Support for the Cosumnes Subbasin Groundwater Authority’s (CGA) Demand Management and Multi-Benefit Recharge Projects and Actions to Achieve

On June 14, 2022, ECOS submitted a letter of support for the Cosumnes Subbasin Groundwater Authority’s (CGA) Demand Management and multi-benefit recharge projects and actions to achieve.

Below is the content of the letter.

Subject: Support for the Cosumnes Subbasin Groundwater Authority’s (CGA) Demand Management and Multi-Benefit Recharge Projects and Actions to Achieve
We understand that CGA is working to secure funding for implementation of the multi-benefit recharge and demand management Projects and Actions identified in the CGA Groundwater Sustainability Plan (GSP).
ECOS appreciates CGA’s initiative to make progress towards basin sustainability, environmental uplift, and shallow well protection.
If a letter of support from ECOS will be of value in assisting CGA in obtaining grant funding for these Projects and Actions, please don’t hesitate to contact us. We are committed to support environmentally beneficial efforts to return the Cosumnes subbasin to sustainability.
We note that the amount of annual groundwater pumping in the subbasin is based on estimates because of the low number of wells with actual pumping metered data available to the GSAs. Given the current condition of the subbasin and the need to rely in part on demand management to reach sustainability, we support efforts to increase the number of metered wells and other actions the GSAs pursue to improve the reliability and accuracy of groundwater pumping information utilized in the management of the Cosumnes subbasin.
We also appreciate the development of the CGA Citizen Advisory Committee. We have identified ECOS representative Neil Dubrovsky to serve on the committee. Neil has extensive groundwater expertise and experience and is particularly familiar with public sources of groundwater monitoring data that may prove useful as projects are developed.
ECOS recognizes the ongoing, complex effects of climate change on the environment and people
in the Cosumnes and Greater Sacramento regions, and California as a whole. We believe that action is needed now and that time is of the essence. Collaborative efforts that address both demand management and multi-benefit recharge, as well as implementation of real time monitoring networks, offer the best chance for timely improvements to basin sustainability, environmental uplift, and shallow well protection.
We look forward to working with CGA in its journey toward returning the Cosumnes subbasin to sustainability.

Click here to view the letter in full.

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.

If the Sierra snowpack vanishes as feared, California will need ideas like this for water

By the Sacramento Bee Editorial Board | February 2, 2022 | The Sacramento Bee

Sacramento — which once only had to worry about seasonal floods — now worries each year about delivering water to its citizens in a hotter and drier California. But there is a way for Sacramento to capture rain and snow, and for the broader region to keep surface reservoirs like Folsom and Oroville lakes nearly full. This same technique could help Sacramento capture enough water to share with neighboring areas in dry years, as well as to store it when we need it most.

Local Groundwater Sustainability

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.

Background

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.

Click here to read our letter in full.

Photo by eberhard grossgasteiger from Pexels

ECOS Comments on South American Subbasin Groundwater Sustainability Plan

On August 4, 2021, ECOS and Habitat 2020 submitted a letter containing our comments on the South American Subbasin Groundwater Sustainability Plan Public Draft dated June 18, 2021.

Click here to view the letter.