Attachment 2 - Revised GSP & Appendices — Manteca City Council, July 19, 2022 (part 6 of 9)

the majority of agriculture in the Sub-basin…alfalfa and irrigated pasture were the next most dominant crop.”
COMMENT: TLG believes that due to a growing number of economic and other environmental factors affecting the ability of farmers to profitably grow crops and operate dairies in the San Joaquin Valley, any water sustainability plan to be considered must take into consideration that many farmers are abandoning lower-priced crops like alfalfa and silage corn to seek higher-priced food crops that may be less tolerant to the salinity levels typical of recycled water (See Project 19/Manteca Recycled Water Project as described on pages 6-28 and 6-29 of the GSP) ___________________________________
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considered a loss to Districts in the short term, has played and will continue to play a crucial role in the long-term sustainability of groundwater resources in the Eastern San Joaquin Sub-basin.” COMMENT: TLG agrees with this comment on page 1-31, but also believes that open canals currently being utilized in the sandy areas of the sub-basin must be properly managed and maintained to offset the potential effects of sedimentation and erosion.

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San Joaquin Valley, flowing northward on the west margin of the Eastern San Joaquin Sub-basin to its confluence with the Sacramento River in the San Joaquin-Sacramento Delta.” COMMENT: TLG believes that channel flow deficiencies and back-water effects in and along the South Delta need to be fully considered and mitigated as part of any GSP to be considered. (See Enclosures 1-18)

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(Eastern San Joaquin Water Resources Model) scenarios due to the sequence of the hydrologic period, population projections, future cropping patterns, and irrigation practices and technologies, as well as uncertainties inherent in the representation of the physical groundwater and surface water system by the model.”

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DWR’s guidance document (DWR, 2018 b) and uses “best available information” related to climate changes in the Eastern San Joaquin Sub-basin. There are limitations and uncertainties associated with this analysis. One important limitation is that Cal Sim II does not fully simulate local surface water operations. Thus, the analysis conducted for this GSP may not fully reflect how surface and groundwater basin operations would respond to changes in water demand and availability caused by climate change.” COMMENT: The uncertainties as detailed on pages 2-134 and 2-151 of the GSP appear to be especially important when considering Section 6.2.6.6 of the GSP describes project #23 (SSJID Storm Water Reuse) which may find it difficult to drain any and all potential storm water drainage flows to be created along and through the South San Joaquin Irrigation District (“SSJID”) distribution system to the San Joaquin River via the French Camp Outlet Canal. (See page 6-32 of the GSP)
TLG also believes that SSJID drainage into the San Joaquin River may also prove problematic at other San Joaquin River outlet locations currently being considered.

Other GSP Projects to consider:
(i) GSP Section 6.2.6.2 describes Project #19 (Recycled Water Transfer to Agriculture) (See GSP Pages 6-28 and 6-29); and
(ii) GSP Section 6.2.6.5 describes Project #22 (Pressurization of SSJID Facilities) (See GSP pages 6-31 and 6-32)
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QUESTION: What drainage and backwater effects may be created in conjunction with GSP Projects #19, 22, and 23?
With a number of unresolved hydrology and other environmental issues that may significantly affect drainage in and along the South Delta, TLG presents the following additional comments for the project staff’s consideration.

As you may be aware, the South Delta-Lower San Joaquin River Basin, including the areas south of Manteca and Lathrop, is a recognized floodplain. The area narrowly escaped the impacts of flooding when a levee breach occurred on February 20, 2017 in South Manteca on the San Joaquin River, thanks to the efforts of several quick-thinking farmers who risked their lives to repair it. The breach occurred when the river channel was flowing at approximately 40,000 cubic feet per second (“cfs”). This flow rate was well below the design capacity of 66,080 cfs that the San Joaquin River levees called for in the 2014 draft copy of the Lower San Joaquin and Delta South Regional Flood Management Plan. TLG believes this breach could be a warning sign of a more disastrous flood to come, and TLG has been urging local and state authorities to take action to protect the region before a more devastating flood occurs.

TLG believes there appears to be an unsustainable level of development growth and changes to land uses affecting the areas in and along the South Delta-Lower San Joaquin River Basin. TLG believes that this growth may create and/or increase flood risks to the urban and rural residents, businesses, and property owners located in the areas to be affected. As the area continues to grow, more residents and businesses will move in, creating more people and valuable property to be affected. The potential damages and impending liability will only increase over time.

TLG is not necessarily opposed to development growth, provided however, that the urban and urbanizing areas already approved or to be considered for development growth must fully identify, allow for, and provide for timely mitigation measures. These measures should fully offset any and all upstream and downstream flood water, storm water, waste water, potable and agricultural/irrigation water delivery, back water, and other hydrology-related short-term as well as long-range impacts that may be created.

TLG believes that this can only be accomplished by putting an end to the continuing delays and immediately performing a full and comprehensive environmental review. This should be performed in conjunction with an updated general plan and related environmental justice element that fully considers and mitigates for the growing storm water, waste water, potable water, irrigation water, transportation, and transit needs affecting the areas in and along the South Delta.

This review should also consider any and all development-related flood and other hydrology-related impacts as affected by the federally-approved Lower San Joaquin River Flood Management Project (100-year level of protection) in association with California Senate Bill No. 5 (“SB5”) (200-year level of protection) requirements as well as any Stanislaus River Basin Drainage Plan (sponsored by the South San Joaquin Irrigation District and Oakdale Irrigation District Tri-Dam Project), or Ripon/South Manteca Stanislaus River Right Bank Levee Breach Flood Fight Action Plan to be considered.
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Over the last few years, TLG has presented hundreds of letters, documents, engineering and survey data, and other forms of evidence to the authorities involved to support our concerns. TLG has also attended dozens of council, commission, and board meetings and has spoken to various authorities both publicly and privately to seek answers regarding federal, state, and local involvement related to water management decisions and potential impacts to our community.

These letters and documents are available on request. The enclosures attached to this letter explain our concerns in detail, linking them to evidence as presented in the previously-released environmental impact reports and feasibility studies. Please review the enclosures attached to understand the full potential for impacts involved.

In summary, TLG is concerned regarding the following points:

1. Backwater effects and changes to drainage patterns, in conjunction with anticipated 200-year flood protection improvements as affected by a San Joaquin River and/or Stanislaus River right bank levee breach, could have a devastating effect on the urbanizing and non-urbanizing areas in and along the South Delta/Lower San Joaquin River Basin. (See Enclosures 1-15)

2. The City of Manteca has been experiencing exponential development growth and urban expansion. Many of the involved projects appear to have been approved with no apparent meaningful consideration for their individual contribution to total cumulative drainage impacts. The accompanying changes to grade, land elevations, and drainage patterns may be creating irreversible impacts to the surrounding community, and could increase flood risk to those affected. (See Enclosures 1-4 and 6-15)

3. TLG believes that these continued project approvals (and associated impacts) directly conflict with the goals and policies stated in the Manteca General Plan 2023 (enacted on October 6, 2003) and fail to adequately address public risk due to recently-discovered San Joaquin River channel flow deficiencies in conjunction with unresolved sedimentation and climate change issues affecting the areas in and along the South Delta.

4. The Paradise Cut Expansion project, in the form presented in the “Conceptual Design Technical Memo/Paradise Cut Expansion Project/April 9, 2019,” may or may not prove adequate in offsetting the full range of development and other hydrology-related impacts that may be created. Also, TLG believes that the Paradise Cut Expansion Stage reductions called for between the Paradise Weir and the Airport Way (Vernalis Bridge) may not fully address the potential for additional drainage impacts to be created. (See Enclosures 1-15) This is especially concerning when considering pages 4 and 5 of the Mossdale Tract Program: 2019 Annual Adequate Progress Report Update for Urban Level of Protection-Final Report (included as Attachment 2 to the 8/20/2019 MCC Meeting Agenda Item B.3), which states that, “the Urban Flood Risk Reduction Study remains incomplete and the Climate Adoption Policy is underway. As such, a new determination that the project meets the appropriate Standard of Protection will need to be made in conjunction with the 2020 Annual Report.”
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QUESTION: How will what appears to be a very real potential for unresolved and continuing sedimentation and climate change issues in and along the South Delta be considered and allowed for in the final Mossdale Tract Drainage Plan? (See Enclosures 1-15 & 18)

5. The San Joaquin River may be unable to handle any and all potential combinations of storm water or waste water flows that may be drained into or along the river channel.

6. With all of the various development and infrastructure projects being approved and considered by the different agencies in and around Manteca and the South Delta region, TLG is concerned that there is a lack of integration and cohesion between the agencies related to the projects. Without a single oversight agency in charge of the “big picture,” or all the hydraulic decisions being made, there may be a potential for the various projects to cause conflicting hydraulic effects and impacts to the upstream and downstream communities that may be affected. A list of forty-one such currently ongoing and planned projects can be found in Enclosure 1. (Also See Enclosures 2-15) QUESTION: How can local, regional, state, and federal authorities work closer together to create an updated water plan that provides water deliveries at the local, regional, and state level while protecting the urban and rural areas along the South Delta from any increases to flood water, storm water, waste water, and other hydrology-related impacts that may be created?

7. Projects appear to continue to be approved by various agencies without the agencies fully understanding the total potential for flood water, storm water, and waste water impacts involved. Agencies, city councils, and districts appear to be more interested in supporting development and in avoiding liability than they are in safeguarding the residents and businesses that may be affected.

QUESTION: What effect will the Daniels Street extension have on stormwater drainage flows currently being drained in and along the French Camp Outlet Canal? (See the July 16, 2019 Manteca City Council meeting agenda item B.4. Also See Enclosure 3) QUESTION: What effect will the proposed formation of the San Joaquin County Flood Control & Water Conservation District (“SJCFCWCD”) Zone 9 Flood Conveyance and Levee Maintenance Benefit Assessment District (and related projects) have on changing drainage patterns and associated outfall locations currently existing and relied upon by the South San Joaquin Irrigation District and its members? (See July 18, 2019 SJAFCA meeting agenda item 5.1. Also See Enclosures 1-15)

8. The Manteca General Plan 2023 states several goals and policies which appear to indicate that Manteca is committed to protecting the community from flooding related to existing and projected development. (See Enclosure 1) It appears that both the cities of Manteca and Lathrop plan on redirecting storm water drainage and/or effluent wastewater flows along and through the urbanizing and non-urbanizing areas in and along the South Delta-Lower San Joaquin River Basin. However, no meaningful solution has been clearly presented to identify City of Manteca effluent waste water spray field discharge facilities ___________________________________
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to replace those to be abandoned due to planned construction of several new development projects.

QUESTION: What effect will filing and/or extending an Exclusive Negotiating Agreement for the Recycled Water Project have on sustaining total potable and irrigation water (ie. groundwater and surface water) volumes available to the urban and rural areas in and around Lathrop and Manteca? (See the July 16, 2019 Manteca City Council meeting agenda item B.8. (See Enclosure 3; Also within Enclosure 1, see its own Enclosure 4)

9. Further, TLG believes that the San Joaquin County (and other local community) general plan(s) have failed to meet the public safety and environmental impact disclosure and mitigation requirements as called for in California Senate Bill No. 1000 (“SB 1000”) (environmental justice) and CEQA. San Joaquin County, as well as the various other non-federal sponsors involved, should be acting in a good-faith manner to fully identify and mitigate the potential for flood and other hydrology related impacts and health risks to the disadvantaged communities that may be affected.

10. The City of Manteca General Plan 2023 indicates that the French Camp Outlet Channel “is the limiting factor that sets the flow rates for drainage systems in the City of Manteca.” TLG believes that due to SB5 200-year flood protection requirements, various flood drainage impacts and back-water effects may be created affecting the hydraulic capacity of the system. TLG also believes this may be particularly true for certain outfall locations that may be proposed in areas not currently protected by a 200-year flood protection levee. (See Enclosure 1)

11. The effect of 200-year flood protection and related potential for underestimating drainage and back water effects associated with the location of the Raymus Expressway as depicted in the proposed Land Use Map Alternatives “A” and “B” to be considered by the Manteca City Council in association with the Manteca City Council 7/30/2019 meeting agenda item C.1. (See Enclosures 10 & 11)
QUESTION: What short term and/or long range changes to flood water, storm water, waste water, potable and irrigation water delivery, and other hydrology related drainage and conveyance patterns may be irreversibly altered due to approval of the proposed Raymus Expressway roadway alignment as detailed in the 5/22/19 Manteca General Plan Land Use Alternative Maps “A” or “B”? (See 7/30/2019 Manteca City Council meeting agenda item C.1 (19-360) Attachments 1 and 2)

12. Undetermined back water and other potential drainage effects associated with the Upper Jones Tract (RD 2029) and Lower Jones Tract (RD 2038) consolidation. (See Enclosures 12 & 13)
QUESTION: Will drainage impacts in and along the South Delta be reduced or adversely affected due to any future improvements to be considered in association with the Upper Jones Tract (RD 2039)/Lower Jones Tract (RD 2038) consolidation? ___________________________________
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13. What appears to be a potential for system-wide ESJGA drainage modeling deficiencies and unmitigated impacts due to apparent ground surface grade and elevation level variations associated with the growing number of collaborative watershed and agricultural landscape easements being acquired on properties located in and along the South Delta. (See Enclosure 19)

14. Changing climate and increasing flood risks across the country. Levees are only one solution to flood control; they have their limits. (See Enclosure 5) On August 5, 2019, the City of Manteca issued a Request for Proposal for Storm Drain Zones 36 & 39 Engineering, Environmental and Permitting (CIP 20004). ("Request for Proposal") (i) Section 2.1 of the Request for Proposal states: "With the exception of Drain #II near the southern boundary of Zone 39, there are no regional drainage facilities in the study area.” However, TLG believes that it is important to mention that a second drain (SSJID drain #10) exists with a location beginning at a point situated adjacent to Airport Way (just north of the Airport Way/Fig Avenue public roadway intersection); and extending in a direction approximately west to the City of Manteca Storm Drainage Zone 39 eastern boundary; and thence turning and continuing in a generally southern direction along the Zone 39 eastern boundary until meeting and connecting with SSJID Drain #11 near the southern boundary of the current City of Manteca city limits.

In addition, a growing number of South Manteca land owners and residents are starting to consider the potential for various changes in drainage patterns, flow volumes and other environmental effects that may significantly impact SSJID drains #10 and #11 as those drains merge together and continue through Drain #11 along the southern boundary of the City of Manteca and into Walthall Slough.

QUESTION: Are local authorities aware that SSJID Drain #11, in its present form, has deviated from a course that appears to be called for in Enclosure 16? QUESTION: Will any and all flow impedances and back water effects be considered as part of any drainage analysis to be performed? (See Enclosures 14 & 15) QUESTION: For what purpose are San Joaquin County land use and/or zoning reclassifications in and along the South Delta being considered? (See Enclosure 17) (ii) In addition, the Request for Proposal does not appear to consider City of Manteca storm drainage Zone 34.

QUESTION: If the French Camp Outlet Canal (FCOC) is abandoned or no longer able to accept drainage flows from the developing areas of Zone 34, where will Zone 34 storm water be drained to? (See Enclosures 14 & 15) QUESTION: What effect will any public facility/infrastructure rehabilitation or improvement projects in and along Little Johns Creek have on the continued ___________________________________
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operation of the FCOC as well as other upstream and downstream areas to be affected?
(iii) The Request for Proposal further states:

4.1 Drainage
Planning and design of storm water collection, conveyance, and storage systems are predicated on the following assumptions:

1. Runoff is attenuated through detention basins prior to discharge to regional Facilities.

Detention basins will be sized to store a 10-yr, 48-hr event. Detention basins will empty by gravity or pumps, over a 96-hr period. The bottom elevation of the detention basin will be a minimum of 2 ft above the groundwater elevation.

2. The high-water level in the storage system will be a minimum of 1 ft below the lowest grade elevation of the property served.

3. Minimum pipe diameter of storm drains will be 12-inches. Pipe velocities will range from

2.5 to 10.0 ft per second (ft/sec). Storm drains will have a minimum cover of 30-inches.

4. Manholes will be located at junction points, changes in alignment, and changes in pipe size. Manholes will be spaced every 300 ft for pipe diameters less than 21-inches and 500 ft for pipe diameters greater that 21-inches.

5. Detention basin pump stations will be designed to discharge the 10-yr, 48-hr storm volume from the basin during a period of not less than 96 hours. Pump stations will be equipped with a minimum of one standby unit. Pump stations will be designed with trash racks sediment dams.

6. Drainage channels will be designed to confine the peak 100-yr discharge with 2 ft of freeboard.

7. Water surface elevation (WSEL) in the San Joaquin River at the railroad bridge crossing near the OLWD storm drain outfall is: (a) 20.6 ft for 10-yr event; (b) 28.0 ft for 100-yr event; and (c) 29.0 ft for 200-yr event. All elevations reference NAVD88 datum.

QUESTION: Are the effects of climate change and unresolved sedimentation issues along the South Delta being fully considered while making the assumption that the water surface elevation in the San Joaquin River at the railroad bridge crossing near the Oakwood Lake Water District storm drain outfall is: (a) 20.6 feet for a 10-year event; (b) 28.0 feet for a 100-year event; (c) 29.0 feet for a 200-year event. (See Enclosures 1-15) QUESTION: In the event of a right bank San Joaquin River or Stanislaus River levee breach, how will flood waters be drained from the urbanizing and non-urbanizing areas south of Manteca?
QUESTION: When considering the magnitude of 100-year, 200-year, or other periodic levels of flood events that are expected to occur, isn’t it likely that water elevations (NAV D88 datum) on the land side (east of the San Joaquin River in the areas south of Manteca) could exceed the 29’-0” elevation as forecasted in the Request for Proposal? QUESTION: What facilities and other actions are planned to safeguard and protect our local urban and rural communities against the unplanned release of right bank San Joaquin ___________________________________
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River levee breach flood waters that historically accumulate and rise in height against the South Manteca portion of the RD 17 dryland cross levee? In closing, TLG urges authorities and project team members involved to stop the delays and recommend and support a full and comprehensive environmental review in conjunction with any and all previously-approved and reasonably-foreseeable projects to determine the total cumulative drainage impacts and backwater effects. This should be done before approving or recommending any ESJGA Groundwater Sustainability Plan or related project to move forward that does not fully identify and mitigate any and all drainage and other impacts to be expected. (See Enclosures 1-19)
Thank you for your attention to this very important matter.

Respectfully,
Martin Harris
for Terra Land Group, LLC.

MH/cm
Enclosures:

Enclosures with hyperlinks can be accessed and downloaded via Dropbox.

1. 2019-07-08 letter from TLG to the Manteca Planning Commission (https://www.dropbox.com/s/gb5m4idk7w968wr/2019-07-22_LTR_MPC_AgIt6.1.pdf?dl= 0)

2. 2019-07-10 letter from TLG to the Tri-Valley San Joaquin Regional Rail Authority (https://www.dropbox.com/s/av5zp60u1f2pyw7/2019-07-10_LTR_TVSJVRRA_ValleyLin k.pdf?dl=0)

3. 2019-07-15 letter from TLG to the Manteca City Council (https://www.dropbox.com/s/6suvyxweqb8wo0i/2019-07-15_LTR_MCC_AgItsB.4.pdf?dl =0)

4. 2019-07-16 letter from TLG to the San Joaquin Area Flood Control Agency (https://www.dropbox.com/s/rwumj9hlh8qfyws/2019-07-16_LTR_SJAFCA_AgIts5.1.pdf? dl=0)

5. 2019-07-19 Manteca Bulletin article “As flood risks increase across USA it’s time to recognize limits of levees”

6. 2019-07-22 letter from TLG to the Central Valley Flood Protection Board (https://www.dropbox.com/s/nzqls8yeelwxk6q/2019-07-22_LTR_CVFPB_AgIts5F.pdf?dl =0)
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7. 2019-07-08 letter from TLG to the San Joaquin County Local Agency Formation Commission
(https://www.dropbox.com/s/kt4dteou08jt7zp/2019-07-08_LTR_LAFCo_AgIt3.pdf?dl=0)

8. 2019-06-10 letter from TLG to the San Joaquin County Local Agency Formation Commission
(https://www.dropbox.com/s/mj03mzwpu3hb24g/2019-06-10_LTR_LAFCo_AgIts3-5.pdf? dl=0)

9. 2019-06-17 letter from TLG to the American Rivers and San Joaquin County Resource Conservation District
(https://www.dropbox.com/s/q24qx0vu98nokdr/2019-06-17_LTR_AmRivers_ParadiseCu t.pdf?dl=0)

10. Attachments 1 and 2 from the 07-30-2019 Manteca City Council Special Meeting, agenda item C.1 (19-360)

11. 2019-07-29 letter from TLG to the Manteca City Council (https://www.dropbox.com/s/w7cu83tzs7io9ll/2019-07-29_LTR_MCC_AgItC.1.pdf?dl=0)

12. 2018-09-10 letter from TLG to the San Joaquin County Local Agency Formation Commission
(https://www.dropbox.com/s/p43d2hsn9kbiow7/2018-09-10_LTR_LAFCo_AgIt4.pdf?dl= 0)

13. 2018-12-12 letter #2 from TLG to the San Joaquin County Local Agency Formation Commission
(https://www.dropbox.com/s/krkzs9w7vpwguo3/2018-12-12_LTR2_LAFCo_AgItPubCom m.pdf?dl=0)

14. 2018-05-14 letter from TLG to Greg Showerman
(https://www.dropbox.com/s/8oao37q42u7u4e5/2018-05-14_LTR_GShowerman_TM2.2. pdf?dl=0)

15. 2018-11-28 letter from TLG to Greg Showerman
(https://www.dropbox.com/s/hftxivtlgnfupdw/2018-11-28_LTR_Showerman_Drainage.pd f?dl=0)

16. South Manteca assessor’s map showing Dredger Cut

17. San Joaquin County Zone Classification application No. PA-1700172 of San Joaquin County: December 7, 2017 Notice of Public Hearing--Item Rescheduled, documentation and supporting maps

18. 08-14-2019 Reservoir storage and release data (as published by the CA Department of Water Resources on the California Data Exchange Center website)

19. American Rivers/CDFW property easement at the Kisst Dairy property as included on the San Joaquin County Habitat Conservation and Open Space Plan (included as Agenda Item 4Q in the August 22, 2019 Joint Meeting of the Board of Directors for the San Joaquin Council of Governments and SJCOG Inc.)
cc:

San Joaquin Flood Control and Water Conservation District, ℅ Fritz Buchman ___________________________________
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San Joaquin Area Flood Control Agency, Attn: Marlo Duncan, Project Manager Manteca City Council, ℅ Lisa Blackmon, City Clerk
City of Manteca Community Development Director, Greg Showerman Central Valley Flood Protection Board, Attn: Ryan Jones Central Valley Flood Protection Board, Attn: Leslie Gallagher, Executive Officer South San Joaquin Irrigation District Board of Directors, ℅ Danielle Barney, Executive Secretary/Clerk of the Board
San Joaquin Council of Governments, ℅ Diane Nguyen
San Joaquin Local Agency Formation Commission, Attn: James Glaser South San Joaquin Groundwater Sustainability Agency, ℅ Danielle Barney Reclamation District No. 17, ℅ Nomellini, Grilli & McDaniel PLC Reclamation District No. 2075, Attn: Pam Forbus
Reclamation District No. 2094, Attn: Pam Forbus
Tri-Dam Project Board of Directors
Eric Thorburn, Oakdale Irrigation District, Water Operations Manager / District Engineer American Rivers, Attn: Aysha Massell, Associate Director Lathrop City Council, ℅ Teresa Vargas, City Clerk
Diane Lazard, City of Lathrop
Michael Mierzwa, Lead Flood Management Planner, California Department of Water Resources
Jon Ericson, Hydrology and Flood Operations Officer, California Department of Water Resources
California Department of Water Resources, Attn: Mary Jimenez ___________________________________
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T E R R A L A N D G R O U P , L L C ___________________________________ Enclosure 5
2019-07-19 Manteca Bulletin article “As flood risks increase across USA it’s time to recognize limits of levees”
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T E R R A L A N D G R O U P , L L C ___________________________________ Enclosure 10
Attachments 1 and 2 from the 07-30-2019 Manteca City Council Special Meeting, agenda item C.1 (19-360)bb
bb
___________________________________
5 1 5 1 E. A L M O N D W O O D D R I V E M A N T E C A, C A 95337 UV120
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May 22, 2019
Legend
Manteca City Limits
Manteca Sphere of Influence
Master/Specific Plan Overlay
Urban Reserve Overlay
Policy Area
Preferred Alternative Land Use Designations
AI - Agricultural Industrial
AG - Agriculture
C - Commercial
CMU - Commercial Mixed Use
DW - Downtown
VLDR - Very Low Density Residential
LDR - Low Density Residential
MDR - Medium Density Residential
HDR - High Density Residential
BIP - Business Industrial Park
BP - Business Professional
I - Industrial
OS - Open Space
P - Park
PQP - Public/Quasi-Public q 0½
1 Miles
R
OTH
R
D
E
X
T
E
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S
I
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N
Manteca General Plan
Preferred Alternative “B”
T E R R A L A N D G R O U P , L L C ___________________________________ Enclosure 16
South Manteca assessor’s map showing Dredger Cut and
SSJID Drains; Figure 5-1 showing future drainage improvements as published in the City of Manteca 2013 Storm Drain Master Plan
___________________________________
5 1 5 1 E
A L M O N D W O O D D R I V E M A N T E C AC A 95337
South Manteca Assessor’s Map
SSJID Drain #11
SSJID Drain #10
SSJID Drain #10
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PS - 20Cotta
PS - 5 Quail Ridge
Brock Elliot
PS - 7Sequoia
PS - 35Dutra NE
PS - 27Roberts
PS - 30Dutra SE
PS - 31Bella Vista
Union Park
PS - 24Gonsalves
St. Dominic's
PS - 25Walnut
PS - 34Spreckels Lower
PS - 33Spreckels Upper
PS - 26Curran Grove PS - 13 Mikesell
PS - 9Industrial Park PS - 8
Vanderbilt
PS - 38Woodward Park
PS - 1North Street
PS - 14New Horizons
PS - 21Button Estates
PS - 29Springport
PS - 22Diamond Oaks
PS - 19Shasta Park
Springtime Park
CrestwoodPark
Colony Park
PS - 11Graystone
St. FrancisPark
PS - 16Mayors
PS - 32Primavera
PS - 28Villa Ticino
PS - 12Doxey
PS - 23Chadwick
TrailwoodChannel
PS - 2Poplar
PS - 10
Bay Meadows Manor Oak
PS - 15Lathrop Road
Pebble &MontereySensor
Lower Drain 4Sensor #1
Upper Drain 5Sensor #5
Lower Drain 5Sensor #2
Drain 7Sensor #3
PS - 3Garden Gate
PS - 4Cardoza East
PS - 36 PaseoDrain 8
PS - 37Crossroads Grace
PS - 41Terra Bella
PS - 40Antigua PS - 39
Paseo West
PS - 43Stadium Center
PS - 45Big LeagueDreams
Moffat
Mt. Valley
PS - 42Tesoro
PS - 46Dutra Estates
PS - 44Raymus Plaza
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PS - 49Rodoni
PS - 48Ashbrooke
PS - 47Maple Valley
PS - 62Union Ranch East
PS - 64Ken Hill
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{ McKinley-Peach Avenue Extension }

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INTERSTATE 5

CITY OF MANTECA

PUBLIC WORKS DEPARTMENT
³
Future Drainage Improvements
Figure 5-1
\\utopia\GIS\Workspace\PW\SDMP\Exhibits\Future_Drainage_Improvements_24x36(fig.5-1).mxd 012 0.5
Miles
Legend:

INTERSTATE 5
#
ZONE 30
ZONE 32
ZONE 34
ZONE 39
ZONE 36

CITY DRAIN (IN USE)

PROPOSED DRAIN BY CITY

PROPOSED SSJID/CITY DUALUSE LATERAL BY DEVELOPEREXISTING SSJID/CITY DUAL USE LATERALSSJID LATERALCITY DRAIN (NOT IN USE)SSJID DRAIN (
$

CITY TELEMETRYMONITORING STATIONPRIVATE TELEMETRY

DIRECT DISCHARGE AREA
!( STORM DRAIN IMPROVEMENT
(A PRIVATE PUMP STATION

PROPOSED LATERAL (CITY/SSJID)
NON_RESIDENTIAL AREAFOR INFILTRATION BASIN

PARCELS

REGIONAL PIPELINE FOR DEVELOPABLE AREA

REGIONAL PUMP STATION
) FOR DEVELOPABLE AREA

PROPOSED LATERAL (DEVELOPER)
T E R R A L A N D G R O U P , L L C ___________________________________ Enclosure 17
San Joaquin County Zone Classification application No. PA-1700172 of San Joaquin County: December 7, 2017 Notice of Public Hearing - Item Rescheduled, documentation and supporting maps
___________________________________
5 1 5 1 E. A L M O N D W O O D D R I V E M A N T E C A, C A 95337

5 5
Alameda Alameda
Contra Costa Contra Costa
Sacramento Sacramento Amador
Amador
Calaveras
Calaveras
Stanislaus Stanislaus
580
205
132
4 12
12 88
160
26 12
88 120
108
99 33
88 120
26 132
4 88
99 Stockton
Tracy
Lodi
Lathrop
Manteca
Ripon
Escalon
Figure LU-1
0 51 2.5 0 General Plan Land Use Diagram
Miles
Legend
City Limits
Interstate
Highway
Water
General Plan
Designations
Residential
Rural (R/R)
Very Low Density
(R/VL)
Low Density (R/L)
Low and Medium
Density (R/LM)
Medium Density (R/M)
Medium-High Density
(R/MH)
High Density (R/H)
Commercial
Neighborhood (C/N)
Community (C/C)
General (C/G)
Office (C/O)
Freeway Service
(C/FS)
Rural Service (C/RS)
Mixed-Use (C/MX)
Recreation (C/R)
Industrial
Limited (I/L)
General (I/G)
Truck Terminal (I/T)
Public/Quasi-Public
Public (P/F)
Agricultural
General (A/G)
Limited (A/L)
Urban Reserve (A/UR)
Open Space
Parks and Recreation
(OS/PR)
Resource Conservation
(OS/RC)
Source: San Joaquin County, 2016
Request No.: A-3
Request No.: A-17
Request No.: A-21
Request No.: B-6
Request No.: G-2
Request No.: G-8
Request No.: F-11
Request No.: A-19 Request No.: F-7
Request No.: C-4
Request No.: B-2
Request No.: B-4
Request No.: F-8
Request No.: F-1
Request No.: C-2
Request No.: A-16
Request No.: F-5
Request No.: E-5
Request No.: C-3
Request No.: G-7
Request No.: A-13
Request No.: D-4
Request No.: B-15
Request No.: A-6
Request No.: B-9
Sources: Esri, HERE, DeLorme, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), MapmyIndia, NGCC, © OpenStreetMap contributors, and the GIS User Community
PA-1700172

REQUEST LOCATOR
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PGDWD PH
Imagery ©2017 Google, Map data ©2017 Google 2000 ft
T E R R A L A N D G R O U P , L L C ___________________________________ Enclosure 18
2019-08-14 Reservoir Data from the CA Department of
Water Resources
___________________________________
5 1 5 1 E. A L M O N D W O O D D R I V E M A N T E C A, C A 95337

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T E R R A L A N D G R O U P , L L C ___________________________________ Enclosure 19
American Rivers/CDFW property easement at the Kisst Dairy property as included on the San Joaquin County Habitat Conservation and Open Space Plan (included as Agenda Item 4Q in the August 22, 2019 Joint Meeting of the Board of Directors for the San Joaquin Council of Governments and SJCOG Inc.
___________________________________
5 1 5 1 E. A L M O N D W O O D D R I V E M A N T E C A, C A 95337 August 2019
SJCOG, Inc.

STAFF REPORT
SUBJECT: American Rivers / California Department of
Fish and Wildlife Easement Holding Request
RECOMMENDED ACTION: Motion to (1) Approve the Conservation Easement Holding Request and (2) Approve
the Treasurer to Negotiate the Terms of the
Easement Holding with the Requesting Parties
DISCUSSION:

SUMMARY:

American Rivers, a nation-wide conservation entity for collaborative watershed and agricultural landscapes, is working with the California Department of Fish and Wildlife (CDFW) to acquire a habitat conservation on a property in San Joaquin County through the Wildlife Conservation Board (WCB) grant program. Because SJCOG, Inc. is the non-profit 501c3 administrators of the San Joaquin County Habitat Conservation and Open Space Plan (SJMSCP), American Rivers and CDFW approached SJCOG, Inc. staff as the best option for both agencies to serve as the holding entity for the acquired land. While the habitat land easement will not provide any mitigation credit for the SJMSCP, it would require the SJCOG, Inc. to take responsibility for accepting, monitor and reporting on the mitigation land to the parties for which it would be compensated.

RECOMMENDATION:

A motion to (1) approve the conservation easement holding request and (2) approve the SJCOG, Inc. Treasurer to negotiate the terms of the easement holding with the requesting parties.

FISCAL IMPACT:

If approved, SJCOG, Inc. will receive the easement through a recorded grant deed and will be provided an endowment for the future costs of land management, monitoring, and reporting.

SJCOG, Inc. will establish an endowment account for this preserve in the amount of roughly $90,023.00 (109.55+/- acres x $821.75 per acre for 2019 endowment amount) for these activities BACKGROUND:

The American Rivers/CDFW property easement at the Kisst Dairy Property is being purchased with grant funds in the Old River Paradise Cut area where many existing SJMSCP easement lands exist. The easement will be a Swainson’s hawk easement for active row cropland. The property is in the Central Zone along Paradise Cut and Alder Avenue as shown in attachment 1 and 2.

The grant easement purchase will have a Preserve Management Plan (PMP) recorded with the grant deed of conservation drafted by American Rivers and CDFW with input by SJCOG, Inc. staff and ICF as land managers for the SJMSCP. The PMP will follow the overall premise of existing SJMSCP management plans for the near-by preserve to allow better management and monitoring as a Row and Field Crop Preserve.

CDFW and American Rivers have drafted a Monitoring Protocol (attachment 3) for consideration by the SJCOG, Inc. Board. The final details of the agreement, compensation, and scope will be completed through negotiations before recording and accepting.

COMMITTEE ACTIONS:
 Habitat Technical Advisory Committee: Information
 SJCOG, Inc. Board – Action Required
ATTACHMENTS:

1. Overview Preserve Location Map

2. Preserve Location Map

3. Monitoring Protocol
Prepared by: Steven Mayo, Program Manager
ATTACHMENT 1
ATTACHMENT 2
This page is intentionally left blank.

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 Chris Thomas
cthomas@th
efreshwatert
rust.org
/northerndel
tagsa@gmail.
com
Northern
Delta
Susatinability
Agency/NDGS
A Associate
Member
Staten Island‐
Conservation
Farms and
Ranches
N/A
Public and Agency
Comment
Disposition/Coordi
nation
The Groundwater Sustainability Plan (“GSP”) development processcould be improved with greater integration of public comments into the GSP. Specifically, there should be a disposition processfor both oral and written comments. In addition, engagement and coordination with adjacent agencies/ subbasins should be clearly documented. The subbasin planning processes in our region will benefit from greater coordination, and doing so will be essential to completing successful GSPs.
2 pp. 2‐56 to 2‐57 2.1.10 HCM Data Gaps Basin Setting The draft GSP has significant and critical gaps in understanding of conditions, which contributes to inadequate modeling.

The data gaps identified in the draft GSP include the following:
—Water quality of principal aquifers
—Aquifer characteristics—Groundwater Level Data—Groundwater Quality Data —Subsurface ConditionsThis extensive list of missing data indicates that the technicalfundamentals of the subbasin's hydrologic and water quality are absent, that the ongoing lack of data collection and analysis is problematic, and calls into question the basis for establishingreliable and defensible thresholds.

Comment
# Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 43 Proposed
Monitoring Well
Network
Basin Setting
To rectify data gaps, a concerted program to resolve data gaps should be developed, funded and implemented. Further, these data gaps preclude the ability to track consistency with the GSP, and ultimately to ensure sustainability. furthermore, there are significant defects in the GSPs proposed monitoring approach.

Sampling frequency was reduced to 2 events a year for‘representative’ monitoring wells. This seems far too infrequent,given the DWR documented ‘critically over‐drafted’ basincondition, existing cones of depression, and the limited number of monitoring wells proposed . (Discussed at July 10, 2019 GWA Board Meeting.) DWR has identified that the well sampling frequency should be based on groundwater conditions and hydrogeologic understanding. https://water.ca.gov/‐/media/DWR‐Website/Web‐Pages/Programs/Groundwater‐ Management/Sustainable‐Groundwater‐Management/Best‐
Management‐Practices‐and‐Guidance‐Documents/Files/BMP‐2‐ Monitoring‐Networks‐and‐Identification‐of‐Data‐Gaps.pdf The draft GSP approach in number, location and frequency of sampling of wells appears to be inconsistent with the DWR BMPs.

Generally, there are too few wells, and they are spatially dispersed outside of the cone(s) of depression over a very large subbasin, and limited sampling frequency will make it difficult to track the sustainability criteria and associated thresholds, the effectiveness of the GSP, and to begin to detect impacts to Groundwater Dependent Ecosystems (GDEs).
11 h p. 2‐65 Figure 2‐37
Only one large cone of depression, an area of significantly reduced water table elevation, is identified in the GSP. This singularfeature differs from previous analyses in the Cosumnes and SouthAmerican subbasins; and, the degree of resolution of the datapresented makes it difficult to tell if there are one or more distinct cones in the central part of the subbasin, but in any case the model shows depletion along Staten Island.

Comment
# Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 5 pp. 2‐65 to 2‐66 Figure 2‐37 Figure 2‐38,
Groundwater Modeling
The model(s) appear to show groundwater elevation declines in the Delta, including Staten Island. These data need further investigation since that condition seems unlikely and not supported by DWR and other groundwater elevation analyses.

ESJ consultants were asked to explain why there were so many apparent discontinuities from the adjacent subbasin documented depressions, and the apparent errors in reporting of groundwater elevations in the Delta. For example, there are inexplicablyirregular patterns of groundwater elevations shown for the Delta.The response was that the model itself had some challenges in development and that stakeholders could ignore those results.There is apparently limited quality control in the modeling effort, and erroneous results were not identified in the draft GSP. To theextent the GSP continues to rely on this modeling, it should identify where and how the data is not considered accurate. Or, if there are significant caveats, how and where those apply. 6 Sections 3.4‐9
Groundwater
Dependent
Ecosystems and
Interconnected
Surface Waters
At the July 10, 2019 GWA Board Meeting, the consultants discussed use of The Nature Conservancy‐initiated GDEassessment approach, “somewhat,” but that in any case that theiranalysis was “consistent.” The approach to GDEs should be clearlydisclosed in the GSP. 7 Figure 3‐64 Figure 3‐65
Similarly, Interconnected Surface Waters (ISW) analysis in thedraft GSP shows portions the sloughs as being variously ‘always losing’ and ‘always gaining’ around the perimeter of Staten Island.Yet, these gaining sections (all at or below sea level) arefurther identified ‘disconnected’ from the groundwater system.

When asked about this obvious error in groundwater depletion modeling below sea level for several streams and Delta sloughs, the staff response was that it appears to be a modeling calibrationerror. It seems unlikely that these data were reviewed beforepublication. If they were reviewed, it would be expected that the text of the draft GSP would explain why it was incorrect or uncertain and how that was being resolved. This discrepancy raises concerns about the quality and the reliability of the GDEand ISW analyses.

Comment
# Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 8 Sea Water Intrusion
The draft GSP has set water quality standards for salinity intrusion that appear inconsistent with meeting environmental and agricultural beneficial uses, and protecting crops from yield losses associated with cumulative impacts of salinity.

The GSP sets the isocontour line for reporting at 500 mg/L,ostensibly “same as Secondary Maximum Contaminant Level (SMCL) for chloride.” (P. 12 July 10, 2019 GWA Board Meeting.) The Chloride SMCL set by the USEPA is 250 mg/L:https://www.epa.gov/dwregdev/drinking‐water‐regulations‐and‐ contaminants https://www.epa.gov/sites/production/files/2018‐ 03/documents/dwtable2018.pdfThe SMCL for Total Dissolved Solids (TDS) set by the USEPA is 500 mg/L: https://www.epa.gov/sites/production/files/2019‐03/documents/cfr‐2011‐title40‐vol23‐part143.pdf 9p. 3‐14 p. 3‐12
Drinking Water
Supplies and
Agricultrual Uses Not
Protected
However, the GSP set the measurable objective at 600 mg/L for TDS and the minimum threshold for TDS at 1,000 mg/L., double the SMCL. This measurable objective is above the SMCL, and themaximum threshold is not protective of drinking water supplies and agricultural uses. By the time water quality has reached the measurable objective it is unlikely to be used for potable water, and places agriculture at risk from yield losses.
10 Chloride Threshold
Too High
The subbasin’s GSP defined minimum threshold for chloride has been set at 2,000 mg/L, well above the limits for harm for manyagricultural crops. http://lawr.ucdavis.edu/cooperative‐ extension/irrigation/drought‐tips/water‐quality‐guidelines‐trees‐and‐vineshttps://catalog.extension.oregonstate.edu/sites/catalog/files/project/pdf/pnw597.pdf 11 p. 3‐12 TDS Threshold Too High
The minimum threshold is set at 1,000 mg/L for TDS, also at or above the level of impact to agricultural most agricultural crops. https://www.usbr.gov/lc/phoenix/programs/cass/pdf/Phase1/ATechapdxTDS.pdf Comment
# Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 12 The monitoring triggers in the draft GSP for chloride and TDS aretoo high to avoid undesireable effects, and do consider leaching fractions or soil salinity accumulation rates in its asumptions that further chronic reductions in crop productivity and other negative impacts would be avoided. The analysis in the draft GSP does not appear to follow a best available science (BAS) approach. Forinstance, the draft GSP fails to dislcose that the levels of TDSidentified as acceptable are associated with levels found to have a 50% yield loss of crops.
13 p. 3‐15
The trigger at 400% SMCL woudl clearly cause negative impacts todomestic well users drinking water quality. The threshold forchloride is impermissibly high and would cause degradation of existing water quality, and potentially institutionalize unsustainable and undesirable water quality.
14 p. 2‐54 Figure 2‐31 Inadequate Baseline and Monitoring The well network and associated chloride concentrations used in the analysis do not adequately represent Delta locations or thepotential for associated sea/brackish water intrusion into shallow groundwater. Significantly more wells at various depths arerequired to show current conditions, and to detect future impactswithin the Delta. 15 p. 2‐78 to 2‐79 Figure 2‐52 Figure 2‐53
Where chloride concentrations are described, there are a disproportionate amount of observations above 250 mg/L. in the Delta.If this threshold were approved it is possible that agricultural groundwater users would not be able to use this water for cropswithout reductions in productivity, and that continued irrigation with this water could reduce the ability to continue farming current crops. This standard is entirely inappropriate for drinkingwater quality. 20 p. 3‐12 Section 3.2.3.1.2
Whatever the particular standard, protection from seawaterintrusion is reliant on the ability of the subbasin to detect undesirable effects. For the entire ESJ subbasin, the draft GSP provides: “Undesirable results occur during GSP implementationwhen more than 25 percent of representative monitoring wells (3 of 10 sites) exceed the minimum thresholds for water quality fortwo consecutive years and where these concentrations are the result of groundwater management activities.”
Comment
# Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 16 Given the limited number of monitoring wells over a vast area, this standard is inadequate for the detection of a groundwaterimpact. The standard would require the source of the exceedanceto be known, and that source to be the ‘result of groundwatermanagement activities’; that there is a monitoring well in proximity, that the exceedance in detected in the twice a yearsampling; that two additional wells are located in the proximity and have similar detections with similar identified causes; and, moreover that those detections happen over two years. Those conditions are obviously unlikely to ever be met; the proposed well monitoring network appears to be so dispersed to ensure that exceedances could only be met at one well at the most. 17 Conculsion
The draft GSP is lacking in available data and an adequateproposed monitoring approach. The draft GSP should be modifiedand updated to include reasonable, scientifically supported thresholds, better track sustainability, and meet SGMA statutory requirements. The draftf GSP should also be updated to clarifywhere the data and the visualizations are not accurate and what process will be applied to improve them. The salinity and TDSlimits are not likely to meet sustainability and could allow significant degradation of water quality if applied.We look forward to working with the ESJ group to ensure acomplete GSP that meets all requriements and can be approved by DWR in the coming months.

TNC Comments
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August 24, 2019
Eastern San Joaquin Groundwater Authority
1810 E. Hazelton Avenue
P.O. Box 1810
Stockton, CA 95201
Submitted online via: http://www.esjgroundwater.org/
Re: Eastern San Joaquin Subbasin Groundwater Sustainability Plan Public Draft Dear Basin Representatives,
The Nature Conservancy (TNC) appreciates the opportunity to comment on the Eastern San Joaquin Subbasin Groundwater Sustainability Plan Public Draft prepared by the Eastern San Joaquin Groundwater Authority under the Sustainable Groundwater Management Act (SGMA) and dated July 2019. TNC provided comments on the Eastern San Joaquin Subbasin Groundwater Sustainability Plan Draft Deliverable 1, which included portions of Chapters 1, 2, 3 and 5, on May 31, 2019. For your convenience, we have included the several attachments (discussed below) to this letter that were also provided in the previous letter.

TNC as a Stakeholder Representative for the Environment TNC is a global, nonprofit organization dedicated to conserving the lands and waters on which all life depends. We seek to achieve our mission through science-based planning and implementation of conservation strategies. For decades, we have dedicated resources to establishing diverse partnerships and developing foundational science products for achieving positive outcomes for people and nature in California. TNC was part of a stakeholder group formed by the Water Foundation in early 2014 to develop recommendations for groundwater reform and actively worked to shape and pass SGMA.

Our reason for engaging is simple: California’s freshwater biodiversity is highly imperiled.

We have lost more than 90 percent of our native wetland and river habitats, leading to precipitous declines in native plants and the populations of animals that call these places home. These natural resources are intricately connected to California’s economy providing direct benefits through industries such as fisheries, timber and hunting, as well as indirect benefits such as clean water supplies. SGMA must be successful for us to achieve a sustainable future, in which people and nature can thrive within Eastern San Joaquin Groundwater Authority region and California.

We believe that the success of SGMA depends on bringing the best available science to the table, engaging all stakeholders in robust dialog, providing strong incentives for beneficial outcomes and rigorous enforcement by the State of California.

Given our mission, we are particularly concerned about the inclusion of nature, as required, in GSPs. The Nature Conservancy has developed a suite of tools based on best available science to help GSAs, consultants, and stakeholders efficiently incorporate nature into GSPs. [916] 449-2850
nature.org
GroundwaterResourceHub.org
555 Capitol Mall, Suite 1290
Sacramento, California 95814
C A L I F O R N I A W A T E R | G R O U N DW A T E R
TNC Comments
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These tools and resources are available online at GroundwaterResourceHub.org. The Nature Conservancy’s tools and resources are intended to reduce costs, shorten timelines, and increase benefits for both people and nature.

Addressing Nature’s Water Needs in GSPs
SGMA requires that all beneficial uses and users, including environmental users of groundwater, be considered in the development and implementation of GSPs (Water Code § 10723.2).

The GSP Regulations include specific requirements to identify and consider groundwater dependent ecosystems (23 CCR §354.16(g)) when determining whether groundwater conditions are having potential effects on beneficial uses and users. GSAs must also assess whether sustainable management criteria may cause adverse impacts to beneficial uses, which include environmental uses, such as plants and animals. In addition, monitoring networks should be designed to detect potential adverse impacts to beneficial uses due to groundwater. Adaptive management is embedded within SGMA and provides a process to work toward sustainability over time by beginning with the best available information to make initial decisions, monitoring the results of those decision, and using data collected through monitoring to revise decisions in the future. Over time, GSPs should improve as data gaps are reduced and uncertainties addressed.

To help ensure that GSPs adequately address nature as required under SGMA, The Nature Conservancy has prepared a checklist (Attachment A) for GSAs and their consultants to use.

The attached version of this checklist was revised in July 2019. The Nature Conservancy believes the following elements are foundational for 2020 GSP submittals. For detailed guidance on how to address the checklist items, please also see our publication, GDEs under SGMA: Guidance for Preparing GSPs1.

1. Environmental Representation
SGMA requires that groundwater sustainability agencies (GSAs) consider the interests of all beneficial uses and users of groundwater. To meet this requirement, we recommend actively engaging environmental stakeholders by including environmental representation on the GSA board, technical advisory group, and/or working groups. This could include local staff from state and federal resource agencies, nonprofit organizations and other environmental interests. By engaging these stakeholders, GSAs will benefit from access to additional data and resources, as well as a more robust and inclusive GSP.

2. Basin GDE and ISW Maps
SGMA requires that groundwater dependent ecosystems (GDEs) and interconnected surface waters (ISWs) be identified in the GSP. We recommend using the Natural Communities Commonly Associated with Groundwater Dataset (NC Dataset) provided online 2 by the Department of Water Resources (DWR) as a starting point for the GDE map. The NC Dataset was developed through a collaboration between DWR, the Department of Fish and Wildlife and TNC.

1 GDEs under SGMA: Guidance for Preparing GSPs is available at:
https://groundwaterresourcehub.org/public/uploads/pdfs/GWR_Hub_GDE_Guidance_Doc_2-1-18.pdf 2 The Department of Water Resoruces’ Natural Communities Commonly Associated with Groundwater dataset is available at: https://gis.water.ca.gov/app/NCDatasetViewer/ TNC Comments
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3. Potential Effects on Environmental Beneficial Users
SGMA requires that potential effects on GDEs and environmental surface water users be described when defining undesirable results. In addition to identifying GDEs in the basin, The Nature Conservancy recommends identifying beneficial users of surface water, which include environmental users. This is a critical step, as it is impossible to define “significant and unreasonable adverse impacts” without knowing what is being impacted. Since the Public Draft GSP includes the Freshwater Species List for the Subbasin provided in our earlier comment letter as Appendix 1-F of the Public Draft, we did not include it as an attachment to this letter. We recommend that after identifying which freshwater species exist in your basin, especially federal and state-listed species, that you contact staff at the California Department of Fish and Wildlife (CDFW), United States Fish and Wildlife Service (USFWS) and/or National Marine Fisheries Services (NMFS) to obtain their input on the groundwater and surface water needs of the organisms on the GSA’s freshwater species list. Because effects to plants and animals are difficult and sometimes impossible to reverse, we recommend erring on the side of caution to preserve sufficient groundwater conditions to sustain GDEs and ISWs.

4. Biological and Hydrological Monitoring
If sufficient hydrological and biological data in and around GDEs is not available in time for the 2020/2022 plan, data gaps should be identified along with actions to reconcile the gaps in the monitoring network.

The Nature Conservancy has thoroughly reviewed the Eastern San Joaquin Subbasin Draft GSP. We appreciate the work that has gone into the preparation of this plan. However, we consider it to be inadequate under SGMA because the basis for removing the majority of the potential GDEs identified in the NC Dataset from further consideration and management as GDEs is not scientifically supported, and could lead to significant and unreasonable impacts. Based on the available data, the removed polygons should be retained and managed as potential GDEs in the plan. If further analysis were to provide substantial evidence that groundwater level declines would not result in an adverse impact to the species in these ecosystems, then consideration could be given to removing them at that time; however, no such evidence has been presented in the draft GSP.

Our specific comments related to the Eastern San Joaquin Subbasin Groundwater Sustainability Plan, Draft Deliverable 1 of the Draft GSP are provided in detail in Attachment B and are in reference to the numbered items in the revised checklist in Attachment A.

Attachment C describes six best practices that GSAs and their consultants can apply when using local groundwater data to confirm a connection to groundwater for DWR’s Natural Communities Commonly Associated with Groundwater Dataset2. Attachment D provides an overview of a new, free online tool that allows GSAs to assess changes in groundwaterdependent ecosystem (GDE) health using satellite, rainfall, and groundwater data.

Thank you for fully considering our comments as you develop your GSP.

Best Regards,
Sandi Matsumoto
Associate Director, California Water Program
The Nature Conservancy
TNC Comments
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Attachment A
Considering Nature under SGMA: A Checklist
The Nature Conservancy is neither dispensing legal advice nor warranting any outcome that could result from the use of this checklist. Following this checklist does not guarantee approval of a GSP or compliance with SGMA, both of which will be determined by DWR and the State Water Resources Control Board.

Environmental User Checklist
The Nature Conservancy is neither dispensing legal advice nor warranting any outcome that could result from the use of this checklist. Following this checklist does not guarantee approval of a GSP or compliance with SGMA, both of which will be determined by DWR and the State Water Resources Control Board.

GSP Plan Element* GDE Inclusion in GSPs: Identification and Consideration Elements Check Box Admin Info

2.1.5 Notice &
Communication
23 CCR §354.10
Description of the types of environmental beneficial uses of groundwater that exist within GDEs and a description of how environmental stakeholders were engaged throughout the development of the GSP. 1 Planning
Framework

2.1.2 to 2.1.4
Description of
Plan Area
23 CCR §354.8
Description of jurisdictional boundaries, existing land use designations, water use management and monitoring programs; general plans and other land use plans relevant to GDEs and their relationship to the GSP. 2 Description of instream flow requirements, threatened and endangered species habitat, critical habitat, and protected areas. 3
Summary of process for permitting new or replacement wells for the basin, and how the process incorporates any protection of GDEs 4
Basin Setting

2.2.1 Hydrogeologic
Conceptual
Model
23 CCR §354.14
Basin Bottom Boundary:

Is the bottom of the basin defined as at least as deep as the deepest groundwater extractions? 5 Principal aquifers and aquitards:

Are shallow aquifers adequately described, so that interconnections with surface water and vertical groundwater gradients with other aquifers can be characterized?
6 Basin cross sections:

Do cross-sections illustrate the relationships between GDEs, surface waters and principal aquifers? 7

2.2.2 Interconnected surface waters: 8
TNC Comments
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Current &
Historical
Groundwater
Conditions
23 CCR §354.16
Interconnected surface water maps for the basin with gaining and losing reaches defined (included as a figure in GSP & submitted as a shapefile on SGMA portal). 9
Estimates of current and historical surface water depletions for interconnected surface waters quantified and described by reach, season, and water year type. 10
Basin GDE map included (as figure in text & submitted as a shapefile on SGMA Portal). 11 If NC Dataset was used:

Basin GDE map denotes which polygons were kept, removed, and added from NC Dataset (Worksheet 1, can be attached in GSP section 6.0). 12
The basin’s GDE shapefile, which is submitted via the SGMA Portal, includes two new fields in its attribute table denoting: 1) which polygons were kept/removed/added, and 2) the change reason (e.g., why polygons were removed).
13 GDEs polygons are consolidated into larger units and named for easier identification throughout GSP. 14
If NC Dataset was not used: Description of why NC dataset was not used, and how an alternative dataset and/or mapping approach used is best available information. 15
Description of GDEs included: 16
Historical and current groundwater conditions and variability are described in each GDE unit. 17 Historical and current ecological conditions and variability are described in each GDE unit. 18 Each GDE unit has been characterized as having high, moderate, or low ecological value. 19 Inventory of species, habitats, and protected lands for each GDE unit with ecological importance (Worksheet 2, can be attached in GSP section 6.0). 20

2.2.3 Water Budget
23 CCR §354.18
Groundwater inputs and outputs (e.g., evapotranspiration) of native vegetation and managed wetlands are included in the basin’s historical and current water budget. 21
Potential impacts to groundwater conditions due to land use changes, climate change, and population growth to GDEs and aquatic ecosystems are considered in the projected water budget. 22 Sustainable Management
Criteria

3.1 Sustainability
Goal
23 CCR §354.24
Environmental stakeholders/representatives were consulted. 23 Sustainability goal mentions GDEs or species and habitats that are of particular concern or interest. 24 Sustainability goal mentions whether the intention is to address pre-SGMA impacts, maintain or improve conditions within GDEs or species and habitats that are of particular concern or interest. 25

3.2 Measurable
Objectives
23 CCR §354.30
Description of how GDEs were considered and whether the measurable objectives and interim milestones will help achieve the sustainability goal as it pertains to the environment. 26

3.3 Minimum
Thresholds
23 CCR §354.28
Description of how GDEs and environmental uses of surface water were considered when setting minimum thresholds for relevant sustainability indicators: 27
Will adverse impacts to GDEs and/or aquatic ecosystems dependent on interconnected surface waters (beneficial user of surface water) be avoided with the selected minimum thresholds? 28 TNC Comments
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Are there any differences between the selected minimum threshold and state, federal, or local standards relevant to the species or habitats residing in GDEs or aquatic ecosystems dependent on interconnected surface waters? 29

3.4 Undesirable
Results
23 CCR §354.26
For GDEs, hydrological data are compiled and synthesized for each GDE unit: 30 If hydrological data are available
within/nearby the GDE
Hydrological datasets are plotted and provided for each GDE unit (Worksheet 3, can be attached in GSP Section 6.0). 31
Baseline period in the hydrologic data is defined. 32
GDE unit is classified as having high, moderate, or low susceptibility to changes in groundwater. 33
Cause-and-effect relationships between groundwater changes and GDEs are explored. 34 If hydrological data are not available
within/nearby the GDE
Data gaps/insufficiencies are described. 35
Plans to reconcile data gaps in the monitoring network are stated. 36 For GDEs, biological data are compiled and synthesized for each GDE unit: 37 Biological datasets are plotted and provided for each GDE unit, and when possible provide baseline conditions for assessment of trends and variability. 38
Data gaps/insufficiencies are described. 39
Plans to reconcile data gaps in the monitoring network are stated. 40 Description of potential effects on GDEs, land uses and property interests: 41 Cause-and-effect relationships between GDE and groundwater conditions are described. 42 Impacts to GDEs that are considered to be “significant and unreasonable” are described. 43 Known hydrological thresholds or triggers (e.g., instream flow criteria, groundwater depths, water quality parameters) for significant impacts to relevant species or ecological communities are reported. 44 Land uses include and consider recreational uses (e.g., fishing/hunting, hiking, boating). 45 Property interests include and consider privately and publicly protected conservation lands and opens spaces, including wildlife refuges, parks, and natural preserves. 46
Sustainable
Management
Criteria

3.5 Monitoring
Network
23 CCR §354.34
Description of whether hydrological data are spatially and temporally sufficient to monitor groundwater conditions for each GDE unit. 47
Description of how hydrological data gaps and insufficiencies will be reconciled in the monitoring network. 48 Description of how impacts to GDEs and environmental surface water users, as detected by biological responses, will be monitored and which GDE monitoring methods will be used in conjunction with hydrologic data to evaluate cause-and-effect relationships with groundwater conditions.
49 TNC Comments
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Projects &
Mgmt
Actions

4.0. Projects &
Mgmt Actions to
Achieve
Sustainability
Goal
23 CCR §354.44
Description of how GDEs will benefit from relevant project or management actions. 50 Description of how projects and management actions will be evaluated to assess whether adverse impacts to the GDE will be mitigated or prevented. 51
* In reference to DWR’s GSP annotated outline guidance document, available at:
https://water.ca.gov/LegacyFiles/groundwater/sgm/pdfs/GD_GSP_Outline_Final_2016-12-23.pdf TNC Comments
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Attachment B
TNC Evaluation of the
Eastern San Joaquin Subbasin Groundwater Sustainability Plan, Public Draft Complete Executive Summary and Main Report
A complete draft of the Eastern San Joaquin GSP has been provided for public review. On May 31, 2019, TNC provided comments on the Eastern San Joaquin Subbasin GSP Draft Deliverable 1, which included portions of Chapters 1, 2, 3 and 5. This attachment summarizes our comments on the complete public draft GSP dated July 2019, and includes any initial review comments from our May 31, 2019 that have not yet been addressed.

Since the GSP does not follow the DWR Annotated GSP Outline, we have organized our comments below in accordance with the item numbers in the checklist included as Attachment A.

Checklist Item 1 – Notice & Communication (23 CCR §354.10). • [Section 1.3.1 Beneficial Uses and Users in the Subbasin (pp. 1-40)] [Checklist item 1]
o Caswell Memorial State Park is incorrectly referred to as being located outside the Eastern San Joaquin Subbasin. The following additional protected lands are located near surface waters within the Subbasin that may be interconnected with groundwater, and/or may rely at least partly on groundwater to support vegetation and sensitive natural communities. These protected lands represent potential beneficial users of groundwater: Durham Ferry State Recreational Area, a small portion (approximately 200 acres) of San Joaquin River National Wildlife Refuge, Army Corps Park, Vernalis Riparian Habitat (Public Conservation Lands), Seegers Preserve, Cabral Island Preserve, Machado Preserve, Hansen Preserve, Micke Grove Park and Zoo, Oak Grove Regional Park, Nakagawa Preserve, El Rio Farms Preserve, Lodi Lake Nature Area, Woodbridge Regional Park, Woodbridge Ecological Preserve, White Slough WA, Nuss Farms, Beck Preserve, Hilder Preserve, Staten Island Ranch, Burchel Preserve, and Ishizuka Preserve. The authors referred to the San Joaquin County General Plan documents, including background reports, for information regarding these important resources.

These potential beneficial groundwater users should be described in the text on pp. 1-18 and shown in Figure 1-11. Please include a description recognizing all of the protected areas in the Subbasin and their beneficial groundwater uses.
o Section 2.2.8 includes a geospatial analysis that removes managed wetlands from consideration as GDEs. The managed wetlands in the Subbasin should be identified in this section.

Checklist Item 2 to 4 - Description of general plans and other land use plans relevant to GDEs and their relationship to the GSP (23 CCR §354.8).

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• [Section 1.2.1 Description of Plan Area (1-10 to 1-21)] Critical habitat is known to exist for protected aquatic species, such as California Tiger Salamander, Steelhead, Delta Smelt, Giant Gartersnake and California Red-Legged Frog in and around the Subbasin
(https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4 fe09893cf75b8dbfb77). There are likely ongoing monitoring programs associated with critical habitat areas and the protected lands. Please include a description of these habitat areas, and associated programs and requirements pertinent to ISWs, GDEs and wetlands. Identify areas where critical habitat exists and overlaps with ISWs and GDEs.
• [Section 1.2.2 Water Resources Monitoring and Management Programs (pp. 1-21 to 1-32)] Per the GSP Regulations (23 CCR §354.34 (a) and (b)), monitoring must address trends in groundwater and related surface conditions (emphasis added). In order for this section to provide the appropriate context and help assure integration of GSP implementation with other ongoing regulatory programs, this section should describe the following:
o Monitoring activities and responsibilities by State, Federal and local agencies and jurisdictions related to aquatic resources and GDEs that could be affected by groundwater withdrawals should be discussed. Section 1.2.2.6 states that there are no agencies that do monitoring specific to surface-groundwater interconnection. While this may be technically correct insofar as it relates to hydrogeologic monitoring, it ignores ongoing monitoring programs related to the state of aquatic resources and GDEs that could be affected by groundwater withdrawals, and that are a direct indicator of potential undesirable results. For example, there are likely ongoing monitoring programs associated with the protected lands listed in our comments to Section 1.3.1, and other open space or preserve areas that may be monitored by public, private or nonprofit entities. A discussion of monitoring programs related to GDEs and ISWs should be included.
o The lack of existing hydrologic monitoring of surface-groundwater interconnection is a significant data gap as it relates to classification and management of GDEs and should be identified as such and further discussed and addressed in the appropriate subsequent sections of the GSP. o Monitoring activities and responsibilities related to instream flow and water quality requirements under applicable Federal Energy Regulatory Commission licenses, Biological Opinions and other regulations or programs are relevant and should be identified. Please include a discussion of water flow and quality monitoring requirements pertinent to ISWs.
• [Section 1.2.3 Land Use Elements or Topic Categories of Applicable General Plans (pp. 1-33 to 1-36 and Appendix 1-E)]
o This section should include a discussion of General Plan goals and policies related to the protection and management of GDEs and aquatic resources that could be affected by groundwater withdrawals, rather than being limited to goals and policies directly related to groundwater resources alone. Section TNC Comments
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Checklist Items 6 and 7 – Hydrogeologic Conceptual Model (23 CCR §354.14) • [Section 2.1.7 Geologic Cross Sections (pp. 2-35 to 2-37)] Please clearly state whether localized perched aquifers are present in the basin. Include example near-surface cross section details that depict the conceptual understanding of shallow groundwater and stream interactions at different locations, including perched and regional aquifers.
• [Section 2.1.8.2 Definable Bottom of the Basin (p. 2-39)] The Bottom of the Basin Boundary was defined by the base of freshwater, which was mapped 45 years ago and pumping since then has very likely resulted in shift in the isohaline contouring in the basin. Defining the bottom of the Subbasin based on geochemical properties is a suitable approach for defining the base of freshwater, however, as noted on page 9 of DWR's Hydrogeologic Conceptual Model BMP
(https://water.ca.gov/LegacyFiles/groundwater/sgm/pdfs/BMP_HCM_Final_2016-12-

23.pdf) "the definable bottom of the basin should be at least as deep as the deepest groundwater extractions". Thus, groundwater extraction well depth data should also be included in the determination of the basin bottom. This will TNC Comments
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prevent the possibility of extractors with wells deeper than the basin boundary from claiming exemption of SGMA due to their well residing outside the vertical extent of the basin boundary. Also, pumping saline groundwater and desalinating it will become increasingly economical under SGMA due to pumping restrictions in the basin.
• [Section 2.1.10 HCM Data Gaps (pp. 2-56 and 2-57)] The Hydrologic Conceptual Model identified several data gaps including the following for groundwater level data:
o Depth- or zone-specific water levels to assess vertical interconnection, including zones within the Principal Aquifer. Nested monitoring wells would be helpful near surface water to show how pumping is impacting surface water flows and GDEs.
o Additional shallow groundwater data near surface waters and NCCAGs. o Additional groundwater level data in the east and northwest areas of the Subbasin.
o Additional groundwater level data near the Mokelumne River to improve quantification and understanding of subsurface flows.

Of these, the second data gap is the information that is most critical to identifying GDEs or potential GDEs and understanding their characteristics.

Checklist Items 8, 9 and 10 – Interconnected Surface Waters (23 CCR §354.16) • [Section 2.1.4.2 Major Hydraulic Features (pp. 2-9 to 2-14)] This section should discuss (or reference the sections discussing) the following:
o Specific ISWs, including the extent of both gaining and losing reaches. o In-stream flow requirements in each of the interconnected rivers/streams including the amount, time of year when the flow minimum is specified, the duration, the freshwater fish species for which it applies, associated permits that set forth the requirements, and the regulating agency setting forth the compliance requirements.
o Areas of critical habitat that exist within rivers and streams. • [Section 2.1.5 Geologic Formations and Stratigraphy (pp. 2-23 to 2-27)] Table 2-2 states that Holocene Stream Channel Deposits are generally not saturated except by the San Joaquin River. Based on the available data, it would be expected that the stream channel deposits associated with the other ISWs in the Subbasin would be saturated near those streams and rivers.
• [Section 2.1.9.2.2 Regional Historic Groundwater Flow and Surface Water Interaction (p. 2-49)] This section focuses on groundwater flow direction and defers further discussion of groundwater conditions to Section 2.2, which does not provide information on historical groundwater-surface water interaction. This section should include a discussion of historic groundwater-surface water interaction.
• Section 2.2.6 Interconnected Surface Water Systems (pp. 2-97 to 2-99)] o The determination as to whether or not a stream reach is interconnected or disconnected was made based on whether modeling conducted for the GSP TNC Comments
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indicated that it is interconnected more than 25 percent of the time. Even if the stream is only connected 25% of the time, it is still connected, and that short period of connectivity may be during critical times for select species or provide a cooling or biogeochemical effect during a critical period. Please describe the technical basis for selecting a 25 percent interconnection threshold, and how it will adequately protect the environmental beneficial uses of surface water in potentially interconnected surface waters from significant and unreasonable impacts related to groundwater extraction.
o Shallow groundwater monitoring data near surface waters and NCCAGs are identified as a data gap in Section 2.1.10, and the use of the Eastern San Joaquin Water Resources Model (ESJWRM) to determine the percentage of time that stream reaches are groundwater connected entails inherent uncertainty. The potential presence of shallow or perched aquifers near the rivers is not assessed or discussed in the GSP. Groundwater modeling conducted by the United States Geological Survey (USGS), DWR and others (e.g., JJ&A, 2018) has considered some river reaches shown as disconnected in Figure 2-66 (pp. 2-99) to be groundwater-connected. No data or discussion is presented regarding the potential groundwater connection of other streams associated with significant wetland and riparian resources, including Pixley Slough, Mormon Slough, Littlejohns Creek, Bear Creek, Potter Creek, Duck Creek and Lone Tree Creek. As such, there is considerable uncertainty regarding the designation of interconnected and disconnected surface water resources in Figure 2-66. The uncertainty regarding the groundwater interconnection of streams in the Subbasin should be identified as a data gap.

Checklist Items 11 through 20 – Groundwater Dependent Ecosystems (23 CCR §354.16) • [Section 2.2.7 Groundwater-Dependent Ecosystems (p. 2-100)] This section includes the incorrect statement that SGMA does not require sustainable management criteria to be established for the management of GDEs. Section 1.3.1 of the GSP states that beneficial users of groundwater and ISWs include “environmental users of groundwater, including species and habitat reliant on instream flows, as well as wetlands and GDEs.” Undesirable results under SGMA include chronic lowering of groundwater levels resulting in significant and unreasonable depletion of supply for beneficial groundwater users, including GDEs. Undesirable results also include depletion of ISWs resulting in significant and unreasonable adverse impacts on beneficial users of surface water, including wetlands and GDEs. The incorrect statement that SGMA does not require the establishment of sustainable management criteria for GDEs should be removed.
• [Section 2.2.8 Methodology for GDE Identification (p. 2-100 to 2-106)] The GSP relies on the NCCAG database developed by TNC for the DWR to identify potential GDEs, and then provides a framework for removing most of these areas from further consideration. It appears that the preliminary desktop analysis documented in the draft GSP resulted an excessive elimination of the NC dataset TNC Comments
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polygons mapped in the Eastern San Joaquin Subbasin. In particular, the methods used to confirm whether or not polygons in the NC Dataset are connected to groundwater in the Eastern San Joaquin Subbasin are highly flawed. We have the following comments on the proposed approach:
o The GSP takes the approach of removing NCCAGs with “access to alternate water supplies” from consideration as GDEs, and states that in order to be considered GDEs, “there must not be alternate water supplies”. Alternate water supplies are assumed to include potential sources of surface water including managed wetlands, irrigated agricultural fields, perennial surface water sources, and other unspecified sources determined by stakeholders on a case-specific basis. This approach is inappropriate and deficient for several important reasons:
▪ There is no hydrologic analysis or empirical data provided as a basis for the proposed buffer zones. The hydrologic connectivity between a GDE and a nearby alternative water source is highly dependent on local conditions and can vary seasonally and by year type. In the case of managed wetlands, no consideration is given to the nature of the wetland and surrounding area, the source and frequency of inundation, the soil types, and other features that would be needed to understand the hydrologic connectivity between the wetland and the surrounding area, or even whether the wetland itself it groundwater dependent for a portion of the year. Similarly, no information is given to the topography and hydrology surrounding irrigated agricultural fields, the soil types involved, irrigation practices, whether irrigation is likely to be curtailed during dry years or during certain crop rotations, and other relevant factors. The hydrologic connectivity of perennial surface water sources cannot be assessed without specific knowledge of the water source, topography and soil conditions. In summary, the adequacy of generic buffer zones to assure GDE access to surface water is unsubstantiated.
▪ No information is provided regarding the species residing in the GDEs, their sensitivity to groundwater level declines, or the extent of their reliance on groundwater vs. the proposed “alternate water supplies.” ▪ There is no evidence of consultation with the regulatory agencies responsible for the protection and management of these resources in the establishment of the proposed framework. It does not appear that any habitat assessments have been conducted.
▪ Ecosystems often rely both on groundwater and surface water to meet their water needs (see Best Management Practice #3 in Attachment C of this letter). The availability of “alternate water supplies” to provide some portion of a GDE’s water demand does not mean all of its water needs can be met through alternate supplies (i.e., without reliance on groundwater).
▪ Groundwater pumping depletes ISWs under both gaining or losing conditions, and GDEs may rely on the interactions of surface water to meet their water requirements.

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Simply put, the approach proposes to manage GDEs without consideration to understanding the nature and needs of the resource being managed. A strictly binary approach, designating all NCCAGs as either 100 percent reliant on groundwater or 100 percent reliant on alternate water supplies is inconsistent with the available science and is not supportable. A scientific rationale for removing areas with access to assumed alternate water sources has not been provided. The deleted potential GDEs should be retained in the GSP and managed as potential GDEs. If further study and consultation with the appropriate regulatory agencies indicates that some areas would not be affected by groundwater withdrawals, consideration could be given to removing them at that time. o We have the following additional comments regarding the potential use of buffer zones to exclude NC-Dataset polygons from further consideration as GDEs:
▪ In the case of managed wetlands, the water sources used by the managed wetlands, the type of managed wetlands, the relationship of the wetlands to groundwater, and the wetland manager should be specified. In addition, these managed wetlands should be identified in Section 1.3.1.
▪ Please refer to Attachment C of this letter for best practices in using groundwater data to verify whether NCCAGs are GDEs. The GSP identifies monitoring data for shallow groundwater near ISWs as a data gap. Please discuss what temporal and spatial data were used to identify “shallow groundwater,” and identify any data gaps.
▪ A scientifically defensible rationale and data for applying the proposed buffer zones used to remove NCCAGs areas proximal to alternate water sources from consideration as GDEs has not been provided. In the absence of specific information regarding groundwater levels near these features, which is identified as a data gap in the GSP, it is possible that they are connected to a shallow groundwater table, at least seasonally. This is true of both gaining and losing reaches. Such a connection means they meet the definition of a GDE, regardless of whether the groundwater is replenished by a surface water source (see Best Management Practice #3 in Attachment C of this letter). In addition, the extent of groundwater reliance, and the ability of species to adapt to seasonal and long-term changes in hydrologic conditions, varies from species to species. We acknowledge that proximity to surface water sources and establishment of buffer zones may be an important consideration in GDE management; however, groundwater extraction can still result in drawdown near these areas, especially at the outer fringes of GDEs that are more vulnerable to drawdown.

Buffer zones, if used, must be supported by actual hydrologic and habitat assessment data. If such data and assessments are not available, the areas should not be deleted from consideration and management as GDEs. The need for
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supporting studies to validate the approach may be identified as a data gap and undertaken in the future.
▪ The “stakeholder feedback” mechanism for removal of NCCAGs from consideration as GDEs is not explained or documented in the GSP.

Please provide details that support removing potential GDEs based on stakeholder feedback. Stakeholder feedback, in the absence of scientifically supportable data and/or agency consultation, may be insufficient to exclude areas from consideration as GDEs.
▪
o We have the following comments about the proposed use of a 30-foot depth to water criterion to exclude NC-Dataset polygons from further consideration as GDEs:
▪ SGMA defines GDEs as "ecological communities and species that depend on groundwater emerging from aquifers or on groundwater occurring near the ground surface". We recommend that depth to
groundwater contour maps are used, where they can be reliably substantiated, to verify whether a connection to groundwater exists for polygons in the NC Dataset. This is preferable to relying on inferences based on the presence of surface water features in the Basin. However, it is important to note that where depth to water is uncertain in proximity to streams, a depth to water criterion for assessing which polygons are GDEs is inappropriate. Please refer to Appendix C of this letter for best practices for using groundwater data to verify a connection to groundwater.
▪ Please provide more details on how depth to groundwater contour maps were developed:
• Are the wells used for interpolating depth to groundwater sufficiently close (<5km) to NC Dataset polygons to reflect local conditions relevant to ecosystems?
• Are the wells used for interpolating depth to groundwater screened within the surficial unconfined aquifer and capable of measuring the true water table?
• Is depth to groundwater contoured using groundwater elevations at monitoring wells to get groundwater elevation contours across the landscape? This layer can then be subtracted from land surface elevations from a Digital Elevation Model (DEM) 3to estimate depth-to-groundwater contours across the landscape.

This will provide much more accurate contours of depth-togroundwater along streams and other land surface depressions where GDEs are commonly found. Depth to groundwater
contours developed from depth to groundwater measurements

3 USGS Digital Elevation Model data products are described at: https://www.usgs.gov/core-sciencesystems/ngp/3dep/about-3dep-products-services and can be downloaded at: https://iewer.nationalmap.gov/basic/ TNC Comments
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at wells assumes that the land surface is constant, which is a poor assumption to make. It is better to assume that water surface elevations are constant in between wells, and then calculate depth to groundwater using a DEM of the land surface to contour depth to groundwater.
▪ The 30-foot depth to water criterion used to exclude riparian areas near streams east of the San Joaquin River from further consideration as GDEs is very broadly applied and poorly supported. Based on our understanding of the regional hydrogeology, we would expect riparian vegetation and wetlands near the major surface drainages to be connected to water tables associated with the regional aquifer system from a point where the streams exit the foothill uplands westward, except in areas of significant, pumping-induced drawdown. Shallow groundwater data near streams are identified as a significant data gap, and the available groundwater level data come from wells screened at a variety of depths. The application of a 30-foot depth to water criterion is inadequately supported in light of the identified data gaps, and should not be used exclude potential GDEs from further consideration without additional study.
▪ While depth to groundwater levels within 30 feet are generally accepted as being a proxy for confirming that polygons in the NC dataset are connected to groundwater, the variable needs of plant species and their dependence on seasonal and inter-annual groundwater level fluctuations should be considered when applying this criterion. The GSP cites a maximum rooting depth of 25 feet for oak trees as a basis for the 30-foot criterion, yet studies have found the roots of oaks can extend deeper than 70 feet to extract water from the capillary fringe immediately above the water table during the summer and fall, and that groundwater reserves provide a buffer to rapid changes in their hydroclimate, as long as groundwater reserves are not depleted by drought or human consumption.4 It is highly advised that seasonal and interannual fluctuations in the groundwater regime are taken into consideration. Utilizing groundwater data from one point in time or contoured with too few shallow monitoring wells can misrepresent groundwater levels required by GDEs, and inadvertently result in adverse impacts to the GDEs. Based on a study we recently submitted to Frontiers in Environmental Science Journal, we've observed riparian forests along the Cosumnes River to experience a range in groundwater levels between 1.5 and 75 feet over seasonal and interannual timescales. Seasonal fluctuations in the regional water table can support perched groundwater near an intermittent river that seasonally runs dry due to large seasonal fluctuations in the regional water table. While perched groundwater itself cannot directly be

4 Miller and others. 2009. Groundwater Uptake by Woody Vegetation in a Semi-Arid Oak Savannah. Water Resources Research. Volume 46. November.

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managed due to its position in the vadose zone, the water table position within the regional aquifer (via pumping rate restrictions, restricted pumping at certain depths, restricted pumping around GDEs, well density rules) and its interactions with surface water (e.g., timing and duration) can be managed to prevent adverse impacts to ecosystems due to changes in groundwater quality and quantity under SGMA.
• Very little description is provided regarding the nature and function of the identified GDEs, their potential sensitivity to groundwater and surface water supply changes, their relative habitat value, or the current and historical groundwater conditions and variability near the GDEs. Given that monitoring of groundwater levels near ISWs has been identified as a data gap and limited resources are available to expand monitoring efforts in these areas, additional assessment would be helpful to identify and prioritize potential data gaps. We recommend that a discussion regarding the nature and characteristics of the identified GDEs be included.

Checklist Items 21 and 22 – Water Budget (23 CCR §354.18) • [Section 2.3.5 Water Budget Estimates (pp. 2-115 to 2-133)] The following items related to GDEs, wetlands and riparian areas should be clarified or considered:
o “Riparian intake from streams” is identified as a stream system water budget component and is defined as the portion of riparian evapotranspiration (ET) met by streamflows. Please include an explanation of the approach to determining the amount of riparian ET demand met by streamflow vs. groundwater evapotranspiration.
o Groundwater outflow to ET does not appear to be identified as a groundwater budget component (for example see Figure 2-74, p. 2-125). In addition, the ET demand of natural vegetation does not appear to be considered in water supply and demand calculations (for example see Table 2-16, p. 2-126).

Since GDEs (including wetlands,riparian vegetation, phreatophytes and other communities) are recognized as beneficial users of groundwater in the Subbasin, it is appropriate to include them in these calculations.

Checklist Items 23 and 25 – Sustainability Goal (23 CCR §354.24) • [Section 3.1 Sustainability Goal (p. 3-1)] The Sustainability Goal is defined as being “ … to maintain an economically-viable groundwater resource for the beneficial use of the people of the Eastern San Joaquin Subbasin … .” Since GDEs, are recognized as beneficial users of groundwater in the Subbasin, they should be mentioned in the Sustainability Goal.

Checklist Item 26 – Measurable Objectives (23 CCR §354.30) and Checklist Items 30 to 33 – Undesirable Results (23 CCR §354.26)
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• [Section 3.2.1.1.1 Description of Undesirable Results (for chronic lowering of groundwater levels (p. 3-3)] This section only describes undesirable results relating to human beneficial uses of groundwater and neglects environmental beneficial uses that could be adversely affected by chronic groundwater level decline. On page 3-5 in Section 3.2.1.2, impacts to GDEs are correctly identified as an undesirable result potentially associated with chronic groundwater level decline. Please add “potential adverse impacts to GDEs” to the list of potential undesirable results presented in Section 3.2.1.1.1.
• [Section 3.2.3.1.1 Description of Undesirable Results (for degraded water quality (p. 3-11)] This section only describes undesirable results in terms of total dissolved solids concentrations and related impacts. The section should be modified to state that overpumping and dewatering of aquitards has been identified as a potential source of elevated arsenic concentrations above drinking water standards in San Joaquin Valley aquifers. The following is a link to a paper by Smith, Knight and Fendorf (2018) titled “Overpumping leads to California groundwater arsenic threat”: (https://www.nature.com/articles/s41467-018-04475- 3).
• [Section 3.2.6.1.1 Description of Undesirable Results (for ISWs (p. 3-11)] This section states that undesirable results related to surface water depletion were defined and evaluated only for major streams and rivers including the Calaveras River, Dry Creek, Mokelumne River, San Joaquin River, and Stanislaus River. The section goes on to state that many of the smaller creeks and streams are solely used for the conveyance of irrigation water and these systems have not been considered in the analysis of depletions. Contrary to these statements, surface water resources in these creeks support significant recognized aquatic habitat, wetlands and riparian zones that represent potential environmental beneficial uses and users of groundwater. A number of these streams are associated with designated protected lands. The analysis for potential depletion of ISWs in Section 3.2.6 should include all beneficial users of surface water that could be affected by groundwater withdrawals, including environmental beneficial users along creeks, even if the creeks are interconnected less than 75% of the time. • [Section 3.2.6.1.2 Identification of Undesirable Results (for ISWs (p. 3-12)] The section states that “undesirable results would occur if groundwater extractions depleted interconnected streams and there was not sufficient surface water to supply … fish and wildlife demands.” This definition of undesirable results is overly narrow and recognizes only a limited subset of the environmental beneficial users of ISWs.

A more complete definition would be that undesirable results would occur if groundwater extraction resulted in a depletion of surface water that caused significant impacts to aquatic species or wildlife, or degradation of GDEs. Please expand the definition of undesirable results to include all of the environmental beneficial uses and users of ISWs, and expand the analysis in Section 3.2.6, as appropriate.
• [Section 3.2.6.1.3 Potential Effects of Undesirable Results (for ISWs (p. 3-12)] The potential effects of undesirable results on environmental beneficial users are not described. Please expand the section to describe the potential effects of TNC Comments
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undesirable results on all beneficial uses and users of ISWs, including environmental uses and users.
• The GDE Pulse web application developed by The Nature Conservancy provides easy access to 35 years of satellite data to view trends of vegetation metrics, groundwater depth (where available), and precipitation data. This satellite imagery can be used to observe trends for NC dataset polygons within the Subbasin. Over the past 10 years (2009-2018), some NC dataset vegetation polygons have experienced adverse impacts to vegetation growth and moisture in the western portion of the Subbasin.

An example screen shot from the GDE Pulse tool is presented below. Please review these spatial patterns and, where possible, correlate them with water level trends. Any indications of adverse trends and any data gaps should be identified.
•
Checklist Items 27 to 29 – Minimum Thresholds (23 CCR §354.28). • [Section 3.2.6.2 Minimum Thresholds (for ISWs (pp. 3-19 and 3-20)] The GSP proposes to use the Minimum Thresholds and Measurable Objectives associated with Chronic Decline in Groundwater Levels as a proxy for management of depletion of ISWs, and concludes that these criteria will be protective of the depletion of ISWs and prevent significant and unreasonable impacts to beneficial surface water uses and users. This conclusion is not adequately supported by data and/or consultation with the agencies that are responsible for the regulation of GDE habitats. We have the following comments:
o The section states that current or historical issues associated with depletion of ISWs were not indicated to be significant and unreasonable based on discussions at GWA Board, Advisory Committee, and Workgroup meetings and TNC Comments
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through input from GSA staff, and that it was therefore assumed that historical conditions are protective of beneficial uses. It does not appear that any consultation occurred with the Federal, State and local agencies responsible for management and regulation of environmental beneficial uses of ISWs, or with the private parties, agencies and NGOs involved in managing the protected lands listed in our response to Section 1.3.1. In addition, no reference is made to the review of supporting documents for General Plan Conservation or Land Use Elements, or to the review of environmental management studies and documents such as Biological Assessments, Biological Opinions, HCPs or other studies regarding the current and historical conditions of the beneficial uses being evaluated. Please provide a more thorough explanation of the basis for the assumption that current and historical groundwater level conditions are protective of beneficial uses related to ISWs. Data gaps should be acknowledged. o The GDE Pulse web application developed by The Nature Conservancy provides easy access to 35 years of satellite data to view trends of vegetation metrics, groundwater depth (where available), and precipitation data. This satellite imagery can be used to observe trends for NC dataset polygons within the Subbasin. Over the past 10 years (2009-2018), some NC dataset vegetation polygons have experienced adverse impacts to vegetation growth and moisture in the western portion of the Subbasin. Please review these spatial patterns and, where possible, correlate them with water level trends. Any indications of adverse trends and any data gaps should be identified.
o The section discusses future use scenarios, associated groundwater level declines and ISW depletions on a broad level. The potential effects of these declines on environmental beneficial uses, including GDEs, are not discussed.

In addition to discussion of potential adverse effects at a general level, a conclusion that significant adverse impacts are unlikely generally requires more site- and resource-specific analysis. Please include a discussion of the potential for adverse effects of surface water depletions on environmental resources, as well as a reasoned analysis of the likelihood of their occurrence under future scenarios. The lack of site-specific data to draw conclusions about specific environmental beneficial users should be recognized as a data gap.
o Please expand the analysis of potential undesirable results to include all environmental beneficial uses and users, including those associated with more local streams and creeks.
o The statement that an additional depletion of the surface water due to groundwater pumping of 50,000 acre-feet per year is not significant and unreasonable needs to be further analyzed. The conclusion is based on analyzing the estimated depletion as a percentage of total surface water discharge. The significance of such a depletion relative to specific beneficial uses and users will depend on its distribution throughout the surface water system. Even a modest amount of depletion may have a significant local adverse effect. The limitations of broad conclusions regarding basin- TNC Comments
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wide surface water flow depletions should be recognized and any data gaps identified.

Checklist Items 47, 48 and 49 – Monitoring Network (23 CCR §354.34) • [Section 4.1 Monitoring Network for Chronic Groundwater Level Decline (pp. 4-1 to 4-8) and Section 4.6 Monitoring Network for Depletion of Interconnected Surface Water (p. 4-14)] The GSP proposes to use groundwater level monitoring for chronic groundwater level decline as a surrogate for monitoring the depletion of ISWs. We have the following comments.
o The areas identified as potential GDEs in the GSP are located near the western boundary of the Subbasin. Only one of the representative monitoring wells appears to be located near those areas (Figure 4-1 on p. 4-5). Very few of the remaining monitoring wells are located near potential ISWs and GDEs.

Specific monitoring should be described to further evaluate, monitor, manage and protect areas with ISWs and GDEs.
o Per the GSP Regulations (23 CCR §354.34 (a) and (b)), monitoring must address trends in groundwater and related surface conditions (emphasis added). Groundwater level monitoring alone may be insufficient to establish a linkage between groundwater extraction and potentially resulting impacts to environmental resources associated with GDEs and ISWs. The cause-effect relationship between groundwater levels and the biological responses that could result in significant and unreasonable impacts to ISWs and GDEs depends on a number of complicated factors, and this relationship is not characterized or discussed. As such, it is not possible to determine whether the proposed monitoring, minimum thresholds and measurable objectives are sufficiently protective to ensure significant and unreasonable impacts to GDEs and ISWs will be prevented. The GDE Pulse interactive mapping application provides an example of a linkage between groundwater level data and GDE health that could be used to incorporate remote sensing into an efficient and incisive monitoring program. Please provide an explanation how groundwater levels will specifically be used to assess adverse impacts to GDEs and ISWs, and identify any data gaps and how they will be addressed.
• [Section 4.7 Data Gaps (pp. 4-14 to 4-17)] Twelve new monitoring wells are proposed to measure groundwater levels and quality in critical areas where data are sparse. These include increased coverage near streams, Subbasin boundaries, and in the central area of groundwater depression. We have the following comments. o Locations should be prioritized near high value or sensitive resources that are vulnerable to significant and unreasonable impacts, such as near the protected lands identified in our comments on Section 1.3.1 or the GDEs identified in the Subbasin. In addition to the major streams and rivers in the subbasin, impacts to smaller creeks and wetland areas should be considered, as these may be the most vulnerable resources. Please discuss the results of a resource assessment or consultations with resource managers that demonstrates a sufficient number of wells is proposed to address data gaps near GDEs and ISWs, and that they are being sited where TNC Comments
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they will provide the most benefit. Alternatively, please outline the process by which this will be accomplished.
o As discussed in our comments above, please address how the need to link and correlate groundwater level declines to biological responses, and significant and adverse impacts to GDEs and ISWs will be addressed.
o Well sites near ISWs should be selected at varying distances from streams and completed as vertically-nested clusters to capture the lateral and vertical gradients between the pumped depths in the aquifer system and the shallow groundwater aquifers that are in communication with ISWs or GDEs. There is a need to enhance monitoring of stream flow and vertical groundwater gradients by installing more stream gauges and clustered/nested wells near streams, rivers or wetlands. Ideally, colocating stream gauges with clustered wells would enhance understanding about where ISWs exist in the basin and whether pumping is causing depletions of surface water or impacts on beneficial users of surface water and groundwater.
o Addressing data gaps is typically iterative and it is not reasonable to expect it will be a one-time process. Please describe the process by which data gaps will be identified and addressed on an ongoing basis. • [Section 5.3 Data Included in the Management System (pp. 5-6 to 5-8)] Table 5.3 indicates that data regarding streamflow and GDEs is not currently included in the proposed Data Management System. Per the GSP Regulations (23 CCR §354.34 (a) and (b)), monitoring must address trends in groundwater and related surface conditions (emphasis added). You cannot manage what you do not measure.

Please discuss which monitoring data for “related surface conditions” will be gathered and incorporated in the DMS to assess potential significant and unreasonable impacts to environmental beneficial uses and users. • [Section 7.3.1 Monitoring (p. 7-5)] This section lists the key components involved in implementation of the monitoring network. Groundwater levels and monitoring will occur semi-annually, but no other information is given. Section 6.3 states that “additional management activities are discussed in Chapter 7: Plan Implementation”, and would include monitoring groundwater use through use of satellite imagery.

However, Chapter 7 does not discuss using imagery or any remote sensing, which is a great tool for monitoring ecosystem health of GDEs and ISWs. Please clarify the potential use of imagery as a monitoring tool, and expand it to monitoring surface indicators of ISW and GDE ecosystem health.
• [Section 7.3.2.2 Basin Conditions (pp. 7-5 and 7-6)] This section describes what current groundwater conditions and monitoring results will be included in the annual monitoring report. Please specifically address ecosystem health of GDEs and ISWs as a surface indictor to subsurface conditions. This can be done using GDE Pulse, remote sensing, imagery or other feasible methods.

Checklist Items 50 and 51 – Project and Management Actions (23 CCR §354.44) • [Section 6.2.1 Project Identification (p. 6-1)] The Subbasin includes many GDEs and ISWs which represent beneficial uses and users of groundwater, and which include potentially sensitive resources and protected lands. Environmental resource TNC Comments
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protection needs should be considered in establishing project priorities. In addition, consistent with existing grant and funding guidelines for SGMA-related work, priority should be given to multi-benefit projects that can address water quantity as well as providing environmental benefits or benefits to disadvantaged communities. Please include environmental benefits and multiple benefits as criteria for assessing project priorities.
• Table 6-1 (pp. 6-2 to 6-7) lists potential projects and the Measurable Objective that is expected to benefit. Only water level benefits are listed, but maintenance or recovery of groundwater levels, or construction of recharge facilities, also will have environmental benefits in many cases. From the table, it is not possible to distinguish the full range of project benefits or how the projects will be prioritized. It would be advantageous to demonstrate multiple benefits from a funding and prioritization perspective.
• [Section 6.2.4 Planned Projects (pp. 6-8 to 6-33)]
o For the projects already identified, please consider stating how ISWs and GDEs will benefit or be protected, or what other environmental benefits will accrue.
o If ISWs will not be adequately protected by those listed, please include and describe additional management actions and projects targeted for protecting ISWs.
o Recharge ponds, reservoirs and facilities for managed stormwater recharge can be designed to include elements that act functionally as wetlands and provide a benefit for wildlife and aquatic species. In some cases, such facilities have been incorporated into local HCPs, more fully recognizing the value of the habitat that they provide and the species they support. For projects that will be constructing recharge ponds, please consider identifying if there will be habitat value incorporated into the design and how the recharge ponds will be managed to benefit
environmental users.
o Specific examples of how project descriptions may be refined to incorporate environmental benefits include the following:
▪ Project 21: Winery Recycled Water will recycle winery wastewater and reuse it for irrigation and in-lieu recharge, or the water will be put into ponds. Please consider identifying what proportion of water will be put into ponds for direct recharge that could also provide a benefit for wildlife and aquatic species.
▪ Project 23: SSJID Stormwater Reuse will capture stormwater for reuse and recharge. Project 18: Farmington Dam Repurpose Project proposes to more than double storage in Farmington Basin for water supply. Please consider assessing ways in which these projects could also provide enhanced wildlife and aquatic species benefits.
▪ For examples of case studies on how to incorporate environmental benefits into groundwater projects, please visit our website:
https://groundwaterresourcehub.org/case-studies/recharge-casestudies/ • [Section 6.3 Management Actions (p. 6-34)] This section lists only administrative actions the GSA will undertake to implement the GSP, and does not identify the management actions to be taken if to assure SGMA compliance if monitoring data TNC Comments
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indicate that measurable objectives or interim milestones are not being achieved. An adaptive management approach, where monitoring data are used to assess results and inform refinement of the management approach is typically specified. Please identify what management actions will be taken if monitoring data indicate that Measurable Objectives or Interim Milestones are not being achieved, or undesirable results are imminent.

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 Attachment A (see
comment letter)
SandiMatsumoto
The Nature
Conservancy N/A N/A N/A
Considering Nature under SGMA: A Checklist "Environmental User Checklist" Attachment B (see
comment letter)
SandiMatsumoto
The Nature
Conservancy N/A N/A N/A
This attachment (also detailed below) summarizes our comments on the complete public draft GSP dated July 2019, and includes any initial review comments from our May 31, 2019 that have not yet been addressed. 1 SandiMatsumoto
The Nature
Conservancy pp. 1‐40 Section 1.3.1 N/A
Caswell Memorial State Park is incorrectly referred to as being located outside the Eastern San Joaquin Subbasin. The following additional protected lands are located near surface waters within the Subbasin that may be interconnected with groundwater, and/or may rely at least partly on groundwater to support vegetation and sensitive natural communities. These protected lands represent potential beneficial users of groundwater: Durham Ferry State Recreational Area, a small portion (approximately 200 acres) of San Joaquin River National Wildlife Refuge, Army Corps Park, Vernalis Riparian Habitat (Public Conservation Lands), Seegers Preserve, Cabral Island Preserve, Machado Preserve, Hansen Preserve, Micke Grove Park and Zoo, Oak Grove Regional Park, Nakagawa Preserve, El Rio Farms Preserve, Lodi Lake Nature Area, Woodbridge Regional Park, Woodbridge Ecological Preserve, White Slough WA, Nuss Farms, Beck Preserve, Hilder Preserve, Staten Island Ranch, Burchel Preserve, and Ishizuka Preserve. The authors referred to the San Joaquin County General Plan documents, including background reports, for information regarding these important resources. These potential beneficial groundwater users should be described in the text on pp. 1‐18 and shown in Figure 1‐11. Please include a description recognizing all of the protected areas in the Subbasin and their beneficial groundwater uses. Section 2.2.8 includes a geospatial analysis that removes managed wetlands from consideration as GDEs. The managed wetlands in the Subbasin should be identified in this section. 2 Sandi
Matsumoto
The Nature
Conservancy
pp. 1‐10 to
1‐21
Section 1.2.1 N/A
Critical habitat is known to exist for protected aquatic species, such as California Tiger Salamander, Steelhead, Delta Smelt, Giant Gartersnake and California Red‐Legged Frog in and around the Subbasin (https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe09893cf75b8dbfb77).

There are likely ongoing monitoring programs associated with critical habitat areas and the protected lands. Please include a description of these habitat areas, and associated programs and requirements pertinent to ISWs, GDEs and wetlands. Identify areas where critical habitat exists and overlaps with ISWs and GDEs.
3 Sandi
Matsumoto
The Nature
Conservancy
pp. 1‐21 to
1‐32
Section 1.2.2 N/A
Per the GSP Regulations (23 CCR §354.34 (a) and (b)), monitoring must address trends in groundwater and related surface conditions (emphasis added). In order for this section to provide the appropriate context and help assure integration of GSP implementation with other ongoing regulatory programs, this section should describe the following: o Monitoring activities and responsibilities by State, Federal and local agencies and jurisdictions related to aquatic resources and GDEs that could be affected by groundwater withdrawals should be discussed. Section 1.2.2.6 states that there are no agencies that do monitoring specific to surface‐groundwater interconnection. While this may be technically correct insofar as it relates to hydrogeologic monitoring, it ignores ongoing monitoring programs related to the state of aquatic resources and GDEs that could be affected by groundwater withdrawals, and that are a direct indicator of potential undesirable results. For example, there are likely ongoing monitoring programs associated with the protected lands listed in our comments to Section 1.3.1, and other open space or preserve areas that may be monitored by public, private or nonprofit entities. A discussion of monitoring programs related to GDEs and ISWs should be included. o The lack of existing hydrologic monitoring of surface‐groundwater interconnection is a significant data gap as it relates to classification and management of GDEs and should be identified as such and further discussed and addressed in the appropriate subsequent sections of the GSP. o Monitoring activities and responsibilities related to instream flow and water quality requirements under applicable Federal Energy Regulatory Commission licenses, Biological Opinions and other regulations or programs are relevant and should be identified. Please include a discussion of water flow and quality monitoring requirements pertinent to ISWs.

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 4 SandiMatsumoto
The Nature
Conservancy
pp. 1‐33 to
1‐36 and
Appendix1‐E)
Section 1.2.3 N/A
This section should include a discussion of General Plan goals and policies related to the protection and management of GDEs and aquatic resources that could be affected by groundwater withdrawals, rather than being limited to goals and policies directly related to groundwater resources alone. Section

1.3.1 correctly identifies environmental uses of groundwater as including “…species and habitat reliant on instream flows, as well as wetlands and GDEs,” and yet Section 1.2.3 and Appendix 1‐E do not identify any General Plan policies related to these resources. Section 1.2.3 should identify if there are any Habitat Conservation Plans (HCPs) or Natural Community Conservation Plans (NCCPs) within the Subbasin and if they are associated with critical, GDE and/or ISW habitats. Appendix 1‐E should identify General Plan policies related to wetlands, riparian habitat, streams, aquatic habitat, and related threatened and endangered species. Section 1.2.3.2 should include a discussion of the relationship of GSP implementation to General Plan goals and policies related to GDEs and aquatic habitat; and also address how GSP implementation will coordinate with the goals of any HCPs or NCCPs. 5 SandiMatsumoto
The Nature
Conservancy
pp. 1‐36 to1‐38 Section 1.2.3.4 N/A
This section should include a discussion of the following: o Future well permitting must be coordinated with the GSP to assure achievement of the Plan’s sustainability goals. o The State Third Appellate District recently found that Counties have a responsibility to consider the potential impacts of groundwater withdrawals on public trust resources when permitting new wells near streams with public trust uses (ELF v. SWRCB and Siskiyou County, No. C083239). The need for well permitting programs to comply with this requirement should be stated. o Section 2.3.3.3 discusses potential exemptions from the Stanislaus County Groundwater Ordinance but does not mention the fact that applicants who are not exempt are required to provide substantial evidence that their proposed extraction will not result in undesirable results, including significant and unreasonable impacts to GDEs and surface waters. 6 SandiMatsumoto
The Nature
Conservancy
pp. 2‐35 to
2‐37 Section 2.1.7 N/A
Please clearly state whether localized perched aquifers are present in the basin. Include example near‐surface cross section details that depict the conceptual understanding of shallow groundwater and stream interactions at different locations, including perched and regional aquifers. 7 SandiMatsumoto
The Nature
Conservancy p. 2‐39 Section 2.1.8.2 N/A
The Bottom of the Basin Boundary was defined by the base of freshwater, which was mapped 45 years ago and pumping since then has very likely resulted in shift in the isohaline contouring in the basin. Defining the bottom of the Subbasin based on geochemical properties is a suitable approach for defining the base of freshwater, however, as noted on page 9 of DWR's Hydrogeologic Conceptual Model BMP (https://water.ca.gov/LegacyFiles/groundwater/sgm/pdfs/BMP_HCM_Final_2016‐12‐23.pdf) "the definable bottom of the basin should be at least as deep as the deepest groundwater extractions". Thus, groundwater extraction well depth data should also be included in the determination of the basin bottom.

This will prevent the possibility of extractors with wells deeper than the basin boundary from claiming exemption of SGMA due to their well residing outside the vertical extent of the basin boundary. Also, pumping saline groundwater and desalinating it will become increasingly economical under SGMA due to pumping restrictions in the basin.
8 Sandi
Matsumoto
The Nature
Conservancy
pp. 2‐56and 2‐57 Section 2.1.10 N/A
The Hydrologic Conceptual Model identified several data gaps including the following for groundwater level data: o Depth‐ or zone‐specific water levels to assess vertical interconnection, including zones within the Principal Aquifer. Nested monitoring wells would be helpful near surface water to show how pumping is impacting surface water flows and GDEs. o Additional shallow groundwater data near surface waters and NCCAGs. o Additional groundwater level data in the east and northwest areas of the Subbasin. o Additional groundwater level data near the Mokelumne River to improve quantification and understanding of subsurface flows. Of these, the second data gap is the information that is most critical to identifying GDEs or potential GDEs and understanding their characteristics.
9 SandiMatsumoto
The Nature
Conservancy
pp. 2‐9 to
2‐14 Section 2.1.4.2 N/A
This section should discuss (or reference the sections discussing) the following: o Specific ISWs, including the extent of both gaining and losing reaches. o In‐stream flow requirements in each of the interconnected rivers/streams including the amount, time of year when the flow minimum is specified, the duration, the freshwater fish species for which it applies, associated permits that set forth the requirements, and the regulating agency setting forth the compliance requirements. o Areas of critical habitat that exist within rivers and streams. 10 SandiMatsumoto
The Nature
Conservancy
pp. 2‐23 to
2‐27 Section 2.1.5 N/A
Table 2‐2 states that Holocene Stream Channel Deposits are generally not saturated except by the San Joaquin River. Based on the available data, it would be expected that the stream channel deposits associated with the other ISWs in the Subbasin would be saturated near those streams and rivers. 11 SandiMatsumoto
The Nature
Conservancy p. 2‐49 Section 2.1.9.2.2 N/A
This section focuses on groundwater flow direction and defers further discussion of groundwater conditions to Section 2.2, which does not provide information on historical groundwater‐surface water interaction. This section should include a discussion of historic groundwater‐surface water interaction.

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 12 SandiMatsumoto
The Nature
Conservancy
pp. 2‐97 to
2‐99 Section 2.2.6 N/A
o The determination as to whether or not a stream reach is interconnected or disconnected was made based on whether modeling conducted for the GSP indicated that it is interconnected more than 25 percent of the time. Even if the stream is only connected 25% of the time, it is still connected, and that short period of connectivity may be during critical times for select species or provide a cooling or biogeochemical effect during a critical period. Please describe the technical basis for selecting a 25 percent interconnection threshold, and how it will adequately protect the environmental beneficial uses of surface water in potentially interconnected surface waters from significant and unreasonable impacts related to groundwater extraction. o Shallow groundwater monitoring data near surface waters and NCCAGs are identified as a data gap in Section 2.1.10, and the use of the Eastern San Joaquin Water Resources Model (ESJWRM) to determine the percentage of time that stream reaches are groundwater connected entails inherent uncertainty. The potential presence of shallow or perched aquifers near the rivers is not assessed or discussed in the GSP. Groundwater modeling conducted by the United States Geological Survey (USGS), DWR and others (e.g., JJ&A, 2018) has considered some river reaches shown as disconnected in Figure 2‐66 (pp. 2‐99) to be groundwater‐connected. No data or discussion is presented regarding the potential groundwater connection of other streams associated with significant wetland and riparian resources, including Pixley Slough, Mormon Slough, Littlejohns Creek, Bear Creek, Potter Creek, Duck Creek and Lone Tree Creek. As such, there is considerable uncertainty regarding the designation of interconnected and disconnected surface water resources in Figure 2‐66. The uncertainty regarding the groundwater interconnection of streams in the Subbasin should be identified as a data gap. 13 SandiMatsumoto
The Nature
Conservancy p. 2‐100 Section 2.2.7 N/A
This section includes the incorrect statement that SGMA does not require sustainable management criteria to be established for the management of GDEs.

Section 1.3.1 of the GSP states that beneficial users of groundwater and ISWs include “environmental users of groundwater, including species and habitat reliant on instream flows, as well as wetlands and GDEs.” Undesirable results under SGMA include chronic lowering of groundwater levels resulting in significant and unreasonable depletion of supply for beneficial groundwater users, including GDEs. Undesirable results also include depletion of ISWs resulting in significant and unreasonable adverse impacts on beneficial users of surface water, including wetlands and GDEs. The incorrect statement that SGMA does not require the establishment of sustainable management criteria for GDEs should be removed.

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 14 SandiMatsumoto
The Nature
Conservancy
p. 2‐100 to2‐106
Section 2.2.8 N/A
The GSP relies on the NCCAG database developed by TNC for the DWR to identify potential GDEs, and then provides a framework for removing most of these areas from further consideration. It appears that the preliminary desktop analysis documented in the draft GSP resulted an excessive elimination of the NC dataset polygons mapped in the Eastern San Joaquin Subbasin. In particular, the methods used to confirm whether or not polygons in the NC Dataset are connected to groundwater in the Eastern San Joaquin Subbasin are highly flawed. We have the following comments on the proposed approach:
oThe GSP takes the approach of removing NCCAGs with “access to alternate water supplies” from consideraƟon as GDEs, and states that in order to be considered GDEs, “there must not be alternate water supplies”. Alternate water supplies are assumed to include potential sources of surface water including managed wetlands, irrigated agricultural fields, perennial surface water sources, and other unspecified sources determined by stakeholders on a case‐specific basis. This approach is inappropriate and deficient for several important reasons:
•There is no hydrologic analysis or empirical data provided as a basis for the proposed buffer zones. The hydrologic connecƟvity between a GDE and a nearby alternative water source is highly dependent on local conditions and can vary seasonally and by year type. In the case of managed wetlands, no consideration is given to the nature of the wetland and surrounding area, the source and frequency of inundation, the soil types, and other features that would be needed to understand the hydrologic connectivity between the wetland and the surrounding area, or even whether the wetland itself it groundwater dependent for a portion of the year. Similarly, no information is given to the topography and hydrology surrounding irrigated agricultural fields, the soil types involved, irrigation practices, whether irrigation is likely to be curtailed during dry years or during certain crop rotations, and other relevant factors. The hydrologic connectivity of perennial surface water sources cannot be assessed without specific knowledge of the water source, topography and soil conditions. In summary, the adequacy of generic buffer zones to assure GDE access to surface water is unsubstantiated. •No informaƟon is provided regarding the species residing in the GDEs, their sensiƟvity to groundwater level declines, or the extent of their reliance on groundwater vs. the proposed “alternate water supplies.” •There is no evidence of consultaƟon with the regulatory agencies responsible for the protecƟon and management of these resources in the establishment of the proposed framework. It does not appear that any habitat assessments have been conducted. •Ecosystems oŌen rely both on groundwater and surface water to meet their water needs (see Best Management PracƟce #3 in AƩachment C of this leƩer).

The availability of “alternate water supplies” to provide some portion of a GDE’s water demand does not mean all of its water needs can be met through alternate supplies (i.e., without reliance on groundwater). •Groundwater pumping depletes ISWs under both gaining or losing condiƟons, and GDEs may rely on the interacƟons of surface water to meet their water requirements.Simply put, the approach proposes to manage GDEs without consideration to understanding the nature and needs of the resource being managed. A strictly binary approach, designating all NCCAGs as either 100 percent reliant on groundwater or 100 percent reliant on alternate water supplies is inconsistent with h il bl i d i bl i ifi il f i ih d l h b
15 SandiMatsumoto
The Nature
Conservancy
pp. 2‐115to 2‐133
Section 2.3.5 N/A
The following items related to GDEs, wetlands and riparian areas should be clarified or considered:
o“Riparian intake from streams” is idenƟfied as a stream system water budget component and is defined as the porƟon of riparian evapotranspiraƟon (ET) met by streamflows. Please include an explanation of the approach to determining the amount of riparian ET demand met by streamflow vs. groundwater evapotranspiration.
oGroundwater ouƞlow to ET does not appear to be idenƟfied as a groundwater budget component (for example see Figure 2‐74, p. 2‐125). In addiƟon, the ET demand of natural vegetation does not appear to be considered in water supply and demand calculations (for example see Table 2‐16, p. 2‐126). Since GDEs (including wetlands,riparian vegetation, phreatophytes and other communities) are recognized as beneficial users of groundwater in the Subbasin, it is appropriate to include them in these calculations.
16 SandiMatsumoto
The Nature
Conservancy p. 3‐1 Section 3.1 N/A
The Sustainability Goal is defined as being “ … to maintain an economically‐viable groundwater resource for the beneficial use of the people of the Eastern San Joaquin Subbasin … .” Since GDEs, are recognized as beneficial users of groundwater in the Subbasin, they should be mentioned in the Sustainability Goal.
17 SandiMatsumoto
The Nature
Conservancy p. 3‐3 Section 3.2.1.1.1 N/A
This section only describes undesirable results relating to human beneficial uses of groundwater and neglects environmental beneficial uses that could be adversely affected by chronic groundwater level decline. On page 3‐5 in Section 3.2.1.2, impacts to GDEs are correctly identified as an undesirable result potentially associated with chronic groundwater level decline. Please add “potential adverse impacts to GDEs” to the list of potential undesirable results presented in Section 3.2.1.1.1.
18 SandiMatsumoto
The Nature
Conservancy p. 3‐11 Section 3.2.3.1.1
DegradedWaterQuality
This section only describes undesirable results in terms of total dissolved solids concentrations and related impacts. The section should be modified to state that overpumping and dewatering of aquitards has been identified as a potential source of elevated arsenic concentrations above drinking water standards in San Joaquin Valley aquifers. The following is a link to a paper by Smith, Knight and Fendorf (2018) titled “Overpumping leads to California groundwater arsenic threat”: (https://www.nature.com/articles/s41467‐018‐04475‐3).

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 19 Sandi
Matsumoto
The Nature
Conservancy p. 3‐11 Section 3.2.6.1.1 ISWs
This section states that undesirable results related to surface water depletion were defined and evaluated only for major streams and rivers including the Calaveras River, Dry Creek, Mokelumne River, San Joaquin River, and Stanislaus River. The section goes on to state that many of the smaller creeks and streams are solely used for the conveyance of irrigation water and these systems have not been considered in the analysis of depletions. Contrary to these statements, surface water resources in these creeks support significant recognized aquatic habitat, wetlands and riparian zones that represent potential environmental beneficial uses and users of groundwater. A number of these streams are associated with designated protected lands. The analysis for potential depletion of ISWs in Section 3.2.6 should include all beneficial users of surface water that could be affected by groundwater withdrawals, including environmental beneficial users along creeks, even if the creeks are interconnected less than 75% of the time. 20 Sandi
Matsumoto
The Nature
Conservancy p. 3‐12 Section 3.2.6.1.2 N/A
The section states that “undesirable results would occur if groundwater extractions depleted interconnected streams and there was not sufficient surface water to supply … fish and wildlife demands.” This definition of undesirable results is overly narrow and recognizes only a limited subset of the environmental beneficial users of ISWs. A more complete definition would be that undesirable results would occur if groundwater extraction resulted in a depletion of surface water that caused significant impacts to aquatic species or wildlife, or degradation of GDEs. Please expand the definition of undesirable results to include all of the environmental beneficial uses and users of ISWs, and expand the analysis in Section 3.2.6, as appropriate. 21 Sandi
Matsumoto
The Nature
Conservancy p. 3‐12 Section 3.2.6.1.3 N/A
The potential effects of undesirable results on environmental beneficial users are not described. Please expand the section to describe the potential effects of undesirable results on all beneficial uses and users of ISWs, including environmental uses and users. •The GDE Pulse web applicaƟon developed by The Nature Conservancy provides easy access to 35 years of satellite data to view trends of vegetaƟon metrics, groundwater depth (where available), and precipitation data. This satellite imagery can be used to observe trends for NC dataset polygons within the Subbasin. Over the past 10 years (2009‐2018), some NC dataset vegetation polygons have experienced adverse impacts to vegetation growth and moisture in the western portion of the Subbasin. An example screen shot from the GDE Pulse tool is presented below. Please review these spatial patterns and, where possible, correlate them with water level trends. Any indications of adverse trends and any data gaps should be identified.

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 22 Sandi
Matsumoto
The Nature
Conservancy
pp. 3‐19and 3‐20 Section 3.2.6.2 N/A
The GSP proposes to use the Minimum Thresholds and Measurable Objectives associated with Chronic Decline in Groundwater Levels as a proxy for management of depletion of ISWs, and concludes that these criteria will be protective of the depletion of ISWs and prevent significant and unreasonable impacts to beneficial surface water uses and users. This conclusion is not adequately supported by data and/or consultation with the agencies that are responsible for the regulation of GDE habitats. We have the following comments:
oThe secƟon states that current or historical issues associated with depleƟon of ISWs were not indicated to be significant and unreasonable based on discussions at GWA Board, Advisory Committee, and Workgroup meetings and through input from GSA staff, and that it was therefore assumed that historical conditions are protective of beneficial uses. It does not appear that any consultation occurred with the Federal, State and local agencies responsible for management and regulation of environmental beneficial uses of ISWs, or with the private parties, agencies and NGOs involved in managing the protected lands listed in our response to Section 1.3.1. In addition, no reference is made to the review of supporting documents for General Plan Conservation or Land Use Elements, or to the review of environmental management studies and documents such as Biological Assessments, Biological Opinions, HCPs or other studies regarding the current and historical conditions of the beneficial uses being evaluated. Please provide a more thorough explanation of the basis for the assumption that current and historical groundwater level conditions are protective of beneficial uses related to ISWs. Data gaps should be acknowledged.
oThe GDE Pulse web applicaƟon developed by The Nature Conservancy provides easy access to 35 years of satellite data to view trends of vegetaƟon metrics, groundwater depth (where available), and precipitation data. This satellite imagery can be used to observe trends for NC dataset polygons within the Subbasin. Over the past 10 years (2009‐2018), some NC dataset vegetation polygons have experienced adverse impacts to vegetation growth and moisture in the western portion of the Subbasin. Please review these spatial patterns and, where possible, correlate them with water level trends. Any indications of adverse trends and any data gaps should be identified. oThe secƟon discusses future use scenarios, associated groundwater level declines and ISW depleƟons on a broad level. The potenƟal effects of these declines on environmental beneficial uses, including GDEs, are not discussed. In addition to discussion of potential adverse effects at a general level, a conclusion that significant adverse impacts are unlikely generally requires more site‐ and resource‐specific analysis. Please include a discussion of the potential for adverse effects of surface water depletions on environmental resources, as well as a reasoned analysis of the likelihood of their occurrence under future scenarios. The lack of site‐specific data to draw conclusions about specific environmental beneficial users should be recognized as a data gap. oPlease expand the analysis of potenƟal undesirable results to include all environmental beneficial uses and users, including those associated with more local streams and creeks.
oThe statement that an addiƟonal depleƟon of the surface water due to groundwater pumping of 50,000 acre‐feet per year is not significant and unreasonable needs to be further analyzed. The conclusion is based on analyzing the estimated depletion as a percentage of total surface water discharge. h i ifi f h d li li ifi b fi i l d ill dd i di ib i hh h f 23 Sandi
Matsumoto
The Nature
Conservancy
pp. 4‐1 to
4‐8 and p.
4‐14
Section 4.1 and
Section 4.6 N/A
The GSP proposes to use groundwater level monitoring for chronic groundwater level decline as a surrogate for monitoring the depletion of ISWs. We have the following comments.
oThe areas idenƟfied as potenƟal GDEs in the GSP are located near the western boundary of the Subbasin. Only one of the representaƟve monitoring wells appears to be located near those areas (Figure 4‐1 on p. 4‐5). Very few of the remaining monitoring wells are located near potential ISWs and GDEs.

Specific monitoring should be described to further evaluate, monitor, manage and protect areas with ISWs and GDEs. oPer the GSP RegulaƟons (23 CCR §354.34 (a) and (b)), monitoring must address trends in groundwater and related surface condiƟons (emphasis added).

Groundwater level monitoring alone may be insufficient to establish a linkage between groundwater extraction and potentially resulting impacts to environmental resources associated with GDEs and ISWs. The cause‐effect relationship between groundwater levels and the biological responses that could result in significant and unreasonable impacts to ISWs and GDEs depends on a number of complicated factors, and this relationship is not characterized or discussed. As such, it is not possible to determine whether the proposed monitoring, minimum thresholds and measurable objectives are sufficiently protective to ensure significant and unreasonable impacts to GDEs and ISWs will be prevented. The GDE Pulse interactive mapping application provides an example of a linkage between groundwater level data and GDE health that could be used to incorporate remote sensing into an efficient and incisive monitoring program. Please provide an explanation how groundwater levels will specifically be used to assess adverse impacts to GDEs and ISWs, and identify any data gaps and how they will be addressed.

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 24 SandiMatsumoto
The Nature
Conservancy
pp. 4‐14 to
4‐17
Section 4.7 N/A
Twelve new monitoring wells are proposed to measure groundwater levels and quality in critical areas where data are sparse. These include increased coverage near streams, Subbasin boundaries, and in the central area of groundwater depression. We have the following comments. oLocaƟons should be prioriƟzed near high value or sensiƟve resources that are vulnerable to significant and unreasonable impacts, such as near the protected lands identified in our comments on Section 1.3.1 or the GDEs identified in the Subbasin. In addition to the major streams and rivers in the subbasin, impacts to smaller creeks and wetland areas should be considered, as these may be the most vulnerable resources. Please discuss the results of a resource assessment or consultations with resource managers that demonstrates a sufficient number of wells is proposed to address data gaps near GDEs and ISWs, and that they are being sited where they will provide the most benefit. Alternatively, please outline the process by which this will be accomplished.
oAs discussed in our comments above, please address how the need to link and correlate groundwater level declines to biological responses, and significant and adverse impacts to GDEs and ISWs will be addressed. oWell sites near ISWs should be selected at varying distances from streams and completed as verƟcally‐nested clusters to capture the lateral and verƟcal gradients between the pumped depths in the aquifer system and the shallow groundwater aquifers that are in communication with ISWs or GDEs. There is a need to enhance monitoring of stream flow and vertical groundwater gradients by installing more stream gauges and clustered/nested wells near streams, rivers or wetlands. Ideally, co‐locating stream gauges with clustered wells would enhance understanding about where ISWs exist in the basin and whether pumping is causing depletions of surface water or impacts on beneficial users of surface water and groundwater. oAddressing data gaps is typically iteraƟve and it is not reasonable to expect it will be a one‐Ɵme process. Please describe the process by which data gaps will be identified and addressed on an ongoing basis.
25 SandiMatsumoto
The Nature
Conservancy
pp. 5‐6 to
5‐8 Section 5.3, Table 5.3 N/A
Table 5.3 indicates that data regarding streamflow and GDEs is not currently included in the proposed Data Management System. Per the GSP Regulations (23 CCR §354.34 (a) and (b)), monitoring must address trends in groundwater and related surface conditions (emphasis added). You cannot manage what you do not measure. Please discuss which monitoring data for “related surface conditions” will be gathered and incorporated in the DMS to assess potential significant and unreasonable impacts to environmental beneficial uses and users. 26 SandiMatsumoto
The Nature
Conservancy p. 7‐5 Section 7.3.1 N/A
This section lists the key components involved in implementation of the monitoring network. Groundwater levels and monitoring will occur semi‐annually, but no other information is given. Section 6.3 states that “additional management activities are discussed in Chapter 7: Plan Implementation”, and would include monitoring groundwater use through use of satellite imagery. However, Chapter 7 does not discuss using imagery or any remote sensing, which is a great tool for monitoring ecosystem health of GDEs and ISWs. Please clarify the potential use of imagery as a monitoring tool, and expand it to monitoring surface indicators of ISW and GDE ecosystem health.
27 SandiMatsumoto
The Nature
Conservancy
pp. 7‐5
and 7‐6 Section 7.3.2.2 N/A
This section describes what current groundwater conditions and monitoring results will be included in the annual monitoring report. Please specifically address ecosystem health of GDEs and ISWs as a surface indictor to subsurface conditions. This can be done using GDE Pulse, remote sensing, imagery or other feasible methods.
28 SandiMatsumoto
The Nature
Conservancy p. 6‐1 Section 6.2.1 N/A
The Subbasin includes many GDEs and ISWs which represent beneficial uses and users of groundwater, and which include potentially sensitive resources and protected lands. Environmental resource protection needs should be considered in establishing project priorities. In addition, consistent with existing grant and funding guidelines for SGMA‐related work, priority should be given to multi‐benefit projects that can address water quantity as well as providing environmental benefits or benefits to disadvantaged communities. Please include environmental benefits and multiple benefits as criteria for assessing project priorities.
29 Sandi
Matsumoto
The Nature
Conservancy
pp. 6‐2 to
6‐7
Table 6.1 N/A
Table 6‐1 lists potential projects and the Measurable Objective that is expected to benefit. Only water level benefits are listed, but maintenance or recovery of groundwater levels, or construction of recharge facilities, also will have environmental benefits in many cases. From the table, it is not possible to distinguish the full range of project benefits or how the projects will be prioritized. It would be advantageous to demonstrate multiple benefits from a funding and prioritization perspective.

Comment # Commenter Commenter Organization Page Number Section, Figure, or Table Number Sentence Starts with, "… Comment 30 Sandi
Matsumoto
The Nature
Conservancy
pp. 6‐8 to
6‐33
Section 6.2.4 N/A
oFor the projects already idenƟfied, please consider staƟng how ISWs and GDEs will benefit or be protected, or what other environmental benefits will accrue.
oIf ISWs will not be adequately protected by those listed, please include and describe addiƟonal management acƟons and projects targeted for protecƟng ISWs.
oRecharge ponds, reservoirs and faciliƟes for managed stormwater recharge can be designed to include elements that act funcƟonally as wetlands and provide a benefit for wildlife and aquatic species. In some cases, such facilities have been incorporated into local HCPs, more fully recognizing the value of the habitat that they provide and the species they support. For projects that will be constructing recharge ponds, please consider identifying if there will be habitat value incorporated into the design and how the recharge ponds will be managed to benefit environmental users. oSpecific examples of how project descripƟons may be refined to incorporate environmental benefits include the following:・Project 21: Winery Recycled Water will recycle winery wastewater and reuse it for irrigaƟon and in‐lieu recharge, or the water will be put into ponds. Please consider identifying what proportion of water will be put into ponds for direct recharge that could also provide a benefit for wildlife and aquatic species. ・Project 23: SSJID Stormwater Reuse will capture stormwater for reuse and recharge. Project 18: Farmington Dam Repurpose Project proposes to more than double storage in Farmington Basin for water supply. Please consider assessing ways in which these projects could also provide enhanced wildlife and aquatic species benefits.
・For examples of case studies on how to incorporate environmental benefits into groundwater projects, please visit our website:
https://groundwaterresourcehub.org/case‐studies/recharge‐case‐studies/ 31 SandiMatsumoto
The Nature
Conservancy p. 6‐34 Section 6.3 N/A
This section lists only administrative actions the GSA will undertake to implement the GSP, and does not identify the management actions to be taken if to assure SGMA compliance if monitoring data indicate that measurable objectives or interim milestones are not being achieved. An adaptive management approach, where monitoring data are used to assess results and inform refinement of the management approach is typically specified. Please identify what management actions will be taken if monitoring data indicate that Measurable Objectives or Interim Milestones are not being achieved, or undesirable results are imminent.

Attachment C (see
comment letter)
Sandi
Matsumoto
The Nature
Conservancy N/A N/A N/A
IDENTIFYING GDEs UNDER SGMA Best Practices for using the NC Dataset Attachment D (see
comment letter)
Sandi
Matsumoto
The Nature
Conservancy N/A N/A N/A
GDE Pulse
A new, free online tool that allows Groundwater Sustainability Agencies to assess changes in groundwater dependent ecosystem (GDE) health using satellite, rainfall, and groundwater data.
25 Attachment C

July 2019
IDENTIFYING GDEs UNDER SGMA
Best Practices for using the NC Dataset
The Sustainable Groundwater Management Act (SGMA) requires that groundwater dependent ecosystems (GDEs) be identified in Groundwater Sustainability Plans (GSPs). As a starting point, the Department of Water Resources (DWR) is providing the Natural Communities Commonly Associated with Groundwater Dataset (NC Dataset) online 5to help Groundwater Sustainability Agencies (GSAs), consultants, and stakeholders identify GDEs within individual groundwater basins. To apply information from the NC Dataset to local areas, GSAs should combine it with the best available science on local hydrology, geology, and groundwater levels to verify whether polygons in the NC dataset are likely supported by groundwater in an aquifer (Figure 1)6. This document highlights six best practices for using local groundwater data to confirm whether mapped features in the NC dataset are supported by groundwater.

The NC Dataset identifies vegetation and wetland features that are good indicators of a GDE. The dataset is comprised of 48 publicly available state and federal datasets that map vegetation, wetlands,

5 NC Dataset Online Viewer: https://gis.water.ca.gov/app/NCDatasetViewer/ 6 California Department of Water Resources (DWR). 2018. Summary of the “Natural Communities Commonly Associated with Groundwater” Dataset and Online Web Viewer. Available at: https://water.ca.gov/-/media/DWR-Website/WebPages/Programs/Groundwater-Management/Data-and-Tools/Files/Statewide-Reports/Natural-Communities-DatasetSummary-Document.pdf Figure 1. Considerations for GDE identification.

Source: DWR2
26 springs, and seeps commonly associated with groundwater in California7. It was developed through a collaboration between DWR, the Department of Fish and Wildlife, and The Nature Conservancy (TNC).

TNC has also provided detailed guidance on identifying GDEs from the NC dataset8 on the Groundwater Resource Hub9, a website dedicated to GDEs.

BEST PRACTICE #1. Establishing a Connection to Groundwater Groundwater basins can be comprised of one continuous aquifer (Figure 2a) or multiple aquifers stacked on top of each other (Figure 2b). In unconfined aquifers (Figure 2a), using the depth-to-groundwater and the rooting depth of the vegetation is a reasonable method to infer groundwater dependence for GDEs. If groundwater is well below the rooting (and capillary) zone of the plants and any wetland features, the ecosystem is considered disconnected and groundwater management is not likely to affect the ecosystem (Figure 2d). However, it is important to consider local conditions (e.g., soil type, groundwater flow gradients, and aquifer parameters) and to review groundwater depth data from multiple seasons and water year types (wet and dry) because intermittent periods of high groundwater levels can replenish perched clay lenses that serve as the water source for GDEs (Figure 2c). Maintaining these natural groundwater fluctuations are important to sustaining GDE health.

Basins with a stacked series of aquifers (Figure 2b) may have varying levels of pumping across aquifers in the basin, depending on the production capacity or water quality associated with each aquifer. If pumping is concentrated in deeper aquifers, SGMA still requires GSAs to sustainably manage groundwater resources in shallow aquifers, such as perched aquifers, that support springs, surface water, domestic wells, and GDEs (Figure 2). This is because vertical groundwater gradients across aquifers may result in pumping from deeper aquifers to cause adverse impacts onto beneficial users reliant on shallow aquifers or interconnected surface water. The goal of SGMA is to sustainably manage groundwater resources for current and future social, economic, and environmental benefits. While groundwater pumping may not be currently occurring in a shallower aquifer, use of this water may become more appealing and economically viable in future years as pumping restrictions are placed on the deeper production aquifers in the basin to meet the sustainable yield and criteria. Thus, identifying GDEs in the basin should done irrespective to the amount of current pumping occurring in a particular aquifer, so that future impacts on GDEs due to new production can be avoided. A good rule of thumb to follow is: if groundwater can be pumped from a well - it’s an aquifer.

7 For more details on the mapping methods, refer to: Klausmeyer, K., J. Howard, T. Keeler-Wolf, K. Davis-Fadtke, R. Hull, A. Lyons. 2018. Mapping Indicators of Groundwater Dependent Ecosystems in California: Methods Report. San Francisco, California. Available at: https://groundwaterresourcehub.org/public/uploads/pdfs/iGDE_data_paper_20180423.pdf 8 “Groundwater Dependent Ecosystems under the Sustainable Groundwater Management Act: Guidance for Preparing Groundwater Sustainability Plans” is available at: https://groundwaterresourcehub.org/gde-tools/gsp-guidance-document/ 9 The Groundwater Resource Hub: www.GroundwaterResourceHub.org 27 Figure 2. Confirming whether an ecosystem is connected to groundwater. Top: (a) Under the ecosystem is an unconfined aquifer with depth-to-groundwater fluctuating seasonally and interannually within 30 feet from land surface. (b) Depth-to-groundwater in the shallow aquifer is connected to overlying ecosystem. Pumping predominately occurs in the confined aquifer, but pumping is possible in the shallow aquifer. Bottom: (c) Depth-to-groundwater fluctuations are seasonally and interannually large, however, clay layers in the near surface prolong the ecosystem’s connection to groundwater. (d) Groundwater is disconnected from surface water, and any water in the vadose (unsaturated) zone is due to direct recharge from precipitation and indirect recharge under the surface water feature. These areas are not connected to groundwater and typically support species that do not require access to groundwater to survive.
28 BEST PRACTICE #2. Characterize Seasonal and Interannual Groundwater Conditions SGMA requires GSAs to describe current and historical groundwater conditions when identifying GDEs [23 CCR §354.16(g)]. Relying solely on the SGMA benchmark date (January 1, 2015) or any other single point in time to characterize groundwater conditions (e.g., depth-to-groundwater) is inadequate because managing groundwater conditions with data from one time point fails to capture the seasonal and interannual variability typical of California’s climate. DWR’s Best Management Practices document on water budgets10 recommends using 10 years of water supply and water budget information to describe how historical conditions have impacted the operation of the basin within sustainable yield, implying that a baseline11 could be determined based on data between 2005 and 2015. Using this or a similar time period, depending on data availability, is recommended for determining the depth-togroundwater.

GDEs depend on groundwater levels being close enough to the land surface to interconnect with surface water systems or plant rooting networks. The most practical approach12 for a GSA to assess whether polygons in the NC dataset are connected to groundwater is to rely on groundwater elevation data. As detailed in TNC’s GDE guidance document4, one of the key factors to consider when mapping GDEs is to contour depth-to-groundwater in the aquifer that is supporting the ecosystem (see Best Practice #5).

Groundwater levels fluctuate over time and space due to California’s Mediterranean climate (dry summers and wet winters), climate change (flood and drought years), and subsurface heterogeneity in the subsurface (Figure 3). Many of California’s GDEs have adapted to dealing with intermittent periods of water stress, however if these groundwater conditions are prolonged, adverse impacts to GDEs can result. While depth-to-groundwater levels within 30 feet4 of the land surface are generally accepted as being a proxy for confirming that polygons in the NC dataset are supported by groundwater, it is highly advised that fluctuations in the groundwater regime be characterized to understand the seasonal and interannual groundwater variability in GDEs. Utilizing groundwater data from one point in time can misrepresent groundwater levels required by GDEs, and inadvertently result in adverse impacts to the GDEs. Time series data on groundwater elevations and depths are available on the SGMA Data Viewer13.

However, if insufficient data are available to describe groundwater conditions within or near polygons from the NC dataset, include those polygons in the GSP until data gaps are reconciled in the monitoring network (see Best Practice #6).

Figure 3. Example seasonality
and interannual variability in
depth-to-groundwater over
time. Selecting one point in time,
such as Spring 2018, to
characterize groundwater
conditions in GDEs fails to capture
what groundwater conditions are
necessary to maintain the
ecosystem status into the future so
adverse impacts are avoided.

10 DWR. 2016. Water Budget Best Management Practice. Available at:
https://water.ca.gov/LegacyFiles/groundwater/sgm/pdfs/BMP_Water_Budget_Final_2016-12-23.pdf 11 Baseline is defined under the GSP regulations as “historic information used to project future conditions for hydrology, water demand, and availability of surface water and to evaluate potential sustainable management practices of a basin.” [23 CCR §351(e)]
12 Groundwater reliance can also be confirmed via stable isotope analysis and geophysical surveys. For more information see The GDE Assessment Toolbox (Appendix IV, GDE Guidance Document for GSPs4). 13 SGMA Data Viewer: https://sgma.water.ca.gov/webgis/?appid=SGMADataViewer 29 BEST PRACTICE #3. Ecosystems Often Rely on Both Groundwater and Surface Water GDEs are plants and animals that rely on groundwater for all or some of its water needs, and thus can be supported by multiple water sources. The presence of non-groundwater sources (e.g., surface water, soil moisture in the vadose zone, applied water, treated wastewater effluent, urban stormwater, irrigated return flow) within and around a GDE does not preclude the possibility that it is supported by groundwater, too. SGMA defines GDEs as "ecological communities and species that depend on groundwater emerging from aquifers or on groundwater occurring near the ground surface" [23 CCR §351(m)]. Hence, depth-to-groundwater data should be used to identify whether NC polygons are supported by groundwater and should be considered GDEs. In addition, SGMA requires that significant and undesirable adverse impacts to beneficial users of surface water be avoided. Beneficial users of surface water include environmental users such as plants or animals 14 , which therefore must be considered when developing minimum thresholds for depletions of interconnected surface water.

GSAs are only responsible for impacts to GDEs resulting from groundwater conditions in the basin, so if adverse impacts to GDEs result from the diversion of applied water, treated wastewater, or irrigation return flow away from the GDE, then those impacts will be evaluated by other permitting requirements (e.g., CEQA) and may not be the responsibility of the GSA. However, if adverse impacts occur to the GDE due to changing groundwater conditions resulting from pumping or groundwater management activities, then the GSA would be responsible (Figure 4).

Figure 4. Ecosystems often depend on multiple sources of water. Top: (Left) Surface water and groundwater are interconnected, meaning that the GDE is supported by both groundwater and surface water. (Right) Ecosystems that are only reliant on non-groundwater sources are not groundwater-dependent. Bottom: (Left) An ecosystem that was once dependent on an interconnected surface water, but loses access to groundwater solely due to surface water diversions may not be the GSA’s responsibility. (Right) Groundwater dependent ecosystems once dependent on an interconnected surface water system, but loses that access due to groundwater pumping is the GSA’s responsibility.

14 For a list of environmental beneficial users of surface water by basin, visit: https://groundwaterresourcehub.org/gdetools/environmental-surface-water-beneficiaries/ 30 BEST PRACTICE #4. Select Representative Groundwater Wells Identifying GDEs in a basin requires that groundwater conditions are characterized to confirm whether polygons in the NC dataset are supported by the underlying aquifer. To do this, proximate groundwater wells should be identified to characterize groundwater conditions (Figure 5). When selecting representative wells, it is particularly important to consider the subsurface heterogeneity around NC polygons, especially near surface water features where groundwater and surface water interactions occur around heterogeneous stratigraphic units or aquitards formed by fluvial deposits. The following selection criteria can help ensure groundwater levels are representative of conditions within the GDE area:
● Choose wells that are within 5 kilometers (3.1 miles) of each NC Dataset polygons because they are more likely to reflect the local conditions relevant to the ecosystem. If there are no wells within 5km of the center of a NC dataset polygon, then there is insufficient information to remove the polygon based on groundwater depth. Instead, it should be retained as a potential GDE until there are sufficient data to determine whether or not the NC Dataset polygon is supported by groundwater.
● Choose wells that are screened within the surficial unconfined aquifer and capable of measuring the true water table.
● Avoid relying on wells that have insufficient information on the screened well depth interval for excluding GDEs because they could be providing data on the wrong aquifer. This type of well data should not be used to remove any NC polygons.

Figure 5. Selecting representative wells to characterize groundwater conditions near GDEs. 31 BEST PRACTICE #5. Contouring Groundwater Elevations
The common practice to contour depth-to-groundwater over a large area by interpolating measurements at monitoring wells is unsuitable for assessing whether an ecosystem is supported by groundwater. This practice causes errors when the land surface contains features like stream and wetland depressions because it assumes the land surface is constant across the landscape and depth-to-groundwater is constant below these low-lying areas (Figure 6a). A more accurate approach is to interpolate groundwater elevations at monitoring wells to get groundwater elevation contours across the landscape. This layer can then be subtracted from land surface elevations from a Digital Elevation Model (DEM)15 to estimate depth-to-groundwater contours across the landscape (Figure b; Figure 7). This will provide a much more accurate contours of depth-to-groundwater along streams and other land surface depressions where GDEs are commonly found.

Figure 6. Contouring depth-to-groundwater around surface water features and GDEs. (a) Groundwater level interpolation using depth-to-groundwater data from monitoring wells. (b) Groundwater level interpolation using groundwater elevation data from monitoring wells and DEM data.

Figure 7. Depth-to-groundwater contours in Northern California. (Left) Contours were interpolated using depth-to-groundwater measurements determined at each well. (Right) Contours were determined by interpolating groundwater elevation measurements at each well and superimposing ground surface elevation from DEM spatial data to generate depth-to-groundwater contours. The image on the right shows a more accurate depth-togroundwater estimate because it takes the local topography and elevation changes into account.

15 USGS Digital Elevation Model data products are described at: https://www.usgs.gov/core-sciencesystems/ngp/3dep/about-3dep-products-services and can be downloaded at: https://iewer.nationalmap.gov/basic/ TNC CommentsEastern San Joaquin Subbasin Groundwater Sustainability Plan, Public Draft Complete Executive Summary and Main Report

Page 32 of 33 ends

BEST PRACTICE #6. Best Available Science
Adaptive management is embedded within SGMA and provides a process to work toward sustainability over time by beginning with the best available information to make initial decisions, monitoring the results of those decisions, and using the data collected through monitoring programs to revise decisions in the future. In many situations, the hydrologic connection of NC dataset polygons will not initially be clearly understood if site-specific groundwater monitoring data are not available. If sufficient data are not available in time for the 2020/2022 plan, The Nature Conservancy strongly advises that questionable polygons from the NC dataset be included in the GSP until data gaps are reconciled in the monitoring network. Erring on the side of caution will help minimize inadvertent impacts to GDEs as a result of groundwater use and management actions during SGMA implementation.

ABOUT US
The Nature Conservancy is a science-based nonprofit organization whose mission is to conserve the lands and waters on which all life depends. To support successful SGMA implementation that meets the future needs of people, the economy, and the environment, TNC has developed tools and resources (www.groundwaterresourcehub.org) intended to reduce costs, shorten timelines, and increase benefits for both people and nature.

KEY DEFINITIONS
Groundwater basin is an aquifer or stacked series of aquifers with reasonably welldefined boundaries in a lateral direction, based on features that significantly impede groundwater flow, and a definable bottom. 23 CCR §341(g)(1) Groundwater dependent ecosystem (GDE) are ecological communities or species that depend on groundwater emerging from aquifers or on groundwater occurring near the ground surface. 23 CCR §351(m)
Interconnected surface water (ISW) surface water that is hydraulically connected at any point by a continuous saturated zone to the underlying aquifer and the overlying surface water is not completely depleted. 23 CCR §351(o) Principal aquifers are aquifers or aquifer systems that store, transmit, and yield significant or economic quantities of groundwater to wells, springs, or surface water systems. 23 CCR §351(aa)
TNC CommentsEastern San Joaquin Subbasin Groundwater Sustainability Plan, Public Draft Complete Executive Summary and Main Report

Page 33 of 33 ends

Attachment D
GDE Pulse
A new, free online tool that allows Groundwater Sustainability Agencies to assess changes in groundwater dependent ecosystem (GDE) health using satellite, rainfall, and groundwater data.

Visit
https://gde.codefornature.org/
Remote sensing data from satellites has been used to monitor the health of vegetation all over the planet. GDE pulse has compiled 35 years of satellite imagery from NASA’s Landsat mission for every polygon in the Natural Communities Commonly Associated with Groundwater Dataset16. The following datasets are included:

Normalized Difference Vegetation Index (NDVI) is a satellite-derived index that represents the greenness of vegetation. Healthy green vegetation tends to have a higher NDVI, while dead leaves have a lower NDVI. We calculated the average NDVI during the driest part of the year (July - Sept) to estimate vegetation health when the plants are most likely dependent on groundwater.

Normalized Difference Moisture Index (NDMI) is a satellite-derived index that represents water content in vegetation. NDMI is derived from the Near-Infrared (NIR) and Short-Wave Infrared (SWIR) channels. Vegetation with adequate access to water tends to have higher NDMI, while vegetation that is water stressed tends to have lower NDMI. We calculated the average NDVI during the driest part of the year (July–September) to estimate vegetation health when the plants are most likely dependent on groundwater.

Annual Precipitation is the total precipitation for the water year (October 1st – September 30th) from the PRISM dataset17. The amount of local precipitation can affect vegetation with more precipitation generally leading to higher NDVI and NDMI.

Depth to Groundwater measurements provide an indication of the groundwater levels and changes over time for the surrounding area. We used groundwater well measurements from nearby (<1km) wells to estimate the depth to groundwater below the GDE based on the average elevation of the GDE (using a digital elevation model) minus the measured groundwater surface elevation.

16 The Natural Communities Commonly Associated with Groundwater Dataset is hosted on the California Department of Water Resources’ website: https://gis.water.ca.gov/app/NCDatasetViewer/# 17 The PRISM dataset is hosted on Oregon State University’s website: http://www.prism.oregonstate.edu/ This page is intentionally left blank.

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 Joey Giordano The Wine Group ES‐6 Figure ES‐6
On Figure ES‐6, I would recommend adding the total for each column/section of the bar graph below the text for each section (i.e. "Pumping under Projected Conditions XX,XXX AF". The figure has less value when you have to rely on the units on the y‐ axis rather than having the totals for each section explicitly marked.

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Groundwater Sustainability Plan
Complete Appendices November 2019
APPENDIX 1-J.

RESPONSE TO PUBLIC COMMENTS
Eastern San Joaquin Groundwater Sustainability Plan
Response to Comments – Master Responses
Master Response 1 -- Groundwater Dependent Ecosystems
1) Section 2.2.7 (Groundwater-Dependent Ecosystems) was revised to classify NCCAG areas that access co-occurring surface water as data gap areas requiring further refinement. Section 2.2.7.1 (Methodology for GDE Identification) was updated to better articulate the methodology used and the describe data gaps within the NCCAG dataset. A footnote was added indicating referencing the use of 2015 groundwater levels in the GDE analysis as follows: This analysis uses 2015 groundwater levels (winter, spring, summer, and fall), which may be deeper than representative levels due to drought conditions, a factor which will be considered in future GDEs analyses. Figure 2-74 was updated to show removed NCCAG areas as data gaps.
2) Language was added to Section 4.7 (Data Gaps) to identify NCCAG areas removed through the GDE analysis are data gaps ideas requiring further refinement (NCCAGs that either access co-occurring surface water or were identified as located in an area with groundwater levels deeper than 30 feet bgs).

The purpose of this is to identify potential existing GDEs that may have been incorrectly eliminated through this screening process.
3) Language was added to Section 4.7 (Data Gaps) to indicate that the ESJGWA would evaluate using the GDE Pulse Tool and other tools to monitor GDEs.
4) The GSP includes the list of freshwater species provided by The Nature Conservancy as Appendix 1-G:

Freshwater Species in the Eastern San Joaquin Subbasin as beneficial users of groundwater. Language was added to Section 2.2.7 (Groundwater-Dependent Ecosystems) and Section 4.7 (Data Gaps) to indicate that fish and wildlife species associated with GDEs are a data gap area.

Master Response 2 -- Interconnected Surface Water
1) The ESJGWA recognizes that depletions of interconnected surface water are a data gap area and supports the use of groundwater levels as a proxy, as this represents the best information currently available. The ESJGWA has identified a need for future study and refinement of interconnected surface water and will continue coordination efforts to better inform basin conditions. 2) Language has been added to Section 4.7 (Data Gaps) identifying interconnected surface water as a data gap area for future study and refinement. The section has also been updated to clarify and better articulate the ESJGWA's focus on installing additional monitoring wells near streams, which can be evaluated for use as representative monitoring wells in the future. 3) The GSP identifies areas in the Subbasin that the ESJGWA believes to be interconnected based on the best available information but recognizes that these areas may require additional analysis and will be updated with future model verification and validation efforts. Figures 2-71 and 2-72 were reviewed for consistency based on comments received and the section was reorganized for clarification. Language in Section 2.2.6 (Interconnected Surface Water Systems) was updated to describe gaining and losing streams as “gaining greater than 75% of the time” and “losing greater than 75% of the time” and Figure 2-72 was updated accordingly. Figure 2-71 was updated to display stream nodes gaining most of the time as interconnected and the language was updated to “interconnected greater than 75% of the time” and “interconnected less than 25% of the time.” Language was added to clarify Figures 2-71 and 2-72 in the GSP are showing model results and are not intended for regulatory purposes. A footnote was added to Figures 2-71 and 2-72 stating: Analysis is based on limited data recognized to have significant gaps.

Interconnected surface water is a recognized data gap in the GSP as discussed in Section 4.7. Stream nodes in areas with poor model calibration were removed from Figures 2-71 and 2-72 and text was added to clarify that this data gap will be resolved in future updates to the GSP. 4) Language was added to Section 2.2.6 (Interconnected Surface Water Systems) clarifying that the ESJWRM historical calibration model results represents the best available information for both current and historical conditions related to interconnectivity between surface water and the groundwater system as follows: This analysis was based on modeling results from the historical calibration of the ESJWRM for approximately 900 stream nodes in the Eastern San Joaquin Subbasin, which represents that best available information for current and historical conditions related to interconnected surface water systems.
5) The GSP includes the list of freshwater species provided by The Nature Conservancy as Appendix 1-G:

Freshwater Species in the Eastern San Joaquin Subbasin as beneficial users of groundwater. 6) Language was added to Section 4.7 (Data Gaps) to indicate that the ESJGWA would evaluate using the GDE Pulse Tool and other tools to monitor GDEs.
7) The ESJGWA considers current minimum thresholds and measurable objectives to be protective of beneficial uses and users in the subbasin, and to be protective of existing in-stream flow requirements for fish and wildlife.

Master Response 3 -- Water Quality
1) A new subsection has been added to Section 3.2.3 (Section 3.2.3.4: Monitoring for Additional Constituents), which states that additional monitoring is needed to identify water quality conditions and trends related to additional constituents including arsenic and nitrate. This new subsection references Chapter 4 (Monitoring Networks) and describes the informational monitoring efforts that will take place as part of the broad monitoring network for water quality, and specifically, the monitoring for arsenic and for cations/anions, which includes nitrate. The subsection also references the existing regulations through existing water resources monitoring and management programs (described in Section 1.2.2).

Language has been added to indicate that if existing regulations are violated, or if monitoring efforts indicate concerning trends, the ESJGWA will evaluate developing minimum thresholds and measurable objectives for additional constituents, as well as to take steps to coordinate with regulatory agencies.

Additionally, language has been added stating that the ESJGWA may require GSAs that are drinking water suppliers to report to the ESJGWA if constituents of concern exceed their MCL. While these reports do not reflect the water quality of private well owners, it would provide a useful basin-wide screen to better inform basin groundwater quality.
2) Language has been added to Section 3.2.3.2 (Minimum Thresholds) referencing Section 3.2.3.4 and indicating the monitoring efforts for additional constituents, including nitrate and arsenic. 3) Language was modified in Section 3.2.3.1.1 (Description of Undesirable Results) to indicate new monitoring efforts in the Subbasin that will occur as part of the broad monitoring network for water quality and to highlight coordination efforts with existing regulatory agencies to determine if existing regulatory requirements are met. Language stating no nexus was removed and replaced with language stating that new monitoring efforts and coordination with existing regulatory agencies will allow the GSAs to determine if groundwater pumping activities are contributing to undesirable effects related to degraded water quality.

Master Response 4 -- Groundwater Storage
1) Given the existing subsurface conditions and large volume for groundwater in storage, the historical undesirable effects in the Eastern San Joaquin Subbasin groundwater have been related to accessibility, not storage volume. Thus, the issues associate with groundwater overdraft are more appropriately addressed through the Chronic Lowering of Groundwater Levels Sustainability Indicator. 2) Language was added to Section 3.2.2 (Reduction in Groundwater Storage) to better articulate the model analysis used to determine no undesirable results for Reduction in Groundwater Storage and to show how using groundwater levels as a proxy is protective as follows: An undesirable result occurs when groundwater storage volumes are insufficient to satisfy beneficial uses within the Subbasin. To identify a volume associated with undesirable results, the ESJWRM was run to estimate the volume of groundwater storage needed to meet beneficial uses. The analysis determined that groundwater demand for beneficial use occurs within the shallowest 23 MAF of the Subbasin, as this is roughly the zone corresponding to the depth at which pumping occurs and is reasonably expected to occur in the future. Based on this analysis, 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. Therefore, undesirable results would occur if groundwater storage were reduced by 23 MAF, to a total volume of 30 MAF…Minimum thresholds for groundwater levels will effectively avoid undesirable results for reduction of groundwater storage. As noted above, the amount of groundwater in storage in the Subbasin is approximately 53 MAF and the undesirable results of reducing beneficial uses would not occur until storage is reduced by 23 MAF, to a total of 30 MAF. The ESJWRM was run to estimate the reduction in groundwater storage that would occur if every representative monitoring well in the Subbasin were to operate at the minimum threshold for the chronic lowering of groundwater levels sustainability indicator. The results of this analysis showed that this scenario would result in a reduction of approximately 1.2 MAF of storage.3 Because undesirable results are anticipated to occur following a reduction of 23 MAF, the minimum thresholds for groundwater levels are protective of beneficial uses.

Minimum thresholds and measurable objectives for groundwater levels can therefore be used as a proxy for reduction in groundwater storage, as groundwater levels are sufficiently protective against occurrences of significant and unreasonable reduction in groundwater storage. 3) The ESJGWA acknowledges conditions of overdraft and in response has identified projects that will recharge and/or offset up to 78,000 AFY to meet the Subbasin's sustainable yield. The groundwater storage estimate of 53 MAF is based on current groundwater conditions calculated for years 1996-2015; this estimate does not include future projects implemented as part of this GSP. Sustainable yield is defined in the GSP as “the maximum quantity of water, calculated over a base period representative of long-term conditions in the basin and including any temporary surplus, that can be withdrawn annually from a groundwater supply without causing an undesirable result” (per CWC §10721(w)). Sustainable yield for the Eastern San Joaquin Subbasin was calculated through development of an ESJWRM sustainable conditions scenario (model run) in which the goal was to generate a long-term (50-year) change in Subbasin groundwater storage of zero, a conservative approach, as a change in storage of greater than zero could occur without causing undesirable results.

Master Response 5 -- Projects
1) The ESJGWA acknowledges that many of the projects are in preliminary planning stages. The ESJGWA has a 20-year planning timeframe to bring the projects online, and will continue to evaluate project benefits, impacts, and costs. The ESJWRM was used to calculate basin-scale planning targets based on projected future water demands. There is uncertainty in these estimates, which will be refined in coming years through model updates and verification studies. Further, this GSP is an adaptive plan, driven by annual monitoring reports. The data in these reports, as well as individual GSA-level water budgets, will provide a means of project evaluation, and will assess potential for undesirable results. The three tiers of projects have been developed to respond to the uncertainty in planning targets and provide greater flexibility in how sustainability will be achieved. The Subbasin may need to recharge and/or offset more or less water than the estimated 78,000 AFY to reach sustainability and can pull from the highest benefit and most feasible projects to do so. 2) GSP projects have been proposed by individual GSAs and will be implemented at the GSA level. The ESJGWA's role in project implementation will be to oversee essential coordination and evaluation activities, but the ESJGWA does not have authority to direct project design, timeline, or initiation. 3) A subsection was added to GSP Chapter 6 (Projects and Management Actions) that outlines a process for management actions if the identified projects do not progress, or if monitoring activities demonstrate that the projects are not effective in achieving stated recharge and/or offset targets:

Although the ESJGWA does not provide direct authority to require GSAs to implement projects, the ESJGWA will be working on GSA-level water budgets and will be requesting annual or biannual progress reports to evaluate progress. If the projects do not progress, or if monitoring efforts demonstrate that the projects are not effective in achieving stated recharge and/or offset targets, the ESJGWA will convene a working group to evaluate supply-side and demand-side management actions such as the implementation of groundwater pumping curtailments, land fallowing, etc. 4) The ESJGWA acknowledges that there are many factors that could affect the availability of surface water, and that has to be evaluated by GSAs in the implementation of projects. The process of GSAs providing biannual reports will allow for the ESJGWA to update the Plan and adjust the implementation course as needed based on conditions.
5) Language was added to the GSP referencing existing conservation management actions (including Urban Water Management Plans and Agriculture Water Management Plans). Additionally, language was added to Section 6.2.2 (Project Implementation) to emphasize the pathway toward sustainability:

Projects will be administered by the GSA project proponents. GSAs may elect to implement projects individually or jointly with one or more GSAs or with the ESJGWA. As the ESJGWA develops GSA-level water budgets, the GSAs will have a better understanding of how projects will be implemented at the GSA-level and can better evaluate progress toward completion.

ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 1 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region The Department believes the GSP does not adequately demonstrate consideration of environmental beneficial uses and users of groundwater in its sustainability management criteria nor does It adequately characterize or consider surface water-groundwater connectivity. Accordingly, the Department recommends that ESJ address these deficiencies before submitting the GSP to the Department of Water Resources (DWR).

Interconnected Surface Water
The GSP as written includes the list of freshwater species provided by The Nature Conservancy as Appendix 1-G: Freshwater Species in the Eastern San Joaquin Subbasin as beneficial users of groundwater. 2 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region

1.2.1.1 Department lands are excluded from 'Summary of Jurisdictional Areas' narrative as well as from Figure 1-11, which maps other federal and state lands.a. Issue: The GSP does not identify the jurisdictional boundaries of Department-owned and -managed lands as required by 23 CCR §354.8(a)(3).b. Recommendation: Include in Figure 1-11 and the accompanying narrative White Slough Wildlife Area, Woodbridge Ecological Reserve, and Vernalis Ecological Reserve Department lands.

Plan Area
Edits made to Figure 1-11 to include White Slough Wildlife Area, Woodbridge Ecological Reserve, and Vernalis Ecological Reserve Department lands. Added text to Section 1.2.1 (Description of Plan Area) to describe these areas: The California Department of Fish and Wildlife (CDFW) owns 880 acres of man-made ditches, canals, and marshes with both grassland and riparian habitat, recognized as the White Slough Wildlife Area. The property was designated by the Fish and Game Commission in 1980 and provides recreational opportunities such as fishing, hunting, and hiking (CDFW, 2019a). CDFW also maintains the 353-acre Woodbridge Ecological Reserve to protect primarily the sandhill crane population, but also other migratory waterfowl. The sandhill crane was listed as a threatened species in 1983. Woodbridge Ecological Reserve and the greater Stockton Delta wetlands make up the largest freshwater marsh in California (CDFW, 2019b). Lastly, Vernalis Ecological Reserve is also shown in Figure 1-11. It serves as a public access area owned by CDFW for hunting and wildlife viewing (CDFW, 2019c).
3 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region

2.2.6 The narrative describing the basin's interconnected surface water conditions lacks specifics and contains inconsistencies in mapped surface water-groundwater interconnectivity.a. Issue:i. The interconnected surface water conditions narrative lacks estimations of the quantity and timing of streamflow depletions as specified in 23 CCR § 354.16(f).ii. Figure 2-65 portrays modeled 'losing,' 'gaining,' and 'mixed' stream reaches, and Figure 2-66 portrays modeled 'interconnected and 'disconnected' streams. Figure 2-66 shows modeled stream reaches as 'disconnected,' whereas Figure 2-65 identifies those same reaches as switching between 'losing,' 'gaining,' and 'mixed.' Accompanying narrative suggests that streams are only mapped as 'interconnected' in Figure 2-66 when they are interconnected at least 75% of the time. This 75% threshold for displaying interconnected surface waters excludes reaches of stream that are intermittently connected to groundwater and that may depend on groundwater contributions to meet the needs of instream or riparian beneficial uses and users of interconnected surface waters. b. Recommendation:i. Identify the estimated quality and timing of streamflow depletions in the ESJ Subbasin. If this information is not available, identify an expeditious path to estimating these values.ii. Update Figure 2-66 to show all interconnected stream reaches, even if they are interconnected less than 25% of the time.

Interconnected Surface Water See Master Response 2 - ISW. 4 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region

2.2.7 GDE identification, required by 23 CCR § 354.16(g), is based on methods that risk exclusion of ecosystems that may depend on groundwater.a. Issue: Methods applied to the Natural Communities Commonly Associated with Groundwater (NCCAG) dataset to eliminate potential GDEs are fallible. i. Depth to Groundwater: The removal of potential GDEs with a depth to groundwater greater than 30 feet during (an unspecified season) of 2015 relies on a single-pointin-time baseline hydrology. Specifically, this 2015 baseline falls several years into a historic drought when groundwater levels throughout the San Joaquin Valley were trending dramatically lower than usual due to reduced surface water availability. Exclusion of potential GDEs based on a snapshot of groundwater elevations during a historic drought is invalid; because this approach does not consider representative climate conditions or account for GDEs that can survive a finite period of time without groundwater access (Naumburg 2005), but that rely on groundwater table recovery for long term survival.ii. Adjacent to Alternate Water Supplies: The GSP notes that "to be dependent on groundwater there must not be other available water supplies" (GSP pp 2-104). This statement disregard's a GDE's adaptability and opportunistic approach to accessing water in which vegetation may vary reliance on surface water and groundwater between seasons and water years. Therefore, the removal of potential GDEs that are within 50 feet of irrigated lands, 150 feet of managed wetlands, and 150 feet of perennial surface water does not consider the potential for GDEs shifting reliance between surface and groundwater. Additionally, vegetation near interconnected perennial surface waters may depend on sustained groundwater elevations to stabilize the gradient or rate of loss of surface water; meaning ecosystems near interconnected surface waters likely depend on sustainable groundwater elevations and constitute GDEs. Therefore, it is possible that any of these potential GDEs proximate to 'alternate water supplies' rely on groundwater during specific seasons or water years.b. Recommendations:i. Depth to Groundwater: Develop a hydrologically robust baseline from which to remove areas with a depth to groundwater greater than 30 feet' that relies on multiple, climatically representative years of groundwater elevation and that accounts for the inter-seasonal and inter-annual variability of GDE water demand. ii. Adjacent to Alternate Water Supplies: Reevaluate potential GDEs previously removed due to proximity to irrigated lands, managed wetlands, and perennial surface waters. Err on the side of inclusivity until there is evidence that the overlying ecosystem has no significant dependence on groundwater across seasons and water year types. Ensure that riparian GDE beneficial users of groundwater and interconnected surface water are carefully considered in the analysis of undesirable results and minimum thresholds for depletions of interconnected surface waters.

GDEs See Master Response 1 - GDEs.
5 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region

2.3.5.4 Projected water budget assumptions may risk overestimating surface water availability and sustainable yield by not relying on best available information [23 COR § 354.18(e)].a. Issue: Projected surface water budget assumptions may risk overestimating water availability. Overestimation of water availability can result in the overallocation of both surface and groundwater water resources, unnecessarily jeopardizing environmental beneficial users. Two water budget assumptions that do not rely on best available information and that underscore current sustainable yield estimations are as follows: 1) the climate change analysis predicting a net depletion of aquifer storage is not reflected in the projected water budget or estimated sustainable yield, rather it is presented as a separate analysis; and 2) projected surface water deliveries need to be updated to reflect any new regulatory reductions of surface water deliveries such as those that may be codified in the State Water Resources Control Board Water Quality Control Plan for the Bay Delta: San Joaquin River Flows and Southern Delta Water Quality.b. Recommendation: Amend the water budget and sustainable yield: 1) apply climate change estimates to the projected water budget and scale the sustainable yield accordingly; and 2) adjust surface water delivery estimates to reflect any new regulatory compliance.

Water Budget
1) Consistent with regulations, the 2070 climate change sensitivity analysis on the projected conditions scenario was used to better understand trends and inform planning. Due to the uncertainty around climate projections in the 2070 timeframe, the ESJGWA Board determined the projected conditions scenario was most appropriate for analyzing sustainable yield in the GSP implementation time period beginning in 2040. Therefore, the sustainable yield analysis did not include climate change. Comment noted for follow up in next round of model refinements and updates to analyses. 2) Added text to Section 2.3.5 (Water Budget Estimates) clarifying that climate change was a separate scenario: “Hydrology under climate change projections was evaluated in a separate ESJWRM scenario and results are discussed separately in Section 2.3.7.4.” 3) Added text to Section 2.3.6 (Sustainable Yield Estimate) clarifying that climate change was not part of the analysis: “The sustainable conditions scenario, building off the projected conditions scenario, does not include climate change discussed in Section 2.3.7. Due to the uncertainty around DWR’s climate projections for a 2070 timeframe, the ESJGWA Board determined the projected conditions scenario was most appropriate for analyzing sustainable yield in the GSP implementation time period beginning in 2040.” 4) The SWRCB did adopt the water quality control plan for the Bay-Delta, which has an impact on the Subbasin and will be addressed in future updates to the GSP. Given the timeframe of the GSP being adopted, it was not possible to include the new regulations in the analysis in this GSP and they will be included in future iterations. 1 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment Interconnected Surface Water 6 Kevin Thomas See Master Response 2 - ISW.

CA Department of Fish and Wildlife, North Central Region

3.2.1 Groundwater Level and Interconnected Surface Water sustainable management criteria do not protect against undesirable results for fish and wildlife beneficial uses and users of groundwater and interconnected surface waters.a. Issues:i. Proxy Metric: Before addressing the individual sustainability criteria for both Groundwater Levels and Depletions of Interconnected Surface Water, the Department challenges the use of groundwater elevations as a proxy metric for Depletions of InterconnectedSurface Water. The GSP does not provide evidence that a "significant correlation exists between groundwater elevations" and Depletions of Interconnected Surface Water [23 OCR §354.36(b)(1)]. Instead, the GSP backs into the proxy metric by associating the proposed Groundwater Level minimum thresholds with the absence of significant and unreasonable surface water depletions, claiming that historical depletions of interconnected surface water had no associated undesirable results (GSP pp 3-19). The GSP offers few details to substantiate this claim that historical surface water depletions did not lead to undesirable results, and the GSP does not specify the modeling exercise used to detennine the insignificance of historical surface water depletions. Provided the status of surface water allocations and aquatic ecosystems on rivers in the ESJ basin, the Department contests that any surface water depletions attributable to groundwater pumping are likely to be significant and unreasonable, particularly in the benchmark year of 2015 when groundwater pumping and surface water temperatures were critically high. Depleted flows in the lower San Joaquin River, many reaches of which are identified as interconnected in the GSP, contribute to increased in-river water temperatures. Groundwater extraction from interconnected aquifers contributes to depletion of instream flow(Barlow and Leake, 2012). Low flows and increased water temperatures in the lower San Joaquin River have been documented to negatively impact Chinook salmon {Oncorhynchustshawytscha) and steelhead {Oncorhynchus mykiss) (Hallock 1970,Marston 2012). Acknowledging that fish and wildlife beneficial uses and users of groundwater likely experienced undesirable results during historical pumping regimes, especially during critically dry years, the GSP cannot rely on groundwater elevation as a proxy metric for Depletions of Interconnected Surface Water. If a significant correlation is lacking between groundwater elevations and Depletions of Interconnected Surface Water, particularly at the representative monitoring well locations used to track groundwater elevations in the ESJ Subbasin, then groundwater elevations used as a proxy for surface water depletions may misinform groundwater management activities and poorly predict instream habitat conditions for fish and wildlife species. Accordingly, the application of Groundwater Level sustainable management criteria to Depletions of Interconnected Surface Water is inappropriate, as it is not grounded in a quantifiable and site-specific understanding of surface water-groundwater connectivity as required by 23 CCR § 354.28 (c)(6)(A).ii. Undesirable Results: Groundwater Level 'undesirable results' and 'effects of undesirable results' do not specify impacts to environmental beneficial users such as terrestrial GDEs (GSP pp 3-3, 3-4). Additionally, the method used to identify undesirable results for Groundwater Levels (i.e., minimum threshold exceedances in groundwater elevation) is applied to the identification of undesirable results for the Depletions of Interconnected Surface Water without a reasonable justification. The indicator of undesirable results for Groundwater Levels is the measure of 25% of monitoring wells falling below their minimum thresholds for two consecutive (non-dry) years, yet the GSP does not prove a relationship between the Groundwater Level identification of undesirable results and the presence of undesirable results for Depletions of Interconnected Surface Water (see Comment #5.a.i). Effectively, the GSP does not connect identification of undesirable results for Depletions of Interconnected Surface Water to effects on interconnected surface water beneficial users per 23 CCR § 354.26 (b)(3). Finally, the GSPnotes that groundwater levels that fall below the minimum threshold during hydrologically dry or critically dry years are not considered to be an indicator of undesirable results (GSP pp 3-3). This means proposed Indicators of undesirable results for Groundwater Levels and Depletions of Interconnected Surface Water do not exist for dry water years. This absence of undesirable results indicators for certain water years means beneficial users of groundwater and interconnected surface water may experience significant and unreasonable effects throughout the duration of dry or critical water years before the undesirable results are 'identified' and managed. Accordingly, there is no groundwater management accountability during the most challenging of years for water resource managers and fish and wildlife beneficial users alike.iii. Minimum Thresholds and Measurable Objectives: Minimum thresholds and measurable objectives for Groundwater Levels, and by proxy, for Depletions of Interconnected Surface Water, are not protective of environmental beneficial uses and users of groundwater and interconnected surface water. Minimum thresholds allow for a decrease of groundwater elevation from 2015, or a comparable historic low, for all representative monitoring sites (3-7); and measurable objectives are set at historically low groundwater elevations (GSP 3-8). These sustainability criteria suggest that groundwater elevations at all representative wells in the ESJ Subbasin can continue to decrease for the next 20 years, dropping further from historically low groundwater elevations during drought years, without witnessing undesirable results.

The ESJ Subbasin is characterized by DWR as 'Critically Overdrafted,' meaning "continuation of present water management practices [in the basin] would probably result in significant adverse overdraft-related environmental, social, or economic impacts" ("Critically"). However, according to the GSP, there are no areas within the basin that are considered to have 'significant and unreasonable existing issues' (GSP pp 3-4), therefore minimum thresholds allow for continued groundwater depletions. Conceptually, there is a disconnect between the ESJ's 'Critically Overdrafted' designation and the GSP's claim that the basin has not experienced undesirable results, nor will it if groundwater levels continue to decrease. More specifically, the Department believes historical declines in terrestrial and aquatic groundwater dependent ecosystem viability, exacerbated by recent drought years, are evidence of undesirable results and further groundwater decline will undoubtedly lead to significant and unreasonable effects on fish and wildlife beneficial uses and users of groundwater and interconnected surface waters under the proposed sustainable management criteria. For example, further streamflow depletion attributable to groundwater pumping that lowers groundwater levels to meet minimum thresholds or even measurable objective may further compromise in-stream temperature targets in the lower San Joaquin River, adversely impacting in-stream species (see Comment #5.a.i). Accordingly, the Department does not believe groundwater levels above the proposed minimum thresholds and below the proposed measurable objectives (in the margin of operational flexibility) will allow the basin to achieve sustainability,particularly with respect to avoiding undesirable results for fish and wildlife beneficial uses and users of groundwater and Interconnected surface water.b. Recommendation:i. Proxy Metrics: To justify use of groundwater elevations as a proxy metric for Depletions of Interconnected Surface Water, the GSP should either specify how groundwater elevations are significantly correlated to surface water depletions; or define an expeditious path to identifying the location, quantity, and timing of surface water depletions caused by groundwater use, per 23 CCR §354.28(c)(6)(A), to better inform sustainability criteria for Depletions of Interconnected Surface Water. ii. Undesirable Results: Specify Groundwater Level 'undesirable results' and 'effects of undesirable results' for environmental beneficial users of groundwater and interconnected surface water. Specify undesirable result indicators for Depletions of Interconnected Surface Water that are relevant to beneficial users of surface waters. Identify undesirable results indicators for dry and critically dry water years for all sustainability indicators.iii. Minimum Thresholds and Measurable Objectives: Reconsider minimum thresholds and measurable objectives, accounting for undesirable results for fish and wildlife beneficial uses and users of groundwater and interconnected surface water. Design sustainable management criteria that reflect a 'Critically Overdrafted' subbasin designation by seeking to improve current groundwater conditions rather than allowing for continued aquifer depletions over the next two decades. For example, historical groundwater pumping has likely contributed to stream disconnection illustrated in figure 2-66 (GSP 2-99); resulting in depleted stream flows and reduced baseflows in ESJ Subbasin tributaries, and exacerbated high water temperatures in the lower San Joaquin River that negatively impact listed species such as the Chinook Salmon. Minimum thresholds and measurable objectives should reflect an effort to prevent further degradation to interconnected surface waters and to avoid undesirable results, rather than risk magnifying historical undesirable results through lowered groundwater elevations. 2 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 7 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region

3.6 The GSP wrongly abdicates responsibility for specific constituents by implying there is no nexus between specific groundwater contaminants and groundwater pumping (GSP pp 3-11).a. Issue. The GSP identifies two primary water quality constituents of concern in the ESJ Subbasin: salinity and arsenic (GSP pp 2-76). The GSP only specifies sustainability management criteria for salinity. The GSP explains that other constituents, including arsenic, are managed through other regulatory programs, and suggests that because GSAs do not have land use authority, they lack an ability to manage for such constituents as arsenic (GSP pp 3-11). Science suggests that over-pumping of aquifers can cause clay layers to compress and release dissolved arsenic, resulting in an increase of arsenic in extracted water ("Groundwater"). Thus, groundwater pumping actions can affect the presence, movement, and concentration of naturally oncoming arsenic in groundwater, potentially increasing anthropogenic and ecosystem exposure to arsenic contamination. According to SGMA statue, GSAs have the authority to establish groundwater extraction allocations, among other relevant authorities [WC § 10726.4]. Because arsenic contamination can be impacted by groundwater pumping, and because GSAs have the authority to manage groundwater pumping, the ESJGWA has a viable management lever over arsenic contamination in the ESJ Subbasin. b. Recommendation: Draft a plan to investigate the relationship between groundwater pumping and the presence, movement, and concentration of arsenic in the ESJ Subbasin and include the plan in the GSP submitted to DWR by January 2020. Develop sustainability criteria for arsenic accordingly and in partnership with existing regulatory programs by the first 5-year GSP update due in January 2025.

Groundwater Quality See Master Response 3 -- Water Quality. 8 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region Monitoring Networks
Number and distribution of groundwater monitoring wells are insufficient for analysis.a. Issue: The current monitoring network lacks a sufficient number and representative distribution of shallow groundwater monitoring wells to monitor impacts to environmental beneficial uses and users of groundwater and interconnected surface waters [23 CCR § 354.34(2)], Few wells are near interconnected surface waters or concentrations of ] GDEs; and therefore, there are few data points on shallow groundwater level trends. These data are critical to understanding groundwater management impacts on fish and wildlife beneficial uses and users of groundwater, including GDEs and interconnected surface water habitats, that are impacted disproportionately by shallow groundwater trends.b. Recommendation: Install additional shallow groundwater monitoring wells near GDEs and interconnected surface waters, potentially pairing multiple-completion wells with streamflow gauges for improved understanding of surface water-groundwater interconnectivity.

Monitoring Network
Data gaps are discussed in Section 4.7 (Data Gaps) and include identified gaps in the monitoring and analysis of interconnected surface waters and GDEs. The GSP includes a plan for the drilling of up to 12 proposed wells to help resolve identified gaps and enhance future analysis of interconnected surface waters and GDEs. These proposed wells would all measure for both groundwater quality and groundwater levels and include 2 deep, nested wells funded under the TSS application and up to 10 shallow wells drilled by the ESJGWA. If a need for more detail is recognized, the monitoring network will be reevaluated as updates to the GSP occur. Frequency of groundwater level monitoring is cited in the Draft Monitoring Networks and Identification of Data Gaps Best Management Practice. While semi-annual monitoring is required for groundwater levels, DWR guidance recommends monthly sampling of groundwater levels for the Subbasin based on aquifer type, volume of long-term aquifer withdrawals, and recharge potential. The ESJGWA Board determined semi-annual sampling was appropriate as it will capture seasonal highs and lows and that additional monitoring would not necessarily provide additional information on trends. 9 Kevin Thomas
CA Department of Fish and Wildlife, North Central Region

6.1 Demand reduction management actions lack emphasis and specificity critical to ESJ Subbasin sustainability goal achievement.a. Issue: The GSP project and management actions focus on supply augmentation, with only three projects intended to conserve groundwater through metering and systems optimization. Though the GSP reserves the flexibility to implement demand-side management In the future (GSP pp 6-1), there are no specifics as to how the ESJGA would implement demand management. This lack of specificity on how demand will be managed may lead to deprioritization or delayed implementation of demand management actions, which can undermine a basin's ability to achieve sustainability goals. Considering the ESJ Subbasins' current unsustainable rate of groundwater consumption and considering the cost and timing challenges associated with supply augmentation projects, a balanced portfolio approach to achieve groundwater sustainability should Include demand-management strategies.b. Recommendation: Add specific measures for initiating demand reduction on an earlier timeline in the ESJ Subbasin to account for groundwater pumping lag Impacts, supply-augmentation project implementation challenges, and a scaled ramping-down of groundwater use that is a necessary ingredient in San Joaquin Valley long-ten groundwater sustainability. Be specific about triggers, timing, and expected outcomes of demand-management actions.

Projects and Management Actions See Master Response 5 - Projects. 10 Bill Mattos California Poultry Federation CFP commends the Draft GSP for emphasizing projects to augment yield and increase recharge. Projects and Management Actions See Master Response 5 - Projects.11 Tom Lippe California Sportfishing Protection Alliance n/a The Plan does not satisfy GSP Rule 355.4(b)(1) because the Plan’s description of the sustainability goal, undesirable results, minimum thresholds, measurable objectives, and interim milestones are not reasonable or supported by the best available information and best available science. Sustainable Management Criteria The ESJGWA has determined that the plan is supported by the best available data and science with extensive input from stakeholders, GSAs, and agencies. 12 Tom Lippe California Sportfishing Protection Alliance n/a The Plan does not satisfy GSP Rule 355.4(b)(3) because the sustainable management criteria and projects and management actions identified in the plan are not commensurate with the level of understanding of the basin setting, based on the level of uncertainty, as reflected in the Plan. Sustainable Management Criteria The ESJGWA has determined that the plan is supported by the best available data and science with extensive input from stakeholders, GSAs, and agencies.13 Tom Lippe California Sportfishing Protection Alliance n/a The Plan does not satisfy GSP Rule 355.4(b)(5) because the Plan does not contain or present substantial evidence to conclude that the projects and management actions identified to achieve sustainable yield are effective or feasible or not likely to prevent undesirable results or to ensure that the basin is operated within its sustainable yield. Projects and Management Actions See Master Response 5 - Projects.14 Greg Kamman California Sportfishing Protection Alliance Section 2.1.9.2.2 Section 2.1.9.2.2 of the GSP (page 2-49) is entitled, Regional Historic Groundwater Flow and Surface Water Interaction. There is no presentation or reference to historic groundwater interaction with surface water in this section of the GSP. Basin Setting Added text to Section 2.1.9.2.2 (Regional Historic Groundwater Flow and Surface Water Interaction) referring to where historic groundwater-surface water interaction is discussed: Historical groundwater-surface water interaction in the context of the twenty years of the historical model (ESJWRM) is discussed in Section 2.2.6.15 Greg Kamman California Sportfishing Protection Alliance Section 2.2.6 Section 354.16 of the GSP Regulations stipulates that each plan describe current and historic groundwater conditions in the basin based on the best available information. With regard to Section 2.2.6 of the GSP.(Interconnected Surface Water Systems), I would like you to be aware of a study completed by Kamman Hydrology & Engineering, Inc. in 2018 , which delineates subterranean streams and Potential Stream Depletion Areas (PSDA) along the Stanislaus River bordering the south side of the ESJGB. PSDA’s are areas where groundwater pumping could potentially cause stream depletion. This report and associated maps are attached for reference and integration into Section 2.2.6 of the GSP. Access KHE's 2018 report at this link: https://www.dropbox.com/s/zzqnn6ifsbahx5p/PSDA-mapping-TechMemorandum_v1%2Bquads.pdf?dl=0 Basin Setting
Thank you for providing the report. Interconnected surface water was discussed at the scale of the Eastern San Joaquin Subbasin in Section 2.2.6, though the figures show more individual stream results. Comment noted for follow up and comparison as analysis of stream-aquifer interaction continues in future GSP updates. 16 Greg Kamman California Sportfishing Protection Alliance Section 2.2.6 Section 2.2.6 of the GSP (page 2-97 to 2-99) also introduces Figure 2-65 (attached as Exhibit A), which shows gaining streams in blue where groundwater discharges to rivers, losing streams in red where streams lose water to the groundwater system, and mixed streams (gaining or losing less than 75 percent of the time) in orange. This analysis was based on modeling results from the historical calibration of the East San Joaquin Water Resources Model (ESJWRM) for approximately 900 stream nodes in the Eastern San Joaquin Subbasin. The historical model calibration period covers the water years 1996-2015. Based on the Cumulative Departure from Mean Precipitation curve presented in Figure 2-71 (pg. 2-109 of GSP), the years 1996-2015 reflect a dry period, as there is a net decrease in approximately 17-inches of precipitation (i.e., change from +7 [1996] to -10 inches [2015] in the cumulative departure curve). This section of the GSP only presents a description of historical (and dry) interconnected surface water conditions. Section 354.16 of the California Code of Regulations (Regulations) stipulates that each Plan shall provide a description of current and historical groundwater conditions in the basin. The GSP fails to describe the current conditions of the interconnected surface water system in the basin.

Interconnected Surface Water See Master Response 2 - ISW. 3 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 17 Greg Kamman California Sportfishing Protection Alliance Section 2.2.6 Section 2.2.6 of the GSP (Interconnected Surface Water Systems; page 2-97 to 2-99) also presents Figure 2-66 (attached as Exhibit B), which is entitled, Interconnected and Disconnected Streams. The GSP states that Stream connectivity was analyzed by comparing monthly groundwater elevations from the historical calibration of the ESJWRM to streambed elevations along the streams represented in the ESJWRM. Exhibit B shows the locations where streams are interconnected at least 75 percent of the time (shown in blue) or disconnected (shown in green). Section 351 of the Regulations defines “interconnected surface water” as surface water that is hydraulically connected at any point by a continuous saturated zone to the underlying aquifer and the overlying surface water is not completely depleted. The GSP (pg. 2-97) states that interconnected surface waters may be either gaining or losing, wherein the surface water feature itself is either gaining water from the aquifer system or losing water to the aquifer system. Exhibit C (attached) is taken from DWR’s water budget BMP guidance document and illustrates the relationship between surface water and groundwater for gaining, losing and disconnected streams. Per this diagram, for a stream to be gaining, it must be hydraulically connected to the aquifer. In many instances, a losing stream may also be in hydraulic connection to the aquifer. Losing streams may become disconnected seasonally or during drought periods in response to a falling water table. There are inconsistencies between the results presented in Exhibits A and B where areas delineated as gaining streams are also identified as being disconnected. A good example of this is the upstream portion of the Stanislaus River located in the southeast corner of the basin. These inconsistencies should be corrected or explained. In addition, the stream connectivity presented in Exhibit B is for historic conditions – the current conditions should also be presented per Regulations.

Interconnected Surface Water See Master Response 2 - ISW. 19 Greg Kamman California Sportfishing Protection Alliance Section 2.3.6 One of the most important outcomes of the GSP is the determination of sustainable yield (sustainability goal) for the basin. Section 2.3.6 (pg. 2-133) of the GSP states that, “The sustainable conditions scenario is based on the projected conditions scenario modified by lowering groundwater production across the model domain.” This section of the GSP then provides some qualitative statements about future supplies, demands and uncertainties in water budget assumptions and numerical modeling. Although the sustainable yield of the basin is determined to be 715,000 AF/yr +/- 10 percent, and a 78,000 AF/yr reduction in groundwater use is needed to achieve sustainability, there is no detailed explanation on how these numbers were determined. Per Section 354.24 of the GSP Regulations, “The Plan shall include a description of the sustainability goal, including information from the basin setting used to establish the sustainability goal, etc.” As written, the GSP does not provide the reader with a clear and detailed explanation on how the sustainable yield figure was derived and if climate change predictions were factored into the quantification. This omission makes it impossible to review and comment on the reliability of the sustainable yield or required reduction figures for the basin under existing or future conditions. Therefore, the draft GSP should be revised to include this information and recirculated for public comment.

Water Budget
1) The text in 2.3.6 (Sustainable Yield Estimate) includes a description of how sustainable yield was estimated using ESJWRM. The analysis of sustainable yield involved simulations on the projected conditions scenario lowering groundwater production across the model domain to achieve a long-term change in storage of, or very close to, zero. 2) The ESJGWA Board determined the projected conditions scenario was most appropriate for analyzing sustainable yield in the GSP implementation time period beginning in 2040. Consistent with regulations, the 2070 climate change sensitivity analysis on the projected conditions scenario was used to better understand trends and inform planning. Therefore, the sustainable yield analysis did not include climate change. Comment noted for follow up in next round of model refinements and updates to analyses. 18 Greg Kamman See Master Response 1 - GDEs. California Sportfishing Protection Alliance Sections 2.2.7, 2.2.8, and 2.2.9 The GSP Regulations define “groundwater dependent ecosystem” (GDE) as ecological communities or species that depend on groundwater emerging from aquifers or on groundwater occurring near the ground surface. Section 354.16 of the Regulations stipulate that Plans identify (current and historic) GDEs within the basin, utilizing data available from the Department, as specified in Section 353.2, or the best available information. As stated on page 2-100, the GSP identifies GDEs within the Subbasin based on determining the areas where vegetation is dependent on groundwater. The GSP presents a methodology where the Natural Communities Commonly Associated with Groundwater (NCCAG) database, developed by DWR, CDFW and The Nature Conservancy (TNC), is used to identify vegetation communities and wetlands that are dependent on groundwater. Figure 2-67 of the GSP (attached as Exhibit D) presents the NCCAG within the basin. The GSP then describes a methodology by which NCCAG’s with alternate water supplies are excluded from consideration as GDEs based on the following criteria: a. Depth to groundwater greater than 30 feet; b. areas within 150 feet of managed wetlands that receive supplemental water; c. areas within 50 feet of irrigated agriculture; d. areas within 150 feet of perennial surface water bodies, and e. areas removed based on stakeholder comment.The resulting areas identified as GDEs within the basin based on these criteria are shown in Figure 2-69 of the GSP (attached as Exhibit E).

There are two major problems with the GSP’s method for delineation of GDEs. First, the GSP method only considers the presence of vegetation communities and wetlands in the determination. GSP Regulations stipulate that “species” dependent on groundwater should also be considered. Thus, the analysis should also take into consideration the presence of fish and wildlife species that rely on riparian wetlands and/or flow in rivers influenced by gaining reaches. The Nature Conservancy refers to these species as Environmental Surface Water Beneficial Users and has prepared a list of freshwater species located within each groundwater basin in California. These lists are posted at their website specifically for GSAs and others to better evaluate the impacts of groundwater management on environmental beneficial users of surface water in GSPs. This best available science should be integrated into the determination of GDEs.The second problem I see in the GSP methodology is the failure to acknowledge that GDEs may depend on shallow groundwater regardless of the presence of alternative water sources. For example, wetlands within or adjacent to irrigated agriculture may not rely on that irrigation for survival; if they did, we would expect to find wetlands growing in all irrigated lands. In addition, the presence and sustainability of perennial surface water in Central Valley Rivers is controlled by many factors (e.g., groundwater inflow, reservoir operations, irrigation drainage, etc.). Modeling results presented in the GSP indicate significant contributions of groundwater flow to “gaining” reaches of the Stanislaus River (see Exhibit A). The riparian and wetland vegetation bordering these gaining reaches are surely sustained to some degree by this groundwater inflow to the river and the shallow groundwater conditions that likely accompany gaining reaches. The interconnected condition is also likely influenced significantly by seasonal and long-term wet and dry cycles. However, the GSP does not quantify the relative spatial or temporal contributions of groundwater supply to riparian habitats. Instead, the GPS simply dismisses these habitats as GDE’s under the assumption that perennial flow is sustained through the summer by agricultural deliveries or tailwater. Therefore, it is my opinion that the process of elimination of GDEs as presented in the GSP is seriously flawed and does not correctly recognize or delineate GDEs in the basin.

GDEs
4 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 21 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The GSP does not currently provide clear information on how and to what extent DAC members rely on groundwater. For example: how much of the population relies on private domestic wells for drinking water? How much of the population relies on small community water systems and where are those systems located? Are those community water systems solely depending on groundwater? How many connections do the small water systems serve? This information is valuable for the reader to understand the scale of the vulnerable population dependent on groundwater for drinking water. [SEE MORE SPECIFICS IN COMMENT LETTER] DACs
1) DAC areas are mapped in Figure 1-8 in Section 1.2.1. The density of domestic wells are mapped in Figure 1-12. 2) An appendix has been added to the GSP which documents the 432 community water systems that received hard copy outreach materials throughout the GSP development process. Section 1.3.4.4 (Stakeholder Database) was updated to list the dates that outreach materials were mailed to community water systems. An analysis was performed to map community water systems that are DAC or SDAC areas, and the results of this analysis are presented in the added appendix. The appendix lists the number of connections served by each system. 3) Section 1.3.1 (Beneficial Uses and Users in the Subbasin) was updated to include community water systems and reference the added appendix. 4) Language was added to Section 1.3.4.5 (Stakeholder Education and Outreach) indicating that many GSAs conducted local outreach within their jurisdiction, including direct mailings to parcels served as part of a small water system. 22 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Although the GSP identifies declining water quality trends for arsenic and nitrate in the basin, which meet the GSP’s definition of undesirable results for water quality, no MOs or MTs are set for these constituents. The concentration of these constituents can be impacted by management actions. [SEE MORE SPECIFICS IN COMMENT LETTER] Groundwater Quality See Master Response 3 -- Water Quality. 23 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The GSP notes plans to coordinate and share data with other regulatory monitoring programs, but does not explain how this coordination will improve sustainability with respect to water quality within the basin. The GSP should identify a clear plan for addressing all groundwater constituents that are contributing to the undesirable results of degraded groundwater quality, including those for drinking water users. [SEE MORE SPECIFICS IN COMMENT LETTER] Groundwater Quality See Master Response 3 -- Water Quality. 24 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Caswell Memorial State Park is incorrectly referred to as being located outside the Eastern San Joaquin Subbasin. [SEE MORE SPECIFICS IN COMMENT LETTER] Clarifying Edit Caswell Memorial State Park is within the Subbasin. Section 1.2.1 (Description of Plan Area) includes text that it is the only state park within the Eastern San Joaquin Subbasin boundary. 25 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Figure 1-11
The authors referred to the San Joaquin County General Plan documents, including background reports, for information regarding these important resources. These potential beneficial groundwater users should be described in the text on pp. 1-18 and shown in Figure 1-11. Please include a description recognizing all of the protected areas in the Subbasin and their beneficial groundwater uses. [SEE MORE SPECIFICS IN COMMENT LETTER] Plan Area Comment noted. This information is beyond the scope of the GSP. Consider for inclusion in future updates to the GSP. 26 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

2.2.8 Section 2.2.8 includes a geospatial analysis that removes managed wetlands from consideration as GDEs. The managed wetlands in the Subbasin should be identified in this section. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs Comment noted for potential inclusion in future update to the GSP. Figure 2-68 was updated to show removed NCCAG areas (including managed wetlands in pink) as data gaps. These identified wetlands were reviewed with local water managers to verify supplemental water deliveries. 27 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Ongoing stakeholder engagement and inclusion throughout the GSP implementation process will be crucial to ensuring that the needs of the most vulnerable beneficial users in the basin are met. [SEE MORE SPECIFICS IN COMMENT LETTER] Outreach This has been noted as a future item for consideration as the GSAs move into GSP implementation. 20 Greg Kamman California Sportfishing Protection Alliance Section 6.2.3 Because the Subbasin is in overdraft, the GSP has identified 23 projects to reduce overdraft conditions and meet long-term water demands and sustainability goals. There are some projects focused on conservation and reuse of reclaimed water, but the majority simply reduce local groundwater demand by providing access to surface water supplies. These projects are limited in geographic area and are intended to provide local solutions. However, from the perspective of a full basin water budget, shifting the reliance from groundwater to surface water supplies may not generate the full benefits anticipated as provided in the project descriptions. This is because diverting and reducing stream flows will lead to reductions in groundwater recharge in other areas within or beyond the basin, via reduced water available for stream infiltration or other uses of stream diversions that contribute to recharge. As required in Section 354.44 of the Regulations, the GSP does not provide a full and comprehensive quantification of demand reduction in response to project implementation – this would require deriving a basin-scale water budget accounting that incorporates project actions. This analysis would also inform the evaluation, as required under Section 355.4 of the GSP Regulations, of Plan/project feasibility and undesirable results (e.g., ecological impacts) associated with increased diversion and use of surface water supplies.Stated another way, I’m concerned that the GSP has not demonstrated that the Project Actions will be effective in achieving stated reductions in groundwater use and avoiding undesirable results. For example, Project 2, the SEWD Surface Water Implementation Expansion Project (SEWD), would require landowners adjacent to surface water conveyance systems (rivers or pipelines) to utilize surface water as part of the SGMA implementation. This would increase surface water usage by about 18,000 to 20,000 AF/year with in-lieu groundwater recharge benefits. This project relies on water from New Hogan Reservoir (Calaveras River water) and New Melones Reservoir (Stanislaus River water). Although the project could reduce groundwater use, there is no analysis provided on how the project would affect surface and ground water resources downstream of the two reservoirs. If this project reduced downstream flows, it could result in depleted surface water supplies, reduced groundwater recharge from the rivers as well as adverse impacts to riparian vegetation and environmental surface water beneficial users.

Similarly, I’m concerned about the assumed feasibility of some projects achieving the desired goal. For example, the groundwater recharge Projects 11 and 12 are anticipated to each recharge 8,000 AF/yr through the construction and operation of independent 10-acre recharge ponds. This equates to recharging 800 feet of water at each pond site between December 1 and June 30th of each year or 3.78 feet daily for the 212 day period. I am skeptical about achieving this level of recharge given the uncertainties in water availability during dry years, operations that would be required to maintain ponding of sufficient depth and duration, and maintaining basin infiltration rates given the likely accumulation of fine grained material that reduces basin permeability. This example demonstrates how the GSP fails to demonstrate how these project can be accomplished in a successful manner under a variety of rainfall and runoff conditions.

Projects and Management Actions See Master Response 5 - Projects. The ESJWRM will be updated to incorporate and evaluate GSP projects in future model refinement efforts. 5 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 28 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Figure 1-8 The Communications plan does not specify how the DACs identified in Figure 1-8 were specifically engaged. The failure to identify small community water systems calls into question how and whether adequate outreach to DACs was conducted. [SEE MORE SPECIFICS IN COMMENT LETTER] Outreach 1) An appendix has been added to the GSP which documents the 432 community water systems that received hard copy outreach materials throughout the GSP development process. Section 1.3.4.4 (Stakeholder Database) was updated to list the dates that outreach materials were mailed to community water systems. An analysis was performed to map community water systems that are DAC or SDAC areas, and the results of this analysis are presented in the added appendix. 2) Section 1.3.1 (Beneficial Uses and Users int he Subbasin) was updated to include community water systems and reference the added appendix. 3) Language was added to Section 1.3.4.5 (Stakeholder Education and Outreach) indicating that many GSAs conducted local outreach within their jurisdiction, including direct mailings to parcels served as part of a small water system. 29 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The “stakeholder feedback” mechanism for removal of NCCAGs from consideration as GDEs is not explained or documented in the GSP. Please provide details that support removing potential GDEs based on stakeholder feedback. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs Text in Section 2.2.7 (Groundwater-Dependent Ecosystems) was edited to clarify what comprised stakeholder feedback: Next, areas identified as GDEs were ground-truthed with GSA staff and Groundwater Sustainability Workgroup (Workgroup) members. Through this process, areas identified GDEs were investigated, and areas identified as known irrigated parcels such as parks were reclassified. These areas are labels on Figure 2-74 as “Stakeholder Comment.” 30 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The GSP uses domestic well depths as a basis for determining water level MTs, but does not present the domestic well depth data in the document. A map or maps showing domestic and public supply well depths would provide more transparency. [SEE MORE SPECIFICS IN COMMENT LETTER] Groundwater Levels Appendix 3-A (Supplemental Data for Groundwater Level Minimum Thresholds) shows the tabulated data for the wells in the representative monitoring network for groundwater levels. The table has been updated to include municipal well depths for Stockton, Manteca, and Lodi. 31 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The GSP identifies that information on domestic well construction including screen interval depths, are not available. However, the GSP does not identify a plan to fill this data gap, even though this information is critical to the GSA’s establishment of their water level MTs. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network Though the ESJGWA is not currently planning to collect construction information about domestic wells, any information that is shared or becomes publicly available will be reviewed for use in updates to the GSP. 32 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Providing maps of the monitoring network overlaid with location of DACs, GDEs, and any other sensitive beneficial users will allow the reader to evaluate the adequacy of the network to monitor conditions near these beneficial users. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network The plan is supported by the best available data and science and meets the requirements of SGMA. The ESJGWA Board supports the inclusion of the monitoring network as presented and approved it in July 2019. 33 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The scientific rationale for removing areas with access to alternate water sources from the identified GDEs should be better explained. Specifically, the results of any supporting habitat assessments should be provided. If no habitat assessments were conducted or reviewed, this should be identified as a data gap. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs See Master Response 1 - GDEs.
34 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists In the case of managed wetlands, the water sources used by the managed wetlands, the type of managed wetlands, the relationship of the wetlands to groundwater, and the wetland manager should be specified. In addition, these managed wetlands should be identified in Section 1.3.1. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs Comment noted. The managed wetlands and surrounding areas are mapped in Figure 2-68. SGMA does note require identification of managed wetlands or further classification. 35 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The approach used to identify and exclude GDEs should be supported by actual hydrologic and habitat assessment data. If such data and assessments are not available, the need for supporting studies to validate the approach should be identified as a data gap. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs GDEs have been identified as data gap areas requiring further refinement. Section 4.7 (Data Gaps) has been updated to reflect this change and to identify plans to collection additional data in areas of shallow groundwater. 36 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Shallow groundwater data near streams are identified as a significant data gap, and the application of a 30-foot depth to water criterion in light of the identified data gaps needs to be explained and supported. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network Section 2.2.7 (Groundwater-Dependent Ecosystems) was expanded to better describe the analysis: To identify NCCAG areas that are GDEs, the analysis identified communities in areas where groundwater levels are shallower than 30 feet bgs, as these areas are thought to be reachable by the root zone of vegetation. Oak trees are considered the deepest-rooted plant in the region with a root zone of roughly 25 feet. This value is considered conservative, as this depth is unlikely to support recruitment of new oak seedlings. NCCAG-identified communities in areas with groundwater shallower than 30 feet were considered as potential GDEs. Communities in areas deeper than 30 feet were identified as data gap areas for future refinement and are labeled on Figure 2-68 as “Depth to Water > 30 ft”. These areas will be refined in future analyses to identify potential existing GDEs that may have been misclassified through this screening process. Additional information regarding plans to fill GDE-related data gaps can be found in Section 4.7.4. 37 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists We recommend that depth to groundwater contour maps are used to verify whether a connection to groundwater exists for polygons in the NC Dataset, instead of relying on inferences based on the presence of surface water features in the Basin. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs Comment noted. This GSP uses a depth to groundwater contour map to evaluate whether a connection to groundwater exists with the Natural Communities Commonly Associated with Groundwater database (collectively developed by TNC, DWR, and CDFW). 38 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists It is highly advised that seasonal and interannual fluctuations in the groundwater regime are taken into consideration in the evaluation of root zones, particularly for oak trees. Utilizing groundwater data from one point in time or contoured with too few shallow monitoring wells can misrepresent groundwater levels required by GDEs, and inadvertently result in adverse impacts to the GDEs. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs See Master Response 1 - GDEs.
39 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists We recommend that a discussion regarding the nature and characteristics of the identified GDEs be included. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs Comment noted. Consider for inclusion in future updates to the GSP. As GDEs are a recognized data gap in the GSP, the list of identified GDEs will continue to be refined. Language was added to Section 4.7 (Data Gaps) to identify NCCAG areas removed through the GDE analysis are data gaps areas requiring further refinement. The purpose of this is to identify potential existing GDEs that may have been incorrectly eliminated through this screening process. 6 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 40 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists It is not clear how climate change is anticipated to change the demands of domestic users and small public water systems or how these demands were accounted for in the projected water budget. [SEE MORE SPECIFICS IN COMMENT LETTER] Climate Change There was no specific analysis done on the impact of climate change on domestic users and small public water systems apart from the simulation of both in the climate change model scenario as a part of the broader urban classification including all cities, private domestic users, and public water systems. Climate change will continue to be evaluated with every update to the GSP. Comment noted for follow up in next round of model refinements and updates to analyses. 41 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Please include an explanation of the approach to determining the amount of riparian ET demand met by streamflow vs. groundwater evapotranspiration. [SEE MORE SPECIFICS IN COMMENT LETTER] Water Budget Riparian evapotranspiration is included in the water budget (part of “Refuge, Native, and Riparian Evapotranspiration” in Table 2-14) and simulated in the model. Both streamflow and groundwater can contribute to meeting riparian evapotranspiration demand and the amount of demand met by each component is estimated directly by the model. “Riparian Intake from Streams” in Tables 2-13 and 2-14 includes all surface water and groundwater contributing to riparian demand through stream-aquifer interaction. The ESJWRM model does not have the level of detail to determine how much groundwater is consumed by riparian demand. 42 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Groundwater outflow to ET does not appear to be identified as a groundwater budget component. In addition, the ET demand of natural vegetation does not appear to be considered in water supply and demand calculations. Since wetlands, GDEs and riparian vegetation are recognized as beneficial users of groundwater in the Subbasin, it is appropriate to include them in these calculations. [SEE MORE SPECIFICS IN COMMENT LETTER] Water Budget
1) Groundwater outflow to evapotranspiration is not directly included as a water budget component and is simulated indirectly in ESJWRM through streamaquifer interaction and seepage of pumped groundwater. 2) Wetlands, GDEs, riparian vegetation, and native (or natural) vegetation are recognized as beneficial users and are included in the water budget, though not separated out and are part of “Refuge, Native, and Riparian Evapotranspiration”. There is not enough information at this time to determine how much groundwater is consumed by each of these demands. 3) This GSP recognized GDEs as a data gap in both the determination of GDEs in the Subbasin as well as the simulation of GDEs in the model. In the model, GDEs are broadly assumed to be represented as native vegetation as they are not specifically included in land use surveys. This representation removes the realistic variation of rooting depths across GDEs and we will consider the specific simulation of GDEs in future updates to the model. Comment noted for follow up in next round of model refinements and updates. 43 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The GSP clearly identifies plans to address data gaps in the monitoring network near streams, but does not clearly identify whether data gaps exist near DACs/drinking water users. A map illustrating the location of current and proposed monitoring well locations and depths relative to domestic and small public water systems wells and depths would allow the reader to assess the adequacy of the proposed network for monitoring impacts to these beneficial users. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network
The ESJGWA Board supports the inclusion of the monitoring network as presented and approved it in July 2019. Data gaps are discussed in Section 4.7 (Data Gaps) and include identified gaps in the monitoring and analysis of interconnected surface waters and GDEs. The GSP includes a plan for the drilling of up to 12 proposed wells to help resolve identified gaps and enhance future analysis of interconnected surface waters and GDEs. These proposed wells would all measure for both groundwater quality and groundwater levels and include 2 deep, nested wells funded under the TSS application and up to 10 shallow wells drilled by the ESJGWA. The plan meets the requirements of SGMA and does not require an additional figure at this time. 44 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Very few of the remaining monitoring wells are located near potential ISWs and GDEs. Specific monitoring of GDEs and ISWs should be described to further evaluate, monitor, manage and protect these areas. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network The ESJGWA Board determined the monitoring network is consistent with SGMA regulations. If a need for more detail recognized, the monitoring network will be reevaluated as updates to the GSP occur. Data gaps are discussed in Section 4.7 (Data Gaps) and include identified gaps in the monitoring and analysis of interconnected surface waters and GDEs. The GSP includes a plan for the drilling of up to 12 proposed wells to help resolve identified gaps and enhance future analysis of interconnected surface waters and GDEs. These proposed wells would all measure for both groundwater quality and groundwater levels and include 2 deep, nested wells funded under the TSS application and up to 10 shallow wells drilled by the ESJGWA. 45 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists It is not possible to determine whether the proposed monitoring, minimum thresholds and measurable objectives are sufficiently protective to ensure significant and unreasonable impacts to GDEs and ISWs will be prevented. The GDE Pulse interactive mapping application14 provides an example of a linkage between groundwater level data and GDE health that could be used to incorporate remote sensing into an efficient and incisive monitoring program. Please provide an explanation how groundwater levels will specifically be used to assess adverse impacts to GDEs and ISWs, and identify any data gaps and how they will be addressed. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network
The ESJGWA Board determined the monitoring network is consistent with SGMA regulations. If a need for more detail recognized, the monitoring network will be reevaluated as updates to the GSP occur. Data gaps are discussed in Section 4.7 (Data Gaps) and include identified gaps in the monitoring and analysis of interconnected surface waters and GDEs. The GSP includes a plan for the drilling of up to 12 proposed wells to help resolve identified gaps and enhance future analysis of interconnected surface waters and GDEs. These proposed wells would all measure for both groundwater quality and groundwater levels and include 2 deep, nested wells funded under the TSS application and up to 10 shallow wells drilled by the ESJGWA. GDE Pulse will be evaluated for use in the next round of GSP updates.
46 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Monitoring well locations should be prioritized near high value or sensitive resources (GDEs) that are vulnerable to significant and unreasonable impacts, such as near the protected lands identified in our comments on Section 1.3.1 or the GDEs identified in the Subbasin. In addition to the major streams and rivers in the subbasin, impacts to smaller creeks and wetland areas should be considered, as these may be the most vulnerable resources. Please discuss the results of a resource assessment or consultations with resource managers that demonstrates a sufficient number of wells is proposed to address data gaps near GDEs and ISWs, and that they are being sited where they will provide the most benefit. Alternatively, please outline the process by which this will be accomplished. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network
The ESJGWA Board determined the monitoring network is consistent with SGMA regulations. If a need for more detail recognized, the monitoring network will be reevaluated as updates to the GSP occur. Data gaps are discussed in Section 4.7 (Data Gaps) and include identified gaps in the monitoring and analysis of interconnected surface waters and GDEs. The GSP includes a plan for the drilling of up to 12 proposed wells to help resolve identified gaps and enhance future analysis of interconnected surface waters and GDEs. These proposed wells would all measure for both groundwater quality and groundwater levels and include 2 deep, nested wells funded under the TSS application and up to 10 shallow wells drilled by the ESJGWA. 47 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Please address how the need to link and correlate groundwater level declines to biological responses, and significant and adverse impacts to GDEs and ISWs will be addressed. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs
The GSP considers environmental users of groundwater, including species and habitat reliant on instream flows, as well as wetlands and GDEs as beneficial uses and users. See Section 1.3.1 (Beneficial Uses and Users in the Basin). Beneficial uses and users are considered in identifying undesirable results for each of the sustainability indicators. 48 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Addressing data gaps is typically iterative and it is not reasonable to expect it will be a one-time process. Please describe the process by which data gaps will be identified and addressed on an ongoing basis. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network The ESJGWA is committed to resolving the data gaps identified during the GSP development process. As discussed in Section 7.6.4 (Monitoring Network Description), a program may be developed for the GSP update to help fill new or remaining data gaps. 49 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

5.3 Section 5.3 Table 5.3 indicates that data regarding streamflow and GDEs is not currently included in the proposed Data Management System. Please discuss which monitoring data for “related surface conditions” will be gathered and incorporated in the DMS to assess potential significant and unreasonable impacts to environmental beneficial uses and users. [SEE MORE SPECIFICS IN COMMENT LETTER] DMS
Surface water data, including streamflow and water quality, is readily and publicly available online and has not be separately added to the DMS, though the system is set up to store streamflow and many other different types of data. Streamflow and surface water gage data was used both to build and calibrate the model, as well as in various analyses for the GSP. All groundwater level monitoring data will be evaluated for analysis of groundwater-surface water interaction and other surface conditions. As GDEs are a recognized data gap in the GSP, additional data may be collected that will be considered for addition to the DMS. 50 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

7.3.1 In Section 7.3.1, please clarify the potential use of imagery as a monitoring tool, and expand it to monitoring surface indicators of ISW and GDE ecosystem health. [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network While there are currently no specific plans regarding the use of imagery is a monitoring tool, any publicly available tools will be evaluated for use in updates to the GSP. 51 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

7.3.2.2 In Section 7.3.2.2, please specifically address ecosystem health of GDEs and ISWs as a surface indicator to subsurface conditions. This can be done using GDEPulse, remote sensing, imagery or other feasible methods [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network While there are currently no specific plans regarding the use of imagery is a monitoring tool, any publicly available tools will be evaluated for use in updates to the GSP. 7 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 52 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Stakeholder input from DAC community members does not appear to have been considered in establishment of water quality URs, based on the information presented in the GSP. [SEE MORE SPECIFICS IN COMMENT LETTER] Outreach 1) An appendix has been added to the GSP which documents the 432 community water systems that received hard copy outreach materials throughout the GSP development process. Section 1.3.4.4 (Stakeholder Database) was updated to list the dates that outreach materials were mailed to community water systems. An analysis was performed to map community water systems that are DAC or SDAC areas, and the results of this analysis are presented in the added appendix. 2) Section 1.3.1 (Beneficial Uses and Users in the Subbasin) was updated to include community water systems and reference the added appendix. 3) Language was added to Section 1.3.4.5 (Stakeholder Education and Outreach) indicating that many GSAs conducted local outreach within their jurisdiction, including direct mailings to parcels served as part of a small water system. 53 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Based on the presented information, domestic well uses are considered under URs and for the development of water level MOS and MTs, but DAC members are not explicitly considered. More detail and specifics regarding DAC members, including those that rely on smaller community drinking water systems, not only domestic wells, is necessary to demonstrate that these beneficial users were adequately considered. [SEE MORE SPECIFICS IN COMMENT LETTER] Sustainable Management Criteria
Groundwater level minimum thresholds considered domestic wells in the analysis to determine the thresholds with the intent of being protective of 90% of domestic wells. In the Subbasin, 22 percent of domestic wells are located within DACs. An appendix has been added to the GSP which documents the 432 community water systems that received hard copy outreach materials throughout the GSP development process. Section 1.3.4.4 (Stakeholder Database) was updated to list the dates that outreach materials were mailed to community water systems. An analysis was performed to map community water systems that are DAC or SDAC areas, and the results of this analysis are presented in the added appendix. 54 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The incorrect statement that SGMA does not require the establishment of sustainable management criteria for GDEs should be removed. [SEE MORE SPECIFICS IN COMMENT LETTER] Clarifying Edit Clarified text in Section 2.2.7 (Groundwater-Dependent Ecosystems): SGMA requires the identification of GDEs. SGMA does not require that additional sustainable management criteria be established to specifically manage these areas, but rather includes GDEs as a beneficial user of water to be considered when developing other sustainable management criteria. 55 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

3.2.1.1.1 Please add “potential adverse impacts to GDEs” to the list of potential undesirable results presented in Section 3.2.1.1.1. [SEE MORE SPECIFICS IN COMMENT LETTER] Clarifying Edit Added text to Section 3.2.1.1.1 (Description of Undesirable Results) to list GDEs as having potential undesirable results due to the chronic lowering of groundwater: Adverse impacts to environmental uses and users, including interconnected surface waters and groundwater-dependent ecosystems (GDEs). 56 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

3.2.6 The analysis for potential depletion of ISWs in Section 3.2.6 should include all beneficial users of surface water that could be affected by groundwater withdrawals, including environmental beneficial users along creeks, even if the creeks are interconnected less than 75% of the time. [SEE MORE SPECIFICS IN COMMENT LETTER] Interconnected Surface Water Comment noted. The ESJGWA supports the definition of undesirable results provided in the GSP, which identifies GDEs and freshwater fish and wildlife species as beneficial users. The ESJGWA will continue to collect data to better inform connectivity conditions in the Subbasin. 57 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The definition of undesirable results for ISWs is overly narrow and recognizes only a limited subset of the environmental beneficial users of ISWs. A more complete definition would be that undesirable results would occur if groundwater extraction resulted in a depletion of surface water that caused significant impacts to aquatic species or wildlife, or degradation of wetlands, riparian habitats and GDEs. Please expand the definition of undesirable results to include all of the environmental beneficial uses and users of ISWs, and expand the analysis in Section 3.2.6, as appropriate. [SEE MORE SPECIFICS IN COMMENT LETTER] GDEs Comment noted. The ESJGWA supports the definition of undesirable results provided in the GSP, which identifies GDEs and freshwater fish and wildlife species as beneficial users. The ESJGWA will continue to collect data to better inform connectivity conditions in the Subbasin. 58 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists

3.2.6.1.3 Please expand Section 3.2.6.1.3 to describe the potential effects of undesirable results on all beneficial uses and users of ISWs, including environmental uses and users. [SEE MORE SPECIFICS IN COMMENT LETTER] Interconnected Surface Water The ESJGWA considers the discussion in Section 3.2.6 (Depletions of Interconnected Surface Water) to be descriptive of beneficial uses and users in the subbasin, and to be protective of existing in-stream flow requirements for fish and wildlife. 59 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The likely benefits and impacts to DAC members by the proposed projects and management actions are not clearly identified in the GSP. A discussion should be added for each project or management action to clearly identify the benefits to DAC drinking water users and potential impacts to the water supply. For all potential impacts, the project/management action should include a clear plan to monitor for, prevent, and/or mitigate against such impacts. [SEE MORE SPECIFICS IN COMMENT LETTER] Projects and Management Actions
Comment noted. The ESJGWA has a twenty year planning timeframe to bring the projects online, and will continue to evaluate project benefits, impacts, and costs. DAC benefits and impacts will be addressed at the GSA level by the project proponents, as determined to be appropriate by the project proponents. SGMA looks at the basin-scale. Project impacts will be evaluated; it is the GSA's responsibility to meet project-level environmental regulations. CEQA compliance will be done at the GSA level. 60 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The GSP does not appear to include any plans to address impacts to domestic well users if domestic wells do go dry in the future. Based on the water level MTs, at least 10% of domestic wells would be expected to be dewatered if MT levels are reached. While the identified projects are intended to keep water levels above the MTs, no program is provided as a contingency in case 1) groundwater conditions decline before the projects are fully implemented, or 2) implementation of such projects does not have the desired effects. A plan to mitigate impacts to DAC drinking water users could include a program to replace wells, connect well users to a public water system, establishment of a tanked water program, etc. The GSP should also identify a mechanism to fund such a program. [SEE MORE SPECIFICS IN COMMENT LETTER] Groundwater Levels
The ESJGWA supports using the minimum thresholds, measurable objectives, and interim milestones for the chronic lowering of groundwater levels sustainability indicator as written. SGMA does not require zero impact, and the ESJGWA has determined that it is not considered significant and unreasonable for wells belonging to the shallowest 10 percent of domestic wells to be dewatered, as the wells that are likely to be dewatered are those that are 50 years or older, have reached the end of their usable life, and would need to be replaced anyway. Data collected on Stanislaus County rural domestic wells that were dewatered in years 2014-2016, showed that the average depth of wells reported as dewatered was 91 ft bgs, and that 60 percent were shallower than 100 ft bgs. Additionally, the average well age for wells reported as dewatered was 55 years, and 52 percent were older than 50 years old.

There are various well impact mitigation programs in place, therefore there were no changes were made to the GSP. 61 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Table 6-1 From Table 6-1 it is not possible to distinguish the full range of project benefits or how the projects will be prioritized. It would be advantageous to demonstrate multiple benefits from a funding and prioritization perspective. [SEE MORE SPECIFICS IN COMMENT LETTER] Projects and Management Actions Comment noted. The text in Chapter 6 (Projects and Management Actions) provides summaries of all potential SGMA projects, including expected project benefits. 62 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Potential impacts of projects and management actions on groundwater levels near surface water bodies should be evaluated as part of the GSP. [SEE MORE SPECIFICS IN COMMENT LETTER]
Projects and Management Actions
Comment noted. The ESJGWA has a twenty year planning timeframe to bring the projects online, and will continue to evaluate project benefits, impacts, and costs. SGMA looks at the basin-scale. Project impacts will be evaluated; it is the GSA's responsibility to meet project-level environmental regulations. CEQA compliance will be done at the GSA level. 63 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The draft GSP sets the minimum thresholds (MTs) for groundwater levels at representative monitoring well sites as the shallower of either: (1) the shallower of 1992 or 2015-2016 historical groundwater levels with a buffer of 100 percent of historical range applied, or (2) the 10th percentile of total depth of domestic wells within a 3-mile radius of a representative monitoring well site1. This approach to setting water level MTs and the selected representative monitoring network leaves key beneficial users in the subbasin, specifically domestic well users and in particular members of disadvantaged communities (DACs), potentially vulnerable to impacts. [SEE MORE SPECIFICS IN COMMENT LETTER, APPENDIX B: FOCUSED TECHNICAL REVIEW] Groundwater Levels
The ESJGWA supports using the minimum thresholds, measurable objectives, and interim milestones for the chronic lowering of groundwater levels sustainability indicator as written. SGMA does not require zero impact, and the ESJGWA has determined that it is not considered significant and unreasonable for wells belonging to the shallowest 10 percent of domestic wells to be dewatered, as the wells that are likely to be dewatered are those that are 50 years or older, have reached the end of their usable life, and would need to be replaced anyway. Data collected on Stanislaus County rural domestic wells that were dewatered in years 2014-2016, showed that the average depth of wells reported as dewatered was 91 ft bgs, and that 60 percent were shallower than 100 ft bgs. Additionally, the average well age for wells reported as dewatered was 55 years, and 52 percent were older than 50 years old.

There are various well impact mitigation programs in place, therefore there were no changes were made to the GSP. 8 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 64 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The draft GSP includes limited analysis of water quality constituents and defines undesirable results (URs) for water quality relative to “impacts to the long-term viability of domestic, agricultural, municipal, environmental, or other beneficial uses over the planning and implementation horizon of this GSP” (Section 3.2.1.1). For the reasons identified below, the water quality monitoring network and analysis presented in the draft GSP does not clearly illustrate how the sustainable management criteria will be sufficient to ensure that the stated water quality UR of impacting the long-term viability of the groundwater resource, particularly for domestic water users including DACs, will be avoided. [SEE MORE SPECIFICS IN COMMENT LETTER, APPENDIX B: FOCUSED TECHNICAL REVIEW] Groundwater Quality See Master Response 3 -- Water Quality. 65 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The draft GSP estimates conditions using 2070 climate forecast. Based on this, the draft GSP estimates that “Under climate change conditions, 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” (Section 2.3.7.4). However, the results of the climate change scenario modeling were not used as the basis for development of Project and Management Actions. Therefore, while climate change is evaluated in terms of future water budget conditions, the draft GSP does not actually include a substantive plan to address the increased deficit anticipated to result from climate change.

Water Budget
Consistent with regulations, the 2070 climate change sensitivity analysis on the projected conditions scenario was used to better understand trends and inform planning. Due to the uncertainty around climate projections in the 2070 timeframe, the ESJGWA Board determined the projected conditions scenario was most appropriate for analyzing sustainable yield in the GSP implementation time period beginning in 2040. Therefore, climate change was not included in the sustainable yield analysis or the estimated amount of direct or in lieu recharge and/or reduction in pumping needed for the Subbasin to reach sustainability. Climate change will continue to be evaluated with every update to the GSP and estimates of projects and management actions will continue to evolve with refinements to the model. Comment noted for follow up in next round of model refinements and updates to analyses. 66 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The draft GSP notes that because there are no available data on local private groundwater pumping, “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. Demand in areas with no access to surface water is completely met by groundwater pumping” (Section 2.3.4.2). However, based on our review of the draft GSP the model-calculated rural residential demands are not presented in the document. This water demand information should be transparently presented for the historical, current, and future water budgets so that the public can review the drinking water demand estimates for domestic users and community water systems, and make an assessment as to the appropriateness of the demands considered in the historical, current, or future water budgets.

Water Budget Specifying urban demand at the level of rural residential demand goes above and beyond the requirements of SGMA. The current text, tables, and figures for the water budget meet the requirements of the GSP. 67 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The draft GSP notes that the future water budget demands for domestic areas outside of those covered by Urban Water Management Plans “are estimated based on rural population” and that “To estimate the urban water demand of rural domestic water areas, the average major urban area GPCD was combined with estimated rural population” (Section 3.2 of Appendix 2-1). However, the draft GSP does not present the population values associated with the rural population or a clear presentation of the results of this method. In order for the public to be able to evaluate the appropriateness of these assumptions, the applied values and resultant demands should be clearly identified in the document.

Water Budget
The model report was finalized in August 2018 and was included as an appendix in the GSP to provide an explanation of the development and calibration of the historical model. The model documentation will be updated as updates to the model are made in the future. Comment noted for follow up in next round of model refinements and updates to analyses.
68 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The proposed projects and management actions include twenty separate direct and in-lieu recharge projects. Recharge projects have the potential to mobilize contaminants, including by mobilizing surface and shallow soil contaminants through percolation, spreading existing contaminant plumes by altering the groundwater flow gradient, and mobilizing naturally occurring compounds through changes in geochemistry due to the introduction of a different water type, among other mechanisms. As recommended in the 2019 Stanford A Guide to Water Quality Requirements Under the Sustainable Groundwater Management Act, “In addition to complying with any regulatory requirements, GSAs undertaking recharge or other active management actions should consider developing a sufficient understanding of the interactions between subsurface geology, geochemistry and GSP projects in their basin. The development of sufficient monitoring networks, capable of detecting changes in groundwater quality conditions related to active management, will be critical to understanding these interactions.”7 Therefore, the GSP should explicitly describe how such risks will be evaluated and monitored as a part of each identified project.

Projects and Management Actions
1) CEQA compliance will be conducted at the GSA level. Language was added to Section 2.2.4.4 (Point Sources) stating that new projects undertaken by GSAs as part of GSP implementation will evaluate contaminant plume movement in a CEQA document, and management through existing regulatory agencies was highlighted. 2) Recharge projects were preliminarily screened for the potential to contribution to the migration of a potential contaminant plume during the GSP project proposal process. Projects with the potential to contribute to the migration of a potential contaminant plume were eliminated from consideration and removed from the GSP list of projects. (See GSP Section 6.2.1 (Project Identification)). 69 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists Based on our assessment of the water levels, a significant proportion of domestic wells have the potential to be partially or fully dewatered if water levels reach the proposed MT levels. However, the draft GSP does not include or describe any plans to develop a well impact mitigation program. Such a program could include a combination of replacing impacted wells with new, deeper wells and/or connecting domestic users to a public water system. A plan to establish an emergency tanked water program, as was done in some areas of California during the last drought, may be an appropriate short-term solution, but would not be a good long-term solution for community members. Key considerations for establishing such a program should include: - A strong preference for connecting current domestic well users to a public water system, whenever possible. Public water systems have an obligation to test water quality for water served, and although the public water systems in this area typically have limited resources, they do have a greater ability to install treatment systems to address water quality impacts, recoup funds for litigated contamination such as 1,2,3-TCP, and apply for and receive grant funding for beneficial projects. Because of this, public water systems, including small community water systems, provide a more reliable drinking water source than privately-owned domestic wells. - A secure and reliable funding source and mechanism for implementation of such a mitigation program needs to be identified. While grant or emergency funding could potentially be available for such a program when needed, the availability of these funds is not certain. A more secure funding mechanism could be the establishment of a reserve fund that is paid into on an annual basis and accrues funds that would then available as water levels drop in the future. - The implementation of a mitigation program should be triggered before wells begin to become unusable, so that funding will be available, and the necessary planning and contracting will be completed such that the necessary construction will be implemented without unnecessarily leaving community members without access to drinking water. Thus, the program should be designed to be proactive, rather than reactive. - A well mitigation program should not be established only in case of emergency. Droughts are said to be becoming more and more frequent and severe, and as such should be included as part of the long-term sustainability planning for the subbasin.

Groundwater Levels
The ESJGWA supports using the minimum thresholds, measurable objectives, and interim milestones for the chronic lowering of groundwater levels sustainability indicator as written. SGMA does not require zero impact, and the ESJGWA has determined that it is not considered significant and unreasonable for wells belonging to the shallowest 10 percent of domestic wells to be dewatered, as the wells that are likely to be dewatered are those that are 50 years or older, have reached the end of their usable life, and would need to be replaced anyway. Data collected on Stanislaus County rural domestic wells that were dewatered in years 2014-2016, showed that the average depth of wells reported as dewatered was 91 ft bgs, and that 60 percent were shallower than 100 ft bgs. Additionally, the average well age for wells reported as dewatered was 55 years, and 52 percent were older than 50 years old.

There are various well impact mitigation programs in place, therefore there were no changes were made to the GSP. 70 Collective Comments: TNC, Audubon California, CWA, CWF, American Rivers, Union of Concerned Scientists The following figures are included in the joint comments document: Figure 1 - Representative Monitoring Network for GW Levels Relative to Domestic Wells, DACs, and Community Water Systems Figure 2 - Water Level MTs and Domestic Wells Figure 3 - Representative Monitoring Network for Water Quality Relative to Domestic Wells, DACs, and Community Water Systems [SEE MORE SPECIFICS IN COMMENT LETTER] Monitoring Network No specific comment to respond to.
71 Collective Comments: The
League of Women Voters of SJC, EJCW, Sierra Club Delta-Sierra Group, Puentes, Restore the Delta Submitting public notices to the newspaper, notices of items on an isolated agenda, or a notice on a website fulfills a minimum outreach requirement for some governmental actions but not for SGMA. Groundwater sustainability plan regulations require that GSAs document in a communication section of the GSP the opportunities for public engagement and active involvement of diverse social, cultural, and economic elements of the population within the basin. These types of public notices do not encourage active involvement of diverse members of our Eastern San Joaquin Subbasin. These minimum public noticing techniques were used when the GSAs were formed and are documented on the SGMA Portal website: https://sgma.water.ca.gov/portal/gsa/all (search for GSA of interest). A single initial notification of GSP preparation was made on behalf of all the GSAs within the Eastern San Joaquin Subbasin and can be found her: https://sgma.water.ca.gov/portal/gsp/init/preview/82. Since the initial notification dated March 16, 2018, development of the GSP has been ongoing, but consistent public outreach has not. A 2017 Department of Water Resources (DWR) grant for Facilitation and Support Services included a stakeholder identification and engagement component, but stakeholder engagement efforts trailed facilitation activities under that agreement by about six months. A situation assessment produced by consultants in December 2018, after the end of the contract period, summarized feedback from one group of stakeholders. That assessment references a separate document with recommendations for adjustment to the stakeholder process, but the separate document is not available online.

Agencies in the Eastern San Joaquin Subbasin formed GSAs primarily to protect their autonomy, not necessarily because they were considering the effect of the GSP on the users they serve or residents within the GSA Boundaries. Some GSAs have names that would not be recognized even by water users that they serve. Examples include the Eastside GSA (Calaveras County Water District, Rock Creek Water District, and Stanislaus County), and South San Joaquin GSA (South San Joaquin Irrigation District). Nevertheless, SGMA assigns GSAs outreach responsibilities. [SEE MORE SPECIFICS IN COMMENT LETTER] Outreach
Outreach efforts conducted as part of GSP development are described in Chapter 1.3 (Notice and Communication). Outreach efforts done by the ESJGWA have gone above and beyond the requirements of SGMA. However, the ESJGWA recognizes there is always room for improvement. The ESJGWA has appointed an Ad Hoc Committee for the purposes of refining implementation and funding next steps. The Ad Hoc Committee has met weekly to bi-weekly since July 2019. Recommendations on outreach efforts moving forward are being identified by the Ad Hoc Committee for ESJGWA action. The Ad Hoc Committee has reviewed the suggestions put forth in this letter and have identified these future actions for consideration moving forward. 73 Collective Comments: The
League of Women Voters of SJC, EJCW, Sierra Club Delta-Sierra Group, Puentes, Restore the Delta Outreach summaries produced and distributed by the GSP consultant team do not provide useful information because they allow for reporting on only certain kinds of outreach, and because even GSAs that perform outreach are not always reporting it.According to the ESJGA GSA Outreach Activities summary (Appendix A), some GSAs have reported no outreach activities at all. This may indicate that no outreach activity occurred or that GSA staff is unwilling or unable to report GSA outreach activities, or that the summary provides data only on electronic outreach. A major theme raised by a member of the ESJ Groundwater Advisory Committee at its June 12, 2019 meeting is that there must be balance between autonomy and accountability. This documentation of SGMA-required outreach activities to encourage active involvement suggests that perhaps too much autonomy has been applied without clearly needed accountability. Also, not all agencies that want autonomy have the capacity or resources to do the required outreach for which they may be held accountable. [SEE MORE SPECIFICS IN COMMENT LETTER] Outreach
Outreach efforts conducted as part of GSP development are described in Chapter 1.3 (Notice and Communication). Outreach efforts done by the ESJGWA have gone above and beyond the requirements of SGMA. However, the ESJGWA recognizes there is always room for improvement. The ESJGWA has appointed an Ad Hoc Committee for the purposes of refining implementation and funding next steps. The Ad Hoc Committee has met weekly to bi-weekly since July 2019. Recommendations on outreach efforts moving forward are being identified by the Ad Hoc Committee for ESJGWA action. The Ad Hoc Committee has reviewed the suggestions put forth in this letter and have identified these future actions for consideration moving forward. 74 Collective Comments: The
League of Women Voters of SJC, EJCW, Sierra Club Delta-Sierra Group, Puentes, Restore the Delta Focusing outreach requirements on individual GSAs has created a situation in which it appears that no outreach has been done to an important and impacted category of users: people on domestic wells. …Those individuals, who are likely very vulnerable to impacts of the GSP, are not being directly noticed. Of most concern are the residents with wells less than 200 feet below ground surface…With the exception of San Joaquin County GSA No.1, GSAs in this Subbasin are either public agencies or a private agency (San Joaquin County GSA No.2 – Calwater) created to provide surface and/or groundwater. These GSAs therefore have some kind of constituency or customer base. People on domestic wells are not part of that base, and responsibility for SGMA outreach to them has not been addressed. [SEE MORE SPECIFICS IN COMMENT LETTER] Outreach
Outreach efforts conducted as part of GSP development are described in Chapter 1.3 (Notice and Communication). Outreach efforts done by the ESJGWA have gone above and beyond the requirements of SGMA. However, the ESJGWA recognizes there is always room for improvement. The ESJGWA has appointed an Ad Hoc Committee for the purposes of refining implementation and funding next steps. The Ad Hoc Committee has met weekly to bi-weekly since July 2019. Recommendations on outreach efforts moving forward are being identified by the Ad Hoc Committee for ESJGWA action. The Ad Hoc Committee has reviewed the suggestions put forth in this letter and have identified these future actions for consideration moving forward. 75 Collective Comments: The
League of Women Voters of SJC, EJCW, Sierra Club Delta-Sierra Group, Puentes, Restore the Delta Recommendations- GSAs in the Eastern San Joaquin Subbasin should increase outreach by print with informational inserts in utility bills, property tax bills, and any other regular correspondence that is sent to households. Notices of the plan commenting period should be posted at each GSA headquarters, along with information about where to find GSA specific information. - Principal and sub-contract consultants who are developing the GSP can develop posters that can be widely distributed, and can provide flyers to the Agricultural Commissioner’s Office, Environmental Health Department, and Community Development Department within Calaveras, San Joaquin, and Stanislaus Counties. - The Eastern San Joaquin Groundwater Authority (ESJGA) website, esjgroundwater.org, should provide GSA website addresses where stakeholders can find GSA and ESJGA level information, GSA contact email addresses, telephone numbers, and GSA staff contact names. Currently only mailing addresses are available for contacting GSAs. A number of non-governmental organizations (NGOs) representatives including the Sierra Club, League of Woman Voters, and Catholic Charities requested back in November 2018 that this information be updated, but that has not been done. - The ESJGA website should provide information about how people can determine the GSA jurisdiction within which they live. - Email inquiries to “Contact Us” on the ESJGA website currently go through a San Joaquin County government subcontractor, who redirects them. Responses to email inquiries, tabulating, and documenting of contacts and responses, should be included on regular outreach summaries. - GSAs a fee to provide funding for an outreach coordinator to perform tasks that GSAs do not have the staff or expertise to perform. - As recommended by the Facilitation and Support Services consultants, a stakeholder or advisory board should be convened when the GSP is submitted, to review and inform implementation.

Outreach
Outreach efforts conducted as part of GSP development are described in Chapter 1.3 (Notice and Communication). Outreach efforts done by the ESJGWA have gone above and beyond the requirements of SGMA. However, the ESJGWA recognizes there is always room for improvement. The ESJGWA has appointed an Ad Hoc Committee for the purposes of refining implementation and funding next steps. The Ad Hoc Committee has met weekly to bi-weekly since July 2019. Recommendations on outreach efforts moving forward are being identified by the Ad Hoc Committee for ESJGWA action. The Ad Hoc Committee has reviewed the suggestions put forth in this letter and have identified these future actions for consideration moving forward. 76 Collective Comments: The
League of Women Voters of SJC, EJCW, Sierra Club Delta-Sierra Group, Puentes, Restore the Delta Each GSA should provide a written explanation of why the outreach they have done so far is adequate to meet the intent of SGMA outreach, and if it has not been adequate, what strategies each GSA proposes for doing adequate outreach during implementation of the plan. This information should be included in the GSP. Outreach Outreach efforts conducted as part of GSP development are described in Chapter 1.3 (Notice and Communication). Outreach efforts done by the ESJGWA have gone above and beyond the requirements of SGMA. However, the ESJGWA recognizes there is always room for improvement. The ESJGWA has appointed an Ad Hoc Committee for the purposes of refining implementation and funding next steps. The Ad Hoc Committee has met weekly to bi-weekly since July 2019. Recommendations on outreach efforts moving forward are being identified by the Ad Hoc Committee for ESJGWA action. The Ad Hoc Committee has reviewed the suggestions put forth in this letter and have identified these future actions for consideration moving forward. 77 Collective Comments: The
League of Women Voters of SJC, EJCW, Sierra Club Delta-Sierra Group, Puentes, Restore the Delta A preliminary list of GSP implementation elements includes a task called “Public Outreach and Website Maintenance.” Providing for public outreach and website maintenance only at the level of the Eastern San Joaquin Groundwater Authority website will not be adequate to cover the outreach obligations of all the GSAs. Outreach Outreach efforts conducted as part of GSP development are described in Chapter 1.3 (Notice and Communication). Outreach efforts done by the ESJGWA have gone above and beyond the requirements of SGMA. However, the ESJGWA recognizes there is always room for improvement. The ESJGWA has appointed an Ad Hoc Committee for the purposes of refining implementation and funding next steps. The Ad Hoc Committee has met weekly to bi-weekly since July 2019. Recommendations on outreach efforts moving forward are being identified by the Ad Hoc Committee for ESJGWA action. The Ad Hoc Committee has reviewed the suggestions put forth in this letter and have identified these future actions for consideration moving forward. 78 John Fio
[email protected]
m650-292-9110
EKI on behalf of Cosumnes Subbasin GSA Working Group

1.2.3.3 Land Use Plans Outside the Plan Area
The section heading indicates it will discuss land use plans outside the ESJ Subbasin, but no specific land use planning information is provided for the adjacent Cosumnes Subbasin aside from referencing the existence of the City of Galt General Plan (2009). Plan Area As the surrounding groundwater subbasins are not designated as critically overdrafted, their GSPs are on a slower timeline. ESJ Subbasin will continue to coordinate with Cosumnes Subbasin and other neighboring subbasins on land use planning in the two subbasins as their GSP work progresses. Text added to 1.2.3.3 discussing continued coordination with neighboring subbasins: Ongoing coordination with neighboring groundwater subbasins will include updates on major land use planning that may impact the groundwater system. 79 Linda [email protected]
Sacramento County Groundwater Sustainability Agency (GSA) - Cosumnes Subbasin

1.2.3.4 Well Permitting
As an adjacent basin please add Sacramento County well permitting. For well standards visit: http://www.emd.saccounty.net/EC/Pages/Wells.aspx Well Permitting A new subsection has been added to the GSP under section 1.2.3.4 (Well Permitting) to add Sacramento well permitting information in response to this comment. 80 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group

1.3.5 Inter-basin Coordination Only provides date of inter-basin meeting. No explanation of topics discussed or outcome from effort. Clarifying Edit Comment noted. As the surrounding subbasins are on a slower timeline than the Subbasin, inter-basin coordination is just beginning and the description in the text is indicative of discussions so far. 81 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group

2.1.9 Principal Aquifer
The northern boundary of the ESJ Subbasin is shared with the Cosumnes Subbasin, however, there seems to be very little information described in writing about subsurface conditions and groundwater flow conditions at that boundary. This appears to be a deficit in the HCM. Basin Setting The ESJGWA determined that the HCM meets the requirements of the Water Code. Subsurface conditions are discussed for the entire Subbasin.

Groundwater flow is discussed broadly in Section 2.1.9.2.2 (Regional Historical Groundwater Flow and Surface Water Interaction) with more discussion and figures in Section 2.2.1.2 (Current Groundwater Elevations). 10 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 82 Linda Dorn
Sacramento County Groundwater Sustainability Agency (GSA) - Cosumnes Subbasin

2.1.10 HCM Data Gaps Sacramento County GSA is adjacent to the northwest data gap area and we encourage coordination with Sacramento County GSA for filling this data gap. Current Groundwater Conditions This has been noted as a future item for consideration as the GSAs move into GSP implementation. 83 Linda Dorn
Sacramento County Groundwater Sustainability Agency (GSA) - Cosumnes Subbasin

2.2.1.1 Historical Groundwater Elevations
Amador County Groundwater Sustainability Authority may have information to help fill this data gap in the northeast corner of the subbasin.https://amadorwater.org/tag/amador-county-groundwater-management-authority/ Basin Setting This has been noted as a future item for consideration as the GSAs move into GSP implementation. 84 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group
Figure 2-38 It would be helpful for neighboring basins if the groundwater elevation map displayed data points and posted values, especially at the basin boundaries where the contours help assess cross boundary flows. Mechanics - Graphics The ESJGWA will continue to coordinate with neighboring subbasins as they develop their plans and establish sustainable management criteria, such that no subbasin is preventing another from achieving sustainability. 85 Linda Dorn
Sacramento County Groundwater Sustainability Agency (GSA) - Cosumnes Subbasin

2.3.1 Water Budget Background Information
Since the Eastern San Joaquin subbasins water budget relies on adjacent subbasins inflow, the water budget inflow information for the Cosumnes subbasin maybe different than what has been calculated. A sentence should be added that reflects how the water budget will handle discrepancies between adjacent subbasins water budgets .

Water Budget
As the Cosumnes Subbasin is not designated as a critically overdrafted, groundwater basin, their GSP is on a slower timeline so analysis was not available for direct comparison during initial inter-basin coordination discussions. ESJ Subbasin will continue to coordinate with Cosumnes Subbasin on boundary flows across Dry Creek as well as sustainable management criteria developed in the two subbasins as their GSP work progresses. 86 Linda Dorn
Sacramento County Groundwater Sustainability Agency (GSA) - Cosumnes Subbasin

2.3.4.1 Assumptions
Used in the Historical
Water Budget
Sacramento County flood gauge information may provide data on flows in Dry Creek that would be more accurate than extracting Dry Creek flow from CalSIMII. Please see the website below for more information on flow for Dry Creek.https://www.sacflood.org/level.php?view=253d63a6-69ea-4c28-bd90-539059aa5fd8&view_group=99a123be-5de5-3678-7140-d7bb445af1b3&group=7c53d59d-d00d707c-d514-fc1327f3c4e9Also Amador County produced a 2006 Dry Creek Watershed Management Plan (attached) that is attached to the e-mail submitting these comments. Amador County has additional information on Cosumnes River flows too.

Basin Setting This has been noted as a future item for consideration as the GSAs move into GSP implementation. 87 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group
Table 2-15
Historical conditions indicate that, on average, net groundwater flow is from the Cosumnes Subbasin into the ESJ Subbasin at a rate of 14,000 acre-feet per year (AF/year). However, inflows from the Cosumnes Subbasin to the ESJ Subbasin increase to 23,000 AF/yr under current conditions (more than 60%) and will be 19,000 AF/yr under projected conditions (more than 30%). These changes in cross-boundary flows are potentially significant, and groundwater level monitoring and protective SMCs are needed near the subbasin boundary to ensure that: (1) undesirable results do not occur across the shared subbasin boundary , and (2) these projected increased levels of inflow to the ESJ subbasin from the Cosumnes Subbasin do not impact the ability of the Cosumnes Subbasin to achieve sustainability.

Water Budget
As the Cosumnes Subbasin is not designated as a critically overdrafted, groundwater basin, their GSP is on a slower timeline so analysis was not available for direct comparison during initial inter-basin coordination discussions. ESJ Subbasin will continue to coordinate with Cosumnes Subbasin on boundary flows across Dry Creek as well as sustainable management criteria developed in the two subbasins as their GSP work progresses. 88 Linda Dorn
Sacramento County Groundwater Sustainability Agency (GSA) - Cosumnes Subbasin

2.3.6 Sustainable Yield Estimate
Assuming groundwater pumping under sustainable conditions will not create changes in groundwater inflow from neighboring basins should include a caveat referencing future GSPs of the neighboring basins will help determine if pumping under sustainable conditions will affect inflows at the basin boundaries. Water Budget As the neighboring subbasins are not designated as critically overdrafted groundwater basins, their GSPs are on a later timeline so analyses were not available for direct comparison during initial inter-basin coordination discussions. ESJ Subbasin will continue to coordinate with neighboring subbasins on boundary flows as well as sustainable management criteria as GSP work progresses. The ESJGWA will continue to coordinate with neighboring subbasins as they develop their plans and establish sustainable management criteria, such that no subbasin is preventing another from achieving sustainability. 89 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group

2.3.6 Sustainable Yield Estimate
The projected water budget shows greater outflows than inflows, resulting in an average annual deficit in groundwater storage of 34,000 AF/year in the ESJ Subbasin. To achieve sustainability, approximately 78,000 AF/year of direct or in lieu groundwater recharge and/or reduction in agricultural and urban groundwater pumping is reportedly needed in the ESJ Subbasin. However, there is no explanation or discussion for how and where these reductions will be achieved. Moreover, the lack of certainty in implementing projects and/or management actions to achieve sustainability create uncertainty in their potential effects on the Cosumnes Subbasin.

Water Budget See Master Response 5 - Projects.
90 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group

2.3.7.4 Eastern San Joaquin Water Budget Under Climate Change Tabulated water budget results like those in Table 2-15 need to be included for the climate change scenario results. Climate Change The current text, tables, and figures for climate change meet the requirements of the GSP. Future updates to the GSP may include more detailed analysis of climate change scenario results. 91 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group

3.2.1.2 Minimum Thresholds
The Minimum Thresholds(MT) for groundwater levels protect against Undesirable Results in the ESJ Subbasin and were specified for 19 wells based on minimum water levels measured in 1992 or 2015-2016, whichever are lowest, plus an operational buffer. These groundwater level MTs are utilized as proxy for groundwater storage, subsidence, and interconnected surface water sustainability indicators for the ESJ Subbasin. The MTs for the ESJ Subbasin should also ensure that they are not creating changes in groundwater inflow that could impede sustainability plans and implementation in the Cosumnes Subbasin. This includes groundwater level monitoring near the subbasin boundary and projected changes under historical, current, projected, and climate change.

Monitoring Network
As the Cosumnes Subbasin is not designated as a critically overdrafted, groundwater basin, their GSP is on a slower timeline so analysis was not available for direct comparison during initial inter-basin coordination discussions. As described in Section 4.7 (Data Gaps) and shown in Figure 4-3, additional groundwater monitoring wells are planned for more groundwater monitoring along the boundary with Cosumnes Subbasin to support future GSP updates. ESJ Subbasin will continue to coordinate with Cosumnes Subbasin on boundary flows across Dry Creek as well as sustainable management criteria developed in the two subbasins as their GSP work progresses.
92 John Fio
EKI on behalf of Cosumnes Subbasin GSA Working Group

3.2.6 Depletion of Interconnected Surface Water
"Depletion of Interconnected Surface Water” states that depletions are considered an Undesirable Result (UR) if the depletions significantly and unreasonably reduce surface water flow or levels and adversely impact beneficial uses of the surface water within the ESJ Subbasin. However, the contribution of these reductions to the cumulative depletion in downstream flows and potential impacts to Cosumnes Subbasin recharge should also be considered, given the important nature of this boundary condition.

Interconnected Surface Water See Master Response 2 - ISW. 93 Rodney [email protected]
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.2.1.1 Sacramento Solano Subbasin (Bulletin 118 Basin Number 5-021.66) Mechanics - Text Comment addressed in text. 94 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin …, while eastern western portions of San Joaquin County and City of Stockton, and western portions of Calaveras and much of Stanislaus County ies, lie in neighboring subbasins. Mechanics - Text Edited text in Section 1.2.1.1: The cities of Lodi, Escalon, Manteca, and Ripon are contained entirely within the Subbasin, while western portions of San Joaquin County and the City of Stockton, and eastern portions of Calaveras and Stanislaus counties, lie in neighboring subbasins or outside of groundwater subbasins altogether.
95 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Well Density Statement is out of context. Paragraph is talking about density of supply wells and the DWR criteria is not applicable to locations chosen by well owners. Monitoring wells are subject to the DWR criteria, which is a different topic. Mechanics - Text Edited text in Section 1.2.1.1 to remove sentence related to monitoring well density. 96 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 1-12 to -14 The download of data for these maps should have included data tables, including number of wells per section, depths, and other information. How were these data addressed in the GSP? Mechanics - Graphics Comment noted. This information is beyond the scope of the GSP. Data used in the figures can be obtained through DWR's Well Completion Report Map Application. 11 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 97 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.2.2Water Resources Monitoring and Management Programs Online System for Well Completion Reports (OSWCR) seems to be oriented to licensed well drillers but has a link to: Well Completion Report Map Application which provides links to PDFs. In addition, the SGMA Data Viewer application provides links to PDFs of well completion reports. Clarifying Edit Comment noted. OSWCR is DWR's database of well completion reports. DWR's SGMA data viewer uses records from OSWCR to display wells with downloadable completion report PDFs. 98 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.2.2.4Land Subsidence Monitoring
The paragraph should acknowledge that DWR (2014) listed the Eastern San Joaquin Subbasin as having a medium to high potential for subsidence due to long-term declining groundwater levels. (Summary of Recent, Historical, and Estimated Potential for Future Land Subsidence in California) Subsidence Comment noted. Continued lowering of groundwater levels may cause subsidence, though there are no historical records of impacts in the Subbasin. 99 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.2.2.4Land Subsidence Monitoring
The paragraph starts with a USGS heading, which only applies to the subsequent paragraph. The paragraph refers to Plate Boundary Observatory (PBO) GPS stations, which are operated by UNAVCO, and refers to station (P781), which was removed from the program in 2014. The text does not acknowledge other PBO stations in the vicinity of the subbasin, including P256 – Brentwood, P257 – Tracy, P273 – Lodi, P274 – Elk Grove, P275 – Galt, and P309 – Linden.The USGS study area may have utilized the PBO stations but the study addressed much of the San Joaquin Valley further south.

Subsidence
1) The ESJGWA supports the use of existing monitoring stations and InSAR data currently referenced in the GSP for the evaluation of subsidence, and believe the conditions of the subbasin do warrant the creation of new subsidence stations at this time. The GSP has been updated to reference the UNAVCO continuous GPS stations in Section 1.2.2.4 (Land Subsidence Monitoring): Reporting since 2004, the UNAVCO (formerly University Navigation Satellite Timing and Ranging or NAVSTAR Consortium) Plate Boundary Observatory network consists of a network of about 1,100 continuous global positioning system (CGPS) and meteorology stations in the western United States to measure deformation resulting from the constant motion of the Pacific and North American tectonic plates in the western United States. Stations located within the Subbasin contain data from at least 2006 to current and include station P309 located east of Linden and station P273 located west of Lodi. Other stations are also available in nearby Subbasins. Subsidence analyses have also been conducted using satellite-based methods over limited time periods, as described below. 2) The paragraph under the USGS heading referring to the nonoperational station P781 was deleted with the expansion of the description of the UNAVCO data. 100 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.2.2.4Land Subsidence Monitoring
The NASA JPL processed dataset spans from May Spring of 2015 to April Summer of 2017 (CA, DWR, 2019). Subsidence Comment noted. Multiple sources refer to the NASA JPL dataset spanning Spring 2015 to Summer 2017. 101 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.3.1Beneficial Uses and Users in the Basin
Text says "…. approximately 1,000 unique domestic, public, and production wells in the Subbasin." but Figure 2-4 shows 6,800 GAMA sites and DWR (2014) says 19,176 wells total. Clarifying Edit The total number of production wells in the Subbasin is not known. Edited Section 1.3.1 (Beneficial Uses and Users in the Basin) to delete sentence mentioning 1,000 wells. 102 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

1.3.5Inter-basin Coordination
To date, there has been at least one meeting between representatives of the GWA and the neighboring basins of Cosumnes, Modesto, Subbasin and Tracy Subbasins to initiate this process. Clarifying Edit Edited text in Section 1.3.5 (Inter-basin Coordination): To date, there have been initial meetings between representatives of the ESJGWA and the neighboring subbasins to initiate this process. 103 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.2Regional Geologic and Structural Setting
The Sierra Nevada Mountain Range, east of the Central Valley, is comprised of pre-Tertiary igneous and metamorphic continental rocks. Clarifying Edit Edited text in Section 2.1.2 (Regional Geologic and Structural Setting): The Sierra Nevada Mountain Range, east of the Central Valley, consists of pre-Tertiary igneous and metamorphic continental rocks. 104 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.3Geologic History Middle to late Tertiary would be more like 23 to 60 or 65 million years Clarifying Edit Text is correct. The middle to late tertiary period is closer in time to now than the earlier portion of the tertiary period, so the ~3-30 million years ago in the text is correct. 105 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.4.2Major Hydraulic Features
Acre-feet per day and cubic feet per second are flow rates, not volumes Clarifying Edit Edited text in Section 2.1.4.2 (Major Hydraulic Features) on Page 2-12 from "volumes" to "flows". 106 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.5Geologic Formation and Stratigraphy
Generally, eastside formation material originates as from continental deposits from the Sierra Nevada and westside formation material originates as from the continental deposits from the Coastal Ranges (marine). Clarifying Edit Edited text in Section 2.1.5 (Geologic Formations and Stratigraphy). 107 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 2-16Geologic Map
The Tulare Formation is listed in the legend but is not present on the map. The Sacramento Regional Geology Map (RGM) does not include the Tulare Formation in its Explanation and the dark orange shading on the San Francisco-San Jose RGM is labeled Tvs for the Valley Springs Formation. The Tulare Formation originates from the Coast Range and would not crop out within the ESJ Subbasin.

Mechanics - Graphics The Tulare Formation was taken out of the legend. This is confirmed by both of the RGMs the commenter cited. 108 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Table 2-2Generalized Stratigraphic Column
See comment above. The explanation summary for the San Francisco-San Jose RGM shows that the Tulare Formation is older than the Turlock Lake Formation. The Geologic Map Explanation indicates the upper Tulare Formation and lower Turlock Lake Formation could be interbedded at depth within the center of the Central Valley. Clarifying Edit According to the San Francisco-San Jose RGM, the Tulare Fm is generally older than the Turlock Lake Fm and likely interbedded in the San Joaquin Valley, as the commenter noted. The Rock Characteristics and Environment column describes the continental basinal equivalent formations from recent to PlioPleistocene. These descriptions can be revised and clarified in future iterations of the GSP. 109 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.5.1.2Ione Formation
The Ione Formation is an important source of both sand and clay but these products are separate. "Kaolinite sand" is not possibly since kaolinite is a clay mineral and not durable enough to be sand. Clarifying Edit Deleted sentence in Section 2.1.5.1.2 (Ione Formation) referring to Ione sand. 110 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.5.1.5Laguna Formation
Which studies suggest that the Pliocene-Pleistocene Tulare Formation (younger) could be part of the middle Pliocene Laguna Formation (older) or occur between the Laguna Formation and the Miocene-early Pliocene Mehrten Formation (older still)? Clarifying Edit Removed in response to comment. 111 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.5.1.6Turlock Lake Formation
According to the USGS (Faunt, 2009), "… the western San Joaquin Valley generally is finer-grained and is underlain by the Corcoran Clay Member of the Tulare Formation (hereafter referred to as the Corcoran Clay)." and "This confining unit is a stratigraphic unit, the Corcoran Clay Member of the Tulare Formation (referred to in this report as the Corcoran Clay." Bold added for emphasis. A search of the report (Faunt, 2009) did not find any reference to the Turlock Lake Formation.

Clarifying Edit Faunt 2009 is not cited in Chapter 2 in reference to the Turlock Lake Formation. 112 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 2-18: Base of Fresh Groundwater Elevation Contours and Stockton Fault Only a single sentence for the figure. Additional text should be added to explain the significance of the information. Basin Setting Added text to reference other sections for discussion of base of fresh water: This feature also influences the location, depth, and thickness of the “base of the fresh water”, as shown below in Figure 2 18. The base of fresh water is discussed further in Sections 2.1.7 and 2.1.8.2. 12 ESJ Public Comments Response
Comment # Commenter Commenter Organization Section, Figure, or Table Number Comment Category Response to Comment 113 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 2-20: Hydrogeologic Crosssections A-A' and BB' - Cross sections are too small, even printed on 11 x 17" paper, as the well labels are not legible. Scale of 0.36 to 0.45 inch per 1000 feet is not reasonable. The Stockton Fault is not depicted or located on Sections D-D' and E-E'.- Page 2-38, first paragraph refers to "well screen interval (shown in red)." but the interval is not 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.

Basin Setting
The level of detail in the GSP is appropriate for a conceptual model of the Subbasin, and the number of cross-sections already exceeds SGMA requirements. Additionally, the well logs for wells shown in the cross-sections are public for detailed review. The representation of Corcoran Clay cross-sections is based on previous work from DWR and is consistent with the latest released version of C2VSim. The image resolution was increased to help with zooming in on small areas. 114 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 2-21: Hydrogeologic Crosssections C-C' and DD' - Cross sections are too small, even printed on 11 x 17" paper, as the well labels are not legible. Scale of 0.36 to 0.45 inch per 1000 feet is not reasonable. The Stockton Fault is not depicted or located on Sections D-D' and E-E'.- Page 2-38, first paragraph refers to "well screen interval (shown in red)." but the interval is not 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.

Basin Setting
The level of detail in the GSP is appropriate for a conceptual model of the Subbasin, and the number of cross-sections already exceeds SGMA requirements. Additionally, the well logs for wells shown in the cross-sections are public for detailed review. The representation of Corcoran Clay cross-sections is based on previous work from DWR and is consistent with the latest released version of C2VSim. The image resolution was increased to help with zooming in on small areas. 115 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 2-22: Hydrogeologic Crosssection E-E'
- Cross sections are too small, even printed on 11 x 17" paper, as the well labels are not legible. Scale of 0.36 to 0.45 inch per 1000 feet is not reasonable. The Stockton Fault is not depicted or located on Sections D-D' and E-E'.- Page 2-38, first paragraph refers to "well screen interval (shown in red)." but the interval is not 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.

Basin Setting
The current model thickness is consistent with the DWR’s C2VSim model and is an area for enhancement in model refinements. New monitoring wells shown in Figure 4-3 will help refine the model thickness through new information about the aquifer on the eastern side of the Subbasin. Comment noted for follow up in next round of model refinements and updates. 117 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin Figure 2-21: Hydrogeologic Crosssection C-C'
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.

2.1.9.1Zones within Principal Aquifer
What about the stratigraphy of the Shallow and Intermediate Zones? Why are is the stratigraphy of the deeper than Deep Zone referenced when few wells are deeper than 500 feet? Basin Setting The level of detail in the GSP is appropriate for a conceptual model of the Subbasin. 119 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.9.1.1Shallow Zone
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? Clarifying Edit The level of detail in the GSP is appropriate for a conceptual model of the Subbasin. The image resolution of the cross-sections was increased to help with zooming in on small areas. 120 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.9.1.3Deep Zone
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? Clarifying Edit The level of detail in the GSP is appropriate for a conceptual model of the Subbasin. The image resolution of the cross-sections was increased to help with zooming in on small areas. 121 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.9.1.4Limited Aquitards
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.

Clarifying Edit Comment noted. Discussion in Section 2.1.9.1.4 is discussing the northern portion of the Corcoran Clay in general (not specific to the Subbasin), while Cross- Section E-E' only shows one small area of the Subbasin. 122 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.9.1.4Limited Aquitards For the 11 x 17" print, that's 0.004 to 0.06 inches Clarifying Edit The level of detail in the GSP is appropriate for a conceptual model of the Subbasin. The image resolution of the cross-sections was increased to help with zooming in on small areas. 123 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.9.2Aquifer Characteristics and Groundwater Quality
Camanche Reservoir is located at the northeastern corner of the subbasin and Oakdale is located at the southeastern corner, ~30 miles apart. Clarifying Edit Edited text in Section 2.1.9.2 (Aquifer Characteristics and Groundwater Quality): The thickest sand and gravel sequences ranged from 500 to 700 feet near the Stanislaus River, south of Woodward Reservoir and northeast of Oakdale. 124 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

2.1.9.2.1Aquifer Parameters and Production Zone Well Capacities Production Zone is new subdivision to the Principal Aquifer. How does it relate to the Shallow, Intermediate and Deep Zones? Clarifying Edit The production zone is not a new subdivision of the principal aquifer. As described in Section 2.1.9 (Principal Aquifer): The Eastern San Joaquin Subbasin HCM has one principal aquifer that provides water for domestic, irrigation, and municipal water supply and that is composed of three water production zones.

These three water production zones are the Shallow, Intermediate, and Deep Zones. 125 Rodney Fricke
GEI on behalf of Sacramento County GSA - Cosumnes Subbasin

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Manteca City CouncilJuly 19, 2022

Manteca City Council
July 19, 2022