Hawk Zone, which must remain free of urban development for the HCP to succeed.

Most of the proposed Boot development would be within the Swainson’s Hawk Zone. The City’s Incidental Take Permit (issued by USFWS and CDFW) for new development in North Natomas depends on the continued integrity of the NBHCP, including continuation of agriculture and open space in the Swainson’s Hawk Zone, and would be jeopardized by new development in the Boot.

Bob Thomas, who is the project representative, was formerly the City Manager who signed the NBHCP Incidental Take Permit as City Manager, and is very aware of the importance of the Swainson’s Hawk Zone, including the Boot area, to conservation of threatened species and the City’s buildout of North Natomas.

Please help us convince the County Board of Supervisors to deny this request. Letters to the Board members can include these important points:

  1. Urbanization planning in the Natomas Basin is contrary to important County General Plan policies, including the Urban Services Boundary, and policies to preserve agricultural and open space lands in the County.
  2. The Urban Services Boundary (which excludes urbanization in this area) is the basis for our regional air quality and transportation plans which protect our health and prevent the congestion that urban sprawl engenders. This is our region’s core strategy for Climate Action and mitigation for Climate Change.
  3. There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized, and thousands of acres of vacant land already zoned for development. There is no economic need to provide for more zoning for urban uses.
  4. There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin. These projects have planned infrastructure and mitigation programs. There is no economic rationale for considering development in the portion of the basin that lacks infrastructure and mitigation programs.
  5. Express your support for the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan. Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.
  6. For residents of Natomas, public safety, emergency evaluation, freeway and airport access and other issues may come to mind in contemplating urbanization west of El Centro and North of I-80.

The hearing is set for 9:30 am, Tuesday, Feb 26, 2019.

The emails for the Board are: SupervisorSerna[at]saccounty[dot]net, nottolid[at]saccounty[dot]net, susanpeters[at]saccounty[dot]net, kennedyp[at]saccounty[dot]net, supervisorfrost[at]saccounty[dot]net, BoardClerk[at]saccounty[dot]net, LundgrenJ[at]saccounty[dot]net.

Please also cc or forward what you send to swainsonshawk[at]sbcglobal[dot]net.

Send an email to the Board Clerk requesting hearing notice and notice of availability of documents: BoardClerk[at]saccounty[dot]net.

For more information on the proposal, check the County website at https://planningdocuments.saccounty.net/. Search for “Upper Westside Specific Plan” Control #: PLNP2018-00284


Swainson’s Hawk in flight

Please share this call to action with friends and family who can help.

Thank you.

Friends of the Swainson’s Hawk
swainsonshawk[at]sbcglobal[dot]net
Judith Lamare
James Pachl

Comments re the Regional Water Authority (RWA) Planning Forum

On January 11, 2019, the Environmental Council of Sacramento and Habitat 2020, sent comments regarding the Regional Water Authority (RWA) Planning Forum.

Below is the content of our letter in full.


John Woodling
Executive Director
Regional Water Authority
5620 Birdcage Street, Ste 180
Citrus Heights, CA 95610

Subject: Regional Water Authority (RWA) Planning Forum

Dear Mr. Woodling,

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.

ECOS/Habitat 2020 are heartened by the extensive work the Regional Water Authority (RWA) and its member organizations are doing to improve the Sacramento Region’s (Region) water reliability and security. The 2018 update of the American River Basin Integrated Regional Water Management Plan (“Plan”) provides a solid framework to guide the Region’s water purveyors and GSAs to improve interconnectivity; engage in water transfers, recharge and banking; plan for and manage the three American River Subbasins sustainably; and, ensure that the Region’s three river systems have sustaining flows, temperatures, and water quality; and, provide the needed habitat for the flora and fauna they support.

We understand that RWA has an established review group called the Planning Forum. ECOS/Habitat 2020 would be pleased to formally join this group. If this meets with RWA needs please include Ted Rauh as our contact point. Ted can be reached at tnrauh[at]att[dot]net or at (916) 261-8011.

We also 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 the Plan lays out a prudent path for the region’s water future. We would be pleased to participate with RWA in the development and implementation of this campaign. ECOS/Habitat 2020 represent, or are affiliated with, most of the environmental and community based groups in the Region, and have strong ties with conservation and other public interest groups as well. We believe we can be of significant assistance. However, we believe several key issues need to be addressed to ensure the full success of outreach effort. If these issues are not addressed important aspects of the Plan may be called into question because of its failure to address the Region’s three groundwater subbasins equally and equitably.

Specifically, we strongly believe that each Subbasin needs to have comprehensive Subbasin descriptive modeling systems that assure accurate accounting and impact assessment of both recharge and pumping operations, and accurately describe the flows and elevations of groundwater through the Subbasin so that a Subbasin management approach can be carried out that is capable of responding to delayed changes within the Subbasin due to pumping and recharge operations, and responds to GDE and other triggers. RWA is in the process of establishing this type of modeling system for the North American Subbasin and is actively working with the other two Subbasins to adopt the same system or establish compatible systems. We fully support these efforts.

The Plan includes the potential for substantial water banking resulting from excess storm water runoff. We have received information from UC Water experts that this resource constitutes a real potential for our region. SAFCA is moving forward with a series of actions outlined in the Plan that can make significant quantities of excess storm water available over sufficient time frames to allow for selective regional groundwater recharge and banking under the right conditions. A critical step in satisfying some of these conditions is the completion of a thorough analysis of where within the Region the prime recharge and extraction zones are located. This analysis should include each area’s compatibility with existing land use and water management/conveyance constraints. This information will allow for appropriate modeling to be developed so that the actual storage, flow, and recovery potential of these groundwater resources can be fully understood. We understand that UC Davis is preparing a project plan to carry out this analysis that may be ready for funding in the near future. We think that a project to determine this information should be included within the Plan.

The above observations are not intended to deter RWA’s important planning and project management activities, but rather to point out several gaps that if not addressed, may diminish the extensive work that has already been done. Regardless of RWA’s ability to react to our suggestions, ECOS/Habitat 2020 stand ready to work collaboratively with RWA to communicate the importance of regional water security 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 comprehensive water security that can benefit the environment. Robert Burness can be reached 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


Read the letter in PDF by clicking here.

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