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


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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


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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

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