Cities Index.
Agenda packet, regular meeting

Madera City Council
April 3, 2024

Document
Agenda packet, regular meeting
Meeting
April 3, 2024
Body
Madera City Council
Pages
47
Original file
43.3 MB
Text extracted from the city's file for reading and search. Open the original on www.madera.gov. That file is the official record.

2.63%
Varies by entry age and service

2.875%

7.00% net of pension plan investment and administrative expenses.

The probabilities of retirement are based on the 2014 CalPERS Experience Study for the period from 1997 and 2011.

The probabilities of mortality are based on the 2014 CalPERS Experience Study for the period from 1997 to 2011. Preretirement and Post-retirement mortality rates include 5 years of projected mortality improvement using Scale AA published by the Society of Actuaries.

City of Madera
Required Supplementary Information (Unaudited) (Continued) Schedule of Changes in Total OPEB Liability and Related Ratios For the Year Ended June 30, 2023
141
Measurement period, year ending: 6/30/2022 6/30/2021 6/30/2020 6/30/2019 6/30/2018 6/30/2017 1 Total OPEB liability
Service cost 266,779 $ $ 188,828 $ 159,827 $ 148,304 $ 196,158 $ 165,796 Interest 84,763 95,919 104,757 110,666 97,813 92,870
Changes of benefit terms (179,263) - - (219,769) -
Differences between expected and actual experience 416,211 - 156,277 - 74,529 - Changes of assumptions (99,963) 255,972 263,250 183,321 (254,393) - Benefit payments, including refunds of member contributions (145,380) (92,662) (196,273) (132,070) (89,635) (111,633) Net change in total OPEB liability 343,147 448,057 487,838 310,221 (195,297) 147,033 Total OPEB liability - beginning 4,220,323 3,772,266 3,284,428 2,974,207 3,169,504 3,022,471 Total OPEB liability - ending (a) $ 4,563,470 $ 4,220,323 $ 3,772,266 $ 3,284,428 $ 2,974,207 $ 3,169,504 OPEB fiduciary net position
Contributions - employer $ 145,380 $ 92,662 $ 196,273 $ 132,070 $ 89,635 $ 111,633 Net investment income - - - - - -
Benefit payments, including refunds of member contributions (145,380) (92,662) (196,273) (132,070) (89,635) (111,633) Administrative expense - - - - - -
Net change in plan fiduciary net position - - - - - -
Plan fiduciary net position - beginning - - - - - -
Plan fiduciary net position - ending (b) $ - $ - $ - $ - $ - $ - Plan net OPEB liability - ending (a) - (b) $ 4,563,470 $ 4,220,323 $ 3,772,266 $ 3,284,428 $ 2,974,207 $ 3,169,504 Plan fiduciary net position as a percentage of the total OPEB liability 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% Covered-employee payroll $ 11,444,154 $ 11,110,829 $ 10,787,213 $ 13,763,983 $ 13,752,967 $ 13,352,395 Plan net OPEB liability as a percentage of covered-employee payroll 39.88% 37.98% 34.97% 23.86% 21.63% 23.74% 1 Information only presented from the implementation year 142
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SUPPLEMENTARY INFORMATION
143
Special Revenue Funds:

Special Gas Tax Fund - This fund is used to account for the receipt of gasoline tax revenue paid to the City as a subvention from the State of California. These funds support maintenance activities and finance street construction projects as provided by State law.

Business Improvement District Fund - This fund is used to account for the City's efforts of the Business Improvement District (BID) to promote commerce in downtown Madera. The funding source is assessment fees.

Park Development Fund - This fund is used for park land acquisition and development. Principal revenue sources are parks acquisition and development fees collected from developers and state revenues for park development.

Parking District Fund - This fund is used to support the activities of the City's Parking Enforcement Office. Nonsworn officers patrol a designated area in Madera's downtown and issue citations to motorists who violate the City's vehicle ordinances.

Federal Aid Urban Fund - This fund is used to report various federal grants awarded to the City by the Federal government not otherwise accounted for in the General Fund or Capital Projects funds. A separate detailed report by program is available which meets the criteria of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, for all federal grants received by the City.

Street Construction Fund - This fund is used to account for right-of-way acquisition, construction, and improvements related to the City's street system. These projects are funded by various state and federal programs and matching City funds.

Landscape Assessment Fund - This fund is used to account for funds received from the landscaping assessment districts to provide for alternative sources of funding for maintenance and service of landscaping located within the public areas of the assessment districts.

Supplemental Law Enforcement Fund - This fund is used to account for revenues and expenditures associated with front line law enforcement and municipal police services. The funding source is state grant funding.

Intermodal Building Fund - This fund is used to account for the operation and maintenance of the intermodal building facility for use by the City and its tenants. The Intermodal Facility currently houses the MAX system, the Greyhound Bus terminal, and Madera Cab Co. This facility relies solely on grants and rents collected to fund its operations, and therefore does not impact the General Fund budget.

Economic Development Fund - This fund is used to account for revenues and expenditures related to programs and projects funded with Economic Development grant proceeds.

Residential Rehab Fund - This fund is used to account for revenues and expenditures related to the City's Down Payment Assistance Program (DAP) which assists low-income residents with purchasing their first homes and the Owner Occupied Rehabilitation (OOR) program that helps existing low-income homeowners make health and safety repairs to their homes.

Non-Major Governmental Funds
144
Special Revenue Funds (Continued):

Low and Moderate Income Housing Fund - This fund is used to account for the balances of the former low and moderate income housing funds of the former Madera Redevelopment Agency and revenues and expenditures related to such housing projects and programs.

Community Facilities Districts (CFD) Fund - This fund is used to account for bond and annual tax assessment proceeds to be used for the construction and implementation of off-site infrastructure improvements. In addition, the Fund accounts for services and administration of assessments received annually.

Capital Projects Funds:

Solar Energy Lease Capital Projects Fund - This fund accounts for the construction of the Solar Energy Lease Purchase projects. These projects are funded by the Solar Energy Lease Purchase debt obligations.

Streets and Roads Fund - This fund is used to account for right-of-way acquisition, construction, and improvements related to the City's street system. These projects are funded by various state and federal programs and matching City funds.

Non-Major Governmental Funds (Continued)
145
Special Business
Gas Tax Improvement Park Parking
Fund District Development District
ASSETS
Cash and investments 4,518,212 $ 2,417 $ 98,941 $ 119,291 $ Accounts receivable, net - 15,663 - 17,974
Intergovernmental receivable 619,527 - - -
Lease receivable - - - -
Notes receivable - - - -
Prepaid items - - - -
Land held for resale - - - -
Total assets $ 18,080 5,137,739 $ 98,941 $ 137,265 $

LIABILITIES, DEFERRED INFLOWS

OF RESOURCES, AND

FUND BALANCES
Liabilities:

Accounts payable 1,120,000 $ 2,417 $ - $ 902 $
Accrued payroll - - - -
Due to other funds - - - -
Deposits payable - - - -
Unearned revenues - - - -
Total liabilities 2,417 1,120,000 - 902
Deferred inflows of resources:

Unavailable revenue - - - -
Related to leases - - - -
Total deferred inflows of resources - - - -
Fund Balances:

Nonspendable - - - -
Restricted 4,017,739 15,663 98,941 136,363
Unassigned (deficit) - - - -
Total fund balances (deficit) 4,017,739 15,663 98,941 136,363 Total liabilities, deferred inflows of
resources, and fund balances $ 5,137,739 $ 18,080 $ 98,941 $ 137,265 (Continued)
Special Revenue
Non-Major Governmental Funds
City of Madera
Combining Balance Sheet
June 30, 2023
146
Supplemental
Federal Aid Street Landscape Law
Urban Construction Assessment Enforcement
ASSETS
Cash and investments - $ - $ 509,717 $ 385,562 $
Accounts receivable, net - - 2,744 56
Intergovernmental receivable 154,125 2,453,431 4,384 111,283 Lease receivable - - - -
Notes receivable - - - -
Prepaid items - 11,330 - 1,027
Land held for resale - - - -
Total assets $ 2,464,761 154,125 $ 516,845 $ 497,928 $

LIABILITIES, DEFERRED INFLOWS

OF RESOURCES, AND

FUND BALANCES
Liabilities:

Accounts payable - $ 1,688,667 $ 1,206 $ 16,972 $
Accrued payroll - - - 6
Due to other funds 36,181 378,236 - -
Deposits payable - - - -
Unearned revenues - - - -
Total liabilities 2,066,903 36,181 1,206 16,978
Deferred inflows of resources:

Unavailable revenue - 1,640,000 - 111,283
Related to leases - - - -
Total deferred inflows of resources 1,640,000 - - 111,283 Fund Balances:

Nonspendable - 11,330 - 1,027
Restricted 117,944 - 515,639 368,640
Unassigned (deficit) (1,253,472) - - -
Total fund balances (deficit) 117,944 (1,242,142) 515,639 369,667 Total liabilities deferred inflows of
resources, and fund balances $ 154,125 $ 2,464,761 $ 516,845 $ 497,928 (Continued)
Special Revenue
City of Madera
Combining Balance Sheet (Continued)
Non-Major Governmental Funds
June 30, 2023
147
Low and
Moderate
Intermodal Economic Residential Income
Building Development Rehab Housing
ASSETS
Cash and investments $ 1,545,268 - $ $ 1,080,131 $ -
Accounts receivable, net 417 - 14,664 885
Intergovernmental receivable 67,512 - 5,000 -
Lease receivable 16,042 - - -
Notes receivable - 7,996,577 - 7,000
Prepaid items 80 - - 694
Land held for resale - - - 670,000
Total assets $ 84,051 $ 1,545,268 $ 9,096,372 $ 1,292,884

LIABILITIES, DEFERRED INFLOWS

OF RESOURCES, AND

FUND BALANCES
Liabilities:

Accounts payable $ 3,161 $ 156,500 $ 3,982 $ -
Accrued payroll 7 - - -
Due to other funds 38,560 - - 343,470
Deposits payable - - - 74
Unearned revenues - - - -
Total liabilities 41,728 156,500 3,982 343,544
Deferred inflows of resources:

Unavailable revenue - - - -
Related to leases - 15,962 - -
Total deferred inflows of resources - 15,962 - -
Fund Balances:

Nonspendable 80 - - 694
Restricted 26,281 1,388,768 9,092,390 948,646
Unassigned (deficit) - - - -
Total fund balances (deficit) 1,388,768 26,361 9,092,390 949,340 Total liabilities, deferred inflows of
resources, and fund balances $ 1,545,268 84,051 $ 9,096,372 $ 1,292,884 $ (Continued)
Special Revenue
City of Madera
Combining Balance Sheet (Continued)
Non-Major Governmental Funds
June 30, 2023
148
Special Revenue
Community Total Other
Facilities Solar Energy Streets and Governmental
Districts Lease Roads Funds
ASSETS
Cash and investments $ 1,297,333 $ - $ 4,028 $ 9,560,900 Accounts receivable, net - - - 52,403
Intergovernmental receivable 5,031 - 3,420,293 -
Lease receivable - - - 16,042
Notes receivable - - 8,003,577 -
Prepaid items - - - 13,131
Land held for resale - - - 670,000
Total assets $ 1,302,364 $ 2,517,025 $ 4,028 $ 24,867,676

LIABILITIES, DEFERRED INFLOWS

OF RESOURCES, AND

FUND BALANCES
Liabilities:

Accounts payable $ - $ - $ 2,993,807 - $
Accrued payroll - - - 13
Due to other funds 3,191,484 - 3,987,931 -
Deposits payable - - - 74
Unearned revenues 113,851 - - 113,851
Total liabilities 113,851 3,191,484 7,095,676 -
Deferred inflows of resources:

Unavailable revenue - - 1,751,283 -
Related to leases - - - 15,962
Total deferred inflows of resources - - - 1,767,245
Fund Balances:

Nonspendable - - - 13,131
Restricted 1,188,513 - 4,028 17,919,555
Unassigned (deficit) - (674,459) - (1,927,931)
Total fund balances (deficit) (674,459) 1,188,513 4,028 16,004,755 Total liabilities, deferred inflows of
resources, and fund balances $ 2,517,025 1,302,364 $ 4,028 $ 24,867,676 $ (Concluded)
Capital Projects
City of Madera
Combining Balance Sheet (Continued)
Non-Major Governmental Funds
June 30, 2023
149
Special Business
Gas Tax Improvement Park Parking
Fund District Development District
REVENUES:

Property taxes $ - $ - $ - $ -
Other taxes - - - -
Investment income (loss) - - - -
Fines and forfeitures - - - 3,845
Intergovernmental 4,194,692 - - -
Charges for services - 19,975 - 17,858
Miscellaneous - - - -
Total revenues 4,194,692 19,975 - 21,703
EXPENDITURES:

Current:

General government - 18,594 - 16,870
Public protection - - - -
Public ways and facilities 2 - - -
Community development - - - -
Capital outlay 35,395 - 6,034 -
Debt service:

Principal - - - -
Interest and fiscal charges - - - -
Total expenditures 35,397 18,594 6,034 16,870

REVENUES OVER
(UNDER) EXPENDITURES 4,159,295 1,381 (6,034) 4,833
OTHER FINANCING SOURCES (USES):

Transfers in - - - -
Transfers out (1,065,007) - - (9,030)
Total other financing sources (uses) (1,065,007) - - (9,030) NET CHANGES IN FUND BALANCES 3,094,288 1,381 (6,034) (4,197) FUND BALANCES:

Beginning of year 923,451 14,282 104,975 140,560
End of year $ 4,017,739 $ 15,663 $ 98,941 $ 136,363
(Continued)
Special Revenue
Combining Statement of Revenues, Expenditures, and Changes in Fund Balances City of Madera
For the Year Ended June 30, 2023
Non-Major Governmental Funds
150
Supplemental
Federal Aid Street Landscape Law
Urban Construction Assessment Enforcement
REVENUES:

Property taxes - $ - $ - $ - $
Other taxes - - 443,140 -
Investment income - - - 2,768
Fines and forfeitures - - - -
Intergovernmental 422,363 887,216 - 341,213
Charges for services - - - -
Miscellaneous - - - -
Total revenues 887,216 422,363 443,140 343,981
EXPENDITURES:

Current:

General government - - - -
Public protection - - - 227,051
Public ways and facilities - 110,872 389,176 -
Community development - - - -
Capital outlay 208,450 302,127 - -
Debt service:

Principal - - - -
Interest and fiscal charges - - - -
Total expenditures 412,999 208,450 389,176 227,051

REVENUES OVER
(UNDER) EXPENDITURES 474,217 213,913 53,964 116,930
OTHER FINANCING SOURCES (USES):

Transfers in - - - -
Transfers out - (512,000) (1,421) -
Total other financing sources (uses) - (512,000) (1,421) - NET CHANGES IN FUND BALANCES 213,913 (37,783) 52,543 116,930 FUND BALANCES (DEFICIT):

Beginning of year (95,969) (1,204,359) 463,096 252,737
End of year $ 117,944 $ (1,242,142) $ 515,639 $ 369,667 (Continued)
City of Madera
Combining Statement of Revenues, Expenditures, and Changes in Fund Balances (Continued) Non-Major Governmental Funds
For the Year Ended June 30, 2023
Special Revenue
151
Low and
Moderate
Intermodal Economic Residential Income
Building Development Rehab Housing
REVENUES:

Property taxes $ - $ - $ - $ -
Other taxes - - - -
Investment income 2,318 25,477 107,691 -
Fines and forfeitures - - - -
Intergovernmental 91,909 - 1,860 -
Charges for services 26,737 - - -
Miscellaneous - - 8,701 614,305
Total revenues 120,964 25,477 118,252 614,305
EXPENDITURES:

Current:

General government 67,830 - - -
Public protection - - - -
Public ways and facilities 48,895 - - -
Community development - 2,522 117,994 26,813
Capital outlay - - - 552,001
Debt service:

Principal - - - -
Interest and fiscal charges - - - -
Total expenditures 116,725 2,522 117,994 578,814

REVENUES OVER
(UNDER) EXPENDITURES 4,239 22,955 258 35,491
OTHER FINANCING SOURCES (USES):

Transfers in - - - -
Transfers out (4,326) - - -
Total other financing sources (uses) (4,326) - - -
NET CHANGES IN FUND BALANCES (87) 22,955 258 35,491
FUND BALANCES (DEFICIT):

Beginning of year 26,448 1,365,813 9,092,132 913,849
End of year $ 26,361 $ 1,388,768 $ 9,092,390 $ 949,340
(Continued)
Special Revenue
City of Madera
Combining Statement of Revenues, Expenditures, and Changes in Fund Balances (Continued) Non-Major Governmental Funds
For the Year Ended June 30, 2023
152
Special Revenue
Community Total Other
Facilities Solar Energy Streets and Governmental
Districts Lease Roads Funds
REVENUES:

Property taxes $ 894,132 $ - $ - $ 894,132
Other taxes - - - 443,140
Investment income 6,643 - - 144,897
Fines and forfeitures - - - 3,845
Intergovernmental - - - 5,939,253
Charges for services - - - 64,570
Miscellaneous - - - 623,006
Total revenues 900,775 - - 8,112,843
EXPENDITURES:

Current:

General government 5,359 - - 108,653
Public protection - - - 227,051
Public ways and facilities - - - 548,945
Community development - - - 147,329
Capital outlay - - - 1,104,007
Debt service:

Principal - 810,000 - 810,000
Interest and fiscal charges - 505,220 - 505,220
Total expenditures 5,359 1,315,220 - 3,451,205

REVENUES OVER
(UNDER) EXPENDITURES 895,416 (1,315,220) - 4,661,638
OTHER FINANCING SOURCES (USES):

Transfers in - 505,223 4,323 509,546
Transfers out (316,440) - - (1,908,224)
Total other financing sources (uses) (316,440) 505,223 4,323 (1,398,678) NET CHANGES IN FUND BALANCES 578,976 (809,997) 4,323 3,262,960 FUND BALANCES (DEFICIT):

Beginning of year 609,537 135,538 (295) 12,741,795
End of year $ 1,188,513 $ (674,459) $ 4,028 $ 16,004,755 (Concluded)
City of Madera
Combining Statement of Revenues, Expenditures, and Changes in Fund Balances (Continued) Non-Major Governmental Funds
For the Year Ended June 30, 2023
Capital Projects
153
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Intergovernmental 3,329,273 $ 3,329,273 $ 4,194,692 $ 865,419 $ Total revenues 3,329,273 3,329,273 4,194,692 865,419
EXPENDITURES:

Current:

Public ways and facilities 590,715 590,715 2 590,713
Capital outlay 2,145,612 2,180,155 35,395 2,144,760
Total expenditures 2,770,870 2,736,327 35,397 2,735,473 REVENUES OVER (UNDER) EXPENDITURES 558,403 592,946 4,159,295 3,600,892 OTHER FINANCING SOURCES (USES):

Transfers out (1,073,151) (1,073,151) (1,065,007) 8,144 Total other financing sources (uses) (1,073,151) (1,073,151) (1,065,007) 8,144 Net change in fund balance $ (514,748) (480,205) $ 3,094,288 3,609,036 $ FUND BALANCE:

Beginning of year 923,451
End of year $ 4,017,739
City of Madera
Budgetary Comparison Schedule
Special Gas Tax Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
154
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Charges for services 24,371 $ 24,371 $ 19,975 $ (4,396) $ Total revenues 24,371 24,371 19,975 (4,396)
EXPENDITURES:

Current:

General government 23,801 23,801 18,594 5,207
Total expenditures 23,801 23,801 18,594 5,207
Net change in fund balance $ 570 570 $ 1,381 811 $
FUND BALANCE:

Beginning of year 14,282
End of year $ 15,663
Budgeted Amounts
City of Madera
Budgetary Comparison Schedule
Business Improvement District Special Revenue Fund
For the Year Ended June 30, 2023
155
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
EXPENDITURES:

Capital outlay 15,059 $ 15,059 $ 6,034 $ 9,025 $
Total expenditures 15,059 15,059 6,034 9,025
Net change in fund balance $ (15,059) (15,059) $ (6,034) 9,025 $ FUND BALANCE:

Beginning of year 104,975
End of year $ 98,941
City of Madera
Budgetary Comparison Schedule
Parking Development Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
156
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Fines and forfeitures 19,797 $ 19,797 $ 3,845 $ (15,952) $ Charges for services 21,334 21,334 17,858 (3,476)
Total revenues 41,131 41,131 21,703 (19,428)
EXPENDITURES:

Current:

General government 34,403 34,403 16,870 17,533
Total expenditures 34,403 34,403 16,870 17,533
REVENUES OVER (UNDER) EXPENDITURES 6,728 6,728 4,833 (1,895) OTHER FINANCING SOURCES (USES):

Transfers out (9,030) (9,030) (9,030) -
Total other financing sources (uses) (9,030) (9,030) (9,030) - Net change in fund balance $ (2,302) (2,302) $ (4,197) (1,895) $ FUND BALANCE:

Beginning of year 140,560
End of year $ 136,363
City of Madera
Budgetary Comparison Schedule
Parking District Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
157
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Intergovernmental 3,293,021 $ 3,293,021 $ 422,363 $ (2,870,658) $ Total revenues 3,293,021 3,293,021 422,363 (2,870,658)
EXPENDITURES:

Current:

Capital outlay 2,257,782 2,309,971 208,450 2,101,521
Total expenditures 2,309,971 2,257,782 208,450 2,101,521 Net change in fund balance $ 983,050 1,035,239 $ 213,913 (769,137) $ FUND BALANCE (DEFICIT):

Beginning of year (95,969)
End of year $ 117,944
City of Madera
Budgetary Comparison Schedule
Federal Aid Urban Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
158
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Intergovernmental 3,086,290 $ 3,086,290 $ 887,216 $ (2,199,074) $ Total revenues 3,086,290 3,086,290 887,216 (2,199,074)
EXPENDITURES:

Current:

Public ways and facilities - 129,250 110,872 18,378
Capital outlay 1,952,040 2,112,945 302,127 1,810,818
Total expenditures 2,242,195 1,952,040 412,999 1,829,196 REVENUES OVER (UNDER) EXPENDITURES 844,095 1,134,250 474,217 (369,878) OTHER FINANCING SOURCES (USES):

Transfers out (512,000) (512,000) (512,000) -
Total other financing sources (uses) (512,000) (512,000) (512,000) - Net change in fund balance $ 332,095 622,250 $ (37,783) (369,878) $ FUND BALANCE (DEFICIT):

Beginning of year (1,204,359)
End of year $ (1,242,142)
City of Madera
Budgetary Comparison Schedule
Street Construction Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
159
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Other taxes 417,383 $ 417,383 $ 443,140 $ 25,757 $
Total revenues 417,383 417,383 443,140 25,757
EXPENDITURES:

Current:

Public ways and facilities 405,269 405,269 389,176 16,093 Total expenditures 405,269 405,269 389,176 16,093
REVENUES OVER (UNDER) EXPENDITURES 12,114 12,114 53,964 41,850 OTHER FINANCING SOURCES (USES):

Transfers out (1,421) (1,421) (1,421) -
Total other financing sources (uses) (1,421) (1,421) (1,421) - Net change in fund balance $ 10,693 10,693 $ 52,543 41,850 $ FUND BALANCE:

Beginning of year 463,096
End of year $ 515,639
City of Madera
Budgetary Comparison Schedule
Landscape Assessment Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
160
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Investment income (loss) 1,235 $ 1,235 $ 2,768 $ 1,533 $ Intergovernmental 162,899 267,899 341,213 73,314
Total revenues 269,134 164,134 343,981 74,847
EXPENDITURES:

Current:

Public protection 204,719 309,719 227,051 82,668
Total expenditures 309,719 204,719 227,051 82,668
Net change in fund balance $ (40,585) (40,585) $ 116,930 157,515 $ FUND BALANCE:

Beginning of year 252,737
End of year $ 369,667
City of Madera
Budgetary Comparison Schedule
Supplemental Law Enforcement Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
161
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Investment income (loss) - $ - $ 2,318 $ 2,318 $
Intergovernmental 50,000 50,000 91,909 41,909
Charges for services 38,180 38,180 26,737 (11,443)
Total revenues 88,180 88,180 120,964 32,784
EXPENDITURES:

Current:

General government 66,896 66,896 67,830 (934)
Public ways and facilities 40,009 40,009 48,895 (8,886) Total expenditures 106,905 106,905 116,725 (9,820)
REVENUES OVER (UNDER) EXPENDITURES (18,725) (18,725) 4,239 22,964 OTHER FINANCING SOURCES (USES):

Transfers out (4,326) (4,326) (4,326) -
Total other financing sources (uses) (4,326) (4,326) (4,326) - Net change in fund balance $ (23,051) (23,051) $ (87) 22,964 $ FUND BALANCE:

Beginning of year 26,448
End of year $ 26,361
City of Madera
Budgetary Comparison Schedule
Intermodal Building Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
162
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Investment income (loss) 11,377 $ 11,377 $ 25,477 $ 14,100 $ Total revenues 11,377 11,377 25,477 14,100
EXPENDITURES:

Current:

Community development 2,324 2,324 2,522 (198)
Total expenditures 2,324 2,324 2,522 (198)
REVENUES OVER (UNDER) EXPENDITURES 9,053 9,053 22,955 13,902 Net change in fund balance $ 9,053 9,053 $ 22,955 13,902 $ FUND BALANCE:

Beginning of year 1,365,813
End of year $ 1,388,768
City of Madera
Budgetary Comparison Schedule
Economic Development Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
163
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Investment income (loss) 414,944 $ 414,944 $ 107,691 $ (307,253) $ Intergovernmental - - 1,860 1,860
Miscellaneous 24,431 24,431 8,701 (15,730)
Total revenues 439,375 439,375 118,252 (321,123)
EXPENDITURES:

Current:

Community development 117,711 126,820 117,994 8,826
Total expenditures 126,820 117,711 117,994 8,826
Net change in fund balance $ 312,555 321,664 $ 258 (312,297) $ FUND BALANCE:

Beginning of year 9,092,132
End of year $ 9,092,390
City of Madera
Budgetary Comparison Schedule
Residential Rehab Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
164
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Intergovernmental 194,750 $ 194,750 $ - $ (194,750) $
Miscellaneous 7,000 7,000 614,305 607,305
Total revenues 201,750 201,750 614,305 412,555
EXPENDITURES:

Current:

Community development 650 36,650 26,813 9,837
Capital outlay 1,686,384 2,136,384 552,001 1,584,383
Total expenditures 2,173,034 1,687,034 578,814 1,594,220 Net change in fund balance $ (1,971,284) (1,485,284) $ 35,491 2,006,775 $ FUND BALANCE:

Beginning of year 913,849
End of year $ 949,340
City of Madera
Budgetary Comparison Schedule
Low and Moderate Income Housing Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
165
Variance with
Final Budget
Actual Favorable/
Original Final Amounts (Unfavorable)
REVENUES:

Property taxes 493,035 $ 493,035 $ 894,132 $ 401,097 $
Investment income (loss) 3,739 3,739 6,643 2,904
Total revenues 496,774 496,774 900,775 404,001
EXPENDITURES:

Current:

General government 6,303 6,303 5,359 944
Total expenditures 6,303 6,303 5,359 944
REVENUES OVER (UNDER) EXPENDITURES 490,471 490,471 895,416 404,945 OTHER FINANCING SOURCES (USES):

Transfers out (316,440) (316,440) (316,440) -
Total other financing sources (uses) (316,440) (316,440) (316,440) - Net change in fund balance $ 174,031 174,031 $ 578,976 404,945 $ FUND BALANCE:

Beginning of year 609,537
End of year $ 1,188,513
City of Madera
Budgetary Comparison Schedule
Community Facilities District Special Revenue Fund
For the Year Ended June 30, 2023
Budgeted Amounts
166
Non-Major Enterprise Funds
Local Transit Fund - This fund is used to account for the activities of the City's public transit operations.

Golf Course Fund - This fund is used to account for the activities of the City's golf course operations.

Airport Fund - This fund is used to account for the activities of the City's airport operations. 167
Local Golf
Transit Course Airport
Fund Fund Fund Total
ASSETS
Current assets:

Cash and investments $ - $ 1,092,013 - $ $ 1,092,013
Accounts receivable, net 16,670 - 35,443 52,113
Intergovernmental receivable 1,409,265 - 31,775 1,441,040 Lease receivable - due within one year - - 36,784 36,784 Prepaid items 358 - 9,721 10,079
Total current assets 1,409,623 16,670 1,205,736 2,632,029 Noncurrent assets:

Lease receivable - due in more than one year - - 822,162 822,162 Capital assets:

Non-depreciable 323,583 146,933 4,087,640 4,558,156
Depreciable, net 7,810,439 1,881,928 7,268,219 16,960,586 Total capital assets 8,134,022 2,028,861 11,355,859 21,518,742 Total noncurrent assets 8,134,022 2,028,861 12,178,021 22,340,904 Total assets 9,543,645 2,045,531 13,383,757 24,972,933

DEFERRED OUTFLOW OF RESOURCES
Related to OPEB - - 4,540 4,540
Related to pensions 298,622 - 81,892 380,514
Total deferred outflow of resources - 298,622 86,432 385,054

LIABILITIES
Current liabilities:

Accounts payable 27,287 417,314 - 444,601
Accrued payroll 2,313 - 6 2,319
Due to other funds 1,255,040 563,534 1,818,574 -
Interest payable - 1,707 - 1,707
Deposits payable - - 14,065 14,065
Compensated absences - due within one year - 21,996 7,289 29,285 Long-term debt - due within one year 161,800 - - 161,800 Total current liabilities 1,306,636 727,041 438,674 2,472,351 Noncurrent liabilities:

Advances from other funds - 12,240 - 12,240
Total OPEB liability - - 19,094 19,094
Aggregate net pension liability - 1,016,682 278,808 1,295,490 Compensated absences - due in more than one year 4,948 - 3,584 8,532 Total noncurrent liabilities 1,021,630 12,240 301,486 1,335,356 Total liabilities 2,328,266 739,281 740,160 3,807,707

DEFERRED INFLOWS OF RESOURCES
Related to service concession arrangement 16,670 - - 16,670 Related to leases - 845,189 - 845,189
Related to OPEB - - 787 787
Related to pensions 15,457 - 4,239 19,696
Total deferred inflows of resources 16,670 15,457 850,215 882,342

NET POSITION
Net investment in capital assets 8,134,022 1,867,061 11,355,859 21,356,942 Unrestricted (deficit) (635,478) (577,481) 523,955 (689,004) Total net position $ 1,289,580 7,498,544 $ 11,879,814 $ 20,667,938 $ City of Madera
Combining Statement of Net Position
Non-Major Enterprise Funds
June 30, 2023
168
Local Golf
Transit Course Airport
Fund Fund Fund Total
OPERATING REVENUES:

Charges for services $ 2,994,770 $ 84,107 $ 348,230 $ 3,427,107 Miscellaneous revenue 1,856 136,078 - 137,934
Total operating revenues 2,996,626 84,107 484,308 3,565,041 OPERATING EXPENSES:

Salaries and benefits 1,119,584 247,560 - 1,367,144
General and administrative 1,900,123 64,083 311,788 2,275,994 Supplies and miscellaneous 456,412 - 28,680 485,092
Parts and supplies - 322,965 - 322,965
Utilities - - 18,331 18,331
Depreciation 428,319 297,676 - 725,995
Total operating expenses 3,904,438 64,083 1,227,000 5,195,521 OPERATING INCOME (LOSS) (907,812) 20,024 (742,692) (1,630,480) NONOPERATING REVENUES (EXPENSES):

Investment income (loss) 2,691 20 45,112 47,823
Property taxes - - 96,082 96,082
Interest expense - (11,910) (634) (12,544)
Total nonoperating revenues (expenses) 2,691 (11,890) 140,560 131,361 (LOSS) BEFORE TRANSFERS (905,121) 8,134 (602,132) (1,499,119)

TRANSFERS
Capital contributions 13,819 - - 13,819
Capital grants 572,961 - 572,961 -
Transfers in 298,804 - 298,804 -
Transfers out (61,704) - (17,672) (79,376)
Total transfers 525,076 298,804 (17,672) 806,208
Changes in net position (380,045) 306,938 (619,804) (692,911) NET POSITION:

Beginning of year 7,878,589 982,642 12,499,618 21,360,849 End of year $ 7,498,544 $ 1,289,580 $ 11,879,814 $ 20,667,938 City of Madera
Combining Statement of Revenues, Expenses, and Changes in Net Position Non-Major Enterprise Funds
For the Year Ended June 30, 2023
169
Local Golf
Transit Course Airport
Fund Fund Fund Total
CASH FLOWS FROM OPERATING ACTIVITIES:

Cash received from customers $ 2,115,312 $ 84,125 $ 350,951 $ 2,550,388 Cash payments to suppliers for goods and services (2,492,105) (64,083) (276,347) (2,832,535) Cash payments to employees for services (618,118) (173,562) - (791,680) Receipts from other operating revenues 1,856 136,078 - 137,934 Net cash provided by (used in) operating activities (993,055) 20,042 37,120 (935,893)

CASH FLOWS FROM NONCAPITAL
FINANCING ACTIVITIES:

Property taxes - - 96,082 96,082
Advances from other funds (24,480) - (24,480) -
Due to other funds 977,355 34,458 1,011,813 -
Transfers from other funds 298,804 - 298,804 -
Transfers to other funds (61,704) (17,672) - (79,376)
Net cash provided by (used in)
noncapital financing activities 915,651 308,782 78,410 1,302,843

CASH FLOWS FROM CAPITAL AND
RELATED FINANCING ACTIVITIES:

Capital grants 572,961 - 572,961 -
Acquisition of capital assets (498,248) (511,320) - (1,009,568) Principal payment of long-term debt (316,100) - (315,876) (631,976) Interest paid on debt (12,744) - (1,717) (14,461)
Net cash provided by (used in) capital and
related financing activities 74,713 (328,844) (828,913) (1,083,044) CASH FLOWS FROM INVESTING ACTIVITIES:

Interest from investments 2,691 20 45,112 47,823
Net cash provided by investing activities 2,691 20 45,112 47,823 Net change in cash and cash equivalents - (668,271) - (668,271) CASH AND CASH EQUIVALENTS:

Beginning of year - 1,760,284 - 1,760,284
End of year $ - $ 1,092,013 - $ $ 1,092,013
(Continued)
City of Madera
Combining Statement of Cash Flows
Non-Major Enterprise Funds
For the Year Ended June 30, 2023
170
Local Golf
Transit Course Airport
Fund Fund Fund Total

RECONCILIATION OF OPERATING INCOME (LOSS) TO
NET CASH PROVIDED BY (USED IN) OPERATING ACTIVITIES:

Operating income (loss) $ (907,812) $ 20,024 $ (742,692) $ (1,630,480) Adjustments to reconcile operating income (loss) to net cash provided by (used in) operating activities:

Depreciation 428,319 297,676 - 725,995
Changes in operating assets and liabilities, and
deferred outflows and inflows of resources:

Accounts receivable, net - (12,251) - (12,251)
Intergovernmental receivable (879,458) - 22,369 (857,089) Lease receivable - 16,646 36,122 52,768
Prepaid items 343 - (705) (362)
Deferred outflows - OPEB related - - (1,205) (1,205)
Deferred outflows - pension related (250,335) (51,424) - (301,759) Accounts payable (135,913) 406,122 - 270,209
Accrued payroll (12,375) - (4,022) (16,397)
Deposits payable - - (100) (100)
Compensated absences (7,418) - (98) (7,516)
Aggregate net pension liability 852,775 162,672 - 1,015,447 Total OPEB liability - - 1,436 1,436
Deferred inflows - lease related (16,628) - (43,419) (60,047) Deferred inflows - OPEB related - - 248 248
Deferred inflows - pension related (81,181) (33,609) - (114,790) Total adjustments (85,243) 18 779,812 694,587
Net cash provided by (used in) operating activities $ (993,055) $ 20,042 $ 37,120 $ (935,893) (Concluded)
For the Year Ended June 30, 2023
City of Madera
Combining Statement of Cash Flows (Continued)
Non-Major Enterprise Funds
171
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172
Internal Service Funds
Fleet Maintenance Fund - This fund is used to account for the accumulation and allocation of costs associated with the maintenance of the City's fleet of vehicles.

Facilities Maintenance Fund - This fund is used to account for the accumulation and allocation of costs associated with the maintenance of the City Hall building and other City buildings.

Technology Fund - This fund is used to account for the costs associated with automation maintenance of the City's various computers, servers and interdepartmental electronic communications. 173
Fleet Facilities
Maintenance Maintenance Technology Total
ASSETS
Current assets:

Cash and investments $ 3,358,487 $ 1,532,333 $ 840,577 $ 5,731,397 Accounts receivable, net 7,481 6,230 666 14,377
Prepaid items - - 57,675 57,675
Total current assets 3,365,968 1,538,563 898,918 5,803,449 Noncurrent assets:

Capital assets:

Non-depreciable 3,026 - - 3,026
Depreciable, net 3,575,159 3,684 395,365 3,974,208
Total capital assets 3,578,185 3,684 395,365 3,977,234
Total noncurrent assets 3,578,185 3,684 395,365 3,977,234 Total assets 6,944,153 1,542,247 1,294,283 9,780,683

DEFERRED OUTFLOW OF RESOURCES
Related to OPEB 27,242 36,323 18,162 81,727
Related to pensions 281,693 563,181 333,088 1,177,962
Total deferred outflow of resources 308,935 599,504 351,250 1,259,689

LIABILITIES
Current liabilities:

Accounts payable 148,991 82,331 - 231,322
Accrued payroll 18 49 24 91
Compensated absences - due within one year 28,793 85,173 28,026 141,992 Long-term debt, due within one year - - 94,498 94,498
Total current liabilities 177,802 167,553 122,548 467,903 Noncurrent liabilities:

Total OPEB liability 114,564 152,752 76,376 343,692
Aggregate net pension liability 959,047 1,917,401 1,134,027 4,010,475 Compensated absences - due in more than one year 15,216 34,184 10,499 59,899 Long term debt - due in more than one year - - 96,792 96,792 Total noncurrent liabilities 1,088,827 2,104,337 1,317,694 4,510,858 Total liabilities 1,266,629 2,271,890 1,440,242 4,978,761

DEFERRED INFLOWS OF RESOURCES
Related to OPEB 4,721 6,295 3,148 14,164
Related to pensions 14,581 29,151 17,241 60,973
Total deferred inflows of resources 19,302 35,446 20,389 75,137

NET POSITION
Investment in capital assets 3,578,185 3,684 395,365 3,977,234 Unrestricted (deficit) 2,388,972 (169,269) (210,463) 2,009,240 Total net position (deficit) $ (165,585) 5,967,157 $ 184,902 $ 5,986,474 $ City of Madera
Combining Statement of Net Position
All Internal Service Funds
June 30, 2023
174
Fleet Facilities
Maintenance Maintenance Technology Total
OPERATING REVENUES:

Charges for services $ 1,980,070 $ 2,126,458 $ 1,372,691 $ 5,479,219 Miscellaneous revenue 28,309 316 218 28,843
Total operating revenues 2,008,379 2,126,774 1,372,909 5,508,062 OPERATING EXPENSES:

Salaries and benefits 618,454 1,750,688 965,077 3,334,219 General and administrative 232,659 255,499 415,817 903,975 Supplies and miscellaneous 240,275 85,403 3,823 329,501 Parts and supplies - - 157,958 157,958
Utilities 1,053 463,337 11,795 476,185
Amortization - - - -
Depreciation and amortization 566,191 1,263 111,483 678,937 Total operating expenses 1,658,632 2,556,190 1,665,953 5,880,775 OPERATING INCOME 349,747 (429,416) (293,044) (372,713)
NONOPERATING REVENUES (EXPENSES):

Interest expense - - (1,143) (1,143)
Total nonoperating revenues (expenses) - - (1,143) (1,143) INCOME (LOSS) BEFORE TRANSFERS 349,747 (429,416) (294,187) (373,856) TRANSFERS:

Transfers in 57,000 - - 57,000
Transfers out (58,036) (103,742) (10,299) (172,077)
Total transfers (1,036) (103,742) (10,299) (115,077)
Changes in net position 348,711 (533,158) (304,486) (488,933) NET POSITION (DEFICIT):

Beginning of year 5,618,446 367,573 489,388 6,475,407
End of year $ 5,967,157 $ (165,585) $ 184,902 $ 5,986,474 City of Madera
Combining Statement of Revenues, Expenses, and Changes in Net Position All Internal Service Funds
For the Year Ended June 30, 2023
175
Fleet Facilities
Maintenance Maintenance Technology Total
CASH FLOWS FROM OPERATING ACTIVITIES:

Cash received from customers $ 1,978,297 $ 2,120,497 $ 1,372,025 $ 5,470,819 Cash payments to suppliers for goods and services (381,505) (825,439) (628,503) (1,835,447) Cash payments to employees for services (448,861) (1,163,997) (637,825) (2,250,683) Receipts from other operating activities 28,309 316 218 28,843 Net cash provided by operating activities 1,176,240 131,377 105,915 1,413,532

CASH FLOWS FROM NONCAPITAL
FINANCING ACTIVITIES:

Transfers from other funds 57,000 - - 57,000
Transfers to other funds (58,036) (103,742) (10,299) (172,077) Net cash (used in)
noncapital financing activities (1,036) (103,742) (10,299) (115,077)

CASH FLOWS FROM CAPITAL AND
RELATED FINANCING ACTIVITIES:

Acquisition of capital assets (310,975) - (13,184) (324,159) Principal payment of long-term debt - - (97,405) (97,405) Interest paid on debt - - (1,143) (1,143)
Net cash (used in) capital and
related financing activities (310,975) (111,732) - (422,707) Net change in cash and cash equivalents 864,229 27,635 (16,116) 875,748 CASH AND CASH EQUIVALENTS:

Beginning of year 2,494,258 1,504,698 856,693 4,855,649 End of year $ 3,358,487 $ 1,532,333 $ 840,577 $ 5,731,397 (Continued)
City of Madera
Combining Statement of Cash Flows
All Internal Service Funds
For the Year Ended June 30, 2023
176
Fleet Facilities
Maintenance Maintenance Technology Total

RECONCILIATION OF OPERATING INCOME
TO NET CASH PROVIDED BY OPERATING ACTIVITIES:

Operating income $ 349,747 $ (429,416) $ (293,044) $ (372,713) Adjustments to reconcile operating income to net
cash provided by operating activities:

Depreciation and amortization 566,191 1,263 111,483 678,937 Changes in operating assets and liabilities, and
deferred outflows and inflows of resources:

Accounts receivable, net (1,773) (5,961) (666) (8,400)
Prepaid items 27,329 32 44,291 71,652
Deferred outflows - OPEB related (7,230) (9,641) (4,821) (21,692) Deferred outflows -pension related (151,349) (377,097) (235,224) (763,670) Accounts payable 65,153 (21,232) (83,401) (39,480)
Accrued payroll (9,344) (24,728) (11,499) (45,571)
Compensated absences (5,530) 17,001 (17,303) (5,832)
Aggregate net pension liability 430,993 1,149,131 712,895 2,293,019 Total OPEB liability 8,614 11,486 5,743 25,843
Deferred inflows - OPEB related 1,488 1,985 993 4,466
Deferred inflows - pension related (98,049) (181,446) (123,532) (403,027) Total adjustments 826,493 560,793 398,959 1,786,245
Net cash provided by operating activities $ 1,176,240 $ 131,377 $ 105,915 $ 1,413,532 (Concluded)
All Internal Service Funds
For the Year Ended June 30, 2023
City of Madera
Combining Statement of Cash Flows (Continued)
177
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178
Custodial Funds
The Custodial Funds are used to account for assets held by the City in a custodial capacity for individuals, private organizations, other governments, and/or other funds. The City maintains the following custodial funds for the purposes indicated:

General Deposit Fund - This fund is used to account for all money held as deposits on behalf of others.

Community Facilities Districts - This fund is used to account for the collection of assessments from property owners and for the remittance of such assessments to bondholders as required by the Improvement Bond Act of 1915 and related California State statutes for the Community Facilities District No. 2006-1. 179
General Community
Deposit Facilities
Fund Districts Total
ASSETS
Cash and investments $ 2,499,300 $ 343,174 $ 2,842,474
Accounts receivable, net 1,658 - 1,658
Prepaid items 925 - 925
Restricted cash and investments with fiscal agents - 48,600 48,600 Total assets 394,357 2,499,300 2,893,657

LIABILITIES
Accounts payable 16,259 $ - $ 16,259 $
Due to City - 614,305 614,305
Total liabilities - 630,564 630,564

NET POSITION
Restricted for:

Individuals, organizations, and other governments 1,868,736 394,357 2,263,093 Total net position $ 1,868,736 $ 394,357 $ 2,263,093
City of Madera
Combining Statement of Fiduciary Net Position
Custodial Funds
June 30, 2023
180
General Community
Deposit Facilities
Fund Districts Total
ADDITIONS:

Special assessments for other governments - $ 184,968 $ 184,968 $ Investment income (loss) 128,204 3,765 131,969
Total additions 188,733 128,204 316,937
DEDUCTIONS:

Administration 9,780 - 9,780
Payments on conduit bonds - principal - 88,740 88,740
Payments on conduit bonds - interest - 80,916 80,916
Total deductions 179,436 - 179,436
Changes in net position 9,297 128,204 137,501
NET POSITION:

Beginning of year 1,740,532 385,060 2,125,592
End of year $ 1,868,736 $ 394,357 $ 2,263,093
City of Madera
Combining Statement of Changes in Fiduciary Net Position Custodial Funds
For the Year Ended June 30, 2023
181
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182

STATISTICAL SECTION
183
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184

CONTENTS PAGE
1 Net Position by Component 186
2 Changes in Net Position 188
3 Fund Balances of Governmental Funds 192
4 Changes in Fund Balances of Governmental Funds 194
5 Governmental Activities Tax Revenues by Source 197
6 Assessed Value of Taxable Property 196
7 Property Tax Levies and Collections 200
8 Direct and Overlapping Property Tax Rates 201
9 Top Ten Principal Property Taxpayers 202
10 Ratios of Outstanding Debt by Type 203
11 Ratios of General Bonded Debt Outstanding 204
12 Direct and Overlapping Governmental Activities Debt 205 13 Legal Debt Margin Information 206
14 Pledged Revenue Coverage 208
15 Demographic and Economic Statistics 210
16 Principal Employers 211
17 Full-Time Equivalent City Government Employees by Function/Program 213 18 Operating Indicators by Function/Program 214
19 Capital Asset Statistics by Function/Program 216
Sources: Unless otherwise noted, the information in these schedules is derived from the City's annual comprehensive financial reports for the relevant year

CITY OF MADERA - STATISTICAL SECTION
Operating Information - These schedules contain service and infrastructure data to help the reader understand how the information in the City's financial report relates to the services the City provides and the activities it performs.

Revenue Capacity - These schedules contain information to help the reader assess the City of Madera's most significant local revenue source, the property tax.

Debt Capacity - These schedules present information to help the reader assess the affordability of the City's current level of outstanding debt and the City's ability to issue additional debt in the future.

Demographic and Economic Information - These schedules offer demographic and economic indicators to help the reader understand the environment within which the City's financial activities take place.

Financial Trends - These schedules contain trend information to help the reader understand how the City of Madera's financial performance and well-being have changed over time.

This part of the City of Madera's annual comprehensive financial report presents detailed information as a context for understanding what the information in the financial statements, note disclosures, and required supplementary information says about the City's overall financial health.
185
2023 2022 2021 2020 2019
Governmental activities
Net investment in capital assets, $ 173,636,768 $ 177,369,996 $ 178,947,614 $ 160,970,918 $ 172,189,172 Restricted 50,277,926 44,524,605 46,349,016 55,679,367 44,311,906 Unrestricted 16,130,158 1,380,440 (9,774,183) (10,495,207) (12,968,431) Total governmental activities net position $ 240,044,852 $ 223,275,041 $ 215,522,447 $ 206,155,078 $ 203,532,647 Business type activities
Net investment in capital assets $ 65,561,102 $ 65,475,770 $ 65,967,085 $ 64,433,636 $ 61,048,060 Restricted 2,579,539 1,794,447 963,474 1,166,101 4,940,553 Unrestricted 43,636,832 41,013,126 33,447,161 26,306,961 17,336,248 Total business type activities net position $ 111,777,473 $ 108,283,343 $ 100,377,720 $ 91,906,698 $ 83,324,861 Primary government
Net investment in capital assets $ 239,197,870 $ 242,845,766 $ 244,914,699 $ 225,404,554 $ 233,237,232 Restricted 52,857,465 46,319,052 47,312,490 56,845,468 49,252,459 Unrestricted 59,766,990 42,393,566 23,672,978 15,811,754 4,367,817 Total primary government net position $ 351,822,325 $ 331,558,384 $ 315,900,167 $ 298,061,776 $ 286,857,508 City of Madera
Schedule 1
Net Position by Component
Last Ten Fiscal Years (accrual basis of accounting)
Fiscal Years
186
2018 2017 2016 2015 2014
Governmental activities
Net investment in capital assets $ 176,114,816 $ 178,119,000 $ 178,483,617 $ 182,403,676 $ 185,644,703 Restricted 37,033,179 34,863,951 32,193,071 32,671,232 32,451,846 Unrestricted (10,128,387) (9,560,807) (11,207,039) (14,435,936) 12,294,870 Total governmental activities net position $ 203,019,608 $ 203,422,144 $ 199,469,649 $ 200,638,972 $ 230,391,419 Business type activities
Net investment in capital assets $ 58,537,120 $ 58,792,617 $ 57,639,498 $ 58,455,927 $ 60,056,090 Restricted 1,125,151 1,076,451 - - -
Unrestricted 15,846,498 13,966,875 17,152,594 15,542,964 19,739,870 Total business type activities net position $ 75,508,769 $ 73,835,943 $ 74,792,092 $ 73,998,891 $ 79,795,960 Primary government
Net investment in capital assets $ 234,651,936 $ 236,911,617 $ 236,123,115 $ 240,859,603 $ 245,700,793 Restricted 38,158,330 35,940,402 32,193,071 32,671,232 32,451,846 Unrestricted 5,718,111 4,406,068 5,945,555 1,107,028 32,034,740 Total primary government net position $ 278,528,377 $ 277,258,087 $ 274,261,741 $ 274,637,863 $ 310,187,379 City of Madera
Schedule 1
Net Position by Component (Continued)
Last Ten Fiscal Years (accrual basis of accounting)
Fiscal Years
187
2023 2022 2021 2020 2019
Expenses
Governmental activities:

General government $ 8,709,507 $ 9,503,665 $ 9,700,357 $ 9,574,371 $ 9,703,723 Public protection 19,843,489 21,670,917 18,826,073 20,182,145 18,983,486 Social services (12,583) 1,061,114 133,639 422,270 330,498 Public ways and facilities 3,690,713 5,320,754 3,741,698 7,369,948 5,478,070 Culture and recreation 4,195,329 5,136,917 5,993,699 4,056,088 4,525,133 Community development 4,670,551 3,158,176 3,509,000 4,654,520 4,492,799 Interest on long-term debt 643,406 671,356 692,894 509,977 210,504 Total governmental activities expenses 41,740,412 46,522,899 42,597,360 46,769,319 43,724,213 Business type activities:

Water 9,595,209 7,317,498 7,427,430 8,295,137 7,654,315 Sewer 12,320,078 8,737,728 9,216,976 10,038,430 9,924,665 Solid waste 9,379,389 6,146,265 5,758,119 5,875,225 6,056,309 Drainage operations 1,241,082 929,265 943,353 1,110,864 1,149,676 Local transit 3,904,438 3,104,405 2,499,127 2,403,789 2,321,063 Golf course 75,993 85,044 94,635 103,861 120,763
Airport 1,227,634 883,402 787,373 801,043 842,652
Total business type activities expenses 37,743,823 27,203,607 26,727,013 28,628,349 28,069,443 Total primary government expenses $ 79,484,235 $ 73,726,506 $ 69,324,373 $ 75,397,668 $ 71,793,656 Program Revenues
Governmental activities:

Program revenues:

General government $ 806,808 $ 951,582 $ 1,174,107 $ 242,424 $ 6,223,401 Public protection 1,654,817 1,583,277 1,906,334 2,492,680 1,498,740 Social services - - - 42,549 45,159
Public ways and facilities 15,013,053 11,479,145 10,910,045 9,246,144 10,385,688 Community development 3,868,158 4,842,711 5,645,305 2,866,097 3,434,002 Culture and recreation 1,225,283 638,302 1,048,539 696,197 941,359 Total governmental activities program revenues 22,568,119 19,495,017 20,684,330 15,586,091 22,528,349 Business type activities:

Program revenues:

Water 12,178,109 13,727,980 13,538,219 12,414,215 12,323,836 Sewer 11,734,950 10,921,383 11,352,608 10,797,565 10,352,115 Solid waste 8,288,152 6,096,051 5,890,825 5,982,010 5,890,085 Drainage operations 1,078,836 1,510,375 1,070,277 869,502 938,423 Local transit 3,581,550 2,842,877 2,398,029 5,873,660 4,316,816 Golf course 84,107 74,712 78,053 101,734 95,889
Airport 348,230 442,548 617,608 581,739 579,745
Total business type activities program revenues 37,293,934 35,615,926 34,945,619 36,620,425 34,496,909 Total primary government program revenues $ 59,862,053 $ 55,110,943 $ 55,629,949 $ 52,206,516 $ 57,025,258 Net (Expense)/Revenue
Governmental activities $ (19,172,293) $ (27,027,882) $ (21,913,030) $ (31,183,228) $ (21,195,864) Business type activities (449,889) 8,412,319 8,218,606 7,992,076 6,427,466 Total primary government net expense $ (19,622,182) $ (18,615,563) $ (13,694,424) $ (23,191,152) $ (14,768,398) City of Madera
Schedule 2
Changes in Net Position
Last Ten Fiscal Years (accrual basis of accounting)
Fiscal Years
188
2018 2017 2016 2015 2014
Expenses
Governmental activities:

General government $ 8,697,525 $ 7,692,256 $ 8,890,092 $ 11,483,880 $ 11,482,393 Public protection 18,425,675 12,903,321 14,722,091 13,759,629 13,358,929 Social services 346,863 303,015 182,286 331,774 517,537 Public ways and facilities 5,081,612 4,607,237 6,852,731 3,695,605 3,766,236 Culture and recreation 4,744,555 4,421,827 4,451,155 4,335,983 3,814,936 Community development 4,022,163 3,029,515 5,249,438 5,812,948 5,478,644 Interest on long-term debt 74,490 110,856 280,037 258,764 269,845 Total governmental activities expenses 41,392,883 33,068,027 40,627,830 39,678,583 38,688,520 Business type activities:

Water 9,262,549 10,066,546 5,590,810 5,668,873 4,788,350 Sewer 9,854,304 8,758,885 8,476,744 7,573,475 7,318,263 Solid waste 5,811,095 6,305,944 4,936,291 4,675,782 4,326,840 Drainage operations 887,698 956,287 1,024,498 900,903 933,506 Local transit 2,166,293 2,184,533 2,051,814 1,996,563 1,827,194 Golf course 199,012 115,882 74,596 122,102 66,651
Airport 1,163,134 893,106 852,560 871,796 687,228
Total business type activities expenses 29,344,085 29,281,183 23,007,313 21,809,494 19,948,032 Total primary government expenses $ 62,349,210 70,736,968 $ 63,635,143 $ 61,488,077 $ 58,636,552 $ Program Revenues
Governmental activities:

Program revenues:

General government 5,727,717 $ 5,526,628 $ 6,996,758 $ 8,763,455 $ 7,894,884 $ Public protection 1,268,539 1,160,181 1,414,790 1,558,094 1,820,803 Social services 87,568 82,637 69,314 80,730 111,223
Public ways and facilities 6,320,845 7,164,876 7,865,237 7,432,036 14,609,971 Community development 2,831,560 3,085,754 3,833,881 5,481,186 9,596,690 Culture and recreation 837,220 934,173 1,529,999 996,481 836,826 Total governmental activities program revenues 17,073,449 17,954,249 21,709,979 24,311,982 34,870,397 Business type activities:

Program revenues:

Water 11,932,955 9,232,389 7,312,514 5,616,869 5,759,100 Sewer 8,791,285 8,108,977 7,469,167 6,474,652 6,275,667 Solid waste 5,872,152 5,889,675 5,695,241 5,697,468 5,550,361 Drainage operations 692,227 706,793 955,602 686,328 793,149 Local transit 2,263,648 2,297,400 2,811,840 1,870,304 2,191,542 Golf course 100,469 93,797 96,542 117,562 122,494
Airport 1,038,032 1,810,619 551,005 647,283 1,341,754
Total business type activities program revenues 30,690,768 28,139,650 24,891,911 21,110,466 22,034,067 Total primary government program revenues $ 46,093,899 47,764,217 $ 46,601,890 $ 45,422,448 $ 56,904,464 $ Net (Expense)/Revenue
Governmental activities (24,319,434) $ (15,113,778) $ (18,917,851) $ (15,366,601) $ (3,818,123) $ Business type activities 1,346,683 (1,141,533) 1,884,598 (699,028) 2,086,035 Total primary government net expense $ (16,255,311) (22,972,751) $ (17,033,253) $ (16,065,629) $ (1,732,088) $ City of Madera
Schedule 2
Changes in Net Position (Continued)
Last Ten Fiscal Years (accrual basis of accounting)
Fiscal Years
189
2023 2022 2021 2020 2019
General Revenues and
Other Changes in Net Position
Governmental activities:

Taxes
Property taxes $ 13,505,386 $ 12,134,288 $ 11,020,353 $ 11,045,364 $ 4,332,639 Sales and use taxes 19,291,534 19,440,017 16,894,337 15,227,811 13,399,196 Franchises taxes 841,540 763,276 721,028 688,563 649,666 Other taxes 2,281,598 2,462,689 1,813,979 2,019,087 1,964,472 Investment income (loss) 959,461 (1,475,300) (97,360) 1,247,564 1,910,967 Miscellaneous 980,194 934,376 317,971 1,205,394 829,050 Gain (loss) on sale of capital assets - - 35,469 (42,920) 43,791 Transfers (1,917,609) 521,130 574,622 352,225 275,116
Special items - Transfers of assets - - 2,062,571 - -
Total governmental activities 35,942,104 34,780,476 31,280,399 33,805,659 23,404,897 Business type activities:

Property taxes 258,727 247,624 237,264 228,943 209,374
Investment income (loss) 679,254 (913,654) 340,816 548,322 407,450 Miscellaneous 1,035,824 680,464 113,658 78,165 76,531
Gain (loss) on sale of capital assets 52,605 135,300 - 86,556 - Transfers 1,917,609 (521,130) (574,622) (352,225) (275,116) Total business type activities 3,944,019 (506,696) 252,416 589,761 418,239 Total primary government $ 39,886,123 $ 34,273,780 $ 31,532,815 $ 34,395,420 $ 23,823,136 Change in Net Position
Governmental activities $ 16,769,811 $ 7,752,594 $ 9,367,369 $ 2,622,431 $ 2,209,033 Business type activities 3,494,130 7,905,623 8,471,022 8,581,837 6,845,705 Total primary government $ 20,263,941 $ 15,658,217 $ 17,838,391 $ 11,204,268 $ 9,054,738 City of Madera
Fiscal Years
Schedule 2
Changes in Net Position (Continued)
Last Ten Fiscal Years (accrual basis of accounting)
190
2018 2017 2016 2015 2014
General Revenues and
Other Changes in Net Position
Governmental activities:

Taxes
Property taxes $ 3,824,185 $ 4,040,067 $ 3,571,669 $ 2,837,432 $ 2,943,796 Sales and use taxes 12,923,918 9,112,909 6,506,004 5,638,847 5,472,283 Transient occupancy taxes 666,238 649,415 678,438 612,474 591,116 Other taxes 1,707,452 1,694,786 2,172,574 2,035,238 1,821,326 Investment earnings 265,581 203,973 603,795 309,988 795,691 Miscellaneous 1,147,727 343,287 580,398 577,213 1,071,486 Gain (loss) on sale of capital assets - 31,374 16,304 26,983 75,607 Transfers 374,407 172,913 1,718,751 1,065,193 2,538,648 Special items - Transfers of assets - - - - -
Total governmental activities 20,909,508 16,248,724 15,847,933 13,103,368 15,309,953 Business type activities:

Other taxes 182,390 171,878 58,333 70,353 61,049
Investment earnings 68,049 120,594 210,257 262,948 19,076 Miscellaneous 3,956 26,004 34,976 28,170 25,478
Gain (loss) on sale of capital assets 12,990 39,821 4,250 14,476 (11,968) Transfers (372,671) (172,913) (1,718,751) (1,065,193) (2,538,648) Total business type activities (105,286) 185,384 (1,410,935) (689,246) (2,445,013) Total primary government $ 16,434,108 20,804,222 $ 14,436,998 $ 12,414,122 $ 12,864,940 $ Change in Net Position
Governmental activities (3,409,926) $ 1,134,946 $ (3,069,918) $ (2,263,233) $ 11,491,830 $ Business type activities 1,241,397 (956,149) 473,663 (1,388,274) (358,978) Total primary government $ 178,797 (2,168,529) $ (2,596,255) $ (3,651,507) $ 11,132,852 $ City of Madera
Fiscal Years
Schedule 2
Changes in Net Position (Continued)
Last Ten Fiscal Years (accrual basis of accounting)
191
2023 2022 2021 2020 2019
General Fund
Nonspendable 141,842 $ 149,510 $ 139,843 $ 249,637 $ 202,901 $ Restricted 2,365,453 - - 401,700 4,934,403
Committed 15,130,431 10,903,504 11,194,964 10,292,405 10,483,246 Assigned 15,797,488 16,614,848 13,906,278 6,763,704 5,528,814 Unassigned 12,291,870 10,908,284 5,482,689 7,398,714 3,049,282 Total General Fund 45,727,084 38,576,146 30,723,774 25,106,160 24,198,646 All other Governmental Funds
Nonspendable 13,131 - 4,010 3,815 27
Restricted 50,277,926 43,876,531 45,692,871 55,277,667 39,377,503 Committed - - - - -
Assigned - - - - -
Unassigned (1,927,931) (1,300,623) (1,460,591) (959,555) - Total all other Governmental Fund 48,363,126 42,575,908 44,236,290 54,321,927 39,377,530 TOTAL FUND BALANCES 94,090,210 $ 81,152,054 $ 74,960,064 $ 79,428,087 $ 63,576,176 $ Last Ten Fiscal Years (modified accrual basis of accounting) Fiscal Years
City of Madera
Schedule 3
Fund Balances of Governmental Funds
192
2018 2017 2016 2015 2014
General Fund
Nonspendable $ 601,522 $ 272,102 $ 368,959 $ 258,252 $ 282,184 Restricted - - 646,823 - 87,453
Committed 11,574,005 - - - -
Assigned 1,199,518 1,199,518 1,199,518 727,159 1,199,518 Unassigned 4,673,303 13,968,482 12,879,473 12,326,175 11,280,658 Total General Fund 18,048,348 15,440,102 14,447,950 13,958,409 12,849,813 All other Governmental Funds
Nonspendable 42 8,547,157 - - -
Restricted 35,986,212 33,857,600 23,974,874 32,277,375 32,615,786 Committed - - - -
Assigned - - - - -
Unassigned - (231,803) - (221,039) 42,897
Total all other Governmental Fund 35,986,254 33,857,600 32,290,228 32,056,336 32,658,683 TOTAL FUND BALANCES $ 54,034,602 $ 49,297,702 $ 46,738,178 $ 46,014,745 $ 45,508,496 Last Ten Fiscal Years (modified accrual basis of accounting) Fiscal Years
City of Madera
Schedule 3
Fund Balances of Governmental Funds (Continued)
193
2023 2022 2021 2020 2019
Revenues
Taxes $ 5,773,982 $ 4,971,690 $ 4,331,022 $ 4,613,254 $ 4,332,639 Sales and use taxes 19,291,534 19,440,017 16,894,337 15,227,811 13,399,196 Other taxes 2,470,829 2,644,500 1,921,747 2,114,190 2,081,211 Use of money and property (689,229) 1,052,683 323,569 1,378,494 2,078,944 Franchises 841,540 763,276 721,028 688,563 649,666
Licenses, permits and fees 1,502,455 1,174,652 1,555,955 1,106,424 1,322,830 Fines 468,972 436,032 452,319 494,823 591,298
Intergovernmental 19,995,869 17,976,535 17,641,730 13,620,058 16,380,444 Charges for services 5,588,835 4,995,341 5,118,683 4,091,909 3,322,989 Other revenue 1,412,845 1,212,449 578,896 1,235,377 1,048,977 Total revenues 58,399,544 52,925,263 49,539,286 44,570,903 45,208,194 Expenditures
General government 4,301,922 3,874,775 3,628,480 2,691,729 3,075,710 Public protection 21,617,953 20,383,663 19,854,358 18,393,027 17,196,886 Social services 181,934 45,991 131,881 198,360 192,633
Public ways and facilities 3,800,991 6,072,097 3,319,019 5,957,037 4,233,896 Community development 4,548,230 5,178,403 5,839,428 3,130,348 3,429,815 Culture and recreation 4,687,240 3,237,150 2,796,274 3,300,189 4,006,826 Capital outlay 2,621,252 6,955,986 18,538,217 13,834,273 6,802,125 Debt service:

Principal 1,074,909 1,034,200 401,700 559,403 633,222
Interest 678,464 709,092 730,344 351,820 52,341
Total expenditures 43,715,921 47,288,331 55,239,701 48,416,186 39,623,454 Culture and recreation
Excess of revenues over (under) expenditures 14,683,623 5,636,932 (5,700,415) (3,845,283) 5,584,740 Other financing sources (uses)
Proceeds from sale of property 400 33,429 513,267 679,580 46,518 Proceeds from issuance of long-term debt - - 19,432,000 - 4,005,000 Premium on bond issuance - - - 648,613 -
Cost of issuance 23,636 - (84,752) - (153,613)
Transfers in 3,350,930 4,304,318 5,103,755 15,443,432 2,768,183 Transfers out (2,796,272) (6,106,850) (4,384,630) (15,773,066) (2,992,087) Total other financing sources (uses) (1,745,467) 555,058 1,232,392 19,697,194 4,322,614 Net change in fund balances $ 12,938,156 $ 6,191,990 $ (4,468,023) $ 15,851,911 $ 9,907,354 Debt service as a percentage of non-capital
expenditures 4.3% 4.3% 3.1% 2.6% 2.1%
Last Ten Fiscal Years (modified accrual basis of accounting) Fiscal Years
City of Madera
Schedule 4
Changes in Fund Balances of Governmental Funds
194
2018 2017 2016 2015 2014
Revenues
Taxes $ 3,825,921 $ 4,054,503 $ 3,115,740 $ 3,087,520 $ 2,869,599 Sales and used taxes 13,262,908 8,741,373 6,506,004 5,638,847 5,539,847 Other taxes 1,707,452 1,698,487 2,141,433 2,041,961 1,842,002 Use of money and property 392,428 358,735 767,778 463,853 961,315 Franchises 666,238 649,415 678,438 612,474 591,116
Licenses, permits and fees 1,049,103 701,825 646,800 595,255 395,730 Fines 588,584 750,388 935,358 985,169 874,861
Intergovernmental 11,781,034 12,654,660 16,326,841 15,934,329 28,437,678 Charges for services 3,457,257 3,497,588 3,240,452 6,041,361 5,775,536 Other revenue 924,918 632,560 437,305 908,991 1,453,736 Total revenues 37,655,843 33,739,534 34,796,149 36,309,760 48,741,420 Expenditures
General government 1,796,055 2,106,580 2,959,739 5,123,445 4,797,564 Public protection 16,932,579 14,934,669 14,621,471 13,616,969 13,177,569 Social services 309,121 405,251 357,699 330,062 510,579 Public ways and facilities 3,476,106 3,101,070 3,834,908 2,532,178 3,012,275 Community development 3,831,163 3,800,416 3,392,870 3,425,208 2,814,466 Culture and recreation 3,598,837 3,106,938 5,219,577 5,380,767 4,681,217 Capital outlay 2,519,381 3,143,357 7,073,119 5,255,764 10,925,198 Debt service:

Principal 1,452,775 568,464 977,512 425,970 415,920
Interest 75,660 113,860 266,431 259,255 270,255
Total expenditures 34,271,455 31,000,827 38,703,326 36,349,618 40,605,043 Excess of revenues over (under) expenditures 3,384,388 2,738,707 (3,907,177) (39,858) 8,136,377 Other financing sources (uses)
Proceeds from sale of property 37,027 41,691 9,969 - -
Proceeds from issuance of long-term debt 895,900 - - - - Premium on bond issuance - 1,540,065 - 157,755 -
Cost of issuance - - - - -
Transfers in 4,504,230 5,005,541 7,289,955 5,557,426 6,338,959 Transfers out (4,812,845) (5,284,157) (6,109,973) (5,111,740) (4,357,470) Total other financing sources (uses) 658,975 (271,588) 2,730,016 603,441 1,981,489 Net change in fund balances $ 4,043,363 $ 2,467,119 $ (1,177,161) $ 563,583 $ 10,117,866 Debt service as a percentage of non-capital
expenditures 4.8% 2.4% 3.9% 2.2% 2.3%
Last Ten Fiscal Years (modified accrual basis of accounting) Fiscal Years
City of Madera
Schedule 4
Changes in Fund Balances of Governmental Funds (Continued) 195
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196
Sources of Business Franchise Property Sales Transient Gas Tax Revenues Licenses Fees Tax Tax 1 Occupancy Tax TOTAL 2022-2023 567,304 $ 1,052,683 $ 5,773,982 $ 19,291,534 $ 1,105,972 $ 2,910,090 $ 30,701,565 $ 2021-2022 566,564 763,276 4,971,690 19,440,017 1,149,939 2,807,345 29,698,831 2020-2021 291,109 721,028 4,331,022 16,894,337 886,017 2,563,059 25,686,572 2019-2020 578,040 688,563 4,613,254 15,227,811 804,286 2,578,121 24,490,075 2018-2019 442,443 649,666 4,332,639 13,399,196 903,124 2,397,464 22,124,532 2017-2018 447,059 666,238 3,824,186 12,934,817 - 1,607,173 19,479,473 2016-2017 426,375 649,415 3,696,995 8,741,373 - 1,145,897 14,660,055 2015-2016 416,806 678,438 3,115,740 6,506,004 - 1,290,623 12,007,611 2014-2015 408,728 612,474 3,087,520 5,638,847 - - 9,747,569 2013-2014 392,946 591,116 2,869,599 5,539,847 - 4,007,477 13,400,985 NOTES:
1) The City passed "Measure T" allowing an additional increase of 0.50% in the local sales tax rate. This local measure became effective on April 1, 2007 and ends on March 31, 2027. In addition, the City passed "Measure K", an additional 0.50% sales tax increase specifically for public safety in November 2016 with no sunset date.

City of Madera
Schedule 5
Governmental Activities Tax Revenues by Source
Last Ten Fiscal Years (modified accrual basis of accounting) 197
CATEGORY 2023 2022 2021 2020 2019
Residential $ 2,760,446,564 $ 2,496,189,868 $ 2,335,164,803 $ 2,201,293,176 $ 2,035,513,239 Commercial 520,965,786 498,301,393 483,155,413 443,426,571 429,900,137 Industrial 186,944,825 169,861,323 174,322,830 178,171,356 179,040,074 Agriculture 15,017,779 14,056,096 13,017,642 13,457,474 12,920,915 Dry Farm 16,137,016 15,746,916 15,306,770 15,019,028 15,391,780 Government - - 2,036,417 2,054,539 -
Institutional 1,426,383 1,603,250 1,920,464 1,282,549 1,674,829 Irrigated 1,732,408 1,697,771 1,680,888 1,635,256 1,603,053 Cross Reference 39,530,686 38,833,078 40,913,367 37,692,391 39,817,937 Vacant Land 212,580,116 207,422,925 196,572,803 183,027,173 219,593,087 SBE Non-Unitary 590,440 548,402 548,402 625,460 625,460 Unsecured 306,329,667 305,755,769 307,490,035 287,932,288 280,734,337 Unknown 653,585 643,408 638,191 628,316 1,236,714
TOTALS 4,062,355,255 3,750,660,199 3,572,768,025 3,366,245,577 3,218,051,562 Total Direct Rate 0.13287 0.12699 0.13147 0.13198 0.13281 NOTES:

City of Madera
Schedule 6
Assessed Value of Taxable Property
Last Ten Fiscal Years
Fiscal Years
In 1978 the voters of the State of California passed Proposition 13 which limited taxes to a total maximum rate of 1%, based upon the assessed value of the property being taxed. Each year, the assessed value of property may be increased by an "inflation factor" (limited to a maximum of 2%). With few exceptions, property is only reassessed as a result of new construction activity or at the time it is sold to a new owner. At that point, the property is reassessed based upon the added value of the construction or at the purchase price (market value) or economic value of the property sold. The assessed valuation data shown above represents the only data currently available with respect to the actual market value of taxable property and is subject to the limitations described above. * Beginning in 2013/14 the Total Direct Rate no longer includes revenue generated from the former redevelopment tax rate areas. For the purposes of this report, residual revenue is assumed to be distributed to the City in the same proportions as General Fund revenue.

Exempt values are not included in Total
Source: HdL Coren Cone 198
CATEGORY 2017 2017 2016 2015 2014*
Residential $ 1,824,835,555 $ 1,824,835,555 $ 1,739,590,175 $ 1,629,686,371 $ 1,518,325,305 Commercial 403,687,826 403,687,826 386,226,705 376,032,631 366,862,480 Industrial 166,063,864 166,063,864 178,416,598 170,784,960 164,018,245 Agriculture 5,275,944 5,275,944 5,153,044 5,042,110 4,791,797 Dry Farm 13,830,501 13,830,501 11,764,375 12,516,645 12,649,078 Government 5,950 5,950 5,861 5,747 5,722
Institutional 1,295,250 1,295,250 1,558,852 1,348,373 1,242,996 Irrigated 1,566,070 1,566,070 1,541,526 1,510,496 1,502,446 Cross Reference 35,511,414 35,511,414 34,716,877 28,515,201 23,735,117 Vacant Land 166,553,864 166,553,864 155,926,515 153,947,112 158,636,497 SBE Non-Unitary 743,768 743,768 743,768 743,768 743,768 Unsecured 221,973,452 221,973,452 201,164,923 200,566,825 191,093,988 Unknown 4,025,707 4,025,707 3,939,930 3,939,713 3,540,012 TOTALS 2,845,369,165 2,845,369,165 2,720,749,149 2,584,639,952 2,447,147,451 Total Direct Rate 0.13243 0.13243 0.13255 0.1328 0.13242 NOTES:

City of Madera
Schedule 6
Assessed Value of Taxable Property (Continued)
Last Ten Fiscal Years
Fiscal Years
In 1978 the voters of the State of California passed Proposition 13 which limited taxes to a total maximum rate of 1%, based upon the assessed value of the property being taxed. Each year, the assessed value of property may be increased by an "inflation factor" (limited to a maximum of 2%). With few exceptions, property is only reassessed as a result of new construction activity or at the time it is sold to a new owner. At that point, the property is reassessed based upon the added value of the construction or at the purchase price (market value) or economic value of the property sold. The assessed valuation data shown above represents the only data currently available with respect to the actual market value of taxable property and is subject to the limitations described above. * Beginning in 2013/14 the Total Direct Rate no longer includes revenue generated from the former redevelopment tax rate areas. For the purposes of this report, residual revenue is assumed to be distributed to the City in the same proportions as General Fund revenue.

Exempt values are not included in Total
Source: HdL Coren Cone 199
Fiscal Year Taxes Levied Collections
Ended for the Percentage in Subsequent Percentage
June 30 Fiscal Year Amount of Levy Years 1 Amount of Levy 2023 $ 4,337,253 $ 4,090,897 94.32% $ 9,509 $ 4,100,406 94.54% 2022 3,804,550 3,763,833 98.93% 5,281 3,769,114 99.07%
2021 3,591,118 3,582,748 99.77% 3,582,748 - 99.77%
2020 3,409,931 3,394,991 99.56% 4,184 3,399,175 99.68%
2019 3,229,350 3,127,793 96.86% 23,314 3,151,107 97.58% 2018 3,128,370 3,093,867 98.90% 1,000 3,094,867 98.93%
2017 2,933,663 2,917,792 99.46% (10,357) 2,907,435 99.11% 2016 N/A N/A 0.00% - - 0.00%
2015 N/A N/A 0.00% - - 0.00%
2014 N/A N/A 0.00% - - 0.00%
NOTES:

N/A - Information not available
Fiscal Year of the Levy Total Collections to Date
1) Delinquent tax collections are recorded in the current levy year and the County does not give the detail as to the levy year for delinquent tax collections. Delinquent tax collections do not include interest and penalties.

City of Madera
Schedule 7
Property Tax Levies and Collections
Last Ten Fiscal Years
Collected within the
200
Fiscal Year
Ended June 30, City of Madera
Madera Unified
School District
State Center
Community
College County-wide Total
2023 0.0% 11.4% 2.8% 100.0% 114.3%
2022 0.0% 12.5% 1.8% 100.0% 114.3%
2021 0.0% 12.5% 1.8% 100.0% 114.3%
2020 0.0% 16.5% 2.6% 100.0% 119.1%
2019 0.0% 9.7% 2.3% 100.0% 112.0%
2018 0.0% 10.3% 2.6% 100.0% 112.9%
2017 0.0% 11.4% 0.8% 100.0% 112.2%
2016 0.0% 12.8% 0.8% 100.0% 113.6%
2015 0.0% 7.3% 0.9% 100.0% 108.2%
2014 0.0% 7.9% 1.0% 100.0% 108.8%
Note: The basis for the tax rates is $100 per assessed valuation. Only 1% of the value is taxed.

Source: Madera County Auditor-Controller Tax Rate Book
City of Madera
Schedule 8
Direct and Overlapping Property Tax Rates
Last Ten Fiscal Years
Source: HdL Coren Cone 201
Percentage of Percentage of
Taxable Total Taxable Taxable Total Taxable
Assessed Assessed Assessed Assessed
Taxpayer Rank Value Value Rank Value Value
John Hancock Life Insurance Co. 1 48,146,582 $ 1.17%
Severn Peanut Company, Inc. 2 24,123,962 $ 0.58%
David L and Partrica R Berry 3 23,638,496 0.57% 1 23,286,493 0.95% Evapco, Inc. 4 21,242,462 0.51%
Sealed Air Corporation 5 20,900,085 0.51% 3 17,751,837 0.72% Newman Development Group of Madera 6 19,532,017 0.47% 6 15,722,442 0.64% The Almond Company 7 19,284,010 0.47%
Crossroads Madera 8 19,137,479 0.46%
801 N Granada Drive LLC 9 18,985,200 0.46%
OldCastle Precast Inc 10 17,900,162 0.43% 2 20,859,668 0.85% Lowes HIW Inc 4 17,725,468 0.72%
Advanced Drainage System 5 16,660,960 0.68%
Berry & Berry, Inc. 7 13,836,594 0.56%
Airport Drive Investment, LLC. 8 13,658,009 0.56%
Eurodrip USA, Inc. 9 13,643,632 0.55%
Color Box, LLC. 10 13,451,501 0.55%
Top Ten Totals 232,890,455 $ 5.64% 166,596,604 $ 6.77%
CITY TOTALS $ 2,459,841,087 4,130,257,128 $
2022-2023 2013-2014
City of Madera
Schedule 9
Top Ten Principal Property Taxpayers
Fiscal Year 2023 and Ten Years Prior
Source: HdL Coren Cone 202
General Special Total Percentage of
Fiscal Obligation Redevelopment Assessment Loans Finance Primary Personal Per Year Bonds Bonds b Bonds Payable Purchase Government Income a Capita a 2023 $ 30,140,000 - $ - $ 299,800 $ 17,834,000 $ 48,273,800 $ 3.57% 737$ 2022 31,580,000 - 414,200 - 18,644,000 50,638,200 4.24% 769 2021 32,970,000 - 525,400 - 19,432,000 52,927,400 4.43% 804 2020 34,295,000 - 633,600 - 19,595,500 54,524,100 4.71% 824 2019 39,862,859 - 738,900 - 492,602 41,094,361 3.84% 628 2018 43,765,850 - 863,554 - 1,023,325 45,652,729 4.59% 687 2017 45,039,358 - 60,088 - 2,425,766 47,525,212 4.95% 718 2016 46,207,821 - 2,683,119 98,022 3,002,145 51,991,107 5.67% 787 2015 47,346,304 - 2,722,525 661,052 1,874,496 52,604,377 5.82% 803 2014 48,439,787 - 2,756,931 842,091 1,964,615 54,003,424 6.03% 857 NOTES:
a)
b) As of February 1, 2012 all redevelopment agencies in California ceased to exist per ABX1 26. The Madera Redevelopment Agencies' obligations were transferred to the Successor Agency.

City of Madera
Schedule 10
Ratios of Outstanding Debt by Type
Last Ten Fiscal Years

GOVERNMENTAL ACTIVITIES
See Schedule 15 (Demographic and Economic Statistics) for personal income and population data 203
Percentage
General Special of Taxable
Fiscal Obligation Redevelopment Assessment Assessed Per Year Bonds Bonds c Bonds Total Property Values a Capita b 2023 30,140,000 - - 30,140,000 0.74% 460 $
2022 - 31,580,000 - 31,580,000 0.84% 480 $
2021 32,970,000 - - 32,970,000 0.92% 501 $
2020 - 34,295,000 - 34,295,000 0.91% 518 $
2019 - 39,862,859 - 39,862,859 1.18% 609 $
2018 - 43,794,788 - 43,794,788 1.36% 659 $
2017 - 45,039,358 - 45,039,358 1.51% 680 $
2016 - 46,231,429 2,683,119 48,914,548 1.72% 740 $
2015 - 47,379,250 2,722,525 50,101,775 1.84% 765 $
2014 - 48,459,969 2,756,931 51,216,900 1.98% 813 $
NOTES:
a) Assessed Value and Actual Value of Taxable Property - provided by HdL, Coren & Cone provided data b) Demographic and Economic Statistics for personal income and population data - Schedule 15 c) As of February 1, 2012 all redevelopment agencies in California ceased to exist per ABX1 26. The Madera Redevelopment Agencies' obligations were transferred to the Successor Agency.

City of Madera
Schedule 11
Ratios of General Bonded Debt Outstanding
Last Ten Fiscal Years

GOVERNMENTAL ACTIVITIES
204
2022-23 Assessed Valuation: $4,062,355,255
Debt
Outstanding % City's Share of
OVERLAPPING TAX AND ASSESSMENT DEBT: 6/30/2023 Applicable 1 Debt as of 6/30/23 State Center Community College District $ 394,910,000 3.768% $ 14,880,209 Madera Unified School District 155,719,922 51.298% $ 79,881,206 City of Madera Community Facilities District No. 2006-1 2,068,320 100.000% $ 2,068,320 TOTAL OVERLAPPING TAX AND ASSESSMENT DEBT $ 96,829,733
DIRECT AND OVERLAPPING GENERAL FUND OBLIGATION DEBT:

Madera County General Fund Obligations 69,728,679 22.324% $ 15,566,230 Madera County Board of Education General Fund Obligations 18,898,549 22.324% 4,218,912 Madera Unified School District Certificates of Participation 82,970,000 51.298% 42,561,951 City of Madera General Fund Obligations Direct Debt 21,765,600 100.000% 21,765,600 TOTAL DIRECT AND OVERLAPPING GENERAL FUND OBLIGATION DEBT $ 84,112,694 OVERLAPPING TAX INCREMENT DEBT (Successor Agency): $ 98.851% 29,793,691 30,140,000 $ TOTAL DIRECT DEBT $ 21,765,600
TOTAL OVERLAPPING DEBT $ 188,970,519
COMBINED TOTAL DEBT $ 210,736,119
NOTES:
(1) Percentage of overlapping agency's assessed valuation located within boundaries of the city. (2) Excludes tax and revenue anticipation notes, enterprise revenue, mortgage revenue and non-bonded capital lease obligations.

City of Madera
Schedule 12
Direct and Overlapping Governmental Activities Debt
As of June 30, 2023
Source: MuniServices, LLC 205
Legal Debt Margin Calculation FY 2023 FY 2022 FY 2021 FY 2020 FY 2019 Assessed value $ 4,130,257,128 $ 3,750,660,199 $ 3,750,525,788 $ 3,572,633,614 $ 3,366,111,166 Debt limit (15% of assessed value) 619,538,569 562,599,030 562,578,868 535,895,042 504,916,675 Debt applicable to limit:

General obligation bonds - - - - -
Less: Amount set aside for repayment
of general
obligation debt - - - - -
Total net debt applicable to limit - - - - -
Legal Debt Margin 619,538,569 562,599,030 562,578,868 535,895,042 504,916,675 Total debt applicable to the limit as a
percentage of debt limit 0.00% 0.00% 0.00% 0.00% 0.00%
NOTES:

Last Ten Fiscal Years
Under State Finance Law, the City's outstanding general obligation debt should not exceed 15% of total assessed property value. By law, the general obligation debt subject to the limitation may be offset by amounts set aside for repaying general obligation bonds.

City of Madera
Schedule 13
Legal Debt Margin Information
206
Legal Debt Margin Calculation FY 2018 FY 2017 FY 2016 FY 2015 FY 2014 Assessed value $ 3,214,555,536 $ 2,984,863,745 $ 2,843,541,362 $ 2,717,869,926 $ 2,580,951,334 Debt limit (15% of assessed value) 482,183,330 447,729,562 426,531,204 407,680,489 387,142,700 Debt applicable to limit:

General obligation bonds - - - - -
Less: Amount set aside for repayment
of general
obligation debt - - - - -
Total net debt applicable to limit - - - - -
Legal Debt Margin 482,183,330 447,729,562 426,531,204 407,680,489 387,142,700 Total debt applicable to the limit as a
percentage of debt limit 0.00% 0.00% 0.00% 0.00% 0.00%
NOTES:

Last Ten Fiscal Years
Under State Finance Law, the City's outstanding general obligation debt should not exceed 15% of total assessed property value. By law, the general obligation debt subject to the limitation may be offset by amounts set aside for repaying general obligation bonds.

City of Madera
Schedule 13
Legal Debt Margin Information (Continued)
207
Net Revenue
Fiscal Gross Available for
Year Revenues Debt Service Principal Interest Coverage
2023 25,365,131 $ 15,129,771 $ 1,295,000 $ 859,510 $ 7.02 2022 24,441,447 12,898,231 1,250,000 905,760 5.98
2021 23,085,235 11,537,418 1,200,000 950,160 5.37
2020 23,244,181 10,309,898 1,155,000 992,895 4.80
2019 21,434,207 6,380,941 1,120,000 1,034,335 2.96
2018 20,664,801 4,378,989 1,075,000 1,074,110 2.04
2017 17,181,561 1,139,743 1,040,000 1,112,590 0.53
2016 14,673,722 3,883,912 70,000 275,697 11.24
2015 - - - - -
2014 - - - - -
Net Revenue
Fiscal Gross Available for
Year Revenues Debt Service Principal Interest Coverage
2023 13,244,985 $ 8,306,127 $ 435,546 $ 203,439 $ 13.00 2022 13,465,525 7,402,503 418,148 214,592 11.70
2021 12,511,993 6,379,309 409,781 225,466 10.04
2020 12,428,666 6,697,361 374,080 40,336 16
2019 - - - - -
2018 - - - - -
2017 - - - - -
2016 - - - - -
2015 - - - - -
2014 - - - - -
City of Madera
Schedule 14
Pledged Revenue Coverage
Last Ten Fiscal Years
Debt Service
Debt Service
2015 Water and Wastewater Revenue Bonds
2019 Water Refunding Bonds
208
Net Revenue
Fiscal Gross Available for
Year Revenues Debt Service Principal Interest Coverage
2023 12,120,146 $ 6,823,644 $ 379,000 $ 142,037 $ 13.10 2022 10,792,230 5,495,728 372,000 150,626 10.52
2021 10,573,242 5,158,109 331,996 196,593 9.76
2020 10,823,426 4,645,738 322,295 206,439 8.79
2019 9,776,777 986,633 312,877 215,998 1.87
2018 8,788,389 266,204 303,735 225,278 0.50
2017 8,042,174 613,008 294,860 234,287 1.16
2016 7,407,933 788,484 286,244 243,032 1.49
2015 5,621,814 984,022 277,879 251,522 1.86
2014 6,199,330 491,670 269,760 0 259,764 0 0.93
Special Net Revenue
Fiscal Assessment Available for
Year Collections Debt Service Principal Interest Coverage 2023 3,049,112 $ 2,799,122 $ 1,440,000 $ 1,403,216 $ 0.98 2022 2,871,594 2,621,594 1,390,000 1,461,510 0.92
2021 3,375,855 3,056,710 1,325,000 1,516,309 1.08
2020 2,790,658 598,095 1,215,000 1,563,337 0.22
2019 3,343,667 2,227,379 1,215,000 1,777,468 0.74
2018 3,686,763 2,917,577 1,295,000 2,269,784 0.82
2017 3,879,515 2,780,354 1,250,000 2,323,983 0.78
2016 1,951,305 209,883 1,190,000 2,374,693 0.06
2015 6,218,663 5,727,877 1,140,000 2,427,021 1.61
2014 724,744 444,534 1,095,000 0 2,474,236 0 0.12
Successor Agency 2018 Tax Allocation Bonds
Debt Service
City of Madera
Schedule 14
Pledged Revenue Coverage (Continued)
Last Ten Fiscal Years
Wastewater Loans Payable
Debt Service
209
Personal
Personal Per Capita School Unemployment
Year Population (1) Income Income (1) Enrollment Rate
2022 65,540 1,352,811,140 $ 20,641 $ 32,161 6.6%
2021 65,843 1,194,391,000 18,139 31,494 9.1%
2020 66,172 1,158,300,000 17,504 32,144 10.9%
2019 65,415 1,069,038,000 16,342 31,925 7.8%
2018 66,419 994,407,000 14,971 31,728 7.7%
2017 66,225 959,263,000 14,484 31,468 7.3%
2016 66,082 917,664,000 13,886 31,077 7.9%
2015 65,474 904,576,000 13,815 30,865 9.1%
2014 63,008 894,966,000 14,204 30,861 9.6%
2013 63,008 895,029,000 14,205 30,478 16.0%
NOTES:

Source:
www.cde.ca.gov
MuniServices, LLC
City of Madera
Schedule 15
Demographic and Economic Statistics
Last Ten Fiscal Years
Data provided by HdL, Coren & Cone
1 Demographic data has a lag because of time to tabulate, 2023 data not available at this time. 210
Percentage Percentage
of Total City of Total City
Employer Employees Rank Employment Employer Employees Rank Employment Madera Unified School District 3500 1 7.94% Madera Unified School District 2139 2 6.22% State of California 2600 2 5.90%
County of Madera 1516 3 3.44% County of Madera 1188 3 3.45% Wal Mart 350 4 0.79%
City of Madera 310 5 0.70% City of Madera 310 7 0.90%
US Government 300 6 0.68%
Camarena Health 249 7 0.57%
Community Action Partnership of Madera Co 235 8 0.53%
Home Depot 170 9 0.39%
JBT Food Tech 165 10 0.37% JBT Food Tech 143 8 0.42%
Valley Children's Healthcare 2500 1 7.27%
Madera Community Hospital 936 4 2.72%
Constellation Wines 400 5 1.16%
Ardagh Group 350 6 1.02%
Evapco West 140 9 0.41%
Georgia Pacific Corp 125 10 0.36%
9395 4.04% 8231 12.99%
44,063 34,400
Source: 2022-23 data based on City of Madera 2023-24 Budget Source: California Employment Department or employer provided ( - ) No data available.
2022-2023 2013-2014
Total City Employment
City of Madera
Schedule 16
Principal Employers
Fiscal Year 2023 and Ten Years Prior
Source: MuniServices LLC 211
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212
FUNCTION/PROGRAM 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 General Government
City Attorney 0000222222
City Council 7777777777
City Manager 2.7 3.7 2.7 2.7 1.7 1.95 2.7 0.7 0.7 1
City Clerk 2222222222
Finance 27.6 24.9 27.7 24.89 24.73 23.73 24.5 24.03 24.45 25.48 Information Technology 4 4 4.2 4.17 4.25 44444
Human Resources 4444444444
Community Development 10.64 1 10.8 1 14.9 18.97 19.59 21.46 21.86 22.13 21.38 21.27 Planning Commissioners 0000000000
Public Safety
Police Officers-Sworn 76 71 71 70.3 70.01 69.84 60 57.25 57 57 Other Full-Time Employees 32 24 24 24 23.48 23.48 20 20 20 20 Public Works
Engineering 19.44 19.9 17.9 13.63 14.67 11.21 11.69 11.85 10.74 10.61 Maintenance 28.22 24.7 17.5 34.45 27.33 28.88 29.57 30.97 30.71 34.78 Transit Services 4.75 5.3 1.7 2.7 3.08 3.08 3.38 3.38 2.98 2.98 Airport 1.88 1.9 1.9 2.86 2.88 2.98 2.46 2.46 2.36 2.58 Solid Waste Disposal 7.26 0.7 0.7 1 6.48 8.88 9.02 7.77 6.69 3.38 Storm Drainage 4.69 4.8 4.1 5.45 5.74 4.54 5.19 4.89 5.89 5.45 Waster 20.54 15.1 18.4 22.34 23.08 25.18 20.66 18.66 16.81 14.74 Wastewater/Sewer 18.82 19.7 25.1 24.66 26.29 26.62 20.32 20.07 19.04 17.59 Waste Disposal Recycling 0 0 0 0 1 1.3 1.35 1.3 1.2 0
Successor Agency/RDA 0.5 0.5 0.5 1 1.8 2.3 2.3 2.3 2.59 2.62 Culture & Recreation 53.81 49.1 37.4 47.64 51.42 56.05 61.12 60.9 53.01 45.67 Total 325.85 293.1 282.7 313.76 322.53 330.48 315.12 307.66 294.55 284.15 City of Madera
Schedule 17
Full-Time Equivalent City Government Employees by Function/Program Last Ten Fiscal Years (As of June 30)
Fiscal Years
213
FUNCTION/PROGRAM 2023 2022 2021 2020 2019
Police
Physical Arrests 2,317 2,653 1,789 1,829 2,381
Parking Violations 401 541 1,432 2,189 1,417
Traffic Violations 1,854 2,676 2,206 3,385 5,141
Community Development
Building Permits Issued 3,534 3,010 2,236 1,797 2,202
Building Inspections Performed 17,324 20,369 12,003 12,003 13,322 Planning Permits Issued 367 270 200 153 196
Public Services
Street Resurfacing (miles) 18 11 16 3 5
Street Light Replacement 203 186 115 86 64
Potholes Filled 1,936 4,836 2,864 2,012 2,341
Waste Water Average Daily
Treatment (millions of gallons) 5 5 5 5 5
Transit Route (Service) Miles 283,815 238,887 258,599 317,504 352,476 Transit Passenger Count 84,567 52,164 54,683 95,326 108,535 Parks & Recreation
Sports Field Participation 775 1,603 360 1,802 1,701
Community Center/Gym/Pool Participation 24,222 14,170 24,728 31,779 38,271 Other Participation 19,629 10,152 86,364 124,062 133,186 NOTES:

N/A - Information not available
Fiscal Years
City of Madera
Schedule 18
Operating Indicators by Function/Program
Last Ten Fiscal Years (As of June 30)
Source: Various City Departments 214
FUNCTION/PROGRAM 2018 2017 2016 2015 2014
Police
Physical Arrests 1,585 1,014 N/A N/A N/A
Parking Violations 953 777 N/A N/A N/A
Traffic Violations 1,824 2,801 N/A N/A N/A
Community Development
Building Permits Issued 2,390 N/A N/A N/A N/A
Building Inspections Performed 16,106 15,186 N/A N/A N/A Planning Permits Issued 234 211 N/A N/A N/A
Public Services
Street Resurfacing (miles) 6 4 8 5 N/A
Street Light Replacement a 206 92 N/A N/A N/A
Potholes Filled 2,703 2,542 N/A N/A N/A
Waste Water Average Daily
Treatment (millions of gallons) 5 5 5 5 5
Transit Route (Service) Miles 140,033 366,788 N/A N/A N/A Transit Passenger Count 143,746 142,991 N/A N/A N/A
Parks & Recreation
Sports Field Participation N/A N/A N/A N/A N/A
Community Center/Gym/Pool Participation N/A N/A N/A N/A N/A Other Participation N/A N/A N/A N/A N/A
NOTES:

Fiscal Years
City of Madera
Schedule 18
Operating Indicators by Function/Program
Last Ten Fiscal Years (As of June 30) (Continued)
Source: Various City Departments 215
FUNCTION/PROGRAM 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 Police
Stations 1111111111
Patrol Units (marked) 19 19 41 41 35 35 34 N/A N/A N/A
Motorcycle unit 5 5 5 4 4 5 3 N/A N/A N/A
K-9 unit 333333 3 3 N/A N/A N/A
Streets
Streets (miles) 203 199 199 199 160 N/A N/A N/A N/A N/A Streetlights 3326 3309 3000 3000 3000 N/A N/A N/A N/A N/A Traffic Signals
CalTrans maintained 16 16 15 15 15 N/A N/A N/A N/A N/A
City of Madera maintained 35 34 32 29 29 N/A N/A N/A N/A N/A Culture & Recreation
Total Park Acreage 160 160 159 159 151 N/A N/A N/A N/A N/A Parks 16 16 15 15 13 N/A N/A N/A N/A N/A
Baseball Fields 2 2 2 2 2 N/A N/A N/A N/A N/A
Softball Fields 9 9 9 9 9 N/A N/A N/A N/A N/A
Soccer Fields 7 7 7 7 7 N/A N/A N/A N/A N/A
Football Fields 0 0 0 0 0 N/A N/A N/A N/A N/A
Tennis Courts 0 0 0 0 0 N/A N/A N/A N/A N/A
Swimming Pools 3 3 3 3 3 N/A N/A N/A N/A N/A
Community Centers 3 3 3 3 3 N/A N/A N/A N/A N/A
Waste Water
Sanitary Sewers (miles) 375.1 375 375 375 408 00000
Storm Sewers (miles) 0000000000
Treatment Capacity (millions of gallons/day) 7000000000 Transit Services
Minibuses
Fixed Route 11 11 11 11 11 11 11 N/A N/A N/A
Dial A Ride 6 6 6 6 6 6 6 N/A N/A N/A
Bus Shelters 71 71 71 71 71 71 71 N/A N/A N/A
NOTES:

N/A - Information not available
City of Madera
Schedule 19
Capital Asset Statistics by Function/Program
Last Ten Fiscal Years
Source: Various City Departments 216

REPORT TO CITY COUNCIL
Council Meeting of: April 3, 2024
Agenda Number: ___________
Keith Helmuth, Department Director
Arnoldo Rodriguez, City Manager
SUBJECT:

Madera Subbasin Joint Groundwater Sustainability Plan (GSP) – Council Update and Consideration of Five-Year Evaluation and Update of the GSP RECOMMENDATION:

Receive update and provide direction regarding information provided as part of this update to City Council
SUMMARY:

The City of Madera (City) is one of seven agencies that have established a Groundwater Sustainability Agency (GSA) within the boundaries of Madera Groundwater Subbasin (Subbasin) pursuant to the 2014 Sustainable Groundwater Management Act (SGMA). The seven GSAs include the following members:
 City of Madera (City)  Gravelly Ford Water District
 County of Madera (County)  Root Creek Water District  Madera Irrigation District (MID)  New Stone Water District (NWSD)  Madera Water District (MWD)
Four GSAs, including the City, County, MID, and MWD, prepared one joint GSP.

The original GSP, prepared in 2020, requires GSAs to achieve groundwater sustainability in a subbasin by 2040. Combined, the original GSP GSAs are responsible for approximately 95 percent of the Subbasin.

Approved by:

Groundwater Sustainability Agency
E-2
The remaining three GSAs, Gravelly Ford Water District GSA, Root Creek Water District GSA and New Stone Water District GSA, each prepared their own individual GSPs, which, when combined with the joint GSP, collectively cover the entire Subbasin as required by SGMA.

The GSAs were required to prepare, adopt and begin implementing the GSP by January 31, 2020.

Following the adoption of the GSP in January 2020, the GSAs were required to submit an update to the GSP every five years. Between the initial adoption and the Five-Year Update, annual reports are also required.

DISCUSSION:

Compliance with SGMA
While the GSP was submitted on time, the Department of Water Resources (DWR) did not initiate their review until October 9, 2020 due to the inability of all seven GSAs to enter into a coordination agreement, also required as a part of SGMA. The results of this review which identified four deficiencies in the GSP was sent to the Subbasin Point of Contact in a letter (Letter) dated September 22, 2022.

In the Letter, DWR represented that if the deficiencies were not addressed by March 21, 2023, DWR, after consultation with the State Water Resources Control Board, would determine the GSP to be inadequate. Such a designation had the potential to trigger a state intervention process as outlined in SGMA.

As a result of the Letter, the GSP was revised to address the deficiencies and submitted to DWR through an upload to the SGMA Portal on March 21, 2023. A very general explanation of how the deficiencies were addressed is as follows:
 Coordination
o Include addendum to the Coordination Agreement in the Revised GSP that addresses sustainability goals and current and projected water balances. An addendum was prepared. Council approved at the draft stage given time constraints.
o Establish Domestic Well Mitigation MOU – A draft of this MOU is incorporated into the Revised GSP. Council approved at the draft stage given time constraints.  Chronic Lowering of Groundwater Table – Revised GSP will use Fall 2015 as basis for the Minimum Threshold. This results in minimum thresholds being higher than the original GSP.
 Land Subsidence—The Revised GSP established a maximum rate of subsidence that decreases in 5-year increments, with the initial rates based on the 2014/15 annual rate of subsidence.
 Interconnected Water Surface – The GSP assumes maintaining the historical time of connection into the future.

As part of the submittal of the Revised GSP, all GSAs that are party to the GSP are expected to adopt the GSP. One GSA, MID, however did not adopt the plan. This resulted in a request for clarification from DWR on April 6, 2023 (See Attachment 1) as the decision by MID raised “significant” questions on the part of the DWR. MIDs decision to not adopt the Revised GSP was explained in a press release (See Attachment 2) stating the MID Board was unable to take action to approve the Revised GSP. The release, prior to DWR’s letter explained the MID board’s decision to not approve (adopt) was based on their opinion that the Revised GSP did not address concerns that included lowering of groundwater tables, water quality impacts, and domestic well concerns. It reported that the “MID Board of Directors strongly felt the Revised GSP did not address these concerns,” and that it “failed to address … very impactful changes and factors.” MID later responded to DWR on April 21, 2023 (Attachment 3). The summary of that letter indicated:
“….the MID GSA strongly believes that the State’s objectives related to the Sustainable Groundwater Management Act (SGMA) would have been thwarted had the MID GSA elected to approve the submission of a revised plan that (i) did not reflect reality, (ii) were fundamentally inaccurate, and (iii) lacked any mechanism for accountability on the part of its signatory GSAs. Thus, while the MID GSA will continue to fully implement its own obligations under the Revised Joint GSP, the MID GSA cannot adopt the Revised Joint GSP without substantial revision.”
As a result of the GSP not being adopted by all four parties to it and DWRs concerns as expressed in their letter of April 6, 2023, there was some concern by the group that the DWR would declare the revised GSP as inadequate and placing the Subbasin in a situation in which the DWR would intervene in its management. Fortunately, the DWR made a determination on December 21, 2023 (Attachment 4) that all four GSPs when considered collectively as the Plan, are approved.

The approval is based on a determination that the Plan conforms to specific requirements of SGMA, is likely to achieve the sustainability goal for the basin covered by the Plan, and whether the Plan adversely affects the ability of an adjacent basin to implement its GSP or impedes achievement of sustainability goals in an adjacent basin.

As part of the approval, a series of corrective actions have been recommended to be addressed in the next evaluation of the plan. It is anticipated these actions will be addressed as part of the upcoming Five-Year Update.

Five-Year Update
As noted previously, the GSAs were required to prepare, adopt and begin implementing the GSP by January 31, 2020. Following the adoption of the GSP in January 2020, the GSAs were required to submit annual reports addressing progress with regard to projects identified in the GSP as well as any other items that may over time not correspond to the data and other assumptions within the GSP that should be documented. In addition, the GSP shall be updated every five years (Update). The Update must be submitted by the end of January 2025.

As part of this discussion, staff is seeking direction from Council with regard to level of participation into the cost of the Five-Year Update.

It is anticipated the original consultant team that prepared the GSP will also prepare the update.

The update will revisit all assumptions, modeling and conclusions of the original GSP. It will also address other items that have been required by the DWR as a result of the approval of the Revised GSP. It is anticipated this Update will commence in the very near future. At present, it appears, given the short time frame between now and the end of January, the County will issue a Notice to Proceed to the consultant even though funding between the four GSPs that are a party to the Update have not yet concluded how the costs will be shared.

As alluded to above, it is anticipated funding for the Update will be provided by the four GSAs that are a party to the GSP. The proposed consultant fee is $438,911. While consultant fees for the original GSP were largely paid by grants, it is not currently anticipated grant funds will be available. As such, the fees would need to be split amongst the four GSAs. Possible funding allocation splits include:
 Split equally or $109,727 per GSA
 Split by GSA acreage
o City – 3.1% or $13,621 based on 10,100 acres
o County – 54.6% or $239,786 based on 177,800 acres
o MID – 41.1% or $180,514 based on 133,850 acres
o MWD - $1.1% or $4,990 based on 3,700 acres
Depending on perspective, arguments for one or the other can be made. As an example, if the City was required to complete its own initial GSP, annual reports and five-year updates, it might not be practical to assume the costs would be three (3) percent of the cost expended as a joint GSP. Unfortunately, it is not possible to determine what the actual cost might be after the fact without significant effort.

Recent MID Correspondence Regarding Five-Year Update
On March 6, 2024, MID sent a letter to all Madera GSAs (Attachment 5); not just those that are a party to the GSP prepared by City, County, MID, and MWD. The key points of this letter included:
 Recommendation that they participate in the Update on a technical basis only – They would provide any necessary data and information that is required and requested. But, they foresee the remaining GSAs making decisions largely independent of MID.  They point out other GSAs have hard decisions moving forward as many are now multiple years behind schedule on projects with negative effects on the aquifer intensifying.
 MID indicates it “is agreeable to approve the Revised GSP to ease process amongst GSAs and State of California”.
 MID has conveyed its willingness to drop its lawsuit against Madera County. MID has conveyed this to Madera County but has yet to receive a response. For context see Attachment 5.

Part of the reasoning behind the key points of the letter is that MID has completed most of the projects and programs outlined in the GSP. Additionally, MID is hopeful that their absence from formal participation in the update will remove any roadblocks for other GSAs.

Because MIDs letter left an impression that it might not participate in the cost of the Five-Year Update, MID was contacted to determine their intent. In an email sent to the other GSAs, MID indicated they are proposing that costs be shared based on the effort required for each GSA. The basis for this is that “there will be significantly more time and effort required on behalf of some GSAs based on their progress (or non-progress) than others, who have completed their projects and are well ahead of the implementation schedule”
Based on the discussion above, staff is of the opinion that a split on the basis of acreage or the method proposed by MID that accounts for effort associated with each individual GSA be utilized.

Domestic Well Mitigation
As part of SGMA, GSAs are, to staff’s understanding to participate in mitigating impacts to small parcel, residential wells. While details of what would be mitigated in terms of costs, the possible ways to mitigate include allocation to GSAs on the basis of equal division of costs, allocation based on acreage or perhaps a third option wherein the City excludes itself from participation based on its pending completion of projects identified in the GSP. When those projects are complete, the City, in theory, will not play a part in the failure of wells. Additionally, if the City is, in theory, at a point where its water usage is considered sustainable (not using more water than it recharges), it is still in a position wherein agricultural well users may be placing City wells at risk if the water table continues to drop.

It is staff’s minimum recommendation that the City only participate in domestic well mitigation in one of the following possible ways:
 Split by percentage of acreage in the Subbasin
 Split by the percentage of impact on the sustainability of the aquifer. The last credible value staff has on this was somewhere around 3 percent based on previous year’s impacts. It is anticipated this will, following completion of City projects go to zero unless the Five-Year Update illustrates that impacts by GSA need to be redetermined.

FINANCIAL IMPACT:

It is not anticipated there will be an impact to the City’s General Fund as directly related to this report. It is possible that there will be impacts associated due to the cost of the Five-Year Update and domestic well mitigation once those costs have been determined and if they are not found to be applicable to the Water Fund.

ALTERNATIVES:

This report currently seeks input based on various alternatives included within the report itself.

Staff is grateful for any other alternatives Council may present.

ATTACHMENTS:

1. DWR Request to MID for Clarification

2. MID Press Release

3. MID Response to DWR

4. DWR Determination

5. MID Letter to All Madera GSAs
Attachment 1
Request to MID for Clarification

CALIFORNIA DEPARTMENT OF WATER RESOURCES

SUSTAINABLE GROUNDWATER

MANAGEMENT OFFICE
715 P Street | Sacramento, CA 95814 | P.O. Box 942836 | Sacramento, CA 94236-0001 April 6, 2023
Thomas Greci
General Manager
Madera Irrigation District Groundwater Sustainability Agency 12152 Road 28 ¼
Madera, CA 93637
[email protected]
Dear Mr. Greci,
I am requesting clarification on behalf of the Department of Water Resources (Department), Sustainable Groundwater Management Office (SGMO) regarding the recently submitted Revised Madera Subbasin Joint Groundwater Sustainability Plan (GSP) as one of four GSPs for the Madera Subbasin (Basin 5-022.06, hereafter “basin”), which was uploaded to the Sustainable Groundwater Management Act (SGMA) Portal on March 21, 2023. As with the original Madera Subbasin Joint GSP, the revised GSP states that it was prepared by four groundwater sustainability agencies (GSAs): Madera Water District GSA, City of Madera GSA, Madera County GSA, and Madera Irrigation District GSA. However, information uploaded to the SGMA Portal indicates only three GSAs have adopted this plan—the Madera Irrigation District GSA (MID GSA) has apparently not adopted the plan.

SGMO’s records indicate that MID GSA adopted the original Joint GSP, submitted to the Department January 31, 2020. On September 22, 2022, the Department determined that the GSPs for the basin were incomplete, including the original Madera Subbasin Joint GSP. SGMO understands the submission of the Revised Joint GSP was intended to be an effort to address the deficiencies identified in the Department’s incomplete staff report. The apparent lack of adoption of the Revised Madera Subbasin Joint GSP by MID GSA is not consistent with how the initial GSP was treated and raises significant questions. The resubmitted GSP without MID GSA’s adoption adds ambiguity to the January 22, 2020, Madera Subbasin Coordination Agreement and the March 2023 amendment to the Madera Subbasin Coordination Agreement.

The Madera Subbasin Coordination Agreement refers to GSPs for each party and specifically references in several places GSPs adopted by each party. The March 21, 2023, First Amendment to The Madera Subbasin Coordination Agreement does not appear to clarify or explain the circumstance of MID GSA not adopting the revised Madera Subbasin Joint GSP.

Furthermore, on March 28, 2023, the MID website contained a news update stating the MID Board was unable to take action on (e.g., adopt) the Revised Madera Subbasin Joint GSP. The release explained the board’s refusal to adopt as grounded in concerns about GSP implementation and GSA cooperation in the basin. It reported that the “MID Board of Directors strongly felt the Revised GSP did not address these concerns,” and that it “failed to address … very impactful changes and factors.”
STATE OF CALIFORNIA | GAVIN NEWSOM, GOVERNOR | CALIFORNIA NATURAL RESOURCES AGENCY DocuSign Envelope ID: 9488661D-E7A8-4C56-B861-97A36D75395A Thomas Greci

Page 2 ends

April 6, 2023
The Revised Madera Subbasin Joint GSP states it covers almost 90% of the basin, and MID GSA’s jurisdiction covers almost 50% of the basin. SGMA grants certain powers to GSAs to implement SGMA, but only if a GSA adopts and submits a plan to the Department. The failure of MID GSA to adopt the Revised Joint GSP raises significant questions regarding basin management under SGMA, especially in the area covered by MID GSA. Accordingly, SGMO requests written responses to the following questions:
1) Has MID GSA adopted the Revised Madera Subbasin Joint GSP, or intend to adopt this GSP by May 5, 2023? If yes, provide the date of the action and a copy of the resolution, or the date in which MID GSA anticipates adoption to be considered by your board. 2) If MID GSA does not intend to adopt the Revised Madera Subbasin Joint GSP, are you committed to implementing the Revised Madera Subbasin Joint GSP in its entirety as submitted to the Department? If not, what GSP does the MID GSA intend to implement? 3) Please explain who and how lands within the jurisdiction of the MID GSA will be managed under SGMA and specifically identify and discuss the relevance of key documents describing, establishing, and confirming this structure (i.e., plans, cooperation agreements, MOUs, etc.)?
Please provide your written responses by April 21, 2023 (14 days) to me at [email protected]. SGMO will review the information you provide and determine if further clarification or actions are necessary prior to continuing our review of the revised submittal for the basin and issuance of a determination.

Sincerely,
Paul Gosselin
Deputy Director
Sustainable Groundwater Management
cc: John Davids, Madera Subbasin Point of Contact, [email protected] Natalie Stork, State Water Resources Control Board, [email protected] DocuSign Envelope ID: 9488661D-E7A8-4C56-B861-97A36D75395A Attachment 2
MID Press Release
3/27/24, 11:29 AM MID Board Unable to Take Action Due to Madera County's Failure to Implement the GSP - Madera Irrigation District https://www.madera-id.org/mid-board-unable-to-take-action-due-to-madera-countys-failure-to-implement-the-gsp/ 1/5 NEWS
Home (https://www.madera-id.org/) / News (https://www.madera-id.org/category/news/) / MID Board Unable to Take Action Due to Madera County’s Failure to Implement the GSP March 28, 2023
MID Board Unable to Take Action Due to Madera
County’s Failure to Implement the GSP
After extensive consideration and deliberation, the Madera Irrigation District (MID or District) Board of Directors at its March 21, 2023 Board Meeting declined to take an action on the Revised Joint Groundwater Sustainability Plan (GSP or Plan). No motion was made for approval of the Revised GSP and no vote was taken.

Madera Irrigation District has long voiced concerns over the Joint Groundwater Sustainability Plan that was approved in 2020, and, in particular, the implementation of (and failure to implement) that Plan by the Madera County Groundwater Sustainability Agency. While MID and its landowners have been investing millions of dollars in tangible projects that both reduce demand and enhance recharge over recent years, some other GSAs have not adhered to their commitments in the Plan and the implementation schedule. These delays and actions or inactions by some other GSAs, primarily Madera County GSA— the largest GSA, with the largest groundwater deficit—have significant realworld effects on the Madera Subbasin’s groundwater aquifer including the  (https://www.facebook.com/MaderaIrrigationDistrict)
3/27/24, 11:29 AM MID Board Unable to Take Action Due to Madera County's Failure to Implement the GSP - Madera Irrigation District https://www.madera-id.org/mid-board-unable-to-take-action-due-to-madera-countys-failure-to-implement-the-gsp/ 2/5 lowering of groundwater tables, water quality impacts, and domestic well concerns. The MID Board of Directors strongly felt the Revised GSP did not address these concerns.

MID has expressed these views in numerous forums and various platforms over the years, with unfortunately no resolution to date. From dialogue with the GSAs to formally filing a lawsuit against Madera County in Superior Court regarding the implementation of the 2020 Joint Groundwater Sustainability Plan, MID continues to strive to ensure implementation of projects and programs occur as agreed to in the GSP and on a schedule that will actually result in sustainable groundwater for Madera.

On March 21, 2023, MID’s Board of Directors did vote to approve the Coordination Agreement for the Madera Subbasin, as MID fully supports coordination efforts that will lead to groundwater sustainability. MID also approved the Domestic Well Memorandum of Understanding, a document that outlines an agreement to develop and fund a domestic well program for the Madera Subbasin. To date, New Stone Water District (NSWD), Gravelly Ford Water District (GFWD), and Root Creek Water District (RCWD) have not approved the Domestic Well Memorandum of Understanding. “Madera Irrigation District is committed to its landowners, the Madera Subbasin, and sustainability. MID is also committed to meeting its obligations under the GSP and is disappointed in the lack of meaningful action by other GSAs, and specifically the Madera County GSA. Unfortunately, the Revised GSP failed to address these very impactful changes and factors” stated Thomas Greci, General Manager. “As demonstrated through its actions, MID is committed to reducing the adverse consequences of groundwater overdraft. However, MID 3/27/24, 11:29 AM MID Board Unable to Take Action Due to Madera County's Failure to Implement the GSP - Madera Irrigation District https://www.madera-id.org/mid-board-unable-to-take-action-due-to-madera-countys-failure-to-implement-the-gsp/ 3/5 cannot approve a plan that does not provide the accountability necessary to ensure other GSAs, including the Madera County GSA, likewise meet their obligations.”
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About Us
History of MID (https://www.madera-id.org/about-us/history-of-mid/) Attachment 3
MID response to DWR
Dear Mr. Gosselin,
Thank you for your letter dated April 6, 2023, which concerns Madera Irrigation District Groundwater Sustainability Agency’s (MID GSA) decision to take no action on the Revised Madera Subbasin Joint Groundwater Sustainability Plan (Revised Joint GSP). The letter seeks clarification as to why the MID GSA declined to take action on the Revised Joint GSP and seeks further information about the MID GSA’s plan for groundwater management going forward. MID GSA strongly supports SGMA’s objective of achieving sustainability and welcomes the opportunity to provide further information to the Department of Water Resources (DWR).

Although the Revised Joint GSP addressed issues DWR identified in its September 22, 2022 letter to the GSAS within the Madera Subbasin, MID GSA has determined the Revised Joint GSP is inadequate.

Specifically, the Revised Joint GSP failed to address the MID GSA’s concern that it provided no accountability for the implementation of the Revised Joint GSP by the other GSAs, which is of particular concem for the Madera County GSA that has by far the largest groundwater deficit and includes the lands most responsible for historic overdraft conditions in the Subbasin. As MID stated in MID’s March 28, 2023, Press Release:

Madera Irrigation District has long voiced concerns over the Joint Groundwater Sustainability Plan that was approved in 2020, and, in particular, the implementation of (and failure t0 implement) that Plan by the Madera County Groundwater Sustainability Agency. While MID and its landowners have been investing millions ofdollars in tangible projects that both reduce demand and enhance recharge over recent years, some other GSAS have not adhered to their commitments in the Plan and the implementation schedule. These delays and actions 0r inactions by some other GSAS, primarily Madera County GSA the largest GSA, with the largest groundwater deficit— have significant real-world e/fects on the Madera Subbasin ’s groundwater aquifer including the PhonB (559) B73-35l4 Buard of Direcmrs
Divisinnl www‘madera-idIJrg David Lnquaci General Manager Divisiun2 Thnmas Greni ESTV w‘ 1920 Tim DaSilva Assistant Divisinn3 General Manager Brian Davis Dina Cadenazzi Nnlan IRRIGATIDN DISTRIET Dwmmn4 Legal Counsel l2l52 Road 28 l/4 James Erickson John P. Kinsey Madera, CA 93637 Division5 EarlJanzen
April 21, 2023
Via US Mail and Email
Paul Gosselin
D€partment of Water Resources P.O. Box 942836 Sacramento, CA 94236-0001 [email protected]
lowering ofgroundwater tables, water quality impacts, and domestic well wncerns. The MID Board ofDirectors stronglyfelt the Revised GSP did not address these concerns.

MID has expressed these views in numerous forums and various platforms over the years, with unfortunately n0 resolution to date. From dialogue with the GSAs to formally filing a lawsuit against Madera County in Superior Court regarding the implementation of the 2020 Joint Groundwater Sustainability Plan, MID continues to strive to ensure implementation ofprojects and programs occur as agreed to in the GSP and on a schedule that will actually result in sustainable groundwaterfor Madera.

The MID GSA also sent the attached letter to all Groundwater Sustainability Agencies (GSAS) in the Madera Subbasin on January 5, 2023, outlining concerns preemptively in an attempt to reach resolution, unfortunately no resolution occurred prior to March 2 1 , 2023, nor since.

Below are MID GSA’s responses to your questions:
1) Has MID GSA adopted the Revised Madera Subbasin Joint GSP, or intend to adopt this GSP by May 5, 2023? Ifyes, provide the date ofthe action and a copy ofthe resolution, or the date in which MID GSA anticipates adoption to be considered by your board.

No, the MID GSA has not and does not intend to adopt the Revised Joint GSP prior to May 5, 2023 as substantial, meaningful edits related to implementation, or lack thereof, have not been made to the document.
2) IfMID GSA does not intend to adopt the Revised Madera Subbasin Joint GSP, are you committed t0 implementing the Revised Madera Subbasin Joint GSP in its entirety as submitted to the Department? Ifnot, what GSP does the MID GSA intend to implement?
Yes, MID GSA is fully committed to implementing the projects and programs outlined in the Revised Joint GSP and strongly implores other GSAs in the Madera Subbasin to share that commitment. MID GSA has already implemented the vast majority of its projects and programs described in the GSP and is significantly ahead of schedule. MID GSA also notes that While the Madera County GSA has technically adopted the Revised Madera Subbasin Joint GSP, it has conversely demonstrated a complete unwillingness to implement the terms of the Revised Joint GSP that it submitted to DWR.

MID GSA strongly believes that action and accountability are far more important than words. 3) Please explain who and how lands within the jurisdiction ofthe MID GSA will be managed under SGMA and specifically identijy and discuss the relevance ofkey documents describing, establishing, and confirming this structure (i.e., plans, cooperation agreements, MOUs, etc)? MID GSA will continue to manage in accordance with the Revised Joint GSP for the Madera Subbasin. The lack of action on the Revised Joint GSP was not due to any intention on the part of MID GSA to avoid its implementation of the Revised Joint GSP; to the contrary, MID GSA’s decision was due to (i) its significant concern that other GSAs are actively refusing to take action in accordance with the Revised Joint GSP and (ii) the Revised Joint GSP’s lack of accountability for GSAs that seek to avoid their obligations thereunder rendered the plan inadequate.

Also, please note the MID GSA has approved the Coordination Agreement and a Domestic Well Memorandum of Understanding, as MID fully supports coordination efforts that will lead to actual groundwater sustainability. In contrast, New Stone Water District (NSWD), Gravelly Ford Water District (GFWD), and Root Creek Water District (RCWD) have not approved the Domestic Well Memorandum of Understanding.

The MID GSA firmly believes that its goals for the Revised Joint GSP are completely in-line with the State of Califomia’s goals, including both the Department of Water Resources and the State Water Resource Control Board. The MID GSA’s entire objective is to achieve and maintain sustainability for the aquifer we share and rely on. To achieve sustainability all GSAs in the Subbasin must follow the plans which have been agreed to. Unfortunately, to date, that has not occurred. Delays in implementation and actions that allow additional overdrafting of groundwater by other GSAs have created conditions in the Subbasin that warrant modifications to the plan and management objectives.

In short, the MID GSA strongly believes that the State’s objectives related to the Sustainable Groundwater Management Act (SGMA) would have been thwarted had the MID GSA elected to approve the submission of a revised plan that (i) did not reflect reality, (ii) were fundamentally inaccurate, and (iii) lacked any mechanism for accountability on the part of its signatory GSAs. Thus, while the MID GSA will continue to fully implement its own obligations under the Revised Joint GSP, the MID GSA cannot adopt the Revised Joint GSP without substantial revision.

W
Thomas Greci
General Manager
cc: John Davids, Davids Engineering
Natalie Stork, SWRCB
Attachment 1
January 5, 2023
Via US Mail and Email
Stephanie Anagnoson
Madera County
200 W. 4th Street, Suite 3100
Madera, CA 93637
Dear Madera Subbasin Groundwater Sustainability Agencies, Madera Irrigation District Groundwater Sustainability Agency (MID GSA) understands that you and your consultants are in the process of preparing updates to your Groundwater Sustainability Plan (GSP) to correct deficiencies identifies by the California Department of Water Resources (DWR). We understand those GSPs will be considered for approval by each of the GSAs in late February/March 2023. As the GSAs within the subbasin are completing these updates, the MID GSA feels it is important to set forth its concerns and expectations with respect to the updated GSPs.

First, MID GSA has significant concerns regarding Madera County’s “allocation approach.” In addition, recent communications from the County related to its “allocation approach” (including the attached) reveal the allocations have been significantly over-assigned. MID GSA has concerns regarding Madera County’s reliance on “transitional water” in the initial amount of 90,000 acre-feet/year, since the extraction of “transitional water” is simply further overdraft. Since the approval of the original GSP, Madera County has adopted resolutions increasing the amount of “transitional water” (overdraft) to 113,000 acrefeet/year. MID does not support any such increase. But even if it did, the Joint GSP and associated models would need to be updated to reflect the change from 90,000 acre feet of “transitional water” (overdraft) to 113,000 acre feet of “transitional water” (overdraft). As a result, the Joint GSP is currently inaccurate and the “update” must correct this massive, impactful flaw.

In addition, on December 6, 2022, a preliminary injunction issued on Madera County’s Prop 218 GSP fee, Madera County’s main funding stream for all GSP projects, including domestic well mitigation. MID has been very concerned about Madera County’s timing, progress, and feasibility of their “projects” outlined in the Joint GSP to date and has communicated this concern numerous times over the years. The fact that there is now a lack of funding further exacerbates that concern tremendously. To our knowledge, the Madera County GSA “projects” in the Joint GSP have not been revised to account for this delay in timing, funding, and potential recharge, nor has the associated model. Again, the Joint GSP should be updated to address this issue.

The MID GSA does not believe it would be appropriate for the GSAs within the Madera Subbasin to support and submit “updated” GSPs to DWR that address only certain elements, while the MID GSA’s basic concerns are left unaddressed. This is particularly true given that Madera County GSA is the largest GSA in the Madera Subbasin, and these concerns go to the heart of whether the Subbasin can achieve sustainability, avoid adverse impacts, and ultimately be successful.

The MID GSA would be happy to engage in a dialog regarding these issues in the near-term so these issues can be addressed in advance of the March 2023 deadline. Should you have any questions, please do not hesitate to contact me.

Sincerely,
Thomas Greci
General Manager
cc: John Davids
Topic: Second reduction in ETAW
Release Date: 11/28/2022
Contact: [email protected]
Summary
IrriWatch is making a second reduction to evapotranspiration of applied water (ETAW) measurements from January 1 through September 30 of 2022 (technical details explained below). Unfortunately, the initial “very hot pixel” reduction performed in late September 2022 to ETAW didn’t fully reduce ETAW to appropriate levels for some fields. This second reduction will have the largest impact on parcels with low or no vegetation (e.g., bare soil and fallowed fields). Importantly, ETAW will be automatically set to zero for fallowed fields (i.e., fields not irrigated for the entire year). On November 24, 2022, the second reduction will be seen as an additional sudden decrease in the graph of accumulated ETAW (see example graph below). Pixel-level values will also be adjusted accordingly.

Technical Details
The Surface Energy Balance Algorithm for Land (SEBAL) scales actual ET between the hot and cold pixels of thermal images collected by satellites. Hot pixels have zero ET and cold pixels have an ET rate according to atmospheric demand. The exceptionally hot and dry conditions during the 2022 summer resulted in larger than normal temperature ranges for hot pixels. For the first time, extraordinarily hot pixels (“extra-hot”) were detected. By scaling ET for extra-hot pixels to zero, less hot pixels received some residual ET, even though in actuality these pixels didn’t have any ET. These hot pixels are generally surfaces with little or no vegetation such as bare soil, fallowed land, roads, urban areas, etc. Because these hot pixels had little vegetation, Transpiration (T) is zero, so all ET is considered soil Evaporation (E).

Consequently, evaporation was overestimated for these hot pixels with low vegetation cover. These over-estimates of E led to an over-estimation of ET and ETAW and were the basis for the first reduction.

Additionally, due to a configuration error in the vegetation cover conversion, fallowed land (i.e., fields not irrigated in 2022) had a minimum vegetation cover of roughly 10 %. Field inspections associated with the verification project revealed these fields to be completely barren despite the reporting of vegetation by IrriWatch. This led to the discovery and correction of the configuration error. However, this configuration error, together with the “extra-hot” pixel issue let to an amount of transpiration (T) attributed to fallowed fields. Initially, fields were designated as fallowed based on the 2018 Department of Water Resources (DWR) land use data. Subsequently, IrriWatch has performed an analysis of satellite imagery from the 2022 irrigation season. Madera County staff have performed field inspections of fields determined to be fallowed from DWR and remote sensing. From these analyses, a final list of fallowed fields has been developed. For these final fallowed fields, ETAW will be set to zero for 2022.

Q & A
Q: How will the correction appear within the IrriWatch portal? A: IrriWatch is a real time service, and it is impossible to stop the system and run it over again. Instead, a second reduction to ETAW will be applied.

Q: What fields or pixels will be most impacted by this reduction? A: Hot fields (i.e., pixels with little or no vegetation) and fields identified as fallowed (i.e., not irrigated for all of 2022) will be most impacted.

Q: Will the reduction apply to the entire year?
A: The reduction applies to ETAW data from January 1 to August 31 of 2022 and was applied on November 24, 2022. The real time IrriWatch data does not have the extra-hot pixel effect after September 1.

Q: What will happen to ETAW if I have a field that I didn’t irrigation in 2022? A: ETAW will be set to zero for all fields that have been determined to be fallowed (i.e., not irrigated for all of 2022) via a combination of DWR data, remote sensing from 2022, and field inspections.

Attachment 4
DWR Determination

CALIFORNIA DEPARTMENT OF WATER RESOURCES

SUSTAINABLE GROUNDWATER

MANAGEMENT OFFICE
715 P Street, 8th Floor | Sacramento, CA 95814 | P.O. Box 942836 | Sacramento, CA 94236-0001 STATE OF CALIFORNIA | GAVIN NEWSOM, GOVERNOR | CALIFORNIA NATURAL RESOURCES AGENCY December 21, 2023
John Davids
Madera Point of Contact
1772 Picasso Avenue, Suite A
Davis, CA 95618
[email protected]
RE: Approved Determination of the Revised Groundwater Sustainability Plans Submitted for the San Joaquin Valley – Madera Subbasin
Dear John Davids,
The Department of Water Resources (Department) has evaluated the four groundwater sustainability plans (GSPs) submitted for the San Joaquin Valley – Madera Subbasin (Subbasin), as well as the materials considered to be part of the required coordination agreement. Collectively, the four GSPs and the coordination agreement are referred to as the Plan for the Subbasin. The Department has evaluated the resubmitted Plan for the Madera Subbasin in response to the Department’s incomplete determination on September 22, 2022, and has determined the Plan is approved. The approval is based on recommendations from the Staff Report, included as an exhibit to the attached Statement of Findings, which describes that the Plan has taken sufficient action to correct deficiencies identified by the Department and satisfies the objectives of the Sustainable Groundwater Management Act (SGMA) and substantially complies with the GSP Regulations. The Staff Report also proposes recommended corrective actions that the Department believes will enhance the GSP and facilitate future evaluation by the Department. The Department strongly encourages the recommended corrective actions be given due consideration and suggests incorporating all resulting changes to the GSP in future updates.

Recognizing SGMA sets a long-term horizon for groundwater sustainability agencies (GSAs) to achieve their basin sustainability goals, monitoring progress is fundamental for successful implementation. GSAs are required to evaluate their GSPs at least every five years and whenever the Plan is amended, and to provide a written assessment to the Department. Accordingly, the Department will evaluate approved GSPs and issue an assessment at least every five years. The Department will initiate the first periodic review of the Plan no later than January 31, 2025.

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STATE OF CALIFORNIA | GAVIN NEWSOM, GOVERNOR | CALIFORNIA NATURAL RESOURCES AGENCY Please contact Sustainable Groundwater Management staff by emailing [email protected] if you have any questions related to the Department’s assessment or implementation of your GSP.

Thank You,
________________________________
Paul Gosselin
Deputy Director
Sustainable Groundwater Management
Attachment:

1. Statement of Findings Regarding the Determination of Approval of the San Joaquin Valley – Madera Subbasin Groundwater Sustainability Plans (December 21, 2023)
DocuSign Envelope ID: E0C6A761-F236-458E-AE81-852601AC9286

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STATE OF CALIFORNIA

DEPARTMENT OF WATER RESOURCES

STATEMENT OF FINDINGS REGARDING THE

APPROVAL OF THE
SAN JOAQUIN VALLEY – MADERA SUBBASIN

GROUNDWATER SUSTAINABILITY PLAN
The Department of Water Resources (Department) is required to evaluate whether a submitted groundwater sustainability plan (GSP or Plan) conforms to specific requirements of the Sustainable Groundwater Management Act (SGMA or Act), is likely to achieve the sustainability goal for the basin covered by the Plan, and whether the Plan adversely affects the ability of an adjacent basin to implement its GSP or impedes achievement of sustainability goals in an adjacent basin. (Water Code § 10733.) The Department is directed to issue an assessment of the Plan within two years of its submission. (Water Code § 10733.4.) If a Plan is determined to be Incomplete, the Department identifies deficiencies that preclude approval of the Plan and identifies corrective actions required to make the Plan compliant with SGMA and the GSP Regulations. The groundwater sustainability agency (GSA) has up to 180 days from the date the Department issues its assessment to make the necessary corrections and submit a revised Plan. (23 CCR § 355.2(e)(2)). This Statement of Findings explains the Department’s decision regarding the revised Plan submitted by the City of Madera GSA, Madera County GSA, Madera Irrigation District GSA, Madera Water District GSA, Gravelly Ford Water District GSA, New Stone Water District GSA, and Root Creek Water District GSA (GSAs or Agencies) for the San Joaquin Valley – Madera Subbasin (No. 5- 022.06) (Subbasin) on March 21, 2023 (2023 Plan).

Department management has discussed the 2023 Plan with staff and has reviewed the Department Staff Report, entitled Sustainable Groundwater Management Program Groundwater Sustainability Plan Assessment Staff Report, attached as Exhibit A, recommending approval of the 2023 Plan. Department management is satisfied that staff have conducted a thorough evaluation and assessment of the 2023 Plan and concurs with staff’s recommendation and all the recommended corrective actions. The Department therefore APPROVES the 2023 Plan and makes the following findings:

A. The initial Plan for the basin submitted by the GSAs for the Department’s evaluation on January 31, 2020 (2020 GSP or 2020 Plan) was determined by Department staff to satisfy the preliminary requirements for Plan review as outlined in § 355.4(a) of the GSP Regulations (23 CCR § 350 et seq.), and Department Staff therefore evaluated the initial Plan.

B. On September 22, 2022, the Department issued a Staff Report and Findings determining the initial 2020 GSP submitted by the Agencies for the basin to be incomplete because the 2020 Plan did not satisfy the requirements of DocuSign Envelope ID: F6DF4CB7-9D58-44C0-A24A-70D06062CB75 Statement of Findings December 21, 2023
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SGMA, nor did it substantially comply with the GSP Regulations. At that time, the Department provided corrective actions in the Staff Report that were intended to address the deficiencies that precluded approval. Consistent with the GSP Regulations, the Department provided the Agencies with up to 180 days to address the deficiencies detailed in the Staff Report. On March 21, 2023, within the 180 days provided to remedy the deficiencies identified in the Staff Report related to the Department’s initial incomplete determination, the Agencies resubmitted a revised Plan to the Department for evaluation.

When evaluating a revised Plan that was initially determined to be incomplete, the Department reviews the materials (e.g., revised or amended Plan) that were submitted within the 180-day deadline and does not review or rely on materials that were submitted to the Department by the GSAs after the resubmission deadline. Part of the Department’s review focuses on how the Agencies have addressed the previously identified deficiencies that precluded approval of the initially submitted Plan. The Department shall find a Plan previously determined to be incomplete to be inadequate if, after consultation with the State Water Resources Control Board, the Agencies have not taken sufficient actions to correct the deficiencies previously identified by the Department. (23 CCR § 355.2(e)(3)(C).) If the Department determines the Agencies have sufficiently addressed those deficiencies, the Department may evaluate other components of the Plan, particularly to assess whether and, if so, how revisions to address deficiencies may have affected other components of a Plan or its likelihood of achieving sustainable groundwater management.

C. The Department’s initial Staff Report identified the deficiencies that precluded approval of the initially submitted 2020 Plan. After staff’s thorough evaluation of the revised 2023 Plan, the Department makes the following findings regarding the sufficiency of the actions taken by the Agencies to address those deficiencies:

1. Deficiency 1: The corrective action advised the Agencies to modify several aspects of their respective GSPs to substantially comply with the GSP Regulations in a coordinated manner. The Department found that the initial GSPs did not sufficiently coordinate on data and methodologies, including coordination of the sustainability goal, water budget and sustainable yield, and undesirable results as required by SGMA and the GSP Regulations. The Department also determined that the 2020 Plan’s definition of an undesirable result for the chronic lowering of groundwater levels was not consistent with the requirements of SGMA.

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The 2023 Staff Report indicates that the Agencies have taken sufficient actions to correct this deficiency, and it should no longer materially affect the ability of the Agencies to achieve sustainability and the ability of the Department to evaluate the likelihood of the 2023 Plan to achieve sustainability.

2. Deficiency 2: The corrective action advised the Agencies to address several aspects of the 2020 Plan’s disclosure, discussion, and analyses of groundwater level sustainable management criteria and potential impacts to groundwater users and uses. The initial 2020 Plan did not establish undesirable results and minimum thresholds for chronic lowering of groundwater levels in a manner substantially compliant with the GSP Regulations. Additionally, the Department found that the Plan did not present sufficient analysis of the effects of minimum thresholds on beneficial uses and users of groundwater in the Subbasin.

The 2023 Staff Report indicates that the Agencies have taken sufficient actions to correct this deficiency, and it should no longer materially affect the ability of the Agencies to achieve sustainability and the ability of the Department to evaluate the likelihood of the 2023 Plan to achieve sustainability.

3. Deficiency 3: The corrective action advised the Agencies to address several aspects of the 2020 Plan’s disclosure, discussion, and analyses of land subsidence sustainable management criteria and potential impacts to groundwater users and uses. The initial Plan did not establish sustainable management criteria for subsidence. The Department determined that the GSAs did not sufficiently demonstrate that undesirable results related to land subsidence are not present and are not likely to occur in the Subbasin.

The 2023 Staff Report indicates that the Agencies have taken sufficient actions to correct this deficiency, and it should no longer materially affect the ability of the Agencies to achieve sustainability and the ability of the Department to evaluate the likelihood of the 2023 Plan to achieve sustainability.

4. Deficiency 4: The corrective action advised the Agencies to address several aspects of the 2020 Plan’s disclosure, discussion, and analyses of interconnected surface water sustainable management criteria and potential impacts to groundwater users and uses. The initial 2020 Plan did not establish sustainable management criteria for interconnected surface water. The Department determined that the GSAs do not sufficiently demonstrate that interconnected surface DocuSign Envelope ID: F6DF4CB7-9D58-44C0-A24A-70D06062CB75 Statement of Findings December 21, 2023
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water or undesirable results related to depletions of interconnected surface water are not present and are not likely to occur in the Subbasin.

The 2023 Staff Report indicates that the Agencies have taken sufficient actions to correct this deficiency, and it should no longer materially affect the ability of the Agencies to achieve sustainability and the ability of the Department to evaluate the likelihood of the 2023 Plan to achieve sustainability.

D. The 2023 Plan satisfies the required conditions as outlined in § 355.4(a) of the GSP Regulations (23 CCR § 350 et seq.):

1. The 2020 Plan was submitted within the statutory deadline of January 31, 2022 (Water Code § 10720.7(a); 23 CCR § 355.4(a)(1)), and the 2023 Plan was submitted within 180 days of the Department’s Incomplete determination (23 CCR § 355.2(e)(2)).

2. The 2023 Plan is complete, meaning it generally appeared to include the information required by the Act and the GSP Regulations sufficient to warrant a thorough evaluation and issuance of an assessment by the Department. (23 CCR § 355.4(a)(2).)

3. The 2023 Plan, either on its own or in coordination with other Plans, covers the entire Subbasin. (23 CCR § 355.4(a)(3).)
E. The general standards the Department applied in its evaluation and assessment of the Plan are: (1) “conformance” with the specified statutory requirements, (2) “substantial compliance” with the GSP Regulations, (3) whether the Plan is likely to achieve the sustainability goal for the Subbasin within 20 years of the implementation of the Plan, and (4) whether the Plan adversely affects the ability of an adjacent basin to implement its GSP or impedes achievement of sustainability goals in an adjacent basin. (Water Code § 10733.) Application of these standards requires exercise of the Department’s expertise, judgment, and discretion when making its determination of whether a Plan should be deemed “approved,” “incomplete,” or “inadequate.”
The statutes and GSP Regulations require Plans to include and address a multitude and wide range of informational and technical components. The Department has observed a diverse array of approaches to addressing these technical and informational components being used by GSAs in different basins throughout the state. The Department does not apply a set formula or criterion that would require a particular outcome based on how a Plan addresses any one of SGMA’s numerous informational and technical components. The Department finds that affording flexibility and discretion to DocuSign Envelope ID: F6DF4CB7-9D58-44C0-A24A-70D06062CB75 Statement of Findings December 21, 2023
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local GSAs is consistent with the standards identified above; the state policy that sustainable groundwater management is best achieved locally through the development, implementation, and updating of local plans and programs (Water Code § 113); and the Legislature’s express intent under SGMA that groundwater basins be managed through the actions of local governmental agencies to the greatest extent feasible, while minimizing state intervention to only when necessary to ensure that local agencies manage groundwater in a sustainable manner. (Water Code § 10720.1(h)). The Department’s final determination of a Plan is made based on the entirety of the Plan’s contents on a case-by-case basis, considering and weighing factors relevant to the particular Plan and Subbasin under review.

F. In making these findings and Plan determination, the Department also recognized that: (1) it maintains continuing oversight and jurisdiction to ensure the Plan is adequately implemented; (2) the Legislature intended SGMA to be implemented over many years; (3) SGMA provides Plans with 20 years of implementation to achieve the sustainability goal in a Subbasin (with the possibility that the Department may grant GSAs an additional five years upon request if the GSA has made satisfactory progress toward sustainability); and, (4) local agencies acting as GSAs are authorized, but not required, to address undesirable results that occurred prior to enactment of SGMA. (Water Code §§ 10721(r); 10727.2(b); 10733(a); 10733.8.) G. The 2023 Plan conforms with Water Code §§ 10727.2 and 10727.4, substantially complies with 23 CCR § 355.4, and appears likely to achieve the sustainability goal for the Subbasin. It does not appear at this time that the 2023 Plan will adversely affect the ability of adjacent basins to implement their GSPs or impede achievement of sustainability goals.

1. The sustainable management criteria and the 2023 Plan’s goal to implement a package of projects and management actions that will, by 2040, balance long-term groundwater system inflows and outflows based on a 50-year period representative of average historical hydrologic conditions are sufficiently justified and explained. The 2023 Plan relies on credible information and science to quantify the groundwater conditions that the Plan seeks to avoid and provides an objective way to determine whether the Subbasin is being managed sustainably in accordance with SGMA. (23 CCR § 355.4(b)(1).)

2. The 2023 Plan demonstrates an understanding of where data gaps exist and has identified areas for improvement of its Plan, including addressing data gaps related to land subsidence and interconnected surface water, refining water budgets, incorporating new information DocuSign Envelope ID: F6DF4CB7-9D58-44C0-A24A-70D06062CB75 Statement of Findings December 21, 2023
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into the numerical model, and expanding monitoring networks. (23 CCR § 355.4(b)(2).)

3. The projects and management actions proposed are designed to meet interim milestones and bring groundwater levels back up to minimum thresholds, mitigate overdraft, and operate the Subbasin sustainably. The projects and management actions are reasonable and commensurate with the level of understanding of the Subbasin setting. The projects and management actions described in the Plan provide a feasible approach to achieving the Subbasin’s sustainability goal and should provide the GSAs with greater versatility to adapt and respond to changing conditions and future challenges during GSP implementation. (23 CCR § 355.4(b)(3).)

4. The 2023 Plan provides a detailed explanation of how the varied interests of groundwater uses and users in the Subbasin were considered in developing the sustainable management criteria and how those interests, including domestic wells, would be impacted by the chosen minimum thresholds. (23 CCR § 355.4(b)(4).)

5. The 2023 Plan’s projects and management actions appear feasible at this time and appear likely to prevent undesirable results and ensure that the Subbasin is operated within its sustainable yield within 20 years. The Department will continue to monitor Plan implementation and reserves the right to change its determination if projects and management actions are not implemented or appear unlikely to prevent undesirable results or achieve sustainability within SGMA timeframes. (23 CCR § 355.4(b)(5).)

6. The 2023 Plan includes a reasonable assessment of overdraft conditions and includes reasonable means to mitigate overdraft. (23 CCR § 355.4(b)(6).)

7. At this time, it does not appear that the 2023 Plan will adversely affect the ability of an adjacent basin to implement its GSP or impede achievement of sustainability goals in an adjacent basin. The Plan states that the Subbasin’s GSAs have met with GSAs in adjacent basins to share data and information to ensure that the implementation of the GSPs will not interfere with neighboring basins.

The Plan also qualitatively describes how minimum thresholds and measurable objectives may affect an adjacent basin, concluding that the Madera Subbasin Plan will not hinder the ability of an adjacent basin to be sustainable; however, the evaluation is provided without specifics. (23 CCR § 355.4(b)(7).)
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8. A satisfactory coordination agreement has been adopted by all relevant parties. (23 CCR § 355.4(b)(8).)

9. The City of Madera GSA, Madera County GSA, Madera Irrigation District GSA, Madera Water District GSA, Gravelly Ford Water District GSA, New Stone Water District GSA, and Root Creek Water District GSA have historically had a role in water planning and management in the Subbasin. The seven GSAs’ history of groundwater management provide a reasonable level of confidence that the GSAs have the legal authority and financial resources necessary to implement the 2023 Plan. (23 CCR § 355.4(b)(9).)

10.Through review of the 2023 Plan and consideration of public comments, the Department determines that the GSAs adequately responded to comments that raised credible technical or policy issues with the Plan, sufficient to warrant approval of the Plan at this time.

The Department also notes that the recommended corrective actions included in the Staff Report are important to addressing certain technical or policy issues that were raised and, if not addressed before future, subsequent plan evaluations, may preclude approval of the Plan in those future evaluations. (23 CCR § 355.4(b)(10).) H. In addition to the grounds listed above, DWR also finds that:

1. The 2023 Plan provides an analysis that documents the expected location and quantity of domestic wells that will experience undesirable results during the GSP implementation period based on future modeled groundwater conditions. Additionally, the Plan describes a domestic well mitigation program that the GSAs will implement to provide assistance to domestic and municipal wells adversely impacted by declining groundwater levels that have occurred since 2015. The Plan describes that the cost of mitigating domestic wells due to lowering groundwater levels is shown to be economically preferable to the costs associated with immediately stabilizing groundwater levels and the resulting impact to the local economy. The Plan’s compliance with the requirements of SGMA and substantial compliance with the GSP Regulations supports the state policy regarding the human right to water (Water Code § 106.3). The Department developed its GSP Regulations consistent with and intending to further the policy through implementation of SGMA and the Regulations, primarily by achieving sustainable groundwater management in a basin. By ensuring substantial compliance with the GSP Regulations, the Department has considered the state policy DocuSign Envelope ID: F6DF4CB7-9D58-44C0-A24A-70D06062CB75 Statement of Findings December 21, 2023
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regarding the human right to water in its evaluation of the Plan. (23 CCR § 350.4(g).)

2. The 2023 Plan acknowledges and identifies interconnected surface waters within the Subbasin. The GSAs propose interim sustainable management criteria to manage this sustainability indicator and measures to improve understanding and management of
interconnected surface water. The GSAs acknowledge, and the Department agrees, many data gaps related to interconnected surface water exist. The GSAs should continue filling data gaps, collecting additional monitoring data, and coordinating with resources agencies and interested parties to understand beneficial uses and users that may be impacted by depletions of interconnected surface water caused by groundwater pumping. Future updates to the Plan should aim to improve the initial sustainable management criteria as more information and improved methodology becomes available.

3. The California Environmental Quality Act (Public Resources Code § 21000 et seq.) does not apply to the Department’s evaluation and assessment of the Plan.

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Accordingly, the revised 2023 Plan submitted by the Agencies for the San Joaquin Valley – Madera Subbasin is hereby APPROVED. The recommended corrective actions identified in the Staff Report will assist the Department’s future review of the Plan’s implementation for consistency with SGMA and the Department therefore recommends the Agencies address them by the time of the Department’s periodic review, which is set to begin on January 31, 2025, as required by Water Code § 10733.8. Failure to address the Department’s Recommended Corrective Actions before future, subsequent plan evaluations, may lead to a Plan being determined incomplete or inadequate.

Signed:
_________________________________
Karla Nemeth, Director
Date: December 21, 2023
Exhibit A: Groundwater Sustainability Plan Assessment Staff Report – San Joaquin Valley – Madera Subbasin (December 21, 2023)
DocuSign Envelope ID: F6DF4CB7-9D58-44C0-A24A-70D06062CB75 California Department of Water Resources
Sustainable Groundwater Management Program Page 1 of 53 State of California
Department of Water Resources
Sustainable Groundwater Management Program
Groundwater Sustainability Plan Assessment
Staff Report
Groundwater Basin Name: San Joaquin Valley - Madera Subbasin (No. 5-022.06) Number of GSPs:

Number of GSAs:
4 (see list below)
7 (see list below)
Submittal Type: Revised Plan in response to Incomplete Determination Submittal Date: March 21, 2023
Recommendation: Approve
Date: December 21, 2023
On March 21, 2023, multiple groundwater sustainability agencies (GSAs) resubmitted multiple groundwater sustainability plans (GSPs) for the entire Madera Subbasin (Subbasin), which are coordinated pursuant to a required coordination agreement, to the Department of Water Resources (Department) in response to the Department’s incomplete determination on September 22, 20221 for evaluation and assessment as required by the Sustainable Groundwater Management Act (SGMA) 2 and GSP Regulations.3 In total, four GSPs have been revised and implemented by seven GSAs.

Collectively, all GSPs and the Coordination Agreement are, for evaluation and assessment purposes, treated and referred to as the Plan for the Subbasin. Individually, the GSPs include the following:
• Gravelly Ford Water District Groundwater Sustainability Plan (Gravelly Ford GSP) – prepared by the Gravelly Ford Water District GSA.
• Joint Groundwater Sustainability Plan (Joint GSP) – prepared jointly by the City of Madera GSA, Madera County GSA, Madera Irrigation District GSA, and Madera Water District GSA.
• New Stone Water District Groundwater Sustainability Agency Groundwater Sustainability Plan (New Stone GSP) – prepared by the New Stone Water District GSA.
1 Water Code § 10733.4(b); 23 CCR § 355.4(a)(4).
https://sgma.water.ca.gov/portal/service/gspdocument/download/9363; Water Code § 10733.4(b); 23 CCR § 355.4(a)(4). 2 Water Code § 10720 et seq. 3 23 CCR § 350 et seq.

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Sustainable Groundwater Management Program Page 2 of 53 • Root Creek Water District Groundwater Sustainability Agency Groundwater Sustainability Plan (Root Creek GSP) – prepared by the Root Creek Water District GSA.

After evaluation and assessment, Department staff conclude the GSAs have taken sufficient actions to correct deficiencies identified by the Department; however, Department staff have provided recommended corrective actions which will be required to be addressed by the Plan’s next periodic evaluation.

Overall, Department staff believe the Plan contains the required components of a GSP, demonstrates a thorough understanding of the Subbasin based on what appears to be the best available science and information, sets well explained, supported, and reasonable sustainable management criteria to prevent undesirable results as defined in the Plan, and proposes a set of projects and management actions that, if successfully implemented, are likely achieve the sustainability goal defined for the Subbasin. 4 Department staff will continue to monitor and evaluate the Subbasin’s progress toward achieving the sustainability goal through Annual Reports and future Periodic Evaluations of the GSP and its implementation.

Based on the reevaluation of the Plan, Department staff recommend the Plan be approved.

This assessment includes six sections:
• Section 1 – Summary: Provides an overview of the Department Staff’s assessment and recommendations.
• Section 2 – Evaluation Criteria: Describes the legislative requirements and the Department’s evaluation criteria.
• Section 3 – Required Conditions: Describes the submission requirements of a response to an incomplete determination to be evaluated by the Department. • Section 4 – Deficiency Evaluation: Provides an assessment of whether and how the contents included in the GSP submittal addressed the deficiencies identified by the Department in the initial incomplete determination. • Section 5 – Plan Evaluation: Provides a detailed assessment of the contents included in the GSP organized by each Subarticle outlined in the GSP Regulations. • Section 6 – Staff Recommendation: Includes the staff recommendation for the Plan and any recommended corrective actions.
4 23 CCR § 354.24.

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Sustainable Groundwater Management Program Page 3 of 53 1 SUMMARY
Department staff recommend approval of the Plan for the Madera Subbasin and have recommended corrective actions designed to address shortcomings of the Plan described in this Staff Report. In the evaluation of the Plan, Department staff concluded that sufficient action was taken to correct the deficiencies; however, Department staff have provided recommended corrective actions which will be required to be address by the Plan’s next periodic evaluation.

The GSA has identified areas for improvement of its Plan (e.g., addressing data gaps related to land subsidence and interconnected surface water, refining water budgets, incorporating new information into the numerical model, and expanding monitoring networks). Department staff concur that those items are important and recommend the GSA address them as soon as possible. As mentioned, Department staff have also identified additional recommended corrective actions that the GSA should consider for the next periodic evaluation of the Plan or sooner (see Section 6). Addressing these recommended corrective actions will be important to demonstrate, on an ongoing basis, that implementation of the Plan is likely to achieve the sustainability goal. The recommended corrective actions generally focus on the following:

1. Providing a detailed explanation specifically discussing and identifying Madera Irrigation District GSA’s legal, contractual, or other authorities or arrangements to implement its obligations under the Joint GSP in the next periodic evaluation.

2. Continuing efforts to further coordinate the GSPs and groundwater management.

3. Sufficiently describing the effect of chronic lowering of groundwater level interim milestones on other sustainability indicators.

4. Reevaluating the quantitative metrics that constitute undesirable results due to land subsidence and sufficiently describing the effect and extent of land subsidence interim milestones that allow continued subsidence during the GSP implementation period.

5. Describing data gaps in the hydrogeologic conceptual model.

6. Sufficiently detailing the degraded water quality undesirable results and explaining the rationale to allow potential further degradation.

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Sustainable Groundwater Management Program Page 4 of 53 2 EVALUATION CRITERIA
The Department evaluates whether a Plan conforms to the statutory requirements of SGMA5 and is likely to achieve the basin’s sustainability goal,6 whether evaluating a basin’s first Plan,7 a Plan previously determined incomplete,8 an amended Plan,9 or a GSA’s periodic update to an approved Plan.10 To achieve the sustainability goal, each version of the Plan must demonstrate that implementation will lead to sustainable groundwater management, which means the management and use of groundwater in a manner that can be maintained during the planning and implementation horizon without causing undesirable results. 11 The Department is also required to evaluate, on an ongoing basis, whether the Plan will adversely affect the ability of an adjacent basin to implement its groundwater sustainability program or achieve its sustainability goal.12 The Plan evaluated in this Staff Report is a revision of the 2020 Plan, which was evaluated by the Department and found to be incomplete. An incomplete Plan is one which Department staff identify as containing one or more deficiencies that preclude its initial approval. Deficiencies may result from supporting information that is insufficiently detailed or analyses that are insufficiently thorough or unreasonable, or where Department staff determine it is unlikely the GSAs in the basin could achieve the sustainability goal under the proposed Plan. After a GSA has been afforded up to 180 days to address the deficiencies and based on the GSA’s efforts, the Department can either approve13 the Plan or determine the Plan inadequate.14
The Department’s evaluation and assessment of a revised or amended Plan, subsequent to the initial Plan being found to be incomplete, as presented in this Staff Report, continues to follow Article 6 of the GSP Regulations15 to determine whether the Plan, with revisions or additions prepared by the GSA, complies with SGMA and substantially complies with the GSP Regulations.16 As stated in the GSP Regulations, “substantial compliance means that the supporting information is sufficiently detailed and the analyses sufficiently thorough and reasonable, in the judgment of the Department, to evaluate the Plan, and the Department determines that any discrepancy would not materially affect the 5 Water Code §§ 10727.2, 10727.4, 10727.6.
6 Water Code § 10733; 23 CCR § 354.24. 7 Water Code § 10720.7. 8 23 CCR § 355.2(e)(2).
9 23 CCR § 355.10.
10 23 CCR § 355.6.
11 Water Code § 10721(v).
12 Water Code § 10733(c).
13 23 CCR §§ 355.2(e)(1). 14 23 CCR §§ 355.2(e)(3).
15 23 CCR § 355 et seq. 16 23 CCR § 350 et seq.

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Sustainable Groundwater Management Program Page 5 of 53 ability of the Agency to achieve the sustainability goal for the basin, or the ability of the Department to evaluate the likelihood of the Plan to attain that goal.”17 The recommendation to approve a Plan previously determined to be incomplete is based on a determination that the GSAs have taken sufficient actions (e.g., amended or revised the Plan) to correct the deficiencies previously identified by the Department that precluded earlier approval.
3 REQUIRED CONDITIONS
For a Plan that the Department determines to be incomplete, the Department identifies corrective actions to address those deficiencies that preclude approval of the Plan as initially submitted. The GSAs in a basin, whether developing a single GSP covering the basin or multiple GSPs, must attempt to address those corrective actions within the time provided, not to exceed 180 days, for the Plan to be evaluated by the Department.

3.1 INCOMPLETE RESUBMITTAL
GSP Regulations specify that the Department shall evaluate a resubmitted GSP in which the GSAs have taken corrective actions within 180 days from the date the Department issued an incomplete determination to address deficiencies.18 The Department issued the incomplete determination on September 22, 2022. The GSAs resubmitted their individual GSPs and the Coordination Agreement on March 21, 2023 in compliance with the 180 day deadline. However, the Madera Irrigation District GSA (MID GSA) did not adopt a resolution approving and/or adopting the Revised Joint GSP, which was prepared jointly by MID GSA, the City of Madera GSA, Madera County GSA, and Madera Water District GSA. However, MID GSA did approve the related Coordination Agreement.

MID GSA’s failure to adopt the Revised Joint GSP concerned Department staff.

Accordingly, on April 6, 2023, the Sustainable Groundwater Management Office sent a letter seeking clarification from MID GSA regarding its failure to adopt the Revised Joint GSP. The MID GSA responded by letter dated April 21, 2023, confirming that “the MID GSA has not and does not intend to adopt the Revised Joint GSP,” stating that “MID GSA has determined the Revised Joint GSP is inadequate,” and explaining that “the MID GSA cannot adopt the Revised Joint GSP without substantial revision.” At the same time, the letter indicated that “[t]he lack of action on the Revised Joint GSP was not due to any intention on the part of MID GSA to avoid its implementation of the Revised Joint GSP,” and vowed that “MID GSA will continue to fully implement its own obligations under the Revised Joint GSP.”
17 23 CCR § 355.4(b).
18 23 CCR § 355.4(a)(4).

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Sustainable Groundwater Management Program Page 6 of 53 MID GSA’s refusal to adopt the Revised Joint GSP, but its apparent intent to implement its obligations under the Revised Joint GSP, creates a level of inconsistency and uncertainty regarding Plan implementation that continues to concern staff. SGMA provides that a GSA may exercise any of the powers granted by SGMA if the GSA adopts and submits a Plan to the Department. Because of MID GSA’s failure to adopt the Revised Joint GSP, it is unclear whether MID GSA has the necessary powers and authorities to implement its obligations under the Revised Joint GSP. In its previous letter, MID GSA claimed it would implement the Plan, but did not provide specific references to existing, non-SGMA authorities granting it the powers to implement the Revised Joint GSP or otherwise explaining how it retained SGMA authorities to do so, or identifying other agreements or entities that had the power and would implement those aspects of the Revised Joint GSP. Without an understanding of these issues, Department staff remain concerned that overall SGMA implementation in the Subbasin may be infeasible or delayed as a result of MID GSA’s failure to adopt the Revised Joint GSP. However, Department staff do not believe this issue precludes an approval recommendation at this time, because various components of the overall Subbasin Plan have been and continue to be implemented and staff is not aware of any existing impediment or delay in implementation caused by these circumstances.

Nevertheless, MID GSA is the only GSA of which Department staff are aware that has refused to adopt a GSP that it intends to implement. This novel circumstance continues to be a concern to Department staff. To alleviate those concerns, Department staff provide a recommended corrective action requiring identification and listing of the specific projects and management actions that MID GSA will or may be responsible for implementing under the Revised Joint GSP and a parallel listing and detailed identification and discussion of the legal, contractual, or other authorities or arrangements that MID GSA is relying or will rely upon in adequately implementing the Plan including those projects or management actions to clearly demonstrate the feasibility of all projects and management actions (see Recommended Corrective Action 1) Department staff will closely monitor Plan implementation and may change its recommendation if MID GSA does not provide a satisfactory response addressing these issues in the next periodic evaluation or if it appears that MID GSA’s failure to adopt the Revised Joint GSP is preventing or delaying Plan implementation or otherwise impacting the likelihood of the Subbasin to achieve sustainability consistent with SGMA timelines.

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Sustainable Groundwater Management Program Page 7 of 53 4 DEFICIENCY EVALUATION
As stated in Section 355.4 of the GSP Regulations, a basin “shall be sustainably managed within 20 years of the applicable statutory deadline consistent with the objectives of the Act.” The Department’s assessment is based on a number of related factors including whether the elements of a GSP were developed in the manner required by the GSP Regulations, whether the GSP was developed using appropriate data and methodologies and whether its conclusions are scientifically reasonable, and whether the GSP, through the implementation of clearly defined and technically feasible projects and management actions, is likely to achieve a tenable sustainability goal for the basin.

In its initial incomplete determination, the Department identified deficiencies in the Plan which precluded the Plan’s approval in September 2022.
19 In September 2022 the GSAs
were given 180 days to take corrective actions to remedy the identified deficiencies.

Consistent with the GSP Regulations, Department staff have evaluated the revised 2022 Plan to determine if the GSAs have taken sufficient actions to correct the deficiencies.

4.1 DEFICIENCY 1. THE GSPS HAVE NOT SUFFICIENTLY COORDINATED ON DATA

AND METHODOLOGIES INCLUDING COORDINATION OF SUSTAINABILITY GOAL,

WATER BUDGET AND SUSTAINABLE YIELD, AND UNDESIRABLE RESULTS AS REQUIRED BY SGMA AND THE GSP REGULATIONS.

4.1.1 Corrective Action 1
As described in the Department’s GSP Assessment Staff Report released on September 22, 2022, Department staff determined that the Subbasin’s definition of an undesirable result for the chronic lowering of groundwater levels was not consistent with the requirements of SGMA. The Department provided the following corrective actions for the Subbasin to consider and address:

The Plan does not provide sufficient explanation to confirm that the GSPs have been developed using the same data and methodologies and that elements of the GSPs have been based upon consistent interpretations of the Subbasin’s setting.

The GSAs in the Subbasin should modify each of their respective GSPs, as well as any applicable coordination materials, to substantially comply with the GSP Regulations and define sustainable yield and undesirable results, and develop water budgets in a manner that addresses groundwater conditions occurring throughout the Subbasin, not for only the portion of the Subbasin represented by the respective GSPs.
19 Incomplete Determination of the 2020 Groundwater Sustainability Plan for the San Joaquin Valley – Madera Subbasin, Department of Water Resources, September 22, 2022. https://sgma.water.ca.gov/portal/service/gspdocument/download/9363 GSP Assessment Staff Report December 21, 2023
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4.1.2 Evaluation
To address the identified deficiencies, the GSAs have supplemented portions of each Plan to use consistent data and methodologies. Specifically, the descriptions supporting the sustainability goal, water budgets, and undesirable results have been further detailed or revised. Most of the supplemented material is provided in the Joint GSP and Coordination Agreement and referenced by the other GSPs.

The Department’s Incomplete Determination notified the GSAs that the Plan did not present a coordinated sustainability goal in the Coordination Agreement applicable to the entire Subbasin. Instead, each GSP described related, but varied sustainability goals. In response, the GSAs amended the Coordination Agreement to include a sustainability goal that all parties agree to as presented below:

The sustainability goal for the Madera Subbasin is to implement a package of projects and management actions that will, by 2040, balance long-term groundwater system inflows and outflows based on a 50-year period representative of average historical hydrologic conditions.20 The Gravelly Ford GSP,21 New Stone GSP,
22 and Root Creek GSP23 still contain the
varied language describing the sustainability goal that was present in the initial Plan submission; however, the language does not conflict with the overarching sustainability goal definition found in the Coordination Agreement. A detailed assessment of the sustainability goal is provided in Section 5.3.1.

The Department’s Incomplete Determination also notified the GSAs that the water budgets presented in each GSP were unclear, used different data, and were difficult to assess. Additionally, the water budget along with an estimate of sustainable yield was not included in the Coordination Agreement as required. In response, the GSAs have amended the GSPs and the Coordination Agreement to include agreed upon water budgets and estimates of sustainable yield. Specifically, the GSPs now all reference historical, current, and projected water budgets24 developed in February 2018 for the entire Madera Subbasin and developed for the seven subregions representing each GSA.

This water budget information was part of the initial Joint GSP submission in 2020 but was not clearly recognized in the other GSPs at the time. A detailed assessment of the water budget is provided in Section 5.2.3.

The GSPs acknowledge that there are still refinements needed to remove discrepancies and further improve the accuracy of the water budgets. The New Stone and Root Creek resubmitted GSPs note that the availability of more specific information and knowledge on the regional scale (i.e., geography, geology, water management practices, familiarity, 20 Madera Subbasin Coordination Agreement, p. 34.
21 Gravelly Ford GSP (Redlined), Section 3.1, p. 53. 22 New Stone GSP (Redlined), Section 4.1, pp. 129-130. 23 Root Creek GSP (Redlined), Section 4.1, pp. 184-185. 24 Joint GSP (Resubmitted), Appendix 2.F, pp. 1322-1620; Appendix 6.D, pp. 2012-3335.

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Sustainable Groundwater Management Program Page 9 of 53 and understanding)25 have been discussed amongst the GSAs and updates to the model will occur during the 2025 evaluation cycle.26 Department staff encourage these efforts and also recommend the GSAs continue productive coordination and refinement of each GSP to be a cohesive Plan for sustainable groundwater management in the Subbasin (see Recommended Corrective Action 2).

4.1.3 Conclusion
Overall, Department staff believe the GSAs have taken sufficient action to address the identified deficiencies. Staff conclude that the enhanced coordination and addition of a coordinated sustainability goal and water budget with agreed upon estimates of sustainable yield for the Subbasin allows the GSAs to manage the Subbasin as intended by SGMA. However, as highlighted in the recommended corrective actions, the GSP should continue efforts to increase cooperative coordination and alignment of each GSP by the next periodic evaluation. The Plan also provides an agreed upon definition of undesirable results occurring in the Subbasin, which is discussed in Section 4.2.2.1.

4.2 DEFICIENCY 2. THE PLAN DOES NOT ESTABLISH MINIMUM THRESHOLDS FOR

CHRONIC LOWERING OF GROUNDWATER LEVELS IN A MANNER SUBSTANTIALLY COMPLIANT WITH THE GSP REGULATIONS.

4.2.1 Corrective Action 2
As described in the Department’s GSP Assessment Staff Report released on September 22, 2022, Department staff determined that the GSAs must provide more detailed explanation and justification regarding the selection of the sustainable management criteria for groundwater levels, particularly the undesirable results, the minimum thresholds, and the effects of those criteria on the interests of beneficial uses and users of groundwater. The Department provided the following corrective actions for the Subbasin to consider and address:

1. The GSAs should describe the specific undesirable results they aim to avoid through implementing the Plan. If, for example, significant and unreasonable impacts to domestic wells are a primary management concern for the Subbasin, then the GSAs should sufficiently explain why that effect was selected and what level of impact(s) to those wells the GSAs consider to be significant and unreasonable. In support of its explanation, the GSPs should also clearly discuss and disclose the anticipated impact of operating the Subbasin at conditions protective against those effects on users of domestic wells and all other beneficial uses and users of groundwater in the Subbasin. The discussion should be supported using best available information, such as using State or county information on well completion reports and dry well reports, to analyze the 25 New Stone GSP (Redlined), Section 3.3, p. 106; Root Creek GSP (Redlined), Section 3.3.3, p. 180. 26 New Stone GSP (Redlined), Section 3.3.1, p. 107.

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2. The GSAs should either explain how the existing minimum threshold groundwater levels are consistent with avoiding undesirable results or they should establish minimum thresholds at the representative monitoring wells that account for the specific undesirable results the GSAs aim to avoid. The Plan should include a detailed description of the factors and information considered and the analytic route and rationale the GSAs employed to reach conclusions regarding significant and unreasonable effects constituting undesirable results for groundwater levels and other applicable sustainability indicators.

3. The GSAs need to provide a description of the relationship between established minimum thresholds for all applicable sustainability indicators including how conditions at minimum thresholds avoid undesirable results for each applicable indicator.

4.2.2 Evaluation
To address the identified deficiencies, the GSAs have supplemented portions of the Plan related to the sustainable management criteria for chronic lowering of groundwater levels.

Specifically, descriptions supporting the undesirable result, minimum thresholds, measurable objectives, interim milestones, and a domestic well mitigation program have been further detailed or revised. Most of the supplemented material is provided in the Joint GSP and referenced by the other GSPs.

4.2.2.1 Describing Undesirable Results and Potential Effects (1) The Department’s Incomplete Determination notified the GSAs that the Plan incorrectly established undesirable results which were applicable only within each GSP area— without agreement between GSPs—and some of the information provided in each GSP was insufficiently detailed.

In response to the corrective action, the GSAs coordinated to develop agreed-upon undesirable results applicable to the entire Subbasin. The GSPs reference information in the Joint GSP as a basis for developing undesirable results, particularly coordinating on defining when an undesirable result will occur (i.e., the quantitative description of minimum threshold exceedances that cause significant and unreasonable effects). In describing undesirable results, each GSP provides a different level of detail. For example, the Joint GSP describes an undesirable result as “those conditions that: 1) Cause significant financial burden to local agricultural interests or other beneficial uses and users who rely on the Subbasin’s groundwater resources, 2) Cause groundwater level conditions at private domestic wells that cannot be mitigated, and 3) Interfere with other sustainability indicators.” 27 The Gravelly Ford GSP refers to this information but also, alongside the New Stone GSP and the Root Creek GSP, provides additional description 27 Joint GSP (Redlined), Section 3.4.1, p. 323.

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As mentioned, the Plan describes details for a domestic well mitigation program, 32 which
the GSAs will implement to provide assistance to domestic and municipal wells adversely impacted by declining groundwater levels that have occurred since 2015.33 The Plan includes supporting information for the mitigation program which document the expected location and quantity of domestic wells that will experience undesirable results during the GSP implementation period. Staff believe the details provided for this framework effectively describe the specific undesirable results the GSAs are trying to avoid. Based on an analysis of 4,822 wells, the GSP documents that up to 1,294 wells,34 located primarily in the central and eastern portion of the Subbasin, 35 would be impacted due to
future modeled groundwater conditions. The total cost to assist impacted wells is estimated to be approximately $39,000,000; however, the Plan describes that the cost of mitigating domestic wells due to lowering groundwater levels is shown to be economically preferable to the costs associated with immediately stabilizing groundwater levels and the resulting impact to the local economy.
36 The GSAs have provided a commitment to this
program including a schedule, timeline, and have reported progress in recent Annual Reports. The GSAs expect that the program would be implemented during the GSP 28 Gravelly Ford GSP (Redlined), Section 3.4.1, p. 60; New Stone GSP (Redlined), Section 4.2.1.1, p. 131; Root Creek GSP (Redlined), Section 4.2.1, p. 186.
29 Joint GSP (Redlined), Section 3.3.1.1, pp. 294-295; Gravelly Ford GSP (Redlined), Section 3.4.1, p. 60; New Stone GSP (Redlined), Section 4.2.1.2, pp. 132-133; Root Creek GSP (Redlined), Section 4.2.1.1, pp. 187-188. 30 Joint GSP (Redlined), Section 3.4.1, p. 323. 31 Joint GSP (Redlined), Section 3.4.1, p. 323.
32 Joint GSP (Resubmitted), Appendix 3.E, pp. 1904-1918, Appendix 2.G, pp. 1733-1813. 33 Joint GSP (Redlined), Section 3.3.1.1, p. 294.
34 Joint GSP (Resubmitted), Appendix 2.G, p. 1762. 35 Joint GSP (Resubmitted), Appendix 2.G, pp. 1783-1787. 36 Joint GSP (Resubmitted), Appendix 3.D, p. 1902.

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Sustainable Groundwater Management Program Page 12 of 53 implementation period, no later than 2025; as of March 2023, the GSP states, the GSAs are continuing to develop the program’s eligibility criteria and terms.37 In addition to the domestic well mitigation program, the Plan includes a suite of over 25 projects and management actions (e.g., demand management, increased recharge, increased surface water supply) which will be utilized to meet interim milestones and bring groundwater levels back up to minimum thresholds, mitigate overdraft, and operate the Subbasin sustainably. At full implementation, by 2040, the projects and actions will provide 215,840 acre-feet per year of annual gross benefit. The estimated capital cost of the projects is over $260,000,000, with an estimated annual operating cost of over $70,000,000; Department staff note that the GSAs have included an estimated economic cost from reduced crop production resulting from demand management in the estimated annual operating cost, which is approximately $54,000,000 per year or over 75% of the total annual cost provided.
38 The implementation schedule and expected benefit of each project was also considered in the modeling scenario used to develop interim milestones. 39 A review of the Annual Reports submitted to the Department shows progress on many of the projects.40 For example, the GSAs report a cumulative total benefit of over 63,000 acre--feet from projects and management actions to date, with a benefit of 7,300 acre-feet for the latest reported water year. 41 With reporting of active
progress toward project implementation, Department staff have increased confidence in the likelihood of the Plan to achieve the sustainability goal of the Subbasin.

Based on the information provided, Department staff think the Plan provides a reasonable description of the potential effects of undesirable results due to lowering of groundwater levels to domestic wells, generally the shallowest wells, and encourage the GSAs to continue development of the domestic well mitigation program and provide progress updates in Annual Reports. The GSAs should continue to progress projects and provide updates of observed benefits to the Department in Annual Reports. Department staff conclude that defining agreed upon undesirable results for the Subbasin and describing the potential effects of planned undesirable results that are likely to occur has sufficiently addressed component 1 of the corrective action.

4.2.2.2 Establishing Minimum Thresholds, Measurable Objectives, and Interim Milestones (2)
The Department’s Incomplete Determination notified the GSAs that each Plan’s varied descriptions and methods to establish minimum thresholds for chronic lowering of groundwater levels were not provided with sufficient supporting information to allow Department staff to evaluate whether the criteria were reasonable or whether operating 37 Joint GSP (Redlined), Section 3.3.1.1, p. 295. 38 Joint GSP (Redlined), Table 4-3, p. 366; Section 4.4.4.5, p. 409. 39 Joint GSP (Redlined), Section 3.2.1.2, p. 270; Joint GSP, Appendix 6.D, pp. 2323-2326. 40 Madera Subbasin Annual Reports, https://sgma.water.ca.gov/portal/gspar/submitted. 41 Joint GSP Water Year 2022 Annual Report, pp. 57-58.

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In response to the corrective action, the GSAs revised the chronic lowering of groundwater levels minimum thresholds to be set at the fall 2015 groundwater level measurement recorded at each representative monitoring site. 42 The Plan explains that
the groundwater level minimum thresholds based on fall 2015 groundwater levels are consistent with the avoidance of significant and unreasonable impacts to other sustainability indicators. 43 The Plan states that the minimum thresholds will keep groundwater elevations generally above levels that have been experienced in the past, and that impacts to shallow well users and other beneficial users of groundwater will generally not exceed what has historically been experienced in the Subbasin. 44 Furthermore, the Plan explains that minimum thresholds established at fall 2015 groundwater levels are consistent with the avoidance of significant and unreasonable impacts for subsidence, water quality, and depletions of interconnected surface water.45 The measurable objectives were revised to the fall 2010 groundwater levels which represents Subbasin conditions prior to the 2012 to 2015 drought period. 46 Department staff believe that establishing minimum thresholds at the fall 2015 groundwater level is a reasonable approach. However, the GSAs intend to allow continued groundwater level declines during the 20-year implementation period based on the GSP’s proposed interim milestones. The process to establish interim milestones is described as a “review and evaluation of measured groundwater level data and future projected fluctuations in groundwater levels during the GSP implementation period utilizing the numerical groundwater flow model, which simulated implementation of projects and management actions.”47 As a result, interim milestones were set to levels below minimum thresholds in years 2025, 2030, and 2035, prior to recovering by 2040 due to the implementation of projects and management actions.48 Interim milestones for 2030 are the lowest groundwater elevations expected to occur during the GSP implementation period. When examining the hydrographs provided, Department staff note the 2030 milestones are frequently below historical lows.49 To successfully implement such a management program, GSAs are required to fully and thoroughly describe undesirable results that may occur prior to achieving sustainability, implement necessary projects and management actions to eliminate those undesirable results, and show measurable progress in annual reporting. The GSP provides information detailing how the proposed management of lowering groundwater levels 42 Joint GSP (Redlined), Section 3.3.1, p. 293.
43 Joint GSP (Redlined), Section 3.3.1.4, pp. 301-303. 44 Joint GSP (Redlined), Section 3.3.1, pp. 293-294. 45 Joint GSP (Redlined), Section 3.3.1.4, pp. 302-303.
46 Joint GSP (Redlined), Section 3.2.1.1, pp. 269-270.
47 Joint GSP (Redlined), Section 3.2.1.2, p. 270.
48 Joint GSP (Redlined), Section 3.2.1.3, p. 271.
49 Joint GSP (Resubmitted), Appendix 2.E.b, pp. 1243-1380; Gravelly Ford GSP (Redlined), Appendix G, pp. 218-224.

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Based on a review of the information found in the resubmitted Plan and Annual Reports, Department staff conclude that at this time the GSAs have sufficiently addressed component 2 of the corrective action.

4.2.2.3 Describing How Minimum Thresholds Avoid Undesirable Results For Other Sustainability Indicators (3)
The Department’s Incomplete Determination notified the GSAs that the GSPs require a description of how conditions at minimum thresholds avoid undesirable results for each applicable indicator.

In response to the corrective action, the GSAs revised the GSPs to include a discussion of the relationship between established minimum thresholds and undesirable results for other sustainability indicators. However, the GSP Regulations require the Department to evaluate whether the minimum thresholds and interim milestones are reasonable50 and established in a manner to avoid undesirable results for each of the other sustainability indicators.
51 Department staff believe the lower interim milestones have the potential to cause undesirable results related to land subsidence, water quality, and interconnected surface water in the Subbasin. For example, the highest annual rate of subsidence was recorded between December 2012 and July 2014, when groundwater levels were declining to historical lows.52 The GSAs should consider and disclose their understanding of the correlation between the declining groundwater levels and the maximum historical rate of subsidence while also describing the relationships between groundwater levels and the other applicable sustainability indicators. Department staff are concerned that impacts on other indicators (such as subsidence and water quality) may not recover in the same manner that groundwater levels may. Therefore, the GSAs should analyze how the groundwater levels at interim milestones will avoid causing undesirable results for other sustainability indicators (see Recommended Corrective Action 3).

Based on a review of the information found in the resubmitted Plan, Department staff conclude that the GSAs have taken sufficient action to address component 3 of the corrective action.
50 23 CCR § 355.4(b)(1).
51 23 CCR § 354.28(b)(2).
52 New Stone GSP (Redlined), Section 3.2.6.1, p. 99.

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4.2.3 Conclusion
At this time, Department staff believe the GSAs have taken sufficient action to address the deficiency identified. Department staff believe that having all the GSPs coordinated and establishing minimum thresholds at 2015 groundwater levels – in conjunction with the implementation of a well mitigation program and the projects and managements actions outlined in the Plan – to be a reasonable means of mitigating overdraft to achieve sustainability by 2040. However, Department staff note the GSAs intend to continue overdraft before 2040 based on the revised interim milestones, which after examining the hydrographs provided, are frequently below historical lows. 53 While SGMA and the GSP
Regulations do not preclude undesirable results from occurring during Plan implementation, undesirable results cannot remain or continue after 20 years of Plan implementation. Department staff encourage the GSAs to continue with planning and implementation of the domestic well mitigation program to assist those users and uses of groundwater and other sustainability indicators (e.g., land subsidence, water quality, or interconnected surface water) that may be affected by lowering groundwater levels. The recommended corrective actions should also be considered by the next Periodic Evaluation for further advancement of the sustainable groundwater management in the Subbasin.

4.3 DEFICIENCY 3. THE PLAN DOES NOT DEVELOP SUSTAINABLE MANAGEMENT

CRITERIA FOR LAND SUBSIDENCE BASED ON BEST AVAILABLE INFORMATION AND SCIENCE.

4.3.1 Corrective Action 3
As described in the Department’s GSP Assessment Staff Report released on September 22, 2022, Department staff determined that the GSAs do not sufficiently demonstrate that undesirable results related to land subsidence are not present and are not likely to occur in the Subbasin. The Department provided the following corrective actions for the Subbasin to consider and address the following:

1. Clarify and address the currently conflicting information in the Plan regarding what is known, qualified by the level of associated uncertainty, about the existence and impact of land subsidence.

2. The GSP should develop sustainable management criteria based on information in the basin setting and establish a monitoring network to adequately monitor conditions..
54 The basin setting should sufficiently detail the physical setting and characteristics of the Subbasin including descriptions of principal aquifers. the definable bottom of the Subbasin and identify data gaps and uncertainty within the 53 Joint GSP (Resubmitted), Appendix 2.E.b, pp. 1243-1380; Gravelly Ford GSP (Redlined), Appendix G, pp. 218-224, New Stone GSP (Redlined), Figures 4-2 through 4-7, pp. 145-150; Root Creek GSP (Redlined), Figures 4-2 through 4-7, pp. 196-201. 54 23 CCR § 354.26.

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4.3.2 Evaluation
To address the identified deficiency, the GSAs have supplemented portions of each Plan to develop sustainable management criteria and monitoring for land subsidence. Most of the supplemented material is provided in the Joint GSP and referenced by the other GSPs.

4.3.2.1 Clarifying Conflicting Information in the Plan (1) The Department’s Incomplete Determination notified the GSAs that the GSPs provided conflicting information related to whether significant and unreasonable land subsidence has occurred or will occur in the Subbasin.

In response to the corrective action, the GSPs acknowledge that significant and unreasonable land subsidence has historically occurred during periods with groundwater pumping in excess of the sustainable yield in areas where critical infrastructure exists and in the western areas that overlay the Lower Aquifer, where the Corcoran Clay exists.55 Additionally, loss of groundwater storage and associated reduction in pore pressures in clay layers in the Lower Aquifer (indicated by lowering groundwater levels) is understood by all parties to lead to conditions that cause or exacerbate land subsidence.56 Between 1926 and 1972, subsidence resulted in up to 4.0 feet of elevation change within the western portion of the Subbasin.57 The highest rate of subsidence, also in western portion of the Subbasin, was 0.60 feet per year from December 2012 through July 2014.58 The Plan also provides various maps documenting the location and extent of subsidence in the Subbasin.59
The Plan provides information about infrastructure that is susceptible to subsidence.

Specifically, the Joint GSP provides an infrastructure sensitivity assessment of critical infrastructure including roads, railroads, highways, waterways, surface water conveyance structures, agricultural wells, domestic wells, public supply wells, and wastewater infrastructure. The assessment discusses impacts or interference with surface land uses and includes details such as proximity, orientation, and relative vulnerability to adverse effects of land subsidence. 60 Generally, the assessment states that the critical infrastructure were not anticipated to be impacted by future subsidence rates. For example, the GSP identifies the Chowchilla Bypass and the Eastside Bypass as critical infrastructure overlaying the Corcoran Clay, near an area of past documented subsidence; based on annual average subsidence rates from 2011 to 2017, the design profile and freeboard of the bypass will not be impacted by residual subsidence through 55 Joint GSP (Redlined), Section 3.4.3, p. 325.
56 Joint GSP (Redlined), Section 3.3.3.7, p. 313.
57 Gravelly Ford GSP (Redlined), Section 2.2.2, p. 41.
58 New Stone GSP (Redlined), Section 3.2.6.1, p. 99.
59 New Stone GSP (Redlined), Figures 3-23 and 3-24, pp. 101-102. 60 Joint GSP (Resubmitted), Appendix 3.G, pp. 1921-1953.

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Based on a review of the information found in the resubmitted Plan, Department staff conclude that the GSAs have addressed component 1 of the corrective action.

4.3.2.2 Developing Sustainable Management Criteria and Monitoring Network (2) The Department’s Incomplete Determination notified the GSAs that the GSPs do not sufficiently demonstrate that undesirable results related to land subsidence are not present and are not likely to occur in the Subbasin.

In response to the corrective action, the GSPs establish revised, coordinated sustainable management criteria for the Subbasin to not allow subsidence once sustainability is achieved in 2040. With that the GSPs amended the minimum thresholds to 0 feet per year (ft/yr).
64 The Plan also identifies a total uncertainty of subsidence to be -0.16 ft/yr, meaning any amount of subsidence less than -0.16 ft/yr would be considered within the uncertainty of measurement and considered 0 ft/yr.65 The Plan states that this minimum threshold is consistent with the sustainable management criteria for groundwater levels which seeks to keep levels above 2015 conditions by 2040.66 The GSAs also revised the measurable objective rate to 0 ft/yr. 67 The Plan allows for minimum threshold exceedances throughout the duration of the implementation phase with the proposed interim milestones, which were revised based on two areas: areas of subsidence monitoring and areas of greater subsidence concern.
68 For areas of monitoring, interim
milestones are established at -0.20 ft/yr by 2025, -0.13 ft/yr by 2030, -0.07 ft/yr by 2035, and 0 ft/yr by 2040 which are monitored by three survey benchmarks and one continuous GPS station. For areas of concern, interim milestones are established at -0.60 ft/yr by 2025, -0.40 ft/yr by 2030, -0.20 ft/yr by 2035, and 0 ft/yr by 2040 and monitored at three survey benchmarks. The established interim milestones are based on observed data with the highest rates (i.e., milestones to 2025) being slightly higher than actual subsidence rates experienced in the Subbasin between 2011 and 2016. 69 The Plan defines an undesirable result as occurring when “… the average subsidence across 75 percent or 61 Joint GSP (Resubmitted), Appendix 3.G, p. 1932.
62 Joint GSP (Resubmitted), Appendix 3.G, p. 1935.
63 Joint GSP (Resubmitted), Appendix 3.G, p. 1933; Joint GSP (Redlined) Section 3.3.3.7, p. 312. 64 Joint GSP (Redlined), Section 3.3.3, pp. 310-314. 65 Joint GSP (Redlined), Section 3.3.3.1, p. 311. 66 Joint GSP (Redlined), Section 3.3.1.4, p. 301.
67 Joint GSP (Redlined), Section 3.2.3.1, p. 279.
68 Joint GSP (Redlined), Section 3.2.3.2, pp. 279-280.
69 Joint GSP (Redlined), Section 3.2.3.2, p. 280.

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Sustainable Groundwater Management Program Page 18 of 53 more RMS in the Subbasin (including RMS in all four GSP plan areas) exceeds the minimum threshold for two consecutive years.”70
Department staff have identified areas for improvement in the GSAs’ defined undesirable results. Specifically, the quantification of conditions that likely would cause undesirable results as when more than 75 percent of the representative monitoring sites in the Subbasin exceed threshold levels for two consecutive years is unsatisfactory, because the Plan does not explain how this threshold would avoid effects the GSAs have determined to be significant and unreasonable. On the contrary, the values and timing of exceedances appear to be arbitrary. Subsidence is prominent and likely to occur in western portions of the Subbasin in correlation with the presence of the Corcoran Clay.

Two of the seven representative monitoring sites are located in that area of the Subbasin; using the current definition, localized subsidence could occur indefinitely without meeting the quantitative criteria for an undesirable result. Furthermore, when considering land subsidence, compacted sediments may not rebound alongside rising groundwater levels due to irreversible changes in the subsurface. Additionally, the Plan establishes two subsidence areas, as mentioned above, which the GSAs do not consider when establishing the quantitative metrics for an undesirable result (i.e., Department staff would expect more stringent metrics in the areas of greater subsidence concern as compared to the subsidence monitoring areas). These criteria should be considered when defining when and where undesirable results occur (see Recommended Corrective Action 4a) While Department staff are encouraged by the updated sustainable management criteria, the Plan still does not identify a total (i.e., cumulative) amount of subsidence which would be considered significant and unreasonable. The interim milestones established using annual rates would allow for up to 6.5 feet of total subsidence by 2040. This appears inconsistent with the legislative intent of SGMA to avoid or minimize subsidence, and no adequate justification for allowing this amount of additional subsidence is provided in the GSP.71 Considering the Subbasin has recently experienced subsidence and contains infrastructure that the GSP identifies as susceptible to subsidence, the GSAs should identify and disclose the cumulative amount of subsidence that can occur without causing significant and unreasonable impacts to the beneficial uses and users of groundwater, surface land uses, and property interests, all of which must be clearly defined. In establishing the cumulative amount of potential subsidence that could occur during GSP implementation, the GSAs should consider the conditions necessary to minimize or halt subsidence during GSP implementation and maintain those conditions once sustainability has been achieved on or before 2040. Based on the amount of subsidence anticipated between now and 2025, Department staff believe this does not preclude approval at this time. However, given that the Plan projects minimum threshold exceedances during implementation, which may likely result in undesirable results related to water levels, and the Plan intends for subsidence to be 0 ft/yr only by and after 2040, Department staff 70 Joint GSP (Redlined), Section 3.4.3, p. 325. 71 Water Code § 10720.1 (e).

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Sustainable Groundwater Management Program Page 19 of 53 recommend identifying and including a quantitative value for cumulative subsidence for minimum thresholds and other sustainability criteria related to subsidence by the first Periodic Evaluation (see Recommended Corrective Action 4b).

SGMA and the GSP Regulations indicate that for a basin to be sustainably managed, the basin must experience no undesirable results within 20 years of plan implementation and then throughout the planning and implementation horizon. Unlike other indicators, the legislature specifically indicated its intent that SGMA implementation avoid or minimize subsidence.72 Unlike groundwater levels that may fall and then rise in a basin, subsidence can often be inelastic and permanent. This means that undesirable results from subsidence during plan implementation will likely still exist and persist to 2040 and beyond. For instance, subsidence that occurs during early Plan implementation that causes lasting impacts to infrastructure, like flood control structures, that substantially interferes with the infrastructure’s operations and utility in 2040 and beyond, constitutes an undesirable result under SGMA. Department staff believe that the Plan’s continued allowance of minimum threshold exceedances during the first 20 years of plan implementation (i.e., allowing further subsidence as a result of water level declines below historic lows at the interim milestones) and potential permanent impacts to surface infrastructure and uses is not consistent with the intent of SGMA to achieve sustainability and to avoid or minimize subsidence. The Plan should consider and provide details describing the current and potentially lasting impacts of subsidence on land uses and groundwater beneficial uses and users as described above in Recommended Corrective Action 4b.

The GSP Regulations require the Department to evaluate whether the minimum thresholds and interim milestones are reasonable73 and established in a manner to avoid undesirable results for each of the other sustainability indicators. 74 Department staff believe the interim milestones below the minimum threshold have the potential to cause undesirable results related to other sustainability indicators which the GSAs also have a responsibility to avoid. For example, the Plan does not provide a discussion of how the subsidence milestones, that allow for continued subsidence and associated irreversible compaction of aquifer materials, relate to the reduction of groundwater storage or the degradation of water quality sustainability indicators. The GSAs should consider and disclose their understanding of this and other relationships between sustainability indicators. The GSAs should analyze whether or how the land subsidence rates at interim milestones will avoid causing undesirable results for other sustainability indicators (see Recommend Corrective Action 4c).

In the establishment of the minimum thresholds for land subsidence, the Plan describes the application of a level of uncertainty to measurements, claiming that the survey measurements have a vertical accuracy of plus or minus 2.5 centimeters. The Plan 72 Water Code § 10720.1(e).
73 23 CCR § 355.4(b)(1).
74 23 CCR § 354.28(b)(2).

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Sustainable Groundwater Management Program Page 20 of 53 proposes adding these uncertainty values so that when two measurements are taken the Agencies consider the total uncertainty in subsidence to be 5 centimeters, which equals approximately -0.16 ft/yr. By this rationale, the Plan assumes that subsidence values less than 0.16 ft/yr are within the uncertainty of measurement and considered to be compliant with the minimum threshold of 0 ft/yr.75 However, although there may be some uncertainty in subsidence measurements, the uncertainty does not necessarily mean that small measurements of subsidence within that range of uncertainty (or accuracy) should be ignored or mean that no subsidence is occurring. Department staff believe this approach of always rounding any annual subsidence measurements within the range of error to zero every year is inconsistent with standard practices. When multiple measurements are taken at the same location, they are compared to the same baseline measurement and, in turn, have the same single level of uncertainty. While it’s understandable to build in an allowance for some level of uncertainty, it appears the Plan allows for the continued subsidence if the measured rate is equal to or less than 0.16 ft/yr. Department staff recommend the Plan revise its application of the level of uncertainty as it relates to subsidence measurements according to standard professional practices (see Recommended Corrective Action 4d).

The Plan acknowledges there are data gaps in assessing subsidence in the Subbasin and provides a workplan76 which aims to provide sufficient data and analysis to fill data gaps, including enhancing monitoring and understanding relationships between land subsidence and groundwater levels at different depths within the western part of the Subbasin, improving quantification of groundwater pumping within Upper Aquifer and Lower Aquifer, and assessing the adequacy of the sustainable management criteria.

Considering the Department provides quarterly updates for monthly InSAR subsidence data covering much of the Subbasin, the GSP should address or explain why the GSAs have decided to not utilize this reliable data source to assess whether management is causing significant and unreasonable effects to surface land uses. Department staff encourage these efforts and also recommend the GSAs take steps to address the recommended corrective actions by the next Periodic Evaluation of the Plan.

Based on a review of the information found in the resubmitted Plan, Department staff conclude that the GSAs have addressed component 2 of the corrective action.

4.3.3 Conclusion
Overall, Department staff believe the GSAs have taken sufficient action to address the deficiency identified. Staff conclude that the zero tolerance for land subsidence minimum thresholds and measurable objectives at the end of the implementation period in 2040 is commensurate with the understanding of SGMA. However, Department staff are concerned with the amount of subsidence that may occur during the implementation period and the potential undesirable results that may cause as a result of permanent impacts to infrastructure and surface land uses. The recommended corrective actions 75 Joint GSP (Redlined), Section 3.3.3.1, p. 311.
76 Joint GSP (Resubmitted), Appendix 3.H, pp. 1954-1968.

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Sustainable Groundwater Management Program Page 21 of 53 should be considered by the next Periodic Evaluation to more align with the intent of SGMA to avoid or minimize subsidence.

4.4 DEFICIENCY 4. THE PLAN DOES NOT DEVELOP SUSTAINABLE MANAGEMENT

CRITERIA FOR THE DEPLETIONS OF INTERCONNECTED SURFACE WATER BASED ON BEST AVAILABLE INFORMATION AND SCIENCE.

4.4.1 Corrective Action 4
As described in the Department’s GSP Assessment Staff Report released on September 22, 2022, Department staff determined that the GSAs do not sufficiently demonstrate that interconnected surface water or undesirable results related to depletions of interconnected surface water are not present and are not likely to occur in the Subbasin.

The Department provided the following corrective actions for the Subbasin to consider and address the following:

1. Clarify and address the currently conflicting information in the Plan regarding what is known, qualified by the level of associated uncertainty, about the presence and degree of interconnected surface water and, if applicable, the depletion of that interconnected surface water by groundwater use, including quantities, timing, and locations.77

2. If the GSAs cannot provide a sufficient, evidence-based justification for the absence of interconnected surface water, then they should develop sustainable management criteria, as required in the GSP Regulations78 based on best available information and science. Evaluate and disclose, sufficiently and thoroughly, the potential effects of the Plan’s sustainable management criteria for depletion of interconnected surface water on beneficial uses of the interconnected surface water and on groundwater uses and users. Additionally, development of sustainable management criteria must be supported by information in the basin setting and the GSAs must develop a monitoring network capable of collecting sufficient data to support analysis of the quantified spatial and temporal exchanges between surface water and groundwater that can be associated with groundwater pumping.

4.4.2 Evaluation
To address the identified deficiency, the GSAs have supplemented portions of the Plan to describe the basin setting, develop sustainable management criteria and monitoring for depletions of interconnected surface water.

4.4.2.1 Clarifying Conflicting Information in the Plan (1) The Department’s Incomplete Determination notified the GSAs that the GSPs provided conflicting information related to identifying the presence of interconnected surface water in the Subbasin.
77 23 CCR §§ 354.28(c)(6)(A-B).
78 23 CCR §§ 354.26, 354.28, 354.30.

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Sustainable Groundwater Management Program Page 22 of 53 In response to the corrective action, the GSPs revised the descriptions of groundwater— surface water interactions in the Subbasin, acknowledging that data indicates that the San Joaquin River appears to be in connection with groundwater during some periods and there is at least some potential for regional groundwater pumping to impact groundwater dependent ecosystems (GDEs) with roots extending down 20 to 30 feet along the San Joaquin River.
79 The method the GSP used to determine the connectivity was to compare the historical regional aquifer groundwater elevations to stream thalweg (deepest portion of stream channel) elevations and assess stream seepage. The comparison of the groundwater levels and stream thalweg suggest the San Joaquin River was likely connected with groundwater from 1958 through 1984, but groundwater was about 10 to 50 feet below the thalweg from 1989 through 2016. 80 While this approach is sufficient to confirm the presence of a hydraulic connection, Department staff note groundwater levels dropping below the thalweg of the San Joaquin River would not be sufficient to prove surface water and groundwater are disconnected. This is because water from the river is still recharging the aquifer and may do so at a rate that would cause mounding in the local water table surrounding the river. The mounding in the water table may enable the river and aquifer to maintain a saturated hydraulic connection when groundwater levels drop well below the bottom of the river. Additionally, stream seepage indicates that during above normal and wet years, such as 2017 and 2019, groundwater is discharged to streams.81 The GSP states that there are data gaps, and provides a workplan82 which aims to provide sufficient data and analysis to fill data gaps, including making a more informed determination of whether or not interconnected surface water is present along the San Joaquin River, improving understanding of the relationship between streamflow and regional groundwater pumping, and providing an improved basis for setting sustainable management criteria if it is determined that interconnected surface water conditions exist.83 At this time, Department staff conclude sufficient action has been taken on this deficiency and believe the GSAs can work with the Department to further efforts on interconnected surface water.

Based on a review of the information found in the resubmitted Plan, Department staff conclude that the GSAs have addressed component 1 of the corrective action.

4.4.2.2 Sustainable Management Criteria and Monitoring Network (2) The Department’s Incomplete Determination notified the GSAs that the GSPs do not sufficiently demonstrate that undesirable results related to depletions of interconnected surface water are not present and are not likely to occur in the Subbasin. Therefore, if the GSAs cannot provide a sufficient, evidence-based justification for the absence of 79 Joint GSP (Redlined), Section 2.2.2.5, p. 120. 80 Joint GSP (Redlined), Section 2.2.2.4, p. 118. 81 Joint GSP (Resubmitted), Figure 2-76, p. 310.
82 Joint GSP (Resubmitted), Appendix 3.I, pp. 1969-1981 83 Joint GSP (Resubmitted), Appendix 3.I, p. 1971.

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Sustainable Groundwater Management Program Page 23 of 53 interconnected surface water, then they should develop sustainable management criteria, as required in the GSP Regulations.

In response to the corrective action, the GSPs established interim sustainable management criteria for depletions of interconnected surface water along the San Joaquin River. Specifically, the GSAs define an undesirable result occurring when greater than 30 percent of representative monitoring wells exceed their minimum thresholds for two consecutive five-year rolling averages.84 Minimum thresholds are defined as the percent of time surface water and groundwater was connected over the historical period of 1989 to 2015. Measurable objectives and interim milestones are the same as minimum thresholds. Monitoring will be conducted annually using three monitoring sites.

The GSAs used a metric called “percent of time connected” to develop the interim sustainable management criteria for depletion of interconnected surface water. 85 In reviewing the information provided in the GSP, Department staff conclude that while developing sustainable management criteria for interconnected surface water is a substantial step forward in addressing the deficiency, the development of sustainable management criteria in the Plan is not consistent with the GSP Regulations. Reporting the percent of time connected does not provide adequate information to describe or evaluate the quantity and timing of depletions of interconnected surface water due to groundwater use, as required by the GSP Regulations.86 As mentioned in Section 4.4.2.1, the GSAs prepared a work plan outlining an approach to fill these data gaps. 87 The work
plan states the GSAs intend to compile and review pertinent existing data and reports, construct and install new monitoring facilities, collect additional field data, and conduct additional technical analysis. The purpose is to make a more informed determination of whether interconnected surface water is present along the San Joaquin River, to improve understanding of the relationships between streamflow, shallow groundwater levels, and regional groundwater pumping.88 While the work plan states that the GSAs will potentially refine or modify the interim sustainable management criteria, it also indicates that the GSAs will continue using the metric of “percent of time connected” for sustainable management criteria 89 – a metric Department staff conclude is not appropriate in estimating timing and volume of interconnected surface water depletion and evaluating potential impacts to beneficial uses and users. The GSAs proposed to complete most of the tasks in the work plan by 2024 with the intent of including the early results in the first Periodic Evaluation.
90 Department staff are encouraged by the GSA’s intent to increase data collection and fieldwork. At this time, Department staff conclude sufficient action has 84 Joint GSP (Redlined), Section 3.4.5, p. 327.
85 Joint GSP (Redlined), Section 3.2.5.1, p. 291, Section 3.3.5.1, p. 319. 86 23 CCR §§ 354.28(c)(6)(A), 354.28(c)(6)(B).
87 Joint GSP (Resubmitted), Appendix 3.I, pp. 1969-1981. 88 Joint GSP (Resubmitted), Appendix 3.I, pp. 1970-1971. 89 Joint GSP (Resubmitted), Appendix 3.I, p. 1979.
90 Joint GSP (Resubmitted), Appendix 3.I, p. 1980.

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Sustainable Groundwater Management Program Page 24 of 53 been taken on this deficiency and believe the GSAs can work with the Department to further efforts on interconnected surface water.

Based on a review of the information found in the resubmitted Plan, Department staff conclude that the GSAs have addressed component 2 of the corrective action.

4.4.3 Conclusion
Overall, Department staff believe the GSAs have taken sufficient action to address the deficiency identified.

Department staff understand that quantifying depletions of interconnected surface water from groundwater extractions is a complex task that likely requires developing new, specialized tools, models, and methods to understand local hydrogeologic conditions, interactions, and responses. During the initial review of GSPs, Department staff have observed that most GSAs have struggled with this requirement of SGMA. However, staff believe that most GSAs will more fully comply with regulatory requirements after several years of Plan implementation that includes projects and management actions to address the data gaps and other issues necessary to understand, quantify, and manage depletions of interconnected surface waters. Department staff further advise that at this stage in SGMA implementation GSAs address deficiencies related to interconnected surface water depletion where GSAs are still working to fill data gaps related to interconnected surface water and where these data will be used to inform and establish sustainable management criteria based on timing, volume, and depletion as required by the GSP Regulations.

The Department will continue to support GSAs in this regard by providing, as appropriate, financial and technical assistance to GSAs, including the development of guidance describing appropriate methods and approaches to evaluate the rate, timing, and volume of depletions of interconnected surface water caused by groundwater extractions. Once the Department’s guidance related to depletions of interconnected surface water is publicly available, GSAs, where applicable, should consider incorporating appropriate guidance approaches into their future periodic updates to the GSP. GSAs should consider availing themselves of the Department’s financial or technical assistance, but in any event must continue to fill data gaps, collect additional monitoring data, and implement strategies to better understand and manage depletions of interconnected surface water caused by groundwater extractions and define segments of interconnectivity and timing within their jurisdictional area. Furthermore, GSAs should coordinate with local, state, and federal resources agencies as well as interested parties to better understand the full suite of beneficial uses and users that may be impacted by pumping induced surface water depletion.

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Sustainable Groundwater Management Program Page 25 of 53 5 PLAN EVALUATION
As stated in Section 355.4 of the GSP Regulations, a basin “shall be sustainably managed within 20 years of the applicable statutory deadline consistent with the objectives of the Act.” The Department’s assessment is based on a number of related factors including whether the elements of a GSP were developed in the manner required by the GSP Regulations, whether the GSP was developed using appropriate data and methodologies and whether its conclusions are scientifically reasonable, and whether the GSP, through the implementation of clearly defined and technically feasible projects and management actions, is likely to achieve a tenable sustainability goal for the basin.

The Department staff’s evaluation of the likelihood of the Plan to attain the sustainability goal for the Basin is provided below. Department staff consider the information presented in the Plan to satisfy the general requirements of the GSP Regulations.

5.1 ADMINISTRATIVE INFORMATION
The GSP Regulations require each Plan to include administrative information identifying the submitting Agency, describing the plan area, and demonstrating the legal authority and ability of the submitting Agency to develop and implement a Plan for that area.91 The Madera Subbasin is bound by the San Joaquin River and Kings Subbasin in the south, Delta-Mendota Subbasin in the west, Chowchilla Subbasin in the north, and the foothills of Sierra Nevada in the east.92 No adjudicated areas are shown on the maps provided in the GSP.
93 The Subbasin does not have any considerable federal lands or state-owned lands.94
The Subbasin is managed by seven groundwater sustainability agencies. Four of those seven groundwater sustainability agencies have developed the Madera Joint Groundwater Sustainability Plan, and the other three groundwater sustainability agencies developed individual groundwater sustainability plans.95 The four GSPs that cover the entire Madera Subbasin are:
• Madera Joint Groundwater Sustainability Plan (Joint GSP) • Gravelly Ford Water District Groundwater Sustainability Plan (Gravelly Ford GSP)
• New Stone Water District Groundwater Sustainability Plan (New Stone GSP) 91 23 CCR § 354.2 et seq. 92 Joint GSP, Section 2.1, p. 63. 93 Joint GSP, Section 2.1.1, p. 63, Figure 2-1, p. 64. 94 Joint GSP, Section 2.1.1, p. 63. Note: Federal land includes primarily rights of way along canals conveying USBR Central Valley Project water. State land includes primarily California Department of Parks and Recreation land along San Joaquin River near Friant, California. 95 Joint GSP, Table 1-4, p. 56.

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Sustainable Groundwater Management Program Page 26 of 53 • Root Creek Water District Groundwater Sustainability Plan (Root Creek GSP) The four groundwater sustainability agencies that developed the Joint GSP collectively are:
• Madera County Groundwater Sustainability Agency
• City of Madera Groundwater Sustainability Agency
• Madera Irrigation District Groundwater Sustainability Agency • Madera Water District Groundwater Sustainability Agency The Joint GSP plan area represents 94% of the Madera Subbasin.96 The Joint GSP provides information that is encompassing-of, relevant-to, and reiterated-in the other three groundwater sustainability plans and is often cited by Department staff when referencing information relevant to the entire Subbasin. Collectively, unless otherwise specified, the four GSPs are referred to as the Plan for the Subbasin.

The Gravelly Ford GSP boundaries are contiguous with the Gravelly Ford Water District and contain approximately 8,500 acres comprised of grape vineyards, tree groves, and rural residences.97 The New Stone GSP boundaries are coterminous with the New Stone Water District boundaries, encompassing approximately 4,200 acres in the northwestern area of the Madera Subbasin. The New Stone Water District consists primarily of agriculture and two landowners.
98 The Root Creek GSP boundaries are the same as the
Root Creek Water District boundaries and is located in the southeastern portion of the Madera subbasin—bounded on the south by San Joaquin River—with the majority of the land being used as agriculture.99
A map showing the Subbasin and adjacent subbasins is shown in Figure 1 below. 96 Joint GSP, Table 1-2, p. 42. 97 Gravelly Ford GSP, Section 1.1.1, p. 6. 98 New Stone GSP, Executive Summary, p. 12. 99 Root Creek GSP, Executive Summary, p. 13, Figure 2-5, p. 43.

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Sustainable Groundwater Management Program Page 27 of 53 Figure 1. Madera Subbasin Location Map100
The land use areas in the Subbasin are broadly classified across three sectors:
agricultural (including dairies), urban, and native vegetation. 101 The Plan includes a summary of land use stating irrigated agriculture is the most prominent land use in the Subbasin, covering approximately 213,000 acres.102 For example, the New Stone GSP states that 100% of land use in the GSP is agricultural.103 Native vegetation and water surfaces collectively were reported to cover the second highest acreage approximately 100,000 acres.104 Urban area that includes cities, residential, and semi-agricultural cover approximately 36,000 acres.
105
The water use source type was not independently presented for the entire Subbasin. For example, the Gravelly Ford GSP states an unquantified, small amount of groundwater pumping occurs for domestic use.106 Instead, it is reported that the water source type is 100 Joint GSP, Figure 2-1, p. 64.
101 Joint GSP, Section 2.1.1, p. 65, Figure 2-2, p. 66. 102 Joint GSP, Table 2-1, p. 68.
103 New Stone GSP, Section 2.5.1, p. 38.
104 Joint GSP, Table 2-1, p. 68.
105 Joint GSP, Table 2-1, p. 68.
106 Gravelly Ford GSP, Section 2.1.5, p. 21.

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107
The Plan includes maps that depict the density of wells (domestic, agricultural, and public supply) by township range and section in Figure 2-5, Figure 2-6, and Figure 2-7 of the Joint GSP prepared from the Department’s Well Completion Report Map Application.108 The highest concentrations of reported domestic wells are centered primarily around the City of Madera and Bonadelle Ranchos-Madera Ranchos in the eastern portion of the Subbasin.
109 Reported irrigation wells are generally less concentrated and more evenly distributed across the Subbasin, though slightly higher concentrations are found in some areas within rural Madera County, Madera Irrigation District, and Root Creek Water District.110
The Plan describes existing water resource management programs operating in the Subbasin. The Joint GSP states the local agencies that have formed each of the Subbasin‘s groundwater sustainability agencies have prepared and adopted several water planning documents in the past, including Madera Integrated Regional Water Management Plan and Madera Regional Groundwater Management Plan. The Subbasin’s other local water management plans, federal, state, and regional groundwater and surface water programs were discussed.111 The Joint GSP states the existing water resource monitoring and management programs constitute a well-developed and broadly distributed system that provides representative data throughout the Subbasin that have been, and will be, incorporated into the Plan as appropriate. 112
The Plan provides a list of public meetings where the Plan was discussed, including GSA board meetings, Coordination Committee meetings, stakeholder advisory committee meetings, and public workshops.113 The GSPs include stakeholder communication and engagement plans to assist Subbasin groundwater sustainability agencies in their efforts to develop general and strategic communications to engage stakeholders in groundwater management activities.
114
The Plan identifies beneficial uses and users of groundwater in the Subbasin. The various stakeholders identified are the general public, private water users, urban and agricultural water users, industrial water users, environmental and ecosystem water uses, tribes, federal lands and integrated regional water management groups.115 The Plan describes the beneficial uses of groundwater in the Subbasin, which includes irrigation and drinking 107 Joint GSP, Figure 2-2, p. 66.
108 Joint GSP, Figures 2-5 through 2-7, pp. 171-173.
109 Joint GSP, Section 2.1.1, p. 70.
110 Joint GSP, Section 2.1.1, p. 70.
111 Joint GSP, Section 2.1.2, pp. 70-77. 112 Joint GSP, Section 2.1.2, pp. 70-77. 113 Joint GSP, Section 2.1.5, pp. 83-90, Table A6.C-2, pp. 1768-1779. 114 Joint GSP, Appendix 2.C.a, pp. 586-638; Gravely Ford GSP, Section 2.1.5, p. 22, New Stone GSP, Section 2.5.3 and 2.5.4, pp.39-40, Root Creek GSP, Section 2.5.3 to 2.5.4, pp. 73-75. 115 Joint GSP, Table 2-5, pp. 85-86, Table A2.C.a-1, pp. 592-593.

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Sustainable Groundwater Management Program Page 29 of 53 water supply (i.e., municipal, urban, and rural).116 According to the Joint GSP, each of the seven groundwater sustainable agencies in the Subbasin held regular public meetings, coordination committee meetings, and subbasin wide technical meetings. 117 For example, according to the Root Creek GSP,
118 engagement with the groundwater users
occurred at the time of formation of GSAs, development of the draft GSP, finalization of the GSP and engagement will continue for the implementation of the GSP.119 Overall, Department staff believe the GSAs have thoroughly described Agency information, plan area, and notice and communication process, in substantial compliance with the GSP Regulations.

5.2 BASIN SETTING
GSP Regulations require information about the physical setting and characteristics of the basin and current conditions of the basin, including a hydrogeologic conceptual model; a description of historical and current groundwater conditions; and a water budget accounting for total annual volume of groundwater and surface water entering and leaving the basin, including historical, current, and projected water budget conditions.120

5.2.1 Hydrogeologic Conceptual Model
The GSP Regulations require a descriptive hydrogeologic conceptual model of the basin that includes a written description supported by cross sections and maps. 121 The hydrogeologic conceptual model is a non-numerical model of the physical setting, characteristics, and processes that govern groundwater occurrence within a basin, and represents a GSA’s understanding of the geology and hydrology of the basin that support the geologic assumptions used in developing mathematical models, such as those that allow for quantification of the water budget.122
The Plan provides a description of the hydrogeologic conceptual model documented in a 2017 technical memoranda123 and qualified maps.
124 The Gravelly Ford GSP provided
additional descriptions to the hydrogeological conceptual model using a 2018 report titled Hydrogeologic Conceptual Model and Groundwater Conditions for the Gravelly Ford Water District GSP,
125 which describes the physical components in the Gravelly Ford 116 Joint GSP, Section 1, p. 40. 117 Joint GSP, Section 2.1.5.3, p. 86. 118 Root Creek GSP, Appendix 2-C, pp. 245-246. 119 Root Creek GSP, Section 2.5.1, pp. 72-73.
120 23 CCR § 354.12 et seq. 121 23 CCR § 354.12 et seq. 122 DWR Best Management Practices for the Sustainable Management of Groundwater: Hydrogeologic Conceptual Model, December 2016: https://water.ca.gov/-/media/DWR-Website/WebPages/Programs/Groundwater-Management/Sustainable-Groundwater-Management/Best-ManagementPractices-and-Guidance-Documents/Files/BMP-3-Hydrogeologic-Conceptual-Model_ay_19.pdf. 123 Joint GSP, Section 2.2.1, pp. 90-96. 124 Joint GSP, Figures 2-5 through Figure 2-46, pp. 171-211, Appendix 2.D, pp. 1078-1090. 125 Gravelly Ford GSP, Appendix B, pp. 89-124.

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and primary users of groundwater128 in the Gravelly Ford GSP area.

The surface geology of the Subbasin is described predominantly as younger and older alluvium with subsurface deposits, from the surface to the bottom of the Subbasin, consisting of alluvium and unconsolidated continental deposits. 129 The Subbasin is depicted to be underlain by crystalline basement complex rocks of the Sierra Nevada.130 The lateral boundaries of the Subbasin are described as the hydrogeologic boundary created by the bedrock of the Sierra Nevada to the east; and the political boundaries of the Kings Subbasin to the south, Chowchilla Subbasin to the north, and Delta-Mendota Subbasin to the west.131
The Plan describes that the bottom of the Subbasin, throughout most of the Subbasin, is defined by the depth to the base of fresh water (groundwater with conductivity up to 3,000 micromhos per centimeter), except in the eastern portion where it is defined by the depth to basement rock.132 However, the Plan states that there are wells screened below the defined base of fresh water while explaining these wells will likely have hydraulic connection with the overlying freshwater zone, so they are considered to be part of the Subbasin.133 For example, cross-sections provided by the Joint GSP depict wells that extend below the bottom of the Subbasin.134
The Plan does not explicitly use the term principal aquifers to describe aquifers within the Subbasin, instead the Plan provides a description of aquifer systems present in the Subbasin. The Plan states that the Corcoran Clay underlies the western one-third of the Subbasin135 and acts as a confining layer separating the upper unconfined aquifer from the lower confined aquifer.136 The top of Corcoran Clay lies between 200 to 350 feet beneath the New Stone GSP area.137 The Plan describes that the area outside of the Corcoran Clay, located in the central and eastern portions of the Subbasin, contains discontinuous clay layers interspersed with permeable coarse-grained units and is generally considered to be semi-confined. The semi-confined aquifer is further described as an upper semi-confined aquifer and a lower semi-confined aquifer (at an estimated depth ranging from 200 to 400 feet which generally correlates to the depth of the Corcoran Clay).138 The Plan states the Subbasin contains areas of perched water. For example, 126 Gravelly Ford GSP, Appendix B, p. 102.
127 Gravelly Ford GSP, Appendix B, pp. 96-99. 128 Gravelly Ford GSP, Appendix B, p. 107. 129 Joint GSP, Section 2.2.1.1, p. 91.
130 Joint GSP, Section 2.2.1.1, p. 91, Figure 2-19, p. 184. 131 Joint GSP, Section 2.2.1.2, p. 91, Figure 2-17, p. 182. 132 Joint GSP. Section 2.2.1.2. pp. 91-92, Figures 2-24 through 2-34, pp. 189-199. 133 Joint GSP, Section 2.2.1.2, p. 92.
134 Joint GSP, Figures 2-24 to 2-34, pp. 189-199.
135 Joint GSP, Section 2.2.1.3, p. 93.
136 New Stone GSP, Section 3.1.8, p. 60.
137 New Stone GSP, Section 3.1.8, p. 60.
138 Joint GSP, Section 2.2.1.3, pp. 93-94.

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Sustainable Groundwater Management Program Page 31 of 53 the Joint GSP states that the approximate location of the perched aquifers are six miles southeast of the City of Madera and ten miles northwest of the City of Madera; depths range from 3 to 27 feet southeast of the City of Madera, 100 feet within the City of Madera, and 105 to 130 feet northeast of Madera. Other sites with perched groundwater are believed to exist, but locations and depths are uncertain due to limited data.139 Department staff find that the Plan introduces uncertainty in the hydrogeologic conceptual model by identifying several aquifers in the Subbasin, but not directly defining any of these aquifers as principal aquifer(s). Additional details are provided below. • The Plan identifies formations (i.e., Modesto, Riverbank, and Turlock Lake Formation - which contains the Corcoran Clay)140 of the Subbasin but does not associate them with principal aquifer(s).
• The Plan describes the lateral and vertical boundaries of the Subbasin141 but does not provide details that describe the lateral and vertical boundaries by principal aquifer. Also, the GSP does not provide sufficient details to support that east of the Corcoran Clay, the upper regional aquifer is semi-confined, instead of unconfined. • The Plan does not provide a map depicting the source and point of delivery for imported waters.
• The Plan provides a description of water quality for total dissolved solids, nitrate, and arsenic along with maps of concentrations within the Subbasin.142 None of the water quality data is identified by principal aquifer, although some of the data is identified by different aquifer descriptions such as upper, lower, shallow wells and deep wells.143
The Plan provides cross-sections that provide sufficient information to depict the major stratigraphic and structural features in the Subbasin. Physical characteristics of the Subbasin are depicted on various maps and figures. The cross-sections depict the base of freshwater, top of crystalline basement complex of the Sierra Nevada along the eastern portion of the Subbasin. Also shown is the upper aquifer and lower aquifer separated by the Corcoran Clay. Additionally, the GSP describes that east of the Corcoran Clay extent, the aquifer system is considered to consist of an upper semi-confined aquifer and a lower semi-confined aquifer; 144 however, the cross-sections show unconfined groundwater levels in the areas identified in the GSP as semiconfined.

The Plan does not explicitly identify data gaps and uncertainty concerning the hydrogeologic conceptual model as required by the GSP Regulations.145 Department staff believe that a discussion regarding data gaps and uncertainty in the hydrogeologic 139 Joint GSP, Section 2.2.2.1, p. 98.
140 Joint GSP, Section 2.2.1.1, p. 91; Root Creek GSP, Section 3.1.2, p. 76. 141 Joint GSP, Section 2.2.1.2, p. 91. 142 Joint GSP, Section 2.2.2.3, pp. 102-104.
143 Joint GSP, Appendix 2.E., pp. 1267-1321. 144 Joint GSP, Section 2.2.1.1, p. 95. 145 23 CCR § 354.14(b)(5).

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Sustainable Groundwater Management Program Page 32 of 53 conceptual model, and plans to address data gaps is necessary, as lack of data and understanding of the physical characteristics of the subbasin may limit sustainable groundwater management (see Recommended Corrective Action 5).

5.2.2 Groundwater Conditions
The GSP Regulations require a written description of historical and current groundwater conditions for each of the six sustainability indicators and groundwater dependent ecosystems.146
Groundwater levels are currently declining across much of the Subbasin in both the unconfined and lower aquifer zones. 147 The current conditions are a continuation of historical trends of declining groundwater levels across much of the Subbasin that have been observed for at least the past 30 years.148 In total, more than 500 hydrographs are included in the Plan covering varying timelines over the last 100 years. Hydrographs included in the Plan show two measurements per year over the well’s entire period of record with the timeline beginning in 1945 or 1920.149
The Subbasin is also losing groundwater storage and has been since at least 1988 based on information provided in the Plan.
150 The Joint GSP includes a summary of various
studies which utilized different specific yield values to estimate the total volume of groundwater storage loss ranging between 1,891,308 acre-feet to 3,073,376 acre-feet for the period 1988 to 2014 and 2,809,149 acre-feet to 4,564,868 acre-feet for the period 1988 to 2016.151 This equates to an annual storage loss of 73,000 to 163,000 acre-feet per year since 1988. 152 The range in change in groundwater storage conditions result from five different specific yield estimates that vary from 5% to 12% for the Subbasin. The Joint GSP includes a summary table (Table 2-8) showing the total change of storage over two time periods: 1988 to 2014 and 1988 to 2016 based on five different specific yield values.153
The Plan identifies nitrate, total dissolved solid (TDS), and arsenic as the current key water quality constituents in the Subbasin. These three constituents were highlighted because they “have greater potential for presenting broader regional groundwater quality concerns extending beyond localized or site-specific contamination cases and are likely to reflect a range of potential contamination sources.”154 The New Stone GSP also states that salinity, chloride, specific conductance, and pesticides are constituents being detected in areas in the district; however, data available within and near the district indicates that levels of these constituents are generally below respective maximum 146 23 CCR § 354.16 (a-f). 147 Joint GSP, Section 2.2.2.1, pp. 97-100. 148 Joint GSP, Figures 2-56 and 2-57, pp. 221-222. 149 Joint GSP, Appendix 2.E.b, pp. 1129-1266. 150 Joint GSP, Section 2.2.2.2, p. 101. 151 Joint GSP, Section 2.2.2.2, pp. 101-102, Table 2-8, p. 102. 152 Joint GSP, Section 2.2.2.2, pp. 101-102, Table 2-8, p. 102. 153 Joint GSP, Table 2-8, p. 102. 154 Joint GSP, Section 2.2.2.3, p. 102.

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than 50 maps displaying chemical concentrations for the key water quality constituents and other chemicals.157
Land subsidence has occurred and continues to occur in the Subbasin. The Joint GSP includes a written description detailing land subsidence over three time periods: 1926 to 1970, 2007-2011, and 2015-2017. 158 The discussion in the GSP focuses on the northwestern portion of the Subbasin where 1 to 2 feet of land subsidence occurred between 1926 and 1970, 0.5 to 1.0 feet occurred between 2007 and 2011, and 1.0 to 1.5 feet between 2015 and 2017.159 The New Stone GSP states the subsiding area near El Nido is approximately 25 miles in diameter and its outer reach extends to the Plan area and the western area of the Subbasin.160 United States Bureau of Reclamation monitoring point 1007R located on the western boundary of Plan area has indicated an annual subsidence rate ranging from 0.09 to 0.60 feet per year since December 2011 with the highest annual rate occurring from December 2012 through July 2014. 161 The Plan includes maps displaying both historical and current land subsidence. 162 Department staff
provide information relevant to this in Section 4.3.

Interconnected surface water potentially exists in localized areas along the San Joaquin River within the Subbasin based on an analysis of comparing groundwater levels to the stream thalweg.163 Based on this analysis, there were also additional portions of the San Joaquin River that were connected with groundwater historically (from 1958 to 1984) but may no longer be connected due to declining groundwater levels.164 The Joint GSP states characterization of hydrogeologic conditions related to the potential for interconnected surface water is currently based on very limited data and, therefore, additional data collection and analyses are needed to update and refine the understanding of how surface water and GDEs may (or may not) be connected to the regional aquifers where groundwater pumping occurs.165 Department staff provide information relevant to this in Section 4.4.
155 New Stone GSP, Section 3.2.5, pp. 77-79.
156 Root Creek GSP, Section 3.2.6, pp. 120-125.
157 Joint GSP, Appendix 2.E, pp. 1268-1321; Root Creek GSP, Figures 3-27 through 3-29, pp. 121-123. 158 Joint GSP, Section 2.2.2.4, p. 105. 159 Joint GSP, Section 2.2.2.4, p. 105, Figures 2-67 through 2-70, pp. 232-235. 160 New Stone GSP, Section 3.2.6.1, p. 82. 161 New Stone GSP, Section 3.2.6.1, p. 82. 162 New Stone GSP, Figures 3-23 and 3-24, pp. 84-85. 163 Joint GSP (Redline), Section 2.2.2.5, p. 118.
164 Joint GSP, Section 2.2.2.5, p. 105. 165 Joint GSP (Redline), Section 2.2.2.5, p. 121.

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Sustainable Groundwater Management Program Page 34 of 53 The Plan identifies four areas within the Subbasin as “Potential GDE Units”.166 The Joint GSP includes a technical memorandum that provides additional information about each of the four Potential GDE Areas including a series of maps, identification of potential GDE species, and a description of GDE conditions in the Subbasin.167 Overall, the Plan sufficiently describes the historical and current groundwater conditions throughout the Subbasin and the information included in the Plan substantially complies with the requirements outlined in the GSP Regulations.

5.2.3 Water Budget
GSP Regulations require a water budget for the basin that provides an accounting and assessment of the total annual volume of groundwater and surface water entering and leaving the basin, including historical, current, and projected water budget conditions, and the change in the volume of water stored, as applicable.

The seven GSAs in the Subbasin use the data and analysis provided in the Technical Memorandum: Data Collection and Analysis (Davids engineering and Luhdorff & Scalmanini Consulting Engineers, July 2017) and the Draft Preliminary Basin Boundary Water Budget (Davids engineering and Luhdorff & Scalmanini Consulting Engineers, February 2018). 168 These documents were used to develop the Subbasin’s water budget.
169 The water budget described in the Joint GSP presents a water budget for the entire Plan area, including annual water budget information for Gravelly Ford GSP, New Stone GSP, and Root Creek GSP; the Gravelly Ford GSP, New Stone GSP, and Root Creek GSP also reference the water budget information in the Joint GSP.170 Detailed information is provided for all seven GSAs in Appendix 6.D of the Joint GSP.171 An assessment of the information is provided below.

The water budgets contain a surface water system and a groundwater system (referred to as accounting centers) for the entire Subbasin. The Plan clearly lists the inflow, outflow, and change in storage components for each accounting center.172 This framework is applied to the current, historical, and projected budgets.

The period 1989-2014 is used as the base period for both the historical and current water budget and represents average hydrologic conditions based on cumulative departure from mean precipitation. 173 The average annual change in storage is calculated as -34,200 acre-feet per year174 for the historical budget. The overdraft estimate for the current water budget is -93,276 acre-feet, calculated using an average of historical 166 Joint GSP, Section 2.2.2.6, p. 107.
167 Joint GSP, Appendix 2.B, pp. 518-584. 168 Madera Subbasin Coordination Agreement, p. 12. 169 Joint GSP, Section 2.2.3.1, p. 114. 170 Joint GSP, Appendix 2.F, pp. 1322-1620. 171 Joint GSP, Appendix 6.D, pp. 2012-2175. 172 Joint GSP, Table 2-10, p. 117. 173 Joint GSP, Section 2.2.3.2, pp. 122-123, Figures 2-81 and 2-82, p. 124. 174 Joint GSP, Table 2-26, p. 159.

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Sustainable Groundwater Management Program Page 35 of 53 hydrologic conditions from 1989-2014 with 2015 land use data. 175 The information presented indicates that change in storage is positive only during wet years at a volume of 122,900 acre-feet. All other years indicate decreases in storage ranging from -82,700 to -230,400 acre-feet.176
Sustainable yield is calculated for the historical and projected water budgets. 177 As reported in the Plan, the historical sustainable yield for the Subbasin is 437,300 acre-feet per year.178 The projected sustainable yield for the Subbasin is 439,300 acre-feet per year with a lower bound of 329,500 acre-feet per year and upper bound of 549,100 acrefeet per year. 179 The projected sustainable yield was calculated only for the sustainability period 2040-2090 with the reasoning that ongoing projects and demand management during the implementation period (2020-2039) will continually shift sustainable yield as project efficacy is evaluated. 180 The similarity of historical and projected sustainable yields suggests the sustainable yield during the implementation period would not differ appreciably from these estimates.

Department staff conclude the historical, current, and projected water budgets included in the Plan substantially comply with the requirements outlined in the GSP Regulations.

The GSP provides the required historical, current, and future accounting and assessment of the total annual volume of groundwater and surface water entering and leaving the Subbasin including an estimate of the sustainable yield of the Subbasin and projected future water demands.

5.2.4 Management Areas
The GSP Regulations provide the option for one or more management areas to be defined within a basin if the GSA has determined that the creation of the management areas will facilitate implementation of the Plan. Management areas may define different minimum thresholds and be operated to different measurable objectives, provided that undesirable results are defined consistently throughout the basin.
181
No management areas were designated per the information provided in the Plan.

5.3 SUSTAINABLE MANAGEMENT CRITERIA
The GSP Regulations require each Plan to include a sustainability goal for the basin and to characterize and establish undesirable results, minimum thresholds, and measurable objectives for each applicable sustainability indicator, as appropriate. The GSP Regulations require each Plan to define conditions that constitute sustainable groundwater management for the basin including the process by which the GSA 175 Joint GSP, Table 2-30, p. 163.
176 Joint GSP, Table 2-33, p. 165.
177 Joint GSP, Section 2.2.3.4, pp. 166-167. 178 Joint GSP, Table 2-34, p. 167. 179 Joint GSP, Table 2-35, p. 168.
180 Joint GSP, Section 2.2.3.4, p. 167.
181 23 CCR § 345.20.

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5.3.1 Sustainability Goal
The GSAs establish a sustainability goal for the Subbasin in the Coordination Agreement which is to “…implement a package of projects and management actions that will, by 2040, balance long-term groundwater system inflows and outflows based on a 50-year period representative of average historical hydrologic conditions.” 183 The Joint GSP explains that during the 20-year implementation period a combination of recharge projects, replacing groundwater use with surface water, and demand reduction management actions are planned. These efforts will “increase groundwater inflows and decrease groundwater outflows to bring the groundwater system into balance by 2040 and will allow its operation to remain sustainable over a 50-year period representing average hydrologic conditions.”184
Each GSP also provides additional specific information describing the goal for each GSP area. For example, the Gravelly Ford GSP describes the sustainability goal for the Subbasin as “…to minimize the listed undesirable results throughout the Subbasin by providing a Gravelly Ford GSP water supply that supports current cultivated acreage in the Plan area by developing an expanded surface water irrigation and recharge program, and groundwater monitoring and land elevation measurement program.”185 The New Stone GSP states that “[t]he goal for the GSP is to provide a tool for managing groundwater, basin-wide, on a long-term basis and to meet measurable objectives for each indicator by maintaining a sustainable yield, thus avoiding undesirable results.”186 The Root Creek GSP explains that the sustainability goal is to work collectively with the other GSAs within the Subbasin to “sustainably manage the groundwater resources of the basin while maintaining openness to the public and stakeholders such that local citizenry has a voice in the outcome.”187 Additionally, the goal of the Root Creek GSP is to “immediately reduce and eventually eliminate systematic overdraft within the [GSP] area.188 While, specifying how each GSP will support the Subbasin sustainability goal within its’ GSP area is an appropriate level of detail for each GSP, Department staff recommend the GSAs continue to coordinate and align this portion of each GSP to provide a more cohesive definition between the specific GSP goal and the sustainability goal for the Subbasin (see Recommended Corrective Action 2). 182 23 CCR § 354.22 et seq. 183 Madera Subbasin Coordination Agreement, p. 34. 184 Joint GSP, Section 3.1.2, p. 244. 185 Gravelly Ford GSP, Section 3.1, p. 48. 186 New Stone GSP, Section 4.1, p. 110. 187 Root Creek GSP, Section 4.1, p. 157. 188 Root Creek GSP, Section 1.2, p. 17.

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5.3.2 Sustainability Indicators
Sustainability indicators are defined as any of the effects caused by groundwater conditions occurring throughout the basin that, when significant and unreasonable, cause undesirable results.189 Sustainability indicators thus correspond with the six undesirable results – chronic lowering of groundwater levels indicating a significant and unreasonable depletion of supply if continued over the planning and implementation horizon, significant and unreasonable reduction of groundwater storage, significant and unreasonable seawater intrusion, significant and unreasonable degraded water quality, including the migration of contaminant plumes that impair water supplies, land subsidence that substantially interferes with surface land uses, and depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water190 – but refer to groundwater conditions that are not, in and of themselves, significant and unreasonable. Rather, sustainability indicators refer to the effects caused by changing groundwater conditions that are monitored, and for which criteria in the form of minimum thresholds are established by the agency to define when the effect becomes significant and unreasonable, producing an undesirable result.

The following subsections consolidate three facets of sustainable management criteria:
undesirable results, minimum thresholds, and measurable objectives. Information, as presented in the Plan, pertaining to the processes and criteria relied upon to define undesirable results applicable to the basin, as quantified through the establishment of minimum thresholds, are addressed for each sustainability indicator. However, a GSA is not required to establish criteria for undesirable results that the GSA can demonstrate are not present and are not likely to occur in a basin.191

5.3.2.1 Chronic Lowering of Groundwater Levels
The GSP Regulations require the minimum threshold for chronic lowering of groundwater levels to be the groundwater elevation indicating a depletion of supply at a given location that may lead to undesirable results.
192
In the September 2022 Incomplete Determination, the Department identified deficiencies related to the sustainable management criteria for the chronic lowering of groundwater levels. The GSAs revised this portion of the Plan, and Department staff evaluate this sustainability indicator in Section 4.2 of this Staff Report. As presented above, Department staff concluded that the GSAs took sufficient action to correct this deficiency to warrant approving the Plan, but staff also provided recommended corrective actions based on the changes the Agencies have made to the sustainable management criteria for this sustainability indicator to further improve management during Plan implementation.
189 23 CCR § 351(ah).
190 Water Code § 10721(x).
191 23 CCR § 354.26(d).
192 23 CCR § 354.28(c)(1).

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5.3.2.2 Reduction of Groundwater Storage
The GSP Regulations require the minimum threshold for the reduction of groundwater storage to be a total volume of groundwater that can be withdrawn from the basin without causing conditions that may lead to undesirable results. Minimum thresholds for reduction of groundwater storage shall be supported by the basin’s sustainable yield, calculated based on the basin’s historical trends, water year type, and projected water use.193 The Plan states groundwater levels act as a proxy for the groundwater storage sustainability indicator and the sustainable management criteria for reduction in groundwater storage are the same as those established for chronic lowering of groundwater levels.194 Department staff will evaluate and compare the groundwater level conditions and reduction of storage in Annual Reports submitted to the Department.

Department staff expect the information will be reported on a per aquifer basis given the groundwater level monitoring network identifies which aquifer the representative monitoring site is monitoring.

5.3.2.3 Seawater Intrusion
The GSP Regulations require the minimum threshold for seawater intrusion to be defined by a chloride concentration isocontour for each principal aquifer where seawater intrusion may lead to undesirable results.195
As stated in the Plan, seawater intrusion sustainability criteria are not applicable to the Subbasin, because it is located more than 70 miles inland and hydraulically disconnected from the ocean.196

5.3.2.4 Degraded Water Quality
The GSP Regulations require the minimum threshold for degraded water quality to be the degradation of water quality, including the migration of contaminant plumes that impair water supplies or other indicator of water quality as determined by the Agency that may lead to undesirable results. The minimum thresholds shall be based on the number of supply wells, a volume of water, or a location of an isocontour that exceeds concentrations of constituents determined by the Agency to be of concern for the basin. In setting minimum thresholds for degraded water quality, the Agency shall consider local, state, and federal water quality standards applicable to the basin.197 The GSP states that “an undesirable result for degraded groundwater quality occurs when groundwater quality exceeds an established MCL and minimum threshold for arsenic, nitrate, or TDS [total dissolved solids] for a significant duration of time and at a significant number of representative monitoring sites and is the direct result of projects or management actions undertaken as part of the GSP implementation.” 198 More 193 23 CCR § 354.28(c)(2).
194 Joint GSP, Section 3.4.2, pp. 277-278. 195 23 CCR § 354.28(c)(3). 196 Joint GSP, Section 3.2.6, p. 259.
197 23 CCR § 354.28(c)(4).
198 Joint GSP, Section 3.4.4, p. 279.

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Significant and unreasonable degradation of water quality is defined as “when beneficial uses for groundwater are adversely impacted by constituent concentrations increasing to levels above the drinking water MCLs for one of the key constituents of interest …due to implementation of a GSP project or management action.” 202 Though the definition provided appears to consider specific effects of degradation of groundwater quality, the GSP does not provide details that explain how the GSAs determined what “adversely impacted by constituent concentrations” means. Additionally, the GSP does not provide descriptions, supported by analysis, of the potential effects on the beneficial uses and users of groundwater, on land uses and property interests, and other potential effects that may occur or are occurring from undesirable results. The GSAs should update the definition of undesirable results to include specific scenarios the GSAs are trying to avoid (e.g., additional cost to domestic well users for well treatment, decrease in water available 199 Joint GSP, Section 3.4.4, p. 279.
200 Water Code § 10721(x).
201 23 CCR § 354.26 (b)(2).
202 Joint GSP, Section 3.4.4, p. 279.

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The GSP provides a description of potential causes of an undesirable result, limited to direct effects of GSP projects or management actions, such as localized pumping clusters (which would particularly affect areas prone to elevated arsenic concentrations occurring at greater pumping water level depths)203 and groundwater recharge which particularly affect areas of actively or formerly cultivated lands where high residual concentrations of nutrients, especially nitrogen, may exist.
204
The GSP establishes the minimum thresholds for degraded water quality at the “[maximum contaminant level (MCLs)] for drinking water for identified key constituents (10 mg/L for nitrate as nitrogen; 500 mg/L for TDS; 10 ug/L for arsenic) or when existing or historical concentrations for the key constituents already exceed the MCL, the minimum threshold is set at the recent concentration plus 20 percent.”205 Measurable objectives are set at current constituent concentrations.206 However, the GSP does not identify which wells have had exceedances in the past or provide the current constituent concentrations in the Plan. The GSP also states “significant and unreasonable degradation of water quality occurs when beneficial uses for groundwater are adversely impacted by constituent concentrations increasing to levels above the drinking water MCLs,” 207 but the GSP does not explain or justify setting minimum thresholds at 20 percent above MCLs, or demonstrate that these increased levels would not adversely impact beneficial uses and users of water. Department staff are not aware of specific concerns regarding degraded water quality that warrant immediate action based on what is provided in the Plan; however, staff believe the GSAs should identify the exact minimum threshold values what will be used and justify how establishing minimum thresholds at the higher of either MCLs or existing concentrations plus 20 percent does not constitute significant and unreasonable effects as defined by the GSP (i.e., “when beneficial uses for groundwater are adversely impacted by constituent concentrations) (see Recommended Corrective Action 6c).

5.3.2.5 Land Subsidence
SGMA defines the undesirable result for subsidence to be significant and unreasonable land subsidence that substantially interferes with surface land uses, caused by groundwater conditions occurring throughout the basin.208 The GSP Regulations require the minimum threshold for land subsidence to be the rate and extent of subsidence that 203 Joint GSP, Section 3.4.4, pp. 279-280. 204 Joint GSP, Section 3.4.4, p. 280. 205 Joint GSP, Section 3.3.4, p. 271. 206 Joint GSP, Section 3.4.2.1, p. 253. 207 Joint GSP, Section 3.4.4, p. 271.
208 Water Code § 10721(x)(5).

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In the September 2022 Incomplete Determination, the Department identified deficiencies related to the sustainable management criteria for land subsidence. The GSAs revised this portion of the Plan and Department staff provide evaluation for this sustainability indicator in Section 4.3 of this Staff Report. As presented above, Department staff concluded the GSAs had taken sufficient actions to correct the deficiencies and provided additional recommended corrective actions based on the changes the Agencies have made to the sustainable management criteria for this sustainability indicator to further improve basin management as the Plan is implemented.

5.3.2.6 Depletions of Interconnected Surface Water
SGMA defines undesirable results for the depletion of interconnected surface water as those that have significant and unreasonable adverse impacts on beneficial uses of surface water and are caused by groundwater conditions occurring throughout the basin.211 The GSP Regulations require that a Plan identify the presence of interconnected surface water systems in the basin and estimate the quantity and timing of depletions of those systems.212 The GSP Regulations further require that minimum thresholds be set based on the rate or volume of surface water depletions caused by groundwater use, supported by information including the location, quantity, and timing of depletions, that adversely impact beneficial uses of the surface water and may lead to undesirable results.213
In the September 2022 Incomplete Determination, the Department identified deficiencies related to the sustainable management criteria of depletions of interconnected surface water. The GSAs revised this portion of the Plan and Department staff provide evaluation for this sustainability indicator in Section 4.4 of this Staff Report. As presented above, Department staff concluded the GSAs had taken sufficient actions to correct the deficiencies and provided additional recommended corrective actions based on the changes the Agencies have made to the sustainable management criteria for this sustainability indicator.
209 23 CCR § 354.28(c)(5).
210 23 CCR §§ 354.28(c)(5)(A-B).
211 Water Code § 10721(x)(6).
212 23 CCR § 354.16(f).
213 23 CCR § 354.28(c)(6).

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5.4 MONITORING NETWORK
The GSP Regulations describe the monitoring network that must be developed for each basin including monitoring objectives, monitoring protocols, and data reporting requirements. Collecting monitoring data of sufficient quality and quantity is necessary for the successful implementation of a groundwater sustainability plan. The GSP Regulations require a monitoring network of sufficient quality, frequency, and distribution to characterize groundwater and related surface water conditions in the basin and evaluate changing conditions that occur through implementation of the Plan.214 Specifically, a monitoring network must be able to monitor impacts to beneficial uses and users,215 monitor changes in groundwater conditions relative to measurable objectives and minimum thresholds,
216 capture seasonal low and high conditions,217 include required information such as location and well construction, and include maps and tables clearly showing the monitoring site type, location and frequency.218 Department staff encourage GSAs to collect monitoring data as specified in the GSP, fill data gaps identified in the GSP prior to the first 5 year update,219 update monitoring network information as needed, follow monitoring best management practices,
220 and submit all monitoring data to the
Department’s Monitoring Network Module immediately after collection including any additional groundwater monitoring data that is collected within the Plan area that is used for groundwater management decisions. Staff note that if GSAs do not fill their identified data gaps, the GSA’s basin understanding may not represent the best available science for use to monitor basin conditions.

Each GSP identifies a distinct monitoring network that measures groundwater elevations for assessment of chronic lowering of groundwater levels. The Joint GSP identifies 37 monitoring wells with 11 wells in the Upper Aquifer, 22 wells in the Lower Aquifer, and four composite wells screened in both aquifers.221 The Joint GSP acknowledges the spatial coverage of the monitoring network for the Upper Aquifer is limited to the southwestern portion of the GSP area.222 The Gravelly Ford GSP states that two different groups of wells are currently being used for monitoring chronic lowering of groundwater levels; one with a network of 24 wells and another network of four wells from outside the GSP area to compare future measurements.
223 However, the Gravelly Ford GSP does
not specify which aquifer the wells are monitoring. The New Stone GSP monitoring network includes six monitoring wells comprised of three California Groundwater Elevation Monitoring Program (CASGEM) monitoring sites and three district wells that will 214 23 CCR § 354.32.
215 23 CCR § 354.34(b)(2).
216 23 CCR § 354.34(b)(3).
217 23 CCR § 354.34(c)(1)(B).
218 23 CCR §§ 354.34(g)-(h).
219 23 CCR § 354.38(d).
220 Department of Water Resources, 2016, Best Management Practices and Guidance Documents. 221 Joint GSP, Section 3.5.1, p. 281. 222 Joint GSP, Section 3.5.1, p. 282. 223 Gravelly Ford GSP, Section 3.5.1, pp. 57-58.

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Sustainable Groundwater Management Program Page 43 of 53 be monitoring the unconfined aquifer and confined aquifer respectively. 224 The Root Creek GSP states that the GSA will use the five wells in the monitoring network within the single aquifer that underlies the GSP area.
225
The Plan proposes to use groundwater levels and the groundwater level monitoring network as a proxy for the loss of groundwater in storage monitoring network because changes in groundwater storage are directly dependent on changes in groundwater levels.
226
The groundwater quality monitoring network in the Joint GSP consists of 12 monitoring sites selected from the GSP groundwater level monitoring network.227 Of these wells, two are screened in the Upper Aquifer, eight in the Lower Aquifer, and two are composite wells screened in both. 228 Additionally, two domestic wells from the Irrigated Lands Regulatory Program, and thirteen public supply wells with ongoing monitoring conducted by other entities are also part of the representative monitoring sites but the GSP does not identify which aquifers the wells are completed in.229 The Gravelly Ford GSP states groundwater quality samples will be collected from 24 wells throughout the district and the samples will be collected once a year.230 The New Stone GSP states the GSA will use the three district wells that monitor the confined aquifer.231 The Root Creek GSP states that degraded water quality will be monitored from 17 sites throughout the GSA’s area of the Subbasin which includes municipal wells, monitoring wells associated with the Riverstone wastewater treatment plant, agricultural wells used in the GSP, and wells associated with CASGEM.232 The Plan states that several agencies monitor and regulate water quality in the Subbasin and the GSAs will collect and review the data published by these agencies, which include the Regional Water Quality Control Board, Environmental Protection Agency, Department of Toxic Substance Control, Madera County, United States Geological Survey, and State Water Resources Control Board. 233
The land subsidence monitoring network in the Joint GSP is comprised of six benchmark survey points monitored by the United States Bureau of Reclamation as part of the San Joaquin River Restoration Program (SJRRP) and one continuous GPS station monitored by UNAVCO as part of the Plate Boundary Observatory Project.234 Two of the benchmark survey points are underlaid by the Corcoran Clay, where subsidence is of most concern.

Representative monitoring site 1007R, a benchmark survey point which is located on the 224 New Stone GSP, Section 5.2.1, pp. 133-134.
225 Root Creek GSP, Section 5.2.1, p. 191.
226 Joint GSP, Section 3.5.1.2, p. 286; Gravelly Ford GSP, Section 3.5, p. 59; New Stone GSP, Section

5.3.1, p. 138; Root Creek GSP, p. 196.
227 Joint GSP, Section 3.5.1.4, p. 287.
228 Joint GSP, Figure 3-2, p. 300.
229 Joint GSP, Section 3.5.1.4, p. 287. 230 Gravelly Ford GSP, Section 3.5.1, p. 58. 231 New Stone GSP, Section 5.5.1, p. 139, Figure 5-1, p. 137. 232 Root Creek GSP, Section 5.4.1, pp. 199-201. 233 Root Creek GSP, Section 5.4.1, p. 199. 234 Joint GSP (Redlined), Section 3.2.3.2, p. 279, Figure 3-10, p. 360.

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Sustainable Groundwater Management Program Page 44 of 53 western edge of the New Stone GSP area, has reported the most severe rate of recent subsidence in the Subbasin.235 The Plan states that all SJRRP and UNAVCO sites will be used to monitor for subsidence in the area and monitoring stations outside the Subbasin will be used to provide regional context. The Root Creek GSP also provides a list of subsidence monitoring done by other agencies such as USGS, DWR, USACE which will be used to verify the Plan’s monitoring network.236 The Gravelly Ford GSP subsidence monitoring program will be expanded by the district to include observations on all the 24 monitoring sites in the GSP area, at a period of three to five years, with some wells observing the Lower Aquifer.237 See Section 4.3.2 for further evaluation of the Plans sustainable management criteria and monitoring network for land subsidence.

Interconnected surface water is evaluated by monitoring groundwater levels at three wells 238 screened in the Upper Aquifer near the San Joaquin River. The Joint GSP explains the representative monitoring sites include a combination of irrigation and monitoring wells with data representing surface water-groundwater interconnection trends from 1989.
239 Streamflow data from gaging stations is also collected and will be used in future studies and evaluations of interconnected surface water, including generating data to better estimate groundwater basin conditions related to interconnected surface water240 (also see Section 4.4.2).

The description of the monitoring in the Plan substantially complies with the requirements outlined in the GSP Regulations. Overall, the Plan describes in sufficient detail a monitoring network that promotes the collection of data of sufficient quality, frequency, and distribution to characterize groundwater and related surface water conditions in the Subbasin and evaluate changing conditions that occur through Plan implementation. The GSP provides a good explanation for the conclusion that the monitoring network is supported by the best available information and data and is designed to ensure adequate coverage of sustainability indicators. The Plan also describes existing data gaps and the steps that will be taken to fill data gaps and improve the monitoring network. Department staff consider the information presented in the Plan as satisfying the general requirements of the GSP Regulations regarding monitoring networks, but also provide recommended corrective actions related to managing and monitoring land subsidence (see Recommended Corrective Action 4).
235 New Stone GSP (Redlined), Section 3.2.6.1, p. 99, Figure 5-2, p. 185. 236 Root Creek GSP (Redlined), Section 5.5.1, pp. 266-267, Section 5.5.3, p. 268. 237 Gravelly Ford GSP (Redlined), Section 3.5.1, p. 76, Section 3.5.4.2, p. 77. 238 Joint GSP (Redlined), Figure 3-4, p. 352, Section 3.5.1.5, p. 336. 239 Joint GSP (Redlined), Section 3.5.1.5, p. 336, Section 3.2.5, p. 288. 240 Joint GSP (Redlined), Section 3.5.1.5, p. 336.

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5.5 PROJECTS AND MANAGEMENT ACTIONS
The GSP Regulations require a description of the projects and management actions the GSAs have determined will achieve the sustainability goal for the basin, including projects and management actions to respond to changing conditions in the basin. 241
The Plan lays out the projects which were selected by the GSAs to achieve the Subbasin sustainability goal by 2040. 242 Generally, the projects are supply augmentation (i.e., recharge or conveyance enhancement) projects which source water from flood releases, Section 215 water, bypass flows, or water purchases. While the total cost of project implementation is not provided, the estimated costs provided in each individual GSP total to over $270,000,000 in capital costs and over $70,000,000 in annual costs; Department staff note that the GSAs have also included an estimated economic cost from reduced crop production resulting from demand management in the estimated annual operating cost, which is approximately $54,000,000 per year or over 75% of the total. 243 Many of
the projects are currently being implemented, having been initiated by past efforts, or will be implemented by 2040. The total expected benefit is 215,840 acre-feet per year244 at full implementation with the majority of the benefit deriving from a demand management program led by the Madera County GSA which will conserve 90,000 acre-feet per year.

Madera County determined that projects were unlikely to generate enough benefit to offset the estimated current and projected future overdraft conditions and decided to implement a management action to gradually reduce groundwater pumping over the GSP implementation period. 245 The demand management effort started in 2020 with 2% demand reduction per year until 2025. Starting in 2026, the demand reduction increases to a 6% reduction rate until 2040.246
Since the submission of the Plan in 2020, the GSAs have provided Annual Reports to the Department that provide updates on progress, a brief overview of these efforts from Water Year 2019 to Water Year 2022 is provided in each revised GSP. A review of the Annual Reports submitted shows progress on a majority of the projects and enhancements of monitoring networks, which now collect more land subsidence, water quality, and groundwater level data; the GSAs also report efforts being made to collect more interconnected surface water data.
247
A review of the projects presented in each GSP is provided below. 241 23 CCR § 354.44 et seq.
242 Joint GSP (Redlined), Section 4, pp. 361-431; Gravelly Ford GSP (Redlined), Section 4, pp. 83-37; Root Creek GSP (Redlined), Section 6, pp. 309-327; New Stone GSP (Redlined), Section 6, pp. 189-199. 243 Joint GSP, Table 4-3, p. 312, Section 4.4.4.5, p. 352. 244 Joint GSP, Tables 4-1 and 4-2, pp. 310-311.
245 Joint GSP, Section 4.4.4, p. 347. 246 Joint GSP, Section 4.4.4.2, p. 348. 247 Joint GSP Water Year 2022 Annual Report, Table 7-1, pp. 56-57; Gravelly Ford GSP Water Year 2022 Annual Report, Section 2.4.3, pp. 18-19; New Stone GSP Water Year 2022 Annual Report, Section 3.1.2, p. 10; Root Creek GSP Water Year 2022 Annual Report, p. 26.

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Madera Water District GSA

1. Surface Water Purchase Program
Madera Irrigation District GSA

1. Groundwater Recharge Basins

2. On-Farm Recharge (Flood-MAR)

3. Madera Irrigation District System Improvements and Programs

4. Madera Ranch Annexation
The City of Madera GSA

1. Berry Basin for groundwater recharge

2. The City of Madera Metering and Volumetric Billing program.

Madera County GSA

1. Water Purchase for Direct or In-Lieu Recharge (starts in 2025)

2. Import and Recharge of Millerton Flood Releases (Flood-MAR) (starts in 2025)

3. Chowchilla Bypass Flood Water Recharge Basins (starts in 2025)

4. Chowchilla Bypass Flood Water Recharge Basins (starts in 2040)

5. Management Action: Demand Management (starts in 2020) The Joint GSP provides an estimate for implementing projects and management actions, which totals approximately $193,460,000 in capital costs and $69,550,000 in annual operating costs.
249 As noted above, the GSAs have included an estimated economic cost from reduced crop production resulting from demand management of approximately $54,000,000 per year in the total annual cost.
250 Based on information provided in the
Joint GSP resubmittal and the 2022 Annual Report,
251 the GSA reports that a cumulative
total benefit of over 63,000 acre-feet from projects and management actions to date, with a benefit of 7,300 acre-feet for the latest reported water year for the GSP area. 252 Demand
management is described to potentially utilize a range of options including allocations, a water trading program, or easements to reduce groundwater demand. In 2022, Madera County took steps to develop a demand management study that was intended to result 248 Joint GSP (Redlined), Section 4, pp. 361-341.
249 Joint GSP (Redlined), Table 4-3, p. 366. 250 Joint GSP (Redlined), Section 4.4.4.5, p. 409. 251 Joint GSP Water Year 2022 Annual Report, Section 7.1, pp. 53-69. 252 Joint GSP Water Year 2022 Annual Report, Table 7-2, p. 58.

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Sustainable Groundwater Management Program Page 47 of 53 in an acreage-based rate for extraction of groundwater within the GSA area. However, following an injunction issued by the Madera County Superior Court in December 2022, the Madera County GSA was ordered to refrain from imposing or collecting any new fees, rates, or GSP Project Fees enacted under Madera County Resolution 2022-086 against landowners in the Madera Subbasin.
253 Nonetheless, Department staff encourage the
GSAs to continue efforts to develop and implement a successful management strategy to reduce groundwater pumping in the Subbasin, since the reduction of groundwater demand, as detailed in the Plan, is an essential part of achieving the sustainability goal for the basin. Department staff will closely monitor and track the implementation of the demand management program; delays in implementation due to litigation or funding are insufficient to justify delays in implementing demand reduction strategies that are needed to sustainably manage the basin.

The Gravelly Ford GSP254 provides details for two projects which the GSA is currently implementing:

1. Recharge Program: this project is the continuation of the recharge program established by the Gravelly Ford Water District in 1961.

2. Increased Measurement, Sampling and Monitoring: this project is to continue data collection efforts.

The Gravely Ford GSP does not provide an estimate for projects and management actions; the cost of implementing the GSP is estimated to be $961,000.255 Based on information in the 2022 Annual Report, 256 the GSA reports that a number of measurements (i.e., depth to groundwater) of private agricultural wells in the GSP area were made and the installation of measurement meters has started on those wells to increase data collection; but the GSAs were not able to discharge surface water into the existing recharge basins during the 2022 Water Year.

The New Stone GSP includes a brief description of one project that is “currently being considered by the [New Stone Water] District”257 which is the:

1. Construct Chowchilla Bypass Turnout, New Canals, and Recharge Basins (Bypass Project)
The Bypass Project is in the “conceptual phase” and implementation will “depend on the availability of land for new recharge basins [which will also determine amount of recharge] and acquiring a source of funding”; the amount of recharge will depend on acres available for recharge facilities but the district has a 15,700 acre-feet appropriative water right. 258 The estimated cost over 20-years for implementing the project is $7,800,000 but no 253 Joint GSP (Redlined), Section 4.10.5.4, p. 430.
254 Gravelly Ford GSP, Section 4, pp. 64-66.
255 Gravelly Ford GSP (Redlined), Section 5.3.1, p. 88. 256 Gravelly Ford GSP Water Year 2022 Annual Report, Section 2.4.3, p. 18-19. 257 New Stone GSP, Section 6.2, pp. 151-157. 258 New Stone GSP, Section 6.2.1.2 through 6.2.1.6, pp. 152-153.

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259 Management actions will be enacted “[i]f basin overdraft isn’t mitigated”260 and the GSP doesn’t provide related cost of implementation or schedule estimates. Based on information in the 2022 Annual Report, 261 the GSA did not provide
substantial updates on the project or management action progress for the 2022 Water Year—but the GSA did report three new wells were added to the monitoring network.

The Root Creek GSP262 includes brief descriptions of three projects:

1. Expansion of the In-Lieu Pipeline (to fully utilize surface water allocations)

2. Intentional Recharge Projects

3. Agricultural Land Conversion (Development of Riverstone)

4. Monitoring Well Program – Interconnected Surface Water The Root Creek GSP provides project cost estimates and projects 2 and 3 are currently being implemented. Additionally, though management actions are referenced, 263 no specific details are provided; the GSP references the continuation of programs that were enacted prior to SGMA related to the use and sustainable management of groundwater.264 During 2022, the GSP states, a benefit of 4,500 acre-feet was realized from projects for the GSP area.
265
The Plan adequately describes proposed projects and management actions in a manner that is generally consistent and substantially complies with the GSP Regulations.266 The projects and management actions, which focus largely on recharge or conveyance projects and demand management, are directly related to the sustainable management criteria and present a generally feasible approach to achieving the sustainability goal of the Subbasin.

As projects and management actions are implemented, the Department expects that progress be included in Annual Reports and any addition or removal of project and management actions be documented in Periodic Evaluations.

5.6 CONSIDERATION OF ADJACENT BASINS/SUBBASINS
SGMA requires the Department to “…evaluate whether a groundwater sustainability plan adversely affects the ability of an adjacent basin to implement their groundwater sustainability plan or impedes achievement of sustainability goals in an adjacent basin.”267 Furthermore, the GSP Regulations state that minimum thresholds defined in each GSP 259 New Stone GSP, Table 7-3, p. 160. 260 New Stone GSP, Section 6.3, p. 154. 261 New Stone GSP Water Year 2022 Annual Report, Section 3.1, pp. 10-11. 262 Root Creek GSP, Section 6.1 through 6.4, pp. 212-226. 263 Root Creek GSP, Table 6-1, p. 213. 264 Root Creek GSP, Section 6.5, p. 226. 265 Root Creek GSP (Redlined), Section 6.7, pp. 326-327. 266 23 CCR §§ 354.44 (a), 354.44 (b), 354.44 (c), 354.44 (d). 267 Water Code § 10733(c).

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The Madera Subbasin has three adjacent basins; the Kings Subbasin, Delta-Mendota Subbasin, and the Chowchilla Subbasin, are all high-priority and required to be managed under a GSP. The Delta-Mendota Subbasin and Chowchilla Subbasins are critically overdrafted and currently have inadequate plans which the Department has referred to the State Water Resources Control Board under Chapter 11 of SGMA. The Kings Subbasin is to the south of the Madera Subbasin bordering the south bank of the San Joaquin River. The Kings Subbasin is designated critically overdrafted and the Kings Subbasin Plan has been approved by the Department.

The Plan states that the Madera Subbasin GSAs have met multiple times with GSAs in adjacent subbasins to ensure that implementation of the Madera Subbasin GSPs will not interfere with the ability of adjacent subbasins to also achieve sustainable groundwater management; however, further details are not provided in the Plan.269 The Plan also qualitatively describes how minimum thresholds and measurable objectives may affect an adjacent basin, concluding that the Madera Subbasin Plan will not hinder the ability of an adjacent basin to be sustainable; 270 however, the evaluation is provided without specifics.

Based on information available at this time, Department staff have insufficient evidence to conclude that groundwater management in the Madera Subbasin will adversely affect the implementation of a plan or impede achievement of sustainability goals in an adjacent basin. Department staff encourage the GSAs to evaluate whether their Plan adversely affects the ability of an adjacent basin to implement their groundwater sustainability plan or impedes achievement of sustainability goals in an adjacent basin. Department staff will continue to review periodic evaluations to the Plan and Annual Reports to assess whether implementation of the Madera Subbasin GSP is likely to impact adjacent basins.

5.7 CONSIDERATION OF CLIMATE CHANGE AND FUTURE CONDITIONS The GSP Regulations require a GSA to consider future conditions and project how future water use may change due to multiple factors including climate change.271 Since the GSP was adopted and submitted, climate change conditions have advanced faster and more dramatically. It is anticipated that the hotter, dryer conditions will result in a loss of 10% of California’s water supply. As California adapts to a hotter, drier climate, GSAs should be preparing for these changing conditions as they work to sustainably manage groundwater within their jurisdictional areas. Specifically, the Department 268 23 CCR § 354.28(b)(3).
269 Joint GSP (Redlined), Executive Summary, p. 25. 270 Joint GSP (Redlined), Section 3.2.1.4, p. 277, Section 3.2.2.4, p. 278, Section 3.2.4.4, p. 285, Section

3.2.5.4, p. 291, Section 3.3.1.5, p. 304, Section 3.3.2.3, p. 309, Section 3.3.3.3, p. 312, Section 3.3.4.3, p. 318, Section 3.3.5.3, p. 319.
271 23 CCR § 354.18.

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Sustainable Groundwater Management Program Page 50 of 53 encourages the GSAs to explore how the proposed groundwater level thresholds have been established in consideration of groundwater level conditions in the Subbasin based on current and future drought conditions. The Department encourages the GSAs to also explore how groundwater level data from the existing monitoring network will be used to make progress towards sustainable management of the Subbasin given increasing aridification and effects of climate change, such as prolonged drought. Lastly, the Department encourages the GSAs to continually coordinate with the appropriate groundwater users, including but not limited to domestic well owners and state small water systems, and the appropriate overlying county jurisdictions developing drought plans and establishing local drought task forces 272 to evaluate how the GSAs’ groundwater management strategy aligns with drought planning, response, and mitigation efforts within the Subbasin.
272 Water Code § 10609.50.

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Sustainable Groundwater Management Program Page 51 of 53 6 STAFF RECOMMENDATION
Department staff believe sufficient action has been taken by the GSAs to the deficiencies identified. Department staff recommend approval of the Plan with the required and recommended corrective actions listed below. The Plan conforms with Water Code Sections 10727.2 and 10727.4 of SGMA and substantially complies with the GSP Regulations. Implementation of the Plan will likely achieve the sustainability goal for the Madera Subbasin. The GSAs have identified several areas for improvement of its Plan and Department staff concur that those items are important and should be addressed as soon as possible. Department staff have also identified additional recommended corrective actions that should be considered by the GSAs for the first periodic assessment of its GSP. Addressing these recommended corrective actions will be important to demonstrate that implementation of the Plan is likely to achieve the sustainability goal.

The recommended corrective actions include:

RECOMMENDED CORRECTIVE ACTION 1
Considering MID GSA has yet to adopt the Plan, by the first periodic evaluation, MID GSA should identify and list the specific projects and management actions that MID GSA will or may be responsible for implementing under the Revised Joint GSP and provide a parallel listing and detailed identification and discussion of the legal, contractual, or other authorities or arrangements that MID GSA is relying or will rely upon in adequately implementing the Plan including those projects or management actions to clearly demonstrate the feasibility of MID GSA implementing all projects and management actions.

RECOMMENDED CORRECTIVE ACTION 2
While the GSAs have established a framework for coordination of multiple GSPs that could serve as a basis to achieve Subbasin sustainability, it is vital that the GSAs continue their efforts to improve coordination and eliminate any remaining areas of disagreement that could delay Plan implementation or affect the likelihood of achieving sustainability.

For example, the GSA should come to a consensus regarding the data and methods utilized to develop refined future water budgets for the entire Subbasin, and agreement regarding the availability and use of more detailed data as it becomes available from each GSP area. These efforts should be done with the ultimate goal that the contents of each GSP should represent a component of a cohesive, unified Plan that will achieve the sustainability goal in the Subbasin consistent with SGMA timelines and not be an isolated document only for a specific GSP area.

RECOMMENDED CORRECTIVE ACTION 3
The GSAs should revise the GSPs to include a discussion of the relationship between the management criteria for chronic lowering of groundwater levels and the other GSP Assessment Staff Report December 21, 2023
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RECOMMENDED CORRECTIVE ACTION 4
Department staff recommend the following as it relates to land subsidence:
a. The GSAs should refine the description of undesirable results to clearly describe the significant and unreasonable conditions the GSAs are managing the Subbasin to avoid, as it relates to land subsidence. More specifically, the GSAs should reevaluate the quantitative metrics that define an undesirable result for subsidence. The reevaluation should consider localized subsidence conditions and the irreversibility of continued inelastic subsidence, especially in the area deemed of “greater subsidence concern.” This is to say that the current quantitative metrics (i.e., 75 percent of the representative monitoring sites in the Subbasin exceed threshold levels for two consecutive years across the entire Subbasin) would not minimize or avoid inelastic subsidence in the most susceptible areas of the Subbasin – predominantly in the north-northwestern portion of the Subbasin which are describe as the areas of greater subsidence concern. b. The GSAs should identify the cumulative amount of subsidence that, if exceeded, would substantially interfere with groundwater and land surface beneficial uses and users in the Subbasin. The Plan should explain how the rate and extent of any future subsidence permitted in the Subbasin may interfere with surface land uses.

The Plan should also include additional details describing measures that consider and disclose the current and potentially lasting impacts of subsidence on land uses and groundwater beneficial uses and users.

Additionally, the GSAs should provide specific details and schedule for projects or management actions that will be implemented to minimize or eliminate subsidence.

The projects or management actions must be supported by best available information and science273 and consider the level of uncertainty associated with the Subbasin.274
c. The GSAs should revise the GSPs to include a discussion of the relationship between the management criteria for land subsidence and the other sustainability indicators, including an explanation of how criteria, including interim milestones, were established to avoid undesirable results for each of the other sustainability indicators.
d. The GSAs should reevaluate or eliminate the application of the level of uncertainty as it relates to subsidence measurements according to standard professional practices. Establishment of sustainable management criteria should not allow for 273 23 CCR § 354.44 (c).
274 23 CCR § 354.44 (d).

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RECOMMENDED CORRECTIVE ACTION 5
The GSA should provide a discussion of the uncertainty concerning the hydrogeologic conceptual model and a description of hydrogeologic conceptual model data gaps.275 For example, the GSP should include revisions to identify how many wells are completed below the bottom of the Subbasin, the amount of water that is extracted from these wells, and a description of changes to groundwater storage calculations for the Subbasin based on best available information.

RECOMMENDED CORRECTIVE ACTION 6
The GSAs must provide more detailed explanation and justification regarding the selection of the sustainable management criteria for degradation of water quality.

Department staff recommend the GSAs consider and address the following:
a. The GSAs should revise the definition of undesirable results so that exceedances of minimum thresholds caused by groundwater extraction are considered in the assessment of undesirable results in the Subbasin.
b. The GSAs should provide a clear definition of what the Plan considers an undesirable result for degraded water quality by describing conditions that it would consider to be significant or unreasonable. For example, the Plan should—in addition to qualitative descriptions—quantify the specific potential effects to beneficial users and uses from undesirable results using best available data and science. This definition should be supported by information described in the basin setting, and other data or models as appropriate, as required by the GSP Regulations.
276
c. The GSAs should identify which minimum threshold values—either the MCL or existing concentration plus 20 percent—will be used at which representative monitoring sites. Also, the GSAs should justify how establishing minimum thresholds at the higher of either MCLs or existing concentrations plus 20 percent does not constitute significant and unreasonable effects as defined by the GSP (i.e., “when beneficial uses for groundwater are adversely impacted by constituent concentrations).
275 23 CCR § 354.14(b)(5). 276 23 CCR § 354.26 (b)(1).

Attachment 5
MID Letter to All GSAs
Phone (559) 673-3514
www.madera-id.org
General Manager
Thomas Greci
Assistant
General Manager
Dina Cadenazzi Nolan
Legal Counsel
John P. Kinsey
March 6, 2024
Via U.S. Mail and Email
Stephanie Anagnoson
Madera County GSA
200 W. 4
th Street, Suite 3100
Madera, CA 93637
Julia Berry
Root Creek WD GSA
P.O. Box 27950
Fresno, CA 93729
Dear Madera Subbasin GSAs,
EST. 1920
MADERA

IRRIGATION DISTRICT
12152 Road 281/ 4
Madera. CA 93637
Keith Helmuth
City of Madera GSA
205 W. Fourth Street
Madera, CA 93637
Don Roberts
Gravelly Ford WD GSA
18811 Road 27
Madera, CA 93638
Board of Directors
Division I
David Loquaci
Division 2
Tim DaSilva
Division 3
Brian Davis
Division 4
James Erickson
Division 5
Carl Janzen
Phil Janzen
Madera Water District GSA
1663 North Schnoor Avenue, #105
Madera, CA 93637
Bert Kaufmann
New Stone Water District GSA
9500 S. De Wolf
Selma, CA 93662
As you are aware, Madera Irrigation District Groundwater Sustainability Agency (MID GSA) has completed virtually all of its projects and programs outlined in the Groundwater Sustainability Plan (GSP).

The MID GSA is 16 years ahead of schedule, which equates to compounding benefits to its groundwater balance and the aquifer.

Given the status of the MID GSA projects and programs, in combination with the status of the other Madera Sub basin GSAs projects and programs ( or lack thereof) and the current mindset of others as described in the "Madera Subbasin Stakeholder Assessment", the MID GSA recommends that its participation on the 5-Year Update be on a technical basis only for required information and outreach.

The MID GSA will happily provide any data and information that is required and requested. However, most discussions and changes that will be required for the 5-Year update do not involve the MID GSA, because, again, the MID GSAs has completed its commitments ahead of schedule, significantly benefiting the aquifer. Other GSAs will have to make hard decisions and changes regarding their projects and programs as many are now multiple years behind schedule with intensifying negative effects on the aquifer. It is clear from the "Madera Sub basin Stakeholder Assessment" and other actions that some GSAs in the Madera Sub basin do not appreciate nor want MID' s input that comes from 100+ years of water management experience in Madera County.

As MID has conveyed many times before, the MID GSA will gladly participate in a Domestic Well Mitigation Program and provide funding at a rate proportionate to its overdraft in comparison to the other GSAs in the Madera Subbasin. When the other six (6) GSAs in the Madera Subbasin are ready to have those discussions, please let us know. MID is also always willing to participate in other joint programs that will benefit the Madera Subbasin.

As those individuals who live in the Madera Subbasin and will feel the results of the actions/inactions of the GSAs, we truly wish success of the GSAs. We hope that this 5-Year Update gives GSAs a chance to reflect on their progress and their capabilities to hopefully make informed, realistic decisions for the future that can be successfully accomplished.

The MID GSA is even willing to take further actions to effectuate this ambitious thinking. Although the Revised Joint Groundwater Sustainability Plan for the Madera Subbasin is flawed and does not reflect reality, the MID GSA is agreeable to approve the Revised Joint Groundwater Sustainability Plan in an effort to ease the process amongst the GSAs and State of California. Additionally, because the County has repeatedly used MID’s SGMA lawsuit as justification for its lack of meaningful progress, MID has conveyed its willingness to drop its lawsuit against Madera County, Case No. MCV086277. MID has conveyed this to Madera County but has yet to receive a response.

MID and the MID GSA sincerely hope that these actions remove all perceived roadblocks and encumbrances, and that other GSAs in the Madera Subbasin can finally make real progress on the implementation projects and programs they committed to over four (4) years ago.

Sincerely,
J%nes Enckson Carl Janzen
Pre31dent Vice President f hair W/>
Tim DaSilva Brian Davis
Director Director
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REPORT TO CITY COUNCIL
Approved by: Council Meeting of: April 3, 2024
Agenda Number: ___________
________________________________
Joseph Hebert, Parks & Community Services Director
_________________________________
Arnoldo Rodriguez, City Manager
SUBJECT:

Madera Municipal Golf Course Update 2024
RECOMMENDATION:

City Council to receive an information report on the status of the Madera Municipal Golf Course and provide direction as appropriate
SUMMARY:

During the June 21, 2023, City Council meeting, Council approved a Ninth Amendment to the Madera Municipal Golf Course and Management Lease Agreement with SGM Inc. dba Sierra Golf Management, Inc. (SGM). This amendment extended the existing lease agreement by an additional five years through June 30, 2028, ensuring the continued partnership in the management of the Madera Municipal Golf Course.

SGM has provided an update to staff, recapping 2023 and updating on what is new for 2024 at the Golf Course.

DISCUSSION:

The following text in italics provides highlights as provided by SGM.

Long-time golf professional Ron Goering has moved on to another facility leaving the way for a new manager and former assistant Tanner Matteson to take over as Head Golf Professional. He brings a fresh set of eyes and newer practices to lead the golf course through the coming years. Tanner has worked in the golf industry for 12 years in both the private and public sectors of the industry. Tanner's knowledge of golf and SGM policy and E-3
procedures will continue to help create a lasting experience for residents and guests in the years to come.

Golf remained strong through 2023 with only a slight correction from the Covid push that all golf courses received in 2020.
 Rounds played in 2023: 36,068
 Rounds played in 2022: 34,955
 Rounds played in 2021: 35,188
Golf continues to gain in popularity in many segments of the population. This is a national trend and Madera Municipal Golf Course is following right along. New marketing strategies have shown that we can stay in the eye of our residents and guests while offering them an experience that is tough to beat for the condition and price of the facility.

Even with the harsh winter in early 2023, the golf course saw the play increase and continue to be strong which benefits both SGM and the City of Madera. 2023 - Golf Course Conditions
Superintendent, Jeremy Jordan, has done a superb job with course conditions and building a solid team of maintenance employees. Just like all businesses in California, one of the biggest challenges is human resources and finding employees who are not only qualified but willing to work. We continue to increase wages and find new ways to incentivize employees. Now that we have entered into a new agreement with the City this will allow us to hire better employees knowing that there is a longer timeline.

In 2023 we had excessive rainfall in the early part of the year which translated to snowpack in the Sierras. This was a gift that enabled the Madera Irrigation District the ability to fill the water feature between the 5th and 6th hole which has sat empty through many years of drought. We also were able to use surface water from the district throughout the entire irrigation season which meant we were not pumping groundwater from our wells to fill ponds and irrigate.

In 2023 we had the USGA visit the golf course and give recommendations on course playability and turf health. One of our major issues was weed infestation and a lack of proper pre-emergents being applied. We have increased our annual chemical budget and at the time of this report, we have made 2 chemical applications with a 3rd coming in the next week.

As always, this time of year our thoughts turn to our water needs. At the time of this report, we do not have a percentage, price, or amount allocated to us yet, but early indications are that we will be receiving district water for our irrigation needs. 2023 - Food and Beverage
In early 2023 we entered into a sublease agreement with Sugar Pine Smokehouse (Sugar Pine) that has benefited not only the golf course but the community, as their beloved local eatery found a new home at the golf course. They have done a great job of creating a community feeling around the course with outside events and entertainment for the residents of Madera. Sugar Pine came in and invested time and money into getting the building where it needs to be to be successful. Some of the projects they tackled:

 Air conditioning units
 Walk-in coolers and kitchen appliances
 Fixed bathroom plumbing and refreshed the restrooms.
 Added new patio furniture.

Sugar Pine has become a great partner for SGM and the City of Madera here at the golf course. We look forward to seeing them succeed with us as we make the Madera Municipal Golf Course a great experience for all Madera residents and out-of-town guests.

SGM 2024 Upcoming News
 Non-Golf Event – Farm Show on the driving range
 Remodel of restrooms
 Central heating to control room temperature for guests and community members  USGA site
Golf Course Maintenance and Operations Progress
In addition to the broader initiatives outlined in this report, it is important to highlight the significant progress made internally towards the maintenance and operations of the golf course during Fiscal Year 2023/2024. The following achievements underscore our commitment to enhancing recreational amenities for our residents:
 Golf Course Advisory Committee Inauguration: Parks & Community Services Director, Joseph Hebert, serves as one of the City-appointed representatives on the Golf Course Advisory Committee. Under his leadership, the committee held its inaugural monthly meeting on August 21, 2023, marking a pivotal step towards collaborative decisionmaking and strategic planning.  Employee Appreciation Day: The city proudly utilized the golf course as a venue for an Employee Appreciation Day, demonstrating our commitment to fostering a positive work environment and recognizing the contributions of hardworking city employees.  Financial Support: The city received $50,000 from SGM and Sugar Pine, with each party contributing $25,000 towards a capital improvement fund. These funds play a vital role in ensuring the continued enhancement and sustainability of the golf course facilities.  Debt Reduction: A final payment of approximately $164,000 was made towards the city's construction of the golf course financed debt, reflecting our steadfast dedication to fiscal responsibility and prudent financial management.
 As a significant milestone, the city officially assumed ownership of the golf course, with the exception of an annual payment of approximately $64,000 to the Airport. This payment is made in recognition of a portion of the golf course being property owned by the Airport.

City 2024 Upcoming
 New Contract Document
 City hosted 4th of July Golf Tournament
 City hosted Fishing Derby events
FINANCIAL IMPACT:

This is an informational report only. No financial impact is associated with the presentation of this information.

ALTERNATIVES:

This report is for informational purposes only.

ATTACHMENTS:

None.

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