Comments regarding sufficiency of South American Groundwater Sustainability Plan

April 15, 2022

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.

Click here to read the letter in full.

Regional Groundwater Sustainability – The Plans are Finished so what’s Next?

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.

Click here to view the matrix.

California calls for more local water conservation

By Kathleen Ronayne, Associated Press | March 29, 2022 | The Sacramento Bee

Californians will be asked to further cut back on their water use, state officials said Monday as they warned water scarcity will shape the future of the drought-stricken state. But those cut backs would come from cities and local water districts, not the state, with members of Gov. Gavin Newsom’s administration saying allowing local retailers to set conservation needs is the best approach in a state of nearly 40 million people where water needs vary.

Read more at: https://www.sacbee.com/news/business/article259883770.html#storylink=cpy

As drought deepens, Californians are saving less water

By Hayley Smith, Los Angeles Times | March 15, 2022 | The Sacramento Bee

LOS ANGELES — California will end winter in a perilous position as record-shattering dryness converges with lagging water conservation efforts in nearly every part of the state, officials said Tuesday. After months of cutting back, new data from the State Water Resources Control Board show that rather than conserving water, Californians increased urban water use 2.6% in January, compared to the same month in 2020 — the baseline year against which current savings are measured.

Read more at: https://www.sacbee.com/news/environment/article259443499.html#storylink=cpy

ECOS letter on Water Agencies’ Participation in Sacramento Area Turf Replacement Study

On February 14, 2022, the Environmental Council of Sacramento submitted a letter to Sacramento Area Water Agencies regarding their participation in a Sacramento Area Turf Replacement Study. Below is the content of the letter.

To: Sacramento Area RWA Water Agencies

The Environmental Council of Sacramento’s Water Committee has begun a project to calculate the potential water savings from conversion of ornamental grasses (turf) to drought-tolerant landscaping in the American River water purveyor area (i.e. Regional Water Authority member agencies). We are interested in your input and participation in this study. This letter describes the study plan. For more information or to participate, please contact Katrina Harrison, PE, ECOS Water Committee member and Project Manager, at kandchf[at]gmail[dot]com or (408) 644-9108.

The Water Committee has met with representatives of the Department of Water Resources (DWR) to share methodologies and inquire about data sources. DWR staff has been helpful but has suggested relying on publicly available datasets. Therefore, Water Committee plans to calculate the area of current ornamental grasses using 2019 or 2020 publicly available fine scale (~1 foot pixel size wherever possible) aerial and infrared imagery. Aerial images include National Agriculture Imagery Program (NAIP), Bing imagery, Planet, and NearMap.

This imagery dataset will be analyzed using the machine learning, or neural net, algorithms of the software program eCognition to determine turf grass area. Land classifications will be digitized in several sample areas, and the computer model will be trained using those areas including calculating the Normalized Difference Vegetation Index (NDVI) as well as a Tree Grass Difference Index. The aerial imagery processing will be validated manually to develop a calculation of the accuracy and estimated error bounds of the analysis.

Following calculation of the area of turf grass, ECOS Water Committee members plan to use California Native Plant Society information on the evapotranspiration and density of different plant palettes – lawn versus drought-tolerant landscaping – to determine the difference in water use. This difference will be multiplied by the area to determine potential water savings.

We appreciate any insight or methodology suggestions you may have. We would like to share our draft results with study participants and will make the final product available to the Water Forum for its consideration in the ongoing Water Forum 2 discussions. If you have an interest in participating, please contact Katrina Harrison at kandchf[at]gmail[dot]com or Ted Rauh at tnrauh[at]att[dot]net. We would appreciate hearing from you before the end of February so that your input can be included in the study.

Click here to view a PDF of the letter.

An ode to our native oaks

By Stephanie Robinson | October 11, 2021 | Sacramento Tree Foundation

Out of all the wonderful trees that make up our urban forest in Sacramento, native oaks hold a special place in our hearts. Ask any staff member what their favorite tree is, and chances are many will mention the valley oak. Native plants are trending, and for good reason – they are so important to our natural ecosystems. But native trees, and native oaks in particular, carry the biggest impact.

This Oaktober, we’re celebrating the oaks that are native to the Sacramento region – the valley oak (Quercus lobata), blue oak (Quercus douglasii), and interior live oak (Quercus wislizeni). These majestic trees provide more benefits than any other tree that grows locally. Thanks to donors and volunteers like you, every year we plant 3,200 native trees throughout the region, both in reforestation sites and at places like homes, parks, and schools.

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