STATE OF CALIFORNIA | GAVIN NEWSOM, GOVERNOR | CALIFORNIA NATURAL RESOURCES AGENCY with loss of access and propose potential new monitoring sites. However, staff have noted that ten sites from the current monitoring network have not had a successful measurement in several years due to repeated inaccessibility or destruction, as documented in the reports. Despite not having measurements for several years, these monitoring sites have not been replaced. Department staff request:
• The GSAs either provide the missing information, if available, or provide an analysis of the level of uncertainty created in developing a detailed understanding of groundwater conditions given that measurements for most of the monitoring networks were not collected. Further, the GSAs should explain how future monitoring efforts will either collect data from each of the representative monitoring sites or identify replacement locations where data will be collected.
2. Additional Information Related to Progress Toward Implementing the Plans Based on the measurements that have been collected, minimum thresholds are being exceeded at over 85% of measured wells (6 of 7) in the Upper Aquifer and over 90% of measured wells (15 of 16) in the Lower Aquifer. Staff note that measurements provided for the spring in 2023—which represents a seasonal high for groundwater elevations—are also below established minimum thresholds for three monitoring sites.
While the planned exceedance of minimum thresholds via interim milestones for a temporary period to allow necessary projects and management actions to be developed and implemented has been evaluated and approved by the Department, it is critical the GSAs show actual progress towards implementing those activities and mitigating overdraft. The GSAs have not provided details demonstrating actual progress toward implementing the Plans to address these exceedances. A key management action planned by the GSAs—titled Demand Management—is anticipated to provide over 40% of the demand reduction required (90,000 acre-feet per) in the Subbasin by 2040. The annual reports document that management action has provided no benefit to date despite the expectation that the quantifiable benefit would start in 2020 and increase by 2% (of the total demand reduction amount) annually, for a total cumulative reduction of 10% by 2025. Given the lack of progress to date, it is unclear how the GSAs will reduce groundwater pumping by the proposed 6% per year rate starting in 2026 as anticipated in the Plans to mitigate the ongoing overdraft and raise water levels to minimum threshold levels. Department staff request:
• The GSAs provide a clear and concise explanation of current groundwater conditions, which include how many minimum threshold and interim milestone exceedances are present in the Subbasin and whether they constitute undesirable results.
• The GSAs provide an update to the suite of feasible projects and management actions to mitigate current levels of overdraft in the Subbasin and are likely to DocuSign Envelope ID: 91189903-AB04-463D-9E2A-47993E8CF538
STATE OF CALIFORNIA | GAVIN NEWSOM, GOVERNOR | CALIFORNIA NATURAL RESOURCES AGENCY achieve the sustainability goal for the Subbasin and allow water levels to stabilize and recover to minimum thresholds levels by 2040.
3. Additional Information Related to Effects to Beneficial Uses and Users of Groundwater
The Department’s Dry Well Reporting System received 37 reports of wells going dry during water year 2023 in the Madera Subbasin. However, the annual reports do not mention this and completely lack a discussion of reported effects to beneficial uses and users, property interests, or well infrastructure as groundwater levels continue to decline. Staff believe documenting the effects occurring in the basin, especially wells going dry, is required to effectively implement the planned well mitigation program and demonstrate progress towards implementing the Plans, including achieving interim milestones.
• The GSAs provide a description of the effects to beneficial uses and users, property interests, and well infrastructure that occurred during water year 2023 due to groundwater conditions. This should include a comparison of the observed dry wells to the anticipated level of impact on domestic and municipal wells used to develop estimates in the GSPs and the mitigation plan. The GSAs should also describe how the GSAs are coordinating with these users to manage the Subbasin to avoid significant and unreasonable conditions.
The GSAs should provide additional information to the Department in the upcoming periodic evaluation (required to be submitted before January 31, 2025) and future annual reports. Failure to provide additional information requested may prevent the Department from concluding that the Plans are being implemented in a manner that will likely achieve the sustainability goal for the basin, which may result in the Plans being found inadequate and referred to the State Water Resources Control Board.
A few other minor issues were noted during the review that should be addressed in future annual report submittals including:
• The data submitted to the SGMA Portal needs to be aggregated for the entire basin, rather than separate data submittals for each GSA. • The basin point of contact should submit one annual report for the entire Subbasin each year with the additional GSA specific information included as appendices, as necessary. The one coordinated annual report should document the aggregated data for the entire Subbasin that was submitted to the SGMA Portal while also presenting the GSA-specific data and information in tabular form.
DocuSign Envelope ID: 91189903-AB04-463D-9E2A-47993E8CF538
STATE OF CALIFORNIA | GAVIN NEWSOM, GOVERNOR | CALIFORNIA NATURAL RESOURCES AGENCY Please contact the assigned DWR basin point-of-contact or [email protected] if you have questions about this notice or the annual reporting process. The Department looks forward to receiving your Water Year 2024 Annual Report by April 1, 2025.
Thank You,
Paul Gosselin
Deputy Director
Sustainable Groundwater Management
DocuSign Envelope ID: 91189903-AB04-463D-9E2A-47993E8CF538 p tWl bbSSWIA,