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).

Ground Water Recharge

Ground Water Recharge: A Pathway Toward Regional Environmental Improvement and Water Supply Security

Presentation to ECOS Board
September 25, 2018 at 6 PM

The current and future water supply security for residential, commercial, industrial, agricultural, and conservation landowner customers in the Sacramento Region (Region) appears to be satisfactory when one reviews the water supply assessments contained in each of the Region’s water purveyors’ Urban Water Management Plans. However, some of these plans do not fully address the implications of climate change on the future availability of water supplies. The recent drought has shown limitations in some of the Region’s water supply systems, and climate scientists predict the frequency and severity of droughts will increase. The State Legislature has moved to ensure the increased frequency and severity of droughts along with other weather changes due to climate change, are planned for in future Urban Water Management Planning cycles. A more comprehensive understanding of the reliability of the Region’s water supplies will be known, once the impact of the Region’s changing climate is fully understood and planned for by all Regional water purveyors.
“Ground Water Recharge: A pathway toward Regional Environmental Improvement and Water Supply Security” Briefing Paper, September 2018

Read more of the briefing paper by clicking here (PDF).

Click here for the full meeting agenda.

Hidden money, weaponized disinformation and a dark development

By Scott Thomas Anderson

July 19, 2018

Sacramento News and Review

Who’s behind the leading phone survey and sponsored Facebook campaign that are trying to assuage Folsom residents about a massive attack on open space?

…

Folsom Ranch, an embattled series of housing developments, is on track to be the largest of its kind in Sacramento County in decades—which means an enormous loss of open space, agricultural land and wildlife habitat.

…

I scanned the room for reactions and paused at former Mayor Bob Holderness. After leaving his elected post, Holderness became a consultant for prominent developers and then spearheaded the campaign for Measure W, the 2004 ballot initiative for the city to annex the land on its southern border, which would be taken over by Folsom Ranch. Today, Holderness represents Westland Capital Partners, a major developer of Folsom Ranch, as well as AKT Development, a major seller of its land.

His jump from elected leader to special-interest contractor was mirrored by former City Manager Martha Lofgren, who helped prepare the South of 50 project on the taxpayers’ dime until 2006, and is now serving as legal counsel for the New Home Company, one of the project’s main developers. But wait, there’s a three-peat! Former city planner Mike McDougall is now a top-ranking manager for Folsom Ranch.

Similar to The Folsom Way’s story-weaving in The Bee—and the meditative voice-over work on its sky-soaring Facebook video—Holderness discusses the South of 50 project as if it was approved by locals when they passed Measure W. But that vote for the city to take control of the rolling land’s future, instead of leaving that up to the county, nowhere mentioned 11,000 homes and suburban sprawl. In fact, the measure specifically forbade housing without a new, secured water supply, which remains in doubt.

Did Holderness know who was behind The Folsom Way? Before I could think more about it, he stood up and decided to jump into the kerfuffle unfolding in the chambers. Holderness strolled over to the podium. “I’m frankly disappointed to see that two of our planning commissioners don’t have a good understanding of what their role is in our city government,” he said. “Perhaps they didn’t understand their assignment, and that’s unfortunate.”

Commissioner Mallory, who’d just finished arguing that consultants have too much power in the city, glanced wearily up and replied, “You, sir, are one of the consultants.”

Photo by Devon McMindes

Click here to read the full article.

ECOS Comments on the Folsom General Plan

On June 25, 2018, ECOS submitted our comments/testimony on the latest changes to the City of Folsom’s General Plan.

Here is an excerpt:

ECOS and Habitat 2020 are greatly relieved to see that the Study Area for new City growth south of White Rock road has been removed from the General plan.

Further growth in this area would pose potentially un-mitigatable impacts to invaluable agricultural and biological resources and severely inhibit successful implementation of the South Sacramento Habitat Conservation Plan (SSHCP), currently in its final phase of adoption after decades of development.

Further growth in this area would be critically inconsistent with the Sacramento Area Council of Governments’ (SACOG) Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) for meeting State mandated greenhouse gas (GHG) reductions, Federal mandates for Air Quality Attainment under the State Improvement Plan (SIP), as well as myriad regional goals for social equity, public health and natural resource conservation.

Finally, ECOS is extremely concerned about the ability of the City to supply adequate water supplies to this potential growth area, or any new expansion area. With the decision to supply the City’s current expansion south of US 50 solely with conservation efforts of existing supplies, it is apparent that the City has fully allocated those supplies. We remain concerned that the City will not be able to supply the current expansion area without severe burdens on existing residents with the mandatory cut-backs in supply that the City is subject to in Dry and Extremely Dry years. We have not seen evidence that the City has yet acquired back up supplies to prevent these burdens, and given this, it is extremely difficult to see how the City could speculate on further expansion of their footprint.

Click here to read the full comment letter.

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.”