Here is a summary of our comments: 1) We find the climate change analysis used as the basis for the GSP is not sufficiently robust to reflect currently anticipated climate change conditions for the region. The analysis does not reflect current science. For this reason, we suggest DWR provide more direction in this area for future GSP updates. 2) We believe a review of the GSP utilizing Article 6, Section 355.4 finds the plan deficient in several important areas. Our findings are listed in more detail below. DWR should work with the subbasin GSAs to address the shortcomings described below before approving the GSP.
Over the past several years local Groundwater Sustainability Agencies (GSAs) charged with managing the region’s groundwater have been assessing the condition of the region’s groundwater resources and developing monitoring systems and management plans and projects to maintain the sustainability of these resources for the foreseeable future. These efforts have resulted in the completion of three Groundwater Sustainability Plans (GSPs) that cover each of the region’s groundwater subbasins – North American Subbasin, South American Subbasin, and Cosumnes Subbasin. The GSPs respond to State required planning criteria outlined in the 2014 Sustainable Groundwater Management Act (SGMA). The California Department of Water Resources webpage has information about SGMA, the GSP planning process, and a public portal containing the three GSPs for the Sacramento region.
ECOS, through the Water Committee, has participated in the development of these GSPs by attending public meetings and workshops, and providing comments on the draft plans. We have condensed these comments into a matrix comparing comments for each of the three GSPs. The matrix contains a summary of each original comment and, in bold, the actions taken by the GSAs to address each comment as documented in the final adopted GSPs. The full text of each ECOS comment letter can be found on the ECOS web site.
While some comments have been addressed in the final plans, others were not. For example, key aspects of the GSPs are six sustainability indicators that establish thresholds for when management actions must be taken to assure continued subbasin sustainability. The North American Subbasin GSP calls for management actions to be taken after one year of one or more of the GSP sustainability indicators exceeding action levels thus indicating the subbasin is in trouble. Unfortunately, the South American Subbasin allows three years of indicator exceedance that may lead to no actions being taken until the fourth year of an indicator being exceeded. The Cosumnes Subbasin did adjust their corresponding exceedance time periods but still allow a problem to exceed one or more threshold criteria for at least two years before actions to remedy the situation are taken. ECOS has argued that a one year exceedance criteria is acceptable and should be utilized in all three GSPs.
ECOS also believes climate change is not effectively addressed in the plans. All three GSPs base their management actions on a climate scenario that seems less realistic than current climate experience and the latest climate science indicates. This errant planning assumption may significantly overestimate the amount of groundwater available to meet demands in the future. If not corrected, sustainable management of the subbasins may be very difficult within the next decade.
ECOS members are meeting with the local GSA representatives to explore options to address our concerns prior to the next GSP updates which are due in 2025. Depending on the outcome of these meetings ECOS may find it necessary to participate in the State’s GSP public comment process.
On September 8, 2021, ECOS and Habitat 2020 submitted a letter regarding the Groundwater Sustainability Plan of the South American Sub-basin (SASb), just south of the American River.
Climate change in the Sacramento region requires innovation to deal with more extremes in precipitation. In wetter years, we should pump water into groundwater basins so that we can pump it out during drier years. Just south of the American River is the South American Sub-basin (SASb) that we agree should be used this way. The SASb Groundwater Sustainability Plan includes a Sustainable Yield value – the amount of groundwater that can be extracted annually from the SASb while maintaining it at a sustainable level. This letter provides comments on how the draft Groundwater Sustainability Plan develops the Sustainable Yield level and proposes management actions that should be taken to ensure the SASb’s Sustainable Yield is maintained in the future.
ECOS, as a Water Forum signatory, is working in concert with all of the Forum members to address the current drought. Unfortunately higher temperatures and periods of drought are increasing in the Sacramento region and we have to prepare for them. The following press release has some important water saving actions you can take and here is another one that will contribute to our current drought situation and the future impacts of climate change as well:
Begin the transition to a beautiful, low-water landscape in your home, business, or public space by removing half of the turf grass this summer. For every one thousand square feet of lawn removed, 90 gallons of water is conserved each time that lawn would have been watered. Now you are ready to add low-water, local native plants and drip irrigation this coming winter. The California Native Plant Society website has information on how to remove your lawn, lists of local native plants that fit your needs and landscape conditions, and tips on how and when to plant them. If you have trees in the lawn area being removed, don’t forget they will still need to be watered.
Landscaping while very important for all of us is a major source of water use. We want beauty and shade in our outdoor spaces; and insects, birds, and animals depend on the plants we choose to survive. Local native plants not only save water, they significantly contribute to the beauty of our region and are critical and highly desirable habitat for local insects, birds and animals.
Ralph Propper, Board President, ECOS
July 8, 2021
Sacramento, Calif. – The following statement was issued today by Jessica Law, Executive Director of the Water Forum, and Sean Bigley, Board Chair of the Regional Water Authority, in response to Gov. Gavin Newsom’s Proclamation of a Drought State of Emergency, expanding the emergency to nine additional counties, and asking the public to voluntarily conserve 15 percent.
“The Governor’s announcement today underscores the severe drought conditions throughout California and in the Sacramento region.
“Sacramento-area leaders across the region’s major municipalities yesterday issued a news release imploring the public to increase their conservation efforts, and we support the Governor’s call for a voluntary 15 percent reduction.
“We understand that the public has continued to conserve since the last drought, and we applaud those efforts. Now, we are asking residents to do more. Increasing conservation this summer will help the environment of the Lower American River and decrease the potential for water shortages in 2022 if drought conditions persist.
“There are many easy and quick water-saving actions that can be taken today, such as dialing back sprinklers by two minutes (while continuing to water your trees), making sure sprinklers and drip irrigation run in the morning, adding mulch to conserve moisture and fixing household leaks.
“Also, there’s never been a better time to take advantage of the many rebate programs available to help with downsizing or replacing a thirsty lawn with beautiful low-water plants or upgrading to efficient irrigation and fixtures.
“You can find more water-saving tips, information about rebates and landscape watering guidelines at BeWaterSmart.info.”
The Sacramento Water Forum is a diverse group of business and agricultural leaders, citizen groups, environmentalists, water managers and local governments working together to balance two co-equal objectives: to provide a reliable and safe water supply for the Sacramento region’s long-term growth and economic health; and to preserve the fishery, wildlife, recreational, and aesthetic values of the lower American River. Learn more at waterforum.org.
The Regional Water Authority (RWA) is a joint powers authority representing 20 water providers serving 2 million people in the greater Sacramento region. Formed in 2001, its primary mission is to help its members protect and enhance the reliability, availability, affordability and quality of water resources. Learn more at rwah2o.org.