shown and likely could not be seen due to the small size of the cross section. Cross sections don't show the three zones within the principal aquifer, except by association with the formations. Model Section D-D' is equivalent to GSP Section C-C' and D-D' shows the Corcoran Clay.
The Corcoran Clay is shown on southern end (7 miles) of Section E-E' but not at the southern end of Section D-D'. According to DWR (1981/2008), the top of the Corcoran Clay cannot be delineated to the east of Highway 99 at Manteca, but Section E-E' is located further east of Highway 99 and would not encounter the clay until several miles further south of the subbasin boundary. Moreover, the depth to the top might be 200 feet on the west side of Manteca, south of Highway 120, which is within the southernmost alignment of Section D-D'.
The presence of the Corcoran Clay appears to be more related to the DWR model of the Central Valley than to well logs.
For the 11 x 17" print, that's 0.01 to 0.12 inches,
and 0.01 inches at 0.06 to 0.07 inches below the land surface, and is not shown on the sections.
What about a bullet for hydraulic conductivity values for each zone to match the other aquifer parameters?
The eastern side of the sections show 1,500 feet and nearly 2,100 feet, respectively, of sedimentary formations without presenting an explanation. Section A-A' shows these formations thinning eastward on top of bedrock. Sections B-B' and C-C' suggest a substantial aquifer further east and the model sections show similar conditions. This thick eastern boundary is not discussed in the text and will produce a high-end bias for the estimate of groundwater storage which could lead to the false sense of sustainability. 5 of 14
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GEI on behalf of
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Cosumnes Subbasin
2- 42
2.1.9.1.3 Deep Zone
As depicted on the hydrogeologic crosssections A-A’ through E-E’ (refer to Figure 2-20, Figure 2-21, and Figure 2-
22), boring logs indicate a significant 30-
foot thick gravel encountered at a depth
from 140 to 170 feet.
45 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 43
2.1.9.1.4 Limited Aquitards
The Corcoran Clay member of the
Turlock Lake Tulare Formation and other
interbedded clay/silts are aquitards that
inhibit groundwater flow. The Corcoran
Clay (found at the base of the upper unit
of the Turlock Formation) is present at a
depth of about 200 feet bgs.
See comments above.
Text on page 2-29 says Corcoran Clay is associated with the Laguna Formation and/or occurs between the Laguna and Mehrten Formations. As shown on Section E-E', the top of Corcoran Clay is ~140 feet and the thickness is ~70 feet at the basin boundary. 46 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 43
2.1.9.1.4 Limited Aquitards
The cross-sections (Figure 2-20, Figure 2-
21, and Figure 2-22) show both the clay
and silt horizons range in thickness from
less than 10 feet to over 150 feet.
For the 11 x 17" print, that's 0.004 to 0.06 inches
47 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 45
2.1.9.2 Aquifer Characteristics
and Groundwater Quality
The thickest sand and gravel sequences
ranged from 500 to 700 feet in the
foothills located near the Stanislaus River
Dry Creek, south of Woodward
Camanche Reservoir and Northeast of
Oakdale.
Camanche Reservoir is located at the northeastern corner of the subbasin and Oakdale is located at the southeastern corner, ~30 miles apart.
48 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 45
Production Zone is new subdivision to the Principal Aquifer. How does it relate to the Shallow, Intermediate and Deep Zones?
49 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 48 SY values range from 4 to 10 percent. Page 2-42 said "Storage coefficients up to 17 percent" for the shallow zone, which should have referred to the specific yield.
50 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 48
Table 2-4
Wells within WaterBearing ZonesWhy was Intermediate and Deep Zones combined? 51 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 50
2.1.9.2.3.1 Geologic Formation
Water Quality
The Ione formation, for instance, is
known to have high sulfate levels in
groundwater related to the pH influence
on pyrite-sulfide rich coal deposits..
The oxidation of pyrite and other sulfide minerals would produce sulfuric acid which would manifest as a lower pH.
52 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 50
Sources of arsenic include weathering of
minerals containing arsenic, desorption
of arsenic under certain pH values, and
release of arsenic in redox conditions
What type of conditions since redox is an abbreviation for reduced versus oxidized conditions - oxygen absent versus oxygen present?
For the 11 x 17" print, that's 0.01 to 0.12 inches,
and 0.01 inches at 0.06 to 0.07 inches below the land surface, and is not shown on the sections.
What about a bullet for hydraulic conductivity values for each zone to match the other aquifer parameters?
2.1.9.2.1 Aquifer Parameters and
Production Zone Well
Capacities
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2- 50
Another element of great importance is
nitrogen, as it is included in many
compounds that are by-products of
agriculture …
The focus of this paragraph is odd. The atmosphere is comprised of 78% nitrogen and the soils and underlying rock in the upland watersheds appears to absorb and store nitrogen. The real important issue is the occurrence of nitrate in the subbasin. How much nitrate occurs in the Mokelumne River (and other rivers) as that surface water enters the subbasin? Why is nitrate omitted from the list of anions in the next paragraph? Why wasn't a box-and-whisker diagram prepared for nitrate to show its variations between 2005 and 2017? 54 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 56
2.1.10 HCM Data Gaps
• Water quality of three zones in
principal aquifers
55 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 57 Groundwater Level Data
• Additional groundwater level data near
major creeks and rivers such as the
Mokelumne River to improve
quantification and understanding of
subsurface flows between subbasins and
for surface water-groundwater
interactions
56 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 57 Subsurface Conditions
• Further definition of aquifer
characteristics (e.g., hydraulic
conductivity, transmissivity, and storage
parameters) within and near Subbasin
boundary areas to the east, southeast,
north and northwest, including aquifer
tests
Why east side of basin, which is bedrock in the foothills of the Sierra Nevada mountains? More attention is needed along the boundary with the Cosumnes and South American Subbasins to the north.
57 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 60
Figure 2-34: Hydrographs
of Selected Wells
SGMA requires the same datum and scaling for hydrographs (to the extent possible). The 10 hydrographs use different horizontal and vertical scales. The horizontal scales varied from starting years between 1950 and 1973 and the ending years between 2014 and 2017 which produced a span of 43 to 67 years. The span of the vertical scales varied between 18 and 180 years.
What are the depths of these 10 wells?
What zones do these wells represent?
Why weren't wells 04N08E06C002 and 04N05E10K001 identified as representative monitoring wells, given their proximal location to the northern boundary of the subbasin? 58 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 62
Figure 2-35: Groundwater
Elevations 1940-2018, (a)
Box-and Whisker Plot
with Precipitation
Difficult plot due to overlapping lines. Change to scale of the second vertical axis to shift the precipitation line above the box-and-whiskers. Average annual precipitation line is not provided, as stated in third note.
What about showing the water year type?
59 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 64
2.2.1.2 Current Groundwater
Elevations
Why are 2016 data omitted from current conditions?
Historical data are 1996 to 2015. Current data are only 2017? 60 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 67
2.2.1.2.1 Vertical Gradients
A downward gradient is one where
groundwater is moving downward could
move deeper through the subsurface if
the vertical hydraulic conductivity allows
the movement.
Vertical gradients only show potential for groundwater flow. An aquitard would prevent that vertical flow.
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GEI on behalf of
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Cosumnes Subbasin
2- 67
At present, USGS nested monitoring
wells confirm downward vertical flows
gradient (Williamson, 1989).
62 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 69
Figures 2-40 to 2-49:
Nested Well Hydrographs
SGMA requires the same datum and scaling for hydrographs (to the extent possible). The 10 hydrographs use different horizontal and vertical scales. Use of the scales would allow the magnitude of the gradients to be evident between locations and allow comparison of the record of data.
63 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 74
2.2.2 Groundwater Storage
In 2015, the total fresh groundwater
storage was estimated as 53.0 MAF and
the cumulative change in storage over
1995-2015 was estimated as -0.91 MAF (-
0.09%), or -0.05 MAF/yr.
Figure 2-50 is not effective at showing anything - just a big blue rectangle with a slightly irregularly top
'-0.91 / 53 *100 = -1.7%
Reduction in storage really only began in 2008 when the value became negative and stay negative thereafter. The average change in storage would be -0.11 MAF/yr for that 8-year period.
64 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 80
Table 2-5: Summary of
Chloride Data by Decade
Table 2-5 shows occurrence of chloride
measurements greater than 250 mg/L by
decade.
65 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 80
Table 2-6: Summary of
Chloride Data by Depth
(1940s-2010s)
Table 2-6 shows occurrence of chloride
measurements greater than 250 mg/L by
well depth.
66 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 82 Chloride data
Approximately 4,600 of the almost
13,000 chloride measurements in the
Eastern San Joaquin Subbasin are from
wells lacking any construction or screen
depth information. Roughly half of the
measurements above 250 mg/L occur in
the wells lacking depth data, which also
show the highest range in values
occurring above 250 mg/L.
Table 2.6 shows that 3,566 samples out of a total of 6,931 samples lack depth data but these data are not limited to only concentrations greater than 250 mg/L.
The no-depth well group does have the highest range but the 100-foot well group has a much higher median value, a higher minimum, and a comparable average relative to the no-depth well group.
67 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 82
2.2.4.1.2 Total Dissolved Solids
TDS, which is a measure of all inorganic
and organic substances present in a
liquid in molecular, ionized, or colloidal
suspended form, is commonly used to
measure salinity.
According to the USGS (Hem, 1985), "Organic matter, if present, may be partly volatile, but it is not completely removed unless the residue is strongly ignited." 68 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 85
Figure 2-57: Maximum
TDS Concentrations in
Shallow Wells 2015-2018
Figure explanation says shallow wells are less than 200 feet but Table 2.7 show depth ranges of 0-100', 100-250', 250-500', and >500', which is not consistent.
How do the depth intervals relate to the zones in the principal aquifer? 69 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 85
Figure 2-58: Maximum
TDS Concentrations in
Deep Wells 2015-2018
Figure explanation says deep wells are greater than 200 feet.
What about intermediate wells?
Vertical gradients only show potential for groundwater flow. An aquitard would prevent that vertical flow.
The table shows that minimum, average, and median values are all less than 250 mg/L.
How do the depth intervals relate to the zones in the principal aquifer? 8 of 14
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GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 95
Table 2-10: MCLs for
Common Petroleum
Hydrocarbons and MTBE
Why are the units for xylene mg/L when the other organics are ug/L? The change seems disingenuous.
71 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 96
Table 2-11: MCLs for
Common Synthetic
Organic Constituents
TCE: Used as a solvent in manufacturing
facilities and dry cleaners
PCE: Used as a solvent in at dry cleaners,
manufacturing facilities, printing shops,
and auto repair facilities
TCE may have been used early in the dry cleaning industry but dry cleaners seem to be the dominant source for PCE plumes.
72 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 101
Figure 2-67: Natural
Communities Commonly
Associated with
Groundwater (NCCAG)
Dark subbasin boundary line obscures the color-coded lines 73 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 109
2.3.3 Use of the ESJWRM
and Associated Data in
Water Budget
Development
Historical Water Budget was established for 20 years (WY 1996 to 2015).
Projected Water Budget was produced for the implementation period, starting in 2020, based on a 50-year previous hydrology (1969 to 2018).
Why is Current Water Budget based on a 50-year period (1969 to 2018) when SGMA requires the use of "the most recent hydrology, water supply, water demand, and land use information."?
I'm thinking a Current Water Budget would be for 2016 and 2017 (maybe 2018) to be consistent with Section 2.2.1.2 - Current Groundwater Elevations.
74 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 110
Table 2-12: Summary of
Water Budget
Assumptions (Historical,
Current, and Projected
Periods)
Hydrologic Years: 50-year period for Current Water Budget is not consistent with SGMA requirement.
All other entries say current and refer to recent information - no the past 50 years.
Note 3 refers to "pre-drought level (assumed water year 2013)". WY 2013 was a critical WY. 75 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 112
2.3.4.2 Assumptions Used
in the Current Water
Budget
The 50-year period is not consistent with SGMA requirement. 76 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 115
2.3.5 Water Budget
Estimates
Land Surface System, Inflows: Riparian
intake from streams
Riparian intake from streams is evapotranspiration outflow from the stream system. How can it also be an inflow?
77 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 121
Table 2-15: Average
Annual Water Budget –
Groundwater System
The proportions of water in the budgets don't vary more than a few percentage point which is likely due to the long-term overlapping periods of data. See previous comments on the use of a 50-year period for current conditions.
Totals for main categories of inflow and outflow don't match table totals (due to rounding [?]).
Tables 2-13 and 2-14 may exhibit similar discrepancies. 78 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Figures 2-72 to 2-80
Magnitude of average annual volumes would be more easily perceived if the vertical scale was the same for each plot.
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79 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 126
Table 2-16: Average
Annual Values for Key
Components of Historical
Water Budget by Year
Type
Above Normal (AN) and
Below Normal (BN) columns How can the average of three AN years be less than one BN year? Is math correct? 80 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 130
2.3.5.4 Projected Water Budget
Estimates
Section needs a figure for projected groundwater budget similar to the historical conditions of 1996 to 2015 (Figure 2-51) and for climate change (Figure 2-102).
What about groundwater budget information for Wys 2016, 2017, and 2018? 81 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 133
2.3.6 Sustainable Yield
Estimate
In order to account for the challenges of
implementing the GSP, this Plan assumes
future operations would remain
consistent for a 25-year period and
groundwater levels would continue to
decline until 2040.
This statement actually implies that groundwater levels will decline until 2045 (2020 + 25 = 2045), which would not be consistent with SGMA's prohibition of "chronic lowering of groundwater levels" which would continue to cause groundwater to flow from the adjacent subbasins and limit their ability to achieve sustainable management, unless ESJ successfully implements all of their projects and management actions. 82 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 134
The sustainable conditions scenario
results in groundwater outflows almost
equal to groundwater inflows, bringing
the long-term (50-year) average change
in groundwater storage to close to zero.
Based on this analysis, the sustainable
yield of the basin is 715,000 AF/year ± 10
percent.
83 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 134
In order to achieve a net-zero change in
groundwater storage over a 50-year
planning period, approximately 78,000
AF/year of direct or in lieu groundwater
recharge and/or reduction in agricultural
and urban groundwater pumping would
need to be implemented in the Eastern
San Joaquin Subbasin.
84 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 138
Figure 2-82: Dry Creek
Hydrograph
Why is a 54-year period (1964 to 2018) used in the projection when the previous text referred to a 50-year period (1696 to 2018)? Shouldn't the time scale be 2020 to 2070 or Year 1 to 50, beginning in 2020?
Same questions for Figures 2-84, 2-86, 2-88, and 2-90.
85 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
2- 148
2.3.7.4 Eastern San
Joaquin Water Budget
Under Climate Change
With a similar surface water supply and
increased water demands under the
climate change scenario, private
groundwater production is simulated to
increase approximately 11 percent, from
801,000 AF/year to 887,000 AF/year.
Does municipal groundwater pumping increase to total?
Does this 50-year average approach really support operations within this sustainable yield within the 20-year planning and implementation horizon? The sustainable yield would appear to range from 643,000 AF/yr to 715,000 AF/yr to 787,000 AF/yr. Table 2-17 says the 50-year total groundwater supply is 801,000 AF/yr, which is 86,000 AF/yr greater than the sustainable yield. Text on page 2-148 also refers to 801,000 AF/yr as private groundwater production.
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GEI on behalf of
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Cosumnes Subbasin
2- 151
Figure 2-102:
Groundwater Budget –
Climate Change Scenario
Cumulative change in groundwater storage continues to decline for the 50-year period which is not consistent with the SGMA prohibition of reduction in groundwater storage. 87 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
3- 6
Figure 3-2: Location of
Representative
Monitoring Wells for
Groundwater Levels
Groundwater along the northern boundary are monitored by two shallow CASGEM wells (Wells 04N07E20H003 and 04N05E24J003) that are 3.3 to 4.2 miles south of the Cosumnes Subbasin.
These wells are located ~8 miles apart along the 26-mile E-W subbasin boundary (excludes 4- mile N-S boundary with Amador County).
Additional monitoring wells should be installed along to the boundary to cover the entire length, including deeper wells, to better define cross boundary flow, vertical gradients, and the surface water-groundwater interaction.
88 89
Rodney
Fricke
The MT for well 04N07E20H003 was confirmed at -81.7 feet MSL by the GSP methodology, but the MT (-31.2 feet MSL) for well 04N05E24J003 was found to be lower by 1.4 feet or -29.8 feet MSL. Appendix 3-A shows a 25-foot buffer compared to the 23.6-foot buffer derived from the difference between the highest and lowest values. The MOs were confirmed for the two wells (Table 3-2).
Use of these management criteria will further reduce groundwater levels and storage along the northern boundary of the subbasin and cause groundwater from the Cosumnes Subbasin to flow into the ESJ Subbasin due to this generous management criteria. Recent groundwater levels (Mar/Apr-19) are 13 and 17 feet above their respective MOs and 58 and 41 feet above their respective MTs (Wells 04N07E20H003 and 04N05E24J003). Use of this criteria will allow the further lowering of groundwater levels and the reduction in storage, which will cause additional groundwater flow from the Cosumnes Subbasin, especially during a long-term period of drought.
Note that the method for establishing the MT buffer is somewhat different for each well, which adds a bias to values. For well 04N07E20H003, the buffer was based on the difference between the highest groundwater level (WL), which occurred during Mar-84 (during an above normal [AN] WY, following the wettest WY on record and a wetter AN WY), and the lowest WL during Oct-16. For well 04N05E24J004, the highest and lowest WLs occurred during Mar-97 and Oct15, respectively. The historical water budget period was established for 1996 to 2015, so the highest and lowest WLs should be restricted to that period (See attached Figures 1 & 2). In addition, Appendix 3-B provides hydrographs with MT and MO lines for a date range beginning in 1990.
This uniform criteria should be applied to all representative WL monitoring wells.
Table 3-1: Minimum
Thresholds for Chronic
Lowering of Groundwater
Levels
3- 7
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Cosumnes Subbasin
3- 9
Table 3-3: Interim
Milestones for Chronic
Lowering of Groundwater
Levels
Current groundwater levels (WL) are set at values for Fall 2015.
For well 04N05E24J004, the "current" WL, MO, and all interim milestones are -6.2 feet MSL. The WL declined further in fall 2016 to -4.2 feet MSL and then varied from 6.3 feet MSL in fall 2017 and 3.3 feet MSL in fall 2018.
For well 04N07E20H003, the "current" WL was -35.5 feet MSL, just above the MO of -36.7 feet MSL, and the first two interim milestones equal -35.5 feet MSL ("current WL") and the third milestone allowed a WL decline to -36.1 feet MSL. The WLs declined during the fall 2016 to -
36.7 feet MSL (MO) and then rose thereafter to -32.8 feet MSL during fall 2017 and -31.4 feet MSL during fall 2018.
91 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
3- 10
3.2.2 Reduction in
Groundwater Storage
3.2.2.1.1 Description of Undesirable Results
DWR has classified the ESJ Subbasin as overdrafted.
The text does not provide a direct rebuttal to this classification or address the contributions of groundwater from the adjacent subbasins which should be an undesirable result of overpumping.
92 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
3- 11
3.2.2.2 Minimum Thresholds
The text does not address the contributions of groundwater from the adjacent subbasins which should be an undesirable result of overpumping. How much groundwater would move into the ESJ Subbasin from adjacent subbasins if the storage were reduced by 1.2 MAF to down to 30 MAF?
93 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
3- 14
Table 3-4: Interim
Milestones for Degraded
Water Quality
The measurable objective for TDS is 600 mg/L - the recommended secondary MCL plus a 100- mg/L buffer. TDS currently ranges from 280 to 510 mg/L (average: 370 mg/L) at the 10 representative monitoring wells. The interim milestones allow incremental increases of TDS over the 20-year period, ranging from 5 to 29 percent (average: 15%), where lower-TDS wells have greater increments and higher-TDS wells have lower increments.
This approach appears to encourage the degradation of water quality as an objective. 94 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
3- 18
3.2.5 Land Subsidence
3.2.5.2 Minimum Thresholds
Further, the use of groundwater levels as
a proxy is necessary, given the lack of
direct monitoring for land subsidence in
the Subbasin.
The text fails to acknowledge the continuous GPS station (P309 - Linden) in the subbasin and the 5 other stations in adjacent subbasins, which be used to interpolate subsidence within the subbasin. Additional GSP stations could be installed in the subbasin. 95 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
4- 8
4.3 MONITORING
NETWORKS FOR
DEGRADED WATER
QUALITY
Monitoring networks monitoring for
water quality will test for total dissolved
solids (TDS), cations and anions, arsenic,
and field parameters including pH,
electrical conductivity (EC), and
temperature.
Anions should include nitrate as well as bicarbonate & carbonate, chloride, and sulfate. 96 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
4- 14
4.3.5 Spatial Density of
Groundwater Quality
Monitoring Wells
DWR’s Monitoring Networks and
Identification of Data Gaps BMP states
“The spatial distribution must be
adequate to map or supplement
mapping of known contaminants” (CA
DWR, 201610b).
Make appropriate revision in Section 8, page 8-6
97 Rodney
Fricke
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Sacramento County GSA -
Cosumnes Subbasin
6- 1
6.2.1 Project Identification
• Project is affordable and costeeffective (highest lowest unit cost per volume water savings)
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Eastern San Joaquin Subbasin GSP Public Draft July 2019 Cosumnes Subbasin Public Comments submitted via e-mail to [email protected] Comment
# Commenter
Commenter
Organization
Section
&
Page
Number
Section, Figure, or
Table Number or Topic Sentence Starts with, "… Comment
98 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
6- 34
6.3 MANAGEMENT ACTIONS
Additional management activities are
discussed in Chapter 7: Plan
Implementation, including:
All of these activities are required by SGMA so they aren't really management actions (reduced pumping, fallowing, … ) as intended by SGMA
99 Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
7- 4
Table 7-2: Costs to GSAs
and GSP Implementation
Costs
100
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Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
7- 7
7.6 DEVELOPING 5-YEAR
EVALUATION REPORTS
101
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Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
7- 5
7.3.1 Monitoring
Components of the annual monitoring
program costs include:
Won't the field crew and their equipment be used for sampling ($57K to $60K) and sampling costs are really laboratory costs ($24K to $30K)?
Will CASGEM continue to exist after full implementation of SGMA? 102
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
7- 8
7.6.3 Reconsideration of GSP
Elements
The water year types from the San
Joaquin Valley Water Year Hydrologic
Classification used in this Plan are based
on stream inflows from a variety of
streams in the San Joaquin Valley. In the
future, a more locally-relevant index may
be developed that would be more
representative of conditions specific to
the Subbasin.
Why waste resources on a new index when a 118-year index is already available for the San Joaquin Valley?
(Sacramento Valley index is 113 years long and is mostly consistent with the San Joaquin Valley index.)
103
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
ES- 3
ES-5.
EXISTING
GROUNDWATER
CONDITIONS
104
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Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
ES- 3
ES-5.
EXISTING
GROUNDWATER
CONDITIONS
Interconnected surface waters are
surface water features that are
hydraulically connected by a saturated
zone to the groundwater system. If the
water table adjacent to a river or stream
goes down as a result of groundwater
pumping, the river or stream may “lose”
water to the underlying aquifer.
Replace with:
Surface waters can be hydraulically interconnected to the groundwater system, where the baseflow is derived from the aquifer (gaining stream) or the stream can lose surface water to the aquifer. If the water table beneath the stream goes down excessively as a result of groundwater pumping, the stream may disconnect from the underlying aquifer. 105
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
ES- 9
ES-10.
PROJECTS AND
MANAGEMENT ACTIONS
Additional management activities
included in the Draft GSP include the
following:
All of these activities are required by SGMA so they aren't really management actions (reduced pumping, fallowing, … ) as intended by SGMA
Developing 5-Year Evaluation Reports:
$800,000 - $2,000,000 every 5 years
$0.8M to $2.0M is quite excessive, as if the GSP will be done over.
Annual reports will provide a significant foundation for the 5-year evaluation and the cost might be only $200K to $300K - hopefully a lot less.
Other costs should be reviewed closely to ensure reasonableness.
California has three secondary maximum contaminant level (SMCL) standards for TDS, all based on aesthetic considerations such as taste and odor, not public health concerns. These are 500 mg/L (recommended limit), 1,000 mg/L (upper limit), and 1,500 2,500 mg/L (shortterm limit). 13 of 14
Eastern San Joaquin Subbasin GSP Public Draft July 2019 Cosumnes Subbasin Public Comments submitted via e-mail to [email protected] Comment
# Commenter
Commenter
Organization
Section
&
Page
Number
Section, Figure, or
Table Number or Topic Sentence Starts with, "… Comment
106
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
ES- 11
ES-11.
GSP IMPLEMENTATION
The GWA Board adopted a preliminary
schedule for project implementation.
Project implementation is scheduled to
begin in 2020, with full sustainability
implementation by 2040.
107
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
ES- 12
ES-12.
FUNDING
Some costs need a closer look, especially the 5-year updates. 108
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model ES-4 Cross Section B-B'
Elevation scale is shown to vary from 2500' to 0' [msl].
The correct elevation range should be 900' msl, based on Figure 22, to a deep negative elevation.
109
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model
Report
Figures 29a to 29f: Cross
Sections
The upper limits of the elevation scale vary from 1800' to 3000'.
The correct elevation range should be 900' msl, based on Figure 22, to a deep negative elevation.
110
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model
Report
Figures 29a: Cross
Section
Section A-A' is located somewhat north of GSP Section A-A'. The GSP section shows the sedimentary formations thinning eastward on top of bedrock. Whereas, the model section shows over 1000 feet of sediments along the eastern boundary of the model. This extra thickness in the model provides additional groundwater storage which could contribute to a false sense of sustainability.
111
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model
Report
2-12
2.9 Model Layering
Layer 1 thickness ranges from 34 to 966 feet and Layer 2 thickness ranges from 50 to 540 feet.
Layer 1 is thickest within the north-central and along the eastern boundary, and the latter condition seems unusual and is not explained by the report. Layer 2 is thickest within the southcentral area and this condition seems reasonable. 112
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model
Report
Figure 23: Layer 1
Thickness
&
Figure 24: Layer 2
Thickness
The thickness of Layer 1 is divided into five categories but the range of the first and last categories are significantly different from the middle 3 categories. The span of the first category is 196 feet and the last category is 520 feet, compared to the 60-foot spans of the middle categories. For comparison, the thickness of Layer 2 is divided into six categories with spans between 60 and 90 feet (average: 73 feet).
These large differences within Layer 1 contribute to the uncertainty in the model output. 113
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model
Report
3-6
3.3.2 Groundwater Pumping
Table 8: Summary of ESJWRM Well
Pumping
City of Galt is located along the northern boundary of the subbasin and produces groundwater for its customers. The model should acknowledge and include the City's groundwater production.
114
Rodney
Fricke
GEI on behalf of
Sacramento County GSA -
Cosumnes Subbasin
Model
Report
4-6
4.7 Final Calibration
Parameters
Table 10: Range of Aquifer Parameter
Values
Why does the Corcoran Clay vertical K values apply to Layers 3 and 4 when the aquitard is situated between Layers 1 and 2?
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Sacramento County GSA in the Cosumnes Subbasin Aug-19
Comments on ESJ Draft GSP
Sustainable Management Criteria for Groundwater Levels along the Northern Boundary of the
Eastern San Joaquin Subbasin
Figure 1
-36.7
-9.0
8.3 -6.2
17.4 MTMT
MO
MO
-90.0-70.0-50.0-30.0-10.0
10.030.0
01-Jan-72 01-Jan-80 01-Jan-88 01-Jan-96 01-Jan-04 01-Jan-12 01-Jan-20 01-Jan-28 01-Jan-36 01-Jan-44 Groundwater Elevation, feet msl
04N07E20H003 04N05E24J004 Interim Milestones Start of Historical Period 31-Jan-40 Sacramento County GSA in the Cosumnes Subbasin Aug-19
Comments on ESJ Draft GSP
Sustainable Management Criteria for Groundwater Levels along the Northern Boundary of the
Eastern San Joaquin Subbasin
Figure 2
-36.7
-9.0
8.3 -6.2
17.4 MT
Revised MT
MT
MO
MO
-90.0-70.0-50.0-30.0-10.0
10.030.0
01-Jan-72 01-Jan-80 01-Jan-88 01-Jan-96 01-Jan-04 01-Jan-12 01-Jan-20 01-Jan-28 01-Jan-36 01-Jan-44 Groundwater Elevation, feet msl
04N07E20H003 04N05E24J004 Interim Milestones Start of Historical Period 31-Jan-40 ~D
DRY CREEK WATERSHED
MANAGEMENT PLAN
A CASE STUDY EXERCISE:
WATERSHED PARTNERSHIPS SEMJNAR
February 27 - March 9, 2006 ,
Folsom, CA
Prepared By:
(r
TEAM I
John Brodie
Jeannie Habben
Jan.Lopez
Sara Martin
Leandro Ramos
Pam Stumer
Diane Zarate
If,
Section 1
ission Statement and Watershed Background
ission Statement
The mission of the Amador Dry Creek Watershed Council (ADCWC) is to preserve the quality of life in our watershed by engaging stakeholders and the community, managing growth and frre hazards, and protecting natural resources, while respecting private property rights.
Background Information
The Dry Creek watershed is located in central California, and drains the portion of the Sierra Nevada foothills between the Cosumnes River and t:Jie Mokelumne River. As shown in Figure 1, the creek flows west/southwest through the western slope of the foothills, joining with its two major tributaries, Sutter Creek and Jackson Creek, on the way. It then flows to the floor of the Central Valley, where it empties into the Cosumnes River. The Cosumnes River empties into the Mokelumne River, which then enters the complex network of tidally-influenced rivers and sloughs of the Sacramento-San Joaquin Delta. The delta waters eventually empty into the San Francisco Bay.
The watershed area encompasses approximately 388 square miles, with over 150 miles of streams and over 900 miles of roads. The majority of the watershed is located in Amador County, but the lower-elevation, western end of the watershed is split between Sacramento County in the north and San Joaquin County in the south. Incorporated cities within the watershed include Jackson, Sutter Creek, Amador City and Ione in Amador county, and Galt in Sacramento County. State Route 49, which connects Sierra Nevada foothill towns, is the major north/south transportation corridor in the watershed, and State Route 88 is the main east/west transportation corridor (see Figure 2).
Streams in the Dry Creek watershed are almost completely unregulated. Lake Amador, located on Jackson Creek near Ione, is the only dammed reservoir in the watershed.
Dry Creek Watershed Management Plan
Team 1 1
March 2006
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Figure 2-Major Roads in the Dry Creek Watershe
Hydrology
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I
Geology
Elevations within the Dry Creek watershed range between 4,000 feet at the upper end of the watershed to approximately 7 feet at the confluence of Dry Creek with ? the Cosumnes River. The main stem Dry Creek eh¥Jnel has a length 0£112.) miles with an elevation drop of approximately-2_50.ifeet. Bycomparison,fue '"' main stem of the neighboring Cosllfil{les River channel travels a length of 133 miles with an elevation drop of625 feet. The downstream end of the watershed is tidally influenced-the daily'tid€range at Dry Creek's confluence with the Cosumnes River is approximately 1.5 to 2 feet.
As mentioned above, streams in the Dry Creek Watershed are largely unregulated. The unregulated nature of the streams, as well as the relatively steep channel profile, mean that Dry Creek is a relatively "flashy" system, with floods peaking over a few hours and lasting just a few days.
The climate of the watershed is Mediterranean1 where summers are hot and dry, and the bulk of the rainfall occurs in the winter, mostly during the months of December through mid.March. Thus, winter rain events are the primary source of annual peak flows in the watershed. Estimated peak flows in Dry Creek are shown below in Table 1.
Table 1. Peak Flows for Dry Creek at Galt
Storm Event (Recurrence Interval) Peak Flow Discharge (cfs) 2-Year 4;230
5-Year 11,200
10-Year 17,800
20-Year 25,400
50-Year 37,000
100-Year 46,900
Source: David Ford Consulting Engineers 2004
Dry Creek is no longer a perennial stream. Flows typically cease in the lower watershed during the late summer and fall due to upstream water use and groundwater overdraft in the lower watershed. Additionally, manipulation of the landscape by humans over the past 200 years has disconnected Dry Creek from many of its historical floodplains around Galt. Because of this, farms and pastures in the lower watershed are often flooded during high flow events.
Amador County lies almost entirely in the Sierra Nevada geomorphic· province; only the extreme portion lies in the Central Valley. From the Central Valley Dry Creek Watershed Management Plan
Team 1 2
March 2006
eastward, the range gradually rises to the glaciated crest in the vicinity of Mokelumne and Thimble Peaks, both of which lie above 9000 feet.
The older rocks of the Sierra Nevada, commonly called the "Bedrock series" consist of isoclinally folded complexly faulted metamorphic rocks of Paleozic and Mesozoic ages, intruded by several types of igneous rocks, chiefly granites.
Unconformably overlying these rocks in the Western portion of Amador County are much younger, nearly flat-lying Tertiary sediments. These nearly flat-lying sediments are commonly called "superadjacent series"
The older metamorphic rocks are divided into the Calaveras and Amador groups and Mariposa formation. The Calaveras group includes all of the pre-Mesozoic rocks in this country while the Amador group and Mariposa formation are Jurassic.
Biological Resources
More information is needed to make a thorough characterization of the biological resources in the Dry Creek watershed. As shown in Figure 3, the upper third of the watershed is primarily vegetated with evergreen forest, the central third of the watershed is comprised of mixed coniferous/deciduous forest and grassland, and the lower third of the watershed is mainly grasslands.
Natural communities, as designated by the California Department of Fish and Game, that are present in watershed include Ione Chaparral in the upper portion of the watershed and Coastal and Valley Freshwater Marsh, Great Valley Mixed Riparian Forest, Great Valley Valley Oak Riparian Forest, Ione Chaparral, Northern Hardpan Vernal Pool, and Valley Oak Woodland in the lower portion of the watershed. Lists of special-status species in the upper and lower watersheds from the California Natural Diversity Database are included as Attachments A and B.
A number of species have attracted stakeholders' attention, many because of their implications for land management issues. Manzanita in the understory oftbe upper watershed forest bas been known to fuel wildfires. Several invasive species have become established, among them Arundo donax, Himalayan blackbeny, yellow star thistle, knapweed, skeleton weed, tree of heaven, and pepperweed.
The federally listed and protected valley elderberry longhorn beetle has also been observed in the lower watershed.
Community Information
Census data for the exact area of the watershed are not readily available, as watershed overlays do not yet figure among the data sets of the U.S. Census Bureau. However, data from the 2000 census do exist for the five cities of the watershed. Those figures indicate that while most of the watershed's communities lie in Amador County, its largest population center is the city of Ory Creek Watershed Management Plan
Team 1 3
March 2006
121•3ow 121"15W 120°45W
38°44'26"N
,21 •• ,.,."WB ,,..,7'59'W
37"54'49"N
USGS NLCD
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D Low Intensity Residential
D High lntcn&ity Residential
f@1 Commorcial/lnd
us trial!Tra
nsp.ortation
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D OuarriesJStrip
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D Daciduous Forest
D Evergreen Forest
D Mixed Forest
D Shrub land
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er
D Grass la nds
/Herba ce ou s
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/Hay
D Row Croi,s
D Small Grains
D Fallow
D Url>an/Recreationa I Grasses
D Woody Wetlands
D Emergent HC!rbaccous
Welland•
120"30W
0 The
National
Map
http://nlltionalmap.gDY/
Geographic Coordinate System (WG
Figure 3-Land Cover in the Dry Creek Watersh
I
Galt, which lies in Sacramento County. In 2000 Galt had a population of 19,472.
The second-largest city was Ione, which houses the Mule Creek State Prison and had a population of7,129; Jackson was the third-largest, with 3,989 residents; Sutter Creek, the fourth-largest, with 2,303, and Amador City the smallest, with 196. Together, the cities in Amador County-Amador City, Ione, Jackson, and Sutter Creek- account for approximately 39% of the county's population of 35,100. An unknown number of people live in the unincorporated areas. On the whole, Amador County's population is older than that of California, with 18 .0% being older than 65, as opposed to 10.6% for the state. A table with the census data is attached (Attachment C).
Given the amount of development that has taken place since the 2000 census, the nwnbers and relationships described above may have changed.
There are a number of other community institutions and characteristics that the Amador Dry Creek Watershed Council may wish to take into account as it plans for its future. One is the presence of groups with varying experience on the land.
Members of an indigenous Native American tribe, the Miwok, continue to practice the old ways; traditional ceremonies are held in the round-house at Chaw'se State Park, and tribal elders practice traditional crafts, among them basketry using local natural materials. Families of some of the county's farmers, ranchers, and vintners have worked the same ground for several generations.
Others who may have ongoing direct experience of the resource include hunters, agricultural workers, skiers, and hikers.
Over the past several years, development and land management have appeared prominently in community interactions. Several collaborative efforts have been undertaken. Homeowners in the KC Ranchettes subdivision, the Amador Fire Safe Council, and the Jackson Rancheria Casino worked together to fund and implement a brush-clearing project to create a :fire break. The Sonoma Ecology Center, which has worked with the Amador County Wine Grape Growers Association, held watershed education workshops-for local eremeutaiy school students and residents of Amador County. The Sutter Creek City Council is studying possibilities for adaptive reuse of Knight Foundry and the Central Eureka Mine; one proposal involves preserving the stamp mill and adding trails with a self-guided interpretive tour_ In January 2006 Amador County announced interest in attracting the headquarters of the state Sierra Nevada Conservancy to a property in Martell formerly owned by Georgia-Pacific. Other interactions on land management include several recent lawsuits: one by the group Protect the Historic Amador Waterways to bait oonstmction of a cros.s-comrty pipelim} that would dry up the Amador Canal; one by the Earth Island Institute-and the Center for Biological Diversity to halt timber harvesting near the Bear Creek Reservoir; and one by Amador County to halt the construction of a casino by the Buena Vista Band.
Known civic organizations operating in the watershed include the Lyons. Club,. which runs an Adopt-a-Highway project; the Rotary Club; Sons in Retirement (SIRS)~ the League of Women Voters of Amador County~ and the Amador County Community Foundation.
Dry Creek Watershed Management Plan
Team 1 4
March 2006
Given the initial survey of community information, a list of stakeholders in the watershed could include the following:
Landowners
• Ranchers
• Faimers
o Homeowners - new and existing
Native American Tribes
State, Federal, and Regulatory Agencies
• CA Department of Fish & Game
• CA State Water Resources Control Board
o Central Valley Regional Water Quality Control
Board
• CA Department of Water Resources
• CA Bay-Delta Authority
• CA Department of Conservation
• CA Department of Health Services
• CA State Parks
• National Oceanic and Atmospheric
Administration - Fisheries
• United States Fish & Wildlife Service
• US Department of Agriculture/Natural
Resources Conservation Services
• Bureau of Land Management
• US Army Corps of Engineers
• US Bureau oflndian Affairs
• US Geological Survey
• US Environmental Protection Agency
Business and Manufacturing
0 Golf Course owner/operator
• Developers
• Tourism
• Casino Owner/operators
• Commercial manufacturing
• Timber Industry
• Mining
UtiJities
• Pacific Gas & Electric
• Amador Water Agency
• Jackson Irrigation District
• Municipal wastewater agencies
Non~Governmental Organizations
• Amador/Dry Creek Watershed Council
• Amador Fire Safe Council
• Dry Creek Conservation
• PHA W - Protect the Historic Amador
Watenvays group
• Foothill Conservancy
• Amador County
• Sacramento County
• San Joaquin County
• Local cities (incorporated or unincorporated)
Water and Wastewater Management
Water use in the watershed includes municipal, domestic and industrial water supply; agricultural irrigation; stock watering, recreation, warm water fish habitat and wildlife habitat.
Dry Creek Watershed Management Plan
Team 1 5
March 2006
A significant portion of the watershed is not served by municipal water or wastewater treatment facilities, and septic systems and wells dominate, particularly in the upper reaches. The upper watershed, located in Amador County, has characteristics distinctly different from the lower watershed.
Information for the lower watershed is limited to the City of Galt in this report.
Amador County
In 1959; the Amador Water Agency was formed for the purpose of providing water and wastewater services to the residents of Amador County. The Agency is governed by a board of five directors who are elected to four year terms. The Agency offices are located in Sutter Creek, California.
Water Sources
The North Fork of the Mokelumne River, located on the Ca1ifornia Sierra Nevada Mountains, is the primary source for the Central Amador Water Project system, the Amador Water System and the PG&E Tiger Creek Powerhouse system. Water supplied from rainfa11 and snowmelt is stored in the Tiger Creek After bay and gravity feeds to the PG&E Powerhouse Memcor Plant where it is treated. Water from the Tiger Creek After bay i_s also pumped to the Buckhorn Water Treatment Plant where it is treated and ready for use by customers of Pine Grove, Pioneer, and several smaller communities. Water from the Mokelumne River is also stored in Lake Tabeaud and conveyed by the Amador Canal to the Tanner Water Treatment Plant where it is treated for use by the customers of Jackson, Sutter Creek~ Amador City and Drytown. The Ione Pipeline transports raw water from the Tanner Reservoir to the Ione Water Treatment Plant where customers are served~ nell .. ~.
The Amador Canal is a flume-like ditch that runs 23 miles from Lake Tabeaud to Tanner Reservoir. It was built in the Gold Rush era and the first water flowed through the canal as motive power for the mills and mines of the county. Later it supplied water for agricultural and domestic purposes to Sutter Creek, Jackson and Amador City (and still does today). It also helps to power Knight Foundry in Sutter Creek, the only remaining and longest continuously operated waterpowered iron works in the United States.
Over many years, leaks in the canal have existed and have been allowed to continue; a valuable ecosystem of plant and animal life has become dependent on the water, as have Amador County citizens through their ground water wells, businesses along the creeks and tourism. The seepage also provides valuable fire protection and helps to cool the air in surrounding areas.
Wastewater Treabnent/Disposal
There are six small wastewater treatment plants located in the watershed:
Amador City, Sutter Creek, Marten, Ione, and Jackson. Amador City, Sutter Creek and Martell have seconda..ry treatment and pump their effluent to Jone.
Ione has settling ponds and percolation ponds to process much of what it receives. A portion of the effluent is advanced treated and pumped for land, Dry Creek Watershed Management Plan
Team 1 6
March 2006
application and golf course irrigation. The plant at Jackson also provides secondary treatment of its influent and then discharges its effluent into Lake Amador. Lake Amador provides water for domestic supply downstream and the Health Department would prefer that the Jackson Plant cease discharging to the lake because of water quality concerns.
Most of the population is on septic systems, which are located throughout the watershed. Many systems are very old and there is concern about the potential for failure. It is unknown if the leach fields from existing septic systems are impacting groundwater or stream water quality.
City of Galt
The City of Galt Public Works Department is responsible for the production of potable water and the operation and maintenance of the wastewater treatment plant for the residents of Galt.
Water Sources
The City of Galt relies upon groundwater from the Cosumnes Sub basin of the San Joaquin Valley Groundwater Basin as its sole source of domestic potable water. The Cosumnes Sub basin is an unadjudicated basin that supports both municipal and agricultural users. Basin inflows include natural and applied water recharge. Subsurface inflow and outflow are not known specifically. Based upon a water balance provided in a 2003 DepartJnent QfWater Resources Bulletin, groundwater outflows exceed groundwater inflows by approximately 4300 acre-feet.per year, suggesting a basin overdraft situation may exist The current system is comprised of two three-million gallon storage tanks with pump stations, seven wells, 62 miles of piping and valves and 5,800 lateral connections. The City currently averages production of over four million gallons per day of domestic water.
Treated Surface Water
Treated surface water is only viable as a future watet_s.upply if the City is successful i.ninegotiating the purchase of imported water supply. The City has researched the availability of surface water-rights for the Cosumnes River as well as from the intennittent creeks in the vicinity of the City.
Wastewater Treatment/Disposal
The City operates and maintains the wastewater treatment plant and is currently processing approximately 2.0-2.2 MGD with a plant capacity of3.0 MGD. In 1991, Galfs Wastewater Treatment Plant was upgraded to full second3A"')' treatment and treatment capacity was increased to 3.0 million gallons per day (MGD). At the time of the expansion, the City did not have sufficient disposal capacity during the summer to handle 3 .0 MGD. At the present, the City has disposal capacity for approximately 2.2 MGD with an additional 0.3 MGD Dry Creek Watershed Management Plan
Team 1 7
March 2006
eapacity available in 20061
• The City owns 180 acres ofrland and leases
additional 180 acres for disposal of effluent by irrigation and i11jecfron of solids.
Land Use
Historically, land use and development in Amador County has been shaped by mining, timber, agriculture, and grazing. Current land use and development is still shaped by those same forces, with the addition of tourism, manufacturing, and the in-migration of retired residents and residents who commute to the relatively distant economic centers of Sacramento and the Bay Area. '
The major development trend is toward greater densities of homes where development is permitted. Amador County remained almost untouched as neighboring El Dorado, Sacramento, and San Joaquin Counties experienced explosive population growth and residential development through the late 1990s.
However, rising real estate prices in neighboring counties and Amador County's desirable climate, rural ambiance, and proximity to major job markets are starting to attract unheard-of amounts of development pressure.
Table 2. General Land Use Categories in Amador County
Percent of
Land Use Acres County
Urban and Suburban (Residential, Commercial, and Manufacturing) 108,619 29% Federal Lands (USFS, BLM & Mokelumne Wilderness) 100,328 27% General Agriculture (Williamson Act) 94,028 25%
Other Agriculture (EBMUD, NID, Non-Williamson Act) 43,582 11% Timber Production (Non-USFS/BLM) 29,524 8%
Total County 376,081 100%
Source: Amador County Fire Hazard Reduction Plan, 2004
Urban and suburban land uses continues to be the highest use of land in Amador County. As shown in the previous table, approximately 25% of agricultural lands remain under Williamson Act conservation contracts, limiting non-agricultural development in the future (Attachment D). Non-renewal of these contracts requires a ten year restricted withdrawal period, with penalties for noncompliance. However, non-irrigated lands currently reflect the fastest growing conversion of land use in an attempt to meet perceived residential needs.
Unincorporated communities developing within the county (and watershed) include Jackson Valley, Martell, and Volcano.
Dry Creek Watershed Management Plan
Team 1 8
March 2006
Planning Efforts
Amador County adopted its first general plan in 1973, and has conducted updates as needed, ori a 10-year review schedule. In November, 2005, the Amador County Board of Supervisors implemented a moratorium on all developments requesting general plan or zoning changes, and began steps to complete an update of its General Plan.
Amador County, and the Dry Creek Watershed area in particular, bas experienced significant growth over the past 10 years. The Amador County Development Policy states that future residential development will be encouraged to take place in the fonn of farms, ranches, and estates throughout the county or through expansion of existing towns and villages. The increasing density of residences in the intermix zone is particularly important due to the extreme wildfire hazard in this area.
These intermix zones, otherwise know as the Wildland Urban Interface (WUI) zones, have been identified to help local agencies, organizations, and landowners focus on management of the inherent fire hazards occurring when populations encroach upon wildland areas.
The following four communities in the Thy Creek watershed are identified in the CERES database as having general plans and zoning ordinances. Table 3 shows population density for those communities.
Table 3. Amador County, California Census Subdivisions (CERES) Community Name
Type
Ione
CCD
Jackson
CCD
Pine Grove-Silver Lake
CCD
Sutter Creek-Plymouth
CCD
Area in square miles Density per square
mile of Land Area
Housing Land Water Total Population Housing Po.pulation Units Units 10,391 2,573 127.24 6.25 133.49 81.66 20.22
6,997 3,211 75.96 2.28 78.23 92.12 42.27
9,784 5,548 218.86 3.10 221.96 44.70 25.35
7,928 3,703 170.91 , 0.10 171.01 46.39 21.67
No information was immediately available for subdivision development within the cities of the watershed. Within the unincorporated areas of the watershed areas, the following subdivision maps were processed as noted in 2006:
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Table 4. Processed Subdivision Maps in the Dry Creek Watershed (Amador County) Community Subdivision Name No. of Units Acres Approved Application Ione Vintage Estates 9 371 X
Jackson Area Clinton Oaks 4 20.6 X
Pine Grove Petersen Ranch 58 141.22 X
" Pine Grove Bluffs- 109 23.87 X Phase 1
" Quail Ridge 81 82 X
" Mokelumne Bluffs 95 137.86 X
" Pine Acres North 106 44.2 X
Sutter Creek Area Sherrill 4 97 X
" LaMel Grand Estates 7 38 X
" Aparicio 4 31.03 X
Total 477 986.66 6 4
Source: Amador County Subdivision records
The Amador Fire Safe Cruu_1cjl has w1itten the Amador CQunty_Fire Hazard Reduction Plan, finalized in May 2004. The objective of this plan is to provide the Amador Fire Safe Council a foundation to identify, prioritize, and link fuel modification treatment areas in order to create a fire safe community.
Other area plans include the Fire Resource Assessment Program of 2003 by the alifornia Departrneut of Forestry and Fire Protection. Lower Moke!umne River Wate;:shed Stewardship Plan by San Jbaguin c i .uncy.Resource Conse1:yalion District and The Lower Mokelumne River Watershed Stewardship Planning Committee.
Since the lower watershed is located in both Sacramento and San Joaquin counties, there are also references in code in th~ 1993 County of Sacramento General Plan Adopted on December 15,...1 993 and the San Joaquin Count)' General Plan 20 l O (San Joaquin County Community Development Dc_partment. .992. ,ffhe Foothm e onservancy developed the Foothill Conservancy Lal)d Use ~ J)ev~ pro~nt. Princip~. w,bich_wstte develo~d in 2?03 aud_adopt~d by the Amador Association of Realtors and the West Pomt Busmess Counctl m 2005.
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Section 2
Issue Identification
Based on the information gathered to date, the following issues of concern were prioritized for the watershed.
Stakeholder Development and Engagement-The ADCWC is a fledgling watershed group and its first priorities should be to eQ_gage as, many,stakeholders as possible in its process and to raise awareness of the relevance of watershed issues to the everyday life of the residents. Building local capacity will allow the ADCWC to leverage the substantial amount of historical knowledge of the watershed among residents, foster support for its actions, and draw from a large pool for volunteer efforts.
Watershed Assessment/Monitoring Efforts-Relatively little is known about the Dry Creek watershed and its resources. In order to provide a starting point for strategic watershed planning and management, baselme information abouUhe watershed and reliable monitoring efforts are needed. This information will allow stakeholders to create an inventory of important issues and goals based on good science, as well as allow the ADC WC to assess the success of its future efforts and adaptively manage those efforts in light of any changes that may occur.
Growth Management-As described in the Land Use section above, lands in the Dry Creek watershed are experiencing tremendous development pressure.
Effects of unregulated growth on quality of life, water quality, water supply, and natural resources in the watershed were the most often articulated concern of members of the ADCWC and other stakeholders. A key role of the ADCWC over the coming years will be to form partnerships with~local agen:cies and o eve)oper.-s to ensure that the development occurs in a maimer complementary to the current cwality of life, anpi ip hannony with existing natural resources.
Additionally, Amador County is currently in the process of updating its general plan, which presents the ADCWC with a real opportunity to influence development policy in a positive way.
Protect Natural Resources-Sustainability of human life, agricultural production, quality of life, healthy ecosystems, and species diversity in and downstream of the D1y Creek Watershed all depend upon the protection and careful stewardship of..natural resources in the watershed. One of the chie.froles of a watershed group is to allow community stakeholders t.o drive'the decisionmaking process abour how to approach ste,wrosbip of these resources.
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Manage Fire Hazards-Fire hanrrd in the eastern portion of the watershed was also expressed as a main concern of stakeholders in the Dry Creek watershed. A Fire Safe Council has already been established in Amador County to address these concerns. Partnering witn'the Amador.Fire Safe Council would be a great opportunity for information...sharing, as well as for the ADCWC to introduce themselves and their mission to a large group of potential stakeholders.
Respect Private Property Rights-Because most of the watershed is privately owned, the cooperation and goodwill of private landowners is necessary for the success of Watershed Plan implementation. Respecting private property rights is the key to receiving that cooperation an'a ris inco~ tedUnto the goals .. .and obJectives of other priority issues .
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?,'L
Section 3
Goals and Objectives for Priority Issues
Stakeholder Development an ngagement
The Amador Dry Creek Watershed Council is a new organization within the community. Composition of the Council should reflect as many interests in the watershed, especially those of private landowners. Members should develop a broad understanding of all conditions and issues in the watershed that impact the quality of life.
r-2.., Goal: Expand Participation in the ADC Watershed
Council
Objective: Include as many stakeholders as possible in
the development o~ the watershed management plan.
Action Steps (to be completed within 1 year of initiation):
Survey stakeholders with pre-paid postcard response for meeting dates, times, etc.
• Establish a "neutral" site for meetings or rotate sites and/or locations. • Get already established groups involved and ask for participation from their members (i.e., Fire Safe Council, RCD Boards, Tribal leaders, Cattlemen's Association, Farm Bureau, PHA W, other NGOs, locaVstate/federal governments.
• Identify education and outreach needs and opportunities. e Identify key issues and develop strategies to address them. • Identify activities to actively engage Council members and others in the community
Performance Measure: Encourage stakeholders participation regularly in plan formulation; completion of a watershed action plan.
Funding Strategies:
• In-kind donations (paper, printing, postage, meeting space, etc.) Dry Creek Watershed Management Plan
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• Community foundation capacity building grants (i.e. Chico database) Goal: Educa'te the community on watershed issues
Objective: Develop and implement an education and
outreach program.
Action Steps:
~ Gather available stakeholder education materials already completed by local agencies
11 Collaborate with private, state and government stakeholders to compile existing resource materials on resource concerns, policy items, and best management practices.
• Work closely with governmental agencies to eliminate duplication of watershed education efforts.
• Develop ways in which research data and information materials are understandable and available for direct use in decision making and implementation by as many stakeholders as possible
a Partner with local volunteer organizations to assist with education and management efforts
a Host public workshops to demonstrate watershed improvements due to activities implemented by watershed projects
• Develop a school classroom outreach presentation
Performance Measure: Variety of materials available; number of workshops and presentations given; partnerships with schools for watershed education Funding Strategies:
• Identify grants and other funding opportunities for planning, implementation, and monitoring project. (Refer to Additional Resources at the end of this report)
• Funding from DFG, USFWS, NOAA Fisheries, National Fish and Wildlife · Foundation, CALFED.
• Funding from community foundations, Jackson Rancheria Casino, and School Districts
Watershed Assessment/Monitoring Efforts
Relatively little is known about the Dry Creek Watershed and its resources. In order to provide a starting point for strategic watershed planning and management, ... baseline information abounhe watershed and-reliable monitoring effo!its_sho"'nld be esf.<tbJisited. This information ~ iJl allow stakehold.ers to create an inventory of lll!POrtant issues and goals,reinforced by data, as'\vell as allow Dry Creek Watershed Management Plan
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the Council to assessrthe success 0f.-i'ts effort~ and adaptively manage fuose ~Q!iis in light of any changes that may occur.
3. >. \ Goal: Establish reJiabl,_baseline information about the watershed.
,'<-) Objective: Identify data gaps and strategies for gathering needed data
.~
bJ Objective: Perform a comprehensive watershed
assessment and update it every five years. The assessment should incorporate information on biological resources, invasive species, stream morphology, water management, land use, demographics, economics, and potential partners.
Action Steps:
• Assemble existing available resource materials, including:
• County Soil map (NRCS)
• Vegetation species inventory (CNPS, RHN, EBJVIUD, PG&E) 11 Mammalian species inventory (DFG, Sierra Club, USFWS, EBMUD, PG&E)
• Avian species inventory (Audubon, Sierra Club, PRBO, EBMUD, PG&E) • Fish species inventory (NOAA Fisheries, DFG, USFWS, Amador Water Agency, EBMUD, PG&E
11 Baseline Water Quality data (RWQCB, water agencies)
Kl Map of land uses ( County Planning)
• Maps of Williamson act land (DOC, 1'i1RCS)
• Conduct riparian habitat assessment
• Identify education and outreach needs and opportunities Performance Measures: maps of each condition (perhaps as GIS layers); ranking of species for preservation, ranking of areas for preservation, ranking target areas for restoration, enhancement, and protection.
Funding Strategy: Funding from DFG, USFWS, NOAA Fisheries, National Fish and Wildlife Foundation, CALFED. In-kind help from other agencies, especially stakeholder agencies.
Objective: Establistra credible water flow and velocity gauging sy_stem~on Dry-Creek and its tributaries. _
The most useful distribution of gauges would require installing eight gauges.
However, with limited funding, installing gauges below each major tributary Dry Creek Watershed Management Plan
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confluence could provide useful data, as could reactivating the gauge on Dry Creek at Galt.
Action Steps:
Install an 8-gauge configuration, including the following:
North Fork Dry Creek above confluence with South Fork Dry Creek, • South Fork Dry Creek above confluence with North Fork Dry Creek, Below confluence of North and South Fork Dry Creeks,
• Sutter Creek above confluence with Dry Creek,
Below confluence of Sutter Creek and Dry Creek,
• Jackson Creek above confluence with Dry Creek,
Below confluence of Jackson Creek and Dry Creek, and
• Dry Creek at Galt.
Perfonnance Measure:
m Produce baseline flow report
11 Establish maintenance plan
11 Respect private property rights in producing data
Funding Strategy:
• Respect private property rights and produce measures to ensure interests are comfortable with funding source, perhaps pursue private support for this effort
• Homeland Security grants
Objective: De.velop a stakeholder water quality
\,') 1 monitoring program.
This effort will function to collect valuable data that can be used in ranking priorities and measuring success of actions, as well as to engage local residents in an activity that will put them on the ground in their watershed, learning how their watershed works and how certain activities affect their watershed, and fostering a personal connection with their local streams.
Action Steps:
• Identify sites for monitoring activities
• Recruit volunteers interested and available for monitoring activities Develop _9r'sampling protocol
11 Provide training for volunteers on sampling protocol Performance Measure:
• Basline report is produced
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• Sampling protocol in compliance with EPA standards and/or State Regulation standards.
• Monitoring schedule is established
Funding Strategy:
• Collaborate with established watershed groups and local governments to identify and promote integration among watershed efforts • Pursue funding frdprivate sources to assist in the assurance that private property rights and concerns can be respected.
~ 4 Growth Management
5.4,1
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Amador County is experiencing accelerated growth, which may adversely impact the availability of water, water quality, traffic and the rural character of the watershed. An effort to update the County General Plan has begun and will take approximately 3-4 years to complete.
Goal: Encourage water use efficiency to ensure an
adequate supply for current and projected domestic
and agricultural uses, and to support the needs of
natural habitats.
Objective: Participate in outreach and education efforts to increase public understanding of the current sources, uses and limitations of water supply in the watershed.
Action Steps:
• Plan approach in collaboration with AW A
• Convene meetings with community groups
• Distribute literature and BMPs for water use efficiency strategies Performance Measure: Pre and post campaign surveys of public understanding of water issues and conservation practices; increased level of understanding and use of conservation measures
Funding Strategy: Partner with local public agencies that might be able to leverage statewide funding sources for water use efficiency.
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!9) Objective: Initiate collaborative among wastewater
management agencies, agricultural producers and
interested stakeholders to develop a plan for reuse of
secondary and advanced secondary treated wastewater
for additional farm and vineyard irrigation.
Action Steps:
11 Plan with AW A and convene meeting of key stakeholders. m Gather and provide information of similar efforts in other communities. 11 Educate the community and farmers on current sources and uses of water, including the viability of using recycled water for additional farm and vineyard irrigation.
Performance Measure: Completed plan for increased agricultural reuse of wastewater; zero discharge to L&ke Amador
Funding Strategy: In-kind services; SWRCB loans/grants
Goal: Balance land use decisions with the need to
maintain a healthy environment and to protect natural
resources
Objective: Integrate Watershed Plan priorities into the revised Amador County General Plan.
Action Steps:
• Participate in the General Plan update meetings (Task Force?) to represent the interests of the watershed in proposed GP atnendments.
Propose language for integration into the General Plan update, which reflects the values and priorities of the community and the health of the watershed.
Performance Measure: Updated Amador County General Plan is consistent with the values and priorities of the community and the health of the watershed.
Funding Strategy: In-kind services
&) Objective: Assist in establishing guidelines for "Smart Growth" in the counties, the cities, and/or the towns in the watershed, including in the Amador County General
Plan, which is currently being updated.
Action Steps:
11 Complete a watershed assessment including water use, well clustering, water draw down, and recharge and riparian areas to address the reduction of corridor habitat as a result of development in the watershed.
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m Assess any established water systems in the watershed checking for water supplies, wastewater disposal, and water quality
11 Attend and participate any Board of Supervisor's meetings addressing growth and land use
Form a sub-committee of the watershed to assist in the Area Plan to include water issues, building locations in respect to riparian areas of the creek, and smart growth policy
11 Address as an issue of growth the reduction and prevention of sedimentation from entering the creek.
Performance Measure: Completed assessment; Smart Growth guidelines established
Funding Strategy: In-kind services; local agency funding/partnership
3.'6 Protect Natural Resources
The many rich natural resources in the Dry Creek Watershed need care and protection to maintain the current quality oflife. Efforts to improve and sustain these resources will help ensure adequate supplies of drinking water, wildlife lo observe and enjoy, healthy ec-osystems with native plants, fire safe communities, and an appreciation for both public land and personal property. 1 . .;,1 Goal: Preserve Natural Resources of Amador Dry Creek Watershed
"-) Objective: Identify areas for habitat protection,
enhancement, and restoration
Action Steps:
• Conduct an analysis of baseline assessment information, as detailed above • Identify data gaps
llil Identify current land protections (Williamson act, easements, encoded setbacks, etc.)
• Identify funding sources for protection/enhancement/restoration (p/e/r) 11 Identify companies/NGO's, or non-profits that perform p/e/r design and construction
Identify permitting needs and problems
Identify Education and Outreach needs and opportunities Performance Measures:
Map of T/E species habitat protection areas (not specific properties) • Safe harbor agreement fot landowners w tie species concerns Dry Creek Watershed Management Plan
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'"of .. ~.._ -
Completed list of alternatives for watershed-wide p/e/r actions. • Agreement from stakeholders on target areas for p/e/r actions li1 Protection and p/e/r priorities are included in the updated county general plan Funding Strategy: CALFED ERP, DFG, USFWS, EPA, RWQCB.
,.5,i. Goal: Reduce and prevent contaminants from entering the watershed (improve and protect water quality).
~ .'i ,")
,, Objective: Implement clean water programs to improve identified problem areas.
Some specific examples include: replace failing septic systems, remove old mine tailings, improve and or install new storm drainage, replace undersized culverts, develop ways to reduce and prevent contaminants from entering the streams.
Action Steps:
• Seek grant funding to support a monitoring program of the Dry Creek watershed to determine the type of pollutants and their effect on water quality.
• Determine the major drainage problems, including those from old mines, old logging camps/mills, housing developments, commercial operations, vineyards, and septic system runoff that are entering the watershed. • Evaluate old mine and old logging residue to determine constituents and assess water quality impacts.
• Develop a monitoring program
• Develop restoration plans, including best management practices for implementation.
Performance Measures: List of priority pollutants; completed water quality impact report; Monitoring program in place; B.MPS developed or under development
Funding Strategy: CALFED ERP, DFG, USFWS, EPA, RWQCB.
Goal: Educate a_nd involve the comm~nity in redu~~ Q
the impacts ef invasive-plants
o..) Objective: Eliminate all noxious weeds or invasive plant species in the watershed.
Action Steps:
• Complete a Noxious Weed/Invasive species assessment in the Dry Creek Watershed
• Educate Stakeholders utilizing materials already completed by local agencies Dry Creek Watershed Management Plan
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Create brochures and hand-outs specific to the invasive species in the Dry Creek Watershed
• Develop methods to eliminate Noxious Weeds/Invasive species in a manner that does not degrade the watershed
Reestablish native plant species to enhance riparian corridors and to sustain threatened and endangered species
Host public workshops and tours to demonstrate watershed improvements due to activities implemented by watershed projects
Recruit volunteers to identify areas of concern and eradicate those areas Performance Measures: Completed assessment and map of priority areas; acres reestablished with native plant species; number of workshops/tours and attendance at those event; number of volunteers/volunteer work days Funding Strategy: CALFED ERP, DFG, USFWS, EPA, RWQCB.
s.&,, 1vtanage Fire Hazards
3 ,(p ·'
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According to the California, Fire Plan, the risk of wild fires is increasing, area population is increasing, and the topography of the area adds to the potential for wildfire. These factors, when combined, place the watershed and its assets at high risk. The threat of a large, damaging wildfire is high, as is the potential for loss of valuable natural resources, personal property and human life.
Goal: Protect the watershed through support for and
implementation of additional fire safety strategies.
Objective: In cooperation with the Fire Safe Council and the community, survey the properties east of Hwy 49 to
determine areas of high fire risk.
Action Steps:
Map areas to be surveyed
• Recruit volunteers and landowners to complete assessment • Develop strategies for reducing fire risk.
Performance Measures: Completed assessment and map of priority areas; Number of volunteers/landowners participating; completed list of strategies and plan for implementation
Funding Strategy: In-kind services
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b)
F-
.. Objective: Reduce excessive fuel loads on public and " private lands and increase public safety
Action Steps:
11 Recruit public agencies and volunteers to support efforts • Construct defensible fuel breaks in most vulnerable areas; • Evaluating fire-fighting access; and
Develop evacuation plan for the watershed
Performance Measures: Number of public agencies and volunteers · participating in effort; Completed defensible fuel breaks; completed evacuation plan.
Funding Strategy: In-kind services; CDF; local fire agencies 3,r,,_7.,,, Goal: Educate and involve landowners in the watershed to keep their property fire safe
IA.) Objective: Provide fire safety guidelines to prevent the threat of a large damaging wildfire or the potential loss of valuable natural resources, personal property, and human life.
Action Steps:
11 Educate property owners on the "Lean, Clean, mid Green" approach • Reduce excessive fuel loads on public and private lands. • Identify areas with excessive fuel loads
Assist landowners in constructing defensible fuel breaks, evaluating firefighting access, and developing an evacuation plan.
Performance Measures: Number of landowners participating iq. educational efforts; vulnerable areas identified; completed defensible fuel breaks; completed evacuation plans.
Funding Strategy: In-kind services; CDF; local fire agencies.
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Section 4
Additional Resources
Mokelumne River Watershed Owner's Manual: Based on the Home* A *Syst model, the Mokelumne River Watershed Owner's Manual is a voluntary, stewardship-based workbook to guide homeowners in reducing non-point source pollution. The workbook was prepared by the San Joaquin County Resource Conservation District in partnership with the Lower Mokelumne River Watershed Stewardship Planning Committee. The manual provides guidelines for evaluating property and formulating action plans to reduce or eliminate nonpoint source pollution for homeowners and other residents of the watershed.
Topics addressed include: storm water management, reducing pollutants in runoff. landscaping and property management to reduce runoff. drinking water well management, well location and maintenance, household wastewater and septic/sewer systems, managing hazardous household products, product disposal, managing swimming pools and similar topics.
Central Valley Waste Services: CVWS offers edm~ational programsi.promoting a clean environment. Specifically, CVWS emphasizes educational programs for:
a) second graders regarding how recycling preserves natural resources and b) fourth graders discussing source reduction of trash. Thousands of ch.ildr,en benefit from these programs annually.
U.C. Cooperative Extension: This agency provides extensive education program addressing watershed management. A few of the most recently developed programs include homeowner education programs targeting the use of residential pesticides ( currently funded by CALFED and targeting Diazinon and Dursban) and a new curriculum targeting grades 3-6 emphasizing water and pesticide education. The agency also holds regular farm commodity meetings (e.g., tomato, com, asparagus, etc.) which emphasize best management practices related to water use and pollution.
Leadership lnstitute's Adopt-A-Watershed: Aclopt-A~ershedJs a K-12 school-community learning experience which uses local watersheds as living Dry Creek Watershed Management Plan
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•
laboratories where students engage in hands-on activities. The program is sponsored by the Leadership Institute. Five primary elements are emphasized: 1) applying science concepts directly to the local watershed, 2) monitoring local watersheds through field study, 3) restoring watersheds through community need-based projects, 4) educating through community action projects and 5) reflecting upon concepts learned while making contributions to the community.
The program addresses plants, wildlife, aquatics, ecosystems, soils, geology, vegetation management, and cultures with a curriculum consistent with state requirements. ]'raining.for teachersJs included in the program. AJ2E£oximately 120 teachers in San Joaqu in County are-currenLly in.voJved in lhe program.
Learning Under Creative Concepts (LUCC): Th.is organization provides stewardship-related programs for young first-offenders and other at-risk youths which help to foster responsibility and self-esteem. Undertaken primarily on LUCC-owned property, these stewardship-based programs include agriculture, riparian restoration, horse rehabilitation, and similar programs.
Lodi-Woodbridge Winegrape Commission (LWWC): LWWC has produced the Lodi Winegrowers Workbook. This self-assessment guide to integrated fanning practices addresses viticulture, soil management, water management, pest management, habitat management, management of human resources and evaluation of wine quality.
CA Dairy Quality Assurance Program (CDQAP): The San Joaquin County U.C. Cooperative Extension office assists in implementation of this voluntary program to encourage management practices promoting resourc~ conservation in dairy operations. Additional program details may be found at CDQA.org.
California Cattleman's Association (CCA) CA Rangeland Water Quality Management Plan Riparian Grazing Project, Beef Quality Assurance Program: The California Rangeland Water Quality Management Program (CRWQMP) was developed by the CCA, U.S. Cooperative Extension, environmental agencies and interest groups to improve water quality on private rangeland under a voluntary program officially adopted in 1995 and including rangeland water quality management strategies, policies and coordination mechanisms as well as sample plants and sources of assistance.
The Riparian Grazing Projects is a joint effort of the CCA and U.S. Cooperative Extension to determine correct and incorrect methods for grazing to ensure riparian success. The project is a statewide study of rangeland riparian areas in which riparian area health, specific site watershed conditions and site specific management are simultaneously examined and address both past and present grazing methods. Program assistance is being provided by the CA Department of Forestry and fire Protection, the U.S. EPA, the CA Department of Fish and Game, the U.S. Department of Forestry, the U.S. Bureau of Land Management, UC Davis and others.
Much like the CA Dairy Quality Assurance Program, this program was begun in 1986 as an industry effort to encourage cattlemen to follow certain quality control measures exceeding those of the U.S. Department of Agriculture and the Food and Drug Administration. The California Cattleman's Association Quality Dry Creek Watershed Mana_gement Plan
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Assurance Program grew from this effort in 1992 and emphasizes a partnership with the-U.C. Cooperative Extension. Surveys and workshops are used to evaluate multiple activities, including animal handling and sanitation activities that may affect the watershed.
Biologically Integrated Orchard Systems (BIOS): Founded in 1993 by the Community Alliance with Family Farmers (CAFF), BIOS is a technical assistance program whose primary purpose is to "build a community of farmers, other agricultural professionals, and public institutions dedicated to the voluntary adoption of whole-systems approaches to farm management that are flexible, maintain long-term profitability, and rely less on chemical inputs." The BIOS program for almonds and walnuts has been llllderway for nearly seven years in the Central Valley where a small, but growing number of farmers have successfully reduced their insecticide, herbicide and fertilizer inputs without affecting yield or quality. The BIOS program is actively working to refine these techniques and extend them to other nut growers using the experiences of the participating growers, their independent pest control advisors and UC researchers.
BIOS programs are active in Merced, Stanislaus, Madera, San Joaquin Colusa, Yolo, Solano and Merced counties. Program cooperators include the University of California Sustainable Agriculture Research and Education Program, UC Statewide Integrated Pest Management Program, UC Cooperative Extension, the USDA's Farm Service Agency, and the USDA's Natural Resources Conservation Service (NRCS).
Biologically Integrated Farming Systems (BIFS): As a result of the success of the BIOS program (see above), the California Legislature created BIFS to extend the BIOS project to include crops and other fanning systems. The University of California Sustainable Agriculture Research and Education Program (SAREP), and the U.S. Environmental Protection Agency support this competitive grant program. The goal of BIFS is to demonstrate and expand the use of integrated farming systems that have been proven to economically reduce the use of farm chemicals. Farmers involved in the BIFS project are:
11 Integrating biological and cultural control of pests into their production systems;
• Using pest monitoring and economic action thresholds to advise the timing of chemical applications;
• Emphasizing soil-building practices such as the use of cover crops to provide all or part of the nitrogen needed by crops, increase water infiltration of the soil and decrease erosion and flooding;
• Using manure to provide nutrients for cover crops;
• Creating an on-farm habitat and restoring riparian areas to encourage beneficial insect populations and improve habitat for fish, migrant birds and game species; and
Improving livestock management while protecting natural resources.
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Central Valley Project Improvement Act/Anadromous Fish Restoration Plan: The Central Valley Project Improvement Act (CVPIA) of 1992 [Section 3405(b)(l)] directed the Secretary of the Interior to develop and implement a program which makes all reasonable efforts to double natural production of anadromous fish in Central Valley rivers and streams by 2002. In response, the U.S. Fish and Wildlife Service prepared the Anadromous Fish Restoration Program Plan (AFRP). The plan identifies multiple anadromous fish habitat deficiencies in each tributary of the Central Valley of California.
Alternative Roofing plans: www ,i:ooJineadow.com
California Conservation Dept-Recycling Division (916)-323-3 83 6 www.consr,v.ca.gov
California EPA-Toxics Help Desk (916)-327-1848 www.calepa.ca.gov California Health Services Dept-Drinking Water and Environmental Management
(916)-322-2308 ww w.dhs.ca.gov/ps/ddwem/
California Pesticide Regulation Department-Environmental Monitoring and Pest Management (916)-324-4100 \VWW .cdpr.ca.gov
California Toxic Substances Control-Public Assistance (916)-322-0476 www .dtsc.ca.gov
California Water Resources Control Board (SWRCB) (916)-341-5250 www.swrcb.ca.gov
SWRCB-Nonpoint Section (916)-341-5494 www.swrcb.ca_.,_gov SWRCB-Stormwater Programs (916)-341-5529 \VWw.swrcb.ca.gov California Native Grass Association www.(igna.org
California Native Plant Society (916)-447-2677 \v,,..:.w.cnps.oi;-g Motor oil and filter recycling (800)-253-2687
United States Department of Agriculture-Natural Resource Conservation Service www.nrcs.usda.gov
A few of the potential funding sources for some of the LMSP programs include:
American Sport fishing Association Fish American Foundation (F AF) and the National Oceanic and Atmospheric Administration (NOAA) - offers funding for community based restoration programs for on-the-grm1nd habitat restoration in marine, estuarine and anadromous fish habitats. $5,000-$30,000. NOAA Dry Creek Watershed Management Plan
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Fisheries Restoration Center, HC-3, RM 15322; 1315 East West Highway; Silver Spring, MD 20910 (301) 713-0174 Ext. 200.
www.nmfs.nona.gov/habitatirestoratioa/comruun ity/index..htrn.
California Resources Agency - California Department of Parks and Recreation, Planning and Local Services Section - Habitat Conservation Fund. P.O. Box 942896; 1416 Ninth St., Sacramento, CA 94296-0001; (916) 653-7423 or visit http://parks.ca . .gov/grants/hcft11cf.htm
California Resources Agency - California Department of Parks and Recreation Recreational Trails Program Grants. Contact (916) 651-8572 or http:/iparks.ca.gov/grants/rtQL.rtpOO.htm
California Resources Agency - Environmental Enhancement and Mitigation Fund Program (EEM) Grants for acq 1 uisition, restoration or enhancement of watersheds, wildlife habitat, wetlands and forests. Grants generally limited to $250,000. Contact (916) 653-5656 or ~ttp~/7ceres.ca.gev7cra/eemp_new.htmi California Department of Conservation Division of Land Resource Protection - California Farmland Conservancy Program (CFCP). Contact (916) 322-9721 or be e-mail at [email protected]>v.
California Department of Conservation Resource Conservation District Assistance Grant Program. Contact the Division of Land Resource Protection. (916) 324-0774
CALFED - Various, including the CALFED Ecosystem Restoration Program and Watershed Program. See www.calfed.ca.gov for details and deadlines.
National Association of Conservation Districts - Conservation Incentives Program (CIP) - visit www.nacd.org
National Fish and Wildlife Foundation - extensive list of grants for resource conservation activities. Contact ( 415) 778-0999 or visit www.nfwf:org/programs/ guiidelines..htm
Northwest Water Law and Policy Project. Video to assist communities in securing funding for restoration projects in local streams and watersheds. Call (503) 768-6761 or e-mail watei;@Jclark.edu
United States Department of Agriculture Natural Resources Conservation Service - Conservation Programs. Extensive list of funding sources and assistance programs: Conservation Technical Assistance, Environmental Quality Incentives Program (EQIP), Wetlands Reserve Program (WRP), Wildlife Habitat Incentives Program (WHIP), Forestry Incentives Program (FIP), Farmland Protection Program (FPP), and many more.
www.nh<l::_nrcs.usda.gov/.PRQGRMASLcpindex.htm
Dry Creek Watershed Management Plan
Team 1 27
March 2006
United States Fish and Wildlife Service Small Wetlands Grants, under $50,000.
Contact (703) 358-1784 or visit
http://n'01thamerican.fws.gov/NA WCA/smg.ra11ls.htr01l
National Resource Projects Inventory- NRPJ - www .icc.ucd:;tvis.edu/n1-pi California Watershed Funding Database - www.calwateI'"Shedfunds.org California Watershed Network - www.watersheclnelwoi:k...or,1 Dry Creek Watershed Management Plan
Team 1 28
• 11
March 2006
Section 5
References
David Ford Consulting Engineers, 2004. Cosumnes and Mokelumne River watersheds - Design storm runoff analysis, prepared for Sacramento County Department of Water Resources, February.
City of Galt Urban Water Management ·Plan, 2005.
City of Galt website.
CALFED Watershed Partnership Seminar Dry Creek Watershed handout.
Dry Creek Watershed Management Plan
Team 1 29
March 2006
Attachment A. Special-Status Species in the Upper Dry Creek Watersheda Federal Status California Status DFG Species CNPS
Common Name Scientific Name Threatened EndanC1ered Threatened Endangered of Concern Listingb Natural Communities
lone Chaparral
Birds
Tricolored blackbird Agelaius tricolor ./
Reptiles/Amohibians
Northwestern pond twtle Emys (=Clemmys) marmorata ,/
marmorata
Invertebrates
Grady's Cave ampbipod Styf(;obromus wadyi
Valley elderberry longhorn Desmocerus californicus ./
beetle dimorphus
Plants
Bisbee Peak rush-rose Helianthemum s14frutescens 3
lone buckwheat Eriogonum apricum var. ./ ./ 1B
avricum
lone manz.anita Arctostavhvlos mvrtifolia ./ 1B
Irish Hill buckwheat Eriogonum apricum var. ./ ./ 1B
vrostratum
Parry's horkelia Horkelia varryi 1B
Pincushion navarretia Navarretia myersii ssp. myersii 1B Prairie wedge grass Svhenopholis obtusata 2
Red Hills soaproot Chloro~alum grandiflorum 1B
Tuolumne button-celery Eryn~ium vinnatisectum 1B
"Data gathered using the California Department of Fish and Game's California Natural Diversity Database Quick Viewer for the following USGS quadrangles:
Amador City, Auk'UID, FiddJetown, Irish Hill, Ione, Jackson, Pine Grove and West Point. This is not an official CNDDB report. b California Native Plant Society (CNPS) " IB Listing-Rare or Endangered in California and elsewhere CNPS "2" Listing-Rare and Endangered in California, more common elsewhere CNPS "3" Listing-Need more information
Attachment B. Special-Status Species in the Lower Dry Creek Watershed8 Federal Status California Status DFG Species CNPS
Common Name Scientific Name Threatened Endangered Threatened Endangered of Concern Listingb Natural Communities
Coastal and Valley Freshwater Marsh
Great Valley Mixed Riparian Forest
Great Valley Valley Oak Riparian Forest
lone Chaparral
Northern Hardpan Vernal Pool
Valley Oak Woodland
Mammals
American badger Taxidea taxus ../
Birds
Bank swallow Riparia rfparia ../
Burrowing owl Athene cunicularia ,/
Golden eagle Aquila chrvsaetos ../
Great blue heron Ardea herodias
Great egret Ardea alba
Swainson's hawk Buteo swainsoni ../
Tricolored blackbird Agelaius tricolor ../
Wliite-tailed kite Elanus leucurus
Reptiles/Amphibians
California tiger salamander Ambvstoma califomiense ../ ../ Foothill yellow-leeged frog Rana boy/ii ../
Giant garter snake Thamnophis gigas ,/ ../
Northwestern pond turtle Emys (=Clemmys) marmorata ../
marmorata
Western pond turtle Emys (=Clemmys) marmorata ../
Western spadefoot Spea (=Scaphiopus) hammondU I ../
Fish
Sacramento splittail Po1;onichthys macrolepidolt1s ,/
In vertebrates
Midvalley fairy shrimp Branchinecta mesovallensis
Ricksecker's water scavenger Hydrochara rickseckeri beetle Valley elderberry longhorn Desmocerus californicus ../
beetle dimorphus
Vernal pool fairy shrimp Branchinecta lynchi ../
Federal Status California Status DFG Species CNPS
Common Name Scientific Name Threatened Endangered Threatened Endangered of Concern Listingb Vernal pool tadpole shrimp Lepidurus packardi ,/
Plants
Bisbee Peak rush-rose I Helianthemum su/frutescens " ;) Blue skullcap Scutellaria lateriflora 2
Bo1rn:s Lake hedge-hyssop Gratiola heterosevala ,/ lB
California linderiella Linderiella occidentalis
Delta: mudwort Limosella subulata 2
Delta tule pea Lathyrus jepsonii var. Jepsonii 1B
Dwarf downingia Downin'i{ia ousilla 2
Ione buckwheat Eriogonum apricum var. ,I ,/ 1B apricum
Ione manzanita Arctostaphylos myrtffolia ,I 1B
Irish Hill buckwheat Eriogonum apricum var. ,/ ,/ 1B
prostratum
Legenere Le~enere limosa lB
Mason's lilaeopsis Lilaeopsis masonii 1B
Parrv's horkelia Horkelia parryi 1B
Pincushion navarretia Nav-arretia mversii ssTJ. myersii 1B Rose-mallow Hibiscus lasiocarpus 2
Sacramento orcutt grass Orcuttia viscida ,/ ,/ 1B
Sanford's arrowhead Sa.vttaria sanfordii 1B
Tuolumne button-celery Eryn)!ium pinnatisectum 1B 6
Data gathered using the California Department of Fish and Game's California Natural Diversity Database Quick Viewer for the following USGS quadrangles:
BrucevilJe, Carbondale, Clay, Galt, Goose Creek, Lodi North, and Thornton. This is not an official CNDDB report. bCalifomia Native Plant Society (CNPS) "lB"Listing-Rare or Endangered in California and elsewhere CNPS "2" Listing-Rare and Endangered in California, more common elsewhere CNPS "3" Listing-Need more infonnation
Attachment C. 2000 census data for Amador County and Dry Creek watershed communities Geographic area %of Total White Black or American Asian Native Other Two or Hispanl Amador populatio African- Indian Hawaiian race more car County n America and and races Latino
populatio n Alaska Other (of any ,. .. ,_ ·- 1. 1;en1us count: members of ethnic aroups AmadorCitv 0.56% 196 178 0 2 0 0 8 8 18
Galt. Sacramento Co11rnv NA 19.472 13,726 225 204 553 31 3616 1H7 6485 lone cnv. Amador Countv 20.31% 7.129 4.128 1.271 164 120 12 1,292 142 1,437 Jackson citv, Amador Counlv 11.36% 3.989 3.731 20 55 23 3 74 83 258 Sutter Creek citv, Amador Countv 6.56% 2,303 2,106 5 30 24 7 49 82 134 Amador Couotv 100.00".l, 35100 30113 1.359 826 350 36 1,769 847 3,126 U. Ethnic groups as% of total
AmadorCitv 100.0% 90.8% 0.0% 1.0% 0.0% 0.0% 4.1% 4.1% 9.2% ,..,.n 100.0% 70.5% 1.2% 1.0% 2.8% 0 .2% 18.6% 5.7% 33.2% (one cltv. Amador County 100.0% 57.9% 17.8% 2.3% 1.7% 0.2% 18.1% 2.0% 20.2% Jackson city, Amador County 100.0% 93.5% 0.5% 1.4% 0.6% 0.1% 1.9% 2.1% 6.5% Sutter Creek city, Amador County 100.0% 91.4% 0.2% 1.3% i.0% 0.3% 2.1% 3.6% 5.8% I
Amador Countv 100.0% 8$.8% 3.9% 1.8% 1.0'.4 0.1% 5.0% 2.4% 8.9%
STA TE OF CALIFORNIA
Arnold Schwarzenegger. Governor
THE RESOURCES AGENCY
Michael Chrisman, Secretary for Resources
DEPARTMENT OF CONSERVATION
Debbie Sareeram, Interim Director
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Amador County Williamson Act Lands 2004
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Attacu1ment A. Special-Status Species in the Upper Dry Creek Watersheda Federal Status California Status DFG Species CNPS
Common Name Scientific Name Threatened Endanaered Threatened Endangered of Concern Listingb Natural Communities '
Ione Chaparral
Birds
Tricolored blackbird Agelaius tricolor ,/
Reptiles/Amphibians ' '
Northwestern pond turtle Emys (=Clemmys) marmorata ,/
marmorata
Invertebrates . ; .
Grady's Cave amphipod Sty!i!obromus !Zradvi
Valley elderberry longhorn Desmoc~us californicus ,/
beetle dimorvhus
Plants ,·
Bisbee Peak rush-rose Helianthemum suffrutescens 3
Ione buckwheat Eriogonum apricum var.
apricum ,/ ,/ 1B
Ione manzanita Arctostavhvlos mvrtifolia ,/ 1B
Irish Hill buckwheat Eriogonum apricum var. ,/ ,/ 1B
prostratum
Parry's horkelia Horkelia parryi 1B
Pincushion navarretia Navarretia mversii s:m. mversii 1B Prairie wedge grass Svhenopholis obtusata 2
Red Hills soaproot Chloro!,!alum !,!randiflorum 1B
Tuolumne button-celery Erynf!ium pinnatisectum 1B
'Data gathered using the California Department of Fish and Game's California Natural Diversity Database Quick Viewer for the following USGS quadrangles:
Amador City, Aukum, Fiddletown, Irish Hill, fone Jackson. Pine Grove, and West Point This is not an official CNDDB report. b California Native Plant Society (CNPS) "1B" Listing-Rare or Endangered in California and elsewhere CNPS "2"-Listing-Rare and Endangered in California, more common elsewhere CNPS "3" Listing-Need more infonnation
10 mi.
_ ....
Mokelumne River Watershed
in Proximity to the Delta
Proposed Project Area: Dry Creek and
Upper Mokelumne River Sub Watersheds
Dry Creek and UpperMokelumne
River Sub-Watersheds Within
the Mokelumne River Watershed
~NRCS=-
MOKELUMNE RIVER
5/11/10
WATER ENTITIES
03/17/10
NAME CREATED GOVNCE PUPOSE & MISSION MEMBERS
TYPE -
OTHER
ENTITIES
CABY
MRA Mokelumne River Authority
MRA Mokelumne River Association.
MRWS Mokelumne River Watershed Council
MWF MOU Mokelumne Water Forum - htJ[!./1" "'" . .:bmud.com/ni>out .:bnl11'1L1w.l.iJ1caiw t1 "'1Pf<l lCCl focrs h~d \.'mt1J..d ;1m11.: water forum web 3-07 11ili' DCW Dry Creek Watershed
UMRWA Created Upper Mokelumne River Water Authority
2000
MRWPA Mokelumne River Water and Power Authority
3 / i7/10
MOKELUMNE RIVER
WATER ENTITIES
03/17/10
NAME CREATED GOYNCE PUPOSE & MISSION MEMBERS
TYPE
CAMWRA
MEMBERS
AWA Legislation Specl Dist Amador Water Agency - http://www.amadorwa.com/ 5 supervisorial dist 1959 Provide treated water & waste water services countywide 5 elected directors Amador Incorp. County Part of CA 3ra congressional district. State assembly I 01 n district.
County 1854 State senate 1st district. htt1rl/v-.rww.co.amador.ca. us/ 5 elected supervisor CPUD Established Specl Dist Calaveras Public Utilities District - http://www.goldrush.com/~cpud/ 1934 Provides water to San Andreas and Mokelumne Hill 5 member board CCWD Formed Specl Dist Calaveras County Water District - http://v,W\.v.ccwd.om/ 5 elected directors 1946 Provide treated water to district members 5 supervi so rial dist Calaveras lncorp. County Part of CA 3ro congressional district. State assembly 251 n district.
County 1850 State senate 1st district. httQ://co.calaveras.ca.us/cc/ 5 elected supervisor JVID 1956 Jackson Valley Irrigation District 5 member board? -
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 EBMUD p. 2‐3 2.1.1.1 "Figure 2‐2 shows the distribution…" The text says that a large number of wells do not have construction depth or screen interval information. Were only the wells with construction information used to prepare the GW elevation contour maps for each principal aquifer? 2 EBMUD p. 2‐12 2.1.4.2
4th paragraph of Sec 2.1.4.2,
3rd sentence
"Flow in the Mokelumne
River below the Camanche
Reservoir varies
seasonally…"
Please modify the discharge values from Camanche Reservoir discussed in the third and fourth sentence of this paragraph. Releases from the Camanche Reservoir could be as low as 100 cfs during critically dry years and up to 5,000 cfs during the wet season. Since the Camanche Dam was completed in 1964, the maximum daily release from the Camanche Reservoir has not exceeded 5,000 cfs. The Mokelumne River flows recorded below Camanche Dam prior to 1964 are not representative of flows observed after the dam was built. 3 EBMUD p. 2‐48 2.1.9.2.1 "The horizontal hydraulic conductivity varies…" What is the basis for the statement that the horizontal hydraulic conductivity values in the model are considered low? If the conductivities are higher, what implications would that have on the results? 4 EBMUD p. 6‐19 6.2.5.3
Second paragraph of Sec
6.2.5.3, second sentence
"The longer term banking
project…"
Please change "will" to "may" in this sentence: The longer term project may use the same concept...
5 EBMUD p. 6‐19 6.2.5.3
Third paragraph of Sec
6.2.5.3, "As part of both the
pilot and longer‐term
projects…"
EBMUD is requesting that this sentence be removed as it does not accurately reflect the terms of the existing Agreement. 6 EBMUD p. 7‐6 7.4.1 EBMUD would like to be informed as the Mokelumne River Loss Study Project moves forward and is interested in being a participant and in providing technical input.
JANE WAGNER-TYACK
COMMUNICATION CONSULTANT
145 South Rose Street, Lodi, CA 95240 w 209-642-5105 w [email protected] ______________________________________________________________________________ August 25, 2019
VIA E-mail
Eastern San Joaquin Groundwater Authority
1810 E. Hazelton Avenue
P. O. Box 1810
Stockton, CA 95201
[email protected]
SUBJECT: Comments on the Groundwater Sustainability Plan Following are comments on elements of the GSP that I think need to be strengthened, based on concerns I have heard expressed in the community, including the wider environmental and social justice community.
While the database of interested parties may have been robust, as the GSP asserts (1.3.4.4), actual outreach to two important groups—people reliant on domestic or community water system wells, and disadvantaged communities—has not been robust. This is a consequence of a variety of factors, including the nature and jurisdictions of the GSAs in this subbasin; the way DWR has defined disadvantaged communities for SGMA purposes; and the lack of projects to which outreach can be tied at this stage in the process.
It is therefore in the best interests of the GWA to ensure that the GSP adequately covers the kinds of social and environmental justice concerns that might be voiced during robust outreach.
A note regarding style: Credibility of the entire GSP will benefit from greater use of the active voice rather than the passive voice. For example, the statement “Water Quality is not known to have adversely affected beneficial uses of groundwater in the Eastern San Joaquin Subbasin, generally” (2.2.4) is in the passive voice, which allows the writer to avoid mentioning any parties responsible for making this determination or the bases on which they have made that determination. Use of the passive voice can make a statement seem both vague and subtly evasive. That will be the case even if, as in this situation, other evidence in the document shows the statement to be literally true: we do not have enough data to know.
Water Quality
The case for setting minimum thresholds only for salinity based on the fact that other constituents of concern are managed through existing management and regulatory programs is not persuasively supported in the GSP.
2 Nitrate
2.2.4.2 says, “Increased nitrate concentrations have not been found to be related to groundwater management activities in the Subbasin.” This statement does not define “groundwater management activities” and does not identify those responsible for the finding of no relationship. Meanwhile, other evidence appears to contradict the assertions.
Prior to the assertion above, in the same paragraph, is the statement that “recent nitrate measurements above the MCL correspond to the overall historical trends and highlight areas with elevated Nitrate concentrations in more recent years.” What is the evidence that these elevated concentrations are unrelated to groundwater management? The superficial treatment of dairies in the GSP is notable given the fact that milk was San Joaquin County’s second top commodity in 2017. This is relevant to the discussion of nitrates as well as point source contamination (see below). Dairies are confined animal feeding operations (CAFOs), and CAFOs are linked to nitrates in water.
The Environmental Working Group’s Farm Subsidy Database lists 347 dairies in San Joaquin County that received Dairy Program subsidies between 1995 and 2019. (https://farm.ewg.org/top_recips.php?fips=06077&progcode=dairy&page=0) Not all of these are in the ESJ Subbasin. However, some are in Stockton, Ripon, Farmington, and west of Lodi, areas the GSP notes have higher nitrate concentrations. Was any effort made to track nitrate relative to dairy operations?
According to 1.2.2.2.6, Irrigated Land Regulatory Program and CV-SALTS, The ILRP monitors for “nutrients (such as TDS and nitrates) in surface and groundwater.” “…[There] are several representative monitoring sites [in the Eastern San Joaquin River Watershed] for the monitoring of dairies. The ILRP is in the process of developing a comprehensive monitoring network for future use to address ILRP data objectives. The San Joaquin County and Delta Water Quality Coalition members also monitor domestic wells for nitrate in high vulnerability areas.” However, this requirement only began January 1, 2019. So there is not a lot of data yet. (Note: The effectiveness of any monitoring network depends on actual participation, which even fines will not necessarily ensure.)
At 2.2.4.4.5, Emerging Contaminants, the GSP says, “Several studies, such as by Watanabe et al. in 2010, have recently been published or are underway regarding the potential link between dairies and the occurrence of pharmaceuticals in shallow groundwater in San Joaquin County.” If pharmaceuticals from dairies may be linked to groundwater, it cannot be plausibly argued that nitrate from dairies may not be similarly linked.
Arsenic
2.2.4.3 says, “Increased arsenic concentrations have not been found to be related to groundwater management activities in the Subbasin.” Again, the statement does not define “groundwater management activities” and does not identify those responsible for the finding of no relationship.
Meanwhile, 4.3 says “Arsenic will be monitored for information purposes and to track trends in arsenic concentrations. The Groundwater Sustainability Plan (GSP) does not include sustainability 3 goals, measurable objectives, or minimum thresholds for arsenic.” Why does the GWA plan to monitor arsenic if it is unrelated to groundwater management? Is it likely that goals, objectives, and minimum thresholds will be set later on the basis of monitoring? (Note: For Figures 2-59, 2-60, and 2-61—why are these showing uniform grids underlying the data points? It suggests that monitoring occurs on a uniform grid.) The rationale for not setting minimum thresholds for arsenic, nitrogen, and sulfate (at 3.2.3.1.1 Description of Undesirable Results) is that “these constituents are managed through existing management and regulatory programs within the Subbasin.” For example, the GSP mentions monitoring through the Central Valley Regional Water Quality Control Board Waste Discharge Requirement (WDR) Dairy program. The GWA will rely on “coordination with existing agencies” to ensure that regulations are being met. “Additionally, SGMA does not give GSAs land use authority, so a nexus must be present between groundwater conditions and groundwater pumping activities.” We need to explain what “nexus” refers to in this context. Also, how will the GSA coordinate with existing agencies?
Point Sources
As with nitrate and arsenic, the GSP provides no convincing support for the statement at 2.2.4.4 that “Point source contamination has not been found to be related to groundwater management activities in the Subbasin.” In fact, there is considerable evidence to the contrary.
Section 1.2.2.2.4, Division of Drinking Water, says, “DDW data was used in the development of this GSP to identify point-source contamination areas.” However, the use of that data appears to have been restricted in the GSP, which notes (2.2.4.4) that “point sources include leaking underground storage tanks, landfills, historical dry cleaners, and others” (emphasis added). CAFOs are point sources under NPDES regulations. Figure 2-62 accompanying the point source discussion shows only Active Investigation and Remediation Sites, not all point-source contamination areas, and the discussion focuses on fuel sites.
The GSP does not provide enough information to demonstrate either that CAFOs do not have any effect on groundwater in the Subbasin or that existing monitoring and regulatory programs will address the situation if there is an effect on groundwater.
The claim that “Point source contamination has not been found to be related to groundwater management activities in the Subbasin” is clearly contradicted by 2.2.4.4.1, which discusses plumes that have been publicized. (It would be better not to introduce this section with the word “publicized,” which suggests that the plumes are included in the GSP primarily because people already know about them.)
In the case of the City of Lodi, it is true that “cleanup [of the Busy Bee plume] [is] moving toward completion under CVRWQCB oversite” (should be “oversight”). However, Section 1.2.3.1.5 says that “…the [Lodi] General Plan recognizes that groundwater contamination and overdraft in the Eastern San Joaquin Subbasin can threaten the City’s ability to meet current water demands and limit future development….” This may or may not refer to the Busy Bee plume, but the City of Lodi clearly would not agree that in general, there is no connection between contamination and groundwater management in the Subbasin.
4 Similarly, Section 1.2.3.1.8 says that “The [Ripon] General Plan predicts that the City of Ripon may have to abandon a large number of wells as sources of potable water due to contamination….” The source of contamination is not mentioned in the GSP, but again, this concern reflects a connection between contaminated water quality and groundwater management.
2.1.1.2, Groundwater Quality Data, says, “The GAMA [groundwater ambient monitoring and assessment] database contains approximately 6,800 well sites through the Eastern San Joaquin Subbasin with over 1.6 million water quality measurements.” However, “significant data gaps remain.” For chloride, for example, “. . . out of the over 6,800 wells listed in GAMA for the Eastern San Joaquin Subbasin, no more than 700 chloride measurements were taken during any year since 2005.” Having such limited data adds to the implausibility of the claim that water quality is not known to have adversely affected beneficial uses of groundwater in the Eastern San Joaquin Subbasin.
Wells and Well Permitting
Information relative to wells is not robust in the GSP, a situation that is not entirely justified by data gaps. Also, the GSP takes a hands-off approach to well permitting. It is natural for people who learn that the Eastern San Joaquin Subbasin is in a condition of overdraft to expect well permitting to be coordinated with the GSP to achieve sustainability goals.
Section 1.2.1.1 (page 1-19) says that “Though there are overlaps and discrepancies in the designation of wells, domestic wells are largely private residential wells, public wells are municipal-operated wells, and production wells are for irrigation or industrial purposes.” These distinctions appear to overlook, or perhaps categorize as a “discrepancy,” the fact that San Joaquin County has 358 small public water systems, defined as having between 5 and 14 service connections. https://www.sjgov.org/department/envhealth/programs/default?id=26243 Some of these will be in the Eastern San Joaquin Subbasin. None of the figures showing well density appears to include these.
The present system of well permitting apparently does not provide the kind of information that it is supposed to provide. 1.2.2.1.5., Data Received Directly from GSAs, describes the Online System for Well Completion Reports (OSWCR), a DWR program that includes about 10,000 domestic wells in the ESJ Subbasin. “. . .[Drilling contractors] are required to submit a Well Completion Report to DWR for upload to the interactive OSWCR web site.” According to 1.2.3.4.1, San Joaquin County has established well standards that require “installing monitoring device(s) for groundwater extraction, elevation, and/or water quality.” So theoretically, extraction information is available.
But 2.1.1.1 says “Vertical data gaps are . . . pronounced, as lack of construction data is an obstacle.” In San Joaquin County, well owners can opt out of groundwater monitoring, which is apparently a major reason for data limitations. Section 1.2.2.1.1 says that for the CASGEM network monitored by CCWD, “additional wells may need to be added in the future if owners opt out of the monitoring network.” In San Joaquin County, a large portion of the wells in the CASGEM monitoring network are privately owned, and when SJCFCWCD sent consent forms, “about 40 were signed and returned.” Is it known how many wells are in this network, and what percentage of consent this represents? By contrast, in Stanislaus County, 17 wells in the Eastern San Joaquin Subbasin alone are in the CASGEM plan to be measured semi-annually.
5 Section 1.2.3.4, Well Permitting, makes it clear that in San Joaquin County and Calaveras County, the purpose of permitting is to prevent groundwater contamination. By contrast, permitting in Stanislaus County has a much broader objective. “In 2014, the DER adopted a Groundwater Ordinance to prohibit unsustainable extraction of groundwater in unincorporated areas of the County.” The GSP should address the question of why the whole Subbasin should not meet this standard. Anecdotal reports of new well drilling in eastern San Joaquin County express a belief that new agricultural wells are adversely affecting existing well owners and exacerbating overdraft in the area, a belief that the GSP does nothing to allay. In the absence of any resource management system with parameters that all groundwater users understand, civil actions will continue to be the only way to resolve disputes between competing users.
Dismissing concerns about the well-permitting process by saying that it is “ministerial” is no longer a convincing argument for the status quo in light of the rejection of Siskiyou County’s argument in the Scott Valley decision that the Public Trust Doctrine does not apply to the county’s issuance of ministerial well construction permits in Scott Valley. Although this decision applies to public uses in navigable waters, it is only a matter of time before the practice of giving a well permit to every property owner who asks for one, without regard to the impact on neighboring groundwater users and the shared aquifer, is subjected to similar scrutiny.
Recommendations
• Prefer the active voice to the passive voice to make clear who is responsible for the content of assertions.
• Reconsider the decision not to set minimum thresholds for nitrate, arsenic, and point sources, or strengthen the case for not doing so.
• Include more information about public water systems.
• Propose a Subbasin-wide well permitting standard that will address sustainability goals, or provide a justification for not doing so.
Jane Wagner-Tyack
cc: Glenn Prasad
Alicia Connelly
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Jane Wagner‐ Tyack
San Joaquin
County Public
Works
ES‐1 Introduction, Paragraph
2 "A Joint Exercise of Powers
Agreement...
"Is comprised of" misrepresents the meaning of "comprise." Preferable: "The GWA is composed of 15 Groundwater Sustainability Agencies" or the "The GWA comprises 15 Groundwater Sustainability Agencies." The same is true for the other two uses of "comprise" in this paragraph.
2 JWT " ES‐1 Introduction, Paragraph 2
SGMA wanted to see an advisory group that included a wide range of stakeholders.
This was not supposed to be just outreach to stakeholders to tell them what was being decided. Maybe you want to mention at the end of this paragraph that "Some input from the Sustainability Workgroup (described below) has also been incorporated into the GSP."
3 JWT " ES‐1ES‐2 "The GWA's jurisdictional
area…
Bulletin 118 and updated‐‐Do you mean "as" updated?
4 JWT " ES‐2ES‐3 "A stakeholder engagement
strategy…
Please delete "all" in the first sentence. The stakeholder engagement strategy is far from inclusive. Also, mention that this is a 24‐member Workgroup. 5 JWT " ES‐2ES‐4 "The Subbasin is located… On the third line, please insert "the" before "San Joaquin River." 6 JWT " ES‐3ES‐5 "The western and southern
portions…
The last sentence in this paragraph seems unnecessarily vague. What effects has the Sacramento‐San Joaquin Delta (note correct name for the Delta) had on groundwater levels in the Subbasin? What surface water has been imported for in‐lieu use? 7 JWT " ES‐3ES‐5 Paragraph beginning with "Groundwater quality… "Concerns" and "maximum" misspelled. Also, in the last sentence, "have not been able to be tied"‐‐SOMEONE's analysis has not tied elevated concentrations of other constitutents to groundwater management activities. I think the water quality argument will be vulnerable here, and it would be best to mention from the beginning whatever data or prior analysis you have to support this assertion. 8 JWT " ES‐3ES‐5 "As such… Need to correct spelling of "volume" and "concern" in the last sentence of the paragraph. 9 JWT " ES‐3ES‐5 "While the San Joaquin Delta… The Delta is properly referred to as "the Sacramento‐San Joaquin Delta." (Do a search of this for the whole document.) Also, third line, "alternations to," do you mean "alterations to"? 10 JWT " ES‐4ES‐6 "The method prescribed… The prior bulleted list is preceded by a statement with a colon. The bulleted item here isn't part of a list. This statement could be made part of the paragraph. 11 JWT " ES‐6ES‐7 "Under the intermediate climate change scenario… Reading that the annual groundwater overdraft is projected to increase to approximately 57,000 AF/year with climate change is likely to send the reader back to find out what the current overdraft is, but I don't see that number above, only a statement that the Subbasin has been overdraft for many years. For comparison purposes, provide an average or range of current overdraft. Also, briefly, what is it about climate change that will lead to greater overdraft? 12 JWT " ES‐7 ES‐8, next to Figure ES‐
6 "The monitoring networks… Line 5, delete "from" before "participating GSA." It isn't necessary. 13 JWT " ES‐7 Figure ES‐6 This map needs a legend for what kinds of wells the different shapes represent. 14 JWT " ES‐8ES‐9 "The DMS can be accessed… After the link, you might tell the reader to use the Guest login. 15 JWT " ES‐9ES‐10 "These additional evaluations… "modification of levels of pumping reduction" is confusing. You could just say, "These additional evaluations may lead to pumping modifications associated with the attainment of reliability." 16 JWT " ES‐9ES‐10 "Several projects… Delete "several," which suggests a small number. 17 JWT " ES‐9ES‐10 "The initial set of projects… "The initial set of projects WAS reviewed" or "The projects WERE reviewed"18 JWT " ES‐9ES‐10 "The projected supply of projects. . .
"Planned projects are anticipated to provide enough water to offset the projected 2040 supply imbalance of ______ AFY."
19 JWT " ES‐12 ES‐12 "The GSAs will evaluation options… It isn't clear how the two bulleted points ("Developing" and "Evaluation") relate to the paragraph that introduces them. Also, "Evaluating" would be the correct parallel to "Developing." Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Jane Wagner‐
Tyack
San Joaquin
County Public
Works
Last paragraph: "The
Eastern San Joaquin GSP. . ."
Introduce the earlier GBA here to distinguish it from the GSA. There was initial confusion; also, the GBA was responsible for much of the prior planning effort, and you will reference it at 1.1.4.3. ". . . fits in with these prior planning efforts, including the Eastern San Joaquin Groundwater Basin Authority (GBA), building on existing local management. . . ."
2 JWT " Page 1‐3 1.1.4 "The Eastern San Joaquin GSP. . ." Change 15 to 16 for number of GSAs and add back in Woodbridge Irrigation District (WID). 3 JWT " Page 1‐8 "Lockeford Community Services District…" In the second sentence, the references to "currently" and "in 2010" in the same sentence are confusing. "The District provides water and wastewater service to approximately 3,200 residents (as of 2010) in the unincorporated…" 4 JWT " Page 1‐9 "The City of Escalon…" "to meet domestic and industrial needs in the City"‐‐which City? Both the City of Escalon and the City of Tracy are named in this sentence. 5 JWT " " "Stockton East Water District…"
Delete "with" before "overlaps." "The SEWD GSA covers 101,000 acres of the District"‐‐meaning unclear. Is this 101,000 acres that are not part of another GSA? Insert "is" between "and" and "provided" at the end of the third line. Last line‐‐ "...two efforts preceding the current GWA that focused..." 6 JWT " " Add back Woodbridge Irrigation District.
7 JWT " Page 1‐14 "The Eastern San Joaquin Subbasin encompasses…" I believe that Thornton should be added as an unincorporated community. 8 JWT " Page 1‐18 1.2.1.1 "Figure 1‐11 shows…" "…within the region that includes the Eastern San Joaquin Subbasin." (Only one of these state parks is actually in the Subbasin.)9 JWT " Page 1‐25 1.2.2.1.5 "These data were provided…" On the first reference to the ESJWRM, write out "Eastern San Joaquin Water Resources Model" so that the reader doesn't have to refer to the list of acronyms. This is a fairly important model not mentioned earlier. 10 JWT " Page 1‐30 1.2.2.7.4 "Measure the volume of water…" "with sufficient accuracy"‐‐sufficient for what? This is extremely vague. If you can without misrepresentation, stop this point after "customers". Otherwise, clarify. 11 JWT " Page 1‐31 1.2.2.8 "All the major irrigation districts…" No pipelines? At the top of the next page, we learn that OID has over time replaced unlined laterals with PVC pipelines. 12 JWT " Page 1‐31 1.2.2.8 "While this entire lateral system…" "105 miles are inconsistent"‐‐meaning unclear. Please clarify. 13 JWT " Page 1‐32 1.2.2.9 "The observed recharge amount…" "…for a total recharge volume of about 65,000 AF since the inception of the project." 14 JWT " Page 1‐34 1.2.3.1.1
Sources are provided for all the other plan information in this section. What is the source of information for the San Joaquin County General Plan? Would it be appropriate to move "(SJC, 2016b)" to the end of this sections as "(San Joaquin County, 2016b)"? And what does "b" refer to?
15 JWT " Page 1‐35 1.2.3.1.8 "The General Plan predicts…" "may have to abandon a large number of wells as sources of potable water due to contamination,…"‐‐What kind of contamination? This is relevant to the Water Quality Sustainability Indicator. 16 JWT " Page 1‐51 1.3.5 "To date…" This sentence says that there has been "at least one meeting". The next sentence refers to "these meetings." These statements need to be consistent.
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Jane Wagner‐
Tyack
San Joaquin
County Public
Works
Para. 1, "The Eastern San
Joaquin GSP… End of 7th line, change "comprised" to "consisting." 2 JWT " " " Para. 4, "The county is presumed..." Delete. This sentence is redundant. 3 JWT " Page 1‐5 1.1.4.2 "Each of the 15 GSAs..."
Change "15" to "16" and change "have" to "has"‐‐"Each. . .has a voice. . .and has appointed". Correct parallelism of bulleted list: Approving budgets, Proposing guidance, Adopting rules, Approving any contracts, Reporting to, Approving and implementing a GSP. For second bulleted list, Recommending for both bullets. 4 JWT " Page 1‐6 1.1.4.3 "Central Delta Water Agency..." Add (CDWA) after the agency name to conform to the style for the other agencies. 5 JWT " Page 1‐7 "Eastside San Joaquin GSA…" Delete "comprised of"‐‐"Eastside San Joaquin GSA is a partnership…." 6 JWT " " "Calaveras County Water District…" Second to last line, insert "the" before "Calaveras River". 7 JWT " " "Stanislaus County…" First line, substitute "and" for "that"‐‐"and extends…" 8 JWT " Page 1‐8 "San Joaquin County…" Change "is comprised of" to "consists of" or "comprises." For a correct usage of "comprise," see the OID description directly above this entry. 9 JWT " " "San Joaquin County No.2…" "Almost 7,000 acres of San Joaquin County plus Cal Water are combined in San Joaquin County No. 2 GSA." 10 JWT " Page 1‐9 "South San Joaquin GSA…"
Substitute "encompass" (as in the SDWA description) for "is comprised of." "Comprise" is not the most accurate word to use in the first bulleted paragraph below. Better: "The cities of Manteca, Ripon, and Escalon account for approximately 20,000 acres of the District area."
11 JWT " Page 1‐10 "Exercise the powers…" Substitute "on" for "to"‐‐"Exercise the powers conferred on GSAs by SGMA." 12 JWT " Page 1‐22 1.2.2 "Statewide Monitoring Programs…" For consistency: add (DWR) after Department of Water Resources; insert Water Data Library before (WDL), add (CV‐SALTS) after Central Valley Salinity Alternatives for Long‐Term Sustainability. Also, for Dairy CARES‐‐Cares is apparently not an acronym.
The correct term is Dairy Cares.
13 JWT " Page 1‐26 1.2.2.2.3 "However, differences…" Remove the "s" from "creates." The subject/verb agreement is "differences…create". 14 JWT " Page 1‐26 1.2.2.2.6 "The 2017 SNMP…" Change "off" to "on"‐‐"was developed based on a detailed water quality analysis…" 15 JWT " Page 1‐31 1.2.2.8 "While this entire lateral system…" Ssubstitute "the entire lateral system historically consisted of open, unlined ditches" 16 JWT " Page 1‐32 1.2.2.8 "SEWD also uses…" Second paragraph on the page, 3rd line, substitute "estimated" for "considered."17 JWT " Page 1‐32 1.2.2.9 "Direct recharge projects…" Delete the second "Figure 1‐16" in the first sentence, at the end. 18 JWT " Page 1‐32 1.2.2.9 "Since 2003…" Add" has"‐‐"Since 2003, SEWD has operated…" 19 JWT " Page 1‐34 1.2.3.1.1 "Stakeholders informed…" Change this to "Stakeholder input informed…"20 JWT " Page 1‐34 1.2.3.1.5 "The 2010 General Plan Update…" Insert "input from"‐‐"...the 1991 General Plan was informed by input from community members…" 21 JWT " Page 1‐35 1.2.3.1.5 "As the primary source…"
Dangling modifier‐‐the General Plan is not the primary source of water supply. But also, groundwater is no longer the primary source of water supply for Lodi, which now gets about 50% of its water most of the time from surface supplies through an agreement with WID. Delete the phrase "As the primary source of water supply for the City of Lodi" and begin the sentence with "The General Plan..." 22 JWT " Page 1‐40 1.3.1 "Agricultural users…" Delete "of" after "hold." 23 JWT " Page 1‐42 1.3.4.2 "The GWA developed…" Delete "relied" and insert "the Workgroup"‐‐"…to promote stakeholder input and relied upon the Workgroup when developing…" 24 JWT " Page 1‐42 1.3.4.2 "The Workgroup included members…" Delete "and"‐‐"members from a variety of organizations who represent one or more…" 25 JWT " Page 1‐47 1.3.4.3 "With the support…" Two sentences have been telescoped here. Change to "detailing a stakeholder engagement strategy developed to achieve…" 26 JWT " Page 1‐47 1.3.4.4 "The database was developed…" There were no prior GWA engagement efforts (because there was no prior GWA). For "GWA", substitute "Eastern San Joaquin Subbasin engagement efforts…" 27 JWT " Page 1‐49 1.2.3.4 "Targeted outreach presentations…" Delete the apostrophe in "Manufacturers." They don't use it. The name style in Table 1‐4 is correct.
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Jane Wagner‐
Tyack
San Joaquin
County Public
Works
2 JWT " Page 2‐16 2.1.4.3 "Hardpan….However, in other areas…" "Pre‐Modesto formations" are mentioned here, but I didn't see those defined earlier, and the Geologic Time Scale in Figure 2‐5 appears not to be designed to include them. They are referenced again in Section 2.1.4.5.1. "During the Pleistocene Epoch when the Modesto and Riverbank formations were deposited..." Can you provide a second Time Scale showing more detail for the Pleistocene? 3 JWT " Page 2‐23 2.1.5 "The Eastern San Joaquin Subbasin…" This paragraph refers the reader to Figure 2‐15 and also refers to "the Central Valley geomorphic province and the granitic Sierra Nevada Geomorphic province." However, neither of these provinces is identified in Figure 2‐15. Also, it would be helpful to have Figure 2‐15 on the same page as this discussion. 4 JWT " Page 2‐23 2.1.5 "The most important fresh water‐bearing…" The sentence refers to the Mehrten and Laguna formations, but these have not been introduced earlier, so the reader has no context in which to place them. As with the Pre‐Modesto and Riverbank formations mentioned in 2.1.4.3 and 2.1.4.5.1, a geologic time scale should be provided.
5 JWT " Page 2‐27 Table 2‐2 Footnote
This footnote says that "Figure 2‐5 contains time scales corresponding to formations." It does not. As noted above, the time scale needs more detail for local formations for the Tertiary and Quaternary periods.
6 JWT " Page 2‐27 Table 2‐2 Water‐Bearing Properties
The table says that the Eocene is "Unimportant to fresh water basin except as possible contaminant source." Is saline water the only contaminant, or are there other possible contaminants? Any mention of contaminants is likely to be a red flag relative to groundwater quality discussions.
7 JWT " Page 2‐27 2.1.5.1.1 and 2.1.5.1.2 "The pre‐Ione Eocene rocks…" Again, if a figure like 2‐5 is going to be provided, it should include all the formations referenced in the text. 8 JWT " Page 2‐28 2.1.5.1.3 "The Oligocene‐Age Valley Springs Formation…" It appears that these local formations are spatial rather than (or in addition to) temporal. Figure 2‐16 is intended to show these formations, but it is VERY hard to read, with excessive grid detail that doesn't appear to be relevant to showing the major formations.
9 JWT " Page 2‐28 2.1.5.1.4 "Overlying the Valley Springs Formation…" Need different visuals for all formations listed under 2.1.5.1 10 JWT " Page 2‐32 2.1.6 "Uplift of the Sierra Nevada…" This sentence concludes with "for the east side of the Great Valley." "Great Valley" is not a term that has been used in this document previously, and it is not a commonly used term in this state. In fact, it isn't clear what it means. Does it refer to California's Central Valley? To the San Joaquin Valley? 11 JWT " Page 2‐38 2.1.7 "The analysis for this GSP…"
This sentence, at the top of page 2‐38, says that water wells and oil and gas wells are "indicated by an asterisk on the cross‐sections." The asterisks are completely illegible. In fact, the cross‐sections are impossible to read. 12 JWT " Page 2‐38 2.1.7 "The analysis inferred…"
The sentence at the bottom of the second paragraph on page 2‐38 says, "The analysis inferred formation contracts in place where this data was limited..." Can you explain what "formation contracts" are? Or do you mean that the formation contracts (decreases in size)?
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 13 JWT " Page 2‐42 2.1.9.1.4 "The clay is typically…" The sentence refers to the condition of the Corcoran Clay "as depicted on Figure 2‐ 22", but it is very hard to discern anything in Figure 2‐22. 14 JWT " Page 2‐47 Table 2‐3 Since there is no list of definitions, define "Aquifer Field" in the text or in a footnote to this table. 15 JWT " Page 2‐49 2.1.9.2.3.1 "The natural geochemical effects…" "The natural geochemical effects on water quality result to mobilize the elemental makeup of sediments"‐‐meaning unclear. Please rephrase to clarify. 16 JWT " Page 2‐50 2.1.9.2.3.1 "Per 23 CCR…"
This sentence sounds awkward and unncessarily legalistic, and it doesn't clearly apply to the rest of the section. That is, it isn't clear that the two lists that follow are intended to summarize the general water quality of principal aquifers; that seems to be covered in the next sections. Can you say this? "General water quality of principal aquifers is summarized in the following sections, as required by 23 CCR ...." 17 JWT " Page 2‐50 2.1.9.2.3.1 "Nitrogen, most commonly occurring as Nitrate…" The sentence says that nitrate (should be lower case) "is well understood as a result of fertilizer application". Actually, nitrate is well understood as a result of studies of the consequences of its agricultural use in fertilizer application. The following sentence says that "Naturally occurring nitrogen must also be discussed to have a complete understanding of the natural conditions" in the Subbasin. A better transition: "Nitrogen also occurs naturally in the Eastern San Joaquin Subbasin.
Extensive work..."
18 JWT " Page 2‐50 2.1.9.2.3.2 "Evaluating the historical trends…" Suggested rewrite for easier reading: "Evaluating the historical trends of these parameters is not straightforward. GAMA records include some groundwater quality results for the Eastern San Joaquin Subbasin going back to the 1940s. However, a thorough analysis requires a large amount of data on all the major cations and anions mentioned above. A large number of measurements of this kind were taken from 2005 to 2017, as shown in Figure 2‐27. Data from 2018 are not included because at the time of writing, that data was incomplete."
19 JWT " Page 2‐52 2.1.9.2.3.2 "Evaluating the years…"
Delete "a better idea" and just say "an idea," since there is not actually any other idea for "better" to refer to. Regarding the Trilinear Diagrams, is it customary to present these without a legend for the symbols?
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Jane Wagner‐
Tyack
San Joaquin
County Public
Works
2 JWT " Page 2‐8 2.1.2 "The Sierra Nevada…" Delete "is comprised of" and substitute "consists of". 3 JWT " Page 2‐8 2.1.2 "The material source…" Add "s" to "source" for correct subject/verb agreement, and add "the" before Sierra Nevada"‐‐"The material sources…are the Coastal Ranges and the Sierra Nevada…" 4 JWT " Page 2‐9 2.1.3 "The origin…" Changes "vary" to "varies" for correct subject/verb agreement‐‐"The origin…varies in geologic time…" 5 JWT " Page 2‐9 2.1.4.1 "Ground surface…" Change "and" to "to"‐‐"Ground surface elevations vary…from almost 1,000 feet…to around sea level…" 6 JWT " Page 2‐12 2.1.4.2 "Two major westerly flowing…" Add "the" before both "Stanislaus River" and "Mokelumne River". 7 JWT " Page 2‐12 2.1.4.2 "In additiion to the Stanislaus..." Delete "the" before "10 watersheds". 8 JWT " Page 2‐15 2.1.4.3 "Alluvial fan…" Change "Figure 3‐9" to "Figure 2‐9". 9 JWT " Page 2‐19 2.1.4.4 "Several districts receive…" Add "the" before "Stanislaus River". 10 JWT " Page 2‐23 2.1.5 "The most important fresh water‐bearing…" Lower case "f" in "Mehrten and Laguna formations" and "Riverbank and Modesto formations." 11 JWT " Page 2‐29 2.1.5.1.6 "The Turlock Lake Formation…" Substitute "consists" for "as consisting." 12 JWT " Page 2‐32 Figure 2‐18 Add "Water" to title‐‐"Base of Fresh Water Elevation Contours and Stockton Fault" 13 JWT " Page 2‐39 2.1.9 "The zones are…"
First bullet‐‐"Shallow Zone that consists of" (replace "is comprised of"); Second bullet‐ ‐"Intermediate Zone that consists of" (replace "is comprised of"). The third bullet is already correct.
14 JWT " Page 2‐39 2.1.9.1 Third and fourth bullets Insert "of" after "depth" in each case‐‐"Depth of discrete layers…" 15 JWT " Page 2‐41 2.1.9.1.1 "The shallow water‐ bearing…" Insert "and" after "geologic formations"‐‐"…are present west of the older geologic formations and extend across…"16 JWT " Page 2‐42 2.1.9.1.1 "Transmissivities…" "gpd/ft"‐‐gallons per day per foot? "gpd" is not on the list of acronyms. 17 JWT " Page 2‐43 2.1.9.1.4 "As depicted on the cross‐ sectiions…" Substitute "have" for "has"‐‐"…thickest sequences…and overbank fines…have been observed."18 JWT " Page 2‐45 2.1.9.2 "Recognition of…" Change "Recognition of" to "Recognizing" so that this bullet point reads like a sentence, as the others to. 19 JWT " Page 2‐45 2.1.9.2.1 "For depiction purposes…" Replace "comprised of" with "encompassing." 20 JWT " Page 2‐47 2.1.9.2.1 "The distribution of production wells…" Change "are" to "is"‐‐"The distribution…is provided…"21 JWT " Page 2‐49 2.1.9.2.3.1 "The USGS…" Replace "which encompasses" with "which includes." In the next sentence, change "is" to "are" for correct subject/verb agreement‐‐"natural geomechanical effects" is the subject of this clause.
22 JWT " Page 2‐49 2.1.9.2.3.1 "Rivers draining areas…" Delete "also" between "rocks" and "have". There is no other condition to which this cleaarly refers. 23 JWT " Page 2‐49 2.1.9.2.3.1 "Groundwater quality…" "…is characterized by Metzger and others in a 2012 study, Test Drilling …" Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 24 JWT " Page 2‐50 2.1.9.2.3.1 "Arsenic is of particular concern…" Insert "is" between "and" and "hazardous"‐‐"…is naturally occuring..and is hazardous…" 25 JWT " Page 2‐50 2.1.9.2.3.1 "Arsenic was detected…" Write out San Joaquin County instead of using SJC. (It is nice not to expect the reader to refer to the acronym list for everything.) 26 JWT " Page 2‐57 2.1.10 "Aquifer characteristics…" "actions" should be plural‐‐"…"a significant impact on how projects and management actions in one part of the basin…" Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 JWT
San Joaquin
County Public
Works
This section misrepresesents the situation in the Delta by suggesting that barriers have been installed to prevent seawater intrusion. No barriers prevent the inland movement of seawater into the Delta; it does occur, and managing it is an ongoing challenge. If you need a reference, I can provide one. Correction: "While the Delta ecosystem evolved with a natural salinity cycle that brought brackish tidal water in from San Francisco Bay, levees installed to allow development of agriculture, followed by development and operation of the Central Valley Project and the State Water Project, have altered the inward movement of seawater through the Delta.
Current management practices endeavor to maintain freshwater flows through a combination of hydraulic and physical barriers, and alterations to existing channels." Change "alternations" to "alterations of existing channels". I don't see the Water Education Foundation listed under References. Also, in the last sentence in this paragraph, delete "sources" and change "are" to "is"‐‐"...salinity in the Subbasin is due to other factors..."
2 JWT " Page 2‐77 2.2.4.1.1 "As shown in Fgure 2‐52…"
The sentence says that additional measurements above 250 mg/L are scatterred throughout SJC (I would just write out San Joaquin County), but the figure does not show any measurements outside the Subbasin.
3 JWT " Page 2‐95 2.2.4.4.1 "Since the discovery…"
This sentence says that groundwater monitoring and evaluation has resulted in removal of contaminant sources and implementation of remedial activities. That isn't something that just monitoring can do. When groundwater monitoring and evaluation identified point source locations for contamination, the City of Lodi initiated remedial activities.
4 JWT " Page 2‐94 to 2‐95 2.2.4.4.1
This entire section appears to contradict the claim in 2.2.4.4 that point source contamination has not been found to be related to groundwater management activities in the Subbasin. Broadly, for ALL similar statements (for example at 2.2.4.2 and 2.2.4.3), there needs to be a clear explanation of what "related to groundwater management activities" actually means.
5 JWT " Page 2‐95 2.2.4.4.2 "Approximately 134 sites…"
This sentence says that sites are doing investigation and remediation. The same statement is made in 2.2.4.4.3 and 2.2.4.4.4 . What is meant by sites? WHO is doing the investigation and remediation? Is this the responsibility of site owners? The RWQCB? Please name an agent or agents for these activities.
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 JWT
San Joaquin
County Public
Works
2 JWT " Page 2‐62 Figure 2‐35 Footnote 3 Delete comma after "line". 3 JWT " Page 2‐64 2.2.1.2 "Along the eastern side…"
Substitute "to" for "and" in this clause‐‐"…the lateral gradient ranges from approximately 21 ft/mi...to 16 ft/mi…" A range is always "from x…to y" (or "is between x and y").
4 JWT " Page 2‐76 2.2.4 "The primary naturally occurring…" Constituents "are related to..." or "relate to…" 5 JWT " Page 2‐76 2.2.4.1 "San Joaquin Delta Sediments…" IMPORTANT: There is no San Joaquin Delta, at least not in California. The San Joaquin River and the Sacramento River meet to form the Sacramento‐San Joaquin Delta. That is the correct name. I recommend doing Find for the whole GSP document to be sure that all of these uses of the name are correct. 6 JWT " Page 2‐76 2.2.4.1 "San Joaquin Delta Sediments…" "Emplace" means to put into position. Suggested revision: "Evaporation of groundwater in discharge areas introduces naturally occurring soluble salts into Sacramento‐San Joaquin Delta sediments."
7 JWT " Page 2‐77 2.2.4.1 "Deep Deposits…This results…" Comma after second "aquifer"‐‐"This results in a saline aquifer underlying the freshwater aquifer, and well pumping can result…" 8 JWT " Page 2‐77 2.2.4.1.1 "As shown…" Change "have" to "has" in the last line‐‐"…the number of measurements…has decreased…" (It is the number, not the measurements, that has decreased.) 9 JWT " Page 2‐87 2.2.4.2 "Under the ILRP…"
Write out "San Joaquin County" here, since it is part of the name of the Coalition.
Otherwise, it sounds like SJC and the Delta Water Quality Coalition are two separate entities.
10 JWT " Page 2‐94 2.2.4.4.1 ""The Busy Bee Plume…" Delete "and" after "closure" and insert a comma‐‐"…now has regulatory closure, with cleanup moving…" 11 JWT " Page 2‐95 2.2.4.4.2 "Of these sites…" Substitute "At" for "Of"‐‐"At these sites, petroleum hydrocarbon constitutents…" 12 JWT " Page 2‐95 2.2.4.4.3 "Of these sites…" Substitute "At" for "Of"‐‐"At these sites, pesticides…" 13 JWT " Page 2‐96 2.2.4.4.4 "Of these sites…" Substitute "At" for "Of"‐‐"At these sites, the most common constitutents…" 14 JWT " Page 2‐96 2.2.5 "Subsidence has not been…" Revise this sentence as follows: "There are no historical records of significant and unreasonable impacts from subsidence in the Eastern San Joaquin Subbasin."15 JWT " Page 2‐100 2.2.8 "The NCCAG database…" Revise this sentence as follows: "A working group consisting of DWR, California Department of Fish and Wildlife (CDFW), and the Nature Conservancy (TNC) developed the NCCAG database by reviewing publicly available state and federal agency datatsets…"
16 JWT " Page 2‐104 2.2.8 "The Plan identifies…" Typo: Should be "The Plan identifies GDEs as NCCAG‐identified areas that meet all of the criteria below." 17 JWT " Page 2‐104 2.2.8 "Areas with a depth..." Comma needed after "region" to prevent misreading, plus "s" on "plant"‐‐"Oak trees are considered the deepest‐rooted plants in the region, with a root zone…" 18 JWT " Page 2‐104 2.2.8 "Areas at least 150 feet from…" Add "to be"‐‐"…are assumed to be unable to access…and to be dependent on…" Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 12 Jane Wagner‐
Tyack
San Joaquin
County Public
Works
2‐108 2.3.1
"Because this process is
new…"
The relationship between these two ideas is not causal but coordinate. Revision:
"This process is new and has been developed under time constraints; the water budget assumptions will be refined in the future…"
3 JWT " 2‐113 2.3.4.2 "As private groundwater
pumping was estimated…"
"Therefore, groundwater pumping to meet agricultural and rural residential needs is calculated by the model based on meeting remaining demands after appropriate surface water delivery is made to respective areas." Please explain what is meant by "appropriate surface water delivery" and which areas are "respective" (and of what they are respective).
4 JWT " 2‐115 2.3.5 "Inflows…" Do you want to add "including urban runoff" to the third bullet? Urban runoff is discussed in detail in Footnote 5 of Table 2‐13. 5 JWT "2‐117 to 2‐118 Table 2‐13
To begin with, please put the table and the footnotes on facing pages. The Hydrologic Period row should show parallel information: For Historical: Water Years 1996‐2015 (20‐Year Period); for Current: Water Years 1969‐2018 (50‐Year Period); for Projected, Water Years 1969‐2018 (50‐Year Period). Without this information, it is hard to fairly evaluate the table in general and Footnote 1 in particular. In Footnote 5, "The historical calibration, with both less precipitation and smaller urban areas..."‐‐ since this represents a yearly average, explain why there is less precipitation. Finally, if surface water is diverted from one part of the Subbasin and delivered to another part of the Subbasin, does that show up somewhere here? Does that warrant a footnote?
6 JWT " 2‐119 to 2‐120 Table 2‐14 Same comments as for Table 2‐13 with respect to headings and footnotes. 7 JWT " 2‐121 to 2‐122 Table 2‐15
Same comments as for Table 2‐13 with respect to headings and footnotes. Also, footnote 1 says that differences in scenarios are related partly to "differences in theinfiltration parameters related to land use." This need to be explained. Also, please provide a footnote explaining why no South American Subbasin outflows are shown. 8 JWT " 2‐122 Table 2‐15 Footnote 4 refers to MAR projects. I'm pretty sure those weren't mentioned earlier in the document. Section 2.3.4.3 would be a logical place to do that. 9 JWT " 2‐123 Figure 2‐72
Labels on the bar graph should correspond to the discussion in the text above the graph. Thus, the right‐hand bar, for Inflow (and these are actually Surface Water Inflows), would show "Upstream Reservoir Releases" or "Reservoir Releases" rather than "Stream Inflows" for the green section (the source of the majority of inflows).
The orange section of the bar would be "Runoff of Precipitation." The yellow section would be "Return Flow of Applied Water." Another color needs to be used for "Stream Gains from Groundwater," as this is MUCH too dark to read. For the Outflow bar, the gray section should be labeled "Downstream Outflows," or better, "San Joaquin River and Mokelumne River Outflows," as in Figure 2‐78. The light blue section is "Stream Seepage to Groundwater." Where are "Surface Water Diversions"?
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 10 JWT " 2‐123ff 2.3.5.1, 2.3.5.2, 2.3.5.4
(Should 2.3.5.4 actually be 2.3.5.3?) For ALL the water budget figures, I encourage using a scale for Average Annual Volume that is the same for all hydrologic periods and all systems. This will be inconvenient in terms of document spacing, but it will convey much more clearly the water budget situation across scenarios and will improve the credibility of the document. It is not usually the intention to mislead with this kind of graphic presentation, but that is frequently the effect. 11 JWT " 2‐124 Figure 2‐73
Inflow categories in the bar graph correspond to the descriptions in the text except that "Total" is not necessary for either Surface or Groundwater Supply. The dark blue background, both here and in subsequent Land Surface System figures, makes the text too hard to read and should be lightened. For Outflow, the orange area should be "Surface Runoff of Precipitation," and the yellow area should be "Return Flow of Applied Water."
12 JWT " 2‐125 Figure 2‐74
Inflow categories in the bar graph correspond to descriptions, except that "Change in Groundwater Storage" is misleading. This is actually a deficit and should be identified that way, and a number could be put on it in the text , which just says "…the inflows do not meet the entire groundwater demand." The amount of the deficit is listed in the text for the current average (on page 2‐129) and for the projected average (on page 2‐132). Alternatively, you could omit that category from the bar graph and show that the Inflow bar is actually lower than the outflow bar. This would be an honest representation of the situation. Tucking the gray bar in the middle appears deceptive. For the Outflow bar, the orange section should be "subsurface Outflow to Neighboring Basins."
13 JWT " 2‐127 Figure 2‐75
See Comment #9 for Figure 2‐72. Labels should be consistent between text and graph and across graphs. Also, keep Inflow discussion first, as in the prior discussion and to align with the fact that Inflows are shown in the left‐hand bar. This will mean deleting "These" from the beginning of the paragraph directly above. 14 JWT " 2‐129 Figure 2‐77
Again, don't bury "Change in Groundwater Storage" in the middle. Call it a deficit, and show it at the top of the bar. It is already identified in the text as 48,000 AF/year.
Also, in the text, refer to groundwater use as "Groundwater pumping," as is done in the bar graph and also in the discussion on page 2‐124. Using the word "production" looks like an attempt to disguise what is actually going on. 15 JWT " 2‐130 Figure 2‐78
As in Figure 2‐72, the Inflo categories are "Reservoir Releases," "Runoff of Precipitation," "Return Flow of Applied Water", and "Stream Gains From Groundwater." Outflow categories are "San Joaquin River and Mokelumne River Outflows", "Stream Seepage to Groundwater", and "Riparian Intake from Streams." But again, surface water diversions are missing from the Outflow bar. The text mentions distribution to local growers of 370,000 AF/year. What about urban diversions?
16 JWT " 2‐131 Figure 2‐79 See Comment #11 on Figure 2‐73 for both Figure 2‐76 and Figure 2‐79. 17 JWT " 2‐132 Figure 2‐80 and accompanying text Again, don't bury "Change in Groundwater Storage" in the middle, and do call it a Deficit. In the text, (first paragraph) use "groundwater pumping" instead of "groundwater production." Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 18 JWT " 2‐133 Table 2‐17
Where do the numbers for the last row, "Change in Groundwater Storage" come from? They don't appear to arise from anything else in the table, where everything is in balance. Should that row be separated from the rest of the table? 19 JWT " 2‐135 2.3.7.2 "The methods suggested by DWR…" "…to ensure the resolution would be reasonable…"‐‐What is meant by "resolution" in this context? 20 JWT " 2‐150 Figure 2‐100
This title is misleading. Climate change will not produce more groundwater. The title should be "Simulated Changes in Groundwater Pumping due to Climate Change." Delete "production" from the Note.
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 12 Jane Wagner‐
Tyack
San Joaquin
County Public
Works
2‐110 Table 2‐12 Footnote 2 "Future evapotranspiration rates are assumed to remain the same as historical." Do you want to add any qualifiying statement here about climate change? 3 JWT " 2‐110 Table 2‐12 Footnote 5 Note that there's an error here for Reference source not found. 4 JWT " 2‐111 2.3.4.1 "Dry creek…" Change "was" to "were"‐‐"…flow estimates…were used…" 5 JWT " 2‐111 2.3.4.1 "Deliveries to agricultural areas…" To be consistent, write out all district names, or don't write out any of them. Also, "including" implies that not all entities are listed. If they are all listed, delete "including" and use a colon after "Subbasin." If you include acronyms after names (which is actually a good idea), put them in parentheses rather than brackets.
Brackets are correctly used in the section above for parenthetical references within parentheses.
6 JWT " 2‐114 2.3.4.3 "Surface water delivery projections…" Change "was" to "were"‐‐"...projections…were estimated…" (The noun with which a verb grammatically agrees is frequently not the closest noun.) 7 JWT " 2‐115 2.3.5 "The primary components of…" Fourth bullet, add "the" between "to" and "stream". 8 JWT " 2‐116 2.3.5 "The estimated water budgets…" "are provided herein" sounds stiff and formal, which is not the tone of the document overall. Suggestion: "…scenarios are provided below, with results summarized in Table 2‐13 and Table 2‐15." 9 JWT " 2‐123 2.3.5.1 "Because of these circumstances…" "…the water budget presented in Table 2‐12…" Table 2‐12 is a summary of water budget assumptions. It doesn't appear to be a water budget. Also, delete "of" between "estimates" and "contributions"‐‐"…the water budget…not only quantifies…but also estimates..."
10 JWT " 2‐124 2.3.5.1 "A groundwater overdraft estimate…" Delete "formerly" from this sentence. It is already clear that previous efforts have given a different estimate. 11 JWT " 2‐124 to 2‐125 2.3.5.1 "Such previous efforts…" NSJCGBA is not on the list of acronyms, and I am not aware of such an entity. Does this refer to a groundwater management plan by the Eastern San Joaquin County Groundwater Basin Authority? ESJCGBA should be on the list of acronyms, as well as GBA.
12 JWT " 2‐125 2.3.5.1 "When these changes occurred…" Sentence is awkward. Suggested revision: "The timing of these changes was often independent of hydrologic conditions…" 13 JWT " 2‐126 Table 2‐16 Footnote 6: Substitute "are" for "is"‐‐"Differences…are more related…" 14 JWT " 2‐126 Table 2‐16
Footnote 3: Revise: "…averaging of the resulting agricultural demand is less a function of water year type than of the time in the simulation when that water year fell."
15 JWT " 2‐131 2.3.5.2 "Inflows are comprised of precipitation…" Substitute "consist of" for "are comprised of." 16 JWT " 2‐132 2.3.5.4 "As expected, in wet years…" (This section should probably be 2.3.5.3.) Change "meets" to "meet" and delete the second "more of"‐‐"…there is more precipitation and surface water to meet the water demand…" 17 JWT " 2‐132 2.3.5.4 "Unlike the historical calibration…" Insert a comma between "averages" and "and"‐‐"…to calculate meaningful averages, and the supplies and demands are…" 18 JWT " 2‐134 2.3.6 "Therefore, to account for these uncertainties…" Delete "use of"‐‐"…a range of assumptions (from high‐end estimates to low‐end estimates)…" Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 19 JWT " 2‐136 Table 2‐18 "Reference ET"‐‐Use "Eto" as provided in the list of acronyms. 20 JWT " 2‐136 2.3.7.3.1 "The resolution of these perturbation factors…" HUC is not on the list of acronyms. Write out "Hydrologic Unit Code" here or include that in the acronyms. 21 JWT " 2‐137 2.3.7.3.1.1 "DWR change factors…" WY is not on the list of acronyms. Write out "Water Year" here orinclude that in the acronyms.
22 JWT " 2‐138 2.3.7.3.1.1 "The exceedance curves…" This sentence is hard to read, but I think what is meant is "…the projected condition scenario and the with‐climate‐change scenario." Add the hyphens. 23 JWT " 2‐140 2.3.7.3.1.2 "Streamflow simulated…" Should be "Streamflows" (plural) to agree with "and those derived using…"24 JWT " 2‐144 2.3.7.3.2 "Change factors are available…" Insert "are" between "and" and "spatially"‐‐"…are available on a monthly time step and are spatially defined…" 25 JWT " 2‐144 2.3.7.3.2.1 "Months with no precipitation…" Words appear to be missing. "…were assumed to have a monthly precipitation…" 26 JWT " 2‐146 2.3.7.3.2.2 "Refinement to the simulated…" Change "are" to "is"‐‐"Refinement…is shown…" Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 JWT
San Joaquin
County Public
Works
"The California Water Code
(CWC) defines…" Define "planning and implementation horizon." 2 JWT " Page 3‐1 3.1 "Groundwater levels in the Subbasin…" Define "implementation period." 3 JWT " Page 3‐10 3.2.2.1.2 "It is roughly estimated…"
Avoid using the passive voice to disguise a source of responsibility. WHO has estimated groundwater demand, and HOW? This information is central to the case we are making.
4 JWT " Page 3‐11 3.2.3.1.1 "Additionally, SGMA does not give…" "…so a nexus must be present between groundwater conditions and groundwater pumping activities." In plain English, what does this mean? 5 JWT " Page 3‐12 3.2.3.1.2 "Undesirable results occur…" "…and where these concentrations are the result of groundwater management activities." What kind of activities? How will we know? 6 JWT " Page 3‐19 3.2.6.2 "Current or historical issues…" To avoid obscurity associated with use of the passive voice: "In discussions of interconnected surface water, the GWA Board, Advisory Committee, Workgroup members, and GSA staff did not indicate signficant and unreasonable depletions, either currently or historically. Based on this input, this GSP assumes that historical conditions are protective of beneficial uses...." I suggest adding "however" at the beginning of the last sentence: "However, if groundwater levels were to fall lower than historical levels..." Regarding "qualified below", where? In the next paragraph? 7 JWT " Page 4‐3 4.1.1 "2. Robust and Extensive Historical Data…" It is worth providing some representative dates for historical data available in this Subbasin, especially since it is noted later that CASGEM data goes back to 2009. Let's not miss any opportunity to note that groundwater conditions have been monitored in this Subbasin for quite a long time.
8 JWT " Page 4‐9 4.3.1 "3. A Range of TDS Concentrations…" "Wells with historically "low" TDS concentrations…" What does this mean? Why is "low" in quotation marks? Quotations marks are sometimes used this way when the writer wants to put distance between the implied meaning and the actual situation.
That would be unwise in this case.
9 JWT " Pages 4‐9 and 4‐13 4.3.1 and 4.3.4
Section 4.3.1 lists the City of Lodi as one of the agencies monitoring and managing wells for groundwater quality, but the City of Lodi is not shown in Table 4‐5. The text should explain why not. Meanwhile, City of Lodi is listed in Table 4‐7, but there is a footnote that TDS has not been regularly monitored at White Slough sites. Should this footnoted information appear in Section 4.3.1 as well? 10 JWT " Page 4‐15 4.7.1 "The DWR's USGS…" Do you mean "guide for selection of wells" rather than "guide for collection of wells"? Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 JWT
San Joaquin
County Public
Works
2 JWT " Page 3‐3 3.2.1.1.1 Second bullet Delete "of" after "Reduction". 3 JWT " Page 3‐3 3.2.1.1.3 "Potential causes…"
Sentence is awkward and hard to read. Revision: "Undesirable results due to future chronic lowering of groundwater levels could result from the following: insufficient pumping offset/reduction in the basin that results in localized or basin‐wide groundwater level lowering; or delays in implementation of GSP programs or projects due to increased demand or regulatory, permitting, or funding obstacles." 4 JWT " Page 3‐4 3.2.1.2 "This examination evidenced…" Substitute "showed" for "evidenced." 5 JWT " Page 3‐5 3.2.1.2 "The GWA Board determined…" "…dewatering of domestic wells is a potential undesirable result that could be used to confirm the adequacy…" 6 JWT " Page 3‐5 3.2.1.2 "The 10th percentile…" "…to account for the fact that domestic wells may have been drilled…" 7 JWT " Page 3‐8 3.2.1.3 "The Margin is defined…" "…the difference between the minimum threshold and the measurable objective." 8 JWT " Page 3‐10 3.2.2.1.4 "If groundwater levels were to reach…" Make this all one sentence‐‐no period after "years", and separate with semi‐colons‐‐ "…effects could include running out of fresh groundwater to access in drought years; increased cost of access; reduction in beneficial uses, such as domestic supply; and changes to agriculture."
9 JWT " Page 3‐11 3.2.2.3 "As chronic lowering of groundwater levels…" This refers the reader to Section 3.2.5.3, but that section just sends the reader somewhere else. It should probably refer to Section 3.2.1.3, where measurable objectives and interim milestones for lowering of groundwater levels are discussed.
Also, insert "as" between "milestones" and "for".
10 JWT " Page 3‐12 3.2.3.1.4 "If groundwater quality…" Add "s" after "effect" and insert a comma and "which" after "supplies"‐‐"…the effects would potentially include…to access alternate supplies, which can be unaffordable…" 11 JWT " Page 3‐12 3.2.3.1.4 "Water quality degradation…" Add "or" after "practices"‐‐"…changes in irrigation practices or crops grown,…"12 JWT " Page 3‐14 3.2.3.3 "600 mg/L…" Delete "are" after "uses" in the last line‐‐"…will protect landscape uses against impacts…" 13 JWT " Page 3‐15 3.2.4.1.1 "There is the possibility…" Use the correct name for the Delta: "the Sacramento‐San Joaquin Delta". 13 JWT " Page 3‐15 3.2.4.1.3 "If seawater intrusion…" Use the correct name for the Delta: "the Sacramento‐San Joaquin Delta".14 JWT " Page 3‐15 3.2.4.1.4 "Water quality degradation…" Add "or" after "practices"‐‐"…changes in irrigation practices or crops grown,…" 15 JWT " Page 3‐18 3.2.5.2 "Historical declines in groundwater levels…" Add "in the Eastern San Joaquin Subbasin"‐‐"…declines in groundwater levels in the Eastern San Joaquin Subbasin have not resulted…" 16 JWT " Page 3‐18 3.2.5.3 "As chronic lowering…" The last line refers the reader to Section 2.2, Current and Historical Groundwater Conditions. It should probably refer to Section 3.2.1.3. 17 JWT " Page 3‐19 3.2.6.1.2 "An undesirable result…"
Add "in" to clarify parallelism, and use semicolons to make this sentence easier to follow‐‐"…if depletions resulted in the release of stored surface water…; in the decrease of acreage…; in the reduction in availability…; or in the elimination…." Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 18 JWT " Page 3‐19 3.2.6.1.4 "If depletions…"
Correct parallelism: "…insufficient surface water would be available to support diversions for agricultural or urban uses or to support regulatory environmental requirements."
19 JWT " Page 3‐19 3.2.6.1.4 "This could result…"
Substitute "pumping" for "production" and correct the parallelism: "This could result in increased groundwater pumping, changes in irrigation practices and crops grown, and adverse effects to property values and the regional economy." 20 JWT " Page 4‐1 4.1.1 "Representative monitoring…" Add "the" between "in" and "production"‐‐"…represent overall conditions in the production zone…" 21 JWT " Page 4‐3 4.1.1 "4. Increased Density…" Substitute "insight into" for "insightful information about"‐‐"…may provide insight into groundwater dynamics…"22 JWT " Pages 4‐3 and 4‐4 4.1.2 "The 76 wells…" Correct the parallelism of the numbered items: "1. They use an existing data source…2. They provide reliable…3. They are in many cases new, having been constructed…" Also correct the parallelism for the second numbered list, on page 4‐ 4, by making the first item a sentence, as the others are: "1. They use an existing data source and have a historical data record;"
23 JWT " Page 4‐4 4.1.2 "The broad monitoring network…" Make this two sentences: "…San Joaquin County's Flag City wells). These will be monitored…" 24 JWT " Page 4‐6 4.1.3 "Taken using a CASGEM‐ approved…" Correct agreement: "using a CASGEM‐approved … method…" or "using CASGEM‐ approved…methods…" 24 JWT " Page 4‐6 4.1.3 "Typical groundwater level measurement…" Add an "s" to "include"‐‐"…measurement equipment…includes…" 25 JWT " Page 4‐7 4.1.4 "The spatial location…" Change "were" to "was" for correct subject/verb agreement: "…spatial location…was based…"26 JWT " Page 4‐8 4.3 "The representative monitoring network…" Change "are" to "is"‐‐"the representative monitoring network is used…" 27 JWT " Page 4‐10 4.3.1 "5. Current TDS Monitoring…" Add comma, and "they" in the second sentence: "These wells are equipped…consistent measurements, and they represent…" 28 JWT " Page 4‐14 4.3.5 "A total of 10 monitoring wells…" Revision: "The representative monitoring network consists of a total of 10 monitoring wells, a density of 0.8 wells per 100 square miles." 29 JWT " Page 4‐14 4.3.5 "The total number of wells…" Add "s" to "meet"‐‐"The total number…meets DWR's recommendations…" 30 JWT " Page 4‐14 4.7 "Additionally, areas…" Insert "a" between "present" and "limitation"‐‐"…wells present a limitation…" Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Jane WagnerTyack San Joaquin County Public Works Page 6-1 6.1 "The Eastern San Joaquin Subbasin…" Correct spelling of "offest" to "offset." 2 JWT " Page 6-1 6.2.1 Bulleted list Third bullet: correct spelling to "cost-effective." 3 JWT " Page 6-2 6.2.3 "The initial set of projects…" For correct subject/verb agreement, change "were" to "was"--"The initial set…was reviewed…" Next sentence, change "are" to "is"--"A final list…is included…" 4 JWT " Page 6-2 PLEASE PROVIDE A MAP SHOWING THE LOCATIONS OF THE PROJECTS.5 JWT " Page 6-3 Table 6-1 Suggest footnoting the annual cost of Project 4 to explain why it is so much higher than the others. (Mostly annual cost of water purchase.) 6 JWT " Page 6-4 Table 6-1 For Project 11, Current Status, change "partied" to "parties." 7 JWT " Page 6-8ff Various "Estimated Costs and Plans to Meet Costs…" In most of the project descriptions that follow, subject/verb agreement needs to be corrected in one of these ways: "The estimated cost for this project includes…" or "The estimated costs for this project include…" 8 JWT " Page 6-11 6.2.4.3 "Installation of other components…" "Installation" is the subject of the sentence. Everything between that and the verb is part of a modifying phrase. So the verb must be "is", not "are"--"Installation…is in the planning stage." 9 JWT " Page 6-12 6.2.4.4
"Trigger for
Implementation…The
availability…"
Suggest inserting "reduced" before "availability" to better reflect the meaning of the sentence--"The reduced availability…would be the only potential cause for a reduction in SWFT production."
10 JWT " Page 6-12 6.2.4.5 "Project status…" Insert "been" between "has" and "completed"--"…project has been completed…" 11 JWT " Page 6-13 6.2.4.5 "Time-Table…" Insert "been" between "has" and "completed"--"…project has been completed…" 12 JWT " Page 6-13 6.2.4.5 "Circumstances…" Insert "been"--"Construction for this project has been completed" (or "is complete"). 13 JWT " Page 6-13 6.2.4.6 "As water is diverted…" Change "has" to "have"--"until 7 years…have elapsed." 14 JWT " Page 6-13 6.2.4.6 "However, individual applicants…" Delete "s" on "on permits", or delete "a." 15 JWT " Page 6-15 6.2.4.7 "Project Status" Delete "at"--"Design for this project is 60 percent complete…"16 JWT " Page 6-15ff Various For most of the Time-Table statements that follow, insert "was" before "initiated" or substitute "began." 17 JWT " Page 6-15 6.2.4.8 "SEWD and CSJWCD…" Substitute "overlie" for "overly. Insert "subject to" between "and" and "historical"-- "…dependent on groundwater and subject to historical overdraft…"18 JWT " Page 6-16 6.2.4.8 "Project
Status…Environmental
review…"
For "implemented," substitute "done," or say that a review "may be required." 19 JWT " Page 6-17 6.2.4.8 "Circumstances for Implementation…" Last line, insert hyphen between "as" and "needed"--"…on an as-needed basis…"20 JWT " Page 6-17 6.2.5.1 "How Project…The contract is long-term…" Correct punctuation: "The contract project is long-term; however, water availability…" 21 JWT " Page 6-18 6.2.5.1
"Circumstances for
Implementation…As
scenarios change…"
Add "the" between "with" and "landowner."
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 22 JWT " Page 6-19 6.2.5.3 "NSJWCD will control…"
Change "withdraw" to "withdrawal" and change the second "pumping" to "pumped"-- "NSJWCD will control the withdrawal of the banked water…and then conveying the pumped groundwater…."
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1JWT
San Joaquin
County Public
Works
Praise up front: Some of the graphics in this document are very good, and could serve as a model for others that are not so good. Figure 4-3 is sharp, and the colors and shapes can be adequately differentiated. It is worth bearing in mind that fairly or not, every unclear graphic is likely to be perceived as intentionally deceptive. 2 JWT " Page 1-4 Figure 1-3
Colors, especially in the legend, are hard to distinguish, and of course Woodbridge Irrigation District will need to be added back. Also, not every area has a corresponding number. Would broadening the color scale from blue/green help? 3 JWT " Page 1-11 Figure 1-4 Legend and logo are fuzzy. Sacrifice the second frame?4 JWT " Page 1-12 Figure 1-5 Colors for East Contra Costa and Tracy subbasins are hard to differentiate, and Tracy and Cosumnes are too similar. I-5 symbol is fuzzy.5 JWT " Page 1-14 Figure 1-7 County boundaries are not adequately distinguishable from other lines. Sacrifice the second f 6 JWT " Page 1-15 Figure 1-8 Fuzzy. Also, the colors make it hard to distinguish SDACs from DACs at this scale. Make it bigger if possible. 7 JWT " Page 1-16 Figure 1-9
Sacrifice the second frame to gain a little size? The map on the facing page doesn't have it. Here and afterward, favor a slightly larger map over a second frame for the figure.
8 JWT " Page 1-17 Figure 1-10 Numbers for roads and highways are fuzzy. 9 JWT " Page 1-18 Figure 1-11 Fuzzy. Also, Lakes and Waterways are too similar in color to Carnegie SVRA, even though the latter has a border. 10 JWT " Page 2-5 Figure 2-3 Highway symbols could be sharper. Landscape orientation is good. 11 JWT " Page 2-10 Figure 2-6 Really nice.12 JWT " Page 2-11 Figure 2-7 Identify Bear Creek, as in Figure 1-5.13 JWT " Page 2-14 Figure 2-8 Some colors are too similar for adjacent watersheds, and blue is always problematic if it is also used for Lakes and Waterways. 14 JWT " Page 2-15 Figure 2-9 Too small; it is very difficult to read city names. Given general layout issues on this and the following page, there probably isn't much that can be done about this. 15 JWT " Page 2-17 Figure 2-10 A bit fuzzy. Especially since there is room, show this with a landscape orientation. 16 JWT " Page 2-18 Figure 2-11 A lot of place and feature names on this map are virtually illegible, and the legend is too small. Figure 2-12 is only slightly better. Maybe nothing can be done about this. 17 JWT " Page 2-22 Figure 2-13 Fuzzy.18 JWT " Page 2-25 Figure 2-16 The underlying grid distracts from the formations this figure is intended to show, which are hard to distinguish at best. Some colors in the legend are too similar--how is Valley Springs distinguished from Tulare? The letters on the color blocks are illegible, and they are important because they are referred to in the Table that follows. Road and highway designations on the map are fuzzy. Why is the word "Flood" floating on the right in Calaveras County?
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 19 JWT " Page 2-31 Figure 2-17
It looks like most of the map units shown in the legend are not features of this subbasin, so maybe this could be simplified by including only those that are. Letters on the color blocks are illegible. It is hard to tell where the Stockton Arch is. Part of the name of "Bear" on the right is missing. Would it be possible to lay the map unit colors and detail over a map with less fuzzy place-name detail and just major roads and water features?
20 JWT " Pages 2-35 to 2-37 Figures 2-20 to 2-22
Most of the detail in these cross-sections is completely illegible. Of course most readers will not care about the individual well identifiers, but if this information is important enough to include in the GSP (and it is referred to several times in the text-- for example, some of these well identifiers apparently have asterisks), then it is important enough to be legible. Using the full page instead of allowing large margins might help a bit, as would putting each cross-section on its own page. Could the legends go underneath instead of beside the cross-sections? 21 JWT " Pages 2-40 to 2-41 Figures 2-23 and 2-24 Well depth colors are indistinguishable, and identifiers could be sharper. Bigger might be better. Landscape orientation would help.22 JWT " Page 2-46 Figure 2-26 There is certainly room here for a landscape orientation, which has just been used for Figure 2-25. 23 JWT " Page 2-51 Figure 2-27 Should definitely be shown in landscape. There is room. 24 JWT " Page 2-52 Figure 2-28 Why no legend? Is everyone supposed to know what these symbols represent? 25 JWT " Page 2-54 Figure 2-31
Different chloride concentrations are impossible to distinguish. I'm working from a hard copy, and just to be sure that I wasn't quibbling about something that would be visible in a different medium, I downloaded this figure and expanded it to fill my desktop computer screen. I still can't tell the difference in concentrations. Don't use a graded color scale?
26 JWT " Page 2-55 Figure 2-32 See comments for Figure 2-31. There is room for landscape orientation for both these figures, but that alone won't solve the problem.27 JWT " Page 2-60 Figure 2-34 This figure is remarkably legible, given the detail it has to convey. The legend is nice and sharp.28 JWT " Pages 2-65 and 2-70 Figures 2-37 and 2-38 Use landscape orientation. Maybe we'll be lucky and they will end up on facing pages.
29 JWT " Page 2-68 Figure 2-39 Correct name of Swenson Gold Course well. It is Swenson Golf Course. Landscape? 30 JWT " Page 2-74 Figure 2-50
This figure is misleading in an important way. The subbasin has a large enough change in groundwater elevation that DWR has put us in the critical overdraft category, but all that shows here is a faintly wavy line at the top of the graph. A separate graph showing everything above 50 MAF at a different scale would more honestly illustrate the situation.
31 JWT " Page 2-75 Figure 2-51
In the legend, green and blue, and brown and pink, are too difficult to distinguish, although they work OK in the chart itself. Make the boxes bigger? Landscape orient this figure?
32 JWT " Pages 2-78 and 2-79 Figures 2-52 and 2-53 Landscape for both? 33 JWT " Page 2-81 Figure 2-54 Yellow hard to see, orange impossible, especially if it is in a city. Landscape? 34 JWT " Pages 2-83 through 2-86 Figures 2-55 through 2- 58 Symbols for different levels of maximum TDS are indistinguishable. (Figure 2-58 is slightly sharper than the others.) Compare to Figure 4-3. Landscape? Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 35 JWT " Page 2-97 Figure 2-64
Road identifiers are REALLY fuzzy, and county names and other features are almost illegible. Numbers in the legend are fuzzy. Is this partly the result of merging the regular subbasin map with InSAR data?
36 JWT " Pages 2-98 and 2-99 Figures 2-65 and 2-66 Landscape? 37 JWT " Pages 2-101, 2-103, and 2-105 Figures 2-67, 2-68, and 2-69 Yellow is too hard to see. Figure 2-68 is also fuzzier than the other two.38 JWT " Page 2-150 Figure 2-101 This figure warrants its own page, with larger boxes to make the colors in the legend distinguishable. Add labels on the right side of the graph above and below the middle line for Demand and Supply, and split the legend identifiers accordingly to help the reader match them to the colors on the graph.
39 JWT " Page 2-151 Figure 2-102 Again, the colors in the legend are hard to differentiate, although they work reasonably well in the graph itself. 40 JWT " Page 3-6 Figure 3-2 Colors for Select Unincorporated Communities and Cities are too hard to differentiate. 41 JWT " Pages 4-5 and 4-11 Figures 4-1 and 4-2 Fuzzy. Compare to Figure 4-3.
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter
Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1JWT
San Joaquin
County Public
Works
"Elevation." If you do that, add "Water" in the legend also. 1 Memorandum
DA T E : Laura Foglia, Ph.D
Katrina Arredondo, Ph.D
Olin Applegate, M.S.
1480 Drew Ave., Suite 100
Davis, CA 95618
530.753.6400
[email protected]
[email protected]
[email protected]
August 26, 2019
T O: Eastern San Joaquin Groundwater
Authority ([email protected])
S U B J E C T : Groundwater Conditions and Management
in the Eastern San Joaquin
Subbasin/Comments on Groundwater
Sustainability Plan Draft Chapters
1. INTRODUCTION
The Eastern San Joaquin Groundwater Authority (ESJGA), which is a joint power authority, must complete a GSP by January 31, 2020 for the critically overdrafted Eastern San Joaquin Subbasin (ESJ Subbasin, or Subbasin). Larry Walker Associates was asked to review and provide comments on the draft Groundwater Sustainability Plan (GSP) by agricultural interests within the Subbasin. These agricultural interests wish to ensure that the GSP accurately reflects conditions within the Subbasin and effectively addresses overdraft conditions in compliance with the Sustainable Groundwater Management Act (SGMA). This memorandum provides initial comments on the analysis of the groundwater conditions and proposed management in the ESJ GSP, as described in publicly released draft chapters.
1 2. COMMENTS ON EASTERN SAN JOAQUIN GSP DRAFT CHAPTERS Draft chapters of the ESJ Subbasin GSP were released in three Bundles in May and June 2019.
The complete GSP draft was released for public comment on July 10th.
This memorandum provides comments on: (1) the Eastern San Joaquin Subbasin water budget; (2) the draft GSP’s characterization of current groundwater conditions; and (3) opportunities for local recharge with surface water to address overdraft conditions. 1 Available at: http://www.esjgroundwater.org/. Although the comment deadline is listed as August 25, 2019, Civil Code 12a extends the deadline to the following business day. We suggest setting future deadlines on business days to avoid confusion.
2 Topic 1. Eastern San Joaquin Subbasin Water Budget
Water budgets were developed for the draft GSP to provide a quantitative account of water entering and leaving the Subbasin. Water enters and leaves due to natural conditions, such as precipitation and streamflow, and/or through human activities, such as groundwater pumping or recharge from applied water. Interconnection between the groundwater system and river/streams accounts for other exchanges. Quantities presented for the water budget components of the Subbasin provide information on historical, current, and projected conditions as they relate to hydrology, water demand, water supply, land use, population, climate variability, groundwater and surface water interaction, and groundwater flow.
Water budget quantities presented in the GSP are based on simulation results from the Eastern San Joaquin Water Resources Model (ESJWRM). The ESJWRM simulates the major hydrologic processes that affect the land surface, stream, and groundwater systems in the Subbasin. The major hydrologic processes can be represented by separate water budgets which detail inflows and outflows occurring at the stream level, land surface level, and groundwater. Estimated water budgets are prepared for historical conditions, current conditions, and projected conditions scenarios. This examination focuses on the groundwater water budget.
The primary components of the groundwater system are:
• Inflows
o Deep percolation from precipitation, applied water (surface water and groundwater) for agricultural lands, and applied water (surface water and groundwater) for outdoor use in the urban areas
o Stream seepage (stream losses to groundwater)
o Other recharge (including unlined canals/reservoir seepage, local tributaries seepage, and Managed Aquifer Recharge projects)
o Subsurface inflow
• Outflows
o Stream gain from the groundwater system
o Groundwater pumping
o Subsurface outflow
• Change in groundwater storage: This reflects average annual change in groundwater storage
The average annual water budget for the groundwater system as presented in the GSP is presented in Table 1. As shown, the historical groundwater budget has greater outflows than inflows, leading to an estimated average annual decrease in groundwater storage of approximately 41,000 AF/year, or roughly 5% of the total inflow for this period. This overdraft estimate represents a refinement over previous efforts, which formerly estimated levels of overdraft to be between 70,000 AF and 150,000 AF annually. The current conditions scenario estimates average annual inflows of 959,000 AF/year and average aquifer outflows of 1,007,000 AF/year, resulting in an average annual deficit in groundwater storage of 48,000 AF/year, or roughly 5% of the total inflow for this period. Under projected conditions, the groundwater system experiences an average of 939,000 AF/year of inflow each year, and total discharges of 973,000 AF/year, resulting in an annual deficit in groundwater storage of 34,000 AF/year, or roughly 4% of the total inflow for this period (GSP, Table 3-4). 3 Table 1. GSP Average Annual Water Budget – Groundwater System (AF/year) Component Historical Calibration
(AF/year)
Current Conditions
(AF/year)
Projected Conditions
(AF/year)
Hydrologic Period Water Years 1996 – 2015 50-Year Period 50-Year Period Total Inflow 811,000 959,000 939,000
Total Outflow 852,000 1,007,000 973,000
Outflow due to
Groundwater Pumping 692,000 851,000 801,000
Change in
Groundwater Storage 41,000 48,000 34,000
As presented in the draft GSP, the groundwater water budget is approximately in balance. In all three scenarios, groundwater pumping represents the largest groundwater system outflow, representing 81%, 85%, and 82% of total outflow for the historical calibration, current conditions, and projected conditions, respectively. Groundwater pumping for all three scenarios is estimated by the ESJWRM based on the need for additional water to meet remaining demands after surface water deliveries occur. Differences in demand largely drive the amount of groundwater pumped, and sustainability cannot be met if the largest outflow of the water budget, groundwater pumping, is estimated solely based on consumptive use methodology as closure to the groundwater water balance. If this information is available, it should be used. A water budget should also be developed to address reasonably foreseeable drought conditions.
In contrast to the draft GSP’s analysis presenting the groundwater water budget as relatively in balance, the GSP also acknowledges the large groundwater depression in the central portion of the Subbasin (GSP Figures 3-37 and 3-38). Long-term trends from 10 wells distributed across the Subbasin with periods of record greater than 40 years show that groundwater elevations have declined over time throughout most of the Subbasin. The average groundwater decline was quantified as -0.5 ft/yr for the period 1996-2015. However, due to the fact that this analysis only includes two wells near the cone of depression, the investigation should be expanded to focus on additional wells located within the sphere of influence of the problem area. This is also true for the Vertical Gradient analysis provided in draft GSP Section 3.4.1.2.1, which lacks any wells located in the southern portion of the Subbasin (GSP Figure 3-39). Groundwater conditions in additional wells should be depicted in the GSP and monitored in order to track the occurrence of undesirable groundwater effects. Additional wells would also assist in tracking the benefits of recharge (discussed below).
The GSP presents analysis on interconnected surface water systems (GSP Section 3.4.6). This section includes figures showing the Subbasin’s losing and gaining streams (GSP Figure 3-65), as well as the interconnected and disconnected streams (Figure 3-66). Interconnected surface waters are surface water features that are hydraulically connected by a saturated zone to the groundwater system. GSP Figure 3-65 and 3-66 shows rivers at the center of the Subbasin as always losing and disconnected, demonstrating that the general trend is for groundwater not to be able to provide any baseflow to the rivers and with groundwater levels always declining.
Furthermore, draft GSP Figures 3-37 and 3-38 lack districts and landmarks, making it difficult to interpret the location and detail of the groundwater depression, including the overlying water 4 agencies. In addition, indicating groundwater levels below ground surface (BGS), rather than above mean sea level (MSL) would be helpful to better understand groundwater conditions.
Topic 2. GSP Unduly Minimizes Overdraft Conditions
The California Department of Water Resources (DWR) lists the ESJ Subbasin as critically overdrafted. As defined by SGMA, a critically overdrafted groundwater basin is “[a] basin is subject to critical overdraft when continuation of present water management practices would probably result in significant adverse overdraft-related environmental, social, or economic impacts.”2
Groundwater levels in the ESJ Subbasin have been monitored since at least the 1950s. A drop of groundwater levels to deeper depths indicates groundwater depletion, while a rise of groundwater levels to shallower depths indicates groundwater recharge. Changes in groundwater levels can arise from seasonal variation and increased groundwater pumping during droughts.
Analysis provided by the Department of Water Resources (DWR) Groundwater Information Center Interactive Map Application3(Figure 1) shows the change in groundwater elevation for three time periods (B: Spring 2004-2014, C: Fall 2006-2016, D: Spring 2008-2018; dark red represents 40 feet of decline, orange represents 20 feet of decline, green represents 10 feet of increase). As shown, during the period spring 2004-2014 (Map B) groundwater levels declined 20 feet in the south-central portion of the Subbasin, while during the period spring 2008-2018 (Map D), groundwater levels declined up to 40 feet in the southern portion of the Subbasin.
Changes for the period Fall 2006-2016 are increasingly pronounced throughout the Subbasin as fall is the lowest period for groundwater elevations due to lack of seasonal recharge, and increased reliance on pumping due to decreased surface water availability during the peak of the irrigation season. It is noted that groundwater elevation changes are impacted year to year by water year type and available surface water deliveries. Although the three time periods do not present a spatially consistent change in groundwater elevation (with the exception of the depression in the south-central portion of the Subbasin), they do depict the overall trend of a persistent decrease in groundwater elevation throughout the Subbasin. While these changes in groundwater elevation are measured by DWR, the GSP presents minimal historical modeled change in storage (GSP Figure 3-50).
2 Available at: https://water.ca.gov/Programs/Groundwater-Management/Bulletin-118/Critically-Overdrafted-Basins 3Available at: https://gis.water.ca.gov/app/gicima/
5 Figure 1. Change in Groundwater Elevation, Eastern San Joaquin Subbasin: Department of Water Resources Groundwater Information Center Interactive Map Application (A: ESJ Boundary; B:
Change Spring 2004 – 2014; C: Change Fall 2006 – 2016; D: Change Spring 2008 – 2018)4 Draft ESJ GSP Figure 3-34 shows ten groundwater wells spread evenly through the basin.
Overall most of the Subbasin shows a long-term decline in groundwater elevations, with an average decline of -0.5 ft/year during the period 1996-2015. Groundwater elevation maps from First Quarter and Fourth Quarter 2017 show a large cone of depression in the center of the basin, with a groundwater elevation deeper than 50 feet below mean sea level (Figures 3-37 and 3-38).
The draft ESJ GSP unduly minimizes Subbasin challenges related to groundwater storage and overdraft. Three examples are provided below.
4 Dark red represents 40 feet of decline, orange represents 20 feet of decline, light green represents 10 feet of increase.
A B: Spring 2004-2014
C: Fall 2006-2016 D: Spring 2008-2018
6 Section 3.4.2 states:
Figure 3-50 shows annual total storage for the combined ESJWRM fresh groundwater layers (not including the deep saline layer). Figure 3-51 shows the cumulative change in storage against annual storage change and water year type. In 2015, the total fresh groundwater storage was estimated as 53.0 MAF and the cumulative change in storage over 1995-2015 was estimated as -0.91 MAF (-0.09%), or -0.05 MAF/year.
Section 4.2.2.1.1 states the following:
Undesirable results related to groundwater storage in the Subbasin have not occurred historically, are not currently occurring, and are not likely to occur in the future. As discussed in the current and historical groundwater conditions section of this GSP (Section 3.4.2), there is a large volume (approximately 53 million acre-feet [MAF]) of freshwater in storage. Previous analysis of groundwater storage using the ESJWRM showed a range of fluctuation from 1996 to 2015 of approximately 0.001 percent per year.
Section 4.2.2.1.3 states:
Although the Subbasin has enough fresh groundwater in storage to sustain groundwater pumping in conditions of overdraft for centuries, dramatic increases in reliance on groundwater, severe drought, or other major changes in groundwater management over time could cause the volume of freshwater in groundwater storage to decline to a significant and unreasonable level.
Thus, while DWR has listed the ESJ Subbasin as critically overdrafted, the ESJ GSP appears to claim that the Subbasin has a nearly balanced water budget and there are minimal problems with groundwater overdraft.
The ESJ Draft GSP also quotes a series of different groundwater overdraft values, leading to unnecessary confusion regarding conditions in the Subbasin. The Annual Water Budget in Table 2-15 is averaged over the entire basin, with a change in groundwater storage of 41,000 AF/year (1996-2015), 48,000 AF/year (past 50 years) and 34,000 AF/year (future 50 years). However, under DWR’s intermediate climate change scenario, the annual groundwater overdraft will increase to 57,000 AF/year, from the previous estimate of 34,000 AF/year. Without climate change, the GSP Executive Summary states that, to reach sustainability, the basin must offset and/or recharge approximately 78,000 AF/year:
This number is larger than the estimated annual overdraft of the projected conditions scenario due to the integrated nature of the groundwater subbasin. As efforts are made to reach sustainability in the Subbasin, flows to and from neighboring basins and flows to and from streams may be impacted, creating the need for additional recharge or pumping reduction greater than the overdrafted amount.
The ESJ Draft GSP should acknowledge the reality of climate change scenarios prescribed by DWR, and highlight the fact that the estimated groundwater pumping offsets and/or recharge of 78,000 AF/year is a conservative estimate that may in reality be closer to 101,000 AF/year (calculated by increasing the change in groundwater storage from 34,000 AF/year (projected conditions for 50-year period) to 57,000 AF/year (climate change scenario).
As explained below, projects that make additional surface water supplies available within the Subbasin would help address these overdraft conditions. 7 Topic 3. Local Groundwater Recharge Opportunities Should be Expanded For groundwater recharge, additional surface water supplies can and should be used to offset groundwater pumping or should be directly discharged into the aquifer through groundwater banking. Water districts within the ESJ Subbasin, including the Oakdale Irrigation District (OID) and the South San Joaquin Irrigation District (SSJID) sell and/or transfer surplus surface water to water users outside the Subbasin. Since 2007, for instance, OID has reported that it sold surplus water and raised $58 million ($5.8 million per year) in revenue over the last ten years. 5 SSJID has also transferred/sold a significant amount of water.
Selling surface water to water users within the Subbasin (rather than selling and transferring water out of the Subbasin) would reduce reliance on groundwater sources and encourage groundwater recharge and sustainability. Stanislaus County has conducted groundwater model scenarios investigating the impact of additional surface water deliveries on groundwater elevations. The Stanislaus County Hydrologic Model released a scenario where the Cities of Ceres and Turlock decreased groundwater pumping due to increased surface water delivery of 5,700 and 11,100 AFY, respectively. The scenario also assumes increased agricultural pumping.
Figure 2 compares two released scenarios: Scenario 2 – Reasonable Upper Bound Potential Demand Increase and Scenario 5 – Additional Surface Water Delivery.6 By replacing groundwater pumping with surface water delivery, the model found moderate groundwater recharge (shown by warm colors).
5 Evaluation of San Joaquin River Flow and Southern Delta Water Quality Objectives and Implementation – Comment Letter 1000-1031. Comment #62. July 2018.
6 Stanislaus County. 2017. Stanislaus County Hydrologic Model: Development and Forecast Modeling. Prepared by Mike Tietze. December 20, 2017. Available at: http://www.stancounty.com/er/pdf/groundwater/draft-tech-memoschm.pdf 8 Chapter 6 of the ESJ Draft GSP lists 23 potential projects to offset the 78,000 AF/year groundwater overdraft, which include direct and in-lieu recharge, intra-basin water transfers, demand conservation, water recycling, and stormwater reuse. Project 8 proposes in-lieu recharge through long-term water transfers to the Stockton East Water District (SEWD) and Central San Joaquin Water Conservation District (CSJWCD) from OID and SSJID. SEWD and CSJWCD have historical groundwater overdraft conditions and water transfers from OID and SSJID could encourage groundwater recharge (GSP, pp. 6-15 to 6-17). Project 8 is projected to offset 45,000 AF/year in groundwater pumping, with a projected annual cost of $9 million at $200 per acrefoot. Due to historical water transfers from OID and SSJID to entities within the ESJ basin, existing infrastructure is adequate for Project 8 to move forward, as stated on pp. 6-16 of the Draft GSP:
Expected project time-table is 2019-2021. A new long-term transfer could begin immediately upon agreement among the parties. Transfers from OID/SSJID to SEWD/CSJWCD have historically been agreed to, with historical transfer amounts varying from 0 to 40,000 AF/year.
According to the 2015 OID Agricultural Water Management Plan (2015 AWMP), transfers from OID to areas outside the Subbasin totaled 325,294 acre-feet between 2005 and 2014 (2015 AWMP Table 5-9.).
7 OID also reported that its surplus water sales since 2007 raised $58 million 7 Available at: https://www.oakdaleirrigation.com/2015-ag-water-management-plan Figure 2. Head Change from the Stanislaus County Hydrologic Model - Scenario 2 (Increased Groundwater Pumping) (left) and Scenario 5 (Replace Groundwater with Surface Water) (right) 9 ($5.8 million per year) in revenue in the succeeding ten years8. These figures (which relate to only one water district) indicate that there is a greater potential for surface water transfers to recharge the overdrafted ESJ Subbasin than acknowledged in the draft GSP.
The ESJ GSP should expand Project 8 to include additional water transfers within the Subbasin for recharge. In addition, Project 8 should not be limited to transfers solely from OID and SSJID to the SEWD and CSJWCD service areas. Instead, all lands subject to declining groundwater levels (GSP Figures 3-37 and 3-38) and with at least Moderately Good recharge potential (GSP, Figure 2-14) should be included. For instance, lands within the Eastside GSA (a cooperative GSA formed by the Calaveras County Water District, Stanislaus County, Calaveras County, and Rock Creek Water District) also have some existing infrastructure to receive transferred water and, according to the draft GSP, these areas also include potential recharge areas (See GSP, Figure 2-14). In addition, if the rate for purchase of surface water was lower, additional purchases may occur voluntarily, potentially increasing recharge. With the expansion of Project 8, overdrafted conditions in the Subbasin would be more readily addressed. To the extent new infrastructure would be needed for an expansion of Project 8, additional Potential Project could be included in GSP section 6.2.5, and could include any necessary improvements to water distribution systems.
The GSP should also promote smaller recharge projects whereby water users may divert surplus surface water supplies for recharge on their own lands. This could be accomplished, for instance, by the creation of a program within the GSP that landowners could join if specified criteria are met. Creation of such a program would assist smaller recharge projects with completion of complex permitting and review requirements.
The efficacy of these projects in their potential to recharge the aquifer should be analyzed using a model scenario with the GSP Eastern San Joaquin Water Resources Model (ESJWRM).
3. CONCLUSION
We hope these comments are helpful in completing a draft GSP that effectively meets the requirements of SGMA. Please contact us if you have any questions. 8 Evaluation of San Joaquin River Flow and Southern Delta Water Quality Objectives and Implementation – Comment Letter 1000-1031. Comment #62. July 2018.
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Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 David Simpson NSJWCD NA NA NA Woodbridge ID and recharge projects within the District need to be included in the Final GSP.
2 David Simpson NSJWCD NA NA NA The GSP should contain a statement of concern relating to SWRCB plans to reduce flows available for use by 40‐60%. The GSP references climatechange yet a far greater threat to sustainability in the basin is thereallocation of surface water flows currently being undertaken by theSWRCB. The Draft GSP assumes constant or increased availabilityof surface water yet the SWRCB has threatened to take 40‐60% of thecurrently available flow in several key rivers. With reduced availability ofsurface water for existing uses and groundwater recharge, there is little to ... no hope of achieving groundwater sustainability without massive new infrastructure, draconian pumping restriction and increased regulation. 3 David Simpson NSJWCD ES‐10, others? Potential Projects NSJWCD and Manaserro Lasko should be spelled Lakso Manaserro should be spelled Manassero
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September 4, 2019
Eastern San Joaquin Groundwater Authority
1810 E. Hazelton Avenue
PO Box 1810
Stockton, CA 95201
[email protected]
Re: Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan To Whom It May Concern:
Restore the Delta works in the areas of public education and outreach so that all Californians recognize the Sacramento-San Joaquin Bay Delta as part of California’s natural heritage, deserving of restoration.
We fight for a Delta with waters that are fishable, swimmable, drinkable, and farmable, able to support the health of the estuary, San Francisco Bay, and the ocean beyond. A coalition of California residents, business leaders, civic organizations, community groups, faith-based communities, union locals, farmers, fishermen, and environmentalists, Restore the Delta envisions the Sacramento-San Joaquin Delta as a place where a vibrant local economy, tourism, recreation, farming, wildlife, and fisheries thrive as a result of resident efforts to protect our waterway commons.
To that end, we are writing to offer comments regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan. We acknowledge that we missed the comment deadline. This happened in part because we were busy completing a climate change analysis of the San Francisco Bay-Delta Estuary, which needed to be completed in order for us to offer thoughtful comments on the relationship between climate change impacts on the Delta and the Eastern San Joaquin Groundwater Basin. If our late comments cannot be accepted, can you please let us know how and where we can engage with the process again to share our findings? We believe you will find our findings worth of consideration and inclusion.
Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan 2 Climate Change Analysis
Restore the Delta observes in Table 2-17 (p. 2-133) of the Draft GSP Chapter 2 finds that in wet years groundwater storage is projected to increase by an annual average of 52 TAF; 23 TAF in above normal years; and decrease by 7 TAF in below normal years, 44 TAF in dry years, and 39 TAF in critically dry years. Overall, over the 50-year planning horizon of the Draft GSP, groundwater storage in the Subbasin is projected to decrease an average of 34 TAF. Over 50 years, this is a cumulative loss of stored freshwater of about 1.7 MAF. This is a much smaller amount than other groundwater sustainability agencies are contemplating elsewhere in California, but it still represents a cumulative loss to storage in our Subbasin. This is about 3.2 percent of the total subsurface freshwater storage of 53 MAF cited elsewhere in the Draft GSP.
Elsewhere, the Draft GSP states that “to achieve a net-zero change in groundwater storage over a 50-year planning period, approximately 78,000 AF/year of direct or in lieu groundwater recharge and/or reduction in agricultural and urban groundwater pumping would need to be implemented the Eastern San Joaquin Subbasin. This number is larger than the estimated annual overdraft of the projected conditions scenario due to the integrated nature of the groundwater sub basin.” (p. 2-134) If neighboring subbasins do less to recharge their underground supplies hypothetically it would mean that the GWA would have to do more, and vice-versa, to avoid undesirable results.
Restore the Delta urges the GWA to recognize this interrelationship more explicitly and to adopt a policy of encouraging neighbors to do their fair share of net recharge (combining “additional recharge or pumping reduction”) activities as they implement their GSPs. We recommend also that the Final GSP incorporate reviews of what neighboring GSAs and their GSPs are contemplating in this regard so that readers of the GWA’s GSP understand what this “neighborhood baseline” consists of when it comes to assessing undesirable results indicators and evaluating the success or failure of neighbors’ implementation projects.
Restore the Delta is by and large disappointed with the Draft GSP’s climate change analysis. The Draft GSP provides no broad overview of what effects climate change is likely to have on Subbasin groundwater resources. There is not even a summary of the California Fourth Climate Change Assessment commentary on what effects are expected in California as we step-by-step enter that climate future. Instead, the Draft GSP presents only a turgid, technical description of its use of DWR climate-change models and the results of those models. This should have been limited to an appendix, and the results simply summarized in the Draft GSP. Instead, the modeling results are presented with little context. The state has presented a comprehensive, region-by-region analysis of climate change effects, and the Draft GSP needs to apply it—both to educate the Subbasin publics (including disadvantaged communities) and to place DWR-based climate change analytic results in context. As drafted, the climate change analysis has been done; GSA staff can check the box for providing a minimally adequate GSP to the state. The water users of the Subbasin deserve more, however. They deserve a Final GSP that tells them what the Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan 3 analysis means for the future of Subbasin groundwater resources and communities, and how it plays out relative to each of the sustainability indicators the Draft GSP puts forward.
Draft GSP Sustainable Indicators/Policies
SGMA’s “undesirable results” include:
• 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;
• significant and unreasonable 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 surface water.
In our testimony to the State Water Board on California WaterFix in 2016, we noted there was a cone of depression in the central part of the Eastern San Joaquin groundwater basin and that salt water intrusion was a risk, especially if freshwater was withdrawn via diversions at the WaterFix north Delta intakes. This condition persists, according to the Draft GSP. We note from Figures 2- 37 and 2-38 (pp. 2-65 and 2-66 of the Draft GSP) that as of 2017 the cone of depression is still very much present. This existing condition has undesirable results now. There are extensive losing stream reaches in the Eastern San Joaquin groundwater basin: Dry Creek along the north boundary, the Mokelumne River below Camanche Reservoir, and Calaveras River and Mormon Slough for nearly their full lengths across the basin. When compared with the groundwater elevation maps that show the cones of depression (Figures 2-37 and 2-38), it is evident that the cones of depression are located directly beneath the Calaveras River and Mormon Slough, which are losing streams—their flows are now disconnected from the groundwater system, as shown in Figure 2-66 (p. 2-99). There also appears to be a portion of a cone of depression beneath Dry Creek near to the Mokelumne River as well, though this is not labeled with the same color as the cone of depression in the Eastern San Joaquin basin. This means that there is great potential for saltwater intrusion, which the draft GSP gently acknowledges. Net subsurface flow is from the west to the east. But the draft GSP is silent about the ecological consequences of having losing streams spanning the groundwater basin. It means that to the extent these streams have riparian vegetation corridors along them, the trees and shrubs that comprise them are stressed, and to the extent stream reaches are devoid of riparian vegetation, river biota are starved of nutrients and shade.
Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan 4 Restore the Delta considers such conditions to be undesirable results of existing conditions along the basin’s most significant losing streams and should be an object of policy for restoration and recovery.
Disadvantaged communities (also known as “environmental justice communities” and “climate justice communities”) are located along the western edge of the Eastern San Joaquin groundwater basin—portions off the central and eastern Delta in the northeastern portion of the basin, the Stockton area, parts of Lodi and eastern Lodi, as well as the central basin (Figure 1-8, p. 1-15). This latter central basin DAC area directly coincides with the location of the losing stream reaches of Calaveras River and Mormon Slough, both of which overlie the cone of depression, which is caused by over-drafting of local aquifers largely by agricultural pumping activities. Disadvantaged communities are forced to live with existing disadvantaged streams— losing streams. The Draft GSP appears to do little to rectify these existing undesirable conditions—undesirable at least from the standpoint of the disadvantaged communities forced to live without healthy riverine ecosystems and recreational and angling beneficial uses of them in their midst.
The Draft GSP tracks the SGMA-defined “undesirable results” in its Sustainability Indicators (Section 3.2).
It defines an undesirable result of “chronic lowering of groundwater levels” as “experienced if sustained groundwater levels are too low to satisfy beneficial uses within the Subbasin over the planning and implementation horizon of this GSP.” Indicators of this undesirable result include number of wells “going dry,” reduction of pumping capacity of existing wells, increased pumping costs due to greater lift, and need for deeper well installations or lowering of pumps.
The Draft GSP sets a threshold of 25 percent of representative monitoring wells (5 of 20 such wells in the Subbasin) have their elevations fall below their minimum level thresholds for two consecutive years that are non-dry (that is, below-normal, above-normal, or wet years). In other words, a SGMA-undesirable result would occur when groundwater levels fall for two consecutive years when there should be instead a net recharging of Subbasin aquifers during non-dry years.
This particular indicator lacks any recognition of the differential impact of falling groundwater elevations on disadvantaged communities relative to other groundwater pumpers like cities and agricultural enterprises. While the plan identifies disadvantaged communities (which we note above), it does not correlate explicitly the degree to which disadvantaged communities in the Subbasin are predominantly reliant on municipal/public or private water systems, or whether they are predominantly reliant on private wells. The Draft GSP provides no policies or program recommendations and needs that would address the question: if these conditions develop where disadvantaged residents lose their pumped groundwater supplies, what steps will the GWA take Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan 5 to mitigate such events and recover the utility of their public/private systems or wells? The Draft GSP would, it appears, wait until impacts on disadvantaged and other communities occur before any actions to prevent such occurrences would be taken. For example, if one year of non-dry groundwater elevation decline results in 5 of the 20 monitoring wells happens, the Draft GSP would appear to require that the GWA wait a full year before any kind of action might be taken.
Moreover, what actions should be taken if such dramatic events occur are not specified (pumping restrictions/moratoria? pump taxes to discourage excessive pumping? revolving loan funds for drilling deeper wells?).
The cost indicator is indeed relevant here. The Draft GSP recognizes just “increase in pumping costs due to greater lift” as an undesirable result relating to lowered groundwater elevations. The Draft GSP fails to provide any cost threshold beyond which point the GWA would presumably act on this triggered indicator. What level of cost increase is reasonable due to greater lift needs? Do public and private well systems need to be treated differently from a cost standpoint than single private wells? Will increased costs for wells operated by members of disadvantaged communities be treated the same or differently than other systems? Restore the Delta recommends that they should be treated differently so that ability to pay is taken into account.
Just as important, what remedial action does the GWA commit to in order to stem impacts to disadvantaged community groundwater users when pumping costs rise? In short, whose groundwater pumping costs are going to be the GWA’s yardstick for determining undesirable results, and what actions will the GWA commit to in redressing undesirable results? For the lowering of groundwater elevation and reduction in groundwater storage indicators, the definitions in the Draft GSP are too vague about which beneficial uses have to be affected by the undesirable result. There needs to be more clear specification of undesirable results in relation to specific beneficial uses. If the GWA means “all beneficial uses” for these indicators, then state “all beneficial uses.” As worded, these indicators give the GWA license to pick favored beneficial uses over others. The cost issue just discussed is an example of this.
The matter of groundwater storage reduction presents different problems. The Draft GSP confidently states that “there is a large volume (approximately 53 million acre-feet [MAF] of freshwater in storage” in the Subbasin, and there appears to be very little fluctuation historically in this volume on a percentage basis. The Draft GSP states that “it is roughly estimated that groundwater demand for beneficial use occurs within the top 23 MAF of the Subbasin.” (p. 3-10) No geographic description of where this 23 MAF occurs is provided. The “threshold” for undesirable result in the Draft GSP on the storage indicator then becomes “when storage is insufficient to satisfy beneficial uses within the Subbasin. Therefore, undesirable results would occur if groundwater storage were reduced to less than 30 MAF.” (Ibid.) Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan 6 Here the Draft GSP fails to connect the already existing undesirable results noted above with this level of groundwater storage in the Subbasin (that is, the cone of depression with the presence of losing streams immediately overlying them, for example, and their occurrence immediately beneath and down-gradient of disadvantaged communities in the Subbasin). The Draft GSP takes current groundwater storage at 53 MAF as an acceptable baseline when it actually represents a storage level that is undesirable given existing surface and subsurface conditions. Restore the Delta urges the GWA to rethink, redefine, and redraft this particular indicator discussion so that existing undesirable conditions can experience recovery and restoration to sustainable conditions as the GSP planning and implementation horizon plays out.
We appreciate that the Draft GSP specifies beneficial uses to be addressed in its “degraded water quality” discussion (beginning p. 3-11). We recommend, however, that this indicator go beyond salinity to factor in any and all surface impaired water ways identified by the Central Valley Regional Water Quality Control Board and the State Water Resources Control Board, connected or disconnected from groundwater systems. This will ensure that no water quality or toxic constituent “falls through the cracks” between SGMA implementation and Clean Water Act enforcement. This will help GWA staff stay abreast of 303d affairs carried out by the water regulators, especially where losing streams or percolation and recharge areas may become contaminated.
The Draft GSP sets a threshold of 3 of 10 water quality monitoring well sites exceeding minimum thresholds for two consecutive years and where these concentrations are the result of groundwater management activities. We ask a similar question as above of the GWA: if a toxic plume suddenly spikes at three or more of the ten water quality monitoring wells, is the Draft GSP to be interpreted as meaning that the GWA would wait up to two years before taking any kind of action to protect public health and safety and address the contamination? Why does this indicator even have a time/duration threshold before enabling the GWA to identify, prevent, or mitigate an undesirable result? As with the cost discussion, what actions does the GWA commit to in order to stem the breaching of the minimum water quality thresholds it has put forward? Would it really allow saltwater intrusion, for example, to proceed for two years before acting to push back the isohaline toward the Delta? That would cost a lot more in water injections and scarce dollars, for example, than if authority for action contained in the Draft GSP allowed more prompt assessment and prevention of saltwater intrusion.
The remaining three indicators in the Draft GSP address sea water intrusion, land subsidence, and depletion of interconnected surface water. Restore the Delta feels that these three indicators in the Draft GSP would all benefit from similar critical review and treatment (including redefinition to include existing undesirable baseline conditions) that we have outlined above for the first three indicators; indeed, our specific comments on reconnecting losing streams to groundwater systems apply to Section 3.2.6 on depletion of interconnected surface water, Comments Regarding the Eastern San Joaquin Draft Groundwater Sustainability Plan 7 including our comments about the relationships of disadvantaged communities to these natural hydrologic systems.
In closing, California Water and the City of Stockton Municipal Utility District depend, in part, on groundwater wells to provide safe and affordable drinking water supplies to residents of environmental justice communities within the City of Stockton. Residents from our environmental justice communities, made it clear during the recent California EPA Environmental Justice Initiative for Stockton, that they do not have confidence in our local drinking water supply due to issues of taste and discoloration. Furthermore, small urban businesses and farms which provide affordable local produce to residents living within Stockton’s food deserts are also dependent on the health of our region’s groundwater system and deserve to be protected from future impacts of saltwater intrusion and pollution plumes. We believe, consequently, that the GWA has a responsibility toward helping ensure that water quality and quantity is protected, and even improved, for the Subbasin, requiring further analysis of climate change impacts as described above.
Thank you for the opportunity to comment.
Sincerely yours,
Barbara Barrigan-Parrilla Tim Stroshane
Executive Director Policy Analyst
Cc: Mayor Michael Tubbs, City of Stockton
Mel Lytle, City of Stockton
Gordon MacKay, City of Stockton
Supervisor Kathy Miller, San Joaquin County
Supervisor Chuck Winn, San Joaquin County
Supervisor Tom Patti, San Joaquin County
Supervisor Bob Elliott, San Joaquin County
Supervisor Miguel Villapudua, San Joaquin County
Fritz Buchman, San Joaquin County
Kris Bilaji, San Joaquin County
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Delta-Sierra Group Mother Lode Chapter
P.O. Box 9258
Stockton CA 95208
Eastern San Joaquin Groundwater Authority 25 August 2019 P. O. Box 1810, Stockton CA 95205
Via email: [email protected] and [email protected] Re: Eastern Joaquin Groundwater Sustainability Plan – Public Draft July 2019 The Sierra Club has adopted a water policy to promote proper management for a healthful and aesthetically pleasing natural environment. The policy calls for thorough water inventories including historic water yields and uses, with priority where substantial demands are anticipated. The Eastern San Joaquin (ESJ) Subbasin is a high priority basin which is critically overdrafted requiring that managers of the resource comprised of 15 Groundwater Sustainability Agencies (GSAs) develop a groundwater sustainability plan (GSP) by January 2020.
The Draft GSP was released in July 2019 and the Delta-Sierra Group has prepared generalized comments regarding the following topics:
1. Initial Notification of GSP Preparation
2. GSP Funding
3. Beneficial Users Outreach
4. Wells
5. Recharge Areas
6. Interconnected surface waters
7. Groundwater dependent Ecosystems
8. Water Quality
9. Data Management System
10. Monitoring
11. Modeling
12. Notice of Intent to Adopt GSP
Initial Notification of GSP Preparation
The 15 GSAs along with 2 now former Eastern San Joaquin GSAs agreed to develop one GSP for the Eastern San Joaquin Groundwater Subbasin. The basis for this cooperation is outlined in the Joint Powers Agreement1
which established the Eastern San Joaquin Groundwater Authority (GWA) to oversee the GSP development. According to the Notice of GSP Plan Development submitted to DWR: “The agreement specifies that the 17 GSAs will coordinate via the GWA to develop and implement a single GSP.”2
The GSP must contain four main components:
1. A description of the plan area and groundwater basin setting (including an assessment of current and future groundwater conditions) and a water budget.
2. Sustainability goals which must avoid all six undesirable results
3. Projects and management actions that will achieve the community’s sustainability goal, and
4. A monitoring plan that will measure progress over time.
The Eastern San Joaquin groundwater basin is characterized as an alluvial basin because most all the underlying sediments were deposited by flowing water and that have been allowed to accumulate over a million years or more3
. The area overlying the basin is located in three counties: San Joaquin, Calaveras, and Stanislaus. Most of the basin lies within San Joaquin County. 1 https://www.sierraclub.org/sites/www.sierraclub.org/files/sceauthors/u14441/Fully%20Executed%20Eastern%20San%20Joaquin%20Groundwater%20Authority%20JPA_02082017.pd f. Fully authorized by signatories October 2017.
2 https://sgma.water.ca.gov/portal/gsp/init/preview/82 Accessed 8.24.19. 3 PAGE R.W., Geology of the Fresh Ground-Water Basin of the Central Valley, California, with Texture Maps and Sections REGIONAL AQUIFER-SYSTEM ANALYSIS; U.S. GEOLOGICAL SURVEY PROFESSIONAL PAPER 1401-C; 1986.
DSG Comments 2
GSP Funding
To develop the GSP a contract was signed with Woodard & Curran for $2,176,420 that is in effect through the submittal of final GSP to DWR in January 2020. To fund the contractual obligation there was a uniform distribution of the local share costs between the then 17 GSAs. The Disadvantaged Community Grant, supported by Sierra Club, reduced the local cost share associated with the $1,500,000 Proposition 1 grant that was awarded to the GWA. Additionally, San Joaquin County Zone 2 Groundwater Investigation Assessment funds were distributed to 16 of the GSAs to further lower local cost shares to approximately $28,000/GSA within San Joaquin County. There was a much more robust discussion about funding the development of the GSP than for implementing the GSP. Table 1 below provides a summary of the GSA’s areas and composition, both factors with groundwater extraction volumes should be considered when determining GSP implementation contributions.
Table 1. GSA’s Area and Primary Land Use
Groundwater Sustainability Agency Area (Acres) Primary Land Use Central Delta Water Agency GSA 52,000 Agricultural
Central San Joaquin Water
Conservation District GSA
73,000 Agricultural
City of Lodi GSA 8,7104 Urban 4,565 population density/mile4 City of Manteca GSA 13,000 Urban 3,784 population density/mile4 City of Stockton 39,000 Urban 4,730 population density/mile4 Eastside San Joaquin GSA 126,000 Agricultural: Calaveras County Water District, Stanislaus County, and Rock Creek Water District (1,800 acres).
Linden County Water District 3,000 Urban 1,800 residents Lockeford Community Services
District
800 Urban 3,200 residents
North San Joaquin Water
Conservation District GSA
149,000 Agricultural: Approximately 50% is irrigated land Oakdale Irrigation District 31,000 Agricultural – supplier of surface water to Urban and Agricultural
County of San Joaquin GSA - Eastern
San Joaquin 1
51,000 Agricultural with unincorporated community service districts
County of San Joaquin GSA - Eastern
San Joaquin 2- Calwater
7,000 Urban – 42,000 connections – County MOA5 with
California Water Service, an investor owned utility
South Delta Water Agency GSA 18,000 Agricultural surface water users, groundwater unusable due to high salinity
South San Joaquin GSA 64,000 Agricultural and Urban: South San Joaquin Irrigation District distributes water for agricultural and urban users; City of Ripon 14,700 residents, and City of Escalon 7,400 residents.
Stockton East Water District GSA 101,000 Agricultural
In June 2019, an Ad Hoc Committee was established by the GWA to evaluate the role of the GWA going forward because many members believed that the JPA was only a coordinating agreement so that a 4 https://www.census.gov/quickfacts/fact/table/mantecacitycalifornia,stocktoncitycalifornia,lodicitycalifornia/LND110210 data not included in the draft GSP. 5 https://www.sierraclub.org/sites/www.sierraclub.org/files/sce-authors/u14441/Cal%20Water%20MOA_A-17- 146_06052017_0.pdf.
DSG Comments 3
single plan could be prepared covering the entire Eastern San Joaquin Groundwater Subbasin rather individual GSAs preparing their own plans.
The uncertainty related to ongoing governance exists in part because the Ad Hoc Committee was created especially so that Brown Act notifications to the public were not required. Whether or not coordination between the 15 GSAs continues during implementation will be in large part determined by what this Ad Hoc Committee reports to the GWA for their consideration. It is expected that this report will be made available either in September 2019 GWA agenda materials or at the September 2019 GWA meeting. In either case long after comments on the draft GSP are due in August 2019. The postponing of these important governance and funding discussions creates a situation of urgency which will likely preclude widespread public outreach and consideration of beneficial users’ comments. The deficiencies related to individual GSA water budgets casts serious doubts about how funding allocations will be made so that basin-wide monitoring and implementation activities are accomplished. A frequent comment has been, why should we fund someone else’s misuse and lack of planning when we have been funding efficiency improvements all along.
Beneficial Users Outreach
To satisfy the requirement to consider all beneficial users when developing the GSP, the Stakeholder Workgroup was formed in June 2018 to convey to the Groundwater Authority the perspectives of beneficial users in the basin. The approach to create a stakeholder committee for outreach to all beneficial user types was presented at the March 2018 GWA meeting. The presentation included the role of the Stakeholder Committee and the flow of information: staff Advisory Committee to Groundwater Authority Board then to Stakeholder Committee, and after the Groundwater Authority Board is “comfortable with everything, the topics will be ready for public presentations”.
The goals of the Stakeholder Workgroup are outlined in the June 2018 Draft Eastern San Joaquin Groundwater Authority Groundwater Sustainability Plan and Sustainable Groundwater Management Program Stakeholder Engagement and Public Outreach Plan. The Workgroup may provide to the consulting team developing the GSP, input regarding the following groundwater-related issues:
• Annual work plans and reports (including mandatory 5-year milestone reports) • Community outreach
• Development, adoption or amendment of the Groundwater Sustainability Plan • Fee proposals
• General advisory
• Inter-basin coordination activities
• Local regulations to implement Sustainable Groundwater Management Act (“SGMA”) • Modeling scenarios
• Monitoring programs
• Projects and management actions to achieve sustainability • Sustainability goals and objectives
• Confirmation of community values
Early on Stakeholder Workgroup members expressed frustration that specific technical information was not available for review in advance of meetings; that during meetings new information was made available on PowerPoint slides only; that meetings were rushed because there was an emphasis on presenting information rather than engaging in meaningful dialogue that could be communicated to the GWA. These issues and others are included in the results of the DWR Facilitation Grant situational assessment completed in December 2018. The Eastern San Joaquin Groundwater Sustainability Work DSG Comments 4
Group Stakeholder Assessment Highlights Report and Highlights presentation6 were available in December 2018 and satisfied the requirements of the Department of Water Resources (DWR) Public Outreach Facilitation Agreement signed in September 2017. Since the GWA did not meet in December 2018 or January 2019 a video7
was prepared for GWA review.
Frequently, information was requested by Workgroup Members so that meaningful comments could be prepared. These requests were:
• For more complete descriptions of management projects before final selection included in the GSP.
• For how responsibilities for funding the implementation of the GSP were to be allocated between the GSAs.
While Stakeholder Workgroup members were apprised of these two major aspects of the GSP, the members had too little detailed information to develop comments to convey their ideas to the GWA.
Because information flow was limited, it is questionable about how robust engagement was during the GSP development.
Members expressed frustration that there were no demand management options to curtail continued development of the groundwater resource in areas were overdraft have been identified. Wells of any size can be drilled in San Joaquin County and Calaveras County with no requirement for metering to verify that permit application estimates of groundwater demand are valid. Stanislaus County, on the other hand has taken a discretionary approach so that new wells installed do not further impact aquifer overdrafted conditions. This discretionary approach as well as the ministerial approach to groundwater well permitting are currently under consideration by the California State Supreme Court Case No. S251709.
Many of the problems related to outreach that were discussed in 2018 continued and are in part summarized in a July 2019 letter submitted by multiple organizations including the League of Women Voters – San Joaquin County, the Delta-Sierra Group of the Sierra Club, Restore the Delta, Environmental Justice Coalition for Water, and Puentes8 .
On August 12, 2019 the members of the Stakeholder Workgroup were notified that scheduling for the final 1.5-hour meeting was underway and would be held in September 2019 to discuss responses to comments received on the Draft GSP, and “conclude with a small thank you ceremony.” Likely, rather than a discussion, this meeting will include a presentation of a few comments or the GSP adoption process. This statement is based on the fact that the Stakeholder Workgroup was informed at the May 2019 that the June 2019 meeting was to include a discussion of Bundle 1 draft GSP comments and only a brief comment was made regarding one stakeholder group’s comments – the Nature Conservancy regarding groundwater dependent ecosystem identification. Instead of a discussion of comments there was an overview presentation of draft GSP Bundles 2 and 3.
Wells, Recharge Areas, Interconnected Surface Waters, and Groundwater Dependent Ecosystems Wells
The GSP Wellhead protection areas and recharge areas Section 1.2.3.4, addresses wellhead protection programs in San Joaquin County, Calaveras County, and Stanislaus County. The discussion regarding wellhead protection areas seemed to be restricted to annular seals on wells which do prevent surficial contamination from entering the aquifer. No analysis was offered as to the variation of well construction 6 https://www.sierraclub.org/sites/www.sierraclub.org/files/sceauthors/u14441/Eastern%20San%20Joaquin%20%20Groundwater%20Sustainability%20Work%20Group%20Stakeholde r%20Assessment%20Highlights%20Report.pdf and https://www.sierraclub.org/sites/www.sierraclub.org/files/sceauthors/u14441/ESJ-Assessment-DRAFT.pdf 7 https://www.youtube.com/watch?v=JKIHfbvTmPs&t=178s not distributed to GWA based on available public records. 8 https://www.sierraclub.org/sites/www.sierraclub.org/files/sceauthors/u14441/Collective%20Comments%20on%20GSA%20outreach%20activities%20%20071719%20final.pdf DSG Comments 5
standards and location requirements that might relate to wellhead protection areas. A brief summary of well construction standards and location requirements for the three counties is included in Table 2. With the exception of Stanislaus County, there are no restrictions on pumping or new well installations, of any size and depth due to the ministerial approach adopted by San Joaquin and Calaveras Counties. Continued issuance of well permits of any size occurs including in areas where cones of depression have been identified due to historic groundwater extraction exceeding groundwater recharge.
Despite the fact that GSAs are able require water management devices on non-de minimis water wells no metering of wells of any size was proposed in the draft GSP. De minimis wells produce less than two acre-feet per year for domestic purposes. Reporting of extraction volumes and meters on all wells not de minimis is required should the State Water Resource Control Board have to regulate a basin. There are several thousand or more wells that are not de minimis that extract groundwater within the Eastern San Joaquin Groundwater Subbasin. The Delta-Sierra Group recommends that the largest non-de minimis extraction wells be metered with an annual reporting requirement. Requiring the metering of the largest extraction wells is a good step towards validating the results of modeling based on acreage and crop types.
Table 2. County Regulation for Well Installation
San Joaquin County9 Stanislaus County10 Calaveras County San Joaquin County
Environmental Health Department
oversees a well permitting program
Stanislaus County Department of
Environmental Resources oversees a well
permitting program
Calaveras County Environmental
Health Department oversees a well
permitting program
Setbacks for Public Water System
Wells (Lots recorded after 1972):
Property Line 25 ft (10 ft)
Septic Tank 100 ft (50 ft)
disposal 100 ft (100 ft)
Sewer Line 50 ft (50 ft)
Stream, Creek, 50 ft (50 ft)
River, Canal
In 2014, the DER adopted a Groundwater
Ordinance to prohibit unsustainable extraction
of groundwater in unincorporated areas of the
County. The DER reviews each Well Permit
Application and determines whether the well
is subject to, or exempt from, the prohibitions
in the Groundwater Ordinance. Permit
Applications for wells intended to extract 2
AF/year of groundwater or less are exempt
from the prohibitions in the Groundwater
Ordinance
Setbacks11
Property line <5 acres 10ft
Property line >5 acres 50 ft
Septic Tank 100ft
Disposal 100ft
Sewer Line 50 ft
Surface Water 25 ft
The minimum depth of the annular
seal for wells in San Joaquin
County:
Public Water Supplies 100 ft
Individual Domestic Well 100 ft
Industrial Wells 100 ft
Agricultural Wells 50 ft
All wells shall have an annual seal except for
Agricultural wells located 300 feet or more
from a domestic well12: Minimum seals as set
forth in Chapter II of the Department of Water
Resources Bulletin No. 74, “Water Well
Standards” (February 1968), or as
subsequently revised or supplemented, which
are incorporated in this chapter and made a
part of this chapter. (Prior code §3-313)13
Community water supply 50 ft
Industrial 50 ft
Individual domestic 20 ft
Agricultural well 20 ft
The minimum dept of the annular
seal for wells in Calaveras
County14:
Public drinking water well 50 ft
Commercial well 50 ft
Industrial well 50 ft
Individual domestic well 20 ft
Agricultural well 20 ft
Vertical geothermal exchange wells
20 ft
Wells within twenty-five (25) feet
of a water way 20 ft below the bed
of the water way.
9 https://www.sjgov.org/uploadedfiles/sjc/departments/ehd/forms/well%20standards.pdf 10 http://www.stancounty.com/er/pdf/application-packet.pdf 11 http://ema.calaverasgov.us/Portals/EMA/Documents/EH/Wells/Minimum_Well_Setbacks.pdf 12 https://qcode.us/codes/stanislauscounty/view.php?version=beta&view=mobile&topic=9-9_36-9_36_070 13 http://wdl.water.ca.gov/waterdatalibrary/docs/historic/Bulletins/Bulletin_74/Bulletin_74-90__1991.pdf 14 http://ema.calaverasgov.us/Portals/EMA/Documents/EH/Wells/Well_Ordinance.pdf DSG Comments 6
Recharge Areas
Groundwater recharge areas were not specifically addressed in GSP Section 1.2.3.4 but instead were discussed in 2.1.4.5.3: Description of Potential Recharge Areas. Modified SAGBI data was used to categorize 310,098 acres out of 610,890 acres (51 percent) of agricultural and grazing land within the Subbasin as moderately good, good, or excellent for groundwater recharge. The Modified SAGBI data show higher potential for recharge than unmodified SAGBI data because the modified data assume that the soils have been or will be ripped to a depth of 6 feet, which can break up fine grained materials at the surface to improve percolation. A generalized map was provided of potential recharge areas as shown below, but a map identifying existing recharge areas that substantially contribute to the replenishment of the groundwater basin was not found in the draft GSP.
SGMA requires that a map identifying existing and potential recharge, and specifically identifying the existing recharge areas that substantially contribute to the replenishment of the groundwater basin. This map shall be provided to the appropriate local planning agencies so that appropriate protection measures may be considered for adoption. In order to enhance recharge opportunities, land use planning that restrict paving and build over in an important mechanism. Good land use policies are necessary components to achieve the sustainability goals for the basin; so that existing recharge can continue and that development of additional regional recharge areas can become part of local water resource and community development plans.
Interconnected Surface Waters
Depletion of interconnected surface waters is an undesirable effect and the minimum threshold is the rate or volume of surface water depletions caused by groundwater use that has adverse impacts on beneficial uses of the surface water. Surface water supplies are available to many beneficial users including those with water rights granted by the State Water Resources Control Board directly or based on historical rights and environmental users including wildlife with and without narrow temperature ranges, and recreational users. When wells of any size are allowed to be drilled as near as 25 feet to 50 feet of a surface water source, it is likely that those wells are influenced to a large degree by surface water flows and contribute to surface water depletions in most circumstances.
DSG Comments 7
The GSP noted in section 3.2.6 Depletion of Interconnected Surface Water that “quantification of depletions is relatively challenging and requires significant data on both groundwater levels near streams and stage information supported by groundwater modeling.” Without restricting the installation of wells within areas of influence that intersect surface waterways, further depletion of interconnected surface waters will continue.
The draft GSP uses groundwater level minimum thresholds as a proxy for the depletion of interconnected surface water sustainability indicator. As such, the minimum thresholds for the interconnected surface water sustainability indicator are the same as the minimum thresholds for the chronic lowering of groundwater levels sustainability indicator. The use of the existing representative groundwater level monitoring wells is inadequate to assess whether or not surface waters are depleted by groundwater extraction wells near surface waterways. Figure 3-2 from the draft GSP shows the minimum threshold compliance well locations. Based on the scale of the legend the nearest well to a surface waterway is Bear Creek #3 which may be up to approximately 1 mile away from Bear Creek (0.5/2*3.75 miles) and operated by the Lockeford Community Services District which also operates wastewater infiltration ponds in the vicinity as shown in the snapshot from the 2007 Central Valley Regional Water Quality Control Board Waste Discharge Requirements15
The CVRWQCB permitted the Lockeford Community Services District in 2007, a monthly average land application flow rate not to exceed 300,000 gallons per day, and upon approval of the Recycled Water Expansion Report by the Executive Officer, the monthly average flow rate may be increased to a maximum of 400,000 gallons per day. The location of Bear Creek #3 is not specified on the CVRWCB map shown below.
15 https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/san_joaquin/r5-2007-0179.pdf accessed 8.25.19
DSG Comments 8
Snapshot from CVRWCD WDR for Lockeford Community Services District The draft GSP included Bear Creek #3 well construction details (780 feet total depth with screened intervals from ground surface to depth or 96 feet to -684 feet mean sea level [msl]), The well could possibly be influenced by land application recharge as well as nearby Bear Creek. The current groundwater level for Bear Creek #3 is -49.3 ft msl with an objective of -50.3 ft msl or approximately 150 feet below ground surface. The minimum threshold for groundwater lowering which is being proposed as a basis for assessing depletion of groundwater is -72.3 ft msl. The minimum threshold is the quantitative threshold for each sustainability indicator used to define the point at which undesirable results may begin to occur. Reduction of groundwater levels approximately 20 feet while possibly causing some domestic or agricultural wells to go dry is not adequate to determine that surface water depletions are or are not occurring. The use of groundwater level reductions is inadequate to assess interconnected surface water impacts.
Groundwater Dependent Ecosystems
Groundwater-dependent ecosystems (GDEs) are defined in the GSP regulations as “ecological communities or species that depend on groundwater emerging from aquifers or on groundwater occurring near the ground surface.” SGMA requires the identification of GDEs but does not require that sustainable management criteria be established to manage these areas. GDEs exist where vegetation accesses shallow groundwater for survival; without the access to shallow groundwater, these plants would die. Thus, this Plan identifies GDEs within the Eastern San Joaquin Subbasin based on determining the areas where vegetation is dependent on groundwater as a reduced subset of potential GDEs identified in the Natural Communities Commonly Associated with Groundwater (NCCAG) database. The significant reduction of GDEs as compared to the NCCAG database was related to co-occurrence of surface water sources including irrigation canals. The Delta-Sierra Group objected in February 2019 to the disqualification of local ecosystems as GDEs if sources other than groundwater are available. Specifically, the criteria to not have other sources of water is defined as being at least 50 feet from irrigated land or 150 feet from either managed wetlands or from perennial surface water bodies. These water sources if not receiving water from groundwater will be discharging to groundwater. In either case freshwater species that are critical for ecosystem sustainability benefit: either the in-stream and riparian ecosystems or groundwater dependent ecosystems. The criteria used when removing GDE from the NCCAG database reduced the importance that these areas represent in the Subbasin. This reduction of designated GDE areas may DSG Comments 9
negatively affect future consideration and management actions and result in negative impacts to GDEs within the Eastern San Joaquin Subbasin. As no sustainable management criteria are required for GDEs, the Delta-Sierra Group recommends that a less restrictive method be used if reductions to the NCCAG are desired, and that the Nature Conservancy and California Department of Fish and Wildlife be consulted.
Water Quality, Data Management System, and Monitoring
Water Quality
The Eastern San Joaquin Subbasin groundwater quality is negatively impacted by contaminates not currently proposed for monitoring or inclusion in the Data Management System. Recent reports of a school using a contaminated well creates a reminder of the many contaminant plumes in the Subbasin including petroleum hydrocarbons, solvents, and emerging contaminants. Additionally, monitoring for nitrates in groundwater samples collected from monitoring wells and on-site domestic wells is now a requirement of the Irrigated Lands General Permit16 with results submitted in the State of California GeoTracker database. Nitrate contamination is a significant problem in agricultural areas related to the handling of wastes and applications of fertilizers.
Data Management System
An important part of the initial steps of implementation will be to have several workshops for beneficial users that are interested in accessing the database and creating reports or accessing pre-made report formats. Probably those staff that will be inputting data will also require training. Ideally, as work continues with the database, methods to incorporate contaminant data stored by the State of California in various databases can be explored. Another possibility is that GSAs exercise their powers and authorities to require that other groundwater management data be included in an expanded database. Fees could be charged of those with reportable results to submit to the database. The fees could offset time required by staff to input the data. Perhaps, San Joaquin Environmental Health could administer the database because they already have access to small water system monitoring data under permit. Those using groundwater and those making important planning decisions would benefit from a centralized location for groundwater quality.
Monitoring
Descriptions of monitoring frequencies need to be revised to consistently described the planned semiannual monitoring. Staff involved with the California Statewide Groundwater Elevation Monitoring (CASGEM) well monitoring suggested that conditions could exist that more frequent monitoring may be necessary to capture valid seasonal fluctuations. Consideration should be given to the sampling of representative groundwater level compliance wells quarterly, a reduction of the DWR monthly monitoring suggestion. Semi-annual monitoring may miss transient changes in response to unseasonable conditions.
Understanding these transient changes may help refine the conceptual model.
The monitoring protocols described in The DWR Best Management Practices for the Sustainable Management of Groundwater Monitoring Protocols, Standards, and Sites are used within the existing CASGEM program. The statement that “these protocols and existing resources will be used when possible in data monitoring and collection in support of this GSP” suggests that some wells being monitored by agencies not using these protocols may elect to continue to use their current protocol. A clear commitment that all representative groundwater wells will have well construction details and have data collected consistently using DWR’s best management practices.
Modeling
The Delta-Sierra Group began asking for model specifics in 2017 and submitted correspondence in June 2018 summarizing those requests followed up with November 2018 and January 2019 correspondence. 16 https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/general_orders/ilrp_wdrs_res_final_web.pdf accessed 8.25.19
DSG Comments 10
Public information requests with the DWR and San Joaquin County Counsel resulted in the report being made available in March 2019, six months after the report publication date and one year after it was due to DWR. Efforts are still underway to understand the complexities of the model and evaluate baseline conditions parameters used for model validation. The August 2018 Model Report included a reference to an April 25,2018 Eastern San Joaquin Water Resources Model IDC Workshop that was not noticed or advertised despite stakeholder collaboration being the first topic discussed. Going forward as the model is refined under contract, the Delta-Sierra Group suggests that model refinement include multiple opportunities for interested parties that are stakeholders to become more familiar with the model.
The sustainable conditions scenario for the water budget results in groundwater outflows almost equal to groundwater inflows with a basin sustainable yield estimated to be 715,000 AF/year ± 10 percent. The water budget that was used to identify the 78,000 AF/year of offset needed to balance the groundwater budget over 50 years, is based on model results. This statement is confusing especially given the description of the model results under climate change, as it is unclear which number is being referred to:
This number is larger than the estimated annual overdraft of the projected conditions scenario due to the integrated nature of the groundwater subbasin.
Examples of offsets that could satisfy the groundwater deficit include direct or in lieu groundwater recharge and/or reduction in agricultural and urban groundwater pumping. Projects that reduce projected groundwater pumping and/or increase recharge will help the Subbasin reach sustainability.
Under the intermediate climate change scenario prescribed by DWR, the depletion in aquifer storage is expected to increase by about 68 percent to an average annual storage change of 57,000 AF/year, from 34,000 AF/year in the projected conditions scenario. If the 68 percent is applied to 78,000 AF/year, deficient an additional 53,000 AF/year will be needed and the planned projects projected to achieve sustainability included in the GSP will be insufficient.
Notice of Intent to Adopt GSP
Between 8.20.19 and 8.25.19, the esjgroundwater.org website was updated with the Notice of Intent to Adopted GSP. The website indicated that the Notice was posted on 8.16.19 and sent by mail and email.
The Notice stated that no sooner than 90 days public hearings will be held to consider adoption of the GSP. The GSAs that were listed included Woodbridge Irrigation District which has withdrawn GSA standing with the Eastern San Joaquin Subbasin GWA and the Department of Water Resources. As of
8.25.19, the Notice of Intent to Adopt GSP was not forwarded to the ESJ interested parties list although interested parties were directed to the esjgroundwater.org website for meeting information and public hearing dates. The Notice of Intent to Adopt GSP did include email addresses of GSA representatives in addition to mailing addresses and FAX numbers.
Thank you for the 45 day comment period for the Eastern San Joaquin Groundwater Subbasin Draft Groundwater Sustainability Plan. If any questions arise regarding these comments, please contact me at [email protected].
Sincerely,
Mary Elizabeth M.S., R.E.H.S.
Delta-Sierra Group Conservation Chair
Sierra Club
Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 BN SSJGSA 1‐1 1.1.1
The following figure (Figure
1‐1) shows flagship reports
from these efforts
Add Ag Water Mangement Plans and General Plans to the list. 2 BN SSJGSA 1‐3 1.1.4 Suggest mentioning that Lathrop signed on to the JPA then voluntarly withdrew citing the Basin Boundary modification approved by DWR.3 BN SSJGSA 1‐3 1.1.4 California Water Service Suggest referencing Memorandum of Agreemnt between Calwater and County 4BN 1‐3 1.1.4 WID WID reinstatement as a GSA
5 BN SSJGSA All Throughout Replace GWA with ESJGWA
6 BN SSJGSA 1‐6 1.1.4.2 Decisions of the GWA… Should also reference the JPA document posted to www.esjgroundwater.org 7 BN SSJGSA 1‐9 1.1.4.3 South San Joaquin Irrigation District Escalon is contracted to receive treated surface water ffrom SSJID but has yet to install infrastructure to connect to the system. 8 BN SSJGSA 1‐9 1.1.4.4 The GWA's JPA … Sentaence should read: The ESJGWA's JPA calls out the following powers granted to GSA's by SGMA. 9 BN SSJGSA 1‐11 Figure 1‐4 Include DWR Subbasin Basin Numbers for San Joaquin Basin and 5‐22.01 10 BN SSJGSA 1‐12 Figure 1‐5 Include DWR Subbasin Basin Numbers for San Joaquin Basin and all adjacent basins. 11 BN SSJGSA 1‐13 Figure 1‐6 Sac Co. ans San Joaquin Co/ shades are too similar. 12 BN SSJGSA 1‐17 Figure 1‐10 Call out USDA CropScape 2015 as Data source. 13 BN SSJGSA 1‐19 and 20 Figures 1‐11 and 1‐12 Call out DWR WDL as data source. 14 BN SSJGSA 1‐23 1.2.2.1.1
Might want to call out that the Board of Supervisors of San Joaquin County also act as the Board of Suerpvisors of the SJCFCWCD. The SJC Public Works Department also staffs the SJCFCWCD.
15 BN SSJGSA 1‐24 1.2.2.1.1 Technically, the SJCFCWCD should be called out, not SJC. 16 BN SSJGSA 1‐25 1.2.2.1.5
Not a Technical Review Committee. Participants possessed technical expertise sch as staff and consultants represeting many of the GSAs forming the ESJGWA. 17 BN SSJGSA 1‐32 1.2.2.8 concrete linbed and replaced with replace "PVC" with "buried" 18 BN SSJGSA 1‐35 1.2.3.1.8 Checking with Ripon on GP descrption 19 BN SSJGSA 1‐36 1.2.3.4.1 Confirm and insert that Municipal codes prohibit private supply wells. 20 BN SSJGSA 1‐39 1.2.4
Current opportunities to
participate in plan…
The GP Update is complete so the opportunity to comment is actually through the discretionary approval process which includes CEQA, Planning Commission, appeals, etc.
21 BN SSJGSA 1‐40 1.3.1 Agricultural users and domestic well Delete "of" 22 BN SSJGSA 1‐47 1.3.4.3 Keep interested list of stakeholders Suggested Edit: and/or their preferred mode of communication 23 BN SSJGSA 2‐1 2.2.1.1
The California Statewide
Groundwater Elevation
Monitoring (CASGEM)
Conssitency: SJCFCWCD is the CASEGEM Entity and the SJC Public Work staffs the SJCFCWCD which is a separate legal entity.
24 BN SSJGSA 2‐4 and 2‐6 Figure 2‐6 Suggest deleting figure 2‐4 amd reference on page 2‐4.
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 25 BN SSJGSA 2‐13 Table 2‐1
Suggest clarifying the nu,mbers as the drainage area or sub‐watershed area vs. watershed area. There may be some confusion as to watershed area vs sub‐ watershed area .
26 BN SSJGSA 2‐14 Figure 2‐8 Same comment above.
27 BN SSJGSA 2‐16 2.1.4.3
The Farmington
Groundwater
Recharge/Seasonal Habitat
Study
"MWD" should be "MWH"
28 BN SSJGSA 2‐64 2.2.1.2 Current groundwater elevation conditions Suggest describing measurements as Spring and Fall rather than by quarter.29 BN SSJGSA 2‐104 2.2.9 See attacehd spreadsheet of polygons that have been investigated by staff and determined to be non‐GDE's. The attached sreadsheet lists the reason for the determination.
30 BN SSJGSA 2‐110 Table 2‐12 See Table note 5: Referrence error 31 BN SSJGSA 2‐115 2.3.4.3 As private groundwater
pumping Suggest referencing IDC in Model Report.
32 BN SSJGSA 2‐123 2.3.5.1
The Joint Powers Agreement
(JPA) selected Replace with "The ESJGWA selected"
33 BN SSJGSA 2‐123 2.3.5.1
When analyzing the water
budget for the stream
system
Rplace "…potentiall significant effects…" with "… a calculated increase…" 34 BN SSJGSA 2‐125 2.3.5.1
Additionally, a portion of
the reduction seen in the
overdraft estimate
Replace "…may be due to a shift to…" with "… are the result of converting from groundwater use to surface water supplies…"
35 BN SSJGSA 2‐126 Table 2‐16 3 Agricultural demand is based on Replace 2nd sentance in footnote 3 with : As agricultural land use continually evolves through changes in crop types and urbanization over the historical calibration, averaging of the resulting agricultural demand is less a function of water year type and rather
dependent more on when in the simulation that year type fell. 36 BN SSJGSA 2‐126 Table 2‐16 4 Urban demand evolves
Replace footnote 4 with: "Urbn demands in the Historic Water Budget are reported values from cited sources. Averaging urban demands by year type may not explicitly depict urban growth patterns during the historical model period" 37 BN SSJGSA 2‐127 2.3.5.2
The current water budget
quantifies inflows Replace "basin" with "Subbasin"
38 BN SSJGSA 2‐128 2.3.5.2 Based on 2014 cropping
patterns and
Ad to beginning of sentence: The analysis fixes the l;anduse to current conditions and is based on…
39 BN SSJGSA 2‐128 2.3.5.2 The almost 2.4 MAF/year of Replace "The almost" with "Approximately" 40 BN SSJGSA 2‐129 2.3.5.2 The current conditions
scenario simulates
I'm not sure what this sentence means if you've defined the current condition as 2014 land use and 2015 population
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 41 BN SSJGSA 2‐130 2.3.5.4
Due to the expansion of
urban area in all the major
municipalities, agricultural
acreage is reduced by less
than 40,000 acres.
Replace two sentances with: An important assumption made in the project water balance analysis that due to projected urban growth, agricultural acreage is xpected to decrease by approximately 40,000 acres. While there is agricultural growth anticipated in the eastern areas
of the Subbasin and potential conversion of existing agricultural land to permanent irrigated crops, no reliable
projections were available to include in the simulation; therefore, no additional agricultural land growth was added to
the projected conditions scenario.
42 BN SSJGSA 2‐134 2.3.6
As efforts are made to reach
sustainability in the
Subbasin
Replace "be impacted" with "vary due to a number of proposed mangement actions resulting in increased groundwater levels...". Impacted only sounds negative. 43 BN SSJGSA 2‐134 2.3.7.1 Consistent with Section 354.18(d)(3) and an analysis was performed for the Subbain evaluating the projected water budget with and … 44 BN SSJGSA 3‐4 3.2.1.2 Each of the three conditions
scenarios
Delete "scenarios"
45 BN SSJGSA 3‐4 3.2.1.2
The GSP authors reviewed
prior groundwater‐related
planning documents
Suggested re‐write: Previously adopted groundwater‐related panning documents were reviewed including the … These documents provided a starting point for setting minimum thresholds.
46 BN SSJGSA 3‐4 3.2.1.2
The 2014 IRWMP indicates
Fall 1992
The reference to Fall 1992 actually was developed as part of the 2007 IRWMP and was used as the basis for comparison in a subsequent Programatic EIR.. 47 BN SSJGSA 3‐5 3.2.1.2
The GWA Board determined
that dewatering of domestic
wells may be a potential
undesirable result that could
potentially be used to
confirm the adequacy of the
minimum threshold
methodology.
Proposed re‐write: The GWA Board determined that dewatering of domestic wells may be a potential is undesirable result that and could potentially be used to confirm the adequacy of the minimum threshold methodology.
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 48 BN SSJGSA 3‐5 3.2.1.2
The 10th percentile
domestic well depth (i.e.,
the depth of the top 10th
percent most shallow well)
wasexamined within a
radius around the
monitoring well
representative of local
conditions. A radius of 3
miles around
therepresentative
monitoring well was used in
all cases except for well
03N07E21L003, where a 2‐
mile radius was useddue to
variations in local well depth
due to proximity to the
Mokelumne River. An
average of 400 domestic
wells werecaptured within a
3‐mile radius of each
representative monitoring
well, covering
approximately 76 percent of
thedomestic wells in the
Subbasin.
Suggest replacing with: A radius of 3 miles around each representative monitoring well was used to idetify the 10th percentile domestic well construction depth. For representative monitoring well 03N07E21L003, a 2‐mile radius was used due to variations in groundwater levels due to its proximity to the Mokelumne River. The 3‐ mile radiii (including the 2‐mile radius of monitoring well 03N07E21L003) of each representative monitoring well, includes an average of 400 domestic wells each capturing approximately 76 percent of the domestic wells in the OSWCR dataset..
Domestic well data was
retrieved from Online
System for Well Completion
Reports
50 BN SSJGSA 3‐5 3.2.1.2 Cosider adding the OSCWR domestic well depth dataset to the Appendix. 51 BN SSJGSA 3‐10 3.2.2.1.1 The undesirable result... Delete: "The undesirable result related to reduction in groundwater storage is defined in SGMA as: Significant and unreasonable reduction in groundwater storage." Consider re‐write: Domestic well data obtained from the OSCWR dataset is sparsely populated with information on total casing depth, screening intervals, and the age of the well. The 10th percentile well depthwas choosen due to the uncertainty in the database and to account for domestic wells that may have been drilled to a very shallow depth prior to the current well drilling standards enforced by local jurisdictionsand/or have reached the end of their lifecycle. The10th percentile domestic well depth for groundwater levels is protective of 90 percent of the domestic wells in the OSCWR dataset and is used as the minimum threshold for 49 BN SSJGSA 3‐5 3.2.1.2 (OSCWR), and information
on casing, screening, and
age of well is not available
in most locations. The 10th
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 52 BN SSJGSA 3‐10 3.2.2.1.1
An undesirable result for
reduction in groundwater
storage in the Eastern San
Joaquin Subbasin is
experienced if sustained
groundwater storage
volumes are too low to
satisfy beneficial uses within
the Subbasin over the
planning and
implementation horizon of
this GSP.
Consider replacing with "The ESJGWA has determined that an undesirable result for the reduction of groundwater storage is experienced if sustained groundwater storage volumes are too low to satisfy beneficial uses within the Subbasin over the planning and implementation horizon of this GSP."
53 BN SSJGSA 3‐10 3.2.2.1.2 It is roughly estimated that groundwater… It is estimated that overlying pumpers have limited access equating to approximately the shallowest 23 MAF of groundwater storage in the Subbasin; therefore an undesirable result would occur if groundwater storage levels were depleted by 23 MAF.
54 BN SSJGSA 3‐10 3.2.2.1.3
Although the Subbasin has
enough fresh groundwater
in storage to sustain
Suggested edit: Depletion of 23 MAF within the SGMA panning horizon of 2040 is highly unlikely. There would need to be an event of a catastrophic nature or proonged and exgerated increases in the mining of groundwater, extreme and severe drought, or other major changes in
groundwater management over time could to cause a depletion of groundwater storage to a
significant and unreasonable level.
55 BN SSJGSA 3‐10 3.2.2.1.4
If groundwater levels were
to reach Suggest adding degredation of produced water quality from groundwaeer sources 56 BN SSJGSA 3‐11 3.2.2.2 As noted above, the amount of groundwater Suggest replacing "… until storage reached 30 MAF..." with "...until storate was depleted by 23 MAF…" 57 BN SSJGSA 3‐12 3.2.3.1.1 GSA members and their affiliates "cities" should be Cities and add SJCFCWCD 58 BN SSJGSA 3‐12 3.2.3.1.2 Give examples of groundwater or water management activities that causes groundwater quality degredation. 59 BN SSJGSA 3‐12 3.2.3.1.3 Suggest adding that increases in salinity only occurred in parts of the Subbasin 60 BN SSJGSA 3‐12 3.2.3.1.4
If groundwater quality were
degraded resulting in
undesirable results, the
effect would potentially
include
Replace fisrt part of first sentence with: The potential effects of degraded groundwater quality would include:
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 61 BN SSJGSA 3‐12 3.2.3.2
The minimum threshold of
1,000 mg/L was
Suggested edits: A minimum threshold of 1,000 mg/L was selected based on stakeholder concerns for drinking water and agricultual benefical uses. The minimum threshold selected by the GWA
Board was also informed by stakeholder input. There was a meeting held in Fall 2018 with GSA representatives from San Joaquin County, City of Lodi, City of Manteca, City of Stockton, and Cal Water and an addiitonal meeting with agribusiness members of the Stakeholder Workgroup.
62 BN SSJGSA 3‐17 3.2.5.1.4 Replace unrecoverable with irecoverable 63 BN SSJGSA 3‐19 3.2.6.1.2
Proposed re‐write: An undesirable result will have been deemed to occur if depletions resulted in an impact to a senior water right holder such as if the release of stored surface water occurred in higher frequencxy and volume to meet fish and wildlife requirements or a decrease in the amout of supply avaiablle for a senior water right holder including riparian diverters, or a potential reduction in acreage of groundwater dependent
ecosystems.
64 BN SSJGSA 4‐1 4. Whole Chapter Replace "GWA" with "ESJGWA" 65 BN SSJGSA 4‐3 4.1.2
The 76 wells included in the
broad monitoring network
Sugggested edit: Of the 107 wells in the broad monitoring network, 76 wells included are wells used in CASGEM…
66 BN SSJGSA 4‐13 4.3.3
SJc also has a monitoring protocol and safety manual which could be refereenced in the GSP and also update at a later date possibley to include data hadleing and database management..
67 BN SSJGSA 4‐15 4.7.3 Monitoring Frequency
Suggest reiterating the monitoring frequecy for all well catagories. Quarterly for representative wellls for levels; semi‐anually for broad network for levels, and both represenative and broad network for water quality.
68 BN SSJGSA 4‐15 4.7.1
The DWR’s USGS National
Field Manual for the
Collection of Water Quality
Data…
Reference also Calaveras, Stanislaus ans San Joaquin Counties applicable monitoring well drilling standards.
69 BN SSJGSA 5‐1 5. Whole Chapter Replace "GWA" with "ESJGWA" 70 BN SSJGSA 5‐8 Table 5‐4 San Joaquin County should be San Joaquin County Flood Control and Water Conservation District
71 BN SSJGSA 6‐1 6. Whole Chapter Replace "GWA" with "ESJGWA" 72 BN SSJGSA 6‐31 6.2.6.5 SSJID currently operates a
3,800‐acre pilot… The project is called the Division 9 Project 73 BN SSJGSA 6‐35 Table 6‐2 Table needs an update of upcoming Important Dates 74 BN SSJGSA 7‐1 7. Whole Chapter Replace "GWA" with "ESJGWA" 75 BN SSJGSA 7‐4 Table 7‐2
Some costs appear low. Dicussions are ongoing as to governance, costs, and sacountability measures. Costs should be re‐estimated higher to avoid sticker shock later during implementation.
76 BN SSJGSA 7‐6 7.4.1 Mokelumne River Loss Study Project Suggest lumping the study in with Model Refinements in section 7.4.2. Also suggest study ciould be expanded to include other rivers. 77 BN SSJGSA 7‐12 7.9
GSP Implementation funding lacks specifics. The ESJGWA Board may wish to bolseter and afirm the funding commitment in the resoution when adopting/afirming the GSP.
FID Land Use Description Based on
0 School Sports Field APN 224‐490‐11
1 Grazing Pasture APN 200‐140‐36
2 Grazing Pasture APN 200‐140‐18 and 200‐14‐05
3 Golf Course Drain APN 200‐130‐04
4 Grazing Pasture APN 206‐110‐08
5 French Camp Outlet Canal (SSJID Drain) APN 241‐310‐32 6 French Camp Outlet Canal (SSJID Drain) APN 241‐310‐32 7 School Sports Field APN 224‐490‐11
8 Grazing Pasture APN 218‐060‐14
9 Grazing Pasture APN 218‐060‐04
10 Grazing Pasture APN 218‐060‐03
11 Grazing Pasture APN 218‐060‐10
0 State Highway Intersection
1 State Highway Intersection
2 Golf Course Riparian Stanislaus River ‐ Jack Tone Golf Course 3 State Highway Intersection
4 Willows APN 257‐300‐07
5 Wastewater Plant APN 241‐310‐58
6 Golf Course Riparian Stanislaus River ‐ Jack Tone Golf Course 7 Wastewater Plant APN 259‐110‐07
8 Golf Course Riparian Stanislaus River ‐ Jack Tone Golf Course NE Corner HWY 120 and Union Road
Location
Location
NE Corner HWY 120 and Airport Way
NW Corner HWY 120 and Airport Way
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Eastern San Joaquin Subbasin GSP Public Draft
Summary of Public Comments and Responses
Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 1 Stockton East
Water District
Stockton East
Water District GSA Page 1 ‐ 27 Section 1.2.2.4
"Periodic subsidence
reporting within the Eastern
San Joaquin Subbasin is not
known to occur.
This sentence does not make sense. Suggest revision to: "There has been no documented subsidence reported within the Eastern San Joaquin Subbasin." 2 Stockton East
Water District
Stockton East
Water District GSA Page 1 ‐ 36 Section 1.2.3.4.1`
"San Joaquin County has
established water well
standards. . . "
A more accurate statement would be "San Joaquin County has established water well standards for new wells that define property line setbacks . . . ETC." as these requirements apply only to new wells.
3 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 111 Section 2.3.4.1
"Streamflows entering the
Subbasin are regulated
releases from respective
reservoirs."
This is not entirely accurate, streamflows entering the subbasin do induce regulated releases from respective reservoirs, but also include inflow from unregulated streams downstream of regulating reservoirs. This should be noted. 4 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 112 Section 2.3.4.1 Riparian Diversions Stockton East Water District should be included in the list of districts with riparian diversions off major streams. 5 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 112 Section 2.3.4.1
"Data on private pumping
was not available. . . "
Data on private pumping is available from Stockton East Water District, was provided to the consultant, and is more accurate that that calculated by the consumptive use methodology.
6 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 112 Section 2.3.4.2 Calaveras River The cited stream flow data does not include inflow into the Calaveras River below New Hogan Dam, including Cosgrove Creek and others. Similarly, the data list does not include flow for other nonregulated reservoirs in the watershed. 7 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 113 Section 2.3.4.2 Riparian Stockton East Water District should be included in the list of districts with riparian diversions off major streams. 8 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 113 Section 2.3.4.2
"As private groundwater
pumping was estimated. . ."
Data on private pumping is available from Stockton East Water District, was provided to the consultant, and is more accurate that that calculated by the consumptive use methodology.
9 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 115 Section 2.3.4.3 Riparian Stockton East Water District should be included in the list of districts with riparian diversions off major streams. 10 Stockton East
Water District
Stockton East
Water District GSA Page 2 ‐ 115 Section 2.3.4.3
"As private groundwater
pumping was estimated. . ."
Data on private pumping is available from Stockton East Water District, was provided to the consultant, and is more accurate that that calculated by the consumptive use methodology.
11 Stockton East
Water District
Stockton East
Water District GSA Page 6 ‐ 9 Section 6.2.4.2
"This is an existing surface
water right." More accurately, these are existing surface water entitlements under contract. 12 Stockton East
Water District
Stockton East
Water District GSA Page 6 ‐ 13 Section 6.2.4.6 "However, individual applicants. . ." Grammatical correction ‐ the word "a" should be deleted before the word "streambed." 13 Stockton East
Water District
Stockton East
Water District GSA Page 7 ‐ 12 Section 7.9 "Prior to implementing. . ." The sentence should be rewritten to state: "Prior to implementing any fee or assessment program, the GSAs would complete a rate assessment study or other analysis if required by consistent with the regulatory requirements." Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 14 Stockton East
Water District
Stockton East
Water District GSA Page 7 ‐ 12 Table 7‐4 In the first and third boxes under "Certainty" the Proposition 218 process should be qualified with "if applicable."
T E R R A L A N D G R O U P , L L C
___________________________________
August 21, 2019
VIA EMAIL
Eastern San Joaquin Groundwater Authority
1810 E. Hazelton Avenue
P. O. Box 1810
Stockton, CA 95201
([email protected])
Re: Public Comments Concerning the Public Draft of the July 2019 Eastern San Joaquin Groundwater Subbasin Groundwater Sustainability Plan.
Dear Board Members,
My name is Martin Harris and I am an authorized representative for Terra Land Group, LLC (“TLG”).
In July 2019, the Eastern San Joaquin Groundwater Authority (“ESJGA”) released a Draft July 2019 Eastern San Joaquin Groundwater Subbasin Groundwater Sustainability Plan (“GSP”) for public review and comment. TLG reviewed the public comment submittal template as provided through the website, but we feel the scope of the project involved merits a longer response than the template provides for. Therefore, we are submitting this formal letter with enclosures attached to do justice to the full environmental impact report.
Section ES-1 of the GSP provides an introduction that details twenty-three potential projects and other actions being considered to meet the requirements of the California Sustainable Groundwater Management Act.
Section ES-7 details water budgeting related to projected groundwater pumping and offsets required to achieve sustainability.