Environmental Community Based Representation on Groundwater Sustainability Agency Boards

On January 29, 2024, ECOS submitted a letter to the Groundwater Sustainability Agency (GSA) Boards in the Sacramento Area about Environmental Community Based Representation.

Below is an excerpt of the letter.

Groundwater management has taken a huge step forward with the Sustainable Groundwater Management Act (SGMA) and the formation of Groundwater Sustainability Agencies (GSA) throughout California. The Environmental Council of Sacramento (ECOS) is very supportive of the Sacramento Area GSA efforts to develop and begin implementation of their Groundwater Sustainability Plans (GSP) and feels the Region has done a good job of working through a multitude of technical issues. ECOS believes implementation of these GSPs requires close coordination between the GSAs, water purveyors, and the public as evidenced by our comments on the GSP annual reports to the State. One way coordination can be improved is through the inclusion of broader representation on GSA Boards of Directors.

Click here to read the letter.

Accounting System for the Regional Water Bank

On August 3, 2023, ECOS submitted a letter to the Regional Water Authority to suggest a meeting to discuss efforts to develop an Accounting System for the Regional Water Bank. Below is an excerpt.

We are interested in learning about how effective the 2012 Accounting Framework was in tracking and accounting for groundwater transactions within the bank, and which aspects of the 2012 Framework may be included in the new Regional Water Bank Accounting Framework currently in development. We are also interested in discussing how the requirements of SGMA will be incorporated in the Framework. Also, we suspect that the expanded monitoring and modeling of both the North and South American subbasins has provided additional sophistication and understanding of how groundwater moves within and between these subbasins. We would like to hear your plans for including this added technical understanding of subbasin operations into the accounting framework. We would also like to learn how you plan to account for any deposited ground water losses, and ideas you are considering regarding the use of portions of deposits to address groundwater dependent ecosystem needs, and, as a set asides to improve basin storage. Finally, the 2012 framework seemed to establish pumping levels for participants tied to water years. Is this approach one you are considering going forward, and would any resulting pumping agreements be included in Individual Purveyor Agreements established as part of the Water Forum 2 process?

Click here to read the letter (PDF).

Stop the diversion of 147,000 acre-feet of American River Water to San Joaquin County

On July 6, 2022, the Environmental Council of Sacramento submitted a letter to the State Water Resources Control Board Administrative Hearings Office (AHO) supporting the AHO’s recommendation to cancel San Joaquin County’s application #29657 from 1990.

Below is an excerpt from the letter.

While not the subject of the AHO’s recommendation, the diversion of 147,000 acre-feet of American River Water to San Joaquin County, as envisioned in application #29657, would have substantial adverse impacts to the American River and would disrupt the Water Forum’s 29 years of work to meet water needs, protect river flows, manage river temperatures for salmon and steelhead, and restore aquatic habitats in the Lower American River. The up-stream diversion would likely impact river flows and summer temperatures. With climate change and the projected demand in this region, the river cannot absorb an additional 140,000+ acre feet of diversion and still maintain the fishery and full recreational potential of the lower American river.

Click here to read the letter in full.