Comments re American River Basin Integrated Regional Water Management Plan Update

On January 11, 2019, the Environmental Council of Sacramento and Habitat 2020, sent comments regarding the 2018 update of the American River Basin Integrated Regional Water Management Plan.

Below is the content of our letter in full.


Richard M. Johnson (Sent via email to johnsonr[at]saccounty[dot]net)
Executive Director of Sacramento Area Flood Control Agency
1007 7th St, 7th floor
Sacramento 95814

Subject: 2018 update of the American River Basin Integrated Regional Water Management Plan

Dear Mr. Johnson,

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.

We are heartened by the extensive work the Sacramento Area Flood Control Authority (SAFCA) and the Regional Water Authority (RWA) are doing to improve the Sacramento Region’s water reliability, security, and flood protection. The 2018 update of the American River Basin Integrated Regional Water Management Plan (“Plan”) includes SAFCA’s efforts to improve Regional flood control, provide for storm water management, and develop excess storm water recharge opportunities all in the face of increasing storm intensity and frequency due to the impacts of climate change. We are especially interested in SAFCA’s efforts to develop and promote the potential beneficial uses of excess storm water that moves down both the American and Cosumnes Rivers. Like SAFCA, we would like to see some of this water captured to restore aquifer levels and stored in the Region’s Subbasins for future use during periods of drought. SAFCA is commended for its success in securing the financial resources required to carry out its programs and projects in this vitally important area of flood protection.

We understand that one of the next steps to acquiring this excess storm water recharge resource is to complete a thorough analysis of where within the Region the prime recharge and extraction zones are located. This analysis should include the area(s) compatibility with existing land usage and water management/conveyance constraints. We understand that Dr. Graham Fogg of UC Davis is preparing a project plan to carry out this analysis and that SAFCA has already held discussions with the Cosumnes Subbasin GSAs on this same topic. A project or projects to carry out this work in both the South American and the Cosumnes Subbasins should be a high priority for inclusion within the Plan, and again, we hope that SAFCA will take a leadership role in working with the UC Davis Water Group and the appropriate GSAs to fund this important work.

We 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 they lay out a prudent path for the region’s water future. SAFCA’s efforts will certainly be prominently featured in this public outreach effort. We hope to participate with SAFCA and RWA in this campaign. ECOS/Habitat 2020 represents most of the environmental and community-based groups in the Region and has strong ties with conservation and other public interest groups as well.

We note with keen interest the efforts SAFCA and others are making to work with the Sacramento Central Groundwater Authority (SCGA) and the Cosumnes Subbasin Groundwater Sustainability Agencies (GSAs) to join with the North American Subbasin GSAs to develop and adopt a comprehensive American River Basin descriptive modeling system (SacIWRM). The region wide adoption of SacIWRM will ensure accurate accounting and impact assessment of both recharge and pumping operations and accurately describe the flows and elevations of groundwater through and between each Subbasin. The SacIWRM will enable each Subbasin’s GSAs to adopt Subbasin management plans that are capable of responding to delayed changes within the Subbasin due to pumping and recharge operations, and respond to GDE and other triggers requiring GSA actions. We understand that SAFCA has volunteered to pay the additional costs the Cosumnes Subbasin GSAs will incur to ensure SacIWRM meets the Cosumnes Subbasin needs. We strongly hope that that the Cosumnes Subbasin GSAs will adopt the SacIWRM model and, if needed, accept SAFCA’s generous financial offer. We will engage with SAFCA and RWA in any way practical to assist in accomplishing this objective.

ECOS/Habitat 2020 stand ready to work collaboratively with SAFCA to communicate the importance of regional water security including appropriate storm water management, recharge, and flood protection; 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 a comprehensive water security investment that can actually benefit the environment. If need be, please contact Robert Burness 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

CC via email: Tim Washburn, Director of Planning, SAFCA, washburnr[at]saccounty[dot]net


Read the letter in PDF by clicking here.

A Note From Our Treasurer: ECOS Needs Your Support

January 11, 2019

Dear Friend,

I hope this letter finds you in good health. I want to highlight some of the Environmental Council of Sacramento’s (ECOS) accomplishments last year, inform you about our plans for the New Year, and ask for your continued financial support—because ECOS would not exist without support from local environmental stewards like you.
We need your support. Please consider becoming a member – better yet with a recurring monthly donation of ten or twenty bucks a month (less than the price of going out to dinner!). You can become a dues-paying member and support our community by clicking here: https://www.ecosacramento.net/membership-account/membership/.

We accomplished a lot in 2018:
· ECOS wins lawsuit securing light rail funding. ECOS secured $40.5 million for the Sacramento Regional Transit Light Rail system by settling our lawsuit challenging the Caltrans Environmental Impact Report for the Capital City Freeway Improvement Project. This money will be used to complete double tracking to Folsom, purchase low floor train cars, and resume evening service on the Gold Line.
· ECOS organizes 29th annual Earth Day. On April 22, 2018, ECOS hosted Sacramento’s annual Earth Day celebration in Southside Park—the largest annual environmental event in Sacramento County. This event now draws over 3,000 visitors to live music, 150 nonprofit and crafts vendor booths, and the largest electric vehicle display and test-drive event in the Sacramento region. Thanks to our partners the Sacramento Electric Vehicle Association and Charge Across Town, some 40 different electric vehicle models were displayed by owners and several hundred test-drives were conducted by regional EV dealers.
· ECOS advocates for underserved communities. In 2018, ECOS advocated for environmental protection in green spaces occupied by Sacramento’s growing homeless population and for expanded homeless services and transitional housing. In addition, ECOS established an Environmental Justice Committee within our organization to identify the priorities of underserved communities and help build networks in support of our mutual environmental interests, including the expansion of public transit, affordable infill housing, and living wages.
· Housing, housing, housing. With the economy continuing to improve, land use projects of increasing size and adverse environmental impact were proposed in Sacramento County last year. If the region does not accommodate the new urban housing market, sprawl will continue, threatening whatever habitat, agriculture and open space is left. So we have also paid a great deal of attention to the intensification of urban development in the region’s cities (Elk Grove, Roseville, Sacramento, Galt, Citrus Heights, West Sacramento, etc.) where the new urban housing market could be focused.

In 2019, ECOS will focus on future transportation funding options, Phase 2 hearings on the California WaterFix, local electric vehicle roll-out, environmental justice group empowerment, and local implementation of the Sustainable Groundwater Management Act next year. You can support our work by becoming a member: https://www.ecosacramento.net/membership-account/membership/.

As you know, we are a small, local organization that operates on a shoestring budget and depends on the financial support of community members like you. ECOS does a lot with a little: we have an annual budget of just thousands of dollars; with more members and an expanded budget, we can serve the community better. We know you receive requests from many organizations and hope our decades of dedicated community service and proven success earn us a spot on your list. As always, we would be extremely grateful for your support.

Happy New Year!

Best Regards,

Earl Withycombe, ECOS Treasurer

P.S. There are many ways to support ECOS. Beyond your annual donation we encourage you to become a monthly sustainer, which give us the financial stability to do more. You can do this by visiting our website (https://www.ecosacramento.net/), and then clicking on “Donate” under “Support ECOS”. We also welcome volunteers for every aspect of our work – you’ll have fun and learn skills as you help our environment. Contact us at office[at]ecosacramento[dot]net.

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

Monitoring Groundwater in Sacramento County

October 12, 2018

The South American Subbasin is located in the central portion of Sacramento County. It is primarily managed by the Sacramento Central Groundwater Authority (SCGA).

ECOS believes that Sacramento Central Groundwater Authority’s understanding of the hydrology of the Subbasin should be measurably improved, and we have written a letter suggesting some ways to achieve that. Below is an excerpt of our letter.

The Environmental Council of Sacramento (ECOS) notes with interest the Sacramento Central Groundwater Authority (SCGA) Board’s September 12, 2018 direction to Staff to evaluate the State of California’s C2VSimFG model input data for the South American Subbasin (Subbasin) and update the State’s model data as necessary. We believe that SCGA’s understanding of the hydrology of the Subbasin should be measurably improved. SCGA should look to the modeling and monitory efforts underway by the Regional Water Authority and the Sacramento Groundwater Authority (SGA), and adopt and put in place a comprehensive and compatible monitoring program for the Subbasin.

We also believe the Board acted with imprudence when it recently adopted its operating budget for the upcoming year, in that, among other issues, the Board did not provide enough funding for groundwater monitoring and modeling. SCGA’s existing set of monitoring wells is insufficient to provide a full understanding of the flows of groundwater into, through and out of the Subbasin. Semiannual data points are not sufficient to understand and effectively manage the Subbasin. While we commend SCGA’s recent effort to provide real time monitoring in a small, select group of wells, we believe you should do far more in this important area.

Click here to read the full letter (PDF).

They are building 11,000 new homes in Folsom. But will there be enough water?

By Ryan Sabalow, Dale Kasler and Tony Bizjak

Updated June 18, 2018

The Sacramento Bee

It’s like a new city springing to life: 11,000 homes and apartments, seven public schools, a pair of fire stations, a police station, a slew of office and commercial buildings and 1,000 acres of parks, trails and other open space. Expected population: 25,000.

But will it have enough water?

As construction begins this month on the first model homes at Folsom Ranch, a 3,300-acre development in the city of Folsom south of Highway 50, state regulators continue to have questions about the project’s water supply. They still aren’t convinced the city has secured enough water to keep showers and spigots flowing as California contends with increasing uncertainty about rain and snowfall.

. . .

The drought, which officially ended last year, seems to have done little to impede development. No cities or counties appear to have curbed their development plans as a direct result of water-supply limitations,

. . . 

Alan Wade, former president of the Save the American River Association, said it’s baffling state water officials would tell Folsom they had doubts about its water supply yet would let the development proceed.

“The reply from Folsom essentially told them to go pound sand: ‘We’re going to go ahead anyway,'” Wade said. “I don’t know how you can get away with that.”

Environmentalists Sue To Block Possible Elk Grove Expansion

June 18, 2018

By Ezra Romero

Capital Public Radio

“This is classic leapfrog development where you are building on green fields instead of brown fields,” said Alexandra Reagan with ECOS.

Reagan says the city should develop existing land within its boundaries. She also says there are 14 impacts that are unavoidable with the project moving forward. They include altering where migratory birds forage and depletion of groundwater resources.

“We feel like those should be addressed before any next steps for planning growth,” Reagan adds.

Read the full article here.